Consistent with our Values, LINN is dedicated to minimizing our impact on the environment. We adhere to an Environmental, Health and Safety (EHS) commitment that guides all of our activities. This commitment helps us earn the trust and respect of our employees, business partners, government agencies and communities. Protecting the environment is also of personal importance since many of our employees and their families live and recreate in or near the areas where we operate.
LINN is committed to reducing spills of any kind. Our goal is to operate safely in order to protect our environment, employees and community members.
LINN takes great pride in our commitment to responsible environmental stewardship. Protecting air quality is an important element of this commitment and we work hard to manage air emissions across our operations.
Environmental, Health and Safety Commitment
- Comply with all applicable EHS laws and regulations
- Adhere to our EHS commitment through demonstrated leadership and the application of appropriate resources
- Assign responsibility and accountability for EHS performance by setting quantifiable goals, tracking progress and reporting results
- Anticipate and manage risk through business processes that emphasize prevention, while also preparing us to effectively respond in the event an incident occurs
- Train our employees to conduct safe and environmentally sensitive operations
- Require all contractors and other parties engaged in activities on our operated properties to comply with our standards as well as all applicable EHS laws and regulations
- Conduct reviews and evaluations of our assets and operations to identify hazards, verify compliance and continuously improve EHS performance
To see our “Contractor Environmental Health and Safety Requirements”, please see Contractor Environmental Health & Safety Requirements.
For more information on LINN’s product safety information, please visit our SDS page.
We take a long-term view of our operational integrity — striving to have the safest and most efficient and effective operations possible. LINN complies with all federal, state and local spill reporting requirements. We track the quantity, cause and impact of a spill, even those that fall below state or federal reporting thresholds. Tracking our performance allows us to monitor trends and continuously improve our processes. We also evaluate and upgrade, as necessary, the infrastructure and facilities of our properties to ensure they are mechanically sound and in compliance with applicable regulations. Our operations approach is also adapted to address the unique characteristics of each area.
LINN has been working to reduce both the number and volume of spills across our operations for the last several years. We have assembled transformational teams in our assets to focus on spill reduction. These teams carefully evaluate the reason for any spills and methods to prevent recurrence. Where needed, infrastructure is prioritized for upgrades. Human factors are minimized and additional failsafe controls are utilized.
In an effort to elevate our spill management processes, we developed annual progress and corrective action plans to identify potential issues. For example, in 2011, we created a spill reduction strategy that is updated annually. Supervisors are encouraged to solicit input from operators to develop area-specific strategies and innovative methods to manage spills. An example includes team “leak hunts,” where employees inspect our facilities to identify potential leaks and maintenance opportunities. The lessons learned from these “leak hunts” are shared across operating areas in an effort to prevent future leaks at any of our facilities.
Additionally, we have developed and/or implemented:
- Spill Prevention, Control and Countermeasure (“SPCC”) Plans: LINN creates site-specific SPCC Plans that highlight items such as site design, training, inspections and response procedures.
- Inspections: LINN employees conduct regular facility inspections to identify potential problems before an incident occurs. We utilize various best-practice methods to conduct inspections such as the American Petroleum Institute Guidelines and Production Facility Guidelines.
- Training: Employees and contractors receive training on Company spill policies, strategies, practices and standards, as well as federal and state regulations.
Spills and Emergency Response
If a spill occurs, our employees and contractors are trained to respond to the incident and abide by all regulatory reporting requirements. In severe cases, we initiate emergency response procedures. Our response to severe spills is often guided by our site-specific Emergency Response Plans (“ERPs”). The purpose of ERPs is to create a standardized approach to managing emergencies in order to provide a safe, effective, coordinated and uniform response. These plans include critical information such as a suggested response to specific types of emergencies, a quick reference for emergency levels, contacts and response guidance, an explanation of our Incident Command System and response plan maintenance.
Emergency Response Trailers
In 2014, the EHS Committee working in the Brea field in California set out to make emergency response more effective and efficient. Historically, emergency response supplies, including those for spills, had been stored in bins onsite. However, getting the necessary supplies required multiple trips to and from the bins. To improve our response process, the Brea facility invested in an emergency response trailer stocked with hay bales, oil booms, saw dust, sprayers, oil pads, shovels and rakes, lights, gloves, boots and other equipment. In the event of an incident, the trailer can be quickly hitched to a truck and taken directly to the site until the designated response crew can arrive.
At the core of our efforts, we manage all of our facilities to comply with local, state and federal requirements. To do this, we maintain a corporate team dedicated to air quality compliance and employ additional experts and consultants at our field locations as needed. At LINN, we expect all of our employees and contractors to be responsible for environmental compliance and the execution of Company best practices documented in our new facility guidelines, field operations manuals, air quality standards and other protocols.
Specific air quality regulations can differ from state to state. Each facility is responsible for maintaining proper permits and reporting annual greenhouse gas emissions and other air quality-related data to state and federal agencies. Rapidly changing rules and regulations require effective communication to appropriate employees. The Environmental, Health and Safety (“EHS”) Department prepares summaries of rule changes for transmittal to operations personnel and EHS staff. This allows our employees to evaluate the applicability of the new rules to their operations and equipment and take the necessary steps to become compliant.
Participation in Air Quality Studies
To best manage the Company’s impacts on air quality, we must first understand the nature of those impacts. We have participated in a number of programs designed to help assess the potential air quality impacts associated with oil and natural gas operations. LINN participated in the natural gas pneumatic controller study sponsored by the Oklahoma Independent Petroleum Association to determine the number, types and associated emissions of different controllers (low continuous bleed, high continuous bleed and intermittent bleed) commonly found at oil and gas production facilities in Oklahoma. The results were shared with the Oklahoma Department of Environmental Quality for their use in evaluating the need for additional regulation and reporting.
We voluntarily participated in Wyoming Department of Environmental Quality (Wyoming DEQ) studies on produced water tank volatile organic compound (“VOC”) emissions and winter ozone air testing. LINN provided the Wyoming DEQ with sites to monitor. These studies are designed to provide the Wyoming DEQ with meaningful data on which to base regulatory strategies.
Emissions Reduction and Energy Conservation Initiatives
Our goal is to minimize emissions whenever feasible. LINN has implemented several pollution control measures aimed at mitigating air emissions from our facilities:
- We utilize vapor collection and recovery units (“VRUs”) at some locations to recover production gas, which contains primarily methane and sometimes VOC emissions. Natural gas venting sources are assessed for the potential use of VRUs or combustors to control emissions.
- Where feasible, we utilize electric motors rather than higher-emitting field gas engines.
- At our fields in Brea, California and Jonah, Wyoming, we generate electricity onsite via natural gas fired turbines. Similarly, we use microturbines driven by production gas produced onsite to generate electricity. While more costly, these measures result in significant emissions reductions.
- At many of our fields, we have achieved cost savings and emission reductions through the use of solar panels to power our well-site automation system that transmits data on our production, emissions and well equipment.