February 25, 2019
The European Chemicals Agency (ECHA) has recommended that companies to prepare for a ‘no deal’ scenario ahead of the UK’s withdrawal on 30 March 2019.With continued political uncertainty regarding the withdrawal agreement, the Agency urges companies to act now to continue complying with their obligations under the REACH; Classification, Labelling and Packaging (CLP); Prior Informed Consent (PIC); and Biocidal Products (BPR) regulations.
To keep substances that are registered under REACH legally on the EU-27/EEA market, UK-based manufacturers and formulators can either transfer their business to, or appoint an only representative in, one of the EU-27/EEA countries. Subject to further developments, ECHA will open a ‘Brexit window’ in REACH-IT from 12 to 29 March, 24:00 hours CET (11 p.m. UK time) to enable UK-based companies to make these changes and transfer their REACH registrations. If an only representative is not appointed, the EU-27/EEA importers will have to submit their own registrations.
Step-by-step instructions for using the ‘Brexit window’ are now available on ECHA’s web pages for the UK’s withdrawal from the EU. The pages also include a link to the European Chemical Industry Council’s (Cefic) recommended standard wording for the suspensive conditional clause to be used in contractual arrangements when appointing only representatives.
If a downstream user in one of the EU-27/EEA countries relies on REACH authorizations granted to a UK-based company, they need to make sure that there is another EU-27/EEA supplier with a valid authorization for their use.
EU-27 companies will also need to notify their exports of hazardous substances regulated under the PIC Regulation when exporting to the UK. This will be done using the ePIC tool. The export notification in ePIC needs to be submitted 35 days before the export. ECHA will soon clarify how to deal with exports to the UK during the period right after the UK’s effective withdrawal.
Companies based in the EU-27/EEA will also need to prepare for placing substances on the UK market after 29 March, which will be governed by UK law. The UK Health and Safety Executive (HSE) has published respective guidance.
Further details, including a list of substances registered only by UK companies, are available on ECHA’s web pages for the UK’s withdrawal from the EU.
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A new report takes the largest tissue companies to task for destroying North American forests and exacerbating the world’s climate crisis. “The Issue with Tissue” reveals Procter & Gamble, Kimberly-Clark, and Georgia-Pacific use zero recycled content in their at-home toilet paper, instead relying on ancient trees clear-cut from the Canadian boreal forest (the “Amazon of the North”). The report by the Natural Resources Defense Council (NRDC) and Stand.earth includes a scorecard grading the sustainability of toilet paper and other tissue products. The average American uses three rolls of toilet paper a week—and major brands’ refusal to create more sustainable products makes consumers unwittingly complicit in flushing forests down the toilet.This destructive tree-to-toilet pipeline does massive harm to Indigenous Peoples and iconic species like the boreal caribou and Canada lynx. Canadas boreal forest also stores nearly two times as much carbon as is in all the worlds recoverable oil reserves combined. Toilet paper and tissue manufacturers continue to rely on forests even though they have the resources and means to create and deliver products with recycled and responsibly sourced content that are better for the planet.
The NRDC/Stand.earth report features a sustainability-based scorecard for at-home tissue brands, assigning F grades to such leading U.S. toilet paper brands as Charmin, Quilted Northern, and Angel Soft. Brands using recycled paper content, including 365, Seventh Generation, and Natural Value were among those awarded A grades in the report. The NRDC/Stand.earth scorecard also ranks facial tissues and paper towels.
Anthony Swift, director, Canada Project, NRDC, said: Most Americans probably do not know that the toilet paper they flush away comes from ancient forests, but clear-cutting those forests is costing the planet a great deal. Maintaining the Canadian boreal forest is vital to avoiding the worst impacts of climate change.
Charmin, the nation’s leading toilet paper brand, is specifically called out for refusing to increase its use of recycled materials.
Shelley Vinyard, report co-author and boreal corporate campaign manager, NRDC, said: Were calling on Procter & Gamble, as the maker of Americas leading toilet paper brand, to stop flushing forests down the toilet. Procter & Gamble has the innovation resources to bring Charmin into the 21st century; the question is whether the company will embrace its reputation as an innovator to create sustainable products using recycled material instead of clear-cut trees.
