Second Draft EPA Mandatory Information Collection Request (ICR) for Oil and Gas Facilities
October 9, 2016

On September 29, 2016, the EPA published the Second Draft Information Collection Request (ICR) for the Oil and Natural Gas Industry. The ICR will collect emission inventory related data that will be used to develop emission standards (reductions) for existing facilities. Existing facilities that are exempt from NSPS OOOO and OOOOa are the target of this data request. The EPA is using its authority under Section 114 of the Clean Air Act to request the information.

This is a one-time survey that seems to be on track for a data submittal to the EPA before the end of 2016. See link: ICR 2nd Draft for details.

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Facility Types Impacted

  • The ICR surveys requests information for onshore oil and gas industry.
  • The notification specifies that the surveys do not include offshore facilities or natural gas distribution facilities.
  • Part 1 reporting is required for Centralized Production Surface Sites and Well Surface Sites as defined in the EPA’s Part-1 Operator Survey form in Excel format.
  • Part 2 reporting will specify the specific facility required to report.

Operator Survey (Part 1)

  • The Operator Survey will be sent to ALL known operators of oil and gas production wells.
  • Gathers data for “Centralized Production Surface Sites” and “Well Surface Sites” as defined in the ICR part 1 form: operator survey (excel). This is a change from the first draft.
  • 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
    • Location
    • Contact information
    • Well ID
    • Well type (stripper or based on GOR)
    • Specify if well hydraulically fractured
    • Number of separators,
    • Presence of flare or thermal combustor
    • Number of storage tanks and number of tank producing >10 BOPD
    • Number of compressors (recip, centrifugal) and glycol dehydrators
    • Use of well unloading
    • Specify whether produces natural gas and/or crude oil or condensate for sales.
  • 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 is not expected to contain any Confidential Business Information (CBI)

Detailed Facility Survey (Part 2)

The Detailed Facility Survey will to collect information on emissions sources and control devices used at production facilities.

The instructions state that generally no additional testing required except as specified in the survey form. The exception is for collection and chemical analysis of a pressurized sample from each separator/heater treater that dumps material (oil, produced water) to an atmospheric storage tank. The CARB Method is required.

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:

  • Facility data
  • Facility status (manned/unmanned), distance to nearby field office, electricity availability
  • Natural gas, crude oil, condensate, produced water production rates
  • Sales gas chemical composition (most recent available)
  • Pipelines length, pig launchers and receivers
  • Voluntary CH4 reductions via EPA STAR program or EPA Methane Challenge
  • Emission control devices (vapor recovery units, flare, enclosed combustion devices)
  • Production Wells including gas and oil prices, royalty rates, severance tax rate, other taxes
  • Injection/Storage Wells
  • Tanks/Separators for crude oil, condensate and natural gas production and storage.
    • Requires separator/heater treater pressurized sample for flash gas determination using CARB method
  • Pneumatic pumps – air driven and natural gas driven
  • Pneumatic controllers – air driven and natural gas driven
  • Gas sweetening units
  • Dehydrators
  • Fugitive equipment counts, applicable regulations, and operation leak monitoring used
  • Compressors
  • Blowdown of gas

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Estimated Number of Companies and Facilities Impacted

  • Operator Survey:  15,000 operators
  • Detailed Facility Surveys:  3,818

 Method of Data Submittal

  • The Part 1 Production 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 mailed.
  • The Part 2 Detailed Facility Survey will use the EPA’s Electronic Greenhouse Gas Reporting Tool (e-GGRT) online system for data form submittal.
  • To submit Part 2 Detailed Facility Survey 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.
  • All submittals must be certified by a person authorized to make the submission.

 Updated Timeline for Submittal

  • Based on a comments due by October 31, 2016, expect the ICR letters in early November 2016, if EPA is intent on obtaining responses for Part 1 by the end of 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

Comments on Requested Second Proposed ICR and Draft Forms

  • Comments are requested on the draft forms.
  • 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 are due on or before October 31, 2016
  • Submit your comments, referencing Docket ID Number EPA–HQ–OAR–2016–0204, to (1) EPA online using www.regulations.gov (preferred method), by email to [email protected]

Get Ready NOW

Operators should prepare now for the data collection, form completion, certification and submittal.

With an expected date of early November 2016 for the surveys to be sent out, operators should start now gathering data. The due date will occur during the November/December holiday season.

Some steps you can do now to prepare for the Operator Survey are listed below.

  1. Review the second 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.
  2. 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:
    1. List of wells producing, temporarily abandoned, abandoned, injection, and storage
    2. List of wells hydraulically fractured
    3. List of wells that use liquids unloading
    4. Gas-to oil ratio
  3. Number of separators at each facility (not normally included in air permit applications).
  4. 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.

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.