News & Analysis as of

Hazardous Waste Enforcement

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Buffalo, New York Diagnostics Facility Enter into Consent...

The United States Environmental Protection Agency (“EPA”) in IMMCO Diagnostics (“ID”) entered into an October 3 expedited settlement agreement (“ESA”) addressing an alleged violation of the Resource Conservation Recovery Act...more

McGlinchey Stafford

Stericycle Agrees to Pay $9.5 Million Civil Penalty for RCRA Violations

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On January 17, 2025, the Environmental Protection Agency (EPA) and the Department of Justice (DOJ) announced a $9.5 million settlement with Stericycle, Inc. for Hazardous Waste Management Violations. The settlement resolves...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Costa Mesa, California Automatic Control Valve Manufacturer...

The United States Environmental Protection Agency (“EPA”) and Griswold Industries (“GI”) entered into a January 3rd Expedited Settlement Agreement (“ESA”) addressing alleged violations of the Resource Conservation and...more

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

Hazardous Waste Enforcement: Tennessee Department of Environment and Conservation Proposed Order and Assessment Addressing Shelby...

The Tennessee Department of Environment and Conservation (“TDEC”) issued on November 15th a Proposed Director’s Order and Assessment (“OA”) to Tradebe Treatment and Recycling of Tennessee, LLC (“TTRT”) addressing alleged...more

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

Hazardous Waste Enforcement: Tennessee Department of Environment and Conservation Proposed Order Addressing Dayton Specialty...

The Tennessee Department of Environment and Conservation (“TDEC”) issued a December 16th Proposed Order and Assessment (“Order”) to Cymer-Dayton, LLC (“CD”). See Case No. HWM 24-0022. The Order provides that CD conducts...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Golden Meadow, Louisiana Port Services Facility Enter into...

The United States Environmental Protection Agency (“EPA”) and HOS Port, LLC (“HOS”) entered into an October 9th Consent Agreement and Final Order (“CAFO”) addressing alleged violations of the Resource Conservation and...more

McGlinchey Stafford

Trump’s Second Term and its Potential Impact on the Bona Fide Prospective Purchaser (BFPP) Defense Under CERCLA

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The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) aims to facilitate cleanup and accountability in hazardous waste sites. The Bona Fide Prospective Purchaser (BFPP) defense was introduced to...more

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

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

The Arkansas Department of Energy and Environment - Division of Environmental Quality (“DEQ”) and Ammunition Operations, LLC (“AO”) entered into a Consent Administrative Order (“CAO”) addressing an alleged violation of...more

McGlinchey Stafford

Potential Impacts on EPA Superfund Program During Trump’s Second Term

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The Environmental Protection Agency’s (EPA) Superfund Program is a cornerstone of the United States’ efforts to remediate contaminated sites and protect public health. The Superfund Program under President-Elect Donald...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Golden Meadow, Louisiana Port Service Facility Enter into...

The United States Environmental Protection Agency (“EPA”) and HOS Port, LLC (“HOS”) entered into an October 9th Consent Agreement and Final Order (“CAFO”) addressing alleged violations of the Resource Conservation and...more

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

Hazardous Waste Enforcement: Alabama Department of Environmental Management and Huntsville Space Flight Center Enter into Consent...

The Alabama Department of Environmental Management (“ADEM”) and George C. Marshall Space Flight Center (“MSFC”) entered into a July 10th Consent Order (“CO”) addressing an alleged violation of the Alabama Hazardous Waste...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Chemical Etching Manufacturer Enter into Expedited...

The United States Environmental Protection Agency (“EPA”) and PMA Industries, Inc. (“PMI”) entered into a May 9th Expedited Settlement Agreement (“ESA”) addressing alleged violations of the Federal Hazardous Waste...more

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

Hazardous Waste Enforcement: Alabama Department of Environmental Management and Refuse Truck Body Manufacturer Enter into Consent...

