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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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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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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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Will TCE Restrictions Take Effect?

Posted by on 8:02 pm in Blog | 0 comments

If you have worked in the environmental business for more than one week, then you have likely run across Trichloroethylene (TCE) – a super solvent that is very useful and ubiquitous in industry, but due to past management practices, is a common environmental contaminant. The future of TCE, at least for degreasing purposes, may be coming to an end – or is it?  Under the amended Toxic Substance Control Act (TSCA) through the Frank R. Lautenberg Chemical Safety for the 21st Century Act, the Environmental Protection Agency has proposed a...

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USEPA Reductions and Green Groups File Lawsuits

Posted by on 1:47 pm in Blog | 0 comments

In early May, I joined two of my colleagues at an annual environmental conference and trade show in the Toronto area.  In an effort to try to gain some “market intelligence” while at the trade show, we did an informal survey.  We asked those in attendance, “What is the most important environmental issue facing the regulated community in Ontario or Canada wide?”  One of the common answers related to the Trump Administration’s focus on US regulations (as well as trade) and how this might impact Canadian manufacturing companies’ ability to...

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Increased Costs for Non-Compliance and Enforcement Notes

Posted by on 1:34 pm in Blog | 0 comments

In case you missed it, there have been several news stories related to environmental enforcement of late. EPA Substantially Raises the Cost of Non-Compliance In July 2016 and again in January 2017, the Environmental Protection Agency (EPA) bumped the cost of non-compliance.  As stated earlier this year in a post by the regulatory training company,  Lion Technology, “This is the second time in six months that US EPA has raised civil penalties; in July, the Agency published a catch-up Rule that substantially raised the fines under EPA...

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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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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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