By Scott Bellinger
Michigan Oil and Gas News
WASHINGTON — The U.S. Environmental Protection Agency (EPA) will require owner / operators of oil and gas facilities to complete and submit surveys requesting information about the facilities as part of an effort to develop standards for methane emissions for the oil and gas industry under the Clean Air Act (CAA).
A notice of the EPA’s submission of an information collection request, or ICR, titled “Information Collection Effort for Oil and Gas Facilities,” to the Office of Management and Budget (OMB) for review and approval was published in the Federal Register on Sept. 29, 2016, along with a description of the two-part information collection.
A public comment period previously requested via the Federal Register on June 3 was extended for an additional 30 day by the notice, with comments on the ICR now due on or before Oct. 31, 2016.
According the Sept. 29 Federal Register notice, oil and gas facilities are, collectively, the largest emitters of methane in the U.S. EPA notes that while a great deal of information is available to provide a technical foundation to support its recent actions, it now seeks more specific information for use in addressing existing source emissions pursuant to CAA section 111(d).
New or modified sources of methane emissions are subject to EPA regulations issued under 40 CFR Part 60 Subpart OOOO and the subsequently issued Subpart OOOOa, commonly referred to as “Quad O” and “Quad Oa.” The new information collection addresses emissions from previously existing sources only.
The information collection will be conducted in two parts:
• Part 1, an operator survey, is designed to obtain information from onshore oil and gas production facilities to better understand the number and types of equipment at production facilities.
• Part 2, a detailed facility survey, will be sent to selected oil and gas facilities across the different industry segments and will collect unit-specific information on emission sources at the facility and any emission control devices or management practices used to reduce emissions.
The Sept. 29 Federal Register notice states that EPA anticipates sending letters to facility owner / operators by late October 2016. The letters would require the owner / operators to complete and submit the Part 1 survey within 30 days of receipt of the survey and would require facilities receiving a Part 2 survey to complete and submit the survey within 120 days of receipt.
EPA estimates that 15,000 operators representing approximately 698,800 facilities will be required to submit the Part 1 survey. The estimated number of respondents for Part 2 is 3,818.
A draft mailing list of owner / operators of oil and gas production facilities that are scheduled to receive letters regarding the surveys may be accessed at https://oilandgasicr.rti.org.
EPA requests that companies add missing information into the list and provide appropriate email addresses for facility / company contacts when possible, as they intend to distribute the ICR materials electronically via email.
Instructions on that website indicate companies should first register on the website, then search by operator, facility, company or corporation using the search fields provided.
A list of facilities matching the search criteria will be provided when the “Search” button is pressed. Information for each entry may be viewed and revised, if necessary.
If a facility or company cannot be located, it may be added to the list.
Further information on submitting comments on the ICR and on the surveys may be found at https://www.federalregister.gov/documents/2016/09/29/2016-23463/information-collection-request-submitted-to-omb-for-review-and-approval-comment-request-information.