Utilities Should Act Now on EPA Regs for Start-Up and Shut-Down

摘要

Earlier this year, in response to a Sierra Club petition (Sierra Club v. EPA 2008), the EPA proposed to eliminate startup, shutdown and malfunction (SSM) air emissions exemptions in utilities' operating permits. The final rules are to be issued May 15, 2014. Because the exemption for startup, shutdown and malfunction was written into numerous federal rules, State Implementation Plans and individual permits, implementing this change is a massive undertaking.