Document 2zN35n38m7BnV7rLmdgVw63b

U.S. ENVIRONMENTAL PROTECTION AGENCY SPCC FIELD INSPECTION AND PLAN REVIEW CHECKLIST ONSHORE OIL DRILLING, PRODUCTION AND WORKOVER FACILITIES Overview of the Checklist This checklist is designed to assist EPA inspectors in conducting a thorough and nationally consistent inspection of a facility's compliance with the Spill Prevention, Control, and Countermeasure (SPCC) rule at 40 CFR part 112. It is a required tool to help federal inspectors (or their contractors) record observations for the site inspection and review of the SPCC Plan. While the checklist is meant to be comprehensive, the inspector should always refer to the SPCC rule in its entirety, the SPCC Regional Inspector Guidance Document, and other relevant guidance for evaluating compliance. This checklist must be completed in order for an inspection to count toward an agency measure (i.e., OEM inspection measures or GPRA). The completed checklist and supporting documentation (i.e. photo logs or additional notes) serve as the inspection report. This checklist addresses requirements for onshore oil drilling, production and workover facilities (including Tier II Qualified Facilities that meet the eligibility criteria set forth in 112.3(g)(2)). Qualified facilities must meet the rule requirements in 112.6 and other applicable sections specified in 112.6, except for deviations that provide environmental equivalence and secondary containment impracticability determinations as allowed under 112.6. Separate and standalone checklists address the requirements for: All other onshore facilities including Tier II Qualified Facilities (i.e., those facilities not involved in oil drilling, production and workover activities); Offshore oil drilling, production and workover facilities; and Tier I Qualified Facilities (for facilities that meet the eligibility criteria defined in 112.3(g)(1)). The checklist is organized according to the SPCC rule. Each item in the checklist identifies the relevant section and paragraph in 40 CFR part 112 where that requirement is stated. Sections 112.1 through 112.5 specify the applicability of the rule and requirements for the preparation, implementation, and amendment of SPCC Plans. For these sections, the checklist includes data fields to be completed, as well as several questions with "yes," "no" "NA" answers. Section 112.6 includes requirements for qualified facilities. These provisions are addressed in Attachment D. Section 112.7 includes general requirements that apply to all facilities (unless otherwise excluded). Section 112.9 specifies spill prevention, control, and countermeasures requirements for onshore oil drilling, production and workover facilities Section 112.10 specifies spill prevention, control, and countermeasures requirements for onshore oil drilling, production and workover facilities. The inspector needs to evaluate whether the requirement is addressed adequately or inadequately in the SPCC Plan and whether it is implemented adequately in the field (either by field observation or record review). For the SPCC Plan and implementation in the field, if a requirement is addressed adequately, mark the "Yes" box in the appropriate column. If a requirement is not addressed adequately, mark the "No" box. If a requirement does not apply to the particular facility or the question asked is not appropriate for the facility, mark as "NA". Discrepancies or descriptions of inspector interpretation of "No" vs. "NA" may be documented in the comments box subsequent to each section. If a provision of the rule applies only to the SPCC Plan, the "Field" column is shaded. Space is provided throughout the checklist to record comments. Additional space is available as Attachment E at the end of the checklist. Comments should remain factual and support the evaluation of compliance. Attachments Attachment A is for recording information about containers and other locations at the facility that require secondary containment. Attachment B is a checklist for documentation of the tests and inspections the facility operator is required to keep with the SPCC Plan. Attachment C is a checklist for oil spill contingency plans following 40 CFR 109. Unless a facility has submitted a Facility Response Plan (FRP) under 40 CFR 112.20, a contingency plan following 40 CFR 109 is required if a facility determines that secondary containment is impracticable as provided in 40 CFR 112.7(d). The same requirement for an oil spill contingency plan applies to the owner or operator of a facility with qualified oil-filled operational equipment that chooses to implement alternative requirements instead of general secondary containment requirements as provided in 40 CFR 112.7(k). Attachment D is a checklist for Tier II Qualified Facilities. Attachment E is for recording additional comments or notes. Attachment F is for recording information about photos. Onshore Oil Drilling, Production and Workover Facilities Page 1 of 14 June 2014 FACILITY INFORMATION FACILITY NAME: Greenwood Resources, LLC - McGilvray A Lease LATITUDE: 38.054895 LONGITUDE: -96.213461 GPS DATUM: WGS84 Section/Township/Range: S17-T23S-R11E FRS#/OIL DATABASE ID: R7-KS-00447 ICIS#: ADDRESS: T Road & 310th Street CITY: Hamilton STATE: Kansas ZIP: 66853 COUNTY: Greenwood MAILING ADDRESS (IF DIFFERENT FROM FACILITY ADDRESS - IF NOT, PRINT "SAME"): PO Box 847 10387 NE St Road CITY: Pratt STATE: Kansas ZIP: 67124 COUNTY: Pratt TELEPHONE: 620-700-0005 FACILITY CONTACT NAME/TITLE: Kenneth Gates, President OWNER NAME: Greenwood Resources, LLC OWNER ADDRESS: PO Box 847 10387 NE St Road CITY: Pratt STATE: Kansas ZIP: 67124 COUNTY: Pratt TELEPHONE: 620-672-2531 FAX: EMAIL: loripwsi@gmail.com FACILITY OPERATOR NAME (IF DIFFERENT FROM OWNER - IF NOT, PRINT "SAME"): SAME OPERATOR ADDRESS: CITY: STATE: ZIP: COUNTY: TELEPHONE: 620-672-2531 OPERATOR CONTACT NAME/TITLE: Don Soule FACILITY TYPE: Oil Production Lease NAICS CODE: 211111 HOURS PER DAY FACILITY ATTENDED: 1 hour TOTAL FACILITY CAPACITY: 104,370 gallons TYPE(S) OF OIL STORED: Crude oil, produced water LOCATED IN INDIAN COUNTRY? YES NO RESERVATION NAME: INSPECTION/PLAN REVIEW INFORMATION PLAN REVIEW DATE: 2/22/24 REVIEWER NAME: William Blair INSPECTION DATE: 2/14/24 TIME: 12:15PM ACTIVITY ID NO: LEAD INSPECTOR: William Blair OTHER INSPECTOR(S): Abigail Sroufe, Abigail Widiker INSPECTOR ACKNOWLEDGMENT I performed an SPCC inspection at the facility specified above. INSPECTOR SIGNATURE: Digitally signed by WILLIAM WILLIAM BLAIR BLAIR Date: 2024.03.22 11:08:20 -05'00' Digitally signed by Whisnant, SUPERVISOR REVIEW/SIGNATURE: Whisnant, Amber Amber Date: 2024.03.22 16:04:25 -05'00' DATE: 3/22/24 DATE: Onshore Oil Drilling, Production and Workover Facilities Page 2 of 14 June 2014 SPCC GENERAL APPLICABILITY--40 CFR 112.1 IS THE FACILITY REGULATED UNDER 40 CFR part 112? The completely buried oil storage capacity is over 42,000 U.S. gallons, OR the aggregate aboveground oil storage capacity is over 1,320 U.S. gallons AND The facility is a non-transportation-related facility engaged in drilling, producing, gathering, storing, processing, refining, transferring, distributing, using, or consuming oil and oil products, which due to its location could reasonably be expected to discharge oil into or upon the navigable waters of the United States Yes No Yes No AFFECTED WATERWAY(S): Onion Creek & Willow Creek DISTANCE: 50 feet FLOW PATH TO WATERWAY: Discharge from tank battery and flow lines from this lease flow to Onion Creek, which leads to Willow Creek; or discharges directly flow to Willow Creek. Note: The following storage capacity is not considered in determining applicability of SPCC requirements: Equipment subject to the authority of the U.S. Department of Transportation, U.S. Department of the Interior, or Minerals Management Service, as defined in Memoranda of Understanding dated November 24, 1971, and November 8, 1993; Tank trucks that return to an otherwise regulated facility that contain only residual amounts of oil (EPA Policy letter) Containers smaller than 55 U.S. gallons; Permanently closed containers (as defined