Frequently Asked Questions - DOC by liwenting

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									All references to “CCR Section” are to California Code of Regulations, Title 14.
       These regulations can be found in DOGGR Publication No. PRC04

                               Frequently Asked Questions:

                                      Facilities Sections
     CCR 1722.8          Bonding

1.   Is there an appeal process for a Life-of-Well or Life-of-Facility Bond imposed by order of the
     State Oil and Gas Supervisor?
     Pursuant to Public Resources Code section 3350, an operator may appeal an order from the
     State Oil and Gas Supervisor to the Director of the Department of Conservation.

     CCR 1722.9          Spill Contingency Plan Requirements

1.   Do I have to provide a map of ALL pipelines in my Spill Contingency Plans? No matter what
     the scale, there are so many pipelines in heavy oil areas that the maps wouldn’t be readable.
     Can main lines be submitted?
     CCR Section 1722.9 (f)(1) states that a map of the production facilities covered by the plan,
     shall include “labeling of all permanent tanks, equipment, and pipelines. If locations are not
     known, the most probable location shall be shown and identified as a probable location.” An
     electronic copy is preferred so that all pipelines can be seen at a usable scale.
2.   Will you accept a Federal SPCC plan to fulfill the requirements for a Spill Contingency Plan?
     The Federal SPCC plan may satisfy the state spill contingency plan requirement. However, if
     a federal SPCC Plan does not address all of the operator’s production facilities or it does not
     contain all of the information required by CCR Section 1722.9, the operator will need to
     prepare a supplement addressing these issues. A spill contingency plan template is available
     on DOGGR’s website.
3.   Can a Hazardous Materials Business Plan (HMBP) be substituted for the list of all chemicals
     for which a Material Safety Data Sheet (MSDS) is required per CCR Section 1722.9(g) for the
     spill contingency plan requirements?
     If an operator has completed a HMBP, it can be submitted to DOGGR. However, a HMBP
     only discusses chemicals stored in high volumes - so it may not replace the list of chemicals
     for which an MSDS is required.
4.   Do you have to submit shut down procedures in the Spill Contingency Plans?
     Operators are not required to submit this information to DOGGR. However, it must be readily
     available to be provided upon request. It is necessary to have complete information about
     emergency shutdown procedures and safety shutdown devices available, particularly for first
     responders.
5.   Do we have to list all installed sensor and alarm systems and where they are located on each
     tank, as part of the Spill Contingency Plan Requirements?
     No, operators just need to describe what systems are installed; see the spill contingency plan
     template at DOGGR’s website.

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     CCR 1760.           Definitions

1.   What is the definition of environmentally sensitive area?
      CCR Section 1760(e) defines an environmentally sensitive production facility.
     Click here to view the PRC04 document.
2.   If there is a production facility consisting of several tanks and they are located close to an
     environmentally sensitive area, such as a waterway, is it possible that some of the tanks will
     meet the environmentally sensitive production facility definition while other tanks within the
     same tank battery do not?
     Per CCR Section 1760(e), in this situation, only the tanks that are “within 200 feet…of
     designated waterways, or other surface waters such as lakes, reservoirs, rivers, canals,
     creeks, or other water bodies that contain water throughout the year” would meet the
     environmentally sensitive area definition.

