Thomas Brugato is an associate in the firm’s Washington, DC office. He focuses on litigation and environmental matters. He regularly advises clients on a wide variety of environmental matters, including under the Clean Air Act, Clean Water Act, and CERCLA.
EPA published today in the Federal Register its final rule governing hazardous waste pharmaceuticals. This rule adopts a novel scheme under the Resource Conservation and Recovery Act (“RCRA”) for the management of hazardous waste pharmaceuticals that are discarded by healthcare facilities or managed by “reverse” distributors. It also applies to other types of products such … Continue Reading
Despite its deregulatory efforts in other areas, the Trump administration continues to enforce pesticide laws rigorously as part of its stated goal of returning EPA to its “core mission.” EPA regulates pesticides pursuant to its authority under the Federal Insecticide, Fungicide, and Rodenticide Act (“FIFRA”), 7 U.S.C. § 136 et seq. “Pesticides” are broadly defined … Continue Reading
EPA has scheduled a stakeholder meeting in Washington, D.C. on June 11 to discuss its proposed nanoscale materials rule under the Toxic Substances Control Act (TSCA). The proposed rule would require manufacturers of nanoscale materials to provide EPA certain information, including health and safety-related information, regarding their nanoscale materials. Public comments are due by July … Continue Reading
EPA’s Environmental Appeals Board has rejected the Sierra Club’s attempt to require certain greenhouse gas (GHG) limits in a preconstruction permit for a new natural gas power plant, in one of the first EAB decisions to address this issue. In re: La Paloma Energy Center, LLC, PSD Appeal No. 13-10 (EAB Mar. 14, 2014). In … Continue Reading
EPA has formally proposed restrictions on carbon dioxide emissions from new power plants, which include a requirement that new fossil fuel-fired plants implement partial carbon capture and sequestration. EPA published the proposal in the Federal Register on January 8, 2014. 79 Fed. Reg. 1,430 (Jan. 8, 2014). Comments on the proposal are due by March … Continue Reading
On December 4 and 5, EPA’s Science Advisory Board (SAB) discussed whether to review the scientific basis for EPA’s requirement that new coal-fired power plants implement partial carbon capture and sequestration (CCS), which is included in EPA’s recently-proposed rule for such power plants. See Standards of Performance for Greenhouse Gas Emissions from New Stationary Sources: … Continue Reading