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McLouth Steel Prods. Corp. v. Thomas

ELR Citation: ELR 20473
Nos. No. 87-1049, 838 F.2d 1317/27 ERC 1288/(D.C. Cir., 02/09/1988)

The court holds that the Environmental Protection Agency's (EPA's) vertical and horizontal spread (VHS) model, used to predict the probable contamination levels of hazardous substances under the Resource Conservation and Recovery Act, constitutes a rule requiring public notice and comment under the Administrative Procedure ACT (APA)....

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