PFAS Superfund Designation: EPA’s Latest Step Starts 90 Day Clock

On January 10, 2022, the EPA submitted a plan for a PFAS Superfund designation to the White House Office of Management and Budget (OMB) when it indicated an intent to designate two legacy PFAS – PFOA and PFOS – as “hazardous substances” under the Comprehensive Environmental Response, Compensation & Liability Act (CERCLA, also known as the Superfund […]

EPA Announces Plans for Waste Rules That Could be a Stepping Stone to Drastically Expanding PFAS Liabilities

Vinson & Elkins LLP EPA announced plans for two separate rulemaking processes that would expand liabilities for PFAS wastes. The first — a rulemaking process to add certain PFAS chemicals as “hazardous constituents” under the Resource Conservation and Recovery Act (“RCRA”) expands remedial obligations to include PFAS at RCRA corrective action sites and could be […]