&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.
-------
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.
-------
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/
-------
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).
-------
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
-------
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
-------
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
-------
Figure 2.
Typical terrain feature* of West Central Texas and Southeastern Oklahoma (Area 1
20
-------
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
-------
Figure3 (a & b). Typical terrain features of East Central Texas (Area 2).
22
-------
Rgure 4 (a & b). Typical terrain features of the Southeast Texas coastal plains (Area 3).
23
-------
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.
-------
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.
-------
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.
-------
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.
-------
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
-------
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]
-------
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
-------
•
Figure 24. Typical unprotected over-water piping at water-bated facilities.
-------
Ftffura 26 (• & b). Wat«r traffkHnduced bank orouon at • watar-baaad facility (a) and typical buHchaads utad to
corract tha arotion problem (b).
-------
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.
-------
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*.
-------
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
-------
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
-------
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
-------
f a 80-well rtrlpper facility In Pennsylvania.
76
-------
&&
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.
-------
Figure 36 (a & b). Views of • 76,000-gallon bulk plant - Penn-Grade area.
82
-------
&S&'
Figure 36 (c). Views (stroam where boom i» to be installed) of a 75,000 gallon bulk plant - Penn Grade area
-------
Figure 37 (• & b). A 41,000-gallon bulk plant on a steep hillside location P«nn Grade area
84
-------
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.
-------
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
-------
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.
-------
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.
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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
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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-
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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.
-------
Figure 47 la & b). Large bulk plant In Connactlcut.
102
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Figure 47 (c). Large bulk plant In Connecticut.
-------
•qpt i fjf-
^si *M
Figurt 48. SPCC plan layout for a large independent bulk plant in Connectkut
-------
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
-------
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'
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Flgura 63 (. ft b). Sm.ll bulk fu.1 dl.tributor in Ma^chu.«u. m.ln pl.nt.
Ill
-------
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.
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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.
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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.
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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.
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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. '
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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.
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of Business, U. S. Department of Commerce, December 1970.
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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
-------
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
-------
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
-------
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
-------
(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
-------
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
-------
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
-------
(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
-------
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 —.
-------
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
-------
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
-------
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
-------
NO. i weu
WEST KtOCC TANK MTTtKY
WEST MOW S.WO WCU
MIL PREVENTION CONTROL
•
138
-------
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
-------
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
-------
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
-------
, 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
-------
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
-------
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
-------
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
-------
APPENDIX D. SAMPLE OF EXISTING SPCC PLANS FOR THE PENN-GRADE REGION
SPILL PREVENTION CONTROL & COUNTERMEASURE PLAN .
FOR PRODUCTION FACILITIES
Section 311 (j) (1) (C) of the Federal Wafer Pollution Control Act Amendments of 1972, authorized
the President to issue regulations establishing procedures, methods, equipment and other require-
ments to prevent discharges of oil and hazardous substances from vessels and from onshore facilities
and offshore facilities, and to contain such discharges. The President delegated the responsibility
for such regulations to the Administrator of the Environmental Protection Agency. Accordingly,
the Administrator developed and promulgated Oil Pollution Prevention regulations in 40 CFRPart
112. These regulations require owners and operator of onshore and offshore no-transportotion re-
lated facilities to develop and implement Spill Prevention Control and Countermeasure (SPCC)
Plans to prevent the discharge of oil into the navigable waters of the United States or adjoining
shoreline.
GENERAL INFORMATION
1. Name and location of facility:
Name Well Number(s) 3
Location:
Direction and distance to nearest town
Permit No.(s) Lot or Section
County Mason State West Virginia
(One topographical map of each operating area suggested)
2. Name, address and phone number of owner or operator:
Nome
Address:
Street State Ohio
City Zip 45714 County
Telephone No. _
3. Nome or title and telephone number of person in charge of facility:
Name or title Telephone
4. Name and telephone number of person responsible for oil spill prevention at foci lily;
Name Telephone
CERTIFICATION
I hereby certify and attest that I am familiar with the facility and the information contained in this
plan and that to the best of my knowledge and belief such information is true, complete and accur-
ate, and this plan has been prepared in accordance with good engineering practices.
Printed namelif RegistoredTngineerSignature of Registered tfngineer
Date: Registration No.:
150
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SPILL RECORD
- Xs*
I. This facility, over the post 12 months, has had a reportable spill.
2. Descriptions of any reportable spills are given below, including corrective action taken
and plans for preventing recurrence.
PREDICTION OF POTENTIAL SPILLS
1. Name of lease(s):
2. Nearest watercourse:
A. Name: Ohio River
B. Distance ond direction from facility:
3. Possible spi
Source
Wellhead Controls
Flowlirtes
Storage Tanks
II sources:
Type of
Rupture
Rupture
Rupture
(such as overflow, rupture or leakage)
Maximum .Maximum Flow Direction
Failure Volume (bbls.) Rate (bbls./hr.) of Flow
or leakage 10 bbls day
or leakage 10 bbts day
, leakage or
10 bbls day
10 bbls day
N/A
overflow
•Important - Advance planning for wells located in flood plains and/or watershed areas should
receive special consideration.
SPILL PREVENTION PLAN CHECKLIST
1. Secondary containment and/or diversionary structures will be used for possible spill sources:
Source Type of Containment or Diversionary Structure
Wellhead Controls Nono
plow Knes None
Storage Tanks Retention pond
Select from:
Onshore: Dikes, berms, retaining walls; curbing; culverting, gutters, drains; weirs, booms,
other barriers, spill diversion and retention ponds.
151
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2. If containment or diversionary structures will be. impracticable, state reasons for impracticability
Small production on a doily basis mokes containment structures for wellhead and flowlines
uneconomical.
and attach a strong oil spill contingency plan and written commitment of manpower, equipment
and materials required to expeditiously control and remove any harmful quantity of oil discharged
Check if attached:
Contingency Plan X _ Written Commitment y
Discussion: Contingency plan is contained in the action plan on page 6 . __ _
3. Onshore Oil Production Facilities
A. Drainage:
(1) Drains of secondary containment shall be cloud and sealed except when rainwater
is drained.
Discussion: No drains in retention pond. In event of spill, oil will be pumped into storage
tanks or tank truck from retention pond. In event retention pond fills up with rainwater, etc.,
same will be picked up by vocumn truck or pumped into tank truck and disposed of.
(2) Drainage from secondary containment shall be conducted under surveillance of
authorized person. (Name or title of authorized person ?Well tender )
Discussion: ^ , will be notified whenever
retention pond needs to be drained and will drain some with its
own equipment or by use of a subcontractor, but under supervision.
(3) Field drainage ditches, road ditches and oil traps or skimmers shall be inspected on
a scheduled, periodic basis for oil accumulations.
How often Every other day or whenever well is pumped
Discussion:
(4) Any oil removed from secondary confainnr.ont, ditches, traps or skimmers s'hall be
disposed of in on approved manner.
Discussion: Oil will be pumped bock into the lease storage tanks
152
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B. Bulk Storage Tanks:
(1) Tank material and construction comply with conditions of storage and material to
be stored.
Discussion: All tanks ore of standard construction for oil storage use.
(2) Secondary containment volume (200bbls ) is greater than the largest single tank
capacity.
Discussion: Retention pond Is at least twice as big os largest single tank and ot least
as large os the total capacity of all the storage tanks on the lease.
(3) Undiked areas drain to a catchment basin or holding pond with a volume of 200 bbls
Discussion: Same retention pond is used where possible. This is the only retention pond or
catchment basin on lease.
