SSM Periods

News & Analysis as of

EPA nixes state exemptions on excess CAA emissions

Affirmative defenses commonly relied upon by facility operators to avoid civil and administrative penalties for violations of air emissions limitations during periods of facility startup, shutdown or malfunction (“SSM”) may...more

EPA Issues SIP Call to Eliminate SSM Defense

EPA has issued a final rule that requires 36 states to revise their State Implementation Plans to eliminate a well-known and often-used Clean Air Act defense for excess emissions. While specific elements of the defense...more

Nothing but Nonsense in New EPA Rule on Emissions

In response to a petition for final rule-making filed by the Sierra Club, the U.S. Environmental Protection Agency issued on May 22, 2015, its final action requiring 36 states to revise their state implementation plans...more

Startup, Shutdown, and Malfunction — No Longer Any Automatic Exemptions or Affirmative Defenses

Last week, EPA finally responded to the Sierra Club’s petition requesting that it eliminate exemptions and defenses for excess emissions resulting from startup, shutdown, or malfunction events. EPA concluded that it needed to...more

EPA Requires States to Revise and Tighten Startup, Shutdown, and Malfunction Regulations

Action Item: In response to pressure from environmental groups, EPA has removed Clean Air Act affirmative defenses previously available to the regulated community for startups, shutdowns, or malfunctions (SSM Rule). The...more

EPA Reverses Course on Malfunctions

EPA proposes eliminating all startup, shutdown and malfunction affirmative defense provisions from SIPS. On September 17, 2014, the United States Environmental Protection Agency (EPA) issued a supplemental notice of...more

EPA Tightens Air Regulations for Emissions During Shutdown, Startup and Malfunction

Introduction - Of particular concern to electric utilities and other major sources operating under Title V permits, on February 12, 2013, the U.S. Environmental Protection Agency (“EPA”) initiated steps under the Clean...more

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