Last week EPA released its proposal for the first set of Maximum Contaminant Levels (MCLs) under the Clean Water Act for per- and polyfluoroalkyl substances (PFAS). In contrast to non-enforceable health advisory levels introduced in 2016 and revised in 2022, MCLs constitute enforceable drinking water standards that will impact drinking water utilities and industry nationwide.
Emilee Mooney Scott
I am a Partner in the Environmental, Energy + Telecommunications Group. My practice focuses on assisting clients in complying with federal and state environmental laws, with a particular focus on the management of hazardous and toxic substances, especially under the Toxic Substances Control Act an the Emergency Planning and Community Right-to-Know Act. I also regularly help clients understand, manage, and limit environmental risk associated with business and property transactions, including assisting clients in complying with transaction-triggered compliance requirements like the Connecticut Transfer Act. My full bio is here.
EPA Proposes to Designate PFOS and PFOA as CERCLA Hazardous Substances
Last week, the U.S. Environmental Protection Agency (EPA) released a pre-publication version of a Proposed Rule to designate PFOA and PFOS as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund). This marks the next step in a trend of increasing regulation of per- and polyfluoroalkyl substances (PFAS), a class…
Changes to PCB Remediation Expected Under Proposed Rule
On October 22, 2021, EPA published a proposed rule that would, if adopted, provide a significantly enhanced additional pathway for remediation of sites impacted by polychlorinated biphenyls or PCBs. EPA helpfully included a redline version showing proposed changes to the regulatory text. EPA is receiving comments on the proposed rule until December 21, 2021.