Chris Perry FRP/SPCC Inspector Region 6

Transcription

1 Chris Perry FRP/SPCC Inspector Region 6 1

2 Best Resource document for SPCC Questions: 2

3 Module Objectives: Provide an overview of 40 CFR 112 Discuss administrative requirements: For development of an SPCC Plan Discuss general contents of an SPCC Plan 3

4 40 CFR 112 Structure General applicability of the Rule Definitions of terms used in the Rule Requirement to prepare an SPCC Plan Amendment of SPCC Plan by RA Amendment of SPCC Plan by owner or operator Qualified Facilities [2006 amendment] General requirements of all facilities Additional specific requirements for different types of facilities and different types of oils Facility Response plans Facility Response training and drills/ exercises 4

5 40 CFR 112 Structure (continued) Appendix A Appendix B Appendix C Appendix D Appendix E Appendix F Appendix G 5 Memorandum of understanding between DOT and EPA Memorandum of understanding among the DOI, DOT and EPA Substantial harm criteria Determination of a worst case discharge planning volume Determination and evaluation of required response resources for facility response plans Facility-specific response plan Tier I Qualified Facility SPCC Plan Template

6 112.1 General Applicability The SPCC Rule applies to a facility that meets the following criteria: Drills, produces, gathers, stores, processes, refines, transfers, distributes, uses, or consumes oil and oil products; and Is non-transportation-related; and Can reasonably be expected to discharge oil in quantities that may be harmful* into or upon the navigable waters of the U.S. or adjoining shorelines; and Meets either of the oil storage capacity thresholds Aboveground storage > 1,320 gallons(including everything 55 gal or bigger); or Completely buried storage > 42,000 gallons * A discharge of oil in quantities that may be harmful under means to cause a film or sheen upon or discoloration of the surface of the water or adjoining shorelines or cause a sludge or emulsion to be deposited beneath the surface of the water or upon adjoining shorelines. 6

7 Qualified Facilities If the facility total aboveground oil storage capacity is And, gallons or less And the facility has Qualified Facility NoApplicability individual aboveground oil Within three years prior to the Plan certification date, or since becoming subject to the SPCC rule if in operation for less than three years, the facility has not had: A single discharge of oil to navigable waters or adjoining shorelines exceeding 1,000 gallons, or Two discharges of oil to navigable waters or adjoining shorelines each exceeding 42 gallons within any 12-month period.1 containers greater than 5,000 gallons; Then the facility is a: Tier I Qualified Facility: Complete and self-certify Plan template (Appendix G to 40 CFR part 112) in lieu of a full PE-certified Plan. Tier II Qualified Facility: Prepare a self-certified Plan in Any individual aboveground oil accordance with all applicable container greater than 5,000 requirements of and gallons; subparts B or C of the rule, in lieu of a PE-certified Plan. 7

8 112.1(e) Prepare and Implement a SPCC Plan 40 CFR part 112 establishes requirements to prepare and implement SPCC Plans Designed to complement existing laws, regulations, rules, standards, policies, and procedures pertaining to safety standards, fire prevention, and pollution prevention rules Purpose: To develop a comprehensive Plan that minimizes the potential for oil discharges to navigable waters or adjoining shorelines Must address all relevant spill prevention, control, and countermeasures necessary at the facility 112.1(e) 8

9 112.2 Definitions: Facilities Facility- any mobile or fixed, onshore or offshore building, property, parcel, lease, structure, installation, equipment, pipe, or pipeline (other than a vessel or a public vessel) used in oil well drilling operations, oil production, oil refining, oil storage, oil gathering, oil processing, oil transfer, oil distribution, and oil waste treatment, or in which oil is used, as described in Appendix A to this part. The boundaries of a facility depend on several site-specific factors, including but not limited to, the ownership or operation of buildings, structures, and equipment on the same site and types of activity at the site. Contiguous or non-contiguous buildings, properties, parcels, leases, structures, installations, pipes, or pipelines under the ownership or operation of the same person may be considered separate facilities. Only this definition governs whether a facility is subject to this part. 9

