Topic Highlights
Spills and leaks pose a risk to human health, ecosystem health, and our business. We take our approach to prevent and manage spills and leaks seriously by seeking to meet or exceed all local, state, and federal policies. If a spill or leak does occur, we aim to respond in an effective and timely manner.
In 2023, we:
- Conducted two drills that involved our Incident Command System (ICS) to respond to incidents and spills simultaneously. The drills allowed employees to practice using the ICS and determined where fail spots may arise in the case of an actual incident.
- Performed more than 2,200 proactive inspections.
What We are Doing
Spills and leaks can adversely impact our landowner partners and lead to ecological damage, environmental fines, remediation costs, operational delays, and reputational risk. We work diligently to avoid spills and leaks and mitigate the potential impacts on human and environmental health when a spill or leak occurs. Our approach to prevent and manage spills and leaks aims to meet or exceed all local, state, and federal policies. If a spill or leak does occur, we aim to respond in an effective and timely manner. We outline all expectations related to spills and leaks to our employees and business partners as part of our Environmental, Health, and Safety (EHS) Management System and in our EHS Handbook.
Governance
Our EHS team reports to our Vice President, EHS and oversees our compliance, spill prevention, and response activities. A member of our EHS team and two backup individuals are always available to receive calls in the event of a spill. Our Vice President, EHS reports information on any significant spills or leaks to the Public Policy and Corporate Responsibility (PPCR) Committee of the Board of Directors and our Environmental, Social, and Governance (ESG) Committee. For more efficient and rapid small-spill response, spills of less than 3 gallons are routed from our emergency call center directly to our third-party remediation business partner, enabling our EHS team to focus on responding to larger, more impactful spills or leaks, should one occur.
Spill and Leak Prevention
To reduce the likelihood and impact of significant spills or leaks, we maintain Spill Prevention, Control, and Countermeasure plans, or Preparedness, Prevention, and Contingency plans, for every worksite that stores fluid. These comprehensive plans, based on regulations established by the U.S. Environmental Protection Agency and the Pennsylvania Department of Environmental Protection (PADEP), guide our employees and contractors to minimize the chance for a release and dictate the actions required should a spill or leak occur. The plans define training programs, inspection protocols, secondary containment monitoring, and repair programs required at each natural gas well and compressor station.
We deploy targeted strategies at each stage of our operations to prevent spills and leaks, for example:
- We implement measures to monitor the risk of a spill or leak and to detect potential equipment failures, including installation of pressure sensors and onsite inspections.
- Our third-party inspectors look for and identify open or closed pad drains during operations and create a corrective action when applicable.
We closely monitor equipment performance, carefully manage wastewater from our operations, and host routine meetings with water haulers to prevent spills from our water system. For more information, please see Water.
Additionally, we hold our employees and contractors to ambitious standards for spill and leak prevention and we continuously work to improve the training we provide. We require all our business partners to complete spill-specific training through our contractor management portal, in addition to our annual EHS training required by all personnel. Our spill-specific training covers methods to prevent, identify, contain, report, and safely control any releases encountered on EQT property. For additional details about our EHS program, please see Workforce Health and Safety.
Spill and Leak Response
When a spill or leak is reported, we request photos and videos to immediately determine the magnitude of the spill, so that our Remediation team can promptly investigate the incident and determine an appropriate response. We strive to achieve a 2-hour response time from our professional remediation company, regardless of the spill size. The Local Government and Community Affairs team is notified of every spill over 5 gallons. The team uses experience from training and input from the EHS team to determine the potential environmental and community impacts and associated procedure for stakeholder notification.
We use appropriate cleanup techniques to mitigate the spill’s impacts, including removal of effluents from soil. We promptly remove and dispose of cleanup materials according to applicable federal, state, and local regulatory requirements to minimize the impact on the environment and local community. We then evaluate the cause of the spill or leak to identify and implement corrective action. We integrate improved techniques and protocols into design standards, operations, and future spill prevention plans to prevent repeat accidents. We share these with employees and contractors to continuously improve our operations. Additionally, we host frequent business partner meetings to discuss their spill and leak performance and make recommendations for improvement.
