Spill Prevention, Control, And Countermeasures Research Articles

Hand Held Technology; Its Place In a Environmental Compliance Monitoring System

This abstract will examine the elements of a field deployable inspection application designed to support the U S Environmental Protection Agency's (USEPA) field mission assignment, through the use of hand held technology. The system is designed to mimic a typical inspection through the use of software applications that replicate hard copy inspection forms. The primary elements of the program are in support of the Spill Prevention Control and Countermeasures (SPCC) regulations codified in Title 40 Code of Federal Regulations Part 112. These regulations govern prevention related activities, Facility Response Plans (FRPs) reviews and Government Initiated Unannounced Exercises (GIUEs). Accordingly, digital inspection/evaluation forms were created utilizing File Maker Pro development software. The forms have been deployed on Apple's IPAD tablets which allow for the integration of locational attributes of Google maps and the tablet's built in digital camera. A typical inspection will consist of an Administrative Form, Notice of Inspection (NOI), SPCC Inspection checklist, FRP Review checklist, FRP Field checklist, FRP Approval Letters and when applicable a GIUE evaluation forms. These files combine to form a complete inspection folder where it is either closed out as compliant or submitted to enforcement for further deliberation. A typical inspection begins with general inspection data being entered into the Administrative Form. Data entered here auto populates each corresponding inspection form. As an added enhancement, each inspection form can be pre- populated with consistently recorded values. This is generally the case when conducting multiple inspection where the company remains the same and/or the consultant has prepared plans in a uniform/standardized manner. Consequently, both latitudinal/longitudinal attributes are automatically embedded within the application along with photographic data. Upon completion of the inspection, the data is then synchronized with a GoZync Application with File Maker Pro server via WIFI or cellular connection. After file completion and administrative review, the report can be emailed to the recipient in a PDF format. To date, field trials have been completed on a local level with the expectation that Branch wide deployment will commence in late FY 16. The Agency recently made a nationwide buy of Apple tablets for On Scene Coordinators (OSCs) as well as inspection personnel within the response program. This helped pave the way for new application development and bringing to fruition the Agency's desired mission to perform its duties in a digital environment.

FLEXIBILITY ON U.S. EPA OIL SPILL PREVENTION MEASURES TO ACCOMMODATE SMALL CAPACITY MULTI-SECTOR STAKEHOLDERS

ABSTRACT In December 2006 the U.S. Environmental Protection Agency (EPA) published revisions to the Spill Prevention Control and Countermeasure (SPCC) regulation (40 CFR part 112) to streamline regulatory requirements pertaining to the prevention of oil discharges to navigable waters and adjoining shorelines. The purpose of these revisions was to allow flexibility for the regulated community in designing an oil spill prevention program that is appropriate for each individual facility. The range of regulated facilities for the SPCC universe includes everything from oil exploration and production facilities to end users of oil. The equipment and oil-handling activities vary as a result of the individual business operations of the facility. EPA has moved away from a prescriptive approach for requirements pertaining to the oil pollution prevention regulation in 40 CFR 112 and has incorporated performance based elements into the regulation to accommodate the wide universe of regulated stakeholders while maintaining protection of human health and the environment. Since promulgation of the regulation, the rule has incorporated alternative measures for when secondary containment is determined to be impracticable. In 2002, a provision was added to the rule to allow for deviations from rule requirements when an alternative environmentally equivalent measure is employed. The most recent revisions to the SPCC rule in 2006 include alternatives for facilities with small oil storage capacities to self-certify their SPCC Plans in lieu of a Professional Engineer certification. Additionally, the Agency is developing an additional proposal to streamline and simplify the SPCC rule for oil and gas production facilities, farms, and a subset of qualified facilities. This paper will highlight the SPCC rule provisions that provide flexibility in order to facilitate compliance and achieve the goal of preventing discharges of oil to navigable waters and adjoining shorelines. It will discuss the background of the SPCC rule; the key revisions that specifically offer alternative compliance options, with a focus on small oil storage capacity facilities; and provide an overview of the 2007 proposed revisions to the SPCC rule.

