So What’s in the Final Version of the Pennsylvania RACT 2 Rule? We are glad that you asked.
Posted: November 6th, 2014
Okay folks, the Pennsylvania Department of Environmental Protection (PADEP) released the final form version of the RACT 2 rule to the Air Quality Technical Advisory Committee (AQTAC) in advance of the supplemental AQTAC RACT 2 meeting scheduled for November 7, 2014 in Harrisburg. After…
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The Reality and Implications of SSM and NESHAPs
Posted: November 4th, 2014
ALL4’s project experience often involves industrial clients that are subject to one (1) or more of the National Emission Standards for Hazardous Air Pollutants (NESHAPs) for source categories (40 CFR Part 63). NESHAPs regulate emissions of hazardous air pollutants (HAPs) […]
Read articleU.S. EPA’s Area Source Boiler MACT Tool
Posted: November 4th, 2014
On October 14, 2014, U.S. EPA released an Area Source Boiler MACT Regulation Navigation Tool to help guide owners and operators of area source boilers through their regulatory requirements under 40 CFR Part 63, Subpart JJJJJJ (National Emission Standards for Hazardous Air Pollutants for Area…
Read articleReminder: Area Source Boiler MACT Notifications are Past Due!
Posted: October 6th, 2014
It has been quite some time since the Area Source Boiler MACT Notifications of Compliance Status (NOCS) were due on July 19, 2014, and even longer since the initial notifications were due on January 20, 2014. Hopefully your facility’s…
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The Saga of the Affirmative Defense and Excess Emissions During Periods of Startup, Shutdown, and Malfunction Continues
Posted: September 19th, 2014
I felt that the Merriam-Webster dictionary definition for saga “a long and complicated story with many details” was appropriate for identifying the latest affirmative defense rulemaking action. The saga continues…
Read articleWhy the Proposed New Emission Factor For Flares Could Have Huge Impacts on Industry
Posted: September 12th, 2014
U.S. EPA is proposing a substantial increase in the emission factor for nitrogen oxides (NOX) emitted from industrial flares. The change, if finalized as currently written, could have far-reaching impacts in industrial sectors that rely on the use of industrial flares…
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Residual Risk and Hazardous Air Pollutants – Why the Rules of the Game Can Change
Posted: August 4th, 2014
The U.S. Environmental Protection Agency (U.S. EPA) maintains a website that identifies dates of upcoming rulemakings in various stages (Notice of Proposed Rulemaking; Final Rule, etc.) to be published in the Federal Register. A review of this website reveals that […]
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Pennsylvania Cat 38 Exemption Recordkeeping and Compliance Demonstration Requirements
Posted: July 28th, 2014
The Pennsylvania Department of Environmental Protection (PADEP) Categorical 38 (Cat 38) Exemption has allowed certain oil and gas exploration, development, and production facilities
Read articleU.S. EPA Proposes Additional Standards of Performance for Municipal Solid Waste Landfills
Posted: July 25th, 2014
On July 17, 2014, the U.S. Environmental Protection Agency (U.S. EPA) issued the results of its initial review of the existing New Source Performance Standards (NSPS) for municipal solid waste (MSW) landfills…
Read articleU.S. EPA Defends Its Major Source Boiler MACT Floor Calculation Methodology
Posted: July 21st, 2014
Those of you following the saga of the Major Source Boiler MACT remand (see our March 17, 2014 and May 22, 2014 blogs for a refresher) will be interested to learn that latest milestone in the process occurred on July 14, 2014. Back in May 2014, the U.S. Environmental Protection Agency (U.S. EPA) was granted 60 days to provide further explanation to the U.S. Court of Appeals for the District of Columbia Circuit on the use of the upper prediction limit (UPL) statistical method to set the emission standards for certain subcategories in the Major Source Boiler MACT rule.
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