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Fox Rothschild Attorneys Submit Comments on USEPA Vapor Intrusion Guidance

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Last night we submitted formal comments on USEPA’s Office of Solid Waste and Emergency Response ("OSWER") draft "final" vapor intrusion guidance. The OSWER guidance and a corresponding Office of Underground Storage Tanks ("OUST") guidance can be accessed here. Our comment submission can be assessed here.  Public input on these documents was due by midnight yesterday, June 24, 2013, at Regulations.gov; docket number: EPA-HQ-RCRA-2002-0033.  Comments submitted yesterday, including ours, were not yet available externally at the Regulations.gov website at the time of this blog posting. 

Needless to say, we are very pleased that USEPA made the decision to post drafts for public comment, as we and others had petitioned last year, and that a number of interested parties took the opportunity to provide substantive input.  Our hope is that the USEPA will use the input it received to generate a more practical final document.