EPA announces new audit policy (and self-reporting) to addresss significant noncompliance in oil and gas industry . . .

EPA announces new audit policy (and self-reporting) to addresss significant noncompliance in oil and gas industry . . .

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New Owner Clean Air Act Audit Program for Oil and Natural Gas Exploration and Production Facilities

New Owner Audit Program

The EPA is in the process of developing a New Owner Clean Air Act Audit Program tailored for the oil and natural gas sector. This program will provide environmentally protective efficiencies and certainty in the oil and natural gas sector based on the Agency’s analysis of the sector’s unique operations. We view this as an opportunity for timely and cost-effective Clean Air Act compliance.

The program initially will be made available to upstream exploration and production sites where EPA and states have seen significant noncompliance. We believe offering additional flexibilities under a specific and tailored new owner audit program will make it easier for the regulated community to self-disclose and correct violations, thereby providing additional protection for public health and the environment.

Standard Agreement

A key program component will require that companies assess storage tank battery vapor control system design as part of the audit process. EPA has developed a draft standard audit program agreement template, shown below, and will be conducting outreach and seeking feedback from states, tribes, the regulated community, environmental NGOs and other stakeholders on the draft agreement.

Submitting Comments about the Draft Agreement

  • EPA will accept comments on the draft standard audit program agreement until Monday, June 4, 2018.
  • Comments should be submitted to: Apple Chapman (chapman.apple@epa.gov), Tim Sullivan (sullivan.tim@epa.gov), and Christopher Williams (williams.christopher@epa.gov).
  • For questions regarding the draft, please contact Apple Chapman (Tel. 202-564-5666) or Tim Sullivan (Tel. 303-312-6196).

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