Coal Ash, Oil Field and Other Solid Wastes

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Companies are facing an onslaught of rapidly changing requirements across federal/state waste programs. Baker Botts provides clients with effective tools in advocacy efforts, as well as avenues to track new legislation, regulatory initiatives and litigation trends, including issues related to Coal Combustion Residuals Rule and Potential Legislation.

Baker Botts lawyers provide counseling on the regulation of coal combustion residuals (CCR) as a solid waste under Subtitle D of RCRA. Specifically, our team provides guidance on how to comply with the management requirements for existing and new CCR landfills and surface impoundments, including:

  • Lining requirements for surface impoundments and landfills that receive coal ash
  • Restrictions on the location of new surface impoundments and landfills
  • Remediation of releases from a lined surface impoundment or landfill
  • Implementation of fugitive dust controls

Solid Waste Definition Rules:
Our lawyers have significant experience with both the 2008 and 2014 solid waste definition rule-makings and provide counseling on a range of issues such as:

  • Verified recycler exclusion
  • Remanufacturing exclusion
  • Legitimate recycling definition
  • Solid waste variances
  • Non-Waste determinations

Oil Field Wastes:
We also advise clients on the management of oil field wastes in accordance with RCRA and Bureau of Land Management rules at the federal level, as well as state-specific requirements. We consult on such oil field waste issues as:

  • Criteria for exploration and production exemption
  • Exemption for crude oil reclamation operations
  • Exemption for service companies
  • Chemical disclosure


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