HomeMy WebLinkAbout1.17 Split Oxy SPCC Plan 020413
Spill Prevention Control and
Countermeasure Plan
Cascade Creek and Collbran
Operational Areas
Mesa and Garfield Counties, Colorado
Prepared for:
OXY USA WTP LP and OXY USA Inc.
Mid-Continent Business Unit – Piceance Asset
760 Horizon Drive Suite 101
Grand Junction, CO 81506
Prepared November 2011
Format Updated February 2013
Oxy SPCC Plan – Cascade Creek and Collbran Operational Areas Review Page 1
Revision Date 2/12/2013 Issued 9/29/2011
Spill Prevention, Control and
Countermeasure Plan
Cascade Creek and Collbran
Operational Areas
Mesa and Garfield Counties, Colorado
Date of Plan: November 11, 2011
Designated person(s) accountable for spill prevention:
Chris Clark, Operations Manager, (970) 263-3607
Oxy SPCC Plan – Cascade Creek and Collbran Operational Areas Review Page 2
Revision Date 2/12/2013 Issued 9/29/2011
SPILL PREVENTION, CONTROL AND COUNTERMEASURE PLAN
REVIEW AND AMENDMENT
In accordance with 40 CFR, Part 112.5, this SPCC Plan will be amended when there is a
change in the facility design, construction, operation, or maintenance that materially
affects its potential for a discharge. The amendment will occur within six months of the
change. To aid in ensuring that amendments are made within the required timeframe, the
SPCC Plan will be reviewed semi-annually for changes by Oxy’s Regulatory
Department. The Regulatory Department will use the Facility Change Guidance
Document (Appendix I) to aid in determining which field changes require a technical
amendment of the Plan. Any and all modifications to the SPCC Plan text, tables, figures,
attachments, and appendices shall be documented on the Document
Revision/Amendment Log in Attachment 1. Each revised sheet shall be noted with the
revision number and revision date. All technical (non-administrative) modifications shall
be reviewed and approved by a Colorado registered Professional Engineer.
In accordance with 40 CFR, Part 112.4, this SPCC Plan must also be amended following
a discharge (per 40 CFR Part 112.1(b) and Part 110), of more than 1000 gallons of oil in
a single discharge event, or more than 42 gallons of oil in each of two (2) discharges
occurring within a 12-month period. Oxy’s Health, Environmental, and Safety (HES)
Department handles spill response and reporting associated with Oxy’s Cascade Creek
and Collbran operating areas. When an unauthorized discharge of greater than 1,000
gallons (23.8 barrels) of oil in a single discharge event occurs, or more than 42 gallons (1
barrel) in each of two (2) discharges occurs within a 12-month period, the HES
Department shall notify the Regulatory Department to initiate a review of the release to
determine if the release or releases meet the description of a “discharge” as provided in
40 CFR Part 112.1(b) and Part 110 and amend the SPCC Plan as necessary. Resulting
amendments will address potential design flaws, engineering controls, or implementation
of new best management practices to reduce the potential for similar discharges. Any
amendments that are performed in accordance with these requirements will be
documented on the Document Revision/Amendment Log (Attachment 1).
Additionally, an amendment to the Plan may also be required by the EPA Regional
Administrator following such a discharge(s). Any amendments that are performed in
accordance with these requirements will be documented on the Document
Revision/Amendment Log (Attachment 1). Any technical amendment of this Plan shall
be certified by a Professional Engineer registered in the state of Colorado.
Five-Year SPCC Plan Review
A complete review and evaluation of this SPCC Plan will occur at least once every five
years from the initial certification date. As a result of this review and evaluation, Oxy
will amend the SPCC Plan within six months of the review date to include more effective
prevention and control technology if: (1) such technology will significantly reduce the
likelihood of a spill event from a facility; and (2) if such technology has been field-
proven at the time of review. Any amendment will be implemented as soon as possible
but in no case later than six months after preparation of the amendment. Any technical
amendment of this Plan shall be certified by a Professional Engineer registered in the
Oxy SPCC Plan – Cascade Creek and Collbran Operational Areas Review Page 3
Revision Date 2/12/2013 Issued 9/29/2011
state of Colorado. The Oxy Operations Manager shall review the proposed amendments
and sign the Five-Year SPCC Plan Review Amendment Log below.
I have completed a review and evaluation of the SPCC Plan for the Cascade Creek and
Collbran Operational Areas on the date indicated below and will or will not amend the
Plan as a result of that review:
Five-Year SPCC Plan Review Amendment Log
Review Date Name & Signature Will Plan be
Amended? Amendment Summary
Oxy SPCC Plan – Cascade Creek and Collbran Operational Areas Approval Page 1
Revision Date 2/12/2013 Issued 9/29/2011
MANAGEMENT APPROVAL
OXY USA WTP LP and OXY USA Inc. agrees to provide the manpower, equipment and
materials required to expeditiously control and remove any quantity of oil discharge that
may be harmful. I approve this SPCC Plan and expect all employees and contractors to
abide by the provisions in the Plan. I certify that the provisions in this SPCC Plan are
being fully implemented.
Management Representative: ______________________________________________
Title: _______________________________________________________ ___________
Signature: _____________________________________________________________
Date: _________________________________________________________________
Oxy SPCC Plan – Cascade Creek and Collbran Operational Areas SPCC Page 1
Revision Date 2/12/2013 Issued 9/29/2011
Table of Contents
1.0 Overview and Organization of Plan ........................................................................ 6
2.0 Owner/Operator Contact Information ..................................................................... 8
3.0 Operational Overview ............................................................................................. 8
3.1 Facility Descriptions and Diagrams .................................................................... 9
3.2 Portable and Temporary Equipment ................................................................. 10
4.0 Facility Layouts and Predictions for Spill Flow ................................................... 10
4.1 Aboveground Storage Containers and Flow-through Process Vessels ............. 11
4.2 Portable and Temporary Tanks ......................................................................... 11
4.3 Pits and Ponds ................................................................................................... 12
4.4 Pipelines ............................................................................................................ 12
4.5 Loading/Unloading Operations ......................................................................... 13
5.0 Containment and/or Diversionary Structures ........................................................ 13
5.1 Secondary Containment Specifications ............................................................ 14
5.2 Flowlines and Intra-facility Gathering Lines .................................................... 16
5.3 Containment Requirements for High Density Areas ........................................ 16
6.0 Container and Equipment Installation and Construction ...................................... 17
6.1 Fire Prevention Measures ................................................................................. 17
7.0 Inspections, Testing and Maintenance .................................................................. 17
7.1 Bulk Storage Container Inspection, Testing and Maintenance ......................... 18
7.1.1 Produced Water Container Maintenance .......................................................... 19
7.1.2 Field-constructed Aboveground Container Maintenance ................................. 20
7.2 Portable and Temporary Container Inspection, Testing and Maintenance ....... 20
7.3 Flow-through Process Vessel Inspection and Testing ...................................... 20
7.4 Oil-filled Operational Equipment Inspection, Testing and Maintenance ......... 21
7.5 Transfer Piping Inspection, Testing and Maintenance ..................................... 21
7.5.1 Pipeline Inspection and Monitoring .................................................................. 22
7.5.2 Pipeline Testing and Maintenance .................................................................... 22
7.6 Pit and Pond Inspection and Maintenance ........................................................ 24
7.7 Saltwater Disposal Facilities Inspections .......................................................... 28
7.8 Field Drainage System Inspections ................................................................... 25
7.9 Recordkeeping .................................................................................................. 25
8.0 Discharge Prevention ............................................................................................ 25
8.1 Facility Oil Transfer Procedures ....................................................................... 26
8.2 Spill Prevention Accountability ........................................................................ 26
8.3 Tank Battery Design ......................................................................................... 26
8.4 Facility Loading/Unloading Operations ........................................................... 27
8.5 Facility Drainage ............................................................................................... 27
8.6 Oil Drilling and Workover Facilities ................................................................ 27
9.0 Oil Spill Control and Countermeasures ................................................................ 28
9.1 Contact & Reporting Information For Discharges ............................................ 28
9.2 Discharge Reporting Requirements .................................................................. 29
10.0 SPCC Training Program ....................................................................................... 32
10.1 Oil-handling Personnel Training ....................................................................... 32
10.2 Spill Prevention Briefings ................................................................................. 33
10.3 Training Documentation and Records .............................................................. 33
11.0 Conformance with State and Federal Oil Pollution Prevention Regulations ........ 33
Oxy SPCC Plan – Cascade Creek and Collbran Operational Areas SPCC Page 2
Revision Date 2/12/2013 Issued 9/29/2011
Tables
Table 4.1 AST and Flow-through Process Vessel Failure Modes
Table 4.2 Portable and Temporary Tank Failure Modes
Figures
Figure 1 Vicinity Map of Oxy’s Operational Areas
Figure 2 Sites within the Mesa Production Area
Figure 3 Sites within the Valley Production Area
Figure 4 Sites within the Logan Wash Production Area
Figure 5 Sites within the Brush Creek Production Area
Figure 6 Sites within the East Plateau Production Area
Figure 7 Sites within the Hell’s Gulch Production Area
Attachments
Attachment 1 Document Revision/Amendment Log
Attachment 2 Secondary Containment Calculations Spreadsheets
Attachment 3 Facility Overview Sheets, Facility Diagrams, Substantial Harm
Checklist and Facility PE Certification
Appendices
Appendix A Contact Lists and Emergency Response Procedure
Appendix B Inspection, Maintenance and Testing Protocols
Appendix C Oxy Exhibit A
Appendix D List of Facilities Utilizing 3-Phase Separators
Appendix E Loading/Unloading Procedures
Appendix F Oil Spill Contingency Plan
Appendix G Emergency Response Plan
Appendix H Regulation Citations
Appendix I Facility Change Guidance Document
List of Acronyms
API American Petroleum Institute
ASC Aboveground Storage Container
Bbl/bbls Barrel/barrels
BMPs Best Management Practices
ERP Emergency Response Plan
FD Facility Diagram
FOS Facility Overview Sheet
MI Mechanical Integrity
NFPA National Fire Protection Association
OSCP Oil Spill Contingency Plan
OSHA Occupational Safety and Health Administration
Oxy OXY USA WTP LP and OXY USA Inc.
