HomeMy WebLinkAbout3.3.11 2009 Spill Response Plan-FinalWilliams,zw,d-a§ww•
SPILL PREVENTION
AND
RESPONSE PLAN
March 2009
Revision 5
Prepared By:
HRL Compliance Solutions, Inc.
744 Horizon Ct, Suite 140
Grand Junction, CO 81506
For:
WILLIAMS COMPANIES, INC.
Robert Bleil, Principal Environmental Specialist
Mike Gardner, Principal Environmental Specialist
PO Box 370
Parachute, CO 81635
Table of Contents
Table of Contents 2
Table of Contents (cont'd) 3
I. Spill Prevention and Response Policy 1
II. Purpose and Scope 1
III. Plan Applicability 1
IV. Spill/Release Prevention 2
A. Standard Routine Prevention and Training 2
B. Areas of Special Concern 3
V. Spill Management 3
A. Discovery 4
B. Containment 4
C. Notification (Williams/Contractors) 5
D. Response 5
1. Williams Spills 5
2. Contractor Spills 6
E. Notification 7
F. Reporting 8
G. Remediation 8
VI. Training 9
VII. Spill /Release Costs and Invoicing 9
Table of Contents (cont'd)
Appendix A
Spill Management Flowchart
Appendix B
Containment
Appendix B-1
Spill Response Station Locations Valley and Highlands
Appendix B-2
Spill Response Station Inventory
Appendix C
Initial Notifications — Valley Asset Team
Appendix C-1
Initial Notifications — Highlands Asset Team
Appendix D
Response
Appendix D-1
Spill Investigation Letter
Appendix E
Federal and State Notification Requirements
Appendix E-1
Federal and State Notification Contact Information
Appendix E-2
Williams' Notification Guidelines
Appendix F
Federal and State Reporting Requirements
Appendix F-1
Reporting Contact Information
Williams E&P
I. Spill Prevention and Response Policy
Spill Response Plan
March 2009
It is Williams' policy that its employees and contractors implement spill prevention and
response plans in order to avoid and minimize the potential for spills and releases in the
exploration and development of natural gas leases, in accordance with Federal and state
regulations. This includes, but is not limited to the development and implementation of
Best Management Practices (BMPs), training, and other actions that prevent, and take
action to, manage spills and releases on Federal, state or private properties that are
leased, managed, owned, or otherwise used by Williams.
II. Purpose and Scope
The purpose of this plan is to provide clear, comprehensive guidance and expectations
for Williams employees and its contractors to prevent, mitigate, and manage spills and
releases. This includes spill/release prevention, discovery, notifications, response
actions, reporting, and subsequent remedial actions (as applicable).
Contractors are required to develop and implement their own spill prevention and response
plans tailored to the scope of activities as described in their Master Service Agreement
(MSA) and Request for Services (RFS), and assure their plan complies with the guidance
and expectations set forth in the Williams Spill Prevention and Response plan.
Williams management and employees supervising natural gas exploration and
development field activities, including contractor activities, are expected to have a
working knowledge of this plan, particularly the chain of command for notification and
reporting of spills and releases.
Williams contractors are responsible for their spills and releases, and those of their
subcontractors, in accordance with their (MSA). In the event of a contractor spill,
Williams responsibilities are limited to ensuring that contractors comply with applicable
federal and state regulations and guidance (including safety). Corrective action will be
implemented (by contractor) to avoid the potential for future spills.
III. Plan Applicability
This plan is applicable to all aspects of Williams exploration and development
operations including, but not limited to, drilling and completion, production, gas plant
operations, and pipeline operations. It is specifically applicable to any vehicles, facilities
and equipment that use, store, transport, dispose, or otherwise handle or manage
chemicals (MSDS-regulated chemicals), hazardous materials, E&P wastes (drilling
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Spill Response Plan
March 2009
muds, produced water, condensate), domestic waste (septic holding tanks), hazardous
waste (oil, grease) extremely hazardous substances, or any other Federal or state
regulated substance or waste.
Federal and State Spill Prevention and Management Regulations
Despite implementation of prevention practices and BMPs, spills may still occur. In the
event of a spill, regulations for spill management can be found in several Federal and
state regulations, including but not limited to the following:
> Clean Water Act (CWA): 40 CFR subchapter D parts 100-149
40 CFR 112 part 112 SPCC
> Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA); 40 CFR part 305 and part 307
> Emergency Planning and Community Right -to -Know Act (EPCRA); 40 CFR part 355
> Toxic Substance Control Act (TSCA); 40 CFR subchapter R parts 700-799
➢ Resource Conservation and Recovery Act (RCRA); 40 CFR subchapter I parts 260-299
➢ Clean Air Act (CAA); 40 CFR subchapter C parts 50-99
➢ Hazardous Materials Transportation Act (HMTA); 49 CFR parts 100-185.
➢ Federal Lands: 43 CFR 3162.5-1 Environmental Obligations. Paragraphs A, B, and
C.
Colorado state requirements for spills and releases are contained in the following
regulations:
> COGCC: Complete Rules 317b and 906 (and related sections)
➢ CDPHE: 6 C.C.R. 1007-2 & 1007-3
➢ CDOT: 8 C.C.R. 1507-25 HMT 3
IV. SpilURelease Prevention
Williams first and foremost priority is that it's employees and contractors take all
reasonable measures and implement BMPs to prevent both stationary and transportation -
related spills and releases from occurring. Measures and BMPs include, but are not
limited to the following:
A. Standard Prevention and Training
➢ Informing and training employees, contractors, and subcontractors of actions
required to avoid potential spill situations such as:
■ Checking for open or secured valves prior to, during and after
loading/unloading operations
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■ Monitoring tank levels (don't count on alarms)
• Building berms around loading/unloading areas
• Providing portable spill basins during fluid transfers
• Checking equipment (tanks, hoses, valves) for deterioration and leaks
• Servicing vehicles/equipment (oil changes, lubrication) responsibly
• Maintaining vehicles to avoid accidents resulting in spills
• Being aware of surroundings when backing or moving vehicles
• Ensuring stable ground when placing equipment, tanks and pipelines
> Providing quarterly training to new Williams and contractor personnel on how
to avoid potential spill situations.
