News & Analysis as of

Hazardous Waste Permits

Latham & Watkins LLP

EPA Proposes Granting Texas Primacy for Class VI Wells

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The proposal could accelerate the permitting process for carbon capture and storage projects in the state. On June 9, 2025, the US Environmental Protection Agency (EPA) signed a proposed rule that, if approved, would...more

Latham & Watkins LLP

EPA Proposes Granting Arizona Primacy for All Classes of Injection Wells

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The proposal could accelerate the permitting process for projects in the state, including carbon capture and storage (CCS) projects....more

Troutman Pepper Locke

New Texas Railroad Commission Rules: Challenges and Permitting for the E&P Industry

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On December 17, 2024, the Railroad Commission of Texas (RRC) adopted new comprehensive regulations governing the handling, storage, treatment, and disposal of oil and gas waste. The rules were published January 3, 2025, in...more

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Hazardous Waste Enforcement: Alabama Department of Environmental Management and Pell City Electrical Equipment Recycling Facility...

The Alabama Department of Environmental Management (“ADEM”) and TCI of Alabama, LLC (“TCI”) entered into a Consent Order (“CO”) to address 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 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

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Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Columbus, Ohio Paint Corporation Enter Into Expedited...

The United States Environmental Protection Agency (“EPA”) and Yenkin-Majestic Paint Corporation (“YMPC”) entered into a February 19th Expedited Settlement Agreement (“ESA”) addressing alleged Resource Conservation Recovery...more

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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

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Hazardous Waste Enforcement: Louisiana Department of Environmental Quality and Hammond Hazardous Waste Storage Facility Enter into...

The Louisiana Department of Environmental Quality (“LDEQ”) and LEI, Inc. (“LEI”) entered into a Settlement Agreement (“SA”) addressed alleged violations of certain hazardous waste regulations. See SA-HE-23-0086....more

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Implementing Climate Resilience/Hazardous Waste Permitting: ASTSWMO Addresses Question to U.S. Environmental Protection Agency...

The Association of State and Territorial Solid Waste Management Officials (“ASTSWMO”) addressed in a January 26th letter to the United States Environmental Protection Agency (“EPA”) a question regarding a draft memorandum the...more

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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

Holland & Knight LLP

New York Drafts Policy for Evaluating Permitting Impacts on Disadvantaged Communities

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New York's groundbreaking Climate Leadership and Community Protection Act (the Climate Act) is known for being the country's most aggressive climate and clean energy statewide agenda. It calls for a mandated goal of a...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

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,...

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

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

Hazardous Waste Enforcement: Alabama Department of Environmental Management and Dothan Aircraft Repair/Refurbishment Facility...

The Alabama Department of Environmental Management (“ADEM”) and Commercial Jet Services LLC (“CJS”) entered into an April 21st Consent Order (“CO”) addressing alleged violations of the Alabama hazardous waste regulations. See...more

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

Medical Waste Enforcement: Alabama Department of Environmental Management and Panama City Medical Waste Transporter Enter into...

The Alabama Department of Environmental Management (“ADEM”) and Trilogy MedWaste Southeast, LLC (“Trilogy”) entered into an August 13th proposed Consent Order (“CO”). See Consent Order No. 21-XXX-CMW. The CO addresses an...more

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

Hazardous Waste Enforcement: Alabama Department of Environmental Management and Sumter County Hazardous Waste TSD Enter into...

The Alabama Department of Environmental Management (“ADEM”) and Chemical Waste Management, Inc., (“CWMI”) entered into a July 12th Consent Order addressing alleged violations of the Alabama hazardous waste regulations. See...more

K&L Gates LLP

Building Relationships with Tribes and Operating on Reservation Lands: Lessons From FMC v. Shoshone

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Building Relationships with Tribes and Operating on Reservation Lands: Lessons From FMC v. Shoshone - On 11 January 2021, the United States Supreme Court declined a petition to review the Ninth Circuit’s decision in FMC...more

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

Hazardous Waste Enforcement: Alabama Department of Environmental Management and Limestone County Automotive Gasket Manufacturing...

The Alabama Department of Environmental Management (“ADEM”) and American Leakless Company LLC (“ALC”) entered into a November 9th Consent Order (“CO”) addressing alleged violations of Alabama hazardous waste regulations. See...more

Holland & Hart LLP

Wyoming Industrial Siting: Navigating the Path for Industrial Growth

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To balance the needs of both industry and communities, Wyoming has developed a uniform, state-wide permitting system for all large-scale industrial facilities. Wyoming's Industrial Development Information and Siting Act sets...more

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

Resource Conservation and Recovery Act/Hazardous Waste Disposal: Federal District Court Addresses United States Challenge to Scope...

The United States District Court for the District of New Mexico (“Court”) in a March 31st Order addressed a dispute regarding a state-issued hazardous waste disposal permit. See United States v. N.M. Env’t Dep’t, No. CV 19-46...more

Vedder Price

Manufacturer Alert - The Environmental Impact of a Suspension or Shut Down in Operations

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If you are operating in a state where your governor has issued a stay at home order (NY, NJ, CT, CA, PA, IL, OH, MI, LA, DE, KY, WI) and you have been forced to suspend or shutdown some or all of your operations, it is...more

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

Post-Closure/Landfill: North Carolina Appellate Court Addresses RCRA Compliance Issue

The Court of Appeals of North Carolina (“Court”) addressed in a January 7th opinion a Resource Conservation and Recovery Act (“RCRA”) closure issue. See State ex. rel. Regan v. Wasco, LLC, No. COA19-355, 2020 WL 63913 (N.C....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

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