Number range CHAPTER **[Disclaimer - Appendix F]{.smallcaps}**

The sample Contingency Plan in Appendix F is intended to provide
examples of contingency planning as a reference when a facility
determines that the required secondary containment is impracticable,
pursuant to 40 CFR §112.7(d). The sample Contingency Plan presents a
variety of scenarios for purposes of illustration only. It 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 for a
contingency plan. Nor is the sample plan a template that must be
followed in order for the facility to be considered in compliance with
the contingency plan requirement.

**[Clearwater Oil Company]{.smallcaps}**

**[Big Bear Lease No. 2 Production Facility]{.smallcaps}**

**[Oil Spill Contingency Plan]{.smallcaps}**

**[Part I]{.smallcaps}**

**Introduction**

**1.1 Purpose and Scope**

This Oil Spill Contingency Plan is prepared in accordance with 40 CFR
112.7(d) to address areas of the facility where secondary containment is
impracticable, as documented in the facility Spill Prevention, Control,
and Countermeasure (SPCC) Plan.

> The purpose of this Oil Spill Contingency Plan ("Contingency Plan") is
> to define procedures and tactics for responding to discharges of oil
> into navigable waters or adjoining shorelines of the United States,
> originating more specifically from flowlines at Clearwater Oil Company
> ("Clearwater") Big Bear Lease No. 2 Production Facility. The
> Contingency Plan is implemented whenever a discharge of oil has
> reached, or threatens, navigable waters or adjoining shorelines.
>
> The objective of procedures described in this Contingency Plan is to
> protect the public, Clearwater personnel, and other responders during
> oil discharges. In addition, the Plan is intended to minimize damage
> to the environment, natural resources, and facility installations from
> a discharge of oil. This Oil Spill Contingency Plan complements the
> prevention and control measures presented in the facility's SPCC Plan
> by addressing areas of the facility that have inadequate secondary
> containment and impacts that may result from a discharge from these
> areas. The facility implements a detailed and stringent flowline
> maintenance program to prevent leaks from the primary system (in this
> case, piping). Areas lacking adequate containment at the Big Bear
> Lease No. 2 Production Facility include the flowlines that run between
> the extraction wells and the tank battery area and between the tank
> battery area and the saltwater disposal area.
>
> This Oil Spill Contingency Plan follows the content and organization
> of 40 CFR part 109 and describes the distribution of responsibilities
> and basic procedures for responding to an oil discharge and performing
> cleanup operations.

**1.2 Resources at Risk**

Clearwater's Big Bear Lease No. 2 Production Facility is located
approximately 6 miles North of Madison, LA, within the Mines River
watershed (see Figure C-1 in Appendix C). The waterways closest to the
facility are Big Bear Creek, which flows approximately ½ mile to the
east of the facility, and the Mines River, which flows 6 miles to the
south in a west-to-east direction and receives water from Big Bear
Creek. The facility diagram included in Appendix C (Figure C-2)
indicates the location of the oil extraction, production, and storage
areas. Ground cover at the facility consists of compacted soil, gravel,
and low lying vegetation. The natural topography of the land is graded
in an east-southeast direction, and all surface drainage from the
facility therefore flows towards Big Bear Creek. The slope is relatively
mild: approximately 4 feet vertical per mile (5,280 feet) horizontal.

> Three flowlines (which contain oil) at the facility lack adequate
> secondary containment (see Figure C-2):

-   **Flowline A.** The flowline from Well A to the tank battery (FLA)
    is approximately 2,100 feet long. It runs aboveground in a
    north-south direction to the tank battery area.

-   **Flowline B.** The flowline between Well B and the tank battery
    (FLB) is approximately 3,400 feet long. It travels in a southwest
    direction to the tank battery area. This flowline runs the closest
    to navigable waters. At the closest point, the flowline is located ½
    mile from Big Bear Creek.

-   **Flowline SWD.** The flowline between the tank battery and the
    saltwater disposal well is approximately 2,000 feet long. It runs in
    an east-west direction.

