EPA-600/i-^-/
                                                   October 1981
GUIDE FOR SPILL PREVENTION CONTROL AND COUNTERMEASURE INSPECTORS
                                by

                         Walter Unterberg
                        Robert M. Moorehead
           Environmental Monitoring & Services Center
               Rockwell International Corporation
                 Newbury Park, California 91320
                    Contract No.  68-03-2648
                       Project Officers:

                        John  S.  Farlow
           Oil  &  Hazardous Materials  Spills  Branch
  Municipal  Environmental Research Laboratory - Cincinnati
             U.S.  Environmental Protection Agency
                    Edison, New  Jersey 08817

                              and
                                 !
                       Thomas J. Charlton
          Division of Oil and Special  Materials Control
               0*ffice of Water Program Operations
             U.S. Environmental Protection Agency
                     Washington, D.C.  20460
          MUNICIPAL  ENVIRONMENTAL RESEARCH LABORATORY
               OFFICE OF RESEARCH AND  DEVELOPMENT
              U.S.  ENVIRONMENTAL PROTECTION AGENCY
                   CINCINNATI,  OHIO 45268

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                                DISCLAIMER
     This report has been reviewed by the Municipal Environmental Research
Laboratory-Cincinnati, U.S. Environmental Protection Agency, and approved for
publication.  Approval does not signify that the contents necessarily reflect
the views and policies of the U.S. Environmental Protection Agency, nor does
mention of trade names or commercial products constitute endorsement or recom-
mendation for use.
                                     ii

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                                   FOREWORD
     The U.S. Environmental Protection Agency was created because of increas-
ing public and government concern about the dangers of pollution to the health
and welfare of the American people.  Noxious air, foul water, and spoiled land
are tragic testimonies to the deterioration of our natural environment.  The
complexity of that environment and the interplay of its components requires a
concentrated and integrated attack on the problem.

     Research and development is that necessary first step in problem solu-
tion; it involves defining the problem, measuring its Impact, and searching
for solutions.  The Municipal Environmental Research Laboratory develops new
and improved technology and systems to prevent, treat, and manage wastewater
and solid and hazardous waste pollutant discharges from municipal and commun-
ity sources, to preserve and treat public drinking water supplies, and to min-
imize the adverse economic, social, health, and aesthetic effects of pollution.

     This publication is one of the products of that research and provides a
most vital communications link between the researcher and the user community.
It describes the spill prevention, control and countermeasure (SPCC) regula-
tions , the role of the SPCC inspector, the affected facilities, and procedures
for carrying out the inspection, and also contains forms needed by the inspec-
tor for documentation and in the field.  This report will be useful for both
training and reference for new SPCC inspectors.

     This project is part of the continuing program of the Oil & Hazardous
Materials Spills Branch, MERL-Ci, to assess and mitigate the environmental im-
pact of oil pollution.
                                  Francis T. Mayo, Director
                                  Municipal Environmental Research Laboratory
                                  Cincinnati
                                     iii

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                                  ABSTRACT
     This report is intended for use in training and guiding inspectors per-
forming compliance inspections and amendment inspections and documenting these
inspections to implement the Oil Pollution Prevention Regulations promulgated
in 40CFR112 for nontransportation-related onshore and offshore facilities.

     The report covers the SPCC regulations, the role of the SPCC inspector,
the affected facilities, and procedures for carrying out the inspection.  It
contains forms for use by the inspector in the field and for documentation.

     The use of these forms will provide nationwide uniformity in SPCC report-
ing.  Suggested procedures appear below in short form, applicable to all
inspections:

                         The SPCC Inspector's 1-2-3
1 - In field fill out "SPCC Inspection Field Sheet" (1 page) (EPA Form 7500-53)

2 - If facility in compliance          If facility NOT in compliance

    Fill out "SPCC Inspection Sum-     Fill out "SPCC Inspection Summary Sheet"
    mary Sheet" (1 page) only (EPA     (1 page) (EPA Form 7500-52) and "Detailed
    Form 7500-52).                     SPCC Documentation" (7 pages) (EPA Form
                                       7500-54).

3 - Enter information in EPA-SPCC Data Bank:

     Form A - Facility Identification

     Form E - Inspection/Enforcement Report

     Form S - Spill Report (if required)

     This report was submitted in partial fulfillment of Task 4 of Contract No.
68-03-2648 by Rockwell International Corporation under the sponsorship of the
U.S. Environmental Protection Agency,  This report covers the period April 20,
1978, to July 31, 1979, and work was completed as of February 28, 1980.
                                      iv

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                                   CONTENTS
Abstract	iv
Acknowledgment	vi


   1.  Introduction  	   1
            SPCC regulations  	   1
            Objective	   2
            Contents 	   2
   2.  Role of the SFCC Inspector	   4
            Duties 	   4
            Knowledge	   6
            Skills 	   7
            Attire and equipment	   9
            Attitude and behavior   	   10
   3.  Affected Facilities and Their Spill Potential  	   13
            Nontransportation-related facilities  	   13
            Spill hazards	14
            Spill causes .	16
   4.  Compliance Inspections	20
            Preparation and initial contact  	   20
            Review of SPCC plan	20
            Facility inspection  	   23
   5.  Amendment Inspections Under 40CFR112.4  	   29
            Preparation	29
            Review of SPCC plan	29
            Facility inspection  .  . . . :	30
   6.  Documentation of SPCC Inspection  -. . .	31

References	•	33
Appendices

   A.  Environmental Protection Agency regulations 	   34
   B.  Nontransportation-related facilities  	   47
   C.  SPCC inspection checklist	73
   D.  Report of SPCC inspection	87
   E.  EPA-SPCC data bank forms	101

Glossary	107

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                               ACKNOWLEDGMENTS
     Discussions were held with and helpful suggestions were received from
the following EPA personnel:

     Tom CharIton, Division of Oil and Special Materials Control,
                     Washington, O.C.

     Ron Clawson, Surveillance and Analysis Division, Region IX,
                     San Francisco, CA

     Wallace Cooper, Surveillance and Analysis Division, Region VI,
                     Dallas, TX

     Steve Dorrler, Environmental Response Team, Edison, NJ

     Jim Jaffe, Enforcement Division, Region IX, San Francisco, CA
                                      vi

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                                  SECTION 1

                                INTRODUCTION
SPCC REGULATIONS

     In December 1973, the U.S. Environmental Protection Agency  (EPA)  issued
in the Federal Register its Oil Pollution Prevention Regulations  for
Nontransportation-Related Onshore and Offshore Facilities  (40CFR112).  The
purpose of these regulations is to prevent spills from nontransportation-
related facilities by establishing procedures, methods, and equipment  require-
ments for owners or operators of facilities engaged in drilling,  producing,
gathering, storing, processing, refining, transferring, distributing,  or con-
suming oil.  These regulations require the owners or operators of designated
onshore and offshore facilities to prepare a Spill Prevention Control  and
Counter-measure Plan (SPCC Plan) in accordance with certain guidelines  contained
within the regulations.  These guidelines require the installation or  construc-
tion of certain spill prevention systems depending upon the type  of operation
conducted at the facility.  It is the intention of these regulations that
these spill prevention systems be designed, installed, and operated according
to good engineering practices.

     Associated with 40CFR112 are several other environmental regulations as
follows (complete texts in Appendix A):

     40CFR109, Criteria for State, Local, and Regional Oil Removal
     Contingency Plans — This regulation governs contingency plans
     which are part of SPCC plans under certain circumstances when
     conventional spill prevention is not feasible;
                   V
     40CFR110, -Discharge of Oil — This regulation applies to the
     discharge of oil into navigable waters, adjoining shorelines,
     or waters of the contiguous zone;

     40CFR114, Civil Penalties for Violation of Oil Pollution Pre-
     vention Regulations — Outlines enforcement procedures, with
     tna-g-tTmim liability of $5000 for each day a violation continues.

     The SPCC inspection program is the mechanism which the EPA uses to deter-
mine compliance with SPCC regulations.  Compliance inspections enforce
40CFR112.3 by verifying that an SPCC plan exists for a facility falling under
40CFR112, that this plan is technically adequate, and that the provisions of
the SPCC plan have actually been carried out in the facility.  The legal basis
for compliance inspections is contained in 40CFR112.3(b), which states, in
part:

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      "Owners  or  operators  of  a facility  for which  an  SPCC plan  is
      required ...  shall  maintain a complete copy of the plan  ...
      and  shall make  such plan available  to the Regional Adminis-
      trator for  on-site  review during normal working  hours."

      When a spill  of a certain magnitude has occurred from a  facility having
an SPCC plan,  40CFR112.4 requires submittal by the owner or operator of his
SPCC  plan to  the EPA Regional Administrator for review and possible amendment.
The Regional  Administrator may require that the plan  be amended to minimize
the possibilities  of spill recurrence.   After EPA  review of the plan, an amend-
ment  inspection  may  be performed which may result  in  additional SPCC require-
ments being specified by the  EPA.  The legal basis for this is contained in
40CFR112.4(d)  which  states, in part:

      "After review of the  SPCC plan  ...  submitted  by  the owner or
      operator ...  the Regional Administrator may require the  owner
      or operator ...  to  amend the SPCC Plan if he  finds that  the
      Plan does not meet  the requirements of this part or that the
      amendment of  the Plan is necessary  to prevent and to contain
      discharges  of oil from such a facility ... and shall specify
      the  terms of  such amendment."

      EPA's SPCC  regulations were to be implemented by 11 January 1975 by about
30,000 oil marketing terminals and bulk  plants; about 285 oil refineries; sev-
eral  thousand production facilities, both onshore  and offshore, and many bulk
oil consumers.   As of 1  June  1976, the EPA had completed 12,313 compliance
inspections.   Evaluation of the SPCC program to date,  in terms of spill his-
tories and enforcement,  has disclosed variations among the EPA regions (Neal
and Dalsimer,   1978).

OBJECTIVE

      Uniformity  in carrying out SPCC inspections is desirable and therefore a
document  which provides  uniform guidance on a nationwide basis is required.
Also, personnel  new  to the SPCC program need to be trained in inspection and
documentation procedures.

      This "Guide for Spill Prevention Control and  Countermeasure Inspectors"
is to be  a training  and  guidance report  for those  performing .compliance in-
spections and amendment  inspections and documenting such inspections to
enforce the Oil  Pollution  Prevention Regulations promulgated  in 40CFR112 for
nontransportation-related  onshore and offshore facilities.  Operators/owners
of such facilities should  also find this report useful in developing their
SPCC  plans.

CONTENTS

      The  remainder of this report is divided into  Arabic-numbered sections.
Section 2 describes  the  role  of the SPCC inspector, including the knowledge
and skills he  should possess,  the attitude and behavior he should exhibit when
dealing with  facility personnel, and the attire and equipment he should take
into  the  field.  Section 3 briefly covers the affected nontransportation-

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related facilities (discussed in detail in Appendix B) and  their potential  for
incurring oil spills.  Section 4 is devoted to Compliance Inspections  starting
with preparations for the inspection and then continuing with  the  initial con-
tact with the facility and the SPCC plan review, and ending with the facility
inspection itself.  Section 5 deals with Amendment Inspections and parallels
4 in its sections.  Section 6 deals with documentation of inspections  for both
compliance and amendment inspections.  This is followed by  a section on Refer-
ences .

     This is followed by a number of appendices which include  the  texts of  the
applicable federal EPA SPCC regulations (Appendix A), a. discussion of
nontransportation-related facilities (Appendix B), an SPCC  inspection  check-
list (Appendix C), Report of SPCC Inspection forms (Appendix D), and EPA-SPCC
Data Bank forms (Appendix E).  The report concludes with a  Glossary of the  most
commonly used terms.

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                                 SECTION  2

                         ROLE OF THE SPCC INSPECTOR

     This section deals with the SPCC inspector's role, knowledge,  skills, at-
titudes, and behavior, as well as  the equipment the inspector should carry and
know how to use.  Both men and women may be inspectors; in what follows, the
use of a masculine pronoun will be taken as applying  to women as well.

     The SPCC inspector works directly or indirectly  for the Surveillance and
Analysis Division or  the Enforcement Division of one  of the 10 U.S. EPA
Regions, shown in Figure 1.  His findings and recommendations are filed in his
division, and when necessary are also transmitted to  the regional Enforcement
Division for action under 40CFR114 (see Section 1 and Appendix A).

     The inspector will be asked to perform both compliance and amendment in-
spections throughout  the states in his EPA Region.  In the case of  coastal
states, this may include offshore  facilities in inland waters of the United
States.  Inland waters generally include those within the coastal 3-mile lim-
it, depending on the  particular state.  The 1977 amendments to the  FWPCA ex-
tended EPA's authority for prevention activity out onto the outer continental
shelf, and additional amendments may extend the jurisdiction of Part 112 at a
later date.

DUTIES

     The obvious purpose of inspecting facilities is  to ensure compliance with
the FWPCA through regulation 40CFR112.  But in a larger sense, it is the spirit
rather than the letter of the law  which should be foremost in the inspector's
mind.  While the inspector makes determinations of fact, and may ascertain that
there are discrepancies and defects in an SFCC plan or its implementation, he
must also be mindful  of the most effective and equitable way in which the SPCC
plan can be brought into compliance and the overall purpose, that of minimiz-
ing oil pollution, achieved.  Even though the inspector is a representative of
the EPA, a government agency, the  principal attitude  he should exhibit is that
of cooperation with the owner/operator of the facility in remedying a problem
in a manner which is  mutually acceptable.  The most successful inspections are
those which achieve the desired results through the cooperation of  the owner/
operator and without  the need for  enforcement action.

     The sequence of  tasks performed by the inspector is generally  the
following:

     1.  Obtain advance information on facility to be inspected;

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         •  REGIONAL HEADQUARTERS
                        "    VII \
                                KANSASCIIV



                                     AH
Figure 1.  EPA Regional Offices - Standard Federal Regions

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      2.  Obtain  and  review SPCC  plan,  at  the  EPA  Region  (if  amendment  inspec-
         tion) or  in the field,  always prior  to field  inspection.

      3.  Make  field  inspection,  filling in  inspection  checklist(s)  applicable
         to  the  particular facility at the  time of  the inspection;

      4.  Write up  inspection field  report while still  at  the facility,  dis-
         cuss  the  report with the facility  operator, and  be  sure to record
         his opinions;

      5.  Write up  inspection documentation  report with conclusions  and  recom-
         mendations;  and in the  case of amendment inspections, .include  speci-
         fic engineering changes which in your judgment should be made  to
         reduce  future  spill hazards;

      6.  Enter information from  the inspection on EPA-SPCC Data Bank forms.

      Some  forms  and  checklists are  provided in this report for use  by inspec-
tors  in  the  field.   However,  it  is  highly desirable that  the documentation
report be  written  as  much as possible  in a  continuous  narrative style,  making
each  documentation report as individual to  the facility of interest as  pos-
sible and  highlighting  the specific nature, problems,  etc. of that  facility.
This  will  enable any subsequent  interaction with  that  facility to be carried
out most effectively, as well as permit any later amendment  inspection  to be
as accurate as possible, comparing  past and present conditions.

KNOWLEDGE

      The inspector must have a good knowledge of  the.basic SPCC regulation
contained  in 40CFR112,  especially Part 112.7 which contains  the guidelines for
SPCC  plans.  Appendix A contains the full text of this regulation as well as
other associated oil  spill regulations. . Jaffe (1978)  paraphrases 40CFR112,
citing legal clarifications.  A  frequently  used format for an SPCC  plan for
production facilities is that suggested by  the American Petroleum Institute in
its Bulletin D16 (API,  1976), of which the inspector should have a reference
copy.

      Next, the inspector must become familiar with the SPCC  plan in its vari-
ous forms.  The  plan contains "certification information" with information
about facility,  ownership, and plan preparation,  followed by sections on pre-
vention  of oil spills and containment  of oil, should a spill occur.  The large
compendium entitled  "Oil Spill Prevention,  Control, and Countermeasure  Plan
Review"  (Pace, Inc.,  1975) has a section on SPCC plans, with several examples.
The inspector should  have a reference  copy  of and be familiar with  this
document.

      The inspector must also know the  makeup of the various  types of
nontransportation-related facilities.   The  facilities  affected are  spelled out,
in the appendix  of 40CFR112 (Appendix  A).   Copious descriptions are contained
in the Pace report,  touching on  all types of facilities.  Section 3 and Appen-
dix B examine these  from the SPCC Inspection standpoint.

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     Before Che inspector embarks on an SPCC Plan Review or a field inspection
of a facility, he must acquaint himself thoroughly with the equipment and
structures that make up that facility.  Once he has a good understanding of
the way in which oil moves into the facility, within the facility, and out of
the facility, he is able to spot the places where potential oil spills can
occur.  Section 3 lists specific spill hazards and causes, edited from the
Pace document.

     For the case of offshore and onshore crude oil petroleum systems, an anal-
ysis of some 15,000 spill records in several states provided SPCC guidelines
for systems and components of such facilities, useful in developing and review-
ing SPCC plans (Ritchie and others, 1973).  Another study investigated small
petroleum production and products distribution facilities in four regions of
the country to identify operational and economic SPCC problems.  For each
type of plant, a generic SPCC plan was developed to serve as a model
(Trentacoste and others, 1980).

     Having acquired a knowledge of the federal regulations, SPCC plans, the
nature of nontransportation-related facilities, and the spill-prone parts of
such facilities, the inspector is in a position to evaluate and review SPCC
plans from a regulatory and broad technical standpoint.

SKILLS

     The most important part of the inspector's job is in the field.  He should
have a scientific or technical background and be a good observer.  Beyond ac-
quiring specific skills which are described below, he must acquire proficiency
in activities which involve making observations of drainage and facility lay-
out.  In addition, the inspector should have a genuine interest in interacting
with people, even though the relationship between the inspector and the owner/
operator may be an adversary one.

     The required skills fall into the following categories:

     1.  Reading of topographical maps and general (not specialized) inter-
         pretation of aerial photographs

     2.  Terrain appraisal to indicate the course taken by potential flows
         of spilled oil

     3.  Ability to determine the adequacy of containment structures and
         contingency plans

     4.  Ability to communicate orally with owner/operator

     5.  Documentation skills,  such as writing, sketching, and photography

     These five skills will be treated in the following subsections.

Reading of Maps and Aerial Photographs

     The inspector will use maps originating from different agencies during
SPCC inspections.  Notably, he will use topographical maps such as those

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distributed by  the U.S.  Geological  Survey, called  "quad sheets."  These maps
contain  (brown) contour   lines which  give an indication of  the  topography of
the actual terrain,  and  (blue) lines  indicative of perennial and intermittent
watercourses.   Superposition  of an  onshore facility on a topographical map
permits  the inspector  to determine  whether or not  a discharge might reach
navigable waters.  An  explanation of  the nature and use of  topographical maps
is contained in the  section on "Stationary Containment" (V.B.4) of Pace Co.
(1975).

     Aerial photography  has been used to clarify details on the ground where
surface  accessibility  is difficult  and where dense vegetation exists.  Spe-
cialized techniques  involving color photography have been developed, notably
by the EPA Laboratory  in Las  Vegas, NV, applicable to SPCC  inspections.  Spe-
cialized differentiations in  color  can be used to  identify variations in sur-
face conditions, including detection of oil-covered areas.  Shadows can be
used to  estimate the ground height  of structures and thus the volume of stor-
age tanks.  Aerial photographs furnished to EPA inspectors will generally
have already been interpreted and questionable areas noted by specialists.
However, the inspector generally familiar with aerial photography can use the
photos to orient the facility on a  quad sheet, orient himself on the facility,
and locate important features to be examined during inspection.

Terrain  Appraisal

     The inspector must  determine,  in the field, whether there is a reason-
able spill expectation,  defined as  the potential flow of spilled oil from a
facility to navigable  waters.  He will need to estimate whether ground slopes
in and around a facility cause any  spilled oil to  flow out or stay contained
within the facility.   He may  use instruments such  as a. hand level to assist
in these observations.   The SPCC regulation only deals with spills reaching
surface  waters.  However,  spills reaching surface  waters by way of transport
by ground water come within the purview of 40CFR112.  Since most areas in the
United States experience rainfall which runs off,  and navigable waters include
intermittent streams (most storm drains ultimately lead to navigable waters),
most onshore facilities  will  have a reasonable spill expectation.  An excep-
tion would be a desert area with negligible rainfall and no navigable waters
in the vicinity.  The  inspector must be able to make simple field drawings and
use topographic maps to  indicate the relationship  between the facility, the
course of oil spills,  and navigable waters.

Adequacy of Spill Containment Measures or Contingency Plans

     Frequently, the inspector will need to know the volume of above-ground
tanks of various shapes  and sizes and also the storable volume within contain-
ment structures such as  dikes.  First he must know the dimensions of these
structures and  if they are not available from plans, field estimates must be
made either by  pacing  or measuring, or by counting plates and seams.  Gener-
ally, a  containment  dike must be able to store the volume of the largest tank
which it surrounds.  Calculation formulas for various shapes encountered in
the field are contained  in Appendix E, "Dike and Tank Volume Calculations," of
the Pace Co. report.   The inspector must also be able to make a judgment as to
the strength of the  structures, from field observation and elementary

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hydrostatics.  Unreinforced concrete block walls, for example, when used for
diking will have strength to retain only a small hydrostatic head.

     40CFR112.7(d) offers an SPCC plan alternative to stationary containment,
in the form  of a strong oil spill contingency plan and a written commitment of
manpower, equipment, and materials to enforce the contingency plan.  When sec-
ondary containment systems are impracticable, the owner/operator must clearly
demonstrate such  impracticability.  The contingency plan then becomes part
of the SPCC plan and the inspector must be able to make a judgment as to its
adequacy, guided by 40CFR109 (Appendix A).

Oral Communication Skills

     The inspector will be involved in face-to-face conversations and tele-
phone conversations with a variety of facility personnel, ranging from upper
management to on-site supervision and workers.  In all these contacts he must
be able to express himself clearly and concisely, sticking to the business at
hand.  He should make a record of important conversations, noting the time,
the place (or if it was a telephone conversation), the other person, and the
main points of what was said on both sides, with quotes of important
statements.

Documentation Skills
     In the course of the field inspection, the inspector may have occasion to
take photographs in the facility and to make field sketches and maps.  He
should always ask permission before using his camera.  He will be filling out
the SPCC Inspection Checklist (Appendix C) and the Report of SPCC Inspection
(Appendix D).  The most important and permanent of these documents is the last-
named because it furnishes the actual evidence for any subsequent enforcement
action, whether it results in a court case or not.  The Report of SPCC Inspec-
tion includes documentation which should be written up in sufficient detail so
that even if the persons associated with the inspection, whether representing
the owner/operator or the government, are no longer available, the report can
stand on its own.  It should be written in narrative form and it may be neces-
sary to include sketches, maps, and/or photographs.

ATTIRE AND EQUIPMENT

     The inspector will be meeting with facility personnel in city offices,
field offices, in onshore facilities, and on offshore platforms.   In each
place, his attire should be suited to the occasion and match that of his
counterparts.  When going into the field, he should carry a hard hat and
pocket knife, and wear tear-resistant clothes and oil- and slip-resistant work
shoes/boots with safety toes, gloves, and raincoat as necessary.  All safety
attire and equipment should be nonsparking, not produce static electricity,
and comply with OSHA regulations.  In his car he should carry an intrinsically
safe camera with film.  Also, a cassette tape recorder might be useful.  These
two devices would normally not be used unless special circumstances arose or
the regional policy required it, and in all cases only with the consent of the
facility owner/operator.  The inspector should carry a rugged briefcase, the
suggested contents of which are listed below:

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      •   Identification/credentials,  with photo

      •   SPCC  Inspection checklist (Appendix C) blanks

      •   Documentation Report of  SPCC Inspection  (Appendix  E)  blanks

      •   SPCC  Inspection Field Report (Appendix D)  blanks

      •   Tablet  (8V  x 11"  min.)/sketch  pad

      •   12-inch scale and  50-foot tape  measure

      •   Shorthand  notebook (for  log/notes)

      •   Tank  and dike volume formulas or  nomographs

      •   Standard symbols listing  and template(s)

      •   Copies  of  40CFR112  (Appendix A)  (one dozen min.)

      •   Maps  of  areas,  including  highway  and topographical

      •   Aerial  photos (if  available)

      •   SPCC  plan  for facility, if available

      •   Extra ballpoint pen,  pencils (various colors)

      •   Three-ring notebook  or clipboard  (this will hold inspection forms
         and copies of 40CFR112)

      •   Pocket  electronic  calculator (in  working condition)

      •   Hand  level and range  finder

ATTITUDE AND  BEHAVIOR

      The overall role of the  SPCC Inspector has been discussed above, in
terms of "matter" and "manner."  -The "matter,",consisting of knowledge,
skills,  and equipment that the inspector  is expected to possess, has been
covered.  The "manner" will be covered here.

      It  is a  fact of  life  that as the world shrinks, individuals and organi-
zations  become more  interdependent and are less and less able to live indepen-
dently of others.  The inspector needs to realize (as the owners/operators
should realize)  that  we are all interdependent and that regulatory agencies
such  as  the EPA are not enemies of business.  They are, in fact, partners.
However, if something goes awry in this partnership a severe adversary rela-
tionship can  develop, which can be detrimental to all concerned.  The inspec-
tor cannot totally avoid such  a relationship, but he can minimize it by proper
attitude and  behavior.
                                      10

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     In any telephone contacts, which may precede face-to-face meetings, the
inspector should establish his image as a firm but polite EPA representative.
When visiting a facility, he should be mindful not only of the general ameni-
ties that a guest observes, but should be particularly aware of specific
taboos with regard to smoking, alcohol, drugs, and firearms.  Under no cir-
cumstances should he visit a facility when under the influence of alcohol or
drugs.  He must not take alcoholic beverages, illegal drugs, and firearms
into a facility.  If a smoker, he should ask permission to smoke if visiting
an office area or other designated smoking area.  The greater part of facili-
ties that handle oil will be designated non-smoking areas, and there may be
state laws governing the carrying of matches and cigarette lighters in such
areas.

     Access to facility areas is at the discretion of the owner/operator.  If
access to any area is denied to an inspector, he should not challenge this,
but make a note of the incident. . In cases of significant noncooperation, a
court order to permit access can be obtained.

     During the Inspection, there will be frequent routine legal questions
regarding time/extensions, applicability, penalties, and so forth, which are
quite clear in 40CFR112 and can be answered in a straightforward manner.  How-
ever, occasionally a difficult legal question may arise.  At this time, it
would be advisable for the inspector to clarify his role, e.g., "I'm here to
evaluate engineering plans — I'm not qualified to give legal opinions; there-
fore, you will need to discuss those areas with the EPA attorney."  Include
the name of an appropriate attorney in the Regional Enforcement Office or the
Regional Counsel as a contact.

     Some specific "do's" and "don'ts" are listed below:

     Do Be;

     .  Businesslike

        Friendly

     .  Knowledgeable

     .  Helpful/Informative

        Cooperative

        Considerate

        Firm (not stubborn)

     Don't Be;

     .  Hostile/belligerent/arrogant

     .  Personal (with criticism)

     .  Insulting

     .  Wasteful of the owner/operator's time

     .  Disinterested in the owner/operator's problems


                                     11

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        The willing target of insults/abuse from facility personnel —
        leave at once

     .  Argumentative

     .  Subjective

        Impatient

     No one can be expected to have all these desirable personality, charac-
ter, and attitudinal traits all the time, but it is essential for the inspec-
tor to strive to have a basic understanding of the "road blocks" to doing an
effective job that he can unintentionally set up.
                                     12

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                                 SECTION 3

               AFFECTED FACILITIES AND THEIR SPILL POTENTIAL
NONTRANSPORTATION-RELATED FACILITIES

     The SPCC regulations affect "Nontransportation-Related Onshore and Off-
shore Facilities."  These are defined in the Appendix to 40CFR112  (reprinted
in full in Appendix A of this report) as falling into 11 categories, briefly
described as follows:

     (a)  Fixed onshore and offshore oilwell drilling facilities

     (b)  Mobile onshore and offshore oilwell drilling platforms, barges,
          derricks, etc.

     (c)  Fixed onshore and offshore oil production structures, platforms,
          derricks, and rigs

     (d)  Mobile onshore and offshore oil production facilities

     (e)  Oil refining facilities

     (f)  Oil storage facilities

     (g)  Industrial, commercial, agricultural, or public facilities which
          use and store oil (including large oil-immersed transformers)

     (h)  Waste treatment facilities

     (i)  Loading racks, transfer hoses, etc., used to transfer oil to and
          from highway vehicles or railroad cars

     (j)  Highway vehicles and railroad cars used for transport of oil
          within a nontransportation-related facility

     (k)  Pipeline systems used for the transport of oil within a
          nontransportation-related facility

     The term "oil" means oil of any kind (animal, mineral, and vegetable)
and in any form'(including crude, refined products, sludge, refuse, oil mixed
with wastes other than dredged spoil).  Excluded are facilities associated
with the handling or transferring of oil in bulk to or from a vessel.

