County worried about proposed oilpatch response plans by Paul Cowley, January 9, 2013, Red Deer Advocate
Proposed changes to provincial regulations around oilpatch emergency response has raised concerns at Mountain View County council. Alberta Energy Resources Conservation Board is updating Directive 071: Emergency Preparedness and Response Requirements for the Petroleum Industry and has asked for public feedback. Council recently reviewed proposed regulatory changes and was not reassured by what it saw in a section that deals with requirements for oil and gas companies to obtain emergency contact information for those living within the emergency planning zone (EPZ) around oil and gas installations.
“Directive 71 from our perspective takes a lot of the onus of oil companies and puts it on municipalities,” said Reeve Bruce Beattie. “We’re not in favour of that.” Beattie said in the past it has always been the role of companies to be responsible for the emergency response plan and ensure they are aware of all landowners and residents, including renters, in the area around an oil and gas facility. “We, as a municipality, we keep track of residences. “But we don’t keep track of who’s living in buildings, who’s living in a rental property, that type of thing,” he said. Ultimately, municipalities are responsible for emergency response, but Mountain View County doesn’t have the resources — or perhaps not even the authority — to collect that kind of information, he added. “Presently, the companies do. So we think it’s a step backward in terms of public safety.”
ERCB spokesman Bob Curran said they will review all of the responses after the deadline for feedback ends on Tuesday. “Once we have all feedback in hand, we will review it and determine if changes are required,” he says in an emailed reply to a request for comment on the county’s concerns. “It would be inappropriate to comment on any feedback until that process is complete.”
Sundre Petroleum Operators Group (SPOG), which represents more than two dozen oil and gas companies in the area, also has expressed reservations with the proposed directive. SPOG points out in a written summary of comments going to the ERCB that the directive notes provincial legislation assigns to a municipality the authority and responsibility for all aspects of emergency response within its jurisdiction. However typically, municipalities do not have the knowledge or experience with oil and gas operations to “deal appropriately with incidents within the EPZ,” says SPOG’s comments. Emergency planning and response should fall on the oil and gas company…. [Emphasis added]
Council voices concerns with proposed changes to oilfield emergency requirements by Dan Singleton, January 8, 2013, Mountain View Gazette
Mountain View County councillors have passed a motion expressing concerns with proposed changes being made to provincial legislation governing emergency response and preparedness in the event of oilfield emergencies. The Energy Resources Conservation Board (ERCB) is proposing changes to its Directive 071 Emergency Preparedness and Response Requirements. As part of that process, municipalities and industry groups have been asked for input and comments on the proposed changes. One of the changes being proposed would require energy resource companies (called duty holders in the directive) to “strive to obtain the following information for each surface development in the emergency planning zone: emergency contact representative name; exact location of the surface development; a 24-hour contact telephone number.” That change is of concern to the county because the duty holder would now be required to “strive to obtain” but would no longer be “required to obtain” the information, which, in turn, could create a public safety concern if the information is not required to be available, said Reeve Bruce Beattie.
During last week’s policies and priorities committe meeting, councillors passed the following motion: “That the committee recommend that a letter from council regarding Directive 071 (be sent to the ERCB) and that we perceive that there is a weakening in the public safety and that that would not be acceptable in the final document.” In a Gazette interview following the motion, Beattie added: “We are concerned that because they are proposing to relax the requirement for oil companies to collect this information, that information will no longer be available should there be an emergency. So are we going to be expected to collect that information? We think it could be a significant downloading on the county.”
Changes to Directive 071 are being proposed in a large number of areas, including notification of residents in emergency response zones, the operation of incident command centres, and the setup of emergency response plans. One change would require duty holders to “strive (again, no longer require) to reach an agreement with local and aboriginal authorities on the specific needs, roles, and responsibilities of each party during an emergency, and include a summary of these roles and responsibilities in its emergency response plan.” The updated directive also would require duty holders to have site-specific emergency response plans, public awareness and corporate emergency management programs in place. Another proposed change would require the duty holder to develop communication plans that identify such things as call-out procedures and immediate action checklists.
