Secondary Containment for Oil & Gas Well Pads
Upcoming SlideShare
Loading in...5
×
 

Secondary Containment for Oil & Gas Well Pads

on

  • 2,529 views

Secondary containment regulations and best management practices

Secondary containment regulations and best management practices

Statistics

Views

Total Views
2,529
Views on SlideShare
2,522
Embed Views
7

Actions

Likes
0
Downloads
20
Comments
0

2 Embeds 7

http://www.linkedin.com 6
http://honyaku.yahoofs.jp 1

Accessibility

Categories

Upload Details

Uploaded via as Microsoft PowerPoint

Usage Rights

© All Rights Reserved

Report content

Flagged as inappropriate Flag as inappropriate
Flag as inappropriate

Select your reason for flagging this presentation as inappropriate.

Cancel
  • Full Name Full Name Comment goes here.
    Are you sure you want to
    Your message goes here
    Processing…
Post Comment
Edit your comment
  • The specific secondary containment requirements are intended to address a major container failure (the entire contents of the container and/or compartment) associated with a bulk storage container; single compartment of a tank car or tank truck at a loading/unloading rack; mobile/portable containers; and production tank batteries, treatment, and separation installations. These specific provisions (see Table 4.1 in Section 4.2) explicitly provide requirements for sizing, design, and freeboard that need to be addressed in the SPCC Plan. The general secondary containment requirements are intended to address the most likely oil discharge from bulk storage containers; mobile/portable containers; production tank battery, treatment, and separation installations; a particular piece of oil-filled operational or process equipment; (non-rack) transfer activity; or piping in accordance with good engineering practice. SPCC 40CFR112.7(c) The entire containment system, including walls and floor, must be capable of containing oil and must be constructed so that any discharge from a primary containment system, such as a tank or pipe, will not escape the containment system before cleanup occurs. At a minimum, you must use one of the following prevention systems or its equivalent: (1) For onshore facilities: (i) Dikes, berms, or retaining walls sufficiently impervious to contain oil; (ii) Curbing; (iii) Culverting, gutters, or other drainage systems; (iv) Weirs, booms, or other barriers; (v) Spill diversion ponds; (vi) Retention ponds; or (vii) Sorbent materials .
  • Environmental Protection Agency State Departments of Environmental Protection Occupational Safety & Health Administration American Petroleum Institute Marcellus Shale Coalition S tate R eview of O il & N atural G as E nvironmental R egulations
  • EPA jurisdiction is provided for under the Clean Water Act
  • Onshore Production Bulk storage containers, including tank batteries, separation, and treating facility installations 112.9(c)(2) Onshore Oil Drilling and Workover Mobile drilling or workover equipment 112.10(c)
  • Among the wastes covered by the 1978 proposal were “gas and oil drilling muds and oil production brines.” The oil and gas exemption was expanded in the 1980 legislative amendments to RCRA to include “drilling fluids, produced water, and other wastes associated with the exploration, development, or production of crude oil or natural gas. . . .” The following simple rule of thumb can be used to determine if an E&P waste is exempt or non-exempt from RCRA Subtitle C regulations: 1) Has the waste come from down-hole, i.e., was it brought to the surface during oil and gas E&P operations? 2) Has the waste otherwise been generated by contact with the oil and gas production stream during the removal of produced water or other contaminants from the product? If the answer to either question is yes, then the waste is likely considered exempt from RCRA Subtitle C regulations. It is important to remember that all E&P wastes require proper management to ensure protection of human health and the environment. Non-Exempt Wastes Unused fracturing fluids or acids Waste solvents Service company wastes such spent solvents, spilled chemicals, and waste acids Used equipment lubricating oils Waste compressor oil, filters, and blowdown Used hydraulic fluids Caustic or acid cleaners
  • Section 6.4.4
