4 The Record is a publication from ALL4’s team that takes an in-depth look at technical and regulatory topics.
U.S. EPA Withdrawal of Regulatory Interpretation for Continuous Monitoring System Requirements
Posted: October 1st, 2019
As we near the start of the third quarter reporting season for continuous monitoring systems (CMS), ALL4’s CMS Practice Area felt it was timely to recommunicate the ending of two years of compliance demonstration uncertainty involving the regulatory interpretation for […]
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Proposed Rulemaking for Ethylene Production NESHAP
Posted: September 12th, 2019
On September 5, 2019, Andrew Wheeler, the U.S. Environmental Protection Agency (U.S. EPA) Administrator, signed a notice proposing changes to the National Emission Standards for Hazardous Air Pollutants (NESHAP): Generic Maximum Achievable Control Technology Standards for Ethylene Production. U.S. EPA […]
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Onboarding: We’ve got one chance at a welcome…and we make it memorable!
Posted: September 12th, 2019
Whether you are stepping on a plane, visiting a model home, or starting a new job, how you’re welcomed forever shapes your experience – I call it the ‘sizzle/fizzle factor’. The upside is when done well, it quickly heightens the […]
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It is Always Best to Report Asbestos
Posted: September 12th, 2019
U.S. EPA’s National Emission Standard for Asbestos are found in 40 CFR Part 61, Subpart M (National Emission Standard for Asbestos), which includes provisions for demolition and renovation. According to 40 CFR §61.145, prior to commencement of demolition, renovation, or […]
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Sticky Situation: What You Should Know About PFAS
Posted: August 29th, 2019
Per- and polyfluoroalkyl substances (PFAS) are a group of more than 3,000 emerging contaminants that have been heavily utilized in a wide range of industries including military training, consumer product manufacturing, and emergency services. Although most of the releases have […]
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Cleaner Air Oregon Regulation: Call to Action and Lessons Learned So Far
Posted: August 28th, 2019
By now I’m sure you’ve heard of or already been involved in some aspect of Oregon Department of Environmental Quality’s (DEQs) new Cleaner Air Oregon (CAO) risk-based toxic air contaminant permitting program. You may also be asking yourself, when am […]
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CMS Data Management: The Importance of Log Books and Reconciling Your Data
Posted: August 21st, 2019
Does your facility operate a continuous monitoring system (CMS) to demonstrate compliance with Federal and/or state monitoring requirements? If so, we want to reiterate the importance of maintaining records/logbooks of events associated with your CMS. In addition to potentially being […]
Read articleWhat Happened: Air Quality Bills to Watch in the 86th Texas Legislative Session
Posted: August 19th, 2019
In April 2019, I shared two articles regarding the legislative process in Texas. The first was an overview of the legislative process related to air-quality related bills considered during the 86th Texas Legislative Session (January 8, 2019 to May 27, […]
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What’s Your Role in our Story?
Posted: August 6th, 2019
Many stories begin with: “It was a dark and stormy night…,” “Once upon a time…,” “So I was drunk one night and…,” or “This one time, at band camp…” However, the story of the ALL4 Washington, D.C. (WDC) office begins […]
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Proposed Rulemaking to Address Reclassification of Major Sources as Area Sources
Posted: August 5th, 2019
The U.S. Environmental Protection Agency (U.S. EPA) proposed a rulemaking in the July 26, 2019 Federal Register to revise the 40 CFR Part 63, Subpart A General Provisions to include requirements for facilities that want to reclassify from a major […]
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