Regulatory Compliance and Policy Analysis

 

Representative Projects









 

Regulatory Compliance

 

Regulatory Compliance

 

Analysis of Criteria for Listing Chemicals under SARA Section 302A, Washington, DC

Provided management assistance to US EPA on a number of projects involving decisionmaking on criteria for listing chemicals as extremely hazardous substances under SARA Section 302A. The project also involved developing threshold planning quantities for extremely hazardous substances, developing exposure guidelines for emergency response planning, listing and de-listing chemicals under various provisions of Title III and identifying information sources on toxic chemicals listed under SARA Section 313. *top

Guidance Document for Interpreting PCB Cleanup Levels at Superfund Sites, Washington, DC

Project involved integrating the Toxic Substances Control Act policy for cleanup of PCB spills with the Office of Research and Development's (ORD) recommended levels for PCB cleanup under Superfund. Prepared a report providing background information on two advisory levels, their differences and consistencies. The report also discussed the relationship of the TSCA policy to Superfund and provided guidance on how to interpret the ORD advisory levels for use at specific Superfund sites. *top

Training Program in RCRA and CERCLA Cleanup Processes, Ohio

For the Department of Energy, designed and conducted a training program for facility personnel addressing CERCLA and RCRA cleanup processes in order to provide a framework for strategic environmental planning and ensure legally sufficient cleanup. Reviewed facility EMS documents as well as Superfund and RCRA assessments and other guidance documents. Through the training course, provided a thorough understanding of underlying Superfund requirements, discussed statutory definitions, provided overviews of removal actions and risk assessments, and reviewed document control procedures and methods of gap analysis and integration of cleanup processes. *top

Compliance Audits, Training and Planning for the Port of Portland, Oregon

Provided compliance audits for various facilities that assessed compliance with all major federal and state regulations. Based on auditor findings, identified facility noncompliances and provided advice regarding activities required to correct noncompliances. Assisted with the planning and development of program components of a Portwide Environmental Compliance Auditing Program. Provided advice on environmental issues related to the Port. Developed and provided training to Port managers and staff on a variety of environmental issues including regulations, EMSs, procedures and compliance issues. *top

Litigation Support for Spill Prevention, Control, and Countermeasure (SPCC) Planning, Northwest US

Providing litigation support for a large civil lawsuit in the US. The project includes providing expert witness assistance on issues regarding fuel SPCC planning and implementation at remote facilities in the Northwest. *top

 

Policy Analysis

 

Assessment of Coal Gasification Plant on the National Priorities List, California

Provided management assistance on assessments for an obsolete coal gasification plant on the National Priorities List. The project involved an analysis of the wastes involved, monitoring to determine the effects on groundwater and risk communication activities regarding the cleanup. A case study was developed for analysis of the success of the risk communication techniques involved. *top

Regulatory Analysis of Federal, State and Local Lead Standards, California

Prepared an in-depth regulatory analysis of federal, state and local lead standards and applicability to specific job tasks. Assessed job site chemical, physical and biological hazards and developed a site-specific work plan that included a waste management/waste minimization plan, safety and health plan and a stand-alone emergency response plan. Developed and presented half-day training sessions for site supervisors and site workers on the California lead standard, the site-specific work plan, safety and health plan and an emergency response plan. *top

Support for US EPA Move to Electronic Reporting, Washington, DC

In support of the Cross-Media Electronic Reporting and Record-Keeping Rule (CROMERRR) conducted a systematic review of EPA information reporting and recording-keeping requirements in all of US EPA's major programs including Air, Water, Toxics, Hazardous Waste and Superfund. Within a six-week time span, reviewed and analyzed extensive documentation including all 40 CFR environmental regulations to identify provisions that affected CROMERRR. Presented a range of alternatives for consideration and analysis by US EPA regarding amendments of regulations, in all US EPA programs, to achieve electronic reporting. *top

Legal and Policy Analysis on Acid Rain, Washington, DC

An EI team member staffed a study requested by the Senate Committee on Environment and Public Works and the House Committee on Energy and Commerce. The study focused on the causes of acid rain and the long-range transport of air pollutants and included potential pollution control strategies. Conducted legal and policy analyses and explained to Congressional staff the scientific evidence concerning acid rain and the associated policy/legal implications. Analyzed and drafted legislation for Congressional staff designed to protect ecosystems and biodiversity from the adverse effects of acid rain. Prepared written testimony and reports for client committees. *top