     Further, only those facilities are affected which could reasonably be

                                      13

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 expected to  discharge oil in harmful  quantities  into  waters  defined as  navi-
 gable and which have non-buried aggregate storage capacity greater  than 1320
 gallons  or non-buried storage capacity  greater than 660  gallons  in  a single
 container or which have underground buried storage capacity  in excess of
 42,000 gallons.


      In  Appendix B there is a detailed  discussion of  typical nontransportation-
 related  facilities from the SPCC standpoint,  emphasizing features prone to
 spills.   Appendix B is divided into (1)  Onshore  Nonproduction-Related Facili-
 ties, (2) Onshore Production and Drilling/Workover Facilities, and  (3)  Off-
 shore Production and Drilling/Workover  Facilities.

 SPILL HAZABDS

      The information in the next few pages   ("Spill Hazards" and  "Spill
•Causes") is  adapted from the Pace Company report,  1975.   Discounting catas-
 trophic  accidents such as major fires,  earthquakes, or explosions,  most oil
 spills resulting in environmental degradation can be  classified  as  (1)  equip-
 ment  omissions  or failures, and (2) operators' errors.   Adequate design,
 proper equipment selection, careful inspection,  and prompt correction of de-
 ficiencies can  prevent almost all damage from the first  classification.  Auto-
 mated monitoring and safeguards can prevent many operational errors.  However,
 no  hardware  can take the place of adequate operator training and supervision.

      Many spills are of small volume, one or  two gallons,  but if these  spills
 occur frequently, the effect on the environment  can be significant.   Large
 spills which might occur if a large storage tank were to rupture can be equal-
 ly  detrimental,  although the occurrence  might be less frequent.  Table  1 has
 been  prepared based on an evaluation  of  both  the probability and severity of
 potential spills.  The relative importance of each is a  matter of experience
 and judgment.

      Data do not exist on the probability and severity of  spills for the fa-
 cilities described in this report.  The  information presented is based  on
 actual experience with spills for the facilities.   An attempt has been  made
 to  present the  relative importance  of spills  by  type.  Naturally, there will
 never be a full consensus on any type of numerical ranking of probability/
 severity. However, this evaluation,  although somewhat arbitrary, should be
 of  value as  a guide in determining  the relative  importance of each  piece of
 equipment and each operation having a potential  for oil  spills.

      Table 1 lists an overall view  of the probability/severity of spills.
 However, a more accurate determination of spill  potential  can be obtained by
 assessing the following factors for a particular facility  under  review:

         Nature  and amount of oil handled

      .   Frequency of use of piping, loading rack,  tank drain, etc.

         Operation conditions:  temperature, pressure,  flowrates

      .   Condition of equipment

                                      14

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                       TABLE  1.   AREAS  OF  POTENTIAL  SPILL HAZARDS*
Tank
BJUI7MEOT
Tanks
Gauges
Sampling facilities
Shell and bottom*
Underground seepage
Heating coils
Containment dikes
Oik* drains
Pio«. Valves S Fitting
Seal failure
Valve seen packing
Gaskets
Pipe rapture
Pumos 4 Mechanl^fll Eauip1
Seels
Lubricating systems
Loading Stations
Fill safeguards
Curbs and drains
tfaste Disposal
Oil sumps
Separators
Site drainage
Pits
OPERATIONS
Tanks
Filling/overfilling
Sampling
Cleaning
Dike draining
Pipes. Valves & Fittings
Maintenance
Collision
Pumps
Maintenance
Loading Racks
Overfills
Loading drips
Waste Disposal
Monitoring
Maintenance




H/3 M/3
a/3 H/3
L/l L/l
L/l L/l
M/2
M/2 M/2
H/2

M/3 M/3
M/2 H/3
L/l L/l
oent
M/2 M/3

L/l
H/2

M/2 M/3
M/2 M/3
H/l L/2


a/i H/i
H/2 M/3
H/l L/2
H/2

H/2
H/l

H/3 H/3

H/2
H/3

H/2 M/3
M/l L/2

Probability
R - High, occurs frequently
M - Medium, could occur periodically
L - Low, could occur on less frequent


M/3
L/l
L/l
M/2

M/3
M/3
L/l
M/3

L/l
H/2

M/2


M/2
M/3
L/2

M/2
L/2

R/3

M/2
H/3

M/3
L/3
KZY:

occasions
Power
Plants


M/3
L/l
L/l
M/l
M/2
L/2

M/3
M/3
L/l
M/2.



M/2
M/2
L/2


M/l
M/3
L/2
L/2

M/2

H/3



M/3
L/3


Industrial Onshore
Plants Drilling Production


H/3
H/3
L/l
L/l
L/2
M/2
M/2

H/2
H/2
L/2
H/2
H/2



M/2
M/2
H/2


H/l '
H/2
M/l
M/2

H/2
L/l

H/2



M/2
L/2




M/3
L/l
M/3 L/2
M/2

L/l L/l
M/2
M/2
L/l
a/3 H/I
a/ 3

H/2
M/2

H/2
M/l
H/2 M/2
M/2 M/2


M/2 H/l
H/3
H/2
H/2

H/l H/3
L/l

H/2 H/3

H/2
H/3

M/2 H/2
H/2 L/2

Severity
Offshore
Produc ciou


M/2
L/l

L/l
M/2
M/2
L/l
H/2
H/2



H/2
H/2


L/2
L/3
L/2

H/2

H/2



H/2
L/l


1 - Major cleanup required
2 - Intermediate cleanup required
3 - Minor cleanup required
* Adapted from Pace Company Consultants and Engineers, 1975.  In training manual for Oil Prevention Control and
  Countermeasure Plan Seview.

                                                  15

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        Degree of operator responsibility
        Distance to water
SPILL CAUSES
     The following is a list of specific causes of potential spills for each
facility type.  These lists are intended to augment the subheadings of Table
1, explaining how spills have occurred at each of the facilities listed.  At
any specific facility, adequate safeguards or adequate maintenance may mini-
mize or negate the potential for spills.  However, each item is worthy of
inspection to properly evaluate the spill expectation (Pace Co., 1975).
     Bulk Storage Facilities — Tank Farms and Tankage, Including  Drums
        Spills due to overfilling of tanks
        Rupture of tanks
        Leaks in pipe, valves, pumps, fittings, and other equipment
        Leaks in containment dikes
        Inadequate secondary containment systems
        Oil flow from diked area through open dike valve
        Level instrument failure allowing tank overfilling
        Piping and tank damage by collision with mobile equipment
        Spills from water drawoff from tanks
        Spills from tank bottom cleanout and sludge disposal
        Improper disposal of samples
        Overflow of oil/water separation equipment by rainfall flooding
        Poor maintenance of pipe, valves, pumps, fittings, and other
        equipment
        Plugging of drainage system by debris
        Oil/water separation equipment with insufficient treatment capacity
        Spills from heating .coils in heavy fuel tanks
        Spills from line flushing
        Spills from pipe and tankage changes
        Spills from underground storage tanks
     .   Possible sabotage
     Bulk Handling Facilities — Terminals. Pipelines
        Spills from quick-connect coupling operation and damaged loading
        connections
        Overfilling tank trucks, tank cars, barges, tankers, etc.

                                     16

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Bulk Handling Facilities — Terminals, Pipelines  (continued)
.  Lack of curbs, drains, and spill collection system
   Improper operation of oil/water separator
.  Leaks from loading arms, especially joints and gaskets
   Improper disposal of sludge from product filters
   Insufficient sump capacity (should be equal to volume of largest
   compartment of tank truck or rail car)
.  Operators incorrectly setting loading meters and tanks overfilling
   Level switch or sump pump failure on oil sumps
   Spills from ruptured hoses
   Spills from truck or rail cars caused by moving before completely
   disconnecting hoses or loading arms
   Possible sabotage
User Facilities — Airports
   Leaks from quick-disconnect couplers
.  Filter sludge disposal
.  Tank sample disposal
   Cleanup of spills in sumps
.  Leaks from pump seals and other equipment due to poor pump
   maintenance
   Spills from storage facilities over or above ground
User Facilities — Power Plants
   Spills from heating coils in heavy fuel tanks
.  Leaks and spills associated with railroad tank car and truck
   unloading facilities
   Leaks from pipe, valves, pumps, fittings, and other equipment
   Leaks from tank mixer stuffing boxes
   Spills and overfilling of tanks
   Sludge disposal from tanks
.  Line flushing oil disposal
.  Spills from storage facilities
User Facilities — Industrial Plants
   Spills due to manual transfer of oil
   Spills from storage tanks

                                17

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User Facilities — Industrial Plants (continued)
   Tank damage as a result of collisions with vehicles
   Spills caused by lack of secondary containment systems
   Spills from oil burners
   Overfilling of tanks
   Leaks from pipe, valves, pumps, fittings, and other equipment
   Leaching from oily wastes
   Spills from deliveries of fuel oil and oil products
   Spills from machinery and cutting fluid operations
   Spills from storage facilities
Drilling and Workover
   Dike leaks and overfilling of the reserve pits
   Spills at the mud preparation site
   Spills from drum and small tank storage of engine and machinery
   lube oils
.  Spills and leaks from fuel tanks
   Machinery leaks from rotary table, draw works, and generators
   Spills from drill pipe racks
   Spills and overflow from settling pit, shale shaker, and mud
   suction pit
.  Leaching from cuttings and shale
   Sand cleanout spills
.  BOP failure; blowout
   Flooding of waste pits due to heavy rainfall
Onshore Production
   Leaks from capped and abandoned wells
   Spills from pipe, valves, pump fittings and other equipment
.  Gathering line leaks
   Gathering line rupture by equipment collision
.  Gathering line breakage by rainfall runoff
   Tank leaks and ruptures
.  Tank overfilling
.  Rod pump stuffing box leaks
   Gauging spills, sample disposal

                                 18

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Onshore Production (continued)
   Transfer hose, coupling, and loading rack spills
   Blowout
   Salt water pit overflow
   Christmas tree leaks
.  Tank cleanout
   Water drawoff sump overflow spills
Offshore Production
.  Deck leaks and spills
   Sand erosion of pipe, valves, and fittings
   Fuel and lube oil spills
   Pump seal and packing leaks
   Pipe, valve, and fitting leaks
.  Drips from draw works, rotary tables, and engines
.  Blowout of well
   Subsurface valve failure
   Sand cleanout and handling spills
                                 19

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                                  SECTION  4

                            COMPLIANCE INSPECTIONS
PREPARATION AND  INITIAL CONTACT

     Once a facility or series of facilities In a certain area has been
selected for compliance Inspection, the inspector should try to obtain as much
advance data as  possible.  These data will include location, names and titles
of operating personnel, name of owner, type of activity, storage capacity,
data on other facility equipment, normal working hours, climate, precipitation,
etc.  In this connection it is very useful to take aerial photographs for they
can reveal not only the sizes of tanks and other facility items, but also oil-
stained areas which show residual oil, presumably from previous spills.  The
general case, though, is that the facility will not have been previously iden-
tified and no data will be available.  Most compliance inspections will be
surprise inspections without warning to the owner or operator.

     Alternately, an initial contact may be made with the owner or operator,
usually by phone, for an early review of SPCC Plan(s).  Such a review meeting
may be attended  by a number of people from the owner/operator's organization,
especially if it is a large organization.  Here the inspector will present his
credentials and  explain precisely the reasons for his visit and his desire to
be cooperative in giving any additional explanations desired and in scheduling
facility inspection visits at times convenient to the owner/operator.

     It will be  very helpful if the inspector can obtain a copy of the SPCC
plan or plans which pertain to the facility or facilities he intends to inspect.
In general, it is preferable to review the SPCC plan before actually visiting
the facility so  that time can be saved during the actual field inspection be-
cause the working of the facility and its spill potential can first be explored
on paper.

REVIEW OF SPCC PLAN

     In order to determine the adequacy of an SPCC plan, it is recommended that
the facility not be surveyed prior to review of the SPCC plan, although many
facilities may have been surveyed by EPA's aerial reconnaissance efforts.  If
the plan is properly prepared, the inspector will be able to formulate a very
clear picture of the facility.  However, if the facility'is surveyed first,
the inspector may assume (from memory) that a particular area is discussed in
the SPCC plan.   Occasionally, for one reason or another, the facility will have
been visited prior to reviewing the SPCC plan, and then it is important that
the plan be reviewed extra carefully and the facility thoroughly inspected


                                      20

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again. — the inspector should always visit the facility after reviewing the
SPCC plan.  Both actions may, of course, be carried out in succession during
a single visit to the facility.

     Two forms for field use in SPCC plan review and facility inspection have
been devised.  The "SPCC Inspection Checklist" (Appendix C) for all types of
facilities is provided for the inspector to make sure he has covered all the
requirements in his review.  This Checklist completely parallels the SPCC
Guidelines set forth in 40CFR112.7.  The items, in order, are:  proper contain-
ment provisions or an alternate spill contingency plan; onshore nonproduction-
related facilities; onshore oil production facilities; onshore drilling and
workover facilities; offshore oil drilling, workover and production facilities;
and facility operation items such as inspection, records, security, personnel
and training.  In the case of simple facilities and experienced inspectors,
the Checklist (Appendix C) may be omitted.

     The "SPCC Inspection Field Sheet (Appendix D) is a one-page writeup in
the field of the findings of the inspector, based on his SPCC plan review and
subsequent facility inspection.  "SPCC Inspection Summary Sheet" and the "De-
tailed SFCC Documentation" in Appendix D are for detailed documentation of the
SPCC inspection (see Section 6). The Field Sheet is EPA Form 7500-53.

SPCC Plans — Small Facilities

     Many of the inspections will involve relatively small facilities, such as:

        Bulk oil storage/distribution

        Service stations

     .  A small oil producer (three or four wells)

     .  Miscellaneous (boat marinas, industrial and agricultural users, etc.)

     These facilities are simple enough so that an inspector can review the
SFCC plan without preliminaries.  In general,  the inspector needs to follow
the order on the "SPCC Inspection Field Sheet" form (Appendix D) after he has
quickly skimmed through the plan for  a general overview.  There are 12 items
on the form, to be filled out in the field.  As a guide, instructions appear
on the reverse of the Field Sheet, EPA Form 7500-53 (App. D).  More specific
instructions appear in the following paragraphs:

     Item 1 of the form is self-explanatory and includes the trade name of the
facility.  It is important that the "location" be as precise as possible,  e.g.,
"on Hwy 35, 7.7 miles south of Sherman, Texas"; or, "on the south shore of Lake
Texoma, approximately one mile west of the Hwy 77 bridge"; or, "5208 N. Elm,
Des Moines, Iowa"; or, "Latitude 29° 44' 25" Longitude 90" 7' 35" (Lake
Salvadore Oil Field, Jefferson Parish, Louisiana)".

     Item 2 should include information about both the owner (of the facility,
of the products stored, of the equipment), and the operator (is he a lessee,
consignee, or an employee?  Is he the one "responsible" for the facility —


                                      21

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 including oil spill prevention?).  The preceding information is important for
 establishing an effective spill prevention program and for EPA Enforcement
 Division attorneys who may have to initiate legal proceedings.

           3 lists the oil materials that are being stored aboveground and bur-
 ied,  by type and size of container.   Sufficient data shall be recorded such
 that  a subsequent change in the facility will be evident at a follow-up inspec-
 tion.  Tanks that alternatively contain different liquids should be so noted in
 the SPCC plan.   Plans that specify buried bulk storage should be carefully
 checked and verified since such storage is rare.   Facilities that store large
 quantities of bulk lube oil will usually need an SPCC plan since it will usu-
 ally  be stored  aboveground.

      Item 4 should include information about  the adequacy of the plan in gen-
 eral, and specific information about  any deficiencies in the plan.    The "Com-
 ments" of Item  10 and attachments can be utilized to provide as  much detail as
 required to provide a complete critique of the plan.   The inspector should,
 after completing his review of the plan,  review his  findings with the operator
 so that he thoroughly understands the situation.   The inspector  should also
 strive to negotiate any differences and report:   the results of  the negotia-
 tion, what actions the operator will  take,  and when  he will take the actions.
 Obviously,  the  major critical area of concern in spill prevention is secondary
 or backup containment for the storage tanks and the  loading/unloading rack.
 The inspector should review the SPCC  plan with special emphasis  on  these areas.

      Item 5,  "Date of Inspection," refers to  the actual visit to the facility.

      Item 6 needs  to include the name,  registration number,  and  state of reg-
 istration of  the certifying Professional  Engineer.  This  certification infor-
 mation is  usually  found at  the front  of the SPCC  plan, but  sometimes  on the
 last  page.  If  the facility has changed,  an amendment  to  the plan may have
 been  prepared and  should be so noted  by the inspector.  Such an  amendment also
 requires  certification.

      Item 7 —  the date of  certification  needs  to include the  date  on  which
 the SPCC  plan was  certified and the dates of  any  amendments  to the  plan.  Ac-
 tually,  the date is  not required by 40CFR112  and may not exist.

      Item 9 should specify  the distance and direction  to the nearest named
 stream,  river,  lake,  bayou  which will receive runoff from the  facility.  If
 that  body of water is relatively insignificant, then the distance and direc-
 tion  to  the next significant body  of water  should also be identified.  If the
 facility runoff  goes  to  a storm drain,  the ultimate receiving water should be
named.

      Items  5. 8, 9,  10,  11,  and  12 are to be  filled in after actual field in-
spection of the  facility.

SPCC  Plans  — Large /Complex Facilities

     These  SPCC  plans would  cover  facilities such as oil/ gas production sys-
tems where  numerous wells,  tank batteries, pipelines, and pieces  of processing


                                      22

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equipment are involved.   It also might  include  large  storage  terminals  which
are located along ship channels, harbors,  etc.,  and have  barge pipelines  and
railroad loading facilities.

     Due to the complex nature of these  facilities, it  is preferable  to begin
the SPCC plan review with a thorough understanding of the total system.   For
example, an offshore oil/gas  field might include the  following geographically
different facilities, each with its own  SPCC plan:

     .  Nine Tank Batteries

        Two Compressor Platforms

     .  One Boat Fueling  Dock

        One Living Charters Facility

        One Maintenance Facility

     .  One Central Oil Storage Facility

     Operationally, these facilities all work together  as a total system, even
though the total area encompassed may be quite large.   Occasionally (because
of the complexity of the  system) a spill hazard  situation may  be overlooked  and
it is up to the inspector to  aid the operator in uncovering the problem area.
This can be best accomplished by an overall review of system drawings, maps,
etc. which can be related to  the various SPCC plans.

     Once an understanding of the entire system  is gained, the inspector and
the operator can begin to make decisions regarding:   (a) which facilities will
be reviewed, (b) where are the maximum spill hazards, (c). inspection schedules,
(d) transportation and manning arrangements for  all facility inspections.

     Using the "SPCC Inspection Checklist" (Appendix C) as a technical guide-
line, the inspector should begin reviewing the SPCC plan(s).  For a normal
compliance inspection, the review of the SFCC plan can proceed in the same
fashion as that described previously for a "small facility" and as shown on
the "SPCC Inspection Field Sheet" (Appendix D).  For facilities which are a
part of a large oil production field, the facility and  the field need to be
identified in addition to the trade name, type of facility,  and location —
for example:

     1.  Name of Facility, type of facility, and location.  XYZ Oil Co.;
         Tank Battery #3, Dog Lake Field; Terrebonne Parish. Louisiana —
         Lat. 29° 10'  50'; Long. 90° 52' 10".

FACILITY INSPECTION

     Frequently the inspector will not have had a chance to  find out whether
a facility has an SPCC plan and he will be making a surprise,  or "cold"  facil-
ity inspection in the field.   In such a case he should contact the facility
owner/operator,  identify himself as an EPA inspector,  and ask for the SPCC


                                      23

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plan for that  facility.   If no plan exists, he should first determine the oil
storage capacity at  that  facility and by comparison with the SPCC regulation
application criterion of  40CFR112.1, determine if the storage capacity is suf-
ficient to fall under the SPCC regulations.  The applicability criteria call
for a total non-buried storage of more than 1320 gallons of oil or a single
container capacity of over 660 gallons, these for aboveground storage; or a
capacity of 42,000 gallons or more of buried storage.  In all cases, there must
be a reasonable expectation that an oil spill would reach waters defined as
navigable in harmful quantities.

     If the oil capacity  of the facility is sufficient to fall under SPCC the
inspector should determine whether  there exists a reasonable spill expecta-
tion from the  layout of the facility, topographical maps, known precipitation,
measured or estimated slopes, etc.  If there is no reasonable spill expecta-
tion, a very rare situation in most parts of the country, the inspector should
terminate the  visit.  However, if a reasonable spill expectation does exist,
the inspector  should proceed, as outlined below.  When there is a valid SPCC
plan he should proceed as  described immediately following.

Facility Inspection With  Valid SPCC Plan

     After the SPCC plan  has been reviewed, it is essential that the facility
be thoroughly  inspected to determine if the SPCC plan has been properly imple-
mented, or if  the plan needs to be amended to reflect changes in the facility
since the plan was originally prepared.  Facility owner/operators must amend
SPCC plans, according to  40CFR112.5, when there is a change in facility design,
construction,  operation,  or maintenance which affects the oil spill potential.
Also, they must conduct a  review every three years to see if an amendment is
necessary.  Since the potential fines which can be levied for failure to imple-
ment SPCC plans are quite  high, it is critical that the inspector exercise the
utmost care and objectivity during this phase of the inspection process.

     To determine if the  SPCC plan has been implemented, the inspector will
need to have with him:  a  copy of the SPCC plan*, the Report of SPCC Inspec-
tion forms (Appendix D),  the SPCC Inspection Checklist (Appendix C), and any
other review notes he has  made.

     A good starting point in the facility inspection is to examine the testing
and inspection records for the facility (last item in Checklist).  This is a
very important area of implementation and may provide the inspector with valu-
able information about the general condition of the equipment,  specific equip-
ment items which are causing most of the problems, oil spill occurrences, etc.
The lack of adequate records usually implies one of the following:   the plan
did not specify record-keeping and/or testing/inspection requirements,  the
operator is not aware of  the requirements, or the operator  does not care.  The
inspector should report the situation accordingly, and try  to resolve any prob-
lems with the  operator.
* Note:  The SPCC plan should always be returned to the operator at the con-
  clusion of the inspection.  If a copy is needed by the inspector for his
  records, he shall obtain the owner's permission and pay for the reproduc-
  tion costs.

                                      24

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     Examination of the facility itself can begin either where  the  oil  enters
the facility  (at the headers, unloading area), or where the oil either  leaves
the facility  or is stored  (at the pipeline pumping unit, storage tanks,  truck
loading rack, etc.).  The  starting point of the inspection is mainly a  matter
of personal choice, but it seems to work better if the inspection progresses
in a direction which is contrary to the flow, e.g., for a production facility,
start at the  storage tanks,  then to the heater-treaters, then to the separa-
tors, etc.  Regardless of  the direction chosen, it is important to  conduct the
inspection in an orderly serial fashion, i.e., avoid a random inspection
process.

     Assuming he decides to begin (in reverse) with the storage tank area/
platform, he  should inspect all aspects of the area, to verify  that:

        The tanks are structurally sound

     .  Liquid level sensors are used (if specified)

        The secondary containment is as specified

        The drain system is satisfactory

        Drains are locked  closed (onshore only)

        Piping and supports are in good condition

        The number and size of the tanks is as specified

        There is no oil in the containment area

     For an offshore oil storage platform, the floor and curbs  of the platform
need to be checked to verify that no liquids can seep through,  and  the drain
system piping must be examined to verify that it is tight and will not leak  .
liquids.  Frequently, the equipment covers large areas and it may be necessary
to crawl around under the platform and determine if there is evidence of the
platform or drain pipes leaking.  (In Gulf area, watch for snakes — especi-
ally under platforms!)  All offshore platforms, which are subject to spilled
oil, need to have adequate drainage and containment systems to  catch spilled
oil.

    The inspection of the facility continues to the next equipment area, which
might be treaters or separators (in the case of oil production), or to loading/
unloading areas (in the case of a bulk oil plant).   Much of the same concern
about some form of containment will be focused upon this area as it was for
the tank storage area.  Wherever oil is being handled, oil spills will occur
at one time or another, and must be controlled.

     As deficiencies are uncovered during the facility inspection, they should
be made known to whomever is accompanying the inspector.   At the conclusion of
the facility  inspection, the inspector will summarize his findings and include
them in Item  8 of the SPCC Inspection Field Report.   The inspector's findings
should be openly and completely reviewed with the owner or operator of the


                                      25

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 facility  at  the conclusion of the  visit.

      If agreement  cannot  be reached  on  the  findings,  the  inspector  should ask
 the owner/operator if  he  would like  to  have his  opinions  included in  the re-
 port.  If so,  the  inspector should ask  him  to  go slow so  that his comments
 can be written down word  for word.   It  is very important  that the inspector
 not paraphrase,  substitute,  or leave out any words.   It is preferable  that the
 owner/operator observe the words as  they are being written down and initial
 his comments.   Alternately,  he may want to  send  along a note as an attachment
 to the report.

      It is well for the inspector  to realize that he  is not a ppliceman, judge,
 attorney,  etc.   He is  merely a reporter who is trained in the technical aspects
 of spill  prevention, control,  and  countermeasures.  Since his reporter's notes
 are private  and confidential,  they are  never to  be left with anyone other than
 the designated representative  of the EPA Regional Administrator or another
 authorized Government  employee.

 Facility  Inspection Without Valid  SPCC  Plan

     Occasionally,  a facility  will have an  "SPCC Plan" that is one or  two
 pages in  length, and does not  address all or any of the requirements of
 40CFR112.  Such a  document is  not  to be considered a  valid SPCC plan,  even if
 it has been  properly certified.  The inspector shall  make a note of such an
invalid plan and advise the  owner/operator  accordingly.  Also, a facility that
is required  to have an  SPCC  plan by  law may be found  to have no SPCC plan at
all.

      In such cases,  it is important  that the inspector proceed with the inter-
view and  the inspection of the facility to  complete the SPCC Inspection Field
 Sheet —  except  Items  6,  7,  and 8, which have  to do with the review of the
 SPCC plan.   Item 4  ("Is an SPCC plan available?") is  important because the in-
 spector must document  his evaluation of the owner's need to have an SPCC plan;
 and, specify why,  if the  owner believes he  does  not need to have an SPCC plan
 for his facility (e.g., — "we only  used that  tank during the oil embargo,"
 or, "we have only  been in operation  about a year — I thought I had two years
 to prepare a plan," or, "I thought that the law  only  applied to facilities that
 were  close to  a large  navigable river like  the Red River or the Mississippi
 River," etc.).   Due to the potentially  serious nature of noncompliance, it is
 imperative that the inspector  be objective,  accurate,  and comprehensive about
 his evaluation.

      Item 9  ("Name of  water body that potential  spill could enter") is obvi-
 ously a factor in  the  evaluation of  the "need  to have a plan," but due to the
 fact  that oil,  in  most areas,  does flow to  a stream eventually during  a heavy
 prolonged rain and when the ground is saturated, very few facilities will be
 exempt due to  their location from water.  However, to avoid possible future
 legal problems,  it  is  recommended  that  a careful analysis of the direction of
 flow  to the  nearest named body of  water (lake, stream, etc.) be performed.

      Item 10 ("Comments") can  include quotes from the owner/operator and shall
 be used to record  all  pertinent information.   As a minimum, it will specify


                                      26

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what, if any, spill prevention, control, and countermeasure equipment is being
utilized, and indicate when preparation and implementation of an SPCC plan may
be expected.

     After all the data have been obtained, the inspector should briefly review
40CFR112 and leave a copy with the owner/operator.  It is advisable to explain
(in a friendly, non-threatening manner) to the operator the legal ramifications,
penalties, etc. of not being in compliance.  He must be given to understand
that the law is reasonable and important and that it is in his own best inter-
est to get into compliance as soon as possible.  If he asks for help in prepar-
ing the SPCC plan or for a recommendation of a professional engineer, the in-
spector must decline on all points to avoid any conflict of interest and unpro-
fessional conduct.  He may refer him to the state authority which performs
registration of Professional Engineers, or a. professional organization which
may have a list of engineers with SPCC experience.

Facility Inspection With Impracticable Oil Containment

     Every SPCC plan must address itself to the prevention of oil spills and
the containment of oil, should a spill occur.   Normally, oil containment is
achieved by the provision of dikes, berms, sumps, catchment basins, baffles,
and the like.  Under 40CFR112.7(d) it is recognized that it is impracticable
for certain facilities, both onshore and offshore, to institute stationary
containment devices.  Instead, a "strong oil spill contingency plan following
the provisions of 40CFR109" and a "written commitment of manpower, equipment,
and materials" for control and removal of spilled oil must be provided.   When
these items appear in an SFCC plan, the inspector must first determine whether,
in his judgment, it is indeed impracticable to build stationary containment
devices, and whether the owner or operator has demonstrated such impractica-
bility.  Many offshore facilities and some onshore locations which do not per-
mit all-around containment of tanks are obvious examples.  Once the inspector
has satisfied himself that a strong contingency plan and commitment of man-
power and materials are called for, he must examine these very closely.

