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EPA Issues Historic Proposed Rule to Designate PFOS and PFOA as Hazardous Substances Under CERCLA
On August 26, 2022, EPA issued its long-awaited notice of proposed rulemaking to designate two commonly used per- and polyfluoralkyl substances (PFAS)—i.e., PFOS and PFOA, including their salts and structural isomers—as “hazardous substances” under C...
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The Recent Rise (and Future Fall?) of Environmental Justice
For the past few months, the federal government has emphasized environmental justice issues in legislation and executive actions. Both the Department of Health and Human Services and the Department of Justice have established Offices of Environmental...
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EPA Issues New HAL for Four Commonly Used PFAS
After months of speculation, on June 15, 2022, EPA issued its drinking water health advisory for four commonly used PFAS: PFOA, PFOS, GenX, and PFBS. EPA’s drinking water health advisories provide information on the levels of a specific contaminant t...
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PFAS Roundup: A Brief Summary of the Standards Set by Western States for PFAS in the Environment
Per- and polyfluoralkyl substances (PFAS) are everywhere. PFAS are a large group of chemicals that have been in use by a variety of industries since the 1940s for their ability to resist heat, oil, stains, grease, and water. For example, in...
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New DOJ Clean Water Act Civil Enforcement Discretion Memo
The U.S. Department of Justice recently issued a new policy on limiting federal civil enforcement penalty actions under the Clean Water Act when a state is already enforcing. The Assistant Attorney General for the Environment and Natural Resources Di...
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EPA and States Issue Temporary Policies: Air and Water Permit Compliance During COVID-19
In light of the COVID-19 crisis, federal and state environmental agencies have issued temporary policies that affect regulated entities. This blog post is intended to help summarize these guidelines and highlights pertinent questions. U.S. ENVIRONME...
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