REVIEW OF OIL SPILL INCIDENTS REPORTED TO THE NATIONAL RESPONSE CENTER FROM ONSHORE OIL PRODUCTION FACILITIES

ABSTRACT The paper discusses considerations for prevention requirements under the Spill Prevention, Control, and Countermeasure (SPCC) regulation (40 CFR part 112) of onshore oil production facilities. The paper summarizes findings from a recent review of oil spill incidents reported to the National Response Center (NRC) during the period of 2000 through 2005. The analysis covers the relative frequencies and magnitudes of reported oil discharges from onshore oil production facilities by material discharged, source, and cause. The findings are complemented by findings from reviews of spill data obtained for selected states (Arkansas, Colorado, Kansas, and Oklahoma) and by field observations of EPA inspectors. 1 The SPCC rule provides specific requirements for different types of E&P facilities, including: onshore oil production facilities (§112.9), onshore oil drilling and workover facilities (§112.10), and offshore oil drilling, production, or workover facilities (§112.11).

PUBLIC PARTICIPATION IN U.S. OIL POLLUTION PLANNING AND PREPAREDNESS POLICY

ABSTRACT Regulatory agencies in the United States represent the Executive Branch of the Federal Government in implementing and enforcing rules, and these agencies are required to follow certain procedures when writing those rules. At a minimum, the agency must publish a notice explaining the proposed rule, request comments, and state the basis and purpose of the final action. This paper provides examples of instances where an agency has revised the rule as a result of comments received or has otherwise been responsive to the commenter'S argument. For example, with regard to oil pollution planning and preparedness policy, commenters on the U.S. Environmental Protection Agency'S proposed revisions to the Spill Prevention Control and Countermeasure (SPCC) plan rule raised the idea of a minimum container size for applicability of the SPCC rule and EPA included such a minimum for the first time in the final rule, thus reducing the burden of the rule for many facilities. Federal agencies are required to request public comments on the issues presented in their proposed rules to enable the agencies to evaluate the new or revised provisions. With agencies now accepting electronic comments through web sites, regulated parties can easily participate in this process. As this paper shows, many agencies that regulate oil pollution planning and preparedness are very responsive to suggestions, and members of the regulated community have an opportunity to influence public policy decisions in this area.

New Spill Prevention, Control, and Countermeasure (SPCC) Plan regulations

AbstractThe Spill Prevention, Control, and Countermeasure (SPCC) program regulates oil storage vessels at federal and industrial installations throughout the United States. After proposing revisions in 1991, 1993, and 1997, the EPA finally promulgated, on July 17, 2002, new regulations for the SPCC program. As written, the new regulations may impose substantial new expense and implementation requirements upon installations. This article provides a detailed review of the primary requirements of the SPCC program and identifies which issues federal installations may need to address as they work to meet the August 17, 2004, deadline to review their plan and complete necessary amendments, and the February 18, 2005, deadline to implement those amendments. © 2003 Wiley Periodicals, Inc.

Spill Prevention Control and Countermeasures: An Expedited Settlement Approach

ABSTRACT The U.S. Environmental Protection Agency (EPA) is responsible for implementing the Spill Prevention Control and Countermeasures (SPCC) regulations under the provisions of the Clean Water Act (CWA) as amended by the Oil Pollution Act of 1990 (OPA 90). These regulations apply to a wide array of facilities involved in exploration, production, refining, manufacturing, distribution, and processing. The agency conducts SPCC inspections as a method of validating compliance with these regulations. In an era of government re-invention, budget constraints and in the spirit of better customer service relations, EPA Region VI has developed an innovative means of obtaining facility compliance with the SPCC regulations. It is formally known as the expedited settlement approach. The purpose of this approach was to provide a more efficient and effective means of validating environmental compliance. The approach is a combination of simplified inspection and enforcement procedures with emphasis upon compliance assistance. The program's initial emphasis is directed at production facilities. The approach is designed to address environmental violations, which are easily correctable and generally have resulted in chronic type spills. This paper will examine the parameters of the expedited settlement approach, its application and implementation through the use of case studies. The results of the case studies will provide a barometer for the success and shortcomings of this type of approach.

THE THREAT OF OIL SPILLS FROM STORAGE TANKS AT END USER FACILITIES

ABSTRACT The oil pollution prevention program of the U.S. Environmental Protection Agency (EPA) addresses a large regulated community—the owners and operators of several hundred thousand nontransportation-related facilities. Regulated oil facilities generally are thought of as refineries, terminals, production field tanks, fuel oil dealers, or gasoline service stations. Some studies of the nationwide petroleum storage capacity do not even consider tanks owned by petroleum consumers, while others recognize that end users constitute a significant part of the nation's oil storage. The storage capacity of fixed petroleum tankage in the tertiary segment (agricultural, commercial, electric utility, industrial, military/government, residential, and transportation sectors) is estimated to comprise more than 20 % of the total U.S. storage capacity. EPA estimates that more than one-half of the facilities required to prepare Spill Prevention Control and Countermeasure (SPCC) plans are such end users. The focus of oil pollution prevention, of course, is preventing spills. Several years ago, an American Petroleum Institute report on aboveground storage tank incidents stated that more than 25% of large petroleum releases in the United States were from tanks controlled by companies outside the petroleum industry. Recent data on large spills (10,000 gallons or more) show similar patterns. Of course, most nontransportation-related spills are from storage tanks or facilities in the petroleum industry (production wells, refineries, terminals, tank farms, and fuel oil dealers). More than 40%, however, are from electric utilities, manufacturing plants, military bases, airports, railroad yards, and other end user facilities. Smaller spills come from a variety of facility types. It is important for EPA and other groups to recognize the end user community and the threat of spills from end user facilities, and to begin to work with the owners and operators of end user facilities to educate them about EPA's oil pollution prevention regulation.

