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SPCC Requirements and Pollution Prevention Practices for Oil Production, Drilling and Workover Facilities
Overview
This guide will assist oil production, drilling and workover facilities with the prevention and control of oil spills. Other guides have been developed to assist other industry sectors in the regulated community. This guide discusses the equipment and operating practices needed to meet the requirements of the Federal Oil Pollution Prevention Regulation found in Title 40 Code of Federal Regulations (CFR) Part 112, which includes the Spill Prevention Control and Countermeasure (SPCC) Plan requirements and the Facility Response Plan (FRP) requirements. The SPCC requirements are the focus of this guide; other guides are available for the facility response planning requirements (40 CFR 112.20 and 112.21) and general information on the Oil Pollution Prevention Regulation.
Recommended practices for pollution prevention and avoiding discharges of oil are also included in this guide. These practices may also assist facilities in achieving compliance with the SPCC requirements and reduce the possibility of product loss and a discharge.
Applicability
of the SPCC Requirements to Oil Production, Drilling, and Workover
Facilities
EPA's SPCC requirements (40 CFR 112.1 through 112.7)
apply to nontransportation-related facilities that could reasonably
be expected to discharge oil into or upon the navigable waters of
the United States or adjoining shorelines, and that have (1) a total
underground buried storage capacity of more than 42,000
gallons; or (2) a total aboveground oil storage capacity
of more than 1,320 gallons, or (3) an aboveground
oil storage capacity of more than 660 gallons in
a single container.
Some facilities may not be regulated if, due to their
location, they could not reasonably be expected to discharge oil
into navigable waters of the U.S. or adjoining shorelines. SPCC-regulated
facilities must also comply with other federal, state, or local
laws, some of which may be more stringent.
An onshore production facility may
include all wells, flowlines, separation equipment, storage facilities
gathering lines, and auxiliary nontransportation-related equipment
and facilities in a single geographical oil or gas field operated
by a single operator. An offshore oil drilling production,
or workover facility may include all drilling or workover equipment,
wells, flowlines, gathering lines, platforms, and auxiliary nontransportation-related
equipment and facilities in a single geographical oil or gas field
operated by a single operator.
Many oil drilling and production facilities are subject
to the SPCC requirements, and some may be subject to the Facility
Response Plan (FRP) requirements under 40 CFR 112.20 and 112.21
and associated appendices. All owners or operators of SPCC-regulated
facilities should determine whether the facility poses a threat
of substantial harm to the environment. As outlined in 40 CFR 112.20(f)(1),
a facility has the potential to cause substantial harm if:
- The facility transfers oil over water to or from vessels
and has a total oil storage capacity,
including both aboveground storage tanks (ASTs) and underground
storage tanks (USTs), greater than or equal to 42,000 gallons;
or
- The facility's total oil storage capacity, including both ASTs and USTs, is greater than or equal to one million gallons, and one of the following is true:
-
The facility lacks secondary containment able to contain the capacity of the largest AST within each storage area plus freeboard to allow for precipitation;
-
The facility is located at a distance such that a discharge from the facility could cause injury to an environmentally sensitive area;
-
The facility is located at a distance such that a discharge from the facility would shut down a public drinking-water intake; or
-
The facility has had a reportable spill greater than or equal to 10,000 gallons within the last five years.
All facilities must document the determination of substantial harm by completing the "Certification of the Applicability of the Substantial Harm Criteria Checklist," provided as Attachment C-II in Appendix C of 40 CFR 112. This certification should be kept with the facility's SPCC Plan. Click here for more information on navigable waters and oil.
The owner or operator of an SPCC-subject facility is required to have a written site-specific spill prevention plan, which details how a facility's operations comply with the requirements of 40 CFR 112.
