Number range CHAPTER **Disclaimer - Appendix E**

The sample Spill Prevention, Control and Countermeasure (SPCC) Plan in
Appendix E is intended to provide examples and illustrations of how a
production facility could address a variety of scenarios in its SPCC
Plan. The "facility" is not an actual facility, nor does it represent
any actual facility or company. Rather, EPA is providing illustrative
examples of the type and amount of information that is appropriate SPCC
Plan language for these hypothetical situations.

Because the SPCC rule is designed to give each facility owner/operator
the flexibility to tailor the facility's SPCC Plan to the facility's
circumstances, this sample SPCC Plan is not a template to be adopted by
a facility; doing so does not mean that the facility will be in
compliance with the SPCC rule requirements. Nor is the sample plan a
template that must be followed in order for the facility to be
considered in compliance with the SPCC rule.

**[Spill Prevention, Control, and Countermeasure Plan]{.smallcaps}**

***Clearwater Oil Company***

**Big Bear Lease No. 2 Production Facility**

5800 Route 417

Madison, St. Anthony Parish, Louisiana 73506

![](media/image1.wmf)

Prepared by

Montgomery Engineering, Inc.

November 23, 2003

**Table of Contents**

+--------------------------------------------------------------+-------+
| Number range CHAPTER                                         | Page  |
+==============================================================+=======+
| Cross-Reference with SPCC Rule                               | 4     |
+--------------------------------------------------------------+-------+
| Introduction                                                 | 5     |
+--------------------------------------------------------------+-------+
| Management Approval                                          | 6     |
+--------------------------------------------------------------+-------+
| Professional Engineer Certification                          | 6     |
+--------------------------------------------------------------+-------+
| Plan Review                                                  | 7     |
+--------------------------------------------------------------+-------+
| Location of SPCC Plan                                        | 7     |
+--------------------------------------------------------------+-------+
| Certification of Substantial Harm Determination              | 8     |
+--------------------------------------------------------------+-------+
| Part I - General Facility Information                        |       |
+--------------------------------------------------------------+-------+
| 1.1 Company Information                                      | 9     |
+--------------------------------------------------------------+-------+
| 1.2 Contact Information                                      | 9     |
+--------------------------------------------------------------+-------+
| 1.3 Facility Layout Diagram                                  | 10    |
+--------------------------------------------------------------+-------+
| 1.4 Facility Location and Operations                         | 10    |
+--------------------------------------------------------------+-------+
| 1.5 Oil Storage and Handling                                 | 11    |
+--------------------------------------------------------------+-------+
| 1.6 Proximity to Navigable Waters                            | 12    |
+--------------------------------------------------------------+-------+
| 1.7 Conformance with Applicable State and Local Requirements | 12    |
+--------------------------------------------------------------+-------+
| Part II - Spill Response and Reporting                       |       |
+--------------------------------------------------------------+-------+
| 2.1 Discharge Discovery and Reporting                        | 13    |
+--------------------------------------------------------------+-------+
| 2.2 Spill Response Materials                                 | 14    |
+--------------------------------------------------------------+-------+
| 2.3 Spill Mitigation Procedures                              | 15    |
+--------------------------------------------------------------+-------+
| 2.4 Disposal Plan                                            | 16    |
+--------------------------------------------------------------+-------+
| Part III - Spill Prevention, Control, and Countermeasure     |       |
| Provisions                                                   |       |
+--------------------------------------------------------------+-------+
| 3.1 Potential Discharge Volume and Direction of Flow         | 18    |
+--------------------------------------------------------------+-------+
| 3.2 Containment and Diversionary Structures                  | 19    |
+--------------------------------------------------------------+-------+
| 3.3 Other Spill Prevention Measures                          | 22    |
+--------------------------------------------------------------+-------+
| 3.4 Inspections, Tests, and Records                          | 23    |
+--------------------------------------------------------------+-------+
| 3.5 Personnel, Training, and Discharge Prevention Procedures | 27    |
+--------------------------------------------------------------+-------+
|                                                              |       |
+--------------------------------------------------------------+-------+
| Appendix A - Facility Diagrams                               | 30    |
+--------------------------------------------------------------+-------+
| Appendix B - Tank Truck Loading Procedure                    | 32    |
+--------------------------------------------------------------+-------+
| Appendix C - Monthly Inspection Checklist                    | 33    |
+--------------------------------------------------------------+-------+
| Appendix D - Record of Dike Drainage                         | 34    |
+--------------------------------------------------------------+-------+
| Appendix E - Discharge Prevention Briefing Log               | 35    |
+--------------------------------------------------------------+-------+
| Appendix F - Discharge Notification Procedures               | 36    |
+--------------------------------------------------------------+-------+
| Appendix G - Equipment Shut-off Procedures                   | 41    |
+--------------------------------------------------------------+-------+
| Appendix H - Written Commitment of Manpower, Equipment, and  | 42    |
| Materials                                                    |       |
+--------------------------------------------------------------+-------+
| Appendix I - Oil Spill Contingency Plan                      | 43    |
+--------------------------------------------------------------+-------+
| # List of Tables                                             |       |
+--------------------------------------------------------------+-------+
| Table 0-1: Record of plan review and changes                 | 7     |
+--------------------------------------------------------------+-------+
| Table 1-1: Facility contact information                      | 10    |
+--------------------------------------------------------------+-------+
| Table 1-2: Characteristics of oil containers                 | 11    |
+--------------------------------------------------------------+-------+
| Table 3-1: Potential discharge volume and direction of flow  | 18    |
+--------------------------------------------------------------+-------+
| Table 3-2: Berm capacity calculations                        | 21    |
+--------------------------------------------------------------+-------+
| Table 3-3: Scope of daily examinations                       | 24    |
+--------------------------------------------------------------+-------+
| Table 3-4: Scope of monthly inspections                      | 25    |
+--------------------------------------------------------------+-------+
| Table 3-5: Schedule of periodic condition inspection of bulk | 26    |
| storage containers                                           |       |
+--------------------------------------------------------------+-------+
| Table 3-6: Components of flowline maintenance program        | 27    |
+--------------------------------------------------------------+-------+
|                                                              |       |
+--------------------------------------------------------------+-------+
| [List of Figures]{.underline}                                |       |
+--------------------------------------------------------------+-------+
| Figure A-1: Site plan.                                       | 30    |
+--------------------------------------------------------------+-------+
| Figure A-2: Production facility diagram.                     | 31    |
+--------------------------------------------------------------+-------+

**Cross-Reference with SPCC Rule**

+---------+------------------------------------------------+----------+
| Number  | **Plan Section**                               | **P      |
| range   |                                                | age(s)** |
| C       |                                                |          |
| HAPTER* |                                                |          |
| *Provis |                                                |          |
| ion\*** |                                                |          |
+=========+================================================+==========+
| 1       | Professional Engineer Certification            | 6        |
| 12.3(d) |                                                |          |
+---------+------------------------------------------------+----------+
| 1       | Location of SPCC Plan                          | 7        |
| 12.3(e) |                                                |          |
+---------+------------------------------------------------+----------+
| 112.5   | Plan Review                                    | 7        |
+---------+------------------------------------------------+----------+
| 112.7   | Management Approval                            | 6        |
+---------+------------------------------------------------+----------+
| 112.7   | Cross-Reference with SPCC Rule                 | 4        |
+---------+------------------------------------------------+----------+
| 112.    | Part I - General Information and Facility      | 9-12     |
| 7(a)(3) | Diagram                                        |          |
|         |                                                | Appendix |
|         | Appendix A: Facility Diagrams                  | A        |
+---------+------------------------------------------------+----------+
| 112.4   | 2.1 Discharge Discovery and Reporting          | 13-15    |
| and     |                                                |          |
| 112.    | Appendix F: Discharge Notification             | Appendix |
| 7(a)(4) |                                                | F        |
+---------+------------------------------------------------+----------+
| 112.    | 2.2 Spill Mitigation Procedures                | 15-16    |
| 7(a)(5) |                                                |          |
|         | Appendix I: Oil Spill Contingency Plan         | Appendix |
|         |                                                | I        |
+---------+------------------------------------------------+----------+
| 1       | 3.1 Potential Discharge Volume and Direction   | 18-19    |
| 12.7(b) | of Flow                                        |          |
+---------+------------------------------------------------+----------+
| 1       | 3.2 Containment and Diversionary Structures    | 19-21    |
| 12.7(c) |                                                |          |
+---------+------------------------------------------------+----------+
| 1       | 3.2.3 Practicability of Secondary Containment  | 21       |
| 12.7(d) |                                                |          |
|         | Appendix H: Written Commitment of manpower,    | Appendix |
|         | equipment, and materials                       | H        |
|         |                                                |          |
|         | Appendix I: Oil Spill Contingency Plan         | Appendix |
|         |                                                | I        |
+---------+------------------------------------------------+----------+
| 1       | 3.4 Inspections, Tests, and Records            | 23-26    |
| 12.7(e) |                                                |          |
|         | Appendix C: Facility Inspection Checklists     | Appendix |
|         |                                                | C        |
+---------+------------------------------------------------+----------+
| 1       | 3.5 Personnel, Training, and Discharge         | 27-29    |
| 12.7(f) | Prevention Procedures                          |          |
|         |                                                | Appendix |
|         | Appendix E: Discharge Prevention Briefing Log  | E        |
+---------+------------------------------------------------+----------+
| 1       | Security -- N/A (does not apply to production  | N/A      |
| 12.7(g) | facilities)                                    |          |
+---------+------------------------------------------------+----------+
| 1       | Loading/Unloading Rack -- N/A (no rack present | N/A      |
| 12.7(h) | at this facility)                              |          |
+---------+------------------------------------------------+----------+
| 1       | Brittle Fracture Evaluation -- N/A (no         | 26       |
| 12.7(i) | field-erected aboveground tank at this         |          |
|         | facility)                                      |          |
+---------+------------------------------------------------+----------+
| 1       | 1.7 Conformance with Applicable State and      | 12       |
| 12.7(j) | Local Requirements                             |          |
+---------+------------------------------------------------+----------+
| 1       | 3.2.1 Oil Production Facility Drainage         | 20       |
| 12.9(b) |                                                |          |
|         | Appendix D: Record of Dike Drainage            | Appendix |
|         |                                                | D        |
+---------+------------------------------------------------+----------+
| 112.    | 1.5.1 Production Equipment                     | 11       |
| 9(c)(1) |                                                |          |
+---------+------------------------------------------------+----------+
| 112.    | 3.2.2 Secondary Containment for Bulk Storage   | 19-21    |
| 9(c)(2) | Containers                                     |          |
+---------+------------------------------------------------+----------+
| 112.    | 3.4 Inspections, Tests, and Records            | 23-26    |
| 9(c)(3) |                                                |          |
|         | Appendix C: Monthly Inspection Checklist       | Appendix |
|         |                                                | C        |
+---------+------------------------------------------------+----------+
| 112.    | 3.3.1 Bulk Storage Containers Overflow         | 22       |
| 9(c)(4) | Prevention                                     |          |
+---------+------------------------------------------------+----------+
| 112.    | 3.3.2 Transfer Operations and Saltwater        | 22-23    |
| 9(d)(1) | Disposal System                                |          |
+---------+------------------------------------------------+----------+
| 112.    | 3.3.2 Transfer Operations and Saltwater        | 22-23    |
| 9(d)(2) | Disposal System                                |          |
+---------+------------------------------------------------+----------+
| 112.    | 3.4.5 Flowline Maintenance Program             | 26-27    |
| 9(d)(3) |                                                |          |
+---------+------------------------------------------------+----------+

\* Only relevant rule provisions are indicated. For a complete list of
SPCC requirements, refer to the full text of 40 CFR part 112.