Our emergency response and preparedness program requires the following actions in the event of an incident:
- Determine the source and type of spill and begin corrective action;
- Evacuate any employees who require medical attention;
- Isolate the area and stop the spill as soon as possible with appropriate methods;
- Contain the spill with available resources — including containment ditches, diking, and spill kits complete with absorbent booms, pads, pillows, and personal protective equipment (we do not use chemical dispersants);
- Report the spill through our Emergency Hotline, which notifies the relevant EHS Coordinator to determine appropriate remediation actions; and
- Perform, or observe, proper cleanup measures as directed by the EHS Coordinator.
We continue to update and refine our ICS to meet stakeholder expectations and industry best practices. In 2023, we conducted two drills that involved use of our ICS to respond to incidents and spills simultaneously. The drills allowed employees to practice using our ICS and determined where fail spots may arise in the case of an actual incident.
Our EHS team meets weekly with our Production Engineering team to review and identify top indicators for potential spills from the prior week. For each incident, we have a Significant Incident Review meeting to discuss what happened, why it happened, and how we plan to prevent a similar future occurrence. Additionally, we hire professional service contractors to manage all spills and leaks associated with our operations. We host frequent meetings with contractors to better understand the incident and discuss our expectations and share findings with other operations and business partners to prevent future occurrences.
Within our digital work environment, we generate dedicated spill and leak reports to notify appropriate personnel of a spill. We provide spill and leak reports to our professional remediation contractors to centralize status updates and appropriate documentation. This allows us to more cohesively track and report spills. This centralized system allows multiple departments, operational groups, support groups, and business partners to be informed from the time an incident is first reported through corrective action and closure.
How We are Doing
We actively work to improve our process for managing spills and leaks. Members of our EHS team periodically perform proactive environmental inspections on all our well sites. Our EHS team performed more than 2,200 proactive inspections in 2023. Our hotline number to report spills and leaks is distributed among our employees and contractors, and we strongly emphasize the importance to report spills, regardless of size or quantity. We also host a quarterly roundtable with other operators in Appalachia to discuss a broad set of topics, including spill and leak performance. For more information, see Workforce Health and Safety.
We do not operate in the Arctic and, therefore, we had no spills that impacted the Arctic or shorelines with Environmentally Sensitive Index rankings 8 to 10.[1]
Reportable Spills Resulting in a Release[2]
| 2021 | 2022 | 2023 | |||
| # | BOE | # | BOE | # | BOE |
Hydrocarbon releases >1 barrels of oil (BBL; 1 barrel of oil equivalent [BOE]) | 1 | 3.6 | 0 | 0 | 1 | 1 |
Non-hydrocarbon releases >1 BBL (1 BOE) | 12 | 23,485[3] | 27 | 311 | 36 | 797 |
Total spills resulting in a release >1 BBL (1 BOE) | 13 | 23,489 | 27 | 311 | 37 | 798 |
Hydrocarbon releases >5 gallons and <1 BBL | 7 | 6 | 9 | 2 | 11 | 2 |
Non-hydrocarbon releases >5 gallons and <1 BBL | 59 | 17 | 56 | 765 | 46 | 14 |
Total spills resulting in a release >5 gallons | 79 | 23,512 | 92 | 1,078 | 94 | 814 |
[1] The scope of spills to environmentally sensitive shorelines include spills to water that reached the soil or spills directly to the soil of shorelines with Environmentally Sensitive Index levels 8 through 10, where levels are defined according to U.S. National Oceanic and Atmospheric Administration’s shoreline sensitivity rankings list.
[2] Includes only reportable spills and volumes outside containment. Our threshold for disclosure of spills is 5 gallons due to the fact that applicable state Departments of Environmental Protection do not require spills under 5 gallons to be reported.
[3] 2021 includes the high estimated range from a subsurface produced water leak associated with a gas processing unit disposal line at one of our well pad sites located in Washington County, Pennsylvania, which we discovered in December 2021. Due to the age of the wells, the released produced water contained only elevated levels of chlorides, with no evidence of other fracturing chemicals. As a result, while some vegetation and aquatic life may have been impacted, testing suggests that these impacts, if any, were minor. This lack of distressed vegetation around the site and subsurface nature of the release impacted our ability to identify the release through earlier onsite inspection. We self-reported the release to the PADEP and are continuing to work cooperatively with PADEP on this matter.