The U.S. Environmental Protection Agency (EPA) and several states have implemented, or propose to implement, new environmental regulations targeting air emission reductions from oil and gas facilities, including, for example, NSPS OOOO. As these programs mature, the industry is tasked with establishing increasingly complex compliance programs, including facilities that have not previously been subject to significant regulatory attention. While most operators have traditionally dealt with requirements established by the state oil and gas commissions, these regulations present a new type of concern for operators. Establishing systematic procedures and protocols can assist operators in meeting their compliance obligations in a consistent and defensible manner. The new air regulations often require testing or other observations, tracking data, and reporting obligations. Colorado’s recently finalized Regulation 7 requirements often require the use of infrared cameras to observe hydrocarbon leakage from equipment, as well as audible, visual and olfactory (AVO) observations. While state regulations may not require procedures, training, or recordkeeping formats, it is in the operators’ best interest to establish these steps to meet their internal requirements as well as establishing defensible data to demonstrate ongoing compliance. For example, if an infrared camera is used to detect hydrocarbon leaks, establishing a monitoring protocol ensures that the monitoring is conducted consistently, and that leak records will be tracked appropriately. A work practice procedure will establish responsibilities for tracking any discovered leaks, implementing maintenance requirements, and maintaining records to demonstrate compliance. When local operating personnel are responsible for compliance, establishing a training program and appropriate recordkeeping provisions will also help to ensure consistent program implementation. By establishing a systematic compliance effort, oil and gas operators can implement cost-effective strategies to meet these new compliance obligations. The optimal compliance approach will vary between operators based on internal resources and systems, and may require increasing staff resources or using external resources to meet these increasingly complex requirements. It is important for operators to consider these factors now to avoid unnecessary compliance hurdles down the road.
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