  • Oil and Gas Act (Act 223) Any well operator who affects a public or private water supply by pollution or diminution shall restore or replace the affected water supply…(Sec. 601.208) Clean Streams Law (P.L. 1987, Act 394 or 1937) Discharge of industrial waste or any substance into the waters which causes pollution is against public policy (Section 3) Permits are required to discharge industrial waste (Section 303, 307) If impounding, handling, storage, transportation, processing or disposing of materials creates a danger of pollution, DEP may establish the conditions under which such activity may be conducted (Section 402) Solid Waste Management Act § 78.55. Control and disposal plan.   (a)  Prior to generation of waste, the well operator shall prepare and implement a plan under §  91.34 (relating to activities utilizing pollutants) for the control and disposal of fluids, residual waste and drill cuttings, including tophole water, brines, drilling fluids, additives, drilling muds, stimulation fluids, well servicing fluids, oil, production fluids and drill cuttings from the drilling, alteration, production, plugging or other activity associated with oil and gas wells.   (b)  The plan shall identify the control and disposal methods and practices utilized by the well operator and be consistent with the act, The Clean Streams Law (35 P. S. § §  691.1—691.1001), the Solid Waste Management Act (35 P. S. § §  6018.101—6018.1003) and § §  78.54, 78.56—78.58 and 78.60—78.63.   (c)  The operator shall revise the plan prior to implementing a change to the practices identified in the plan.   (d)  A copy of the plan shall be provided to the Department upon request. § 91.34. Activities utilizing pollutants.   (a)  Persons engaged in an activity which includes the impoundment, production, processing, transportation, storage, use, application or disposal of pollutants shall take necessary measures to prevent the substances from directly or indirectly reaching waters of this Commonwealth, through accident, carelessness, maliciousness, hazards of weather or from another cause.   (b)  The Department may require a person to submit a report or plan for activities described in subsection (a). Upon notice from the Department and within the time specified in the notice, the person shall submit to the Department the report or plan setting forth the nature of the activity and the nature of the preventative measures taken to comply with subsection (a). The Department will encourage the use of pollution prevention measures that minimize or eliminate the generation of the pollutant over measures which involve pollutant handling or treatment. The Department will encourage consideration of the following pollution prevention measures, in descending order of preference, for environmental management of wastes: reuse, recycling, treatment and disposal. http://apps.sos.wv.gov/adlaw/files/rulespdf/35-01.pdf
  • S tate R eview of O il & N atural G as E nvironmental R egulations (independent body of state, industry and environmental stakeholders) IN PA, secondary containment liners are recommended but not required.
  • Best Practices for Drilling and Well Co nstruction Waste management strategy should include storage containment, spill contingency plan, transfer and disposal procedures (3.8) Fuel storage should include secondary containment (6.3) Drilling fluid tanks and manifolds should be considered for placement inside lined secondary containment areas. (10.6) Drilling fluid containment and catchment systems should be considered. (10.7) Best Practices for Well Completion and Work-over Operations Waste management strategy should include storage containment, spill contingency plan, transfer and disposal procedures (3.8) Fuel storage should include secondary containment (6.3) Work-over fluid tanks and manifolds should be considered for placement inside lined secondary containment areas. (10.5) Work-over fluid containment and catchment systems should be considered. (10.6)
  • Secretary of Energy Advisory Board:
  • Secretary of Energy Advisory Board:
