News & Analysis as of

RCRA Hazardous Waste

Jenner & Block

Legal Considerations Concerning the End-of-Life Management of Solar, Wind, and Battery Technologies in the US

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Solar, wind, and battery technologies have, and will continue to be, front and center of the renewable energy and clean technology transition. Entities in the renewable energy and clean technology space should be closely...more

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

The Tennessee Department of Environment and Conservation (“TDEC”) issued a May 14th Director’s Order and Assessment (“Order”) to Federal Express Corporation (“Federal Express”). See Case No. HWM 24-0028....more

Troutman Pepper Locke

New Texas Railroad Commission Rules: Challenges and Permitting for the E&P Industry

Troutman Pepper Locke on

On December 17, 2024, the Railroad Commission of Texas (RRC) adopted new comprehensive regulations governing the handling, storage, treatment, and disposal of oil and gas waste. The rules were published January 3, 2025, in...more

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

Hazardous Waste Enforcement: Alabama Department of Environmental Management and Lincoln Automobile Manufacturing Facility Enter...

The Alabama Department of Environmental Management (“ADEM”) and Honda Development & Manufacturing of America, LLC DBA Alabama Auto Plant (“Honda”) entered into a Consent Order (“CO”) addressing alleged violations of the...more

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U.S. House of Representatives Appropriation Committee: Association of State and Territorial Solid Waste Management Officials...

The Association of State and Territorial Solid Waste Management Officials (“ASTSWMO”) submitted testimony to the United States House Appropriations Subcommittee on Interior, Environment, and Other Related Agencies. The...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Tracy, California Glass Container Manufacturing Facility...

The United States Environmental Protection Agency (“EPA”) and Owens-Brockway Glass Container Inc. (“OB”) entered into an April 8th Consent Agreement (“CA”) addressing alleged violations of the Resource Conservation and...more

Williams Mullen

Drumming Up a Change? EPA’s Review of the RCRA “Empties” Rule and Its Impact on Generators and the Drum Reconditioning Industry

Williams Mullen on

EPA recently initiated a rulemaking process aimed at reviewing how empty industrial drums are regulated under the Resource Conservation and Recovery Act (RCRA). This is a move which could have significant implications for...more

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RCRA Guidance Letter/Military Munitions Rule: U.S. Environmental Protection Agency Addresses Manifest Exemption for Geographically...

The United States Environmental Protection Agency (“EPA”) Office of Resource Conservation Recovery addressed in a March 6th Resource Conservation and Recovery Act (“RCRA”) guidance letter a request from the University of...more

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

The Alabama Department of Environmental Management (“ADEM”) and Sanmina Corporation (“SC”) entered into a Consent Order (“CO”) addressing alleged violations of the Alabama Hazardous Waste Regulations. See Consent Order No....more

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Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Camden, New Jersey Drum Reconditioner Enter into Consent...

The United States Environmental Protection Agency (“EPA”) and Patrick J. Kelly Drums, Inc. (“PJKD”) entered into a February 27th Consent Agreement and Final Order (“CAFO”) addressing alleged violations of the Resource...more

Paul Hastings LLP

RCRA Rules Face Hazardous Times

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In an executive order issued February 19, 2025, President Donald Trump instructed federal agency heads to “initiate a process to review all regulations subject to their sole or joint jurisdiction” for purposes of “rescinding...more

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Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Columbus, Ohio Paint Corporation Enter Into Expedited...

The United States Environmental Protection Agency (“EPA”) and Yenkin-Majestic Paint Corporation (“YMPC”) entered into a February 19th Expedited Settlement Agreement (“ESA”) addressing alleged Resource Conservation Recovery...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Allentown, Pennsylvania Coil Coating Facility Enter into...

The United States Environmental Protection Agency (“EPA”) and Vorteq Coil Finishers, LLC (“Vorteq”) entered into a January 22nd Consent Agreement (“CA”) addressing alleged violations of the Resource Conservation and Recovery...more

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

McGlinchey Stafford on

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

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Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Cedar Rapids, Iowa Industrial Paint Manufacturer Enter into...

The United States Environmental Protection Agency (“EPA”) and Klinger Paint Company, Inc. (“Klinger”) entered into a January 7th Consent Agreement and Final Order (“CAFO”) addressing alleged violations of the Resource...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: 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

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

Treatment, Storage, and Disposal Facilities/Climate Risks: U.S. Government Accountability Office Report Recommending U.S....

The United States Government Accountability Office (“GAO”) issued a November 2024 report titled: Hazardous Waste: EPA Should Take Additional Actions to Encourage Treatment, Storage, and Disposal Facilities to Manage...more

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

Universal Waste Rule/Solar Panel and Lithium Battery Universal Waste Proposed Rule: Association of State and Territorial Solid...

The Association of State and Territorial Solid Waste Management Officials (“ASTSWMO”) submitted comments to the United States Environmental Protection Agency (“EPA”) addressing a Solar Panel and Lithium Battery Universal...more

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

Data Quality Issues Within the Hazardous Waste e-Manifest System: Association for State & Territorial Solid Waste Management...

The Association for State and Territorial Solid Waste Management Officials (“ASTSWMO”) published a position paper titled: DATA QUALITY ISSUES WITHIN THE HAZARDOUS WASTE e-MANIFEST SYSTEM (“Position Paper”)....more

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Citizen Suit Action/RCRA: Federal Court Addresses Applicability to Agency Supervised Site Remediation

The United States District Court for the District of New Jersey (“Court”) addressed in a June 25th Opinion an issue arising out of a Resource Conservation and Recovery Act (“RCRA”) citizen suit action. See Raritan Baykeeper,...more

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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: U.S. Environmental Protection Agency and Richmond, Missouri Epoxy Manufacturing Facility Enter into...

The United States Environmental Protection Agency (“EPA”) and Arnette Polymers, LLC (“Arnette”) entered into an August 19th Consent Agreement and Final Order (“CAFO”) addressing alleged violations of the Missouri hazardous...more

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

Data Quality Issues Within the Hazardous Waste e-MANIFEST System: Association for State and Territorial Solid Waste Management...

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

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