**Introduction**

The purpose of this Spill Prevention Control and Countermeasure (SPCC)
Plan is to describe measures implemented by Clearwater to prevent oil
discharges from occurring, and to prepare Clearwater to respond in a
safe, effective, and timely manner to mitigate the impacts of a
discharge from the Big Bear Lease No. 2 production facility. This SPCC
Plan has been prepared and implemented in accordance with the SPCC
requirements contained in 40 CFR part 112.

In addition to fulfilling requirements of 40 CFR part 112, this SPCC
Plan is used as a reference for oil storage information and testing
records, as a tool to communicate practices on preventing and responding
to discharges with Clearwater employees and contractors, as a guide on
facility inspections, and as a resource during emergency response.

**Management Approval**

**40 CFR 112.7**

Clearwater Oil Company ("Clearwater") is committed to maintaining the
highest standards for preventing discharges of oil to navigable waters
and the environment through the implementation of this SPCC Plan. This
SPCC Plan has the full approval of Clearwater management. Clearwater's
management has committed the necessary resources to implement the
measures described in this Plan.

Bill Laurier is the Designated Person Accountable for Oil Spill
Prevention at this Clearwater facility and has the authority to commit
the necessary resources to implement the Plan as described.

Authorized Facility Representative: Bill Laurier

Signature: Bill Laurier

Title: Field Operations Manager

Date: November 23, 2003

![](media/image2.wmf){width="1.3597222222222223in"
height="1.3597222222222223in"}

**Professional Engineer Certification**

**40 CFR 112.3(d)**

The undersigned Registered Professional Engineer is familiar with the
requirements of Part 112 of Title 40 of the *Code of Federal
Regulations* (40 CFR part 112) and has visited and examined the
facility, or has supervised examination of the facility by appropriately
qualified personnel. The undersigned Registered Professional Engineer
attests that this Spill Prevention, Control, and Countermeasure Plan has
been prepared in accordance with good engineering practice, including
consideration of applicable industry standards and the requirements of
40 CFR part 112; that procedures for required inspections and testing
have been established; and that this Plan is adequate for the facility.
\[112.3(d)\]

This certification in no way relieves the owner or operator of the
facility of his/her duty to prepare and fully implement this SPCC Plan
in accordance with the requirements of 40 CFR part 112.

[Peter E. Trudeau]{.underline} *[November 23, 2003]{.underline}*

Signature Date

[Peter E. Trudeau, P.E.]{.underline}

Name of Professional Engineer

*[90535055]{.underline} [Louisiana ]{.underline}*

Registration Number Issuing State

**Plan Review**

**40 CFR 112.5**

In accordance with 40 CFR 112.5, Clearwater Oil periodically reviews and
evaluates this SPCC Plan for any change in the facility design,
construction, operation, or maintenance that materially affects the
facility's potential for an oil discharge. Clearwater reviews this SPCC
Plan at least once every five years. Revisions to the Plan, if any are
needed, are made within six months of this five-year review. Clearwater
will implement any amendment as soon as possible, but not later than six
months following preparation of any amendment. A registered PE certifies
any technical amendment to the Plan, as described above, in accordance
with 40 CFR 112.3(d).

Scheduled five-year reviews and Plan amendments are recorded in Table
0-1. This log must be completed even if no amendment is made to the
Plan. Unless a technical or administrative change prompts an earlier
review, the next scheduled review of this Plan must occur by *November
23, 2008.*

**Table 0-1**: Record of Plan Review and Changes

+--------+----------+--------------+----------+-----------------------+
| **     | **Au     | **Review     | **PE     | **Summary of          |
| Date** | thorized | Type**       | Certifi  | Changes**             |
|        | Indi     |              | cation** |                       |
|        | vidual** |              |          |                       |
+--------+----------+--------------+----------+-----------------------+
| 11     | Bill     | Initial Plan | Yes      | N/A                   |
| /23/03 | Laurier  |              |          |                       |
+--------+----------+--------------+----------+-----------------------+
| 04     | Bill     | Off-cycle    | No       | Changed telephone     |
| /14/04 | Laurier  | review       |          | number for Field      |
|        |          |              |          | Operations Manager.   |
|        |          |              |          |                       |
|        |          |              |          | Corrected page        |
|        |          |              |          | numbers in Table of   |
|        |          |              |          | Content.              |
|        |          |              |          |                       |
|        |          |              |          | Non-technical         |
|        |          |              |          | amendments, no PE     |
|        |          |              |          | certification is      |
|        |          |              |          | needed.               |
+--------+----------+--------------+----------+-----------------------+
|        |          |              |          |                       |
+--------+----------+--------------+----------+-----------------------+
|        |          |              |          |                       |
+--------+----------+--------------+----------+-----------------------+
|        |          |              |          |                       |
+--------+----------+--------------+----------+-----------------------+

**Location of SPCC Plan**

**40 CFR 112.3(e)**

In accordance with 40 CFR 112.3(e), and because the facility is normally
unmanned, a complete copy of this SPCC is maintained at the field office
closest to the facility, which is located approximately 25 miles from
the facility at 2451 Mountain Drive, Ridgeview, LA. Additional copies
are available at the Clearwater Oil Company management office, located
at 13000 Main Street, Suite 400, Houston, TX.

**Certification of Substantial Harm Determination**

**40 CFR 112.20(e), 40 CFR 112.20(f)(1)**

**Facility Name: Clearwater Oil Company, Big Bear Lease No. 2**

1\. Does the facility transfer oil over water to or from vessels and
does the facility have a total oil storage capacity greater than or
equal to 42,000 gallons?

Yes G No O

2\. Does the facility have a total oil storage capacity greater than or
equal to 1 million gallons and does the facility lack secondary
containment that is sufficiently large to contain the capacity of the
largest aboveground oil storage tank plus sufficient freeboard to allow
for precipitation within any aboveground storage tank area?

Yes G No O

3\. Does the facility have a total oil storage capacity greater than or
equal to 1 million gallons and is the facility located at a distance (as
calculated using the appropriate formula) such that a discharge from the
facility could cause injury to fish and wildlife and sensitive
environments?

Yes G No O

4\. Does the facility have a total oil storage capacity greater than or
equal to 1 million gallons and is the facility located at a distance (as
calculated using the appropriate formula) such that a discharge from the
facility would shut down a public drinking water intake?

Yes G No O

5\. Does the facility have a total oil storage capacity greater than or
equal to 1 million gallons and has the facility experienced a reportable
oil spill in an amount greater than or equal to 10,000 gallons within
the last 5 years?

Yes G No O

**Certification**

I certify under penalty of law that I have personally examined and am
familiar with the information submitted in this document, and that based
on my inquiry of those individuals responsible for obtaining this
information, I believe that the submitted information is true, accurate,
and complete.

Bill Laurier *Field Operations Manager*

Signature Title

*Bill Laurier* *November 23, 2003*

Name (type or print) Date

**PART I - GENERAL FACILITY INFORMATION**

**40 CFR 112.7(a)(3)**

**1.1 Company Information**

**1.2 Contact Information**

The designated person accountable for overall oil spill prevention and
response at the facility, also referred to as the facility's "Response
Coordinator" (RC), is the Field Operations Manager, Bill Laurier.
24-hour contact information is provided in Table 1-1.

Personnel from Avonlea Services Inc. ("Avonlea") provide operations
(pumper/gauger) support activities to Clearwater field personnel,
including performing informal daily examinations of the facility
equipment, as described in Section 3.4 of this SPCC Plan. Avonlea
personnel regularly visit the facility to record production levels and
perform other maintenance/inspection activities as requested by the
Clearwater Field Operations Manager. Key contacts for Avonlea are
included in Table 1-1.

**Table 1-1**: Facility contact information

+--------------+----------------+------------------+-------------------+
| **Name**     | **Title**      | **Telephone**    | **Address**       |
+--------------+----------------+------------------+-------------------+
| Lester       | Vice-President | (555)-289-4500   | 13000 Main        |
| Pearson      | of Operations  |                  | Street, Suite 400 |
|              |                |                  |                   |
|              | Clearwater Oil |                  | Houston, TX 77077 |
|              | Co.            |                  |                   |
+--------------+----------------+------------------+-------------------+
| Carol        | Regional       | \(405\) 831-6320 | 2451 Mountain     |
| Campbell     | Director of    | (office)         | Drive             |
|              | Operations     |                  |                   |
|              |                | \(405\) 831-2262 | Ridgeview, LA     |
|              | Clearwater Oil | (cell)           | 70180             |
|              | Co.            |                  |                   |
+--------------+----------------+------------------+-------------------+
| Bill Laurier | Field          | \(405\) 831-6322 | 2451 Mountain     |
|              | Operations     | (office)         | Drive             |
|              | Manager        |                  |                   |
|              |                | \(405\) 829-4051 | Ridgeview, LA     |
|              | Clearwater Oil | (cell)           | 70180             |
|              | Co.            |                  |                   |
+--------------+----------------+------------------+-------------------+
| Joe Clark    | Field          | \(406\) 545-2285 | 786 Cherry Creek  |
|              | Supervisor     | (office)         | Road              |
|              |                |                  |                   |
|              | Avonlea        | \(406\) 549-9087 | Avonlea, LA 70180 |
|              | Services, Inc. | (cell)           |                   |
+--------------+----------------+------------------+-------------------+
| William      | Pumper         | \(406\) 549-9087 | 786 Cherry Creek  |
| Mackenzie    |                | (cell)           | Road              |
|              | Avonlea        |                  |                   |
|              | Services, Inc. |                  | Avonlea, LA 70180 |
+--------------+----------------+------------------+-------------------+

**1.3 Facility Layout Diagram**

Appendix A, at the end of this Plan, shows a general site plan for the
facility. The site plan shows the site topography and the location of
the facility relative to waterways, roads, and inhabited areas. Appendix
A also includes a detailed facility diagram that shows the wells,
flowlines, tank battery, and transfer areas for the facility. The
diagram shows the location, capacity, and contents of all oil storage
containers greater than 55 gallons in capacity.

**1.4 Facility Location and Operations**

Clearwater owns and operates the Big Bear Lease No. 2 production
facility, which is located approximately six miles north of Madison, St.
Anthony Parish, Louisiana (see Figure A-1 in Appendix A). The site is
accessed through a private dirt/gravel road off Route 417.

As illustrated in Figure A-2 in Appendix A, the facility is comprised of
five main areas: Well A, Well B, the saltwater disposal well, flowlines,
and a tank battery. The tank battery includes three 400-barrel (bbl) oil
storage tanks, one 500-bbl produced water tank, one 500-bbl gun barrel,
and associated flowlines and piping.