in 112.2); Motive power containers (as defined in 112.2); Hot-mix asphalt or any hot-mix asphalt containers; Completely buried tanks subject to all the technical requirements of 40 CFR part 280 or a state program approved under 40 CFR part 281; Heating oil containers used solely at a single-family residence; Underground oil storage tanks deferred under 40 CFR part 280 that supply emergency diesel generators at a nuclear power generation facility licensed by the Nuclear Regulatory Commission (NRC) and subject to any NRC provision regarding design and quality criteria, including but not limited to CFR part 50; Any facility or part thereof used exclusively for wastewater treatment (production, recovery or recycling of oil is not considered wastewater treatment); (This does not include other oil containers located at a wastewater treatment facility, such as generator tanks or transformers) Pesticide application equipment and related mix containers; Any milk and milk product container and associated piping and appurtenances; and Intra-facility gathering lines subject to the regulatory requirements of 49 CFR part 192 or 195. Does the facility have an SPCC Plan? Yes No FACILITY RESPONSE PLAN (FRP) APPLICABILITY--40 CFR 112.20(f) A non-transportation related onshore facility is required to prepare and implement an FRP as outlined in 40 CFR 112.20 if: The facility transfers oil over water to or from vessels and has a total oil storage capacity greater than or equal to 42,000 U.S. gallons, OR The facility has a total oil storage capacity of at least 1 million U.S. gallons, AND at least one of the following is true: The facility does not have secondary containment sufficiently large to contain the capacity of the largest aboveground tank plus sufficient freeboard for precipitation. The facility is located at a distance such that a discharge could cause injury to fish and wildlife and sensitive environments. The facility is located such that a discharge would shut down a public drinking water intake. The facility has had a reportable discharge greater than or equal to 10,000 U.S. gallons in the past 5 years. Facility has FRP: Yes No NA Facility has a completed and signed copy of Appendix C, Attachment C-II, "Certification of the Applicability of the Substantial Harm Criteria." Comments: Substantial Harm Criteria form not signed. FRP Number: Yes No Onshore Oil Drilling, Production and Workover Facilities Page 3 of 14 June 2014 SPCC TIER II QUALIFIED FACILITY APPLICABILITY--40 CFR 112.3(g)(2) The aggregate aboveground oil storage capacity is 10,000 U.S. gallons or less AND In the three years prior to the SPCC Plan self-certification date, or since becoming subject to the rule (if the facility has been in operation for less than three years), the facility has NOT had: Yes No A single discharge as described in 112.1(b) exceeding 1,000 U.S. gallons, OR Two discharges as described in 112.1(b) each exceeding 42 U.S. gallons within any twelve-month period1 Yes No Yes No IF YES TO ALL OF THE ABOVE, THEN THE FACILITY IS A TIER II QUALIFIED FACILITY2 SEE ATTACHMENT D FOR TIER II QUALIFIED FACILITY CHECKLIST REQUIREMENTS FOR PREPARATION AND IMPLEMENTATION OF A SPCC PLAN--40 CFR 112.3 Date facility began operations: 1970 Date of initial SPCC Plan preparation: Current Plan version (date/number): 112.3(a) For drilling, production or workover facilities, including mobile or portable facilities, that are offshore or have an offshore component; or facilities required to have and submit a FRP: In operation on or prior to November 10, 2010: Plan prepared and/or amended and fully implemented by November 10, 2010 Facilities beginning operation after November 10, 2010: o Plan prepared and fully implemented before drilling and workover facilities begin operations; or o Plan prepared and fully implemented within six months after oil production facilities begin operations For all other drilling, production or workover facilities, including mobile or portable facilities: In operation on or prior to November 10, 2011: Plan prepared and/or amended and fully implemented by November 10, 2011 Facilities beginning operation after November 10, 2011: o Plan prepared and fully implemented before drilling and workover facilities begin operations; or o Plan prepared and fully implemented within six months after oil production facilities begin operations Unknown Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA 112.3(d) Plan is certified by a registered Professional Engineer (PE) and includes statements that the PE attests: PE is familiar with the requirements of 40 CFR part 112 PE or agent has visited and examined the facility Plan is prepared in accordance with good engineering practice including consideration of applicable industry standards and the requirements of 40 CFR part 112 Procedures for required inspections and testing have been established Plan is adequate for the facility For produced water containers subject to 112.9(c)(6), any procedure to minimize the amount of free-phase oil is designed to reduce the accumulation of free-phase oil and the procedures and frequency for required inspections, maintenance and testing have been established and are described in the Plan, if applicable Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA PE Name: Gary Reed License No.: 7168 State: Kansas Date of certification: 112.3(e)(1) Plan is available onsite if attended at least 4 hours per day. If facility is unattended, Plan is available at the nearest field office. (Please note nearest field office contact information in comments section below.) Yes No NA Comments: PE did not attest to all required statements for the plan, no date for the plan is included, and no PE stamp visible. 1 Oil discharges that result from natural disasters, acts of war, or terrorism are not included in this determination. The gallon amount(s) specified (either 1,000 or 42) refers to the amount of oil that actually reaches navigable waters or adjoining shorelines not the total amount of oil spilled. The entire volume of the discharge is oil for this determination. 2 An owner/operator who self-certifies a Tier II SPCC Plan may not include any environmentally equivalent alternatives or secondary containment impracticability determinations unless reviewed and certified by a PE. Onshore Oil Drilling, Production and Workover Facilities Page 4 of 14 June 2014 AMENDMENT OF SPCC PLAN BY REGIONAL ADMINISTRATOR (RA)--40 CFR 112.4 112.4(a),(c) Has the facility discharged more than 1,000 U.S. gallons of oil in a single reportable discharge or more than 42 U.S. gallons in each of two reportable discharges in any 12-month period?3 If YES Was information submitted to the RA as required in 112.4(a)?4 Was information submitted to the appropriate agency or agencies in charge of oil pollution control activities in the State in which the facility is located112.4(c) Date(s) and volume(s) of reportable discharges(s) under this section: _____________________________________________________________ Were the discharges reported to the NRC5? 112.4(d),(e) Have changes required by the RA been implemented in the Plan and/or facility? Comments: Spill reported to NRC (1391171) and Kansas agencies on 02/09/2024. Yes No Yes No NA Yes No NA Yes No Yes No NA AMENDMENT OF SPCC PLAN BY THE OWNER OR OPERATOR--40 CFR 112.5 112.5(a) Has there been a change at the facility that materially affects the potential for a discharge described in 112.1(b)? If YES Was the Plan amended within six months of the change? Were amendments implemented within six months of any Plan amendment? 112.5(b) Review and evaluation of the Plan completed at least once every 5 years? Following Plan review, was Plan amended within six months to include more effective prevention and control technology that has been field-proven to significantly reduce the likelihood of a discharge described in 112.1(b)? Amendments implemented within six months of any Plan amendment? Five year Plan review and evaluation documented? 