The panel started off by summarizing the points discussed during yesterday's SPCC Workshop that we blogged on at length. Please take a look at that blog post for more information.
The panel then moved on to discuss the exemption of fracking flow back water from regulation. However, the EPA is interested in examining the issues and associated risks. There is a draft oil and gas spill policy that is being circulated that will require that all spills regardless of quantity are to be reported. There are also sections on remediation addressing small spills, Act 2 process, and alternate clean up methods.
Act 13 of 2012 requires that drilling and fracking operations have secondary confinement to contain ground spills. There is an API guidance document that give examples of containment that can be used on site.
The Pennsylvania Land Recycling Act (Act 2) encourages voluntary cleanups and uses risk based standards to guide cleanups. Three cleanup standards are: statewide (concentrations of carcinogens and toxins, residential and non-residential exposures); background; and site specific.
The Secretary of Energy Advisory Board, Governor's Marcellus Shale Advisory Commission, and Citizen's Marcellus Shale Group are three bodies that are providing commentary on secondary containment. They note that the greatest risk comes from ground spills from fracking support services and not directly from fracking.
Best practices include:
- Keep the frac pad surface clean and dry to prevent falls.
- Multiple layers of pad liners are a tripping hazard. Composite liners are puncture resistant and recyclable.
- Frac tank containment needs to be 110% of tank capacity. If a wall is used that is greater than 2 feet, supply wall ladders to prevent falls when entering the containment area. This will prevent worker injuries.
- Fluid dispensing is a high-risk area for spills that should have secondary containment.
- Surround spills with booms to prevent spreading.
- Mark your spill response trailer with GPS coordinates so that you can locate it in an emergency.