The production facility is generally unmanned. Clearwater\'s field
office is located 25 miles from the site, at 2541 Mountain Drive,
Ridgeview, Louisiana. Field operations personnel from Clearwater, or
pumpers acting as contractors to Clearwater visit the facility daily
(2-4 hours each day) to record production rates and ensure the proper
functioning of wellhead equipment and pumpjacks, storage tanks,
flowlines, and separation vessels. This includes performing equipment
inspections and maintenance as needed.

The facility produces an average of 30 bbl (1,260 gallons) of crude oil
(approximately 40 API gravity) and 140 bbl (5,880 gallons) of produced
water each day. The produced water tank contains an oil/produced water
mixture. It is subject to 40 CFR part 112 and is covered by this SPCC
Plan.

**1.5 Oil Storage and Handling**

**1.5.1 Production Equipment**

Oil storage at the facility consists of one (1) 500-bbl gun barrel,
three (3) 400-bbl aboveground storage tanks, one (1) 500-bbl produced
water tank, and associated piping, as summarized in Table 1-2. The total
oil capacity at this facility is 2,200 bbl (92,400 gallons).

All oil storage tanks are shop-built and meet the American Petroleum
Institute (API) tank construction standard. Their design and
construction are compatible with the oil they contain and the
temperature and pressure conditions of storage. Tanks storing crude or
produced oil (#1 through #4) are constructed of welded steel following
API-12F *Shop Welded Tanks for Storage of Production Liquids*
specifications. Steel tanks are coated to minimize corrosion. Tank
holding produced water (#5) constructed of fiberglass following API-12P
*Fiberglass Reinforced Plastic Tanks* specifications.

Other production equipment present at the facility include the pumpjacks
at each well and water pumps for transfer of saltwater to the injection
well. These store a minimal amount of lubricating oil (less than 55
gallons). Lubricating oil and other substances, such as solvents and
chemicals for downhole treatment, are also stored at the facility, but
in quantities below the 55-gallon threshold for SPCC applicability.
Table 1-2 lists all oil containers present at the facility with capacity
of 55 gallons or more.

**Table 1-2**: Characteristics of oil containers

  -------- --------------------------- ------------------ ----------- ------------- -------------
  **ID**   **Type**                    **Construction**   **Primary   **Capacity    **Capacity
                                                          Content**   (barrels)**   (gallons)**

  #1       Gun barrel                  Steel              Oil         500           21,000

  #2       AST                         Steel              Oil         400           16,800

  #3       AST                         Steel              Oil         400           16,800

  #4       AST                         Steel              Oil         400           16,800

  #5       AST                         Fiberglass         Produced    500           21,000
                                                          water and                 
                                                          oil mixture               

                                                          TOTAL       2,200         92,400
  -------- --------------------------- ------------------ ----------- ------------- -------------

**1.5.2 Transfer Activities**

Wells A and B produce crude oil, produced water (saltwater), and small
amounts of natural gas. The oil and water are produced through the
tubing, while the natural gas is produced through the casing. Well
liquids are then routed via 2-inch steel flowlines to the gun barrel
tank for separation, while the gas is sent to a flare. Produced
saltwater is routed from the gun barrel to the 500-bbl saltwater storage
tank first, then is pumped through flowlines to the saltwater disposal
well where it is injected. The disposal well is located approximately
2,000 ft to the west of the tank battery. The crude oil is sent to the
three 400-bbl (16,800-gallon) oil storage tanks.

Crude oil from the lease is purchased by Clearwater's crude oil
purchaser and transported from the facility by the purchaser's tanker
truck. Although daily well production rates may vary, enough crude is
produced and stored for approximately one 180-bbl (7,560-gallon) load of
oil to be picked up weekly by the transporter. The largest tanker truck
visiting the facility has a total capacity of 210 bbl (8,820 gallons).
Tanker trucks come to the facility only to transfer crude oil and do not
remain at the facility. All transfer operations are attended by the
trucker or by field operations personnel and meet the minimum
requirements of the U.S. Department of Transportation Hazardous
Materials Regulations. Appendix B to this Plan summarizes the Tank Truck
Loading Procedure at this facility.

Produced saltwater is pumped via transfer pumps from the saltwater tank
to the saltwater disposal well, located approximately 2,000 feet west of
the facility, by 2-inch PVC flowlines (FLSW). The disposal well meets
all requirements of the Underground Injection Control (UIC) program (40
CFR parts 144-148).

**1.6 Proximity to Navigable Waters**

The facility is located within the Mines River watershed, approximately
half a mile to the west of Big Bear Creek, and six miles North of the
Mines River. The wells and tank battery are situated on relatively level
ground that slopes in a general southeastern direction. The site plan in
Figure A-1 in Appendix A shows the location of the facility relative to
nearby waterways. The facility diagram included in Figure A-2 in
Appendix A indicates the general direction of drainage. In the event of
an uncontrolled discharge from the wells, flowlines, or the tank battery
areas, oil would follow the natural topography of the site and flow into
Big Bear Creek. Big Bear Creek meets with the Mines River to the south
just before the town of Madison. The River then flows in a general
easterly direction following Route 101.

**1.7 Conformance with Applicable State and Local Requirements
\[112.7(j)\]**

The SPCC regulation at 40 CFR part 112 is more stringent than
requirements from the state of Louisiana for this type of facility. This
SPCC Plan was written to conform with 40 CFR part 112 requirements. The
facility thereby conforms with general requirements for oil pollution
facilities in Louisiana. All discharge notifications are made in
compliance with local, state, and federal requirements.

**PART II. SPILL RESPONSE AND REPORTING**

**40 CFR 112.7**

**2.1 Discharge Discovery and Reporting \[112.7(a)(3)\]**

Several individuals and organizations must be contacted in the event of
an oil discharge. The Field Operations Manager is responsible for
ensuring that all required discharge notifications have been made. All
discharges should be reported to the Field Operations Manager. The
summary table included in Appendix F to this SPCC Plan provides a list
of agencies to be contacted under different circumstances. Discharges
would typically be discovered during the inspections conducted at the
facility in accordance with procedures set forth in Section 3.4.1 of
this SPCC Plan, Table 3-3 and Table 3-4, and on the checklist of
Appendix C. The Form included in Appendix F of this Plan summarizes the
information that must be provided when reporting a discharge, including
contact lists and phone numbers.

**2.1.1 Verbal Notification Requirements (Local, State, and Federal (40
CFR part 110))**

Any unauthorized discharge into air, land or water must be reported
immediately to the State Police and the Emergency Planning Commission as
soon as the discharge is detected.

For any discharge that reaches navigable waters, or threatens to reach
navigable waters, *immediate* notification must be made to the National
Response Center Hotline (800-424-8802) and to the Environmental
Protection Agency.

In the event of a discharge that threatens to result in an emergency
condition, facility field personnel must verbally notify the Louisiana
Emergency Hazardous Materials Hotline (225-925-6595) immediately, and in
no case later than *within one (1) hour* of the discovery of the
discharge. An emergency condition is any condition that could reasonably
be expected to endanger the health and safety of the public; cause
significant adverse impact to the land, water, or air environment; or
cause severe damage to property. This notification must be made
regardless of the amount of the discharge.

In the event of a discharge that does not present an emergency
situation, verbal notification must be made to the Office of
Environmental Compliance (by telephone at 225-763-3908 during office
hours or 225-342-1234 after hours, weekends, and holidays; or by e-mail
utilizing the Incident Report Form and procedures found at
www.deq.state.la.us/surveillance) *within twenty-four (24) hours* of the
discovery of the discharge.

**2.1.2 Written Notification Requirements (State and Federal (40 CFR
part 112))**

A written notification will be made to EPA for any single discharge of
oil to a navigable waters or adjoining shoreline waterway of more than
1,000 gallons, or for two discharges of 1 bbl (42 gallons) of oil to a
waterway in any 12-month period. This written notification must be made
within 60 days of the qualifying discharge, and a copy will be sent to
the Louisiana Department

of Environmental Quality (DEQ), which is the state agency in charge of
oil pollution control activities. This reporting requirement is separate
and in addition to reporting under 40 CFR part 110 discussed above.

For any discharge reported verbally, a written notification must also be
sent to the DEQ and to the St. Anthony's Parish Local Emergency Planning
Committee (LEPC), both within five (5) days of the qualifying discharge.

A written notification to the State Emergency Response Commission or
LEPC is required for a discharge of 100 lbs or more beyond the confines
of the facility (equivalent to 2 mcf of natural gas, or 13 gallons of
oil) within five (5) days of the qualifying discharge.

**2.1.3 Submission of SPCC Information**

Whenever the facility experiences a discharge into navigable waters of
more than 1,000 gallons, or two discharges of 42 gallons or more within
a 12-month period, Clearwater will provide information in writing to the
EPA Region 6 office within 60 days of a qualifying discharge as
described above. The required information is described in Appendix F of
this SPCC Plan.

**2.2 Spill Response Materials**

Boom, sorbent, and other spill response materials are stored in the shed
next to the loading area and are accessible by Clearwater and Avonlea
personnel. The response equipment inventory for the facility includes:

\(4\) Empty 55-gallons drums to hold contaminated material

3.  50-ft absorbent socks

4.  10-ft sections of hard skirted deployment boom

5.  50-ft floating booms

(200 pounds) "Oil-dry" loose absorbent material

(4 boxes) 2 ft x 3 ft absorbent pads

(3 boxes) Nitrile gloves

(3 boxes) Neoprene gloves

(6 pairs) Vinyl/PVC pull-on overboots

\(3\) Non-sparking shovels

\(3\) Brooms

(20) Sand bags

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(1) Combustible Gas Indicator with H~2~S detection capabilities

Additional equipment and material are also kept at the field office. The
inventory is checked monthly by Clearwater field operations personnel to
ensure that used material is replenished. Supplies and equipment may be
ordered from:

1.  Rocky Mountain Equipment Co. (800) 959-3000

2.  Quick Sorbent (800) 857-4650.

**2.3 Spill Mitigation Procedures**

![](media/image3.wmf){width="2.8125in" height="5.2083333333333336e-2in"}

The following is a summary of actions that must be taken in the event of
a discharge. It summarizes the distribution of responsibilities among
individuals and describes procedures to follow in the event of a
discharge.

A complete outline of actions to be performed in the event of a
discharge from flowlines reaching or threatening to reach navigable
waters is included in the facility Contingency Plan (see Appendix I of
this SPCC Plan).

In the event of a discharge, Clearwater or contractor field personnel
and the Field Operations Manager shall be responsible for the following:

**2.3.1 Shut Off Ignition Sources**

Field personnel must shut off all ignition sources, including motors,
electrical circuits, and open flames. See Appendix G for more
information about shut-off procedures.

**2.3.2 Stop Oil Flow**

Field personnel should determine the source of the discharge, and if
safe to do so, immediately shut off the source of the discharge. Shut in
the well(s) if necessary.

**2.3.3 Stop the Spread of Oil and Call the Field Operations Manager**

If safe to do so, field personnel must use resources available at the
facility (see spill response material and equipment listed in Section
2.2) to stop the spilled material from spreading. Measures that may be
implemented, depending on the location and size of the discharge,
include placing sorbent material or other barriers in the path of the
discharge (e.g., sand bags), or constructing earthen berms or trenches.

