&EPA
           United States
           Environmental Protection
           Agency
           Industrial Environmental Research  EPA-600/7-80-004
           Laboratory         January 1980
           Cincinnati OH 45268
           Research and Development
Spill Prevention,
Control and
Countermeasure
Practices at Small
Petroleum  Facilities

Interagency
Energy/Environment
R&D Program
Report

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                 RESEARCH REPORTING SERIES

 Research reports of the Office of Research and Development, U.S. Environmental
 Protection Agency, have been grouped into nine series. These nine broad cate-
 gories were established to facilitate further development and application of en-
 vironmental technology. Elimination of traditional grouping was consciously
 planned to foster technology transfer and a maximum interface in related fields.
 The nine series are:

      1.  Environmental Health Effects Research
      2.  Environmental Protection Technology
      3.  Ecological Research
      4.  Environmental Monitoring
      5.  Socioeconomic Environmental Studies
      6.  Scientific and Technical Assessment Reports (STAR)
      7.  Interagency Energy-Environment Research and Development
      8.  "Special" Reports
      9.  Miscellaneous Reports

 This report has been assigned to the INTERAGENCY ENERGY-ENVIRONMENT
 RESEARCH AND DEVELOPMENT series. Reports in  this series result from the
 effort funded under the 17-agency Federal  Energy/Environment Research and
 Development Program. These studies relate to EPA's mission to protect the public
 health and welfare from adverse effects of pollutants associated with energy sys-
 tems. The goal of the Program is  to assure the rapid development of domestic
 energy supplies in an environmentally-compatible manner by providing the nec-
 essary environmental data and control technology. Investigations include analy-
 ses of the transport of energy-related pollutants and their health and ecological
 effects;  assessments of, and development of, control technologies for energy
 systems; and integrated assessments of a wide range of energy-related environ-
 mental issues.
This document is available to the public through the National Technical Informa-
tion Service, Springfield, Virginia 22161.

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                                           EPA-600/7-80-004
                                           January 1980
SPILL PREVENTION, CONTROL AND COUNTERMEASURE
  PRACTICES AT SMALL PETROLEUM FACILITIES
                     by

           Nicholas P. Trentacoste
              George R. Bierman
              James Cunningham
         Science Applications, Inc.
          McLean, Virginia 22102
           Contract No. 68-03-2032
               Project  Officer

             Frank J. Freestone
  Oil and Hazardous Materials Spills Branch
Industrial Environmental  Research Laboratory
          Edison,  New Jersey 08817
 INDUSTRIAL ENVIRONMENTAL RESEARCH LABORATORY
     OFFICE OF RESEARCH AND DEVELOPMENT
    U.S. ENVIRONMENTAL PROTECTION AGENCY
          CINCINNATI,  OHIO 45268
                                     EPA - RIP LIBRAJ

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                                DISCLAIMER
     This report has been reviewed by the Industrial Environmental Research
Laboratory-Cincinnati, U.S0 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 endorse-
ment or recommendation for use.
                                    ii

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                                  FOREWORD
     When energy and material resources are extracted, processed, converted,
and used, the related pollutional impacts on our environment and even on our
health often require that new and increasingly efficient pollution control
methods be used.  The Industrial Environmental Research Laboratory-Cincinnati
(lERL-Ci) assists in developing and demonstrating new and improved methodol-
ogies that will meet these needs both efficiently and economically.

     This study was made in response to the oil pollution prevention regula-
tion  (40 CFR 112) promulgated by the U. S. Environmental Protection Agency on
December 11, 1973.  The regulation covers spill prevention and control for
nontransportation-related, on-shore and off-shore facilities.  The measure
requires that owners and operators of affected facilities prepare and imple-
ment a spill prevention control and countermeasure  (SPCC) plan for each facil-
ity  (40 CFR 112.3(a)) and, further, that each Plan be certified by a regis-
tered professional engineer (40 CRF 112.3(d)).

     The purposes of this study were to identify SPCC practices at small
petroleum facilities, to determine technical problems as they related to spill
prevention and control at these facilities, and to devise alternative feasible
engineering solutions to overcome problems and assure compliance with the
regulation and guidelines (40 CFR 112.7)).
                                        David G. Stephan
                                            Director
                          Industrial Environmental Research Laboratory
                                           Cincinnati
                                     111

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                                  ABSTRACT


     A study was conducted of small petroleum production and petroleum prod-
ucts distribution facilities (stripper wells and bulk plants) to determine
ability to comply with the oil pollution prevention regulation (40 CFR Part
112).  Four regions of the United States were covered:  Texas/Oklahoma,
Louisiana, Penn-Grade (Pennsylvania, Ohio, Kentucky, West Virginia, New York),
and New England.  Field surveys were conducted at 125 individual facilities:
55 production facilities in the Texas/Oklahoma region, 15 production facili-
ties in Louisiana, 20 production facilities and 18 bulk plants in the Penn-
Grade region, and 17 bulk plants in New England.  The facilities themselves
were categorized into generic types, both within regions and across-the-board.

     Numerous technical problems were identified involving the ability of
these facilities to comply with the regulation and the techniques selected by
the owners and operators to achieve compliance.  The problems and compliance
techniques were evaluated for both appropriateness and cost.  The problems
were also screened and grouped in categories of problems most common to all
facilities, both by facility type and geographic area.  Engineering solutions
have been proposed for these most common problems, with emphasis on the most
cost-effective  solutions.

     Existing spill prevention, control and countermeasure  (SPCC) plans  (re-
quired  by the regulation)  for  the  facilities visited  were reviewed and
assessed  for adequacy if  the owners/operators made  them available.  Finally,
for the several  generic types  of  facilities identified, SPCC plans were
developed.   Each generic  SPCC  plan  serves as a  model  for  any facility  of  the
type covered and requires  modification only to  account  for  minor  variables
peculiar  to  a specific  site.

     This report was  submitted in fulfillment of Contract No.  68-03-2032  by
Science Applications, Inc.,  under the sponsorship of the  U.  S.  Environmental
Protection  Agency.   This  report covers  the period July  1974 through  January
1977.   Nearly all of  the  field work (surveys) was completed during the last
half of 1974, however.
                                      ±V

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                                  CONTENTS

Foreword	      iii
Abstract	       iv
Figures	       vi
Tables	        x
Metric conversion table 	       xi
Acknowledgments 	      xii

   1.   Introduction	        1
             The Oil Spill Prevention Control and Countermeasure
                Regulation	        1
             Scope of the Study	        2
             Objectives of the Study	        4
   2.   Conclusions	        6
             General Conclusions	        6
             Texas/Oklahoma Area	        8
             Louisiana Area	        9
             Penn-Grade Area	       10
             Bulk Plants — Penn-Grade/New England Area 	       11
   3.   Survey Methodology	       13
             Introduction 	       13
             Area Selection Procedures	       13
             Selection of the Four Survey Areas	       14
             The Area Surveys	       14
             Area Survey Summaries	       15
   4.   Results and Discussion	       16
             Introduction 	       16
             Texas/Oklahoma Area	       17
             Louisiana Area	       38
             Penn-Grade Area	       60
             New England Area	       92

Bibliography	      117

Appendices
   A.   Cost estimating data for engineering solutions to oil spill
             prevention and control 	      120
   B.   Sample of existing SPCC plans for the Texas/Oklahoma region .      123
   C.   Sample of existing SPCC plans for the Louisiana region. . . .      129
   D.   Sample of existing SPCC plans for the Penn-Grade region . . .      150
   E.   Generic SPCC plans for the Texas/Oklahoma region	      162
   F.   Generic SPCC plans for the Louisiana region	      166
   G.   Generic SPCC plans for the Penn-Grade region	      186
   H.   Generic SPCC plans for the New England region	      197

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                                   FIGURES
lumber                                                                  Page

   1   Geographic areas of Texas-Oklahoma covered by the survey	    18

   2   Typical  terrain features of West Central Texas and Southeastern
       Oklahoma (Area 1)	    20

   3   (a  & b)  Typical terrain features of East Central  Texas  (Area  2)  .    22

   4   (a  & b)  Typical terrain features of the  Southeast Texas  coastal
       plains (Area  3)	    23

   5  Typical  stripper well  facility  in Texas  and Oklahoma	    24

   6   (a  & b)  Typical scenes indicating poor facility housekeeping  —
       Texas/Oklahoma area	    26

   7  Typical  Texas/Oklahoma stripper facility tankage  arrangement.  .  .    27

  8   (a  & b) Variations of  the basic stripper well  facility —
       Texas/Oklahoma area	    28

      (c  & d) Variations of  the basic stripper well  facility —
       Texas/Oklahoma area	    29

      (e  & f) Typical  dikes  and firewalls  surrounding stripper well
       facilities —  Texas/Oklahoma  area  	    30

      (g  & h) Typical  dike that has been breached  (g) and unprotected
       area around storage  tanks  (h)  for  stripper well  facilities —
       Texas/Oklahoma  area	    31

      (i  & j) Inadequate security fencing  (i)  and no security fencing
       (j)  surrounding typical stripper well  facilities — Texas/
       Oklahoma area	    32

  9  Suggested drainage from firewall	    35

 10  Geographic areas of Louisiana covered by the survey 	    39

 11   (a  & b) Typical terrain features in Louisiana Area 1 —
       the Mississippi area	    41

      (c)  Typical terrain features in Louisiana Area 2 — the
       Mississippi Spillway	    42

                                    vi

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                              FIGURES (Cont'd.)

Number

  12  Typical terrain features in Louisiana Area 2 — the Vinton
        Field	42

  13  Typical terrain features in Louisiana Area 3 — Sabin National
        Wildlife Refuge vicinity	43

  14  Typical terrain features in Louisiana Area 4 — the Crowley
        Field	43

  15  Typical terrain features in Louisiana Area 5 — Avery Island
        vicinity	44

  16  (a & b) Typical containment structures built from surface soil
        in the Louisiana water areas	46

  17  Typical on-shore facility 	  48

  18  Typical water location facility 	  49

  19  (a & b) Typical water-based facilities in Louisiana 	  51

  20  (a & b) Typical barge-mounted production facilities in Louisiana.  52

  21  Typical arrangement where access road forms a breach in secondary
        containment dike	  54

  22  Consequences of a poorly designed salt water pit dike	54

  23  (a & b) Typical minimal leak protection at platform-mounted
        water-based facility	56

  24  Typical unprotected over-water piping at water-based facilities  .  57

  25  (a & b) Water-traffic-induced bank erosion at water-based
        facility (a) and typical bulkheads used to correct the erosion
        problem (b)	58

  26  Map indicating the Penn-Grade area surveyed	62

  27  (a & b) Typical urban area terrain in the Penn-Grade area ....  64

      (c) Typical urban area terrain in the Penn-Grade area 	  65

  28  Typical stripper facility arrangement in the Penn-Grade area.  .  .  66

  29  Multiple well stripper facility layout, West Virginia 	  67

  30  Multiple well stripper facility layout, Pennsylvania	68

                                     vii

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                              FIGURES  (Cont'd.)

Number

  31  (a & b)  Details (well location)  of multiple-well stripper
        facility in West Virginia (see Figure 29)	    70

      (c & d)  Details (storage tanks)  of multiple-well stripper
        facility in West Virginia (see Figure 29)	    71

      (e & f)  Details (well locations) of multiple-well stripper
        facility in West Virginia (see Figure 29)	    72

  32   (a & b)  Details (storage tanks and drainage pit)  of multiple-well
        stripper facility in Pennsylvania (see Figure 30)  	    73

      (c  & d)  Details (production well and storage tank)  of multiple-
       well stripper facility in Pennsylvania (see  Figure 30)	    74

      (e  & f)  Details (production well and drainage  pit)  of multiple-
       well stripper facility in Pennsylvania (see  Figure 30)	    75

 33   (a  & b) Details (water knock-out at storage tank) of a 60-well
       stripper  facility  in Pennsylvania 	    75

      (c) Details  (electrically operated  well) of a  60-well  stripper
       facility  in Pennsylvania	    	    77

      (d) Details  (disposal  Pit)  of a  60-well  stripper  facility  in
       Pennsylvania	    77

 34   (a & b) Details  (production wells and storage  tanks) of a  typical
       small off-highway/hillside production unit — Penn-Grade area  .    78

 35  Layout of a 75,000-gallon bulk station, Penn-Grade area 	    81

 36   (a & b) Views of a 75,000-gallon bulk plant — Penn-Grade area.  .    82

      (c) Views  (stream where boom is to be installed) of a 75,000-
       gallon bulk plant — Penn-Grade area	    83

 37   (a & b) A 41,000-gallon bulk plant on a steep hillside location —
       Penn-Grade area	   34

 38   (a & b) A 56,000-gallon bulk station in a valley between two
       hills — Penn-Grade area	   85

      (c & d) A 56,000-gallon bulk plant in a valley between two
       hills — Penn-Grade area	   86
                                   Vlll

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                              FIGURES (Cont'd.)

Number                                                                  Page

  39  (a & b) Bulk plant in a congested city area — Perm-Grade
        area.  This facility does not have any containment dikes
        around its tankage	   88

      (c & d) Bulk plant in a congested city area — Penn-Grade
        area.  Undiked area shown as well as drainage collection
        for facility	   89

  40  (a & b) A 149,000-gallon bulk plant located on a bluff — Penn-
        Grade area.  Dike construction shown around a new tank installa-
        tion	   90

  41  The New England survey area	   94

  42  (a & b) Typical bulk plant on squeezed-in site — New England
        area	   95

  43  (a & b) Typical bulk plant with ample space, but with terrain and
        drainage problems — New England area	   96

  44  (a & b) Fuel oil unloading dock and piping at a New Hampshire
        paper mill	   98

  45  (a & b) Small independent bulk plant in Maine	   99

  46  SPCC Plan Layout for a large independent bulk plant in New
        Hampshire	101

  47  (a & b) Large bulk plant in Connecticut	102

      (c) Large bulk plant in Connecticut	  .  103

  48  SPCC Plan layout for a large independent bulk plant in Connecti-
        cut 	104

  49  Small bulk plant in New Hampshire	105

  50  Small bulk plant No. 1 in Vermont	106

  51  Layout of small bulk plant No. 2 in Vermont	107

  52  (a & b) Small bulk plant No. 2 in Vermont	108

      (c & d) Small bulk plant No. 2 in Vermont	109

  53  (a & b) Small bulk fuel distributor in Massachusetts, main plant.  Ill
                                     0.x

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                              FIGURES  (Cont'd.)

Number                                                                  Page

  54  Small fuel distributor in Massachusetts, Branch Plant No. 1  ...  112

  55  Small bulk fuel distributor in Massachusetts which uses natural
        topographical features  (depression in ground) to catch a
        potential spill from storage tanks	  112

  56    Typical bulk station tank battery	  113
                                   TABLES

Number                                                                  Page

   1  Stripper wells and production in the three survey areas .....     3

   2  SPCC Statistics	     7

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                             CONVERSION FACTORS
                           U. S. AND METRIC UNITS

     Each unit in Italic type is followed by its equivalent in other units of
the same quantity.
Acre — 0.0015625 square mile (statute):  4.3560 x lo1* square feet; 0.40468564
   hectare.
Barrel — 42 gallons.
Centimeter — 0.0328084 foot; 0.393701 inch.
Circular Mil — 7.853982 * 10~7 square inches; 5.067075 x 10"6 square centi-
   meters.
Cubic Centimeter — 0.061024 cubic inch; 0.270512 dram (U. S. fluid);
   16.230664 minims  (U. S.); 0.999972 millilitpr.
Cubic Foot — 0.803564 bushel (U. S.); 7.480520 gallons  (U. S. liquid);
   0.028317 cubic meter; 28.31605 liters.
Cubic Inch — 16.387064 cubic centimeters.
Cubic Meter — 35.314667 cubic feet; 264.17205 gallons (U. S. liquid).
Foot — 0.3048 meter.
Gallon (U. S. liquid) — 0.1336816 cubic foot; 0.832675 gallon  (British);
   231 cubic inches; 0.0037854 cubic meter; 3.785306 liters.
inch — 2.54 centimeters.
Kilogram — 2.204623 pounds  (avoirdupois).
Kilometer — 0.621371 mile  (statute).
Meter — 1.093613 yards; 3.280840 feet; 39.37008 inches.
Mile (statute) — 1.609344 kilometers.
Sguare Centimeter — 0.155000 square inch.
Square Foot — 0.09290304 square meter.
Square Inch — 645.16 square millimeters.
Sguare Meter — 10.763910 square feet.
Square Yard — 0.836127 square meter.
Ton ("short; — 907.18474 kilograms.
yard — 0.9144 meter.
                                     XI

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                               ACKNOWLEDGMEN TS
     The authors gratefully acknowledge the support and contributions of the
staff of the Energy and Environmental Sciences Division of Science Applica-
tions, Inc.  Special thanks are due to Mr. V. Buell.

     We also wish to express our appreciation for the continuing guidance and
assistance offered by Frank Freestone and Thomas J. Charlton of the U. S.
Environmental Protection Agency.
                                    xii

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                                 SECTION 1

                                INTRODUCTION


EPA'S OIL POLLUTION PREVENTION REGULATION

     EPA's OIL POLLUTION PREVENTION REGULATION (40 CFR 112)  was promulgated on
December 11, 1973, as a key element in the efforts of the U.S.  Environmental
Protection Agency (EPA) to prevent, control and assure accountability for oil
spilled into the navigable waters of the United States or the adjoining shore-
lines.  The objective of the regulation is to prevent such spills as they
might occur, or reasonably be expected to occur, from nontransportation-
related, on-shore and off-shore facilities.  In short, the regulation covers
owners and operators of nontransportation-related facilities that are in any
way engaged in production, processing, refining, distribution and consumption
of petroleum and petroleum products so long as the storage capacity at any
facility exceeds the limitations established by the regulation.  For above-
ground storage, the limit is a total storage capacity of 1,320 gallons, or a
single container with a capacity of 660 gallons.  For underground storage,
the limit is a total of 42,000 gallons.

     In effect, the first limitation exempts individuals such as householders
and other similar low-volume users from compliance with the regulation.  The
second limitation effectively exempts such facilities as most local service
stations from the regulation.  Thus, the purpose of the regulation is met by
providing for spill prevention and control accountability on the part of all
other elements of the petroleum industry, in addition to all industrial users
of petroleum and petroleum products who exceed the above storage quantity limi-
tations.  It is also notable that all departments, agencies and instrumentali-
ties of the Federal Government are subject to the regulations on the same basis
as private enterprise, with the exception of the penalty provisions.

     The regulation has two unique features designed to promote assurance
that all covered petroleum producers and users do, in fact, take positive
steps toward spill prevention and control, and that those steps form the
basis for accountability.  The first of these features is the requirement
that the owner/operator develop, document, implement and maintain a spill pre-
vention, control and countermeasure (SPCC) plan for each affected facility;
the second is the requirement that each SPCC plan be certified by a registered
professional engineer  (PE) before it can become effective under the regula-
tion.  Thus not only must specific SPCC features be prescribed by the facility
owner/operator, but assurance is gained that those features are based on sound
engineering practice as it relates to each individual facility.

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      The regulation includes a number of facility design and operating  guide-
 lines for spill prevention and control,  and each owner/operator  is  afforded
 flexibility in determining the proper methods for each facility  within  the
 framework of these guidelines (section 40 CFR 112.7  of the regulation).   This
 intent recognizes that each facility is  different because of topography,
 relationship to waterways, location and  siting.
 SCOPE OF THE STUDY

      The study was limited  to independent  producers  and  distributors,  i.e.,
 the smaller business  units  in the petroleum industry.  This  emphasis was
 based on the notion that  these firms  and individuals would be  the parties
 encountering the  greatest difficulty  in complying with the oil spill preven-
 tion regulations  and,  therefore,  that the  problems and solutions of these
 industry elements concerning  the  regulation would be of  special interest.
 For these reasons,  in the oil production sector, heavy emphasis was given to
 stripper wells, although  a  number of  higher-production wells were included
 in  view  of their  location with respect to  waterways.  Likewise, the distribu-
 tion facilities survey was  concentrated on the  smaller bulk plants, although
 several  larger  installations  were included,  either because of their locations
 or  because they demonstrated  peculiar siting problems.

      The surveys  themselves were  conducted in four geographical regions of the
 United States  —  three surveys  for production facilities, and two for distri-
 bution facilities.  These are discussed below.

 Production Facilities  Survey

      Field  surveys  of  production  facilities  concentrated on stripper wells and
 were  conducted in the  Texas/Oklahoma  area, the Louisiana area and the Penn-
 Grade area.  These  three  areas were selected for two reasons.  First is that
 all exhibit difficult  terrain  features with respect to spill prevention and
 control, and second, there are large  concentrations of stripper wells in
 these regions.

      In  the Texas/Oklahoma area, the  terrain runs from coastal wetlands to
 arid plains.  The Louisiana area, with extensive oil production in the
Mississippi valley and bayou areas, exemplifies the most  difficult protec-
 tion conditions with respect to waterways.   The Penn-Grade area,  most of
which is located in the most rugged areas of the Appalachians, typifies the
 spill prevention and control problems encountered in mountainous  terrain,
especially mountainous terrain with substantial annual rainfall and  numerous
rivers and streams.

     In addition to the difficult terrain conditions exemplified  by  these
areas, they are of further importance because of the very large number of
strippper wells they contain.   As Table 1  indicates,  these three  areas account
for more than 65 percent  of  the U. S.  stripper wells.  The Texas/Oklahoma

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     TABLE 1.  STRIPPER WELLS AND PRODUCTION IN THE THREE SURVEY AREAS*
Region
and
States
Included
Texas/Oklahoma :
Texas
Oklahoma
Total
Penn-Grade :
Pennsylvania
Ohio
Kentucky
West Virginia
New York
Total
Louisiana
Total
Number
of
Stripper
Wells

87,412
59,817
147,229

32,095
15,406
13,914
13,600
4,828
79,843
12,808
239,880
%
of
U. S.
Total*

23.9
16.3
40.2

8.8
4.2
3.8
3.7
1.3
21.8
3.5
65.5
Annual Production
from
Stripper Wells
(bbl)

126,386,936
73,694,737
200,081,673

3,399,000
6,361,600
6,463,912
2,763,000
896,000
19,883,512
7,501,798
227,376,983
%
of
U. S.
Total"1"

30.7
17.9
48.6

0.82
1.54
1.57
0.65
0.22
4.80
1.8
55.2
* Source:  National stripper Well Survey, January 1, 1975, Interstate Oil
  Compact Commission, Oklahoma City, Oklahoma.

"*" U. S. totals:  Stripper wells — 366,095; stripper well production —
  411,936,033 barrels.
area is of special interest, since it accounts for nearly 49 percent of U. S.
stripper well production.  Although the Penn-Grade area accounts for less than
5 percent of total U. S. stripper production, it is also of special interest
because the oil produced is extremely high quality lubricating oil, and the
area holds nearly 22 percent of U. S. stripper wells.

     Finally, it should be noted that the surveys did not attempt 100 per-
cent coverage of each region.  Rather, it was necessary to select sub-areas
that would typify the terrain features of interest as they relate to a wide
variety of production facilities.

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 Distribution Facilities Survey

      This survey was concentrated in two regions — New England and Penn-
 Grade.*  The New England region was selected for primary study because it has
 a very large number of distribution facilities (bulk plants),  especially so in
 proportion to its population.   The region is largely dependent on fuel oil
 for heating, since it has no oil production, and very little  natural gas is
 piped into the region.  Therefore, the fuel oil,  in addition  to other refined
 bulk petroleum products,  has to be transported into the region by surface
 carriers.   This situation has  given rise to the large number  of distribution
 facilities.

