News & Analysis as of

RCRA Clean Air Act Hazardous Waste

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

Hazardous Waste Enforcement: Tennessee Department of Environment and Conservation Proposed Order/Assessment Addressing Chattanooga...

The Tennessee Department of Environment & Conservation (“TDEC”) issued a proposed Director’s Order and Assessment (“Order”) to Techniques Surfaces, USA, Inc. (“TS”) addressing alleged violations of the Tennessee hazardous...more

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

Reconditioning/Used Drum Management: ASTSWMO Comments Addressing U.S. Environmental Protection Agency Advance Notice of Proposed...

The Association of State and Territorial Solid Waste Management Officials (“ASTSWMO”) submitted comments to the United States Environmental Protection Agency (“EPA”) on November 22 addressing the following Advance Notice of...more

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

Draft U.S. Environmental Protection Agency National Enforcement and Compliance Document for Years 2024-2027: Association of State...

The United States Environmental Protection Agency (“EPA”) published in the January 12th Federal Register a Request for Public Comment on the National Enforcement and Compliance Initiatives (“NECIs”) it is proposing for fiscal...more

Pillsbury Winthrop Shaw Pittman LLP

EPA Tentatively Rejects the Center for Biological Diversity’s Petition to Regulate PVC as a Hazardous Waste

The EPA’s tentative determination signals the possibility of a future course reversal, and interested parties should consider making public comments, which could influence the outcome of the process. The U.S. Environmental...more

Smith Gambrell Russell

Timber and Paper Industry Petition EPA to Ease Restrictions on Burning Paper Residuals

Smith Gambrell Russell on

In December, 2021, representatives of the timber and paper industry petitioned the EPA to ease restrictions on the burning of railroad ties and paper residuals as fuel without triggering strict hazardous waste combustion...more

Farella Braun + Martel LLP

Summary of Latest Federal Action Regarding PFAS

A few considerations practitioners should keep in mind when dealing with contamination involving per- and polyfluoroalkyl substances (PFAS) contamination. The PFAS Action Act of 2021 passed in the House and was received in...more

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

Use of Polymerization as Treatment Method: U.S. Environmental Protection Agency RCRA Guidance

The United States Environmental Protection Agency (“EPA”) addressed in a December 4, 2020, letter a request for a regulatory determination on hazardous waste generator activities associated with polymerization (“POLYM”) as a...more

Beveridge & Diamond PC

RCRA Air Compliance Initiative and Rescission of “Once In, Always In” Policy Present Federal and State Self-Audit Opportunities

Beveridge & Diamond PC on

Key Takeaways - • What Happened: EPA urges self-audits for facilities subject to RCRA Parts 264/265 Subparts AA, BB and CC air emission standards to avoid potential for substantial penalties and injunctive relief ...more

Williams Mullen

Environmental Notes - October 2018

Williams Mullen on

EPA has announced a new compliance policy that some will view as providing welcome relief to industry and others may view as providing unwarranted concessions. The subject line of the EPA memo announcing the new policy is...more

Burr & Forman

Air Emissions Regulated Under RCRA?

Burr & Forman on

Certain regulated entities that operate under Clean Air Act permits are being reminded that those permits do not necessarily cover air emissions associated with the management of hazardous wastes regulated by the federal...more

Williams Mullen

Environmental Notes - May 2016

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The news has been full of stories and articles concerning Coal Combustion Residuals (CCR), also referred to as coal ash. CCR became a hot topic in 2008 when a coal ash pond at a utility plant in Tennessee spilled more than 5...more

Pillsbury - Gravel2Gavel Construction & Real...

More Than Chickens, Lizards and Polar Bears – Environmental Case Law Update (Dec. 2015 – Mar. 2016)

This blog, although not brief, is a brief report on some of the significant environmental law and administrative cases decided in late December and the first quarter of 2016. U.S. SUPREME COURT - FERC Final Rule re...more

Williams Mullen

Environmental Notes - October 2015

Williams Mullen on

In a significant setback for the Obama Administration, the U.S. Court of Appeals for the Sixth Circuit has temporarily blocked implementation of the Clean Water Rule issued jointly by EPA and the U.S. Army Corps of Engineers...more

Bergeson & Campbell, P.C.

Wrap-Up of Federal and State Chemical Regulatory Developments, September 2015

EPA Releases TSCA Assessment Documents For Flame Retardant Chemicals: On August 18, 2014, the U.S. Environmental Protection Agency (EPA) released for public comment three Problem Formulation and Initial Assessment documents...more

Bergeson & Campbell, P.C.

Wrap-Up of Federal and State Chemical Regulatory Developments, August 2015

EPA Issues Direct Final Rule On Significant New Use Notification Electronic Reporting: On July 20, 2015, the U.S. Environmental Protection Agency (EPA) issued a direct final rule amending the Toxic Substances Control Act...more

Beveridge & Diamond PC

RMP and General Duty Clause Enforcement Continues at EPA Region 1

As we reported last year, the U.S. EPA has stepped up its enforcement activity under the risk management provisions of the Clean Air Act (“CAA”), Section 112(r), focusing on both the Risk Management Plan (“RMP”) program rules...more

Williams Mullen

Environmental Notes - June 2015

Williams Mullen on

In this Issue: - EPA Issues SIP Call to Eliminate SSM Defense - EPA and Corps Define “Waters of The United States” - Frequent Questions: EPCRA 313 - Generators Need to be Vigilant About TCLP Sampling...more

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