ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
EPA-330/2-77-008
Carbon Tetrachloride Spill Evaluation
FMC Corp oration
South Charleston, West Virginia
FEBRUARY 25-27, 1977
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
DENVER.COLORADO
MARCH 1977
VWWx?
-------
Environmental Protection Agency
Office of Enforcement
EVA-ZZO/2-77-008
CARBON TETRACHLORIDE SPILL EVALUATION
FMC CORPORATION
South Charleston, West Virginia
(February 25-27, 1977)
March 1977
National Enforcement Investigations Center
Denver, Colorado
-------
CONTENTS
I SUMMARY AND CONCLUSIONS 1
II RECOMMENDATIONS 5
III INTRODUCTION 6
IV INSPECTION OF AGING AND STORAGE TANKS ... 7
Aging Tanks 7
Storage Tanks 15
V PROCESSING AREA 19
VI SPILL PREVENTION 21
Review of FMC's SPCC Plan 22
APPENDICES
A Attendance Lists for FMC/EPA-NEIC Meetings
B FMC's SPCC Plan
C 40 CFR 112
D Sample SPCC Plan Format from American
Petroleum Institute Bulletin D-16
TABLES
1 Thickness Determinations, T-2206 12
2 Thickness Determinations, T-2205 14
3 Thickness Determinations, T-2204 16
4 Thickness Determinations, T-2803 18
5 Carbon Tetrachloride Storage Tanks .... 23
FIGURES
1 Aging Tank T-2206 with Plate Patch .... 9
2 Tank T-2206 Leak Location 10
3 Aging Tank T-2205 Thickness Measurements . 13
i i i
-------
I. SUMMARY AND CONCLUSIONS
1. On Thursday, February 24, 1977, at approximately 1:50 a.m., FMC
Corporation personnel reported to the West Virginia Department of
Natural Resources that Aging Tank T-2206 in the FMC carbon tetra-
chloride manufacturing facility at South Charleston, West Virginia
developed a leak and an estimated 400 to 500 gallons (5,300 to
6,600 pounds) of carbon tetrachloride were spilled into the Kanawha
River. According to FMC officials, this spill lasted approximately
65 minutes.
2. Visual observation of Aging Tank T-2206 by personnel from EPA1s
National Enforcement Investigations Center (NEIC) confirmed the
fact that a patch on this tank had recently been rewelded. The new
weld was on an old weld at the top of a patch (about 18 x 18 inches)
originally put on the tank in February 1976. The old weld was the
source of the leak.
3. NEIC personnel checked the wall thickness of the aging vessel that
failed and of the other two aging vessels in the process scheme.
In addition, the wall thickness of seven of the eight carbon tetra-
chloride storage tanks was checked. Testing was done using a K-B
Model CL204 ultrasonic tester.
4. Several wall thickness determinations were made in the vicinity of
the large patch on Aging Tank T-2206. -The lowest value observed by
the EPA personnel was 0.163-inch. This value was confirmed by FMC
personnel. FMC drawings indicated that the original tank wall
thickness was 1/2- (0.50) inch. One other small patch (about 3x4
inches) was found on this tank.
-------
2
5. Testing on Aging Tank T-2205 identified one area of the tank
having a wall thickness of 0.173-inch. This tank was reported to
have had an original wall thickness of 1/2- (0.50) inch. Insuffi-
cient measurements were made to assure that the tank is not less
than 0.173-inch thick at any point.
6. Several structural codes prohibit steel plate walls from being less
than 3/16- (0.1875) to 1/4- (0.250) inch thick. These codes are
published by the American Petroleum Institute (3/16-inch minimum),
American Water Works Association (1/4-inch minimum), and American
Society of Mechanical Engineers (1/4-inch minimum).
7. The tensile stress in the thinnest section of Aging Tank T-2205 was
calculated to be about 5,000 psi; steels conventionally used in
tank construction have recommended tensile working limits of
10,000 to 30,000 psi. The tensile stress in the tank wall is
modified by a shear stress due to the compressive loading by the
tank walls and roof.
8. Wall thickness measurements made on the storage tanks, as distin-
guished from the aging tanks, indicate that these tanks have had
minimal corrosion. The current wall thickness for the storage
tanks is very close to the original thickness given in the FMC
specifications.
9. The carbon tetrachloride Finished Storage Tank T-2803 showed evi-
dence of a small leak at a weld between the second and third plates
on the northeast quadrant of the tank. This leak area was approxi-
mately 3 inches long on the horizontal weld. The leakage had
removed the asphalt coating on the outside of the tank, from the
weld down to the bottom of the tank; however, this area showed no
liquid leakage on February 26, 1977. The liquid level in this tank
was not determined and may have been below the area of the leak.
This may be the source of a continuing leak.
-------
3
10. A crack was observed in a weld on the east end of a chlorination
feed tank. FMC officials stated that no spill was associated with
this vessel, that it is not in service, and that it is being
replaced. No evidence was noted that would indicate a spill from
this tank; however, steam and hydrochloric acid fumes were escaping
to the atmosphere from the cracked area.
11. Since no radiographic testing was conducted on the welds of any of
tanks, no statements can be made regarding their safety. Also, the
number of wall thickness determinations is not sufficient to
assure that the thinnest areas were located.
12. Several small corroded pipes extending from vessels were observed
in the process area. These could be accidentally broken off, thus
causing a carbon tetrachloride spill.
13. Corroded hand rails and structural steel make the process area
potentially unsafe for the workers.
14. FMC officials stated that the Company had reported about 40 spills
to the West Virginia Department of Natural Resources in the last
two years.
15. Currently, FMC has no spill prevention, control, and countermeasure
(SPCC) plan or containment system in the carbon tetrachloride
manufacturing or storage tank area.
16. The FMC oil SPCC plan, which was evaluated by EPA-NEIC, was not in
compliance with the provisions of the Code of Federal Regulations,
Title 40, Part 112 (40 CFR 112).
17. FMC is currently constructing a spill control and containment
system in the process area. This should, according to company
officials, contain minor spills such as the one that occurred on
-------
4
February 24, 1977. A copy of this plan is on file with the West
Virginia Department of Natural Resources but not with the EPA. FMC
is projecting a May 1977 completion of this project. Since the
details of this spill control plan have not been evaluated by the
EPA, this agency does not attempt judgement as to whether this
project would control a major process rupture.
-------
II. RECOMMENDATIONS
It is recommended that:
1. FMC arrange for structural analysis of all equipment, tanks and
piping in the carbon tetrachloride process area so that an in-
dependent determination of the requirements for safe operation can
be made. The analysis should be completed and results submitted to
EPA by April 30, 1977.
2. FMC expedite the construction of the spill control and containment
project in the process area so that this project can be completed
as soon as possible and in no case later than May 1, 1977.
3. FMC submit complete engineering plans, specifications and an opera-
tional narrative for the process area spill control and containment
project to the EPA by March 31, 1977.
4. FMC refile the existing SPCC plan in accordance with the criteria
of 40 CFR 112.*
5. EPA Region III obtain the records of all spills reported by FMC to
the West Virginia Department of Natural Resources in the past two
years and evaluate the nature, cause and size of each spill.
* Code of Federal Regulations, Title 40, Part 112.
-------
III. INTRODUCTION
On February 24, 1977, EPA Region III requested the assistance of
the National Enforcement Investigations Center (NEIC) in evaluating a
carbon tetrachloride spill which occurred early that morning at the FMC
Corporation plant in South Charleston, West Virginia. Representatives
from NEIC, Region III, and the West Virginia Department of Natural
Resources met with FMC officials on February 25, 26 and 27 [see Attendance
Lists, Appendix A] to evaluate the cause of the spill and determine
whether a spill of this type can be averted in the future.
FMC officials reported that a leak in carbon tetrachloride Aging
Tank T-2206 was discovered at about 1:50 a.m. on February 24, and that
it leaked for about 65 minutes before it could be stopped. FMC estimated,
and NEIC personnel confirmed, that 400 to 500 gallons (5,300 to 6,600
pounds) of carbon tetrachloride were discharged to the Kanawha River.
In the past two years, FMC officials said, about 40 spills had been
reported to the Department of Natural Resources.
When the February 24 leak was discovered, carbon tetrachloride
filled the tank to a depth of 21 feet. After 65 minutes of pumping at
60 to 80 gallons/minute, the tank content was reduced to 10 feet, 1 foot
below the leak. Also, the plant carbon tetrachloride production rate
was reduced. According to FMC officials, 65 minutes were required to
decrease the level of carbon tetrachloride because the main pump failed
and the spare pump would run only intermittently.
At meetings held with FMC officials, plant processes were discussed,
and the plant was toured to view major process equipment. Also, NEIC
personnel used a portable ultrasonic tester to measure tank wall thick-
ness at various points on Aging Tanks T-2204, T-2205, T-2206, and on all
active carbon tetrachloride storage tanks.
-------
IV. INSPECTION OF AGING AND STORAGE TANKS
AGING TANKS
On February 26, three aging tanks in the FMC plant were inspected
using a portable, battery-powered ultrasonic tester (K-B Model CL204).
On February 27, the four "day storage," two "sour storage" tanks and one
small "finished storage" tank were inspected with the same equipment.
The ultrasonic tester projects a pulsed beat of ultrasonic energy
into the steel of the tank wall. This pulse is reflected from the inner
surface of the tank and received at the ultrasonic transducer. The time
required for this two-way trip is accurately measured and converted to a
thickness value based on the speed of sound in carbon steel. With
calibration on a known standard, the instrument has a resolution of
0.0001-inch. The February 26 and 27 data, which appeared as four-digit
electronic displays, were rounded to three decimal places at the time of
measurement.
In addition to obtaining an objective record of the tank wall
thickness, subjective notes were taken based on the variability and
strength of the signal return from the transducer. This information is
indicative of the condition of the inside surface of the tank — a
smooth uniform plane versus a corroded, pitted tank surface. In the
case of severe pit corrosion, no signal is received by the transducer,
and no thickness value can be determined.
During a February 25 meeting, FMC personnel indicated that the
February 24 failure occurred on the third in the series of carbon
tetrachloride aging tanks. An 18-inch-square patch had previously been
-------
8
welded to the exterior of the tank about 10 feet above the tank bottom
[Figure 1]. The February 24 leak occurred in an opening in the weld at
the top of this patch, resulting in a spill of approximately 400 to 500
gallons (5,300 to 6,600 pounds) of 97% carbon tetrachloride.
Upon inspection of tank T-2206, NEIC personnel found that the leak
site had been covered by a large weld over the previous weld. Figure 2
shows the new bead of welding at the top of the visible patch.
T-2206 Measurements
Ultrasonic testing of Aging Tank T-2206 (3rd tank in series) began
at 2:50 p.m. on February 26 with calibration of the ultrasonic tester
against known standards. Thickness determinations were made in the
vicinity of the large patch; many of the sites gave no return, indicating
pit corrosion on the inside surface. Values as low as 0.163-inch wall
thickness were measured on the tank wall immediately to the left (east)
of the patch. Other readings within the area to the left of the patch
indicated a thickness of 0.278-inch, compared to a previously determined
thickness of 0.270-inch made by FMC personnel. Values above and to the
left of the leak site were measured at 0.174-inch, compared to an FMC
value of 0.170-inch.
Readings continued on Aging Tank T-2206 at other sites around the
periphery of the tank and at various elevations. A small patch had been
welded to the tank about 12 feet above the tank bottom and approximately
180° around from the large patch. Thickness determinations in this area
were approximately 0.3-inch. Determinations near the top of the tank
and on the tank dome indicated a thickness of about 0.5-inch, which is
the reported uniform thickness of the tank when new. However, Company
personnel indicated that the tank was probably made from a number of
old, existing tanks in the plant and could have been 3/8-inch thick when
-------
Figure 1. Aging Tank 7-2206 with Plate Patch.
FMC South Charleston Plant
-------
Figure 2. Aging Tank T-2 206 with Patch.
Leak occurred at weld near center top of patch.
FMC South Charleston Plant
-------
11
new rather than the reported 1/2-inch. Table 1 illustrates relative
locations of the thickness determinations made on tank T-2206.
T-2205 Measurements
Testing was next conducted on Aging Tank T-2205 (2nd tank in series).
Insulation on this tank was, for the most part, very wet. The source
and composition of the moisture was not determined. Measurements on the
dome and the upper plate revealed a thickness of about 0.7-inch, indi-
cating that the tank probably was made of 3/4-inch plate, rather than
the 1/2-inch plate shown on FMC drawings.
The north side of the tank at 3 to 4 feet above the base yielded
extremely variable readings, and in some cases there was no signal
return. Readings as low as 0.173-inch wall thickness were determined at
this site. The readings were definitely indicative of a zone of rather
severe corrosion around and above the outlet valve for this tank. Test
areas and some of the thickness determinations are indicated in Figure 3,
and the measured thicknesses are listed in Table 2.
Calculations on the tensile stress in the thin section of Aging
Tank T-2205 yield results of approximately 5,000 psi. Steels convention-
ally used in tank construction have recommended tensile working limits
of 10,000 to 30,000 psi. In addition, shear stress is imposed on the
tank wall due to compressive loading by the tank walls and roof.
Because of time and physical limitations, insufficient measurements were
made to assure that no point is less than 0.173-inch thick.
