In our October 17th blog, we shared EPA’s Enforcement Initiatives for 2017-2019 (the new “cycle” will begin October 1, 2016). Based on “stakeholder” feedback, those plans have now been expanded.
The original initiatives, such as focusing on livestock agriculture, reducing air pollution, and energy extraction, all remain. The new and expanded initiatives are outlined below:
New EPA Initiative: Keeping Industrial Pollutants Out of the Nation’s Waters
According to the EPA, “Certain facilities in industrial sectors like chemical and metal manufacturing, mining and food processing are responsible for nutrient and metal pollution in lakes, rivers and streams, and can degrade water quality and threaten drinking water sources (emphasis added).”
Comment: The EPA also stated that they will focus on reducing “illegal pollution discharges.” Whether this includes, and/or will focus on, point and non-point sources discharges isn’t clear. Certainly, if you happen to be involved in one of the mentioned industry sectors, you will want to get your various “discharge ducks” in a row. As an aside, if you happen to have concerns about non-point source runoff of nitrogen, see this webinar on nitrogen runoff by Dr. Michael Sklash (conducted for National Milk Producers Federation).
New EPA Initiative: Reducing Risks of Accidental Releases at Industrial and Chemical Facilities
According to the EPA, “Thousands of facilities nationwide, many of which are in low income or minority communities, make, use and store extremely hazardous substances. EPA will focus on reducing the risks of accidents through innovative accident prevention measures and improving response capabilities.”
Comment: Requirements for management/storage of chemicals at manufacturing facilities has become increasingly stringent and, in some cases, burdensome. Regulations change, new/different chemicals are used, and processes are modified depending on client needs. For these reasons (and more) we routinely assist companies with environmental compliance assessments.
No one, regardless of income of social status, should be unnecessarily exposed to pollutants. The politicization of pollution, however (which is often associated with discharge permits in low-income/minority neighborhoods), can be emotionally charged and can ultimately discourage manufacturing jobs where they are needed most.
We hope that the new and expanded initiatives will keep partisan politics out of the mix and that decisions are based on science.
EPA Expanded Initiative: Cutting Hazardous Air Pollutants
According to the EPA, “Leaks, flares, and excess emissions from refineries, chemical plants and other industries emit hazardous air pollutants that are known or suspected to cause cancer and birth defects, seriously impact the environment, and pose risks to local communities and facility employees. EPA will continue to implement this initiative, and expand it to address air toxics violations at facilities that generate, treat, store or dispose of hazardous waste.”
Comment: See our previous comment (above).
For more information on the EPA’s February 18, 2016, announcement regarding their Enforcement Initiatives, click here.
Practical Environmental Solutions
For nearly 30 years, Dragun Corporation has been assisting our clients with practical environmental solutions. If you have questions about an environmental compliance issue, contact Matthew Schroeder, M.S., P.E. (mschroeder@dragun.com) or Jeffrey Bolin, M.S., CHMM (jbolin@dragun.com). Matt has 20 years of experience, and Jeff has more than 30 years of experience. Both Matt and Jeff have practical experience in negotiating environmental permits with state and federal regulators.