Spare Parts and Permit Conditions
Posted: September 25th, 2012
A seemingly simple question was recently raised by an ALL4 client regarding the level of spare parts inventories that facilities are obligated to keep on hand for air pollution control equipment, as required by applicable air permits…
Read article
September 2012 Pennsylvania Air Quality Technical Advisory Committee Update
Posted: September 17th, 2012
The September 2012 Air Quality Technical Advisory Committee (AQTAC) meeting was held on Wednesday, September 12th. The agenda was very full, with three proposals that the Pennsylvania Department of Environmental Protection (PADEP) was seeking approval…
Read article
Mind Your NAAQS: An Update
Posted: September 17th, 2012
The pre-election regulatory lull is in full swing, so we thought it was a good time to get fully caught up on the latest National Ambient Air Quality Standards (NAAQS) news…
Read articleU.S. EPA Proposed NSPS Revisions – Stationary Gas Turbines and Stationary Combustion Turbines
Posted: September 10th, 2012
In the August 29, 2012 Federal Register, U.S. EPA published a proposal to amend various portions of the New Source Performance Standards (NSPS) for Stationary Gas Turbines (40 CFR Part 60 Subpart GG) and Stationary Combustion Turbines (40 CFR Part 60 Subpart KKKK)…
Read article
Recent Non-Hazardous Secondary Material (NHSM) Determinations
Posted: September 10th, 2012
There has been a lull in U.S. EPA’s issuance of the “comfort” letters requested by the regulated community for non-hazardous secondary materials (NHSM) legitimacy determinations. However, the lull was recently broken…
Read articleMore Greenhouse Gas Reporting Rule Revisions
Posted: September 4th, 2012
On August 24, 2012 in Federal Register Vol.77, No 165, U.S. EPA announced the finalization of amendments to specific provisions of the Greenhouse Gas Reporting Rule. The amendments are intended to provide greater clarity and flexibility to facilities subject to…
Read article
Affirmative Defense Under NESHAP General Provision Requirements
Posted: August 29th, 2012
On October 16, 2009, the U. S. District of Columbia Circuit Court (the Fifth Circuit Court) vacated the “Startup, Shutdown, and Malfunction (SSM) exemption” allowed under the General Provisions in Part 63, Subpart A of the National Emission Standards for […]
Read articleCSAPR: The Latest U.S. EPA Casualty
Posted: August 27th, 2012
In a continuing trend, the DC Circuit Court (Court) handed U.S. EPA yet another loss in EME Homer City Generation LLC v EPA. The casualty this time: the Cross States Air Pollution Rule (CSAPR)…
Read articleGreenhouse Gas Confidentiality Determinations Finalized by U.S. EPA
Posted: August 24th, 2012
On August 13, 2012 in Federal Register Vol.77, No 156, U.S. EPA announced the finalization of confidentiality determinations for regulations under the Mandatory Greenhouse Gases Reporting Rule…
Read articleResidual Risk and Technology Review Completed for a Pulp and Paper Industry NESHAP
Posted: August 15th, 2012
On July 31, 2012, U.S. EPA finalized the residual risk and technology review conducted for the National Emission Standards for Hazardous Air Pollutants (NESHAP) for pulp and paper production areas of mills using the kraft, sulfite, semi-chemical, and soda pulping processes (40 CFR Part 63 Subpart S)
Read article