> All three flowlines are aboveground, with the exception of a short
> portion of Flowline B that is buried under the dirt/gravel access
> road. A drainage ditch runs along the access road to the east of the
> tank battery and along Route 417. The ditch flows into Big Bear Creek.
> Given the direction of surface drainage, a discharge from any of the
> three flowlines could reach Big Bear Creek, either directly or via the
> drainage ditch, and from there, flow southward to the Mines River.
>
> Neither Big Bear Creek nor the Mines River is used as a public
> drinking water supply, although animals grazing on the nearby land are
> often seen drinking from Big Bear Creek and the Howard Fleming Farm
> has an agricultural irrigation intake on Big Bear Creek (see the
> Notification Form later in this Plan for contact information). The two
> waterways, however, provide habitat for a number of aquatic species
> and mammals and are used by local residents for recreational purposes.
> The Mines River runs through the center of Madison. Recreational and
> scenic areas are located on both banks of the river. A public park is
> located approximately 1 mile east from the town center and 8 miles
> from the facility. Recreational uses on the Mines River include picnic
> areas, walking trails, canoeing, and nature watching.
>
> There are no residences within the immediate vicinity of the facility.
> The closest residence is located 1 mile to the north of the site,
> upstream on Big Bear Creek. The closest residence downstream from the
> site is located 3 miles away. Both residences have private drinking
> water wells. Clearwater will coordinate with the Madison fire and/or
> police departments and with its residential neighbors to provide the
> appropriate warnings in the event of a discharge that could affect
> public health and safety.

**1.3 Risk Assessment**

> The facility is comprised of approximately 7,500 feet of 2-inch
> diameter flowlines. With the exception of a short road crossing, the
> flowlines are located aboveground. The flowlines do not have secondary
> containment, since such containment is impracticable at this facility
> (see discussion on impracticability of secondary containment in the
> facility's SPCC Plan).

The total daily production rate at the facility varies, but can reach as
much as 1,260 gallons of crude oil and 5,880 gallons of produced water.
The two wells have approximately equal production rates (each 3,570
gallons per day). Flowline B, the longest of the three flowlines and the
one closest to navigable waters, contains up to 555 gallons of oil/water
when charged. The facility is visited daily. For planning purposes, the
worst-case discharge is therefore the volume of oil within the flowline
plus 24 hours of production, or 4,125 gallons.

> A discharge of this quantity of oil could potentially reach Big Bear
> Creek. The velocity of oil over land is estimated, based on past
> experience and a simple calculation of flow over short grass
> pastureland, at approximately 0.2 feet/second.[^1] Considering the
> distance between Flowline B and Big Bear Creek (½ mile) and the 2-foot
> elevation gradient, the oil, if unimpeded, could reach Big Bear Creek
> in as little as 4 hours. The water current in Big Bear Creek averages
> approximately 0.3 feet/second during high stages. Over a 24-hour
> period, the oil could travel approximately 5 miles downstream from the
> release point. The Mines River, which is located only 6 miles
> downstream to the south of the tank battery area, could therefore
> possibly be affected by a discharge.

**1.4 Response Strategy**

> Clearwater personnel and contractors are equipped and trained to
> respond to certain "minor discharges" confined within the facility.
> Minor discharges can generally be described as those where the
> quantity of product discharged is small, the discharged material can
> be easily stopped and controlled, the discharge is localized, and the
> product is not likely to seep into groundwater or reach surface water
> or adjoining shorelines. Procedures for responding to these minor
> discharges are covered in the SPCC Plan.
>
> This Contingency Plan addresses all discharge incidents, including
> those that affect navigable waters or during which the oil cannot be
> safely controlled by facility personnel and confined within the
> boundaries of the facility. Response to such incidents may necessitate
> the assistance of outside contractors or other responders to prevent
> imminent impact to navigable waters.

**[Part II]{.smallcaps}**

**Spill Discovery and Response**

**2.1 Distribution of Responsibilities**

Clearwater has the primary responsibility for providing the initial
response to oil discharge incidents originating from its facility. To
accomplish this, Clearwater has designated the Field Operations Manager,
Bill Laurier, as the qualified oil discharge Response Coordinator (RC)
in the event of an oil discharge.