112.5(c) Professional Engineer certification of any technical Plan amendments in accordance with all applicable requirements of 112.3(d) [Except for self-certified Plans] Yes No Yes No Yes No Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Name: License No.: State: Date of certification: Reason for amendment: Plan recommended berm walls be built to a minimum 29" height for secondary containment around the tank farm. Comments: I observed eroded berm walls and overgrown vegetation within sized secondary containment around the tank battery. 3 A reportable discharge is a discharge as described in 112.1(b)(see 40 CFR part 110). The gallon amount(s) specified (either 1,000 or 42) refers to the amount of oil that actually reaches navigable waters or adjoining shorelines not the total amount of oil spilled. The entire volume of the discharge is oil for this determination 4 Triggering this threshold may disqualify the facility from meeting the Qualified Facility criteria if it occurred in the three years prior to self-certification 5 Inspector Note-Confirm any spills identified above were reported to NRC Onshore Oil Drilling, Production and Workover Facilities Page 5 of 14 June 2014 GENERAL SPCC REQUIREMENTS--40 CFR 112.7 Management approval at a level of authority to commit the necessary resources to fully implement the Plan6 Plan follows sequence of the rule or is an equivalent Plan meeting all applicable rule requirements and includes a cross-reference of provisions If Plan calls for facilities, procedures, methods, or equipment not yet fully operational, details of their installation and start-up are discussed (Note: Relevant for inspection evaluation and testing baselines.) 112.7(a)(2) If YES The Plan includes deviations from the requirements of 112.7(g), (h)(2) and (3), and (i) and applicable subparts B and C of the rule, except the secondary containment requirements in 112.7(c) and (h)(1), 112.9(c)(2), 112.9(d)(3), and 112.10(c) The Plan states reasons for nonconformance Alternative measures described in detail and provide equivalent environmental protection (Note: Inspector should document if the environmental equivalence is implemented in the field, in accordance with the Plan's description) Describe each deviation and reasons for nonconformance: PLAN Yes No Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA FIELD Yes No NA 6 May be part of the Plan or demonstrated elsewhere. Onshore Oil Drilling, Production and Workover Facilities Page 6 of 14 June 2014 PLAN FIELD 112.7(a)(3) Plan describes physical layout of facility and includes a diagram7 that identifies: Location and contents of all regulated fixed oil storage containers Storage areas where mobile or portable containers are located Completely buried tanks otherwise exempt from the SPCC requirements (marked as "exempt") Transfer stations Connecting pipes, including intra-facility gathering lines that are otherwise exempt from the requirements of this part under 112.1(d)(11) Yes No Yes No Plan addresses each of the following: (i) For each fixed container, type of oil and storage capacity (see Attachment A of this checklist). For mobile or portable containers, type of oil and storage capacity for each container or an estimate of the potential number of mobile or portable containers, the types of oil, and anticipated storage capacities (ii) Discharge prevention measures, including procedures for routine handling of products (loading, unloading, and facility transfers, etc.) (iii) Discharge or drainage controls, such as secondary containment around containers, and other structures, equipment, and procedures for the control of a discharge (iv) Countermeasures for discharge discovery, response, and cleanup (both facility's and contractor's resources) (v) Methods of disposal of recovered materials in accordance with applicable legal requirements (vi) Contact list and phone numbers for the facility response coordinator, National Response Center, cleanup contractors with an agreement for response , and all Federal, State, and local agencies who must be contacted in the case of a discharge as described in 112.1(b) Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No Yes No 112.7(a)(4) Does not apply if the facility has submitted an FRP under 112.20: Yes No NA Plan includes information and procedures that enable a person reporting an oil discharge as described in 112.1(b) to relate information on the: Exact address or location and phone number of the facility; Date and time of the discharge; Type of material discharged; Description of all affected media; Cause of the discharge; Damages or injuries caused by the discharge; Estimates of the total quantity discharged; Estimates of the quantity discharged as described in 112.1(b); Actions being used to stop, remove, and mitigate the effects of the discharge; Whether an evacuation may be needed; and Source of the discharge; Names of individuals and/or organizations who have also been contacted. 112.7(a)(5) Does not apply if the facility has submitted a FRP under 112.20: Plan organized so that portions describing procedures to be used when a discharge occurs will be readily usable in an emergency Yes No NA 112.7(b) Plan includes a prediction of the direction, rate of flow, and total quantity of oil that could be discharged for each type of major equipment failure where experience indicates a reasonable potential for equipment failure Yes No NA Comments: The plan should be revised to include all wellheads, flowlines, and mobile or portable containers across the entire facility. 7 Note in comments any discrepancies between the facility diagram, the description of the physical layout of facility, and what is observed in the field Onshore Oil Drilling, Production and Workover Facilities Page 7 of 14 June 2014 PLAN FIELD 112.7(c) Appropriate containment and/or diversionary structures or equipment are provided to prevent a discharge as described in 112.1(b), except as provided in 112.7(k) of this section for certain qualified operational equipment and 112.9(d)(3) for certain flowlines and intra-facility gathering lines at an oil production facility. The entire containment system, including walls and floors, are capable of containing oil and are constructed to prevent escape of a discharge from the containment system before cleanup occurs. The method, design, and capacity for secondary containment address the typical failure mode and the most likely quantity of oil that would be discharged. See Attachment A of this checklist. For onshore facilities, one of the following or its equivalent: Dikes, berms, or retaining walls sufficiently Weirs, booms or other barriers, impervious to contain oil, Spill diversion ponds, Curbing or drip pans, Retention ponds, or Sumps and collection systems, Sorbent materials. Culverting, gutters or other drainage systems, Identify which of the following are present at the facility and if appropriate containment and/or diversionary structures or equipment are provided as described above: Bulk storage containers Yes No NA Yes No NA Mobile/portable containers Yes No NA Yes No NA Oil-filled operational equipment (as defined in 112.2) Yes No NA Yes No NA Other oil-filled equipment (i.e., manufacturing equipment) Yes No NA Yes No NA Piping and related appurtenances Yes No NA Yes No NA Mobile refuelers of non-transportation-related tank cars Yes No NA Yes No NA Transfer areas, equipment and activities Yes No NA Yes No NA Identify any other equipment or activities that are not listed above: _________________________________________ Yes No NA Yes No NA 112.7(d) Secondary containment for one (or more) of the following provisions is determined to be impracticable: Yes No General secondary containment 112.7(c) Loading/unloading rack 112.7(h)(1) Bulk storage containers 112.8(c)(2)/112.12(c)(2) Mobile/portable containers112.8(c)(11)/112.12 (c)(11) If YES The impracticability of secondary containment is clearly demonstrated and described in the Plan For bulk storage containers,8 periodic integrity testing of containers and integrity and leak testing of the associated valves and piping is conducted Yes No NA Yes No NA Yes No NA Yes No NA (Does not apply if the facility has submitted a FRP under 112.20): Contingency