PC 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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Poking Holes In Your Electronic Compliance Report
Posted: May 24th, 2017
So maybe you’re one of the many facilities who are now subject to electronic reporting requirements under a 40 CFR Part 60 (NSPS) or Part 63 (NESHAP) rule. Perhaps even this past year was your first time having to submit your semi-annual or annual compliance report…
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CISWI or PC NESHAP Compliance Demonstration Timelines and Milestones Considerations
Posted: May 8th, 2017
If you’re like me, it’s hard to believe that it is May already. Time seems to move faster every time I stop and think about it. Why is this relevant? The compliance date for 40 CFR Part 60, Subpart DDDD [Emissions Guidelines and Compliance Times for Commercial and…
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Getting Your CMS House in Order
Posted: May 4th, 2017
We are all wondering how the proposed cutbacks at U.S. EPA could influence the day-to-day compliance obligations at facilities using continuous monitoring systems (CMS). The organizations that may be affected the most by the anticipated U.S. EPA cutbacks are the state…
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