In 1988, North Dakota Governor George Sinner was Chairman of the Interstate Oil Compact Commission, later to become the Interstate Oil and Gas Compact Commission (IOGCC). IOGCC is an organization of states that promotes the conservation and efficient recovery of domestic oil and natural gas resources while protecting health, safety and the environment. IOGCC represents the governors of 36 states that produce virtually all the onshore domestic oil and natural gas in the United States.
Governor Sinner met with J. Winston Porter, EPA Assistant Administrator for Solid Waste and Emergency Response, to discuss ways in which IOGCC could assist in encouraging improvements to state regulations and enforcement of existing programs, the second prong of the agency's approach. As a result of that meeting, in January 1989, IOGCC formed a Council on Regulatory Needs. The Council had 12 members who were state regulatory officials representing oil and gas agencies and environmental protection agencies in the six major producing regions of the country.
A nine member advisory committee, made up of three state regulators, three industry representatives and three public interest or environmental representatives, supported the Council. Five representatives from the EPA, two from the U.S. Department of Energy (DOE), and two from industry, who acted as official observers, assisted the Council. Governor Sinner and Governor Garey Carruthers of New Mexico were co-chairs of the Council. EPA provided a two-year, $299,999 grant to support Council activities.
An organizational meeting of the Council was held in February of 1989. During that meeting the distinction between Council members, advisors and observers was minimized and all parties were invited to participate as stakeholders representing their various interests. The Council was charged with reviewing state E&P waste management programs and with establishing guidelines that would represent minimum acceptable regulatory criteria. This charge did not include wastewater discharges to surface waters permitted under the Clean Water Act or waste injection into Class II disposal wells permitted under the Safe Drinking Water Act.
The Council formed a Technical Committee and an Administrative Committee. The Technical Committee had three subcommittees to address pits, land application and commercial facilities. The Administrative Committee consisted of four subcommittees to develop guidelines for personnel and resources, organization and coordination, statutory authority, and state and federal relations. These subcommittees met over the next several months as independent work groups. In June the Council met to receive draft criteria from the Technical Committee. In December the Council received draft criteria from the Administrative Committee.
As part of the Council's effort, a review of state E&P waste programs was undertaken. A questionnaire was developed and sent to all oil and gas producing states. Survey results, as well as information contained in the EPA Report to Congress and the IOGCC Summary of State Regulations, were used to develop comprehensive summaries of state programs.
In early 1990, the committee reports were revised and combined with the summary of state programs into a single document. The booklet entitled "EPA/IOCC Study of State Regulation of Oil and Gas Exploration and Production Waste" was published by IOGCC. This publication became commonly known among the states as the "IOCC Guidelines" or the "Green Book." The guidelines included an implementation strategy. One step in the strategy was to review and update of the guidelines every three years. Another step was to use the guidelines as a basis for conducting reviews of state E&P waste management programs. These reviews were to be coordinated by IOGCC.
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