Following the purchase of hundreds of upstream assets, CEC was contracted by an owner operator to perform air quality compliance audits for all the newly acquired facilities in accordance with the agreed upon terms of the EPA’s Oil and Gas New Owner Audit program. EPA developed the Oil and Gas New Owner Audit program to encourage voluntary compliance auditing in exchange for compliance deviation forgiveness for companies that voluntarily report and correct air quality violations per the agreement. CEC was tasked with developing the audit criteria checklists, standard operating procedures, developing the emissions calculations guidelines, performing field inventory and compliance audits, leak detection surveys on the storage vessels and closed vent systems, and the desktop review of all available compliance records and reports, as well as developing the final compliance report for the client..
In this presentation, we will discuss the steps in the process including the background and benefits of the program, field inspection/inventory activities and the processes involved in managing and evaluating the data for final compliance determinations. We will also spend some time discussing lessons learned as well as highlighting some of the items that contributed to the success of the project.