Ann M. Zwick

Representative Matters

• Represented the largest scrap metal recycler in the Midwest in obtaining a construction permit from the Illinois EPA.  The facility will be located in an environmental justice area and involved significant public comment.  The Illinois EPA held its first virtual public hearing on the permit application.

• Advised client in revamping its business plan and operational practices to reopen following a government-requested shutdown due to elevated air emissions.

• Represented client in obtaining an air construction permit for a lead refiner in an EJ area involving air dispersion modeling.

• Counseled clients on performing stack testing to demonstrate compliance with permit limits and National Emission Standards for Hazardous Air Pollutants (NESHAP) standards.

• Counseled clients on performing air dispersion modeling associated with permitting decisions.

• Counseled a landfill owner on revised New Source Performance Standards (NSPS) and National Emission Standards for Hazardous Air Pollutants (NESHAPs) to control landfill gas emissions.

• Counseled scrap metal recyclers and refiners as potentially responsible parties (PRPs) on useful products and Superfund Recycling Equity Act defenses to arranger liability under CERCLA.

• Represented client in obtaining a Section 404 permit from the U.S. Army Corps of Engineers.

• Represented a manufacturer in developing OSHA compliance policies with on-site contractors.

• Represented landfill owners in litigation and enforcement actions involving landfill gas emissions, odors and alleged disposal of unpermitted TENORM waste.

• Represented a landfill owner in an administrative appeal of a corrective action plan approved by the state environmental agency for the disposal of unpermitted waste.

• Represented clients in responding to U.S. Environmental Protection Agency (USEPA) Clean Air Act Section 114 information requests.

• Counseled clients on conducting environmental, health and safety (EHS) audits and self-disclosure to governmental agencies under State and Federal audit rules.

• Represented clients on negotiating and appealing state permit conditions.

• Counseled client on compliance with the Pipeline and Hazardous Materials Safety Administration (PHMSA) regulations for landfill gas pipelines.

• Counseled client on compliance with U.S. Department of Transportation (DOT) Hazardous Materials Regulations (HMR) and import/export rules.

• Counseled clients on compliance with USEPA regulations to control the release of CFCs and other refrigerants.

• Represented clients in local siting proceedings for numerous solid waste landfills and transfer stations.  Negotiated and drafted numerous host agreements with local governmental bodies.  Successfully defended appeals of a local siting decision before the Illinois Pollution Control Board and Illinois Appellate Court.

• Natural gas power plant siting project in the Chicago suburbs.

• Permitting and zoning approvals for compost facilities.

• Remediation of property under state voluntary cleanup programs.

• Regulatory compliance counseling and environmental permitting of industrial facilities.

• Represented a media company in obtaining zoning approval for a state-of-the-art Doppler weather radar tower.

• Represented an ethylene oxide manufacturer in local land use and zoning matters.

• Represented an industrial client in negotiating water rates with a municipality.

• Represented a commercial property owner in negotiating and drafting a chilled water service agreement to obtain chilled water for cooling and air conditioning purposes.