Babst Calland Shareholder, Jean Mosites will be presenting at the Air & Waste Management Association, Allegheny Mountain Section Luncheon on November 10, 2016. In 1978, EPA’s first proposed hazardous waste regulations under RCRA contained a carve-out for “oil and gas drilling muds” and “production brines” exempting them from storage, treatment and disposal standards to which hazardous wastes were subject.  EPA justified the classification because such wastes were high in volume...