CPG Regulatory Compliance & Environmental Impact 2 — Questions and Answers
Question 1: Under the Clean Water Act Section 404, which federal agency issues permits for the discharge of dredged or fill material into waters of the United States related to oil and gas operations?
- EPA
- Army Corps of Engineers (Correct answer)
- Bureau of Land Management
- FERC
Correct answer: Army Corps of Engineers
The Army Corps of Engineers administers Section 404 permits for dredge-and-fill activities in navigable waters and wetlands.
Question 2: The Resource Conservation and Recovery Act (RCRA) Subtitle D classifies oil and gas exploration and production wastes as:
- Hazardous waste requiring Subtitle C management
- Non-hazardous solid waste exempt from Subtitle C (Correct answer)
- Universal waste subject to streamlined handling
- Mixed waste co-regulated with NRC
Correct answer: Non-hazardous solid waste exempt from Subtitle C
Under the 1988 Bentsen Amendment, E&P wastes were specifically exempted from RCRA Subtitle C hazardous waste regulations and managed as non-hazardous solid waste.
Question 3: A Spill Prevention, Control, and Countermeasure (SPCC) Plan is required under 40 CFR Part 112 when an oil and gas facility has an aboveground oil storage capacity exceeding:
- 660 gallons in a single container
- 1,320 gallons aggregate aboveground (Correct answer)
- 2,500 gallons aggregate aboveground
- 10,000 gallons aggregate aboveground
Correct answer: 1,320 gallons aggregate aboveground
Facilities with aggregate aboveground oil storage capacity greater than 1,320 gallons and a reasonable expectation of discharge to navigable waters must prepare an SPCC Plan.
Question 4: Which federal regulation requires operators on federal and Indian lands to minimize venting and flaring of natural gas and capture a specified percentage of produced gas?
- BLM Venting and Flaring Rule (Waste Prevention Rule) (Correct answer)
- EPA New Source Performance Standards Subpart OOOOa
- Clean Air Act Title V Operating Permit Rule
- PHMSA Gas Pipeline Safety Rule
Correct answer: BLM Venting and Flaring Rule (Waste Prevention Rule)
BLM's Waste Prevention Rule (43 CFR Part 3179) requires operators on federal and Indian lands to capture gas and minimize venting and flaring to reduce waste.
Question 5: The National Environmental Policy Act (NEPA) requires federal agencies to prepare an Environmental Impact Statement (EIS) when a proposed action is determined to be:
- Categorically excluded from environmental review
- A major federal action significantly affecting the human environment (Correct answer)
- A routine ministerial action with no discretionary element
- A project valued over $10 million in federal funds
Correct answer: A major federal action significantly affecting the human environment
NEPA mandates an EIS for any major federal action that may significantly affect the quality of the human environment, including federal oil and gas lease approvals.
Question 6: Under EPA's Greenhouse Gas Reporting Program (40 CFR Part 98 Subpart W), which threshold triggers mandatory GHG reporting for petroleum and natural gas systems?
- 500 metric tons CO2e per year
- 1,000 metric tons CO2e per year
- 25,000 metric tons CO2e per year (Correct answer)
- 100,000 metric tons CO2e per year
Correct answer: 25,000 metric tons CO2e per year
Petroleum and natural gas systems must report GHG emissions when they emit 25,000 metric tons or more of CO2 equivalent per year.
Question 7: Which document establishes baseline environmental conditions before drilling begins and is used to compare post-operation conditions for liability assessment?
- Drilling Permit Application
- Baseline Environmental Assessment (BEA) (Correct answer)
- Well Completion Report
- Plugging and Abandonment Plan
Correct answer: Baseline Environmental Assessment (BEA)
A Baseline Environmental Assessment documents pre-operational soil, water, and air conditions and serves as the reference point for evaluating operator liability after drilling.
CPG Regulatory Compliance & Environmental Impact 2
Under the Clean Water Act Section 404, which federal agency issues permits for the discharge of dredged or fill material into waters of the United States related to oil and gas operations?