Page 140 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Eric P. Anderson, PMP
President
EPA Systems, LLC
Austin, Texas
Page 240 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Background
Brief Outline of the Rule Applicability
Changes for RY 2014
Changes for RY 2015
Proposed Changes for RY 2016
Summary
Page 340 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
GHG Mandatory Reporting Rule Program (GHGRP) 40 CFR Part 98
• Initially published 10/30/2009
• 46 emission source categories
• CO2, CH4, N2O, SF6, HFCs, and other fluorinated gases
Did not require control of GHG
Applicability
• >25000 MT CO2e per facility
Background
Page 440 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Offshore petroleum and
natural gas production
Onshore petroleum and
natural gas production
Onshore natural gas
processing
Onshore natural gas
transmission compression
Subpart W – Petroleum and Natural Gas Systems
Underground natural gas
storage
Liquefied natural gas (LNG)
storage
LNG import and export
equipment
Natural gas distribution
Boosting and Gathering (2016)
Page 540 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Continued
Natural gas pneumatic device and pneumatic pump venting
Well venting for liquids unloading
Gas well venting during well completions with and w/o hydraulic fracturing
Gas well venting during well workovers with and w/o hydraulic fracturing
Flare stack emissions
Storage tanks (production and transmission)
Reciprocating compressor rod packing venting
Subpart W - Source Types
Page 640 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Subpart W - Source Types
Well testing venting and flaring
Associated gas venting and flaring
Dehydrator vents
Blowdown vent stacks
EOR injection pump blowdown
Acid gas removal vents
EOR hydrocarbon liquids dissolved CO2
Centrifugal compressor venting
Equipment leaks
Combustion equipment (onshore production and distribution only)
Page 740 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Subpart C – Combustion
Subpart NN – Suppliers of Natural Gas Liquids (fractionators)
Subpart PP – Suppliers of Carbon Dioxide
Subpart RR – Geologic Sequestration of Carbon Dioxide
Subpart UU – Injection of Carbon Dioxide
Other Applicable Subparts
Page 840 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Confidential Business Information (CBI) elements back reported
for 2011, 2012, and 2013 (e.g., Deferred Reporting Elements)
• Potentially impacts Subpart C and a number of Subpart W
elements
Changes for RY 2014
Page 940 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
In August 2011 [FR 56010], EPA deferred the reporting deadline for
a number of Subpart W equation inputs until March 31, 2015.
In October 2014 [FR 63750], EPA finalized the approach to reporting
these deferred inputs and in addition made several minor
modifications to the reporting requirements for Subpart W.
This results in reporters having to submit the deferred Subpart W
data for RY 2014 and deferred data for RY 2011, RY 2012, and RY
2013 as part of the facility’s RY2014 submission.
RY 2014 General Elements
Page 1040 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
EPA allows one of two methods for 2014 reporting:
• Submit CBI data in Inputs Verifier Tool (IVT) by web form or XML
schema; or
• Submit CBI data for 2014 using Web forms or Subpart C XML
schema and indivudla spreadsheets for 2010, 2011, 2012 and
2013 (to be developed)
Subpart C Deferred Reporting
Page 1140 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Inputs to equations (e.g., number of high-bleed pneumatics)
Results of intermediate calculations (e.g., measured flow rate of
backflow)
Production / throughput data
Defined new CBI data elements applicable to reporters whose
ONLY wells in a sub-basin are either wildcat or delineation wells
(must report API well numbers)
Deferred Elements
Page 1240 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Deferred Data Elements
Page 1340 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
If spreadsheet reporter, deferred elements must be reported in
individual yearly spreadsheets
If XML reporter, deferred elements can be reported as separate
nodes in RY 2014 reporting form
In either case must report file name for previous reporting year
How to Report
Page 1440 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Wildcat or Delineation wells get 2-year reporting delay
• Applies to sub-basins where ONLY wells are delineation or
wildcat
• Delays reporting certain data associated with gas well
completions with hydraulic fracturing and production storage
tanks
Additional Elements Subject to Reporting Delay
Page 1540 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Delineation well: a well drilled in order to determine the boundary
of a field or producing reservoir.
Wildcat well: a well outside known fields or the first well drilled in
an oil or gas field where no other oil and gas production exists.
