EPA is accepting comments on an information collection request (ICR), NSPS for Municipal Solid Waste Landfills, submitted to the Office of Management and Budget (OMB). Comments will be accepted until March 1, 2021 and should be submitted online using www.regulations.gov
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EPA Publishes Interim Guidance on the Destruction and Disposal of PFAS
By Ann Zwick
On December 18, 2020, the U.S. Environmental Protection Agency (EPA) released its Interim Guidance on the Destruction and Disposal of Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) and Materials Containing Perfluoroalkyl and
Polyfluoroalkyl Substances (PFAS). The Interim Guidance is not a rule…
Amendment to CCR Rule Provides Exception to Closure Requirement for Certain Unlined Ash Impoundments
By Ryan Rudich
The Trump administration’s EPA has again finalized changes to the CCR Rule. The most recent rule change—”Part B”—provides an exception to the Rule’s mandate that all unlined impoundments close on or before April 11, 2021. If the rule stands—a…
EPA Announces Extension of Temporary COVID-19 Manifest Signature Policy
The U.S. Environmental Protection Agency (“EPA”) recently announced that it will be extending its COVID-19 Implications for Signing Paper Hazardous Waste Manifests policy (“Temporary COVID-19 Manifest Signature Policy” or “Policy”) until November 30, 2020.
On May 18, 2020, EPA issued…
In Wake of COVID-19, USEPA Allows On-Site Inspections to be Replaced by Off-Site Monitoring Activities
In the wake of the COVID-19 pandemic, the U.S. Environmental Protection Agency (EPA) has suspended requirements for state agencies to perform on-site compliance inspections in favor of off-site monitoring alternatives.
In a recent letter, the EPA Office of Enforcement…
EPA Announces Plan to Terminate COVID-19 Enforcement Discretion Policy on August 31, 2020
The United States Environmental Protection Agency (“EPA”) recently announced that it will be terminating its temporary enforcement discretion policy on August 31, 2020 at 11:59 PM Eastern Daylight Saving Time. In general, this means that EPA will not base any…
Supreme Court Green Lights State Law Claims in Superfund Context
By Bob Baratta
In Monday’s split decision, the U.S. Supreme Court held that the Comprehensive Environmental Response, Compensation and Liability Act (“CERCLA”) (i) does not preclude owners of contaminated property from pursuing state law claims for nuisance, trespass and strict liability, but (ii)…
Michigan Environment, Great Lakes and Energy Department announces new policy on enforcement discretion arising from COVID-19
“Michigan Environment, Great Lakes and Energy Department announces new policy on enforcement discretion arising from COVID-19”
Link: https://www.michigan.gov/egle/0,9429,7-135–523592–,00.html
How “Stay at Home” Orders are Impacting the Waste Industry Across the Country
In a matter of days, Americans have been asked to stay home as states across the country issue orders requiring non-essential businesses to cease operations. Given the essential public health role of the waste and recycling industries, however, these industries…
U.S. Environmental Protection Agency Set to Scale Back Enforcement Actions During COVID-19
By Ryan Rudich
On March 26th, the U.S. Environmental Protection Agency (“EPA” or “Agency”) issued a sweeping guidance memorandum, announcing its intent not to bring enforcement actions for a range of violations of environmental laws caused by the ongoing COVID-19 pandemic.
For an…