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September 2011 

In This Issue
What's Going On With the 1-Hour SO2 NAAQS Implementation Process?
Cement Sector Relief Act of 2011
U.S. EPA National Enforcement Initiatives for Fiscal Years 2011 - 2013
Proposed Ozone NAAQS Withdrawn
GHG Reporting - Confidential Business Information
Don't Miss ALL4 at the National Safety Council 2011 Congress and Expo!
We Don't Mean to Brag, But...
ALL4's Employee Spotlight: Bob Kuklentz
ALL4's: Is That Your Final Answer?
EnviroReview Extract
Are You Ready For A Challenge?
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What's on ALL4's Calendar?
2011
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.

October 4, 2011 -   PA Chamber Environmental Conference - Pittsburgh, PA

October 5 - 6, 2011 - AWMA NSR Training - Indianapolis, IN
 
October 7, 2011 -
TN Chamber Environmental Conference - Burns, TN

October 11, 2011 - Wilkes University Career Fair - Wilkes-Barre, PA

October 12, 2011 - Drexel University Career Fair - Philadelphia, PA

October 19, 2011 - PA Chamber Environmental Conference - Harrisburg, PA
 
 
October 26, 2011 -  PA Chamber Environmental Conference - Valley Forge, PA
 
October 27 - 28, 2011 - 10th Annual Modeling Conference - North Carolina
 
October 31 - November 2, 2011 - National Safety Council Expo - Philadelphia, PA


What's Going On With the 1-Hour SO2 NAAQS Implementation Process?
Confused GroupNow that we've all had some time to digest the plethora of guidance memoranda and updated air quality modeling programs that were released in March and April of 2011 and summarized by ALL4 in our April 4 The Record article, what has actually been happening with the 1-hour sulfur dioxide (SO2) National Ambient Air Quality Standards (NAAQS) implementation process?  As was outlined in the preamble to the final 1-hour SO2 NAAQS, an analytic approach that used both air quality monitoring and air quality dispersion modeling was being used for the attainment designation process given the limited network of ambient SO2 monitors.  Initial attainment status designations were due to U.S. EPA by June 3, 2011, and at that time most states recommended an "unclassifiable" designation for any areas that did not have monitors (since no air quality modeling had yet been completed).  States now have until April 3, 2012 to provide updated information to U.S. EPA using air quality dispersion modeling to support their attainment designations for the 1-hour SO2 NAAQS.  ALL4 was curious regarding where individual states actually were in the attainment designation process for the 1-hour SO2 NAAQS, so we contacted 22 states and asked them the following six (6) questions:
  1. Are you currently completing any air quality dispersion modeling to support the SO2 attainment designations in your state?
  2. If so, are you using AERMOD to conduct this air quality dispersion modeling?
  3. What are the screening criteria that you are using for determining what facilities to include in this air quality dispersion modeling?
  4. Who is conducting the air quality dispersion modeling?
  5. What is your timeline for completion?
  6. Do you have any other comments on the process?
Read on as ALL4's Dan Dix discusses ALL4's findings about the status of the 1-hour SO2 NAAQS implementation process.

Please contact ALL4's Dan Dix at 610.933.5246 x18 ([email protected]) with questions related to the 1-hour SO2 NAAQS implementation process.

Cement Sector Relief Act of 2011
Cement Kiln
On July 28, 2011, H.R. 2681 (Cement Sector Relief Act of 2011) was introduced in the House of Representatives for consideration.  If passed, the bill would direct the Administrator of U.S. EPA to issue new rules to replace the following three (3) interrelated rules that affect the Portland Cement industry:
  • National Emission Standards for Hazardous Air Pollutants (NESHAP) from the Portland Cement Manufacturing Industry (Portland Cement MACT).
  • Standards of Performance for New Stationary Sources and Emission Guidelines for Existing Sources:  Commercial and Industrial Solid Waste Incineration Units (CISWI).
  • Identification of Non-Hazardous Secondary Materials (NHSM) That Are Solid Waste.
While addressing a number of issues, the bill specifically provides that in defining the terms "commercial and industrial solid waste incineration unit," "commercial and industrial waste," and "contained gaseous material," the Administrator should adopt the meaning of those terms set forth in (more...)