  • Pad Containment --This is the main liner that is placed over a large square footage, typically centered off the wellheads. This is the first liner installed before a rig move. Highly suggest attaching the liner directly to the cellar walls, either mechanically or with a coating, to prevent any back up at the well head from pushing under the liner. Berming is typically 6" to 8" high. Although some operators tie into plastic barricades (to control traffic to designated areas), the entrance ways are typically only 6" to 8".   Tank Farm Containment --This is the containment under the battery of frac tanks and may or may not be on top of Pad Containment.  Plastic, metal or concrete barricades are used to provide high walls to meet the 110% containment of the largest tank or 10% of the total volume in a small footprint.  If walls are 3' or higher, use a bridge ladder to enter/exit since you cannot step over them easily.   Equipment Containment --This liner that is placed directly under equipment that is leak prone.  It may be on the Pad Containment to limit spread (mud tanks, pump house) or it could be under a generator, light post, sewer treater, etc. that is off the Pad Containment.  Berming is typically 6" to 8" high.   Containment Recommended Practices: 1. Large panels should be seamed together with a wedge welder, not a hot air gun or extrusion welder, to ensure good seam contact over long lengths. The hot air gun and extrusion welder should only be used for spot repairs or detail work around obstacles.  2. Fuel tanks should be double-walled. Some operators place them on two liners (Pad and Equipment/Tank Containment), with the second cut to fit around them specifically. This provides four levels of containment.  3. If secondary containment walls are higher than 3', use a bridge ladder to enter and exit the area.  4. If you have designated entrance areas, string flag the rest or place plastic barricades around the perimeter. Avoid posts that could be impalement hazards.  5. Do not use metal L-brackets to build spot containment. They are an impalement hazard.  6. Vacuum off standing water before it freezes. If over an inch, it takes a long time to melt off.  7. Use dark colored liner in the winter. The sunlight in the morning will quickly melt ice and evaporate water.  8. Do not place pipe racks directly on the containment liner. This is one of the most hole prone areas. Use rig mats on the liner or keep the liner tight to the catwalk.  9. Use rig mats for the drill cutting bins and trackhoe path on the liner. This is one of the most hole prone areas.  10. Use outrigger pads when positioning heavy equipment on the containment liner. This is one of the most hole prone areas.  11. Use liners with high coefficients of friction to limit slips and falls when wet. Avoid ones with smooth seams. There is a large change in the coefficient of friction between the two areas.  12. Limit loose layers and wrinkles in the containment liner. Wrinkles should be pulled out during installation. The edges should be sandbagged until the berm is in place or berm at least two sides before equipment moves in.  13. Do not place grounding rods in high traffic areas. They are an impalement hazard. Cover exposed ends with buckets, tennis balls or other protective cushioning. If placed through the liner, boots or gaskets must be used. 14. Place a liner sleeve into the cellar and bond the liner edges to it to conform to the opening. This should then be mechanically fastened to prevent spills in the cellar from spreading under the liner.  15. Clean up hydrocarbon spills as quickly as possible, such as drilling mud and pipe dope. Place catch basins where this is likely to happen (i.e. valves).  16. Make frac tank containment a stand-alone containment. The base liner should wrap and terminate at the berm. Patching a berm over the top is suspect for leaks.  17. Test field suspect seams for water tightness. A vacuum tester is non-destructive.   18. The subbase has a large effect on the number of patches required throughout the liner lifetime. A gravel base will shift to disperse load; 2A Modified is recommended.  2B has rounded stones and results in few punctures--but may develops ruts.  Avoid a hard surface (cement dirt) with scattered loose stones since the forces will be concentrated on the scattered stones. A covering of dust/screening over larger rocks will work—but may turn into mud as operations progress. All pads should be rolled before the liner is installed.   19.  If corrugated pipe is used to make the berm, the sections that meet to establish a corner should strapped together to prevent kick out.        
