Spill Response on an Ohio`s Horizontal Oil and Gas Well Pad
Transcription
Spill Response on an Ohio`s Horizontal Oil and Gas Well Pad
SPILL RESPONSE IN OHIO: PRACTICAL GUIDANCE FOR OPERATORS OF HORIZONTAL OIL AND GAS WELLS Kris Andersen, Senior Environmental Consultant ALL Consulting - Tulsa, Oklahoma Presented at: American Institute of Professional Geologists Columbus, OH April 2015 OUTLINE • • • • Introduction Regulatory Structure Contamination Avoidance Spill Response Measures INTRODUCTION Copyright 1999- 3 WELL PADS IN THE UTICA SHALE PLAY • The Utica Shale play is bringing heavy industry to rural areas of eastern Ohio. Over the course of a few weeks, a remote pasture or hilltop can be converted to a 5 acre well pad. In less than a year, as many as six or more wells can be producing thousands of barrels of condensate and millions of cubic feet of natural gas. TYPICAL CHEMICALS ON-SITE • Development of unconventional plays requires a greater variety of chemicals, equipment and crews than conventional plays. Construction Diesel Engine Oil Coolant Hydraulic Oil Drilling Frac Diesel Diesel Engine Oil Engine Oil Coolant Coolant Hydraulic Oil Hydraulic Oil Compressor Oil Compressor Oil Potassium Brine Chloride Acid Mud and Corrosion Additives Inhibitors Brine Biocides Surfactant Drill-out Diesel Engine Oil Coolant Hydraulic Oil Compressor Oil Brine Produced Hydrocarbons Flowback Diesel Engine Oil Coolant Hydraulic Oil Brine Produced Hydrocarbons Production Diesel Engine Oil Compressor Oil Coolant Brine Produced Hydrocarbons REGULATORY STRUCTURE JURISDICTION • Under Ohio law (Ohio Revised Code (ORC) 1509.02), the Ohio Department of Natural Resources (ODNR) has nearly exclusive jurisdiction over activities on oil and gas locations. • Accordingly, spills that are limited to oil and gas locations may need to be reported to ODNR, but may not be considered releases to the environment unless they extend beyond the limits of the location. • Spills to the environment, beyond the limits of an oil and gas location, may be reportable to other agencies such as the National Response Center (NRC), the Ohio Environmental Protection Agency (Ohio EPA), the county Local Emergency Planning Commission (LEPC), and the jurisdictional fire department. Refer to Table 1 for spills of crude oil and related materials, hazardous substances. INCIDENT REPORTING • In general, any spills should be reported to the jurisdictional ODNR County Inspector. Informal reporting guidelines can be developed with individual inspectors based on the relationship and experience with the inspector. TABLE 1 - SPILL NOTIFICATION AND REPORTING REQUIREMENTS TYPE AND VOLUME OF SPILL Release of any volume crude oil/produced water spill that has the potential to contaminate the surface of the land, or water on the surface or in the subsurface. Release of any amount of oil that causes a film or sheen on a waterway or causes discoloration of the surface of the waters or causes a sludge or emulsion to be deposited beneath the surface of the waters. Release of crude oil/produced water >1,000 gals from a single spill or >42 gals for each of 2 spills within a 12-month timeframe of crude oil that reaches a navigable waterway. Spill amounts represent the volume that reaches the navigable waterway; not the volume of the spill which could be greater. Any spill or release of petroleum product (e.g., diesel fuel, gasoline, hydraulic fluid, etc.) to the environment, excluding navigable waters, of 25 gallons or more. Any spill of crude oil to the environment, excluding navigable waters, of 210 gallons (5 barrels) or more. Any release of hazardous substance or extremely hazardous substance over its assigned reportable quantity (RQ). REPORTING REQUIREMENTS FOR SPILLS ODNR – Verbal notification immediately NRC, Ohio SERC, LEPC, Jurisdictional FD – Verbal notification immediately Ohio SERC, LEPC - Written follow-up emergency notice within 30 days. U.S. EPA and LEPC – Verbal notification immediately and written report within 30 days. Ohio SERC and LEPC– Verbal notification immediately and written report within 30 days. NRC, Ohio SERC, LEPC, Jurisdictional FD – Verbal notification immediately Ohio SERC, LEPC - Written follow-up emergency notice within 30 days. REGULATORY DEFINITION • ORC 1509.22(A) “…no person shall place or cause to be placed in ground water or in or on the land or discharge or cause to be discharged in surface water brine, crude oil, natural gas, or other fluids associated with the exploration, development, well stimulation, production