Re: OIL SPILL in SAN FRAN and EPA rules
- From: oiltheearth@xxxxxxxxx
- Date: Tue, 4 Dec 2007 21:09:35 -0800 (PST)
On Nov 11, 8:26 pm, oiltheea...@xxxxxxxxx wrote:
EPA, with this action, is deregulating the oil industry...this action
is flying very low under the radar. This action proposes significant
reductions one of the few federal regulations protecting the nations
waters from oil spills. Look at the document in the docket called
EPA-HQ-OPA-2007-0584-0021 which shows the changes made to the rule at
OMB after the rule left EPA. This regulatory action WILL DEREGULATE
CERTAIN OIL DRILLING AND PRODUCTION EQUIPMENT....INCLUDING ON THE
NORTH SLOPE OF ALASKA....PLEASE COMMENT AND PROVIDE INPUT ON THE
ACTION
Please comment
Comment on the proposed SPCC rule amendment and review docket
documentshttp://www.regulations.govfollow the online instructions to comment
on Docket ID No. EPA-HQ-OPA-2007-0584
There is a very interesting piece in the production part of the
proposal. Look at the preamble language on page 58413 to page 58418
of the proposal titled " 6. Produced Water Storage Containers" EPA
asks for comment on approaches that were not in the original EPA
proposal that went to OMB (see red line strikeout document EPA-HQ-
OPA-2007-0584-0021 page 134 in the docket). In fact EPA asks for
comment on deregulating produced water tanks that hold oil yet the EPA
paper in the docket EPA-HQ-OPA-2007-0584-0015 clears shows an oil
spill risk from these tanks. More interesting is the fact that EPA
does not propose rule language only approaches. EPA should not
finalize any of these approaches without developing a supplemental
proposal (why no proposed rule language???...this seems odd).
Additionally, if you read page PAGE 134 OF THE POST OMB REVIEW RED
LINE STRIKE OUT VERSION OF THE RULE (EPA-HQ-OPA-2007-0584-0021) it is
clear this whole section was added after the rule left EPA, including
approaches from DOE???? EPA's seems to say in the EPA-HQ-
OPA-2007-0584-0015 document that these produced water tanks that hold
oil pose a risk of oil spillage, while their data in this document
also shows that this sector in enjoying an increasing spill trend as
compared to other sectors (see below).
Finally Read:
Page 48 of the document in the EPA docket called (EPA-HQ-
OPA-2007-0584-0015) Considerations for the Regulation of Onshore Oil
Exploration and Production Facilities Under the Spill Prevention,
Control, and Countermeasure Regulation 40 CFR part 112). The document
appears to state that the production sector has an increasing spill
rate as compared to other sectors. Please see this excerpt from page
48.
Looking at spill data over the longer time period covered by the ERC
database (1980
through 2003), we note that reported crude oil spills from production
activities have
generally increased during that time period (Exhibit 35), while
reported crude oil spills from
non-production sectors have generally decreased (Exhibit 36). This
trend may indicate an
increase in the frequency of oil discharges from onshore production
facilities, despite the
concurrent decrease in oil production discussed in Section 1 of this
paper.
Please take the time to comment on this rule. Comment on the proposed
SPCC rule amendment and review docket documents
http://www.regulations.gov follow the online instructions to comment
on Docket ID No. EPA-HQ-OPA-2007-0584 or try this direct link
http://www.regulations.gov/fdmspublic/component/main?main=DocumentDetail&d=EPA-HQ-OPA-2007-0584-0001
.
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