President Obama’s centerpiece of his climate policy agenda, the “Clean Power Plan,” has become one of the most heavily litigated environmental regulations ever. Twenty-seven states and numerous industry groups have filed more than fifteen separate lawsuits challenging the Environmental Protection Agency’s (“EPA”) statutory authority to promulgate the regulations. Seventeen states, the District of Columbia, the
Awaiting the Arrival of Proposed Revisions to OSHA PSM and EPA’s RMP Rules: New OSHA Policy Statement Defining RAGAGEP
The Occupational Safety and Health Administration (“OSHA”) published a Request for Information (“RFI”) on December 9, 2013 concerning possible changes to the Process Safety Management (“PSM”) program codified at 29 C.F.R. 1910.119. See 78 Fed. Reg. 73756 (Dec. 9, 2013). Likewise, the Environmental Protection Agency (“EPA”) published an RFI on July 31, 2014 relating
EPA Extends Public Comment Period on Proposed Rulemaking for Fracking Wastewater
The EPA has proposed pretreatment standards for the Oil and Gas Extraction Category (40 CFR Part 435). The regulations would address discharges of wastewater pollutants from onshore Unconventional Oil and Gas (UOG) extraction facilities to Publicly-Owned Treatment Works (POTWs). The EPA contends that “the proposed rule would better protect public health, the environment, and the
EPA Establishes New Refinery AP-42 Emission Factors: No Revision to Flare Nitrogen Oxide (NOx) Factor
Last year, the EPA announced its intention to add or modify a number of AP-42 emission factors, primarily for petroleum refineries, pursuant to a consent decree entered into with Air Alliance Houston, Community In-Power and Development Association, Inc., Louisiana Bucket Brigade and Texas Environmental Justice Advocacy Services (“Plaintiffs”). The EPA informally solicited comments on its
Awaiting the Arrival of Proposed Revisions to OSHA PSM and EPA’s RMP Rules: Expanding Mechanical Integrity to Cover Any Safety-Critical Equipment
The Occupational Safety and Health Administration (“OSHA”) published a Request for Information (“RFI”) on December 9, 2013 concerning possible changes to the Process Safety Management (“PSM”) program codified at 29 C.F.R. 1910.119. See 78 Fed. Reg. 73756 (Dec. 9, 2013). Likewise, the Environmental Protection Agency (“EPA”) published an RFI on July 31, 2014 relating
Awaiting the Arrival of Proposed Revisions to OSHA PSM and EPA’s RMP Rules: Requiring Third-Party Compliance Audits
The Occupational Safety and Health Administration (“OSHA”) published a Request for Information (“RFI”) on December 9, 2013 concerning possible changes to the Process Safety Management (“PSM”) program codified at 29 C.F.R. 1910.119. See 78 Fed. Reg. 73756 (Dec. 9, 2013 ). Likewise, the Environmental Protection Agency (“EPA”) published an RFI on July 31, 2014 relating
Awaiting the Arrival of Proposed Revisions to OSHA PSM and EPA’s RMP Rules: Mandatory Updating of Defining RAGAGEP
The Occupational Safety and Health Administration (“OSHA”) published a Request for Information (“RFI”) on December 9, 2013 concerning possible changes to the Process Safety Management (“PSM”) program codified at 29 C.F.R. 1910.119. See 78 Fed. Reg. 73756 (Dec. 9, 2013). Likewise, the Environmental Protection Agency (“EPA”) published an RFI on July 31, 2014 relating
Awaiting the Arrival of Proposed Revisions to OSHA PSM and EPA’s RMP Rules: Defining Recognized and Generally Acceptable Good Engineering Practices
The Occupational Safety and Health Administration (“OSHA”) published a Request for Information (“RFI”) on December 9, 2013 concerning possible changes to the Process Safety Management (“PSM”) program codified at 29 C.F.R. 1910.119. See 78 Fed. Reg. 73756 (Dec. 9, 2013). Likewise, the Environmental Protection Agency (“EPA”) published an RFI on July 31, 2014 relating
Awaiting the Arrival of Proposed Revisions to OSHA PSM and EPA’s RMP Rules: Atmospheric Storage Tanks
The Occupational Safety and Health Administration (“OSHA”) published a Request for Information (“RFI”) on December 9, 2013 concerning possible changes to the Process Safety Management (“PSM”) program codified at 29 C.F.R. 1910.119. See 78 Fed. Reg. 73756 (Dec. 9, 2013). Likewise, the Environmental Protection Agency (“EPA”) published an RFI on July 31, 2014 relating
LDEQ Now Limits Term for Minor Source Air Permits and Requires Update for Such Existing Permits
In the past, Minor Source Air Permits issued by LDEQ typically did not have an expiration date. That has changed. Per Louisiana Revised Statute 30:2023(A), all environmental permits issued by the Louisiana Department of Environmental Quality (“LDEQ”) “shall have, as a matter of law, a term of not more than ten years.” Louisiana’s air quality