(4) All tanks shall be visually inspected on a periodic basis. (Maintaining a written record
of inspection is suggested.)
Discussion: Monthly inspection to be completed on or before lost day of month & so indicated
on written report moiled lo Oil & Gas Corp., P.O.Box , , Ohio, , on
or before the tenth (10th) day of the month following the inspections.
(5) Tanks are engineered with one or more of the following fail-safe devices:
a. Adequate tank capacity to prevent overfill
b. Overflow equalizing lines
c. Adequate vacuum protection
d. High level sensors
Discussion: All storage tanks are of 100 bbl capacity and whenever o second tank is joined
as a tank battery, on cquojuirig overflow line will bo installed.
C. Infra-facility Transfer Operations:
(1) Abovegrourtd valves and pipelines shall be inspected on a scheduled, periodic
basis of every other day or whenever well is pumped.
Discussion:
153
-------
(2) Solt woter disposal facilities shall be inspected on o periodic basis of monthly
Discussion: To be inspected on or prior to the last day of each month
(3) Records of flowline repairs shall be maintained and used in a maintenance and re-
placement program.
Discussion: Oil & Gas Corp. will moke all necessary repairs after being notified by
well tender
4. Inspections and Records
A. The required inspections follow written procedures.
Discussion: Inspections ore to be visual and any leaks, seveidy rusted pipe, fittings or
or any potential spill sources are to he reported to Oil A Gas Corp. within U ^r^
B. The written procedures and a record of inspections shall be signed by the appropriate
supervisor.
Discussion: Written inspections ore to be moiled to Oil & Gas Corp, osouHingft
under Item D-4, page 4, and other written inspections ore to be moiled to Romeo with weekly
meter or pumper reports. Inspections locating spills ore to be reported immediately, qnd inspections
locating potential spills are to be reported within 8 hours, both being reported to
5." Personnel, Training and Spill Prevention Prodecures
A. Personnel shall be properly instructed in the following:
(1) Operation and maintenance of equipment to prevent oil discharges, and
(2) Applicable pollution control laws, rules and regulations.
B. Spill prevention briefings for the operating personnel shall be conducted on o scheduled,
periodic basis of annually
Discussion: Tliero will IK; on HP-SPCC mooting for all personnel every December in the
oftict- of Oil & Gas Corp.
154
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6. ACTION PLAN (suggested plan outline to be used if your spill should reach woter)
A. Action Center (the location or center that direction For the cleanup and containment
operaVion will issue from)
Name Oil & Gas Corp. Street
City State Ohio
Telephone
B. Communication
(1) Federal EPA AC 215 597-9898
(2) W.Va. Water Resources Division AC304 348-2107
(3) U. S. Coast Guard - CapK of the Porf, Hunrmgron,W.Vo. AC304 675-3160
Capt. of the Port, Pittsburgh, Pa. AC412 741-4174
(4) Local Fire Dept. AC304 675-1410
C. Immediate Work Force
(1) List names and telephone numbers of your own people that would be immediately
available to you on a 24 hour basis.
(2) List your own equipment, such as dozers, trucks, etc., that would be immediately
available to you on a 24 hour basis.
None
(3) List men and equipment that a sub-contractor could make immediately available
to you on a 24 hour basis, also list the telephone numbers of the people to call.
Oil & Gas Corp.
2 bulldozers - 3 trucks - 3 pumps and suction lines - assorted picks, shovels, hoes
D. Standby Work Force:
List additional or standby men and equipment, along with telephone number:, fn the event
that additional service is needed.
Well Services - small tools, absorbent' materials, lab
Pump trucks, absorbent materials, lab
cmulsifiers, detergents, foams
. Clean Up Materials:
List the availability of materials that may be needed in a clean-up operation such as
straw, sawdust, sand, etc.
Straw, sawdust and other absorbent materials ore kept at Oil 8. Gas Corp. shop
in , Ohio,
155
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-3
-3
u
o
3
156
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Appendix 2 - Representative SPCC Plan (Pennsylvania)
SPILL PREVENTION CONTROL & COUKTERMEASURE PLAN
FOR PRODUCTION FACILITIES
Section 311 (J) (1) (C) of the Federal Water Pollution Control Act Amendments of 1972,
authorized the President to issue regulations establishing procedures, methods, equip-
ment and other requirements to prevent discharges of oil and hazardous substances
from vessels and from onshore facilities and offshore facilities, and to contain such
discharges. The President delegated the responsibility for such regulations to the
Administrator of the Environmental Protection Agency. Accordingly, the Administrator
developed and promulgated Oil Pollution Prevention regulations in 40 CFR Part 112,
These regulations require owners and operator of onshore and offshore no-transportation-
related facilities to develop and implement Spill Prevention Control and Countermeasure
(SPCC) Plans to prevent the discharge of oil into the navigable waters of the United
States or adjoining shoreline.
GENERAL INFORMATION
1. Name and location of facility:
Nane
Well Number (s) if 2
Location:
Direction and distance to nearest town 2 Miles South of
Permit No.(s)_) _ F.,ot or Cection __ Twp. ____
County State Dhfo
(One topographical map of each operating area suggested)
2. Name, address and phone number of owner or operator:
Name
:se:
Ohio
Address:
Street
City
State
Zip. "
Telephone No.
County_
3. Name or title and telephone number of person in charge of facility:
Name or title _ Telephone: _
4, Name and telephone number of person responsible for oil spill prevention at
facility:
Name
Telephone :.
CERTIFICATION
\ hereby certify and attest that I om fam^ttatTVi.th the facility end the information
contained in this, plan and that to th^i^s'fc ftf-my) Knowledge and belief such infor-
mation is true, complete and accuratnycin3--this plants bean prepared in accordance
with Bo°d engineering practices. " '•' c ^
printed name of Registered Engineer
f Registered Engineer
157
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SPILL RECORD
Yet Mo
1. This facility, over the past 12 months, has had a reportable spill. """"" ~T
. _ji
2. Descriptions of any reportable spills are given below,
Including corrective action taken and plans for preventing
recurrence.
PREDICTION OF POTENTIAL SPILLS
1. Name ot leasa (a) i #2 Well
2. Nearest watercourse:
A. Name:
B. Distance and direction from facility; 1500 Teat.
"*. Probable spill sources: (such as overflow, rupture or leakage)
Maximum Maximum Flow Direction
Source Type of Failure Volume (bbls.) Rate (bbls./hr.) of Flow
Wellhead
Controls Rupture or Leakage 5/day Same U > su
Flowline " " » »
Storage Tank Rupture or Leakage 200/day N/A H
or Overflow
* Important - Advance planning for wells located in flood plain* and/or watershed
areas should receive special consideration.
SPILL PREVENTION PLAN CHECKLIST
1. Secondary containment and/or diversionary structures will be used for possible
spill sources:
Source Type of Containment or Diversionary Structure
Wellhead Controls None
flow Line None
Storage Tank Retention Pond
Select from:
Onshore: Dikes, berms, retaining walla; curbing; culverting, gutters, drain*;
weirs, boons, other barriers, spill diversion and retention ponds.
