Dave and Scott,
 
I saw an article mentioning that EPA published a draft guidance (66 Fed. Reg. 52,403) clarifying the definition of "stationary source" to allow heat/power co-generation facilities to be treated as separate sources from the underlying host facility (e.g., a manufacturing plant) for NSR purposes.
 
Although the focus of the draft guidance is on cogeneration facilities, I suppose that there might be some general language in there that could clarify the single-source analysis as it pertains to the ancillary equipment at our plants for which no separate BACT analysis was done.  Are either of you familiar with the new draft guidance (or with anything else that we could use to bolster our position on this issue)?
 
Many thanks,
 
Ryan



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