On February 28, 2024, the Food and Drug Administration (“FDA”) published a news release regarding the voluntary market phase-out of per and polyfluoroalkyl substances (PFAS) in grease-proofing substances used on food packaging. The FDA stated that the completion of this phase-out “eliminates the primary source of dietary exposure to PFAS from authorized food contact uses.”… Continue Reading
On January 25, 2018, Bill Wehrum, the new Assistant Administrator of US EPA’s Office of Air and Radiation, issued a memorandum to all Regional Air Division Directors rescinding US EPA’s historic “Once In Always In” (OIAI) policy for major sources under US EPA’s National Emission Standards for Hazardous Air Pollutants (NESHAP) program. Under the “Once In Always In” (OIAI) … Continue Reading
Generally, any physical change in or change in method of operation of an existing major stationary source that significantly increases emissions of any regulated New Source Review (NSR) air pollutant emitted will trigger NSR permitting review under the Clean Air Act as a major modification. However, air pollution control regulations also generally contain exclusions from the definition of major modification for … Continue Reading
On February 21, 2014, the Pennsylvania Supreme Court declined reconsideration of its December 19, 2013 decision striking down a number of provisions in the State’s 2011 hydraulic fracturing law known as Act 13. As we previously reported, the law made substantial changes to the state’s oil and gas laws, some of which the Court determined to be … Continue Reading
On August 23, 2013, environmental groups represented by Earthjustice alerted USEPA in a 60 day notice letter that the groups intend to sue the Agency for its alleged failure to comply with Clean Air Act (CAA) §112(d) and §112(f) by failing to revise maximum achievable control technology (MACT) standards for 46 source categories within eight … Continue Reading
Under the Clean Air Act’s New Source Review (NSR) / Prevention of Significant Deterioration (PSD) program, operators do not have to obtain a preconstruction permit before modifying an existing major source of air pollution as long as the modification does not result in a significant net emissions increase. In determining whether the modification will require NSR … Continue Reading
Manganese is a naturally occurring metal utilized in numerous processes including the manufacture of steel alloys and dry-cell batteries, for wastewater treatment, and as a paint pigment. Manganese emissions have also been associated with incineration of sewage sludge and medical waste, welding, and the wear of certain parts (e.g., brakes, tires and rail car wheels) … Continue Reading