158
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it containment or diversionary structures will be impracticable, state reasons
for impracticability Small production on a daily basis from the well
makes containment structures for wellhead and Flom line uneconomical.
and attach a strong oil spill contingency plan and written commitment of manpower,
equipment and materials required to expeditiously control and remove any harmful
quantity of oil discharged. Check if attached:
Contingency Plan.- X Written Commitment
Discussion; Contingency plan is contained in the action plan on Page 5j
3. Onshore Oil Production Facilities
~~~ ~~ Yes No
A. Drainage:
(1) Drains of secondary containment shall be closed and sealed
except when rainwater is drained. _X__ _____
(2) Drainage from secondary containment shall be conducted
under surveillance of authorized person. X ____
(Name or title of authorized person Pumper )
(3) Field drainage ditches, road ditches and oil traps or
skimmers shall be inspected on a scheduled, periodic ba&ia
for oil accumulation*. X
How often dally
(4) Any oil removed from secondary containment, ditches,
traps or skimmers shall be disposed of in an approved
manner. X
Discussion:,
8. Bulk Storage Tanks:
(1) Tank material and construction comply with conditions
of storage and material ko bo scored.
(2) Secondary containment volume ( ) is greater than
the largest single tank capacity.
(3) Undlked areas drain to a catchment basin or holding
pond.
(4) All tanks shall be visually inspected on a periodic
basis (Maintaining a written record of inspection
is suggested)
(5) Tanks are engineered with one or more of the following
fail-safe devices:
a. Adequate tank capacity to prevent overfill
b. Overflow equalizing lines
c. Adequate vacuum protection
d. High lovol sensors whore facilities ara part
,-.< (••••—»nf.>r •Mv.in.-rion ronrriU. cvr.tom
159
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Di«"-ussion:
C. Intra-facility Transfer Operations:
Yea Ho
(1) Aboveground yalves and pipelines shall be inspected on *~~
a scheduled,'periodic basis of DAILY
(2) Sale water disposal facilities shall be inspected
periodically. X
(3) Records of flowline-repairs shall be maintained and "~~
used in a maintenance and replacement program. X
Discussion:
4, Inspections and Records
A. The required inspections follow written procedures X
B. The written procedures and a record of inspections shall be
signed by the appropriate supervisor. X
Discussion:
5. Personnel. Training, .and Spill Prevention Procedures
A. Personnel shall be properly instructed in the following:
(1) Operation and maintenance of equipment to prevent oil,
discharges, and _X_
(2) Applicable pollution control lavs, rules, and regulations. J<_
B. Spill prevention briefings for .the operating personnel shall
be conducted on'a scheduled, periodic basis X
Discussion:
160
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6. ACTION PLAN (suggested plan outline to be used if your spill should
reach water)
A. Action Center (the location or center that direction for the cleanup and
containment operation will issue from)
Same Oil Company Street
City State Ohio
Telephone ^^^ .
B. Communication
(1) Federal EPA AC 216 333-7556
(2) State EPA AC 614 299-6336 (Emergency No.)
(3) USCG AC 216 522-3983
(4) Local Fire Dept.
C. Immediate Work Force
(1) List names and telephone numbers of your own people that would b«
immediately available to you on a 24 hour basis.
(2) List your own equipment, eucn as dozers, trucks, etc., that vould
be immediately available to you on a 24 hour basis.
Pick-up Truck
Assorted shovels, picks, hoes - Field Office
(3) List men and equipment that a sub-contractor could make immediately
available to you on a 24 hour basis, also list the telephone numbers
of the people to call.
Hauling (Back hoes, Trucks)
Tractor Service (Tractors, Trucks, Back Hoes)
j>.. Standby Work Force
List additional or standby men and equipment,. along with telephone
numbers, in the event that additional service is needed.
See #1 and #3
Z. Clean Up Materials
List the availability of materials that may be needed in a clean-up
operation ouch AS straw, sawdust, sand, cmulsifiers, detergents,
fooraa, etc,
Straw, sawdust, sand kept at field Office in Ohio
161
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APPENDIX E. GENERIC SPCC PLANS FOR THE TEXAS/OKLAHOMA REGION
Plan 5-1
SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN
1. Facility Information
Name of Facility
Type of Facility Oil Well (Two)
Location of Facility_
Company Information
Name of Company_
Address
Phone Number_
Owner
Person Responsible for SPCC Plan_
3. List of Agencies to Notify in Case of Spill
U.S.C.G. National Response Center (800) 424-8802 (24hr.)
Federal EPA Office: Phone # Location
State Pollution
Control Office: Phone # Location
4. Spill History
This facility has experienced no spills since January
10, 1973.
5. Description of Facility & Drainage
This lease handles flow from two wells producing a total of
75 bpd of oil and about 25 bpd of salt water. A sketch attached
hereto shows the layout of this facility. Land is nearly flat,
and the territory is arid with less than 20 inches of rain per
year. There are no brooks or streams within several miles.
Oil flows to a gunbarrel tank outside existing firewall and
from gunbarrel to salt water (75bbl) or oil tanks (500 bbl).
Both salt water and oil are picked up by truck.
6. Containment
a. Existing
Existing containment consists of only the fire wall
around the salt water and oil tanks.
162
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b. Proposed
Consistent with the Oil Spill Prevention regulation
40 CFR 112.7 (e) 2 ii, proposed containment will be
an 8" high earthen dike with capacity > 500 bbl around
wells, gunbarrel, fire wall and access road as shown.
A minimum amount of grading will conduct all spills and
leaks from wells, piping and gunbarrel to sump in lower
corner. A ramp will be built over the access road to
prevent a low spot in the secondary dike.
7. Transfer Operations
Oil and salt water are picke up from inside the secondary dike
so there is no danger of pollution leaving the lease area.
8. Inspection and Training
A daily visual inspection is made of all facilities by the
pumper for signs of leaks, spills, corrosion, etc. Any repairs
or replacements found necessary will be made promptly and the
area cleaned up. Spilled oil will be removed, stored in drums
for disposal by a waste oil dealer or re-entered into the product
line. The pumper is experienced in oil field operations and is
familiar with SPCC Plan. Formal training or briefing sessions
on spill prevention are held twice a year.
9. Certification
I hereby certify that this plan has been prepared with good
engineering judgment and fulfills the requirements of 40 CFR
Part 112.
Name (Print)
Registration Number
State
Signature_
Date
163
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SECONDARY CONTAINMENT DIKE 8" HIGH
IF GROUND SLOPES TO THE SOUTH
THE SECONDARY DIKE IS NOT REQUIRED
ALONG THE NORTH SIDE.
TEXAS NEARLY FLAT TERRAIN.
EVAPORATION NEARLY EQUAL TO
RAINFALL.
-------
ESTIMATED COST OF IMPROVEMENTS
Dike, 400 L.F. @ 1.05 $ 420.00
Grading 4000 S.Y. @ .50 S.Y. (Machine) 2000.00
$2420.00
Fence, 1f required, 400 L.F. @ 4.00 $1600.00 (optional)
165
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APPENDIX F. GENERIC SPCC PLANS FOR THE LOUISIANA REGION
Plan 6-1
SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN
1. Facility Information
Name or Number
Type Oil Production/Storage
Location
2. Company Information
Name of Company_
Addresa
Phone Number
Owner
Person Responsible for SPCC Plan_
3. List of Agencies to Notify in Case of Spill
U.S.C.G. National Response Center (800) 424-8802 (24hrs.)
Federal EPA Office: Phone # Location
State Pollution
Control Office: Phone # Location
4. Spill History
This facility has experienced no spills since January 10
1973.
