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Waste Management

Industrial & Hazardous Waste - the firm is prepared to assist in all areas of waste management, including
developing waste management strategies, securing permit authorizations, and determining compliance at
facilities that generate, transport, store, dispose and otherwise manage waste.

Municipal Solid Waste - assistance is provided in permitting and compliance issues concerning waste
disposal, transport, transfer, incineration and other municipal waste management activities.

Superfund - representation and counsel provided to Potentially Responsible Parties (PRPs) and others
involved in Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) actions.

Waste Classification - assistance in evaluation and regulatory interpretation of Class 1, Class 2, Class 3 or
Hazardous waste identifications.

Voluntary Cleanup Program (VCP) and Innocent Owner Program (IOP) - assistance to owners of
contaminated property interested in preserving or restoring property value.
Remediation - counsel and representation concerning the Texas Risk Reduction Program (TRRP) rules
and response actions to historical and accidental releases of regulated substances.

Compliance - assistance and counsel to entities seeking to determine compliance through self-evaluative
audits, or as necessary to respond to agency enforcement actions. Prior experience has included work
with property owners, Superfund PRPs, municipal solid waste operators, hazardous waste treatment
facilities, electric utilities, cities and commercial entities.

Water Quality

Permits - wastewater and stormwater discharge permit application counsel and assistance during the
preparation of applications and negotiations with regulatory agencies.

Compliance - assistance and counsel to entities seeking to determine compliance through self-evaluative
audits, or as necessary to respond to agency enforcement actions. Prior experience has included work
with utilities, cities and commercial entities.

Petroleum Storage Tanks

Regulation - assistance provided to owners and operators concerning registration, regulatory
interpretation, and other issues involving underground and aboveground storage tanks.

Remediation - counsel and representation concerning responses to historical and accidental releases of
regulated substances, including responses conducted under the Texas Risk Reduction Program (TRRP).

Compliance - assistance and counsel to entities seeking to determine compliance through self-evaluative
audits, or as necessary to respond to agency enforcement actions. Prior experience has included work
with land owners and PST facility operators.

Environmental Audits

Audits - assistance is offered in conducting due diligence transactional audits, compliance audits, and
self-evaluation audits. Audits are conducted under the attorney client and attorney work product
privileges, and based on the client needs, under the state environmental audit act and the EPA audit policy.
When in the best interest of the client the firm works with engineering consultants to provide technical
review and support while also providing compliance counsel under available privileges. Prior experience
has included work with property owners, utilities and cities.

Rule Adoption and Policy Issues
Proposed Rules - the firm assists clients by evaluating the potential impact of proposed regulations. When
appropriate, the firm will prepare comments and participate as appropriate to influence the rule adoption
process.

General Policy Issues - assist in efforts to impact procedures and policies of regulatory agencies that affect
client operations. Prior experience has included work with utilities, federal military facilities and cities.

Special Assistance

The firm looks forward to working with clients who require innovative or creative solutions to
unanticipated environmental situations. For example, unique technology projects, e.g., experimental
weather modification devices or waste-to-energy projects, may demand extraordinary handling if existing
regulations do not accommodate or appreciate the special needs and benefits of such operations.

The firm works with clients on a wide range of air quality permitting issues including the following:

Permitting - facilities require regulatory authorization for air emissions, and firm helps clients through the
sometimes complicated permitting process. The firm has assisted with all types of New Source Review
and other regulatory permitting actions, including Permit Exemptions, Permits by Rule, Standard Permits,
Title V, Prevention of Significant Deterioration (PSD), and related authorizations.

Nonattainment and State Implementation Plan (SIP) issues - assistance is provided to municipalities,
counties, industry and other parties interested in proposed plans to reestablish compliance with federal
ambient air quality standards, or seeking to participate by pursuing alternatives to proposed plans.

Compliance - assistance and counsel to entities seeking to determine compliance through self-evaluative
audits, or as necessary to respond to agency enforcement actions. Prior experience has included work
with gas and coal-fired electric utilities, bulk storage and loading operations, rock & concrete crushers,
solid waste landfills, paint facilities, incinerators, cement plants, cities, counties, industry groups, coalitions
of parties, etc.