Formation of STRONGER
In February 1999, EPA called a meeting of state and industry stakeholders and DOE to discuss the future of the state review process. EPA confirmed its continuing support of the process, even in the absence of environmental stakeholder participation. EPA pledged financial support to get the process restarted and indicated anticipated financial support for future years. The Governing Body was formed and named State Review of Oil & Natural Gas Environmental Regulations (STRONGER). Officers were elected and preliminary rules of process were adopted. Members were assigned responsibilities for investigating incorporation of the Governing Body as a non-profit corporation, drafting a work statement for contracted administrative services, soliciting environmental participants, and determining sections of the guidelines that needed revision.
Over the next several months, STRONGER members pursued their assignments and reported their progress to the group at numerous meetings and conference calls. DOE provided interim administrative services to STRONGER through the Aspen Group, a consultant they had under contract. In March, STRONGER members decided to incorporate as a 501(c)(3) corporation, reviewed draft Articles of Incorporation and Bylaws, and discussed EPA and DOE participation on the Board of Directors. These issues and a grant application for EPA funding were discussed in April.
At the STRONGER meeting in May, the National Fish and Wildlife Foundation joined as an environmental/conservation stakeholder. It was decided that EPA and DOE would participate on the Board of Directors as non-voting, non-managerial members. Articles of Incorporation were approved for filing and Bylaws were adopted. Five committees were formed for revising the guidelines and members volunteered to serve as "Champion" for each committee. Committees were formed to review sections pertaining to NORM, data management, waste minimization, commercial facilities and waste characterization, and to develop a new section on implementation performance. Champions were assigned the responsibility to develop the mission statement, scope, goals and schedule for each committee and to work with the committees throughout the revision process. A preliminary schedule for state reviews and follow-up reviews, based on states that volunteered for review during 2000, was developed.
During June 1999, Articles of Incorporation were filed for State Review of Oil & Natural Gas Environmental Regulations, Inc. (STRONGER), bylaws were formally adopted and officers were elected. Guideline revision committee chairs were approved and committees were charged with their missions, goals and schedules. Committees were given an ambitious schedule of developing draft revisions for distribution, review and comment by IOGCC Official Representatives at their September Quarterly Meeting, and developing final proposed revisions, considering comments received from Official Representatives, for distribution and approval at the December IOGCC Annual Meeting. An administrative search committee was formed to recruit and evaluate candidates to provide administrative services to the STRONGER Board of Directors. An application for a grant to support STRONGER activities was submitted to EPA. At the IOGCC State Review Committee meeting, a subcommittee was formed to update the report "State Actions Based on State Review Process Recommendations."
In August, a letter of invitation signed by EPA Assistant Administrator for Solid Waste and Emergency Response and the Chairman of the STRONGER Board of Directors was mailed to 89 environmental organizations to determine their level of interest in participating in the process.
In September 1999, draft revisions to the guidelines were distributed to IOGCC Official Representatives for review. At the 1999 IOGCC Fall Quarterly meeting, the anticipated schedule for guideline adoption and use of the revised guidelines for state reviews was discussed. Comments on the draft revisions were requested by mid-October. Also in September, an EPA grant offer award was received by STRONGER, and Bear West Company was selected to provide administrative services.
The EPA grant offer was accepted in October. In November, a contract was negotiated with Bear West for administrative services. The committees revised the draft guidelines after consideration of comments received. After adoption by the STRONGER Board of Directors, the guideline revisions were distributed to IOGCC Official Representatives, State Directors and State Review Committee members.
At the IOGCC Annual Meeting in December 1999, Official Representatives were not ready to adopt the guideline revisions. Some states did not have an opportunity to coordinate the reviews of multiple agencies responsible in their state for E&P waste regulation. Other states wanted an opportunity for more detailed review and discussion of the revisions. Consequently, the Official Representatives tabled a motion for conditional adoption of the revised guidelines.
In its place, they adopted a motion to coordinate in-state review of the revisions, submit comments to STRONGER by mid-February, and to consider the revisions for adoption at the March meeting. And an addendum to "State Actions Based on State Review Process Recommendations" was distributed. [NOTE: The revised Guidelines were subsequently accepted by the IOGCC Official Representatives at their June, 2000 mid-year meeting]