Requirements for specific elements to be included
in the SPCC Plan are found in 40 CFR 112.7. The SPCC Plan must be
reviewed and certified by a Registered Professional Engineer who
is familiar with SPCC and has examined the facility. To be in compliance,
the facility's SPCC Plan must satisfy all of the applicable requirements
for drainage of all operating areas (e.g., oil production, oil drilling,
and workover facilities), containment for tank batteries and central
treating stations, bulk storage tanks, unloading and loading areas,
transfer operations (intrafacility piping), inspections and records,
security, and training. Most importantly, the facility must fully
implement the SPCC Plan. Newly constructed facilities and facilities
that make modifications must prepare or revise their SPCC Plan within
six months. Modifications may include, for example, changes in piping
arrangements or installation or removal of tanks.
[40 CFR 112.7(c)]
SPCC requires containment of drainage from the operating
areas of a facility to prevent oil spills and contaminated runoff
from reaching storm drains, streams (perennial or intermittent),
ditches, rivers, bays, and other navigable waters.
Secondary containment and diversionary structures
should be in place to contain oil-contaminated drainage (e.g., rainwater)
or leaks from all tank battery and central treating plant installations.
For these purposes, facilities should use dikes, berms, curbing,
culverts, gutters, trenches, absorbent material, retention ponds,
weirs, booms, and other barriers or equivalent preventive systems.
SPCC requirements are performance-based, which permits facility
owners and operators to substitute alternative forms of spill containment
if the substitute provides substantially equivalent protection against
discharges to navigable waters to that provided by the systems listed
in 40 CFR 112.7(c).
Substantially
equivalent containment systems may be possible for AST systems (e.g.,
small double-walled ASTs equipped with spill prevention devices)
that generally have capacities of less than 12,000 gallons. Alternative
containment systems may not be appropriate for tank systems larger
than 12,000 gallons or for systems that consist of several tanks
connected by manifolds or other piping arrangements that would permit
a volume of oil greater than the capacity of one tank to be spilled
as a result of a single system failure.
Secondary Containment
Systems
Dirt berms or retaining walls are commonly employed for secondary containment purposes, especially at very large oil storage tank farms where installing concrete retaining walls would be too expensive. Field production facilities almost always utilize dirt berms for containment purposes, due to the availability and cost effectiveness of dirt in production areas. If dirt berms are used, they should contain some clay and be compacted. Limitations of using dirt for building secondary containment structures are:
- Erosion - Earthen berms are subject to water and wind erosion and require frequent rebuilding.
- Impermeable soil - Sandy soil does not effectively contain oil spills; groundwater contamination may result. Impervious liners of clay or synthetic membranes may be required to contain oil spills.
- Plant growth - Vegetation inside bermed areas is a fire hazard and also restricts the operator's ability to detect spills or defective equipment. In addition, large vegetation, such as trees or bushes, have root systems which could degrade the berm and facilitate leakage.
Some facilities may use concrete blocks to build secondary containment structures. Concrete blocks may not be sufficient for this purpose for the following reasons:
-
Settling eventually separates or cracks the blocks and destroys the integrity of the wall.
-
Concrete blocks are very porous and do not establish liquid-tight seals between mortared joints.
-
Water and ice penetrate the blocks and eventually break them apart due to the freeze-thaw expansion properties of water.
If concrete is used to build secondary containment
structures, then poured concrete walls are the preferred method.
Poured concrete containment systems are very strong, fairly watertight,
and resistant to petroleum penetration. It should be stressed that
conventional concrete is not totally impervious to petroleum, and
any spill left inside a containment area may eventually penetrate
the concrete and conceivably contaminate groundwater sources. Therefore,
spills inside diked areas should be cleaned up as soon as possible.
Whatever material or method is employed for secondary
containment, it must hold the entire contents of the largest tank
located in the containment structure. The containment structure
must be sufficiently impervious to contain spilled oil. Diked areas
should be free of pooled oil; spills should be removed promptly.
Tank batteries and central treating stations, which may use any of the secondary containment systems listed in the above section, should have drains closed and sealed at all times except when rainwater is being drained. Prior to drainage, the diked area must be inspected to ensure that:
- The water meets applicable water quality standards and will not cause a harmful discharge, i.e., oil sheen upon the surface or a sludge or emulsion deposit beneath the surface of the water;
- The bypass valve is opened and resealed following drainage under responsible supervision; and
- Adequate records are kept of such drainage, i.e., time, date, employee who performed drainage. These records should be made part of the SPCC Plan and kept for three years at a minimum.
