4 The Record is a publication from ALL4’s team that takes an in-depth look at technical and regulatory topics.
Extension of a Wool Fiberglass Manufacturing Compliance Deadline
Posted: August 14th, 2017
The National Emissions Standards for Hazardous Air Pollutants (NESHAP) located at 40 CFR Part 63 Subpart NNN regulates hazardous air pollutants (HAPs) emitted from wool fiberglass manufacturing facilities. The rule was first proposed in 1997 and finalized in its original form…
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How My Next Chapter Helps Write ALL4’s Book
Posted: August 14th, 2017
I’m sitting in the Charlotte airport. My flight from Philly was delayed and I missed my connection to Columbus, OH. Now I have more than three hours to spare before the last scheduled flight out of here. I’m still panting from my sprint across the B and C Terminals…
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Ohio EPA Requests Feedback Before Amending RACT Regulations
Posted: August 7th, 2017
The Ohio Environmental Protection Agency (Ohio EPA) is planning to amend its nitrogen oxides (NOX) reasonably available control technology (RACT) regulations, which are found at Ohio Administrative Code (OAC) 3745-110. In what is known as the Early Stakeholder…
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Is Your Cleanup Site “Stuck”?
Posted: August 2nd, 2017
“Going nowhere, fast.” An odd expression, but a circumstance to which we can all relate to from time to time. But it’s a particularly unproductive circumstance when corporate resources are expended at remediation sites and there is no apparent prospect for a timely…
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Proposed Industrial Cleaning Solvents RACT Rule is Out
Posted: August 1st, 2017
Does your facility use industrial cleaning solvents? If so, you should be aware that the Pennsylvania Department of Environmental Protection (PADEP) has proposed a new rule, 25 Pa. Code 129.63a – Control of Volatile Organic Compound (VOC) Emissions from…
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Navigating State-Specific Air Toxics Programs
Posted: July 31st, 2017
Hazardous Air Pollutants (HAP), also commonly referred to as Toxic Air Pollutants (TAP) or air toxics, are those pollutants that are known or suspected to cause cancer or other serious health effects, such as reproductive effects, birth defects, or adverse […]
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U.S. EPA Approves PADEP’s 2006 SIP Revision Via Direct Final Action
Posted: July 26th, 2017
It’s Friday, July 7,2017 and I’m reading Federal Register Vol. 82, No. 129 (my life is very exciting). As I stand here reading, I’m 37 years, 8 months, and 7 days old. Page 31464 of Federal Register Vol. 82, No. 129 includes a notice indicating that the…
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PC MACT Carousel
Posted: July 25th, 2017
Today (July 25th) is National Carousel Day. Ironically, it is also the expiration date of the original 1-year additional compliance alternative for sources required to use a hydrogen chloride (HCl) continuous emission monitoring system (CEMS) to demonstrate compliance…
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Reasonably Available Control Technology (RACT 2) Post-Compliance Deadline Happenings
Posted: July 21st, 2017
Major sources of NOx and/or VOC (i.e., potential to emit greater than or equal to 100 tons per year of NOx and/or 50 tons per year of VOC) subject to the Pennsylvania Reasonably Available Control Technology (RACT 2) rule had to demonstrate compliance with the applicable
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Vacatur of NSPS Subpart OOOOa Stay and More Litigation on the Horizon
Posted: July 14th, 2017
(UPDATE 7/14/17): On July 13, 2017, the U.S. Court of Appeals for the D.C. Circuit granted the U.S. EPA a 14-day extension to comply with the court’s earlier decision vacating U.S. EPA’s stay of certain 40 CFR Part 60, Subpart OOOOa (Subpart OOOOa) provisions. The extension…
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