Greater Natural Buttes 

Draft 

Environmental Impact Statement

DES 10-31
 

Volume II 

(Appendices) 

Bureau of Land Management 

Vernal Field Office/Utah 

July 2010 
BLM Mission Statement 

The Bureau of Land Management is responsible for the stewardship of our public lands. It is 

committed to manage, protect, and improve these lands in a manner to serve the needs of the 

American people for all times. 

Management is based upon the principles of multiple use and sustained yield of our nation’s 

resources within a framework of environmental responsibility and scientific technology. These 

resources include recreation, rangelands, timber, minerals, watershed, fish and wildlife, wilderness, 

air and scenic, scientific, and cultural values. 
vii

 

List of Appendices 

Appendix A – Applicant-Committed Environmental Protection Measures 

Appendix B – Interdisciplinary Team Analysis Record Checklist 

Appendix C – Transportation Plan 

Appendix D – Example Spill Prevention Control and Countermeasures Plan 

Appendix E – Reclamation Plan 

Appendix F – Soil Mapping Data 

Appendix G – Air Quality Technical Support Document 

Appendix H – Special Status Species List 

Appendix I – Migratory Bird Species List 

Appendix J – Integrated Weed Management Plan 

Appendix K – Range Improvement Specifications and Design Drawings 

Appendix L – BLM and USFWS Clay Reed-mustard and Uinta Basin Hookless Cactus Conservation Measures 

Appendix M – Graham’s Beardtongue Conservation Measures 

DEIS July 2010 
Appendix A 

Applicant-Committed Environmental Protection Measures 

DEIS 

July 2010 
 

 

Appendix A 

Applicant-Committed Environmental Protection Measures
 

Topic(s) Applicant-Committed Measures 

Surface Disturbance KMG would utilize shared well pads to the extent possible, in consideration of technical, 

environmental, and economic viability, to minimize the amount of total surface 

disturbance in the GNBPA. 

Surface Disturbance KMG would develop a Transportation Plan that will detail the procedures intended to 

minimize construction of roads needed to implement Project activities. KMG’s 

Transportation Plan would include construction procedures to prevent/minimize 

sedimentation that may result from road and/or pad construction. KMG would submit the 

plan to the BLM prior to the initiation of Project activities. 

Surface Disturbance Each new produced water disposal well would be located on existing production 

locations. 

Surface Disturbance KMG would evaluate deepening existing wells to accomplish Mesaverde-only 

completions before twinning an existing well. 

Surface Disturbance KMG would strive to continually improve the development processes in order in minimize 

the surface impact where practical. 

Cultural Resources A Class III archeological survey has been conducted on all federal and/or tribal lands in 

the GNBPA. All personnel would refrain from collecting artifacts and from disturbing any 

significant cultural resources in the area. KMG would be responsible for informing all 

persons in the area who are associated with this Project that they may be subject to 

prosecution for knowingly disturbing historic or archaeological sites or for collecting 

artifacts. All vehicular traffic, personnel movement, construction, and restoration activities 

would be confined to the areas examined, as referenced in the archaeological report, and 

to the existing roadways and/or evaluated access routes. If historic or archaeological 

materials were to be uncovered during construction, KMG would immediately stop 

surface disturbing activities that might further disturb such materials and contact the 

appropriate AO. 

Paleontological 

Resources 

KMG would conduct a paleontological survey on all of its federal, state, and tribal 

locations. All personnel would refrain from collecting fossils and from disturbing any 

significant fossil in the GNBPA. If fossils were to be uncovered during construction, KMG 

would immediately stop surface disturbing activities that might further disturb such 

materials and contact the appropriate AO. 

Vegetation / Noxious 

and Invasive Species 

KMG would develop a Pesticide/Herbicide Use Plan for submission to the BLM and State 

of Utah prior to the initiation of Project activities. 

Vegetation / Noxious 

and Invasive Species 

In accordance with the procedures described in its Pesticide/ Herbicide Use Plan, KMG 

would monitor for the growth of invasive species resulting from surface disturbance 

caused by Project activities and would control weeds caused by Project activities. 

Vegetation / Noxious 

and Invasive Species 

KMG would use its best efforts to control noxious weeds along access road 

authorizations, pipeline route authorizations, well sites, or other proposed facilities by 

spraying or mechanical removal. A list of noxious weeds would be obtained from the BLM 

or the appropriate County Extension Office. On BLM-administered land, a Pesticide Use 

Proposal would be submitted and approved prior to the application of herbicides or other 

pesticides or possibly hazardous chemicals. 

Sedimentation, Erosion, 

and Stormwater Runoff 

KMG would employ industry best management practices to control stormwater runoff, 

including appropriate measures to prevent disturbed sediments from reaching the White 

River drainage during precipitation events. 

DEIS A-1 July 2010 
 

 

Appendix A (Continued) 

Topic(s) Applicant-Committed Measures 

Raptors KMG would adhere to seasonal and spatial buffers applicable to occupied raptor nests in 

the GNBPA in consideration of guidelines developed by the Utah Division of Wildlife 

Resources and the USFWS. 

Migratory Birds KMG would install bird-excluding devices that prevent the perching and entry of migratory 

birds on or into its new fired vessel exhaust stacks. In addition, KMG completed 

retrofitting approximately 1,014 existing exhaust stacks in 2007. 

Sage Grouse Protection KMG would utilize low-profile tanks in areas where sage grouse leks are determined to 

be active to minimize the opportunities for raptor perching. 

Sage Grouse Protection No surface-disturbing activities would be allowed year-round within 1⁄4-mile of active 

Sage-grouse leks. 

Pipeline Construction KMG would utilize the applicable USFWS’ Best Management Practices for work in Utah 

streams where pipelines or roads cross a stream. Additionally, KMG would utilize BLM 

Hydraulic Considerations for Pipeline Crossings of Stream Channels (prepared by the 

Utah State Office BLM, Salt Lake City, Utah). 

Water Use KMG would attempt to maximize the use of produced water for completion purposes. 

Water Quality/ 

Soils 

KMG would position two 15-foot emergency response spill trailers in areas in or near the 

GNBPA to respond to accidental spills or releases. At least one of the trailers would be 

located at a drilling site near the White River, if necessary. Each trailer would be 

equipped with 300 feet of 10-inch Techniboom, tow bridles, and anchor sets. In addition, 

the trailers contain sorbent pads, sorbent booms, flash lights, life jackets, Tyvek suits and 

other safety equipment. KMG has conducted training sessions that included two days of 

instruction and field exercises with 15 field employees. The training was conducted by the 

Texas Engineering Extension Service Emergency Services Training Institute. 

Air Quality KMG would use water or other BLM-approved dust suppression during drilling and 

completion operations for dust abatement on access roads, as needed. KMG would use 

water or other BLM-approved dust suppression in high traffic areas during production 

operations for dust abatement, as needed. 

Air Quality KMG employees would comply with speed limits on unpaved county roads used for 

access and would use safe vehicle speeds on other access unpaved roads. 

Air Quality KMG would use zero emission dehydrators at existing and future compressor stations 

and production wells. 

Air Quality KMG would utilize electricity to power at least 50 percent of its compressor stations. 

Air Quality KMG would install vapor recovery systems to capture volatile organic compounds 

emissions associated with production tanks with the potential to emit more than 20 tpy 

VOCs. 

Air Quality KMG would install low-bleed pneumatic devices at existing and future compressor 

stations and production wells. 

Air Quality KMG would use green completions for all completion activities under their project. 

Air Quality KMG would phase in the use of Tier 2 drill rig engines by 2012. 

Air Quality KMG would use lean burn natural gas fired stationary engines for the project. 

Air Quality KMG would use an oxidation catalyst on all natural gas fired engines to reduce the 

emission of CO and VOCs. 

Wilderness 

Characteristics 

KMG would not disturb the surface for Project activities in NENW Section 22, T10SR23E. 

DEIS A-2 July 2010 
 

 

 

Appendix A (Continued) 

Topic(s) Applicant-Committed Measures 

Wildlife Installation of raptor perch deterrents. 

In order to minimize potential of electrocution mortality of raptors, KMG would utilize 

methods and designs described in Suggested Practices for Raptor Protection on Power 

Lines (APLIC 2006) and in Mitigating Bird Collisions with Power Lines (APLIC 1994) 

during construction, operation, and maintenance of power lines. 

Surface Disturbance Burying of distribution pipelines and/or flow lines in or adjacent to access roads. 

KMG would evaluate burying pipelines after site-specific evaluation of surface and 

subsurface conditions with consideration to the materials that would be transported 

through the pipelines. KMG proposes to bury approximately 10 miles of pipelines 

transporting produced water and 25 miles of gas-transportation pipelines. In areas where 

there is sufficient soil to excavate and after consultation with the BLM AO, KMG would 

consider burying well gathering lines adjacent to access roads.1 

Transportation Centralizing production facilities. 

Project wells would utilize centralized compression facilities. The proposed use of 

telemetry would reduce the frequency of well visits and therefore decrease vehicle traffic 

within the GNBPA, one objective of combining production facilities. 

Surface Disturbance Drilling multiple wells from a single pad. 

KMG would carefully evaluate drilling multiple wells from a single pad on an ongoing 

basis and has included the potential to use multiple wells from a shared pad in the 

GNBPA to the extent that KMG determines technically and economically viable. 2 

Wildlife Wildlife monitoring. 

KMG would enter into discussions with the BLM to determine how, when and for what 

species wildlife monitoring may be implemented. KMG would participate in industry 

groups and projects to support efforts to reduce impacts to wildlife that may result from oil 

and gas activities in the GNBPA. KMG would enter into discussions with the BLM to 

mutually investigate possibilities for voluntary offsite mitigation measures for wildlife 

habitat enhancement after evaluation of the effectiveness of onsite mitigation, including 

best management practices. 

Public Safety 

Wildlife 

Seasonal restriction of public vehicle access. 

KMG would construct fences to surround its proposed evaporation ponds to prevent the 

public or animals from accessing these facilities. In consultation with the BLM AO, KMG 

would comply with applicable OSHA requirements by taking measures such as installing 

“warning” signs at locations where public access could result in potential safety issues. 

Transportation Most of the unpaved roads within the GNBPA are claimed as Class “B” and “D” roads by 

Uintah County and are, therefore, public roads. The remaining roads in the GNBPA are 

short, dead end roads used to access well pads. These roads would not be considered 

“through” roads by the public, rendering their use by the public unlikely. 

Visual Resources Avoiding placement of production facilities on hilltops and ridgelines. 

KMG would utilize low-profile tanks in the portions of the GNBPA visible from the White 

River where the river can be viewed from the location, such as ridgelines, or would utilize 

topographic features, to the extent available, to prevent viewing the tanks from the White 

River. 

Visual Resources Screening facilities from view. 

KMG would utilize topographic features, to the extent available, and utilize screening or 

other design measures, to the extent practical, to prevent stationary permanent 

equipment from being viewed from the White River. KMG would develop methods for 

screening facilities on a site-specific basis. 

DEIS A-3 July 2010 
 

 

 

Appendix A (Continued) 

Topic(s) Applicant-Committed Measures 

Surface Disturbance Use of common utility or right-of-way corridors. 

KMG would locate gathering lines adjacent to access roads. KMG would locate larger 

pipelines adjacent to roads or within existing utility corridors. 

Floodplains Exempting existing pipelines and projects previously approved, KMG would bury gas 

pipelines associated with new and future construction within 100-year floodplains. 

Noxious and Invasive 

Weeds 

KMG would conduct pre-disturbance weed inventories to identify locations of noxious and 

invasive weed species. 

Sedimentation, Erosion, KMG will implement Reasonable and Prudent Practices for Stabilization (RAPPS) and 

and Stormwater Runoff develop Storm Water Pollution Prevention Plans (SWPPPs) for individual new 

construction sites associated with compressor stations, processing plants, and pipeline 

projects that disturb more than 5 acres. 

Surface Disturbance KMG would not construct new mancamps within 0.5 mile of floodplains (including the 

floodplain) of major drainages (Sand Wash, Cottonwood Wash, Bitter Creek, White River, 

Green River); and within occupied Threatened and Endangered Plant habitat. This 

mitigation measure would be applied only if there is a demonstrated need (i.e., only if 

other mitigations do not adequately mitigate impacts). 

Threatened and 

Endangered Fish 

KMG would adhere to the following mitigation regarding protection of threatened and 

endangered fish: 

1. Limit pumping to off-channel locations – ones that do not connect to the river during 

high spring flows. 

2. If the pump head is located in the river channel where larval fish are known to occur, 

the following measures apply: 

a. Pumps will not be situated in low-flow or no-flow area as these habitats tend to 

concentrate larval fishes; 

b. Limit the amount of pumping, to the greatest extent possible, during that period of 

the year when larval fish may be present (see above); and 

c. Limit the amount of pumping, to the greatest extent possible, during the pre-dawn 

hours as larval drift studies indicate that this is a period of greatest daily activity. 

3. Screen all pump intakes with 1⁄4” mesh material. 

4. Report any fish impinged on the intake screen to the Service (801.975.3330) and the: 

Utah Division of Wildlife Resources 

Northeastern Region 

152 East 100 North 

Vernal, UT 84078 

Phone: (435) 781-9453 

1

 The disturbance associated with these buried gas gathering and water pipelines is considered in the analysis as new disturbance. 2

 For the purpose of the EIS analysis, all wells in the Proposed Action Alternative and the Optimal Recovery Alternative are assumed to be 

drilled vertically. 

DEIS A-4 July 2010 
Appendix B 

Interdisciplinary Team Analysis Record Checklist 

DEIS 

July 2010 
 

 

 

 

 

 

 

 

Appendix B 

Interdisciplinary Team Analysis Record Checklist 

Project Title: Greater Natural Buttes EIS 

NEPA Log Number: UT-080-07-785 

File/Serial Number: 

Project Leader: Stephanie Howard 

DETERMINATION OF STAFF: (Choose one of the following abbreviated options for the left 

column) 

NP = not present in the area impacted by the proposed or alternative actions. 

NI = present, but not affected to a degree that detailed analysis is required. 

PI = present with potential for significant impact analyzed in detail in the EA; or identified in a DNA as 

requiring further analysis. 

NC = (DNAs only) actions and impacts not changed from those disclosed in the existing NEPA documents 

cited in Section C of the DNA form. 

Determination Resource Rationale for Determination* Signature Date 

EIS 

Section(s) 

PI Air Quality Compressors are proposed. Generators will initially power 

the injection pumps and produced water disposal wells. 

Fugitive dust will also occur. 

