In 2010 the Alberta Energy Regulator (AER), developed Directive 076 (Enhanced Production Audit Program) and had producers begin to self-assess themselves and declare the results. Similarly in Saskatchewan, the Ministry of Energy and Resources (MER) has adopted the same program. I have been fortunate enough to conduct dozens of EPAP reviews, and it is apparent that needs are substantially different depending on a company’s size, resources, business processes, and current measurement compliance. What may be good for a large producer is almost always not needed or necessary for a small producer. Within this paper, an alternative cost-effective and value-added solution will be discussed that will be intriguing to smaller producers.

With classic small and mid-sized company EPAP programs, typically the audit occurs once a year with declaration and remediation recommendations from the EPAP assessment provider. All too often once the declaration has been signed off and filed most of the remediation recommendations get neglected or other more important activities begin to creep in and the remediation activities get put back in the to-do que. Eventually, the EPAP audit is again back and nothing has been remediated. This can be an ever-rotating wheel of never improving stagnation. From my experience, this is an unfortunate norm since many companies are required to operate very lean with today’s oil and gas environment. This being said, help is on the way with Intricate’s low cost / high-value solution.

Intricate’s low cost / high-value solution removes the annual guess work of what the results will be and the uncomfortable conversations between EPAP owners and their senior management. This solution provides a work together type of relationship between the company and the EPAP evaluator quarterly. The idea for this solution is to assess a company’s controls in a joint one-on-one effort. Usually, an auditor will request and receive the control data then determine mitigation levels. With this solution, the determination and prioritized goals will be conducted together. During these sessions, better understanding will be achieved by all stakeholders of what is required of them but also an added value of control performers personalizing and owning their part of the company’s EPAP program.

Other companies are experiencing high success, the following will be an explanation of how a meeting typically goes:

• During the setup of a project, it is determined what the operating areas are. Typically the areas will be divided so that all areas will be reviewed either quarterly or set to a predetermined frequency and schedule.
  
• Initially, Intricate’s tool for this solution is required to be populated with the company’s EPAP controls; if a company requires assistance developing EPAP controls then Intricate is very experienced in doing so.
  
• These controls will then be associated to EPAP’s current theme noncompliance events (NCEs). Each NCE will be risk ranked based on the company’s business model and operating activities.
  
• Above is the time-consuming portion of the project. This is a one-time exercise that carries on as the program progresses.
  
• The next step is for appropriate control stakeholders to collaborate with Intricate’s measurement specialist and follow the user friendly steps in the EPAP tool.
  
• During the review, the Measurement Specialist (MS) will narrate the controls that have been associated with each particular theme and the perceived NCE that control is attempting to mitigate.
  • If the NCE has been deemed a low risk to the company then the question will require a conversation type response, or
  • If the NCE has been deemed a high risk for the company then the control performer will be required to show a sample set of acceptable documents to the MS.
    
• During the review of the sample set, the control performer and the MS will determine if the documents meet the intent of the control by successfully reducing associated risks.
  
• If it has been determined that a control is not reducing a company’s risk or that risk is not being controlled, the control performers and the MS discuss possible solutions for either adopting a control or strengthening a current control going forward.
  
• Each theme will have a clear list of items to address.
  
• Together, priority will be discussed and current work efforts to ensure value added remediation activities can be achieved.
  
• Once the items are prioritized, then the highest priority item will be documented with control performer association and accountability.
  
• If the group determines to add another item then it will be and the EPAP program will continue to evolve. During this phase, if multiple EPAP themes will benefit from one remediation item, then that item will be associated so the best bang for the buck is adopted.

The idea behind this methodology is once the remediation items have been determined, then during each quarterly meeting, there will be a discussion on the remediation items. When an action item has been achieved, an assessment of the outcome will again be reviewed by the group. If successful, this control will be determined as effective and therefore strengthens the associated theme. With having the opportunity to continually improve the company’s EPAP program and reviewing progress quarterly, a proactive philosophy has been adopted. As the program progresses, the meetings typically become shorter and require less time being spent on in-depth documentation reviews by instead continual improvements and creating efficiencies and intrinsic value to the company.

As is evident from the above solution, EPAP should not be a program that is deemed a cost but more of a business strength. With successful businesses, large or small, effective and efficient business processes is paramount to a company’s growth and bottom line. If a more proactive approach is adopted within the EPAP program then not only the government’s requirements will be met but also greater business value will be achieved.

Below is a sample of a company’s time commitment for quarterly meetings.

Area	Q1	Q2	Q3	Q4
North West	10 hrs.	4 hrs.	2 hrs.	2 hrs.
South East	10 hrs.	4 hrs.	2 hrs.	2 hrs.
Central	10 hrs.	4 hrs.	2 hrs.	2 hrs.

About the Author

Richard Boscher is a Measurement Specialist and Journeyman Instrument Technician at Intricate; a Canadian energy services provider. Richard has been working in Industry for 24 years both as a service provider and as an employee for major producers as a Measurement Coordinator/Specialist.