Document vyQk6Od2veX8mkNDoOwJbaQjm

ENVIRONMENTAL PROTECTION AGENCY SPCC FIELD INSPECTION AND PLAN REVIEW CHECKLIST OFFSHORE 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 offshore oil production, drilling, and workover facilities. Separate and standalone checklists address the requirements for: Onshore facilities including Tier II Qualified Facilities (excluding oil drilling, production and workover facilities); Onshore oil drilling, production and workover facilities including Tier II Qualified Facilities as defined in 112.3 (g) (2); and Tier I Qualified Facilities (for facilities that meet the eligibility criteria defined in 112.3 (g) (1)). 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. 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 " or " NA " answers. Section 112.7 includes general requirements that apply to all facilities (unless otherwise excluded). Section 112.11 specifies spill prevention, control, and countermeasures requirements for offshore 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 D at the end of the checklist. Comments should remain factual and support the evaluation of compliance. Attachments (Attachments A and B are included for hybrid facilities which have both offshore and onshore components) Attachment A is a checklist for Sections 112.8 and 112.12. This checklist specifies requirements for spill prevention, control, and countermeasures for onshore facilities (excluding oil production facilities). Attachment B is a checklist that specifies requirements for spill prevention, control, and countermeasures for onshore oil production facilities (112.9 provisions) and onshore drilling and workover facilities (112.10 provisions) Attachment C is for recording information about containers and other locations at the facility that require secondary containment. Attachment D is a checklist for documentation of the tests and inspections the facility operator is required to keep with the SPCC Plan. Attachment E 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 F is for recording additional comments or notes. Attachment G is for recording information about photos. Offshore Oil Drilling, Production and Workover Facilities Page 1 of 10 June 2014 ED_019088A_00006187-00001 FACILITY INFORMATION FACILITY NAME: LATITUDE:LONGITUDE:GPS DATUM: Section / Township / Range:FRS # / OIL DATABASE ID:ICIS #: ADDRESS: CITY:STATE:ZIP:COUNTY: MAILING ADDRESS (IF DIFFERENT FROM FACILITY ADDRESS - IF NOT, PRINT " SAME "): CITY:STATE:ZIP:COUNTY: TELEPHONE:FACILITY CONTACT NAME / TITLE: OWNER NAME: OWNER ADDRESS: CITY:STATE:ZIP:COUNTY: TELEPHONE:FAX:EMAIL: FACILITY OPERATOR NAME (IF DIFFERENT FROM OWNER - IF NOT, PRINT " SAME "): OPERATOR ADDRESS: CITY:STATE:ZIP:COUNTY: TELEPHONE:OPERATOR CONTACT NAME / TITLE: FACILITY TYPE:NAICS CODE: HOURS PER DAY FACILITY ATTENDED:TOTAL FACILITY CAPACITY: TYPE(S) OF OIL STORED: LOCATED IN INDIAN COUNTRY? YES NO RESERVATION NAME: INSPECTION / PLAN REVIEW INFORMATION PLAN REVIEW DATE:REVIEWER NAME: INSPECTION DATE:TIME:ACTIVITY ID NO: LEAD INSPECTOR: OTHER INSPECTOR(S): INSPECTION ACKNOWLEDGMENT I performed an SPCC inspection at the facility specified above. INSPECTOR SIGNATURE:DATE: SUPERVISOR REVIEW / SIGNATURE:DATE: Offshore Oil Drilling, Production and Workover FacilitiesPage 2 of 10June 2014 ED_019088A_00006187-00002 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 oThiel fsatcoirlaigtye icsa paa cniotny - itsr aonvsepro rt1a,t3i2o0n U-. Sr.el agtaeldl ofnasc iAliNtDy 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 AFFECTED WATERWAY(S): FLOW PATH TO WATERWAY: DISTANCE: Yes No Yes No 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) Completely buried tanks subject to all the technical requirements of 40 CFR part 280 or a state program approved under 40 CFR part 281; 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; . 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: CHECKCHECKCHECKCHECKCHECK NAA FRP Number: Facility has a completed and signed copy of Appendix C, Attachment C-II, " Certification of the Applicability of the Substantial Harm Criteria. " Yes No Comments: Offshore Oil Drilling, Production and Workover Facilities Page 3 of 10 June 2014 ED_019088A_00006187-00003 REQUIREMENTS FOR PREPARATION AND IMPLEMENTATION OF A SPCC PLAN-40 CFR 112.3 Date facility began operations: 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: * Ini mpolpeemreanttieodn boyn Noorv epmrbieorr 1t0o, N2o0v1e0m ber 10, 2010: Plan prepared and / or amended and fully Yes No NA * Facilities beginning operation after