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, the EPA continues to add
Continue Reading Trump Administration Superfund Related Activities
By Andrew H. Perellis, Kay R. Bonza, and Craig B. Simonsen
Seyfarth Synopsis: With the EPA adding the consideration of vapor intrusion in its Superfund site investigations, hundreds of sites that previously would not rank high enough to qualify for listing on the National Priorities List of contaminated sites would now likely qualify.
The U.S. Environmental Protection
Continue Reading EPA Eases Path to Superfund Listing: Vapor Intrusion Component Added to the Hazardous Ranking System
By Andrew H. Perellis and Craig B. Simonsen
The U.S. Environmental Protection Agency (EPA) has just announced a proposed rule to add a subsurface intrusion (SsI) component to the Superfund Hazard Ranking System (HRS). Addition of a Subsurface Intrusion Component to the Hazard Ranking System, RIN 2050-AG67 (February 3, 2016).
By adding the consideration of vapor intrusion, hundreds of
Continue Reading EPA Plans to Ease Path to Superfund Listing: Vapor Intrusion Component to be Added to the Hazardous Ranking System
By Jeryl L. Olson and Craig B. Simonsen
In a busy day for vapor intrusion, last week the U. S. Environmental Protection Agency made several announcements about vapor intrusion.
First, it announced it had submitted a draft rule to the White House OMB seeking to add vapor intrusion to the pathways evaluated under the Hazard Ranking Scoring (HRS) System for
Continue Reading EPA Takes Positions on Vapor Intrusion
By Andrew H. Perellis and William R. Schubert
A recent Government Accountability Office report (GAO-13-252) called on EPA to improve its management of alternatives to National Priorities List placement.
The report found that at most sites that EPA deems eligible for NPL placement, EPA uses an alternative approach so that the site can be remediated without being placed on the
Continue Reading GAO Report Criticizes Inconsistency Among EPA Regions For Alternate Cleanups Managed Outside of Superfund