Operating conditions during periods of startup, shutdown, and malfunction (SSM) are not normal and often result in unrepresentative emissions that exceed permitted limitations.
Originally published in The Natural Gas &...more
On October 6, 2014, EPA issued a final rule mandating the use of the 2013 standard, ASTM E1527-13, for conducting Phase I Environmental Site Assessments for satisfaction of All Appropriate Inquiries ("AAI") under CERCLA. . ...more
Evaluating environmental risks associated with real estate transactions is a standard, and often standardized, practice for sophisticated real estate practitioners. However, in light of several recent developments - the...more