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.
Comment submitted by E. Duffy
This is comment on Rule
Oil Pollution Prevention: Non-Transportation Related Onshore Facilities; Spill Prevention, Control, and Countermeasure Rule - Final Amendments
View Comment
Related Comments
View AllPublic Submission Posted: 02/13/2009 ID: EPA-HQ-OPA-2007-0584-0189
Mar 05,2009 11:59 PM ET
Public Submission Posted: 02/19/2009 ID: EPA-HQ-OPA-2007-0584-0190
Mar 05,2009 11:59 PM ET
Public Submission Posted: 02/19/2009 ID: EPA-HQ-OPA-2007-0584-0191
Mar 05,2009 11:59 PM ET
Public Submission Posted: 02/27/2009 ID: EPA-HQ-OPA-2007-0584-0193
Mar 05,2009 11:59 PM ET
Public Submission Posted: 02/27/2009 ID: EPA-HQ-OPA-2007-0584-0194
Mar 05,2009 11:59 PM ET