T-2204 Measurements
Aging Tank T-2204 (1st in series) was found to have a rather uni-
form thickness of approximately 0.5-inch. The tank surface near the
-------
12
Table 1
PLOT OF THICKNESS DETERMINATIONS
AGING TANK T-2206
FMC Corporation3 South Charlestons West Virginia
Approximate Height Tank Wall Thickness at Indicated
Above Base (ft) Compass Points (inch)
East South West North
30 0.502
16 0.448 0.443
0.292
11 0.309 0.331 0.230 0.174
9 0.215 0.278
8 0.525 0.314++
0.296 0.288
4 0.448 0.403
t data are placed in the table to recreate approximate location
of measurement on tank wall.
t+ This point on patch plate3 all other readings taken on original
tank wall.
-------
13
Figure 3. Aging Tank T-2 205.
Thickness measurement sites on north side near base.
Chalk numbers on tank are measured wall thickness in O.xxx inches.
FMC South Charleston Plant
-------
14
Table 2
PLOT OF THICKNESS DETERMINATIONS
AGING TANK T-2205
FMC Corporation, South Charleston, West Virginia
Approximate Height Tank Wall Thickness at Indicated
Above Base (ft) Compass Points (inch)
East South West North
30 0.696
20 0.770
0.792
6 0.537 0.711
(0.173 to 0.349)
4 0.302 0.732 0.735 0.304
0.218
Base 0.260
t Data are placed in the table to recreate approximate location of
measurement cm tank wall.
-------
15
base on the west side was severely pitted on the outside, to the degree
that no thickness determinations could be made. The insulation around
tank T-2204 was quite wet, either from rainfall or from minute quantities
of seepage through welds or small holes. Thickness measurements are
listed in Table 3.
Tank Mall Strength
A thickness of at least 3/16- (0.1875) inch than required by vir-
tually all structural codes for tanks, including those published by the
American Petroleum Institute (3/16-inch minimum), American Water Works
Association (1/4-inch minimum), and American Society of Mechanical
Engineers (1/4-inch minimum). In addition, no allowance was made for
corrosion, as is required by the codes cited. Furthermore, the existence
of 3/4-inch-thick metal on the top of the tank adds compressive loading
to the tank and further stresses the tank material.
STORAGE TANKS
FMC maintains four horizontal "day storage" tanks for storing the
daily carbon tetrachloride production. At the end of the day, the
quality of the stored material is tested and the carbon tetrachloride is
either transferred to "finished storage" tanks or, if the quality does
not meet specifications, to "sour storage" tanks for reprocessing.
Day-Storage Tank Measurement
Ultrasonic testing of the four day-storage tanks was conducted on
February 27. Thickness measurements were made on these four tanks (T-802,
T-803, T-804, and T-805) at mid-height and approximately 1 foot from the
-------
16
Table 3
PLOT OF THICKNESS DETERMINATIONS
AGING TANK T-2204
FMC Corporation3 South Charleston, West Virginia
Approximate Height Tank Wall Thickness at Indicated
Above Base (ft) Compass Points (inch)
East South West North
30 0.505
0.502
0.494 0.492 0.467 0.449
t Data are placed in the table to recreate approximate location
of measurement on tank wall.
-------
17
bottom near the east end of the tank, as well as at mid-height and near
the bottom on the east dome of the horizontal tanks. Thickness deter-
minations were from 0.5- to 0.6-inch. Only minor amounts of corrosion
appeared to exist and thickness values were generally uniform.
Sour-Storage Tank Measurement
Ultrasonic testing was conducted on the two sour-storage tanks.
Tank T-2801 was tested at four points about 1 foot from the bottom on
the cardinal compass directions, and at a point about 12 feet above the
base on the southeast quadrant. These values were remarkably uniform at
approximately 0.37-inch thickness.
Ultrasonic testing was also conducted on sour-storage tank T-2802
at points 1 foot from the tank bottom on the compass coordinates, and
at points just above and just below the 6-foot weld on the northeast
quadrant of the tank. Again, the readings were remarkably consistent at
approximately 0.37 inch.
Final-Storage Tank Measurement
Carbon tetrachloride which does meet product specifications is
pumped from the day-storage tanks to final-storage tank T-2803. FMC
personnel had previously measured tank wall thickness at a number of
points up a ladder on the southwest quadrant of this tank. NEIC person-
nel measured thicknesses at the same points and obtained very close
agreement with previous Company measurements [Table 4], Evidence of a
small leak at a weld between the second and third plates was noted on
the northeast quadrant. The leak was through a zone approximately
3 inches long on the horizontal weld. The leakage had removed the
asphalt coating from the tank all the way down the side of the tank;
however, this area showed no liquid leakage on this date. The liquid
level in this tank was not determined and may have been below the area
of the leak.
-------
Table 4
ULTRASONIC THICKNESS DETERMINATIONS*
Final Storage Tank T-2803
FMC Corporation
South Charleston, West Virginia
Location at Ladder
Thickness
EPA
FMC
(inch)
SW side, 3 inches from bottom
0.358
0.350
1/3 distance up first plate
0.356
0.345
2/3 distance up first plate
0.350
0.340
Top of first plate
0.349
0.355
Bottom of second plate
0.310
0.305
Middle of second plate
0.308
0.300
Top of second plate
0.302
0.295
Bottom of third plate
0.248
0.245
Middle of third plate
0.245
0.240
Top of third plate
0.240
0.240
Bottom of fourth plate
0.256
0.250
Middle of fourth plate
0.258
0.260
t Data collected February 273 1977.
-------
V. PROCESSING AREA
During the ultrasonic testing and the plant inspection, EPA person-
nel made general observations of plant conditions. It was noted that
the entire processing area was extremely corroded as a result of the
corrosive nature of the impurities in the product and the many fumes
within the plant area. Pure carbon tetrachloride, by itself, is not
corrosive. The impurities in the product during the manufacturing pro-
cess, however, are quite corrosive which accounts for the severe cor-
rosion in the process area and the lack of corrosion in the product
storage area.
All handrails and structural steel in the process area are badly
corroded and could be unsafe. Most of the processing equipment appears
to be very badly corroded with a high potential for developing leaks.
This is suggested by the FMC statement that in the past two years FMC
has reported about 40 spills to the West Virginia Department of Natural
Resources.
Corrosion of the numerous shut-off valves within the plant was
cause for concern. Due to the condition of many of these valves, it is
doubtful that they could be closed during an emergency. An extremely
large pipe wrench and "cheater" were required to turn off the valve on
tank T-2206 during the February 24 spill. This valve would normally
have been closed with a small valve wrench.
In addition to corrosion of the valves, there were a number of
sources of potential failure, partly stemming from plant design and
partly due to the severe corrosion. For example, a 1/2- to 3/4-inch
pipe projected approximately 2 feet horizontally from a pipe line at
-------
20
the bottom of tank T-2205. This pipe ended in a pressure gauge and
could easily have been broken by falling equipment or personnel in the
vicinity. Had this occurred, carbon tetrachloride under a pressure of
approximately 19 psi would have run directly into the Kanawha River
until the cut-off valve on tank T-2205 could have been closed. These
observations were conveyed to FMC personnel in a debriefing on February
27.
No radiographic testing was conducted on welds on the tanks; hence
no statements can be made regarding their safety. It is recommended
that the insulation be stripped from the three aging tanks and that a
complete structural test be conducted on them. Piping and mixing vessels
should also be structurally evaluated.
One chlorination feed tank in the carbon tetrachloride process had
a crack in a weld on the east end of the tank. FMC officials stated
that this tank is currently out of service, that a replacement tank has
been ordered, and that there was no spill associated with this vessel.
During the evaluation, no evidence was noted that would indicate a spill
from this vessel; however, steam and hydrochloric acid fumes were escaping
to the atmosphere from the cracked area. In normal operation, this tank
would contain carbon tetrachloride, sulfur monochloride, carbon disulfide,
and hydrochloric acid.
-------
VI. SPILL PREVENTION
FMC currently has no spill control system in the carbon tetra-
chloride manufacturing or storage tank areas; however, construction is
in progress that is designed to contain spills in the process area. FMC
officials stated that this construction is to be completed by May 1,
1977. A description of this project has been filed with the West
Virginia Department of Natural Resources but has not been filed with the
EPA.
In the current system, all of the non-contact cooling water (6,000
to 20,000 gallons/minute) is discharged into ground-level trenches in
•k
the process area and then to the river at NPDES discharge point 019.
These same trenches also collect all spills in the process area. After
the spill containment project is completed, all cooling water will be
removed from these trenches, collected in pipes, monitored for carbon
tetrachloride and discharged to the river. The only liquid that will be
collected in the trenches will be leaks from pumps, floor washings and
process spills. This liquid in the trenches will be sent to either of
two 50,000-gallon concrete containment tanks and the carbon tetrachloride
will be recovered.
FMC described the spill containment plan as follows:
1. The entire process area will have a 6-inch-high curb around it
and two concrete containment tanks will be installed. The
entire area will be blocked off so that only cooling water
will flow to the river via NPDES discharge point 019. All
liquid discharged in the process area will flow to the
* National Pollutant Discharge Elimination System.
-------
22
containment tanks, the carbon tetrachloride will be recovered,
and only soluble carbon tetrachloride will be discharged from
the containment tanks to NPDES discharge point 018.
2. All cooling water will be removed from the trenches in the
process area, put into pipes, monitored for carbon tetra-
chloride and discharged to NPDES discharge point 019. In the
event that carbon tetrachloride in excess of an unspecified
amount is found in the cooling water, the cooling water will
be diverted to the containment tanks until the source of
carbon tetrachloride is found and this leak is corrected.
When this project is completed, it should contain and eliminate all
leaks and spills, such as the one on February 24. With the information
available, it is not possible to determine whether the planned spill
containment system would prevent discharge if a major spill, such as
that caused by the rupture of a process tank, should occur.
FMC has eight carbon tetrachloride storage tanks, varying in size
from 14,600 to 1,269,000 gallons [Table 5]. There is no provision for
containing the carbon tetrachloride from these tanks. If a leak de-
velops or a tank ruptures, the carbon tetrachloride would be spilled
into the river.
A spill prevention, control and countermeasure (SPCC) plan should
be developed by FMC for these storage tanks.
REVIEW OF FMC's SPCC PLAN
A spill prevention, control and countermeasure (SPCC) plan is
¦k
required under 40 CFR 112 for all shore facilities which have a total
* Code of Federal Regulations3 Title 40, Part 112.
-------
Table 5
CARBON TETRACHLORIDE STORAGE TANKS
FMC Corporation
South Charleston3 West Virginia
Tank No.
Tank Use
Tank Volume
(gallons)
T-802
Day-storage
14,620
T-803
Day-storage
14,620
T-804
Day-storage
14,620
T-805
Day-storage
14,620
T-2801
Sour-storage
24,080
T-2802
Sour-storage
24,080
T-2803
Finished-storage
294,000
T-2804
Finished-storage
1,269,000
-------
24
storage capacity of more than 1,320 gallons of oil if the storage is
above ground, or more than 42,000 gallons of oil for buried storage.
Oil is defined to mean "oil of any kind or in any form, including, but
not limited to petroleum, fuel oil, sludge, oil refuse and oil mixed
with wastes other than dredged spoil."
A copy of the FMC plan [Appendix B] was obtained on February 26
from Mr. E. C. Ladd of FMC. The plan is reviewed below for compliance
with EPA regulations as defined in 40 CFR 112 [Appendix C]. Section
112.7 of this regulation presents guidelines for the preparation and
implementation of an SPCC plan. Appendix D is a sample SPCC plan format,
as recommended by American Petroleum Institute Bulletin D-16.
Section 112.7(a) provides that any facility which has experienced
one or more "spill events" within twelve months prior to the effective
date should include a written description of any such spill. No descrip-
tion of spills is included in the FMC plan. Statements by corporate
personnel indicated that the plant has experienced numerous spills of
various materials during the past two years. The spills have been
reported to the West Virginia Department of Natural Resources but have
not been reported to the EPA.
Part 1 of the FMC SPCC plan notes that the total volume of "scrap
oil" is less than 1,320 gallons and, hence, the provisions of Part 112
do not apply. Regulation 40 CFR 112 does not provide for the industry's
distinguishing the various categories of oil and excluding those portions
which are less than 1,320 gallons total. Rather, the regulation limits
the aggregate storage of oil to 1,320 gallons for those facilities which
do not require an SPCC. The scrap oil is apparently stored in 55-gallon
metal drums for removal by a private contractor.
Part 2 of FMC's SPCC plan deals with transformers within the FMC
operation containing a total of 111,081 gallons of oil. The conclusion
-------
25
of the plan is that the transformers are under sufficient surveillance
and inspection so that "no further oil spill protection is required."
This is counter to Section 112.7(c)(1) of the regulation, which requires
a preventive system which provides for containment and/or diversion to
prevent oil reaching navigable waters. No provision is made under this
Section for "constant operation surveillance." Section 112.7(d) does
provide for those cases where containment is deemed not practicable but
requires the development of a strong oil spill contingency plan and
written commitment of manpower, equipment and material to control spilled
oil. Part 2 of the FMC SPCC is not adequate in view of the regulations
and should be amended.