     In this connection, he must use the detailed criteria set forth in
40CFR109 (Appendix A) under these general headings:

     •  Definition of the authorities, responsibilities, and duties of all
        ... to be involved ... in planning or directing oil removal operations;

     •  Establishment of notification procedures for the purpose of early
        detection and timely notification of an oil discharge;

     •  Provisions to assure that full resource capability is known and  can
        be committed during an oil discharge situation;

     •  Provisions for well-defined and specific actions to be taken after
        discovery and notification of an oil discharge; and

     •  Specific and well-defined procedures to facilitate recovery of dam-
        ages and enforcement measures as provided for by state and local
        statutes and ordinances.


                                      27

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     Before the inspector approves this feature of an SPCC plan, he must
examine all the steps in such a scenario, including the availability of applic-
able equipment, materials, and supplies, both locally and regionally, adequate
to remove the maxlTnum oil discharge to be anticipated.  He must agree that
there is a "strong" oil spill contingency plan and associated written commit-
ment, sufficiently effective to contain the mairtmm spillage which could occur.
If he is not satisfied that this is the case, he should note any deficiencies
in the containment features of the SPCC plan and require that these be
strengthened.
                                      28

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                                  SECTION  5

                    AMENDMENT INSPECTIONS UNDER 40CFR112.4
PREPARATION

     When there has been a "triggering" spill as defined in 40CFR112.4(a), the
owner must file with the Regional Administrator information including an  SPCC
plan with amendments, if any, incorporating the cause of the spill(s), counter-
measures, equipment repairs or replacements, and additional preventive measures
taken or contemplated to minimize the possibility of recurrence.  The same in-
formation must also be sent by the owner/operator to the State water pollution
agency which may conduct a review and make recommendations to the Regional
Administrator.  The Regional Administrator may require that the owner/operator
amend the SFCC plan for the facility and specify the terms of the amendment.
An amendment inspection will normally be required to determine if such an amend-
ment is necessary and, if so, what operations should be addressed in the amend-
ment.  Before conducting an amendment inspection, the inspector must make him-
self thoroughly familiar with materials submitted by the owner/operator and
the State, including a description of the facility.  He is then ready to make
a review of the SPCC plan.

REVIEW OF SPCC PLAN

     The inspector shall review the original SPCC plan, the information regard-
ing the spills, and the corrective actions taken, if any, to determine if ap-'
propriate measures are being taken to eliminate the cause(s) of the spills.
He is not restricted to evaluating just the equipment which failed, but he may
examine all aspects of the SPCC plan to determine if other areas need changing.

     The technical procedure for reviewing the SPCC plan is the same as in a
compliance SPCC plan review, which is described in the preceding section.
However, since a spill has occurred, the inspector will have additional infor-
mation, furnished by the owner/operator as required by 40CFR112.4(a), includ-
ing drawings, maps, and operational data.  The SPCC plan review and the facil-
ity inspection may result in a requirement by the Regional Administrator that
the SPCC plan be amended, specifying the terms of the amendment.  The owner/
operator may ask for a reconsideration of the decision by the Regional Admin-
istrator.  He may also appeal the final decision of the Regional Administrator
to the EPA Administrator.  The owner/operator has 30 days after receiving the
final notice from the Regional Administrator or the EPA Administrator in which
to incorporate the amendment into his SPCC plan and he has an additional six
months in which to implement the amendment.
                                      29

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     After the amendment has been implemented, the inspector may visit the
facility and again review  the SPCC plan and, based upon the data previously
submitted and an examination of the facility, determine whether or not the
amendment has been implemented.

     Due to the added complexity of an amendment inspection, it is recom-
mended that his comments regarding the SPCC plan be recorded directly on the
Detailed SPCC Documentation forms (Appendix D), which may also be used for
recording the facility inspection, described in the following paragraphs.

FACILITY INSPECTION

     At the outset, it is  to be remembered that the inspector carries a
greater responsibility in  an amendment inspection than in a normal compliance
inspection.  He also has much more authority to change the spill prevention
aspects of a facility.

     The amendment inspection itself is identical to the facility compliance
inspection and the procedure will not be repeated here.  Extra care should be
given to the cause of the  original spill, and to the assessment of any cor-
rective action taken by the owner/operator.  However, he should carefully
examine all other areas of the facility.

     The conclusion of the amendment inspection is identical to that of the
compliance inspection.  It will include a review of the results of the in-
spection with the owner/operator, and a summary of the changes which need to
be made in either the SPCC plan or the facility.  After the review, the in-
spector  should thank the  owner for his hospitality, give him names/addres-
ses/ telephone numbers of people to call or write if he has any additional
questions, and take his leave.
                                     30

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                                SECTION  6

                     DOCUMENTATION OF  SPCC  INSPECTION

     The final phase of the SPCC Inspection process  is  the documentation,  to
be written on blank forms that are to  be completed for  both Compliance  In-
spections and Amendment Inspections.   They  are  in Appendix D,  "Report of
SPCC Inspection,"  as EPA Forms 7500-52 and 7500-54.  There are eight pages.
The first, Part B, is the "SPCC Inspection  Summary Sheet" and  if  the facility
is in compliance, nothing more is required.  If the  facility is not in  com-
pliance, Part C, "Detailed SFCC Documentation"  in seven items  (seven pages)
is to be filled out.  Item 1 is a facility  description,  Item 2 describes the
receiving water in case of a spill, Item 3  is for comments by  the inspector
and by the owner/operator, Item 4 is devoted to the  SPCC plan  review for all
inspections, Item 5 is for SPCC Amendment Recommendations in the  case of an .
Amendment Inspection, Item 6 is one or more field drawings, and Item 7  is one
or more photographs.


     As a guide to filling out Part B  (EPA Form 7500-52) and Part C (EPA Form
7500-54), instructions have been placed on the  face of Part B  and on the last
page (page 8, following Item. 7) of Part C.  These forms  are available at the
EPA Regions.


     The inspector should prepare the  documentation as  soon as possible after
the actual inspection, using the Inspection Checklist (Appendix C) and SPCC
Inspection Field Sheet (Appendix D), plus other notes as raw materials.
Timely preparation of the documentation will permit impressions still fresh
from the inspection to be part of the  report.   In fact,  portions of Parts B
and C may be filled out in the field.  The emphasis is  entirely on narrative
writing; all the items in the facility observation report are  intended to be
narrative in nature where quantitative data are not involved.  The documenta-
tion must be clear and complete enough to stand by itself.  It may be required
in the future when memories are dim or the principals may no longer be avail-
able to bear witness.

     This documentation format is useful for both compliance and amendment
inspections.  Item 4 of the "Detailed  SPCC Documentation" is to be devoted to
the SPCC plan review for a statement of inadequacies in  the SPCC plan or its
implementation.  Item 5 should contain SPCC plan amendment recommendations to
the Regional Administrator in the nature of engineering  changes in the spill
prevention control, and countermeasure equipment or changes in facility oper-
ation that should be added to the SPCC plan and implemented in the facility.
                                     31

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     The "Report of SPCC. Inspection," including the documentation, is kept  in
the files of the Regional Office, and may be used for enforcement purposes.

     An added documentation feature should be the use of the EPA Oil and Spe-
cial Materials Control Division's National Computerized SPCC Data Bank.
Three blank forms are used to enter the information on the computer.  These
forms appear in Appendix E, and are as follows:

     Form A - Facility identification - contains information similar to
     that in the SPCC Inspection Field Sheet

     Form E - Inspection/Enforcement Report - contains information from
     the SPCC Inspection Summary Sheet

     Form S - Spill Report - if required

     The documentation on the National SPCC Data Bank is very important be-
cause it permits later retrieval of inspection information when triggering
spills and facility changes have taken place.  It also keeps account of the
causes of spills that can be used to reinforce or amend the SPCC regulation.
                                     32

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                                  REFERENCES
American Petroleum Institute.  1976.  Suggested Procedure for Development of
Spill Prevention Control and Countermeasure Plans.  API Bulletin D 16.  Dallas,
Texas.  8 pp. plus forms.

Jaffe, James.  1979.  Oil Pollution Prevention.  The Blue Book.  Spill Control
Association of America, Southfield, Michigan.  15 pp.

Neal, E. and A. Dalsimer.  1978.  Evaluation of the Oil Spill Enforcement Pro-
gram (no report number).  Chi Associates, Inc., Arlington, Virginia.  69 pp.
plus appendices.

Pace Company Consultants and Engineers, Inc.  1975.  Oil Spill Prevention, Con-
trol and Countermeasure Plan Review.  Department of Environmental Science and
Engineering, Rice University, Houston, Texas.  389 pp. plus appendices.

Ritchie, J.E., Jr., F.J. Allen, Jr., R.M. Feltes, R.Q. Foote, Q.A. Shortt,
E.B. Bell, and J. Winn.  1973.  Petroleum Systems Reliability Analysis: A
Program for Prevention of Oil Spills Using an Engineering Approach to a Study
of Offshore and Onshore Crude Oil Petroleum Systems,  2 vols.  EPA-R2-73-280a
and b.  Office of Research and Monitoring, U.S. Environmental Protection
Agency, Washington, D.C.

Trentacoste, N.P., G.R. Bierman, and James Cunningham.  1980.  SPCC Practices
at Small Petroleum Facilities.  EPA-600/7-80-004.  Industrial Environmental
Research Laboratory, U.S. Environmental Protection Agency, Cincinnati, Ohio.
                                      33

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                                APPENDIX  A

                ENVIRONMENTAL PROTECTION AGENCY REGULATIONS
     The following pages contain reproductions from the Code of Federal Regula-
tions (CFR), CFR Title 40 - Protection of the Environment, Parts 109, 110, 112,
and 114.

       Part 109 is titled "Criteria for State, Local, and Regional Oil Removal
Contingency Plans.  Part 110 is "Discharge of Oil," Part 112 is "Oil Pollution
Prevention: Nontransportation-Related Onshore and Offshore Facilities, and
Part 114 is "Civil Penalties for Violation of Oil Pollution Prevention Regula-
tions: Nontransportation-Related Onshore and Offshore Facilities.

      40CFR112 was last amended March 26, 1976 (see p. 39).  A proposed modifi-
cation was published May 20, 1980, in the Federal Register, Vol. 45, No. 99,
pp. 33814-33826.  The comment period expired July 21, 1980, but the new regu-
lation has not yet been promulgated.  When a new 40CFR112 takes effect, the
holder of this report is requested to substitute the new regulation for the one
printed here.
                                      34

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                                                                                                       131:0701
                      ENVIRONMENTAL PROTECTION  AGENCY REGULATIONS
  ON  CRITERIA  FOR  STATE,  LOCAL AND  REGIONAL  OIL REMOVAL  CONTINGENCY PLANS

                               (40 CFR 109; 36 FR 22485, November 25, 1971)
         PART 109 - CRITERIA FOR STATE,
             LOCAL AND REGIONAL OIL
          REMOVAL CONTINGENCY PLANS
Sec.
109.1 Applicability.
1092 Definitions.
109 J Purpose and scope.
109.4 Relationship to Federal response actions.
109.5 Development and implementation criteria for State,
      local and regional oil removal contingency plans.
109.6 Coordination.
  AUTHORITY:  The provisions of this Part  109 issued
under  sec.  110X1XB), '84  Stat.  96,   33  U.S.C.
1161(JX1XB).

§109.1  Applicability.
  The criteria in this part are provided to assist State, local
and  regional  agencies  in  the development of oil removal
contingency plans for  the inland navigable waters of the
United States and all  areas other than the high seas, coastal
and contiguous zone waters,  coastal and Great Lakes ports
and harbors and such other  areas as may be agreed  upon
between  the  Environmental  Protection  Agency  and the
Department  of Transportation  in accordance with section
ll(jXl)(B) of the Federal Act. Executive Order No. 11548
dated July 20, 1970 (35 F.R. 11677) and section 306.2 of
the National  Oil  and  Hazardous Materials  Pollution  Con-
tingency Plan (35 F.R. 8511).

§109.2  Definitions.
  As used  in these guidelines, the following terms shall
have the meaning indicated below:
  (a) "Oil"  means oil  of  any  kind  or  in any  form,
including, but not limited to.  petroleum.'fuel oil, sludge, oil
refuse, and oil mixed  with wastes other than dredged spoil.
  (b) "Discharge" includes,  but is not limited  to. any
spilling,  leaking, pumping, pouring,  emitting,  emptying, or
dumping.
  (c) "Remove" or "removal" refers to the removal of the
oil  from  the  water and shorelines  or the  taking of such
other actions as may be necessary to minimize or mitigate
damage to the public health or welfare, including, but not
limited to, fish, shellfish, wildlife, and public and private
property, shorelines, and beaches.
  (d) "Major  disaster" means -any  hurricane, tornado,
storm, flood, high water, wind-driven water, tidal wave,
earthquake, drought, fire, or  other catastrophe in any part
of the United States which, in the determination of the
President, is or  threatens to  become of sufficient severity
and magnitude to warrant disaster assistance by the Federal
Government  to  supplement the efforts and available  re-
sources of States and local governments and relief organiza-
tions  in alleviating the damage,  loss, hardship, or suffering
caused thereby.
   (e) "United States" means  the  States,  the District  of
Columbia,  the Commonwealth of Puerto Rico, the Canal
Zone, Guam. American Samoa, the Virgin Islands, and the
Trust Territory of the Pacific Islands.
   (0 "Federal  Act"  means the Federal Water  Pollution
Control Act, as amended, 33 U.S.C. 1151, et seq.

§109.3 Purpose  and scope.
   The guidelines in this part establish minimum criteria for
the development and implementation of State, local, and
regional contingency plans by State and local governments
in consultation  with  private interests to  insure timely,
efficient,  coordinated and  effective  action  to minimize
damage resulting from oil  discharges.  Such plans will  be
directed toward  the protection  of the  public health  or
welfare of the United States, including, but not limited to,
fish, shellfish, wildlife, and public and  private property,
shorelines, and beaches. The development and implementa-
tion of such plans shall be consistent with the National Oil
and Hazardous Materials Pollution Contingency Plan. State,
local  and   regional  oil  removal  contingency  plans shall
provide for the coordination of the total response to an oil
discharge  so  that contingency organizations established
thereunder can  function  independently, in conjunction
with each  other, or in conjunction with the National and
Regional  Response Teams established by the National Oil
and Hazardous Materials Pollution Contingency Plan.

§109.4 Relationship to Federal response actions.
   The National  Oil and  Hazardous  Materials Pollution
Contingency  Plan  provides that  the  Federal  on-scene
commander  shall investigate all  reported  spills.  If such
investigation shows that  appropriate action is being taken
by either the  discharger or non-federal entities, the Federal
on-scene commander shall monitor and provide advice  or
assistance,  as required.  If  appropriate  containment  or
cleanup  action is not being taken by the discharger  or
non-Federal entities, the Federal on-scene commander will
take  control  of  the response activity  in accordance with
section 1 l(cXl)of the Federal Act.

§109.5 Development  and  implementation  criteria  for
  State, -local and regional oil removal contingency plans.
  Criteria  for the development  and  implementation of
State, local and regional oil  removal contingency plans are:
                               Copyright C 1972 by Th« Bureau of National Affairs, Inc.
                                                   35

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131:0702
                            FEDERAL  REGULATIONS
   (a)  Definition  of the  authorities,  responsibilities and
duties of all persons, organizations or agencies which are to
be involved or could be involved in planning or directing oil
removal  operations, with  particular care to clearly define
the authorities, responsibilities and duties of State and local
governmental  agencies to avoid unnecessary duplication  of
contingency planning activities and to minimize the poten-
tial for conflict and confusion that could be generated in an
emergency situation as a result of such duplications.
   (b)  Establishment of notification procedures  for the
purpose  of early detection and timely notification of an oil
discharge including:
   (1)  The  identification  of critical  water  use  areas  to
facilitate the reporting of and response to oil discharges.
   (2)  A current  list  of  names,  telephone  numbers and
addresses of the responsible persons and alternates on call
to receive  notification of an  oil discharge as well as the
names, telephone numbers and addresses of  the organiza-
tions and agencies to  be notified when an oil discharge is
discovered.
   (3)  Provisions for access to a  reliable communications
system for timely  notification  of an  oil discharge  and
incorporation in the communications system of the capa-
bility for interconnection with the communications systems
established  under related  oil  removal contingency plans,
particularly State and National plans.
   (4)  An established, prearranged procedure for requesting
assistance during a  major disaster or when  the situation
exceeds  the   response  capability of  the State,  local or
regional authority.
   (c)  Provisions to  assure that full resource capability  is
known and  can be committed  during  an  oil  discharge
situation including:
   (I)  The  identification and inventory of applicable equip-
ment,  materials  and  supplies which are available locally and
regionally.
   (2)  An estimate of the equipment, materials and supplies
which  would  be  required to remove  the maximum  oil
discharge to be anticipated.
   (3)  Development of  agreements and  arrangements  in
advance  of an oil  discharge for the acquisition of equip-
ment,  materials and supplies to be  used  in responding  to
such a discharge.
   (d)  Provisions  for well defined and specific actions to be
taken  after discovery and notification of an oil discharge
including:
   (1)  Specification of an oil discharge response operating
team consisting of trained, prepared and available operating
personnel.
   (2)  Predesignation  of a properly  qualified oil discharge
response coordinator who is charged with  the responsibility
and  delegated  commensurate  authority  for  directing and
coordinating response operations and who knows how  to
request assistance from  Federal authorities operating under
existing national and regional contingency  plans.
   (3)  A preplanned location for an oil discharge response
operations  center and a reliable communications system for
directing the coordinated overall response operations.
   (4)  Provisions  for  varying  degrees of response  effort
depending on the severity of the oil discharge.
   (5)  Specification of the order of priority in which the
various water uses are to be prptected where more than one
water  use may be adversely affected as a result of an oil
discharge  and  where  response operations  may  not  be
adequate to protect all uses.
   (e) Specific  and well  defined procedures  to facilitate
recovery  of damages and enforcement measures as provided
for by  State and local statutes and ordinances.

§109.6 Coordination.
   For  the purposes of coordination, the contingency plans
of State  and local  governments should be developed  and
implemented in consultation with private  interests. A copy
of any  oil removal contingency plan developed by State and
local governments should be forwarded to the  Council on
Environmental  Quality  upon* request  to  facilitate  the
coordination of these contingency plans with the National
Oil and Hazardous Materials Pollution Contingency Plan.
                                               Environment R«port«r

                                                     36

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                                                                                                                S-330
                                                                                                            131:0901
                         ENVIRONMENTAL PROTECTION AGENCY REGULATIONS
                                             ON  DISCHARGE OF OIL


                                (40 CFR 110; 41 FR 49810,  November 11,  1976)
 Trtlaao  Protection of the Environment

    CHAPTER I — ENVIRONMENTAL
        PROTECTION AGENCY
    PART 110— DISCHARGE OF OIL

See.
110.1  Definitions.
UOJ  AppUcaDlUty.
110.3  Discharge Into navigable waters harm-
        ful.
110.4  Discharge Into conttguoua zone harm-
        ful.
110 J  Diaeharge prohibited.
1104  Exception for veeael anginas,
110.7  Dispersants.
1103  Demonstration project*.
110.9  Hotioe.
  Atrnsoarrr: Sees. 311(b>  (3) and (4) and
SOI (a) ot the Federal Water Pollution Con-
trol Act Amendments of 1973 (33 U.S£. 1391
ttaeq.).

§ 110.1   Definition*.

  As  used  in this part, the following
terms shall have the meaning Indicated
below:
  (a) "Oil" means oil ox any kind or In
any form. fr»*1"'*t'"g. but not limited to.
petroleum, fuel oiL sludge, oil refuse, and
oil mixed with wastes other than dredged
spoil:
  (b) "Discharge" includes, but is not
limited  to,  "iy spilling,  ****r'T>gj pump-
ing.   pouring., emitting,  emptying  or
dumping;
  (c) "Vessel'' means every description
of watereraft or other artificial contriv-
ance used, or capable of being used, as a
means of transportatioa on water other
than a public vessel:
  (d) "Public vessel"  means a vessel
owned or bareboat chartered and oper-
ated by the United States, or by a State
or political subdivision thereof, or by a
foreign  nation, except when such vessel
is engaged in commerce;
  (e) "United States" means the States.
the District of Columbia, the  f-f^rnm^
wealth of Puerto Rico, the Canal Zone.
Ouam. A™****" Samoa, the Virgin Is-
lands. and the Trust Territory of the Pa-
cific T**"****!
  (f)  "Person" includes an  individual.
firm,  corporation,  association,  end a
  (g) "Contiguous zone- "•«"« the en-
tire zone established or to be established
by the United States under article 24 of
the Convention on the Territorial Sea
and the Contiguous Zone;
  (h) "Onshore facility" means any fa-
cility (including, but not Hmttod to motor
vehicles «™«< rolling stock) of any
located in. on. or under, any *""J within
the United States other *fr«" submerged
land:  >
  U>  "Offshore faculty**  means  any
facility of any kind located in. on,  or
under, any of the navigable waters of the
United States other **»«» a vessel or pub-
lic vessel:
  (J)  "Applicable  water quality  stand-
ards" means State -water quality stand-
ards adopted by the State and approved
by EPA pursuant  to section 303 of the
Federal Act or promulgated by EPA pur-
suant to that section:
  ck)  "Federal Act" means the Federal
Water  Pollution   Control   Act,   as
amended. 33 U.S.C. 1251. etseq;
  (D  "Sheen" means an iridescent ap-
pearance on the surface of water;
  (m>  "Sludge" means an aggregate  of
oil or oil  and other mntftr of any kind
in any form other  than  dredged spoil
having a combined specific gravity equiv-
alent to or greater than -water:
§ 110.2  Applicability.
  The regulations  of this part apply  to
the discharge of oil into or upon the wa-
ters of the United States, adjoining
shorelines or into or upon the waters  of
the contiguous zone, prohibited by sec-
tion 311 (b)  (3)  of  the Federal  Act.
§ 110.3  Discharge into navigable water*
     harmful.
  For purposes of  section 311(b)  of the
Federal Act. discharges of  such quanti-
ties of oil  into or upon the navigable wa-
ters of the  United States  or adjoining
shorelines determined to be harmful  to
the public health or welfare of the United
States, at all times and locations and
mvi*r  all  circumstances and  conditions.
except as provided in i 110.6 of this part.
include discharges  which:
  (a)  Violate applicable water quality
standards, or
  (b) Cause a «i«« or sheen upon or dis-
coloration of the surface of the water  or
adjoining shorelines or cause a sludge  or
emulsion  to be deposited  beneath the
surface of the water or upon adjoining
§ 110.4  Discharge into contiguous zone
     harmful*
  For purposes of section 311 (b)  of the
Federal Act. discharges of such quantities
of oil into or upon the waters of the con-
tiguous OTHP determined to be harmful
to 'the public  health  or welfare  of the
 United States, at all times and locations
 and under  all circumstances and con-
 ditions, except as provided in . 110.6. in-
 clude discharges which:
   (a)  Violate applicable water quality
 standards  in navigable waters of  th»
 United States, or
   (b)  Cause a film or sheen upon or dis-
 coloration of the surface of the water or
 adjoining shorelines or cause a sludge
 or emulsion to be deposited beneath  the
 surface of the water or upon adjoining
 shorelines.
 §  110.5  Discharge prohibited.
   As provided in section 311 of the
 Federal Act. no person shall discharge or
 cause  or permit to  be discharged  into
 or upon the navigable waters of  the
 United States, adjoining shorelines,  or
 into or upon the waters of the contiguous
 zone any oil. in harmful quantities  as
 determined  In 55110.3  and 110.4 except
 'as the same may be permitted in  the
 contiguous zone under Article IV of  the
 International Convention for the Pre-
 vention of Pollution of the Sea by Oil.
 1954. as amended.

 §110.6  Exception for vessel engines.
   For  purposes of section 311 (b) of the
 Federal Act. discharges of  oil  from a
 properly functioning vessel engine are
 not deemed to be harmful; but such oil
 accumulated in a vessel's bilges «»n*n not
 be so exempt.

 §  110.7  DUpenanta.
   Addition of dispersants or  emulsiners
 to oil to be discharged which would cir-
 cumvent the provisions of this part is
 prohibited.
 §  110.8  Demonstration project*.
   Notwithstanding any  other provisions
 of this part, the Administrator of the
 Environmental Protection Agency may
 permit the discharge of oil into or upon
the navigable waters of the United States.
 adjoining shorelines, or into or upon the
 waters of the contiguous zone, in connec-
 tion with research, demonstration proj-
 ects, or studies relating to the prevention.
 control, or abatement of oil pollution.
 § 110.9  Notice.
  Any  person in charge of any vessel or
onshore or offshore facility shall, as soon
as he has knowledge of any discharge of
oil from such vessel or facility in viola-
tion of J 110.5. immediately  notify the
appropriate  agency of such discharge in
   12-24-76
                                 Copyright 
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 131:0902                                                                                    FEDERAL LAWS


accordance with sucn procedures aa the  scribe. The procedures for such notice an  33 C7R Part 153. Subpart B, 41FR12S28
Secretary of  Transportation may pre-  sec forth In U.S. Coast Guard regulations,  ec seq. (March 25.1976).
                                              Environment Reporter                    [S*c. 11 (LSI

                                                 38

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                                                                                                                S-314
                                                                                                            131:0931
                         ENVIRONMENTAL PROTECTION AGENCY  REGULATIONS
                                       ON OIL POLLUTION PREVENTION

                (40  CFR  112:  38  FR  34164,  December  11,  1973;  Amended by  39  FR 31602,
           August 29,  1974; 41 FR 12657, March 26, 1976)
PART 112—OIL POLLUTION PREVENTION
  Non-transportation Related Onshore and
           Offshore Facilities
  AirmomrrT: Sees. 311 (J) (1) (C). 311U) (2).
S01(a). Federal Water Pollution Control Act
(See. 2. Pub. U 93-MO. 86 Stas. 816 et sec..
(33 T7J3.C. 1291 et «eq.)): See. 4. Pub. L.
93-900. 88 Stat. 887: 5 U.S.C. Bear?. Flan of
1970 No. 3 (1870). 33 FS 1B623. 3 CPR 1966-
1970 Comp^ E.O. 11739. 38 PS 21243. 3 CFB.

