Comment submitted by E. Duffy

Document ID: EPA-HQ-OPA-2007-0584-0193
Document Type: Public Submission
Agency: Environmental Protection Agency
Received Date: February 25 2009, at 02:01 PM Eastern Standard Time
Date Posted: February 27 2009, at 12:00 AM Eastern Standard Time
Comment Start Date: February 3 2009, at 12:00 AM Eastern Standard Time
Comment Due Date: March 5 2009, at 11:59 PM Eastern Standard Time
Tracking Number: 808ddb4d
View Document:  View as format xml

View Comment

Contrary to suggestions in the preamble, production facilities having complex operations, including wells, separators, heater treaters, pumps, Tanks and injection wells. Marginal oil is produced from wells (17% of oil wells and 9% of gas wells) that operate on the lower edge of profitability. According to the Report of the National Energy Policy Development Group (May 2001), oil spills have been increasing since the early 1990’s. According to the report, the problem may caused by aging pipelines, storage tanks and other infrastructure components. Since these are the oldest of facilities, they would be the one posing the highest risk to the environment. At the current and predicted future crude oil prices, even stripper wells are producing healthy profits for their owners. States in general simply do not address equivalent requirements of the SPCC regulations and especially not to the extent the SPCC regulations go to prevent oil discharges.

Related Comments

    View All
Total: 59
Anonymous public comment
Public Submission    Posted: 02/13/2009     ID: EPA-HQ-OPA-2007-0584-0189

Mar 05,2009 11:59 PM ET
Anonymous public comment
Public Submission    Posted: 02/19/2009     ID: EPA-HQ-OPA-2007-0584-0190

Mar 05,2009 11:59 PM ET
Comment submitted by A. Martins
Public Submission    Posted: 02/19/2009     ID: EPA-HQ-OPA-2007-0584-0191

Mar 05,2009 11:59 PM ET
Comment submitted by E. Duffy
Public Submission    Posted: 02/27/2009     ID: EPA-HQ-OPA-2007-0584-0193

Mar 05,2009 11:59 PM ET
Comment submitted by David F. Darling, Director, Environmental Affairs, National Paint & Coatings Association
Public Submission    Posted: 02/27/2009     ID: EPA-HQ-OPA-2007-0584-0194

Mar 05,2009 11:59 PM ET