Law School Case Brief
Train v. Colo. Pub. Interest Research Grp., Inc. - 426 U.S. 1, 96 S. Ct. 1938 (1976)
When aid to construction of the meaning of words as used in the statute is available, there certainly can be no rule of law which forbids its use, however clear the words may appear on superficial examination.
Colorado residents and organizations who claimed potential harm from the discharge of radioactive effluents from two nuclear power plants, brought an action against petitioner, the Administrator of the Environmental Protection Agency (EPA), under the Federal Water Pollution Control Act (FWCPA). The EPA disclaimed any authority under the FWPCA to set standards for the discharge of radioactive materials. Petitioner EPA claimed that the effluents were instead subject to regulation under the Atomic Energy Act, contending that source, byproduct, and special nuclear materials were specifically excluded from EPA regulation. At issue was whether the EPA had authority under the FWPCA to regulate the discharge of nuclear waste into the nation's waterways and whether the nuclear materials at issue were "pollutants," within the meaning of the FWPCA. In its review, the United States Court of Appeals for the Tenth Circuit held that the FWCPA required the EPA to regulate discharges of all radioactive materials into the nation's waters. The case was elevated on certiorari.
Were nuclear materials considered pollutants within the meaning of the FWPCA?
The United States Supreme Court reversed, holding that the term "pollutants" did not include source, byproduct, and special nuclear materials under the Federal Water Pollution Control Act. Thus, the EPA Administrator had acted in accordance with his statutory mandate in declining to regulate the discharge of such materials.
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