News & Analysis as of

Hazardous Substances Clean Air Act Regulatory Reform

Mitchell, Williams, Selig, Gates & Woodyard,...

Synthetic Organic Chemical Manufacturing Industry/Polymers and Resins Industry NESHAP: American Chemistry Council/American Fuel &...

The American Chemistry Council (“ACC”) and American Fuel & Petrochemical Manufacturers (“AFPM”) sent a March 31st letter to the United States Environmental Agency (“EPA”) requesting: …a two-year exemption from the...more

McGlinchey Stafford

Trump Announces Presidential Exemptions Under Clean Air Act

McGlinchey Stafford on

In an unprecedented move, the Trump administration established an electronic mailbox to allow the regulated community to request a Presidential Exemption to certain requirements of the Clean Air Act (CAA). Under Section...more

McGuireWoods LLP

EPA Reconsiders NESHAPs: Key Changes and Industry Impacts for the HON Rule

McGuireWoods LLP on

The Environmental Protection Agency (EPA) on March 12 announced that it will reconsider eight National Emission Standards for Hazardous Air Pollutants (NESHAPs), affecting critical sectors within the American energy,...more

Seyfarth Shaw LLP

EPA-pocalypse Now!

Seyfarth Shaw LLP on

Seyfarth Synopsis: A second Trump administration is likely to bring sweeping changes to environmental regulatory and enforcement agendas. During the first Trump term, his administration focused on significant deregulation in...more

Robinson+Cole Environmental Law +

Back From the Grave? “Once In, Always In” for Hazardous Air Pollutant Emissions

In the Byzantine complexity of the Clean Air Act (CAA), EPA’s “once in, always in” policy regarding hazardous air pollutants (HAP) has been particularly confounding.  And now it’s back in play, through regulatory revisions...more

Jenner & Block

U.S. EPA’s Addition of 1-BP to CERCLA Hazardous Substance List Likely Precursor to Similar Actions on PFAS

Jenner & Block on

On April 8, 2022, U.S. EPA added the industrial solvent 1-bromopropane (1-BP) to its list of CERCLA hazardous substances; this listing was triggered by U.S. EPA’s decision to add 1-BP to the Clean Air Act’s list of hazardous...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Air Enforcement: Tennessee Air Pollution Control Board Proposed Order/Civil Penalty Addressing Ashland City, Tennessee Water...

The Tennessee Air Pollution Control Board (“TACB”) issued a March 4th Technical Secretary’s Order and Assessment of Civil Penalty (“Order”) addressing an alleged air permit violation by State Industries, LLC (“State”). See...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Status of Clean Air Act State Implementation Plan Submittals/Approvals: U.S. Environmental Protection Agency Office of Inspector...

The U.S. Environmental Protection Agency (“EPA”) Office of Inspector General (“OIG”) issued a March 25th Notification of Evaluation titled: Status of Clean Air Act State Implementation Plan Submittals and Approvals...more

Williams Mullen

Environmental Notes - March 2018

Williams Mullen on

Since 1995, EPA has followed a policy that any air emissions source that emits one or more hazardous air pollutants (“HAPs”) above major source emissions thresholds is always considered a major source of HAPs. This is so even...more

Robinson & Cole LLP

EPA Tosses Out the “Once In, Always In” Policy For Major Sources of Hazardous Air Pollutants

Robinson & Cole LLP on

On January 25, 2018, the Environmental Protection Agency (EPA) withdrew its longstanding but controversial “once in, always in” policy that a “major source” of hazardous air pollutants (HAP) was forever locked into “major...more

Seyfarth Shaw LLP

EPA Withdraws “Once In Always In” Policy For Major HAP Sources

Seyfarth Shaw LLP on

Seyfarth Synopsis: In another example of business-friendly regulatory agency actions, the U.S. Environmental Protection Agency has just rescinded the “Seitz Memo” associated with the “Once In, Always In” policy affecting the...more

Pierce Atwood LLP

EPA's "Once In, Always In" Policy Is Tossed Out

Pierce Atwood LLP on

On January 25, 2018, EPA announced that it was withdrawing its “once in, always in” policy for the classification of major sources of hazardous air pollutants (HAPs) under Section 112 of the Clean Air Act. Under its new...more

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