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HomeMy WebLinkAbout1.08 SPCC, Fugitive dust controlSpill Prevention Control and Countermeasure Plan Grand River Gathering LLC High Mesa Compressor Station OA Project No. 012-0732 826 21 ½ Road | Grand Junction, CO 81505 | TEL 970.263.7800 | FAX 970.263.7456 SPILL PREVENTION CONTROL AND COUNTERMEASURE PLAN HIGH MESA COMPRESSOR STATION GARFIELD COUNTY, COLORADO GRAND RIVER GATHERING, LLC 2128 Railroad Avenue Rifle, CO 81650 REVISION DATE: April 2012 i TABLE OF CONTENTS Section Page No. SECTION 1.0 MANAGEMENT COMMITMENT CERTIFICATION ............................................................ 1 SECTION 2.0 ENGINEERING CERTIFICATION ...................................................................................... 2 SECTION 3.0 INTRODUCTION ................................................................................................................. 3 SECTION 4.0 GENERAL APPLICABILITY ................................................................................................ 4 SECTION 5.0 SPCC PLAN ADMINISTRATION: §112.3, §112.4, AND §112.5 ........................................ 5 5.1 Requirement to Prepare and Implement a n SPCC Plan : §112.3 ...................................... 5 5.2 Amendment of SPCC Plan by Regional Administrator: §112.4 ......................................... 5 5.3 Amendm ent of SPCC Plan by Owner/Operator: §112.5 ................................................... 6 SECTION 6.0 QUALIFIED FACILITY PLAN REQUIREMENTS: §112.6 ................................................... 7 SECTION 7.0 SPCC PLAN GENERAL REQUIREMENTS §112.7 ........................................................... 8 7.1 General Facility Information ............................................................................................ 8 7.2 General Facility Description ............................................................................................ 9 7.3 SPCC Plan Conformance and Deviations: §112.7(a)(1) and (2) ....................................... 9 7.4 Facility Layout: §112.7(a)(3)............................................................................................ 9 7.5 Oil Storage Capacity: §112.7(a)(3)(i) ............................................................................... 9 7.6 Discharge Prevention Measures: §112.7(a)(3)(ii) .......................................................... 10 7.7 Discharge Drainage Controls: §112.7(a)(3)(iii) .............................................................. 10 7.8 Countermeasures for Discharge Discovery, Response and Cleanup: §112.7(a)(3)(iv) ... 11 7.9 Recovered Materials Disposal: §112.7(a)(3)(v) .............................................................. 11 7.10 Contact List and Notification Phone Numbers: §112.7(a)(3)(vi)...................................... 12 7.11 Reporting and Notification Procedures: §112.7(a)(4) ..................................................... 12 7.12 Oil Spill Response Procedures: §112.7(a)(5) ................................................................. 12 7.13 Discharge Analysis: §112.7(b)....................................................................................... 12 7.14 Spill Containment: §112.7(c) ......................................................................................... 12 7.15 Spill Containment Practicability: §112.7(d) .................................................................... 13 7.16 Inspections, Tests and Records: §112.7(e) ................................................................... 13 7.17 Personnel Tr aining and Discharge Prevention Measures: §112.7(f) ............................... 13 7.18 Security: §112.7(g) ....................................................................................................... 14 7.19 Facility Tank Car and Tank Truck Loading/Unloading: §112.7(h) ................................... 14 7.20 Brittle Fracture Analysis: §112.7(i) ................................................................................ 14 7.21 Applicable Requirements: §112.7(j) ............................................................................... 14 7.22 Qualified Oil-filled Operational Equipment : §112.7(k) .................................................... 14 SECTION 8.0 SPCC PLAN REQUIREMENTS FOR ONSHORE FACILITIES (EXCLUDING PRODUCTION FACILITIES): §112.8 ............................................................................... 15 SECTION 9.0 SPCC PLAN REQUIREMENTS FOR ONSHORE OIL PRODUCTION FACILITIES: §112.9 ......................................................................................................... 16 9.1 Oil Production Facility Drainage: §112.9(b) ................................................................... 16 9.2 Oil Production Facility Bulk Storage Containers: §112.9(c) ............................................ 16 9.3 Facility Transfer Operations, Oil Production Facility: §112.9(d) ..................................... 17 SECTION 10.0 SPCC PLAN REQUIREMENTS FOR ONSHORE OIL DRILLING AND WORKOVER FACILITIES: §112.10 ................................................................................. 18 SECTION 11.0 SPCC PLAN REQUIREMENTS FOR OFFSHORE OIL DRILLING, PRODUCTION AND WORKOVER FACILITIES: §112.11 ............................................... 18 TABLE OF CONTENTS (Continued) ii APPENDICES Appendix A – Certification of the Applicability of the Substantial Harm Criteria Appendix B – Oil Spill Response Procedures (Including Notification Phone Numbers) Appendix C – SPCC Plan Review/Amendment Documentation Appendix D – Facility Information Figure 1 Facility Location Map Figure 2 Facility Diagram Secondary Containment Calculations Appendix E – Inspection Procedures and Records Appendix F – Training Procedures and Records 1 SECTION 1.0 MANAGEMENT COMMITMENT CERTIFICATION Management approval has been extended at a level with authority to commit the necessary resources to implement this Spill Prevention, Control and Countermeasure (SPCC) plan. Pursuant to §112.7(d), this is the written commitment of Grand River Gathering, LLC (GRG) to provide the manpower, equipment and materials required to expeditiously control and remove any quantity of oil discharged that may be harmful to human health and the environment. A copy of this plan shall be maintained by the operator as described herein and will be made available to the EPA Regional Administrator for on-site review during normal working hours. Authorized Management Representative: Signature: Name: Mike Rose Title: Director, Engineering, Construction and Operations Date: SECTION 2.0 ENGINEERING CERTIFICATION Pursuant to §112.3(d) and by means of this certification , I attest that: I am familiar with the requirements of the SPCC rule ( 40 CFR 112); The facility has been visited and examined by myself or my agent; This plan has been prepared in accordance w ith good engineering practice , including consideration of appl icable industry standards, and with the requirements of the SPCC rule; Procedures for required inspections and testing have been established; and, This plan is adequate for the facility. Signature of Profess ional Engineer State Registration No. Cn,~ State Note : The PE's certification does not relieve the owner/operator of the facility of the duty of fully implementing the SPCC plan in accordance with all applicable requirements. 2 3 SECTION 3.0 INTRODUCTION In January 1974, the Environmental Protection Agency (EPA) adopted 40 CFR Part 112 as the Oil Pollution Prevention Program. This program was most recently amended on November 5, 2009 and the amended regulations took effect on January 14, 2010. These oil pollution prevention regulations require the preparation of a Spill Prevention Control and Countermeasure (SPCC) Plan for a facility engaged in drilling, producing, gathering, storing, processing, refining, transferring, distributing, using, or consuming oil and oil products, and which due to its location, could reasonably be expected to discharge oil in quantities that may be harmful, as described in 40 CFR Part 110, into or upon the navigable waters of the United States or adjoining shoreline, or into or upon the waters of the contiguous zone, or in connection with activities under the Outer Continental Shelf Lands Act or the Deepwater Port Act of 1974, or that may affect natural resources belonging to, or under the exclusive authority of the United States (40 CFR, Part 112.1(b)). The SPCC regulations and additional information can be found at: http://www.epa.gov/oilspill/spcc.htm. The following sections of this plan are presented in the sequence of the SPCC rule, as required by the rule. The substantive requirements (§112.7 and §112.9) are addressed in Sections 7.0 and 9.0, respectively. Throughout this plan, where applicable, references to the appropriate subsections of 40 CFR Part 112 are provided, followed by an explanation of how the requirements have been addressed. 4 SECTION 4.0 GENERAL APPLICABILITY The Oil Pollution Prevention Regulations (40 CFR Part 112) require preparation of an SPCC plan for facilities that have discharged or could reasonably be expected to discharge oil into or upon navigable waters of the United States or adjoining shorelines. Specifically, §112.1(d)(2) requires an SPCC plan to be developed for facilities where the buried below ground storage capacity of oil is greater than 42,000 gallons or the aggregate aboveground storage capacity of oil is greater than 1,320 gallons (inclusive of containers with thresholds of 55-gallons or greater). The High Mesa Compressor Station covered in this SPCC plan has a collective potential maximum aboveground storage capacity above the threshold amount, thus GRG is required to develop, implement, and maintain an SPCC plan for the facility. The purpose of this SPCC plan is to identify sources of oil at the High Mesa Compressor Station and outline procedures to prevent the release of oil into or upon navigable waters of the United States or that may affect the natural resources of the United States. Any facility that could, because of its location, be expected to cause substantial harm to the environment by discharging oil into or on navigable waters or adjoining shorelines is required to prepare and submit a facility response plan (FRP) to the USEPA Regional Administrator (RA) in accordance with 40 CFR Part 112.20. The High Mesa Compressor Station is not considered such a facility because it does not meet any of the substantial harm criteria specified in §112.20. These criteria, and the associated applicability determination regarding the High Mesa Compressor Station, are shown in Appendix A. This appendix is the Certification of the Applicability of the Substantial Harm Criteria required by §112.20 and must be maintained at the facility. Because submittal of an FRP is not required, except at the discretion of the RA, this SPCC plan provides information and procedures for responding to discharges. 5 SECTION 5.0 SPCC PLAN ADMINISTRATION: §112.3, §112.4, AND §112.5 5.1 Requirement to Prepare and Implement an SPCC Plan: §112.3 This SPCC plan is intended to comply with the SPCC rule (40 CFR Part 112) that was most recently amended on November 5, 2009 and took effect on January 14, 2010. This facility was operational before November 10, 2011, so the provisions of §112.3(c) do not apply. This facility is not an onshore or offshore mobile facility, so the provisions of §112.3(c) do not apply. In accordance with §112.3(d), this SPCC plan has been reviewed and certified by a professional engineer. See Section 2.0 of this document. As this facility is not typically manned for at least 4 hours per day, in accordance with §112.3(e)(1) and (2), a complete updated copy of the SPCC Plan and associated files will be maintained at the GRG office in Rifle, Colorado. During normal working hours the plan will be available to authorized representatives of Local, State or Federal governing agencies for on-site review and a copy will be submitted to the EPA if requested. 5.2 Amendment of SPCC Plan by Regional Administrator: §112.4 In accordance with §112.4(a), whenever more than 1,000-gallons of oil have been discharged in a single incident or more than 42-gallons of oil have been discharged in each of two incidents over a 12-month period, GRG will submit an incident report to the EPA RA within 60 days (refer to the definition of a discharge previously provided in Section 4.0). The report must include the following:  §112.4(a)(1): Name of the facility;  §112.4(a)(2): Name of the operator;  §112.4(a)(3): Location of the facility;  §112.4(a)(4): Maximum storage or handling capacity of the facility and the normal daily throughput;  §112.4(a)(5): Corrective action and countermeasures that have been taken, including a description of equipment repairs and replacements;  §112.4(a)(6): An adequate description of the facility, including maps, flow diagrams, and topographical maps, as necessary;  §112.4(a)(7): The cause of such discharge as described in 40 CFR 112.1(b), including a failure analysis of the system or subsystem in which the failure occurred;  §112.4(a)(8): Additional preventive measures taken or planned to minimize the possibility of recurrence; and  §112.4(a)(9): Such other information as the Regional Administrator may reasonably require pertinent to the SPCC Plan or discharge. 6 In accordance with 40 CFR 112.4(c), copies of the incident report will also be forwarded to the Colorado Oil and Gas Conservation Commission (COGCC) and/or the Colorado Department of Public Health and Environment (CDPHE) as appropriate (See Appendix B for spill reporting details). The RA may subsequently propose by certified mail or personal delivery that this SPCC plan be amended. GRG will act in accordance with §112.4(d), (e), and (f) and will amend this SPCC plan as needed within 30 days and implement the amended plan within six months, unless the RA specifies another date. 5.3 Amendment of SPCC Plan by Owners or Operators: §112.5 In accordance with §112.5(a), when there is a change in facility design, construction, operation, or maintenance that materially affects the facility’s potential for a discharge, GRG will amend this SPCC plan within six months of the change and implement the amended plan as soon as possible, but not later than six months following preparation of the amendment. Modifications which may require plan amendments and certification include: - Commissioning or decommissioning of containers or oil-filled equipment - Replacement, reconstruction, or movement of containers or oil-filled equipment - Reconstruction, replacement, or installation of piping systems - Construction or other work that alters secondary containment structures - Changes in stored materials or type of equipment service - Changes in operating and maintenance procedures that affect SPCC compliance. There are no exempted produced water containers at this facility, according to the requirements of §112.9(c)(6)(i), so sections §112.5(b) and (c) do not apply to this facility. In accordance with §112.5(d), GRG will also review this plan at least once every five years from the last review. As a result of the review, the plan will be amended within six months of the review if more effective prevention and control technology has been field-proven at the time of the review and will significantly reduce the likelihood of a discharge. The amended plan will be implemented as soon as possible, but not later than six months following preparation of the amendment. The designated person accountable for oil spill prevention at the facility (see Section 7.1) will document completion of each five year review, sign a statement as to whether the plan will be amended, and record the results in Appendix C. As required by §112.5(e), technical amendments to the plan will be certified by a Professional Engineer. Any such amendments to this SPCC plan shall be noted on the Amendment Log included in Appendix C of this SPCC plan. Entries into the log will indicate a general description of the changes that were made to the facility, the corresponding changes that were made to the SPCC plan, including plan section and page numbers, and the name and signature of the person making the changes. A new certification page will be signed, sealed and inserted into this plan to complete the amendment process. Non-technical changes include, but are not limited to, such items as: contact lists, more stringent requirements for stormwater discharges to comply with NPDES rules, phone numbers, product changes if the new product is compatible with conditions in the existing tank and secondary containment materials, and any other changes which do not materially affect the facility’s potential to discharge oil. If GRG personnel are unsure whether the amendment is technical or non-technical, the amendments should be reviewed and certified by a Professional Engineer. 7 SECTION 6.0 QUALIFIED FACILITY PLAN REQUIREMENTS: §112.6 This facility either does not meet the qualified facility qualification criteria in §112.3(g), or the operator is not choosing to self-certify the SPCC plan. As such, the provisions of §112.6 do not apply to this plan. 8 SECTION 7.0 SPCC PLAN GENERAL REQUIREMENTS: §112.7 This section presents facility-specific details associated with the general requirements for SPCC plans outlined in §112.7. As previously indicated in Sections 1.0, 2.0 and 3.0, this SPCC plan has been prepared in accordance with good engineering practice, with management approval at a level with authority to commit the necessary resources for full implementation, and in the sequence of the rule. 7.1 General Facility Information Name and type of facility: The High Mesa Compressor Station is a natural gas production facility owned and operated by Grand River Gathering, LLC. The High Mesa Compressor Station is considered a production facility, as it is upstream of associated custody transfer points to transportation-related systems. Location of facility: The High Mesa Compressor Station is located in the southeast quarter of the northeast quarter of Section 36 in Township 7 South, Range 96 West in Garfield County, Colorado. The town of Parachute, Colorado, which lies approximately 3.9 miles north of the facility, is the nearest population center. See Figure 1 for additional site location information. Owner name and address: Grand River Gathering, LLC 2300 Windy Ridge Parkway, Suite 240S Atlanta, GA 30339 (770)-504-5004 Designated personnel accountable for spill prevention: Regional/District Contact SPCC Contact Mr. Mike Rose Mr. Floyd Alvey Director, Eng., Const. and Operations Compression Supervisor Grand River Gathering, LLC Grand River Gathering, LLC 2128 Railroad Avenue 2128 Railroad Avenue Rifle, CO 81650 Rifle, CO 81650 (214) 242-1964 office (970) 440-1001 office (214) 926-6299 mobile (970) 319-0357 mobile Has the facility experienced a reportable oil spill (discharge) event during the past 12 months? No, the facility has not experienced a reportable oil spill event during the 12 months preceding the certification date of this SPCC plan. 9 7.2 General Facility Description The High Mesa Compressor Station is a natural gas production facility owned and operated by Grand River Gathering, LLC. The facility is located in western Colorado, in Garfield County. The area surrounding the facility is considered multiple-use land and area activities include oil and gas exploration and production. The location of the facility and details of the oil storage areas are depicted in Appendix D. According to U.S. Geological Survey topographic mapping sources (Parachute, Colorado quadrangle), the site lies at an approximate elevation of 5,940-feet above mean sea level with shallow relief in the immediate vicinity of the site. All existing drainages in the vicinity of the facility discharge to the Colorado River, which lies approximately 1.9 miles northwest of the facility. Pete and Bill Creek runs approximately 1,900-feet southwest of the facility. Drainage within the site boundary is governed by surface topography. Downhill slope direction arrows on Figure 2 indicate the predicted general direction of storm water flow to the north. The facility consists of metering equipment, separation equipment, above ground storage tanks, and piping systems. Products related to the maintenance and operation of the facility are stored in above ground storage tanks. Natural gas liquids are occasionally taken from the facilit y via tank truck. The facility operates 24 hours per day and is inspected daily by operations personnel. An inventory of all facility storage tanks is provided in Section 7.5. Specific liquids stored at the facility are considered oils, as defined in 40 CFR §112.2, for the purpose of this SPCC plan. The facility is considered a production facility and is thus subject to the specific SPCC requirements of 40 CFR §112.9 for onshore production facilities. 7.3 SPCC Plan Conformance and Deviations: §112.7(a)(1) and (2) This SPCC plan is intended to conform to the applicable requirements of CFR 40 §112.7, as detailed in the subsequent sections of this SPCC plan. The High Mesa Compressor Station is an onshore production facility and is therefore subject to §112.9. 7.4 Facility Layout: §112.7(a)(3) Oil storage areas at the facility are identified on Figure 2. There are no completely buried or bunkered tanks or connected underground piping at the facility as defined by §112.2 of the SPCC regulations, other than lines leading from the separation equipment to storage tanks. Aboveground storage containers and oil-filled equipment applicable to this plan are listed below in Section 7.5 7.5 Oil Storage Capacity: §112.7(a)(3)(i) A summary of the substances, containers, and container capacities applicable to this plan is provided in the following table. Although oil-filled equipment are not considered bulk storage containers as defined by §112.2, the applicability criteria such as oil storage capacity and potential for a discharge still pertain and the prevention of discharges from such equipment is covered in §112.7(k) of the SPCC rule. Consequently, the type of oil and capacity of the oil- filled equipment at the High Mesa Compressor Station are included in the summary. 10 SPCC-Regulated Storage Containers and Oil-Containing Equipment Container/Equipment Description Container Reference ID Container Storage Capacity (BBL) Net Containment Capacity (BBL) Condensate/Prod. Water AST 1 300 441 Condensate/Prod. Water AST 2 300 441 Slug Catcher 3 710.4 0 Separator 4 TBD 124 Scrubber Vessel 6 18.9 0 Lubricating Oil AST 9 24 28 Lubricating Oil AST 10 24 28 Lubricating Oil AST 11 24 67 Lubricating Oil AST 12 24 67 Compressor Engine (x9) 14 2 (ea., est.) 0 Compressor (x9) 15 2 (ea., est.) 0 Compressor Scrubber (x18) 16 1.5 (ea., est.) 0 Notes: The indicated net capacities are gross containment volumes less the displaced volume of other equipment within the containment space (if applicable) and at least 2.2 inches of freeboard to accommodate precipitation associated with a 24-hour 25-year storm event. (Source: NOAA Atlas 2) 7.6 Discharge Prevention Measures: §112.7(a)(3)(ii) The High Mesa Compressor Station relies on a number of measures to aide in the prevention of a discharge. Descriptions of these measures are provided below.  Routine maintenance of any oil-containing equipment is performed by trained personnel at the location of the equipment utilizing soaker pads and the available secondary containment structures and/or drip pans as warranted.  Each storage tank or vessel has a system in place that has been designed and installed in accordance with good engineering practice to prevent discharges. These features may include: adequate containment volume to avoid overfill during normal operations, and; high level sensors and controls to stop liquid flow. All discharge features are inspected at regular intervals. 7.7 Discharge or Drainage Controls: §112.7(a)(3)(iii) The products stored at the High Mesa Compressor Station (e.g. natural gas liquids, produced water, and lubricating oil) are noncorrosive materials and are compatible with the materials with which the storage containers and containment structures at the facility are constructed. The containment structures at the facility are designed to provide adequate protection against the discharge of oil. Secondary containment is provided for the atmospheric aboveground storage tanks. Secondary containment details are provided in Section 7.14. 11 Containment capacity calculations and/or specifications are provided in Appendix D. Each secondary containment system, including the walls and floor of each respective system, is capable of containing oil and has been constructed so that any discharge from a primary containment system (such as a tank or pipe) will not permeate, drain, infiltrate, or otherwise escape before cleanup occurs. 7.8 Countermeasures for Discharge Discovery, Response and Cleanup: §112.7(a)(3)(iv) As part of routine facility operational procedures, visual exterior inspections of the oil storage containers and equipment are made several times per week, at a minimum, for signs of deterioration or leaks. Deficiencies noted from these examinations are entered on a check sheet and corrected in a timely manner. Inspection check sheets are kept in a logbook in the field office in Rifle, Colorado. In addition to the regular checks, the oil storage equipment is inspected annually according to the written procedures outlined in Section 7.16 of this plan. Any discharge occurring at the facility would likely be discovered by GRG operational personnel during routine site visits. Upon discovery, response procedures will be immediately initiated. In the event of a release, the facility has trained personnel and equipment available to contain and clean up minor volumes of discharged oil. On-site equipment and materials include spill kits, shovels, and sorbent materials (booms, pads, etc.) that may be used to dike, contain , and remove minor releases. In the event of a larger discharge, specific response procedures have been developed (See Appendix B). As part of these procedures, external resources (contractors) have been identified to assist facility personnel. To ensure the commitment of these external resources, GRG maintains a service agreement with each selected contractor. A list of approved contractors is kept at the facility and at the GRG office in Rifle, Colorado. At a minimum, contractors identified to assist in a spill response will have the capabilities to provide emergency response, industrial power vacuuming, tank and pipeline cleaning, equipment decontamination, excavation/earthmoving and waste transportation and disposal services. 7.9 Recovered Materials Disposal: §112.7(a)(3)(v) Materials recovered during a spill event will be appropriately containerized or will be remediated on site in accordance with Colorado Oil and Gas Conservation Commission (COGCC) stipulations. Soils and other solids will be placed in 55-gallon drums or roll-off containers, or in other approved containers as warranted. Liquids will be placed in 55-gallon drums or will be collected in a tank truck using industrial power vacuuming. Recovered materials will be labeled, characterized and disposed/recycled in accordance with applicable federal, state and local regulations. 12 7.10 Contact List and Notification Phone Numbers: §112.7(a)(3)(vi) The contact list for oil spill response activities is provided in Appendix B, as part of the Oil Spill Response Procedures developed for the High Mesa Compressor Station. 7.11 Reporting and Notification Procedures: §112.7(a)(4) Reporting and notification requirements are outlined in the Oil Spill Response Procedures provided in Appendix B. 7.12 Oil Spill Response Procedures: §112.7(a)(5) Oil Spill Response Procedures for the High Mesa Compressor Station are provided in Appendix B. 7.13 Discharge Analysis: §112.7(b) Pursuant to §112.7(b), the reasonably expected modes of equipment failure or accidental fluid release are: - Failure modes: Corrosion, piping or valve failure, tank failure, pressure vessel rupture, overflow, overfilling, vandalism, lightning strikes, and human error. - Rate of discharge flow: the rate of flow of an accidental release will vary depending on ambient conditions, the type of failure mode causing the release, the location of the release, and the volume of material stored in the container or equipment. The ambient temperature at the time of release can affect fluid viscosity and flow rates. Piping or valve failures can result in flow rates ranging from 1 to several hundred gallons per hour. Tank failures or lightning strikes can result in instantaneous releases of entire container volumes. - Discharge quantity: discharge quantities will vary depending on the type and location of the failure. Tank release quantities will not exceed the storage volume of the tank. Process equipment release quantities will be dependent on the length of time that the release goes undetected. - Preventative measures: Tanks and oil-filled equipment are constructed in accordance with API, ASME, or other applicable industry standards. Where practicable, diversionary or containment structures are in place to control or contain released fluids as described in this document. 7.14 Spill Containment: §112.7(c) Oil storage containers at the High Mesa Compressor Station are equipped with secondary containment as noted in this document. Spill containment at the facility is described below: - Secondary containment is typically provided for the lubricating oil, and condensate above ground storage tanks in the form of earthen dikes or steel-wall containers. Containment or discharge prevention measures for other oil-filled equipment and vessels is provided as described below in Section 7.22. 13 - Containment structures are, or will be, configured to contain the storage capacity of the largest tank within the containment area, plus at least 2.2 inches of freeboard to accommodate precipitation associated with a 24-hour 25-year storm event (Source: U.S. Department of Commerce National Oceanic and Atmospheric Administration Atlas 2, Volume II). The containment volume calculations associated with the secondary containment structures are presented in Appendix D. 7.15 Spill Containment Practicability: §112.7(d) No discussions related to practicability are warranted because this SPCC plan either does not deviate from the requirements of §§112.7(c), 112.7(h)(1), 112.8(c)(2), 112.8(c)(11), 112.9(c)(2), 112.10(c), 112.12(c)(2), and 112.14(c), or, where it does deviate, the deviations are not practicability-caused issues. 7.16 Inspections, Tests and Records: §112.7(e) Oil storage containers, oil-filled equipment and related containment structures at the High Mesa Compressor Station are visually examined several times per week, at a minimum, for signs of deterioration or leaks. These inspections are conducted as part of normal facility operations. Deficiencies noted from these examinations are entered on a check sheet and corrected in a timely manner. The equipment is also inspected annually according to the written procedure in Appendix E. Signed and dated records of all inspections and other pertinent information, such as spills, removal and disposal of spill contaminated materials, replacement or repair of equipment, and training are maintained for a minimum of 3 years. 7.17 Personnel Training and Discharge Prevention Measures: §112.7(f) Oil-handling personnel operating the facility are required to have training in the operation and maintenance of equipment to prevent the discharge of oil; discharge procedure protocols; applicable pollution control laws, rules, and regulations; general facility operations; and the contents of the facility SPCC plan. They are under the direct supervision of the Compression Supervisor, who is responsible for establishing performance and duty guidelines and is the designated person accountable for spill prevention at the facility. Regular safety meetings are held to discuss a variety of safety procedures and other pertinent job responsibility criteria. A written record of all training is maintained for three years. At a minimum, training is conducted annually and whenever new spill regulations are promulgated, existing operating systems are modified, personnel responsibilities change, or the SPCC plan is amended. In addition, regular safety meetings will be used as a forum to reinforce understanding of SPCC procedures as necessary. An outline of the topics to be covered during SPCC training is presented in Appendix F. Attendance rosters and other training records will be maintained at the field office in Rifle, Colorado for a period of no less than three years. 14 7.18 Security: §112.7(g) The security requirements of the SPCC rule are not applicable to t he High Mesa Compressor Station, as the facility is a production facility. 7.19 Facility Tank Car and Tank Truck Loading/Unloading: §112.7(h) The High Mesa Compressor Station has no loading/unloading racks as defined in §112.2. Proper loading procedures will be followed and wheel chocks used by tank truck drivers to prevent vehicles from departing or moving before completed disconnection of flexible or fixed oil transfer lines. All tank truck drivers are required to comply with DOT regulations in 49 CFR Part 177 and facility standard operating procedures. All drivers must be authorized and/or certified by GRG. When possible, GRG operations personnel will remain with any delivery truck during filling operations to monitor the transfer; inspect outlets, connections and valves on the delivery tank truck before and after oil-filling operations; and make adjustments as necessary. The driver or an operations personnel member visually inspects all tank trucks before leaving the loading/unloading areas. The lowermost drain and all outlets of transport vehicles shall be inspected and, if necessary, make certain that they are tightened, adjusted, or replaced to prevent liquid discharge while in transit. 7.20 Brittle Fracture Analysis: §112.7(i) The High Mesa Compressor Station has no field-constructed aboveground oil-storage containers that apply to this plan and therefore this section of the regulation is not applicable. 7.21 Applicable Requirements: §112.7(j) Sections 7.0 and 9.0 of this plan provide detailed discussions of conformance with the applicable requirements and other effective discharge prevention used at the facility. 7.22 Qualified Oil-filled Operational Equipment: §112.7(k) This facility contains qualified oil-filled operational equipment (i.e. equipment that includes an oil storage container in which the oil is present solely to support the function of the device and that has not had a single discharge exceeding 1,000 gallons or two discharges exceeding 42 gallons within a twelve month period in the three years preceding this plan). The qualified oil-filled equipment is included in the facility inspection program discussed in Section 7.16 of this plan to detect equipment failure and/or discharges. The equipment is covered by an oil spill contingency plan following the provisions of 40 CFR Part 109 as described in Appendix B. Section 1.0 of this plan contains a written commitment of manpower, equipment, and materials required to expeditiously control and remove any quantity of oil discharged that may be harmful. 15 SECTION 8.0 SPCC PLAN REQUIREMENTS FOR ONSHORE FACILITIES (EXCLUDING PRODUCTION FACILITIES): §112.8 The High Mesa Compressor Station is not an onshore non-production facility. Consequently, the provisions in §112.8 do not apply. 16 SECTION 9.0 SPCC PLAN REQUIREMENTS FOR ONSHORE OIL PRODUCTION FACILITIES: §112.9 9.1 Oil Production Facility Drainage: §112.9(b) Precipitation that may accumulate in any contained area is normally allowed to evaporate. No automatic pumps or ejector devices are present in any of the containment areas. If removal of any water accumulated in the containment areas is necessary, it will be conducted under the direct supervision of responsible personnel as described in this section. Accumulated precipitation is removed, when necessary, from secondary containment areas using a vacuum truck, pump, or other appropriate method. Removed water is disposed of in accordance with applicable local, state, and federal regulations. Prior to removal of the water from any containment area, the responsible personnel visually inspect the water in the containment structure and note the appearance of the water in the facility logs. The name of the person draining the containment, as well as the date, time, and approximate quantity of water removed will also be recorded in the facility logs and kept on file with the SPCC documents for a period of at least three years. A secondary containment drainage log is included in Appendix E. The drain systems at the High Mesa Compressor Station are of the ‘enclosed’ type. All process effluents are routed through drain lines to storage tanks. No process effluents, untreated or treated, are released off-site. All field drainage systems (such as drainage ditches or road ditches) in the vicinity of the facility are inspected at regular intervals for the presence of accumulated oil that may have resulted from a small discharge. Any accumulated oil will be removed from these areas promptly upon discovery. 9.2 Oil Production Facility Bulk Storage Containers: §112.9(c) In accordance with §112.9(c)(1), the products stored at the High Mesa Compressor Station are compatible with the materials with which the storage containers and containment structures at the facility are constructed. Specific secondary containment details are presented in Section 7.14. In accordance with §112.9(c)(2), the tank battery and oil-filled equipment areas are equipped with sized secondary containment or covered by discharge prevention measures as noted in this document. Secondary containment at the facility is described in Section 7.14 and Appendix D. In accordance with §112.9(c)(3), oil storage containers, oil-filled equipment and related containment structures at the High Mesa Compressor Station are visually examined several times per week, at a minimum, for signs of deterioration or leaks. These inspections are conducted as part of normal facility operations. Deficiencies noted from these examinations are entered on a check sheet and corrected in a timely manner. The equipment is also inspected annually according to the written procedure in Appendix E. In accordance with §112.9(c)(4), each storage tank or vessel at the High Mesa Compressor Station has a system in place that has been designed and installed in accordance with good 17 engineering practice to prevent discharges. These features may include adequate container volume to avoid overfill and high-level sensors and controls to stop liquid flow. All discharge prevention features are inspected at regular intervals. Certain flow-through process vessels at the facility are not equipped with sized secondary containment. The alternate requirements of §112.9(c)(5) are followed, including these actions: - Periodically and on a regular schedule, the process vessels and associated equipment are visually inspected and/or tested for leaks, corrosion, or other conditions that could lead to a discharge. - Corrective action is taken, or repairs are made to process vessels and associated equipment when necessary as indicated by regularly scheduled visual inspections, tests, or evidence of an oil discharge. - Prompt removal or initiation of actions to stabilize and remediate any accumulations of oil discharges associated with process vessels and associated equipment. - If the facility discharges more than 1,000 gallons of oil in a single discharge, or discharges more than 42 gallons in each of two discharges, within any twelve month period, from process flow-through vessels, then GRG will make certain that all process vessels comply with the requirements of §112.9 within six months of the discharge. There are no produced water tanks at this facility subject to §112.9(c)(6). 9.3 Facility Transfer Operations, Oil Production Facility: §112.9(d) In accordance with §112.9(d)(1), all above ground valves and piping associated with transfer operations are periodically and regularly inspected for the general condition of flange joints, valve glands and bodies, drip pans, pipe supports, and other appurtenances. There is no saltwater/oil field brine disposal equipment at this facility subject to §112.9(d)(2). In accordance with §112.9(d)(3), the facility flowlines with the potential for a discharge are either provided secondary containment, or covered by an oil spill contingency plan following the provisions of 40 CFR Part 109 as described in Appendix B. Section 1.0 of this plan contains a written commitment of manpower, equipment, and materials required to expeditiously control and remove any quantity of oil discharged that may be harmful. In accordance with §112.9(d)(4), the facility adheres to a program of flowline maintenance that includes: - Ensuring that flowlines and associated valves and equipment are compatible with the type of production fluids, their potential corrosivity, volume, and pressure, and any other conditions expected in the operational environment. - Visually inspecting and/or testing flowlines and associated appurtenances on a periodic and regular schedule for leaks, oil discharges, corrosion, or other conditions that could lead to a discharge as described in §112.1(b). - Taking corrective action or making repairs to and flowlines and associated appurtenances as indicated by regularly scheduled visual inspections, tests, or evidence of a discharge. - Promptly removing or initiating actions to stabilize and remediate any accumulations of oil discharges associated with flowlines and associated appurtenances. 18 SECTION 10.0 SPCC PLAN REQUIREMENTS FOR ONSHORE OIL DRILLING AND WORKOVER FACILITIES: §112.10 The High Mesa Compressor Station is not an onshore oil drilling or workover facility. Consequently, the provisions in §112.10 do not apply. SECTION 11.0 SPILL PREVENTION, CONTROL, AND COUNTERMEASURE PLAN REQUIREMENTS FOR OFFSHORE OIL DRILLING, PRODUCTION AND WORKOVER FACILITIES: §112.11 The High Mesa Compressor Station is not an offshore oil drilling, production or workover facility. Consequently, the provisions in §112.11 do not apply. Appendix A Certification of the Applicability of the Substantial Harm Criteria Certification of the Applicability of the Substantial Harm Criteria Facility Name: High Mesa Compressor Station Facility Location: The High Mesa Compressor Station is located in the southeast quarter of the northeast quarter of Section 36 in Township 7 South, Range 96 West in Garfield County, Colorado. Refer to Section 7.1 or Appendix D for site location information. 1. Does the facility transfer oil over water to or from vessels and does the facility have a total oil storage capacity greater than or equal to 42,000 gallons? YES__________ NO X 2. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and does the facility lack secondary containment that is sufficiently large to contain the capacity of the largest aboveground oil storage tank plus sufficient freeboard to allow for precipitation within any aboveground storage tank area? YES__________ NO X 3. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located at a distance (as calculated using the appropriate formula in Attachment C-III to this appendix {Appendix C to 40 CFR 112} or a comparable formula¹) such that a discharge from the facility could cause injury to fish and wildlife and sensitive environments? For further description of fish and wildlife and sensitive environments, see Appendices I, II, and III to DOC/NOAA”s “Guidance for Facility and Vessel Response Plans: Fish and Wildlife and Sensitive Environments” and the applicable Area Contingency Plan. YES__________ NO X 4. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located at a distance (as calculated using the appropriate formula in Attachment C-III to this appendix {Appendix C to 40 CFR 112} or a comparable formula¹) such that a discharge from the facility would shut down a public drinking water intake²? YES__________ NO X 5. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and has the facility experienced a reportable oil spill in an amount greater than or equal to 10,000 gallons within the last 5 years? YES__________ NO X CERTIFICATION I certify under penalty of law that I have personally examined and am familiar with the information submitted in this document, and that based on my inquiry of those individuals responsible for obtaining this information, I believe that the submitted information is true, accurate, and complete. ___________________________________ Signature Title ___________________________________ Name (please type or print) Date ¹ If a comparable formula is used, documentation of the reliability and analytical soundness of the comparable formula must be attached to this form. ² For the purposes of 40 CFR part 112, public drinking water intakes are analogous to public water systems as described at 40 CFR 143.2c. Appendix B Oil Spill Response Procedures Oil Spill Response Procedures FACILITY NAME: HIGH MESA COMPRESSOR STATION FACILITY ADDRESS: SE NE SECTION 36 IN TOWNSHIP 7 SOUTH, RANGE 96 WEST IN GARFIELD COUNTY, COLORADO NEAR PARACHUTE, COLORADO REFERENCE: SECTION 7.12 OF SPCC PLAN WRITTEN PROCEDURES APPROVED BY: Signature Title Name (please type or print) Date Oil Spill Response Procedures 1. Response Management Structure The Spill Coordinator and Alternate Spill Coordinator(s) are responsible for implementing response procedures in the event of an oil spill or discharge emergency. These personnel have the authority to commit the resources necessary to carry out a response. However, all operating personnel at the High Mesa Compressor Station receive training to familiarize themselves with all aspects of the SPCC Plan, facility operations, the location and characteristics of materials handled at the facility, and the location of all records within the facility; and are responsible for proper implementation of response procedures should the Spill Coordinator or Alternate Spill Coordinator(s) be unavailable. 2. Initial Response Releases at the High Mesa Compressor Station will be discovered through observations made during the course of normal work activities, inspections of work areas and equipment, monitoring devices, or by chance. Discovering a release is the first step in initiating a response. Upon discovery, the individual discovering a release should immediately: 1. Assess the basic situation. 2. Stop the source of the release if safely possible using available resources (including spill kits). 3. Restrict ignition sources if the material is flammable. 4. Secure the area as off limits. 5. In the event that the incident poses an immediate threat of fire, explosion, or other impact to safety, health, or the environment, contact the local fire department at 911. DO NOT HANG UP after completing the report, let the dispatcher hang up first. 6. Report the release to the Spill Coordinator or an Alternate Spill Coordinator (see attached Oil Spill Incident Notification Phone Numbers). 7. The Spill Coordinator (or alternate) will determine whether the spill incident warrants evacuation of the facility. If so, the procedures outlined in the facility Emergency Action Plan will be followed. 8. The Spill Coordinator (or alternate) will determine whether the spill incident constitutes a discharge as defined in §112.1(b) of the SPCC regulations (see Section 3, below) and will notify appropriate federal, state, and local agencies of the spill/release incident if warranted. 9. If the spill involves a minor volume of oil, it can be cleaned up by facility personnel provided that 1) they are OSHA trained and have received their current refresher training; 2) appropriate material safety data sheets (MSDS sheets) are available for the material spilled; and 3) appropriate personal protective equipment (PPE) is available. 10. If the spill involves a significant volume of oil, or any of the three criteria listed in (9) above are not met, it should be cleaned up by a properly certified outside contractor (see attached Oil Spill Incident Notification Phone Numbers). 3. Oil Spill Emergency Reporting If the release constitutes a discharge as defined in §112.1(b) of the SPCC regulations, it will be considered an Oil Spill Emergency. A release of oil is considered a discharge under this Plan only if: the release is into or upon the navigable waters of the United States, adjoining shorelines, or waters contiguous with navigable waters of the United States. This is apparent if a release impacts surface water quality by causing a film, sheen, or discoloration of the water surface, or upon water or adjoining shorelines, or causes a sludge or emulsion to be deposited beneath the surface of the adjoining shorelines. Impacts to groundwater also apply if the groundwater is contiguous with navigable waters of the United States (i.e., groundwater discharges to/contributes to the total volume of a surface water body that is itself contiguous with navigable waters of the United States). In summary, if a release directly affects surface water or groundwater at the facility, it must be considered an Oil Spill Emergency. Federal and local authorities to be notified in the event of an Oil Spill Emergency are outlined below. State of Colorado In Colorado, a spill or release of E&P wastes or produced fluids is to be reported within 24 hours if the spill has entered waters of the state (any surface or groundwater) or entered navigable waters (any surface water) in sufficient quantities to cause a sheen on the water or stain on the shore. Spills less than 5 barrels that do not impact, or threaten to impact, water, and which can be immediately contained and cleaned up, do not need to be reported. Spills greater than 20 barrels must be reported with 24 hours. All spills and releases of exploration and production waste or produced fluid exceeding five barrels, including those contained within lined or unlined berms, shall be reported in writing on the Colorado Oil and Gas Conservation Commission (COGCC) Spill/Release Report Form 19 within 10 days of discovery of the spill. In addition, spills or releases that exceed twenty barrels of exploration and production waste or produced fluid shall be reported on COGCC Form 19 and verbally reported to the COGCC as soon as practicable within 24 hours of discovery. Spills or releases of any size that impact or threaten to impact any waters of the state, residence or occupied structure, livestock or public byway, shall be verbally reported to the COGCC Environmental Release/Incident Report Hotline (1-877-518-5608) as soon as practicable after discovery. See COGCC Rule 906 for more information. If the spill may reach waters of the State (which include surface water, ground water and dry gullies or storm sewers leading to surface water), it must also be reported immediately to the Colorado Department of Public Health and Environment. Refined petroleum releases must be reported if they have entered navigable waters or if the quantity release exceeds 25 gallons. In general, verbal or telephone reports are to be made within 24 hours. The Director, Engineering, Construction and Operations or the Compression Supervisor will notify regulatory agencies as appropriate. As a practical matter, an evaluation of the specifics of each spill and a determination of reporting requirements will be made. If there is any question about reporting requirements, GRG will over-report rather than under-report. Written, follow up reports are to be sent within 10 days to: - Colorado Oil and Gas Conservation Commission 1120 Lincoln # 801 Denver, Colorado 80203 (Use COGCC Spill/Release Form) - Bureau of Land Management - File an "Undesirable Event Form" with: Glenwood Springs Resource Area Office 50629 Highways 6 and 24 P.O. Box 1009 Glenwood Springs, CO 81602 If the Local Emergency Planning Commission (LEPC) was notified of the spill (in the event of a hazardous substance release) a report should also be sent to: Jim Sears Garfield County Department of Emergency Management (LEPC) 107 8th Street Glenwood Springs, CO 81601 United States Environmental Protection Agency (EPA) An oil spill is reportable to the EPA if any of the following criteria are met: A) Is the spill to navigable waters or adjoining shorelines? B) Could Water Quality Standards be violated? C) Could the spill cause a film, “sheen”, or discoloration? D) Could the spill cause a sludge or emulsion? E) Do any of the reporting exemptions apply? Exemptions include 1) Properly functioning vessel engines not deemed harmful, 2) Research and Development Releases (approved on a case by case basis), 3) NPDES Permitted Releases, and 4) Discharges Permitted Under the International Convention for the Prevention of Pollution from Ships (MARPOL) If the answer to any question A through D above is “yes” and none of the exempt ions apply then the release is reportable to the EPA. To report an oil spill or hazardous substance release, call  the National Response Center: (800) 424-8802 For information on EPA’s Oil Spill Program, call the Oil Spill Program Information Line at (800) 424- 9346.  Region 8 EPA (CO, MT, ND, SD, UT, WY) 999 18th Street, Suite 500 Denver, Colorado 80202-2466 http://www.epa.gov./region08/ Telephone: (303) 312-6312 email: r8eisc@epa.gov Fax: (303) 312-6339 Toll Free: (800) 227-8917 4. Follow-up Activities After the initial response, reporting, and notification associated with a spill incident, the Spill Coordinator (or alternate) will prepare a written report which includes following: 1. Time and date of the incident; 2. Source and exact location of the spill; 3. Material involved; 4. Cause of the incident; 5. Estimated spill volume; 6. Names of any waterways involved; 7. Description of all media impacted by the spill; 8. Description of damages or injuries caused by the spill; 9. Actions taken to stop, remove, and mitigate the effects of the material spilled 10. Names of individuals and organizations contacted (time, day, who received call, who called from GRG, and pertinent notes). 11. Who reported to the scene from Federal, State, and Local agencies (time, day, etc)? In addition, whenever more than 1,000-gallons of oil are discharged in a single incident or more than 42-gallons of oil have been discharged in each of two incidents over a 12-month period, GRG will submit a report to the United States Environmental Protection Agency (USEPA) Regional Administrator (RA) as outlined in Section 5.2 of the SPCC Plan. 5. Sustained Actions Where prolonged mitigation and recovery actions are required in response to a spill or release, the Spill Coordinator (or alternate) will manage the activities with any or all of the following, as warranted: 1. An outside contractor. 2. An environmental/engineering consultant. 3. Any outside vendor responsible for the incident. 4. The appropriate local, state, and federal agencies. Most release incidents at the High Mesa Compressor Station are expected to be handled without implementing sustained actions. Oil Spill Response Procedures Notification Phone Numbers EPA 24-Hour Spill Notification Number 303.293.1788 Department of Transportation National Response Center 800.424.8802 Colorado Department of Public Health & Environment (CDPHE) 303.692.3033 CDPHE 24-Hour Spill Hotline 877.518.5608 Colorado Oil & Gas Conservation Commission (COGCC) 303.894.2100 COGCC Environmental Release/Incident Report Hotline 877.518.5608 Colorado Division of Labor, Oil Inspection Section 303.620.4300 Colorado PUC Safety and Enforcement Section 800.888.0170 Colorado State Patrol Hazmat Service 970.242.7283 St. Mary’s Hospital – Grand Junction, CO 970.244.2273 Grand River Medical Center – Rifle, CO 970.625.1510 *Garfield County Sheriff 970.945.0453 Garfield County Department of Emergency Management 970.945.9789 U.S. Dept. of Interior, Bureau of Land Management, Grand Junction Field Office 970.244.3000 U.S. Dept. of Interior, Bureau of Land Management, White River Field Office 970.878.3800 Grand River Gathering, LLC. Corporate Office 770.504.5004 Grand River Gathering, LLC. Rifle Office 970.440.1000 Mike Rose – Director, Engineering, Construction and Operations Office: 214.242.1964 Mobile: 214.926.6299 Floyd Alvey – Compression Supervisor Office: 970.440.1001 Mobile: 970.319.0357 Greg Gohn – Pipeline Supervisor Office: 970.440.1003 Mobile: 970.319.7506 Eric Stockbridge – Health, Safety, Env. and Regulatory Advisor Office: 214.462.7707 Mobile: 214.253.9849 * = this is a non-emergency number. Emergency calls should dial 911. Spill Response Contractor: Hyland Enterprises, Inc. Office: 970.625.8270 Spill/Release Information Form High Mesa Compressor Station Exact name, address, and location of the facility: Date and time of the discharge: Name, title and phone number of the person reporting the spill, the responsible party and the contact person: Source of the discharge: Type or description of material discharged: Estimated total quantity of the discharge: Estimated total quantity discharged as described in §112.1(b): Names of individuals and/or organizations that have been contacted: Bodies of water involved, the extent of actual and potential pollution or threat to surface water: A chronology of all occurred events including: a complete description of circumstances causing the release or spill, actions taken and explanations: A description of all impacted media: A description of all damages or injuries caused by the discharge: Actions being used to stop, remove, or mitigate the effects of the discharge, including disposal and treatment: Other appropriate information for the particular spill or release: Appendix C SPCC Plan Review/Amendment Documentation Five-Year Review Documentation In accordance with §112.5(b), this SPCC plan been reviewed to determine if more effective prevention and control technology is available to significantly reduce the likelihood of a discharge. Pursuant to §112.5(b) and by means of this certification, I attest that I have completed a review and evaluation of this SPCC plan for GRG, and as a result Will Will Not amend the plan. A Professional Engineer has reviewed technical amendments to the plan and certified the revised document. Signature, Authorized Facility Representative Date Name (Printed) Title SPCC Plan Amendment Log Date of Amendment General Description of Changes Page Numbers of Changes Name of Certifying PE Name of Management Reviewer Appendix D Facility Information .--' ,... NAP SCURCE: 7 .a M~UlE U.S.C3.8. TCI'CORAPIIC -{PARACKJlE ~RANCILE) SITE LOCATION: 8E NE 8ECIION 38, TOWNSHP7 80111H. RANGE 118 WEST J / PR()..IE¢TN0: 011-:tl3:t FACU..I!YLOCAT10N- OIWCI fUllER OAlliERINQ, U.C 1-0RA~=WN=BY~:=..;;O..;;M;;..P __ --1 HC3HMESAOOMPRES90RSTAT10N 0\0LSSON DATE: 2r.IG/12 OARF1EUH:ct.NTY, CIOI.CRAOO ASSOCIAU.S FIOLRE 1 - AU _'11E_......,. ~---- I I I I I I I I /1 /~ ... / 7 "~ / / ~ / ·" .. rr • _____ , .... -.- ) ·--IIM111 ·-IYIII - - 0 -------......... .... [I]. ---- ' ,. Ar e a H W 1 W 2 L 1 L 2 W 3 L 3 L 4 X S Depth Volume ID C o n t e n t s / D e s c r i p t i o n V o l u m e ( B B L ) D i a m e t e r ( F T ) I D M a te r i a l S h a p e ( F T ) ( F T ) ( F T ) ( F T ) ( F T ) ( F T ) ( F T ) ( F T ) ( F T ²) ( F T ³ ) ( B B L ) ( I N . ) ( B B L ) ( B B L ) 1 C o n d e n s a t e / P r o d . W a t e r 3 0 0 1 2 1 S t e e l O b l o n g 2 . 5 - - - - - - - - - - - - 2 5 . 0 5 3 . 0 2 8 . 0 1 1 3 . 0 4 2 , 9 7 7 5 3 0 2 . 2 3 8 . 9 5 0 2 C o n d e n s a t e / P r o d . W a t e r 3 0 0 1 2 1 S t e e l O b l o n g 2 . 5 - - - - - - - - - - - - 2 5 . 0 5 3 . 0 2 8 . 0 1 1 3 . 0 4 2 , 9 7 7 5 3 0 2 . 2 3 8 . 9 5 0 3 S l u g C a t c h e r 7 1 0 . 4 - - - N o n e N o n e 0 . 0 0 . 0 0 . 0 0 . 0 0 . 0 - - - - - - - -- 0 0 0 2 . 2 0 . 0 0 4 S e p a r a t o r T B D 2 E a r t h R e c t a n g u l a r 1 . 8 1 9 . 0 1 5 . 0 2 8 . 0 2 4 . 0 - - - - - - - - - 0 7 7 6 1 3 8 2 . 2 1 4 . 5 0 5 M e t h a n o l T a n k 1 2 3 S t e e l R o u n d 2 . 0 - - - - - - - - - - - - 9 . 5 9 . 5 0 . 0 0 1 4 2 2 5 2 . 2 2 . 3 0 6 S c r u b b e r V e s s e l 1 8 . 9 - - - N o n e N o n e 0 . 0 0 . 0 0 . 0 0 . 0 0 . 0 - - - - - - - - - 0 0 0 2 . 2 0 . 0 0 7 C o o l a n t 1 2 4 S t e e l R o u n d 2 . 0 - - - - - - - - - - - - 8 . 0 8 . 0 0 . 0 0 1 0 1 1 8 2.2 1.6 0 8 C o o l a n t 1 2 5 S t e e l R o u n d 2 . 0 - - - - - - - - - - - - 8 . 0 8 . 0 0 . 0 0 1 0 1 1 8 2.2 1.6 0 9 L u b r i c a t i n g O i l 2 4 6 F i b e r g l a s s R e c t a n g u l a r 2 . 0 6 . 5 6 . 5 1 3 .3 1 3 . 3 - - - - - - - - - 0 1 7 3 3 1 2 . 2 2 . 8 0 10 L u b r i c a t i n g O i l 2 4 7 F i b e r g l a s s R e c t a n g u l a r 2 . 0 6 . 5 6 . 5 1 3. 3 1 3 . 3 - - - - - - - - - 0 1 7 3 3 1 2 . 2 2 . 8 0 11 L u b r i c a t i n g O i l 2 4 8 S t e e l R e c t a n g u l a r 1 . 0 1 5 . 5 1 5 . 5 2 9 . 5 29 . 5 - - - - - - - - - 0 4 5 7 8 1 2 . 2 1 4 . 9 0 12 L u b r i c a t i n g O i l 2 4 8 S t e e l R e c t a n g u l a r 1 . 0 1 5 . 5 1 5 . 5 2 9 . 5 29 . 5 - - - - - - - - - 0 4 5 7 8 1 2 . 2 1 4 . 9 0 13 C o o l a n t 2 4 8 S t e e l R e c t a n g u l a r 1 . 0 1 5 . 5 1 5 . 5 2 9 . 5 2 9 . 5 - - - - -- - - - 0 4 5 7 8 1 2 . 2 1 4 . 9 0 14 C o m p r e s s o r E n g i n e ( x 9 ) 2 ( e a . ) - - - N o n e N o n e 0 . 0 0 . 0 0 . 0 0. 0 0 . 0 - - - - - - - - - 0 0 0 2 . 2 0 . 0 0 15 C o m p r e s s o r ( x 9 ) 2 ( e a . ) - - - N o n e N o n e 0 . 0 0 . 0 0 . 0 0 . 0 0 . 0 - -- - - - - - - 0 0 0 2 . 2 0 . 0 0 16 C o m p r e s s o r S c r u b b e r ( x 1 8 ) 1 . 5 ( e a . ) - - - N o n e N o n e 0 . 0 0 .0 0 . 0 0 . 0 0 . 0 - - - - - - - - - 0 0 0 2 . 2 0 . 0 0 (BBL) (%) 441 147 124 #VALUE! 23 191 16 136 16 136 28 117 28 117 67 277 Multiple Tank T NET CAPACITY Containment 1 Precipitation Freeboard Containment 8 Containment 2 Containment 3 Containment 4 Containment 5 Containment 6 Containment 7 La r g e s t V o l u m e T a n k / E q u i p m e n t C o n t a i n m e n t Re c t a n g u l a r C o n t a i n m e n t O b l o n g C o n t a i n m e n t G r o s s C a p a city LA R G E S T T A N K D E T A I L S CU R R E N T C O N T A I N M E N T D E T A I L S SE C O N D A R Y C O N T A I N M E N T C A L C U L A T I O N S SE C O N D A R Y C O N T A I N M E N T C A P A C I T Y C A L C U L A T I O N S HI G H M E S A C O M P R E S S O R S T A T I O N GR A N D R I V E R G A T H E R I N G , L L C . No t e s : H = C o n t a i n m e n t H e i g h t BB L = B a r r e l ( s ) W1 = C o n t a i n m e n t w i d t h a t t o p . GA L = G a l l o n ( s ) W2 = C o n t a i n m e n t w i d t h a t b o t t o m . FT ³ = C u b i c F e e t W3 = O v e r a l l c o n t a i n m e n t w i d t h ( f o r o b l o n g / r o u n d c o n t a i n m en t ) . FT = F e e t L1 = C o n t a i n m e n t l e n g t h a t t o p . IN = I n c h e s L2 = C o n t a i n m e n t l e n g t h a t b o t t o m . 1 F T ³ = 7 . 4 8 1 G a l l o n s L3 = O v e r a l l c o n t a i n m e n t l e n g t h ( f o r o b l o n g / r o u n d c o n t a i n me n t ) . 1 B a r r e l = 4 2 G a l l o n s L4 = S t r a i g h t s e c t i o n l e n g t h ( f o r o b l o n g / r o u n d c o n t a i n m e n t) . 1 B a r r e l = 5 . 6 C u b i c F e e t T = T o t a l C o n t a i n m e n t C a p a c i t y Ca l c u l a t i o n f o r r e c t a n g u l a r c o n t a i n m e n t : T = ( H /3 ) x [ ( W1 x L1 )+ ( W2 x L2 )+ S Q R T ( W1 x L1 x W2 x L2 )] Ca l c u l a t i o n f o r o b l o n g c o n t a i n m e n t : T = ( ( W3 ²x π ) / 4 ) x H +( W3 x L4 x H ) Pr e c i p i t a t i o n f r e e b o a r d d e p t h i s t h e 2 5 - y e a r , 2 4 - h r r ai n f a l l e v e n t p r e c i p i t a t i o n a m o u n t ( S o u r c e - N O A A A t l a s 2, V o l u m e I I ) Appendix E Inspection Procedures and Records Inspection Procedures and Records FACILITY NAME: HIGH MESA COMPRESSOR STATION FACILITY ADDRESS: SE NE SECTION 36 IN TOWNSHIP 7 SOUTH, RANGE 96 WEST IN GARFIELD COUNTY, COLORADO NEAR PARACHUTE, COLORADO REFERENCE: SECTION 7.16 OF SPCC PLAN WRITTEN PROCEDURES APPROVED BY: Signature Title Name (please type or print) Date Inspection Procedures and Records 1. Responsibilities These procedures establish the requirements for periodic inspections and tests for the oil storage vessels and oil-filled equipment listed at the High Mesa Compressor Station, to minimize the risk of a spill incident. The Compression Supervisor is responsible for the implementation of these procedures. Specifically, the Compression Supervisor is responsible for:  Conducting the inspections;  Producing documentation for deficiencies found during the inspections; and  Making certain that remediation or repair work is properly prioritized and completed in a timely manner. The Compression Supervisor may designate another personnel member to complete the inspections. Designated personnel will have the authority to commit the resources necessary to carry out a response, if warranted. Operating personnel at the High Mesa Compressor Station receive training to familiarize themselves with all aspects of the SPCC Plan, facility operations, the location and characteristics of materials handled at the facility, and the location of pertinent records within the facility. 2. Procedures The Compression Supervisor (or designee) will conduct an annual visual inspection of the oil storage vessels and oil-filled equipment identified in Section 7.5 of the SPCC Plan. The inspections will be documented using the attached inspection forms. The annual inspection includes a visual examination of exterior surfaces for leaks and other deficiencies of the vessel, supports, connected piping and valves and secondary containment. It also includes visual inspection and monitoring of any leak detection system or other monitoring or warning systems (e.g., level indic ation/alarm or interstitial space monitoring). If any inspection reveals a leak or equipment deficiency outside of normal operating conditions, corrective action must be taken promptly to eliminate the leak or deficiency. Deficiencies noted during the inspection are recorded as a work order. The inspector will complete the following: 1. Visually inspect exterior surfaces of storage vessels and oil-filled equipment, along with associated piping, valves and other appurtenances for: o Drip marks or droplets of f luid/stored materials o Discoloration on equipment or ground surfaces o Puddles of spilled or leaked material o Corrosion o Cracks o Localized dead vegetation. 2. Visually inspect vessel/equipment supports, foundations, and containment structures for excessive settlement, apparent structural weakness, cracks or other deficiencies that would allow tanks or secondary containment structures to fail or leak. 3. Inspect and monitor existing leak detection systems (for example, observation ports on double-bottom tanks), cathodic protection equipment and other warning systems such as alarms and level gauges. If, during the annual inspection, the inspector observes a spill of oil from any of the equipment the inspector shall immediately initiate the oil spill response procedures outlined in Appendix B of this SPCC Plan. Inspection Procedures and Records Secondary Containment Drainage Log Date and Time of Drainage Containment Area Drained (ID# or description) Appearance (visual, odor, etc.) Note: Do not discharge water containing any contaminant and/or free oil or an oil sheen. Approximate Quantity Removed (Gals) Method of Removal and Disposal Annual SPCC Inspection Report Field Name: Site Location: Date of Inspection: Any evidence of recent liquid spills to ground? (circle): Yes No If “Yes” describe equipment and location: Inspection Item Present (Y/N) Condition: Good/ Satisfactory/ or Requires Maintenance Notes and description of maintenance required/Other Comments Storage Tanks Secondary Containment Structures Treaters & Separators Aboveground Piping Valves & Fittings Supporting Foundations Field Drainage Conveyances Truck Load out Piping 55-gal Drums Berm Dimensions Check and Condition Other Equipment Vessels Other: Notes: Based upon my visual inspection of site conditions, this facility is in compliance with its SPCC plan or reported deficiencies of oil accumulations as described above have been reported and corrective actions taken as required by law. Inspector Printed Name: Inspector Signature: Inspection Report Sent to: Date: Appendix F Training Procedures and Records Training Procedures and Records Spill Prevention Training Outline FACILITY NAME: HIGH MESA COMPRESSOR STATION FACILITY ADDRESS: SE NE SECTION 36 IN TOWNSHIP 7 SOUTH, RANGE 96 WEST IN GARFIELD COUNTY, COLORADO NEAR PARACHUTE, COLORADO REFERENCE: SECTION 7.17 OF SPCC PLAN WRITTEN PROCEDURES APPROVED BY: Signature Title Name (please type or print) Date Training Procedures and Records Topics to be Covered in SPCC Training 1. Introduction/Training Roster 2. Facility Layout 3. General Facility Operations 4. Location of Oil Storage Areas a. Above Ground Storage Tanks b. Compressors/Separators/Scrubbers c. Lubricating Oil Containers 5. Facility SPCC Plan a. Physical Location of Plan b. Introduce/Review Contents of SPCC Plan i. General SPCC Requirements (§112.7) ii. Specific Requirements for Onshore Production Facilities (§112.9) 6. Operation of Oil-Filled Equipment and Containment Equipment a. Above Ground Storage Tanks i. Fill Procedures b. Compressors/Separators/Scrubbers i. Maintenance Procedures c. Lubricating Oil Containers i. Handling Procedures 7. Oil Spill/Discharge Response Procedures a. Appendix B of SPCC Plan 8. Known Oil Spill/Discharge Incidents at Facility in Past 12 Months 9. Applicable Rules and Regulations a. Federal Regulations i. 40 CFR 110: Discharge of Oil ii. 40 CFR 112: Oil Pollution Prevention b. State Regulations (CDPHE) c. Local (Garfield County LEPC) Training Procedures and Records Oil Discharge Prevention Briefings (Training) Roster INSTRUCTOR: DATE: EMPLOYEE TITLE SIGNATURE Fugitive Dust Control Plan Grand River Gathering LLC High Mesa Compressor Station OA Project No. 012-0732 826 21 ½ Road | Grand Junction, CO 81505 | TEL 970.263.7800 | FAX 970.263.7456 - 1 - Summit and Grand River Gathering, LLC Fugitive Dust Control Plan Piceance Basin Natural Gas Development Projects Piceance Unit Scope The scope of these guidelines is to outline some basic principles to minimize and control fugitive dust emissions during land development. Requirements Encana places the highest priority on the health and safety of our workforce and protection of our assets and the environment. Applicable Documents Department of Public Health and Environment Air Quality Control Commission Regulation 1 5CCR 1001-3 Quality These guidelines will be reviewed periodically and will be shared with employees and contractors to ensure that they have adequate knowledge to minimize fugitive dust emissions. 1.0 Introduction Land development activities, including clearing, excavating, and grading, release fugitive dust, a pollutant regulated by the Air Pollution Control Division (Division) at the Colorado Department of Public Health and Environment. However, small land development activities that are less than 25 contiguous acres and less than 6 months in duration do not need to report air emissions to the Division, but must use appropriate control measures to minimize the release of fugitive dust from the site. This Fugitive Dust Control Plan addresses how dust will be kept to a minimum at the Summit/Grand River Gathering’s Project sites. This plan focuses action on: 1. Identifying specific individual sources of fugitive dust. 2. Control options for unpaved roadways. 3. Control options for disturbed areas. 4. Control options for transport, storage and handling of bulk materials. 5. Contingency Plan for alternative action in the event that control strategies are not adequate, effective, or practicable. . - 2 - 2.0 Specific Sources Specific types of fugitive dust sources may appear to have negligible dust emissions, but when combined with other specific sources underway at the same time can create dust plumes that are visible beyond that which is appropriate for designated speeds and designs and may exceed nuisance emission limitation guidelines. It is important to consider all activities on the site together in determining compliance with federal, state, and local air quality regulations. Task: Provide field personnel and contractors with the information required to limit fugitive particulate matter (fugitive dust) from all specific sources to include: • Unpaved Roadways and traffic areas. • Construction activities including Earth Moving and excavation. • Bulk Material (i.e. gravel and soils). • Storage and handling of materials 3.0 Control Options for Unpaved Roadways Any owner or operator responsible for construction or maintenance of any (existing or new) unpaved roadway is required to use all available, practical methods to minimize dust emissions: Task: Provide guidelines for minimizing fugitive dust emissions from all specific sources on unpaved roadways and traffic areas: • Require that all passenger vehicles, construction equipment, and truck traffic obey the posted speed limits on all unpaved County roads to and from the project site. • Ensure that vehicle speeds on new and existing access roads on the project site do not exceed 15 miles per hour by posting speed limits along these roads. • Restrict vehicle traffic to existing roads by posting signs and/or providing the locations of allowable access routes to all field personnel and visitors. • Encourage carpooling to and from the project site to limit traffic on existing County roads. • Roads and well locations will be surfaced with compacted gravel to protect against wind erosion, to reduce the amount of fugitive dust generated by traffic and other activities, and to reduce carryout/trackout. • Use dust inhibitors (surfacing materials, water, or non-saline dust suppressants) on all unpaved collector, local, and resource roads to prevent fugitive dust problems (ensure that any dust suppressants used are appropriate for road conditions and will not comprom ise the safety of workers on the project site). • Restrict vehicular access during periods of inactivity using gates, fencing, and/or onsite security personnel. 4.0 Control Options for Disturbed Areas Disturbed areas include new roads, well pads, parking and staging areas, and materials storage areas that have been cleared of vegetation, leveled, or excavated. These areas are susceptible to wind erosion and are a major source of fugitive dust emissions that require the appropriate controls and dust mitigation methods. Note that specific sources are subject to change as project conditions change, and will require an evaluation of current control options to ensure effectiveness and practicality. - 3 - Task: Limit the adverse impacts of fugitive dust emissions through control measures and operational procedures designed so that no off-property transport emissions occur at the project site: • Ensure that land clearing, grading, earthmoving, and excavation activities are suspended when wind speeds exceed a sustained velocity of 20 miles per hour. • Surface all bare ground with gravel as soon as practicable after clearing, leveling, and grading. • Use dust inhibitors (surfacing materials, water, or non-saline dust suppressants) on all disturbed areas as necessary to prevent fugitive dust problems. • Identify the water source to be used for dust suppression, and ensure that contract water haulers are available when needed. • Reduce the amount of time between initially disturbing the soil and revegetating or other surface stabilization. • Apply vegetative or synthetic cover to topsoil and spoil piles as soon as practicable following stockpiling to prevent wind erosion and fugitive dust emissions. • Compact the soil on disturbed areas that will not be surfaced with gravel or revegetated immediately following construction. • Minimize surface disturbance to only that necessary for safe and efficient construction and operations. • Use vegetative mulch, reseeding, or other methods of surface stabilization on all areas adjoining development to include shoulders, borrow ditches, and berms if practical. • Restrict vehicular access during periods of inactivity using gates, fencing, and/or onsite security personnel. • Identify any new sources of fugitive dust emissions and evaluate and implement the appropriate control methods for that source. • Incorporate fugitive dust controls in all lands projects. 5.0 Control Options for Transport, Storage and Handling of Bulk Materials Transporting bulk materials, such as gravel and fill material, can result in off-property dust emissions and other impacts (i.e. broken windshields) over some distance if the appropriate control measures are not implemented. Storage and handling of bulk materials once they arrive at the project site also requires that controls are in place to ensure that these materials do not exceed regulated nuisance dust emissions. Task: Use control measures and operational procedures designed so that no off-property transport emissions occur along public roadways to and from the project site: • Enclose, cover, water, or otherwise treat loaded haul trucks to minimize the loss of material to wind and spillage. • Require that all contract haul vehicles obey the posted speed limits on all public roadways to and from the project site. • Ensure that haul truck speeds on new and existing access roads on the project site do not exceed 15 miles per hour by posting speed limits along these roads. • Restrict haul trucks to existing roads and pad locations. • Do not attempt to load/unload haul trucks when wind speeds exceed a sustained velocity of 20 miles per hour. • Promptly remove dust-forming material from haul trucks to minimize entrainment of fugitive particulate matter. • Avoid storage and handling of bulk material any more than necessary to complete construction. • Use covers, enclosures, wind breaks, or watering to prevent fugitive dust emissions from material storage piles • Restrict access to construction areas and storage piles during periods of inactivity using gates, fencing, and/or onsite security personnel. - 4 - 6.0 Contingency Planning Alternative control measures may become necessary in the event that the current dust control strategy is not adequate or effective for conditions. An alternative plan may require addition planning, permitting, or other regulatory compliance requirements to implement. In this case, the current activities at the project site would necessarily be suspended until such time as the alternate dust control methods could be put into place. Task: Implement alternative action to fugitive dust control plan and to each specific source if deemed necessary to comply with federal, state, and local air quality regulations: • Provide field personnel and contractors with contact information for responsible individuals in cases where control measures need to be escalated in response to weather conditions (i.e. increased windiness). • Use an appropriate alternative dust inhibitor if water does not prove to be effective under normal circumstances, and obtain all regulatory permissions for the use of chemical suppressants on the project site. • Use vegetative blankets or other methods for cover of topsoil, spoil, and bulk material storage piles if immediate cover becomes necessary. • Attempt to locate alternative sources of bulk material closer to the project site if fugitive dust emissions or other im pacts from contract haul trucks on state or federal highways become an issue with public safety or regulatory compliance. - 5 - Appendix A Contacts - 6 - SUMMIT/GRAND RIVER GATHERING PERSONNEL Name Title Office Cell - 7 - CONTRACT CONSTRUCTION