GHG Reporting, Subpart W, Petroleum and Natural Gas Systems

Final rule published 11/8/10; published in Federal Register 11/30.
Final Rule

Here's an overview article published March 2011 in the Air Pollution Consultant on-line magazine (available through Cyber Regs). (Added 6/14/11, KMM)


All the Part 98 subparts are collected here:
GHG Reporting Rule Web Site

Here's the text relating monitoring and QA/QC requirements (§98.234):

The GHG emissions data for petroleum and natural gas emissions sources must be quality assured as applicable as specified in this section. Offshore petroleum and natural gas production facilities shall adhere to the monitoring and QA/QC requirements as set forth in 30 CFR 250.

(a) You must use any of the methods described as follows in this paragraph to conduct leak detection(s) of equipment leaks and through-valve leakage from all source types listed in §98.233(k), (o), (p) and (q) that occur during a calendar year, except as provided in paragraph (a)(4) of this section [which requires optical imaging for inaccessible areas as defined].

(1) Optical gas imaging instrument. Use an optical gas imaging instrument for equipment leak detection in accordance with 40 CFR part 60, subpart A, §60.18(i)(1) and (2) of the Alternative work practice for monitoring equipment leaks [This is italicised in the original. It would seem to refer to some document, but word searching this rule yielded no other occurrence.]. Any emissions detected by the optical gas imaging instrument is a leak unless screened with Method 21 (40 CFR part 60, appendix A-7) monitoring, in which case 10,000 ppm or greater is designated a leak. In addition, you must operate the optical gas imaging instrument to image the source types required by this subpart in accordance with the instrument manufacturer’s operating parameters.

(2) Method 21. Use the equipment leak detection methods in 40 CFR part 60, appendix A-7, Method 21. If using Method 21 monitoring, if an instrument reading of 10,000 ppm or greater is measured, a leak is detected. Inaccessible emissions sources, as defined in 40 CFR part 60, are not exempt from this subpart. Owners or operators must use alternative leak detection devices as described in paragraph(a)(1) of this section to monitor inaccessible equipment leaks or vented emissions.

(3) Infrared laser beam illuminated instrument. Use an infrared laser beam illuminated instrument for equipment leak detection. Any emissions detected by the infrared laser beam illuminated instrument is a leak unless screened with Method 21 monitoring, in which case 10,000 ppm or greater is designated a leak. In addition, you must operate the infrared laser beam illuminated instrument to detect the source types required by this subpart in accordance with the instrument manufacturer’s operating parameters.

(4) Optical gas imaging instrument. An optical gas imaging instrument must be used for all source types that are inaccessible and cannot be monitored without elevating the monitoring personnel more than 2 meters above a support surface.

(5) Acoustic leak detection device. Use the acoustic leak detection device to detect through-valve leakage. When using the acoustic leak detection device to quantify the through-valve leakage, you must use the instrument manufacturer’s calculation methods to quantify the through-valve leak. When using the acoustic leak detection device, if a leak of 3.1 scf per hour or greater is calculated, a leak is detected. In addition, you must operate the acoustic leak detection device to monitor the source valves required by this subpart in accordance with the instrument manufacturer’s operating parameters.

Comments:

• Is acoustic leak detection (5) limited to only a subset of required monitoring? Appears that way.
• It looks like (4) is an extension of (1) and indicates that, in some cases, using a camera is the only option.

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GHG Reporting Nuts and Bolts - Article

Helpful article with some detailed guidelines and suggestions regarding GHG reporting:

GHG Reporting Article

GHG Reporting - Subpart W, brief summary

"EPA has changed the proposal in three ways. First, the rules add two new reporting segments within the sector—onshore petroleum and natural gas production and natural gas distribution facilities. Second, the rule seeks to reduce the burden on the regulated community by taking a new approach to emissions monitoring in the sector. EPA’s previous proposal relied heavily on comprehensive leak detection and direct measurements for capturing emissions data. Because emissions sources in this sector are relatively diffuse, i.e., thousands of miles of pipelines and valves, EPA recognized that direct emissions monitoring would impose a significant cost on the industry. As a result, EPA’s current proposal allows most facilities to measure emissions through engineering estimates, emission modeling software, and emission factors.[4] Third, EPA seeks to alleviate confusion caused by the previous proposal by providing separate definitions for “vented” and “fugitive” emissions instead of collectively defining both sources as “fugitive.”

"EPA’s proposal requires facilities that emit greater than 25,000 metric tons or more per year of CO2 equivalent to report their GHG emissions. Due to the diffuse nature of the storage facilities, wells, and associated pipelines in the industry sector, the proposal contains three different “facility” definitions for three different industry segments, all of which differ from the definition provided in the 2009 GHG Reporting Rule. For example, a facility in the onshore petroleum and natural gas production segment is defined to include all petroleum or natural gas equipment associated with production wells that are under common ownership or control and within one hydrocarbon basin.[5] Therefore, unlike the 2009 GHG Reporting Rule, an onshore production “facility” need not be connected or even located on adjacent properties; rather, the total fugitive and vented emissions from an unconnected network of wells, pipelines, and processing facilities would count towards the 25,000 metric ton reporting limit. Unique facility definitions are also provided for the offshore petroleum and natural gas production and natural gas distribution industry segments."

EPA Releases Additional Proposed Greenhouse Gas Emissions Reporting Rules for Three Industry Sectors Marten Law