Frost Brown Todd LLC
Steve practices in all areas of environmental law with a particular focus on counseling and litigation representation on air emission issues. He routinely counsels clients on air permitting issues, including state installation and operation permits, New Source Review, Title V, New Source Performance Standards, and hazardous pollutant MACT standards. In addition, he counsels clients on solid and hazardous waste management, and RCRA corrective action.
Successful defense of a glass manufacturing plant in a U.S. EPA New Source Review enforcement action based on BACT determinations and interpretation of condensible particulate matter requirements.
Successful defense of a paper mill in a U.S. EPA New Source Review enforcement action based on technical and engineering analyses that demonstrated increased emissions were not associated with any physical changes.
Successful defense of an integrated steel mill in a U.S. EPA New Source Review enforcement action, based on a detailed netting analysis and a determination of the applicability of NSR exemptions.
Obtained the reversal, through a seven day hearing before the Environmental Review Appeals Commission, of a board of health's multiple denials of operating licenses for a solid waste facility, which was affirmed on appeal.
Conducted environmental audits of numerous facilities, including a food processing facility, an aluminum foundry, a glass finishing facility, and a nine-day comprehensive audit of a major manufacturing facility.
Conducted a compliance audit requiring evaluation of state air permitting requirements for 39 states.
Convinced U.S. EPA to forgo RCRA corrective action at steel finishing facility due to lack of statutory authority.
Counseled companies on compliance with cap-and-trade program requirements, including program applicability determinations, initial allocation of emission allowances and credits, quality assurance/quality control monitoring obligations, and sufficiency of data reporting.
Assisted clients in remediation obligations pursuant to purchase agreements, closure plans, and consent orders.
Defense of numerous private and governmental CERCLA cost recovery actions regarding landfills, foundries, mining sites and waste disposal sites.