Whiting Oil and Gas Corporation
Whiting Oil and Gas Corporation page Environmental, Health & Safety Newsletter Environmental, Health & Safety Newsletter 1
Fall 2015
In this Issue: Fall Tidbits.................................................1 Flash Fire Demos Prompting Some to Reevaluate Clothing....................2 A Little Thing That Can Save Our Life.........3 Records Retention.....................................4 The Use of Drones.....................................8 Air Permitting on Native American Land.............................10 Electronic Cigarettes in the Indoor Environment................................11 August Recycling Statistics.......................12 The Importance of Being Earnest... With Preventative Maintenance, A Not-So-Trivial Requirement for Serious Operators....................................13 Whiting Employee Photos.......................14 EH&S Values Winner and Nominees.......15
Editors: Kyla Livingston and Katie Roberts
Fall Tidbits
Amy Beck, Administrative Assistant Lead, Dickinson, ND As the air turns cooler and leaves drop from the trees, it’s important to keep a few important fall safety tips in mind around your home. With safety awareness and proper precautions, your family can enjoy that crisp autumn weather while avoiding some of the dangers that can come with the season.
• Every month should be fire prevention month, but we tend to plug in a lot more devices in the fall. Please test all smoke alarms and have a family fire drill.
• Turn your heater on before the temps drop so can you be sure it works. Contact a technician to inspect that it’s operating properly if you suspect it needs servicing.
• If you use a space heater, remember to keep it away from clothing, bedding, and furniture. Do not use your space heater as a dryer for hats, gloves and other articles of clothing.
• If you have a fireplace, be sure to inspect the chimney to make sure it is free of debris and is unobstructed so combustibles can vent. Make sure bricks, mortar and liner are in good condition.
• Avoid fires while doing laundry by cleaning filters after each load of wash and removing lint that collects in dryer vents.
• Check all outdoor lighting fixtures to make sure they are working properly. This can safeguard you against falls and neighborhood crime.
Make this fall season a fun and safe one by being prepared, having a high level of awareness and knowing the right resources to contact if you’re in doubt of what to do. ■
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Flash Fire Demos Prompting Some to Reevaluate Clothing
Excerpt from Anna Schumann’s article with SmartBrief Shannon Chollett, Health and Safety Coordinator I, Denver, CO At Whiting Oil & Gas Corporation, all Flame Resistant Clothing (FRC) clothing must be made from materials that meet the flame resistance performance criteria and certified as NFPA 2112 Compliant. FRC must cover the entire body (trunk, arms, legs and waist). See manufacturer’s specifications on proper laundering. Whiting’s hazard risk category requires no less than an HRC 2, which provides minimum arc flash protection for employees working around electrical equipment, a Workplace Hazard Assessment for Personal Protective Equipment (PPE) will need to be completed to determine what HRC rating is required. Refer to the FRC section in Whiting’s PPE Practice for more information. In 2014, Westex held a live flash fire demonstration at Texas A&M’s state ofthe-art testing facility. This year’s lineup included NFPA 2112 experts, burn unit specialists and some of the most realistic flash fire tests ever performed. Safety managers consider several factors when evaluating PPE clothing, such as protection, comfort, value and compliance. For many, knowing that fire-resistant clothing is compliant is enough-but after watching a flash fire demonstration in which several types of compliant FRCs were put to the test on manikins, some plan to reevaluate what their employees are wearing.
Manikins wearing non-compliant clothing, such as cotton and poly cotton and 2112-compliant garments from the top sellers in the FRC market were exposed to flash fires to see how each withstood burn conditions. Cotton and poly cotton continued to burn minutes after the flash fire ended, while the fireresistant garments self extinguished almost immediately. However, there are two very important things FR clothing should do; one is not ignite and continue to burn. Second, it should be able to insulate the wearer from the hazard so that it minimizes burn injury through the garment. This second factor is a big part of why simply accepting anything that complies is risky and unwise; if all one looks for is a ‘pass’ label, you’ll never see the huge performance differences that exist among compliant garments. One key factor that John Allen, U.S. onshore commercial manager for Wood Group PSN, often considers is comfort. By the beginning of May, his employees in South Texas had already experienced 10O-degree temperatures, so finding lightweight options that his employees like and that are compliant has been an issue. “We’re struggling over NFPA 2112 and finding garments that meet the standards,” Allen said. “To see how they tested was an eye opener.”
