(INC) must be immediately corrected by the operator. Normally these detailed inspections require 2 weeks for the inspection team to inspect one onshore or offshore facility. Following is a tabulation of INC's that were issued for Santa Barbara Channel Platforms A and B, lease OCS-P 0240 during seven semi-annual inspections. The June 1971 semi-annual inspection was the first of this type detailed inspection. It must be kept in mind that for example the 5 incidents of noncompliance (INC's) issued for Platform A during the March 1974 inspection were minor in nature and resulted from the testing of approximately 2,400 items (there are thousands of potential INC's). c. Other Inspections In addition to inspecting and witnessing operations, beach walks are frequently made to check for oil pollution. Fixed-wing aircraft and helicopter flights are made (normally biweekly) to check for oil pollution and to chart the natural oil seepage. Also, boat surveys are made in immediate areas of operation and many points in the Santa Barbara Channel to check for oil pollution. These beach walks and aerial and boat surveillances cover an area from Point Conception to Port Hueneme. The testing of new oil-spill containment and cleanup equipment in the Santa Barbara Channel is frequently witnessed. Also inspected are the areas utilized by various oil companies and Clean Seas, Inc., for storing booms, skimmers, pumps, barges, and other oil-spill containment and cleanup equipment. The enforcement policy is intended to reduce the frequency of noncompliance with lease requirements that may lead to loss of life, loss of property and resources, or damage to the environment. In 1971 new and more detailed standardized inspection procedures were established for OCS operations. The requirements in the OCS Orders and Regulations were expressed as a check list of specific items relating to safety equipment and procedures. The items reflect the existence of potentially hazardous conditions if the specified equipment is missing or not operable, or specified procedures are not followed. This compilation of items is titled "List of Potential Items of Noncompliance and Enforcement Action," and referred to as the (PINC) list. The Santa Barbara District has prepared a PINC list, consisting of approximately 2,400 items, for each platform and onshore facility. During the inspection of drilling and production operations, depending on the hazard presented toward safety or pollution, either a written warning is given that allows the operator 7 days to correct the incident of noncompliance (INC), or a shut-in order is issued. The shut-in order may be applied only to the equipment affected by the incident of noncompliance (INC), such as a particular piece of production equipment or a producing zone, or to the entire drilling rig, production platform, or onshore facility. To date, in the Santa Barbara Channel, incidents of noncompliance have been minor in nature, requiring only a warning that corrections be made within 7 days. The operators have never failed to comply within the 7-day limit except on a few occasions whereby the operator acquired an extension of several days from the Geological Survey. There have been a few cases where the operator was required to immediately bypass a particular piece of equipment until it was repaired or replaced and in certain instances this in turn necessitated that production be temporarily cut back or that drilling be temporarily interrupted. Additional penalties for noncompliance are specified in sec. 5(a)(2) of the Outer Continental Shelf Lands Act (43 U.S.C. sec. 1334 (a) (2)). "Any person who knowingly and willfully violates any rule or regulation prescribed by the Secretary for the prevention of waste, the conservation of natural resources, or the protection of correlative rights shall be deemed guilty of a misdemeanor and punishable by a fine of not more than $2,000 or by imprisonment, and each day of the violation shall be deemed a separate offense." Also sec. 5(b) (1) and (2) provide for cancellation by notice of nonproducing and producing leases subject to judicial review or appropriate judicial proceedings. Oil spills occasionally occur as a result of natural disasters, equipment failure, or human error. For this reason OCS Order No. 7 sets forth a reporting procedure for notifying appropriate persons and agencies and requires that immediate corrective action be taken. Additionally, it 1 requires that all OCS operators have an approved spill contingency plan 1 Earlier in this section OCS Order No. 7 was discussed and exerpts were included. which includes spill cleanup and containment equipment. This pollution control equipment may be maintained on the particular facility or, at the discretion of the Area Supervisor, may be land based. The operators in the Santa Barbara Channel have pooled resources and formed Clean Seas, Incorporated, to supplement their individual spill cleanup contingency plans. Additionally, there is the National Contingency Plan which in turn requires Regional Contingency Plans. a. Organizations Formed by Companies for Spill Containment and During the past 5 years, organizations have been formed, along the Pacific Coast, for pollution control; these function in the manner of fire stations. These organizations are of two basic types: (1) a nonprofit corporation which has its own equipment; or (2) a cooperative organization which has contracted for the use of local, privately owned equipment. The Oregon State Oil It has been organized to The Washington State Oil Spill Cooperative operates off the State of Washington. Although this organization covers all of the coast of Washington, its primary area of interest is Puget Sound. Spill Cooperative is headquartered in Portland. contain and remove any oil spillage on either the coastline or rivers of Oregon. A small cooperative has been formed at Eureka, California, and operates off the northern California coast. In the San Francisco area, a corporation known as Clean Bay, Incorporated has been founded. In the Santa Barbara Channel, some 15 State and Federal lease operators have formed a nonprofit corporation called Clean Seas, Incorporated. In the Los Angeles-Long Beach-San Diego area, there is a cooperative group known as P.I.C.E., which is an acronym for Petroleum Industry Coastal Emergency Cooperative (recently changed to "Clean Coastal Waters"). These six cooperative groups provide complete coverage of the Pacific @ast between the Canadian Mexico borders. In addition, similar type groups are presently being formed in Alaska, Canada, and Hawaii. These nine organizations are referred to as the "Pacific Basin Oil Spill Cleanup Organizations." Inasmuch as Clean Seas, Incorporated, is the emergency cooperative b. Clean Seas, Incorporated Clean Seas, Incorporated, (CSI), is comprised of 15 oil companies operating in the Santa Barbara Channel Area. The membership agreement allows the member companies involved to supplement their individual contingency plans by using all, or any part of, the CSI organization. CSI is also available to nonmembers and government agencies such as the Coast Guard, the Environmental Protection Agency, and the Navy for combating oil spills related to nonmembers. The managers of the Pacific Basin Oil Spill Cleanup Organizations meet in planning sessions approximately every 3 months. One beneficial product of these meetings is a mutual assistance agreement, involving Clean Seas, Inc., Clean Bay, Inc., and the other clean-up |