News & Analysis as of

RCRA Hazardous Waste PFAS

Holland & Knight LLP

2024 Midyear PFAS Regulatory Update: Final Rules Recently Issued by EPA and What's to Come

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Just past the halfway point of 2024, it's already been a busy year for those following regulatory developments related to per- and polyfluoroalkyl substances (PFAS). Building on its plans in the 2021 PFAS Strategic Road Map...more

Baker Donelson

Is "Forever" Really Forever? EPA's New Guidance on PFAS Destruction and Disposal

Baker Donelson on

EPA recently published a 2024 update to its Interim Guidance on the Destruction and Disposal of Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) and Materials Containing PFAS (Interim Guidance), as required by the...more

ArentFox Schiff

EPA Updates Interim Guidance on Destruction and Disposal of PFAS Wastes

ArentFox Schiff on

On April 8, the US Environmental Protection Agency (EPA) issued interim guidance for public comment regarding the destruction and disposal of per- and polyfluoroalkyl substances (PFAS). Below, we discuss the guidance and...more

Pillsbury - PFAS Observer

EPA Proposes to Designate Nine PFAS Compounds as Hazardous Constituents, Seeks Industry Input

The clock is winding down on businesses interested in commenting on EPA’s proposal to designate nine per- and polyfluoroalkyl substances (PFAS) as hazardous constituents under the Resource Conservation and Recover Act (RCRA)....more

Vinson & Elkins LLP

EPA Proposes Rules to Expand its PFAS Authority Under RCRA

Vinson & Elkins LLP on

On February 8, 2024, the Environmental Protection Agency (EPA) published two proposed rules that would expand its regulatory authority over PFAS: one to list nine PFAS as hazardous constituents subject to the Resource...more

Fox Rothschild LLP

EPA Proposes to List Nine PFAS as RCRA Hazardous Constituents

Fox Rothschild LLP on

On February 8, 2024, EPA published a proposed rule to list nine PFAS, their salts and their structural isomers, as hazardous constituents under RCRA regulations. If the proposed rule is finalized, the nine PFAS (PFOA, PFOS,...more

Latham & Watkins LLP

EPA Proposes New RCRA Rules With Significant Compliance Obligations

Latham & Watkins LLP on

The proposed rules would expand the RCRA Corrective Action regime to PFAS and potentially other emerging contaminants. They may complicate ongoing compliance efforts as well as lead to significant value chain impacts....more

Perkins Coie

EPA’s Latest PFAS Push Targets Nine Substances Under RCRA

Perkins Coie on

U.S. Environmental Protection Agency (EPA) Administrator Michael Regan signed two proposed rules related to per- and polyfluoroalkyl substances (PFAS) and the agency’s corrective action authority under the Resource...more

ArentFox Schiff

EPA Proposals on PFAS Compounds and Hazardous Waste May Presage Opening the Floodgates for RCRA Regulation and Enforcement

ArentFox Schiff on

On January 31, the US Environmental Protection Agency (EPA) issued two proposed rules to facilitate the targeting of PFAS. The first proposed rule would add certain per- and polyfluoroalkyl substances (PFAS) compounds to...more

Holland & Knight LLP

EPA Proposes RCRA Corrective Action Expansions Targeting PFAS

Holland & Knight LLP on

The 1984 Hazardous and Solid Waste Amendments amended the Resource Conservation and Recovery Act (RCRA) to add the following sections requiring corrective action for releases of hazardous waste or hazardous constituents ...more

Jones Day

EPA Proposes New Set of Rules to Regulate PFAS Under RCRA

Jones Day on

On February 8, 2024, the Environmental Protection Agency ("EPA") proposed two regulations that would add nine per- and polyfluoroalkyl substances ("PFAS") to the list of Resource Conservation and Recovery Act ("RCRA")...more

Robinson+Cole Environmental Law +

Nine PFAS Compounds Proposed to be Hazardous Constituents Under RCRA

On February 8, 2024, the U.S. Environmental Protection Agency (EPA) published two proposed rules in the Federal Register that would expand the EPA’s authority to address certain per-and polyfluoroalkyl substances (PFAS) under...more

