Doing Things Right in the Powder River Basin

How Thunder Creek Gas Services, L.L.C. is Doing Things Right in the Powder River Basin 

Implementing industry best practices is better for clients, the community, and the environment.

The Powder River Basin (PRB) stretches from southeast Montana to northeast Wyoming within the northern Great Plains. Its rolling green grass and sage-covered plains serve as both a topographic drainage and geologic structural basin. The Basin is bordered by the Bighorn Mountains to the west and Black Hills Uplift to the east. To the south, it is framed by the Casper Arch, Laramie Mountains, and Hartville Uplift. In addition to being an important ecological treasure, the basin is rich in important resources like coal, crude oil, and natural gas.

PRB has been experiencing a resurgence in oil and gas production due to advances in horizontal drilling and hydraulic fracturing. These technological advances have made it a popular spot for companies to enter. The challenge for oil and gas companies is meeting the demand while also considering landowners, the environment, state and federal agency requirements, and a constantly changing regulatory landscape.

One company, Thunder Creek Gas Services, L.L.C. (Thunder Creek) has been in operation in the Powder River Basin of Wyoming since 1999 and has been a subsidiary of Meritage Midstream for 7 years, providing oil and gas producers gas gathering and processing services. Thunder Creek’s services include natural gas gathering, compression, treating, processing and transportation.  

One of Thunder Creek’s biggest challenges is meeting their producers’ needs, schedules and budgets while also satisfying landowner requirements and multiple agency requirements (Wyoming Game and Fish Department, Wyoming Department of Environmental Quality, Wyoming State Engineers Office, BLM, USFWS, U.S. Army Corps of Engineers, Wyoming SHPO). Agency requirements may conflict with producer needs/schedules/budgets. And Thunder Creek often has a short window to build and get a pipeline tested and operational. Balancing all those factors is a delicate dance.

Given the schedule and cost restraints associated with their projects, it seems counterintuitive that an oil and gas company would focus so much of their attention on environmental concerns. And yet, that’s exactly what Thunder Creek is doing. Over the years, Thunder Creek has developed its own system of best practices in order to protect natural and cultural resources and water systems. Why? Because they have learned that proactively doing things the right way best serves clients, the community, stakeholders, and the environment in the long run. Here’s how:

Powder River Basin System and Project Scope

The Thunder Creek pipeline gathering system covers nearly the entire PRB. The PRB is drained by two major systems—the Powder River drainage basin, which flows generally north into the Yellowstone River, which then joins the Missouri 

River; and Cheyenne River Drainage Basin, which flows east-northeast into the Missouri River. These drainage basins and their tributaries are home to numerous natural and cultural resources, including bald and golden eagles, ferruginous hawks and other raptors, greater sage-grouse, and Ute ladies’-tresses; prehistoric and historic settlements and activity areas including prehistoric open camps and stone circle sites, and lithic scatters, and historic homesteads, ranching complexes, mining-related resources, trails, and roads.

While a few of their projects have involved federal lands and have thus been subject to very defined permitting requirements, the majority of Thunder Creek’s projects are located entirely on private or State of Wyoming-managed land, and do not involve a federal surface management agency. SWCA provides a full range of environmental regulatory and compliance services for Thunder Creek’s projects, including natural and cultural desktop analysis and field surveys; SWPPP permitting, inspections, and reporting; and BLM and USFS permitting, when a federal nexus is involved. Thunder Creek has worked with SWCA to craft a robust environmental program for their PRB system that ensures full compliance with federal and state laws and regulations, including the Clean Water Act, Endangered Species Act, Migratory Bird Treaty Act, National Historic Preservation Act, Wyoming State Executive Order on Greater Sage-grouse, and Wyoming stormwater regulations.

• “More than 200,000 miles of pipeline crisscross our country. Generally buried underground, they are the safest and most efficient way to move large amounts of natural gas, crude oil, and related products. These are the products we depend on every day to heat our homes, generate electricity and cook our food. Pipelines also reduce air and water pollution by eliminating the need for trucks and ships on our roads and waterways.” -Meritage Midstream website

Being Good Land Stewards and Neighbors

The nature of Thunder Creek’s work means that they will have a presence in the PRB for years to come. They realized that not only should they consider their current environmental requirements, but that they should also look further down the road. As Thunder Creek’s Associate General Counsel and Vice President of Land, Kate Broome explains, “The core of the Thunder Creek pipeline system was built over the last several decades across family ranches that still exist today. Taking care of the land and maintaining good working relationships with these ranches over the last two decades has been beneficial to our ability to conduct current and future business.”

In fact, Thunder Creek’s corporate values statements include being good neighbors: “We are guests on the land and must be good stewards of the environment. We work closely with landowners and strive to have a positive impact on the communities where we work by supporting local businesses and nonprofits.”

But what exactly does it mean to be a good steward and neighbor? “We have over 1,600 miles of gas gathering and 

residue pipelines and 118 miles of NGL pipeline with a total processing capacity of 380,000 Mcfd.  This makes us the largest natural gas midstream company in the Powder River Basin” says Adam Schorger, Survey and GIS Manager. Thunder Creek’s projects are located on land owned by almost 250 different landowners. Thunder Creek’s environmental and land departments have spent countless hours cultivating relationships with landowners and other stakeholders. Thunder Creek uses their strong environmental program to demonstrate their commitment to being good neighbors and land stewards – laying down matting in wet areas to prevent rutting and erosion issues, avoiding construction during critical wildlife time periods to avoid wildlife disturbance and rerouting pipelines to protect historic properties.

