JUST WHAT CONSTITUTES A REPORTABLE INCIDENT UNDER THE AUGUST 9TH SHALE OIL AND GAS EMERGENCY RULE UPDATE?
By Dave Mustafaga, CPG  |   August 11th, 2016
   
REPORTABLE INCIDENTS | You must contact ODNR-DOGRM when any of the following happens:
 
  1. Natural Gas- A release of natural gas via blowout, uncontrolled pop-off valve in an urbanized area, or a release of gas that threatens public safety.
  2. Hydrogen Sulfide- A release of hydrogen sulfide within the working area of a production operation or on location in a sustained airborne concentration exceeding 20 parts per million (ppm) for a duration greater than 10 minutes or results in injury or death of an individual.
  3. Fire or Explosion- A fire or explosion on a production operation or on location that requires an emergency responder to be contacted by the reporting person.   Non-reportable incidents such as a controlled flare or burn, properly functioning emission control devices per Ohio EPA, subsurface detonation of perforation guns, seismic shots, or controlled blasting for well site construction are excluded from this provision.
  4. Release of oil, condensate, or materials saturated with these products- A release of oil, condensate, or materials saturated with these products outside of secondary containment and into the environment in an amount over 210 U.S. gallons (i.e. 5 barrels) within a 24-hour period.
  5. Release of oil, condensate, or materials saturated with these products in defined environmentally sensitive areas- A release of oil, condensate or materials saturated with these products outside of secondary containment and into the environment in an amount over 25 U.S. gallons within a 24-hour period in an urbanized area, an emergency management zone of a surface water public drinking water supply, the five-year time of travel associated with a groundwater-based public drinking water supply, and a 100-year flood hazard area (per FEMA’s national flood insurance rate map).
  6. Release of refined products outside of secondary containment- A release of refined oil products (including oil-based drilling fluid, petroleum distillate, spent or unused paraffin solvent, gasoline, fuel oil, diesel fuel, or lubricants) outside of secondary containment and into the environment in an amount exceeding 25 U.S. gallons within a 24-hour period.
  7. Release to waters of the state- A release of oil, condensate, materials saturated with these products or refined oil products that enters the waters of the state and causes a film or sheen on the surface of the water.
  8. Release of brine or semi-solid wastes- A release of brine or semi-solid wastes (including drilling mud, sludge, or tank bottom sediments) outside of secondary containment and into the environment in an amount exceeding 42 U.S. gallons within a 24-hour period.
  9. Release of brine from a vehicle, vessel, railcar, or container- A release of brine from a vehicle, vessel, railcar, or container that enters the environment and in an amount that exceeds 42 U.S. gallons.
  10. Release of hazardous substance or extremely hazardous substance- A release of a hazardous substance or an extremely hazardous substance at a production operation or on location in a reportable amount (per the appropriate federal definition of these substances) with any 24-hour period.
For a summary on the required REPORTABLE INFORMATION please click HERE
 
For information on MATERIAL INCIDENT REPORTING AT A PROCESSING PREMISE click HERE
 
ADDITIONAL INFORMATION
For additional information on the emergency rule, including draft language, please visit the ODNR-DOGRM’s website, located at: http://oilandgas.ohiodnr.gov/laws-regulations/opportunities-for-involvement#DR2
Dave Mustafaga, CPG, Senior Project Manager | Environmental Division Leader
David oversees the operations of Hull’s Environmental Division and Site Assessment and Remediation Practice Area and has over 20 years of experience conducting and managing environmental investigations and corrective actions.  He has experience permitting unconventional oil and gas wells in Ohio, co-facilitating public outreach meetings associated with pre-drill groundwater sampling events, evaluating water sourcing and well siting constraints, and conducting emergency response action investigations on active oil and gas well sites.  In our rapid response work, David serves as both coordinator of personnel and technical director responsible for quality of the work and compliance with regulatory obligations.
 
 
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