The EPA intends to collect emission inventory related data from the oil and gas industry to gather information that will be used to develop emission standards (reductions) for existing facilities.
The New Source Performance Standards in 40 CFR 60 Subpart OOOO and OOOOa exempt existing oil and gas facilities that were constructed on or prior to August 23, 2011 (and not modified or reconstructed after that date). These “existing” facilities are the target of this data collection.
The method that will be used to obtain the data is an Information Collection Request (ICR). The EPA is not required to go through rulemaking to request this information. EPA has authority under Section 114 of the Clean Air Act to request the information provided the request is approved by the Office of Management and Budget (OMB).
Comments on Proposed ICR and Draft Forms
- Comments are requested on the need for the survey, whether the request will have a practical utility, to ensure appropriate data collected and the amount of burden on operators.
- The draft Operator Survey and Detailed Facility Survey forms were posted online for review. To download a copy of draft forms, see link: https://www3.epa.gov/airquality/oilandgas/methane.html
- Comments on the draft forms will help ensure the right information is collected and to obtain industry, nongovernmental organization and public input.
- Comments are due on or before August 2, 2016
- Submit comments, referencing Docket ID No. EPA–HQ–OAR–2016–0204, online using www.regulations.gov (preferred method), or by mail to: EPA Docket Center (EPA/DC), Environmental Protection Agency, Mail Code 28221T, 1200 Pennsylvania Ave. NW., Washington, DC 20460.
Method of Data Submittal
- The Operator Survey data may be submitted in hardcopy format to the address given in the ICR letter or electronically at https://oil&gasicr.rti.org/ - to be activated after ICR letters are sent out.
- The Detailed Facility Survey will use the EPA’s Electronic Greenhouse Gas Reporting Tool (e-GGRT) online system for data form submittal.
- To submit data online, you will need a CDX account or an e-GGRT account. You should be able to use the same account as used to report data for the Greenhouse Gas reporting rule.
- Expect EPA to give guidance on how to submit the data using the required forms.
Timeline for Submittal
- EPA anticipates issuing the CAA section 114 letters requesting ICR data by October 30, 2016.
- Expect that the Operator Survey and Detailed Facility Survey letter(s) would be mailed on the same dates.
- Operator Survey due date: within 30 days of request letter receipt
- Operator Survey data expected to be submitted before end of December 2016
- Detailed Facility Survey due date: within 120 days of letter receipt
Estimated Number of Companies and Facilities Impacted
- Operator Survey: 22,500 operators
- Detailed Facility Surveys: 3,385
Facility Types Impacted
- The ICR surveys will request information for onshore petroleum and natural gas production facilities.
- The “facility” definition used for the ICR is similar to the one employed by State regulatory agencies for air permitting new and existing oil and gas production facilities. This is different from the categories (production versus gathering and boosting) used in 40 CFR 60 Subparts OOOO and OOOOa and used in 40 CFR 98 Subpart W – Greenhouse Gas Reporting.
- Oil and gas well data that is proposed to be reported uses similar data that is required for 40 CFR 98 Subpart W – Greenhouse Gas Reporting
Operator Survey (Part 1)
- The Operator Survey will be sent to ALL known operators of oil and gas production wells.
- The survey collects information that will be used to identify and categorize all potentially affected oil and gas production facilities.
- It is designed to obtain readily available information on the number and types of equipment at all onshore oil and gas production facilities in the United States.
- Facility level information proposed for collection is for ALL oil and gas facilities and wells that a company operates. Some of the proposed data required includes:
- Company contact information
- Facility name, ID and permit number
- Contact information
- Facility status (manned/unmanned), distance to nearby field office, electricity availability
- Total number of wells with API Number or Well Number
- Number of wells hydraulically fractured or re-fractured
- Number of producing and abandoned or capped wells
- Number of separators
- Number of storage tanks and number of tank producing >10 BOPD
- Number of compressors
- Presence of a combustor or flare at the facility
- The facility definition that is commonly employed when permitting new and existing sources is used. This includes all buildings, equipment, structures, and other stationary equipment that are located on one or more contiguous or adjacent properties and that are under common ownership or control. See link: Source Determination for Certain Emission Units in the Oil and Natural Gas Sector
- Operators will complete the survey form, including equipment counts for all oil and gas production facilities that they operate with the exception of facilities selected to complete the Detailed Facility Survey.
- The Operator Survey not expected to contain any Confidential Business Information (CBI).
- This Operator Survey may be submitted either electronically or by hardcopy. The owner or operator must certify that the information being provided is accurate and complete.
Detailed Facility Survey (Part 2)
The Detailed Facility Survey will to collect information on emissions sources and control devices used at production facilities. The data proposed to be collected include emission inventory detailed data (similar to that required in an air permit application) for the following emission sources and processes:
- Natural gas, crude oil, condensate, produced water production rates
- Natural gas composition
- Well specific data
- Gas sweetening units
- Fugitive equipment counts
- Blowdown of gas
- Pneumatic pumps – air driven and natural gas driven
- Pneumatic controllers – air driven and natural gas driven
- Emission control devices (vapor recovery units, flare, enclosed combustion devices)
Get Ready NOW
Since all operators will get the Operator Survey, it is prudent for all operators to prepare now for the data collection and submittal.
The timeline to complete and submit the survey does not give operators much time: within 30 days for the Operator Survey and 120 days for the Detailed Survey. With an expected date of October 30, 2016, for the surveys to be sent out, operators should start now gathering data. Of course, the data requested in the finalized survey forms could require less or more data – depending on comments and OMB approval.
Some steps you can do now to prepare for the Operator Survey are listed below.
- Review the draft “Part 1. Production Operator Survey” forms for a list of data that may be required. The list below is not definitive and subject to change in final ICR.
- Prepare a list of all oil and gas wells with API or Well ID number (including producing, capped or abandoned and injection wells) and also:
- List of wells capped or abandoned
- List of wells hydraulically fractured
- List of wells that use well unloading
- Prepare a list of all oil and gas production facilities you operate with status as manned or unmanned and whether electricity available.
- Number of separators at each facility (not normally included in air permit applications).
- Gather copies of air permit applications and air permits for facilities you operate. These documents can help complete the Operator and Detail survey forms. The air permit application used to generate an air permit will have a greater level of detail regarding emission sources than the air permit for a facility.
- Map (with scale) of production facilities with nearby field offices and gas gathering pipelines.
HY-BON/EDI ICR Services
HY-BON/EDI can assist your company in completing the survey forms as a part of our services. Our trained IQR field staff and engineers are well versed in the inventory and emission controls data that the ICR survey forms will require. We can ensure that data is gathered, verified and the forms completed so that you meet the required deadlines. Call us now on how we can help you comply with this requirement.