What Do the New Generator Improvement Rules Mean for TSDFs?


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Most RCRA-permitted TSDFs are also large quantity generators (LQGs).  Prior to the generator improvement rules, some hazardous waste management requirements were consistent between LQGs and RCRA-permitted TSDFs.  Therefore, it was possible for a facility to follow the provisions within their RCRA permit application and comply with those LQG requirements that were consistent.  Since the generator improvement rules have become effective, there are now some obvious differences, most notably with the contingency plan and labeling of waste tanks/containers.

The generator improvement rules require that a quick reference guide to the contingency plan be prepared and submitted to local responders.  This guide must include specific information and maps, presented in layman’s terms.  Labels on waste tanks/containers must identify the hazards of the wastes being accumulated and RCRA waste codes must be marked on waste containers prior to shipment off-site.  So, is a RCRA-permitted facility expected to submit a modification for update of their application?  The answer is No.  If a RCRA permit application currently contains provisions to comply with one or more generator requirements, the facility only needs to prepare or update internal procedures and submit the quick reference guide to local responders to comply with the generator improvement rules.  However, U.S. EPA has recommended that RCRA-permitted facilities review their application to determine if modifications would be beneficial considering the generator improvement rules.

In terms of timing, most of the generator improvement rules must be implemented beginning on their effective date.  For the contingency plan quick reference guide, an LQG (or TSDF that is also an LQG) must prepare and submit the guide the next time some other update to the contingency plan is required.  For facilities that do not routinely update their contingency plan, it is recommended that the quick reference guide be prepare and submitted sooner rather than later to avoid the possibility of forgetting about the requirement.  Cox-Colvin has already begun preparing quick reference guides for clients and helping them navigate the other generator improvement rule requirements. For additional information or assistance, contact the author.

Published in October 2020 Focus on the Environment Newsletter

On September 1, 2020, US EPA Office of Land and Emergency Management (OLEM) Assistant Administrator Peter Wright, announced the 2030 vision, mission, and goals for the Resource Conservation and Recovery Act (RCRA) Corrective Action hazardous waste facility cleanup program.  The announcement of the RCRA cleanup goals for the next 10 years was provided as part of the Association of State and Territorial Solid Waste Management Officials (ASTSWMO) 2020 RCRA Corrective Action Virtual Conference.  The ASTSWMO 2020 Corrective Action Conference was the first national Corrective Action conference since 2008.  The presentations from the virtual conference can be accessed through the ASTSWMO website.

The 2030 vision and goals replace the 2020 goals established in 2004.  The prior goals targeted achieving 95% completion of the following three milestones at 3,779 baseline facilities by 2020:

  • Human exposure under control (aka the Human Health Environmental Indicator [EI] or CA 725)
  • Migration of contaminated groundwater under control (aka Groundwater Environmental Indicator or CA 750)
  • Remedy Construction (aka CA 550)

As part of Peter Wright’s keynote speech, EPA formally stated for the first time that, although close, they would not likely meet all the 2020 Corrective Action goals by the end of the EPA’s 2020 fiscal year.  According to Wright, EPA is projected to meet the Human Health EI goal, achieving the human health under control determination at 96% of the baseline facilities, but would come up short of the goals for the Groundwater EI and the Remedy Construction milestone, achieving 91% and 79%, respectively.

For 2030, EPA has developed a new vision, mission, and goals for the Corrective Action program as follows.

Vision

“RCRA Corrective Action cleanups support healthy and sustainable communities where people and the environment are protected from hazardous contamination today and into the future.”

Mission

“EPA, states, and tribal partners work together to ensure that owners and operators of hazardous waste treatment, storage, and disposal facilities conduct effective and efficient cleanups to protect human health and the environment, support continued use, and make land ready for reuse including, if necessary, placement of controls to protect communities into the future.”

Goals (emphasis added to get to the heart of the goal):

1. Through 2030, the RCRA Corrective Action Program will ensure that RCRA cleanups are initiated and completed efficiently and expeditiously. Commitments regarding what work is planned and what progress is made will be visible to the public. An ambitious universe of cleanups will be identified for completion by 2030.

2. By 2030, the RCRA Corrective Action Program will eliminate or control adverse impacts beyond facility boundaries at RCRA Corrective Action facilities wherever practicable and the program will focus attention on cleanups that will not meet this target.

