New Source Review Project Emissions Accounting Guidance Memorandum
Posted: March 15th, 2018
On March 13, 2018 the U.S. EPA issued a much-anticipated policy guidance memorandum titled “Project Emissions Accounting Under the New Source Review (NSR) Preconstruction Permitting Program”. The policy guidance is extremely important because…
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40 CFR Part 63, Subpart MM Amendments – What’s the Next Step for Pulp and Paper Mills?
Posted: March 5th, 2018
On October 11, 2017, U.S. EPA finalized revisions to 40 CFR Part 63, Subpart MM (National Emission Standards for Hazardous Air Pollutants for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand-Alone Semichemical Pulp Mills). The revisions…
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Demonstrating Compliance and the Importance of Permit Language (Sweat the Details)
Posted: February 28th, 2018
On the air quality side of the world of environmental compliance, ALL4 is seeing an increased emphasis on monitoring and recordkeeping, more specifically, electronic data and electronic reporting, as related to demonstrating compliance with permit requirements. Such data may be […]
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House New Source Review Reform Hearing: Can We Make Progress?
Posted: February 15th, 2018
Yesterday I attended the House of Representatives Energy and Commerce Committee hearing titled “New Source Review Permitting Challenges for Manufacturing and Infrastructure.” With the current administration and legislative balance in place, now is widely viewed…
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U.S. EPA Clarifies NSR Emissions Projections and its Role in the Review Process
Posted: February 14th, 2018
U.S. EPA published a policy memo on ‘New Source Review Preconstruction Permitting Requirements: Enforceability and Use of the Actual-to-Projected-Actual Applicability Test in Determining Major Modification Applicability’ on December 7, 2017. This is a hefty…
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U.S. EPA Revises “Once In, Always In” Policy for MACT Sources
Posted: January 26th, 2018
The U.S. EPA has withdrawn the “once in, always in” policy associated with changing the status of a facility from a major source of hazardous air pollutants (HAP) to an area source of HAP to avoid the applicability of major source maximum achievable control…
Read article42nd Annual A&WMA/ASME Information Exchange: A Recap
Posted: January 17th, 2018
The Air and Waste Management Association (A&WMA), in collaboration with the American Society of Mechanical Engineers (ASME), hosted an information exchange in Durham, NC. The information exchange was held mid-December 2017, with the purpose of allowing…
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2018 Look Ahead
Posted: January 10th, 2018
Introduction to Annual Look Ahead 2018 Colin McCall Portions of this 4 The Record article is available as a podcast episode on ALL4’s Air Quality Insider At ALL4, before we make plans for the year ahead we always look backwards to […]
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The Clean Power Plan – Where Does It Stand, Where Are Things Headed?
Posted: November 6th, 2017
On October 16, 2017, U.S. EPA proposed repeal of the Clean Power Plan (CPP). The CPP is more formally entitled “Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Generating Units.” Under the CPP, states would be responsible for implementing […]
Read articleAre Pennsylvania Air Emissions and Permitting Fees on the Rise?
Posted: October 24th, 2017
Unfortunately, the answer is yes…eventually. Although not yet officially proposed and opened for public comment, the Pennsylvania Department of Environmental Protection…
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