permian basin oilfield environmental consulting services
PERMIAN BASIN OILFIELD ENVIRONMENTAL CONSULTING SERVICES STATEMENT OF QUALIFICATIONS Spill Response and Remediation SPCC Plans and Inspection NORM Management Waste Management Air Quality Permitting, Monitoring and Compliance Environmental Due Diligence and Auditing Section 404 (WOTUS) Delineations and Permitting Wildlife and ESA Surveys, Monitoring and Management Federal Land Permitting, Compliance and Reclamation 3
CONTENTS OF THIS STATEMENT OF QUALIFICATIONS Our Company Our Values Our People Our Services and Experience Our Clients Our Contact Information
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OUR COMPANY KC Harvey Environmental, LLC (“KC Harvey”), headquartered in Bozeman, Montana, specializes in providing environmental consulting, engineering, technology and field services to the oil and gas industry in major production areas in the continental U.S. We focus on delivering world-class environmental science and engineering services related to the exploration, production, and transportation of oil and gas resources. We maintain operations in several major oil and gas production areas in the U.S, including the Permian Basin of west Texas and southeast New Mexico. KC Harvey is recognized for innovations and accomplishments in oilfield environmental management, such as, the beneficial use of oil and gas produced water, the efficient integration of oilfield-scale inspection and maintenance services, large scale land reclamation, bioremediation of hydrocarbon contaminated soil, and exceptional environmental due diligence. We provide our services from a low overhead, small business platform to remain clientfocused, responsive, efficient and fiscally responsible. KC Harvey has been in the environmental and natural resource consulting business for 24 years. We focus on providing the following professional environmental consulting services to clients operating in the Permian Basin: • Spill Response and Remediation • SPCC Plans and Inspection • NORM Management • Waste Management • Air Quality Permitting, Monitoring and Compliance • Environmental Due Diligence and Auditing • Section 404 (WOTUS) Delineations and Permitting • Wildlife and ESA Surveys, Monitoring and Management • Federal Land Permitting, Compliance and Reclamation (New Mexico)
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OUR VALUES We operate at the busy intersection of economy, energy and environment. The world economy runs on energy. The vibrancy and achievement of American innovation is in no small part due to the stability and sustainability of our energy infrastructure and delivery system. Likewise, our ability to develop and use energy resources sustainably requires environmental protection, mitigation and restoration. At KC Harvey, we are committed to our clients, their mission to produce energy, and their need for protection of the natural environment. We are dedicated to safety, innovation, efficiency, sustainability and integrity. We deliver these skills through a passionate and skilled workforce with remarkable dedication and problem solving capacity. Our people are practical, agile, creative and strategic, and provide scientific and engineering services without surprises. We develop client relationships that span decades, and the success of our clients is our legacy. Our reward is energy production with a clean environment and a vibrant economy. KC Harvey’s value proposition to our clients in the Permian Basin is simple: We focus on oil and gas KC Harvey is a client-focused, professionally managed small business enterprise with low overhead that focuses on the environmental management needs of the oil and gas E&P and midstream industry. Safety is paramount KC Harvey maintains a professional safety program and an excellent safety record. KC Harvey is an alternative to small, low cost firms that are not professionally managed and do not maintain an adequate safety program. We are lean and nimble KC Harvey is also an alternative to the large, institutional engineering firms and their high overhead, cost, poor response time, and inherent need to over-bill their clients. We can adjust immediately to the changing conditions and requirements of our clients. We have the knowledge and experience KC Harvey is owned and managed by five very senior professionals with decades of national and international experience, much of it with large national engineering firms. We simply provide more for less cost.
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OUR PEOPLE At KC Harvey, we’re passionate about people, energy independence, environmental quality and a growing, sustainable economy. How do we prevent and solve environmental problems while exceeding our clients’ expectations and establishing ourselves as leaders in the field? Simple. We hire the best. We employ innovative technologies. We focus on our strengths. We offer top-to-bottom, inception-toconclusion integrated services. We embrace safety. Through it all, we remember the people – the employee, the client, the local stakeholder – and we keep them at the center of every action we take, every solution we present, every project we complete…..no surprises. The growing KC Harvey team employs full time professionals plus additional seasonal staff. Team members are recruited based on credentials and accomplishments, industry reputations, and relationships with clients. Every team member contributes, is relied upon for input, and has shared values and goals that allow us to exceed the expectations of our clients. Our team includes scientists, engineers, data specialists, field services managers, safety managers and business professionals and maintains competence and credentials across the following disciplines: Earth Sciences Soil science, geology, hydrology, geohydrology, geomorphology, geochemistry and environmental chemistry Ecological Sciences Plant, weed, rangeland, forest, wetland and wildlife ecology Remediation Sciences Soil and groundwater remediation, land reclamation and ecological restoration Engineering Civil, environmental, chemical, geotechnical and water resources engineering Data Management and Analysis Data validation, database development, GIS and statistics
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Our services and experience Our consulting services are provided from a foundation of applied science and engineering. We apply these skills to diverse client needs ranging from urgent response to long-term management. Completing quality consulting projects on time and within budget is our minimum performance standard. At KC Harvey, we believe in more than just quality, timeliness and financial responsibility. We believe in true innovation and “out of the box” thinking to exceed our client’s expectations. Even the smallest, seemingly mundane task can benefit from innovation. Our solutions, aimed at both preventing and solving problems, span the full life cycle of the typical oil and gas E&P or midstream project. In the Permian Basin, we provide the following professional environmental consulting services:
• Spill Response and Remediation • SPCC Plans and Inspection • NORM Management • Waste Management • Air Quality Permitting, Monitoring and Compliance • Environmental Due Diligence and Auditing • Section 404 (WOTUS) Delineations and Permitting • Wildlife and ESA Surveys, Monitoring and Management • Federal Land Permitting, Compliance and Reclamation (New Mexico) In addition to these key services, KC Harvey is capable of providing additional support services to the oil and gas industry in the Permian Basin, including land reclamation planning and implementation, stormwater management, NPDES permitting, assistance with the development of plans of operations and APDs, and litigation support. Specifics regarding the key services that we provide to our clients in the Permian Basin and related experience are presented on the following pages.
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SPILL RESPONSE AND REMEDIATION KC Harvey personnel respond to hydrocarbon and produced water spills in the oilfield. We stand ready to provide overall spill response management, site investigation, product removal, soil excavation and disposal, site restoration, and agency coordination services. We also have soil and vadose zone science expertise to establish whether or not a spilled material will travel offsite or permeate to groundwater, concurrently with initial response and cleanup activities. Our ability to rapidly assess the fate and transport of a spilled material can improve the response process and transform a spill from an acute issue to a monitored natural attenuation approach, thus reducing costs significantly. Our spill response and remediation services include: • Emergency response planning and incident management • Sampling and analysis planning • Site soil and groundwater sampling and analysis • Monitoring well installation • Data management and interpretation • Contaminant delineation and characterization • Contaminant fate and transport assessment • Soil and groundwater remediation • Soil removal and replacement • Bioremediation / on-site and off-site landfarming • Soil vapor extraction / in-situ oxidation and soil washing • Monitored natural attenuation • Remedial action oversight • Agency coordination, reporting and compliance • Final site restoration and reclamation • Closure documentation • Post-remediation monitoring Examples of our spill response and remediation project experience include: Groundwater Assessment and Remediation for a Confidential Client, Block 16 Commonpoint, Pyote, Texas. Soil and groundwater assessment and remediation activities were carried out at a former natural gas commonpoint near Pyote, Texas. The scope of work included assessment of historic hydrocarbon releases and spills involving waste pits, tank batteries, flow lines, dehydrators, and flares both on the facility and on surrounding gas plants. Assessment included a review of historic documents, conducting geophysical (resistivity and conductivity) surveys, collecting soil samples from over 100 soil borings, monitoring well borings, and groundwater sampling. A treatability pilot test was designed and conducted to evaluate remediation options for treating soil and groundwater. The final design included 20 groundwater recovery wells and 28 soil vapor extraction (SVE) wells. Light Non-Aqueous Phase Liquids (LNAPL) were recovered using a field constructed oil/water separator. Recovered groundwater was treated in air sparging tanks and discharged along a pipeline right-of way under permit from the Texas Railroad Commission. Vapors from SVE wells and air sparging tanks were treated using a thermal oxidizer under a Permit by Rule Authorization from the Texas Commission on Environmental Quality.
