SPCC Rule Review. Spill Prevention Control & Countermeasures NON-TRANSPORTATION RELATED ONSHORE AND OFFSHORE FACILITIES

Transcription

1 SPCC Rule Review Spill Prevention Control & Countermeasures NON-TRANSPORTATION RELATED ONSHORE AND OFFSHORE FACILITIES Code of Federal Regulations Title 40 CFR Part 112

2 40 CFR PART 112 Prevention requirements: The original SPCC regulations promulgated in 1973 Issued under the authority of the Clean Water Act sections 311(j) and 501 Codified at 40 CFR part 112 First effective on January 10,

3 SPCC Rule Revision Revisions proposed to current rule in 91, 93, 97 Final rule published in Federal Register July 17, 2002, effective August 16, 2002 Revises applicability New subparts Other modifications 3

4 Purpose of 40 CFR Part 112 To PREVENT discharges of oil into the waters of the United States 4

5 What three areas should an SPCC Plan address? Operating procedures installed by the facility to prevent the occurrence of oil spills Control measures installed to prevent a spill from entering navigable waters Countermeasures to contain, clean up, and mitigate the effects of an oil spill that impacts navigable water 5

6 When and Why do I Need an SPCC Plan? SPCC regulations apply to facilities that: Have an aboveground storage capacity (including operating equipment) of oil that is greater than 1,320 gallons (31.4 barrels) in containers equal to or greater than 55 gallons or Have a completely buried storage capacity (including operating equipment) of oil that is greater than 42,000 gallons AND Due to their location, could reasonably be expected to impact Navigable Waters of the U.S. or adjoining shorelines 6

7 EPA has Extended SPCC Compliance Dates to July 1, 2009 EPA has extended the compliance dates for owners and operators to prepare or amend and implement SPCC Plans until July 1, EPA expects to propose further revisions to the SPCC rule in 2008, and the extension would allow EPA the time to promulgate further regulatory revisions before the compliance dates. 7

8 Implementation Timeframes What are the current compliance dates? A facility (other than a farm) starting operation... On or before August 16, 2002 After August 16, 2002 through July 1, 2009 After July 1, 2009 Must... Maintain its existing Plan Amend and implement the Plan no later than July 1, 2009 Amend and implement a Plan no later than July 1, 2009 Prepare and implement a Plan before beginning operations 8

9 112.7(f) The revised rule mandates training for oilhandling employees only, instead of all employees. It specifies additional topics for the training of these employees. It also specifies that discharge prevention briefings must be conducted at least once a year, instead of at intervals frequent enough to assure adequate understanding of the SPCC Plan for that facility. 9

10 TECHNICAL REQUIREMENTS Bulk Storage Containers Must have secondary containment for the entire capacity of the single largest container plus freeboard for precipitation No specific freeboard value or % required (for example 110%). Use local climate conditions and engineering principles. Must be able to substantiate. 10

11 Fig. B Year Return Period, 24 hour Duration Precipitation, inches (SCS, 1986): 11

12 TECHNICAL REQUIREMENTS Bulk Storage Containers Must have secondary containment for the entire capacity of the single largest container plus freeboard for precipitation No specific freeboard value or % required (for example 110%). Use local climate conditions and engineering principles. Must be able to substantiate. Includes most saltwater tanks 12

13 TECHNICAL REQUIREMENTS What about flow through equipment? Most recent proposal does not require sized containment for separators, heater treaters, gun barrels, etc. but must have inspection and other containment contingencies similar to flowlines. 13

14 TECHNICAL REQUIREMENTS Facility Transfer Operations Production facilities must have a program of flowline maintenance to prevent spills No large scale corrosion (pitting, flaking) Leaking/corroded flowlines repaired or replace Proper containment for flowline spills 14

15 TECHNICAL REQUIREMENTS Facility Transfer Operations Containment is often impractical If not practical: Impracticality claim must be made Written contingency plan (commitment of manpower and materials, testing, etc.) 15

16 Facility Transfer Operations Containment structures are physically impractical for the various flowlines from the wellhead to the tank battery. Therefore, the operator s inspection and response plan for these flowlines can be as follows: 16

