4 The Record is a publication from ALL4’s team that takes an in-depth look at technical and regulatory topics.
Refinery MACT I – Do You Really Know What Your DAHS is Doing?
Posted: June 15th, 2017
By now, I’m sure you have familiarized yourself with 40 CFR Part 63, Subpart CC – National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries (Refinery MACT I) and you have (hopefully) developed a compliance strategy for the new requirements that apply…
Read articleTCEQ Air Quality 101 Blog Series – NSR Permitting
Posted: June 6th, 2017
In late March, I had the opportunity to participate in an event called the Texas Independence Relay (TIR), which is a 2-day, 10-person running event from Gonzales through Houston, covering 200 miles from start to finish. The relay commemorates the independence of the State of Texas…
Read articleU.S. EPA Grants Reconsideration of Additional NSPS Subpart OOOOa Provisions
Posted: June 5th, 2017
As reported in our blog, U.S. Environmental Protection Agency (U.S. EPA) announced in an April 18, 2017 letter to oil and gas industry groups that it was reconsidering certain fugitive emissions monitoring requirements of the 40 CFR Part 60 Subpart OOOOa Standards of Performance…
Read articlePublic and Industry Comment on Regulatory Reform
Posted: June 4th, 2017
This past April, Lindsey wrote about U.S. EPA’s Regulatory Reform Task Force seeking public input for potential repeals, replacements, or modifications of existing regulations as directed by President Trump’s Executive Order (EO) 13777. Written comments were due by May 15, 2017 and…
Read articlePoking Holes In Your Electronic Compliance Report
Posted: May 24th, 2017
So maybe you’re one of the many facilities who are now subject to electronic reporting requirements under a 40 CFR Part 60 (NSPS) or Part 63 (NESHAP) rule. Perhaps even this past year was your first time having to submit your semi-annual or annual compliance report…
Read articleRe-Entrainment. What is it and should you be evaluating it for your site or next project?
Posted: May 17th, 2017
|Who should consider a re-entrainment evaluation?|Information necessary to conduct a re-entrainment evaluation|AERMOD|ASHRAE Minimum Dilution Models|Hospital Example Re-Entrainment Evaluation|Ship Example Re-Entrainment Evaluation|Recommendations| Have you ever seen a plume from a stack swirl around when it gets caught in the wake of […]
Read articleProposed Amendments to the Massachusetts RACT Regulations
Posted: May 11th, 2017
In August 2016, the Massachusetts Department of Environmental Protection (MassDEP) proposed amendments to 310 CMR §7.00 – Air Pollution Control, including amendments to the Massachusetts Reasonably Available Control Technology (RACT) regulations for sources of nitrogen oxides…
Read articleCISWI or PC NESHAP Compliance Demonstration Timelines and Milestones Considerations
Posted: May 8th, 2017
If you’re like me, it’s hard to believe that it is May already. Time seems to move faster every time I stop and think about it. Why is this relevant? The compliance date for 40 CFR Part 60, Subpart DDDD [Emissions Guidelines and Compliance Times for Commercial and…
Read articleGetting Your CMS House in Order
Posted: May 4th, 2017
We are all wondering how the proposed cutbacks at U.S. EPA could influence the day-to-day compliance obligations at facilities using continuous monitoring systems (CMS). The organizations that may be affected the most by the anticipated U.S. EPA cutbacks are the state…
Read article33 Late Air Toxics Rules, 2 Court Decisions, Reduced U.S. EPA Resources, and 6 Things Industry Should Do
Posted: April 27th, 2017
The subject of overdue air toxics rules, specifically the risk and technology review (RTR), has gotten its fair share of air time in federal district courts of late. At the same time, it’s been nearly impossible not to hear about […]
Read article