Plan following the provisions of 40 CFR part 109 is provided (see Attachment C of this checklist) AND Written commitment of manpower, equipment, and materials required to expeditiously control and remove any quantity of oil discharged that may be harmful Yes No NA Yes No NA Yes No NA Comments: The plan should be revised to describe how secondary containment is provided for oil-filled operational equipment, piping and appurtenances, and transfer areas. The plan does not describe the general containment provided for the production wellheads (OFOE) and associated aboveground flowlines. Secondary containment is impracticable for buried flowlines, although, no claim of impracticability is made in the SPCC Plan. 8 These additional requirements apply only to bulk storage containers, when an impracticability determination has been made by the PE Onshore Oil Drilling, Production and Workover Facilities Page 8 of 14 June 2014 112.7(e) 112.7(f) (1) (2) (3) 112.7(h) PLAN FIELD Inspections and tests conducted in accordance with written procedures Record of inspections or tests signed by supervisor or inspector Kept with Plan for at least 3 years (see Attachment B of this checklist)9 Yes No Yes No Yes No Yes No Yes No Yes No Personnel, training, and oil discharge prevention procedures Training of oil-handling personnel in operation and maintenance of equipment to prevent discharges; discharge procedure protocols; applicable pollution control laws, rules, and regulations; general facility operations; and contents of SPCC Plan Person designated as accountable for discharge prevention at the facility and reports to facility management Discharge prevention briefings conducted at least once a year for oil handling personnel to assure adequate understanding of the Plan. Briefings highlight and describe known discharges as described in 112.1(b) or failures, malfunctioning components, and any recently developed precautionary measures Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Tank car and tank truck loading/unloading rack10 is present at the facility Yes No Loading/unloading rack means a fixed structure (such as a platform, gangway) necessary for loading or unloading a tank truck or tank car, which is located at a facility subject to the requirements of this part. A loading/unloading rack includes a loading or unloading arm, and may include any combination of the following: piping assemblages, valves, pumps, shut-off devices, overfill sensors, or personnel safety devices. If YES (1) (2) (3) Does loading/unloading rack drainage flow to catchment basin or treatment facility designed to handle discharges or use a quick drainage system? Containment system holds at least the maximum capacity of the largest single compartment of a tank car/truck loaded/unloaded at the facility An interlocked warning light or physical barriers, warning signs, wheel chocks, or vehicle brake interlock system in the area adjacent to the loading or unloading rack to prevent vehicles from departing before complete disconnection of flexible or fixed oil transfer lines Lower-most drains and all outlets on tank cars/trucks inspected prior to filling/departure, and, if necessary ensure that they are tightened, adjusted, or replaced to prevent liquid discharge while in transit Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Comments: Mr. Soule told me tanks are manually gauged daily. Mr. Soule told me tanks, pipes, appurtenances, transfer areas, stuffing boxes, etc. are visually inspected daily and maintenance is provided on an "as needed" basis. In the field I observed oil discharges at the transfer points for tanks 1, 2, 3, 4, 5, 6, 7, 8, 9, and 12 and the wellhead that transfers to tank 1. 9 Records of inspections and tests kept under usual and customary business practices will suffice 10 Note that a tank car/truck loading/unloading rack must be present for 112.7(h) to apply Onshore Oil Drilling, Production and Workover Facilities Page 9 of 14 June 2014 112.7(i) 112.7(j) 112.7(k) If YES 112.7(k) PLAN FIELD Brittle fracture evaluation of field-constructed aboveground containers is conducted after tank repair, alteration, reconstruction, or change in service that might affect the risk of a discharge or after a discharge/failure due to brittle fracture or other catastrophe, and appropriate action taken as necessary (applies to only fieldconstructed aboveground containers in production service, drilling, and workover service) Yes No NA Yes No NA Discussion of conformance with applicable more stringent State rules, regulations, and guidelines and other effective discharge prevention and containment procedures listed in 40 CFR part 112 Yes No NA Qualified oil-filled operational equipment is present at the facility11 Yes No Oil-filled operational equipment means equipment that includes an oil storage container (or multiple containers) in which the oil is present solely to support the function of the apparatus or the device. Oil-filled operational equipment is not considered a bulk storage container, and does not include oil-filled manufacturing equipment (flow-through process). Examples of oil-filled operational equipment include, but are not limited to, hydraulic systems, lubricating systems (e.g. , those for pumps, compressors and other rotating equipment, including pumpjack lubrication systems), gear boxes, machining coolant systems, heat transfer systems, transformers, circuit breakers, electrical switches, and other systems containing oil solely to enable the operation of the device. Check which apply: Secondary Containment provided in accordance with 112.7(c) Alternative measure described below (confirm eligibility) Qualified Oil-Filled Operational Equipment Has a single reportable discharge as described in 112.1(b) from any oil-filled operational equipment exceeding 1,000 U.S. gallons occurred within the three years prior to Plan certification date? Have two reportable discharges as described in 112.1(b) from any oil-filled operational equipment each exceeding 42 U.S. gallons occurred within any 12-month period within the three years prior to Plan certification date?12 Yes No NA Yes No NA If YES for either, secondary containment in accordance with 112.7(c) is required Facility procedure for inspections or monitoring program to detect equipment failure and/or a discharge is established and documented Does not apply if the facility has submitted a FRP under 112.20: Contingency plan following 40 CFR part 109 (see Attachment C of this checklist) is provided in Plan AND Written commitment of manpower, equipment, and materials required to expeditiously control and remove any quantity of oil discharged that may be harmful is provided in Plan Yes No NA Yes No NA Yes No NA Yes No NA Comments: Plan should be revised to include a discussion on qualified oil-filled operational equipment and secondary containment provided for them (i.e., wellheads, etc.). 