> The RC plays a central coordinating role in any emergency situation,
> as illustrated in the emergency organization chart in Figure 2-1.

The RC has the authority to commit the necessary services and equipment
to respond to the discharge and to request assistance from Madison fire
and/or police departments, contractors, or other responders, as
appropriate.

> The RC will direct notifications and initial response actions in
> accordance with training and capabilities. In the event of a fire or
> emergency situation that threatens the health and safety of those
> present at the site, the RC will direct evacuations and contact the
> fire and police departments.
>
> In the event of an emergency involving outside response agencies, the
> RC's primary responsibility is to provide information regarding the
> characteristics of the materials and equipment involved and to provide
> access to Clearwater resources as requested. The RC shall also take
> necessary measures to control the flow of people, emergency equipment,
> and supplies and obtain the support of the Madison Police Department
> as needed to maintain control of the site. These controls may be
> necessary to minimize injuries and confusion.
>
> Finally, the RC serves as the coordinator for radio communications by
> acquiring all essential information and ensuring clear communication
> of information to emergency response personnel. The RC has access to
> reference material at the field office either as printed material or
> on computer files that can further assist the response activities.
>
> Whenever circumstances permit, the RC transmits assessments and
> recommendations to Clearwater Senior Management for direction. Senior
> Management is contacted in the following order: (1) Regional Director
> of Operations; (2) Vice-President of Operations.
>
> In the event that the Field Operations Manager is not available, the
> responsibility and authority for initiating a response to a discharge
> rests with the most senior Clearwater employee on site at the time the
> discharge is discovered (Crew Lead) or with the contractor Field
> Supervisor (or next person in command) if contractor personnel are the
> only personnel on site.

**2.2 Response Activities**

In the event of a discharge, the first priority is to stop the product
flow and to shut off all ignition sources, followed by the containment,
control, and mitigation of the discharge. This Contingency Plan breaks
actions to be performed to respond to an oil discharge into different
phases, described in greater detail in the checklists below.

**2.2.1 Discharge Discovery and Source Control**

> **Minor Discharge.** A minor discharge (i.e., small volume leak from
> flowlines or other equipment) will be discovered by Clearwater
> facility personnel or by contractor personnel during scheduled daily
> or monthly visits to the facility. Aboveground flowlines are visually
> inspected formally once a month during the normal inspection rounds.
>
> **Major Discharge.** A more severe and sudden discharge will trigger
> the automatic shut down of the pumping units and will affect oil
> production. The impact will be detected during the daily visit to the
> production area by Clearwater or contractor field personnel. The
> maximum amount of time until a major discharge is detected can be up
> to 24 hours.
>
> Notifications to the National Response Center, Louisiana authorities,
> and St. Anthony's Parish Emergency Committee must occur immediately
> upon discovery of reportable discharges.

+--------+-------------------------------------------------------------+
| *      | **Actions**                                                 |
| *Compl |                                                             |
| eted** |                                                             |
+========+=============================================================+
|        | Immediately report the discharge to the RC, providing the   |
|        | following information:                                      |
|        |                                                             |
|        | 1.  Exact location;                                         |
|        |                                                             |
|        | 2.  Material involved;                                      |
|        |                                                             |
|        | 3.  Quantity involved;                                      |
|        |                                                             |
|        | 4.  Topographic and environmental conditions;               |
|        |                                                             |
|        | 5.  Circumstances that may hinder response; and             |
|        |                                                             |
|        | 6.  Injuries, if any.                                       |
+--------+-------------------------------------------------------------+
|        | Turn off all sources of ignition.                           |
+--------+-------------------------------------------------------------+
|        | Turn off lift pumps that charge or provide flow to the      |
|        | flowline.                                                   |
+--------+-------------------------------------------------------------+
|        | Locate the flowline break.                                  |
+--------+-------------------------------------------------------------+
|        | If safe to do so, isolate the affected section of piping by |
|        | closing off the closest valves upstream and downstream from |
|        | the break.                                                  |
+--------+-------------------------------------------------------------+