  • Pad Containment --This is the main liner that is placed over a large square footage, typically centered off the wellheads. This is the first liner installed before a rig move. Highly suggest attaching the liner directly to the cellar walls, either mechanically or with a coating, to prevent any back up at the well head from pushing under the liner. Berming is typically 6" to 8" high. Although some operators tie into plastic barricades (to control traffic to designated areas), the entrance ways are typically only 6" to 8".   Tank Farm Containment --This is the containment under the battery of frac tanks and may or may not be on top of Pad Containment.  Plastic, metal or concrete barricades are used to provide high walls to meet the 110% containment of the largest tank or 10% of the total volume in a small footprint.  If walls are 3' or higher, use a bridge ladder to enter/exit since you cannot step over them easily.   Equipment Containment --This liner that is placed directly under equipment that is leak prone.  It may be on the Pad Containment to limit spread (mud tanks, pump house) or it could be under a generator, light post, sewer treater, etc. that is off the Pad Containment.  Berming is typically 6" to 8" high.   Containment Recommended Practices: 1. Large panels should be seamed together with a wedge welder, not a hot air gun or extrusion welder, to ensure good seam contact over long lengths. The hot air gun and extrusion welder should only be used for spot repairs or detail work around obstacles.  2. Fuel tanks should be double-walled. Some operators place them on two liners (Pad and Equipment/Tank Containment), with the second cut to fit around them specifically. This provides four levels of containment.  3. If secondary containment walls are higher than 3', use a bridge ladder to enter and exit the area.  4. If you have designated entrance areas, string flag the rest or place plastic barricades around the perimeter. Avoid posts that could be impalement hazards.  5. Do not use metal L-brackets to build spot containment. They are an impalement hazard.  6. Vacuum off standing water before it freezes. If over an inch, it takes a long time to melt off.  7. Use dark colored liner in the winter. The sunlight in the morning will quickly melt ice and evaporate water.  8. Do not place pipe racks directly on the containment liner. This is one of the most hole prone areas. Use rig mats on the liner or keep the liner tight to the catwalk.  9. Use rig mats for the drill cutting bins and trackhoe path on the liner. This is one of the most hole prone areas.  10. Use outrigger pads when positioning heavy equipment on the containment liner. This is one of the most hole prone areas.  11. Use liners with high coefficients of friction to limit slips and falls when wet. Avoid ones with smooth seams. There is a large change in the coefficient of friction between the two areas.  12. Limit loose layers and wrinkles in the containment liner. Wrinkles should be pulled out during installation. The edges should be sandbagged until the berm is in place or berm at least two sides before equipment moves in.  13. Do not place grounding rods in high traffic areas. They are an impalement hazard. Cover exposed ends with buckets, tennis balls or other protective cushioning. If placed through the liner, boots or gaskets must be used. 14. Place a liner sleeve into the cellar and bond the liner edges to it to conform to the opening. This should then be mechanically fastened to prevent spills in the cellar from spreading under the liner.  15. Clean up hydrocarbon spills as quickly as possible, such as drilling mud and pipe dope. Place catch basins where this is likely to happen (i.e. valves).  16. Make frac tank containment a stand-alone containment. The base liner should wrap and terminate at the berm. Patching a berm over the top is suspect for leaks.  17. Test field suspect seams for water tightness. A vacuum tester is non-destructive.   18. The subbase has a large effect on the number of patches required throughout the liner lifetime. A gravel base will shift to disperse load; 2A Modified is recommended.  2B has rounded stones and results in few punctures--but may develops ruts.  Avoid a hard surface (cement dirt) with scattered loose stones since the forces will be concentrated on the scattered stones. A covering of dust/screening over larger rocks will work—but may turn into mud as operations progress. All pads should be rolled before the liner is installed.   19.  If corrugated pipe is used to make the berm, the sections that meet to establish a corner should strapped together to prevent kick out.        
  • It may be on the Pad Containment to limit spread (mud tanks, pump house) or it could be under a generator, light post, sewer treater, etc. that is off the Pad Containment.  Berming is typically 6" to 8" high.

