DAN A. HUGHES COMPANY, L.P.

INTERIM SPILL PREVENTION, CONTROL &

COUNTERMEASURE PLAN



















Collier-Hogan Oil Well Permit #1349
Section 20, Township 47S, Range 28E
Naples, Collier County, Florida 34117

Prepared by:


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TABLE OF CONTENTS

SPCC CROSS REFERENCE TABLE [112.7] .................................................................................... iii
PROFESSIONAL ENGINEER CERTIFICATION [112.3(d)] ............................................................ v
LOG OF PLAN REVIEW AND AMENDMENTS [(112.5)] ............................................................. vi
MANAGEMENT APPROVAL [(112.7)] .......................................................................................... vii

1.0 GENERAL INFORMATION ........................................................................................... 1
1.1 Purpose [12.7(a)(1), 112.3(e)] ................................................................................. 1
1.2 Deviations from the Rule [112.7(a)(2)] ..................................................................... 1
1.3 Organization and Responsibilities ............................................................................ 1
2.0 FACILITY DESCRIPTION ............................................................................................. 3
2.1 Facility Operations [112.7(a)(3)] ............................................................................. 3
2.2 Facility Storage [112.7(a)(3)(i)] ............................................................................... 4
2.3 Discharge Prevention Measures [112.7(a)(3)(ii)] ....................................................... 5
2.4 Discharge Controls [112.7(a)(3)(iii)] ........................................................................ 6
2.5 Discharge, Discovery, Response, and Cleanup [112.7(a)(3)(iv)] .................................. 6
2.6 Disposal of Recovered Materials [112.7(a)(3)(v)] ...................................................... 8
2.7 Emergency Contact List [112.7(a)(3)(vi)] ................................................................. 8
3.0 SPILL REPORTING INFORMATION [112.7(A)(4)] ........................................................ 9
3.1 General Reporting Information ................................................................................ 9
3.2 Regulatory Reporting Information [112.4 (a) (c)] .................................................... 9
4.0 SPILL PREDICTIONS, VOLUMES, RATE AND CONTAINMENT [112.7(B)] ...............11
5.0 CONTAINMENT AND DIVERSIONARY STRUCTURES [112.7(C)&(D)] ......................11
6.0 INSPECTIONS, TESTS, AND RECORDS [112.7(E)] ......................................................12
6.1 Daily Observations ...............................................................................................13
6.2 Monthly Inspections ..............................................................................................13
6.3 Periodic Integrity Testing .......................................................................................14
7.0 TRAINING AND DISCHARGE PREVENTION PROCEDURES [112.7(F)] ....................15
7.1 Training [112.7(f)(1)] ............................................................................................15
7.2 Spill Prevention Coordinator [112.7(f)(2)] ...............................................................15
7.3 Oil Discharge Prevention Briefings [112.7(f)(3)] ......................................................15
8.0 SECURITY [112.7(G)] ....................................................................................................16
8.1 Fencing [112.7(g)(1)] ............................................................................................16
8.2 Master Flow and Drain Valves [112.7(g)(2)] ............................................................16
8.3 Oil Pump Starter Controls [112.7(g)(3)] ..................................................................16
8.4 Loading/Unloading Connections [112.7(g)(4)] .........................................................17
8.5 Lighting [112.7(g)(5)] ...........................................................................................17
9.0 FACILITY LOADING/UNLOADING RACK [112.7(H)] .................................................17
10.0 BRITTLE FRACTURE EVALUATION [112.7(I)] .........................................................17
11.0 OTHER APPLICABLE DISCHARGE PREVENTION REGULATIONS [112.7(J)] .......17
12.0 OIL PRODUCTION FACILITY DRAINAGE [112.9(B)] ...............................................18
13.0 BULK OIL STORAGE CONTAINERS [112.9(C)] .........................................................18
13.1 Oil Storage Container Compatibility [112.9(c)(1)] ..................................................18
13.2 Oil Storage Container Secondary Containment and Drainage [112.9(c)(2)] ................18
13.3 Inspection, Tests, and Records [112.9(c)(3)] ...........................................................19
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13.4 Overflow Prevention [112.9(c)(4)] ........................................................................19
14.0 OIL TRANSFER OPERATIONS [112.9(D)] ..................................................................20
14.1 Flowline Maintenance [112.9(d)(3)] ......................................................................20
14.2 Saltwater Disposal System [112.9(d)(2)] ................................................................21



LIST OF APPENDICES

Appendix A - Site Location and Facility Layout Maps
Appendix B - Oil Storage Tank Inventory Table
Appendix C - General Oil Transfer Procedure
Appendix D - Spill Release Notification Form
Appendix E - Monthly Inspection Checklist
Appendix F - Records of Annual SPCC Plan Training
Appendix G - Secondary Containment Drainage Log
Appendix H - Substantial Harm Criteria
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COLLIER-HOGAN SPCC CROSS REFERENCE TABLE
GUIDELINES FOR THE PREPARATION AND IMPLEMENTATION OF A SPILL PREVENTION
CONTROL AND COUNTERMEASURE PLAN

SPCC REGULATORY SECTION SECTION PAGE(S)
112.3 Requirements to prepare and implement a SPCC plan

112.3(d) P.E. certification of plan. - v
112.3(e) Maintain copy of plan. 1.1 1
112.4 Amendment of SPCC plan by regional administrator

112.4 (a)-(c) Discharge reporting. 3.2 9
112.5 Amendment of SPCC plan by owner/operator

