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EPA's Reinterpretation of the RCRA Industrial Ethyl Alcohol Exemption

In November 2022, the US Environmental Protection Agency (EPA) published a memo regarding the management of discarded hand sanitizer under the Resource Conservation and Recovery Act (RCRA), which was discussed in a prior...more

Manifestly Different: New Responsibilities for Non-Hazardous Waste Handlers Hidden in E-Manifest Hazardous Waste Rules

New Responsibilities for Non-Hazardous Waste Handlers Hidden in E-Manifest Hazardous Waste Rules - U.S. Environmental Protection Agency’s (“EPA”) Final Rule on User Fees for Electronic Hazardous Waste Manifest Systems,...more

Less Waste, More Recycling - The D.C. Circuit Cleans Up EPA’s Definition of Solid Waste

The U.S. Court of Appeals for the D.C. Circuit recently issued a decision that may be of interest to recyclers and others who generate or handle materials for recycling and reclamation. On July 7, 2017, in American Petroleum...more

Coal Ash Backfill: Congress Authorizes EPA to Approve State Coal Combustion Residue Programs

As mentioned in our Alert of “A WIIN for Water Infrastructure” on the recently signed Water Infrastructure Improvements for the Nation (“WIIN”) Act, Congress included provisions intended to provide national consistency and...more

Air Dud: Emitters of Hazardous Substances Not Liable Under CERCLA

In a case of first impression, the Ninth Circuit recently ruled that facilities with air emissions that included hazardous substances could not be liable for remediating other properties contaminated by those hazardous...more

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