Area Source Boiler MACT Notification of Compliance Status (NOCS) Due
Posted: July 9th, 2014
Area sources were required to complete most of their initial compliance obligations for the Area Source Boiler MACT Rule back in March 2014; however, there is just one (1) last obstacle…
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U.S. EPA Proposes Benzene Fenceline Monitoring for Refineries Amongst Other MACT and NSPS Changes
Posted: June 30th, 2014
U.S. EPA has proposed an amendment to 40 CFR Parts 63, Subpart CC and Subpart UUU that requires all petroleum refineries to deploy passive time-integrated benzene samplers at the fenceline (where fenceline is equivalent to the facility property line) of […]
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Risk Assessment: Refinery MACT 1 and 2
Posted: June 30th, 2014
Section 112(f)(2) of the Clean Air Act (CAA) requires the U.S. EPA to determine for source categories subject to Maximum Achievable Control Technology (MACT) standards whether the emission standards provide an ample margin of safety to protect public health…
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Where Did These New Quality Assurance Requirements For Opacity Monitors Come From?
Posted: May 22nd, 2014
U.S. EPA proposed quality assurance requirements for continuous opacity monitoring systems (COMS) at stationary sources
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Boiler MACT Remand Request Granted!
Posted: May 22nd, 2014
On February 28, 2014, U.S. Environmental Protection Agency (U.S. EPA) requested a remand without vacatur of the set of rules commonly referred to as…
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ALL4 Discusses RACT 2 in PA Chamber’s Catalyst
Posted: May 19th, 2014
All4 Inc.’s Roy Rakiewicz recently penned an article in the Pennsylvania Chamber of Commerce’s quarterly publication, Catalyst. In the Spring 2014 edition…
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CSAPR’s Triumphant Return
Posted: May 16th, 2014
On April 29, 2014 the Supreme Court issued a ruling in EPA v. EME Homer City Generation, L.P. that has reinstated U.S. EPA’s Cross-State Air Pollution Rule (CSAPR). This is the latest reversal that essentially overturns…
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Startup, Shutdown, and Malfunction (SSM) and Pressure Relief Devices Updates for Resin Manufacturers
Posted: April 24th, 2014
Early this year, the U.S. Environmental Protection Agency (U.S. EPA) proposed several updates to the air toxics rule for manufacturers of amino/phenolic resins…
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Affirmative Defense is Vacated for the Cement Industry
Posted: April 24th, 2014
I wrote a blog back in February that was intended to raise the awareness level of the cement industry regarding new requirements for their MACT operations and maintenance (O&M) plans…
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RACT 2 In Pennsylvania is Now Proposed
Posted: April 18th, 2014
The online version of the Pennsylvania Bulletin includes the long awaited proposed rulemaking “Additional RACT Requirements for Major Sources of NOx and VOC” (i.e., RACT 2)…
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