Building a Sustainable Data Management Program in the Upstream Oil and Gas Industry

摘要

A key challenge to sustainable air quality compliance programs is the gathering and management of data across the lifecycle of operations. In recent years, US Environmental Protection Agency (EPA) has promulgated and/or amended a number of regulatory drivers that affect the upstream oil and gas (O&G) industry, including the Greenhouse Gas Reporting Program (GHGRP), specifically Title 40 Code of Federal Regulations (CFR) Part 98 Subpart W, New Source Performance Standards (NSPS) 40 CFR 60 Subpart OOOO, National Emissions Standards for Hazardous Air Pollutants (NESHAP) 40 CFR 63, specifically Subpart HH and Subpart ZZZZ, etc. Within each of these regulatory requirements, there are a number of similar and potentially overlapping data parameters which must be gathered, quality assured, recorded, and managed to demonstrate compliance with each regulation. Implementing an integrated data management system allows for more efficient, streamlined reporting which will minimize value erosion and compliance risk while maximizing future value creation. A strategically designed and maintained data repository will provide reliable documentation of compliance in the event of an EPA, state, or internal audit. One of the cornerstones of a sustainable data management program is stakeholder engagement at the facility, operations, environmental, and corporate levels, as applicable. Engagement of the right stakeholders can help identify existing data systems which are already in place, thereby improving efficiency. A sustainable data management program can be built to take advantage of existing systems as available, which will reduce additional burden in data collection efforts. Key data management challenges for regulatory compliance across the exploration and production segment of the O&G industry will be discussed in this paper, along with a phased approach to building a sustainable data management system. Key components of a sustainable data management program include identification and closure of compliance gaps, data mapping and documentation, implementation of data flow procedures for contractors and sub-contractors, management of change (MOC), and ensuring a system is robust enough to handle personnel changes. Mechanisms to implement a sustainable data management program, including environmental management information systems (EMIS), will be explored.