Stephanie Howard 8/27/2007 3.1 

4.1 

5.3.1 

Appendix G 

NP Areas of Critical 

Environmental Concern 

No existing ACECs are in the project area. Chuck Patterson 8/27/2007 3.4.2.1 

5.3.7 

PI Cultural Resources Based on current data there are between 8,600 and 8,800 

archaeological and historical sites in the project area. 

There are two (Willow Creek Drainage and Bitter Creek 

Drainage) highly sensitive areas to the tribes on both BLM 

and Indian lands. In chapter 3, need to identify sensitivity 

areas referencing previously done statistical studies (four 

are available in this office) and also discussions of TCPs. 

Need a synthesis of impacts based on previous overall 

inventory. The synthesis needs to be used to determine the 

potential impacts of maximum development on 

archaeology. Note: Kerr-McGee has hired a consulting firm 

to do a Class III (100%) inventory of the project area 

(12/07/07). 

Blaine Phillips 8/27/2007 3.2 

4.2 

5.3.2 

PI Environmental Justice No minority or economically disadvantaged populations are 

present in the project area. However, approximately half of 

the project involves minerals that generate revenue for the 

Northern Ute Tribe. The various alternatives will have 

varying impacts on the Tribe depending on the amount of 

revenue generated. 

Stephanie Howard 9/10/07 3.8.9 

4.8 

NP Farmlands (Prime or 

Unique) 

All prime farmlands in Uintah County are irrigated. All 

unique farmlands in Uintah County are orchards. No 

irrigated lands or orchards are located on BLMadministered land in the project area. No prime or unique 

farmlands exist in the Vernal Field Office area as 

documented in the Vernal RMP. 

Stephanie Howard 9/30/07 3.11 

DEIS B-1 July 2010 
 

 

 

 

Determination Resource Rationale for Determination* Signature Date 

EIS 

Section(s) 

PI Floodplains Cottonwood Wash, Sand Wash, White River, Bitter Creek, 

Kennedy Wash, and unnamed 100-year floodplain 

ephemeral tributaries to the White River would potentially 

be impacted by the proposed project. 

Stephanie Howard 9/10/07 3.13.2 

4.13 

5.3.13 

PI Invasive, Non-native 

Species 

A pre-project weed inventory should be conducted within 

the project area prior to surface disturbance with a copy of 

the survey provided to the BLM if it is third party. A 

Pesticide Use Proposal should be approved before 

disturbance is authorized. Daily pesticide application 

records will be kept, summarized, and submitted on an 

annual basis or as requested by Vernal Field Office weed 

specialists. Vehicles and equipment should be power 

washed prior to entering the project area if coming from 

outside the Uinta Basin. Invasive and noxious weeds will 

be the responsibility of the operator to control once the 

ground has been disturbed. Weeds must be controlled prior 

to seed development. 

Jessie Salix 8/27/07 3.11.2 

4.11 

5.3.11 

Appendix J 

PI Native American Religious 

Concerns 

The Hopi has communicated that rock cairns may have 

cultural and religious importance to them. These are being 

investigated as resources permit. 

Blaine Phillips 8/27/2007 3.2 

4.2 

5.3.2

 6.1 

PI Threatened, Endangered or 

Candidate Animal Species 

High Potential for water depletion for listed fish species. 

Sedimentation and runoff issues also. Not in BF Ferret 

Primary Management Zone. 

Scott Ackerman 8/27/2007 3.14.1.3 

3.14.2.2 

4.14 

5.3.14.3 

6.1 

Appendix H 

PI Threatened, Endangered or 

Candidate Plant Species 

Populations of Uinta Basin hookless cactus (Sclerocactus 

wetlandicus) are known in T8S R21E SEC 29 S2S2; T9S 

R22E SEC 17 SW, SEC 30 SE, SEC 31 NW, SEC 32 S2, 

SEC 33 S2, SEC 35 NW; T10S R22E SEC 4; and T10S 

R23E SEC 7 NW. A population of clay reed-mustard 

(Schoenocrambe argillacea) is known in T11S R21E SEC 

18 SW. 

Clayton Newberry 12/11/200 

7 

3.11.3 

4.11 

5.3.11.1 

6.1 

Appendix H 

Appendix L 

Appendix M 

NI Wastes (hazardous or 

solid) 

All trash would be picked up and disposed of at an 

approved site, most likely the Uintah County landfill. No 

potentially harmful materials or substances would be left on 

or in the vicinity of the project area. No chemicals subject 

to SARA title III in amounts greater than 10,000 pounds 

would be used. No extremely hazardous substances as 

defined in 40 CFR 355 in threshold planning quantities 

would be used. 

Stephanie Howard 8/27/2007 2.5.6 

Appendix D 

DEIS B-2 July 2010 
 

 

 

 

 

 

 

Determination Resource Rationale for Determination* Signature Date 

EIS 

Section(s) 

PI: Surface 

PI: Ground 

Water Quality 

(surface/ground) 

Surface: Potential for sedimentation through construction 

and contamination through construction and operation to 

affect surface water quality. Also potential for increased 

erosion due to surface disturbance resulting in increased 

sedimentation entering project area drainages. 

Ground: The operator has certified compliance with all 

Onshore Oil and Gas Orders. Onshore Order No. 2 (Drilling 

Operations) will assure that the project will not adversely 

affect groundwater quality. These guidelines specify that 

“...proposed casing and cementing programs shall be 

conducted as approved to protect and/or isolate al usable 

water zones, potentially productive zones, and any 

prospectively valuable deposits of minerals. Any isolating 

medium other than cement shall receive approval prior to 

use.” Due to the state-of-the art drilling and well completion 

techniques, the possibility of adverse degradation of 

groundwater quality or prospectively valuable mineral 

deposits by drilling will be negligible. However, there is a 

potential for ground water contamination from the 

construction and operation of facilities associated with this 

proposal. Disclosure of the types and amounts of 

hazardous materials associated with this field development, 

spill contingency plans for planned facilities and adherence 

to Oil and Gas Onshore Order No. 2 will help to lower the 

potential of adverse impacts to ground water in this area. 

Stephanie Howard 9/10/07 Surface: 

 3.13.1

 4.13

 5.3.13 

Ground: 

 3.13.3

 4.13

 5.3.13 

PI Wetlands/Riparian Zones Wetland/riparian zones occur along Bitter Creek and the 

White River in the project area. There is also some 

wetland/riparian in Sections 15 and 16 of T10S R21E. 

Potential for impacts to these areas from project activities. 

Stephanie Howard 9/10/07 3.11.1 

3.13.2 

4.11 

4.13 

5.3.11 

5.3.13 

NP Wild and Scenic Rivers No wild or scenic rivers exist in the project area. Chuck Patterson 8/27/2007 3.4.2.1 

NP Wilderness No wilderness or wilderness study areas are present Chuck Patterson 8/27/2007 3.4.2.1 

PI County Transportation Plan Document should contain travel plan that would address 

roads issues regarding type, maintenance, and standards, 

and that the road would be maintained throughout the life of 

the project. Company should contact Uintah County 

Planning and Zoning Department for necessary County 

permits. Contact Road Department if crossing of county 

roads, and Public Lands Department if maintenance and 

improvement on County roads is necessary. 

Diane Caltharp 8/27/2007 3.10 

4.10 

5.3.10 

Appendix C 

PI Fish and Wildlife including 

Special Status Species 

other than FWS Candidate 

or Listed species (e.g. 

Migratory Birds) 

Migratory bird issues – removal of nesting and foraging 

habitat, potential for impacts from open pits, vehicles, 

general activity. Sage grouse habitat fragmentation, direct 

impacts to lekking areas. Raptors- fragmentation of 

nesting, wintering and foraging habitat, impacts from 

vehicles, activity. Big game crucial habitat – primarily 

antelope, continued fragmentation and additional structures 

within habitat, loss of forage, increased risk to vehicle 

collisions. Impacts to sensitive fish species due to 

increased sedimentation, runoff and increased potential for 

spills. Scattered white tail prairie dog population. 

Scott Ackerman 8/27/2007 3.14 

4.14 

5.3.14 

Appendix H 

Appendix I 

NI Fuels / Fire Management No planned Fuel Projects in the area. Access for 

suppression would not be diminished. 

Steven Strong 8/24/07 NA 

PI Geology / Mineral 

Resources 

Within the area of known oil shale and gilsonite. Jerry Kenczka 8/27/2007 3.3 

4.3 

5.3.3 

DEIS B-3 July 2010 
 

 

 

 

 

 

 

 

Determination Resource Rationale for Determination* Signature Date 

EIS 

Section(s) 

NI Lands / Access Access roads, gas pipelines, powerlines, anything off unit 

requires a right of way. If a well pad or injection facility is 

applied for an SF 299 and Bond would be required. Does 

not need to be included in write up in chapters 3 and 4, but 

recognize that bonds and right- of- ways do need to be 

addressed. Conflicts with other rights of way are not 

anticipated, but if they do occur they will be resolved on a 

site specific basis. 

No changes to land use as designated in the Book Cliffs 

RMP are anticipated to be necessary. 

Paul Rodriquez 8/27/2007 2.3 

2.5 

3.4 

4.4 

5.3.4 

PI Livestock Grazing Allotments in the project area include Antelope Draw, 

Coyote Wash, Olsen AMP, Sand Wash, Seven Sisters, 

Mike Cutler/ 

Dusty Carpenter 

12/9/2009 3.6 

4.6 

Southern Canyon, Thorne-Ute Broome, and White River 5.3.6 

Bottom. Previous oil and gas actions have eliminated 

AUMs from these allotments. The proposed action would 

Appendix K 

eliminate additional AUMs on these allotments. AUM 

adjustments on these allotments would occur through a 

process that includes quantitative monitoring and analysis 

of available forage. 

PI Paleontology PFYC Class 4 or 5 (highly sensitive) because most of the 

surface geology is Uinta Formation. Class 3 along the 

Robin Hansen 5/12/2008 3.5 

4.5 

Bitter Creek where the Green River Formation outcrops and 5.3.5 

Class 2 along the alluvial deposits along Bitter Creek and 

the White River flood plains. 

PI Rangeland Health 

Standards and Guidelines 

Not all allotments have been assessed in the project area. 

Allotments that have been assessed are meeting standards 

Mark Wimmer/ 

Mike Cutler 

9/30/2009 4.6 

with some areas at risk due to oil and gas activity. See the 

soils, weeds, riparian, and water quality sections. 

PI Recreation A portion of the White River SRMA is located within the Chuck Patterson/ 9/30/2009 3.7 

project area. Recreational boating is along the river from the 

beginning of March to the end of June. Disbursed OHVing 

is found throughout the project area. Hunting is also 

Jason West 4.7 

5.3.7 

throughout the area, especially within the Book Cliffs 

Limited entry elk and deer unit. See the Utah Big game 

Bucks, Bulls and Once-in-a-lifetime Proclamation for 

hunting dates and number of permits offered. Hunting is 

managed by Utah Division of Wildlife Resources. 

PI Socioeconomics Socio-economics will be impact by this project. Also, Stephanie Howard 8/27/2007 3.8 

implementing the proposed project will positively impact the 4.8 

socioeconomics of the Northern Ute Tribe. 5.3.8 

PI Soils Increase in sedimentation and erosion likely. Steve Strong 8/24/07 3.9 

4.9 

5.3.9 

PI Veg. Vegetation including Vegetation will be impacted by the construction of new Clayton Newberry 8/29/07 3.11.1 

NP SS. Special Status Species roads, pads, ponds and facilities. 4.11 

other than FWS Candidate 5.3.11 

or Listed species No Bureau-sensitive special status plants species are 

known from the area of proposed activity. 

Appendix H 

PI Visual Resources Class II along the river, disturbances in this are may not be 

within management objectives. The remainder of the 

project area is Class III and IV so the project would be 

Chuck Patterson/ 

Stephanie Howard 

9/30/2009 3.12 

4.12 

5.3.12 

within management objectives in those areas. Need to 

conduct an “as seen” GIS analysis along the White River to 

determine line-of-sight. Also, conduct an “as seen” analysis 

on a 5-mile radius from the Goblin City Overlook. 

DEIS B-4 July 2010 
 

 

 

 

 

Determination Resource Rationale for Determination* Signature Date 

EIS 

Section(s) 

PI Waters of the U.S. (C.O.E.) Discharge activities within waters of the United States 

(including wetlands), if any are proposed, and crossings of 

water of the U.S. may require a Department of the Army 

permit. 

Sue Nall 9/19/07 3.13.2 

4.13 

5.3.13 

NP Wild Horses and Burros There are no herd areas, herd management areas, wild 

horses and burros present in the project area. 

Kevin Lloyd 8/27/2007 NA 

PI BLM Natural Areas A portion of the BLM White River Natural Area is located 

within the project area. 

Jason West 9/30/2009 3.4.1 

4.4 

5.3.4 

PI Woodland / Forestry Cottonwood (Populus fremontii) is present along rivers and 

streams in the project area, and would be impacted if 

ground disturbing activities encroach into river and steam 

ways and their associated riparian zones. 

Small isolated stands of pinyon juniper woodland exist in 

the project area; these stands could be impacted if 

development occurred in or near them. 

David Palmer 8/27/2007 3.11.1 

4.11 

5.3.11 

PI Non-WSA lands with 

wilderness characteristics 

The White River non-WSA lands with wilderness 

characteristics overlaps the project area and may be 

impacted by the proposed project. No impact to the BLM 

White River natural area is anticipated. 

Stephanie Howard 3/24/2010 3.14 

4.14 

5.3.14 

FINAL REVIEW:
 

Reviewer Title Signature Date Comments 

NEPA / Environmental 

Coordinator 

Authorized Officer 

DEIS B-5 July 2010 
Appendix C 

Transportation Plan 

DEIS 

July 2010 
 

Appendix C 

Greater Natural Buttes Project Area
 

Natural Gas Development Project
 

Transportation Plan
 

Introduction 

In August 2007, Kerr-McGee Corporation (KMG) submitted a proposal to the Bureau of Land Management 

Vernal Field Office (VFO) to develop hydrocarbon resources underlying oil and gas leases owned, at least in 

part, by KMG within the Greater Natural Buttes Project Area (GNBPA) in Uintah County, Utah. KMG’s intent is 

to explore and develop all potentially productive subsurface formations underlying the land in the project area. 

KMG is the designated operator or owns contractual leasehold rights for approximately 85 percent of the lands 

within the GNB boundary. The project area consists of an existing natural gas producing area located on 

lands owned by the United States, State of Utah, and private entities. In addition to new road construction, 

KMG’s planned project development would rely upon use of a network of existing highways, county roads, and 

roads on private, state, and United States lands. 

