We’ve discussed in our previous posts the process that EPA will likely use to designate PFOA and PFOS as “hazardous substances,” how that designation will impact responsible parties, and
Continue Reading Impact of “Hazardous Substance” CERCLA Designation on State Superfund Laws
Adam H. Cutler
Potential Impact PFOA and PFOS Designation as “Hazardous Substance” on Ongoing EPA-lead Investigations and Remediations
By Adam H. Cutler & Robert J. Schena on
In two of our previous posts, we discussed the United States Environmental Protection Agency’s (EPA) “Hazardous Substance” Designation Process and the Implications of a Designation on Responsible Parties. Here,…
Continue Reading Potential Impact PFOA and PFOS Designation as “Hazardous Substance” on Ongoing EPA-lead Investigations and Remediations
Implications of EPA Designation of PFOA and PFOS as “Hazardous Substances”
By Adam H. Cutler & Robert J. Schena on
The Biden Administration has pledged to designate certain PFAS as hazardous substances under federal law. What effect would the United States Environmental Protection Agency’s (EPA) designation of PFOA and PFOS…
Continue Reading Implications of EPA Designation of PFOA and PFOS as “Hazardous Substances”
State PFAS Enforcement Against the Federal Government – Irresistible Force Meets Immovable Object?
By Adam H. Cutler on
In September 2020, the New Mexico Environment Department (NMED) finalized the settlement of an enforcement action against Cannon Air Force Base (CAFB), a federal facility, relating to the facility’s discharge…
Continue Reading State PFAS Enforcement Against the Federal Government – Irresistible Force Meets Immovable Object?
Your Mission, Should You Choose to Accept It…: The “Innovative Ways to Destroy PFAS Challenge”
By Adam H. Cutler on
In July 2020, we posted on takeback disposal options for some PFAS-containing firefighting foams, with a caveat about recent actions taken by the New York State Department of Environmental Conservation…
Continue Reading Your Mission, Should You Choose to Accept It…: The “Innovative Ways to Destroy PFAS Challenge”
State AFFF takeback programs may provide appropriate disposal options for local authorities and other users of older PFAS-containing foams
By Adam H. Cutler on
As more states develop regulatory standards for PFAS, many are also recognizing that certain formulations of firefighting foams that were manufactured into the early 2000s or earlier contain legacy PFAS…
Continue Reading State AFFF takeback programs may provide appropriate disposal options for local authorities and other users of older PFAS-containing foams
NJDEP Issues Final Rule Regulating PFOA and PFOS
By Adam H. Cutler on
On June 1, 2020, NJDEP published its final rule (52 N.J.R. 1165(b)) setting drinking water standards, also known as maximum contaminant levels or “MCLs,” and final groundwater standards for the…
Continue Reading NJDEP Issues Final Rule Regulating PFOA and PFOS
EPA Releases 2019 Year in Review, Including Summary of PFAS Actions
By Adam H. Cutler on
Earlier this year, the EPA put out its annual Year in Review, summarizing its major accomplishments for 2019 across the full breadth of the agency’s program activities. With respect…
Continue Reading EPA Releases 2019 Year in Review, Including Summary of PFAS Actions
Update on NJDEP Issuance of Final Drinking Water and Groundwater Cleanup Standards for PFOA and PFOS, Addition of PFOA and PFOS to Its List of Hazardous Substances, and Amendment of Other Rules Related to PFOA, PFOS and PFNA
By Adam H. Cutler & Robert J. Schena on
Updating our previous post, as of the April 6, 2020 issue of the New Jersey Register, NJDEP has not yet published its anticipated Final Rule setting drinking water and groundwater…
Continue Reading Update on NJDEP Issuance of Final Drinking Water and Groundwater Cleanup Standards for PFOA and PFOS, Addition of PFOA and PFOS to Its List of Hazardous Substances, and Amendment of Other Rules Related to PFOA, PFOS and PFNA
UPDATED 4/6/2020: NJDEP Issuing Final Drinking Water and Groundwater Cleanup Standards for PFOA and PFOS; Adding PFOA and PFOS to Its List of Hazardous Substances; and Amending Other Rules Related to PFOA, PFOS and PFNA
By Adam H. Cutler & Robert J. Schena on
Consistent with a Proposed Rule published on April 1, 2019, NJDEP will publish a Final Rule in the New Jersey Register (possibly as soon as April 6, 2020) [UPDATED …
Continue Reading UPDATED 4/6/2020: NJDEP Issuing Final Drinking Water and Groundwater Cleanup Standards for PFOA and PFOS; Adding PFOA and PFOS to Its List of Hazardous Substances; and Amending Other Rules Related to PFOA, PFOS and PFNA