3. By 2030, the RCRA Corrective Action Program will ensure or confirm that land within facility boundaries at RCRA Corrective Action facilities will be safe for continued use or reasonably foreseeable new uses wherever practicable and the program will focus attention on cleanups that will not meet this target.

4. By 2025, the RCRA Corrective Action Program will identify the key elements of effective Long Term Stewardship for Corrective Action cleanups, and regions and states will have approaches in place to ensure implementation of the key elements.

5. By 2022, program procedures will be in place to regularly adjust the universe of facilities in the cleanup pipeline to reflect current program priorities.

The generally vague vision\mission statements and goals provide little in the way of specifics.  The next step for EPA will be the preparation of a program plan to be completed in four to six months from the announcement.   The program plan should hopefully provide specific details.  But for now, here are the takeaways:

  • From the perspective of the owner/operator, I cannot find fault with the mission statement. EPA claims to have put considerable effort into the crafting of the specific language and it is likely to please most stakeholders.
  • Corrective Action will focus on controlling or eliminating adverse impacts beyond the facility boundaries.
  • EPA has clearly moved beyond investigation of most sites and is focused on remedies and long-term stewardship of the numerous facilities that will rely on land use controls as they wrap up RCRA Corrective Action.
  • Additional scrutiny and better tracking of long-term stewardship of land use controls are likely in the future.
  • Opportunities for public sharing of site information and public involvement in key Corrective Action site decisions are likely to continue to increase.
  • EPA will be reprioritizing the baseline of individual facilities, bringing in those facilities subject to RCRA Corrective Action which were not included in the 2020 baseline of 3,778 of facilities and potentially removing those facilities which have completed Corrective Action.
  • The universe of facilities in the cleanup pipeline will be regularly adjusted to reflect program priorities as opposed to the relatively static baseline of facilities subject to the 2020 goals.

Published in October 2020 Focus on the Environment Newsletter.

On October 21, 2020, the Division of Materials and Waste Management of the Ohio Environmental Protection Agency (Ohio EPA) announced that the proposed explosive gas rule,  for municipal solid waste landfills was filed with the Joint Committee on Agency Rule Review (JCARR).  Landfill gas is a natural by-product of the anaerobic decomposition of organic waste in a landfill.  The composition, quantity and rate of landfill gas generation are dependent on the types of waste that are decomposing and the level of microbial activity in the waste.  The production of landfill gas creates positive pressure with the landfill that forces the gas to migrate. Rule 3745-27-12 of the Ohio Administrative Code (OAC), first enacted in 1988, sets out the requirements for monitoring explosive gas migration at solid waste landfills. The proposed rule submitted to JCARR is substantially different from the 1988 rule. Because more than 50% of the rule was amended, the current rule is being rescinded and the new rule is being promulgated. As such, determining what changes were made to the rule is somewhat problematic. However, these are some of the changes that we see in the proposed rule:

  • Changes to the applicability of the rule, excluding solid waste landfill facilities that have an occupied structure within 1,000 feet of the limits of solid waste placement and were previously licensed between July 1, 1970 and May 31, 1988 unless they have received a notification from Ohio EPA that they are subject to the rule.
  • A requirement that all solid waste landfill facilities subject to the rule prepare an explosive gas monitoring plan (EGMP) on forms prescribed by the director. The director can require the preparation and submittal of a new or revised EGMP, including facilities that already have an approved EGMP. This is to ensure all EGMPs statewide are current and appropriately designed for the effective monitoring and managing explosive gas migration.
  • Language recognizing that the director may require previously excluded landfills to manage and remediate explosive gas migration towards occupied structures.
  • Requirements regarding the design, placement, and construction of explosive gas monitoring probes and alternative monitoring devices. The design of explosive gas probes includes the requirement that they be fully screened throughout the depth of waste placement. If there are multiple significant zones of saturation (SZSs), the director may require that multiple probes screened at each SZS be installed.
  • Language requiring explosive gas monitoring (probe installation and sampling) within 180 days of the discovery of new structures constructed within 1000 feet of the horizontal limits of solid waste placement.
  • Language regarding the explosive gas meters used for monitoring:
    • Detection limit (i.e., less than 1% methane by volume)
    • Calibration gas concentration to be between 1% and 5% methane by volume, or as specified by the manufacturer
    • Management of explosive gas alarms in structures
  • Provisions allowing the director to require the frequency of explosive gas monitoring

When this rule becomes effective, in accordance with Rule 3745-27-12(F), applicable landfills that are operating on the effective day of the rule must submit an EGMP concurrent with a request to alter an effective EGMP or at the same time as the ten-year update schedule. Solid waste landfill facilities that ceased operation prior to the effective date of this rule must submit an EGMP that complies with this rule no later than 270 days after the effective date of the revised rule or not later than 270 days after receipt of a notification from Ohio EPA that these rules apply to their facilities.

