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Final Rule Exemption for Agriculture under CERCLA/EPCRA is Vacated

Posted by on 8:30 pm in Blog | 0 comments

In late 2008, the US Environmental Protection Agency (EPA) issued a “final rule” exempting air release reporting for animal waste at farms under two environmental regulations:  the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) and the Emergency Planning and Community Right to Know Act (EPCRA). The 2008 EPCRA exemption did not apply to large facilities, nor did it apply to facilities that have reporting obligations because of refrigeration (ammonia use).  Also, the exemptions were very specific, applying to...

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10-Second Environmental Compliance Check Up

Posted by on 11:02 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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RCRA Changes Final

Posted by on 6:52 pm in Blog | 0 comments

In late 2015, we discussed some substantive proposed changes to the Resource Conservation and Recovery Act – RCRA (Meaningful Amendments to the Resource Conservation and Recovery Act).  As we stated then, these amendments appeared to be helpful to smaller generators of hazardous waste. With little fanfare, perhaps because the country was consumed with the national elections, these, arguably, significant changes to RCRA were published on November 28, 2016.  See EPA Final Rule.  This final (federal) rule is effective on May 30, 2017. RCRA...

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Environmental Enforcement and Activists

Posted by on 7:26 pm in Blog | 0 comments

As we wrote in our February 16th blog, it appears that environmental groups are energized, “funded,” and ready for a battle.  In an article in the Connecticut Law Tribune, Robert F. Kennedy, Jr. (never one to attempt to placate those with opposing viewpoints) seemed to reflect environmentalist’s readiness for battle.  In talking about the Keystone XL pipeline, Mr. Kennedy said: “That pipeline is a boondoggle that will create 35 American jobs while endangering the water supply for many people.  It will enrich a few billionaires and a few...

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Understanding Groundwater and Nitrates

Posted by on 3:00 pm in Blog | 0 comments

In an effort to get media attention regarding his concern about a petroleum pipeline, a man and his grandson walked into a public meeting, without shirts, covered in what looked like oil (turns out it was chocolate cake frosting). To no surprise, this got the attention of the local media and made for some attention-grabbing photographs. Those in the regulated community understand the significant role that emotions can play with respect to environmental issues.  For agriculture, it’s multiple emotionally-charged issues including how food is...

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Two Words For You: Vapor Intrusion

Posted by on 2:38 pm in Blog | 0 comments

Mr. McGuire: I just want to say one word to you. Just one word. Benjamin: Yes, sir. Mr. McGuire: Are you listening? Benjamin: Yes, I am. Mr. McGuire: Vapor. Benjamin: Exactly how do you mean? An ever so slight variation of the dialogue from the movie, “The Graduate.” To be more specific, it would be two words, Vapor Intrusion. Vapor Intrusion, or VI, is the watch word or phrase in the environmental assessment world right now.  Furthermore, because the “intrusion” of vapors into buildings can affect the health of the occupants, property...

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A New Administration and Four Environmental Considerations

Posted by on 5:34 pm in Blog | 0 comments

We currently have a lot of moving parts relative to how environmental issues might be shaped in the coming months and years. A new administration, a new Justice at the Supreme Court, energized environmental groups, ongoing environmental challenges and as always, emerging environmental issues. New administrations (especially when political parties change) always translate to policy changes. These changes may be amplified under the current political climate. What follows is merely my personal opinion/observations as it relates to environmental...

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Emerging Environmental Issue: PFOA

Posted by on 2:22 pm in Blog | 0 comments

Scott Pruitt, the nominee to lead the US Environmental Protection Agency (EPA) said, “PFOA needs to be addressed quickly whether under TSCA or the Safe Drinking Water Act.”  If the potential incoming director of the EPA has this issue on their radar, it deserves some attention by the regulated community. PFAS, PFOA, PFOS When you start digging into this group of emerging contaminants, you find that there are a lot of four letter “P” acronyms, and it can get confusing.  In general, per- and polyfluoroalkyl substances (PFAS) refers to the group...

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Livestock Agriculture: Fewer Inspections & Enforcement, WOTUS, and Nutrients

Posted by on 7:22 pm in Blog | 0 comments

The U.S. Environmental Protection Agency (EPA) has stated on several occasions that one of their priorities is to focus on agriculture. In fact, as we wrote in late 2015, the EPA stated that one of their six 2017-2019 focus areas was going to be “Preventing Animal Waste from Contaminating Surface and Ground Water.”  Environmental Enforcement at Concentrated Animal Feeding Operations (CAFOs) However, in a recent article in Circle of Blue, author Brett Walton writes, “Federal inspections of cattle and hog feedlots, turkey houses, and other...

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Environmental Compliance: A Look Back and Planning for 2017

Posted by on 4:17 pm in Blog | 0 comments

The fun work in our business is when we get to untangle complicated issues involving soil and groundwater contamination …  Those projects when we can roll up our sleeves and help our clients figure out Where did the contamination originate?  Who is responsible?  How do you prove it?  How do you most effectively address the issue? The more constant part of our business is environmental compliance.  Environmental compliance isn’t “sexy,” and when you stay ahead of the enforcement curve, it isn’t exciting. But as anyone who has been on the wrong...

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