1349h Co Spcc

DAN A. HUGHES COMPANY, L.P.

INTERIM SPILL PREVENTION, CONTROL &

COUNTERMEASURE PLAN

Collier-Hogan Oil Well Permit #1349

Section 20, Township 47S, Range 28E

Naples, Collier County, Florida 34117

Prepared by:

Received DEP O&G 4/22/2014

i

TABLE OF CONTENTS

SPCC CROSS REFERENCE TABLE [112.7] .................................................................................... iii

PROFESSIONAL ENGINEER CERTIFICATION [112.3(d)] ............................................................ v

LOG OF PLAN REVIEW AND AMENDMENTS [(112.5)] ............................................................. vi

MANAGEMENT APPROVAL [(112.7)] .......................................................................................... vii

1.0 GENERAL INFORMATION ........................................................................................... 1

1.1 Purpose [12.7(a)(1), 112.3(e)] ................................................................................. 1

1.2 Deviations from the Rule [112.7(a)(2)] ..................................................................... 1

1.3 Organization and Responsibilities ............................................................................ 1

2.0 FACILITY DESCRIPTION ............................................................................................. 3

2.1 Facility Operations [112.7(a)(3)] ............................................................................. 3

2.2 Facility Storage [112.7(a)(3)(i)] ............................................................................... 4

2.3 Discharge Prevention Measures [112.7(a)(3)(ii)] ....................................................... 5

2.4 Discharge Controls [112.7(a)(3)(iii)] ........................................................................ 6

2.5 Discharge, Discovery, Response, and Cleanup [112.7(a)(3)(iv)] .................................. 6

2.6 Disposal of Recovered Materials [112.7(a)(3)(v)] ...................................................... 8

2.7 Emergency Contact List [112.7(a)(3)(vi)] ................................................................. 8

3.0 SPILL REPORTING INFORMATION [112.7(A)(4)] ........................................................ 9

3.1 General Reporting Information ................................................................................ 9

3.2 Regulatory Reporting Information [112.4 (a) – (c)] .................................................... 9

4.0 SPILL PREDICTIONS, VOLUMES, RATE AND CONTAINMENT [112.7(B)] ...............11

5.0 CONTAINMENT AND DIVERSIONARY STRUCTURES [112.7(C)&(D)] ......................11

6.0 INSPECTIONS, TESTS, AND RECORDS [112.7(E)] ......................................................12

6.1 Daily Observations ...............................................................................................13

6.2 Monthly Inspections ..............................................................................................13

6.3 Periodic Integrity Testing .......................................................................................14

7.0 TRAINING AND DISCHARGE PREVENTION PROCEDURES [112.7(F)] ....................15

7.1 Training [112.7(f)(1)] ............................................................................................15

7.2 Spill Prevention Coordinator [112.7(f)(2)] ...............................................................15

7.3 Oil Discharge Prevention Briefings [112.7(f)(3)] ......................................................15

8.0 SECURITY [112.7(G)] ....................................................................................................16

8.1 Fencing [112.7(g)(1)] ............................................................................................16

8.2 Master Flow and Drain Valves [112.7(g)(2)] ............................................................16

8.3 Oil Pump Starter Controls [112.7(g)(3)] ..................................................................16

8.4 Loading/Unloading Connections [112.7(g)(4)] .........................................................17

8.5 Lighting [112.7(g)(5)] ...........................................................................................17

9.0 FACILITY LOADING/UNLOADING RACK [112.7(H)] .................................................17

10.0 BRITTLE FRACTURE EVALUATION [112.7(I)] .........................................................17

11.0 OTHER APPLICABLE DISCHARGE PREVENTION REGULATIONS [112.7(J)] .......17

12.0 OIL PRODUCTION FACILITY DRAINAGE [112.9(B)] ...............................................18

13.0 BULK OIL STORAGE CONTAINERS [112.9(C)] .........................................................18

13.1 Oil Storage Container Compatibility [112.9(c)(1)] ..................................................18

13.2 Oil Storage Container Secondary Containment and Drainage [112.9(c)(2)] ................18

13.3 Inspection, Tests, and Records [112.9(c)(3)] ...........................................................19


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13.4 Overflow Prevention [112.9(c)(4)] ........................................................................19

14.0 OIL TRANSFER OPERATIONS [112.9(D)] ..................................................................20

14.1 Flowline Maintenance [112.9(d)(3)] ......................................................................20

14.2 Saltwater Disposal System [112.9(d)(2)] ................................................................21

LIST OF APPENDICES

Appendix A - Site Location and Facility Layout Maps

Appendix B - Oil Storage Tank Inventory Table

Appendix C - General Oil Transfer Procedure

Appendix D - Spill Release Notification Form

Appendix E - Monthly Inspection Checklist

Appendix F - Records of Annual SPCC Plan Training

Appendix G - Secondary Containment Drainage Log

Appendix H - Substantial Harm Criteria


Collier-Hogan Oil Well Permit #1349 SPCC Plan April 21, 2014

Project Number 1014-1

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COLLIER-HOGAN SPCC CROSS REFERENCE TABLE

“GUIDELINES FOR THE PREPARATION AND IMPLEMENTATION OF A SPILL PREVENTION

CONTROL AND COUNTERMEASURE PLAN”

SPCC REGULATORY SECTION SECTION PAGE(S)

112.3 Requirements to prepare and implement a SPCC plan

112.3(d) P.E. certification of plan. - v

112.3(e) Maintain copy of plan. 1.1 1

112.4 Amendment of SPCC plan by regional administrator

112.4 (a)-(c) Discharge reporting. 3.2 9

112.5 Amendment of SPCC plan by owner/operator

112.5(a-c) Plan amendment, review, and P.E. certification. - vi

112.7 General requirements for Spill Prevention, Control and Countermeasure Plans

112.7 Management approval of Plan - vii

112.7(a)(1) Include discussion of facility's conformance with requirements. 1.1 1

112.7(a)(2) Deviation with regulations, equivalent environmental protection. 1.2 1

