Managing refrigerant and refrigeration systems can be a challenge for facilities and facility managers due in part to expanding regulatory requirements. Section 608 (Refrigerant Management Requirements) of the Clean Air Act was updated to expand requirements for managing ozone-depleting substance (ODS) refrigerants to now also include ODS substitutes. ODS substitutes which are now regulated include hydrofluorocarbons (HFCs) (e.g., R-410A, R-407C and R-134a), perfluorocarbons (PFCs) (e.g., R-116), and hydrofluoro-olefins (HFOs) (e.g., 1234YF). These are collectively referred to as “non-exempt ODS substitutes.”Read More
As Americans, we have come to expect that our drinking water supply will be safe and reliable, and with a few notable exceptions such as the situation in Flint, Michigan, this is a reasonable expectation. Federal, state, and local governments have invested billions of dollars to ensure that water delivered to our homes and workplaces is safe to consume. However, routine systems, equipment, and activities have the potential to contaminate water supplies and water systems. By understanding and implementing cross-connection protection practices, we can help to minimize the risk of contamination to our potable water supplies.Read More
Several administrations have made attempts to "streamline" the NEPA process, and in January of this year President Trump issued Executive Order (EO) 13766 Environmental Reviews and Approvals for High Priority Infrastructure Projects, followed in June by EO 13807 Establishing Discipline and Accountability in the Environmental Review and Permitting Process for Infrastructure Projects. The goal of these efforts is to reduce the overall timeline for environmental reviews, with an emphasis on optimizing efficiency, interagency coordination, and reducing unnecessary burdens. In response to the President's Executive Orders, in September 2017, the Council on Environmental Quality (CEQ) issued an "initial list of actions" it will take to enhance and modernize the federal environmental review process, which includes development of a framework for implementation of "One Federal Decision," new guidance for implementing NEPA, and a review of existing CEQ implementing regulations to identify needed changes and clarifications. However, the implementation of these new Executive Orders and related changes to review processes, guidance, and potential regulatory changes will ironically take some time.Read More
The Emergency Planning and Community Right-to-Know Act (EPCRA) requires most federal and industrial/commercial facilities to report information related to their use of hazardous materials. For federal facilities, Executive Order (EO) 12856, Federal Compliance with Right-To-Know Laws and Pollution Prevention Requirements, first established EPCRA reporting requirements, which were later emphasized in EO 13693, Planning for Federal Sustainability in the Next Decade.
This article reviews EPCRA reporting requirements, summarizes some of the hazardous materials that are commonly reported and those that are sometimes overlooked, and provides tips and insights to help facilities remain in compliance.Read More
On November 28, 2016, the U.S. Environmental Protection Agency (EPA) published its final Hazardous Waste Generator Improvements Rule in the Federal Register. The new rule makes over 60 changes to the existing Resource Conservation and Recovery Act (RCRA) generator regulations. Although some of the changes are minor or simple clarifications, many are significant and potentially applicable to every industry that generates hazardous waste. The new rule reorganizes the regulations to make them more user-friendly, clarifies many ambiguities and contradictions, and addresses previously documented gaps in the regulations.
Here are ten things that you should know about the new rule prior to it taking effect.Read More