| What's on ALL4's Calendar? |
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At ALL4, we like to get out and about -- whether presenting or taking part in technical and regulatory conferences. Stop by and see us at these upcoming events.
COMING SOON...
- ALL4's Training Schedule
- 4 The Record Extra! Boiler MACT 114 Requests |
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A Fine Particulate Series (Part 3): PM2.5 Prevention of Significant Deterioration (i.e., Attainment) - What You Need to Know |
 U.S. EPA's final rules (and policies) governing the implementation of the New Source Review (NSR) program for fine particulate matter (i.e., particulate matter with an aerodynamic diameter less than 2.5 microns, or PM2.5) are now being implemented. In the March 2009 issue of 4 The Record, ALL4's PM2.5 Team discussed the technical basics of PM2.5. Then, in the April 2009 issue, ALL4's PM2.5 Team provided details regarding PM2.5 and nonattainment New Source Review (NNSR). Part 3 of the series addresses PM2.5 and Prevention of Significant Deterioration (PSD) and includes a discussion on determining PSD applicability (or non-applicability), PM2.5 precursors, Best Available Control Technology (BACT) considerations, PM2.5 air quality modeling requirements, and timing and cost considerations when planning for PSD projects where PM2.5 emissions may be a factor.
- Background
- Determining PSD Applicability
- PSD Permit Application Preparation
- PSD Permitting Requirements
- PSD Air Quality Modeling Requirements
- Conclusions & End Notes
Please contact ALL4's Colin McCall at 610.933.5246 x20 or [email protected] should you have any questions related to PM2.5 permitting in attainment areas. |
| GUEST ARTICLE: A Practical Guide for Responding to Section 114 Requests |
 Receiving a request for information under Section 114 of the Clean Air Act (CAA or Act) can be an unnerving and overwhelming experience. U.S. EPA may collect information under Section 114 of the Act for various purposes, including for the development of a regulatory standard. However, Section 114 Requests are often, and most notably, used as an enforcement tool. This article will provide thoughts and insights for dealing with a U.S. EPA Section 114 Request, from both a legal and a technical perspective.
Read on as Manko, Gold, Katcher and Fox LLP's (MGKF's) Carol McCabe and ALL4's John Slade discuss:
- First Steps
- Gathering Information
- Developing a Reponse
- Interpreting U.S. EPA
- Responding Clearly
- Conclusion
Carol McCabe is a partner with MGKF. She counsels clients on a wide variety of environmental litigation and regulatory issues, including air permitting and compliance. MGKF is an environmental and energy law practice with trusted advisors who deliver innovative solutions to today's complex environmental and energy law compliance, transactional and litigation problems. ALL4 has been working with MGKF attorneys for over 15 years.
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ALL4 Signs Greater Philadelphia Green Business Commitment |
 ALL4 is excited to share that we've signed the Greater Philadelphia Green Business Commitment! Through this program, we support the Pennsylvania Environmental Council's (PEC's) "Sustainable Philadelphia" and PENJERDEL's "Green Vision" initiatives to promote the Philadelphia region as a green place to do business. ALL4 has joined the Commitment as a Basic Charter Member by already meeting the seven (7) mandatory measures and at least 20 additional measures required by the program - a nice reflection of the sustainable practices already underway at our Kimberton headquarters! Our "Green Office Working Committee" is energized to implement additional measures at ALL4 headquarters, increase awareness around sustainability in our local business community, and accept the challenge to become recognized as a Silver Member within our first six (6) months of membership. For more information, visit http://www.phillygreenbiz.com/.
