4 The Record is a publication from ALL4’s team that takes an in-depth look at technical and regulatory topics.
Tightening the Reins on GHG Emissions
Posted: March 7th, 2016
The Obama Administration announced its “Strategy to Reduce Methane Emissions from the Oil and Gas Sector” (Strategy) in March 2014 outlining the steps that the Administration will take towards reducing United States (U.S.) greenhouse gas (GHG) emissions by 17 percent […]
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Refinery Sector Rule Update: Compliance Dates for Flares and What You Should Be Doing Now
Posted: March 2nd, 2016
Back in December, the final Refinery Sector Rule (RSR) was published in the Federal Register, which outlined several new requirements for refinery flares. If you own or operate a refinery that has a flare, or plan to install a flare in the future, then you’ll want to know the new…
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Proposed Alignment of the Oil and Gas Sector GHG Reporting Rule (Subpart W) With NSPS OOOOa
Posted: March 2nd, 2016
On January 29, 2016, U.S. EPA proposed revisions to 40 CFR Part 98 Subpart W – Mandatory Greenhouse Gas (GHG) Reporting for Petroleum and Natural Gas Systems (Subpart W). These proposed revisions come not long after several other new reporting requirements were…
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Technical Staff Representative
Posted: February 29th, 2016
What a year 2015 was. But it is in the books and we are on to 2016! 2016 will bring more events, more headlines, and more technological advances than we have ever seen before. 2016 will also be a year of new roles and new responsibilities for some of us. I would…
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RACT 2 Methods of Compliance
Posted: February 27th, 2016
The revised Final-Form Reasonably Available Control Technology (RACT) 2 Rule was approved by the Pennsylvania Environmental Quality Board (EQB) on November 17, 2015. Although the final form of the RACT 2 rule has not yet been published in the Pennsylvania Bulletin, it is already…
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Why Facilities Should Be Proactive Rather Than Reactive – Amendments to the Risk Management Program Rule
Posted: February 26th, 2016
UPDATE (2/26/2016): As a follow-up to my blog below regarding upcoming changes to the Risk Management Program, U.S. EPA has released a prepublication rule. EPA will hold a public hearing in Washington, D.C…
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More “Clarifying” Proposed Amendments to Refinery Sector Rule
Posted: February 16th, 2016
On February 9, 2016, U.S. EPA issued proposed amendments to the December 1, 2015 published Refinery Sector Rule [i.e., 40 CFR Part 63, Subparts CC (Refinery MACT 1 ) and UUU (Refinery MACT 2) and, 40 CFR Part 60, Subparts J and Ja]. I know what you’re thinking….
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The Secret to Your Environmental Permitting Challenges – A PAL Permit
Posted: February 12th, 2016
As the one in charge of dealing with environmental issues at your facility the following “hypothetical” conversation with your Plant Manager or engineering group may sound familiar. Plant Manager: “We have a project in the works that with a few […]
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Report on Pennsylvania’s Methane Reduction Plan, General Permit for Well Pads, and GP-5 Modifications
Posted: February 12th, 2016
The agenda for the Air Quality Technical Advisory (AQTAC) meeting on February 11, 2016 included the following informational items pertaining to the natural gas industry. 1. Pennsylvania’s Methane Reduction Strategy…
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RACT 2 – I have less than a year to comply!? What should I be doing now?
Posted: February 12th, 2016
Wow! Raise your hand if you can’t believe that you are now less than one (1) year away from the final compliance deadline for the Pennsylvania Reasonably Available Control Technology (RACT 2) regulations? That’s right – even though the final form of the rule has not…
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