5. Description of Facility and Drainage
This lease handles the flow from two wells classified as oil
wells. Total production from this facility is 100 bpd of
oil and 35 bpd of salt water and a small amount of gas
sufficient to operate the heater treater. A sketch attached
hereto shows the layout of this facility. Equipment consists
of heater treater, low pressure separator, one 500 bbl salt
water storage vessel and four 500 bbl oil storage vessels and
salt water pump for disposal to injection well. The terrain
is completely flat and drainage from lease is to the north
west corner where it flows into a roadside ditch for about
1/2 miles to a drainage canal.
166
-------
The well is operated by the company's own employee and is visited
several times each day. The well stream flows to a heater treater
for separation after which the oil flows to its storage vessel and
the salt water to another vessel. The gas is piped to a low pressure
separator and subsequently used for operating the heater treater. The
salt water collected in the storage tank is pumped to a disposal well
and the oil is collected by truck and delivered to the customer.
Containment and Drainage
A small firewall around the tanks will contain minor leaks and spills,
however, it does not have enough volume to contain a single tank.
A secondary containment dike is constructed around the entire lease as
shown in the enclosed schematic drawing. Its height is 18 inches and
will contain a spill of 1300 bbls. The diked area is sufficiently
impervious to contain spilled oil. A pipe and valve leading to the
drainage ditch is used for disposing of the contents of the secondary
containment dike after the fluid has been tested for clarity, oil and
salt water content. This valve is locked. A ramp for entrance of
vehicles is provided at roadway to maintain integrity of secondary dike.
Area will be graded to drain to sump and discharge valve.
Transfer Operations
—
Oil is picked up from storage tanks by truck at point shown on sketch.
This is outside firewall dike but inside secondary dike.
Tnspection and Training
—
A daily visual Inspection is made of all facilities by the pumper for
signs of leaks, corrosion, etc. All repairs and/or replacements are
promptly made and the area cleaned up. Material from spills or leaks
is stored in drums for disposal by a waste oil dealer or re-entered
into the product line. The pumper is experienced in oil field opera-
tions and is familiar with the SPCC plans; however, formal training
and briefings concerning spill preventive practices are held twice a
year.
167
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9. Certification
I hereby certify that this plan has been prepared with qood
enalneerlnq judgment and fulfills the requirements of 40 CFR
Part 112
Name (Print)
Reqlstration No._
State
S1gnature_
Date
168
-------
SECONDARY CONTAINMENT DIKE
\
o
o
dh
Q
HEATER -
TREATER
o
:IREWALL
(TRUCK
LOADING
500 BBL
OIL STORAGE
TANKS (4)
- SALTWATER TANK
LOW
PRESSURE
SEPARATOR
f
SECONDARY I
DIKE DRAINAGE
SUMP
FIREWALL DRAIN
SALT WATER
T
WELL
u
RAMP
OVER
DIKE
LEASE LINE
FACILITY IS
SURROUNDED BY
RICE FIELDS
ACCESS ROAD
169
-------
COST ESTIMATE FOR IMPROVEMENTS
900 L.F. Secondary Dike (Mach.) -40 L.F $ 360,00
4" Valve and 12' of 4" Pipe at Sump 334.00
Access Ramps to Sump 150.00
Grading Area to Sump 1000.00
$1844.00
170
-------
Plan 6-2
SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN
i f Facility Information
Name of Facility_
Type of Facility
Location of Facility_
Company Information
Name of Company_
Address
Phone Number
Owner
Person Responsible for SPCC Plan_
List of Agencies to Notify in Case of Spill
U.S.C.G. National Response Center (800) 424-8802 (24hr)
Federal EPA Office: Phone # Location
State Pollution
Control Office: Phone # Location
A. Spill History
This facility has experienced no spills since January
10, 1973.
e Description of Facility
This well is classified as a gas well, producing 600 MCF/day
of gas and approximately 200 bpd of oil and 5 bpd of salt
water. The equipment consists of the following: Gunbarrel
tank, separator, glycol unit, one 500 bbl API salt water
tank and two 500 bbl API oil storage tanks. The entire
facility has been placed on timber piles and located in the
bayou about 80 feet from the shore line (marsh) as shown in
the sketch attached hereto. The well stream flows' through
a low pressure separator followed by a glycol unit and into
the gas pipe line. The liquid component of the well stream
leaves the separator and flows into a gunbarrel tank.
171
-------
which separates the oil from the water. The oil and water
then flow to their respective storage tanks.
The oil storage tanks are interconnected at the top by piping
and valves to prevent spill over. The oil flows by gravity
from these tanks through a pipeline through normally locked
valves to an oil loading pier and into a barge. The salt
water is also pumped to a barge for storage and eventual
disposal since this facility is located in a fresh water
area.
Since this facility is located entirely on the water, any
spill is immediately in a navigable waterway. Secondary
containment of a spill by the use of dikes is impossible.
6. Containment and Drainage
a. Existing
A sump box which is drained by gravity to a disposal pit
is located at the end of the oil loading pier. The oil
discharge hose is covered by a blind flange and is kept
in the sump box when not in use. The two concrete pads
containing the storage vessels and related equipment
have six-inch-high curbing. This curbing contains small
leaks (total capacity < 500 bbl), which are drained
directly to a disposal pit. However, there is no pro-
tection from a tank (500 bbl) rupture or leaks in the
pipes located below the walkway, or in the lines leading
to facility from the well or loading piers.
Secondary containment of capacity > 500 bbl will be
constructed around the gunbarrel tank and storage tanks.
The diked area will be sufficiently impervious to contain
oil spills.
b. Proposed
(1) We will provide a 500-gallon sump tank under each
platform to catch BS&W, small leaks and rain water, and
install drip pans under all above-water piping, drip pans
to drain to one of the sump tanks.
172
-------
(2) We will discontinue use of the disposal pit
except 1n emergencies.
(3) We will install gas-operated pumps at sumps and
redrculate all liquids through the gunbarrel — thus
creating a completely closed system.
(4) We will install a floating boom around the entire
pier assembly, including well and loadina pier, to contain
leaks from pipes located directly over the water or over-
flow from sumps. Any pollution in this area will be
skinned as soon as it occurs.
(5) In the event of a major spill or tank rupture, the
boom will be disconnected from around the pier and deploy-
ed downstream of the facility to contain the spill. A
cleanup contractor will be called immediately to remove
the spilled oil.
7. Inspection and Training
A contract pumper, who is familiar with this plan and trained
1n the use of the facility equipment, is responsible for the
operation of the facility. Daily visu?1 inspection of the
entire facility is part of his routine duties. Any leaks or
malfunctions in the equipment are repaired or replaced promptly.
Training on spill prevention and cleanup is given twice a year.
8. Certification
I hereby certify that this plan has been prepared with good
engineering judgment and fulfills the requirements of 40 CFR
Part 112.
Name (Print)
Registration No.
State
S1gnature_
Date
173
-------
MARSH
WATER LINE
ABANDONED
SEPARATOR
GLYCOL UNIT
GUN
BARREL
TANK
FLOATI
BOOM
OIL
LOADING
PIER
BAYOU
-------
COST ESTIMATES FOR IMPROVEMENTS
Floating Boom 500 L.F.
-------
Plan 6-3
SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN
1. Facility Information
Name of Facility
Type of Facility
Location of Facility_
2. Company Information
Name of Company_
Address
Phone Number
Owner
Person Responsible for SPCC Plan_
3. List of Agencies to Notify in Case of Spill
U.S.C.G. National Response Center (800) 424-8802 (24hr.)
Federal EPA Office: Phone # Location
State Pollution
Control Office: Phone // Location
4. Spill History
This facility has experienced no spills since January
10, 1973.