10 112.2 Definitions: Facilities (continued) Onshore facility any facility of any kind located in, on, or under any land within the United States, other than submerged lands. Complex facility possessing a combination of transportation-related and non-transportation-related components that is subject to the jurisdiction of more than one Federal agency under section 311(j) of the CWA 10 Offshore facility any facility of any kind (other than a vessel or public vessel) located in, on, or under any of the navigable waters of the United States, and any facility of any kind that is subject to the jurisdiction of the United States and is located in, on, or under any other waters

11 112.2 Definitions: Facilities (continued) Production facility- all structures (including but not limited to wells, platforms, or storage facilities), piping (including but not limited to flow-lines or intra-facility gathering lines), or equipment (including but not limited to workover equipment, separation equipment, or auxiliary non-transportation-related equipment) used in the production, extraction, recovery, lifting, stabilization, separation or treating of oil (including condensate), or associated storage or measurement, and is located in an oil or gas field, at a facility. This definition governs whether such structures, piping, or equipment are subject to a specific section of this part. 11

12 112.2 Definitions (continued) Permanently Closed means any container or facility for which: (1)All liquid and sludge has been removed from each container and connecting lines (2)All connecting lines and piping have been disconnected from the container and blanked off, all valves (except for ventilation valves) have been closed and locked, and conspicuous signs have been posted on each container stating that it is a permanently closed container and noting the date of closure Oil and Water Mixtures Oil and water mixture containers are subject to the SPCC rule. A mixture of wastewater and oil is oil under the statutory and regulatory definition of the term (33 U.S.C. 1321(a)(1) and 40 CFR and 112.2). A discharge of wastewater containing oil to navigable waters or adjoining shorelines in a harmful quantity (40 CFR part 110) is prohibited (see July 17, 2002, 67 FR 47069). One example of an oil and water mixture is produced water. 12

13 EPA/USCG Jurisdiction at an MTR 33 CFR Marine transportation-related facility (MTR facility) means any onshore facility or segment of a complex regulated under section 311(j) of the Federal Water Pollution Control Act (FWPCA) by two or more Federal agencies, including piping and any structure used or intended to be used to transfer oil to or from a vessel, subject to regulation under this part and any deepwater port subject to regulation under part 150 of this chapter. For a facility or segment of a complex regulated by two or more Federal agencies under section 311(j) of the FWPCA, the MTR portion of the complex extends from the facility oil transfer system s connection with the vessel to the first valve inside the secondary containment surrounding tanks in the non-transportationrelated portion of the facility or, in the absence of secondary containment, to the valve or manifold adjacent to the tanks comprising the non-transportation-related portion of the facility, unless another location has otherwise been agreed to by the COTP and the appropriate Federal official. 13

14 112.3 Prepare and Implement a Plan The facility owner/ operator must prepare an SPCC Plan: In writing In accordance with and any other applicable sections of 40 CFR part

15 Plan Preparation and Implementation for Production Facilities A new oil production facility has six months after the start of operations to prepare and implement an SPCC Plan. Start of operations is indicated by the start of well fluid pumping, transfer via flow lines, separation, treatment or storage of crude oil, or other oil storage in capacities greater than the SPCC applicability threshold. The timeframe was chosen because oil production facilities are likely to stabilize within six months after the start of operations. Applicable only to oil production facilities, because of their uniquely variable and uncertain initial flow rates Does not apply to drilling or worker facilities/operations (b)(1) and (3)

16 Professional Engineer Certification A licensed PE must review and certify a Plan and all technical amendments (unless a Tier I or nonhybrid Tier II Plan) The certification does not relieve the owner/operator of their duty to prepare and fully implement a Plan PEs do not need to be licensed in the state in which the facility is located for Federal compliance State s may have laws that require a PE to be licensed in the state and may prohibit self certification of Tier I and Tier II plans PEs can be employees of the facility (d), 112.5(c)

17 PE Attestation In the certification, the PE attests that: He/she is familiar with the Rule requirements He/she or his/her agent visited and examined the facility The Plan has been prepared in accordance with good engineering practice, including the consideration of applicable industry standards, and with the requirements of 40 CFR part 112 IV. Procedures for required inspections and testing have been established V. The Plan is adequate for the facility VI. If applicable, for a produced water container subject to 112.9(c)(6), any procedure to minimize the amount of free-phase oil is designed to reduce the accumulation of free-phase oil and the procedures and frequency for required inspections, maintenance and testing have been established and are described in the Plan. I. II. III (d)(1)