112.7(a)(3) Physical layout of facility and facility diagram. 2.1 3

112.7(a)(3)(i) Type of oil in each container and capacity. 2.2 4

112.7(a)(3)(ii) Discharge prevention measures. 2.3 5

112.7(a)(3)(iii) Discharge or drainage controls. 2.4 6

112.7(a)(3)(iv) Countermeasures. 2.5 6

112.7(a)(3)(v) Methods of waste disposal. 2.6 8

112.7(a)(3)(vi) Contact list/phone numbers. 2.7 8

112.7(a)(4) Discharge reporting procedures. 3.0 9

112.7(a)(5)

Organize plan in a way that makes discharge response procedures

readily useable. 1.0 1

112.7(b) Spill predictions. 4.0 11

112.7(c)(i-vi)

Provide appropriate diversion/containment to prevent discharge from

reaching navigable water. 5.0 11

112.7(d) Impracticability of control measures. 5.0 11

112.7(e) Inspections, tests, and records. 6.0 12

112.7(f)(1) Personnel training. 7.0 15

112.7(f)(2) Designate person accountable for discharge prevention. 7.2 15

112.7(f)(3) Discharge prevention briefings. 7.3 15

112.7(g) Security. 8.0 16,17

112.7(h) Loading/unloading racks. 9.0 17

112.7(i) Field-constructed AST and brittle fracture failure. 10.0 17

112.7(j) Other applicable standards. 11.0 17

112.9 SPCC Plan requirements for Onshore Oil Production Facilities

112.9(b) Oil production facility drainage. 12.0 18

112.9(c)(1) Bulk storage container compatibility. 13.1 18

112.9(c)(2) Secondary containment. 13.2 18




iv

COLLIER-HOGAN SPCC CROSS REFERENCE TABLE

“GUIDELINES FOR THE PREPARATION AND IMPLEMENTATION OF A SPILL PREVENTION

CONTROL AND COUNTERMEASURE PLAN”

SPCC REGULATORY SECTION SECTION PAGE(S)

112.8(c)(3) Inspections, tests, and records. 13.3 19

112.9(c)(4) Overflow prevention. 13.4 19

112.9(d) Oil transfer operations. 14.0 20

112.9(d)(3) Flowline maintenance. 14.1 20

112.9(d)(2) Saltwater disposal system. 14.2 21

112.20(e) Substantial Harm Criteria App. H -




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PROFESSIONAL ENGINEER CERTIFICATION [112.3(d)]

In accordance with 40 CFR Part 112.3(d), I hereby certify that I or my agent has visited and

examined the facility covered in this SPCC Plan, and being familiar with the requirements of 40 CFR

Part 112, attest that this Plan has been prepared in accordance with good engineering practice,

including consideration of applicable industry standards, and with the requirements of 40 CFR Part

112. I also certify that procedures for required inspections and testing as referenced in this SPCC

Plan have been established and that this SPCC Plan is adequate for this facility.

_________________________ _______________

Signature Date

Florida Registered Professional Engineer No.

DISCLAIMER: THIS INTERIM SPCC PLAN FOR THE COLLIER HOGAN OIL WELL

PERMIT #1349 IS BASED ON DESIGN INFORMATION AND NOT ACTUAL FIELD

CONDITIONS. THE PLAN WILL BE UPDATED AS NECESSARY TO REFLECT EXISTING

CONDITIONS, EQUIPMENT, PROCEDURES, ETC. FOLLOWING CONSTRUCTION, AT

WHICH TIME THE PROFESSIONAL ENGINEER CERTIFICATION AND MANAGEMENT

APPROVAL SECTIONS WILL BE FINALIZED.




vi

LOG OF PLAN REVIEW AND AMENDMENTS [112.5]

NON-TECHNICAL AMMENDMENTS

Non-technical amendments are not certified by a Professional Engineer.

Examples of changes include, but are not limited to, phone numbers, name changes or any non-technical text

change(s).

TECHNICAL AMENDMENTS

Technical amendments are certified by a Professional Engineer.

Examples of changes include, but are not limited to, commissioning or decommissioning containers; replacement,

reconstruction or movement of containers; reconstruction, replacements or installation of piping systems;

construction or demolition that might alter secondary containment structures; changes of product or service; or

revision of standard operation or maintenance procedures at the facility.

An amendment made under this section will be prepared within six (6) months of the change and implemented as

soon as possible, but no later than six months following the preparation of the amendment.

MANAGEMENT REVIEW

Management will review this SPCC Plan at least once each five (5) years and document the review on the form

below.

Review

Date

Printed Name Signature Amend Plan

(will/will not)




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MANAGEMENT APPROVAL [40 CFR 112.7]

This SPCC Plan for the Collier-Hogan facility addresses prevention of and response to releases

of oil. This Plan has the full approval of the appropriate Dan A. Hughes Company, LP (Hughes)

management personnel, who have the authority to commit the resources necessary to fully

implement it. Below is the signature of the appropriate management employee(s).

Signature Signature

Title Title

Date Date

Signature Signature

Title Title

Date Date




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1.0 GENERAL INFORMATION

1.1 Purpose [12.7(a)(1), 112.3(e)]

This SPCC Plan was developed in conformance with good engineering practices and with the oil

pollution control requirements outlined in 40 CFR Part 112.

The master copy of this SPCC Plan is maintained at the offices of Dan A. Hughes Company, LP

(Hughes) home office in Beeville, Texas. A field copy of this Plan will be kept on site with the

Field Gauger at the Collier-Hogan facility at all times during active operations. Records related

to this SPCC Plan, including equipment inspections and testing, employee training, and spill

reports are maintained by the Operations Manager, who is responsible for the upkeep of this

Plan.

1.2 Deviations from the Rule [112.7(a)(2)]

This SPCC Plan is designed to comply with the requirements outlined in 40 CFR 112. In the

event any deficiencies are identified in the implementation of this Plan, they will be addressed

using either a.) equivalent environmental protection, or b.) a recommendation for corrective

action by the certifying professional engineer.

1.3 Organization and Responsibilities

Key individuals will be identified as the Primary Spill Response Coordinator and the Secondary

Spill Response Coordinator. A description of the associated responsibilities for each position is

outlined in the following sections.




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Primary Spill Response Coordinator

The Field Gauger, or the Operation Manager’s specifically designated (in writing) representative,

is assigned as the Primary Spill Response Coordinator for the facility. The Primary Spill

Response Coordinator has the responsibility and authority for implementing the SPCC Plan.