5. Description of Facility
This well is classified as an oil well producing 70 bbls/day
of oil, a small amount of gas (100 MCF/day) and no salt
water. The equipment used at this facility includes the
following: Line heater, separator, glycol unit, low pressure
water knockout unit and two 500 bbl API oil storage tanks.
This equipment is shown schematically in the attached sketch.
This facility is operated by a contract pumper who visits the
site once or twice a day. The well is located in a bayou
about 100 feet from shore and a well stream of about 3 bbls/
hour flows through the line heater to the onshore separator.
Gas flows through the glycol unit to the product line whereas
176
-------
the oil flows to the low pressure water knock-out to the oil
storage tank. The oil storage tanks are connected at the top
by pipe and valve to prevent spill over. The oil flows by
gravity from the tanks to the oil loading pier where it is
loaded into a barge for customer delivery.
This facility is located in the marsh land adjacent to a
bayou. Any spill from this facility immediately becomes a
spill event. The natural drainage from this facility is
directly into a navigable stream and secondary containment
is nearly Impossible because of the lack of available material
to construct the dike and a firm foundation on which to install
the dike.
Containment and Drainage
a. Existing
A sump box is located at the oil loading pier and is
drained via pipe to the interior of the tank dike. The
oil discharge hose is covered with a blind flange and
kept in the sump box when not in use. A six inch high
concrete curb extends around the oil storage tanks to
contain small leaks ( <100 bbls). In addition, an earthen
dike has been constructed around the oil tanks and is
sufficiently impervious to contain the contents of one of
these tanks in the event of a large spill («s 500 bbls).
However, in the case of a tank rupture, this dike will
probably be breached. The contents of this dike are
piped through a normally closed valve to a disposal pit,
which will be discontinued.
b. Proposed
The area around all facilities and pipelines located out-
side of the existing earthen dike will be graded to a
sump tank which is placed at a low point of the facility.
The drainage from within the earthen dike will also be
directed to a new sump tank. A pump will be located
177
-------
In the sump tank to recirculate all spills back through
the low pressure water knock out thus forming a closed
system. The sump tank should be sized to contain 3 bbls/
hour for 18 hours from a ruptured oil line plus 2 inches
of rain water, approximately 100 bbls.
A floating boom will be Installed around the oil loading
and well head piers as shown. Any pollution showing
within the boom area will be skimmed promptly.
7. Inspection and Training
A daily visual inspection of all piping and equipment is made
by the pumper who 1s experienced in oil field operation and
1s familiar with the SPCC Plan. All repairs and/or replacements
necessary will be made promptly. Formal training and briefings
on spill prevention and cleanup are given twice a year.
8. Certification
I hereby certify that this plan has been prepared with good
engineering judgment and fulfills the requirements of 40 CFR
Part 112.
Name (Print)
Registration Number_
State
S1gnature_
Date
178
-------
SWAMP
ABANDON
L.P.
WATER
KNOCKOUT —I
GRADE THIS AREA TOWARD SUMP TANK
6LYCOL UNIT
(-SEPARATOR
SUMP
BOX
BAYOU
-------
ESTIMATED COST OF IMPROVEMENTS
Assemble and Transport Material $ 1200.00
Sump tank, 50 bbl 2160.00
Install tank 250.00
Pump & Piping from Pump to Low Pressure Water
Knock out 890.00
Grading by hand 2000 S.Y. @ 1.00 2000.00
Drip Pans Loading Rank 200 L.F. & 3.50 700.00
1100 L.F. of Floating Boom 9 12.00 13200.00
Standby & Lost Time 30% Labor 1200.00
$21600.00
180
-------
Plan 6-4
SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN
1. Facility Information
Name of Facility R12N T6E 76289
Type of Facility Oil Production (Intermediate)
Location of Facility
2. Company Information
Name of Company
Address
Phone Number_
Owner
Person Responsible for SPCC Plan_
3. List of Agencies to Notify in Case of Spill
U.S.C.G. National Response Center (800) 424-8802 (24hr.)
Federal EPA Office: Phone # Location
State Pollution
Control Office: Phone # Location
4. Spill History
This facility has experienced no spills since January 10, 1973.
5. Description of Facility
This well is classified as an oil well producing 100 bpd of oil
and 30 bpd of salt water. A minimal amount of gas is also
produced, however, it is either vented to the atmosphere or
used to operate pumps. Equipment used consists of: Heater
treater, glycol unit and a barge containing two 5000 bbl
compartments for oil and water, respectively.
The well is located in the Bayou about 100 feet from the shore
line. The oil and salt water storage for this facility are
located on the barge (shown in the sketch attached hereto),
whereas the remainder of the facility equipment has been placed
In the marsh. The barge is diked on all four sides forming a
pond, the height of which is kept 2 feet below the top of the dike.
The well stream flows to a heater treater for separation.
181
-------
The oil and salt water subsequently flow in their respective
pipe lines to separate compartments on the barge, and the
small amount of gas 1s usually flared or used to run pumps.
The oil is pumped from the barge to the loading pier and trans-
ported to another barge for delivery to the customer. The
salt water is also transported by barge to a safe disposal
site, since this is a fresh water area.
Containment and Drainage
a. Existing
Any spill or leaks resulting from the heater treater
piping or glycol units located on the marsh land will
immediately contaminate the shore line. A spill from
the barge, however, can be contained for several days
within the pond before any seepage to the surrounding
water-way will result.
A sump box (drained by gravity to the pond) is located
at the end of the oil loading pier. The loading hose
is covered with a blind flange and kept in the sump box
when not in use. The pond created by the dike surrounding
the barge is sufficiently large enough to contain the
contents of the oil and salt water in the barge.
b. Proposed
The area around the heater treater glycol unit and under
pipe lines leading to the barge will be graded to a small
sump which can be pumped out to the pond. In the event
of a major spill, a surface pump will be installed to
reef rail ate the entire contents of the pond through
the heater treater, thus creating a closed system. All
piping over the water from well or loading piers will
have drip pans installed so spills can be conducted to
the above sump. 500 L.F. of floating boom will be install-
ed as shown on sketch. In the event of a spill, the
182
-------
boom will be Installed downstream and a cleanup contractor
called in at once.
7. Inspection and Training
A dally visual Inspection of all facilities is made by the
pumper who is experienced in oil field operations and is
familiar with the SPCC Plan. Formal training and briefings on
oil spill prevention and cleanup are given twice a year. All
repairs or necessary replacements are made promptly.
8. Certification
I hereby certify that this plan has been prepared with good
engineering judgment and fulfills the requirements of 40 CFR
Part 112.
Name (print)
Registration Number_
State
Signature_
Date
183
-------
SWAMP
HEATER
THEATER
DIKE
SUMP BOX
OIL
LOADING
PIER
BAYOU
-------
ESTIMATED COST OF IMPROVEMENTS
Staging and Delivery of Material $ 1200.00
Drip Pans on Pipeline Loading Pier, 100 L.F.
9 3.50 350.00
Drip Pans on Well Line, 80 L.F. @ 3.50 280.00
Sump Tank 70 bbl, Z800 + 350 I nstal 1 ati on 3150.00
Pump & Piping to Heater Treater 825.00
Repair Low Spots in Dike Around Barge 200.00
Grade Area to Sump 1000 S.Y. @ 1.00 1000.00
Floating Boom 500 L.F. @ 12.00 6000.00
Productivity 30% of Labor 1080.00
$14085.00
185
-------
APPENDIX G. GENERIC SPCC PLANS FOR THE PENN-GRADE REGION
Plan 7-1
SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN
1. Facility Information
Name of Facility .
