A short presentation about the upcoming Mandatory request from the EPA to all known Oil and Gas Operators.

1. R. Scott Baber
Baber Environmental Assistance & Remediation, LLC
June 15, 2016

2. EPA Plans to Regulate Emissions from
Existing Oil and Gas Facilities
• The EPA’s first step is to ask industry how to gather information
• Once comments are received they send the “Non Voluntary” request
• Requests are sent via Section 114 Information Requests; response is
Mandatory

3. Summary
• EPA issued the final Quad Oa rule on Thursday May 12, 2016.
• The final rule was published in the Federal Register on June 3, 2016.
• Quad Oa is a New Source Performance Standard that regulates emissions from new or modified sources.
• Bundled within the Quad Oa rules was a request for comments on an Information Collection Effort; EPA’s initial attempt at regulating
existing facilities.
• This summary is focused on that proposed information request
• Agenda
• Request for Comments
• Regulatory Background
• Part 1
• Part 2
• Timing

4. Request for Comments
• Before the Information Collection Effort is begun the EPA is requesting
comments.
• The EPA is asking for comments on this information collection effort to be
submitted within 60 days of publication in the Federal Register (publication
was June 3, 2016 so comment period ends August 2, 2016).

5. Regulatory Background
• The information summarized herein is a summary of the initial collection
effort that was released on Thursday May 12, 2016 therefore it is an “As
Proposed” summary – the EPA may/will adjust the final request based on
comments received.
• The request is a way for EPA to learn more about existing facilities so they
can better regulate emissions from those existing facilities.
• These existing facilities will be regulated under Section 111(d) of the clean
air act.

6. Information Collection Effort
Part 1
• There will be two parts to the information collection.
• Part 1 (Operator Survey) will seek facility level information (e.g. facility name, location,
contact information, number of wells, tanks, and compressors) using the definition of
facility employed when permitting – not facility as defined by GHG rules.
• Part 1 will be sent to all known operators of oil and gas production wells and
specifically the onshore petroleum and natural gas production segments.
• Part 1 requires that the information be certified by the owner operator and may be
submitted either electronically or hard copy.
• Part 1 is estimated to have 22,500 respondents representing 698,800 facilities.

7. Information Collection Effort
Part 2
• Part 2 (Detailed Facility Survey) will collect detailed unit specific information on
emission sources and any emission control devices or management practices used to
reduce emissions.
• Part 2 will be sent to selected oil and gas facilities across onshore production,
gathering and boosting, processing, compression/transmission, pipeline, natural gas
storage, and LNG and storage/import/export facilities.
• Part 2 will request specific equipment counts, equipment leaks, measurement data,
and flash analyses.
• Part 2 will require samples of tank feed streams if not available.

8. Information Collection Effort
Part 2, continued
• Part 2 well types will be categorized in one of two ways – either by Gas to
Oil Ratio (GOR) or by regional groupings of basins (this method is used in
the GHG rule). The EPA will choose which method to use based on the
comments received from industry.
• Part 2 must be submitted electronically through the EPA Electronic
Greenhouse Gas Reporting Tool (e-GGRT).
• Part 2 is estimated to have 3,385 respondents, the number of affected
facilities was not listed.

9. Information Collection Effort
Timing
• The publication in the Federal Register was June 3, 2016
• Comments are due within 60 days of publication (August 2, 2016)
• The EPA will be using their authority under Section 114 (Request For Information) of the
clean air act, response is mandatory.
• EPA anticipates sending Section 114 letters by October 30, 2016.
• Part 1 surveys will be due within 30 days of receipt.
• Part 2 surveys will be due within 120 days of receipt.
• https://www.federalregister.gov/articles/2016/06/03/2016-11967/proposed-information-
collection-request-comment-request-information-collection-effort-for-oil-and

10. Contact Information
• R. Scott Baber
• Baber Environmental Assistance & Remediation
• Phone: 405-659-8115
• Scott@BaberEnvironmental.com