According to the National Centers for Environmental Information, 50,015 wildfires have burned approximately 2,539,627 acres of land in the United States. A wildfire is classified as a fire that burns out of control in a natural area. Wildfires may begin sporadically and spread quickly, and can result in catastrophic losses to homes, lives, and communities.
Often overlooked are the impacts wildfires can have on oil and gas operations. Active oil and gas fields may contain highly flammable substances, which can increase the spread or severity of a wildfire. The potential for wildfires to cause severe damage underscores the need for stringent fire safety protocols.
Should a fire approach an area with active oil and gas operations, steps can be taken in advance to prepare for this event and to recover from potential impacts to the facility.
This article provides guidance based on various resources and is not intended to replace existing local, state, and federal laws and regulations. In preparation for and prevention of a wildfire, oil and gas operators and owners in all areas should:
1. Regularly inspect your systems and facilities to ensure orderly operation.
Prevention begins before the threat of a wildfire exists. Be prepared for the threat of a wildfire by ensuring that the facility is operating according to industry and construction standards as well as local fire codes. Proper maintenance will ensure safety equipment will respond as designed during an emergency. Be proactive in ensuring the site is fire safe.
2. Stay informed by educating yourself on the risk of wildfires in your area.
Although wildfires can occur at any time of the year, the potential for wildfires is always greater when there is little to no rainfall combined with high winds. There are resources available which aid in the understanding of the potential risk for wildfires. For example, the U.S. Drought Monitor provides weekly updates regarding the status of drought. It can also be extremely useful in assessing conditions which may be conducive to wildfire. Stay advised of the latest reports on the location and status of active fires in relation to active sites and be ready to take action if wildfires are burning near a facility.
Additionally, the National Weather Service may issue a “Red Flag Warning” which indicates that warm temperatures, very low humidity, and stronger winds are expected to combine to produce a heightened risk of fire danger. The combination of these conditions results in an increased risk for a wildfire or rapid-fire growth if an incident were to occur.
During a “Red Flag Warning,” it is important to follow local fire codes, extinguish any fires properly by drowning flames with water, and maintain caution when operating any equipment which could pose a potential fire threat.
On the other hand, “Fire Weather Watches” are issued by the National Weather Service to alert the public to a possible development of red flag conditions, usually within one to three days before a forecasted weather event. Although “Fire Weather Watches” and “Red Flag Warnings” are advisories issued by the National Weather Service to alert the public of weather conditions conducive to fires, a “Red Flag Warning” means that the threat is more severe.
A “Fire Weather Watch” may eventually evolve into a “Red Flag Warning” by the National Weather Service when the necessary weather conditions rise to the level of serious urgency. Pay attention to “Fire Weather Watches” and “Red Flag Warnings” affecting operational areas, as these alerts are indicative of the potential for an increased risk for wildfires.
3. Develop an emergency plan that specifically addresses wildfire protocol.
Just as in any emergency, the actions taken in the first few moments of a wildfire are usually critical, especially in the oil and gas industry, where fires can quickly spread and consume entire facilities. Thus, it is imperative to have a plan in place to respond quickly and calculated in the event of a wildfire.
4. Prioritize personal safety.
Ensure the safe evacuation of all on-site employees when necessary. Communicate with all employees regarding potential threats and safety hazards.
5. Take action to secure the premises and make post-fire recovery easier.
If deemed safe and practical, take all appropriate steps to prevent fires from coming into contact with active wells, flowlines, pipelines, storage tanks, and gathering lines. For example, in 2011, the Louisiana Department of Natural Resources’ Commissioner of Conservation issued an advisory to Louisiana oil and gas operators whose facilities were directly threatened by wildfires to remove crude oil or condensate from storage tanks or shut-in wells, production facilities, flowlines, or pipelines.
Remove combustibles and unnecessary items from the area and ensure all emergency mechanisms are functioning. Contain any spilled liquids, if possible, to prevent the spread of the fire.
6. Be knowledgeable of local and federal laws.
States may have their own set of laws and regulations governing fire safety for oil and gas operations. In some states, regulations require that combustible vegetation, trash, and debris should always be kept at least 100 feet away from oil and gas equipment such as wellheads, production equipment, storage tanks, and other exploration and production site structures.
