Subject: SPCC Plan Development Timing
In response to the question about the timing for developing and implementing new SPCC plans, following are some of the comments I have received.
SPCC Plan Development: Current SPCC regulations require that plans be prepared and implemented prior to beginning operations at a facility. Previously, operators were given six months to prepare a plan and an additional six months to implement a plan after the beginning of operations for a new facility. Since oil and gas facilities are usually located in remote locations that are not easily accessible, preparation of SPCC plans prior to operation of a facility will result in production delays, additional costs and inefficiency. Once a well is drilled, time is required to test the well and size the equipment for the production rates. The inefficiencies will result if a PE needs to visit a site a second time after the testing and completion phase. Site visits and development of SPCC plans after completion will delay production. In addition, the transfer of numerous facilities from one operator to another will cause inefficiencies and delay production, if a new plan must be prepared prior to operation of the facility by the new owner. The regulation should allow six months after operation begins to prepare and implement a plan for a new facility and for acquisition of existing facilities.
From (one company’s) perspective, the timing issue is that we have approximately 75 drilling rigs running all the time. Some of the wells take 3 days to drill, some take 28 days, some take 45 days, and some take months. We easily have up to 100 new facilities being built in a month, but they are strewn across 8 states and in multiple counties. We have trained our construction foremen to build the locations to SPCC specifications (dikes with adequate storage capacity for the tanks and separators inside, secondary containment under load lines, etc.), so the secondary containment parts of the rule are being complied with from the beginning. In most cases, the drill wells are in fields where we already have lots of other wells, and SPCC plans already exist in the area that spell out contingency plan features including emergency callout lists, the location of absorbent pads, booms, etc. It's just the difficulty of getting someone to fill in the paperwork and getting a P.E. to certify the plans that makes the logistics difficult to accomplish without a six month lead time.
The underlying issue is that we can have some sense of the elements of an oil or natural gas production facility, but the final plan elements cannot be determined until the production details are determined. After that, the timing question is driven by the limitations of planning resources – including Professional Engineers – and any additional construction work that must be done. For larger companies more resources are available. For smaller ones the task is harder.