4 The Record is a publication from ALL4’s team that takes an in-depth look at technical and regulatory topics.
U.S. EPA to Reconsider Certain Requirements of NSPS Subpart OOOOa and Stays Fugitive Emissions Monitoring Compliance Date
Posted: April 27th, 2017
In an April 18, 2017 letter to oil and gas industry groups, the U.S. Environmental Protection Agency (U.S. EPA) announced that it is reconsidering the fugitive emissions monitoring requirements of the 40 CFR Part 60 Subpart OOOOa…
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U.S. EPA Task Force Seeks Public Input on Existing Regulations
Posted: April 21st, 2017
On February 24, 2017, President Trump issued Executive Order (EO) 13777 entitled “Enforcing the Regulatory Agenda.” In this EO, the President established a timeline to “evaluate existing regulations (as defined in section 4 of Executive Order 13771) and make recommendations…
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Continuous Monitoring System Data – The Risk of Being Isolated
Posted: April 11th, 2017
Annalise recently wrote an article called “What-If Island,” where the “island” represented “creating a story,” usually about something that is not as scary as we make it out to be in our heads. “Being on an island” can also refer to being isolated, which is something…
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PC MACT HCl CEMS – Does July 25, 2017 Sound Familiar?
Posted: April 6th, 2017
July 25th, 2017 is the expiration date for the 1-year additional compliance alternative for sources required to use a hydrogen chloride (HCl) continuous emission monitoring system (CEMS) to demonstrate compliance with the Portland Cement MACT (i.e., PC MACT or 40 CFR Part 63, Subpart LLL) HCl emission limit.
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Presidential Executive Order Targets NSPS Subpart OOOOa Regulations
Posted: March 31st, 2017
In June 2016, we wrote about the arrival of 40 CFR Part 60 Subpart OOOOa – Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced After September 18, 2015 for the oil and gas…
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Toxics Release Inventory Reporting for Natural Gas Processing Facilities
Posted: March 26th, 2017
(Update March 2017): After requests from stakeholders for an extension for comments on the EPA’s proposed addition of natural gas processing facilities to the Toxics Release Inventory, EPA has extended the comment period on the proposal. An additional 60 days have…
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Turning 15!
Posted: March 23rd, 2017
I am the proud father of a 15-year old son at home and the proud “father” of a 15-year old company. I love observing my son in his life journey as he is figuring himself out through the teen-age years. He is building on the foundation…
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Goodbye Exemption No. 38, Hello GP-5A: Changes on the Horizon for the Pennsylvania Natural Gas Industry
Posted: March 23rd, 2017
UPDATE (3/23/17): PADEP has posted drafts of the GP-5 and GP-5A permits for the natural gas industry. In addition, a draft of the revised Air Quality Permit Exemptions list with modifications to the Exemption Category No. 38 requirements has also been posted. The deadline…
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Is Your Continuous Monitoring Data Leaving You Vulnerable and Exposed?
Posted: March 21st, 2017
The U.S. EPA announced, in a 2013 blog, the terminology “NextGen” (U.S. EPA’s Next Generation of Compliance and Enforcement) and its five interconnected components. Fast-forward to the Spring of 2017…the U.S. EPA is continuing to implement their NextGen…
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