Environmental groups continue their attack on long-standing rule provisions under the Clean Air Act that limit or exclude liability related to “startup, shutdown, and malfunction” events. Historically, USEPA has acknowledged that it may be impracticable, if not impossible, for industry to meet emissions standards during certain periods, including during startup, shutdown or malfunction events, when emissions are typically higher than during normal operation. However, in May 2015, in response to prior challenges, USEPA instructed 36 states to revise their implementation plans with regard to SSM events.
Continue Reading Environmental Groups Challenge EPA Refinery Rule

Final Rules

On November 13, 2014, the United States Environmental Protection Agency (USEPA) finalized revisions to the Greenhouse Gas Reporting Program (GHGRP) for the petroleum and natural gas systems source category. 40 C.F.R. part 98, subpart W (subpart W).  The final revisions also revise the general provisions (subpart A). 
Continue Reading USEPA Finalizes Amendments to GHG Reporting Regulations for the Oil and Gas Sector And Proposes Additional Subpart W Revisions for Comment