In the event of a significant discharge, field personnel must
immediately contact the Field Operations Manager, who may obtain
assistance from authorized company contractors and direct the response
and cleanup activities. Should a discharge reach Big Bear Creek, only
physical response and countermeasures should be employed, such as the
construction of underflow dams, installation of hard boom and sorbent
boom, use of sorbent pads, and use of vacuum trucks to recover oil and
oily water from the creek. If water flow is low in the creek,
construction of an underflow dam downstream and ahead of the spill flow
may be advantageous. Sorbent material and/or boom should be placed
immediately downstream of the dam to recover any sheen from the water.
If water flow is normal in the creek, floating booms and sorbent boom
will be deployed. Vacuum trucks will then be utilized to remove oil and
oily water at dams and other access points. Crews should remove oiled
vegetation and debris from the creek banks and place them in bags for
later disposal. After removal of contaminated vegetation, creek banks
should be flushed with water to remove free oil and help it flow down to
dams and other access points where it can be recovered by vacuum truck.
At no time shall any surfactants, dispersants, or other chemicals be
used to remove oil from the creek.

**2.3.4 Gather Spill Information**

The Field Operations Manager will ensure that the *Discharge
Notification Form* is filled out and that notifications have been made
to the appropriate authorities. The Field Operations Manager may ask for
assistance in gathering the spill information on the *Discharge
Notification Form* (Appendix F) of this Plan:

1.  Reporter's name

2.  Exact location of the spill

3.  Date and time of spill discovery

4.  Material spilled (e.g., oil, produced water containing a reportable
    quantity of oil)

5.  Total volume spilled and total volume reaching or threatening
    navigable waters or adjoining shorelines

6.  Weather conditions

7.  Source of spill

8.  Actions being taken to stop, remove, and mitigate the effects of the
    discharge

9.  Whether an evacuation may be needed

10. Spill impacts (injuries; damage; environmental media, e.g., air,
    waterway, groundwater)

11. Names of individuals and/or organizations who have also been
    contacted

**2.3.5 Notify Agencies Verbally**

Some notifications must be completed *immediately* upon discovering the
discharge. It is important to immediately contact the Field Operations
Manager so that timely notifications can be made. If the Field
Operations Manager is not available, or the Field Operations Manager
requests it, field personnel must designate one person to begin
notification. Section 2.1 of this Plan describes the required
notifications to government agencies. The Notification List is included
in Appendix F of this SPCC Plan. The Field Operations Manager must also
ensure that written notifications, if needed, are submitted to the
appropriate agencies.

**2.4 Disposal Plan**

The cleanup contractor will handle the disposal of any recovered
product, contaminated soil, contaminated materials and equipment,
decontamination solutions, sorbents, and spent chemicals collected
during a response to a discharge incident.

Any recovered product that can be recycled will be placed into the gun
barrel tank to be separated and recycled. Any recovered product not
deemed suitable for on-site recycling will be disposed of with the rest
of the waste collected during the response efforts.

If the facility responds to a discharge without involvement of a cleanup
contractor, Clearwater will contract a licensed transportation/disposal
company to dispose of waste according to regulatory requirements. The
Field Operations Manager will characterize the waste and arrange for the
use of certified waste containers.

All facility personnel handling hazardous wastes must have received both
the initial 40-hour and annual 8-hour refresher training in the
Hazardous Waste Operations and Emergency Response Standard (HAZWOPER) of
the Occupational Health and Safety Administration (OSHA). This training
is included as part of the initial training received by all field
personnel. Training records and certificates are kept at the field
office.

**PART III. SPILL PREVENTION, CONTROL, AND**

**COUNTERMEASURE PROVISIONS**

**40 CFR 112.7 and 112.9**

**3.1 Potential Discharge Volume and Direction of Flow \[112.7(b)\] and
Containment \[112.7(a)(3)(iii)\]**

Table 3-1, below, summarizes potential oil discharge scenarios. If
unimpeded, oil would follow the site topography and reach Big Bear
Creek.

**Table 3-1**: Potential discharge volume and direction of flow

  ------------------------------------------------------------------------------------------------
  Number range        **Type of         **Maximum   **Maximum    **Direction of  **Containment**
  CHAPTER**Source**   failure**         Volume      Discharge    Flow**          
                                        (gal)**     Rate                         
                                                    (gal/hr)**                   
  ------------------- ----------------- ----------- ------------ --------------- -----------------
  **Tank Battery**                                                               

  Crude Oil Storage   Rupture due to    16,800      16,800       Southeast       Containment berm
  Tank                lightning strike,                          towards Big     
                      seam failure                               Bear Creek.     

                      Leak at manway,   24          1            Southeast       
                      valves                                     towards Big     
                                                                 Bear Creek.     

                      Overflow (1 day's 1,260       53           Southeast       
                      production)                                towards Big     
                                                                 Bear Creek.     

  Gun barrel          Rupture due to    21,000      21,000       Southeast       Containment berm
                      lightning strike,                          towards Big     
                      seam failure                               Bear Creek.     

                      Leak at manway,   42          2            Southeast       
                      valves                                     towards Big     
                                                                 Bear Creek.     

                      Overflow (1 day's 7,140       298          Southeast       Containment berm
                      production)                                towards Big     
                                                                 Bear Creek.     

  **Flowlines** **and                                                            
  Piping**                                                                       

  Flowlines and       Rupture/failure   3,570       148          Southeast       Containment berm
  Piping on Storage   due to corrosion                           towards Big     
  Tanks and Gun                                                  Bear Creek.     
  Barrel                                                                         

                      Pinhole leak, or  48          2            Southeast       
                      leak at                                    towards Big     
                      connection                                 Bear Creek.     

  Flowlines and       Rupture/failure   3,570       148          Southeast       None; See Oil
  Piping associated   due to corrosion                           towards Big     Spill Contingency
  with wells                                                     Bear Creek.     Plan

                      Pinhole leak, or  48          2            Southeast       None; See Oil
                      leak at                                    towards Big     Spill Contingency
                      connection                                 Bear Creek.     Plan

  **Wells**                                                                      

  Polished rod        Leak              24          1            Southeast       Well pad
  stuffing box,                                                  towards Big     
  valves, fittings,                                              Bear Creek.     
  gauges                                                                         

  **Saltwater                                                                    
  Disposal**                                                                     

  Piping/hoses,       Leak              24          1            Southeast       Containment berm
  pumps, valves                                                  towards Big     
                                                                 Bear Creek.     

  **Transfers and                                                                
  Loading                                                                        
  Operations**                                                                   

  Transport truck     Rupture           84          84           Southeast       Downslope berm
  loading hose                                                   towards Big     
                                                                 Bear Creek.     

  Offload line,       Leak              42          1            Southeast       Downslope berm
  connection                                                     towards Big     
                                                                 Bear Creek.     

  Tank truck          Over-topping      1,680       1,680        Southeast       Drainage ditch
                      while loading                              towards Big     
                                                                 Bear Creek.     

  Transfer valve      Rupture, leak of  3           3            Southeast       Load line
                      valve packing                              towards Big     container, curb
                                                                 Bear Creek.     
  ------------------------------------------------------------------------------------------------

**3.2 Containment and Diversionary Structures \[112.7(c) and
112.7(a)(3)(iii)\]**

The facility is configured to minimize the likelihood of a discharge
reaching navigable waters.

The following measures are provided:

-   Secondary containment for the oil storage tanks, saltwater tank
    (which may have small amounts of oil), and gun barrel is provided by
    a 60 ft x 40 ft x 2.5 ft earthen berm that provides a total
    containment volume of 867 barrels (36,423 gallons), as described in
    Section 3.2.2 below. The berm is constructed of native soils and
    heavy clay that have been compacted, then covered with gravel. A
    clay layer in the shallow subsurface exists naturally and will stop
    any spilled oil from seeping to deeper groundwater.

-   The tank truck loading area is flat but gently slopes to the
    southeast, where a crescent-shaped, open berm has been placed to
    catch any potential spills from tanker transport trucks. The bermed
    area provides a catchment basin of 40 barrels (1,680 gallons), the
    maximum expected amount of a spill from the tanker due to
    overtopping of the truck during loading. In addition, the end of the
    load line is equipped with a load line drip bucket designed to
    prevent small discharges that may occur when disconnecting the hose.

-   Booms, sorbents, shovels, and other discharge response materials are
    stored in a shed located in close proximity to the loading area.
    This material is sufficient to contain small discharges (up to
    approximately 200 gallons).

These measures are described in more details in the following sections.

**3.2.1 Oil Production Facility Drainage \[112.9(b)\]**

Facility drainage in the production/separation area but outside
containment berms is designed to flow into drainage ditches located on
the eastern and southern boundaries of the site. These ditches usually
run dry. The ditches are visually examined by facility personnel on a
daily basis during routine facility rounds, during formal monthly
inspections, and after rain events, to detect any discoloration or
staining that would indicate the presence of oil from small leaks within
the facility. Any accumulation of oil is promptly removed and disposed
off site. Formal monthly inspections are documented.

Discharges from ASTs are restrained by the secondary containment berm,
as described in Section 3.2.2 of this Plan. Discharges occurring during
transfer operations will be contained at each well by the rock pad or
will flow into the drainage ditch located at the facility.

**3.2.2 Secondary Containment for Bulk Storage Containers
\[112.9(c)(2)\]**

In order to further minimize the potential for a discharge to navigable
waters, bulk storage containers such as all tank battery, separation,
and treating equipment are placed inside a 2.5-ft tall earthen berm
(fire wall). The berm capacity exceeds the SPCC and Louisiana
requirements. It provides secondary containment sufficient for the size
of the largest tank, plus at least 1 ft of freeboard to contain
precipitation. This secondary containment capacity is equivalent to 173
percent of the capacity of the largest tank within the containment area
(500 barrels) and exceeds the 10 percent freeboard recommended by API
for firewalls around production tanks (API-12R1). The amount of
freeboard also exceeds the amount of precipitation anticipated at this
facility, which is estimated to average 3.5 inches for a 24-hour,
25-year storm, based on data from the nearby Ridgeview Regional Airport.
Details of the berm capacity calculation are provided in Table 3-2.

**Table 3-2**: Berm capacity calculations

  ------------------------------ ----------------------------------------
  Number range CHAPTER**Berm     
  Capacity**                     

  Berm height                    2.5 ft

  Berm dimensions                60 ft x 40 ft = 2,400 ft^2^

  Tank footprint                 4 tanks @ 12 ft dia. each = 4 x (π
                                 12^2^/4) = 452 ft^2^

  Net volume                     2.5 ft x (2,400 - 452) = 4,869 ft^3^ =
                                 36,423 gallons

  Ratio to largest tank          36,423 / 21,000 = 173%

                                 

  **Corresponding Amount of      
  Freeboard**                    

  100% of tank volume            21,000 gallons = 2,807 ft^3^

  Net area (minus tank           2,400 ft^2^ - 452 ft^2^ = 1,948 ft^2^
  footprint)                     

  Minimum berm height for 100%   2,807 ft^3^ / 1,948 ft^2^ = 1.44 ft
  of tank volume                 

  Freeboard                      2.5 ft - 1.44 ft = 1.06 ft
  ------------------------------ ----------------------------------------

The floor and walls of the berm are constructed of compacted earth with
a layer of clay that ensures that the berm is able to contain the
potential release of oil from the storage tanks until the discharge can
be detected and addressed by field operations personnel. Facility
personnel inspect the berm daily for the presence of oil. The sides of
the berm are capped with gravel to minimize erosion.

