Keeping our environment Always On.
CONSOL Energy has positioned itself as a top-tier environmental steward while successfully developing resources to supply national and global energy needs. We never stop identifying opportunities and implementing solutions that drive safety, production, and utilization of our strategic resources in smarter, more efficient ways.
We strive to operate in an environmentally sound, reliable and efficient manner. Furthermore, we recognize that both our environmental responsibilities go beyond those required under statutory obligations. That’s why we design and operate our business to exceed the expectations of our employees, communities, regulators and shareholders.
As a natural resource extraction company, we recognize the importance of environmental management, and we practice the responsible use of the land, water and air in our operational areas. Compliance with all environmental laws and regulations is not only expected, but is a condition of employment at CONSOL. Environmental excellence is our goal, and we plan and operate our businesses to ensure we meet the expectations of all our stakeholders.
Our Environmental Management System (EMS) provides a framework for the way we conduct our business and for continuous improvement in our management systems and performance standards as related to environmental compliance. Following a systematic approach of effective planning, review and corrective action, each of CONSOL’s operations assesses priorities and sets environmental goals and targets on an annual basis. Our team of HSE auditors monitors progress towards meeting environmental goals and targets throughout the year. All data relating to environmental performance is captured in our electronic data management system and reported to the appropriate regulatory authorities as required by state and federal guidelines. Our EMS was designed to be in compliance with the ISO 14001 standard.
CONSOL Energy Environmental Policy
The safety and health of our employees and contractors, and full compliance with the laws and regulations that govern our businesses, are CONSOL's top two core values. Therefore, we strive to conduct our operations to avoid adverse impacts to human health and to operate in an environmentally sound, reliable, and efficient manner.
We are committed to continuously improving our environmental performance and have established objectives to:
- Continuously improve compliance within our operating permits
- Avoid, reduce, or minimize the environmental footprint of our operations
- Maximize water reuse
- Reduce process air emissions
Our performance is monitored continuously and reported annually. Updates and corrections are made as business conditions warrant.
In 2015, CONSOL sold more than 5,179 tons of metal, 1,039 tons of mine belt, and 244 tons of other miscellaneous items as scrap. This recycling effort repurposed used materials, saved landfill space, and generated additional revenue for the company. In addition to the industrial materials recycled, nearly 79 tons of paper were recycled at our corporate offices.
Focus on Water Quality
The Federal Clean Water Act requires wastewater dischargers to have a permit establishing pollution limits, and specifying monitoring and reporting requirements. These wastewater permits, called National Pollutant Discharge Elimination System (NPDES) permits, regulate industrial point sources such as mine water discharges that flow directly into receiving waters. NPDES permits regulate wastewater discharges with the goals of protecting public health and aquatic life. All NPDES permits include site-specific effluent limits and compliance monitoring and reporting requirements.
In 2015, CONSOL had 141 NPDES permits with 732 discharge outlets across its mining operations. Each of these outlets has site specific monitoring requirements, usually bimonthly sampling, which equals thousands of opportunities for non-compliance with permit requirements. In 2015, CONSOL achieved 99.9% compliance with NPDES permit effluent limits.
Mitigation banking is a mitigation option that permittees can use to offset aquatic resource impacts by purchasing mitigation credits. These credits are established by a third party who performs stream or wetland creation, enhancement, restoration, and/or preservation activities at an off-site location. In turn, CONSOL purchases these credits to use in the mitigation of our mining activities.
CONSOL is one of the first energy companies to participate in mitigation banking in Pennsylvania. By purchasing approved mitigation credits for stream impacts of approximately 84,000 feet and wetland impacts of approximately 27 acres, we were able to obtain our refuse disposal permit, reducing long-term liabilities associated with mitigation monitoring, and maintenance while providing for adequate conservation of environmental resources. Purchasing mitigation credits provides efficiencies for both the company and agencies in preparation, review, and approval of permits.
CONSOL evaluated opportunities for mitigation banking by working directly with an approved mitigation banking company and our own land department to identify mitigation bank areas that were dedicated specifically to the Company’s long-term mitigation needs. By setting up mitigation banks to include CONSOL owned properties, time and resources were significantly reduced leading to substantial financial savings.
Biodiversity, defined as the variety and variability of life in an ecosystem, is often used as an indicator of the health of an ecosystem. Proper management of biodiversity is important to ensure the continued availability of suitable habitat for species survival and use as a natural resource for humanity.