      Although the bulk plant survey was concentrated in the New England re-
 gion,  opportunities did arise  during the surveys  in the other  three regions to
 observe a  number of bulk  plants.   This was particularly true  in the Penn-Grade
 area where,  again,  the rugged  terrain was of special interest  as it related
 to  facility  siting and spill prevention and control problems.
 OBJECTIVES  OF  THE  STUDY

     Overall,  the  study  had  three  broad  objectives.   They  were:

     1)   To determine the technical problems  the  facilities have  in
          complying with the regulation  and what cost-effective tech-
          nical solutions are available  for these  problems

     2)   To determine,  in general, the  costs  of compliance with the
          regulation, i.e., the costs of preparing and  implementing
          SPCC plans

     3)   To prepare a manual that delineates  the  technical problems
          and alternative solutions to aid facility owners/operators
          in complying with the regulations.

     The first objective is succinctly discussed in Section 2.  The second
objective was aimed at determining the actual  cost the  facility owners/
operators experienced in complying with  the oil spill prevention regulations.
Because of the critical differences in the economic impact of one-time costs
 (i.e.,  initial investment) and ongoing costs (i.e., operating costs), the
objective had to be considered as having three elements:

     1)   The cost of preparing SPCC plans
* Because of the similarity of the conditions under which the distribution
  facilities were found in each of these two regions, they will be discussed
  as one (New England)  in this section of the report, and reference to the
  Penn-Grade area will be to indicate a unique situation or to stress a
  particular point further.

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     2)    The cost of PE certification of the plans

     3)    The cost of implementing the plans.

     The first two of these are one-time costs, unless the SPCC plans have to
be revised in the future as facilities are altered and operations are changed.
Any substantial revisions would require recertification of the plan.  These
two cost items are of special interest because they are wholly new costs to
the facilities covered by the regulation; that is, owners/operators have never
before had to incur such costs.

     Accordingly, depending on the interpretation of the regulation by any
individual owner/operator, these costs can vary widely.  For example, an
owner/operator can prepare the plan himself, then hire a PE for the certi-
fication.  Or he might hire the PE both to prepare and certify the plan.
Should the owner/operator happen to be a PE  (as is true in some cases), he can
do the preparation/certification personally.  These costs can also vary sub-
stantially when an independent PE is hired for the job, depending on the PE's
interpretation of the regulation.

     The latter factor can also heavily impact the costs of implementing the
plan.  The independent PE's interpretation may be such that, depending on the
status of the facility in question, he will opt for extreme (and expensive)
engineering measures for spill prevention and control before he will certify
the plan.  Or he may determine that existing protection at the facility is
adequate and recommend no changes.  Furthermore, should it be determined that
preventive measures are impractical and a contingency-type plan is needed for
a facility, plan implementation costs vary widely.  Such costs will depend on
the facility's site-specific problems and whether or not the owner/operator
implements the contingency plan with all in-house personnel or subcontracts
a part or the whole implementation phase of the contingency plan.

     Thus, the compliance cost determination objective has many facets.  In
particular, it was necessary during the surveys to determine the requirements
of the SPCC regulation that resulted in the specific courses of action taken
by facility owners/operators.

     The third study objective of preparing a technical manual relates
directly to and, in fact, stems from the first two objectives.  It was noted
earlier that the study emphasis was on practical, cost-effective solutions
to technical problems experienced by the facilities in complying with the
regulation.  In keeping with this focus, a variety of technical solutions
are presented in Section 4 and in the Appendices, both of which constitute
the technical manual of alternative solutions required by this third major
objective.

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                                  SECTION 2

                                 CONCLUSIONS
      The survey conclusions presented here address the facility  design  and
 operating factors  that must be changed to prevent oil spillage,  and  the re-
 sponse  measures required if and when an oil spill reaches  navigable  waters.
 The  conclusions are presented in five parts:   The general  conclusions appli-
 cable to the  facilities in all areas surveyed  and conclusions  specific  to
 each of the four areas surveyed.
GENERAL CONCLUSIONS

     Some of  the problems  that  the  facilities  faced  in complying with the oil
spill prevention regulation  were  independent of geographic location.  As might
be expected,  the small operators  generally  seek to comply either by hastily
preparing a poor SPCC plan and  finding a PE to certify it, or by using a
standard SPCC plan format  but failing to implement an adequate plan.  This
approach does not solve the  oil spill prevention problem and may result in
fines from EPA for inadequate plans.  An adequate SPCC plan generally means
that a facility needs a good operations and maintenance plan including per-
sonnel training, inspections with checklists, routine preventive maintenance
and the incorporation of fail-safe  systems.  Of course, some facilities were
poorly designed and required basic  changes  to prevent oil spillage.

     Spill data recently compiled by the U. S. Environmental Protection Agency
for petroleum marketing distributors, bulk  storage and production operations
(see Table 2) indicate that  the great majority of spills are the result of
equipment failure and personnel errors.  These data are consistent with the
findings of this study and suggest that if  good SPCC plans are prepared and
implemented by the facility owner/operators, that the opportunity for the
occurrence of a spill would be minimized.

Facility Design and Maintenance

     Maintenance of facility equipment,  tanks and piping was  generally ob-
served to be out of keeping with good engineering standards and specifica-
tions.   Unless properly maintained,  this equipment will cause oil spillage
through leaks or malfunctions.   Corrosion,  leaky seals and gaskets are all
functions of wear life and ultimately cause oil spillage if not corrected.

     The most common and economical  means for  preventing oil  spillage from
entering navigable waters is to  construct an earthen dike around the facility.

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                          TABLE  2.    SPCC STATISTICS*
Cause of spill
Casual tits >
Overturning (capslxlng)
Colli « Ion with vehicle
Ixploslon
flr«
Grounding
Sinking
Nell blowout
Other
Total
Iqulffnt ftilumt
Um
Automatic shutdown
Corrosion, pip*
Corrosion, tank
Defective valvea
Hose rupture
Pipe rupture
Pump
Tank rupture
Veld failure, factory
•eld failure, field
Other
Total
Fenonne.1 errors t
Incorrect valve handling
Improper hose connection
Improperly secured flangee
Tank overflow
Other
Total
Deliberate diichtrgumi
Dumpino
Disposal of waste oil
Pumping ballast
Pumping bilges
Vandalism
Other
Total
Hfturml fhenoaentt
Flooding
Freezing
Heavy seas
Heavy winds
Natural seepage
Other
Total

Number of spills resulting froa
specific type of operation
Marketing distribution Bulk storage1'
Total spills — 304 Total spills — 89

1
9
0
)
0
0
0
_1
It

0
1
19
27
14
11
10
8
13
0
0
34
137

15
10
4
74
23
126

8
3
0
0
7
	 1
19

3
0
0
0
2
	 J_
e

1
1
0
1
0
0
0
_1
4

0
0
1
s
s
2
e
i
8
0
0
-ii
44

«
0
0
20
6
32

0
1
0
0
4
0
5

1
0
0
1
1
1
4
t a
Production
Total spills — 4S6

0
0
1
2
0
0
7
_A
14

2
7
41
14
96
3
40
19
5
1
1
55
284

18
0
2
43
17
80

4
1
0
0
29
3
37

14
6
0
1
3
17
41
• Data base supplied by T. Char 1 ton of the U. S. Environmental Protection Agency  (1976).
t "Bulk storage" is a broad generic category and may include some data from marketing or  production
  facilities.  Any data listed under "bulk storage" are not duplicated elsewhere.

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 Most of the facilities had dikes,  but  the  earthen  dikes were generally observed
 to be poorly designed, constructed,  and  maintained.  A good dike design should
 include a drawing showing critical dimensions,  specification of construction
 materials,  specification of soil compaction  and construction methods and pro-
 visions for drainage  and oil/water separation,  recovery and disposal.  Allowing
 standing oil/water to accumulate within  the  diked  areas was observed to be not
 only a poor housekeeping/facility  maintenance practice, but also a potential
 oil spill problem.  Heavy rainfall combined  with the continued accumulation of
 oil spillage within the  dike could overflow  the dike and eventually flow into
 navigable waters.   If designed, constructed  and maintained properly (according
 to  good  engineering practices), earthen  dikes,  where feasible, represent the
 most effective and  economical  technique  for  containing oil spillage and comply-
 ing with the  oil  spill prevention  regulation.

      Facility transfer operations  were also  considered a major compliance prob-
 lem.   Substandard facility operations and procedures were observed to be a
 major  source  of oil spillage from  overfilling of storage tanks and tank trucks,
 leakage  during hose connection/disconnection, spillage during tank sampling
 and  water drawdown and premature tank truck  departures.  Most of these problems
 were related  to human error and could be economically corrected by formulating
 a good operating procedures manual for the facility.
TEXAS/OKLAHOMA AREA

     This part of the survey dealt with stripper wells that were mostly in dry,
arid geographical locations far removed from water.  Some of the facilities
would not require an SPCC plan according to 40 CFR 112.1.  However, in this
area, the two defined modes of oil spillage that could result in water con-
tamination are the result of rainwater runoff and the direct spillage into
standing bodies of water.

     Specific facility deficiencies were observed to be related to the follow-
ing:
     •  Most facilities are remotely located, largely unattended, and
        without electrical power lines, making spill detection/alarm
        and reasonable response time in case of major oil spills very
        difficult.

     •  The oil/water separators (typically of the gun-barrel design)
        are designed in such a way that if the level control valve
        malfunctioned, considerable oil spillage could occur.

     •  Production facilities in grazing areas are unfenced (a security
        item) and accessible to grazing livestock that could cause equip-
        ment damage and potentially result in oil spillage.

     The SPCC plans reviewed in this area followed a standard format and were
lacking in good engineering design and practice required to overcome the above-
mentioned problems.  Some of the plans merely stated that because of location
with respect to a waterway, no further action was required of the owner/

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operator (which in some cases was true).   For facilities requiring an SPCC
plan, sample generic plans are included  in the Appendix of this report for
use as guidelines in preparing plans aimed at the specific facility problems
encountered in the Texas/Oklahoma area.
LOUISIANA AREA

     This survey involved two types of facilities characteristic of this area:
1) on-shore and 2) water-based.  Water-based facilities include facilities con-
structed away from shore over the water and usually mounted on pile-supported
platforms.  On-shore facilities (or shore-based) include facilities constructed
along the shore and many times are part of the water-based facility's operation.
The problems encountered with the on-shore facilities were solvable using pre-
viously mentioned conventional techniques, including secondary containment
dikes.  Here heater-treaters were used for oil/water separation and the produc-
tion wells were of greater capacity than stripper wells (i.e., 10 bpd).  How-
ever, the water-based facilities were remotely located in marshlands and bayous,
usually unmanned, and presented complex problems for the preparation and
implementation of adequate SPCC plans.

     Although the water-based facilities problems were complex, the SPCC plans
were simple, followed a standard format and did not reflect good engineering
thought and solutions to the difficult problems.  The major complexities at
these facilities included the following:

        Oil production wells and loading facilities were mounted on
        piles in mid-stream of the waterways
        Rise and fall of the water level due to flooding can be as
        much as 13 feet* in the Mississippi Spillway — this mostly
        affects the shore-based storage tanks and oil/water separators

        Unless carefully designed,earthen dikes, drainage and disposal
        pits will not work here due to high soil permeability

        Over-water piping was largely unprotected against leakage
        directly into the water from joints, flanges and pipe corrosion

        Heavy waterway traffic causes water-induced soil erosion along the
        shoreline, including storage tank dikes located close to the shore.

     Suggested solutions to these problems are  included in the generic SPCC
plans found in the Appendix section of this report and are summarized below:

        A closed drainage system should be designed for the over-water
        pipes, water-based well and shoreline storage tanks (typical de-
        signs are included in the Appendix section of this report)
   The audience reached by this report will be more familiar with the English
   system of units rather than the Metric System of units — therefore, its
   use (see p. xi of the report for Metric Conversion Table).

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         To prevent soil/dike erosion caused by excessive waterway
         traffic, bulkheads should be designed for shore-based
         facilities

         Polyethylene (or equivalent material) liners should be used
         in all earthen dikes, and in drainage and disposal pits

         A strong drainage and maintenance plan for all dikes and pits
         should be required for facilities where periodic flooding
         occurs; also,  a strong contingency plan should be required,
         with specified spill control equipment and designated/trained
         response teams.
 PENN-GRADE AREA

      This  part  of  the  survey  covered both  stripper well and bulk distribution
 facilities in the  Pennsylvania,  Ohio, and  West Virginia areas.*  Most of the
 production facilities  surveyed were very small,  less than 1 barrel per day
 (bpd), and family-owned  (called  "Ma and Pa").  Very little evidence of spill-
 age was found,  and the potential  for large spills was small for the facilities
 surveyed.   However, the  facilities were located  in mountainous and hilly areas,
 The streams flowing in the valleys provided the  potential for contaminating
 bodies of  water.   The  local soil  was generally considered adequate for con-
 structing  impervious earthen  dikes and drainage  pits that would prevent spills
 from  entering these water courses.

      Specific problems encountered in production were:

     •  The hilly  terrain made diking difficult, and many sites had
        either poorly  constructed diking or none at all.

     •  The production facilities were very small and unattended. They
        had not cost-effectively implemented a good SPCC plan requiring
        maintenance of equipment, corrosion protection and protection
        against leaks and spills.

     •  Many oil/water separators were undersized, with no overflow
        protection, and had no secondary containment system or high-
        level alarms.

     •  Roadside storage tanks without security fences (and thus vulner-
        able to being hit by tank trucks and other vehicles)  and without
        protection against tank overfilling and oil transfer spills were
        common.
* Since the conditions relating to the bulk distribution facilities in the
  Penn-Grade area are similar to those encountered in the New England area,
  all discussions of the bulk distribution facilities for these two areas
  are found under Bulk Plants — Penn-Grade/New England Areas.

                                     10

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     •  The combination drainage ditch/pit arrangements used at many
        sites were underdesigned and were improperly designed for uncon-
        trolled syphon-drain without oil/water separation, discharge
        inspection or security provisions.

     Recommended solutions to these problems are included in the generic SPCC
plans found in the Appendix section of this report and are summarized below:

     •  Earthen dikes, drainage ditches and pits on hilly terrain
        should be designed for:

        -  Capacity (rainfall plus oil spillage) of largest single
           tank or process unit

           Diversion of runnoff water around ditches and pits

           Provision for routine inspection of rainwater before
           discharge  (discharge valve must be securely closed)
           taking maximum advantage of the slope of the land when
           possible

     •  In case of control valve malfunction, oil/water separators
        should have automatic high-level shut-off valves and dikes

     •  Since many of these facilities appeared to be old, with
        deteriorating equipment:

        -  Hydrostatic testing  (or the equivalent thereof) of all
           pipes, tanks, valves and connections should be conducted

           All worn-out, leaky parts should be replaced

           Cathodic protection systems should be used to prevent
           underground pipe and tank corrosion

     •  Roadside storage tanks should be diked to contain an oil spill
        and divert highway drainage or, if located in close quarters,
        should have steel/concrete curbing with grading designed for
        oil/water flow into a drainage trench and ultimately to a re-
        motely located containment pit for proper treatment and dis-
        posal.
BULK PLANTS — PENN-GRADE/NEW ENGLAND AREAS

     Although a number of the General Conclusions apply to bulk plant
design and operations, the differences between this type of facility and
oil production facilities are such that more complete treatment of  those
conclusions is needed to provide the clarity not afforded by  a blanket
statement.  Since these facilities are typically located within cities  and
towns where spills  (especially major spills) present numerous hazards to
the environment and human safety, protection against spills from bulk plants

                                     11

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 is of further critical interest.   Moreover,  bulk plants observed during this
 survey are typical of such facilities anywhere in the country,  so the  conclu-
 sions given below can be considered as applicable nationwide:

      •  Maintenance items such as repairs to leaking valves and
         cleaning and painting of  piping and  vessels that are
         typically covered by SPCC plans are  not regularly per-
         formed.

      •  Many bulk plants and tank truck loading-unloading facili-
         ties are often squeezed into limited space, making secondary
         containment,  drainage,  and disposal  difficult to design and
         implement.

      •  Bulk plants are not  often surrounded by fencing,  and they
         have insufficient lighting to help prevent  equipment damage
         and spills  resulting from vandalism.

      •  For relatively inexpensive solutions to spill control prob-
         lems, unique  terrain features of bulk plant properties  and
         natural  slopes should be  taken advantage  of when  possible.

      •   Color-coding  and labeling of  piping  and rapid positive  identi-
         fication  of contents  were needed at  most  bulk plants.

      •   Some  facilities  were  located  adjacent  to  municipal  storm  sewer
        basins without provisions for  preventing  spills  from entering
         them.

      Recommended  solutions to these problems are  included in the  generic SPCC
plans located in  the Appendix of  this  report and  are  briefly summarized below:

     •  Techniques  for overcoming  space  limitation problems  include:

           Use of steel-reinforced concrete rather than earthen dikes

           Use of trenches or drain pipes leading to  remotely located
           oil/water storage

        -  Oil/water separation and water discharge facilities  (which
           requires an NPDES permit)

        -  More frequent inspections and routine maintenance

     •  Security appears to be uniquely important for these facilities
        and should include strong  fencing, ample lighting, and,  through
        the implementation of good security measures such as plant
        component locking, inaccessibility of the facility.
                                     12

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                                 SECTION 3

                            SURVEY METHODOLOGY
INTRODUCTION

     The fundamental requirement in conducting the study was to assure that
the status and needs of the industrial sectors of interest would be appro-
priately covered with respect to the oil spill prevention regulations.
However, resources available for the study did not permit detailed study
in all areas of the country.  A progressive selection procedure was there-
fore employed to identify areas for the survey that would demonstrate
conditions of such facilities wherever they might be located.
AREA SELECTION PROCEDURES

     The first step in this procedure was to meet with EPA Regional Office
staff members directly involved in administering the regulation  (the excep-
tions were EPA Regions 4 and 9, where it was determined, after consultation
with EPA headquarters representatives, that an insufficient variety of
facilities existed to make them good candidate areas for study).  The
Regional Office staff were solicited to learn what the industry's experience
had been in their areas in complying with the regulation.  Additionally,
those staff members were asked to identify the industry trade associations
and individuals in their regions who are recognized leaders in the petroleum
production and products distribution industries.

     The next step was to contact the identified leaders and to  solicit
their views on the regulation's impact and of the modes and techniques of
compliance available to and favored by their member owner/operators.
Finally, these industry representatives were requested to suggest individual
owners/operators who might be amenable to having study team members visit
their properties.  It was also requested that these owners/operators and
their properties be selected for representation of typical SPCC  problems,
peculiar site problems and for indication of good engineering practice in
complying with the regulation.  Some of those facilities were visited for
observation of SPCC problems and solutions, and for discussion with the
owners/operators.

     The purpose of this "first round" of discussions and visits was to
determine the extent of compliance problems — the regulation's  impact in
the several regions, to serve as the basis for selection of areas for de-
tailed  survey.
                                      13

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 SELECTION OF THE FOUR  SURVEY AREAS

     As a result of all  the inputs gained  through the procedure outlined
 above, the Texas/Oklahoma, Louisiana, Penn-Grade and New England areas were
 selected for detailed  survey.  Additional  input to this decision was gained
 from further discussions with EPA representatives and trade association
 officials.  For the four areas selected, these two groups also provided
 major assistance in the development of a roster of facilities that would
 be visited during the  surveys.  The trade  association officials were particu-
 larly helpful in arranging the study team's initial contacts with the facili-
 ty owners/operators.
THE AREA SURVEYS

     Within each of the four areas selected for detailed survey, a number
of individual facility owners/operators were contacted, with the request
that study team members be permitted to visit specific facilities.  Where
agreement was achieved, the team members then visited the facilities with
four objectives to be accomplished:

     1}   To review and analyze individual facility SPCC plans and
         acquire copies, if available.  The plans were not always
         available at the facilities, since the owner/operator might
         keep them at his central office which, in many cases, is
         quite some distance from the facility.

     2)   To discuss with the owner/operator the actions they had
         deemed necessary at the facility to comply with the regula-
         tion, and the reasons for settling on particular courses of
         action.   The owners/operators were also requested to furnish
         information on the costs incurred or necessary to implement
         the spill prevention and control actions, especially where
         construction was involved, and the costs incurred for Regis-
         tered Professional Engineer certification of the SPCC plans.

     3)   To inspect the facility to observe its operating conditions,
         the spill prevention and control provisions and its re-
         maining  spill prevention and control needs.   Where permis-
         sion could be obtained,  photographs were taken of the facili-
         ties, their relationship to the surrounding land areas, and
         the provisions for spill prevention and control.

     4)   To prepare a set of notes describing the facilities and the
         operating practices,  emphasizing the spill hazards and the
         prevention and control  provisions.   Sketches were also made
         of the facilities'  layouts,  with more  detailed sketches indi-
         cating the spill  hazards and the prevention/control provisions.
                                     14

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AREA SURVEY SUMMARIES

     At the conclusion of the facility survey in each of the four geographic
areas, the study team conducted detailed reviews of the results of the many
facilities visits made and developed summaries for each area.  The purpose
of these reviews and summaries (which are presented in Chapter 4, Results
and Discussions) were:

     •  To determine the generic types of facilities found in each
        area, so that broad, yet accurate, descriptions could be pre-
        pared that would indicate to future users of the report just
        what they might expect to find upon entering the areas.

     •  To prepare, for each generic type of facility, an SPCC plan
        that would, if implemented, provide adequate spill prevention
        and control for that type of facility.  Thus, users of the
        report are afforded a vehicle for comparing the adequacy of
        actual facility SPCC plans they might come upon at facilities,
        not only in the survey areas, but in any area of the U. S.
        where facilities are encountered that fit any of the identified
        generic types.

     •  To determine the technical problems involved in the achieve-
        ment of adequate spill prevention and control at facilities
        in each area.

     •  To prepare a set of alternative technical solutions  (i.e.,
        engineering solutions) for each of the problems identified,
        so that users of the report will have available a range of
        suggested solutions that might be employed at any given facil-
        ity.  For each technical solution, an implementation cost
        estimate was prepared.  To the maximum extent possible, these
        cost estimates have been based on data given by Means Construc-
        tion Cost Index,(1974) to assure that the estimates are stan-
        dardized and therefore indicative of costs any owner/operator
        might expect to incur in utilizing any of the solutions.  Since
        these estimates are based on 1974 index data, they would have
        to be updated to the year in which they are used by applying a
        multiplier that will reflect the annual rate of increase in
        construction costs since 1974.

     The principal study interest was focused on the smaller facilities  in
the production and distribution industries.  For this reason,  in reviewing
the survey results and developing the summaries, concerted attention has
been given to small-facility problems.  Therefore, in developing the generic
facility SPCC plans and the alternative technical solutions  to specific  spill
prevention and control problems, every effort has been made  to identify  the
most practical and cost-effective solutions.
                                     15

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                                  SECTION 4

                           RESULTS AND DISCUSSION
 INTRODUCTION

     This chapter presents  the  summaries of  the  surveys conducted  in each of
 the  four survey areas, i.e., Texas/Oklahoma, Louisiana, Penn-Grade and New
 England.  To promote easy use of the  information presented, each of the
 summaries is subdivided  into the following sections:

     •  Discussion of the overall survey region,- with a map showing
        the more specific areas in which the survey was concentrated.
        Included is information describing the number, types and
        concentrations of facilities  within  the  survey area.

     •  Description of the  survey area, including terrain, soil
        type(s) and climatology.  To  the extent  possible, photo-
        graphs are included.

