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Weekly Update Volume 39, Issue 24

08/24/2009

LITIGATION

CERCLA, UNILATERAL ADMINISTRATIVE ORDERS:



The Ninth Circuit upheld the dismissal of a hazardous waste site operator's lawsuit challenging EPA's administration of unilateral administrative orders (UAOs) under CERCLA. The operator, which characterized UAOs as "emergency orders," alleged that EPA "routinely" issues emergency orders "where no conceivable emergency exists." It therefore sought a judicial declaration that EPA's "pattern and practice" in administering CERCLA UAOs is unconstitutional. The operator has standing to challenge the validity of the UAO to which it is subject because, assuming that its allegations are correct and EPA issued the order ultra vires, the operator has suffered concrete and particularized harm and seeks to litigate its own rights. But, because of CERCLA §113(h)'s limitation on the timing of judicial review, the operator must await completion of the work required by the UAO to bring its individual challenge. As to its challenge to all other UAOs, the operator plainly lacks standing. Even if EPA issued improper orders to other entities at other sites, the operator suffered no concrete and particularized harm as a result and, in any event, it lacks prudential standing to litigate the rights of those third parties. The operator cannot evade the "timing of review" limitation on a substantive challenge to its order simply by asserting that other orders, too, might suffer from a similar alleged substantive flaw. The operator also alleged that EPA refused to certify completion of the work required by UAOs so as to delay judicial review. But this claim is not ripe because the feared harm has not yet been realized. As soon as the operator believes that it has completed the UAO work it is required to perform, it can petition EPA for reimbursement and, if EPA refuses, bring an action in federal court. City of Rialto v. West Coast Loading Corp., No. 08-55474, 39 ELR 20184 (9th Cir. Aug. 14, 2009).


CERCLA, REMEDIATION:



The Eighth Circuit affirmed a lower court order holding that a company substantially complied with a state's remediation plan for cleaning up PCB contamination at a hazardous waste site. The company's predecessor-in-interest operated an electrical transformer repair facility on the subject property, which led to significant PCB contamination. The company was held liable under CERCLA and the Minnesota Environmental Response and Liability Act and ordered to clean up the contamination. Roughly 10 years later, the lower court modified the underlying injunction, finding that no further relief was necessary. The lower court did not err in finding that no further relief was necessary since there was substantial evidence that the company completed the remediation plan required by the state. In addition, the lower court properly denied the current property owner's motion to increase the bond posted by the defendant-company to cover the cost of future remediation since the motion was untimely. But the court remanded the order for clarification and/or reconsideration of the owner's motion for $59,448.61 in response costs. Kennedy Building Associates v. CBS Corp., No. 07-3622, 39 ELR 20186 (8th Cir. Aug. 18, 2009).


WATER POLLUTION, STANDING:



The Seventh Circuit held that an environmental group lacks standing in their action against several government agencies for allowing the discharge of bullets into Lake Michigan at a U.S.-operated gun range. The group alleged that the deterioration of the lead bullets in the water harmed the environment in violation of the CWA, RCRA, CERCLA, and state nuisance law. Individual members' concern over drinking water did not provide standing because the drinking water in the area was below the environmental limit on lead pollution allowed by the city government, thereby negating any claim of harm. And their concerns over birds, fish, and wildlife were too general and did not allege any particular or specific harm that had been caused by the bullets. Because the individual members did not possess standing, the group did not possess standing on their behalf. Accordingly, the lower court properly dismissed the suit for lack of subject matter jurisdiction. Pollack v. United States Department of Justice, No. 08-3857, 39 ELR 20183 (7th Cir. Aug. 13, 2009).