**2.2.2 Assessment and Notifications**

+--------+-------------------------------------------------------------+
| *      | **Actions**                                                 |
| *Compl |                                                             |
| eted** |                                                             |
+========+=============================================================+
|        | Investigate the discharge to assess the actual or potential |
|        | threat to human health or the environment:                  |
|        |                                                             |
|        | 7.  Location of the discharge relative to receiving         |
|        |     waterbodies;                                            |
|        |                                                             |
|        | 8.  Quantity of spilled material;                           |
|        |                                                             |
|        | 9.  Ambient conditions (temperature, rain);                 |
|        |                                                             |
|        | 10. Other contributing factors such as fire or explosion    |
|        |     hazards; and                                            |
|        |                                                             |
|        | 11. Sensitive receptors downstream.                         |
+--------+-------------------------------------------------------------+
|        | Request outside assistance from local emergency responders, |
|        | as needed.                                                  |
+--------+-------------------------------------------------------------+
|        | Evaluate the need to evacuate facility and evacuate         |
|        | employees, as needed.                                       |
+--------+-------------------------------------------------------------+
|        | Notify the fire/police departments and St. Anthony's Parish |
|        | Emergency Committee to assess whether community evacuation  |
|        | is needed.                                                  |
+--------+-------------------------------------------------------------+
|        | Notify immediately:                                         |
|        |                                                             |
|        | 1.  911                                                     |
|        |                                                             |
|        | 2.  National Response Center                                |
|        |                                                             |
|        | 3.  Response contractor(s)                                  |
|        |                                                             |
|        | 4.  St. Anthony's Parish Emergency Planning Committee       |
|        |                                                             |
|        | 5.  State authorities                                       |
+--------+-------------------------------------------------------------+
|        | Communicate with neighboring property owners regarding the  |
|        | discharge and actions taken to mitigate the damage.         |
+--------+-------------------------------------------------------------+
|        | If the oil reaches (or threatens to reach) the Mines River, |
|        | notify the local fire/police departments to limit access to |
|        | the River by local residents until the oil has been         |
|        | contained and recovered.                                    |
|        |                                                             |
|        | Additionally, notify downstream water users of the spill    |
|        | and of actions that will be taken to protect these          |
|        | downstream receptors.                                       |
+--------+-------------------------------------------------------------+

**2.2.3 Control and Recovery**

> The RC directs the initial control of the oil flow by Clearwater,
> Avonlea Oil Services, and other contractor personnel. The actions
> taken will depend on whether the oil has reached water or is still on
> land. All effort will be made to prevent oil from reaching water.

**If the oil has not yet reached water:**

  -----------------------------------------------------------------------------
  **Completed**   **Actions**
  --------------- -------------------------------------------------------------
                  Deploy sand bags and absorbent socks downgradient from the
                  oil, or erect temporary barriers such as trenches or mounds
                  to prevent the oil from flowing towards Big Bear Creek.

                  Implement land based response actions (countermeasure) such
                  as digging temporary containment pits, ponds, or curbs to
                  prevent the flow of oil into the river.

                  Deploy absorbent sock and sorbent material along the
                  shoreline to prevent oil from entering waters.
  -----------------------------------------------------------------------------

**If the oil has reached water:**

  -----------------------------------------------------------------------------
  **Completed**   **Actions**
  --------------- -------------------------------------------------------------
                  Contact cleanup contractor(s).

                  Deploy floating booms immediately downstream from the release
                  point. Big Bear Creek is narrow and shallow. Floating boom
                  deployment does not require the use of a boat.

                  Control oil flow on the ground by placing absorbent socks and
                  other sorbent material or physical barriers (e.g., "kitty
                  litter," sandbags, earthen berm, trenches) across the oil
                  flow path.

                  Deploy additional floating booms across the whole width of
                  the Creek at the next access point downstream from the
                  release point. Access points and staging areas along the
                  shoreline are identified on Figure C-1 of this Contingency
                  Plan.