Type of Facility_
Location of Facility_
2. Company Information
Name of Company_
Address
Phone Number_
Owner
Person Responsible for SPCC Plan_
3. List of Agencies to Notify in Case of Spill
U.S.C.G. National Response Center (800) 424-8802 (24hr.)
Federal EPA Office: Phone // Location
State Pollution
Control Office: Phone # Location
4. Spill History
This facility has experienced no spills since January 10, 1973.
5. Description of Facility
Two samll stripper wells (1 bpd each) are located on a side
hill sloping down towards the highway. Lines from these wells
run along the ground to a 5 bbl water knock out tank and then to
a 100 bbl capacity storage tank, setting at the side of the road.
A sketch is attached hereto showing the layout of this facility.
No protection or containment exists and any spill from water
knock out or pipe would drain to the highway. This type of
leak undetected for 24 hours could not exceed two bbls.
The oil storage tank, 100 bbls, if overfilled or if left with
an open valve, would drain to the highway and to the ditch
at the left and into a brook.
186
-------
5, Proposed Containment and Drainage
A small ditch will be excavated around the wells, water knock
out and under pipes, with excavation built up on the outside to
keep out rain water from surrounding areas. See Section A-A
and B-B on the attached sketch. These trenches will be connected
so that all spills and leaks will be conducted to the top of the
bank near the tank, thus draining into the new dike.
Around the storage tank a new earthen dike, 12" wide on top and
from 12" to 15" high (> 100 bbl capacity) will be constructed
along the highway and to the left of the tank tieing into the
existing bank at either end. Area inside the dike will be imper-
vious to oil spills and graded to a sump in the low corner. At
this point, a 4" line with a valve will drain from sump to ditch.
The valve will be locked in a closed position and all water tested
before discharge.
All ditches and dike areas will be maintained to provide flow at
all times and any spills or leaks cleaned up at once and stored
in drums for disposal by a waste oil dealer or re-entered into
the product line.
Truck loading connections will be kept inside the new dike.
7. Inspection and Training
A visual inspection will be made three times a week and all the
necessary repairs and replacements made. Spill prevention train-
ing is given twice a year, with emphasis on cleanup of ground
spills.
8. Certification
I hereby certify that this plan has been prepared with good
engineering judgement and fulfills the requirements of 40 CFR
Part 112.
Name (Print)
Registration Number
State
Signature_
Date
187
-------
GO
00
12" DIKE
ROAD
DITCH UNDER
PIPES
5 BBL
WATER
KNOCKOUT
ELL
WELL
rli1*"
m j ,.
*' ^-
6" J
•4" - 6"
SECTION A-A
12"
SECTION B-B
SIPHON DETAIL
-------
ESTIMATED COST OF IMPROVEMENTS
4" Valve, 12' of 4" Pipe for Dike $ 284.00
Rent Hand Temper for Dike Compaction
1 day
-------
Plan 7-2
SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN
1. Facility Information
Name of Facility_
Type of Facility_
Location of Facility_
2. Company Information
Name of Company
Address
Phone Number
Owner
Person Responsible for SPCC Plan_
3. List of Agencies to Notify in Case of Spill
U.S.C.G. National Response Center (800) 424-8802 (24hr.)
Federal EPA Office: Phone // Location
State Pollution
Control Office: Phone // Location
4. Spill History
This facility has experienced no spills since January
10, 1973.
5. Description of Facility
The 17 wells of this facility are scattered over eight to ten
acres of wooded land on both sides of a brook. The sketch
attached hereto shows the layout and drainage pattern of this
facility. Fifteen (15) of these wells flow by gravity to the
two 100-bbl storage tanks along the highway. The remaining
two wells flow to a 100-bbl tank along the brook and the oil
is then pumped to the roadside tanks for delivery to the truck.
All wells are pumped and are operated by individual timing
devices set to run the pump from 15 to 30 minutes, 3 or 4
times a day. The amount of oil being pumped at any given time
would not exceed one or two barrels per hour.
190
-------
6. Containment and Drainage
a. Existing
The only containment existing now are the pits as shown on
the attached sketch. These pits are continuously drained
through a 4-1nch siphon arrangement as shown on the sketch
attached. There are no definite means of conducting spills
and leaks to these pits. The six wells along the north edge
of the lease have no pits provided. Piping is run along the
ground with no provision for containment of spills. The two
storage tanks along the road have no dike or grading to keep
spills from truck loading or overfilling from draining to
highway.
b. Proposed
At the roadside tanks a three sided concrete curb will be
constructed open on the bank side, and the area graded
so all spills will be directed over the bank toward the
pit. Dikes around this pit will be raised to provide for
18" of storage above siphon level and extended to the bank.
The bank will be graded and a 6-inch dike (> 100 bbl capacity)
extended up each side to concrete curbs to positively direct
leaks or spills from tank to pit and keep all outside rain
water from entering this area.
At the low storage tank and pump along the brook, a partial
earth dike (> 100 bbl capacity) will be built on the low side
to contain tank spills. A 4-inch line with valve normally
closed will drain this dike to the pit southwest of the tank.
With the three storage tanks now properly diked, any large
spill, up to 100 bbl, from the tanks are contained.
The only remaining sources of spills or leaks will be from
Individual wells or lines and would never exceed 2 to 3 bbl/
hour. With timing devices in operation, this would be a
maximum of 2 bbl/hr x 1/2 hr x 4 operations per 24 hr,
or 4 bbl total for a 24-hour period.
191
-------
Where pits are adjacent to wells and piping pits will be
repaired to maintain a top elevation high enough to turn
all rain water that falls outside. In addition, small
dikes about 6" high will be extended from pit dike to
surround adjacent well or wells, insuring positive flow
to wells. See sketch attached.
For the six wells along north edge we will install two
new pits as shown and extend the dike around the well as
shown.
Beyond this impervious containment, any leak in a line
not protected will have a small pit hand excavated as
soon as the leak is discovered and the spill cleaned up
and hole filled with fresh dirt as soon as repairs are
completed.
7. Inspection and Training
This facility is visited a minimum of once a day by the owner
or a qualified person and all facilities are inspected. Any
repairs or replacements needed are made promptly. Training
sessions on spill prevention and cleanup are given twice a year.
8. Certification
I hereby certify that this plan has been prepared with good
engineering judgment and fulfills the requirements of 40 CFR
Part 112.
Name (Print)
Registration Number
State
Signature
Date
192
-------
EARTHEN DIKE
CONCRETE
DIKE
ROAD
6"
SECTION B-B
193
-------
tttlNTAIN 1?" BELOW TOP
OF DIKE
A /—
OLD DIKE
NEW DIKE AROUND
TANK FOR POSITIVE
FLOW INTO PIT. MAY
SLOPE UP GRADF IF TANK
IS HIGH. MINIMUM DIKE
HEIGHT = 1 FT.
MIN.
L AROUND
SECTION A-A
EDGE OF
EXISTING
PIT
THIS SOLUTION
CAN BE USED
WHERE SEVERAL
WELLS ARE ABOV!
PIT WITH MO
TANK. THIS
ARRANGEMENT ALSO
KEEPS RAINWATER
FALLING OUTSIDE THE
OUT OF PIT.
