News & Analysis as of

Standard Operating Procedures Environmental Protection Agency (EPA)

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Borger, Texas, Refinery Enter into Consent Agreement

The United States Environmental Protection Agency (“EPA”) and Phillips 66 Company (“Phillips 66”) entered into a September 15th Consent Agreement and Final Order (“CAFO”) addressing alleged violations of the Resource...more

Jenner & Block

New EPA Rule Removes Emergency Defense Waiver in Title V Air Permits

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On July 21, 2023, the Environmental Protection Agency published a final rule eliminating an affirmative defense for Clean Air Act permit emissions violations caused by “emergency” circumstances. “Major sources” (i.e....more

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

Overseeing the Validity of Financial Assurance Mechanisms: U.S. Environmental Protection Agency RCRA Guidance Memorandum

The United States Environmental Protection Agency (“EPA”) issued a June 17th Resource Conservation and Recovery Act (“RCRA”) guidance memorandum (“Memo”) titled: Overseeing the Validity of Financial Assurance Mechanisms...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Covington, Louisiana, Health Care Facility Enter into...

The United States Environmental Protection Agency (“EPA”) and Ochsner Health Center (“OHC”) entered into an October 6th Consent Agreement and Final Order (“CAFO”) addressing alleged violations of the Resource Conservation and...more

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

Generator Improvements Rule/Definition of Solid Waste Revision: Penny J. Wilson (Arkansas Department of Environmental Quality)...

Penny J. Wilson undertook a presentation at the Arkansas Environmental Federation Regulated Waste Seminar that addressed two topics related to the Resource Conservation and Recovery Act (“RCRA”): Generator Improvements...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and San Antonio, Texas Medical Facility Operator...

The United States Environmental Protection Agency (“EPA”) and Gastroenterology Consultants of San Antonio, P.A. (“GCS”) entered into a Consent Agreement and Final Order (“CA”) addressing alleged Resource Conservation and...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Nashville, Tennessee Hospital Owner Enter into Consent...

The United States Environmental Protection Agency (“EPA”) and Hospital Authority of the Metropolitan Government of Nashville and Davidson County (d/b/a Nashville General Hospital [“Metropolitan”]) entered into a September...more

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