Good communication with the landowners minimizes maintenance in the long run and quickly gets the land back in working condition, Broome says, “so, our approach not only positively affects our bottom line over time, but also creates a positive working relationship with the landowners.”

How to Establish Industry Best Practices

Thunder Creek has realized over the years that it’s more cost and time effective to enact solutions (like avoidance or mitigation) voluntarily and not always wait for an agency to direct them. They know that if they implement best practices (like raptor nest avoidance, for example), future changes in regulation or enforcement may not impact them because they’re already doing it.

“Thunder Creek has a list of values that we embrace that include both “Integrity” and being a “Good Neighbor.” We believe respecting cultural landmarks and the wildlife aligns with both of these core values. Industry Best Practices such as active mitigation and avoidance have been imbedded in our workflows, and this demonstrates our commitment to being good stewards of Wyoming and its diverse resources.“

-Engineering Manager, Dain Santarelli

Here are a few examples of best practices in action for natural and cultural resources:

• For compliance with the Bald and Golden Eagle Protection Act (BGEPA) and Migratory Bird Treaty Act (MBTA), Thunder Creek has SWCA do desktop analysis, field surveys, and construction monitoring for eagle and raptor nests. Wyoming 

  

   has various sources of data on eagle and raptor nest locations, which are very helpful in quickly identifying projects that could potentially impact these species. If nests are identified in a desktop analysis or field survey, Thunder Creek will first try to reroute its project to stay outside of the buffer distance recommended by USFWS Wyoming Ecological Services Office. If avoidance isn’t possible, Thunder Creek will follow USFWS seasonal timing recommendations, meaning that they won’t construct during the breeding/nesting season period that USFWS recommends for each raptor/eagle species. Thunder Creek follows these recommendations to be protected in case the regulatory situation changes in the future and incidental take of migratory birds is considered prohibited again. If Thunder Creek cannot avoid or restrict their construction schedule, then they commit to construction monitoring (and often post construction monitoring) of active eagle and raptor nests. SWCA sends avian biologists to monitor nests that are within a certain distance of active construction. If the avian biologists observe any behaviors that indicate potential disturbance, then Thunder Creek works with SWCA to come up with a mitigation strategy to get the project done while still protecting the resource.

• For waters of the U.S. (WOTUS), when weather conditions or land access restrictions prevent full delineations of potentially jurisdictional WOTUS crossings (and subsequent threatened and endangered species assessments and historic property evaluations), Thunder Creek will either bore the crossing or reroute the project to avoid the crossing. This prevents any surface disturbance of potential WOTUS. Boring can be expensive, but Thunder Creek would rather pay that cost than accidentally impact an unevaluated area that potentially contains a wetland. 
  • When Thunder Creek uses Nationwide Permit 12, they make sure to follow all general and regional permit conditions, including having SWCA perform field surveys to make sure general conditions 18-21 for endangered species, migratory birds, bald and golden eagles, historic properties, and artifacts are met.
• Thunder Creek understands that cultural resources throughout the PRB are important to landowners and other stakeholders, and has made it a practice to protect known historic properties and sites of potential traditional or religious cultural significance to Native American tribes through avoidance by reroutes or boring. Their understanding is that landowners and the community are aware of such resources and want them protected.
• Several historic trails bisect the PRB. The National Register of Historic Places-listed Bozeman Trail trends north-south through the full extent of the PRB. Associated recorded trail segments have been determined to either contribute or not contribute to the trail’s overall eligibility. When projects involving no federal nexus (and thus no federal protection for cultural resources) overlap this trail, Thunder Creek’s preferred action is to reroute for avoidance of the trail. If not possible, they reroute to cross a non-contributing segment of the trail. In rare cases where this is not an option—only twice in the past 4 years—they bore a significant depth beneath the trail so that the surface and any potential subsurface cultural material remains intact. This is done with the assistance of SWCA’s cultural resource specialists who determine adequate avoidance entry and exit locations and monitor these activities to ensure no physical impacts occur.

Looking Ahead

By being proactive about their environmental work and using industry best practices, Thunder Creek has avoided many resource issues and surprises for their projects. They’ve already accounted for them and taken steps to mitigate them. Hayden Truscott, EHS Manager, says “Our pipeline projects and well connects team has developed over time. The team now consists of a group of professionals with a variety of expertise who review and approve each project. The team completes a pre-job check list prior to initiating construction activities. The checklist helps us to identify potential environmental impacts and any issues that have been identified concerning historical or culturally sensitive sites. This allows the team to make the appropriate decisions and potentially any reroutes to ensure that we mitigate any compliance issues that could arise on a construction project.” They recommend this approach to other companies wanting to do long-term work in one geographic area. You can juggle your own needs with clients and stakeholders and the environment. It may require more time up front, looking at desktop analysis, looking at potential sensitive cultural and natural resources, and creating plans to address them. But the payoff is long-term success on multiple fronts.