BROTHERTON, WILLIAM J., BCM Engineers Inc., Dallas, TX

ABSTRACT: Environmental Liability Associated with Oil and Gas Production Sites: A Case Study

This paper will address the environmental liabilities that are typically associated with oil and gas production sites. A walk-through of an environmental investigation at an actual site will be presented.

The paper will outline "typical" environmental assessment procedures. The purpose of these procedures is to investigate the following, so as to determine how each of these may affect environmental conditions: (1) site topography, (2) site geology, (3) site hydrogeology, (4) major waterways and land features, (5) historical or archaeological significance, and (6) existing site conditions.

In addition, some discussion will focus on nearby regulated sites. Regulated sites include those that fall under the umbrella of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), the Resource Conservation and Recovery Act (RCRA), the Clean Air Act (CAA), and the Toxic Substances Control Act (TSCA).

The majority of the paper, however, will focus on the actual site conditions encountered at an exploration and production (E & P)site. E & P wastes are currently exempt from RCRA subtitle C.

RCRA exemption, however, does not mean state and federal regulations do not affect E & P sites. Hydrocarbon contaminated soil, saltwater disposal, spill prevention and control, asbestos-containing materials, naturally occurring radioactive material (NORM); all of these and more are issues that must be identified and properly dealt with.

The case study used in this paper will illustrate how E & P sites are investigated and, based on that investigation, what steps should be taken to minimize the liabilities.

AAPG Search and Discovery Article #90987©1993 AAPG Annual Convention, New Orleans, Louisiana, April 25-28, 1993.