On September 23, 2016 EPA issued the second draft of an Information Collection Request (ICR) to require oil and natural gas companies to provide extensive information needed to develop regulations to reduce methane emissions from existing oil and gas sources. EPA clarified that the facility survey will not request detailed information on every well in the industry; rather, it will focus the detailed information request on randomly selected wells, asking for details on those wells, other wells and equipment at that same surface site as the randomly selected well(s) and the centralized production sites those wells feed. EPA expects to issue the CAA Section 114 letters to the industry by late October, 2016. These letters will require that the owner/operator of an oil and gas facility complete and submit the Part 1 survey within 30 days of receipt of the survey, and facilities complete and submit the Part 2 survey within 120 days of receipt.
Though the revised ICR surveys are very similar to the drafts released on May 12, 2016, there are a few notable differences:
1) The Part 1 survey now differentiates data requests between centralized facilities and well surface sites.
2) In addition to all of the physical and operational data requested in Part 2 for production wells, EPA is now additionally requesting financial data:
-“Estimated annual fixed O&M cost for the well in 2015 ($/yr)”
-“Estimated variable O&M cost for the well in 2015 ($/BOE)”
-“With current prices, how long do you expect the well to produce economically?”
3) The Part 2 survey includes a new request for injection storage wells.
4) The Part 2 survey now includes VOC potential-to-emit and VOC and speciated hydrocarbon actual emissions.
EPA estimates the industry cost of responding to the ICR at about $37 million.
The second draft ICR will be available for public comment for 30 days after the Federal Register publishes a notice of its availability. For more information, see the EPA ICR Announcement.