Watching Government TRI reporting

The Environmental Protection Agency is working on a proposal that could require larger U.S. oil fields to disclose their toxic emissions to the public.

Under the Toxic Release Inventory (TRI) program, large manufacturers must report their emissions to EPA, which then makes the data public on the theory that citizens have the right to know what local plants are discharging.

Now EPA is studying whether to expand the TRI reporting program to exploration and production (E&P) operations.

Opposition

The Interstate Oil & Gas Compact Commission, which represents producing states, and the American Petroleum Institute argue that oil fields should not be included.

API estimates TRI reporting could cost the E&P industry $228 million in the first year and $110 million/year thereafter. The Department of Energy has estimated the cost could total $8.5 billion in the first 5 years.

Iogcc said expanding TRI to routine E&P operations, including reinjection of produced water for enhanced oil recovery or disposal, would be unnecessarily costly and could mislead the public.

After the U.S. government expanded TRI reporting to its own facilities, data about Elk Hills field caused a public uproar in Kern County, Calif., in late 1994. The federally operated field was listed as the top polluter in the county, although "wastes" were mostly reinjected water.

Iogcc said, "TRI reporting would provide virtually no environmental or community right to know benefits because the vast majority of E&P facilities are in remote rural areas or offshore, far from communities."

API estimated 80% of the 1,311 oil facilities EPA has surveyed are more than 10 miles from population centers of 10,000 people or more. It added that EPA has vastly overestimated the industry's reportable TRI releases.

Uncertainty

Lynn Goldman, the assistant EPA administrator running the TRI program, told an Iogcc meeting in Washington, "We're looking at the oil and gas industry, although we have not yet determined which new sectors will come within TRI."

Goldman said about 10% of the 35,000-40,000 E&P facilities in the U.S. might be large enough to exceed the threshold volumes of emissions.

For general industry, the threshold is a plant with 25,000 lb/year of contaminants and more than 10 employees.

Goldman said EPA probably will define an E&P facility as a 35 well oil field. But EPA is having trouble deciding who should be counted as an employee in a particular oil field. She said the rule would not exempt remote fields.

She conceded "it doesn't make much sense" to report on volumes of water that is reinjected, although trace contaminants in water might fall under the rule.

Although industry would have the expense of reporting, she said, there would be no extra monitoring or testing because EPA is less concerned about exact amounts than it is about giving people a right to know what's being released in their community.

Goldman stressed, "No decisions have been made. We're wide open to discussion." She expects EPA to send a proposed rule to the Office of Management & Budget this summer.