COMPLYING WITH THE NEW OSHA SILICA

STANDARD – OIL AND GAS OPERATIONS

AIHA Rocky Mountain Section

Fall Technical Conference – Silica Panel – September 20, 2016

Pablo Sosa, CSP

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Introduction

► Name: Pablo Sosa

► Occupation: Consultant with Bureau Veritas

► Certification: Certified Safety Professional

► Background: Retired Air Force Veteran. Worked various Health Safety and Environmental roles in Aerospace, Manufacturing, Oil and Gas, and Research and Development labs.

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Overview

► Present a timeline for Oil and Gas Operations from 2011 to 2013 leading up to changes with the Silica Standard.

► Provide Initial Monitoring Data

► Provide Controls Attempted and results

► Provide Engineering Control from Sierra Dust Control which helped achieved compliance.

► All monitoring was done using an aluminum cyclone. The exception is the OSHA monitoring which used a Dorr Oliver. All results were compared against a calculated PEL and the New OSHA Silica PEL of 50 ug/m3.

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Oil and Gas Operations – Prior to New Standard

► Our company anticipated changes to the OSHA Silica Standard and knew that we had to look at exposures and quantify them.

► From 2011 to 2012 we performed monitoring during cementing operations and hydraulic fracturing operations.

► Cementing Operations

- Area Air Samples were taken on cement trucks where

operators controlled the flow of cement into the batch

mixer truck and in the batch mixer area.

- Personal air samples were taken on Batch Mixer

operator and Cement Truck Operators.

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Oil and Gas Operations – Prior to New Standard

► Hydraulic Fracturing

- Area samples were taken on the mountain movers,

T-Belt, Blender Hopper, and Sand Castles.

- Personal air monitoring was taken on mountain mover

operators, T-Belt Operator, Blender Operator, and

Employees working in the area around hydraulic

fracturing operations.

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Initial Sampling Results

► Initial Sampling Results for Cementing and Hydraulic

Fracturing Operations varied.

► Cementing Operations indicated levels above a calculated

PEL for Respirable Crystalline Silica for the Batch Mixer

Operator.

► Hydraulic Fracturing Operations indicated levels above a

calculated PEL for Respirable Crystalline for all

employees associated with hydraulic fracturing operations.

► Anticipating changes to the Silica Rule we also knew we

would be above the proposed PEL of 50 ug/m3.

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Implementing Controls – Cementing Operations

► Cementing Operations

- We knew our sample results showed approximately one

to one and half times above a calculated PEL for the

Batch Mixer Operator.

► Controls Implemented:

Engineering – A water jet was introduced into the

configuration of the batch mixer which keep

the dust down.

PPE – Respirators were required for Batch Mixer until

further monitoring conducted.

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Implementing Controls – Cementing Operations

► Air Monitoring was re-accomplished and levels of

respirable crystalline silica measured were Non-Detect.

► However, Batch Mixer still used respirator because of

caustics in cement additives.

► Monitoring continued to be performed for several

cementing operations and various locations throughout

the U.S. and showed levels below the calculated PEL and

new PEL for respirable crystalline silica.

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Implementing Controls – Hydraulic Fracturing

► Air Monitoring results revealed exposure levels to Silica

ranging from 4 to 15 times above the calculated PEL for all

operators involved in the fracturing process.

► Initial Controls:

Engineering – Company would start looking at options

available and begin to explore.

PPE – Employees were placed on Respiratory Protection

Program and provided respirators.

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Implementing Controls – Hydraulic Fracturing

► In 2013 received citation from OSHA for failure to explore

and implement Engineering controls.

► Going forward we tried numerous controls such as:

- Automating sand deliver process to the T-Belt using an

infrared reading eye.

- Result was automatic eye would fail occasionally

causing sand to spill and during evening operations eye

was difficult to operate because a light source needed to

be shined on it.

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Implementing Controls – Hydraulic Fracturing

- Powered Air Purifying Respirators were also provided to

employees to try.

- Result was the difficulty T-Belt Operators had when

attempting to observer sand being delivered to the

hopper. Additionally, temperature extremes would have

an affect on battery life, etc.

- Misting systems to wet the sand and keep dust levels

down.

- Air monitoring results showed the misting system was not

effective in reducing silica levels below calculated and

proposed OSHA Silica PEL. Additionally, the system

requrired cranes to be utilized to put in place.

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Hydraulic Fracturing – Effective Engineering

Controls

► After approximately a year of attempting to find an

effective engineering control for hydraulic fracturing

operations we worked with a contract company to

configure dust control for our operations.

► The contract company had a proven track record of dust

control operations and was willing to work with our team to

solve our problem.

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Hydraulic Fracturing – Engineering Controls

► Sierra Dust Control would work with our team to evaluate

hydraulic fracturing operations and develop a solution.

These are examples of engineering control implemented.

Dust Escaping Mountain Mover Prior to Dust Control

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Hydraulic Fracturing – Engineering Controls

Dust Control on Three Movers and Blender

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Hydraulic Fracturing – Engineering Controls

Dust Control On Sand Castles

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Hydraulic Fracturing – Engineering Controls

Dust Control on T-Belt and Hopper

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Hydraulic Fracturing – Engineering Controls

Dust Control on T-Belt and Hopper - Night Operations

LED Inside Cover Inside T-Belt

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Hydraulic Fracturing - Results

► Air monitoring was conducted during operations with the

controls implemented. New results showed exposure

levels below the calculated PEL and proposed OSHA

Silica standard.

► OSHA decided to conduct monitoring on our site to see

effectiveness of new controls.

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Conclusion

► Engineering controls provided by Sierra Dust Control

worked. Air monitoring was conducted for various types of

configurations on well pad, environments (i.e. snow), and

operations (i.e. Sand Castles versus Mountain Movers).

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Contact Information – Indoor & Outdoor Dust Control

► Sierra Dust Control – Booth At Conference or

303-655-8633

www.sierrafracsand.comwww.sierrafracsand.com