TRI and P2 APR – Successfully Closing Out This Reporting Season

March reporting deadlines are still on the horizon. While you still have time, watch our uploaded January webinar and review our slides to assist in your first round of reporting. While you’re still finalizing your March reports, be mindful of the July 1st TRI and P2 Annual Progress Report just around the corner. We will host a live lunchtime webinar on March 28th to help you prepare for report requirements, report submittal and best methods for reducing waste and TRI releases. Texas’ Waste Reduction Policy Act of 1991 was adopted to prevent pollution in Texas. The Texas Commission on Environmental Quality (TCEQ) adopted the corresponding rule under 30 TAC 335 Subchapter Q, which requires small and large quantity generators of hazardous waste and TRI reporters to prepare a five-year P2 Plan and submit an Executive Summary of the plan to TCEQ. Large quantity generators and TRI reporters are also required
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Owners of the Land Lend a Hand: The Role of Landowners in Endangered Species Recovery

Imperiled species and their habitats are protected under the Endangered Species Act (ESA), administered by the U.S. Fish and Wildlife Services (USFWS) and the National Marine Fisheries Services (NMFS). Threatened and endangered species are afforded the same protection under the Act and are listed solely based on their biological status and threats to their existence. Under the Act, species and their habitats are protected by prohibiting the “take” of listed animals and trade in listed plants and animals. The USFWS and NMFS, along with their partners (including private landowners), also work towards the recovery of species, where the decline of species at risk is mitigated by removing or reducing threats to those populations. In May 2018, the black-capped vireo was removed from the federal threatened and endangered species list.  This small songbird with a black cap and white face mask was listed as federally endangered in 1987 mainly due to
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AWS and Tier II are just Warmups – The TRI/P2 Deadline is Looming

We kicked off this reporting season with our March reporting deadlines, which we covered in our Compliance Reporting webinar. As March is quickly approaching, you can still watch the uploaded webinar and review our slides to assist in your first round of reporting. It’s not over just yet – the July 1st TRI and P2 Annual Progress Report deadlines will be here before you know it. We will host a live lunchtime webinar on March 28th to provide essential information such as requirements to report, data gathering and the preparation and submittal of these reports so you can be prepared and start early! The Toxic Release Inventory (TRI) program requires regulated industries to report certain toxic chemicals that are released to the environment.  The TRI reporting program is often referred to as Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA) which was passed by Congress in 1986. 
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Key Factors in a Successful Remediation Project

We have previously discussed spill response activities for Sites where an active release occurred and identified key factors in addressing spills.  For historical release Sites that were not addressed or Sites which have undergone insufficient remediation of contaminated media (soil, surface water, groundwater), it is important to formulate a complete Site remedial strategy to establish what the end goal will be for site clean-up. Utilizing regulatory guidance, along with identified Site-specific characteristics, allows for flexibility in site clean-up approaches. Consistent Strategy. It is very important to establish what the key drivers are for the Site-specific contaminants.  Whether it is crude oil, condensate, refined product, produced water, or stored materials on Site — developing a sampling program to address the extent of affected media will allow for consistency in evaluating data and presenting information to the regulatory agency.  It is equally important to develop consistent field screening methods and action levels to
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Too Many Cooks in the Kitchen?

Keeping your project on track when you have stakeholder involvement You’re an environmental manager for your company, and you learn that a contractor doing repair work has caused a release from one of your pipelines which is located on private property.  You report the spill to the authorities, notify the landowner, and initiate cleanup activities.  The contractor files a claim with their insurance carrier. Following initial response actions, soil and groundwater is investigated and cleanup goals are established.  It sounds straightforward until the various stakeholders get involved.  The stakeholders include the construction contractor, their insurance company, the insurance company’s consultant, the regulatory agency, and the landowner, in addition to you and your environmental consultant.  All parties want the spill cleaned up but have different goals and objectives. In another case, no one knows exactly when the spill, or multiple spills, occurred, but the cleanup has been underway for years. Initial
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Avoiding Pitfalls in Environmental Reporting