> Provide annual training for all employees who have completed initial spill
prevention training.
B. Areas of Special Concern (317B Areas)
➢ Williams now operates or will operate in some areas which require, due to
increased public concern and new regulations, a higher level of preventative
action. This would include the following:
• All areas south of the Colorado River
• The new 317B areas as outlined in the revised COGCC 300 series rules
➢ Actions that will require further due diligence on the part of Williams when
operating in these areas would include:
• Checking for seeps and springs within a 1/8 mile radius
■ Checking for surface water such as ponds within a 1/8 mile radius.
■ Full understanding of what the new 317B areas are and knowledge of
how to implement the Beaver Creek and Battlement Mesa Tactical Spill
Response Plan.
V. Spill Management
For purposes of this plan, spill response and management addresses the major steps
listed below. A flowchart illustrating an overall view of how Williams spill response and
management operates is located in Appendix A.
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A. Discovery
Discovery includes either actual or potential spills/releases, and in some cases
situations that are not a spill or release, but someone has reported it as such. In any
event, it is important to confirm that an actual or potential spill situation has occurred
before the implementing spill response. If in doubt contact the appropriate spill
response personnel as listed in Appendix C for assistance prior to implementing this
plan.
IF A SPILL OR RELEASE PRESENTS AN IMMEDIATE THREAT TO HUMAN
HEALTH, SAFETY, THE ENVIRONMENT, EVOLVES INTO OR IS ALREADY
AN EMERGENCY SITUATION AS OUTLINED IN THE EMERGENCY
RESPONSE PLANS (ERPs), CALL 911 AND IMPLEMENT THE
APPROPRIATE ERP.
B. Containment
Containment, for purposes of this plan, means stopping the spill or release from
increasing in volume, size or duration. The person/persons who discover the spill
should attempt to contain the spill only if safe to do so.
Under no circumstances should field personnel attempt to manage an unknown spill or
situation without adequate training, personal protective equipment (PPE) or without
exercising extreme caution.
DO NOT ATTEMPT TO CONTAIN THE SPILL IF UNSAFE TO DO SO
If there is no immediate threat to human health, safety or the environment, and
you are convinced that the spill can be safely contained then one can:
> Survey the area for personal safety.
> Stop the activity or process causing the spill/release.
> Warn others in the area, secure the scene of the spill/release
> Isolate the affected spill area.
> Initiate notifications as outlined in Appendix C and C-1
➢ Avoid direct contact with the spilled material;
➢ Avoid inhalation of any gases, fumes, vapor or smoke — stay upwind;
➢ Stay at safe location near the spill until an authorized spill responder arrives.
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Spill containment options and materials used may vary depending upon the media
affected. See Appendix B for containment options and materials that can be utilized.
C. Notification (Williams/Contractors)
The person discovering the spill must make initial notifications in accordance with
Appendix C and C-1. When making the initial notifications, the information outlined
in Appendix C and C-1 must be provided. This information is also on the field
notification cards that are provided by both the Valley and Highlands Asset Teams
*URGENT NOTIFICATION REQUIREMENT*
For any petroleum product (oil, gas) spill/release that reaches live water, has the
potential to reach live water, affects a drainage that flows to live water, or is in a
317b area; immediately notify the appropriate Williams Env. Team Lead
Immediately. (See Appendix C & C1)
D. Response
1. Williams Spills
Spills in which Williams is the responsible party, response actions will be determined
by one or a combination of the following Williams designated personnel as outlined in
Appendix C:
> Williams Operations Manager or Designee
> Williams Environmental Team Lead (Bleil-Valley; Gardner -Highlands)
> Williams Spill Contractor (HRL-Valley and Highlands)
The appropriate Williams Spill Contractor will perform the following response actions:
1) Receive confirmation of containment actions
2) Direct further response actions as needed using approved spill response
contractors
3) Assign a Spill Project Number/Charge Code for response contractor invoicing
4) Investigate using the Environmental Incident Investigation Form (Appendix D)
5) Perform required Federal and/or state notifications if required (Appendix E &
F)
6) Report the status of the spill on the weekly Business Unit Spill Tracking Report
7) Forward the weekly report/updates through HRL to designated Williams
personnel
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2. Contractor Spills
Contractors with a valid MSA are fully responsible for their spills. This includes all
costs associated with responding to, containment, notification and reporting,
remediation, and corrective actions necessary to minimize the potential for future
spills. Williams or their environmental spill response contractor will complete the
necessary reporting to the appropriate federal or state agency as outlined in
Appendices E & F.
Contractor Spill, response actions will be conducted in accordance with the
Contractor's Spill Prevention and Response Plan.
Contractors will be responsible for the following items if it is determined that they are
the responsible party in the event of a spill or release:
> A meeting will be held with the responsible contractor following notification of
the spill. The contractor's representative will be in a supervisory role and will
contact the Williams spill response team lead:
1. The contractor responsible for the spill will schedule a meeting with the
Williams spill response team lead within 24 hours of the spill.
2. The contractor will bring their spill investigation form and it will be
reviewed to assure completeness of the form.
3. In addition a spill investigation letter will be filled out by the
responsible contractor and it will be submitted to the Williams spill
response team lead within 3 days of the spill or release. A copy of this
letter is located in Appendix D-1.
4. The contractor will be informed that the person or persons responsible
for the release will attend the next available spill prevention training.
