R. Scott BaberBaber Environmental Assistance & Remediation, LLC

June 15, 2016

EPA Plans to Regulate Emissions from Existing Oil and Gas Facilities• The EPA’s first step is to ask industry how to gather

information• Once comments are received they send the “Non

Voluntary” request• Requests are sent via Section 114 Information Requests;

response is Mandatory

Summary• EPA issued the final Quad Oa rule on Thursday May 12, 2016.

• The final rule was published in the Federal Register on June 3, 2016. • Quad Oa is a New Source Performance Standard that regulates emissions from new or modified sources. • Bundled within the Quad Oa rules was a request for comments on an Information Collection Effort; EPA’s

initial attempt at regulating existing facilities.

• This summary is focused on that proposed information request• Agenda

• Request for Comments• Regulatory Background• Part 1• Part 2• Timing

Request for Comments

• Before the Information Collection Effort is begun the EPA is requesting comments.

• The EPA is asking for comments on this information collection effort to be submitted within 60 days of publication in the Federal Register (publication was June 3, 2016 so comment period ends August 2, 2016).

Regulatory Background

• The information summarized herein is a summary of the initial collection effort that was released on Thursday May 12, 2016 therefore it is an “As Proposed” summary – the EPA may/will adjust the final request based on comments received.

• The request is a way for EPA to learn more about existing facilities so they can better regulate emissions from those existing facilities.

• These existing facilities will be regulated under Section 111(d) of the clean air act.

Information Collection Effort Part 1

• There will be two parts to the information collection.• Part 1 (Operator Survey) will seek facility level information (e.g. facility name,

location, contact information, number of wells, tanks, and compressors) using the definition of facility employed when permitting – not facility as defined by GHG rules.

• Part 1 will be sent to all known operators of oil and gas production wells and specifically the onshore petroleum and natural gas production segments.

• Part 1 requires that the information be certified by the owner operator and may be submitted either electronically or hard copy.

• Part 1 is estimated to have 22,500 respondents representing 698,800 facilities.

Information Collection Effort Part 2

• Part 2 (Detailed Facility Survey) will collect detailed unit specific information on emission sources and any emission control devices or management practices used to reduce emissions.

• Part 2 will be sent to selected oil and gas facilities across onshore production, gathering and boosting, processing, compression/transmission, pipeline, natural gas storage, and LNG and storage/import/export facilities.

• Part 2 will request specific equipment counts, equipment leaks, measurement data, and flash analyses.

• Part 2 will require samples of tank feed streams if not available.

Information Collection Effort Part 2, continued

• Part 2 well types will be categorized in one of two ways – either by Gas to Oil Ratio (GOR) or by regional groupings of basins (this method is used in the GHG rule). The EPA will choose which method to use based on the comments received from industry.

• Part 2 must be submitted electronically through the EPA Electronic Greenhouse Gas Reporting Tool (e-GGRT).

• Part 2 is estimated to have 3,385 respondents, the number of affected facilities was not listed.

Information Collection Effort Timing

• The publication in the Federal Register was June 3, 2016• Comments are due within 60 days of publication (August 2, 2016) • The EPA will be using their authority under Section 114 (Request For

Information) of the clean air act, response is mandatory.• EPA anticipates sending Section 114 letters by October 30, 2016.• Part 1 surveys will be due within 30 days of receipt.• Part 2 surveys will be due within 120 days of receipt.• https://

www.federalregister.gov/articles/2016/06/03/2016-11967/proposed-information-collection-request-comment-request-information-collection-effort-for-oil-and

Contact Information

• R. Scott Baber• Baber Environmental Assistance & Remediation• Phone: 405-659-8115• Scott@BaberEnvironmental.com