Waste Management
Contact: Matthew B. Eugster
Many clients have turned to Varnum's environmental attorneys for assistance in waste management legal issues, including:
- Acquisition of state and local solid waste disposal construction and operation permits.
- Counsel concerning landfill siting, licensing, license renewal, and closure, under both RCRA and Michigan’s Act 641/NREPA Part 115.
- Preparation of hazardous waste permit applications, closure plans, post-closure plans, financial assurance materials, and other regulatory compliance steps, under both RCRA and state laws.
- Counsel on waste-to-energy, recycling, and reuse options.
- Defended U.S. EPA civil penalty litigation for T/S/DF permitting and financial responsibility violations; accomplished “clean” closure of surface impoundments.
- Represented manufacturers in RCRA proceedings with Illinois, Iowa, Kentucky, Michigan, and Ohio, corrective action strategies (including GPRA Baseline), and response to visual site inspection/preliminary assessment.
- Defended Michigan automotive parts manufacturer in state administrative civil penalty action for generator waste management violations; T/S/DF violations and penalties withdrawn based on wastewater treatment system exemption.
- Defended U.S. EPA Region 6 enforcement proceedings; coordinated RFI/CMS, closure under New Mexico law, and corrective action; and pursued EIL insurance coverage.
- Represented various foundries regarding closure of surface impoundments and waste pile units, corrective action, and inspection assessments response strategies.
- Defended State DEQ litigation claim of penalties for waste manifesting system violations, inadequate closure, and spill reporting, as well as corrective action.
- Challenged listed hazardous waste exclusion denial in District of Columbia Circuit Court of Appeals.