Todd Fracassi

Todd Fracassi

Pepper Hamilton LLP

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Expect Increased Environmental Regulatory Scrutiny in the Wake of the Flint Water Crisis

The regulated community should plan for an increased level of agency oversight, inspection and enforcement and increased public involvement. Although there has been much finger pointing as to which party or parties may...more

3/28/2016 - Contamination Drinking Water Enforcement Actions Environmental Liability Environmental Site Assessment Inspections Manufacturers Permits Water Supplies

When May a Previously Approved Site Closure Not Provide Closure - Reopening Vapor Intrusion Sites

We can expect the trend seen in Massachusetts and some other states of reevaluating and reopening previously closed sites to address the vapor intrusion pathway to grow. Massachusetts is the latest state to reevaluate...more

3/22/2016 - Contaminated Properties Department of Environmental Protection EPA Toxic Exposure Vapor Intrusion Vapor Intrusion Guidance

What Does the Health Care Industry Do Now When Disposing "Hazardous Waste" Pharmaceuticals?

Potentially affected health care facilities should evaluate current management practices, evaluate best management practices for regulated facilities, and develop a plan to prepare for and manage a regulatory inspection....more

3/1/2016 - Clean Water Act Environmental Liability EPA Hazardous Waste Healthcare Facilities Pharmaceutical Industry Pharmacies Prescription Drugs

EPA's NPDES Electronic Reporting Rule: A Step Toward A Next Generation Compliance Strategy

The final rule strives to take advantage of information technology, allowing resources to be used more efficiently and effectively, and giving the EPA, states and the public better access to key data. Implementation will...more

9/29/2015 - Biosolids Clean Water Act Compliance EPA Federal Register Final Rules Information Technology NPDES Reporting Requirements Storm Sewers

Six Things the Private Sector Should Know About EPA's Final Vapor Intrusion Guidance

The cumulative impact of the EPA guidance is to require the generation of more data, which means more sampling and analysis, more frequent and stringent remediation, and potentially higher remediation costs. At long...more

8/24/2015 - Compliance Department of Defense (DOD) EPA Final Guidance Groundwater OSHA Preemption Sewer Systems Underground Storage Tanks Utility Sector Vapor Intrusion Volatile Organic Compounds (VOC)

Every Picture Tells a Story... Convincing Regulators and Courts of Your Client’s Position

When facing the potential of spending large sums of money on remediation, administrative enforcement, or litigation due to a chemical release to the environment, you must be able to take the collected information and data and...more

11/25/2014 - ASTM Contaminated Properties Data Collection Enforcement Actions Environmental Impact Report (EIR) Environmental Liability EPA Popular Remediation US Army Corps of Engineers

Fourth Circuit Brownfields Decision Stops Short Of Worst-Case Outcome

In a closely watched Superfund case decided April 4, 2013, the Fourth Circuit Court of Appeals interpreted the scope of landowner liability protections Congress put in place in 2002 to "promote the cleanup and reuse of...more

4/17/2013 - Bona Fide Purchaser Brownfield Properties CERCLA Superfund

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