4 The Record is a publication from ALL4’s team that takes an in-depth look at technical and regulatory topics.
Vacatur of NSPS Subpart OOOOa Stay and More Litigation on the Horizon
Posted: July 14th, 2017
(UPDATE 7/14/17): On July 13, 2017, the U.S. Court of Appeals for the D.C. Circuit granted the U.S. EPA a 14-day extension to comply with the court’s earlier decision vacating U.S. EPA’s stay of certain 40 CFR Part 60, Subpart OOOOa (Subpart OOOOa) provisions. The extension…
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Proposed Virginia Air Permit Program Fees
Posted: July 14th, 2017
Title V of the Clean Air Act (Title V) requires that states develop operating permit programs funded by fees paid by owners or operators of major stationary sources regulated under the programs. Virginia’s State Air Pollution Control Board (Control Board) recently…
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SPCC Plans – Some Pitfalls of Oil Spill Prevention, Control, and Countermeasure Compliance
Posted: July 10th, 2017
Does your facility have a Spill Prevention, Control and Countermeasure (SPCC) Plan? When is the last time you reviewed it? Is it up to date? Have you kept track of all minor facility changes that materially affect potential discharges? Are you on track to complete…
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Further Delay of Implementation of Certain NSPS Subpart OOOOa Requirements
Posted: June 29th, 2017
On June 5, 2017, the U.S. Environmental Protection Agency (U.S. EPA) granted reconsideration and stayed the effectiveness of certain fugitive emissions, pneumatic pump, and Professional Engineer (P.E.) certification requirements of 40 CFR Part, 60 Subpart-OOOOa Standards of Performance…
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Boiler MACT Update and Preparing for your July Report
Posted: June 20th, 2017
Things have been fairly quiet with respect to Boiler MACT lately…or so it may seem. With the next semiannual report due by July 31, here’s an update on what you need to know…
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New to Air Quality or All4 Inc.? Well so am I.
Posted: June 19th, 2017
Never in a million years would I have thought there was so much that went into Air Quality. I guess the average person takes for granted all that’s regulated and expected into keeping our air clean. What I’m learning is that reaching out to that expert can be like your own insurance policy…
Read articleRefinery MACT I – Do You Really Know What Your DAHS is Doing?
Posted: June 15th, 2017
By now, I’m sure you have familiarized yourself with 40 CFR Part 63, Subpart CC – National Emission Standards for Hazardous Air Pollutants from Petroleum Refineries (Refinery MACT I) and you have (hopefully) developed a compliance strategy for the new requirements that apply…
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TCEQ Air Quality 101 Blog Series – NSR Permitting
Posted: June 6th, 2017
In late March, I had the opportunity to participate in an event called the Texas Independence Relay (TIR), which is a 2-day, 10-person running event from Gonzales through Houston, covering 200 miles from start to finish. The relay commemorates the independence of the State of Texas…
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U.S. EPA Grants Reconsideration of Additional NSPS Subpart OOOOa Provisions
Posted: June 5th, 2017
As reported in our blog, U.S. Environmental Protection Agency (U.S. EPA) announced in an April 18, 2017 letter to oil and gas industry groups that it was reconsidering certain fugitive emissions monitoring requirements of the 40 CFR Part 60 Subpart OOOOa Standards of Performance…
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Public and Industry Comment on Regulatory Reform
Posted: June 4th, 2017
This past April, Lindsey wrote about U.S. EPA’s Regulatory Reform Task Force seeking public input for potential repeals, replacements, or modifications of existing regulations as directed by President Trump’s Executive Order (EO) 13777. Written comments were due by May 15, 2017 and…
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