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Pipeline Release Response and Remediation, Williston Basin, North Dakota. KC Harvey carried out a comprehensive soil and groundwater site investigation to determine the nature and extent of a crude oil release (1000 bbls) associated with a pipeline rupture. Remedial alternatives were assessed based on the findings of the site investigation, relevant regulatory requirements and cost. KC Harvey managed all activities associated with soil remediation including excavation/removal/replacement and onsite bioremediation. KC Harvey performed final site restoration and managed all agency coordination and closure documentation. Spill Response and Remediation Planning, Williston Basin, North Dakota. KC Harvey is retained by a national insurance underwriter to respond to petroleum and produced water spills throughout the Bakken oil and gas region of North Dakota. Assignments include emergency site investigation, fate and transport analysis to ascertain whether or not a spill is truly an emergency situation, agency communications, and remediation planning and implementation. Soil, Sediment, Surface Water, and Groundwater Assessment, Alvin, Texas. A phased assessment was completed to evaluate affected environmental media (soil, sediment, surface water and groundwater) contaminated by petroleum hydrocarbon releases. A former waste storage area, fuel island, and oil and waste water storage tanks were also evaluated. The affected area included the site and adjacent residential property. Constituents of concern included petroleum hydrocarbons, volatile organic compounds, and arsenic. The assessment activities identified source areas, delineated the extent of impacted media, identified areas where soil remediation was necessary, and evaluated natural attenuation as a remediation option for groundwater.
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SPILL PREVENTION CONTROL AND COUNTERMEASURE (SPCC) plans and inspection
KC Harvey prepares and certifies field wide SPCC plans and conducts field inspections on hundreds of oil and gas locations per year for our oil and gas clients. We also re-write existing SPCC plans to increase efficiencies for management of numerous oilfield well locations across large areas. Our SPCC experts can help you understand the distinction between requirements and recommended practices. Our SPCC services include: • Development of SPCC Plans - Prevention: ways to minimize and prevent spills through design, training and monitoring - Control: a plan to adequately control potential spills with controls like secondary containment - Countermeasure: a guide for first responders to follow in the event of a spill • Training your workforce on roles and responsibilities • Compliance - Regular inspections - Maintenance - Suggestions for improvement - Agency reporting - Record keeping Examples of our SPCC project experience include: Preparation and Certification of SPCC Plans for Ultra Petroleum, Wyoming. KC Harvey has prepared individual and field wide SPCC plans and conduct site inspections for hundreds of natural gas well locations throughout the Pinedale Anticline of Wyoming. This has been an ongoing project with Ultra since 2009. Preparation of a Field-wide SPCC Plan for Devon Energy, Wyoming. KC Harvey developed and implemented a field-wide SPCC plan involving for 750 natural gas well locations in the Washakie Basin of southcentral Wyoming. Efficiencies were designed into the SPCC program by developing site map templates, digital input formats, and using custom applications and tablet computers for field inspections. Preparation and Certification of SPCC Plans for Antero Resources, West Virginia and Ohio. KC Harvey is responsible for an ongoing SPCC program for Antero Resources in the Marcellus and Utica regions of West Virginia and Ohio. The scope includes inspections, SPCC plan preparation and certification on several hundred natural gas well locations.
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NORM MANAGEMENT
The management of naturally occurring radioactive materials (NORM) is becoming a critical environmental issue for the oil and gas industry. KC Harvey has the training, experience, and equipment to perform NORM surveys in the oilfield environment. We can characterize the nature and extent of NORM and help develop waste minimization and management protocols so that NORM materials do not accumulate to unmanageable levels. KC Harvey maintains staff with specific oilfield NORM training and Radiation Safety Officer (RSO) certification and a certified NORM inspector in our Permian Basin office. Our NORM management services include: • Pre-acquisition NORM surveys • NORM surveys conducted by certified inspectors • Developing NORM Management Plans to minimize and manage NORM • Developing Worker Protection Plans • Workforce training on roles and responsibilities pertaining to: - Inspections - Tank labelling requirements - Maintenance - Surveys - Record keeping - Worker Protection Plans Examples of our NORM management project experience include: NORM Waste Management and Pit Closure for Key Energy Services, Inc., Sydney, Montana. Project consisted closing a former unloading pit associated with a Class II injection well. Pit sediments were analyzed and classified as NORM waste. NORM waste was disposed of at a licensed facility. Non-NORM material (concreted and hydrocarbon impacted soils) were disposed of at a local landfill. The former pit area was backfilled, graded and seeded. NORM Inventory and Assessment for Montana Power Company, Montana. KC Harvey personnel performed a comprehensive NORM survey and assessment of natural gas natural gas production equipment and tanks in natural gas fields throughout the state of Montana. The scope of work included the evaluation of NORM levels to determine if NORM thresholds were exceeded. The findings of the site wide survey were mapped and presented in a spatial format. Recommendations for management and disposal were included in a comprehensive report. NORM Mitigation Project for Encana Oil and Gas, Wyoming. KC Harvey personnel performed a NORM survey and assessment of above-ground storage tanks used to store production liquids on individual well locations. The project included developing a management and mitigation approach for tanks where NORM levels exceeded regulatory thresholds. A field-wide approach for addressing NORM exceedances was also developed.
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Condensate 222Rn and Particulate Scale
Origins of Naturally Occurring Radioactive Materials (NORM)
Particulate Scale and ??? Rn
Gas
Oil
GOSP
Ra Ra Pb 222Rn ???
222Rn, 210Pb,210Po
plates tubular
Water
228 210
Ra isotopes precipitate as mineral scale
222
Rn travels with gas
Ra, 228Ra, 228Th, 222Rn, 214Bi, 210Pb
226
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WASTE MANAGEMENT
KC Harvey personnel have decades of waste management experience ranging from the day to day management of exempt oilfield wastes, to solid and hazardous wastes regulated under RCRA, to large-scale CERCLA remediation programs. Our oilfield waste management services include: • Preparation of comprehensive oilfield waste management plans • Hazardous materials characterization, manifesting, TCLP testing • Environmental due diligence of landfills • Oversight and reporting of asbestos abatement • Landfarm design, permitting and operation • Innovative waste management concepts • Injection well permitting • Produced water management plans • Produced water treatment assessment Examples of our oilfield waste management project experience include: Oilfield Waste Management Plan, Encana Oil and Gas, USA, Riverton, Wyoming. Prepared a comprehensive waste management plan for oil and gas operations including management of used oil and oily liquids, non-hazardous and hazardous waste streams, hydrocarbon impacted soil, and solid wastes. Assisted with permitting two injection wells capable of disposing 5,000 BPD of production liquids. Developed standard sampling and monitoring methods for managing drill cuttings disposal to meet Wyoming regulatory guidelines. Provided production and midstream managers with information necessary to better understand issues related to waste management and advantages of waste minimization. Waste Disposal Environmental Investigation, Texas. KC Harvey personnel responded to a U.S. EPA Criminal Investigation Division (CID) inquiry regarding long term waste disposal practices. An anonymous complaint filed with EPA reported that drums with industrial waste were buried by a former property owner. The area was investigated using non-intrusive geophysical methods. The findings of the investigation and a response plan were recommended to the client and the EPA. Development and Deployment of Wastewater Land Application/Irrigation Systems for the Beneficial Use of Produced Water, Wyoming, Montana and Colorado. KC Harvey scientists and engineers pioneered the use of saline-sodic produced waters for irrigation of crops and forage in the western U.S. The scope of this decade-long program included research and development, individual project design, water chemistry assessment, project water balance modeling, screening and characterization of candidate sites, crop selection, soil amendment prescriptions, landowner negotiations, regulatory agency coordination and permitting, construction, system operation, and environmental monitoring. Over 3,000 acres of pivot irrigation systems were installed. For this innovative work, KC Harvey received a national award from the Soil Science Society of America.
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Troubleshooting of Oilfield Landfarm Operations, Green River Basin, Wyoming. KC Harvey soil scientists and bioremediation experts conducted a forensic assessment of multiple failed landfarming operations on well locations in the Green River Basin of Wyoming. Contamination levels had been static for over a decade at these facilities. Soil physical, chemical and biological characteristics were assessed and an improved bioremediation prescription was developed and implemented. The prescriptions were successful in rapidly degrading total petroleum hydrocarbons to below state cleanup levels in only one summer season. Review and Troubleshooting of Bioremediation Landfarm, Helena, Montana. KC Harvey soil and bioremediation experts carried out a technical review of a large bioremediation land treatment unit for a railroad client in Montana. Contaminants of concern include diesel fuel, lube oils and other petroleum hydrocarbons. The objectives of the project were to troubleshoot operations to optimize biodegradation rate and extent. Developed and implemented a plan for maintaining optimum soil moisture, oxygen and nutrient conditions for bioremediation that improved facility performance.