NUTSHELL SUMMARY OF EPA'S NATIONAL SURVEY OF OIL STORAGE FACILITIES

ABSTRACT In April 1995, EPA conducted a national survey of oil storage facilities potentially subject to its Spill Prevention, Control and Countermeasures (SPCC) regulation (40 CFR Part 112). The purpose of the survey was to answer five specific questions: (1) How many facilities are regulated by EPA's SPCC program? (2) What types of facilities does the SPCC program regulate? (3) What do these facilities look like? (4) Which facilities pose the greatest oil spill risk? And (5) How effective is the SPCC program in reducing oil spill risk? This nutshell summary briefly discusses EPA's analysis of the survey data.

FACILITY-SPECIFIC CONTINGENCY PLANNING UNDER THE OIL SPCC REGULATIONS

ABSTRACT Under the U.S. Environmental Protection Agency's (EPA) Oil Spill Prevention, Control, and Countermeasures (SPCC) program, facilities must complete an oil spill prevention and control plan. If a facility is unable to complete a control plan, a contingency plan must be completed in accordance with the SPCC regulations. A recent EPA SPCC Program Task Force found these regulations to be inadequate in several areas, including mandatory facility-specific contingency planning. Contingency planning should be conducted in a three-phase approach: completing risk assessment of the specific facility, determining the manner in which identified risks will be managed, and preparing for the execution of contingency plans during a spill emergency. A risk assessment of a facility subject to the SPCC regulations consists of hazard identification, vulnerability and exposure analysis, and event and fault tree analysis. Risk management consists of various components, including the identification of personnel, equipment, emergency procedures, and waste disposal options. The execution of a contingency plan depends upon accessibility of the appropriate equipment, which may include trucks, boats, communication systems, booms, and dispersants. Contingency plans for facilities covered under the SPCC regulations should provide specific information related to notification procedures, spill response, and mitigation.

A COMPARISON OF REGULATIONS RELATED TO THE OIL SPCC PROGRAM

ABSTRACT Several federal agencies regulate selected aspects of the production, refining, transportation, and storage of petroleum and petroleum products. Based on analyses of such programs, the U.S. Environmental Protection Agency (EPA) may propose modifications to the Oil Spill Prevention, Control, and Countermeasures (SPCC) program. These proposed changes would be likely to result in improved consistency with other government and industry standards. Regulatory changes may occur in two extensive and significant areas: adoption of specific and widely recognized industry and regulatory tank standards, and mandatory contingency planning at all facilities covered by the SPCC regulations. Relevant industrial, trade association, and technical standards generated by the American Petroleum Institute, the Underwriters Laboratories, Inc., the National Fire Protection Association, the American National Standards Institute, and the National Association of Corrosion Engineers have been reviewed for applicability to the SPCC regulations. Areas of concern include materials specifications, welding requirements, pressure testing prior to service, overpressure and vacuum relief requirements, design specifications, hydrostatic testing requirements, and siting specifications.

A CASE HISTORY ILLUSTRATION OF EPA'S REGION 6 SPILL PREVENTION, CONTROL AND COUNTERMEASURES PROGRAM

ABSTRACT An inspection program addressing oil spills and spill prevention was conducted in the environmentally sensitive Caddo Lake area of Texas and Louisiana. Eighty oil storage leases were inspected in this area, and 82.5 percent of these leases were found to be out of compliance. Through EPA's Region 6 oil spill prevention program, which includes working to promote compliance with the Spill Prevention, Control, and Countermeasures (SPCC) regulations by the facility, all but one of the leases achieved compliance.