PPE Personal Protection Equipment
SWD Saltwater Disposal Facilities
SPCC Spill Prevention, Control, and Countermeasure
UL Underwriter’s Laboratory
UST Underground Storage Tank
Oxy SPCC Plan – Cascade Creek and Collbran Operational Areas SPCC Page 3
Revision Date 2/12/2013 Issued 9/29/2011
Cross Reference
40 Code of
Federal
Regulations
(CFR) Part Requirement
SPCC Plan
Section
112.3 (a)(1) Amend Plan as necessary per updated regulations
Review Pg 2
112.3 (b) Amend Plan if a new oil production facility becomes operational Review Pg 2
112.3 (d) Professional Engineer certification
ATT 3
112.3 (e) Maintain a copy of Plan at required facilities
2.0
112.4 Report certain discharges to EPA
Review Pg. 2,
9.2
112.5 (a) Amend Plan following significant changes to the facility
Review Pg 2
112.5 (b) Review Plan at least every five years and amend if appropriate Review Pg 2
112.5 (c) Professional Engineer review of technical amendments
Review Pg 2
112.7 Management approval of Plan
Approval Pg 1
112.7 Provide a cross reference matrix to regulations
Cross
Reference
112.7 Discuss needed facilities, equipment, or procedures not yet operational in
separate paragraphs
5.1
112.7 (a)(1) Discussion of facility conformance with the regulations
11.0
112.7 (a)(2) Equivalent environmental protection is allowed for deviations from
portions of regulations. Reasons for non conformance must be stated
11.0
112.7 (a)(3) Describe the physical layout of the facility. Provide a facility diagram
including tanks, underground tanks, storage areas for mobile containers,
produced water containers, associated piping, transfer stations,
connecting pipes and intra-facility gathering lines
3.1, FOSs,
FDs (ATT 3)
112.7 (a)(3)(i) Plan must include type of oil in each container and capacity of each
container
3.1, 3.2, FOSs,
FDs (ATT 3)
112.7 (a)(3)(ii) Discharge prevention measures including procedures for oil handling at
loading/unloading areas
8.1
112.7 (a)(3)(iii) Drainage control around containers and other equipment
5.0
112.7 (a)(3)(iv) Countermeasures for discharge discovery, response and cleanup 9.0, APP F
112.7 (a)(3)(v) Methods of disposal of recovered materials
9.0, APP F
112.7 (a)(3)(vi) Contact list including phone numbers
9.1, APP A
112.7 (a)(4) Discharge reporting procedures, information to be included
9.2
112.7 (a)(5) Organize Plan to make it useful in an emergency
9.1
112.7 (b) Provide an equipment failure analysis including sources, quantity,
direction, and rate of flow
4.0
112.7 (c) General secondary containment requirement (typical failure mode and
most likely quantity) for areas from which a discharge could occur by at
least one of eight specified measures
5.0
112.7 (d) If necessary provide an explanation of impracticability of secondary
containment, conduct periodic integrity testing of containers and
periodic integrity and leak testing of valves and piping
11.0
112.7 (d)(1) For impracticability, provide an oil spill contingency Plan per part 109 11.0, APP F
112.7 (d)(2) For impracticability, provide written commitment of manpower,
equipment, and materials
Approval Pg 1
Oxy SPCC Plan – Cascade Creek and Collbran Operational Areas SPCC Page 4
Revision Date 2/12/2013 Issued 9/29/2011
40 Code of
Federal
Regulations
(CFR) Part Requirement
SPCC Plan
Section
112.7 (e) Written procedures for inspections and tests
7.0, APP B
112.7 (e) Records of inspections must be signed and kept with Plan for three years 7.9
112.7 (f)(1) Train oil handling personnel
10.1
112.7 (f)(2) Designate an individual accountable for discharge prevention
8.2
112.7 (f)(3) Conduct an annual discharge prevention briefing
10.2
112.7 (g) Security (oil production facilities excluded)
N/A
112.7 (h)(1) Provide sized secondary containment (largest compartment on tanker) for
loading/unloading racks
8.4
112.7 (h (2) Provide systems to prevent truck departure before disconnection 8.4, APP E
112.7 (h)(3) Inspect truck prior to filling and departure
8.4, APP E
112.7 (i) Evaluate field constructed containers for brittle fracture failure when
containers are altered or repaired
7.1.2
112.7 (j) Compliance with State requirements
11.0
112.7 (k) Qualified oil-filled operational equipment – alternative to general
secondary containment requirements
7.4
112.7 (k)(2)(i) If no secondary containment, prepare inspection procedures or
monitoring program
7.4
112.7 (k)(2)(ii) If no secondary containment, provide an oil spill contingency Plan per
part 109
7.4, APP F
112.7 (k)(2)(ii) If no secondary containment, provide written commitment of resources 7.4, Approval
Pg 1
112.9 (b)(1) Oil production facility drains of dikes must be kept closed. Inspect diked
areas before draining water and remove accumulated oil
8.5
112.9 (b)(2) Inspect field drainage systems, oil traps, sumps or skimmers for oil and
remove accumulated oil
7.8
112.9 (c)(1) Material and construction of containers must be compatible with stored
material and conditions of storage
6.0
112.9 (c)(2) Provide sized secondary containment (capacity of largest container plus
precipitation) for tank battery, separation, and treating facility
installations
5.1
112.9 (c)(2) Confine drainage from undiked areas to catchment basin or holding pond 5.0
112.9 (c)(3) Visually inspect containers, foundations, and supports periodically and
on a regular schedule
7.0, APP B
112.9 (c)(4) Engineer tank batteries to prevent discharges with one of the following
features:
8.3
112.9 (c)(4)(i) Provide adequate tank capacity to prevent overfilling, or
8.3
112.9 (c)(4(ii)) Provide overflow equalizing lines between containers, or
8.3
112.9 (c)(4(iii)) Provide vacuum protection to prevent collapse, or
8.3
112.9 (c)(4)(iv) Provide high level sensors
8.3
112.9 (c)(5) Alternative to sized secondary containment for some flow through
process vessels
7.3
112.9(c)(5)(i) Periodically and regularly inspect and/or test flow through process
vessels and associated components
7.3
112.9(c)(5)(ii) Take corrective action as indicated by inspections or tests or evidence of
oil
7.0
Oxy SPCC Plan – Cascade Creek and Collbran Operational Areas SPCC Page 5
Revision Date 2/12/2013 Issued 9/29/2011
40 Code of
Federal
Regulations
(CFR) Part Requirement
SPCC Plan
Section
112.9(c)(5)(iii) Remove or stabilize and remediate any accumulation of oil
7.0
112.9 (c)(6) Alternative to sized secondary containment for some produced water
containers
5.1, 7.1.1
112.9 (c)(6)(i) Implement a procedure to remove free-phase surface oil. Include written
procedures, frequency, amount of oil expected inside container, and a PE
certification. Maintain records of these activities.
7.1.1
112.9 (c)(6)(ii) On a regular schedule visually inspect and/or test produced water
containers and associated piping
7.1.1
112.9 (c)(6)(iii) Take corrective action as indicated by inspections or tests or
accumulation of oil
7.0
112.9 (c)(6)(iv) Promptly remove or stabilize and remediate accumulation of oil 7.0
112.9 (d)(1) Periodically and regularly inspect aboveground valves, piping, drip pans,
supports, and pumps associated with transfer operations
7.0
112.9 (d)(2) Inspect salt water disposal facilities
7.7
112.9 (d)(3) For flowlines and intra-facility gathering lines without secondary
containment provide:
5.2
112.9 (d)(3)(i) Oil spill contingency per Part 109 and
5.2, APP F
112.9 (d)(3)(ii) Written commitment of resources
5.2, Approval
Pg 1
112.9(d)(4) Prepare and implement a flowline maintenance program including: 7.5.1, 7.5.2
112.9(d)(4)(i) Ensure materials are compatible with fluids
7.5.1, 7.5.2
112.9(d)(4)(ii) Visually inspect or test flowlines and intra-facility gathering lines on a
regular and periodic schedule. For lines not having secondary
containment the frequency and type of testing must allow for prompt
implementation of the contingency Plan.
7.5.1, 7.5.2
112.9(d)(4)(iii) Take corrective action as a result of inspections, tests, or evidence of a
discharge
7.0
112.9(d)(4)(iv) Promptly remove or stabilize and remediate oil discharges
7.0
112.10 Requirements for onshore oil drilling and workover facilities which are
responsible for providing a site-specific SPCC Plan
8.6
112.20 (e)
112.20(f)(1)
Certification of the applicability of substantial harm criteria
ATT 3
Oxy SPCC Plan – Cascade Creek and Collbran Operational Areas SPCC Page 6
Revision Date 2/12/2013 Issued 9/29/2011
Spill Prevention, Control and Countermeasure Plan
Cascade Creek and Collbran Operational Areas
Mesa and Garfield Counties, Colorado
1.0 Overview and Organization of Plan
This Spill Prevention, Control and Countermeasure (SPCC) Plan has been prepared for
the OXY USA WTP LP and OXY USA Inc. (Oxy) natural gas production facilities
identified in Attachment 2 of this Plan and located in Oxy’s Cascade Creek and Collbran
Operational Areas (in the Mid-Continent Business Unit – Piceance Asset). The Plan has
been prepared in accordance with the requirements established in 40 CFR Part 112 – Oil
Pollution Prevention regulations, Parts 112.1 through 112.7, 112.9, 112.10 and 112.20.
Where applicable, the regulatory citation has been provided at the beginning of each
section containing information regarding compliance with the regulation. Excerpts from
the cited regulations have been provided in Appendix H of this Plan. In some cases the
regulatory language was paraphrased for clarity. Oxy’s SPCC Plan is living document,
and as such, the Plan should be reviewed by Oxy’s Regulatory, Operations, Facilities,
and HES Departments regularly.
The following presents an overview of the remaining sections of this SPCC Plan:
Section 2 identifies the owner and operator of the regulated facilities, including company
contact information; discusses distribution of the Plan and provides an overview of Oxy’s
operations in the areas.
Section 3 provides an overview of area operations and equipment.
Section 4 describes the physical location of the operating areas, and references the
individual facility diagrams that describe the physical layout of each facility managed
under the scope of this Plan.
Section 5 explains the containment and diversionary structures or equipment used at the
facilities to prevent discharged oil from reaching navigable waters.
Section 6 discusses requirements for the construction of containers and equipment.
Section 7 describes the inspections, tests, maintenance and records conducted at the
facility to ensure compliance with applicable SPCC requirements.
Section 8 discusses discharge prevention measures.
Section 9 provides information regarding oil spill control and countermeasures.
Section 10 describes spill prevention training, including personnel training and spill
prevention briefings.