The Bureau of Land Management (BLM) is currently preparing an Environmental Impact Statement (EIS) to 

analyze potential environmental, cultural, social, and economic impacts likely to be associated with KMG’s 

proposal. Additionally, the EIS will identify alternatives to KMG’s proposal that meet the purpose and need of 

the project and develop mitigation strategies to address the impacts of KMG’s proposal and any alternatives 

developed. 

This transportation plan incorporates the BLM’s Road Manual 9113 and the Surface Operating Standards for 

Oil and Gas Exploration and Development, Fourth Edition (Gold Book – BLM and USFS 2007). BLM’s Road 

Manual 9113 and the Gold Book provide KMG with a combination of guidance and standards for ensuring 

compliance with agency policies and operating requirements. As such, these are reference documents and 

the associated guidance and standards serve as a basis for identifying appropriate road design, construction, 

and maintenance standards following site-specific analysis. This plan outlines the construction and 

maintenance actions that KMG would employ. If conditions warrant, KMG would cooperate with the 

appropriate surface management agency or private surface owner to identify and apply additional measures. 

Purpose and Scope 

The objective of KMG’s transportation planning for the GNB project area is to minimize resource conflicts and 

development costs within the project area through proper road design, construction, and maintenance 

activities. This plan describes KMG’s anticipated use of existing roads and construction and use of proposed 

access roads. In addition to this plan, BLM manuals, the Gold Book, and county transportation codes and 

standards would be used as appropriate in planning and design efforts for each new access road. 

KMG recognizes that, in addition to BLM, existing roads to and within the GNB project area are under the 

jurisdiction of other governmental agencies (e.g., Uintah County and Uintah and Ouray Tribal Government) 

who may have specific design and maintenance requirements for roads under their jurisdiction. Construction 

standards and maintenance agreements for roads under private agreements may or may not exist. In these 

cases, KMG would strive to implement road design, construction, and maintenance standards consistent with 

adjacent jurisdictional government agencies unless otherwise requested by private surface owners. 

The transportation plan objectives include: 

• Maximize use of the existing road system; 

• Facilitate identification of roads not needed for operations; 

• Construct roads to the minimum standard necessary to accommodate anticipated traffic and weather; 

DEIS C-1 July 2010 
 

 

 

•	 Minimize the number of loop roads; 

•	 Minimize the crossing of side slopes greater than 40 percent; 

•	 Minimize profile grades; 

•	 Minimize drainage crossings, with emphasis placed on drainages with potentially large runoff flows 

and floodplains; 

•	 Meet the needs and requirements of KMG, the BLM, Uintah County, Northern Ute Tribe, the State of 

Utah, and private surface owners; 

•	 Incorporate environmental and resource considerations; and 

•	 Provide for inspection and maintenance activities. 

General Location Information 

The GNB project area is located in central Uintah County south of Vernal, Utah. The project area includes 

U.S. Highway 40, State Highway 45 and 88, and Uintah County roads 3260, 3410, and 3420 as major access 

routes (see Map C-1). Additional developed access roads within the GNB project area are owned or managed 

by Uintah County, the BLM, the Northern Ute Tribe (administered by the Bureau of Indian Affairs [BIA]), the 

State of Utah, and private entities. Additionally, there are numerous undeveloped roads/routes within and 

adjacent to the area. 

Primary access to the GNB project area is via Glen Bench Road, State Highway 45, and State Highway 88. 

Access within the project area would be via the existing road network, which consists of arterial roads and 

individual well access roads. County roads within the project area include Class 1-B gravel roads (Seven 

Sisters Road, Fidlar Road, Bitter Creek Road, and Seep Ridge Road) and a Class 1-B paved and graveled 

road (Glen Bench Road). 

The GNB project area consists of approximately 162,911 acres in an existing gas producing area located in 

T8S/R20-23E, T9S/R20-24E, T10S/R20-23E, and T11S/R21-22E in Uintah County, Utah. The proposed wells 

would be drilled and facilities would be constructed within 88,565 acres of federal land; 39,399 acres of land 

owned by the Northern Ute Tribe and administered by the BIA; 32,755 acres of land owned by the State of 

Utah; and 2,192 privately owned acres of land, which includes allottees. The BLM administers 79 percent, the 

State of Utah owns 20 percent, and the private owners or tribal allottees own 1 percent of the subsurface 

minerals below the project area. Surface and mineral ownership is summarized in Table 2.1-1 of the EIS. 

Existing Development 

Based on current Utah Department of Oil, Gas, and Mining (UDOGM) information (October 2007) for existing 

oil and gas infrastructure in the GNB project area, 1,562 vertical productive wells have been drilled on single 

well pads and are in operation. Table 2.2-1 of the EIS identifies those existing or approved oil and gas 

facilities that are present within the GNB project area. 

Summary of Proposed Development 

Although actual operations are subject to change as the project proceeds, KMG’s plan is to drill additional 

wells at an average rate of approximately 334 wells per year over a period of 10 years, or until the resource 

base is fully developed, with a maximum total of 3,496 wellbores. KMG estimates that each proposed new well 

would require an average of 0.25 miles of new or upgraded road construction. The plan also assumes that a 

total of 179 new wells would be drilled by other operators having leasehold rights in the GNB project area. This 

plan does not obligate those operators. 

DEIS	 C-2 July 2010 
Glen Bench Road 

(3260) 

Fidlar Road 

(3440) 

Seven Sisters Road 

(3420) 

Bitter Creek Road 

Seven Sisters Road 

(3420) 

Seven Sisters Road

(3420) 

Seep Ridge Road 

Seep Ridge Road 

Glen Bench Road 

(3260) 

88 

Bitter Creek Road 

East Bench Road 

Love Road 

West Sand Wash Road 

West Fork Cottonwood 

Wash Road 

West Fork Cottonwood 

Wash Road 

Hatch Reservoir Road 

White River South Road 

NB. PIPELINE 

NB. PIPELINE 

Coyote Wash Road 

West Sand Wash Road 

Chipeta Grove Road 

Glen Bench Cutoff 

Kennedy Wash Road 

Chipeta Grove Road 

Archy Bench Road 

White River 

Coyote Wash Road 

South Road 

Middle Road 

Middle Road 

East Bench Road 

West Sand Wash Road 

Island Gas Field Road 

Green River 

Willow 

Creek 

Duch esne River 

8-T4-R3
 4-T8-R22 4-T8-R21 4-T8-R24 4-T8-R23 4-T8-R20
 Uintah

Area County

of

Detail Utah

8-T5-R3
 

Named Streams and Rivers 

4-T9-R23 4-T9-R22 Township/Range 4-T9-R21
 EIS Project Area 

Trunk Roads 

4-T9-R24 Other Roads 

4-T9-R20
 

88 

Glen Bench Road 

(3260) 

4-T10-R24 

4-T10-R23 4-T10-R20 4-T10-R21 

4-T10-R22
 

Bitter Creek
 

Cutoff
 

Archy Bench Road 

Love Road Seep Ridge Road 

1012 0.5 

Scale in Miles 

2 0 1.5 1 0.5 2

Love Road Scale in Kilometers 

Greater Natural Buttes 

Area Gas Development 

Project EIS
 

4-T11-R20
 4-T11-R21
 4-T11-R22 4-T11-R23 4-T11-R24
 

Map C-1
 

Transportation Plan Roads
 

C-3

X:\0Projects\12100_013_Kerr_McGee_Greater_Natural_Buttes\Figures_Folder\PDEIS\MapC-1_ExistingAccessRoads.mxd 

8/14/2009 @ 12:05:40 PM 
 

 

 

 

 

The ultimate pace, location, timing, and total number of wells developed within the GNB project area may be 

affected by factors outside of KMG’s control such as permit approvals, production success, geology, 

engineering technology, economic factors, commodity prices, rig availability, and lease stipulations. Because 

of this uncertainty, future transportation routes would be developed incrementally as wells are developed and 

additional information becomes available. KMG would coordinate with government agencies having 

jurisdiction over transportation routes to accomplish the goals of this plan. The productive life of each well is 

estimated to be approximately 30 to 50 years. 

Access Road Construction and Maintenance Overview 

Evaluation of Existing Roads 

The existing road network within the GNB project area is discussed in more detail in Chapter 3.0, Affected 

Environment. KMG would upgrade, reconstruct, and/or maintain existing roads utilizing standards consistent 

with those of the appropriate surface management agency or private surface owner on which the road occurs. 

Upgrading, reconstruction, and maintenance may include some or all of the procedures as identified below in 

the section: “Access Road Construction and Maintenance Practices and Procedures.” 

Existing roads requiring upgrading would meet standards appropriate to the anticipated traffic flow and all 

weather road requirements. Construction or upgrading would not occur during muddy conditions. 

 Road Types 

BLM recognizes several functional classifications for roads in Road Manual 9113. They are: 

1)	 Collector Roads. These roads normally provide primary access to large blocks of land and connect 

with or are extensions of a public road system. Collector roads accommodate mixed traffic and serve 

many uses. They generally receive the highest volume of traffic of all the roads in the Bureau road 

system. User cost, safety, comfort, and travel time are primary road management considerations. 

Collector roads usually require application of the highest standards used by the Bureau. 

2)	 Local Roads. These roads normally serve a smaller area than collectors, and connect to collectors or 

public road systems. Local roads receive lower volumes, carry fewer traffic types, and generally serve 

fewer uses. User cost, comfort, and travel time are secondary to construction and maintenance cost 

considerations. Low volume roads in mountainous terrain may be single-lane roads with turnouts. 

3)	 Resource Roads. These are normally spur roads that provide point access and connect to local or 

collector roads. They carry very low volume and accommodate only one or two types of use. Use 

restrictions are applied to prevent conflicts between users needing the road and users attracted to the 

road. The design of these roads is governed by environmental compatibility and minimizing Bureau 

costs, with minimal consideration for user cost, comfort, or travel time. Roads servicing individual 

oil/gas exploration and production locations fall within this classification, and they are often referred to 

as well access roads. 

Road Construction Planning 

Terrain, well spacing, surface use restriction, and other constraints may prevent KMG from locating future well 

sites adjacent to or nearby existing roads. However, most new road construction would likely consist of short 

segments to connect proposed well sites to existing access routes. New roads would be built and maintained 

to provide year-round access. 

KMG in cooperation with the appropriate surface management agency and/or private surface owner would 

conduct field evaluations to select routes to best serve the respective management needs of the approving 

entity. Access roads would be designed to accommodate the anticipated use (e.g., light vehicles and/or heavy 

DEIS	 C-4 July 2010 
 

truck). Design criteria include, but may not be limited to roadway structure, travel-way width, shoulders, 

slopes, curve radius, safety, traffic requirements, vehicle characteristics, maintenance costs, snow removal, 

sight distances, and environmental and resource considerations. Vehicle speeds would be limited to be 

consistent with the road’s intended designed use (BLM Manual 9113). 

The location access roads would be planned to the extent practicable to avoid sensitive areas and to minimize 

impacts to water, soil, vegetation, sensitive species, wildlife habitat, and land management prescriptions. 

When sensitive areas cannot be avoided, KMG would strive to employ practices to prevent, reduce, or mitigate 

all potential adverse effects caused by construction and use of the road. 

 Road Construction Procedures 

On BLM-managed lands, KMG proposes to construct required new access roads across public lands in 

accordance with BLM Manual 9113 and the Gold Book standards and as appropriate for site-specific 

conditions. BLM has the option of determining whether professional engineering design and construction 

oversight is necessary or whether the road can be constructed by the operator consistent with site-specific 

standards and approved road design. The need for professional engineering design and oversight would be 

based on factors such as topography, soils, hydrology, safety, and levels and types of use by the operator and 

general public. 

Based on pre-construction onsite reviews that may include surface owner representatives and cooperating 

agencies, roads would be located to minimize disturbances and maximize transportation efficiency. New well 

site access roads would be designed and constructed to resource road standards to facilitate reclamation 

should the well be a dry hole. Roads located on private lands would be constructed in accordance with 

standards imposed by the private land owner. The number of roads would be limited to decrease potential 

impacts by discouraging development of looped roads and by accessing wells from short resource roads off 

the local roads. Roads would be designed to minimize disturbance and would be built and maintained as 

specified by the BLM to provide safe operating conditions at all times. Surface disturbance would be contained 

within the road ROW. 

Construction equipment and techniques used by KMG would be to the standards found in the BLM Road 

Manual 9113 (e.g., crown-and-ditch method). Should soft spots develop on the roadway during construction or 

drilling operations, they would be immediately covered with crushed rock or gravel. Where identified during 

on-site review by the BLM, problem areas on access roads to producing well sites would be graveled to a 

depth of 4 to 6 inches to reduce erosion and sedimentation. Graveling would be accomplished within a time 

period specified by BLM. Surfacing and base course materials would be obtained from existing, operational 

gravel pits located on private or federal lands near the project area. Topsoil would be spread and vegetation 

would be windrowed to the side slopes of the newly constructed access roads, and revegetation would begin 

the first appropriate season following the well going into production. 

Small drainage crossings on access routes within the project area would utilize culverts sized to accommodate 

a 25 year storm event. Low water crossings also may be used in shallow channel crossings. Low water 

crossings of channels would consist of excavating an area approximately 4 feet deep under the travel way and 

filling it with rock and gravel to the level of the drainage bottom. Channel banks on either side of such 

crossings would be cut down to reduce grade where necessary. Generally, culverts would be installed on 

smaller, steeper channel crossings. Topsoil would be saved before channel-crossing construction occurs. 

Also, the total area to be disturbed would be flagged on the ground before construction begins 

In the event drilling is non-productive, all disturbed areas, including the well site and new access road, would 

be reclaimed to the approximate landform that existed prior to construction. Reclamation and site stabilization 

techniques (e.g., topsoil application and seed mixture) would be implemented as specified in the APD Surface 

Use Plan or the ROW Plan of Development (POD). If drilling is productive, all access roads to the well site 

would remain in place for well servicing activities (i.e., maintenance, improvements, etc.). Partial reclamation 

DEIS C-5 July 2010 
 

 

 

would be completed on segments of the well pad and access road ROW no longer needed. Reclamation of 

resource roads would be implemented the first growing season after well abandonment. 

Vehicle Use and Road Maintenance 

Monitoring road use plays an important role in a maintenance plan. KMG would conduct regular inspections to 

identify road problems such as ruts, holes, crown and ditch elements, standing water on road surface, 

surfacing materials, blockage of water into and from culverts, interim reclamation, and control of noxious and 

invasive weeds. Inspections would be routinely conducted following rapid snowmelt and prolonged rain 

events. Maintenance activities could include but not be limited to blading, resurfacing, dust abatement, spot 

repairs, culvert cleaning, noxious and invasive weed control, reseeding, regarding, and snow removal. The 

road surface and shoulders would be kept in a safe and usable condition and would be maintained in 

accordance with the original construction standards. All drainage ditches and culverts would be kept clear and 

free-flowing and would be maintained according to original construction standards. The approved use 

authorization route for the access road would be kept free of trash during operations. 

