Five Considerations of Being a CISWI Unit
Posted: August 1st, 2013
With so much talk of boilers and heaters since the 4 Rules were published in early 2013, most facilities are focused on developing an understanding and strategy to comply with the Maximum Achievable Control Technology (MACT) standards for Boilers (commonly […]
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7th Circuit Court of Appeals Upholds Statute of Limitation in NSR Enforcement Case
Posted: July 26th, 2013
In a very interesting ruling that, at first glance, would appear to have major ramifications to how U.S. EPA pursues New Source Review (NSR) enforcement cases…
Read articleYou are NOT Subject to a NESHAP Standard…Now What?
Posted: July 23rd, 2013
With all of the activity surrounding National Emission Standards for Hazardous Air Pollutants (NESHAPs) lately (boilers, internal combustion engines, and a slew of new and sometimes obscure area source standards)…
Read articleNice While It Lasted: Biogenic CO2 Exemption From Tailoring Rule Struck Down
Posted: July 22nd, 2013
The D.C. Circuit Court threw out the biogenic CO2 exemption from air permitting activities under the Federal Greenhouse Gas (GHG) Tailoring Rule on July 12, 2013…
Read articlePolicy On Public Participation
Posted: July 2nd, 2013
The Pennsylvania Department of Environmental Protection (PADEP) has issued a draft revised guideline for public participation in the permit review process for permits or other applicable authorization application submitted for Department review. The draft document establishes…
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Addressing Environmental Justice in the Permitting Process
Posted: June 28th, 2013
On February 11, 1994, Executive Order 12898 Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations was issued. Executive Order 12898 calls on each Federal agency to make achieving environmental justice part of its mission. Since that […]
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Single Source Determinations For Air Quality Permitting Applicability
Posted: June 11th, 2013
Once again, single source determinations and the confusing issue of whether to aggregate emissions from multiple sources together for permitting as a single source (facility) is in the limelight for the…
Read articleContentious Air Permitting Issues for the Pennsylvania Oil and Gas Industry
Posted: June 6th, 2013
On May 30, 2013 the Clean Air Council (CAC) submitted a 60-day Notice of Intent to Sue U.S. EPA regarding Pennsylvania’s air permitting of the oil and gas industry. Specifically, the CAC…
Read articleNJDEP Cracks Down on Emergency Generators
Posted: April 19th, 2013
New Jersey Department of Environmental Protection (NJDEP) has begun to restrict certain specific uses of emergency generators. NJDEP has learned that some facility owners and operators of…
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What Rich Oil Men Need to Know About Quad O Revisions
Posted: April 10th, 2013
No doubt that Jed Clampett and J.R. Ewing would not have been quite as successful with their oil and natural gas operations if they had to meet the Standards of Performance for New Stationary Sources…
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