EarthFax evaluated four pump stations associated with a major U.S. petroleum pipe line company to ensure compliance with Spill Prevention, Control, and Countermeasure (“SPCC”) regulations and the requirements of the Oil Pollution Act of 1990 (“OPA-90”). These stations pump crude oil through 20- and 24-inch diameter pipe that extends 940 miles from Casper, Wyoming to St. Louis, Missouri.
We toured each site to review the layout of the facilities and inventory the respective storage capacities of the surge tanks and the spill containment. We then subcontracted with an aerial photography company to produce digital topographic maps of each facility, allowing us to efficiently evaluate containment and other conditions at the sites. Using this information, we determined whether existing spill containment structures at the facilities were adequate to control a worst-case discharge according to regulatory requirements.
To ensure facility compliance, we prepared SPCC plans for two of the facilities and an OPA-90 facility-specific response plan for one of the facilities. Plans that had been prepared for the remaining facility were adequate. We provided independent certification of each of the plans and included containment calculations and drawings that show applicable drainage areas, tank fields, oil groups, and inter-area conveyances. Under separate cover, we suggested improvements that would be required to bring the facilities into compliance with SPCC regulations and OPA-90 requirements.