NEPA, INJUNCTIONS:



The Ninth Circuit reversed a lower court decision denying environmental groups' motion to preliminarily enjoin three logging projects in the Plumas National Forest in California. The U.S. Forest Service issued the contracts in its attempt to fund fire prevention activities. Among other claims, the groups argued that the Service violated NEPA by failing to consider a reasonable range of alternatives before adopting its "2004 Framework," an amendment to the forest plans governing California's Sierra Nevada region, including Plumas. The groups sought a preliminary injunction that would allow the three logging projects to proceed only to the extent they are consistent with the Service's 2001 Framework. The lower court denied the injunction, and this court reversed based on its finding that the groups demonstrated a likelihood of success on the merits of their NEPA claim. Since then, however, the U.S. Supreme Court issued its decision Winter v. Natural Resources Defense Council, Inc., 129 S. Ct. 365, 39 ELR 20279 (2008). This decision requires the court to revisit its holding with respect to the factors governing preliminary relief other than likelihood of success on the merits—irreparable harm, balancing of equities, and the public interest. The court, therefore, modified its earlier opinion and remanded the case so the lower court can assess these non-merits factors in the context of the narrow injunction the groups requested—to halt the three site-specific projects only to the extent they are inconsistent with the 2001 Framework. Sierra Forest Legacy v. Rey, No. 07-16892, 39 ELR 20182 (9th Cir. Aug. 13, 2009).


INJUNCTIONS, MOOTNESS:



The Eighth Circuit affirmed a lower court decision holding moot certain parts of a 1975 injunction regulating air emissions from a mining company's taconite pellet operation in Silver Bay, Minnesota. The lower court held that since portions of the injunction had been effectively incorporated into state administrative law, those portions of the injunction no longer had any force or effect. It therefore vacated the air-emissions provisions from the injunction sua sponte. The state appealed, but it failed to show how the lower court abused its discretion by vacating the air-emissions provisions, particularly since the state's air permitting regulations and the injunction contain identical language. Similarly, the state failed to show that the mining company is likely to repeat its violation in the absence of the injunction. The court also dismissed the mining company's appeal and the federal government's cross-appeal since they were not aggrieved parties. The order granted the mining company all of the relief that it sought, and the federal government's interests were not affected since its interests in the injunction extended only to water-emissions provisions, not air emissions provisions. United States v. Northshore Mining Co., Nos. 08-1423, -1533, 39 ELR 20185 (8th Cir. Aug. 17, 2009).


CALIFORNIA ENVIRONMENTAL QUALITY ACT:



A California appellate court upheld a lower court decision denying a city's petition to overturn a school district's final environmental impact report (FEIR) for a high school construction project. The city argued that the school district failed to provide adequate detail and analysis sufficient to enable meaningful consideration of the environmental issues raised by the proposed project in violation of the California Environmental Quality Act (CEQA). But the FEIR adequately analyzed the challenged impacts of the project and undertook a meaningful analysis of alternatives. Accordingly, the district complied with CEQA. Long Beach v. Los Angeles Unified School District, No. B207721, 39 ELR 20187 (Cal. App. 2d Dist. July 16, 2009).


Copyright© 2009, Environmental Law Institute, Washington, D.C. All rights reserved.


THE FEDERAL AGENCIES

Note: Citations below are to the Federal Register (FR).


AIR:



  • EPA updated the outer continental shelf air regulations for the Santa Barbara County air pollution control district in California. 74 FR 42175 (8/21/09).

  • SIP Approvals: Arizona (stay and deferral of sanctions for Pinal County) 74 FR 41340 (8/17/09). Michigan (abbreviated Clean Air Interstate Rule (CAIR) SIP) 74 FR 41637 (8/18/09).

  • SIP Proposals: Arizona (particulate matter emissions from construction and related activities and unpaved parking lots) 74 FR 41347 (8/17/09). California (basic and enhanced vehicle inspection and maintenance program) 74 FR 41818 (8/19/09); (volatile organic compound and nitrogen oxide emissions for the San Joaquin Valley unified air pollution control district) 74 FR 41826 (8/19/09); (withdrawal and replacement of rule proposed July 14, 2009, for the San Joaquin Valley unified air pollution control district) 74 FR 41829 (8/19/09). Maryland (CAIR SIP) 74 FR 42038 (8/20/09). Michigan (abbreviated CAIR SIP; see above for direct final rule) 74 FR 41648 (8/18/09).

ENERGY:



  • EPA announced availability of expert peer review of proposed revisions to the national renewable fuel standard program. 74 FR 41359 (8/17/09).

HAZARDOUS & SOLID WASTE:



  • EPA entered into a proposed administrative settlement under CERCLA that requires the settling party to pay $160,000 in U.S. response costs incurred at the Jones Road Ground Water Plume Superfund site in Houston, Texas. 74 FR 42301 (8/21/09).