Part 3 of the FMC SPCC plan deals with the carbon disulfide plant,
which uses a kerosene-type absorption oil. This material is subject to
the SPCC requirements. The plan states that an American Petroleum
Institute (API) separator, 75 feet long, 11 feet wide, and 5 feet deep,
was put into service in early 1973. A skimmer is provided to pump
collected oil back to a process tank. Curbs and dikes are used to
"insure that all oil spills drain to the API tank." No data are provided
on the capacity of the curbs and dikes. Unloading areas are stated to
be "properly diked," with oil spills pumped to the API separator. No
information is provided on the capacity of the spill pump nor is infor-
mation provided on the dike volume and capacity for comparison with the
stated 7,000-gallon-tank truck used to bring oil to the area. The dikes
should hold at least the maximum capacity of the tank truck used for
transportation.
Part 4 of the FMC plan deals with the hydrogen peroxide plant.
This plant uses a kerosene-type work solution with 112,000 gallons in
storage tanks and 172,000 gallons in circulation within the process.
The plan states that the "entire process area is curbed and diked so
that any spills or runoffs are collected in a common drain sewer. This
discharges to a 25,000-gallon retention tank." No data are provided on
-------
26
the capacity of the curb and dike system. The 25,000-gal1 on retention
tank obviously cannot retain the entire 172,000 gallons of kerosene
circulating within the process at any given time. Any overflow from the
retention tank is supposedly pumped back to the process unit; however,
the capacities of the pumps are not stated. Overflow from the retention
basin would discharge to the FMC fly ash pond. This fly ash pond is
drained by an underflow weir which further tends to reduce oil spillage;
however, the fly ash basin appears to be subject to potential flooding.
Part 5 of the plan deals with the "Bins Run oil storage tank," a
gas well and an oil storage tank with a capacity of 4,200 gallons. The
plan states that the tank is to be relocated in the "summer or fall of
1974." No amended plan was included. It is noted that the plan date
was October 1974, which was after the stated time of tank relocation.
The FMC SPCC plan which was obtained on February 26, 1977 has not
been subjected to a thorough SPCC plan review. A brief review, however,
indicates probable deficiencies. It is recommended that Region III
personnel carefully review all the components of the FMC plan. It is
further recommended that FMC be required to prepare SPCC plans in the
detail recommended by the American Petroleum Institute.
-------
APPENDIX A
ATTENDANCE LISTS FOR FMC/EPA-NEIC MEETINGS
February 25-26-27, 1977
-------
EPA-FMC MEETINGS
Wayne C. Smith
Jim V. Rouse
David L. Brooman
Stanley A. Miskura
Lacy "Bud" Zimmerman
J. K. Chapman, Jr.
W. Warren Upton, Attorney
February 25, 1977
Attendance List 1
EPA-NEIC
EPA-NEIC
EPA-NEIC
FMC
W.VA.Dept. Natural Res,
FMC
Jackson, Kelly, Holt
and 0'Farrel1
B.P. Leber, Manager,
East Plant
Gregory R. Gorrell, Attorney
Wm. M. Blankenship,
Tech. Advisor
John R. Hufto, Resident Mgr.
Industrial Chemicals Div.
FMC
Jackson, Kelly, Holt
and 0'Farrel1
EPA-Region III
FMC
Wayne C. Smith
Jim V. Rouse
David L. Brooman
Wm. N. Blankenship,
Tech. Advisor
Rohn Khera
F. Roseberry, Tech. Supt.
East Plant
B. P. Leber, Mgr., East
Plant
Edward W. Sutton, Env. Mgr.
East Plant
Ernest C. Ladd, Env. Mgr.
February 26, 1977
Attendance List 2
EPA-NEIC
EPA-NEIC
EPA-NEIC
EPA-Region III
FMC
FMC
FMC
FMC
FMC Chemical Hdq.
Wayne C. Smith
Jim V. Rouse
David L. Brooman
Wm. M. Blankenship
Tech. Advisor
L. H. Zimmerman
D. B. Edwards
F. J. Roseberry
B. P. Leber
Ernest C. Ladd
February 27, 1977
Attendance List 3
EPA-NEIC
EPA-NEIC
EPA-NEIC
EPA-Region III
W.VA.Dept. Natural Res,
FMC
FMC
FMC
FMC
Denver, CO
Denver, CO
Denver, CO
So. Charleston, W.VA.
Nitro, W.VA.
So. Charleston, W.VA.
Charleston, W. VA.
So. Charleston, W.VA.
Charleston, W.VA.
Philadelphia, PA.
So. Charleston, W.VA.
Denver, CO
Denver, CO
Denver, CO
Philadelphia, PA
So. Charleston, W.VA.
So. Charleston, W.VA.
So. Charleston, W. VA.
So. Charleston, W.VA.
Philadelphia, PA.
Denver, CO
Denver, CO
Denver, CO
Philadelphia, Pa.
Nitro, W. Va.
So. Charleston, W.VA.
So. Charleston, W.VA.
So. Charleston, W.VA.
Philadelphia, PA.
-------
APPENDIX B
FMC'S SPCC PLAN
-------
. copy to 2-/2-6/77
ls->c4~ W>0*MiTH - B-f* 26
(1). AJ. &LqrvCEj&HlP -E.P4
SPILL PREVENTION CONTROL AND E*L> L^P/J - fMt
COUNTERMEASURE PLANS
The EPA requires a Spill Prevention and Counterneasure Plan (SPCC). The
follcvlng details the plan as required under Federal Regulations 40 CFR 112,
"Oil Pollution Prevention".
All oil storage or bulk use areas In the plant have been reviewed. The
following Is the SPCC for each situation.
Environmental Manager, E. W. Sutton, Is designated aa accountable for oil
spill prevention, and will report necessary items to line management.
1. Scrap Oil
Scrap or used lubricating oil, transformer oil, paint thinners, etc., are
stored behind 28-3, in 55-galIon metal drums. Minor spills are absorbed in
the ground. When some 1000 gallons of scrap oil is accumulated, it la
currently removed *>y Cralgaville Distributing, Inc., and used to spray on
their coal piles at Chelyan, West Virginia.
Since the aggregate storage is less than 1320 gallons {112.1(c)(2)], the pro-
visions of Section 112 do not apply. No further control is required; existing
control is adequate.
2. Tranaforaers
There are 92 oil filled transformers In the plant with a total of 111,081
gallons of oil. Sizes range from 15 to 11,640 gallons. They are all provided
with electrical overload protection and, in the event of overpressure, have a
top relief valve. In the event of overpressure, top gasses are released, not
the oil. The larger transformers have continuous temperature oonltoring.
The transformers are under constant operator surveillance and a continuous
inspection and maintenance program. The transformer oil is checked annually
for dielectric strength.
In view of the construction of these units, their necessary upkeep, and
constant monitoring, no further oil spill protection is required.
3. Carbon Disulfide Plant
The Carbon Disulfide Plant uses a kerosene-type absorption oil. 17,000 gallons
is in T-302,the storage tank, and 4,000 gallons is circulating in the system.
In early 1973 an American Petroleum Institute (API) design oil-water separator
was put into service. The unit is 75 feet long, 11 feet wide, and 5 feet deop.
A skimmer is provided to pump collected oil back to a process tank. Curbs and
dikes in the oil-containing section of the plant insure that all spills drain
to the API tank.
-------
Spill Prevention Control and Countermeasure Plan
Page 2
3. Carbon Disulfide Plant, continued
The oil storage tank and oil pump are contained within an adequate concrete
dike area, which can be Isolated.
Oil 16 unloaded from a 7,000 gallon tank truck. The unloading station area
Is properly diked and oil spills are pumped Into the API separator.
All equipment and tanks are under control of round-the-clock operators and
supervision. Repairs are made as required under a written work order systea,
signed by the responsible supervisor.
The plant Is fully fenced, and entrance gates guarded by watchmen. On evening
and midnight shifts the watchmen make hourly total plant patrols. The Carbon
Disulfide Plant has round-the-clock chemical operators. The chenical operators
continually monitor the entire oil system as part of their normal duties. A
high level alarm is provided on Inlet of the API separ-tor to alert the
operators of any unusual situation.
The facility has adequate lighting for both the patrolling watchmen, and
in-plant operators.
All personnel are properly trained in the operation and maintenance of the
equipment. All understand (he operation of the equipment as it la part of «
continuously-operating chemical process operating unit.
4. HydroRen Peroxide Plant
The Hydrogen Peroxide Plant uses a kerosene-type work solution. 112,000 gallons
Is contained In storage tanks and 172,000 gallons is circulated within the
process. The main storage tank of 47,000 gallons is protected by an earthen
dike, secured with heavy crushed stone, with a valved off drain which is only
opened to drain .iny accumulated rainwater. An unused extractor vessel In the
new process area is used to store an additional 35,000 gallons of oil. A
2,000 gallon storage tank is located in the southwest comer of the process
area. The entire process area is curbed and diked, so that any spills or
runoffs are collected in a common drain sewer. This discharges to a 25,000
gallon retention tank. Oil collected in the retention tank is pumped back to
the process unit. Overflow water from the tank discharges to a fly ash
settling basin. This discharge Is clear, however any oil particles In the
discharge ate retained by the absorbaiit fly ash particles. The water discharge
from the fly ash basin is through an underflow weir to further prevent any oil
spillage.
The cooling system in this chemical process unit is captive, recirculating
through cooling towers. Any oil leaks from heat exchangers are retained In
the cooling tower basins.
Oil is unloaded from tank cars in the process area. Any splll6 flow into the
collection system and are retained in the oil retention tank.
-------
Spill Prevention Control and Countermeasure Plan
Page 3
4. HydroRen Peroxide Plant, continued
All equipment and tanks are under control of round-the-clock operators and
supervision. Repairs are made as required under a written work order system,
signed by the responsible supervisor.
The plant is properly fenced, with the entrance gate guarded by operators.
On evening arid midnight shifts the operators make hourly total plant patrols.
The rlydrogen Peroxide Plant has round-the-clock chemical operators. The
chemical operators continually monitor the entire oil system as part of their
normal duties.
A level alarm (red light) is on the 25,000 gallon oil retention tank. It is
set to alert the operation when 1000 gallons of oil is in the tank.
The facility has adequate lighting for the patrolling in-plant operators.
All personnel are properly trained in the operation and maintenance of the
equipment. All understand the operation of the equipment as it Is part of a
continuously operating chemical process operating unit.
5. Bens Run Oil Storage Tank
Gas well No. 101 at Bens Run has a separator, and an oil storage tank con-
taining 4200 gallons. The tank contains water and drip oil from the gas. We
plan to relocate this tank In the summer or fall of 1974. Uhen relocated the
tank will be provided an earthen dike, a drain line and valve. The valve will
be locked in the closed position. It will be opened by supervision when
necessary to drain off rainwater. In the event of an oil spill, portable pumps
will be used to remove the oil. No pumping system will be provided.
The tank will be inspected periodically and repairs, including painting, will
be done as necessary.
The tank Is contained in a fenced area, and is monitored dally. No lighting
is provided, as it is in a remote area.
Training requirements are minimal as operation of the tank is under direct
supervision of management.
EWSutton
10-8-74
r
Certificate No 4815
-------
APPENDIX C
CODE OF FEDERAL REGULATIONS
TITLE 40, PART 112
-------
RULES AND REGULATIONS
Title 40—Protection of tho Environment
CHAPTER I—ENVIRONMENTAL
PROTECTION AGENCY
SUBCHAPTER D—V/MCR PROGRAMS
PART 112—OIL POLLUTION PREVENTION
Non transportation Related Onshore and
Offshore Facilities
Notire of proposed rule making was
published on July 19. 1913 containing
proposed regulations icquircd bv an
pursuant to section 31l(j)(l' of the
Federal Water Pollution "ontiol \ t.
