When your civil works project is in the middle of the biggest oil and gas boom in the United
States and is located on one of North Americas main flyways for migratory birds, the
Environmental Compliance position that William D. Harlon III occupied until 2015 at the
Garrison Project can be pretty demanding. Though he only started at the Project in 2012 after
9 years at the Wilmington District and one year at the Savannah District, he managed to take
on dozens of compliance issues and resolve nearly all of them with the support of a great
In February 2015, Harlon was promoted to Environmental Compliance Coordinator for the
Omaha District, overseeing the compliance program for all civil works Projects in this colossal
district. This work load encompasses the 6 hydropower plants on the Missouri River from Fort
Peck in Montana to Gavins Point in Nebraska. Omaha District also covers 3 earthen dams in
the Denver, Colorado area, 2 earthen dams in the Black Hills of South Dakota, 2 earthen dams
in North Dakota, 14 earthen dams in Nebraska, and a levee system with a pumping plant in
Williston, North Dakota.
IAs the sole ECC at Garrison, Mr. Harlon was responsible for compliance at the third largest
reservoir in the nation. Garrison consists of 492,000 acres of land and water, 36 recreation
sites, numerous out-granted properties, and a large hydropower facility with five generating
units providing a total capacity of 583,000 kilowatts. In addition, Harlon was responsible for
two additional multipurpose dams, Pipestem and Bowman-Haley as well as a resource office in
Williston, North Dakota. As a prospective, each of the smaller field sites is located
approximately 3 hours from the primary administrative office in Riverdale, North Dakota.
When it comes to the oil and gas industry, the Williston Basin has experienced both boom and
bust in the past. The boom periods began in the early 1950s and then again when gas prices
spiked in the late 70s and early 80s. Since development began in the Williston Basin,
producers have drilled nearly 200 wells within Corps fee boundaries. Many of these wells were
dry or have been plugged and abandoned but there are approximately 70 wells still listed as
actively producing on Corps property. Many consider technological advances in
hydrofracking as the key to the current oil boom which began around 2006. The subsequent
surge in development correlated to a sharp increase of mineral leasing requests where the
Corps retained fee ownership on the surface. The Omaha District sought to streamline the
applicants review process by creating a new Oil & Gas Policy and Oil & Gas Management Plan.
Both the Policy and Plan are used as a means to follow a standardized process with all
applicants. Mr. Harlon actively participated with a group of professional peers from the Project
and District office during their development. The Plan was approved by Ms. Kathryn Schenk,
Omaha District Chief of Operations, in December 2013 and the Policy was approved shortly
thereafter by Colonel Joel R. Cross, District Engineer, in July 2014.
Simply overseeing the compliance Program for the typical operational activities at the 3rd
largest Reservoir in the nation is a full time job in itself. However, it is the work activities
associated with the oil and gas boom that posed the real challenge that consumed quite a bit
of Harlons time at Garrison. Additional duties from the oil & gas workload included working
with multiple agencies and responsible parties during spill events, communicating effectively
with industry seeking reclamation of historic facilities, and coordinating compliance inspections
Harlon worked with numerous public and private sector entities to ensure that the Garrison
Project met or exceeded Corps environmental standards. A few examples of his work stand
He worked with EPAs Region VIII Regional Response Team, along with a diverse cadre of
federal, state and tribal agencies to develop a spill response management plan to address the
region-wide potential for a significant oil spill into inland waters including Lake Sakakawea and
the entire upper Missouri River watershed.
Second, Mr. Harlon relentlessly pursued oil development companies that were seeking to close
out or reclaim old and antiquated facilities on Corps managed lands to ensure their procedures
met Corps reclamation expectations. Different producers obviously approach reclamation
differently but Mr. Harlon utilized effective communication to relay consistent expectations. Mr.
Harlon continues to seek a balance for implementing limited requirements with a common
thread of reducing the long term environmental liability to the Corps and ultimately to the
taxpayer. One particular project included a synchronized effort to reclaim multiple well pads
that were operated by SM Energy. Mr. Harlon worked with SM Energy and their consultant,
Pioneer Technical Services, to draft an acceptable sampling and reclamation plan. By the end
of the Project, SM Energy provided both surface and subsurface sampling, removed all
operational equipment, regraded the site to predevelopment topography, reseeded the site with
a mix of native vegetation, and even improved the drainage and added gravel to an access
road to a public shooting range and adjacent wildlife management area.
Finally, Mr. Harlon worked hard to ensure that the Garrison Project performed to meet
authorized purposes under rapidly evolving conditions, and he actively employed the ERGO
program to ensure compliance. Leading the local team at Garrison, Mr. Harlon worked
diligently at developing relationships with power plant, outside maintenance, natural resources,
administrative and other personnel to build an ad hoc compliance team. With managements
support for a culture of a proactive environmental compliance program, the entire Garrison
Team work together as additional eyes and ears for the compliance function. This is what
actually resulted in success at the Garrison Project.
The results of the internal assessments since 2012 have been outstanding. When Mr. Harlon
started in 2012, Harlons list of non-compliance findings numbered in excess of 100. During the
transition into his new role as District ECC, there were approximately 10 open findings
remaining. He attributes this success to the relationships that he has built and a Project staff
who is willing to work hard to implement corrective actions.
Harlons time at Garrison was hardly uneventful. One example included an incident where a
large explosion occurred at a hydrofracking chemical facility that was located just one block
from the USACE resource office in Williston. This incident occurred within days of the arrival of
a Corps ERGO Assessment Team from the Seattle District. The explosion and subsequent
response caused concern for contaminated air and water quality on adjacent Corps lands.
Needless to say, the visiting Seattle Team was astonished to see how even adjacent incidents
were impacting the staffs workload and Project purposes at Garrison. In many ways though,
that particular week was atypical in that Mr. Harlon had to coordinate with response agencies
and industry while trying to conduct a routinely scheduled ERGO assessment. Interestingly
enough, that particular week ended with Mr. Harlon being called to a second unrelated spill
from an oil & gas well pad located on Corps property about an hour and a half from Williston.
Additional examples of environmental concerns and coordination have included assessing
impacts from a nearby towns wastewater treatment facility and two large produced water
Harlon graduated from Penn State University with a Bachelors degree in Forest Science and
started his career at John H. Kerr Reservoir in the Wilmington District. He remembers a
conversation with Terry Ramsey, OPM at W. Kerr Scott. During the conversation Ramsey asked
Harlon, "When you retire, would you be content to have been only a forester? If not, I challenge
you to expand your professional duties within the Corps. Harlon responded to the challenge
by going on to work as a realty specialist for the Savannah District, a land use coordinator at
the Wilmington District, and then to accept the Environmental Compliance role at Garrison
Project, Omaha District.
Harlon says that his favorite part of his job is "building relationships at the District and
Project levels that help strike a balance between industry and Corps purposes. I never know
what each day is going to bring but it always goes back to those lynchpins.