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Transporting Skid Tanks: Mark Morgan (PMAA Weekly Review) Addresses Hazardous Materials Regulations Issues

Mark S. Morgan authored an article in the December 13th Petroleum Marketers Association of America (“PMAA”) publication, PMAA Weekly Review titled: U.S. DOT hazardous Material Requirements for Transporting “Empty” Skid...more

Nationwide Permits/Clean Water Act: Field Notes (Wetland Studies and Solutions, Inc.) References Potential Early Reissuance

The publication Field Notes stated in its November 21st edition that the United States Army Corps of Engineers (“Corps”) is: . . . working on modifying several Nationwide Permits (NWPs) ahead of their current expiration...more

Proposed Methanol Manufacturing/Shipping Terminal (Kalama, Washington): Sierra Club Files National Environmental Policy Act...

The Sierra Club and several other organizations (collectively “Sierra Club”) filed a Complaint for Declaratory and Injunctive Relief (“Complaint”) in the United States District Court for the Western District of Washington...more

Dyed Diesel/Kerosene Dispenser Labels: PMAA Weekly Review Notes Increased Internal Revenue Service Enforcement

The November 15th edition of the PMAA Weekly Review (“Review”) published an article titled: IRS Issues Hefty Fines for Failure to Display Dyed Fuel Dispenser Labels...more

UO19 (Benzene) U22 (Toluene)/Delisting Petition for One-Time Amount: November 12th U.S. Environmental Protection Agency Federal...

The United States Environmental Protection Agency (“EPA”) published a November 12th Federal Register Notice proposing to grant three petitions to delist a one-time amount up to 20,100 cubic yards of Resource Conservation and...more

State Clean Energy Policy Priorities: Democratic Attorney Generals' October 28th Letter to the Federal Energy Regulatory...

Ten states and the District of Columbia Democratic Attorney Generals sent an October 28th letter to the Federal Energy Regulatory Commission (“FERC”) regarding what they described as an opportunity for the offices: . . ....more

Effluent Guidelines/Clean Water Act: U.S. Environmental Protection Agency Notices Availability/Program Plan 14

The United States Environmental Protection Agency (“EPA”) published an October 24th Federal Register Notice referencing the availability of Preliminary Effluent Guidelines Program Plan 14 (“Plan 14”). See 84 Fed. Reg....more

Gasoline/Clear Diesel Taxes: Arkansas Oil Marketers Association Publication Notes Pending Increase

The Arkansas Oil Marketers Association (“AOMA”) issued a September 6th Breaking News Notice referencing an increase for state gasoline and clear diesel taxes for the period of October 1, 2019 through September 30, 2020....more

Solar Generation Construction Costs: U.S. Energy Information Administration Report Notes Decrease

The United States Energy Information Administration (“EIA”) issued a September 3rd report stating that annual capacity-weighted average construction costs for solar photovoltaic systems continue to decrease. The conclusion...more

Arkansas Oil Marketers Association Environmental Workshop: Arkansas Department of Environmental Quality Storage Tank Trust...

The Arkansas Oil Marketers Association held their annual environmental workshop on August 29th in Little Rock, Arkansas. The workshop addressed and variety of environmental issues associated with the utilization, storage,...more

Arkansas Oil Marketers Association Hazardous Materials Training Class: September 5th - Russellville, Arkansas

The Arkansas Oil Marketers Association (“AOMA”) has scheduled a Hazardous Materials Training Class for September 5th. The class will be held in Russellville, Arkansas....more

State Storage Tank Funds: 2018 ASTSWMO 2018 Survey Results

The Association of State and Territorial Solid Waste Management Officials (“ASTSWMO”) issued a document titled: State Funds Survey Results 2018 (“Survey”) ...more

Brine Injection/UIC: U.S. EPA Environmental Appeals Board Addresses Challenges to Class II Permit

The United States Environmental Protection Agency (“EPA”) Environmental Appeals Board (“EAB”) addressed in an August 8th Order challenges to an Underground Injection Control (“UIC”) Class II Permit (“Permit”) issued by the...more

RCRA/Citizen Suit Enforcement: Environmental Integrity Project Notice of Intent to Sue Phillips 66 Company/Los Angeles County,...