He/she also must assure that all oil-handling personnel and site responders are adequately trained

regarding the provisions of the SPCC Plan and spill response procedures, so that they can

appropriately respond to any reasonably expected release.

The Primary Spill Response Coordinator will be available through contact cellular telephone, or

other 24-hour phone contact. In the absence of the Primary Spill Response Coordinator, a

designated Secondary Spill Response Coordinator shall be contacted to implement the SPCC

Plan in the event of an emergency.

Under normal circumstances, the Primary Spill Response Coordinator will be responsible for

coordinating spill response activities and notifying the responsible management personnel at

Hughes as well as external parties (in Section 3.0, Spill Reporting) of a spill or release. In the

event that neither the Primary Spill Response Coordinator nor Secondary Spill Response

Coordinator is able to implement these actions in a timely manner, the First Responder or other

local management personnel will be responsible for implementing the SPCC Plan.

Secondary Spill Response Coordinator

The Production Superintendent, or the Operation Manager’s specifically designated (in writing)

representative, is assigned as the Secondary Spill Response Coordinator for the facility. In order

to perform this role, the Secondary Spill Response Coordinator must be familiar with the SPCC

plan and response requirements.




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First Responder

During emergency situations, it is critical to have responsible personnel appointed and trained to

respond. Hughes will assign and train all Operations employees to serve as First Responders to

implement the site-specific provisions of the SPCC Plan. First Responders are familiar with the

operations of the Hughes equipment and facility, as well as the characteristics of hazardous

materials and wastes handled at the facility.

The First Responder will identify the problem, assess the health and environmental hazards, and

take all reasonable measures to stabilize the situation and minimize the extent of the spill or

release. The First Responder will then coordinate with the Primary (or Secondary) Spill

Response Coordinator to complete the spill response activities. These will include, but not be

limited to: removal and disposal of residues and contaminated soil, decontamination and

maintenance of emergency equipment, and submittal of the incident reports. These activities will

be directed by the Primary (or Secondary) Spill Response Coordinator.

2.0 FACILITY DESCRIPTION

2.1 Facility Operations [112.7(a)(3)]

The Collier-Hughes Oil Production facility is located at Section 20, Township 47S, Range 28E of

the Corkscrew NE United States Geological Survey 7.5 Minute Topographic Quadrangle Map in

Naples, Collier County Florida. The facility consists of one oil production well operated in

accordance with Oil Well Permit #1349 (Collier 20-3H), one salt water disposal well operated in

accordance with Injection Well Permit #1350 (Collier 20-5 SWDW), two water production wells,

and associated oil production equipment including generators, pumps, processing vessels, solid

waste disposal containers, fuel storage tanks, and crude oil storage tanks. Facility operations are

enclosed within a 2’ X 2’ storm water berm with approximate dimensions of 298’ X 298’. The




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oil production well will be located in the center of the enclosure at geographic coordinates

26.372251° North, 81.54086° West.

Produced fluids are initially transferred to a separator/heater to remove water from the crude oil.

Following separation, water is transferred to two 8,820-gallon polyethylene bulk storage

containers and crude is transferred into four 18,312-gallon steel bulk storage containers. The

water will be initially loaded into a truck for offsite disposal at a permitted disposal facility.

Depending on the volume and quality of water produced, Hughes will evaluate using the

injections well for disposal. The crude oil will be transferred to a truck for transportation and

sale offsite.

A site location map, aerial photograph, and a facility layout map are included in Appendix A.

2.2 Facility Storage [112.7(a)(3)(i)]

The facility has a total maximum oil storage capacity of approximately 100,000 gallons including

crude oil, oily wastewater, gasoline, and diesel fuel. The material and construction of bulk

storage containers at the facility are compatible with the material stored and conditions of

storage, such as pressure and temperature. Refer to the Oil Storage Tank Inventory table

included in Appendix B for a complete inventory of bulk oil storage containers.

Secondary containment for the crude oil and oily wastewater tanks is provided by a 2’ X 2’ storm

water berm with approximate dimensions of 298’ X 298’. Based on the relatively high viscosity

of crude oil, Hughes anticipates that any spills will be cleaned up prior to reaching groundwater

or migrating offsite. Due to the relatively low viscosity of diesel fuel and gasoline, the

transmissive sandy soil at the facility, impermeable secondary containment systems or double

walled tanks are utilized for storage of diesel and gasoline to minimize the potential for a release

to impact human health or the environment. Visible discharges that result in a loss of product




5

from containers will be promptly addressed and any accumulations of oil in the diked area will be

promptly removed and disposed in accordance with applicable regulations.

Mobile storage containers that are subject to SPCC regulations (e.g., 55-gallon drums) are stored

in areas within buildings or designated oil storage areas that are designed to control discharges

when unattended and not under the direct oversight or control of facility personnel. Spill pallets

are used to provide secondary containment for unattended or temporarily stored mobile

containers. A facility layout map showing the location of the bulk storage containers, mobile

storage areas, spill kits, and other features covered by this Plan is included in Appendix A.

There are no underground storage tanks at the facility.

2.3 Discharge Prevention Measures [112.7(a)(3)(ii)]

The following discharge prevention measures will be employed where applicable:

I. When manually transferring oil between containers, equipment, tanks, or

tankers, the transfer operation will be attended at all times.

II. Prior to any transfer operation between containers, tanks, and/or tankers, the

item to be filled shall be checked to ensure the integrity of the container and

that adequate fill margin is available so that overflow does not occur.

III. When loading or unloading oil into or out of tanks or equipment, special

precautions to prevent any amount of oil from reaching the ground will be

taken. These precautions should include the use of absorbent pads, drip

pans, or other means to prevent a release of oil to the environment. Valves

and hoses will be wiped off as necessary to prevent oil drips from reaching

the ground.

IV. Mobile or portable storage tanks and tank trucks shall be positioned or

located so as to prevent spilled oil from reaching yard drains, sewer inlets, or

waterways. If this is not possible, spill prevention equipment, such as drip

pans, drain covers, and barrier booms will be used to prevent a release from

reaching the ground.




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V. Outside contractors doing work at the facility shall be notified and required

to comply with the applicable portions of this SPCC Plan.

VI. Oil Transfer Operations: General oil transfer procedures are outlined in

Appendix C.

