News & Analysis as of

Comprehensive Environmental Response, Compensation and Liability Act New Guidance

Seyfarth Shaw LLP

New Year, New Penalties: OSHA and USEPA Increase Penalties

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The federal Occupational Safety and Health Administration (OSHA) and Environmental Protection Agency (“EPA”) have published their 2025 increases to civil penalties....more

Perkins Coie

Two PFAS Designated as CERCLA Hazardous Substances

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The U.S. Environmental Protection Agency (EPA) announced a Final Rule on April 19, 2024, designating two of the most common per- and polyfluoroalkyl substances (PFAS)—PFOA and PFOS, including their salts and structural...more

Eversheds Sutherland (US) LLP

In long-awaited move, EPA designates two PFAS as hazardous substances and issues PFAS enforcement policy

Capping a flurry of recent activity concerning per- and polyfluoroalkyl substances (PFAS), US EPA on April 19, 2024 designated two PFAS as hazardous substances. Designations of other PFAS are likely to follow. The same day,...more

Goldberg Segalla

Leading with Lead: EPA to Implement Strategy for Lead in 2024

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The U.S. Environmental Protection Agency kicked off the New Year by strengthening its guidance for investigating and cleaning up lead-contaminated soil at residential properties, especially in areas where children live and...more

Bricker Graydon LLP

What is an “Energy Community” - IRS Provides Guidance on Key Aspect of the Inflation Reduction Act

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The Inflation Reduction Act (IRA) has been called the most aggressive climate investment ever undertaken by the U.S. Congress. With approximately $370 billion dollars in funding over the next 10 years, it is projected that...more

Foley & Lardner LLP

IRS Releases Guidance on Energy Community Credit Adder

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On April 4, 2023, the Department of Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) released Notice 2023-29 (the “Notice”) providing a high-level overview of the rules they intend to include in...more

Nossaman LLP

EPA Announces Update to Civil Monetary Penalties – Impacts on Water Providers

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On January 6, 2023, the U.S. Environmental Protection Agency (EPA) announced its Final Rule, listed at 88 FR 986, updating the maximum civil monetary penalties that may be assessed for violations of environmental statutes....more

Eversheds Sutherland (US) LLP

The Superfund Tax is back: Recent IRS guidance and background

As this nation prepared to celebrate the Independence Day long weekend, many were preparing for the July 1, 2022, reinstatement of the Superfund chemicals tax (the Superfund Tax). The Superfund Tax is an excise tax imposed on...more

Jenner & Block

How Low Can You Go—U.S. EPA Attempts to Answer that Question With New PFAS Health Advisory Levels

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U.S. EPA issued its long anticipated interim updated drinking water health advisories for perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) that replace previous U.S. EPA health advisories for these per-...more

King & Spalding

EPA Receives Objection To Proposed Adoption Of ASTM’s Updated Phase I Guidance

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As our loyal readers know, in January ASTM International revised its Standard Practice for Phase I Environmental Site Assessments (Phase I) to address PFAS as a “non-scope” consideration. (As a reminder, “non-scope”...more

Woods Rogers

Environmental Justice Emerges as EPA and Virginia Priority

Woods Rogers on

Recent guidance issued by the U.S. Environmental Protection Agency (“EPA”) evidences EPA’s intention to better incorporate Environmental Justice (“EJ”) considerations into program administration and enforcement. ...more

Holland & Hart LLP

Recent EPA Guidance Spells Out Superfund Liability Protections Available to Local Governments

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State and local governments are in a unique position when it comes to facilitating the cleanup and redevelopment of contaminated properties within their jurisdictions and can play a vital role in revitalizing neighborhoods...more

Williams Mullen

EPA Releases New Guidance on CERCLA Landowner Liability Protections

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EPA recently issued a guidance document (the “Guidance”) that supersedes and clarifies its 2003 guidance on what prospective purchasers of real estate must do to qualify for one of CERCLA’s three landowner liability...more

Holland & Knight LLP

EPA Releases Updated CERCLA Common Elements Guide - Enforcement Discretion Guidance Provides Important Direction on Landowner...

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• The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) imposes strict, joint and several, retroactive liability on property owners and operators for releases of hazardous substances. However,...more

Miles & Stockbridge P.C.

EPA Deletes Several Superfund Sites from the NPL and Targets More in 2018 and Beyond

U.S. Environmental Protection Agency (EPA) Administrator Scott Pruitt says that expediting cleanups at Superfund sites is one of his top priorities. Since 1980, EPA has had the authority to clean up contaminated sites and...more

Williams Mullen

Hurricanes and Flooding: Surely EPA Regulations are Suspended?!

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It seems to happen every year. A natural disaster disrupts fall football season, and interstates are full of evacuees gobbling up hotel rooms and squatting in the nearest safety zones. In those times, no one ever thinks of...more

Williams Mullen

EPA Issues New Contaminated Sediments Guidance

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Earlier this year, EPA released revised guidance for remediation of contaminated sediments at sites being addressed by EPA under CERCLA (the “New Sediment Guidance”). The guidance identifies six key clarifications to EPA...more

Williams Mullen

Environmental Notes - December 2016

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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

Seyfarth Shaw LLP

EPA Takes Positions on Vapor Intrusion

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In a busy day for vapor intrusion, last week the U. S. Environmental Protection Agency made several announcements about vapor intrusion. First, it announced it had submitted a draft rule to the White House OMB seeking to...more

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