     CCR 1773.1          Production Facility Secondary Containment

1.  Is secondary containment necessary for fresh water tanks?
    CCR Section 1760(k) excludes “fire suppressant equipment” from the definition of “production
    facility,” so fire water tanks do NOT have to have secondary containment. However, CCR
    Section 1773.1 does not provide an exemption for fresh water tanks. It states that “all
    production facilities storing and/or processing fluids…shall have secondary containment.”
    Therefore secondary containment is required for fresh water tanks not used for fire
    suppression.
2. Does a double wall tank satisfy secondary containment requirement?
    No. Secondary containment is defined as an “engineered impoundment such as a catch
    basin, which can include natural topographic features, that is designed to capture fluid
    released from a production facility.” The regulations do not differentiate between double and
    single walled tanks. All need secondary containment.
3. Does a heater-treater or separator constitute a tank?
    No, a heater-treater or separator is not a tank. However, they will both need secondary
    containment.
4. Is there an exemption to the secondary containment requirement due to the location of the
    production facility, such as on a hillside?
    No. If perimeter containment isn’t possible, a catch basin -- which is part of the secondary
    containment definition per CCR Section 1760(n) -- can be constructed.
5. Secondary containment around a heater-treater might be unsafe due to the proximity of
    flammable crude and an ignition source. Will there be variances from the requirement due to
    safety concerns?
    There is no exemption in the regulations for secondary containment around heater-treaters.
    The regulations do not require that fluid be contained immediately around the equipment. If a
    safety issue exists, the containment should be designed to channel the fluid away from the
    vessel.
 6. Headers are exempt from secondary containment per CCR Section 1773.1. Do the Automatic
    Well Testers (AWT) associated with them need to have secondary containment?
    No, the AWTs that are associated with header/manifold systems do not have to have
    secondary containment.
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 7. Does a tank that is empty of fluids and disconnected have to have secondary containment?
    No, CCR Section 1773.1 applies only to production facilities storing and/or processing fluids.
8. Can we use a soils engineering firm to run an analysis of the area around a production facility
    to test the soil and see if it can contain fluids per CCR Section 1773.1(c)? If the analysis
    shows that the soils are sufficiently compacted to retain fluids for 72 hours, will that satisfy the
    above referenced requirement?
    Yes, a soils analysis which shows that the area within the secondary containment is able to
    contain fluid for 72 hours will satisfy CCR Section 1773.1(c). Operators should be prepared to
    supply the analysis to DOGGR upon request.

     CCR 1773.2           Tank Construction and Leak Detection

1.   Will partial replacement of a tank bottom be a trigger for installing a leak detection system?
     No, CCR Section 1773.2 states that “when a tank bottom is replaced, a leak detection system
     shall be installed…” The entire tank bottom needs to be replaced for this section to apply.
2.   Are tanks that are designed and manufactured, but not yet installed, considered new tanks
     when they are installed at a later date?
     Yes, a tank is a “new tank” when it is installed.
3.   Will compacted earth satisfy the impermeable layer requirements for tanks?
     The intent of this regulation was to place an impermeable layer– examples include High
     Density Polyethylene (HDPE), cement, or gunite etc. -- to meet this requirement. In some
     cases, materials can be compacted to the point where they would create an impermeable layer
     and they may meet the requirement of this regulation.
4.   Does a concrete foundation without grooves satisfy the leak detection requirement and
     impermeable barrier requirement for CCR Section 1773.2(b)?
     Concrete does provide an impermeable barrier to prevent downward migration, but without the
     grooves it does not allow fluid to drain away from the tank to be detected by visual inspection.
     Therefore, it does not satisfy all of the conditions of CCR Section 1773.2 (b).
5.   Is moving an old tank to another facility considered “new construction?”
     Yes, installing or moving a tank to a new location would fall under new construction. At that
     point, per CCR Section 1773.2, the “sub-base of the foundation shall include an impermeable
     barrier designed to prevent downward fluid migration and to allow leaks to drain away from the
     tank and be detected by visual inspection.”
6.   How do we determine whether a production facility is located above subsurface fresh water?
     Among the ways to determine whether there is subsurface fresh water present are:

     1. Call the local DOGGR office.
     2. Contact your local Regional Water Quality Control Board (RWQCB).
     3. Visit DOGGR’s website:

        http://www.conservation.ca.gov/dog/pubs_stats/Pages/technical_reports.aspx
        Under California Oil & Gas Fields there are 3 volumes. Volume 1 covers Central California.
        Volume 2 covers Southern, Central Coastal, and Offshore. Volume 3 covers Northern
        California. Each oil field will have a data sheet that will indicate whether fresh water is
        present. At the bottom of the sheet is an area which reads: Base of fresh water (ft.). If it is


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blank or says none, then there isn’t any fresh water present. If there is a depth given that is
the depth to the Base of Fresh Water. See below:




                                     Page 4 of 8
9.   What leak detection system models are available for going under tanks?
     One publication that is available to help you is API Publication 334, First Edition, March 1996,
     “A Guide to Leak Detection for Aboveground Storage Tanks.” An operator could also consult
     with tank inspection/construction or repair companies for information regarding this matter.