112.5(a-c) Plan amendment, review, and P.E. certification. - vi
112.7 General requirements for Spill Prevention, Control and Countermeasure Plans
112.7 Management approval of Plan - vii
112.7(a)(1) Include discussion of facility's conformance with requirements. 1.1 1
112.7(a)(2) Deviation with regulations, equivalent environmental protection. 1.2 1
112.7(a)(3) Physical layout of facility and facility diagram. 2.1 3
112.7(a)(3)(i) Type of oil in each container and capacity. 2.2 4
112.7(a)(3)(ii) Discharge prevention measures. 2.3 5
112.7(a)(3)(iii) Discharge or drainage controls. 2.4 6
112.7(a)(3)(iv) Countermeasures. 2.5 6
112.7(a)(3)(v) Methods of waste disposal. 2.6 8
112.7(a)(3)(vi) Contact list/phone numbers. 2.7 8
112.7(a)(4) Discharge reporting procedures. 3.0 9
112.7(a)(5)
Organize plan in a way that makes discharge response procedures
readily useable. 1.0 1
112.7(b) Spill predictions. 4.0 11
112.7(c)(i-vi)
Provide appropriate diversion/containment to prevent discharge from
reaching navigable water. 5.0 11
112.7(d) Impracticability of control measures. 5.0 11
112.7(e) Inspections, tests, and records. 6.0 12
112.7(f)(1) Personnel training. 7.0 15
112.7(f)(2) Designate person accountable for discharge prevention. 7.2 15
112.7(f)(3) Discharge prevention briefings. 7.3 15
112.7(g) Security. 8.0 16,17
112.7(h) Loading/unloading racks. 9.0 17
112.7(i) Field-constructed AST and brittle fracture failure. 10.0 17
112.7(j) Other applicable standards. 11.0 17
112.9 SPCC Plan requirements for Onshore Oil Production Facilities


112.9(b)
Oil production facility drainage. 12.0 18
112.9(c)(1) Bulk storage container compatibility. 13.1 18

112.9(c)(2)
Secondary containment. 13.2 18
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COLLIER-HOGAN SPCC CROSS REFERENCE TABLE
GUIDELINES FOR THE PREPARATION AND IMPLEMENTATION OF A SPILL PREVENTION
CONTROL AND COUNTERMEASURE PLAN

SPCC REGULATORY SECTION SECTION PAGE(S)
112.8(c)(3) Inspections, tests, and records. 13.3 19
112.9(c)(4) Overflow prevention. 13.4 19
112.9(d) Oil transfer operations. 14.0 20
112.9(d)(3) Flowline maintenance. 14.1 20
112.9(d)(2) Saltwater disposal system. 14.2 21
112.20(e) Substantial Harm Criteria App. H -

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PROFESSIONAL ENGINEER CERTIFICATION [112.3(d)]


In accordance with 40 CFR Part 112.3(d), I hereby certify that I or my agent has visited and
examined the facility covered in this SPCC Plan, and being familiar with the requirements of 40 CFR
Part 112, attest that this Plan has been prepared in accordance with good engineering practice,
including consideration of applicable industry standards, and with the requirements of 40 CFR Part
112. I also certify that procedures for required inspections and testing as referenced in this SPCC
Plan have been established and that this SPCC Plan is adequate for this facility.


_________________________ _______________
Signature Date


Florida Registered Professional Engineer No.

DISCLAIMER: THIS INTERIM SPCC PLAN FOR THE COLLIER HOGAN OIL WELL
PERMIT #1349 IS BASED ON DESIGN INFORMATION AND NOT ACTUAL FIELD
CONDITIONS. THE PLAN WILL BE UPDATED AS NECESSARY TO REFLECT EXISTING
CONDITIONS, EQUIPMENT, PROCEDURES, ETC. FOLLOWING CONSTRUCTION, AT
WHICH TIME THE PROFESSIONAL ENGINEER CERTIFICATION AND MANAGEMENT
APPROVAL SECTIONS WILL BE FINALIZED.
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LOG OF PLAN REVIEW AND AMENDMENTS [112.5]
NON-TECHNICAL AMMENDMENTS
Non-technical amendments are not certified by a Professional Engineer.
Examples of changes include, but are not limited to, phone numbers, name changes or any non-technical text
change(s).
TECHNICAL AMENDMENTS
Technical amendments are certified by a Professional Engineer.
Examples of changes include, but are not limited to, commissioning or decommissioning containers; replacement,
reconstruction or movement of containers; reconstruction, replacements or installation of piping systems;
construction or demolition that might alter secondary containment structures; changes of product or service; or
revision of standard operation or maintenance procedures at the facility.
An amendment made under this section will be prepared within six (6) months of the change and implemented as
soon as possible, but no later than six months following the preparation of the amendment.
MANAGEMENT REVIEW
Management will review this SPCC Plan at least once each five (5) years and document the review on the form
below.
Review
Date
Printed Name Signature Amend Plan
(will/will not)









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MANAGEMENT APPROVAL [40 CFR 112.7]

This SPCC Plan for the Collier-Hogan facility addresses prevention of and response to releases
of oil. This Plan has the full approval of the appropriate Dan A. Hughes Company, LP (Hughes)
management personnel, who have the authority to commit the resources necessary to fully
implement it. Below is the signature of the appropriate management employee(s).



Signature Signature
Title Title
Date Date
Signature Signature
Title Title
Date Date

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1.0 GENERAL INFORMATION

1.1 Purpose [12.7(a)(1), 112.3(e)]

This SPCC Plan was developed in conformance with good engineering practices and with the oil
pollution control requirements outlined in 40 CFR Part 112.

The master copy of this SPCC Plan is maintained at the offices of Dan A. Hughes Company, LP
(Hughes) home office in Beeville, Texas. A field copy of this Plan will be kept on site with the
Field Gauger at the Collier-Hogan facility at all times during active operations. Records related
to this SPCC Plan, including equipment inspections and testing, employee training, and spill
reports are maintained by the Operations Manager, who is responsible for the upkeep of this
Plan.

1.2 Deviations from the Rule [112.7(a)(2)]

This SPCC Plan is designed to comply with the requirements outlined in 40 CFR 112. In the
event any deficiencies are identified in the implementation of this Plan, they will be addressed
using either a.) equivalent environmental protection, or b.) a recommendation for corrective
action by the certifying professional engineer.

1.3 Organization and Responsibilities

Key individuals will be identified as the Primary Spill Response Coordinator and the Secondary
Spill Response Coordinator. A description of the associated responsibilities for each position is
outlined in the following sections.



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Primary Spill Response Coordinator

The Field Gauger, or the Operation Managers specifically designated (in writing) representative,
is assigned as the Primary Spill Response Coordinator for the facility. The Primary Spill
Response Coordinator has the responsibility and authority for implementing the SPCC Plan.
He/she also must assure that all oil-handling personnel and site responders are adequately trained
regarding the provisions of the SPCC Plan and spill response procedures, so that they can
appropriately respond to any reasonably expected release.

