The Ethylene MACT – An Air Quality Compliance Marathon
Posted: March 24th, 2016
” Over the years, ALL4 has chronicled the slow and not always steady regulatory development process in multiple blogs, articles, and presentations. For me, as the Air Toxics Knowledge Area Leader for ALL4’s RegTech Operations Group, I am responsible for […]
Read articleU.S. District Court Rules on Risk and Technology Review for Pulp Mills
Posted: March 18th, 2016
Every eight (8) years, U.S. EPA is required to conduct a Risk and Technology Review (RTR) for maximum achievable control technology (MACT) standards. Based on the results of the RTR, U.S. EPA must either promulgate revised emissions standards or publish…
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Baby Steps…to Final RACT 2 Publication
Posted: March 18th, 2016
“Baby steps onto the elevator…baby steps into the elevator…I’m in the elevator”
We are almost there. The elevator door is open, we just need to baby step inside…the long awaited RACT 2 Rule has passed the final significant hurdle as it moves toward official…
The Components of a RACT 2 Proposal
Posted: March 16th, 2016
The proposed 25 Pa. Code §§129.96 – 129.100, Additional RACT Requirements for Major Sources of NOX and VOCs, also known as the RACT 2 Rule, is expected to be promulgated in Spring 2016. If you are a follower of our blogs, you already know that facilities will only have…
Read articleTightening the Reins on GHG Emissions
Posted: March 7th, 2016
The Obama Administration announced its “Strategy to Reduce Methane Emissions from the Oil and Gas Sector” (Strategy) in March 2014 outlining the steps that the Administration will take towards reducing United States (U.S.) greenhouse gas (GHG) emissions by 17 percent […]
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Proposed Alignment of the Oil and Gas Sector GHG Reporting Rule (Subpart W) With NSPS OOOOa
Posted: March 2nd, 2016
On January 29, 2016, U.S. EPA proposed revisions to 40 CFR Part 98 Subpart W – Mandatory Greenhouse Gas (GHG) Reporting for Petroleum and Natural Gas Systems (Subpart W). These proposed revisions come not long after several other new reporting requirements were…
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Refinery Sector Rule Update: Compliance Dates for Flares and What You Should Be Doing Now
Posted: March 2nd, 2016
Back in December, the final Refinery Sector Rule (RSR) was published in the Federal Register, which outlined several new requirements for refinery flares. If you own or operate a refinery that has a flare, or plan to install a flare in the future, then you’ll want to know the new…
Read articleRACT 2 Methods of Compliance
Posted: February 27th, 2016
The revised Final-Form Reasonably Available Control Technology (RACT) 2 Rule was approved by the Pennsylvania Environmental Quality Board (EQB) on November 17, 2015. Although the final form of the RACT 2 rule has not yet been published in the Pennsylvania Bulletin, it is already…
Read articleMore “Clarifying” Proposed Amendments to Refinery Sector Rule
Posted: February 16th, 2016
On February 9, 2016, U.S. EPA issued proposed amendments to the December 1, 2015 published Refinery Sector Rule [i.e., 40 CFR Part 63, Subparts CC (Refinery MACT 1 ) and UUU (Refinery MACT 2) and, 40 CFR Part 60, Subparts J and Ja]. I know what you’re thinking….
Read articleRACT 2 – I have less than a year to comply!? What should I be doing now?
Posted: February 12th, 2016
Wow! Raise your hand if you can’t believe that you are now less than one (1) year away from the final compliance deadline for the Pennsylvania Reasonably Available Control Technology (RACT 2) regulations? That’s right – even though the final form of the rule has not…
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