Inland Spill Contingency Plans Required by January 1, 2016

Owners/operators of Inland Pipelines, Oil Wells/Production Facilities, and Railroads located within 1/4 mile of surface Waters of the State must prepare and submit an Oil Spill Contingency Plan (C-Plan) to the Office of Spill Prevention and Response (OSPR).

Per new regulations adopted in September, 2015:

• C-Plans must ensure Best Achievable Protection from oil spill or threat of spill.
• All C-Plans must list at least one Rated OSRO by January 2016.
• Oil Spill Response Operators (OSROs) must be rated/confirmed by OSPR to have the personnel and equipment necessary to respond to all contingency plan needs for inland areas.
• Owner-operators can apply for rating as OSROs.
• C-Plans must include strategies to protect environmentally sensitive areas (ESAs).
• C-Plans must identify use of the Oiled Wildlife Care Network or acceptable alternative.

Written exemptions can be obtained for facilities located within ¼-mile of State surface waters depending on factors such as slope, elevation, specific gravity and pour point of oil produced or transported; permanent natural or man-made barriers; avoidance of natural or man-made drainage such as storm drains, culverts and canals. Small distribution lines (< 5/8-inch and < 10 miles) that would not impact waters of the State within 4 hours of a spill are also exempt. C-Plans are not required for equipment already regulated as underground storage tanks or above ground petroleum storage tanks.

InterAct can help you:

• Efficiently analyze whether or not your oil-related facility is located near State waters or where an oil spill could impact State waters, and whether or not it meets the criteria for exemption requests.
• Prepare supporting technical documentation for exemption requests.
• Quickly identify and develop protection strategies for any ESAs near your facilities.
InterAct’s Regulatory team has thorough knowledge of the new C-Plan requirements, and we are experienced at preparing C-Plans, developing spill prevention and mitigation measures, and identifying and evaluating environmentally sensitive areas.

This Regulatory Alert was prepared by InterAct, an Acteon company, to advise our clients of impending deadlines and applicable regulatory requirements. No official agency policy is implied.

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