Affirmative Defense is Vacated for the Cement Industry

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Courtesy of All4 Inc.

I wrote a blog back in February that was intended to raise the awareness level of the cement industry regarding new requirements for their MACT operations and maintenance (O&M) plans.  As part of addressing action items related to that blog, many owners/operators that are affected by 40 CFR Part 63, Subpart LLL – National Emission Standards for Hazardous Air Pollutants (NESHAP) From the Portland Cement Manufacturing Industry (Subpart LLL) may have already started the process of converting their startup, shutdown, and malfunction plan (SSMP) into an O&M Plan or a Malfunction Plan that specifically addresses affirmative defense. 

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