Accumulated oil on the water should be picked up and returned to storage or disposed of in accordance with approved methods.
Field drainage ditches, road ditches, and oil traps,
sumps or skimmers, if such exist, should be inspected at regularly
scheduled intervals for accumulation of oil that may have escaped
from small leaks. Any such accumulation should be removed.
Tank Material
Most production storage tanks are constructed of welded, riveted, or bolted steel. Fiberglass tanks are commonly used for storing saltwater (brine). Most steel tanks are provided with removable clean-out plates which allow workers to enter the tanks and clean them or perform repairs. Most tanks require periodic cleaning due to paraffin (a wax-like hydrocarbon) deposits and sediment accumulation. The gasket located between the clean-out plate and tank is a common source of leakage and should be periodically checked, repaired, or replaced as necessary.
Wooden tanks cannot be repaired if they are leaking, rotten, or lack structural integrity. Evidence of fresh oil-saturated soil or pooling oil around the tank is an adequate indication of leakage. Since leaking wooden tanks cannot be repaired, they need to be taken out of service.
No tank should be used for the storage of oil unless its material and construction are compatible with the material stored and the conditions of storage.
Secondary Containment
All tank battery and central treating plant installations
should be provided with a secondary means of containment for the
entire contents of the largest single tank, if feasible, or an alternate
system, such as those outlined in 40 CFR 112.7(c)(1).
Drainage from undiked areas should be safely confined
in a catchment basin or holding pond. This may not be practical
for a production facility due to terrain, weather, or the location
of the undiked areas. In such cases, a production facility owner
may want to substitute a contingency plan which designates equipment
and manpower to control, contain, and clean up a spill in this area,
in lieu of using secondary containment.
Visual Inspections
On a scheduled periodic basis, all tanks that are
used for oil storage should be visually examined by a competent
person for condition and need for maintenance. Such examination
should include the foundation and supports of tanks that are above
the surface of the ground. There should be no large gaps between
the foundation and the tank bottom or between the ground surface
and the tank bottom (if the tank sits directly on the ground). Concrete
foundations should not be crumbling or excessively cracked. Storage
tank foundations should provide adequate support for tanks.
ASTs should be properly maintained to prevent leakage
of oil through bolts, gaskets, rivets, seams, and any other part
of the tank. Tanks should be structurally intact, with no cracks,
holes, or leaks.
Oil storage tanks should be maintained and free of
excessive rust and exterior corrosion. Excessive rust or corrosion
may be identified by pitting or flaking on steel surfaces. A good
maintenance program will provide for periodic cleaning and painting
of tanks.
Fail-Safe Engineering
New and old tank battery installations should be fail-safe engineered or updated to prevent spills. Consideration should be given to one or more of the following:
- Adequate tank capacity to assure that a tank will not overfill if a pumper/gauger is delayed in making his/her regular rounds. High volume producing wells should have adequate storage capacity to handle production yields. Evidence of tank overflows, such as streaks down the sides of the tanks or pooled oil, may be an indication that tank capacity is inadequate for the lease.
- Overflow equalizing lines between tanks so that a full tank can overflow to an adjacent tank. These lines are usually located on the top of the tanks.
- Vacuum protection to prevent tank collapse when oil is removed during a pipeline run. Vacuum vents allow air flow into a tank and prevent a vacuum from forming inside the tank.
- High level sensors generate and transmit an alarm signal to a computer, where such facilities are a part of a computer production-control system. It is fairly uncommon to find production facilities which are computer controlled due to the remote nature of most production areas.
All aboveground pipes and valves should be regularly
examined on a scheduled basis by trained personnel. Flange joints,
valve glands and bodies, supports, and metal surfaces should be
evaluated. Any defective or leaking equipment should be replaced
or repaired. Pumping well polished rod stuffing boxes should be
examined often, because leaks can develop quickly when stuffing
boxes lose their seals due to friction from contact with the moving
polished rod.
Off-load lines or sales outlet connections used for
tank truck transfers of crude oil should have valves closed and
outlets capped when not in use. Drip pans or buckets should be placed
below the outlet or connection to catch small spills or leaks of
oil.