The berm is equipped with a manual valve of open-and-closed design. The
valve is used to drain the berm and is normally kept closed, except when
draining water accumulation within the berm. Drainage from the berm
flows into the drainage ditch to the south of the production/ separation
area. All water is closely inspected by field operations personnel (who
are the persons providing "responsible supervision") prior to draining
water accumulation to ensure that no free oil is present (i.e., there is
no sheen or discoloration upon the surface, or a sludge or emulsion
deposit beneath the surface of the water). The bypass valve for the
containment structure is opened and resealed following drainage under
the responsible supervision of field operations personnel. Free oil is
promptly removed and disposed of in accordance with waste regulations.
Drainage events are recorded on the form provided in Appendix D,
including the time, date, and name of the employee who performed the
drainage. The records are maintained with this SPCC Plan at the
Ridgeview field office for a period of at least three years.

**3.2.3 Practicability of Secondary Containment \[112.7(d)\]**

Flowlines adjacent to the production equipment and storage tanks are
located within the berm, and therefore have secondary containment.
Aboveground flowlines that go from the wells to the production equipment
and buried flowlines, however, lack adequate secondary containment.

The installation of double-wall piping, berms, or other permanent
structures (e.g., remote impoundment) are impracticable at this facility
due to the long distances involved and physical and road/fenceline
right-of-way constraints. Additionally, such permanent structures would
create land erosion and access problems for the landowner's farming
operations and current uses of the land (e.g., agricultural production,
animal grazing).

Other measures listed under 40 CFR 112.7(c) such as the use of sorbents
are also impracticable as means of secondary containment since the
volumes involved may exceed the sorbent capacity and the facility is
attended for only a few hours each day.

Because secondary containment for flowlines outside of the tank battery
is impracticable, Clearwater has provided with this Plan additional
elements required under 40 CFR 112.7(d), including:

-   A written commitment of manpower, equipment, and materials required
    to expeditiously control and remove any quantity of oil discharged
    that may be harmful (see Appendix H).

-   An Oil Spill Contingency Plan following the provisions of 40 CFR 109
    (see Appendix I).

**3.3 Other Spill Prevention Measures**

**3.3.1 Bulk Storage Containers Overflow Prevention \[112.9(c)(4)\]**

The tank battery is designed with a fail-safe system to prevent
discharge, as follows:

-   The capacity of the oil storage tanks is sufficient to ensure that
    oil storage is adequate in the event where facility personnel are
    unable to perform the daily visit to unload the tanks or the pumper
    is delayed in stopping production. The maximum capacity of the wells
    linked to the tank battery is approximately 600 barrels per day. The
    oil tanks are sized to provide sufficient storage for at least two
    days.

1.  The tanks are connected with overflow equalizing lines to ensure
    that a full tank can overflow to an adjacent tank.

**3.3.2 Transfer Operations and Saltwater Disposal System \[112.9(d)\]**

All aboveground valves and piping associated with transfer operations
are inspected daily by the pumper and/or tank truck driver, as described
in Section 3.4 of this Plan. The inspection procedure includes observing
flange joints, valve glands and bodies, drip pans, and pipe supports.
The conditions of the pumping well polish rod stuffing boxes, and
bleeder and gauge valves, are inspected monthly.

Components of the produced water disposal system are inspected on a
monthly basis by field operation personnel as described in Section 3.4
and following the checklist provided in Appendix C of this SPCC Plan.
This includes the pumps and motors for working condition and leaks,
hoses, valves, flowlines, and the saltwater injection wellhead.
Maintenance and operation of the well itself and the downhole injection
comply with EPA's and the state's Underground Injection Control (UIC)
rules and regulations (40 CFR parts 144-148).

**3.4 Inspections, Tests, and Records \[112.7(e)\]**

This Plan outlines procedures for inspecting the facility equipment in
accordance with SPCC requirements. Records of inspections performed as
described in this Plan and signed by the appropriate supervisor are a
part of this Plan, and are maintained with this Plan at the Ridgeview
field office for a minimum of three years. The reports include a
description of the inspection procedure, the date of inspection, whether
drainage of accumulated rainwater was required, and the inspector's
signature.

The program established in this SPCC Plan for regular inspection of all
oil storage tanks and related production and transfer equipment follows
the American Petroleum Institute's *Recommended Practice for Setting
Maintenance, Inspection, Operation, and Repair of Tanks in Production
Service* (API RP 12R1, Fifth Edition, August 1997). Each container is
inspected monthly by field operation personnel as described in this Plan
section and following the checklist provided in Appendix C of this SPCC
Plan. The monthly inspection is aimed at identifying signs of
deterioration and maintenance needs, including the foundation and
support of each container. Any leak from tank seams, gaskets, rivets,
and bolts is promptly corrected.

This Plan also describes provisions for monitoring the integrity of
flowlines through a combination of monthly visual inspections and
periodic pressure testing or through the use of an alternate technology.
The latter element is particularly important for this facility since
flowlines do not have adequate secondary containment.

The inspection program is comprised of informal daily examinations,
monthly scheduled inspections, and periodic condition inspections.
Additional inspections and/or examinations are performed whenever an
operation alert, malfunction, shell or deck leak, or potential bottom
leak is reported following a scheduled examination. Written
examination/inspection procedures and monthly examination/inspection
reports are signed by the field inspector and are maintained at the
field office for a period of at least three years.

**3.4.1 Daily Examinations**

The facility is visited daily by field operations personnel. The daily
visual examination consists of a walk through of the tank battery and
around the wells. Field operations personnel check the wells and
production equipment for leaks and proper operation. They examine all
aboveground valves, polished rod stuffing boxes, wellheads, fittings,
gauges, and flowline piping at the wellhead. Personnel inspect pumps to
verify proper function and check for damage and leakage. They look for
accumulation of water within the tank battery berms and verify the
condition and position of valves. The storage tanks are gauged every
day. A daily production report is maintained. All malfunctions, improper
operation of equipment, evidence of leakage, stained or discolored soil,
etc. are logged and communicated to the Clearwater Field Operations
Manager.

**Table 3-3: Scope of daily examinations**

+--------------+-------------------+-----------------------------------+
| **Facility   | **Item**          | **Observations**                  |
| Area**       |                   |                                   |
+==============+===================+===================================+
| Storage      | Leaks             | Tank liquid level gauged          |
| Tanks (Oil   |                   |                                   |
| and Produced |                   | Drip marks, leaks from weld       |
| water)       |                   | seams, base of tank               |
|              |                   |                                   |
|              |                   | Puddles containing spilled or     |
|              |                   | leak material                     |
|              |                   |                                   |
|              |                   | Corrosion, especially at base     |
|              |                   | (pitting, flaking)                |
|              |                   |                                   |
|              |                   | Cracks in metal                   |
|              |                   |                                   |
|              |                   | Excessive soil or vegetation      |
|              |                   | buildup against base              |
+--------------+-------------------+-----------------------------------+
|              | Foundation        | Cracks                            |
|              | problems          |                                   |
|              |                   | Puddles containing spilled or     |
|              |                   | leaked material                   |
|              |                   |                                   |
|              |                   | Settling                          |
|              |                   |                                   |
|              |                   | Gaps at base                      |
+--------------+-------------------+-----------------------------------+
|              | Flowlines         | Evidence of leaks, especially at  |
|              | problems          | connections/collars               |
|              |                   |                                   |
|              |                   | Corrosion (pitting, flaking)      |
|              |                   |                                   |
|              |                   | Settling                          |
|              |                   |                                   |
|              |                   | Evidence of stored material       |
|              |                   | seepage from valves or seals      |
+--------------+-------------------+-----------------------------------+
| Wells        | Leak              | Evidence of oil seepage from      |
|              |                   | pumping rod stuffing boxes,       |
|              |                   | wellhead and wellhead flowlines,  |
|              |                   | valves, gauges                    |
+--------------+-------------------+-----------------------------------+
| SW Pumps     | Leaks             | Leaks at seals, flowlines,        |
|              |                   | valves, hoses                     |
|              |                   |                                   |
|              |                   | Puddles containing spilled or     |
|              |                   | leaked material                   |
|              |                   |                                   |
|              |                   | Corrosion                         |
+--------------+-------------------+-----------------------------------+

**3.4.2 Monthly Inspections**

Table 3-4 summarizes the scope of monthly inspections performed by field
personnel.

The monthly inspection covers the wellheads, flowlines, and all
processing equipment. It also includes verifying the proper functioning
of all detection devices, including high-level sensors on oil storage
tanks, heater treater, and separators. Storage tanks are inspected for
signs of deterioration, leaks, or accumulation of oil inside the
containment area, or other signs that maintenance or repairs are needed.
The secondary containment area is checked for proper drainage, general
conditions, evidence of oil, or signs of leakage. The monthly inspection
also involves visually inspecting all aboveground valves and pipelines
and noting the general condition of items such as transfer hoses, flange
joints, expansion joints, valve glands and bodies, catch pans, pipeline
supports, pumping well pumping rod stuffing boxes, bleeder and gauge
valves, locking of valves, and metal surfaces.

The checklist provided in Appendix C is used during monthly inspections.
These inspections are performed in accordance with written procedures
such as API standards (e.g., API RP 12R1), engineering specifications,
and maintenance schedule developed by the equipment manufacturers.

All safety devices are tested quarterly by a third party inspector. The
tests are recorded and the results are maintained with this Plan at
Clearwater's field office. Testing of the safety devices is conducted in
accordance with guidelines API RP-14C published by the American
Petroleum Institute, or in accordance with instructions from the
device's manufacturer. Written test procedures are kept at the offices
of the third party testing company and are available upon request.

Twice a year, facility personnel drive to the pre-established response
staging areas located at three different points along Big Bear Creek
(see Oil Spill Contingency Plan in Appendix I) to ensure that the
dirt/gravel roads are accessible using field vehicles and that the Oil
Spill Contingency Plan can be implemented in the event of a discharge
from flowlines reaching the Creek.