November 10, 2010: 0 Plan prepared and fully implemented before drilling and workover facilities beginTCHECK: KCE:: D: D: D D: D__A__ operations; or Plan prepared and fully implemented within six months after oil productionYes No NA facilities begin operations 112.3 (d) Plan is certified by a registered Professional Engineer (PE) and includes statements that the Yes No NA PE attests: * PE is familiar with the requirements of 40 CFR part 112Yes NoNA * PE or agent has visited and examined the facilityYes: HD: D:: _: _: NA * Plan is prepared in accordance with good engineering practice including considerationYes No: NA of applicable industry standards and the requirements of 40 CFR part 112 * Procedures for required inspections and testing have been establishedYes NoNA * Plan is adequate for the facilityYes No NA For produced water containers subject to 112.9 (c) (6), any procedure to minimize theYes No NA 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 PE Name:License No.:State:Date of certification: 112.3 (e) (1) Plan is available onsite if attended at least 4 hours per day. If facility is unattended, Plan isYes No: NA available at the nearest field office. (Please note nearest field office contact information in comments section below.) 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 reportableYes No. discharge or more than 42 U.S. gallons in each of two reportable discharges in any 12- month period? If YES * Was information submitted to the RA as required in 112.4 (a)? Yes No NA * Was information submitted to the appropriate agency or agencies in charge of oilYes No NA 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 NRC?Yes No 112.4 (d), (e) Have changes required by the RA been implemented in the Plan and / or facility?Yes No NA Comments: 1 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. 2 Triggering this threshold may disqualify the facility from meeting the Qualified Facility criteria if it occurred in the three years prior to self certification 3 Inspector Note - Confirm any spills identified above were reported to NRC Offshore Oil Drilling, Production and Workover FacilitiesPage 4 of 10June 2014 ED_019088A_00006187-00004 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 dischargeYes No described in 112.1 (b)? If YES * Was the Plan amended within six months of the change?YesNo * Were amendments implemented within six months of any Plan amendment?YesNo 112.5 (b) Review and evaluation of the Plan completed at least once every 5 years?YesNoNA Following Plan review, was Plan amended within six months to include more effectiveYesNoNA 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?Yes NoNA Five year Plan review and evaluation documented?YesNoNA 112.5 (c) Professional Engineer certification of any technical Plan amendments in accordance with all Yes No NA applicable requirements of $ 112.3 (d) [Except for self - certified Plans] Name:License No.:State:Date of certification: Reason for amendment: Comments: GENERAL SPCC REQUIREMENTS-40 CFR 112.7PLANFIELD Management approval at a level of authority to commit the necessary resources toYesNo fully implement the Plan * 4 Plan follows sequence of the rule or is an equivalent Plan meeting all applicableYes No NA rule requirements and includes a cross - reference of provisions If Plan calls for facilities, procedures, methods, or equipment not yet fullyYes No NA operational, details of their installation and start - up are discussed (Note: Relevant for inspection evaluation and testing baselines.) 112.7 (a) (2) The Plan includes deviations from the requirements of 112.7 (g),Yes No NA (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) If YES* The Plan states reasons for nonconformanceYesNo ONA Alternative measures described in detail and provideYes No NA s,Yes No NA 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: 4 May be part of the Plan or demonstrated elsewhere. Offshore Oil Drilling, Production and Workover FacilitiesPage 5 of 10June 2014 ED_019088A_00006187-00005 PLAN FIELD 112.7 (a) (3) Plan describes physical layout of facility and includes a diagramYes NoYes No 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) Plan addresses each of the following: (i) For each fixed container, type of oil and storage capacity (seeYes NoYes No 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 routineYes No> Yes No handling of products (loading, unloading, and facility transfers, etc.) (iii) Discharge or drainage controls, such as secondary containmentYes NoYes No around containers, and other