§ 112.1  General applicability.
   (a)  This part establishes procedures.
methods and  equipment  and, other re-
quirements for equipment to prevent the
discharge of  oil  from non-transporta-
tion-related onshore and offshore facili-
ties Into or upon the navigable waters of
the United States or adjoining shore-
lines.
   (b)  Except  as provided In paragraph
(d) of this section, this part applies to
owners or operators of non-transporta-
tion-related onshore and offshore facili-
ties engaged in drilling, producing, gath-
ering,   staring,   processing,   refining.
transferring, distributing or  «  As provided in see. 313  (88 Stat.
875) departments, agencies, and instru-
mentalities of the Federal government
are subject to these  regulations to the
same extent as any person, except for the
provisions of i 112.8.
   (d)  This part does not apply to:
   (1)  Facilities, equipment or operations
which are not subject to the jurisdiction
of the Environmental Protection Agency.
as follows:
   (A)  onshore and  offshore facilities,
which, due to their location, could not
'reasonably be  expected to discharge oil
into, or  upon  the navigable waters  of
the1 United States or adjoining shore-
Tines. This determination shall be based
solely  upon a consideration of the geo-
graphical, locattonal aspects of the facil-
ity  (such as  proximity to  navigable
waters or adjoining shorelines, land con-
tour,  drainage, etc.)  and shall exclude
consideration of manma/ie features such
as dikes, equipment or other structures
which may serve to restrain, hinder, con-;
tain or otherwise  prevent a discharge o»
oil from reaching navigable waters of the
United States or adjoining • shorelines:
         (B) equipment or operations of vessels
       or transportation-related  onshore and
       offshore facilities' which are subject to
       authority and control of the Department
       of Transportation,  as .defined  in  the
       Memorandum of Understanding between
       the Secretary of Transportation and the
       Administrator of the Environmental Pro-
       tection Agency, dated November 24,1971.
       36 FR 24000.
         (2)   those facilities which,  although
       otherwise subject to  the jurisdiction of
       the Environmental Protection Agency,
       meet both of the following requirements:
         (A)  the  underground buried  storage
       capacity of the facility is 42.000  gallons
       or less of oil. and
         (B) the storage capacity, which is not
       buried, .of the  facility is  1.320  gallons
       or less of oil, provided no single container
       has a capacity  in excess of 660 gallons.
            [41 FR 12657, March 26, 1976]
         (e> This part provides for the prepara-
       tion and implementation  of Spill Pre-
       vention Control  and  Countermeasure
       Plans  prepared  in   accordance  with
       9112.7. designed to complement existing
       laws, regulations, rules, standards, poli-
       cies and procedures pertaining to safety
       standards, fire prevention  and  pollution
       prevention rules, so as to form a compre-
       hensive balanced Federal/State spin pre-
       vention program, to mtn
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 131:0932
                                                FEDERAL REGULATIONS
ance used, or capable of  bring used as
a  means  at transportation on  water.
other than a public vesseL

§ 112^  Remuremena  for preparation
    and implementation of Spill Preven-
    tion  Control  and  Councermeaiare
    Piano.
   'a)  Owners or operators of onshore
 and offshore facilities in operation on or
 before the effective date of this part that
 have discharged or, due to their loca-
 tion, could  reasonably  be expected to
 discharge oil In" harmful quantities, as
 defined in 40 CFR Part 110. into or upon
 the navigable waters of the United States
 or adjoining shorelines, shall prepare a
 Spin Prevention Control and Counter-
 measure   Plan   (hereinafter   "SPCC
 Plan"), in writing and in accordance with
 section 112.T. Except as provided for in
 paragraph  of this section, such SPCC
 Plan shall be prepared within six months
 after the effective date of this part and
 shall be  fully  implemented as soon  as
 possible, but not later than one rear after
 the effective date of this part.
       [41 FR 12657, March 26, 1976]
   (b)  Owners or operators of  onshore
 and offshore facilities that become op-
 erational after the effective date of »I<-T
 part, and that have discharged or could
 reasonably  be expected to discharge oil
 in harmful quantities, as defined in  40
 CFR Part 110, into or upon the navigable
 waters of the United States or adjoining
 shorelines, shall prepare an SPCC Plan
 in accordance with  5112,7.  Except  as
 provided for in paragraph (f) of this sec-
 tion, such SPCC Plan «hnii be prepared
 within six months after  the  date such
facility begins  operations  and shall be
fully  implemented  as soon as possible.
 but not later <*«•» one year after such
 facility begins operations.
   (c) Owners  or operators of onshore
*n«< offshore mobile or portable facilities,
such as onshore drilling or workover rigs.
 barge mounted offshore drilling or work-
over rigs, and portable fueling facilities
shall  prepare and implement an  SPCC
Plan as required by paragraphs (a), (b)
and   of this section. The  owners  or
operators  of such faculty need not pre-
pare a new  SPCC  Plan each time the
facility is  moved to a new site. The SPCC
Plan may be a general plan, prepared in
accordance with section 112.7, using good
engineering practice. When the mobile or
portable facility is moved. It must be lo-
cated and installed  using the spill pre-
vention practices outlined in  the  SPCC
Plan for the facility. No moot: or port-
able facility subject  to this regulation
shall operate unless the SPCC Plan has
been implemented. Ths SPCC Plan "shall
only apply while the facility is in a IseJ
 • non-transportation)  operating mode.
    [41 FR 12657. March 26,  1976]
   (d)  No  SPCC Plan shall be effective
to satisfy  the requirements of this part
nniaw it has been reviewed by a Regis-
tered  Professional Engineer and certi-
fied .to by such Professional  Engineer.
By m^rn of this certification the en-
gineer, having examined the facility and
being familiar with the provisions of this
part, shall attest that the SPCC Plan has
been prepared in accordance with good
 engineering practices. Such certification
 shall In no way relieve the owner or op-
 erator of an onshore or offshore facility
 of his duty to prepare and fully imple-
 ment  such Plan  in  accordance  with
 3112.7, as  required by paragraphs (a).
 (b) and (c) of this section.

  (e)  Owners or operators of a facility
for which an SPCC Plan is required pur-
suant to paragraphs (a),  (b)  or  (c) of
this  section shall maintain a complete
copy of the Plan at such  facility if the
facility is normally attended at least 3
hours per day, or at the  nearest field
office if the facility is not so attended.
and  «*"*ii pig>a such Plan available to
the Regional Administrator for on-site
review during  normal working hours.
  (f) Extensions of time.

  (1) The Regional Administrator may
authorize an extension of  time for the
preparation and full implementation of
an SPCC Plan beyond the time permitted
for the preparation and implementation
of an SPCC'Plan pursuant to paragraphs
 (a),  (b)  or (c> of this section where he
finds that  the owner or operator of  a
facility subject to  paragraphs  (a), (b)
or (c) of this section cannot fully com-
ply with the requirements of this part
as a result  of either  nonavailability of
qualified personnel, or  delays in con-
struction or equipment delivery beyond
the control and without the fault of such
owner  or operator or their  respective
agents or employees.
  (2) Any owner or operator seeking an
extension of time pursuant to paragraph
 (f) (1) of this section may submit a letter
of request to the Regional Administrator.
Such letter shall include:
  (i) A complete copy of the SPCC Plan,
if completed:
  (il> A full explanation of the cause for
any such delay and the specific aspects
of the SPCC Plan affected by the delay;

  (ill)  A full discussion of actions being
taken or contemplated to minimize or
mitigate such delay;

  (iv)  A proposed time schedule for the
implementation of any corrective actions
being taken or contemplated, including
interim dates for completion  of tests or
studies, installation and operation of any
necessary equipment or other preventive
measures.
In addition, such owner or operator may
present additional oral or  written state-
ments in support of his letter of request.

  (3) The  submission of a letter of re-
quest for extension of Mm« pursuant to
paragraph  (f) (2) of this section shall In
no way  relieve the owner or  operator
from his obligation to comply with the
requirements of 3 112.3 (a), (b) or (c).
Where an extension of time is  authorized
by the Regional Administrator for par-
ticular equipment  or  other specific as-
pects of  the SPCC Plan, such extension
shall in no way affect the owner's or op-
erator's obligation to comply with the
requirements of 3112.3  (a), (b) or (c)
with respect to other equipment or other
specific aspects of the SPCC Plan for
which an extension of time has not been
expressly authorized.

         Environment Reporter

                40
 § 112.4  Amendment of SPCC Plan* by
     Regional Administrator.
  (a) Notwithstanding compliance with
 § 112.3,  whenever a faculty subject  to
 3 112.3 (a) , (b)  or (c) has: Discharged
 more than 1.000 U.S. gallons of oil into
 or  upon  the navigable  waters of the
 United States or adjoining shorelines in
 a single spill event, or discharged oil  in
 harmful quantities, as defined in 40 CFR
 Part  110. into  or upon  the  navigable
 waters of the United States or adjoining
 shorelines in two spill events, importable
 under section 311 (b) (.5) of the FWFCA.
 occurring within any twelve month pe-
 riod.  the owner  or operator of such fa-
 cility «rmn submit to t*r> Regional Ad-
 ministrator, within 60 days from the fc*m*
 such facility becomes subject to this sec-
 tion. the following:
  (1) Name of the facility;
  (2) Name(s) of the owner or operator
 of the facility;
  (3) Location of the facility:
  (4) Date and  year of initial faculty
 operation;
  (5) ttfa-Trfrnmn storage or fraTTfT^g ca—
 paclty of the facility "Bd  normal daily
   (6) Description of the facility, includ-
 ing maps. Sow diagrams, «"d topograph-
 ical maps:
   (7) A complete copy of the SPCC Plan
 with any amendments;
   (8) The cause(s)  of such spill, includ-
 ing a failure analysis of system or sub-
 system in which the failure occurred;
   (9) The  corrective  actions  and/or
 countermeasures taken.  Including  an
 adequate  description of equipment  re-
 pairs and/or replacements;
   (10)  Additional preventive  measures
 taken or contemplated  to minimize  the
 possibility of recurrence;
   (11)  Such other Information as  the
 Regional Administrator may reasonably
 require  pertinent  to  the  Plan  or spill
 event.
   (b) Section 112.4 shall not apply until
 the expiration of the time permitted for
 the preparation and implementation of
 an SPCC  Plan pursuant to 5 112.3  (a),
 (b),(c)  and(f).
   (c) A complete copy of all information
 provided to the Regional Administrator
 pursuant to paragraph (a) of this section
 shall be sent at the  same time to  the
 State agency in charge of water pollu-
 tion control activities  in and for  the
 State in which the faculty is located.
 Upon receipt of such information such
 State agency may conduct a review and
 make recommendations to the Regional
 Administrator as to further procedures,
 methods, equipment and other require-
 ments for equipment necessary to pre-
 vent and  to contain discharges of  oil
from such facility.
   (d) After review of the SPCC Plan for
 a  facility  subject  to  paragraph (a) of
 this section, together with all  other  in-
 formation submitted  by the owner or
 operator of such  facility, and  by  the
State agency under paragraph (c)  of
 this  section, the Regional Administra-
tor may require the owner or  operator
 of such  facility to amend the SPCC Plan
 if  he fl"d« that the Plan does not meet
the requirements of this part or that
tee amendment of the Plan  is neces-
                                                                                      [S«c.

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  OIL POLLUTION PREVENTION
                                                                       S-314
                                                                   131:0933
 sary to prevent and to contain discharges
 of oil from such facility.
 .   (e)  When the Regional  Administra-
 tor proposes to require an.amendment to
 *>*• SPCC Plan, he «hail yMfy *>!• fa-
 cility operator by certified mail addressed
 to, or by personal delivery to, the faculty
 owner or operator, that he proposes to
 require an  Plan, and
 shaii specify *n* terms of such amend-
 ment.  If the facility  owner  or opera-
 tor is a corporation, a copy  of  such
 notice «ha-fl also be mailed to the regis-
 tered agent, if any, of such corporation
 in the State where such facility is lo-
 cated.  Within  30  days from  receipt of
 such notice, the facility owner or opera-
 tor  may submit  written information.
 views,  and arguments on tfr*» aTTM^riTn^m,
 After  considering all relevant material
 presented,  the Regional Administrator
 shall notify the facility owner or opera-
 tor of  any **n+nfirn**it required or shall
 rescind the notice. The  amendment re-
 quired by  the Regional Administrator
 -«haJi  become part  of the Plan 30 days
 after such  notice,  unless the  Regional
 Administrator, for  good  cause,   shall
 specify another effective date. The owner
 or operator of the facility shall imple-
 ment tfr* afjfl»firfTfl»nt of t^<* Plan as soon
 as  possible, but  not  later  than six
 months  after ^ft tLmm^f^mafnt becomes
 part of the Plan. imi«« the Regional Ad-
 ministrator specifies another date.
     An ostner or operator may appeal
 a decision made by the Regional Admin-
 istrator  requiring an amendment to an
 SPCC  Plan. The-appeal shall be made to
 the Administrator of the United States
 Environmental Protection . Agency  and
 must be made in writing within 30 days
 of receipt of the notice from the-Regional
 Administrator requiring the amendment.
 A complete copy of tbe  appeal must be
 sent to the Regional Administrator at the
 time tbe appeal is made. The appeal shall
 contain a clear and concise statement of
 the issues and points of fact in tbe case.
 It may also contain additional informa-
 tion from the owner or operator, or from
 any other person. The Administrator or
 his designee may request additional in-
 formation from tbe owner  or  operator.
 or from  any other person. The Adminis-
 trator  or his designee shall render a de-
 cision  within 60 days of receiving tbe ap-
 peal and shall notify the owner or oper-
 ator of his decision.
      [41  FR 12657, March 26, 1976]


• § 112^  Amendment -of Spill Prevention
     Control and Coontenneasure Plan* by
     owners or operators.
   (a)  Owners or operators  of  faculties
 subject to } 112J (a). (b)  or (c) shaD.
 amend the SPCC Plan for such facility
 in accordance  with  5112.7  whenever
 there is a change in facility "*" be effective  to satisfy the require-
                                         ments  of this section ««i»«« it has been
                                         certified by a Professional Engineer  in
                                         accordance with  9112.3 (d).

                                         § 112.6 Gvil penalties for violation of
                                              Oil Pollution Prevention Regulation*.
                                           Owners or  operators ot facilities sub-
                                         ject to  1112.3(a), (b)  or (c) who violate.
                                         the requirements  of  this Part  112 by
                                         failing  -r refusing to comply with any of
                                         the  provisions of  3112-.3.  ! 112.4  or
                                         5112 J «n».n be liable for a civil penalty of
                                         not more than $3,000  for each day such
                                         violation ^TI**""**  ClvH penalties «*">n
                                         be imposed in  accordance with proce-
                                         dures set out in  Part 114 of this sub-
                                         chapter O.
                                         § 112.7  Guidelines 'for the preparation
                                              and implementation of a Spill Pre-
                                              vention Control and Coanlermeasnre
                                              Plan.
                                           The SPCC Plan shall be a carefully
                                         thought-out plan, prepared in accordance
                                         with good  engineering  practices, and
                                         which has the full approval of manage-
                                         ment at a level with authority to com-
                                         mit the necessary  resources. If the plan
                                         «*it«  for additional  fn^Wtlr?  or  proce-
                                         dures. methods, or  equipment not  yet
                                         fully operational, these items  should be
                                         discussed in separate paragraphs, and
                                         the  details  of  installation  
-------
  131:0934
                                                 FEDERAL REGULATIONS
the event of an uncontrolled spin, return
the oil to toe plant.
 •  (7> Where drainage waters are treated
in  more than  one treatment unit, nat-
ural hydraulic Sow  should be used. If
pump   transfer  Is  needed.' two "lift"
pumps  should  be provided, and at least
one of the pumps should be permanently
installed  when such treatment  is con-
tinuous. In any  event,  whatever tech-
niques are used facility drainage systems
should  be adequately engineered to pre-
vent oil from reaching navigable  waters
In  the  event  of equipment failure  or
human error at the facility.
  (2) Bulk storage tanks (onshore); (ex-
cluding  production facilities).  (1)   No
tank should be used for  the storage of
oil  '^pigg* its material *n>*  construction
are compatible with the  material  stored
and conditions of storage such as pres-
sure «"d temperature, etc.
  (11) All bulk storage tank installations
should be constructed so  that a second-
ary means of containment Is provided for
the entire contents of the largest single
tank plus  sufficient freeboard to allow
for precipitation. Diked areas should be
sufficiently impervious to  contain spilled
oil. Dikes, containment curbs, and  pita
are commonly employed for this purpose.
but they may not always be appropriate.
An alternative  system could consist of a
complete  drainage trench enclosure ar-
ranged  so that a spill could terminate
and be safely  confined  in an in-plant
catchment basin or holding pond.
  (ill)  Drainage  of rainwacer  from the
diked area into a storm drain or an efflu-
ent discharge that empties into an open
water course, lake, or pond, and bypass-
ing the in-plant  treatment system may
be acceptable if:
  (A) The  bypass  valve  is  normally
sealed closed.
  (B) Inspection of  the run-off rain
water  ensures  compliance with  appli-
cable water  quality standards and  will
not cause a harmful discharge as denned
in 40 CFR 110.
   AH aboveground valves and pipe-
 lines should be subjected to regular ex-
 aminations  by operating personnel at
 which  time the  general condition of
 items, such as flange joints, expansion
 joints,  valve glands and bodies, catch
 pans, pipeline supports, locking of valves.
 and metal surfaces should be assessed. In
 addition, periodic pressure testing may
 be warranted for piping in areas where
 facility drainage is  such that a  failure
 might lead to a spill event.
   (v) Vehicular traffic granted entry into
 the facility should  be warned verbally
 or by appropriate signs to be sure that
 the vehicle, because of its size, will not
 endanger above ground piping.
   (4) Facility tank car and tank truck
 loading/unloading rack  (onshore).  (1)
 Tank car and tank truck loading/un-
 loading procedures should meet the min-
 imum requirements ""1 regulation estab-
 lished by the Department of Transpor-
 tation
   (11) Where  rack  area drainage does
 not flow into a catchment basin or treat-
 ment facility designed to handle spills, a
 quick drainage system should be used for
 tank truck  loading and unloading areas.
 The  containment system should  be de-
 signed to hold at least maximum capacity
 of any single compartment of a tank car
 or tank truck loaded or unloaded In the
 plant.
   (ill) An interlocked warning light or
 physical  barrier  system,  or  warning
 signs, should be provided in loading/un-
 loading areas to prevent vehicular de-
 parture  before  complete disconnect of
 flexible or fixed transfer  'in»«.
   (iv> Prior to filling and departure of
 any tank car or tank truck, the lower-
most  drain  and all  outlets  of  such, ve-
hicles should be closely  examined  for
 leakage, and if necessary, tightened, ad-
justed,  or  replaced  to  prevent  liquid
leakage while in transit.
   (3) Oil production facilities (onshore).
 (1) Definition. An onshore production fa-
 culty may  include  all wells,  flowlines,
 separation equipment, storage  facilities,
 gathering lines, and auxiliary non- trans-
 portation-related equipment and  facili-
 ties in  a single geographical oil  or gas
 field  operated by a single operator.
   (11) Oil production facility (onshore)
 drainage. (A) At tank batteries and cen-
 tral treating stations where  an acci-
 dental  discharge  of oil would have  a
 reasonable possibility of reaching navi-
 gable waters, the dikes or equivalent re-
 quired under 5112.7(c)(l)  should have
 drains  closed  and sealed at all times
 except when rainwater is being drained.
 Prior to drainage, the diked area should
 be Inspected as provided in paragraph
 (e>(2)(ui)  (B), C), and (D). Accumu-
 lated oil on the  rainwater should  be
 picked up and returned to storage or dis-
 posed of in accordance with  approved
 methods.
   (3)  Field  drainage  ditches,  roeo
 ditches. ""* oil  traps, sumps  or skim-
 mers, if such exist,  should be Inspected
 at regularly scheduled intervals for ac-
 cumulation of oil that may have escaped
 from small leaks. Any such accumula-
 tions should be removed.
   (ill) Oil production facility (onshore)
 ouflfc  storage tanks.  (A) No tank should
 be used for  the storage of oil unless its
 material and construction are  compati-
 ble with  the material stored and  the
 conditions of storage.
         (SM. m.7(eM5Hiii)]

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 OIL POLLUTION PREVENTION
                                                                         3-!3t
                                                                     131:0935
   (B) All tank battery and central treat-
ing p1*"1* truttaiiaMMTM «houirf be provided
with a secondary mpans of containment
tar the entire contents of the largest sin-
gle famfe if feasible, or alternate systems
such as  those outlined in 5 112.7(c) (1).
Drainage from undiked areas should be
safely confined in a «itotmt»nt t»g«rt sumps are not practicable
oil contained  in collection  equipment
should be removed as often as necessary
to prevent overflow.
   (ill) For facilities employing a sump
system, sump and drains should be ade-
quately sized and a spare pump or equiv-
alent  method  should  be  available to
remove liquid from the sump and assure
that oil does not escape. A regular sched-
uled preventive maintenance inspection
and testing program should be employed
to assure reliable operation of the liquid
removal system and pump start-up de-
vice. Redundant automatic sump pumps
and control devices may be  required on
some installations.
   (lr)  In  areas  where separators  and
treaters are equipped with dump valves
whose predominant mode of failure Is in
the closed position and pollution risk is
high,  the  facility  should  be specially
equipped to  prevent  the escape  of oil.
This could be accomplished by extending
the flare line to a diked area if the sepa-
rator is near shore, equipping it with a
high liquid level sensor *hp^ will auto-
matically shut-in wells producing to the
separator,  parallel   redundant   dump
valves, or other feasible alternatives to
prevent oil discharges.
   (v) Atmospheric storage or surge tanks
should be equipped with high liquid level
sensing devices or other  acceptable al-
ternatives to prevent oil discharges.
  (vl) Pressure tanks should be equipped
with high and  low pressure sensing de-
vices to activate  an alarm and/or con-
trol the flow or other acceptable alterna-
tives to prevent oil discharges.
  (vil) Tanks should be equipped with
suitable corrosion protection.
  (viil) A written procedure for inspect-
ing  and  testing  pollution  prevention
equipment  and systems should  be pre-
pared  and maintained at the  facility.
Such  procedures  should be included as
part of the SPCC Plan.
  (ix) Testing and inspection of the pol-
lution prevention equipment and systems
at the facility should be conducted by the
owner or operator on a scheduled peri-
odic basis commensurate with the com-
plexity, conditions ftrvl ^pMiimgEanr**^ of
the facility or other appropriate regula-
tions.
   (x) Surface and subsurface well shut-
 in valves and devices in use at the facil-
 ity  should be sufficiently  described to
 determine method of activation or con-
 trol, e.g.. pressure differential, change in
 fluid or flow conditions, combination of
 pressure and flow, manual or remote con-
 trol  mffttantmat  Detailed records  for
 each well, while not necessarily part of
 the plan should be kept by the owner or
 operator.
   (3d) Before drilling below any '•q-g'yg
 string. «"""1 during workover operations
 a blowout preventer (BOP) assembly and
 well control system should be installed
 that is capable of controlling any well-
 head pressure that is expected to be en-
 countered  while that BOP assembly is
 on the well. Casing and BOP Installations
 should be  in accordance with State reg-
 ulatory agency requirements.
   (jdi) Extraordinary well control meas-
 ures should be  provided should emer-
 gency conditions, including fire, loss of
 control and other abnormal conditions.
 occur. The degree of control system  re-
 dundancy  should vary  with hazard ex-
 posure  and probable  consequences of
 failure. It  is recommended  that surface
 shut-in systems have redundant or "fail
 close" valving. Subsurface safety valves
 may not be needed in producing wells
 that will not flow but should be installed
 as required by applicable State regula-
 tions.
   (xiil)  In order that  there will be no
 misunderstanding of joint and separate
 duties and obligations  to perform work
 in  a  safe and  pollution free manner.
 written instructions should be prepared
 by the owner or operator for contractors
 and subcontractors to  follow whenever
 contract activities Include servicing a
 well or systems appurtenant to a well or
 pressure vessel.  Such  instructions  and
 procedures should be maintained at the
 offshore production facility. Under cer-
 tain circumstances and conditions such
 contractor  activities may  require  the
 presence at the faculty  of an authorized
 representative of the owner or operator
 who would Intervene when necessary to
 prevent a spill event.
   (xiv) All manifolds (headers) should
 be equipped with check valves on indi-
 vidual flowlines.
  (xv)  If  the  shut-in  well pressure is
 greater i**** the working pressure of the
flowllne  and manifold valves up to and
 inHiiHing the header valves associated
with that individual flowllne.  the  flow-
 line should be equipped with a high pres-
sure sensing device and shutin valve at
 the wellhead "r»i«"» provided with a pres-
sure relief  system to prevent over pres-
suring.
  (xvl) AH pipelines appurtenant to  the
facility should be protected from corro-
sion.  Methods used, such as protective
coatings or cathodic protection, should
be discussed.
  (xvii) Sub-marine pipelines appurten-
ant to the  facility should be adequately
protected against environmental stresses
and  other  activities such  as  filing
operations.
  (xviil)  Sub-marine pipelines appurten-
ant  to the facility should  be  in good
                                 Copyright <£ 1973 by Th« Bureau of National Affairs,  Inc.


                                                    43

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131:0936
            FEDERAL REGULATIONS
ope7atin£ condition at nil times and in*
spected on a scheduled periodic basis for
failures.   Such  inspections  should  be
documented arvi  ^<\ipta^pi»rf  at  t2ie
facility.
   (8)  Inspections and  records.  Inspec-
tions required by  this part should be in
accordance  with written procedures de-
veloped for  the  facility by the owner or
operator.  These written procedures and
a record of the inspections, signed by the
appropriate  supervisor  or   inspector.
should be made part of the SPCC Plan
and maintained for a period of three
years.
   (9)  Security (excluding oil -production
facilities). (1) All  plants handling, proc-
essing, and  storing oil should be  fully
fenced, and entrance  gates should  be
locked and/or guarded when  the plant
is not in production or is unattended.
   (11)  The master flow  and drain valves
and any  other  valves  that* will  permit
direct  outward  flow of the  tank's con-
tent to the surface should  be securely
locked in the  closed position  when in
non-operating or  non-standby status.
   (ill)  The  starter control  on  all  oil
pumps should  be locked in  the  "off"
position  or  located at  a site  accessible
only  to authorized  personnel  when the
pumps are  in a non-operating or non-
standby status.
   (iv)  The 'loading/unloading  connec-
tions of oil  pipelines should be securely
capped or  blank-flanged  when  not in
service or standby service  far an ex-
tended  time.   This  security  practice
should also apply to pipelines that are
emptied   of liquid  content  either  by
draining or by  inert gas pressure.
   (v)  Facility lighting should be com-
mensurate with the type and location of
the facility.  Consideration  should  be
given  to:  (A)  Discovery of  spills oc-
curring during  hours of darkness, both
by operating  personnel, if present, and
by non-operating personnel  (the  gen-
eral public, local police, etc.)  and  (B)
prevention  of  spills occurring through
acts of vandalism.
   (10) Personnel,   training  and  rpitt
prevention procedures. (1) Owners or op-
erators are  responsible for properly In-
structing tnrtr personnel in the operation
and ""*|"**T«TIM» of equipment to pre-
vent the  discharges of oil and applicable
pollution  control laws, rules  and regula-
tions.
   (11)  Tftyh  applicable facility  should
have a designated person who is account-
able for oil  spill prevention and who re-
ports to line Tran ^np**** **r *
   (UD Owners   or   operators   should
schedule  and  conduct spill  prevention
briefings  for  their  operating  personnel
at Intervals frequent enough  to assure
adequate understanding of  the  SPCC
Plan  for that  facility. Such  briefings
                                                   highlight  "J"<  describe  known
                                           spill events or failures, malfunctioning
                                           components, and recently developed pre-
                                           cautionary measures.
                                             Memorandum, of Understanding between
                                           the Secretary ot Transportation and the Ad-
                                           ministrator at che Environmental Protection
                                           Agency.
                                                    section n—ocrnvrrtONs

                                             The Environmental Protection Agency and
                                           the Department of Transportation agree that
                                           for the purposes of Executive Order 11S48.
                                           the. term:
                                             (1)  "Non-transportation-related onshore
                                           and offshore faculties" means:
                                             (A)  Fixed onshore and offshore ou well
                                           drilling  facilities  Including all equipment
                                           and appurtenances related  thereto used  In
                                           drilling operations for exploratory or develop-
                                           ment wells, but excluding any terminal facil-
                                           ity, unit or process integrally associated with
                                           the handling or transferring of oil la bulk to
                                           or from a vessel.
                                             (B)  Mobile onshore and offshore ou veil
                                           drilling platforms, barges, trucks, or other
                                           mobile facilities Including ail equipment and
                                           appurtenances related  thereto  when such
                                           mobile facilities are fixed la position for the
                                           purpose of drilling operations for exploratory
                                           or development wells, but excluding any ter-
                                           minal facility, unit or process integrally as-
                                           sociated with the handling or transferring of
                                           oil In  bulk to or from a vessel.
                                             (C)  fixed onshore and offshore oil produc-
                                           tion structures,  platforms, derricks, and rigs
                                           including all equipment and appurtenances
                                           related thereto, ai well  as  completed wells
                                           and the wellhead separators, oil separators.
                                           and storage facilities used In the production
                                           of oil. bus excluding any terminal facility,
                                           unit  or  process  Integrally  associated with
                                           the handling or transferring of oil In bulk
                                           to or  from a vessel.
                                             (D)  Mobile onshore and offshore oil pro-
                                           duction  facilities  Including all equipment
                                           and appurtenances related  thereto  as well
                                           as completed weus and wellhead equipment.
                                           piping from wellheads to oil separator!, oil
                                           separators, and storage facilities used tn the
                                           production of oil when such mobile facilities
                                           are axed In position  for  the purpose of oil
                                           production operations,  but  excluding any
                                           terminal facility, unit or process  Integrally
                                           associated  with the handling or transferring
                                           of oil  in bulk to or from a vessel.
                                             (Z)  OU  refining facilities Including  all
                                           equipment   and   appurtenances   related
                                           thereto as well as tn-plant processing unit*.
                                           storage units, piping, drainage systems and
                                           wane  treatment unit* used  la the refining
                                           of ou. bat excluding any terminal facility.
                                           unit or process Integrally associated with the
                                           handling or transferring ot oil In bulk to or
                                           from a Teasel.
                                             (»)  OU  storage faculties  Including  all
                                           equipment   and   appurtenances   related
                                           thereto as well as fixed bulk plant storage.
                                           terminal oU storage facilities, consumer stor-
                                           age, pumps and drainage systems used In the
                                           storage of oil. but  excluding inline or break-
                                           out storage tank* needed for the continuous
                                           operation  of a' pipeline system  and  any
                                           terminal facility, unit or process  Integrally
                                           associated  wtth the handling or transferring
                                           of oil  in bulk to or from * vessel.
  (G)  Industrial, commercial, agricultural
or public faculties which use and store oil.
but excluding any terminal facility, unit or
process integrally associated  wtth the han-
dling or transferring of oil In bulk to or from
a vessel.
  (HI  Waste treatment  facilities  Including
in-plant pipelines, affluent discharge  lines.
and storage tanks, but excluding waste treat-
ment facilities located on vessels and termi-
nal  storage ranlti and appurtenances for the
reception of oily ballast water or tank wash-
ings from vessels and associated systems used
for  off-loading vessels.
  (I)  Loading racks, transfer hoses, loading
urns and other equipment  which are ap-
purtenant  to  a nontransportatlon-relaud
facility or  terminal  facility  and  which are
used to transfer oil In bulk to or from high-
way vehicles or  railroad  can.
  (J)  Highway  vehicles  and railroad cars
which,  are used  for che transport of oil ex-
clusively within the confines of a aontrans-
portation-related facility and which are not
Intended to transport, oil in interstate or In-
trastate commerce.
  (K)  Pipeline systems which  are used for
the transport of oil exclusively within the
confines of a nontransportatloa-related facil-
ity or terminal facility and which are not In-
tended to  transport  oil  In Interstate  or
Intrastate commerce, but excluding pipeline
systems  used to transfer oil in bulk  to or
from a vessel.
  (2)  "transportation-related onshore and
offshore facilities" means:
  (A)  Onshore  and offshore terminal facili-
ties Including transfer hoses, loading arms
and  other  equipment  and  appurtenances
used for the purpose of  handling or  trans-
ferring oil- "in bulk to or from a vessel  as
well as storage  tanks and appurtenances for
the reception of oily ballast water or <•»"*
washings from  vessels, but  excluding ter-
minal  waste treatment  facilities  and ter-
minal oil storage facilities.
  (B)  Transfer  hoses,  loading arms and
other  equipment  appurtenant  to a  non-
transportation-related facility which  is used
to transfer oU in bulk to  or from a vessel.
  (C)  Interstate and Intrastate onshore and
offshore  pipeline systems including  pumps
and  appurtenances related thereto as well
as In-line or breakout storage tanks  needed
for  the continuous operation of  a pipeline
system, and pipelines from onshore and off-
shore oil production facilities, but excluding
onshore and offshore piping from wellheads
to oU  separators and pipelines which are
used for the transport  of  oil exclusively
within the confines of a  nontransportation-
related  facility  or  terminal facility and
which  are not Intended  to transport  oU  la
interstate or  Intrastate  commerce   or  to
transfer oil In bulk to or from a vessel.
  (D)  Highway  vehicles  and railroad cars
which  are used  for the transport  of  ou  In
interstate or Intrastate commerce and the
equipment   and  appurtenances  related
thereto, and equipment used for the fueling
of locomotive units,  as well  as the nghts-
of-way on which they operate. Excluded are
highway vehicles and railroad cars and mo-
tive power used  exclusively within the con-
fines of a aontransportatlon-related facility
or terminal  facility and  which are aot in-
tended for use  la interstate or  latrastate
commerce.
                                                     Environment Reporter

