The United States Environmental Protection Agency (“EPA”) issued a prepublication version of a Final Rule that would designate two of the Per-and polyfluoroalkyl substances (“PFAS”) as Comprehensive Environmental Response,...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
The Environmental Protection Agency (EPA) has made several recent changes that will affect compliance obligations under the Resource Conservation and Recovery Act (RCRA). First, EPA finalized revisions to the definition of...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
Time to Pay More: EPA Increases Maximum Civil Penalties - Remember the days when the maximum civil penalty EPA could assess for a violation of environmental law was $25,000 per day? Those days disappeared 26 years ago...more
EPA has tentatively denied a petition to expand the test for the hazardous waste characteristic of corrosivity to cover more wastes. In so doing, however, EPA left the door open to reconsider the decision based on public...more
Earlier this week, the D.C. Circuit Court of Appeals rejected both industry and environmental group petitions challenging EPA’s determination of what is a solid waste in the context of Clean Air Act standards for incinerators...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