> All contractors must provide proof that they have a qualified environmental
person in-house or an environmental consultant to manage spills.
In the event the responsible party has the ability to control a spill within the guidelines
of this plan, the Williams' spill response contractor will still provide oversight on
Williams' behalf to assure the spill has been managed correctly and there are no
repercussions to Williams as a result of the spill or release, if the spill is located on a
Williams lease or property.
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Contractors will be required to include and maintain a current listing of all
chemicals, substances and wastes used in their operations (as well as the applicable
MSDS sheets) in their Spill Prevention and Response Plan.
E. Notification
Federal and State verbal notification requirements for spills are based on two criteria:
1. The type of material spilled and;
2. The volume of material spilled.
3. Affected environmental media (i.e. soil, water)
These materials are further sub -divided into two categories;
1. Exploration and Production Waste (E&P Waste) such as produced water,
condensate, or any other material that has been down hole and;
2. Non -E&P Waste such as fuels and oils. This would include materials such
as diesel fuel, hydraulic oil, motor oil, and glycol.
The most common materials encountered when responding to spills and notification
volumes are outlined in Appendix E. For materials that are not listed in Appendix E,
one must consult the MSDS sheet for the material spilled, determine if it is E&P or
Non -E&P waste and make the appropriate notification if required if the reportable
quantity is exceeded. Contact information for federal and state agencies is outlined in
Appendix E-1.
In order to provide further due diligence, Williams has notification requirements for
spills, both company and contractor, with volumes that are less than the federal and
state requirements. These notification requirements are in place to satisfy
environmental obligations that the operator must comply with. These are set forth in
Title 43 of the Code of Federal Regulations. Specifically they are found in Chapter II,
Part 3160, subpart 3162, Section 3162.5-1 Environmental Obligations. These are
outlined in Appendix E-2.
*URGENT NOTIFICATION REQUIREMENT*
For any spill/release that migrates off the pad and reaches live water, or has the
potential to reach live water, or affects a drainage that flows to live water;
immediately notify the Williams Env. Team Lead Immediately. (See Appendix C)
In addition, Williams uses the notification requirements as outlined Appendix E-2 to
track and document the cause of spills so procedural changes can be implemented to
better manage spills and prevent them.
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F. Reporting
Federal and State reporting requirements for spills, as with notification, are again based
on;
1. The type of material spilled and;
2. The volume of material spilled
3. Affected environmental media (i.e. soil, water)
These materials as well are sub -divided into two categories
1. Exploration and Production Waste (E&P Waste) such as produced water,
condensate, or any other material that has been down hole and;
2. Non -E&P Waste such as fuels and oils. This would include materials such
as diesel fuel, hydraulic oil, motor oil, and glycol.
Even though a spill may not require verbal notification it still may be reportable. The
most common materials encountered when responding to spills and reporting volumes
are outlined in Appendix F. For materials that are not listed in Appendix F one must
consult the MSDS sheet for the material spilled, determine if it is E&P or Non -E&P
waste and submit the appropriate form or forms if required. Contact information for
federal and state agencies is outlined in Appendix F-1.
In the event that a spill or release resolve in significant damage to equipment, a
Form 22 will be submitted to the COGCC by Williams' safety department within 10
days of the incident.
G. Remediation
In some instances, remediation may be required when a spill occurs. Whether or not a
spill requires remediation is, again, dependant on the type of material spilled, the
volume spilled, and if the spill is contained on the pad by stormwater controls or tank
berms already in place. In addition remediation will be dependent on whether or not the
pad is a working well pad or a well pad that has been reclaimed. Spills that migrate off
any pad in volumes greater than those stated in Appendix E-2 will, in most cases, need
to be remediated. The Williams environmental team lead, or the appropriate spill
response contractor will make these determinations.
*URGENT NOTIFICATION REQUIREMENT*
For any spill/release that migrates off the pad and reaches live water, or has the
potential to reach live water, or affects a drainage that flows to live water;
immediately notify the Williams Env. Team Lead Immediately. (See Appendix C)
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In the event a spill is remediated and results in the accumulation of either E&P or Non -
E&P waste, refer to the Williams Waste Management Plan for management and
disposal of these wastes.
VI. Training
It is required that all Williams and contractor personnel responsible for spill response
and management complete Williams spill response training on an annual basis. At a
minimum this includes Operations Managers, Field Supervisors, and EHS management
and staff.
It is strongly recommended that Williams and contractor personnel performing field
response and remediation activities complete the 24 -Hour HAZWOPER course and
annual refresher courses.
As stated in Section IV, training for new Williams and contractor employees will be
offered on a quarterly basis. This can be arranged through HRL Compliance Solutions,
Inc or Cordilleran Compliance Services, Inc. Documentation that your employees have
completed the necessary training will be provided.
Williams and contractor employees that have documented proof they have completed the
initial spill response training will be required to update their training annually.
VII. Spill /Release Costs and Invoicing
All spills must be billed to the appropriate project charge code (aka AFE) regardless of
where the spill actually occurred.
For contractor spills, Williams will only pay the costs associated with oversight of the
spill billed to Williams by its Spill Response Contractor. All other costs are the
responsibility of the contractor causing the spill. This includes response costs by third
party contractors to contain spills.
Williams will not accept invoices from third parties for contractor spills. If a bill is
inadvertently forwarded to Williams, the amount will be deducted from future payments
and show as a credit to Williams.
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Appendix A.
Williams Spill Management Flowchart
?1 but .r5 bat
Soil Impact
No Reporting to
COGCC
Williams Spill Management Flow Chart
Develop
Remediation
Workplan
•
Implament
Remediation
Workplan
Submit C3osure
Report
s5 hut -420 Obis
Suit Impact
Reportto COGCC
Form 19
>-2d bbl
RepOII to COGCC
Verbally Withy 24
firs or Discovery
Submit Form 19
aFvFill 27if
Requested by COGCC
Implement
R6reedietion
Workplan
SUbrntt Closure
Report
Spill Discovered
Contain
Spill
It sure to du so
NOtipcatiortis
Appendix C
Material
SpIIIed
Water Impact
Any Amount
t
Report to f!RC.
