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New EPA Air Toxics Rule Afflects Facilities with TEG Dehydrators

The Energy Law

If a TEG dehydration unit meets the exemption criteria, the owner/operator must maintain records of the applicable throughput or emissions determinations. The owner/operator must submit an initial notification to the delegated state agency and the EPA. prior to January 3, 2007), initial notification is due by January 3, 2008.

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EPA’s Shifting Guidance on Startup, Shutdown, and Malfunction Defenses in State Implementation Plans and Its Effect in Louisiana

The Energy Law

On September 30, 2021, the EPA once again signaled a policy change on what provisions a state can include in its Clean Air Act State Implementation Plan (“SIP”) for exemptions and affirmative defenses during periods of startup, shutdown, and malfunction (“SSM”). 33840 (June 12, 2015). LAC 33:III.507.J.1. 2020 SSM SIP Policy Memorandum.