• 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 »

  • Final Rule Revising National Minimum Criteria to 2015 Coal Combustion Residuals (CCR) Rule  - 

    On April 17, 2015, the Environmental Protection Agency (EPA) promulgated national minimum criteria for existing and new coal combustion residuals (CCR) landfills and existing and new CCR surface impoundments. With the most recent rulemaking, EPA is »

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