Representative Work

Among his notable matters, Steve:

  • Assisted a client in the design and implementation of a rolling corrective action audit that identified and resolved hundreds of chemical release issues within a tight time frame at nearly thirty facilities across the county to meet a U.S. Environmental Protection Agency (EPA) compliance order deadline.
  • Led numerous teams on transactional projects to identify and address permit transfer obligations for large asset sales, reorganizations, and rebranding efforts.
  • Designed and redesigned several corporate EHS audit programs to achieve company compliance objectives and streamline assessment functions.
  • Negotiated a 93% reduction in a multi-million dollar penalty demand by U.S. Department of Justice and EPA on a multi-site, multi-state risk management plan enforcement matter by systematically disassembling the government’s conclusions about program deficiencies.

Other successful projects include counseling on numerous major and minor source air permits to support facility sitings and expansions; defending several companies and a major municipality against allegations of Clean Water Act violations brought by citizens groups and EPA; counseling a spent carbon recycling company through a hazardous waste treatment permitting process with EPA, including a pending appeal of permit provisions; and obtaining siting approvals and permits 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 1,500 ton per day construction and demolition debris recycling facility.