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| Sladecast: Thoughts on Changes Coming from the New U.S. EPA |
 ALL4's John Slade shares his thoughts on the changes coming from the new U.S. EPA. Click here to listen. Please contact ALL4's John Slade at 610.933.5246 x36 or [email protected] should you want to hear more. | |
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| NJDEP Consideration of Health Risk from Internal Combustion Engines |
 The New Jersey Department of Environmental Protection's (NJDEP's) Subchapter 17 rules require facilities to consider air toxics when installing or modifying sources of air emissions. NJDEP has alerted facilities through their quarterly Industrial Stakeholder Group meeting that existing internal combustion engines that undergo permit modification will need to consider air toxic impacts as a result. NJDEP has found that the majority of existing internal combustion engines that undergo modifications do not pass the Level I Risk Screen criteria due to diesel particulate emission health risks. As a result, NJDEP has offered the following solutions that will assist facilities in meeting the Level I Risk Screen to reduce diesel particulate emissions:
- Limit the fuel sulfur content to no greater than 15 ppm sulfur.
- Retrofit the modified engine with a diesel particulate filter. Note that industrial representatives communicated that back pressure issues on retrofitted units are a problem and the cost of retrofitting the engines is anywhere from $10,000 to $15,000. NJDEP noted that the retrofit cost is reasonable due to the health risks.
- Increase the stack height and/or move the engine further from the existing fence line perimeter.
- Take an overall limit for operating the internal combustion engine(s) on site to reduce the overall health risk at the facility fence line, i.e., reducing the emission impact.
Please contact ALL4's Cara Fox at 610.933.5246 x23 or [email protected] for more information regarding NJ air quality assistance and/or considerations for existing internal combustion engines. |
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Juggling a lot of environmental responsibilities? |
 Are you really keeping track of all the environmental regulatory changes that could impact your facility?
What if you didn't have to worry about keeping up to date on environmental regulatory changes?
What if a customized environmental regulatory update report, EnviroReview, showed up in your inbox once a month? Hmmm...
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| McCarthy Confirmed by U.S. EPA |
 On June 2, 2009, the U.S. Senate voted to confirm the nomination of Ms. Regina McCarthy for the position of Assistant Administrator for the Office of Air and Radiation at the U.S. Environmental Protection Agency (U.S. EPA). Ms. McCarthy is the current Commissioner of the Connecticut Department of Environmental Protection and is also the Chairwoman of The Climate Registry. She is known for her work with the Regional Greenhouse Gas Initiative (RGGI), a market-based greenhouse gas program with 10 Northeastern state participants. She was nominated on March 16, 2009 but her approval was on a slow track due to concerns that some Senate members had around her position on how the New Source Review (NSR) Prevention of Significant Deterioration (PSD) program could be applied to require air permits for emissions of carbon dioxide (CO2) as a result of U.S. EPA's "endangerment finding." There was also speculation that once her confirmation was complete, several regulatory initiatives that have been pending within U.S. EPA would quickly be released. Chief among these pending initiatives is a potential re-formulated Boiler MACT rule which could ultimately impact thousands of sources.
Please contact ALL4's Dan Holland at 610.933.5246 x15 or [email protected] if you would like more information on the nomination. |
| ALL4's Greenhouse Gas Inventory Starter Kit - Get Yours Today! |
 Does your greenhouse gas inventory need to sprout?
GHG reporting rules have been proposed and U.S. EPA is currently digging out from the piles of comments that they received. The final rule is due out this fall. In the meantime, you know you should get started determining your company's Greenhouse Gas (GHG) emissions, but you don't know how best to get started. You don't want to commit thousands upon thousands of dollars right now while regulations and reporting requirements are still being sorted out.
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| What about the Section 114 Testing Requirements for Boilers and Solid Waste Incinerators? |
 This month's 4 The Record features an guest article co-authored by Manko, Gold, Katcher & Fox, LLP and All4 Inc. on A Practical Guide for Responding to Section 114 Requests.
But what if you receive a Section 114 letter that requires you to perform an actual emission test program?
Almost 300 facilities have recently received Section 114 Letters from U.S. EPA requiring fuel sampling and emission testing for the purposes of developing emission standards for boilers and solid waste incinerators. The emission test program results developed from the test programs must be submitted to U.S. EPA within 120 days from the receipt the Section 114 Letter.
Stay tuned.... ALL4's 4 The Record Extra! on this very subject is due out shortly and will provide valuable information needed to complete the Section 114 test programs so that U.S. EPA gets the information they requested and your facility can utilize the test results for future compliance strategies.