Analysis of RCRA Hazardous Wastes Containing PCBs, Washington, DC

Provided project management assistance to US EPA's Office of Solid Waste on a project designed to determine the types and quantities of RCRA hazardous wastes containing PCBs being land disposed. This project involved characterization of the wastes, identification of their sources and determination of current waste management practices. *top

Financial and Economic Impacts of RCRA Regulations on Small Quantity Generators, Washington, DC

Analyzed the financial and economic impacts of RCRA regulations on small quantity generators. The analysis included characterization of waste streams produced by small quantity generators including the physical and chemical characteristics of the waste and the amounts produced. *top

Regulatory Impact Analysis for PCB Regulation, Washington, DC

Analyzed a proposed rule requiring notification and manifesting by processors and disposers of PCBs under TSCA. The project included the determination of costs and benefits to industry, the government and society associated with the proposed regulations. The analysis required an assessment of the PCB processing and disposal industry including the facilities involved and the amounts of waste generated. *top

Development of Groundwater Integration Strategy, Washington, DC

Assisted US EPA's Office of Solid Waste in developing a groundwater integration strategy. Reviewed guidance, regulations and the statutory language of the Minimum Technology Requirements, Location Guidance, Corrective Action/Groundwater Monitoring and Land Disposal Restrictions. The project was designed to ensure that the four programs worked together in an efficacious manner to protect human health and the environment. *top

Chemical Use Analysis for Formaldehyde in Wood Products and Textiles, Washington, DC

Conducted a chemical use analysis for formaldehyde in wood products and textiles for US EPA's Office of Toxic Substances. The project involved a marketing analysis and survey of relevant documents. *top

Analysis of Asbestos Hazard and Emergency Response Act for Removal of Asbestos-Containing Material, Washington, DC

Provided management assistance to the Office of Toxic Substances on a study to determine the extent to which the unavailability of liability insurance for schools and asbestos abatement professionals inhibited removal of asbestos-containing material from schools as required under AHERA. The study included interviews with representatives of different groups involved in asbestos abatement in schools including local education authorities funded under the Asbestos School Hazard Abatement Act, asbestos abatement contractors and consultants, financial assurance providers, and state agencies. The study also included a survey of those potentially affected by AHERA. *top

Regulatory Impact Analysis for Regulation of the Release of Genetically Engineered Microorganisms, Washington, DC

Developed a regulatory impact analysis for the rule regulating the release of genetically engineered microorganisms. The project involved a survey of biotechnology companies potentially subject to TSCA and the assessment of costs and benefits to industry, the government and society associated with the proposed regulations. The project required a detailed understanding of the policies of the US EPA and other governmental agencies with regards to the regulation of biotechnology products. *top

Evaluation of Toxics Release Inventory Reporting Requirements, Washington, DC

Assisted in developing Toxic Release Inventory (TRI) rulemaking. Responsibilities included analyzing and evaluating technical comments regarding industry's reporting issues and concerns associated with TRI reporting requirements. Issues ranged from measuring chemical content in waste streams to fugitive emissions from loose valves in piping systems. Project required an understanding of waste volumes, toxicity and mobility. Synthesized both public and private sector comments on proposed changes to reporting requirements. *top

Underground Storage Tank Characterization, Washington, DC

Provided technical information to US EPA regarding the identification and characterization of the hazardous components of gasoline and other products stored in underground tanks. Provided advice on the potential for the tanks to leak and the toxicity of the hazardous substances. Also assisted in analyzing the fate and transport of hazardous substances in groundwater. *top

Biological Opinion and Systems Operation Review, Washington

On behalf of the Confederated Tribes of the Colville Reservation, prepared comments for submittal to the Bureau of Reclamation regarding the Tribes' comments and concerns with a biological opinion/systems operation review of proposed changes to operations at Grand Coulee Dam. The proposed changes involved altering the drawdown amount and schedule for the reservoir (Lake Roosevelt) behind the dam. Analyzed impacts on tribal fisheries and contaminated sediments in the lake and investigated the effects on air quality during drawdown when contaminated bank sediments are exposed to sun and wind. Coordinated comments of various tribal members, consultants and lawyers. *top

 

 

 

 

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