NEW DIKE
DIKED AREA
194
-------
ELEV.60
THESE TWO
WELLS PUMP
TO ROAD
PIT
ELEV. 15
STORAGE TANKS
WELLS
SMALL LOCAL OPERATOR
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' X 2000'
(NOT TO SCALE).
PIPE ABOVE GROUND EXCEPT FOR
ROAD CROSSING.
195
-------
PROPOSED COST OF IMPROVEMENTS
Concrete Structure at Roadside Tanks, 80 LF x 1.95 F.
T 27 * 6 yds 9 160.00 $ 960.00
Piping & 4" Valve @ Lower Storage Tank 284.00
Grading within Dikes and Well Area:
17 Wells 20 x 50 - 1000 SF ) 34005^ = 126 SF x
Road 20 x 40 = 800 SF j ~~TJ1.00/SY Hand
Lower Tank 40 x 40 = 1600 SF: 126.00
Repair 7 Pits, 1000 LF x $1.02/LF Hand 1020.00
Build 2 new Pits, Exc. 30 x 20 x 2 x 2 * 27 = 90 CY
(Machine) 1.00 90.00
Dike 100 LF x 1.021 LF Hand 102.00
Small Dikes around Well, 17 wells x 100 LF x .75 (Hand). 1275.00
$3857.00
Travel Time Allowance 25% 964.00
$4821.00
196
-------
APPENDIX H. GENERIC SPCC PLANS FOR THE NEW ENGLAND REGION
Plan 8-1
SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN
1. Facility Information
Name of Facility_
Type of Facility Fuel Oil Distributor
Location of Facility
Company Information
Name of Company
Address
Phone Number_
Owner
Person Responsible for SPCC Plan_
List of Agencies to Notify in Case of Spill
U.S.C.G. National Response Center (800) 424-8802 (24hr)
Federal EPA Office: Phone # _ Location
State Pollution
Control Office: Phone # _ Location _
Fire Department : Phone # _ Location _
Police Department: Phone // _ Location _
4. Spill History
This facility has experienced no spills since January
10, 1973.
5. Description of Facility and Containment
This facility is laid out as shown on the sketch attached here-
to. There are 5 horizontal 10,000 gallon storage tanks handling
92 fuel oil. Distribution is accomplished with 2 small delivery
trucks. Material is received by transport trucks not owned
by this facility.
Truck spills are contained by concrete aprons and catch basins
leading to a 4,000 gallon underground storage tank. This
capacity is equivalent to one compartment of a transport truck.
197
-------
Tank ruptures and/or pipe spills are contained within the concrete/
dike which has an overall capacity of 24,000 gallons. In the
event that a small leak would squirt the contents of the tank
beyond the concrete dike, the area lightly hatched between
dashed lines is graded to drain the fluid to the concrete apron
catch basins. Moreover, before any water is drained from the
sump it is checked for pollution prior to opening the valve.
All containment areas are sufficiently impervious to contain
oil spills.
Transfer Operations
Generally, fuel oil is delivered by transport truck to the
facility during normal operating hours. However, occasional
after hours deliveries are made by special arrangements with
the owner. The basic rules are: no smoking, shut off motor,
hook truck to grounding system, check all valves (facility
and truck) for proper flow and tightness, gage tanks and fill.
After the delivery has been completed, this procedure is reversed.
Regular delivery trucks are loaded under the same procedures
except for gaging of the tanks.
Inspection and Records
Visual inspections are made daily of all equipment and piping;
when replacement or repair is needed it is done promptly.
Housekeeping is kept up and small leaks from normal operations
are cleaned up immediately. No written procedures have been
prepared or records kept.
Security
All valves permitting the outward flow from any storage tank
or containment area are kept locked.
Lighting is adequate and the master switch for all pumps is
located Inside the warehouse.
The facility is fully fenced, gates are locked when the facility
is unattended.
198
-------
Vandalism or trespassing has not been experienced and no fence
1s provided around this facility.
9. Personnel Training and Procedures
All drivers and employees are made aware of the danger of a
spill and are under orders to clean up any spill wherever it
occurs. In the event of a spill, all trucks have been equipped
with a shovel and absorbent material. Training sessions are
given twice a year on spill prevention and cleanup methods.
10. Certification
I hereby certify that this SPCC Plan has been prepared with
good engineering judgment and fulfills the requirements of
40 CFR Part 112.
Name
Registration Number_
State
Signature
Date
199
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(101 ACCESS)
TO HIGHWAY
200'
RAILROAD
PROPERTY LINE
CONCRETE
TRANSFER
APRON
4000 GAL. 5-10,000 GAL.
UNDERGROUND #2 FUEL OIL TANKS
AREA DRAINS
GENERALLY
TO WEST
OFFICE
AMD
GARAGE
PROPERTY LINE
CONCRETE DELIVERY
APRON
TO HIGHWAY
100'
(10' ACCESS)
200
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ESTIMATED COST OF IMPROVEMENTS
Underground storage tank $ 2500.00
Lines, TOO LF of 4" pipe @ 7.00 700.00
2 aprons 12' x 30' x 2 = 720 SF @ 1.50 1080.00
2 concrete catch basins 900.00
Wall around tanks, 21 CY 0 160.00 3360.00
Grade area, gravel, 460 CY @ 3.00 1380.00
Spread gravel, 1 ump sum 120.00
$10040.00
201
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Plan 8-2
SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN
1. Facility Information
Name of Facility_
Type of Facility Fuel Oil Distributor
Location of Facility
Company Information
Name of Company_
Address
Phone Number
Owner
Person Responsible for SPCC Plan_
List of Agencies to Notify in Case of Spill
U.S.C.G. National Response Center (800) 424-8802 (24hr)
Federal EPA Office: Phone // Location
State Pollution
Control Office: Phone # Location
Fire Department: Phone # Location_
Police Department: Phone # Location_
4. Spill History
This facility has experienced no spills since January
10, 1973.
5. Description of Facility and Containment
This facility is laid out as shown on the sketch attached here-
to. There are seven (7) horizontal 10,000 gallon storage tanks
handling #2 fuel oil. Fuel oil is received and distributed to
customers by transport trucks. All trucks are owned by the
facility. All flow from the facility is from the high ground
(note contours) at the south end, then to a small stream. The
drive beyond (left side) the tank is hard to use and a concrete
retaining wall was built across the lower end of this drive, as
shown, creating a storage capacity of 30,000 gallons. A locked
202
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valve is located at the lower center of the wall to control
drainage from the area. A concrete fire wall is built
around the tanks on the north, south and east sides, while
on the west side it is a steep earth bank. A concrete
apron with catch basin (> 10,000 gal. capacity) is built at
the loading rack and a 4" drain line extends underground
to the pit as shown. With this, all spills, leaks and rain
fall are caught in this impervious containment area, which
has been designed to be consistent with 40 CFR 112.7 (3)
2 ii. All discharges are made only after testing of liquid
and under continuous supervision.
6. Transfer Operations
Generally, fuel oil is delivered by transport trucks during
normal working hours. After-hour deliveries can be made by
special arrangement with the owner. The basic rules are:
no smoking, shut off motor, connect to grounding system,
check all valves (facility and truck) for proper flow and
tightness, gage and fill. Regular delivery trucks are loaded
under the same procedures, except for gaging of tanks.
7. Inspection and Records
Visual inspections are made daily of all equipment and piping;
when replacement or repair is needed it is done promptly.
Housekeeping is kept up constantly and small leaks or spills
from normal operations are cleaned up immediately. No
written procedures have been prepared or records kept.