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AIR QUALITY PERMITTING, MONITORING AND REPORTING KC Harvey maintains an experienced air quality management team to serve our oil and gas clients in the Permian Basin. This team is led by a Master of Science level chemical engineer with decades of air quality related experience including emissions characterization, permitting and compliance monitoring. Our oilfield air quality practice integrates well with other environmental services and can add efficiency to larger fieldwide compliance and inspection programs. Our oilfield air quality permitting, monitoring and reporting services include: • Leak Detection and Repair (LDAR) – Method 21 • Development and implementation of Quality Improvement Program (QIP) • Visual Opacity Testing – Method 9 • Visible Determination of Fugitive Emissions – Method 22 • Preparation of air quality permit applications (NSR and PSD permits) • Directed Inspection and Maintenance (DI & M) • Development and implementation of Work Practice Plans • Ambient air quality monitoring • Air emissions inventories • Greenhouse Gas (GHG) Inventory and Mandatory Reporting Rule (MRR) assistance Examples of our oilfield air quality project experience include: Title V Permit Major Modification, Sunoco Refinery, Tulsa Oklahoma. The scope of work included a major modification to the facility’s Title V Permit as part of a $500 million process modification, leading to a comprehensive New Source Review (NSR) / Prevention of Significant Deterioration (PSD) Permit preparation for four criteria air pollutants. Tasks included ambient air quality impact analysis using EPAapproved air dispersion modeling techniques, BACT/LAER review, and Class 1 area impact analysis. Other air quality support activities included: liaison with local, state and federal regulatory agencies, development of corporate environmental management plans (EMPs) and programs, regulatory interpretation and application to facility processes, training, regular site visits, emissions tracking, file reviews at state and EPA offices, and report preparation. Emissions Inventory and Permit Review of Natural Gas Field, Green River Basin, Wyoming. Completed a field wide emissions inventory for a natural gas field that included over twenty multi well locations, two central facilities and a compressor station. Emissions sources were inventoried for each location to evaluate permit compliance. Equipment documented included glycol dehydration units, heaters, pneumatic pumps, tanks, flares, and combustors. Emissions from glycol dehydration units, and produced water and condensate storage tanks were modeled using current production data and product analysis. Total site emissions, including fugitive emissions were calculated for each location. Permitting issues including unpermitted sources and exceedance were identified. Recommendations for source reduction were provided where needed.
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Annual Emissions Inventory Reporting, Green River Basin, Wyoming. The Wyoming Department of Environmental Quality, Air Quality Division requires annual reporting for oil and gas production facilities. Minor source emissions inventories are collected every three years in accordance with 40 CFR Part 51,
Subpart A, or sites located in the Upper Green River Basin reporting is required on an annual basis. KC Harvey documented emissions from stationary engines, heaters, tanks, dehydration units, pneumatic pumps, fugitive emissions, venting and blowdown, drill rigs, completion and workover, truck loading and on-road mobile units. Detailed review of annual data was completed to finalize annual reports for submission to the Air Quality Division. New Source Review Permitting, Upper Green River Basin, Wyoming. Wyoming Air Quality Standards and Regulations (WAQSR) Chapter 6, Section 2(a)(i) New Source Review requires new construction projects, or construction projects modifying existing facilities or sources to undergo review and permitting. KC Harvey provided New Source Review (NSR) and permitting services for several operators in the Upper Green River Basin of Wyoming. Work was completed for both existing well locations and for new construction. Risk Assessment of Accidental Gas Release for Agip Energy – Eni, NG/Brass Operations, Nigeria. Conducted detailed environmental consequence analyses for unintended (accidental) gas release from two contiguous (33 mile) natural gas pipelines. The analysis included estimation of probability and impacts of pipeline failure, identification of possible zones of impacts, and estimation of worst- and alternative-case scenario environmental consequences in subsea and onshore environments. The project was consistent with the clients’s corporate Risk Management Program modelled after the USEPA/OSHA RMP/PSM programs.
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ENVIRONMENTAL DUE DILIGENCE AND AUDITING Clients retain KC Harvey to conduct environmental due diligence and audits of oil and gas assets because of our extensive on the ground environmental management experience in oilfields. We deliver accurate and practical information and advice regarding environmental, safety and social issues that may impact decisions and transactions related to mergers and acquisitions, financing and investment, initial public offerings (IPOs), divestitures and emerging technologies. Our sector-leading due diligence team will support your price negotiations by documenting environmental conditions, liabilities and regulatory compliance prior to closure of the transaction. In addition to the identification of existing liabilities, our team can identify posttransaction operational risks that may impact future environmental and/or social licensing and long-term value of the acquisition. Our environmental due diligence and audit services include: • ASTM Environmental Transaction Screens • ASTM Phase I and II Environmental Site Assessments • Rapid high level environmental, safety and social screening of acquisition targets • Tailored and comprehensive environmental, safety and social due diligence assessments • Identification of post-transaction operational risks • Tailored seller-side assessments to prevent erosion of deal value • Comprehensive environmental compliance auditing • Asset retirement obligation evaluation Examples of our environmental due diligence and audit project experience include: Pre-Transaction Environmental Due Diligence of Questar Natural Gas Production Assets, Wyoming, Utah and Colorado, for Dominion Resources Inc. KC Harvey was retained by Dominion Resources, Inc. (the “Buyer”) to conduct an expedited environmental due diligence review of multi-billion dollar oil and gas exploration and production (E&P) assets in the states of Wyoming, Colorado and Utah. The scope of this tailored review included (1) the evaluation of local, state and federal environmental regulatory compliance records and related matters associated with the E&P assets and operations and how any compliance issues may impact future operations, permitting and expansion; (2) review and analysis of existing environmental data and information related to the E&P assets and operations provided by the Seller through a “Digital Data Room” with respect to environmental management and future operations and expansion; and (3) review of data and reports prepared by the Seller regarding existing environmental conditions and liabilities with respect to the adequacy of the cost estimates for managing or remediating identified environmental liabilities. The scope of the review included air, land surface and subsurface, water resources, wildlife resources, soil and vegetation resources, waste materials and waste management facilities, and well locations and access roads. KC Harvey completed this time critical review in a total of ten days.
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Pre-acquisition Environmental Due Diligence, Bearpaw Natural Gas Production Area, Northern Montana, for Stinson Morrison Hecker on behalf of NorthWestern Energy (NWE) Company. NWE and Stinson Morrison Hecker (SMH) retained KC Harvey to perform environmental due diligence of selected natural gas facilities within the Bearpaw Natural Gas Production area. This area extends over four counties and is approximately 800 square miles. KC Harvey identified potential environmental conditions associated with over 1500 natural gas production wells, 25 midstream facilities, and 20 produced water
storage impoundments owned and operated by Devon Energy, NFR Bear Paw Basin, and several other smaller oil and gas companies. In addition to 450 field inspections, due diligence activities included a review of air quality operating permits, waste management program, SPCC program, stormwater management program, and agency notices of violation. Three comprehensive reports were prepared for the client prior to NWE’s final acquisition of the assets. This was the largest single acquisition of oil and gas assets in the history of Montana. Environmental Audit and Training Program, Key Energy Services, Inc., Texas. Developed an environmental audit and training program for company facilities. The audit program was developed to train company personnel the skills necessary to perform periodic audits necessary for SPCC and SWPPP compliance and company audit protocols. The training program was developed in an on-line format. Periodic on-site training was provided when requested or when necessary in response to specific incidents.
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SECTION 404 / WOTUS DELINEATIONS AND PERMITTING KC Harvey soil scientists, plant ecologists and hydrologists are trained, certified as necessary, and experienced at accurately identifying and delineating jurisdictional Waters of the United States (WOTUS) including wetlands for proposed oil and gas development projects. Our Section 404 / WOTUS delineations and permitting services include: • Screening level identification of jurisdictional wetlands and streams • Field delineation of jurisdictional wetlands and streams • Preparation of US Army Corp of Engineers Section 404 permit applications • Mitigation planning, design and implementation • Wetland monitoring and assessment
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Examples of our Section 404 / WOTUS delineations and permitting project experience include: Delineation of Jurisdictional Waters and Wetlands and Section 404 Permitting for the Proposed Dakota Access Pipeline, Energy Transfer Partners, South Dakota and North Dakota. KC Harvey was selected to carry out baseline environmental surveys, including the delineation of jurisdictional wetlands and other waters along several hundred miles of the proposed right of way for the controversial Dakota Access Pipeline. This massive project involved preparation of Section 404 permit applications and ongoing coordination with FERC and US Army Corp of Engineers to ensure that the pipeline construction schedule would not be impacted. KC Harvey completed this logistically challenging project on time and on budget. Delineation of Jurisdictional Waters and Wetlands and Section 404 Permitting for the Proposed Vantage Pipeline and Extensions, Pembina Pipeline Corporation, North Dakota. KC Harvey was selected by Pembina to assist with the preparation of a Presidential (US State Department) Permit for building a pipeline across the international boundary with Canada. The project scope included environmental baseline surveys, delineation of jurisdictional wetlands and other waters, Section 404 permitting, preparation of an environmental impact statement, PSC and FERC permitting, and environmental inspection responsibility during pipeline construction. KC Harvey was instrumental in helping the client receive a controversial Presidential Permit at the same time the federal government was considering the same permit for the proposed Keystone XL pipeline. Wetland Delineation and Section 404 Permitting, Antero Resources, West Virginia and Ohio. KC Harvey was tasked for the last four years with the delineation of wetlands and other WOTUS features, and preparation of Section 404 permit applications for proposed natural gas well locations and pipeline right of ways throughout West Virginia and Ohio development areas. Wetland Delineation and Section 404 Permitting, Triad Hunter, West Virginia and Ohio. KC Harvey carried out numerous delineations of jurisdictional wetlands and other WOTUS features. Section 404 permit applications were prepared and shepherded through the U.S. Army Corp of Engineers prior to natural gas well and pipeline construction.
