EPA Clean Air Act ICR

Under the authority of the Clean Air Act, the United States Environmental Protection Agency (EPA) will send, or has sent, information collection requests, called “ICRs,” to thousands of oil and gas operators across the country. These ICRs can be expected before the end of 2016. 

The EPA uses ICRs under the Clean Air Act to obtain information for the purpose of developing new air emissions standards and regulations. EPA has stated the purpose of this ICR is to gather information in order to eventually enact new air regulations limiting emissions of methane gas from existing oil and gas facilities. 

There are two parts to this ICR. Part I is the operator survey. It requires inventory of all oil and gas facilities, number of wells, separators, storage tanks, and compressors at each facility. Part I is to be completed and submitted within 30 days of receiving it. 

Part II is the detailed facility survey. It will go to operators of selected oil and gas facilities that, in EPA’s opinion, constitute a representative sample of the domestic United States oil and gas industry. Any facility that is selected to receive Part II will be exempted from having to complete Part I. Part II is much more detailed and demanding than Part I. It requires a wide variety of specific information, including for example, equipment counts and measurement data. Part II must be completed and submitted to EPA within 120 days of receiving it.  

Failure to respond to an ICR, or a Section 114 letter, could carry penalties under the Clean Air Act of up to $93,750 per day of violation.

On January 10th, 2017 Aaron Mooney from COMM Engineering will make a presentation on this subject and answer questions. COMM Engineering is the global leader in facility engineering and environmental consulting for air, water, and waste for the oil and gas industry, with a specialty in air emissions. COMM Engineering pioneered the EPA certified combustor as the first manufacturer to successfully test, certify, and submit results to the EPA for an enclosed combustor per the requirements of the regulation.  

Space is limited for this presentation. Registration is $20 and includes lunch. Please call 352-5637 to reserve your seat. 

Location: Amarillo National Bank, Plaza II conference room, 2nd floor

Time: 11:30 am – 1:00 pm 

Date: January 10, 2017


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The Panhandle Producers & Royalty Owners Association is an advocate for oil and gas producers, mineral royalty owners and industry support companies in the Texas panhandle, western Oklahoma and southwestern Kansas. Association advocacy is both proactive and responsive and includes:

  • Providing resources and contacts for member education and training
  • Representation before local, statewide and national governmental bodies and their leaders
  • Representation before civic and service organizations, media and schools
  • Facilitation of member networking opportunities
  • Disbursement of industry information to members


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