CPG Regulatory Compliance & Environmental Impact 3 — Questions and Answers
Question 1: The Endangered Species Act Section 7 requires federal agencies to consult with which agency before authorizing actions that may affect a listed species on federal oil and gas acreage?
- EPA
- Bureau of Land Management
- U.S. Fish and Wildlife Service or NOAA Fisheries (Correct answer)
- Army Corps of Engineers
Correct answer: U.S. Fish and Wildlife Service or NOAA Fisheries
Section 7 consultation is conducted with the U.S. Fish and Wildlife Service (terrestrial/freshwater species) or NOAA Fisheries (marine/anadromous species).
Question 2: Safe Drinking Water Act Underground Injection Control (UIC) Class II wells are specifically designated for:
- Municipal wastewater injection
- Hazardous waste disposal by deep well injection
- Oil and gas brine disposal and enhanced recovery injection (Correct answer)
- Carbon dioxide sequestration
Correct answer: Oil and gas brine disposal and enhanced recovery injection
UIC Class II wells are used exclusively for fluids associated with oil and gas production, including brine disposal wells and enhanced recovery injection wells.
Question 3: An operator receives a Notice of Violation (NOV) from the state regulatory agency. The most immediate required action is typically to:
- File a lawsuit challenging the NOV
- Submit a written response and corrective action plan within the specified deadline (Correct answer)
- Immediately cease all operations statewide
- Transfer the well to a new operator
Correct answer: Submit a written response and corrective action plan within the specified deadline
NOVs typically require the operator to respond in writing within a defined period, acknowledging the violation and presenting a corrective action plan.
Question 4: The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) imposes liability for contaminated site cleanup on:
- Only the party who caused the contamination
- Only the current property owner at time of discovery
- Any potentially responsible party including past owners and transporters (Correct answer)
- Only parties that signed a consent decree
Correct answer: Any potentially responsible party including past owners and transporters
CERCLA's strict, joint and several, retroactive liability extends to current and former owners, operators, generators, and transporters of hazardous substances.
Question 5: Federal offshore oil and gas operations are primarily regulated by which agency under the Outer Continental Shelf Lands Act?
- EPA
- Bureau of Safety and Environmental Enforcement (BSEE) (Correct answer)
- Coast Guard
- FERC
Correct answer: Bureau of Safety and Environmental Enforcement (BSEE)
BSEE, within the Department of the Interior, oversees safety and environmental enforcement for OCS oil and gas operations under OCSLA.
Question 6: Which provision of the Clean Air Act established the New Source Performance Standards (NSPS) that limit VOC and methane emissions from new and modified oil and gas well completions?
- Section 109 – National Ambient Air Quality Standards
- Section 111 – Standards of Performance for New Stationary Sources (Correct answer)
- Section 112 – National Emission Standards for Hazardous Air Pollutants
- Section 129 – Solid Waste Combustion
Correct answer: Section 111 – Standards of Performance for New Stationary Sources
CAA Section 111 authorizes EPA to set NSPS for new and modified stationary sources, including oil and gas well completions, implemented as Subparts OOOO and OOOOa.
Question 7: A petroleum geologist discovers that produced water from a well is being discharged into an ephemeral stream without a permit. The correct first action is to:
- Continue operations and document the discharge in the daily log
- Immediately stop the discharge and notify the appropriate regulatory agency (Correct answer)
- Apply for an after-the-fact NPDES permit
- Request a variance from the state agency within 30 days
Correct answer: Immediately stop the discharge and notify the appropriate regulatory agency
Unpermitted discharge to waters of the US is a Clean Water Act violation; operations must stop immediately and regulators must be notified to limit liability and environmental harm.
CPG Regulatory Compliance & Environmental Impact 3
The Endangered Species Act Section 7 requires federal agencies to consult with which agency before authorizing actions that may affect a listed species on federal oil and gas acreage?