An overview of oil and gas exploration and production waste issues
Conference
·
OSTI ID:269165
- Kleberg & Head, Houston, TX (United States)
The petroleum exclusion of CERCLA and the drilling fluids exemption of RCRA were both created in 1980 to provide the oil and gas exploration and production industry with ample protection from excessive federal environmental regulation. Over the last 15 years, federal court decisions, EPA`s administration of these programs, and state regulatory actions have substantially reduced the scope of these two provisions. This presentation will explore the original intent of CERCLA`s petroleum exclusion and RCRA`s drilling fluids exemption, and how this original intent is at odds with subsequent EPA and judicial interpretation of these provisions. The presentation will conclude with an assessment of the current scope of the petroleum exclusion and the drilling fluids exemption, including a (cautious) prediction of the direction that federal and state policy governing exploration and production wastes is likely to take in the next few years.
- OSTI ID:
- 269165
- Report Number(s):
- CONF-960107--
- Country of Publication:
- United States
- Language:
- English
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