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WILDLIFE AND ESA SURVEYS, MONITORING AND MANAGEMENT KC Harvey’s team of wildlife, aquatic and ecological scientists provide a full range of biological services to our clients operating in the Permian Basin, ranging from baseline habitat and population surveys to permitting and mitigation/restoration. In addition, we maintain a network of local consulting biologists who are experts in the species and habitats of the Permian region to augment our core team. Our wildlife survey, monitoring and management services include: • Federal and state protected species habitat assessment • Federal and state protected species presence or absence surveys • Baseline wildlife and habitat assessments, surveys, and analyses • Survey and monitoring of migratory birds, prairie chicken, and raptors • USFWS Biological Assessments and Biological Evaluations • Section 7 Consultation support • Section 10(a)(1)(B) Incidental Take Permit assistance • Fisheries and aquatic ecology • Radiotelemetry and tagging studies • Bat surveys including use of AnaBat™ • Fish and wildlife passage, and conflict and collision reduction • Habitat improvement, reclamation and restoration • Site ecological risk assessments • Conservation and habitat mitigation banking Examples of our wildlife related project experience include: NPL Project Area Vegetation and Sage Grouse Habitat Mapping, Upper Green River Basin, Wyoming. Developed and applied an innovative vegetation and sage grouse habitat mapping technique using remote sensing, field mapping, and GIS analysis. The methodology uses the definition of sage grouse habitat in the Wyoming Governor’s Executive Order for sage grouse protection updated in 2011. This was the first Habitat Assessment Framework (HAF) based predictive model for identifying habitats within Core Area suitable for development. The deliverables allow oil and gas operators to quantify habitat potentially impacted in different development scenarios. Greater Sage Grouse Monitoring, Pinedale Anticline Project Area, Wyoming. Shell, Ultra Petroleum, Questar. Trapped and installed GPS collars on 90 sage grouse as part of a two-year project to assess habitat selection and seasonal movement patterns and evaluate changes due to oil and gas development. Conducted lek surveys and monitored nesting success. Installed noise monitoring equipment to record and evaluate drill rig and compressor station noise levels. The comprehensive project report evaluated if threshold levels of sage grouse metrics were exceeded that would require changes to oil and gas development plans.
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Soils, Vegetation, and Sage Grouse Habitat Mapping, EnCana Oil and Gas (USA), Inc., Jonah Field, Wyoming. Completed a two year project using Quickbird satellite imagery and LIDAR elevation data to map soils, vegetation, and sage grouse habitat. The project included developing and testing analysis methods on a pilot scale, implementing remote sensing analysis for the entire gas field, incorporating
several years of field monitoring data as ground truth, and reporting results. In addition to creating framework soils and vegetation data layers, the project satisfied the BLM’s wildlife management plan requirement that operators map sage grouse habitat. Wind Development Wildlife and Ecological Assessments, Pathfinder Wind Energy, Natrona and Carbon Counties, Wyoming. KC Harvey completed a multi-disciplinary effort to develop wind energy resources including baseline data collection for soil, vegetation, water resources, and wildlife. Wildlife species included sage grouse, raptors, pronghorn, deer, elk, small mammals, songbirds, reptiles, and amphibians. Assessments were three year efforts to meet NEPA and Wyoming DEQ permit requirements. North Moneta Cooperative Sage Grouse Study, Multiple Oil and Gas Producers, Lysite, Wyoming. KC Harvey completed a sage grouse habitat study in a 180,000 acre proposed oil and gas production area in Fremont County, Wyoming. Included conducting lek, brood, and wintering habitat surveys on BLM, State, and private lands in designated Core Area using the Habitat Assessment Framework (HAF) (BLM, 2010) under the updated Governor’s Executive Order on sage grouse (2011). Project also includes development of a HAF based predictive model for identifying micro-scale habitats within Core Area suitable for development siting. Hogback Ridge and Slater Bordeaux Wind Development Wildlife and Ecological Assessments, Pathfinder Renewable Energy LLC, Wyoming. KC Harvey completed two multi-year wildlife and ecological assessments for proposed wind energy developments in Wyoming. Assessments included federal and state listed species including leks and wintering and brooding habitats for sage grouse under the Governor’s Executive Order and Wyoming Game and Fish Department (WGFD), U.S. Fish and Wildlife Service (USFWS), and BLM protocols. Assessments were three year efforts to meet NEPA and Wyoming DEQ permit requirements.
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FEDERAL LAND PERMITTING, COMPLIANCE AND RECLAMATION A large portion of the Permian Basin in New Mexico is located on federal land managed by the U.S. Bureau of Land Management (BLM). Proposed oil and gas development projects on federal land require review in accordance with the National Environmental Policy Act (NEPA). Unless a proposed activity is Categorically Excluded under NEPA from additional review, drilling or pipeline right-of-way projects may require an Environmental Assessment (EA) or Environmental Impact Statement (EIS) before they can proceed. In addition to NEPA review, there may be additional requirements on permitting for oil and gas development on federal lands. KC Harvey is known throughout the western U.S. for its expertise in environmental compliance and reclamation services for the oil and gas industry. Our federal land permitting and compliance related services include: • Baseline environmental surveys • Preparation of third party NEPA, EA and EIS documents • Preparation of APDs • Soil salvage and reclamation planning, design and implementation • Reclamation success monitoring Examples of our federal land permitting, compliance and reclamation project experience include: Continental Divide/Creston EIS, Baseline Surveys and Reclamation Plan Development. Bureau of Land Management, Rawlins, Wyoming. KC Harvey participated on a multi-disciplinary team developing an EIS for the Continental Divide/Creston 5000 well natural gas infill drilling project in south central Wyoming. KC Harvey was responsible for baseline soil and vegetation data collection, analysis, and reporting and developed the field wide reclamation plan for the EIS. Bear Paw South Natural Gas Project EIS, North Central Montana. Devon Energy Corporation, Montana. KC Harvey scientists served on a multi-disciplinary team for development of an EIS for expanded drilling in the 376,000 acre Bear Paw South natural gas field in north central Montana. KC Harvey was responsible for baseline data collection, analysis, and reporting of geology and minerals, water resources, soils and reclamation, vegetation and noxious weeds, and range resources. Natural Gas Field Reclamation, Wamsutter Natural Gas Field, South Central Wyoming. Since 2008, KC Harvey provided comprehensive science-based reclamation services to multiple natural gas producers operating on federal land in the 1.25 million acre Wamsutter natural gas field in south central Wyoming. This program covers more than 2500 well pad locations, pipelines, roads, and other facilities. Services provided include permitting support, pre-construction reclamation planning, soil management, reclamation monitoring, invasive plant control, reclamation seeding, erosion control installations, soil amendments, fertilization, and other reclamation practices. KC Harvey conceived and initiated this program, developed standard operating procedures, and has improved efficiency and reduced costs to clients over time.
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Reclamation Program Development and Implementation, Jonah Field, Encana Oil and Gas USA, Inc. Wyoming. KC Harvey reclamation scientists designed and implemented a first of its kind site-specific, science-based reclamation program across the Jonah natural gas field on federal land in western Wyoming. The scope of this multi-year project included soil physicochemical assessment, soil salvage planning and implementation, baseline vegetation inventory, forensic soil investigations, reclamation implementation, design and construction of irrigation systems, soil amendment prescriptions, and field-wide monitoring of reclamation success. All work was reviewed and approved by regional BLM officials.
