Compliance Audits for South Texas Crude Terminals
W&M conducted environmental compliance audits for seven newly acquired NuStar assets that included storage terminals located along a crude oil pipeline system that spans from LaSalle County and Frio County to Live Oak County.
W&M conducted environmental compliance audits under the Texas Environmental Health and Safety Audit Privilege Act. The environmental compliance audits included review of U.S. Environmental Protection Agency (EPA) and Texas Commission on Environmental Quality (TCEQ) regulations in the areas of hazardous and non-hazardous waste generation and recycling; Spill Prevention, Control and Countermeasure (SPCC); Storm Water Pollution Prevention; Emergency Planning and Community Right-to-Know Act (EPCRA) reporting; wastewater discharge; and air emissions permitting. The work was performed under the direction of NuStar’s legal counsel.
W&M prepared a letter report of audit findings, identified compliance gaps, and cost estimates for corrective actions. A summary table was prepared for each Site documenting violations discovered to date. W&M also participated in meetings, conference calls and email correspondence with NuStar as needed to discuss audit findings.