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Use of Polymerization as Treatment Method: U.S. Environmental Protection Agency RCRA Guidance

The United States Environmental Protection Agency (“EPA”) addressed in a December 4, 2020, letter a request for a regulatory determination on hazardous waste generator activities associated with polymerization (“POLYM”) as a...more

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Detroit, Michigan, Chrome/Oxide Coating Manufacturer Enter...

The United States Environmental Protection Agency (“EPA”) and Perfection Industries, Inc. (“PII”) entered into a March 18th Consent Agreement and Final Order (“CAFO”) addressing alleged violations of certain Michigan rules...more

Closed Hazardous Waste Units/Office of Inspector General Report: U.S. Environmental Protection Agency Statement

A March 30th blog item was posted addressing a United States Environmental Protection Agency (“EPA”) Office of Inspector General (“OIG”) report titled: EPA Does Not Consistently Monitor Hazardous Waste Units Closed with...more

Closed Hazardous Waste Units: U.S. Environmental Protection Agency Office of Inspector General Report

The United States Environmental Protection Agency (“EPA”) Office of Inspector General (“OIG”) issued a March 29th report titled: EPA Does Not Consistently Monitor Hazardous Waste Units Closed with Waste in Place or Track...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Easton, Maryland, Pharmaceutical Packaging Manufacturer...

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

Phosphogypsum/Phosphoric Acid Production Wastewater: Center for Biological Diversity Petition to U.S. Environmental Protection...

The Center for Biological Diversity (“CBD”) and a number of other environmental organizations submitted a February 8th document to the United States Environmental Protection Agency (“EPA”) titled: Petition for Rulemaking...more

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Western Illinois University Enter into Consent Agreement and...

The United States Environmental Protection Agency (“EPA”) and Western Illinois University (“Western”) entered into a February 11th Consent Agreement and Final Order (“CAFO”) addressing alleged violations of the Illinois...more

Hazardous Waste Enforcement: Alabama Department of Environmental Management and Athens Automotive Gasket Manufacturing Facility...

The Alabama Department of Environmental Management (“ADEM”) and American Leakless Company LLC (“ALC”) entered into a November 9th Consent Order (“CO”) addressing alleged violations of the Alabama regulations related to...more

Criminal Enforcement/Water Control Law: Virginia Attorney General Announces Indictment of Whiskey Distillery

The Commonwealth of Virginia Office of the Attorney General (“AG”) issued a January 15th news release announcing indictments of a Virginia whiskey distillery for alleged violations of the Virginia Water Control Law. ...more

No Migration Variances/Resource Conservation and Recovery Act: U.S. Environmental Protection Agency Requests Comment on Petition...

The United States Environmental Protection Agency (“EPA”) published a January 19th Federal Register Notice requesting comments on guidance relating to the No Migration Variance (“NMV”) petition process. See 86 Fed. Reg. 5190....more

Hazardous Waste Enforcement: Alabama Department of Environmental Management and Huntsville Solar Panel Manufacturing Facility...

The Alabama Department of Environmental Management (“ADEM”) and LG Electronics USA, Inc. (“LG”) entered into a January 6th Consent Order (“CO”) addressing alleged violations of the ADEM Administrative Code addressing...more

Hazardous Waste Enforcement: Arkansas Department of Energy and Environment - Division of Environmental Quality and Hot Springs...

The Arkansas Department of Energy and Environment – Division of Environmental Quality (“DEQ”) and Timber Automation, LLC (“TA”) entered into a December 17th Consent Administrative Order (“CAO”) addressing alleged violations...more

Hazardous Waste Enforcement: Tennessee Department of Environment and Conservation Proposed Order/Assessment Related to Memphis...

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

Criminal Enforcement/Clean Water Act: Leetsdale, Pennsylvania, Copper-Processing Company Charged for Alleged Violations

The United States Attorney’s Office for the Western District of Pennsylvania issued a December 1st news release stating that a copper-processing company had been charged with three felony counts alleging violations of the...more

Hazardous Waste Enforcement: Alabama Department of Environmental Management and Limestone County Automotive Gasket Manufacturing...

The Alabama Department of Environmental Management (“ADEM”) and American Leakless Company LLC (“ALC”) entered into a November 9th Consent Order (“CO”) addressing alleged violations of Alabama hazardous waste regulations. See...more

Criminal Enforcement: Former Electronics Recycling Company President Sentenced for Alleged Hazardous Waste Violations

The United States Attorney for the Western District of Wisconsin issued a November 19th news release stating that James Moss (“Moss”) of Ladysmith, Wisconsin, was sentenced by a U.S. District Judge to 18 months in federal...more

Hazardous Waste Enforcement: Alabama Department of Environmental Management and Montgomery Hinge/Kick-Plate Manufacturing and...

The Alabama Department of Environmental Management (“ADEM”) and C. Hager & Sons Hinge Manufacturing Company, Inc. (“C. Hager”) entered into an October 21st Consent Order (“CO”) addressing alleged violations of the Alabama...more

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Grand Rapids, Michigan, Hospital Enter into Consent...

The United States Environmental Protection Agency (“EPA”) and Spectrum Health Hospitals (“Spectrum”) entered into an October 29th Consent Agreement and Final Order (“CAFO”) addressing alleged violations of the Resource...more

Universal Waste Enforcement: Arkansas Department of Energy and Environment – Division of Environmental Quality and Crittenden...

The Arkansas Department of Energy and Environment – Division of Environmental Quality (“DEQ”) and Upper Edge Technologies, Inc. (“Upper Edge”) entered into an October 13th Consent Administrative Order (“CAO”) addressing...more

Hazardous Waste Enforcement: Alabama Department of Environmental Management and Cullman County, Alabama, Hazardous Waste...

The Alabama Department of Environmental Management (“ADEM”) and Action Environmental, LLC, (“Action”) entered into an October 1st Consent Order (“CO”) addressing alleged violations of the ADEM Admin. Code addressing the...more

Renewable Energy: California Department of Toxic Substances Control Classifies Solar Panels as Universal Waste

The California Department of Toxic Substances Control (“DTSC”) announced in an October 26th news release that it was classifying hazardous waste (i.e., discarded) solar panels as universal waste. DTSC states that the...more

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Covington, Louisiana, Health Care Facility Enter into...

The United States Environmental Protection Agency (“EPA”) and Ochsner Health Center (“OHC”) entered into an October 6th Consent Agreement and Final Order (“CAFO”) addressing alleged violations of the Resource Conservation and...more

RCRA Guidance/COVID-19: Signing Paper Hazardous Waste Manifests

The United States Environmental Protection Agency (“EPA”) issued an August 20th memorandum titled: Statement About Signing Paper Hazardous Waste Manifest During the COVID-19 Public Health Emergency (“Statement”) - The...more

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Blue Cross Blue Shield of Louisiana Enter into...

The United States Environmental Protection Agency (“EPA”) and Blue Cross Blue Shield of Louisiana (“Blue Cross”) entered into a September 22nd Administrative Compliance Order on Consent (“Order”) addressing alleged violations...more

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