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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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