Secondary Containment for Oil & Gas Well Pads Secondary Containment for Oil & Gas Well Pads Presentation Transcript

  • Secondary Containment Beth Powell Managing Director Well Pad Containment Division www.newpig.com/shalegas
  • Secondary Containment Safeguarding method in addition to the primary containment systemSpecific/Sized – Indoor: Sump capacity should contain 10% of the volume of total containers or the total volume of the largest container, whichever is greater – Outdoor: Plus sufficient freeboard to contain precipitationGeneral – Address typical failure mode and the most likely quantity – Passive or Active
  • Regulations and Best Practices EPA PA DEP LiquidsSTRONGER AdvisoryAPI CommissionsMSC & Boards
  • EPAOil & Gas Extraction Point Source – 40 CFR 435.32 – There shall be no discharge of waste water pollutants into navigable waters from any source associated with production, field exploration, drilling, well completion, or well treatment (i.e., produced water, drilling muds, drill cuttings, and produced sand).
  • SPCCSpill Prevention, Control, and Countermeasure (SPCC) – 40 CFR 112 – Monitors plans to prevent oil spills at facilities • 1320 gallons of above-ground storage capacity • Potential to reach “navigable waters” • Oil, oil-like and oil/water mixtures – Clarifies “facility”; can be considered mobile or portable – Sets compliance date of November 10, 2011 for facilities that came into operation after August 12, 2002 http://www.epa.gov/osweroe1/docs/oil/spcc/spcc_101_prod.pdf
  • SPCC 40CFR112.7(c)The entire containment system, including walls and floor, must be capable ofcontaining oil and must be constructed so that any discharge from a primarycontainment system, such as a tank or pipe, will not escape thecontainment system before cleanup occurs.At a minimum, you must use one of the following prevention systems or its equivalent: (1) For onshore facilities: (i) Dikes, berms, or retaining walls sufficiently impervious to contain oil; (ii) Curbing; (iii) Culverting, gutters, or other drainage systems; (iv) Weirs, booms, or other barriers; (v) Spill diversion ponds; (vi) Retention ponds; or (vii) Sorbent materials.
  • SPCC Examples Methods Description of Secondary Containment ExamplesDikes, berms, or retaining walls Raised earth embankments or concrete containment walls used in areas with potential for largesufficiently impervious to contain oil discharges, such as single or multiple aboveground storage tanks and certain piping.Curbing Permanent concrete or asphalt apron surrounded by a curb. Can be used where only small spills are expected and also used to direct spills to drains or catchment areas.Culverting, gutters, or other drainage Types of permanent drainage systems designed to direct spills to remote containment orsystems treatment areas.Weirs Dam-like structures with a notch through which oil may flow to be collected. Used in combination with skimmers to remove oil from the surface of water.Booms Form a continuous barrier placed as a precautionary measure to contain/collect oil. Typically used for the containment, exclusion, or deflection of oil floating on water, and is usually used to address oil spills that have reached surface waters.Barriers Spill mats, storm drain covers, and dams used to block or prevent the flow of oil.Spill diversion and retention ponds Designed for long-term or permanent containment of storm water capable to capture and hold oil or runoff and prevent it from entering surface water bodies.Sorbent materials Materials include spill pads, pillows, socks, mats, clay, vermiculite, and diatomaceous earth. Used to isolate and contain small drips or leaks until the source of the leak is repaired. Used to isolate and contain small drips or leaks until the source of the leak is repaired. Drip pansDrip pans are commonly used with product dispensing containers (usually drums), uncoupling of hoses during bulk transfer operations, and for pumps, valves, and fittings.Sumps and collection systems A permanent pit or reservoir and the troughs/trenches connected to it that collect oil.
  • SPCC ProvisionsType of Facility Secondary Containment Rule Section(s)All Facilities General containment (areas with 112.7(c) potential for discharge, e.g., piping, oil-filled operating and manufacturing equipment, and non- rack related transfer areas)Onshore Storage Bulk storage containers 112.8(c)(2) or 112.12(c)(2) Mobile or portable oil containers* 112.8(c)(11) or 112.12(c)(11)Onshore Production Bulk storage containers, including 112.9(c)(2) tank batteries, separation, and treating facility installations*Onshore Oil Drilling and Workover Mobile drilling or workover 112.10(c) equipmentOffshore Oil Drilling, Production, and Oil drilling, production, or workover 112.7(c)Workover equipment SPCC Guidance for Regional Inspectors http://www.epa.gov/oem/docs/oil/spcc/guidance/4_SecondaryContainment_Impracticability.pdf
