LINN has a growing portfolio of long-life oil and natural gas assets. Consistent with our Values, we are dedicated to minimizing our impact on the environment. LINN adheres 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. For more information about health and safety at LINN, please see our People pages.
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. Since we typically acquire mature properties, the infrastructure and facilities of these properties are evaluated and upgraded as necessary 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 2014, we reduced the frequency of spills by 15 percent company-wide. Three of four divisions experienced reductions between 22 and 24 percent. These improvements are significant because they have been attained during a year in which we integrated several new assets into LINN processes. As the assets are integrated, we placed a heightened focus on spill minimization.
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:
- Production Facility Design and Construction Guidelines: These guidelines establish expectations for the environmental and safety aspects of designing and constructing production facilities owned and operated by LINN.
- 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.
Contractor “Good Catch”
The use of contractors is vital to our business, and we expect them to adhere to the same rigorous safety and environmental standards as our employees. In 2014, a contractor noticed a distant patch of snow at our Piceance, Colorado operations that was different in appearance than other snow in the surrounding area. The contractor immediately shut down work and inspected the area. Upon further investigation, the contractor determined that the difference in appearance was due to a leak. Thanks to his quick thinking and proper responses, the volume of the leak was minimized and the site was quickly remediated.
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. While the Brea facility has not had to deploy the trailer, test runs show that it should reduce response time and makes the process for containing incidents more organized and effective. The success of this initiative led to additional trailers being assembled at some of our assets in the Rockies.
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. T
To help bolster our compliance efforts and to stay informed about the latest air quality regulations, we participate in a number of trade associations. Participation in these groups allows us to engage with our peers to solve common challenges, to champion industry best practices and to provide opportunities to share lessons learned from our own operations. We actively participate in the following organizations, among others:
- American Exploration and Production Council (AXPC)
- California Independent Petroleum Association (CIPA)
- Colorado Oil and Gas Association (COGA)
- Independent Petroleum Association of America (IPAA)
- New Mexico Oil and Gas Association (NMOGA)
- Oklahoma Independent Petroleum Association (OIPA)
- Petroleum Association of Wyoming (PAW)
- Texas Oil and Gas Association (TXOGA)
- Western Energy Alliance (WEA)
Participation in Air Quality Studies
To best manage our impacts, 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.
Additionally, we support several industry studies focused on air quality. LINN is a sponsor of an ozone monitoring station in Utah’s Uinta Basin. The station helps the Environmental Protection Agency and the Utah Division of Air Quality track ozone concentrations in the basin and determine the need for supplemental regulations. The study’s outcomes will help us target emissions control measures effectively and efficiently.
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.
Case Study: Wyoming
LINN’s operations in Wyoming’s Jonah Field are within a designated Ozone Non-Attainment area and therefore must comply with stringent air regulations. This designation results in stricter regulation of nitrogen oxide and VOC emissions; which are precursors to ozone formation. LINN implements a rigorous testing and inspection program to keep equipment operating within permitted limits. LINN applied for and received a “Voluntary Air Permit” for our drilling operations, under which we committed to the installation of a Selective Catalytic Reduction system as well as quarterly emission testing of these engines. This technology reduces the nitrogen oxide emissions of these diesel engines. We also have a dedicated employee working to inspect our production locations using Forward Looking Infrared cameras to detect natural gas leaks around flanges, valves, tank hatches, etc. so they can be repaired as soon as possible.
Case Study: California
Production from LINN’s California assets comes primarily from “heavy oil” reservoirs that require the injection of steam to stimulate the oil recovery process. LINN utilizes both conventional steam generators and cogeneration units to produce the steam energy required for heavy oil production. While both processes are highly efficient, LINN’s utilization of cogeneration units, or combined heat and power generation, provides more sustainable benefits and a greater reduction of overall emissions than conventional units. LINN’s cogeneration units make use of what would otherwise be waste heat from electricity generation to create steam. They are net energy producers, producing approximately 91 megawatts (“MW”) of electricity, of which roughly nine MW are utilized onsite, with the remaining estimated 82 MW supporting California’s regional electric grid. For comparison, generating the volume of steam produced by LINN’s three cogeneration facilities would require the use of eight conventional steam generators, which consume, rather than produce, roughly two MW each. Thus, one process generates two beneficial products by providing electrical energy to the grid rather than drawing from those resources, while also producing steam that reduces LINN’s production costs. LINN also complies with the regional Cap and Trade program in California, purchasing emissions credits to fuel production growth.