     •  Descriptions of  the different types of facilities en-
        countered during the survey,  with breakdowns into generic
        types  (figures and photographs) and discussions of the
        operating procedures and characteristics of each generic
        facility type.

     •  Technical problems encountered at the facilities with re-
        spect to spill prevention and control and alternative
        technical solutions to those  problems, including imple-
        mentation cost data for the solutions.  Again, photographs
        and sketches are included for clarification.

     •  Discussion of existing SPCC plans for the facilities, in-
        cluding information indicating the costs of preparation,
        certification and implementation as experienced by and
        when available from the various owners/operators surveyed.

     The essential purpose of this final overall summary section is to demon-
strate the commonality of spill prevention and control among the types of
facilities of interest — wherever they may be found — and, therefore, to
demonstrate that the study's results are applicable to all similar petroleum
production and products distribution facilities nationwide.
                                    16

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TEXAS/OKLAHOMA AREA

Introduction and Summary

     The objective of this portion of the study was to survey a representa-
tive sample of the stripper well industry in the Texas/Oklahoma area in order
to determine the technical problems these facilities are experiencing in
complying with 40 CFR Part 112, and to recommend a number of alternative
solutions to these problems.  Due to their location, some stripper wells
probably do not require an SPCC plan according to 40 CFR 112.1,  (b) and
 (d); (4).  These solutions have taken the form of the preparation of generic
SPCC plans which can be implemented by the majority of stripper well owners/
operators at a reasonable cost and yet provide adequate protection to the
environment.  The generic SPCC plans are given in Appendix E.

     The Texas/Oklahoma survey region was divided into four geographical
types of areas, only three of which have distinct geological and clima-
tological features.  These areas are shown on the map in Figure  1 and are
described below:

     •  Area 1 — West Texas between the cities of Fort Worth,
                  San Angelo, Odessa, Lubbock and Wichita Falls;
                  Oklahoma between the cities of Durant, Sopulpa,
                  Muskogee and Hugo.  These two areas, being
                  similar, were combined into Area 1.

     •  Area 2 — East Texas between the cities of Silsbee,
                  Liberty, Crockett, Palestine, Athens, Sulphur
                  Springs, Atlanta and the Louisiana state line.

     •  Area 3 — Texas coastal areas between Freeport, Houston,
                  Beaumont, Orange, Louisiana state line and the
                  Gulf coast;  also, the area around Corpus Christi,
                  bounded by Port Lavaca, Beeville, Mathis, Alice
                  and Falfurrios.

     Approximately 55 facilities were surveyed in the Texas/Oklahoma area;
 20  in each of Areas  1 and 2, and 15 in Area 3.  All of the facilities survey-
 ed were of the stripper-well type which, by definition, are those  that  pro-
 duce less than 10 bbls of oil  per day per well.  These facilities  are generally
 owned by small independent operators, and many of the operations are economic-
 ally marginal.  Thus, a minimum amount of investment capital is  available  for
 facility improvements.  However, the total yearly production of  oil  from
 these stripper  facilities in this area is not insignificant  (~ 200,000,000
 bbls) when compared  to the entire U. S. domestic production.

     Most of the SPCC plans that were reviewed in this area  followed the
 American Petroleum Institute  (API) suggested format  (API Bulletin  D-16).  Many
 of  the very small operations surveyed had no SPCC plans at all and may  not have
 required one.  The majority of plans that were reviewed indicated  a  lack of
 thought  and ingenuity.  Statements in the plans regarding  inspection,  training,
 and recordkeeping appeared mimicked and, though not proven so, were  probably

                                     17

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Plpml.
                                18

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never implemented.  The fact that the pumpers were generally unfamiliar
with these plans tends to support this conclusion.

     Although not documented, it seems reasonable that any major oil spills
(10,000 gallons or about 240 bbl) would most likely occur through human
error, i.e., unloading or leaving drawdown valves open and unattended for
substantial time periods or through catastrophic failure  (storage tank or
other vessel rupture).  Even though such events are infrequent, protection
against them should be provided.

     The average storage tank capacity is 500 bbl, with a minimum of 250 bbl
and a maximum of 1,000 bbl, whereas gun-barrel tanks  (oil-water separators)
average 400 to 500 bbl and heater-treaters average 250 bbl.

     Through discussions with the facility operators, it was found that the
most frequent causes of spills were leaks in pipe or tube connections, pump
and pumping unit seals, tank overflows, seepage through firewalls and from
loading, gauging and transfer operations.  Typically, these spills vary from
a few gallons to approximately 50 bbl.  For all of the facilities surveyed,
there was no sign of pollution in any of the nearby waterways.  Most of
the noticeable pollution from spills was around or adjacent to the facili-
ties themselves, and this was generally a result of minor leaks and poor
housekeeping.

     The major facility technical problems encountered during the survey
were:  poorly designed and constructed diking, lack of diking or other means
of containment around the facility, poor housekeeping, insufficient facility
maintenance and human error or carelessness in the operation of valves
associated with the  facility.

Description of the Survey Area

     The basic soil  in Area 1 is of the residual  type, weathered in place
primarily from sandstone and secondarily from shales.  The  terrain generally
consists of plateaus and plains  of moderate relief, which can be seen in
Figure 2.  This area varies from arid  to semi-arid, with  15 to 20 inches
annual rainfall.  Most minor oil spills present no problem  in this area
since the oil/water mix would either rapidly evaporate or absorb into the
sandy soil before reaching the nearest waterways which are  few and widely
scattered.  Even a large spill generally would not reach  a  navigable stream.
In such cases, the Federal regulation  40 CFR 112  requiring  SPCC plans
probably does not even apply.  However, fresh water is very scarce in this
primarily cattle-raising area and, therefore, extreme care  is taken by both
landowners and facility operators to protect all  existing water  supplies.

     In Area 2  (Figure 1), the basic soil is alluvial (clay,  silt,  sand  and
gravel), both marine and continental deposits, which  thicken  toward  the
coast.  Clay belts are also present in this region.   The  terrain  in  the  area
is essentially flat, with the exception of the northern area  where  it becomes
slightly rolling with gentle rises.  The area has considerable  timber,  but
is used primarily for cattle grazing.  Annual rainfall here varies  from 30
to 40 inches at the  northern end to 40 to 50 inches  toward the  southern end.


                                     19

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Figure 2.
Typical terrain feature* of West Central Texas and Southeastern Oklahoma (Area 1
                                       20


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The threat of oil spills being carried to nearby navigable waters and stand-
ing water bodies is present.   Typical views of this area can be seen in
Figure 3.  Four main rivers run through this region from north to south.
Beginning in the east, the Sabine River runs along the Texas/Louisiana
border; moving west, there are the Neches, Trinity and San Jacinto Rivers.
Pollution problems resulting from a major spill are more likely here than
in Area 1 (Figure 1) because of the proximity of these rivers and their
tributaries.

     The basic soil in Area 3  (Figure 1)  is alluvial marine and continental
deposits, with considerable organic material around the Houston area, chang-
ing to a more clay-like soil in the Corpus Christi area.  The terrain in
this region is completely flat as shown in Figure 4 and is used primarily
for cattle grazing.  Railfall in this area varies from 30 to 35 inches at
Corpus Christi to 45 to 50 inches yearly in Beaumont.  There is a threat
of runoff water to transport spilled oil from the facilities to the nearby
waterways.  More importantly, however, this region is extremely sensitive
to oil spills because of its location in relation to the Gulf of Mexico.

Description of Facilities

     All of the stripper well production encountered in this survey area was
accomplished through the use of pumping units  (secondary recovery).  These
are old fields and as the field pressure declines, it becomes necessary to
begin pumping relatively early in the life of the field.  According to the
operators, maintenance costs are high and small spills are  frequent.   In
east Texas and along the Gulf Coast where the soils are predominantly  sedi-
mentary, settlement of the overburden, as natural field pressure decreases,
tends to maintain an element of pressure on the field at all times.  Thus,
pumping is not required until late in the development of the field.  Mainten-
ance costs are generally lower and spills are less frequent.  The product
generally consists of crude oil with very small amounts of  gas.  Salt water
production varies from practically nothing in the west Texas/Oklahoma  area
to as much as 99 percent in the east Texas and coastal regions.  Well depths
range from 500 feet in west Texas/Oklahoma to 3,000 feet in east Texas and
to a depth of 7,500 feet along the Gulf Coast.

     The basic stripper-well facility encountered throughout this survey is
shown schematically in Figure  5.   Its operation is as follows:  a pumping
unit is  installed over production well A.  The wellstream  flows to  the gun-
barrel tank B which separates  the oil from the salt water.  The gun-barrel
units are nothing more than  large vertical tanks equipped  with level-control
valves.  The salt water flows  to tank C and then to  the salt water  pump F.
From this point, the  salt water can be loaded onto a  truck  for disposal or
directed to a disposal well.   The disposal well can  either  be  an  abandoned
oil well or a new well prepared specifically  for this purpose.   From the
gun-barrel  tank B,  the separated oil  flows to  the oil storage  tanks D (always
a minimum of two).  These  tanks are  filled alternately  and the oil  delivered
to the customer by  either  pipeline or truck.   The  trucks  and  the  pipeline
can be loaded by either gravity  flow  or by the use of pumps.   When  oil is
removed  from the facility  tanks, it  is the customer  who gauges the  tanks
prior  to and after  removal.  Before  removing  the oil  from the  tank, the

                                      21

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Figure3 (a & b). Typical terrain features of East Central Texas (Area 2).
                               22

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Rgure 4 (a & b). Typical terrain features of the Southeast Texas coastal plains (Area 3).
                                      23

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to
•u
                OIL PRODUCTION WELL
                  A
                                                        ALTERNATE SALTWATER
                                                       j TO TRUCK
                                                       P] SALTWATER PUMP
                                                            F
                                                                              S.W.D. WELL
                                                                             >
CONFINEMENT DIKE
                                   B
•=y^- 	 •» ^^_=»* 	 »» -*~~:
1
-" " 	 1
r 1
                            /
                       /
                                  DRAIN
                                                                                 OIL TO TRUCK
                                                                                 OR PIPELINE
                                                                                   E
                                      Figure 5. Typical stripper wtll facility in Texn and Oklahoma.

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customer drains a small amount from the bottom of each tank to check the
basic sediment and water (BS&W) content.  The BS&W is normally drained to
the ground inside the firewall, and is the primary cause of poor house-
keeping, as typified by the scenes of Figure 6.

     A gun-barrel tank is shown as the second vessel from the right in
Figure 7.  This vessel separates oil from water by gravity, the oil rising
to the top and the salt water  (white line) coming from the bottom of the
tank.  The elevation of the delivery line to the salt water tank (adjacent
to the gun-barrel) is set so that the salt water in the line is balanced
by the height of the salt water and oil in the gun-barrel.  The oil is
delivered to the two tanks on the left side of Figure 7 via the black line
just above the gun-barrel.  To the extreme right (Figure 7), outside of
the firewall is a heater-treater  (not being used in this facility).  A
heater-treater also serves to separate the oil from the water? however,
the mixture is heated to aid the separation of the oil from the oil-water
emulsion.  Since the heat is supplied by burning gas and the flame is open
to the outside, the heater-treater must be placed sufficiently far from the
oil storage tanks and always outside of the firewall.

     The two oil storage tanks shown in Figure 7 are inter-connected at the
top with a pipe and valve.  The valve is normally open so that if one tank
is overfilled, it will spill into the reserve tank.  The valve is closed
during the removal of oil by the customer to prevent pulling a vacuum on
the second tank or mixing the contents of the two tanks.  The improper
operation of this valve is the cause of many spillovers, since the pumper
normally visits these facilities once a day, and if the valve is left
closed and there is a delay in his return, a spill occurs.

     There are many variations of the basic facility described in Figure 5.
Additional wells can be fed through the same facility by adding more storage
tank volume and by varying the size of the gun-barrel or heater-treater.
The physical features of the facility also vary according to the terrain;
i.e., the storage tanks are normally located at a lower elevation  than the
well pump to reduce the pressure on the pump rod stuffing boxes.  Wells may
also be located a half-mile from  the tank battery.  Some of these variations
are shown in the scenes depicted by Figure 8  (a-d).

Technical Problems Encountered

     The most  frequently encountered technical problems which may  result in
spills or tend to propagate them  are discussed in the following paragraphs.
In general, failure to implement  adequate SPCC plans is the underlying defi-
ciency at the  root of most of  the technical problems presented below:

     1)  Dikes and firewalls were underdesigned on capacity and lack-
         ing in good engineering  practice, especially with regard  to
         specification of construction materials, soil  compaction  and
         leak-proof liners  (see Figures 8e,  f, g, and h).
                                     25

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Flgura6(a&b). Typlca. .can.. Indicating poor facility hou.eka.ping - T.xa./Oklahom. ar...
                                        26

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•
                                                   Rgure 7. Typical Texas/Oklahoma stripper facility tankage arrangement.

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Figure 8 (a fr bl. Variation* of the basic stripper well facility - Texas/Oklahoma area.
                                    28

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Figures (c & d). Variations of the basic stripper well facility - Texas/Oklahoma area.
                                     29

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                                  X
                                                      «>•




Figure 8 (e 6 f). Typical dikes and firewalls surrounding stripper well facilities - Texas/Oklahoma area.









                                                30

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Figure  8 (g & h).  Typical dike that has been breached (g) and unprotected area around storage tanks  (h) for
                 stripper well facilities - Texas/Oklahoma area.
                                                  31

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Figure 8 (i & j). Inadequate security fencing (i) and no Mcurity fencing (j) surrounding typical stripper
               well facilities - Texas/Oklahoma area.
                                               32

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     2)   Oil/water  separators  (gun-barrel  type)  are  designed such  that
         a simple malfunction  of  the  level-control valve  would cause
         considerable  spillage of oil mixed in salt  water (see Figure 8i).

     3)   Improper discharge, clean-up and  disposal of BS&W,  rainwater
         and tank overflows were  noticed at the sites and existing
         SPCC plans failed to  properly address this  problem by specify-
         ing needed procedures and equipment (see Figures 8a and b).

     4)   Primarily  because of  fire hazards, pumps and heater-treaters
         are placed outside  the firewalls.  These types of equipment  are
         usually undiked and,  in  addition  to pipe connections, valves,
         pumping unit  seals, pipe corrosion and transfer operations,  are
         the predominant sources  of minor  spills (see Figure 7).

     5)   Operator  errors and/or careless operations  with respect to
         valves cause  tank overflows and spills during tank gauging,
         BS&W drawdown and truck-loading transfer operations.

     6)   Spill detection and response time (12-hour  minimum is normal)
         are difficult problems since most facilities are remotely lo-
         cated, largely unattended, and generally power lines are  not
         available  for remote  sensor alarms.

     7)   Security  fencing at these facilities is either lacking or in-
         adequate,  therefore,  grazing cattle can enter the confines of
         the facility  and destroy dikes and/or damage equipment (see
         Figures 8  i and  j).

Solutions to Technical Problems

     Recommended solutions to the technical problems described above are
as follows:

     1)   The worst spill that can reasonable be  expected is the rupture
         of a 1,000-bbl storage tank which may result in the  release of
         the entire contents of the  tank.   Depending on the location and
         cause of  the rupture, the tank contents may be released rapidly,
         in which  case the dikes previously described may be  breached due
         to the momentum of the flowing oil or released over  a  long period
         of time if the rupture is not  too severe.   In order  to contain
         this maximum spill, any one of the three following procedures
         is recommended.  In the first method, a secondary containment
         dike, a minimum of 1 foot high on level ground and at  least 30
         feet beyond the  firewall  (or, where  there  is no firewall, at
         least 50 feet from the tank) can be  constructed.   If the ground
         is slightly sloped, the dike could vary from nothing on  one side
         to 1.5 to 2.0 feet at the low point.   In the second  method, a
         dam is constructed across the  ditch  below  the  facility (if this
         type of drainage exists)  to the  height  necessary  to  hold back
         the oil.   In crowded production  areas,  the dam  could serve
         several facilities or an  entire  field.  The  third  alternative

                                     33

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     applies to an area where the terrain is favorable or there
     exists a natural depression to build a pit to which all spills
     and drainage can be conducted.  In all three of the above pro-
     cedures, some means of disposing of the spilled material must
     be employed.  The disposal methods are the same as those that
     would apply within a firewall and are discussed in (3)  below.
     All dikes,  dams and firewalls should be designed for durability
     and the construction materials specified to retain the  oil and
     salt water for 2-month periods without leaching.   Compaction
     and shaping of this material should follow good engineering
     practice.   Moreover,  vegetation of some type should be  grown
     on the structure in order to prevent its erosion.   In addition,
     a  fence should be installed at the perimeter of these structures
     in order to prevent their destruction by grazing cattle.

2)   Contingency provisions for overflow from a gun-barrel type
     separator  can be gained from the types of dikes and drain-
     age  discussed above.   Perhaps the best approach would be  a
     low-height  secondary  dike around the perimeter  of  the prop-
     erty.   In any case, the containment provided should be
     sufficient  to hold at least the quantity of oil-salt water
     mixture  that would be pumped from the well during  the long-
     est  period  that  the facility is expected to be  unattended.
     In addition,  the level-control  valves themselves should be
     checked  and  maintained regularly for proper operation,  i.e.,
     to be  certain that the  mechanism does not corrode  or other-
    wise  fail.

3)   The  one way  in which  to keep the area within the firewall
    clean  is to provide drainage to one  corner and  install a
    pipe and valve through  the  firewall  for  drainage.   The
    collected material  (rainwater,  BS&W,  etc.)  can  then  be
    pumped out or allowed  to  flow by gravity.   In addition to
    draining all  fluids within  the  firewall  to one  corner, if
    a pipe or even a small  open  trench were  cut  to  the  low
    corner of the facility  from the  BS&W drawdown point,  a
    cleaner operation would result.   A schematic drawing  of
    this drainage design is shown in Figure  9.

4)  When replacing pump seals, valves, or while  loading  trucks
    or performing routine maintenance, the use of buckets or
    drip pans is an inexpensive method of keeping the area
    around the facility clean.  An alternative method is  to
    maintain sorbent materials at the facility and to clean
    up the area as soon as the work has been completed.

5)  Operator errors and carelessness can be overcome with
    regular training sessions, written procedures for opera-
    tions and maintenance, and checklists that must be com-
    pleted, signed and filed.
                                34

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OJ
Ul
DRAIN OUTLET
                                                                                                      SLOPE LINES
                                                                                                       1/8" PER FT.
                                                                                                      'FLOW DITCH
     tv
/SWIVEL JOINT
r\       /
              \ SI
                                             POST WITH CHAIN TO KEEP
                                             DRAIN IN UPRIGHT POSITION
                                         3" OR 4" PIPE
                                                                     FIREWALL (CONFINEMENT DIKE)
                                                                              8: TANK DRAW VALVES
                                                                                FOR B.S. & W.
                                       SUMP

                                               NOTE: Drain outlet can be set
                                               to maintain any elevation in
                                               pit.  Drain from pit  is from
                                               bottom, hence draining clear
                                               water.
                        SECTION A A
                                     Figure 9. Suggested drainage from firewall.

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 Discussion of Existing  SPCC Plans

      Most of the  existing  SPCC  plans  reviewed during the survey follow the
 API  format but fail  to  incorporate  the engineering thinking, design and
 specification required  to  formulate a good plan.  A number of other plans
 reviewed  were simply statements  to  the effect that due to the location of
 the  facility with respect  to a waterway, no further action on the owner/
 operator's part is required, which  is valid for some cases.  The latter
 plans were found  to  predominate  in  the west Texas/Oklahoma areas where
 rivers  and streams are  very scarce.

     There is little  evidence of SPCC plan implementation other than slightly
 improved  housekeeping and  some hastily constructed firewalls.

     A  typical example  of  a completed API-SPCC plan from the Texas/Oklahoma
 area is presented  in Appendix B.  After having reviewed a number of these
 completed  API-SPCC plans,  there are several pertinent comments concerning
 the information contained  therein.  Referring to the SPCC plan in Appendix B,
 the following comments  are  made:

 Part I
     Page  1 of 3 - None of  the plans  indicated a reportable spill in the
                   12 months prior  to January 1, 1974.  This is not sur-
                   prising  for Area 1, but is almost unbelievable for
                   Areas 2  and 3.   A  reported spill would require a
                   written  description, corrective action taken and plans
                   for  preventing reoccurrence.

     Page  2 of 3 - An SPCC  plan with  this page attached was not seen.
                   This is  the heart  of the whole form for determining
                   the  adequacy of  the plan.  If properly filled out
                   with all  spill sources listed and with a sketch of
                   the  facility made mandatory, a good picture of the
                   pollution hazard of the facility would be presented.

     Page  3 of 3 - The  answer to question 8 was always "yes," therefore,
                   indicating that  it was practical to prevent oil from
                   reaching  the navigable waters:  Questions 9 and 10
                   are  always answered "yes" and the supporting discus-
                   sion is usually  similar to that shown.  However,question
                   9B was not usually answered, indicating that written
                   procedures did not exist.

Part II — Alternate B

     Questions in  this  section are fairly well answered,  with the exception
of A-2.  Most answers to this question refer back to A-l, which covers diked
 storage areas; however, very little secondary containment has been noted
 anywhere.  Attachment No. 3  is filled out but, from the time of plan prepara-
 tion, no  further records are kept.
                                     36

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     In conclusion, it is felt that the API-SPCC plan format was used to
merely satisfy the preparation of a SPCC plan which is required by 40 CFR
Part 112.  However, the guidelines for preparation given in 40 CFR 112.7
were generally not satisfied even though they were supposedly reviewed and
certified by a registered professional engineer.  Therefore, a new plan has
been prepared which satisfies the guidelines and requires more engineering
thought rather than yes and no answers to a prescribed set of questions.

Recommended SPCC Plan

     Many of the facilities surveyed in the Texas/Oklahoma area are similar-
ly constructed and have experienced essentially the same technical problems
with regard to oil spills.  Therefore, a generic SPCC plan, with options,
has been prepared for the entire Texas/Oklahoma area.  This plan is presented
in Appendix E and a brief description of its content is presented below.

     The cover sheet for the plan is basically the same as that employed by
API.  On the second sheet, under item C — Description of Facility, are
listed seven items which give all the pertinent information concerning the
physical characteristics of the facility.  It is believed that the inclusion
of a sketch of the facility is a very important item.  The work required in
preparing D — Description of Operation, will force the plan's preparer to
think carefully about how this particular facility functions.  Under item E
is a list of equipment or methods of operation designed to prevent oil spills.
The seven listed items are all covered by the API format; however, in this
plan, "yes" and "no" type answers cannot be used and the plan preparer must
again think about how the facility is to be operated.

Conclusions:  Texas/Oklahoma Area

     The following conclusions are based on conversations, observations and
data collected during this survey:

     1)  Throughout this survey, no signs of pollution of navigable
         streams  (as defined in 40 CFR Part 112.2) or adjoining shore-
         lines were observed.  Minor leaks or spills were generally con-
         fined to the immediate vicinity of the stripper-well facility
         and usually resulted from pipe connections, valves, pump seals,
         maintenance and transfer operations and poor housekeeping.

     2)  At very little additional cost to the operator, housekeeping
         and maintenance around these facilities can be improved and
         improvement in both is needed.

     3)  Joint land use areas, i.e., oil production and either  farming
         or cattle grazing, have tended to ensure that these production
         facilities do not pollute the surrounding environment, except
         that fencing is not always provided around the facilities to
         prevent grazing cattle from damaging the equipment.  The
         reason for this extra care is that the oil producer  is liable
         for any resulting damage.
                                     37

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      4}   Secondary containment by low dikes or dams,  as  discussed
          earlier,  is the most economical solution  to  pollution pre-
          vention for the on-shore production facilities  surveyed,
          but is not often employed.