U.S. EPA National Enforcement Initiatives for Fiscal Years 2011 - 2013
Planning and Implementation Crossroads
While U.S. EPA has certainly been focusing a large portion of its emissions reduction regulatory development and compliance enforcement efforts on the usual suspects (i.e., fossil fuel-fired energy production and use sectors such as coal-fired utilities, cement manufacturing, glass production, and large industrial boilers), they have now added energy extraction initiatives to the "list."  The energy extraction initiatives include coal mining and gas extraction (including Marcellus Shale gas).  The following three (3) initiatives are a few examples from a short list of U.S. EPA's six (6) top initiatives for fiscal years 2011-2013:       
  • Reducing Widespread Air Pollution from the Largest Stationary Sources, especially the Coal-Fired Utility, Cement Manufacturing, Glass Manufacturing, and Acid Production Sectors.
  • Reducing Pollution from Mineral Processing Operations.
  • Assuring Energy Extraction Sector Operations' Compliance with Environmental Laws.
The intensity of regulatory development and compliance with those requirements is going to be a significant challenge (more...)

Proposed Ozone NAAQS Withdrawn
Ozone LayerAt the request of President Obama, U.S. EPA has withdrawn the draft ozone National Ambient Air Quality Standards (NAAQS).  The current 8-hour ozone NAAQS is 75 parts per billion (ppb).  U.S. EPA had been close to finalizing a revised ozone NAAQS at a level between 60 and 70 ppb prior to withdrawing the draft proposal.  In the withdrawal request, the President cited concerns about the regulatory burden on industry and about the timeline for the next ozone NAAQS reconsideration, which is scheduled to begin in 2013.  The withdrawal is the second time in the past several months that a proposed NAAQS level has remained unchanged.  U.S. EPA proposed earlier in the year to maintain the current NAAQS levels for carbon monoxide (CO).  The withdrawal of the draft ozone NAAQS eliminates (more...)

GHG Reporting - Confidential Business Information
Confidential StampNow that you are busy entering  your data for the 2010 Greenhouse Gas (GHG) Emissions Inventory Report into U.S. EPA's Electronic Greenhouse Gas Reporting Tool (e-GGRT), you may become puzzled because e-GGRT is requiring you to enter information that you believe is confidential business information (CBI) and you understood that reporting of that information had been deferred by U.S. EPA.  You're not alone.  When it comes to e-GGRT and CBI, it is easy to get confused.  Here's why.

In recent months U.S. EPA took several different actions related to CBI and how it is treated for submitting data under the requirements of 40 CFR Part 98 (the GHG Reporting Rule).  In two (2) separate rules published on December 27, 2010 and August 25, 2011, U.S. EPA deferred the reporting deadline for data elements that are used by reporters as inputs to GHG emission calculation equations under the GHG Reporting Rule.  The deadline for reporting some of these data elements is now deferred to March 31, 2013 and the deadline for reporting others is deferred to March 31, 2015.  Examples of these deferred data elements include (more...)

Don't Miss ALL4 at the National Safety Council 2011 Congress and Expo!
Many Hats
We know that environmental professionals wear multiple hats - especially those with Environmental, Health, and Safety (EHS) roles.  What if your Environmental hat was a little easier to wear?  What if you had an organized summary of last month's environmental activity delivered right to your inbox?  Come meet ALL4's Annalise Matulewicz at the NSC Expo October 31 - November 2 and learn more about EnviroReview, ALL4's customized environmental regulatory update service.  You don't know what you're missing.

Pssst!  Mention 4 The Record to Annalise to receive a special gift!