18 Plan Location Maintain a complete copy of the Plan: At the facility if it is attended at least 4 hours per day At the nearest field office if the facility is attended for less than 4 hours per day Have the Plan available to the RA/delegated inspector for on-site review during normal working hours (Region 6 rarely does unannounced inspections, but needs to be available in case one occurs) (e)

19 112.4 Amendment of SPCC Plan by Regional Administrator Notify Regional Administrator Submit specific information to the RA if the facility discharged: More than 1,000 gallons of oil in a single discharge as described in 112.1(b) More than 42 gallons of oil in each of two discharges as described in 112.1(b) within any 12-month period The gallon amount (42 or 1,000) refers to the amount of oil that reaches navigable waters which is reportable under 40 CFR 110 No action necessary until one of the above triggering events Still required to report to NRC in accordance with 40 CFR part (a) and (b)

20 112.4 Amendment of SPCC Plan by Regional Administrator (continued) Submit information to RA within 60 days of becoming subject to this section Name, location, and description of facility Contact name Maximum storage or handling capacity and normal daily throughput Corrective action and countermeasures taken Cause of discharge Additional preventive measures taken Other information reasonably required Send copy to appropriate state agencies (a) and (c)

21 112.5 Amendment of SPCC Plan by Owners or Operators For changes in facility design, construction, operation, or maintenance that materially affect the potential for a discharge as described in 112.1(b) Commissioning and decommissioning containers Replacement, reconstruction, or movement of containers Reconstruction, replacement, or installation of piping systems Construction or demolition that might alter secondary containment structures Changes in product or service Revision of operating or maintenance procedures

22 112.5 Amendment of SPCC Plan by Owners or Operators Amend within 6 months; implement ASAP, but no later than 6 months after amendment State of Louisiana Requirement: LAC 33:IX.905.E Amendments of Plans by Owners/Operators. Owners or operators of facilities shall amend the plan for such facility whenever there is a modification in facility design, construction, storage capacity, operation or maintenance which renders the existing plan inadequate. The amendment shall be implemented prior to or concurrent with the facility modification

23 Plan Review Complete review and evaluation of Plan Once every 5 years from the date facility becomes subject to the Rule Only technical changes require a PE review and certification Amend Plan within 6 months to include more effective prevention and control technology Implement ASAP, but no later than 6 months of amendment **LAC 33:IX.905.F Operators of facilities shall review the plan every five years and shall amend the plan within 90 days of the review to include more effective prevention and control technology if such technology will significantly reduce the likelihood of a spill event and if such technology has been field proven at the time of the review (b) and (c)

24 Documenting Plan Review Must document Plan review and evaluation Sign statement at beginning or end of Plan or in a log or an appendix I have completed review and evaluation of the SPCC Plan for (name of facility) on (date), and will (will not) amend the Plan as a result. PE must certify any technical amendment to Plan (b) and (c)

25 112.7 General Requirements for SPCC Plans Plan Format Prepare in writing and according to good engineering practice Approval of management with authority to commit resources to fully implement the Plan For procedures, methods, and equipment that are not yet fully operational: Discuss in separate paragraphs Explain separately the details of installation and start- up

26 Alternate Plan Formats If a Plan does not follow the sequence specified in the Rule, an equivalent Plan may be prepared: example Acceptable to the Regional 112.7(a)(3) Section 4.1 Administrator Meets all applicable requirements in Rule Provide a detailed crossreference that shows the location of each of the SPCC requirements 112.7(a)(3)(i) Section (a)(3)(ii) Section (a)(3)(iii) Section (a)(3)(iv) Section (a)(3)(v) Section (a)(3)(vi) Section

27 Items to Address in the Plan Type of oil in each container and its storage capacity ii. Discharge prevention measures including procedures for routine handling of products iii. Discharge or drainage controls iv. Countermeasures for discharge discovery, response, and cleanup v. Methods of disposal of recovered materials vi. Contact list and phone numbers (including NRC) If no FRP, then: i. Information for reporting Organize portions of the Plan describing procedures for when a discharge occurs to make them readily available during emergency (a)(3)