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OUR clients KC Harvey has the pleasure and the privilege of providing consulting services to many of the world’s leading oil and gas E&P and midstream companies. In the Permian Basin, we currently have Master Service Agreements with the following oil and gas clients:
Pioneer natural Resources EOG Resources PDC Energy Encana Noble Energy
Hess Halcon Spectra Energy Energy Transfer Partners
In addition to our Permian Basin clients listed above, we have the privilege of serving the following oil and gas companies:
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ExxonMobil Shell Oil Company BP America Chevron Corporation ConocoPhillips Marathon Oil Encana Corporation Santos Ltd. EOG Resources Devon Energy Anadarko Petroleum Whiting Petroleum Continental Resources Hess Corporation Dakota Access Pipeline Energy Transfer Partners Mistral Energy Vantage Pipeline Pembina Pipeline US
Spectra Energy Noble Energy Antero Resources Aethon Energy Linn Energy Williams WPX Energy QEP Resources Questar Dominion Energy Fidelity E&P Co. RedLeaf Resources Southland Royalty Co. Breitburn Energy Partners Triad Hunter PDC Energy Halcon Eureka Hunter
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Contact Us For more information on how we might assist you with the production of oil and gas resources in the Permian Basin, please contact: Dan Gibson, PG
Permian Basin Operations Manager (432) 614-6096 [email protected] David Marshall, PG
Permian Basin Principal-in-Charge (406) 585-7402, extension 103 [email protected] 2
CONTENTS OF THIS STATEMENT OF QUALIFICATIONS Our Company Our Values Our People Our Services and Experience Our Clients Our Contact Information
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OUR COMPANY KC Harvey Environmental, LLC (“KC Harvey”), headquartered in Bozeman, Montana, specializes in providing environmental consulting, engineering, technology and field services to the oil and gas industry in major production areas in the continental U.S. We focus on delivering world-class environmental science and engineering services related to the exploration, production, and transportation of oil and gas resources. We maintain operations in several major oil and gas production areas in the U.S, including the Permian Basin of west Texas and southeast New Mexico. KC Harvey is recognized for innovations and accomplishments in oilfield environmental management, such as, the beneficial use of oil and gas produced water, the efficient integration of oilfield-scale inspection and maintenance services, large scale land reclamation, bioremediation of hydrocarbon contaminated soil, and exceptional environmental due diligence. We provide our services from a low overhead, small business platform to remain clientfocused, responsive, efficient and fiscally responsible. KC Harvey has been in the environmental and natural resource consulting business for 24 years. We focus on providing the following professional environmental consulting services to clients operating in the Permian Basin: • Spill Response and Remediation • SPCC Plans and Inspection • NORM Management • Waste Management • Air Quality Permitting, Monitoring and Compliance • Environmental Due Diligence and Auditing • Section 404 (WOTUS) Delineations and Permitting • Wildlife and ESA Surveys, Monitoring and Management • Federal Land Permitting, Compliance and Reclamation (New Mexico)
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OUR VALUES We operate at the busy intersection of economy, energy and environment. The world economy runs on energy. The vibrancy and achievement of American innovation is in no small part due to the stability and sustainability of our energy infrastructure and delivery system. Likewise, our ability to develop and use energy resources sustainably requires environmental protection, mitigation and restoration. At KC Harvey, we are committed to our clients, their mission to produce energy, and their need for protection of the natural environment. We are dedicated to safety, innovation, efficiency, sustainability and integrity. We deliver these skills through a passionate and skilled workforce with remarkable dedication and problem solving capacity. Our people are practical, agile, creative and strategic, and provide scientific and engineering services without surprises. We develop client relationships that span decades, and the success of our clients is our legacy. Our reward is energy production with a clean environment and a vibrant economy. KC Harvey’s value proposition to our clients in the Permian Basin is simple: We focus on oil and gas KC Harvey is a client-focused, professionally managed small business enterprise with low overhead that focuses on the environmental management needs of the oil and gas E&P and midstream industry. Safety is paramount KC Harvey maintains a professional safety program and an excellent safety record. KC Harvey is an alternative to small, low cost firms that are not professionally managed and do not maintain an adequate safety program. We are lean and nimble KC Harvey is also an alternative to the large, institutional engineering firms and their high overhead, cost, poor response time, and inherent need to over-bill their clients. We can adjust immediately to the changing conditions and requirements of our clients. We have the knowledge and experience KC Harvey is owned and managed by five very senior professionals with decades of national and international experience, much of it with large national engineering firms. We simply provide more for less cost.
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OUR PEOPLE At KC Harvey, we’re passionate about people, energy independence, environmental quality and a growing, sustainable economy. How do we prevent and solve environmental problems while exceeding our clients’ expectations and establishing ourselves as leaders in the field? Simple. We hire the best. We employ innovative technologies. We focus on our strengths. We offer top-to-bottom, inception-toconclusion integrated services. We embrace safety. Through it all, we remember the people – the employee, the client, the local stakeholder – and we keep them at the center of every action we take, every solution we present, every project we complete…..no surprises. The growing KC Harvey team employs full time professionals plus additional seasonal staff. Team members are recruited based on credentials and accomplishments, industry reputations, and relationships with clients. Every team member contributes, is relied upon for input, and has shared values and goals that allow us to exceed the expectations of our clients. Our team includes scientists, engineers, data specialists, field services managers, safety managers and business professionals and maintains competence and credentials across the following disciplines: Earth Sciences Soil science, geology, hydrology, geohydrology, geomorphology, geochemistry and environmental chemistry Ecological Sciences Plant, weed, rangeland, forest, wetland and wildlife ecology Remediation Sciences Soil and groundwater remediation, land reclamation and ecological restoration Engineering Civil, environmental, chemical, geotechnical and water resources engineering Data Management and Analysis Data validation, database development, GIS and statistics
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Our services and experience Our consulting services are provided from a foundation of applied science and engineering. We apply these skills to diverse client needs ranging from urgent response to long-term management. Completing quality consulting projects on time and within budget is our minimum performance standard. At KC Harvey, we believe in more than just quality, timeliness and financial responsibility. We believe in true innovation and “out of the box” thinking to exceed our client’s expectations. Even the smallest, seemingly mundane task can benefit from innovation. Our solutions, aimed at both preventing and solving problems, span the full life cycle of the typical oil and gas E&P or midstream project. In the Permian Basin, we provide the following professional environmental consulting services:
• Spill Response and Remediation • SPCC Plans and Inspection • NORM Management • Waste Management • Air Quality Permitting, Monitoring and Compliance • Environmental Due Diligence and Auditing • Section 404 (WOTUS) Delineations and Permitting • Wildlife and ESA Surveys, Monitoring and Management • Federal Land Permitting, Compliance and Reclamation (New Mexico) In addition to these key services, KC Harvey is capable of providing additional support services to the oil and gas industry in the Permian Basin, including land reclamation planning and implementation, stormwater management, NPDES permitting, assistance with the development of plans of operations and APDs, and litigation support. Specifics regarding the key services that we provide to our clients in the Permian Basin and related experience are presented on the following pages.
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SPILL RESPONSE AND REMEDIATION KC Harvey personnel respond to hydrocarbon and produced water spills in the oilfield. We stand ready to provide overall spill response management, site investigation, product removal, soil excavation and disposal, site restoration, and agency coordination services. We also have soil and vadose zone science expertise to establish whether or not a spilled material will travel offsite or permeate to groundwater, concurrently with initial response and cleanup activities. Our ability to rapidly assess the fate and transport of a spilled material can improve the response process and transform a spill from an acute issue to a monitored natural attenuation approach, thus reducing costs significantly. Our spill response and remediation services include: • Emergency response planning and incident management • Sampling and analysis planning • Site soil and groundwater sampling and analysis • Monitoring well installation • Data management and interpretation • Contaminant delineation and characterization • Contaminant fate and transport assessment • Soil and groundwater remediation • Soil removal and replacement • Bioremediation / on-site and off-site landfarming • Soil vapor extraction / in-situ oxidation and soil washing • Monitored natural attenuation • Remedial action oversight • Agency coordination, reporting and compliance • Final site restoration and reclamation • Closure documentation • Post-remediation monitoring Examples of our spill response and remediation project experience include: Groundwater Assessment and Remediation for a Confidential Client, Block 16 Commonpoint, Pyote, Texas. Soil and groundwater assessment and remediation activities were carried out at a former natural gas commonpoint near Pyote, Texas. The scope of work included assessment of historic hydrocarbon releases and spills involving waste pits, tank batteries, flow lines, dehydrators, and flares both on the facility and on surrounding gas plants. Assessment included a review of historic documents, conducting geophysical (resistivity and conductivity) surveys, collecting soil samples from over 100 soil borings, monitoring well borings, and groundwater sampling. A treatability pilot test was designed and conducted to evaluate remediation options for treating soil and groundwater. The final design included 20 groundwater recovery wells and 28 soil vapor extraction (SVE) wells. Light Non-Aqueous Phase Liquids (LNAPL) were recovered using a field constructed oil/water separator. Recovered groundwater was treated in air sparging tanks and discharged along a pipeline right-of way under permit from the Texas Railroad Commission. Vapors from SVE wells and air sparging tanks were treated using a thermal oxidizer under a Permit by Rule Authorization from the Texas Commission on Environmental Quality.
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Pipeline Release Response and Remediation, Williston Basin, North Dakota. KC Harvey carried out a comprehensive soil and groundwater site investigation to determine the nature and extent of a crude oil release (1000 bbls) associated with a pipeline rupture. Remedial alternatives were assessed based on the findings of the site investigation, relevant regulatory requirements and cost. KC Harvey managed all activities associated with soil remediation including excavation/removal/replacement and onsite bioremediation. KC Harvey performed final site restoration and managed all agency coordination and closure documentation. Spill Response and Remediation Planning, Williston Basin, North Dakota. KC Harvey is retained by a national insurance underwriter to respond to petroleum and produced water spills throughout the Bakken oil and gas region of North Dakota. Assignments include emergency site investigation, fate and transport analysis to ascertain whether or not a spill is truly an emergency situation, agency communications, and remediation planning and implementation. Soil, Sediment, Surface Water, and Groundwater Assessment, Alvin, Texas. A phased assessment was completed to evaluate affected environmental media (soil, sediment, surface water and groundwater) contaminated by petroleum hydrocarbon releases. A former waste storage area, fuel island, and oil and waste water storage tanks were also evaluated. The affected area included the site and adjacent residential property. Constituents of concern included petroleum hydrocarbons, volatile organic compounds, and arsenic. The assessment activities identified source areas, delineated the extent of impacted media, identified areas where soil remediation was necessary, and evaluated natural attenuation as a remediation option for groundwater.
