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New EPA Air Toxics Rule Afflects Facilities with TEG Dehydrators

The Energy Law

prior to January 3, 2007), initial notification is due by January 3, 2008. the date of a performance evaluation; the planned date of a performance test; and startup, shutdown, and malfunction reports). 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”). 2008), and a 2014 decision, in which the D.C. 33840 (June 12, 2015).