4 The record articles

Proposed Alignment of the Oil and Gas Sector GHG Reporting Rule (Subpart W) With NSPS OOOOa

Posted: March 2nd, 2016

Authors: Megan S. 

On January 29, 2016, U.S. EPA proposed revisions to 40 CFR Part 98 Subpart W – Mandatory Greenhouse Gas (GHG) Reporting for Petroleum and Natural Gas Systems (Subpart W).  These proposed revisions come not long after several other new reporting requirements were finalized on October 22, 2015 for Subpart W (addressed in the blog, “Final 2015 Revisions to the GHG Reporting Rule for the Oil and Gas Sector” from December 2015).  The recently proposed revisions will add new monitoring methods for leak detection, emission factors for leaking equipment (referred to as “leaker emission factors” within the proposed revisions), reporting requirements, and confidentiality determinations.

The purpose of the recently proposed equipment leak requirements from oil and gas equipment in Subpart W is to align leak detection methods with the recently proposed 40 CFR Part 60 Subpart OOOOa – Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution (Subpart OOOOa).  As such, if Subpart OOOOa (when final) is amended in the future to incorporate new technologies or monitoring methods, Subpart W requirements will be automatically updated by reference.  The proposed leak detection provisions would only be required for sources reporting under Subpart W that are also subject to Subpart OOOOa.  Facilities with a Subpart OOOOa affected source would calculate and report their GHG emissions by using the data derived from the Subpart OOOOa fugitive emissions requirements, the Subpart W equipment leak survey calculations, and leaker emission factors.  For sources reporting under Subpart W that are not subject to Subpart OOOOa, the proposed leak detection methods could be voluntarily used.

The table below, reproduced from Page 7 of the Federal Register “Table 2 – Proposed Equipment Leak Requirements for Subpart W,” provides a summary of the proposed amendments:

The U.S. EPA expects that the proposed Subpart W amendments would be published at the same time or soon after the final Subpart OOOOa rule is published to ensure alignment.  The U.S. EPA anticipates finalization before the end of 2016.  The new methods and emission factors would need to be used starting on the effective date of the finalized amendments.

The U.S. EPA has determined that the new data reporting elements in the proposed Subpart W amendments are not entitled to confidential protection and that the final confidentiality determinations previously made are unaffected and continue to apply.  The comment period on this action has been extended from the original February 29, 2016 deadline, and comments must be received on or before March 15, 2016.

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

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