Area of focus

Waste - RCRA - Resource Conservation and Recovery Act

Our lawyers have been personally involved in virtually every major rulemaking, legislative effort, and national litigation since the 1980s regarding EPA’s regulation of waste. We have deep ...

Representative experience

Prepared the collective comments of 11 national industrial trade associations on EPA’s most important proposed changes to its hazardous waste generator rules in 35 years.

In last two years, defended clients in precedent-setting enforcement actions in Regions 3, 5 and 6 resulting in RCRA counts being dropped and 60% penalty reductions.

Represented the leading U.S. marketer of recycled coal ash in EPA rulemaking, legislation and citizen suit, resulting in favorable EPA decision to regulate ash as nonhazardous waste.

Prepared an Amicus brief for two multinational chemical manufacturers challenging EPA’s “legitimacy” criteria in its recycling rules.

Published Works

Key changes in EPAs waste generator improvements rule Law360

The new Hazardous Waste Generator Improvements Rule is the U.S. Environmental Protection Agency’s first major effort in 35 years to amend its rules that apply to generators of...

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Publications

Splitting the Difference on Coal Ash Public Utilities Fortnightly

Industry wins exemption for "beneficial use" but faces tighter rules on impoundments and landfills.

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Publications

Final EPA Hazardous Waste Rule Will Discourage Recycling Law360

"On Dec. 10, 2014, the U.S. Environmental Protection Agency placed on its website its long-awaited, 507-page final definition of solid waste (DSW) rule, which is the most recent chapter in...

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Publications

Recycling and the Definition of Solid Waste ABA Book Publishing

Kenneth Kastner is the author of a chapter that was published in the book The RCRA Practice Manual, Third Edition. The chapter addresses recycling and the definition of solid...

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