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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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…
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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…
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….
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Report on Pennsylvania’s Methane Reduction Plan, General Permit for Well Pads, and GP-5 Modifications
Posted: February 12th, 2016
The agenda for the Air Quality Technical Advisory (AQTAC) meeting on February 11, 2016 included the following informational items pertaining to the natural gas industry. 1. Pennsylvania’s Methane Reduction Strategy…
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…
Read articleBrace Yourself – 2016 Chemical Data Reporting is Coming
Posted: February 8th, 2016
2016 is special not only because it is a leap year, but it is also a reporting year in the Toxic Substances Control Act (TSCA) Chemical Data Reporting (CDR) rule cycle. Every four (4) years (the previous report was required in 2012), manufacturers of TSCA regulated chemicals must…
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February Ain’t What It Used to Be – Major Source Boiler MACT Compliance is Upon Us
Posted: February 3rd, 2016
February is exciting enough with Valentine’s Day, the Super Bowl, and particularly for 2016, those leap year birthdays! However, this February brought with it another exciting event – the Major Source Boiler MACT compliance date. Now that it has arrived, there are plans to prepare…
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