Archives

Five Steps to See if You Could Be a DHS High-Risk Chemical Facility

Yesterday we reviewed the Department of Homeland Security’s (DHS) new plans to improve how it assesses facility risks under the Chemical Facility Anti-Terrorism Standards (CFATs).  Today we will outline five steps to help you determine if your facility could be targeted as high risk and subject to submitting the initial Top-Screen survey to the DHS.

D.C. Circuit Issues Mammoth Ruling on Combustion Rules

In one of the more impressive displays of environmental law we have seen, a panel of the U.S. Court of Appeals for the D.C. Circuit ruled on approximately 30 consolidated challenges—about half filed by industry and half by environmental groups—to three EPA rules issued to control emissions of air toxics from combustion units. Industry struck […]

Exemption for Closed CCR Landfills… Canceled!

In response to an order from the U.S. Court of Appeals for the D.C. Circuit, the EPA has issued a direct final rule amending its regulations (April 17, 2015, FR) governing the disposal of coal combustion residuals (CCRs) as solid waste under Resource Conservation and Recovery Act (RCRA) Subtitle D. In the CCR rule, the […]

Calculations for Containment Size

Q. In doing calculations for the size of containment, can you include the equilibrium volume of the inside of the storage tank as part of the containment volume? How often should a tank have integrity test done?

earth

Climate Change Now a Big Part of NEPA Reviews

A little more than 3 years after President Obama introduced his national action climate plan in a speech at Georgetown University, the White House Council on Environmental Quality (CEQ) has released final guidance on how federal departments and agencies should consider greenhouse gas (GHG) emissions and the effects of climate change in reviews conducted under […]

What to Do if Your Facility Poses Chemical Security Risks

What should you do if you think your facility poses security risks under the Department of Homeland Security’s (DHS) Chemical Facility Anti-Terrorism Standards (CFATs)? First of all, take a breath and step back. Today we will review DHS’s plans to improve how it assesses CFAT facility risks, and tomorrow we will offer five steps to […]

A General Air Permit… Is It Right for Me?

Obtaining an air permit is not often a quick or simple process, but under the correct circumstances the process can be streamlined by using a general permit. Regulatory agencies often develop general permits for common source categories with similar operations, similar emissions, and similar regulatory requirements.

Training Records: How to Choose an LMS that Works for You

Keeping track of training is an essential task for environment, health, and safety (EHS) managers, but it can be time-consuming and difficult to keep up with. Enter learning management systems (LMSs), electronic databases specifically designed for tracking employee training and continuing education. But if you’ve ever chosen or had to work with a poorly designed, […]