The Primary Spill Response Coordinator will be available through contact cellular telephone, or
other 24-hour phone contact. In the absence of the Primary Spill Response Coordinator, a
designated Secondary Spill Response Coordinator shall be contacted to implement the SPCC
Plan in the event of an emergency.

Under normal circumstances, the Primary Spill Response Coordinator will be responsible for
coordinating spill response activities and notifying the responsible management personnel at
Hughes as well as external parties (in Section 3.0, Spill Reporting) of a spill or release. In the
event that neither the Primary Spill Response Coordinator nor Secondary Spill Response
Coordinator is able to implement these actions in a timely manner, the First Responder or other
local management personnel will be responsible for implementing the SPCC Plan.

Secondary Spill Response Coordinator

The Production Superintendent, or the Operation Managers specifically designated (in writing)
representative, is assigned as the Secondary Spill Response Coordinator for the facility. In order
to perform this role, the Secondary Spill Response Coordinator must be familiar with the SPCC
plan and response requirements.



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First Responder

During emergency situations, it is critical to have responsible personnel appointed and trained to
respond. Hughes will assign and train all Operations employees to serve as First Responders to
implement the site-specific provisions of the SPCC Plan. First Responders are familiar with the
operations of the Hughes equipment and facility, as well as the characteristics of hazardous
materials and wastes handled at the facility.

The First Responder will identify the problem, assess the health and environmental hazards, and
take all reasonable measures to stabilize the situation and minimize the extent of the spill or
release. The First Responder will then coordinate with the Primary (or Secondary) Spill
Response Coordinator to complete the spill response activities. These will include, but not be
limited to: removal and disposal of residues and contaminated soil, decontamination and
maintenance of emergency equipment, and submittal of the incident reports. These activities will
be directed by the Primary (or Secondary) Spill Response Coordinator.

2.0 FACILITY DESCRIPTION

2.1 Facility Operations [112.7(a)(3)]

The Collier-Hughes Oil Production facility is located at Section 20, Township 47S, Range 28E of
the Corkscrew NE United States Geological Survey 7.5 Minute Topographic Quadrangle Map in
Naples, Collier County Florida. The facility consists of one oil production well operated in
accordance with Oil Well Permit #1349 (Collier 20-3H), one salt water disposal well operated in
accordance with Injection Well Permit #1350 (Collier 20-5 SWDW), two water production wells,
and associated oil production equipment including generators, pumps, processing vessels, solid
waste disposal containers, fuel storage tanks, and crude oil storage tanks. Facility operations are
enclosed within a 2 X 2 storm water berm with approximate dimensions of 298 X 298. The
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oil production well will be located in the center of the enclosure at geographic coordinates
26.372251 North, 81.54086 West.

Produced fluids are initially transferred to a separator/heater to remove water from the crude oil.
Following separation, water is transferred to two 8,820-gallon polyethylene bulk storage
containers and crude is transferred into four 18,312-gallon steel bulk storage containers. The
water will be initially loaded into a truck for offsite disposal at a permitted disposal facility.
Depending on the volume and quality of water produced, Hughes will evaluate using the
injections well for disposal. The crude oil will be transferred to a truck for transportation and
sale offsite.

A site location map, aerial photograph, and a facility layout map are included in Appendix A.

2.2 Facility Storage [112.7(a)(3)(i)]

The facility has a total maximum oil storage capacity of approximately 100,000 gallons including
crude oil, oily wastewater, gasoline, and diesel fuel. The material and construction of bulk
storage containers at the facility are compatible with the material stored and conditions of
storage, such as pressure and temperature. Refer to the Oil Storage Tank Inventory table
included in Appendix B for a complete inventory of bulk oil storage containers.

Secondary containment for the crude oil and oily wastewater tanks is provided by a 2 X 2 storm
water berm with approximate dimensions of 298 X 298. Based on the relatively high viscosity
of crude oil, Hughes anticipates that any spills will be cleaned up prior to reaching groundwater
or migrating offsite. Due to the relatively low viscosity of diesel fuel and gasoline, the
transmissive sandy soil at the facility, impermeable secondary containment systems or double
walled tanks are utilized for storage of diesel and gasoline to minimize the potential for a release
to impact human health or the environment. Visible discharges that result in a loss of product
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from containers will be promptly addressed and any accumulations of oil in the diked area will be
promptly removed and disposed in accordance with applicable regulations.

Mobile storage containers that are subject to SPCC regulations (e.g., 55-gallon drums) are stored
in areas within buildings or designated oil storage areas that are designed to control discharges
when unattended and not under the direct oversight or control of facility personnel. Spill pallets
are used to provide secondary containment for unattended or temporarily stored mobile
containers. A facility layout map showing the location of the bulk storage containers, mobile
storage areas, spill kits, and other features covered by this Plan is included in Appendix A.
There are no underground storage tanks at the facility.

2.3 Discharge Prevention Measures [112.7(a)(3)(ii)]

The following discharge prevention measures will be employed where applicable:

I. When manually transferring oil between containers, equipment, tanks, or
tankers, the transfer operation will be attended at all times.

II. Prior to any transfer operation between containers, tanks, and/or tankers, the
item to be filled shall be checked to ensure the integrity of the container and
that adequate fill margin is available so that overflow does not occur.

III. When loading or unloading oil into or out of tanks or equipment, special
precautions to prevent any amount of oil from reaching the ground will be
taken. These precautions should include the use of absorbent pads, drip
pans, or other means to prevent a release of oil to the environment. Valves
and hoses will be wiped off as necessary to prevent oil drips from reaching
the ground.

IV. Mobile or portable storage tanks and tank trucks shall be positioned or
located so as to prevent spilled oil from reaching yard drains, sewer inlets, or
waterways. If this is not possible, spill prevention equipment, such as drip
pans, drain covers, and barrier booms will be used to prevent a release from
reaching the ground.

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V. Outside contractors doing work at the facility shall be notified and required
to comply with the applicable portions of this SPCC Plan.