Oxy SPCC Plan – Cascade Creek and Collbran Operational Areas SPCC Page 7
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Section 11 discusses the facility’s overall conformance with state and federal SPCC
requirements, any planned corrective actions, and environmental protection measures
being implemented in the interim.
Figures 1 – 7 are maps identifying the areas of operation included in this Plan.
Attachment 1 contains the Document Revision/Amendment Log. This log is used to
track revisions and amendments that are made to the SPCC Plan. Any and all
modifications to the SPCC Plan text, tables, figures, attachments, and appendices shall be
documented in this section.
Attachment 2 contains the worksheet used to calculate the secondary containment
capacity at each individual facility. The worksheet may be used to aid in evaluating
changes in site conditions and in determining whether or not the capacity of an individual
containment unit is sufficient during inspections.
Attachment 3 contains a listing of facilities managed under the scope of this Plan and an
information sheet for each facility that depicts the layout of the facility and provides
required facility-specific information. Also included in this attachment are the
Substantial harm Criteria Checklist and PE Certification for each facility.
Appendix A outlines contact information for Oxy emergency response personnel and
other emergency contacts identified within the operational areas.
Appendix B contains inspection, testing and maintenance documents and information.
Appendix C contains Oxy’s Exhibit A form to be utilized for documentation purposes in
the event of a release.
Appendix D contains the list of facilities utilizing 3-phase separators.
Appendix E contains loading/unloading procedures and an example of the types of
warning signs found at each facility.
Appendix F contains a copy of the Oil Spill Contingency Plan that has been developed
for the facilities managed under the scope of this Plan.
Appendix G contains a copy of the Oxy Emergency Response Plan for the Piceance
Asset.
Appendix H provides excerpts from the regulations cited in the Plan.
Appendix I contains the Facility Change Guidance Document. This document provides
guidelines for managing SPCC facility changes.
Oxy SPCC Plan – Cascade Creek and Collbran Operational Areas SPCC Page 8
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2.0 Owner/Operator Contact Information
40 CFR 112.3(e)
Oxy owns and operates the facilities being managed under the scope of this Plan. The
Oxy field office located in Grand Junction, Colorado serves as the support office for the
Piceance, Mid-Continent Business Unit. General contact information for the Grand
Junction office is provided below. Contact information for key Oxy operations personnel
working in the Cascade Creek and Collbran Operational Areas is included in Appendix
A.
OXY USA WTP LP and OXY USA Inc.
760 Horizon Drive, Suite 101
Grand Junction, CO 81506
970-263-3600
A copy of this SPCC Plan is maintained at each of the offices identified below. Each of the
offices is normally attended at least four hours per day and serves as the nearest field office
for nearby facilities that are not so attended. The Plan is available for onsite review during
normal business hours. Hard copies of the Plan have been numbered for document control
purposes to ensure that revisions are made to each copy in circulation. Copies that are not
numbered will not be considered complete or current and should not be referenced.
The master copy (original) of this Plan is maintained at the Grand Junction field office and
is the version with which records of inspections and tests are maintained, in accordance with
Section 7.8 of this Plan.
1. Grand Junction Office (master & e-copy)
2. Cascade Creek Field Office (copy)
3. Brush Creek Field Office (copy)
4. Conn Creek Compression Facility (copy)
5. East Plateau Compressor Station (copy)
6. Alkali Creek Compressor Station (copy)
3.0 Operational Overview
Oxy owns and operates natural gas exploration and production operations in the Cascade
Creek and Collbran Operational Areas located in the Piceance Basin in western Colorado.
The two areas cover approximately 129,000 net acres and include more than 500
production wells and associated production facilities. The Collbran Operational Area is
divided into the Brush Creek, East Plateau, and Hell’s Gulch Production Areas, while the
Cascade Creek Operational Area is comprised of the Mesa, Valley, and Logan Wash
Production Areas. Figure 1 depicts the two operational areas.
In each area, natural gas extraction pads contain wells that operate continuously,
producing a stream containing gaseous and liquid phases. The gaseous and liquid phases
Oxy SPCC Plan – Cascade Creek and Collbran Operational Areas SPCC Page 9
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are processed through a two- or three-phase heated separator located at the extraction pad
where they are physically separated. The gaseous phase is transferred via underground
piping to a central compression facility for distribution and sales. The extracted liquid
fraction contains a mixture of water and petroleum products (i.e., oil). The mixture is
further separated into a condensate fraction containing more oil and a smaller fraction of
water and a produced water fraction, composed of primarily water with a minor amount
of oil. Tri-ethylene glycol dehydration units may be utilized to reduce and/or eliminate
excess fluids in the stream (well pad facilities). Tri-ethylene glycol dehydration units are
utilized at the compression facilities. The condensate and produced water fractions are
piped to storage tanks located at the extraction pad. The condensate is then transferred
off-site for immediate sales or is transferred via piping or truck off-site to the Central
Water Handling Facility for treatment (i.e., additional water removal) and storage before
being transported off-site for sales.
From the extraction pad storage tanks, produced water is transferred via piping or truck to
the Cascade Creek Central Water Handling Facility, where the produced water is treated
by gravity separation for the removal of solids, allowing sufficient time for solids to settle
out before being transferred to an area storage pit for beneficial reuse or being shipped to
an injection well for disposal by Oxy. Products of the production water treatment process
may also be transferred to an off-site location for beneficial reuse or proper disposal.
Separated produced water may also be transferred from either the Collbran or Cascade
Creek Operational Areas via truck or pipeline to an injection facility where it is further
separated and filtered before being sent to an injection well for disposal via pipeline.
The individual natural gas production facilities managed under the scope of this Plan, as
identified in Attachment 3, are defined per 40 CFR 112 as oil production facilities. The
facilities are located in Mesa and Garfield Counties in western Colorado. The Brush
Creek, East Plateau, and the majority of the Hell’s Gulch Production Areas are located in
Mesa County, while the Mesa, Valley, Logan Wash and a small portion of the Hell’s
Gulch Production Area resides in Garfield County.
3.1 Facility Descriptions and Diagrams
40 CFR 112.7(a)(3), (a)(3)(i)
Figure 1 depicts the physical locations of the Cascade Creek and Collbran Operational
Areas, while Figures 2 – 7 identify the locations of individual oil production facilities
within each Production Area. All Oxy oil production facilities located within the
Cascade Creek and Collbran Operational Areas are subject to the requirements of this
SPCC Plan. For each of the subject facilities, a facility overview sheet (FOS) and facility
diagram (FD) has been developed. The FOS identifies the location of the facility and
provides a written description of the physical layout of the individual facility, as well as a
list of containers, container contents, potential spill sources, and an assessment of
existing secondary containment structures. The FDs mark the location and contents of
each fixed oil storage container and the storage area where mobile or portable containers
may be located. In addition, the diagrams identify the location of all underground storage
tanks, transfer stations, connecting pipes, and intra-facility gathering lines. Current FOSs
and FDs are maintained in Attachment 3 of this Plan.
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Revision Date 2/12/2013 Issued 9/29/2011
3.2 Portable and Temporary Equipment
40 CFR 112.7(a)(3)(i)
Facilities may utilize portable/mobile and temporary containers to store 55 gallons or
more of an oil product or material. Such portable containers may be used to store fuels,
lubricating oils, condensate, produced water, etc. Estimated capacities for these
containers range from 55 gallons (e.g., hydraulic oil drum) to 500 bbls (e.g., frac tank).
Depending on the activity, there may be anywhere from 0 to 100 portable containers at a
facility at any given time.
4.0 Facility Layouts and Predictions for Spill Flow
40 CFR 112.7(b)
Where experience indicates a reasonable potential for equipment failure to occur (such as
a tank overflow, pipeline valve leak or rupture, tank leak, etc.), Oxy has performed an
analysis of the typical modes of each type of major failure as part of Oxy’s Critical
Process Equipment annual review. This Critical Process Equipment review is performed
for each new facility or when an existing facility is modified. Included in the review are
predictions for the direction of flow, estimated rates of flow, and total quantity of oil that
could be discharged from the facility as a result of each major type of failure.
Oil spills are expected to be confined to a containment structure unless the failure occurs
outside of containment. If the discharged oil is outside of or moves beyond a
containment structure, the predicted direction of flow will follow the drainage patterns
described on the FOSs and depicted on the individual FDs located in Attachment 3.
Under a worst-case scenario, the total quantity of oil that may be discharged from each
container is anticipated to be the capacity of that container. Where containers are hard-
piped together at or near the bottoms of the tanks for equalization or other purposes, and
valves between the tanks are operated in an open position when unattended, the total
quantity of oil that may be discharged is estimated to be the total capacity of each
interconnected container. The FOS provides the volume of each container and notes any
interconnected containers. A discussion of the types of major equipment failures and
estimates for the anticipated rates of flow for each failure type is provided in the sections
below for Aboveground Storage Containers (ASCs), portable and temporary containers,
flow-through process vessels, pits/ponds, pipelines, and loading/unloading operations.
For pipelines and loading/unloading failures, an estimate of the total volume of oil that
could be released is also provided below.
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4.1 Aboveground Storage Containers (ASCs) and Flow-through
Process Vessels
The major failure modes for ASCs and their associated equipment include valve leaks,
tank overflow, and tank rupture. The rate of material flow from a storage tank due to a
leak or rupture will depend on the cause, size and location of the leak or rupture.
Experience indicates that ASC components are prone to fail at loading/unloading
connections, welds, flanged valve points, near the tank base when exposed to standing
water or when wet gravel/soil maintains contact with side walls, and when damaged (i.e.,
struck by lightning, heavy equipment, etc.). The rate of overflow from an ASC can also
vary depending on the rate of material flow into the tank at the time the tank capacity is
exceeded.
Flow-through process vessels utilized in the Cascade Creek and Collbran Operational
Areas include separators, pig launchers/receivers, knockout pots, pumps, filter pods, etc.
The major failure modes and estimated flow rates for flow-through process vessels mirror
those of ASCs for leaks or ruptures. Because flow-through process vessels are typically
fully enclosed, overflow is not considered a major failure mode for these units.
The following table provides estimated rates of flow in the event of an equipment failure.
Table 4.1 ASC and Flow-through Process Vessel Failure Modes
Failure Mode Estimated Rate of Flow
Valve Leak – Minor Less than 1 bbl/day
Valve Leak – Major 1 to 20 bbl/day
Rupture – Minor Up to 1 bbl/day
Rupture – Catastrophic 1500 bbl/day
Overflow* 1 to 2,600 bbl/day
* Failure mode analysis and rate of flow estimated for ASCs only
4.2 Portable and Temporary Containers
Portable and temporary containers are subject to same major failure modes as ASCs.