The Environmental Integrity Project and Environmental Advocates sent an August 7th Notice of Intent to Sue (“Notice”) to Phillips 66 Company (“Phillips”) alleging violations of the Resource Conservation and Recovery Act...more

Citizen Suit Enforcement/Safe Drinking Water Act: Center for Biological Diversity Notice of Intent to Sue U.S. Environmental...

The Center for Biological Diversity (“CBD”) sent a July 25th 60-day Notice of Intent to Sue (“Notice”) to the United States Environmental Protection Agency (“EPA”) alleging a violation of the Endangered Species Act...more

State of Washington Rail Transport Crude Oil Volatility Rules: U.S. Pipeline and Hazardous Materials Safety Administration Public...

The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) issued a July 24th Public Notice and Invitation to Comment (“Notice”) addressing the states of North Dakota and Montana’s (“States”) request...more

U.S. Environmental Protection Agency Compliance Requirements for Sale of E15 Gasoline Blends: Mark Morgan (Petroleum Marketers...

Petroleum Marketers Association of America (“PMAA”) Regulatory Counsel Mark Morgan authored a June 28th Compliance Bulletin titled: EPA Compliance Requirements for Sale of E15 Gasoline Blends (“Bulletin”)...more

E15/ASTSWMO Tanks Subcommittee: Comments Addressing Proposed Increase of E15 (Ethanol)

The Tanks Subcommittee of the Association of State and Territorial Solid Waste Management Officials (“ASTSWMO”) submitted April 25 comments to the United States Environmental Protection Agency (“EPA”) on the: Proposed Rule...more

Underground Injection Wells/Industrial Waste: Texas Appellate Court Addesses Challenge to Texas Commission of Environmental...

A Texas Appellate Court addressed in a May 22nd opinion issues associated with challenges to underground injection control permits. See Dyer, et al. v. Texas Commission on Environmental Quality, et al., 2019 WL...more

Air Enforcement: Alabama Department of Environmental Management and Elmore County, Alabama Bulk Gasoline Plant Enter into Consent...

The Alabama Department of Environmental Management (“ADEM”) and Turner Oil Company, Inc. (“Turner”) entered into an April 24th Consent Order (“CO”) addressing alleged air violations. Turner is stated to be the...more

Cargo Tank Marking/Placarding/Hazardous Materials Regulations: U.S. Pipeline and Hazardous Materials Safety Administration...

The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) addressed in a February 7th letter a request for clarification of the Hazardous Materials Regulations (“HMR“) applicable to marketing and...more

Liquefied Natural Gas Export Facility: Oregon Department of Environmental Quality Denial of 401 Water Quality Certification

The Oregon Department of Environmental Quality (“ODEQ”) issued a May 6th denial of a Clean Water Act Section 401 Water Quality Certification for a proposed liquid natural gas export facility (“Facility”) in Coos Bay,...more

Challenge to UIC Class II Permit: April 29th U.S. EPA Environmental Appeals Board Decision

The United States Environmental Protection Agency (“EPA”) Environmental Appeals Board (“EAB”) addressed in an April 29th decision a challenge to an underground injection control (“UIC”) Class II Permit (“Permit”) that had...more

Hazardous Materials/Transportation: U.S. Pipeline and Hazardous Materials Safety Administration Addresses Overpacking Question

The United States Pipeline and Hazardous Materials Safety Administration (“PHMSA”) in a February 25th letter provided clarification of the Hazardous Materials Regulations (“HMR”) applicable to the shipment of hazardous...more

Solid and Hazardous Waste Judicial/Regulatory Developments (2018-2019): Arkansas Environmental Federation Presentation...

I undertook a presentation on April 17th at the Arkansas Environmental Federation Regulated Waste Seminar titled: Solid and Hazardous Waste Judicial/Regulatory Developments: 2018 – 2019 - The discussion addressed...more

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