  • EPA entered into a proposed de minimis administrative agreement under CERCLA that requires 291 settling parties to pay a total of $3,743,361.69 for past and future U.S. cleanup costs incurred at the Mercury Refining Superfund site in the towns of Colonie and Guilderland, New York. 74 FR 42301 (8/21/09).

WATER:



  • EPA Region 6 announced the availability of 12 TMDLs and calculations for the Atchafalaya River and the Mississippi River Basins of Louisiana. 74 FR 42068 (8/20/09).

  • EPA announced the availability of its proposed decisions identifying water quality limited segments in Arizona and their associated pollutants to be listed under CWA §303(d)(2); the Agency requests public comment. 74 FR 42069 (8/20/09).

  • EPA determined that adequate facilities for the safe and sanitary removal and treatment of sewage from all vessels are reasonably available for the Broad Creek, Jackson Creek, and Fishing Bay Watersheds in Middlesex County, Virginia. 74 FR 42070 (8/20/09).

  • EPA and NOAA approved New Jersey's coastal nonpoint source pollution control program and invited public comment. 74 FR 41864 (8/19/09).

WILDLIFE:



  • FWS, NOAA, and USDA announced that a National Aquatic Animal Health Plan for the United States is being made available for public review and comment. 74 FR 42225 (8/21/09).

  • FWS announced a 12-month finding on a petition to list the ashy storm-petrel as threatened or endangered under the ESA; the Agency found that listing is not warranted. 74 FR 41832 (8/19/09).

  • FWS, acting on a petition to list 206 species in the mountain-prairie region of the United States as threatened or endangered under the ESA, announced its 90-day finding on 38 of those species; the Agency found that listing nine of the species may be warranted and initiated a status review of the remaining 29 species to determine if listing is warranted. 74 FR 41649 (8/18/09).

  • FWS proposed to designate approximately 74,223 acres in Sonoma County, California, as critical habitat for the distinct population segment of the California tiger salamander. 74 FR 41662 (8/18/09).

DOJ NOTICES OF SETTLEMENT:



  • United States v. City of Portsmouth, No. 1:09-cv-283 (D.N.H. Aug. 17, 2009). A settling CWA defendant must control discharges from its combined sewer overflows and wastewater treatment facility, must propose a schedule for construction of a secondary wastewater treatment facility, and must comply with the construction schedule for violations of an NPDES permit. 74 FR 42326 (8/21/09).

  • United States v. Waste Management of Wisconsin, Inc., No. 09-cv-0135 (E.D. Wis. Aug. 17, 2009). Settling CERCLA defendants must pay $1,000 and pursue insurance proceeds to reimburse U.S. costs incurred at the Watertown Tire Fire site in Watertown, Wisconsin. 74 FR 42326 (8/21/09).

  • United States v. City of Newburgh, No. 08 Civ. 7378 (SCR) (S.D.N.Y. Aug. 17, 2009). Under a modified consent decree, an additional 58 CERCLA defendants must pay $426,220 to the United States for contamination at the Consolidated Iron and Metal Company Superfund site in Newburgh, New York. 74 FR 42327 (8/21/09).

  • United States v. Magellan Ammonia Pipeline, No. 02:09-cv-2425 (D. Kan. Aug. 14, 2009). Settling CWA and CERCLA defendants must pay $3,650,000 in penalties to the United States for the discharge and inadequate reporting of anhydrous ammonia from a pipeline in Blair, Nebraska, and Kingman, Kansas, and must undertake injunctive measures to prevent a recurrence. 74 FR 42111 (8/20/09).

  • United States v. Ohio Edison Co., No. C2-99-1181 (S.D. Ohio Aug. 11, 2009). Under a modified 2005 consent decree, a settling CAA defendant must repower one of its coal-fired power plants near Shadyside, Ohio, using primarily renewable biomass fuel. 74 FR 41455 (8/17/09).

Copyright© 2009, Environmental Law Institute, Washington, D.C. All rights reserved.


THE CONGRESS
Congress is currently in recess but will reconvene on September 8, 2009.

 


Copyright© 2009, Environmental Law Institute, Washington, D.C. All rights reserved.


