News & Analysis as of

RCRA Hazardous Waste Enforcement Actions

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

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

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

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

The Arkansas Department of Energy & Environment – Division of Environmental Quality (“DEQ”) and United States Army, Pine Bluff Arsenal (“U.S.”) entered into a July 13th Consent Administrative Order (“CAO”) addressing actions...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and United Parcel Service Enter into Consent Agreement and Final...

The United States Environmental Protection Agency (“EPA”) and United Parcel Service (“UPS”) entered into an October 17th Consent Agreement and Final Order (“CAFO”). See EPA Docket No. RCRA-06-2022-0942. The CAFO is...more

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

Hazardous Waste Enforcement: Alabama Department of Environmental Management and Geneva County Aluminum HVAC Component Manufacturer...

The Alabama Department of Environmental Management (“ADEM”) and Ruskin Company, Inc. (“RCI”) entered into an August 24th Consent Order (“CO”) addressing alleged violations of the Alabama Hazardous Waste Regulations. See...more

Fox Rothschild LLP

State Enforcement Against the Federal Government, Part 2

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Almost two years ago, we posted on the civil settlement of a dispute between the New Mexico Environment Department (NMED) and the U.S. Department of Defense (DoD) over a state-level enforcement action against Cannon Air Force...more

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

Manufacturing Process Unit Exemption/RCRA: U.S. EPA Administrative Law Judge Addresses Applicability Question

A United States Environmental Protection Agency (“EPA”) Administrative Law Judge Christine Donelian Coughlin (“ALJ”) interpreted the Resource Conservation and Recovery Act (“RCRA”) term “manufacturing process unit” (“MPU”) in...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Johnstown, Pennsylvania, Tank/Container Manufacturer Enter...

The United States Environmental Protection Agency (“EPA”) and Johnstown Tube Laser, LLC, (doing business as Environmental Tank & Container) (“Johnstown”) entered into a Consent Agreement (“CA”) addressing alleged violations...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Jackson, Michigan, Metal Finishing Facility Enter into...

The United States Environmental Protection Agency (“EPA”) and Elm Plating Company (“EPC”) entered into a Consent Agreement and Final Order (“CAFO”) addressing an alleged violation of the Resource Conservation and Recovery Act...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Richmond, Virginia Electronics Recycling Facility Enter into...

The United States Environmental Protection Agency (“EPA”) and AERC Acquisition Corporation dba AERC Recycling Solutions (“AERC”) entered into a February 25th Consent Agreement (“CA”) addressing alleged violations of the...more

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

Criminal Enforcement/ RCRA: US Department of Justice Announces Sentencing of Madison Heights, Michigan Plating Company/ Owner

The United States Department of Justice (“DOJ”) Issued on November 6th a press release announcing the sentencing of Electro- Plating Services Inc (“EPS”) and its owner Gary Sayers for alleged violations of the Resources...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Kinsale, Virginia Facility Enter into Consent Agreement

The United States Environmental Protection Agency (“EPA”) and Potomac Supply Company, LLC (“Potomac”) entered into an October 30th Consent Agreement (“CA”) addressing alleged violations of Resource Conservation and Recovery...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Front Royal, Virginia Automobile Coatings Manufacturing...

The CA provides that ACS is an owner and operator of a facility (“Facility”) as those terms are defined in RCRA in Front Royal, Virginia. The Facility operates as an automobile coatings manufacturing facility. It is stated...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Inman, South Carolina Chemical Manufacturing Facility Enter...

The United States Environmental Protection Agency (“EPA”) and Milliken & Company (“MC”) entered into a July 9th Consent Agreement (“CA”) addressing an alleged violation of the South Carolina regulations related to the...more

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

Solid and Hazardous Waste Judicial/Regulatory Developments (2018-2019): Arkansas Environmental Federation Presentation...

I undertook a presentation on April 17th at the Arkansas Environmental Federation Regulated Waste Seminar titled: Solid and Hazardous Waste Judicial/Regulatory Developments: 2018 – 2019 - The discussion addressed...more

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

Criminal Enforcement/Hazardous Waste: U.S. Department of Justice References Guilty Plea of Madison Heights, Michigan,...

The United States Department of Justice (“DOJ”) issued a February 14th news release stating that Gary Alfred Sayers and his company, Electro-Plating Services Inc. (“EPSI”) pleaded guilty to a felony charge of illegal storage...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Detroit, Michigan Facility Complaint and Compliance Order

The United States Environmental Protection Agency (“EPA”) and DCI Aerotech Inc. (“DCI”) executed a Complaint and Compliance Order (“Order”) addressing alleged violations of the Resource Conservation and Recovery Act (“RCRA”)...more

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

Used Oil/Hazardous Waste Enforcement: U.S. Environmental Protection Agency and South Lyon, Michigan Metal Heat Treating Facility...

The United States Environmental Protection Agency (“EPA”) and Sun Steel Treating (“Sun”) entered into a June 21st Consent Agreement and Final Order (“CAFO”) addressing alleged violations of Resource Conservation and Recovery...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and U.S. Department of Navy Enter into Consent Agreement

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

Holland & Knight LLP

Issue Spotlight: Proper Hazardous Waste Storage and Disposal at Healthcare Facilities

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With all of the regulatory obligations that hospitals and other healthcare facilities need to comply with, it might be easy to overlook an environmental law that can lead to significant trouble. Hospitals may find themselves...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Beloit, Wisconsin Food Ingredient Manufacturer Enter into...

The United States Environmental Protection Agency (“EPA”) and Kerry Biofunctional Ingredients, Inc. d/b/a Kerry Bio Sciences (“Kerry”) entered into an April 10th Consent Agreement (“CA”) addressing alleged violations of...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and City University of New York Enter into Consent Agreement

The United States Environmental Protection Agency (“EPA”) and City University of New York (including Brooklyn College) (“CUNY”) entered into a March 8th Consent Agreement and Final Order (“CAFO”) addressing alleged violations...more

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

Criminal Enforcement/Resource Conservation and Recovery Act: United States Department of Justice Announces Guilty Plea of Metal...

The United States Department of Justice (“DOJ”) announced in an October 18th news release that Phillip Michael Huddleston pleaded guilty to violating the Resource Conservation Recovery Act (“RCRA”). DOJ states alleges that...more

Williams Mullen

Environmental Notes - October 2015

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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

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

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

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