Deputy Grand Chief Mandy Gull, Cree Nation, said: "As Indigenous Peoples in the boreal forest, we live on the food from our land. The forest is our supermarket, with aisles of berries and meats and fish. My hope is that, once people know that their choice of tissue will determine whether food will be there for us tomorrow, they will help protect our homelands by switching to recycled and responsibly sourced products."
The Canadian boreal is a vast landscape of coniferous, birch, and aspen trees. It contains some of the last of the worlds remaining intact forests, and is home to over 600 Indigenous communities, as well as boreal caribou, pine marten, and billions of songbirds. The loss of intact boreal forest is impacting Indigenous Peoples ways of life and driving the decline of caribou and other species.
Tzeporah Berman, director, International Program, Stand.earth, said: “As a Canadian, I am horrified that Charmin and other leading brands are making toilet paper out of trees clearcut from ancient boreal forests. These forests are some of the most important intact ecosystems left on earth; they are the breeding grounds for the majority of North Americas songbirds and home to threatened species such as boreal caribouand; we are flushing them down the toilet?”
Fortunately, solutions to the tree-to-toilet pipeline already exist. Instead of relying on virgin fiber from ancient forests, tissue companies can use recycled content or sustainably sourced alternative fibers. Use of these materials to create tissue can dramatically reduce our destructive impact on the boreal and other forests in North America and around the world.
The NRDC/Stand.earth report revealed that the United States is a particularly voracious consumer of tissue products. The U.S. tissue market generates $31 billion in revenue every year, second only to China, and Americans, who make up just over 4% of the world’s population, account for over 20% of global tissue consumption.
NRDC and Stand.earth have called on Procter & Gamble and other toilet paper and tissue manufacturers to shift to recycled content and sustainable alternative fibers, and to take additional steps to ensure their supply chain is fully protective of boreal caribou habitat and respects Indigenous
EPA Has Released First Major Update to TSCA Inventory
EPA has released a required update of the Toxic Substances Control Act (TSCA) Inventory listing the chemicals that are actively being manufactured, processed and imported in the United States.A key result of the update is that less than half of the total number of chemicals on the current TSCA Inventory (47 percent or 40,655 of the 86,228 chemicals) are currently in commerce. As the result of a tremendous effort on behalf of thousands of stakeholders and manufacturers from across the country, this information will help EPA focus risk evaluation efforts on chemicals that are still on the market.
“It’s important for us to know which chemicals are actually in use today. This will help us with our work prioritizing chemicals, evaluating and addressing risks. This information also increases transparency to the public,” said Office of Chemical Safety and Pollution Prevention Assistant Administrator Alexandra Dapolito Dunn.
As recently as 2018, the TSCA Inventory showed over 86,000 chemicals available for commercial production and use in the U.S. Until this update, it was not known which of these chemicals on the TSCA Inventory were actually in commerce. Under amended TSCA – The Frank R. Lautenberg Chemical Safety for the 21 Century Act – EPA was required to update the list and designate which chemicals are active or inactive in U.S. commerce.
More than 80 percent (32,898) of the chemicals in commerce have identities that are not Confidential Business Information (CBI), increasing public access to additional information about them. For the less than 20 percent of the chemicals in commerce that have confidential identities, EPA is developing a rule outlining how the Agency will review and substantiate all CBI claims seeking to protect the specific chemical identities of substances on the confidential portion of the TSCA Inventory.
Under the TSCA reset, from August 11, 2017 through October 5, 2018, chemical manufacturers and processors were required to provide information on which chemicals were manufactured, imported or processed in the U.S. over the past ten years, the period ending June 21, 2016. The agency received more than 90,000 responses, which represents a significant reporting effort by manufacturers, importers and processors.
To download the public version of the initial TSCA Inventory, get more information about the TSCA Inventory Notification (Active-Inactive) Requirements rule, or requirements to notify EPA going forward: http://www.epa.gov/tsca-inventory.
New NDEQ After-Hours Phone Number for Emergency Notifications
There is a new phone number in effect for reaching the Nebraska Department of Environmental Quality after normal business hours, for those who are required to immediately report environmental spills, accidents or potential violations to the Department. The new number for after-hours notifications is 402-479-4921. This phone number replaces 402-471-4545. The number for reporting to the NDEQ during our normal business hours (Monday through Friday, 8 AM – 5 PM CST) continues to be 402-471-2186 or toll-free at 1 877-253-2603. Those calling these numbers after-hours, holidays and weekends will receive a recorded message advising them to call 402-479-4921 to immediately report spills, accidents or violations.
