The OOOOa Initial Compliance Period Began! Time is Running Out.
Posted: October 3rd, 2016
The New Source Performance Standards (NSPS) at 40 CFR Subpart OOOOa (Subpart OOOOa) became effective on August 2, 2016. This means that owners and operators with affected sources must be in compliance with the Subpart OOOOa standards starting…
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Electronic Reporting for the Secondary Aluminum Industry
Posted: September 26th, 2016
As Chuck described in his January blog, the Subpart RRR amendments include provisions requiring that performance test data to be electronically submitted through the U.S. Environmental Protection Agency (U.S. EPA) Electronic Reporting Tool (ERT). While E-reporting…
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Proposed Information Collection Request for the Plywood and Composite Wood Products NESHAP and Implications for the Industry
Posted: September 22nd, 2016
On September 8, 2016, the U.S. Environmental Protection Agency (U.S. EPA) published a proposed Information Collection Request (ICR) for the Plywood and Composite Wood Products (PCWP) National Emission Standards for Hazardous Air Pollutants…
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Boiler MACT Vacatur and Remand: The Details Unfold
Posted: August 29th, 2016
As I wrote about in my last post, the United States Court of Appeals for the District of Columbia Circuit (“D.C. Circuit Court” or “Court”) issued an opinion on July 29, 2016 regarding three related rules for boilers, process heaters, […]
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2016 Chemical Data Reporting in Full Swing
Posted: August 29th, 2016
In our February blog post “Brace Yourself – 2016 Chemical Data Reporting is Coming”, we talked about 2016 being a reporting year in the Toxic Substances Control Act (TSCA) Chemical Data Reporting (CDR) rule cycle. This report is due every four years and requires…
Read articleRACT 2 – T Minus 2 Months 2 Go
Posted: August 24th, 2016
You have likely heard about RACT 2 at this point, but you may not have yet acted on what you’ve heard. Human nature is bent toward procrastination. We get it and that’s part of why we’re here. The proposal deadline for RACT 2 submittals is quickly approaching whether you’ve…
Read articleDon’t Fall out of Compliance with RACT 2
Posted: August 18th, 2016
Summer is practically over, fall is almost here, and Halloween costumes are already out. Although your local retail stores are prepared for October, are you? Your facility’s RACT 2 proposal is due in nearly two months on October 24, 2016. If you followed…
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D.C. Circuit Court Issues Remand and Vacatur of Certain Boiler MACT and CISWI Provisions
Posted: August 9th, 2016
On July 29, 2016, the United States Court of Appeals for the District of Columbia Circuit (D.C. Circuit Court) issued a decision regarding three rules for boilers, process heaters, and incinerators…
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Coming Summer 2019: Benzene Fenceline Monitoring Data Available to the Public
Posted: July 27th, 2016
A few weeks ago, U.S. EPA hosted a webinar to discuss the data management system for the Refinery Sector Rule – Benzene Fenceline Monitoring (BFM) Rules. As part of this system, U.S. EPA will be posting all of the BFM data submitted through the Compliance and Emissions Data Reporting Interface…
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Update on the Cross State Air Pollution Rule – Pennsylvania and Beyond
Posted: July 21st, 2016
” Many of you may have forgotten about the Cross State Air Pollution Rule (CSAPR) and its status. CSAPR is one of those “on-again/off-again” rules that U.S. EPA (EPA) has developed. As a reminder, CSAPR replaced the Clean Air Interstate […]
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