Under the auspices of the Federal Clean Water Act, the Environmental Protection Agency (EPA) requires oil and gas operators to have Spill Prevention Control and Countermeasure (SPCC) plans in place to mitigate damage to the inland waterways of the United States in the event of an unintended release of fluids from a production or SWD facility.
This requirement stems from a law passed decades ago and many operators are not in compliance, have plans that are out of date, or not properly maintained. When an event occurs that precipitates an inspection by the EPA, the fines for not having a plan in place or for not maintaining that plan are often more than the cost of a proper and properly maintained SPCC plan. Accordingly, it is a good practice to comply with this regulation.
Of course, the goal is to never have spills, but that is not realistic in the oil and gas arena. If you haven’t already, take a look at the numerous ways EPA inspectors can tie up your operations if you fail to maintain or manage your SPCC plan(s) with good operating procedures and within the regulation. While the EPA can’t sever you, you might wish they had when the final bill comes in. Proactive compliance is often cheaper and less disruptive to operations. Having proper plans in place and accurately maintained files flows directly to the bottom line in more ways than one. SPCC plans do not have to cost an arm and a leg to be effective.
Let Allied Testing:
• Develop and produce your SPCC plans
• Audit your current plans for compliance
• Assist in maintaining your plans
It does little good to try to patch the fence once the horse is out of the field, and it costs more money and energy to be reactive than to be proactive.