This change is in response to a recent upgrade in the Nebraska State Patrol (NSP) phone system.
The new number is a direct line to the NSP Dispatch Center in Lincoln. By calling this new number, you will remain able to reach NDEQ after-hours through the NSP when required to do so.
Pharmaceutical Residues in Fresh Water Pose a Growing Environmental Risk
Over the past 20 years, concentrations of pharmaceuticals have increased in freshwater sources all over the world, according to environmental experts at Radboud University. Levels of the antibiotic ciprofloxacin have reached the point of potentially causing damaging ecological effects. The research is the first to examine the risks of two particular medicines in global freshwater sources, and was published in Environmental Research Letters. “The study calls for more widespread data gathering to measure the problem around the world.”“Getting an accurate picture of the environmental risks of pharmaceuticals around the world depends on the availability of data, which is limited,” says Rik Oldenkamp, lead author of the article. “It's true that there are models, such as the ePiE model, which can give detailed predictions of pharmaceutical concentrations in the environment, but these are often only applicable to places where we already have a lot of information, such as rivers in Europe.”
The new model developed by the researchers, which builds on an existing model with a lower resolution, makes it possible to come up with worldwide predictions for individual ecoregions.
For the two pharmaceuticals investigated in the study – carbamazepine, an anti-epileptic drug, and ciprofloxacin, an antibiotic – the environmental risks were found to be 10 to 20 times higher in 2015 than in 1995. The increased human use of ciprofloxacin was found to have a particularly high impact globally.
“The concentrations of this antibiotic can be harmful for bacteria in the water, and these bacteria in turn play an important role in various nutrient cycles,” says Oldenkamp. “Antibiotics can also have a negative impact on the effectiveness of bacteria colonies used in wastewater treatment.”
Antibiotic resistance has been on the agenda of the World Health Organization (WHO) and United Nations General Assembly for a few years now. “Generally, it’s seen as a problem for the health sector, as resistant bacteria can be spread within hospitals or through livestock,” says Oldenkamp. “But there’s little awareness of the role of the environment in this problem, even though it becomes increasingly clear that the environment functions as a source of resistance for various pathogens.”
“Our model predicts a relatively high environmental risk for ecoregions in densely populated and dry areas such as the Middle East, yet those are precisely the areas where there is little data on pharmaceutical use and concentrations in surface waters,” says Oldenkamp. The researchers predicted human pharmaceutical consumption in these areas using regression models based on consumption in other countries, along with socio-economic and demographic information, and linked this to information related to other factors such as water sources and the number of people with access to wastewater treatment.
“Our model shows a particular need for new data in these types of areas,” says Oldenkamp. “The model is really a starting point for creating an insight into the environmental risks posed by pharmaceuticals all over the world.”
Carbon Dioxide Converted into a Useful Product
Carbon dioxide is a troublemaker. So it’s a good idea to remove it from power plant emissions — and it may have an extra economic benefit. Until now, carbon dioxide has been dumped in oceans or buried underground. Industry has been reluctant to implement carbon dioxide scrubbers in facilities due to cost and footprint.
What if we could not only capture carbon dioxide, but convert it into something useful? S. Komar Kawatra and his students have tackled that challenge, and they’re having some success. A team lead by Kawatra, a professor of chemical engineering at Michigan Technological University, his PhD students, Sriram Valluri and Victor Claremboux, and undergraduate Sam Root, have designed a carbon dioxide scrubber. They are working on converting the carbon dioxide they capture into oxalic acid, a naturally occurring chemical in many foods.
Oxalic acid is used by industry to leach rare earth elements from ore bodies. The rare earths are used in electronics such as cell phones. Rare earths are not presently produced in the United States; China produces 90 percent or more of the rare earths in the world. By producing oxalic acid domestically, it may be possible to profitably extract rare earth elements in the U.S., which is important for national security, Kawatra said.
The group installed their carbon dioxide scrubber at the Michigan Tech steam plant, where they are testing with real flue gas at pilot plant scale. The steam plant produces flue gas that contains eight percent carbon dioxide. The chemical engineers’ scrubber brought the emissions down to four percent and their goal is to reduce it below two percent.
“Below two percent, we are happy,” Kawatra said. “Below one percent, we will be very happy.”
