• EPA’s New Owner Clean Air Act Audit Program for Oil and Gas Exploration Facilities  - 

    As a part of its renewed emphasis on encouraging companies to audit and correct environmental violations, the U.S. Environmental Protection Agency (EPA) has prepared a draft version of a New Owner Clean Air Act Audit Program (Audit Program or draft »

  • New Developments in the Ongoing Saga for Major Source Determinations  - 

    In the world of the Clean Air Act, being a major source is a big deal. You have to get a Title V operating permit. You probably have to comply with one or more National Emission Standards for Hazardous Air Pollutants (NESHAPs). You have to prepare »

  • Summary of the RMP Reconsideration Rule  - 

    BackgroundOn May 30, 2018, EPA published the proposed Risk Management Program (RMP) Reconsideration Rule (83 FR 24850), which makes significant changes to the RMP Final Rule finalized on January 13, 2017 (82 FR 4594). The proposed Reconsideration »

  • NSR Reform - Living with Uncertainty  - 

    If you live in a world where New Source Review (NSR) laws, regulations, and guidance documents are part of your everyday conversation, you may be a little on edge right now. Feeling uncertain about the future direction of the NSR program is normal »

  • DC Court Vacates RMP Delay Rule  - 

    On August 17, 2018 the DC Circuit Court vacated the RMP Delay Rule, impacting the effective date of the January 2017 Final Rule provisions. The court held that EPA was inconsistent in its actions and did not have statutory authority for a delay »

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