IN THE STATES

Note: The entries below cover state developments since the last issue of Update. The entries are arranged by state, and within each section, entries are further subdivided by subject matter area. To access material previously reported in 2009, visit our list of Cumulative State Developments. For state material reported prior to 2009, visit the ELR Archives.


The states below have updates this week:

















Montana New Jersey Pennsylvania
Nebraska New York South Carolina
Nevada North Carolina Utah
New Hampshire Ohio Washington

MONTANA


Hazardous & Solid Waste:



  • The Department of Environmental Quality will hold a public hearing on proposed amendments to Mont. Admin. RR. 17.50.403, 17.50.410, 17.50.501 through 17.50.503, 17.50.508, 17.50.509, and 17.50.513; and the repeal of Mont. Admin. RR. 17.50.505, 17.50.506, 17.50.510, 17.50.511, 17.50.526, 17.50.530, 17.50.531, 17.50.542, 17.50.701, 17.50.702, 17.50.705 through 17.50.710, 17.50.715, 17.50.716, and 17.50.720 through 17.50.726, pertaining to the licensing and operation of solid waste landfill facilities. The hearing will be November 4, 2009. See http://deq.mt.gov/dir/legal/Notices/17-284Apro.pdf

Water:



  • The Department of Environmental Quality will hold a public hearing on proposed amendments to Mont. Admin. RR. 17.38.101, 17.38.208, 17.38.225, 17.38.229, 17.38.231, and 17.38.513, pertaining to plans for public water or wastewater systems, treatment requirements, control tests, microbial treatment, sanitary surveys, and chemical treatment of water; the adoption of New Rules I through IV, pertaining to ground water, initial distribution system evaluations, stage 2 disinfection byproducts requirements, and enhanced treatment for cryptosporidium; and the repeal of Mont. Admin. RR. 17.38.701 through 17.38.703, pertaining to licenses--private water supplies, disposal of excrement, and barnyards and stockpens. The hearing will be September 3, 2009. See http://deq.mt.gov/dir/legal/Notices/17-291pro.pdf

  • The Department of Environmental Quality will hold a public hearing on proposed amendments to Mont. Admin. RR. 17.30.201, pertaining to permit fees. The hearing will be September 3, 2009. See http://deq.mt.gov/dir/legal/Notices/17-290pro.pdf

  • The Department of Environmental Quality seeks public comment on proposed amendments to Mont. Admin. RR. 17.30.617 and 17.30.638, pertaining to outstanding resource water designation for the Gallatin River. Comments are due November 20, 2009. See http://deq.mt.gov/dir/legal/Notices/17-276Bpro.pdf

NEBRASKA


Hazardous & Solid Waste:



Toxic Substances:



  • The Department of Environmental Quality will hold a public hearing on proposed amendments to 198 Neb. Admin. Code §003, relating to pesticide application. The amendments would require that when pesticides are loaded on a fixed-wing aircraft for application, the loading will take place on a load-out pad. The hearing will be September 17, 2009. See http://www.sos.ne.gov/rules-and-regs/regtrack/details.cgi?proposal_id=0000000000000762

NEVADA


Air:



NEW HAMPSHIRE


Water:



NEW JERSEY


Water:



  • The Department of Environmental Protection adopted amendments to N.J. Admin. Code §7:7A-16, Freshwater Wetlands Protection Act. The amendments increase the maximum penalty from $10,000 to $25,000, lengthen the time in which a person may request a hearing to challenge an administrative enforcement action, and include the alleged violator's conduct as a basis for assessing a penalty (in addition to violation type, seriousness, and duration). See http://www.nj.gov/dep/rules/adoptions/adopt_090817a.pdf

NEW YORK


Toxic Substances:



  • The Department of Environmental Conservation seeks public comment on proposed amendments to N.Y. Comp. Codes R. & Regs. tit. 6, §325.7, Pesticide Applicator Certification and Direct Supervision Requirements. The amendments would exempt persons authorized to apply 100% corn oil to bird eggs from pesticide applicator certification requirements. Comments are due September 28, 2009. See http://www.dec.ny.gov/regulations/34113.html#part325sect7

Water:



