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New Documents
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News:
On July 9, 2018, his first day as Acting EPA Administrator, Andrew Wheeler denied a petition to reconsider the Agency’s residual risk and technology review (RTR) of its 2001 National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand-Alone Semi-Chemical Pulp Mills.
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Industry struck out swinging on all five parts of its petitions to the U.S. Court of Appeals for the D.C. Circuit to invalidate requirements in the EPA’s National Emissions Standards for Hazardous Air Pollutants (NESHAP) for Brick and Structural Clay Products Manufacturing; and the NESHAP for Clay Ceramics Manufacturing.
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In implementing major policies, it is unlikely that Andrew Wheeler, the EPA’s new acting administrator, will differ in any significant way from Scott Pruitt, the man he’s replacing to direct the activities of the Agency’s 14,000 employees.
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In his 12 years as a judge on the U.S. Court of Appeals for the D.C. Circuit, Brett Kavanaugh has been a prolific author, writing nearly 300 opinions, including a handful addressing the legality of major EPA regulations.
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Judge Brett Kavanaugh, President Donald Trump’s choice to replace Justice Anthony Kennedy on the bench of the U.S. Supreme Court, has served as a judge on the U.S. Court of Appeals for the D.C. Circuit since 2006, three years after he was nominated for the position by President George W. Bush.
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Beginning January 1, 2019, employers with employees who apply pesticides by spray to agricultural fields in Oregon will be subject to state rules to protect agricultural workers, the pesticide applicators, and others, including the families of these workers.
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Notwithstanding many verbal endorsements from the Trump administration and several preliminary regulatory actions, coal-fired energy is not experiencing a renaissance in the United States.
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In a tweet, President Trump has accepted the resignation of Scott Pruitt, as EPA Administrator. Deputy Administrator Andrew Wheeler will step in as Acting EPA Administrator. Pruitt was perhaps the most controversial selection to head the Agency.
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White Papers:
After years of sputtering progress, the Department of Homeland Security’s (DHS) Chemical Facility Anti-Terrorism Standards (CFATS) program is beginning to resemble a well-run, if not yet mature, government-industry undertaking.
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The June 2016 amendments to the Toxic Substances Control Act (TSCA) expanded the categories of persons who may request confidential business information (CBI) about chemicals, which regulated entities submitted to the EPA.
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Guidance Documents:
This EPA fact sheet explains how inspectors can review manifests on the e-Manifest system prior to conducting and onsite review, obtain copies of the manifests, and verify that recordkeeping requirements are being met.
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This EPA fact sheet explains how site mangers obtain access to view, create, and /or sign manifests electronically and the three permission levels for e-Manifest: viewer, preparer, and certifier.
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Updated Documents
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Forms:
Use this form template to document any benchmark exceedances and how they were responded to, including corrective action taken, a finding that the exceedance was due to natural background pollutant levels, or a finding that no further pollutants reductions were technologically available and economically practicable and achievable.
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Use this form template to document maintenance of your stormwater control measures.
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Use this form template to document any corrective actions taken at your facility.
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Use this form template to describe any deviations from the schedule for visual assessments and/or monitoring and the reason for the deviations.
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Use this form template to document employee training about the requirements of the stormwater pollution prevention plan (SWPPP).
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Use this form template to document the maintenance of your facility's industrial equipment and systems.
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Use this form template to document your routine facility inspections pursuant to your industrial stormwater permit.
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Use this form template to document the amendments to your stormwater pollution prevention plan (SWPPP).
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Use this BLR document as an attachment to your hazardous waste contingency plan or as a stand-alone list of emergency contacts.
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Use this BLR document as an attachment to your hazardous waste contingency plan or as a stand-alone record of your procedures to decontaminate equipment, personal protection equipment (PPE), and workers.
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Use this BLR document as an attachment to your hazardous waste contingency plan or as a stand-alone list of the hazardous waste generated and/or stored at the facility.
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Use this BLR document as an attachment to your hazardous waste contingency plan or as a stand-alone list of your procedures for responding to tank and container spills.
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Use this BLR document as an attachment to your hazardous waste contingency plan or as a stand-alone list of emergency procedures in the event a tank or drum storing hazardous waste ignites.
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This EPA form is untilized to notify the agency of demolition or renovation activities subject to the Asbestos NESHAP under 40 CFR 61, Subpart M (40 CFR 61.145).
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Guidance Documents:
This EPA fact sheet explains how inspectors can review manifests on the e-Manifest system prior to conducting and onsite review, obtain copies of the manifests, and verify that recordkeeping requirements are being met.
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This EPA fact sheet explains how site mangers obtain access to view, create, and /or sign manifests electronically and the three permission levels for e-Manifest: viewer, preparer, and certifier.
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The EPA has streamlined the self-reporting process under its Audit Policy and Small Business Compliance Policy by developing an online tool for disclosing violations. This infographic highlights what you need to know about EPA’s e-disclosure process.
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This EPA fact sheet describes how generators can use the e-Manifest system to create and track their manifest. It also explains how generators can contintue to use a paper manifest or, alternatively, a "hybrid" manifest (a combination of paper and electronic submissions).
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This EPA fact sheet explains the scope and benefits of the e-Manifest system that launched on June 30, 2018.
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This EPA fact sheet explains what steps facilities that receive hazardous waste must take to use the e-Manifest system. This would include obtaining an EPA identification number.
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This EPA fact sheet explains what steps transporters of hazardous waste must take to use the e-Manifest system.
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This EPA fact sheet explains what steps permitted hazardous waste treatment, storage, and disposal facilities (TSDFs) that receive hazardous waste must take to use the e-Manifest system.
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This EPA fact sheet explains how, under the e-Manifest system, brokers will have the option to prepare manifests electronically for their generator clients. To use an e-Manifest, brokers will need to obtain an EPA ID and register for e-Manifest system.
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Regulatory Analysis:
Required by both the Department of Transportation (DOT) and the U.S. Environmental Protection Agency (EPA), a hazardous waste manifest is the shipping paper for hazardous waste. The paper manifest travels with the hazardous waste from the point of generation, through transportation, to the final treatment, storage, and disposal facility (TSDF). Each party in the chain of shipping, including the generator, signs and keeps a manifest copy, creating a "cradle to grave" tracking of the hazardous waste. Hazardous waste shipments offered for transportation by a generator and shipped to a TSDF may, alternatively, be tracked with an electronic manifest.
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Toxic air pollutants, also known as HAPs, are those pollutants that are known or suspected to cause cancer, other serious health effects, or adverse environmental effects. Other health effects can include damage to the immune system, as well as neurological, reproductive, developmental, respiratory, and other health problems.
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Although climate change remains a topic surrounded by controversy and debate that is zealously supported on both sides, actions are being taken that necessitate businesses evaluate their overall GHG management strategy. Regardless of whether you are a believer or nonbeliever in the climate change issue, regulations are being developed and implemented to monitor and control GHG emissions, and those taking note of these actions will be able to remain in compliance with any applicable requirements and avoid enforcement actions from regulatory authorities.
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