We Don't Mean to Brag, But...
Fireworks
Did you know that ALL4 was recently named to the 2011 Inc. 5000 list of fastest growing private companies in America for the 4th consecutive year? How about that we were named to The Zweig Letter's 2011 Hot Firms List? Or to the Philadelphia Business Journal's 2011 list of Best Places to Work? It's been quite a year - we'd like to thank all of our clients, partners, and staff for helping us make the ALL4 vision for being a best-in-class company a reality!

ALL4's Employee Spotlight: Bob KuklentzEmployee
Bob Kuklentz We're introducing a new monthly feature to 4 The Record entitled "ALL4's Employee Spotlight."  Each month's 4 The Record will present an interview with one of ALL4's employees.  This month's employee spotlight is on Project Manager Bob Kuklentz.

What did you do before you joined ALL4?

When I graduated from college I got a job as a plant environmental manager for a chemical specialties manufacturer.  I had plant responsibilities for environmental, health, and safety.  At the time, many of the company's products contained chemicals that were being phased out due to their ozone depleting potential.  I was heavily involved in the transition to alternate chemicals, including educating customers on the product changes forced by the elimination of many of the solvents that had served industry for many years.  It was an interesting time.  After about three years I accepted a corporate environmental position at a multi-site paperboard packaging company.  Over the years I had environmental responsibilities for up to 10 facilities in the U.S. and Canada.  During my tenure the company transitioned from solvent-based printing to water-based printing, and greatly reduced emissions.  I worked there for 17 years working my way to corporate environmental manager.  

 Click here to read more of Bob's responses to questions such as:
  • What one piece of advice would you give to college students looking for a position in the consulting business?
  • What do you like best about your career?
  • What was your biggest challenge in your first year?
  • Who is the best dresser at ALL4?
  • What makes you great?
  • As a big Phillies fan, give me your 4-man pitching rotation for the playoffs, 1-4 and a prediction on the playoffs. 
 
ALL4's: Is That Your Final Answer?
Is That Your Final Answer?Last Month's Answer and Winner: There were several people who remembered their 4th grade math lesson on the distributive property because we received multiple correct answers for the August "Is That Your Final Answer" quiz.  As you may recall, we needed to know the length that would be required to be added to a steel band tightly wrapped around the 24,900 mile circumference of the earth such that the additional length would allow the tallest ALL4 employee to walk under the band anywhere along the band. By using the distributive property, one can very easily calculate that increasing the length of the band by only approximately 40 feet would allow Tom Saylor (officially the tallest ALL4 employee) to walk under the band.  The first respondent with the correct answer was Mr. Ron Gore of the Alabama Department of Environmental Management.  However, as a public servant, Ron is committed to maintaining impartiality and thus he requested that he be excused from the competition thereby elevating Mr. Philip Antici of FutureFuel Chemical Company as the official August winner.  Thanks to everyone who submitted the correct answer (there were no wrong answers received).  4th grade math teachers everywhere must be proud.
 

Question: It is only September 2011, but already the presidential election process seems to be capturing more and more attention.  So why should the September "Is That Your Final Answer" question be any different?  Since 1970 there have been 12 individuals who have served as senate-confirmed U.S. EPA administrators.  Of these 12, only two individuals, William Ruckelshaus and Russell Train, have served under more than one president.  Name the presidents that Ruckelshaus served under or the presidents that Train served under.  As a hint, all of the presidents were Republicans and this is a tricky question.
 
Answer:  Please e-mail your answer to [email protected].  Include in the e-mail your name, answer, and address (to receive your prize).