VI. Oil Transfer Operations: General oil transfer procedures are outlined in
Appendix C.

2.4 Discharge Controls [112.7(a)(3)(iii)]

In general, Hughes provides appropriate containment and/or diversionary structures or equipment
to prevent a discharge as described in the SPCC regulations. All facility equipment including the
oil well, flow lines, gathering lines, processing equipment, and bulk storage containers are
positioned within a 2 X 2 storm water berm with dimensions of 298 X 298 by 2, providing
approximately 1,328,500 gallons of secondary containment. The containment system is capable
of containing oil and is constructed such that any discharge will not escape the containment
system before cleanup occurs. At a minimum, Hughes utilizes one or more of the following
prevention systems or its environmental equivalent to control discharges:
Dikes, berms or retaining walls
Double-walled tanks
Curbing
Culverting, gutters, or other drainage systems
Weirs, booms or other barriers
Sorbent materials

2.5 Discharge, Discovery, Response, and Cleanup [112.7(a)(3)(iv)]

The basic concept of this Plan is that personnel who discover a leak or spill, whether by routine
or non-routine inspections, take immediate action designed to stop, or at least slow, the spill and
to minimize further damage. Personnel discovering the spill will be designated the "First
Responder" and will have specific responsibilities with regard to spill control and
countermeasures. The First Responder will notify his supervisor or the Primary Spill Response
Coordinator, who will then implement additional actions of spill response (control and
containment) and notification.
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In the event of an oil spill (that does not constitute an imminent threat to health and safety), the
following actions will be taken by facility personnel upon discovery of the spill:

First Responder - personnel discovering the spill must:

Identify the leaking/spilled substance;

Shut off, or slow the rate of, the spill or release;

Eliminate any source of ignition in the area;

Control the spreading of spilled material to the extent practical; and,

Notify a supervisor or the Primary or Secondary Spill Response Coordinator. This
notification should include the source of the spill, the type of material spilled, the
approximate rate of discharge, and the approximate extent of spillage that has
already taken place.

Primary or Secondary Spill Response Coordinator - depending on which one is available at the
time of the spill, must immediately:

Arrange for dispatching personnel, equipment, and materials, as necessary, to
contain and control the spill;

Coordinate containment and control actions, such as construction of earth berms,
dikes or diversion ditches, placement of absorbent materials, etc.;

As applicable notify the Operations Manager, Field Gauger, and Production
Superintendent of the spill and provide information regarding the source and type of
spill, location of the spill, and the name and location of any off-site water bodies
that may be impacted by the spill;

Make external notification in accordance with the procedures outlined in Section 3.0
of this Plan;

Commence and complete countermeasures (recovery of spilled material, clean up
impacted spill area), provide security for the spill area, and coordinate any
communications with the news media; and,
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Complete the Spill/Release Notification Form (Appendix D) or other reports and
submit these to the Operations Manager for review.

The facility maintains a variety of spill containment and recovery equipment and materials,
including designated Spill Kits. Spill Kits are strategically located near potential spill sources
and typically consist of a 55-gallon DOT drum or similar container, a spark-free shovel,
chemical-resistant rubber gloves, broom, and absorbent materials (pads, socks, and booms). In
addition to the Spill Kits for minor spills, the facility maintains excavation equipment to
immediately address large spills. Other available equipment and materials include pumps,
drums, and assorted sorbent materials.

In the event of a large release requiring use of mechanized equipment, the Primary or Secondary
Spill Response Coordinator shall contact a qualified emergency response contractor.

2.6 Disposal of Recovered Materials [112.7(a)(3)(v)]

Disposal of recovered oil and oil-contaminated materials will take place in accordance with
applicable local, state, and federal regulations. Produced water will be temporarily stored in two
bulk storage containers pending offsite disposal at a permitted facility. Depending on the quality
and volume of produced water, Hughes will evaluate using the on site underground injection well
for disposal.

2.7 Emergency Contact List [112.7(a)(3)(vi)]

The following Hughes personnel shall be contacted in the event of a release requiring response
actions.

Operations Manager (361) 358-3752
Production Superintendent (361) 358-3752
Field Gauger (361) 358-3752
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3.0 SPILL REPORTING INFORMATION [112.7(a)(4)]

3.1 General Reporting Information

Hughes will conduct internal and external notification and reporting in the event of an oil release.
The Primary Spill Response Coordinator is responsible for ensuring all appropriate notifications
have been made. All discharges should be reported to the Operations Manager and documented
on the Spill/Release Notification Form included in Appendix D.

Minor spills may be cleaned up by facility personnel provided the following conditions are met;
The spill has not resulted in a release to the environment or caused a threat to human
health;
Spill response materials are available and in good condition;
Appropriate personal protective equipment (PPE) is available;
The extent of the spill is limited to less than 10 gallons.
Minor spills do not require notification to external agencies. All recovered materials will be
appropriately contained, labeled, and properly disposed in accordance with state local
regulations.

3.2 Regulatory Reporting Information [112.4 (a) (c)]

External notification is required for a discharge that results in ANY of the following:
A violation of water quality standards
Visible film or sheen on the water surface
Sludge or emulsion deposited below the water surface
Release of greater than 25 gallons to any surface
Response efforts that require additional state or federal assistance.

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All reportable spills shall be documented on the Spill Release/Notification Form included in
Appendix D.

If a discharge of oil reaches navigable waters of the United States, it is immediately reportable to
the National Response Center (NRC) under 40 CFR Part 110, which was established under the
authority of the Clean Water Act (CWA). Discharges of oil must be reported if they "cause a
film or sheen upon or discoloration of the surface of the water or adjoining shorelines or cause a
sludge or emulsion to be deposited beneath the surface of the water or upon adjoining
shorelines." (40 CFR 110.3(b)).

Additionally, whenever the facility discharges greater than 1,000 gallons of oil in a single
discharge event, or discharges more than 42 gallons of oil in each of two discharges occurring
within a 12-month period, the U.S. EPA Regional Administrator must be notified in writing
within 60 days of the subject spill.

