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Oregon Pursues Listing PFOA and PFOS as Hazardous Substances under State Cleanup Law

Last month, the Oregon Department of Environmental Quality (DEQ) announced a rulemaking process to list perflouorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) as hazardous substances under the Oregon Cleanup...more

EPA Proposes Cleanup Authority Expansion Under RCRA for PFAS and Other Emerging Contaminants

On February 8, 2024, the U.S. Environmental Protection Agency (EPA) proposed two rules to expand the Agency’s authority to address releases of per- and polyfluoroalkyl substances (PFAS) and other emerging contaminants at...more

EPA Seeks Comments on Potential Changes to the RCRA Definition of Empty Containers and Standards for Managing Used Containers

The U.S. Environmental Protection Agency (EPA) is considering and seeking public comment on potentially significant amendments to the hazardous waste regulations concerning the management, recycling, and disposal of drums and...more

EPA Seeks Comments on Potential Designation of Additional PFAS as CERCLA Hazardous Substances

On April 13, 2023, the U.S. Environmental Protection Agency (EPA) published in the federal register an Advanced Notice of Proposed Rulemaking (ANPRM) seeking public input to inform its decision whether to designate additional...more

EPA Amends All Appropriate Inquiries Standard for Phase I Environmental Site Assessments

Key Takeaways - • Effective February 13, 2023, parties may rely on ASTM E1527-21 to satisfy All Appropriate Inquiries (AAI) under the Comprehensive Environmental Response, Compensation, and Liability Act, as amended, 42...more

Washington Supreme Court Affirms Ecology’s Authority to Bypass Rulemaking When Requiring New PCB Sampling Methods Under CWA...

The Washington State Supreme Court agreed with the Department of Ecology in a dispute over whether Ecology should have followed notice and comment rulemaking procedures when adding two new controversial test methods for...more

EPA Headquarters Prods Cleanup Programs on Enforcement to Strengthen EJ

On July 1, 2021, EPA’s Office of Enforcement and Compliance Assurance (OECA) issued a memorandum to all EPA Regional Offices urging the offices to increase cleanup program enforcement under the Comprehensive Environmental...more

Supreme Court Clarifies That Only CERCLA Settlements Trigger Contribution Claims

On May 24, the Supreme Court weighed in on an issue that for decades has bedeviled litigants under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA): When can potentially responsible parties...more

Supreme Court Rules that Landowners at a CERCLA Site Cannot Require Additional Cleanup under State Law without Advance EPA...

Summary - Private landowners at a federal Superfund site cannot use state law claims to require additional remediation without advance EPA approval, based on a limitation in the Comprehensive Environmental Response,...more

Proposed Changes to Effluent Limit Guidelines for Steam Electric Power Generating Facilities

In keeping with the priorities of the Trump administration, EPA issued long-awaited proposed changes to the 2015 Effluent Limitations Guidelines and Standards for the Steam Electric Power Generating Point Source Category...more

Carbon Markets Roundup August 2019

B&D’s Carbon Markets Roundup covers domestic and international developments related to carbon pricing and related regulatory programs aimed at regulating or reducing greenhouse gas emissions. This edition of Carbon Markets...more

Despite Sophisticated Acquisition Contract, Allocation of CERCLA Liability Unclear

An April 11, 2019 decision by the U.S. District Court for the District of Montana illustrates the challenges of contracting away CERCLA liability even when contractual negotiations occur between sophisticated parties....more

For the First Time, EPA Proposes to Add a Site to the National Priorities List Solely Based on the Risk Posed by Vapor Intrusion

EPA has proposed to add the Rockwell International Wheel & Trim Site in Grenada, Mississippi to the National Priorities List, the first site added based solely on the risk to human health from vapor intrusion from subsurface...more

For the First Time, U.S. EPA Proposes to Add a Site to the National Priorities List Solely Based on the Risk Posed by Vapor...

The National Priorities List is designed to identify the contaminated sites that pose the highest risk to human health or the environment so that U.S. EPA can focus its efforts on these sites. For the first time, on January...more

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