                  Deploy protective booming measures for downstream receptors
                  that may be impacted by the spill.
  -----------------------------------------------------------------------------

**2.2.4 Disposal of Recovered Product and Contaminated Response
Material**

> The RC ensures that all contaminated materials classified as hazardous
> waste are disposed of in accordance with all applicable solid and
> hazardous waste regulations.

  --------------- -------------------------------------------------------------
  **Completed**   **Actions**

                  Place any recovered product that can be recycled into the gun
                  barrel tank to be separated and recycled.

                  Dispose of recovered product not suitable for on-site
                  recycling with the rest of the waste collected during the
                  response efforts.

                  Collect all debris in properly labeled waste containers
                  (impervious bags, drums, or buckets).

                  Dispose of contaminated material in accordance with all
                  applicable solid and hazardous waste regulations using a
                  licensed waste hauler and disposal facility, after
                  appropriately characterizing the material for collection and
                  disposal.

                  Dispose of all contaminated response material within 2 weeks
                  of the discharge.
  --------------- -------------------------------------------------------------

**2.2.5 Termination**

> The RC ensures that cleanup has been completed and that the
> contaminated area has been treated or mitigated according to the
> applicable regulations and state/federal cleanup action levels. The RC
> collaborates with the local, state and federal authorities regarding
> the assessment of damages.

+--------+-------------------------------------------------------------+
| *      | **Actions**                                                 |
| *Compl |                                                             |
| eted** |                                                             |
+========+=============================================================+
|        | Ensure that all repairs to the defective equipment or       |
|        | flowline section have been completed.                       |
+--------+-------------------------------------------------------------+
|        | Review circumstances that led to the discharge and take all |
|        | necessary precautions to prevent a recurrence.              |
+--------+-------------------------------------------------------------+
|        | Evaluate the effectiveness of the response activities and   |
|        | make adjustments as necessary to response procedures and    |
|        | personnel training.                                         |
+--------+-------------------------------------------------------------+
|        | Carry out personnel and contractor debriefings as necessary |
|        | to emphasize prevention measures or to communicate changes  |
|        | in operations or response procedures.                       |
+--------+-------------------------------------------------------------+
|        | Submit any required follow-up reports to the authorities.   |
|        |                                                             |
|        | *40 CFR 112.4(a)*In the case where the discharge (as        |
|        | defined in 40 CFR 112.1(b)) was greater than 1,000 gallons  |
|        | or was the second discharge (as defined in 40 CFR 112.1(b)) |
|        | of 42 gallons or more within any 12-month period, the RC is |
|        | responsible for submitting the required information within  |
|        | 60 days to the EPA Regional Administrator following the     |
|        | procedures outlined in Appendix B.                          |
|        |                                                             |
|        | Within 30 days of the discharge, the RC will convene an     |
|        | incident critique including all appropriate persons that    |
|        | responded to the spill. The goal of the incident critique   |
|        | is to discuss lessons learned, the efficacy of the          |
|        | Contingency Plan and its implementation, and coordination   |
|        | of the plan/RC and other state and local plans.             |
|        |                                                             |
|        | Within 60 days of the critique, the Contingency Plan will   |
|        | be updated (as needed) to incorporate the results,          |
|        | findings, and suggestions developed during the critique.    |
+--------+-------------------------------------------------------------+

**2.3 Discharge Notification**

Instructions and phone numbers for reporting a discharge to the National
Response Center and other federal, state, and local authorities are
provided in Appendix B to this Plan. *Any discharge to water must be
reported immediately to the National Response Center.* The Response
Coordinator must ensure that details of the discharge are recorded on
the Discharge Notification Form provided in Appendix B.

> If the discharge qualifies under 40 CFR part 112 (see Appendix B for
> conditions), the RC is responsible for ensuring that all pertinent
> information is provided to the EPA Regional Administrator.

