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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
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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.