Final 2015 Revisions to the GHG Reporting Rule for the Oil and Gas Sector

On October 22, 2015, U.S. EPA issued final amendments to 40 CFR Part 98, Subpart W (Mandatory Greenhouse Gas (GHG) Reporting for Petroleum and Natural Gas Systems).  The amendments – which were proposed on December 9, 2014 – require GHG emissions reporting for several sources that had not previously been included in Subpart W.  The new sources include gathering and boosting facilities, completions and workovers of oil wells with hydraulic fracturing, and blowdowns of natural gas transmission pipelines between compressor stations.  The revisions also include the addition of well identification reporting requirements for certain facilities.  Finally, confidentiality determinations were finalized for new data elements in the amendments.

The major amendments to 40 CFR Part 98, Subpart W include the following:

• The addition of two new industry segments:
  • Onshore Petroleum and Natural Gas Gathering and Boosting segment:
    • Includes GHG emissions from equipment such as acid gas removal units, storage tanks, blowdown vents, dehydrators, equipment leaks, flare stacks, and pneumatic devices.
  • Onshore Natural Gas Transmission Pipeline:
    • Includes GHG emissions from blowdowns of natural gas pipelines between compressor stations.
• Changes for the existing Onshore Petroleum and Natural Gas Production segment:
  • Completions and workovers of oil wells with hydraulic fracturing are now included.
  • Well identification numbers associated with individual oil and gas wells are required to be reported.
• Best Available Monitoring Methods (BAMM) are allowed only for reporting year 2016 on a short-term transitional basis for the facilities new to reporting under Subpart W and facilities subject to new monitoring requirements as a result of these amendments.  Beginning January 1, 2017, reporters must discontinue use of BAMM and follow all applicable monitoring and QA/QC requirements of Subpart W.
• The U.S. EPA is required to make information obtained under section 114 available to the public, except for information that qualifies for confidential treatment. The U.S. EPA has determined that this action is subject to the confidential treatment provisions and has finalized the confidentiality determinations as proposed.  More specific information can be found on Page 18 of the Federal Register.

In addition, the following are two (2) responses from the U.S. EPA to take note of:

• The U.S. EPA has not changed the definition of “gas well” or “oil well.”  Rather, reporting of GHG emissions are required from completions and workovers with hydraulic fracturing for wells in the Onshore Petroleum and Natural Gas Production segment, regardless of whether the primary product is oil or natural gas.
• The U.S. EPA is assessing the potential opportunities for application of remote sensing technologies and other innovations in measurement or monitoring technology.  Provisions related to advanced measurement or monitoring methods are not addressed in this rule and the U.S. EPA has not responded to comments regarding advanced measurement or monitoring methods in this rulemaking. Instead, following review of the data and information received in comments, the U.S. EPA may propose amendments related to the use of innovative technologies in reporting to the Greenhouse Gas Reporting Program (GHGRP) in a future rulemaking.

These amendments are effective January 1, 2016 and will come into play for the 2016 calendar year.  The annual reports due March 31, 2016 will not have to implement these amendments, but reporters will have to begin monitoring, recordkeeping, and calculating emissions in accordance with the amendments beginning January 1, 2016.  The first reports to be submitted using the amended requirements will be those submitted March 31, 2017, covering the reporting year 2016.

If you have any specific questions, feel free to reach out to JP Kleinle at jkleinle@all4inc.com or myself at mstroup@all4inc.com.