09.2014
|
Lawyer Publications
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09.2014
|
Lawyer Publications
The debate over startup, shutdown and malfunction (SSM) emissions cuts to the heart of a core dispute between regulators and the regulated: EPA believes that emissions during SSM events are “phases of normal plant operation.” Refiners - and the rest of the regulated community - believe that SSM events are unavoidable outliers, which should not be subject to all applicable emission limits. To read more, click here.
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