Copyright 2004, Society of Petroleum Engineers Inc. This paper was prepared for presentation at The Seventh SPE International Conference on Health, Safety, and Environment in Oil and Gas Exploration and Production held in Calgary, Alberta, Canada, 29–31 March 2004. This paper was selected for presentation by a SPE Program Committee following review of information contained in a proposal submitted by the author(s). Contents of the paper, as presented, have not been reviewed by the Society of Petroleum Engineers and are subject to correction by the author(s). The material, as presented, does not necessarily reflect any position of the Society of Petroleum Engineers, its officers, or members. Papers presented at SPE meetings are subject to publication review by Editorial Committees of the Society of Petroleum Engineers. Electronic reproduction, distribution, or storage of any part of this paper for commercial purposes without the written consent of the Society of Petroleum Engineers is prohibited. Permission to reproduce in print is restricted to a proposal of not more than 300 words; illustrations may not be copied. The proposal must contain conspicuous acknowledgment of where and by whom the paper was presented. Write Librarian, SPE, P.O. Box 833836, Richardson, TX 75083-3836, U.S.A., fax 01-972-952-9435.

Every year oil and gas fields play out their useful economic life. Once production ceases, the facilities are often suspended awaiting their ultimate fate. In this time lag, until the sites are decommissioned and remediated, much will deteriorate. Also, during this period, infrastructure in remote regions often departs south, leaving the environmental project with a wide range of challenges that are not encountered in less remote areas. Any decommissioning project can have many safety hazards. In a remote project, these hazards are magnified because of the difficulty in getting resources or emergency aid. For example, the discovery of asbestos can endanger unprepared workers; it can delay the project while qualified contractors are retained and it will increase costs. For a remote site, the solution is to plan, plan and plan for both the expected and a contingency plan for the unexpected. The first step in planning the project is to complete a hazard assessment. Hazard Assessment Identification of the site hazards is the critical first step in developing the safety plan. A site visit is usually the only way to determine the hazards. The site visit should always be conducted in summer, as many features and hazards are hidden during the winter, when the work will typically be completed. In today’s era of computer aided drawings, it seems unlikely that there could be no drawings or other records of the site, but facilities that were built in the 50’s, 60’s and 70’s may only have the most rudimentary written documentation. Therefore,

during the site visit it is imperative to photograph and inventory everything of significance to allow for proper planning. A typical hazard analysis is shown in Table 1. Identify Scope of Project With any project, it is important to define the project goals. The project plan and safety plan can then be written to support the goals. The scope of remedial projects can typically include: • Environmental assessment • Facility decommissioning • Soil remediation In the Canadian and American north the decommissioning project is more likely to occur in the winter because of the need for winter roads. Facility decommissioning and environmental assessments are easily achievable in winter with a good logistics and safety plan. Remediation is more difficult and is not always possible in cold weather. If heavy equipment is needed for remediation, you may be required to mobilize the equipment in winter to be left there until summer. Regulatory Requirements It is important to review regulatory requirements while writing the safety plan. Simple things like First Aid training and Medic qualification are different for each of Alberta, British Columbia, NWT and Alaska. Workers should have the training and support required by each jurisdiction. The approach advocated here does not address regulations, but provides a management framework to address compliance.

Fort Nelson Fort Nelson is located 142 kilometers from the 60th parallel. The author coordinated the decommissioning of three central gas dehydrator facilities and a salt spill site that was located a further 135 kilometers away. The last 40 kilometers of road is simply frozen seismic lines cleared of snow. The safety plans discussed here were developed the hard way as various issues arose during the projects including the author getting lost en route to a site.