CONSOL’s biodiversity policy focuses on habitat protection, impact avoidance, restoration, and compensation. We approach protection of biodiversity by first taking all possible measures to avoid impacts, then by going above and beyond requirements when performing mitigation of impacts. Where CONSOL operates in proximity to protected species or habitat, our approach includes early identification and clear delineation of exclusion zones and time frames for work. These are incorporated into project planning, and appropriate mitigation plans are developed and submitted to regulatory agencies for approval.
CONSOL utilizes our internal team of environmental professionals and our trusted environmental consultants to assist and train our planning and operational personnel on the importance of identifying and avoiding protected species and habitat. A good example of this planning is demonstrated in the approach we take with respect to conservation of bats, many of which are federally listed as either endangered or threatened species. Both the Indiana Bat and Northern Long Eared Bat are found within our operational area. CONSOL conducts bat surveys and incorporated the bats’ seasonal movements into project planning. In addition, CONSOL has constructed new bat hibernacula under the guidance of an outside expert with the approval of regulatory agencies. Some of the bat protection projects we were involved in for 2015 include:
- Paid $192,733 into the Indiana Bat mitigation fund for Pennsylvania pipeline and well site projects,
- Installed a bat condo on our West Virginia bat conservation area,
- Installed 26 bat boxes within an Indiana Bat occupation area in Greene County, Pennsylvania
- As part of gas and coal bat mitigation requirements, we began working with the Pennsylvania Game Commission to plan for the donation of approximately 1,700 acres for public game land use as part of a U.S. Fish and Wildlife Service (FWS) bat conservation area, and
- Paid $291,180 into the Indiana Bat Contribution fund in 2015 for Pennsylvania coal projects.
CONSOL Energy tracks the following metrics to report performance:
|E&P Operations NOV
|CONE Gathering LLC NOV
|Coal Operations** NOV
|Water Operations NOV
*Note: 2013, 2014, and 2015 data for our Coal Operations does not include data from our discontinued operations that were included in the assets sold to Murray Energy Corporation in 2013.
Our Performance in 2015
Our Gas Operations saw close to a 50% increase in violations due, in large part, to spills on our sites. In 2013, CONSOL introduced the Loss of Primary Containment Policy, which converts spill incidents into a spill incident rate. We began work with our contracting community to improve behavior and focus attention on spills and processes and procedures related to fluid transfers and containment. While we believe we have had great success with the program and overall releases from active/manned sites have decreased, we continued to see an increase in violations related to releases on unmanned/producing well sites. The majority of these releases were from on-site tanks and the releases were contained. These incidents are self-reported to the regulatory agencies and result in the issuance of violations. This upward trend again forces our eyes toward the preventative maintenance aspects associated with aging infrastructure and equipment. Process improvements from both internal policy as well as in accordance with new state regulation (centering on tank inspections) are expected to improve our compliance performance in 2016.
In the Oil, Gas & Energy Quarterly, 2016 publication, CONSOL was rated best in environmental performance out of 20 of our peer E&P companies. John Pendley, an Associate Professor of Accounting at Susquehanna University, utilized a formula developed to rank the nation’s E&P companies based on environmental impact. Professor Pendley normalized performance metrics; in this case the number of violations assessed by a given state regulatory agency, by the amount of hydrocarbon (Btu) the company produces. This allowed for a comparison of companies no matter their size or extent of E&P activity. Our Coal Operations had another record breaking year in terms of environmental compliance and have recorded our fewest environmental compliance exceptions since we started reporting. We remain steadfast in promoting environmental awareness, eliminating environmental liabilities, and training on environmental aspects for CONSOL and contract employees.
As a leader in environmental excellence we strive to continuously improve our performance. We have amended our employees’ Short Term Incentive Compensation (STIC) so that it contains an environmental performance metric to promote our core values of safety, compliance and continuous improvement. We have also implemented monthly contractor performance reviews in order to identify contractors displaying a pattern of repeated incidents. Performance reviews will be based upon safety and environmental incidents and may include an individual compliance meeting with contractors in order to set HSE goals for the contractor. HSE contractor performance reviews will play a key factor in ensuring that contractor, sub-contractor, and vendor partners maintain a high level of safety and environmental compliance. Outcomes of contractor performance reviews and intervention will help determine the contractors and service suppliers with whom we continue to do business.