Special Topics in Environmental Management

SPCC—Lessons Learned

An oil production company operating in Big Horn County, Wyoming was recently fined for the discharge of approximately 162 barrels of oil into a tributary of a major river. The discharge came from a leak in a pipeline at its pumping facility. The facility is on an onshore oil gathering, pumping, and storage station that gathers crude oil from various production facilities into a single 1.47-million-gallon (gal) storage tank.


TRAC360 for SPCC provides all of the PE-written and reviewed templates that you need to create your facility-specific required plans, checklists, and training. See how it can solve your top compliance challenges. Find out.


What Went Wrong

One late winter morning in 2010, approximately 162 barrels (6,804 gal) of crude oil spilled from a pipeline at the facility, flowed over land and into a tributary about 3.3 miles away from the point where the tributary flows into the river. Much of the discharged oil was recovered within a week, but recovery and remediation efforts continued until that November. The incident occurred 20.6 miles downstream from where the river flows into the Big Horn River, which is designated as a navigable water of the United States.

When the facility’s SPCC Plan was reviewed, there were a number of deficiencies, including:

  • The facility diagram was incomplete and did not include piping, all the transfer pumps and associated piping, and a clear representation of how oil moved from the tank to the outgoing pipeline.
  • The Plan did not discuss the age of, and the integrity-testing schedule for the tank at the facility.

In addition, because the shell capacity of the tank was over 1 million gal, the facility was required to have a Facility Response Plan (FRP). It did not.


The Ultimate SPCC Compliance Tool

TRAC360 for SPCC is a powerful application that simplifies compliance with EPA’s Spill Prevention, Control, and Countermeasure rule. Whether you need help creating your facility-specific SPCC Plan, writing inspection checklists for your tanks, or training your oil-handling workforce, TRAC360 is there to help. Learn More.


The Fine and the Fix

The oil production company was fined $170,000. The fine could have been more, but the company did a number of things that shed a good light on itself in the eyes of the government. The company:

  • Submitted and adequate FRP to the EPA;
  • Removed from service the gathering line that was the source of the discharge; and
  • Responded promptly and adequately to the discharge.

In addition, the company no longer owns or operates the facility in Big Horn County.

 

Leave a Reply

Your email address will not be published. Required fields are marked *

This site uses Akismet to reduce spam. Learn how your comment data is processed.