epa subpart Articles

  • Navigating NSPS subpart Db for boilers: a case study

    Over the past year, Trinity assisted a chemical company with the permitting and installation of a new 220 MMBtu/hr package boiler. The new natural gas-fired boiler replaces coal-fired units that were installed in the 1940s. Navigating through the numerous, and at times conflicting, regulatory requirements applicable to such a unit has been challenging. With careful planning and implementation, ...


    By Trinity Consultants

  • EPA finalizes boiler NESHAP

    EPA published the final National Emission Standards for Hazardous Air Pollutants (NESHAP) for industrial, commercial, and institutional boilers and process heaters at both major and area sources of hazardous air pollutants (HAP) emissions. EPA developed separate rules for units at major sources of HAP emissions (greater than 10 tons per year [tpy] of any single HAP and/or greater than 25 tpy of ...


    By Trinity Consultants

  • EPA mandatory reporting of GHGs rule

    Recent EPA Guidance EPA does not intend for the calibration requirements of 98.3(i) to apply to any units where the rule allows the use of “company records” to quantify fuel usage or other parameters; however, a facility’s GHG monitoring plan must include descriptions of the procedures and methods used for quality assurance, maintenance, repair of all flow meters ...


    By Trinity Consultants

  • U.S. EPA Proposes Overdue Refinery Air Rules

    U.S. EPA officially published revisions to the Maximum Achievable Control Technology (MACT) and New Source Performance Standards (NSPS) Refinery Air Rules (i.e., 40 CFR Part 60 Subparts J and Ja, and 40 CFR Part 63 Subparts CC and UUU, Refinery MACT 1 and Refinery MACT 2, respectively) today, ...


    By All4 Inc.

  • EPA proposes updates to CISWI rules

    On June 4, 2010, the U.S. EPA proposed updates to the Standards of Performance for New Stationary Sources (NSPS) for Commercial and Industrial Solid Waste Incineration (CISWI) Units (NSPS Subpart CCCC) and Emission Guidelines (EG) for Existing CISWI Units (EG Subpart DDDD), collectively referred to as the "CISWI Rules." In order to describe the proposed updates to the CISWI Rules, it is necessary ...


    By Trinity Consultants

  • EPA proposes revisions to GHG mandatory reporting rule for stationary combustion sources

    This summer, EPA proposed several updates and amendments to the GHG Mandatory Reporting Rule (40 CFR Part 98). This activity is consistent with EPA’s stated intention to issue amendments and re-propose subparts (i.e., those subparts that were initially reserved upon finalization of the rule last October) by the end of 2010. EPA’s published revisions in the Federal Register on June 15, ...


    By Trinity Consultants

  • EPA Proposed “Franken-MACT” for Utilities

    EPA published the highly anticipated proposed Maximum Available Control Technology (MACT) Standard for the utility sector (40 CFR 63 Subpart UUUUU). When considered together with the growing list of proposed and final rules impacting the utility sector (Transport Rule/Cross-State Rule, Coal Combustion Byproducts Rule, Cooling Water Intake Rule, Regional Haze Rule, revised National Ambient Air ...


    By Trinity Consultants

  • Preparing for EPA’s mandatory reporting of greenhouse gases rule

    Recent action by the US EPA to finalize the Mandatory Reporting of Greenhouse Gases (GHG) Rule means that environmental managers must now seriously examine whether they are fully prepared to address the imminent requirements. This article provides some assistance by summarizing key points regarding the final versus proposed rule, providing clarification on key questions that have arisen since the ...


    By Trinity Consultants

  • Tuning Your Boiler for EPA Boiler MACT Compliance

    The EPA’s Boiler MACT regulations are heating up. Boiler MACT is an EPA rule to limit hazardous air pollutants (HAP) from commercial and industrial boilers and process heaters. Originally proposed in 2011 as a mandate driven by the Clean Air Act,  the rules are Area Source Boiler MACT 40 CFR 63, subpart JJJJJJ for smaller boilers (stores, hotels, apartments, ...


    By Sierra Instruments, Inc.

  • EPA Proposes Revisions to RCRA Definition of Solid Waste

    On June 30, 2011, U.S. Environmental Protection Agency (EPA) Administrator Lisa Jackson signed a proposed rule seeking to narrow certain recycling exemptions under the Resource Conservation and Recovery Act's (RCRA) "Definition of Solid Waste" (DSW) provisions. The rule should be published in the Federal Register within the next two weeks. A pre-publication copy of the rule and related ...


