Relevance:
Spill Prevention Control & Countermeasure (SPCC), SPCC evaluations, SPCC inspections, and negative declarations.
Project Characteristics:
The U.S. Environmental Protection Agency (EPA) Code of Federal Regulations (CFR) Title 40 addresses Protection of the Environment. Under CFR 40, Chapter I, Subchapter D, Part 112, which addresses Oil Pollution Prevention, owner or operators of non-transportation-related onshore or offshore facilities engaged in drilling, producing, gathering, storing, processing, refining, transferring, distributing, using, or consuming oil and oil products, which due to their location could reasonably be expected to discharge oil in quantities that may be harmful into or upon the navigable waters of the United States (WOTUS) or adjoining shorelines, are required to prepare, implement, and maintain a Spill Prevention, Control, and Countermeasure (SPCC) Plan.
Ensolum assists operators with writing, reviewing, and revising their SPCC plans and conducting SPCC evaluations to ensure compliance with regulations. Ensolum was requested to conduct a desktop review of oil and gas production facilities to evaluate nearby waterways and determine SPCC applicability. The following databases and geographic information systems (GIS) layers were referenced during the evaluation:
- United States Geological Survey (USGS) topographic map
- National Environmental Policy Act (NEPA) NEPAssist
- Unities States Environmental Protection Agency (EPA) WATERSKMZ Tool
Photo 1: SPCC-Applicable Oil Storage Tanks
Ensolum reviewed sites for SPCC applicability using the criteria defined in Conoco’s Spill Prevention and Management manual provided by the client. When evaluating SPCC applicability criteria, WOTUS features were identified as all named water features plus one unnamed stream reach upstream of the named features. Ensolum used geographic information system (GIS) tools to efficiently identify the client’s oil and gas production facilities within one-quarter mile of navigable WOTUS, which could be reasonably expected to discharge oil into or upon navigable WOTUS, and therefore, require an SPCC Plan. Those not within one-quarter mile were documented as negative declarations.
The deliverable provided by Ensolum included a database-generated client-specific negative declaration form, with a topographic map and aerial imagery showing the site location and nearby waterways. The list of sites reviewed by Ensolum and determined to be non-SPCC-applicable was included as an addendum to a field-wide SPCC plan.
Photo 2: Topographic Figure, Non-SPCC-Applicable Facility