Reclamation and Abandonment 

When the GNB project area or portions thereof are ready to be abandoned (est. 30 to 50 years), final 

disposition of the access roads would be determined. KMG’s preference would be to abandon and reclaim all 

resource roads; however, management needs of surface management agencies and/or private surface 

owners may dictate otherwise. Anticipated future uses could include access to accommodate ranching and 

livestock operations, recreation, or administrative needs. Reclamation protocols are described in Appendix E 

of the EIS. 

KMG anticipates that county roads would likely be retained in an upgraded status (local/collector roads), as 

would improvements to surface management agency designated roads. Resource roads developed as 

access to individual wells sites are likely to be reclaimed and returned to conditions similar to those existing 

prior to natural gas development activities. If KMG has assumed any maintenance responsibilities for roads 

that would be retained, those responsibilities would revert to Uintah County, the surface management agency, 

and/or the private surface owner as appropriate. 

Access Road Construction and Maintenance Practices and Procedures 

KMG would employ the following as part of its transportation planning: 

•	 The location of each well and access road for each well will be shown on maps and described in the 

site-specific Application for Permit to Drill (APD) and/or Right-of-Way (ROW). The access road will be 

centerline flagged during the time of staking. 

•	 All improvements requested for existing access roads will be described in the site-specific APD and/or 

ROW. 

•	 All existing roads will be maintained and kept in good repair during all drilling and completion
 

operations associated with this well. 

•	 Access roads and surface disturbing activities will conform to standards outlined in the BLM Gold 

Book: Surface Operating Standards for Oil and Gas Exploration and Development, 2007. 

•	 On Northern Ute Tribal, private, and/or state surface, access roads will be constructed according to 

the surface owner’s specifications. 

•	 New access roads on BLM surface will be: Crowned (2 to 3 percent), ditched, and constructed with a 

running surface of 18 feet and a maximum disturbed width of 45 feet. 

DEIS	 C-6 July 2010 
•	 The disturbed width may be wider than 45 feet when approved by the appropriate Authorized Officer 

to accommodate large equipment, or to allow for intersections, sharp curves, steep grades, or other 

safe road construction and maintenance practices. These situations will be discussed and a decision 

made at the on-site field review. Site-specific proposals will be included in the APD and/or ROW. 

•	 Graveling or capping the roadbed will be performed as necessary to provide a well-constructed, safe 

road. 

•	 Prior to construction or upgrading, the proposed road will be cleared of any snow and allowed to dry 

completely. 

•	 Unless specified in the site-specific APD and/or ROW, the following specifications will apply: 

− No pipelines will be crossed with the new construction. 

− The maximum grade will be less than 8 percent. 

− There will be no turnouts. 

− If it becomes necessary to install a culvert, it will be specified in the APD or the BLM will be 

notified of the installation via Sundry Notice. 

− Appropriate water control features will be constructed to control erosion. 

− There will be no gates, cattleguards, fence cuts, or modifications to existing facilities. 

•	 Surfacing material may be necessary, depending upon weather conditions. 

•	 Surface disturbance and vehicular traffic will be limited to the approved location and approved access 

route and travel surface. Any additional area needed will be approved in advance. 

•	 Road drainage crossings will be of the typical dry creek drainage crossing type. Crossings will be 

designed so they will not cause siltation or accumulation of debris in the drainage crossing nor will the 

roadbed block the drainage. 

•	 Erosion of drainage ditches by runoff water will be prevented by diverting water off at frequent 

intervals by means of cutouts. 

•	 Should mud holes develop, they will be filled in and detours around them avoided. 

•	 When snow is removed from the road during the winter months, the snow will be pushed outside of 

the borrow ditches, and the cutouts kept clear so that snowmelt will be channeled away from the road. 

•	 The use of topsoil for construction activities will not be allowed. 

•	 Surface and subsoil materials in the immediate area will be utilized. 

•	 Any gravel will be obtained from a commercial source. 

The use of materials under BLM jurisdiction will conform to 43 CFR 3602.33. Mineral materials displaced in the 

ordinary course of conducting operations and/or construction activities may be used for oil and gas 

development purposes within the subject lease in accordance with BLM approved actions. Mineral materials 

also may be obtained by making application for a mineral material sale under the provisions of 43 CFR 

Subpart 3602, Mineral Materials Sales. 

DEIS	 C-7 July 2010 
Appendix D 

Example Spill Prevention Control and Countermeasures Plan 

DEIS 

July 2010 
 

SPILL PREVENTION, CONTROL AND 

COUNTERMEASURE PLAN 

PREPARED FOR: 

COMPANY NAME 

FACILITY OR AREA NAME 

FACILITY OR AREA ADDRESS LINE 1 

FACILITY OR AREA ADDRESS LINE 2 

CITY, STATE, ZIP CODE 

PLAN TYPE: 

§112.8 Requirements for Onshore Facilities 

(excluding Production Facilities) 

IF AN EMERGENCY OR SPILL, 

CONTACT 

FACILITY OR AREA NAME AT PHONE NUMBER OR 

DESIGNATED PERSON AT PHONE NUMBER 

AND REFER TO SECTION A.2. FOR SPILL REPORTING 

AND RESPONSE PROCEDURES 

PREPARED ON MM/DD/YYYY 

DEIS D-1 July 2010 
LIST OF FACILITIES COVERED BY THIS PART A 

DEIS D-2 July 2010 
ACTION ITEM SUMMARY
 

Throughout this Spill Prevention, Control and Countermeasure (“SPCC”) Plan (the “Plan”), items that 

require specific attention because of inspection, training and recordkeeping requirements, are 

presented in bold print and underlined. These ‘Action Items’ are summarized below. 

PART A – GENERAL PLAN REQUIREMENTS 

	 Section A.1.1. – (At all times) Maintain a complete copy of the SPCC Plan at the nearest 

field office. 

	 Section A.1.3. – (After change to a Facility) The SPCC Plan will be revised whenever there 

are design, construction, operation, or maintenance changes to a Facility. See Log of Plan 

Review and Amendments. 

	 Section A.1.3. – (Every 5 years) Management must review, evaluate and re-certify the Plan 

for its adequacy. 

	 Section A.1.5. - (At all times) Inspection procedures, tests and records, signed by the 

appropriate supervisor or inspector, will be kept with the SPCC Plan for a period of no less 

than three years. 

	 Section A.1.5. – (Annual) Leak test all buried metallic storage tanks. 

	 Section A.1.5. – (Annual) Inspection of SPCC Facilities (e.g. bulk storage containers, oil-filled 

equipment, oil and oily-water containing process units, and containment structures) will be 

conducted. 

	 Section A.1.5. – (On a regular basis) Conduct a non-destructive integrity test on 

aboveground bulk storage container systems. 

 Section A.1.5. – (On a regular basis) Test liquid level sensing devices. 

 Section A.1.6. - (Prior to assignment of responsibilities) All oil-handling personnel will be 

trained in discharge prevention and spill response prior to the assignment of job 

responsibilities. 

 Section A.1.6. – (Annual) Discharge prevention briefings for oil-handling personnel will be 

conducted. 

	 Oil Spill Contingency Plan and/or Facility Response Plan will be updated on an asneeded basis 

PART B – FACILITY INFORMATION 

 Section B.1.5.1. - (Upon installation or repair) Wrap, coat and, if feasible, cathodically 

protect buried piping. 

 Section B.1.5.4. - (Annual) Inspection of aboveground piping will be conducted. 

 Section B.1.5.4. - (As necessary) Integrity and leak testing of buried piping must be 

conducted at the time of installation, modification, construction, relocation, or replacement. 

 Section B.1.8. - (After repair or change) Field constructed containers must be reevaluated 

for brittle fracture failure potential. 

 Section B.1.10. - (Each drainage/discharge event) All discharges of stormwater from 

secondary containment must be evaluated and recorded. 

DEIS	 D-3 July 2010 
TABLE OF CONTENTS 

LIST OF FACILITIES COVERED BY THIS PART A 

ACTION ITEM SUMMARY 

TABLE OF CONTENTS 

LOG OF PLAN REVIEW AND AMENDMENTS - PART A 

FEDERAL REGULATORY REQUIREMENTS / SPCC PLAN CROSS-REFERENCE 

PART A – GENERAL PLAN REQUIREMENTS 

A.1. GENERAL INFORMATION 

A.1.1. Plan Copy [§112.3(e)] 

A.1.2. Management Approval [§112.7] 

A.1.2.1. Designated Person Accountable for Oil Spill Prevention at the Facility [112.7(f)(2)] 

A.1.3. Amendment of Plan by Owner or Operator [§112.5] 

A.1.4. Oil Spill Contingency Plan [§112.7(d)] 

A.1.5. Inspections, Tests And Records [§112.7(e), §112.8(c)(4), (6), (8), (10)] 

A.1.6. Personnel Training [§112.7(f)] 

A.1.7. Security [§112.7(g)] 

A.1.8. Conformance with State Requirements [§112.7(j)] 

A.2. SPILL REPORTING AND RESPONSE [§112.7(a)] 

A.2.1. Emergency Contact Information [§112.7(a)(3)(vi)] 

A.2.2. Spill Reporting Requirements and Amendment of Plan by Regional Administrator 

[§112.4(a), §112.7(a)(4) and §112.7(a)(5)] 

A.2.2.1. Spill Reporting and Response Requirements 

A.2.3. Emergency Response Procedures [§112.7(a)(3)(iv) and (a)(5)] 

A.2.3.1. Spill Discovery and Response 

A.2.3.2. Spill Response Resources 

A.2.4. Recovered Materials Management [§112.7(a)(3)(v)] 

A.3. Substantial Harm Determination [§112.20] 

A.4. Facility Response Plan [§112.20] 

FIGURES 

Figure A-1 Emergency Response Flowchart and Responsibilities 

Figure A-2 Substantial Harm Criteria Checklist 

APPENDICES 

Appendix A Forms 

Spill Report Form 

Regional Administrator Reporting Form 

Annual SPCC Inspection Checklist 

SPCC Drainage Inspection and Discharge Log 

DEIS	 D-4 July 2010 
PART B – FACILITY INFORMATION 

B.1. FACILITY NAME AND LOCATION [§112.7(a)(3)] 

B.1.1. Designated Person at Facility [§112.7(f)(2)] 

B.1.2. Professional Engineer Certification [§112.3(d)] 

LOG OF PLAN REVIEW AND AMENDMENTS - PART B 

B.1.3. Facility Conformance with SPCC Rule [§112.7(a)(1) and (a)(2)] 

B.1.4. Facility Description [§112.7(a)(3)] 

B.1.5. Facility Transfer Operations [§112.8(d)] 

B.1.5.1. Buried Piping Protection and Examination [§112.8(d)(1)] 

B.1.5.2. Not-In-Service and Standby Service Terminal Connections [§112.8(d)(2)] 

B.1.5.3. Design of Pipe Supports and Protection from Vehicular Traffic [§112.8(d)(3) and 5)] 

B.1.5.4. Aboveground Piping and Appurtenance Protection and Examination [§112.8(d)(4)] 

B.1.5.5. Loading/Unloading Racks [§112.7(h)] 

B.1.6. Facility Storgage and Bulk Storage Containers [§112.7(a)(3)(i), 112.7(i), 112.8(c)(1) 

and (8)] 

B.1.6.1. Tank Compatibility with Contents [§112.8(c)(1)] 

B.1.6.2. Engineer or Update Each Container [§112.8(c)(8)] 

B.1.6.3. Buried or Partially Buried Metallic Tanks [§112.8(c)(4) and (5)] 

B.1.6.4. Internal Heating Coils [§112.8(c)(7)] 

B.1.7. Fault Analysis [§112.7(b)] 

B.1.8. Brittle Fracture Evaluation [§112.7(i)] 

B.1.9. Secondary Containment [§112.7(c) , §112.7(k) and §112.8(c)(2) and (11)] 

B.1.10. Facility Drainage [§112.8(b) and (c)(9)] 

TABLES 

Table B-1 Site Specific Data and Containment Calculations 

FIGURES 

Figure B-1 Facility Diagram 

Figure B-2 Facility Map (optional) 

TABLE OF CONTENTS (Cont’d) 

DEIS	 D-5 July 2010 
 

 

 

 

 

 

 

LOG OF PLAN REVIEW AND AMENDMENTS - PART A 

NON-TECHNICAL AMENDMENTS 

• Non-technical amendments are not certified by a Professional Engineer. 

• Examples of changes include, but are not limited to, phone numbers, name changes, or any non-technical text 

change(s). 

TECHNICAL AMENDMENTS 

• Technical amendments are certified by a Professional Engineer (§112.5(c)). 

• Examples of changes include, but are not limited to, commissioning or decommissioning containers; 

replacement, reconstruction, or movement of containers; reconstruction, replacement, or installation of piping 

systems; construction or demolition that might alter secondary containment structures; changes of product or 

service; or addition/deletion of standard operation or maintenance procedures related to discharge prevention 

measures. It is the responsibility of the field to determine, and confirm with the regulatory authority as 

necessary, what constitutes a technical amendment. The preamble of the rule states that an amendment is 

required only “when there is a change that materially affects the facility’s potential to discharge oil” (67 FR 

47091). 

• An amendment made under this section will be prepared within six (6) months of the change and implemented 

as soon as possible but not later than six (6) months following preparation of the amendment. 

• Technical Amendments affecting various pages within the Plan will require P.E. certification of the Plan and will 

be documented on the log form below. 

MANAGEMENT REVIEW 

• Management will review this SPCC Plan at least every five (5) years and document the review on the form 

below (§112.5(b)). 

• By signature below, signor confirms that management has completed a review and evaluation of this SPCC 

Plan. 

Review/ 

Amend 

Date 

Signature* 

(Specify) 

Amend Plan 

(will/will not) 

Description of 

Review/Amendment 

Affected 

Page(s) 

P.E. 

Certification 

(Y/N) 

*Typically signed by Manager, Professional Engineer or Plan Reviewer 

Area Name: Operating Area Name

DEISD-6 July 2010 
 

FEDERAL REGULATORY APPLICABILITY / SPCC PLAN CROSS-REFERENCE 

Citation Description Heading (Page) 

Part A Part B 

Subpart A Applicability, Definitions, and General Requirements for All Facilities and All 

Types of Oil 

(See Below) 

§112.3(d) Professional Engineer Certification B.1.2. 

