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Data Quality Issues Within the Hazardous Waste e-MANIFEST System: Association for State and Territorial Solid Waste Management...

The Association for State and Territorial Management Officials (“ASTSWMO”) published a position paper titled: DATA QUALITY ISSUES WITHIN THE HAZARDOUS WASTE e-MANIFEST SYSTEM (“Position Paper). The Position Paper...more

RCRA/11th Amendment: Federal Court Addresses Immunity of Two California Officials

A United States District Court (E.D. California) (“Court”) addressed in a July 31st Order a federal question jurisdiction issue arising out of a Federal Resource Conservation and Recovery Act (“RCRA”) judicial action. See...more

Hazardous Waste Enforcement: Alabama Department of Environmental Management and Huntsville Space Flight Center Enter into Consent...

The Alabama Department of Environmental Management (“ADEM”) and George C. Marshall Space Flight Center (“MSFC”) entered into a July 10th Consent Order (“CO”) addressing an alleged violation of the Alabama Hazardous Waste...more

CERCLA/Superfund: Federal Appellate Court Considers Whether Imposition of Arranger Liability Requires Knowledge Waste is Hazardous

The United States Court of Appeals for the Fourth Circuit (“Fourth Circuit”) addressed in a June 25th Opinion an issue involving arranger liability under the Comprehensive Environmental Response, Compensation, and Liability...more

Hazardous Waste Enforcement: Alabama Department of Environmental Management and Saraland Commercial Truck Wash Facility Enter into...

The Alabama Department of Environmental Management (“ADEM”) and Qualawash Holdings, LLC (“QH”) entered into a Consent Order (“CO”) addressing alleged violations of the Alabama Administrative Code addressing hazardous waste....more

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Chemical Etching Manufacturer Enter into Expedited...

The United States Environmental Protection Agency (“EPA”) and PMA Industries, Inc. (“PMI”) entered into a May 9th Expedited Settlement Agreement (“ESA”) addressing alleged violations of the Federal Hazardous Waste...more

Hazardous Waste Enforcement: Alabama Department of Environmental Management and Refuse Truck Body Manufacturer Enter into Consent...

The Alabama Department of Environmental Management (“ADEM”) and the Heil Company, Inc. (“Heil”) entered into a June 12th Consent Order (“CO”) addressing alleged violations of the Alabama Hazardous Waste Regulations. See...more

Hazardous Waste Enforcement: Arkansas Department of Energy & Environment - Division of Environmental Quality and Magnolia Fuel...

The Arkansas Department of Energy & Environment – Division of Environmental Quality (“DEQ”) and LB Amfuel Real Estate, LLC (“Amfuel”) entered into a June 17th Consent Administrative Order (“CAO”) addressing alleged violations...more

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Wheeling, Illinois Solvent/Paint Coatings Manufacturer Enter...

The United States Environmental Protection Agency (“EPA”) and Sunnyside Corporation (“Sunnyside”) entered into a June 4th Consent Agreement and Final Order (“CAFO”) addressing alleged violations of the Illinois Hazardous...more

Hazardous Waste Enforcement: Mississippi Commission on Environmental Quality and Belmont Recreational Vehicle Facility Enter into...

The Mississippi Commission on Environmental Quality (“MCEQ”) and Tiffin Motorhomes, Inc. (“Tiffin”) entered into an Agreed Order (“AO”) addressing alleged violations of the Mississippi Hazardous Waste Regulations. See Order...more

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Fredonia, Kansas Hazardous Waste Management Facility Enter...

The United States Environmental Protection Agency (“EPA”) and Systech Environmental Corp. (“STC”) entered into a February 22nd Consent Agreement and Final Order (“CAFO”) addressing the federal/Kansas hazardous waste...more

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Thousand Oaks, California Medical Center Enter into...