     CCR 1773.3           Tank Maintenance and Inspections

1.   If an operator is cleaning a tank, or doing any other non-required maintenance, does DOGGR
     need to be notified for an inspection?
     No, DOGGR only needs to be notified for inspection or testing that is required by regulation.
2.   Are fiberglass repairs on a steel tank acceptable?
     Fiberglass is an acceptable repair for a steel tank. However, fiberglass is not heat tolerant and
     is not acceptable for heated tanks.
3.   Is there a size requirement for lettering on tanks?
     CCR Section 1773.3 requires that all tanks shall be properly identified with the operator’s tank
     ID, tank type, and appropriate hazard placards or labels. There isn’t a size requirement.
     However, CCR Section 1773.5 states that out-of-service production facilities shall have “Out-
     of-Service“ or “OOS “painted in bold letters at least one foot high, if possible, on the side of the
     tank or vessel at least five feet from the ground surface, or as high as possible, along with the
     date it was taken out of service.”

     CCR 1773.4           Tank Testing and Minimum Wall Thickness Requirements

1.   What is an acceptable method of tank wall or bottom thickness testing and what are the
     minimum number of readings required?
     Examples of methods of tank wall or bottom thickness testing are Ultrasonic, Radiographic (X-
     Ray), Magnetic Particle Testing, and Magnetic Flux Testing. The regulations don’t specify a
     minimum number of test points required, but the location and number of test points must be


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     adequate to ensure that the tank meets the minimum tank wall thickness requirement (0.06
     inch).
2.   Do we have to test the thickness of the tank roof?
     No, CCR Section 1773.4 only applies to the wall and bottom plate thickness of metal tanks that
     are subject to corrosion.
3.   What is a reportable quantity?
     Whether a discharge of oil is reportable depends on the location and, in some cases, the
     volume of the discharge. A summary of what is reportable can be found in the California State
     Oil Spill Contingency Plan, on page 5 –
     http://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=16612
4.   If I have fiber glassed or cemented the bottom of my tank, do I still have to comply with the
     bottom plate test requirement per CCR Section 1773.4?
     CCR Section 1773.4(h) states that “tanks that are not susceptible to corrosion, such as non-
     metal tanks and tanks with liners, are not subject to the requirement of this section…” Since
     the metal tank bottom has been replaced with a substance that is not subject to corrosion, it
     would be exempt from this requirement. However, the tank “shall be inspected and tested
     according to the manufacturer’s specifications or as requested by the Supervisor or district
     deputy.” The wall thickness testing requirements would still apply.

     CCR 1773.5           Out-of-Service Production Facility Requirements

1.   Is there a minimum threshold for a leaking tank? If a leaking tank can be repaired quickly,
     does it have to be taken out of service?
     There isn’t a minimum threshold for a leaking tank. Tanks that are leaking should not be in
     use. If fluid is escaping a tank, in any amount, the tank is not performing its basic design
     function of containing fluids safely. CCR Section 1773.5(a) allows an operator six months
     before an out-of-service production facility must be drained and secured. CCR Section 1773.5
     provides that production facilities may be reactivated as soon as repairs are completed,
     assuming that the production facility is not out of compliance with applicable testing and
     inspection requirements. If a tank has a minor leak that can be repaired quickly, then the tank
     can be put back into use quickly, without needing to comply with the Out-of-Service
     requirements of CCR Section 1773.5.
2.   Is there a size requirement for lettering on tanks?
     CCR Section 1773.3 requires that all tanks shall be properly identified with the operator’s tank
     ID, tank type and appropriate hazard placards or labels. There isn’t a size requirement.
     However, CCR Section 1773.5, states that out-of-service production facilities, shall have “Out-
     of-Service“ or “OOS “painted in bold letters at least one foot high, if possible, on the side of the
     tank or vessel at least five feet from the ground surface, or as high as possible, along with the
     date it was taken out of service.”