CDPHE, COGCC, 8
BLM {FED LsaSeSl
Imrnedietely
Report la COGCC
Force 19
Complete
Form 27
Workplan
1
Implement
Remediation
Workplan
1
Submit Closure
Report
Spill Response
Station Locations
Appendhx B
Water Impact
Any Amount
Report to NRC
& CDPHE
Immediately
t
Develop
Remediation
Workplan
Implement
Remediation
Workplan
Submit Closure
Report
!Determine Materia!
Soil Imps or
gal
RO Exceeded
NFA Necessary
Submit Closure
Report
Yes
Report Ta
Appropri to Siete
cr Federal Agency
Devatap
Ranierilati-On
WeiKplan
.t
Implement
Refnedletion
Workplan
t
Subn It Closure
Rapot
Appendix B.
Containment
Williams, designated spill response, and contractor personnel involved in day to day
operations at Williams facilities should carry some basic spill response materials with them
at all times in order to contain spills and releases. However, as stated in section B of the
Spill Prevention and Response Plan;
DO NOT ATTEMPT TO CONTAIN THE SPILL IF UNSAFE TO DO SO
Listed below are some options that can be implemented for spill containment
Containment materials for spills/releases to soil and surface water
1. Portable spill kits as stated above. Kits should contain
• Absorbent pads
• Absorbent Booms
• Absorbent Clay
• Shovels
2. Soil stockpiles located in strategic locations for berm construction of needed.
3. Vacuum truck company phone numbers for removal of free liquids from pads,
roads, drainages, and surface water in the event free product or sheen is present.
In the event that additional spill response materials are needed; Williams has placed six spill
response stations at various locations. Six are located in the Valley and three are located in
the Highlands. Figures 1 & 2 in Appendix B-1 depict the locations of Williams' Spill
Response Stations. A list of materials and equipment that is stored in the spill response
stations is included in Appendix B-2.
Note: Each spill response station has an inventory checkout list that should be filled out prior
to taking materials from the station. This better enables Williams to track items utilized
during spill response. An example of the inventory checkout list is also included in
Appendix B-2.
Containment options for spills/releases to soil and surface water
If it is determined that there is no immediate threat to human health and one is certain that
the spill can be safely contained then the following options can be implemented;
1. Attempt to stop the spill at the source such as closing valves, plugging holes,
etc.
2. For releases to soil try to isolate the spill area by constructing earthen berms,
placing booms or absorbent pads around the spill avoiding direct contact with
the material spilled.
3. Remove free liquids if possible
4. For spills/releases that potentially or have impacted surface water attempt to
stop the material released at the point where it enters the water. (i.e. earthen
berms, absorbent booms/ pads) then;
5. In flowing water place booms/dikes at easily accessible downstream locations
as close to the point where the spill/release enters the surface water.
6. Have vac trucks dispatched to the location to remove any free product or sheen
visible on the water.
Appendix B-1.
Spill Response Station Locations
Valley and Highlands
w Parachute Field
Spill Response Station 35
Cottonwood Compressor Station
it „
. . T -S -94-W
Sh•
arrard.Compressor.Station_ ;�
• SpiII Response ASt n
' 1
Legend
0 SpiII Response Station
Existing Road
Figure 1:
Valley SpiII Response
Station Locations
0 0.5 1 2
Miles
Williams
c./
O:\Projects\PIC\_MultiProspect\07\0629_SpillResponseLocations_HRL\SpillResponseValley.mxd klee 3/19/2009 12:58:55 PM
Legend
0 Spill Response Station
Existing Road
Figure 2:
Highlands Spill Response
Station Locations
0
S
2.5 5
Miles
W:II:ams..
O:\Projects\PIC\_MultiProspect\07\0629_SpillResponseLocations_HRL\SpillResponseHighlands.mxd mreynold 9/25/2007 11:01:31 AM
Appendix B-2.
Spill Response Station Inventory
Spill Response Station Inventory List
All valley and Highlands spill response stations will at a minimum contain the following items
with the exception of the GV 82-5 and the RU 31-12V stations which will have additional spill
response materials as noted below.
3 -Cases 17" x 19" x 3/8" Oil absorbent Pads (12 per case)
1 -Case 7" W x 15" L Oil Absorbent Pillows (16 per case)
1 -Case 3" x 4' Mini Booms (30 per case)
2 -Cases 3" x 8" Oil Absorbent Booms (6 per case)
1 -Case 5" x 10' Oil Absorbent Booms
2 -Boxes 36" x 56" 3 mil Trash Can Liners
1 Large Tyvek Coverall
1 Extra Large Tyvek Coverall
1 -Bag Size 10 Green Nitrile Gloves (12 pairs per bag)
2 Round Point Blade Shovels
2 Square Point Blade Shovels
15 5-1/2 foot Steel Fence Posts
1 Fence Post Driver
1 -Roll 16 GA Tie Wire
1 -Bundle Wooden Stakes
1 20' x 20' Liner
6 28" Traffic Cones
2 -Rolls Duct Tape
2 -Rolls 6 mil 20' x 100' Plastic Sheeting
3 20 lb. Fire Extinguishers
1 Metal First Aid Kit
2 55 Gal. Poly Drums (Drums contain absorbent booms, pillows and pads)
1 55 Gal Steel Drum
4 5 -gallon buckets with lids
1 -sheet '/2" plywood
Note:
The GV 82-5 spill response station will contain 2-12" x 50' river booms for spills that could
potentially impact the Colorado River. It will also contain a small trash pump and associated
plumbing to pump water if necessary.
