Environmental Compliance

By Jeryl L. OlsonKay R. Bonza, and Craig B. Simonsen

Seyfarth Synopsis: The U.S. Chemical Safety and Hazard Investigation Board (CSB) has proposed new accidental chemical release reporting requirements that are broad in scope and would cover additional chemicals, threshold quantities, and areas than existing narrow regulatory release reporting requirements already

By Jeryl L. OlsonPatrick D. Joyce, Adam R. Young, Ilana R. Morady, and Craig B. Simonsen

Seyfarth Synopsis:  The continued efforts of federal, state, and local governments to legalize cannabis, both in medical and recreational uses, leaves many potential impacts, including environmental law and regulatory issues in the manufacturing

By Jeryl L. Olson, Patrick D. Joyce, and Craig B. Simonsen

Seyfarth Synopsis:  EPA, in an Advance Notice of Proposed Rulemaking, requests comments on adding certain per- and polyfluoroalkyl substances (PFAS) to the TRI chemical list.

The U.S. Environmental Protection Agency (EPA) has asked industry stakeholders to provide comments on a proposal

By Jeryl L. Olson and Craig B. Simonsen

Seyfarth Synopsis:  Last week the U.S. Environmental Protection Agency (EPA) finalized a “streamlined system” for managing hazardous waste aerosol cans as Universal Waste.  The Agency believes that the new system will be “clear, practical, and protective” and will promote recycling, and estimates the change will save

By Andrew H. PerellisRebecca A. Davis, and Craig B. Simonsen

Seyfarth Synopsis: The Army Corps of Engineers (Corps) and the U.S. Environmental Protection Agency (EPA) published its final rule this week to repeal the 2015 rule that “impermissibly expanded the definition of ‘waters of the United States’ (WOTUS)” under the Clean

By Andrew H. PerellisJeryl L. OlsonPatrick D. Joyce, and Craig B. Simonsen

Seyfarth Synopsis:  Consistent with guidance issued by the Environmental Protection Agency (EPA) in March 2018, the Agency has now proposed to codify changes to the New Source Review (NSR) applicability regulations to clarify the requirements that

By Andrew H. Perellis, Jeryl L. Olson, Patrick D. Joyce, and Craig B. Simonsen

Seyfarth Synopsis: The Illinois Supreme Court recently affirmed that the Illinois Pollution Control Board’s clean construction or demolition debris (CCDD) rules were not arbitrary and capricious. County of Will v. Pollution Control Board, Docket Nos. 122798

By Jeryl L. Olson and Andrew H. Perellis

Seyfarth Synopsis: USEPA published an Interpretive Statement (dated April 12, 2019), which according to the Agency “clarifies” that releases of pollutants to groundwater from a point source are “categorically excluded” from Clean Water Act National Pollutant Discharge Elimination System (NPDES) permitting requirements. 

According to the Agency,

By Rebecca A. Davis and Jeryl L. Olson

Seyfarth Synopsis:  Under the Trump Administration, the U.S. Environmental Protection Agency (EPA) has fully or partially deleted 22 sites from the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) National Priorities List (NPL).  This is the largest number of deletions in one year since 2005. 

However,