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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
On January 31, the US Environmental Protection Agency (EPA) issued two proposed rules to facilitate the targeting of PFAS. The first proposed rule would add certain per- and polyfluoroalkyl substances (PFAS) compounds to...more
The United States Environmental Protection Agency (“EPA”) issued a pre-publication final rule adding hazardous waste aerosol cans to the universal waste program under the federal Resource Conservation and Recovery Act...more
Seyfarth Synopsis: Last week the U.S. Environmental Protection Agency (EPA) finalized a “streamlined system” for managing hazardous waste aerosol cans as Universal Waste. The Agency believes that the new system will be...more
This is the eighth issue of WilmerHale’s 10-in-10 Hot Topics in Energy Series. Over the course of 10 weeks, our attorneys will share insights on current and emerging issues affecting the US energy sector. Attorneys from...more
The U.S. Environmental Protection Agency (the “EPA”) launched its new Hazardous Waste Electronic Manifest (“e-Manifest”) System on June 30, 2018. The new requirements impact all U.S. companies that handle waste requiring a...more
The Ninth Circuit recently ruled that the Resource Conservation and Recovery Act’s (RCRA) anti-duplication provisions under 42 USC § 6905 do not apply in the absence of a stormwater discharge permit issued under the Clean...more
The United States Court of Appeals for the District of Columbia Circuit recently rejected portions of an EPA rule designed to distinguish true recycling from “sham recycling” under the Resource Conservation and Recovery Act...more
On July 7, 2017, the U.S. Court of Appeals for the District of Columbia Circuit (“D.C. Circuit” or the “Court”) issued a decision invalidating two key elements of the regulatory definition of solid waste under the Resource...more
The Michigan Department of Environmental Quality (MDEQ) recently announced that it will be evaluating the vapor intrusion (VI) pathway at 4,000 sites, including as many as 375 Resource Conservation and Recovery Act (RCRA)...more
Prompted by a 2013 Commission for Environmental Cooperation (CEC) report on hazardous waste exports from the U.S. and changes to the 2001 Organization for Economic Cooperation and Development’s (OECD) Council Decision for...more
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
After years of relative easing in its interpretation of the Resource Conservation and Recovery Act rules that govern industrial recycling, the Environmental Protection Agency is now taking a harder line. A recently issued...more
Today EPA issued a final rule regulating coal combustion residuals (CCR) as solid waste under Subtitle D of the Resource Conservation and Recovery Act (RCRA). This ends years of speculation regarding whether EPA might decide...more
Our firm has recently represented clients in two projects associated with brownfields that may signal an increased willingness on the part of regulatory authorities to facilitate redevelopment of contaminated properties. ...more