Now, Allen plans to reassess what employees are wearing at every location, and going forward, plans to spend more time asking suppliers for specific data on how clothing fared in burn tests. Jordon Tench, process safety engineer for BP America, said in the past he’s looked at PPE based solely on if they met NFPA 2112 standards. “I’d thought that if they complied, they were all the same,” he said. “But I didn’t fully understand what the standards meant and what was behind them.” In the future, Tench said he plans to be more aware of all the FRC options available. “It really comes down to what’s proven in the industry.” Brad Livingston, whose partner was killed and who was severely burned in back-to-back well explosions 23 years ago, appreciates the effort that Allen and Tench put into understanding safety standards and compliance issues. “Buying, using, giving your guys cheap PPEs, it doesn’t work,” Livingston said. “You’ll have to explain to those families why your company spent the least amount of money possible on their protection. What a difference it would have made for me that day. You have to buy the right stuff. It’s a shortcut if you don’t.” ■
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A Little Thing That Can Save Your Life Joel Lujan, Health and Safety Coordinator I, Odessa, TX It is said that it is the little things that matter. For example, you are driving home one day and you see a field full of sunflowers. You decide to stop and pick some flowers for your loved one. Even though it was a little thing, no doubt it made a huge impact on your loved one. Little things can be very important. When it comes to safety, there are a lot of little things that make a difference. We all know the basics…hard hats, safety glasses, steel toe boots, etc. However, included in the basics should be our H2S monitor. This little thing can save our life! There are many types of H2S monitors. Many times we refer to them by color. However, all H2S monitors do the same thing…check for poisonous H2S gas. How can we ensure our monitors are working properly? First, we have to test them regularly. There are three types of tests we can perform. The first is a function test. Some monitors have a button we can press that checks the internal electrical components. It ensures these
components are working properly. Some monitors do not have this function. Then there is a bump test and a calibration test. What is the difference? A bump test is the application of a low concentration gas, usually 20-25 ppm. This is enough to ensure the sensors are going to sound at low and high levels. Each monitor has a set level. Most H2S monitors are programed to sound at 10 and 20 ppm. Depending on the manufacturer, a bump test should be done daily or before each use. Now there is one monitor that has dual sensors. According to the manufacturer, this monitor only needs to be calibrated, not bumped. That leads us to the next test…calibration. Like it was brought out before, a low concentration of gas is used to test the monitors. When you calibrate a monitor, you bring the sensor to the correct value of the gas. For example, because of use, the sensor may be set to alarm at 12 ppm and 22 ppm. Calibrating the sensor will bring it back down to 10 ppm and 20 ppm. According to the manufacturer, this should be done at least once a month.
Most monitors should last from 1 to 3 years. This seems to be a big gap. However, many things affect the battery life of the monitor. One thing is the alarm. The battery is utilized any time the alarm is sounded. The number of times along with the duration the alarm is sounded will decrease the life of the battery. Another thing that affects the battery life is weather. Most monitors have a specified operating temperature range. It can vary from -40°F to 122°F. During the summer months, temperatures can exceed 122° F inside of the vehicle. For this reason, many have decided to keep their monitor with them instead of leaving it inside the vehicle. In order for our H2S monitor to be effective, we must wear it properly. Where should that be? OSHA requires that worker exposure monitoring air samples be collected in the breathing zone. This zone is defined as an area “within a 10 inch radius of the workers nose and mouth. “ Therefore, air sampling filters may be attached to the collar or lapel. (webapps.dol.gov/elaws/osha/lead/ glossary.asp) At the end of the day, we all want to go home to our loved ones. Our H2S monitors will help us do that. They are essential when working in areas where H2S gas is present. When your H2S monitor sounds, it is important to move immediately upwind. Delaying could cost our life. Therefore, keep your monitor with you. Wear it properly. Ensure it is checked regularly. Clean it as needed. This little thing can save your life! ■
Whiting Oil and Gas Corporation Environmental, Health & Safety Newsletter
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Records Retention
Justin Clock, Health and Safety Professional I, Northern Rockies Everyone that works for Whiting has some form of paperwork to complete and often times these documents are required to be on a retention schedule. OSHA requires employers to retain certain documents for a specific time period; other documents are retained for other company requirements. As an employee it is beneficial to understand that you have the right to review these documents and what is exactly retained for records. The following list sets out the typical OSHA standards and the General Duty Clause that may require an employer to create, retain, and produce certain documents. This list is focused on the standards that are applicable to general industry (29 CFR 1910) and not construction (29 CFR 1926), although some general industry standards are substantially similar and also applicable to the construction industry.
Control of Hazardous Energy–Lockout/Tagout (LOTO) 29 CFR 1910.147 requires the employer to develop procedures to protect employees who service or maintain its machines against unexpected energization or start-up of equipment or release of stored energy. 29 CFR 1910.147(c)(7). The employer must train its “authorized” employees how perform LOTO with these procedures, as well as “affected” employees who may be exposed to the equipment.
