COMPLYING WITH THE NEW OSHA SILICA STANDARD – OIL AND GAS OPERATIONS AIHA Rocky Mountain Section Fall Technical Conference – Silica Panel – September 20, 2016 Pablo Sosa, CSP
Introduction ► Name: Pablo Sosa ► Occupation: Consultant with Bureau Veritas ► Certification: Certified Safety Professional ► Background: Retired Air Force Veteran. Worked various Health Safety and Environmental roles in Aerospace, Manufacturing, Oil and Gas, and Research and Development labs. Bureau Veritas 2
Overview ► Present a timeline for Oil and Gas Operations from 2011 to 2013 leading up to changes with the Silica Standard. ► Provide Initial Monitoring Data ► Provide Controls Attempted and results ► Provide Engineering Control from Sierra Dust Control which helped achieved compliance. ► All monitoring was done using an aluminum cyclone. The exception is the OSHA monitoring which used a Dorr Oliver. All results were compared against a calculated PEL and the New OSHA Silica PEL of 50 ug/m3. Bureau Veritas 3
Oil and Gas Operations – Prior to New Standard ► Our company anticipated changes to the OSHA Silica Standard and knew that we had to look at exposures and quantify them. ► From 2011 to 2012 we performed monitoring during cementing operations and hydraulic fracturing operations. ► Cementing Operations - Area Air Samples were taken on cement trucks where operators controlled the flow of cement into the batch mixer truck and in the batch mixer area. - Personal air samples were taken on Batch Mixer operator and Cement Truck Operators. Bureau Veritas 4
Oil and Gas Operations – Prior to New Standard ► Hydraulic Fracturing - Area samples were taken on the mountain movers, T-Belt, Blender Hopper, and Sand Castles. - Personal air monitoring was taken on mountain mover operators, T-Belt Operator, Blender Operator, and Employees working in the area around hydraulic fracturing operations. Bureau Veritas 5
Initial Sampling Results ► Initial Sampling Results for Cementing and Hydraulic Fracturing Operations varied. ► Cementing Operations indicated levels above a calculated PEL for Respirable Crystalline Silica for the Batch Mixer Operator. ► Hydraulic Fracturing Operations indicated levels above a calculated PEL for Respirable Crystalline for all employees associated with hydraulic fracturing operations. ► Anticipating changes to the Silica Rule we also knew we would be above the proposed PEL of 50 ug/m3. Bureau Veritas 6
Implementing Controls – Cementing Operations ► Cementing Operations - We knew our sample results showed approximately one to one and half times above a calculated PEL for the Batch Mixer Operator. ► Controls Implemented: Engineering – A water jet was introduced into the configuration of the batch mixer which keep the dust down. PPE – Respirators were required for Batch Mixer until further monitoring conducted. Bureau Veritas 7
Implementing Controls – Cementing Operations ► Air Monitoring was re-accomplished and levels of respirable crystalline silica measured were Non-Detect. ► However, Batch Mixer still used respirator because of caustics in cement additives. ► Monitoring continued to be performed for several cementing operations and various locations throughout the U.S. and showed levels below the calculated PEL and new PEL for respirable crystalline silica. Bureau Veritas 8
Implementing Controls – Hydraulic Fracturing ► Air Monitoring results revealed exposure levels to Silica ranging from 4 to 15 times above the calculated PEL for all operators involved in the fracturing process. ► Initial Controls: Engineering – Company would start looking at options available and begin to explore. PPE – Employees were placed on Respiratory Protection Program and provided respirators. Bureau Veritas 9
Implementing Controls – Hydraulic Fracturing ► In 2013 received citation from OSHA for failure to explore and implement Engineering controls. ► Going forward we tried numerous controls such as: - Automating sand deliver process to the T-Belt using an infrared reading eye. - Result was automatic eye would fail occasionally causing sand to spill and during evening operations eye was difficult to operate because a light source needed to be shined on it. Bureau Veritas 10
Implementing Controls – Hydraulic Fracturing - Powered Air Purifying Respirators were also provided to employees to try. - Result was the difficulty T-Belt Operators had when attempting to observer sand being delivered to the hopper. Additionally, temperature extremes would have an affect on battery life, etc. - Misting systems to wet the sand and keep dust levels down. - Air monitoring results showed the misting system was not effective in reducing silica levels below calculated and proposed OSHA Silica PEL. Additionally, the system requrired cranes to be utilized to put in place. Bureau Veritas 11
Hydraulic Fracturing – Effective Engineering Controls ► After approximately a year of attempting to find an effective engineering control for hydraulic fracturing operations we worked with a contract company to configure dust control for our operations. ► The contract company had a proven track record of dust control operations and was willing to work with our team to solve our problem. Bureau Veritas 12
Hydraulic Fracturing – Engineering Controls ► Sierra Dust Control would work with our team to evaluate hydraulic fracturing operations and develop a solution. These are examples of engineering control implemented. Dust Escaping Mountain Mover Prior to Dust Control Bureau Veritas 13
Hydraulic Fracturing – Engineering Controls Dust Control on Three Movers and Blender Bureau Veritas 14
Hydraulic Fracturing – Engineering Controls Dust Control On Sand Castles Bureau Veritas 15
Hydraulic Fracturing – Engineering Controls Dust Control on T-Belt and Hopper Bureau Veritas 16
Hydraulic Fracturing – Engineering Controls Dust Control on T-Belt and Hopper - Night Operations LED Inside Cover Inside T-Belt Bureau Veritas 17
Hydraulic Fracturing - Results ► Air monitoring was conducted during operations with the controls implemented. New results showed exposure levels below the calculated PEL and proposed OSHA Silica standard. ► OSHA decided to conduct monitoring on our site to see effectiveness of new controls. Bureau Veritas 18
Conclusion ► Engineering controls provided by Sierra Dust Control worked. Air monitoring was conducted for various types of configurations on well pad, environments (i.e. snow), and operations (i.e. Sand Castles versus Mountain Movers). Bureau Veritas 19
Contact Information – Indoor & Outdoor Dust Control ► Sierra Dust Control – Booth At Conference or 303-655-8633 www.sierrafracsand.comwww.sierrafracsand.com Bureau Veritas 20
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