8. Security
All valves permitting the outward flow from any storage tank
or containment area are kept locked.
Lighting is adequate and master switches for all pumps are
located inside of the locked warehouse.
203
-------
Entire property is fully enclosed with a 6 foot chain link
fence and 2 strands of barbedwire.
9. Personnel Training and Procedures
All drivers and employees are made aware of the danger of a
spill and are under strict orders to clean up any spill
immediately wherever it occurs. All trucks are equipped
with a shovel and absorbent material, and some are kept
at designated areas around facility. Training sessions
are given twice a year on spill cleanup methods and
techniques.
10. Certification
I hereby certify that this SPCC Plan has been prepared
with good engineering judgment and fulfills the require-
ments of 40 CFR Part 112.
Name (Print)
Registration Number_
State
S1gnature_
Date
204
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STREET
) C
-NEW
CONCRETE
WALLS
10
EXISTING—«-|
COflRETE
WALL
STORAGE
205
-------
ESTIMATED COST OF IMPROVEMENTS
Concrete apron, 360 SF @ 1.50 $ 540.00
Catch basin w/grade & cover 450.00
4" line, 80 LF 0 7.00 LF 560.00
Valve through wall 300.00
Concrete wall across driveway, 11 CY @ 160... 1700.00
Concrete around tanks, 9 CY 9 $160 1440.00
$5350.00
Note: On five facilities, owner reported a total expense of $40,000.
206
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Plan 8-3
SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN
1. Facility Information
Name of Facility
Type of Facility Fuel Oil Distributor
Location of Facility
2. Company Information
Name of Company_
Address
Phone Number_
Owner
Person Responsible for SPCC Plan_
3. List of Agencies to Notify in Case of Spill
U.S.C.G. National Response Center (800) 424-8802 (24hr)
Federal EPA Office: Phone # Location
State Pollution
Control Office: Phone # Location
Fire Department: Phone # Location
Police Department: Phone # Location
4. Spill History
This facility has experienced no spills since January
10, 1973.
5. Description of Facility and Containment
This facility is laid out as shown on the sketch attached here-
to. There are five (5) 10,000 gallon vertical storage tanks
handling # 2 fuel oil. Distribution is accomplished by use of
one transport truck and two delivery trucks. This area drains
from north to south and at the lower end, extending across the
entire property is a 50,000 gallon capacity excavated earthen
pit lined with polyethylene blanket. This pit is equipped with
a locked outlet valve draining to a dry well. All spillage
leaks and rainfall lead to this pit and no drainage will be
made from this pit without proper inspection and supervision.
207
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6. Transfer Operations
Fuel oil is delivered to the facility by transport truck during
the normal eight hour working day, however, occasional after-
hours deliveries are made in which case the owner or an employee
are present to supervise the operation. The basic rules followed
during loading and unloading of the tank trucks at the facility
are no smoking, shut off motor, hook truck to ground system,
check all valves (both facility and truck for proper positioning
and tightness), and gage tanks to be filled. After delivery
has been completed the reverse of this procedure is followed.
These same procedures are followed with the exception of gaging
the tanks when the trucks are making deliveries to customers.
7. Inspection and Records
Visual Inspections are made daily of all equipment and piping
and when replacement or repair is needed it is done promptly.
Housekeeping is kept up and any small leaks from hose connec-
tions, valves, pipe joints are cleaned up immediately.
8. Security
A fence with a locked gate completely surrounds the entire
facility. Facility lighting is adequate to detect oil spills.
Flow/drainage valves, and pump starter controls, which service
the storage tanks, are kept locked in the closed/off position
when non-operating.
208
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10 Certification
I hereby certify that this SPCC Plan has been prepared with
good engineering judgment and fulfills the requirements of
40 CFR Part 112.
Name __
Registration Number
State
Signature ^__^__^,
Date
209
-------
HIGHWAY ELEV. 0
DRAIN (LOCKED)
DRY WELL ELEV. 2.0
ELEV. 15.0 TOP PIT
ELEV. 8.0 BOT. PIT
50,000 GAL. CAPACTTY
jSpLYETHYLENE LINED
ELtV.
CURB ASPHALT
FENCE
5-10,000 GAL.
TANKS
HIGHWAY
210
-------
ESTIMATED COST OF IMPROVEMENTS
Fence and gate, 480 LF @ 10.00 $ 4800.00
Polyethylene cover 4000 SF P.045 180.00
Concrete outlet section, 13 CY 0 160 2080.00
Excavate pit, 1000 CY (Machine) @ 1.00 1000.00
Haul out material, 1000 CY 9 .80 CY 800.00
Miscellaneous grading, asphalt curbs, and
telephone poles to hold polyethylene cover
1n place 1000.00
$ 9860.00
211
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TECHNICAL REPORT DATA
(Please read Inductions on the reverse before completing)
t. REPORT NO.
EPA-600/7-80-004
2.
3. RECIPIENT'S ACCESSION>NO.
4. TITLE AND SUBTITLE
SPILL PREVENTION, CONTROL AND COUNTERMEASURE
PRACTICES AT SMALL PETROLEUM FACILITIES
5. REPORT DATE
January 1980 issuing date
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
Nicholas P. Trentacoste, George R. Bierman,
James Cunningham
8. PERFORMING ORGANIZATION REPORT NO.
>. PERFORMING ORGANIZATION NAME AND ADDRESS
Science Applications, Inc.
1651 Old Meadow Road
McLean, Virginia 22102
10. PROGRAM ELEMENT NO.'
INE 826
11. CONTRACT/GRANT NO.
68-03-2032
12. SPONSORING AGENCY NAME AND ADDRESS
INDUSTRIAL ENVIRONMENTAL RESEARCH LABORATORY
OFFICE OF RESEARCH AND DEVELOPMENT
U. S. ENVIRONMENTAL PROTECTION AGENCY
CINCINNATI, OHIO 45268
13. TYPE OF REPORT AND PERIOD COVERED
Final 5-79
14. SPONSORING AGENCY CODE
EPA/600/12
IB. SUPPLEMENTARY NOTES
16. ABSTRACT
A study was conducted of small petroleum production and petroleum products distribution facilities (stripper
wells and bulk plants) to determine ability to comply with the oil pollution regulation (40 CFR Part 112).
Four regions of the United States were covered: Texas/Oklahoma, Louisiana, Perm-Grade (Pennsylvania, Ohio,
Kentucky, West Virginia, New York), and New England. Field surveys were conducted at 125 individual facili-
ties: 55 production facilities and 18 bulk plants in the Perm-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 regu-
lation and the techniques selected by the owners and operators to achieve compliance. The problems and com-
pliance 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 solut-.ons.
Existing spill prevention, control and countermeasure (SPCC) plans (required by the regulation) for the facili-
ties 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.
7.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
MDENTIFIERS/OPEN ENDED TERMS
c. COSATI Field/Group
Oil spills, oil production and storage
facilities, stripper wells, SPCC Plan
preparation and compliance, technical prob-
lems and solutions in compliance with Oil
Pollution prevention Regulation 40 CFR 112
68-D
8. DISTRIBUTION STATEMENT
RELEASE TO PUBLIC
19. SECURITY CLASS (This Report)
UNCLASSIFIED
21. NO. OF PAGES
224
20. SECURITY CLASS (Thispage)
UNCLASSIFIED
22. PRICE
CPA Form 2220-1 (*-73)
212
(.US GOVERNMENT HUNTING OFFCt 1980-657-146/5559
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