2.4 Discharge Controls [112.7(a)(3)(iii)]

In general, Hughes provides appropriate containment and/or diversionary structures or equipment

to prevent a discharge as described in the SPCC regulations. All facility equipment including the

oil well, flow lines, gathering lines, processing equipment, and bulk storage containers are

positioned within a 2’ X 2’ storm water berm with dimensions of 298’ X 298’ by 2’, providing

approximately 1,328,500 gallons of secondary containment. The containment system is capable

of containing oil and is constructed such that any discharge will not escape the containment

system before cleanup occurs. At a minimum, Hughes utilizes one or more of the following

prevention systems or its environmental equivalent to control discharges:

Dikes, berms or retaining walls

Double-walled tanks

Curbing

Culverting, gutters, or other drainage systems

Weirs, booms or other barriers

Sorbent materials

2.5 Discharge, Discovery, Response, and Cleanup [112.7(a)(3)(iv)]

The basic concept of this Plan is that personnel who discover a leak or spill, whether by routine

or non-routine inspections, take immediate action designed to stop, or at least slow, the spill and

to minimize further damage. Personnel discovering the spill will be designated the "First

Responder" and will have specific responsibilities with regard to spill control and

countermeasures. The First Responder will notify his supervisor or the Primary Spill Response

Coordinator, who will then implement additional actions of spill response (control and

containment) and notification.




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In the event of an oil spill (that does not constitute an imminent threat to health and safety), the

following actions will be taken by facility personnel upon discovery of the spill:

First Responder - personnel discovering the spill must:

Identify the leaking/spilled substance;

Shut off, or slow the rate of, the spill or release;

Eliminate any source of ignition in the area;

Control the spreading of spilled material to the extent practical; and,

Notify a supervisor or the Primary or Secondary Spill Response Coordinator. This

notification should include the source of the spill, the type of material spilled, the

approximate rate of discharge, and the approximate extent of spillage that has

already taken place.

Primary or Secondary Spill Response Coordinator - depending on which one is available at the

time of the spill, must immediately:

Arrange for dispatching personnel, equipment, and materials, as necessary, to

contain and control the spill;

Coordinate containment and control actions, such as construction of earth berms,

dikes or diversion ditches, placement of absorbent materials, etc.;

As applicable notify the Operations Manager, Field Gauger, and Production

Superintendent of the spill and provide information regarding the source and type of

spill, location of the spill, and the name and location of any off-site water bodies

that may be impacted by the spill;

Make external notification in accordance with the procedures outlined in Section 3.0

of this Plan;

Commence and complete countermeasures (recovery of spilled material, clean up

impacted spill area), provide security for the spill area, and coordinate any

communications with the news media; and,




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Complete the Spill/Release Notification Form (Appendix D) or other reports and

submit these to the Operations Manager for review.

The facility maintains a variety of spill containment and recovery equipment and materials,

including designated Spill Kits. Spill Kits are strategically located near potential spill sources

and typically consist of a 55-gallon DOT drum or similar container, a spark-free shovel,

chemical-resistant rubber gloves, broom, and absorbent materials (pads, socks, and booms). In

addition to the Spill Kits for minor spills, the facility maintains excavation equipment to

immediately address large spills. Other available equipment and materials include pumps,

drums, and assorted sorbent materials.

In the event of a large release requiring use of mechanized equipment, the Primary or Secondary

Spill Response Coordinator shall contact a qualified emergency response contractor.

2.6 Disposal of Recovered Materials [112.7(a)(3)(v)]

Disposal of recovered oil and oil-contaminated materials will take place in accordance with

applicable local, state, and federal regulations. Produced water will be temporarily stored in two

bulk storage containers pending offsite disposal at a permitted facility. Depending on the quality

and volume of produced water, Hughes will evaluate using the on site underground injection well

for disposal.

2.7 Emergency Contact List [112.7(a)(3)(vi)]

The following Hughes personnel shall be contacted in the event of a release requiring response

actions.

Operations Manager – (361) 358-3752

Production Superintendent – (361) 358-3752

Field Gauger – (361) 358-3752




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3.0 SPILL REPORTING INFORMATION [112.7(a)(4)]

3.1 General Reporting Information

Hughes will conduct internal and external notification and reporting in the event of an oil release.

The Primary Spill Response Coordinator is responsible for ensuring all appropriate notifications

have been made. All discharges should be reported to the Operations Manager and documented

on the Spill/Release Notification Form included in Appendix D.

Minor spills may be cleaned up by facility personnel provided the following conditions are met;

The spill has not resulted in a release to the environment or caused a threat to human

health;

Spill response materials are available and in good condition;

Appropriate personal protective equipment (PPE) is available;

The extent of the spill is limited to less than 10 gallons.

Minor spills do not require notification to external agencies. All recovered materials will be

appropriately contained, labeled, and properly disposed in accordance with state local

regulations.

3.2 Regulatory Reporting Information [112.4 (a) – (c)]

External notification is required for a discharge that results in ANY of the following:

A violation of water quality standards

Visible film or sheen on the water surface

Sludge or emulsion deposited below the water surface

Release of greater than 25 gallons to any surface

Response efforts that require additional state or federal assistance.




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All reportable spills shall be documented on the Spill Release/Notification Form included in

Appendix D.

If a discharge of oil reaches navigable waters of the United States, it is immediately reportable to

the National Response Center (NRC) under 40 CFR Part 110, which was established under the

authority of the Clean Water Act (CWA). Discharges of oil must be reported if they "cause a

film or sheen upon or discoloration of the surface of the water or adjoining shorelines or cause a

sludge or emulsion to be deposited beneath the surface of the water or upon adjoining

shorelines." (40 CFR 110.3(b)).

Additionally, whenever the facility discharges greater than 1,000 gallons of oil in a single

discharge event, or discharges more than 42 gallons of oil in each of two discharges occurring

within a 12-month period, the U.S. EPA Regional Administrator must be notified in writing

within 60 days of the subject spill.