Following notification of the reportable release, the NRC should contact the State Watch Office
(SWO), who in turn contacts the district office of the Florida Department for Environmental
Protection (FDEP); however, it is the responsibility of the Operations Manager to ensure all
appropriate external notifications have been made. The NRC and SWO shall be contacted
immediately following any releases meeting the aforementioned conditions. The FDEP shall be
notified within writing within 24 hours of the discovery of a discharge or before the close of the
next business day. The following is a list of federal, state, and local agencies to be contacted in
the event of a reportable release;
Danger to Life or Health
Police/Fire Department 911
Immediate Notification
National Response Center (800) 424-8802
State Watch Office (800) 320-0519
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Alternate Immediate Contacts
U.S. EPA Region IV Spill Reporting Center (404) 562-8700
U.S. Coast Guard, Region 7 (305) 535-4472
Subsequent Notifications
Collier County Emergency Management (239) 252-3600
FDEP Office of Emergency Response (Ft. Myers) (239) 344-5600
FDEP South District (239) 344-5600

4.0 SPILL PREDICTIONS, VOLUMES, RATE AND CONTAINMENT [112.7(b)]

Although various scenarios for equipment failure are possible for each oil source, a worst-case release
is assumed to be complete rupture of the largest container with instantaneous loss of all contents. The
largest bulk storage container is approximately 18,300 gallons for storage of crude oil. In the event of
a minor release from spills/drips or a catastrophic failure, oil would be contained inside the secondary
containment structure until clean up occurs.

5.0 CONTAINMENT AND DIVERSIONARY STRUCTURES [112.7(c)&(d)]

All facility equipment including the oil well, flow lines, gathering lines, processing equipment,
and bulk storage containers are positioned within a 2 X 2 storm water berm with dimensions of
298 X 298 by 2, providing approximately 1,328,500 gallons of secondary containment. The
containment system is capable of containing oil and is constructed such that any discharge will
not escape the containment system before cleanup occurs in accordance with 112.1(b).

Based on the relatively high viscosity of crude oil, Hughes anticipates that any spills will be
cleaned up prior to reaching groundwater or migrating offsite. Due to the relatively low viscosity
of diesel and gasoline, and the transmissive sandy soil at the facility, either impermeable
secondary containment systems or double walled tanks are utilized for storage of diesel and
gasoline to minimize the potential for a release to impact human health or the environment.
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The facility maintains a variety of spill containment and recovery equipment and materials,
including designated Spill Kits. Spill Kits are strategically located near potential spill sources
and typically consist of a 55-gallon DOT drum or similar container, a spark-free shovel,
chemical-resistant rubber gloves, broom, and absorbent materials (pads, socks, and booms). In
addition to the Spill Kits for minor spills, the facility maintains excavation equipment to
immediately address large spills. Other available equipment and materials include pumps,
drums, and assorted absorbent materials.

6.0 INSPECTIONS, TESTS, AND RECORDS [112.7(e)]

Hughes performs inspections, tests, and evaluations in accordance with the general procedures
outlined in the American Petroleum Institute (API) guidance manual entitled Recommended
Practice for Setting, Maintenance, Inspection, Operation, and Repair of Tanks in Production
Service, dated April 2008. The inspection program consists of informal daily observations and
scheduled monthly inspections as outlined below in Table 6-1.

Table 6-1: Inspection and Testing Program
Facility
Component
Action Frequency/Circumstances
Aboveground
Bulk Storage
Container
Test container integrity. Combine visual
inspection with another testing technique in
accordance with standard industry practices
(e.g. non-destructive shell testing). Inspect
outside of container for signs of deterioration
and discharges.
Daily/Monthly visual
inspection. Integrity testing
schedule in accordance with
API RP 12R1.
Container
supports and
foundation
Inspect container supports and foundation.
Monthly and whenever
material repairs are made.
Liquid level
sensing devices
Test for proper operation. Monthly.
Diked Area
Inspect for signs of deterioration, discharges,
or accumulation of oil inside diked areas.
Monthly.
Lowermost
drain and all
outlets of tank
truck
Visually inspect. Prior to filling and departure.
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All
aboveground
valves, transfer
piping, and
appurtenances
Assess general condition of items, such as
flow lines, flange joints, expansion joints,
pipeline supports, locking of valves, and
metal surfaces.
Daily/Monthly.
Oil Well and
Injection Well
Inspect for evidence of oil seepage/release
from well head, flow lines, valves, gauges,
etc.
Daily/Monthly.
Discharge
response
equipment/spill
kits
Check inventory. Daily/Monthly.

6.1 Daily Observations

Hughes conducts informal daily observations while the facility is operational, including a site
walk and visual assessment of the bulk storage tanks, processing equipment, oil well, and the
injection well. Field operations personnel visually examine all above ground valves, polished
rod stuffing boxes, wellheads, fittings, gauges, and flowline piping. Any deficiencies identified
are immediately addressed and any evidence of spills/releases are immediately corrected and
reported to the Operations Manager.

6.2 Monthly Inspections

Monthly inspections are performed for the wellheads, flowlines, processing equipment, bulk storage
containers, aboveground piping, including the following elements, as applicable;

Observing the exterior of aboveground storage tanks, pipes, and other equipment for
signs of deterioration, leaks, corrosion, and thinning.

Observing tank foundations and supports for signs of instability or excessive
settlement.

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Observing the tank fill and discharge pipes for signs of poor connection that could
cause a discharge, and tank vent for obstructions and proper operation.

Verifying the proper functioning of overfill prevention systems.

Observing the oil and injection well for evidence of seepage from the well, flowlines,
valves, and gauges.

Checking the inventory of discharge response equipment and restocking as needed.

All problems regarding the wells, bulk storage containers, piping, containment, or response
equipment must be immediately reported to the Operations Manager. Visible oil leaks from tank
walls or from tanks, piping, or other components must be repaired as soon as possible to prevent
a larger spill or a discharge to navigable waters or adjoining shorelines. Pooled oil must be
removed immediately upon discovery.

The monthly inspections are documented on the inspection form included in Appendix E. These
forms are signed by the Operations Manager or his designated representative and are maintained
with the SPCC Plan for a period of three years.

6.3 Periodic Integrity Testing

In addition to the previously described daily and monthly inspections by facility personnel, bulk
storage containers at that require a formal inspection are periodically evaluated by an outside
certified tank inspector following the guidelines outlined in the American Petroleum Institute
Standard API RP 12R1, Setting, Maintenance, Inspection, Operation, and Repair of Tanks in
Production Service, dated April 2008, as further described in Section 13.6 of this Plan.

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7.0 TRAINING AND DISCHARGE PREVENTION PROCEDURES [112.7(f)]

7.1 Training [112.7(f)(1)]

All oil-handling personnel are trained, at a minimum, in the following:
Operation and maintenance of equipment to prevent discharges of oil;
Oil discharge procedure protocols;
Applicable pollution control laws, rules and regulations;
General facility operations; and
Contents of the facility SPCC Plan.