28 Facility Diagram Describe in your plan the physical layout of your facility and include a facility diagram. Supplements facility description, which may include facility location, type, size, and proximity to navigable waters, etc. Includes completely buried tanks that are otherwise exempted from the Rule Provides enough detail to undertake prevention activities, perform inspections, and take response measures Includes intra-facility gathering lines that are otherwise exempted from the Rule ** ** Overlay diagrams showing different portions of the piping system may be used where the complexity of the piping systems would make a single diagram difficult to read. These diagrams must be available at the facility (explained in section of the Regional Inspectors Guidance Document) (a)(3)

29 Facility Diagram Required elements: Recommended elements: The location and contents of oil Secondary containment containers (>55 gallons) Completely buried tanks otherwise exempt Connecting piping Transfer stations Storm drain inlets and surface *** Requirements for the facility diagram are different between SPCC and FRPs. The differences will be discussed in the FRP Power Point 29 waters Direction of flow in the event of a discharge Legend scale and symbols Location of response kits and firefighting equipment Location of valves or drainage system controls Compass direction Topographical information and area maps 112.7(a)(3)

30 Facility Diagram Requirement Revision clarifies that the facility diagram must include all fixed (i.e., not mobile or portable) containers. For mobile or portable containers, the diagram must: Identify a storage area on the facility diagram (e.g., a drum storage area). Include a separate description of the containers in the storage area in the Plan, or reference facility inventories that can be updated by facility personnel. ** Provide an estimate of the potential number of containers, types of oil, and anticipated capacities ** All containers need to be listed including SPCC regulated process vessels and oil filled operational equipment (a)(3)

31 31

32 Volume and Content of Tanks and Containers TANK/CONTAINER VOLUME (gallons) CONTENTS Area A Raw Material Bulk Storage Tank Tank Tank Tank Tank Tank ,000 4,000 20,000 20,000 20,000 6,000 Product Product Product Product Product Product Tank 9 40,000 Product C -- Toluene Area B Finished Product Storage Tank 6 20,000 Product D Proprietary oil 20,000 Product D Proprietary oil Tank 7 Area C Electrical Equipment Transformer E1 Transformer E2 Area D Liquid Product Accumulation Tank Process Area Primary Reactor Distillation Direct Contact Cooling Stripping Pump/Tank Condenser Liquefier Underground Storage Tanks Tank 9 (otherwise exempt from SPCC requirements) Tank 10 (otherwise exempt from SPCC requirements) Tank , ,000 8,000 2,000 A A B B B B #2 fuel oil #2 fuel oil #6 fuel oil #6 fuel oil #6 fuel oil Kerosene Silicon-based dielectric fluid Silicon-based dielectric fluid Product D Proprietary oil Intermediate Intermediate Intermediate Intermediate Intermediate Intermediate Gasoline Gasoline Heating oil oil oil oil oil oil oil product product product product product product

33 Failure Analysis Where experience indicates reasonable potential for equipment failure Tank loading or unloading equipment Tank overflow, rupture, or leakage Any other equipment known to be a source of a discharge Predict for each type: Direction Rate of flow Total quantity of oil which could be discharged (b)

34 Recordkeeping Written procedures of tests and inspections Keep record of procedures and record of inspections/tests Signed by appropriate supervisor or inspector With SPCC Plan Period of three years Records of inspection/tests kept under usual and customary business practices suffice; e.g. electronic copies (e)

35 Personnel Training Train oil-handling personnel Operation/maintenance of prevention equipment Discharge procedure protocols Applicable pollution control laws, rules, and regulations General facility operations Contents of the facility SPCC Plan Designate person accountable for discharge prevention and who reports to facility mgmt (list an actual name) Schedule/conduct at least one briefing/year: Known discharges and failures, malfunctioning components, new precautionary measures (f)

36 Secondary Containment Onshore facilities require sized secondary containment that will hold the capacity of the largest tank plus freeboard (the EPA recommends using the 25 year 24 hour rain event for that area but this is not a mandated design requirement) Offshore facilities: The SPCC rule does not specify secondary containment sizing. For facilities employing a sump system, provide adequately sized sump and drains and make available a spare pump to remove liquid from the sump and assure that oil does not escape. Inspect/test sumps regularly. 36

