News & Analysis as of

RCRA

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

U.S. House of Representatives Appropriation Committee: Association of State and Territorial Solid Waste Management Officials...

The Association of State and Territorial Solid Waste Management Officials (“ASTSWMO”) submitted testimony to the United States House Appropriations Subcommittee on Interior, Environment, and Other Related Agencies. The...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Tracy, California Glass Container Manufacturing Facility...

The United States Environmental Protection Agency (“EPA”) and Owens-Brockway Glass Container Inc. (“OB”) entered into an April 8th Consent Agreement (“CA”) addressing alleged violations of the Resource Conservation and...more

Williams Mullen

Drumming Up a Change? EPA’s Review of the RCRA “Empties” Rule and Its Impact on Generators and the Drum Reconditioning Industry

Williams Mullen on

EPA recently initiated a rulemaking process aimed at reviewing how empty industrial drums are regulated under the Resource Conservation and Recovery Act (RCRA). This is a move which could have significant implications for...more

Williams Mullen

Environmental Notes - April 2025

Williams Mullen on

Under the Clean Air Act, sources frequently must undergo “New Source Review” (NSR) permitting, which is a pre-construction permitting program. NSR establishes requirements for new or modified sources prior to initiating...more

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

RCRA Guidance Letter/Military Munitions Rule: U.S. Environmental Protection Agency Addresses Manifest Exemption for Geographically...

The United States Environmental Protection Agency (“EPA”) Office of Resource Conservation Recovery addressed in a March 6th Resource Conservation and Recovery Act (“RCRA”) guidance letter a request from the University of...more

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

Hazardous Waste Enforcement: Alabama Department of Environmental Management and Huntsville Circuit Board Manufacturing Facility...

The Alabama Department of Environmental Management (“ADEM”) and Sanmina Corporation (“SC”) entered into a Consent Order (“CO”) addressing alleged violations of the Alabama Hazardous Waste Regulations. See Consent Order No....more

Wenning Environmental

Will damage, impact, and risk assessment get “DOGE’d”?

Wenning Environmental on

President Trump’s January 31, 2025, executive order (EO), Unleashing Prosperity Through Deregulation, and the White House Council on Environmental Quality (CEQ) February 25 interim final rule removing CEQ regulations...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Camden, New Jersey Drum Reconditioner Enter into Consent...

The United States Environmental Protection Agency (“EPA”) and Patrick J. Kelly Drums, Inc. (“PJKD”) entered into a February 27th Consent Agreement and Final Order (“CAFO”) addressing alleged violations of the Resource...more

Paul Hastings LLP

RCRA Rules Face Hazardous Times

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In an executive order issued February 19, 2025, President Donald Trump instructed federal agency heads to “initiate a process to review all regulations subject to their sole or joint jurisdiction” for purposes of “rescinding...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Columbus, Ohio Paint Corporation Enter Into Expedited...

The United States Environmental Protection Agency (“EPA”) and Yenkin-Majestic Paint Corporation (“YMPC”) entered into a February 19th Expedited Settlement Agreement (“ESA”) addressing alleged Resource Conservation Recovery...more

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

Improved Procedures for Facility/Site Transfers Between RCRA Hazardous Waste Cleanup/CERCLA Cleanup Activities: U.S. Environmental...

The United States Environmental Protection Agency (“EPA”) issued a December 19, 2024 Resource Conservation Recovery Act (“RCRA”) guidance document titled: Improved Procedures for Facility/Site Transfers Between RCRA Hazardous...more

Beveridge & Diamond PC

The Citizens Are Coming: Citizens Groups Are Better Funded Than Ever and Will Take Over Where Biden Left Off (Updated)

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We expect newly-confirmed U.S. Environmental Protection Agency (EPA) Administrator Lee Zeldin to quickly follow through on President Trump’s promises to draw down federal enforcement efforts. In a stark directive, Trump has...more

Gray Reed

Waste Management Companies Beware! The Resource Conservation and Recovery Act was Amended

Gray Reed on

In a previous post, I mentioned that contracts between public entities and private waste management companies usually contain compliance and regulation clauses.  Such a clause requires a waste management company to comply...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Allentown, Pennsylvania Coil Coating Facility Enter into...

The United States Environmental Protection Agency (“EPA”) and Vorteq Coil Finishers, LLC (“Vorteq”) entered into a January 22nd Consent Agreement (“CA”) addressing alleged violations of the Resource Conservation and Recovery...more

Troutman Pepper Locke

Recent Executive Action May Impact PFAS Regulation

Troutman Pepper Locke on

The regulation of per- and polyfluoroalkyl substances (PFAS), or “forever chemicals,” was a focal point for the Biden administration. In April 2024, the administration, through the U.S. Environmental Protection Agency (EPA),...more

Balch & Bingham LLP

Managing Solid Waste Challenges in the Energy Transition

Balch & Bingham LLP on

The transition to sustainable energy in the United States is reshaping how we create, store, and use energy – especially electricity – and the landscape is changing rapidly. This shift introduces new waste management...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Buffalo, New York Diagnostics Facility Enter into Consent...

The United States Environmental Protection Agency (“EPA”) in IMMCO Diagnostics (“ID”) entered into an October 3 expedited settlement agreement (“ESA”) addressing an alleged violation of the Resource Conservation Recovery Act...more

McGlinchey Stafford

Stericycle Agrees to Pay $9.5 Million Civil Penalty for RCRA Violations

McGlinchey Stafford on

On January 17, 2025, the Environmental Protection Agency (EPA) and the Department of Justice (DOJ) announced a $9.5 million settlement with Stericycle, Inc. for Hazardous Waste Management Violations. The settlement resolves...more

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

Citizen Suit Action/RCRA: Conservation Law Foundation Alleges Violations by Natural Gas Pipeline System

The Conservation Law Foundation, Inc. filed a citizen suit Complaint in the United States District Court of Massachusetts on November 12th alleging violations by the following: Besides the Conservation Law Foundation, the...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Cedar Rapids, Iowa Industrial Paint Manufacturer Enter into...

The United States Environmental Protection Agency (“EPA”) and Klinger Paint Company, Inc. (“Klinger”) entered into a January 7th Consent Agreement and Final Order (“CAFO”) addressing alleged violations of the Resource...more

Seyfarth Shaw LLP

New Year, New Penalties: OSHA and USEPA Increase Penalties

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The federal Occupational Safety and Health Administration (OSHA) and Environmental Protection Agency (“EPA”) have published their 2025 increases to civil penalties....more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Costa Mesa, California Automatic Control Valve Manufacturer...

The United States Environmental Protection Agency (“EPA”) and Griswold Industries (“GI”) entered into a January 3rd Expedited Settlement Agreement (“ESA”) addressing alleged violations of the Resource Conservation and...more

Stinson LLP

Trump's First 100 Days: Environmental

Stinson LLP on

At a high level, President-elect Trump is expected to issue executive orders to pause pending rules, use the Congressional Review Act to withdraw recently finalized rules, and halt agency activity while the administration...more

Bergeson & Campbell, P.C.

Wrap-Up of Federal and State Chemical Regulatory Developments, December 2024

TSCA/FIFRA/TRI - EPA Releases Final Supplement To The Risk Evaluation And Revised Unreasonable Risk Determination For 1,4-Dioxane: On November 13, 2024, the U.S. Environmental Protection Agency (EPA) announced the release...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Golden Meadow, Louisiana Port Services Facility Enter into...

The United States Environmental Protection Agency (“EPA”) and HOS Port, LLC (“HOS”) entered into an October 9th Consent Agreement and Final Order (“CAFO”) addressing alleged violations of the Resource Conservation and...more

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