It’s a real possibility. “We’ve already got it down to zero percent in the laboratory,” Valluri noted.
Undergrads work with graduate students to monitor the carbon dioxide scrubber.
In the steam plant, they tap a sample stream of flue gas from the boiler’s main exhaust line. The flue gas comes out of the burner at 300-350 degrees Fahrenheit. The sample is compressed through a filter that removes particles, then passes through a cooling unit before it enters the bottom of the scrubbing column.
A sodium carbonate solution is pumped into the top of the 11-foot-tall scrubbing column. The flue gas is bubbled up through the column. As it moves toward the top, the sodium carbonate or soda ash removes much of the carbon dioxide from the gas. Kawatra and his students monitor the amount of carbon dioxide constantly.
“The biggest challenge is a fluctuating ratio of gases in the flue gas,” Valluri said. Team member Root elaborated, “You need a cascade control system that measures the carbon dioxide and manipulates the amount of scrubbing solution accordingly.”
“Our next challenges are, how much can we scale the scrubber up and what can we use the carbon dioxide for,” Valluri said. This ties into Valluri’s and Claremboux’s other research project, the conversion of carbon dioxide to useful products. They have been able to produce oxalic acid from carbon dioxide at laboratory scale.
John Simmons, a Michigan Tech alumnus in the Chemical Engineering Academy at Tech and chairman of Carbontec Energy in Bismarck, North Dakota, is supporting Kawatra’s research. He says the savings to industry of this kind of carbon dioxide scrubber is enormous.
The usual method of removing carbon dioxide from emissions uses amines, nitrogen-based chemical compounds that bind the carbon dioxide. But amines cost $20,000 a ton, Simmons said. Carbonates like the soda ash that Kawatra’s team is using cost $200 a ton. Simmons is excited about the potential for producing a commercial product from the captured carbon dioxide. “I don’t think sequestering it in the ground is a good idea,” he said. “We have to find a way to utilize it commercially.”
The technology, trade-named the "Clearite VI Carbon Dioxide Capture/ Utilization Process," was patented (Patent No. US7,919,064B2 ) by the inventors, S. Komar Kawatra, Tim Eisele and John Simmons, and assigned to Michigan Tech. Carbontec Energy Corporation, the technology sponsor, is the exclusive worldwide licensee and plans to commercialize the technology through joint ventures and sub-licenses.
Simmons is pleased that Kawatra and his students are conducting a pilot plant study of their scrubber in Michigan Tech's natural gas fired steam plant. "It was important to test the process under actual emission conditions," he explained.
Kawatra is happy with the progress he and his students have made removing carbon dioxide from flue gas. And he’s excited about the prospect of creating a marketable product from it. “We want to find uses for it,” he said. “We want to help industry make money. We want to show that you can take harmful waste like carbon dioxide and make it produce a profit.”
Company Agrees to Huge Penalty for Refrigerant Releases
Trident Seafoods Corporation has agreed to reduce emissions of ozone-depleting substances from refrigeration equipment on its vessels, under a proposed settlement with the EPA and U.S. Department of Justice to resolve alleged violations of the Clean Air Act. Under the settlement, Trident will spend up to $23 million to reduce coolant leaks from refrigerators and other equipment, use alternative refrigerants, and improve company-wide compliance. The company will also pay a $900,000 civil penalty.“As a result of today’s settlement, Trident Seafoods will implement common-sense methods to reduce releases of ozone depleting refrigerants into the atmosphere,” said EPA Pacific Northwest Regional Administrator Chris Hladick. “With millions of pounds of refrigerants still in circulation in the U.S., it’s imperative that companies properly maintain and repair their appliances to ensure these don’t leak out and harm the ozone layer.”
Trident is one of the largest seafood processing companies in Alaska and the Pacific Northwest. Within its numerous fish catching and processing vessels, Trident uses thousands of pounds of ozone depleting substances as refrigerants. EPA alleged that Trident violated the Clean Air Act by failing to promptly repair leaks of the refrigerant R-22, an ozone-depleting hydrochlorofluorocarbon (HCFC). Trident’s failures allowed its appliances to leak refrigerant at high rates for thousands of days, causing over 200,000 pounds of harmful refrigerant to be released into the atmosphere.
