STRONGER
STRONGER
State
State
Review
Review
Process
Process
Presentation
to
the
EPA
Presentation
to
the
EPA
May
2005
May
2005
Lori
Wrotenbery
Lori
Wrotenbery
1980
RCRA
Amendments
1980
RCRA
Amendments

EPA
study
(
1986
EPA
study
(
1986­
87)

87)


EPA
regulatory
determination
(
1988)

EPA
regulatory
determination
(
1988)


Found
state
and
federal
regulation
to
be
Found
state
and
federal
regulation
to
be
generally
adequate
generally
adequate

Recognized
regulatory
gaps
and
inadequate
Recognized
regulatory
gaps
and
inadequate
enforcement
enforcement

Developed
a
three
Developed
a
three­
pronged
approach:

pronged
approach:


Improve
existing
programs
under
RCRA,
Safe
Improve
existing
programs
under
RCRA,
Safe
Drinking
Water
Act,
and
Clean
Water
Act
Drinking
Water
Act,
and
Clean
Water
Act

Work
with
states
to
improve
their
programs
Work
with
states
to
improve
their
programs

Work
with
Congress
on
any
additional
Work
with
Congress
on
any
additional
legislation
that
might
be
needed
legislation
that
might
be
needed
State
Review
Process
State
Review
Process

1989
1989
­
IOGCC
Council
on
Regulatory
Needs
IOGCC
Council
on
Regulatory
Needs

1990
1990
­
Published
first
Guidelines
and
began
Published
first
Guidelines
and
began
state
reviews
state
reviews

State
State­
by
by­
state
reviews
of
regulatory
programs
state
reviews
of
regulatory
programs
against
the
published
Guidelines
against
the
published
Guidelines

Conducted
by
multi
Conducted
by
multi­
interest
stakeholder
teams
interest
stakeholder
teams

Result
in
written
report
of
findings
and
Result
in
written
report
of
findings
and
recommendations
recommendations

30
reviews
of
19
state
programs
conducted
to
30
reviews
of
19
state
programs
conducted
to
date
date
Purposes
of
State
Reviews
Purposes
of
State
Reviews

To
evaluate
state
oil
and
gas
programs
against
To
evaluate
state
oil
and
gas
programs
against
published
Guidelines
published
Guidelines

To
measure
To
measure
the
effectiveness
of
program
the
effectiveness
of
program
implementation
implementation

To
document
program
strengths
To
document
program
strengths

To
identify
and
recommend
areas
for
state
program
To
identify
and
recommend
areas
for
state
program
improvement
improvement

To
share
new
or
innovative
program
elements
To
share
new
or
innovative
program
elements

To
increase
the
understanding
of
the
regulatory
To
increase
the
understanding
of
the
regulatory
process
by
all
stakeholders
process
by
all
stakeholders

To
promote
consistency
among
state
programs,

To
promote
consistency
among
state
programs,

while
allowing
flexibility
to
address
unique
while
allowing
flexibility
to
address
unique
circumstances
circumstances
2000
Guidelines
2000
Guidelines
Section
1
Section
1   

   
Introduction
Introduction
Section
2.

Section
2.  
  ...
Scope
of
the
Guidelines
Criteria
...
Scope
of
the
Guidelines
Criteria
Section
3
Section
3   

   
General
Criteria
General
Criteria
Section
4
Section
4   

   
Administrative
Criteria
Administrative
Criteria
Section
5
Section
5   

   
Technical
Criteria
Technical
Criteria
Section
6
Section
6   

   
Abandoned
Sites
Abandoned
Sites
Section
7
Section
7   

   
NORM
NORM
Section
8
Section
8   

   
Performance
Measures
Performance
Measures
Section
9
Section
9   

   
Recommendation
for
Future
Work
Recommendation
for
Future
Work
2005
Guidelines
Revisions
2005
Guidelines
Revisions

Updating
and
Clarification
Updating
and
Clarification

Enhanced
Oilfield
Spill
Risk
Management
Enhanced
Oilfield
Spill
Risk
Management

Enhanced
Program
Performance
Enhanced
Program
Performance
Measurement
Measurement

Storm
Water
Management
Storm
Water
Management
Stormwater
Guidelines
Stormwater
Guidelines

New
section
of
Guidelines
New
section
of
Guidelines

Drafted
by
stakeholder
team
with
state,

Drafted
by
stakeholder
team
with
state,

industry,
and
public
interest
participation
industry,
and
public
interest
participation

State
programs
may
be
rule
State
programs
may
be
rule­
based
or
rely
on
based
or
rely
on
operator
operator­
specific
plans
specific
plans

STRONGER
may
place
links
to
state
and
other
STRONGER
may
place
links
to
state
and
other
BMPs
on
its
website
as
a
resource
BMPs
on
its
website
as
a
resource
Guidelines
Revision
Guidelines
Revision
Timetable
Timetable

Draft
Guidelines
published
May
1,
2005
Draft
Guidelines
published
May
1,
2005

Comments
requested
by
June
17,
2005
Comments
requested
by
June
17,
2005

Revised
draft
to
be
published
by
August
Revised
draft
to
be
published
by
August

Review
by
IOGCC
in
September
Review
by
IOGCC
in
September

Implementation
of
new
Guidelines
beginning
in
Implementation
of
new
Guidelines
beginning
in
2006
2006
State
Review
Process
State
Review
Process
Strengths
Strengths

Guidelines
standards
established
by
stakeholders
Guidelines
standards
established
by
stakeholders

Guidelines
recognize
regional
differences
Guidelines
recognize
regional
differences

Focus
on
program
performance
Focus
on
program
performance

Reviews
performed
by
multiple
stakeholder
teams
Reviews
performed
by
multiple
stakeholder
teams

Reviews
document
program
strengths
and
Reviews
document
program
strengths
and
opportunities
for
improvement
opportunities
for
improvement

Follow
Follow­
up
reviews
are
conducted
up
reviews
are
conducted

Process
can
fill
regulatory
gaps
Process
can
fill
regulatory
gaps

Process
is
a
model
for
evaluation
of
other
Process
is
a
model
for
evaluation
of
other
environmental
regulatory
programs
environmental
regulatory
programs
