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 […]
Read articleCarbon 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 […]
Read articleComment 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 […]
Read articlePennsylvania 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. […]
Read articleMarcellus Shale – The Saga Continues…Or Does It?
Posted: August 17th, 2011
On May 30, 2011, New York Governor Andrew Cuomo’s office issued an order giving the New York State Department of Environmental Conservation (NYSDEC) until July 1, 2011 to complete a draft of an Environmental Impact Statement (EIS) outlining the processes […]
Read articlePM2.5: Repeal and Reminder
Posted: June 25th, 2011
U.S. EPA has repealed the Prevention of Significant Deterioration (PSD) “Grandfathering” provision for particulate matter with an aerodynamic diameter of less than 2.5 microns (PM2.5). Facilities that submitted PSD construction permit applications prior to the promulgation of the PM2.5 New […]
Read articleMarcellus Shale in New York – The Saga Continues
Posted: June 20th, 2011
While numerous drilling operations in Pennsylvania and West Virginia have begun to tap the vast natural gas resources in the Marcellus Shale formation during the past several years, New York has been, to put it mildly, reluctant to join the […]
Read articleBoiler MACT…Yes…No…Maybe?
Posted: June 10th, 2011
Many questions surround the logic that U.S. EPA used to develop the emission limits contained in the Boiler MACT. One potential flaw identified by those petitioning U.S. EPA for judicial review of the Boiler MACT is the establishment of…
Read articleEPA Provides New Source Review (NSR) “Netting” Guidance
Posted: April 17th, 2011
In a recent letter dated April 4, 2011 to the Indiana Department of Environmental Management (IDEM), U.S. EPA clarified its position on conducting “Step 2” of a New Source Review (NSR) permitting applicability analysis (determine the net emissions increase). This […]
Read articlePennsylvania Plan Approval Expiration Date/Duration Revisions
Posted: March 23rd, 2011
Facilities in Pennsylvania should be aware of a recent change in the interpretation of standard Plan Approval (i.e., construction permit) language regarding Plan Approval duration and “shakedown” periods. The change impacts the temporary operation of a new, or newly modified, […]
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