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Increase in Chemical Security Vulnerability Assessments Likely Under New DHS Standards

The Department of Homeland Security (DHS) Chemical Facility Anti-Terrorism Standards (CFATS) program identifies and regulates high-risk chemical facilities to ensure that security measures are in place to reduce the risk of...more

Refrigeration Systems Targeted: Risk Management Plans and Release Reporting

Companies operating ammonia refrigeration systems are easy targets for EPA under a number of environmental programs. Recent history suggests release reporting under Section 112(r) of the Clean Air Act (CAA) and under the...more

Environmental Notes - July 2017

On June 1, 2017, President Trump announced that the United States will withdraw from the Paris climate agreement (“Paris Agreement”). The Paris Agreement was signed by 195 countries in December of 2015. The goal of the...more

Environmental Notes - May 2017

The Clean Power Plan (“CPP”), and its companion new source review rule, is the Obama Administration’s signature regulation on reducing greenhouse gas emissions from power plants. Among other things, it requires states to put...more

EPA Issues New Contaminated Sediments Guidance

Earlier this year, EPA released revised guidance for remediation of contaminated sediments at sites being addressed by EPA under CERCLA (the “New Sediment Guidance”). The guidance identifies six key clarifications to EPA...more

EPA Proposes Further Delay of Revised RMP Rule

As we reported in the April issue of Environmental Notes, the Trump administration issued a final rule on March 16, 2017 that delayed the effective date of regulations making significant changes to requirements applicable to...more

EPA Proposes Use Restrictions on TCE

EPA is proposing significant use restrictions and recordkeeping requirements on those facilities using or distributing trichloroethylene (TCE), a widely used industrial solvent. The agency proposed two rules in a month’s time...more

EPA Issues Formaldehyde Emission Standards for Composite Wood Products

Title VI of the Toxic Substances Control Act authorizes EPA to reduce formaldehyde exposures from composite wood products, and EPA recently did so by promulgating its long-anticipated Formaldehyde Emission Standards for...more

Environmental Notes - February 2017

President Trump has wasted no time in acting on his environmental agenda. On January 24, his second working day in office, the President signed two Executive Orders giving the green light to construction of the Keystone and...more

Environmental Notes - December 2016

The Virginia Department of Environmental Quality (“DEQ”) has clarified its approach to issuing “no further action” letters (“NFAs”) for sites with both petroleum and non-petroleum contamination. This clarified approach will...more

EPCRA Update: Nonylphenol Ethoxylates Proposed as 313 Toxic Chemical Categor

EPA is proposing to add Nonylphenol Ethoxylates (NPEs) to the list of Toxic Chemicals under Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA). Comments on the proposal must be received on or...more

12/15/2016  /  EPA , EPCRA , Manufacturers , Toxic Chemicals

EPA Publishes Revised Pesticide Application General Permit

EPA has promulgated a final rule revising the Pesticide General Permit (the “2016 PGP”). The 2016 PGP is applicable only in four states (Idaho, Massachusetts, New Hampshire, and New Mexico) and at federal facilities, but the...more

12/15/2016  /  EPA , Final Rules , General Permit , NAICS , Pesticides

Environmental Notes - November 2016

EPA has revised its procedures for making certain changes to its “Test Methods for Evaluating Solid Waste, Physical/Chemical Methods,” also known as SW-846. The test method and its compendium of guidance documents provide...more

EPA Elects Not to Publicize Changes to S-846 Guidance

EPA has revised its procedures for making certain changes to its “Test Methods for Evaluating Solid Waste, Physical/Chemical Methods,” also known as SW-846. The test method and its compendium of guidance documents provide...more

11/10/2016  /  EPA , RCRA , Solid Waste

EPCRA Section 313 Reporting: Frequent Questions

This is the second installment of frequently asked questions regarding Toxic Release Inventory (TRI) reporting under Section 313 of the Emergency Planning with Community Right-to-Know Act (EPCRA). As noted in our first...more

EPCRA 313 Reporting – FAQs

The Emergency Planning and Community Right-to-know Act (EPCRA) requires Form R reports to be filed with EPA each July 1 for each listed “toxic chemical” a facility manufactures or processes in excess of 25,000 lbs., or...more

Environmental Notes - May 2016

The news has been full of stories and articles concerning Coal Combustion Residuals (CCR), also referred to as coal ash. CCR became a hot topic in 2008 when a coal ash pond at a utility plant in Tennessee spilled more than 5...more

Hazardous Waste: New Corrosivity Test Denied, But the Fight is Not Over

EPA has tentatively denied a petition to expand the test for the hazardous waste characteristic of corrosivity to cover more wastes. In so doing, however, EPA left the door open to reconsider the decision based on public...more

Environmental Notes - April 2016

EPA’s Office of Enforcement and Compliance Assurance recently proposed changes to its National Program Manager (NMP) Guidance that, in part, would revise EPA’s National Enforcement Initiatives (“NEIs”) for federal fiscal...more

Environmental Notes - January 2016

Dominion Virginia Power (Dominion) operates a coalfired power plant in Chesapeake, Virginia. It maintains permits for its operations, including a Virginia solid waste management permit and a Virginia Pollutant Discharge...more

OSHA Extends Process Safety Management Standard Compliance Date for Bulk Chemical Distributors

OSHA has come full circle…almost. In a December, 2015 revised interim enforcement memorandum, the agency indicated it will not enforce the Process Safety Management (PSM) Standard for “highly hazardous chemicals” (HHC)...more

North Carolina DENR is Now DEQ; New Audit Privilege and Limited Immunity Enacted

The Regulatory Reform Act of 2015 (the “Act”), passed by the North Carolina General Assembly in September and signed by Governor McCrory on October 22, made a number of significant changes to the state’s environmental laws. ...more

Can Air Emissions Result in CERCLA Liability?

Liability under the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) results from “releases” of hazardous substances. The term “release” is usually used in the context of something spilled or...more

EPA Issues Final MACT for Brick and Structural Clay Products and Clay Ceramics Manufacturing

Section 112(d) of the Clean Air Act requires EPA to set emission standards for hazardous air pollutants emitted by sources in certain specified source categories and subcategories. EPA recently published final maximum...more

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