News & Analysis as of

RCRA New Guidance

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

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

Seyfarth Shaw LLP

New Year, New Penalties: OSHA and USEPA Increase Penalties

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The federal Occupational Safety and Health Administration (OSHA) and Environmental Protection Agency (“EPA”) have published their 2025 increases to civil penalties....more

Goldberg Segalla

Leading with Lead: EPA to Implement Strategy for Lead in 2024

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The U.S. Environmental Protection Agency kicked off the New Year by strengthening its guidance for investigating and cleaning up lead-contaminated soil at residential properties, especially in areas where children live and...more

Pillsbury Winthrop Shaw Pittman LLP

EPA Clarifies Requirements for Management of End-of-Life Lithium-Ion Batteries under RCRA

New EPA guidance clarifies the application of federal hazardous waste requirements under the Resource Conservation and Recovery Act (RCRA) to the management and recycling of spent lithium-ion batteries. As the demand for...more

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

Allowing Remote Signers for Electronic Manifests: U.S. Environmental Protection Agency Issues Guidance

The United States Environmental Protection Agency (“EPA”) issued May 5th Resource Conservation and Recovery Act (“RCRA”) guidance titled: Allowing Remote Signers for Electronic Manifests (“Guidance”)...more

ArentFox Schiff

New Guidance from EPA Finds Spent Li-Ion Batteries Are “Hazardous Waste” Under RCRA

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Already among the most widely used battery chemistry, lithium-Ion (Li-Ion) batteries are experiencing a rapid increase in use and demand. A growing number of these energy-dense batteries are being manufactured and used in...more

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

Comparison of U.S. Environmental Protection Agency Underground Storage Tank Regulations and National Fire Protection Association...

The Association of State and Territorial Solid Waste Management Officials (“ASTSWMO”) published a document titled: Comparing EPA UST Regulations and NFPA Fire Codes (“Guidance”)...more

Nossaman LLP

EPA Announces Update to Civil Monetary Penalties – Impacts on Water Providers

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On January 6, 2023, the U.S. Environmental Protection Agency (EPA) announced its Final Rule, listed at 88 FR 986, updating the maximum civil monetary penalties that may be assessed for violations of environmental statutes....more

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

Open Burning/Open Detonation of Waste Explosives Under the Resource Conservation and Recovery Act: U.S. Environmental Protection...

The United States Environmental Protection Agency (“EPA”) issued a June 7th guidance document titled: Open Burning and Open Detonation (OB/OD) of Waste Explosives Under the Resource Conservation and Recovery Act (RCRA)...more

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

Applicability of RCRA Organic Air Emission Standards to Equipment and/or Closure Devices/Subpart BB v. Subpart CC: U.S....

The United States Environmental Protection Agency (“EPA”) issued a December 22, 2021, memorandum titled: Applicability of RCRA Organic Air Emission Standards to Equipment and/or Closure Devices, Subpart BB versus Subpart...more

Woods Rogers

Environmental Justice Emerges as EPA and Virginia Priority

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Recent guidance issued by the U.S. Environmental Protection Agency (“EPA”) evidences EPA’s intention to better incorporate Environmental Justice (“EJ”) considerations into program administration and enforcement. ...more

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

Use of Polymerization as Treatment Method: U.S. Environmental Protection Agency RCRA Guidance

The United States Environmental Protection Agency (“EPA”) addressed in a December 4, 2020, letter a request for a regulatory determination on hazardous waste generator activities associated with polymerization (“POLYM”) as a...more

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

Resource Conservation and Recovery Act Guidance Memorandum: e-Manifest User Fees FY 2020/FY 2021

The United States Environmental Protection Agency (“EPA”) addressed in a July 22nd memorandum how the Office of Resource Conservation and Recovery (“ORCR”) is setting user fees for the e-Manifest Program. The Guidance...more

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

RCRA Guidance: U.S. Environmental Protection Agency Addresses Terms Owner or Operator

The United States Environmental Protection Agency (“EPA”) added a December 17, 2018, letter to its Resource Conservation and Recovery Act (“RCRA”) Compendium (“Compendium”) addressing the terms “owner” or “operator.” The...more

Williams Mullen

Environmental Notes - October 2018

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EPA has announced a new compliance policy that some will view as providing welcome relief to industry and others may view as providing unwarranted concessions. The subject line of the EPA memo announcing the new policy is...more

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

Polyurethane Processing: American Chemistry Guidelines for Management and Disposal of Hazardous Wastes

The American Chemistry Council (“ACC”) issued a guidance document titled: Guidelines for Management and Disposal of Hazardous Wastes from Polyurethane Processing (“Guidelines”) ...more

Seyfarth Shaw LLP

EPA Takes Positions on Vapor Intrusion

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In a busy day for vapor intrusion, last week the U. S. Environmental Protection Agency made several announcements about vapor intrusion. First, it announced it had submitted a draft rule to the White House OMB seeking to...more

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