Gregory R. Wall

As a former US Environmental Protection Agency (EPA) senior attorney, Greg uses his agency experience to resolve difficult environmental matters. He brings over 20 years of practice in environmental law and has particular knowledge of PFAS, CERCLA/Superfund, TSCA, FIFRA, and RCRA. According to Chambers USA, “Greg has an exceptional ability to make complex issues understandable” (2024).

Greg co-chairs the firm’s chemical regulatory and PFAS practices and advises clients across diverse industries—including chemical, pesticide, oil and gas, electric utility, food and beverage, electronics and semiconductors, financial services, private equity, retail, mining, rail, airline, and marine transport—in environmental regulatory, counseling, enforcement defense, litigation, and transactional matters. Greg was involved in shaping and framing some of the earliest site remediation enforcement actions involving PFAS and analyzing EPA’s statutory and regulatory authorities to address PFAS contamination under existing law. His experience in both private and public practice helps him navigate the regulatory process with an informed understanding of government decision-making and strategies for efficiently resolving complex legal and policy issues. Drawing on his EPA experience, he has negotiated settlements saving clients millions of dollars in penalties in EPA enforcement actions, particularly under TSCA and FIFRA. He also has significant experience related to the acquisition and sale of environmentally-impaired property, conducting voluntary cleanups, negotiating environmental liability transfers, and the re-development of brownfield sites, including for renewable energy projects. 

Greg practiced CERCLA at the highest levels in the federal government and relies on that experience in his defense of clients facing government enforcement or private party contribution actions. Greg previously served as the lead EPA Headquarters attorney on cleanup enforcement cases at Superfund sites with remedies exceeding $1 billion. He not only worked on national CERCLA matters, but also authored national guidance documents and drafted model settlement documents used by EPA nationwide. During his EPA tenure, Greg received numerous EPA and DOJ awards, including for his work on the Administrator’s Superfund Task Force and the development of EPA’s national enforcement response to the US Supreme Court’s landmark decision in Burlington Northern & Santa Fe Railway v. United States.

Greg is an adjunct professor at William & Mary Law School, teaching Environmental Law and the Regulation of Toxic Substances and Hazardous Waste.

PFAS

• Providing comprehensive regulatory counseling and advocacy to clients in multiple industry sectors on PFAS issues in the US to develop company-wide PFAS compliance and business continuity strategies, monitor regulatory developments, craft supply chain communications and contractual provisions, and respond to customer inquiries.
• Counseling a wide spectrum of clients on compliance methodologies for EPA’s expansive TSCA Section 8(a)(7) PFAS reporting rule.
• Assisting clients to develop compliance certifications, purchase order terms, and indemnity agreements addressing PFAS risks in transactional documents.
• Advising manufacturing clients on the evolving patchwork of state laws and regulations imposing controls and restrictions on PFAS-containing products, and seeking exemptions from PFAS bans for currently unavoidable uses.
• Successfully opposed a state environmental agency’s request to conduct a PFAS investigation for an industrial client at a contaminated site with no history of PFAS use or disposal.
• Advising clients on the risks of continuing to use PFAS-containing firefighting foam at manufacturing plants.
• Representing an industrial client in landlord-tenant negotiations and litigation related to PFAS discovered in a property’s soil and groundwater.
• Advised major pesticide manufacturer on strategies to address PFAS contaminated groundwater migrating from a military base adjacent to its property.
• Conducting environmental due diligence and PFAS risk analyses for transactions involving the acquisition of companies in the plastics, food packaging, and electronics industries.

Contaminated Sites and Remediation

• Represent railroad passenger corporation in cost recovery negotiations and litigation for costs incurred in conducting the investigation and cleanup of polychlorinated biphenyls (PCBs) at one of the busiest train stations in the world.
• Represent a global crop protection client working with a group of multinational companies conducting an extensive cleanup at a complex site in Nebraska, which has attracted local, regional, and national media attention, as well as significant political interest. This work involves close coordination with counsel for other companies, technical consultants, communications and public relations professionals, and interfacing with state and federal regulators.
• Represented federal and private sector clients in CERCLA litigation involving over 50 federal Superfund sites, including precedential trials and appeals addressing novel arranger liability and divisibility issues, the intersection of section 107 cost recovery and section 113 contribution actions, and the interplay between CERCLA remedies and state common law claims.
• Negotiated CERCLA settlement agreements for cost recovery and performance of response actions at Superfund sites across the country.
• Represented an industrial parts manufacturer in responding to a 70-page CERCLA Section 104(e) information request from EPA regarding the client’s involvement with a large PCB-contaminated sediment site in New England.
• Conducted in-depth corporate history research and persuaded EPA that a client was not liable as a successor at a Superfund site with cleanup costs estimated at over $10 million.
• Represented a client in connection with the closure of a PCB commercial storage facility regulated under the TSCA PCB program. Work involved retaining and coordinating with multiple consultants, advising the client through a detailed regulatory approval process for closure and remediation plans, negotiating with EPA, and contracts negotiations for a fixed-price remediation contract.
• Counseled private equity, financial institutions, real estate investors, and industrial clients on CERCLA landowner liability protections, environmental insurance, and contractual risk allocation mechanisms for the redevelopment and reuse of contaminated property.
• While at EPA, represented the Agency in a CERCLA section 106(b) reimbursement proceeding before the Environmental Appeals Board raising arranger liability issues of first impression.

