Shouldn’t Plant Washington have conducted a case-by-case MACT analysis?
MACT, which stands for Maximum Achievable Control Technology, addresses emissions of hazardous air pollutants (HAPs) such as acid gases and metals. After Plant Washington’s air permit application was submitted to the Georgia Environmental Protection Division (EPD) in January 2008, the U.S. Court of Appeals (District of Columbia Circuit) vacated EPA rules regarding mercury, including the Clean Air Mercury Rule (CAMR). As a result of that court decision, the main boiler at Plant Washington was required to conduct a case-by-case MACT analysis, which also was submitted to the Georgia EPD as part of the air permit application process.
