What Happens To Chemicals in Soil?

Dr. James Dragun will once again teach his soil chemistry class at the 22nd Annual International Conference on Soil, Water, Energy, and Air. This is the 11th year Dr. Dragun has been asked to teach at this conference.

The conference will be held March 19-22, 2012, at the Mission Valley Marriott in San Diego, California.

For more information about the conference, click here http://tinyurl.com/79z9d6e.

For more information about the Dragun Corporation go to www.dragun.com


Beware the N Rays!

In 1903, French Physicist, René Prosper Blondlot (1849-1930) claimed he discovered a new type of radiation.  He called the new radiation, the N-ray, named after Nancy, the name of the town and the university where he lived and worked.  And Blondlot had his followers; dozens of other scientists who “confirmed” the existence of N-rays in their own laboratories (more than 50 technical papers were written on the subject).

Alas, N-rays don’t exist.

So, how could so many scientists be wrong?  They were human and deceived themselves into thinking they were seeing something that just wasn’t so. They saw what they wanted to see with their instruments, not what was actually there.

Blondlot was not a charlatan; in fact, according to his Facebook page (yes even deceased scientists have Facebook pages), “He made the first measurement of the speed of radio waves, by measuring the wavelength using Lecher lines.”

Scientists, even good scientists, can be deceived. Focusing on the fundamentals of good science is as important today as it was in the 1800s.  Whether we are trying to assess responsibility and an applicable cleanup approach for TCE in groundwater or assessing radiation – there is no substitute for good science.

Amended Reporting Requirements under TSCA Approaching Fast!

As you may be aware, 2012 is a Toxic Substances Control Act (TSCA) chemical reporting year.  This means if you manufacture (import), process, distribute, and/or use chemical substances for commercial purposes, you may be subject to TSCA reporting.  Even your chemical manufacturing byproducts may be subject to reporting requirements.

What makes this reporting cycle more noteworthy is that in August 2011, the Environmental Protection Agency (EPA) issued amendments to the TSCA Inventory Update Reporting (IUR) rule. The IUR is now the Chemical Data Reporting (CDR) rule.  Among other changes, this new rule revises how to determine if a chemical meets a reporting threshold and institutes gradual reductions in reporting thresholds over the next two reporting cycles.  A link to the new rule is provided below.

In addition to the reduced reporting threshold for certain chemicals, there have been other changes including a modification in the reporting frequency from every five years to every four years.

CDR submissions must be completed electronically through the EPA’s e-CDRweb reporting tool and Data Exchange (CDX) system between February 1, 2012 and June 30, 2012.  CDX accounts can take a couple of weeks to set up, and the reporting process can be very time consuming, so it would be wise to start early.

If you have any questions regarding the TSCA reporting requirements or require assistance with an environmental permit or plan, contact Matthew Schroeder (mschroeder@dragun.com) at 248-932-0228.


The New Ontario Environmental Discharge Permitting Process

By now you know that on October 31, 2011, the Ontario Ministry of Environment (MOE) changed the environmental discharge permitting process.  The original Certificate of Approvals (CofA) process is now the Environmental Activity & Sector Registry (EASR) and Environmental Compliance Approval (ECA).

The details of this new regulation can be found at the MOE’s website (bottom of page); but here are a few common questions and answers as it relates to the new permitting process.

How does this new permitting process differ from the old CofA process?  There are several changes, you might want to go to the MOE’s website to become more familiar with the changes (see link below), but one of the significant changes to the process is that the old CofA required multiple approvals for individual processes and equipment.  Now, depending on the process and activities, you can apply for a single “all inclusive” approval.

Who qualifies for the EASR.  The EASR allows you to register certain activities with the MOE, rather than apply for an approval. The registry is available for common systems and processes, which a preset rules of operation can be applied.  The EASR has limited applicability; it is currently available for heating systems, standby power systems, and automotive refinishing.  If you don’t qualify for an EASR, then you would apply for an ECA using the new “smart application form.”

Do I even need a discharge permit?  According to the MOE, “If a business’s activities impact the natural environment, that business needs an approval from the Ministry of the Environment (MOE) to operate legally in Ontario.”  The basic rule is if you currently have or are going to discharge a “pollutant” to the environment, you need a permit. 

What about me, I have an existing CofA, do I need to reapply? No. If you have an existing Certificate of Approval (CofA prior to October 31, 2011), it will continue to apply and will be treated as an ECA.  You need to do nothing at this time.  However, if you plan to add to or modify a process for which you currently have a CofA, you may have to reapply.  Other activities that may require changes from CofA to ECA include changes in ownership of a facility.

Is there still a Comprehensive Certificate of Approval?  What used to be a Comprehensive CofA is now an ECA with Limited Operational Flexibility. 

Is there anything I need to do? This much has not changed; if you are going to have a discharge to the environment (air, water, or noise), you need a permit.  The name has changed, the process is (hopefully) better, but you still need a permit.  All ECA permits must meet the requirements in O.Reg 255/11 of the Environmental Protection Act.

To read more about the ECA process, go to the Ontario Ministry of Environment’s website (below).  If you need assistance with an environmental permit, contact Christopher Pare’ (cpare@dragun.com) at 519-979-7300.


An Environmental “How To” Seminar

How to avoid… Excessive Judgment costs, Excessive Settlement costs and Excessive Remediation costs!

There is no cost to attend, but space is limited.  If you would like to attend, please make your reservations with Agnes (amytych@dragun.com) by February 10, 2012.  The seminar will be held in our Farmington Hills, Michigan office.

For more information about this seminar, visit our website http://www.dragun.com/us/press/news/seminars/feb2012/index.htm