29 CFR 1910.147(f)(2) requires the on-site employer and outside employer to inform each other of their respective lockout or tagout procedures. Document retention: The LOTO standard requires employers to certify that periodic inspections have been performed at least annually. Accordingly, employers should retain certifications for one year or until a new certification is created. It is also advisable that employers retain employee LOTO training records for the duration of employment.
Occupational Noise Exposure 29 CFR 1910.95 requires the employer to provide a hearing conservation program (education, annual audiograms, hearing protection) for employees who are exposed to noise levels equal to or exceeding an eight-hour time weighted average (TWA) of 85 decibels on the A scale. The employer must conduct a noise survey to determine those jobs that may require employees to be included in the program. Employees who suffer hearing loss at certain frequencies must be included on the OSHA 300 Log. The employer must develop a written program and administer it. Document retention: Employers must retain noise exposure measurement records for two years. Employers also must retain audiometric test records for the duration of the affected employee’s employment.
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Personal Protective Equipment (PPE) 29 CFR 1910.132. The employer must conduct an initial certified hazard assessment of the workplace to determine whether hazards are present that require personal protective equipment for eyes, face, head, and extremities to protect against injury. The employer must provide each employee with the necessary PPE, train the employee in the use of PPE, and enforce its use. The employer must pay for the PPE with limited exceptions. A second certification is required to confirm that the PPE was provided, the employee received training in how to utilize it, and that the employee “understood” the training. Document retention: Employers should retain the written certifications of a hazard assessment and employee training for the duration of employment for all employees exposed to identified hazards. It is also advisable for employers to retain employee PPE training records for the duration of employment.
Hazard Communication (Employee Right to Know) 29 CFR 1910.1200 requires the employer to develop a written hazard communication program to protect employees against any hazardous chemical that presents a physical or health hazard. The employer is required to conduct an assessment to determine which hazardous chemicals may be present, to inform employees of the presence of the hazardous chemicals, train employees on how to read a Safety Data Sheet (SDS) for each hazardous chemical. Employees are entitled to access to the SDS and to obtain copies. Document retention: Employers must retain SDSs for the duration of employment plus 30 years for all employees exposed to the chemical in question, unless there is some other record of the identity of the substance or chemical, where it was used, and when it was used. The employer must also be sure it has a copy of all SDSs for all chemicals that are currently in use. It is also advisable for employers to retain employee hazard communication training records for the duration of employment.
Process Safety Management
29 CFR 1910.119 requires employers who utilize certain toxic, reactive, flammable, or explosive chemicals in certain quantities to develop a written 14-part PSM program. The PSM program addresses all aspects of work around the covered “process” that utilizes the chemicals.
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29 CFR 1910.119(h) requires training of contractor employees who perform certain work around the covered process concerning the hazards and elements of the PSM program. Document retention: Employers must retain process hazard analyses (PHAs) for the life of the covered process. In addition, the employer must prepare a written record that each employee who is involved in the operation of the process was trained and understood the training. These verification records should be retained for the length of the employee’s employment. We recommend that employers also retain all process safety information (PSI) used for developing, maintaining, auditing, and otherwise managing all processes for the life of the processes. Any incident investigation conducted under the PSM standard must be retained for five years. Additionally, employers must retain the two most recent compliance audit reports conducted under the PSM standard.
Emergency Action Plans
29 CFR 1910.38 requires the employer to develop an emergency action plan (EAP) to protect employees against the hazards of fires or other emergencies. The EAP must include provisions for reporting a fire or other emergency, evacuation procedures, and the alarm system. The employer must train each employee. (29 CFR 1910.38(e)) Document retention: There are no specific document retention requirements under 29 CFR 1910.38, aside from the requirement that employers develop and maintain a written EAP. If the employer has 10 or fewer employees, the plan does not have to be in writing.
Fire Extinguishers
29 CFR 1910.157 requires the employer to provide fire extinguishers and mount, locate, and identify them so that they are readily accessible to employees. If employees are expected to use the fire extinguishers, the employer must provide training upon initial employment and at least annually thereafter. The employer must develop an educational program if it expects the employees to use the fire extinguishers. Many employers specifically prohibit employees from using the fire extinguishers to avoid this training obligation. Document retention: If the employer permits the employees to use the fire extinguishers, the educational program and training should be in writing and maintained for the length of employment.
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Permit-Required Confined Spaces
29 CFR 1910.146 requires the employer to identify all confined spaces within the workplace that employees or outside contractors may be required to enter and contain a hazardous atmosphere, engulfment hazard, an internal configuration that could trap or asphyxiate an entrant, or other serious safety or health hazard. The employer must develop a written program and procedures for employees who enter the confined spaces. Only trained and authorized employees can enter the space. 1910.146(c)(8) requires the host-employer to provide certain information to other contractors who will have their employees enter the space. Document retention: Employers must retain each canceled entry permit for at least 1 year and review them within one year after each entry. It is also advisable to retain employee confined space training records for the duration of employment.
