Oil and Gas Floodplain Regulation file

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Oil and Gas
Floodplain Regulation
Amy Brandley, CFM
Floodplain Administrator, Canadian County, OK
Canadian County, Oklahoma
900 square miles
Fastest growing
county in OK
Canadian County, Oklahoma:
Third in the nation in
the number of
Federally Declared
Disasters over the
last decade.
-USA Today, Feb 11, 2008
Tornadoes
Wildfires
Ice Storms
Floods
Giant Fish
Oklahoma Flood Facts
• Of the 58 Major Disaster Declarations in
Oklahoma since 1955, 40 have involved flooding.
(FEMA)
• Oklahoma is consistently recognized by FEMA
and others as having the best floodplain
management program in Region VI and one of the
top programs in the country.
OK is one of the top producers of
oil and gas in the nation
But…
• Many Oklahoma communities are not
following floodplain regulations for oil and
gas development in their floodplains.
• O/G is heavily regulated by the Oklahoma
Corporation Commission, but they don’t
require any floodplain management
practices.
Where We Have Been
• We have worked with the Oklahoma Water
Resources Board, the Oklahoma
Corporation Commission, the Oklahoma
Independent Petroleum Association, local
regulatory permitting consulting firms, and
individuals from the oil and gas industry to
learn about oil and gas and come up with
our requirements.
Where We Are Headed
• Oklahoma Independent Petroleum
Association, OWRB, OFMA, Corporation
Commission, and the state legislature are
working toward standardizing oil and gas
floodplain permitting across the state.
We need a statewide
consistent effort
• Some communities are requiring too much.
• Some communities are requiring too little.
• These widely varying requirements are
difficult for the O/G industry.
Due Consideration
• Our efforts at permitting the industry must
not place undue hardship on a business that
is often required to be in the floodplain.
• We are familiar with due consideration with
the agriculture industry.
• This is STATE LAW: OS 82 Section 1614
Regulate the industry in an
expedient manner, enforcing
the minimum NFIP standards
Why is it important to
regulate the oil and gas
industry in our floodplains?
Canadian County Oil and Gas Wells
Kingfisher, OK, August 19, 2007
Bartlesville OK, July 3, 2007
Yukon, OK, August 22, 2007
Greenfield, OK, August 19, 2007
Blaine County, OK, August 19, 2007
Pipeline Break, Blaine Co., OK
Canadian County, OK, May 9, 2007
Coffeyville, Kansas, July 2, 2007
REUTERS/Cindy Price/The Coffeyville Journal/Handout
Problems
• Many oil and gas companies (including
pipelines) do not know they need a
floodplain permit, especially in the
unincorporated counties.
• Different communities have different
floodplain requirements.
• We have a huge number of unprotected
production sites in our state’s floodplains.
So How Do You Find Them?
• Look for drilling rigs!
• Go through Landmen
– Make sure your county clerk’s office of land records
has a prominently displayed floodplain map with permit
requirement
• Check your state’s O/G regulatory agency website
• Get to know your state’s regulatory agency local
inspector
• Road Crossing Permits in your county
• County District Shops
• Assessor’s Office
• Check local newspaper listings
OK Corporation Commission Website
• Screen shot of webpage
Identifying O/G Equipment
• It’s hard to permit if you don’t know what
it is!
• Different counties and states may have
different types of production and
equipment.
Safety
• Get permission to go onto site.
• Watch out for dangers at the site.
• Safety concerns:
–
–
–
–
–
Poisonous Gas
Chemicals
Energized Electrical Equipment
Potentially Explosive Atmosphere
Armed Landowners
Drilling Rig
Photos courtesy Center for Local
Government Technology, OSU
Well Head/Christmas Tree
Photos courtesy Center for Local
Government Technology, OSU
Pump Jack
Photos courtesy Center for Local
Government Technology, OSU
In-Line Heater
Photos courtesy Center for Local
Government Technology, OSU
Separator
Photos courtesy Center for Local
Government Technology, OSU
Separator
Photos courtesy Center for Local
Government Technology, OSU
Heater
Treater
Photos courtesy Center for Local
Government Technology, OSU
Tank Batteries
Photos courtesy Center for Local
Government Technology, OSU
Tank Batteries
Photos courtesy Center for Local
Government Technology, OSU
Production Unit
Photos courtesy Center for Local
Government Technology, OSU
Production Unit
Photos courtesy Center for Local
Government Technology, OSU
Dehydrator
Photos courtesy Center for Local
Government Technology, OSU
Meter Run
Photos courtesy Center for Local
Government Technology, OSU
Meter Run
Photos courtesy Center for Local
Government Technology, OSU
Compressor
Photos courtesy Center for Local
Government Technology, OSU
Compressor
Photos courtesy Center for Local
Government Technology, OSU
Workover Rig
Photos courtesy Center for Local
Government Technology, OSU
What do the O/G companies
have to do to be compliant?