For critical sour well drilling or completion operations, the duty holder would be required to ensure that the equipment identified in the emergency response plan is located where specified in the plan before critical zone operations begin. The duty holder’s emergency response plans would also be required to include well information, including if applicable, the maximum expected H2S concentrations and corresponding maximum cumulative H2S release rates, and pipeline information, including the location of emergency shutdown valve locations and the segment distance between valves, and licensed and maximum expected operating pressures. Under the Municipal Government Act and the Emergency Management Act, counties, including Mountain View County, are assigned the authority and the responsibility for all aspects of an emergency response.
As part of the Directive 071 review process, Sundre Petroleum Operators Group (SPOG) officials have also reviewed the proposed changes and provided the following comments to the ERCB: … “Typically municipalities do not have the knowledge or experience with oil operations to deal appropriately with incidents within the emergency planning zones. The emergency response plan planning and response should fall on the duty holder and the mutual aid agreement should ensure functional relationships exist with the municipalities and the duty holder.” … SPOG is also recommending that duty holders actively participate in all local mutual aid and synergy groups, saying: “In today’s world, companies are doing more with fewer resources and these groups help fill the gap between the minimum requirement and the social licence to operate in a community.”
The ERCB expects to have all changes to Directive 071 completed by 2015. [Emphasis added]
CLIENT ADVISORY New Technology Creates New Insurance Issues for Oil and Gas Lease Operators by Pascal Ray and the AmWINS Energy Specialty Practice
This shift to unconventional drilling and heavy multi-stage fracking has created new insurance issues for the industry:
• Increase in blowouts during the completion/fracking stage.
• Increase in blowouts involving communication between multiple wells.
• Increase in blowouts caused by casing/cementing failure.
• Increase in blowouts caused by surface events.
In addition to these blowout trends, we are seeing:
• An increase in blowouts involving producing wells.
• An increase in blowouts involving plugged and abandoned wells.
While fracking has been the cause of some of the blowout increases, producing wells and plugged and abandoned wells are experiencing underground blowouts from the failure of old and corroded casings. These underground blowouts can lead to cratering events that are costly and difficult to bring under control. Underground blowouts can be much more expensive to bring under control than surface blowouts, yet many operators do not insure these wells or have high enough limits for them. Another issue that has arisen from fracking is an increase in surface and water table pollution events that can result in expensive claims and erode the Control of Well limit rapidly, if not entirely. As a result, many of the blowouts that are now occurring are under-insured.
Forty-three households were involved in the class-action suit…. A separate amount was given to Mr. and Mrs. Payne, whose house on English Drive was lifted off its foundation by the explosion. Ohio Valley Energy and other companies involved with the drilling also paid off Nationwide Insurance, which had the coverage on the Paynes’ home.
[Refer also to: FrackingCalgary
How Often Do Fracked Wells Leak? When industry says hardly ever, that’s a myth. It’s a documented, chronic problem Part Three in a series by Andrew Nikiforuk, January 9, 2013
Hydraulic fracturing with gelled propane by Gasfrac/Crew Energy Inc./Caltex Energy Inc. contaminated groundwater near Grande Prairie: ERCB Investigative Report and groundwater monitoring by Alberta Environment
Fluid Migration mechanisms due to faulty well design and / or construction: An overview and recent experiences in the Pennsylvania Marcellus Play by Anthony R. Ingraffea, Ph.D, P.E., October 2012
Source and Migration Pathways of Natural Gas in Near-Surface Ground Water Beneath the Animas River Valley, Colorado and New Mexico by Chafin, Daniel, T. 1994, USGS Water Resources Investigations Report 94-4006
Man made migration pathways probably introduced most near surface gas to the study area … Gas well annuli are more important than natural fractures for the upward migration of gas
Fingerprinting of gas contaminating groundwater and soil in a petroliferous region, Alberta, Canada by Barb Tilley and Karlis Muehlenbachs, Proceedings from International Network of Environmental Forensics conference, Cambridge, UK, July 25-27, 2011