| 3.
Rusty or Dirty Tanks - The EPA
seeks to invesigate these type facilities
after observing from a fly over, when
they are searching for oil spills. They
feel the operator may be having equipment
failure, or is careless in their
operations. Malfunctioning dumps and
surges in production sometimes cause such
problems of tanks running over. Vacum
trucks pulling bottoms also cause the
appearance of a tank to have been run
over. All old spillage should be cleaned
up as soon as possible, as well as tanks
sides cleaned. While painting tanks do
not make a lease produce more oil, a
freshly painted tank will provide the
appearance of a maintained lease.
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| 4.
Soil - Years of operating a
lease many times cause a lease to appear
to be a poorly operated facility. The
soil and gravel within the containment
area must be kept clean in case a natural
rainfall or spillage would cause the area
to float over the sides of the berms. The
soil and gravel around the tanks should
be kept level, and no higher than the
base of the tanks, so that if the bottom
of the tanks begin to leak, then the leak
will be observed. High soil also cause
the volume amount of the containment area
to be calculated incorrectly. Your spill
plan will detail the containment area and
surface volume which it will hold. .
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| 5.
Berms, Dykes, Firewalls - The
EPA is very concerned about your
containment areas to prevent oil spills.
The material used to create the berms of
the containment area must be of a
impermeable material, and maintained at
least to the minimum height of your SPCC
plan. The height all the way around the
containment area needs to be level, and
you should observe that the berms were
built to compensate for the degree of
slope. Since the berm height is taken
from the level of the bottom of the
tanks, do not build the tanks up on a
high level, conversley, lowering the
tanks will minimize the dyke height. All
moats, ditches and catch basins within
the containment area are not calculated
to determine the berm height, as the oil
will float out when these are full of
water. An operator should keep all rain
water out of the containment area at all
times. If the berm height is not
maintained, the EPA will fine the
operater regardless of a oil spill or
not. Firewalls are not to be the same
height as outer berms. .
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| 6.
Livestock and Fences - There
exist no legislation to keep the tank
battery fenced, on private lands. Yet
cattle and livestock can wear down your
berms and dikes, and rub on your
equipment to cause failure, leaks or oil
spills. Within residential areas the
issue of liability arises and an operator
can be fined .
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| 7.
Trash - All trash must be
removed from the containment area. This
means all jugs, barrels, litter,
abandoned equipment, pipe, fittings etc.
While all non-flammable materials just
need to be placed in one central area
outside the containment area, all
flammable materials and trash containers
need to be kept 75 feet away from your
containment area. If your facility looks
trashy from the air, and investigation on
the ground will follow. .
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| 8.
Catch Buckets - All load lines
penetrating the bermed containment area
must have some tyupe of catch bucket
underneath the valve / open end. These
buckets must have a lid and must be kept
sucked dry by the oil haulers. There is
no mandatory type of bucket, as the
operator is responsible should for any
spills that get out of the bucket. Not
recommended are 5 gallon buckets. .
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| 9.
Barrels - Any barrel not being
used as a trash barrel either needs to be
removed if empty or put on pallets or
racks. There are no exceptions. Barrels
outside the containment area, must have
their own containment area if it is fuel.
..
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| 10.
Load Lines - All load lines
whether inside or outsde the secondary
containment area must have a bull plug
installed. Legislation is pending to
require all loadline valves to be located
within the containment areas. API states
the point of custody transfer is at the
header valve on the tank. Yet the
operator is responsible for oil spills on
the lease. .
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| 11.
Dike Drains - Federal Law says
you can have a dike drain, but you must
have a bull plug in the drain and you
must documentate your drainage. You may
only drain fresh water with no sheen and
the salt content must be below EPA
mandaged requirements. It is your
responsibility to know what those current
requirements are. Dead vegitation below
the drain area is a sure sign to the EPA
you are not checking the salt content,
and EPA can and will fine the operator. .
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No Photo Available
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| 12.
Signs - Lease signs need to be
at facility as well as on the lease road
entry. The data on each sign varies from
state to state. .
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No
Photo Available
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| 13.
Hazzard Signs - Legislation is
pending that would require an operator to
label the tanks and above ground lines
every 100 feet. In an emergency, the
personnel on site need to know what is in
each tank, and it is the operator to let
the personnel know. .
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| 14.
Open Tanks or Pits - Open Tanks,
Pits, Salt Pots, etc must have some type
of net over the tank or pit. The purpose
of the nets is to keep wildlife out of
the tanks or pits. The EPA will use nets
to seine your vessels and pits, and any
animal found will cost the operator
money, be it a frong, owl, bat, bird or
rat. Vent hatches on enlclosed tanks must
be kept closed, with no exceptions.
Devices meant to scare away birds, etc,
are not approved methods of keeping
wildlive out of your facility. .
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| 15.
Separators and Well Heads -
Separators that have very little fluid
flowing through them (less than 42 Gal.
in 24 hours) don't technically have to
have a secondary containment area around
them, however, it is the operator's
responsibility to prevent and oil spill
outside a contained area. .
.
.
.
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| 16.
Electrical Panels - New
construction mandates electric outside of
the diked area. Eventually the EPA will
have all electric removed from inside the
containment. It does not make good sense
to put a electric panel inside a pond of
oil or salt water. .
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17. Brush and Trees
- Considered fire hazzards. All brush and
trees and overhanging limbs are to be
kept out of the containment area. The
operator will be fined for an unlevel
tank if a tree is growing out from
underneath the tanks. Dead foliage and
dead vegitation is a sign of pollution or
salt intrustion, and the EPA will fine
the operator. Green, lush vegetation
around your facility is a signal to the
EPA that the operator has had an oil
spill in the area and a fine can be
imposed.
.
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18. Pits -
Pits used to contain oil, sludge, etc,
must have a rubber liner. If you have a
non-lined pit full of oil that has been
dug out in the dirt next to your tanks,
it is considered an active oil spill and
the operator will be fined. Concretetanks
are grandfathered in right now, but if
the EPA comes to your facility they may
require you to drain and clan them so
they can be inspected for leakage and
cracks. If the soill around them is full
of oil you can get fined. From an
engineering viewpoint, replace them with
an approved above ground tank and clean
up any contaminated soils.
.
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19. High Volume Salt
Water Facilities - All
facilities that flow or dispose of large
volumes of salt water should take special
precaution to prevent a salt water spill.
To the EPA, a salt water spill is worse
in many ways than an oil spill.
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