The scope of Mr. Gramling's practice includes:
- Federal and State hazardous waste permitting, compliance, and enforcement.
- Management of generation, storage and disposal of hazardous waste.
- Corrective action for hazardous waste.
- EPCRA chemical inventory storage and reporting.
- CERCLA/Superfund representation in administrative/EPA proceedings:
- Corporate audits and due diligence of waste vendors to avoid Superfund-like liabilities.
- Drycleaning program sites.
- Petroleum program sites.
- Brownfields sites.
- Voluntary Cleanup, including filing of Voluntary Cleanup Tax Credit applications.
- Federal and state point-source permitting and compliance and enforcement under the Clean Water Act.
- Surface and groundwater pollution.
- Stormwater permitting.
- Wetland development and mitigation.
- Clean Air Act: Risk Management Plans.
- OSHA worker protection/ PEL issues
- Asbestos regulation
- Endangered Species Act consultation on permits.
- Taking issues.
- Listing and delisting of species.
- Incidental take statements.
Safety and Health:
- Avoidance of criminal investigations and prosecutions.
- Chemical release reporting.
- Conducting and managing compliance audits of corporate operations and facilities for clients, using the work product doctrine and attorney client privilege to enhance the protection afforded these audits from discovery in litigation. We work with our corporate clients on indoor air quality evaluations, hazardous waste compliance audits, endangered species critical constraints audits, and occupational safety and health compliance audits.
- Real estate due diligence to coordinate Phase I and Phase II environmental assessment activities for the benefit of our clients, working closely with traditional real estate counsel in this process. As a result of our years of experience, we have become very efficient at identifying issues, estimating the magnitude of problems in relation to the value of the transaction, and developing strategies to resolve the environmental problem so that the real estate transaction proceeds.
- Merger and acquisition due diligence.
- Development of Corporate Environmental Management Systems.
- OSHA Hazard communications and worker safety issues as they relate to environmental concerns, including indoor air quality problems.
- Multi-employer worksite contract and liability issues relating to real estate development, projects and construction.
Mr. Gramling is experienced in most substantive areas of regulation and is familiar with all major federal and Florida laws regulating the environment and land usage. These major federal statutes include:
- Engaged as Subject Matter Expert in 1996-1999 legislative sessions regarding Florida Drycleaning Solvent Cleanup Program.
- Drafted legislation.
- Lobbied and passed various bills in the Florida Legislature.
National Environmental Policy Act of 1969 (NEPA); 42 U.S.C. 4321-4347
NEPA is the basic national charter for protection of the environment.
It establishes policy, sets goals, and provides means for carrying out
More about NEPA
Chemical Safety Information, Site Security and Fuels Regulatory Relief
Act Public Law 106-40, Jan. 6, 1999; 42 U.S.C. 7412(r)
Amendment to Section 112(r) of the Clean Air Act
Summary and full text
The Clean Air Act (CAA); 42 U.S.C. s/s 7401 et seq. (1970)
| CAA full text
| Guide to
The Clean Water Act (CWA); 33 U.S.C. ss/1251 et seq. (1977)
CWA summary | CWA
Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA or Superfund) 42 U.S.C. s/s 9601 et seq. (1980)
| CERCLA full
The Emergency Planning & Community Right-To-Know Act (EPCRA);
42 U.S.C. 11011 et seq. (1986)
| EPCRA full text
The Endangered Species Act (ESA); 7 U.S.C. 136;16 U.S.C. 460
et seq. (1973)
ESA summary | ESA full text
Federal Insecticide, Fungicide and Rodenticide Act (FIFRA); 7
U.S.C. s/s 135 et seq. (1972)
| FIFRA full text
Federal Food, Drug, and Cosmetic Act (FFDCA) 21 U.S.C. 301 et
FFDCA summary | FFDCA full text
Food Quality Protection Act (FQPA) Public Law 104-170, Aug. 3,
FQPA summary | FQPA full text
The Freedom of Information Act (FOIA); U.S.C. s/s 552 (1966)
| FOIA full text
The Occupational Safety and Health Act (OSHA); 29 U.S.C. 651
et seq. (1970)
| OSHA full text
The Oil Pollution Act of 1990 (OPA); 33 U.S.C. 2702 to 2761
OPA summary and full text
The Pollution Prevention Act (PPA); 42 U.S.C. 13101 and 13102,
s/s et seq. (1990)
The Resource Conservation and Recovery Act (RCRA); 42 U.S.C.
s/s 321 et seq. (1976)
| RCRA full
The Safe Drinking Water Act (SDWA); 42 U.S.C. s/s 300f et seq.
| SDWA full text
The Superfund Amendments and Reauthorization Act (SARA); 42 U.S.C.9601 et seq. (1986)
| SARA full text
The Toxic Substances Control Act (TSCA); 15 U.S.C. s/s 2601 et
| TSCA full