as amended '86 Stat 868 33 USC 1251
et scq l. 1KWPCA • to prevent, discharges
of oil into the navigable watcis of the
United Slates and to contain Mich dis-
charges if they occur The proposed reg-
ulations endeavor to prevent such spills
by establishing procedures methoJs and
equipment requirements of ow nei -> or op-
erators of facilities engaged in drilling
producing, gathering storms processing
Teftning transfemnj disti ibutiii?. or
consuming oil
Written comments on the proposed
regulations were solicited and icceived
from lntci ested patties In addition a
number of teroal comments on the pro-
posal Merc also received The wutlen
comments are on file at the Divic.on of
Oil and Ha7ardous Materials OPice of
Water Picgram Oi>ciations US En-
vironmental Protection Agency, Wash-
ington D C
All of the coTimenLs have been given
careful consiriei alion and a numuer of
changes have been made in the rer Na-
tion These changes incoipoiate eithei
suggestions made in the comments or
Ideas Initiated by the suggestions
Some comments reflected a misunder-
standing of the fundamental principles
ol the regulation specificallj us tliov ap-
plied to older facilities and mw inal op-
erations During the development of the
regulation it was recognized that no
single design or operational standard can
be prescribed foi alt non-tiansportaiion
related facilities since the equipment
and opciational procedures appropriate
/or one facility may not be appiopriaLe
Jor another because of factois such as
function location and age of each facil-
ity Also new facilities could nch'eve ft
higher lev el of spill prevention tha i older
laclhties bj the use of fail-sale design
concepts and innovative spill prevention
methods and procedures It was con-
cluded that older facilities and marginal
operations cuuld develop stinng spill con-
tingency plans and commit manpower
oil containment devices and removal
equipment to compensate for inheicnt
weaknesses in the spill prevention plan
Appropriate chances wcie made in the
regulation to simplify clarify or correct
deficiencies in the proposal
A discussion of these changes, section
by section follows
A Section 112 1—Crncral applicabil-
Itv Section 112 1(b) the "foresecabil-
Ity provision", contained In 112 l'd( (4)
was added to paragraph 112 1(b) As
modified, the regulation applies to non-
transportation-relatcd onshore and off-
shore facilities which, due to their loca-
tion. could reasonably be expected to dis-
charge oil Into or upon the navigable
waters of the United States or adjoining
shorelines
Sections 112 lib!, 112 Hd) (4) and
112 3 arc now consistent
Section 112 1 <3> exemption for
f.iclitics with nonburicd tankage nas
extended to 1320 -allons in a?^re^ate
with no ringlc tank laiser than b60 gal-
lons and applies to all oils not just hcat-
in™ oil and motor fut1 Tin- . of G60
gallo'is arc the nomial domestic coac size
for nonbuned heating o.l UnVs Bii'ld-
ings nuj have two such lanls Facilities
containing small quantities of oil other
than moLor fuel or heating oil would
nKo be exempt thus niirin1 this con-
sistent with the definition oi oil in ? 112 2
B Section 11? 2—Di /nations Section
1122<1> Lne term na' r_able vvaleis'
was expanded to the moie de«criniivc
deflnit'on usea bv ihc \ational Pollutant
Discharge Elimination &vslein
Section 112 2 in• the US Coast
Guard definition of the term vessel'
was included This tciin is used in the
rcgulal.on and the definition is consist-
ent -villi the Department ol Tianspor-
ta'ion regulations
C Section l!J3—Requirements tor the
prepai ation and implementation of spill
pretention control and countermcacurc
plans A new pa-a^-aph id wis added
to 5 112 3 which applies to mobile or port-
ab'e facilities subject to the rculanon
These facilities need not picpare a new
Spill Prevention Control ind Counter-
measure PI in tSPCC Plan) each time the
facility Is moved to a new site but may
prepaie a general plan id»nti(j ing cood
spill pievention ui'-incerir.g pnctices ias
outlined m the guidelines s 112 7), and
implement these ptacticcs at each new
location
Section 112 3, (b) and (f) (which
was 5 112 3 tlie Re-
gional Administrator
Section 112 3(e) (which was §112 3
(d) in the proposed rule making) was
modilied to require the maintenance of
the SPCC Plan for inspection at the fa-
cility only il the facility was normally
manned If the facility is unmanned, the
Plan may be kept at the nearest field
oEQcc.
Section 112 3< i > < 1) (5 1123'eMl) In
tho proposed rendition' was chained to
includo the non nail itulitv of qualified
personnel as a icasou for the Kcuonal
Administrator grinting -ill cxunsion of
time
D Section 112 1—A'.'crrtment ol 'pill
pretention contm! at it ronnti rmcamrc
plans by Reatonrl Adr. mtrnlrr Section
112 Hsi'l!1 pc-iii.:- " • ltc» lonal Ad-
mmisti itor to require mu the owuci oi
opmtor furnish idditnrul in'oinntion
to I2l'\ alter one or .to e -m l ill ill h is
occurred Tlie chince luirii. the request
for additional infoitnuion to tint per-
tinent to Ihc SPCC Plan or to the pollu-
lioi. incident
Sect on 112 4'b' now. inds Section
112 4 " • *' not Th.-> siD-e t tion • ' ' '
Section 112 4(e) al owed the Regional
Admmjst-.nor to re imcndincnts
to SPCC Plans and -.pes.-r'Cs that the
amend nenl murl he mroriHir iied in the
Plan within 30 dajs i piess the Regional
At-iTTT.-trator ecirii"; a') enl tr effec-
tive date Tlie ch m^e a'.o" s ihe Hogion.il
Ad ninisti atoi to spier j an> appiop.i-
ate a ue that is rcuonarilc
Section 112 4'f) A i cv * 112 41ft has
been acioed which pro.idcs foi an appeal
bv an owner oj operator .i.s.i i decision
lendeicd bj the Hecion .1 AnmuiLslr.ilor
on an amencL-nent to .11 bPCC Plan The
aui)"?l is made to t\e nuii-u.iior of
F"PA a i d the uar aer.i|) i ot.. Iii.e^ the pto-
ecaures for making siis'i ai" appeal
E Sccfion 112 5—I'u'idmcnf n/ sjiii/
preiriinon eonfrol and cot/nfrrrnrnsurc
plans bv oliners or operators Section
112 5 three
yea.s The amendment riquned the in-
corporation of anv new field-proven
technology and hid to be ceitified bj a
Professional Engineer
The chance requncs that the owner
or operator review ti.e Phu every three
years to see if it netdv anunriment New
technology need be ircoipoiated or'v if
it will s ginficantlj rmucc the 'ikchnood
of a spill The change will prevent friv-
olous -ctrofitting of tq.mimcnl to fanli-
tics whose prevention ;>! ms arc working
succc-'.fully apd will not requ.re engi-
neering certification un'ess an amend-
ment is necessary
Section 112 5¦ c> this p.n i-rapn rc-
quued that the owner or f'ptr.iror amend
Ins SPCC Plan ^hen hi-, fac'..ty heevne
subject to 5112 4 (a'nLncime'it b> t;io
Regionil Admnnstr itoi i 'Inis para-
graph has been removed It is inconsist-
ent to require the ov ncr or operator to
independently amcnu the Plan .vhile the
Rcfiionrl AdniinLjtrator 13 icvicwuig it
for po^ible umer.dnK u
f Section 112 C—f nit iicnaUrrs Thero
are no changes in th.s section
G Section 112 7—(run1'lines lor the
preparation and imp/cnien£nf'On ot a
spill prcrention control and conntrr-
mcasurc plan Numerous chaises have
been made In the guidi lines section, the
changes have been primarily
1 To correct the use of language la-
consistent with guidelines I''or example,
the word "shall" has been changed to
"should" in S 112 7(a) through (e).
A-l
-------
RULES AND REGULATIONS
i. To give the engineer preparing the
Plan greater latitude to uu; alternative
methods better suited to a given facility
or local conditions.
3 To co\cr facilities subject to the reg-
ulation, but for which no guiuclincs were
previously given Tills catcgo' v Include":
such things us mobile facllitic nd drill-
ing nnd workover rigs
In oddltion wording was clanged to
differentiate between periodic observa-
tions by operating personnel and formal
Inspections with attendant record keep-
ing
These regulations shall become effec-
tive January 10, 1974
Dated November 27. 1973
John Qcarles,
Acting Administrator
A new Part 112 would be added to sub-
chapter D, Clnpter 1 of Title 40, Code of
Federal Regulations as follows
Bee.
112 1 General applicability
112 3 Definitions
113.3 Requirements for preparation and Im-
plementation of Spill Pre entlan
Control and Countermcar.ure plana
1121 Amendment of Spill Prevent'on Con-
trol and Counlcrmeasure Plans b>
Regional Administrator
112.5 Admeudment of Spill Prevention Con-
trol and Countermcasure Plans by
oi-ners or opemto-n
112 6 Civ II penalties
112 7 Guidelines for the preparation and
Implementation of a Spin Preven-
tion Control ond Countermcasure
Plan
Appendix Memorandum of Understanding
Between tho Secretary of the De-
partment of Trampo-tallon and the
Administrator of the LnvtronncntaJ
protection Agenej Section II—Defi-
nitions
nrc siibjoct to these rerulatlons to the
same extent as any person, except for the
provisions of t 112 6
(d) This part docs not apply to
< 11 Equipment or operations of vessels
or transi>on.iition-rcl ited onslioie and
oilshorc f.kililies which are fcubject to
authority and control of the Dcpa'Intent
of Transiwrtstion as defined In the
Memoinndum of Understandinr between
the Secretarj of " iansportation and the
Administrator of the Environmental Pro-
tection Aeency, dated November 24. 1971.
36 FR 24000
(2) Facilities which have an aggregate
Btorngc of 1320 gallons or less of oil, pro-
vided no sirplc container lias a capacity
in excess of 660 gallons
(3) Facilities which have a total stor-
age capacilv of 42000 gallons or less of
oil and such total storage cnpacity is
burled underground
(4) Non-transportation-related on-
shore and offshore faciht es, which due
to their location could not reasonably
be expected to discharge oil Into or upon
the ha . 'sable waters of the United States
or adjoining shorelines
(e) Tnts part provides for the prepara-
tion and implementation of Spill Pre-
vention Control and Countermea-ure
Plans prepared in accordance with
5 112 7, dengned to complement existing
laws regulations rules, standards, poh-
cies and procedures pertaining to sauty
standards, fue prevention and pol!t-t.on
prevention rules so as to fo'-m a compre-
hensive balanced Federal/Suae spill pre-
vention program to minimize the poten-
tial for oil discharges Compliance with
this part uoes not in any uav relieve the
owner or operator of an onshore or on
offshore facilitj from compliance with
other Federal, State or local laws
AuTiioarrT Sees 311())(1)(C) 31101(2),
(01(a), Federal Water Pollution Control Act
(Sec 3 Pub L 92-500 B0 Stat 816 rt crq
(33 OSC 12M ct scq ) ). Sec 4(b), Plib L.
03-500. 80 Stat 697 5 C S C Reo-v Plan cr!
1970 No 3 (1970), 35 Ftt 15GJ3 3 CFP. 10C8-
1970 Comp EO 11735 38 Fit 21243 3 CFR.
§ 112 1 Ccnornl applicability.
(a) This part establishes procedures,
methods and equipment and other re-
quirements for equipment to prevent the
discharge of oil frotn non-transporta-
tion-related onshore and olfrhorc f.tcili-
tles Into or upon the navigable waters of
tlie United Stales or adjoining snore-
lines.
(b) Except as provided in paragraph
(d) ot this section, this part npplies to
owners or operators of non-transporta-
tion-rclatcd onshore and oifshore fvili-
tlcs engaged in drilling producing fath-
ering, storing processing, refining,
transferring distributing 01 consuming
oil nnd oil products, and uhlrh. due to
their location, could reasonably be ex-
pected to discharge oil in harmful quan-
tities, as defined In Part 110 of this chap-
ter, Into or upon the navigable waters of
the United Stales or adjoinlnr shorelines
(c) As provided In see 313 '80 Stat
875> departments, orcncies, and instru-
mentalities of the Federal government
§ 112.2 Definition*.
For the purposes of this part
(a) "Oil' means oil of any kind or In
anv form Including, but not limited to
petroleum fuel oil sludge, oil refuse and
oil mixed with wastes other than dredged
spoil
(b) "Discharge" includes but is not
limited to any spilling, leaking, pump-
ing pouring emitting, emptjing or
dumping Tor purpotes of this part, the
tern ' cuscnarge' shall not include any
dischMre of oil which is authonred by
a permit Issued pursuant to Section 13
of the River and Harbor Act of 1839 (30
Stat 1121 33 use 407). or Sections 402
or 405 of the FWVCA Amendments of
1072 <86 Stat 816 ct scq .33 USC 1251
et seq ).
(c) "Onshore facility" means any
facility of anv kind located in, on or
under any land within the United States,
other than submerged lands which Is
not a transpoitatlon-related facility
(d) "Offshore facility" means any
f.icility of any kind located in. on. or
under any of the navigable waters of
tho United States which Is not a trans-
portation-! elated facility
tci "Owner or operator" means any
person owiung or opcrntinc an onshore
facility or an offshore facility, and in the
cose of any abandoned offshore facility,
the person who owned or opemU-d such
facility Immediately prior to such aban-
donment
(f) "Person" Includes an Individual.
Arm, corporation, association, and a
partnership
(g) ' Regional Admln'strator". means
the Regional Administrator of the En-
vironmental Prot'X'tion Agency, or his
dei'Kiiec in and for th*- IVgicn in which
the faemtv is located
(h) ' rranspori-ulcrn-rclated' and
"non-transportaiion-rel.ued ' as ap-
plied to an onshore or olMiore faclity
are defined In tne Mcmoranoum of
Understanding between the Secet-sry
of Transportation and the Administra-
tor of the Environmental Protection
Agency, dated November 24, 1971 3G FR
24080
"Spill event' means n discharge of
oil Into or npon the navigable waters of
the United States or adjoining shorei'nes
In haimiul quantities, as defined at 40
CFR Part 110
(j) "United States" means the States,
the District of Columbia the Common-
wealth of Puerto Rico the Canal Zone.