structures, equipment, and procedures for the control of a discharge (iv) Countermeasures for discharge discovery, response, and cleanup Yes NoYes No (both facility's and contractor's resources) (v) Methods of disposal of recovered materials in accordance withYes No applicable legal requirements (vi) Contact list and phone numbers for the facility responseYes No 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) 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* Description of all affected media; number of the facility;* Cause of the discharge; Date and time of the discharge;* Damages or injuries caused by the * Type of material discharged;discharge; * Estimates of the total quantity discharged;* Actions being used to stop, remove, andwww * Estimates of the quantity discharged asmitigate the effects of the discharge; described in $ 112.1 (b);* Whether an evacuation may be needed; * Source of the discharge;and * 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:Yes No NA Plan organized so that portions describing procedures to be used when a discharge occurs will be readily usable in an emergency 112.7 (b) Plan includes a prediction of the direction, rate of flow, and totalYes No NA quantity of oil that could be discharged for each type of major equipment failure where experience indicates a reasonable potential for equipment failure Comments: 5 Note in comments any discrepancies between the facility diagram, the description of the physical layout of facility, and what is observed in the field Offshore Oil Drilling, Production and Workover FacilitiesPage 6 of 10June 2014 ED_019088A_00006187-00006 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 offshore facilities, one of the following or its equivalent: * Curbing or drip pans; * Sumps and collection systems; For onshore facilities, one of the following or its equivalent: * Dikes, berms, or retaining walls sufficientlyWeirs, 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 containersstorageYes I No NA Yes CHECK: C: C: D: D: _: _ Mobile / portable containersYes No NA TECKY:::: CHECHECK: C::: _: CHECKED NA Oil - filled operational equipment (as defined in 112.2)Yes No NA H KYK::::: CHECHECKC KC::::::: NA Other oil - filled equipment (i.e., manufacturing equipment) Yes No NA Yes No NA Pipingandrelated appurtenancesYes No NA Yes DT: CHECK: C: C: D D: _ _ _: _ Mobile refuelers or 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 listedYes No NA Yes No NA above: 112.7 (d) Secondary containment for one (or more) of the followingYes No provisions is determined to be impracticable: General secondary containmentBulk storage containers 112.7 (c)112.8 (c) (2) /112.12 (c) (2) Loading / unloading rackMobile / portable 112.7 (h) (1)containers112.8 (c) (11) /112.12 (c) (11) If YESThe impracticability of secondary containment is clearlyKYK:::: KC KCCC NA Yes: CHECK No NA demonstrated and described in the Plan For bulk storage containers, 6 periodic integrity testing ofYes No NA Yes No NA containers and integrity and leak testing of the associated valves and piping is conducted (Does not apply if the facility has submitted a FRP under $ 112.20):Yes NoNA 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 Yes T THE NOT CHECKEDNEKAKE CHECK: Yes No s, required to expeditiously control and remove any quantity of oil discharged that may be harmful Comments: 6 These additional requirements apply only to bulk storage containers, when an impracticability determination has been made by the PE Offshore Oil Drilling, Production and Workover FacilitiesPage 7 of 10June 2014 ED_019088A_00006187-00007 PLAN FIELD 112.7 (e) Inspections and tests conducted in accordance with writtenYes No> Yes No procedures Record of inspections or tests signed by supervisor or inspectorYes NoYes No cKheecpklti stw) ith Plan for at least 3 years (see Attachment B of thisYes No Yes No 112.7 (f) Personnel, training, and oil discharge prevention procedures (1) Training of oil - handling personnel in operation and maintenance of Yes No NA Yes No NA equipment to prevent discharges; discharge procedure protocols; applicable pollution control laws, rules, and regulations; general facility operations; and contents of SPCC Plan (2) Person designated as accountable for discharge prevention at the Yes:::::: No NA Yes CHECK: No D: D D:: D:: D__A__ NA facility and reports to facility management (3) Discharge prevention briefings conducted at least once a year forYes No ONA Yes No NA 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 112.7 (h) Tank car and tank truck loading / unloading rack is present at the facilityYes 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) Does loading / unloading rack drainage flow to catchment basin orYes No NAYes: C CHECK NO: NA treatment facility designed to handle discharges or use a quick drainage system? Containment system holds at least the maximum capacity of theYes No NAYes No > NA largest single compartment of a tank car / truck loaded / unloaded at the facility (2) An interlocked warning light or physical barriers, warning signs,Yes No NAYes No NA 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 (3) Lower - most drains and all outlets on tank cars / trucks inspectedYes NOT NA Yes No NA prior to filling / departure, and, if necessary ensure that they are tightened, adjusted, or replaced to prevent liquid discharge while in transit 112.7 (i) Brittle fracture evaluation of field - constructed abovegroundYes No NAYes No: NA 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 field - constructed aboveground containers in production service, drilling, and workover service) 112.7 (j) Discussion of conformance with applicable more stringent StateYes No NA rules, regulations, and guidelines and other effective discharge prevention and containment procedures listed in 40 CFR part 112 ,,,, Comments: 7 Records of inspections and tests kept under usual and customary business practices will suffice 8 Note that a tank car / truck loading / unloading rack must be present for 112.7 (h) to apply. Though this requirement applies to all facilities, loading and unloading rack equipment is often not present at typical offshore production facilities. Offshore Oil Drilling, Production and Workover FacilitiesPage 8 of 10June 2014 ED_019088A_00006187-00008 PLAN FIELD 112.7 (k) Qualified oil - filled operational equipment is present at the facilityYes 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. If YES Check which apply: Secondary Containment provided in accordance with 112.7 (c) Alternative measure described below (confirm eligibility) 112.7 (k) Qualified Oil - Filled Operational Equipment Has a single reportable discharge as described in 112.1 (b) from any oil - filledYes No NA 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 - filledYes No NA operational equipment each exceeding 42 U.S. gallons occurred within any 12-month period within the three years prior to Plan certification date? 10 If YES for either, secondary containment in accordance with $ 112.7 (c) is required Facility procedure for inspections or monitoring program toYes No NA Yes No NA 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 AttachmentYes No NA C of this checklist) is provided in Plan AND Written commitment of manpower, equipment, and materialsYes No NA required to expeditiously control and remove any quantity of oil discharged that may be harmful is provided in Plan OFFSHORE OIL DRILLING, PRODUCTION OR WORKOVER FACILITIES-40 CFR 112.11 PLAN FIELD 112.11 (b) Oil drainage collection equipment used to prevent and controlYes No: NA H KYK::::::: CHECK NO: NA small discharges around pumps, glands, valves, flanges, expansion joints, hoses, drain lines, separators, treaters, tanks, and associated equipment Facility drains are controlled and directed toward a centralYes No NA Yes: CHECK No: NA collection sump to prevent a discharge as described in 112.1 (b); if drains and sumps not practicable, oil in collection equipment removed as often as necessary to prevent overflow 112.11 (c) For facilities using a sump system, sump and drains adequatelyYes No NA Yes No NA sized Comments: For facilities using a sump system, spare pump available toYes KNOCK NA Yes No NA remove liquids and assure that oil does not escape Regularly scheduled preventive maintenance inspection andYes No NA Yes No NA testing program to assure reliable operation of liquid removal system and pump start - up device Redundant automatic sump pumps and control devices areYes No NANoNA installed if necessary 9 This provision does not apply to oil - filled manufacturing equipment (flow - through process) 10 A reportable discharge is a discharge as described in 112.1 (b) (see 40 CFR part 110). 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. Offshore Oil Drilling, Production and Workover FacilitiesPage 9 of 10June 2014 ED_019088A_00006187-00009 PLAN FIELD 112.11 (d) If separators and treaters are equipped with dump valves whichYes No NA Yes No NA predominantly fail in the closed position and where pollution risk is high, facility equipped to prevent discharges by: Extending the flare line to a diked area if the separator is near shore; Equipping separator with high liquid level sensor to automatically shut in wells producing to the separator; or Installing parallel redundant dump valves. 