New California Storm Water Regulations and the Impact on Oil and Gas Exploration and Development

With recent Ninth Circuit Court of Appeals decision requiring oil and gas producers to comply with the Clean Water Act, the oil and gas industry must now follow National Pollutant Discharge Elimination System (NPDES) requirements including construction storm water permitting. Our presentation will discuss the impacts of regulations required by the State of California Construction General Permit (CGP) for storm water runoff associated with oil and gas exploration and production activities that may cause storm water runoff and effluent discharges into surface waters. As of July 1, 2010, these regulations apply to all construction projects that disturb soil greater than one acre associated with exploration and production, including drill site preparation, the movement and placement of drilling equipment, including access roads and pipeline installation. CGP storm water monitoring requirements are based on Risk Levels (1, 2, & 3) for traditional sites such as drill pads and roads, and Type Levels (1, 2 &3) for Linear Underground/Above Ground (LUP’s) pipelines and overhead utilities. Monitoring may include field pH and turbidity measurements, suspended sediment, concentration, and non-visual pollutants three times per day during rain events. Numeric Action Levels and Numeric Effluent Limits have been set for pH and turbidity. Required Best Management Practices (BMP’s) and good housekeeping practices at drill sites will be discussed that could aid in maintaining the runoff from pre-to post construction condition. As of September 1, 2011, new professional certifications are required to prepare the construction project Storm Water Pollution Prevention Plan (SWPPP) and associated activities. The SWPPP writer must be a trained Qualified SWPPP Developer (QSD) and site inspections must be conducted by a Qualified SWPPP Practitioner (QSP). These requirements and strategies for successful oil and gas operations necessary to limit soil erosion and storm water runoff will be discussed.

AAPG Search and Discovery Article #90142 © 2012 AAPG Annual Convention and Exhibition, April 22-25, 2012, Long Beach, California