1 

# ...for Onshore Oil Production, Drilling and Workover Facilities

Click to add your information here 

# SPCC 101...3 

# Please note that this presentation is a summary and does not cover every SPCC provision.
Always refer to the SPCC rule and official Agency guidance found at www.epa.gov/oilspill5 

# What is the SPCC Rule?

 Spill Prevention, Control, and Countermeasure rule

 Part of the Oil Pollution Prevention regulation (40 CFR part 112)

– Includes requirements for Facility Response Plans (FRPs) for certain facilities which may pose a substantial harm to waterways and the environment


###  Purpose
– To develop plans designed to prevent oil discharges from reaching the navigable waters of the U.S. or adjoining shorelines6 

# Requirements of the SPCC rule

 Requires certain facilities, including production facilities, to develop and implement a site specific SPCC Plan to address:

– Containment and procedures to Prevent oil discharges;

– Proactive Control measures to keep an oil discharge from entering navigable waters of the U.S. or adjoining shorelines (containment); and

– Effective Countermeasures to contain, clean up, and mitigate any oil discharge that affects navigable waters of the U.S. or adjoining shorelines (spill response measures).7 

# SPCC Rule Overview

 Authority from Clean Water Act

 Oil Pollution Prevention regulation codified at 40 CFR part 112

 Original rule effective in January 1974

 Non - delegable to other agencies8 

# Rule Applies To Non
Transportation Related Facilities

 Drilling

 Producing

 Gathering

 Storing

 Processing  Refining

 Transferring

 Distributing

 Using

 Consuming 

### Regulations apply to owners and operators of facilities involved in:16 

# What are the SPCC criteria?

 Facility stores > 1,320 gallons of oil in aggregate above
- ground storage or has 42,000 gallons of completely buried oil storage capacity; and

 Facility has a “reasonable expectation of an oil discharge” to waterway or adjoining shoreline. 

### You must have an SPCC Plan if:17 

# SPCC Applicability

 Owner/operator makes the initial decision on applicability of SPCC regulations to the facility

– Does the facility meet the applicability criteria (volumes of oil, expectation to spill to waterway)?


###  No requirement to submit SPCC Plan to EPA for approval

 EPA does not formally “approve” or disapprove of SPCC Plan

 Plan is required upon inspection during regular workday18 

# SPCC Applicability
Counted Not Counted 55
- gallons or greater

5
- gallon container 30

- gallon drum

Permanently Closed19 

# Definitions
- Oil

 Oil, as defined in Section 311 (a)(1) of the CWA, can be of any kind or in any form including, but not limited to



### - Petroleum and non
petroleum based oils



### - Crude Oil



### - Refined Products



### - Animal Fats, and



### - Vegetable oils20 

# Examples 

# of Oil at Production, Drilling and Workover

 Produced water containing oil

 Crude oil

 Oily waste

 Fuel for drill rig

 Hydraulic oils21 

# Examples 

# of Oil at Production, Drilling and Workover

 Fuel storage for vehicles

 Lubrication oils (pumpjack)

 Oil in transformers

 Liquid oil condensate

 Oil based frac fluids

 Natural Gasoline 22 

# Navigable Waterways of the U.S. and Adjoining Shorelines

 Applicability of the SPCC rule is predicated on a reasonable expectation of discharge of oil to “navigable waters of the U.S. or adjoining shorelines”

 What are navigable waters of the U.S.? In general:

– Surface waterways
– streams, creeks, rivers, lakes

– Wetlands adjacent to a navigable waterway

 Nexus important

– Can be intermittent streams. Best determination if flowing at least seasonally (3 months or more), depending on several factors (see Rapanos Guidance) http://www.epa.gov/owow_keep/wetlands/guidance/CWAwaters.html

– Defined flow pathway to clearly navigable waters of the U.S. good start in determination
– don’t assume

 EPA has developed draft guidance on navigable waters of the U.S and adjoining shorelines.

http://water.epa.gov/lawsregs/guidance/wetlands/CWAwaters.cfm23 

# Navigable Waters of the U.S. and Adjoining Shorelines Discussion24 

# What is a “Reasonable Expectation of an Oil Discharge”?

 Initial determination by the owner/operator based on geographical and location aspects of the production facility

 You may consider proximity to water, land contour, drainage

 Exclude manmade features, such as secondary containment dikes around tanks and impoundments, in determination

 Good idea to document determination

- Particularly if you conclude you are not subject to the rule

- Not a rule requirement
 See Section 2.4 of SPCC guidance document http://www.epa.gov/emergencies/docs/oil/spcc/guidance/2_Applicability.pdf26 