17 Facility Transfer Operations While driving the lease daily, the pumper will look for any evidence of leaks. The pumper will walk the flowlines quarterly to inspect for leaks. The pumper should note on his daily reports the date of which this quarterly inspection was made. 17

18 Facility Transfer Operations The operator will keep a supply of sorbent material available in the proximity of the lease to aid in immediate spill response in the event that a leak is discovered. Reporting and response to a leak will be carried out as described in Section 6 of this SPCC Plan 18

19 Tank Truck Loading/Offloading Secondary containment is required Loading Area vs. Loading Rack Can be simple Does not have to be berms Examples include: Crescent shaped berm down slope Use of ditching Booms, pads or sorbent material on site 40 CFR 112.7c 19

20 SPCC Spill Response Kit Description & Overview Provides conveniently available absorbent materials and personal protective equipment (PPE) Kit Contains: (2) 55-gallon drums with lever lock lids (4) 5 x 10 absorbent booms (1) bale of absorbent pads (3) bags of sorbent material (2) pair of gloves (6) 5-mil drum liners (1) shovel (2) pair of safety glasses (2) protective coveralls Easy access with Lever Lock Lid 20

21 SPCC Spill Response Kit Kit assists with compliance of Spill Prevention and Control Countermeasure Plan for onsite containment in the loading area (under 40 CFR 112.7c) Provides first line of defense if an oil spill should occur and help prevent oil from reaching navigable waters Conveniently located kit allows for immediate response 21

22 Qualified Facilities Must meet eligibility criteria to use alternative option Streamlined regulatory requirements Self-certified SPCC Plan instead of one reviewed and certified by a Professional Engineer Streamlined integrity testing requirements Streamlined facility security requirements May also use qualified oil-filled operational equipment option since an impracticability determination by a PE is not necessary 22

23 Qualified Facilities Eligibility Criteria Facility must have 10,000 gallons (238 Bbls) or less in aggregate aboveground oil storage capacity For the 3 years prior to Plan certification, or since becoming subject to the rule if it has operated for less than 3 years, the facility must not have had: A single discharge of oil to navigable waters exceeding 1,000 U.S. gallons, or Two discharges of oil to navigable waters each exceeding 42 U.S. gallons within any 12-month period 23

24 Reportable Discharge History When determining the applicability of this criterion, the gallon amount(s) specified (either 1,000 or 42) refers to the amount of oil that actually reaches navigable waters or adjoining shorelines, not the total amount of oil spilled Oil discharges that result from natural disasters, acts of war, or terrorism are not included Facilities that have a reportable oil discharge after selfcertifying the SPCC Plan do not automatically lose eligibility However, the Regional Administrator has the authority to require a Plan amendment 24

25 Self-Certification Owner/operator attests that he/she is familiar with the rule and has visited and examined the facility Owner/operator also certifies that: The Plan has been prepared in accordance with accepted and sound industry practices and standards and with the rule requirements Procedures for required inspections and testing have been established The Plan is being fully implemented The facility meets the qualifying criteria The Plan does not deviate from rule requirements except as allowed and as certified by a PE Management approves the Plan and has committed resources to implement it 25

26 Discharge Procedure Protocol Accidental Discharge Contingency Plan/Spill Report Planned Discharge Drainage Discharge Report 26

27 Pollution Control Laws Rules and Regulations State: Oklahoma Corporation Commission Federal: 40 CFR 112 / Clean Water Act Reporting Requirements 10 Bbls or more on land Any amount on or that has the potential for reaching a navigable waterway 27

28 SPCC Plan Overview Attested by PE Approved by company management Contact information 28

29 SPCC Plan Overview Prevention Measures Secondary containment Calculation of required berm height Measure berm height from lowest point 29

30 SPCC Plan Overview Inspection Tanks visual okay for non-field constructed < 760 Bbls Base of tanks Vegetation inside of battery Fluid standing inside of battery Flowlines Load lines 30

31 SPCC Plan Overview Contingency Plan 1. Stop the source 2. Contain the spilled fluid 3. Call emergency / report numbers 4. Recover and remove 5. Clean up / remediate 6. Complete written report 7. Correct cause of spill to prevent recurrence 31

32 For more additional information contact: Enviro Clean Products & Services