News & Analysis as of

Hazardous Waste

Mitchell, Williams, Selig, Gates & Woodyard,...

Engineering/Institutional Control Components of RCRA Corrective Action Remedies: U.S. Environmental Protection Agency Guidance...

The United States Environmental Protection Agency (“EPA”) Office of Resource Conservation and Recovery transmitted a November 24, 2025, guidance document addressing the following subject: Long-Term Implementation of...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Blythe, California Solar Power Station Enter into Expedited...

The United States Environmental Protection Agency (“EPA”) and Genesis Solar, LLC (“GS”) entered into a January 12th Expedited Settlement Agreement (“ESA”) addressing an alleged violation of the Resource Conservation and...more

FBT Gibbons LLP

NYSDEC Finalizes Important Amendments to Its Brownfield and Superfund Regulations

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On December 31, 2025, the New York State Department of Environmental Conservation (NYSDEC) finalized important amendments to the regulations that implement its remedial programs, including the Brownfield Cleanup Program (BCP)...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing Waste...

The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”)  addressed in a January 6th Interpretive Letter clarification of the Hazardous Materials Regulations (“HMR”) applicable to the definition of a...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Evaluation of the EPA's e-Manifest System: U.S. EPA Office of Inspector General Project Notification

The United States Environmental Protection Agency (“EPA”) Office of Inspector General (“OIG”) issued a November 19th notification memorandum titled: Evaluation of the EPA’s e-Manifest System (“Memorandum”)....more

Mitchell, Williams, Selig, Gates & Woodyard,...

Hazardous Waste Enforcement: Louisiana Department of Environmental Quality and Houma Marine/Industrial Coatings Distributor Enter...

The Louisiana Department of Environmental Quality (“LDEQ”) and All America Paint & Supply, Inc. (“AAPS”) entered into a Settlement Agreement (“SA”) addressing alleged violations of the Louisiana Hazardous Waste Regulations....more

Allen Matkins

California Environmental Law & Policy Update 12.5.25

Allen Matkins on

The California Board of Environmental Safety on November 17 approved the state’s first hazardous waste management plan despite sharp criticism from environmental groups who say several aspects of the plan could invite...more

Goldberg Segalla

How New York State’s Superfund Amendments are Expanding the Use of Environmental Liens

Goldberg Segalla on

Gov. Kathy Hochul’s recently enacted budget bill for 2025-2026 includes several important changes to the New York State Superfund program. The Superfund was created to help enforce state hazardous waste regulations and to...more

Vorys, Sater, Seymour and Pease LLP

US EPA Issues Draft Approval of Additional Authorization for Ohio’s RCRA Program

On November 18, 2025, US EPA proposed approving the state of Ohio’s application for further authorization of its state Resource Conservation and Recovery Act (RCRA) program. 90 Federal Register 51625 (November 18, 2025)....more

Mitchell, Williams, Selig, Gates & Woodyard,...

Trespass/Nuisance: Family Trust Files Benton County, Arkansas Circuit Court Action Lowell Facility Alleging Illegal Mining/Dumping

The Trustees of the McJunkins Family Trust U/A (“Trust”) filed a November 11th pleading in the Circuit Court of Benton County, Arkansas styled: Complaint at Law and Request for Injunctive Relief with Request for Emergency...more

Allen Matkins

California Environmental Law & Policy Update 10.31.25

Allen Matkins on

Exxon Mobil last Friday filed suit in federal court challenging two California laws that would require the oil company to report greenhouse gas emissions resulting from the use of its products globally. The 30-page complaint,...more

Winstead PC

EPA’s New Residential Lead Directive: Key Implications for Developers and Investors

Winstead PC on

On October 16, 2025, the U.S. Environmental Protection Agency’s (EPA) Office of Land and Emergency Management (OLEM) issued the Residential Lead Directive for CERCLA Sites and RCRA Hazardous Waste Cleanup Program Facilities...more

Vorys, Sater, Seymour and Pease LLP

US EPA Announces Rulemaking for End-of-Life Treatment of Solar Panels & Lithium Batteries

US EPA recently announced the intention to revise the federal universal waste regulatory framework under the Resource Conservation and Recovery Act (RCRA) to reflect an increase in valuable wastes from the evolving...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Wood Treaters/Resource Conservation and Recovery Act: U.S. Environmental Protection Agency Interpretive Letter Response to Treated...

