May 2018, the U.S. EPA (Environmental Protection Agency) announced an audit program targeting the E&P industry. This compliance and enforcement initiative indicates that there will be an increase of pressure at both the federal and state levels to focus on environmental compliance on the production and exploration in the oil and gas industry. In June 2018, the RRC (Texas Railroad Commission) announced that within the next five years, they intend to inspect every on-shore well in the state.
Texas, Oklahoma, and Wyoming, as well as many other states, have programs that help mitigate penalties at the state level by allowing them to achieve compliance. With the EPA’s proposed industry and media-specific audit and immunity program, they are signaling heightened enforcement heavily focused on the E&P sector. With a maximum per diem penalties for 2018 of $97,229 per violation for CAA violations, this should be a high priority for any business that is regulated by CAA compliance.
Just last month (June 2018), the RRC released its Oil and Gas Monitoring “Enforcement Plan.” The agency intends to increase the number of wells inspected to 80% in the fiscal year 2019 (That’s up from 42% in 2017). Furthermore, they stipulate that they will inspect all offshore wells in state waters every two years.
These environmental regulatory imposed requirements include limitations on venting and flaring VOCs, H2S monitoring and compliance, including equipment compatibility, public notice and contingency planning, and pit management and closure.
Well inspections will be prioritized by proximity to public or sensitive areas, operator’s compliance history, and knowledge or concerns specific to geographic location. Complaints and responses to emergencies will continue to receive the highest priority.
E&P companies should take these changes seriously and consider either gaining a thorough understanding of facility operations and compliance before any inspection or hire a company that can help them to become compliant.
OTA has real solutions. We have developed a proven process to help simplify environmental compliance. Our environmental department comes with extensive field experience and understanding of regulations to provide a well-rounded compliance consultation and report. Give us a call at 214-717-0775 or email us at compliance@OTACompression.com.
