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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

Beat the Clock: Timely Reporting of Releases of Hazardous Substances

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

Environmental Notes - August 2019

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

Superfund Neighbors Come Knocking

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

Environmental Notes - July 2017

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

Environmental Notes - December 2016

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

Common Stock Used to Reimburse EPA for CERCLA Response Costs

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

EPA Region III Assesses Largest Superfund Stipulated Penalty Ever

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

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

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