News & Analysis as of

Hazardous Waste Compliance

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

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

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,...

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

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

Hazardous Waste Enforcement: Alabama Department of Environmental Management and Marshall County Specialty Tank Manufacturer Enter...

The Alabama Department of Environmental Management (“ADEM”) and Pinnacle Manufacturing, LLC (“Pinnacle”) entered into a March 5th Consent Order (“CO”) addressing alleged violations of the Alabama Hazardous Waste regulations....more

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

Transportation/Hazardous Materials; Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing...

The Pipeline and Hazardous Materials Safety Administration (“PHMSA”) issued a January 10th interpretive Letter addressing the application of the Federal Hazardous Materials Regulations (“HMR”) to the combustible liquid...more

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

Transportation/Hazardous Materials: Pipeline and Hazardous Materials Safety Administration Letter Addressing Packaging Residue

The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a January 7th Interpretive Letter a question regarding the Hazardous Materials Regulation’s (“HMR”) applicability to residue on...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

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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

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,...

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: Tennessee Department of Environment and Conservation Proposed Order and Assessment Addressing Shelby...

The Tennessee Department of Environment and Conservation (“TDEC”) issued on November 15th a Proposed Director’s Order and Assessment (“OA”) to Tradebe Treatment and Recycling of Tennessee, LLC (“TTRT”) addressing alleged...more

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

Hazardous Waste Enforcement: Tennessee Department of Environment and Conservation Proposed Order Addressing Dayton Specialty...

The Tennessee Department of Environment and Conservation (“TDEC”) issued a December 16th Proposed Order and Assessment (“Order”) to Cymer-Dayton, LLC (“CD”). See Case No. HWM 24-0022. The Order provides that CD conducts...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

Mayer Brown

BIMCO Submits Document To IMO Regarding Inconsistencies Between Hong Kong And Basel Conventions

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The Baltic and International Maritime Council ("BIMCO"), in conjunction with Bangladesh, India, Norway, Pakistan and the International Chamber of Shipping (ICS), submitted a document to the International Maritime Organization...more

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

Hazardous Waste Enforcement: Alabama Department of Environmental Management and Jefferson County Hazardous Waste Management...

The Alabama Department of Environmental Management (“ADEM”) and Safety-Kleen Systems, Inc. (“Safety-Kleen”) entered into a December 22nd Consent Order (“CO”) addressing alleged violations of the Alabama Hazardous Waste...more

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

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

The Alabama Department of Environmental Management (“ADEM”) and Safety-Kleen Systems, Inc. (“Safety-Kleen”) entered into a Consent Order (“CO”) addressing alleged violations of the Alabama Hazardous Waste Regulations. See...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,...

Used Oil/Hazardous Waste Enforcement: Louisiana Department of Environmental Quality and New Orleans Armored Combat Vehicle...

The Louisiana Department of Environmental Quality (“LDEQ”) and Textron Inc. (“TI”) entered into a Settlement Agreement (“Agreement”) addressing alleged violations of the Louisiana Hazardous Waste Regulations. See Settlement...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

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

Arkansas Department of Energy & Environment - Division of Environmental Quality Hazardous Waste Generator Reminder: U.S....

The Arkansas Department of Energy & Environment – Division of Environmental Quality (“DEQ”) is circulating a Resource Conservation and Recovery Act (“RCRA”) Hazardous Waste Generator Reminder which references a March 14th...more

ArentFox Schiff

Environmental Justice Update: New York Becomes Second State to Require EJ-Focused Cumulative Impact Analysis

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On New Year’s Eve, New York Governor Kathy Hochul signed New York’s “Cumulative Impacts” bill into law, making New York the second state in the nation to require assessment of “cumulative impacts” affecting certain...more

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

Hazardous Waste Enforcement: Alabama Department of Environmental Management and Glencoe Commercial Hazardous Waste...

The Alabama Department of Environmental Management (“ADEM”) and American Transportation Solutions, LLC (“ATS”) entered into a December 14th Consent Order (“CO”) addressing an alleged violation of the Alabama Hazardous Waste...more

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

Hazardous Waste Enforcement: Arkansas Department of Energy & Environment - Division of Environmental Quality and Pine Bluff...

The Arkansas Department of Energy & Environment - Division of Environmental Quality (“DEQ”) and AGROdeviate, LLC, (“AGROdeviate”) entered into a September 29th Consent Administrative Order (“CAO”) addressing alleged...more

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

Air Enforcement: Alabama Department of Environmental Management and Madison County Army Research and Development Facility Enter...

The Alabama Department of Environmental Management (“ADEM”) and United States Army Garrison – Redstone Arsenal (“RSA”) entered into a June 15th Consent Order (“CO”) addressing alleged violations of the Alabama Hazardous Waste...more

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