EPA Issues Guidance For Continuing or Suspending Response Actions During COVID-19 Crisis

In our post discussing EPA’s Enforcement Discretion guidance, we mentioned that EPA was working on guidance for performing remedial actions during the Covid-19 crisis. On April 10th, EPA issued its “Interim Guidance on Site Field Work Decisions Due to Impacts of COVID-19” (Interim Guidance) to regional offices when determining to continue, reduce, or pause on-site …

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Revised ESD Essential Services Guidance Appears to Include Phase 1 Reports and End Confusion for Consultants

As we discussed in a prior Post, the Empire State Development Corporation (ESD) issued a guidance document that were exempt from  Governor Cuomo’s  Executive Order 202.8 banning non-essential services from operating to control the spread of the covid19 virus. In response, the New York State Department of Environmental Conservation (“NYSDEC”) issued its own Guidance describing the …

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NYSDEC Clarifies Requirements for Execution and Submission of BCP Agreements and Amendments

The New York State Department of Environmental Conservation (“NYSDEC”)  has received numerous inquiries about issues arising with the execution of Brownfield Cleanup Program (“BCP”) agreements and amendments  because of the Covid19 pandemic. In response, the NYSDEC has issued the following guidance: The DYSDEC will grant reasonable extensions of time for the execution of Brownfield Cleanup …

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NYSDEC Issues Further Guidance on Essential Activities For Brownfield Projects

In a prior post, we discussed a letter NYSDEC issued to staff and standby contrators interpreting Governor Cuomo’s Executive Order 202.6 (EO) and the Empire State Development Corporation Guidance on shutdown of all non-essential services and activities. DEC has now posted further clarification on its  website that it considers the following activities as essential services: …

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NYSDEC Will Exercise Enforcement For Signature Procedures for Certain Waste Streams

To prevent spread of COVID-19, the New York State Department of Environmental Conservation (NYSDEC) will exercise its enforcement discretion with respect to certain provisions of 6 NYCRR Parts 364,372,374-2, and 381. According to a Letter issued by the NYSDEC Office of General Counsel, the agency will not pursue enforcement of requirements for signatures on waste …

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NYSDEC Exercising Enforcement For Bottle Redemptions

Pursuant to Empire State Development Corporation’s  Guidance on Executive Order 202.6, “trash and recycling collection, processing and disposal services” are considered essential business or entities that are not required to reduce in-person workforce by 100%.  The exclusion includes collection, transportation, processing and disposal activities for any solid wastes, regulated medical waste, hazardous wastes, radioactive wastes …

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NYC OER Issues Guidance Implementing Construction Ban For Remedial Sites

On March 30th, the NYC Department of Buildings issued a memo implementing Governor Cuomo’s Executive Order 202.6 (EO) and New York State Empire Development Corporation  Guidance  requiring the shutdown of all non-essential construction except emergency construction For projects enrolled in its Voluntary Cleanup Program or the “e” designation program, OER will implement the construction ban on …

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EPA Issues Enforcement Discretion Memo for Routine Civil Violations Arising from COVID-19 Pandemic

Update: EPA has created a frequently-asked questions about covid-19 webpage that is available Here. The federal Environmental Protection Agency has issued a Memo announcing that it will temporarily exercise enforcement discretion for certain civil violations where the non-compliance was a result of the COVID-19 pandemic. Contrary to news articles in such publications  as E&E News, The …

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NYSDEC Determines Remedial Activities Are “Essential Services” Under Governor’s Executive Order

On Saturday, March 21, 2020, New York Governor Andrew Cuomo issued a new Executive Order No. 202.8 (EO 202.8) “Continuing Temporary Suspension and Modification of Laws Relating to the Disaster Emergency ” requiring all businesses and not-for-profit entities to require 100%  of  workers to work from home effective at 8 p.m. Sunday, March 22, 2020.Businesses …

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EPA Proposes to Regulate PFOAs and PFOS in Drinking Water

On February 20th, EPA Announced  it will make a regulatory determination (RD) for two emerging contaminants-perfluorooctanesulfonic acid (PFOS) and perfluorooctanoic acid (PFOA)- under the Safe Drinking Water Act (SDWA) as part of its fourth Contaminant Candidate List. This is the first step in determining whether PFOA and PFOS should be regulated under the SDWA. EPA is …

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