                                                            44

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                                                                                                               S-219
                                                                                                           131:0971
                           EPA INTERIM  REGULATIONS ON CIVIL PENALTIES
                 FOR VIOLATIONS OF OIL POLLUTION PREVENTION REGULATIONS
                                 (40CFR 114; 39 FR 31602, August 29,  1974)
   Title 40— Protection of Environment

    CHAPTER I— ENVIRONMENTAL
        PROTECTION AGENCY
             [7BL 330-3]

PART 114 — CIVIL PENALTIES FOR VIOLA-
  TION OF OIL POLLUTION  PREVENTION
  REGULATIONS

           Interim Regulation

  ATTHOwrr: Sea. 311 (J). 501 (a.). Pub. L»w
92-400, 88 Stai. 868, 880 (33 U.S.C. 1331 (J),
 NON-THANSPORTATlOir RSLATXB ONSHORE
        ABO OITSEORZ P*.«!II.ITIKS
§ 114.1   General applicability.
  Owners or operators of faculties sub-
ject to 9 112.3 (a) , (b) or (c) of this sub-
chapter who violate the requirements of
Part 112 of this Subchapter O by failing
or refusing- to comply with any of the
provisions of 5112.3, 112.4. or  112.5 of
this subchapter shall be liable for a civil
penalty of not more than $5,000 for each
day such violation continues. Civil pen-
alties shall be assessed and compromised
in accordance with this Part. No  penalty
«h«n be assessed until the owner or oper-
ator shall  have been given notice and
an opportunity for hearing hi  accord-
ance with this Part.
§ 114.2   Violation.
  Owners or operators of facilities shall
be  liable for a civil penalty for  non-
compliance  with the  requirements of
Part  112 of this subchapter. Including
but not limited to failure to?
   (a) Prepare a Spill  Prevention  Con-
trol and Countermeasure (SPCC)  plan
in accordance with 9 112.3 of this sub-
chapter:
   (b) Eave a SPCC plan certified by a
Registered Professional Engineer as re-
quired by 9 112J of this subchapter;
   (c) Implement the SPCC plan as re-
quired by 9 112.3 of this subchapter;
   (d) Submit Information  after a spill
as required by 9 112.4 of this subchapter:
   (e) Amend plan as required by i 112.4
of this subchapter:
   (f)  Implement amendment as required
by 5 112.4 of this subchapter;
   (g) Amend plan  after change In fa-
cility design as required by 5 112.8 of
t>ii« subchapter;
   (h) Review plan  every three years as
required by 9 112.5 of this  subchapter:
   (1)  Amend plan  after review as re-
quired by 9 112 .5: or
   (J) Have amendment certified as re-
quired by 9 112.5 of this subchapter and
implemented.
§ 114^  Determination of penalty.
   Right to request a hearing; and
  (h) The  procedures  for requesting a
hearing including the right to be repre-
sented by counsel,

§ 114.5   Request for bearing.
  Within thirty (30) days of the date of
receipt of a Notice of Violation, the per-
son named in  the Notice may request a
hearing by  submitting a written request
signed by or on behalf of such person by
a duly authorized officer, director, agent,
or attorney-in-fact, to the Regional Ad-
ministrator.
  (a) Requests for hearings shall:
  (1) State the name and address of the
person requesting the hearing:
  (2) Enclose  a copy of the Notice of
Violation; and
  (3) State with particularity the issues
to be raised by such person at the hear-
ing.
  (b) After a request for hearing which
complies with the requirements of para-
graph (a) of this section has  been filed,
a hearing  «M'l be  scheduled for the
earliest practicable date.
  (c) Extensions of the  time for the
commencement of the hearing may be
granted for good cause shown.
§ 114.6  Presiding Officer.
  The hearing shall be conducted by the
Presiding Officer. The Regional Adminis-
trator may designate any attorney in the
Environmental Protection Agency to act
as the Priding Officer. No person sh«H
serve as a Presiding Officer where he has
any prior connection with the case in-
cluding without limitation the perform-
ance of investigative or prosecuting func-
tions or any other such functions. The
Presiding Officer appointed -«h»n  have
the full authority to conduct the hearing.
decide issues and to assess a civil penalty
as appropriate.

§ 114.7   Consolidation.
  The Presiding Officer may, in his dis-
cretion, order consolidation of any hear-
ings held under this Part and arising
within one Region whenever he deter-
mines that consolidation will expedite or
simplify  the consideration of the issues
presented. The Administrator  may.  in
his  discretion, order consolidation, and
designate one Region to be responsible
for the conduct of any hearings held un-
der  this Part which  arise in different
Regions  whenever he  determines  that
consolidation will  expedite or simplify
the consideration of the Issues presented.
Consolidation shall not aSect  the right
of any person to raise  issues that could
have been raised if consolidation had not
occurred. At the conclusion of the hear-
ing the  Presiding Officer shall render  a
separate decision for each  separate civil
penalty case.
§114.8   Preparing conference.
  The Presiding Officer may hold one or
more prehearing  conferences  and  may
issue a hearing agenda which may in-
clude, without limitation, decisions with
regard to any or all the following:
  (a) Stipulations and admissions;
  (b) Disputed issues of fact;
  (c) hearing procedures including sub-
mission of oral or written testimony and
the time allotted for oral arguments; and
  (d) any other matter which may ex-
pedite the hearing or aid in disposition
of any issues raised therein.
§ 114.9   Conduct of hearing.
  The hearing shall be held in the gen-
eral location of  the facility where the
alleged violation occurred  or as agreed
to by EPA and the person charged. The
                                 Copyright 
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 131:0972
                                                   FEDERAL REGULATIONS
Presiding Officer shall have the duty to
conduct  a fair and  impartial hearing.
to take action to avoid unnecessary delay
in the disposition of proceedings, and to
m?tn»-ajn order. The person charged with
the violation may  offer relevant facts.
statements,  explanations,  and  other
items which  such person feels should be
considered in  defense  to the charges,
bearing on the person's efforts to achieve
compliance after notification of the vio-
lation or which may bear upon the pen-
alty to be assessed. The EPA or other ap-
propriate Agency personnel shall have
the opportunity to offer facts, statements,
explanations and other items including
testimony of other  appropriate Agencies
personnel  in  order  for  the Presiding
Officer to be fully informed. In the event
the matter cannot be resolved by settle-
ment the person charged with the viola-
tion shall be informed in writing,  of the
decision of the Presiding Officer ar"1 ?hal1
be advised of his right to appeal.


§ 114.10  Decision.
  Within thirty (30)  days after the con-
clusion  of  the hearings,  the Presiding
Officer shall issue findings with respect
to the matter, including,  where appro-
priate to the amount of the civil penalty.
In assessing the  civil penalty the  Pre-
siding Officer shall consider the factors
set forth in i  114.3. A copy of the  Pre-
siding Officer's decision  shall be sent to
the person charged in the  Notice of Vio-
lation. The decision of the Presiding Of-
ficer shall become the final decision of
the  Environmental  Protection  Agency
unless within fifteen (15)  days from the
date of receipt of such decision, the per-
son assessed the penalty appeals the de-
cision to the Administrator, or ""i«*re the
Administrator shall have stayed the ef-
fectiveness of  the decision pending re-
view.

§ 114.11  Appeal to Administrator.
   (a) The person assessed a penalty in
the  Presiding  Officer's  determination
shall have the right to appeal  an ad-
verse decision to the Administrator upon
filing a  written Notice  of  Appeal in the
form required by paragraph (b) of this
section  within fifteen (15) days of the
date the receipt of the Presiding Officer's
decision.
   (b)  The Notice of Appeal shafl:
   (1)  State the name and address of the
person filing the Notice of Appeal;
   (2)  Contain a  concise  statement of
the facts on which the person relies;
   (3)  Contain a  concise statement
the legal basis on which  the person re-
lies; and
   (4)  Contain a  concise statement set-
ting forth  the action which the person
proposed that the Administrator take.
   (c) The  Administrator may  delegate
this authority to  act in  a given case.
   (d)  The Administrator, after a Notice
of Appeal in proper form  has been filed.
shall  render a decision with  respect to
the appeal  promptly. In  rendering his
decision, the Administrator may  adopt,
modify, or  set  aside the decision of the
Presiding Officer in any respect and shall
include in  his  decision  a  concise  state-
ment of the basis  therefore. The decision
of the Administrator  on appeal shall be
effective when rendered.
                                                 Environment Reporter


                                                       46

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                                  APPENDIX B

                     NONTRANSPORTATION-RELATED FACILITIES

     Nontransportation-related facilities engaged in drilling, • producing,
gathering, storing, processing, refining, transferring, distributing, or con-
suming oil, which could reasonably be expected to discharge oil in harmful
quantities into waters defined as navigable and which have nonburied aggre-
gate storage capacity greater than 1320 gallons or nonburied storage capacity
greater than 660 gallons in a single container, or which have buried storage
capacity in excess of 42,000 gallons are subject to 40CFR Part 112 and must
have an SPCC Plan.  Note that 24 full 55-gallon drums make up 1320 gallons.

     "Storage" can include oil production equipment such as separators, heaters,
treaters, etc.  Therefore, owners and operators of oil production facilities
maintain an SPCC program for their facilities which do not have oil storage
tanks per se.

     The following describes the three major facility categories:  (1) Onshore
Nonproduction-Related, (2) Onshore Oil/Gas Production and Drilling/Workover,
and (3) Offshore Oil/Gas Production and Drilling/Workover.  The sections which
follow describe some of the technical features of typical facilities which may
be encountered by the inspector.  There is one major spill prevention area .
which is common to all of them, and that is secondary containment.  Various
secondary containment systems are discussed, as are other important spill pre-
vention measures which the inspector should look for.

ONSHORE NONPRODUCTION-RELATED FACILITIES

     These facilities include bulk oil storage and distribution (bulk plants
and marketing terminals), some service stations, boat marinas, truck terminals,
refineries, terminals, oil consumers, and any other facilities not related to
oil/gas production.

     Bulk oil storage and distribution facilities such as bulk plants frequent-
ly fall under the requirements of 40CFR Part 112 and are characteristic of a
typical nonproduction facility.  An example of a bulk plant is shown in Figure
B-l and consists of:

     (a)  Loading rack area

     (b)  Unloading area

     (c)  Storage tanks — underground and aboveground

     (d)  Office area

                                      47

-------
                       UNLOADING
                          AREAS
CONCRETE
   DIKE
                        SUMP & PUMP
                            TO TREATMENT^
                              OR PICK UP
/
V
Fo"
o
:'o
|O
*0
^0
TANKS(4)
*0
'G.
 A
%
I?
,;'!
l •.-;
                                                              ••ftv^r •*/•
                                                                  .••.*
             &
          *!

             I
           .  '•••
          ^  '•'.
             ?•,  W
             ••f \   • n
             * '  > \\
          vx  »'•   •* -*C
          X  ^   fl\
             *\J&
                                                              \ 5' 'A

                                                              ^|~|

                                                              •A ^?  •*

                                                            x^l-^
                                                              v» Q • "_•
       •^h
  UNDERGROUND
      TANKS
x	x
            ir-
            »'.•
                                                                   ,i2
                  .•**
                 ;i
                 -4:
                 :%
             »'-1l
          x s^ ~'4
            &   .-«
            •^N   Vlrt
            I •« ,   | »s.
            !rrx • rf
                 Figure B-l.  Bulk oil plant—plan view.
                                  48

-------
     (e)  Warehouse  (used for storing lube oil and other products)

     (f)  Truck parking

     (g)  Pumps, valves, piping

     These components are interrelated operationally and the entire facility
should therefore be viewed as a system.  Even the office area, although not a
source of oil spills, is related to the loading rack area, tanks, etc., and
thus may be a human factor in preventing a spill in these areas.  Also, there
are different spill prevention approaches and these may vary from a number of
individual spill prevention structures to a single structure or piece of equip-
ment which can handle the entire facility.  Terrain, drainage, existing facil-
ity design, operational characteristics, etc. all impact the final optimum
spill prevention design.  It is therefore appropriate to understand the overall
equipment layout and operation of the facility before evaluating the individual
solutions.

     For example, a loading area may not, by itself, have any spill containment
and the tanks by themselves do not have any containment, but the runoff from
the facility may flow into a catchment basin which is under the jurisdiction
of the facility.  With proper monitoring and control of the basin, this could
be a satisfactory solution.  The inspector needs to be careful to not impose
requirements upon the owner of the facility which exceed the minimum as re-
quired by the regulation.  This is true for all operators, from the wealthiest
to the poorest,  there are economically viable solutions to all problem situa-
tions.   If the facility has suffered a triggering spill, the Regional Adminis-
trator may require an amendment necessary to control spills and protect the
environment.

The Loading Rack Area

     This area is used to load oil products (diesel fuel, heating oil, gaso-
line, etc.) into tank trucks, and due to its frequent use is very susceptible
to oil spillage.  Since most spills are caused by human error, it is recom-
mended that the following preventive measures be taken:

     •  Electric controls for pumps should either be locked individually or
        locked within a cabinet or behind a locked door to prevent the pumps
        from being turned on by unauthorized persons.

     •  Warning signs or obstructions should be used to help prevent trucks
        from driving away while the loading hose is connected.

     •  Instructions need to specify that loading will be accomplished only
        while an operator is in attendance at the loading rack.

     It must be realized that in spite of these controls, accidents will still
occur.   Therefore, secondary containment must be provided so that a spill from
that area will not leave the property, even in adverse weather.   Two types of
containment systems are frequently employed:   a quick drainage system or diver-
sionary structure which diverts flow to a sump or oil/water separator;  or a


                                      49

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dike, catchment basin, or containment  area.  There are other containment con-
figurations, but. most of them are  variations in arrangement rather than basic
function.  In all cases, the containment volume must be of sufficient size to
hold the largest compartment of the  truck which is being loaded, which will
usually vary from 300 to 1200 gallons.  The two types of systems are described
in the following paragraphs.

Quick Drainage System—
     A quick drainage system is frequently employed on new installations where
it can be built in at the outset.  A typical system is shown in Figure B-2 that
shows how runoff from a loading rack will be contained within a curbed area,
which will then divert the flow to drains which are in turn connected to an
            CURBED
          COLLECTION
             AREA
DRAIN
                                                TO TREATMENT, DISCHARGE
                                                OR PICKUP AS APPROPRIATE
                     SUMP SYSTEM
                      .TANK
                      •PUMP
                      • LEVEL SENSOR
                      Figure B-2.  Quick drainage system.
                                      50

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underground tank, or sump.  The underground tank has a volume of  sufficient
size to contain the largest compartment of the operator's  truck.  The oil col-
lected in the sump can be collected and disposed of properly.

     This system is rather elaborate, and due to terrain it may be mandatory,
but it does have advantages for the operator, e.g., the system is clean, is
easily maintained, and takes a minimum of aboveground space, which may be
quite valuable.  A refinement of this system is to have a  roof constructed over
the curbed area which keeps storm runoff out of the collection sump.

Diversionary Structures—
     Diversionary structures are any structures which divert flow to another
location where the spilled oil can be collected, contained, and removed prior
to the escape of oil from the facility.  An example of a diversionary structure
is shown in Figure B-3.  In this case it was impractical to build an underground
collection system; therefore the rack loading site was graded and curbed to
force the runoff into a diked area which was several feet  lower in elevation and
was also used to contain the storage tanks.  Note that the drain valve must be
kept locked closed.

     Figure B-4 shows another configuration whereby runoff from the loading
area (which is inclined) is collected and diverted by gravity to an under-
ground pipe.  This proved beneficial to the operator because the installation
was rather simple and a minimum of downtime was needed for construction.

Bulk Oil Storage Tanks

     Bulk oil storage tanks are another frequent source of oil spills, and oc-
casionally large oil spills.  It is mandatory that aboveground tanks have sec-
ondary containment in the form of retaining walls, berms, dikes, etc., i.e.,
any structure which will keep the contents of the largest tank from leaving
the owner's property.

     A typical method for accomplishing this is to surround the tanks with an
earthen dike constructed of  selected compactable soil so that it is impervi-
ous to oil.  It is important that the dimensions of the dike be clearly speci-
fied in writing (e.g. , "the dike shall have the following minimum inside dim-
ensions:  24 feet by 48 feet by 2 feet high"), or on a drawing.  The inspector
may have to check the dimensions and dike volume.

     Materials used in construction can be almost anything, so long as they are
relatively impermeable to oil and are structurally adequate to withstand the
hydrostatic forces and the environmental conditions.   Material selection and
design of the dike/retaining wall should be specified on the plan and not be
left up in the air.  If a concrete retaining wall is specified, it should be
securely anchored to a footing and should have sufficient strength to withstand
the full hydrostatic head.  Concrete block wall construction is acceptable for
low walls, but it is highly susceptible to cracking and usually requires peri-
odic caulking or other refurbishment.

     Draining from secondary containment areas is usually accomplished by a
pipe which extends through the wall.  A positive action (manually operated)


                                      51

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                                         VALVE
                                      IW/LOCK
                                    (NORMALLY
                                      CLOSED)
                                                 RACK
                                                LOADING
                                                 AREA
                                   -MTMIN.  RACK LOADING CONCRETE
                                              SURFACE
                                                           CURB
      REINFORCED
CONCRETE WALL 12* HIGH
3" MIN      SECTION A-A
        ROTATED 90° C.C.W.
   NOTES:
   1. SECONDARY CONTAINMENT IS AREA SHOWN INDICATED BY HEAVY LINE.
   2. DIKE AROUND RACK AREA SHALL CAUSE DRAINAGE/SPILLS TO
     FLOW INTO TANK CONTAINMENT AREA.
    Figure B-3.   Secondary containment—loading rack and storage tanks.
                                  52

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01
TRUCK
TRAFFIC
SEE NOTE
\
DRAIN
TO
SUMP v
jr'?*-
6-SEWER PIPE
MIN. 45' LONG
1
\
+-

CURB
X
1 TRUCK
/ / LOADING
/ / AREA
STEEL GRATE
£ * *+. * •-». * ^ • f* •** * j»v *x T
/
Jt
%
\
I 	 •
1

m — UUMUIHO nMor\

~~— ~— ic
•/7
v*^ 1
I
>
-^ 	


ii tj
ONCRETE —
J
FILL PIPES (5) '
(CONCRETE
OR EARTH • \
OPTIONAL )
\r
^» e
^ pi nww

CURB
Amn»
	 k_
m
a:
0



t
AF
1
23'
•RON

                                                   (APPROX)
             NOTE:
             1. CONTAINMENT AREA IS INDICATED INSIDE HEAVY LINE.
              ARROWS SHOW DRAINAGE FLOW DIRECTION.
             2. SUMP LOCATED AT END OF SEWER PIPE SUFFICIENT TO
              CONTAIN VOLUME OF SINGLE LARGEST COMPARTMENT.
                         Figure B-4.  Diversionary structure for rack loading area.

-------
valve permits only water to be drained by an operator who must see to it that
no oil is released and keep the valve locked when closed.  A suitably rigged
red flag should indicate if the valve is open.  Other methods of drainage in-
clude pumps that discharge fluids into standby tanks, oil/water separators,
removal of fluids by vacuum trucks, and specially designed valves that allow
water to pass through, but close when a liquid containing hydrocarbons flows
through the valve.  These hydrocarbon sensing valves are reported to be expen-
sive, subject to fouling by sand and dirt, and are not recommended.  In no case
should flapper valves be utilized for draining secondary containment areas,
since these valves may be subject to sticking open.

     The storage tanks themselves need to be in generally good structural con-
dition, i.e., there should be a minimum of corrosion and there should be no
leaking at any of the seams or pipe joints   Some older riveted tanks and bolt-
up tanks experience slight weeping at joints with no danger to the equipment.
If the tanks are on supports, the latter should be in sound condition.  This
also applies to the piping, pipe supports, and related equipment.  Foundations
should also be examined, if possible, for signs of failure.

Unloading Areas

     Unloading areas are used to transfer incoming oil products from a tank
truck to the facility, and are usually located not too far from the loading
rack.  It is therefore frequently possible to combine the secondary contain-
ment for the unloading area into the rack loading containment system by grad-
ing, drains, curbing, etc.  In general, the same spill prevention measures
apply as for the rack loading area.  However, there is a distinction between
the two areas which is quite important, i.e., whereas the rack loading area
may be used almost continuously, the unloading area will be used less frequent-
ly (generally once or twice a day).  Also, if the proper precautions are taken
in unloading, the chance of human error is greatly reduced.  In many older
facilities, or existing facilities which have built-in physical limitations,
operational changes can be made which will reduce the likelihood of an oil  •
spill to a low level.  Additionally, the operator can provide backup measures
to clean up any oil which might spill, e.g., absorbents (such as straw, "Oil-
sorb"), vacuum equipment, barriers, etc.  However, it should be emphasized that
secondary containment should also be utilized in the loading area whenever
practicable.

Miscellaneous Spill Prevention Measures

     Many facilities have empty drums, waste oil storage, steam cleaning equip-
ment, and other oil-related equipment, which are oil spill hazards.   All this
equipment should be treated in a manner to allow oil to be collected and dis-
posed of properly.  To accomplish this easily, it is frequently advantageous
to use a separator on the rack loading area as a collection point.  It is im-
portant that the operator not discharge oil on the ground in a random fashion,
where the next rain will carry it off the facility and into a nearby stream.

     Bulk plants and similar facilities should implement periodic formal in-
spections of all spill prevention equipment and procedures.  These inspections
                                      54

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should be performed at least once a year.  A sample "Inspection Record" is
shown in Figure B-5.  Informal inspections should be performed daily to weekly
of oil/water separators, locks and other security devices related to spill pre-
vention, structures/tanks, and oil accumulations within secondary containment
enclosures.

ONSHORE OIL/GAS PRODUCTION AND DRILLING/WORKOVER FACILITIES

     Production facilities are also required to have spill prevention measures
taken to prevent oil spills from reaching the waters of the U.S.  The follow-
ing paragraphs describe some typical onshore production systems and various
spill prevention problems and solutions.  As before, the best general solution
is to have adequate secondary containment.

Onshore Production System

     A typical onshore production system is shown in Figure B-6 and consists of
wells, well heads, separators, stock tanks, flow treater, salt water pit, salt
water tank, salt water disposal well, and miscellaneous pumps, valves, etc.
There are obviously numerous variations and all of them cannot be described
here; however, as in a multi-lease production system (where it is necessary to
differentiate the ownership of the oil that is being produced), the systems
are usually repetitions of a single system.

     With only a few exceptions, large amounts of corrosive salt water are pro-
duced along with the oil and gas.  In the production process this water tends
to partially mix with the oil, forming an emulsion.  Treatment of the emulsion
is necessary to separate the oil and water so that the oil can be sold and the
water disposed of properly.  Heat, gravity, and chemicals are used, individu-
ally or collectively, to accomplish the separation process.

Holding Pits—
     In the older oil fields, settling pits were frequently used to complete
the separation process.  Fields like this are still in operation but are grad-
ually being phased out, in part due to their being an oil spill hazard.   Most
states now prohibit the use of pits except on a temporary, emergency basis.
It is not too unusual to see a pit with the walls eroded to the point that oil
is about to overflow the pit.  Therefore, extreme care must be taken by the
operators to ensure that the pit has sufficient freeboard (one foot minimum),
and that oil/water emulsion is not seeping through the wall of the pit (some-
times seepage, once it has started, can only be stopped by lining the pit).
Occasionally, several pits connected in series will be used to improve the sep-
aration process and facilitate oil removal.  Since they will all contain salt
water and varying amounts of oil, all the pits need to be sound.   If the pit is
used only during "emergencies," then the plan should clearly define what con-
stitutes an emergency, the "normal" condition of the pit or how it will be
maintained to keep it ready for use during an emergency, and the minimum safe
operating standards during the emergency.

Stock Tanks—
     Stock tanks should always be provided with secondary containment with a
volume equal to the largest tank plus a reasonable allowance for rainwater.


                                      55

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                                            ANNUAL INSPECTION RECORD

                                                              COMMENTS
              EQUIPMENT         INSPECTION              (CONDITION OF EQUIPMENT                 INSPECTOR'S
    DATE      INSPECTED          METHOD                   OR ACTION TAKEN)                     SIGNATURE
01
                                   Figure B-5.   Sample  inspection record  form.

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 DISPOSAL PIT
     SALT WATER TANK





      SEPARATORS



            STOCK TANKS
          .^
          . ir/
          '.Sf.

          '.VT*
...;-:""•   •';.*.--?.*-*
Figure B-6.  Drainage—oil production  system.
                       57

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Usually, containment is effected by a dike placed around a group of tanks close
together.  Water is drained from the diked area by opening a valve (Figure B-7)
or dropping a "swing pipe"  (Figure B-8).  The valve and pipe are always locked
when closed; when they are open for draining, a suitably rigged red flag should
so indicate..

     If more than one stock tank is used, the tanks should be interconnected
such that if overfilling of a tank occurred, the overflow would be absorbed
by the other tanks.  This is especially important where oil production rates
are high in relation to the capacity of the tanks, and timing of tank gaugings
becomes critical.  In situations like this, additional safeguards such as
high-level sensors/alarms may be needed if it is not practical to increase the
tank capacity to prevent overfilling.

Pumping Units—
     A reciprocating pumping unit on an oilwell commonly uses a crank and arm
which drives a "walking" beam which in turn produces an up-and-down motion to
pump oil from down in the well to the surface.  The driving rod at the sur-
face is polished such that a stuffing box will seal against the rod and pre-
vent oil from escaping.  However, the packing eventually becomes worn and the
gland needs to be re-tightened or the packing replaced.  Frequently this is
neglected and the result is oil leakage which may vary from a quart to several
barrels per day.  If the pumping unit is near a body of water, a sump system
should be installed as an oil spill prevention measure and, as in all cases,
the oil seals (gland and packing) shall be maintained to a good operating con-
dition.  (Note:  The sump can frequently be built in near the stuffing box in
a way that will collect mostly oil and very little rainwater.)

Flowlines—
     Flowlines (from the wells to the tank battery) are subject to corrosion
of both the inside and outside of the pipes.  Flowlines are also susceptible
to damage from vehicles, earth-moving equipment, farming operations,  earth/
moving/settling, thermal stresses and vibration.  Also, flowlines are, in the
majority of cases, not visible.  They are either intentionally buried for
protection, or they are covered up by nature.  Sometimes they are on top of
the ground, but shrubs, vines, grass, etc., obscure them.  It is therefore in
most cases almost impossible to inspect a flowline to determine its condition
before a failure occurs.

