Whiting is deeply committed to protecting the environment as we safely and responsibly develop our resources. At all levels within our company, Whiting continuously takes measures to prevent and minimize the environmental impact of our operations. We are also seeking new and innovative ways to reduce pollutant and greenhouse gas emissions, reduce the company’s carbon footprint and properly manage waste.
Responsible Water Use
We understand and respect water as a limited natural resource, and we are committed to responsible water use. We recognize that our water use affects neighboring communities, governments, businesses, and industries, and we are dedicated to responsible, effective water use practices in the development of energy resources. We use only the volume of fresh water necessary and source fresh water from nearby water sources. Where possible, we utilize pipelines to transport fresh water from its source to the usage point, eliminating haul truck use and the associated emissions and road traffic. As water sources and needs necessarily differ across our varying operations, the following describes our commitment to responsible water use in our shale play hydraulic fracturing (fracking) operations.
In furtherance of our commitment to responsible water use, we have developed a Water Strategies Committee tasked with routinely identifying means to promote increased water efficiency, evaluating water resources less impactful to neighboring communities, and investigating the viability of water recycling technology. The Committee is developing key metrics by which progress in furthering these goals may be measured. In addition, we have partnered with industry members in the Energy Water Initiative to study, describe, and improve life cycle water use and management. These efforts help us evaluate and reduce our impact to neighboring communities and the environment.
Bakken Shale Play
In our Bakken shale play, fresh water needs are met by a variety of surface and groundwater sources. We seek out fresh water from closely-located sources, and by using closely-sourced water, we reduce the truck miles traveled and associated truck emissions per gallon of fresh water used. In addition, we mitigate fresh water use by substituting recycled produced water for fresh water, where possible, and the Water Strategies Committee is exploring expansion of produced water recycling. The table below provides fresh and produced water usage metrics.
Water Volumes Used in Northern Rockies Well Completion Operations
DJ Basin Shale Play
In our Denver-Julesburg Basin shale play, limited surface water availability dictates that fresh water needs are met primarily by private, non-tributary groundwater sources in Weld County. All fresh water is transported via pipeline to its end-use point, which has eliminated approximately 28,000 water haul truck trips and associated air emissions and traffic. Our transporting of water by pipeline is estimated to reduce approximately 2,455 and 15 tons of greenhouse gas and nitrogen oxide emissions, respectively, each year.
Water Volumes Used in DJ Basin Well Completion Operations
Drilling and Completions Fluids
In our drilling operations, we utilize drilling fluids consistent with standard industry practice to minimize environmental impact and optimize well control. Where possible, we employ water-based drilling mud systems, which utilize biodegradable vegetable oils. Drill cuttings from these water-based mud system operations are separated from the drilling fluids and treated on location or properly disposed in compliance with applicable laws and regulations. This on-location treatment eliminates the need to dispose of drill cuttings in landfills, reducing our environmental impact and eliminating air emissions associated with truck hauling to landfills. Drilling fluids are transported and re-used on the next drilling location.
Hydraulic fracturing completions require the use of water, sand, and chemical additives. Typically, more than 99 percent of the completion fluids are sand and water. The remainder is a blend of chemical additives that are often common household products. We do not use diesel in our completion fluids.
Through our service providers, we utilize a number of dry chemicals in our Bakken and DJ Basin completion operations. The use of dry chemicals increases transportation efficiency and aids in ease of clean-up in the event of a spill. Our Water Strategies Committee is tasked with evaluating the use of dry chemicals in additional completion operations.
We are dedicated to disclosing the chemicals used in our completion fluids in an effort to promote trust, which we believe is essential to the continued progress of energy development. We provide a Hydraulic Fracturing Fluid Product Component Information Disclosure Report for each of our wells. More than 1,700 of our reports may be found on the FracFocus website. In addition to the operator and the fluid content, each filing identifies the API number, job start and end dates, state, county, and well name.
We work with all of our vendors in order to report fluids used in hydraulic fracturing to FracFocus. As a producer, we are required by state and federal law to keep Material Safety Data Sheets (MSDS), which are prepared and provided by our vendors. The MSDS describes the components of a given hydraulic fracturing fluid by well location. OSHA regulations govern the content of the MSDS and establish the criteria for the disclosure of this information including protecting “trade secret” and “confidential” business information. We provide the information included in the applicable MSDS to FracFocus, but we are not permitted by law to disclose hydraulic fracturing fluid components used by our vendors that are protected as “trade secret” or “confidential.”
