News & Analysis as of

Clean Air Act Hazardous Substances Environmental Protection Agency (EPA)

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

Lime Manufacturing Plants/NESHAP: National Lime Association Files Petition for Review before U.S. Court of Appeals for the D.C....

The National Lime Association (“NLA”) filed on September 13th a Petition for Review (“Petition”) before the United States Court of Appeals for the D.C. Circuit challenging the United States Environmental Protection Agency’s...more

Stoel Rives - Environmental Law Blog

EPA Reconsiders New Risk Management Program Regulations, but Regulations Remain in Effect

The D.C. Circuit Court of Appeals placed the challenges to the U.S. Environmental Protection Agency’s (“EPA”) risk management regulation on hold for 120 days while the EPA reconsiders the concerns raised by challengers....more

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

New Source Performance Standards/National Emission Standards for Hazardous Air Pollutants: U.S. Environmental Protection Agency...

The United States Environmental Protection Agency (“EPA”) issued a pre-publication version of a proposed rule that would remove affirmative defense provisions from certain Clean Air Act New Source Performance Standards...more

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

EPA's RMP Rule: Failures to Protect the American People/American Manufacturing: U.S. House of Representatives Subcommittee on...

The United States House of Representatives Subcommittee on Environment, Manufacturing, and Critical Materials of the Energy and Commerce Committee held a May 7th Hearing titled: EPA’s RMP Rule: Failures to Protect the...more

Holland & Knight LLP

Chemical Transporters Face Ongoing Challenges from EPA's Focus on "Transit-Related" Activity

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Chemical transport, tank cleaning and transportation depot operators breathed a sigh of relief in March 2024 when the U.S. Environmental Protection Agency (EPA) dropped provisions from a proposed rule when it issued its final...more

Dechert LLP

Dechert Re:Torts - Issue 15

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Previous editions of Re:Torts (It’s (Still) Important Enough to Get It Right; Opioid Public Nuisance Question) have covered decisions that addressed whether various states permit public nuisance claims in connection with the...more

Pillsbury Winthrop Shaw Pittman LLP

EPA Issues New Rules Regarding Response and Risk Management Plans

The Accidental Chemical Release Rules have an effective date of May 10, 2024, and includes a number of situations requiring compliance, generally by May 10, 2027. The new Clean Water Act facility response plan...more

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

Air Enforcement: U.S. Environmental Protection Agency and Taunton, Massachusetts, Ethylene Oxide Sterilization Facility Enter into...

The United States Environmental Protection Agency ("EPA") and Professional Contract Sterilization, Inc. ("PCSI") entered into a February 6th Consent Agreement ("CA") addressing alleged violations of the Clean Air Act. See...more

Williams Mullen

"Risky Businesses" Beware - EPA's New Risk Management Plan Requirements Could Bite

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Under the Clean Air Act, facilities that present a high risk of chemical accidents, including those engaged in industries such as chemical manufacturing, paper manufacturing, and warehousing and storage, are required to...more

Downey Brand LLP

EPA Adds Extensive New Amendments to its Risk Management Program in Final Rule

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On March 11, 2014, the Environmental Protection Agency (EPA) published in the Federal Register amendments to the Risk Management Program (RMP) rule (Final Rule). Going into effect on May 10, 2024, EPA’s Final Rule, named the...more

Kelley Drye & Warren LLP

EPA Finalizes First-Ever Facility Response Plan Requirements for “Worst-Case” Chemical Discharges to Water

Echoing recent revisions strengthening the Risk Management Program under the Clean Air Act, the U.S. Environmental Protection Agency (“EPA” or ​“the Agency”) on March 14, 2024 finalized a rule requiring certain facilities to...more

Stinson LLP

EPA Releases Risk Management Program Final Rule

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On March 1, 2024, the U.S. Environmental Protection Agency (EPA) signed its final “Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act; Safer Communities by Chemical Accident...more

Allen Matkins

California Environmental Law & Policy Update 12.29.23

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Truck engine maker Cummins Inc. has agreed in principle to pay a $1.675 billion civil penalty for installing devices on hundreds of thousands of engines to allow them to emit excess pollution. According to the U.S. Department...more

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

Reconditioning/Used Drum Management: ASTSWMO Comments Addressing U.S. Environmental Protection Agency Advance Notice of Proposed...

