4 The Record is a publication from ALL4’s team that takes an in-depth look at technical and regulatory topics.
Preparing for the First GHG Report Under the Revised Subpart W Provisions
Posted: October 24th, 2016
As we talked about in our December 2015 blog post, U.S. EPA finalized amendments to the 40 CFR Part 98 Mandatory Greenhouse Gas (GHG) Reporting Rule on October 22, 2015, which affected facilities in the Petroleum and Natural Gas Systems industry which are regulated…
Read articleWhat’s Being Reconsidered in the Refinery Sector Rule?
Posted: October 13th, 2016
On October 5, 2016, U.S. EPA announced reconsideration of issues raised in petitions submitted for sections of the Refinery Sector Rule (RSR) [i.e., 40 CFR Part 60, Subparts J and Ja and 40 CFR Part 63, Subparts CC (Refinery MACT […]
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As the seasons change, so will your Performance Test Methods (Potentially)!
Posted: October 6th, 2016
As the season changes from summer to fall, so will most of your performance test methods and performance specifications. U.S. EPA issued a final rule on August 30, 2016 to make technical and editorial corrections and updates to testing provisions. The revisions…
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The OOOOa Initial Compliance Period Began! Time is Running Out.
Posted: October 3rd, 2016
The New Source Performance Standards (NSPS) at 40 CFR Subpart OOOOa (Subpart OOOOa) became effective on August 2, 2016. This means that owners and operators with affected sources must be in compliance with the Subpart OOOOa standards starting…
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Electronic Reporting for the Secondary Aluminum Industry
Posted: September 26th, 2016
As Chuck described in his January blog, the Subpart RRR amendments include provisions requiring that performance test data to be electronically submitted through the U.S. Environmental Protection Agency (U.S. EPA) Electronic Reporting Tool (ERT). While E-reporting…
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Proposed Information Collection Request for the Plywood and Composite Wood Products NESHAP and Implications for the Industry
Posted: September 22nd, 2016
On September 8, 2016, the U.S. Environmental Protection Agency (U.S. EPA) published a proposed Information Collection Request (ICR) for the Plywood and Composite Wood Products (PCWP) National Emission Standards for Hazardous Air Pollutants…
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So You Want to Be a Consultant, Why ALL4? (An Open Letter to College Seniors)
Posted: September 6th, 2016
September is upon us and daylight is fading each day, a constant reminder of summer’s inevitable fate. Although summer is coming to a close, it allows for the beginning of something new. For you – the beginning of your final year as a college undergraduate…
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Boiler MACT Vacatur and Remand: The Details Unfold
Posted: August 29th, 2016
As I wrote about in my last post, the United States Court of Appeals for the District of Columbia Circuit (“D.C. Circuit Court” or “Court”) issued an opinion on July 29, 2016 regarding three related rules for boilers, process heaters, […]
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2016 Chemical Data Reporting in Full Swing
Posted: August 29th, 2016
In our February blog post “Brace Yourself – 2016 Chemical Data Reporting is Coming”, we talked about 2016 being a reporting year in the Toxic Substances Control Act (TSCA) Chemical Data Reporting (CDR) rule cycle. This report is due every four years and requires…
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RACT 2 – T Minus 2 Months 2 Go
Posted: August 24th, 2016
You have likely heard about RACT 2 at this point, but you may not have yet acted on what you’ve heard. Human nature is bent toward procrastination. We get it and that’s part of why we’re here. The proposal deadline for RACT 2 submittals is quickly approaching whether you’ve…
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