4 The Record is a publication from ALL4’s team that takes an in-depth look at technical and regulatory topics.
“Excuse me, can we have your continuous emissions monitoring system (CEMS) data?”
Posted: April 26th, 2018
In a March 29, 2018 memorandum, the U.S. EPA announced that the Office of Inspector General (OIG) for the U.S. EPA plans to begin research to “evaluate the data quality of emissions monitoring data from large stationary sources of air pollution…
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Proposed Amendments to Refinery MACT 1 and MACT 2 Regulations
Posted: April 24th, 2018
On March 19, 2018, the U.S. Environmental Protection Agency (U.S. EPA) proposed amendments to the National Emission Standards for Hazardous Air Pollutants (NESHAP) Refinery MACT 1 and Refinery MACT 2 regulations and the 40 CFR Part 60…
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NSR Reform 2018: Look to the Past
Posted: April 9th, 2018
The time for changes to the New Source Review (NSR) program is upon us. Our thinking at ALL4 is that the recent reversal in U.S. EPA policy regarding the accounting of emissions decreases from projects is just the beginning. We […]
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Proposed Pennsylvania Storage Tank and Spill Prevention Program Rule Revisions
Posted: March 26th, 2018
The Pennsylvania Environmental Quality Board (EQB) has proposed amendments to 25 Pa. Code Chapter 245 regarding the Storage Tank and Spill Prevention Program. The proposed amendments are required by the U.S. Environmental Protection Agency…
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Georgia Permittees (Major, Minor, and Synthetic Minor): Have You Heard the News?
Posted: March 22nd, 2018
On March 8, 2018, the Georgia Environmental Protection Division (GEPD) released a Notice of Public Hearing and Proposed Amendments to the Georgia Rules for Air Quality Control codified by the Georgia Administrative Code (G.A.C.) 391-3-1. Specifically…
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Are Pennsylvania Air Emissions and Permitting Fees on the Rise? – Update
Posted: March 21st, 2018
Last year I penned a blog regarding potential changes to emissions and permitting fees within Pennsylvania. The blog was based upon information provided by the Pennsylvania Department of Environmental Protection (PADEP) to the Air Quality…
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New Source Review Project Emissions Accounting Guidance Memorandum
Posted: March 15th, 2018
On March 13, 2018 the U.S. EPA issued a much-anticipated policy guidance memorandum titled “Project Emissions Accounting Under the New Source Review (NSR) Preconstruction Permitting Program”. The policy guidance is extremely important because…
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Proposed Revisions to Testing Regulations for Air Emissions Sources
Posted: March 8th, 2018
On January 26, 2018 the U.S. EPA published the proposed rule that revises testing regulations for air emissions sources. The proposed rule is currently open for public comments, which are due by March 27, 2018. The following discussion highlights some of the general…
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40 CFR Part 63, Subpart MM Amendments – What’s the Next Step for Pulp and Paper Mills?
Posted: March 5th, 2018
On October 11, 2017, U.S. EPA finalized revisions to 40 CFR Part 63, Subpart MM (National Emission Standards for Hazardous Air Pollutants for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand-Alone Semichemical Pulp Mills). The revisions…
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Demonstrating Compliance and the Importance of Permit Language (Sweat the Details)
Posted: February 28th, 2018
On the air quality side of the world of environmental compliance, ALL4 is seeing an increased emphasis on monitoring and recordkeeping, more specifically, electronic data and electronic reporting, as related to demonstrating compliance with permit requirements. Such data may be […]
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