To implement the ERP program for the oil and gas sector, LADEQ will work collaboratively with the Louisiana Department of Natural Resources (LDNR), which also regulates many of the same facilities in this sector, to exchange information on existing wells and processing facilities.
This project consists of three phases:
(1) Database development and stakeholder outreach
This phase, estimated to last one year, will result in development of a database for tracking the identity of all oil and gas production facilities within the state and their permit compliance data. LADEQ and the LDNR will work in collaboration with state and local economic development agencies, local chambers of commerce, local community groups, and trade associations to complete this task. Each Agency in this collaboration hopes to reduce the administrative burden associated with collection and management of high-quality compliance data.
Concurrently, the LADEQ will collaborate with external stakeholders to develop Environmental Business Practice Indicators (EBPI), which will provide measurable statistical data on sector compliance for use by operators, and establish compliance and environmental results expectations. The outputs include workbooks, fact sheets, and other compliance assistance tools for businesses, as well as inspection tools and methods (e.g., a multi-media inspector check list, multi-media ERP training for inspection staff). Training workshops will also be delivered to facility operators to help them understand and address all applicable federal and state environmental regulations, as well as requirements of the program, including the adoption of best management practices and pollution prevention and waste reduction methods.
(2) Baseline compliance measurements and compliance materials development
This phase will last approximately one year and will initiate regulatory inspection of a statistically-based sampling of the state’s oil and gas facilities to establish an initial assessment of compliance rates. These initial assessments will not be official enforcement inspections, and violations discovered under these assessments will be addressed under the enforcement discretion policy developed under Phase I. Inspectors will use the opportunity to educate operators and provide facility owners/operators with copies of the self-certification workbook, compliance forms, and fact sheets for their use in returning to or maintaining compliance and self-certifying their performance. Owners/operators will be encouraged to attend some of the established compliance assistance workshops. A web-based system will be implemented to accept and document the submittal of self-certification reports by the state's oil and gas owners and operators.
(3) Compliance assessment through post-compliance inspections
This phase focuses on implementation with a duration of roughly one year. During this phase, completion of the web-based information system will occur. LADEQ will also begin training workshops which include materials such as the ERP sector workbooks and compliance check lists for facility operators throughout the State. LADEQ anticipates that, at least initially, it will receive hard copy of the self-certifications from participants to allow LADEQ staff to review them for completeness and accuracy before they enter the information into the database.
Final compliance assessment inspections will be conducted at a statistically selected sample of sites to gather performance measure data to assess the accuracy of self-certifications and confirm rates of compliance. The data will compare with the baseline compliance data to assess the success of the ERP program in improving environmental performance.