Facility personnel receive annual environmental, health, and safety training. The training
documentation records are included in Appendix F. All records of training to meet the SPCC
requirements are the responsibility of the Operations Manager and will be maintained for a
period of three (3) years.

7.2 Spill Prevention Coordinator [112.7(f)(2)]

The facility Spill Prevention Coordinator is the Operations Manager or his/her designee. The
Spill Prevention Coordinator is responsible for discharge prevention at the facility.

7.3 Oil Discharge Prevention Briefings [112.7(f)(3)]

Discharge prevention briefings for oil handling personnel will be conducted during scheduled
safety meetings or other meetings or training sessions. It is required that training be conducted
at least once per year for operating personnel to assure adequate understanding of the SPCC
Plan for the facility. These briefings must highlight and describe known discharges to navigable
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waterways or failures, malfunctioning components and recently developed precautionary
measures. Records of the briefings will be maintained for three years (Appendix F).

8.0 SECURITY [112.7(g)]

In general, the facility is considered secure because equipment and other storage containers are
contained within a fenced area on private property that is accessible to authorized personnel only.

8.1 Fencing [112.7(g)(1)]

The facility is enclosed with security fencing. Gates are kept locked 24 hours per day. Access is
restricted to authorized personnel only.

8.2 Master Flow and Drain Valves [112.7(g)(2)]

If applicable, master flow and drain valves and any other valves permitting direct outward flow
of the container contents to the surface have adequate security measures so that they remain in
the closed position when in non-operating or standby status.

8.3 Oil Pump Starter Controls [112.7(g)(3)]

If applicable, the starter control on each oil pump is locked in the off position and accessible
only to authorized personnel when the pump is in a non-operating or standby status.





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8.4 Loading/Unloading Connections [112.7(g)(4)]

The loading/unloading connections of oil pipelines or facility piping are securely capped or
blank-flanged when not in service for an extended time. This security practice also applies to
piping that is emptied of liquid content either by draining or by inert gas pressure.

8.5 Lighting [112.7(g)(5)]

The facility lighting is commensurate with the type and location of the facility to assist in the:

Discovery of oil discharges occurring during hours of darkness, both by operating
personnel and by non-operating personnel (i.e., general public, local police, etc.),
and

Prevention of oil discharges occurring through acts of vandalism.

9.0 FACILITY LOADING/UNLOADING RACK [112.7(h)]

Tank car and/or tank truck loading/unloading racks are not present the facility covered by this
Plan.

10.0 BRITTLE FRACTURE EVALUATION [112.7(i)]

Field-constructed bulk storage containers are not present at the facility covered by this Plan.
Therefore, brittle fracture evaluation requirements are not applicable.

11.0 OTHER APPLICABLE DISCHARGE PREVENTION REGULATIONS [112.7(j)]

No more stringent SPCC state or local rules, regulations, or guidelines apply to the facility
covered by this Plan. Per U.S. EPA guidelines, a reportable release will "cause a film or sheen
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upon or discoloration of the surface of the water or adjoining shorelines or cause a sludge or
emulsion to be deposited beneath the surface of the water or upon adjoining shorelines." (40 CFR
110.3(b)).

12.0 OIL PRODUCTION FACILITY DRAINAGE [112.9(b)]

All facility equipment including the oil well, flow lines, gathering lines, processing equipment,
and bulk storage containers are positioned within a 2 X 2 storm water berm with dimensions of
298 X 298 by 2, providing approximately 1,328,500 gallons of secondary containment. The
containment system is capable of containing oil and is constructed such that any discharge will
not escape the containment system before cleanup occurs in accordance with 112.1(b). Any
accumulated precipitation within the secondary containment is emptied using pumps. These
pumps are manually activated and the condition of all accumulated storm water is inspected for
the presence of a sheen before pumping to ensure that no oil is discharged. Drainage events are
recorded on the Secondary Containment Drainage Log, included in Appendix G of this Plan.

13.0 BULK OIL STORAGE CONTAINERS [112.9(c)]

13.1 Oil Storage Container Compatibility [112.9(c)(1)]

All containers used for the storage of oil at the covered by this Plan are of a material and
construction compatible with the oil stored and conditions of storage, such as pressure and
temperature.

13.2 Oil Storage Container Secondary Containment and Drainage [112.9(c)(2)]

Drainage of uncontaminated rainwater from diked areas with bulk oil storage tanks will not be
allowed to enter a storm drain or be discharged into an open watercourse, lake, or pond until the
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retained rainwater is inspected for a sheen to prevent a discharge of oil to a waterway. All
drainage of the secondary containment shall be documented on the Secondary Containment
Drainage Log included in Appendix G.

13.3 Inspection, Tests, and Records [112.9(c)(3)]

Visual inspections of wells, flowlines, bulk storage containers, and secondary containment by
facility personnel are performed according to the procedures described in Section 6.0 of this
SPCC Plan. Leaks from tank seams, gaskets, rivets, and bolts are promptly corrected. The
monthly inspections are documented on the inspection form included in Appendix E. These
forms are signed by the Operations Manager or his designated representative and are maintained
with the SPCC Plan for a period of three years.

The scope and schedule of certified inspections and tests performed on the facility bulk storage
containers are specified in the guidelines outlined in the American Petroleum Institute Standard
API RP 12R1, Setting, Maintenance, Inspection, Operation, and Repair of Tanks in Production
Service. Tanks that require a formal inspection by a certified tank inspector, which lack previous
inspection records, will undergo a formal inspection within 15 years of the date of construction.
The initial formal inspection will determine the suitability for continued use and the date of the
next scheduled formal inspection.

Fifty-five (55) gallon drums, portable totes and tanks, and other single-use containers will be
subject to visual inspections only.

13.4 Overflow Prevention [112.9(c)(4)]

Bulk tank installations will be engineered or updated in accordance with good engineering
practice to avoid discharges. At least one of the measures listed here and described in the
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regulations will be provided for this purpose and will be tested regularly, unless equivalent
environmental protection is provided.

(i) High liquid level alarms;
(ii) High liquid level pump cutoff devices;
(iii) Direct communication between gauging attendant and pumping station;
(iv) Liquid level fast response systems.