**[Part III]{.smallcaps}**

**Response Resources and Preparedness Activities**

**3.1 Equipment, Supplies, Services, and Manpower**

Spill kits are provided in a storage shed at the production site that is
accessible by both Clearwater and Avonlea personnel (see Figure C-2 in
Appendix C). Response equipment and material present at the site
include:

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

1.  50-ft absorbent socks

2.  10-ft sections of hard skirted deployment boom

3.  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

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

> This material is sufficient to respond to most minor discharges
> occurring at the facility and to initially contain a major discharge
> while waiting for additional material or support from outside
> contractors. The inventory is verified on a monthly basis during the
> scheduled facility inspection by designated personnel and is
> replenished as needed.
>
> Additional material and equipment is kept at Clearwater's field
> office, located 25 miles from the facility. This additional material
> includes empty storage drums, absorbent socks and booms, containment
> booms, sand bags, personal protective gear, etc. It also includes all
> necessary communication equipment to coordinate response activities
> (cell phones, two-way radios). The Field Office serves as the response
> operation center during a response.

Clearwater has three employees trained and available to respond to an
oil discharge. Clearwater personnel may be assisted by three additional
employees from the facility's main contractor, Avonlea Oil Services. All
employees are familiar with the facility layout, location of spill
response equipment and staging areas, and response strategies, and with
the SPCC and Oil Spill Contingency Plans for this facility. All have
received training in the deployment of response material and handling of
hazardous waste (HAZWOPER) and have attended the required refresher
courses.

To respond to larger discharges and ensure the removal and disposal of
cleanup debris, Clearwater has established agreements with two
specialized cleanup contractors: EZClean and Armadillo Oil Removal, with
EZClean contacted first and acting as the primary response/cleanup
contractor and Armadillo Oil Removal acting as the alternate or in a
supporting role. Contact information is provided in Appendix A. These
contractors have immediate access to an assortment of equipment and
materials, including mechanical recovery equipment for use on water and
on land, small boats, floating booms, and large waste containers. Each
contractor has sufficient response equipment to contain and recover the
maximum possible discharge of 4,125 gallons. EZClean and Armadillo Oil
Removal are able to respond *within 4 hours* of receiving a verbal
request from the RC. Clearwater discusses response capacity needs on an
annual basis with each contractor to ensure that sufficient equipment
and material are available to respond to a potential 4,125-gallon
discharge. The inventories of EZClean and Armadillo Oil Removal
equipment are maintained with the response agreements and updated
annually.

**3.2 Access to Receiving Waterbody**

![](media/image3.wmf){width="2.25in" height="2.342361111111111in"}

Big Bear Creek would be the first waterbody affected in the event of a
discharge. From there, the oil would flow into the Mines River. The
response strategy consists of: (1) deploying booms and other response
equipment at various points downstream from the oil plume to prevent its
migration; and (2) deploying booms as a protective measure for an
irrigation water intake and other downstream sensitive receptors.

> Vehicular access to Big Bear Creek is essential to ensure that the
> response equipment can be effectively deployed to contain oil at
> various points along the waterway and prevent further migration of the
> oil

towards the Mines River.

![](media/image4.wmf){width="2.25in" height="1.5541666666666667in"}

> Three access points have been established along Big
>
> Bear Creek and are marked on the map in Figure C-1 (BB1, BB2, and
> BB3). These access points provide sufficient cleared land for a
> staging area from which Clearwater or contractor personnel can deploy
> response equipment, and recover and store spilled oil. Twice a year,
> as part of the monthly inspection of the facility, Clearwater facility
> personnel drive to each access point and make sure that it remains
>
> accessible (e.g., vegetation is not overgrown and the dirt trail is
> not impassable for a field vehicle). The respective property owners
> have agreed to allow access to Clearwater's personnel and contractors
> for response and maintenance purposes. Although no further approval is
> needed prior to the deployment of response equipment, the RC will
> contact the property owners as necessary to inform them of activities
> being carried out.
>
> If necessary, three access points are also available along the Mines
> River. One is located in the center of Madison, at the bridge crossing
> for Route 101, the second is located at the public park two miles
> downstream from the center, and the third one is located at the bridge
> crossing for Route 54, four miles downstream from the center.
> Coordination with the Madison police/fire departments is necessary to
> stage equipment at these three access points.

