Onshore Unconventional Hydrocarbon Development Legacy Issues and Innovations in Managing Risk–Day 1: Proceedings of a Workshop (2018) / Chapter Skim
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5 Intersection of Technology and Regulation: Smoothing the Interface Through Time
5 Intersection of Technology and Regulation: Smoothing the Interface Through Time
Pages 43-56
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From page 43... ...
Effective regulators, Anderson noted, have long recognized that it is vital for them to pursue continual improvement. In recent years, regulators represented by the Interstate Oil and Gas Compact Commission (IOGCC)
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From page 44... ...
Anderson noted the importance of professional development and training opportunities for field inspectors. One relatively new project he highlighted called "Top Corps" trains field inspectors and is coordinated jointly by the University of Texas, Colorado School of Mines, and The Pennsylvania State University.
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In this regard, Vendel remarked on the benefits to states based on the collaboration between the Interstate Oil & Gas Compact Commission (IOGCC) and the Groundwater Protection Council (GWPC)
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From page 46... ...
construction rule required engineering plans, a permit, and land reclamation with engineercertified drawings and plans, technical review of the plans, and engineers in the field ensuring that well sites are constructed to reduce environmental impacts. This rule has been a real success with few failures since the rule was implemented, he said.
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From page 47... ...
These features will aid real time enforcement and help reduce instances of negative legacy impacts. Improving Practices: Performance Standards, Third Party Certification, and Other Approaches Susan Packard LeGros, Center for Responsible Shale Development Packard LeGros opened her presentation by remarking on the convergence among the attendees at the workshop that technology has advanced at a pace that exceeds the ability of state government and regulation to keep up.
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From page 48... ...
The Center is also working on continuous improvement because the goal of the organization is to identify ways performance standards can articulate a level of performance that exceeds existing state regulation. This presents a continuing challenge, for example, when the performance standards were initially drafted in 2011 and 2012; state regulations had not at that time caught up to industry's activities and technologies.
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From page 49... ...
FIGURE 5.5 Incentivizing Voluntary Standards. SOURCE: Packard LeGros, slide 13.
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Companies like Anadarko are keen on making sure that once a well is plugged and abandoned that it remains in that FIGURE 5.6 Comparison between the surface footprints for various energy production projects that generate approximately the same amounts of energy. Left to right: horizontal drilling for shale resources, drilling for conventional oil and gas resources, wind farm; solar farm.
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From page 51... ...
Anadarko is looking at produced water as a usable byproduct. McBride noted stakeholder engagement as a critical component of any company's development of oil and gas resources.
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MODERATED DISCUSSION A participant commented on the design of regulations and asked whether appropriate regulatory design could alleviate concerns about the technology interface and the adaptation of regulations to technology. If regulations were performance standards or economic incentive approaches, the participant said, those changes in technology would be incentivized by the regulations themselves.
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From page 53... ...
For example, new federal performance standards are incorporated into their standards for existing facilities, and the Center is demonstrating that those standards can be met and can help inform the regulatory process. A participant continued that thought by suggesting that although the CRSD is not focused on trying to impact regulations, the CRSD standards are robust, and by keeping the standards ahead of the rules, one is probably influencing the course of future regulation which may otherwise have challenges in maintaining pace with industry practice.
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From page 54... ...
McBride indicated that industry is familiar with formation water and they know the water quality criteria for receiving water if it is discharged. Anderson noted that EPA has indicated that key toxicity data are missing for 73 percent of the constituents in produced water from unconventional oil and gas development.
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From page 55... ...
The participant then asked the panelists, what is the primary area that needs to be advanced to ensure high standards of performance for the long term? The panelists responded by suggesting that solid-waste disposal; financial assurance; good historical records with accurate data on past drilling activity, well locations and conditions, and plugging and abandoning activities; and landscape and community impacts were critical needs.
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