Compliance Counseling

Robert’s long-standing counseling practice involves all aspects of environmental compliance, with a particular focus on Clean Air Act regulations, including:

  • Benzene Waste Operations National Emission Standards for Hazardous Air Pollution (NESHAP)
  • Vinyl Chloride NESHAP
  • Refinery Maximum Achievable Control Technology (MACT)
  • Fiberglass MACT
  • New Source Performance Standards for petroleum refineries and storage tanks
  • Prevention of Significant Deterioration
  • Non-Attainment New Source Review

Agency Rulemaking

Robert represents trade associations and companies in rulemaking proceedings under the Clean Air Act (including the air toxics and enforcement sections) and the Clean Water Act.