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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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EPA Updates to the Refrigerant Management Regulations

EPA has updated the refrigeration management regulations of 40 CFR Part 82 – Section 608, that became effective on January 1, 2017. Previously exempt refrigeration and comfort cooling appliances containing greater than 50 pounds of refrigerant substitutes like hydrofluorocarbons (HFCs), hydrofluoroolefins (HFOs), perfluorocarbons (PFCs), and R-134a are now subject to this regulation. Section 608 of ...

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EPA’s Revisions to EPCRA 312 Tier II Reporting

EPA has issued revisions to 40 CFR Part 370 that affect Tier I and Tier II reporting under Sections 311 and 312 of the Emergency Planning and Community Right to Know Act (EPCRA). The revisions affect the Tier II report due March 1, 2018 for the 2017 reporting year. The changes are intended to align ...

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