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Generic 311/312 reporting for oil fields or wells

A petroleum company owns many oil wells on a large oil field.  Each well is on its own plot of land.  These plots of land are not adjacent or contiguous and the oil field itself spans many local planning districts.  For purposes of Sections 311/312 reporting, is each oil well a separate facility and must separate reports filed for each oil well?

The definition of facility for Sections 311/312 includes "all buildings, equipment, structures, and other stationary items that are located on a single site or on contiguous or adjacent sites that are owned or operated by the same person" (52 FR 38364).  Therefore, unless the well properties are adjacent or contiguous, each well is a separate facility.  The Title III definition of facility applies to the land surface only; the fact that one oil company may own the subsurface rights of an entire oil field does not make the field one "facility".

Under Sections 311/312, a report must be prepared for each facility owned or operated by the same person.  The regulations stipulate that certain information must be provided to the specified agencies.  Nowhere do the regulations stipulate a separate report for each facility, EPA does not prohibit one report being filed for similar multiple facilities, so long as the report satisfies the statutory information requirements.

Filing one report for similar multiple facilities is a kind of "generic reporting".  A generic report would consist of one submission for each section - one MSDS for each reportable chemical and one Tier I/II - which would provide the required information on each well (facility).  However, a generic report may only be submitted for similar facilities.  In order for facilities to be considered similar, they must have present the same extremely hazardous substances and hazardous substances on-site at any one time in similar amounts.  If the facilities are not similar, the generic report would not contain the facility-specific required information and the facility would not be considered in compliance with Sections 311/312.

When submitting a report under Sections 311/312, the report must be sent to the SERC, the LEPC and the fire department.  In the case of a generic report being submitted, the report must be submitted to every SERC, LEPC and fire department under whose jurisdiction the similar facility crosses.

In the case of reporting for an oil field and oil wells therein, generic reporting will prove beneficial since most wells are similar on a given field.  Simply make sure that the wells are in fact similar, that the generic report provides the facility-specific information required and that the report is submitted to all relevant State and local agencies.  In that manner, the generic report will provide all facility-specific information to all relevant State and local agencies.