11 This provision does not apply to oil-filled manufacturing equipment (flow-through process) 12 Oil discharges that result from natural disasters, acts of war, or terrorism are not included in this determination. The gallon amount(s) specified (either 1,000 or 42) refers to the amount of oil that actually reaches navigable waters or adjoining shorelines not the total amount of oil spilled. The entire volume of the discharge is oil for this determination. Onshore Oil Drilling, Production and Workover Facilities Page 10 of 14 June 2014 ONSHORE OIL PRODUCTION FACILITIES--40 CFR 112.9 NA PLAN FIELD (Drilling and workover facilities are excluded from the requirements of 112.9) Production facility means all structures (including but not limited to wells, platforms, or storage facilities), piping (including but not limited to flowlines or intra-facility gathering lines), or equipment (including but not limited to workover equipment, separation equipment, or auxiliary non-transportationrelated equipment) used in the production, extraction, recovery, lifting, stabilization, separation or treating of oil (including condensate), or associated storage or measurement, and is located in an oil or gas field, at a facility. This definition governs whether such structures, piping, or equipment are subject to a specific section of this part. 112.9(b) Oil Production Facility Drainage (1) At tank batteries, separation and treating areas where there is a reasonable possibility of a discharge as described in 112.1(b), drains for dikes or equivalent measures are closed and sealed except when draining uncontaminated rainwater. Accumulated oil on the rainwater is removed and then returned to storage or disposed of in accordance with legally approved methods Prior to drainage, diked area inspected and action taken as provided below: 112.8(c)(3)(ii) - Retained rainwater is inspected to ensure that its presence will not cause a discharge as described in 112.1(b) 112.8(c)(3)(iii) - Bypass valve opened and resealed under responsible supervision 112.8(c)(3)(iv) - Adequate records of drainage are kept; for example, records required under permits issued in accordance with 122.41(j)(2) and (m)(3) Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA (2) Field drainage systems (e.g., drainage ditches or road ditches) and oil traps, sumps, or skimmers inspected at regularly scheduled intervals for oil, and accumulations of oil promptly removed Yes No NA Yes No NA 112.9(c) Oil Production Facility Bulk Storage Containers Bulk storage container means any container used to store oil. These containers are used for purposes including, but not limited to, the storage of oil prior to use, while being used, or prior to further distribution in commerce. Oil-filled electrical, operating, or manufacturing equipment is not a bulk storage container. (1) Containers materials and construction are compatible with material stored and conditions of storage such as pressure and temperature Yes No NA Yes No NA (2) Except as allowed for flow-through process vessels in 112.9(c)(5) and produced water containers in 112.9(c)(6), secondary containment provided for all tank battery, separation and treating facilities sized to hold the capacity of largest single container and sufficient freeboard for precipitation. Drainage from undiked area safely confined in a catchment basin or holding pond. Yes No NA Yes No NA Yes No NA Yes No NA (3) Except as allowed for flow-through process vessels in 112.9(c)(5) and produced water containers in 112.9(c)(6), periodically and upon a regular schedule, visually inspect containers for deterioration and maintenance needs, including foundation and supports of each container on or above the surface of the ground Yes No NA Yes No NA (4) New and old tank batteries engineered/updated in accordance Yes No NA Yes No NA with good engineering practices to prevent discharges including at least one of the following: Adequate container capacity to prevent overfill if a Adequate vacuum protection to prevent container collapse; or pumper/gauger is delayed in making regularly scheduled rounds; Overflow equalizing lines between containers so that a full container can overflow to an adjacent container; High level sensors to generate and transmit an alarm to the computer where the facility is subject to a computer production control system Comments: In the field I observed that the tank farm had inadequate sized secondary containment, the earthen berm was deteriorated and had overgrown vegetation on the berm walls and within secondary containment. Onshore Oil Drilling, Production and Workover Facilities Page 11 of 14 June 2014 (5) (i) (ii) (iii) (iv) (6) (i) (ii) (iii) (iv) (v) Comments: PLAN FIELD Flow-through Process Vessels. Alternate requirements in lieu of sized secondary containment required in (c)(2) and requirements in (c)(3) above for facilities with flow-through process vessels: Flow-through process vessels and associated components (e.g. dump valves) are periodically and on a regular schedule visually inspected and/or tested for leaks, corrosion, or other conditions that could lead to a discharge as described in 112.1(b) Yes No NA Yes No NA Corrective actions or repairs have been made to flow-through process vessels and any associated components as indicated by regularly scheduled visual inspections, tests, or evidence of an oil discharge Yes No NA Yes No NA Oil removed or other actions initiated to promptly stabilize and remediate any accumulation of oil discharges associated with the produced water container Yes No NA Yes No NA All flow-through process vessels comply with 112.9(c)(2) and (c)(3) within six months of any flow-through process vessel Yes No NA Yes No NA discharge of more than 1,000 U.S. gallons of oil in a single discharge as described in 112.1(b) or discharges of more than 42 U.S. gallons of oil in each of two discharges as described in 112.1(b) within any twelve month period.13 Produced Water Containers. Alternate requirements in lieu of sized secondary containment required in (c)(2) and requirements in (c)(3) above for facilities with produced water containers: A procedure is implemented on a regular schedule for each produced water container that is designed to separate the freephase oil that accumulates on the surface of the produced water. A description is included in the Plan of the procedures, frequency, and amount of free-phase oil expected to be maintained inside the container; PE certifies in accordance with 112.3(d)(1)(vi); Records of such events are maintained in accordance with 112.7(e). Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA If this procedure is not implemented as described in the Plan or no records are maintained, then facility owner/operator must comply with 112.9(c)(2) and (c)(3). Each produced water container and associated piping is visually inspected, on a regular basis, for leaks, corrosion, or other conditions that could lead to a discharge as described in 112.1(b) in accordance with good engineering practice. Yes No NA Yes No NA Corrective action or necessary repairs were made to any produced water container and associated piping as indicated by regularly scheduled visual inspections, tests, or evidence of an oil discharge. Yes No NA Yes No NA Oil removed or other actions initiated to promptly stabilize and remediate any accumulation of oil discharges associated with the produced water container. Yes No NA Yes No NA All produced water containers comply with 112.9(c)(2) and (c)(3) within six months of any produced water container discharge of more than 1,000 U.S. gallons of oil in a single discharge as described in 112.1(b) or discharges of more than 42 U.S. gallons of oil in each of two discharges as described in 112.1(b) within any twelve month period.14 Yes No NA Yes No NA 13 Oil discharges that result from natural disasters, acts of war, or terrorism are not included in this determination. The gallon amount(s) specified (either 1,000 or 42) refers to the amount of oil that actually reaches navigable waters or adjoining shorelines not the total amount of oil spilled. The entire volume of the discharge is oil for this determination. Onshore Oil Drilling, Production and Workover Facilities Page 12 of 14 June 2014 PLAN 112.9(d) Facility transfer operations, pumping, and facility process (1) All aboveground valves and piping associated with transfer operations are inspected periodically and upon a regular schedule to determine their general condition. Include the general condition of flange joints, valve glands and bodies, drip pans, pipe supports, pumping well polish rod stuffing boxes, bleeder and gauge valves, and other such items Yes No NA (2) Saltwater (oil field brine) disposal facilities inspected often to detect possible system upsets capable of causing a discharge, particularly following a sudden change in atmospheric temperature Yes No NA (3) If flowlines and intra-facility gathering lines are not provided with secondary containment in accordance with 112.7(c) and the facility is not required to submit an FRP under 112.20, then the SPCC Plan includes: (i) An oil spill contingency plan following the provisions of 40 CFR part 10914 (ii) A written commitment of manpower, equipment, and materials required to expeditiously control and remove any quantity of oil discharged