Because these containers are generally present in areas of high activity and operators are
expected to closely monitor transfer operations, it is anticipated that the failure of a
portable or temporary container would be discovered and remedied in a timely manner.
As with ASCs, the rate of material flow from a portable or temporary container due to a
leak or rupture will vary according to the cause, size and location of the leak or rupture.
The estimated flow rates provided in Table 4.2 below are based on past experience.
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Table 4.2 Portable and Temporary Container Failure Modes
Failure Mode Estimated Rate of Flow
Valve Leak – Minor Less than 1 bbl/day
Valve Leak – Major 40 to 250 bbl/day
Rupture – Minor Up to 1 bbl/day
Rupture – Catastrophic 37,500 bbl/day
Overflow 1 to 250 bbl/day
4.3 Pits and Ponds
Produced water may be stored within permitted pits or ponds located at facilities within
the Cascade Creek and Collbran Operational Areas. Pits are generally utilized during
drilling and initial completions activities as reserve pits which may receive de minimus
amounts of hydrocarbons. Any oil encountered during initial drilling and completions are
managed in accordance with Colorado Oil and Gas Conservation Commission (COGCC)
regulations. Storage ponds are typically used to store filtered produced water containing
a limited amount of oil and are therefore managed under the scope of this Plan. Pits and
ponds currently managed under this SPCC Plan are identified on the FOS and FD
provided in Attachment 3.
The major failure mode associated with pits and ponds involves the failure of a primary
liner resulting in a release to the secondary liner or, where double liners are not used,
resulting in a release to the ground. Pits and ponds are typically provided with two high-
density polyethylene liners (a primary and secondary liner) or a high-density
polyethylene liner with a geocomposite underlayment layer. Oxy’s largest storage pond
is also equipped with a leak detection system. The potential discharge rate of material
flow from a leaking liner may range from 1 to 10 bbl/day. Pits are typically monitored
through visual inspection. Ponds are monitored by a number of methods, including the
use of high level indicators networked to Oxy’s SCADA system which provides real-time
fluid level data and periodic checks of the interstitial space between liners. These best
management practices (BMPs) should ensure that the volume of material likely to be
released from a pit before a leak or overflow is identified and corrected is minimal.
4.4 Pipelines
Major failure modes for pipelines include leaks and ruptures. The rate of material flow
from a pipeline due to a leak or rupture will depend on the size of the line, rate of flow of
material through the line, and the size, location and cause of the leak or rupture.
Experience indicates that pipelines are prone to fail at connections, welds, flanged valve
points, risers, and any sections of line with turbulent flow and/or differing pressures, such
as elbows, reductions, intersections, etc. The estimated rate of flow for a small-sized leak
is less than one bbl/min, while the rate of flow associated with the complete rupture of a
major transfer pipeline could be in excess of 100 bbl/min. The total amount that could be
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discharged in the event of a pipeline rupture will depend on the location and magnitude
of the failure and could exceed the maximum capacity of the largest container being
transferred (ranging from the smallest container volume to the largest, as identified in
Attachment 3).
4.5 Loading/Unloading Operations
At many of the facilities managed under the scope of this Plan, condensate and produced
water are transported to and from the site via tank truck. While loading, the potential
exists for the truck compartment to overflow, or the transfer hose to malfunction, break or
prematurely disconnect during the loading process. In addition, any volume of oil
remaining in the transfer hose may inadvertently be drained to the ground while
disconnecting from the truck. Although drip pans or loading buckets are provided for
truck and tank connections at each production facility, a spill may occur if the release is
not immediately controlled or the volume released exceeds the capacity of the drip pad or
bucket. The estimated rate of material flow resulting from an overflow or broken hose
component is based on the average pump loading rate and is anticipated to be 1 to 10
bbl/min. Should the leak, rupture, disconnection, etc. occur on a line open to the tank or
tank truck, the flow rate may be higher.
The total oil quantity that could be discharged will depend on the location and magnitude
of the failure. The total volume of oil that could be discharged from a failure at a tank
truck connection under a worst-case scenario is 110 bbl, the volume of the largest pump
truck utilized at facilities in the Cascade Creek and Collbran Operational Areas. Should a
failure occur at or near a tank loading/unloading arm, the spilled oil would likely be
contained within the unit’s secondary containment structure. However, some
loading/unloading connections reside outside the containment structure. In such cases the
total volume of oil that could be discharged is estimated to be the volume of the tank
being loaded or unloaded.
Because loading and unloading operations are continuously monitored by trucking
personnel, the total volume of oil released before the problem is identified and corrected
should be limited.
5.0 Containment and/or Diversionary Structures
40 CFR 112.7(a)(3)(iii), 112.7(c), 112.9(c)(2)
Containers and equipment used to store, process and/or transfer oil-containing materials
are considered to be primary containment for the oil. Examples of primary containers
used in the Cascade Creek and Collbran Operational Areas include storage containers,
process vessels, transfer piping, pits/ponds, and portable/temporary containers and
equipment. SPCC regulations require that a secondary means of containment be
provided for primary containers to prevent a discharge of oil from reaching a waterway.
The secondary containment systems used at Oxy facilities include both active and passive
methods. Passive measures are permanent installations that don’t require deployment,
such as berms, dikes, and permanent prefabricated units. Active measures such as the
placement of drip pans or sorbent materials may also be used.
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General secondary containment is typically achieved through utilization of berms and
walls sufficiently impervious to contain oil. The types of containment structures utilized
include earthen berms, concrete, metal and HESCO (steel wire mesh containers typically
filled with crushed rock/soil) containment structures constructed on-site, prefabricated
units such as bladder pods, and prefabricated polyethylene and metal containers (e.g.,
troughs, stock tanks). Oxy does not maintain bulk oil storage containers in
undiked/bermed areas.
The facility-specific information located in Attachments 2 and 3 of this Plan provide
details regarding the types and capacities of secondary containment structures in place at
each facility. The FDs depict the locations of secondary containment structures and the
general flow of surface drainage. The Secondary Containment Calculations Spreadsheet
included as Attachment 2 of this Plan provides detailed information regarding the
volume, dimensions, and adequacy of containments for individual containers.
5.1 Secondary Containment Specifications
40 CFR 112.9(c)(2) and (c)(6), COGCC 906.e(1), 604a.(4)
Secondary containment structures provided for containers and vessels holding
condensate, produced water, fuels, lubricating oils and other oil-containing materials are
required to hold, at a minimum, the contents of the largest container present inside the
containment area, plus (if exposed to the weather) enough freeboard to hold precipitation
from a significant storm event. The amount of freeboard for containment structures
located in the Cascade Creek and Collbran Operational Areas was conservatively
calculated based on the 25-year 24-hour storm event, which is 0.21 feet (Western US
Precipitation Frequency Maps http://www.wrcc.dri.edu/pcpnfreq.html).
Most of the facilities containing 3-phase separators contain multiple produced water
tanks that are hard-piped together for equalization purposes and to help prevent freezing
during the winter. Additionally some of the sites operate with 2-phase separators that
also contain above ground equalization lines. While these facilities with equalization
lines are all located within secondary containment, the containment is generally not large
enough to hold the volume of all the tanks that are manifolded together. In these
instances, Oxy’s oil management procedures will consist of removing recoverable oil
from produced water tanks not less than semi-annually. Oxy will draw down the
produced water tanks and remove recoverable oil prior to the onset of winter and then
again in the Spring. Based on operational history, the maximum amount of free-phase oil
expected to accumulate inside the container is 60 bbls (2,520 gallons) between semi-
annual removal operations. Actual accumulations will vary based on the number of wells
on location, tank capacity, and production rates, but in general should not exceed 60 bbls.
Oxy will utilize the SCADA system to monitor water and oil volumes and schedule
additional oil removal operations as necessary. The maximum amount of oil that will be
allowed to accumulate in a produced water tank before removal is 120 barrels, except
when poor road conditions and safety considerations preclude truck passage. In that case,
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oil will be removed when it is practical and safe to do so. The facilities utilizing 3-phase
separators are listed in Appendix D.
In lieu of sized secondary containment for flow-through process vessels such as
separators, free water knockouts, gun barrels, heaters and heater treaters, Oxy has
provided appropriate containment and/or diversionary structures or equipment to prevent
a discharge. Flow-through process units are located on each pad at a such distance from
the perimeter that a release from the equipment would be contained on the pad surface
until clean up could occur. All pad surfaces are designed flat or sloped to the cut side as
to deter runoff of small releases and impacted rainwater. This general containment is
assessed annually during the annual regulatory pad inspection process. The maximum
volume assumed for a likely release scenario is 10 barrels. Each pad surface has been
determined to be capable of containing this volume, in the event of a release, until further
response actions can occur. In the event of a release, additional countermeasures in the
form of spill response and containment actions will include the construction or
deployment of one or more of the following:
Dikes, berms, or retaining walls sufficiently impervious to contain oil;
Curbing;
Culverting, gutters, or other drainage systems;
Weirs, booms, or other barriers;
Spill diversion ponds;
Retention ponds; or
Sorbent materials.
In addition, flow-through process vessels and associated components (such as dump
valves) will be periodically, and on a regular schedule, visually inspected and/or tested
for leaks, corrosion, or other conditions that could lead to a discharge. When indicated by
regularly scheduled visual inspections, tests, or evidence of an oil discharge, corrective
actions will be taken and repairs made to flow- through process vessels and any
associated components. Accumulations of oil discharges associated with flow-through
process vessels will be promptly removed or actions will be initiated to stabilize
and remediate the released materials.
If any facility discharges greater than 1,000 gallons of oil/produced water in a single
discharge to navigable waters of the U.S., or greater than 42 gallons of oil/produced
water in each of two discharges to navigable waters of the U.S. within any twelve month
period from flow-through process vessels, sized secondary containment, capable of
containing the entire capacity of the largest single container and sufficient freeboard to
contain precipitation, must be installed within six months of the release.
Oxy maintains oil removal records using haul tickets and pumper records, customary
with Oxy’s regular business practices including the purchasers ticket.
In accordance with 40CFR112.9(c)(6)(v) Oxy will take corrective action within six
months from the time that a facility becomes subject to this section.
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All newly constructed facilities, or when existing secondary containments are modified,
will be provided with sized secondary containment sufficient to contain the multiple
volumes of any tanks that are equalized (the largest tank) plus freeboard for precipitation.