**Table 3-4: Scope of monthly inspections**

+--------------+-------------------+-----------------------------------+
| **Facility   | **Equipment**     | **Inspection Item**               |
| Area**       |                   |                                   |
+==============+===================+===================================+
| Tank Battery | Storage tanks     | Leakage, gaskets, hatches         |
|              |                   |                                   |
|              |                   | Tank liquid level checked         |
|              |                   |                                   |
|              |                   | Tank welds in good condition      |
|              |                   |                                   |
|              |                   | Vacuum vents                      |
|              |                   |                                   |
|              |                   | Overflow lines                    |
|              |                   |                                   |
|              |                   | Piping, valves, and bull plugs    |
|              |                   |                                   |
|              |                   | Corrosion, paint condition        |
|              |                   |                                   |
|              |                   | Pressure / level safety devices\* |
|              |                   |                                   |
|              |                   | Emergency shut-down system(s)\*   |
|              |                   |                                   |
|              |                   | Pressure relief valves\*          |
+--------------+-------------------+-----------------------------------+
|              | Area              | Berm and curbing                  |
|              |                   |                                   |
|              |                   | Presence of contaminated/stained  |
|              |                   | soil                              |
|              |                   |                                   |
|              |                   | Excessive vegetation              |
|              |                   |                                   |
|              |                   | Equipment protectors and signs    |
|              |                   |                                   |
|              |                   | Engine drip pans and sumps        |
|              |                   |                                   |
|              |                   | General housekeeping              |
+--------------+-------------------+-----------------------------------+
| Truck        | Offload lines,    | Valve closed and in good          |
| Loading      | drip pans,        | condition                         |
|              | valves, catchment |                                   |
|              | berm              | Cap or bull plug at end of        |
|              |                   | offload line/connection           |
|              |                   |                                   |
|              |                   | Sign of oil or standing water in  |
|              |                   | drip pan(s)                       |
|              |                   |                                   |
|              |                   | Sign of oil or standing water in  |
|              |                   | catchment berm                    |
|              |                   |                                   |
|              |                   | Sign of oil in surrounding area   |
+--------------+-------------------+-----------------------------------+
|              | Production        | Gauges (pressure, temperature,    |
|              | equipment         | and liquid level)                 |
|              |                   |                                   |
|              |                   | Pressure / level safety devices\* |
|              |                   |                                   |
|              |                   | Emergency shut-down system(s)\*   |
|              |                   |                                   |
|              |                   | Pressure relief valves\*          |
+--------------+-------------------+-----------------------------------+
| Wells        | Area              | Spills and leaks (e.g., stuffing  |
| (including   |                   | box)                              |
| saltwater    |                   |                                   |
| disposal     |                   | Equipment protectors and signs    |
| well)        |                   |                                   |
|              |                   | General housekeeping              |
+--------------+-------------------+-----------------------------------+
| Leasehold    | Flowlines         | Flowline between the well and     |
| area between |                   | tank battery/gun barrel           |
| wells and    |                   |                                   |
| Tank Battery |                   | Exposed line of buried piping     |
|              |                   |                                   |
|              |                   | Valves (condition of, whether     |
|              |                   | locked or sealed)                 |
|              |                   |                                   |
|              |                   | Evidence of leaks and/or damage,  |
|              |                   | especially at connections/collars |
|              |                   |                                   |
|              |                   | Corrosion (pitting, flaking)      |
|              |                   |                                   |
|              |                   | Pipe supports                     |
+--------------+-------------------+-----------------------------------+
|              | Road and Field    | Evidence/puddles of crude oil     |
|              | Ditches           | and/or produced water             |
+--------------+-------------------+-----------------------------------+
| Other        | Chemicals, Fuels  | Storage conditions                |
|              | and Lube Oils     |                                   |
+--------------+-------------------+-----------------------------------+
| Response     | Area              | Road practicable by field vehicle |
| staging      |                   |                                   |
| areas        |                   | Area clear of excessive           |
|              |                   | vegetation                        |
+--------------+-------------------+-----------------------------------+
| \* Tested    |                   |                                   |
| quarterly by |                   |                                   |
| third party  |                   |                                   |
| inspection   |                   |                                   |
| company.     |                   |                                   |
+--------------+-------------------+-----------------------------------+

**3.4.3 Periodic Condition Inspection of Bulk Storage Containers**

A condition inspection of bulk storage containers is performed by a
qualified inspector according to the schedule and scope specified in API
RP 12R1. The schedule is determined based on the corrosion rate; with
the first inspection performed no more than 15 years after the tank
construction, as detailed in Table 3-5.

Three bulk storage containers installed at this facility were moved from
another facility decommissioned by Clearwater. These bulk storage
containers were leak tested after relocation to the facility.

**Table 3-5: Schedule of periodic condition inspection of bulk storage
containers**

  ----------------------------------------------------------------------------
  **Tank**   **Year    **Last          **Next inspection by**
             Built**   Inspection**    
  ---------- --------- --------------- ---------------------------------------
  #1         1983      11/5/1998       11/5/2008\*

  #2         2002      None            First inspection to be performed by
                                       12/31/2017\*

  #3         1995      None            First inspection to be performed by
                                       12/31/2010\*

  #4         2002      None            First inspection to be performed by
                                       12/31/2017\*

  #5         1991      None            First inspection to be performed by
                                       12/31/2006\*
  ----------------------------------------------------------------------------

\* Dates for subsequent external inspections must follow the
recommendations of the certified inspector, not to exceed three-quarters
of the predicted shell/roof deck corrosion rate life, or maximum of 15
years.

**3.4.4 Brittle Fracture Evaluation \[112.7(i)\]**

At the present time, none of the bulk storage containers at this site
was field-erected, and therefore no brittle fracture evaluation is
required.

**3.4.5 Flowline Maintenance Program \[112.9(d)(3)\]**

Because the facility is relying on a contingency plan to address
discharges, the flowline maintenance program is specifically implemented
to maintain the integrity of the primary container (in this case piping)
to minimize releases of oil from this part of the production facility.
The facility's gathering lines and flowlines are configured, inspected
monthly for leaks at connections and on each joint, corrosion (pitting,
flaking), and maintained to minimize the potential for a discharge as
summarized in Table 3-6. Records of integrity inspections, leak tests,
and part replacements are kept at the facility for at least three years
(integrity test results are kept for ten years).

**Table 3-6: Components of flowline maintenance program**

+---------------+------------------------------------------------------+
| **Component** | **Measures/Activities**                              |
+---------------+------------------------------------------------------+
| Configuration | 2.  Well pumps are equipped with low-pressure        |
|               |     shut-off systems that detect pressure drops and  |
|               |     minimize spill volume in the event of a flowline |
|               |     leak.                                            |
|               |                                                      |
|               | -   Flowlines are identified on facility maps and    |
|               |     are marked in the field to facilitate access and |
|               |     inspection by facility personnel. Flowline maps  |
|               |     and field tags indicate the location of shutdown |
|               |     devices and valves that may be used to isolate   |
|               |     portions of the flowline.                        |
|               |                                                      |
|               | -   With the exception of a portion of Flowline B    |
|               |     under an access road, the flowlines and          |
|               |     appurtenances (valves, flange joints, supports)  |
|               |     can be visually observed for signs of leakage,   |
|               |     deterioration, or other damage.                  |
+---------------+------------------------------------------------------+
| Inspection    | 1.  Lines are visually inspected for leaks and       |
|               |     corrosion as part of the monthly rounds by field |
|               |     personnel, as discussed in Section 3.4 above.    |
|               |                                                      |
|               | 2.  The buried portions of Flowline B are            |
|               |     coated/wrapped and visually observed for damage  |
|               |     or coating condition whenever they are repaired, |
|               |     replaced, or otherwise exposed.                  |
|               |                                                      |
|               | -   Every five years, flowlines are tested using     |
|               |     ultrasonic techniques to determine remaining     |
|               |     wall thickness and mechanical integrity. Copies  |
|               |     of test results are maintained at the facility   |
|               |     for ten years to allow comparison of successive  |
|               |     tests.                                           |
+---------------+------------------------------------------------------+
| Maintenance   | 1.  Any leak in the flowline or appurtenances is     |
|               |     promptly addressed by isolating the damaged      |
|               |     portion and repairing or replacing the faulty    |
|               |     piece of equipment. Clearwater does not accept   |
|               |     pipe clamps and screw-in plugs as forms of       |
|               |     repair.                                          |
|               |                                                      |
|               | Any portion of a flowline that fails the mechanical  |
|               | integrity test is repaired and retested, or          |
|               | replaced.                                            |
+---------------+------------------------------------------------------+

**3.5 Personnel, Training, and Discharge Prevention Procedures
\[112.7(f)\]**

The Field Operations Manager has been designated as the point of contact
for all oil discharge prevention and response at this facility.

All Clearwater field personnel receive training on proper handling of
oil products and procedures to respond to an oil discharge prior to
entering any Clearwater production facility. The training ensures that
all facility personnel understand the procedures described in this SPCC
Plan and are informed of the requirements under applicable pollution
control laws, rules and regulations. The training also covers risks
associated with potential exposure to hydrogen sulfide (H~2~S) gas. All
Clearwater field personnel also receive an initial 40-hour HAZWOPER
training (and 8-hour annual refresher training) as per OSHA standard.

Clearwater ensures that all contractor personnel are familiar with the
facility operations, safety procedures, and spill prevention and control
procedures described in this Plan prior to working at the facility. All
contractors working at the facility receive a copy of this SPCC Plan.
Avonlea personnel visiting the facility receive training similar to that
provided to Clearwater oil handling employees.

Clearwater management holds briefings with field operations personnel
(including contractor personnel as appropriate) at least once a year, as
described below.

**3.5.1 Spill Prevention Briefing**

The Field Operations Manager conducts Spill Prevention Briefings
annually to ensure adequate understanding and effective implementation
of this SPCC Plan. These briefings highlight and describe known spill
events or failures, malfunctioning components, and recently developed
precautionary measures. The briefings are conducted in conjunction with
the company safety meetings. Sign-in sheets, which include the topics of
discussion at each meeting, are maintained with this Plan at
Clearwater's field office. A *Discharge Prevention Briefing Log* form is
provided in Appendix E to this Plan and is used to document the
briefings. The scheduled annual briefing includes a review of Clearwater
policies and procedures relating to spill prevention, control, cleanup,
and reporting; procedures for routine handling of products (e.g.,
loading, unloading, transfers); SPCC inspections and spill prevention
procedures; spill reporting procedures; spill response; and recovery,
disposal, and treatment of spilled material.

Personnel are instructed in operation and maintenance of equipment to
prevent the discharge of oil, and in applicable federal, state, and
local pollution laws, rules, and regulations. Facility operators and
other personnel have an opportunity during the briefings to share
recommendations concerning health, safety, and environmental issues
encountered during facility operations.

The general outline of the briefings is as follows:

2.  Responsibilities of personnel and Designated Person Accountable for
    Spill Prevention;

3.  Spill prevention regulations and requirements;

4.  Spill prevention procedures;

5.  Spill reporting and cleanup procedures;

6.  History/cause of known spill events;

7.  Equipment failures and operational issues;

8.  Recently developed measures/procedures;

9.  Proper equipment operation and maintenance; and

10. Procedures for draining rainwater from berms.

**3.5.2 Contractor Instructions**

In order that there will be no misunderstanding on joint and respective
duties and responsibilities to perform work in a safe manner, contractor
personnel also receive instructions on the procedures outlined in this
SPCC Plan. The instructions cover the contractor activities such as
servicing a well or equipment associated with the well, such as pressure
vessels.

