By Jeryl L. Olson and Craig B. Simonsen

On September 11, 2013, U.S. Environmental Protection Agency published its revised Spill Prevention Control and Countermeasures (SPCC) Guidance for Regional Inspectors, which is directed not only to EPA inspectors, but also to owners and operators of facilities subject to the SPCC requirements.  The Clean Water Act guidance is designed to “facilitate nationally…
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