      5)   The use of remote control,  visual  or audio alarms,  automatic
          operations and fail-safe systems is not feasible  for the
          stripper  operations  surveyed because of their prohibitive
          costs  and facilities being  largely unattended and in re-
          mote locations.

      6)   The cost  of SPCC plan preparation  (similar to that  shown in
          Appendix  B)  by a registered PE  is  approximately $200 in
          the area  surveyed and probably  requires 4 to 8  hours prepara-
          tion time.

      7)   The  cost  involved in implementing  the generic SPCC  plan
          (presented in  Appendix E) would depend upon  the size of
          the  facility.   However,  it  is estimated that this cost
         would  range  between  $1,000  and  $2,500 for the majority of
          facilities  surveyed  (based  on 1974 typical costs  — see
         Appendix A).
LOUISIANA AREA

Introduction and Summary

     The objectives of this portion of the study were to survey representa-
tive samples of both the water-based and on-shore oil production industry
in Louisiana, with emphasis on the Louisiana State waters area, for the
purpose of determining the technical problems these facilities are experi-
encing in complying with 40 CFR Part 112, and to recommend a number of
alternative solutions to these problems.  These solutions are in the form
of generic SPCC plans for the various categories of facilities identified
during the survey, which can be implemented by the majority of production
facility owners/operators at reasonable costs, yet provide adequate protec-
tion to the environment.  The generic SPCC plans are given in Appendix F.

     The Louisiana survey was divided into five geographical areas which
are included in the region south of highway 1-10 and bordered by the Texas
state line on the west and by the Mississippi River on the east.  These
areas are shown on the map in Figure 10 and are described below:

     •  Area 1 — The Atchafalaya Basin or Spillway is a fresh water area
                  which can only be reached by boat since there are no
                  roads.  This area serves as a floodway to take the ex-
                  cess water from the Mississippi River and deposit it in
                  the Gulf of Mexico.  The Spillway starts at Morganza,
                  on the north, and extends south about 75 miles to Morgan
                  City.  The Atchafalaya River Valley forms the boundaries
                  of the Spillway on the east and west.  The width of the

                                     38

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Sabine National
Wildlife Rafuga
       COASTAL MARSHLANDS
                             Figure 10.  Geopaphic areas of Louisiana covered by the survey.

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                   Spillway  averages  about  15  to  16 miles, with  the widest
                   point  being  23 miles.  The  survey covered the central
                   section of the Spillway  where  the averaqe water level
                   is  2.2 feet  and the  land elevation is 5 to 6  feet on
                   the average, with  occasional small rises to 8 or 9 feet.
                   When the  floodway  is open,  the water level rises to
                   14  or  18  feet, which necessitates the termination of
                   all  oil production activities  in this reqion.  During
                   the  survey,  the water level was receding from a high
                   level and averaged about 4.5 feet.  The Spillway area
                   is  a complicated maze of bayous and dredged canals and
                   required an  experienced  guide  to locate the problem oil
                   production facilities of interest in the survey (8 in-
                   stallations were visited).  The photographs in Figure 11
                   are representative of the characteristics of this partic-
                   ular area.

     •  Area 2 —  This is the Vinton field, which is just south of
                  Vinton, Louisiana.  Two  oil production facilities
                  were surveyed in detail  in  this primarily agricul-
                   tural  (rice growing) area.  Figure 12 is typical of
                   the terrain in this region.

     •  Area 3 	 This area is approached  from Johnsons Bayou on the
                  coast and is in the vicinity of the Sabine National
                  Wildlife Refuge.   Marshlands predominate here and
                   access to this region is primarily by boat.   Two
                   facilities were surveyed in detail in this area.
                  Figure 13 is representative of the terrain en-
                  countered in that area.

     •  Area 4 — Figure 14 is typical of  this primarily inland agri-
                  cultural area which is known as the Crowley field.
                  Two facilities in this region were surveyed in detail.

     •  Area 5 —  This area is in the vicinity of Avery Island and
                   includes the coastal marshlands.  Figure 15 is
                   representative of the terrain features encountered
                   there.   Only one facility was surveyed in detail in
                   this area.

     The water-based production facilities in the Louisiana coastal areas
normally produce gas and oil.  Most of the oil is a condensate, having a
fairly low specific gravity.  Salt water production ranges from practically
nothing to as high as 70 to 80 percent of  the flow from the well.   Most of
the wells in this  region are rated as gas  producing, which by definition
means that the production of gas is greater than or equal to 15,000 cubic
feet of gas per 1  barrel of oil.   However,  there are a number of wells which
produce oil as the primary product.   Oil production per well ranges from a
low of about 40 to a high of about 350 bbl  a day for most of the wells
surveyed.  The facilities visited in this  area are a very special type,
primarily due to their physical location,  and are probably not duplicated
anywhere else in the United States.
                                     40

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Figure 11 (a & b). Typical terrain features in Louisana Area 1 - the Mississippi area.
                                     41

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Figure 11 (cl. Typical terrain features in Louisana Area 1 - the Mississippi Spillway
      Figure 12. Typical terrain features In Louisiana Area 2 - the Vlnton Field.
                                      42

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Figure 13.  Typical terrain features In Louisiana Area 3 — Sabln National Wildlife Refuge vicinity.
           Figure 14. Typical terrain features In Louisiana Area 4 — the Crowley Reid.
                                           43

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-
-
                                                         Figure 15. Typical terrain features in Louisana Area 5 — A very Island vicinity.

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     Most of the SPCC plans for the Louisiana water-based facilities were
unavailable since the facilities themselves are in remote locations and
usually are unmanned most of the time.   These plans are kept primarily in
district offices which are located 40 to 60 miles from the facility itself.
The plans that were reviewed followed the API format.  They did not reflect
engineering thought in their preparation.  The pumpers who service these
facilities were, in general, not familiar with the plans but knew of their
existence.  Statements in the plans regarding inspection, training and
record keeping are minimal and lead one to believe that they are not being
implemented.

     Although no signs of oil pollution were observed in the water during
the survey, the remains of previous oil discharges were evident on many of
the adjoining shorelines.  While this evidence might have been indicative
of actual spill events from individual facilities, it may have been symbolic
of a greater oil discharge problem that is always present in the Mississippi
Spillway.  This greater problem relates directly to the functioning of the
Spillway itself.  It was indicated earlier that when the Spillway  is  flooded,
the water level can rise 9 to 13 feet above the land elevation.  When this
high water occurs, the land on which storage tanks, oil-water  separators
and collection pits are situated will be flooded, very  likely  above the  tops
of firewalls and dikes at the facilities.  Any oil or oily wastes  around the
facility's equipment, even inside the firewalls and dikes, will be washed
away.  It has also been noted that, at the time of the  survey, the water
level was receding from a high level and was still 2 to 3  feet above  the
normal level.

     The problems encountered with the on-shore facilities in  the  rice grow-
ing region of Areas 2 and 4 can easily be overcome.  The  application  of  the
secondary containment procedures as applied to the Texas/Oklahoma  area would
be quite adequate.  However, the problems become quite  difficult  in Areas  1,
3 and 5 where most of the facilities are either in the  water or directly on
the adjoining shoreline.  Preventive measures and  a  strong countermeasure
plan appear to  be the only  solution for  the off-shore wells whereas a com-
bination control and countermeasure solution would be applicable  to the
facilities on the adjoining shorelines.

Description of  the  Survey  Area

     The  terrain  in  the  Louisiana  survey region  is completely  level and  the
soil consists of  alluvial deposits ranging  from  3,000  to 8,000 feet in depth
over the  various  oil-producing sands.   At  the  surface,  the soil  is a  very  wet
sticky gumbo which  is difficult to handle.   Dikes  and  pits constructed of
this surface material are  highly undesirable  since they wash away easily in
heavy  rains.  Typical structures composed  of  this  material,  and which are
common to the survey area,  are shown  in Figure  16.

     The  vegetation  encountered in the  areas  farther from the  coast is agri-
cultural,  consisting primarily of  rice,  sugar  cane and soy beans.  Land in
this area not being  used for  agricultural  purposes supports  various grasses
and some  trees.  The terrain  closer  to  the  coastal areas is  composed pri-
marily of marshes and swamps  and contains  water  lilies, marsh grass and
cypress  forests.
                                     45

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Figure 16 (a & b). Typical containment structure* built from surface soil In the Louisiana water areas.
                                            46

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     The climate in this region is sub-tropical and the average annual rain-
fall is between 56 and 66 inches.  The evaporation rate is relatively low in
this area and therefore cannot be relied upon for disposing of the salt water
contained in open pits around many of the facilities.

Description of Facilities

     Practically all of the production in this area is obtained from flowing
wells; only one pumping well facility was observed during the entire survey.
The product obtained from this area consists primarily of gas and the oil is
largely a condensate rather than the heavy dark crude oil.  Salt water pro-
duction in the area varies from practically nothing to as much as 70 to 80
percent of the flow from the well.  The weli depth in the region varies from
3,000 to 8,000 feet, with multiple overlying oil sands.

     There are two distinct types of production facilities in this area:  the
dry-land and the water-based facility.  These facility types will be discus-
sed separately below.

Dry Land Facilities —

     The generic dry-land facility is shown schematically in Figure  17.  This
facility operates in the following manner;  The well  stream flows from  the
producing well through a line heater to a high-pressure,  low-temperature
separator  (LTX) unit which extracts the gas from  the  liquid mixture.  The
extracted gas is subsequently directed to a gas pipeline  and the  liquid con-
tinues to flow to a low-pressure  separator.  Gas  resulting from the  low-
pressure separation process  is either vented to  the  atmosphere or compressed
and transferred to the gas pipeline if sufficient  quantities are  available.
From  the low-pressure separator,  the well stream  continues to  a gun  barrel
which  separates the oil  from the  water  (a heater-treater  can  also be used).
The salt water is subsequently pumped to a  storage tank and then  disposed of
by reinjecting it into a salt water disposal well.  Salt  water disposal pits
are also available  for the storage of salt  water  in  emergency  situations.   The
oil that is  obtained  from the gun barrel is transferred to oil storage  tanks
from which  it  is delivered to trucks.  The  storage tanks  are  surrounded by  a
firewall which will normally hold the contents of the largest  vessel.   A
secondary  containment dike is constructed around  the entire lease to contain
any conceivable spill.   The  area within  the dike  is  graded and drained  to a
sump  as  shown  in the  figure.  There  are, of course,  many  variations  in  the
quantity of  equipment,  tanks, etc.,  as well as physical arrangement.  If the
well  pressure  is not  too high, the  LTX unit can  be dispensed  with,  thereby
leaving  only the gun-barrel  or heater-treator  separation  unit.   Glycol  units
are also common to  these primary gas  producing wells and  are  used to dry the
gas before  it  enters  the pipeline.

Water-Based  Facilities —

      The equipment  associated with  and the  operational characteristics of  the
water-based  facilities  are similar  to the dry-land facilities.   However,  there
are many complications  that  arise primarily because  of their  physical location.
A typical  facility  is  shown  in Figure  18.   All of the oil wells  themselves  are

                                      47

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       RICE
co
                                                     ROAD
                     NOTE:  This entrance area (X)
                            tends to be too low.
RICE
                                                                              SECONDARY CONTAINMENT DIKE
                                               OIL TO
                                               TRANSPORT
                                               TRUCKS

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                                 MARSH & SWAMP
VD
                                    WELL
                                                                                   WALKWAY &
                                                                                   DOCK ON PILES
                                                                            OIL LOADING DOCK
                                                               CANAL OR BAYOU
                                                  Figure 18.  Typical water location facility.

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 located under the canal and bayou waters.   The piers  which are used for
 loading the oil into barges are also shown in Figure  18.   Any spill or leak-
 age at these points enters directly into the  navigable  waters.  &11 of t^e
 remaining components of the facility are located on the adjoining shoreline
 where the natural drainage is into the  canal  or bayou as  shown in Figure 19
 (a).   Several other generic arrangements of the facility  equipment were ob-
 served during the survey.   Figure 19 (b)  shows a situation in which the en-
 tire  facility has been placed on piles  over the water.   In Figure 20 (a)   a
 floating barge is used (in lieu of land-based storage tanks)  to store the
 oil  and salt water.   Figure 20 (b)  is representative  of a- case in which the
 storage of the oil and salt water is in tanks on top  of a barge.   The re-
 mainder of the facility's  equipment in  the last two cases is  usually placed
 on  the adjoining shore line.   These later  two types of  facilities are not
 classified as on-shore or  off-shore types  by  the Louisiana State  Department
 of Conservation,  but are referred to as intermediate  facilities.

 The Louisiana  Department of  Conservation —

      The  Louisiana Department of  Conservation has contributed  significantly
 to the  achievement of reduced pollution levels  from the oil and gas  produc-
 tion  industry  in  Louisiana.   The  state  has been  divided into  six  districts
 for this  purpose  and  has thirty  staff members  in the  Inspection Division
 and ten  in the  Enforcement  Division.  The  Enforcement Division  provided the
 study team with an appropriate guide and means of transportation  into  the
 various oil  and gas producing areas.

     Each  production  facility  is visited by a state inspector at  least twice
 a year.  Moreover, every spill is inspected and  a report prepared  for  follow-
 up at a later date.   Some of  their  facility requirements are pertinent to the
present study and  are discussed below:

     •  Firewalls are required for  100 percent containment of all  stor-
        age vessels within a  lease only when the facilities are adjacent
        to highways, schools, hospitals, etc., or within the city  limits.
        However, specific containment requirements are not listed  for
        other situations.

     •  In fresh water areas, the disposal of  salt water is allowable
        only if its concentration is less than or equal  to 250 ppm.
        However, in salt water areas there is  no limit on the salt
        water discharge.

     •  Gas wells are classified as those with a production level in
        excess of 15,000 cubic feet per  bbl of oil,  otherwise they
        are termed oil wells.

     •  All heaters or heater-treaters must be at least  100 feet from
        the oil storage tanks unless equipped  with flame arresters.

     •  No gas may be vented to the atmosphere except  in very small
        amounts and then from only those wells classified as oil
        producing.

                                     50

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Figure 19 (a ft b). T-pical water basud facilities In Louisiana.
                           5]

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Rgura 20 (a & b). Typical barge-mounted production facilities in Louisiana.
                                 52

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     •  All open storage pits (usually for salt water and BS&W)  are to
        be deactivated and used only in emergency situations.

     •  Salt water disposal systems must be closed and the levels in
        all existing pits must be less than 2 feet from the top of
        the pit.  This 2-foot limit also applies to dikes and fire-
        walls.   All oil spills are to be cleaned up and removed from
        the facility site.

     Louisiana has classified oil wells within the state into three cate-
gories, as follows:  1) on-shore, 2) off-shore, and 3) intermediate.  The
surveys were mostly concerned with the intermediate type of oil production
facility although some on-shore facilities were inspected.  The intermediate
facilities are those located in the area where the coastal marshes begin and
terminates at the 3-mile limit.  The off-shore facilities are generally those
that lie beyond the 3-mile limit.  A recent Federal ruling has given the
authority for regulation of these off-shore production facilities to the
Federal Government.

Technical Problems Encountered and Alternative Solutions

On-Shore Facilities —

     The on-shore facilities surveyed were primarily  in Areas 2 and 4.  These
facilities generally were in compliance with 40 CFR Part  112.  Extensive use
was made of the secondary dike for containment purposes.  The only weakness
observed at these facilities was in their access  roads, which tended to be
lower than the remainder of the dike.  Figure  14  clearly  shows this condition.
An inexpensive solution to this problem would  be  to install a small ramp over
the top of the dike to allow for the flow of traffic  without damaging the
dike.  A similar situation exists for the facility shown  in Figure  21 where
all of the drainage comes to a low point, just to the right of the  entrance.
An inexpensive solution to this problem would  be  to install a dike  across
the road with a sump and  sealed drain valve  in the lower  corner.

     Within the secondary containment dike,  minor oil spills appear at the
truck-loading facilities  (see Figure 14), the  BS&W draw-down valve  and the
pumps.  These leaks rarely get beyond the lease area  itself and are generally
cleaned up, leaving only  a black stain on the  ground.

     Salt water pits should be used only  in  emergencies,  since the  evapora-
tion potential  of  this area  is nil.  A closed  system  for  the disposal of the
salt water should be installed and  the reliance,  as  in the past,  on open pit
disposal should be discontinued.

     Pit dikes  are generally  in  poor condition primarily  because  of the  use
of improper materials  and in  the manner  in which  they were constructed.
Figure  22  shows a  pit  dike that  was used  for salt water and  BS&W containment.
The wall was breached,  letting oil  run out  into  the  ditches  and  sugar cane
fields.  The clean area  (repaired)  inside  the  pit is  where the  break  occurred.
Heavy  rain on top  of the  full  pit  apparently overtopped the  dike to cause  this
spill.

                                     53

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Figure 21. Typical arrangement where access road forms a breach in secondary containment dike
               Figure 22. Contaquences of a poorly designed salt water pit dike.
                                         54

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     The installation of fences around the entire lease would be desirable,
since it would prevent cattle from damaging the secondary containment dikes
and prevent vandals from entering the facility area.

Water-Based Facilities —

     The water-based facilities surveyed were primarily in Areas 1, 3 and 5.
As noted previously, Louisiana has an intermediate facility classification
which is neither on-shore or off-shore.  Off-shore facilities do not have
off-shore storage tanks and are compact enough to make use of drip pans and
sumps.  These facilities are also manned around the clock and have sufficient
automatic equipment to shut down promptly in an emergency.

     The facilities in Areas 1, 3 and 5 are alike in all respects except that
the Area 1 facilities are in the Spillway, which is a fresh water region.

     Salt water production from these wells cannot be directly input into
the Spillway unless it is in concentrations of less than or equal to 250 ppm.
Areas 3 and 5 are salt water and there is no restriction on the disposal of
salt water resulting from the oil production operations.

     In all of the installations encountered in this area, space is at a
premium.  The facilities are generally built on top of the canal dredgings,
or on wood piles with a timber platform, or on wood piles with concrete
platforms.  The platforms supporting the storage tanks generally have only
a 6-inch concrete curb  (see Figure 23  (a)) or a metal tray  (Figure 23  (b))
to prevent small leaks from entering the water.  Protection against a tank
rupture is generally nonexistent at these facilities.

     At many of these installations, pipes generally run  from the  facility,
unprotected from leaking into  the water, to land-based storage tanks as  shown
in Figure 24.

     All three of these areas  are subject to tropical storms and,  in the
Spillway, flooding  from the Mississippi  River is always a threat.   In such
situations, the oil production operations must be  terminated and the facili-
ties secured until  the hazard  has passed.

      In these areas, salt water pits  should only be used  for emergency pur-
poses because they  are  generally  severely damaged  by either heavy  rains  or
high tides.

     As a result of the entremely heavy boat  traffic  in many of  the canals
and bayous, the banks  are experiencing severe  erosion  problems  as  shown  in
Figure  25  (a).  This problem can  be  solved by  the  installation  of  bulkheads
similar to that shown  for another facility  in  the  lower  photo of Figure  25  (b).

      Since most of  these  facilities  are unmanned between the  hours of 5  p.m.
and  7  a.m., any problems  that develop can go undetected  for as  long as 14 hours.

      The  delivery  of equipment to this area  must be  by barge,  boat or airplane.
In either of  these  cases, the costs  associated with  this mode of transport  are
very high.
                                      55

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Figure 23 (a & bl.  Typical minimal leak protection at platform-mounted water-based facility.
                                        56

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•
                                                    Figure 24. Typical unprotected over-water piping at water-bated facilities.

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Ftffura 26 (• & b).  Wat«r traffkHnduced bank orouon at • watar-baaad facility (a) and typical buHchaads utad to
                   corract tha arotion problem (b).

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     The types of problems that have been encountered in this region preclude
the use of any simple and/or inexpensive containment procedures.

     At the present time,  the recommendation is for a strong countermeasure
plan which would depend heavily on the use of booms to contain and control
an oil spill.

     For installations along the shoreline, some grading or ditching to a
sump can be employed to contain minor leaks or spills.  The grading should
be performed in such a manner as to direct the spilled material to the water-
way rather than into the marshes where it will be very difficult, if not im-
possible, to clean up.

     A closed system for the disposal of salt water should be installed at
all installations.  Provisions should also be made to recirculate BS&W and
oil spilled  from normal operations.  Before the accumulation of this material
becomes too  great, it should be removed from the site.

     During  maintenance and transfer operations, the use of drip pans should
be encouraged as an inexpensive method of preventing spills.

Discussion of Existing SPCC Plans

     Most of the existing SPCC plans are very  brief  and  reflect  the  lack  of
effort employed in their preparation.  All of  the  SPCC plans reviewed during
the survey have followed the API format.   Moreover,  there  is little  evidence
that any changes have been made to  the  facility as  a result  of the  prepara-
tion of the  SPCC plans.   It  is more likely that the  plan was prepared based
on what existed at the facility at  the  time of plan  preparation.

     Appendix C contains  three  SPCC plans  which represent  the most  complete
and satisfactory of  those that were reviewed  during  the  survey.   The plan
for Facility #1  is by far the  best, and it has been implemented,  as can be
seen by  referring  to Figure  14.

      The  plans for Facilities  #2  and #3 were  rated better  than  average;
however,  there were  some  discrepancies.   Facility #2 includes  an off-shore
well,  and Part 1,  page 2  describes potential  spills from lines  between the
well  and the on-shore facilities.   However,  Part  II, Alternate  B, pages 1
and 2,  describes  the on-shore facilities,  but the information concerning
 spills from these is not  included on page 2 of Part I.   There are also con-
 flicting answers to  questions 7 and 8 in Part I.

 Recommended SPCC Plans

      A series of recommended SPCC plans for the generic types of on-shore
 and water-based facilities in the Louisiana Area are presented in Appendix F.
 As in the case of recommended plans for the Texas/Oklahoma area, a key feature
 of these plans is that they are designed to prompt considerable thought  on the
 part of the owner/operator, and to preclude the use of  "yes" or  "no" answers
 to a set of prescribed questions.
                                      59

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 Conclusions:  Louisiana Area

      The following conclusions are a result of conversations, observations
 and data collected during this survey:

      1)  For on-shore facilities, very few signs of pollution were ob-
          served except in the immediate vicinity of the lease.  With
          respect to the intermediate locations, even small leaks con-
          stitute a spill event, and a number of them were observed as
          oil-stained shorelines.

      2}  Tank ruptures pose more of a pollution threat to inter-
          mediately located facilities than to the on-shore facili-
          ties.

      3)  Housekeeping and maintenance could be improved throughout the
          entire area without expending a significant amount of funds.
          In the intermediate locations, there are not any land owners
          to keep the facility operator in line; however,  the State is
          doing an excellent job in this respect.

      4)  A closed system for salt water disposal  and drainage from
          leaks or spills should be implemented at the intermediate
          locations.   The use of pits  should be abandoned,  except in
          emergency situations.

      5)   In areas where  there is  an excessive  amount of boat traffic,
          erosion of the  neighboring shoreline  has been significant.
          The installation of bulkheads  is  one  way of countering this
          problem.