that might be harmful Yes No NA Yes No NA (4) A flowline/intra-facility gathering line maintenance program to prevent discharges is prepared and implemented and includes the following procedures: (i) Flowlines and intra-facility gathering lines and associated valves and equipment are compatible with the type of production fluids, their potential corrosivity, volume, and pressure, and other conditions expected in the operational environment Yes No NA (ii) Flowlines and intra-facility gathering lines and associated appurtenances are visually inspected and/or tested 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). If flowlines and intra-facility gathering lines are not provided with secondary containment in accordance with 112.7(c), the frequency and type of testing allows for the implementation of a contingency plan as described under 40 CFR 109 or an FRP submitted under 112.20 Yes No NA Yes No NA (iii) Repairs or other corrective actions are made to any flowlines and intra-facility gathering lines and associated appurtenances as indicated by regularly scheduled visual inspections, tests, or evidence of a discharge Yes No NA (iv) Oil removed or other actions initiated to promptly stabilize and remediate any accumulations of oil discharges associated with the flowlines, intra-facility gathering lines, and associated appurtenances Yes No NA ONSHORE OIL DRILLING AND WORKOVER FACILITIES--40 CFR 112.10 112.10(b) Mobile drilling or workover equipment is positioned or located to prevent a discharge as described in 112.1(b) Yes No NA 112.10(c) Catchment basins or diversion structures are provided to intercept and contain discharges of fuel, crude oil, or oily drilling fluids Yes No NA 112.10(d) Blowout prevention (BOP) assembly and well control system installed before drilling below any casing string or during workover operations BOP assembly and well control system is capable of controlling any well-head pressure that may be encountered while on the well Yes No NA Yes No NA Comments: FIELD Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA NA Yes No NA Yes No NA Yes No NA Yes No NA 14 Note that the implementation of a 40 CFR part 109 plan does not require a PE impracticability determination for this specific requirement Onshore Oil Drilling, Production and Workover Facilities Page 13 of 14 June 2014 This page left intentionally blank. Onshore Oil Drilling, Production and Workover Facilities Page 14 of 14 June 2014 ATTACHMENT A: SPCC FIELD INSPECTION AND PLAN REVIEW TABLE Documentation of Field Observations for Containers and Associated Requirements Inspectors should use this table to document observations of containers as needed. Containers and Piping Check containers for leaks, specifically looking for: drip marks, discoloration of tanks, puddles containing spilled or leaked material, corrosion, cracks, and localized dead vegetation, and standards/specifications of construction. Check aboveground container foundation for: cracks, discoloration, and puddles containing spilled or leaked material, settling, gaps between container and foundation, and damage caused by vegetation roots. Check all piping for: droplets of stored material, discoloration, corrosion, bowing of pipe between supports, evidence of stored material seepage from valves or seals, evidence of leaks, and localized dead vegetation. For all aboveground piping, include the general condition of flange joints, valve glands and bodies, drip pans, pipe supports, bleeder and gauge valves, and other such items (Document in comments section of 112.9(d).) Secondary Containment (Active and Passive) Check secondary containment for: containment system (including walls and floor) ability to contain oil such that oil will not escape the containment system before cleanup occurs, proper sizing, cracks, discoloration, presence of spilled or leaked material (standing liquid), erosion, corrosion, penetrations in the containment system, and valve conditions. Check dike or berm systems for: level of precipitation in dike/available capacity, operational status of drainage valves (closed), dike or berm impermeability, debris, erosion, impermeability of the earthen floor/walls of diked area, and location/status of pipes, inlets, drainage around and beneath containers, presence of oil discharges within diked areas. Check drainage systems for: an accumulation of oil that may have resulted from any small discharge, including field drainage systems (such as drainage ditches or road ditches), and oil traps, sumps, or skimmers. Ensure any accumulations of oil have been promptly removed. Check retention and drainage ponds for: erosion, available capacity, presence of spilled or leaked material, debris, and stressed vegetation. Check active measures (countermeasures) for: amount indicated in plan is available and appropriate; deployment procedures are realistic; material is located so that they are readily available; efficacy of discharge detection; availability of personnel and training, appropriateness of measures to prevent a discharge as described in 112.1(b). Note that appropriate evaluation and consideration must be given to the any use of active measures at an unmanned oil production facility. Container ID/ General Condition15 Aboveground or Buried Tank Storage Capacity and Type of Oil Type of Containment/ Drainage Control Overfill Protection and Testing & Inspections Tank 1 (A) - Gun Barrel 300 bbls / 12,600 gallons Inadequate sized secondary Mechanical overfill; visual containment inspections not recorded Tanks 2, 3, 4, 5, 9 (A) - Bulk Oil 210 bbls / 8,820 gallons Inadequate sized secondary Visual overfill; visual each (44,100 gallons total) containment inspections not recorded Tanks 6, 7 (A) - Bulk Oil 200 bbls / 8,400 gallons Inadequate sized secondary Visual overfill; visual each (16,800 gallons total) containment inspections not recorded Tanks 10, 11 (A) - Gun Barrel 175 bbls / 7,350 gallons Inadequate sized secondary Mechanical overfill; visual each (14,700 gallons total) containment inspections not recorded Tank 8 (A) - Bulk Oil 210 bbls / 8,820 gallons Inadequate sized secondary Out of service containment Tank 12 (A) - Gun Barrel 175 bbls / 7,350 gallons Inadequate sized secondary Out of service containment 15 Identify each tank with either an A to indicate aboveground or B for completely buried Onshore Oil Drilling, Production and Workover Facilities Page A-1 of 2 June 2014 ATTACHMENT A: SPCC FIELD INSPECTION AND PLAN REVIEW TABLE (CONT.) Documentation of Field Observations for Containers and Associated Requirements Container ID/ General Condition16 Aboveground or Buried Tank Storage Capacity and Type of Oil Type of Containment/ Drainage Control Overfill Protection and Testing & Inspections 16 Identify each tank with either an A to indicate aboveground or B for completely buried Onshore Oil Drilling, Production and Workover Facilities Page A-2 of 2 June 2014 ATTACHMENT B: SPCC INSPECTION AND TESTING CHECKLIST Required Documentation of Tests and Inspections Records of inspections and tests required by 40 CFR part 112 signed by the appropriate supervisor or inspector must be kept by all facilities with the SPCC Plan for a period of three years. Records of inspections and tests conducted under usual and customary business practices will suffice. Documentation of the following inspections and tests should be kept with the SPCC Plan. Inspection or Test Documentation Present Not Present Not Applicable 112.7-General SPCC Requirements (d) Integrity testing for bulk storage containers with no secondary containment system and for which an impracticability determination has been made (d) Integrity and leak testing of valves and piping associated with bulk storage containers with no secondary containment system and for which an impracticability determination has been made (h)(3) Inspection of lowermost drain and all outlets of tank car or tank truck prior to filling and departure from loading/unloading rack (i) Evaluation of field-constructed aboveground containers for potential for brittle fracture or other catastrophic failure when the container undergoes