All contractual agreements between Clearwater and contractors
specifically state:

> Personnel must, at all times, act in a manner to preserve life and
> property, and prevent pollution of the environment by proper use of
> the facility's prevention and containment systems to prevent
> hydrocarbon and hazardous material spills. No pollutant, regardless of
> the volume, is to be disposed of onto the ground or water, or allowed
> to drain into the ground or water. Federal regulations impose
> substantial fines and/or imprisonment for willful pollution of
> navigable waters. Failure to report accidental pollution at this
> facility, or elsewhere, can be cause for equally severe penalties to
> be imposed by federal regulations. To this end, all personnel must
> comply with every requirement of this SPCC Plan, as well as taking
> necessary actions to preserve life, and property, and to prevent
> pollution of the environment. It is the contractor's (or
> subcontractor's) responsibility to maintain his equipment in good
> working order and in compliance with this SPCC Plan. The contractor
> (or subcontractor) is also responsible for the familiarity and
> compliance of his personnel with this SPCC Plan. Contractor and
> subcontractor personnel must secure permission from Clearwater's Field
> Operations Manager before commencing any work on any facility. They
> must immediately advise the Field Operations Manager of any hazardous
> or abnormal condition so that the Field Operations Manager can take
> corrective measures.

**APPENDIX A: Facility Diagrams**

![](media/image4.wmf)

![](media/image5.wmf)

**Figure A-2:** Production Facility Diagram

**APPENDIX B: Tank Truck Loading Procedures**

**Loading Tank Truck**

Make sure the vehicle tank is properly vented before starting to load or
unload. If you are not certain that the trailer is properly vented, you
must contact your supervisor and request permission to open the trailer
dome before starting to load or unload.

**To Load from Storage Tank to Tank Truck**

-   Attach ground cable or bonding clamp to trailer.

-   Use wheel chocks or other similar barrier to prevent premature
    departure.

-   Hook up load hose and open all appropriate valves from storage tank
    to trailer entry.

-   Disengage clutch and place pump in load position.

-   Release clutch slowly.

-   Adjust throttle to proper engine RPM.

-   When trailer is loaded to appropriate level, slow engine speed.

-   Close valve to storage tank.

-   Loosen loading hose to allow enough air to drain loading hose dry.

-   Ensure that drips from the hose drain into the spill bucket at the
    loading area.

-   Disconnect loading hose completely, close load valve, plug and
    fasten securely.

-   Close belly valve on trailer.

-   Disconnect ground cable.

-   Promptly clean up any spilled oil.

-   Inspect lowermost drains and valves of the vehicle for
    discharges/leaks and ensure that they are tightened, adjusted, or
    replaced as needed to prevent discharges while vehicle is in
    transit.

**APPENDIX C: Monthly Inspection Checklist**

Further description and comments, if needed, should be provided on a
separate sheet of paper and attached to this sheet. Any item answered
"YES" needs to be promptly reported, repaired, or replaced, as it may
result in non-compliance with regulatory requirements. Records are
maintained with the SPCC Plan at the Ridgeview field office.

Date: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ Signature:
\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

+------------------------------------+---+---+-----------------------+
|                                    | Y | N | Description &         |
|                                    | e | o | Comments              |
|                                    | s |   |                       |
|                                    |   |   | (Note tank/equipment  |
|                                    |   |   | ID)                   |
+------------------------------------+---+---+-----------------------+
| **Storage tanks and Separation     |   |   |                       |
| Equipment**                        |   |   |                       |
+------------------------------------+---+---+-----------------------+
| *Tank surfaces show signs of       |   |   |                       |
| leakage*                           |   |   |                       |
+------------------------------------+---+---+-----------------------+
| *Tanks show signs of damage, rust, |   |   |                       |
| or deterioration*                  |   |   |                       |
+------------------------------------+---+---+-----------------------+
| *Bolts, rivets or seams are        |   |   |                       |
| damaged*                           |   |   |                       |
+------------------------------------+---+---+-----------------------+
| *Aboveground tank supports are     |   |   |                       |
| deteriorated or buckled*           |   |   |                       |
+------------------------------------+---+---+-----------------------+
| *Aboveground tank foundations have |   |   |                       |
| eroded or settled*                 |   |   |                       |
+------------------------------------+---+---+-----------------------+
| *Gaskets are leaking*              |   |   |                       |
+------------------------------------+---+---+-----------------------+
| *Level gauges or alarms are        |   |   |                       |
| inoperative*                       |   |   |                       |
+------------------------------------+---+---+-----------------------+
| *Vents are obstructed*             |   |   |                       |
+------------------------------------+---+---+-----------------------+
| *Thief hatch and vent valve does   |   |   |                       |
| not seal air tight*                |   |   |                       |
+------------------------------------+---+---+-----------------------+
| *Containment berm shows            |   |   |                       |
| discoloration or stains*           |   |   |                       |
+------------------------------------+---+---+-----------------------+
| *Berm is breached or eroded or has |   |   |                       |
| vegetation*                        |   |   |                       |
+------------------------------------+---+---+-----------------------+
| *Berm drainage valves are          |   |   |                       |
| open/broken*                       |   |   |                       |
+------------------------------------+---+---+-----------------------+
| *Tank area clear of trash and      |   |   |                       |
| vegetation*                        |   |   |                       |
+------------------------------------+---+---+-----------------------+
| *Equipment protectors, labels, or  |   |   |                       |
| signs are missing*                 |   |   |                       |
+------------------------------------+---+---+-----------------------+
| **Piping/Flowlines and Related     |   |   |                       |
| Equipment**                        |   |   |                       |
+------------------------------------+---+---+-----------------------+
| *Valve seals or gaskets are        |   |   |                       |
| leaking.*                          |   |   |                       |
+------------------------------------+---+---+-----------------------+
| *Pipelines or supports are damaged |   |   |                       |
| or deteriorated.*                  |   |   |                       |
+------------------------------------+---+---+-----------------------+
| *Buried pipelines are exposed.*    |   |   |                       |
+------------------------------------+---+---+-----------------------+
| **Transfer equipment**             |   |   |                       |
+------------------------------------+---+---+-----------------------+
| *Loading/unloading lines are       |   |   |                       |
| damaged or deteriorated.*          |   |   |                       |
+------------------------------------+---+---+-----------------------+
| *Connections are not capped or     |   |   |                       |
| blank-flanged*                     |   |   |                       |
+------------------------------------+---+---+-----------------------+
| *Secondary containment is damaged  |   |   |                       |
| or stained*                        |   |   |                       |
+------------------------------------+---+---+-----------------------+
| **Response Kit Inventory**         |   |   |                       |
+------------------------------------+---+---+-----------------------+
| *Discharge response material is    |   |   |                       |
| missing* *or damaged or needs      |   |   |                       |
| replacement*                       |   |   |                       |
+------------------------------------+---+---+-----------------------+

Additional Remarks (attach sheet as needed):

> **APPENDIX D: Record of Dike Drainage**

This record must be completed when rainwater from diked areas is drained
into a storm drain or into an open watercourse, lake, or pond, and
bypasses the water treatment system. The bypass valve must normally be
sealed in closed position and opened and resealed following drainage
under responsible supervision. Records are maintained with the SPCC Plan
at the Ridgeview field office.

  ----------- ---------- ------------ ----------- ------------ --------------------
  **Date**    **Area**   **Presence   **Time      **Time       **Signature**
                         of Oil**     Started**   Finished**   

  12/5/2003   Tank       No oil       08:00       8:40         William Mackenzie
              battery                                          

                                                               

                                                               

                                                               

                                                               

                                                               

                                                               

                                                               
  ----------- ---------- ------------ ----------- ------------ --------------------

**APPENDIX E: Discharge Prevention Briefing Log**

  ------------ ------------------------------- ---------------------------
  **Date**     **Type of Briefing**            **Instructor(s)**

  12/5/2003    Scheduled refresher. All field  Helena Berry, Optimal H&S
               personnel.                      Inc.

  11/25/2004   Scheduled refresher. All field  Bill Laurier
               personnel.                      

                                               

                                               

                                               

                                               

                                               

                                               
  ------------ ------------------------------- ---------------------------

**APPENDIX F: Discharge Notification Procedures**

Circumstances, instructions, and phone numbers for reporting a discharge
to the National Response Center and other federal, state, and local
agencies, and to other affected parties, are provided below. They are
also posted at the facility in the storage shed containing the discharge
response equipment. Note that any discharge to water must be reported
immediately to the National Response Center.

> Field Operations Manager, Bill Laurier (24 hours) (405) 829-4051

Local Emergency (fire, explosion, or other hazards) 911

+---------------+-------------+--------------------+-----------------+
| **Agency /    | **Agency    | **Circumstances**  | **When to       |
| O             | Contact**   |                    | Notify**        |
| rganization** |             |                    |                 |
+===============+=============+====================+=================+
| *Federal      |             |                    |                 |
| Agencies*     |             |                    |                 |
+---------------+-------------+--------------------+-----------------+
| National      | 1-8         | Discharge reaching | **Immediately   |
| Response      | 00-424-8802 | navigable waters.  | (verbal)**      |
| Center        |             |                    |                 |
+---------------+-------------+--------------------+-----------------+
| EPA Region VI | 1-8         |                    | **Immediately   |
| (Hotline)     | 00-887-6063 |                    | (verbal)**      |
+---------------+-------------+--------------------+-----------------+
| EPA Region VI | First       | Discharge 1,000    | Written         |
| Regional      | Interstate  | gallons or more;   | notification    |
| Administrator | Bank Tower  | or second          | within 60 days  |
|               | at Fountain | discharge of 42    | (see Section    |
|               | Place       | gallons or more    | 2.1 of this     |
|               |             | over a 12-month    | Plan)           |
|               | 1445 Ross   | period.            |                 |
|               | Avenue,     |                    |                 |
|               | 12^th^      |                    |                 |
|               | floor,      |                    |                 |
|               | Suite 1200  |                    |                 |
|               |             |                    |                 |
|               | Dallas TX   |                    |                 |
|               | 75202       |                    |                 |
+---------------+-------------+--------------------+-----------------+
| *State        |             |                    |                 |
| Agencies*     |             |                    |                 |
+---------------+-------------+--------------------+-----------------+
| Office of     | 2           | 1\) Injury         | **Immediately   |
| State Police, | 25-925-6595 | requiring          | (verbal)**      |
| T             |             | hospitalization or |                 |
| ransportation | or          | fatality.          | Written         |
| and           |             |                    | notification to |
| Environmental | 1-8         | 2\) Fire,          | be made within  |
| Safety        | 77-925-6595 | explosion, or      | 5 days.         |
| Section,      |             | other impact that  |                 |
| Hazardous     |             | could affect       |                 |
| Materials     |             | public safety.     |                 |
| Hotline       |             |                    |                 |
|               |             | 3\) Release        |                 |
|               |             | exceeding 24-hour  |                 |
|               |             | reportable         |                 |
|               |             | quantity.          |                 |
|               |             |                    |                 |
|               |             | 4\) Impact to      |                 |
|               |             | areas beyond the   |                 |
|               |             | facility's         |                 |
|               |             | confines.          |                 |
+---------------+-------------+--------------------+-----------------+
| Office of     | 2           | Discharges that    | **Within 1      |
| State Police, | 25-925-6595 | pose emergency     | hour** of       |
| T             |             | conditions,        | discovery       |
| ransportation | or          | regardless of the  | (verbal).       |
| and           |             | volume discharged. |                 |
| Environmental | 1-8         |                    | Written         |
| Safety        | 77-925-6595 |                    | notification    |
| Section,      |             |                    | within 7        |
| Hazardous     |             |                    | working days.   |
| Materials     |             |                    |                 |
| Hotline       |             |                    |                 |
+---------------+-------------+--------------------+-----------------+
| Louisiana     | 2           | Discharges that do | Within 24 hours |
| Department of | 25-763-3908 | not pose emergency | of discovery    |
| Environmental |             | conditions.        | (verbal).       |
| Quality,      | or          |                    |                 |
| Office of     | 2           |                    | Written         |
| Environmental | 25-342-1234 |                    | notification    |
| Compliance    | (after      |                    | within 7        |
|               | business    |                    | working days.   |
|               | hours,      |                    |                 |
|               | weekends    |                    |                 |
|               | and         |                    |                 |
|               | holidays)   |                    |                 |
+---------------+-------------+--------------------+-----------------+
| *Local        |             |                    |                 |
| Agencies*     |             |                    |                 |
+---------------+-------------+--------------------+-----------------+
| St. Anthony's | 3           | Any discharge of   | **Immediately   |
| Parish        | 37-828-1960 | 100 lbs or more    | (verbal)**      |
| Emergency     |             | that occur beyond  |                 |
| Planning      |             | the boundaries of  | Written         |
| Committee     |             | the facility,      | notification    |
|               |             | including to the   | within 7 days.  |
|               |             | air.               |                 |
+---------------+-------------+--------------------+-----------------+
| *Others*      |             |                    |                 |
+---------------+-------------+--------------------+-----------------+
| Res           | EZ Clean    | Any discharge that | As needed       |
| ponse/cleanup |             | exceeds the        |                 |
| contractors   | \(800\)     | capacity of        |                 |
|               | 521-3211    | facility personnel |                 |
|               |             | to respond and     |                 |
|               | Armadillo   | cleanup.           |                 |
|               | Oil Removal |                    |                 |
|               | Co. (214)   |                    |                 |
|               | 566-5588    |                    |                 |
+---------------+-------------+--------------------+-----------------+
| Howard        | \(405\)     | Any discharge that | As needed       |
| Fleming Farm  | 235-6893    | threatens to       |                 |
| (agricultural |             | affect neighboring |                 |
| irrigation    |             | properties and     |                 |
| intake)       |             | irrigation         |                 |
|               |             | intakes.           |                 |
+---------------+-------------+--------------------+-----------------+