Bloodborne Pathogens 29 CFR 1910.1030 requires an employer to develop a written program to protect employees at the workplace who are reasonably expected to have occupational exposure to bloodborne pathogens (i.e., bloodborne diseases). The employer is required to assess all jobs to determine whether there is such exposure and, if so, to train employees in the hazards, provide PPE, and develop procedures for medical evaluation and treatment if an employee has actual exposure. Document retention: Employers must retain employee exposure records for the duration of employment plus 30 years. Training records must be retained for three years from the date on which the training occurred, although it is advisable to retain training records for the duration of employment.
Respiratory Protection 29 CFR 1910.134 requires the employer to conduct an assessment of the workplace to determine whether there are harmful dusts, fumes, mists, sprays, or vapors which may create a respiratory health hazard. If there are such hazards, the employer is required to develop a written respiratory protection program, to evaluate employees to determine whether they are physically capable of wearing a respirator, to provide such respiratory protection at the employer’s cost, and to train employees how to wear and maintain respiratory protection. The employer must enforce the use of the respiratory protection.
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Document retention: Employers must retain records of employee medical evaluations for the duration of employment plus 30 years. Employers also must retain fit test records for respirator users until the next fit test is administered.
Electrical Safety (Safety-Related Work Practices)
29 CFR 1910.331-.335 requires an employer who will permit its employees to perform work on or in the vicinity of exposed energized parts (which cannot be locked out and tagged out) to provide extensive training in the hazards of working or in the vicinity of live electrical equipment, protective clothing, and insulated tools and devices. The employer must designate employees as “authorized” in order to perform such work or “unqualified,” in which case such employees cannot perform such work. The employer may be required to conduct an electrical exposure hazard survey of electrical equipment under NFPA 70E in order to determine what PPE should be used, what training is necessary, and to otherwise be in compliance with OSHA safety requirements. Document retention: OSHA’s electrical safety standards do not have any specific record retention requirements, however it is advisable to retain employee training records under these standards for the duration of employment. If an employer conducts an electrical exposure hazard survey, the employer should retain it for as long as the hazard exists.
Access to Employee Exposure and Medical Records
29 CFR 1910.1020 requires the employer to inform employees of their right to have access to all records maintained by the employer that reflect an employee’s exposure to any toxic substance or harmful physical agent (e.g., chemicals, dusts, vapors, noise, mold, etc.) or any medical records the employer maintains on an employee, except for certain exceptions. Employees are entitled to have access and to obtain a copy at the employer’s expense. Document retention: Employers must retain employee exposure records for the duration of employment plus 30 years. If the employer maintains certain employee medical records, the employer must retain them for the duration of employment plus 30 years.
Powered Industrial Trucks
29 CFR 1910.178 requires an employer to develop a written program to train all employees who will be required and authorized to operate powered industrial trucks as to the hazards of such equipment and to certify their
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training after they receive classroom-type training and are actually observed operating the equipment under the physical conditions at the workplace, such as aisles, ramps, etc. The employee must be retrained and recertified every three years, at minimum, or after an accident or “near miss” that resulted from an unsafe act. Document retention: The powered industrial truck standard does not specify how long training certifications must be retained after the initial certification or the certification required every three years or after a “near miss.” It is advisable that employers retain the training certifications for the duration of employment for each employee.
OSHA 300 Log of Work-Related Fatalities, Injuries and Illness
29 CFR 1904.0. The OSHA 300 Log must be maintained by employers unless there is an exemption, based on the NAICS code or the size of the employer. The employer is required to record on the Log, within seven calendar days, each fatality, injury, or illness that is recordable under OSHA definitions. The host employer is required to enter into its Log the injuries or illnesses of outside employees at the work site under certain conditions—for example, temporary employees who are under the direction and control of the host employer. The OSHA 300 Log must be maintained and certified by the employer on an annual basis. For each entry on the Log, there must be an OSHA 301 Incident Report form, or its equivalent, which can be the employer’s First Report of Injury or Illness form required by the state workers’ compensation law. An annual summary must be prepared and posted using the 300A annual summary form or an equivalent. In order to comply with OSHA’s recordkeeping requirements, it is critical that employees are trained from their initial employment that they must immediately report any occupational injury or illness to determine whether it is recordable. Document retention: The OSHA Log, the annual summary, and the OSHA Incident Report forms must be retained by employers for five years following the end of the calendar year that these records cover. The OSHA Log must be maintained on an “establishment basis” based on NAICS codes. It is possible that employers may have some “establishments” where a Log must be maintained and others where maintaining a Log is not necessary.