a repair, alteration, reconstruction or change in service or has discharged oil or failed due to brittle fracture failure or other catastrophe k(2)(i) Inspection or monitoring of qualified oil-filled operational equipment when the equipment meets the qualification criteria in 112.7(k)(1) and facility owner/operator chooses to implement the alternative requirements in 112.7(k)(2) that include an inspection or monitoring program to detect oil-filled operational equipment failure and discharges 112.9-Onshore Oil Production Facilities (excluding drilling and workover facilities) NA (b)(1) Rainwater released directly from diked containment areas inspected following 112.8(c)(3)(ii), (iii) and (iv), including records of drainage kept (b)(2) Field drainage systems, oil traps, sumps, and skimmers inspected regularly for oil, and accumulations of oil promptly removed (c)(3) Containers, foundations and supports inspected visually for deterioration and maintenance needs (c)(5)(i) In lieu of having sized secondary containment, flow-through process vessels and associated components visually inspected and/or tested periodically and on a regular schedule for conditions that could result in a discharge as described in 112.1(b) (c)(6)(ii) In lieu of having sized secondary containment, produced water containers and associated piping are visually inspected and/or tested for leaks, corrosion, or other conditions that could lead to a discharge as described in 112.1(b) in accordance with good engineering practice (d)(1) All aboveground valves and piping associated with transfer operations are regularly inspected (d)(2) Saltwater disposal facilities inspected often to detect possible system upsets capable of causing a discharge (d)(4)(ii) For flowlines and intra-facility gathering lines without secondary containment, in accordance with 112.7(c), lines are visually inspected and/or tested periodically and on a regular schedule to allow implementing the part 109 contingency plan or the FRP submitted under 112.20 Onshore Oil Drilling, Production and Workover Facilities Page B-1 of 2 June 2014 This page left intentionally blank. Onshore Oil Drilling, Production and Workover Facilities Page B-2 of 2 June 2014 ATTACHMENT C: SPCC CONTINGENCY PLAN REVIEW CHECKLIST NA 40 CFR Part 109-Criteria for State, Local and Regional Oil Removal Contingency Plans If SPCC Plan includes an impracticability determination for secondary containment in accordance with 112.7(d), the facility owner/operator is required to provide an oil spill contingency plan following 40 CFR part 109, unless he or she has submitted a FRP under 112.20. An oil spill contingency plan may also be developed, unless the facility owner/operator has submitted a FRP under 112.20 as one of the required alternatives to general secondary containment for qualified oil filled operational equipment in accordance with 112.7(k). 109.5-Development and implementation criteria for State, local and regional oil removal contingency plans17 Yes No (a) Definition of the authorities, responsibilities and duties of all persons, organizations or agencies which are to be involved in planning or directing oil removal operations. (b) Establishment of notification procedures for the purpose of early detection and timely notification of an oil discharge including: (1) The identification of critical water use areas to facilitate the reporting of and response to oil discharges. (2) A current list of names, telephone numbers and addresses of the responsible persons (with alternates) and organizations to be notified when an oil discharge is discovered. (3) Provisions for access to a reliable communications system for timely notification of an oil discharge, and the capability of interconnection with the communications systems established under related oil removal contingency plans, particularly State and National plans (e.g., National Contingency Plan (NCP)). (4) An established, prearranged procedure for requesting assistance during a major disaster or when the situation exceeds the response capability of the State, local or regional authority. (c) Provisions to assure that full resource capability is known and can be committed during an oil discharge situation including: (1) The identification and inventory of applicable equipment, materials and supplies which are available locally and regionally. (2) An estimate of the equipment, materials and supplies that would be required to remove the maximum oil discharge to be anticipated. (3) Development of agreements and arrangements in advance of an oil discharge for the acquisition of equipment, materials and supplies to be used in responding to such a discharge. (d) Provisions for well defined and specific actions to be taken after discovery and notification of an oil discharge including: (1) Specification of an oil discharge response operating team consisting of trained, prepared and available operating personnel. (2) Pre-designation of a properly qualified oil discharge response coordinator who is charged with the responsibility and delegated commensurate authority for directing and coordinating response operations and who knows how to request assistance from Federal authorities operating under existing national and regional contingency plans. (3) A preplanned location for an oil discharge response operations center and a reliable communications system for directing the coordinated overall response operations. (4) Provisions for varying degrees of response effort depending on the severity of the oil discharge. (5) Specification of the order of priority in which the various water uses are to be protected where more than one water use may be adversely affected as a result of an oil discharge and where response operations may not be adequate to protect all uses. (e) Specific and well defined procedures to facilitate recovery of damages and enforcement measures as provided for by State and local statutes and ordinances. 17 The contingency plan should be consistent with all applicable state and local plans, Area Contingency Plans, and the NCP. Onshore Oil Drilling, Production and Workover Facilities Page C-1 of 2 June 2014 This page left intentionally blank. Onshore Oil Drilling, Production and Workover Facilities Page C-2 of 2 June 2014 ATTACHMENT D: TIER II QUALIFIED FACILITY CHECKLIST NA TIER II QUALIFIED FACILITY PLAN REQUIREMENTS --40 CFR 112.6(b) 112.6(b)(1) Plan Certification: Owner/operator certified in the Plan that: (i) He or she is familiar with the requirements of 40 CFR part 112 (ii) He or she has visited and examined the facility18 (iii) The Plan has been prepared in accordance with accepted and sound industry practices and standards and with the requirements of this part (iv) Procedures for required inspections and testing have been established (v) He or she will fully implement the Plan (vi) The facility meets the qualification criteria set forth under 112.3(g)(2) (vii) The Plan does not deviate from any requirements as allowed by 112.7(a)(2) and 112.7(d), except as described under 112.6(b)(3)(i) or (ii) (viii) The Plan and individual(s) responsible for implementing the Plan have the full approval of management and the facility owner or operator has committed the necessary resources to fully implement the Plan. Yes No Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA 112.6(b)(2) Technical Amendments: The owner/operator self-certified the Plan's technical amendments for a change in facility design, construction, operation, or maintenance that affected potential for a 112.1(b) discharge Yes No NA If YES Certification of technical amendments is in accordance with the self-certification provisions of 112.6(b)(1). Yes No NA (i) A PE certified a portion of the Plan (i.e., Plan is informally referred to as a hybrid Plan) Yes No NA If YES The PE also certified technical amendments that affect the PE certified portion of the Plan as required under 112.6(b)(4)(ii) Yes No NA (ii) The aggregate aboveground oil storage capacity increased to more than 10,000 U.S. gallons as a result of the change Yes No NA If YES The facility no longer meets the Tier