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…
Read articleWhere 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
Read articleBoiler 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…
Read articleALL4 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…
Read articleCSAPR’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…
Read articleAffirmative 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…
Read articleStartup, 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…
Read articleRACT 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)…
Read articleNew Ultra Fine Particulate NAAQS in the (Not So Distant) Future?
Posted: April 16th, 2014
The U.S. Environmental Protection Agency (U.S. EPA) has expressed that a revisit of existing particulate matter (PM) National Ambient Air Quality Standards (NAAQS) may result in a first-time…
Read articleKraft Pulp Mill NSPS (40 CFR Part 60 Subpart BBa) Has Been Finalized!
Posted: April 11th, 2014
U.S. EPA has finalized their review of the Kraft Pulp Mill NSPS, codified at 40 CFR Part 60 Subpart BBa. The final rule was published in the Federal Register on April 4, 2014…
Read article