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printech, May, 2002
Re: EPA Position on EMSs


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From:Tom Linder(TLinder@iccnet.com)
Date: Tue, 21 May 2002 08:22:02


There are two possible ways in which EMS could be applied. 1. Enforcement. If you have an EMS, does that count as an SEP (Supplemental Environmental Project)? Can it help reduce the penalty? 2. Regulatory Relief. In theory, if you have an EMS, you should be entitled to some regulatory relief. In reality, there is not statutory basis for this, so it is tough to pull off. EPA has inserted EMS stuff in the Iron and Steel Effluent Guideline and it will be in the upcoming Concentrated Animal Feedlot Operations (CAFO) rule, but I have not heard a lot of noise about any relief in exchange for EMSs. Hope that helps. Tommy Linder



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