enforcement.

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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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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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 To Receive Full Delegation from EPA for RCRA Program

EPA proposed to approve final authorization to the New York Department of Environmental Conservation (NYSDEC) to administer the state hazardous waste program in lieu of the federal RCRA program. 78 FR 15299 (3/11/13). The authorization will become effective on May 10, 2013 unless EPA receives adverse written comment by April 10, 2013. The NYSDEC hazardous …

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NY Ct Says Former Tenant Liable For Abandoned Tanks As Trade Fixtures

Federal and state underground storage tank (UST) programs impose closure obligations on the owners or operators of USTs that are taken out of service. If the tanks are to be inactive for a short period of time (the time period varies depending on the state), the tanks must comply with temporary closure requirements. Owners or …

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