112.11 (e) Atmospheric storage or surge containers equipped with high liquid Yes No NA Yes THECHANCE No D: D: D: D: D_E_A_LA level sensing devices that activate an alarm or control the flow, or otherwise prevent discharges 112.11 (f) Pressure containers equipped with high and low pressure sensing Yes: CTCC: No NA Yes No NA devices that activate an alarm or control the flow 112.11 (g) Containers equipped with suitable corrosion protectionYes No NAYes No NA 112.11 (h) Written procedures maintained in the SPCC Plan for inspectingYes No NAYes No NA and testing pollution prevention equipment and systems 112.11 (i) Testing and inspection of pollution prevention equipment andYes No NAYes No NA systems conducted on a scheduled periodic basis commensurate with the complexity, conditions, and circumstances of the facility and any other applicable regulations. Simulated discharges are used for testing and inspecting humanYes NOT No NA Yes No NA and equipment pollution control and countermeasure systems 112.11 (j) Detailed records are provided that describe surface andYes No NAYes CHECKED_O_CHECKCHECK No _____ NA subsurface well shut - in valves and devices in use at the facility for each well. Records are sufficient to determine the method of activation orYes NoYes NoNA control, such as pressure differential, change in fluid or flow conditions, combination of pressure and flow, or manual or remote control mechanisms 112.11 (k) Blowout prevention (BOP) assembly and well control systemYes No NAYes No NA installed before drilling below any casing string and during workover operations BOP assembly and well control system capable of controlling any Yes No NA Yes No NA well - head pressure that may be encountered while on the well 112.11 (I) Manifolds (headers) equipped with check valves on individualYes No NA > Yes No NA flowlines 112.11 (m) If the shut - in well pressure is greater than the working pressure of O Yes No NA Yes No NA the flowline and manifold valves up to and including the header valves, flowlines are equipped with a high pressure sensing device and shut - in valve at the wellhead, OR pressure relief system provided for flowlines 112.11 (n) Piping appurtenant to the facility is protected from corrosion, suchYes No NAYes No NA as with protective coatings or cathodic protection 112.11 (0) Sub - marine piping appurtenant to the facility is protected againstYes No NAYes environmental stresses and other activities such as fishing operations 112.11 (p) Sub - marine piping maintained in good operating condition at allYes No NA Yes No: NA times. Piping periodically inspected or tested on a regular schedule for failures. Documentation of inspections or tests kept at facility. Comments: Offshore Oil Drilling, Production and Workover FacilitiesPage 10 of 10June 2014 ED_019088A_00006187-00010 ATTACHMENT ANA PLAN FIELD ONSHORE FACILITIES (EXCLUDING PRODUCTION) 40 CFR 112.8 / 112.12 112.8 (b) / 112.12 (b) Facility Drainage Diked Areas Drainage from diked storage areas is:Yes No NAYes No NA (1)* Restrained by valves, except where facility systems are designed to control such discharge, OR * Manually activated pumps or ejectors are used and the condition of the accumulation is inspected prior to draining dike to ensure no oil will be discharged Comments: 112.8 (c) /112.12 (c) Bulk Storage ContainersNA 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. If bulk storage containers are not present, mark this section Not Applicable (NA). If present, complete this section and Attachment C of this checklist. (1) Containers materials and construction are compatible withYes No NAYes No NA material stored and conditions of storage such as pressure and temperature (3) Is there drainage of uncontaminated rainwater from diked areasYes No NACHCHECK: KYK Yes: D:: D: D: D: No D D:: D: D NA into a storm drain or open watercourse? If YES Bypass valve normally sealed closedYes No NAYes No NA Retained rainwater is inspected to ensure that its presenceYesNoNAYesNoNA will not cause a discharge as described in 112.1 (b) Bypass valve opened and resealed under responsibleYesNoNAYesNoNA supervision Adequate records of drainage are kept; for example, recordsYesNAKYK:::: CHECK No NA required under permits issued in accordance with 40 CFR 122.41 (j) (2) and (m) (3) (4) For completely