operations, or plugging of oil and gas resources that causes or could reasonably be anticipated to cause damage or injury to public health or safety or the environment.” • OAC 1501: 9-07(A) “All persons engaged in any phase of operation of any well or wells shall conduct such operation or operations in a manner which will not contaminate or pollute the surface of the land, or water on the surface or in the subsurface” GUIDANCE FROM ODNR INSPECTORS • Unlike states with specific, prescribed spill reporting thresholds (e.g., reportable quantities (RQs)), Ohio rules prohibit contamination of the environment. Operators in Ohio are expected to clean up all spill and work closely with their Division of Oil & Gas Resource Management (DOGRM) Inspectors. • Operators need to work closely with their assigned DOGRM County Inspector and must keep the Inspector informed of operators’ activities. This is especially true of non-routine events (e.g., spills). • Communications with ODNR should be direct, i.e., you must speak with them directly in person or by phone. Voice mail or email notifications is generally not acceptable. GUIDANCE FROM ODNR INSPECTORS • Most inspectors will expect that an operator will have plans and protocol in place to respond to spills. Inspectors will want to be notified and informed of an assessment of a spill and any potential harm to people and the environment. Inspectors will want to know: Material Spilled Quantity spilled Process spilled from How site personnel were involved in the spill Has the spill been stopped? Were there any injuries? What’s being done to make sure the spill doesn’t happen again? GUIDANCE FROM ODNR INSPECTORS • The response by most inspectors will also vary based on: vs. Spills on the pad surface (gravel) or on the access road Small spills on containment that will be cleaned up immediately vs. Spills that cannot or will not be cleaned up quickly due to volume or nature of the spilled material and/or availability of response resources Spills occurring entirely on the oil & gas location vs. Spills onto secondary containment Spills that have or can migrate off the location Is the incident likely to be reported to any outside agency by private citizens? Have law enforcement or fire department been called? Will the news media pay attention (e.g., fire or incident in view of nearby homes, public roads)? GUIDANCE FROM ODNR’S WEBSITE • Visit ODNR’s Website: – http://oilandgas.ohiodnr.gov/well-information/emergency-response CONTAMINATION AVOIDANCE ZERO-DISCHARGE PADS Pads with runoff controls that can also prevent off-pad release of spilled liquids. • Do not provide complete containment • Slow and control spills for recovery efforts • As part of spill avoidance/cleanup program, can help with regulator acceptance of spill cleanup and mitigation planning RIG CONTAINMENT SECONDARY CONTAINMENT • Cleanup of spilled liquids on containment plastic is much easier. • Spills and contaminated surfaces should be cleaned as soon as possible to avoid accumulating contaminated precipitation. SPILL RESPONSE MEASURES SPILL RESPONSE PROCEDURE Identify and Stop Source Prevent Migration Cleanup Spilled Material Remove Impacted Media Test as Required Site Restoration Appropriate initial response can make the difference between a catastrophe and a manageable mishap. It is important to isolate the area of the spill so that traffic does not travel through the spill and spread the material. SPILL RESPONSE • Spills that occur off the oil and gas well pad. Releases that occur on public rights-of-way. Releases that extend significantly beyond an oil and gas location and/or have clear impacts to surface or groundwater. Most commonly under the jurisdiction of the Ohio Department of Transportation or U.S. Department of Transportation, as well as the Ohio EPA or US EPA, and are the direct responsibility of the carrier involved in the incident and usually not the operator. Involve regulators beyond ODNR, e.g., Ohio EPA, US EPA, Corps of Engineers. SPILL SOURCES • Most on-site spills occur during fluid transfer: – Trucks and Tanks – Valves, Hatches, Hoses, and Connections INITIAL RESPONSE AND REPORTING Determine the extent of a release: • Direct Observation • Direct Reading Instruments • Field Sampling INITIAL RESPONSE AND REPORTING Direct Observation • Visual evidence of releases on ground surface are the best indication of the extent of fresh spills. • Standing liquids, residue, stained gravel or soil from small spills can usually be cleaned up quickly. • Use of ground marking