EPA Issues Final Information Collection Request (ICR) for the Oil and Natural Gas Industry



On November 10, 2016, the US EPA issued a final Information Collection Request (ICR) for oil and gas companies.  According to EPA, the information collected will be used to develop regulations to reduce methane emissions and emissions of other air pollutants from oil and gas sources.  The oil and gas industry segments included in this ICR include:  onshore petroleum and natural gas production; onshore petroleum and natural gas gathering and boosting; onshore natural gas processing; onshore natural gas transmission compression; onshore natural gas transmission pipelines; underground natural gas storage; LNG storage; and LNG import and export equipment.

There will be 2 parts to the information collection.

  • Part 1 Operator Survey:  This form will collect comprehensive information from onshore petroleum and natural gas production facilities in order to better inform EPA of the number and types of equipment at production facilities.  Operators will be required to provide information regarding their company (facility name, address, contact information) as well as location and types of equipment (i.e. number and location of wells, tanks, dehydrators, and compressors) present at well surface sites and centralized production surface sites.  The form will also require operators to identify which wells feed into each centralized production surface site.

    It is expected that all oil and gas producers will receive a Part one Operator survey.

  • Part 2 Facility Survey:  This form will collect detailed, unit specific information on emission sources at specific facilities, as well as emission control devices or management practices used to reduce emissions.  Operators must provide actual component and equipment counts (pneumatic device count and equipment leak component counts), measurement data (separator/storage vessel flash analyses), and operational data (pressures and temperatures of operating equipment, for example).

    EPA expects to send 4,656 Part 2 questionnaires across the entire oil and gas industry segment.

The final ICR reflects EPA's considerations of the comments provided by the regulated community and others on the draft ICR.  EPA has made the following changes from the draft ICR in an attempt to lessen the industry burden including:

  • The final ICR provides owners and operators 60 days to respond to the operator survey and 180 days to respond to the facility survey (as opposed to 30 and 120 days, respectively).
  • Since the Gas to Oil ratio (GOR) indicates whether primary product of a well site is likely to be oil or gas, the wells will be categorized by the GOR.  This will give EPA information about the types of equipment at the site.
  • Many questions (i.e. questions about access to electricity, the number of facilities that are manned or unmanned, liquids unloading, and hydraulic fracturing ) have been moved from the operator survey (part 1) to the more specific facility survey (part 2).
  • The final ICR splits the gathering and boosting segment into compressor stations and pipeline facilities in the facility survey.
  • The final ICR allows owners/operators to use one of three Gas Processors Association (GPA) sampling methods for pressurized liquids sampling; the draft ICR only allowed for one method (the CARB method).
  • EPA has clarified that the person or entity owning or operating a facility at the time of receipt of the ICR letter will be responsible for responding to the ICR.
  • The final ICR clarifies that the facility survey (e.g., the part 2) will not request detailed information on every well in the industry.  It will focus the detailed information requests on randomly selected wells.

The letters are expected to be mailed via registered mail on or near November 15, 2016.  Response to the ICR is mandatory under Section 114 of the Clean Air Act.  For more information regarding the ICR, or for more information how Trinity can assist, contact Georgette Reeves by email, or by phone at (512) 349-5800.