Oxygen – We need it to live, and so does your 40 CFR Part 63, Subpart DDDDD Boiler!
Posted: December 16th, 2015
Let’s talk about oxygen! Sure, we all know that it’s critical to life, but did you know that it is also a critical part of the major source Boiler MACT rule? According to 40 CFR §63.7525(a), a boiler or process heater that is subject to a carbon monoxide (CO) emissions limit must install, operate, and maintain an oxygen (O2) analyzer system…
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The Shoe Has Dropped But Most Companies Don’t Know It – It’s Called PADEP RACT 2
Posted: December 11th, 2015
About 400 facilities in Pennsylvania probably don’t know they have been given a New Year delivery even before the dropping of the ball in Times Square. The delivery is not a bundle of joy brought in by a stork, it’s a count-down clock and it’s already ticking…
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More Residual Risk Review Activity for Hazardous Air Pollutants (HAPs) on the Horizon
Posted: December 10th, 2015
Earlier this year, a coalition of environmental groups sued U.S. EPA for failing to implement the residual risk and technology review (RTR) process for National Emission Standards for Hazardous Air Pollutants (NESHAP), commonly referred to as Maximum…
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Meteorological Monitoring Requirements of the Petroleum Refinery Rule
Posted: December 10th, 2015
The Petroleum Refinery Rule Package was published in the Federal Register on December 1, 2015 officially starting the two (2) year process of preparing for and implementing the 40 CFR Part 63 Subpart CC benzene fenceline monitoring (BFM) requirements so that…
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Time to Upgrade Your Facility’s Data Management System?
Posted: December 2nd, 2015
” Are you worried about your compliance approach using data collected from continuous monitoring systems (CMS) at your facility? Or maybe the inefficiencies in your process you currently use for managing your data cause you to periodically lose sleep. It […]
Read articleUpdated: U.S. EPA Issues Long-Awaited Petroleum Refinery Rule Package
Posted: December 2nd, 2015
UPDATE (12/2/15): The Petroleum Refinery Rule Package was published in the Federal Register on December 1, 2015. The publication establishes a February 1, 2016 effective date…
Read articleCross-State Air Pollution Rule (CSAPR) Update
Posted: December 1st, 2015
On November 16, 2015, the United States Environmental Protection Agency (U.S. EPA) proposed the Cross-State Air Pollution Rule (CSAPR) Update. According to U.S. EPA, the proposed rule will affect 3,047 electric generating units at 913 coal-, gas-, and oil-fired facilities in 23 states…
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Finalized Refinery Rule – Flare Edition
Posted: November 23rd, 2015
New requirements for flaring operations have been issued as part of the refinery rule updates. The proposed changes were discussed in detail in Roy’s 4 the Record article last May , and now that the rule is final, I’ll discuss the key changes from the proposed rule…
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Pennsylvania RACT 2 – We Are Finally There…And Even Though We Just Arrived, You’re Already Behind
Posted: November 19th, 2015
I had the opportunity to attend the Environmental Quality Board (EQB) Meeting on November 17, 2015. It was the most crowded that I’ve ever seen Room 105 of the Rachel Carson State Office Building. So…
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U.S. EPA Finalizes Major Source Boiler MACT Reconsiderations
Posted: November 19th, 2015
On November 5, 2015, U.S. EPA finalized the proposed reconsiderations to the Major Source Boiler MACT rule. (As of the date of this article, the proposed reconsiderations to the Area Source Boiler MACT and CISWI rules have not yet been finalized.) The final Major Source Boiler MACT rule…
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