**3.3 Communications and Control**

A central coordination center will be set up at the field office in the
event of a discharge. The field office is equipped with a variety of
fixed and mobile communication equipment (telephone, fax, cell phones,
two-way radios, computers) to ensure continuous communication with
Clearwater management, responders, authorities, and other interested
parties.

> Communications equipment includes:

1.  **Portable hand-held radios.** Clearwater maintains a two-way base
    station and four portable radio units. These radio units are kept at
    the field office as part of the response equipment. Local emergency
    responders have been provided with the response frequencies that
    will be used during an incident.

2.  **Cell phones.** Each field vehicle and the RC are provided with a
    cell phone. The RC and/or his alternate (Site Supervisor when the
    Field Operations Manager is not "on call") can be reached by cell
    phone 7 days a week, 24 hours a day.

3.  **Additional equipment.** Additional equipment will be obtained from
    EZClean and/or Armadillo Oil Removal in the event that more
    communications equipment is necessary.

> The RC is responsible for communicating the status of the response
> operations and for sharing relevant information with involved parties,
> including local, state, and federal authorities.
>
> In the event that local response agencies, Louisiana authorities, or a
> federal On Site Coordinator (OSC) assumes Incident Command, the RC
> will function as the facility representative in the Unified Command
> structure.

**3.4 Training Exercises and Updating Procedures**

Clearwater has established and maintains an ongoing training program to
ensure that Clearwater personnel responding to oil discharges are
properly trained and that all necessary equipment is available to them.
The program includes on-the-job training on the proper deployment of
response equipment and periodic practice drills during which Clearwater
personnel are asked to deploy equipment and material in response to a
simulated discharge. The RC is responsible for implementing and
evaluating employee preparedness training.

> Following a response to an oil discharge, the RC will evaluate the
> actions taken and identify procedural areas where improvements are
> needed. The RC will conduct a briefing with field personnel,
> contractors, and local emergency responders to discuss lessons learned
> and will integrate the outcome of the discussion in subsequent SPCC
> briefings and employee training seminars. As necessary, the RC will
> amend this Contingency Plan or the SPCC Plan to reflect changes made
> to the facility equipment and procedures. A Professional Engineer will
> certify any technical amendment to the SPCC Plan.

**[APPENDIX A]{.smallcaps}**

**[Emergency Contacts]{.smallcaps}**

**Facility Operations**

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

**Local Emergency Responders**

+-------------------+-------------+------------------------------------+
| **Name**          | **          | **Address**                        |
|                   | Telephone** |                                    |
+-------------------+-------------+------------------------------------+
| Fire/Police       | 911         | 2451 Mountain Drive, Madison, LA   |
| Departments       |             | 70180                              |
|                   | \(405\)     |                                    |
|                   | 830-2000    |                                    |
+-------------------+-------------+------------------------------------+
| Emerson Hospital  | \(405\)     | 13000 Main Street, Madison, LA     |
|                   | 831-9558    | 70180                              |
+-------------------+-------------+------------------------------------+

**Cleanup Contractors**

  ------------------- --------------- ------------------------------------
  **Name**            **Telephone**   **Address**

  EZClean             \(800\)         1200 Industry Park Drive, Gardner,
                      521-3211        LA 70180

  Armadillo Oil       \(214\)         25 B Street, Suite #6, Madison, LA
  Removal             566-5588        70180
  ------------------- --------------- ------------------------------------

**Neighboring Property Owners**

  --------------- --------------- -------------------------------- --------------
  **Name**        **Telephone**   **Address**                      **Location**

  Maurice Richard \(405\)         5540 Route 417, Madison, LA      BB1
                  830-2186        70180                            

  Jim Larouche    \(405\)         6075 Greenfield Drive, Madison,  BB2
                  832-2645        LA 70180                         

  Peter Martin    \(405\)         1644 Oilfield Road, Madison, LA  BB3
                  832-5527        70180                            

  Howard Fleming  \(405\)         531 Horseshoe Road, Madison, LA  
                  235-6893        70180                            
  --------------- --------------- -------------------------------- --------------

