This year is sure to bring a number of significant changes in
the areas of waste management and cleanup, vapor intrusion, due
diligence and issues related to real estate purchases.
Waste Management and Cleanup
Coal combustion residuals (CCR): The tumultuous
four-year journey to the adoption of a federal coal combustion
residuals (CCR) regulation came to an end in late December when the
U.S. Environmental Protection Agency (EPA), pursuant to a court
order, issued its final regulation. This guarantees that 2015 will
be a year filled with uncertainty as to its interpretation,
concerns over who will enforce it and legal challenges to it on a
number of grounds.
The greatest uncertainty concerns the fact that EPA views this
as a "self-implementing" rule, which establishes
standards and deadlines for closure, assessment and corrective
action at existing ponds and landfills, and location and design
requirements for new ones. However, there are no provisions