Following notification of the reportable release, the NRC should contact the State Watch Office

(SWO), who in turn contacts the district office of the Florida Department for Environmental

Protection (FDEP); however, it is the responsibility of the Operations Manager to ensure all

appropriate external notifications have been made. The NRC and SWO shall be contacted

immediately following any releases meeting the aforementioned conditions. The FDEP shall be

notified within writing within 24 hours of the discovery of a discharge or before the close of the

next business day. The following is a list of federal, state, and local agencies to be contacted in

the event of a reportable release;

Danger to Life or Health

Police/Fire Department 911

Immediate Notification

National Response Center (800) 424-8802

State Watch Office (800) 320-0519




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Alternate Immediate Contacts

U.S. EPA Region IV Spill Reporting Center (404) 562-8700

U.S. Coast Guard, Region 7 (305) 535-4472

Subsequent Notifications

Collier County Emergency Management (239) 252-3600

FDEP Office of Emergency Response (Ft. Myers) (239) 344-5600

FDEP South District (239) 344-5600

4.0 SPILL PREDICTIONS, VOLUMES, RATE AND CONTAINMENT [112.7(b)]

Although various scenarios for equipment failure are possible for each oil source, a worst-case release

is assumed to be complete rupture of the largest container with instantaneous loss of all contents. The

largest bulk storage container is approximately 18,300 gallons for storage of crude oil. In the event of

a minor release from spills/drips or a catastrophic failure, oil would be contained inside the secondary

containment structure until clean up occurs.

5.0 CONTAINMENT AND DIVERSIONARY STRUCTURES [112.7(c)&(d)]

All facility equipment including the oil well, flow lines, gathering lines, processing equipment,

and bulk storage containers are positioned within a 2’ X 2’ storm water berm with dimensions of

298’ X 298’ by 2’, providing approximately 1,328,500 gallons of secondary containment. The

containment system is capable of containing oil and is constructed such that any discharge will

not escape the containment system before cleanup occurs in accordance with 112.1(b).

Based on the relatively high viscosity of crude oil, Hughes anticipates that any spills will be

cleaned up prior to reaching groundwater or migrating offsite. Due to the relatively low viscosity

of diesel and gasoline, and the transmissive sandy soil at the facility, either impermeable

secondary containment systems or double walled tanks are utilized for storage of diesel and

gasoline to minimize the potential for a release to impact human health or the environment.




12

The facility maintains a variety of spill containment and recovery equipment and materials,

including designated Spill Kits. Spill Kits are strategically located near potential spill sources

and typically consist of a 55-gallon DOT drum or similar container, a spark-free shovel,

chemical-resistant rubber gloves, broom, and absorbent materials (pads, socks, and booms). In

addition to the Spill Kits for minor spills, the facility maintains excavation equipment to

immediately address large spills. Other available equipment and materials include pumps,

drums, and assorted absorbent materials.

6.0 INSPECTIONS, TESTS, AND RECORDS [112.7(e)]

Hughes performs inspections, tests, and evaluations in accordance with the general procedures

outlined in the American Petroleum Institute (API) guidance manual entitled Recommended

Practice for Setting, Maintenance, Inspection, Operation, and Repair of Tanks in Production

Service, dated April 2008. The inspection program consists of informal daily observations and

scheduled monthly inspections as outlined below in Table 6-1.

Table 6-1: Inspection and Testing Program

Facility

Component Action Frequency/Circumstances

Aboveground

Bulk Storage

Container

Test container integrity. Combine visual

inspection with another testing technique in

accordance with standard industry practices

(e.g. non-destructive shell testing). Inspect

outside of container for signs of deterioration

and discharges.

Daily/Monthly visual

inspection. Integrity testing

schedule in accordance with

API RP 12R1.

Container

supports and

foundation

Inspect container supports and foundation. Monthly and whenever

material repairs are made.

Liquid level

sensing devices Test for proper operation. Monthly.

Diked Area Inspect for signs of deterioration, discharges,

or accumulation of oil inside diked areas. Monthly.

Lowermost

drain and all

outlets of tank

truck

Visually inspect. Prior to filling and departure.




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All

aboveground

valves, transfer

piping, and

appurtenances

Assess general condition of items, such as

flow lines, flange joints, expansion joints,

pipeline supports, locking of valves, and

metal surfaces.

Daily/Monthly.

Oil Well and

Injection Well

Inspect for evidence of oil seepage/release

from well head, flow lines, valves, gauges,

etc.

Daily/Monthly.

Discharge

response

equipment/spill

kits

Check inventory. Daily/Monthly.

6.1 Daily Observations

Hughes conducts informal daily observations while the facility is operational, including a site

walk and visual assessment of the bulk storage tanks, processing equipment, oil well, and the

injection well. Field operations personnel visually examine all above ground valves, polished

rod stuffing boxes, wellheads, fittings, gauges, and flowline piping. Any deficiencies identified

are immediately addressed and any evidence of spills/releases are immediately corrected and

reported to the Operations Manager.

6.2 Monthly Inspections

Monthly inspections are performed for the wellheads, flowlines, processing equipment, bulk storage

containers, aboveground piping, including the following elements, as applicable;

Observing the exterior of aboveground storage tanks, pipes, and other equipment for

signs of deterioration, leaks, corrosion, and thinning.

Observing tank foundations and supports for signs of instability or excessive

settlement.




14

Observing the tank fill and discharge pipes for signs of poor connection that could

cause a discharge, and tank vent for obstructions and proper operation.

Verifying the proper functioning of overfill prevention systems.

Observing the oil and injection well for evidence of seepage from the well, flowlines,

valves, and gauges.

Checking the inventory of discharge response equipment and restocking as needed.

All problems regarding the wells, bulk storage containers, piping, containment, or response

equipment must be immediately reported to the Operations Manager. Visible oil leaks from tank

walls or from tanks, piping, or other components must be repaired as soon as possible to prevent

a larger spill or a discharge to navigable waters or adjoining shorelines. Pooled oil must be

removed immediately upon discovery.

The monthly inspections are documented on the inspection form included in Appendix E. These

forms are signed by the Operations Manager or his designated representative and are maintained

with the SPCC Plan for a period of three years.

6.3 Periodic Integrity Testing

In addition to the previously described daily and monthly inspections by facility personnel, bulk

storage containers at that require a formal inspection are periodically evaluated by an outside

certified tank inspector following the guidelines outlined in the American Petroleum Institute

Standard API RP 12R1, Setting, Maintenance, Inspection, Operation, and Repair of Tanks in

Production Service, dated April 2008, as further described in Section 13.6 of this Plan.