**[Appendix B]{.smallcaps}**

**[Discharge Notification Procedures]{.smallcaps}**

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 occurs beyond |                 |
| Planning      |             | the boundaries of  | Written         |
| Committee     |             | the facility,      | notification    |
|               |             | including to the   | within 7 days.  |
|               |             | air.               |                 |
+---------------+-------------+--------------------+-----------------+
| *Others*      |             |                    |                 |
+---------------+-------------+--------------------+-----------------+
| Res           | EZClean     | Any discharge that | As needed       |
| ponse/cleanup |             | exceeds the        |                 |
| contractors   | \(800\)     | capacity of        |                 |
|               | 521-3211    | facility personnel |                 |
|               |             | to respond and     |                 |
|               | Armadillo   | clean up.          |                 |
|               | 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.           |                 |
+---------------+-------------+--------------------+-----------------+
| Maurice       | 4           | When deploying     | As needed       |
| Richard       | 05-830-2186 | response equipment |                 |
|               |             | from Access Point  |                 |
|               |             | BB1 on Big Bear    |                 |
|               |             | Creek.             |                 |
+---------------+-------------+--------------------+-----------------+
| Jim Larouche  | 4           | When deploying     | As needed       |
|               | 05-832-2645 | response equipment |                 |
|               |             | from Access Point  |                 |
|               |             | BB2 on Big Bear    |                 |
|               |             | Creek.             |                 |
+---------------+-------------+--------------------+-----------------+
| Peter Martin  | 4           | When deploying     | As needed       |
|               | 05-832-5527 | response equipment |                 |
|               |             | from Access Point  |                 |
|               |             | BB3 on Big Bear    |                 |
|               |             | Creek.             |                 |
+---------------+-------------+--------------------+-----------------+

The person reporting the discharge must provide the following
information:

1.  Name, location, organization, and telephone number

2.  Name and address of the owner/operator

3.  Date and time of the incident

4.  Location of the incident

5.  Source and cause of discharge

6.  Types of material(s) discharged

7.  Total quantity of materials discharged

8.  Quantity discharged in harmful quantity (to navigable waters or
    adjoining shorelines)

9.  Danger or threat posed by the release or discharge

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

11. Number and types of injuries (if any) and damaged caused

12. Weather conditions

13. Actions used to stop, remove, and mitigate effects of the discharge

14. Whether an evacuation is needed

15. Name of individuals and/or organizations contacted

16. 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:

1.  Name of the facility

2.  Name of the owner or operator

3.  Location of the facility

4.  Maximum storage or handling capacity and normal daily throughput

5.  Corrective actions and countermeasures taken, including a
    description of equipment repairs and replacements

6.  Description of facility, including maps, flow diagrams, and
    topographical maps

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

8.  Additional preventive measures taken or contemplated to minimize
    possibility of recurrence

9.  Other pertinent information requested by the Regional Administrator.

**Discharge Notification Form**

\*\*\* Notification must not be delayed if information or individuals
are not available. Additional pages may be attached to supplement
information contained in the form.

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:            | Tel. #:                          |
| Individual     |                  |                                  |
+----------------+------------------+----------------------------------+
| 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     |                  |                                  |
+----------------+------------------+----------------------------------+
| OSRO/cleanup   |                  |                                  |
| contractor     |                  |                                  |
+----------------+------------------+----------------------------------+

**Appendix C**

**[Site Plan and Facility Diagram]{.smallcaps}**

**Figure C-1**: Site Plan (pre-designated staging areas are indicated).

  ----------- ------------------------------------- -----------------------
  **Staging   **Location**                          **Contact Information**
  area**                                            

  BB1         5540 Route 417, Madison, LA (access   Maurice Richard;
              from path to the right of the storage 405-830-2186
              shed).                                

  BB2         6075 Greenfield Drive, Madison, LA.   Jim Larouche;
                                                    405-832-2645

  BB3         1644 Oilfield Road, Madison, LA       Peter Martin;
                                                    405-832-5527
  ----------- ------------------------------------- -----------------------

[^1]: ^?^ Calculated using sheet flow transport equations.