EPA

EPA Withdraws Final Rule That Would Have Recognized ASTM E1527-21 While Continuing To Recognize ASTM E1527-13

As we  predicted,  EPA received numerous negative comments to its Direct Final Rule that would have recognized that the new ASTM E1527-21 phase 1 standard may be used to comply with the All Appropriate Inquires (AAI) rule for asserting certain landowner liability defenses and qualify for brownfield grants. All of the comments criticized EPA’s plan to …

EPA Withdraws Final Rule That Would Have Recognized ASTM E1527-21 While Continuing To Recognize ASTM E1527-13 Read More »

Expect Adverse Comments as EPA Drops Ball on ASTM Recognition

In our prior blog, we announced that the Environmental Protection Agency (“EPA”) would publish a proposed rule and direct final rule proposing to amend and amending the All Appropriate Inquiries rule (“AAI”)  to reference the revised ASTM E1527-21 ‘‘Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process’’ (“E1527-21”) and allowing it to …

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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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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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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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