§112.3(e) Plan Copy A.1.1. 

§112.4 Amendment of SPCC Plan by Regional Administrator A.2.2. 

§112.5 Amendment of SPCC Plan by Owners or Operators A.1.3., 

(vi) 

(B-2) 

§112.7 General requirements for SPCC Plans for all facilities and all oil types A.1., (vii) B.1.3. 

§112.7(a) General requirements: discussion of facility’s conformance with rule 

requirements; deviations from Plan requirements; facility characteristics that 

must be described in the Plan; spill reporting information in the Plan; 

emergency procedures and waste management 

A.2., 

A.2.1, 

A.2.2., 

A.2.3., 

A.2.4. 

B.1., 

B.1.1., 

B.1.3., 

B.1.4. 

§112.7(b) Fault analysis B.1.7. 

§112.7(c) Secondary containment B.1.9. 

§112.7(d) Contingency planning A.1.4. 

§112.7(e) Inspections, tests, and records A.1.5. 

§112.7(f) Employee training and discharge prevention procedures A.1.6. 

§112.7(g) Security (excluding oil production facilities) A.1.7. 

§112.7(h) Loading/unloading (excluding offshore facilities) B.1.5.5. 

§112.7(i) Brittle fracture evaluation requirements B.1.8. 

§112.7(j) Conformance with State requirements A.1.8. 

§112.7(k) Qualified Oil-filled Operational Equipment B.1.9. 

Subpart B Requirements for Petroleum Oils and Non-Petroleum Oils, Except Animal 

Fats and Oils and Greases, and Fish and Marine Mammal Oils; and 

Vegetable Oils (Including Oils from Seeds, Nuts, Fruits, and Kernels) 

(See Below) 

§112.8 Requirements for onshore facilities (excluding production facilities) (See Below) 

§112.8(a) General and specific requirements (See Below) 

§112.8(b) Facility drainage B.1.10. 

§112.8(c) Facility bulk storage containers A.1.5. B.1.6., 

B.1.9. 

§112.8(d) Facility transfer operations, pumping and facility processes B.1.5. 

§112.9 Requirements for onshore production facilities NA NA 

§112.10 Requirements for onshore oil drilling and workover facilities NA NA 

§112.11 Requirements for offshore oil drilling, production, or workover facilities NA NA 

Subpart C Requirements for Animal Fats and Oils and Greases, and Fish and Marine 

Mammal Oils; and Vegetable Oils, Including Oils from Seeds, Nuts, Fruits, 

and Kernels 

(See Below) 

§112.12 Requirements for onshore facilities (excluding production facilities) NA NA 

§112.13 Requirements for onshore oil production facilities NA NA 

§112.14 Requirements for onshore oil drilling and workover facilities NA NA 

§112.15 Requirements for offshore oil drilling, production, or workover facilities NA NA 

Subpart D Response Requirements (See Below) 

§112.20 Facility response plans A.3., A.4. 

§112.21 Facility response training and drills/exercises NA NA 

DEIS D-7 July 2010 
 

 

 

SPILL PREVENTION, CONTROL, AND COUNTERMEASURE PLAN 

Company Name 

Facility or Area Name 

PART A – GENERAL PLAN REQUIREMENTS 

A.1. GENERAL INFORMATION 

The regulations requiring preparation of SPCC Plans were revised by USEPA on July 17, 2002 and 

December 26, 2006. The SPCC regulations are intended to prevent the discharge of oil into or upon the 

navigable waters of the United States. The regulations, which are codified in 40 CFR 112 (each relevant 

regulatory citation is identified by brackets), require that facilities that have the potential to impact 

navigable waters and with aboveground oil storage capacity of 1,320 gallons or more, exclusive of exempt 

containers, prepare and implement an SPCC Plan. 

This Plan is presented in two parts: 1) a Part A that contains Area-specific information that is associated 

with all of the Facilities within that Area, and 2) a Part B for each Facility in the Area that contains the 

SPCC information specific to that Facility. Thus, Part A in its entirety is fully incorporated into each Part B 

and each Part B relies on and incorporates the information contained in Part A. In accordance with 

40 CFR 112, a Cross-Reference Table is included in Part A of this Plan and indicates which provisions are 

located in the Part A and/or Part B. The Table of Contents for this Plan also serves as a cross-reference. 

A.1.1. Plan Copy [§112.3(e)] 

A complete copy of the SPCC Plan will be maintained either at the facility, if normally attended at 

least four hours per day, or at the nearest manned office and will be available for onsite review during 

normal working hours. 

A.1.2. Management Approval [§112.7] 

I hereby certify that this document and all attachments have full management approval and will be fully 

implemented under my direction or supervision. Based on my inquiry of the person or persons who 

manage the Facilities, or those persons directly responsible for gathering information, the information 

submitted is, to the best of my knowledge and belief, true, accurate, and complete. Should a discharge 

occur, Management is committed to provide the necessary manpower, equipment, and resources required 

to expeditiously control and remove any harmful quantity of oil discharged. 

Name: Management Name Signature: 

Title: Management Title Date: 

DEIS D-8 July 2010 
A.1.2.1. Designated Person Accountable for Oil Spill Prevention at the Facility [112.7(f)(2)] 

The following Designated Person is accountable for discharge prevention and reports to the 

management personnel listed above. 

Name: Designated Person 

Title: Designated Person Title 

A.1.3. Amendment of Plan by Owner or Operator [§112.5] 

The SPCC Plan will be revised whenever there is a change to facility design, construction, 

operation, or maintenance that materially affects the Facility’s potential for discharge as described 

in 40 CFR 112.1(b) and/or as described in the Log of Plan Review and Amendments of this Plan. As 

required by the regulations, the Plan will be revised within six (6) months of such facility change. 

All amendments will be properly authorized by Facility management and will be implemented as soon as 

possible, but not later than six (6) months following the preparation of the amendment. Technical 

amendments will be certified by a Professional Engineer as required by 40 CFR 112.5(c) and kept as an 

attachment to this plan. The completion of the Plan reviews will be documented on Log of Plan Review 

and Amendments attached to the Plan. 

Facility management will review and evaluate the entire Plan for its adequacy at least once every 

five (5) years. At the conclusion of this review, management must affirmatively document the review by 

completing the Log of Plan Review and Amendments. 

If as a result of this review and evaluation, the Plan requires amendment, it must be amended within six 

(6) months of the completion of the review to include more effective prevention and control technology, if 

the technology has been field-proven at the time of the review and will significantly reduce the likelihood of 

a discharge as described in 40 CFR 112.1(b). 

A.1.4. Oil Spill Contingency Plan [§112.7(d)] 

The operator has determined that for its bulk storage and process containers, the use of containment 

and/or diversionary structures to prevent discharged oil from reaching navigable waters is practical and 

effective at the facilities covered under this Part A. The operator has implemented an Oil Spill 

Contingency Plan for those facilities that have wellheads, oil-filled equipment, truck loading areas, 

flowlines and gathering lines not equipped with secondary containment. The Oil Spill Contingency Plan 

serves as a written commitment of manpower and resources as discussed in each facility's SPCC Part B, 

Section B.1.9. Facilities are visited on a frequent basis and any spills or accidental releases of oil are 

properly cleaned up. 

DEIS D-9 July 2010 
 

 

A.1.5. Inspections, Tests And Records [§112.7(e), §112.8(c)(4), (6), (8) and (10)] 

Inspection procedures and a record of the inspections and tests, signed by the appropriate 

supervisor or inspector, will be kept with the Plan for a period of three years. If during any 

inspection, equipment or a containment system is found to be malfunctioning, resulting in a loss of oil from 

the container, including but not limited to seams, gaskets, piping, pumps, valves, rivets, and bolts, the tank 

or structure will be removed from service and appropriate repairs completed. 

A documented leak test for every buried metallic storage tank will be completed annually. Defects 

discovered in the course of the testing will result in the tank being removed from service and repaired as 

soon as practicable. 

A documented visual inspection for every bulk storage container system, oil and water containing 

process unit, and containment structure will be completed annually. Tank, heater treater, separator 

and other process container inspections will seek out evidence of wear, defect, and releases in the oil and 

water containing units and their support system. Inspections of containment areas will seek out general 

damage, breach of the floor, breach of the walls and releases. Defects discovered in the course of the 

inspections will be repaired as soon as practicable. See Appendix A for sample Annual Inspection forms. 

A non-destructive integrity test will also be conducted on a regular basis on all aboveground bulk 

storage container systems. Options include hydrostatic testing, radiographic testing, ultrasonic testing, 

or acoustic emission testing. The frequency of and type of testing must take into account container size 

and design, and should follow manufacturer’s recommendations or industry accepted practices. Process 

Safety Management (PSM) facilities may also have recommended testing frequencies for bulk storage 

containers. Defects discovered in the course of the testing will result in the tank being removed from 

service and repaired as soon as practicable. 

Liquid level sensing devices, installed in storage containers, will be tested on a regular basis. The 

frequency of testing should follow manufacturer’s recommendations or industry accepted practices. 

Process Safety Management (PSM) facilities may also have recommended testing frequencies for these 

types of devices. Malfunctioning devices will be removed from service and repaired or replaced as soon 

as practicable. 

A.1.6. Personnel Training [§112.7(f)] 

Appropriate oil-handling personnel will be trained in discharge prevention and spill response prior 

to the assignment of job responsibilities. Training will be completed under the charge of the 

Designated Person, as identified in Section A.1.2.1 of this Plan, (Designated Person) or a qualified, 

designated representative. Training may be done in conjunction with other materials handling training. At 

a minimum the training will include: 

• Operation and maintenance of equipment to prevent discharges; 

• Discharge emergency protocols; 

• Applicable pollution control laws, rules, and regulations; 

• General Facility operations; and 

DEIS D-10 July 2010 
 

• The contents of the SPCC Plan. 

A discharge prevention briefing for appropriate oil-handling personnel will be scheduled at least 

annually (this may be done in conjunction with other required annual training) and will be documented in 

the Area training logs. At a minimum, annual briefings will include: 

• The contents of the SPCC Plan; 

• Descriptions of known discharges or failures and their corrective actions; 

• Malfunctioning components; and 

• Recently developed precautionary measures. 

A.1.7.	 Security [§112.7(g)] 

The Facilities operate 24 hours per day, 365 days per year. Each facility handling, processing or storing 

oil is fully fenced. Entrance gates are locked when the facility is unattended. All valves, including master 

and drain valves that allow for the direct flow of oil from a container to the surface, are secured in the 

closed position when not in operation. When not in operation, controls for oil pumps will be locked in the 

"off" position. Pump controls are located at sites accessible only by authorized personnel. Loading and 

unloading oil pipelines will be securely capped or blanked-flanged when not in service. Where practicable, 

lighting is provided commensurate with the type and location of the facility. 

A.1.8.	 Conformance with State Requirements [§112.7(j)] 

This SPCC Plan conforms to all State rules, regulations, and guidelines. Appropriate state reporting 

guidelines are provided in the Oil Spill Contingency Plan. 

A.2.	 SPILL REPORTING AND RESPONSE [§112.7(a)] 

Pursuant to Section 112.2, the term ‘discharge’ means ‘spilling, leaking, pumping, pouring, emitting 

emptying or dumping of oil’. For the purpose of this Plan the terms discharge, spill and release shall be 

synonymous. Additional information with regard to spill reporting and response can be found in the Oil 

Spill Contingency Plan. 

A.2.1.	 Emergency Contact Information [§112.7(a)(3)(vi)] 

The emergency contact lists for responding to spills are provided in the Oil Spill Contingency Plan. 

A.2.2.	 Spill Reporting Requirements and Amendment of Plan by Regional Administrator 

[§112.4(a), §112.7(a)(4) and §112.7(a)(5)] 

The requirements for spill notification and reporting to local, state, and/or federal officials depend upon 

the nature and extent of the spill. Notification of and reporting to federal, state, and local agencies may 

be required as referenced in the Oil Spill Contingency Plan. A copy of the spill report form is provided in 

Appendix A and should be used to assist in meeting the reporting requirements identified below. Nonreportable spill events must be addressed immediately by containing, removing, and disposing of the 

released material according to applicable regulations. 

DEIS	 D-11 July 2010 
 

 

Also note, that there are special reporting requirements for facilities that experience reportable spills to 

navigable waters as reference in 40 CFR 112.1(b) of 1,000 gallons (238 bbls) or more or that 

experience two (2) reportable spills as reference in 40 CFR 112.1(b) of greater than 42 gallons (1 bbls) 

each within a 12-month period. Those facilities meeting one or both of these criteria are required to 

submit a report to the Regional Administrator within 60 days of the spill event (see Regional 

Administrator Reporting Form in Appendix A). 

After review of the information submitted, or after an on-site review of the Plan, the Regional Administrator 

may require an amendment to the Plan if the Regional Administrator finds that the Plan does not meet the 

requirements of 40 CFR 112 or if an amendment is necessary to prevent and contain discharges at the 

Facility. 

A.2.2.1. Spill Reporting and Response Requirements 

Following discovery of a spill, on-scene personnel should notify their Supervisor and/or the Designated 

Person as soon as practicable. If the situation allows, on-scene personnel should also attempt to 

control or eliminate the source of the spill. 

A preliminary spill assessment is to be conducted by on-scene personnel to provide the Designated 

Person with the information necessary to initiate the appropriate response. A Spill Report Form (see 

Appendix A) should be completed, provided to the Designated Person and include the following 

information: 

•	 Date and time of incident; 

•	 Type and estimated total quantity of material released; 

•	 Source and cause of the release; 

•	 Description of all affected media and assessment of environmental conditions such as 

precipitation, wind speed and direction, and temperature; 

•	 Estimated spill destination and local topography; 

•	 Assessment of immediate danger to human life or health or to the environment, including outside 

the Facility, and extent of damages or injuries, if any and 

•	 Actions being used to stop, remove, and mitigate the effects of the release. 

A.2.3. Emergency Response Procedures [§112.7(a)(3)(iv) and (a)(5)] 

If a spill occurs, Facility personnel trained in accordance with the training requirements of this Plan, or their 

Contractors listed in the Oil Spill Contingency Plan, will respond as outlined in Figure A-1 Emergency 

Response Flowchart and Responsibilities. 

A.2.3.1. Spill Discovery and Response 

In the event of a release, the observer will move to a place of safety in relation to the spill. Only if trained 

to do so and if it is safe, the observer will take reasonable efforts to stop or control the source of the spill. 