Brine Disposal
Saltwater (brine) disposal facilities should be examined
often to detect system upsets that could cause an oil discharge,
particularly following sudden changes in atmospheric temperature.
Flowline Maintenance
Production facilities should have a program of flowline
maintenance to prevent spills from this source. The program should
include periodic examination and corrosion protection. Flowlines
should be repaired or replaced as necessary.
Adequate records should be made of such repairs, kept
for a minimum of three years, and made part of the SPCC Plan.
Mobile drilling or workover equipment should be positioned
or located so as to prevent spilled oil from reaching navigable
waters.
Depending on the location of the well, catchment basins
or diversionary structures (i.e., ditches, berms, walls, etc.) may
be necessary to intercept and contain spills of fuel, crude oil,
or oily drilling fluids.
Before drilling below any casing string or during
workover operations, a BOP assembly and well control system should
be installed that is capable of controlling any wellhead pressure
that could be encountered while the BOP assembly is on the well.
Casing and BOP installations should be installed in accordance with
state regulatory agency requirements.
Oil drainage collection equipment must be used to
prevent and control small oil spillage around pumps, glands, valves,
flanges, expansion joints, hoses, drain lines, separators, treaters,
tanks, and allied equipment. Drains on the facility should be controlled
and directed toward a central collection sump or equivalent collection
system sufficient to prevent discharges of oil into navigable waters.
Where drains and sumps are not practicable, oil contained in collection
equipment should be removed as often as necessary to prevent overflow.
For facilities employing a sump system, sump and drains
should be adequately sized and a spare pump or equivalent method
should be available to remove liquid from the sump and assure that
oil does not escape. A regularly scheduled preventive maintenance
inspection and testing program should be employed to assure reliable
operation of the liquid removal system and pump startup device.
Redundant automatic sump pumps and control devices may be required
on some installations.
In areas where oil-water separators and heater-treaters
are equipped with dump valves, which fail most often in the closed
position creating a high pollution risk, the facility must be specially
equipped to prevent the escape of oil. This could be accomplished
by extending the flare line to a diked area if the separator is
near shore, equipping it with a high liquid-level sensor that will
automatically shut in wells producing to the separator, parallel
redundant dump valves, or other feasible alternatives to prevent
oil discharges.
Atmospheric storage or surge tanks should be equipped
with high liquid-level sensing devices or other acceptable alternatives
to prevent oil discharges. Pressure tanks should be equipped with
high and low pressure sensing devices to activate an alarm or control
the flow or with other acceptable methods to prevent oil discharges.
Tanks should be equipped with suitable corrosion protection.
A written procedure for inspecting and testing pollution prevention
equipment and systems should be prepared and maintained at the facility.
Such procedures should be included as part of the SPCC Plan.
Testing and inspection of the pollution prevention
equipment and systems should be conducted by the owner or operator
on a scheduled periodic basis in accordance with applicable regulations
commensurate with the complexity, conditions and circumstances of
the facility.
Surface and subsurface well shut-in valves and devices
in use at the facility should be sufficiently described to determine
method of activation or control (e.g., pressure differential, change
in fluid or flow conditions, combination of pressure and flow, manual
or remote control mechanisms). Detailed records for each well, while
not necessarily part of the plan, should be kept by the owner or
operator.
Before drilling below any casing string and during
workover operations, a blowout preventer (BOP) assembly and well
control system should be installed that are capable of controlling
any wellhead pressure that is expected to be encountered while that
BOP assembly is on the well. Casing and BOP installations should
be installed in accordance with state regulatory agency requirements.
Extraordinary well control measures should be provided
that would address emergency conditions, including fire, loss of
control and other abnormal conditions. The degree of control system
redundancy should vary with hazard exposure and probable consequences
of failure. It is recommended that surface shut-in systems have
redundant or ''fail close'' valving. Subsurface safety valves may
not be needed in producing wells that will not flow but should be
installed as required by applicable state regulations.