15

7.0 TRAINING AND DISCHARGE PREVENTION PROCEDURES [112.7(f)]

7.1 Training [112.7(f)(1)]

All oil-handling personnel are trained, at a minimum, in the following:

Operation and maintenance of equipment to prevent discharges of oil;

Oil discharge procedure protocols;

Applicable pollution control laws, rules and regulations;

General facility operations; and

Contents of the facility SPCC Plan.

Facility personnel receive annual environmental, health, and safety training. The training

documentation records are included in Appendix F. All records of training to meet the SPCC

requirements are the responsibility of the Operations Manager and will be maintained for a

period of three (3) years.

7.2 Spill Prevention Coordinator [112.7(f)(2)]

The facility Spill Prevention Coordinator is the Operations Manager or his/her designee. The

Spill Prevention Coordinator is responsible for discharge prevention at the facility.

7.3 Oil Discharge Prevention Briefings [112.7(f)(3)]

Discharge prevention briefings for oil handling personnel will be conducted during scheduled

safety meetings or other meetings or training sessions. It is required that training be conducted

at least once per year for operating personnel to assure adequate understanding of the SPCC

Plan for the facility. These briefings must highlight and describe known discharges to navigable




16

waterways or failures, malfunctioning components and recently developed precautionary

measures. Records of the briefings will be maintained for three years (Appendix F).

8.0 SECURITY [112.7(g)]

In general, the facility is considered secure because equipment and other storage containers are

contained within a fenced area on private property that is accessible to authorized personnel only.

8.1 Fencing [112.7(g)(1)]

The facility is enclosed with security fencing. Gates are kept locked 24 hours per day. Access is

restricted to authorized personnel only.

8.2 Master Flow and Drain Valves [112.7(g)(2)]

If applicable, master flow and drain valves and any other valves permitting direct outward flow

of the container contents to the surface have adequate security measures so that they remain in

the closed position when in non-operating or standby status.

8.3 Oil Pump Starter Controls [112.7(g)(3)]

If applicable, the starter control on each oil pump is locked in the “off” position and accessible

only to authorized personnel when the pump is in a non-operating or standby status.




17

8.4 Loading/Unloading Connections [112.7(g)(4)]

The loading/unloading connections of oil pipelines or facility piping are securely capped or

blank-flanged when not in service for an extended time. This security practice also applies to

piping that is emptied of liquid content either by draining or by inert gas pressure.

8.5 Lighting [112.7(g)(5)]

The facility lighting is commensurate with the type and location of the facility to assist in the:

Discovery of oil discharges occurring during hours of darkness, both by operating

personnel and by non-operating personnel (i.e., general public, local police, etc.),

and

Prevention of oil discharges occurring through acts of vandalism.

9.0 FACILITY LOADING/UNLOADING RACK [112.7(h)]

Tank car and/or tank truck loading/unloading racks are not present the facility covered by this

Plan.

10.0 BRITTLE FRACTURE EVALUATION [112.7(i)]

Field-constructed bulk storage containers are not present at the facility covered by this Plan.

Therefore, brittle fracture evaluation requirements are not applicable.

11.0 OTHER APPLICABLE DISCHARGE PREVENTION REGULATIONS [112.7(j)]

No more stringent SPCC state or local rules, regulations, or guidelines apply to the facility

covered by this Plan. Per U.S. EPA guidelines, a reportable release will "cause a film or sheen




18

upon or discoloration of the surface of the water or adjoining shorelines or cause a sludge or

emulsion to be deposited beneath the surface of the water or upon adjoining shorelines." (40 CFR

110.3(b)).

12.0 OIL PRODUCTION FACILITY DRAINAGE [112.9(b)]

All facility equipment including the oil well, flow lines, gathering lines, processing equipment,

and bulk storage containers are positioned within a 2’ X 2’ storm water berm with dimensions of

298’ X 298’ by 2’, providing approximately 1,328,500 gallons of secondary containment. The

containment system is capable of containing oil and is constructed such that any discharge will

not escape the containment system before cleanup occurs in accordance with 112.1(b). Any

accumulated precipitation within the secondary containment is emptied using pumps. These

pumps are manually activated and the condition of all accumulated storm water is inspected for

the presence of a sheen before pumping to ensure that no oil is discharged. Drainage events are

recorded on the Secondary Containment Drainage Log, included in Appendix G of this Plan.

13.0 BULK OIL STORAGE CONTAINERS [112.9(c)]

13.1 Oil Storage Container Compatibility [112.9(c)(1)]

All containers used for the storage of oil at the covered by this Plan are of a material and

construction compatible with the oil stored and conditions of storage, such as pressure and

temperature.

13.2 Oil Storage Container Secondary Containment and Drainage [112.9(c)(2)]

Drainage of uncontaminated rainwater from diked areas with bulk oil storage tanks will not be

allowed to enter a storm drain or be discharged into an open watercourse, lake, or pond until the




19

retained rainwater is inspected for a sheen to prevent a discharge of oil to a waterway. All

drainage of the secondary containment shall be documented on the Secondary Containment

Drainage Log included in Appendix G.

13.3 Inspection, Tests, and Records [112.9(c)(3)]

Visual inspections of wells, flowlines, bulk storage containers, and secondary containment by

facility personnel are performed according to the procedures described in Section 6.0 of this

SPCC Plan. Leaks from tank seams, gaskets, rivets, and bolts are promptly corrected. The

monthly inspections are documented on the inspection form included in Appendix E. These

forms are signed by the Operations Manager or his designated representative and are maintained

with the SPCC Plan for a period of three years.

The scope and schedule of certified inspections and tests performed on the facility bulk storage

containers are specified in the guidelines outlined in the American Petroleum Institute Standard

API RP 12R1, Setting, Maintenance, Inspection, Operation, and Repair of Tanks in Production

Service. Tanks that require a formal inspection by a certified tank inspector, which lack previous

inspection records, will undergo a formal inspection within 15 years of the date of construction.

The initial formal inspection will determine the suitability for continued use and the date of the

next scheduled formal inspection.

Fifty-five (55) gallon drums, portable totes and tanks, and other single-use containers will be

subject to visual inspections only.

13.4 Overflow Prevention [112.9(c)(4)]

Bulk tank installations will be engineered or updated in accordance with good engineering

practice to avoid discharges. At least one of the measures listed here and described in the




20

regulations will be provided for this purpose and will be tested regularly, unless equivalent

environmental protection is provided.

