EPAP COMPLIANCE IS NOT OPTIONAL. DO IT RIGHT

We have seen a shift to a proactive control based audit approach since the Alberta Energy Regulator (AER) implemented the Enhanced Production Audit Program (EPAP) on January 4, 2010 which requires operators to implement control procedures for measurement and production reporting as well as to provide an annual declaration attesting that key controls are in place. The objective of the EPAP program is to improve compliance to measurement related requirements (primarily Directive 7 and 17, but also includes Directive 46, 56 and 60).

Although standard/efficient processes are the foundation of any successful implementation, processes alone cannot deliver the necessary value. In order to achieve sustainable success 3 critical elements must be present (people, processes, technology). Processes are only as effective as the people using them. Alignment of people is the most complex and difficult of all technical implementations. Technology will be able to be applied to automate manual tasks, capture data, enforce data/process standards, support collaboration and monitor exceptions. All of this must be accomplished in the face of an expanding regulatory framework and significant public scrutiny.

Incomplete or inaccurate data can cause rework of production that could have millions of dollars of impact on revenue, and wasted significant manpower. The oil and gas business by its nature involves significant risks therefore there is a need to effectively manage what is within “your” control. Avoiding costly reworks and non-compliance penalties is essential to maintaining efficiency and reducing the financial risk in the business. It is critical that companies have good core process/tools in place that are scalable and expandable to meet the needs of a growing organization and changing regulatory landscape.

ALTO Produce (ready to produce) was built to capture/enforce EPAP controls, and to ensure that well and facility set ups can be done in a timely manner so that production can be turned on quickly. RTP contains all the pertinent information required to record any production flow changes such as new drill, re-activation, recompletion, comminglement, equipment changes, third party tie-in, abandonment and suspension. ALTO Produce captures the mandatory data elements needed to meet both the producer’s internal needs as well as satisfy the regulatory requirements. ALTO Produce is not meant to be another silo application. RTP can integrate with PVR, PRISM, ProdView, Protrend, Qbyte, ALTO Drill, ALTO eProcure, AFE Navigator, CS Explorer, Roughneck and many more.

Some of the areas covered by RTP include

• Schematic changes

• Working interest ownership

• Calibrations

• Sampling process

• Sample points, frequency

• Equipment consumption

• Product transfer

• Product sales

• Auditable processes and data (not able to be “massaged”)

• H2S etc.

Multi discipline team collaboration workflow (non sequential)

• Production Engineers

• Field Operations

• Mineral Land

• Surface Land

• Construction

• Marketing

• Measurement Group

• Integrity Engineering (or EPCM)

• HSE Group

• Joint Venture

• Finance

• Production Accounting

Signing the yearly declaration is a liability and requires a certain level of confidence. How confident are you that key controls are in place before you sign next time?