General Duty Clause Section 5(a)(1) of the OSHA Act requires an employer to identify “recognized hazards likely to cause serious injury or death” to an employee, which hazards may not be regulated by a specific OSHA
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regulation, and to take “feasible” actions to abate or correct such hazards. This duty can be based upon the “recognition” of the hazard in the employer’s own, existing programs or within the employers industry. Document retention: While there are no specific standards for “recognized hazards” covered under the General Duty Clause, and thus no specific record retention requirements, it is advisable for employers to retain any training records it has developed addressing any “recognized hazards” for the duration of employment, including the written policy, training records, and documents that evidence discipline for violation of the policy.
Disciplinary Records
There is no regulation that requires an employer to maintain written records of employee discipline for violations of the employer’s safety and health policies. If, however, the employer wants to credibly assert the “unavoidable employee misconduct” defense to avoid liability for OSHA citations, the employer is highly recommended to maintain written records of discipline indicating the nature of the violation, the date, the name of the employee who committed the violation, and the name of the supervisor who imposed the discipline. This same documentation can be useful in the event that the employer has to defend an employment discrimination or wrongful termination action by being able to prove that the action was based on a legitimate non-discriminatory reason— that is, violation of safety and health policies.
Conclusion In addition to the summary of OSHA-related documents discussed above, there are numerous other OSHA regulations that have document retention requirements. If an employer is subject to any of these regulations, the regulations must be reviewed and appropriate document retention procedures must be developed. Even when an OSHA standard does not specify how long certain records must be retained, it is advisable to consider retaining such records for a significant length of time. For example, many OSHA standards require employee training but do not necessarily require documentation of training or retention of training documents. Nonetheless, it is advisable to prepare and retain training documents for the duration of employment.
Source: Occupational Safety & Health, 2015 ■
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The Use of Drones in the Environmental World Justin Mantelli, ACTS Professional, Denver, CO Ever since the use of the term “drone” became part of our everyday vernacular, there have been articles published stating that the EPA has been using drones to ‘silently’ track various environmental topics. The main rumor had been that the EPA has been using these unmanned machines to track farmers in Nebraska and Iowa. There were various speculations to answer ‘why’ but most believed it was to track illegal land use and unauthorized waste disposal activities. The invention of “drones” or small, unmanned, flying machines started in the early 1900s. In 1917 Elmer Sperry together with radio engineer Peter Hewitt, began construction of the radiocontrolled “Hewitt-Sperry Automatic
Airplane” dubbed the “Flying Bomb.” This craft was able to fly up to 50 miles while carrying a 300-pound bomb. The success of this project led the U.S. Army to commission a second project, the rail-launched Kettering Aerial Torpedo “Bug” (seen below). The next major use of drones came during World War II when the second generation of “Bug”, as well as the “Bat,” radio-controlled glide bomb was developed and used by the British. Now, I’m not trying to imply that the EPA is using “flying bombs” to eliminate Nebraskan farmers, but the EPA certainly has the capability and power to use such devices to track anything in their jurisdiction without the target ever knowing. Both the Washington Post and L.A. Times have released articles trying
to debunk the rumors while other news outlets cite pictures and fuzzy evidence to exacerbate the government’s ‘big brother’ portrayal. A search of the EPA’s website does suggest that the federal agency has been developing spy drones (unmanned aerial vehicles) for the purpose of monitoring pollution and land use for years. An EPA project entitled Landscape Characterization and Change Detection Methods Development Research was scheduled for completion in 2009. This project describes how the EPA would use “UAV and satellite based remote sensor data to provide a continuous environmental monitoring capability.” The report describes how the EPA used technologies developed by the
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The invention of “drones” or small, unmanned, flying machines started in the early 1900s.