(i) High liquid level alarms;

(ii) High liquid level pump cutoff devices;

(iii) Direct communication between gauging attendant and pumping station;

(iv) Liquid level fast response systems.

14.0 OIL TRANSFER OPERATIONS [112.9(d)]

14.1 Flowline Maintenance [112.9(d)(3)]

The flowline maintenance program is implemented to maintain the integrity of flow lines to

minimize the potential for oil to be released to the environment. The gathering lines and

flowlines are inspected daily and monthly during routine inspections that are further described in

Section 6.0 of this plan. The inspection includes a visual assessment of potential leaks (or

potential future sources) within the piping and valve connections, corrosion of the external

coating, flowline supports, and connections to the wells, processing equipment, and bulk storage

containers. The flowlines will be evaluated using ultrasonic thickness measurement every five

years to determine corrosion rates, wall thickness, and mechanical integrity. Copies of the

integrity testing results will be maintained with the Plan for a minimum of 10 years.

The well pump is equipped with a low-pressure automatic shutoff system to detect pressure drops

and minimize spill volumes in the event of a leak. Flow lines will be depicted on the facility

diagram and will be marked in the field to allow operators to readily identify shutoff valves in the

event that a portion of a flowline must be isolated. In the event a flowline leak is identified,

operators will immediately address any releases, isolate the subject flowline section, and repair or

replace the equipment before returning to service.




21

14.2 Saltwater Disposal System [112.9(d)(2)]

The facility maintains one saltwater injection well (Permit #1350) to dispose of uncontaminated

water. Components of the produced water disposal system are inspected on a daily and monthly

basis by field operation personnel as described in Section 6.0. of this Plan. The inspection

includes the pumps and motors for proper condition, hoses, valves, flowlines, and the saltwater

injection wellhead. Maintenance and operation of the well itself and the downhole injection

comply with and the FDEP and U.S. EPA Underground Injection Control (UIC) rules and

regulations (40 CFR parts 144-148).


APPENDIX A

SITE LOCATION & FACILITY LAYOUT MAPS


COLLIER-HOGAN SPCC PLAN

FIGURE 1: LOCATION MAPReceived DEP O&G

4/22/2014

SITE


FIGURE 2: TOPO MAP

00

2000'1000'

SCALE: 1" = 2000'

MAP PROVIDED BY:


APPROXIMATE

PROJECT BOUNDARY

00

100'50'

SCALE: 1" = 100'

AERIAL IMAGERY: 2012 COLLIER COUNTY


FIGURE 3: AERIAL PLANReceived DEP O&G

4/22/2014

00

50'25'

SCALE: 1" = 50'


FIGURE 4: FACILITY LAYOUTReceived DEP O&G

4/22/2014

APPENDIX B

OIL STORAGE TANK INVENTORY TABLE


Tank No. Contents Configuration

Shell

Material

Height /

Length

Diameter

(ft)

Volume

(Gal) Fill Method

Overfill

Protection Secondary Containment

1 Crude Oil & Water Vertical Cylinder Carbon Steel 24 12 19,068 Automatic High-Level Alarm 298' X 298' X 2' Gravel Berm

2 Waste Water Vertical Cylinder Fiberglass 15 10 8,820 Automatic High-Level Alarm 298' X 298' X 2' Gravel Berm

3 Waste Water Vertical Cylinder Fiberglass 15 10 8,820 Automatic High-Level Alarm 298' X 298' X 2' Gravel Berm

4 Crude Oil Vertical Cylinder Carbon Steel 16 14 18,312 Automatic High-Level Alarm 298' X 298' X 2' Gravel Berm




8 Diesel Horizontal Cylinder Carbon Steel 12 4.5 1,034 Manual Stick Gauge Double-Wall Tank

9 Diesel Horizontal Cylinder Carbon Steel 12 4.5 1,034 Manual Stick Gauge Double-Wall Tank

OIL STORAGE TANK INVENTORY

COLLIER-HOGAN OIL WELL PERMIT #1349


APPENDIX C

GENERAL OIL TRANSFER PROCEDURES


OIL TRANSFER PROCEDURE

Transferring of oil to/from a tank presents the highest level of interaction between the oil storage tanks and

facility or contractor personnel. Since there is a higher probability for spills to occur during oil transfers, the

following spill prevention procedure is utilized:

Stage Tasks

Prior to loading/

Unloading

□ Visually check all hoses for leaks and wet spots.

□ Verify that sufficient volume (ullage) is available in the storage tank or truck.

□ Lock in the closed position all drainage valves of the secondary containment

structure.

□ Secure the tank vehicle with wheel chocks and interlocks.

□ Ensure that the vehicle’s perking brakes are set.

□ Verify proper alignment of valves and proper functioning of the pumping system.

□ If filling a tank truck, inspect the lowermost drain and all outlets.

□ Establish adequate bonding/grounding prior to connecting to the fuel transfer point.

□ Turn off cell phone.

During loading/

unloading □ Driver must stay with the vehicle at all times during loading/unloading activities.

□ Periodically inspect all systems, hoses and connections.

□ When loading, keep internal and external valves on the receiving tank open along

with the pressure relief valves.

□ When making a connection, shut off the vehicle engine. When transferring Class 3

materials, shut off the vehicle engine unless it is used to operate a pump.

□ Maintain communication with the pumping and receiving stations.

□ Monitor the liquid level in the receiving tank to prevent overflow.

□ Monitor flow meters to determine rate of flow.

□ When topping off the tank, reduce flow rate to prevent overflow.

After loading/

unloading

□ Make sure the transfer operation is completed.

Close all tank and loading valves before disconnecting.

□ Securely close all vehicle internal, external, and dome cover valves before

disconnecting.

□ Secure all hatches.

□ Disconnect grounding/bonding wires.

□ Make sure the hoses are drained to remove the remaining oil before moving them

away from the connection. Use a drip pan.

□ Cap the end of the hose and other connecting devices before moving them to

prevent uncontrolled leakage.

□ Remove wheel chocks and interlocks.

□

Inspect the lowermost drain and all outlets on tank truck prior to departure. If

necessary, tighten, adjust, or replace caps, valves, or other equipment to prevent oil

leaking while in transit.


