Category: Special Topics in Environmental Management

EPA Begins Rulemaking on Streamlining NSR

The EPA is proposing to amend its New Source Review (NSR) regulations (40 CFR 51.166 and 51.165) to allow the emissions decreases from a single project to be included in Step 1 of the NSR applicability test. The EPA has interpreted existing regulations to indicate that only emissions increases may be considered in Step 1, […]

Green Chemistry

What’s the Definition of ‘Green Chemistry?’

Green chemistry and its close relative, sustainable chemistry, are concepts and practices that would seem to have no detractors, not within industry, not among environmental and public health groups, and not throughout the federal and state governments. And yet, while no one appears to publicly oppose these types of chemistry, their integration into the manufacturing […]

Hard-rock mining

Hard-Rock Mining Not Subject to Financial Responsibility Rule

If a federal agency proposes a regulation and then subsequently declines to promulgate that regulation, is the second action arbitrary and capricious because it is not a “logical outgrowth” of the proposal, that is, because the option not to regulate is not sufficiently discussed in the proposal?

Inspector is taking notes to a notepad in front of a facility.

EHS Enforcement Begins (and Ends) with Your Permits

No one looks forward to the day when the regulatory authority arrives at your facility for an inspection.  Will he or she find issues of noncompliance?  Will an enforcement action or penalty be forthcoming?  But remember, the ultimate goal of the inspector is not to write up a notice of violation but to ensure your […]

Shredded tire, tire crumbs

Tire Crumb Study (Part 1) Is Released

The EPA, the Centers for Disease Control and Prevention/Agency for Toxic Substances and Disease Registry, and the Consumer Product Safety Commission have released the first report in their investigation into recycled tire crumbs that are used in playing fields and playgrounds.

EPA, Environmental Protection Agency

OECA Finalizes Policy on EPA-State Enforcement Partnership

The EPA’s Office of Enforcement and Compliance Assurance (OECA) has finalized a policy document titled Enforcing Effective Partnerships Between the EPA and the States in Civil Enforcement and Compliance Assurance Work. The intent of the document is to delineate to the extent possible how the EPA and states that are authorized to implement and enforce […]