Department of Defense and NASA “to develop terrestrial, coastal ocean, and surface-troposphere flux unmanned aerial vehicle (UAV) missions” in order to “support environmental decision making” and measure “biogenic emissions”. Recent advancements along with the availability of this technology in today’s marketplace would allow the EPA to ‘secretly’ or ‘knowingly’ pinpoint an oil and gas plant to quickly monitor the site’s emissions verses what is on file with the agency to begin to efficiently ‘truth-check’ an industry that is under already under the microscope. The oil and gas industry should, at the least, be aware of the potential for such a program and make sure their proverbial ‘cows are in a row.’ On the other side of the ball, various oil and gas industry partners have started utilizing drones for various environmental applications. TriHydro Corporation, a Whiting vendor, is preparing to enter the skies with an unmanned aerial vehicle program. Vice President Keith Marcott said potential applications could include aerial photography and mapping; aerial inspection and inventory; topographic mapping; change detection; infrastructure inspection and monitoring; conveyance evaluation;
resource management; volumetric surveys; vegetation monitoring; and wildlife and livestock surveys. TriHydro is the first of what could be many companies preparing to take advantage of technologies to not only become more efficient but to put the link between environmental programs and advancing technology on the map. ■
References: Coutros, Katherine. “Landscape Characterization and Change Detection Methods Development Research (20052007).” http://cfpub.epa.gov/si/si_public_ record_report.cfm?dirEntryId=11068 Wilcox, Mark. “Trihydro Pierces Sky with Drones.” http://wyomingbusinessreport. com/trihydro-pierces-sky-with-drones
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Air Permitting on Native American Land Eric Barndt, Environmental Professional III, Denver, CO How are air emissions from oil and gas operations handled on Indian lands? The United States Environmental Protection Agency (EPA) implements the Clean Air Act regulations on Indian land through the Tribal Authority Rule, or TAR. The TAR treats eligible federally-recognized Indian tribes in the same manner as states and defines eligibility requirements for a tribe to participate in many Clean Air Act programs. This is generally the same system that exists for states, in that states and tribes can seek authority over certain provisions of the Clean Air Act. This requires a tribe to set up their own regulations and obtain implementation approval from the EPA. For states this process results in a State Implementation Plan (SIP). Similarly, if a tribe seeks and is awarded authority, they have established a Tribal Implementation Plan (TIP). In both states and tribal cases, there is no requirement for SIPs or TIPs to be established and if states or tribes do not seek authority the EPA remains the regulatory authority for air emissions. What about the newly acquired Kodiak facilities that Whiting operates on the Fort Berthold Indian Reservation in North Dakota? Currently Whiting is required to prepare and submit an air registration to the EPA within 90 days of well’s first date of production (FDOP). This requirement is similar to the North Dakota Department of Health, Division of Air Quality well registration program. In addition, on April 22, 2013 the EPA approved and promulgated a Federal Implementation Plan (FIP) for oil and natural gas well production facilities on the Fort Berthold Indian
Reservation (FBIR, the Mandan, Hidatsa, and Arikara Nation) in North Dakota. Under the FBIR FIP Whiting must meet the following requirements:
• Prior to a well’s FDOP, casinghead gas from oil and natural gas well completion/recompletion operations must be routed to a control device (flare or combustor) with a minimum 90% VOC destruction efficiency (DE).
• Beginning on the well’s FDOP natural gas emissions from production operations and storage operations must be routed to a flare or combustor with a minimum 90% VOC DE.
• Within 90 days of FDOP produced natural gas must be routed to sales or to a flare or combustor with a minimum 98% VOC DE.
• Within 90 days of FDOP standing, working, breathing, and flashing losses from produced oil storage and produced water tanks must be routed to sales or to a flare or combustor with a minimum 98% VOC DE.
• Conduct and document quarterly visual inspections of hatches, covers, seals, PRVs and vent lines to ensure proper operation.
• Conduct and document daily Audio, Visual and Olfactory (AVO) inspections of all equipment associated with each control device to ensure system integrity.
• Submit an annual report to EPA Region 8 by August 15 of each year including details of compliance with and exceptions to the FBIR FIP. What will happen in the future for air permitting and compliance on Indian lands, including facilities on the FBIR?
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On August 18, 2015, the EPA proposed a FIP to implement a new rule titled Review of New Sources and Modifications in Indian Country: Federal Implementation Plan for Managing Air Emissions from True Minor Sources Engaged in Oil and Natural Gas Production in Indian Country, or the NSR FIP. The rule would apply to owners and operators that plan new construction or modifications of existing covered sources after October 3, 2016 and would require that they register the sources with the EPA 30 days prior to the start of construction. The proposed rule does not include compliance requirements for existing sources, however the EPA may eventually target existing sources. The rule is much broader in comparison to current requirements and will incorporate six existing federal rules by reference that will regulate emissions from process heaters; fuel storage tanks; diesel, gasoline and natural gas engines; oil and gas well drilling and processes; and glycol dehydrators. The proposed FIP requirements include emission limitations and standards, monitoring, and testing and recordkeeping and reporting.
