What Will Compliance in the Next Generation Look Like for New Oil and Gas Operations?

For the past few years, the U.S. Environmental Protection Agency (U.S. EPA) has been talking about a “…modern approach to compliance, taking advantage of new tools and approaches…” that they refer to as Next Generation Compliance.  Overall, Next Generation Compliance represents a multi-pronged approach intended to improve compliance across the nation.  The effort includes five (5) specific components including: Better permit and regulation design, use of advanced emissions/pollutant detection technology, electronic reporting, transparency (i.e., increased public access to information), and development of “innovative enforcement” approaches.  These components have resulted or will result in a heavy dose of electronic reporting with increased transparency to the public, increased and advanced monitoring (e.g., imaging of fugitive emissions), third-party verification of compliance, and other mechanisms that U.S. EPA is currently exploring.  Next Generation Compliance even has its own website.

So why should you be interested or concerned about this?

Why worry about something that you don’t have to do yet?

Next Generation Compliance is already happening!  Other industries and facilities are already complying with rules that have Next Generation Compliance components incorporated [e.g., 40 CFR Part 60, Subparts IIII and JJJJ (Reciprocating Internal Combustion Engines), 40 CFR Part 63, Subpart LLL (Portland Cement)].  The proposed Standards of Performance for Crude Oil and Natural Gas Facilities for New Sources (New Source Performance Standards or NSPS Subpart OOOOa) rule include several of these Next Generation Compliance mechanisms.  Mechanisms such as periodic fugitive emissions surveys using optical gas imaging (OGI) from well sites and compressor stations, leak detection and repair (LDAR) for open-ended valves or lines, electronic reporting through the Compliance and Emissions Data Reporting Interface (CEDRI) (which allows the public immediate electronic access to the report after U.S. EPA review), and more.

ALL4 has been busy helping clients in other sectors with monitoring plans, test data reporting and compliance demonstrations via U.S. EPA’s Electronic Reporting Tool (ERT), CEDRI, and Central Data Exchange (CDX).  Our experience has shown that electronic reporting can be a complex and time-consuming effort.  Don’t take it lightly!

As things happen, ALL4 will keep you updated on the status of the proposed rules, changes, and how they will affect your environmental compliance.  In the meantime, if you have any specific questions, please don’t hesitate to reach out to me at scunningham@all4inc.com or JP Kleinle at jkleinle@all4inc.com.