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SPILL PREVENTION CONTROL AND COUNTERMEASURE (SPCC) plans and inspection
KC Harvey prepares and certifies field wide SPCC plans and conducts field inspections on hundreds of oil and gas locations per year for our oil and gas clients. We also re-write existing SPCC plans to increase efficiencies for management of numerous oilfield well locations across large areas. Our SPCC experts can help you understand the distinction between requirements and recommended practices. Our SPCC services include: • Development of SPCC Plans - Prevention: ways to minimize and prevent spills through design, training and monitoring - Control: a plan to adequately control potential spills with controls like secondary containment - Countermeasure: a guide for first responders to follow in the event of a spill • Training your workforce on roles and responsibilities • Compliance - Regular inspections - Maintenance - Suggestions for improvement - Agency reporting - Record keeping Examples of our SPCC project experience include: Preparation and Certification of SPCC Plans for Ultra Petroleum, Wyoming. KC Harvey has prepared individual and field wide SPCC plans and conduct site inspections for hundreds of natural gas well locations throughout the Pinedale Anticline of Wyoming. This has been an ongoing project with Ultra since 2009. Preparation of a Field-wide SPCC Plan for Devon Energy, Wyoming. KC Harvey developed and implemented a field-wide SPCC plan involving for 750 natural gas well locations in the Washakie Basin of southcentral Wyoming. Efficiencies were designed into the SPCC program by developing site map templates, digital input formats, and using custom applications and tablet computers for field inspections. Preparation and Certification of SPCC Plans for Antero Resources, West Virginia and Ohio. KC Harvey is responsible for an ongoing SPCC program for Antero Resources in the Marcellus and Utica regions of West Virginia and Ohio. The scope includes inspections, SPCC plan preparation and certification on several hundred natural gas well locations.
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NORM MANAGEMENT
The management of naturally occurring radioactive materials (NORM) is becoming a critical environmental issue for the oil and gas industry. KC Harvey has the training, experience, and equipment to perform NORM surveys in the oilfield environment. We can characterize the nature and extent of NORM and help develop waste minimization and management protocols so that NORM materials do not accumulate to unmanageable levels. KC Harvey maintains staff with specific oilfield NORM training and Radiation Safety Officer (RSO) certification and a certified NORM inspector in our Permian Basin office. Our NORM management services include: • Pre-acquisition NORM surveys • NORM surveys conducted by certified inspectors • Developing NORM Management Plans to minimize and manage NORM • Developing Worker Protection Plans • Workforce training on roles and responsibilities pertaining to: - Inspections - Tank labelling requirements - Maintenance - Surveys - Record keeping - Worker Protection Plans Examples of our NORM management project experience include: NORM Waste Management and Pit Closure for Key Energy Services, Inc., Sydney, Montana. Project consisted closing a former unloading pit associated with a Class II injection well. Pit sediments were analyzed and classified as NORM waste. NORM waste was disposed of at a licensed facility. Non-NORM material (concreted and hydrocarbon impacted soils) were disposed of at a local landfill. The former pit area was backfilled, graded and seeded. NORM Inventory and Assessment for Montana Power Company, Montana. KC Harvey personnel performed a comprehensive NORM survey and assessment of natural gas natural gas production equipment and tanks in natural gas fields throughout the state of Montana. The scope of work included the evaluation of NORM levels to determine if NORM thresholds were exceeded. The findings of the site wide survey were mapped and presented in a spatial format. Recommendations for management and disposal were included in a comprehensive report. NORM Mitigation Project for Encana Oil and Gas, Wyoming. KC Harvey personnel performed a NORM survey and assessment of above-ground storage tanks used to store production liquids on individual well locations. The project included developing a management and mitigation approach for tanks where NORM levels exceeded regulatory thresholds. A field-wide approach for addressing NORM exceedances was also developed.
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Condensate 222Rn and Particulate Scale
Origins of Naturally Occurring Radioactive Materials (NORM)
Particulate Scale and ??? Rn
Gas
Oil
GOSP
Ra Ra Pb 222Rn ???
222Rn, 210Pb,210Po
plates tubular
Water
228 210
Ra isotopes precipitate as mineral scale
222
Rn travels with gas
Ra, 228Ra, 228Th, 222Rn, 214Bi, 210Pb
226
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WASTE MANAGEMENT
KC Harvey personnel have decades of waste management experience ranging from the day to day management of exempt oilfield wastes, to solid and hazardous wastes regulated under RCRA, to large-scale CERCLA remediation programs. Our oilfield waste management services include: • Preparation of comprehensive oilfield waste management plans • Hazardous materials characterization, manifesting, TCLP testing • Environmental due diligence of landfills • Oversight and reporting of asbestos abatement • Landfarm design, permitting and operation • Innovative waste management concepts • Injection well permitting • Produced water management plans • Produced water treatment assessment Examples of our oilfield waste management project experience include: Oilfield Waste Management Plan, Encana Oil and Gas, USA, Riverton, Wyoming. Prepared a comprehensive waste management plan for oil and gas operations including management of used oil and oily liquids, non-hazardous and hazardous waste streams, hydrocarbon impacted soil, and solid wastes. Assisted with permitting two injection wells capable of disposing 5,000 BPD of production liquids. Developed standard sampling and monitoring methods for managing drill cuttings disposal to meet Wyoming regulatory guidelines. Provided production and midstream managers with information necessary to better understand issues related to waste management and advantages of waste minimization. Waste Disposal Environmental Investigation, Texas. KC Harvey personnel responded to a U.S. EPA Criminal Investigation Division (CID) inquiry regarding long term waste disposal practices. An anonymous complaint filed with EPA reported that drums with industrial waste were buried by a former property owner. The area was investigated using non-intrusive geophysical methods. The findings of the investigation and a response plan were recommended to the client and the EPA. Development and Deployment of Wastewater Land Application/Irrigation Systems for the Beneficial Use of Produced Water, Wyoming, Montana and Colorado. KC Harvey scientists and engineers pioneered the use of saline-sodic produced waters for irrigation of crops and forage in the western U.S. The scope of this decade-long program included research and development, individual project design, water chemistry assessment, project water balance modeling, screening and characterization of candidate sites, crop selection, soil amendment prescriptions, landowner negotiations, regulatory agency coordination and permitting, construction, system operation, and environmental monitoring. Over 3,000 acres of pivot irrigation systems were installed. For this innovative work, KC Harvey received a national award from the Soil Science Society of America.
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Troubleshooting of Oilfield Landfarm Operations, Green River Basin, Wyoming. KC Harvey soil scientists and bioremediation experts conducted a forensic assessment of multiple failed landfarming operations on well locations in the Green River Basin of Wyoming. Contamination levels had been static for over a decade at these facilities. Soil physical, chemical and biological characteristics were assessed and an improved bioremediation prescription was developed and implemented. The prescriptions were successful in rapidly degrading total petroleum hydrocarbons to below state cleanup levels in only one summer season. Review and Troubleshooting of Bioremediation Landfarm, Helena, Montana. KC Harvey soil and bioremediation experts carried out a technical review of a large bioremediation land treatment unit for a railroad client in Montana. Contaminants of concern include diesel fuel, lube oils and other petroleum hydrocarbons. The objectives of the project were to troubleshoot operations to optimize biodegradation rate and extent. Developed and implemented a plan for maintaining optimum soil moisture, oxygen and nutrient conditions for bioremediation that improved facility performance.