    By Bergeson & Campbell, P.C.

  • The Hammer Falls Again as U.S. EPA Proposes Revisions to `MACT Hammer` Regulations

    Until now, States have been left to interpret the applicability of section 112(j) with little input from U.S. EPA. Some States have adopted a “wait and see” approach and are waiting for U.S. EPA to weigh in on the issue. In the absence of any guidance, some States, such as Pennsylvania, have called for some sources to submit applications that meet the 112(j) requirements. The ...


    By All4 Inc.

  • U.S. EPA Proposes Substantial Refinery Flare Operating and Monitoring Requirements

    U.S. EPA is proposing to amend the operating and monitoring requirements for flares at petroleum refineries.  The proposed revisions are complex and are far reaching, and if promulgated, will affect all flares at petroleum refineries.  U.S. EPA’s stated rationale for the proposed revisions is that the ...


    By All4 Inc.

  • EPA Releases Guidance Document: Antimicrobial Pesticide Use Site Index

    On July 24, 2015, the U.S. Environmental Protection Agency (EPA) issued a Federal Register notice extending the public comment period regarding its proposed Antimicrobial Pesticide Use Site Index (USI) from July 31, ...


    By Bergeson & Campbell, P.C.

  • U.S. EPA Proposed Benzene Fenceline Monitoring for Refineries Amongst Other MACT and NSPS Changes

    U.S. EPA has proposed an amendment to 40 CFR Parts 63, Subpart CC and Subpart UUU that requires all petroleum refineries to deploy passive time-integrated benzene samplers at the fenceline (where fenceline is equivalent to the facility property line) of their facility to alert them of fugitive emissions from leaks of Subpart ...


    By All4 Inc.

  • Measurement of Sulfur in Refinery Flare Gas Streams for Compliance with EPA SubpartJ(a) Regulations

    The Challenge Measurement of high range and low range H,S in refinery flare gas streams for compliance with EPA regulation NSPS Subpart J(a). The rule has placed an extra investment and operational burden on petroleum refineries to meet the regulatory requirement. AMETEK offers an economical solution to meet the challenge with an emphasis on lower capital and operating cost along with ...

  • U.S. EPA`s Proposed Greenhouse Gas Standards for the Utility Industry - How Powerful Are They?

    A major event in the Climate Change arena occurred on March 27, 2012 when, for the first time, U.S. EPA proposed Standards of Performance for New Stationary Sources (NSPS) for emissions of carbon dioxide (CO2).  The proposed standards were specific to new affected fossil fuel-fired electric utility ...


    By All4 Inc.

  • EPA Issues Interim Guidance Concerning Antimicrobial Data Requirements

    On Thursday, April 30, 2015, the U.S. Environmental Protection Agency (EPA) issued interim guidance that it intends to clarify its toxicology data requirements for antimicrobial pesticides used on food contact surfaces.  In addition,  ...


    By Bergeson & Campbell, P.C.

  • Legal Lookout: EPA Proposes Lead-Based Paint Removal Requirements

    Untitled Document On Jan 10, 2006, EPA proposed extensive requirements to minimize the introduction of lead hazards resulting from the disturbance of lead-based paint during ...


    By Bergeson & Campbell, P.C.

  • U.S. EPA Promulgates Final Air Toxics Standards for Compression Ignition Reciprocating Internal Combustion Engines (RICE)

    On March 3, 2010, U.S. EPA promulgated final National Emissions Standards for Hazardous Air Pollutants (NESHAP) for existing compression ignition (CI) stationary Reciprocating Internal Combustion Engines (RICE) that were not previously regulated by the existing, so called, RICE MACT (i.e., 40 CFR Part 63, Subpart ZZZZ).  The RICE MACT rule was originally promulgated in 2004.  The March ...


    By All4 Inc.

  • QuadOa and OGI: how EPA regulations are changing the way we look at gas leaks

    Earlier this year, the Environmental Protection Agency (EPA) published Regulation 40 CFR, Part 60, Sub-part OOOOa, commonly known as Quad Oa, and finally brought optical gas imaging (OGI) firmly into the mainstream. This presents a major shift in the way fugitive emissions are regulated, and the technology that can be used.  Detecting and acting on gas leaks is naturally a major ...

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