DEIS	 D-12 July 2010 
 

 

The observer will immediately report the spill to their Supervisor and/or Designated Person. If necessary, 

the Designated Person, or his designee, will notify the On-Scene Commander to assess the situation and 

initiate response actions. The Designated Person, or his designee, will then determine if the spill is 

reportable, notify the appropriate Agencies, and provide the information listed on the spill report form in 

Appendix A. 

The spill will be isolated and cleaned up as directed by the Designated Person and/or On-Scene 

Commander. In general, the procedures to be used are as follows: 

•	 Identify the material spilled and its source; 

•	 Remove all sources of ignition; 

•	 Take appropriate measures to stop the flow of material; 

•	 Quickly determine the size and flow direction of the spill; 

•	 If possible, contain the spill with equipment and materials located within the area; 

•	 Determine if the spill can be handled by Facility personnel or whether an emergency clean-up 

contractor must become involved; 

•	 Recover spilled material and dispose of properly; and 

•	 Complete the Spill Reporting Form (Appendix A) as directed by the Designated Person and/or OnScene Commander. 

A.2.3.2. Spill Response Resources 

The necessary response personnel, materials, contractors, and equipment are listed in the Oil Spill 

Contingency Plan and will be mobilized as needed to respond to each spill. Resources are as follows: 

•	 Emergency Response Personnel - Manage and/or conduct emergency response actions. All 

emergency response personnel have full authority to implement response actions. 

•	 Emergency Response Contractors - Emergency response personnel utilize emergency response 

contractors to supplement internal resources. 

•	 Emergency Response Authorities - Emergency response personnel have access to a number of 

external emergency response authorities who can provide assistance during spill response 

events. 

•	 Spill Response Equipment and Materials - Various spill response materials are maintained in the 

area of the Facilities. These materials are stored either at the facility or supplied by contractors 

and are available for use by Company Emergency Response Personnel and Emergency 

Response Contractors. 

A.2.4. Recovered Materials Management [§112.7(a)(3)(v)] 

Following an emergency response incident, the On-Scene Commander and any involved contractors 

will ensure that any material recovered is properly characterized and managed in accordance with 

applicable regulations. Additionally, following the completion of spill response and cleanup activities, 

DEIS	 D-13 July 2010 
emergency equipment and supplies will be decontaminated and returned to storage or replaced, as 

appropriate. 

A.3. Substantial Harm Determination [§112.20] 

A Substantial Harm determination has been conducted for all SPCC Facilities covered by this Part A. A 

certified Substantial Harm Checklist has been signed and attached as Figure A-2. 

A.4. Facility Response Plan [§112.20] 

In accordance with 40 CFR 112.20, it has been determined that a Facility Response Plan is not required 

for any SPCC Facility covered by this Part A. To support this determination, a certified Substantial Harm 

Checklist has been signed and attached as Figure A-2. 

DEIS D-14 July 2010 
Discovery of Spill 

ntrol the source of the spill 

Notify Supervisor and 

Di d P 

ed Person Summon emergency medical and 

fire personnel, as warranted 

Notify Incident 

Commander 

Report spill to Agencies 

Submit written reports to 

Agencies 

On-Scene 

Commander 

Notify EHS, Legal and 

Operations personnel 

Initiate response 

actions 

Recover free liquids 

Cleanup, remediate and 

reclaim impacted area 

Coordinate third party 

contractors, as 

Characterize waste 

materials and manage 

accordingly 

Control and eliminate the 

source of the spill 

FIGURE A-1 

EMERGENCY RESPONSE FLOWCHART AND RESPONSIBILITIES 

DEIS D-15 July 2010 
 

 

 

 

 

 

 

 

 

 

FIGURE A-2 SUBSTANTIAL HARM CRITERIA CHECKLIST [§112.20] 

AREA NAME: 

AREA ADDRESS 

Operating Area Name 

Area Address Line 1 

City, State 

1.	 Do any of the facilities covered in this plan 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 No 

2.	 Do any of the facilities covered in this plan 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 oil storage tank area? 

Yes No 

3.	 Do any of the facilities covered in this plan 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 formula in Attachment C-III, Appendix C, 40 CFR 112 or a comparable 

formula1

) such that a discharge from the facility could cause injury to fish and wildlife and sensitive environments? For further 

description of fish and wildlife and sensitive environments, see Appendices I, II, and III to DOC/NOAA’s “Guidance for Facility 

and Vessel Response Environments” (§10, Appendix E, 40 CFR 112 for availability) and the applicable Area Contingency Plan. 

Yes No 

4.	 Do any of the facilities covered in this plan 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 formula in Attachment C-III, Appendix C, 40 CFR 112 or a comparable 

formula1

) such that a discharge from the facility would shut down a public drinking water intake2? 

Yes No 

5.	 Do any of the facilities covered in this plan 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 No 

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 information, I believe that the submitted information is true, 

accurate, and complete. 

Certifying Person Name 

Name (please type or print) Signature 

Certifying Person Title 

Title Date 

From 40 CFR 112 Appendix C, Attachment C-II 

1

 If a comparable formula is used, documentation of the reliability and analytical soundness of the comparable formula must be attached to this form. 

2

 For the purposes of 40 CFR part 112, public drinking water intakes are analogous to public water systems as described at 40 CFR 143.2(c). 

DEIS D-16 July 2010 
ATTACHMENT A 

FORMS 

Spill Report Form
 

Regional Administrator Reporting Form 

Annual Inspection Checklist 

SPCC Drainage Inspection and Discharge Log 

DEIS D-17 July 2010 
 

 

 

 

 

 

 

 

 

 

 

 

 

_____________________________________________________________________________________ 

 

 

 

REGIONAL ADMINISTRATOR REPORTING FORM [§112.4(a)] 

When reporting a discharge under 40 CFR 112.4(a), the information listed in the Regional Administrator Reporting 

Form must be submitted to the Regional Administrator within 60 days. (Check as appropriate) 

This Facility has experienced a reportable spill as referenced in 40 CFR Part 112.1(b) of 1,000 gallons (23.8 bbls) 

or more 

This Facility has experienced two (2) reportable spills as referenced in 40 CFR Part 112.1(b) of greater than 42 

gallons (1 bbls) each within a 12-month period. 

FACILITY NAME AND LOCATION: 

CONTACT PERSON (NAME, ADDRESS/PHONE NUMBER):
 

MAXIMUM STORAGE/HANDLING CAPACITY: 

NORMAL DAILY THROUGHPUT: 

CORRECTIVE ACTION/COUNTERMEASURES: 

FACILITY DESCRIPTION (Include maps and facility diagrams as needed): 

CAUSE OF DISCHARGE/FAILURE ANALYSIS:
 

PREVENTIVE MEASURES TAKEN: 

Name (please type or print) Signature 

Title Date 

DEIS D-18 July 2010 
 

_______________________________________________________________________________________ 

_______________________________________________________________________________________ 

_______________________________________________________________________________________ 

___ 

 

B.1 

SPILL PREVENTION, CONTROL AND COUNTERMEASURE PLAN 

Company Name 

Facility or Area Name 

PART B – FACILITY INFORMATION 

FACILITY NAME AND LOCATION [§112.7(a)(3)] 

Facility or Area Name WINS No: NA 

Legal Location (Section / Township / Range) 

 County/Parish, State 

Latitude: Latitude Longitude: Longitude 

Directions to the Facility: 

B.1.1 Designated Person at Facility [§112.7(f)(2)] 

Name: Designated Person Name Title: Designated Person Title 

B.1.2 Professional Engineer Certification [§112.3(d)] 

By means of this Professional Engineer Certification, I hereby attest to the following: 

•	 I am familiar with the requirements of Title 40, Part 112 of the Code of Federal Regulations (40 CFR 

112); 

•	 That I, or my agent, has visited and examined the above referenced Facility; 

•	 That this Spill Prevention, Control and Countermeasure Plan, Parts A and B, (the Plan) has been 

prepared in accordance with good engineering practice, including applicable industry standards, and 

with the requirements of 40 CFR 112; 

•	 That procedures for inspections and testing have been established; and 

•	 This Plan is adequate for the Facility. 

Date: 

Name: 

(Seal) Signature: 

Company: 

Registration No.: 

State: 

The Facility recognizes that, in accordance with 40 CFR 112.3(d)(2), engineer certification in no way relieves 

the Facility of the responsibility to prepare and fully implement the Plan. 

DEIS	 D-19 July 2010 
 

 

 

 

 

LOG OF PLAN REVIEW AND AMENDMENTS - PART B 

NON-TECHNICAL AMENDMENTS 

• Non-technical amendments are not certified by a Professional Engineer. 

• Examples of changes include, but are not limited to, phone numbers, name changes, or any non-technical text 

change(s). 

TECHNICAL AMENDMENTS 

• Technical amendments are certified by a Professional Engineer (§112.5(c)). 

• Examples of changes include, but are not limited to, commissioning or decommissioning containers; 

replacement, reconstruction, or movement of containers; reconstruction, replacement, or installation of piping 

systems; construction or demolition that might alter secondary containment structures; changes of product or 

service; or addition/deletion of standard operation or maintenance procedures related to discharge prevention 

measures. It is the responsibility of the field to determine, and confirm with the regulatory authority as 

necessary, what constitutes a technical amendment. The preamble of the rule states that an amendment is 

required only “when there is a change that materially affects the facility’s potential to discharge oil” (67 FR 

47091). 

• An amendment made under this section will be prepared within six (6) months of the change and implemented 

as soon as possible but not later than six (6) months following preparation of the amendment. 

• Technical Amendments affecting various pages within the Plan will require P.E. certification of the Plan and will 

be documented on the log form below. 

MANAGEMENT REVIEW 

• Management will review this SPCC Plan at least every five (5) years and document the review on the form 

below (§112.5(b)). 

• By signature below, signor confirms that management has completed a review and evaluation of this SPCC 

Plan. 

Review/ 

Amend 

Date 

Signature* 

(Specify) 

Amend Plan 

(will/will not) 

Description of 

Review/Amendment 

Affected 

Page(s) 

P.E. 

Certification 

(Y/N) 

*Typically signed by Manager, Professional Engineer or Plan Reviewer 

Facility Name: Facility Name 

DEIS D-20 July 2010 
 

B.1.3. Facility Conformance with SPCC Rule [§112.7(a)(1) and (a)(2)] 

This Plan is presented in two parts: (1) a Part A which contains Area-specific information that is associated 

with all of the Facilities within that Area and (2) a Part B for each Facility in the Area that contains the SPCC 

information specific to that Facility. Thus, Part A in its entirety is fully incorporated into each Part B and 

each Part B relies on and incorporates the information contained in Part A. In accordance with 40 CFR 

112.7, a Cross-Reference Table is included in Part A of this Plan and indicates which provisions are located 

in the Part A and/or Part B. 

As an onshore natural gas processing facility, the following sections of SPCC regulations apply: Sections 

112.1 through 112.8. Section 112.9 does not apply because it addresses onshore oil production facilities. 

Section 112.10 is not applicable to this Facility and is only applicable to those Facilities where the company 

is the owner and/or operator of an onshore oil drilling and workover facility. Section 112.11 does not apply 

because it specifically applies to offshore facilities. Sections 112.12 through 112.15 are not applicable 

because the Facility does not store, use or process animal fats and oils and greases. Sections 112.20 and 

112.21 do not apply because this facility is not required to maintain a Facility Response Plan. 

The Facility is in conformance with all applicable requirements specified in 40 CFR 112.7 and 112.9 unless 

noted in Table B-1. 

B.1.4. Facility Description [§112.7(a)(3)] 

EXAMPLE: Natural gas produced in the surrounding field is routed to the Facility via the gas collection 

system (Figure B-2). Natural gas enters the Facility through the inlet scrubber, where liquids are gravity 

separated from the stream. The natural gas is then compressed in three stages from approximately 0.5 

pounds per square inch gauge (psig) to 500 psig. Between the second and third stages of compression, the 

natural gas is diverted to the amine system for the removal of hydrogen sulfide (H2S) and carbon dioxide 

(CO2). Diethanolamine is utilized to absorb the H2S and CO2 from the natural gas stream. Once removed 

from the natural gas stream, the H2S and CO2 are piped to the sulfur recovery system. A modified Claus 

process is employed to convert the H2S into elemental sulfur. 

Upon exiting the amine system, the natural gas is routed to the third stage compressors and then to the lean 

oil system. Lean oil is utilized to absorb the propane, butane and natural gasoline contained in the natural 

gas stream. Methane and ethane exit the main absorber and are sent to the plant fuel system. The 

propane, butane and natural gasoline are recovered by heating the lean oil and flashing the mix from the oil. 

The mixed propane, butane and natural gasoline stream is combined with third party natural gas liquids and 

piped to the fractionation system. Following the consolidation of the streams, the new stream enters the 

caustic system to remove any residual H2S and other sulfur compounds. The combined stream is then 

returned to the fractionation system where propane, butane and natural gasoline products are separated 

and directed to storage. The three products are trucked offsite. 

Triethylene glycol is utilized to remove water vapor from various gas streams at the Facility. 

DEIS D-21 July 2010 
 

 

 

Operations at the Facility are controlled from a centralized control room. A Foxboro computer control 

system and associated pneumatic controls allow an operator to monitor and adjust the processes from the 

control room. 

B.1.5.	 Facility Transfer Operations [§112.8(d)] 

B.1.5.1. Buried Piping Protection and Examination [§112.8(d)(1)] 

Newly installed or repaired buried piping will be wrapped, coated to minimize corrosion. The buried 

piping will also be cathodically protected unless it is determined that cathodic protection is not appropriate 

considering site-specific conditions, facility configuration, and other engineering factors. If cathodic 

protection is determined infeasible, other protective measures to assess and ensure the continued fitness 

for service of piping will be implemented. Additionally, any exposed buried piping will be inspected for 

deterioration and repaired/replaced as appropriate. 

B.1.5.2. Not-In-Service and Standby Service Terminal Connections [§112.8(d)(2)] 

If piping is taken out of service or is put in standby service for an extended time, all terminal connections at 

the transfer point will be capped or blind-flanged, and marked as to origin. 

B.1.5.3. Design of Pipe Supports and Protection from Vehicular Traffic [§112.8(d)(3) and (5)] 

Pipe supports are designed to minimize abrasion and corrosion and allow for expansion and contraction of 

the associated piping. The aboveground piping at the Facility is protected from vehicular traffic. 

B.1.5.4. Aboveground Piping and Appurtenance Protection and Examination [§112.8(d)(4)] 

The Facility’s aboveground piping is inspected annually for wear, failure and leakage. During the 

course of inspection, valves, joints and other connections will be assessed by the inspector, as well as 

external pipe supports. The Inspection Checklist included in Part A, Appendix A will be utilized to guide 

and document the inspection of SPCC Facilities. Completed checklist forms will be maintained in the 

nearest field office along with the Plan. 

