News & Analysis as of

Solid Waste Environmental Protection Agency (EPA) RCRA

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

Hazardous Waste Enforcement: U.S. Environmental Protection Agency and Camden, New Jersey Drum Reconditioner Enter into Consent...

The United States Environmental Protection Agency (“EPA”) and Patrick J. Kelly Drums, Inc. (“PJKD”) entered into a February 27th Consent Agreement and Final Order (“CAFO”) addressing alleged violations of the Resource...more

Balch & Bingham LLP

Managing Solid Waste Challenges in the Energy Transition

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The transition to sustainable energy in the United States is reshaping how we create, store, and use energy – especially electricity – and the landscape is changing rapidly. This shift introduces new waste management...more

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

Non-Hazardous Secondary Materials: U.S. Environmental Protection Agency Notes Materials Lifecycle Management Company Name Change...

The United States Environmental Protection Agency (“EPA”) published in its RCRA Online database a September 10th letter from Materials Life Cycle Management Company (“MLCM”) referencing a name change to NuCycle Energy....more

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

Universal Waste Rule/Solar Panel and Lithium Battery Universal Waste Proposed Rule: Association of State and Territorial Solid...

The Association of State and Territorial Solid Waste Management Officials (“ASTSWMO”) submitted comments to the United States Environmental Protection Agency (“EPA”) addressing a Solar Panel and Lithium Battery Universal...more

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

Data Quality Issues Within the Hazardous Waste e-Manifest System: Association for State & Territorial Solid Waste Management...

The Association for State and Territorial Solid Waste Management Officials (“ASTSWMO”) published a position paper titled: DATA QUALITY ISSUES WITHIN THE HAZARDOUS WASTE e-MANIFEST SYSTEM (“Position Paper”)....more

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

Data Quality Issues Within the Hazardous Waste e-MANIFEST System: Association for State and Territorial Solid Waste Management...

The Association for State and Territorial Management Officials (“ASTSWMO”) published a position paper titled: DATA QUALITY ISSUES WITHIN THE HAZARDOUS WASTE e-MANIFEST SYSTEM (“Position Paper). The Position Paper...more

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

Solid Waste Management Unites/Corrective Action: ASTSWMO Comments Addressing U.S. Environmental Protection Agency Proposed Rule...

The Association of State and Territorial Solid Waste Management Officials (“ASTSWMO”) submitted March 26th comments to the United States Environmental Protection Agency (“EPA”) addressing a proposed rule which would amend the...more

Morgan Lewis

EPA Releases Proposed Resource Conservation and Recovery Act PFAS Rules

Morgan Lewis on

The US Environmental Protection Agency (EPA) published on February 8, 2024 two proposed rules addressing per- and polyfluoroalkyl substances (PFAS) under the Resource Conservation and Recovery Act (RCRA). The rules, if...more

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

Reconditioning/Used Drum Management: Utility Solid Waste Activities Groups Comments Addressing U.S. Environmental Protection...

The Utility Solid Waste Activities Group (“USWAG”) submitted November 22nd 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,...

Technical Corrections / Hazardous Waste Generator Improvements / Pharmaceuticals / Definition of Solid Waste: U.S. Environmental...

The United States Environmental Protection Agency (“EPA”) issued a direct final rule on August 9th denominated: Hazardous Waste Generator Improvements Rule, the Hazardous Waste Pharmaceuticals Rule, and the Definition of...more

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

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

Beveridge & Diamond PC

EPA Announces Plan to Modify and Expand the RCRA Universal Waste Rule for Lithium Batteries and Solar Panels

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As part of an effort to improve the recycling and management of wastes from the generation and storage of renewable energy, the U.S. Environmental Protection Agency (EPA) recently announced that it is developing a proposed...more

Troutman Pepper Locke

U.S. EPA Issues FAQ Memo on Lithium-Ion Battery Management Under RCRA

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As lithium-based batteries become more prevalent in everything from electric vehicles (EVs) to industrial-scale batteries, as well as e-scooters and personal electronics, more questions arise regarding how to properly manage...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,...

Plastic Production: 48 Members of Congress Address Letter to U.S. Environmental Protection Agency Administrator Michael Regan

Forty-eight Democratic Congressmen sent a February 9th letter to U.S. Environmental Protection Agency (“EPA”) Administrator Michael S. Regan asking that the agency address what they argue are needed efforts regarding plastic...more

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

Building Up Environmental Justice in EPA's Land Protection/Cleanup Programs: U.S. Environmental Protection Agency Announces Action...

The United States Environmental Protection Agency (“EPA”) issued a document titled: EJ Action Plan – Building Up Environmental Justice in EPA’s Land protection and Cleanup Programs (September 22) (“Action Plan”)...more

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

Post-Closure Care Beyond 30 Years at RCRA Subtitle C Facilities: Association of State and Territorial Solid Waste Management...

The Association of State and Territorial Solid Waste Management Officials (“ASTSWMO”) issued a position paper titled: Post-Closure Care Beyond 30 Years at RCRA Subtitle C Facilities (“Position Paper”) The Position...more

Troutman Pepper Locke

Environmental Groups Voluntarily Dismiss Their Untimely Challenge to “Part B” CCR Rule Revisions

Troutman Pepper Locke on

As previously reported, a coalition of environmental groups recently filed a petition for review in the D.C. Circuit Court of Appeals (D.C. Circuit) challenging the U.S. Environmental Protection Agency’s (EPA) recent final...more

Akin Gump Strauss Hauer & Feld LLP

Closure: EPA Finalizes Long-awaited CCR Rule Revisions and Surface Impoundment Deadlines

Following years of litigation and a segmented rulemaking process, the U.S. Environmental Protection Agency (EPA) finalized revisions to portions of its coal combustion residuals (CCR) regulations governing, among other...more

Beveridge & Diamond PC

EPA Finalizes Changes to the RCRA Ignitability Characteristic, Backing Away from Proposed Substantive Modifications But Providing...

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On June 8, 2020, the Administrator of the U.S. Environmental Protection Agency (EPA) signed a final rule to “modernize” the ignitability characteristic under the Resource Conservation and Recovery Act (RCRA), which is one of...more

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

Coal Combustion Residuals/RCRA: Earthjustice Notice of Intent to Sue U.S. Environmental Protection Agency for Alleged Failure to...

Earthjustice on behalf of a number of environmental organizations sent a February 7th letter to United States Environmental Protection Agency (“EPA”) Administrator Andrew Wheeler styled...more

Seyfarth Shaw LLP

EPA Promulgates “Streamlined System” for Managing Hazardous Waste Aerosol Cans

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Seyfarth Synopsis: Last week the U.S. Environmental Protection Agency (EPA) finalized a “streamlined system” for managing hazardous waste aerosol cans as Universal Waste. The Agency believes that the new system will be...more

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

Solvent-Contaminated Wipes Exclusion/RCRA Guidance: U.S. Environmental Protection Agency Addresses Application of Recycling...

The United States Environmental Protection Agency (“EPA”) issued a June 11th interpretive letter addressing the Resource Conservation and Recovery Act (“RCRA”) solvent-contaminated wipes exclusions (“Exclusions”)found at 40...more

Pillsbury - Gravel2Gavel Construction & Real...

DC Circuit Upholds EPA’s Latest RCRA Recycling Rule

On July 2, 2019, the U.S. Court of Appeals for the District of Columbia Circuit decided the case of California Communities Against Toxics, et al. v. EPA. In this decision, the court rejected the latest petition to strike or...more

Holland & Hart LLP

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

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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

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