     If an operator has uninspectable flowlines, he should develop and utilize
a preventive maintenance program which includes testing, failure prediction
analysis, and recommendations for temporary repair and permanent replacement.
The operator should make this a priority item and stay ahead of the problem.

Separators and Heater/Treaters—
     Separators, heater/treaters, and other process equipment should be pro-
vided with secondary containment whenever practical.  The means for accom-
plishing containment are similar to those, discussed for "Stock Tanks."  It is
often possible, if the terrain allows, to divert the flow from the area around
the separators to the tank dike area.  It may not be advisable to collect oil
right at the heater/treater.  The flow can often be diverted to another loca-
tion to avoid creating a fire hazard.  Typically, the separators and treaters


                                     58

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                                                 DIKE
                                                            NORMALLY
                                                              CLOSED
                           Figure B-7.  Drain valve.
FLOW-
                  DIKE
                    %^MP
                          J.T      -^ft;
                          .«**        *»i »^..

                       J;^-»     . *« -*i .  . ,-*v^'«t^
                       »• 1    '^f£t    > .N*7^*..!
                       %^f\   -    *
                	.g>^».•<•'./ ^J	>
             ROUND PLATE
             (WATER STOP)
^J!
POST
X
5««i*_
                                                                           ^
            Figure B-8.  "Swing  pipe" drain (in closed position)

                                      59

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are  small  compared with the stock tanks,  and  are  easier .to  inspect  and  main-
tain than  flowlines.   It is possible  to establish an  effective" monitoring  and
failure prevention program and contingency plan that  can  provide  a  reasonable
degree of  spill  prevention for the separators and heater/treaters which some-
times cannot, practically, be afforded secondary  containment.   Contingency
plans should only  be  used in those situations where it is impractical to
build secondary  containment for a facility.

Onshore Drilling/Workover Facilities

     Secondary containment shall  be installed around  the  appropriate area  of
each rig to prevent oil (crude, oily  drilling fluids, fuels) from reaching
navigable  water.   Since most drilling rigs use diesel fuel  or gasoline  as  an
energy source for  the prime mover,  the volume of  the  secondary  containment
must be at least large enough to  contain  the  fuel tank(s) plus  rainwater.  If
drain valves are used,  they shall normally be locked  closed as  indicated
previously.

     A blowout prevention (BOP) assembly  shall be used that is  capable  of
withstanding the full pressure that the well can  develop.   Most oil-producing
states have requirements for installation of BOP  stacks.

OFFSHORE OIL/GAS PRODUCTION AND DRILLING/WORKOVER FACILITIES

Offshore Production Facility

     A typical offshore oil production facility is shown  in Figure B-9, and
consists of the following basic equipment:  wellhead, flowlines,  risers, mani-
folds, storage tanks,  separators, heater/treaters, and an oil collection sys-
tem.  Applicable parts  of 40CFR Part  112 are discussed in the following
paragraphs.

Facility Drainage—
     Normally, for  an offshore facility it is not practical to have secondary
containment that is of  sufficient volume to contain "the largest  single tank."
Therefore, other measures need to be  employed that will reduce the risk of
oil  pollution to a  minimum practicable level.

     One of the most  important spill  prevention measures that must be utilized
is a collection system  for drips, leaks,  and spillage of oil on offshore plat-
forms.  The collection  system can be  a combination of individual drip pans
and  diversionary structures  or impervious decking and drains that route the
oil  to a tank or a  sump.   In all these cases it is imperative that procedures
and  equipment be provided for removing the collected oil on a regular basis.
Small-volume drip pans  with  no drain/sump are somewhat impractical if they
are  exposed to rain,  since  they will overflow and would require almost con-
tinual inspection.

     A commonly used  system  that has proved effective is shown in Figure B-10
and  consists of curbed  and impervious platform structures that collect oil
and water, and divert these  fluids  to drains through which they flow under
gravity to a large  sump  or caisson  that allows collection and treatment.  Oil


                                     60

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                                    SALT WATER
                                  TANK PLATFORM-
 HEATER-TR EATER
   PLATFORM
OIL STOCK TANK
  PLATFORM
           SUMP

SUMP PLATFORM
   SEPARATOR
    PLATFORM
     HEADER
   CHECK VALVES ~ ~1"
               •""    x

  WELLHEAD
                  FLOWLINES
                  (SUBMARINE)
                 Figure B-9.  Offshore  production facility.

which is collected is either pumped back into  the system or  disposed of
properly.

     It is imperative that the collection system be  leakproof,  i.e., the plat-
form must be impermeable, the drain pipes must be sound,  etc.

Sump System—
     The sump system should be of sufficient volume  to  contain  any anticipated
leaks and spills.  This can be based on past experience and  on  the history of
the facility in question.

     An automatic sump pump should be used to  remove any collected oil  or
rainwater and a backup system should be available in the event  that the pri-
mary system becomes inoperative.

     In general, all sumps require regular inspection.   Typically,  the  maximum
inspection interval should be one day.
                                      61

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               OIL
        RETURNS TO SYSTEM

               1
     PUMP
           OIL & STORM WATER
              FROM DRAINS
                                          SUMP
TO WASTEWATER
TREATMENT UNIT
;• » r~* I Ivl I ^  X

 /  J ff
                       SUMP
                   SECTION A—A
             TREATER
                                     SALTWATER
                                       TANK
                                a7~*\*
                                Qi
                        STOCK TANKS
  O DRAIN
 — DRAINLINE
 •— DRAINLINE BELOW PLATFORM
 ^ DIRECTION OF FLOW
     Figure B-10.  Curbed platform drain system.
                      62

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Separator and Treater Dump Valves—
     It is essential that when dump valves on separators and treaters are set
to close upon a failure in the system, the relief valves not be vented to the
atmosphere.  The effect of venting directly into air would cause oil to spray
randomly in all directions, including into the water.  It is recommended that
if the dump valves are set to close upon failure, the pressure relief valves
be vented to a surge tank or scrubber which has the structural strength and
volume to adequately handle the fluid flow and pressures.

     In no event should a dump valve failure cause fluids to be discharged
through a flare line if the flare line does not extend to a disposal pit or
other containment structure.

Tanks—
     All atmospheric storage or surge tanks should be equipped with high liquid
level detectors that will either activate alarms and/or control flow to the
tanks.  It is essential that tanks must be in good condition and not leaking
or in imminent danger of leaking/failing.

     All tanks should be adequately protected internally and externally from
corrosion, as required to prevent leakage or spillage.  Methods of controlling
corrosion may include protective coatings, cathodic/anodic protection, chemi-
cal treatment of oil, etc.

Spill Prevention Equipment and Systems—
     In order to maintain a relatively spill-free facility, it is vital that
proper inspection and testing procedures be prepared and implemented for pol-
lution prevention related equipment.  Equipment of particular importance
includes.:

        Liquid level sensors

        Pressure sensors

        Sump pump systems           «

        Valves

        Alarms

        Corrosion prevention equipment

        Integrity of containment and diversionary structures (platform sur-
        faces, drain line, sumps, disposal pits, etc.)

     To ensure that the procedures are being followed, it is mandatory that
authority for carrying out the procedures be properly delegated and that the
records associated with the inspections be properly kept.  It should always
be assumed that if records of inspections are not being maintained, then the
inspections are not being performed.
                                     63

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Well Control—Systems and Equipment—
      The wells should be capable of being shut in  when an  abnormal  pressure
or  fluid flow condition exists.   The controls to shut in the well should be
fail-safe.   Due to  the nature  of this surface/subsurface valving, it  will not
be  practical for the  inspector to much more than verify that the valves are
properly connected  and that  the  equipment is not experiencing a leak.   It
would be detrimental  to the  operator for  the inspector to  insist on witnessing
a well shut-in, since restarting the well can be time-consuming and quite
expensive.
      Blowout preventor valve assemblies are devices  that enable the operator
to  contain a well during workover or drilling operations.  A diagram  of a BOP
assembly is  shown in  Figure  B-ll.   It includes two annular rings (S and T)
that can seal around  the drill pipe or the "kelly"  (drive  shaft).   It  also has
two ram-type valves that can seal around  the drill pipe during an emergency.
i 41
• "vrx 	 *-•— ss.lr.1. ,,
:c "' •;•:: i - i 5r: '
	 £
— H
" '; !•«
i. i N
                                            C Kelly
                                            H Rotary machine
                                            J Rotarymachmedrive
                                            K Vibrating mudscreen
                                            L Outlet for drilling fluid
                                            R Cut-out section of drilling floor
                                            S Hydraulically operated blowout preventer
                                            T Hydraulically operated blowout preventer (rnastergate)
                                            U Outlets, provided wuh valves and chokes for drilling fluid
                                             when upper blowout preventer is closed
                                            V Surface casing (conductor)
                                           W Cement bond between casing and borehole wall
                                            X Drill pipe
                                            Y Heavy, thick-walled pipe (drill collars) at bottom of drilling string
                                            Z Roller bit (for hard formations)

                                           A Flow of drilling fluid
                   Figure B-ll.   Blowout preventor assembly.
                                         64

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     A BOP assembly must always be utilized during a workover or drilling
operation and must be of sufficient strength to withstand the full pressure
that can be produced in the well.  (This does not include wire line workovers,
which may not require or utilize BOPs.)

Flowlines and Pipelines—
     Flowlines are a frequent source of oil spill pollution.  They are usually
in water and/or silt and are therefore difficult to inspect to verify their
integrity.  It is usually not practical to hire divers, X-ray equipment, etc.
to inspect them on a regular basis.  Therefore, the producing companies will
sometimes wait until the flowline begins to leak before corrective action is
taken.  Sometimes the "corrective action" may be a clamp that seals around
the leaking area and stops the flowline from leaking for a period of time,
until a. new leak occurs.

     The obvious disadvantages to this process are (1) oil pollution itself
is utilized as the method of determining a leak, and (2) the method of repair
can be classified as temporary, i.e., the flowline may be "thin" along the
entire length.  (It is not uncommon to see flowlines that have clamps every
4 feet.)  Therefore, a flowline that has failed may be in need of replacement,
especially if it has a record of repeated failures.  Preventive maintenance
programs can be established that will, through testing and statistical analy-
sis, reduce the risk of oil spills from this source to a minimum.

     To avoid flow from an active well to another flowline (which may be in-
active and/or open) it is necessary that the individual flowlines have check
valves at the header or manifold.

     In the event that the well is capable of producing pressures, either
naturally or with artificial lift, which are in.excess of the safe working
pressure of the flowline, then that flowline needs to have either a pressure.
sensor that will shut in the well automatically when the safe working pressure
limit is reached, or a pressure relief system to a safe vent.

Offshore  Drilling/Workover Rigs

     As indicated previously, each oil drilling and workover rig should have
its own SPCC plan.  Offshore drilling rigs have many SPCC requirements that
are similar to those for oil production facilities; however, there are some
differences in operation and construction that are significant to the
inspector.

     The type of drilling rig is usually determined by the depth of water,
prevailing winds, and other environmental or operational conditions.   For shal-
low depths encountered in inland waters of protected coastal waters,  barge
rigs are normally used.  For offshore waters, platform rigs are utilized.

Barge Rigs—
     Drill barges are used in shallow water locations such as the canals,
bayous, and lakes in Southern Louisiana and Mississippi, etc.  The barges are
towed to the location, submerged to touch bottom, and kept in place by piles
driven into the bottom.  Since the setup time for drilling is usually a matter


                                     65

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of a few hours, barge rigs are employed whenever possible.  A pictorial view
of a barge rig is shown in Figure B-12.  The areas of particular interest to
spill prevention are illustrated in Figure B-13.

     The upper level of the rig contains the derrick, rotary table, drilling
operator s and controllers, draw-works, drill-pipe, living quarters, and cas-
ings.  Occasionally, it will contain small quantities of diesel fuel, gasoline,
solvents, lubricants, etc.  As a result, the upper-level areas which contain
oil materials need to be contained so that all liquids will drain in a con-
trolled manner and not flow over the side of the barge into the water.  It is
common practice to weld steel plates Co the edge of the deck to limit the out-
ward flow of liquids.  The inspector should verify that the curbing has the
required integrity and is free of holes, pitting, cracks, and gaps.  Occasion-
ally, the crew will drill holes in the curbing to release water that may be
standing in a low area.  Obviously, this negates the effectiveness of the curb
and is not allowable.  If the operator determines that it is not in his best
interests to provide curbing around the deck, he may choose to install indi-
vidual collection equipment at each oil source.

     The intermediate level usually provides space for the drilling fluid sys-
tem, which includes the mixing hoppers, pumps, shaker, and settling pit, and
storage for liquids and powders. "This level does not ordinarily contain any
oil products, but if it does it should be contained in a manner similar to
that described previously , to eliminate the possibility of oil discharging
into the water.
                  Figure B-12.  Barge-mounted drilling rig.
                                      66

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                            UPPER DECK CURB
                                       FLOOR DRAIN
                                                  HULL
                                                OF BARGE
                                             & BALLAST TANKS
                                  SUMP/SEPARATOR
                   B.O.P. ASS'Y
KEYWAY/GATE
(SEE FIG. B-14)
 Figure B-13.  Barge collection/drainage system.
                      67

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      The Lower level of a barge rig is a likely place for oil spills.   It is
 the location of the diesel engines, gear reducers,  compressors,"fuel tanks,
 and lube oil storage.   The picture is further complicated by these items being
 located adjacent to the ballast tanks, i.e.,  any oil that leaks  into the bal-
 last tanks will eventually be pumped overboard when water is emptied from the
 ballast tanks prior to moving the barge.   It  is essential, then',  not only that
 the lower platform level be contained (to prevent oil from flowing overboard),
 but that the deck be sealed to keep any oil accumulations from entering the
 ballast tanks.   The inspector should verify that only water can  enter  the bal-
 last tanks, and that the curbing has the integrity  to prevent oil from flow-
 ing over the side of the barge.

      The lower level of the barge also utilizes a "keyway" (Figure B-14)  that
 is  a catchall sump and is located in the hull of the barge at the wellhead.
 During  drilling,  the keyway gate and spray unit are used  to prevent oil and
 other contaminants from dispersing into the open water.   However,  since the
 keyway  gate is  not used during transit,  the drains  leading to the keyway  must
 be  kept closed  then.

      A  more acceptable solution is to  have all the  drains  connect to interme-
 diate sump tanks  that  have a water leg.   The  water  leg can then empty  into the
 keyway,  regardless of  whether or not the  gate is  in place  during  transit.
 During  drilling/workover,  it is important that the  keyway  gate fit  tightly to
 avoid seepage of  fluids  from the keyway.   Spray systems are also  recommended
 to  keep  oil substances away from the gate.  The inspector  should  check  the
 plan and the rig  to verify their implementation.

      As  indicated previously,  the drilling contractor must  utilize  the proper
well control equipment,  including a blowout preventer.  The  BOP must be sized
 to  handle  the maximum  well pressures that  can be  generated.

 Platform Rigs—
      The type of  platform drilling rig  in  use varies with  the water depth,
 distance from shore, and  sea state.  Fixed drilling platforms are used for the
 shallowest  and clamest conditions.   Jackup rigs are used for intermediate
 depths and  severer states.   Semisubmersible rigs are the largest  in size and
 find  application  in the deepest waters furthest from shore.  Each of these is
briefly  discussed below.

      Fixed Drilling Platforms—These find use in depths up to 100 feet only,
and are  nearly identical  to  production platforms.  The discussion of SPCC
features of  offshore production platform presented earlier in this appendix
therefore will provide suitable information.

     Jackup Drilling Rigs—Jackup rigs (see Figure B-15)  are frequently util-
ized where the environment can be severe and deeper waters (to 300 feet) are
encountered, e.g., off the coast of Texas, California, Louisiana,  etc.   As
shown in Figure B-16,  the  typical jackup rig uses a rack (on the  leg) and pin-
ion drive system  to raise and lower the rig's  legs relative to the floor of
the ocean.  When  the legs are on the bottom, jacking crews elevate the dril-
ling  floor to above the anticipated maximum wave height,  e.g., 25 to 35 feet
in the Gulf of Mexico.
                                     63

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PNEUMATIC SEAL
                      B.O.P.
                                                OIL&
                                                WATER
        ELEVATION:SECT1ON A-A
Figure B-14.  Keyway for drilling rig.
                 69

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        Figure B-15.  View of jackup  drilling rig.
Figure B-16.  Rack and pinion drive in jackup  drilling  rig.
                            70

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     Spill prevention measures are similar to the barge-type rig in that they
must have

        A curbed drainage system

        A sump to collect all oil

        A blowout preventer

        A contingency plan

     Since the jackup rig is above the water and does not utilize ballast
tanks, it is easier for the inspector to determine structural integrity of
curbs, presence of oil leaks and proper functioning of sump collection equip-
ment.  The inspector should check very carefully to determine that all well
shut-in devices are working properly and that inspection records of these de-
vices are being meticulously maintained.

     Semisubmersible Drilling Rigs—Semisubmersible drilling rigs are quite
large, expensive to build and operate, and are used in offshore drilling to
water depths up to 2000 feet.  A photograph of a self-propelled Semisubmersible
rig underway is shown in Figure B-17.  When the rig reaches the drilling loca-
tion, the ballast tanks are filled, thereby lowering and stabilizing the rig.
Anchored guy lines keep the rig over the hole, thus achieving horizontal con-
trol.  Figure B-18 shows the submarine features of a Semisubmersible rig.

     Spill prevention measures are nearly identical to those implemented on
jackup rigs and barges, except for two areas.  The blowout preventer stack is
always on the ocean floor and the riser from the BOP typically includes a ten-
sioner system, pipe slip joints, pipe ball joints, etc., to facilitate move-
ment of the floating vessel relative to the BOP.
                                     71

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  Figure B-17.  View of semisubmersible drilling rig.
                       LOAD
SEMISUBMERSIBLE RIG
A...- 	
~IU
-
'
3 MVJUHI1NV3 UINt
                    WELL
                        "4r     SUBSEA B.O.P.
Figure B-18.  Submarine features  of  semisubmersible rig.
                           72

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GENERAL
             CONTAINMENT  EQUIPMENT/STRUCTURE OR  CONTINGENCY  PUN
SPCC PREVENTION PLAN  CHECKLIST
Secondary containment and/or diversionary  structures are used for  possible
spill sources:
            Source
       Type of Containment  or Diversionary Structure
Select from:   Dikes,  berma, retaining walla, curbing,  culverting,  gutters,
drains,  weirs, booms, other barriers, spill diversion,  retention ponds  and
sorbent  materials.
If  the containment or diversionary structures above are  impracticable,
state reasons  for impracticability:  	
 and attach  a strong oil spill contingency plan and written commitment  of
 manpower equipment and  materials required to  expedltlously control and re-
 move  any harmful quantity of oil discharged.   Check  if attached:
           Contingency P

 Discussion:
                             Written Commitment
   APPLICABLE EPA GUIDELINES

        40 CFR PART  112.7


  I 1IJ.7  Cul4dinc4 lot  ilia prep.rillon
     •nil InptenienUllim of • Spill Pre-
     vention Control and  Counlenueuure
     Plan.

        Tttt complete tafCC Han mall
  follow the aequenee outlined belov. and
  Include « dUcuulon of the facility', con-
  formaiice with the appropriate guideline*
    Offsbore faalllUM.
    Curbing, drip pani
   (Ul BumM knd collection eyiterni

   (d> When It U determined  that the
 Installation of •truoturef or equipment
 lilted In 1112.7(0) to prevent dUeharged
 oil from  retelling the  navigable water*
.  I* not practlcabfe from any onahore or
  offdior* facility, tne owner or operator
  ihould   clearly demonttraU  euoh Im-
  practicability and  provide the follow-
  big:
    (DA  atrong oil aplll'contingency plan
  following the provUlon of 40 CPH Part

   (1) A written commitment of man-
 power,   equipment  and  material* re-
 quired to expedtuoualy control and re-
 move any harmful  quantity of oil dU-
 charged.
                                                                                                                                            n

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                  NONPRODUCTION - ONSHORE
                                                                                  YES
NO
                                                                                                                40 CFR PART 112.7
A.   Drainage

     (l)   Drains Area  diked storage areas  have valves.

     (2)   Drain valves are  manual, open-and-olose design.

     (3)   Rain water from diked areas is inspected before drainage.

     (U)   Plant drainage systems are  equipped  with  either:

           a.   Ponds, ifigonna or catchment  basins to retain oil or
           b.   A  diversion  system at the final discharge point which
                could contain an uncontrolled spill  and return the
                oil to the plant.

      (5)  Flow of drainage water between  treatment units Is  by
           either:

           a.   Natural  hydraulic  flow or

           b.   Two "lift" pvDBQps  (one  a spare and one permanently
                installed).   _
 Discussion:
                 (I) Facility drainage (on*hor0>; <«x-
               cludlna production /adWIei).  Drain-
               age front diked storage areas should be
               restrained by  valves or  other positive
               mean* to prevent a spill or other excee-
               olve leakage at oU Into the drainage sys-
               tem or Inplant effluent treatment sys-
               tem, except where plan systems are de-
               •Igned  to handle auoh leakage. Diked
               area* may be emptied by pump* or elec-
               tors; however. Uteae should be manually
               activated and the condition of the accu-
               mulation  should be examined  before
               starting to be iure no oil will bo dis-
               charged Into the water.
                  (ft) Mapper-type drain valve* ihould
               not be used to drain diked anas. Valvee
               used for  the drainage  of diked area*
               ahould, a* far a* practical, be ot man-
                ual,  open-and-oloaed   design.  When
                plant  drainage drahu  directly  Into
                water  oounee and  not Into waitewater
                treatment plants, retained storm water
                should be Inspected as provided In para-
                graph UHanill)  (B. O and D) baton
                drainage.
                   (Ill) Plant .drainage systems from uoi
                diked  areas should. If possible, flow Into
                ponds, lagoons or catchment basins, de-
                signed to retain oil or return It to the
                facility. Catchment f*f ***tf should not be
                located  In  areas  subject  to periodic
                flooding.
                     If plant drainage  Is  not en*
                glneered a* above, the anal discharge of
                all In-nlant ditches should be equipped
                with a  diversion system that ooul4. In
                the event of an uncontrolled spill, return
                IbeoUlo the plant.
                   (v) Where drainage waters are treated
                hi more than one treatment unit, nat-
                ural hydraulic flow should be used. If
                pump transfer Is  needed, two  nut*
                . pumps thimM be provided* ^A s>fc leasfe
                • one of the pujnp^ should be, pemunenlsV
                 Installed when ftuch treatment Is con-
                 tinuous. In  any event, whatever te«b>>
                inl4)UM art used facility drainage ivstttm
                 should be adequately engmewd M pro-
                 vent o|| from teaching navlgablk waif re
                 la the mgpt  ot equSpmenl fafiiire or
                 human «rroi at (h* (

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NONPRODUCTION - ONSHORE  (Continued)
                                                                                          40 CFR  PART  112.7
B. Bulk Storage Tanks


    (1)  Tank material and construction are  compatible  with  fluid
         stored.

    (2)  Secondary  containment volume is greater  than the largest
         single tank capacity plus an allowance for rainwater.

    (3)  Drainage of rainwater from  diked  areas into open waters,
         by-passing laplant treatment. Is  accomplished according
         to the f clewing:

          a.   Normally the by-pass valve is sealed closed.

         b.   The rainwater Is  Inspected to insure compliance
               with water quality standards.

          c.   The by-pass valve is  opened  and  reaealed under
               responsible supervision.

          d.   Records  are kept of bypassing and drainage  events.

     (10  Burled metallic  storage taalu:

          a.   New tanks are coated and wrapped to reduce  corrosion.

          b.   Cathodlc protection is  provided for tanks as
               necessary.

           o.  Tanks  are pressure  tested on a scheduled, periodic
               basis.

     (5)   Partially burled metallic tanks  are avoided  (for
           stored  oil) unless adequate shell coating is provided
           for the buried portion.
                                                              YES   NO
                                                                                                     (3) Bulkttoraottanki (onsnore); (ex-
                                                                                                   cluding production /ocUKto).  (|>  NO
                                                                                   tank should bo used for tho storage of
                                                                                   oil unless IU material and construction
                                                                                   are compatible with tho material stored-
                                                                                   and condition* of storage *uch aa pree-
                                                                                   8uro and temperature, etc.
                                                                                     (II) All bulk storage Unk Installations
                                                                                   ahould bo constructed so that a sccond-
                                                                                   ary mean* of containment Is provided for
                                                                                   the entire contents of the largest single
                                                                                   tank plus sufficient freeboard to  allow
                                                                                   for precipitation. Diked area* ahould be
                                                                                   sufficiently Impervious to contain spilled
                                                                                   oil. Dikes, containment curb*, and pita
                                                                                   are commonly employed for thla purpose.
                                                                                   but they may not always be appropriate.
                                                                                   An alternative lystent could consist of a
                                                                                   complete drainage trench enclosure ar-
                                                                                   ranged  so that a spill could terminate
                                                                                   and be safely confined In an In-plant
                                                                                   catchment basin or holding pond.
                                                                                     (Ill)  Drainage of rainwater from the
                                                                                   diked area Into a storm drain or an efflu-
                                                                                   ent discharge that empties Into an open
                                                                                   water course, lake, or pond, and bypass-
                                                                                   ing the In-plant treatment system may
                                                                                   be acceptable U:
                                                                                     (A) The  bypass valve  la normally
                                                                                   sealed closed.
                                                                                     (B) Inspection  of  the  run-off  rain
                                                                                   water  ensures compliance with appli-
                                                                                   cable water quality standards and will
                                                                                   not cause a  harmful discharge at defined
                                                                                   In 40 Cm 110.
                                                                                     (C) The  bypass valve Is opened, and
                                                                                   reseated following drainage  under re-
                                                                                   sponsible supervision.
                                                                                        Adequate  records  are  kept of
                                                                                   such events.
                                                                                     (lv>  Burled metallic storage tanks rep-
                                                                                   resent  a potential for undetected  spills.
                                                                                   A new buried Installation should be pro-
                                                                                   tected   from  corrosion by  coatlnga,
                                                                                   oathodlo protection or other effective
                                                                                   methods compatible with local soil con-
                                                                                   ditions. Such buried tanks should at Uasi
                                                                                   be subjected to regular pressure testing.
                                                                                     (v) Partially burled metallic tank* for
                                                                                   bhe storage  of oil should be avoided, un-
                                                                                   less the buried section of the shell Is aide--
                                                                                   quately coated, altute partial ••burial In
                                                                                   damp earth can cause rapid oomilen of
                                                                                   mo tall to surfaces, especially at tbe eartfe/
                                                                                   air Interface.

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O>
              NONPROUUCTION -  ONSHORE(ConCinued)


(6)   Aboveground tanks are tested by one of the
      following nethoda:

      a.   Hydrostatic testing

      b.   Visual inapeotion

      c.   Shell thickness  testing  (cooparison
           records of shell thickness reduction
           are Baintalned)

(7)   Internal  heating coil leakage  is controlled
      by one or more of the following:

      a.   Monitoring the steam return or exhaust
           lines for  oil.

      b«   Passing the steam return or exhaust  lines
           through a  settling  tank, skinner or  other
           separation system.

      c.   Installing external heating systems.

(8)   All  bulk  storage tanks  are externally
      inspected on a monthly  basis  (including
      seams, rivets, bolts, gaskets, notzle
      connections, valves, connected pipelines
      and  tank  foundation  and/or supports) for
      leaks or  failures.

(9)   Tanks are fail safe  engineered by  one of the
      following:

      a.   High  liquid level alarms with  an audible
           signal at  a constantly manned  station.

      b.   High  liquid level pump cutoff  devices.

      o.   Direct comnunication between the tank
           gauge? and pumping  station.

      d.   One fast means of determining  the liquid
           level in tanks (such as digital ccnputers,-
           telepulse  or direct visual gauges).
                                                                      YES
                                                                                                          40 CFR  PART  112.7
  (vl> Aboveground  Unks  should  be
subject to periodic Integrity letting, tak-
ing  Into account tank design (flouting
roof. etc.) and tulng such technique* a*
hydrottatlo letting. «iiual Inspection or a
system of non-destructive shell thickness
tenting. Comparison records sttould be
kept where appropriate, and lank rap-
ports  and  foundations should be In-
cluded In these Inspections.  In addition,
the outside of the tank  should fre-
quently be observed by operating person-
nel for signs of  deterioration,  leaks
which might cause * spill, or accumula-
tion of oil Inside diked areas.
   To control leakage  through de-
fective Internal heating colU. the fol-
lowing factors should be coiuldered and
auplled. as appropriate.
  (A> The steam return or exhaust lines
from Internal heating colls which dis-
charge Into an open water course should
be  monitored  for  contamlnallc .  or
passed through a settling tank, sklmmsr.
or other separation or rcteaUw system.