Published in October 2020 Focus on the Environment Newsletter

The Interstate Technology Regulatory Council (ITRC) has released the new Incremental Sampling Methodology (ISM-2) Update Document. As defined by ITRC, ISM is a structured composite sampling and processing protocol that reduces data variability and provides a reasonably unbiased estimate of the mean contaminant concentration in a volume of soil targeted for sampling. The web-based ISM-2 was developed to build on the original 2012 version (ISM-1) and to reflect advancements in technology and share case studies that provide insight into the potential applications, benefits, and challenges of the approach.

Published in August 2020 Focus on the Environment Newsletter

The Michigan Department of Environment, Great Lakes, and Energy (EGLE) recently promulgated state drinking water standards for seven per- and polyfluoroalkyl substances (PFAS).  Drinking water standards, also known as maximum contaminant levels (MCLs) are the maximum amount of a contaminant allowed in drinking water. When the amount of a contaminant in drinking water is higher than the MCL, the water supplier must take action such as treatment or follow-up testing. The new Michigan PFAS MCLs, shown on the below table, took effect on August 3, 2020.

Specific PFAS

CAS #

Drinking Water MCL Parts per Trillion (ppt)

Perfluorooctanoic acid (PFOA)

335-67-1

8

Perfluorooctanesulfonic acid (PFOS)

1763-23-1

16

Perfluorononanoic acid (PFNA)

375-95-1

6

Perfluorohexane sulfonic acid (PFHxS)

355-46-4

51

Perfluorohexanoic acid (PFHxA)

307-24-4

400,000

Perfluorobutane sulfonic acid (PFBS)

375-73-5

420

Hexafluoropropylene oxide dimer acid (HFPO-DA)

13252-13-6

370

The establishment of the new MCLs had an immediate effect on Michigan’s previously established generic groundwater cleanup criteria.  Generic cleanup criteria represent concentrations of a hazardous substance in different environmental media (groundwater, soil, and vapor) that allow appropriate risk management decisions regarding contaminated sites. As established under Part 201, Environmental Remediation, of the Natural Resources and Environmental Protection Act, 1994 PA 451, as amended [MCL 324.20120a(5)], state MCLs, once established, are also used as the basis of the generic cleanup criteria for groundwater used as drinking water.  Consequently, the new state drinking water standards of 0.008 µg/L (parts per billion) and 0.016 µg/L, respectively for PFOA and PFOS replaced the previously established residential and nonresidential drinking water cleanup criteria of 0.07 µg/L for the combined concentrations of PFOA and PFOS. The updated generic groundwater cleanup criteria for residential and non-residential groundwater were updated the same day the new MCLs went into effect.

There are currently no generic cleanup criteria for the other five PFAS compounds with recently established MCLs.  In other words, if you search the Michigan EGLE generic groundwater cleanup criteria table for any of the other five PFAS compounds (i.e., PFNA, PFHxS, PFHxA, PFBS, HFPO-DA), you won’t find them despite the fact that they now have MCLs. EGLE must go through the process set forth by statute and rule to establish generic cleanup criteria for the remaining five PFAS compounds. This is somewhat of a formality, however, as for all practical purposes, the MCLs will be considered generic cleanup standards until developed.

Published in August 2020 Focus on the Environment Newsletter

On December 2, 2020, the Environmental Protection Agency (EPA) will celebrate its 50th birthday. Nearly 50 years ago, on December 2, 1970, President Richard Nixon created EPA by executive order to consolidate in one agency a variety of federal research, monitoring, standard-setting, and enforcement activities to ensure environmental protection across the country.  Eight years prior, Rachel Carson, an inveterate birdwatcher published Silent Springs on the indiscriminate use of pesticides and the fear that without control fewer species of birds would be singing each spring.  Who can forget, our own Cuyahoga River catching fire in 1969?  The first Earth Day took place on April 22, 1970 in what was considered by some the start of the modern environmental movement.  Who knows what the next 50 years will bring for EPA and the environmental movement, but no one can argue that EPA has not been good for this country and the world. 