buried metallic tanks installed on or after January 10, 1974 (if not exempt from SPCC regulation because subject to all of the technical requirements of 40 CFR part 280 or 281): Provide corrosion protection with coatings or cathodicY::: No: NA Y:::::::::::: NA protection compatible with local soil conditions Regular leak testing conductedYes No NA Yes No NA (5) The buried section of partially buried or bunkered metallic tanksYes No NAY:::: CHECK: No NA protected from corrosion with coatings or cathodic protection compatible with local soil conditions Comments: Offshore Oil Drilling, Production and Workover FacilitiesPage A-1 of 2June 2014 ED_019088A_00006187-00011 ATTACHMENT APLAN FIELD (6)Test or inspect each aboveground container for integrity on aYes No NAYes No NA regular schedule and whenever you make material repairs. Techniques include, but are not limited to: visual inspection, hydrostatic testing, radiographic testing, ultrasonic testing, acoustic emissions testing, or other system of non- destructive testing Appropriate qualifications for personnel performing tests andYes inspections are identified in the Plan and have been assessed in accordance with industry standards * The frequency and type of testing and inspections areYes No NAYes No NA documented, are in accordance with industry standards and take into account the container size, configuration and design * Comparison records of aboveground container integrity1 Yes No: NA TECH KYK::::: CHECKC KCC:: C CHECK NA testing are maintained * Container supports and foundations regularly inspectedYes * Outside of containers frequently inspected for signs ofYes No NAYes No NA deterioration, discharges, or accumulation of oil inside diked areas * Records of all inspections and tests maintained 11Yes No NAYes No NA Integrity Testing Standard identified in the Plan: 112.12 Conduct formal visual inspection on a regular schedule for bulkYes No NAYes NoNA (c) (6) (ii) storage containers that meet all of the following conditions: (Applies toSubject to 21 CFR part 110;* Have no external insulation; and AFVO Facilities only) Elevated;Shop - fabricated. Constructed of austenitic stainless steel; In addition, you must frequently inspect the outside of the container Yes No NA Yes No NA for signs of deterioration, discharges, or accumulation of oil inside diked areas. You must determine and document in the Plan the appropriateYes NoNAYes NoNA qualifications for personnel performing tests and inspections. 11 (10) Visible discharges which result in a loss of oil from the container,Yes No NAYes No NA including but not limited to seams, gaskets, piping, pumps, valves, rivets, and bolts are promptly corrected and oil in diked areas is promptly removed 112.8 (d) /112.12 (d) Facility transfer operations, pumping, and facility process (4) Aboveground valves, piping, and appurtenances such as flangeYes No NAYes No NA joints, expansion joints, valve glands and bodies, catch pans, pipeline supports, locking of valves, and metal surfaces are inspected regularly to assess their general condition Integrity and leak testing conducted on buried piping at time ofYes No NAYes No NA installation, modification, construction, relocation, or replacement Comments: 11 Records of inspections and tests kept under usual and customary business practices will suffice Offshore Oil Drilling, Production and Workover FacilitiesPage A-2 of 2June 2014 ED_019088A_00006187-00012 ATTACHMENT BNA PLAN FIELD ONSHORE OIL PRODUCTION FACILITIES-40 CFR 112.9 (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 - transportation- related 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 aYes NoYes No NA 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 thatYes NoYes No NA its presence will not cause a discharge as described in 112.1 (b) 112.8 (c) (3) (iii) - Bypass valve opened and resealed underYes NoYes No NA responsible supervision 112.8 (c) (3) (iv) - Adequate records of drainage are kept; forYes NoYes No NA example, records required under permits issued in accordance with $ 122.41 (j) (2) and (m) (3) (2) Field drainage systems (e.g., drainage ditches or road ditches) and Yes KC KCK___Yes No NA oil traps, sumps, or skimmers inspected at regularly scheduled intervals for oil, and accumulations of oil promptly removed 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 materialYes NoYes No NA stored and conditions of storage such as pressure and temperature (2) Except as allowed for flow - through process vessels in 112.9 (c) (5)Yes NoYes No NA 