37 Secondary Containment (continued) The SPCC plan needs to discuss the secondary containment set up for all areas that require containment at the facility. Plans are usually missing a discussion of the general containment options that are being implemented at the facility for areas such as transfer areas, piping and mobile portable containers. For facilities utilizing Active Measures to meet secondary containment, the plan needs to have a detailed discussion showing how these are being met *Figure 4-10: Sample calculation of appropriate general secondary containment capacity at a transfer area (c)

38 Loading Rack vs. Loading Area Loading Arm Sized secondary containment 38 for the largest single compartment of truck/railcar loading or unloading (no freeboard) Interlocking warning lights, physical barrier systems, warning signs, wheel chocks Lower-most drains and all outlets on tank cars/trucks inspected prior to filling/departure and if necessary, ensure that they are tightened, adjusted, or replaced to prevent liquid discharge while in transit. No loading arms General containment, i.e. spill kits, spill buckets or active measures (detailed explanation in Guidance Document 4.7.2)

39 Loading Rack vs. Loading Area Loading arms No Loading arms 39

40 112.8 SPCC Requirements for Bulk Storage Facilities 40

41 112.8 Facility Drainage Outlines specific requirements (in addition to general requirements in 112.7) for Bulk storage facilities regarding: Facility Drainage Restrain drainage from diked areas by valves (manually operated and not flapper type valves) to prevent discharge (pumps may be used to drain diked areas, but must be manually activated, 112.8(b)) 41 Water must be inspected for sheen before discharge Valves can only be opened under supervision Maintain drainage records (c)(3)(iv) Keep adequate records of such events, for example, any records required under permits issued in accordance with (j)(2) and (m)(3) 112.8(b)(1,2) & 112.8(c)(3)

42 Facility Drainage (continued) Undiked Drainage Requirements Design facility drainage systems from undiked areas with a potential for a discharge (such as where piping is located outside containments walls) to flow into ponds, lagoons or catchment basins. If facility is not designed as stated above, the facility must equip the final discharge of all ditches inside the facility with a diversion system that could, in the event of a discharge, retain oil in the facility (b)(3,4)

43 Bulk Storage Containers Container compatibility: Do not use a container for the storage of oil unless its material and construction are compatible with the material stored and the conditions of storage The containment structure or measure must be able to contain the entire capacity of the largest single container and sufficient freeboard to contain precipitation Must ensure that the diked areas are sufficiently impervious to contain discharged oil. **Drums and totes that are 55 gallons or larger must have secondary containment: 112.8(c)(11) (c)(1,2)

44 Sufficiently Impervious Guidance Document The determination that a facility's soil is sufficiently impervious must be made on a case-by-case basis by the certifying PE (or owner/operator, in the case of qualified facilities). The PE/owner/operator must base determinations of sufficiently impervious secondary containment design on good engineering practice and site-specific considerations and this must be documented in the Plan. The certification of the Plan s adequacy is the responsibility of the PE (or the owner or operator of a qualified facility) and a determination of sufficient imperviousness may be based strictly on geotechnical knowledge of soil classification and best engineering judgment 44

45 Sufficient Freeboard Design Standard EPA did not set a standard requirement for freeboard capacity (e.g., freeboard to contain precipitation from a 25-year, 24-hour storm event or 110% of storage tank capacity) The 25-year, 24-hour storm event was a preamble recommendation based on a RCRA requirement, and is not an SPCC requirement The proper method of design is a matter of good engineering practice The requirement is based on containment of oil and rainfall, not a percentage of the tank s size 45 The 110% of storage tank capacity rule-of-thumb may be a potentially acceptable design criterion in many situations, but in some cases it may not be

46 Sufficient Freeboard Capacity Determination Factors to consider Local precipitation conditions (rainfall and/or snowfall) Height of existing dike wall Size of tank/container Safety considerations Frequency of dike drainage and inspection Displacement due to other tanks and/or equipment in the containment area The certifying PE determines what is sufficient freeboard and should document this determination with supporting calculations in the SPCC Plan 46

47 Container Inspections Must be periodically visually inspected for deterioration or maintenance needs. Must be integrity tested on a regular schedule (per appropriate industry standard) Integrity Testing Requirements: Test or inspect each aboveground container for integrity on a regular schedule Provide appropriate qualifications for personnel performing tests Document the frequency and type of testing Comparison records of integrity testing are maintained Container supports and foundations regularly inspected Outside of containers frequently inspected Records of all inspections and tests are maintained (c)(6)

