EPA Removes Exemptions for Emissions During Startup, Shutdown and Malfunctions
On May 22, 2015, USEPA issued a final rule that clarifies their position on exemptions and affirmative defenses to emissions during startup, shutdown and malfunction events. (“SSM”). This rule is a response to a petition filed by Sierra Club to require EPA to invalidate certain provisions of state implementation plans (“SIPs”), including Ohio’s, following the D.C. Circuit’s recent decision that Clean Air Act (“CAA”) emissions limits must apply “continuously.”[1] In this rule,
Environmental Law Update - EPA Proposes New Guidelines Governing Disposal of Dental Amalgam
Under a recently proposed rule, dental offices would be required either to not handle dental amalgam, or else do baseline and annual monitoring for mercury, as well as install amalgam separators and follow handling guidelines. In an attempt to limit the release of mercury from dental amalgam, on September 25, 2014, EPA proposed technology-based pretreatment standards, for any water drained to public sewers. This rule will impact dental offices of any size that currently use a