Because the majority of containment structures utilized have been constructed in
accordance with existing requirements, any tank or piping failures occurring inside of
containment are expected to be confined and not discharged to the environment. Double-
walled tanks, drip pans, sorbent material and other measures may also be utilized to
comply with containment requirements. The containment systems utilized are designed
to be capable of containing oil and have been constructed so that material inadvertently
released from a container will not escape the containment system before cleanup occurs.
5.2 Flowlines and Intra-facility Gathering Lines
40 CFR 112.9(d)(3)
Active natural gas extraction wells are typically set inside of conductor holes and/or
vaults to provide containment for wellhead. The wells operate continuously and produce
a stream containing gaseous and liquid phases that flow through gathering and flowlines.
The gaseous phase and liquid phase, containing water and oil, is transported a short
distance to a three-phase heated separator located at the extraction pad. The gaseous
phase is separated by the separation unit and is conveyed via underground piping to a
central compression station for distribution and sales. The liquid phase (condensate and
produced water is piped to storage containers located at the pad. An Oil Spill
Contingency Plan (OSCP) has been developed for intra-facility gathering and flowlines
under the scope of this Plan. The OSCP is provided as Appendix F.
Tank-related piping or process equipment is operated in a manner to minimize the
potential for leaks or spills and may be located inside secondary containment. Standard
discharge prevention practices include the utilization of drip pans for equipment, such as
pumps, and loading hose connections that have the potential for drips and leaks during
operation. Valve covers are also installed as a best management practice to help
minimize the amount of area likely to be impacted by a sudden release. For example, a
cover over a valve could help control a spray of oil from a failed gasket that may have
otherwise resulted in the oil spray being deposited over a much wider area. Oxy is
committed to expeditiously controlling and removing any amount of oil released from
facility pipelines or any other source.
5.3 Containment Requirements for High Density Areas
COGCC 603.e
Oxy does not currently operate facilities within high density areas or designated outside
activity areas as defined by COGCC Rule 603.b and the definition of designated outside
activity areas. If future facility locations are constructed within high density areas or
designated outside activity areas, Oxy will comply with all applicable COGCC
requirements, including those established for the construction of secondary containment
berms.
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6.0 Container and Equipment Installation and Construction
40 CFR 112.9 (c)(1), 40 CFR 112.9 (d)(4)(i)
Protocols implemented by the Oxy Facilities Department help ensure that when bulk
storage containers are installed or repaired, the materials used for construction/repair of
the containers are compatible with the type of stored oil. Maintenance protocols have
also been developed for the installation and repair of pipelines, flowlines, intra-facility
gathering lines, and their associated valves and equipment. Such protocols ensure that
the materials used for line construction are compatible with the types of fluids
transferred, their potential corrosivity, volume, pressure, and other conditions expected in
the operational environment. For example, gas gathering lines are installed in accordance
with ANSI 600 rating requirements to help ensure integrity under varying conditions of
field operating pressure. Additional maintenance procedures ensure that containers and
piping are constructed such that they will remain structurally sound under varying storage
and transfer conditions (i.e., extreme hot and cold temperatures).
6.1 Fire Prevention Measures
COGCC 604.a, COGCC 604a.(4)
When constructing new atmospheric tanks to be utilized for crude oil storage or when
redesigning existing crude oil storage areas, the following fire prevention measures are
observed, as applicable:
Tanks shall be a minimum of seventy-five (75) feet from a fired vessel or heater-
treater.
Tanks shall be a minimum of fifty (50) feet from a separator, well test unit, or
other non-fired equipment.
Tanks shall be a minimum of seventy-five (75) feet from a compressor with a
rating of 200 horsepower, or more.
Tanks shall be a minimum of seventy-five (75) feet from a wellhead.
Gauge hatches on atmospheric tanks used for crude oil storage shall remain closed
at all times when not in use.
Vent lines from individual tanks shall be joined and ultimate discharge shall be
directed away from loading racks and fired vessels.
No potential ignition sources shall be installed inside the secondary containment
area unless the containment area encloses a fired vessel.
7.0 Inspections, Testing and Maintenance
40 CFR 112.7(e), 112.9(c)(3), (c)(5), (c)(6), (d)(1), (d)(4)
The following sections discuss the inspection, testing and maintenance activities required
by the federal Oil Pollution Act (40 CFR 112), the COGCC, and Oxy policy. In
accordance with the Mid-Continent Business Unit Mechanical Integrity (MI) Program,
production equipment will be visually inspected and maintained in accordance with the
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procedures outlined in Appendix B. The intent of the MI Program is to ensure that
process equipment is designed, constructed, installed, and maintained utilizing
recognized and generally accepted good engineering practices, to ensure that it remains
fit for service over its lifecycle, and to minimize risk of uncontrolled releases. The MI
Program includes the following types of process equipment:
Fired Pressure Vessels
Unfired Pressure Vessels
Bulk Storage Containers
Piping Systems conveying produced water and condensate
Flare Systems, including piping, vessels, vaporizers, knockout pots, ignition
systems, and other process equipment used to collect the discharge of relief vents
in emergency events to safely combust flammable gases or liquids with minimal
risk to the environment and processes
Relief Devices, including pressure relief valves, rupture discs, and emergency
vents
Steel Structures (primary structural steelwork, e.g., stairwells, vessel, and column
primary supports)
All inspections are performed by qualified inspectors who are knowledgeable of facility
operations, the equipment type and its associated components, and the characteristics of
the material being stored, transferred, or processed. The inspections and tests performed
in accordance with the requirements of this Plan are documented and managed in
accordance with Section 7.9 of this Plan. In the event that an inspection or test identifies
either the need for repair, evidence of a discharge or is found to be otherwise unsuitable
for service, corrective action shall be implemented accordingly. As soon as practicable
following the detection of a leak, the affected portion of the line will be isolated and
repaired or replaced. In addition, any oil discharges associated with storage containers or
associated equipment shall be promptly removed.
It is also Oxy policy that all inspection, testing and maintenance activities be performed
in accordance with applicable requirements of the Occupational Safety and Health
Administration (OSHA) and company health and safety programs (e.g., control of
hazardous energy-LOTO, confined space entry, respiratory protection, hot work, etc.) and
any equipment-specific operating procedures.
7.1 Bulk Storage Container Inspection, Testing and Maintenance
40 CFR 112.9 (c)(3) and (c)(6), COGCC 604.a(9)
All aboveground bulk storage containers are maintained in accordance with the Oxy MI
Program. Bulk storage containers, containment systems, tank foundations, supports, and
associated equipment are inspected and tested in accordance with an established
schedule. The inspection and testing schedule for bulk storage containers located in the
Cascade Creek and Collbran Operational Areas is maintained at the Grand Junction field
office. The type and frequency of inspection and/or testing for individual containers is
determined by the container type and size, type of installation, corrosion rate and
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previous inspection history. During the visual inspections, the aboveground storage
containers, containment systems, surrounding surface areas, piping, valves, and all other
applicable equipment are inspected for signs of deterioration and leaks. Tanks are also
inspected to ensure that gauge hatches are being maintained in a closed position when not
in use as required. Results of the inspections are recorded on the appropriate inspection
checklist, provided in Appendix B.
Oxy performs a minimum of three types of inspections for all SPCC-regulated facilities;
Annual Inspections, COGCC Inspections and Periodic Observations. Annual Inspections
are conducted according to the procedures outlined in Appendix B.2, Oxy Piceance Pad
Inspection Procedure. During the Annual Inspections, a thorough visual inspection is
conducted, containment dimensions and condition are checked, and the facility-specific
information provided on the FOS and FD is updated with any changes. Results of the
Annual Inspections are recorded on the Oxy Piceance Pad Inspection Checklist, provided
in Appendix B.1. Oxy also performs an inspection of its COGCC facilities on an annual
basis as required by COGCC regulations. The results of COGCC Inspections are
recorded on COGCC Form 36 reports (Appendix B.5). COGCC Inspections include an
assessment of secondary containment structures and other BMPs, including pit liners.
In addition to the annual inspections described above, Oxy also performs observations at
SPCC-regulated facilities on a periodic basis, with the frequency of observations not to
exceed 30-days. These visual inspections are conducted by qualified field personnel who
are familiar with the operation of facility equipment and in accordance with the Oxy
Periodic Monitoring Procedure (Appendix B.4).
The requirement for bulk storage container testing is largely dependent upon the
adequacy of the container’s secondary containment. If a secondary containment
structure is determined to have inadequate capacity, the containment shall either be
repaired or a program of integrity testing of the containers within the containment shall
be implemented. Testing intervals for bulk storage containers and associated valves and
piping will be established by the MI Lead using one of three methods shown below:
A. Time-Based Criteria (usually required by jurisdictional rules)
B. Time/Condition-Based Criteria (as detailed in API 653)
C. Risk-Based Criteria (as allowed by API 653)
Note: Fiberglass tanks are inspected in intervals utilizing FTPI 2007-1 for guidance.
Testing intervals established for affected bulk storage containers shall not exceed five
years. The inspection and testing schedules for individual containers will be maintained
at the Oxy Grand Junction field office.
7.1.1 Produced Water Container Maintenance
40 CFR 112.9 (c)(6)
Produced water containers are constructed with materials compatible with their contents,
have been provided with secondary containment, are visually inspected on a periodic
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basis, and have been provided with appropriate discharge prevention measures as
required by 40 CFR 112.9. The remaining sections of this Plan discuss these
requirements and specific methods of conformance in greater detail.
Where produced water containers do not meet the sized secondary containment
requirements of 40 CFR 112.9 (c)(6), Oxy has elected to implement the procedure
described above in Section 5.1.
7.1.2 Field-constructed Aboveground Container Maintenance
40 CFR 112.7(a)(2), 40 CFR 112.7(i)
Inspection, testing and maintenance procedures specific to field-constructed aboveground
containers are provided in Appendix B. Field-constructed aboveground containers are
inspected for integrity on a regular schedule and whenever material repairs are made. If a
field-constructed ASC undergoes a repair, alteration, reconstruction, or change in service,
it will be evaluated for the risk of discharge or failure due to brittle fracture or other
catastrophe. Such an evaluation will also be conducted if an ASC has discharged oil or
failed due to brittle fracture or other catastrophe. Corrective action will be taken as
determined necessary by the evaluation. Qualified contractors and personnel are
employed to perform all ASC repair, alteration, and/or reconstruction activities in
accordance with accepted industry practices and regulations.