The Alabama Department of Environmental Management (“ADEM”) and the Heil Company, Inc. (“Heil”) entered into a June 12th Consent Order (“CO”) addressing alleged violations of the Alabama Hazardous Waste Regulations. See...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Wheeling, Illinois Solvent/Paint Coatings Manufacturer Enter...

The United States Environmental Protection Agency (“EPA”) and Sunnyside Corporation (“Sunnyside”) entered into a June 4th Consent Agreement and Final Order (“CAFO”) addressing alleged violations of the Illinois Hazardous...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Fredonia, Kansas Hazardous Waste Management Facility Enter...

The United States Environmental Protection Agency (“EPA”) and Systech Environmental Corp. (“STC”) entered into a February 22nd Consent Agreement and Final Order (“CAFO”) addressing the federal/Kansas hazardous waste...more

ArentFox Schiff

EPA Updates Interim Guidance on Destruction and Disposal of PFAS Wastes

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On April 8, the US Environmental Protection Agency (EPA) issued interim guidance for public comment regarding the destruction and disposal of per- and polyfluoroalkyl substances (PFAS). Below, we discuss the guidance and...more

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

Used Oil/Hazardous Waste Enforcement: Louisiana Department of Environmental Quality and Baton Rouge Industrial Equipment Testing...

The Louisiana Department of Environmental Quality (“LDEQ”) and Quality Testing, Inc. (“QTI”) entered into a Settlement Agreement (“SA”) addressing alleged violations of the Louisiana Used Oil and Hazardous Waste Regulations. ...more

Holland & Knight LLP

Senate Committee Convenes Hearing to Examine PFAS as Hazardous Substances

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The U.S. Environmental Protection Agency (EPA) issued a proposed rule on Sept. 6, 2022, to designate perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS), along with their structural isomers, as hazardous...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Andrews, Texas Radioactive Waste Treatment/Disposal Facility...

The United States Environmental Protection Agency (“EPA”) and Waste Control Specialists (“WCS”) entered into a February 24 Consent Agreement and Final Order (“CAFO”) alleging violations of certain Texas/federal hazardous...more

ArentFox Schiff

EPA Proposals on PFAS Compounds and Hazardous Waste May Presage Opening the Floodgates for RCRA Regulation and Enforcement

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On January 31, the US Environmental Protection Agency (EPA) issued two proposed rules to facilitate the targeting of PFAS. The first proposed rule would add certain per- and polyfluoroalkyl substances (PFAS) compounds to...more

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

Hazardous Waste Enforcement: Tennessee Department of Environment and Conservation Proposed Order/Assessment Addressing Chattanooga...

The Tennessee Department of Environment & Conservation (“TDEC”) issued a proposed Director’s Order and Assessment (“Order”) to Techniques Surfaces, USA, Inc. (“TS”) addressing alleged violations of the Tennessee hazardous...more

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

Environmental Criminal Enforcement/Motor Fuels: California Attorney General Files Felony Charges Addressing Alleged Sale of...

The California Attorney General (“AG”) filed on January 18th felony charges against Lamb Fuels, Inc. (“Lamb Fuels”) and two employees for allegedly illegally treating and transporting hazardous waste in California. The...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Shreveport, Louisiana, Refinery Enter into Consent Agreement

The United States Environmental Protection Agency (“EPA”) and Calumet Shreveport Refining, LLC (“Calumet”) entered into an October 25th Consent Agreement and Final Order (“CAFO”) addressing alleged violations of the Resource...more

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

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

The Alabama Department of Environmental Management (“ADEM”) and Safety-Kleen Systems, Inc. (“Safety-Kleen”) entered into a Consent Order (“CO”) addressing alleged violations of the Alabama Hazardous Waste Regulations. See...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Neodesha, Kansas, Boat Manufacturer Enter into Consent...

The United States Environmental Protection Agency (“EPA”) and Cobalt Boats, LLC (“Cobalt”) entered into a November 3rd Consent Agreement and Final Order (“CAFO”) addressing alleged violations of the federal and Kansas...more

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