EPA recently revised the national emission standard for hazardous air pollutants for certain coating manufacturers. The result is new performance tests and controls for existing affected sources adding metal hazardous air...more
Since the November presidential election, most trade journals have expressed the same or similar headlines: “The Joe Biden/Kamala Harris administration will elevate enforcement for violation of environmental rules and...more
EPA recently published a final rule restricting the manufacture, processing, and import of methylene chloride in the United States for consumer paint and coating removal. The rulemaking is a result of risk assessments...more
The 2016 amendments to the Toxic Substances Control Act (TSCA) required EPA to designate chemical substances on the TSCA Chemical Substance Inventory as either “active” or “inactive” in U.S. commerce. To accomplish that, EPA...more
New Source Review (“NSR”) remains a focus of enforcement for EPA. Between last year and now, EPA finalized eight settlements with manufacturers and one with a utility, asserting NSR violations for allegedly not obtaining a...more
5/3/2018
/ Clean Air Act ,
Clean Water Act ,
Discharge of Pollutants ,
Environmental Protection Agency (EPA) ,
Groundwater ,
Groundwater Management Plan ,
Landfills ,
Manufacturers ,
Methane ,
Mining ,
NPDES ,
POTWs
Since 1995, EPA has followed a policy that any air emissions source that emits one or more hazardous air pollutants (“HAPs”) above major source emissions thresholds is always considered a major source of HAPs. This is so even...more
2/14/2018
/ Air Pollution ,
Carbon Emissions ,
Clean Air Act ,
Deregulation ,
Environmental Policies ,
Environmental Protection Agency (EPA) ,
Hazardous Substances ,
Manufacturers ,
Pollution Control ,
Regulatory Reform ,
Title V
EPA has begun promulgating regulations to implement the Frank R. Lautenberg Chemical Safety for the 21st Century Act of 2016 (Act), legislation that makes significant changes to the Toxic Substance Control Act (TSCA). EPA...more
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
7/10/2017
/ CERCLA ,
Clean Air Act ,
Corporate Financing ,
Emergency Response ,
Enforcement Actions ,
Environmental Protection Agency (EPA) ,
EPCRA ,
Food Manufacturers ,
Manufacturers ,
Reporting Requirements ,
Risk Management
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
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
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
CONGRESS FINDS THE FORMULA TO REFORM CHEMICAL REGULATION -
The Toxic Substance Control Act (TSCA) is the primary federal law by which the manufacture, import and use of chemical substances are regulated in the United...more
7/20/2016
/ Administrative Procedure Act ,
Air Pollution ,
Chemical Safety for the 21st Century Act ,
Clean Air Act ,
Clean Water Act ,
Comment Period ,
Construction Industry ,
Environmental Protection Agency (EPA) ,
EPCRA ,
Final Action ,
Final Rules ,
Hawkes Co v United States Army Corps of Engineers ,
Jurisdictional Determination (JD) ,
Land-Use Permits ,
Manufacturers ,
MATS ,
Mining ,
Occupational Exposure ,
OSHA ,
Power Plants ,
Proposed Amendments ,
Sackett ,
SCOTUS ,
Shipbuilding ,
Silica ,
Toxic Chemicals ,
Toxic Exposure ,
Toxic Substances Control Act (TSCA) ,
US Army Corps of Engineers ,
Waters of the United States ,
Wetlands
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
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
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
Effective July 27, 2015, EPA amended key components of the National Emission Standard for Hazardous Air Pollutants (NESHAP) for new and existing portland cement kilns. The changes, in part, were necessary to comply with a...more
In this Issue:
- EPA Issues SIP Call to Eliminate SSM Defense
- EPA and Corps Define “Waters of The United States”
- Frequent Questions: EPCRA 313
- Generators Need to be Vigilant About TCLP Sampling...more
6/15/2015
/ CERCLA ,
Clean Air Act ,
Clean Water Act ,
Environmental Protection Agency (EPA) ,
Final Rules ,
Hazardous Waste ,
Manufacturers ,
NAAQS ,
Ozone ,
Proposed Regulation ,
RCRA ,
Reporting Requirements ,
Sierra Club ,
Toxic Chemicals ,
US Army Corps of Engineers ,
Waste Disposal
In this Issue:
- Virginia’s Draft State Water Resources Plan
- Frequent Questions: Form R Part II
- Manufacturers and Temporary Workers
- Farms and the Water Resources Reform and Development Act...more
As the July 1 deadline for filing the Form R for your facility approaches, these additional Frequent Questions may assist your preparation.
Question: For purposes of Section 313 reporting, is ammonium nitrate in a...more