  • SPCC § 112.10 Provisions• If you are the owner or operator of an onshore oil drilling and workover facility, you must:• (a) Meet the general requirements listed under §112.7, and also meet the specific discharge prevention and containment procedures listed under this section.• (b) Position or locate mobile drilling or workover equipment so as to prevent a discharge as described in §112.1(b).• (c) Provide catchment basins or diversion structures to intercept and contain discharges of fuel, crude oil, or oily drilling fluids.• (d) Install a blowout prevention (BOP) assembly and well control system before drilling below any casing string or during workover operations. The BOP assembly and well control system must be capable of controlling any well-head pressure that may be encountered while that BOP assembly and well control system are on the well.
  • RCRAResource Conservation & Recovery Act (RCRA) – 40 CFR 260-265 (generator standards) – Restricts hazardous waste collection and storage – Defines “characteristic” and “listed” hazardous wastes • Ignitability • Corrosivity • Reactivity • Toxicity – Exempts flowback fluids at federal level (state laws may apply) – May not exempt fracturing fluids at federal level
  • NPDESNational Pollutant Discharge Elimination System (NPDES) – 40 CFR 122 – Limits water pollution through permits – Defines oil pollution as a “sheen” on the water – Regulates stormwater discharges from construction sites (1 acre plus), industrial facilities and municipalities – Considers sediment to be the most common pollutant – Requires E&P sites to have sediment controls – Delegates permitting to states; all Marcellus Shale states have received delegation
  • Hydraulic Fracturing StudySection 6.4.4• EPA is interested in gathering information relating to the current on-site management practices that are used to prevent and/or contain accidental releases of flowback and produced water to drinking water resources.
  • PA DEPOil & Gas ActClean Streams LawSolid Waste Management ActPrevention, Preparedness and Contingency (PPC) Plan• 25 Pa. Code §§ 78.55 Control and Disposal Plan• 25 Pa. Code §§ 91.34 Activities Utilizing Pollutants• Spills of 5 gallons or greater are reportable
  • Oil & Gas Spill Policy Draft• Report a spill or release regardless of the quantity spilled• If secondary containment is in place, notify if the quantity of material exceeds 42 gallons• Remove the spilled material from the secondary containment within 24 hours• When spilled onto the ground, the material is usually either residual waste or hazardous waste
  • STRONGERPennsylvania Hydraulic Fracturing State Review—September 2010Recommendation 9.2.1.10. – The review team recommends that secondary containment requirements be established for tanks used in hydraulic fracturing operations.
  • Act 13 of 2012• The environmental protection provisions are effective April 16, 2012.• Unconventional well sites must be designed and constructed to prevent spills to the ground surface or off the well site. Containment practices must be in place during both drilling and hydraulic fracturing operations and must be sufficiently impervious and able to contain spilled materials, and be compatible with the waste material or waste stored within the containment. Containment plans must be submitted to the department and describe any equipment that is to be kept onsite to prevent a spill from leaving the well pad.• Containment systems shall be used wherever drilling mud, hydraulic oil, diesel fuel, drilling mud additives, hydraulic fracturing additives, and/or hydraulic fracturing flowback are stored. Containment areas must be sufficient to hold the volume of the largest container stored in the area plus ten percent. (§3218.2 of the Act) http://files.dep.state.pa.us/OilGas/OilGasLandingPageFiles/Act13/Act_13_FAQ.pdf
  • API Recommend PracticeEnvironmental Protection for Onshore Oil and Gas Production Operations and Leases (51R)– Containment should be constructed so spilled fuels or chemicals do not reach the ground– Control the spread to the smallest possible area • Drip pans under equipment and storage containers • Retaining walls or dikes around tanks and other spill prone equipment • Secondary catchment basins • Permanent booms in the adjoining water basin • Temporary booms deployed after the spill occurs • Cleanup materials sufficient to handle small spills stocked on site
  • API Guidance DocumentPractices for Mitigating Surface Impacts Associated with Hydraulic Fracturing (HF3) – Spill prevention, response and cleanup procedures as part of SOP manual for storing oil, chemicals or other fluids – Installation of containment, BMPs, barriers and response equipment • Sloping well location away from surface water • Retaining walls or dikes around tanks • Secondary catchment basins • Absorbent between sites and surface waters • Temporary containment and liners during drilling and completions
  • Marcellus Shale Coalition Best Practices for Drilling and Well Construction &Best Practices Well Completion and Work-over Operations– Waste management strategy should include storage containment, spill contingency plans, transfer and disposal procedures– Fuel storage should include secondary containment– Drilling fluid tanks and manifolds should be considered for placement inside lined secondary containment areas– Drilling fluid containment and catchment systems should be considered
  • Appalachian ShaleRecommended Practices Group Recommended Standards and Practices – The use of an impermeable material (natural or manmade) under critical well pad areas. – The use of secondary containment for tanks (excluding freshwater). – Store liquid additives with secondary containment – Appropriate amounts of sorbent materials (spill kits)
  • Commissions & BoardsSecretary of Energy Advisory Board Incidents causing problems have been unrelated to fracking itself but have arisen from surface spills, poor cementing jobs in wellbores and other operational failuresGovernor’s Marcellus Shale Advisory Commission8.1.1The primary concerns regarding hydraulic fracturing relate to surface spills of fluids, well control and lost containment of production and flowback water on the surfaceCitizen’s Marcellus Shale Commission2.2 Well pads should be impervious and tanks should be surrounded by secondary containment to capture any spillage
  • Energy Institute University of Texas at Austin• Surface spills of fracturing fluids appear to pose greater risks to groundwater sources than from hydraulic fracturing itself• Gaps remain in the regulation of well casing and cementing, water withdrawal and usage, and waste storage and disposal• Regulations should focus on the most urgent issues, such as spill prevention — which may pose greater risk than hydraulic fracturing itself• Enforcement actions tend to emphasize surface incidents more than subsurface contaminant releases, perhaps because they are easier to observe
  • Shale ContainmentsPad – Large square footage, typically centered off the wellheads – 6 to 8 inch high bermsTank – 110% (150% in WV) of the largest tank – 2 to 3 foot high bermsEquipment – Placed under equipment that is leak prone – 6 to 8 inch high berms
  • Pad Containment Work surfaces should be as clean and dry as possible to prevent slips and falls. Tip: Polyethylene liners should be covered in felt to increase the coefficient of friction. Tip: Limit wrinkled, loose layers of material to reduce tripping hazards. OSHA 29 CFR 1910.22 SPCC 40 CFR 112.7 NPDES 40 CFR 122.26 RCRA 40 CFR 264.175
  • Composite Pad Liners Composite liners are slip resistant and 4X more puncture resistant. Tip: Withstands rigging up and down. Tip: Doesn’t crack when cold. Tip: Holes are readily detectable and easily repairable. Tip: Recyclable to reduce 93% of landfill burden. OSHA 29 CFR 1910.22 SPCC 40 CFR 112.7New Pig Patents Pending NPDES 40 CFR 122.26 RCRA 40 CFR 264.175
  • Pad Subbase Avoid mud. Tip: Cement dirt should be capped with at least 2 inches of stone. Tip: Stone should firm (no rolling or pumping) and rolled. Tip: Stone should be 2 inches or less in diameter. 2A Modified is preferred. River rock may develop rutts.
  • Soft Subbase
  • Resulting Rutts
  • Pad Layout Start square to end square. This is important when using rig mats. Tip: Square off of the main wellhead. Tip: Mark side and account for berming width. Tip: Use sand bags to keep panels in place. Tip: Starting and stopping lines reduce wasted material.
  • Seam Welding Automated wedge welders should be used for all liners to join large panels together. Tip: Set to correct temperature and speed depending on material and site conditions. Tip: Avoid “walking the dog”. Use a handle to guide the welder. OSHA 29 CFR 1910.22 SPCC 40 CFR 112.7 NPDES 40 CFR 122.26 RCRA 40 CFR 264.175
  • Leak Testing Split welder seams can be tested by pressure. Solid wedge welder seams can be tested by vacuum. Tip: Vacuum tester can be moved 30 inches every 10 seconds OSHA 29 CFR 1910.22 SPCC 40 CFR 112.7 NPDES 40 CFR 122.26
  • Patching Plastic Liner: 2)Dry surface 3)Heat tack patch 4)Grind edge 5)Extrusion weld Composite Liner: 8)Dry surface 9)Surround with sealant 10)Heat tack patch OSHA 29 CFR 1910.22 SPCC 40 CFR 112.7 NPDES 40 CFR 122.26 RCRA 40 CFR 264.175
  • Attachment to Cellar Prevents leak in cellar from backing up under the liner. Tip: Can be mechanically attached or spray coated with polyurea. OSHA 29 CFR 1910.22 SPCC 40 CFR 112.7 NPDES 40 CFR 122.26 RCRA 40 CFR 264.175
  • Traffic Control Control access to either ramps or foam berms.   Tip: Plastic barricades seem to have the most success in limiting traffic. OSHA 29 CFR 1910.22 SPCC 40 CFR 112.7 NPDES 40 CFR 122.26 RCRA 40 CFR 264.175
  • Low-Wall Berming Most common materials are railroad ties, corrugated pipe or foam. Tip: Tie corrugated pipe corners together to prevent kick out. Tip: Folds should reach the top of the berm to maintain sump capacity. OSHA 29 CFR 1910.22 SPCC 40 CFR 112.7 NPDES 40 CFR 122.26 RCRA 40 CFR 264.175
  • Grounding Rods Ideally grounding rods should be outside of the pad containment. Tip: Use a boot with standing pipe. Pipe should be as tall as the berm. OSHA 29 CFR 1910.22 SPCC 40 CFR 112.7 NPDES 40 CFR 122.26 RCRA 40 CFR 264.175
  • Hole Prone AreasPipe Racks – Use rig mats or outrigger pads OR – Keep liner tight to catwalkBackyard – Use rig mats for trackhoe path to drilling cutting binsOutriggers – Use outrigger pads when positioning heavy equipment
  • Frac Tank Containment 110% of largest tank. Berm walls are typically metal, concrete or plastic barricades. Tip: Subtract out tank displacement when calculating capacity. Tip: Keep separate from pad containment. Berm should terminate, meaning no hats. Tip: Higher sidewalls increase sump capacity for smaller footprints.
  • Brine Tank Containment Brine tanks are permanent structures and should have permanent secondary containment. Tip: Install a ladder to prevent falls. OSHA 29 CFR 1910.22 SPCC 40 CFR 112.7 NPDES 40 CFR 122.26 RCRA 40 CFR 264.175
  • Fuel Tank Containment Fuel tanks should be double wall construction so that secondary containment travels with the tank. Tip: Tertiary containment Tip: Quaternary containment OSHA 29 CFR 1910.22 SPCC 40 CFR 112.7 NPDES 40 CFR 122.26 RCRA 40 CFR 264.175
  • Equipment Containment Typically used under generators, light posts, and sewer treaters. Tip: Can be reused from site to site. OSHA 29 CFR 1910.22 SPCC 40 CFR 112.7 NPDES 40 CFR 122.26 RCRA 40 CFR 264.175
  • Collapsible Storage Lightweight and reusable spot containment can be used for tanks, separators and vehicles. Tip: Float-up walls reduce impalement and tripping concerns. Tip: Drive-through options eliminate need to drop and raise walls. SPCC 40 CFR 112.7 NPDES 40 CFR 122.26 RCRA 40 CFR 264.175
  • Perimeter Control Sediment and oil are the two largest stormwater pollutants. Remember, it only takes a sheen for a spill to be reportable. Tip: Compost-filled sock does not fall over. Tip: Can be treated to remove oil and heavy metals. NPDES 40 CFR 122.26 25 Pa. Code §§ 78.55 25 Pa. Code §§ 91.34
  • Fluid Dispensing Fluid dispensing is a high-risk area for spills. Tip: Place quick-throw berms under hose connections. OSHA 29 CFR 1910.106 SPCC 40 CFR 112.7 NPDES 40 CFR 122.26
  • Universal Spill Removal Surround spill with booms to prevent spreading. Tip: Choose socks filled with earthen materials to create stronger containment dikes. Tip: Absorbent mats cover large surface areas to soak up spills. NPDES 40 CFR 122.26 25 Pa. Code §§ 78.55 25 Pa. Code §§ 91.34
  • Oil/Diesel Spill Removal Oil-only absorbents will not pick up water, which reduces disposal costs. Tip: Place booms at an angle in water basins as a preventative measure. Tip: Select UV-resistant absorbents if installed in the field for more than 3 months. SPCC 40 CFR 112.7 NPDES 40 CFR 122.26 25 Pa. Code §§ 78.55 25 Pa. Code §§ 91.34
  • Response Trailers Equipment available for cleanup of a given spill must be listed. Tip: Use GPS coordinates to mark locations of the off-site trailers. Tip: Keep first responder boom supplies on site to surround perimeter. OSHA 29 CFR 1910.120 SPCC 40 CFR 112.7 25 Pa. Code §§ 78.55 25 Pa. Code §§ 91.34
  • Truck Kits Address the typical failure mode and the most likely quantity. Tip: 5- to 8-gallon kits fit inside cabs. Tip: Consider pop-up pools for fuel tank damage and shovels for spills to soil. OSHA 29 CFR 1910.120 SPCC 40 CFR 112.7 25 Pa. Code §§ 78.55 25 Pa. Code §§ 91.34
  • Drain Covers Storm drains are a major entry point into U.S. waters, which can trigger multiple violations. Tip: Cover drains during bulk transfer as a precaution. SPCC 40 CFR 112.7 NPDES 40 CFR 122.26
  • Waste Collection – Solid Reduce air pollutant emissions from storage containers with continuous gaskets. Tip: Latching lids provide easy access for frequently opened and closed containers. RCRA 40 CFR 262.34 RCRA 40 CFR 264.1086
  • Waste Collection – Liquid Hazardous waste can be collected in satellite accumulation drums in quantities of 55 gallons or less. Tip: Use a funnel with integral venting and overflow prevention to reduce spills. OSHA 29 CFR 264.1086 RCRA 40 CFR 262.34 RCRA 40 CFR 264.173
  • Contaminated Soil Keep spill waste separate from drill cuttings. Tip: Stock bags with the highest weight capacity and UN rating needed.
  • Questions?