• Get floodplain permit before development
begins
• Floodproof, elevate or relocate
• Present you with floodproof or elevation
certificate(s) when completed
Specifics
• Establish BFE
• 3 Options:
– Elevate site above BFE, Elevation Certificate
required.
– Relocate site out of floodplain.
– Floodproof: Anchor all production equipment
to BFE; protect vulnerable equipment such as
well head with guard to prevent flood debris
damage. Floodproof certificates must be
provided.
Specifics Continued
• All vulnerable utilities must be above BFE.
• A closed mud pit system must be used.
• The lease road must be constructed so it will not
obstruct the flow of water.
• A culvert must be placed in the barrow ditch
where lease road meets county road.
• Tree and brush debris must be removed from
floodplain or burned.
Specifics Continued
• The O/G company should provide you with
a list of production equipment on the site.
• O/G company must notify you if
– they add new equipment.
– they sell the site to another company.
• Make agreement to be able to inspect the
site periodically after permit is completed.
Permit Steps
1. Identify site on floodplain map.
a) What is the potential water velocity at the site?
b) How far would they have to go to get tanks and
equipment out of floodplain?
c) Note whether lease road will be under water during
flood or will impede water flow.
2. Visit the site—Know your site!
a) Take photos
b) Note condition and location of trees and shrubs
Drought
Same site, during a wet year
Permit Steps cont.
3. Collect documents from the O/G company
a.
b.
c.
d.
e.
f.
g.
Completed permit application form
Detailed plans and specs for the site
Engineered anchoring plans
Staking plat
Other applicable permits
Spill Prevention and Counter Measure Plan
Emergency Evacuation Plan
Permit Steps cont.
4. Floodplain board meets to consider
approval of permit.
• Issue permit and checklist.
• If necessary schedule an intermediate
inspection.
• When development is complete, do final
inspection, collect flood proofing and/or
elevation certificates, and take photos.
THIS CERTIFIES THAT
BLAINE COUNTY FLOODPLAIN
PERMIT
NO.
26
__________
HAS BEEN
ISSUED TO
Continental
Resources, Inc.
_
LOCATION
DATE ISSUED
NW/4 Sec 14-T16N-R12W
Well Boston Trust 1-14
April 2, 2007
BY
PHONE 580-623-7283
Local Administrator
POST ON PREMISES IN PLAIN VIEW
OF A PUBLIC ROAD
Pipelines
• Have your Floodplain Board establish burial
depth requirement.
• Canadian County:
– 72 inches under creeks/rivers, 48 inches in the
rest of the floodplain
– Must sign Statement of Burial Depth
Compliance
The Good,
The Bad and
The Ugly
The Good
Proper anchoring
Proper anchoring
Proper anchoring on equipment other than tanks
Anchoring
Anchoring
Anchoring
Well Head Guard
Elevation of production site
Relocated production equipment
Relocated production equipment
The Bad and the Ugly
Infringement on waterway
Well head guard
Tree debris blocking waterway next to pad
River movement placed well head in river channel
New unpermitted equipment added after final inspection
Our Challenge:
Educate and Partner
• Media publicity
– Press releases to local newspapers
– Commissioners/Council meetings
• Website
• Floodplain presentations in community
– Civics groups are always looking for presenters!
– Hand out free floodplain maps of the county. People
love to get maps.
• OCC district quarterly meetings
• Industry association partnerships
– Oklahoma Independent Petroleum Association
– Landmen Associations
TheYukon
Review, our
partners in
educating the
public
Educate the Industry
• Approach them with an attitude of cooperation.
• If they don’t know about fp permitting, give them
the benefit of the doubt--the first time only!
• There are many different people involved with an
oil and gas site. Educate them all.
• A good working relationship with the industry is
the goal.
Amy Brandley, CFM
Canadian County Floodplain Administrator
(405) 262-1070
brandleya@canadiancounty.org
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