The Association for State and Territorial Management Officials (“ASTSWMO”) published a position paper titled: DATA QUALITY ISSUES WITHIN THE HAZARDOUS WASTE e-MANIFEST SYSTEM (“Position Paper). The Position Paper...more
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
The US Environmental Protection Agency (EPA) published on February 8, 2024 two proposed rules addressing per- and polyfluoroalkyl substances (PFAS) under the Resource Conservation and Recovery Act (RCRA). The rules, if...more
The United States Environmental Protection Agency (“EPA”) issued a direct final rule on August 9th denominated: Hazardous Waste Generator Improvements Rule, the Hazardous Waste Pharmaceuticals Rule, and the Definition of...more
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
As part of an effort to improve the recycling and management of wastes from the generation and storage of renewable energy, the U.S. Environmental Protection Agency (EPA) recently announced that it is developing a proposed...more
As lithium-based batteries become more prevalent in everything from electric vehicles (EVs) to industrial-scale batteries, as well as e-scooters and personal electronics, more questions arise regarding how to properly manage...more
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
On New Year’s Eve, New York Governor Kathy Hochul signed New York’s “Cumulative Impacts” bill into law, making New York the second state in the nation to require assessment of “cumulative impacts” affecting certain...more
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
The Association of State and Territorial Solid Waste Management Officials (“ASTSWMO”) issued a February 2022 report titled: Best Practices to Ensure State Collaboration in Superfund (“Report”) ...more
I undertook an Arkansas Environmental Federation webinar held by the organization’s Land and Sustainability Committee on May 20th titled: Solid and Hazardous Waste/Recycling Administrative/Judicial Developments: 2020-2021...more
The United States Environmental Protection Agency (“EPA”) and Aphena Pharma Solutions – Maryland, LLC (“APS”) entered into a February 16th Consent Agreement (“CA”) addressing certain alleged violations of the Maryland...more
As previously reported, a coalition of environmental groups recently filed a petition for review in the D.C. Circuit Court of Appeals (D.C. Circuit) challenging the U.S. Environmental Protection Agency’s (EPA) recent final...more
On February 11, three environmental groups — Sierra Club, Alliance for Affordable Energy, and PennEnvironment, Inc. — filed a petition for review in the D.C. Circuit Court of Appeals (D.C. Circuit) challenging the U.S....more
The Tennessee Department of Environment and Conservation (“TDEC”) issued a December 1st proposed Director’s Order and Assessment (“Order”) to Methodist Healthcare – Memphis Hospitals (“MHMH”) addressing alleged violations of...more
The Tennessee Department of Environment and Conservation (“TDEC”) and Moody & Associates, Inc., d/b/a Technical Plating (“Moody”) entered into a Settlement Agreement and Order (“Agreement”) addressing alleged violations of...more
Following years of litigation and a segmented rulemaking process, the U.S. Environmental Protection Agency (EPA) finalized revisions to portions of its coal combustion residuals (CCR) regulations governing, among other...more
On June 8, 2020, the Administrator of the U.S. Environmental Protection Agency (EPA) signed a final rule to “modernize” the ignitability characteristic under the Resource Conservation and Recovery Act (RCRA), which is one of...more
Earthjustice on behalf of a number of environmental organizations sent a February 7th letter to United States Environmental Protection Agency (“EPA”) Administrator Andrew Wheeler styled...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
On July 2, 2019, the U.S. Court of Appeals for the District of Columbia Circuit decided the case of California Communities Against Toxics, et al. v. EPA. In this decision, the court rejected the latest petition to strike or...more
The United States Court of Appeals for the District of Columbia Circuit has upheld the Transfer-Based Exclusion in EPA’s final rule Revisions to the Definition of Solid Waste, 73 Fed. Reg. 64,668, 64,669 (Oct. 30, 2008). The...more
The United States Environmental Protection Agency (“EPA”) in a March 21st letter addressed a request to determine whether certain discarded carpet that a company plans to process into fuel would be considered a solid waste...more
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