4 The Record is a publication from ALL4’s team that takes an in-depth look at technical and regulatory topics.
U.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)…
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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…
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More 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…
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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 […]
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ALL4’s: Is That Your Final Answer?
Posted: August 27th, 2012
Test your knowledge across the environmental field, on the building blocks of air quality rules, on ALL4 general trivia, and with brain teasers that have perplexed us…Take on ALL4’s Is That Your Final Answer?
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CSAPR: 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)…
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Greenhouse 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…
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You May Ask Yourself, “How Did I Get Here?”
Posted: August 23rd, 2012
At the age of 18, I thought the most important decision of my life was deciding which dress I should wear to prom. Looking back now, I see that I couldn’t have been more wrong…
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Source Aggregation and the Plain Meaning of “Adjacent”
Posted: August 17th, 2012
An interesting Court of Appeals decision was made by a three member panel of the Sixth Circuit this week (the Sixth Circuit is in Cincinnati and serves Michigan, Ohio, Kentucky and Tennessee). The case involves aggregation of sources for purposes of…
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Residual 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)
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