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Issues » Hot TopicsReasonable and Prudent Practices for Stabilization (RAPPS) at Oil and Natural Gas Exploration and Production Sites
The RAPPS described in this guidance were compiled by the Independent Petroleum Association of America and several other oil and gas trade associations and their members. The RAPPS guidance lists various operating practices and control measures used by oil and gas operators to effectively control erosion and sedimentation in storm water runoff from clearing, grading, and excavation operations at oil and gas exploration and production sites under various conditions of location, climate, and slope. After a producer determines that storm water runoff from clearing, grading, and excavation operations requires coverage under a construction general permit (CGP), the producer should consult the Environmental Protection Agency's or the state's Construction General Permit (CGP) to evaluate whether those permits require different or additional best management practices (BMPs) beyond the reasonable and prudent practices described in the RAPPS document. The RAPPS are suggestions of alternatives, from which one or more of the listed techniques or practices may be selected for a given site under site-specific circumstances. Not all RAPPS listed will necessarily be required for any given project. The list of RAPPS may not exhaust all of the available RAPPS that may be effective for any given construction site. Other RAPPS, not listed on the flowcharts in this document, may be beneficial for controlling surface water runoff from a construction site, in addition to or in lieu of the RAPPS listed in this document. Each topographic area type of the country is treated separately. Within each topographic area type, decision tree analyses are presented based on the percentage of vegetative cover and the distance to regulated water bodies. For each category, possible RAPPS are presented. As the instructions indicate, a producer may choose one or a combination of the RAPPS to control runoff from the construction site. The map on page 3 of the RAPPS document delineates the topographic areas of the country. Identify the area where the facility is located and then turn to the guideline under that particular area type to find the applicable RAPPS. Appendix A of the report describes each of the proposed RAPPS. Appendix B describes typical regulated water body crossings. For Xeric Plains, turn to Section 3.2 (page 8) of the document for a description of the type land involved and a discussion of factors to be considered in selecting a RAPPS. Page 9 provides the initial decision tree to make a RAPPS selection. For a particular facility, determine the relative percentage vegetative cover (see page A-1 and make a reasonable guess). Next, judge the slope of the area. Then, determine the distance from the edge of the construction site to the regulated water body (e.g., creek, stream, farmer's pond). These three factors will result in the list of possible RAPPS that can be used. Check the index (yellow box) to see what RAPPS are recommended for the facility location. A description of the RAPPS is found in Appendix A (pages A-2 thru A-17). Contact Ryan Ullman at rullman@ipaa.org if you have any questions or comments about the RAPPS guidance. Click here to download this document in Adobe Acrobat (PDF) format. (File size: 3.65 MB)
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