Marcellus Shale – The Saga Continues…Or Does It?
Posted: August 17th, 2011
On May 30, 2011, New York Governor Andrew Cuomo’s office issued an order giving the New York State Department of Environmental Conservation (NYSDEC) until July 1, 2011 to complete a draft of an Environmental Impact Statement (EIS) outlining the processes […]
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PM2.5: Repeal and Reminder
Posted: June 25th, 2011
U.S. EPA has repealed the Prevention of Significant Deterioration (PSD) “Grandfathering” provision for particulate matter with an aerodynamic diameter of less than 2.5 microns (PM2.5). Facilities that submitted PSD construction permit applications prior to the promulgation of the PM2.5 New […]
Read articleMarcellus Shale in New York – The Saga Continues
Posted: June 20th, 2011
While numerous drilling operations in Pennsylvania and West Virginia have begun to tap the vast natural gas resources in the Marcellus Shale formation during the past several years, New York has been, to put it mildly, reluctant to join the […]
Read articleBoiler MACT…Yes…No…Maybe?
Posted: June 10th, 2011
Many questions surround the logic that U.S. EPA used to develop the emission limits contained in the Boiler MACT. One potential flaw identified by those petitioning U.S. EPA for judicial review of the Boiler MACT is the establishment of…
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EPA Provides New Source Review (NSR) “Netting” Guidance
Posted: April 17th, 2011
In a recent letter dated April 4, 2011 to the Indiana Department of Environmental Management (IDEM), U.S. EPA clarified its position on conducting “Step 2” of a New Source Review (NSR) permitting applicability analysis (determine the net emissions increase). This […]
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Pennsylvania Plan Approval Expiration Date/Duration Revisions
Posted: March 23rd, 2011
Facilities in Pennsylvania should be aware of a recent change in the interpretation of standard Plan Approval (i.e., construction permit) language regarding Plan Approval duration and “shakedown” periods. The change impacts the temporary operation of a new, or newly modified, […]
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Reality Check: BACT for GHG Emissions?
Posted: February 7th, 2011
Greenhouse gas (GHG) emissions are now officially addressed by new source permitting rules. The “Tailoring Rule” requires that sources get serious about addressing project-related GHG emissions when preparing Prevention of Significant Deterioration (PSD) permit applications. When a source is unable […]
Read articleBoiler MACT and CISWI Test Data Available On-Line
Posted: February 10th, 2010
Last summer, U.S. EPA notified over 100 facilities that they were being called upon to conduct stack testing as part of the Agency’s information gathering efforts to address the vacated National Emissions Standards for Hazardous Air Pollutants for Industrial, Commercial, […]
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U.S. EPA Identifies Additional Industries for Possible Financial Responsibility
Posted: January 9th, 2010
On January 6, 2010, U.S. EPA published an advanced notice of proposed rulemaking (ANPRM) in the Federal Register that identifies additional classes of facilities within three (3) industries for which it plans to develop proposed requirements for financial responsibility under […]
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U.S. EPA Proposes to Withdraw Emission Comparable Fuel Exclusion
Posted: December 22nd, 2009
The December 8, 2009 Federal Register included a notice that U.S. EPA is proposing to withdraw certain provisions of the Resource Conservation and Recovery Act (RCRA) rule under Subtitle C that provide for the exclusion of comparable fuel, emission-comparable fuel […]
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