II qualifying criteria in 112.3(g)(2) because it exceeds 10,000 U.S. gallons in aggregate aboveground storage capacity. The owner/operator prepared and implemented a Plan within 6 months following the change and had it certified by a PE under 112.3(d) Yes No NA 112.6(b)(3) If YES Plan Deviations: Does the Plan include environmentally equivalent alternative methods or impracticability determinations for secondary containment? Identify the alternatives in the hybrid Plan: Environmental equivalent alternative method(s) allowed under 112.7(a)(2); Impracticability determination under 112.7(d) Yes No NA Yes No NA Yes No NA 112.6(b)(4) (i) (A) (B) (C) For each environmentally equivalent measure, the Plan is accompanied by a written statement by the PE that describes: the reason for nonconformance, the alternative measure, and how it offers equivalent environmental protection in accordance with 112.7(a)(2); For each secondary containment impracticability determination, the Plan explains the reason for the impracticability determination and provides the alternative measures to secondary containment required in 112.7(d) AND PE certifies in the Plan that: He/she is familiar with the requirements of 40 CFR Part 112 He/she or a representative agent has visited and examined the facility The alternative method of environmental equivalence in accordance with 112.7(a)(2) or the determination of impracticability and alternative measures in accordance with 112.7(d) is consistent with good engineering practice, including consideration of applicable industry standards, and with the requirements of 40 CFR Part 112. Yes No NA Yes No NA Yes No NA Yes No NA Yes No NA Comments: 18 Note that only the person certifying the Plan can make the site visit Onshore Oil Drilling, Production and Workover Facilities Page D-1 of 2 June 2014 This page left intentionally blank. Onshore Oil Drilling, Production and Workover Facilities Page D-2 of 2 June 2014 ATTACHMENT E: ADDITIONAL COMMENTS The facility SPCC plan is incomplete and remiss for all 40 CFR 112 plan preparations except 112.3(e)(1), 112.7(a)(3)(vi), 112.7(f)(2), 112.9(c)(2). The plan should be revised to include the numerous missing plan preparations. A lead line which produces for the McGilvray lease discharged releasing roughly 3 barrels of crude oil to Willow Creek, this discharge was reported to NRC (1391171) and Kansas Agencies on 02/09/2024. A lead line which produces for the Ellis lease discharged roughly 0.25 barrels of crude oil to Onion Creek, this discharge was reported to the NRC (1391711) and Kansas Agencies on 02/16/2024. 112.3(a) - The SPCC plan has not been fully implemented and has no date of preparation. 112.3(d) - The PE does not include statements that they attest the procedures for required inspections and testing; or that any procedure to minimize the amount of free-phase oil is designed to reduce the accumulation of free-phase oil and the procedures and frequency for required inspections, maintenance and testing have been established and are described in the Plan. 112.5(b) - A documented review and evaluation of the plan has not been completed at least once every five years. 112.7 - The SPCC Plan does not meet all of the applicable rule requirements. 112.7(a)(3) - The facility diagram is remiss for locations of all production wellheads and the location of portable containers. (i) The SPCC plan does not describe the types of oil, storage capacities, and number of portable containers located at the facility. (ii) The SPCC plan does not provide discharge prevention measures. (iii) the SPCC plan and the facility do not provide discharge and drainage controls for the control of a discharge. (iv) The SPCC plan does not provide countermeasures for discharge discovery, response, and cleanup. (v) The SPCC plan does not provide methods of disposal of recovered materials in accordance with applicable legal requirements 112.7(a)(4) - The SPCC plan does not provide a spill response procedure. 112.7(a)(5) - The SPCC plan is not organized to be used when a discharge occurs to be readily useable in an emergency. 112.7(b) - The SPCC plan does not include a prediction of the direction, rate of flow, and total quantity of oil which could be discharged from the facility as a result of each type of equipment failure. 112.7(c) - Excessive vegetation is present on the earthen berm. The height of the berm is inadequate sized to prevent a worse case discharge. The plan does not describe secondary containment for portable storage containers, production wellheads and transfer areas, and flowlines. 112.7(d) - No impracticability claim is made regarding secondary containment provided for the production wellheads and buried piping. 112.7(e) - The SPCC plan should be revised to include inspections or testing procedures. No records of inspections and tests were provided at the time of the inspection. 112.7(f)(1) - The SPCC plan should be revised to include training of oil handling personnel in operation and maintenance of equipment to prevent discharges, discharge procedure protocols; applicable pollution control laws, rules, and regulations; general facility operations; and contents of SPCC Plan. 112.7(f)(3) - The SPCC plan should be revised to include discharge prevention briefings to be conducted at least once a year for oil handling personnel to assure adequate understanding of the Plan. 112.7(j) - The SPCC plan should be revised to include conformance with applicable more stringent State rules, regulations, and guidelines. 112.9(c)(1) - The SPCC plan should state if bulk storage containers materials and construction are compatible with material stored and conditions of storage such as pressure and temperature. Onshore Oil Drilling, Production and Workover Facilities Page E-1 of 2 June 2014 ATTACHMENT E: ADDITIONAL COMMENTS (CONT.) 112.9(c)(2) - The facility secondary containment berm height is inadequate sized to hold the capacity of the largest single container and sufficient freeboard for precipitation. 112.9(c)(3) - The SPCC plan should be revised to include visual inspections of containers for deterioration and maintenance needs, including foundation and supports of each container on or above the surface of the ground. 112.9(c)(4) - The SPCC plan should state if tank batteries are engineered/updated in accordance with good engineering practices to prevent discharges. 112.9(d)(1) - The SPCC plan should be revised to include visual inspections of all aboveground valves and piping associated with the transfer operations. 112.9(d)(2) - The SPCC plan should be revised to include inspections of saltwater disposal facility valves and piping. 112.9(d)(3) - No secondary containment is provided for the facility's flowlines. The facility has not prepared an oil spill contingency plan following the provisions of Part 109. The facility has not prepared and implemented a written commitment of manpower, equipment and materials to expeditiously control and remove any quantity of oil discharged that might be harmful. 112.9(d)(4) - The facility's flowline maintenance program procedures do not address: (i) flowline compatibility with the type of production fluids, potential corrosivity, volume, and pressure. (ii) flowline visual inspection procedures. (iii) corrective action or repairs to any flowlines and associated appurtenances as indicated by visual inspections, tests, or evidence of a discharge. (iv) the plan and the facility do not promptly remove or take actions to stabilize and remediate any accumulations of oil discharges associated with flowlines and associated appurtenances. Onshore Oil Drilling, Production and Workover Facilities Page E-2 of 2 June 2014 Photo# See ATTACHMENT F: PHOTO DOCUMENTATION NOTES Photographer Name Time of Photo Taken Compass Direction Description Attached Photolog Onshore Oil Drilling, Production and Workover Facilities Page F-1 of 2 December 2012 (12-10-12) Photo# ATTACHMENT F: PHOTO DOCUMENTATION NOTES (CONT.) Photographer Name Time of Photo Taken Compass Direction Description Onshore Oil Drilling, Production and Workover Facilities Page F-2 of 2 June 2014