Responding to the Oil & Gas ICR Effectively.

Last March, the EPA announced its next step in reducing emissions from the oil and natural gas industry: moving to regulate emissions from existing sources. In May, the EPA issued a draft 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. Afterwards, the agency issued a Request for Information to seek commentary on innovative strategies that can accurately and cost-effectively locate, measure and mitigate methane emissions. The comment period on the ICR closed on August 2, 2016. EPA has stated that they expect to issue the ICR this fall.

With extensive experience serving the energy and oil and gas industries across the U.S., EDGE can help effectively manage company response programs. We have experience leading companies through Utility Maximum Achievable Control Technology (MACT) and Refinery MACT ICRs and subsequent rulemaking. We’ve assisted clients with their initial applicability reviews and reporting for the New Source Performance Standard (NSPS) Subpart OOOO and Greenhouse Gas Reporting Subparts C and W. Additionally, we have other oil and gas experience that required direct measurement of VOC emissions from oil and condensate storage tanks in the Dallas-Fort Worth area, as well as evaluation of VOC and hazardous air pollutant (HAP) emissions from produced water/saltwater storage tanks servicing oil and gas wells. These projects, which were managed by now EDGE personnel, give EDGE a unique insight into the operations of oil and gas facilities—insight that will prove beneficial in helping operating companies respond to the forthcoming ICR.

It is not too early to begin preparations for the ICR. If you plan on using a consultant to support this resource-intensive effort, then engage one now to facilitate preparations. Give us a call. We would love to buy you lunch and discuss a solution that makes sense for you.

Take the next step by contacting Chris Colville and George Holder for assistance in tackling this environmental challenge hurdle, and we look forward to providing further insight.


Sources:
EPA’s Actions to Reduce Methane Emissions
Proposed Information Collection Request
Upstream Oil and Gas Storage Tank Emission Measurements
Emission Factor Determination for Produced Water Storage Tanks