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