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Plan ahead to protect operational flexibility

Journal Article · · Pollution Engineering
OSTI ID:78042
Freedom to change or modify facility operations in response to changing market forces is crucial to staying in business. To protect this freedom, EPA included operational flexibility provisions in the operating permit rule, 40 CFR 70, which implements Title 5 of the 1990 Clean Air Act Amendments (CAAA). Recently, EPA proposed new operational flexibility provisions that may narrow the category of changes a facility could make without a permit modification. EPA`s proposal also contains clarifications of other operational flexibility provisions. Although EPA`s proposed revisions may be changed by the time the rule is finalized, understanding them and the reasoning behind them provides valuable insight to developing a favorable Title 5 permit. EPA`s proposed operational flexibility provisions could restrict changes a facility could make without a permit modification. Understanding the reasoning behind the revisions is key to developing a favorable Title 5 permit.
OSTI ID:
78042
Journal Information:
Pollution Engineering, Journal Name: Pollution Engineering Journal Issue: 5 Vol. 27; ISSN PLENBW; ISSN 0032-3640
Country of Publication:
United States
Language:
English

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