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ARTICLE · 23 FEBRUARY 2024

EPA Proposes RCRA Corrective Action Expansions Targeting PFAS

Holland & Knight
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The 1984 Hazardous and Solid Waste Amendments amended the Resource Conservation and Recovery Act (RCRA) to add the following sections requiring corrective action for releases...

United StatesEnvironment
Dianne Phillips
Dianne Phillips
Meaghan Hembree
Meaghan Hembree
Molly Broughton
Molly Broughton
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Highlights

  • The U.S. Environmental Protection Agency (EPA) is proposing to amend the Resource Conservation and Recovery Act (RCRA) definition of hazardous waste applicable to corrective action to include releases from solid waste management units that are not explicitly stated as hazardous waste but meet the statutory definition.
  • Another proposed rule will list nine per- and polyfluoroalkyl substances (PFAS) compounds, their salts and structural isomers as hazardous constituents under the RCRA corrective action program.
  • This Holland & Knight alert examines the EPA's proposals and provides timelines for public comment.

The 1984 Hazardous and Solid Waste Amendments amended the Resource Conservation and Recovery Act (RCRA) to add the following sections requiring corrective action for releases of hazardous waste or hazardous constituents:

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