Proposed Industrial Cleaning Solvents RACT Rule is Out
Posted: August 1st, 2017
Does your facility use industrial cleaning solvents? If so, you should be aware that the Pennsylvania Department of Environmental Protection (PADEP) has proposed a new rule, 25 Pa. Code 129.63a – Control of Volatile Organic Compound (VOC) Emissions from…
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Navigating State-Specific Air Toxics Programs
Posted: July 31st, 2017
Hazardous Air Pollutants (HAP), also commonly referred to as Toxic Air Pollutants (TAP) or air toxics, are those pollutants that are known or suspected to cause cancer or other serious health effects, such as reproductive effects, birth defects, or adverse […]
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U.S. EPA Approves PADEP’s 2006 SIP Revision Via Direct Final Action
Posted: July 26th, 2017
It’s Friday, July 7,2017 and I’m reading Federal Register Vol. 82, No. 129 (my life is very exciting). As I stand here reading, I’m 37 years, 8 months, and 7 days old. Page 31464 of Federal Register Vol. 82, No. 129 includes a notice indicating that the…
Read articlePC MACT Carousel
Posted: July 25th, 2017
Today (July 25th) is National Carousel Day. Ironically, it is also the expiration date of the original 1-year additional compliance alternative for sources required to use a hydrogen chloride (HCl) continuous emission monitoring system (CEMS) to demonstrate compliance…
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Reasonably Available Control Technology (RACT 2) Post-Compliance Deadline Happenings
Posted: July 21st, 2017
Major sources of NOx and/or VOC (i.e., potential to emit greater than or equal to 100 tons per year of NOx and/or 50 tons per year of VOC) subject to the Pennsylvania Reasonably Available Control Technology (RACT 2) rule had to demonstrate compliance with the applicable
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Vacatur of NSPS Subpart OOOOa Stay and More Litigation on the Horizon
Posted: July 14th, 2017
(UPDATE 7/14/17): On July 13, 2017, the U.S. Court of Appeals for the D.C. Circuit granted the U.S. EPA a 14-day extension to comply with the court’s earlier decision vacating U.S. EPA’s stay of certain 40 CFR Part 60, Subpart OOOOa (Subpart OOOOa) provisions. The extension…
Read articleSPCC Plans – Some Pitfalls of Oil Spill Prevention, Control, and Countermeasure Compliance
Posted: July 10th, 2017
Does your facility have a Spill Prevention, Control and Countermeasure (SPCC) Plan? When is the last time you reviewed it? Is it up to date? Have you kept track of all minor facility changes that materially affect potential discharges? Are you on track to complete…
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Further Delay of Implementation of Certain NSPS Subpart OOOOa Requirements
Posted: June 29th, 2017
On June 5, 2017, the U.S. Environmental Protection Agency (U.S. EPA) granted reconsideration and stayed the effectiveness of certain fugitive emissions, pneumatic pump, and Professional Engineer (P.E.) certification requirements of 40 CFR Part, 60 Subpart-OOOOa Standards of Performance…
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Boiler MACT Update and Preparing for your July Report
Posted: June 20th, 2017
Things have been fairly quiet with respect to Boiler MACT lately…or so it may seem. With the next semiannual report due by July 31, here’s an update on what you need to know…
Read articleRefinery MACT I – Do You Really Know What Your DAHS is Doing?
Posted: June 15th, 2017
By now, I’m sure you have familiarized yourself with 40 CFR Part 63, Subpart CC – National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries (Refinery MACT I) and you have (hopefully) developed a compliance strategy for the new requirements that apply…
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