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Environmental
The Emergency Planning and Community Right-to-Know Act (EPCRA) was passed by Congress in 1986 in the aftermath of chemical accidents at Union Carbide plants in India and West Virginia. The Act requires companies to develop emergency plans and procedures in the event of industrial accidents and to inform local communities and state officials about the volume and nature of chemicals used at its facilities.
Waller Lansden’s environmental attorneys have extensive experience with a wide range of EPCRA issues. We have assisted clients with EPCRA applicability analysis and have obtained favorable applicability determinations from EPA. We have assisted various clients with filing Tier Two forms and Material Safety Data Sheets to comply with EPCRA Sections 311 and 312. We also have assisted clients with filing Toxic Release Inventory (TRI) forms to satisfy EPCRA Section 313 requirements.
Our firm has filed disclosures under EPA’s Audit Policy in various EPA regions on behalf of various clients for EPCRA nonreporting. We have obtained determinations from EPA that no fees or penalties will be assessed. We have also successfully defended EPCRA enforcement actions taken by EPA, and have assisted clients with penalty mitigation matters related to EPCRA reporting requirements.
Significant Matters
- Self-disclosure of multiple years of incomplete filings for TRI reporting with resulting determination of no penalty or further enforcement for client
- Assist clients in auditing chemical inventory at facilities to ensure accurate reporting
- Assist client in developing strategy to reduce volume of chemicals required to be reported in TRI as releases
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