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proposed NSR FIP. However, the proposed NSR FIP does not exempt facilities from complying with the FBIR FIP. The FBIR reservation-specific FIP also regulates VOC emissions from oil and natural gas well completions, well casing heads, and heater treaters at oil and natural gas production facilities, which are not currently regulated by the six existing rules that are to be incorporated by reference. This means we may need to comply with both the proposed NSR FIP and the existing FBIR FIP. The EPA will hold a public meeting in Denver on September 23, 2015 and will accept comments on the proposed rule until October 26, 2015. Whiting’s Environmental Department will be participating in the Denver public meeting and is currently networking with other FBIR producers and industry trade organizations to prepare and submit comments on the proposed rule. ■
The rule also proposes that, prior to beginning construction; sources would be required to assess impacts on threatened and endangered (T&E) species and historic properties. With regards to the FBIR, the EPA has determined that the reservation-specific FIP is not a permitting program and does not exempt facilities from any federal Clean Air Act permitting requirements, which would include compliance with the
Photo Credit: Sarah Paycer
Electronic Cigarettes in the Indoor Environment Kelly Corbell, Strategic Safety Lead, Denver, CO. Via the American Industry Hygiene Association Presenters: C. Marcham, University of Oklahoma Health Sciences Center, Oklahoma City, OK; M. O’Reilly, School of Public Health, Manlius, NY; A. Rule, Johns Hopkins University, Baltimore, MD; E. Floyd, OUHSC, Oklahoma City, OK; W. Friedman, HUD, Washington, DC Electronic cigarette use is increasing worldwide. “Vaping” has been promoted as a beneficial smoking cessation tool and an alternative nicotine delivery device with no combustion byproducts. However, nicotine is a highly addictive substance; increased use among teens and non-smokers may result in nicotine dependency. Research indicates that vaping solutions—and their emissions—may contain much more than nicotine, e.g., aerosolized flavorings, propylene glycol,
and other intentional and unintentional contaminants which could present a health hazards. While e-cigarettes’ use and exposure may lower some or most risks vs. cigarettes, the health effects of nicotine and aerosol exposures from them are not well understood. Vaping aerosols are not benign, especially for bystanders in areas with limited ventilation or with compromised health conditions. ■
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August Recycling Statistics Customer Name:
TM
Automated Sustainability Report
ARTIS HRA 1700 Broadway, LP
Altogether Recycling Collected: 4,737 lbs
Account: 008044 Service Period: August 2015
Trash Collected: 30,099 lbs Compostable Materials Collected: 0 lbs Total Materials Collected: 34,836 lbs
Monthly Collection Report Tons of Trash
Tons of Recycling 16
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August Diversion Rate: 13.6%
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July Diversion Rate: 20.1%
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A 32% Decrease in Recycling
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Diversion Rate Comparison How You Are Doing You
Average Alpine
Customer Ranking* When compared to other Commercial customers your rank this month is 941 out of 3,099. Last month's rank was 801.
14%
When compared to other Office Building customers your rank this month is 266 out of 619. Last month's rank was 207.
12%
"Green" Alpine
56%
Average Alpine Customer: The average diversion rate for all Alpine Customers "Green" Alpine Customer: The average diversion rate of the top 10% of Alpine customers
*Your Customer Rank compares your diversion rate to other Alpine customers with similar business types
Your Environmental Impact This Month You conserved 325 gallons of oil
You saved enough electricity to power the average US home for 575 days
You saved 33 trees
You helped keep 1 truck load of trash out of the landfill
You avoided 6,477 lbs carbon equivalent of GHG emissions
You saved 10,777 gallons of water
This Month's Tip for Increasing Recycling One way to increase recycling at your workplace....replace your desk side trash with a desk side recycle container and have central trash instead of central recycling.
Whiting Oil and Gas Corporation Environmental, Health & Safety Newsletter
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The Importance of Being Earnest... With Preventative Maintenance, A Not-So-Trivial Requirement for Serious Operators (with apologies to Oscar Wilde) Tom Gibbons, Environmental Audit Professional I, Denver, CO It is said that the true value of any used car lies in the maintenance that was performed on it. The same is true for the equipment that keeping Whiting’s facilities running every day. EPA and state agencies also recognize this importance and they have established air quality requirements to ensure operators properly maintain their equipment. In most cases, there is a general duty to maintain and operate equipment in a manner consistent with good air pollution control practices for minimizing emissions. In particular, these agencies have targeted requirements for engines, flares, and combustors. Other common equipment includes dehydrators and vapor recovery units (VRUs) that capture tank vapors. These rules have a common theme: a plan must be developed and followed, and records must be maintained to demonstrate compliance. Although manufacturers have maintenance plans for their equipment, Whiting typically opts to develop its own plans based on operational experience and how a particular unit is intended to be run. In some cases, equipment is leased and the leasing company performs and documents the maintenance. In other cases, Whiting owns the equipment but it is maintained by a third party contractor. Nevertheless, Whiting needs a copy of the maintenance plan and the associated records of maintenance performed from the leasing company or contractor.