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Safety in Decommissioning and Remediation of Remote Sites Timothy R. Taylor / Petro-Canada

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Table 1: Hazard Analysis

Decommissioning and Remediation Hazard Analysis Location: ________________________________ Date ____________ Construction Date: _________________ Hazard Class Type

Field Results Special

Equipment Training (Alberta)

Service Sour or Sweet Gas Monitor H2S Alive Gas Liquids (condensate, crude) Spill kits WHMIS Climate Season for project to be completed Winter clothing Average precipitation Average temperature Access Year round access available Winter road required Airstrip or helipad available Fuel cache Flying time to nearest serviced airstrip Distance to nearest hospital Maps GPS Cell phone coverage Satellite Phone Site size Hand held radio Chemical Hazards

Asbestos Specialized workers

Naturally Occurring Radioactive Materials (NORM)

Surveillance Meter

Specialized workers

PCBs (Was the facility built before 1975?) Used oils Chemicals Sample bottles Odour potentials Onsite Lab / lab chemicals Lab Pack Site Weeds Energy Are pipes blinded Vessels degassed Steam truck Electrical power shut off Fuel gas Wastes Hazardous wastes? TDG How was domestic waste handled? Closest appropriate landfill Is incineration allowed On-Site Storage Underground storage tanks Ground

Disturbance Above ground tanks Waste Barrels Inventory. Can contents be

identified? Are barrels sound? Oversize barrels

State of suspension

Are there wells associated with the facility and were they suspended properly?

Were piping and vessels gas free and a corrosion inhibitor used?

Various blind sizes

Wildlife Are there any hazards or sensitivities? Bear activity Pepper spray,

bear bangers, air horns

Bear Avoidance

Camps Was there an on-site camp Evidence of hantavirus or rodents Respirators Other animals in residence

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Developing A Safety Plan Safety plans for decommissioning and remediation of remote sites are different from those at sites near services because of the need for self-sufficiency. A good plan can only be developed from a sound hazard analysis. Some key considerations for the safety plan include:

Access Access should be planned carefully to allow workers and equipment to reach the site in a safe and secure manner. In the event of an emergency you must be able to access or obtain support. The safety plan should have: • Maps. Is a clear map available to all workers who will

access the site? It is important to have a map and instructions drawn up and distributed at the kick-off meeting. The use of GPS units should be encouraged. Specialized software programs currently enable the use of moving map technology on laptops and handheld units.

• Check-ins. When workers are scheduled to be in-transit a check-in system should be used to ensure they reach their destinations. Tracking services may be available commercially.

• Snow clearing services should be reliable and timely. Ensure the contractor has the equipment and knowledge to perform the work safely.

• Emergency rescues. Identify who is responsible for these tasks and get their contact information.

• Preparation for transportation, treatment and extraction of injured workers. If the hospital is nearby, field first aid skills are less critical as ambulances can reach the site. If the site is remote, special consideration for first aid, medic skills and equipment is required.

• Contingency transportation in event of an emergency. A helipad should be considered if emergency rescue is to be by air.

Communications The project will need to have adequate communication that is tested and functional. In populated areas cell phone use is taken for granted. Remote sites may not have this luxury. The communication plan will allow workers to communicate with each other, emergency services, support services and the home office. Communication services can include: • Radio. Inexpensive handheld radios can allow workers to

communicate effectively on-site up to three kilometres. Boosted sets can allow further distances and are ideal for longer projects, but are more expensive to set-up.

• Cell phones. Ideally suited because of their low cost and mass availability. Coverage can be quite surprising – the Mackenzie Delta in the Canadian Northwest Territories has quite good coverage! Bag cell phones, although less common, do have a greater range.

• E-mail. E-mail can be achieved using cell technology, but it is slow. Consideration should be given to using dedicated IDs where attachments are not permitted. The attachments can make a system non-functional because of slow speed.

• Satellite handheld phones. If cell phones do not work, a satellite phone will usually work. Ensure workers know how to use them, as they often have complicated dialing codes. Their disadvantages include cost and a conversational time delay.

• Satellite dish systems. These are the most expensive communication systems, but can handle data and voice connections.