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 basinYesNoYes NoNA or holding pond. (3) Except as allowed for flow - through process vessels in 112.9 (c) (5) Yes NoYes No NA 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 (4) New and old tank batteries engineered / updated in accordance with::::: DECKYKKEKETECTED NoYes No NA 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 * High level sensors to generate and transmit an alarm to the rounds; computer where the facility is subject to a computer production * Overflow equalizing lines between containers so that acontrol system full container can overflow to an adjacent container; Comments: Offshore Oil Drilling, Production and Workover FacilitiesPage B-1 of 4June 2014 ED_019088A_00006187-00013 ATTACHMENT BPLAN FIELD (5) 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: (i) Flow - through process vessels and associated components (e.g.Yes No NA Yes No NA 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) (ii) Corrective actions or repairs have been made to flow - throughYes No NAYes No NA process vessels and any associated components as indicated by regularly scheduled visual inspections, tests, or evidence of an oil discharge (iii) Oil removed or other actions initiated to promptly stabilize andYes No NAYes No NA remediate any accumulation of oil discharges associated with the produced water container (iv) All flow - through process vessels comply with 112.9 (c) (2) andYes No NA Yes No NA (c) (3) within six months of any flow - through process vessel 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. 12 112.9 (d) Facility transfer operations, pumping, and facility process (1) All aboveground valves and piping associated with transferYes No NA Yes No NA 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 (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 CFRYes No NAYes: TECNO CHE NA part 10913 (ii)A written commitment of manpower, equipment, and materialsYes No NAYes NoNA required to expeditiously control and remove any quantity of oil discharged that might be harmful Comments: 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. 13 Note that the implementation of a 40 CFR part 109 plan does not require a PE impracticability determination for this specific requirement Offshore Oil Drilling, Production and Workover FacilitiesPage B-2 of 4June 2014 ED_019088A_00006187-00014 ATTACHMENT BPLAN FIELD (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 valvesYes No NA Yes No NA and equipment are compatible with the type of production fluids, their potential corrosivity, volume, and pressure, and other conditions expected in the operational environment (ii) Flowlines and intra - facility gathering lines and associatedYes No NA Yes No NA 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 withYes No NAYes No NA 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 (iii) Repairs or other corrective actions are made to any flowlines andYes No NA Yes: CHECHECK No NA intra - facility gathering lines and associated appurtenances as indicated by regularly scheduled visual inspections, tests, or evidence of a discharge (iv) Oil removed or other actions initiated to promptly stabilize andYes No NAYes No NA remediate any accumulation of oil discharges associated with the produced water containers ATTACHMENT BNA PLAN FIELD ONSHORE OIL DRILLING AND WORKOVER FACILITIES-40 CFR 112.10 112.10 (b) Mobile drilling or workover equipment is positioned or located toYes No NAYes No NA prevent a discharge as described in 112.1 (b) 112.10 (c) Catchment basins or diversion structures are provided to interceptYes No NA YES: CHECK NO:: NA and contain discharges of fuel, crude oil, or oily drilling fluids 112.10 (d) Blowout prevention (BOP) assembly and well control systemYes No NAYes No NA installed before drilling below any casing string or during workover operations BOP assembly and well control system is capable of controllingYes No NA Yes No NA any well - head pressure that may be encountered while on the well Comments: Offshore Oil Drilling, Production and Workover FacilitiesPage B-3 of 4June 2014 ED_019088A_00006187-00015 This page left intentionally blank. Offshore Oil Drilling, Production and Workover Facilities Page B-4 of 4 June 2014 ED_019088A_00006187-00016 ATTACHMENT C: 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 $ 112.11.) 