RIASSUNTO
IADC Members
Abstract
The objective of this presentation is to summarize the nature and scope of the more major costs of environmental compliance as they apply to the field operations of oil and gas well drilling and production. An analysis of the appropriate federal laws is also addressed and included are the necessary reporting levels in both the federal and state governments. This information should be sufficiently definitive to allow the uninitiated to reference sources and begin a compliance program. Also. the advanced reviewer will not only receive a refresher. program. Also. the advanced reviewer will not only receive a refresher. but additional insight into potential future jurisdictional arenas that appear to be on the horizon by both federal and state regulatory agencies.
Introduction
The maze of environmental legislation at the federal and state levels that has arisen over the past two decades has keenly brought into focus the question of ""the cost of environmental compliance."" Presently. the oil and gas industry is spending its dollars determining how to comply with these complex laws. A better understanding of these individual acts is mandatory for both operating and staff positions to eliminate the element of confusion. Compliance can be so costly that American industry has already experienced examples of marginally profitable companies calling it quits, rather than shoulder the additional burden of modernizing their operations to adequately meet the mandated environmental requirements. Much of the industry's confusion comes as a result of these laws being pyramided atop one another. Each law has its own list of toxic substances as well as its own reporting requirements. To stay abreast. companies have had to look to specialists in a very narrow discipline for sound advice. Although this overview of environmental requirements provides much ground work. more detailed information regarding the cost of environmental compliance within individual operations will ultimately necessitate individual calculations as operations vary significantly and these variations can cause dramatic fluctuations in cost.
THE LAWS
To begin, we will look at some of the more significant laws that require our attention today and from there we will consider observations on ""the cost of environmental compliance."" The next few paragraphs and figures summarize the significant federal environmental laws which impact E and P operations. The laws are discussed in general terms and the reader is advised to look at the specific laws and implementing regulations for details.
Air Pollution and Prevention Control Act ""Clean Air Act""
The Air Pollution and Prevention Control Act. known as the Clean Air Act, became law in 1970. Its stated purpose was to obtain zero pollution for stationary and mobil discharges. Companies are the liable pollution for stationary and mobil discharges. Companies are the liable parties if they fail to meet air pollution standards of specific parties if they fail to meet air pollution standards of specific geographical regions. No record keeping is required unless the company finds itself out of compliance. If non-compliance is ascertained. then federal and state reporting becomes mandatory. This law has its own list of airborne pollutants. Civil and criminal penalties can apply. It is most case to sustain a violation in urban areas with some states such as California being very sensitive. Figure 1 summarizes the Clean Air Act.
Figure 1
(1) Date Enacted - 1970
(2) Purpose- Obtain zero pollution for stationary and mobile discharges (3) Liability - Company liable if fails to meet air pollution standards of a geographical region. Truck mounted rigs included. (4) Record Keeping None
(5) Federal Reporting None unless out of compliance
(6) State Reporting Same as immediately above
(7) Pollutant(s) - Small number of airborne
(8) Damages - Civil and criminal
Water Pollution and Control Act -Clean Water Act""
The Water Pollution and Control Act, known as the Clean Water Act, became law in 1972.
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