7.2 Portable and Temporary Container Inspection, Testing and
Maintenance
40 CFR 112.7(e)
Portable and temporary containers with an oil-containing capacity of 55 gallons or greater
are periodically inspected and maintained. When in active use, portable and temporary
containers are observed for condition daily by facility operations personnel. Utilizing the
same inspection process as described for bulk storage containers, visual inspections of
portable and temporary containers are performed on a periodic basis in accordance with
the procedures outlined in Appendix B. Testing requirements for portable and temporary
containers are determined by the Oxy Facilities Department. The inspection and testing
schedule for portable and temporary containers operated in the Cascade Creek and
Collbran Operational Areas is maintained at the Grand Junction field office.
7.3 Flow-through Process Vessel Inspection, Testing and Maintenance
40 CFR 112.9(c)(5)
Flow-through process vessels are factory-inspected prior to being placed into service and
are provided with secondary containment when feasible. All vessels are visually
inspected for deterioration and maintenance needs on a periodic basis as outlined in the
Oxy Facility Periodic Monitoring Procedure in Appendix B.4. These vessels are also
inspected annually according to the Oxy Piceance Facility Inspection Procedure in
Appendix B.2.
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Oxy uses MAXIMO, an equipment management database system, to schedule and
manage periodic testing of a representative sample of units for corrosion monitoring and
testing. These inspections monitor corrosion rates and are used to develop field wide
replacement and repair maintenance programs. All flow-through process vessels are
maintained in accordance with the Oxy MI Program.
If an individual facility discharges more than 1,000 U.S. gallons (23.8 barrels) of oil in a
single spill event, or discharges more than 42 U.S. gallons (1 barrel) of oil in each of two
spill events within any twelve month period, from flow-through process vessels within
six months from the date of the discharge, sized secondary containment will be provided
for all flow-through process vessels at the facility. 40 CFR Part 112.1(b) and Part 110
describe the types of spills that would be reportable under this requirement. Oxy will
also comply with other applicable federal and state regulations.
7.4 Oil-filled Operational Equipment Inspection, Testing and
Maintenance
40 CFR 112.7(k)
Facility processes may utilize oil-filled operational equipment. Such equipment may
include transformers, lubricating systems for compressors, pump jacks, etc. This type of
equipment is typically provided with general secondary containment. At facilities where
secondary containment is not provided for all oil-filled operational equipment, a
procedure has been implemented for inspecting the equipment on a regular basis to detect
equipment failure and/or an oil discharge. An outline of the general procedure is as
follows.
Prior to use, Oxy personnel or designated contractor will inspect all oil-filled operational
equipment, associated facilities, and devices for corrosion and leaks. Also, on a periodic
basis, qualified facility operations or contract personnel will visually inspect all oil-filled
operational equipment, connecting lines, and associated structures and devices for:
leaks or other oil discharges;
signs of corrosion;
loose bolts or missing plugs;
accumulation in drip pans; and
general physical condition of the equipment.
Deficiencies are documented and corrective actions will be taken to repair or replace the
damaged equipment as outlined in the Oxy Facility Periodic Monitoring Procedures
(Appendix B.4). Testing of oil-filled operational equipment is performed as needed
based on operational knowledge and visual inspection.
7.5 Transfer Piping Inspection, Testing and Maintenance
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Transfer piping is visually inspected during installation activities in accordance with the
Oxy MI Program. All pipeline inspections are performed by qualified inspectors who are
knowledgeable of the transfer operation, the type of piping and its associated
components, and characteristics of the material being transferred. The inspections,
testing and maintenance protocols established for transfer piping are detailed in the
following sections.
7.5.1 Pipeline Inspection and Monitoring
40 CFR 112.9 (d), (d)(4)(ii)-(iv)
To reduce the potential for discharges from pipelines, Oxy operates a program of pipeline
inspection and monitoring. Examples of the pipelines operated within the Cascade Creek
and Collbran Operation Areas include gathering lines from wellheads and central
delivery points to compressor stations, condensate and produced water delivery lines
to/from separators, tanks and the Central Water Handling Facility. The terms flowline
and intra-facility gathering line are used often. For the purposes of this Plan, a flowline
refers to a pipeline that connects pads to mainlines and other facilities, such as the Central
Water Handling Facility in Cascade Creek. Intra-facility gathering lines refer to those
lines located on a particular well pad or facility used to transport material within the
facility. For example, intra-facility gathering lines may be utilized to collect gas and
liquids from a well head and distribute to a separator located on the well pad. Above
ground flow and gathering lines are inspected frequently by qualified production
technicians or contract personnel performing routine operations at the facility.
During the periodic inspections conducted for aboveground bulk storage containers,
process vessels, portable and temporary tanks, and oil-filled equipment, as described in
the sections above, the associated transfer piping is also inspected. Specifically, piping,
valves, flange joints, valve glands and bodies, drip pans, pipe supports, pumping well
polish rod stuffing boxes, bleeder and gauge valves, and other such items are inspected
for signs of deterioration and leaks and recorded on the appropriate periodic inspection
checklist.
In accordance with the protocols established by the Oxy Facilities Department, newly
installed piping undergoes a thorough quality assurance process that involves x-rays of
welds and hydro-testing prior to being placed into service. Pipelines are monitored by
facility personnel during periods of operation for general condition, signs of leaks or
other potential problems. Pipelines, valves and associated equipment are inspected
regularly during the equipment inspections described in earlier sections of this Plan. In
addition, wells are provided with constant surveillance via an automated system designed
to trigger an alarm in the event of a catastrophic release.
7.5.2 Pipeline Testing and Maintenance
40 CFR 112.9 (d)(4)(i)
Existing pipelines and newly installed pipelines are tested and maintained in accordance
with established Oxy protocols including the Oxy MI Program. The management
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practices implemented include the utilization of established standards for the selection
and installation of pipelines within the Cascade Creek and Collbran Operational Areas.
Management practices also include procedures for the routine monitoring, testing and
maintenance of pipelines as well as their valves, flanges, and associated devices. To aid
in ensuring employee safety and environmental protection, all maintenance and testing
activities are performed by personnel who are knowledgeable in facility operations and
the specific operation of the equipment being maintained.
General procedures for the maintenance and testing of pipelines with the Cascade Creek
and Collbran Operational Areas include the following:
Prior to installing, replacing, or repairing pipelines, valves, or associated devices,
facilities maintenance personnel must ensure that the materials to be transferred
are compatible with the construction materials to be employed. Potential
concerns involving corrosive production fluids, transfer volumes, line pressure,
and other such conditions expected in the operational environment are addressed
prior to installation.
All pipelines are to be identified on facility diagrams and are clearly marked in
the field to facilitate access and inspection by Oxy and/or contract personnel.
Pipelines associated with wells with known or suspected corrosion mechanisms
are protected through the utilization of continuous or batch treatment with
corrosion inhibitor.
Cathodic protection is provided on key trunk pipelines.
Corrosion drip points are present on critical mainlines.
Where practicable, electric water pumps are enabled with automatic devices that
shut down the pump when pressures reach a level that indicate a problem.
When repairing or reconstructing flowlines, intra-facility gathering lines, and/or
associated valves and equipment, the materials used for construction are
compatible with the types of production fluids transferred, their potential
corrosivity, volume, and pressure, and other conditions expected in the
operational environment. The transfer piping and other equipment are
constructed such that the lines will contain the materials under varying storage
conditions (i.e., extreme hot and cold temperatures).
The general maintenance and testing procedures referenced above are performed on
individual sections of lines and associated equipment at a frequency determined by Oxy’s
Facilities Department. The frequency for maintaining and testing lines located within
secondary containment is based on several factors, including the age of the pipeline,
known or suspected corrosion issues, materials used in construction, number of elbows,
expansions, contractions, etc. The maintenance and testing performed for pipelines that
have not been afforded secondary containment is scheduled on a more frequent basis to
aid in ensuring that the OSCP developed for Cascade Creek and Collbran Operational
Area facilities can be effectively implemented.
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7.6 Pit and Pond Inspection and Maintenance
COGCC 902.b and 902.c
Pits and ponds utilized in the Cascade Creek and Collbran Operational Areas are
constructed, monitored, and operated to provide for a minimum of two (2) feet of
freeboard at all times between the top of the pit wall at its point of lowest elevation and
the fluid level of the pit. The methods employed to monitor and maintain freeboard in pits
and ponds include the routine visual checks, electronic and traditional level indicators.
Corrective action (i.e., pumping of pit or pond) is undertaken as necessary to ensure the
required level of freeboard is maintained. In accordance with COGCC Rule 906, any
unauthorized release of fluids from a pit will be reported to the appropriate authorities.
Pits and ponds are lined using high-density polyethylene and range from 24 to 60
millimeters thick. During the operation of pits and ponds, if the monitoring equipment or
visual check identifies a drop in fluid level, Oxy will drain the fluid to adequately inspect
the liner integrity. If holes or tears are identified in the pit liner Oxy will repair the holes
following manufacturer specifications. Following the repair of the liner, Oxy will
conduct a seam test and hydro-test to ensure adequate integrity of the liner prior to
refilling the pit or pond.
Any accumulations of oil or condensate in a pit are removed within twenty-four (24)
hours of discovery as required. Operators use skimming, steam cleaning of exposed
liners, or other safe and legal methods as necessary to maintain pits in clean condition
and to control hydrocarbon odors. De minimis amounts of hydrocarbons are allowed to
be present in a pit only if the pit has been specifically permitted for oil or condensate
recovery or disposal use.
7.7 Saltwater Disposal Facilities Inspections
40 CFR 112.9(d)(2)
Saltwater disposal facilities (SWDs) typically consist of a tank battery, offloading area,
filtration pods, and a pump building. At the SWD, produced water is sent to an injection
tank battery where it is processed through an additional filter pod assembly and then sent
to a tank battery for settling and storage before being processed further.
Visual SPCC inspections are conducted at SWD facilities on a periodic basis. Annual
inspections and periodic observations are conducted at SWD facilities in accordance with
the procedures outlined in Appendix B. When in active use, SWD facilities are visually
inspected daily. Because a sudden change in atmospheric temperature may lead to upset
conditions within SWDs, Oxy personnel also conduct a visual inspection of SWDs during
routine operational activities. As an additional discharge prevention measure, Oxy has
installed high level alarms on tanks at SWD facilities located in the Cascade Creek and
Collbran Operational Areas.
