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.


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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.


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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.