Transportation The safety plan must address how workers and equipment will reach the site safely. Check-in points and satellite tracking systems should be considered. Vehicles going to the site must be capable of reaching it safely. Four wheel drive vehicles can help but are no guarantee of safety. All trucks should have: • Winter survival gear • Appropriate tires • Chains if appropriate • Communications device • Recent mechanical check • Handheld Global Position System (GPS) unit • First aid kit Many jurisdictions have specific legal requirements for the first aid kit depending on the task and size of the crew. Fuel should be available at the project site for emergency re-fueling. Signs are also useful to help drivers confirm they are on the right roads.

Weather In the north, winter can be a dangerous time. It is important to have reliable weather forecasts and should be a part of the trip planning. Forecasts should be reviewed as part of the daily tailgate meeting. It is important to remember that in a blizzard, even short distances can be extremely hazardous for travel. Contingency plans must be made to accommodate workers in case of a decision to not travel. The contingency plan should include provision for shelter, food and water and boredom. The lack of any of these will sometimes drive people to take additional risks.

Daylight Hours With a decommissioning or remediation project occurring in the winter it is important to understand the hours of work and the hours of light. If light is not long enough or even available, consider generators and lights. However, powered

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light has some distinct limitations because of shadows and may require task planning or seasonal planning. For example February or March may be better to work in than December. If workers are not familiar with the daylight hours, consider including a discussion in the kick-off meeting. 24-hours of darkness can be quite disconcerting!

Shelter Poor accommodations can present a safety concern as well as effect productivity. If field staff is worried about how dry or warm they will be at night, how can they concentrate on their work? Remote sites generally have no convenient hotel, so workers typically reside in work camps. The safety plan should ensure that the camps have: • Adequate capacity. Workers should have as much

consistency as possible in accommodation • Recent health and safety inspection • Emergency plan • Water and sewage systems that meet regulations • Good meals

Waste Management Plan Decommissioned equipment needs to be flushed and cleaned of all hazardous materials. The hazardous material must then be treated and disposed of. In winter where access is by ice road or aerial access, hazardous waste disposal can be dangerous and expensive. A waste management plan is important to ensure waste is disposed safely and efficiently. The plan should identify each type of waste likely to be encountered during the project and should also include: • Storage requirements • Transportation of Dangerous Goods classifications • Manifest requirements • Treatment/disposal options • Transportation requirements • Waste contractors The plan should be developed in consultation with both local regulations and the regulations of the provinces or states through which the waste will be transported and disposed. If there was a camp on-site requiring decommissioning, years of disuse may make it hazardous to human health. On some sites the best solution, if regulations allow, is to have a very large campfire. The ashes will be much safer to clean up.

Decontamination Plan Before work can begin on the actual deconstruction of the

facility, it must be gas and liquid free. The hazard analysis should have identified the state of suspension. With a combination of steam truck and vacuum truck, piping systems should be made gas and liquid free prior to decommissioning. A welder is essential to make secure connections for these services.

Spill Contingency Plan Although most developed oil and gas fields are covered by a mature spill cooperative, remote suspended sites have slightly different needs. Coop equipment is often a long distance away and may not be well suited for the type of small spills that can be expected on a remediation or decommissioning project. Spills are often of fuel, small volumes of chemicals or fluids in piping and vessels. A spill kit is a useful component to the project. The size will vary from a kit bag in the truck to a shipping container of supplies and will depend on the scope of the project. Consideration for the spill kits should include: • Shovels • Absorbent rope for creating barriers • Absorbent pads • Drip trays • Gloves and disposable coveralls • Garbage bags for oily debris • Barrels for recovered materials. These make ideal

containers for the spill equipment. A spill “first aid” sheet is recommended. It should include regulatory contacts, reporting thresholds and a basic spill report form.

