On May 4, 2018, the EPA made available for public comment a draft standard audit program agreement tailored for new owners of oil and natural gas exploration and production facilities. As stated in the draft agreement:
“The oil and natural gas exploration and production sector is a dynamic energy-producing industry where facilities are routinely transferred in asset sales and other business transactions. Auditing newly acquired oil and natural gas exploration and production facilities' compliance with environmental laws and regulations is a key way in which oil and natural gas exploration and production companies can help ensure responsible domestic energy production.”
Information on the audit program is available on the EPA website.
The draft agreement focuses on Clean Air Act compliance and requires correction of any violations discovered. It includes several appendices. One addresses the design and sizing of vapor control systems, as well as operating procedures for field surveys of those systems. Another specifies the preparation of audit protocols, checklists, semiannual reports, and a final report, as well as recordkeeping requirements that address confidentiality and retention times.
EPA will accept comments on the draft standard audit program agreement until Monday, July 2, 2018. Trinity is offering a complimentary webinar on July 19, which will include an overview of the proposed program, discuss audit material development, and address how this policy works in parallel with state-level programs.
Register online to attend the webinar.
Trinity has collaborated with oil and gas companies across the U.S. on air quality audits and can offer practical assistance to prepare for and conduct programs tailored to your needs. Contact Trinity at (800) 229-6655 for help with environmental compliance and audits.