The RU 31-12V will contain an additional Case of 5" x 10' oil absorbent booms.
(Indicate Field) Spill Response Station Inventory List
All Valley and Highlands spill response stations will at a minimum contain the following items with the exception of the GV 82-5 and the RU 31-12V stations which will have additional spill response materials as noted below.
Incident Location Quantity/ Initials/ Date
3 -Cases 17" x 19" x 3/8" Oil absorbent Pads (12 per case)
1 -Case 7" W x 15" L Oil Absorbent Pillows (16 per case)
1 -Case 3" x 4' Mini Booms (30 per case)
2 -Cases 3" x 8" Oil Absorbent Booms (6 per case)
1 -Case 5" x 10' Oil Absorbent Booms
2 -Boxes 36" x 56" 3 mil Trash Can Liners
1 ea. Large Tyvek Coverall
1 ea. Extra Large Tyvek Coverall
1 -Bag Size 10 Green Nitrile Gloves (12 pairs per bag)
2 ea. Round Point Blade Shovels
2 ea. Square Point Blade Shovels
15 ea. 5-1/2 foot Steel Fence Posts
1 ea. Fence Post Driver
1 -Roll 16 GA Tie Wire
1 -Bundle Wooden Stakes
1 ea. 20' x 20' Liner
6 ea. 28" Traffic Cones
2 -Rolls Duct Tape
2 -Rolls 6 mil 20' x 100' Plastic Sheeting
3 ea. 201b. Fire Extinguishers
1 ea. Metal First Aid Kit
2 ea. 55 Gal. Poly Drums (Drums contain absorbent booms, pillows and pads)
1 ea. 55 Gal Steel Drum
4 ea. 5 -gallon buckets with lids
1 -sheet '/2" plywood
Note:
• The GV 82-5 spill response station will additionally contain 2-12" x 50' river booms for spills that could potentially impact the Colorado River. It will also contain a small trash pump and associated plumbing to pump water
if necessary.
• The RU 31-12V will contain an additional Case of 5" x 10' oil absorbent booms.
Appendix C.
Initial Notifications (Williams/Contractors)
Piceance Valley Asset Team Contacts for
Emergencies/Spills/Incidents
Piceance-Valley Asset Team Contact Emergencies/Spills/ Incidents
Name
Title/Position
Cell #
Other#
Operation Management
Steve Soychak
E&P District Manager
970-216-0922
970-309-9766
Scott Brady
Drilling/Completion Supt
970-270-9187
970-523-0332
Steve Harris
Completions Mgr
970-948-4312
303-618-7341
Brad Moss
Production/Facilities Supt
970-987-1737
970-256-3379
Paul White
District Prod Engineer Mgr -E&P
970-456-3337
970-245-5417
Health & Safety i i �
Kevin McDermott
Safety Mgr
970-309-1195
N/A
Delbert Dowling
Exploration & Production Safety Coord. Sr.
970-589-5736
N/A
Brian Gingrich
Exploration & Production Safety Coord. Sr.
970-216-6820
N/A
Greg Anoia
Exploration & Production Safety Coord. Sr.
970-216-1387
N/A
Environmental
Rob Bleil
Environmental Manager
970-210-2050
970-243-1936
Kent Rider
Environmental Lead - E Rulison
970-250-7328
970-640-5266
'Jason Raley
Environmental Lead - Parachute / W Rulison
970-210-4351
970-231-0554
Mike Shoemaker
Environmental Lead - GV / Red Point
970-250-5778
970-985-8661
Karolina Blaney
Spills / Incident Lead
970-589-0743
970-245-3791
Public Relations
Susan Alvillar
Communication Spec. III
970-216-3878
970-241-4430
Donna Gray
Communication Spec. II
970-589-1557
N/A
Land
Sandy Hotard
Field Land Manager
970-210-9709
970-256-8939
Bryan Hotard
South of the River
970-361-2006
970-985-4904
Roy McClung
North of the River
970-640-2790
970-285-7028
Contractors
Walt Proulx
MB Construction (Spill Response)
970-985-1372
970-858-8546
Gene Thurston
MB Construction -Only if can't Reach Walt
970-216-0642
N/A
Pat Brown
Roustabouts (Spill Response)
970-210-9051
970-243-8519
Mark Mumby
HRL Comp (Spills/Releases)
970-260-1576
970-243-2209
Tom Kirkpatrick
KERS! (Storm water)
970-270-7687
683 -1777 -Blake
Appendix C 1.
Initial Notifications (Williams/Contractors)
Highlands Asset Team Contacts for
Emergencies/Spills/Incidents
Piceance HIGHLANDS Asset Team Contacts -- Emergencies/Spills/Incidents
Name
Title/Position
Cell # Other # 1 Home #
ENVIRONMENTAL EMERGENCIES/INCIDENTS (spills, pits/liners, wildlife, storm water, etc...)