Emergency Response After completing the hazard assessment and establishing the management plans, the emergency response plan should be easy to put together. It should establish the contingencies for each potential emergency. There are many standards for writing an emergency plan like the Canadian Standards Association CAN/CSA-Z731-03 Emergency Preparedness and Response. http://www.csa-international.org/default.asp?language=english. Whichever model is chosen, the plan should be easy to follow and ideally written by the project team. The project team including field supervisors and logistics specialists should be familiar with the plan. The need for first aid attendants or medics should be considered in consultation with the regulations. Each jurisdiction has slightly different requirements. One useful addition to the plan is to have a one-page summary of the plan with phone numbers attached to the backside of the site map.

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Workers

Qualifications for workers A decommissioning project will require several different skills that are well understood in the oil and gas industry, like welders and heavy equipment operators. Less well understood, is the need to bring workers with the right attitude for remote work. Their workplace is a long way from home, cold and with few amenities. After work there is little to do. The project team must select workers and contractors used to working in this environment.

Training From the hazard assessment, the project team will be able to predict the training qualifications needed for workers. In addition to the basic training for Transportation of Dangerous Goods (TDG), hazard information systems and first aid, other basic skills may be needed. • Driving is often the most hazardous task – consider the

need for workers to have collision avoidance training and basic cold survival training.

• Often respirators must be used. Workers should be fitted for their masks and understand how to use them.

In the United States, much of this training is included in the U.S Department of Labor Occupational Safety and Health Administration (OSHA) Hazardous Waste Operations and Emergency Response Standard (HAZWOPER) certification. www.osha.gov

Hire locally As part of the field hazard assessment, it is important to determine what resources are available locally. Local resources may be able to help the project team understand: • Site history • Local logistical support availability • Weather impacts • Road conditions Specialists will still be required, especially for tasks like asbestos removal, but the inclusion of local knowledge will greatly increase the chance of success in completing the project on time and safely.

Kick-off Meeting and Tailgate Meetings Tailgate meetings are important to review the daily hazards of the job. The difference in a remote site is where they are held. If held outside in the cold, workers attention can drift. The meetings should be held in a protected area, like the dining area of camp.

Include in the meeting: • Review of on-site hazards • Ground disturbance procedures • Weather and temperature • Muster points • Emergency procedures • Review of unusual or critical tasks • Road conditions The meeting should be documented and all on-site workers should be signed in. Personal Protective Equipment Working in the cold can be very hazardous. It is important to ensure that anyone going to the site, even visitors, bring warm clothing. Fire retardant outer clothing is still recommended, as there are many flammable hazards in a suspended oil and gas facility. Standard protective equipment issued in the south may not work well in the winter. For example safety goggles or face shields will rapidly fog up creating a greater hazard than they protect. Use common sense in developing the site policy. When selecting other equipment like gas detectors, make sure they will work in the cold or make sure they can be warmed up regularly. Project Logistics Most winter projects have additional timing difficulties. Where access can only be made using ice roads, the project must wait until the roads are ready and it must be complete before break-up. Winter storms can quickly delay a project as they can stop all work. The ability to get needed equipment and workers to the site on time is therefore much greater. Safety equipment must arrive with the workers. Consider using a logistics specialist to support the plan during the field component. The specialist will have the ability to get supplies and equipment to the site quickly and safely and will likely save you money. When choosing expert help, make sure that the skills match the task.

Documentation As the site is being decommissioned and remediated, progress should be carefully documented. The documentation should include: • Line location drawings for underground utilities • Tailgate meetings • Spill and event reports

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• Waste manifests for all wastes removed from the site • Time sheets • Photographs are exceptionally helpful in documenting

work progress Conclusion Decommissioning and remediation projects of remote sites require significant planning, including a detailed safety plan. Attention to detail will lead to a safer work environment. Acknowledgements The author wishes to acknowledge all who have reviewed and commented on this paper and in particular special acknowledgement to Dean Wall and Caroll Taylor for their challenge and encouragement to finish this paper.