Condensed EPA commentary: SIP rules must ensure that emissions during startup conditions are minimized. We believe this could be addressed by adding rule text establishing appropriate time limitations on gas turbine startup, requiring sources to minimize time and emissions during startup, and demonstration in the staff report that the rule minimizes emissions during startup.
New section 3.2.3 places no time limitation on opacity between 20% and 40% for gas turbines except as defined in the District
permit pursuant to new section 2.5.
This is inconsistent with long-standing national policy on excess emissions.
From Federal Register (http://www.regulations.gov/)
Craig Thiry, The Avogadro Group (CT-TAG)