News & Analysis as of

RCRA Waste Management

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

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

Gray Reed

Waste Management Companies Beware! The Resource Conservation and Recovery Act was Amended

Gray Reed on

In a previous post, I mentioned that contracts between public entities and private waste management companies usually contain compliance and regulation clauses.  Such a clause requires a waste management company to comply...more

Balch & Bingham LLP

Managing Solid Waste Challenges in the Energy Transition

Balch & Bingham LLP on

The transition to sustainable energy in the United States is reshaping how we create, store, and use energy – especially electricity – and the landscape is changing rapidly. This shift introduces new waste management...more

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

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,...

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

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

Open Burning/Open Detonation of Waste Explosives/RCRA: Association of State and Territorial Solid Waste Managing Officials'...

The Hazardous Waste Subcommittee of the Association of State and Territorial Solid Waste Management Officials (“ASTSWMO”) submitted June 20th comments to the United States Environmental Protection Agency (“EPA”) on its...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

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

Solid Waste Management Unites/Corrective Action: ASTSWMO Comments Addressing U.S. Environmental Protection Agency Proposed Rule...

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

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

Lead Contaminated Soil/Residential Sites: Association of State and Territorial Solid Waste Management Official's Comments on...

The Association of State and Territorial Solid Waste Management Officials (“ASTSWMO”) Board of Directors submitted a March 19th letter to the United States Environmental Protection Agency (“EPA”) providing comments on its...more

McGlinchey Stafford

EPA Test Methods 1633 and 1621 Shape Future of PFAS Management

McGlinchey Stafford on

The U.S. Environmental Protection Agency (EPA) finalized Test Methods 1633 and 1621, environmental sampling methods for analyzing up to 40 target per- and polyfluoroalkyl substances (PFAS) in soil, groundwater, and other...more

Morgan Lewis

EPA Releases Proposed Resource Conservation and Recovery Act PFAS Rules

Morgan Lewis on

The US Environmental Protection Agency (EPA) published on February 8, 2024 two proposed rules addressing per- and polyfluoroalkyl substances (PFAS) under the Resource Conservation and Recovery Act (RCRA). The rules, if...more

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

RCRA Info/2023 Biennial Report: Arkansas Department of Energy & Environment - Division of Environmental Quality Announces Module...

The Arkansas Department of Energy & Environment – Division of Environmental Quality (“DEQ”) circulated a reminder that states: The 2023 Biennial Report module in RCRAInfo is now open to start capturing data....more

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

Reconditioning/Used Drum Management: Cement Kiln Recycling Coalition Comments Addressing U.S. Environmental Protection Agency...

The Cement Kiln Recycling Coalition (“CKRC”) submitted November 21st comments to the United States Environmental Protection Agency (EPA”) addressing the following Advance Notice of Proposed Rulemaking (“ANPR”) titled: ...more

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

Technical Corrections / Hazardous Waste Generator Improvements / Pharmaceuticals / Definition of Solid Waste: U.S. Environmental...

The United States Environmental Protection Agency (“EPA”) issued a direct final rule on August 9th denominated: Hazardous Waste Generator Improvements Rule, the Hazardous Waste Pharmaceuticals Rule, and the Definition of...more

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

Reconditioning/Used Drum Management: ASTSWMO Comments Addressing U.S. Environmental Protection Agency Advance Notice of Proposed...

The Association of State and Territorial Solid Waste Management Officials (“ASTSWMO”) submitted comments to the United States Environmental Protection Agency (“EPA”) on November 22 addressing the following Advance Notice of...more

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

Hazardous Waste Management Program Implementation Costs: Association of State and Territorial Solid Waste Management Officials...

The Association of State and Territorial Solid Waste Management Officials (“ASTSWMO”) issued a November 2023 report titled: Hazardous Waste Management Program Implementation Costs Report (“Report”) - The Report was...more

Beveridge & Diamond PC

EPA Announces Plan to Modify and Expand the RCRA Universal Waste Rule for Lithium Batteries and Solar Panels

Beveridge & Diamond PC on

As part of an effort to improve the recycling and management of wastes from the generation and storage of renewable energy, the U.S. Environmental Protection Agency (EPA) recently announced that it is developing a proposed...more

Seyfarth Shaw LLP

USEPA Memo and Q&A on RCRA Rules for Lithium Ion and Lithium Metal Batteries

Seyfarth Shaw LLP on

Seyfarth Synopsis: USEPA has published a new Memo on RCRA Applicability to End-of-Life Lithium Batteries. ...more

K&L Gates LLP

EPA's Reinterpretation of the RCRA Industrial Ethyl Alcohol Exemption

K&L Gates LLP on

In November 2022, the US Environmental Protection Agency (EPA) published a memo regarding the management of discarded hand sanitizer under the Resource Conservation and Recovery Act (RCRA), which was discussed in a prior...more

Beveridge & Diamond PC

New EPA Guidance on Lithium-Ion Batteries Leaves Critical Questions Unanswered

On May 24, 2023, the U.S. Environmental Protection Agency (EPA or the Agency) issued guidance on the potential applicability of the nation’s hazardous waste regulatory program under the Resource Conservation and Recovery Act...more

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

Lithium Battery Recycling Regulatory Status: US Environmental Protection Agency Issues Memorandum Addressing Frequently Asked...

The United States Environmental Protection Agency (“EPA”) issued a May 24th Guidance Memorandum titled: Lithium Battery Recycling Regulatory Status and Frequently Asked Questions (“Memorandum”)...more

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

Draft U.S. Environmental Protection Agency National Enforcement and Compliance Document for Years 2024-2027: Association of State...

The United States Environmental Protection Agency (“EPA”) published in the January 12th Federal Register a Request for Public Comment on the National Enforcement and Compliance Initiatives (“NECIs”) it is proposing for fiscal...more

ArentFox Schiff

ESG Litigation Update: Circular Economy-Focused Litigation

ArentFox Schiff on

Americans have been “recycling” since colonial times. However, it wasn’t until the 1960s that Americans began viewing recycling ― often provided alongside rubbish removal ― a more formal solution to problems posed by consumer...more

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