The Enhanced Production Audit Program (EPAP) applies to all Business Associates that operate oil and gas facilities that are subject to the Ministry of the Economy's measurement and reporting requirements. Directive PNG076: Enhanced Production Audit Program (EPAP) was put into effect in April 2016 and sets out requirements for operators to declare the degree to which they have controls in place to assure compliance with the Regulator's oil and gas measurement and reporting requirements.
Directive PNG076 underwent a number of adjustments including but not limited to changes regarding penalties and the definition of a facility. The province sought feedback on proposed changes to the directive.
Overview of Proposed Changes
More substantive proposed changes included:
- A financial penalty charged for failure to submit an EPAP declaration by the deadline. Since each operator receives a notice one month before the declaration is generated, another notice when the declaration is generated, and a Petrinex EPAP warning report before the deadline, it is clear that no additional warnings are needed.
- A change surrounding the definition of a facility. For the purposes of EPAP, the definition of a facility will now include "reporting pipelines," which is a new term that is defined in Directive PNG032.
- Additional wording in Section 8 that indicates a financial penalty for non-response to workflows. This wording is consistent with section 11.10 of Directive PNG032 and uses penalty provisions in The Oil and Gas Conservation Regulations, 2012 to charge such a penalty.
Another notable change was regarding the submission due date. The previous due date was the last day of the second month following an operator's declaration month. The due date will now be the last business day (Monday to Friday except holidays) of the second month following and operator's declaration month. There are a number of additional smaller changes.
Further details on the proposed changes are outlined in the: