In a letter to Mr. Burt Cassidy dated June 14, 2018, EPA’s Office of Air Quality Planning and Standards (OAQPS) rejected an argument in the context of plantwide applicability limits (PALs) that a unit should be considered “new” for purposes of determining baseline actual emissions (BAE) if the BAE period fell within 2 years of initial startup of the unit. Instead, OAQPS states that a unit is “new” only if, at the time of the permit application, it is within 2 years of unit startup.
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