Startup, Shutdown and Malfunction Emissions – EPA Final Action

Is your facility or state affected by the EPA’s Startup, Shutdown and Malfunction Emissions final action? If your state is affected, this could require a change to your facility operations, to your DAS configuration, and to your reporting requirements.

The EPA issued a final action on May 22, 2015 to ensure states have implementation plans in place for emissions to be fully compliant with the Clean Air Act (CAA) during periods of Startup, Shutdown and Malfunction (SSM). In the rule, there are 36 states that are required to correct specific SSM provisions and submit a State Implementation Plan (SIP) revision that addresses this action by November 22, 2016.

In the past, there have been some exemptions from emission limits during periods of SSM that have been approved by the EPA and adopted into SIPs. This final action by the EPA was issued, in part, as recent court decisions have challenged these SSM exemptions to the CAA (which have been allowed as affirmative defense provisions in the past), stating they cannot be allowed in SIPs.

If you are not sure how this rule is going to affect you, or if you need help ensuring that you will maintain compliance, contact Air Tox to see how our staff of experts can help you: info@airtoxenviro.com.