EPA Developing Self-audit Policy for New Oil and Gas Owners

Posted on 2/1/2019 by Roger Marks

EPA is developing a new Clean Air Act audit policy that would give new owners of oil and natural gas exploration and production facilities nine months to self-inspect their operations, disclose violations to EPA, and correct any violations they find. Facility owners will be able to avoid civil penalties for violations they self-report and correct in line with the requirements of the new program.

A Draft agreement for the new program is available on EPA’s website.

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The new self-audit program specifically addresses steps to identify and correct excess emissions from storage tank vapor control systems. These vapor control systems have been at the heart of at least three recent high-dollar Clean Air Act enforcement actions.

EPA’s Use of Self-Audits to Protect the Environment

EPA has long relied on self-disclosures as a tool to boost environmental compliance at industry facilities. EPA’s current self-audit policy has been in place since 1995 and provides incentives for regulated facilities to bring themselves into compliance with Federal environmental requirements.

In December 2015, EPA launched a web-based “eDisclosure” tool to encourage regulated entities to voluntarily discover, disclose, correct, and prevent the recurrent violation of environmental regulations.

EPA has posted a Q&A regarding the new self-audit policy here: https://www.epa.gov/sites/production/files/2018-06/documents/qaoilandnaturalgasnewownerauditprogram.pdf

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Whether you’re new to EPA compliance or you’re the go-to person for all-things-environmental in your organization, you will take away new insights and prepare for what’s coming next in EPA regulation.

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Tags: audit, Clean Air Act, EPA, new rules, oil and gas

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