COMPREHENSIVE SPILL MANAGEMENT AT AN OIL FIRED ELECTRIC POWER PLANT ON THE COLUMBIA RIVER*

ABSTRACT A comprehensive oil spill control project at an oil-fired electric power plant resulted in preparation of a spill prevention, control, and countermeasures (SPCC) plan for the facility and an operations manual for fuel transfer at the fuel dock on the Columbia River. Hydrologic studies led to the design of a spill containment system for the dock. Engineering techniques were established for evaluating the design's effectiveness in this estuarine location.

OIL SPILL PREVENTION AND CONTROL AT NAVAL SHORELINE ACTIVITIES1

ABSTRACT In response to Environmental Protection Agency and U.S. Coast Guard regulations, the United States Navy has undertaken a comprehensive program to minimize the potential for land-based oil spills originating from naval shoreline oil storage and handling facilities. Construction and maintenance projects have been begun to prevent land-based oil spills from occurring or from reaching adjacent navigable waters. These projects were preceded by careful policy development, surveys of existing conditions, and analyses of remedial alternatives. Specifically, the Naval Facilities Engineering Command divisions have assisted shoreline activities in the preparation of oil spill prevention, control, and countermeasures (SPCC), and oil spill contingency plans. Improved spill containment and cleanup technologies, as well as improved personnel training, have contributed greatly to the refinement and upgrading of these plans. SCS Engineers (SCS) has been involved in all phases of compliance with these plans. Plan and manual reviews were supplemented by detailed field surveys and subsequent development of remedial projects to be instituted at all deficient facilities. Based on the preliminary recommendations and design sketches prepared for tank farm sites at San Clemente Island, SCS is now providing design and related services for oil spill prevention and control facilities.

SPCC PLANNING: GOOD MANAGEMENT PRACTICE

ABSTRACT The Oil Spill Prevention Program of the Environmental Protection Agency (EPA) requires Spill Prevention Control and Countermeasure (SPCC) plans for facilities with oil storage capacity above certain minimum amounts. The object of this paper is to discuss the additional beneficial effects of a good SPCC plan beyond the obvious reduction in spill hazard. A good spill prevention plan includes many fundamental good management practices. Cleaner, more attractive facilities, accurate inventories, and safer working conditions, are some of the improvements that may go along as part of a good spill prevention program. Specific examples are drawn from experiences in SPCC planning for a variety of facilities such as home heating oil distributors, truck stop operations, and large manufacturing facilities. Facilities required to have an SPCC plan have more to gain than mere compliance with federal regulations when they put their plan into effect. With a good spill prevention plan, the facility will operate more effectively and more profitably.

SPILL PREVENTION: THE SPCC APPROACH

ABSTRACT The Oil Spill Prevention Program of the Environmental Protection Agency is discussed as it has evolved from the implementing legislation: section 311(j)(l)(C) of the Federal Water Pollution Control Act. The regulations apply to all non-transportation-related facilities with oil storage in excess of certain minimum amounts from which spilled oil could reasonably be expected to reach navigable waters. The prevention program centers around a requirement in the regulation that these facilities must prepare and implement a Spill Prevention Control and Countermeasure (SPCC) plan. The type of engineering analysis needed to prepare or review a plan is discussed along with an outline of what EPA considers to be the elements of a good plan. After the period for plan implementation is past, a facility must submit its SPCC plan to EPA for review if it experiences spill problems. After review, EPA may require revisions to the plan in the form of amendments, but there are several levels of technical appeal on amendments. The paper discusses EPA plan reviews, amendment procedures, appeals on amendments, and finally, penalty procedures and appeals from penalties.

Spill Prevention — Phase II

ABSTRACT Since the enactment of the Water Quality Improvement Act of 1970 considerable progress has been made in contingency planning and spill response. Of the estimated 10,000 oil spills which occur annually, actions have been taken in the majority of the cases to remove the spilled oil from the environment. However, the actual amount recovered is still small compared with the estimated spillage rate of ten million gallons per year. Improved cleanup technology can reduce the amount of oil remaining in the environment but only through implementation of Phase II — Spill Prevention will the number of incidents be reduced. This paper discusses the EPA prevention program as it relates to national oil spill problems. The national program revolves around the spill prevention, control and countermeasure (SPCC) concept which incorporates contingency planning, spill response and prevention into one single comprehensive program. This approach permits flexibility in design and encourages innovation so that each facility may develop an optimum plan to eliminate spills. It is recognized that a facility's age, location and function must be evaluated to determine the best balance between prevention measures and effective spill response. The first phase of this program has been initiated through special provisions of the Refuse Act Permit Program. The program will be expanded with the promulgation of the oil prevention regulation which is being developed in accordance with Section 11(j)(l)(C) of the FWPC* Act as amended.