Site visits and development of SPCC plans after completion will delay production.

WHITEHOUSE: Meeting Materials

In response to the question about the timing for developing and implementing new SPCC plans, following are some of the comments I have received.

WHITEHOUSE: Meeting Materials

Since oil and gas facilities are usually located in remote locations that are not easily accessible, preparation of SPCC plans prior to operation of a facility will result in production delays, additional costs and inefficiency.

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In most cases, the drill wells are in fields where we already have lots of other wells, and SPCC plans already exist in the area that spell out contingency plan features including emergency callout lists, the location of absorbent pads, booms, etc.

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