48 Example of Integrity Testing Info INSPECTION TYPE External Inspection API 653 (inservice) API 653 Ultrasonic Testing of the Shell (inservice) Internal Inspection API 653 (outof-service) FREQUENCY Lesser of 5 years OR 1/4 of the life of the shell Lesser of 15 years OR 1/2 the life of the shell Lesser of 10 years OR the life of the tank bottom INSPECTOR QUALIFICATION OR TRAINING API 653 Certified Inspector API 653 Certified Inspector DOCUMENTATION RECOMMENDED RECORD RETENTION API 653 Certified Report API 653 Certified Report Life of the Tank Life of the Tank Level II or Level III of ASNTSNT- TC - IA (See API 650 paragraph 6.3.2, 10 ed, Addendum 3) API 653 Certified Inspector API 653 Certified Report 48 ** SPCC rule requires that records be maintained for three years. Life of the Tank

49 Other SPCC Inspections Effluent treatment facilities observed frequently enough to detect possible system upsets Visible discharged which results in a loss of oil from the container are promptly corrected and oil removed 112.8(c)(9,10) Above ground valves, piping and appurtenances are inspected regularly to assess their general conditions Integrity and leak test conducted on buried piping at the time of installation, modification, construction, relocation or replacement 112.8(d)(4,5) 49

50 Bulk Storage Containers Each container is equipped with at least one of the following: High liquid level alarms High liquid level pump cutoff devices Direct audible signal communications Fast response system for determining liquid level Should regularly test liquid level sensing devices to ensure proper operations 112.8(c)(8) 50

51 SPCC Requirements Oil Production Requirements for Onshore Oil Production Facilities (excluding drilling and workover facilities) Requirements for Onshore Oil Drilling and Workover Facilities Requirements for Offshore Oil Drilling, Production and Workover Facilities 51

52 Onshore Production Definition and Timeframe A new oil production facility has six months after the start of operations to prepare and implement an SPCC Plan. Start of operations is indicated by the start of well fluid pumping, transfer via flowlines, separation, treatment or storage of crude oil, or other oil storage in capacities greater than the SPCC applicability threshold (b)

53 General Requirements Applicable to ALL Facilities Production facilities must meet general requirements under Except the security requirement ( 112.7(g)) 53

54 112.9 SPCC Requirements for Onshore Production Facilities General secondary containment requirement applies to the following examples: Christmas tree, wellhead, and pump jack stuffing box Oil-filled equipment (transformers, pumpjacks) Transfer areas Piping runs/racks, manifolds, etc. Flow and intra facility gathering lines Truck loading/unloading areas (not loading rack) No specific-sized volume requirement for the above Sizing based on most likely spill scenario, not container size 54

55 112.9 Facility Drainage Inspect diked areas prior to draining and in accordance with 112.8(c)(3) (ii)(iii) and (iv) Remove accumulated oil on the rainwater and return it to storage or dispose of it in legally approved method Oil field drainage systems 55 Inspect at regularly scheduled intervals field drainage systems (such as drainage ditches or road ditches), and oil traps, sumps, or skimmers for an accumulation of oil that may have resulted from any small discharge Promptly remove any accumulations of oil 112.9(b)(2)

56 112.9 Facility Drainage At tank batteries and separation and treating areas Close and seal at all times drains of dikes (or drains of equivalent measures) where there is a reasonable possibility of a discharge Prior to drainage, must inspect diked area and take action according to 112.8(c)(3) Keep bypass valve closed Inspect retained rainwater to ensure it will not be discharged in harmful quantities Supervise open bypass valve, and reseal after drainage is complete (b)(1)

57 Bulk Storage Containers at Production Facilities Container compatibility Do not use a container for the storage of oil unless its material and construction are compatible with the material stored and the conditions of storage (c)(1) 57 1

58 Bulk Storage Containers at Production Facilities The containment structure or measure must be able to contain the entire capacity of the largest single container and sufficient freeboard to contain precipitation If facility drainage is used as a method of secondary containment for bulk storage containers, drainage from undiked areas must be safely confined in a catchment basin or holding ponds and sized to contain the entire capacity of the largest single container and sufficient freeboard to contain precipitation (c)(2)

