News & Analysis as of

RCRA Oil & Gas

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

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

Citizen Suit Action/RCRA: Conservation Law Foundation Alleges Violations by Natural Gas Pipeline System

The Conservation Law Foundation, Inc. filed a citizen suit Complaint in the United States District Court of Massachusetts on November 12th alleging violations by the following: Besides the Conservation Law Foundation, the...more

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Golden Meadow, Louisiana Port Services Facility Enter into...

The United States Environmental Protection Agency (“EPA”) and HOS Port, LLC (“HOS”) entered into an October 9th Consent Agreement and Final Order (“CAFO”) addressing alleged violations of the Resource Conservation and...more

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

Storage Tank Enforcement: U.S. Environmental Protection Agency and Owner of Pennsylvania Retail Motor Fuel Facilities Enter into...

The United States Environmental Protection Agency (“EPA”) and National Retail Properties Trust (“NRPT”) entered into a January 29th Consent Agreement (“CA”) addressing alleged violations of certain Resource Conservation and...more

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

UO19 (Benzene) U22 (Toluene)/Delisting Petition for One-Time Amount: November 12th U.S. Environmental Protection Agency Federal...

The United States Environmental Protection Agency (“EPA”) published a November 12th Federal Register Notice proposing to grant three petitions to delist a one-time amount up to 20,100 cubic yards of Resource Conservation and...more

Bergeson & Campbell, P.C.

Wrap-Up of Federal and State Chemical Regulatory Developments, October 2019

TSCA/FIFRA/TRI - EDF Reports That EPA Has “Muzzled” SACC: The Environmental Defense Fund (EDF) published a September 16, 2019, blog item entitled “EPA’s latest move to deflect criticism of its TSCA risk evaluations: Muzzle...more

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

Arkansas Oil Marketers Association Environmental Workshop: Arkansas Department of Environmental Quality Storage Tank Trust...

The Arkansas Oil Marketers Association held their annual environmental workshop on August 29th in Little Rock, Arkansas. The workshop addressed and variety of environmental issues associated with the utilization, storage,...more

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

State Storage Tank Funds: 2018 ASTSWMO 2018 Survey Results

The Association of State and Territorial Solid Waste Management Officials (“ASTSWMO”) issued a document titled: State Funds Survey Results 2018 (“Survey”) ...more

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

RCRA/Citizen Suit Enforcement: Environmental Integrity Project Notice of Intent to Sue Phillips 66 Company/Los Angeles County,...

The Environmental Integrity Project and Environmental Advocates sent an August 7th Notice of Intent to Sue (“Notice”) to Phillips 66 Company (“Phillips”) alleging violations of the Resource Conservation and Recovery Act...more

Pillsbury - Gravel2Gavel Construction & Real...

EPA Announces Decision to Retain Current Position on RCRA Regulation of Oil and Gas Production Wastes

After much study, EPA has decided against changing its current RCRA Subtitle D rules affecting the state regulation of oil and gas exploration & production waste. ...more

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

Solid and Hazardous Waste Judicial/Regulatory Developments (2018-2019): Arkansas Environmental Federation Presentation...

I undertook a presentation on April 17th at the Arkansas Environmental Federation Regulated Waste Seminar titled: Solid and Hazardous Waste Judicial/Regulatory Developments: 2018 – 2019 - The discussion addressed...more

WilmerHale

Environmental Litigation Alert: Citizen Suits Challenge Rollbacks, Replacements and Project Approvals

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This is the eighth issue of WilmerHale’s 10-in-10 Hot Topics in Energy Series. Over the course of 10 weeks, our attorneys will share insights on current and emerging issues affecting the US energy sector. Attorneys from...more

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

RCRA Listed Hazardous Waste/F037: U.S. Environmental Protection Agency Grants Delisting Petition

The United States Environmental Protection Agency (“EPA”) published an August 22nd Federal Register Act notice granting a petition to exclude (“delist”) hazardous waste generated by a particular facility from the Resource...more

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

Used Oil/Hazardous Waste Enforcement: U.S. Environmental Protection Agency and South Lyon, Michigan Metal Heat Treating Facility...

