News & Analysis as of

NESHAP Proposed Rules

Mitchell, Williams, Selig, Gates & Woodyard,...

New Source Performance Standards/National Emission Standards for Hazardous Air Pollutants: U.S. Environmental Protection Agency...

The United States Environmental Protection Agency (“EPA”) issued a pre-publication version of a proposed rule that would remove affirmative defense provisions from certain Clean Air Act New Source Performance Standards...more

Goldberg Segalla

EPA’s Final EtO Rule Finally Finalized

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The Environmental Protection Agency on March 14 announced final amendments to the National Emission Standards for Hazardous Air Pollutants (NESHAP) applicable to 90 large commercial sterilization facilities that use ethylene...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Hazardous Air Pollutants/Clean Air Act: U.S. Environmental Protection Agency Proposed Rule Addressing Issues Associated with...

The United States Environmental Protection Agency (“EPA”) published in the September 13th Federal Register a proposed rule that would amend the general provisions for Clean Air Act National Emission Standards for Hazardous...more

Mitchell, Williams, Selig, Gates & Woodyard,...

U.S. EPA Proposed NSPS/NESHAP for Synthetic Organic Chemical Manufacturing Industry: American Chemistry Council/Fuel and...

The American Chemistry Council, American Fuel & Petrochemical Manufacturers, U.S. Tire Manufacturers Association, and Vinyl Institute (collectively “ACC”) submitted July 7th comments to the United States Environmental...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Mercury/Air Toxics Standard NESHAP for Coal and Oil-Fired Electric Utility Steam Generating Units: National Association of Clean...

The National Association of Clean Air Agencies (“NACAA”) submitted June 22nd comments to the United States Environmental Protection Agency (“EPA”) in its docket addressing Proposed National Emission Standards for Hazardous...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Small/Intermediate Gasoline Bulk Storage Plants/NESHAP: Congressional Letter to U.S. Environmental Protection Agency Requesting...

A combined 82 Senators and Members of the United States House of Representatives sent a May 22nd letter to United States Environmental Protection Agency Administrator Michael Regan addressing certain aspects of EPA’s proposed...more

Goldberg Segalla

Highly Anticipated Proposed EtO Rules the EPA Just Announced: Were They Worth The Wait?

Goldberg Segalla on

After years of delays – largely due to the COVID-19 pandemic – on April 11, 2023, the U.S. Environmental Protection Agency finally issued two proposals that would reduce ethylene oxide (EtO) emissions affecting fence-line...more

Williams Mullen

Environmental Notes - April 2023

Williams Mullen on

EPA’s Big Plans for 2023: Top Air Rulemakings We Are Watching - An environmental lawyer walks into a cocktail party. An often-asked question is: What is happening at EPA in your world? What should we be watching that...more

Mitchell, Williams, Selig, Gates & Woodyard,...

NESHAP/U.S. Environmental Protection Agency Proposed Technology Review Standards of Performance for Bulk Gasoline Terminals:...

The Energy Marketers of America (“EMA”) submitted September 13th comments on the United States Environmental Protection Agency’s (“EPA”) proposed rule addressing Clean Air Act National Emission Standards for Hazardous Air...more

Mitchell, Williams, Selig, Gates & Woodyard,...

NESHAP/Bulk Gasoline Terminals: NESCAUM Comments on Proposed Technology Review/Standards of Performance

The Northeast States for Coordinated Air Use Management (“NESCAUM”) submitted August 9th comments to the United States Environmental Protection Agency (“EPA”) addressing: National Emission Standards for Hazardous Air...more

Clark Hill PLC

EPA Proposes Updates to Air Toxics and Performance Standards For Lead Acid Battery Plants

Clark Hill PLC on

On Feb. 11, EPA proposed updates to both the National Emissions Standards for Hazardous Air Pollutants (NESHAP) that apply to Lead Acid Battery (LAB) Manufacturing Area Sources (Subpart PPPPPP) and the New Source Performance...more

ArentFox Schiff

EPA Issues Proposed Rule Imposing More Stringent Air Emissions Controls for Lead Acid Battery Manufacturing

ArentFox Schiff on

Batteries play a fundamental role in energy storage, and currently nearly 99 million lead acid batteries are manufactured each year. This past Wednesday, U.S. Environmental Protection Agency (EPA) issued a proposed rule in...more

King & Spalding

EPA's Reconsideration of Ethylene Oxide Under the Clean Air Act - A Sign of Future Chemicals Policy to Come?

King & Spalding on

On January 25, 2022, the U.S. Environmental Protection Agency (“EPA”) reaffirmed its interpretation of ethylene oxide (“EtO”) requirements which may signal EPA’s increased scrutiny of chemical emissions generally and the...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Miscellaneous Coating Manufacturing/NESHAP: U.S. Environmental Protection Agency Proposed Residual Risk and Technology Review

The United States Environmental Protection Agency (“EPA”) published a September 4th Federal Register Notice proposing the results of a Residual Risk and Technology Review (“RTR”) of the Clean Air Act National Emission...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Reclassification of Major Sources as Area Sources: U.S. Environmental Protection Agency Proposed Revisions to Clean Air Act...

The United States Environmental Protection Agency (“EPA”) is proposing provisions to the General Provisions of the Clean Air Act National Emission Standards for Hazardous Air Pollutants (“NESHAP”). David Carstens of Harbor...more

Mitchell, Williams, Selig, Gates & Woodyard,...

NESHAP for Surface Coating of Metal Cans/Coating - Residual Risk and Technology Reviews: U.S. Environmental Protection Agency...

The United States Environmental Protection Agency (“EPA”) issued a June 4th proposed rule in regards to the: National Emissions Standards for Hazardous Air Pollutants (NESHAP) for the Surface Coating of Metal Cans and...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Emissions Averaging/Proposed NESHAP for Clay Ceramics Manufacturing: National Association of Clean Air Agencies Comments

The National Association of Clean Air Agencies (“NACAA”) submitted October 4th comments to the United States Environmental Protection Agency (“EPA”) on its proposed National Emission Standards for Hazardous Air Pollutants...more

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