The following notice was prepared by IPAA, of which IPANM is a cooperating association:

The U.S. Environmental Protection Agency (EPA) has promulgated new regulations to reduce air emissions from the oil and natural gas industry.  As you know, IPAA opposed several elements of these regulations and some provisions were modified.  IPAA is continuing to seek changes from EPA.

However, while many of the requirements are subject to a phased in compliance period, one provision – the advance notification of completion provision – takes effect on October 15, 2012.

IPAA has been working with EPA to make the Quad “O” transition as smooth as possible.  Generally, states have been delegated authority for Clean Air Act (CAA) compliance.  IPAA anticipates that as Quad “O” is implemented, states will be delegated authority for the notification requirements.  However, in the interim period, prior to states officially being delegated Quad “O” authority, operators should notify EPA in advance of completions.

EPA must be notified 48 hours prior to completion.  To notify EPA, operators must send an email to their EPA Regional Inbox. 

The email addresses are:

Region 2 – r2wellcompletion@epa.gov
Region 3 – r3wellcompletion@epa.gov
Region 4 – r4wellcompletion@epa.gov
Region 5 – r5wellcompletion@epa.gov
Region 6 – r6wellcompletion@epa.gov
Region 7 – r7wellcompletion@epa.gov
Region 8 – r8wellcompletion@epa.gov
Region 9 – r9wellcompletion@epa.gov
Region 10 – r10wellcompletion@epa.gov

Operators must submit the following information and data to EPA no later than 2 days prior to the commencement of completion:

– The anticipated date of the well completion operation.
– Contact info for the owner/operator.
– API well number.
– Latitude/Longitude coordinates for each well in decimal degrees to an accuracy and precision of five decimals of a degree using NAD-1983.
– Planned date of the beginning of flowback.

States will be required to obtain this same information in order to be delegated authority under the CAA.

As Quad “O” implementation moves forward, IPAA understands that operators will only have to provide their state regulators with advance notice of completions, if the state has been delegated authority under the CAA.  Additionally, IPAA understands advance notification to a state agency (even if it is the Oil and Gas Commission and not the Department of Environmental Quality or equivalent state air regulator) would appear to be sufficient, given the language.  However, the rulemaking is silent on this point. The specific regulations are found in EPA’s New Source Performance Standard (NSPS) for the Oil and Gas Sector, Subpart OOOO (Quad “O”).   IPAA will continue to seek additional clarification on this point.  In the event that your state does not have CAA enforcement authority, you should continue to notify EPA with advance notice of completion by sending an email to the appropriate inbox.

Please contact Matt Kellogg (mkellogg@ipaa.org or 202-857-4722) if you have any questions.