      6)   The cost of pollution  controls  or countermeasures  at the
          intermediate  locations will be  high.   Floating booms for
          spill  control costs in the neighborhood  of  $12 per foot.
          Materials  for the construction  of dikes,  bulkheads,  etc.,
          must be brought  to  the site by  boat,  which  is  also expensive.
PENN-GRADE AREA

Introduction and Summary

     The objectives of this portion of the study were to survey a represen-
tative sample of the stripper-well industry and bulk-oil distribution facili-
ties in the Penn-Grade area (Pennsylvania, Ohio and West Virginia) in order
to determine the problems these facilities are experiencing in complying
with 40 CFR Part 112; and to recommend a number of alternative solutions to
these problems.  The solutions will be in the form of generic SPCC plans for
the various categories of facilities identified during the survey aimed at
cost-effective implementation requirements and providing adequate protection
of the environment.  The generic SPCC plans are presented in Appendix G.
                                     60

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     The area covered by this survey includes the oil production and fuel
distribution facilities operating along either side of the Ohio and Allegheny
Rivers from Point Pleasant, West Virginia, to Bradford, Pennsylvania.  A map
of the survey area is shown in Figure 26.  Among the many sites surveyed in
the Penn-Grade area are those that represent some of the earliest production
in the U. S.

     All of the oil production facilities visited in this area were of the
stripper-well type which, by definition, produce less than 10 bpd.  However,
the majority of the stripper wells surveyed produce far less than 3 to 5 bpd.
According to the figures quoted in the National Stripper Well Survey (January
1, 1975), Ohio production averaged 1.2 bpd/well, West Virginia was 0.55 bpd/
well, and Pennsylvania was 0.29 bpd/well.  The total number of wells in the
Penn-Grade area is about 61,000, with a total annual production of 12.5 million
barrels.

     The wells that produce the oil in the Penn-Grade area are owned/operated
by individuals ("Ma and Pa" operators); small independents  (30 to 100 wells)
and larger commercial organizations such as Kendall, Quaker state and Pennzoil.
Quaker State and Pennzoil account for nearly 30 percent of the total produc-
tion from this area.

     Representative SPCC plans from West Virginia, Ohio, and Pennsylvania are
given in Appendix D.  The general formats for these plans are almost identical.
From the survey it was estimated that approximately 30 to 50 percent of the
"Ma and Pa" operators had SPCC plans, whereas up to 90 percent of the small
independent operators had prepared plans and all of the larger commercial
companies had plans.  Obtaining ownership data  for the  "Ma and Pa" operators
on a timely basis was almost impossible because of the frequency with which
the facilities changed hands and the general unavailability of the owners.

     No evidence of any major spills involving  the bulk distributors was
found and very little evidence of even  small spills was noted.  For  the
stripper-well facilities, even though the daily production  is  small, a sub-
stantial spill potential exists since many of these  facilities go unattended
for very long time periods.  Several months  is  routine and  no  attendance  for
as long as  a year is not uncommon.  Frequently, the only person who  sees  any
part of the facilities during these periods  would be  the pumper.  Even then,
he might see only the storage tanks, which are  often  some distance  removed
from the rest of the facility.  Moreover, for low-production wells,  the  inter-
vals between collections can be many months.  The  storage tanks  for  the
stripper facilities generally had a capacity of 100  bbl, with  an occasional
facility having a 200-bbl-capacity tank.  Spills  from these facilities,  in
the event of a tank rupture, would probably  not approach  100 bbl  since  the
tanks are not often filled to that capacity, depending on the  collection
schedule.   Nonetheless,  the potential  does exist.   Spills observed in the
Penn-Grade  area generally  were  the result of tank overfilling, leaking pump
packings and leaks  in the  pipelines leading  from the wells  to  the storage
tanks.
                                      61

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                                                  /  NEW YORK
                                                     Bradford .
                                                        TUNA CREEK
                                           Warren
                                      Titusville
     | Meadville
          •A
                                    A Oil City

                                     ALLEGHENY RIVER
    Canton +(~~)
                                                 PENNSYLVANIA
                             Pittsburgh
                                 MONONGAHELA RIVER
        Clarington 9
              'A
                                               MARYLAND
New Matamoras*
 Marietta
New Martinsville
             Burning Springs
               LITTLE  KANAWHA RIVER
         WEST VIRGINIA
                                             OIL PRODUCTION
                                         A  BULK DISTRIBUTION
         Charleston
            KANAWHA RIVER
      Pettu$ABeckleV
        Figure 26. Map indicating tht Penn-Grade area surveyed.
                              62

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Description of the Survey Area

     The terrain in the Penn-Grade area is mountainous and rugged.  The par-
ticular survey area follows river valleys with mountains on either side,
and the flood plains vary from practically nothing to as much as 2,500 feet.
Figure 27 depicts typical urban area terrain (in this case, at Oil City,
Pennsylvania).  The soil in this area is of the residual type, weathered in
place from sandstone and limestone with little or no alteration by transport.
The ground is covered with grasses and plants and the hills are heavily wooded
with pine and hardwood forests.  Generally, the climate is rather severe
along the Allegheny River, with long cold winters and warm but short summers;
however, along the Ohio River, the climate is somewhat milder.  The rainfall
in this area varies between 30 and 35 inches annually.  Evaporation is reason-
ably high, but not sufficient to be a factor with respect to oil spills reach-
ing waterways.  Stream valleys are numerous, and stripper wells are not very
far from one or more streams.

Description of Stripper Well Facilities in the Penn-Grade Area

     The survey covered over twenty different stripper-well facilities con-
sisting of about 125 distinct wells.  The entire production of the Penn-Grade
area is a paraffin-based oil which, when refined, produces a  superior grade
of lubricating oil.  This type of oil separates from water easily, so the
equipment needed in the production process is less complicated than required
in other areas of the country.  In this respect, gun-barrels, heater-treaters
and oil/gas separators are not required.

     The facilities generally consist of two 100-bbl oil  storage  tanks which
are interconnected to prevent overfilling.  The tanks are usually located
below the well or wells and along or adjacent to a highway or all-weather
access road.  In about 20 to 30 percent of the facilities surveyed, a  single
100-bbl storage tank was in use.  These tank batteries  are generally connected
to from one to twenty wells which are located anywhere  from 50 to 1,200 yards
from the storage tanks.  All of the wells  in this area  are being  pumped and
it is common  to see a number of them interconnected through sucker rods or
cables to a central source of power.  The well depth  in the Penn-Grade  area
is shallow and generally varies between 700 and 1,500 feet.

     The recovery of oil  from  these wells  is by secondary means.  By  far the
dominant secondary recovery method is fresh-water flooding and, as a  conse-
quence, increasing amounts of  salt water  are generated  with the passage of
time.   In this area, when wells are on primary recovery,  the  salt water quan-
tities  are nil.  But, when water  flooding is employed,  the fresh  water pumped
down takes on salt as  it passes through the  formations.  The  resultant oil-to-
salt water ratio  is low  at first, but  increases gradually as  the  oil  pool  is
depleted.  The producers  have  found that  water  flooding can be employed for
about  15 years before  the economic  limit  is  reached.   Generally,  salt water
production in the  area  is not  high  enough to create  a difficult disposal  prob-
lem.   As  a rule, water production does  not currently exceed 50 percent of the
well  stream  and  the evaporation rate  is  high enough  to keep the problem under
control if proper  disposal techniques  are employed.   This means a well-designed
salt water collection  pit, equipped so  that the  water can be siphoned off at

                                     63

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Rgure 27 (a & b). Typlc.l urban area terrain In tha Pann-Grada araa.

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                   Figure 27 (c). Typical urban area terrain in the Perm-Grade area.
controlled rates.  Gas has also been used to pressurize  these wells but the
geologic structure is too porous for it to be effective.

     The diking of tanks is not normally practiced  in this area,  primarily
because of the difficult terrain.  However, the  area around the tank battery
is usually graded to drain into a pit.  These pits  are generally equipped
with a siphon-type overflow, as indicated by Figure 28,  leading directly to
natural drainage swales, brooks, and dry runs.   The drainage areas are normally
clean; however, in a few cases a scum of oil has been observed on some of these
surfaces.  In areas where wells are remote  from  the tank batteries, water
knockouts and pits have been installed.

     The majority of pumping units are  electrically operated and many are on
time clocks.  The average well is pumped only once  or twice a day for periods
ranging from 15 minutes to 2 hours.

     Most of the pumping units are not  visible  from the tank battery because
of their location in the woods.  The  layouts  of  two complete facilities of
this type are schematically  shown  in  Figures  29  and 30.

     The facilities depicted by  Figures 29 and  30 are operated by  two  distinct
independents.  The  facility  shown  in  Figure 29  represents two adjacent leases
in West Virginia.   The  three wells on the  Lucas lease produce a  total  of  6  bpd,
while  the two wells on  the  Schultz  lease  produce 7 bpd.  All piping for these
                                      65

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APPENDIX 4 - SKETCH 1
                                               Witer Knockout.
                                                42 Gal. Drum
                                                (See Photo 65)
                                                                      _ Oil to Tanks
                                                                        by Gravity
  Well &
Pumping  Unit
                                                              Water Knockout •
                                                              (See Photo 74)
 -Well Stream

100 bbl.
Storage
Tank
\<



                                                                                       Water to Pit
                                                                       '-• A0f Tank to Pit
                        Figure 28.  Typical stripper facility arranpnwnt in the Pann-Grad* are*.

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Notes:
  • Piping for this
    facility  is com-
    pletely  underground.
  • ~2000 CF  of gas/day
    flared
  • 3 Lucas wells (6 bbl/day)
  • 2 Schultz wells  (7 bbl/day)
                                        Old Town Creek

                                          $  Lucas  2
                               \  X/  Farm
                                  NV      House

                                 0\
                           Brick  Home    \
                                                                       Legend:
                                                                              Oil Wells
                                                                              Oil Storage Tanks
              Figun 29.  Multiple w»ll nripptv facility layout, Wert Virginia.
                                           67

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                                                                         Legend:

                                                                               Oil Wells
                                                                               Storage Tanks
                                      Elev 60±
                                                                           Elev 15±
These two
Wells pump
  to Road
Storage Tanks
                                                   NOTES:
                                                   17 wells  producing 30 bbls/
                                                   day. All  wells feed to tank
                                                   by gravity except two noted.
                                                   All  pits are not shown.
                                                   Area covered about 2000 ft
                                                   x 2000 ft  (not to scale)
                                                   Pipe above ground except for
                                                   road crossings.
            Figure 30.  Multiple Well Stripper  Facility  Layout,  Pennsylvania.
                                            68

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two leases is underground because of the joint land use (between oil produc-
tion and farming)  provisions in this area.   Photographs of the properties are
shown in Figure 31.

     The lease represented in Figure 30 consists of 17 wells located in a
forested area of Pennsylvania.  The total production from the lease is about
30 bpd.  Figure 32 illustrates the appearance of the property.

     Figure 33 depicts the property of an independent operator in Pennsylvania
having 60 wells and 10 storage tanks, and which produces about 50 bpd.  The
lease is long and narrow and runs from a creek across flood plain to a high-
way, across the highway and up along the hillside.  Figure 33  (a and b) shows
one of the tank batteries.with water knockout similar to that shown in the
schematic drawing of Figure 28.  Figure 33 (c) represents a typical electric-
ally operated well installation and Figure 33 (d) shows a typical pit in the
flood-plain area used to catch discharged water and spills.

     A typical small off-highway/hillside production operation is shown in
Figure 34.  The facility consists of the three pumping units  shown  in Fig-
ure 34  (a); the tank battery with water knockout appears in Figure  34  (b).

     Many other installations were visited during the survey;  however, it
would be repetitive to discuss all of them here.

Technical Problems Encountered

     The technical problems encountered  in the  Penn-Grade area stem primarily
from the following set of circumstances:  1)  nearly all of  the oil  is being
produced by the application of secondary recovery methods,  mostly water
flooding; 2)  the production from any given well is uncertain  at  all times,
and 3) new wells must be  drilled each year to maintain current production
levels.  A new well costs in  the neighborhood of $12,000  (at  1974  cost  levels).
In order to recover the drilling costs,  this  new well must  produce  between  20
and 40 bpd for a  time period  of  2 to 6 weeks.  Thereafter,  the production rate
decreases to  less than 1  bpd.  If a  new  well  is able  to perform in  this  manner,
the operation is  considered productive;  if not, it  usually  results  in a loss
to the owners/operators.

     The  technical and operational problems  in  this  region  result  essentially
from inaccessibility  of  the  area.  The  rugged terrain and normally heavily
wooded areas  presented here make access  for  equipment maintenance  and the
construction  of  dikes and pits very difficult.   For these reasons,  backhoes
are normally  used in  place  of bulldozers for dike and pit construction,  and
the  installation of pipe (above  or below ground) usually involves  an in-
ordinate  amount  of very  expensive hand labor.

      In order to maintain production in cold weather, the pipes and tanks
must be heated.   Because of the  costs involved  in heating the equipment,
 the facilities are not  normally  operated during the very cold weather.

      Another operational problem that results in technical difficulties is
 that these wells are  operated on an intermittent basis.  The total pumping

                                     69

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Figure 31 (a » b). Details (wall location) of multiple well stripper facility In West Virginia (see Figure 29).
                                                   70


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Figure 31 (c & d). Details (storage tanks) of multiple-well stripper facility in West Virginia (see Figure 29).
                                                'I

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Figure 31 (a ft f > Details (wall location*) of multiple well stripper facility In West Virginia (see Figure 29).
                                                72

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            •  .
     •
           ®£A*-* • -•
-
    ngur. 32 (a & b). Data.lt (.tor-fl. tank.and draln.g. pit) of muhlpl.-w.ll trippa, facility In P.nn.ylvanla (see Rflur. 30).
                                                        73

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Figure 32 (c&d).
D.tail. (production well and .torag. tank) of murtipl.-w.il stripp.r facility In P.nn.ylv.ni. f.M R8ur. 3,,
                                                       74

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Flgur. 32 (a & f).
Detail, (production w.ll and dr.ln.fl. pit) of muttlpl.-w.H «ripp.r f.c..rty ,„ P.nn.y.v.nl. (n. Rflur. 30).
                                      75

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         f a 80-well rtrlpper facility In Pennsylvania.
76

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                                                                                               &&
Figure 33 (c). Details (electrically operated well) of a 60 well stripper facility In Pennsylvania.
       Figure 33 (d).  Details (disposal pit) of a 60 wall stripper facility in Pennsylvania.
                                          77

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FI8ur« 34 (a & b). Detail* (production wall* and .torage tank.) of a typical amall off-hlghway/hlll«lda production unit
                Penn Grade area.
                                                    78

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time for an entire week may be 4 to 6 hours,  which usually occurs in 15-minute
time intervals several times a day.  This intermittent operating mode leads
to occasional pipeline plugging which is the  source of many small leaks.
Moreover, it also causes problems in the packing glands at the pump, which
then must be replaced.  These sources of leaks are frequent in the Penn-Grade
area; however, they are minor because if undetected for a day, they will only
result in 1 or 2 barrel spills at the maximum.  Usually the total spillage
from this source is much less.

     Dikes around the oil storage tanks associated with the stripper wells
are practically nonexistent for the "Ma and Pa" and small independent pro-
ducers.  The larger commercial operators such as Quaker State have constructed
some dikes around their facilities, followed by pits.

         The solutions to many of these technical problems involve the ex-
penditure of funds for increased maintenance or the construction of adequate
dikes or pits.

Discussion of Existing SPCC Plans

      All of the SPCC plans reviewed during the survey were of  the  same basic
format.  One simple SPCC plan from each of the three  states surveyed  is shown
in Appendix D.   If these forms are properly filled out, they  should  represent
adequate SPCC plans.  However, it  is worth noting that the Professional
Engineers retained by the  facility owners have not indicated  that  they were
familiar with the requirements of 40 CFR Part 112.   This  latter statement  is
required as indicated in 40 CFR  Part 112.3.d.

     A number of the  SPCC  plans  have stated that due  to the smaller  production,
on a daily basis from these wells, the  installation  of containment structures
for well heads  and flow lines is uneconomical.  Moreover,  statements  have
appeared in several of the SPCC  plans  indicating  that materials, manpower  and
equipment  for control and  clean-up are  available  in  the event of a spill  that
threatens a waterway.

Recommended SPCC Plans

     Two stripper-well  facilities  representative  of  the  Penn-Grade area were
chosen  and  SPCC plans prepared.  The first facility  produces  30 bpd of  oil
from a  total  of 17 wells  — this situation is typical of  a small independent
operator in the Penn-Grade area.  The  second  facility is  of  the "Ma and  Pa"
variety, with two  wells  producing  about 1 bpd each.   The  recommended SPCC
plans  for  these facilities appear  in Appendix G.

Conclusions:   Penn-Grade Stripper-Well Production Facilities in Area Visited

      The following conclusions are based on  observations, conversations and
data taken during the survey:

      1)   The results of this survey support  the conclusion that with the
          small  and intermittent oil production from each of the facili-
          ties and in consideration of the difficulties of the  terrain,

                                      79

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          a very good job is being done to minimize the occurrence of
          spills.  The small well-head and pipeline spills observed were
          confined to the immediate area surrounding the facilities and
          in most cases did not pose a threat to nearby water courses.

      2)  The pits and ditches used for containing water and spilled oil
          are generally adequate for the type of production operation
          that exists in the Penn-Grade area, however,  they should be
          upgraded to meet the requirements of the Oil  Pollution Preven-
          tion regulation, i.e., 40 CFR 112.7 (e)  (2)  ii.   in almost all
          of the cases observed, the automatically siphoned fluid from
          these pits did not contain a significant quantity of oil.   How-
          ever, in a very few cases, some salt water was being siphoned
          from the ditches.   This is not a serious problem now but could
          develop into one in the future.

      3)   Compliance with the Oil Pollution Prevention  regulations is
          fairly good except in the cases of the "Ma and Pa" type of
          production operations.  The reason for this situation is that
          these operators either do not know of the existence of the
          regulations or prefer to ignore them because  they have not
          had spills in the  past and are willing to run the risk of
          fines and/or operation shutdown in lieu  of expending funds
          for environmental  protection that they believe is unnecessary.

Description of Bulk Plant Facilities in the Penn-Grade Area

      Eighteen bulk  distributors were surveyed in  detail in the Penn-Grade
area.   The  layouts  and locations were similar to  those found in the New England
area  and  are as follows:  facilities in crowded city areas;  those located  in a
valley between hills and in proximity to  a stream;  facilities  located  on a
terrace between a hill and  a water course;  those  located  at the foot of  a  hill
and adjacent to a highway or railroad,  and facilities  located on a  bluff.   •j$i&
facilities  are briefly described below.

      Figure  35 is a plan drawing of a 75,000-gallon bulk  marketing  facility
located in  a valley between two hills and  in  the  vicinity of  a creek.  Fig-
ure 36 gives  different views of the facility  showing its  various  features.
At the time  of the  survey,  a floating boom was  planned for permanent installa-
tion  in the  creek in the  event  of  a major  spill from the  facility.

     Figure  37  presents views of a 41,000-gallon-capacity bulk  distributor
located on the  terrace of a steep  hillside.   Figure 37  (a)  shows  the terrain
and underground tanks which are  filled  from the top levels.  A highway is
located about  50 feet to the right  of  the  facility, followed by  steep hill-
sides.  At the  extreme left center  of  the picture is a  railroad which parallels
the highway.  All of  the drainage  from this facility is toward  the railroad,-at
which point the  owner has plans for  the construction of a  retention wall.
ure 37  (b) shows the  loading rack at the facility.

     Figure 38  illustrates  a 56,000-gallon bulk distributor which is located
in a valley between two hills.  Figure 38  (a) shows the storage tanks and

                                     80

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                                            -Up
                                                                            Highway Level
Up-
00
                          Private Residence
                                Boom & Sorbent
                                Material Storage

[
I— 1
1


Loading Rac


Pumps
ca
	 1
1 	 1
k

jj Service Station

1 15K | | 25K L-

1 tSK | | 10K |

i

i
'

1

Private 'Residence


Gasoline

— Containment Dike

                      Boom to be
                      Installed Here in
                      Event of Spill
                                                                           Steep Hills


                                                 Figure 35.  Layout of a 75,000-gallon bulk plant—Penn-Grade area.

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Figure 36 (a & b). Views of • 76,000-gallon bulk plant - Penn-Grade area.
                                82

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            &S&'

Figure 36 (c).  Views (stroam where boom i» to be installed) of a 75,000 gallon bulk plant - Penn Grade area

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Figure 37  (• & b).    A 41,000-gallon bulk plant on a steep hillside location P«nn Grade area
                                            84

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Figure 38 (a & b). A 56,000 gallon bulk station in • valley between two hillt - Penn-Grade area (note earthen
                 containment dikes at rear of both photographs).
                                                  85

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Figure 38 (c 6 d). A 66,000-gallon bulk plant In a valley between two hill* - Penn Grade area.


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loading rack followed by hills; off to the right is a creek which precedes a
railroad and a highway.  Beyond the dike shown in Figure 38 (b)  is a creek
which turns to the left beyond the dike.  The dike extends along the left
side of the property line to turn water from the hillside to the creek.
Figure 38 (c) shows the highway and railroad bridges to the right of the
facility (Figure 38 (a)).  The last, Figure 38 (d), shows the color coding
of fuel lines at the facility.

     The bulk distribution facility shown in Figure 39 is located in a crowded
city area.   Figures 39  (a) and (b) show the undiked tankage across the rear
of the property.  In Figure 39 (c) , the loading rack and fencing along the
right side of the property is shown.  Figure 39 (d) shows the front of the
property and the direction of the drainage to the rear of the facility.  A
spill from this facility would flow into a culvert located 150 yards away
from the facility property line.  The SPCC plan for this facility calls for
a dam and clean-up ahead of this culvert.  Dikes were not considered for
this particular facility because the tanks are located practically on  the
property line.

     Figure 40  (a) illustrates a bulk oil distribution plant having a  capacity
of 149,000 gallons.  The  facility  is located on a bluff, from which a  terrace
was excavated and the  tanks set in.  On the open  side of the terraced  area,
a dike has been constructed and is  shown in Figure 40  (b) .

      In all of  the facilities  visited,  almost 100 percent  of them had  adequate
lighting, valves with  locks and locked  electrical controls.  However,  fencing
surrounding  the entire facility was absent  in almost  4  out of  5  cases.

Technical Problems Encountered

      The technical problems encountered at  the bulk-storage facilities in the
Penn-Grade area are listed below:

      1)  General maintenance  of  facilities  was  not  quite as good as the
         housekeeping, and there  was  a  need in  some  facilities for  re-
         pair of  leaking valves,  and  sandblasting and painting of corrod-
         ed  pipelines  and vessels.  This was covered  in the facility SPCC
         plans  but  not followed  up.

      2)  Many of  the  facilities  were  constructed in limited space with
         the property bordered by highways, railroads,  rivers  and occu-
         pied property on both sides.   Also noted were V-shaped areas
         between  highway and/or railroads and streams with occupied
         property at  the open end of  the V.  Many of these facilities
         had natural  dikes  on one or  more sides.   An explosion or tank
          rupture  in these small areas could cause oil spillage beyond
          the facility limits.

      3)   Security lighting and locked valves were generally adequate,
          but fencing was lacking in many cases.  Fencing should be
          called for on all prepared SPCC plans.
                                      87

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Figure 39 (a ft b). Bulk plant In a congested city area - Penn Grade area. This facility does not have any containment

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Figure 39 (c fr d). Bulk plant in a congested city area - Penn-Grade area. Undiked area shown as well as drainage
                collection area for facility.
                                                  89

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Figure 40 (a ft b). A 149.000 gallon bulk plant located on a bluff - Penn-Grade area. Dike construction shown around i
                new tank installation.

