API E4 : 2003

1 OVERVIEW OF RELEVANT STATUTES
  1.1 Clean Water Act
  1.2 The Comprehensive Environmental Response Compensation
       and Liability Act (CERCLA or Superfund)
  1.3 Emergency Planning and Community Right-to-Know Act
       (EPCRA)
2 OVERVIEW OF GOVERNMENT AGENCIES
  2.1 National Response Center
  2.2 The State Emergency Response Commission or SERC
  2.3 The Local Emergency Planning Committee or LEPC
3 RELEASE REPORTING FLOWCHARTS
4 REPORTING REQUIREMENTS UNDER THE CLEAN WATER ACT (CWA)
  4.1 General Requirements
  4.2 Scope of the Discharge Reporting Requirement
  4.3 Definition of "Navigable Waters of the United States"
  4.4 Definition of "Hazardous Substance" and "Harmful
       Quantity"
  4.5 Procedures for Reporting to the NRC
  4.6 Procedures for Reporting to the Regional Administrator
       of the EPA
  4.7 Enforcement
5 REPORTING REQUIREMENTS UNDER THE COMPREHENSIVE ENVIRONMENTAL
  RESPONSE COMPENSATION AND LIABILITY ACT (CERCLA)
  5.1 General Requirements
  5.2 Definition of Hazardous Substance
  5.3 Petroleum Exclusion
  5.4 Exploration and Production Waste Exemption
  5.5 Definition of Reportable Quantity
  5.6 Definition of Reportable Release
  5.7 Period of Release
  5.8 Mixtures of Hazardous Substances
  5.9 Determining the RQ for Waste Streams
  5.10 Definition of Facility
  5.11 Releases into the Environment
  5.12 Workplace Exclusion
  5.13 "Immediate" Notice
  5.14 Mechanics Of CERCLA Notification
  5.15 Reporting "Continuous Releases"
  5.16 "Federally Permitted" Releases
  5.17 Enforcement Provisions
6 REPORTING REQUIREMENTS UNDER THE EMERGENCY PLANNING AND
  COMMUNITY RIGHT-TO-KNOW ACT (EPCRA)
  6.1 Key Definitions for EPCRA Programs
  6.2 Transportation Exclusion
  6.3 The CERCLA Petroleum Exclusion and EPCRA
  6.4 Elements of Section 304 Reporting Requirements
  6.5 Mechanics of Notification
  6.6 Section 302 Notification
  6.7 Hazardous Chemical Reporting (Sections 311 and 312)
  6.8 Enforcement
  6.9 Citizen Suits
7 RELEASE REPORTING EXAMPLES
APPENDIX A THRESHOLD PLANNING QUANTITIES (TPQS) AND REPORTABLE
           QUANTITIES (RQS) FOR COMMON OIL FIELD CHEMICALS
           (CURRENT AS OF THE DATE OF PUBLICATION)
APPENDIX B WHAT INFORMATION TO REPORT TO THE NATIONAL RESPONSE
           CENTER
APPENDIX C ADDRESSES AND TELEPHONE NUMBERS OF COAST GUARD
           DISTRICT OFFICES AND EPA REGIONAL OFFICES
APPENDIX D EXEMPT AND NONEXEMPT EXPLORATION AND PRODUCTION WASTE
APPENDIX E EPA GUIDANCE DOCUMENTS ON FEDERALLY PERMITTED
           RELEASES TO AIR "GUIDANCE ON THE CERCLA SECTION
           101(10)(H) FEDERALLY PERMITTED RELEASE DEFINITION FOR
           CERTAIN AIR EMISSIONS," 67 FED. REG. 18, 899 (APRIL
           17, 2002)
           "GUIDANCE ON THE CERCLA SECTION 101(10)(H) FEDERALLY
           PERMITTED RELEASE DEFINITION FOR CLEAN AIR ACT
           "'GRANDFATHERED' SOURCES," 67 FED. REG. 19, 750
           (APRIL 23, 2002)
APPENDIX F OCTOBER 25, 1990, LETTER FROM JIM MAKRIS, EPA,
           CLARIFYING THE APPLICABILITY OF THE DEFINITION OF
           "FACILITY" TO SUBSURFACE OPERATIONS
           API PUBLICATIONS, BULL. E1 SECOND EDITION P.75
APPENDIX G API CORRESPONDENCE WITH THE EPA REGARDING EPCRA
           SECTION 311 AND 312 REPORTING REQUIREMENTS FOR THE
           E&P INDUSTRY
           BULLETIN E1: 3 LETTERS PP. 71 - 74
APPENDIX H GENERIC TIER TWO INVENTORY OF HAZARDOUS CHEMICAL
           CATEGORIES FOR THE OIL AND GAS EXPLORATION AND
           PRODUCTION INDUSTRY AND GENERIC LIST OF
           HAZARDOUS CHEMICAL CATEGORIES FOR THE OIL AND GAS
           EXPLORATION AND PRODUCTION INDUSTRY

Provides guidance to the oil and gas production industry on reporting releases of hazardous substances and petroleum to water as required by the Clean Water Act (CWA) and reporting releases of hazardous substances into the environment as required by the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and the Emergency Planning and Community Right-to-Know Act (EPCRA). Only covers federal requirements for release reporting under the CWA, CERCLA and EPCRA. Covers the reporting of what most in the industry consider "emergency" releases, which are unplanned and typically are not covered under a permit issued by a government agency.