Page 161 - Environmental Control in Petroleum Engineering

148 Environmental Control in Petroleum Engineering

needed, and make recommendations for corrective action to address
problems. In preparing the written report, any problems can usually
be grouped into one of the following three categories:
1. Activities that are in violation of permits or regulations, activities
that are in violation of company policies, or policies that encour-
age activities to be in violation. These activities require the
attention of senior management and need immediate correction.
2. Conditions that could result in a violation or in a situation that
could harm the environment. Corrective actions are needed, but
immediate action is not necessarily required. Corrective actions
could be scheduled around site operations.
3. Local issues concerning housekeeping, storage, purchasing, or
similar items. Corrective actions are recommended, but not
necessarily required.
Depending on the magnitude of the problems identified and the
corrective actions recommended, a follow-up visit should be conducted
within 3 to 12 months after the audit.
Typical operational problems that are identified in environmental
audits are compressors and engines that are installed without state
permits or inventorying; gas plants and sweetening plants that are
installed or modified without considering new source performance
standards [NSPS] or prevention of significant deterioration [PSD]
monitoring, analysis, or control technology; unapproved analytical
methods that are used for determining compliance; and underground
injection wells that have not received the proper permits. Typical
problems with personnel training are field foremen who do not know
if hazardous substances are located at their site or how to report a
release to regulatory agencies if a release occurs, and engineering staff
who are not well informed of environmental design requirements.
One difficulty with performing an internal environmental audit is
that the U.S. Environmental Protection Agency can request a copy of
the audit under certain circumstances. Unless there is a commitment
by top management to correct any and all deficiencies found, the
existence of the audit could leave the company and its employees open
to regulatory action, including criminal penalties for willful violation
of the law for not implementing corrective measures.
A number of case histories on developing environmental audits for
oil and gas production facilities have been published (Guckian et al.,