     CCR 1777.2           Production Facility Reporting Requirements

1.   Does returning an Out-of-Service tank to service have to be reported to or witnessed by
     DOGGR?



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     CCR Section 1777.2(4)(b) requires that “operators shall notify the local district office within 60
     days after…reactivating an Out-of-Service tank.” DOGGR does not need to witness the tank
     being returned to service.
2.   What is the format of the notification required under CCR Section 1777.2(b) for production
     facility reporting requirements? Is a phone call acceptable?
     Operators need to provide a written report (email is acceptable) to the local DOGGR office
     within 60 days after completing new construction, alteration, or decommissioning of a
     production facility, or reactivating an Out-of-Service tank. The report should describe what
     work was done to the production facility.
3.   Does DOGGR need to be called to witness tank wall and tank bottom thickness tests?
     Yes. CCR Section 1777.2(c) requires that operators notify the local DOGGR district office 48
     hours or more prior to conducting required tank or pipeline testing specified in CCR Sections
     1773.4 (tank testing) and 1774.1 (pipeline testing).
4.   Will DOGGR waive the 48 hour requirement to pressure test a pipeline that had a reportable
     quantity leak prior to placing it back in service?
     DOGGR needs to be notified of the pressure test so that we may witness the test if possible.
     However, in most cases DOGGR will not require an operator to wait 48 hours prior to putting a
     repaired pipeline that leaked a reportable quantity back into service.


     CCR 1777.3           Production Facility Documentation Retention Requirements

1.   Why do we need to record the qualifications of personnel that perform work on production
     facilities?
     Operators should be aware of the basic qualifications of staff and contractors who are
     conducting their repairs, maintenance, testing, and inspections. Including this information in
     the maintenance records will greatly enhance the value of the records. CCR Section 1777.3
     (b)(4) does not prescribe minimum standards for staff qualifications or otherwise dictate hiring
     practices or standards.

                                           Pipeline Section

1.   Do I have to provide a map of ALL pipelines in my Spill Contingency Plans? No matter what
     the scale there are so many pipelines in heavy oil areas, that the maps wouldn’t be readable.
     Can main lines be submitted?
     CCR Section 1722.9 (f)(1) states that a map of the production facilities covered by the plan,
     include “labeling of all permanent tanks, equipment, and pipelines. If locations are not known,
     the most probable location shall be shown and identified as a probable location”. An electronic
     copy is preferred so that all pipelines can be seen at a usable scale.
2.   How long do you have before you need to make your temporary repair to pipeline a permanent
     one? What is the definition of temporary repair?
     The term temporary is not defined by statute or regulation. Repairs should be completed as
     soon as reasonably possible.
3.   Do replaced pipelines need to be wrapped?



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     Yes, per CCR Section 1774(b), good oilfield practice includes, “Utilization of pipeline coating or
     external wrapping for new or replaced buried or partially buried pipelines to minimize
     external corrosion.”


4.  If a section of pipeline is replaced, how much of the line will be required to be tested?
    If the pipeline has a leak resulting in the release of a reportable quantity, the entire pipeline will
    need to be tested. However, if the whole pipeline is replaced (example from the wellhead to
    the header) the line doesn’t have to be tested. If a portion of the pipeline is replaced, the entire
    line must be tested.
5. Do I have to test all pipelines or can I test a representative sample?
    CCR Section 1774.2 requires a description of the testing method and schedule for all pipelines
    to be included in the Pipeline Management Plan. This section does not require pipeline
    testing. If the schedule is only for a certain portion of pipelines contained within the
    management plans, testing a representative sample would be acceptable.
6. What is a reportable quantity?
    Whether a discharge of oil is reportable depends on the location and, in some cases, the
    volume of the discharge. A summary of what is reportable can be in the California State Oil
    Spill Contingency Plan, on page 5:
     http://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=16612
7. To what pressure does a pipeline have to be tested after it has had a leak that resulted in the
    release of a reportable quantity?
    In order to verify the integrity of a pipeline, it should be tested to the Maximum Operating
    Pressure after it has been repaired.
8. Will DOGGR waive the 48 hour requirement to pressure test a pipeline that had a reportable
    quantity leak prior to placing it back in surface?
    DOGGR needs to be notified of the pressure test so that we may witness the test if possible.
    However, in most cases DOGGR will not require an operator to wait 48 hours prior to putting a
    repaired pipeline that leaked a reportable quantity back into service.
9. Will pipe lines inside a tank battery need to be tested?
    There is no variance for testing pipe lines within a tank battery. In situations, for pipelines
    which aren’t buried, for “process piping” that isn’t reasonably able to be pressure tested,
    corrosion testing, such as ultrasonic, would be allowed.
10. Do operators have to call every day for pipeline testing if they have ongoing tests planned?
    No, operators may submit a testing schedule.
    Operators are only required to notify DOGGR for testing of:
          Environmentally sensitive pipelines.
          Pipelines that have had a leak resulting in a release of a reportable quantity.
          Pipeline test ordered by the Supervisor (CCR1777.2 (c), or CCR 1774.1).




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