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SSM Periods Exemptions

Williams Mullen

Air Program Malfunction Exemption Nixed, But Not Agency Discretion

Williams Mullen on

Virginia’s State Air Pollution Control Board (“Board”) recently amended its regulations to remove the long-standing malfunction exemption available to regulated sources of air pollution for violations of emission limits and...more

Foley Hoag LLP - Environmental Law

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

K&L Gates LLP

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

K&L Gates LLP on

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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