Poking 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…
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CISWI 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…
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Getting 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 […]
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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.
Read articlePresidential 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…
Read articleToxics 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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