The Association for State and Territorial Management Officials (“ASTSWMO”) published a position paper titled: DATA QUALITY ISSUES WITHIN THE HAZARDOUS WASTE e-MANIFEST SYSTEM (“Position Paper). The Position Paper...more
A United States District Court (E.D. California) (“Court”) addressed in a July 31st Order a federal question jurisdiction issue arising out of a Federal Resource Conservation and Recovery Act (“RCRA”) judicial action. See...more
Just past the halfway point of 2024, it's already been a busy year for those following regulatory developments related to per- and polyfluoroalkyl substances (PFAS). Building on its plans in the 2021 PFAS Strategic Road Map...more
EPA recently published a 2024 update to its Interim Guidance on the Destruction and Disposal of Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) and Materials Containing PFAS (Interim Guidance), as required by the...more
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
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
The United States Environmental Protection Agency (“EPA”) and Southern Galvanizing Company (“Southern”) entered into a March 26th Consent Agreement (“CA”) addressing alleged violations of the Federal and Maryland Hazardous...more
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
The United States Environmental Protection Agency (“EPA”) addressed in a March 22nd letter questions it was asked regarding the application of the Resource Conservation and Recovery Act (“RCRA”) to pharmaceutical hazardous...more
I undertook a presentation at the April 17, Arkansas Environmental Federation Land Seminar titled: Solid and Hazardous Waste/Recycling Administrative/Judicial Development – 2023-2024 The presentation...more
The Association of State and Territorial Solid Waste Management Officials (“ASTSWMO”) submitted March 26th comments to the United States Environmental Protection Agency (“EPA”) addressing a proposed rule which would amend the...more
The clock is winding down on businesses interested in commenting on EPA’s proposal to designate nine per- and polyfluoroalkyl substances (PFAS) as hazardous constituents under the Resource Conservation and Recover Act (RCRA)....more
The United States Environmental Protection Agency issued what it describes as “foundational policy document” for addressing climate adaption in the Resources Conservation and Recovery Act (“RCRA”) corrective action process....more
On February 8, 2024, the Environmental Protection Agency (EPA) published two proposed rules that would expand its regulatory authority over PFAS: one to list nine PFAS as hazardous constituents subject to the Resource...more
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
The Association of State and Territorial Solid Waste Management Officials (“ASTSWMO”) addressed in a January 26th letter to the United States Environmental Protection Agency (“EPA”) a question regarding a draft memorandum the...more
On February 8, 2024, EPA published a proposed rule to list nine PFAS, their salts and their structural isomers, as hazardous constituents under RCRA regulations. If the proposed rule is finalized, the nine PFAS (PFOA, PFOS,...more
The proposed rules would expand the RCRA Corrective Action regime to PFAS and potentially other emerging contaminants. They may complicate ongoing compliance efforts as well as lead to significant value chain impacts....more
U.S. Environmental Protection Agency (EPA) Administrator Michael Regan signed two proposed rules related to per- and polyfluoroalkyl substances (PFAS) and the agency’s corrective action authority under the Resource...more
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
The 1984 Hazardous and Solid Waste Amendments amended the Resource Conservation and Recovery Act (RCRA) to add the following sections requiring corrective action for releases of hazardous waste or hazardous constituents ...more
On February 8, 2024, the Environmental Protection Agency ("EPA") proposed two regulations that would add nine per- and polyfluoroalkyl substances ("PFAS") to the list of Resource Conservation and Recovery Act ("RCRA")...more
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
On February 8, 2024, the U.S. Environmental Protection Agency (EPA) published two proposed rules in the Federal Register that would expand the EPA’s authority to address certain per-and polyfluoroalkyl substances (PFAS) under...more
On February 8, 2024, the U.S. Environmental Protection Agency (EPA) proposed two rules to expand the Agency’s authority to address releases of per- and polyfluoroalkyl substances (PFAS) and other emerging contaminants at...more