# Definition of Production Facility

 Revision clarifies that the definition of “production facility” is used to determine which sections of the rule apply at a particular facility (e.g., § 112.9).
 Revised definition is consistent with the revision to the definition of “facility”.
 Clarifies the flexibility allowed in determining the boundaries of the facility.
 Clarifies that condensate is regulated. § 112.225 

# What the definition means...

 According to EPA guidance, the extent of a “facility” depends on site
- specific circumstances:

- Ownership, management , and operation of the buildings, structures, equipment, installations, pipes, or pipelines on the site;

- Similarity in functions, operational characteristics, and types of activities occurring at the site;

- Adjacency; or

- Shared drainage pathways (e.g., same receiving water bodies).27 

# Amended Definition

Production facility means all structures (including but not limited to wells, platforms, or storage facilities), piping (including but not limited to flowlines or intra
- facility gathering lines), or equipment (including but not limited to workover equipment, separation equipment, or auxiliary non
- transportation
- related equipment) used in the production, extraction, recovery, lifting, stabilization, separation or treating of oil (including condensate) , or associated storage or measurement, and is located in an oil or gas field, at a facility. This definition governs whether such structures, piping, or equipment are subject to a specific section of this part.101 

# Onshore Drilling and Workover Requirements102 

# Onshore Drilling and Workover Requirements

 Meet general requirements listed under 40 CFR 112.7, and:

 Position or locate mobile drilling or workover equipment so as to prevent a discharge 

### 112.10(b)103 

###  Provide catchment basins, reserve pits, or diversion structures to contain any spill of oil or oily fluids (drilling mud) 

# Onshore Drilling and Workover Requirements

112.10(c)104 

###  No specific sizing requirement, and no freeboard requirement for secondary containment



### 112.10(c) 

# Onshore Drilling and Workover105 

###  Install a Blow Out Prevention (BOP) assembly and well control system

 The BOP assembly and well control system must be capable of controlling any well
head pressure that may be encountered 

# Onshore Drilling and Workover

112.10(d)28 

# “Wet Gas” and “Dry Gas” Facilities

 Liquid condensate is an oil.

 A natural gas production facility may store condensate in quantities that meet the applicability criteria for the SPCC.

– Considered a production facility ( § 112.9 applies).

– Called a “wet gas production facility”


###  EPA believes that a “dry gas production facility” is not an oil production, oil recovery, or oil recycling facility, as described in the clarification published May 25, 2004 (69 FR 29728)

– Stores no condensate

– SPCC requirements do not apply, so long as no other oil is stored at the facility to make it otherwise regulated29 

# Dry Gas and Produced Water Tank30 

# Produced Water Container

 Produced water container means a storage container at an oil production facility used to store the produced water after initial oil/water separation, and prior to reinjection, beneficial reuse, discharge, or transfer for disposal

 Definition is used to determine which containers are eligible for alternative measures for produced water containers31 

# Produced Water Container32 

# Produced Water Containers

Above left: Infrared photograph of a produced water storage tank with a two foot oil layer on top of water.33 

# Permanently 

# Closed

 Permanently closed means any container or facility for which:

– All liquid and sludge has been removed from each container and connecting line;

– All connecting lines and piping have been disconnected from the container and blanked off;

– All valves (except for ventilation valves) have been closed and locked; and

– Conspicuous signs have been posted on each container stating that it is permanently closed and noting the date of closure
.34 

# Permanently Closed

 SPCC rule exempts any oil storage container that is permanently closed.

– A tank that has either never stored oil, or has been permanently closed, and arrives at a facility is not counted until the tank is actually used to store oil.
 Definition of “permanently closed” does not require a container to be removed from a facility.

– Permanently closed containers may be brought back into use as needed for variations in production rates and economic conditions
.35 

# Key SPCC Requirements

 Prepare Plan in accordance with Good Engineering Practices

 Full approval of management to implement Plan and sign off

 Follow sequence of Section 112.7, or use a cross - reference section36 

# Key SPCC Requirements

 SPCC regulations requires preparation and implementation of a written Plan to address:

– Operating procedures for routine handling of products to prevent a discharge of oil;

– Discharge or drainage control measures to prevent a discharge of oil;

– Countermeasures to contain, clean up, and mitigate an oil spill;

– Methods of disposal of recovered materials; and

– Contact list and phone numbers of company, contract response personnel, and National Response Center37 

# Professional Engineer (PE)

 Certified by a licensed PE, and attests:

– PE familiar with 40 CFR Part 112

– PE or agent visited facility

– In accordance with good engineering practices

 Consider applicable industry standards

 In compliance with regulations

– Inspection and testing procedures are established38 

# Professional Engineer (PE)

 Certified by a licensed PE, and attests:

– Plan is adequate for facility

– That, if applicable, for a produced water container subject to § 112.9(c)(6), any procedure to minimize the amount of free
- phase oil is designed:

• To to reduce the accumulation of free
- phase oil; and

• Procedures and frequency for required inspections, maintenance and testing have been established and are described in the Plan45 

###  SPCC Plan must be maintained at facility if manned 4 hours/per day or more, or at nearest field office if manned less than 4 hours/per day

 Usual and customary business practices records serve as documentation of inspection or tests 

# Key SPCC Requirements46 

# Inspections, Tests, and Records

 Conduct inspections and tests in accordance with written procedures developed by the facility or by the engineer who certifies the facility Plan

 Keep these written procedures and a record of the inspections and tests, signed by the appropriate supervisor or inspector, with the SPCC Plan for a period of three years55 

# General Secondary Containment

 “General” Secondary Containment requirement applies to the following examples:

– Christmas tree, wellhead, and stuffing box

– Oil
- filled equipment (transformers, pumpjacks, etc.)

– Transfer areas
 Piping runs/racks, manifolds, etc.
 Flow and intra facility gathering lines
 Truck loading/unloading areas (not loading rack)


###  No specific
- sized volume requirement
 Sizing based on typical spill size not container size62 

# Specific Secondary Containment Requirements for Production

 Applies to bulk storage containers at the tank battery, separation and treatment facilities, including, but not limited to:

 Stock tanks,
 Produced water containers, *
 Separation equipment * (e.g., heater
- treaters and separators)  If facility drainage is used as secondary containment for bulk storage containers, then drainage from undiked areas must be safely confined in a catchment basin or holding ponds  Secondary containment sized to the capacity of the largest single container with sufficient freeboard to contain precipitation

* The SPCC rule includes alternative measures for certain production equipment in lieu of sized secondary containment6872 72 

# General Requirements Applicable to ALL Facilities

 Production facilities must meet general requirements under 112.7

– Except the security requirement ( 112.7(g))

– Except general containment requirement ( § 112.7(c)) for certain flowlines and gathering lines79 

# Production Facility Drainage

 Oil field drainage

– Inspect at regularly scheduled intervals for an accumulation of oil that may have resulted from any small discharge

– Promptly remove any accumulations of oil 

###  Remove accumulated oil on the rainwater and return it to storage or dispose of it in legally approved method8081 

### Container compatibility ( 112.9(c)(1)): Do not use a container for the storage of oil unless its material and construction are compatible with the material stored and the conditions of storage 

# Bulk Storage Containers at Production Facilities82  For all bulk containers in the tank battery, separation and treatment facilities satisfy the sized containment requirement (sized to largest container plus freeboard for precipitation); or

 For process vessel and/or produced water containers, you may meet the alternative compliance requirements

 For oil containers that directly support production operations at a production facility but are not a part of a tank battery, or separation, and treatment equipment, then follow § 112.7(c) for secondary containment requirements

 If the bulk container does not support production operations then the § 112.8 requirements apply 

# Bulk Storage Containers at Production Facilities 112.9(c)(2)83 

# Bulk Storage Container Inspections at Production Facilities

 Visual Inspection ( 112.9(c)(3))

 Periodically and upon a regular schedule visually inspect each container for deterioration and maintenance needs

 Include the foundation and support of each container that is on or above the surface of the ground89 

# Compliance Alternative: Produced Water Containers

 Instead of providing sized secondary containment for produced water containers, a facility owner/operator can:

– Have a PE certify a procedure for each produced water container that is designed to separate the free
- phase oil that accumulates on the surface of the produced water, that is implemented on a regular schedule;

– Conduct visual inspections, maintenance and corrective action;
 General secondary containment requirements still apply If the facility discharges to navigable waters or adjoining shorelines:

– 1,000 U.S. gallons of oil in a single discharge, or

– 42 U.S. gallons of oil in each of two discharges within a 12 month period from a produced water container, then the facility owner/operator may no longer take advantage of this alternative option and must comply with the sized secondary containment requirements at § 112.9(c)(2) and inspection requirements at § 112.9(c)(3) within six months of the discharge.90  A procedure designed to remove free
- phase oil that accumulates on the surface of the produced water container

– Implemented on a regular schedule

– General secondary containment must be able to address the amount of oil in the produced water container
 SPCC Plan must include:

– Description of the free
- phase oil separation and removal;

– Frequency it is implemented;

– Amount of free
- phase oil expected to be inside the container; and

– Description of the general secondary containment
 Owner or operator must keep records of the implementation of these procedures in accordance with § 112.7(e). 

