4 The Record is a publication from ALL4’s team that takes an in-depth look at technical and regulatory topics.
U.S. EPA Defends Its Major Source Boiler MACT Floor Calculation Methodology
Posted: July 21st, 2014
Those of you following the saga of the Major Source Boiler MACT remand (see our March 17, 2014 and May 22, 2014 blogs for a refresher) will be interested to learn that latest milestone in the process occurred on July 14, 2014. Back in May 2014, the U.S. Environmental Protection Agency (U.S. EPA) was granted 60 days to provide further explanation to the U.S. Court of Appeals for the District of Columbia Circuit on the use of the upper prediction limit (UPL) statistical method to set the emission standards for certain subcategories in the Major Source Boiler MACT rule.
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Environmental Consulting Firms: Is bigger really better?
Posted: July 17th, 2014
We recently warmly welcomed Jennifer Flannery and Renee Cheng as our newest ALL4 members. Both women chose to leave a larger environmental consulting firm for ALL4, a “smaller” (hmm, for now) consulting company…
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Proposed GHG Standards – Comments on Standards for New Sources
Posted: July 15th, 2014
Although the deadline to submit public comments was November 29, 2013, the September 2013 proposed rule for new EGUs continues to receive its fair share of criticism amongst industry, political groups, and environmentalists alike. One argument at play is that […]
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U.S. EPA’s Proposed Greenhouse Gas Standards for the Utility Industry – How Powerful Are They?
Posted: July 15th, 2014
A major event in the Climate Change arena occurred on March 27, 2012 when, for the first time, U.S. EPA proposed Standards of Performance for New Stationary Sources (NSPS) for emissions of carbon dioxide (CO2). The proposed standards were specific […]
Read articleHouston: Here I Come!!
Posted: July 11th, 2014
Working for a small (and growing) company can provide one with lots of opportunities, unique experiences, responsibilities, etc. For a consultant who thrives on a fast pace…
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Area Source Boiler MACT Notification of Compliance Status (NOCS) Due
Posted: July 9th, 2014
Area sources were required to complete most of their initial compliance obligations for the Area Source Boiler MACT Rule back in March 2014; however, there is just one (1) last obstacle…
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U.S. EPA Proposes Benzene Fenceline Monitoring for Refineries Amongst Other MACT and NSPS Changes
Posted: June 30th, 2014
U.S. EPA has proposed an amendment to 40 CFR Parts 63, Subpart CC and Subpart UUU that requires all petroleum refineries to deploy passive time-integrated benzene samplers at the fenceline (where fenceline is equivalent to the facility property line) of […]
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Risk Assessment: Refinery MACT 1 and 2
Posted: June 30th, 2014
Section 112(f)(2) of the Clean Air Act (CAA) requires the U.S. EPA to determine for source categories subject to Maximum Achievable Control Technology (MACT) standards whether the emission standards provide an ample margin of safety to protect public health…
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Permit Aggregation Ruling
Posted: June 23rd, 2014
For some time, U.S. EPA has considered the concepts of contiguous or adjacent, common control, and industrial groupings when determining whether emissions from multiple “sites” should be aggregated for air permitting purposes…
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Where Did These New Quality Assurance Requirements For Opacity Monitors Come From?
Posted: May 22nd, 2014
U.S. EPA proposed quality assurance requirements for continuous opacity monitoring systems (COMS) at stationary sources
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