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    4)   For hillside locations, containment can be provided in most
        cases by dikes, earth or masonry, and natural barriers.  One
        weakness noted in containment was at driveways where dikes
        are interrupted.  A solution to this problem would be to con-
        tinue the dike and provide ramps as required for truck access.

    5)   Loading on or adjacent to highways.  In one facility the tanker
        truck parks in the street where spillage could follow the street
        drainage to the nearest catch basin.  Although this is a small
        facility, there is sufficient area for tankers to pull into the
        facility and maneuver to a new unloading facility at the bottom
        of the street embankment.  The second facility is small and all
        loading is adjacent to the street.  A small concrete wall should
        be built along the edge of the property with ramps at either end
        for truck access and egress.

    6)  Color coding and labeling of lines and valves was lacking in
        many cases.  It is recommended that this be done in all cases.
        This is not an expensive  improvement and will certainly avoid
        unnecessary operational errors that can lead  to  spills as well
        as  improving  facility  safety.

    7)  Transfer operations at bulk-loading  facilities  occur  several
        times daily with a high probability of at  least a  small amount
        of  spillage in connecting and disconnecting the transfer  hoses.
        Provisions must be made  to catch these small  spills.   The use
        of  drip pans  at the hose  connections  is  an inexpensive way of
        avoiding these types of  spills.   Containment  pits  or  concrete
        aprons with catch  basins  and sump drains  must be provided in
        case of  a  premature truck departure;  overfilling of tanks;
        leaky valves,  connections, hoses and pipes.

Discussion of  Existing SPCC Plans

     Although  existing SPCC plans were not obtained for these facilities,  many
of the  sites surveyed  had  SPCC plans  that, in general, were implemented.

Recommended SPCC Plans

     The recommended SPCC plans for the Penn-Grade area survey of bulk plants
are almost identical with those observed during the New England survey.
Therefore, a discussion of these plans will be presented in the New England
survey analysis section of this report.

Conclusions:  Bulk Stations in the Penn-Grade Area

     The  following conclusions resulted  from the survey:

     1)   The trade associations in the Penn-Grade  area  are very active
          in campaigning for the preparation of SPCC plans by  their
          members.
                                     91

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      2)  Almost all of the distributors have prepared SPCC plans and
          implemented them.

      3)  No spills have been experienced at any of the facilities visited.

      4)  As in most of the other areas, especially with the very small
          bulk distributors, protection against a tank rupture resulting
          in the spilling of the entire contents of the storage vessel
          has not been accounted for in the implemented SPCC plans.  This
          latter situation is inconsistent with the guidelines section of
          the Oil Spill Prevention regulation (40 CFR 112.7 (e)  2 ii).

      5)   No drainage records from these facilities are being kept at the
          present time.

      6)   In the preparation of SPCC plans,  Registered Professional Engin-
          eers are concentrating on spill containment only and by the
          nature of the  plans resulting are  probably unfamiliar  with the
          other provisions of the regulations,  especially those  dealing
          with truck loading,  locked valves, fencing,  electrical,  etc.

      7)   Many of the distributors have spent between $600 and $1,500 for
          engineering services to prepare SPCC plans and  from a  few hundred
          up to $15,000  for facility improvements.

NEW ENGLAND AREA

Introduction and Summary

      The  objective of this portion  of  the study was to survey a representa-
tive  sample of the bulk marketing-distribution industry  in the New England
area  with the  intent of determining the  technical problems these  facilities
are experiencing in complying with  40  CFR Part 112, and  to recommend a
of alternative solutions  to these problems.  These  solutions  will be  in the
form  of generic  SPCC plans for the  various  categories of  facilities identi-
fied  during the  survey.   During  the New  England area survey,  two  generic
facilities  were  identified and SPCC plans prepared.  The  generic  SPCC plans
are presented  in Appendix H.

     The New England Survey area included the States of Maine, New Hampshire
Vermont, Massachusetts, Connecticut, and Rhode Island.  The cities visited in
each of these  states were as follows:

     Maine                      New Hampshire           Vermont

     Augusta                    Portsmouth              Barre
     Chisolm                    Manchester              Springfield
     Livermore Falls
                                     92

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     Massachusetts                Connecticut             Rhode  Island

     Boston                      Bridgeport             Providence
     Wellsley
     South Weymouth
     Avon
     Hanover
     Pembroke
     Duxbury

     A detailed map of the New England survey area is shown in Figure 41.

     The type of facilities visited in this area were bulk oil marketing out-
lets, handling primarily #2 fuel oil for home heating.  In some of the smaller
towns, however, regular gasoline and kerosene were also available for farm use.
The quantity of oil products stored at these facilities varied from as little
as 50,000 gallons in the smaller inland towns to as much as 2,000,000 gallons
in the larger cities along the coast.  Specifically, the type of facilities
visited were a papermill, 13 independent bulk plants, and 3 major oil company
distribution outlets.  There were also two basic types of facilities that
were encountered during the survey.  The first type of plant covered a very
small area and was squeezed in between railroads, highways and adjoining
properties.  Examples of this type of facility can be seen in Figure 42.  The
second type of facility had an ample amount of land, but the terrain and drain-
age presented problems to the facility owner.  Examples of this type of  facil-
ity can be seen in Figure 43.

     SPCC plans were available for review  at each of the facilities surveyed.
The plans did not follow any specific format and varied from a few pages in
length for the smaller facilities to as much as twenty pages for  the larger
ones.  Each of the plans reviewed included a detailed schematic drawing  of
the facility; however, in these plans there was no mention of security measures
taken at the sites.

     The spill experience in this area was found  to be very good, with no
spills in excess of  500 gallons reported,  and these were infrequent.  Most
of the spills encountered were caused by personnel errors and were generally
a result of overfilling a tank or associated with truck loading or unloading
operations.

     The  economic  impact  of the  regulations  appears  to be  a very  strong  issue
among the  smaller  independent bulk marketing dealers.   As  a direct result  of
this  issue, many of  the  smaller  dealers are  just  not complying with  the  regula-
tions.   On  the other hand,  the  larger dealers are complying with  the  regulations.

Description of the Survey Area

      Proceeding inland from the ocean,  this  region  of the country progressive-
ly becomes more  hilly and mountainous.   The  geology of this area is generally
glacial till overlying metamorphic and  intrusive rocks with frequent and ir-
regular outcrops.   A course stratified  drift is predominant in the upper drain-
 age  systems whereas silt and clay deposits are  generally found at the mouth

                                      93

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Figure 41.  The New England survey area.
                  94

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Figure 42 (a & b). Typical bulk plant on «queezed-ln «tte - New England area.
                                  95

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Figure 43 la & b). Typical bulk plant with ample space, but with terrain and drainage problems - New England area.
                                                 96

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of the rivers.  In some areas along the Atlantic  coast,  coal  ash and  other
industrial wastes were used for landfill.   This activity resulted in  making
the soil extremely acid and unsuitable for underground storage tanks  because
of potential corrosion problems.

     The vegetation in this region consists of numerous heavily wooded areas
and some farmland.  The climate is mild during the summer months, with average
temperatures in the 68  to 70 F range whereas the winters are rather  cold,  with
the average temperature in the 20  to 35 F range.  The rainfall for this area
varies from 30 to 45 inches per year.

Description of
     The majority of the facilities visited during this survey were small
independent fuel-oil distributors.  In addition, one industrial plant and
several fuel-oil distributors owned by the major oil companies were also
visited.  This section of the report is devoted to a discussion of those
facilities and the measures being undertaken by them to comply with 40 CFR
Part 112.

     Industrial paper plant (New Hampshire) — This plant, shown in Figure 44,
was built during the early 1800s and is located on the east bank of the
Kennebec River.  The fuel oil storage for this facility consists of a new
50,000-gallon cathodically protected underground storage tank.  The feed line
from the tank runs on the ground over a steep bank and then under railroad
tracks  into the power house.  At the top of the bank, where the fuel delivery
trucks  deliver the fuel oil, there  is no protection against spills, thereby
making  the cemetary to the left of  the tank vulnerable to  spills.  At the
time of the survey, a small curb was being constructed and an area graded to
flow to the left into a 4 ,000-gallon-capacity pit  (this is the volume con-
tained  in one compartment of the tank truck) .  A concrete-lined trench will
also be built under the entire length of the fuel  feed line except where it
passes  under the railroad tracks — in this area the pipe  will be buried.
On the  other side of the  tracks, a  culvert will be constructed which leads
into a  concrete basement  of an abandoned building  — this  concrete basement
is capable of holding 50,000 gallons of fuel oil  (the capacity of the tank).

     Small Independent Fuel Oil Distributor  (Maine) — In  maine, two similar
installations were  found  and Figure 45 depicts  one of them.   The highway that
passes  in  front of  the facility is  12 to 15  feet higher than  the storage tanks,
and in  the rear of  the facility is  the Androscoggin River. On the  side  of  the
facility,  the ground  is higher at  one end.   In  order to safeguard against
spills, a  dike has  been built along the river  side and extends around both
sides  to  the tank battery.  This  dike has  sufficient capacity to contain the
contents  of  the largest tank.  The lighting  at  this facility  was very adequate
and the entire property was fenced  except  for  the  entrance area.   The  loading
rack,  however, was  separately fenced and under  lock.  Housekeeping  at  this
 facility appeared to  be very good.   The total  fuel storage was  198,000  gallons,
 of which 32,000 gallons consisted  of kerosene  and  the remainder  was #2  fuel
oil-
                                      97

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                                                                                        1
Rgura 44 la ft b). Fuel oil unloading dock and piping at a Naw Hampshire paper mill.
                                  98


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                                                                                            ,
•-
                           Rgure 46 (a & b). Small Independent bulk plant In Milne.
                                                 99

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      Large Fuel Oil Distributor  (New Hampshire) — This installation is locat
 at the head of Portsmouth Harbor on the mouth of the Piscataqua River.  The
 facility is surrounded by a street on one side and water on the other three
 sides.  No diking presently exists at this facility.  The installation pres-
 ently handles only #2 fuel oil in four tanks:  two 350,000-gallon,  one     ""
 300,000-gallon and one 10,000 gallon.

      This facility was not in business at the time of the survey,  as far as
 storage was concerned, and was for sale.  However, a good SPCC plan costino
 $2,000 had been prepared for this installation and the design changes are
 represented in Figure 46.  The total estimated cost of implementing this plan
 was approximately $20,000.                                                  TO

      When the facility was  in operation, fuel oil  deliveries were  received
 by barge.   At the time of the survey,  however,  the firm's delivery trucks
 were  driving to a large terminal  in Portland, Maine,  to obtain the  fuel oil
 at 1/2  cent/gallon cheaper  than delivery by barge.

      Large  Fuel Oil Distributor (Connecticut)  — This facility is  located i
 Bridgeport  Harbor on a short canal  leading out from Long Island Sound.   The
 site  is  illustrated by Figure 47.   The  storage  capacity for  this facility is
 2,000,000 gallons  of fuel oil.  A drawing of its SPCC plan is shown by Fig-
 ure 48.   In complying with  OSHA,  NFPA,  USCG,  and EPA regulations, the  facilit
 owner stated that  he was  spending in excess of  $140,000 to improve  the instal-
 lation.  Up to the time of  the  survey,  the following  improvements had  been
 made  at  this  facility:  Sandblasted and reworked all  storage tanks,  repaired
 or replaced all pipes  and manifolds and color coded them,  installed a  foam
 system in case of  fires,  provided a boom around barges,  installed high-level
 alarms,  and provided sumps  and  curbs around truck-loading  facilities.   All Qt
 this  work resulted in  a considerable loss  of  sales  because of the long  shut-
 down  times  required to  complete the work.

      The entire area surrounding the facility is enclosed by  a concrete wall
 which shows some weathering.  It was planned that this wall would be repaired
 or replaced as required;  however, work on  this part of the project was  to  be
 delayed for a  while, since it would require the loss of more  operating  time
 and thus sales.

      Small Fuel Oil Distributor in the Center of Town  (New Hampshire) 	
 facility was located on the main street of the town and was about 150 feet
above the Merrimack River, which lies 3/4 of a mile east of the facility  (30
Figure 49).  Directly under the facility lies a combined storm and sanitary
sewer and a catch basin is located on the property  (lower right in Figure 49)
The fuel oil storage facilities consist of 11 horizontal 20,000-gallon tanks *
in two groups of 6 and 5 tanks, respectively.  Each group of tanks is complete.
ly diked and has its own loading rack.  The entire facility has been asphalted"
and is completely fenced for security.

     The facility is bounded on two sides by streets, each having a locked
gate entrance.  The left side of the property is high and slopes about 5 feet
to the other side where a concrete retaining wall has been constructed,
it not for the city sewer line,  any spill could easily be contained.  The

                                    100

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Figure 46.  SPCC plan layout for a largt indapandent bulk plant in New Hampshire.

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Figure 47 la & b).  Large bulk plant In Connactlcut.
                    102

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Figure 47 (c).  Large bulk plant In Connecticut.

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•qpt	i fjf-
                                         ^si  *M
Figurt 48. SPCC plan layout for a large independent bulk plant in Connectkut

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                        Rgura 49. Small bulk plant in N«w Hampshire.
righthand group of tanks drains to a new 4,000-gallon hold  sump, which  is  lo-
cated between the tank and the existing catch basins.  For  the  lefthand group
of tanks, any. spill would enter the sewer; in the event of  a minor  spill,  a
sand barrel and shovel are available for preventing  this  from happening.   In
the case of a major spill, a front-end loader is available  to position  the
15 tons of sand normally kept at the facility.

     Small Fuel Oil Distributor  (Vermont)  — This facility  is shown in  Fig-
ure 50 and is probably the worst installation surveyed in the New  England  area.
The diking is inadequate and the housekeeping is rather poor.   The  facility
is long and narrow  (250 feet by 50 feet) and is bounded on  one  side by  a
street and on the other by Stephens Branch, which empties into  the  Winooski
River downstream about 5 miles.  The total capacity  of this facility is about
100,000 gallons, consisting of 5,000 gallons of 80-octane gasoline, 15,000
gallons of hi-test gasoline, 15,000 gallons of regular gasoline,  20,000 gal-
lons of kerosene and  the balance of about  45,000 gallons  consisting of  #2  fuel
oil.

     The existing dike begins at the garage and extends  along the  river bank
and returns to  the  street.  The area under the tanks is  only 8  or  10 inches
below street level, and any spill would  gravitate  to a  low spot between the
tanks and  the street.  The SPCC plan for this  facility  called for containment
of 15,000  gallons in  lieu of the 20,000-gallon capacity  of the  largest tank

                                     105

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                       Figure 50. Small bulk plant No. 1 in Vermont.
(this is inconsistent with the guidelines section of the  Oil  Pollution Pre-
vention regulations 40 CFR 112.7  (e) 2 ii) and a 1.7-foot-high  dike  with a
zero bottom area and a 2,350-square-foot top area.  The existing  dike  is 3
feet high, but it does not protect the street area.  Any  major  spill would
run by the dike and enter Stephens Branch.  The lighting  at this  facility is
adequate, but the three tanks in the foreground have been leased  out and have
no fencing.  The cost of the preparation of the SPCC plan for this facility
was $440.  However, it appears that this money was  wasted in  view of the
remaining spill potential of this facility.

     Small Fuel Oil Distributor  (Vermont) — The facility shown in Figures 51
and 52 is in fairly good condition with the one exception of  security  fencing.
The general drainage pattern for this facility  (see Figure 51)  is directed
toward the catch basin for a city storm sew*er.  During heavy  rains,  water
accumulates in the vicinity of the horizontal storage tank battery and must
be drained from this area.  Even a minor spill during this time could  create
some potential problems.

     A concrete block wall begins behind the office building  (Figure 51)  and
encloses three sides of the horizontal tanks.  The  area under the tank battery
averages 10 inches below the grade level outside of the tank  area where the
city storm sewer catch basin is located.  A full tank rupture would  probably
flood toward the loading rack and street.  In order to prevent  this  from
                                     106

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  5 mi 1 to Conn River
FiguraSI.  Layout of mall bulk plant No. 2 in Vermont

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Rgura 62 (• & b). Small bulk plant No. 2 In Vermont.
                   108

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..
                               Figure 52 (c & d). Small bulk plant No. 2 In Vermont.




                                                  109

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 happening, the concrete block wall should be extended so as to enclose the
 entire tank battery.

      Small Fuel Oil Distributor (Massachusetts)  — This distributor has a
 main plant that has been in the family for three generations and has recentl
 purchased four additional facilities within a range of 20 to 25 miles.  The
 total capacity of all of these facilities is 255,000 gallons,  with 70,000
 gallons at the main plant and between 40,000 and 50,000 gallons at each of
 the remaining facilities.   The SPCC plan for this operation does not have
 writeup,  instead it lists tank capacities, personnel,  telephone numbers of
 EPA,  fire departments,  etc.,  material available  for spill clean-up and a
 drawing of each installation  showing contours, containment capacities and
 other improvements.   To date  (time of the survey)  this facility owner had ex-
 pended $45,000 for improvements, with another $10,000  anticipated for the n
 future to complete the  work.   A good deal of ingenuity has been displayed in.**
 adapting  the  natural terrain  to his facilities'  requirements.

      The  main plant (shown in Figure 53)  is completely fenced  and the hous
 keeping and lighting are excellent.   The  seven 10,000-gallon storage tanks
•are on  high ground in the  rear of  the facility.   The containment volume was
 obtained  by constructing a crosswalk between the building and  telephone pole
 (top  photo of Figure 53).   The wall  on  the opposite  side  of the tank battery
 has been  constructed in such  a manner as  to divert a spill  into the  contain-
 ment  area.  The  concrete loading pad with the catch basin also drains to th
 containment area.

      Figure 54  shows a  50,000-gallon facility located  between  two  highways
 one lower than  the  facility and the  other higher than  the facility.   A 50  000
 gallon  polyethylene-lined  pit  which  catches  all spills  and  rainwater  at thi
 facility  is also shown  in  Figure 54.  The valve from the  pit leads to a dr
 well  for  the  disposal of clean water.

      Figure 55  shows  a  40,000-gallon  facility which has had only a small c  x
 installed beyond the  tanks and in  front of  the highway.   This  curb turns all
 of the  spilled material  into a natural grass-lined depression  capable  of
 containing the contents  of the largest tank.

Technical Problems Encountered

      Figure 56 shows a typical tank battery  installation.  The number of tank
 in a  battery generally varies between 3 and  5 and occasionally there are c    S
binations of both horizontal and vertical storage tanks within a battery    TV.
most  common situation is to have 3  to 5 horizontal storage tanks, each havi   G
a capacity of between 10,000 and 20,000 gallons.   The loading and unloadina ^
of these  tanks usually occurs along the long dimension of the facility.  Th'
 type  of facility can usually hold within its dikes the contents of the  lara
 tank  plus the accumulated rainfall.  Although a tank rupture which releases
 the contents of the tank in a very  short period of time is rare, the force
and velocity of the emerging fluid  could easily surge over the top of the
dike.   Another event, not quite as  rare as a tank rupture, is the occurrenc
of a  hole in the tank.  This latter situation can occur from tank corrosion
or a bullet hole.  For a typical 10-foot-high (completely filled) tank, th'

                                     110

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Flgura 63 (. ft b). Sm.ll bulk fu.1 dl.tributor in Ma^chu.«u. m.ln pl.nt.
                               Ill

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                  Figure 64. Small fuel distributor In Massachusetts, Branch Plant No. 1.
Figure 56. Small bulk fud distributor in Massachusetts which UMS natural topographical futures
          (daprauion in around) to catch a potential spill from storage tanks.
                                             112


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                                    70'
o
CM
                      VERTICAL  TANKS (12' Diameter)


            Cont.  Area (70 x 20  - 37r62) 7.5 =  7950 gal /ft of height
                                     70'
 ID
 CS1
                             HORIZONTAL TANKS

                   Cont.  Area 70 x 25 x 7.5 = 13,100 gal /ft pf
           Figure 56. Typical bulk station tank battery.



                                  113

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 latter situation would cause a stream of  fluid  having  a velocity of ~25  fps.
 If the tank were 16 feet above the  ground (typical height), then the stream
 of fluid would pass over the dike.   In order  to overcome this problem, a
 secondary dike and/or  possibly some grading of  the area exterior to the  tank
 battery would  be required.   The most favorable  solution, however, would  be  to
 extend the dikes to a  distance of 25 feet from  any tank and to include the
 truck  loading  and unloading  racks within  that expanded area.  This solution
 would  eliminate  the need for two separate drainage systems, one for the  truck
 and the  other  for the  tank battery.   In addition, an overall lower dike  height
 would  be required.

     In  some cases  drainage  from these dikes  is from the low point of the
 interior surface.   Moreover,  at other facilities, engineers have specified
 oil/water  separators to  be incorporated into  the drainage systems,  it is
 our recommendation  that  a sump 36 inches  square and 36 inches deep be placed
 inside the dike.  In this sump, a pipe should be positioned 6 inches from the
 bottom surface to ensure draining only clean  uncontaminated water from the
 diked area.

 Operating Procedures

     The operating  procedures  followed by the bulk oil marketing facilities
 generally  fall into two  categories:   those concerned with the larger facili-
 ties which are located on the  coastline and those that are followed by the
 smaller  inland dealers.  For  the larger facilities, these procedures are in
written  form and  follow  to the letter  the  EPA and USCG guidelines.  In the
 case of  the smaller facilities, the  procedures  are fairly simple and are not
 in writing.  For  the latter case, of most  interest here, the fuel oil is
 generally delivered by transport trucks during  the normal working hours.
 The rules that are  generally  followed  at  the  facility are:  No smoking,  shut
off truck motor,  connect truck to ground  system, check all valves (truck and
 facility) for proper flow, gage tanks  and  fill.  When this procedure has been
 completed, reverse  the procedure.  The delivery trucks are manned by employees
of the facility who are  constantly being drilled on clean-up procedures.  For
 this reason, these  trucks always carry shovels  and sorbent material for clean-
up purposes.

Discussion of Existing SPCC Plans

     All of the  installations  visited  in New  England had SPCC plans prepared.
 These plans were  in report form and  generally contained the following informa-
 tion:

     1)  Name of  company, location,  personnel and persons to notify
          in the  event of a spill

     2)  Verbal description of  the facility,  a  layout drawing of the
          facility and the types of oil stored

     3)  Direction  of drainage
     4)  Material available for clean-up
     5)   Containment volume required and how  to provide it.

                                     114

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     The preparation of the facility drawing was the plan's most important
feature, particularly in those cases where contours and elevations were
noted.  However, very little information was given for operating procedures,
lighting, security, and housekeeping, except for the >200,000-gallon storage
facilities.  The impression left by these plans was that the preparers were
not familiar with the specific requirements of 40 CFR Part 112.

Recommended SPCC Plans

     Recommended SPCC plans for bulk plants of the type encountered in New
England would be broken down as follows  (typical SPCC plans for each of  two
generic facility types are shown in Appendix H):

     1)  Company Information — Name, location, list of officers and
         personnel  in charge of spill prevention

     2)  List of agencies to notify in the event of a spill

     3)  Spill  history

     4)  Facility Description  — In addition to listing  tanks  and
         capacities, equipment, trucks,  etc.,  and  spill  clean-up
         materials  on hand, a  drawing of the entire  facility  should
         be made to include property lines, streets,  buildings,
         dikes, related  equipment, contours of key elevations, and
         drainage patterns

     5)  Spill  containment  (including dike materials,  volume  and
         design)*

         a)   Drainage  (see  40 CFR Part  112.7  (e)  1)

         b)   Tanks (see 40  CFR Part 112.7  (e)  2)

         c)    Facility  transfer pumps  (see  40  CFR Part 112.7  (e) 3)

         d)    Loading racks  (see  40  CFR Part 112.7 (e)  4)

      6)   Inspection (see 40  CFR Part 112.7  (e) 8)

      7)   Security  (fencing,  lighting,  valves)  (see 40 CFR
          part  112.7 (e)  9)

      8)   Personnel training (see 40 CFR Part 112.7 (e)  10)

      9)   operating procedures.
 * can be shown on a drawing under Item 4.