# Procedure to Remove Oil from Produced Water Containers91 

# PE Certification

 PE attests that Plan is prepared in accordance with good engineering practices and includes a provision certifying that:

– An oil removal procedure for produced water containers is designed to reduce the accumulation of free
- phase oil, and

– The procedures and frequency for required inspections, maintenance and testing have been established and are described in the Plan.114 

# Reporting of Oil Spills

 Report all oil discharges to navigable waters of the U.S. or adjoining shorelines to NRC at 1 - 800 - 424 - 8802

 Federal government's centralized reporting center, which is staffed 24 hours a day by U.S. Coast Guard personnel

 Any person in charge of a vessel or an onshore or offshore facility must notify NRC immediately after he or she has knowledge of the discharge

 NRC relays information to EPA or U.S. Coast Guard depending on the location of the incident

 An On - Scene Coordinator evaluates the situation and decides if federal emergency response action is necessary115 

# Specific SPCC Spill Reporting Requirements

 Report to the EPA Regional Administrator (RA) when there is a discharge of:

– More than 1,000 U.S. gallons of oil in a single discharge to navigable waters of the U.S. or adjoining shorelines

– More than 42 U.S. gallons of oil in each of two discharges to navigable waters of the U.S. or adjoining shorelines within a 12
- month period

– When making this determination it is the amount of the discharge in gallons that reaches navigable waters of the U.S. or adjoining shorelines

– An owner/operator must report the discharge(s) to the EPA Regional Administrator within 60 days116 

# For More Information

 EPA’s SPCC web page

 http://www.epa.gov/emergencies/content/spcc/index.htm
 EPA Oil Spill and Emergency Management web pages

 www.epa.gov/oilspill

 www.epa.gov/emergencies

 HOTLINE : Superfund, TRI, EPCRA, RMP, and Oil Information Center

– (800) 424
- 9346 or (703) 412
- 9810

– TDD (800) 553
- 7672 or (703) 412
- 3323

– www.epa.gov/superfund/resources/infocenter117 

# SPCC Contacts

REGION SPCC COORDINATORS 1 CT, RI, MA, NH, VT, ME Alex Sherrin ( 617) 918
- 1252 sherrin.alex@epa.gov
2 NJ, NY, PR, VI Larry D’Andrea ( 732) 906
- 6964 dandrea.larry@epa.gov 3 PA, WV, VA, MD, DC Arlin Galarza
- Hernandez ( 215) 814
- 3223 galarza
- hernandez.arlin@epa.gov 4 KY, NC, TN, SC, MS, AL, GA, FL Ted Walden ( 404) 562
- 8752 walden.ted@epa.gov
5 MN, WI, MI, IL, IN, OH Barbara Carr ( 312) 886
- 7187 carr.barbara@epa.gov

6 NM, TX, OK, AR, LA Don Smith ( 214) 665 - 6489 smith.donaldp@epa.gov Chris Perry ( 214) 665
- 6702 perry.chris@epa.gov

7 NE, KS, IA, MO Alan Hancock ( 913) 551
- 7647 hancock.alan@epa.gov118 

# SPCC Contacts

REGION SPCC COORDINATORS 8 MT, ND, SD, WY, UT, CO Melissa Payan ( 303) 312
- 6511 payan.melissa@epa.gov 9 CA, NV, AZ, HI, Guam, American Samoa, Northern Marina Islands Pete Reich (415) 972 - 3052 reich.peter@epa.gov Janice Witul ( 415) 972
- 3089 witul.janice@epa.gov

10 WA, OR, ID, AK WA: Mike Sibley (206 ) 553
- 1886 sibley.michael@epa.gov OR, ID: Richard Franklin ( 503) 326
- 2917 franklin.richard@epa.gov AK: Matt Carr ( 907) 271
- 3616 carr.matthew@epa.gov HQ - Office of Emergency Management: Mark Howard ( 202) 564
- 1964 howard.markw@epa.gov Patricia Gioffre ( 202) 564
- 1972 gioffre.patricia@epa.gov Troy Swackhammer ( 202) 564
- 1966 swackhammer.j
- troy@epa.gov
HQ - Office of Civil Enforcement: David Drelich (202) 564
- 2949 drelich.david@epa.gov Kelly Brantner (202) 564
- 9933 brantner.kelly@epa.gov HQ - Office of Compliance: Dan Chadwick (202) 564
- 7054 chadwick.dan@epa.gov120 

# Legal disclaimer

• EPA has made every effort to ensure the accuracy of this presentation. However, please note:
• This presentation is for informational purposes only and does not constitute Agency guidance.

• This presentation does not bind the Agency and does not govern Agency actions in the event of any conflict with a statute, regulation, policy, guidance, or other interpretation of the law by EPA.119 

# Questions?