Did You Say “Part 70 Source” or “Par 70 Course?”
Posted: October 15th, 2012
It was around this time last year when I began playing golf. Participating in ALL4’s annual golf outing last October was my third time ever swinging clubs. I’ve been playing regularly ever since…
Read articleReforming U.S. EPA’s Science Advisory Process
Posted: October 8th, 2012
Science is usually just one component of environmental regulatory decision-making, but the quality and interpretation of that science often becomes the central subject of debate when regulated entities and…
Read articlePSD Permitting in Georgia – Homework Isn’t Just for Kids!
Posted: October 1st, 2012
In the spirit of a brand new school year, the Georgia Environmental Protection Division (GEPD) recently published a document that is required reading for those with air permitting interests in Georgia…
Read articleThe Sixth Circuit Court of Appeals Rejects U.S. EPA’s Functional Interrelatedness Test for Air Aggregation
Posted: September 27th, 2012
Introduction On August 7, 2012, the United States Court of Appeals for the Sixth Circuit, in a 2 to 1 decision, [1] vacated the United States Environmental Protection Agency’s (U.S. EPA) final determination that Summit Petroleum Corporation’s (Summit) commonly owned natural […]
Read articleExploring Plantwide Applicability Limit (PAL) Basics
Posted: September 27th, 2012
Initiating a project that triggers major new source review (NSR) requirements or an NSR applicability analysis at an existing major stationary source is arguably more difficult now than at any time since the inception of the Clean Air Act (CAA). […]
Read articleSpare Parts and Permit Conditions
Posted: September 25th, 2012
A seemingly simple question was recently raised by an ALL4 client regarding the level of spare parts inventories that facilities are obligated to keep on hand for air pollution control equipment, as required by applicable air permits…
Read articleSeptember 2012 Pennsylvania Air Quality Technical Advisory Committee Update
Posted: September 17th, 2012
The September 2012 Air Quality Technical Advisory Committee (AQTAC) meeting was held on Wednesday, September 12th. The agenda was very full, with three proposals that the Pennsylvania Department of Environmental Protection (PADEP) was seeking approval…
Read articleSource Aggregation and the Plain Meaning of “Adjacent”
Posted: August 17th, 2012
An interesting Court of Appeals decision was made by a three member panel of the Sixth Circuit this week (the Sixth Circuit is in Cincinnati and serves Michigan, Ohio, Kentucky and Tennessee). The case involves aggregation of sources for purposes of…
Read articleGreenhouse Gas Tailoring Rule – Thresholds, Minors, and PALs, Oh My!
Posted: July 27th, 2012
We’re a year and a half into U.S. EPA’s integration of greenhouse gases (GHG) into its Prevention of Significant Deterioration (PSD) and Title V permitting programs, and the excitement keeps on coming! The GHG Tailoring Rule, first promulgated on June […]
Read articleADEM Posts New Waste and Water Forms
Posted: July 19th, 2012
On July 6, 2012, the Alabama Department of Environmental Management (ADEM) announced that their website (Forms section) has been updated with the following forms concerning National Pollutant Discharge Elimination System (NPDES) and waste systems…
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