On July 27, 2018 the California Division of Oil, Gas, and Geothermal Resources (“DOGGR”) issued two notices of proposed rulemaking action applicable to oil and gas operations in the state.  DOGGR released updated underground injection control (“UIC”) regulations, as well as proposed regulations for idle well testing and management.

UIC Regulations

DOGGR supervises the drilling, operation, maintenance, and plugging and abandonment of onshore and offshore oil, gas, and geothermal wells.  Wells that inject fluid for the purposes of enhancing oil or gas recovery, re-pressuring oil or gas reservoirs, or disposing of wastewater and other byproducts associated with oil and gas production – referred to as injection wells or UIC wells – fall within DOGGR’s regulatory scope.Continue Reading DOGGR Issues Revised Regulations for UIC and Idle Wells

On February 1, 2018, the U.S. Court of Appeals for the Ninth Circuit upheld the district court’s decision, finding that the County of Maui violated the Clean Water Act (“CWA”) when it discharged treated effluent into underground injection wells, which then allowed the effluent to seep into the Pacific Ocean.  The Ninth Circuit panel held that the wells were required to obtain National Pollutant Discharge Elimination System (“NPDES”) permit coverage because the discharge from the wells was “fairly traceable” from the discharge point (point source) to a navigable water.
Continue Reading Injection Well Operators Beware: Ninth Circuit Finds Underground Injection Wells Require NPDES Permit under the Federal Clean Water Act

February 17, 2017 marked the deadline by which legislators had to introduce bills for the first half of the 2017-2018 Legislative Session.  The Stoel Rives’ Oil & Gas Team has been and will continue to monitor bills throughout the current two-year session and will provide periodic updates as to the status of those bills.  Below is the current status and summary of some of the bills Stoel Rives is monitoring.

Please also reference our Renewable + Law post summarizing bills related to energy law here.

AB 55 (Thurmond, D):  Refineries: turnarounds

STATUS: Introduced December 5, 2016; referred to Committee on Labor & Employment on January 19, 2017

The California Refinery and Chemical Plant Worker Safety Act of 1990 requires every petroleum refinery employer to submit to the Division of Occupational Safety and Health a full schedule for the following calendar year of planned turnaround every September 15th. The employer is also required, upon the request of the division, to provide the division with specified documentation relating to a planned turnaround within a certain period of time. This bill would require the documents to be provided to the division upon request also include all documentation necessary to demonstrate compliance with the above-described skilled and trained workforce requirements.  A violation of the bill’s requirements would be a crime.Continue Reading Oil & Gas Related Bills Introduced in the 2017-2018 Legislative Session