hazardous substance
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OMB Throws Potential Speed Bump in Front of U.S. EPA’s Efforts to Designate PFAS as CERCLA Hazardous Substances

On August 12, 2022, the Office of Management and Budget (OMB) completed its review of U.S. EPA’s proposed rule to designate perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS) as CERCLA hazardous substances. Continue reading
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EPA Proposes Hazardous Substance Facility Response Plan Regulations; Includes Climate Change and Environmental Justice Considerations
On March 11, 2022, the U.S. Environmental Protection Agency (“EPA”) announced it was proposing new regulations that would require certain facilities located close to navigable waters create and submit Facility Response Plans for worst case discharges of hazardous substances. Continue reading
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PFOA and PFAS Take Another Step Towards Becoming Full-Fledged Members of the CERCLA Family of Hazardous Substances

On January 10, 2022, U.S. EPA forwarded a proposed rule that seeks to designate perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS) as “hazardous substances” under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). Although not unexpected since this was a key element of U.S. EPA’s PFAS Strategic Roadmap, U.S. EPA’s proposed rule is unique… Continue reading
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Earth Day 2021: CERCLA and RCRA in The Biden Administration: Elevating Climate Change and Environmental Justice in Addressing Hazardous Wastes
We close out the Corporate Environmental Lawyer Blog’s weeklong celebration of Earth Day with the two federal programs aimed at cleaning up existing toxic waste sites and preventing the creation of new ones, the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (“CERCLA”) and the Resource Conservation and Recovery Act (“RCRA”). Continue reading
2019 GAO Report, American Jobs Plan Fact Sheet, American Rescue Plan Act of 2021, ARAR, Biden Administration, Brownfields, CERCLA, chemical manufacturer, chemicals, clean water, Climate Change, Contamination, criminal prosecution, dioxane, Earth Day, Earth Week, electric power generation, Electric Utilities, Emerging Contaminants, Environmental Law, environmental review requirement, EPA, federal appropriations, federal clean air, financial responsibility exemption, hazardous substance, NPL, petroleum and coal, PFAS, RCRA White House, regulatory role, regulatory rollback, remedial role, SDWA, Superfund Strategic Plan, Superfund Task Force, sustainability, Trump Administration -
Environmental Organizations Petition EPA to Expand Enforcement of Clean Air Act’s General Duty Clause
Various environmental organizations, led by the Environmental Integrity Project (“EIP”), are urging the United States Environmental Protection Agency (“EPA”) to expand enforcement of Section 112(r)(1) of the Clean Air Act (CAA)—commonly known as the General Duty Clause (“GDC”)—in order to more closely regulate the handling of hazardous substances at industrial facilities permitted under the CAA. Continue reading