  • The Delaware River Basin Commission, a federal-state regional agency, will hold a public hearing on proposed amendments to the Commission's Water Quality Regulations, Water Code and Comprehensive Plan. The amendments would revise the human health water quality criteria for PCBs in the Delaware Estuary, extend application of the Commission's PCB human health water quality criterion to Delaware Bay, and provide for the use of compliance schedules where implementation of a stream quality objective established by the Commission requires a reduction of the pollutant concentration or loading of a discharge to Basin waters. The hearing will be October 8, 2009. See http://www.dos.state.ny.us/info/register/2009/aug19/pdfs/rules.pdf (pp. 3-5)

NORTH CAROLINA


Air:



  • The Department of Environment and Natural Resources will hold a public hearing on proposed amendments to 15A N.C. Admin. Code 02D.0408, Lead; 15A N.C. Admin. Code 02D.0540, Particulates From Fugitive Dust Emission Sources; 15A N.C. Admin. Code 02D.1104, Toxic Air Pollutant Guidelines; and 15 N.C. Admin. Code 02Q.0711, Emission Rates Requiring a Permit. The amendments would update the ambient air quality standard for lead to reflect the federal revisions to the lead NAAQS, remove the phrase "from process operations" from the definition of fugitive dust emissions, remove the annual Acceptable Ambient Level (AAL), and add daily and hourly AALs for Acrylonitrile. The hearing will be September 23, 2009. See http://www.ncoah.com/rules/register/Volume24Issue04August172009.pdf (pp. 161-69)

OHIO


Water:



  • The Ohio Environmental Protection Agency will hold a public hearing on proposed amendments on Ohio Admin. Code 3745:1-05, Antidegradation; and Ohio Admin. Code 3745:1-07, Water Use Designations and Statewide Criteria. The proposed changes will revise the definitions of the recreation use designations, remove fecal coliform water quality criteria, and revise E. coli water quality criteria. The hearing will be September 10, 2009. See http://www.registerofohio.state.oh.us/pdfs/phn/3745_NO_84059_20090806_1300.pdf

  • The Ohio Environmental Protection Agency will hold a public hearing on proposed amendments on Ohio Admin. Code 3745:91-02, Application for Approval of Plans; Ohio Admin. Code 3745:91-03, Requirements for Plan Drawings; and Ohio Admin. Code 3745:91-08, Procedure for Approval. The amendments establish requirements for plan drawings and procedures for plan approval or modification. The hearing will be September 15, 2009. See http://www.registerofohio.state.oh.us/pdfs/phn/3745_NO_84860_20090813_0957.pdf

PENNSYLVANIA


Air:



  • The Department of Environmental Protection will hold public hearings on proposed revisions to Pennsylvania's SIP. The changes would incorporate the Diesel-Powered Motor Vehicle Idling Act. The hearings will be September 17 and 18, 2009. See http://www.pabulletin.com/secure/data/vol39/39-33/1472.html

Water:



  • The Delaware River Basin Commission, a federal-state regional agency, will hold a public hearing on proposed amendments to the Commission's Water Quality Regulations, Water Code and Comprehensive Plan. The amendments would revise the human health water quality criteria for PCBs in the Delaware Estuary, extend application of the Commission's PCB human health water quality criterion to Delaware Bay, and provide for the use of compliance schedules where implementation of a stream quality objective established by the Commission requires a reduction of the pollutant concentration or loading of a discharge to Basin waters. The hearing will be October 8, 2009. See http://www.pabulletin.com/secure/data/vol39/39-33/1459.html

  • The Department of Environmental Protection has extended the Pennsylvania NPDES Stormwater Discharges From Municipal Storm Sewer Systems General Permit (PAG-13). The general permit will now expire on March 9, 2011. See http://www.pabulletin.com/secure/data/vol39/39-33/1470.html

  • The Department of Environmental Protection seeks public comment on proposed revisions to the NPDES General Permit for Stormwater Discharges Associated With Construction Activities. The changes would renew the permit for five years. Comments are due September 14, 2009. See http://www.pabulletin.com/secure/data/vol39/39-33/1473.html

SOUTH CAROLINA


Air:



UTAH


Water:



WASHINGTON


Water:



  • The Department of Ecology adopted emergency rules at Wash. Admin. Code 173-539A, Upper Kittitas Emergency Ground Water Rule. The rule establishes a partial withdrawal of groundwater within a portion of Kittitas County, Washington. The partial withdrawal and restrictions are designed to prevent new uses of water that negatively affect flows in the Yakima River and its tributaries. The withdrawal allows for continued development using the groundwater exemption or new permits when the new consumptive use is mitigated by one or more pre-1905 water rights held by Ecology in the trust water right program of equal or greater consumptive quantity. See http://apps.leg.wa.gov/documents/laws/wsr/2009/16/09-16-075.htm

Copyright© 2009, Environmental Law Institute, Washington, D.C. All rights reserved.


