By Dave Mustafaga, CPG  |   August 12th, 2016
   
ARE YOU SOMEONE RESPONSIBLE FOR REPORTING AN EMERGENCY AT AN OIL AND GAS  WELL, PRODUCTION OR PROCESSING FACILITY?
 
On August 9, 2016 Governor John Kasich signed into effect Executive Order 2016-04K, which creates and implements a one-call emergency notification system for oil and natural gas related emergencies. This executive order allows the Ohio Department of Natural Resources (ODNR) Division of Oil and Gas Resources Management (DOGRM) to immediately adopt administrative rules necessary to implement this system. DOGRM will then have 120 days (until December 7, 2016) to implement the executive order via the normal rulemaking procedure under Ohio law. 
 
In addition, the Executive Order also makes revisions to the Ohio Fire Code (OAC 1301:7-7-01) to include fire and safety standards relating to shale oil and gas processing facilities, including general processing and fractionation facilities as authorized in ORC 3737.832. 
 
The 24/7 emergency notification telephone number is: 1-844-OHCALL1
 
The rule also discusses notification by electronic means being an option. However, the initial release by the ODNR only mentions the emergency notification hotline.
 
WHO REPORTS?
According to OAC 1501:9-8-01 “Reporting person” under the rule means any of the following:
 
  1. The owner of the well
  2.  A person to whom an order or permit is issued under ORC Section 1509
  3.  A person to whom an order or permit is issued under OAC Section 1501:9
  4. A person to whom a registration certificate is issued under ORC Section 1509.222 (brine transportation)
  5. A person engaged in an activity pursuant to ORC Section 1509.226 (surface application of brine by local governments)
“Contractors” performing services on behalf of a reporting person are required to notify the reporting person immediately (no later than 30 minutes) after the contractor becomes aware of an incident unless that time is impracticable under the circumstances. If the reporting person is not present on site and cannot be reached, the contractor shall notify DOGRM within 30 minutes after the contractor becomes aware of a reportable occurrence.  
 
For a summary listing of all REPORTABLE INCIDENTS please click HERE
 
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.
 
 
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.
 
 
By Dave Mustafaga, CPG  |   August 10th, 2016
   
REPORTABLE INFORMATION
The reporting person should provide the DOGRM with the following information either as known or as can reasonably be estimated:
 
  1. Name and phone number of a person who can provide information on this occurrence
  2. Location of the occurrence, the county, township, section/lot number, directions from the nearest intersection, and GPS coordinates of the occurrence
  3. Identification information, such as authorized owner’s or person’s name, permit number, order number, or registration     certificate number
  4. The type of occurrence or occurrences being reported
  5. Potential health effects and safety concerns associated with the occurrence
  6. Mitigation measures initiated or performed (including evacuation)
  7. Whether local fire department or emergency medical services responded to the occurrence?
  8. Identify other state or federal agencies notified
  9. If the release was a release of oil, condensate, materials saturated with these products, refined oil products, brine, or semi-solid wastes:
a.       The source of the release
b.       The chemical name, description or identity of all substances released
c.        Is the substance an extremely hazardous substance?
d.       For liquids, the estimated quantity in U.S. gallons released outside of secondary containment
e.       For solids, the estimated quantity in pounds released outside of secondary containment
f.        The date, time, and duration of the release if known
g.       Identification of the environmental medium or media into which the substance was released; and,
h.       Other actions proposed for response to the release
 
ADDITIONAL REQUIREMENTS BY THE RULE
Follow up reporting may be required to DOGRM within 30 days after the release for specific release scenarios defined in the Rule or as directed by the Chief.   
 
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.
 
 
By Dave Mustafaga, CPG  |   August 9th, 2016
   
HAZARDOUS MATERIAL INCIDENT REPORTING AT SHALE OIL PROCESSING PREMISES HAS CHANGED.
 
Section 124 The Ohio Fire Code (OAC 1301:7-7-01) revisions include fire and safety standards relating to shale oil and gas processing facilities, including general processing and fractionation facilities as authorized in ORC 3737.832.   
 
A hazardous material incident at a Shale Oil Processing Premise is defined as the following:
 
Any fire or explosion that occurs at a shale oil processing premise that results in:
  1. Death or serious physical harm to any person;
  2. Substantial risk of death or serious physical harm to any person;
  3. Over $1000 of damage to any structure, property, premise or vehicle; or 
  4. A local fire department, law enforcement agency or other emergency management agency responding to the incident location; or
Any event, occurrence, action or omission at a shale oil processing premise that results in a substantial violation of this code or the building code as listed in rule 1301:7-7-47 of the Administrative Code and that involves:
 
  1. The occupancy of a shale oil processing premise; or
  2. The handling or other use, or the results of handling or other use of, a hazardous material at or associated with a shale oil processing premise.
 
INCIDENT REPORTING
 
All hazardous material incident(s) at a shale oil processing premise shall be reported by the responsible person or, if such person is not immediately available, any other person with direct knowledge of the incident to the State of Ohio by calling 1-844-OHCALL1 (1-844-642-2551).
 
The reporting of a hazardous material incident at a shale oil processing premise shall occur immediately upon discovery or knowledge of the incident unless unsafe conditions exist that inhibit the responsible party from reporting, reporting can then be delayed until it is safe to do so. 
 
 A reporting person required to notify the State of a hazardous material incident as specified in this rule shall provide, at the time of notification, specific site features and conditions as defined in the rule.
 
The state fire marshal may require the responsible person to provide additional information at the time of initial reporting and filing of additional reports with all information as required by the state fire marshal after the incident as necessary to obtain compliance with this code. 
 
Compliance with this rule does not eliminate the requirement that a responsible person or other person as referenced in this rule comply with any other applicable state or federal law. 
 
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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