U.S. EPA Issues Final Rule Enforcing 2015 Ban on State Exemptions for Startup, Shutdown and Malfunction Emissions
Vorys Energy
JANUARY 20, 2022
EPA’s policy on State regulatory exemptions for air emissions during periods of facility startup, shutdown and malfunction (SSM). EPA’s reinstatement of a 2015 policy that SSM exemption and affirmative defense provisions in a State Implementation Plan (SIP) will generally be viewed as inconsistent with Clean Air Act (CAA) requirements, U.S.
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