Trident will retrofit or retire 23 refrigeration appliances used on 14 marine vessels to use an alternative refrigerant that does not harm the ozone layer compared to typical refrigerants. Trident agreed to retrofit nine of these appliances as part of a Supplemental Environmental Project. Because of these retrofits, nearly 100,000 pounds of harmful refrigerant will be removed from use, and future leaks will not damage the ozone layer.
Trident will also conduct routine leak inspections of all appliances, promptly repair leaks, install leak detectors to monitor appliances for leaks, add fluorescent dye into appliances to assist staff in detecting leaks, compile information to assist in identifying common failure points on appliances, and train employees to properly manage the appliances. In addition, the settlement sets a corporate-wide refrigerant leak cap and requires Trident to retain a 3rd-party auditor to review the company’s compliance with the consent decree and regulations.
The total estimated emission reductions from this settlement are equal to the amount from over 143,000 passenger vehicles driven in one year, the CO2 emissions from 734 million pounds of coal burned, or the carbon sequestered by over 790,000 acres of forests in one year.
The Clean Air Act’s National Recycling and Emission Reduction Program governs the management of ozone-depleting substances and implements the United States’ mandates under the 1991 Montreal Protocol on Substances that Deplete the Ozone Layer. EPA regulations require that owners or operators of industrial refrigeration equipment that contains over 50 pounds of ozone-depleting refrigerants repair leaks within 30 days, verify and document leak repairs and servicing. The regulations also prohibit appliances from being opened by people other than specially trained certified technicians and require the use of certified refrigerant recovery devices when appliances are opened.
Between 2009 and 2016, Trident violated these regulations on numerous occasions. In addition to its failures to repair leaking appliances, Trident also failed to create adequate servicing and compliance records on at least 289 occasions. Trident also, at times, used uncertified technicians to perform work on refrigerant equipment and used inadequate refrigerant recovery equipment.
Trident and its subsidiaries Royal Viking Inc and Golden Dawn LLC own and operate four factory processor vessels, one freighter vessel, nearly 30 catcher and tender vessels, and 10 land-based facilities in Alaska and the Pacific Northwest. In most of these vessels and facilities, Trident uses ozone-depleting HCFCs in its refrigeration appliances in sizes ranging from less than 50 pounds of refrigerant to greater than 5,000 pounds of refrigerant.
The proposed settlement was lodged in the U.S. District Court for Alaska and is subject to a 30-day public comment period and court approval.
Refinery Ordered to Study Hazardous Waste Releases
The EPA has ordered Greka to conduct sampling at its Santa Maria, Calif. refinery to determine whether improper storage and management of hazardous wastes contaminated local soil and groundwater.“Poor management of hazardous waste can release contaminants into the environment and affect local communities,” said EPA Pacific Southwest Deputy Regional Administrator Deborah Jordan. “Today’s order requires Greka to determine if its refinery is affecting nearby farmlands, groundwater and the communities of Santa Maria and Guadalupe.”
A December 13, 2018 EPA inspection found Greka’s facility, which does not have a required permit to store hazardous waste, had improperly stored, labeled and managed hazardous waste from their refinery processes. EPA inspectors documented waste dumped directly into an unlined pit, also known as a surface impoundment, located 90 feet from agricultural lands.
The order requires Greka to develop a plan to determine and catalogue the magnitude and extent of possible off-site migration of hazardous wastes. The work plan must provide extensive information on the surface impoundment, including age, capacity, structural integrity, construction, and maintenance procedures. Greka must analyze the hazardous waste and develop a comprehensive groundwater and soil monitoring plan to ensure contamination is not migrating off-site. The company has 45 days to submit the plan to EPA for approval.
The EPA is coordinating its investigation with the California Department of Toxic Substances Control and the Regional Water Quality Control Board to ensure effective oversight of the facility.
Greka’s Santa Maria facility is surrounded by agricultural land and close to residential neighborhoods of Santa Maria and Guadalupe.
Integrity Applied Science Fined $24,335 for EPCRA Reporting Violations
EPA announced an Emergency Planning and Community Right-to-Know Act (EPCRA) settlement with Integrity Applied Science in which the company has agreed to pay a $24,335 penalty and comply with requirements to report hazardous chemicals stored at their facility at 10765 Turner Boulevard in Longmont, Colo. This case is part of EPA’s National Compliance Initiative to reduce risks from chemical accidents, and addresses compliance within an industrial sector--chemical manufacturing-- that can pose serious risks from such accidents.The settlement resulted from a 2018 EPA inspection at the facility which revealed violations of EPCRA’s hazardous chemical storage reporting regulations. EPA was made aware of potential violations at the facility due to complaints from the Weld County Local Emergency Planning Committee (LEPC) and the Mountain View Fire Protection District.
