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In response to a settlement with environmental groups and a court order, the EPA has taken the first step to fulfill its obligation under Clean Water Act (CWA) Section 311(j)(1)(C) to issue regulations regarding discharges of hazardous substances from non-transportation-related onshore facilities. Specifically, the EPA is proposing to take no action, that is, promulgate no […]
At the Connecticut Business and Industry Association’s (CBIA) 2018 Energy and Environment Conference, a panel of industry experts recommended several best practices and business strategies that companies should consider as part of their spill response preparation process beyond the mandatory Spill Prevention, Control, and Countermeasure (SPCC) requirements.
Q. My client has their 5-year review of their Spill Prevention, Control, and Countermeasure (SPCC) plan due this year. If they find shortcomings, can they still do the 5-year review/certification of the SPCC to be in compliance, if they program and budget in the project to address the shortcoming?
An oil production company operating in Big Horn County, Wyoming was recently fined for the discharge of approximately 162 barrels of oil into a tributary of a major river. The discharge came from a leak in a pipeline at its pumping facility. The facility is on an onshore oil gathering, pumping, and storage station that […]
There is much confusion surrounding the applicability of SPCC requirements. A question that recently came across the desk of one environmental expert involved oil in flavorings. The person asked if flavorings that contain small amounts of oil (for example, almond and hazelnut oil) count towards an inventory to determine SPCC applicability if they are stored […]
Penalty—$3,650; Cost to Come into Compliance—$30,000 An onshore oil production company in Illinois racked up a rather small penalty of $3,650 for SPCC violations. However, its cost to come into compliance was a substantial $30,000. Their violations can be divided into seven main categories: Problems with the Plan itself: The facility diagram was inadequate. The […]
Standard SPCC plans must describe security procedures for their operation (excluding oil production facilities). The security requirements are meant to prevent oil discharges that result from vandalism or other unauthorized access to oil containers or equipment. Security procedures must include provisions to: Secure and control access to each facility’s handling, processing, or storage areas. Secure […]
A Look at Common Ski Area SPCC Violations Having an SPCC Plan that was not fully implemented. 40 CFR Section 112.3, states, “The owner or operator or an onshore or offshore facility subject to this section must prepare in writing and implement a Spill Prevention, Control, and Countermeasure Plan … in accordance with 112.7 [General […]
Multiple Ski Areas Learn SPCC Compliance Lesson Over the past few years, the U.S. Environmental Protection Agency (EPA) has reached settlements with a number of ski areas in New England communities throughout Maine, New Hampshire, and Vermont. According to the EPA, the settlements “were reached under an expedited settlement program whereby EPA agreed to resolve […]
SPCC Violations Underscore Importance of Facility Response Plans In December 2014, the U.S. Environmental Protection Agency (EPA) announced a settlement with an Alaska-based oil field services company for multiple violations of the SPCC rule, including failure to submit an FRP. Under the SPCC regulations, there are two scenarios that require preparation and submission of […]