Varnum has represented a variety of clients before the U.S. EPA for violations of the Toxic Substance Control Act (TSCA):

A client's self-reported transportation and storage of waste oil allegedly contaminated with PCBs resulted in a U.S. EPA Administrative Complaint seeking a $110,000 civil penalty. Varnum's aggressive Accelerated Decision approach resulted in dismissal of 3 out of 5 Counts. The dispute was ultimately settled for a civil penalty reduced by over 85%, with no admission of any wrongdoing and the Consent Order automatically terminated upon payment.

Varnum represented a transporter who was alleged by U.S. EPA to have illegally transported PCB wastes for disposal. U.S. EPA had filed an Administrative Complaint seeking approximately $60\,000 in civil penalties. Varnum was able to convince U.S. EPA to voluntarily dismiss the Complaint with prejudice based on an intensive review of the facts and recharacterization of the events involved, and no penalty was paid.

Varnum has defended several manufacturers in cases where U.S. EPA has filed notices of violations or administrative complaints with respect to PCB spills or leaks from electrical transformers and capacitors\, as well as required record-keeping under TSCA. Varnum has successfully negotiated favorable results for the clients in these cases, including the use of "Supplemental Environmental Projects" or environmentally-beneficial projects in lieu of cash penalty payments.