On May 12, 2016, the EPA proposed a rule (RIN 2060-AN36) which would remove the exemption for site cleanup activities under the hazardous waste statutes from the emissions standards for hazardous air pollutants under the Clean Air Act.  The proposed rule would amend the National Emission Standards for Hazardous Air Pollutants (“NESHAP”), Site Remediation Rule, to include activities taken under CERCLA and RCRA, as well as RCRA corrective actions and orders. Under the amended rule, the NESHAP permitting requirements would apply to site activities that involve the removal and treatment of hazardous substances from soil or groundwater, the removal of… Read more