United States Environmental Protection Agency (“EPA”) Office of Resource Conservation and Recovery Deputy Director Andrew Baca transmitted an October 8th Interpretive Letter addressing issues involving wood treatment....more

Williams Mullen

Multiphase Solid Waste Ignitability Rule: Regulating the Unknown

Williams Mullen on

Deciding the regulatory status of solid phase wastes is difficult but determining whether those wastes should be evaluated as ignitable liquids at some time in the future is nearly impossible. Yet, that is what the law...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Residential Lead Directive for CERCLA Sites/RCRA Hazardous Waste Cleanup Program Facilities: U.S. Environmental Protection Agency...

The United States Environmental Protection Agency (“EPA”) issued an October 16th directive titled: Residential Lead Directive for CERCLA Sites and RCRA Hazardous Waste Cleanup Program Facilities (“Directive”)....more

Mitchell, Williams, Selig, Gates & Woodyard,...

Hazardous Waste Enforcement: Alabama Department of Environmental Management Proposed Order Addressing Montgomery Automotive Part...

The Alabama Department of Environmental Management (“ADEM”) issued a September 28th Order to Gerhardi, Inc. (“GI”) addressing alleged violations of Alabama hazardous waste regulations. GI is stated to operate an...more

Mitchell, Williams, Selig, Gates & Woodyard,...

U.S. Environmental Protection Agency Hazardous Waste Electronic Manifest System: Association of State and Territorial Solid Waste...

The Hazardous Waste Subcommittee of the Association of State and Territorial Solid Waste Management Officials (“ASTSWMO”) sent a September 16th letter providing comments to the United States Environmental Protection Agency...more

Haynes Boone

Three’s a Regulatory Crowd: Hong Kong Convention Enters Into Force Amidst Existing Recycling Regulation Regimes

Haynes Boone on

After more than 15 years since its adoption, triggered by the ratifications of Bangladesh and Liberia, the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009 (Hong Kong...more

Shipman & Goodwin LLP

Aisle Be Back…If My Floor Isn’t Forever Contaminated: PFAS in Floor Waxes and Other Products

Shipman & Goodwin LLP on

With new scientific information and legal developments emerging daily, concerns over per- and polyfluoroalkyl substances (PFAS) contamination have moved from future threat to present liability —including for buildings that...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Ladson, South Carolina Vehicle Assembly Plant Enter into...

The U.S. Environmental Protection Agency (“EPA”) and Mercedes-Benz Vans, LLC, (“MBV”) entered into a June 16th Consent Agreement (“CA”) addressing alleged violations of the Hazardous Waste Regulations. See Docket No....more

Mitchell, Williams, Selig, Gates & Woodyard,...

Multimedia Enforcement: Louisiana Department of Environmental Quality and Broussard Oil Services Storage/Distribution Center Enter...

The Louisiana Department of Environmental Quality (“LDEQ”) and Clariant Corporation (“CC”) entered into a Settlement Agreement (“Agreement”) addressing alleged violations of the hazardous waste, SPCC, and stormwater...more

K&L Gates LLP

Vermont's Agency of Natural Resources to Implement Nation's First Household Hazardous Waste Stewardship Program

K&L Gates LLP on

Vermont has become the first state in the nation to implement a household hazardous waste extended producer responsibility law. This is an important development for two key reasons....more

Mitchell, Williams, Selig, Gates & Woodyard,...

Hazardous Waste Enforcement: Mississippi Commission on Environmental Quality and Hernando Automotive Products Formulator Enter...

The Mississippi Commission on Environmental Quality (“MCEQ”) and Niteo Products LLC (“NP”) entered into a June 17th Agreed Order (“AO”) addressing alleged violations of the Mississippi Hazardous Waste Regulations. See Order...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Hazardous Waste Enforcement: Alabama Department of Environmental Management and Brewton Railcar Repair Facility Enter into Consent...

The Alabama Department of Environmental Management (“ADEM”) and Frit Car, Inc. (“FCI”) entered into an August 6th Consent Order (“CO”) addressing alleged violations of the Alabama Hazardous Waste Regulations. See Consent...more

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