Definitions consistent with NSPS OOOO
Definitions
Page 1640 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Using IVT form assumes reporter wants all data to remain CBI
Subpart C web-form or XML Schema assumes reporter doesn’t
want data treated as CBI
If using IVT form (web-form or XML schema) relieves reporter
from reporting deferred data elements
Subpart C Deferred Reporting
Page 1740 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
CBI / Deferred elements include:
Total fuel usage (Tier 1)
Monthly fuel gas usage (Tier 2/3)
Monthly HHV values (Tier 2/3)
Average HHV value (Tier 2)
Average CC value (Tier 3)
Average MW value (Tier 3)
Subpart C Deferred Reporting
Page 1840 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Pneumatic devices and pumps (onshore production)
• Counts (or estimated counts) by classification (high bleed, low
bleed, intermittent bleed)
Acid Gas Removal (onshore production, processing)
• Annual average fraction CO2 in or out of AGR
• Total throughput through AGR (million cubic feet per year)
• Annual quantity of CO2 recovered and transferred outside the
facility under Subpart PP
Dehydrators <0.4 mmscf/day (production, processing)
• Count
Subpart W Deferred Reporting
Page 1940 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Dehydrators >0.4 mmscf/day (production, processing) must
report GRI Glycalc inputs
• Dehy feed flow rate (mmscfd)
• Absorbent circulation pump type
• Flash tank separator
• Stripper gas
• Type of absorbent
• Dehy operating hours
• Temperature and pressure of wet natural gas
• Concentration CH4 and CO2 in wet natural gas
Subpart W Deferred Reporting
Page 2040 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Gas well completions and workovers with hydraulic
fracturing
If using Equation W-10A
• Measured flow rate of backflow during completions
• Measured flow rate of backflow during workovers
• Total number of day sof backflow from all well completions
• Total number of days of backflow from all well workovers
Number of reduced emission “green” completions
Subpart W Deferred Reporting
Page 2140 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Gas well completions and workovers with hydraulic
fracturing
Volume of gas recovered to sales from green completions
Number of “green” workovers
Volume of gas recovered to sales from green workovers
Subpart W Deferred Reporting
Page 2240 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Gas well completions and workovers without hydraulic fracturing
• Total number of completions
• Total count of workovers that flared or vented gas to the
atmosphere
Blowdown vent stacks (processing)
• Total number of blowdowns for each unique physical volume in
the calendar year if using Equation-14A (was already required for
those using 14B)
Subpart W Deferred Reporting
Page 2340 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Atmospheric Storage Tanks > 10 bbls/d
• Quantity of CH4 and CO2 recovered using vapor recovery (VRU)
broken down by Methods 1 and 2 and Methods 3 and 4
• Total volume of oil from wellhead separators sent to tanks
• Total volume of oil from all wells
Atmospheric Storage Tanks < 10 bbls/d
• Number of wellhead separators
• Number wells without wellhead separators
• Quantity of CH4 and CO2 recovered using vapor recovery (VRU)
Subpart W Deferred Reporting
Page 2440 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Centrifugal and reciprocating compressors (onshore production)
• Count
Centrifugal compressors (Processing)
• Total time in operating mode (hours)
• Total time in depressurized mode (hours)
• Reporter Emission factor for blowdown vents (operational mode)
(cfh)
• Reporter Emission factor for wet seal oil degassing vent
emissions (cfh)
• Reporter Emission factor for isolation valve emissions
depressurized mode (cfh)
Subpart W Deferred Reporting
Page 2540 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Reciprocating compressors (Processing)
• Total time in operating mode (hours)
• Total time in standby pressurized mode (hours)
• Total time in depressurized mode (hours)
• Reporter Emission factor for blowdown vents (operating mode)
• Reporter Emission factor for standby pressurized mode
• Reporter Emission factor for isolation valve emissions
depressurized mode
Subpart W Deferred Reporting
Page 2640 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Well venting for liquids unloading (onshore production)
• Average flow rate of the measured well
Combustion Emissions
• Volume of fuel (by fuel type) for:
External combustion units > 5 mmBtu/hr
Internal combustion units > 1 mmBtu/hr (and compressor engines)
Subpart W Deferred Reporting
Page 2740 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Flares (onshore production, processing)
• Volume of gas combusted in cubic feet
• Combustion efficiency (normally defaulted to 98%)
Equipment leaks using emission factors (onshore production)
• Total count for each major equipment type (e.g., separators,
compressors, dehys, etc.)
