News & Analysis as of

Hazardous Waste Appeals

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

Hazardous Waste Enforcement: Tennessee Division of Solid Waste Management Proposed Order and Assessment Addressing Ripley...

The Tennessee Division of Solid Waste Management (“TDSWM”) issued a February 7th Proposed Director’s Order and Assessment (“Order”) to SRG Global Coatings, LLC (“SRG”). See Case No. HWM 24-0024. The Order provides that...more

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

RCRA Corrosivity Hazardous Waste Characteristic: Federal Appellate Court Addresses Denial of Petition Requesting Expansion

The United States Court of Appeals for the District of Columbia (“Court”) addressed in a July 25th decision an issue involving the Resource Conservation and Recovery Act (“RCRA”) hazardous waste characteristic of corrosivity....more

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

Hazardous Waste Enforcement: Tennessee Department of Environment and Conservation Proposed Order Addressing Rocky Top Office...

The Tennessee Department of Environment and Conservation (“TDEC”) issued an April 12th proposed Director’s Order and Assessment (“Order”) to Ultra Tech Extrusions of Tennessee, Inc. (“Ultra Tech”) addressing alleged...more

Mintz

Another case in which a non-governmental organization wants a court to tell EPA how to do its job

Mintz on

Yesterday a three judge panel of the United States Court of Appeals for the District of Columbia heard from lawyers for the Public Employees for Environmental Responsibility (PEER) and the Environmental Protection Agency...more

Downey Brand LLP

Board of Environmental Safety: California’s New Hazardous Waste Permit Review Authority is Ramping Up

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In July 2021, Governor Gavin Newsom signed SB 158 into law, which established the Board of Environmental Safety (BES)—an agency charged with overseeing the Department of Toxic Substances Control’s (DTSC) hazardous waste...more

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

Oakland Athletics Strike Out: California Appellate Court Rejects Team's Petition Seeking Regulation of Metal-Shredding Operation...

The California Court of Appeal (First District – Division 3) (“Court of Appeal”) in a September 30th Opinion addressed The Oakland Athletics’ (The Athletics Investment Group, LLC) (“Athletics”) argument that the California...more

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

Hexavalent Chromium/RCRA: Federal Appellate Court Reconsiders Public Water System Liability

The United States Court of Appeals for the Ninth Circuit (“Ninth Circuit”) in a July 1st Opinion addressed a prior September 29th decision discussing the potential liability of a public water system pursuant to the imminent...more

Perkins Coie

California River Watch v. Vacaville: “A Better Considered Position” Under RCRA

Perkins Coie on

The U.S. Court of Appeals for the Ninth Circuit, on July 1, 2022, took the extraordinary step of reversing its prior decision in California River Watch v. City of Vacaville. The Ninth Circuit ruled that “transportation” under...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Eleventh Circuit Limits Reach of OSHA’s ‘HazWoper’ Standard

On June 15, 2022, the United States Court of Appeals for the Eleventh Circuit issued a decision limiting the reach of the emergency response provisions of 29 C.F.R. § 1910.120, the Occupational Safety and Health...more

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

Sale of Commercial Property: New Jersey Appellate Court Addresses Whether Remediation Contractor Owed Duty to Subsequent Property...

The Superior Court of New Jersey, Appellate Division (“Court”) addressed in a January 12th Opinion an issue relating to the environmental remediation of a commercial property. See Sunway Equity, LLC v. Suburban Propane, LP,...more

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

Hazardous Waste Enforcement: Tennessee Department of Environment and Conservation Proposed Order Addressing Kingston Treatment...

The Tennessee Department of Environment and Conservation (“TDEC”) issued a proposed Director’s Order and Assessment (“Order”) to Diversified Scientific Services, Inc. (“DSSI”) addressing alleged violations of the Tennessee...more

Downey Brand LLP

Ninth Circuit Finds that Distribution of Drinking Water Containing MCL-Compliant Levels of Hexavalent Chromium Gives Rise to RCRA...