Integrity and leak testing of buried piping must be conducted at the time of installation, 

modification, construction, relocation, or replacement. 

B.1.5.5. Loading/Unloading Racks [§112.7(h)] 

This Facility is not equipped with loading/unloading racks; therefore this section is not applicable. 

B.1.6.	 Facility Storage and Bulk Storage Containers [§112.7(a)(3)(i), 112.7(i), 112.8(c)(1), (4), (5), (7) 

and (8)] 

The Facility is equipped with the petroleum product containers listed in Table B-1. 

B.1.6.1.	 Tank Compatibility with Contents [§112.8(c)(1)] 

All containers are compatible with the material stored within and the conditions of storage. See Table B-1 

for a listing of each container type. 

DEIS	 D-22 July 2010 
 

 

 

B.1.6.2. Engineer or Update Each Container [§112.8(c)(8)] 

‘Good engineering practice’ for container installations at non-production facilities includes four elements: (1) 

high liquid level alarms, (2) high liquid level pump cutoff devices, (3) direct audible or code signal 

communications and (4) a fast response system for determining the liquid level of each bulk storage 

container. In accordance with 112.8(c)(8), every container installation must be equipped with at least one of 

four ‘good engineering practice’ elements. The Facility employs at least one of the above 'good engineering 

practices'. 

B.1.6.3. Buried or Partially Buried Metallic Tanks [§112.8(c)(4) and (5)] 

If present, buried and partially buried metallic storage tanks will be protected from corrosion through 

coatings or cathodic protection compatible with local soil conditions. 

B.1.6.4. Internal Heating Coils [§112.8(c)(7)] 

If present, steam and exhaust return lines associated with internal heating coils must be monitored if the 

system discharges to a waterway. If the system does not discharge to a waterway, then the steam and 

exhaust return lines must be routed through a settling tank, skimmer or other separation or retention 

equipment. 

B.1.7. Fault Analysis [§112.7(b)] 

Where there exists a reasonable potential for equipment failure, the Plan must include a prediction of the 

direction, rate of flow and total quantity of oil which could be discharged from each type of failure. For this 

Facility, potential discharges of oil include container and/or pipe failure and spills. Potential spill sources 

(equipment), total quantity of oil (capacity), rate of flow (rate) and prediction of the flow path (flow direction) 

are summarized in Table B-1. 

B.1.8. Brittle Fracture Evaluation [§112.7(i)] 

Field constructed containers must be reevaluated after each repair or change of service to confirm 

that they are not vulnerable to a brittle fracture failure. A qualified professional will be secured to do 

each evaluation and, should risk of brittle fracture be found during evaluation, the container will be repaired 

or taken out of service and replaced, as appropriate. This reevaluation procedure will be performed in 

addition to the annual inspections. See Table B-1 for a listing of those containers at the Facility that were 

field constructed. 

B.1.9. Secondary Containment [§112.7(c), §112.7(k) and §112.8(c)(2) and (11)] 

All dikes and berms are constructed of material (i.e. metal, compacted earth, concrete) that is sufficiently 

impervious to contain oil. Secondary containment is considered practicable for the Facility with the 

exception of the following: 

•	 Inlet flowlines and some facility piping may not be provided with a means of secondary 

containment as specified by 112.8. The long distances involved along with physical, 

geographical and road/fenceline right-of-way constraints make secondary containment 

impracticable. Furthermore, such permanent containment structures would create land erosion 

and access problems for landowners. 

•	 Undiked areas within the facility may not be provided with secondary containment due to limited 

space and/or safety hazards. 

DEIS	 D-23 July 2010 
 

Some oil-filled operational equipment may not be provided with secondary containment. Examples of oilfilled operational equipment include, but are not limited to, hydraulic systems, lubricating systems (i.e., 

those for pumps, compressors and other rotating equipment, including pumpjack lubrication systems), 

gear boxes, machining coolant systems, heat transfer systems, transformers, circuit breakers, electrical 

switches, and other systems containing oil solely to enable the operation of the device. 

For the equipment and/or areas listed above, an Oil Spill Contingency Plan has been prepared and will be 

implemented in case of a spill. An inspection and monitoring plan has been established for the oil filled 

equipment that does not have secondary containment. Drain lines from diked areas or catchment basins 

must utilize manual open and close valves. Mobile and portable oil storage containers should be 

positioned within the facility to prevent a discharge. A description of the secondary containment is 

provided in Table B-1 and in the facility diagram. 

B.1.10. Facility Drainage [§112.8(b) and (c)(9)] 

Small quantities of stormwater collected inside berms are typically lost through evaporation. Water 

accumulated in the secondary containment areas will be inspected prior to discharge to confirm that it 

does not pose a threat of a harmful discharge. A harmful discharge is defined as one that violates 

applicable water quality standards or causes a film or sheen upon or discoloration of surface water or 

adjoining shorelines. 

Field drainage systems and road ditches will be visually inspected on a regular basis for accumulation of 

oil or oil impacted soil. Accumulations of oil will be recovered promptly and placed in the production 

system or taken to an approved disposal site. Discharges of stormwater will occur using the following 

procedures: 

•	 Prior to discharge, the water must be visually inspected for the presence of oil or oily sheen. If oil 

is present, the water cannot be discharged and must be recovered and placed into the production 

system or taken to an approved disposal site. 

•	 All discharges of stormwater from secondary containment must be recorded. The date of 

the discharge must be noted on the SPCC Drainage Inspection and Discharge Log form. 

If the secondary containment is equipped with a drain, the drain must be closed and sealed when it is not in 

use. 

DEIS	 D-24 July 2010 
TABLE B-1 SITE SPECIFIC DATA 

FACILITY NAME: Facility or Area Name DATE: MM/DD/YYYY 

EQUIPMENT CONTENTS CAPACITY TYPE FIELD CONSTRUCTED? TYPE OF FAILURE RATE (bbl/hr) FLOW DIRECTIO

Inlet Scrubber 

V8-201 

NGL 126 bbls Steel No 

Structural 

Failure/Spill 

32 ESE 

Total SPCC Volume: Up to 200 barrels 

*Largest container size used to determine amount of secondary containment required. NA – Not Applicable 

DEIS D-25 
CONTAINMENT CALCULATION 

Western Side of Facility Surface flow within the confines of the western side of the Facility is collected by the drainage channels and is then directed to either a Colle(1)	 Calculate Total Containment Capacity 

Containment = Length x Width x Height Collection Basin = 100 ft x 100 ft x 2 ft = 20,000 ft3 

20,000 ft3 x 7.48 gal/ft3 x 1bbl/42 gal = 3562 bbl 

Gully = 120 ft x 13 ft x 5 ft = 7800 ft3 

7800 ft3 x 7.48 gal/ft3 x 1bbl/42 gal = 1389 bbl 

(2)	 Calculate Net Containment Capacity 

Net Capacity = Total Capacity – Displacement of single largest tank? Displacement = Footprint (of what?) x Dike Height No Additional Equipment in Containment Structures Net Capacity = 3562 bbl + 1389 bbl = 4951 bbl 

(3)	 Calculate Freeboard 

Required Freeboard = Storm Event x Dike Footprint The 24-hour 25-year storm event for the area is expected to produce 2.6 inches (0.22 ft) of precipitation. 0.22 ft x 1100 ft x 550 ft = 133,100 ft3 (Dimensions of fenced area) 

133,100 ft3 x 7.48 gal/ft3 x 1 bbl/42 gal = 23,704 bbl
 Approximately 20 percent of the runoff is assumed to enter the Collection Basin and Gully via the Drainage Channels, based on FacRequired Freeboard = 23,704 x 0.20 = 4741 bbl
 

(4)	 Calculate Excess Containment Capacity 

Excess Capacity = Net Capacity – Rain Freeboard – Volume of Largest Container 4951 bbl – 4741 bbl – 45 bbl = 165 bbl of Excess Containment Capacity 

Eastern Side of Facility Surface flow within the confines of the eastern side of the Facility is contained by a series of berms, the Evaporation Pit and the Catch Basin

(1)	 Calculate Total Containment Capacity 

Containment = Length x Width x Height Earthen Berm DS = 190 ft x 60 ft x 1 ft = 11,400 ft3 

11,400 ft3 x 7.48 gal/ft3 x 1bbl/42 gal = 2030 bbl 

Earthen Berm DS drains to the Evaporation Pit; therefore the berm capacity is limited by the capacity of the pit. Evaporation Pit = 60 ft x 40 ft x 3.7 ft = 8880 ft3 

8880 ft3 x 7.48 gal/ft3 x 1bbl/42 gal = 1581 bbl 

Earthen/Concrete Berm LA = 165 ft x 200 ft x 1.7 ft = 56,100 ft3 

56,100 ft3 x 7.48 gal/ft3 x 1bbl/42 gal = 9991 bbl 

Earthen Berm CB (Catch Basin) = 380 ft x 270 ft x 3 ft = 307,800 ft3 

307,800 ft3 x 7.48 gal/ft3 x 1bbl/42 gal = 54,818 bbl 

DEIS	 D-26 
(2)	 Calculate Net Basin Capacity 

Net Capacity = Total Capacity – Displacement Displacement = Footprint x Dike Height Earthen Berm DS/Evaporation Pit Displacement = No Additional Equipment in Evaporation Pit Net Capacity = 1581 bbl Earthen/Concrete Berm LA Displacement = (π/4) x (21.5 ft)2 x 1.7 ft = 617 ft3 

617 ft3 x 7.48 gal/ft3 x 1 bbl/42 gal = 110 bbl 

Net Capacity = 9991 bbl – 110 bbl = 9881 bbl Earthen Berm CB (Catch Basin) Displacement = No Additional Equipment in Catch Basin Net Capacity = 54,818 bbl Because of the configuration of the berms, once they fill with fluids, they will overflow into the Catch Basin. Therefore, only the C

evaluated. Due to the large amount of equipment within the Facility, a displacement equal to one-third of the surface area (12 incassumed. Also, only 80 percent of the surface area is utilized for this evaluation since 20 percent is assumed to be addressed bstructures. Facility Surface Area Displacement = (1100 ft x 550 ft) x 0.33 x 1 ft x 0.80 = 159,720 ft3 159,720 ft3 x 7.48 gal/ft3 x 1 bbl/42 gal = 28,445 bbl 

Net Capacity = 54,818 bbl – 28,445 bbl = 26,373 bbl 

(3)	 Calculate Freeboard 

Required Freeboard = Storm Event x Dike Footprint The 24-hour 25-year storm event for the area is expected to produce 2.6 inches (0.22 ft) of precipitation. 0.22 ft x 1100 ft x 550 ft = 133,100 ft3 (Dimensions of fenced area) 

133,100 ft3 x 7.48 gal/ft3 x 1 bbl/42 gal = 23,704 bbl
 Approximately 80 percent of the runoff is assumed to enter the Catch Basin, based on Facility topographical features. Required Freeboard = 23,704 x 0.80 = 18,963 bbl
 

(4)	 Calculate Excess Basin Capacity 

Excess Capacity = Net Capacity – Freeboard – Volume of Largest Container 26,373 bbl – 18,963 bbl – 837 bbl = 6573 bbl of Excess Containment Capacity 

DEIS	 D-27 
FIGURES 

DEIS D-28 July 2010 
FIGURE B-1 

DEIS D-29 July 2010 
FIGURE B-2 (optional) 

DEIS D-30 July 2010 
Appendix E 

Reclamation Plan 

DEIS 

July 2010 
Page: 1 of 1 

RECLAMATION PROGRAM FINAL DRAFT 

Date: 01/31/2008 

Revision: 

Contents 

Section Topic Page 

1.0 Introduction 2 

2.0 Applicability 2 

3.0 Goals and Objectives 2 

4.0 Responsibilities 3 

5.0 Pre-Construction and Pre-Disturbance Activities 3 

6.0 Short-Term Reclamation 5 

7.0 Long-Term Reclamation 5 

8.0 Final Reclamation 5 

9.0 Seeding and Re-vegetation 6 

10.0 Monitoring and Performance Assurance 7 

11.0 Training 7 

12.0 Relationship to Contractual Agreements 8 

13.0 Relevant APC Programs 8 

14.0 Document Management 8 

15.0 References 8 

DEIS E-1 July 2010 
Page: 2 of 2 

RECLAMATION PROGRAM Revision: FINAL DRAFT 

Date: 01/31/2008 

1. Introduction 

1.1 For the purposes of this Program, Reclamation is defined as the process of 

returning lands that have been disturbed to a condition that will meet specified 

regulatory requirements and other binding agreements. Anadarko’s Reclamation 

Program establishes the expectations, conditions, guidelines and performance 

standards for reclamation following company activities. 

1.2 Anadarko operates in multiple regulatory jurisdictions with various reclamation 

requirements. This document has been prepared to allow flexibility in order to 

comply with the various agency requirements. 

1.3 This document does not modify government regulatory requirements, other 

internal reporting requirements outside of Environmental, Health and Safety (EHS) 

and Operations, or any specific binding agreement (e.g., lease obligations, surface 

use agreements). 

2. Applicability 

2.1 The Federal Land Policy Management Act of 1976 (FLPMA) mandates that the 

public lands be managed in a manner that will protect the quality of scientific, 

scenic, historical, ecological, environmental, air and atmospheric, water resource, 

and archeological values. 

2.2 This Program applies to disturbed lands on federal-owned surfaces, state-owned 

surfaces and privately-owned surfaces. Reclamation should be conducted on 

disturbed surface that is not necessary for continued production and operation. 

2.3 Typical areas requiring reclamation covered under this Program include: 

• Well Locations 

• Transportation Corridors (e.g., roads) 

• Pipelines / Flowlines 

• Right-of-Ways (ROWs) 

• Pits/Reservoirs 

• Utility Corridors (e.g., water, electricity, communication) 

• Facilities (e.g., compressor stations, tank batteries) 

3. Goals and Objectives 

3.1	 By implementing a Reclamation Program, it is Anadarko’s goal to maintain 

stewardship to the environment, foster good-will with federal, state and local 

DEIS E-2 July 2010 
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RECLAMATION PROGRAM Revision: FINAL DRAFT 

Date: 01/31/2008 

regulatory agencies, be a “good neighbor” with surface owners, and comply with 

all applicable regulations. 

3.2	 Stabilization (Short-Term) Reclamation – The objective of Short-Term 

Reclamation is to stabilize a disturbed area, protect adjacent areas from undue 

degradation during construction and development phases and reduce the cost and 

effort of Interim and Final Reclamation. 