States may issue state-wide or parish/county-wide burn bans when state and local authorities determine environmental conditions conducive to the rapid spread and growth of wildfires are present. It is important to be aware of and in compliance with existing federal or state laws and regulations to avoid liability for potential violations and to avoid contributing to the spread of wildfires.
7. Secure any storage tanks.
In September of 2021, the US Environmental Protection Agency (EPA) released a guide to use as a resource in the event of a wildfire for underground storage tank (UST) and oil aboveground storage tank (AST) owners and operators. The goal of the guide is to aid in the prevention of environmental harm that may result when a wildfire reaches UST systems or oil ASTs and associated equipment. Although specific to AST and UST owners and operators, the guide contains useful information that can be applicable to all equipment located in active oil and gas operation sites.
The EPA urges the importance of knowing and using key safety features, such as the emergency stop switch or emergency shut-off, which is required by national fire codes. Sheer valves are also an important safety mechanism which can protect against the risk of impact on the fuel dispenser. When sheer valves are tripped, piping will become capped at two points and will limit the potential of the fuel feeding the fire. Some sheer valves are manufactured to trip in the event of a fire while others must be manually tripped. Regardless, when leaving a UST facility during a wildfire, ensure that the fuel valves are tripped to prevent the fuel from intensifying the fire. It is important to take inventory by checking the level of fuel in the tanks regularly, as this is the most effective way to know if there has been a release of product from an UST.
Specifically, the EPA advises UST facility owners to develop a contingency plan, which includes, but is not limited to:
- A facility diagram which identifies all UST locations and remediation systems
- Emergency contacts
- Facility geospatial data
- Checklist and inventory of items necessary to maintain a minimum level of service after wildfire
- List of UST contactors, UST testers, and money available for facility restoration
- UST fire preparation and facility restoration checklists
The EPA urges AST facility owners to confirm that the AST system is designed, installed, and operated according to industry and construction standards and local fire codes. The EPA also advises that when a fire approaches an AST facility, facility owners should attempt to record tank inventory before shutting the system down and shut down the tank system using the emergency shutdown system. If possible, isolate the system electrical components, which is completed by turning off the power to the system at the facility circuit panel by turning the power off at the circuit breaks.
8. Practice a safe and productive re-entrance.
Based on the severity of the wildfire, it may be a long period of time before you receive permission to re-enter the field. Ensure that the field is safe prior to re-entering the field by communicating with local fire departments. Once deemed safe to re-enter, begin by securing the premises. Install signs that convey that the facility is closed if necessary. Conduct an inventory assessment and document damaged equipment.
9. Report any spills or hazardous discharges to the appropriate authority.
Oil and gas operators should report any releases or discharges to applicable federal, state, local, or tribal regulatory authorities. Per the EPA, the person or organization responsible for a release or spill is required to notify the federal government when the amount reaches a federally-determined limit. There are separate reporting requirements for oil spills and hazardous substance releases. States may also have separate reporting requirements. The National Response Center is the designated federal point of contact for reporting the discharges into the environment and can be reached at (800) 424-8802.
10. Be aware of potential post-wildfire effects.
Wildfires can cause immediate and long-term issues. Following severe wildfires, the soil may be burned to the point that it is unable to absorb water. This increases the chance of flash floods or mudflows in certain areas. It is important to understand that depending on the location of the facility and the precipitation the area receives after a wildfire, the facility may be subject to developing debris flow fields, which can be dangerous and destructive to oil and gas operations.
Conclusion
Because wildfires can have severe and lasting effects on the affected land and communities, it is vital that all oil and gas operations are conducted with an emphasis on wildfire safety and prevention, especially in areas in which wildfires pose a significant threat.
There are many accessible resources which can assist in predicting conditions which are conducive to the threat of wildfire. Thus, oil and gas operators must remain cognizant of weather conditions and potential contributing factors in the operational area to ensure proper preparedness and prevention of wildfires. Being prepared by having an emergency plan, knowing and complying with state and federal laws and regulations, and securing the operational area in advance of the threat of wildfires is the best way to mitigate risks resulting from natural disasters such as wildfires.
Authors: John C. Funderburk and Sydney J. St. Pierre (Kean Miller LLP)
