Field-Wide SPCC Plans

Project: Spill Prevention, Control, and Countermeasure (SPCC) inspections and SPCC Plan

Project Characteristics:

The U.S. Environmental Protection Agency (EPA) Code of Federal Regulations (CFR) Title 40 addresses Protection of the Environment. CFR 40, Chapter I, Subchapter D, Part 112 addresses Oil Pollution Prevention. The owner or operators of non-transportation-related onshore or offshore facilities engaged in drilling, producing, gathering, storing, processing, refining, transferring, distributing, using, or consuming oil and oil products, which due to their location could reasonably discharge oil in quantities that may be harmful. Consequently, this oil may be discharged into navigable waters of the United States (WOTUS) or adjoining shorelines. Owners or operators are thus required to prepare, implement, and maintain a Spill Prevention, Control, and Countermeasure (SPCC) Plan. As required by 40 CFR 112, a Professional Engineer (P.E.) must review and recertify the SPCC Plan any time the facility undergoes technical changes, or at least once every five years. 

Ensolum conducted a required five-year review of 13 field-wide SPCC Plans in Colorado and Wyoming. Ensolum reviewed for overall compliance with current SPCC regulations and updated to changes in owner or operator processes and procedures.

As part of the five-year review, a Colorado or Wyoming Registered P.E. inspected, reviewed, and updated as appropriate within the field-wide SPCC Plan over 500 oil and gas production facilities, saltwater disposal facilities, compressor stations, and gas plants. During the inspection, Ensolum inventoried tanks and equipment and measured containment around all SPCC-applicable tanks and containers. Additionally, Ensolum noted potential areas of environmental concern. Due to the high volume of facilities included in the review, Ensolum utilized a customized mobile application data collection database to increase efficiency in the field and during the compliance review. Ensolum provided for each facility in the SPCC Plan. In addition, Ensolum provided standardized figures and calculation tables. Ensolum identified deficiencies and provided corrective action recommendations for compliance. 

P.E certified final SPCC. The P.E. certification is valid for a period of five years, at which point the SPCC Plans require another full review. Ensolum will maintain the data collected during their review in the client-specific database. It is readily available to access or update as needed. 

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