Emergency Response Concerns Related to 5.8 of the Sandoval County Oil and Gas Draft Ordinance

Letter the Chief of Sandoval County Emergency Management

Assistant Chief/Emergency Management

The Sandoval County Fire Chief has indicated in public meeting that the SaCo Fire Dept. and personnel are trained and equipped to respond to all oil and gas industry emergencies in order to protect the health safety and general welfare of the public. The current County Oil and Gas Ordinance Draft includes; 5.8. Emergency Response Plan. The applicant shall submit an Emergency Response Plan identifying all fire, police, and emergency response services in the County that are closest to the well site as well as a description of standard operating procedures, including applicable health, safety, and environmental protocols, used by the operator in the event of emergencies. The Emergency Response Plan must include a section for fire protection and when the permittee will call emergency responders. The Planning and Zoning Division Director or designee shall convey the Emergency Response Plan to the Fire Department Fire Chief or designee for review and may revise as needed. The Fire Department Fire Chief or designee shall issue a determination to accept or deny the Emergency Response Plan within 30 days. The applicant may file for a Variance on the determination of the Fire Department Fire Chief or designee to the Planning and Zoning Commission. In the event that the Fire Department Fire Chief or designee does not provide a determination on the submitted Emergency Response Plan to the applicant within 30 days, via electronic email and/or certified mail/return receipt, the Emergency Response Plan shall be deemed approved.

This ordinance Section raises numerous concerns with the public and seems wholly inadequate as an inclusion in Sandoval County Law. Shouldn’t 5.8 also include SOP’s by which the County will evaluate the Emergency Response Plan and capabilities of the applicant, so that the public, the County and the applicant can know prior to submission what will be expected? Is it even possible or practical to expect that the Fire Chief or you as the Assistant Chief/Emergency Manager can adequately investigate the real capabilities of an applicant in 30 days. I am just not convinced that the Fire Chief has properly assessed the potential ramifications of this section of the ordinance to his responsibilities and to the public safety.

In addition to the preparedness of the applicant, there are obvious public concerns regarding the abilities and the preparedness of the Sandoval County Fire Department with regards to all things related to the oil and gas industry. I have included just a preliminary list of concerns that the public needs to be assured on.

  1. SOP’s
  2. Existence and positioning of well control equipment.
  3. Emergency response equipment and personnel deployment protocol.
  4. SaCo well controls Emergency Plan.
  5. Requirements and costs of all necessary training and equipment upgrades.
  6. Stationing locations of individuals with adequate well design and chemical training.
  7. Sight design and access capabilities of SaCo personnel.
  1. Periodic site inspection requirements.
  2. Chemical storage requirements.
  3. Chemical and site specific suppression and response deployment plans.
  4. Number of SaCo personnel increase required per well application.
  5. Requirements by SaCo on the safety regulations for well pad personnel.
  6. Has an impact assessment been performed for SaCo regarding anticipated changes affecting inthe County?
  7. Does the county have monitoring equipment available in case of chemical leaks and spills?
  8. Hydrogen Sulfide detection and mitigation procedures.