Guam. American Samoa the Vi*gln Is-
lands. and the Trust Territory of the
Pacific Islands
(k) The term "navigable wate-s" of
the United States means "navigable
waters' rs delrcd .r. rec: c. 5C2'7> of
the FWTCA ard Wc.udes
(1) all navigable waters of the United
States, as defined in jud
-------
(b) Owners or operators of onshore
and onshore facilities that become op-
erational after the cITrctue date of this
pari, and that have riistharged or could
reasonably be expected to diM-hat.e oil
In harmful quantities, as deruicd in 40
CPU Part 110 into ot upon the naiikable
waters of the United Slates or adjoining
shorelines, shall pieparc an SPCC Plan
In accordance with 5 112" Except as
provided for in paragraph applv
while the facility Is In a fixed (non trans-
portation) operatic mode
(d) No SPCC Plan shall be effective
to satisfy the requirements ot this part
unless it has been rcvie" ed bv a P.cgis-
tcred Professional Engineer and certi-
fied lo by such Professional Engineer
By means of this ceitifVv.ion the en-
gineer, having examined the facil'iv and
being familiar with the provisions o: this
part, shall attest that the SPCC Pl.in has
been prepared in accoi dance witn good
engineering practices Such certification
thai! In no Hay relieie the owner o- op-
erator of an onshore or onshore facility
of his duty to prepare and fuJlj imple-
ment such Plan in accordance With
{1127. as required by paragraphs (a),
(b) and (c) of this section
(e) Owners or oprratois of a facility
for which an SPCC Plan is requireu pui-
suant to paragraphs of
this section shall maintain a complete
copy of the Plan at sucli facility if the
lacility Is normally attended at least 8
hours per daj, or at the rcaicst Held
office if the facility Is not so attended,
and shall make such Plan availacle to
the Regional Administiator for on-site
review during norma! worktng hours
(f) Extensions of tune
(1) The Regional Administrator may
authorize an extension of time for the
preparation a.nd full Implementation of
an SPCC Plan besond the tune permitted
for the preparation and implementation
of an SPCC Plan pursuant to paragraphs
(a). ot tills section cannot fully com-
ply with the requirements of this part
as a result of either nonavailability of
qu.ililied pcisonuel or delajs In con-
struction or equipment delivery beyond
the conLrol and «ilhout the fault of such
owner or optratoi oi their respective
agents or employes
12> Anv owner oi operator seeking an
extension of time puisuant to paragraph
i f i tli ol this section mav submit a Icltci
of request to the Regional Admmistiator
Such letter shall include
Mi A complete copv of the SPCC Plan,
if completed,
(il) A full cvplanatiou of the cause for
anv such dclav ai.d the specific aspects
of the SPCC Plan alTected b> the dela>.
(ihl A full discussion of actions being
taken or contemplated to minunipe or
mitigate such deliv,
(iv) A pioposcd time schedule for the
Implementation of anv corrective actions
being taken or contemplated including
Inteiini dates for completion of tests or
studies installation and operation of an>
nccess.ny equipment or olner pievcntive
measures
In addition, such owner or operator may
"resent additional oral or written state-
ments m support of lus letter of icquest
<3> The subnn«.on of a letter of re-
quest for extension oi tune puisuant to
paragraph of this sect on shall In
r.o way relieve the ov ner or operator
from his obllsai on to complv with the
requirements of i 112 3 'a), ib) or (c>
Wnese an extension oi tune is authoiued
by the Regional Adrrjn.strator for par-
ticular equipment or other specific as-
rccii of the SPCC Plan such extension
shall in no nay a.Tect the owners or op-
c-ators obligation to comply with the
requirements of 5 112 3 (a>. (b) or tc)
v 1th respect to other equipment or other
specific aspects of the SPCC Plan for
v hich an extension of tune has not been
expressly authorized
§ 1 12 1 Anirnilmrnl of SPCC Plans by
Iti^ionil AilnwMi~lrulr>r
(a> Notwithstanding compliance with
5 1123 whenever a facility subject to
5 112 3 fa), or (c) has Dlschaised
moie than 1,000 US gallons of oil li\to
or upon the navinab'e waters of the
United States or adjoining shorelines m
a single spill event oi dischaiged oil in
harmful quantities as defired In 40 CPR
Pail 110 Into or upon the navigable
v iucis of the United States or adjoining
shorelines in two spill events reportable
under section 311(b)(j> qf the i-\SPCA,
occuinng within any tv clve month pe-
nod the owner or operator of such la-
cility shall sub-rut to tile Regional Ad-
ministrator. within 60 da>s fiom the time
Mich facilitv becomes subject to this sec-
tion the following
(11 Name of tnc facility,
(2) Nanie(s) of the owner or operator
of the facility,
(3) Location of the facility:
(4) Date and year of initial facility
operation,
(5) Maximum storage or handling ca-
pacity of the facility and normal dally
throughput.
(6) Descilption of the facility. Includ-
Inr maps, flow diaginms. and lopogiaph-
lial maps,
(7> A complete copy of the SPCC Plan
with an> amendments
<01 "1 he causeisi of such spill includ-
ing a fnihiie ainhMs of sjstrm oi sub-
system In which the I lilmc occulted.
¦ D' The conectiM- actions Midi or
counteimcasuics t ikcn i,nluding an
adequate desci lption of equipment re-
pairs and/or leplaccn.ents,
(10' Additional piewnlne measures
taken or rontciiinlalcd to minimize the
possibility of recuiieiice
tilt Such olhei iiifomiaiion as the
ncnoml Admin^tiatoi mav icasonaulv
requne peitinent to the Plan or spill
event
lb> Section 112 4 shall not applv until
the expuntion of the time peunit'ed for
the prepaiation and implementation of
an SPCC Plan pursuant lo : 11J3
ic• A complete com of all inhumation
piovidcd to the Regional Ad'innistiator
pursuant to panrraph i.a) of this section
shall be sent nt the >irae tune to the
State arency in chaire of watei pollu-
tion control actr.it es |-i m ceniPed m nl addiessed
to, or by peisoral ilrhveij io. fie lacibly
owner or operatoi, that le pioposes to
require an nmcndmi nt to the Pi m and
srall specify the Ve.ms of such .uii"i.d-
ment If the faciht,' owner oi opcik-
tor Is a corporation a cop> of suc'i
notice shall also lie mailed to the tecls-
tered arcnt, if any of such coipuiation
in the State wheie such [auhtv r. lo-
cated Witlun 30 tl i s froin icceipt of
such notice, the facility owner or opera-
tor may submit v rittcn infoin.ation
view s, and arguments on the amendment
After considering all relevant materal
presented the Regional .Vmlnistr iter
shall notify the fat ility ov nri oi opera-
tor of any amendment requued or shall
rescind Hie notice The amendment re-
quired by the Urginnnl Administrator
shall become part ol the Plan 30 days
A-3
-------
RULES AND REGULATIONS
after such notice, unless the Regional
Administrator, for Rood cause, shall
specify another effective date The owner
or operator of the facility shall Imple-
ment the Amendment of the Plan as soon
as possible, but not 1 iter than si\
months after the amendment becomes
part of the Plan unless the Rcrional Ad-
ministrator si wellies another dale
(f) An owner or operator may appeal
a decision made by the riigiou.il Acimiu-
Istiator lcquumg an amendment to an
SPCC Plan The appeal shall lie made to
the Administrator of the United States
Envnonmental Piotcclmn Agency and
must be made In willing within JO days
of receipt of the notice from the Regional
Administrator rcqunmg the amendment
A complete copy of the appeal must be
sent to the Regional Administrator at the
time the appeal is made The appe.il shall
contain a clear and concise statement of
the Issues and points of fact m tlic case
It may alio contain additional Informa-
tion which the ownei or operator wishes
to present In support of Ins aigument
The Admunstiator or his designee may
request additional infoimatiuti from the
owner or operator, or from any other
person The Adnnmstritor or his des-
ignee may request additional informa-
tion from the owner or operator or from
any other person The Administrator 01
his designee shall render a decision
within CO days of receiving the appeal
and shall notify the owner or ope ator of
his decision
§ 112 5 Amrmlrnrnl of ^pill Prnriitiiu
Control and OumlcriHtasurr I'Ijiis hy
owners or operator*
(a) Owners or operators of facilities
subject to }112 3 (a), (b) or (ct shall
amend the SPCC Plan for such fachty
In accoidanco with 5 1127 whenever
there is a change in facility design con-
struction, opeiation or maintenance
which materially affects the facility's
potential for the dischaige of oil into or
upon the navigable waters of the United
States or adjoininc shorelines Such
amendments shall be fully implemented
as soon as possible, but not later than
dx months after such change occurs
or fc) shall complete ft
review and evaluation of the SPCC Plan
ot least once every thioc years from the
date such facility becomes subject to tlus
part As a result of this luvicw and eval-
uation. the owner or opciator '.hall
amend the SPCC Plan within six months
of the review to include more ertectivc
prevention and contiol technology If
(1) Such technology will significantly
reduce the likelihood of a spill event
Irom the facility, and <2) if such tech-
nology has been field-pioven at the tune
of the review.
(c) No amendment to an SPCC Plan
shall be effective to satisfy the require-
ments of this section unless It has been
certified by a Professional Engineer In
accordance with J 112 3(d).
§ J12.6 Gvil penalties.
Owners or operators of facilities sub-
ject to 5 112 3 (a), (b) or (c) who vio-
late the requirements ot this part by
falling ot icfusing to comply with any
of the piowsions of 5 112 3 J 112-4. or
5 112 5 shall be liable for a ciul pemltv
of not more than S3 000 for each day
that such violation continues The Re-
pional Admlm .trator may assess and
compromise such civil pciMlty No
penally shall be assessed until the owner
oi opeialor shall have been Riven notice
and an opportunity for hearing
§ i 12 7 C.umIcIiiics fnr llir preparation
mill implement ilmn r>f a ?>pill I'd *
ifnlion Contrul ami Counlcrnicisurc
rijn.
The SPCC Plan shall be a carefully
thought-out plan, prepared in accoid.ince
Willi rood engineering practices, and
which has the full approval of manige-
ment at, a level with authonlv to com-
mit the necessary resouices ff the plan
calls for additional facilities or proce-
dures methods or equipment not jet
fully operational these items should be
discussed in sepaiate paugraphs and
the details of instillation and opera-
tional slarl-up should be explained '"p-
nntelj The complete SPCC Plan si.all
follow the sequence outlined below and
mcludc a discussion of the facility's con-
foimai cc v tl. the appiopnate guidelines
listed
Appropriate containment and/or
diversionary structuies or equipment, to
prevent discharged oil fiom reaching a
navirablc walei course should be pro-
vided One of the follouing preventive
systems or its equivalent should be
used as a mmunum
(1) Otishote facilities
(1) Dikes, berms ot retaining walls
siidlcicnlly impervious to contain spilled
oil
(n) Curbing
(in) Cuiverting, gutters or other
drainare systems
(iv) Weirs, booms or other barriers
(v) Spill diveision ponds
(vl) Retention ponds
Sorbcnt matei lals
(2) Offshore facilities
(I) Curbing, drip pa.is
(II) Sumps and collection systems
(d) When It is determined that the
Installation of structures or equipment
listed In { 112 T(c> to pi event discharged
oil from reaching the navigable waters
Is not practicable from any onshore or
offshore facility, the owner or operrtor
should clearly demonstrate such im-
piacUcabilny and piovide the follow-
ing
il)A strong oil spill contingency plan
following the provision of 40 C1"R Part
109
(2) A written commitment of man-
power equipment and materials re-
qu'red to r> peamouslv control and re-
move any hatmful quantity of oil dis-
chaiged
ie> Li addition to the minimal pre-
vention standards listed under before
drainage
tin) Plant drainage systems from un-
diked areas should if poss.b.e flow into
ponds lagoons or catchment basins de-
signed to retain oil or icttirn it to the
facility Catchment basins should not be
located in areas subject to periodic
flooding
i iv) If plant drainage is not en-
gineered as above the final disrhargc of
all In-plant d l-chcs should be equipped
with a diversion system that could n
the event of an uncontrolled spill, return
the oil to the plant
(v) Where drainage waters arc treated
In more than one treatment unit nat-
ural hydraulic flow should be used If
pump transfer Is needed, two lift"
pumps should be provided and at least
one of the pumps should be permanently
Installed when such treatment is con-
tinuous In any event whatever tech-
niques are used facility dramas systems
should be adequately engineered to pre-
vent oil from reaching navigable waters
In the event of equipment failure or
human error at the facility
<2) Bulk storage tanks (onshore). (ex-
cluding pmdurtttm facilities). U> Ho
A-4
-------
lank should be used for the storage of
oil unless lis material and construction
arc compatible with the material stored
and conditions of storage such as pres-
suro and temperature, etc
The bypass vahc Is opened, and
resealed following drainage under re-
sponsible supervision
(D) Adequate records are kept of
such events
(lv) Burled metallic storage tanks rep-
resent a ixjtentla! for undetected spills
A new burled Installation should be pro-
tected from corrosion by coatlnfrs,
eathodlc protection or other effective
methods compatible with local soil con-
ditions Such buried tanks should at least
be subletted to regular pressure testing
Aboveground tanks should be
tubject to periodic Integrity testing tak-
ing Into account tank design Uioating
roof, etc ) and using sucn l-rctmlqucs as
hydrostatic testing visual Inspection or a
system of non-destructive shell tliickness
testing Compaiison records should be
kept where appropriate and tank sup-
ports and foundations should be in-
cluded in thece Inspections In addition
the outside of the tank should fre-
quently be observed by operating person-
nel for signs of deterioration leaks
which might cause a spill or accumula-
tion of oil Inside diked areas
The feasibility of Installing an ex-
ternal heating sjstcm should also be con-
sidered
ivlli) New and old tank installations
should, as far as practical be fall-sofa
engineered or updated Into a fall-safo
engineered Installation to avoid spills
Consideration should be given to prov Id-
itiR enp or more of the lollowlrg devices
1Ai High liquid level alarms with an
audiulc cr visual signal at a constantly
manned operation or surveillance sta-
tic*! in sma1^' plants an audible air
veiit may sufi'cc
'B' Considering size and complcxit}
of the laeilitv high liquid level pump
cutofr devices set to slop flow at a pre-
detcimined lank content level
'Ci Direct audible or code signal com-
munication between the tank gauger and
the pumping station
t.D> A fas*, icspon^c svstem for deter-
