Why It Matters to Us
In addition to impacting the environment, spills can adversely impact our landowner partners and lead to environmental fines, remediation costs, operational delays and reputational risk. We recognize stakeholder concerns regarding the substances involved in a spill, and work hard to avoid spills and mitigate the potential impacts on human and environmental health when a spill occurs.
What We Are Doing
We are committed to preventing spills to protect people, the environment and our business. We take our approach to managing spills seriously by seeking to meet or exceed all local, state and federal policies. If a spill does occur, we seek to ensure a timely and effective response. We outline all expectations related to spills to our employees in our Environmental, Health and Safety (EHS) Management System, and our Contractor Environmental Handbook shares our expectations with contractors.
Our Environmental Operations Compliance team oversees our compliance, spill prevention and response activities, reporting to our Director, Environmental Affairs. A member of this team and two backup individuals are available at all times to receive calls in the event of a spill. All large-scale incidents are reported to our Vice President, Environmental, Health and Safety and our Chief Executive Officer. Our Vice President, Environmental, Health and Safety reports information on spills to our Public Policy and Corporate Responsibility Committee on a quarterly basis and to our Environmental, Social and Governance (ESG) Committee on a periodic basis.
To reduce the likelihood and impact of significant spills, we maintain Spill Prevention, Control and Countermeasure (SPCC) plans for every worksite that stores fluid. These comprehensive plans, based on regulation established by the U.S. Environmental Protection Agency (EPA), guide our employees and contractors to minimize the chance for a release and dictate the actions required should a spill occur. The plans define training programs, inspection protocols, secondary containment monitoring and repair programs required at each of our natural gas wells and compressor stations.
We deploy targeted strategies at each stage of our operations to prevent spills. We implement measures to monitor the risk of a spill and detect potential equipment failures, including installing pressure sensors and conducting onsite inspections. We pay special attention to managing wastewater from our operations during production. For example, we require pad drains to be closed during operations to prevent substances from leaving the site. Water collected from the pad drains is tested to ensure we meet applicable water quality requirements before it is released back into the environment. The completion phase of our operations represents the biggest risk for potential leaks due to the large volume of water on site. To appropriately manage these risks, we deploy ongoing monitoring activities and utilize specialized spill containment and leak prevention equipment to reduce the risk of groundwater contamination.
At EQT, we hold our employees and contractors to high standards for spill performance. We want everyone working on our behalf to take spill prevention seriously. To that end, we continuously work to improve the training we provide related to managing spills. In 2019, we rolled out our FOCUS program, geared toward promoting an overall culture of safety — including spill prevention — through family, obligation, communication, understanding and support. We designed and implemented a FOCUS training related to safe water hauling in 2019 that more than 800 EQT contractors and employees completed. For additional details, see Occupational Health and Safety.
When a spill is reported, we request photos and videos to immediately determine the magnitude of the spill so our Remediation team can further investigate the incident and determine an appropriate response. We strive to achieve a two-hour response time from our professional remediation company, regardless of the spill size.
In the event of a spill, we use appropriate cleanup techniques to mitigate the spill’s effects, including removal of effluents from soil. We promptly remove and dispose of cleanup materials according to prevailing federal, state and local regulatory requirements, thereby minimizing the impact on the environment and local community. We then evaluate the cause of the spill to identify and implement corrective action. We work to prevent repeat accidents by integrating improved techniques and protocols into design standards, operations and future spill prevention plans. We share these with employees and contractors to continuously improve our operations.
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 taking corrective action.
- Evacuate any employees requiring medical attention.
- Isolate the area, and stop the spill as soon as possible using 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 Environmental Coordinator to determine appropriate remediation actions.
- Perform, or observe, proper cleanup measures as directed by the Environmental Coordinator.
As part of our company policy, we hire professional service contractors to manage all spills associated with our operations. Our Contractor Environmental Handbook describes our formal spill prevention and mitigation expectations, including guidance on utilizing and maintaining secondary containment to prevent spills, regularly inspecting equipment, reporting all spills to our Emergency Dispatch Center and using a spill kit. We also follow up with contractors involved in a spill to better understand the incident and discuss our expectations. During quarterly meetings with EQT contractors, we provide examples of real-life incidents to help prevent future spills.
How We Are Doing
We continually work to improve our process for managing spills. Members of our EHS team perform proactive environmental inspections and hazard hunts on all of our well sites on a periodic basis. Our EHS team performed 1,440 proactive environmental inspections and 789 proactive hazard hunts in 2019. We also implemented a new process to enhance our response to spills by creating a dedicated spill report in our digital work environment to notify appropriate personnel of a spill. Our professional remediation contractors also have access to the report, enabling them to upload status updates and appropriate documentation into one centralized system. This process allows for more cohesive tracking and reporting of spills.
We also host a quarterly roundtable to discuss a broad set of topics, including spill performance. We invite our peers in the Marcellus Basin to participate in the roundtable events, which allows us to discuss key topics such as equipment failures and process improvements.
In 2019, while our number of spills remained roughly in line with 2018, spills in excess of one barrel decreased by over 50%. A majority of the spills were unintended releases of produced water, most of which occurred as a result of either equipment failure (e.g., frozen lines, tank arm failures and corrosion) or behavioral issues (e.g., preventable water truck accidents, not following proper procedures and communication issues). We took prompt action to remediate these spills as needed and, to address spills due to behavioral issues, we met with employees and contractors to discuss recent spills and provided additional training. For two spills that met our significance standard in classification, we performed root cause analyses that resulted in the implementation of new company-wide procedures and installation of new equipment to prevent future releases.
We do not operate in the Arctic and, therefore, no spills impacted the Arctic or shorelines with Environmentally Sensitive Index (ESI) rankings 8-10.
Reportable Spills Resulting in a Release1
Hydrocarbon release >1 BBL (1 BOE)
Nonhydrocarbon releases >1BBL (1 BOE)
Total spills resulting in release >1BBL (1 BOE)
|Total hydrocarbon spills||26||179.60||13||67.95|
|Total non-hydrocarbon spills||37||235.84||57||131.35|
|TOTAL SPILLS RESULTING IN RELEASE||63||415.44||70||199.30|
1 Includes reportable spills and volumes outside containment; this volume excludes a 15,000 bbl municipal water spill released from a water source that is not among our assets. The Department of Environmental Protection absolved EQT of any wrong-doing in connection with such spill (OSR-16422). 2019 data excludes 600 bbl of a spill that that was contained, but includes the remaining amount that was released.