Multipollutant Rules: What’s In Store?
Posted: January 9th, 2012
There is significant discussion in the regulatory and regulated community regarding the trend towards “multipollutant” rules. U.S. EPA’s current focus on “multipollutant” rules can be traced to a publication entitled “Air Quality Management in the United States,” prepared as a […]
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Marcellus Drilling Operations: Air Quality Requirements Overview
Posted: January 9th, 2012
Introduction For as much excitement as there has been about the potential benefits of drilling in the Marcellus Shale from the perspective of energy needs and employment opportunities, it is also hard to ignore the sometimes vociferous opposition from environmentalists […]
Read articleAir Quality, Acronyms, and Midstream Marcellus Operations
Posted: January 9th, 2012
In the March 2011 issue of 4 The Record, ALL4’s Marcellus Gas team provided a general overview of air quality requirements surrounding drilling operations. Drilling, along with exploration, and the physical process of bringing gas to the surface are part […]
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U.S. EPA’s Proposed Revisions to Oil and Natural Gas Sector NSPS and NESHAPs
Posted: January 9th, 2012
Using a “sector-based approach,” U.S. EPA proposed revisions to both the Standards of Performance for New Stationary Sources (NSPS) and National Emission Standards for Hazardous Air Pollutants (NESHAP) for the oil and gas industry on August 23, 2011. Comments regarding […]
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Lots of Rules, Lots of Uncertainty
Posted: January 9th, 2012
There has been an unprecedented amount of regulatory action by U.S. EPA over the last several years. As a consequence of this activity, uncertainty for industry has become the “new normal” along with the associated “regulatory backlog” that afflicts under-staffed […]
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Caught in the Crossfire
Posted: January 9th, 2012
Eerily similar to the political and ideological extremism that has overtaken both houses of Congress, the various factions that typically provide “public” comments on proposed new and revised air quality regulations are generally split between industry trade or lobbying organizations […]
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Mass Confusion: Are Greenhouse Gases for PSD Permitting Treated the Same Way as Other Regulated PSD Pollutants?
Posted: December 28th, 2011
Can a facility be a classified as a major stationary source for greenhouse gas (GHG) emissions only, and if so, do all modifications at the facility need to be evaluated for Prevention of Significant Deterioration (PSD) applicability for all New […]
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Carbon Capture and Sequestration Deemed Not Cost Effective by DOE
Posted: November 17th, 2011
Since the beginning of 2011, major sources of greenhouse gas (GHG) emissions that trigger Prevention of Significant Deterioration (PSD) permitting have been required to implement Best Available Control Technology (BACT) for GHG emissions from new and modified sources. A recent […]
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Comment Period Extension for Proposed Oil and Gas NSPS/NESHAP Revisions
Posted: November 10th, 2011
In an October 28, 2011 Federal Register announcement, U.S. EPA extended the comment period for the proposed revisions to both the Standards of Performance for New Stationary Sources (NSPS) and National Emission Standards for Hazardous Air Pollutants (NESHAP) for the […]
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Pennsylvania NOx Allowance Alert
Posted: October 23rd, 2011
For non-electric generation unit (non-EGU) sources that have either allowance surrender requirements or regulatory compliance options that allow the surrender of NOx allowances under Pennsylvania regulations, the new U.S. EPA Cross-State Air Pollution Rule (CSAPR) may render such requirements meaningless. […]
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