Regulatory Counseling and Advocacy

• Conducted a multi-year comprehensive TSCA and EPCRA regulatory audit of a client's semiconductor manufacturing facility. Counseled client into compliance and disclosed potential violations to EPA under the Audit Policy, resulting in avoidance of millions of dollars of gravity-based penalties.
• Assisted clients with TSCA premanufacture notification review process and negotiation of TSCA section 5(e) orders to bring chemical products, including products of biotechnology and nanotechnology, to the market in the US.
• Advised clients on testing, risk reporting, inspections, recordkeeping, and import and export requirements under TSCA.
• Assisted a bio-industrial client to obtain a notice of determination from EPA to use existing stocks of chemicals imported in violation of TSCA.
• Assisted clients to bring industrial chemical and biotechnology-derived products to market in Asia under foreign chemical control regimes in China, Taiwan, Japan, and South Korea.
• Advised clients on pesticide regulatory issues under FIFRA including product registration, labeling, the treated-article exemption, import and export requirements, jurisdictional issues, and enforcement matters.
• Advised clients on compliance with RCRA regulatory requirements for the generation, transportation, treatment, storage, and disposal of various waste streams, including power generator waste, discarded ration heaters, byproducts from chemical manufacturing processes, and oil and gas wastes.
• Prepared comments for a chemical-specific trade association on multiple state and federal rulemakings under TSCA and the Clean Air Act.
• Counseled office equipment and consumer electronics manufacturers on EPA’s ENERGY STAR programs, product specifications, and labeling.

Environmental Regulatory Enforcement and Litigation

• Successfully resolved a significant Virginia Department of Environmental Quality (VADEQ) enforcement action related to hazardous waste compliance at a national food and beverage manufacturer’s facility in Virginia.
• Defended a chemical company in an EPA enforcement action alleging TSCA Section 8 Chemical Data Reporting and Section 4 test rule violations, resulting in EPA dismissing three violations entirely and negotiating a 72% reduction in proposed penalties.
• Defended a bio-industrial company in an EPA enforcement action alleging TSCA Section 5 new chemical and Section 12 export notice violations, negotiating a 79% reduction in proposed penalties.
• Defended a chemical distribution company in an EPA enforcement action under FIFRA alleging the sale and distribution of an unregistered pesticide, marshalling ability to pay and other arguments to negotiate a 74% reduction in proposed penalties.
• Defended a chemical product company in an EPA enforcement action under FIFRA alleging pesticide labeling violations, negotiating a 72% reduction in proposed penalties.
• Represented an electric distribution cooperative participating as an intervening defendant in a NEPA challenge involving the client’s coal-fired power plant in the US District Court for the District of Columbia.
• Represented a coal-fired power plant in a TPDES permit contested case hearing involving Clean Water Act section 316(b) and water quality issues before the Texas State Office of Administrative Hearings.
• Represented clients before EPA regarding alleged violations of EPA’s Clean Air Act ozone-depleting substances regulations.
• Represented a client being investigated by DOJ for criminal violations of the Clean Water Act for discharges from oil platforms.
• Represented a coatings manufacturer before California’s South Coast Air Quality Management district for alleged violations of VOC-content regulations.
• Represented an electric utility being investigated by EPA as part of the New Source Review Enforcement Initiative.
• Represented a trade association client in arbitration involving false advertising claims and unsubstantiated health risks allegedly posed by exposure to a chemical substance.

Environmental Representation in Transactions and Securities Filings

• Conducted environmental due diligence reviews and negotiated contractual provisions for mergers and acquisitions, real property, and leasing transactions involving billions of dollars for clients in the real estate, financial services, private equity, oil and gas (upstream, midstream, and downstream), chemical, coal mining, marine transport, hospitality, and manufacturing sectors.
• Represented the investing partner in a joint venture for the acquisition and redevelopment of a steel manufacturing facility with a 100-year operating history subject to significant environmental remediation obligations. Work included conducting extensive due diligence, transferring the current owner’s environmental permits, obtaining the requisite financial assurance under applicable regulatory requirements, negotiating environmental indemnity and escrow provisions, and helping the client secure a tower of environmental insurance policies.
• Represented an international power producer on the construction and financing of a merchant power plant in South America.
• Represented securities issuers and underwriters in all environmental aspects of offerings of stocks, notes, and master limited partnership interests in filings with the US Securities and Exchange Commission for oil and gas, maritime, chemical, and other industries.
• Represented a private equity client on all environmental matters related to the acquisition of solid waste landfills in multiple states.
• Negotiated an environmental indemnity for a private equity client’s acquisition of a rubber manufacturing company. Developed a compliance and self-disclosure plan to address outstanding environmental compliance issues.
• Counseled Fortune 500 clients on parent, shareholder, and other organizational environmental liability for acts of subsidiaries and other business affiliates.
• Counseled an international energy company in evaluating potential permitting and environmental liabilities associated with its acquisition of a petroleum refinery.
• Counseled a foreign oil company on environmental requirements and potential liability exposures associated with an offshore lease in the Outer Continental Shelf.

• Recognized as a Leader in Environment, Virginia, Chambers USA, 2024
• Selected as a member of the Lawdragon Green 500: Leaders in Environmental Law (2023, 2024)
• Recognized as 2021 Environmental Group of the Year, Law360, January 2022
• 2021 and 2017 Chambers USA Environment Law Firm of the Year
• US EPA, Bronze Medal for Commendable Service – CERCLA Liability and Redevelopment Action Team (2019)
• US EPA, Bronze Medal for Commendable Service – Accelerating Responsible Party Cleanup Team (2019)
• US EPA, Team Leader of the Year, Office of Enforcement and Compliance Assurance (2015)
• US DOJ, Certificate of Commendation, Environmental and Natural Resources Division (2013)