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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, the exclusion applies regardless of…
Continue Reading USEPA Determines Pollutant Releases to Groundwater from Point Source Do Not Require NPDES Permit

By Jeryl L. Olson and Craig B. Simonsen

The U.S. Environmental Protection Agency, in response to Executive Order 13650, Improving Chemical Facility Safety and Security (EO), is publically, through a Federal Register notice, requesting public comments on “potential revisions” to its Risk Management Program. 79 Fed. Reg. 44604 (July 31, 2014).

This request is part of an effort highlighted in…
Continue Reading EPA Request for Information on Clean Air Act Accidental Release Prevention Program

By Andrew H. Perellis and Craig B. Simonsen

Senator Frank Lautenberg introduced legislation yesterday intended to reduce the risk to communities from attack or catastrophic incident. The proposed legislation would require high risk chemical, oil refineries, and water facilities to assess and develop plans to address their vulnerabilities.  The legislation would also require the highest-risk facilities to use “Inherently Safer Technology&rdquo…

Continue Reading Congress Considers Bills to Impose Heightened Safety Obligations Upon Chemical Facilities