Beveridge & Diamond PC

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

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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

Morgan Lewis

EPA Releases Proposed Resource Conservation and Recovery Act PFAS Rules

Morgan Lewis on

The US Environmental Protection Agency (EPA) published on February 8, 2024 two proposed rules addressing per- and polyfluoroalkyl substances (PFAS) under the Resource Conservation and Recovery Act (RCRA). The rules, if...more

Stinson LLP

EPA Proposes to Regulate Nine PFAS as RCRA “Hazardous Constituents”

Stinson LLP on

The U.S. Environmental Protection Agency (EPA) has taken its first major action of 2024 to regulate per- and polyfluoroalkyl substances (PFAS) across environmental media. On January 31, 2024, EPA issued pre-publication...more

Mintz

EPA's execution of its PFAS road map proves the wheels of justice aren't the only ones that turn slowly.

Mintz on

While I was on vacation last week, EPA proposed to identify as “hazardous constituents” nine of the “forever chemicals" known collectively as PFAS. EPA's proposal will now be subject to public comment before perhaps being...more

Davis Wright Tremaine LLP

Hazardous Waste Facilities Beware: PFAS Soon to Be Regulated Under RCRA

On January 31, 2024, the Environmental Protection Agency ("EPA") proposed two new rules that would add nine per- and polyfluoroalkyl compounds (known as "PFAS") to its list of hazardous constituents regulated under the...more

Kelley Drye & Warren LLP

EPA Extends RCRA ​“Hazardous Constituents” Proposal to Nine PFAS

On January 31, 2024, the United States Environmental Protection Agency (“EPA” or ​“the Agency”) issued a proposal to amend Resource Conservation and Recovery Act (“RCRA”) regulations to include nine specific per- and...more

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

Draft U.S. Environmental Protection Agency National Enforcement and Compliance Document for Years 2024-2027: Association of State...

The United States Environmental Protection Agency (“EPA”) published in the January 12th Federal Register a Request for Public Comment on the National Enforcement and Compliance Initiatives (“NECIs”) it is proposing for fiscal...more

Fox Rothschild LLP

State Enforcement Against the Federal Government, Part 2

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Almost two years ago, we posted on the civil settlement of a dispute between the New Mexico Environment Department (NMED) and the U.S. Department of Defense (DoD) over a state-level enforcement action against Cannon Air Force...more

Kilpatrick

Put This In Your Pipe and Leach It – EPA Considering Whether to Designate Discarded Products Containing PVC as a RCRA Hazardous...

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Walk around your basement – see those pipes?  Would you consider those pipes to be hazardous waste? What about rain boots?  Garden hose? Shower curtain?  Traffic cones? All of these and more have the potential to be...more

Farella Braun + Martel LLP

Summary of Latest Federal Action Regarding PFAS

A few considerations practitioners should keep in mind when dealing with contamination involving per- and polyfluoroalkyl substances (PFAS) contamination. The PFAS Action Act of 2021 passed in the House and was received in...more

BCLP

PFAS Update: A Retrospective on Federal PFAS Regulation in 2021

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As anticipated, 2021 was an eventful year for the regulation of per- and polyfluoroalkyl substances (“PFAS”) at the federal level. BCLP has highlighted the key developments in this document, but this is not intended to be a...more

Lathrop GPM

EPA Responds to Petition for PFAS Rulemaking

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EPA announced plans to initiate two rulemakings involving PFAS, one that would list four PFAS compounds as Hazardous Constituents under the Resource Conservation and Recovery Act (RCRA), the federal hazardous waste law, and...more

Perkins Coie

Beyond Cradle to Grave: EPA Proposes to Regulate PFAS “Forever Chemicals” Under RCRA

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In response to a petition from New Mexico Governor Michelle Lujan Grisham, the U.S. Environmental Protection Agency announced on October 26, 2021, that it will take steps toward regulating per- and polyfluoroalkyl substances...more

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