Part III: 5 Environmental Programs that Apply to You: Spill Prevention

One of the toughest tasks in compliance audit is telling a well-intentioned client that the environmental program that he has been ignoring does, in fact, apply to his operation. In most instances, it’s not a matter of being unaware of the regulation but instead incorrectly determining that the requirement doesn’t apply. This can result from several sources of false confidence:

A program may not be an exact fit–An emergency response program would seem on the surface not to apply to a facility that doesn’t house any hazardous materials or dispose of hazardous waste
A program may not have been intended for them–An oil spill prevention program would seem not to apply to a facility that does not store oil
A facility may have had successful agency compliance inspections–The inspector may have been conducting a media-specific inspection and may not have looked at issues outside that specific medium. Or, as inspectors or human, he may have just missed it—this time.

This is the third in a five part series. In part one, we examined the requirements of the Emergency Planning and Community Right to Know Act (EPCRA). In part two, we looked at the Clean Water Act’s Stormwater Permtting Program.

In this third article of a five part series, we will briefly touch on the requirements of the Clean Water Act’s Spill Prevention, Control, and Countermeasures (SPCC) rule.

EPA regulations require certain facilities that use, store, or process oil to develop written plans to prevent, mitigate, and respond to spills. The Facility Response Plan (FRP) rule and the Spill Prevention, Control, and Countermeasures (SPCC) rule were implemented in response to a catastrophic 1988 spill in Jefferson Hills, Pennsylvania, where nearly 1 million gallons of diesel fuel was spilled into the Monongahela River. The accident was determined to be the result of an improperly reassembled storage tank.

The SPCC rule requires facilities to install secondary containment and other structures to prevent a spill from migrating offsite, to develop a written response plan, to conduct routine training, and to perform periodic inspections of storage tanks and piping.

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FLASH:  MSU’s Gulf Community Design Studio Receives EPA Award for Bayou Auguste Restoration

USEPA – The U.S. Environmental Protection Agency’s (EPA) Gulf of Mexico Program recognized Mississippi State University’s Gulf Community Design Studio (GCCDS) in Biloxi, Miss. with a First Place 2015 Gulf Guardian Award in the Civic/Non-Profit Category. The awards ceremony was July 30th at the Texas State Aquarium in Corpus Christi, Texas.

In 2009, GCCDS worked to produce neighborhood plans for East Biloxi, Miss., a community still recovering from the devastation caused by Hurricane Katrina. From a list of concerns, residents responded positively to suggestions to improve a degraded inner-city bayou. GCCDS began its work to restore Bayou Auguste by engaging elementary student in environmental education activities, and later expanded outreach to a wider audience of residents. The goals of the project were to restore and expand the natural habitat, to make a beautiful natural place free of invasive species and litter, to provide public access and learning opportunities, and to increase local environmental stewardship.

GCCDS worked in partnership with other organizations to transform Bayou Auguste into a neighborhood nature park. GCCDS secured several grants and led a partnership with the City of Biloxi, the Biloxi Housing Authority, Biloxi Public Schools, and the Land Trust for the Mississippi Coastal Plain. The City provided assistance to remove fill material and a retaining wall and to reshape the stream bank. Hundreds of students and volunteers planted native plant species along the upland habitats of Bayou Auguste that reduce erosion and filter stormwater runoff and improve water quality.


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FLASH: EPA Proposes Methane Standards for Oil & Gas Industry

USEPA proposed new methane emissions standards on Tuesday for the oil and gas industry.

As part of the proposal, the agency is updating the 2012 New Source Performance Standards (NSPS) to address methane as well as VOC emissions for sources covered in that rule. EPA’s proposal would also require that industry reduce VOC and methane emissions from hydraulically fractured and refractured oil wells. The proposal is also intended to reduce methane and VOC  emissions downstream from wells and production sites, covering equipment in the natural gas transmission segment of the industry that was not regulated in the agency’s 2012 oil and natural gas rules. Additionally, the agency proposes to clarify and streamline Clean Air Act permitting requirements in states and Indian country.

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