59 Bulk Storage Containers at Production Facilities Visual Inspection ( 112.9(c)(3)) Periodically and upon a regular schedule visually inspect each container for deterioration and maintenance needs Include the foundation and support of each container that is on or above the surface of the ground Guidance for Compliance: API 12R1 - Recommended Practice for Setting, Maintenance, Inspection, Operation, and Repair of Tanks in Production Service 59

60 Bulk Storage Containers (continued) Engineered according to good engineering practice to prevent discharges, Provide one of the following: The container capacity adequate to assure that a container will not overfill if a pumper/gauger is delayed in making regularly schedule rounds Overflow equalizing lines between containers so that a full container can overflow to an adjacent container Vacuum protection that is adequate to prevent container collapse during a pipeline run or transfers High level sensors to generate and transmit an alarm signal to the computer where the facility is subject to a computer production control system (c)(4)

61 Applicability of Rule to flow-through process vessels Specific sized secondary containment requirements and the inspection requirements of (c)(2) (3) apply. However, containment alternative available (see Guidance Section 4.8.1) and discussion in later slides 61

62 Flow-through Process Vessels Instead of sized secondary containment for flowthrough process vessels, an operator may, as an option, provide general containment and the following: Visually inspect and/or test on a periodic and regular schedule for leaks, corrosion, or other conditions that could lead to a discharge as described in 112.1(b) Take corrective action or repair flow-through process vessels and any associated components as indicated by regularly scheduled visual inspections, tests, or evidence of an oil discharge Promptly remove or initiate actions to stabilize and remediate any accumulations of oil discharges (c)(5)

63 Flowlines & Intra-facility Gathering Lines Required to have general secondary containment under 112.7(c) or alternate measures under 112.9(d)(3). Remember general secondary containment intended for most likely spill scenario Operators should be considering volume, rate, pressure of well fluids in lines 63

64 Compliance Alternative: Flowlines Secondary containment is often impracticable for flowlines and intra-facility gathering lines Amended Rule provides an optional alternative to general secondary containment Instead of secondary containment for flowlines and intrafacility gathering lines, amended Rule requires: Implementation of an oil spill contingency plan in accordance with 40 CFR part 109 Written commitment of manpower, equipment, and materials to control and remove any quantity of oil discharged that may be harmful No PE impracticability determination required Secondary containment may still be used instead (c) and 112.9(d)(3)

65 Flow and Intra-Facility Gathering Line Maintenance Program The maintenance program must address procedures to: 1. Ensure compatibility with the type of production fluids, their potential corrosivity, volume, and pressure, and other conditions expected in the operational environment 2. Visually inspect and/or test on a periodic and regular schedule for leaks, oil discharges, corrosion, or other conditions that could lead to a discharge as described in 112.1(b). For flowlines and intra-facility gathering lines that are not provided with secondary containment in accordance with 112.7(c), the frequency and type of testing must allow for the implementation of a contingency plan as described under 40 CFR part Take corrective action or make repairs as indicated by regularly scheduled visual inspections, tests, or evidence of a discharge 4. Promptly remove or initiate actions to stabilize and remediate any accumulations of oil discharges associated with flowlines, intra-facility 65 gathering lines, and associated appurtenances 112.9(d)(4)

66 Onshore Drilling and Workover Drilling Rig Workover or Completion Rig 66

67 112.3 Requirement for SPCC Plans Drilling, Production, and Workover Facilities, and Mobile Facilities Plan does not have to be amended or a new plan prepared each time the facility moves Mobile facilities such as these can have a general plan Plan is applicable only while the facility (e.g., drilling rig and all its components) are in a fixed, operating mode

68 General Requirements Really only 4 requirements under this section: Meet the general requirements for the Plan listed under 112.7, and the specific discharge prevention and containment procedures listed under this section (a)

69 Onshore Drilling and Workover Position or locate mobile drilling or workover equipment so as to prevent a discharge as in 112.1(b) 69 Workover or Completion Rig (b)

70 Onshore Drilling or Workover Equipment Required to provide catchment basins or diversion structures to intercept and contain discharges of fuel, crude oil, oily drilling fluids General Secondary Containment - No specific sizing requirement, and no freeboard requirement (c)

71 Onshore Drilling and Workover Install a Blow Out Prevention (BOP) assembly and well control system before drilling below any casing string or during workover operations (d)