mining the hqu'd level of each bulk stor-
age tank such as dlntnj computers tele-
pulse or direet vision gauges or their
equivalent
IE' Liquid level sensing devices should
be rcgularlj tested to insure proper
operation
i]x> P'mt effluents which are dis-
charged into navlgaole waters should
have disposal facilities observed fre-
quent)} erough to detect possicc s}stcm
upsets that could cause an oil spi'l eicnt
i\i Visible oil leaks which result in a
loss of oil from tank seams gaskets rivets
and bolus sufficiently large to cause the
accumulation of oil in di»ed areas should
be prompt!} corrected
(jili Mobile or pc-table oil storage
tanks 'ons.iore) snould be positioned or
located so as to prevent spilled oil from
rcachi 'g navigable waters A secondary
means of containment such as dikes or
catchment basins shou'd De furnished
for the largest single compartment or
tank These facilities should be located
w here they will not be subject to periodic
flooding or washout
(3' Facility (rcns/cr operations piunp-
mv and m-ptant process (onshore!, (ex-
cluding p'oduct.on /aciltlK's) (it Buried
piping Installations should have a pro-
tective wrapping and coatlnr and should
be cathodically protected If soil condi-
tions warrant If a section of burled line
is exposed for an} reason it should be
c?i cMjU r cxnmlned for deterioration If
corros'on damano Is found Additional
examination and coi lectivo action should
be taken as Indicated bv the magnitude
of the drmnge An alternative would be
the more Ircquem use of exposed pi|)e
corridors or galleries
'ill When a pipeline Is not In service
or In standby service for an extended
time the terminal connection at the
transfer point should be capped or
blank-flanged and marked as to origin
fin) Pipe supports should be properly
designed to minimise abrasion and cor-
rosion and allow for expansion and con-
traction
(|v> All aboveground valves and pipe-
lines should be subjected to recular ex-
aminations by operating personnel at
which time the general condition of
items, such as flange Joints, expansion
joints valve glands and bodice catch
pans pipeline supports locking of valves,
and metal surfaces should be a.-scs.scd In
addition periodic pressure testing may
be warranted for piping in .ireas uhere
facility drainage Is mii h that a failure
might lead to a spill event
ivi Vehicular tradlc granted enti} into
the facil'ty should be warned \oi ballv
or bj appropriate virus to be Mire tint
the vehicle because of it-s si,£ will not
endanger above nound piping
d) Facilir ImK car nnd ta".( trurk
load'nn unlr* nn rar< mris/mrc) ill
Tmk car ai ¦) tank tiurk Innri'iig un-
loading procedures should meet the min-
imum req'iii cments, and rc'.ulanon est lb-
Jjjl.cd bj the Depnrlnicnt of r.inspoi-
tation
ml Where rack area diair.a e docs
not flow into a catchment basin oi treat-
ment facilitv designed to ha.ul'c spills a
quick drainage s\stem shou'd be used Mi
tank truck loading and unimd'iK aicas
The containment s}stem sj-ould be de-
signed to hold at least m i\i num rap uity
of an} single compai tment of a ianw car
or tank truck loaded or unloaded in the
plant
'hii An interlocked warning licht or
phvsical baiTler s> stem or warning
signs should be provided in loading un-
loading areas to present vehicular de-
parture before complete disconnect of
fexiblc or fixed transfer lines
in and all outlels of Mich ve-
hicles should be clorcl\ cammed for
lcakace and if ncccssar, tiehtcned ad-
justed or replaced to prevent liquid
leakage while in tiansit
<5> Oil production /anlitirs 'i,ii IB) C) md
-------
(B) All tank battery and ccntrnl treat-
ing plant InstivlliUonsshould l>c provided
with a secondary means of cnnuiuimcnt
lor tlio entire contents of the larrr.t sin-
gle lank il I(m-mhic or alternate sj stems
such as those outlined in } 1U7n>
Drainage from undiked areas should be
safely confined in a catchment, basin or
holding pond
All tanks containing oil should be
Visually examined by a coini>ctent per-
son for condition and need lor nv-ue-
nanco on a scheduled periodic bj.sis
Buch examination should include the
foundation and supports of Links that
are above the surface of the ground
(D) New and old Uvnk battery installa-
tions shouid a-s far as practical be fjil-
safe engineered or updated into a fjil-
safo engineered installation to prevent
spills Consideration should be gr.cn to
one or more of the following
(II Adequate tank capncit> to assvre
that a tank will not overfill shou'd a
pumper/gauger be delayed In making; his
regular rounds
(2) Overflow equalizing lines octween
tanks so that a lull Link can overllow to
an adjacent tank
<31 Adequate vacuum protection to
prevent tank collapse dunng a pipeline
run
(<) High level sensors to generate and
transmit an alarm signal to the computer
where facilities arc a part ol a computer
production control sjsiem
(iv) Facility transfer oprrctions oil
production lacihtv (onshore) (A) .Ml
above ground valves and pipelines should
be examined periodically on a sched.ucd
basis for general condition of items such
as flange joints, valve glands and bodies
drip pins, pi|>cline supports pumping
well polish rod stuffing boxes, bleeder and
fauge valves
Salt water 'oil field brine) dis-
posal facilities should be examined often,
particularly following a sudden change in
atmosphenc temperature to detect pos-
sible system upsets that could cause an
oil discharge
(C) Production facilities should have
a program of flowlme maintenance to
prevent spills 'rom this source Tne pro-
gram should Include periodic examina-
tions. corrosion protection flo'line re-
placement and adequate records as ap-
propriate for the irdividu.i.1 facility
(6) Oil drilling and uarkoier /anltties
(onshorcl tl> Mobile drilling or workov or
equipment should be positioned or lo-
cated so as to prevent spilled oil from
reaching navigable waters
(II) Dependir.K on the location ntch-
ment ba.Miis or diversion structure; may
be necessary to intercept and contain
spills of fuel, crude oil. or oily drilling
fluids
(III) Before drilling below any casing
string or during workover oncritions a
blowout prevention iBor> assemblv and
well control sjsLem should be installed
that Is capable of controlling any well
head pressure that is expected to be
encountered while thvt BOP avcmhly Is
on tho well Casing and HOI' Instillations
should be In accordance with State reg-
ulatory agency requirements
(1) Oil drilling, production or viork-
orer focihfica (offshore! (ll Definition
"An oil drilling, production or workover
facility (oTstiorc)" may Include all drill-
ing or vvorko;er equipment we'ls flow-
Imcs palhenng lines, phtforms and
auxilnry nontransiKirlation - iclatcd
equipment and facilities In a Mii.'le geo-
gr.iptucal oil or gas field oiJcrntcd by a
sinele operator
MP Oil drainage rollcction equipment
• houicl be u-cd to prevent and central
sm ill oil spillace around pumps elands
valves flanges, cvpansion louus hoses
di.iin lines sepanvors tieilcrs tanks
and all-ed equipment Drains rn ihe
[acilus should be controlled and directed
toward a ccntial collection «utnp or
equivalent collection svstcm sullicicnl to
movent drchaiKes of oil into the nav nza-
bic waters of the United States Where
drains and sumps arc not practicable
oil ro.-lruncd In collection equipment
should be removed as often n-s necessary
to prevent overflow
Hui Tor facilities emplo>ing a sump
sjstem sump and drains should be ade-
quately sued and a spare puirp o- equiv-
alent method should be available to
remove liquid from the sump and assume
that oil docs not escape A rerular sched-
uled preventive maintenance ir_iuec .on
and tesfng urogram should be eirplojcd
to assure reliable operation of the liquid
removal sv sLcm and pump siart-up oe-
vice Kiclundant automatic sump pumps
and control devices may be required on
some installations
(Iv > In areas where separator and
trcatcrs are equipped with du np valves
whose predominant mode of failure Is In
the c^ed position and pollution risk Ls
high the ficil'ty should be specially
equipped to prevent the escape of oil
This could be accomplished bv cxtencing
the flare l.ne to a diked area if the sepa-
rator is near shore equipping It with a
hi(h liquid level sensor t) at will auto-
matically shut-In wells producing to the
separator parallel redundant dump
valves or other leasiblc alternatives to
prevent oil drebarges
(v i Atmospheric storaRc or surge tanks
should be equipped with high 115111-1 level
sensing devices or other acceptable al-
tematnes to prevent oil discliarrcs
Prrssmc tanks should be equipped
with hl,'h tmd low pressure sensing de-
vires to activate an alarm and/or con-
trol 'he flow or other acceptable alterna-
tives to prevent o'l disrhiu.-cs
tvili Tan) 1 should be equipped wRh
suitable coriosion protection
(vnn A written procedure for inspect-
ing and testing pollution preirn'-Ion
equipment ond systems should be pre-
pared and maintained at the facility
Such pro-cdurcs should be included nj
part of the SPCC Plan
not be needed 111 producing wplls
that will not flow but should be installed
as required by applicable State rrgula-
t'Oll-S
-------
RULES AND REGULATIONS
operating condition at nil times nnd In-
spected on a scheduled periodic basis for
failures Such inspections should be
documented nnd maintained at the
facility
(8> Inspections and records Inspec-
tions requlied by this part should be in
accordance with mil ten prooeiluics de-
veloped for the fncilitj by the oiwier or
opciftlor These written procedures and
a record of the inspections signed by the
appropriate supervisor or inspector
should be made pmt of the SP(C I'l-in
and maintained lor a period of thice
years
(9) Security including oil vroduction
facilities) All plants handling: proc-
essing. and storm; oil should be fully
Tcnccd, and entrance sales should be
locked and/or pinrded when the plant
Is not In production or is unattended
(11) Tlie master flow, and dmn vahei
and any other \akes that will per-nt
direct outward flow of the tanks con-
tent to the surface should be securely
locked In the closed position when In
non-operatlns or non-standby status
(Ul) The starter contiol on all oil
pumps should be locked In the ' oil"
position or located at a site accessible
onlj to nulhoii7ed peisonncl when the
pumps are In a iion-opcratinc or non-
standby status
(lv) The loading/unloading connec-
tions of oil pipelines should be securely
capped or blam.-flnnccd when not In
6ervlce or standby service lor an ex-
tended time This security practice/
should also apply to pipelines that are
emptied of liciu.d content either by
draining or by Inert eas picvsure
Discovery of -spills oc-
curring during hours of dantness both
by operating personnel. If present, arid
by non-operating personnel (the gen-
eral public, local police, etc ) and (B)
prevention of splits occurring through
acts of vandalism
(10) Persoiinc/, training and jpilf
jvcvcnfion proccc/urcs (1) Oftnep. or op-
erators are responsible for properly In-
structing their personnel In Uie oix;r.itlon
nnd malnteinnre of equipment to pre-
vent the dlsrharcs of oil and applicable
pollution control 1ms. rules and regula-
tions
(111 Each applicable facility should
have n tic~.irn.iled person -who Is account-
able for nil spill prevention imd who re-
ports to Unc innnnecmcnt
Owners or operators should
schedule nnd conduct *pi!l prevention
brirfinpi lor their opcratinc personnel
at Intervals frequent enough to n--j.ure
adequate understanding of the SPOC
Plan for that facility Such briefings
should hlrhllnht and describe known
spill events or failures malfunctioning
components and recently dcvelo|>cd pre-
cautionary measures
Appendix
Memorandum of Understanding l>ct*ecn
tho Secretary of lYanspomilon and the Ad-
nili Utrator of Iho Environmental rrotccuon
Agency
SECTION n—DEriNITIONS
Tho Ftnl^onmerual Protection Age ic\ nnd
the Department of Transportation a^iee thnt
for the purpoc.cs of ExccutUc Order 11548
the tenn
(1) ' Von-tn.n«.portaUon-relftled onshore
and onshore facilities me ana
fA1 rncd onshore and offshore oil •acII
drilling fevel 11 tics |j eluding all equipment
end appurtenances rented thereto used In
drilling operations for or d^tclop-
ment .veils but exefv rffng any urmrnaf
' Ij \i lit or process Integrally kv.oclatcd \Uih
the handling or tr^nsferting of oil in bulk to
or from a vcs^l
{n 1 Mobile on^ho-e and oiTshore oil *ell
drilling platform.1! barges trucks or other
mobile ftciiuicb including oil equipment and
appurtenances related thereto *hcn 6u<*h
mobile facilities are lixed In position for tho
purpose of drilling operations for explor-uory
or do*eiopment uebs but exrludi i, u'i. ter-
minal ficiht/ \inlt o- proee»s inu-craHy as-
roclated uHh ihc hand 'n, or transferring of
oil In bulk to or frcn a \ecsel
(C) Flxrd onshore nnd offshore oil produc-
tion structures plaifoiins derricks and rigs
iiiduUInil aid appurtenant cs
related t icrcio r«; 7 ell as corr.piced uclls
-"d. the uclJhcid separators oil separators,
and storage MOHties uacd In thr prcdnctton
of oil hLi ciclucing an/ lerminnl facility,
unit or process Lnter'al'v associated fcl'h
the handllnr or transferring of oil In bulk
to or from & vcs:>]
(Di Mobile onshore and ofchore oil pro-
duction facilities including all equipment
nnd appuncnancet related thirelo as well
as completed uolli and aeliheid equipment
i|*»'ng from vellheadi to o'l scpmito-s oil
separators nnd sto-ixce facilities us<^d hi the
production of oil uhen i\ich mobi'c facllitRs
rue fixed in pc'Jtion for the purpose of oil
production operftiions but eicludln^ 417
terminal facility unit or process integrally
a^ocJated Alih the handling or transferring
of oil in bulk to or from & vessel
(E) Oil relnlrg facilities includlnq all
equipment and appurtenances related
thereto as v.clj fi3 in-piant prores'.lnc; units,
storage unlta plplnp, dnvlnipc syslc:ii* and
waat* treatment units uie«J In the r^lnlnt*
of oil but ctciucf'rp anj wcrnfr.ai
unit or process Inicgr j-liy nisoclnietl w, ith the
handling o~ translcrrln^ o! oil Ln buU to or
tram a Missel
(D OIL storr^o 1 acllltlcs Including nil
cqulpmrnt njid a[>purtcnancc9 related
IheTcio as w-cll m nxed bulk plant -.torr.r;o,
terminal oU storage facilities coniumcr ?tor»
fcite. pum;/n (Lnd drain ire systems wed l:i the
"¦tornpr! of -oil, t>i;t. excluding Inline or brer*-
out fi-onre tinlcs needed for th« conlJnuoL'j
opcraiion of a pipeline system and any
terminal facility, unit or proce^ lDtcrmJIy
JtssocLated with the handling or transferring
of oU In bulk to or from a vessel
(G) Industrial, commercial, Apricultural
or public facilities uhlch lite aiul store oil
but excluding ftfiy tcrntnn) anil or
proce&a Int^prally associated urh the han-
dltng or tnii^Tcrrlng of oU ui bi Ik to or 'rorn
» \cssel
(JI) Wa*>te treatment farlli'lf. Including
In-plant pipelines cfMic.it and "\hlch ire not In-
tended to lrnnrport oil *11 inVrstru? or
Int-Vjtato coniTnerce but exLlud'c.p pipeline
sjs ems used to transfer ou in bu.»c to or
from a \cvic!