The United States Environmental Protection Agency (“EPA”) and Sun Steel Treating (“Sun”) entered into a June 21st Consent Agreement and Final Order (“CAFO”) addressing alleged violations of Resource Conservation and Recovery...more

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

Storage Tank Enforcement: U.S. Environmental Protection Agency and Owner/Operator of New York Facilities Enter into Expedited...

The United States Environmental Protection Agency and Blueox Corporation (“BC”) entered into an April 4th Expedited Settlement Agreement (“ESA”) addressing alleged violations of Subtitle I of the Resource Conservation and...more

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

Storage Tank Enforcement: U.S. Environmental Protection Agency and Elmira, New York/Newton, New Jersey Underground Storage Tank...

The United States Environmental Protection Agency (“EPA”) entered into an Expedited Settlement Agreement (“ESA”) with First Group America, Inc., d/b/a First Student, Inc. and First Transit, Inc. See Docket No....more

Katten Muchin Rosenman LLP

D.C. Circuit Vacates Portions of EPA's Definition of Solid Waste Rule

On July 7, 2017, the United States Court of Appeals for the District of Columbia Circuit (the D.C. Circuit) vacated portions of the U.S. Environmental Protection Agency's (EPA) 2015 rule on the Definition of Solid Waste (the...more

Gray Reed

A Development in Earthquakes and Fracking

Gray Reed on

Sierra Club v. Chesapeake Operating LLC et al is news more shocking than “Man Bites Dog”! A federal court has acknowledged that others are better equipped to address certain issues than the judiciary!...more

Pillsbury - Gravel2Gavel Construction & Real...

District Court Invokes Burford Abstention and Primary Jurisdiction Doctrines to Dismiss RCRA Citizen Suit

The U.S. District Court for the Western District of Oklahoma has dismissed the Sierra Club’s Resource Conservation and Recovery Act (RCRA) citizen suit, filed against several oil and gas producers seeking declaratory and...more

Stoel Rives LLP

Industry Groups Push Back Against Environmental Activists in Suit Over Oil & Gas Waste Disposal Regs.

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As we discussed earlier, environmental activists have asked the Environmental Protection Agency (“EPA”) to update its oil and gas drilling waste disposal rules under the Resource Conservation and Recovery Act (“RCRA”). The...more

Burr & Forman

Air Emissions Regulated Under RCRA?

Burr & Forman on

Certain regulated entities that operate under Clean Air Act permits are being reminded that those permits do not necessarily cover air emissions associated with the management of hazardous wastes regulated by the federal...more

Jackson Walker

Environmental Groups File Suit Seeking Revision of E&P Waste Regulations

Jackson Walker on

On May 4, 2016, the Environmental Integrity Project (EIP), National Resources Defense Council (NRDC); Earthworks; Center for Health, Environment and Justice; and three other environmental groups (hereinafter collectively...more

Stoel Rives LLP

Environmentalists Sue EPA to Force Update of Drilling Waste Regulations

Stoel Rives LLP on

On May 4, 2016, a coalition of environmental organizations (“Plaintiffs”) filed suit against the U.S. Environmental Protection (“EPA”) in U.S. District Court for the District of Columbia to compel the EPA to promulgate...more

Kelley Drye & Warren LLP

Sierra Club Sues Over Oklahoma Earthquakes

The Sierra Club has filed suit against three oil and gas companies operating in Oklahoma, alleging that the companies’ wastewater injection practices were behind the recent uptick in earthquake activity in the state. The...more

Bergeson & Campbell, P.C.

Wrap-Up of Federal and State Chemical Regulatory Developments, September 2015

EPA Releases TSCA Assessment Documents For Flame Retardant Chemicals: On August 18, 2014, the U.S. Environmental Protection Agency (EPA) released for public comment three Problem Formulation and Initial Assessment documents...more

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