3.3	 Interim (Long-Term) Reclamation – The objective of Interim Reclamation is to 

shape, stabilize, re-vegetate, or otherwise treat disturbed areas in order to provide 

a self-sustaining and productive use of the land during production operations. 

3.4	 Final Reclamation – After production and operations cease, the goal of final 

reclamation is to return the land to a condition that approximates that which 

existed prior to disturbance and maintain a stable and productive condition 

compatible with the land use. 

4. Responsibilities 

4.1 Production Superintendents – Production Superintendents are accountable for 

assuring compliance with this Program. 

4.2 Operations Department – The Operations Department will be responsible for, 

topsoil management, minimizing disturbance, and stabilization of disturbed soil 

throughout project and facility development and operation. 

4.3 Regulatory Department – The Regulatory Department is responsible for 

permitting, notice of intent, subsequent reports of activities and final 

abandonment. The appropriate environmental or reclamation analyst should be 

contacted to follow up any onsite inspections. 

4.4 Regional EHS Department – The Regional EHS Department is responsible for 

designing, implementing, monitoring and tracking the progress of reclamation 

including erosion and weed control measures. The Regional EHS Department 

will also provide the necessary training to the Operations Department. 

5. Pre-Construction and Pre-Disturbance Activities 

5.1	 Reclamation begins prior to surface disturbing activity commencement. 

5.2	 A Baseline Vegetation Survey may be conducted prior to soil disturbing activity. 

The inventory should include the species composition, cover and density. This 

DEIS E-3 July 2010 
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RECLAMATION PROGRAM Revision: FINAL DRAFT 

Date: 01/31/2008 

inventory will aid in the selection of a suitable seed mix and aid in determining 

when final reclamation is complete. 

5.3	 

This information may include, but is not limited to, weeds and soil conditions, 

precipitation maps, soil survey maps, county maps, land use maps, topographic 

maps, survey plats of the proposed project, and an outline of impacts. 

5.4	 The Bureau of Land Management’s (BLM's) placement Best Management 

Practices (BMPs) for Fluid Mineral Operations should be considered. Examples 

of placement BMPs include the following. 

•	 Locations should be selected that will minimize disturbance. The disturbed 

area should be large enough to conduct a safe drilling and production 

operations. Use existing roads whenever possible. Site access should be 

planned for the minimum width. 

•	 Use corridors when possible, (one route for the power line, pipeline, and 

assess road). 

• Consolidating and reducing facility size. 

Preliminary site information may be gathered prior to any soil disturbing activity. 

5.5 The selection of the best soil erosion and sediment controls for the specific site 

should be primarily based on the nature of the construction activity and the 

conditions that exist at the site. Minimum BMPs that should be utilized at each 

site include: 

• Minimize the amount of soil disturbed and preserve existing vegetation, 

• Prevent soil (or sediment) movement from leaving the original location 

within the construction site by the proper installation of erosion controls, 

• Complete scheduled inspection as required by the Storm Water Pollution 

Prevention Plan (SWPPP), and 

• Maintain erosion and sediment control until vegetation has been reestablished. 

5.6	 Prior to site disturbing activities Operations, Regulatory, and EHS Departments 

should meet to discuss: 

• An outline of expectations to operation personnel and contractors 

• Safety issues 

• Top soil management 

•	 Review BMPs for erosion control, soil stabilization, and Short-Term 

Reclamation 

• Review of any site specific Conditions of Approval 

DEIS E-4 July 2010 
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RECLAMATION PROGRAM Revision: FINAL DRAFT 

Date: 01/31/2008 

6. Short-Term Reclamation 

6.1	 Short-Term Reclamation commences as soon as soil disturbing activities begin up 

to completion of construction and drilling activity. 

6.2	 Soil erosion and sediment controls may be implemented to reduce the amount of 

soil that is carried off-site and to reduce the disturbance of the top soil. 

6.3	 Topsoil is an important component of the reclamation process. Topsoil is typically 

the most fertile portion of soil. Minimal topsoil disturbance will aid in the 

reclamation process. Whenever possible, the first 6 to 12 inches of top soil should 

be side cast (never piled) for replacement at a later date. The salvaged topsoil 

should be applied as soon as possible to the area being reclaimed and generally 

within one year. A more detailed description of topsoil management can be found 

in the Handbook of Western Reclamation Techniques (see Section 15, 

References). 

7. Long Term Reclamation 

7.1 Long -Term Reclamation can occur during production operations. The long-term 

reclamation of an area helps stabilize and reduce final reclamation costs. 

Examples of long-term reclamation are listed below. 

• Utility corridors should be backfilled and re-vegetated. 

• The size of the well site should be reduced, if possible, to the area that is 

necessary for safe ongoing operation. Un-used areas at the well site 

should be re-vegetated. 

• Linear features along side roads, such as borrow ditches and utility 

corridors should be re-vegetated. In some cases roads may be narrowed 

and the un-needed portions re-contoured and re-vegetated. 

• Pits, when possible should be closed and backfilled. The surface area recontoured and re-vegetated. 

7.2 A complete description of long-term reclamation projects can be found in the 

Bureau of Land Management’s Goldbook and the Handbook of Western 

Reclamation Techniques (see Section 15, References). 

8. Final Reclamation 

8.1	 Final Reclamation can generally be judged complete when the landscape features 

meet the post-disturbance land use and vegetation shows signs of being selfDEIS E-5 July 2010 
Page: 6 of 6 

RECLAMATION PROGRAM Revision: FINAL DRAFT 

Date: 01/31/2008 

sustaining, vigorous, diverse, and established with a density sufficient to retain 

fundamental resources. 

8.2	 All disturbed areas, including well pads, access roads, pipeline ROWs, should be 

reclaimed per the surface owner standards and /or requirements. 

8.3	 Final reclamation may include re-contouring the area to its original contour, 

seeding, controlling noxious weeds, and other reclamation practices described in 

the Handbook of Western Reclamation Techniques (see Section 15, References). 

8.4	 Reclamation activities will be considered complete when applicable standards 

have been met, when vegetation has reached a minimum of 75 percent of 

background vegetation (undisturbed areas), or as approved by surface owner. 

8.5	 Once Final Reclamation has been achieved, the appropriate regulatory agencies 

should be notified. For example, 

• BLM and/or Bureau of Reclamation – Sundry (Final Abandonment Notice) 

• State Departments of Environmental Quality – Notice of Termination 

• State Oil & Gas Conservation Commissions – Bond release 

• Landowners – Cessation of surface use payments 

9. Seeding and Re-vegetation 

9.1 The goal of seeding is to re-vegetate and stabilize a disturbed site. The result of 

seeding should be a self-sustaining community of perennial vegetation. 

9.2 Seeding and re-vegetation is a component of short-term, long-term, and final 

reclamation. 

9.3 Seeding should occur as quickly as possible during the first appropriate seeding 

season. 

9.4	 The seed mix selected for re-vegetation should include a diverse mix of perennial 

species specified by the surface management agency or surface owner and are 

adapted to the region and consistent with the current land use. The seed mix 

selection should be guided by experiences in similar location and observation of 

undisturbed vegetation in the area and at the discretion of the surface owner. 

9.5	 Certified weed free seed mix should be used. Seeding rates can be calculated 

using the Natural Resource Conservation Service’s Technical Notes Reading Seed 

Packaging Labels and Calculating Seed Mixtures (see Section 15, References). 

DEIS E-6 July 2010 
9.6	 The methodology for seeding should generally be site specific. The 

methodologies for seeding techniques are described in the Handbook for Western 

Reclamation Techniques and Dryland Pastures in Montana and Wyoming (see 

Section 15, References). 

9.7	 Predatory grazing on areas being newly established should be avoided if possible. 

10. Monitoring and Performance Assurance 

10.1	 Monitoring is the orderly and quantitative collection, analysis and interpretation 

of resource data to evaluate progress toward a goal. 

10.2	 The purpose of monitoring is to assess and assure performance and in progression 

toward final reclamation. 

10.3	 Monitoring methodologies and frequency generally should be scientific, 

according to surface use agreements, Bureau of Land Management (BLM) 

methodology, other regulatory requirements, or according to the project 

Conditions of Approval document. 

10.4 Monitoring should continue until at least 75 percent or greater of vegetation, as 

compared to surrounding undisturbed areas, is established. If after two growing 

seasons, progression toward this standard has not been accomplished, further site 

evaluation may be necessary to determine if re-seeding or other actions are 

required to improve reclamation success. 

10.5 Geospatial databases should be used to track the reclamation process. Data that 

should be tracked includes, but not limited to the following. 

• Areas of disturbance 

• Seeding data 

•
 Vegetation progress 

•
 Construction information 

•
 Inspection information 

• Well Data 

• Weed Data 

11. Training 

11.1	 Awareness training of this Program should be conducted by the Regional EHD 

Departments for the Operations Group. Individuals with responsibilities 

involving construction and surface disturbing activities may receive additional 

training beyond awareness training. 

Page: 7 of 7 

RECLAMATION PROGRAM Revision: FINAL DRAFT 

Date: 01/31/2008 

DEIS E-7 July 2010 
Page: 8 of 8 

RECLAMATION PROGRAM Revision: FINAL DRAFT 

Date: 01/31/2008 

11.2	 Training of field level personnel will take place at the following frequency: 

A. Initial Training will involve awareness of the Reclamation Program. 

B. Refresher Training will be conducted on an annual basis. 

11.3	 Training topics can include, but are not limited to: 

• Weeds 

• Top soil management 

• Reclamation practice 

• Erosion control 

12. Relationship to Contractual Agreements 

12.1	 Nothing contained in this Program document shall be construed as altering in any 

way the rights, duties, and/or obligations contained in any applicable contract or 

master service agreement (Contract) between parties. Where a conflict arises 

between this Program document and the Contract, the language in the Contract 

will be controlling. 

13. Relevant APC Programs 

13.1 The following Programs are referenced within the Anadarko Reclamation 

Program: 

A. Applicable Stormwater Pollution Prevention Plans (SWPPP) 

B. The Reasonable and Prudent Practice (RAPPS) for Stabilization of Oil & 

Gas Construction Sites. 

14. Document Management 

14.1	 Reclamation documentation forms, information, and data will be retained in 

Anadarko Field and/or Regional office files in accordance with the Anadarko 

Records Retention Policy (DRM-1). 

DEIS E-8 July 2010 
RECLAMATION PROGRAM 

Page: 9 of 9 

Revision: FINAL DRAFT 

Date: 01/31/2008 

15. References 

15.1	 U.S. Federal Regulations 

A. 43 CFR §3160, Bureau of Land Management – Onshore Oil and Gas 

Operations. 

15.2 Oil and Gas – Surface Operating Standards for Oil and Gas Exploration and 

Development (Gold Book). 

15.1	 Handbook of Western Reclamation Techniques – Second Edition. 2006. 

15.1 Draft - Solid Minerals Reclamation Handbook. 

15.1	 Natural Resource Conservation Service’s Technical Notes – Wyoming. Reading 

Seed Packaging Labels and Calculating Seed Mixtures. June 2001. 

15.1	 Guidebook to the Seed of Native and Non-Native Grasses, Forbs and Shrubs of 

the Great Basin. U.S. Department of the interior, Bureau of Land Management. 

2005. 

15.1	 Dryland Pastures of Montana and Wyoming; Montana State University Extension 

Service, 2003 

DEIS E-9 July 2010 
Appendix F 

Soil Mapping Data 

DEIS 

July 2010 
Appendix F
 

Detailed Soil Mapping Unit Information for the SSURGO Survey Area within the GNBPA 

Unit 

Area 

(acres) % of Area Soils Slopes % Comp Landscape Positi

154 19,309.5 15.71% Motto-RO Complex 2>25 75 - 10 Structural bench, hill / Escar

36 16,390.6 13.34% Cadrina ext stl-RO Complex 25>50 65 - 20 Hill / Escarp, ledge, eros rem

126 13,602.6 11.07% Lanver-Walknolls aassoc 2>25 50 - 35 Plateau / Hill 

62 9,500.0 7.73% Crustown-Motto Complex 2>25 50 - 35 Hill / Structural bench, hill 

266 8,881.7 7.23% Walknolls-Uendals assoc 2>25 55 - 30 Hill / Hill 159 7,073.5 5.76% Muff-Cadrina, Cool assoc 1>25 50 - 35 Strath terrace / Hill 

12 6,613.4 5.38% Badland-RO complex 1>100 50 - 35 Eros rem, hill, ridge / Escarp

152 5,804.1 4.72% Motto-Casmos complex 2>25 55 - 30 Structural bench, hill / Hill 

38 5,317.7 4.33% Cadrina-Casmos-RO complex 2>40 40-30-15 Hill / Hill / Escarp, ledge, ero13 3,833.4 3.12% Badland-Tipperary assoc 1>8 60 - 25 Eros rem, hill, ridge / Structu

264 3,757.4 3.06% Walknolls-RO complex 2>50 75 - 15 Hill / Escarp, ledge, eros rem

33 3,451.1 2.81% Cadrina assoc 2>25 55 - 30 Hill 80 3,397.8 2.76% Gilston-Muff-Cadrina, Cool compl 1>25 30-30-30 Drainageway / Strath ter / H

262 2,967.4 2.41% Walknolls-Gilston assoc 2>25 55 - 35 Hill / Drainageway 

14 2,603.0 2.12% Badland-Walknolls-RO complex 50>90 50 - 35 Eros rem, hill, ridge / Hill / E42 2,525.7 2.06% Casmos-Cadrina-Badland comp 4>25 35-30-20 Hill / Hill / Escarp, ledge, ero

120 1,501.6 1.22% Jenrid sandy loam 0>2 85 Alluvial flat 

179 1,324.2 1.08% Pherson-Hickerson complex 1>8 45 - 40 Drainageway / Flood plain, a

121 1,112.3 0.91% Jenrid -Eghelm complex 0>3 60 - 25 Alluvial flat / Flood plain 173 1,021.3 0.83% Pariette gravelly sandy loam 2>8 85 Strath terrace, fan remmant 

113 899.3 0.73% Ioka gravelly sandy loam 0>3 85 Alluvial flat 158 458.0 0.37% Muff gravelly sandy loam 2>8 85 Strath terrace 

241 365.2 0.30% Turzo complex 2>4 60 - 25 Alluvial flat 242 261.2 0.21% Turzo loam 0>4 85 Alluvial flat 

79 233.7 0.19% Gilston-Chalkcliff assoc 2>25 50 - 40 Drainageway / Fan remnant 

285 206.2 0.17% Water 

488.8 0.40% 12 minor map units comprised of soils, 

riverwash, and rock outcrop 

 TOTAL 122,900.7 100.00% 

DEIS F-1