Drilling Residuals Management
We are committed to responsible drilling residual management and reduction. 100 percent of our drilling rigs utilize a closed loop system. We send drilling waste to disposal facilities that are compliant with applicable laws and regulations. To ensure the disposal facilities that we utilize meet our standards, we perform independent audits of the following standards.
- Compliance with applicable state and federal permits, laws, and regulations
- Implementation of environmental, health, and safety programs meeting our standards
- Possession of adequate liability insurance
- Maintenance of sound facility structural integrity
We believe this added precaution ensures our drilling residuals are disposed of responsibly and minimizes any adverse environmental impact.
Where possible, drill cuttings are treated on location in compliance with applicable laws and regulations. This on-location treatment eliminates the need to dispose of drill cuttings in landfills, reducing our environmental impact and eliminating air emissions associated with truck hauling to landfills.
GAS GATHERING AND PROCESSING
Whiting has made significant investments in natural gas gathering and processing infrastructure to maximize natural resource recovery and minimize natural resource waste. It is Whiting’s policy to capture and market natural gas resources wherever feasible.
Whiting has constructed and now operates 4 natural gas processing plants and the associated gas gathering lines. This has given Whiting the ability to process its own natural gas for distribution to the consumer market that could otherwise be flared. In areas where Whiting has not established gas gathering and processing plants, it is our practice to look for other opportunities to send produced natural gas to market. An example is the 20” pipeline that Whiting built from the Tarpon area to a third party compressor station in North Dakota. This further increased Whiting’s gas capture rate, which set the curve for the state’s new flaring standard. By maximizing its marketing of natural gas, Whiting reduces potential emissions.
We are committed to reducing air emissions and minimizing our impact to communities and the environment. We do so by complying with air quality laws and regulations and going beyond baseline compliance in a number of ways. At this time, we reduce emissions by implementing emissions reducing programs and by utilizing emissions-efficient technology, as described below. Each of the following reduces VOC emissions, and where we eliminate or reduce combustion sources, both VOC and NOx reductions are realized.
We are committed to reducing flaring and have constructed gathering systems and natural gas processing plants in our Bakken and Denver-Julesburg Basin (DJ Basin) shale play operations. These facilities have provided an essential gas market in remote areas that allows us and other operators to sell natural gas rather than flare it. We also complete our wells using green completion techniques that minimize flaring by routing natural gas to available pipelines. Additionally, North Dakota has statewide flaring limitations and we have reduced our flaring below such limits for each required flaring reduction.
Where possible, we utilize dual-fuel technology that reduces air emissions during our drilling and completion operations, and we utilize more efficient natural gas to power operations where electricity is unavailable. In 2016, our commitment to efficient fuels allowed us to substitute locally-sourced natural gas for approximately 207,000 barrels of diesel in our DJ Basin shale play. In addition to the fuel being more efficient, this natural gas utilization project has eliminated approximately 1,160 diesel hauling truck trips, associated road traffic, and an estimated 357 tons of greenhouse gas.
Eliminating Truck Trips
We believe in reducing our reliance on truck transportation and utilize pipelines to transport fluids wherever feasible. Pipeline transportation eliminates the need to utilize hauling trucks, resulting in reduced air emissions and truck traffic. In 2016, our commitment has resulted in a reduction of approximately 201,000 truck trips from our Bakken Basin shale play and approximately 88,000 truck trips from our DJ Basin shale play.
We investigate the feasibility of using instrument air-driven pneumatic controllers for each project in our Bakken and DJ Basin shale plays, and we have incorporated this technology into many of our facilities. Air-driven pneumatic controllers reduce emissions by utilizing compressed air, rather than natural gas, to operate control valves. Where instrument air is not available and the process and conditions allow, we utilize low-bleed controllers.
Alternative Energy Sources
We are committed to reducing emissions by utilizing electricity to power our operations where possible. For each operation, we evaluate the technical feasibility of utilizing electrically-driven equipment and choose such equipment when conditions allow. For example, we use solar electric pumps where possible and electric motors, rather than gas-driven engines, across many of our operations.
GREENHOUSE GAS REPORTING
We are committed to minimizing methane leaks across our operations and do so by regularly inspecting our facilities at frequencies that meet or exceed regulatory standards and expeditiously repairing discovered leaks. In our Bakken and DJ Basin shale play assets, we employ trained inspection teams tasked with inspecting facilities for leaks and ensuring leaks are expeditiously repaired. These inspection teams are equipped with, and trained to effectively use, forward-looking infrared (FLIR) camera technology. In the DJ Basin, inspection teams conduct audio, visual, and olfactory (AVO) inspections at least every week and FLIR camera inspections at least every other week. In the Bakken, inspection teams conduct AVO and FLIR inspections at least monthly. In addition to our dedicated inspection teams, we train field employees to spot and repair leaks during daily rounds.