Please contact ALL4's Eric Swisher at 610.933.5246 x17 or [email protected] if you would like more information on Section 114 Testing Requirements. |
| ALL4 PM2.5 Breakfast Update... |
 ALL4 held a PM2.5 Breakfast Update on May 20, 2009. Presenters included (as pictured, left to right), Wes Fritz - Weston Solutions, John Slade - ALL4, Colin McCall - ALL4, Bart Cassidy - MGKF, and Roy Rakiewicz - ALL4. Nearly 50 environmental professionals were in attendance and represented a variety of industries, including Power, Chemical, Refining, Cement, Brick, Aggregates, and Metals. Everyone left the seminar a little smarter and more informed about PM2.5! What did a few of our attendees have to say: "PM2.5 is a very timely topic for my facility. The presentations were thorough and provided valuable information on various facets of the subject."
"....able to effectively cover a lot of material in a short time frame."
"The speakers were impressive in their technical competence and communication skills."
"Good coverage of a difficult (and complex) subject, very knowledgeable speakers."
Congratulations to Glen Gery's Mike Krzyzanowski, who won the drawing for a free 6 month EnviroReview subscription. Want to learn more about Mike's windfall? Click here. Congrats to our other drawing winners who went home with some great ALL4 gear.
Missed the event and want to know what content we covered? Email Kristin Gordon for the slides. Stay tuned for ALL4's 2009 3rd and 4th quarter training schedule for other timely topics, including a PM2.5 webinar. For more information on ALL4 Training, please contact ALL4's Kristin Gordon at 610.933.5246 x33 or [email protected]. |
| EnviroReview Extract |
 EnviroReview is ALL4's regulatory update product which summarizes multimedia environmental changes at the Federal, state, and local level. Being on top of the regulatory development process is paramount to continued environmental compliance. "EnviroReview Extract" is a monthly feature sharing several highlights of the previous month's EnviroReview.
This month's highlights include:
Federal News
U.S. EPA has taken final action on a rule that amends and delays the effective date of the rule addressing "aggregation" under the Prevention of Significant Deterioration (PSD) and the nonattainment New Source Review programs (collectively, "NSR"). The NSR Aggregation Amendments, published in January 2009, describe when a source must combine nominally-separate physical changes and changes in the method of operation for the purpose of determining whether they are a single change resulting in a significant emissions increase. U.S. EPA is delaying the effective date of the NSR Aggregation Amendments for an additional 12 months to allow sufficient time to conduct a reconsideration proceeding which was prompted by a National Resources Defense Council (NRDC) petition.
Federal News
U.S. EPA extended the public comment period for the draft document titled, "Risk and Exposure Assessment to Support the Review of the SO2 Primary National Ambient Air Quality Standards: Second Draft." U.S. EPA extended the comment period that originally ended on May 20, 2009 until June 11, 2009 in order to provide stakeholders and the public adequate time to conduct appropriate analyses and prepare meaningful comments.
Federal News
U.S. EPA is proposing a supplemental action to the proposed amendments to the New Source Performance Standards (NSPS) for coal preparation and processing plants published on April 28, 2008. The supplemental action proposes to (1) revise the particulate matter (PM) emissions and opacity limits included in the original proposal for thermal dryers, pneumatic coal-cleaning equipment, and coal handling equipment; (2) expand the applicability of the thermal dryer standards so that the proposed standards would apply to both direct contact and indirect contact thermal dryers drying all coal ranks and pneumatic coal-cleaning equipment cleaning all coal ranks; (3) establish a sulfur dioxide (SO2) emission limit and a combined nitrogen oxide (NOx) and carbon monoxide (CO) emission limit or thermal dryers; (4) amend the definition of coal for purposes of Subpart Y to include petroleum coke and coal refuse; and (5) establish work practice standards to control coal dust emissions from open storage piles and roadways associated with coal preparation and processing plants.
