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05/08/2012

Get Ready Now for July 1st TRI Reporting Deadline!

It’s that time again. July 1st is the deadline for submission of the Toxic Release Inventory. Here’s a reminder of the Who, What, and When of TRI....

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04/10/2012

New Construction General Permit for Stormwater Discharges

On February 16, 2012, U.S. EPA issued a new Construction General Permit for Stormwater Discharges, replacing the 2008 Construction General Permit that expired on February 15, 2012. Clean Water Act permits typically must be renewed every...

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03/13/2012

Safe Drinking Water Act: Two Kinds of Water Quality Standards

Q. Under the Safe Drinking Water Act, the Environmental Protection Agency establishes quality standards for public water supply systems. The EPA sets two kinds of standards: “Primary” and “Secondary.” What’s the difference...

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02/14/2012

Tier II Reporting: LEPCs and SERCs

Yes, it’s that time again! The annual hazardous chemical inventory report required under the EPCRA rules at 40 CFR 370 is due on March 1, 2012. The inventory reporting rule applies to any facility that is required to prepare or have available a material safety data sheet (MSDS) for a hazardous chemical under...

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02/14/2012

Federal Register Prints Flexibility Agendas

Yesterday, the Federal Register finally published the Fall 2011 Regulatory Flexibility Agendas, as required by the Regulatory Flexibility Act (5 USC 602). Compared to the Unified Agenda published last month (and discussed ), the Flexibility Agendas only include rules that have a significant economic impact on a substantial number of small entities (SEIOSNOSE) or are otherwise identified as significant rulemakings. Ever since the OMB took the lead on managing the agendas...

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01/31/2012

Fall 2011 Regulatory Agendas: Environmental Protection

Twice each year, the departments and independent agencies of the Federal government publish public agendas of their rulemaking activities. These semiannual agendas both review recent new rules and announce upcoming rule activities. While each agency and department creates its own agenda...

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01/10/2012

TSCA Chemical Data Reporting: The New Form U and You

On August 16, 2011 (76 FR 50816), EPA published its new Chemical Data Reporting (CDR) Rule, replacing the previously existing Inventory Update Report (IUR) Rule. While the form for submitting data remains the same (the Form U), some key information has changed...

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12/13/2011

Environmental Regulations Year in Review

As the year comes to a close, we take a moment to look back and reflect on what the U.S. Environmental Protection Agency has done, and not done, over the past twelve months...

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11/29/2011

Preparing for 2012 Reporting Obligations

Personally, the last month of the year usually means entry into the year–end holiday season. For EHS managers, this should also mean preparing your 2012 compliance calendars. These calendars will likely include various reporting obligations. While many of your reporting obligations and frequencies are site–specific (e.g., NPDES discharge monitoring reports and Clean Air Act Title V certifications), some events...

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11/08/2011

Feature Article: Trick or Treat? EPA Issues NPDES General Permit for Pesticide Application

On October 31, 2011, the EPA finalized a general permit under the Clean Water Act National Pollutant Discharge Elimination System (NPDES) for pesticide applications [76 FR 68750, November 7, 2011]. This action is the final step in fulfilling the Agency’s obligations in response to...

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When US EPA introduced the Resource Conservation and Recovery Act (RCRA), the hazardous waste management standards included reduced requirements for some large-volume wastes. After studying the hazards of wastes in oil and gas exploration and production (E&P) operations, as directed by the US Congress, EPA determined regulation of these wastes under RCRA was not warranted. Therefore, many oil and gas E&P wastes are excluded from the RCRA Subtitle C hazardous waste management standards.

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Understanding the RCRA Exclusion for Oil and Gas

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