On November 10, 2016, EPA released the final edition of the Information Collection Request (ICR) for the Oil and Natural Gas Industry. The key purpose of the ICR is to provide information to EPA in order to create new rulemaking under Section 111(d) of the Clean Air Act (CAA) for EXISTING sources of Methane in the upstream and midstream oil and natural gas sectors.
Letters will be sent to operators via registered mail under Section 114 of the CAA and response will be mandatory for all recipients. Some changes from the draft ICRs includes a new deadline of 60 days to complete Part 1 Surveys and 180 days to complete Part 2 Surveys, moving some questions from the Part 1 Survey to the Part 2 Survey, splitting the Gathering and Boosting segment for ease of understanding, and changing the requirements for pressurized liquid sampling for separators with a throughput of more than 10 barrels per day.
Information on the ICR can be found here: https://www.epa.gov/controlling-air-pollution-oil-and-natural-gas-industry/oil-and-gas-industry-information-requests
The following information comes from EPA’s fact sheet :
What the Final ICR Covers
- The ICR seeks information from the following segments of the oil and gas industry: onshore production, gathering and boosting, gas processing, transmission, storage, and liquefied natural gas (LNG) import/export. It does not request information from offshore production or local natural gas distribution facilities that provide gas to businesses and homes.
- Like the two draft ICRs that were made available for public comment earlier in 2016, the final ICR comprises two parts:
- An “operator survey” 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; and
- A “facility survey,” to collect detailed information on emissions sources and emissions control devices or practices in use at facilities in the onshore production, gathering and boosting, processing, compression/transmission, pipeline, natural gas storage, and LNG storage and import/export facilities. EPA expects much of the information requested in the facility survey to be readily available from company records; however, owners/operators may have to collect some information – such as counts of pneumatic devices. This more detailed survey will be sent to a representative sample of facilities rather than to all facilities, in order to reduce the burden to the industry.
The operator survey will be sent to approximately 15,000 owners/operators in the oil and gas industry; the more detailed facility will be sent to approximately 4,650 owners/operators.
If you have any questions, contact Joe Pere at 512-474-9097 or Joe.Pere@Cook-Joyce.com.