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CERCLA Release Reporting Exemption for Federally Permitted Releases

Seasoned environmental professionals are well-acquainted with the typical hazardous substance release reporting analysis under CERCLA; where a reportable quantity of a hazardous substance is released into the environment...more

Closure Requirements for Large Quantity Generators under the Hazardous Waste Generator Improvements Rule

Large quantity generators (LQGs) of hazardous waste who accumulate hazardous waste for no more than 90 days know proper adherence to unit-specific and facility-wide closure requirements is an essential condition for exemption...more

Emergency Preparedness and Prevention under the Hazardous Waste Generator Improvements Rule

Generators of hazardous waste have long understood the importance of emergency preparedness and prevention to regulatory compliance and facility safety.  Contingency planning and coordination with emergency service providers...more

A New Pill to Swallow: EPA’s Hazardous Waste Pharmaceuticals Rule

Certain pharmaceuticals are regulated under the Resource Conservation and Recovery Act (RCRA) as “hazardous waste” when they are discarded.  EPA recently finalized new management standards for hazardous waste pharmaceuticals...more

Environmental Notes - October 2018

EPA has announced a new compliance policy that some will view as providing welcome relief to industry and others may view as providing unwarranted concessions. The subject line of the EPA memo announcing the new policy is...more

EPA Publishes Guidance for State CCR Permitting Programs

In April, 2015, EPA published in the Federal Register a final rule regulating the management and disposal of coal combustion residuals (CCR), commonly known as coal ash, from coal-fired power plants. Among other things, the...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

Environmental Notes - October 2015

In a significant setback for the Obama Administration, the U.S. Court of Appeals for the Sixth Circuit has temporarily blocked implementation of the Clean Water Rule issued jointly by EPA and the U.S. Army Corps of Engineers...more

Environmental Notes - June 2015

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

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