Engines Newer engines may be subject to federal New Source Performance Standards (NSPS) that are designed minimize NOx, CO, VOC, and particulate matter emissions,
while older engines are subject to federal Maximum Achievable Control Technology (MACT) standards that are designed to limit emissions of hazardous air pollutants (HAPs). Maintenance requirements vary by engine type. Some common preventative maintenance requirements for gas-fired engines include:
• Changing oil and filter • Checking belts and hoses • Checking and maintaining the air-fuel ratio controller (AFRC)
• Replacing the oxygen sensor Some common preventative maintenance requirements for diesel-fired engines are:
• Changing oil and filter • Checking belts and hoses • Draining and changing the fuel filter • Draining water and sediment from the fuel tank
• Draining exhaust condensate trap • Checking and changing the air cleaner element
Emissions Control If there is an emissions control device on the equipment, the maintenance needed to keep it performing properly needs to be considered. Engines commonly have catalysts to reduce emissions. The catalyst should be inspected periodically and cleaned or, if necessary, replaced. Flare tips and combustor burners can get fouled over time and need cleaning to prevent smoking. Some emissions control devices have monitoring systems to help indicate when there may be an operational problem. Engine catalysts, for example, are often equipped with sensors to measure the pressure drop as exhaust gases move
across the catalyst. If the pressure drop is outside an acceptable range, the catalyst must be inspected and perhaps cleaned or replaced. Flares and combustors have thermocouples to sense temperature to ensure the pilot is burning and waste gases are combusted. The sensors used to monitor emissions control devices may have their own periodic requirements, such as calibration of pressure gauges and thermocouples.
Maintenance Interval Preventative maintenance is often based on timed maintenance (runtime hours) or a set schedule (daily, weekly, monthly, annually, etc.) and, in some cases, it is whichever comes first. What are some implications for Whiting? Pumping unit engines which run intermittently, for example, may be subject to preventative maintenance that is based on runtime. So rather than assuming the unit runs 24/7, it may be worthwhile to install an hour meter or document well downtime with company records in order to demonstrate compliance with applicable air quality rules. There’s the familiar used car sales adage: “the car was owned by a little old lady and only driven to church on Sunday.” While that car may be a cream puff, its belts, hoses, and fluids must be changed on a time schedule even when the car is not being driven very much. Similarly, Whiting equipment needs preventative maintenance to keep running smoothly and to avoid breakdowns and operational downtime of a facility. Please contact your local Environmental Professional or Coordinator if you have any questions. ■
Whiting Oil and Gas Corporation Environmental, Health & Safety Newsletter
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The Whiting Float We had a great presence at the Roughrider Days Parade in North Dakota.
Swainson’s Hawk South of Redtail Gas Plant He was right across from the Midway Grill (maybe wanting a snack?) . —Special thanks to Dan Holmen for sending in a photo of Hank the Hawk to the newsletter
Bravo Dome—Harding Co, NM Yarbrough 2028 #291 Killdeer (killdee) birds enjoying a swim in our reserve pit. —Photo by Danny Holcomb (consultant) on May 7, 2015
North Dakota Team Over 55 Whiting employees went above and beyond at the Bismarck Marathon in September raising over $100,000 for Make-A-Wish North Dakota and the Wounded Warrior Project. We all applaud your accomplishment and contributions to these great charities!
Whiting Oil and Gas Corporation Environmental, Health & Safety Newsletter
WHITING EH&S
Values The whiting EH&S Values EXCELLENCE — Striving to be exceptionally good at every component of your job TEAMWORK — Collaborating to achieve a
shared goal
COMMUNICATION — Sharing and
exchanging thoughts, opinions and information
INTEGRITY — Cultivating moral character
and adherence to ethical principles
Congratulations to Justin Korkus and Michael Craig on exemplifying the EH&S Department Values!
Teamwork Justin Korkus Due to several Whiting assets being sold, Justin’s area of responsibility has been reduced substantially. Instead of allowing this to impact his morale, or taking a “breather” from a typically busy work load, Justin has gone out and picked up several types of projects to help relieve the burden from those who are the busiest.
Community Stewardship
COMPANY PRIDE — Taking pride and
honor in working for a leader within the industry
COMMUNITY STEWARDSHIP — Fulfilling
commitment to serve the communities in which we operate
Michael Craig Michael teamed up with the state to perform security assessments for several schools throughout the state. These assessments are used to develop a list of recommendations to increase the security of the students and staff.
The Whiting Values Committee would also like to recognize the following individuals who were nominated for this award: Brian Wurm Melissa Halverson
Patrick McNamara Jeff Brown
Amy Beck Jesse Olson
Whiting Oil and Gas Corporation Environmental, Health and Safety 1700 Broadway | Suite 2300 | Denver, CO 80290 | www.Whiting.com
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