The Association of State and Territorial Solid Waste Management Officials (“ASTSWMO”) submitted comments to the United States Environmental Protection Agency (“EPA”) on November 22 addressing the following Advance Notice of...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

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

Hazardous Air Pollutants/Clean Air Act: U.S. Environmental Protection Agency Proposed Rule Addressing Issues Associated with...

The United States Environmental Protection Agency (“EPA”) published in the September 13th Federal Register a proposed rule that would amend the general provisions for Clean Air Act National Emission Standards for Hazardous...more

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

112(r)(7)/Air Enforcement: U.S. Environmental Protection Agency and Portage, Indiana, Water Company Enter into Consent Agreement...

The United States Environmental Protection Agency (“EPA”) and Indiana- American Water Company, Inc. (“IAWC”) entered into an August 16th Consent Agreement and Final Order (“CAFO”) addressing alleged violations of the Clean...more

King & Spalding

New Executive Order Doubles Down on Environmental Justice Focus and Brings New Concerns for Business

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President Biden issued an Executive Order on April 21, 2023 titled “Revitalizing Our Nation’s Commitment to Environmental Justice for All” (the “EO”). The EO continues the Administration’s emphasis on environmental justice by...more

Williams Mullen

Environmental Notes - April 2023

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EPA’s Big Plans for 2023: Top Air Rulemakings We Are Watching - An environmental lawyer walks into a cocktail party. An often-asked question is: What is happening at EPA in your world? What should we be watching that...more

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

Mercury and Toxic Standards for Power Plants: U.S. Environmental Protection Agency Final Rule Reaffirming Appropriate and...

The United States Environmental Protection Agency (“EPA”) published on February 15th a final rule reaffirming its decision that it remains appropriate and necessary to regulate hazardous air pollutants (“HAP”) from power...more

Williams Mullen

EPA Enforcement Alert: Emergency and Non-Emergency Stationary Sources Are the Focus of EPA

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​​​​​​​In a recent “Enforcement Alert,” EPA set out its intent to target owners and operators of stationary engines for compliance with Clean Air Act emissions requirements. According to the Enforcement Alert, “EPA has been...more

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

112(r)/Clean Air Act Enforcement: U.S. Environmental Protection Agency and Middlesboro, Kentucky, Food Manufacturing Facility...

The United States Environmental Protection Agency (“EPA”) and Smithfield Packaged Meats Corporation (“Smithfield”) entered into an August 30th Consent Agreement (“CA”) addressing alleged violations of the regulations...more

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

Risk Management Program/Clean Air Act: U.S. Environmental Protection Agency Announces Proposed Revisions to Accidental Release...

The United States Environmental Protection Agency (“EPA”) on August 18th announced a prepublication proposed rule that would amend the Clean Air Act Risk Management Program (“RMP”) regulations....more

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

Public Health Air Quality Act of 2022: Congressional Legislation Introduced to Expand Fenceline/Ambient Air Monitoring

Congressman Rochester (Delaware) and Senator Duckworth (Illinois) have introduced S.4510 which is denominated the Public Health Air Quality Act of 2022 (“S.4510”). The legislation addresses Clean Air Act monitoring...more

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

NESHAP/Clean Air Act: U.S. Environmental Protection Agency Proposes Technology Review and Standards of Performance for Bulk...

The United States Environmental Protection Agency (“EPA”) issued last week a prepublication proposed rule addressing Clean Air Act National Emission Standards for Hazardous Air Pollutants (“NESHAP”) for Gasoline Distribution...more

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