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2.5 Good Housekeeping <br />NSI currently employs a number of good housekeeping practices: garbage and waste materials <br />are contained within a large dumpster outside of the processing plant which has a functional lid <br />and is emptied on a weekly basis; all chemicals and fuels are stored in the same room, are <br />properly labeled, and the associated MSDS sheets are easily accessible; walkways, driveways, <br />and access roads are kept free of trash, debris, and other obstructions; the interior of the <br />processing plant is swept weekly; and storage containers and drums are stored away from direct <br />traffic routes. <br />The following are additional good housekeeping practices that are to be employed by NSI under <br />this SWMP: the exterior of the processing plant, specifically beneath the conveyor belt between <br />the plant and the silo, will be swept weekly to eliminate as much sodium bicarbonate dust <br />exposed to the atmosphere as possible; all chemical substances present within the plant will be <br />listed in a spreadsheet and updated as necessary; a dumpster or trash container will be present on <br />all well pads during drilling operations. <br />2.6 Spill Prevention and Response Procedures <br />On the NSI Lease, there are 3 immediate locations where liquid spills are possible: along the <br />trace of the pipelines running to and from the plant and well field; within the piping of the <br />interior of the processing plant; and on an active well pad during drilling and injection/recovery <br />activities. Additionally, there is a possibility of sodium bicarbonate powder spills in the loading <br />bay area of the storage silo. In general, topography around the NSI plant and well field is gently <br />sloping to the northeast. As such, any barren or pregnant liquor spills from the pipelines would <br />flow in this direction, though flow would be limited and would find localized depressions, likely <br />in the form of the ditches associated with the access roads that are adjacent to and parallel the <br />pipeline trace. If pipeline spills occurred immediately outside the plant or from one of the <br />storage tanks, the spill would flow into one of the 8 drainage zones and would eventually be <br />filtered into one of the four ditches that surround the vicinity of the plant. Pregnant or barren <br />liquor spills from the piping inside the processing plant would be filtered into the drainage <br />beneath the plant that flows to the evaporation pond. Fuel, oil, or drilling mud spills occurring <br />on an active well pad would be contained within the pad, as the pad is to be graded and bermed. <br />Sodium bicarbonate powder spills would be contained and be able to be maintained within the <br />storage silo. Figures 1, 2, and 3 display the location of these potential spill areas and the <br />structural control measures associated with them. <br />In the event of a spill, the following procedures are to be followed: <br />1) Call /notify the NSI SWMP Administrator. Determine if Boiler /Pump shut -down <br />procedures need to be implemented. Depending upon the Administrator's location, <br />Daub & Associates, Inc. NSI 2011 SWMP <br />Page 11 <br />