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AIR QUALITY PERMITTING, MONITORING AND REPORTING KC Harvey maintains an experienced air quality management team to serve our oil and gas clients in the Permian Basin. This team is led by a Master of Science level chemical engineer with decades of air quality related experience including emissions characterization, permitting and compliance monitoring. Our oilfield air quality practice integrates well with other environmental services and can add efficiency to larger fieldwide compliance and inspection programs. Our oilfield air quality permitting, monitoring and reporting services include: • Leak Detection and Repair (LDAR) – Method 21 • Development and implementation of Quality Improvement Program (QIP) • Visual Opacity Testing – Method 9 • Visible Determination of Fugitive Emissions – Method 22 • Preparation of air quality permit applications (NSR and PSD permits) • Directed Inspection and Maintenance (DI & M) • Development and implementation of Work Practice Plans • Ambient air quality monitoring • Air emissions inventories • Greenhouse Gas (GHG) Inventory and Mandatory Reporting Rule (MRR) assistance Examples of our oilfield air quality project experience include: Title V Permit Major Modification, Sunoco Refinery, Tulsa Oklahoma. The scope of work included a major modification to the facility’s Title V Permit as part of a $500 million process modification, leading to a comprehensive New Source Review (NSR) / Prevention of Significant Deterioration (PSD) Permit preparation for four criteria air pollutants. Tasks included ambient air quality impact analysis using EPAapproved air dispersion modeling techniques, BACT/LAER review, and Class 1 area impact analysis. Other air quality support activities included: liaison with local, state and federal regulatory agencies, development of corporate environmental management plans (EMPs) and programs, regulatory interpretation and application to facility processes, training, regular site visits, emissions tracking, file reviews at state and EPA offices, and report preparation. Emissions Inventory and Permit Review of Natural Gas Field, Green River Basin, Wyoming. Completed a field wide emissions inventory for a natural gas field that included over twenty multi well locations, two central facilities and a compressor station. Emissions sources were inventoried for each location to evaluate permit compliance. Equipment documented included glycol dehydration units, heaters, pneumatic pumps, tanks, flares, and combustors. Emissions from glycol dehydration units, and produced water and condensate storage tanks were modeled using current production data and product analysis. Total site emissions, including fugitive emissions were calculated for each location. Permitting issues including unpermitted sources and exceedance were identified. Recommendations for source reduction were provided where needed.
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Annual Emissions Inventory Reporting, Green River Basin, Wyoming. The Wyoming Department of Environmental Quality, Air Quality Division requires annual reporting for oil and gas production facilities. Minor source emissions inventories are collected every three years in accordance with 40 CFR Part 51,
Subpart A, or sites located in the Upper Green River Basin reporting is required on an annual basis. KC Harvey documented emissions from stationary engines, heaters, tanks, dehydration units, pneumatic pumps, fugitive emissions, venting and blowdown, drill rigs, completion and workover, truck loading and on-road mobile units. Detailed review of annual data was completed to finalize annual reports for submission to the Air Quality Division. New Source Review Permitting, Upper Green River Basin, Wyoming. Wyoming Air Quality Standards and Regulations (WAQSR) Chapter 6, Section 2(a)(i) New Source Review requires new construction projects, or construction projects modifying existing facilities or sources to undergo review and permitting. KC Harvey provided New Source Review (NSR) and permitting services for several operators in the Upper Green River Basin of Wyoming. Work was completed for both existing well locations and for new construction. Risk Assessment of Accidental Gas Release for Agip Energy – Eni, NG/Brass Operations, Nigeria. Conducted detailed environmental consequence analyses for unintended (accidental) gas release from two contiguous (33 mile) natural gas pipelines. The analysis included estimation of probability and impacts of pipeline failure, identification of possible zones of impacts, and estimation of worst- and alternative-case scenario environmental consequences in subsea and onshore environments. The project was consistent with the clients’s corporate Risk Management Program modelled after the USEPA/OSHA RMP/PSM programs.
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ENVIRONMENTAL DUE DILIGENCE AND AUDITING Clients retain KC Harvey to conduct environmental due diligence and audits of oil and gas assets because of our extensive on the ground environmental management experience in oilfields. We deliver accurate and practical information and advice regarding environmental, safety and social issues that may impact decisions and transactions related to mergers and acquisitions, financing and investment, initial public offerings (IPOs), divestitures and emerging technologies. Our sector-leading due diligence team will support your price negotiations by documenting environmental conditions, liabilities and regulatory compliance prior to closure of the transaction. In addition to the identification of existing liabilities, our team can identify posttransaction operational risks that may impact future environmental and/or social licensing and long-term value of the acquisition. Our environmental due diligence and audit services include: • ASTM Environmental Transaction Screens • ASTM Phase I and II Environmental Site Assessments • Rapid high level environmental, safety and social screening of acquisition targets • Tailored and comprehensive environmental, safety and social due diligence assessments • Identification of post-transaction operational risks • Tailored seller-side assessments to prevent erosion of deal value • Comprehensive environmental compliance auditing • Asset retirement obligation evaluation Examples of our environmental due diligence and audit project experience include: Pre-Transaction Environmental Due Diligence of Questar Natural Gas Production Assets, Wyoming, Utah and Colorado, for Dominion Resources Inc. KC Harvey was retained by Dominion Resources, Inc. (the “Buyer”) to conduct an expedited environmental due diligence review of multi-billion dollar oil and gas exploration and production (E&P) assets in the states of Wyoming, Colorado and Utah. The scope of this tailored review included (1) the evaluation of local, state and federal environmental regulatory compliance records and related matters associated with the E&P assets and operations and how any compliance issues may impact future operations, permitting and expansion; (2) review and analysis of existing environmental data and information related to the E&P assets and operations provided by the Seller through a “Digital Data Room” with respect to environmental management and future operations and expansion; and (3) review of data and reports prepared by the Seller regarding existing environmental conditions and liabilities with respect to the adequacy of the cost estimates for managing or remediating identified environmental liabilities. The scope of the review included air, land surface and subsurface, water resources, wildlife resources, soil and vegetation resources, waste materials and waste management facilities, and well locations and access roads. KC Harvey completed this time critical review in a total of ten days.
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Pre-acquisition Environmental Due Diligence, Bearpaw Natural Gas Production Area, Northern Montana, for Stinson Morrison Hecker on behalf of NorthWestern Energy (NWE) Company. NWE and Stinson Morrison Hecker (SMH) retained KC Harvey to perform environmental due diligence of selected natural gas facilities within the Bearpaw Natural Gas Production area. This area extends over four counties and is approximately 800 square miles. KC Harvey identified potential environmental conditions associated with over 1500 natural gas production wells, 25 midstream facilities, and 20 produced water
storage impoundments owned and operated by Devon Energy, NFR Bear Paw Basin, and several other smaller oil and gas companies. In addition to 450 field inspections, due diligence activities included a review of air quality operating permits, waste management program, SPCC program, stormwater management program, and agency notices of violation. Three comprehensive reports were prepared for the client prior to NWE’s final acquisition of the assets. This was the largest single acquisition of oil and gas assets in the history of Montana. Environmental Audit and Training Program, Key Energy Services, Inc., Texas. Developed an environmental audit and training program for company facilities. The audit program was developed to train company personnel the skills necessary to perform periodic audits necessary for SPCC and SWPPP compliance and company audit protocols. The training program was developed in an on-line format. Periodic on-site training was provided when requested or when necessary in response to specific incidents.
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SECTION 404 / WOTUS DELINEATIONS AND PERMITTING KC Harvey soil scientists, plant ecologists and hydrologists are trained, certified as necessary, and experienced at accurately identifying and delineating jurisdictional Waters of the United States (WOTUS) including wetlands for proposed oil and gas development projects. Our Section 404 / WOTUS delineations and permitting services include: • Screening level identification of jurisdictional wetlands and streams • Field delineation of jurisdictional wetlands and streams • Preparation of US Army Corp of Engineers Section 404 permit applications • Mitigation planning, design and implementation • Wetland monitoring and assessment
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Examples of our Section 404 / WOTUS delineations and permitting project experience include: Delineation of Jurisdictional Waters and Wetlands and Section 404 Permitting for the Proposed Dakota Access Pipeline, Energy Transfer Partners, South Dakota and North Dakota. KC Harvey was selected to carry out baseline environmental surveys, including the delineation of jurisdictional wetlands and other waters along several hundred miles of the proposed right of way for the controversial Dakota Access Pipeline. This massive project involved preparation of Section 404 permit applications and ongoing coordination with FERC and US Army Corp of Engineers to ensure that the pipeline construction schedule would not be impacted. KC Harvey completed this logistically challenging project on time and on budget. Delineation of Jurisdictional Waters and Wetlands and Section 404 Permitting for the Proposed Vantage Pipeline and Extensions, Pembina Pipeline Corporation, North Dakota. KC Harvey was selected by Pembina to assist with the preparation of a Presidential (US State Department) Permit for building a pipeline across the international boundary with Canada. The project scope included environmental baseline surveys, delineation of jurisdictional wetlands and other waters, Section 404 permitting, preparation of an environmental impact statement, PSC and FERC permitting, and environmental inspection responsibility during pipeline construction. KC Harvey was instrumental in helping the client receive a controversial Presidential Permit at the same time the federal government was considering the same permit for the proposed Keystone XL pipeline. Wetland Delineation and Section 404 Permitting, Antero Resources, West Virginia and Ohio. KC Harvey was tasked for the last four years with the delineation of wetlands and other WOTUS features, and preparation of Section 404 permit applications for proposed natural gas well locations and pipeline right of ways throughout West Virginia and Ohio development areas. Wetland Delineation and Section 404 Permitting, Triad Hunter, West Virginia and Ohio. KC Harvey carried out numerous delineations of jurisdictional wetlands and other WOTUS features. Section 404 permit applications were prepared and shepherded through the U.S. Army Corp of Engineers prior to natural gas well and pipeline construction.
