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, Philip L. Comella, and Craig B. Simonsen
Speaking of the U.S. EPA’s draft guidance addressing vapor intrusion at contaminated sites, Mathy Stanislaus, the Agency’s Assistant Administrator for Solid Waste and Emergency Response, recently told BNA Bloomberg that “my plan is to get this out this year.”
The Agency published its original notice in November 2002,
Continue Reading EPA to Issue Its Final Vapor Intrusion Guidance in 2014?
By Andrew H. Perellis and Jeryl L. Olson
Properties in Illinois that are currently contemplating or pending sale, and properties with existing No Further Remediation (NFR) letters, may encounter difficulties and issues arising under the recent indoor inhalation rules adopted in Illinois. In the Matter of: Tiered Approach to Corrective Action Objectives (TACO) (Indoor Inhalation): Amendments to 35 Ill. Adm.
Continue Reading No Further Remediation Letters and the New Indoor Inhalation Pathway in Illinois
By Andrew H. Perellis and Craig B. Simonsen
The environmental community continues to focus on the vapor intrusion pathway — guidance has been issued by ASTM, ITRC and more than 25 States. Most recently, the U.S. Environmental Protection Agency’s (EPA or Agency) Office of Underground Storage Tanks (OUST) just published an information paper entitled, “Petroleum Hydrocarbons And Chlorinated Hydrocarbons
By Philip L. Comella and Craig B. Simonsen
The U.S. Environmental Protection Agency (EPA or Agency) just released its Toxicological Review of Trichloroethylene (EPA/635/R-09/011F, September 28, 2011) (Toxicological Review). This publication represents the first time that EPA has classified trichloroethylene (TCE) (CASRN 79-01-6) as a human carcinogen regardless of the route of exposure. TCE had previously been classified
Continue Reading EPA Classifies Trichloroethylene (TCE) as Human Carcinogen