U.S. EPA Finalizes Guidance on Fine Particulates and Ozone Significant Impact Levels
Posted: May 1st, 2018
On April 17, 2018, the U.S. Environmental Protection Agency (U.S. EPA) Office of Air Quality Planning and Standards (OAQPS) finalized guidance and supporting documents recommending Significant Impact Levels (SILs) for ozone (O3) and fine particulates (PM2.5) that…
Read articleNSR Reform 2018: Look to the Past
Posted: April 9th, 2018
The time for changes to the New Source Review (NSR) program is upon us. Our thinking at ALL4 is that the recent reversal in U.S. EPA policy regarding the accounting of emissions decreases from projects is just the beginning. We […]
Read articleGeorgia Permittees (Major, Minor, and Synthetic Minor): Have You Heard the News?
Posted: March 22nd, 2018
On March 8, 2018, the Georgia Environmental Protection Division (GEPD) released a Notice of Public Hearing and Proposed Amendments to the Georgia Rules for Air Quality Control codified by the Georgia Administrative Code (G.A.C.) 391-3-1. Specifically…
Read articleAre Pennsylvania Air Emissions and Permitting Fees on the Rise? – Update
Posted: March 21st, 2018
Last year I penned a blog regarding potential changes to emissions and permitting fees within Pennsylvania. The blog was based upon information provided by the Pennsylvania Department of Environmental Protection (PADEP) to the Air Quality…
Read articleNew 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…
Read article40 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…
Read articleDemonstrating 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 […]
Read articleHouse 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…
Read articleU.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…
Read articleU.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 article