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The Ninth Circuit recently issued a decision in Cal. River Watch v. City of Vacaville (Case No. 20-16605) (“Vacaville”) regarding the breadth of Resource Conservation and Recovery Act (“RCRA”) liability for contributing to...more

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

Hazardous Waste Regulations: Louisiana Appellate Court Addresses Whether Verified Reclamation Variance Is Appealable

The Court of Appeal of Louisiana (First Circuit) (“Court”) issued a September 23rd opinion addressing a challenge to the Louisiana Department of Environmental Quality’s (“LDEQ”) granting of a Verified Reclamation Facility...more

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

Hazardous Waste Incinerator/Clean Air Act: U.S. EPA Environmental Appeals Board Addresses Petition Challenging Title V Permit

The United States Environmental Protection Agency (“EPA”) Environmental Appeals Board (“EAB”) issued a July 21st Order addressing a Petition by the American Bottom Conservancy (“Conservancy”) which challenged the issuance...more

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

U.S. Environmental Protection Agency e-Manifest User Fees: Environmental Technology Council Files United States Court of Appeals...

The Environmental Technology Council (“ETC”) filed a Petition for Review (“Petition”) in the United States Court of Appeals for the District of Columbia challenging the fee schedule issued by the United States Environmental...more

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

U.S. EPA Environmental Appeals Board: Vickery, Ohio Hazardous Waste TSD Facility Challenges Certain Permit Conditions

Vickery Environmental, Inc. (“Vickery”) filed an October 7th Petition for Review (“Petition”) before the United States Environmental Protection Agency (“EPA”) Environmental Appeals Board (“EAB”) challenging certain conditions...more

Holland & Hart LLP

RCRA's Definition of Solid Waste – The DC Circuit Brings Clarity to a Core Element of RCRA

Holland & Hart LLP on

The United States Court of Appeals for the District of Columbia Circuit has upheld the Transfer-Based Exclusion in EPA’s final rule Revisions to the Definition of Solid Waste, 73 Fed. Reg. 64,668, 64,669 (Oct. 30, 2008). The...more

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

Waste Derived Fuels/Cement Manufacturing Facility: Indiana Appellate Court Addresses Zoning Classification Issue

The Court of Appeals of Indiana “Court“ in an April 18th opinion addressed a zoning question associated with a cement kiln’s desire to utilize liquid waste derived fuels (“LWDF”). See Essroc Cement Corp v. Clark County Board...more

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

Environmental Assessment/Engineering Firm: Massachusetts Appellate Court Addresses Application of Statute of Limitations to...

he Appeals Court of Massachusetts (“Appellate Court”) addressed in an April 12th opinion whether a malpractice action against a former engineering firm and its owner was barred by the statute of limitations. See Cedar Crest...more

Bennett Jones LLP

Washington Court Affirms Assertion of Specific Jurisdiction over Canadian Mining Company

Bennett Jones LLP on

On September 14th, 2018, the United States (U.S.) Court of Appeals for the Ninth Circuit in the Eastern District of Washington (the "Court"), upheld the District Court decision to hold Canadian mining company, Teck Cominco...more

Akin Gump Strauss Hauer & Feld LLP

Stay or Go: D.C. Circuit Halts EPA’s Stay of Obama-era Risk Management Plan Amendments

On August 17, 2018, the United States Court of Appeals for the District of Columbia Circuit vacated a rule that delayed the effective date of the 2017 Risk Management Program (RMP) Rule amendments issued by the U.S....more

Williams Mullen

Strange But True: Recent EPA and State Actions Show Breadth of Environmental Enforcement

Williams Mullen on

A trilogy of recent federal and state enforcement actions show just how far agencies will go to enforce environmental regulations. Now may be a good time for a compliance audit....more

Best Best & Krieger LLP

First Amendment Rights of California Public Agencies Affirmed by Appellate Court - Anti-SLAPP Motion Successful in Dispute

Best Best & Krieger LLP on

A court of appeal dismissed a challenge to a county’s characterization of stored chemicals as hazardous waste, holding that by making that determination and forwarding it to the district attorney, the county had engaged in...more

Williams Mullen

Environmental Groups Argue Sham Recycling Rule Should Be Recycled by EPA Rather Than Partially Discarded by Court

Williams Mullen on

EPA promulgated a final rule in 2015 redefining “solid waste” under the Resource Conservation and Recovery Act (“RCRA”) to curb sham recycling (the “Rule”). In the August 2017 issue of Environmental Notes, we reported that...more

Williams Mullen

RCRA Corrective Action Liability: Can it be Imposed on a Company that Never Owned or Operated the Facility?

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The North Carolina Court of Appeals recently issued a ruling that will have a significant impact on business transactions involving property subject to a permit or corrective action obligations under the Resource Conservation...more

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