Due to the success of our inspection programs, at this time no tool exists to measure limited, occasional leaks. Industry recently has partnered with research and environmental groups to better understand and quantify oil and gas production methane leaks. As such, we estimate emissions of greenhouse gases (GHG) in accordance with the requirements of EPA’s Mandatory Greenhouse Gas Reporting rule (40 CFR Part 98). As part of this program, we measure, where possible, or estimate emissions of methane, carbon dioxide, and nitrous oxide for multiple emission source types in the production, gathering and boosting, processing, and transmission industry sectors, where applicable. These emissions are reported to EPA annually for each calendar year, and reports are made publically available on EPA’s webpage at www.epa.gov/ghgreporting. For basins or facilities for which we are required to report, we estimate and report equipment leak emissions using EPA’s emission factors that assume constant leak rates per equipment type and that do not account for the inspection and repair programs we have implemented. Therefore, we believe this method likely overestimates our actual equipment leak emissions. Using the estimated equipment leak emissions provided to EPA, the table below presents estimated equipment leak methane emissions as a percentage of the total natural gas produced in 2015 for our Bakken and Denver-Julesburg shale play assets.
Calendar Year 2015 Estimated Methane Emissions from Equipment Leaks
REDUCED EMISSIONS COMPLETIONS
Ahead of the recently published Federal regulations, Whiting began implementing practices where drilling and workover operations would utilize techniques aimed at reducing greenhouse gases. The use of these techniques has greatly reduced Whiting’s carbon footprint, pollutant and greenhouse gas emissions and natural gas flaring during completions and workovers. At Whiting, we are committed to protecting the environment.
LOW-EMITTING PNEUMATIC DEVICES
Ahead of the recently published Federal regulations, Whiting enacted a policy whereby all newly installed natural gas-driven pneumatic devices must be low-emitting, except where safety or operational conditions require a higher-emitting device. At facilities where compressed air is available, Whiting has begun using air actuated controllers. Whiting believes such a policy greatly reduces its carbon footprint, pollutant and greenhouse gas emissions and conserves valuable natural resources.
LEAK DETECTION INSPECTIONS
We believe in capturing available natural gas and have implemented leak detection and repair programs to minimize natural gas leaks in our Bakken and DJ Basin shale play operations. Our trained operators and staff routinely seek out and expeditiously repair leaks. As part of these efforts, our staff utilizes forward-looking infrared (FLIR) camera technology across all our operations. We have been leaders in our utilization of FLIR camera technology, which began in 2010 and well ahead of regulations requiring FLIR camera inspections.
FACILITY INSPECTIONS AND MAINTENANCE
In addition to FLIR inspections, Whiting personnel routinely inspect facilities in an effort to identify potential emission and liquid leak sources, along with sediment discharge due to stormwater. Through inspection, Whiting is better able to anticipate equipment and BMP failure and to identify and repair equipment when leaks or discharges do occur.
Whiting has developed a robust routine maintenance program to track and trend all maintenance concerns to closure, giving Whiting the clarity to target reoccurring maintenance issues and enhance equipment reliability. The end result of periodic inspections and more reliable equipment is increased capture of natural gas and oil, reduced generation of air pollutants and enhanced prevention of damaging product or sediment releases. This practice also realizes an increased retention of land mass and protection of the environment surrounding our operations.
SPILL PREVENTION AND RESPONSE
Whiting has developed a robust Spill Prevention, Control and Countermeasure (SPCC) Plan that provides personnel with the tools they need to efficiently and effectively prevent releases and respond to them if they occur. Strategically located spill response trailers throughout our drilling and production areas offer quick response time to Whiting assets. Peer benchmarking studies show that Whiting is consistently below the industry average for spills.
Whiting also prepares for potential incidents through rigorous emergency response training and an Incident Command System. In addition, several individual programs exist to review and update all emergency response plans and processes as necessary.
Whiting is also one of the original members of the Sakakawea Area Spill Response, LLC (SASR). It is a company composed of 13 oil, gas and pipeline operators in the upper Missouri River and Lake Sakakawea region. SASR members have agreed to share resources and purchase and maintain equipment in order to respond quickly and comprehensively to an open water spill. The goal is to minimize impacts to the area and protect local residents and the environment. Part of Whiting’s reputation as a clean and responsible operator can be attributed to these practices and prevention efforts.
