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Waste Management


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 Resource Conservation and Recovery Act (RCRA) and Michigan’s Act 641/Natural Resources and Environmental Protection Act (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 treatment, storage, and disposal facility (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 Government Performance and Results Act (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in state administrative civil penalty action for generator waste management violations; T/S/DF violations and penalties withdrawn based on wastewater treatment system exemption.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 RCRA Facility Investigation (RFI)/Corrective Measures Study (CMS), closure under New Mexico law and corrective action, and pursued Engineers India Limited (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.

For more information, please contact your Varnum attorney, or Matt Eugster at 616/336-6821 or

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