In December, 2021, representatives of the timber and paper industry petitioned the EPA to ease restrictions on the burning of railroad ties and paper residuals as fuel without triggering strict hazardous waste combustion...more
The Environmental Protection Agency (EPA) has made several recent changes that will affect compliance obligations under the Resource Conservation and Recovery Act (RCRA). First, EPA finalized revisions to the definition of...more
The United States Environmental Protection Agency (“EPA”) in a February 7th Federal Register notice issued a final rule amending the Non-Hazardous Secondary Material Rule (“NHSMR”) to add certain treated railroad ties...more
One of the most vexing aspects of hazardous waste management hinges on a very basic question: whether something is in fact a regulated hazardous waste in the first place. This fundamental issue often arises for recycled or...more
It’s almost never easy to fathom federal environmental regulations and this held true when a set of regulations was recently issued by the U.S. EPA. On December 20, 2012, the Agency issued a series of rules, primarily under...more