Recent news from the AER regarding EPAP.
Message to Industry regarding the Enhanced Production Audit Program (EPAP) – System Functionality Release May 2012
Additional functionality was introduced into the EPAP System in May 2012 to add required functionality and to enhance the user experience.
The following functionality was included in the May 2012 release.
AER Directive 076 Modifications
- AER Directive 076: Operator Declaration Regarding Measurement and Reporting Requirements (Directive 076) came into effect on January 4, 2010. Requirement # 2 in Section 2 (Declaration Regarding AER Measurement and Reporting Requirements) states: “An operator’s declaration must cover the 12 calendar months ending in the operator’s declaration month and must be received by the end of the month following the declaration month”.
- In order to obtain more accurate operator facility counts for the declaration period on the declaration appendices, the AER has determined that the declaration submission timing must be revised such that Industry operators submit their declarations no earlier than the first day of the second month following the declaration month and no later than the last day of the second month following the declaration month. This revision to the declaration submission timing requirement will better align with the time frame in which operators must inform the Petroleum Registry of Alberta of facility ownership changes.
- As a result, beginning with the 2012 declaration submission year, operators are advised that declarations must be submitted to the AER no earlier than the first day of the second month following the declaration month and no later than the last day of the second month following the declaration month. Directive 076 is currently being revised to reflect this new declaration submission timing requirement.
- PLEASE NOTE- THE EPAP SYSTEM IS CURRENTLY UNABLE TO ACCEPT 2012 DECLARATIONS. OPERATORS WILL BE INFORMED WHEN THE ABILITY TO SUBMIT DECLARATIONS IS AVAILABLE.
Compliance Assessment Indicator Categories
The Compliance Assessment Indicator Category of “Concern” has been replaced with “Conditional”. A revised description of the Compliance Assessment Indicator Categories can be found at Compliance Assessment Categories- June 2012
Communication within the EPAP System
The Production Audit Team (PAT) now has the ability to communicate with Operators using the Action Item functionality within the EPAP System. An Action Item is a formal request from the PAT to an Operator to provide additional information or to investigate a specific issue.
The assigned PAT Member may initiate a:
- BA Level Action Item: used to discuss company-level issues. When requesting information from an Operator, the assigned PAT Member will create a BA Action Item in the EPAP System. The Operator’s Primary Contact will receive a BA Action Item Notification via email.
- CAI Level Action Item: used to discuss facility specific issues. When investigating a CAI flagged at a facility, the assigned PAT Member will create a CAI Action Item. The Operator’s Primary Contact will receive a CAI Action Item Notification via email.
The Operator’s designated Primary Contact will receive a Notification email from the EPAP System:
- indicating the PAT Member has created an Action Item within the EPAP System,
- confirming the Operator’s Action Item submission response in the EPAP System.
To submit a response to an Action Item, an Operator must log onto the EPAP System and input the appropriate details. Step-by-Step instructions on how to respond via the EPAP System can be found below.
- BA Action Item Response Instructions
- BA Action Item Rejection Response Instructions
- CAI Action Item Response Instructions
- CAI Action Item Rejection Response Instructions
Changes to the Workflow State of a Compliance Assessment Indicator (CAI)
PAT Members now have the ability to change the workflow state of a CAI. For instances where a facility is being flagged with a specific CAI, the state of the CAI can be modified if, after Operator investigation it is determined that normal operating conditions of the facility are triggering the CAI. An explanation in support of the Operator’s findings can be provided to the assigned PAT Member.
The Operator’s Primary Contact, or an Authorized Contact within the company with the designation of EPAP Editor, would be required to submit, via the EPAP System, a request for a change in workflow state including all supporting documentation. Upon review and acceptance of the request, the PAT member would change the CAI state from “Valid” to “No Action Required- Acceptable Response”. Although the CAI would continue to be flagged on a monthly basis, it would no longer be considered an issue by the PAT member.
DUE TO STAFFING LIMITATIONS AND WORKLOAD THE ENTIRE CHANGE PROCESS COULD BE EXTENSIVE. In the interim it is recommended that the state of the CAIs in question be handled by Operators as has been done in the past.
For detailed instructions on what is required to change the state of a CAI please see below:
- CAI State Change Action Item Response Instructions
- CAI State Change Action Item Rejection Response Instructions
- Compliance Assessment Indicator State Change Requests
Voluntary Self Disclosure (VSD) Submissions
If an Operator identifies an AER measurement and reporting Noncompliance Event (Noncompliance) at a facility, the Operator can submit the remediation (Work Plan) and resolution (Evidence) details through the use of the VSD function within the EPAP System.
Once the VSD Work Plan and Evidence are accepted by the assigned PAT Member, further AER enforcement action for the identified Noncompliance would not occur. However, if a request for investigation regarding a particular AER measurement and reporting Noncompliance has been initiated by the PAT Member, a VSD submission is no longer an option. If you required additional details on the qualifications of a VSD, please refer to AER Directive 19 -AER Compliance Assurance-Enforcement.
To submit a VSD, an Operator must log onto the EPAP System and input the appropriate details. Step-by-Step instructions on how to submit and respond to a VSD via the EPAP System can be found below: