Super Emitter Program Form Logic-Third Party Notification Forms

Super Emitter Form Logic

Third Party Notifiers: Third Party Notification Forms

A person or organization that receives certification from EPA as a Third Party Notifier will, starting fifteen days after certification, be able to send EPA notifications of a Super Emitter event, defined as a methane emission of 100kg/hr. EPA will perform a data quality check, including (but not limited to) confirmation that the emissions exceed the 100kg/hr threshold with approximately 98% certainty and that the identified facility is located near the plume. After submission, the notifier will receive a copy of the data quality check. Third-party notifiers can update previously submitted forms in the event of an error or if new information causes them to revise their data. If the notification passes the data quality check, EPA will notify the owner/operator, who must initiate a super-emitter event investigation within 5 days and submit a response form to EPA within 15 days.

Owner/Operators: Designating Responsible Officials and Owner/Operator Response Form

The optional first step for owner/operators will be to designate Responsible Officials by downloading, filling out and uploading the Designating Responsible Officials spreadsheet. This form will ensure that EPA sends notifications to the personnel specifically chosen by owner/operator for their facilities. Along with spreadsheet, owner/operators can also provide geographic files to identify their facilities. Owner/operators may use the same form to update this information as personnel responsibilities change and facilities are built or change ownership. In the absence of such a file, EPA will notify the company employee, such as the regulatory analyst, who most recently completed a state or federal activity for this facility, such as submitting a permit to drill or information under EPA’s Greenhouse Gas Reporting Program. However, this official may have left the company or be on leave, so without the Designating Responsible Officials form, notifications are less reliable.

The owner/operator must complete the form within 15 days of receiving the notification. After completion of the form, the owner/operator may amend the form at any time to provide new information as it becomes available. If the owner/operator responds that the emission is on-going, they must update the form on or before the estimated completion date to either confirm completion or provide a new estimated completion data.

The form is divided into Data Groups, depending on how the respondent answers certain questions. All questions marked with an asterisk in the accompanying pdf are required if the Data Group is required. No respondent will see all the Data Groups. For instance, owner/operators of NSPS OOOO affected facilities that did not identify the source will be required to answer questions about their search. Owner/operators that did identify the source must provide information about the source and its status, but not about the search. The first table shows the required information and who must provide it, or may provide it. Following that are the branching questions, and how the Data Groups depend on the branching questions to direct the respondent to the provide the required information. There is also a Data Group, “Optional Additions,” which allows respondents to include self-reported data on the public portal.

Table 1– Owner/Operator Data Groups Associated with Super-Emitter Program

Owner Operator (O/O) Data	Data Group	Who must respond	Who may respond
Point of contact information	A	All
Notification information	B
Demonstrable Error	C	O/O of oil and gas facilities within 50m of coordinates
Applicability and Identification	D
Evaluation of Source	E	O/O of facilities not claiming demonstrable error who identified source of emission
Status and Response	F
Search for Source	G	O/O of affected facilities not claiming demonstrable error who did not identify source	O/O of non-affected facilities not claiming demonstrable error who did not identify source
Optional Additions	H	None	O/O of oil and gas facilities within 50m of coordinates
Attestation	I	All

Branching Questions:

B 1: Are you the owner or operator or responsible official (where applicable) of an oil and natural gas facility (e.g., individual well site, centralized production facility, natural gas processing plan, or compressor station) within 50 meters from the latitude and longitude provided in the EPA notification?

C 1: Do you assert a demonstrable error in the notification?

D 1: Is there an affected facility or associated equipment subject to regulation under NSPS OOOO, NSPS OOOOa, NSPS OOOOb, and/or a State or Federal Plan implementing OOOOc at this oil and gas facility?

D 2: Did you identify the source of the super emitter event?

Table 2– Required Data Depending Owner/Operators Response Data Groups

Group Description	Required Data Groups	Branching Question(s)	Answer
Owner/Operator who does not own facility within 50m	A, B, I	B 1	No
Owner/Operator asserting Demonstrable Error in Notification	A, B, C, D, I	B 1	Yes
		C 1	Yes
Owner/Operator of Facility that does not have equipment subject to OOOO, OOOOa, OOOOb, or OOOOc who identified the source of the emission	A, B, C, D, E, F, I	B 1	Yes
		C 1	No
		D 2	Yes
Owner/Operator of Facility of affected facilities who did not identify source of emission	A, B, C, D, G, I	B 1	Yes
		C 1	No
		D 1	Yes
		D 2	No
Owner/Operator of Facility of affected facilities who did not identify source of emission	A, B, C, D, I	B 1	Yes
		C 1	No
		D 1	No
		D 2	No