To eliminate any potential for misunderstandings,
written instructions should be prepared by the owner or operator
for contractors and subcontractors to follow whenever contract activities
include servicing a well or systems appurtenant to a well or pressure
vessel. Such instructions and procedures should be maintained at
the offshore production facility. Under certain circumstances and
conditions, such contractor activities may require the presence
at the facility of an authorized representative of the owner or
operator who would intervene when necessary to prevent a spill.
All manifolds (headers) should be equipped with check
valves on individual flowlines.
If the shut-in well pressure is greater than the working
pressure of the flowline and manifold valves up to and including
the header valves associated with that individual flowline, the
flowline should be equipped with a high pressure sensing device
and shut-in valve at the wellhead unless provided with a pressure
relief system to prevent overpressuring and system failure.
All pipelines appurtenant to the facility should be
protected from corrosion. Methods used, such as protective coatings
or cathodic protection, should be discussed in the SPCC Plan.
Submarine pipelines appurtenant to the facility should
be adequately protected against environmental stresses and other
activities, such as fishing operations. They should be in good operating
condition at all times and inspected on a scheduled periodic basis
for failures. Such inspections should be documented and maintained
at the facility.
Wellheads and Christmas
Trees
Flowing and pumping wells should be maintained and
inspected for leaks and possible sites of failure. This means that
wellheads (both casing heads and tubing heads), christmas trees,
and associated valves, fittings, and pressure gauges should be inspected
and repaired as necessary. Leaks which have saturated the soil should
be stopped and any accumulations of oil removed. Oil-saturated soil
is often removed or remediated in accordance with state regulations.
Separators, Heater-Treaters,
and Other Process Vessels
Separators, heater-treaters, and other process vessels
are susceptible to many of the same corrosion and leakage problems
as petroleum storage tanks. Concrete foundations crack, crumble,
and deteriorate, and vessel bases, flowlines, valves, joints, and
pressure gauges corrode and leak if not properly maintained.
If present, concrete foundations of separators should
be structurally sound and capable of providing adequate support
for the separator. Separator vessels themselves should be free of
extensive corrosion, cracks, or leaks. Flowlines, dump valves, joints,
and gauges should be adequately maintained and free of leaks and
drips. Dump valves commonly malfunction and should be checked. Soil
beneath separators should not be saturated with oil. Adequate secondary
containment must be provided to contain spills. This can be provided
in the form of a dike or berm, or a drainage system which flows
into a holding pond or basin to catch and contain a spill.
The containment system must be large enough to hold
the contents of the largest process vessel or storage tank.
Flarelines
Flarelines are sometimes used to vent excess gas pressure
from heater-treater (separator) units to a site away from the tank
battery. These flarelines are a source of occasional spillage when
the dump valve located on the separator malfunctions and oil is
forced out the flareline and onto the ground outside the retaining
berm. If there are indications of spillage, such as oil stains,
or pooled oil under flarelines, flarelines should be provided with
secondary containment in the form of sumps, dikes, or retention
ponds.
Oil production facilities are subject to the same
inspection and record keeping requirements as bulk oil storage facilities
regarding diked area drainage, transfer operations, and flowline
maintenance. Tanks, separators, supports and foundations must be
visually examined on a scheduled periodic basis and adequate records
must be kept.
Records of inspection procedures, maintenance, and
draining of diked areas should be included in the facility's SPCC
Plan, and must be kept for a minimum of three years.
Oil production facilities are subject to the same
requirements regarding personnel training in spill prevention as
bulk oil storage and handling facilities.
A large number of spills are caused by operator error;
therefore, training and briefings are important for the safe and
proper functioning of a facility. Training encourages up-to-date
planning for the control and response to a spill and an understanding
of the facility's spill prevention controls and SPCC Plan. Regular
safety and spill prevention briefings should be held to facilitate
discussions of spill events or failures, malfunctioning equipment,
and recently developed precautionary measures. Also, one person
must be designated accountable for spill prevention at the facility.
Owners
and operators are responsible for properly instructing drivers,
tank gaugers, pumpers, and any other operating personnel involved
in oil operation systems in the operation and maintenance of equipment
to prevent the discharge of oil and applicable pollution control
laws, rules and regulations. All employees should be familiar with
the SPCC Plan and where it is kept, or have a copy of the Plan available
for their use.
