Since the beginning of the Title V program many years ago, the term “Once In Always In” meant that if a facility becomes a major source and is subject to a NESHAP found in 40 CFR Part 63, then that NESHAP would perpetually apply to that facility. As an environmental professional, I have witnessed the significant consternation for the industry in that there was no longer an incentive to reduce air pollution as a method to reduce the regulatory burden in which the company is su

Crystalline silica is a common and naturally-occurring material that is found in sand, concrete, brick, block, natural stone and mortar. Inhalation of respirable crystalline silica (RCS) can cause silicosis. Silicosis is an incurable lung disease that impairs a person’s ability to take a full breath due to scarring of the lungs. Silicosis can progress even after a person is no longer exposed to the dust, causing severe shortness of breath many years later. The science avai

The Michigan EGLE Air Quality Division (AQD) is required to prepare an annual report per the Natural Resources and Environmental Protection Act. The AQD Annual Report gives an overview of Michigan’s air quality for 2019, along with any changes that occurred in monitoring programs throughout the year. Since EGLE began monitoring air quality in the early ‘70s, criteria pollutant levels have continually decreased. The six pollutants monitored by EGLE AQD are: Carbon monoxide (

As aboveground storage tank operators are aware, AP-42 Section 7.1 (Organic Liquid Storage Tanks) has been updated multiple times in the last year, most recently in March 2020. The updates made wholesale changes to ordinary tank emissions (working/breathing) but also added two sections specifically for tank cleaning. These additions align AP-42 with the parallel API document, API Technical Report 2568 – Evaporative Loss from the Cleaning of Storage Tanks. This document was