Category: Special Topics in Environmental Management

The Truth about CSOs

Here’s the Problem About 700 U.S. cities, concentrated in the Northeast, the Great Lakes region, and the Pacific Northwest, have combined sewer systems (CSSs).  CSSs link sanitary sewers and stormwater conveyances to outfalls to surface water bodies.  When the weather is dry or moderately wet, the CSS carries both urban street runoff and sanitary sewage […]

A Quick Look at Changes to the Stormwater MSGP

Note: Industrial facilities that want coverage under the 2015 MSGP must submit a Notice of Intent (NOI) by September 2 to be covered by the new permit. No NEPA Review for New Sources The EPA prepared an environmental assessment (EA) under the National Environmental Policy Act (NEPA) to determine the potential environmental impact of the […]

Will You Be WOTUSed?

Who Gets WOTUSed? Do the waterbodies near where you want to either develop or expand meet the new definition of waters of the United States (WOTUS), requiring you to get a permit? Here are some things to consider. You Need to Get a Permit if the Water … Is currently in use, was used at […]

What They’re Saying about WOTUS

What WOTUS Does Briefly, WOTUS redefines which waters are waters of the United States and, by doing so, decides whether your project will need a permit. According to the EPA, the rule does not alter existing exemptions from Clean Water Act (CWA) jurisdiction, including exemptions for normal farming, ranching, and silviculture activities. The major and most […]

Can Suppliers Help Your GHG Emission Reduction Efforts?

Suppliers, if you’re breathing a sigh of relief because so far the EPA has not targeted you to reduce your GHG emissions, don’t settle back just yet. Walmart, et al. may be doing the Agency’s job for it. Recap: Scope 3 emissions include indirect GHG emissions from sources not owned or directly controlled by the company […]

Not Just the Big Guys—Where Do GHG Emissions Come From?

Today we will discuss how the EPA categorizes GHG emissions and why its approach doesn’t affect just large sources. Tomorrow we will look at how large companies are doing EPA’s job and finding some success in reducing overall GHG emissions by leaning on smaller companies such as their vendors. ‘Scope’ It Out! The GHG emissions […]

UST Amendments—What You Need to Know About O&M and Secondary Containment

According to the EPA, while information on sources and causes of releases show that releases from tanks are less common than they once were, releases from piping and spills and overfills associated with deliveries have emerged as more common problems. The Agency attributes the lack of proper operation and maintenance of UST systems as a […]

Refrigerants—Cold Lessons Learned

A refrigerant formulator was recently fined $300,000 by the EPA and the Department of Justice for violations of SNAP regulations. First, let’s look at what the pertinent regulations say, then at what the company allegedly did, and finally what the fix will be. Note: Under SNAP, a “producer” is any person who manufactures, formulates, or […]

Managing Refrigerants—It’s a SNAP!

Many refrigerants have been determined to be ozone-depleting substances (ODS) and have been targeted for phaseout under the Montreal Protocol. Chemicals used in the Refrigeration and Air-Conditioning industrial sector is one group for which the U.S. Environmental Protection Agency (EPA) has reviewed and identified substitutes under the Clean Air Act’s (CAA) Significant New Alternatives Policy […]