Region VIII Problem Oil Pit Effort

Abstract

ABSTRACT Improper construction and operation of open oil pits used by the oil and gas exploration and production industries result in the deaths of hundreds of thousands of mammals and millions of birds each year. Releases from exploration and production operations of oil and produced water “brine,” which carry heavy metals and other contaminants to surface waterways and to subsurface groundwater pose a threat to human health, wildlife, and water resources for agricultural, domestic and recreational uses. The U.S. Environmental Protection Agency Region VIII (EPA), U.S. Fish and Wildlife Service Region VI (FWS), the U.S. Bureau of Land Management (BLM), and various state and tribal agencies, “the partners,” have joined in a coordinated effort to address “problem oil pits.” The composition of the partnership varies within each state based on which state and tribal agency or agencies have responsibilities related to each facility. Examples of state agencies which were members of the partnership are the Colorado Oil and Gas Conservation Commission, Colorado Department of Public Health and the Environment, Montana Department of Natural Resources and Conservation, Montana Department of Environmental Quality, Wyoming Oil and Gas Conservation Commission, and the Wyoming Department of Environmental Quality. The Shoshone, Arapahoe, and Ute Mountain Ute tribes are some of the tribes involved in the partnership The goals identified by the partners were: (1) to minimize the potential for bird and other animal mortality from contact with oil; (2) to ensure that oil production and exploration facilities are constructed and managed in an environmentally protective manner in compliance with all requirements and to rectify other existing environmental issues; and last but not least in priority, (3) to protect the health of the community and environmental resources for future generations. Data compiled during field inspections by the partners indicated a strong correlation between bird and wildlife mortality and the extent of the surface covered by oil at the problem oil pits. Almost 89% percent of the bird mortality and almost 65 percent of the wildlife mortality were recovered from pits whose surfaces were 100% covered with oil. All of the remaining bird and wildlife mortality occurred in pits with significant amounts of oil on the surface. The aerial survey conducted in this effort identified an initial 409 sites which had potential problem oil pits. Field inspections were conducted at 299 of those sites. Of note is the fact that 172 sites of the 299 were found to have ongoing discharges in excess of permitted limits and/or uncontained leaks, spills or discharges of oil. Thus, the same poor management practices which result in problem oil pits, present compliance problems which may lead to discharges of oil into the waters of the United States. All of the dead birds and wildlife recovered by the inspection teams were found in or near pits which had no netting; none were found at sites which had netting. Some of the pits where mortality occurred had flagging. Thus, netting is the only effective deterrent device which would prevent birds and wildlife from entering these oil covered pits. The partners developed processes to gather and evaluate information, and to make decisions on the appropriate actions in response to issues in a coordinated way. Key to the problem oil pit effort was the success of the formal and informal communications with the regulated community which resulted in many of the problem pits being remediated before the next bird migratory season began. The partners, believe that most of the remaining problems at oil exploration and production pits identified in the effort thus far will be remedied within 1 year. The lessons learned from this close coordination improved their working relationships and enhanced their ability to resolve environmental problems together in the future. Long term communication strategies being developed will help ensure that goals continue to be met and a high degree of long-term environmental protection is achieved.