The United States Environmental Protection Agency (“EPA”) and Los Robles Hospital Medical Center (“ Los Robles”) entered into a March 27th Expedited Settlement Agreement (“ESA”) addressing an alleged violation of the Federal...more

Hazardous Waste Enforcement: U.S. Environmental Protection Agency in Baltimore, Maryland Galvanize Enter into Consent Agreement

The United States Environmental Protection Agency (“EPA”) and Southern Galvanizing Company (“Southern”) entered into a March 26th Consent Agreement (“CA”) addressing alleged violations of the Federal and Maryland Hazardous...more

National Capacity Variance/Generator Status: U.S. Environmental Protection Agency Guidance Addresses Hazardous Waste...

The United States Environmental Protection Agency (“EPA”) addressed in a March 22nd letter questions it was asked regarding the application of the Resource Conservation and Recovery Act (“RCRA”) to pharmaceutical hazardous...more

Hazardous Waste Enforcement: Louisiana Department of Environmental Quality and Hammond Hazardous Waste Storage Facility Enter into...

The Louisiana Department of Environmental Quality (“LDEQ”) and LEI, Inc. (“LEI”) entered into a Settlement Agreement (“SA”) addressed alleged violations of certain hazardous waste regulations. See SA-HE-23-0086....more

Solid and Hazardous Waste/Recycling Administrative/Judicial Development-2023-2024: Arkansas Environmental Federation Presentation

I undertook a presentation at the April 17, Arkansas Environmental Federation Land Seminar titled: Solid and Hazardous Waste/Recycling Administrative/Judicial Development – 2023-2024 The presentation...more

Used Oil/Hazardous Waste Enforcement: Louisiana Department of Environmental Quality and Baton Rouge Industrial Equipment Testing...

The Louisiana Department of Environmental Quality (“LDEQ”) and Quality Testing, Inc. (“QTI”) entered into a Settlement Agreement (“SA”) addressing alleged violations of the Louisiana Used Oil and Hazardous Waste Regulations. ...more

Solid Waste Management Unites/Corrective Action: ASTSWMO Comments Addressing U.S. Environmental Protection Agency Proposed Rule...

The Association of State and Territorial Solid Waste Management Officials (“ASTSWMO”) submitted March 26th comments to the United States Environmental Protection Agency (“EPA”) addressing a proposed rule which would amend the...more

Integrating Climate Change Adaption Considerations into the RCRA Corrective Action Process: U.S. Environmental Protection Agency...

The United States Environmental Protection Agency issued what it describes as “foundational policy document” for addressing climate adaption in the Resources Conservation and Recovery Act (“RCRA”) corrective action process....more

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Portland, Oregon Plating Facility Enter into Consent...

United States Environmental Protection Agency (“EPA”) and East Side Plating, Inc. (“East Side”) entered into a March 13th Consent Agreement and Final Order (“CAFO”) addressing alleged violations of the Clean Air Act...more

Hazardous Waste Enforcement: Alabama Department of Environmental Management and Sumter County Commercial Hazardous Waste...

The Alabama Department of Environmental Management (“ADEM”) and Chemical Waste Management, Inc. (“CWMI”) entered into a February 27th Consent Order (“CO”) addressing alleged violations of the Alabama hazardous waste...more

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Andrews, Texas Radioactive Waste Treatment/Disposal Facility...

The United States Environmental Protection Agency (“EPA”) and Waste Control Specialists (“WCS”) entered into a February 24 Consent Agreement and Final Order (“CAFO”) alleging violations of certain Texas/federal hazardous...more

Authorizing the Sale of Cannabis Waste: State of Washington Legislation

The Washington State Legislature has passed legislation which would allow in certain circumstances the sale of cannabis waste. The legislation is denominated Senate Bill 5376....more

Residential Property Sales/Superfund: Proposed Maryland Legislation Requiring Contract Disclosure of Area National Priority List...

Legislation (“SB 125”) was introduced into the Maryland General Assembly (2024 Session) that would require the seller of any residential property located within 0.5 miles of a National Priority List (“NPL”) Superfund...more

Implementing Climate Resilience/Hazardous Waste Permitting: ASTSWMO Addresses Question to U.S. Environmental Protection Agency...

The Association of State and Territorial Solid Waste Management Officials (“ASTSWMO”) addressed in a January 26th letter to the United States Environmental Protection Agency (“EPA”) a question regarding a draft memorandum the...more

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