Spill Prevention Control & Countermeasure (SPCC), SPCC evaluations, SPCC inspections, and negative declarations.
The U.S. Environmental Protection Agency (EPA) Code of Federal Regulations (CFR) Title 40 addresses Protection of the Environment. CFR 40, Chapter I, Subchapter D, Part 112 addresses Oil Pollution Prevention. The 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 discharge oil in quantities that may be harmful. Consequently, this oil could be discharged into navigable waters of the United States (WOTUS) or adjoining shorelines. Owners or operators are thus required to prepare, implement, and maintain a Spill Prevention, Control, and Countermeasure (SPCC) Plan.
Moreover, Ensolum assists operators with writing, reviewing, and revising their SPCC plans and conducting SPCC evaluations. Additionally, Ensolum ensures compliance with regulations. Ensolum conducted a desktop review of oil and gas production facilities to evaluate nearby waterways and determine SPCC applicability. Ensolum referenced the following databases and geographic information systems (GIS) layers 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
Furthermore, 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, Ensolum identified WOTUS features 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. Ensolum reasonably expected these facilities to discharge oil into or upon navigable WOTUS. Therefore, they required an SPCC Plan. Ensolum documented those not within one-quarter mile as negative declarations.
Ensolum’s deliverable also included a database-generated client-specific negative declaration form, with a topographic map and aerial imagery showing the site location and nearby waterways. Finally, Ensolum determined the list of reviewed sites as non-SPCC-applicable and included them as an addendum to a field-wide SPCC plan.
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Photo 2: Topographic Figure, Non-SPCC-Applicable Facility