Tuesday, November 19, 2013
Sarah Ferdico, Communications
Natural gas operators must comply with a complex mix of state and federal regulations regarding environmental, health, and safety laws. Olsson employees made presentations to a group of natural gas operators at a recent continuing education program covering oil and gas jurisdictional issues and internal audit strategies.
During the program, Olsson staff members discussed a range of environmental challenges in the oil and gas industry and the related federal and state regulations. They also covered how to maintain compliance in areas such as air quality, assessment and remediation, water and stormwater management, asbestos, polychlorinated biphenyl (PCBs), environmental due diligence/auditing procedures, and general safety topics.
Synopses of the topics covered during the program are provided below.
Tony Barlage, Olsson’s Air Quality and Compliance team leader, discussed trends showing North America becoming a worldwide leader in natural gas production. Tony understands the full range of air quality regulations at the Colorado and federal levels for oil and gas production. Tony’s presentation reviewed these federal and state regulations, as well as the general permitting process. Tony pointed out that creating new facilities or modifying existing facilities might trigger the permitting process.
Senior Geologist James Hix, PG, discussed the various locations at a natural gas site that may harbor asbestos-containing materials, including gas wells, booster stations, and compressor stations, and the appropriate methods for sampling, abatement, and disposal. Although asbestos may be encountered in a variety of products, one of the most common areas for oil and natural gas operations is in asphaltic pipe coatings. Usually pipe coatings are not friable, meaning that they cannot be pulverized or reduced to powder using hand pressure. However, these materials can be damaged to a point where they are friable if not handled appropriately. Agencies that regulate asbestos include OSHA and EPA, as well as state agencies, so it is important that operators understand the rules that apply to these materials.
Stormwater, Spill Prevention, and Hydrostatic Test Water Discharge Permits
James also discussed a variety of issues related to water and natural gas facilities. Stormwater management requires a solid understanding of the Clean Water Act, as well as the federal and state agencies that provide oversight on stormwater issues. James reviewed when spill prevention control and counter measure (SPCC) plans are required at a facility, when SPCC plans need to be reviewed, as well as training for oil handling personnel. James also discussed the range of monitoring requirements and processes associated with Hydrostatic Test Water Discharge permits.
Environmental Due Diligence
Stuart Francone, vice president and senior project manager, presented information on the importance of conducting an environmental due diligence process before a purchase. Stuart also discussed identifying and planning assets, conducting the actual assessment, and reviewing a list of environmental issues as part of the due diligence process.
Polychlorinated Biphenyl (PCBs)
Stuart also addressed PCBs that are potentially present in oil and gas facilities from the historic use of PCB-affected lubricants and greases. Stuart described the background of PCBs in the natural gas industry, the most typical forms of PCBs, and where they are most often present at oil and gas facilities. Detailed information on PCB impacts associated with air compressor systems, turbine gas compressors, and valve grease were presented. Stuart outlined the regulatory aspects of PCBs, starting with the federal Toxic Substances Control Act (TSCA) of 1976 and the PCB "Mega Rule" of 1998. He then reviewed key aspects of the PCB regulations, including definitions and equivalencies, use authorizations, marking and labeling, abandonment and removal of pipelines, storage of PCBs, and record keeping requirements.
Assessment and Remediation and Waste Management
John Lohner, vice president and Olsson’s Oil and Gas practice group leader, shared his 30 years of environmental experience and discussed the fundamentals of assessment and remediation based on Colorado regulations. John talked about what to do if a company has a spill or a release, state regulations and reporting requirements, site assessment techniques, remediation technologies, and federal regulations for waste management activities.
Health and Safety
John also discussed health and safety issues related to the oil and gas industry, including key issues for OSHA and the National Institute for Occupational Safety and Health (NIOSH). John described ensuring behavior-based safety, managing process safety, developing and implementing emergency action plans, and preparing and following contractor safety plans.
Olsson staff members have many years of field and practical experience in environmental compliance and the oil and gas industry. Compliance is a complex and constantly changing web of state and federal regulations, and natural gas operators can rely on Olsson’s expertise to help keep them compliant. For more information, call Stuart Francone or John Lohner at 303.237.2072.