The rules don’t matter at this point in the governance cycle, attempts to be clever will be ignored by the federal government. Start tearing up the rails used for delivery of coal to these plants, and it solves the problem of illegal DOE must run orders for coal generators that have reached retirement and have received grid operator approval to shutdown. No coal supply, no way to satisfy an illegal order.
Be prepared to switch gears and approach an adversary at their level. Legality when the law matters, direct action when the law doesn’t matter.