paint is often helpful • Some materials (e.g., diesel fuel, coolant and condensate) have a distinctive odor or color that can be useful as an indicator. FIELD INSTRUMENTATION Direct Reading Instruments: • chloride strips, • pH strips • photoionization detectors • Air meters (4 gas) • Water quality meters INITIAL RESPONSE AND REPORTING • Field Sampling and Laboratory Analysis INITIAL RESPONSE AND REPORTING SAFETY INITIAL SPILL CONTROL INTERNAL REPORTING ON-SITE SAFETY • Assess the spill area and determine if it is safe to enter area to address the spill. If there is an imminent danger to life and health, follow protocol in Operator Emergency Response Plan. • Determine if on-site equipment is sufficient to handle the release without risk to Life Safety • If safe, shut off ignition sources, flow sources and control the spill using absorbents, berms, etc. INITIAL SPILL CONTROL • If spill exits pad, prevent spilled materials from entering any waterway (e.g., drainage channels, streams, wetlands, sewers) • Whether on or off-pad, take immediate steps to limit flow of released materials (e.g., booms, interception trench(es)) • Recover spilled liquids from pad surface as quickly as possible INITIAL REPORTING • Plainly spoken and clear communications are critical to the safety of personnel, contractors, responders and neighbors. • All spills must be reported immediately to the Operator Company Man/EHS Representative who is responsible for contacting the Spill Coordinator with the following information: – Time of discovery, location of spill (on/off containment), type and volume of material spilled, volume recovered, source and cause of spill, and containment/corrective measures taken. • The Operator Company Man/EHS Representative should complete the Operator Spill Report Form and forward a copy to the Operator’s Spill Coordinator. ON-SCENE INCIDENT COMMAND Establish Site Control Identify On-Scene Incident Commander Evacuate Personnel to Muster Area Account for all site personnel (Head Count #1) o Staff, contractors, visitors Stabilize personnel with minor injuries Evacuate personnel with emergency medical needs Identify Chemical / Physical hazards Isolate hazardous locations (as needed) e.g. o Police – Block local roads and highways o Police – Evacuate neighbors Establish personal protective equipment requirements Establish staging areas and check-in system o Conduct pre-entry briefings Monitor wind direction and speed for changes that could: o Increase the size or complexity of the incident; o Affect Muster Areas or other Staging Areas, o Affect Evacuation Routes or Site Access Routes. Establish Support Zones o First Aid Stations o Decontamination zones o Evacuation landing zones o Site ingress / egress Facility Emergency Management Assess Incident Severity o Current and potential outcomes Activate the Appropriate Contingency Plan o Spill Prevention, Control and Countermeasure o H2S o Medical Emergency o Fire, or Explosion Establish Communications (as needed) o Fire/Police/Emergency Medical Transport o Muster Areas and Support Zones o Management Level Incident Commander Establish incident-specific operational objectives, e.g. o Prevent loss of life o Eliminate ignition sources o Extinguish fires (if safe to do so) o Control fluids o Prevent property damage o Protect the environment Minimize effects of incident (if safe to do so) o Stop flow of fluids by closing valves, diking, etc. o Prevent liquids from flowing off site o Prevent liquids from reaching surface water Assign Resources (Personnel and Equipment) o Monitor Operations o Monitor Incident for Changing Hazards o Relay Information to the Incident Commander o Re-Establish Business Operations CONTRACTOR MANAGEMENT • It may be expected that operators will hold vendors responsible for their own spills. Many contractors either have the resources to clean up their spills or have contracted response resources. At a minimum, contractors or vendors are often held financially responsible for the response costs for spills that they cause. • Operators may also have their own arrangements with vendors to provide spill response equipment and manpower resources. SOME SPILL CASE STUDIES QUESTIONS? . Contact: Kris Andersen Senior Environmental Consultant ALL Consulting – Cadiz, Ohio [email protected] Cell: 740-600-1190 www.all-llc.com Citation Information: J. Daniel Arthur, P.E., SPEC., Kris Andersen. “Spill Response in Ohio: Practical Guidance for Operators of Horizontal Oil and Gas Wells”. Presented at AIPG Conference in Columbus, OH. April 2015.