Stephen M. Richmond

Mr. Richmond's counseling experience includes the following representative cases: 

 Air Matters

• Provide advice and conduct training on the requirements of the Mandatory Greenhouse Gas Reporting Rule to industrial facility owners and operators throughout the country.

• Led teams responsible for responding to many Clean Air Act Section 114 document production orders from US EPA.

• Coordinated defense and negotiated multiple consent orders between metals foundry and state enforcement agency to resolve allegations of air compliance issues at a metals foundry in New England.

• Discovered new source review and new source performance standard issues at a Midwestern mineral services company, advised client on the filing of governmental disclosures, and successfully resolved enforcement negotiations.

• Discovered new source review and new source performance standard issues at a Midwestern mineral services company, the filing of governmental disclosures, and the successful resolution of enforcement negotiations.

• Advised Gulf Coast chemical company on air evaluation resulting in discovery of new source review issue, disclosure to US EPA and state, and negotiation of a low-penalty resolution, including submittal of after-the-fact PSD permit application.

• Advised industrial company on the discovery of complex benzene NESHAP compliance issues, coordinated audit disclosures, provided advice and support on issue resolutions. 

• Counseling on the drafting, negotiation and implementation of Clean Air Act Title V operating permits at industrial facilities throughout the country, on the establishment of reasonable inquiry processes for ongoing compliance, and on continuing semi-annual deviation reporting and annual compliance certifications.

Waste and Recycling Matters

• Have obtained site assignments in Massachusetts for many solid waste and recycling facilities, including a 950 ton per day solid waste landfill and recycling facility, a 600 ton per day materials resource recovery facility, and a 1500 ton per day construction and demolition debris recycling facility.

• Have negotiated multiple long term landfill development contracts. Experience includes representing both private developers and municipal facility owners.  

• Represented several coalitions comprised of solid waste industry trade associations, private companies and government partners in proceedings before the federal Surface Transportation Board and federal courts to force all transfer station developments to adhere to same rules.  Proceedings have involved facilities proposed in New Jersey, Massachusetts and Pennsylvania.

• Represented coalition of construction and demolition debris processors and recyclers in negotiations with state agency on proposed enforcement initiatives.

• Counseled a chemical manufacturing facility in Kansas on closure and corrective action permit negotiations and permit implementation. Settled simultaneous federal and state RCRA permit appeals.

• Ongoing representation of hazardous waste recycling facility located in the Southwest in RCRA Part B permitting. Negotiated successful dispositions of several enforcement initiatives brought by US EPA.

Acquisition and Disposition Matters

• Performed environmental due diligence reviews on the assets of an independent energy producer with fifteen facilities throughout the country.

• Led teams responsible for identifying permit transfer requirements for several large corporate reorganizations involving hundreds of facilities across the United States. 

• Conducted permit transfer evaluation for acquisition of manufacturing company with multiple facilities.

• Negotiated environmental liability transfer provisions for sale of chemical company with multiple facilities.

• Negotiated environmental liability transfer provisions for acquisition of a power plant in the Mid Atlantic region. 

• Represented biosolids management company in the public bidding of biosolids recycling facility projects, and in the negotiation of teaming agreements and design/build/operate contracts.

Environmental Health and Safety Audits

• Counseled large national industrial company on the implementation of its environmental audit program, and assisted with the preparation of audit reports and the conduct of post-audit notifications and corrective actions.

• Served as Director of EHS Audit for independent power producer and environmental infrastructure company. Responsible for planning, staffing and implementing domestic and international environmental, health and safety audits at solid waste, hazardous waste, water treatment, and manufacturing facilities, and for reporting and tracking results