Environmental Management Contacts:
Mike Gardner
Environmental Team Manager
970-623-4875
970-263-2760
970-858-0708
John Suchar
Environmental Specialist
970-274-9543
970-623-8988
970-640-8993
Jason Rauen
Environmental Specialist
970-274-4564
970-623-8993
970-254-9377
Tom Kirkpatrick
KERSI (Storm water Contractor)
970-270-7687
N/A
N/A
Mark Mumby
HRL (Spill Response Contractor)
970-260-1576
970-243-3271
970-243-2209
Kris Rowe
HRL (Spill Response Contractor)
970-261-2015
970-243-3271
N/A
Herman Lucero
HRL (Spill Response Contractor)
970-261-3571
970-243-3271
970-241-0296
Drilling Management --contacts for incidents associated w/ drilling activities
M
Jim Jackson
Drilling Superintendent
970-930-5396
888-623-2253
N/A
Lyn Cass
Drilling Superintendent
970-755-0083
970-263-2716
970-984-0647
Completions Management --contacts for incidents associated w/ completion activities
Jim Lake
Completions Superintendent
970-270-7356
970-263-2761
970-285-2245
Colt Stewart
Completions Supervisor
970-623-5153
N/A
N/A
Production/Operations Management --contacts for incidents associated w/ production and operations
Blake Roush
Highlands Project Manager
970-260-7028
970-263-5321
N/A
Ron Cornett
Construction Manager
970-987-4603 1
970-623-8947
N/A
Darryl
Zimmerman
Construction Supervisor
970-755-0090
N/A
N/A
Scott Dembowski
Ryan Gulch Supervisor
970-755-0078
877-532-9926
N/A
Sam Bevan
Allen Point Supervisor
970-589-1435
970-263-2813
N/A
Mike Grattan
Allen Point Supervisor
970-250-9680
970-263-5317
N/A
Equipment Contractors --Contact if there is an IMMEDIATE need for equipment
Bob Prather
MB Construction
970-574-8120
970-250-0385
N/A
Doug Moody
Moody Construction
970-379-6351
970-878-8771
N/A
Quentin Hoops
Roustabout Specialties
970-640-3360
N/A
N/A
Curt Dembowski
C & J Field Services
970-629-5161
970-675-2480
N/A
Spill Response Stations --Access only for IMMEDIATE need of spill response/containment materials
Ryan Gulch Station: Located at Ryan Gulch Compressor Station
Trail Ridge Station: Located at Trail Ridge Man Camp
Allen Point Station: Located at AP 34-8-695 Well Pad
HEALTH & SAFETY EMERGENCIES (operational/vehicle accidents involving human health)
Health & Safety Management Contacts:
Kevin McDermott
Safety Spec Team Leader
970-309-1195
970-683-2294
N/A
Delbert Dowling
Safety Coord. Sr. - Drilling
970-589-5736
970-623-8918
N/A
Brian Gingrich
Safety Coord. Sr. - Production
970-216-6820
970-263-2705
N/A
Greg Anoia
Safety Coord. Sr. - Plants
970-216-1387
970-263-1387
N/A
Spill Notification Information Checklis
Caller should provide the following information for
X Name of caller w/ call back number
X Location of incident
X Type of substance released
X Estimated quantity released
X Time/Date of incident
X Responsible party
X Cause of incident
X Impacted areas (i.e. pad surface only, off location, surface
X Immediate response/mitigation actions
safe and efficient
water, etc)
incident response:
Revised 11/21/2008
Appendix D.
Response
Williams Environmental Incident Investigation Form
Surface Owner
Notification Required
Contacted By
Date
Williams
ENVIRONMENTAL
INCIDENT
INVESTIGATION
Occurred:
(FIELD WORKSHEET — NOT OFFICIAL)
Location ID:
Field T R S Qtr/Qtr
Investigation Date: Lead:
Incident Log Entry:
Time: Discovered By: Company:
Phone:
INCIDENT TYPE RELEASE TYPE LANDS AFFECTED MEDIA AFFECTED BIOTA AFFECTED
( ) Facility
( ) Transportation
( ) E&P Waste
( ) Non — E&P
( ) Private
( ) Federal
( ) State
( ) Land/Soils
( ) Air
( ) Waters (U.S.)
( ) Wetland/Riparian
( ) Ground water
( ) None
( ) Plants
( ) Wildlife — Game
( ) Wildlife — T&E
( ) Wildlife — Non -game
( ) Other:
( ) Other:
( ) On -Lease
( ) Off -Lease
SIGNIFICANT THREAT TO HUMANS OR ENVIRONMENT ( ) NO ( ) YES — Implement Emergency Response
INCIDENT DESCRIPTION (How incident occurred, type of effluent, emissions, chemical,
etc.):
Y
N
Date:
ESTIMATED VOLUME/QUANTITY OF RELEASE:
RESPONSIBLE PARTY:
COMPANY: CONTACT: PHONE:
WILLIAMS CONTACTS:
Parachute: ( ) Bleil ( ) Gardner
RESPONSE ACTIONS
Response Contractor - 1: Date: Time:
Response Contractor - 2: Date: Time:
Environmental Contractor Contacted
()Yes()No
Samples Required:
() Yes ()No
COCs:
DESCRIPTION OF ACTIONS (Equipment/Materials Used, containment, soils removed, water removed,
etc.)
Date:
Y
N
Terminated By: Date: Time:
SURFACE OWNER / REPORTING ACTIONS
AGENCY NOTIFICATION / REPORTING ACTIONS
Agency/Owner
Notification Required
Reporting Required
Fed - BLM
Y
N
Date:
Y
N
Date:
COGCC
Y
N
Date:
Y
N
Date:
CDPHE
Y
N
Date:
Y
N
Date:
NRC
Y
N
Date:
Y
N
Date:
REMEDIAL ACTION REQUIRED: ( ) NO ( ) YES:
FORM 22 REQUIRED: ( ) NO ( ) YES: If yes contact HSE for submittal of the Form 22
Appendix D1 .
Response
Williams Spill Investigation Letter
.--_:_-------,-,
Williams
‘,.....,...
WILLIAMS PRODUCTION RMT COMPANY
1058 County Road 215
P.O. Box 370
Parachute, Colorado
81635
office (970) 285-9377
fax (970) 285-9573
(Date)
(Contractor's Address)
Dear Mr or Ms.