                                      115

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Impact of SPCC Plan Implementation

     The technical problems associated with the bulk marketing facilities in
complying with 40 CFR Part 112 generally are not difficult to solve.  Many
facility owners in the New England area have spent in the range of $10K to
$50K for spill containment only.  However, in many of these cases, the problem
of security  (fences, lights, etc.) has been overlooked.  This latter item, if
included in the facility modification, could result in substantial additional
funds expended by the owner/operator.

Conclusions

     1)   The spill experience in this area is quite good, with the
         largest spills in the range of 500 gallons.  Most of these
         spills have been caused by personnel error rather than
         equipment failure.

     2)   A Massachusetts dealers' association estimated that of its
         450 members (which  represent about 1/3 of the total dealers
         and about 75 percent of the volume of business in the state),
         that about 100 have not complied with the Oil Spill Preven-
         tion regulations and would prefer to close their businesses
         rather than comply.

     3)   The engineers in the New England area generally have not used
         the volume of the largest tank (rather,  75 to 85 percent of
         the largest tank) to calculate the required containment volume
         for the  various facilities.   This situation is counter to the
         requirements of the  guidelines section of the Oil Spill Preven-
         tion regulation (40  CFR 112.7 (e)  2 ii).

     4)   Security and lighting generally have  been overlooked at many
         of  the facilities visited, primarily  because  the engineers
         preparing SPCC  plans  in  this area are unfamiliar with the
         details  of  40 CFR Part 112.

     5)   The  costs associated  with the preparation of  SPCC plans  in
         this  area have  been  in the  $400  to $5,000 range,  whereas  the
         cost  of  implementation has been  in the  $5,000  to  $50,000  range.
                                    116

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                              BIBLIOGRAPHY
1   Aerial Surveillance Spill Prevention System, Environmental Protection
    Technology Series, August 1972.

2   Annual Production by Active Fields — Oil & Gas Division, The Railroad
    Commission of Texas, 1973.

3.  Annual Summary,  Industrial Fishery Products — 1972, U.  S. Department of
    Commerce, January 7, 1974.

4.  Annual Summary,  Industrial Fishery Products — 1973, U.  S. Department of
    Commerce, April  3,  1974.

5.  climate-logical Data —  Annual  Summary 1974  (for Texas,  Oklahoma,
    Louisiana, West  Virginia, Pennsylvania,  New Hampshire,  Vermont,  Massa-
    chusetts, and Maine), Environmental  Data Service,  National Oceanic and
    Atmospheric  Administration, U.  S. Department  of Commerce.

6.  Control  of  Hazardous Material  Spills.   In:  Proceedings of  the  1974
    National Conference on  Control of Hazardous Material Spills, American
     Institute of Chemical Engineers,  San Francisco, California,  August 25-28,
     1974.

7.  Fitzgibbon,  D.  S.,  Historical  Statistics (Fish Meal,  Oil and Solubles),
    U. S. Department of the Interior, U. S.  Fish  and  Wildlife Service,
    Washington,  D.  C.,  October  1969.

o   Gas-Oil Ratio Calculations,  The Railroad Commission of Texas, Oil and
     Gas Division, Revised October 1970.

 a.  General Conservation Rules and Regulations of Statewide Application,
     State of Texas, The Railroad Commission of Texas, January 1, 1974.

10.  Geological Surveys  (for Texas, Oklahoma, Louisiana, West Virginia,
     Pennsylvania, New Hampshire, Vermont,  Massachusetts, and Maine),  u. S.
     Geological Survey, U. S. Department of the Interior, 1973.

11.  industrial Fishery Products, Economic Analysis 1-20, National Oceanic
     and  Atmospheric Administration  (NOAA), Market Research  and  Service
     Division, Washington, D. C., February 1974.

12   Louisiana Oil Marketers Association, listings by  Districts  and  Parishes,
     June 30, 1974.


                                     117

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  13.  Menhaden  —  Natural  Resource  from  the Pastures of the Sea, National
      Meal and  Oil Association, National Fisheries Institute.   '

  14.  The Most  Essential Ingredient in Ohio Contractor's Liquid Handling On*.
      tions, Solid Waste Magazine,  March 1974.                           "pera-

  15.  National  Stripper Well Survey, Interstate Oil Compact Commission
      National  Stripper Well Association, January 1, 1973.

 16.  National  Stripper Well Survey, Interstate Oil Compact Commission,
      National  Stripper Well Association, January 1, 1975.

 17.  1974 National Trade and Professional Associations of  the United Stat
      and Labor Unions, Vol. IX, Columbia Books, Inc.,  1974.                S

 18.  Oil Pollution Prevention, Vol. 38,  No.  237,  Part  II,  u.  s. Environmental
      Protection Agency,  Washington, D.  C.,  December 11,  1973.

 19.  Oil Spill  Containment Systems   (Second  Edition), u.  s. Environmental
      Protection Agency,  Washington, D.  C.,  January 1973.

 20.  Oil Spill  Control Survey  for Onshore and Offshore Facilities,  Ameri
      Petroleum  Institute,  March 1970.                             'an

 21.  Oil Spills of Hazardous Substances, U.  S.  Environmental  Protection
      Agency,  Division  of Oil and  Hazardous Materials,  Washington, D.  c.

 22.   Oil Spill  Treating  Agents (a compendium),  American Petroleum Institut-
      Pro ject  #OS-6. May  1,  1970.                                          te'

 23.   Oil Spill  Treating  Agents (a compendium),  American Petroleum Institut
      Publication No. 4150,  Revised  1972.                                    •

 24.   Oil Spill  Treating Agents Selection Based  on Environmental Factors
      Report to  American Petroleum Institute Committee  for Air and Water'
      Conservation, American Petroleum Institute, Publication No. 4068
      October 1970.                                              *      '

25.   Pederson,  J.  A., Cost-Price  Study of Producing Stripper Wells, Annual
     Meeting, National Stripper Well Association, October 22, 1973.

26.  Petroleum  Facts and Figures, American Petroleum Institute, 1971

27.  Petroleum  Systems Reliability Analysis,  Vol.  II — Appendices,  u  s
     Environmental Protection Agency, Washington,  D.  C.,  August 1973

28.  Proceedings of the Joint Conference on Prevention  and  Control of oil
     Spills,  American Petroleum Institute and Federal Water Pollution
     Administration,  New York,  N.  Y., December 15-17, 1969.

29.  Purser,  P.  E., EPA Spill Prevention Control and Countermeasure Plan
     Fact Sheet, Environmental  Protection Agency,  Washington,  D. c.      '


                                    118

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30.  The Railroad Commission of Texas, Annual Report, Oil and Gas Division,
     1973.

31.  stripper Production Down but Future Bright, The Oil & Gas Journal,
     January 7, 1974.

32.  A Study of Commercially Important Estuarine-Dependent Industrial Fishes,
     Louisiana Wildlife and Fisheries Commission, Technical Bulletin No. 4,
     December 1972.

33.  Suggested Procedures for Development of Spill Prevention Control and
     Countermeasure Plans, American Petroleum Institute Bulletin D16, First
     Edition, March 1974.

34.  systems Study of Oil Spill Cleanup Procedures,  Industry Response Plan,
     Vols. I and II, Report to the Committee for Air and Water Conservation,
     American Petroleum Institute, February 1970.

35.  Texas Oil and Gas Conservation Laws, Title 102, Revised Civil Statutes
     of Texas, The Railroad Commission of Texas, January 1971.

36.  Wholesale Trade — Petroleum Bulk Stations and  Terminals, 1967  Census
     of Business, U. S. Department of Commerce, December 1970.
                                     119

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                               APPENDICES


 APPENDIX A.  COST ESTIMATING DATA FOR ENGINEERING SOLUTIONS TO Oil
              PREVENTION AND CONTROL


      This appendix presents unit cost data employed in developing the
 estimated costs for construction and equipment installations recommends
 elsewhere in this report for oil spill prevention and control  at the
 production and distribution facilities of interest.   To provide a stand
 reference baseline,  nearly all  of the unit costs  given below were taken
 from Means'  Building Construction Cost Data.  1974.*  There  are two exce
 tions.   One is the towboat-barge costs that are necessarily incurred In
 moving  construction  materials  and equipment to water-based  facilities in
 the Louisiana  area,  where  cost  data  were obtained directly  from service
 contractors.   The second exception is the cost figures  for  sump tanks
 which were  obtained  directly from vendors.                            '

      In  all  cases, the  cost data given here (Tables A-l through A-3)
 tend  to  be  conservative, essentially because no allowance has  been made
 for inflation  since  1974 (i.e.,  the  cost figures  are  in 1974 dollars)
 In  addition, the  cost figures do not include the  normal general con-
 tractor's profit  margin, since facility  owners/operators frequently'Der
 form  the work with their own personnel.   Other factors that would need
 to  be considered  are (1) prevailing  wage  rates in various areas of the
 country and  (2) the accessibility  of a site and its distance from avail
 able  labor and equipment.   With  respect  to prevailing wage rates  it
 should be noted that the Means data  include installation labor and are
 based on costs averaged for 30 major  urban areas across the country
The effects of the accessibility and distance factors can vary widely
The owners, operators, and contractors experience, as indicated durirm
the surveys, has  been that the added costs for transportation of
materials and equipment, along with workers' travel time can add as much
as  50 percent to the costs for getting work done at water-based facil-i
ties in Louisiana and up to 25 percent in the  more remote sections nf
the Penn-Grade Area.
  Building Construction Cost Data,  1974.  32nd  Annual  Edition,  Robert
  Snow Means Company,  Inc.,  Duxbury,  Massachusetts,  1974.
                                 120

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      TABLE A-1.   CONSTRUCTION  AND  EQUIPMENT  COSTS  (INSTALLED)
                   Item
Cost/Unit
Concrete, slabs 4" to 5"  thick

Concrete, 8" walls up to  3'0" high

Concrete catch basins, with frame and grate

Polyethylene liner, 6 mil.
                    8 mil.

Floating booms

Fence (chain link), 6' high with 3 strands
   barbed wire, 2" posts, 9 gauge steel

Fence, field, wood posts, with  4 strands
   barbed wire

Clearing land (small trees) manual

Valve, 3" gate

Valve, 4" gate

Pipe, 3" steel

Pipe, 4" steel
Underground Drains:

       6" Concrete pipe
       Trench excavation, machine
       Trench excavation, manual
       Trench backfill, machine
       Trench backfill, manual

Earthwork:

       Excavation, machine
       Excavation, manual
       Dike fill, machine
       Dike fill, manual
       Grading, manual
       Fill material, hauled in
       Drainage ditch
       Excavated material, haul out
$1.50/sf
 160/sy

 450 ea.

 .045/sf
 .048/sf
 12.00/lf


 10.00/1 f


 4.00/1f

 .30/sy

 120 ea.

 200 ea.
 6.00/1f
 7.00/1f
 2.50/1f
 2.00/cy
 10.00/cy
 •60/cy
 3.00/cy
 1.00/cy
 10.00/cy
 2.25/cy
 6.00/cy
 1.00/cy
 3.00/cy
 16.00/100  If
 •80/cy
                                 121

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TABLE A-2.  COSTS FOR EARTH DIKES
Cost/If
Top Width
IS-
IS"
18"
18"
Costs for Lou1
Costs for
barge delivery
Slope Height
1 on 1^ 18"
24"
36"
48"
cy/lf
.17
.26
.52
1.10
Manual
$1.02
$1.56
$3.10
$6.60
Machine
$ .39
$ .59
$1.17
$2.48
siana Water-Based Facilities
mobilization of material and equipment and
are estimated to be
$1 ,200 per
TABLE A-3. COSTS FOR SUMP
Diameter * Length Capacity
(ft) (bbl)
4 x 10
4 x 12
5x8
5 x 10
5 x 12
6 x 10
6 x 12
6 x 14
22
26
28
35
42
50
60
70
Weight
(lb)
1580
1840
1720
2045
2365
2542
2930
3315
facility.
TANKS
Cost
($/lb)
0.85
0.85
0.85
0.85
0.85
0.85
0.85
0.85
tow-boat


	 • 	 _
Total Cost
(each)
$1,343
1,570
1,462
1,739
2,010
2,160
2,490
2,818
              122

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APPENDIX B.    SAMPLE OF EXISTING  SPCC  PLANS  FOR THE  TEXAS/OKLAHOMA
                 REGION

                  (friar t» commit I ing Fart I, refer to rrgiilntUMi ami itutrvetia** pagt S.)

           SPILL PREVENTION  CONTROL & COUNTERMEASURE  PLAN
                                        PARTI
                                GENERAL INFORMATION
      1. Nameof facility.
      2. Tnrtf"~"»r  Onshore Production Facility
      8. Location of facility  San *«tricio  County
      4.  Name and address of owner or operator:

             Name    Management Company

             Addrew _	
                      Corpus  Christi, Texas   78401
      6. Designated person accountable for oil spill prevention at facility:

             Name and title.	,	
      6. Facility experienced a reportable oil spill event during the twelve months prior to Jan. 10, 1974
          (effective date of 40 CFR. Part 112). (If YES, complete Attachment #1.)          	

                                 MANAGEMENT APPROVAL
                      This SPCC Flan will be implemented as herein described.

              Signature _	———	

              Name	__—_____—.

                      Production  Superintendent	

                                      CERTIFICATION
      I hereby certify that I have examined the facility, and being familiar with the provisions of 40
      CFR, Part 112. attest that this SPCC Finn has been prepared in accordance with good engineering
      practices.
                                             Printed Name of Registered Professional Engineer

      fSeal)                                  —_-_«_—_—_—_.—--—_—_«—^_______^_^___________^_
                                             Signature of Ueiristercd Professional Engineer

             7/7/74	      Registration No	State.
                                                               (Part 1)  Page 1  of 3
                                           123

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                                        I'AKT I
                              GENKKAL INFORMATION



 7.  Potential Spills — 1'redictimt & Control:

                                Total
               Major Type      Quantity         Rate        Direction       Secondary
   Source      of Failure        (bbls)        (bbls/hr)      of Flow*     Containment
   Discussion:
•Attach map if appropriate.
Name of facility.

Operator	
                                                                      (Part I) |'W i of ,
                                      124

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                                 PARTI
                         GENERAL INFORMATION


                    to ffalemcnl* thmtU la: YES. NO, orNA (Not Applicable).]

8.  Containment or diversionary structures or equipment to prevent oil from reaching
   navigable waters are practicable. (If NO, complete Attachment #2.)            Yes
   Inspections and Records
   A. The required insi>ections follow written procedures.                        Yes
   B. The written procedures and a record of inspections, signed by the appropriate
     supervisor or inspector^are attached.
             ! Inspection  procedure  calls  for a check of  the water's
     odor, clarity and taste, prior to draining the dikes.  The
     presence of  any concealed pollutant that might occur at  this
     facility can be easily ascertained  in this manner.   Should this
     check indicate a pollutant  present,  then a chemical analysis
     will be performed before the  water  is drained.   The Drain Valve
     will be kept sealed in the  closed position except  when draining
     operations are being conducted.—Draining  operations will be
     conducted  by a responsible  person.	
10. Personnel, Training, and Spill Prevention Procedures
   A. Personnel are properly instructed in the following:
      (1) operation and maintenance of equipment to prevent oil discharges, and     Yes
      (2) applicable pollution control laws, rules, and regulations.                 Yes
      Describe procedures employed for instruction:  Personnel are  given  verbal
      instruction in operation  and maintenance of equipment and	
      applicable operating problems are discussed.   Only experienced
      personnel are  utilized in the operation of this facility.	
    B. Scheduled  prevention briefings for the operating personnel are conducted fre-
      quently enough to assure adequate understanding of the SPCC Plan.       Yes
      Describe briefing program:  The  plan  is  discussed verbally with all
      personnel involved in  the operation of this  facility.   In	
      addition to the plan,  all known  spill  events,  failures, mal-
      functioning components,  and recent developed precautionary
      measures are  discussed.	
  Name of facility.

  Operator	
                                                               (Part I) F*Kt S ft 3
                                   125

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          (Prior to completing /'art //, Allmuttt D, rtftr tv rifulaliont mul inntruetiaiu paf» t.)

                            PART II. ALTERNATE B
                     DESIGN AND OPERATING INFORMATION
                      ONSHORE OIL I'RODUCTION FACILITY

               IKtupanm to ttattmentu ikouU ke: YES, NO. or NA (Not AjtptimhU).']


 A.  Facility Drainage
   1.  Drainage from diked storage areas is controlled as  follows (include operating  description
      of valves, pumps, ejectors, etc.): Drainage from  all  diked  storage areas
        is  accomplished  by means of a manually operated valve.  The
        drain valve will be sealed in a  closed position except wheTT"
        actual draining  operations are being conducted.           	
   2.  The procedure for supervising the drainage of rain water from secondary containment into
      a storm drain or an open watercourse is as follows (include description of (a) inspection for
      pollutants,  and  (b) method of valving security). (A record of inspection and drainage
      events is to be maintained on a form similar to Attachment ?±3):   fA)  Prior to
        opening drain valve,  water is checked for odor,  taste  and"	
        clarity.   Should  the  presence of pollutants be  suspected!	'
        then a chemical analysis J8~obtained.    (B)  Drain  valve la	
        manually operated  and remains sealed except while rain water"
        is actually oeing  drained. ~A record is maintained ot  all	'
        draining events                                  ~~~	
   3.  Field drainage ditches, road ditches, and oil traps, sumps, or  skimmers, if such
      exist, are inspected at regularly scheduled intervals for accumulations of oil.      Yes
      Describe inspection procedures, intervals, and methods employed to remove oil: All a ugh
        places on  this  facility where oil might accumulate are  visually
        inspected on  a  daily  basis.   All accumulations of oil  are ro'_
        moved  immediately.  Means of  removal may  be a hand-held bucket
        or i«Ttable pump, or  a vacuum truck as dictated by the  size"
        and location  of the accumulation.                             •—
B. Bulk SI oraRt Tanks
  1. Describe tank design, materials of construction, and fail-safe engineering: features-The
       tanks on this lease are standard API  tanks  and are in service-
       able condition.   Adequate capacity is provided..	
  Xante of facility.

  Operator	
                                                      (I'.rt II. Allmulr II) l»«r, | of j
                                    126

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                          PART II, ALTERNATE 11
                   DESIGN AND OPERATING INFORMATION
                    ONSHORE OIL PRODUCTION FACILITY

              (Rr«jmm
-------
                           SPCC PLAN, ATTACHMENT #3
                    ONSIIOKK FACILITY  BULK STOIlAtiE TANKS
                                 DHAJNAGE SYSTEM
 Inspection Procedure:
Record of drainage, bypassing:, inspection, and oil removal from secondary containment:
                 Date of
   Date of      Bypassing^    Date of                         Supervisor's or
  Drainage    Open   Closed  Inspection   Oil Removal         Inspector's Signature
 Name of facility.

 Operator	
                                                             (AlUchmrnl ,#l. Xllf Pl»»)
                                    128

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APPENDIX C.   SAMPLE OF  EXISTING SPCC  PLANS  FOR THE LOUISIANA  REGION


                   (Prior to eomitUting Part I, rr/tr to rtgulntimi and itutnetinn pagi S.)

            SPILL PREVENTION CONTROL &  COUNTERMEASURE PLAN
                                         PART I
                                 GENERAL INFORMATION
     1. Name of facility  Facility Me. 1
     2. Typettfff"j«y   Onshore Production Facility
     8. Location of facility-
                       State of Louisiana
      4. Name and address of owner or operator:

             Name  	

             Address _	_	
                       Lafayette, Louisiana   70501
      6. Designated person accountable fov oil spill prevention at facility:

             Name and title	Production Foreman - Onshore

      6.  Facility experienced a importable oil spill event during the twelve months prior to Jan. 10, 1974
         (effective date of 40 CFR, Pnrt 112). (If YES, comple*? Attachment #1.)  No	

                                  MANAGEMENT APPROVAL
                      This SPCC Plan will be implemented as herein described.
              Signature.

              Name
              Title      pi vis Ion Manager
                                       CERTIFICATION
     I hereby certify that I have examined the facility, and being:  familiar with the provisions  of  40
     CFR, Part 112, attest that this SPCC Plan has been prepared in accordance with good engineering
     practices.
                                              Printed Name of Registered Professional Engineer

      (Seal)                                   	
                                              Signature of Registered, Professional Engineer

             June 28. 1974	      Registration No	Stale	
                                                                          (Part)) I>«K« | .r 3
                                            129

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                                            PAKT I
                                   GENKKAL INFORMATION
        7.  I'etentul Spills _ Prediction & Control:

Source
Flow Line to Heater
•nd Heater
Flow Line-Heater
to LTX I LTX Unit
Flow Line to Tank
Battery
Gas Sales Line

Low Pressure
Separator at
Tank Battery
Tanks





Major Type
of Failure
Leak or
Rupture
Leak or
Rupture
Leak

Leak or
Rupture
Leak


Leak/
Rupture or

Overflow


Total
Quantity
(bbls)
200 B/D

200 B/D

200 B/D

1 B/D

200 B/D


400 bbls.

200 B/D



Kate
(bbls/hr)
8.33

8.33

8.33

0.04

8.33




8.33



Direction
of Flow*
South

South

South

South

North or
South

North or
South

North or
South


Secondary
Containment
Ring Levee
(5,000 bbl.)
Ring Levee
(5.000 bbl.)
None
1
None

Ring Levee
(10,000 bbl.)

Firewall & Ring
Levee
(10,000 bbl.)
Firewall t Ring
• i»jj
Levee
(10,000 bbl.)
         Discussion:
The Meaux II Xmas tree and  separation equipment are encircled by a ring levee
Maintained at ground elevation + 2 feet.   All the water caught within this  levee
will be subject  to  Inspection  and any oil  found will be removed before the water
It drained into  the drainage ditch.
       •Attach map if appropriate.
       Name of facility.

       Operator	
                                                                        (Pin i) t'.ice i ,r i
                                         130

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                                           TAUT I
                                  GENKUAL INFORMATION
      7. Potential Spills — Prediction & Control:
         Source
                    Major Type
                    of Failure
 Total
Quantity
 (bbls)
  Rate
(bblj»/hr)
Direction      Secondary
of Flow*      Containment
NEAUX NO. 2 WELL  t TANK BATTERY
Flow Line to
Heater and
Heater
Flow Line-Heater
to LTX « LTX Unit
Flow Line- LTX to
Heater-Treater
and Heater-
Tree ter
Flow Llne-Heater-
Treater to Tank
Tenk
Gas Sales Line
Leak or
Rupture
Leak or
Rupture
Leak or
Rupture
Leak or
Rupture
Leak or
Rupture
or Overflow
Leak or
Rupture
18 B/0
18 B/D
18 B/0
18 B/D
210 bbls.
18 B/D
1 B/D
0.75
0.75
0.75
0.75
0.75
0.04
North or
South
North or
South
North or
South
North or
South
North or
South
North or
South
North or
South
Ring Levee
(10,000 bbl.)
Ring Levee
(10,000 bbl.)
Ring Levee
(10,000 bbl.)
Ring Levee
(10,000 bbl.)
Firewall C
Levee
(10,000 bbl.)
None
          Discussion:

 The Heaux No. 2 Xmas  tree,  separation equipment, and the  common tank battery  are
 encircled by a ring  levee maintained at ground elevation  + 2  feet.  The common
 tank battery is encircled by  a  firewall within the ring  levee.   All the water
 caught within the firewall  and/or the ring levee will be  subject to Inspection,
 and any oil  found will  be removed before the water Is drained into the drainage
 ditch.
        •Attach map if appropriate.
        Name of facility.

