4 The Record is a publication from ALL4’s team that takes an in-depth look at technical and regulatory topics.
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…
Read articleRACT 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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Who’s Next?
Posted: August 18th, 2016
The years really do fly by. Most of the folks I started my career with back in the early ‘70s have already retired and the remaining die-hards are certainly counting the days. Here at ALL4 we’ve been expending serious energy over the last few years with succession planning…
Read articleDon’t Fall out of Compliance with RACT 2
Posted: August 18th, 2016
Summer is practically over, fall is almost here, and Halloween costumes are already out. Although your local retail stores are prepared for October, are you? Your facility’s RACT 2 proposal is due in nearly two months on October 24, 2016. If you followed…
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D.C. Circuit Court Issues Remand and Vacatur of Certain Boiler MACT and CISWI Provisions
Posted: August 9th, 2016
On July 29, 2016, the United States Court of Appeals for the District of Columbia Circuit (D.C. Circuit Court) issued a decision regarding three rules for boilers, process heaters, and incinerators…
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