Published in the August 2020 Focus on the Environment Newsletter.

In our July 2020 newsletter, we introduced Ohio EPA’s pilot program on the use of virtual site visits (VSVs) for select categories of inspections.  Recently, I made the trip to a client’s facility and provided assistance conducting a VSV with Ohio EPA during a RCRA Post-Closure inspection.  Regardless of the type of VSV inspection, below are some helpful tips to prepare for and conduct the VSV.

  • Ohio EPA will contact the facility regarding their intent to perform a VSV and schedule a date/time for a trial run to test the audio and video equipment/software.  Ohio EPA uses the Microsoft Teams platform, so it is recommended you become familiar with its operation and test it ahead of the trial run.  During the trial run, the audio and video will be tested, however, there will not be a need to walk the facility.  Near the conclusion of the trial run, a mutually agreeable date/time for the actual VSV will be determined.  If not previously discussed, it is recommended that the facility ask the agency if there are specific areas of interest Ohio EPA was planning to cover during the VSV.
  • Following the trial test and prior to the VSV, it is recommended that the facility perform a mock VSV with other facility members observing remotely.  This will allow the person who is conducting the walk-through to develop an efficient travel path, identify any potential issues that need corrected, and ensure a strong audio/video signal throughout the walk.  If an area of the facility is encountered with a weak signal, you will have time to troubleshoot options for improving the signal.  At worst case, you will be able to provide Ohio EPA with a heads-up that certain portions of the VSV may lose audio and/or video.  A weak signal will freeze the video before the audio drops off.  If you find that the video freezes and remains frozen after passing through the area with the weak signal, manually turn off your camera feed (while remaining connected via audio) and then turn it back on to re-establish video.
  • At the start of the VSV, plan to spend a few minutes in an office area to re-iterate the agency’s areas of interest and prioritize certain items.  The VSV is typically scheduled for two hours and the agency expectation is to not run beyond this time to avoid scheduling conflicts with both the agency and facility.  If document review is part of the inspection, the agency will typically ask that certain documents are provided ahead of or after the VSV so as to not spend time searching or reviewing documents while live streaming. 
  • When conducting the VSV, it is recommended a group of at least two facility personnel perform the walk-over.  One person would be in charge of operating the video stream and would perform most of the talking.  The second person would lead the route and take notes.  The person operating the video feed may be somewhat distracted and not fully aware of their surroundings, therefore the second person also serves as a safety lookout.
  • There is typically a few second delay from saying something to when it is heard by others that are logged into the VSV.  Therefore, if two or more facility personnel are performing the walk-over and each is using their own device for audio, a few feet of distance should be maintained between them to avoid echo or difficulty hearing.  Only one person needs to operate a video feed, the other person on the walk-over should have only audio feed active.  Because Microsoft Teams allows use of an internet link for audio/video or a phone number for audio only, it is recommended that the facility person who is not leading the video stream use the phone number.  Often, the phone signal may be stronger than the internet link for audio/video so if the person who operates the video feed happens to completely lose signal, the other person can notify the agency of the temporary issue.  
  • Some devices have longer battery life than others.  It is recommended to have a full charge on the device that will run the video feed before the VSV begins and to also bring a backup battery pack.
  • Many facilities have proprietary operations.  Although the agency will typically provide copies of any screenshots they take during the VSV, it is recommended that the operator turn off the video feed or point the camera to the ground between locations.  Not only will this approach prevent potential for photographing proprietary operations, but it will also keep the VSV focused on the intended items, avoid straying from the planned walking path, and allow the facility personnel to be more alert on their surroundings when walking.
  • Many facilities are loud and may require hearing protection.  As such, it is recommended that ear buds (wireless or wired) be used for the audio interface rather than a speaker.  Although ear buds do not provide the same hearing protection as ear plugs, you may be able to convince your safety department to allow use of the ear buds in place of the ear plugs during the VSV.  Consideration of the time spent at a noisy area and the protection provided by the ear buds should be considered.  If additional hearing protection is unavoidable, the use of ear buds under muffs may be possible.  Do not hesitate to discuss this issue with Ohio EPA in the trial run call.  
  • Following the walk-over portion of the VSV, Ohio EPA will likely review their inspection checklist while the audio/video stream is still live.  If not, the facility personnel should request that it is reviewed prior to concluding the VSV.  By reviewing the checklist together, any potential misinterpretations or issues may be quickly clarified or addressed. 