        Operator	
                                                                           (l'»r« |> !>«*• I of »
                                              131

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                                        PART I
                               GENERAL INFORMATION

                         to (tatenwiito iknld W.- YBS, NO. »r AM fW.< Applic*U,).}

  8.  Containment or diversionary structures or equipment to prevent oil from reaching
     navigable waters are practicable.  (If NO, complete Attachment £2.)               Yes

  9.  Inspeetionx and Record*
     A. The required in*pcctionx follow written procedures.                             Yei
     B. The written procedures and a record of inspections,  signed by the appropriate
        supervisor or inspector, are attached.                                         Yes
        Discussion:		
10.  Personnel, Training, and Spill Prevention Procedure*
    A. Personnel are properly instructed in the following:
       (1) operation and maintenance of equipment to prevent oil discharges, and       Y«»
       (2) applicable pollution control laws, rules,and regulations.                     Ye« __
       Describe procedures employed for instruction:—Field personnel  are confuted at
       Jeast weekly to discuss the operation, maintenance and  uo-keeo of  prodOT_-_
       Hon  eoulomgnf «« Mel I  as safety and environmental protecting.	
    B. Scheduled prevention  briefings for the operating personnel are conducted fre-
       quently enough to assure adequate understanding of the SPCC Plan.          Yes
       Describe briefing program:   The field  personnel played a major  role In bulldTnn
       the ring  levees. Installing the  drains and valves; therefore,  they hava a
       food understanding of the SPCC Plan.

       Monthly meetings are  held to review the SPCC Plan.                 —	
 Name of facility.

 Operator	
                                          132

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          (Pritr to t»mpltti*f I'mrt II, MlmMt B. rt/rr to rrpitelwiw nut uulmctiMu ptg* 1.)

                              PART II. ALTERNATE n
                      DESIGN AND OPERATING INFOUMATION
                       ONSHORE OIL  PRODUCTION FACILITY

                (Atipeiw* to •lattmtnt* iluuU be: YES. NO. «r ATA (N»t AppitraUtJ.l

A. Facility Drainage
   1  Drainage from diked storage areas is controlled as follows (include operating description
      of valves, pumps, ejectors, etc.):   Drains have  sealed valves.  Rain  water is  in-
       spected for rainbow before  draining.   Seal  is removed, water drained  and
       valve resealed.	
   2. The procedure for supervising the drainage of rain water from secondary containment into
      a storm drain or an open watercourse is as follows (include description of (a) inspection for
      pollutants, and  (b) method  of  valving security). (A record of inspection and drainage
      events is to be maintained on a  form similar to Attachment £3):  Pumper wi II  inspect
       rain water for  condensate or rainbow.  Any pollutants present  shall  be re-
      "jnoved before  draining.  After  satisfactory Inspection,  the valve  will be ~
       unsealed, water drained and valve  resealed.   Drainage will be  recorded on
      ITroper drainage system record.


   S. Field drainage ditches, road ditches, and oil  traps, sumps, or skimmers, if such
      exist, are inspected at regularly scheduled intervals for accumulations of oil.       Ves
      Describe inspection procedures, intervals, and methods employed to remove oil; On ski timers
      Jr^ated within  secondary containment, pumper will  visually  Inspect daily.
       Any  condensate  accumulation shall  be  returned to  tank or removed by approved
       oil  absorbent material.	.
 B. Bulk Storage Tanks
    1.  Describe tank design, materials of construction, and fail-safe engineering features:.	
       ^toraoe tanks located within one common 1000 barrel  firewall.   The  1000
        barrel  firewall and  tanks  are located within a 10.000 bbl.  secondary  con-
        tainment.	
       ~~~	Heaux in	2-210 bbl.  welded API tanks	
       ~~                             1-400 bbl.  welded API tank

       ~~             Meaux 12        2-2K) bbl.  welded API tanks

       "~~      Salt Water  Disposal   1-frOO bbl.  welded API tank

       ~         All tanks have 2-ounce pressure/vacuum thief hatch, vent  llnesT"
                 and equalizing lines.
    Name of facility.

    Operator	
                                                              (l>«rt II, AUrriuU II) l'«»r 1 »f 1
                                          133

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                               PART II. ALTERNATE B
                       DESIGN AND OPERATING INFORMATION
                        ONSHORE OIL  PRODUCTION FACILITY

                      ir (. ,Mrmrml, *h«*M br: YES, NO. w HA (till

   2. Describe secondary containment design, construction materials, and volume? Secop farv
      cf«,ralFinieqt consists of  earthen firewallsr  dikes  and ring  [eyfits  with «, _
      •Inlaum capacity equal to the largest  tank  plus a sufficient
      for  precipitation.	_.
   8. Describe tank examination methods and procedures:  Tanks,  foundations and  fire-
      tolls  shall be visually  inspected daily by pumper.   Monthly Inspection
      by supervisor at time of monthly safety and environmental protection
      •ectlng.	.	
C. FmeBity Transfer Operations
   1. Describe scheduled basis for examinations of above-ground valves and pipelines and salt water
      disposal facilities:	Valves, pipelines  and SWD facilities  are visually
      dally  by  pumper and monthly  by  supervisor.	
   2.  Describe flow-line maintenance program to prevent «piH«;  Flow  lines are visually
      Inspected daily by ounper and Monthly by supervisor.	
D. Ofl Drilling and Workovcr Farililirs
   1.  A Notcout prevrntrr (BOP) juwmlily and well control system is installed before
      drilling below any «-a*ing string ami. a» required during workover operations.
   i  The BOP assembly is capable of controlling any expected wellhead pressure.         Yea
   S.  Caring and BOP installations conform to state regulations.                    _

  Kame of facility	

  Operator	—.	
                                                            
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                          8FCC PLAN. ATTACHMENT #3
                   ONSIIUKK  FACILITY BULK STOItACR TANKS
                               UKAINAVE SYSTEM
Infection Procedure:   Pumper wilt inspect rainwater for condensate or rainbow.  Any
pollutants present shall be removed before draining.  After satisfactory  inspection
the valve will be unsealed, water drained, and valve reseated.
 Record of drainage, bypassing, inspection, and oil removal from secondary containment:  p.  MEAUX fl
                Date of
    Date of     Bypassing     Date of                         Supervisor's or
   Prtinagt    Open   Closed  Inspection   Oil Removal        Inspector's Signature
    Nan* of facility.

    Operator	
                                                                       *x snr
                                         135

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                           SI'CC PLAN. ATTACHMENT #.1
                   ONSHORE FACILITY BULK STORAGE TANKS
                                DRAINAGE SYSTEM

Imipcction Procedure: Pumper will Inspect rainwater for condensate or rainbow.  Any
pollutants  present shall  be removed before draining.  After  satisfactory Inspection
the valve will  be unsealed, water drained, and valve reseated.                       '
Record of drainage, bypassing, inspection, and oil removal from secondary containment:  P.  MEAUX 12
                Date of
   Date of      Bypassing     Date of                         Supervisor's or
  Drainage    Open  Closed  Inspection   Oil Removal         Inspector's Signature
 Nnnic of facility

 Operator	
                                                            (AlUrhmrni #1. sifC l'Un>
                                     136

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                          SPCC PLAN, ATTACHMENT £.1
                   ONSHORE FACILITY HULK  STORAGE  TANKS
                               DRA1NAUK SYSTEM

litftpcction Procedure:  Pumper will Inspect rainwater  for condensate or rainbow.  Any
pollutants present shall be removed before draining.  After satisfactory inspection.
the valve will be unsealed, water drained, and valve  resealed.
 Record of drainage, bypassing, inspection, and oil removal from secondary containment:  WEST  RIDGE TANK
                 Date of
    Date of      Bypassing      Date of                         Supervisor's or
   Drainage    Open   Closed  Inspection    Oil Removal         Inspector's Signature
    Name of fnrility.

    Operator	
                                                              Un)
                                            137

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        NO. i weu
WEST KtOCC TANK MTTtKY
WEST MOW S.WO WCU
                                                                   MIL PREVENTION CONTROL
                                                                               •
                                     138

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139

-------
                (friar to etmidttixg Part I, rr/tr t» rtgnlatimi and irutmttimu fagi S.)


         SPILL PREVENTION CONTROL & COUNTERMEASURE PLAN

                                       PARTI
                              GENERAL INFORMATION


  1. Name of facility	^clllty *2	_

  2. Typ*ntf•"ii»y    Intermediate Production  Facility       	
  & Location of facility.
  4. Name and address of owner or operator:

         Name  	

         Address	
 6. Designated person accountable for oil spill prevention at facility:

         Name and title	,	Production Superintendent

 6. Facility experienced a reportable oil spill event during the twelve months prior to Jan. 10, 1974
     (effective date of 40 CFR. Part 112).  (If YES, complet" Attachment £1.)

                              MANAGEMENT APPROVAL
                  This SPCC Plan will be implemented as herein described.
         Signature.

         Name    .

         Title
                                   CERTIFICATION
I hereby certify that I have examined the facility, and being  familiar with the provisions of 40
CFR. Part 112, attest that this SPCC Plan has been prepared in accordance with food engineering
practices.
                                         Printed Name of Registered Professional Engineer

(Seal)                                    	       _
                                         Signature of Registered Professional Engineer

          July 1. 1974	      Registration No	State	
                                                                     (Part 1) rage 1 of J
                                       140

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                                    PART I
                            GENERAL INFORMATION


7.  Potential Spills — Prediction & Control:

                              Total
             Major Type      Quantity         Rate        Direction      Secondary
  Source      of Failure        (hhls)        (bbls/hr)      of Flow*      Containment

 16"  Main      Major  Line       30        30 bbls/hr    South       Hot Practical
 Line         Break
 Onshore
   Discussion:   The above prediction  Is based on a complete break In the 16"
    Main Line feeding  this  facility.   All  offshore wells are equipped with
    safety shut-In devices  which  should readily react to the pressure drop
    and shut in all flow within  10 minutes.   Only fluid lost from the line
    should be that which gravitates out of the line.  Since the  16" line at
    the offshore structure  Is  some 45* above the beach line, It  Is calculated
    that a maximum of  11 barrels  of fluid 50 percent oil would gravitate
    out of line with an estimated 50  barrels of fluid (50 percent oil) to
    be blown out while line pressure  Is bleeding off.
  •Attach muj» i( appropriate.
  Nitnic of facility.

  Operator	
                                                                    (l¥.r« I) r«B» 2 gf 3
                                        141

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                                        PART I
                               GENERAL INFORMATION

                         to itattmnli ilavU he: YES, NO, tr NA (Not ApplicaUt).]

 8. Containment or diversionary structures or equipment to prevent oil from reaching
    navigable waters are practicable. (If NO. complete Attachment #2.)                Yes

 9. Inspections and Records
    A. The required inspections follow written procedures.                              Yes
    B. The written procedures and a record of inspections, signed by the appropriate
       supervisor or inspector, are Wtt8h«a. filed in office.                        Yes
       Discussion:	
10.  Personnel, Training, and Spill Prevention Procedures
    A. Personnel are properly instructed in the following;:
       (1) operation and maintenance of equipment to prevent oil discharges, and       Yes
       (2) applicable pollution control  laws, rules, and regulations.                    Yes
       Describe procedures pmploygri for instmftmn •   All  employees have been Instructed
       In  spill  prevention and are periodically refreshed  as to procedures and
       'furnished copies  of laws and  regulations.
    B. Scheduled  prevention briefings for  the  operating personnel are conducted fre-
       quently enough  to assure adequate  understanding of the SPCC Plan.          Yes
       Describe briefing program:  New employees are  briefed as  to  the  Importance of
       spill prevention  and  periodic  briefings will  be scheduled.	
  Name of facility.

  Operator	
                                                                        (Part !)r«crt«ra
                                         142

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                                        , f«/cr

                              PART II, ALTERNATE B
                      DESIGN AND OPERATING INFORMATION
                       ONSHORE OIL PRODUCTION FACILITY

                [JtmjimiJW U ttfttmmlf ikfuU k*. YES. NO, «r AM fN»t

A. Facility Drainage
   1.  Drainage from diked storage areas is controlled as follows (include operating description
      ofvalves,pumps,ejectors,etc.): Salt water  In tank firewall  can be drained Into
       water pit adjacent to diked area.   Oil and water within diked area and
       adjacent water pit are picked up  by a  portable pump powered by an Internal
       combustion engine and recycled  through gun-barrel  and tanks.	
   2. The procedure for supervising the drainage of rain water from secondary containment into
      a storm drain or an open watercourse is as follows (include description of (a) inspection for
      pollutants, and  (b)  method of valving security).  (A record of inspection and drainage
      events is to be maintained on a form similar to Attachment £3);  Not drained.	
    8.  Field drainage ditches, road ditches, and oil traps, sumps, or skimmers, if such
       exist are inspected at regularly scheduled intervals for accumulations of oil.
       Describe inspection procedures, intervals, and methods employed to remove oil:   The ditches
        are under daily surveillance.  Should any accumulation appear it will be
        picked up by a vacuum truck and returned to the, gun-barrel. _
 B. Bulk SloreRe Tanks
    1. Describe  tank design, materials of construction, and fail-safe engineering features:	
       _•» - 1.000  hhl.  bolted galvanized steel  tanks  -  Condensate	
        1 - l.SOO  bbl.  bo'ted galvanized oun-barrel	.—	
        I - 1.000  bbl.  bolted galvanized steel  tank - water settling.,	

        All storage  tanks have overflow lines to other  tanks and are protected  by
        pressure/vacuum thief hatches and by vapor-recovery valves.	
    Name of facility.

    Operator	
                                                               (Part II. AMmwlr H) !*»«» I •( 1
                                           143

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                              PART II.  ALTERNATE  »
                      DESIGN AM) OI'KKATING INFORMATION
                       ONSIIOKE OIL PRODUCTION FACILITY

                [Jtn/w»v to ,Mrwntt» tlimiH he: YEfi, NO. or NA (Nat

   2. Describe secondary containment desiprn, construction mnteriats, and volume:_Ihe_tank_
  battery Is protected  bv a firewall of  Impervious  material which  calculates
  to hold 3.930 bbls  of  fluid which  Is over twice  the volume of  fluid  held bv
  the largest tank.   This also covers a sufficient  allowance for precipitation.
   8.  Describe tank examination methods and procedures:   Ta>Ti^ «r» .....mi^n  fr.qm».,t|y
  by the production  foreman for any external  Indications of possible failure.
  Internal examinations  are made by foreman during  any tank cleaning occurrences.
  Expert personnel are consulted any time tank  conditions are questionable.
C. Facility Transfer Operations
   1.  Describe scheduled basis for examinations of above-ground valves and pipelines and salt water
      disposal facilities; Transfer valves and lines  in  the battery area are  visible
  •t all  times and are  Inspected dally.  The salt water disposal facility  Is
  checked dally and settling  tank effluent  is sampled monthly.	
   2.  Describe flow-line maintenance program *» prevent «pill«;   The 16" lines servicing
      this facility are protected against corrosion by cathodlc protection  de-
      vices and coatings.	
   Oil Drilling and Workover Facilities  N/A wells feeding  this  facility are located  offshore.
   1. A blowout preventer (BOP) assembly and well control system is installed before
     drilling l>olo\v any rasinjr Mrinjj and. a* required during workorer o|x>rntionx.    	
   2. The BOP assembly is capable of controlling any expected wellhead pressure.      	
   3. Caning and RO1*  installations conform to state regulations.                    	
  Name of facility.

  Operator	
                                                           (P«rt II. AHcTB.tr II) Pi*, 2 of 1
                                         144

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              (Prior to eomiilttinp Part I. rrfer tit rrfulnliunt and itutruetio** jtao* S.)

       SPILL PREVENTION CONTROL & COUNTERMEASURE PLAN

                                     PART  I
                             GENERAL INFORMATION


1.  Name of facility	Facility |3	,	

2.  Typt rf fa"imy    ONSHORE PRODUCTION FACILITY	
8. Location of facility.
4. Name and address of owner or operator:

        Name  	

        Address	
 5. Designated person accountable fov oil spill prevention at facility:

        Name and title	      Production Superintendent

 6.  Facility experienced a reportable oil spill event during the twelve months prior to Jan. 10,1974
    (effective date of 40 CFR. Part 112). (If YES, complete Attachment #1.) _ NO-

                              MANAGEMENT APPROVAL
                  This SPCC Plan will be implemented as herein described.
        Signature.

        Name

        Title
                                   CERTIFICATION
I hereby certify that I have examined the facility, and being familiar with the provisions of 40
CFR, Part 112, attest that this SPCC Plan has been prepared in accordance with good engineering
practices.
                                          Printed Name of Registered Professional Engineer

 (Seal)                                     	
                                          Signature of Registered Professional Engineer

          July 1,  197*1	      Registration No	State	
                                                                       
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                                     PART I
                            GENKKAL INFORMATION


7. Potential Spills — Prediction & Control:

                              Total
             Major Type     Quantity        Uate        Direction       Secondary
  Source      of Failure        (bUs)        (bbls/hr)      of Flow*      Containment

Top allow-    Flowllne         70           8.7        South       Not Practical
able flowing Break
Well
  Discussion:  The above prediction Is based on a complete  (100 percent)  flow-
  line break at  the  beginning of an 8-hour unattended period.  This  complete
  flowllne  break would  more than likely have to be caused by some outside
  source  (bulldozer, etc.)  and therefore,  would not occur during the un-
  attended  period.   Normally a flowllne leak would be a small pin hole which
  would release  only a  small  fraction of the oil Indicated above and would
  be located and repaired before the 8 hours had elapsed.  Any oil lost  In
  the above situation would be Isolated and picked up by a vacuum truck
  within a  few hours of discovery.
•Attach map if appropriate.
Name or facility.

Operator	
                                                                  d'arl I) Pig, 2 of 3
                                     146

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                                       PARTI
                              GENERAL INFORMATION


                [fte<|M»u« to tlattmcnti ilumU ft«: YES, NO.orNA (Net ApplitaUt).]

8. Containment or diversionary structures or  equipment to prevent oil from reaching
   navigable waters are practicable.  (If NO, complete Attachment £2.)
 9.  Inspections and Records
    A. The required insi>cctions follow written procedures.
    B. The written procedures and a record of inspections,  signed by the appropriate
       supervisor or inspector, are xttMtucfc  filed at  office.
       Discussion : __ _____
10.  Personnel, Training, and Spill  Prevention Procedures
    A. Personnel are properly instructed in the following:
       (1) operation and  maintenance of equipment to prevent oil discharges, and       Yes
       (2) applicable pollution control laws, rules, and regulations.                     Yes
       Describe procedures, employed for instruction:   All employees have been  I n s t r uc ted
       Tn  spTTf prevention and are perrodfcally refreshed as  to procedures, and
       furnished copies of laus  and rapnl»«•!»-.,	
    B. Scheduled prevention briefings for the operating personnel are conducted fre-
       quently enough to assure  adequate  understanding of the SPCC Plan.          Y««
       Describe briefinc program: —New  employees are briefed as to the  Importance  of
       spill  prevention  and periodic briefings will  be scheduled.
   Name of facility.

   Operator	
                                                                          (Part I) P«*e 1 tt 3
                                           147

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           (Prior la completing /'art //, Altrrnatf B, nftr to rvpulad'im* ami autnetmu page 7.)

                               PART II, ALTERNATE B
                       DESIGN AND OPERATING INFORMATION
                        ONSHORE OIL  PRODUCTION  FACILITY

                IKnpmua It itnttmtnt* nhttiU be: YE ft. NO, or NA (Not ApplienUt).]

A.  Facility Drainage
   I. Drainage from  diked storage areas is con-trolled as follows (include operating description
      of valves, pumps, ejectors, etc.):  Oil  and water within the diked storage area  is
       picked up by a  stationary oas  operated pump  or  portable pump  powered by ?r)
       Internal combustion  engine and recycled through gun-barrels and  stock
   2. The procedure for supervising the drainage of rain water from secondary containment into
      a storm drain or an open watercourse is as follows (include description of (a) inspection for
      pollutants, and  (b> method of valving security).  (A record of inspection and drainage
      •vents is  to be maintained on a form similar to Attachment ;±3):  No Drainage.	
   8.  Field drainage ditches, road ditches, and oil traps, sumps, or skimmers, if such
      •xlst. are inspected at regularly scheduled intervals for accumulations of oil.       Yes
      Describe inspection procedures, intervals, and methods employed to remove oil:   The d I te_ht>«
      are  under  daily surveillance.	If  an accumulation occurs, oil  is  oickeH ,,p hy
      vacuum  truck.	
B. Bulk Storage Tanks
   1.  Describe tank design, materials of construction, and fail-safe engineering features:
      BATTERY t\   k - 1.000 bbl  bolted galvanized tanks for  oil  storage    '
      	4 -   500 bbl  bolted galvanized tanks for  condensat	
      	2 - 1.500 bbl  bolted galvanized salt water settling tanks
                       1.000 bbl  bolted galvanized oil gun-barrel	
                   1  -    frOO bbl  bolted galvanized condensate  gun-barrel
                   1  -    300 bbl  bolted galvanized test gun-barrel
         	300 bbl welded test tank	
      All storage  tanks have overflow lines~to other tanks and  are protected  by
      Pressure/Vacuum thief hatches  and by Vapor Recovery valves.            "	
      BATTERY I 2  —  3 - 300 bbl welded tanks for oil storage are  protected by
                Pressure/Vacuum  thief hatches.
  Name of facility.

  Operator	
                                                             
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                             PAUT II, ALTERNATE B
                     DESIGN AND Oi'KKATING INFORMATION
                       ONSIIOKK OIL PRODUCTION FACILITY
                       tn ulnlrmtnlii tlinnlil hr: YKK. NO, or NA (Vat
  2. Describe secondary containment design, construction materials, and volume :_T*!l!L
     batteries are protected with firewalls of  impervious material  of sufficient
     volume to contain more than the volume'of  the largest tank with an ample
     allowance for precipitation.	 	  	

     BAIIfcKV »\ Firewall measures IBS'"X 285' X AT~caTca1ated"tb"h6rd'~37759'jTbls.

     BATTERY »'l Firewall ieasures 60' ITPtO'  X  V calculated  to hold 5,989  bbls.
   3 Describe tank examination methods and procedures:    Tanks  ar» oyjminoH avtor^ally
     frequently by production foreman.   Internal examination is made during tank
     cleaning process.—Expert personnel are consulted  if condition of  tank is
     questionable.	
C, Facility Transfer Operations
   1.  Describe scheduled basis for examinations of above-ground valves and pipelines and salt water
      disposal facilities:  Transfer ya)»P<:  and  pipelines ar?  vUlhl.. at all  Mnn.«	
      ana are Inspected daily.   Salt water  disposal facility is checked  frequently
   2. Describe flowline maintenance program to prevent spills; All  flowllnes  are protected
      qgalnst corrosion  by wrapping and  doping or plastic coating.	
 D. Oil Drilling and Workovor Facilities
    1. A blowout prevonter (ROP) assembly and well control system is installed before
      drillinjr below any casinji string and, as required during workowr operations.
    2. Tl»e BOl' assembly is capable of controllint; any expected \vellhc