14.0 OIL TRANSFER OPERATIONS [112.9(d)]

14.1 Flowline Maintenance [112.9(d)(3)]

The flowline maintenance program is implemented to maintain the integrity of flow lines to
minimize the potential for oil to be released to the environment. The gathering lines and
flowlines are inspected daily and monthly during routine inspections that are further described in
Section 6.0 of this plan. The inspection includes a visual assessment of potential leaks (or
potential future sources) within the piping and valve connections, corrosion of the external
coating, flowline supports, and connections to the wells, processing equipment, and bulk storage
containers. The flowlines will be evaluated using ultrasonic thickness measurement every five
years to determine corrosion rates, wall thickness, and mechanical integrity. Copies of the
integrity testing results will be maintained with the Plan for a minimum of 10 years.

The well pump is equipped with a low-pressure automatic shutoff system to detect pressure drops
and minimize spill volumes in the event of a leak. Flow lines will be depicted on the facility
diagram and will be marked in the field to allow operators to readily identify shutoff valves in the
event that a portion of a flowline must be isolated. In the event a flowline leak is identified,
operators will immediately address any releases, isolate the subject flowline section, and repair or
replace the equipment before returning to service.

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14.2 Saltwater Disposal System [112.9(d)(2)]

The facility maintains one saltwater injection well (Permit #1350) to dispose of uncontaminated
water. Components of the produced water disposal system are inspected on a daily and monthly
basis by field operation personnel as described in Section 6.0. of this Plan. The inspection
includes the pumps and motors for proper condition, hoses, valves, flowlines, and the saltwater
injection wellhead. Maintenance and operation of the well itself and the downhole injection
comply with and the FDEP and U.S. EPA Underground Injection Control (UIC) rules and
regulations (40 CFR parts 144-148).










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APPENDIX A

SITE LOCATION & FACILITY LAYOUT MAPS
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COLLIER-HOGAN SPCC PLAN
FIGURE 1: LOCATION MAP
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SITE
COLLIER-HOGAN SPCC PLAN
FIGURE 2: TOPO MAP
00
2000' 1000'
SCALE: 1" =2000'
MAP PROVIDED BY:
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APPROXIMATE
PROJ ECT BOUNDARY
00
100' 50'
SCALE: 1" =100'
AERIAL IMAGERY: 2012 COLLIER COUNTY
COLLIER-HOGAN SPCC PLAN
FIGURE 3: AERIAL PLAN
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00
50' 25'
SCALE: 1" =50'
COLLIER-HOGAN SPCC PLAN
FIGURE 4: FACILITY LAYOUT
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APPENDIX B

OIL STORAGE TANK INVENTORY TABLE
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Tank No. Contents Configuration
Shell
Material
Height /
Length
Diameter
(ft)
Volume
(Gal) Fill Method
Overfill
Protection Secondary Containment
1 Crude Oil & Water Vertical Cylinder Carbon Steel 24 12 19,068 Automatic High-Level Alarm 298' X 298' X 2' Gravel Berm
2 Waste Water Vertical Cylinder Fiberglass 15 10 8,820 Automatic High-Level Alarm 298' X 298' X 2' Gravel Berm
3 Waste Water Vertical Cylinder Fiberglass 15 10 8,820 Automatic High-Level Alarm 298' X 298' X 2' Gravel Berm
4 Crude Oil Vertical Cylinder Carbon Steel 16 14 18,312 Automatic High-Level Alarm 298' X 298' X 2' Gravel Berm
5 Crude Oil Vertical Cylinder Carbon Steel 16 14 18,312 Automatic High-Level Alarm 298' X 298' X 2' Gravel Berm
6 Crude Oil Vertical Cylinder Carbon Steel 16 14 18,312 Automatic High-Level Alarm 298' X 298' X 2' Gravel Berm
7 Crude Oil Vertical Cylinder Carbon Steel 16 14 18,312 Automatic High-Level Alarm 298' X 298' X 2' Gravel Berm
8 Diesel Horizontal Cylinder Carbon Steel 12 4.5 1,034 Manual Stick Gauge Double-Wall Tank
9 Diesel Horizontal Cylinder Carbon Steel 12 4.5 1,034 Manual Stick Gauge Double-Wall Tank
OIL STORAGE TANK INVENTORY
COLLIER-HOGAN OIL WELL PERMIT #1349
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APPENDIX C

GENERAL OIL TRANSFER PROCEDURES
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OIL TRANSFER PROCEDURE

Transferring of oil to/from a tank presents the highest level of interaction between the oil storage tanks and
facility or contractor personnel. Since there is a higher probability for spills to occur during oil transfers, the
following spill prevention procedure is utilized:
Stage Tasks
Prior to loading/
Unloading
Visually check all hoses for leaks and wet spots.
Verify that sufficient volume (ullage) is available in the storage tank or truck.

Lock in the closed position all drainage valves of the secondary containment
structure.
Secure the tank vehicle with wheel chocks and interlocks.
Ensure that the vehicles perking brakes are set.
Verify proper alignment of valves and proper functioning of the pumping system.
If filling a tank truck, inspect the lowermost drain and all outlets.
Establish adequate bonding/grounding prior to connecting to the fuel transfer point.
Turn off cell phone.

During loading/
unloading
Driver must stay with the vehicle at all times during loading/unloading activities.
Periodically inspect all systems, hoses and connections.

When loading, keep internal and external valves on the receiving tank open along
with the pressure relief valves.

When making a connection, shut off the vehicle engine. When transferring Class 3
materials, shut off the vehicle engine unless it is used to operate a pump.
Maintain communication with the pumping and receiving stations.
Monitor the liquid level in the receiving tank to prevent overflow.
Monitor flow meters to determine rate of flow.
When topping off the tank, reduce flow rate to prevent overflow.

After loading/
unloading
Make sure the transfer operation is completed.
Close all tank and loading valves before disconnecting.

Securely close all vehicle internal, external, and dome cover valves before
disconnecting.
Secure all hatches.
Disconnect grounding/bonding wires.

Make sure the hoses are drained to remove the remaining oil before moving them
away from the connection. Use a drip pan.

Cap the end of the hose and other connecting devices before moving them to
prevent uncontrolled leakage.
Remove wheel chocks and interlocks.