f4.) ' t-anrportntlon-relatcd onshore and
orshoro facilities' rreuns
\A) Onshore and o:Ti'iore te-m'jml fatui-
ties Inc'udlng trans'cr hos^s loat'lnf; arms
and o'^er evji^pment a^d a,»,jitr < rajiies
v-^ed for t' c purnoto of h" d • r or trn is-
ferrl ""q oil In buU to or from n v 1 sm I as
we»l a3 sto-aqt) tanks and a~puric*u,nc-es for
tho receptio \ of oltv bi3rast cr lank
7-ashln^s from tcafe's but rxrludl^j" ter-
minal waste treatment facUlt'es and ter-
mlnaJ oil stora^o facilities
(li) Transfer ho«*s londlrn arms and
other equipment appjrienttnt to a non-
transportatlou-rclated facllUv \».hlch Is used
to trmslir oil in bu.r to or fro.ii d >c^el
(C) Intcr-i'Atc and lntr-'-slat'* o^w'^ore and
o"s^ot'e p'pelino s\5tcms IncluJlnc; pumns
and app'if^e'M'fes related tht'^'o as wcli
a."* ln-li"e or breakout srora~e tv.iss rccdcd
tor the continuous operatiOT (rX a pl,jci»io
6ybtcni and pipelines ?ro n 01 shore* luid on-
shore oil production fa-!l!t'es but eicludlns
oaihorw and OTshore plpinc frr.ni wc'l^eads
to oil separators acid plprlincs - htca are
u^ed for tho transport o' n I r\clu 1 ely
Althln iho conflrcs of a r.o7>vra-"spo',tn,tion-
re'ntrd factlliy or 'crm'r-i firiiry Qrd
w.'ilch are not Intended to tran.pport oil In
interstate or intr&At-ato cor ncrce or to
transfer oil in bulk to or fro n a ;o.-^l
(D) J[':r^A*y ^ehlc'es and railroad c*n
vhlcli uo \iu:d for ih© lr:»jr«pr.rt c/ r.|] in
HiUi^Uto or lnlrr;tAic co^irrcrco a^tl ii e
en whjch they onsrat^ f xcluried
hUbuay rchLclts an-d railroad cjuu aj'.d mo-
tl\t> pow.rr xised exclu^hel? Aithln the con-
fr.cs of a no-ntrarLoporuitlou-rciatcd IficlHty
or terminal facility and "«hlch aro nc»t in-
tended for u&o la inter^toto or Lotrastate
commerco
\m DOC 73-25445 Filed 13-I0-73P6 45 mi
A-7
-------
RULES AND REGULATIONS
PART 110—DISCHARGE OF OIL
Bcc
110 1 Definitions
110 2 Applicability
110 J Discharge Into navigable waters
harmful
1104 Discharge Into contiguous rone 3mrm-
rul
1105 Dlaclnrpc prohibited
HOG Exception lor vessel encmes
1101 Dlspcrsaiits
1108 nrmonstrailon projects
110 9 Notice
Autuomtt The provisions 0/ this Po-rt
110 Uiuctl under sec HISIOI as intended.
81 Slat «3. 33 USC 1101
§ 1 ]0.1 Di fiinli.m-
As used in this part the following
terms shall have the mcami'g indicated
below.
(a) "OH" means oil of any kind or In
any form, Including but not limited to
petroleum, fuel oil, sludge, oil refuse oil
mixed with ballast or b.l e anc oil n.i\cd
wllh wastes other than ri'-erti.ed spoil
(b> "Discharge" includes but Is not
limited to, any spilling Ic.ikin:: pump.ng,
pouring, emitting, emptjmg or dunpi-'g.
ned or bare-boat chartered and oper-
ated by the United States or b; a State
or political subdivision thereof, or by a
foreign nation, e\cept when such vessel
Is encaged In commerce
(c) "Untied States ' means t.ie States,
the District of Columbia the Common-
wealth of Puerto Fliec. the Canni Zone.
Guam, American Samoa tne Vi-gin
Islands, and tlie Tnist icrrtory of the
Pacific Islands,
"PcriOi!" includes an individual,
firm, corporation, association, and a
partnership.
(g> "Contiguous zone" means the en-
tire zone established or to be estab'ished
by the United Stales under article 2-i of
the Convention on fie Territoilal Sea
and the Contiguous Zone.
"Federal Acl" means the Tederal
Wnler Pollution Control Act. as amended,
33 USC 1151, cl se /tinr
harmful.
For purposes of section 11(b) of the
Fedcial Act discharges of such quantities
oi oil into oi upon the waters of the con-
tiguous 7one detei mined to be harmful to
the public health or welfaieof the United
S'alcs, at all times and locations and
uader all circumstances and condition;,
evcopt as provided m section 110 6 of tins
patt includedischarrc; which
iiifare of the water or upon adjoining
shorelines
§110 3 Dim f< irjir prolululrd
As provided m section lKbHl!) of the
Federal Act no peison shall dischaipe or
cause or pcimit to be discharged into or
upon the navTnbic voters of the United
States, adjoining shoielines. or into or
upon the water., of the contiguous ?onc
nnv oil in haimful quantities as deter-
mined in $5 110 3 and 110 4 of this part,
except as the same may be permitted in
the contiguous ?one under Aiticle IV of
the International Convention for the
1'icvcntion of Pollution of tile Sea by Oil,
1954, as dmended
^ I 1 0 (t i \i < |iliit for « r-M I rti£iur«
For purposes of section 1Kb) of the
Federal Act. dischaiges of oil from a
properly functioning vessel engine arc
not deemed to be harmful, but such oil
accumulated m a vessel s bilges shall not
be so exempt
§ I 10 7 Ili-pcr- iijIh
Addition of dispcrsants or emulslflers
to oil to be disci lajgrd which would cir-
cumvent the provisions of this part Is
prolubitcd
§110 8 1)* mouslr ilioii cl«.
Notwithstanding nnv other piovisious
of this part, the Adiuin'stiaior of the Ln-
vironmcnl.il I'rotei tion Ar encv niav per-
mit tne discharge of oil into or upon the
navigable waters of the United St Ues,
adjoining shorelines, or into or upon the
waters of the contiguous /one m ron-
nertmn with irscarrh rir monsti atton
projects, or studies iclatmr to the pie-
vcntion control, or abatement of oil
pollution
§ 110 9 IVllllC
Anv person in charge of anj vessel or
onshore or ofTshoie facility shall as soon
as he lias knowledge of anv rt.schaige of
oil from such vessel or facility in viola-
tion of 3 110 5 of this part immediately
notify the U S Coast Guard of such dis-
charge in accoidanrc with such pio-
cedurcs as the Secietaiy of Transpoita-
tion may pi escribe
Appendix B
CODE OF FEDERAL REGULATIONS
TITLE 40 - PROTECTION OF THE
ENVIRONMENT
PART 110- DISCHARGE OF OIL
A-8
-------
APPENDIX D
SAMPLE SPCC PLAN FORMAT FROM
AMERICAN PETROLEUM INSTITUTE BULLETIN D-16
-------
(Pnor to com)ih ting i'rr/ tl,ufertoi cguln tinna ntul ninti ueturns page 5 )
SPILL PREVENTION CONTROL & COUNTERMEASURE PLAN
PART I
GKNF1UL INFORM \TION
1 Name of facility
2. T\ pc of facility
3 Location of faciliU
4 Name and addicss of ounei 01 opeiatoi:
Name :
Addi ess
5 Designated peison accountable foi oil spill pi e\cntion at f.icilit\
Name and title
G Facility expenenced ,\ lepoi table oil spill e\ent dui 111;: tlie t\\eh e months pi 101 to .Ian 10, 1071
(effecti\e date of 10 C'FIt, r.ut 112) (If YHS complete Attachment =rl )
MANACKMKNT AI'PKOVAL
This SPCC Plan will be implemented as heiein described
Signatuie
Name
Title
CEKTIF1C \TION
I heieb\ cei 11f\ that I have examined the f.icilit\, and being fannliai with the piousions of 10
CFK, Part 112, attest that this SI'CC Plan has Ijccm picpaicd in accoidance with good cnginccnng
practices
Punted Name of Registered Piofcssional Engineci
(Seal)
Signatuie of Kegisteied Piofcssional Fngmeei
Date Rcgistiation No State
B-l
(I'ort ]) I'afii' I of 3
-------
PART I
GENERAL INFORMATION
7. Potential SpilK — Prediction & Control.
Total
Major Type Quantity Hate Direction Second.ny
§ouicc ofFailiiie (bbls) (bbls/hi) of Flo" * Containment
Discussion:
'Attach m.iji if apiiroprute.
Name of facility
Operator
(P»rt I) l'*gc 2 of T
B-2
-------
PART I
(JENKRAI, INFORM VriON
l/!rs/mii*e ta sttitrnn ills he YES, \0, or NA (Not ApjtUcahle) ]
Containment or di\ei Monai v stiitctines 01 equipment to pievent oil from Teaching
n.-niRable uateis aie piactuable (If NO, complete Attachment =i2 )
Inspections and Recoids
A The loqun ed inspections lollou \m itten pio;eduie-
K. Tlie wiitten piocedines .mil ,i n'mid of inspections, sipned b\ the appropiiate
siipenisoi oi mspcctoi. ai e attached
Discussion
Pcisonnel. Ti.lining, and Spill !'¦ r\rnlion 1'iocediiies
A Pei scinnel aie piopcih instiuctcd in the following
(1) opeiation and numtcnam e of equipment to pi e\ cnt oil disehni ges, and
(2) applicable pollution contiol laws, 1 ules. and i emulations
Dcstnhe piocedines employed foi induction-
1> Scheduled ))ie\ention buefmgs foi the opeiatmg peisonnel aie conducted fre-
quenth enough to assuie ailecpiate undo standing of the SPCC Plan
Dcsu ibe bi icfnifr piogiam
Name of facility
Opeiator
B-3
(Part I) I'aRc 3 of 3
-------
(I'l wi to cumith'tntg 1'iiit //, Altt i ntiU <1, >i /ri tu ngulotiont, ami nt\trncttvns jmijt 3 0-7.)
PART II. ALTERNATE A
DESIGN AM) Ol'CR VTING INFORM \TION
ONSHORE FAClUn (EXCLUDING PRODUCTION)
Faiililj Di.linage
1. Di.unajre fiom diked sloias-e mens is cont 1 oiled "as follows (include opeiatinft desciiption
of \al\os, pumps, ejectois, etc (\'ot< FIi><>-type nthn should vol br unci)
2 Diaina) method ol \ .il\ liijr seem il\) ( A tecoid of inspection and diainage esents
is to he maintained on a foim similai to Attachment :="})
Name of f,ic ihtv
Opetatoi
(Part II, Altrrnali' A) Pbrc l of 5
B-4
-------
PART II. ALTERNATE A
DESIGN AND OPERATING INFORMATION
ONSHORE FACILITY (EXCLLDIMJ PRODUCTION)
[Ktsponie In alnh mr»t\ ilitwhl YES. SO, or V 1 f\'nt \\iiihenUle) ]
P.. Hiitk Sloraue Tank*.
