Beginning April 16,2015, energy companies with coal- and/or oil-fired electric generating units (EGUs) must be in compliance with a major EPA rule-the mercury and air toxics standards (MATS). The MATS was issued together with EPA's NSPS also for coal- and oil-fired EGUs (Utility NSPS). The final rules were published February 16, 2012, but there has been lingering uncertainty regarding requirements during periods of start-up and shutdown. In fact, it took the EPA until November 19, 2014, to publish a follow-up rule clarifying how compliance may be achieved during start-up and shutdown. While shutdown is covered in the rule, the bulk of the action is directed toward start-up. EGU operators are provided with two compliance alternatives. In both cases, compliance during start-up is achieved through a work practice standard-rather than by complying with numeric emissions limits-based on the use of clean fuel. Once the start-up period ends, EGU operators must achieve the numeric emissions limits in MATS/ Utility NSPS.
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