Inspect the lowermost drain and all outlets on tank truck prior to departure. If
necessary, tighten, adjust, or replace caps, valves, or other equipment to prevent oil
leaking while in transit.

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APPENDIX D

SPILL/RELEASE NOTIFICATION FORM
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Spill/Release Notification Form


Page 1 of 2

Facility:

REPORTING PARTY
Name:
Title:
Phone Number:
Company:
Address:
City/State/Zip:
INCIDENT DESCRIPTION
Incident Date Incident Time Report Date Report Time

Material Released: Approximate Quantity
Location of Spill/Release
Longitude (if known):
Latitude (if known):
Discharge
Source
Tank
Drum/portable container
Oil-containing equipment
Oil piping
Other
Unknown
Description:
Cause and Circumstances of the Spill or Release:
Existing or Potential Hazards (fire, explosion, etc.) if any:


IMPACT
Number of Injuries:
Number of Fatalities:
Evacuation Required?:
Property Damage?:
Yes No
Yes No
If yes, describe below:






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Spill/Release Notification Form


Page 2 of 2
RESPONSE ACTIONS
Action Taken to Correct or Mitigate the Incident:
Actions Planned to Prevent Recurrence:
NOTIFICATIONS WITHIN COMPANY
Reported by: Reported to: Time Date
11:00 AM 09/44/2006






NOTIFICATIONS TO AGENCIES
Reported by: Reported to: Agency Incident No. Time Date






ADDITIONAL INFORMATION (attach additional pages as necessary)


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APPENDIX E

MONTHLY INSPECTION CHECKLIST
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Appendix E: Monthly Inspection Checklist
Further description and comments, if needed, should be provided on a separate sheet of paper and
attached to this sheet. Any items answered YES needs to be promptly reported, repaired, or replaced,
as it may result in non-compliance with regulatory requirements. Records are maintained with the SPCC
Plan at the Collier-Hogan field office.
Date:_______________ Signature:___________________


Yes No
Description & Comments
(Note tank/equipment ID)
Storage tanks and Separation Equipment
Tank surfaces show signs of leakage
Tanks show signs of damage, rust, or deterioration
Bolts, Rivets or seams are damaged
Aboveground tank supports are deteriorated or buckled
Aboveground tank foundations have eroded or settled
Gaskets are leaking
Level gauges or alarms are inoperative
Vents are obstructed
Thief hatch and vent valve does not seal air tight
Containment berm shows discoloration or stains
Berm is breached or eroded or has vegetation
Berm drainage valves are open/ broken
Tank area clear of trash and vegetation
Equipment protectors, labels, or signs are missing
Piping/Flowlines and Related Equipment
Valve seals or gaskets are leaking.
Pipelines or supports are damaged or deteriorated.
Buried pipelines are exposed.
Transfer Equipment
Loading/ Unloading lines are damaged or deteriorated.
Connections are not capped or blank-flanged
Secondary containment is damaged or stained
Response Kit Inventory
Discharge response material is missing or damaged or
needs replacement

Additional Remarks (attach sheet as needed):
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APPENDIX F

RECORDS OF ANNUAL SPCC TRAINING
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RECORD OF ANNUAL SPCC PLAN TRAINING

Training will be scheduled and conducted annually to ensure adequate understanding of this SPCC Plan. The training will
also highlight and describe known discharge events or failures, malfunctioning components, and recently implemented
precautionary measures and best practices. Personnel will also be instructed in operation and maintenance of equipment to
prevent the discharge of oil, and in applicable pollution laws, rules, and regulations.
Location:

Date:

Instructor:


Employee No. Signature Name Job Classification





















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APPENDIX G

SECONDARY CONTAINMENT DRAINAGE LOG
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Secondary Containment Drainage Log

Facility:
This form must be completed whenever rainwater from diked areas is drained into a storm drain or onto the ground. If a sheen is present, you must describe the measures taken to
prevent oily water from being discharged.
Inspectors Diked Visible Sheen Time Time If sheen present
Date Signature Area ID No Yes Started Completed describe action taken


















































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APPENDIX H

SUBSTANTIAL HARM CRITERIA




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CERTIFICATION OF THE APPLICABILITY OF SUBSTANTIAL HARM CRITERIA
Facility Name: Collier Hughes Oil Production Facility
Facility Location: Section 20, TWP 47 S, RNG 28E Bell Meade NE USGS 7.5 min QD

1. Does the facility transfer oil over water to or from vessels and does the facility have a total oil storage capacity greater than or equal to 42,000
gallons?
Yes ___ No _X__

2. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and does the facility lack secondary containment that
is sufficiently large to contain the capacity of the largest aboveground oil storage tank plus sufficient freeboard to allow for precipitation
within any aboveground oil storage tank area?
Yes ___ No _X__

3. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located at a distance (as
calculated using the appropriate formula in Attachment C-III to this appendix or a comparable formula 1) such that a discharge from the
facility could cause injury to fish and wildlife and sensitive environments? For further description of fish and wildlife and sensitive
environments, see Appendices I, II, and III to DOC/NOAA's "Guidance for Facility and Vessel Response Plans: Fish and Wildlife and
Sensitive Environments" (see Appendix E to this part, section 13, for availability) and the applicable Area Contingency Plan.
Yes ___ No _X__

4. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and is the facility located at a distance (as
calculated using the appropriate formula in Attachment C-III to this appendix or a comparable formula
1
) such that a discharge from the
facility would shut down a public drinking water intake?
2

Yes ___ No _X__

5. Does the facility have a total oil storage capacity greater than or equal to 1 million gallons and has the facility experienced a reportable oil
discharge in an amount greater than or equal to 10,000 gallons within the last 5 years?
Yes ___ No _X__



Certification

I certify under penalty of law that I have personally examined and am familiar with the information submitted in this document, and that
based on my inquiry of those individuals responsible for obtaining this information, I believe that the submitted information is true, accurate,
and complete.



______________________________________ ________________________________

Signature Title


______________________________________ ________________________________

Name (please type or print) Date
1
If a comparable formula is used, documentation of the reliability and analytical soundness of the comparable formula must be
attached to this form.
2
For the purposes of 40 CFR part 112, public drinking water intakes are analogous to public water systems as described at 40 CFR 143.2(c).
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