Abstract: Industry Requested Exploration/Production Environmental Regulation
California State Review by the Interstate Oil and Gas Compact Commission recommends state and regional water boards issue requirements to all pits subject to basin plans and chapter 15. Resource shortfalls have kept production pits from being Water Board priorities. Threat of United States EPA designation of crude oil as hazardous waste and subsequent land use conflicts of buried pits in developing areas have led to the call for full implementation of State regulations.
Recommended state improvements include (1) interagency communication, cross training, computer database, and inspections; (2) development of guidance documents and consistency in pit closure policy, permitting, water quality in DOG pit rules, land spreading, road spreading, and minimum construction and operation requirements and; (3) administratively finding additional resources to fully implement requirements, increase records
retention time, consider compliance history, revise Water Board/DOG Memorandum of Understanding and adjust DOG financial assurance program to provide incentive for proper and timely well plugging and site reclamation.
Industry/Regulatory Agency cooperation can significantly reduce the burden of regulation implementation. Industry willingness to pay appropriate regulatory fees can facilitate regulation execution. Field drilling crew education can minimize regulatory implementation costs. Mud pit Resource Conservation and Recovery Act exemption can be maintained if hazardous substances (e.g., pipe dope and solvents) are kept out of the pit.
AAPG Search and Discovery Article #90981©1994 AAPG Pacific Section Meeting, Ventura, California, April 27-29, 1994