Records of employee training and spill prevention
briefings for personnel should be included in the SPCC Plan and
kept for a minimum of three years. Click here for more information
on the Owner/Operator Relationship.
There are a variety of ways for a facility to be designed and constructed to achieve compliance with the SPCC requirements. Facilities may differ greatly in the types of diversionary structures and spill control equipment employed. Facilities should also consult industry associations, which specifically identify technical and engineering standards for the design and construction of tanks and pipelines; cathodic protection of tanks and pipelines; AST tank bottom liners; tank inspection, repair, alteration, and reconstruction; tank cleaning; and tank overfill protection. These standards may assist the facility in identifying good engineering practices and achieving compliance with the SPCC requirements.
Summary of Common Industry Standards | |
Underwriters Laboratory (UL) Standard 142
Steel Aboveground Tanks for Flammable and Combustible Liquids |
This standard applies to steel atmospheric tanks intended for aboveground storage of noncorrosive, stable, flammable, and combustible liquids that have a specific gravity not exceeding that of water. The standard does not apply to API Standard 650, 12D, and 12F tanks. |
National Fire Protection Association (NFPA)
Code 30
Flammable and Combustible Liquids Code, Chapter Two |
This standard applies to all flammable and combustible liquids, including waste liquids (except those that are solid at 100 degrees Fahrenheit or above and those that are liquefied gases or cryogenic). Chapter Two, Tank Storage, applies to aboveground and indoor storage of liquids in fixed tanks and portable tanks with storage capacities of more than 660 gallons. |
American
Petroleum Institute (API) Standard 620
Design and Construction of Large, Welded, Low-Pressure Storage Tanks |
This standard addresses large field-assembled storage tanks that have a single vertical axis of revolution and contain petroleum intermediates and finished products, as well as other liquid products handled and stored by the petroleum industry. |
API Standard 650
Welded Steel Tanks for Oil Storage |
This standard provides material, design, fabrication, erection, and testing requirements for vertical, cylindrical, aboveground, closed- and open-top, welded steel storage tanks in various sizes and capacities. |
API Recommended Practice 651
Cathodic Protection of ASTs |
This recommended practice describes the corrosion problems characteristic in steel ASTs and associated piping systems and provides a general description of the two methods used to provide cathodic protection. |
API Recommended Practice 652
Lining AST Tank Bottoms |
This recommended practice describes the procedures for achieving effective corrosion control in ASTs by application of tank bottom linings to existing and new storage tanks. |
API Standard 653
Tank Inspection, Repair, Alteration, and Reconstruction |
This standard pertains to carbon and low alloy steel tanks built in conformance with API Standard 650 or 12C and provides criteria for the maintenance, inspection, repair, alteration, relocation and reconstruction of welded or riveted, nonrefrigerated, atmospheric pressure ASTs after they have been placed in service. |
API Recommended Practice 920
Prevention of Brittle Fracture |
This recommended practice addresses toughness levels for pressure vessels to prevent failure by brittle fracture. |
API Standard 2015
Safe Entry and Cleaning of Tank |
This standard provides guidelines for the development of safety practices for planning, managing, and conducting work in atmospheric and low pressure storage tanks. |
API Recommended Practice 2350
Overfill Protection for Petroleum Tanks |
This recommended practice provides guidelines for establishing operating procedures and for selecting equipment to assist in the reduction of overfills. |
API Standard 2610
Design, Construction, Operation and Maintenance and Inspection of Terminal and Tank Facilities |
This standard compiles various standards, specifications, and recommended practices developed by API and other entities for managing terminals and tanks. |
Acknowledgments
We would like to acknowledge Richard Franklin, U.S.
EPA Region VI, for his valuable assistance in the preparation of
this guide. The following publication also provided valuable assistance:
U.S. Environmental Protection Agency, 1995. SPCC/OPA
Manual. U.S. EPA Region VIII, Ecosystem Protection and Remediation
Preparedness Team. Denver, Colorado.