“EPA values the partnerships we have developed with state and local emergency response agencies here in Colorado,” said Suzanne Bohan, director of enforcement programs at EPA Region 8. “We appreciate Integrity Applied Science’s effort to remedy these reporting deficiencies. This action will secure and encourage compliance with chemical reporting requirements that keep our citizens and our emergency responders safe.”
“The Weld County Local Emergency Planning Committee is pleased that EPA investigated and took appropriate action based upon our complaint,” said Roy Rudisill, director of Weld County Emergency Management and chair of the Weld County LEPC. “We viewed this as a serious matter as Integrity Applied Science’s failure to report in a timely manner was a concern for our first responders and our citizens who live in the area.”
The Integrity Applied Science facility is subject to EPCRA reporting regulations because it holds hazardous chemicals above regulatory threshold quantities. Section 312 of the Act requires facilities to submit an annual Emergency and Hazardous Chemical Inventory Form to state and local emergency responders.
The Emergency Planning and Community Right-to-Know Act establishes requirements for federal, state and local governments, Indian tribes, and industry regarding emergency planning and “Community Right-to-Know” reporting on hazardous and toxic chemicals. Failure to comply with these requirements prevents emergency responders from preparing for, and safely responding to, emergencies at facilities where chemical hazards may exist. These and additional Community Right-to-Know provisions help increase public’s knowledge and access to information on chemicals at individual facilities, their uses, and releases into the environment.
EPA Avoids Formal Comments on State Water Permits
The EPA has been preventing its specialists from formally communicating concerns about state-issued pollution permits, according to a lawsuit filed by Public Employees for Environmental Responsibility (PEER). As a result, EPA objections to state lapses in administering key environmental laws are being squelched.The PEER suit focuses on PolyMet Mining’s planned $1 billion NorthMet mine copper-nickel mine in northern Minnesota. The mine and processing plant would occupy 19,000 acres in the St. Louis River basin, creating a permanent pollution source in the river flowing into Lake Superior. The project would also destroy more than 900 acres of wetlands.
Until Trump’s election, the EPA Great Lakes Regional Office had submitted detailed comments to the two state permitting agencies, the Minnesota Department of Natural Resources and the Minnesota Pollution Control Agency (MPCA) expressing concerns about potential violations of the Clean Water Act.
During the past two years, however, EPA staff have been disallowed from providing comments in writing to their state counterparts. Instead, EPA staff were reduced to reading comments over the phone, according to call notes taken by MPCA staff. Nor would EPA release the finalized but still unsubmitted comments in response to a longstanding Freedom of Information Act (FOIA) request.
“It is ridiculous that EPA can only conduct kabuki oversight since staff may only read but not register serious objections about potential pollution violations,” stated PEER staff Counsel Kevin Bell, who filed the FOIA lawsuit seeking release of the undelivered EPA NorthMet mine comments. “EPA apparently wants to ensure there is no paper trail evidencing the very real concerns of career professional staff.”
EPA’s withdrawal from regulatory oversight is not limited to this Polymet mine in Minnesota. EPA employees from other regions report similar constraints to PEER. Many cite an October 30, 2018 memo issued by Acting Administrator Andrew Wheeler directing EPA regional offices to exhibit “general deference to the states.”
“The purpose of federal environmental laws is to guarantee a uniform safety net for clean water, air, and soil throughout the nation,” explained PEER Science Policy Director Kyla Bennett, a scientist and attorney formerly with EPA, noting that the Wheeler memo on deference to states stems from former Administrator Scott Pruitt’s “Cooperative Federalism” doctrine. “At EPA, oversight now means to overlook since political consensus is prized over EPA’s commitment to public health and the environment.”
PEER has previously pursued litigation faulting EPA for routinely preventing creation of records documenting the basis for its actions under Pruitt. Wheeler won dismissal of the suit by promising reforms, but the Polymet case and other instances raise new questions as to the efficacy of these “reforms.” Meanwhile, a retired EPA lawyer has asked the agency’s Office of Inspector General to thoroughly investigate the PolyMet permit.
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