APPENDIX D

SPILL/RELEASE NOTIFICATION FORM


Spill/Release Notification Form

Page 1 of 2

Facility:

REPORTING PARTY

Name:

Title:

Phone Number:

Company:

Address:

City/State/Zip: INCIDENT DESCRIPTION

Incident Date Incident Time Report Date Report Time

Material Released: Approximate Quantity

Location of Spill/Release

Longitude (if known): Latitude (if known):

Discharge

Source

Tank

Drum/portable container

Oil-containing equipment

Oil piping

Other

Unknown

Description:

Cause and Circumstances of the Spill or Release:

Existing or Potential Hazards (fire, explosion, etc.) if any:

IMPACT

Number of Injuries:

Number of Fatalities:

Evacuation Required?:

Property Damage?:

Yes No

Yes No

If yes, describe below:


Spill/Release Notification Form

Page 2 of 2

RESPONSE ACTIONS

Action Taken to Correct or Mitigate the Incident:

Actions Planned to Prevent Recurrence:

NOTIFICATIONS WITHIN COMPANY

Reported by: Reported to: Time Date

11:00 AM 09/44/2006

NOTIFICATIONS TO AGENCIES Reported by: Reported to: Agency Incident No. Time Date

ADDITIONAL INFORMATION (attach additional pages as necessary)


APPENDIX E

MONTHLY INSPECTION CHECKLIST


Appendix E: Monthly Inspection Checklist

Further description and comments, if needed, should be provided on a separate sheet of paper and

attached to this sheet. Any items answered “YES” needs to be promptly reported, repaired, or replaced,

as it may result in non-compliance with regulatory requirements. Records are maintained with the SPCC

Plan at the Collier-Hogan field office.

Date:_______________ Signature:___________________

Yes No

Description & Comments

(Note tank/equipment ID)

Storage tanks and Separation Equipment

Tank surfaces show signs of leakage ☐ ☐

Tanks show signs of damage, rust, or deterioration ☐ ☐

Bolts, Rivets or seams are damaged ☐ ☐

Aboveground tank supports are deteriorated or buckled ☐ ☐

Aboveground tank foundations have eroded or settled ☐ ☐

Gaskets are leaking ☐ ☐

Level gauges or alarms are inoperative ☐ ☐

Vents are obstructed ☐ ☐

Thief hatch and vent valve does not seal air tight ☐ ☐

Containment berm shows discoloration or stains ☐ ☐

Berm is breached or eroded or has vegetation ☐ ☐

Berm drainage valves are open/ broken ☐ ☐

Tank area clear of trash and vegetation ☐ ☐

Equipment protectors, labels, or signs are missing ☐ ☐

Piping/Flowlines and Related Equipment

Valve seals or gaskets are leaking. ☐ ☐

Pipelines or supports are damaged or deteriorated. ☐ ☐

Buried pipelines are exposed. ☐ ☐

Transfer Equipment

Loading/ Unloading lines are damaged or deteriorated. ☐ ☐

Connections are not capped or blank-flanged ☐ ☐

Secondary containment is damaged or stained ☐ ☐

Response Kit Inventory

Discharge response material is missing or damaged or needs replacement ☐ ☐

Additional Remarks (attach sheet as needed):


APPENDIX F

RECORDS OF ANNUAL SPCC TRAINING


RECORD OF ANNUAL SPCC PLAN TRAINING

Training will be scheduled and conducted annually to ensure adequate understanding of this SPCC Plan. The training will also highlight and describe known discharge events or failures, malfunctioning components, and recently implemented precautionary measures and best practices. Personnel will also be instructed in operation and maintenance of equipment to prevent the discharge of oil, and in applicable pollution laws, rules, and regulations.

Location:

Date:

Instructor:

Employee No. Signature Name Job Classification


APPENDIX G

SECONDARY CONTAINMENT DRAINAGE LOG


Secondary Containment Drainage Log

Facility: This form must be completed whenever rainwater from diked areas is drained into a storm drain or onto the ground. If a sheen is present, you must describe the measures taken to

prevent oily water from being discharged.

Inspector’s Diked Visible Sheen Time Time If sheen present

Date Signature Area ID No Yes Started Completed describe action taken


APPENDIX H

SUBSTANTIAL HARM CRITERIA


CERTIFICATION OF THE APPLICABILITY OF SUBSTANTIAL HARM CRITERIA Facility Name: Collier Hughes Oil Production Facility

Facility Location: Section 20, TWP 47 S, RNG 28E Bell Meade NE USGS 7.5 min QD

1. Does the facility transfer oil over water to or from vessels and does the facility have a total oil storage capacity greater than or equal to 42,000

gallons?

Yes ___ No _X__

2. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and does the facility lack secondary containment that

is sufficiently large to contain the capacity of the largest aboveground oil storage tank plus sufficient freeboard to allow for precipitation

within any aboveground oil storage tank area?

Yes ___ No _X__

3. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located at a distance (as

calculated using the appropriate formula in Attachment C-III to this appendix or a comparable formula 1) such that a discharge from the

facility could cause injury to fish and wildlife and sensitive environments? For further description of fish and wildlife and sensitive

environments, see Appendices I, II, and III to DOC/NOAA's "Guidance for Facility and Vessel Response Plans: Fish and Wildlife and

Sensitive Environments" (see Appendix E to this part, section 13, for availability) and the applicable Area Contingency Plan.

Yes ___ No _X__

4. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located at a distance (as

calculated using the appropriate formula in Attachment C-III to this appendix or a comparable formula1) such that a discharge from the

facility would shut down a public drinking water intake?2

Yes ___ No _X__

5. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and has the facility experienced a reportable oil

discharge in an amount greater than or equal to 10,000 gallons within the last 5 years?

Yes ___ No _X__

Certification

I certify under penalty of law that I have personally examined and am familiar with the information submitted in this document, and that

based on my inquiry of those individuals responsible for obtaining this information, I believe that the submitted information is true, accurate,

and complete.

______________________________________ ________________________________ Signature Title ______________________________________ ________________________________

Name (please type or print) Date

1 If a comparable formula is used, documentation of the reliability and analytical soundness of the comparable formula must be

attached to this form. 2 For the purposes of 40 CFR part 112, public drinking water intakes are analogous to public water systems as described at 40 CFR 143.2(c).


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