INTERNATIONAL

CHINA'S "CANCER VILLAGES" HEAVILY POLLUTED


Located just downstream from three steel factories, a paper mill, and a bone-processing plant, the citizens of Xiadian have grown used to seeing the Baoqiu River turn red, yellow, and sometimes white from what they say is untreated industrial wastewater. The town also has seen at least 50 of its 3,000 residents die of cancer in the past five years; an unknown number of others are being treated for cancer or other pollution-related diseases. Xiadian is one of dozens of places in China that local media have dubbed "cancer villages." Cancers of the liver, stomach, and lung and leukemia are all showing up in these villages at rates environmental activists say are above average. The situation brings into sharp focus the problems of rural communities where environmental protection is less stringent than in major cities such as Beijing. After years of heavy pollution, the big cities are increasingly pushing their heavy industry to rural areas and away from their more middle-class and environmentally conscious residents. Acknowledging the problems, China's Ministry of Environmental Protection said last month that it would release $134 million from a special fund to help build wastewater and sewage treatment facilities and ensure safe drinking water in villages throughout the country. For the full story, see http://www.washingtontimes.com/news/2009/aug/16/cancer-villages-in-rural-china-heavily-polluted/

CLIMATE CHANGE ADAPTATION AND MITIGATION COSTS ESTIMATED AT $300 BILLION ANNUALLY


With 110 days left until the Copenhagen Climate Conference, only "limited progress" was made at the most recent United Nations climate change talks where financing to cut and cope with climate change proved to be a major sticking point among negotiators. Speaking at the meeting, Yvo de Boer, head of the UN Climate Change Secretariat, said, "The world will need a phenomenal amount of money to change its energy supply from fossil fuels to cleaner sources and to adapt to climate change." De Boer estimates the annual cost of climate change adaptation at US$100 billion per year. This is the amount needed to cope with natural disasters such as flooding and drought that will result from increased warming. Meanwhile, he pegs the cost of cutting global emissions at US$200 billion annually. Currently, the draft text contains 200 brackets indicating points of disagreement between negotiators, who differ on who should bear the financial burden of the climate change challenge. Nevertheless, De Boer stressed that a UN climate pact to be agreed upon in Copenhagen should set up a fair mechanism for raising long-term funds rather than compel countries to contribute specific amount. "A robust burden-sharing formula is the most important thing." For the full story, see http://www.unep.org/Documents.Multilingual/Default.asp?DocumentID=594&ArticleID=6270&l=en

MAJOR EU POWER PLANT INVESTS TO CUT EMISSIONS


The European Union's biggest polluter, a lignite-fired power plant in Belchatow, Poland, will need to buy up to 20 million tons of carbon dioxide (CO2) emission permits by 2013, its chief Jacek Kaczorowski told Reuters on Friday. Belchatow released the equivalent of nearly 31 million tons of CO2 into the atmosphere last year, topping by 4 million tons its EU-set ceiling as part of the bloc's attempts to curb global warming. Despite the global economic crisis, which has significantly curbed demand for power and led to fewer polluting emissions, Belchatow will still see a big deficit in carbon permits it needs in the next few years. "Our emissions in coming years of the 2008-2012 accounting period will stand at similar levels. So at the end of the whole period, we will be short some 14-20 million tonnes of CO2 permits," Kaczorowski said. "And this is what we are interested in buying." To avoid huge costs in the future, Belchatow is working on Poland's first carbon capture and storage (CCS) installation and plans more investments to limit greenhouse gas emissions. The European Commission has earmarked 180 million euros for the CCS, but still has two months before a final decision. For the full story, see http://www.reuters.com/article/GCA-GreenBusiness/idUSTRE57K1QA20090821

Copyright© 2009, Environmental Law Institute, Washington, D.C. All rights reserved.


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