    High liquid level alarms with  an
audible or visual signal at  a constantly
manned operation or survelllsruvs sta-
tion; In smaller plants an audible air
vent may suffice.
  (B>  Considering else and complexity
of the facility,  high liquid level pump
niton devices set to stop flow at a pre-
determined tank content level.
  (C»  Direct audible,' or code signal com-
munication between ue tank gatlgv and
the pumping station.
    A fast response system for deter-
mining the liquid level of each bulk stor-
age tank such as digital computers.  Ulc-
piilse,  or direct vision gauges or Uwdr
equivalent.
  (K> Uquld level sensing devices should
be  regularly tested  to Insure  proper
operation.
  (U)  Plant effluent* which are  dis-
charged  Into navigable waters should
have disposal  faculties observed  fre-
quently enough to detect possible system
upsets that could cause an oil spill event.
   Visible oil leaks which result In a
loss of oil from tank seams. gsskeU. rivet*
and bolU sufficiently large to eause Out
accumulation of oil In diked area* should
be promptly corrected.
    afoblle or portable oil storage
tanks (onshore! should be  positioned or
located so as to prevent ipulsd oil from
reaching navigable waters. A secondary
means of containment, such as dikes or
catchment l&slns, should  b* lujnlstvMl
for the  largest single coinpartrnent or
tank. These facilities  should b* locate*
where they will not be subjeqt <
Hooding or

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          NONPRODUCTION - ONSHORE (Continued)
     a.   Liquid level sensing devices are
          Inspected and tested on a scheduled,
          periodic basis.

(10)   Frequent  plant effluent observations to
     detect upsets are made*

(11)   Mobile storage tanks are properly
       positioned to prevent spill reaching
       navigable water.

Discussion:
                                                       YES   NO
                                                                                                   40 CFR PART 112.7
  (3) facility trantler operation*. pump-
Ing, and in-plant proccit (onihore); (ex-
cluding production tacUtttct).  liurled
piping Installations ihould have a pro-
tective wrapping and coaUng and should
be catltodlcally protected If aoll condi-
tions warrant. If a secUon of buried Una
la exposed /or any reason. It should be
carefully  examined for deterioration. If
corrosion damage la found,  additional
examination and corrective action should
be taken  as Indicated by the magnitude
of the damage. Ah alternative would be
the more frequent use of exposed pipe
corridors  or galleries.
Intra-Facility Transfer Operations, Pumping
and Inplant  Process

A.   Burled Pipelines

  (l)  Pipelines are wrapped and coated
       to reduce corrosion.

  (2)  Cathodlo protection is  provided  for
       pipelines aa needed*

  (3)  When a pipeline section is exposed, it
       is inspected and corrective action taken
       as necessary.

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                   NONPRODUCTION - ONSHORE  (Continued)
                                                                              YES
NO
                                                                                                                 40 CFR PART  112.7
             Pipeline terminal connections are  capped or blank-
              flanged and narked  if the  pipeline !• not in ser-
              vice car on standby  service for long periods*
        Discussion:
        C.   Pipe  supports are  designed to minimize  abrasion
             and corrosion and  allow for expansion and contractions4
        Discussion:
00
         Q.  All  aboveground valves and pipelines are inspected
             on a scheduled, periodic basis  (including flange
             Joints, valve glands and bodies,  catch pans, pipe-
             line supports, looking of valves, and  metal surfaces.)

          Discussion:
                      (lit When a pipeline la not in service.
                    or In standby service (or «n extended
                    time the terminal  connection at the
                    transfer point should be capped or
                    blank-flanged, and marked at to origin.
                       Pipe support* should be properly
                    designed to mlnlmlM abrasion and cor-
                    rosion and allow for expansion and con-
                    traction.
                      Uv) All aboveground valvw and pipe-
                    lines should be subjected to regular ex-
                    amination* by operating personnel at
                    which  time the  general condition of
                    Items, such  a* flange joint*, expansion

                     JolnU. valve glands and bodies, catch
                     pan*, pipeline supports, loosing of valve*.
                     and metal aurf aeei should be assessed. In
                     addition, portodto pctuure testing may
                     be warranted (or piping la area* where
                     (acUlty drainage Is such that a faOiue
                     night lead to a spUl event.
                       (v) Vehicular traffic granted entry Into
                     the facility should be wanted verbally
                     or by appropriate sign* to be Mire that
                     the vehicle, because of It* alat. will not
        E.  Vehicles entering the facility  are inspected  and/or
              warned to avoid  damaging aboveground piping.
        Discussion:

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                   NONPRODUCTION - ONSHORE  (Concluded)
                                                                                                     40 CFR PART 112.7
     Discussion (oont'd)
D.   Intro-Facility Tank Car & Tank Truck Loading/Unloading
Tn requirements
     A. Loading/unloading procedures meet the
        and regulations of the Department of  Transportation.

     B.  The unloading area ha*  quick  drainage system*

     C.  The containment  system  will hold maximum capacity of
         any single tank  truck loaded/unloaded in the plant.

     D.  An interlocked warning  light  or physical barrier  system
         or warning signs are provided In the loading/unloading
         areas to prevent vehicular departure before disconnect
         of transfer lines*

     E.  Drains  and outlets on tank trucks and tank cars are
         checked for leakage before 1f""M"g or

     Discussion:
                    <4> -facility tank car and lanfc (ruck
                  loading/unloading rack (oiuhorc).  (It
                  Tank CM and Unk truck loadlng/un-
 YES    NO        loading procedure! ahould meet Ut« mln-
——   ——       imiunreQUlremenU and regulation eetab-
                  Uehed by the Department ol Transpor-
                  tation.
                    
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                                OIL PRODUCTION -  ONSHORE
                                                                                                               40  CFR  PART 112.7
oo
O
E.   Oil Production -  Onshore                         ,

     (1)  Secondary containment drains are
           closed and locked.

     (2)  Ditches,  sumps,  traps,  etc.  are
           kept olean ot oil

     (3)  Tanks are compatible with oil stored.

     (It)  Tanks fc treating equipment have second-
           ary flOtlta^yVf^P1^ •

     (5)  Tank batteries are  failsafe.

                 (»)   Tanks have extra capacity.

                 (b)   Equalising lines are used.

                 (o)   Vacuum  eliminators  are used.

                 (d)   High level alarms are  used.

     (6)  Piplng/pluntoing egulpnent is Inspected
           regularly.

      (7)  Disposal pits are kept  at sufficiently
            low levels.

      (8)  Flowline  preventive  maintenance  program
            is  utilised.
         Discussion:
YES     NO       at GU production faclllMe«(on*nore>.
                 (I) Definition. An onthore production fa-
                 cility may Include.all wells, flowllnet.
                 separation equipment, ttoraga faclUUet.
                 gathering llnet, and auxiliary non-trent-
                 portatlon-relaUd equipment and faclll-
                 tle* In a tingle geographical'oil or gaa
                 field operated by a'tingle operator.
                    OU  production laeUUu (ontftort)
                 drainage. (A) At tank batteries and cen-
                 tral  treating  station* where  an acci-
                 dental  discharge  of oil would have a
                 reasonable pottlblllty of reaching navi-
                 gable water*, the dike* or equivalent re-
                 quired under 1111.7(0 (O  thould have
                 drain* closed  and tealed  at  all lime*
                 except when rainwater It being drained.
                 Prior to drainage. Uie diked area thould
                 be  Inspected at provided In paragraph
                  (eXaUIID (B). Ot, and (Dt. Accumu-
                  lated oil  on the rainwater ihould  be
                  picked up and returned to ttorage or dlt-
                  poted  of  In accordance with approved
                  method*.
                    (B>   Field  drainage  dllchei.  road
                  dltche*. and oil trap*, tumpa or tklm-
                  mert. If tucli exltt.  ihould be Impeded
                  at regularly acheduled Interval* for ac-
                  cumulation of oil that may have escaped
                  from tmajl  leaks. Any tuch accumula-
                  tion* thould be removed.
                    (im OU production facility (oiwhore)
                  bulk *lora0« tanJkt.  (A> No tank thould
                  be iiied for Uie ttorage of oil unlett IU
                  material  and construction  an compati-
                  ble with  the material itored and the
                  condition* of ttorage.

                     All lank battery and central treat-
                  Ing plant Installation! ihould be provided
                  with a taoondary mean* of containment
                  for the entire content* of the largett tin-
                  gle tank  If feasible,  or alternate system*
                  tuch at those outlined In  I ua.7(cl(l>.
                  Drainage from undlked area* should bo
                  safely confined In a catchment basin or
                  holding pond.
  (O AU tank* containing oU tbould bo
vltually examined by a competent per-
eon for condition and need for mainte-
nance) on a eoheduled  periodic bail*.
Buch examination  thould Include the
foundation and rapport* of  tank* Uxat
are above the surface of the ground.
   Haw and old tank battery Initalla-
Uon* ihould. at far a* practical, be fall-
tale engineered or  updated Into a tall-
Mfe •neutered IntUllatlon to prevent
iplUe. Oantlderatlon thould b* given to
on* or more of the following:
  (II Adequate tank capacity  to attur*
that a tank will not overfill  ihould a
pumpar/caugM be dtUyed lu uakiog hU
regular round*.
   (1) Overflow equallalng line* between
 tank* aa.Uui a full lank can overlbnt to
 an adlacent Unk.
   (Jt  Adequate vacuum protection to
 prevent  tank collapee during a plpelin*
 run.
   (41 High level teuton to general* and
 tranwntt an alarm tignal U the computer
 where facUltla* are a part of a computer
 production control tytUm.
   (lv> fooUUy traniltr operalloiM. oil
 produeildtt  /acUlly (onihort). (A) AU
 above grotmd valvet and pipeline* ihould
 be examined periodically on a aoheduled
 batU Mr'generai condition of item* tucfa
 a* QaogtloiuU. valve glandt and bodice,
 drip .pant, pipeline  tupporU. pumping
 well potlih rod atuffliM boiet. bleeder and
 gauge valve*.
    (B> Salt water (oil field urine)  dlt-
 poial faolUtle* should be examined often.
 particularly following a tudden ehange In
 atmotpherlc temperature to dttcct pot-
 tlbl* *ytUm upeet* that could, oautt an
 oil dlacharge.
    (C) Production facUltle* thould  have
  a program of Bowline maintenance to
  prevent tpillt from thle tource. The pro-
  gram tliould btcluda periodic examlna-
  Uont, corrotlon protection, flowllna re-
  placement, and adequate record*, a* ap-
  propriate, for the Individual  facility.

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          DRILLING  AND WORKOVER - ONSHORE
                                                                                                         40 CFR PART 112.7
F.   Oil Drilling and Workover  (Onshore)

     (1)  Secondary containment is  provided.

     (2)  Blowout preventers are utilized.

Discussion:
                                                                        YES     NO
   «u» uu uniting ana workover /oeMMfn
 (onsfcore) (It Mobile drilling or woriraiver'
 equipment should  be positioned OF lo-
 cated w>  M to prevent spilled otf from
 reaching  navtg«bld waUn.
   (II) Depending on the location, catch-
 ment baalni or dlvaratan iinwturea may
 b«i necMaaiy to Intercept and  contain
 ipUU of fuel, thide oil. or oily  drilling
 fluids.
  (Ill) Before drilling below any casing
 tiring or  during workover operation*, a
 blowout prevention (BOP)  auembly and
 well  control lyotem ahould be Installed
 Uiat  U capable of  controlling any well
head prewure that U expected to  be
encountered while that BOP aaaombly U
on the well. Owing and BOP Installation*
ahould be In accordance with State reg-
ulatory agency requirements.

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                          OIL  DR1I.LINC/WORKOVER ANu PRODUCTION  - OFFSHORE
OO
0.   Oil prllling/^orkover and Production -
     Offahore

     (1)  Drainage/collection equipment  1*
           properly  installed?

     (2)  Sump* are properly "lied,  and  have
           a  preventive   giainte&ance prograa,
           and are kept free  of ollt

     (3)  Bump  pump/control* are redundant
            (when automatic)T

     (k)  It dump valvea are eet to be oloaed
           in the event of failure,  are Mas-urea
           taken to  prevent oil discharge* to
           vatert

     (9)  Are bleb  level alarm*  utilised on
           atorage and pressure tankeT

     (6)  Tanka are protected frou  corroalont

     (7)   Inspection and testing procedure!  are
          are written and lapleaentedt

Dlacuacion:	
                                                                                      YES
                                                                    HO
        40 CFK PART 112.7


   (II  Ott 4rW*t. prodiulkm. or work-
 ainrlacUUItt lofikorck. (It Definition:
 •An oil drilling, production of workover
 f acllllr (ooVdtoret* ma* Include all drlll-
 tiil at workovor  equipment, well*. Bow-
 line*,  gallieruig  line*.  plaUorm*,  Mid
 auillurj    nontranaporlaUon - related
 equipment and lacllllle* In a tlmle geo-
 (niihlwl oil or IM Oelil oponttcd 6» t
 iliulo otKimlor.
   till  OU draliuie collullun cqulpnienl
 •iHHild be  uud to prevent »nd conltol
 (null  oil iiilllaf • cround puinix. (luidi,
 Vftlvea. AMile*. BK|uin>lon lolitU. tioiei.
 drain  Unci.»«c|i»r«ior». treiler*. Unit.
 and allied  equipment. Drain* on Uia
 f aclilly ahoiild !>• controlled and directed
 toward a  central collection  aump or
 equivalent collection oriUiu mfflctent to
 prevent dUcliariee of oil Into Uu natlga-
 bla watera al tha Onlted Bute*. Wh»r«
 dralni and aumiic ara not pracUcabl*
 oil conlalned In collection  equipment
 auould In removed M alien M oeccAiarr
• to prevent ovcrAow.
   IIU) Pbr laellUlei employlni a tump
 •y«ten>. nuitp and dialiu aliouM bo ade-
. quatelr elted and a iiiar* pump or equiv-
 alent  method ahoutd  be  available lo
 tenant liquid Irom the etunp and awure
 •that oil doee not euapa. A rc|Ul«r evhed-
 »Kd MvvfiiUva maintenance liupecllon
 and teethif pragran aliould be emulated
 lo awura nllable operation of the liquid
 removal eiretam and pump aUrt-up da-
 vice. Bedundant autamatlo eump puinpe
 and control device* ma> be required on
 eome  buUllatlaiu.
    Prewure tank* ilmuld be equipped
 •llh high and low preaiur* Miulug de-
 vice* lo activate ail alarm and/or con-
 trol the How or other acceptable alterna-
 tive* lo prevent  oil dlacharge*.
   (till Tank* ihoiilil be equipped with
 eullable corroilon protection.
   Ivllll A written procedure lor liupect-
 Ing and  leillnf pollution iwevenllou
 equliuntnt and 
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   OIL DRILLING/WOUKOVER AND PRODUCTION - OFFSHORE(Continued)
                                    40 CRF PART  112.7
                                                                       YES
HO
CD
OJ
       (6)   Testing/Inspection occurs on regularly
              scheduled baalat

       (9)   8urfaoe/aubaurface abut-In  valvea are
              properly  activated by pressure  or
              flow,  eto.t

       (10)  B.O.P.'a  aro utilised during drilling/
              vorkovert

       (11)  Well surface ehut-ln valvea have re-
              dundant or final-close valvlngt
               Instructions have been prepared  for
               contraotora and auboontractora ao that
              the work la performed In a cafe  and
              pollution  free  mannert
       (13)  Manifolds have  checkvalvea. Installed on
              Individual  flowllneaT

       (lU)  Where well  pressure  can be greater than
              the saf e working pressure of the flow
              lines - are veils automatically  abut-In
              when the pressure exceeds the safe UnltT

       (15)  Are all pipelines protected by corrosion
              prevention  systems?
  mi Testing and inspection of Uu pol-
lution prevention equipment and systems
at the laclllty should be conducted by Utt
owner or operator on a scheduled  peri-
odic bail* commensurate with tbe  com-
plexity, condltloni and clrcunulancoi of
the facility or other appropriate regula-
            aurface and lubturfac* well shut-
         In valvei and device* In use at the facil-
         ity eliould  be  sufficiently described  to
         determine method of activation or con-
         trol, e.g.. pressure differential, change In
         fluid or flow condition!, combination at
         pressure and flow, manual or remote con-
         trol mechanUnu. Detailed record*  for
         each well, while not necessarily part of
         the plan ihould be kept by the owntr or
         operator.
           (ill)  Before drilling below any cailng
         airing, and during workover  operation!
         a blowout preventer (BOPk assembly and
         well control system  ehould be Initalled
         that U capable of controlling any well-
         head preuure that U expected to be en-
         countered while that BOP auembly U
         on the well. Gating and BOP installation*
         ehould be In accordance with BUle reg-
         ulatory agency requirement*.
           <«U> Extraordinary well control meai-
         ure* ehould be provided ihould  emer-
         gency  condition*. Including Or*', loe* of
         control and other abnormal condition*.
         occur. Hie degree of control tyttem re-
         dundancy should vary with haunt  ex-
         posure and probable  consequence*' of
         failure. It U recommended that aurtac*
         •hut-In *y«tem* have redundant or "fall
         clo«e" valvlng. Bubiurface safety  valve*
         may not be needed  hi producing well*
         that will not flow but ehould be Installed
         a* required by applicable BtaU regula-
         tion*.
           (xil!> In order that there  will  be no
         mleundentandlng of Joint and separate
         dutle* and obligation* to perform work.
         In a safe  and pollution free  manner.
         written Instruction*  should be prepared
         by the owner or operator for contractor*
         and subcontractor*  to follow whenever
         contract activities  Include servicing  a
         well or systems appurtenant to a weU or
         pressure veaacl. Buch  Instruction*  and
         procedure* ihould be maintained  at the
         offshore production  facility. Under cer-
         tain circumstance* and conditions such
         contractor activities may require  the
         presence at the facility of an authorised
         representative of the owner or operator
         who would Intervene when necessary to
         prevent a spill event.
           Ulvk Air manifolds (headers) should
         be equipped with check valves on Indi-
         vidual flowllue*.
  Uvt  It the shut-in well pressure  I*
greater than the working pressure of the
Bowline and manifold valve* up to and
Including the header valve* modeled
with that Individual  Oowlloe. the flow-
line should be equipped with a high pre*-
•suro sensing device and shuUn valv*  at
the wellhead unless provided with a pres-
sure relief system to prevent over pres-
suring.
  a
faculty should be protected from corro-
sion. Method* used,  such a* protective
coaling* or cathodlo protection, should
be discussed.

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          OIL DRILLING/WORKOVER AND  PRODUCTION - OFFSHORE  (Concluded)
             40 CFR  PART 112.7
                                                                                   YES
NO
               (16)   Are submarine pipelines  protected from stresses
                      (waves,  fishing  lines, etc.)?

               (17)   Are submarine pipelines  in good operating condi-
                      tion and Inspected on a  periodic basis for
                      failures (if it  is impractical to visually
                      Inspect  - do they have a statistical  prevention
                      program?)
         (xvll) Bub-mnrlne pipelines ttppinten-
       ant to the facility should be adequately
       protected against environmental stresses
       and  other activities such as Ashing
       operations.
         (nv'.'M. Sub-marine pipelines appurten-
       ant to the (acllkty should be In good

       operating condition at «X\ times ana m-
       epected on a scheduled periodic basis for
        failures.  Buch  Inspections  should be
        documented  and  maintained at  the
        facility.
          Discussion:
00

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                                          FACILITY OPERATION
                                                                                                                        AO CFH  PAHT 112.7
Inspections and Records

A.   Hie required  inspections follow written procedures.

B.   The written procedures and a record of inspections,
     signed  by the appropriate supervisor, are  included
     in the  8POO -'—

Discussion!	
                                                                                              YES
                                                                                                      NO
oo
Cn
                         flecurity
                         A.  Plant* handling or  (taring oil are fenced.
                         B.
                         C.
    Entrance  gatea are locked and/or guarded when
    the plant ia unattended or not  in production.

    Any valvea which  pernlt direct  outward flow  of
    a  tank's  contents are  locked closed when in  non-
    operating or non-standby status.
                         D.   Starter controls on all oil pumps  in non-operating
                              or non-standby status are  locked or electrically '
                              isolated in the "off position.
                         E.
    H»o  loading/unloading connections of oil pipe-
    lines are  capped  or blank-flanged when not in
    service or on standby service for extended
    periods.
                                                                                                                  <•> iMpulloat *«d record*. Inapee-
                                                                                                                 Uon* required bjr Ibla part ehould U In
                                                                                                                 accordance with arrUUn procedural do-
                                                                                                                 Teloped fur the facility b» the owntr or
                                                                                                                 operttar. lluw wrlltao piocMturu uid
                                                                                                                 • record of lit* liupcoUoiu. ilfned bf UM
                                                                                                                . tpproprul*  nitxrTbor  or lotpeclor.
                                                                                                                 diould be niMl* p«rt of uu BPCO Plan
                                                                                                                 •nd mtluUlued for *  ptrlod of litre*
  (I) Security leicludtii tU ftaiuoHatt
/oclllllMt. U> All plwU handUof. proc-
tMlnf. uid itoriui oil ihould b*  fidlr
fenced,  luid'enlnnct (tie* (liould b*
locked and/or fiurded when the plaol
U not la production or b unalUndtd.
  Ill) Tlw muter flow and drain val»c*
and any olhar «al«e* that wtll permit
dlioct outwud flow of UM taukl con-
Uiit to Ibe turfaoa ahould ba tocuraly
lacked la lit* cloedU pMllloa  wlien In
naa-o|i*raUii« or non-ilandbr lUtuei
  flllk lit* (tarter control on all oil
pump* aluiuM  U locked In the  -oO"
potJUoa or located at a til* aeceulbl*
only to aulhorUtd penonnal •ben u>*
punipe u«, la * oan-opeiaUn( or con-
tlandbr ilalu*.
  Ill) Tlw loedlni/unloadlDf connec-
tloni of oil pipeline* aluuld b* aecunlf
capped or blank-Hauled •ban nut to
aenlce or elaoiiby eervk* for an at-
tended  lUue.  TliU eecurtiir  praoUce
ahould alao apply to ptptllnM that ar*
emptied  of  liquid tonltal either b»
dralnlni or b» Inert |U pmeura.

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                             FACILITY OPERATION  (Concluded)

              F.  Deacription of the lighting around the facility:
              Discussions
oo
ox
Personnel; Training and Spill Prevention Procedure!

A.   Personnel are properly Instructed In the followIngi

     (1)  Operation and  maintenance of equipment to pre-
          vent oil discharge*, and

     (2)  Applicable pollution control law*, rule* and
          regulations.

B.   Spill prevention briefings  for the  operating  per-
     sonnel are conducted on a scheduled, periodic basis.
                                                                                YJa     no
                                                                                                         40 CFK I'AHT  112.7
  lit Facum lignum niouM U con-
meiwirUa »IU> Uw trp* tod location ol
th* IftcUHy. CMukUrellaa *lioulfl  b*
•ticn tar I/O Hteovery  ol *plll* oo-
currinf during boon ol dufciuu. both
bjr opeitgnc berunoel. U pnunl, anil
bl nau-oMUUn|r ptrwuuol lUw tta-
cnl putolta,  ti>al italic*. *lo.t uxl (B>
pnnntlao at wU)> .occurring Uuauib
•cb al fr-vUllH,!,
  oai ffwmut  Katoin«  and ,t*u
pr«iKp|(w mtytttVM, «J> Owiitu or op-
onion *M rMpomlbta i« prapcriy ta-
otrucUui Ui*H IM»UUI«| la lit* opwtUoa
uiii uikluUtu-uc* ol wjulpmwil la pn-
vcnt Ih* dUeliuiM ol all M>4iin>Uc*J>U
polluUaa«Bnln>l Uwi. rolM M4.r*fUlit-
HOIU.
  (Ilk Each  »pBllc*l>l* tKlllIf  ihoulil
lutv* k dml«D4Ud twnoa who U Koaunt-
kUo lor all «i>UI pmakUNl *nd «*>o ro-
parU to Un* muugmuDt.  .
  (III! Ownon  or  oiMnlan  (Itould
•cliedul* i *ad •aoodi^fl o41l nmtntlaa
brioflnto 4*1 Ihclr. aptnUdf p*nonn«l
•t InUrvtlt  Irtqixut'Iaouih la uur*
»doQu*t*.tv>ilniUn4b>s'ol Ik* OKM.
Hui iJi-.ltalt IwDII*. «**; brt«ftni*
              Fully describe methods and  schedules  for above:

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                                APPENDIX  D

                         REPORT OF SPCC INSPECTION


     This appendix contains all the SPCC Inspection and Documentation Report
Forms to be filled out by SPCC Inspectors:

     A.  SPCC Inspection Field Sheet (two sides) - EPA Form 7500-53

     B.  SPCC Inspection Summary Sheet (one side) - EPA Form 7500-52

     C.  Detailed SPCC Documentation (eight sides) - EPA Form 7500-54

     Instructions for A. are on its side two, while instructions for C. are
on its side eight.  These report forms are available at the EPA Regions.
                                     87

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A. SPCC INSPECTION FIELD SHEET
( To be completed if SPCC Regulation is applicable to Facility • see 4QCFR Part 112.1.)
I*. NAME OF FACILITY
1C. FACILITY LOCATION
20. NAME Of OWNER AND/OR
OPERATOR RESPON9I8II.E FOR FACIUITY
ZC. MAIUINC ADDRESS
SEE
INSTRUCTIONS
ON REVERSE
IB. TYPE OF FACIUITY

26, TELEPHONE NUMBER
Anta Cod*
( )

3. TYPES Of Oik. STORED AND CAPACITY Of ABOVEaROUND AND BURIED STORAGE.
4. IS A CERTIFIED SPCC PI. AN
». NAME ANO REGISTRATION
AVAICABkE FOR INSPVCTIONt Qycs QNO
NUMBER OF CERTIFYINS ENGINEER Q NOT AWAIUABCE
9. DATE OF INSPCCTION
7. OATS Sr»CC PUAN WAS
cxRTinso QMOT AVAIUABU.C
«. IS SPCC PLAN FULLY IMPUEMSNTEOT (An til* ttcmt caited (or In eh* Plan in t/ic inttrcit oftpM pnvtntlon actually InttalltA • if obtervablef)
QNOT APPI.ICA>I.E
DOWNSTREAM (If known)

1 0. COMMENTS llncludf comment* fry owner/operator • writ* on tee* or attack txtra thtttt if n**d»d)
i ta. SPCC NO.
1 Ib. CASE NO. 11C.NPO
128. INSPECTOR (Ugn>
t3 rtO. |_Jf^oT AVAIUABUa
1 2O. DATE
1ZC. INSPECTOR (pnnti
EPA Form 7500-53 (9-80)
                                                           89

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                                                               INSTRUCTIONS
       1.   Tracts name of facility and its precise location, using geographical latitude and longitude if necessary.
       2.   If owner and operator are different persons, give information for both. State relation between them • is operator assignee, leases, or
           employee? Who is responsible for SPCC?
       3.   Note capacity and whether tanks are full or not. Note tanks which store alternate oils. Check lube storage • whether buried or above-
           ground (latter mora likely).
       4.   Note adequacy  of Plan; if inadequate, state specific defects. Use 10. below for details.
       5.   Actual date of visit to facility.
       S.   Include state in which engineer is registered. If Plan was amended and the amended Plan certified by a different engineer, list information
           for all engineers.
       7.   List for original Plan and any amended Plans.
       3.   Summary of deficiencies in Plan implementation. Discuss this with operator and record his opinions and comments in 10. below.
       9.   Specify distance and direction to nearest named stream, river, lake, bayou, estuary, etc. which will receive runoff from the facility.  If
           facility runoff goes to storm drain, ultimate receiving water should be named.
       10.  Space for comments by inspector and operator. Inspector should briefly list SPCC equipment actually in use at time of inspection,  if
           facility was not in compliance, inspector should include expected dates of Plan preparation and/or implementation.
       11.  SPCC No. refers to national EPA Data Bank. Case No. refers  to Regional EPA designation.
       12.  Date on which Field Sheet was actually completed.
 to. COMMKNTS (connnutct from other tide)
EPA Form 7500-53 (9-80)          REVERSE
                                                                   90

