Category: Special Topics in Environmental Management

News: Farmers, Are You Exempt?

Regulatory exemptions for farms are common throughout the major U.S. environmental statutes, including the Emergency Planning and Community Right-to-Know Act (EPCRA). But exemptions for farms do not apply to all requirements in the major reporting provisions of EPCRA.

D.C. Circuit Upholds 2012 Chromium NESHAP

In an opinion filed July 21, 2015, two legal challenges to multiple aspects of EPA’s 2012 revised National Emissions Standards for Hazardous Air Pollutants (NESHAP) governing chromium electroplating and anodizing facilities were consolidated and denied in their entirety by a panel of the U.S. Court of Appeals for the D.C. Circuit.  The EPA had revised […]

Oil Spill Bi-Products and Municipal Landfills

Under the used oil management rules at 40 CFR 279.22(d), upon detection of a release of used oil to the environment (e.g. soil) that is not subject to the underground storage tank requirements of 40 CFR 280, generators of used oil must (among other requirements) “clean up and manage properly the released used oil and […]

Is The President’s Climate Pledge Out Of Reach?

In December 2015, representatives of the world’s nations will convene in Paris to negotiate a climate change agreement to replace the 1997 Kyoto Protocol.  In contrast to limited U.S. involvement in the development and implementation of the Kyoto agreement, the U.S. is expected to play a pivotal role in the Paris talks. Read more.

Is it safe to say that the RCRA regulations on recyclable materials from which precious metals are reclaimed have not been affected by the 2015 DSW Final Rule?

The 2015 Definition of Solid Waste Final Rule (2015 Final Rule) does not significantly affect the recycling exemption from full RCRA Subtitle C regulation found at 40 CFR 266.70 for precious metals being reclaimed in accordance with the 40 CFR 266.70 provisions. When in the process of revising the 2008 DSW rule, however, EPA did […]

Are Our Chemical Facilities Safe Enough?

In August 2013, President Obama issued Executive Order (EO) 13650, titled Improving Chemical Facility Safety and Security, largely in response to the ammonium nitrate explosion in West, Texas. The EO directed actions to be taken on many fronts to address chemical facility safety, but two years later, what progress has been made on the front […]