Storm water discharges from oil and gas related construction activities
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Storm Water Discharges from Oil and Gas Related Construction Activities. EPA Public Meeting Dallas, Texas May 10, 2005. Overview. History Rule deferral rationale Regulatory options EPA analysis Q&A. Chronology. Oil and Gas Exemption.

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Storm Water Discharges from Oil and Gas Related Construction Activities

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Storm Water Discharges from Oil and Gas Related Construction Activities

EPA

Public Meeting

Dallas, Texas

May 10, 2005


Overview

  • History

  • Rule deferral rationale

  • Regulatory options

  • EPA analysis

  • Q&A


Chronology


Oil and Gas Exemption

  • CWA §402(l)(2) - The Administrator shall not require a permit … for discharges of stormwater runoff from … oil and gas exploration, production, processing, or treatment operations or transmission facilities, composed entirely of flows which are from conveyances or systems of conveyances … used for collecting and conveying precipitation runoff and which are not contaminated …

  • Construction activity, includes clearing, grading, and excavating

  • Since 1992, EPA has considered construction activity at oil and gas sites to require permit coverage – i.e., not considered to fall under exemption.


Construction

and Industrial

EPA as NPDES Permitting Authority

Federal Facilities

Oil and Gas

Puerto Rico

Virgin Islands

Tribes

Other Territories


2003 Facts and Figures

  • ~28,000 new well sites in 29 states

  • EPA administers the Storm Water program in AK*, TX, OK, and NM:

    • 48% of the wells are drilled

    • 66% of estimated compliance costs are accrued

    • Permit addresses ESA and NHPA

* Vast majority of AK sites are >5 acres and covered by Phase I regulations.


Deferral Rationale

  • Phase II Rule determined that few if any oil and gas sites exist between 1 and 5 acres

  • EPA subsequently deferred requirement for small oil and gas sites to obtain permit coverage

  • EPA performing:

    • Economic impact analysis, including cost/benefit analysis

    • BMP review

      • Industry Standard Operating Procedures

      • BLM Gold Book Guidelines

      • State prescribed BMPs

    • Analysis of regulatory options


Regulatory Options

EPA is currently evaluating 2 options (against the baseline) for regulating small oil and gas construction activity:

(Baseline) - Regulate consistent with Phase II Rule

(Option 1) – Create New Waiver

(Option 2) - Non-permitting program [CWA 402(p)(6)]


Regulatory Options (Baseline)

Baseline Approach:

  • Requirements include:

    • Coverage under Construction General Permit

    • Develop site-specific Storm Water Pollution Prevention Plan (SWPPP)

    • Perform routine inspections

    • ESA/NHPA considerations (for EPA permits)


Baseline Approach

GAO-05-240, February 2005


Baseline – Construction SWPPP

  • Site Description

  • Controls to Reduce Pollutants

    • Erosion and Sediment Controls

    • Stabilization Practices

    • Storm Water Management

  • Maintenance

  • Inspections


Baseline-SWPPP: Site Description

  • Description of construction activity

  • Sequence of major soil disturbing events

  • Total and disturbed area (acreage)

  • Storm water discharges (location)

  • Site map

  • Storm water controls (location)

  • Receiving waters (name, location)

  • Endangered species; historic preservation


Baseline-SWPPP: Erosion and Sediment Controls

  • Properly select and install controls to:

    • Minimize erosion

    • Retain sediment on-site

    • Remove any sediment that accumulated off-site

  • Remove sediment from sediment traps

  • Prevent litter from entering streams


Baseline-SWPPP: Stabilization Practices

  • Temporary Seeding

  • Permanent Seeding

  • Mulching

  • Sod Stabilization

  • Vegetative Buffer Strips

  • Tree Preservation

  • Contouring and Protecting Sensitive Areas


Baseline-SWPPP: Structural Controls


Maintenance and Inspections

  • BMPs must be maintained in effective operating condition

  • Any repairs must be performed before next anticipated storm event, if possible.

  • Inspect at least every 14 calendar days and within 24 hours after any storm event of 0.5 inches or greater (or every 7 days) until permit coverage terminated.


Regulatory Option #1- Waiver

  • Sites <5 acres would be waived from permit coverage under certain conditions

  • Sites 5 acres and above would still be required to obtain permit coverage

  • Possible waiver eligibility requirements:

    • Short term (<30 days) construction

    • Proximity to water body

    • Slope, region, and other site-specific considerations

    • BMP implementation


Regulatory Option #2-Non-Permitting NPDES Program

  • Comprehensive program under CWA section 402(p)(6)

  • Develop a program for O&G construction activity

  • Likely similar BMP requirements as baseline and Option 1

  • Evaluate legal authorities and responsibilities


Economic Analysis: Purpose

  • Evaluate the costs and benefits of the requirements under the Phase II Storm Water Rule

  • Follow analytical approach using relevant data from the Phase II analysis (1998).

  • Examine the costs and benefits for 3 rulemaking options:

    • Baseline (expiration of deferral after 6/12/06)

    • Waiver

    • Non-permitting program under CWA 402(p)(6)


Economic Analysis: Impacts

  • Direct costs

    • Notice of Intent

    • SWPPPs

    • BMPs

    • Potential ESA & NHPA Considerations

  • Indirect costs

    • Revenue delay

    • Forgone lease bonus payments

    • Idle rig contract payments

    • Project cancellation


Next Steps

  • Gather additional information

  • Complete Economic Analysis

  • Notice of Proposed Rulemaking (9/05)

  • Comment period

  • Final Rulemaking (6/06)

Questions?


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