The final answer feature of 4 The Record is designed to test your knowledge across the environmental field, quiz you on the building blocks of air quality rules, stump you on ALL4 general trivia, and challenge you with brain teasers that have perplexed us.  The first correct answer e-mailed to us will qualify the respondent for free ALL4 gear and will enter the winner in our end-of-the year "Final Answer Championship."  The subsequent month's 4 The Record will identify the winner and the correct answer from the previous month's question.  You must be an active subscriber of 4 The Record to win a monthly prize and be eligible for the championship prize.  ALL4 employees and family members are not eligible to compete.  Hope you enjoy this feature and good luck!
EnviroReview Extract
EnviroReview
EnviroReview is ALL4's customized environmental 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 deferred the reporting deadline for data elements that are used by direct emitter reporters as inputs to emission equations under the Mandatory Greenhouse Gas Reporting Rule. The deadline for reporting some of these data elements was deferred to March 31, 2013 and the deadline for reporting others was deferred to March 31, 2015. This final rule does not change any other requirements of the Mandatory Greenhouse Gas Reporting Rule. The effective date of this rule was September 9, 2011.

Federal News

U.S. EPA has proposed to address the reviews of the New Source Performance Standards (NSPS) for volatile organic compound and sulfur dioxide emissions from natural gas processing plants. U.S. EPA has proposed to add to the source category list any oil and gas operation not covered by the current listing. This action also includes proposed amendments to the existing NSPS for volatile organic compounds from natural gas processing plants and proposed standards for operations that are not covered by the existing NSPS. In addition, this action proposes how U.S. EPA will address the residual risk and technology review conducted for the oil and natural gas production and natural gas transmission and storage National Emission Standards for Hazardous Air Pollutants (NESHAP). This action further proposes standards for emission sources within these two (2) source categories that are not currently addressed, as well as amendments to improve aspects of these NESHAP related to applicability and implementation. Finally, this action addresses provisions in these NSPS and NESHAP related to emissions during periods of startup, shutdown, and malfunction. 

Federal News

U.S. EPA has issued a final rule following completion of its review of the air quality criteria and the National Ambient Air Quality Standards (NAAQS) for carbon monoxide (CO).  U.S. EPA has concluded that the current primary standards are requisite to protect public health with an adequate margin of safety, and is retaining those standards.  U.S EPA has also concluded that no secondary standard should be set for CO at this time.  U.S. EPA has also made changes to the ambient air monitoring requirements for CO, including those related to network design, and has updated, without substantive change, aspects of the Federal reference method.

Pennsylvania News
U.S. EPA has approved a State Implementation Plan (SIP) revision submitted by the Commonwealth of Pennsylvania. The SIP revisions pertain to the control of nitrogen oxide (NOx) emissions from glass melting furnaces. U.S. EPA has approved these revisions to reduce NOx emissions from glass melting furnaces in accordance with the requirements of the Clean Air Act (CAA).

Are You Ready For A Challenge?
ALL4 Group PictureMost of you are probably fairly happy with your current work situation.  Why wouldn't you be in this economy, it is just good to have a job.  

But sometimes don't you let your mind wander when you are working at your desk and don't you start to wonder:

  • That there might be something more out there, something more challenging?
  • About working in an environment without all the red tape?  
  • What it would feel like to be part of a real team environment where everyone is pulling for the same common goal?  
  • About starting your own company?
  • What it would feel like to be a part of a best in class company that offers unlimited personal and professional growth opportunities?  

Read on if you (or someone you know) answered "yes" to any of these questions.

Visit ALL4's Employee Spotlight featuring Bob Kuklentz to read about Bob's experiences and career highlights.

 
 
ALL4 LogoWe hope you've enjoyed our September 2011 4 The Record.  Feel free to forward suggestions, thoughts, and/or comments to [email protected].





Sincerely,
All4 Inc.
Name

Kristin M. Gordon, P.E.
Your environmental compliance is clearly our business.
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All4 Inc. is an environmental consulting company specializing in air quality consulting services, primarily assisting our clients with complex air permitting, modeling, continuous monitoring, and regulation compliance. ALL4 operates under the premise that the success of our company is measured by the success of our clients, and with the clear understanding that knowledge is power, that there is no substitute for experience, and that the proper application of our expertise to our clients' projects can provide them a competitive advantage. ALL4 operates a corporate office located in Kimberton, PA and a regional office in Columbus, GA. Visit www.all4inc.com and www.enviroreview.com for more information.