GOADS-2008
Published on November 08, 2007

The Minerals Management Service’s (MMS) Notice to Lessees No. 2007-G25 requires lessees to collect and submit air emissions and equipment usage data during calendar year 2008.

Ongoing GOADS-2008 data collection is mandatory for OCS production facilities west of 87° 30’ West longitude that have more than just fugitive emissions sources and/or a single diesel crane engine (e.g. platforms larger than single-well caissons). Although emissions reporting is not required for “minor sources” (e.g. single-well caissons and living quarters), these sources will need to be included as a one-time identification. The data will be collected from January 1, 2008 to December 31, 2008 and must be submitted to MMS by April 21, 2009.

The MMS expects to use this data for compliance with the 1990 Clean Air Act Amendments as well as for verification of data provided by industry through existing means. Data provided through OGOR reporting, Development Operations Coordination Documents (DOCD) and similar avenues will be cross-referenced against the data.

The new GOADS-2008 software eliminates the need to enter “static” data monthly as was the case with the earlier version. This will help streamline the work and reduce the likelihood of data entry errors. Operators who participated in the first two GOADS projects will enjoy the benefit of having their static data (for structures that existed at the time) downloaded directly from MMS, reducing initial setup costs in most cases.

PROCESS

J. Connor Consulting, Inc. (JCC) has extensive experience in conducting this type of work. We were one of the largest data contributors during the GOADS 2000 and 2005 air emissions projects. Our strategy for conducting this work consists of:


    1. Project Setup – Download existing static data from MMS, if your company participated in GOADS 2005. Gather remaining data and verify current configuration of facility equipment through drawing review and/or conversations with personnel familiar with the current configuration. This phase also includes the design of daily/monthly customized spreadsheets and forms for each facility and setting up field communications for monthly data collection.

    2. Monthly Data Collection/Quality Control/Data Entry – This includes routine monthly data collection, quality control, and database entry. It also includes associated filing, telephone discussions, faxes and e-mails. Should you have a platform rig working during the GOADS inventory period, JCC will gather the additional emissions data at no additional charge.

    3. Final Submission – This includes final review, report preparation and data submission to the MMS.


COSTS
    1. Project Setup – One time charge per platform:

    DATA AVAILABILITY REGULATED COMPLEX FACILITY CAISSON/GOADS EXEMPT FACILITY
    EXISTING DATA $400 $75
    FROM SCRATCH $1200 $75

    2. Monthly Data Collection/Quality Control/Data Entry - $105/Platform

    This quote assumes that accurate data for each facility is provided to JCC in a timely manner. If additional data is needed for monitoring and report preparation, the gathering and collection of such data will be charged at the normal JCC hourly consulting rate. If travel is required, travel time and expenses are additional.

    Please acknowledge receipt of this email by either authorizing JCC to proceed with collecting GOADS data on your behalf, or advising that your company is handling this requirement in a different manner (available at this page). You may contact me or Matt Harlan at (281) 578-3388. Our email addresses are jodie.connor@jccteam.com and matt.harlan@jccteam.com.

    Thank you,

    Jodie Connor


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This Regulatory Alert was prepared by J. Connor Consulting, Inc. to advise our clients of impending deadlines and applicable regulatory requirements. No official agency policy is implied.