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EPA Finalizes National Primary Drinking Water Regulation for Certain PFAS

The U.S. Environmental Protection Agency (EPA) has finalized its proposed rule establishing National Primary Drinking Water Regulation (NPDWR) for certain PFAS compounds. The final rule sets Maximum Contaminant Levels (MCL)...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

EPA Foregoes Requiring Financial Assurances from the Chemical, Power, Petroleum, and Coal Products Industries

Overview - On December 2, 2020, EPA published its final decision declining to impose financial assurance requirements under section 108(b) of the Comprehensive Environmental Response, Compensation, and Liability Act...more

EPA Finalizes Important Changes to Agency Guidance Procedures

Key Takeaways - • What Happened: EPA finalized new procedures for issuing, identifying, and maintaining Agency guidance documents....more

EPA Lifting COVID-19-Related Enforcement Discretion Policy on August 31

On August 31, the U.S. Environmental Protection Agency (EPA) will terminate its March 26, 2020 policy that provided enforcement discretion for certain types of violations due to impacts from COVID-19. The policy identified...more

EPA Weighs Lifting COVID-19-Related Enforcement Discretion Policy

EPA has recently confirmed that it is reviewing its March 26, 2020 guidance that provided enforcement discretion for certain types of violations due to impacts from COVID-19. The policy, described in a prior Beveridge and...more

EPA Tackles Controversial Clean Water Act Certification Requirements

The U.S. Environmental Protection Agency (EPA) published a final rule to interpret the requirements for water quality certification under section 401 of the Clean Water Act. This Section grants states and approved tribes the...more

Opportunities for Industry Action in Response to President Trump’s Executive Order Limiting EPA and Other Federal Agency Use of...

Summary - Stakeholders in the regulated community have a unique but time-limited opportunity to petition the U.S. Environmental Protection Agency (EPA) and other federal agencies to either add or remove specific guidance...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

EPA Issues Interim COVID-19 Guidance for Superfund Sites and Other Cleanup Actions

Key Takeaways - • What Happened: On April 10, 2020, EPA issued a memo, Interim Guidance on Site Field Work Decisions Due to Impacts of COVID-19, that outlines considerations for reconciling remediation schedules with the...more

EPA Policy Provides Enforcement Relief Where Needed Due to Pandemic

On March 26, 2020, EPA issued new guidance addressing a range of issues relating to environmental compliance and enforcement during the COVID-19 pandemic. The Agency sets expectations for the regulated community to continue...more

Complying with the CCR Rule: A Moving Target

The Coal Combustion Residuals (CCR) Rule, first issued in April 2015, regulates the disposal of coal ash in landfills and surface impoundments under Subtitle D of the Resource Conservation and Recovery Act. It provides...more

EPA Issues Updated Guidance on “Common Elements” of Superfund Innocent Landowner Defenses

On July 29, 2019, EPA issued updated guidance on the “Common Elements” of the innocent landowner defenses under the Superfund statute: the Comprehensive Environmental Response, Compensation, and Liability Act....more

EPA Proposes Revisions to Rules for Disposal of Coal Combustion Residuals from Electric Utilities

Today, EPA published a proposal to amend the regulations in 40 CFR Part 257, Subpart D, governing the disposal of coal combustion residuals (“CCR” or coal ash) in landfills and surface impoundments. The proposed rule is the...more

CERCLA Task Force Issues Recommendations

EPA Administrator Scott Pruitt has announced a set of Task Force recommendations that are aimed at improving the Superfund program. The Agency’s adoption of these recommendations is another indication that demonstrable...more

EPA Retracts CERCLA Remedy Selection Authority from Regional Offices for Remedies that Exceed $50 Million

On May 9, 2017, EPA Administrator Scott Pruitt issued two new delegations under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund) that limit to the Administrator (and possibly the...more

EPA Proposes to Amend the Site Remediation NESHAP to Remove the Exemption for Site Remediation Activities Performed under CERCLA...

On May 13, 2016, EPA proposed to amend several provisions of the National Emission Standards for Hazardous Air Pollutants (NESHAPs): Site Remediation. The Site Remediation Rule currently exempts from hazardous air pollutant...more

EPA Regulates Coal Combustion Residuals as Solid Waste and Retains Exclusions for Beneficial Use

Today EPA issued a final rule regulating coal combustion residuals (CCR) as solid waste under Subtitle D of the Resource Conservation and Recovery Act (RCRA). This ends years of speculation regarding whether EPA might decide...more

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