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7.8 Field Drainage System Inspections
40 CFR 112.9(b)(2)
Inspections of facility drainage systems and road ditches are conducted by an Oxy
Stormwater Inspector on a periodic basis utilizing the CDPHE Stormwater Inspection
Form. Stormwater inspections are conducted semi-annually as part of Oxy’s COGCC
stormwater inspection program and annually as part of Oxy’s COGCC Form 36
inspections, but may be performed more frequently to aid in compliance with permit-
specific requirements. Any observed accumulations of oil are investigated and addressed
as needed.
7.9 Recordkeeping
40 CFR 112.7(e)
All inspections and tests conducted to comply with SPCC requirements must be
performed in accordance with written procedures that have been developed specifically
for facilities within the Oxy Cascade Creek and Collbran Operational Areas. The
procedures are outlined in appropriate sections of the Plan and the checklists and
procedures listed in Appendix B. Inspection and testing records must be signed by the
appropriate supervisor or inspector and must be maintained in the Grand Junction office
with the master copy of this Plan for a minimum period of three years. ASC records and
certified inspection reports are maintained for the life of the ASC.
8.0 Discharge Prevention
Discharge prevention measures, including procedures for routine handling of products
(loading, unloading, facility transfers, etc.), are described in the following sections and in
the loading/unloading procedure provided in Appendix E. In summary, condensate and
produced water tanks may be loaded/unloaded manually using tank trucks or are
loaded/unloaded via Oxy’s water pipeline gathering system. Oil transfers are conducted
during normal business hours and truck drivers are present during loading/unloading
activities to watch for and correct leaks or other issues. If any leaks are detected, the
driver will manually close the appropriate valves to control flow and address any spilled
material. Tank trucks in service in the Oxy Cascade Creek and Collbran Operational
Areas are equipped with a spill response kit. Because of the physical controls and
procedures implemented, any spills resulting from loading/unloading operations are
expected to be limited in volume and readily cleaned. All releases of oil to the
environment are expected to be reported and are subsequently inspected to evaluate the
root cause and potential preventative actions.
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8.1 Facility Oil Transfer Procedures
40 CFR 112.7(a)(3)(ii)
Individual facilities have implemented operation and equipment-specific procedures for
the routine transfer of oil products (fuel, lubricating oils, etc.) and oil-containing
materials (produced water, condensate, etc.) between containers. Appendix E details
specific procedures that Oxy personnel and contractors follow when transferring oil and
oil containing materials between containers. General procedures for the transfer of oil at
any location within the Cascade Creek and Collbran Operational Areas are as follows:
1. Before initiating the transfer of oil from one container to another, check level
readings to ensure there is adequate free space available in the receiving container
2. Operators must stay in the area (outside of the vehicle) during transfers and
monitor equipment and operations closely (checking lines, pumps, hoses, etc. for
proper operation and signs of leakage)
3. Operators must inspect transfer equipment and produced water delivery lines prior
to, during, and following use, for leaks, oil discharges, corrosion, and other conditions
that could lead to a discharge
4. Operators must provide absorbent pads, pans, buckets, etc., as needed to prevent
drips from contacting the ground
8.2 Spill Prevention Accountability
40 CFR 112.7(f)(2)
The Operations Manager stationed in the Grand Junction field office, is the individual
who has been designated by Oxy as accountable for oil spill prevention at the facilities
managed under the scope of this Plan. The Oxy Operations Manager may be contacted
by telephone at (970) 263-3600.
8.3 Tank Battery Design
40 CFR 112.9(c)(4)
Standard engineering practices are utilized at both new and existing tank batteries to
prevent discharges. Oil storage tanks in the Cascade Creek and Collbran Operational
Area, are provided with one or more of the following discharge prevention measures.
One or more top overflow equalization lines.
High level sensors that, once the storage tank becomes full, generate and transmit
an alarm signal to the electronically controlled automation equipment, which then
shuts down the active processes of the well.
A container capacity adequate to assure that the container will not overfill if an
operator or pumper is delayed in making their scheduled rounds.
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The facility-specific information provided in Attachment 3 identifies the discharge
prevention measures implemented at individual locations.
Prior to the filling or departure of an oil transport vehicle, the lowermost drain and all
outlets are closely inspected for discharges. If necessary, caps are tightened, adjusted, or
replaced to prevent a discharge of oil while in transit. During loading/unloading
operations at each facility, drip pans are placed under connections at the back of the tank
trucks where the potential for spills outside secondary containment exists. Truck drivers
are required to perform constant monitoring of loading/unloading operations. Each tank
truck is required to carry a spill kit in the event that a spill is encountered and any oil that
is released to the ground is cleaned up immediately.
8.4 Facility Loading/Unloading Operations
40 CFR 112.7(h)(1), (h)(2), (h)(3)
The facilities managed under the scope of this Plan do not currently utilize
loading/unloading rack systems. Tank truck loading and unloading activities occur at
transfer facilities and at loading/unloading areas throughout the Cascade Creek and
Collbran Operational Areas. Environmental protection is provided in these areas through
the use of both passive (i.e., containment structures) and active (i.e., spill kits) secondary
containment practices. Facility Drainage
40 CFR 112.9(b)(1)
As a standard practice, the secondary containment structures constructed at the facilities
managed under the scope of this Plan are not equipped with drains. Pre-fabricated
containment structures (e.g., troughs, stock tanks) may have small drain holes present;
however, these drains are not used to empty the containment structure and are maintained
closed. As a standard practice, drainage of materials that accumulate in secondary
containment to the ground outside of containment is not performed. Secondary
containment structures are drained manually using a hand bailer, portable pump or via
tank truck. Accumulated rainwater or material resulting from a release within secondary
containment structures is transported to the Oxy Central Water Handling Facility for
storage, treatment and disposal, in accordance with applicable rules and regulations.
Procedures for transferring oil from a storage tank into a tank truck are included in
Appendix E of this Plan.
8.5 Oil Drilling and Workover Facilities
40 CFR 112.10(a)-(d)
The following discharge prevention measures are implemented at oil drilling and
workover facilities operated within the Cascade Creek and Collbran Operational Areas.
The site is evaluated to determine the most suitable location for mobile drilling or
workover equipment to aid in preventing a discharge to the environment and is
positioned accordingly.
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Diversion structures such as absorbent booms and socks are provided at drilling
and workover operations to help intercept and contain a discharge of oil.
A blowout preventer (BOP) assembly and well control system is installed before
drilling below any casing string and during workover operations. The BOP
assembly and well control system installed are capable of controlling any well-
head pressure that may be encountered while that BOP assembly and well control
system are on the well.
Oxy personnel responsible for oversight of drilling and workover operations are trained
in the requirements of this Plan and ensure that the requirements noted above have been
complied with prior to beginning operations. Drilling and workover facilities typically
operate in accordance with the controls specified in facility-specific SPCC Plan provided
by the drilling and completions operators.
9.0 Oil Spill Control and Countermeasures
40 CFR 112.7(a)(3)(iv), 40 CFR 112.7(a)(3)(v)
Specific procedures for discharge discovery, response, and cleanup are provided in the
OSCP that has been developed for the facilities managed under the scope of this Plan. The
OSCP is maintained in Appendix F of this Plan and provides information and procedures
for reporting a discharge, for taking initial actions to mitigate the effects of the discharge,
for determining whether or not an evacuation is needed, and for ensuring that recovered
materials are disposed of in accordance with applicable legal requirements.
The OSCP follows the provisions of Oxy’s Emergency Response Plan (ERP). The ERP
provides guidance for action in a number of emergency scenarios, including a
chemical/oil release or spill emergency. The OSCP and ERP are updated annually. Oxy
oil-handling personnel are trained on the content of the ERP on a yearly basis. A copy of
the current Oxy ERP has been provided for reference in Appendix G.
9.1 Contact & Reporting Information For Discharges
40 CFR 112.7(a)(3)(vi)
Discharges of oil to the environment that occur in the Cascade Creek and Collbran
Operational Areas must be reported. Individuals who discover an oil spill have been
instructed to immediately report the incident to their Supervisor. The Supervisor then
follows the reporting procedure outlined in the ERP and the OSCP. Appendix A
provides a quick reference of emergency contact numbers and emergency response
procedures. Internal reporting is required for any discharge of oil to the environment,
while the need to report discharges to local, state and federal agencies will depend on the
magnitude and location of the release. Appendix A of this Plan provides a contact list
and phone numbers for Oxy personnel, cleanup contractors, the National Response
Center and other regulatory agencies. Also provided in Appendix A is a quick reference
procedure for reporting oil discharges. The OSCP located in Appendix F includes
detailed information regarding the circumstances requiring reporting, an explanation of
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which agencies need to be notified under the different circumstances, the types of
reporting required (phone, mail, etc.), time frames for reporting, etc.
Guidance For Identifying Discharges That Need To Be Reported
For the purposes of this Plan, a reportable discharge is defined by 40 CFR 110.3
as “Discharge of oil in such quantities as ‘may be harmful’.
a. Discharges of oil in such quantities that the Administrator has
determined may be harmful to the public health or welfare or the
environment of the United States include discharges of oil that:
(i) Violate applicable water quality standards; or
(ii) Cause a film or sheen upon or discoloration of the surface of the
water or adjoining shorelines or cause a sludge or emulsion to be
deposited beneath the surface of the water or upon adjoining
shorelines.
b. In addition, 40 CFR 112.2 - Definitions provides useful definitions for
common terms. Discharge includes, but is not limited to, any spilling,
leaking, pumping, pouring, emitting, emptying, or dumping of oil, but
excludes discharges in compliance with a permit…
c. Navigable waters of the United States means “navigable waters” as
defined in section 502(7) of the Federal Water Pollution Control Act,
and includes:
(i) All navigable waters of the United States and tributaries of such
waters;
(ii) Interstate waters;
(iii) Intrastate lakes, rivers, and streams which are utilized by interstate
travelers for recreational or other purposes;
(iv) Intrastate lakes, rivers, and streams from which fish or shellfish are
(v) taken and sold in interstate commerce.
9.2 Discharge Reporting Requirements
40 CFR 112.7(a)(4), C.R.S. 25-8-601(2), 40 CFR 112.4 (a)-(c)
Under the Oxy reporting procedure, personnel from the Oxy HES and Regulatory
Department or Operations Manager is responsible for contacting the appropriate agencies
and reporting the release. In the event that a harmful quantity of oil is released or is
suspected of having been released to the navigable waters of the U.S.; 40 CFR Part
112.1(b) and Part 110 describe the types of spills that would be reportable under this
requirement (see section 9.1.a).