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WILDLIFE AND ESA SURVEYS, MONITORING AND MANAGEMENT KC Harvey’s team of wildlife, aquatic and ecological scientists provide a full range of biological services to our clients operating in the Permian Basin, ranging from baseline habitat and population surveys to permitting and mitigation/restoration. In addition, we maintain a network of local consulting biologists who are experts in the species and habitats of the Permian region to augment our core team. Our wildlife survey, monitoring and management services include: • Federal and state protected species habitat assessment • Federal and state protected species presence or absence surveys • Baseline wildlife and habitat assessments, surveys, and analyses • Survey and monitoring of migratory birds, prairie chicken, and raptors • USFWS Biological Assessments and Biological Evaluations • Section 7 Consultation support • Section 10(a)(1)(B) Incidental Take Permit assistance • Fisheries and aquatic ecology • Radiotelemetry and tagging studies • Bat surveys including use of AnaBat™ • Fish and wildlife passage, and conflict and collision reduction • Habitat improvement, reclamation and restoration • Site ecological risk assessments • Conservation and habitat mitigation banking Examples of our wildlife related project experience include: NPL Project Area Vegetation and Sage Grouse Habitat Mapping, Upper Green River Basin, Wyoming. Developed and applied an innovative vegetation and sage grouse habitat mapping technique using remote sensing, field mapping, and GIS analysis. The methodology uses the definition of sage grouse habitat in the Wyoming Governor’s Executive Order for sage grouse protection updated in 2011. This was the first Habitat Assessment Framework (HAF) based predictive model for identifying habitats within Core Area suitable for development. The deliverables allow oil and gas operators to quantify habitat potentially impacted in different development scenarios. Greater Sage Grouse Monitoring, Pinedale Anticline Project Area, Wyoming. Shell, Ultra Petroleum, Questar. Trapped and installed GPS collars on 90 sage grouse as part of a two-year project to assess habitat selection and seasonal movement patterns and evaluate changes due to oil and gas development. Conducted lek surveys and monitored nesting success. Installed noise monitoring equipment to record and evaluate drill rig and compressor station noise levels. The comprehensive project report evaluated if threshold levels of sage grouse metrics were exceeded that would require changes to oil and gas development plans.
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Soils, Vegetation, and Sage Grouse Habitat Mapping, EnCana Oil and Gas (USA), Inc., Jonah Field, Wyoming. Completed a two year project using Quickbird satellite imagery and LIDAR elevation data to map soils, vegetation, and sage grouse habitat. The project included developing and testing analysis methods on a pilot scale, implementing remote sensing analysis for the entire gas field, incorporating
several years of field monitoring data as ground truth, and reporting results. In addition to creating framework soils and vegetation data layers, the project satisfied the BLM’s wildlife management plan requirement that operators map sage grouse habitat. Wind Development Wildlife and Ecological Assessments, Pathfinder Wind Energy, Natrona and Carbon Counties, Wyoming. KC Harvey completed a multi-disciplinary effort to develop wind energy resources including baseline data collection for soil, vegetation, water resources, and wildlife. Wildlife species included sage grouse, raptors, pronghorn, deer, elk, small mammals, songbirds, reptiles, and amphibians. Assessments were three year efforts to meet NEPA and Wyoming DEQ permit requirements. North Moneta Cooperative Sage Grouse Study, Multiple Oil and Gas Producers, Lysite, Wyoming. KC Harvey completed a sage grouse habitat study in a 180,000 acre proposed oil and gas production area in Fremont County, Wyoming. Included conducting lek, brood, and wintering habitat surveys on BLM, State, and private lands in designated Core Area using the Habitat Assessment Framework (HAF) (BLM, 2010) under the updated Governor’s Executive Order on sage grouse (2011). Project also includes development of a HAF based predictive model for identifying micro-scale habitats within Core Area suitable for development siting. Hogback Ridge and Slater Bordeaux Wind Development Wildlife and Ecological Assessments, Pathfinder Renewable Energy LLC, Wyoming. KC Harvey completed two multi-year wildlife and ecological assessments for proposed wind energy developments in Wyoming. Assessments included federal and state listed species including leks and wintering and brooding habitats for sage grouse under the Governor’s Executive Order and Wyoming Game and Fish Department (WGFD), U.S. Fish and Wildlife Service (USFWS), and BLM protocols. Assessments were three year efforts to meet NEPA and Wyoming DEQ permit requirements.
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FEDERAL LAND PERMITTING, COMPLIANCE AND RECLAMATION A large portion of the Permian Basin in New Mexico is located on federal land managed by the U.S. Bureau of Land Management (BLM). Proposed oil and gas development projects on federal land require review in accordance with the National Environmental Policy Act (NEPA). Unless a proposed activity is Categorically Excluded under NEPA from additional review, drilling or pipeline right-of-way projects may require an Environmental Assessment (EA) or Environmental Impact Statement (EIS) before they can proceed. In addition to NEPA review, there may be additional requirements on permitting for oil and gas development on federal lands. KC Harvey is known throughout the western U.S. for its expertise in environmental compliance and reclamation services for the oil and gas industry. Our federal land permitting and compliance related services include: • Baseline environmental surveys • Preparation of third party NEPA, EA and EIS documents • Preparation of APDs • Soil salvage and reclamation planning, design and implementation • Reclamation success monitoring Examples of our federal land permitting, compliance and reclamation project experience include: Continental Divide/Creston EIS, Baseline Surveys and Reclamation Plan Development. Bureau of Land Management, Rawlins, Wyoming. KC Harvey participated on a multi-disciplinary team developing an EIS for the Continental Divide/Creston 5000 well natural gas infill drilling project in south central Wyoming. KC Harvey was responsible for baseline soil and vegetation data collection, analysis, and reporting and developed the field wide reclamation plan for the EIS. Bear Paw South Natural Gas Project EIS, North Central Montana. Devon Energy Corporation, Montana. KC Harvey scientists served on a multi-disciplinary team for development of an EIS for expanded drilling in the 376,000 acre Bear Paw South natural gas field in north central Montana. KC Harvey was responsible for baseline data collection, analysis, and reporting of geology and minerals, water resources, soils and reclamation, vegetation and noxious weeds, and range resources. Natural Gas Field Reclamation, Wamsutter Natural Gas Field, South Central Wyoming. Since 2008, KC Harvey provided comprehensive science-based reclamation services to multiple natural gas producers operating on federal land in the 1.25 million acre Wamsutter natural gas field in south central Wyoming. This program covers more than 2500 well pad locations, pipelines, roads, and other facilities. Services provided include permitting support, pre-construction reclamation planning, soil management, reclamation monitoring, invasive plant control, reclamation seeding, erosion control installations, soil amendments, fertilization, and other reclamation practices. KC Harvey conceived and initiated this program, developed standard operating procedures, and has improved efficiency and reduced costs to clients over time.
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Reclamation Program Development and Implementation, Jonah Field, Encana Oil and Gas USA, Inc. Wyoming. KC Harvey reclamation scientists designed and implemented a first of its kind site-specific, science-based reclamation program across the Jonah natural gas field on federal land in western Wyoming. The scope of this multi-year project included soil physicochemical assessment, soil salvage planning and implementation, baseline vegetation inventory, forensic soil investigations, reclamation implementation, design and construction of irrigation systems, soil amendment prescriptions, and field-wide monitoring of reclamation success. All work was reviewed and approved by regional BLM officials.
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OUR clients KC Harvey has the pleasure and the privilege of providing consulting services to many of the world’s leading oil and gas E&P and midstream companies. In the Permian Basin, we currently have Master Service Agreements with the following oil and gas clients:
Pioneer natural Resources EOG Resources PDC Energy Encana Noble Energy
Hess Halcon Spectra Energy Energy Transfer Partners
In addition to our Permian Basin clients listed above, we have the privilege of serving the following oil and gas companies:
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ExxonMobil Shell Oil Company BP America Chevron Corporation ConocoPhillips Marathon Oil Encana Corporation Santos Ltd. EOG Resources Devon Energy Anadarko Petroleum Whiting Petroleum Continental Resources Hess Corporation Dakota Access Pipeline Energy Transfer Partners Mistral Energy Vantage Pipeline Pembina Pipeline US
Spectra Energy Noble Energy Antero Resources Aethon Energy Linn Energy Williams WPX Energy QEP Resources Questar Dominion Energy Fidelity E&P Co. RedLeaf Resources Southland Royalty Co. Breitburn Energy Partners Triad Hunter PDC Energy Halcon Eureka Hunter
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Contact Us For more information on how we might assist you with the production of oil and gas resources in the Permian Basin, please contact: Dan Gibson, PG
Permian Basin Operations Manager (432) 614-6096 [email protected] David Marshall, PG
Permian Basin Principal-in-Charge (406) 585-7402, extension 103 [email protected] 2
