Stephen M. Richmond

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

 Air Matters

• Discovery of 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.  

• Discovery of air permitting issues at a natural gas fractionation facility in Texas, the voluntary shutdown of the facility, and the negotiation of a no-penalty resolution and startup of the facility.

• Counseling on the drafting, negotiation and implementation of Clean Air Act Title V operating permits at industrial facilities throughout the country.

Solid Waste Matters

• Obtained site assignment for a 950 ton per day solid waste landfill and recycling facility.

• Obtained site assignment and seven special permits for a 600 ton per day materials resource recovery facility. Filed judicial appeals challenging conditions placed on both approvals and successfully negotiated resolutions.

• Obtained site assignment for 1500 ton per day construction and demolition debris recycling facility. 

• Represented several coalitions of municipal and solid waste industry trade associations in challenges before the federal Surface Transportation Board of attempts by private companies to build and operate solid waste facilities in New Jersey and Massachusetts under claims of preemption from state and local law.

Hazardous Waste Matters

• 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.

• Represented hazardous waste recycling facility located in the Southwest in RCRA Part B permitting. 

Acquisition and Disposition Matters

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

• 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. 

• 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

• Have advised many companies on the conduct of environmental and health and safety self assessments at facilities throughout the country and on the submittal of written disclosures to US EPA and state regulators to obtain penalty protection and mitigation.

• 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 service 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.