oil and gas floodplain regulation amy brandley, cfm floodplain administrator, canadian county, ok

Oil and GasFloodplain 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 photosb) 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 companya. Completed permit application form

b. Detailed plans and specs for the site

c. Engineered anchoring plans

d. Staking plat

e. Other applicable permits

f. Spill Prevention and Counter Measure Plan

g. 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 NW/4 Sec 14-T16N-R12W Well Boston Trust 1-14 DATE ISSUED 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

Canadian County Floodplain Management

201 N Choctaw Ave El Reno, OK 73036

(405) 262-1070 ext 6260 Dear Permit Holder: Enclosed you will find your floodplain permit issued by Canadian County. Please display in a prominent location at the development site. An intermediate and final inspection may be necessary to complete your floodplain development permit process. First:

Please schedule an inspection with me before the foundation is poured on an elevated structure so that any errors in lowest floor elevation can be corrected before the foundation is set.

Please schedule an inspection with me and the flood-proofing engineer or architect before flood-proofing structures are set in place.

No intermediate inspection is required. When your development is completed, please contact me so that I can do the final inspection. Please have the following ready at the final inspection:

Flood proofing certificate(s) signed by a licensed engineer or architect for the following structure(s):_______________________________________ ___________________________________________________________ ___________________________________________________________

Elevation Certificate of the lowest floor (including basement) completed by a licensed engineer, architect, or land surveyor for the following structures:__________________________________________________ ___________________________________________________________ ___________________________________________________________

No certificate needed.

Failure to provide the required certification is a violation of this permit. Your permit is not complete until the final inspection is done and until I have certified that you have fulfilled all the requirements of your permit. If you have any questions, please do not hesitate to contact me. Amy Brandley Date Floodplain Administrator