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 Hazardous and Medical Waste
Generation, Transportation and Disposal – RCRA
The Resource Conservation and Recovery
Act (RCRA) requires EPA and the states to regulate all aspects of the
generation, transportation, treatment, storage and disposal of solid and
hazardous wastes. The firm regularly provides counseling and
representation concerning all aspects of the federal RCRA program, New
York State hazardous waste laws and regulations and other state
regulatory programs. We continually monitor and analyze new regulatory
developments and provide advice on the scope and requirements of state
and federal programs. The firm also represents its clients during their
interaction with state and federal regulatory authorities on matters
such as permits, inspections, remedial action, closure/post closure,
corrective action, and civil and criminal enforcement. We also have
represented clients regarding underground storage tank regulation,
removal and remediation. Attorneys at the firm also have been called
upon to counsel clients on the proper handling and disposal of medical
and infectious wastes, including the permitting of infectious waste
incinerators.
Specific examples of the firm’s experience include the following:
- Defending the issuer of a closure bond in litigation brought by
the government against the bond issuer relating to the clean-up of a
hazardous waste treatment facility.
- Advising an industrial generator of hazardous wastes on compliance
with RCRA’s recordkeeping, reporting, and permitting requirements in
connection with an audit of the client’s environmental programs.
- Defending an industrial client in administrative enforcement
action by EPA for penalties pursuant to RCRA’s UST regulation program.
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