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Superfund Sites Getting Immediate and Intense Action

Posted by on 4:37 pm in Blog | 0 comments

Resolving to solve impasses that have delayed progress on a short list of Superfund Sites, the United States Environmental Protection Agency (EPA) has released their list of sites that will be, “targeted for immediate and intense action.” We mentioned this new focus on Superfund Sites in our November 10, 2017 blog, “Transforming Superfund.”  This focus is a result of the recommendation by the Superfund Taskforce from the last summer (2017). List of 21 Superfund Sites To Get Attention The list of 21 sites includes Mohawk Tannery in New...

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Environmental Enforcement Eye Opener

Posted by on 7:47 pm in Blog | 0 comments

Admittedly, the exciting work in “our world” is peer reviewing complex soil and groundwater projects and providing litigation support for those projects. Emerging and developing issues such as vapor intrusion and per- and poly-flouoroalkyl substances are also real attention getters. However, the constant (though never static) in the environmental world is environmental compliance and enforcement.  It’s one of the reasons we provide monthly environmental compliance reminders. Environmental Enforcement at What Company? If you don’t think...

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Transforming Superfund?

Posted by on 8:06 pm in Blog | 0 comments

One of the areas that is getting attention under the new administration is the Superfund program (a.k.a., The Comprehensive Environmental Response and Liability Act, CERCLA). Having a long history in the environmental business, I have witnessed what was generally a good idea, cleaning up the nation’s past environmental sins, become a very sluggish bureaucratic program.  It is widely recognized that progress on Superfund sites has been slow (if at all), leaving some of the nation’s highest priority sites on the National Priorities List (NPL)...

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EPA’s Latest Draft Strategic Plan

Posted by on 2:30 pm in Blog | 0 comments

The direction of the EPA under the new administration has been on the mind of the regulated community, as well as environmental groups, for several months.  Following the submittal of the Draft FY 2018-2022 EPA Strategic Plan, we are getting a better idea of this direction. The most public of the changes is related to climate change.  In fact, if you compare the 2014-2018 EPA Strategic Plan (climate change mentioned first among their goals) to the current Draft Strategic Plan, this is an obvious change, as the EPA has eliminated the focus on...

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EPA R&D, Citizen Scientists, and Focus on Nutrients

Posted by on 4:32 pm in Blog | 0 comments

President Trump has proposed a $2.7 billion reduction in the EPA’s budget, which would amount to a 31% cut.  However, ultimately, congress controls the purse strings and many are betting that the reduction will be significantly less than what has been proposed. With the expectation of potentially-significant cuts in their 2018 budget, the US Environmental Protection Agency (EPA) is looking at a variety of approaches to address environmental concerns. Citizen Scientists For example, the EPA’s Office of Research and Development evaluated state...

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10-Second Environmental Compliance Check Up

Posted by on 10:57 am in Blog | Comments Off on 10-Second Environmental Compliance Check Up

Below are Dragun’s monthly environmental compliance tips and reminders.  These very brief tips are provided in our monthly newsletters along with other environmental news.  If you are not receiving our newsletter, you can sign up on our website, or contact me ( and I will add your name to our database. If you have an immediate question about an environmental compliance issue, or would like us to address a specific environmental compliance issue in the future, contact Matthew Schroeder, P.E. (, at...

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Environmental Compliance and Enforcement Update

Posted by on 1:16 pm in Blog | 0 comments

It’s been a while since we last looked at environmental enforcement activity (see Increased Costs for Non-Compliance and Enforcement Notes).  Six-figure fines were noted when doing a quick survey of environmental enforcement action over the past few months. Fines, Compliance Program, and Training NVR, a residential home developer, violated the stormwater requirements of the Clean Water Act and paid a civil penalty of $425,000. According to the EPA, NVR failed to obtain coverage under a National Pollutant Discharge Elimination System (NPDES)...

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Concerns about RCRA Changes

Posted by on 2:36 pm in Blog | 0 comments

The 2016 proposed amendments to the Resource Conservation and Recovery Act (RCRA) were substantial.  Some of these changes are helpful, and we discussed those positive changes last fall in one of our blogs. However, as is often the case with regulatory changes, it’s only after the details are released that we learn the full impact of amendments. In an article that appeared in The National Law Review, we learned much more about the final version of the RCRA changes.  If you are a generator of hazardous waste, we encourage you to read the...

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Vaporized: No More Vapor Intrusion Criteria – Sort Of

Posted by on 1:16 pm in Blog | 0 comments

Whether we agreed with it or not, it seemed like there was a process in Michigan to evaluate the vapor intrusion pathway under Part 201 of the Natural Resources and Environmental Protection Act (NREPA) at sites with releases of volatile chemicals.  However, just when we thought that the vapor intrusion screening levels (VISLs) presented in the Michigan Department of Environmental Quality (MDEQ) Guidance Document for the Vapor Intrusion Pathway, dated May 2013, were relatively set, the MDEQ announced their decision to rescind them. Michigan’s...

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Changes in SARA Tier I and Tier II Chemical Reporting Regulations

Posted by on 8:11 pm in Blog | 0 comments

Several years ago, the Occupational Safety and Health Administration (OSHA) revised their Hazard Communication Standards (HCS) in response to the United Nations Globally Harmonization System. The changes to OSHA’s HCS affect specific Environmental Protection Agency (EPA) reporting requirements.  Accordingly, the EPA recently issued revisions to the hazard categories in the regulations under 40 CFR Part 370 for reporting under Sections 311 (Tier I) and 312 (Tier II) of the Emergency Planning and Community Right-to-Know Act (EPCRA). Previously,...

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