Regulatory Compliance & Environmental Issues Flashcards

What is 'produced water' and what is the primary federal regulatory concern for its disposal onshore?

Answer: Water co-produced with oil and gas from the reservoir; regulated primarily under SDWA Class II UIC disposal well rules and state programs

Produced water is naturally occurring formation water that comes up with hydrocarbons; its underground disposal is regulated under SDWA Class II injection well rules.

Under OSHA's Process Safety Management (PSM) standard (29 CFR 1910.119), what threshold quantity of flammable liquids in a process triggers PSM requirements?

Answer: 10,000 lbs at or above the normal boiling point

OSHA's PSM standard applies when a process contains 10,000 lbs or more of a flammable liquid or gas at or above its normal boiling point.

Which BLM regulation governs the measurement, reporting, and royalty valuation of oil and gas produced from federal and Indian leases?

Answer: 30 CFR Parts 1202 and 1206 (ONRR Royalty Valuation)

The Office of Natural Resources Revenue (ONRR) administers 30 CFR Parts 1202 and 1206, which govern royalty reporting and valuation for federal and Indian mineral production.

A 'completion report' submitted to BLM after drilling a well on federal land must include:

Answer: Geologic, engineering, and production test data, including casing details, perforations, and initial production rates

BLM's Well Completion or Recompletion Report (Form 3160-4) requires comprehensive technical data including geology, casing program, completion interval, and initial production test results.

Under CERCLA, what is the legal significance of being designated a 'Potentially Responsible Party' (PRP)?

Answer: PRPs may be held jointly and severally liable for all cleanup costs at a Superfund site regardless of fault percentage

CERCLA imposes strict, joint and several liability on PRPs, meaning any one party can be held responsible for 100% of cleanup costs regardless of their proportionate contribution.

The 'Royalty-In-Kind' (RIK) program, historically used by ONRR, allowed the federal government to:

Answer: Accept oil or gas production instead of cash royalty payments from lessees

Under the RIK program, the federal government took its royalty share in the form of actual production rather than cash, which it then marketed independently.

Which federal regulation requires oil and gas operators to submit an 'Application for Permit to Drill' (APD) and what agency reviews it?

Answer: 43 CFR Part 3162; BLM reviews APDs for onshore federal and Indian oil and gas leases

BLM's regulations at 43 CFR Part 3162 require operators to file an APD and receive BLM approval before drilling on federal or Indian lands.