Environmental Notes - June 2015

Williams Mullen

In this Issue:

- EPA Issues SIP Call to Eliminate SSM Defense

- EPA and Corps Define “Waters of The United States”

- Frequent Questions: EPCRA 313

- Generators Need to be Vigilant About TCLP Sampling Protocol

- EPA Proposes to Redesignate Charlotte Area to Attainment for Ozone Standard

- South Carolina Court Limits CERCLA Remedies

- Excerpt from 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 differ from state-to-state, the defense generally offers protection from enforcement when manufacturers and other sources exceed emission limits during periods of startup, shutdown, or malfunction (“SSM”). The idea behind the defense is that excess emissions during these periods are often unavoidable, and it would be unfair to impose penalties under such circumstances. Virginia, South Carolina and North Carolina have long had such a defense in their air regulations and their approved SIPs.

Please see full Newsletter below for more information.

LOADING PDF: If there are any problems, click here to download the file.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Williams Mullen | Attorney Advertising

Written by:

Williams Mullen

Williams Mullen on:

Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide
- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.