Hazardous Waste
Hazardous Waste practice requires that we address issues on behalf of our clients that include:
- Providing advice to client regarding what is and is not a regulated as a hazardous waste
- Hazardous waste compliance activities and documents required by state and federal administrative laws and regulations
- Notifications and permitting related to hazardous waste
- Unauthorized releases or discharges of hazardous waste
- Defense of administrative or civil enforcement actions related to hazardous waste issued or instituted by state or federal administrative agencies
- Defense of civil actions by state and US departments of justice related to hazardous waste after referral of administrative enforcement actions by state or federal environmental agencies
Hazardous Waste matters in which the firm has or attorneys with the firm have been involved include the following:
- Prepared RCRA Training Plan, RCRA Inspection Plan, RCRA Contingency Plan, chemical product pre-acceptance and receiving procedures and hazardous waste analysis and determination procedures for a chemical blending company actions
- Defended an enforcement action by the State of Kentucky on behalf of a chemical manufacturer regarding to RCRA jurisdictional issues related to certain manufacturing equipment. Investigated alleged regulatory violations, located and coordinated experts and developed defense strategies.
- Prepared opinion for a chemical blending company detailing upgrades needed to satisfy SPCC and RCRA tank and container storage standards and NEPA/ OSHA flammable liquid tank storage standards
- Prepared comments on proposed state hazardous waste regulations on behalf of an transportation company
- Prepared opinion detailing upgrades needed to satisfy RCRA and SPCC tank storage and addressing container storage standards, requirements for less-than-90-day storage for tanks and containers and requirements for hazardous waste tank storage for a barge maintenance and cleaning facility
- Prepared hazardous waste determination procedures, RCRA Training Plan, RCRA Inspection Plan, RCRA Contingency Plan, RCRA Inspection Program, waste pile sampling program for a barge cleaning and maintenance facility
- Prepared opinions regarding options pursuant to then-current land ban regulations for the excavation and relocation of contaminated soil from a landfarm operation that received wastes otherwise regulated as a hazardous waste prior to RCRA regulation on behalf of a commercial TSD facility
- Responsible for day to day activities of ensuring RCRA compliance at a large organic and inorganic chemical manufacturing facility, a large chemical manufacturing facility and a commercial hazardous waste TSDF
- Developed and maintained the following regulatory documents for a large commercial hazardous waste TSDF: RCRA Waste Analysis Plan, Closure/Post Closure Plan & Cost Estimates, RCRA Contingency Plan, RCRA Inspection Plan, RCRA Training Plan, RCRA Security Procedures, Generated Waste Management Program, Waste Reduction Plan
- Developed and maintained the following regulatory documents for a large chemical manufacturing facility: RCRA Contingency Plan, RCRA Inspection Plan, RCRA Training Plan, Generated Waste Management Program, Waste Reduction Plan