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Permitting Flexibility & Cost Saving Opportunities for Atlanta Metro Facilities

On June 21, 2018, the changes to Georgia’s permitting requirements for the Atlanta metro area became effective.  Facilities have opportunities to improve permit flexibility or possibly simplify permitting (and save costs) by downgrading permit status.  Some Title V facilities may become Synthetic Minors, while Synthetic Minors may become True Minors.  These downgrades could save facilities ...

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EPA Issues San Antonio Ozone Nonattainment Designations

On July 17, 2018, U.S. EPA issued the area designations for the 2015 ozone standards for eight counties in Texas, encompassing the San Antonio metropolitan area.  The designations will take effect 60 days from the date of Federal Register publication and will address the following counties: Atascosa, Bandera, Comal, Guadalupe, Kendall, Medina, and Wilson – ...

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EPA Issues Common Control Revised Interpretation Analysis

On April 30, 2018, EPA issued a letter to Pennsylvania Department of Environmental Protection (PADEP) responding to a request to review a document submitted on behalf of Meadowbrook Energy LLC (Meadowbrook) concerning whether emissions from a biogas processing facility under development by Meadowbrook should be aggregated with the co-located landfill owned by Keystone Sanitary Landfill, ...

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Making Compliance Plans Effective

Background Environmental regulations are established to minimize the impact a company and their operations can have on the environment. In many instances, compliance plans are a requirement of a regulation. Examples of compliance plans include Storm Water Pollution Prevention Plans (SWPPP), Spill Prevention Control and Countermeasures (SPCC) Plans, and Hazardous Waste Contingency Plans.  Compliance plans ...

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EPA Reverses MACT Once-In-Always-In Policy

On January 25, 2018, EPA issued a guidance memo reversing its long-held policy that a major source of HAP must stay subject to MACT standards, even if it subsequently reduces its HAP emissions to minor (area) source levels (i.e., the “once-in-always-in” policy). Now, EPA is stating that HAP major sources can reduce their emissions to ...

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The Business of the Environment

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