The person reporting the discharge must provide the following
information:

-   Name, location, organization, and telephone number;

-   Name and address of the owner/operator;

-   Date and time of the incident;

-   Location of the incident;

-   Source and cause of discharge;

-   Types of material(s) discharged;

-   Total quantity of materials discharged;

-   Quantity discharged in harmful quantity (to navigable waters or
    adjoining shorelines);

-   Danger or threat posed by the release or discharge;

-   Description of all affected media (e.g., water, soil);

-   Number and types of injuries (if any) and damaged caused;

-   Weather conditions;

-   Actions used to stop, remove, and mitigate effects of the discharge;

-   Whether an evacuation is needed;

-   Name of individuals and/or organizations contacted; and

-   Any other information that may help emergency personnel respond to
    the incident.

Whenever the facility discharges more than 1,000 gallons of oil in a
single event, or discharges more than 42 gallons of oil in each of two
discharge incidents within a 12-month period, the Manager of Field
Operations must provide the following information to the U.S.
Environmental Protection Agency's Regional Administrator within 60 days:

-   Name of the facility;

-   Name of the owner or operator;

-   Location of the facility;

-   Maximum storage or handling capacity and normal daily throughput;

-   Corrective actions and countermeasures taken, including a
    description of equipment repairs and replacements;

-   Description of facility, including maps, flow diagrams, and
    topographical maps;

-   Cause of the discharge(s) to navigable waters, including a failure
    analysis of the system and subsystems in which the failure occurred;

-   Additional preventive measures taken or contemplated to minimize
    possibility of recurrence; and

-   Other pertinent information requested by the Regional Administrator.

**Discharge Notification Form**

\*\*\* Notification must not be delayed if information or individuals
are not available.

Facility: Clearwater Oil Company Big Bear Lease No. 2 Production
Facility

5800 Route 417, Madison, Louisiana 73506

+----------------+------------------+----------------------------------+
| **Description  |                  |                                  |
| of Discharge** |                  |                                  |
+----------------+------------------+----------------------------------+
| Date/time      | Release date:    | Discovery date:                  |
|                |                  |                                  |
|                | Release time:    | Discovery time:                  |
|                |                  |                                  |
|                | Duration:        |                                  |
+----------------+------------------+----------------------------------+
| Reporting      | Name:            |                                  |
| Individual     |                  |                                  |
|                | Tel. #:          |                                  |
+----------------+------------------+----------------------------------+
| Location of    | Latitude:        | Description:                     |
| discharge      |                  |                                  |
|                | Longitude:       |                                  |
+----------------+------------------+----------------------------------+
| Equipment      | G piping         | Description:                     |
| source         |                  |                                  |
|                | G flowline       | Equipment ID:                    |
|                |                  |                                  |
|                | G well           |                                  |
|                |                  |                                  |
|                | G unknown        |                                  |
|                |                  |                                  |
|                | G stock, flare   |                                  |
+----------------+------------------+----------------------------------+
| Product        | G crude oil      | \* Describe other:               |
|                |                  |                                  |
|                | G saltwater      |                                  |
|                |                  |                                  |
|                | G other\*        |                                  |
+----------------+------------------+----------------------------------+
| Appearance and |                  |                                  |
| description    |                  |                                  |
+----------------+------------------+----------------------------------+
| Environmental  | Wind direction:  | Rainfall:                        |
| conditions     |                  |                                  |
|                | Wind speed:      | Current:                         |
+----------------+------------------+----------------------------------+
| **Impacts**    |                  |                                  |
+----------------+------------------+----------------------------------+
| Quantity       | Released:        | Recovered:                       |
+----------------+------------------+----------------------------------+
| Receiving      | G water\*\*      | G Release confined to company    |
| medium         |                  | property.                        |
|                | G land           |                                  |
|                |                  | G Release outside company        |
|                | G other          | property.                        |
|                | (describe):      |                                  |
|                |                  | \*\* If water, indicate extent   |
|                |                  | and body of water:               |
+----------------+------------------+----------------------------------+
| Describe       |                  |                                  |
| circumstances  |                  |                                  |
| of the release |                  |                                  |
+----------------+------------------+----------------------------------+
| Assessment of  |                  |                                  |
| impacts and    |                  |                                  |
| remedial       |                  |                                  |
| actions        |                  |                                  |
+----------------+------------------+----------------------------------+
| Disposal       |                  |                                  |
| method for     |                  |                                  |
| recovered      |                  |                                  |
| material       |                  |                                  |
+----------------+------------------+----------------------------------+
| Action taken   |                  |                                  |
| to prevent     |                  |                                  |
| incident from  |                  |                                  |
| reoccurring    |                  |                                  |
+----------------+------------------+----------------------------------+
| Safety issues  | G Injuries       |                                  |
|                |                  |                                  |
|                | G Fatalities     |                                  |
|                |                  |                                  |
|                | G Evacuation     |                                  |
+----------------+------------------+----------------------------------+
| **N            |                  |                                  |
| otifications** |                  |                                  |
+----------------+------------------+----------------------------------+
| **Agency**     | **Name**         | **Date/time reported &           |
|                |                  | Comments**                       |
+----------------+------------------+----------------------------------+
| Company Spill  |                  |                                  |
| Response       |                  |                                  |
| Coordinator    |                  |                                  |
+----------------+------------------+----------------------------------+
| National       |                  |                                  |
| Response       |                  |                                  |
| Center         |                  |                                  |
|                |                  |                                  |
| 1-800-424-8802 |                  |                                  |
+----------------+------------------+----------------------------------+
| State police   |                  |                                  |
+----------------+------------------+----------------------------------+
| Parish         |                  |                                  |
| Emergency      |                  |                                  |
| Response       |                  |                                  |
| Commission     |                  |                                  |
+----------------+------------------+----------------------------------+
| oil spill      |                  |                                  |
| removal        |                  |                                  |
| organi         |                  |                                  |
| zation/cleanup |                  |                                  |
| contractor     |                  |                                  |
+----------------+------------------+----------------------------------+

**APPENDIX G: Equipment Shut-off Procedures**

  -----------------------------------------------------------------------
  **Source**       **Action**
  ---------------- ------------------------------------------------------
  Manifold,        Shut in the well supplying oil to the tank battery if
  transfer pumps   appropriate. Immediately close the header/manifold or
  or hose failure  appropriate valve(s). Shut off transfer pumps.

  Tank overflow    Shut in the well supplying oil to the tank battery.
                   Close header/manifold or appropriate valve(s)

  Tank failure     Shut in the well supplying oil to the tank battery.
                   Close inlet valve to the storage tanks.

  Flowline rupture Shut in the well supplying oil to the flowline. Close
                   nearest valve to the rupture site to top the flow of
                   oil.

  Flowline leak    Shut in the well supplying oil to the flowline.
                   Immediately close the nearest valve to stop the flow
                   of oil to the leaking section.

  Explosion or     Immediately evacuate personnel from the area until the
  fire             danger is over. Immediately shut in both wells if safe
                   to do so. If possible, close all manifold valves. If
                   the fire is small enough such that it is safe to do
                   so, attempt to extinguish with fire extinguishers
                   available on site.

  Equipment        Immediately close the nearest valve to stop the flow
  failure          of oil into the leaking area.
  -----------------------------------------------------------------------

**APPENDIX H: Written Commitment of Manpower,**

**Equipment, and Materials**

In addition to implementing the preventive measures described in this
Plan, Clearwater will also specifically:

11. In the event of a discharge:

-   Make available all trained field personnel (three employees) to
    perform response actions

-   Obtain assistance from an additional three full-time employees from
    its main operations contractor (Avonlea Services)

-   Collaborate fully with local, state, and federal authorities on
    response and cleanup operations

12. Maintain all on-site oil spill control equipment described in this
    Plan and in the attached Oil Spill Contingency Plan. The equipment
    is estimated to contain oil spills of up to 500 gallons.

13. Maintain all communications equipment in operating condition at all
    times.

14. Ensure that staging areas to be used in the event of a discharge to
    Big Bear Creek are accessible by field vehicles.

15. Review the adequacy of on-site and third-party response capacity
    with pre-established response/cleanup contractors on an annual basis
    and update response/cleanup contractor list as necessary.

16. Maintain formal agreements/contracts with response and cleanup
    contractors who will provide assistance in responding to an oil
    discharge and/or completing cleanup (see contract agreements
    maintained separately at the Ridgeview field office and lists of
    associated equipment and response contractor personnel
    capabilities).

Authorized Facility Representative: Bill Laurier

Signature: Bill Laurier

Title: Field Operations Manager

**APPENDIX I: Oil Spill Contingency Plan**

*The oil spill contingency plan is maintained separately at the
Ridgeview field office.*

*\[Refer to the sample Contingency Plan also available from EPA for more
information on the content and format of that Plan\]*