The above tips should help for a smooth and productive VSV.  A follow up letter on the VSV will be provided by Ohio EPA, which will include the completed checklist, any screenshots taken, and outcome.  Ideally, this letter is provided within 30 days of the VSV.  If you don’t receive the letter within this timeframe, it is recommended to inquire on its status. 

Published in the August 2020 Focus on the Environment Newsletter.

Have you ever received an agency’s request for additional investigation and thought, “surely we’ve done this before?” You are not alone. Particularly on “lower priority” and long-running sites, involved parties can easily lose track of what has been done. Client, agency, and consulting staff turnover can make this even more likely. Cox-Colvin’s Data InspectorTM provides a solution to this problem, as demonstrated by recent projects

On a recent project, our client proposed a voluntary remedy to avoid a possible enforcement action that had been discussed for years. The regulatory personnel reviewing the proposal initially expressed concern that the proposed remedy was premature due to a lack of data on some exposure pathways. Our client’s representative had a feeling that the concerns had already been addressed and delivered boxes of historical documents to Cox-Colvin. Some of the reports dated back to the mid-1990s, well before the regulatory reviewers, and our client’s representatives, were involved with the project. After organizing and scanning the documents, we compiled laboratory data, GIS sampling locations, and reports into our Data InspectorTM data management system. A summary document was prepared and presented to the agency. Realizing how much investigation had already been completed, an occasionally tense dialogue became more conciliatory and the project is moving toward a mutually beneficial outcome. By importing the data and reports into Data InspectorTM our client can rest assured that they will not need to rely on that déjà vu feeling next time.

On another project, a historical industrial release migrated into the surrounding community. Through time, our client became increasingly suspicious that contaminant plumes from other sources had comingled with their release. Cox-Colvin was asked to review investigations conducted by neighboring industries that were in the public record. By compiling data from a multitude of investigations within and near the project area into a single database, a more refined conceptual site model was developed that indicated there were indeed multiple sources and responsible parties contributing to the contaminant plume. This approach had several benefits, including 1) cost savings in not needing to perform additional investigation, 2) avoiding the need to work out multiple access agreements to conduct sampling, 3) time savings in using already existing data, and 4) nearly 40 years of historical data that showed how conditions had changed and improved over time. Most importantly, the client was able to set realistic (while still protective) cleanup goals that avoid endless cleanups of unrelated plumes from off-site facilities.

Cox-Colvin prides itself on our decades-long client relationships. Our existing clients value our ability to identify and locate reports that were prepared for their predecessor’s predecessor. Whether the data is used to show that an area never had a release, to evaluate changes over time, or simply to prove that something was already investigated 30 years ago, having a single Data InspectorTM repository has been proven invaluable time and again.

On July 6, 2020, the Ohio Environmental Protection Agency (Ohio EPA) Division of Materials and Waste Management filed eight municipal solid waste (MSW) landfill rules with the Joint Committee on Agency Review.  The eight rules proposed for revision are:

  1. 3745-27-02 Permit to install
  2. 3745-27-05 Applicability and relation to other laws
  3. 3745-27-06 Sanitary landfill facility permit to install application
  4. 3745-27-07 Additional criteria for approval of sanitary landfill facility permit to install applications
  5. 3745-27-08 Sanitary landfill facility construction
  6. 3745-27-09 Sanitary landfill facility operating record
  7. 3745-27-11 Final closure of a sanitary landfill facility
  8. 3745-27-14 Post-closure care of sanitary landfill facilities

The public comment period will run until August 12, 2020. On that date, the Ohio EPA will hold a virtual public hearing on the rules. The link to the virtual hearing is at the Ohio EPA’s webex events site: https://ohioepa.webex.com/mw3300/mywebex/default.do?siteurl=ohioepa&service=6

Written comments can be submitted during the virtual public hearing or emailed to Michelle Mountjoy at michelle.mountjoy@epa.ohio.gov.

The Interstate Technology and Regulatory Council (ITRC) has released an online Risk Communication Toolkit.  The EPA defines “risk communication” as the process of informing people about potential hazards to their person, property, or community. It is a science-based approach for communicating effectively in situations of high stress, high concern, or controversy. Now more than ever, risk communication is front and center in our everyday lives and the timing of this document could not be better.


