Zephyr prepared Spill Prevention, Control, and Countermeasure (SPCC) Plans for 17 natural gas processing facilities located in Texas, Louisiana, and Alabama. The majority of these facilities had no pre-existing SPCC plans. Some of the gas plants were “complex” facilities with portions of the plant subject to Department of Transportation requirements and other portions subject to Environmental Protection Agency regulations. In addition, some facilities meet the definition of “production” facilities subject the requirements of 40 CFR Part 112.9 and other facilities were subject to the requirements of 40 CFR Part 112.8. The Plans were prepared in accordance with the requirements of SPCC Plans. Where deficiencies were noted with regard to compliance with the requirements of 40 CFR Part 112, Zephyr provided recommended changes and conceptual designs of secondary containment structures. For most of the facilities, there were no detailed plans and specifications for the units subject to the SPCC requirements. Zephyr field staff provided detailed information with regard to tank capacities, materials of construction, secondary containment measurements, site drainage, etc. Detailed site drawings depicting the locations of the oil containing units were prepared by Zephyr.