EPA Audit of DOGGR Released
Monday Morning Report, September 6, 2011.
The California Division of Oil, Gas and Geothermal Resources (DOGGR) released the executive summary and full text of an audit of their Class II Underground Injection Control (UIC) Program conducted by outside consultants to the U.S. Environmental Protection Agency (EPA).
The audit looks at multiple issues within the Class II UIC Program.
· Definitions of Underground Sources of Drinking Water (USDWs) and Base of Fresh Water (BFW)
· Area of Review (AOR)/Zone of Endangering Influence (ZEI) considerations, including corrective action requirements, well construction practices, and status of wells located within the AOR
· CDOGGR annual project reviews
· Monitoring program, including procedures for establishing Maximum Allowable Surface Pressures (MASPs)
· Inspections and compliance/enforcement procedures
· Idle well planning and testing
· Financial responsibility requirements
· Plugging and abandonment requirements
· UIC staff qualifications.
DOGGR is expected to respond to the audit with comments. CIPA and WSPA are reviewing the reports and will incorporate elements into proposals we are requesting be implemented to create more certainty and speed into the permitting process.
For additional information, please contact Rock Zierman.