4 The Record is a publication from ALL4’s team that takes an in-depth look at technical and regulatory topics.
Final Amendments to 40 CFR Part 60 Subpart OOOO
Posted: August 14th, 2013
On August 2, 2013, the U.S. Environmental Protection Agency (U.S. EPA) finalized revisions to the storage vessel provisions of 40 CFR Part 60 Subpart OOOO – Standards of Performance for Crude Oil…
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Clearer Water? – EPA Proposes Electronic Reporting and Transparency for NPDES Facility Information
Posted: August 13th, 2013
On July 30, 2013, U.S. EPA continued its move toward more transparency of environmental information by proposing the National Pollutant Discharge Elimination System (NPDES) Electronic Reporting Rule…
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Five Considerations of Being a CISWI Unit
Posted: August 1st, 2013
With so much talk of boilers and heaters since the 4 Rules were published in early 2013, most facilities are focused on developing an understanding and strategy to comply with the Maximum Achievable Control Technology (MACT) standards for Boilers (commonly […]
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A Petition to U.S. EPA for a Rulemaking and Interpretive Guidance Coverage Pertaining to Methane Sources
Posted: July 29th, 2013
On March 19, 2013, Clean Air Task Force (CATF), Environmental Defense Fund (EDF), Natural Resources Defense Council (NRDC), and Sierra Club (hereto, collectively referred to as the “Petitioners”) submitted…
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7th Circuit Court of Appeals Upholds Statute of Limitation in NSR Enforcement Case
Posted: July 26th, 2013
In a very interesting ruling that, at first glance, would appear to have major ramifications to how U.S. EPA pursues New Source Review (NSR) enforcement cases…
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You are NOT Subject to a NESHAP Standard…Now What?
Posted: July 23rd, 2013
With all of the activity surrounding National Emission Standards for Hazardous Air Pollutants (NESHAPs) lately (boilers, internal combustion engines, and a slew of new and sometimes obscure area source standards)…
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Nice While It Lasted: Biogenic CO2 Exemption From Tailoring Rule Struck Down
Posted: July 22nd, 2013
The D.C. Circuit Court threw out the biogenic CO2 exemption from air permitting activities under the Federal Greenhouse Gas (GHG) Tailoring Rule on July 12, 2013…
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Policy On Public Participation
Posted: July 2nd, 2013
The Pennsylvania Department of Environmental Protection (PADEP) has issued a draft revised guideline for public participation in the permit review process for permits or other applicable authorization application submitted for Department review. The draft document establishes…
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The President’s “Climate Action Plan”
Posted: July 2nd, 2013
On June 25, 2013 President Obama released his much anticipated Climate Action Plan (Plan). Driving home the point that changes to cut our carbon pollution should be done to forge a better tomorrow for our future generations…
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Addressing Environmental Justice in the Permitting Process
Posted: June 28th, 2013
On February 11, 1994, Executive Order 12898 Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations was issued. Executive Order 12898 calls on each Federal agency to make achieving environmental justice part of its mission. Since that […]
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