Trooper, your killing me, this will be my last post on this subject, I promise, but I cant take it.
It is abundantly obvious that you have never had dealings with the EPA, but the State where you drill does. Lets start with Louisiana, go to the CFR and you will see that LADEQ has be delegated by the EPA as the enforcement authority for “Oil and Natural Gas Production Facilities”, and just about any other Oil based industry. When the Feds delegate to the States, the “delegations are subject to all of the conditions and limitations set forth in Federal law, regulations, policy, guidance, and determinations”.
Take a look at 40CFR112.1 which states: “this part applies to any owner or operator of a non-transportation-related onshore or offshore facility engaged in drilling, producing, gathering, storing, processing, refining, transferring, distributing, using, or consuming oil and oil products”
Also, look at 40CFR 112.10.
Sec. 112.10 Spill Prevention, Control, and Countermeasure Plan requirements for onshore oil drilling and workover facilities.
If you are the owner or operator of an onshore oil drilling and workover facility, you must:
(a) Meet the general requirements listed under Sec. 112.7, and also meet the specific discharge prevention and containment procedures listed under this section.
(b) Position or locate mobile drilling or workover equipment so as to prevent a discharge as described in Sec. 112.1(b).
(c) Provide catchment basins or diversion structures to intercept and contain discharges of fuel, crude oil, or oily drilling fluids.
(d) Install a blowout prevention (BOP) assembly and well control system before drilling below any casing string or during workover operations. The BOP assembly and well control system must be capable of controlling any well-head pressure that may be encountered while that BOP assembly and well control system are on the well.
I can go on and on if you like, honestly, where do you think the “rules and regulations” come from Baton Rouge?
I have never had to drill a well, nor cap a well and I hope I never will. I only to deal with liability issues when TSHTF. As I have stated before, a landowner can never ever avoid liability by transferring to a third party.
Thanks, but I'll pass on the LADNR, it can't help with the liability issues. I do love the world today for many reasons, including the web, because I get the chance to see someone who drills and caps wells for a living try to explain environmental liability.