Transportation/Hazardous Materials: U.S. Pipeline and Hazardous Materials Safety Administration Interpretive Letter Addressing Battery Energy Storage System
The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) clarified in a July 29th Interpretive Letter the federal Hazardous Materials Regulations (“HMR”) applicable to hazmat registration for lithium batteries that comprise a battery energy storage system (“BESS”). See…
Wastewater Enforcement: Arkansas Department of Energy and Environment - Division of Environmental Quality and City of Stuttgart Enter Into Consent Administrative Order
The Arkansas Department of Energy and Environment - Division of Environmental Quality (“ADEQ”) and the City of Stuttgart, Arkansas entered into a May 22nd Consent Administrative Order (“CAO”) addressing an alleged violation of a Clean Water Act National Pollutant Discharge Elimination System…
Application of the RCRA to Telecommunications Cables: U.S. Environmental Protection Agency Interpretive Letter
The United States Environmental Protection Agency (“EPA”) Office of Resource Conservation and Recovery addressed in a July 23rd interpretive letter: … the application of the Resource Conservation and Recovery Act (RCRA) to telecommunications cables that "remain[] in their original place of…
Arkansas Advisory Committee on Petroleum Storage Tanks: August 28th Meeting
As noted in a previous blog post, Arkansas operates a petroleum storage tank trust fund that provides reimbursement for eligible storage tanks that suffer corrective action requirements and third-party damage claims due to a release of petroleum. The Advisory Committee on Petroleum Storage Tanks…
Indirect Discharge/Wastewater Enforcement: Alabama Department of Environmental Management and Jasper Chicken Processing Facility Enter into Consent Order
The Alabama Department of Environmental Management (“ADEM”) and Mar-Jac Poultry AL, LLC (“MJ”) entered into a Consent Order (“CO”) addressing alleged violations of a State Indirect Discharge (“SID”) Permit. The CO provides that MJ operates a chicken processing facility in Jasper, Alabama. ADEM is…