California News
The California Air Resources Board (CARB) will conduct a public hearing on June 25 and 26, 2009 to consider the adoption of a new regulation to impose fees on sources of greenhouse gas (GHG) emissions, and to consider the adoption of an amendment to the existing Mandatory Reporting of GHG Emissions. The proposed fees would fund the implementation of Assembly Bill 32 (AB 32) (California Global Warming Solutions Act of 2006) and would impose fees on entities in six (6) sectors of the economy: natural gas entities, producers and importers of gasoline and diesel fuel, refineries, cement manufacturers, retail providers and marketers of imported electricity, and facilities that combust coal. The proposed amendments would require entities subject to Mandatory Reporting of GHG Emissions to use CARB's "GHG Reporting Tool" to electronically report the required data. Comments are due June 24, 2009. Delaware NewsU.S. EPA is proposing to disapprove Delaware's demonstration of attainment of the 8-hour ozone National Ambient Air Quality Standard (NAAQS) for the Delaware portion of the Philadelphia-Wilmington-Atlantic City moderate ozone nonattainment area (Philadelphia Area) because it has been determined that the photochemical modeling does not demonstrate attainment, and the weight of evidence analysis included in the State's State Implementation Plan (SIP) to support the attainment demonstration does not provide sufficient evidence that the area will attain the NAAQS by the June 2010 deadline. |
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East Penn Manufacturing Honored with Cevallos Award |
 On May 30, 2009, the Pennsylvania Institute for Children's Environmental Health (PICEH) honored East Penn Manufacturing (Lyon Station, PA) with the Cevallos Award for children's environmental health and environmental stewardship. Robert Flicker accepted the award on behalf of East Penn. This award, PICEH's highest honor, is named for Dr. F. Javier Cevallos, president of Kutztown University. Dr. Cevallos actively gathered support for the foundation of PICEH within the Kutztown University community, and this award serves as an acknowledgment from PICEH's board of directors of those who exemplify Dr. Cevallos' dedication to children's environmental health. The Cevallos Award is not an annual award, and those awarded must demonstrate advocacy of children's environmental health, as well as a personal, public, and financial commitment to advancing children's environmental health issues.
East Penn Manufacturing was honored with the Cevallos Award for their exemplary overall environmental performance, and more specifically for significantly reducing ambient lead concentrations while growing the site, utilizing a zero discharge wastewater treatment facility, recycling wastewater to conserve freshwater resources, recycling spent sulfuric acid from recycled batteries, and utilizing innovative solutions to address pollution control challenges. East Penn is also third party certified to the ISO 14001 standard and is a recent recipient of the Pennsylvania Governor's Award.
Bill Straub and Roy Rakiewicz of ALL4 had the honor of attending the ceremony during which EPM accepted the award. ALL4 would like to congratulate East Penn Manufacturing for upholding their commitment to promoting children's environmental health issues and working to assure a cleaner and safer environment for our future. | |
| Careers @ ALL4 |
 At ALL4, we are constantly growing: personally, professionally, and as a company. Because growth is so present in our organization, we are continually looking to hire environmental professionals that share our same vision and passion for helping our clients be successful. If you are an environmental professional that wants to......
- Work in a relaxed and employee-centered work environment,
- Be given the opportunity to measure success based on your own merits,
- Make a tangible contribution to the growth of the company,
- Work in a culture of accountability,
- Be rewarded for your efforts that go above and beyond "business as usual,"
- Receive a benefits package that is unmatched in our industry,
- Have access to mentoring and hands-on training from experienced experts in the environmental consulting business,
- Constantly challenge yourself both technically and personally,
- Have the opportunity to contribute to the management and the direction of the company,
- Be asked your opinion and given the freedom to put it into action, and
- Be part of an organization that is striving to be "best in class" every day,
.....then you need to contact ALL4 now at [email protected].
Even if you personally do not have an interest in joining ALL4, but know someone who might, please inquire about our "Referral Rewards" program. For more information, please check out our career section and/or email us at [email protected]. |
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 We hope you've enjoyed our June 2009 4 The Record. Feel free to forward suggestions, thoughts, and/or comments to [email protected].
Sincerely,
All4 Inc.
Kristin M. Gordon, P.E.
Your environmental compliance is clearly our business. |
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