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                                            B. SPCC INSPECTION SUMMARY SHEET
I SPCC NO.
                                             CASE NO.
                                                                                         DATS Or IN3PCCTlQr>
  lAME OP INSPECTOR (Signature)
                                                                                         DATE OP OOCUMBNTATION REPO-RT
 NAME OP INSPECTOR (Print)
                                                                                         NPOBS NO.
                                                             1. FACILITY
 a. COMPANY
 ADDRESS
                                                                                                 TELEPHONE
                                                                                                          ZIP CODE
 PACIUITY NAMS
 b. PAC1UITY LOCATION
 PARENT CORPORATION
 AOORE9S
                                                                                                          ZIP CODE
 C. WATER 800V PROTECTED
                                                             2. PURPOSE
 INITIATION: j_|Routine Surveillance   '    QCoast Guard Information
           Qj Spill Report    Q Citizen Information   i~1 Other Itoecifvl:
             J Plan Preparation
             1 Follow-up
Plan Implementation
Plan Amendment
                                                           3. INFECTION
 INDIVIDUAL. CONTACTED
 INDIVIDUAL. CONTACTED
                                                                                        TITLE
 NOTIPICATION
                           4. FINDINGS
                             3, ATTACHMENTS (None required if facility in apparent compliance!
 SOURCE IN APPARENT COMPLIANCE WITH SPCC REQUIREMENTS:
           Qj Have adequate plan
           Qj Not subject to regulations
                 Q Insufficient storage
                 Q No reasonadla spill expectation
           PjPlan fully implemented
           Q New facility operational less than 6 months
     DNO
           Q No plan
           Q Plan not properly certified
           [j Plan does not have management approval
                  not maintained at facility manned 8 hrs/day
              Inadequate plan (detai/9d SPCC ftan review artxhed)
                  not fully implemented
           FlPlan not reviewed within 3 years
                             •Detailed Observations
                             •Photographs
                             Slides
                             Map
                             •Field Drawing
                             •Comments
                             Telephone Conversations
                             •SPCC Plan
NONE  ATTACHED  ALREADY ON PILE
  D        G              a
  a        a              a
  a        a              a
  a        a              a
  a        a              a
  a        a              a
  no              D
  a        a              a
                             •(ALL  REQUIRED IF  FACILITY  IS  NOT IN APPARENT COM-
                            PLIANCE. If photos not permitted, check "None" and explain. Add
                             "SPCC Plan " to List of Attachments when appropriate.!
     l_| Other
 EPA Form 7500-52 (6-80)
                                                                  91

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                           C. DETAILED SPCC DOCUMENTATION
     SEE
INSTRUCTIONS
  ON PACE a
FACILITY
                                                                                 OAT* Or INSPECTION
                                            1. FACILITY DESCRIPTION
I a. TYPE OP BUSINESS/OPERATION
1C. FACILITY OIU STORAGE
1C. PRCVKNTION MEASURES PROVIDED
Id. APPEARANCE Of FACILITY
t«. PAST SPIUU HISTORY
EPA Form 7500-54 (9-801
                                                                                                     PAGE I OP a
                                                     92

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                                              2. RECEIVING WATER (should a spill occur)
Za. NAME AND/OR DESCRIPTION
    Q Perennial         CD' ntermirtent
    Q Water present at time of inspection
    Q Inspector traced discharge to receiving water
    Q Inspector traced apparent drainage path to receiving water
    I"") Receiving water identified by company representative
    l~|Receiving water identified from topo maps
        eceiving water identified by other means Ispocifyl:
zt>. PHOOABUS ruow PATH TO RECEIVING WATER
1C. CUIMATIC INFORMATION  PROM OWNER/OPERATOR
EPA Form 7500-54 (9-801                                                                                                 PAGE 2 OF s
                                                               93

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                                                       3. COMMENTS
EPA Form 5700-54 (9-80)
                                                              94

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                                                 4. SPCCPLAN REVIEW
EPA Form 7500-54 (9-80)                                                                                      PASS 4 Of a
                                                         95

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                          5. SPCC AMENDMENT RECOMMENDATIONS (Amendment Insoectiont only I
EPA Form 7500-54 (9-80)                                                                                    PACE son
                                                        96

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                      6. FIELD DRAWINGS (Attach more sheen if needed, and show north arrow or other orientation)
FACILITY
                                                                                             INSPECTION OATS
INSPECTOR
EPA Form 7500-54 (9-80)
                                                                                                                 PAGE 6 OF t
                                                             97

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7. PHOTOGRAPHS (Attach more sheets if needed 1
SUBJECT
PHOTOGRAPHER
WITNESSES
O ATE/TIM ^DIRECTION
SUBJECT
PHOTOGRAPHER
PACIUITY
WITNESSES
WITNESSES
CAMSR A/ PI UJV1/ ATTACHMENTS
FACILITY
WITNgSSSS
WITNESSES WITNESSES
DATE/TIMB/OIRECT1ON
CAMERA/FILM/ ATTACHMENTS
                                             ATTACH PHOTOGRAPHS HERE
EPA Form 7500-54 (9-801
                                                       98
                                                                                                     PA«« 7 OF I

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                                                              INSTRUCTIONS
         Page 1:   FACILITY DESCRIPTION
                  (a) Make detailed in narrative style: use extra sheets it needed.
                  (b)  Include all storage; indicate capacity and actual amount and type of oil in each tank, including tanks not in use • above-
                  ground or buried.  Indicate percent of oil in mixed storage  and  annual throughput where possible. If this information is
                  included on attached drawing or lists, state this here.
                  (c)  Describe all  types  and adequacy of prevention measures • dikes, catchment areas, drainage systems, separators,  tank
                  level alarm systems, drainage pumps, etc. Describe major security  measures taken - locks, guards, fencing, etc.
                  (d)  Describe maintenance at facility. Use such terms as "neat and well-maintained",  "messy and poorly maintained" etc.
                  Describe any unsatisfactory maintenance such as oil pools, broken dikes, etc.
                  (el Obtain statement about past spills at this facility; observe drain controls: look for evidence of past spills.

         Page 2:   RECEIVING WATER
                  (a)  This  should  be a recognizable river,  stream, lake, estuary, etc. which can be expected to contain water at least part
                  of the year.
                  (b)  Explicitly describe, using approx. distances in meters or kilometers (feet or milei). all of the drainage paths from facility
                  to receiving water or storm drain in (a).
                  (c) Add here any statements obtained about annual rainfall, runoff, flooding, etc.

         Page 3:   COMMENTS
                  Describe soil  conditions  as they relate to spill  runoff and  whether spills have a reasonable chance of reaching drainage
                  channels, storm  drains or waterways. Obtain statements  from owner/operator which  indicate whether the person is aware
                  of 40CFR 112.

         Paga 4:   SPCC PLAN REVIEW
                  State whether facility has an SPCC Plan and whether it  is adequate. Describe in detail any inadequacies in SPCC Plan or
                  its implementation. Include references to pertinent paragraphs of  Spill Prevention Regulations.

         Page 5:   SPCC AMENDMENT R ECOMMENOATIONS I Amendment Inspection only)
                  Describe areas of past and potential oil spills and corrective actions, preventive measures and countermeasures carried out
                  in facility. Based on your inspection, will these features of the  post-spill SPCC Plan adequately  minimize the possibility
                  of recurrence? Why? if not, state recommendations for SPCC Plan amendments in detail - attach quantitative information,
                  drawings, etc.

         Page 6:   FIELD DRAWINGS (attach more sheets if needed and snow north arrow or other orientation}
                  Show:   all major features with spill potential  requiring spill  prevention measures; all drainage features  that relate to
                           potential spills, such as catch basins, storm drains, channels, ponding areas, dikes, sumps, etc.; the appropriate
                           distances in meters or kilometers (feet or miles! along  drainage paths from spill potential areas to water course
                           or water body in 2(a).

         Page 7:   PHOTOGRAPHS (attach  more sheets if needed!
                  Show inadequate SPCC features, spills, poor maintenance, proximity to waterways, and so forth. Mount photographs on
                  page 7; attach more sheets if needed.
EPA Form 7500-54 (9-80)
                                                                    99
                                                                                                                                    • Of a

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                   APPENDIX  E.   EPA-SPCC DATA BANK FOEMS
                                                                                                             HIT' ;*
                 U.S. ENVIRONMENTAL PHQTSCTICN AGSNO'
                 OIL AMD SPECIAL MATERIALS CONTROL DIVISION

                         FACILITY  IDENTIFICATION
                                    (Form A)
                      NOTE
                Alt non»chaded
                areas must  cantata
                an entry.
                                                                                                  0. FOR CONTROL USE ONLY
  This form is to be completed in  conjunction with other Oil and  Special Materials Cantroi Division forms or singly where no SPCC
  number has been assigned or an SPCC number is unknown.  Eater the Locator Code.  It consists of the first five alphabetic charac-
  ters of the Facility Name, followed by the Zip Code for the Facility Site (lor of/shore lacilitiea the Zip Code portion  should  ba
  zero lilted.).
 1«- LOCATOR CODE ANO LOCATOR ZIP
               (ZIP cooei
                                         b. START-UP OATS
                                              7      /
Enter this date
if it is later
than 01/10/74
                                                  3A-V
                C.MAS THE NAME OP THE FACILITY CHANGED
                  WITHI_M_ THE LAST YEAR (Yft. or No)   _
 • . MAS TM« LOCATION Of TMC FACILITY CH AMOCO WITHIN LAST V KANT (T»« OT Ha)
 2. TMK FOLLOWING INFORMATION IS RELATED TO THE FACILITY;
                                                                                     b. TY»C IS A»jr PABT 0» THC FACILITY
                                                                                        NON'TflANSPONTAriON RKLATCO*
                                                                                               (T«« or Hot
 e. STATC
              COUNTY
                                                       •. CITY
               LOCATION

   f. LATITUOC         ». LONCITUOC
                                           h. SUBVCY OC1CRIPTION
                                        w
                    U TOTAL JTO»AO« CAPACITY O»
                      » ACILITYfln t*llen*>
                   fi
   ace  MI
              SBC
                              MIN   SKC
L3
 3. THE FOLLOWING INFORMATION IS RELATED TO THE OWNER/OPERATOR
 «. NAM8
           AOOnci* C$tr««()
 c. CITY
                                                                  d. STATC    •. ZIP
 r. TSLXPMONC
 4. THE FOLLOWING ARE DIRECTIONS TO FACILITY SITE (Option*! — IS "artU or !•••)
SPA f*tm 7SOW3
                                    PNCVIOUS COITION MAY  sc usca
                                                         101

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                      U.S. SNVIRCNMENTAL PROTECTION AGENCY
                    OIL ANO SPECIAL MATERIALS CONTROL DIVISION

                       INSPECTION/ENFORCEMENT REPORT
                                    (Form E)
                                                                                           RIN 75JO-I5I
                                                                              a FOR CONTROL USE ONLY
I.  SPCC NUMBER
                   U the SPCC number a not entered,
                   complete the Facility Identification
                   Form.
                                                   2. DATE OP INSPECTION
                                                    MO
                      A     A
                                                           DAY
                                                                  YH
3. HAS AN INSPECTION/ENFORCEMENT REPORT BEEN PREVIOUSLY COMPLETED FOR THE DATE OP INSPECTION (aoovcl?

  D YES   O NO (if answer is "Yes" - complete No. 5, if applicable, then skip to No. 12.)
                                COMPLETE ALL APPLICABLE SECTIONS BELOW
4. *. INSPECTOR'S LAST NAME
                                                   B. INSPECTOR'S ORGANIZATION
S. SPILL I.O. (if inspection result ofspui)
                ft. ESTIMATED NUMBER MAN-HOURS INVOLVED IN INSPECTION

                           (whole hounf
7. IS PAC1UTY SUBJECT TO PART 1127
  DYES   Q NO (If answer is "No" - complete No. 3 then stop)
                                 COMPLETE ALL APPLICABLE SECTIONS 3ELOW
3. PURPOSE OP INSPECTION

  A  O PLAN PREPARATION ONLY
3 D PLAN PREPARATION ANO IMPLEMENTATION
9.
  A  Q PREVIOUS VIOLATION CORRECTED

         (If 9A or B is checked - STOP HERE.)
       B O.NO VIOLATION POUNO
10. VIOLATION coOE/R6FERRAUf7//0isc/iec*ed - 11. is required.)

  Violation Code (check as many as three):

  Z   tt  Failure to  prepare any  SPCC Plan

  A   U  Failure to  prepare an SPCC Plan in accordance  with 112.7

  3   O  Failure to  have SPCC Plan  certified as  required by 112.3(d)

  C   /~7  Failure to  implement SPCC  Plan

  0   £17  Failure to  submit  information after triggering spill  as  required by  112.4(a)

  5   £17  Failure to  amend plan as required by 112.4(d)

  F   ry  Failure to  implement amendment as required by  112.4(e)

  G   /~7  Failure to  amend,  certify  or implement  after facility  change  as required by
             112.5(a)

  H   /"7  Failure to  review,  amend,  certify or implement as required by 112.5(b)
 I. SEPERREO TO ENFORCEMENT/0
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                           ENFORCEMENT INFORMATION (Complete any/all sections below if possible)
 12. DATE NOV ISSUED (by enforcement)
        I/I  I  I/I
    MO     DAY    YH
PINE PHOPOSSO (by enforcement)
                     (whole dollars)
 14. DATE PHE-HEAHING CONFERENCE H6LO
                                                 19. OATS HEARING HELD
        \A\\A
    VTYTA
    MO     DAY    YH
                                                    MO     DAY    YH
                                                                                 16. DATE HEARING APPEALED
\A\   I/I
                                                                                    MO     DAY     YH
 7. DATE FINS COLLECTED
                                                 18. ACTUAL FINS COLLECTSO

    MO     DAY     YH
                                                                         (whole dollars)
                                              THIS WOULD CLOSE CASE
 9. COMMENTS (uptsonai - 10 Una or lea. of not more than 60 characters each)
EPA Form 7500-15 
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                                                                                                                     RET 7550-151
 ji. SPILI
 ^fc SPIL
ml
                          OIL ANO SPCC1AI. MAT CHI A Li CONTROL. QIVI3ION
                                        SPILL REPORT
                                            (FORM S)
                                                                                                 O. rQH C3NTP.3L USE 3NLY
1. SPILL. IDENTIFICATION
   SPILL IO NO.
            I     I     I  I   I
                                 *r*tt
                                                  b. SPCC NO.
(T/ fft« SPCC num6«r i* nac
«nr»r»rf. cempltts Ota ?*citltr
Identification Form,)
                                                                                                C. NPO2S NO. a/ «!>t>tlco6t*)
               S ORGANIZATION (RO)
   d. RO NAME (Actvmllr emu*iat tpilt)
     MAILING AOO2E35
  J. CITY
                                                                   ^STATS
                                                                           h-ZlPCOOC
  i. TCUCPM9NC NO.
  2. LOCATION OF SPIL.L
 a.RSCION &.STAT2   e. COUMTY
                                                                   d. CITY
  SSOGRAPMIC LOCATION
 C. UATITUOC-MORTH £. bONaiTUOC-WCIT  g. SUMVSY
    OKS  MIM   ice     DCS MIN   J«e
                                           i    t
                                           CT SgCT
                                                    IKCT  TOMNSHIV
  h. OtHKCTIONa TO SVfUL IIT*
  3. SPILL INFORMATION
   a. SPILL OAT:
         a*"   V*
                                                    OATB AftSPTCTIMS   e. «S
                                                             HH   Mll
   C. REPORTERS TSL£PKONE NO.
                                      f, REPORTER'S ORGANIZATION
                                                                          h. GENERAL WATER 3OOY fCft»e*
                                                                             INLAND
                                                                             COASTAL
                                                                                                         SB CAT
  i. SPECIFIC WATER
                               on* anlr)
    RIVCft
                                                  I   OPCN WATKM
                                                                             [T8MMINAU (OOCJC)
    STMCAM fCf*»k)
                             PONO
                                                     •AY ffftamrr or Sound}
                                                                                                        I TRlauT«RV
                                                     (•OUT (Hftbcr Ar»»t     I   ICAMAL
                                                                                                       NONC
     UTER aoor NAME
                                                     n
                                                         Sc. RIVER MILE INOEX (II xmm)
                                                                                             jp     (Page 1  of  2)
 SPA Form 7500-13 (R«»- 1-77)  PREVIOUS S3ITION IS OBSOLETE.
                                                                                                           (Continued on rev«rsa)
                                                               105

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 5. REFER TO USER'S MANUAL FOR FOUR OtSIT COOES
                                                                   S. CO SPILL REQUIRING SPA SUPPORT fCh.cit 4a/o»J
                -rf/4/f et»«l»)
   a. SPILL
      SeuMCS
                                         99" eetf*
                                                                               T PARTICIPATION
                                                                            TSCHNICAL  ASSISTANCE
                                                                            OAMASC ASSSSSMKNT/RSSTOMATION
               (4-4fllt eat!*)
   b. 3PILL
      CAUSE
                                     (II "99" cod* *t>*clir>
         USS Of OISPCRSANTS
      J   | CHECK HERE If SPILL OCCURRED UNDERGROUND
                                                                     e.
                ) S P A MAN-MOUMS INVOL.VS9 A9OVS
   RSCIONAU RESPONSE TEAM fCJwe* on.)
9. CLEANUP ACCOMPLISHED (fvndf* br)
          RRT NOT ACTIVATRD
                                                                                      SOVCRNMCNT
          BUT TCLCPMONC ACTIVATSO
                                                                            STATK aOVSRNMgNT
          BUT A3SSM«LCO
                                                                     d.
                                                                            OTHCH
  . EPA SPILL RSOUIPING 3ESIONAL RCSPONSS
                                                     6»/o«r)
                                                                   Iff CLEANUP COSTSfn Anown;
          OSC »MYSICALL¥ ON SCSNK
                                                                                      IN WMOLS OOULAH3
          OSC MONITOKSO 9V PMON8. STC.
          EKT ASSISTANCS
          OAMACC ASSCSSMKNT/RSSTOnATION
11. C3 FINES COLLECTED (S3 Jnd 34 rie<«l

                   IN WHOLE SOLLAM3
                   MCeiONAL MAN-MO UBS INVOLVSO AEOve
 12. COMMENTS (Including r*mor*l aitttott)
                                                                                                        (Page  2  of  2)
SPA
          7500-13 (S«». 1-79) (Hs»«>«)
                                                                 106

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                                  GLOSSARY

Amendment inspection:  An inspection conducted under provisions of
     40CFR112.4 by which EPA may require an amendment to a facility's SPCC
     Plan following a triggering spill.

Annulus or annular space:  The space between the drill stem and the wall of
     the hole or casing.

Assessment:  An initial monetary penalty prescribed for infractions of oil
     spill or spill prevention regulations.

Barrel:  42 United States gallons at 60 degrees Fahrenheit.

Bilge:  Stagnant, dirty water that gathers in the rounded, lower part of a
     ship's hull.

Blowout:  A wild and uncontrolled flow of subsurface formation fluids through
     an oil or gas well.

Blowout preventer (BOP):  A device to control formation pressure on an oil or
     gas well by closing the annulus when pipe is suspended in the well or fay
     closing the top of the casing at other times.

Breakout tank:  A tank along a pipeline utilized for intermediate storage.

Brine:  Water saturated with or containing a high concentration of salt or
     salts; also, any strong saline solution containing such other salts as
     calcium chloride, zinc chloride, calcium nitrate.  The term may be used
     to describe water produced with crude oil from a well.

Bulkhead:  A wall or partition holding back earth, fire, fluids, etc.

CFR:  Code of Federal Regulations.

Cantilever:  A projecting beam or structure anchored at one end extending
     over a space, designed to bear loads.

Casing:  Large steel pipe used in an oil or gas well to "seal off" or "shut
     out" water and prevent caving of loose gravel formations when drilling
     and producing.   When the casings are set, drilling continues through and
     below the casing with a smaller bit.  The overall length of this casing
     is called the string of casing.  More than one string inside the other
     may be used in drilling the same well.
                                      107

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Centrifuge:  A device for the mechanical separation of solids from a liquid.
     Usually used on weighted drilling muds to recover the mud and discard
     solids.  The centrifuge uses high-speed mechanical rotation to achieve
     this separation as distinguished from the cyclone-type separator in
     which the fluid energy alone provides the separating force.

Christmas tree:  Assembly of fittings and valves at the top of the casing of
     an oil or gas well that controls the flow of oil or gas from the well.

Circulate:  The movement of fluid in a well drilling or workover operation
     from the suction pit through pump, drill pipe, bit annular space in the
     hole and back again to the suction pit.

Closed in:  A well capable of producing oil or gas, but temporarily not
     producing.

Compliance inspection:  An inspection of a facility to determine the exist-
     ence, implementation, and certification of an SFCC Plan.

Core:  A sample of material taken from a well by means of a hollow drilling
     bit.  Cores are analyzed to determine their water and oil content, por-
     osity, permeability, etc.

Cracking:  An oil refining process of breaking down hydrocarbons into lighter
     hydrocarbons of lower molecular weight.

Cut oil:  Oil that contains water, also called wet oil.

Cut:  Term used in refining to designate a component or narrow boiling range
     fraction of crude oil.

Dash pot:  A mechanical dampening device.

De-emulsifier:  Breaks up water-oil emulsion.

Dessicant:  A drying agent.

Development well:  An oil or gas well drilled for production from an estab-
     lished field or reservoir.

Disposal well:  A well through which water (usually salt water)  is returned
     to subsurface formations.

Diversionary structures:  (Figures B-3 and B-6)  Devices that divert flow
     from one area to another, such as ditches, pipes, culverts.

Drill pipe:  Special pipe designed to withstand the torsion and  tension loads
     encountered in drilling.

Drilling mud:  A suspension, generally aqueous, used in rotary drilling to
     clean and condition the hole and to counterbalance formation pressure;
                                     108

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     consists of various substances in a finely divided state, among which
     bentonite and barite are most common.

Dump valve:  A mechanically or pneumatically operated valve used on separa-
     tors, treaters, and other vessels for the purpose of draining, or "dump-
     ing" a batch of oil or water.

Emulsion:  Combination of water and oil.

Enforcement activity:  Those actions taken by the EPA under the provisions
     of particular sections of the FWPCA.

Flowline:  Carries oil or gas from wellhead to first stage in processing.

Free flowing well:  A well which produces oil or gas without any means of
     artificial lift.

Freewater knockout:  An oil/water separation tank at atmospheric pressure.

FWPCA:  The Federal Water Pollution Control Act.

Gas lift:  A means of stimulating flow in an oil well by aerating the fluid
     column in the well with compressed gas.

Gas-oil ratio:  Number of cubic feet of gas produced with a barrel of oil.

Gathering line:  A pipeline, usually of small diameter, used in gathering
     crude oil from the oil field to a point on a main pipeline.

Header:  A section of pipe into which several sources of oil, such as well
     streams, are combined.

Heater-treatar:  A vessel used to break oil-water emulsion and separate oil
     and water with heat.

Knot:  One nautical mile per hour, equivalent to 1.15 statute miles per hour.
                       u
Location (drill site):  Place at which a well is to be or has been drilled.

Low flash crude:  Crude oil with a low ignition temperature.

Manifold:  A pipe with one inlet and several outlets or one outlet with sev-
     eral inlets used for collecting or distributing fluids.

Manway:  An opening large enough for a man to enter; a manhole.

Offshore facility:  A facility of any kind located in, on, or under the navi-
     gable waters of the United States, other than a vessel or public vessel.

Oil:  Any form of oil (e.g., animal, vegetable,  mineral)  including petroleum,
     fuel oil, sludge, oil refuse and oil mixed with wastes other than
     dredged spoil.


                                     109

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Oil shale:  A sedimentary rock containing solid organic matter  (kerogen) that
     yields substantial amounts of oil when heated to high temperatures.

Oil well:  A well completed for the production of crude oil from at least one
     oil zone or reservoir.

Onshore facility:  A facility of any kind located in, on, or under any land
     within the United States, other than submerged land.

Permafrost:  Subsoil that remains permanently frozen.

Permeability:  The permeability (or perviousness) of rock is its capacity for
     transmitting a fluid.  Degree of permeability depends upon the size and
     shape of the pores, the size and shape of the interconnections, and the
     extent of the latter.  The unit of permeability is the darcy.

Pig:  A device that is forced through a pipe to clean the pipe or separate
     materials flowing through the pipe.

Porosity:  The volume of pore space expressed as a percentage of the total
     volume of the rock mass.  The percentage or pores of interspaces forming
     the total bulk of the material.  The absorbent capacity of the material
     or the volume of liquid held by the pores.

Riser:  Vertical line between flowline and manifold.

Separator:  A vessel used to separate oil and gas by gravity.

SPCC:  Spill Prevention Control and Countermeasure (Plan).

Spill potential:  The total amount of oil that may be spilled at a particular
     time and place.

Sump:  Tank to collect fluids from drain systems.

Tank:  A bolted or welded atmospheric or pressure container designed for
     receipt, storage, and discharge of oil or other liquid.

Tank battery:  A group of tanks to which crude oil flows from producing wells.

Treater:  Gravity separation equipment used to break an oil-water emulsion in
     an oil field.

Triggering spill:  A spill of over 1000 gallons or the second of two report-
     able spills within 12 months at a facility subject to SPCC regulations.

USEPA:  United States Environmental Protection Agency.

Vapor space:  The space above the surface of a volatile liquid in a closed
     container.
                                    110

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Violation:  An infraction of provisions of Sections 311(b)(5), 311(b)(6), or
     ell(j)(2) of the FWPCA.

Viscosity:  A measure of resistance to flow of a liquid.

Water flooding:  In an oil field, water injection under pressure into the
     formation via injection wells to displace the oil toward the producing
     wells.

Well completion:  In a potentially productive formation, the completion of a
     well in a manner to permit production of oil or gas; the walls of the
     hole above the producing layer (and within it if necessary) must be sup-
     ported against collapse and the entry into the well of fluids from for-
     mations other than one producing layer must be prevented.  A string of
     casing is always run and cemented, at least to the top of the producing
     layer, for this purpose.  Some geological formations require the use of
     additional techniques to "complete" a well, such as casing the producing
     formation and perforating the casing to make entry holes, using slotted
     pipes, consolidating sand layers with chemical treatment, etc.

Well head:  Equipment used at the top of a well, including casing head, tubing
     head, hangers, and the Christmas tree.

Wildcat well:  A well in unproved territory.

Wireline:  Device which removes paraffin from the flowline.

Work over:  To clean out or otherwise work on a well in order to increase or
     restore production.

Work-over fluid:  Any type of fluid used in workover operation to control a
     well.  Drilling mud, diesel oil or salt water may be used.

"308 letter":  A letter written under authority of Section 308 of the FWPCA.
                                     111

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                                    TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing/
1. REPORT NO.

 EPA-6QO/ 2-81-Ml.
                                                            3. RECIPIENT'S ACCESSION»NO.
4. TITLE AND SUBTITLE
 Guide for Spill Prevention
 Inspectors
                            Control  and Countermeasure
5. REPORT OATH
   October 1981
                                                            6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)

  Walter Unterberg and Robert  M.  Moorehead
                                                            8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME ANO ADDRESS
  Rockwell International
  2421 West Hill crest  Drive
  Newbury Park, CA 91320
                                                            10. PROGRAM ELEMENT NO.

                                                             1 NE  823	
J_N£
11. COf
                                                                NTRACT/GRANT NO.
                                                             68-Q3-264S
12. SPONSORING AGENCY NAME ANO ADDRESS
 Municipal  Environmental Research Laboratory - Cin.,  OH
 Office of Research and Development
 U.S.  Environmental Protection  Agency
 Cincinnati, Ohio 45268
                                                            13. TYPS OP REPORT ANO PERIOD COVERED
                                                            Final
                                                            14. SPONSORING AGENCY CODE
                                                            EPA/600/14
IS. SUPPLEMENTARY NOTES
 Project Officer:  John S.  Farlow
                                        (201)  321-6631
16. ABSTRACT
      This  report is intended for  use  in training and guiding  inspectors performing com-
pliance  inspections and amendment inspections and documenting these inspections to imple-
ment  the Oil  Pollution Prevention  Regulations promulgated in  40CFR112 for nontransporta-
tion-related  onshore and offshore  faciliti-es.
      The report covers the SPCC regulations,  the role of the  SPCC  inspector, the affectec
facilities, and procedures for carrying out the inspection.   It contains forms for use b>
the inspector in the field and for documentation.
     The use  of these forms will provide nationwide uniformity in  SPCC  reporting.   Sug-
gested procedures  appear below in  short form, applicable to all inspections:
                          The SPCC  Inspector's 1-2-3
    In field  fill  out "SPCC Inspection  Field  Sheet" (1 page)  (EPA  Form  7500-53)
    If facility in compliance           If facility NOT in compliance
    Fill out  "SPCC Inspection Sum-      Fill out "SPCC Inspection Summary Sheet"
    mary Sheet" (1 page) only (EPA    •  (1 page) (EPA Form 7500-52)  and  "Detailed
    Form 7500-52).                      SPCC Documentation" (7 pagesTTEPA Form 7500-54).
    Enter  information in EPA-SPCC  Data  Bank:
      Form  A - Facility Identification
      Form  E - Inspection/Enforcement Report
      Form  S - Spill  Report (if required)
3 -
17.
                                KEY WORDS ANO DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.lOENTlFIERS/OPSN ENDED TERMS
              c. COSATI Field/Group
 Oils
 Pollution
 Prevention
 Counter-measures
 Inspection
                                               Inspector's Guide
                                               Oil Spill Prevention
                                               SPCC
18. DISTRIBUTION STATEMENT
    Release to Public
                                              19. SECURITY CLASS (Thit Report)

                                                UNCLASSIFIED	
              21. NO. OF PAGES
                118
                                              20. SECURITY CLASS (Thit page)

                                                UNCLASSIFIED	
                                                                         22. PRICE
SPA Farm 2220-1 (9-73)
                                           112

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