In This Issue

Final Rule on Greenhouse Gas Emissions Reporting for Petroleum and Natural Gas Systems

EPA-HQ-OAR-2009-0923; FRL-9226-1; RIN 2060-AP99

The Environmental Protection Agency (EPA) has promulgated a regulation (SubPart W of 40 CFR Part 98) to require monitoring and reporting of greenhouse gas emissions from petroleum and natural gas systems. This action adds this source category to the list of source categories already required to report greenhouse gas emissions. This action applies to sources with carbon dioxide equivalent emissions above certain threshold levels as described in this regulation. This action does not require control of greenhouse gases. The affected source categories are:

  • Offshore petroleum and natural gas production. Offshore petroleum and natural gas production is any platform structure, affixed temporarily or permanently to offshore submerged lands, that houses equipment to extract hydrocarbons from the ocean or lake floor and that processes and/or transfers such hydrocarbons to storage, transport vessels, or onshore. In addition, offshore production includes secondary platform structures connected to the platform structure via walkways, storage tanks associated with the platform structure, and floating production and storage offloading equipment (FPSO). This source category does not include reporting of emissions from offshore drilling and, exploration that is not conducted on production platforms.
  • Onshore petroleum and natural gas production. Onshore petroleum and natural gas production means all equipment on a well pad or associated with a well pad (including compressors, generators, or storage facilities), and portable non-self-propelled equipment on a well pad or associated with a well pad (including well drilling and completion equipment, workover equipment, gravity separation equipment, auxiliary non-transportation-related equipment, and leased, rented or contracted equipment) used in the production, extraction, recovery, lifting, stabilization, separation or treating of petroleum and/or natural gas (including condensate). This equipment also includes associated storage or measurement vessels and all enhanced oil recovery (EOR) operations using CO2, and all petroleum and natural gas production located on islands, artificial islands, or structures connected by a causeway to land, an island, or artificial island.
  • Onshore natural gas processing. Natural gas processing means facilities that separate and recovers natural gas liquids (NGLs) and/or other non-methane gases and liquids from a stream of produced natural gas using equipment performing one or more of the following processes: oil and condensate removal, water removal, separation of natural gas liquids, sulfur and carbon dioxide removal, fractionation of NGLs, or other processes, and also the capture of CO2 separated from natural gas streams. This segment also includes all residue gas compression equipment owned or operated by the natural gas processing facility, whether inside or outside the processing facility fence. This source category does not include reporting of emissions from gathering lines and boosting stations. This source category includes: (1)all processing facilities that fractionate and (2) those that do not fractionate with throughput of 25 MMscf per day or greater.
  • Onshore natural gas transmission compression. Onshore natural gas transmission compression includes any stationary combination of compressors that move natural gas at elevated pressure from production fields or natural gas processing facilities, in transmission pipelines, to natural gas distribution pipelines, or into storage. In addition, transmission compressor stations may include equipment for liquids separation, natural gas dehydration, and tanks for the storage of water and hydrocarbon liquids. Residue (sales) gas compression operated by natural gas processing facilities are included in the onshore natural gas processing segment and are excluded from this segment. This source category also does not include reporting of emissions from gathering lines and boosting stations-these sources are currently not covered by subpart W.
  • Underground natural gas storage. Underground natural gas storage includes subsurface storage, including depleted gas or oil reservoirs and salt dome caverns that store natural gas that has been transferred from its original location for the primary purpose of load balancing (the process of equalizing the receipt and delivery of natural gas); natural gas underground storage processes and operations (including compression, dehydration and flow measurement, and excluding transmission pipelines); and all the wellheads connected to the compression units located at the facility that inject natural gas into and remove natural gas from the underground reservoirs.
  • Liquefied natural gas (LNG) storage. LNG storage includes onshore LNG storage vessels located above ground, equipment for liquefying natural gas, compressors to capture and re-liquefy boil-off-gas, re-condensers, and vaporization units for re-gasification of the liquefied natural gas.
  • LNG import and export facilities. LNG import equipment includes all onshore or offshore equipment that receives imported LNG via ocean transport, stores LNG, re-gasifies LNG, and delivers re-gasified natural gas to a natural gas transmission or distribution system. LNG export equipment means all onshore or offshore equipment that receives natural gas, liquefies natural gas, stores LNG, and transfers the LNG via ocean transportation to any location, including locations in the United States.
  • Natural gas distribution. Natural gas distribution includes the distribution pipelines (not interstate transmission pipelines or intrastate transmission pipelines) and metering and regulating equipment at city gate stations, and excluding customer meters, that physically deliver natural gas to end users and is operated by a Local Distribution Company (LDC) that is regulated as a separate operating company by a public utility commission or that is operated as an independent municipally-owned distribution system. This segment excludes customer meters and infrastructure and pipelines (both interstate and intrastate) delivering natural gas directly to major industrial users and “farm taps” upstream of the local distribution company inlet-these sources are not covered by subpart W.

The final rule is effective on December 30, 2010.

Editor’s note: If your air emissions compliance personnel aren’t already familiar with this topic, they have a lot of reading to do!