The EPA is at it yet again, this time tightening emission limits for Sewage Sludge Incineration (SSI) units. The NAM and several other business groups are concerned with the manner in which EPA is proposing to address periods of startup, shutdown or malfunction (SSM) in this rulemaking and several other recently proposed and final rules for combustion units. To that end, the coalition urged the Environmental Protection Agency (EPA) to withdraw the SSI proposed rule in comments it filed this week with the agency.
In the proposal, the EPA applies the same emission limits during startup and shutdown as during normal operating periods. In many cases, it may be that combustion units emit a higher concentration of pollutants during these startup and shutdown periods. In addition, the EPA asserts that it is not required to account for malfunctioning equipment in setting emission standards. The agency continues to set dangerous precedent by prescribing standards that real world equipment is not able to meet. These standards impose undue regulatory burden and compliance costs on manufacturers which in turn impacts their ability to compete in the global marketplace.