What Do the New Generator Improvement Rules Mean for TSDFs?

  • By: Nick
  • Posted: 11/3/20

Most RCRA-permitted TSDFs are also large quantity generators (LQGs).  Prior to the generator improvement rules, some hazardous waste management requirements were consistent between LQGs and RCRA-permitted TSDFs.  Therefore, it was possible for a facility to follow the provisions within their RCRA permit application and comply with those LQG requirements that were consistent.  Since the generator… Read More »

RCRA Corrective Action 2030 Goals and Outcome of 2020 Goals Announced

  • By: George
  • On September 1, 2020, US EPA Office of Land and Emergency Management (OLEM) Assistant Administrator Peter Wright, announced the 2030 vision, mission, and goals for the Resource Conservation and Recovery Act (RCRA) Corrective Action hazardous waste facility cleanup program.  The announcement of the RCRA cleanup goals for the next 10 years was provided as part… Read More »

New Ohio EPA Explosive Gas Monitoring Rule Promulgated

  • By: Steve
  • On October 21, 2020, the Division of Materials and Waste Management of the Ohio Environmental Protection Agency (Ohio EPA) announced that the proposed explosive gas rule,  for municipal solid waste landfills was filed with the Joint Committee on Agency Rule Review (JCARR).  Landfill gas is a natural by-product of the anaerobic decomposition of organic waste… Read More »

Updated ITRC Incremental Sampling Methodology (ISM) Guidance Released

  • By: George
  • The Interstate Technology Regulatory Council (ITRC) has released the new Incremental Sampling Methodology (ISM-2) Update Document. As defined by ITRC, ISM is a structured composite sampling and processing protocol that reduces data variability and provides a reasonably unbiased estimate of the mean contaminant concentration in a volume of soil targeted for sampling. The web-based ISM-2 was developed to build… Read More »

Michigan PFAS Groundwater Cleanup Criteria Revised to Reflect Newly Added State MCLs

Published in August 2020 Focus on the Environment Newsletter The Michigan Department of Environment, Great Lakes, and Energy (EGLE) recently promulgated state drinking water standards for seven per- and polyfluoroalkyl substances (PFAS).  Drinking water standards, also known as maximum contaminant levels (MCLs) are the maximum amount of a contaminant allowed in drinking water. When the… Read More »

EPA Turns 50 This Year

  • By: George
  • Published in August 2020 Focus on the Environment Newsletter On December 2, 2020, the Environmental Protection Agency (EPA) will celebrate its 50th birthday. Nearly 50 years ago, on December 2, 1970, President Richard Nixon created EPA by executive order to consolidate in one agency a variety of federal research, monitoring, standard-setting, and enforcement activities to… Read More »

Helpful Tips Based on Participation in an Ohio EPA Virtual Site Visit

  • By: Nick
  • Posted: 08/25/20

Published in the August 2020 Focus on the Environment Newsletter. In our July 2020 newsletter, we introduced Ohio EPA’s pilot program on the use of virtual site visits (VSVs) for select categories of inspections.  Recently, I made the trip to a client’s facility and provided assistance conducting a VSV with Ohio EPA during a RCRA… Read More »

DATA déjà vu?

  • By: Nate
  • Posted: 08/24/20

Published in the August 2020 Focus on the Environment Newsletter. Have you ever received an agency’s request for additional investigation and thought, “surely we’ve done this before?” You are not alone. Particularly on “lower priority” and long-running sites, involved parties can easily lose track of what has been done. Client, agency, and consulting staff turnover… Read More »

Ohio EPA Proposes to Revise Eight Municipal Solid Waste Rules

On July 6, 2020, the Ohio Environmental Protection Agency (Ohio EPA) Division of Materials and Waste Management filed eight municipal solid waste (MSW) landfill rules with the Joint Committee on Agency Review.  The eight rules proposed for revision are: 3745-27-02 Permit to install 3745-27-05 Applicability and relation to other laws 3745-27-06 Sanitary landfill facility permit… Read More »

Timing is Everything – ITRC Releases Risk Communication Toolkit

  • By: George
  • The Interstate Technology and Regulatory Council (ITRC) has released an online Risk Communication Toolkit.  The EPA defines “risk communication” as the process of informing people about potential hazards to their person, property, or community. It is a science-based approach for communicating effectively in situations of high stress, high concern, or controversy. Now more than ever,… Read More »

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