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 any use of active measures at an unmanned production facility. Container ID / General Condition14Storage Capacity and TypeType of Containment /Overfill Protection and Aboveground or Buried Tank of OilDrainage ControlTesting & Inspections 14 Identify each tank with either an A to indicate aboveground or B for completely buried Offshore Oil Drilling, Production and Workover FacilitiesPage C-1 of 2June 2014 ED_019088A_00006187-00017 ATTACHMENT C: SPCC FIELD INSPECTION AND PLAN REVIEW TABLE (CONT.) Documentation of Field Observations for Containers and Associated Requirements Container ID / General Condition 15Storage Capacity and TypeType of Containment /Overfill Protection and Aboveground or Buried Tank of OilDrainage ControlTesting & Inspections 15 Identify each tank with either an A to indicate aboveground or B for completely buried Offshore Oil Drilling, Production and Workover FacilitiesPage C-2 of 2June 2014 ED_019088A_00006187-00018 ATTACHMENT D: 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. Documentation Not Inspection or TestNot Present Applicable Present 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 112.11-Offshore oil drilling, production and workover facilities (c) Regularly scheduled preventive maintenance inspection and testing program to assure reliable operation of liquid removal system and pump start - up device (i) Testing and inspection of pollution prevention equipment and systems performed on a scheduled periodic basis. Simulated discharges are used for testing and inspecting human and equipment pollution control and countermeasure systems (p) Submarine piping periodically inspected or tested for failures 112.8 / 112.12-Onshore Facilities (excluding oil production facilities)NA (b) (1), (b) (2) Inspection of storm water released from diked areas into facility drainage directly to a watercourse (c) (3) Inspection of rainwater released directly from diked containment areas to a storm drain or open watercourse before release, open and release bypass valve under supervision, and records of drainage events (c) (4) Regular leak testing of completely buried metallic storage tanks installed on or after January 10, 1974 and regulated under 40 CFR 112 (c) (6) Regular integrity testing of aboveground containers and integrity testing after material repairs, including comparison records OO (c) (6), Regular visual inspections of the outsides of aboveground containers, supports (c) (10) and foundations (c) (6) Frequent inspections of diked areas for accumulations of oil (d) (4) Regular inspections of aboveground valves, piping and appurtenances and assessments of the general condition of flange joints, expansion joints, valve glands and bodies, catch pans, pipeline supports, locking of valves, and metal surfaces (d) (4) Integrity and leak testing of buried piping at time of installation, modification, construction, relocation or replacement Offshore Oil Drilling, Production and Workover FacilitiesPage D-1 of 2June 2014 ED_019088A_00006187-00019 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) (d) (1) All aboveground valves and piping associated with transfers are regularly inspected (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 Comments: Offshore Oil Drilling, Production and Workover Facilities Page D-2 of 2 June 2014 ED_019088A_00006187-00020 ATTACHMENT E: SPCC CONTINGENCY PLAN REVIEW CHECKLISTNA 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 plans 16 "YesNo (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. O (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. 16 The contingency plan should be consistent with all applicable state and local plans, Area Contingency Plans, and the NCP. Offshore Oil Drilling, Production and Workover FacilitiesPage E-1 of 2June 2014 ED_019088A_00006187-00021 This page left intentionally blank. Offshore Oil Drilling, Production and Workover Facilities Page E-2 of 2 June 2014 ED_019088A_00006187-00022 ATTACHMENT F: ADDITIONAL COMMENTS Offshore Oil Drilling, Production and Workover Facilities Page F-1 of 2 June 2014 ED_019088A_00006187-00023 ATTACHMENT F: ADDITIONAL COMMENTS (CONT.) Offshore Oil Drilling, Production and Workover Facilities Page F-2 of 2 June 2014 ED_019088A_00006187-00024 ATTACHMENT G: PHOTO DOCUMENTATION NOTES Photo # Photographer Time of Compass Description Name Photo Taken Direction Offshore Oil Drilling, Production and Workover Facilities Page G-1 of 2 June 2014 ED_019088A_00006187-00025 ATTACHMENT G: PHOTO DOCUMENTATION NOTES (CONT.) Photo # Photographer Time of Compass Description Name Photo Taken Direction Offshore Oil Drilling, Production and Workover Facilities Page G-2 of 2 June 2014 ED_019088A_00006187-00026