Summary of the Proposed Rule On August 18, 2022, the U.S. Environmental Protection Agency (EPA) released a pre-publication version of its Proposed Rule to amend the Risk Management Program (RMP) regulations at 40 C.F.R. Part 68. EPA’s Proposed Rule, referred… More
An agency’s new “interpretation” of its rules often puts business clients in a difficult position: On the turn of a dime, what seemed to be legal yesterday could become illegal tomorrow. Without notice, longstanding activities can be at risk of… More
On April 11, 2016, the U.S. Environmental Protection Agency (“EPA” or “Agency”) published notice in the Federal Register that it is tentatively denying a Petition which“requests that the Agency make two changes to the current corrosivity characteristic regulation under the… More
On October 29, 2013, the U.S. District Court for the District of Columbia (the “Court”) issued a memorandum opinion resolving cross motions for summary judgment regarding the application of section 2002(b) of the federal Resource Conservation and Recovery Act (“RCRA”)… More
On January 14, 2009, the National Resources Defense Council (“NRDC”) petitioned the U.S. Environmental Protection Agency (“EPA” or “Agency”) to revise a number of National Emission Standards for Hazardous Air Pollutants (“NESHAPs”).
On March 10, 2009, the U.S. Environmental Protection Agency (“EPA” or “Agency”) published a prepublication Notice of Proposed Rulemaking (“NPRM”) which, if implemented as proposed, would require annual reporting of greenhouse gas (“GHG”) emissions from a broad range of facilities,… More