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Title: Plan ahead to protect operational flexibility

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.
Authors:
Publication Date:
OSTI Identifier:
78042
Resource Type:
Journal Article
Resource Relation:
Journal Name: Pollution Engineering; Journal Volume: 27; Journal Issue: 5; Other Information: PBD: May 1995
Country of Publication:
United States
Language:
English
Subject:
54 ENVIRONMENTAL SCIENCES; 29 ENERGY PLANNING AND POLICY; CLEAN AIR ACTS; IMPLEMENTATION; INDUSTRIAL WASTES; AIR POLLUTION CONTROL; PERMITS