News & Analysis as of

Hazardous Waste Corrective Actions RCRA

Holland & Knight LLP

2024 Midyear PFAS Regulatory Update: Final Rules Recently Issued by EPA and What's to Come

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Just past the halfway point of 2024, it's already been a busy year for those following regulatory developments related to per- and polyfluoroalkyl substances (PFAS). Building on its plans in the 2021 PFAS Strategic Road Map...more

Mitchell, Williams, Selig, Gates & Woodyard,...

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

Mitchell, Williams, Selig, Gates & Woodyard,...

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

Mitchell, Williams, Selig, Gates & Woodyard,...

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

Holland & Knight LLP

EPA Proposes RCRA Corrective Action Expansions Targeting PFAS

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The 1984 Hazardous and Solid Waste Amendments amended the Resource Conservation and Recovery Act (RCRA) to add the following sections requiring corrective action for releases of hazardous waste or hazardous constituents ...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Hazardous Waste Management Program Implementation Costs: Association of State and Territorial Solid Waste Management Officials...

The Association of State and Territorial Solid Waste Management Officials (“ASTSWMO”) issued a November 2023 report titled: Hazardous Waste Management Program Implementation Costs Report (“Report”) - The Report was...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Post-Closure Care Beyond 30 Years at RCRA Subtitle C Facilities: Association of State and Territorial Solid Waste Management...

The Association of State and Territorial Solid Waste Management Officials (“ASTSWMO”) issued a position paper titled: Post-Closure Care Beyond 30 Years at RCRA Subtitle C Facilities (“Position Paper”) The Position...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Hazardous Waste Enforcement: Arkansas Department of Environmental Quality and Calhoun County, Arkansas Ordnance Manufacturing...

The Arkansas Department of Environmental Quality (“ADEQ”) and Armtec Countermeasures Co. (“ACC”) entered into a March 29th Consent Administrative Order (“CAO”) to address alleged violations of Arkansas Pollution Control &...more

Williams Mullen

RCRA Corrective Action Liability: Can it be Imposed on a Company that Never Owned or Operated the Facility?

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The North Carolina Court of Appeals recently issued a ruling that will have a significant impact on business transactions involving property subject to a permit or corrective action obligations under the Resource Conservation...more

Manatt, Phelps & Phillips, LLP

Will NYSDEC's Audit Agreement for Retail Pharmacies Provide a Path to Increased Compliance?

Federal and state hazardous waste handling and disposal requirements, which were established to address issues related to industrial waste generators and disposal facilities, are often a complicated and awkward fit for retail...more

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