We at W&M, somewhat affectionately, refer to the time period of January 1 – July 1 as “Reporting Season” due to the myriad of compliance deadlines all crammed into that timeframe.  As you will recall, it all begins on March 1 with the Emergency Planning and Community Right-to-Know Act (EPCRA) Tier II reporting and Annual Waste Summary (AWS) reporting deadline.  Shortly after is the March 31 deadline for Air Emissions Inventory Reporting (AEIR) and the Multi-Sector General Permit (MSGP) Stormwater Pollution Prevention Plan (SWP3) annual reporting.  As you would expect, there are a number of pitfalls that you will want to avoid when completing your reporting.  We’ll discuss more during the January Webinar, but here are a few to get you started: Pitfall #1:  Quality of Information Not all information is created equal and not all information is good information.  When gathering data, it is important to be specific as
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Proposed Changes to the Endangered Species Act

ASSESSMENTS AND ECONOMIC CONSIDERATIONS In July of this year, the federal government proposed an amendment to the Endangered Species Act (ESA) that redefines/streamlines the procedures and criteria for listing and delisting endangered species and designating critical habitat.  There are a handful of amendments that are proposed but the overall direction points to allowing the U.S. Fish and Wildlife Service (FWS) to make unique or tailored assessments based on the species, habitat, region, etc. when deciding to list or delist a species. Additionally, the ESA currently states that it will not take economic or other impacts into consideration when listing, delisting, or reclassifying a species.  That is not being changed at this time.  However, under the proposed amendments, the FWS acknowledges that there is value in referencing economic or other considerations such as ambient air studies, cost/benefits analysis, etc. By clarifying the criteria for critical habitat designations, the proposed changes aim
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Brace yourself for March, it’s just around the corner.

For Environmental Health and Safety (EHS) Managers or professionals, the new year brings a new outlook on your job, promises to yourself and your company, and the desire for improvement over the past year. Unfortunately, the new year also brings the crushing realization that March is just around the corner, almost taunting you for becoming cocky in November and December when few environmental reports are due to the State or EPA. March marks the beginning of the annual reporting deadlines. The reporting calendar begins with the Emergency Planning and Community Right-to-Know Act (EPCRA) Tier II report and the Annual Waste Summary (AWS) due March 1st, and then you dive right into the Multi-Sector General Permit (MSGP) Stormwater Pollution Prevention Plan (SWP3) Benchmark Monitoring (BM) reporting and Discharge Monitoring Report, and the Air Emissions Inventory Report (AEIR), all due on March 31.  Individually the reports are not overly difficult or time
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A.D.D.ing It All Up

We never thought we would want to write about this topic, much less need to write about it. Unfortunately, it is the reality we live in. We all spend much of our day in office areas with dozens of co-workers, a good portion of us are parents with school-aged children, and we spend a large part of our lives in congested areas (shopping malls – while they still exist, hospitals, churches, etc.) – each potentially susceptible to attack Adapting to an unfortunate reality Active shooter situations are occurring at an alarming rate and don’t appear to be limited to a specific race, culture, demographic, or even physical region. What makes active shooter situations so frightening is that there is no real outward rhyme or reason as to when and where they occur. They are unpredictable by nature. They typically involve only one or two shooters that have a plan (well developed
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Waste Management Needs Everyone’s Help! If Not, It’s Just a Waste!

How often do you walk through your facility and spot an unlabeled or open waste container? As you walk through your plant and waste storage areas, do you see problems with waste and product management, such as missing signage or products stored outside of secondary containment. You think, “These problems weren’t here last week!”, and “What am I going to do, we have an internal audit is next month!!” As an ESH professional, it’s easy to “see” these items are not in compliance with the regulations. However, do the workers and supervisors understand the requirements AND the results if an outside agency finds them? For better or worse, most ESH professionals are responsible for all three areas of compliance – environmental, health and safety. Environmental compliance is a big responsibility, and one person can’t be in the entire facility every moment of every day. You need help! You could ask
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