The following information is required to be submitted to Williams within 3 business days of the
date of the spill to demonstrate compliance with the terms and conditions of your MSA regarding
spills.
a. The date and time of the spill
b. The date, time Williams was notified
c. The name of the Williams' person contacted
d. The name of the responsible supervisor
e. The name of the responsible individual
f. The name of your Environmental Consultant
g. Description of what was spilled
h. The cause of the spill
i. The volume of the spill
j. Media Affected (soil, live water, drainage, vegetation)
k. The location of the spill on a 1:24,000" topo map or aerial photo, with GIS coordinates.
1. Photos of the spill
m. Actions taken to stop and contain the spill
n. Planned remediation
o. Storage, treatment and disposal of spill waste
p. Communication with third parties to include law enforcement, other agencies.
q. A copy of your Spill Prevention and Response plan
r. Evidence that the responsible individual and supervisor are trained in spill prevention and
response.
s. Planned actions to prevent further occurences
Spill Prevention and Response is critical to Williams reputation with regulatory agencies,
landowners and the communities in which we operate. Repeated spills and releases that may be
deemed as negligence by Williams or regulatory agencies may result in revisions to, or termination
of, your MSA with Williams.
Karolina Blaney
Williams Spill Program Lead
.--_:_-------,-,
Williams
‘,.....,...
WILLIAMS PRODUCTION RMT COMPANY
1058 County Road 215
P.O. Box 370
Parachute, Colorado
81635
office (970) 285-9377
fax (970) 285-9573
cc: R. Bleil
M. Paules
E. Joyner
M. Mumby (HRL)
Operations Manager
Appendix E.
Federal and State Notification Requirements
APPENDIX E - FEDERAL AND STATE NOTIFCATION REQUIREMENTS
E&P Waste
Chemical
Media Affected
Minimum Amount to
Report
RQ
Notification
Requirement
(Verbal)
NRC
COGCC
CDPHE
BLM
Condensate/Crude Oil
Surface
water/Groundwater
Any Amount Impacting
Water (FEE/FED)
Immediately
X
X
X
X
Soil
>5 bbls but <20 bbls (FEE)
None
>20 bbls (FEE)
24 Hours
X
>10 bbls but <100 bbls (FED)
24 Hours
Io
bbls
>100 bbls (FED)
24 hours
X
X
Produced Water/Flowback
Water
Surface
water/Groundwater
Any Amount Impacting
Water(FEE/FED)
Immediately
X
X
X
X
Soil
>5 bbls but <20 bbls (FEE)
None
>20 bbls (FEE)
24 Hours
X
>10 bbls but <100 bbls (FED)
24 Hours
I>20f
bbls
>100 bbls (FED)
24 Hours
X
X
Non E&P Waste
Diesel Fuel/Gasoline
Surface
water/Groundwater
Any Amount Impacting
Water (FEE/FED)
Immediately
X
X
X
Soil
> 25 gallons (FEE/FED)
24 Hours
X
>10 bbls but <100 bbls (FED)
24 Hours
X
>100 bbls (FED)
24 Hours
X
X
Waste Oil/Lube Oil
Surface
water/Groundwater
Any Amount Impacting
Water (FEE/FED)
Immediately
X
X
X
Soil
> 25 gallons (FEE/FED)
24 Hours
X
>10 bbls but <100 bbls (FED)
None
X
>100 bbls (FED)
24 Hours
X
X
Chemical
Media Affected
Minimum Amount to
Report
Notification
Requirement
NRC
COGCC
CDPHE
BLM
Footnote:
1. Notification requirements that are listed above are for the most common chemicals encountered in day to day Williams operations.
2. For chemicals not listed consult the MSDS for the chemical of concern or call a Williams environmental team lead.
3. Reportable quantities that are reported by weight need to be converted to a barrel or gallon equivalent for BLM notification
requirements.
4. See attachment 1 for contact information.
RQ
(Verbal)
Ethylene Glycol
Surface
water/Groundwater
Any Amount Impacting
Water (FEE/FED)
Immediately
X
X
X
Soil
1,000 lbs. (FEE/FED)
24 Hours
X
3
>10 bbls but <100 bbls (FED)
None
X
3
>100 bbls (FED)
24 Hours
X
X
Methanol
Surface
water/Groundwater
Any Amount Impacting
Water (FEE/FED)
Immediately
X
X
X
Soil
> 25 gallons (FEE/FED)
24 Hours
X
>10 bbls but <100 bbls (FED)
None
X
>100 bbls (FED)
24 Hours
X
X
Methyldiethanolamine
Surface
water/Groundwater
Any Amount Impacting
Water (FEE/FED)
Immediately
X
X
X
Soil
1,000 lbs. (FEE/FED)
24 Hours
X
3
>10 bbls but <100 bbls (FED)
None
X
3
>100 bbls (FED)
24 Hours
X
X
Footnote:
1. Notification requirements that are listed above are for the most common chemicals encountered in day to day Williams operations.
2. For chemicals not listed consult the MSDS for the chemical of concern or call a Williams environmental team lead.
3. Reportable quantities that are reported by weight need to be converted to a barrel or gallon equivalent for BLM notification
requirements.
4. See attachment 1 for contact information.
Appendix E-1.
Federal and State Notification Contact Information
Public Safety Officials and Government Agencies
Public Safety Notification - Verbal
Fire 911
Police/Sheriff 911
Colorado State Highway Patrol Hazardous Waste Division ..970-858-2291
Government Agency Notifications — Verbal
National Response Center 1-800-424-8802
(24 hr/day — 7 days/week)
Colorado Department of Natural Resources 303-894-2100
Oil and Gas Conservation Commission (24 hr/day)
Colorado Department of Public Health and Environment 970-625-2497
24 Hour Spill Response
Colorado Department of Public Health and Environment 303-692-3500
Water Quality Control Division
Garfield County Health Department 970-625-5200
U.S. Department of Interior, BLM, White River Field Office 970-878-3800
U.S. Department of Interior, BLM, Glenwood Springs Field Office 970-947-2800
U.S. Department of Interior, BLM, Grand Junction Field Office 970-244-3000
Appendix E-2.
