GHG Reporting Rule Changed for RY 2016: A Streamlined Plan for

Midstream Compliance

Phil Roberts, The Williams Companies

GHG Reporting Program Changes

40 CFR Part 98Greenhouse Gas Reporting Rule2015 Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems; Final Rule

Published: 80 FR 64262October 22, 2015www.federalregister.gov

GHG Reporting Program Changes

• Why the Changes? EPA’s Response to The White House’s,

“Climate Action Plan – Strategy to ReduceMethane Emissions, March 2014”

Addressed NGO Group Petition requesting EPA to collect GHG data for known, unreported sources

• Purpose of the Changes Improve GHG Inventory by Addressing Methane

Data Gaps

Final Rule - Highlights • New Industrial Segment

Onshore Petroleum and Natural Gathering and Boosting

• Facility Definition (Gathering and Boosting) “All gathering pipelines and other equipment located along those pipelines that are under common ownership or common control by a gathering system owner or operator and that are located in a single hydrocarbon basin…”

http://archives.datapages.com/data/bulletns/1990-91/data/pg/0075/0010/0000/1644.htm?doi=10.1306%2F0C9B29C5-1710-11D7-8645000102C1865D

AAPG Bulletin 75, No. 10, Oct. 1991

http://ngmdb.usgs.gov/Geolex/stratres/provinces

Final Rule - Highlights• Who Must Report?

Facilities > 25,000 mt CO2e / yr

• Important Dates Rule Takes Effect on January 1, 2016 Automatic BAMM – All of RY 2016 First Report - March 31, 2017

• Excluded Systems Gathering systems under a vacuum Gathering systems with GOR < 300 scf / STB

Final Rule - Highlights• What GHGs Must be Reported?

CO2, CH4 and N2O from:1. Combustion emissions sources 2. Natural gas pneumatic device venting 3. Natural gas pneumatic pump venting4. Acid gas removal vents 5. Dehydrator vents6. Blowdown vent stacks

Final Rule - Highlights• What GHGs Must be Reported?

CO2, CH4 and N2O from:7. Storage tank vented emissions8. Flare stack vented emissions9. Centrifugal compressor venting

10. Reciprocating compressor venting 11. Equipment leaks12. Gathering pipeline leaks

Final Rule - Highlights• Supplemental Activity Data to be Reported Quantity of natural gas received and delivered by

the Facility Quantity of hydrocarbon liquids received and

delivered by the Facility

• Purpose of Supplemental Activity Data EPA: To “inform future policy decisions”

Final Rule - Highlights• Best Available Monitoring Methods (BAMM)

BAMM Is:o Monitoring methods that don’t meet

Subpart W specificationso Supplier datao Engineering calculationso Other company records

BAMM is used when measurement data or leak detection data can’t be collected

Final Rule - Highlights• Best Available Monitoring Methods (BAMM)

BAMM Isn’t:o An alternate means of calculating GHG

emissions

BAMM Applicability for RY 2016o Automatic; no pre-approval requiredo Applicable to new industry segments and

emission sourceso Allows reporters to prepare for data collection

Final Rule - Highlights• Combustion Emissions – Important Note If the fuel is pipeline quality gas with HHV > 950

Btu / scf, calculate emissions using any tier presented in Subpart C.

If fuel is field gas, natural gas with HHV < 950 Btu / scf, or non-pipeline quality natural gas, calculate emissions according to Subpart W.

All combustion emissions to be reported under Subpart W.

Streamlined Data CollectionEvaluate Alternate Collection Methods • Combustion Emissions

Metered fuel volume versus run-hours • Blowdown Vent Stacks

Blowdown counts versus metered volumes• Flare Stack Emissions

Metered inlet volume versus engineeringcalculations

• AGR Unit (Amine)EmissionsModeling versus quarterly sampling

Streamlined Data Collection• Natural Gas Pneumatic Device Venting Inventory Total Count and Type:

o Continuous low bleed (< 6 scfh)o Continuous high bleed (> 6 scfh) o Intermittent bleed

EPA Natural Gas STAR, 2/2/12

Streamlined Data Collection• Natural Gas Pneumatic Device Venting

RY 2016 and RY 2017o Develop engineering estimate of total number

of pneumatic deviceso Develop engineering estimate of each type

RY 2018o Hard count of total number and each type of

pneumatic devices required Type: Engineering estimate / best available data

Streamlined Data Collection• Pneumatic Device Venting Information Sources - P&IDs, equipment inventory

databases, OOOO annual reports Field Survey – Conduct device counts using

trained personnel; complete one-third of sites/yr

Streamlined Data Collection• Utilize Available Data from: Corporate measurement databases Corporate asset management systems Facility operations reports

Facility process historians

Streamlined Data Reporting• Use Direct Reporting Structure

Operating Area

Operations Technician

Designated Air Representative or

Environmental Specialist

Environmental Specialist

(GHG Reporting

Group)

Corporate Office

GHG Reporting Team

Streamlined Data Reporting• Report GHG Data on a Shared Company Application Provide portals specific to each operating area Issue read - write access for all members of the

GHG reporting team Update GHG input data on a monthly basis Conduct QA / QC review on a quarterly basis (No data on personal hard drives)

Streamlined Data Reporting• Create Stream Composition Library Standard and extended gas analyses Condensate analyses Organize by Facility (Basin) and county

• Create Modeling File Library Glycol dehydrators Storage tanks AGR Units

Streamlined Data Reporting• Standardize Reporting Forms Provide separate forms for major equipment Furnish combined form for population-based

equipment Make forms available on shared company

application

Streamlined Data Reporting• Standardize Calculation Tools Develop standard calculation tool for

each emissions source Update calculations tool in one location

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Conclusion• New, expanded reporting requirements for the

midstream sector were recently included in EPA’s revision of the Mandatory GHG Reporting Rule.

• Vented and combustion-related GHG emissions must now be reported for gathering systems in the Onshore Gathering and Boosting Sector.

• A streamlined approach to data collection and reporting will mitigate future increases in environmental compliance costs.

Conclusion• Strategies for streamlining include the following: Evaluate alternate data collection methods; Access data from existing databases and

management systems; Employ a direct GHG reporting structure; Report GHG data on a shared company

application; and Develop standardized reporting forms for

company use.

GHG Reporting Rule Changed for RY 2016: A Streamlined Plan for

Midstream Compliance

Phil Roberts, The Williams Companies