4 The Record is a publication from ALL4’s team that takes an in-depth look at technical and regulatory topics.
RACT 2 Methods of Compliance
Posted: February 27th, 2016
The revised Final-Form Reasonably Available Control Technology (RACT) 2 Rule was approved by the Pennsylvania Environmental Quality Board (EQB) on November 17, 2015. Although the final form of the RACT 2 rule has not yet been published in the Pennsylvania Bulletin, it is already…
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Why Facilities Should Be Proactive Rather Than Reactive – Amendments to the Risk Management Program Rule
Posted: February 26th, 2016
UPDATE (2/26/2016): As a follow-up to my blog below regarding upcoming changes to the Risk Management Program, U.S. EPA has released a prepublication rule. EPA will hold a public hearing in Washington, D.C…
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More “Clarifying” Proposed Amendments to Refinery Sector Rule
Posted: February 16th, 2016
On February 9, 2016, U.S. EPA issued proposed amendments to the December 1, 2015 published Refinery Sector Rule [i.e., 40 CFR Part 63, Subparts CC (Refinery MACT 1 ) and UUU (Refinery MACT 2) and, 40 CFR Part 60, Subparts J and Ja]. I know what you’re thinking….
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The Secret to Your Environmental Permitting Challenges – A PAL Permit
Posted: February 12th, 2016
As the one in charge of dealing with environmental issues at your facility the following “hypothetical” conversation with your Plant Manager or engineering group may sound familiar. Plant Manager: “We have a project in the works that with a few […]
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RACT 2 – I have less than a year to comply!? What should I be doing now?
Posted: February 12th, 2016
Wow! Raise your hand if you can’t believe that you are now less than one (1) year away from the final compliance deadline for the Pennsylvania Reasonably Available Control Technology (RACT 2) regulations? That’s right – even though the final form of the rule has not…
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Report on Pennsylvania’s Methane Reduction Plan, General Permit for Well Pads, and GP-5 Modifications
Posted: February 12th, 2016
The agenda for the Air Quality Technical Advisory (AQTAC) meeting on February 11, 2016 included the following informational items pertaining to the natural gas industry. 1. Pennsylvania’s Methane Reduction Strategy…
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Brace Yourself – 2016 Chemical Data Reporting is Coming
Posted: February 8th, 2016
2016 is special not only because it is a leap year, but it is also a reporting year in the Toxic Substances Control Act (TSCA) Chemical Data Reporting (CDR) rule cycle. Every four (4) years (the previous report was required in 2012), manufacturers of TSCA regulated chemicals must…
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February Ain’t What It Used to Be – Major Source Boiler MACT Compliance is Upon Us
Posted: February 3rd, 2016
February is exciting enough with Valentine’s Day, the Super Bowl, and particularly for 2016, those leap year birthdays! However, this February brought with it another exciting event – the Major Source Boiler MACT compliance date. Now that it has arrived, there are plans to prepare…
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Don’t Let Great People Hold You Back
Posted: February 3rd, 2016
Relax. I’m not trying to convince you that great people (GPs) aren’t that great. I’ll take GPs over crazy or mean any day. Just hear me out…err, read me out. I’ll start off by saying this is a sore spot for me because…
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Wait…We Have to Report our Generator Use to U.S. EPA?
Posted: January 19th, 2016
Kayla T. introduced you to the terms Compliance and Emissions Data Reporting Interface (CEDRI) and Central Data Exchange (CDX) through her recent blog, ERT and CEDRI: What the Heck Is It and How Does It Impact You? Reports to the U.S. Environmental Protection Agency (U.S. EPA)…
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