To limit risk and liability in the handling and disposal of waste, Whiting has taken active steps to build a waste management program. Waste Management Plans are in place for all operational areas, providing guidance to Whiting personnel and contractors on the proper handling, management and disposal of waste. An approved waste vendor program is also in place to ensure that waste vendors, such as landfills and saltwater disposals, can legally accept and are knowledgeable about how to properly dispose of Whiting’s waste.
We are committed to responsibly managing the hazards associated with naturally occurring radioactive materials (NORM) and maintain a Certified Industrial Hygienist and Radiation Safety Officer on staff that supports all NORM-related activities involving risk of exposure to employees and contractors. We have also developed practices which characterize NORM exposure risks and prescribe multiple layers of control to reduce the potential for NORM exposure to employees and contractors. In addition, we provide periodic NORM awareness and NORM surveyor trainings to our employees.
To identify and manage NORM hazards, we conduct initial and follow-up NORM assessments of our facilities. When NORM hazards are identified, we focus first on engineering controls and preventive maintenance and then on administrative controls and personal protective equipment. Each Whiting production office maintains radiation detection equipment used by trained personnel to perform NORM surveys on equipment in our process streams and on used equipment/piping slated for sale or disposal.
Lastly, where a remediation project involves regulated concentrations of NORM, we place significant importance on using contract companies that hold a specific license to perform NORM remediation.
Whiting understands that being a responsible operator is more than reducing air emissions or preventing spills. It is because of this that Whiting has developed an informational program to communicate the importance of being aware of the flora and fauna in the areas in which we operate. Informational brochures, complete with identification pictures, are distributed on an annual basis to personnel, contractors and field offices to help those working at Whiting locations identify threatened or endangered species. Colorado Wildlife and North Dakota Wildlife brochures can be found below. Guidance on how to avoid sensitive areas is also vital to ensuring Whiting’s disturbance is minimal to the wildlife around us.
Colorado Wildlife Brochure
COMPLIANCE AND AUDITING
Whiting builds compliance programs for health, safety and environmental laws and regulations, along with internal standards by identifying the applicable requirements and putting practices in place to meet them. A central environmental database, integrated with several other Whiting systems, is the core of our compliance effort. It allows us to more adequately track and trend data, accumulate compliance documentation, and provide more tools to verify compliance across the entire company.
To balance compliance efforts, Whiting has established an aggressive auditing program involving site inspections, desktop compliance reviews, verification through database tracking, reporting and legal counsel. The goal of this auditing program is to assess compliance of our operations and measure the effectiveness of our EH&S management systems.
COMMUNITY EMERGENCY RESPONSE PREPAREDNESS
Natural disasters present risks to our employees, the environment and the communities where we operate. We support groups that are well trained and prepared to respond to emergencies and natural disasters. In September 2013, Whiting donated over $100,000 after floods devastated the communities where our employees live and work throughout Colorado.
REDUCED VEHICULAR EMISSIONS
Where possible, Whiting has pushed to sell product through Lease Automatic Custody Transfer units, or LACTs. This impacts the environment through a drastic reduction in oilfield truck traffic which becomes tangible through a reduction in vehicular emission, noise reduction and road dust. Whiting also encourages all of its Denver employees to use mass transit to reduce vehicular emissions by providing public transit passes at no cost to the employee. Carpooling when in the field and limiting idle time of field vehicles are also encouraged to maximize fuel economy and prevent unnecessary emissions.
Whiting views its contractors as an extension of the company and we take steps to verify our contractors are meeting the Whiting standard. A screening process is completed on all potential contractors to ensure training programs, health and safety policies and work practices meet the criteria set by Whiting. In addition, signage is present at Whiting locations to help reinforce the EH&S expectations and training is offered to align contractors with Whiting’s goal of environmental compliance.
It is clear to Whiting that positive relationships with regulators, the community, peer operators and landowners are critical to operating responsibly. Transparency and honesty are cornerstones of these relationships. We regularly discuss upcoming plans, provide status updates, review regulatory requirements and stay involved in rulemaking processes and maintain a rapport that enhances these working relationships.
We are committed to minimizing our impact to the community and environment. Our two major plays are relatively remote, minimizing any potential adverse community impact. Any complaint received by Whiting is referred to the appropriate department/supervisor and appropriately resolved. We encourage community members to report any potential environmental impacts caused by our activity. To notify Whiting personnel of any observed impact, please email firstname.lastname@example.org, and Whiting personnel will promptly address your concern.
Whiting’s recycling program continues to grow company-wide. An office recycling program is established in the Denver corporate office and field offices have begun to explore recycling programs in their areas. Recycling efforts can even be found throughout field operations with scrap metal recycling containers and Whiting personnel continually looking for available equipment or parts for reuse. These practices all add up to reduce the volume of waste being sent to local landfills.