The non-applicability action type (NN) should be used for the Regions to report NSR/PSD investigations at facilities that turned out not to be subject to NSR/PSD. NN stands for: 'EPA NSR/PSD Non-Applicability Determination Investigation'.
The proper entry of a non-applicable NSR/PSD investigation is as follows. If a Region initiates a NSR/PSD investigation, and it turns out the facility is not subject to NSR/PSD, the Region should enter the activity twice:
- Using the EI investigation code to document the work, against an appropriate air program code (i.e., Title V or SIP), and
- Enter the non-applicability action type (NN) to document non-applicability.
Entering the investigation this way will ensure it is counted in the metric: "All Federal Civil Investigations" metric as well as in the metric: "National Priority NSR/PSD Investigations".
Please contact Betsy Metcalf at 202-564-5962 or David Sprague at 202-564-4103 if you have any questions about this guidance.