Subpart W Deferred Reporting
Page 2840 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
EOR injection pump blowdown (production)
• Volume of critical phase gas between isolation valves
• Number of blowdowns per year
• EOR injection gas density
EOR dissolved liquids CO2 (production)
• Volume of oil produced per sub-basin
• Amount of CO2 retained in HC liquids
Subpart W Deferred Reporting
Page 2940 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Transmission storage tanks – no change
Well testing venting/flaring – no change
Associated gas venting/flaring – no change
Subpart W Deferred Reporting
Page 3040 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Greatly expands the reporting of inputs to equations (nearly 500
new or revised reporting outputs)
Eliminates the reporting of GHGs in CO2e
Modifies a number of equations (most notably the flowback
equations)
Modifies the data collection techniques for compressor venting
Applicable to all data collected starting 1 January 2015
Changes to RY 2015 Reporting
Page 3140 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Number of pneumatic devices
Input parameters to equations for AGRs
More inputs to Glycalc Model
Additional inputs to well venting equations
Many more well type configurations for flowback reporting
2015 Reporting Changes
Page 3240 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Many more well type configurations for flowback reporting (by
sub-basin)
• Completion/Workover
• Horizontal/Vertical
• With/Without flaring
• REC/Non-REC Completion
• Rec/Non-REC Workover
Volumetric flow rates during flowback and during period
immediately following turning gas to separation
2015 Reporting Changes
Page 3340 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Completions and Workovers w/o Fracing
• Average daily gas production rate
• Total hours gas vented to flare
• Average daily gas production rate for flared
completions/workovers
Blowdowns
• Total annual volume of gas vented from each source “unique
physical volume”
• Reporting by “equipment type”
• Total number of Blowdowns for each “equipment type”
2015 Reporting Changes
Page 3440 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Onshore Production Storage Tanks
• Changes number of calculation methods from 5 to 3
Associated Gas venting and flaring
• Changes definition of “stranded gas”
Compressor venting
• Must report reporter emission factors and associated data (e.g.,
hours in each op mode)
• Information on any Scheduled outages
• Information on venting configuration (manifolding)
• Individual measurement data
2015 Reporting Changes
Page 3540 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Flowback Calculations
• Requires the capture of the period from 1st gas appearance to
separation
• Must define reproducible procedure for how this will be done
• Requires this initial flowback gas volume to be captured
Changes to stuck dump valve calculations
Changes to associated gas venting Calculations
Addition of new compressor calculations
2015 Calculation Changes
Page 3640 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Published 9 December 2014
Scheduled for 1 January 2016 Reporting Year
Add “boosting and gathering” to Subpart W
Adds oil well flowback emissions
Proposed 2016 Changes
Page 3740 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Emissions from hydraulic fracturing of oil wells
• Uses similar equations currently used for gas wells but doesn’t
allow choke equations
Boosting and Gathering
• Facility is defined as HC Basin
• Includes pipelines, compressors, dehydration, AGR, and well
defined connection between production and downstream
• First proposed in April 2010 and then postponed
Proposed 2016 Changes
Page 3840 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Defined as:
“gathering pipelines and other equipment used to collect
petroleum and/or natural gas from onshore production gas or oil
wells and used to compress, dehydrate, sweeten, or transport the
gas to a natural gas processing facility, a natural gas transmission
pipeline, or a natural gas distribution pipeline.”
Proposed 2016 Changes
Page 3940 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Includes:
“would include, but would not be limited to, gathering pipelines,
separators, compressors, acid gas removal units, dehydrators,
pneumatic devices/pumps, storage vessels, engines, boilers,
heaters, and flares.”
Would still require 25,000 MT CO2e for reporting
Proposed 2016 Changes
Page 4040 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Emission calculation methods generally in line with onshore
natural gas production
Would require reporting API well numbers
Provisions for advanced innovative monitoring methods such as
optical remote sensing technologies
Limits BAMM
Proposed 2016 Changes
Page 4140 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Natural gas pneumatic device venting
Natural gas driven pneumatic pump venting
Acid gas removal vents.
Dehydrator vents
Blowdown vent stacks
Storage tank vented emissions
Flare stack emissions
Centrifugal compressor venting
Reciprocating compressor venting
Proposed 2016 Changes
Page 4240 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Equipment leaks from valves connectors, open ended lines,
pressure relief valves, pumps, flanges, and other equipment leak
sources (such as instruments, loading arms, stuffing boxes,
compressor seals, dump lever
arms, and breather caps)
Gathering pipeline equipment leaks.
Combustion Emissions from stationary or portable equipment
Proposed 2016 Changes
Page 4340 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Many changes happening to RY 2014, RY 2015, and potentially
RY 2016
Be aware of the changes to ensure smooth reporting in each of
the next three reporting years
Must have reporting procedures ready for 2015 and be ready to
implement new 2016 requirements
Summary
Page 4440 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Thank You
And
Happy Reporting
Page 4540 CFR Part 98 GHG Reporting for the Oil and Gas Industry
Rule, Past, Present, and Future
Eric P. Anderson, PMP
EPA Systems, LLC
4201 W. Parmer Ln
Building B, Suite 280
512-821-1504