4 The Record is a publication from ALL4’s team that takes an in-depth look at technical and regulatory topics.
As The Biomass Turns…Greenhouse Gases from Biomass and Biogenic Sources
Posted: November 21st, 2012
The regulatory community has become (for the most part) accustomed to the permitting requirements for greenhouse gases (GHGs). It has become second nature to include them in emission inventories…
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Hazardous Waste Manifests – A Future Without Filing Cabinets?
Posted: November 19th, 2012
On October 5, 2012 The Hazardous Waste Electronic Manifest Establishment Act (ACT) was signed into law by President Obama. This ACT amends Subtitle C of the Solid Waste Disposal Act…
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EPA’s Aggregation Appeal Denied by Court of Appeals
Posted: November 16th, 2012
The 6th Circuit Court of Appeals rejected U.S. EPA’s appeal of the Court’s August 7th, 2012 aggregation decision. The August 7th decision invalidated U.S. EPA’s method of considering the functional…
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Aggregation Appeal Denied
Posted: November 15th, 2012
The 6th Circuit Court of Appeals rejected U.S. EPA’s appeal of the Court’s August 7th, 2012 aggregation decision. The August 7th decision invalidated U.S. EPA’s method of considering…
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A Time For Different Thinking Related to PSD Permitting
Posted: November 9th, 2012
U.S. EPA recently issued a New Source Review (NSR) memo on October 15th that clarifies the timeline that an applicant can expect for “timely and consistent permit processing” of a Prevention of Significant Deterioration (PSD) air permit application…
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Clarification – Pennsylvania Contemplating “RACT 2” Regulation
Posted: November 7th, 2012
On September 12, 2012, the Pennsylvania Department of Environmental Protection (PADEP) presented a draft proposed rulemaking, “Additional RACT Requirements for Major Sources of NOX and VOC” (referred to as “RACT 2”)…
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“Short Stay” of Chemical Manufacturing Area Source (CMAS) NESHAP
Posted: November 5th, 2012
On October 22, 2012 U.S. EPA issued a short stay of the final National Emission Standards for Hazardous Air Pollutants (NESHAP) for Chemical Manufacturing Area Sources (CMAS) identified as 40 CFR Part 63, Subpart VVVVVV. On January 30, 2012, U.S. EPA…
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Decision 2012: Where Has the Environment Gone?
Posted: November 5th, 2012
Strikingly absent from either candidate’s discourse in the past months, the environment has seemingly taken a back seat to the economy in this election. Indeed, environmental issues have…
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Musings on Monitoring: The Who, What, When, Why, and How of Atmospheric Measurements
Posted: October 30th, 2012
The installation and operation of ambient pollutant and meteorological monitors has never traditionally been a part of the laundry list of environmental tasks at most facilities. Ambient monitoring installations by facilities have been limited to consent decrees and large Prevention […]
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In Case You Forgot: Boiler MACT, CISWI, and NHSM Recap
Posted: October 29th, 2012
In anticipation of the Boiler MACT, Commercial and Industrial Solid Waste Incineration (CISWI), and Non-hazardous Secondary Materials (NHSM) rules being finalized (we suspect after the upcoming elections)…
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