Williams Notification Guidelines
Williams Company and Contractor Notification Requirements
As stated in section E. of this plan, Williams has established threshold values on materials spilled
or released in order to provide additional due diligence to satisfy federal and state requirements.
Also Williams utilizes this data to track and identify potential trends to implement procedural
changes which can better manage spill/releases and better manage them. The Williams reporting
requirements area as follows;
1. Any spill of E&P waste (produced water, condensate) greater than 1 barrel and Any Spill of
non -E&P waste (Diesel fuel, motor oil) greater than 5 gallons needs to be reported to the
proper Williams environmental team lead in order to provide the due diligence requirements
set forth in Section 3162.5-1 of the Code of Federal Regulations.
2. Any spill of E&P or non -E&P waste in the quantities listed above that has migrated off-site
needs to be reported to the appropriate Williams environmental team lead Immediately.
As stated above; if you are unable to contact the designated Williams personnel listed in
Appendix C, contact the appropriate spill response contractor (HRL Valley/Highlands) so any
notification/reporting that may be necessary can be completed within the designated reporting
time.
*URGENT NOTIFICATION REQUIREMENT*
For any spill/release that migrates off the pad and reaches live water, or has the
potential to reach live water, or affects a drainage that flows to live water;
immediately notify the Williams Drilling/Field Lead Supervisor and the appropriate
Williams Env. Team Lead Immediately. (See Appendix C)
Appendix F.
Federal and State Reporting Requirements
APPENDIX F - FEDERAL AND STATE REPORTING REQUIREMENTS
E&P Waste
Chemical
Media Affected
Minimum Amount to
Report
RQ
Reporting
Requirement
(Written)
NRC
COGCC
CDPHE
BLM
Condensate/Crude Oil
Surface
water/Groundwater
Any Amount Impacting
Water (FEE/FED)
10 days (State)
15 days (Fed)
X
X
Soil
>5 bbls but <20 bbls (FEE)
10 days
X
>20 bbls (FEE)
10 days
X
>10 bbls but <100 bbls (FED)
10 days (State)
15 days (Fed)
IF > 20
bbls
X
>100 bbls (FED)
10 days (State)
15 days (Fed)
X
X
Produced Water/Flowback
Water
Surface
water/Groundwater
Any Amount Impacting
Water (FEE/FED)
10 days (State)
15 days (Fed)
X
X
Soil
>5 bbls but <20 bbls (FEE)
10 days
X
>20 bbls (FEE)
10 days
X
>10 bbls but <100 bbls (FED)
10 days (State)
15 days (Fed)
If > 20
bbls
X
>100 bbls (FED)
10 days (State)
15 days (Fed)
X
X
Non E&P Waste
Diesel Fuel/Gasoline
Surface
water/Groundwater
Any Amount Impacting
Water (FED)
15 days
X
Soil
> 25 gallons (FEE/FED)
None
>10 bbls but <100 bbls (FED)
15 Days
X
>100 bbls (FED)
15 Days
X
Waste OiI/Lube Oil
Surface
water/Groundwater
Any Amount Impacting
Water (FED)
15 Days
X
Soil
> 25 gallons (FEE/FED)
None
>10 bbls but <100 bbls (FED)
15 Days
X
>100 bbls (FED)
15 days
X
Chemical
Media Affected
Minimum Amount to
Report
RQ
Notification
Requirement
(Verbal)
NRC
COGCC
CDPHE
BLM
Ethylene Glycol
Surface
water/Groundwater
Any Amount Impacting
Water (FED)
15 Days
X
Soil
1,000 lbs. (FED)
None
3
>10 bbls but <100 bbls (FED)
15 Days
3
>100 bbls (FED)
15 Days
X
Methanol
Surface
water/Groundwater
Any Amount Impacting
Water (FED)
15 days
X
Soil
> 25 gallons (FEE/FED)
None
>10 bbls but <100 bbls (FED)
None
3
>100 bbls (FED)
15 Days
3
Methyldiethanolamine
Surface
water/Groundwater
Any Amount Impacting
Water (FED)
15 Days
X
Soil
1,000 lbs. (FED)
15 Days
3
>10 bbls but <100 bbls (FED)
None
3
>100 bbls (FED)
15 Days
X
Footnote:
1. Reporting requirements that are listed above are for the most common chemicals encountered in day to day Williams operations.
2. For chemicals not listed consult the MSDS for the chemical of concern or call a Williams environmental team lead.
3. Reportable quantities that are reported by weight need to be converted to a barrel or gallon equivalent for BLM reporting
requirements.
4. See attachment 1 for contact information.
5. Notify the Colorado State Highway Patrol for transportation related spills involving hazardous materials.
Appendix F-1.
Reporting Contact Information
Government Agency Reporting — Written
Colorado Department of Public Health and Environment 303-692-3500
Water Quality Control Division
4300 Cherry Creek Drive South
Denver, Colorado 80222-1530
Colorado Department of Natural Resources 303-894-2100
Oil and Gas Conservation Commission
707 Wapiti Ct., Suite 204
Rifle, Colorado 81650
Colorado Public Utilities 303-894-2000
1580 Logan Street, 2nd Floor
Denver, Colorado 80203
U.S. Department of Transportation 202-366-4595
Office of Pipeline Safety
Information Resource Manager
Washington, DC 20590
(Gas Distribution — Form RSPAF 7100.1-1)
Gas Transmission and Gathering — Form 7100.2-1)
U.S. Department of Transportation 720-963-3161
Office of Pipeline Safety
12300 West Dakota Avenue, Suite 110
Lakewood, Colorado 80228
(To Obtain Forms RSPAF 7100.1-1 and 7100.2-1)