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RACT Discussion

RACT Discussion . Is RACT, as your state implements it, the application of a technology, the application of a technology and an emission limit, or an emission limit? If it is the application of a technology, does RACT include operating parameters?

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RACT Discussion

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  1. RACT Discussion • Is RACT, as your state implements it, the application of a technology, the application of a technology and an emission limit, or an emission limit? If it is the application of a technology, does RACT include operating parameters? • Does your state have a policy that sets RACT using a cost per ton basis? If so, have your cost/ton limits increased with the increasing stringency of the ozone standard? • Does your state have another method of implementing the economically feasible criteria of RACT?

  2. RACT Discussion • Does your state have a single RACT limit applied on an annual basis or does your state have additional or alternate RACT requirements for ozone season? Are VOC and NOx different in this respect? • Do you apply RACT on a case by case basis, or group by equipment type or by fuel? • What percentage of your sources, subject to RACT, are above 25 tons/year, 50 tons/year, 100 tons/year? Does this affect how RACT is applied to them?

  3. RACT Discussion • Does your state have RACT limits averaged on shorter timeframes than 30 day rolling average? Longer timeframes? • Does your state have RACT limits for a source that exclude start up, shut down, low capacity or provide other exclusions? • If a source is currently meeting a very stringent limit does your state automatically consider that limit RACT? Would similar sources be expected to meet the same limit? Would it matter if the limit was the result of an enforcement action?

  4. RACT Discussion • Are your RACT limits primarily contained in regulation, state operating permits, or consent orders? Are there other types of enforceable documents that could contain RACT limits? • Is your state on track to submit the July 2014 RACT SIP on time? • Does your state believe that RACT can simply mean buying the controls ... or do you believe that RACT means not only buying the controls, but also running those controls when needed to address the ozone problem?

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