In case you missed it, on June 15, (now former) U.S. Environmental Protection Agency (EPA) Administrator Scott Pruitt signed a proposed action to establish no additional regulatory requirements under the Clean Water Act (CWA) section 311(j)(1)(C) authority for CWA hazardous substances (HS) discharge prevention. The EPA published the Notice of Propose Rulemaking (NPRM) on June […]

Your engineer finally delivered the Spill Prevention, Control, and Countermeasure Plan (SPCC Plan) for your facility, and it requires that you train Oil-handling employees. Oil-handling employees? How do you determine which of your employees meet the definition of that term? BACKGROUND EPA’s SPCC regulation (found at 40 CFR 112.7) require that the owner or operator […]

If you think your facility doesn’t have a Class V underground injection well, you might want to check again. Recent enforcement action by EPA Region 9 has resulted in violations against facilities that failed to identify, register, and maintain their dry wells.  If you don’t know what an underground injection well is, read on. What […]

Well, we think so. Identifying the same type of compliance deficiency in multiple locations, or during each recurring audit for the same facility, can only get us so far. Assuming the deficiency was corrected following each audit, the problem is re-emerging. Perhaps if we figured out the underlying cause, we could resolve it once and […]

On January 15, 2018, increased EPA civil penalty levels went into effect. These penalty increases, which are intended to keep up with inflation, increase the maximum civil penalties EPA can impose for violations of environmental laws by two percent. Clean Air Act (CAA): $97,229 (from $95,284) Clean Water Act (CWA): $53,484 (from $52,414) Resource Conservation […]

While reviewing the potential impact upon historic resources in northwest Tennessee, we had an opportunity to perform a Historical Architecture Survey. This survey entailed of recording over 250 structures that were older than 50 years old. I performed the field reconnaissance and our architectural historian, Chris Baker, evaluated these places based on documentary evidence. The […]

On a foggy November morning in Western Maryland, I find myself alone on a mountain top. Although Halloween had pasted, the atmosphere is something out of a Stephen King story. I am here to evaluate the area where a proposed telecommunications tower will be located. What does archaeology have to do with telecommunications tower? The […]

As opposed to a commercial ESA where the property footprint consists of a building, series of buildings, a city block, or an undeveloped acreage, a wireless Phase I ESA is typically focused on a specific site location, existing tower compound, or proposed installation path within a building.  The wireless company is concerned not only with […]