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SPCC Compliance FAQs for Production, Drilling and Workover Facilities

SPCC Plan Compliance FAQs for Production, Drilling and Workover Facilities

Q: Are there SPCC Plan requirements that apply to all covered oil production, drilling and workover facilities?

A: Yes. 40 CFR part 112.7 provides the general requirements for SPCC Plans at all facilities covered by the regulations. Although these requirements are extensive, there are a few key aspects that should be considered upfront, including:

  • The Plan must be prepared in accordance with good engineering practices,
  • The Plan must have the full approval of management at a level of authority that allows for the commitment of resources necessary to fully implement the Plan,
  • The Plan must be prepared in writing,
  • The Plan must be prepared following the sequence provided in 112.7 or an equivalent Plan must be prepared that is acceptable to the Regional Administrator and that meets all of the applicable requirements listed in 112.7, and is supplemented with a section cross-referencing the location of requirements listed in this part and the equivalent requirements in the other prevention plan. If the Plan calls for additional facilities, procedures, methods, or equipment not yet fully operational, these items must be discussed in separate paragraphs, and must explain separately the details of installation and operational start-up.

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Q: In addition to the general SPCC Plan requirements defined in 40 CFR part 112.7, are there additional requirements specifically for onshore oil production facilities?

A: Yes. 40 CFR part 112.9 contains additional SPCC Plan requirements for onshore production facilities, excluding workover and drilling facilities. These include an extensive and variety of activities and other requirements related to:

  • Oil production facility drainage
  • Oil production facility bulk storage containers, and
  • Oil production facility transfer operations.

Q: In addition to the general SPCC Plan requirements defined in 40 CFR part 112.7, are there additional requirements specifically for onshore oil workover and drilling facilities?

A: Yes.  40 CFR part 112.10 contains additional specific requirements for onshore oil workover and drilling facilities, including:

  • Positioning or locating mobile drilling or workover equipment in such a way as to prevent a discharge as described in 112.1(b),
  • Providing catchment basins or diversion structures to intercept and contain discharges of fuel, crude oil, or oily drilling fluids, and
  • Installing a blowout prevention (BOP) assembly and well-control system before drilling below any casing string or during workover operations. The BOP assembly and well-control system must be capable of controlling any well-head pressure that may be encountered while that BOP assembly and well control system are on the well.

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Q: What elements does the EPA require or recommend be included in diagrams required in SPCC Plans?

A: The SPCC regulations require facility diagrams to include:

  • The location and contents of oil containers with a capacity of 55 gallons or more,
  • Completely buried tanks and gathering lines that are otherwise exempt,
  • Connecting piping, and
  • Transfer stations.

The EPA also recommends inclusion of the following elements in the diagrams:

  • Secondary containment,
  • Storm drain inlets and surface waters,
  • Direction of flow in the event of a discharge,
  • Legend  with scale and symbols,
  • Location of response kits and firefighting equipment,
  • Location of valves or drainage system controls,
  • Compass directions, and
  • Topographical information and area maps.

Q: Should facility diagrams include all fixed, mobile and portable containers?

A: No. Only fixed containers should be included in the facility diagram. However, with regard to mobile and portable containers, the facility diagram must:

  • Identify a storage area such as a drum storage area,
  • Include a separate description of the containers in the storage area in the SPCC Plan, or reference facility inventories that can be updated by facility personnel, and
  • Provide an estimate of the potential number of containers, types of oil, and anticipated capacities of the containers.

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