Molten Sulfur Residue/Transportation: U.S. Pipeline and Hazardous Materials Safety Administration Addresses Hazardous Materials Regulations/Transloading Issue
The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a June 24th interpretive letter the applicability to the Hazardous Materials Regulations (“HMR”) to residue of molten sulfur on tank cars during transloading. PHMSA was responding to a December 6, 2018…
Corporate Average Fuel Economy/Inflation Adjustment for Penalties: Thirteen States File Judicial Challenge to National Highway Traffic Safety Administration Rule
Thirteen states filed a Petition for Review of a Final Rule of the National Highway Traffic Safety Administration (“Petition”) challenging a rule promulgated by the National Highway Traffic Safety Administration (“NHTSA”). The Petition asks the United States Court of Appeals for the Second Circuit…
Solvent-Contaminated Wipes Exclusion/RCRA Guidance: U.S. Environmental Protection Agency Addresses Application of Recycling Provisions
The United States Environmental Protection Agency (“EPA”) issued a June 11th interpretive letter addressing the Resource Conservation and Recovery Act (“RCRA”) solvent-contaminated wipes exclusions (“Exclusions”)found at 40 C.F.R. 261.4(a)(26) and 40 C.F.R. 261.4(b)(18). EPA addressed whether the…
Lead/OSHA Enforcement: Frenchtown, New Jersey Painting/Wall Covering Contractor Proposed to be Assessed Penalty for Alleged Violations
The United States Occupational Safety and Health Administration (“OSHA”) issued a July 24th news release stating that it had cited Scots Christopher Rule, LLC (“SCR”) for alleged violations involving the renovation and remodeling of a worksite in Easton, Pennsylvania. The alleged violations are…
Wastewater Enforcement: Arkansas Department of Environmental Quality and City of Bigelow, Arkansas Enter into Consent Administrative Order
The Arkansas Department of Environmental Quality (“ADEQ”) and the City of Bigelow, Arkansas (“City”) entered into a July 1st Consent Administrative Order (“CAO”) addressing an alleged violation of a Clean Water Act National Pollution Discharge Elimination System (“NPDES”) permit. See LIS No…