72 Offshore Oil Drilling, Production and Workover Facilities 72

73 General Requirements Offshore production facilities are subject to requirements under Tailored specifically for the offshore operating environment. Meet the general requirements for the Plan listed under 112.7, and the specific discharge prevention and containment procedures listed under this section (a)

74 Offshore Oil Drilling, Production and Workover Facilities Not enough room to contain worst case scenario spill Rather, oil drainage equipment is used to control small oil discharges Direct facility drains toward a central location with a sump to prevent a discharge. Sump system should have adequately sized equipment and have a spare pump available or a redundant automatic sump pump installed. Regularly scheduled preventative maintenance inspection and testing program to ensure reliable operation of the liquid removal system and pump start-up device (b),(c)

75 Offshore Separators, Treaters If separators and treaters have a dump valve and have a high risk of pollution, facility must be specially equipped to prevent the discharge of oil (Production flow-thru process equipment used at offshore oil production facilities are not eligible for the alternate compliance option in 112.9(c)(5)) Atmospheric storage containers or surge containers should be equipped with high liquid level alarms or flow controls Pressure containers equipped with high and low pressure sensing devices that activate an alarm or flow control (d),(e)(f)

76 Offshore Separators, Treaters, ASTs Equip containers with suitable corrosion protection Galvanized steel tanks (f),(g)

77 Offshore Written Procedures, Testing Prepare and maintain at the facility a written procedure For inspecting and testing pollution prevention equipment and systems Conduct testing and inspection of the pollution prevention equipment and systems Periodic basis Use simulated discharges for testing and inspecting Describe in records Surface and subsurface well shut-in valves and devices (h), (i), (j)

78 Offshore BOP Stack Install a BOP assembly and well control system during workover operations and before drilling below any casing string The BOP assembly and well control system must be capable of controlling any well-head pressure that may be encountered while the BOP assembly and well control system are on the 78 well (k)

79 Offshore Flowlines Flowlines should contain High Pressure sensing device Shut-in valve at the wellhead/or Provide a pressure relief system for flowlines All manifolds should be equipped with check valves on individual flowlines Protect piping to the facility from corrosion Protective coatings Cathodic protection (l), (m), (n)

80 Offshore Submarine Piping Protect and maintain submarine piping to the facility against environmental stresses and other activities. Inspect or test piping periodically and according to a schedule Document and keep a record of the inspections and tests at the facility **State of Louisiana Requirement: Per LDEQ, in the state of Louisiana the facility must pressure test their flow lines annually (o),(p)

81 Double Hulled Barges The SPCC plan should include a detailed description of the inspection protocols for the barge: The make up of the barge and its different compartments Does the interstitial space contain ballast water or not What should the inspector be looking for 81 81

82 Hybrid Facilities Facilities that fall under a combination of 112.8, and/or must have a SPCC plan that is written with the requirements of each section that governs the facility. * The EPAs newest Offshore Inspection form has all three areas in the form 82 82

83 SPCC Inspection Process Facility Inspection Targeting History of non-compliance Spill history of an geographic area Spill Responses ** Distance to navigable waters Proximity to sensitive ecosystems Citizen Complaints ** State/Federal referrals ** ** Regional priorities 83

84 SPCC Inspection Process (continued) Type of Inspections Unannounced Spill Responses Citizen Complaints Repeat Violators Announced Contact via phone/ to schedule inspection (Region 6 will normally make notifications around 2 weeks prior to inspection accompanied with Official NOI and copy of inspections documents) Coordination of logistics with facility personnel (EPA provides their own transportation). 84

85 SPCC Inspection Process (continued) Day of Inspection: Review of SPCC plan (if not provided in advance) Review of all required records Detailed walkthrough of facility Debrief (No inspection paperwork left at facility other than the NOI)) After Inspection: Inspector will type up all findings from inspection on the SPCC Checklists The checklist will be forwarded to the Oil Team Leader for review and signature Oil Team Leader will final report to facility Facility will provide documentation for correcting all discrepancies to the EPA Inspector within 30 Days of the Inspection 85

86 Best Resource document for SPCC Questions: 86

87 87 For more information visit or contact Chris Perry Tom McKay (214) Bryant Smalley (Team Lead) (214)