1. Describe Link design, niatenals of construction, fail-safe engineering featuies and if
needed, corrosion protection
2. Describe sccondaiv containment design, consti uction matPiiaK and \olume
3. Describe tank inspection methods, pioceduies. and record keeping'
4. Internal heating coil leakage is controlled b\ one or more of the following control factors
(a) Monitoring the steam return or exhaust lines for oil
Describe monitoring procedure
(b) Passing the steam ictiirn or exhaust lines through
-------
PART I!. AI.THKNATK A
DESIGN AM) Ol'Klt \TING INFORM \TION
ONSHORE FACILITY (KXC'Ll'DING I'RODUCTION)
[Rcsitnntr to stnti nn nti thntthl hf VA'V, iVO, ot jV I (S'nt 1 pphrnhle) ]
C. Faulif\ Tian^fei Opei.ilions. Pumping. and In-pl.mt Pioccss
1. Conosion piotoction foi buiird pipelines
(n) Pipelines .ue wi.ipped anil coated to i educe coi i osion
(b) Cathodic piolection is ptovidod foi pipeline; if deteinuncd necessai y by elec-
trolvlic testing
(c) When a pipeline section is exposed, it is examined and coi 1 ecti\e action taken
as neccssaiy
2. Pipeline teinnnal connections aie capped oi blank-flanged and marked if the pipe-
line is not in seiucc oi on st.imlb\ scimco foi extended penods
Descnbe cnteiia foi detei mining when to cap or blank-flange
3 Pipe suppoits aie designed to nunimi/.e abiasion and coirosion and allow foi
expansion and conti action
Dcsci ibe pipe suppoi t design
A Desciilie pioceduies foi legulaih examining all abo\ e-gi ound \al\es and pipelines (includ-
ing flange joints, v.ihe glands and bodies, catch pans, pipeline suppoits, locking of valves,
and metal sui faces) •
5. Descnbc pioceduies foi warning \chicles entering the facility to avoid damaging above-
giound piping:
Name of facility
Operator
B-6
(Part II, Altt'inato A) PaRc 3 of 5
-------
PART II, ALTERNATE A
DESIGN AND OPERATING INFORMATION
ONSHORE FACILITY (EXCLUDING PRODUCTION)
[/fosponte to statements should he YKS", NO, or M (Not Applicable) ]
D. Facility Tank Car & Tank Truck Loading/Unlo iding Rack
Tank car and tank truck loading/unloading occurs at the facility (If YES, complete
1 through 5 below )
1. Loading/unloading procedures meet the minimum requirements and regulations
of the Department of Transportation
2. The unloading area has a quick drainage s> stem
3. The containment sjstem will hold the maximum capacity of any single compart-
ment of a tank truck loaded/unloaded in the plant
Describe containment system design, construction materials, and volume
4. An interlocked warning light, a physical harrier system, or warning signs nre pro-
vided in loading/unloading areas to prevent vehicular departure before disconnect
of transfer lines
Describe methods, procedures, and/or equipment used to prevent prematuie vehicular
departure
5. Drains and outlets on tank trucks and tank cars are checked foi leakage before
loading/unloading or departure
Name of facility
Operator
B-7
(I'irl II, Allrrnati- A) I'»Kr < of 5
-------
PART II. AMTRNATK A
DHKIGN AM) OITRVTINC INFORM \TION
ONSIIORK FA( ll.m (i:\Cl.l DING PRODUCTION)
[Rt'tfumtr to atoti inrutt shmthl In } h S't \f), ot \ I (Xnt 1 iijihruhlc) ]
I!. Sccuiily
1 Danls handling, piocessmjr, 01 stoiinp: oil .11 o fenced
2. lailiance pates aie locked .ind/01 rii,tided uhen the plant is unattended 01 not 111
pioductioii
3 An\ \al\cs \vIiicti peinul dnect out u aid flou of a tank's contents aie locked
closed when 111 non-opoiatmx 01 standbj status
4 Rtaitei contiols on all oil pumps 111 not) opei ating 01 standln status rue
(a) locked in the off position, .
(b) located at site accessible onl\ lo authoii/ed personnel
5. Discussion of items 1 thiouj;h I .is appiopnate .
(! Discussion of the lighting aiound the f.icilit\
Name of facility
Opeialoi
B-C
(Part II. Alternate \) Pdm* 3 of 5
-------
(Puor to rompicttng I*ntt //, Alti nniti' H. lcffr to i cqulntioiis antl ui^tmrtionm pnqt 7 )
PART II. ALTERNATE 15
DESIGN AM) OPERATING INFORMATION
ONSHORE OIL PRODUCTION FACILITY
[Kf^l'on^p to vtntt wi nti sliooltl ft i YKS, \'0 nt V I (Vnt A i>i>Ucnftlc) ]
A l'iicilitv Dtainage
1. Drainage fiom diked stoiage aieas is controlled as follows (include operating dcnnption
of \al\es, pumps, cjectois, etc )
•J The pioceduie foi Mipei vising the di.image of t.un walci fioin M*cnndai\ containment into
a stoini di.un oi ,in open \\ateicoui^e is as follous (include )
" Field diainage ditches iond ditches and oil tiaps sumps, oi skimmers, if such
exist, aie inspected .it i ojrul.ii I \ scheduled intei\.iK foi accumulations of oil _
De*(iibe inspection pioceduies lnteivaK and methods emplo\ed to iemo\eoil _ _
1! ltulk Ktoiagc Tank*-
1. Dcscube tank design, matenals of consti uc tion, and fail-safe engineei ing featuies
Name of facilit-v
Operator
B-9
(I'art II, Altruist.- II) Pace I of 2
-------
PART II, ALTERNATE B
DESIGN AND OPERATING INFORMATION
ONSHORE OIL PRODUCTION FACILITY
[Reipoiwe to itntements should be YES, NO, or NA (Not Applicable) ]
2. Describe secondary containment design, construction materials, and volume.
3. Describe tank examination methods and procedures
C. Facility Transfer Operations
1. Describe scheduled basis for examinations of above-ground valves and pipelines and salt water
disposal facilities .
2. Describe flowhne maintenance program to prevent spills
D. Oil Drilling and Workover Facilities
1. A blowout preventer (BOP) assembly and well control system is installed before
drilling below any casing string and, as required during workover operations
2 The BOP assembly is capable of controlling any expected wellhead pressure.
3. Casing and BOP installations conform to state regulations
Name of facility
Operator
B-10
(Part II, Alternate B) Page 2 of 2
-------
(I'uih to foiii/i/Wmj I'nrt II, Altrniiite C. 11 fcr to rrgulntiuna mill instinctual* /ni'ic h )
PART IF, ALTERNATE C
DESIGN ANI) OPER VTING INFORMATION
OFFSHORE OIL DRILLING. PRODI CTION. OK \\OKkO\ER FACILITY
[Renni-r to st'itriiifiiti ilioiilil In YI.'S, SO, o> V \ (\nt Ai>j>lrcnhlr ) ]
A. Facility DiainnRC
1. Oil riiamagc and collection equipment is \i-cd to catch small oil leakage mound
jjuinps, glands, valves, flanjres. expansion joints, hoses, Hi am lines, sepai atois,
ticatei s, tanks, etc
2 Diains ducct all oil to a cential sum]) 01 equualent
3. Whcie diains and sumps an> not piaclicable, oil collection equipment is emptied as
often as necessai y to pi event o\ ei flow
Discuss fi equencv of sin \ eillance and iemo\ al of oil fiom collection equipment
1> Sump System
A sump svstem is used at this faciht\ (If YI'S, complete 1 and 2 below )
1 De.sciibe opeiation of sump and diain liquid iemo\al s\stem
2 Descnbc pieventive maintenance inspection, test piogiam, and record keeping:
Name of facility
Opcratoi
B-ll
(Part II, Allciuntc C) Tn^c I of 3
-------
PART II. ALTRRNATR C
DESIGN AM) OPKK \TING INFORM \TION
OFFSHORR OIL DRILLING, PRODICTION, OK \\ORKO\RR FACILITY
to stnlewrnts should bt Yf-'S, SO. ot KA (\ut -1 /ijiltcablc) ]
C. Scpaialor and Ticater Dump V.ihes
In areas whcio pollution iisk is hiprh as a lesult of dump \al\e failuic is the piedom-
mant mode of failuic in the closed position'
If YRS, destnbc safet\ ecjinpnient ami pioceduies used to pie\ent oil disthaiges to the w.iloi
when dump \al\ c failuie ocuirs
D. Tanks
Describe equipment used to prevent oil dischaiges (include discussion of conosion piotcction
measuies) .
E Pollution Piexenlion Equipment and Systems
Written inspection and testing pioteduies foi pollution pre\ention equipment and systems aie
shown on Attachment = 1
F Well Control Systems and Equipment
1. Hioduciix; 11 'ells T\pes r>f sin face and subsurface shut-in \alves and deuces utilized at this
facility aie descubed as to the method of operation and control on Attachment rrr>
2 Drilluini,tion\ A blouout pie\enter (HOP) assembh and uell
control system is installed before dulling below any casing string and, as icquircd
during workover opeiations
Name of facilitj
Operator
B-12
(I'art II, \lU i nalc C) I'apt I of J
-------
PART IF, ALTERNATE C
DESIGN AND OPERATING INFORMATION
OFFSHORE OIL DRILLING, PRODUCTION. OR WORKOVER FACILITY
[t\rajinusr In \tntimcnts should he YES, NO, or NA (Not Applicable).]
2. The P.OP assembly is capable of conli oiling any expected wellhead piessuie.
3. Casing and DOP installations confoim to state 1 emulations
C WnKcn Institutions for Contractors
1. Wnttcn insli uctions dis( ussing duties and obligations to prevent pollution aie
piepaied foi contiactors sei vicing a well or sjstems appuitenant to a well or
pi essuie v es--els
2. These insti uctions aie m.untamed at the offshore facility
3 An authoi i/ed lepiesentative of theownei oi opeiatoi is piesent under cei tain cir-
cumstances and conditions to intei\ene when necessary to pi event a spill event
H Flow lines
1. All heafleis have check \al\es qii individual flow lines
2 Wheio the shut-in well piessuie is gienlei than the woiking pressuie of the
flowlme, manifold valves, and flowline hcadei valves, the flowline shall have a
high piessuie sensing device and shut-in valve at the wellhead to pievent over-
pi essuimg (unless a piessuie itlief svstem is piovided)
1 Pipelines
1 Descube conosion piotection measures foi pipelines within the facility:
2 Submanne pipelines connected to the facility are adequately piotected against
envnoiiment.il sti esses and fishing opeiations
3 Descnbc submanne pipeline inspection-foi-failuie piocedures and recoid keeping
Name of facility
Opeiator
B-13
(Pait II, Alternate C) PaRr 3 of 3
-------
SPCC PLAN, ATTACHMENT =1
SPILL HISTORY
(Complete tliis form for anv lejwrtable spill (s) which has (ha\e) occurred fiom this facility
during the twelve months pnoi to January 10, 1971 into -—
navigable water.)
1 Date Volume Cause.
Corrective action taken:
Plans for pteventing lecurience:
2. Date Volume Cause
Corrective action taken:
Pliins for pi eventing lecurrence:
3 Date Volume Cause:
Coirectiveaction taken:
Plans for pi eventing recurrence.
Name of facility
Operator
(Attachment # 1, SPCC Plan)
B-14
-------
SPCC PLAN, ATTACHMENT if2
OIL SPILL CONTINGENCY PL\iYS AND
WRITTEN COMMITMENT OF MANPOWER
Secondary containment or diversionary structuies are impiacticable for this facility for the fol-
lowing leasons (attach additional pages if nccessaiy):
Yrs
A strong oil &pill contingents plan is attached
A wi itten commitment of manpouei is attached
Name of facility
Operator
B-15
(Attachment #2, SPCC Plan)
-------
Inspection Procedure:
SPCC PLAN, ATTACHMENT r±.1
ONSHORE FACILITY HULK STORAGE TANKS
DRAINAGE SYSTEM
Rccoifl of diainape, bypassing, inspection, and oil removal fion) secondary containment.
Date of
Date of K\ passing Date of Supervisoi's or
Diainapc Open Closed Inspection Oil Removal Inspectoi's Signatuie
Name of facility
Opcratoi
B-1C
(Attachment #3, SPCC Plan)
-------
SPCC PLAN, ATTACHMENT £1
OFFSHORE OIL DRILLING. PRODUCTION. OR WORKOVER FACILITY
POLLUTION PRE\ ENTION EQUIPMENT AND SYSTEMS
Pollution Prc\ention Equipment:
Desciiplion Inspection Procedures Test Procedures
Supervisoi \ 01
Inspection Inspector's
or Test Date Condition Action Taken Signature
Name of facility
Operator
B-17
(Attachment #4, SPCC Plan)
-------
SPCC PLAN ATTACHMENT =3
OFFSHORE OIL DRILLING. PRODUCTION, OR WORKOVER FACILITY
WELL CONTROL SYSTEMS AND EQUIPMENT
List typc(s) of suiface and subsurface well shut-in valves and dc\ices used to maintain contiol of
wells, showing (a) method of activation and control, and (b) description:
Method of Activation
Item and Control Description
Name of facility
Operator
B-18
(Attachment #5, SPCC Dan)
------- |