As the seasons change, so will your Performance Test Methods (Potentially)!
Posted: October 6th, 2016
As the season changes from summer to fall, so will most of your performance test methods and performance specifications. U.S. EPA issued a final rule on August 30, 2016 to make technical and editorial corrections and updates to testing provisions. The revisions…
Read articleRACT 2 – T Minus 2 Months 2 Go
Posted: August 24th, 2016
You have likely heard about RACT 2 at this point, but you may not have yet acted on what you’ve heard. Human nature is bent toward procrastination. We get it and that’s part of why we’re here. The proposal deadline for RACT 2 submittals is quickly approaching whether you’ve…
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U.S. EPA Proposes Guidance on Fine Particulate and Ozone Significant Impact Levels
Posted: August 7th, 2016
UPDATE 9/7/16: The values in the tables within this article have been updated per EPA’s corrections to the draft guidance. On August 1, 2016 U.S. EPA made available for public comment draft guidance and supporting documents recommending Significant Impact Levels […]
Read articleTightening the Reins on GHG Emissions
Posted: March 7th, 2016
The Obama Administration announced its “Strategy to Reduce Methane Emissions from the Oil and Gas Sector” (Strategy) in March 2014 outlining the steps that the Administration will take towards reducing United States (U.S.) greenhouse gas (GHG) emissions by 17 percent […]
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The Secret to Your Environmental Permitting Challenges – A PAL Permit
Posted: February 12th, 2016
As the one in charge of dealing with environmental issues at your facility the following “hypothetical” conversation with your Plant Manager or engineering group may sound familiar. Plant Manager: “We have a project in the works that with a few […]
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The Shoe Has Dropped But Most Companies Don’t Know It – It’s Called PADEP RACT 2
Posted: December 11th, 2015
About 400 facilities in Pennsylvania probably don’t know they have been given a New Year delivery even before the dropping of the ball in Times Square. The delivery is not a bundle of joy brought in by a stork, it’s a count-down clock and it’s already ticking…
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How Should it Feel Working with an Air Quality Consultant?
Posted: October 29th, 2015
I thought it might be helpful for folks looking for assistance with air quality related issues to provide some insights that I’ve gained over my 40+ years working in this field. In the early part of my career I spent […]
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“Winning by Losing”…or Some Such Thing
Posted: October 5th, 2015
As previously discussed here by yours truly, on May 1, 2015, the U.S. Court of Appeals for the District of Columbia Circuit issued a decision to remand and vacate the so-called 100-hour “exemption” for RICE…
Read articleU.S. EPA Proposes to Define “Adjacent” for the Oil and Gas Industry
Posted: September 14th, 2015
Previous ALL4 blogs and at least one 4 The Record article have discussed the extremely complex issue of single source aggregation for air permitting. This issue has been particularly difficult for the oil and gas industry…
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U.S. EPA Proposed Amendments to Subpart OOOO and Proposed a New Subpart OOOOa
Posted: August 27th, 2015
The anticipation ended on August 18, 2015 when the U.S. Environmental Protection Agency (EPA) proposed to amend 40 CFR Part 60, Subpart OOOO (Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution) and create a new…
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