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
The obligation of manufacturing facilities to report releases of hazardous substances to local, state, or federal authorities is a complex regulatory subject. Multiple variables may impact whether a facility with a release to...more
In 2016, EPA published the long-anticipated Hazardous Waste Generator Improvement Rule (HWGIR) updating requirements for generators of hazardous waste. The HWGIR also clarifies EPA polices governing accumulation of hazardous...more
A case currently pending before the United States Supreme Court may significantly impact legal rights of potentially responsible parties (PRPs) involved in the cleanup of Superfund Sites. The case was brought in Montana State...more
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
7/10/2017
/ CERCLA ,
Clean Air Act ,
Energy Policy ,
Environmental Protection Agency (EPA) ,
EPCRA ,
Landfills ,
Methane ,
Paris Agreement ,
Pesticides ,
Regulatory Agenda ,
Regulatory Burden ,
Superfund ,
Trump Administration
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
12/15/2016
/ CERCLA ,
Common Stock ,
Contaminated Properties ,
Environmental Protection Agency (EPA) ,
EPCRA ,
General Permit ,
NESHAP ,
New Guidance ,
Pesticides ,
Remediation ,
Solar Energy ,
Superfund ,
Underground Storage Tanks
A recent CERCLA settlement provides an unusual method for reimbursing response costs incurred by EPA at a Superfund site. Under a proposed Consent Decree concerning the Yavapai Penta Superfund Site in Prescott, Arizona,...more
The Rodale Manufacturing facility in Emmaus, Pennsylvania was added to the National Priorities List in 1991 after more than 50 years of electrical component manufacturing. Operations at the facility included electroplating,...more
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
5/20/2016
/ Air Pollution ,
Clean Air Act ,
Coal Ash ,
Consent Decrees ,
Deepwater Horizon ,
Department of Environmental Quality ,
Department of Justice (DOJ) ,
Department of Labor (DOL) ,
Environmental Crimes ,
Environmental Protection Agency (EPA) ,
EPCRA ,
Groundwater ,
Hazardous Communication Standard ,
Hazardous Waste ,
Individual Accountability ,
OSHA ,
RCRA ,
Safety Data Sheets ,
Sierra Club ,
Solid Waste ,
SSM Periods ,
Superfund ,
Toxic Chemicals ,
Training Requirements ,
Utilities Sector ,
Workplace Safety ,
Yates Memorandum
U.S. Supreme Court to Decide Whether Jurisdictional Determinations May be Appealed -
The U.S. Army Corps of Engineers determines the presence or absence of wetlands and other “waters of the United States” on a...more
3/17/2016
/ Administrative Appeals ,
Administrative Procedure Act ,
CERCLA ,
Certiorari ,
Chesapeake Bay ,
Clean Water Act ,
Comment Period ,
Damages ,
Environmental Liability ,
Environmental Protection Agency (EPA) ,
Farm Bureau ,
Groundwater ,
Hawkes Co v United States Army Corps of Engineers ,
Indemnification ,
Judicial Review ,
Jurisdictional Determination (JD) ,
Permits ,
Property Owners ,
Proposed Regulation ,
Real Estate Transfers ,
SCOTUS ,
Superfund ,
Takings Clause ,
TMDL ,
TX Supreme Court ,
US Army Corps of Engineers ,
Vapor Intrusion ,
Volatile Organic Compounds (VOC) ,
Waters of the United States ,
Watershed ,
Wetlands