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For clarification purposes, the following definitions are provided:
Oil - Per 40 CFR 112, the term “oil” refers to oil of any kind or in any form, including,
but not limited to: oils, greases, condensate, fuel oil, synthetic oils, or the resulting
mixture of oil with other non-oil liquid (i.e., produced water).
Discharge - A “discharge” as described in 40 CFR Part 112.1(b) and Part 110, refers to a
discharge of oil in quantities that “may be harmful” into or upon navigable waters. The
term discharge, in general, includes any spilling, leaking, pumping, pouring, emitting,
emptying, or dumping of oil. Navigable waters include tributaries, streams, rivers and
lakes. Per 40 CFR Part 110.3, a discharge of oil in such quantities as “may be harmful”
include discharges of oil that (a) violate applicable water quality standards; or (b) cause a
film or sheen upon or discoloration of the surface of the water or adjoining shorelines or
cause a sludge or emulsion to be deposited beneath the surface of the water or upon
adjoining shorelines.
Such an event must be immediately reported to the following regulatory agencies:
1) National Response Center
Washington, D.C.
800-424-8802 (24 hour phone)
2) Colorado Department of Public Health and Environment
Water Quality Control Division
4300 Cherry Creek Dr. South
Denver, CO
1-877-518-5608 (24 hour hotline)
3) US Environmental Protection Agency
Region VIII Response Center
1595 Wynkoop Street
Denver, Colorado 80202-1129
303-293-1788 (24 hour phone)
4) Colorado State Inspector of Oils
1515 Arapahoe Street
Denver CO 80202-2117
303-620-4029
When contacting these agencies, the following information is provided:
responsible company/person, including exact address and telephone number;
name of person reporting the release;
date and time of release;
designation and location of the facility (coordinates are provided on the FOS);
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telephone number for the facility (provide the contact number on the FOS (970-263-
3600) and contact information for the individual reporting the call);
type of material discharged;
estimate of the quantity released;
waterway affected, including amount reaching water;
source of the discharge;
a description of all affected media;
cause of release;
damages or injuries caused by the discharge;
action taken to stop, remove, and mitigate the effects of the release;
whether an evacuation is needed; and
names and/or organizations who have also been or will be contacted.
Additional agency notifications may include the Colorado State Inspector of Oils, COGCC,
U.S. Army Corps of Engineers, and other agencies are listed in Appendix A. Oil spill
reporting requirements and procedures are detailed in the OSCP. A copy of the OSCP is
provided in Appendix F.
Following a discharge totaling more than 1,000 gallons of oil in a single discharge event,
or more than 42 gallons of oil in each of two (2) discharges occurring within a 12-month
period, the facility must submit the following information to the U.S. EPA Regional
Administrator and the CDPHE within 60 days of the event(s).
name of facility;
name of person reporting the release;
designation and location of the facility (coordinates are provided on the FOS);
maximum storage or handling capacity of the facility and normal daily throughput
corrective action and countermeasures you have taken, including a description of
equipment repairs and replacements
an adequate description of the facility, including maps, flow diagrams, and
topographical maps, as necessary
the cause of such discharge, including a failure analysis of the system or
subsystem in which the failure occurred
additional preventive measures you have taken or contemplated to minimize the
possibility of recurrence
other information as the Regional Administrator may reasonable require pertinent
to the Plan or discharge.
Spill events that may require the Regional Administrator notification described above
will exhibit one or more of the following characteristics:
a. Violate applicable water quality standards; or
b. Cause a film or sheen upon or dis-coloration of the surface of the water or
adjoining shorelines or cause a sludge or emulsion to be deposited beneath the
surface of the water or upon adjoining shorelines; or
c. May affect natural resources belonging to, appertaining to, or under the exclusive
management authority of the United States.
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The SPCC Plan must also be amended, as required, following such a discharge(s). The
SPCC Plan may also be amended if required by the Regional Administrator. If
necessary, an appeal may be made regarding the Regional Administrator’s decision to
require an amendment to the Plan.
10.0 SPCC Training Program
10.1 Oil-handling Personnel Training
40 CFR 112.7(f)(1)
Oxy provides the following training to oil-handling personnel prior to assuming new job
responsibilities and annually thereafter:
Operation and maintenance of equipment to prevent oil discharges:
1. Practices to minimize oil discharge, including best management practices to
minimize potential for discharge during truck loading;
2. Applicable oil spill prevention (state and federal) laws, rules, and regulations;
3. General facility operations;
4. Discharge procedure protocols; and
5. The contents of this SPCC Plan.
In addition to the oil-handling personnel training described above, the Oxy SPCC
Training Program includes the components outlined below:
Qualified and experienced personnel conduct the on-the-job training of new
and/or inexperienced employees prior to independent assignment.
Formal training on the operation and maintenance of oil field equipment is
provided through company-sponsored training on an "as needed" basis.
Pollution prevention and applicable regulatory requirements are brought to the
attention of employees on a continuing basis in safety meetings, personal
consultations, posters, literature distribution, etc.
To help ensure that facility inspections are performed in accordance with
established procedures, any contract or Oxy personnel performing inspections
must first receive training in the applicable procedure provided in Appendix B.
Oxy Piceance Pad Inspection Checklist Training
The Oxy Regulatory Department schedules and conducts training for personnel
conducting the annual Oxy Rockies Pad Inspections. The training provides all the
necessary information for inspection personnel to conduct a thorough inspection,
identify existing and potential issues, recommend corrective or preventive actions,
and accurately record and report the inspection.
OXY Periodic Monitoring Training
The Oxy Regulatory Department schedules and conducts training for field
personnel responsible for implementing the Oxy Periodic Monitoring Program.
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The training provides all the necessary information for field personnel to monitor
the status and condition of oil storage and processing equipment, identify existing
and potential issues, take proper preventive or corrective action, and effectively
implement the Oxy Corrective Action Tracking Program.
10.2 Spill Prevention Briefings
40 CFR 112.7(f)(3)
Oxy schedules and conducts prevention briefings for oil-handling personnel who perform
work in the Cascade Creek and Collbran Operational Areas at least monthly to assure
adequate understanding of this SPCC Plan. These briefings include discussion of known
discharges, potential discharges, component malfunctions or failures, and recently
developed precautionary measures.
10.3 Training Documentation and Records
Curriculums for the SPCC training and briefing sessions described in the sections above
and associated attendance records for oil-handling employees are maintained for a
minimum period of three (3) years in the Grand Junction Oxy office.
11.0 Conformance with State and Federal Oil Pollution
Prevention Regulations
40 CFR 112.7(d)
The contents of this SPCC Plan conform to state and federal oil pollution prevention
regulations applicable to natural gas production facilities. As of the revision date of this
Plan, required oil pollution controls are in place or equivalent environmental protection
and corrective action plans are in place in the Cascade Creek and Collbran Operational
Areas.
Because of the large area traversed by pipelines throughout the Cascade Creek and
Collbran Operational Areas, and the fact that much of the piping is underground, Oxy has
determined that the installation of secondary containment for all piping is not practicable.
Where active and passive containment had not been provided for pipelines, a robust
pipeline inspection and maintenance program has been implemented by Oxy to prevent
oil discharges (e.g., physical barriers, corrosion inhibitors, etc.), to allow for the prompt
detection of problems that may lead to a release (e.g., pigging, testing corrosion coupons,
etc.), and to identify leaks (e.g., inspections, remote monitoring, etc.) in a timely manner.
An OSCP has been also developed for the facilities managed under the scope of this Plan.
The OSCP details procedures for the expeditious control and cleanup of spills. These
measures provide a level of environmental protection for piping equivalent to secondary
containment.
In the event than an existing oil container is identified without the required discharge
prevention measures (i.e. insufficient secondary containment), corrective actions such as
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the addition of secondary containment, the repair of damaged containment structures,
and/or the expansion of secondary containment structure dimensions will be implemented
to provide the necessary capacity. In the interim, environmental protection, including the
utilization of active secondary containment measures (e.g., spill kits staged in operational
areas), may be provided. Additional protection measures include the implementation of a
periodic integrity and leak testing program for the identified containers and their
associated equipment (as described in Section 7.0). In addition to regular integrity
testing, a rigorous inspection and maintenance program has also been implemented.
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Figures
Figure 1 – Vicinity Map of OXY’s Operational Areas
Figure 2 – Sites within the Mesa Production Area
Figure 3 – Sites within the Valley Production Area
Figure 4 – Sites within the Logan Wash Production Area
Figure 5 – Sites within Brush Creek Production Area
Figure 6 – Sites within East Plateau Production Area
Figure 7 – Sites within Hell’s Gulch Production Area
OXY SPCC Plan – Garfield and Mesa Counties, Colorado
Attachment 1
Document Revision/Amendment Log
OXY SPCC Plan – Garfield and Mesa Counties, Colorado
Attachment 2
Secondary Containment Calculations Spreadsheet
Attachment 3
List of Facilities
Facility Overview Sheets
Facility Diagrams
Substantial Harm Criteria
Checklist and
PE Certification
Appendix A
Contact Lists and Emergency Response Procedures
OXY SPCC Plan – Garfield and Mesa Counties, Colorado
Appendix B
Inspection, Maintenance and Testing Protocols
B.1 Oxy Piceance Pad Inspection Checklist
B.2 Oxy Piceance Pad Inspection Procedure
B.3 Oxy Facility Periodic Observation Procedure
B.4 COGCC Form 36
B.5 Oxy Mechanical Integrity Standard
OXY SPCC Plan – Garfield and Mesa Counties, Colorado
B.1 Oxy Piceance Pad Inspection Checklist
OXY SPCC Plan – Garfield and Mesa Counties, Colorado
B.2 Oxy Piceance Pad Inspection Procedure
OXY SPCC Plan – Garfield and Mesa Counties, Colorado
B.3 Oxy Periodic Monitoring Procedure
OXY SPCC Plan – Garfield and Mesa Counties, Colorado
B.4 COGCC Form 36
OXY SPCC Plan – Garfield and Mesa Counties, Colorado
B.5 Oxy Mechanical Integrity Standard
OXY SPCC Plan – Garfield and Mesa Counties, Colorado
Appendix C
Oxy Exhibit A
OXY SPCC Plan – Garfield and Mesa Counties, Colorado
Appendix D
List of Facilities Utilizing 3-Phase Separators
OXY SPCC Plan – Garfield and Mesa Counties, Colorado
Appendix E
Loading/Unloading Procedures
Appendix F
Oil Spill Contingency Plan
Appendix G
Oxy Emergency Response Plan
Appendix H
Regulation Citations
Appendix I
Facility Change Guidance Document