Audit, Compliance and Risk Blog

New Rules for Fracking on Federal Lands

Posted by Jon Elliott on Tue, Apr 07, 2015

Although the pace of fracking projects rises and falls with changes in oil prices, regulation of fracking develops at slower and steadier rates. This month, the U.S. Bureau of Land Management (BLM) has completed nearly five years of rulemaking by revising its rules for oil and gas production from federal and Indian lands, to add requirements for hydraulic fracturing projects. These rules update and expand drilling permit rules in place for three decades. BLM reports that production from over 100,000 onshore oil and gas wells on federally-managed land accounts for 11 percent of U.S. natural gas supply and five percent of its oil, and that over 90% of wells currently being drilled on these land involve hydraulic fracturing.

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Tags: Environmental risks, Environmental, EHS, EPA, Greenhouse Gas, fracking, hydraulic fracking

Have You Completed Your Hazardous Materials Management Plan?

Posted by Jon Elliott on Wed, Feb 25, 2015

A wide variety of federal, state and even local laws apply environmental, health and safety (EH&S) protection requirements to chemicals. EH&S compliance personnel are accustomed to complying with chemical management requirements imposed by the Environmental Protection Agency (EPA), Occupational Safety and Health Administration (OSHA), and their state equivalents.

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Tags: Corporate Governance, Health & Safety, OSHA, California Legislation, Environmental risks, Environmental, EPA, Greenhouse Gas, ghg, Hazcom

Composting in a Condo

Posted by Jane Dunne on Tue, Feb 10, 2015

Being a good citizen and composting food scraps really isn’t that hard if you live in a house. But what if you live in a condo? You might think it isn’t possible (or maybe you even think it isn’t worth it) to do your part and compost your organic wastes. Let me show you how to do it and why it’s worth it.

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Tags: Health & Safety, Environmental risks, Environmental, EHS, Greenhouse Gas, ghg

EPA Proposes Stricter Standards For Ground Level Ozone in Ambient Air

Posted by Jon Elliott on Mon, Jan 19, 2015

The Clean Air Act (CAA) requires the Environmental Protection Agency (EPA) to create a list of air pollutants based on emissions that cause or contribute to air pollution that may reasonably be anticipated to endanger public health or welfare.  EPA also sets air quality criteria for acceptable concentrations in ambient air, referred to as National Ambient Air Quality Standards (NAAQS).

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Tags: Environmental risks, Environmental, EPA, Greenhouse Gas, ghg, climate change

U.S. And China Try To Change The Climate Change Conversation

Posted by Jon Elliott on Wed, Nov 26, 2014

On November 12, U.S. President Barack Obama and Chinese President Xi Jinping announced a bilateral agreement to cut greenhouse gas (GHG) emissions. Since these countries are the two biggest economies and largest emitters of GHGs – and are in a period when they seem to disagree about almost everything – this agreement has substantial symbolic value. But will it have much practical value?

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Tags: Business & Legal, Environmental risks, Environmental, Greenhouse Gas, ghg

Climate Change Adaptation Plans—EPA Issues A Model

Posted by Jon Elliott on Mon, Nov 24, 2014

Strategic planners around the world are preparing “climate change adaptation plans,” designed to identify their organization’s key activities and missions, evaluate how climate change might affect them, and develop organizational changes designed to anticipate and adapt in ways that preserve the organization’s performance. On October 31, the US Environmental Protection Agency (EPA) issued its own Climate Change Adaptation Plan. EPA’s divisions (Water, Air and Radiation, etc.) and 10 regional offices also issued plans covering their activities. These Plans provides a collective model for multi-level organizational plans, and also tell organizations in the US what help to expect from EPA when they plan for their own adaptations to climate change.

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Tags: Corporate Governance, Business & Legal, Environmental risks, Environmental, EHS, EPA, Greenhouse Gas, climate change

EPA Reports Progress On Urban Air Toxics

Posted by Jon Elliott on Mon, Sep 15, 2014

Important Clean Air Act (CAA) elements direct the US Environmental Protection Agency (EPA) to reduce emissions of hazardous air pollutants (HAPs). Unlike the conventional pollutants associated with regional problems such as smog or acid rain, HAPs represent a list of 187 specific air toxics that can be harmful in low concentrations in much smaller areas. HAPs are subject to tighter controls and lower permitting thresholds.

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Tags: Business & Legal, Health & Safety, Environmental risks, Environmental, EHS, EPA, Greenhouse Gas, ghg, Hazcom, mact

Supreme Court Narrows EPA Authority to Regulate CO2 Emissions

Posted by Jon Elliott on Mon, Jul 21, 2014

Since the US Supreme Court affirmed in 2007 that the Clean Air Act (CAA) provides the Environmental Protection Agency (EPA) with authority to regulate carbon dioxide (CO2) and other greenhouse gases (GHGs), EPA has pursued a growing set of regulatory initiatives. In each, EPA has attempted to fit GHGs into statutory and regulatory programs originally designed for more conventional pollutants – and the entities it targets have sued the agency claiming the stretch to GHGs exceeds EPA’s authority. Each court decision has adjusted the contours of EPA’s CAA authority, legitimizing some stretches and vacating others.

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Tags: Corporate Governance, Business & Legal, Environmental risks, Environmental, EHS, EPA, Greenhouse Gas, ghg

NTSB and PHMSA Focus on Facility Response Plans for Pipelines

Posted by Allison Campbell on Mon, Jul 14, 2014

Investigation of the 2010 spill at Marshall, Michigan, the largest on-land spill in US history, underlines the reality that a Facility Response Plan (FRP) is more than a government-required document—an inadequate document or plan can lead to environmental and economic disaster. Owners and operators of onshore pipelines must review and update FRPs every five years from the date of last submission or last approval, and whenever new or different operating conditions arise that would affect the plan. (49 CFR 194.121 Response Plan Review and Update Procedures). PHMSA recently released two Advisory Bulletins reminding operators what it requires in an FRP and listing five of the most common reasons for it to reject an FRP.

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Tags: Corporate Governance, Business & Legal, Health & Safety, Environmental risks, Environmental, EHS, EPA, Greenhouse Gas, ghg, Hazcom, Oil & Gas, Transportation

What might EPA’s Clean Power Plan Mean?

Posted by Jon Elliott on Mon, Jun 09, 2014

On June 2, the U.S. Environmental Protection Agency (EPA) proposed a new Clean Power Plan, in which the agency will apply its authority under the Clean Air Act (CAA) to dramatically reduce greenhouse gas (GHG) emissions from fossil fuel-fired electric generating units (EGUs). EPA calculates that these power plants account for roughly one-third of all domestic GHG emissions in the US. Advocates on opposite sides of this controversial proposal claim this Plan would either become the most important US initiative to address climate change, and/or would crash economies through much of the US heartland by strangling coal-fired electricity production. Let’s hope we end up closer to the optimistic scenario!

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Tags: Corporate Governance, Business & Legal, Health & Safety, Environmental risks, Environmental, EPA, Greenhouse Gas, ghg