With the stated intent of improving clarity and consistency, the EPA has proposed multiple changes to 40 CFR 98 subpart W, the section of the GHG reporting program (GHGRP) affecting emissions that must be reported by operators in the petroleum and natural gas sector.

According to the Agency, the proposed changes revise certain calculation methods, amend certain monitoring and data reporting requirements, clarify certain terms and definitions, and correct certain technical and editorial errors that have been identified during implementation.  The proposed revisions were identified from the verification of annual reports, reviews of best available monitoring method (BAMM) request submittals, and questions raised by reporting entities.

No additional CBI protections

Because of the proposed changes, the EPA must also revisit the confidential business information (CBI) status of new or revised data that must be submitted by operators.  The Clean Air Act (CAA) prohibits the Agency from giving CBI protection to emissions data, which, in the context of the GHGRP, generally refers to inputs to emissions equations.   The Agency is proposing that the CBI applies neither to any of the new/revised data elements nor for one existing data element. 

BAMM to be removed

The EPA lists the proposed changes as follows:

• Revise units of measure, terms, and definitions in certain equations to provide consistency throughout the rule, provide clarity, and better reflect facility operations.
• Clarify or simplify calculation methods for certain sources at a facility, such as liquids unloading, completions and workovers, onshore production storage tanks, blowdown vents, associated gas venting and flaring, and natural gas distribution sources.
• Expand the use of site-specific gas composition data for natural gas transmission compression and underground natural gas storage facilities.
• Revise calculation methods for centrifugal and reciprocating compressors that have presented safety and operational process concerns for reporters.
• Clarify and provide greater specificity regarding procedures for estimating missing data.
• Remove provisions related to BAMM since the proposed revisions address safety and technical concerns that may have prevented full compliance with the rule.
• Revise reporting requirements to clarify and align more closely with the calculation methods and to clearly identify the data that must be reported for each source type.

Compliance with 2015 reports

The EPA is planning to address the comments on the proposed changes and publish final amendments before the end of 2014.  If finalized, these amendments would become effective January 1, 2015.  Facilities would therefore be required to follow the revised methods to calculate emissions beginning January 1, 2015 (i.e., beginning with the 2015 reporting year).  The first annual reports of emissions calculated using the amended requirements would be those submitted by March 31, 2016, which would cover the 2015 reporting year.  For the 2014 reporting year, reporters would continue to calculate emissions and other relevant data for reports that are submitted according to existing requirements at 40 CFR Part 98, which are applicable to the 2014 reporting year (i.e., those currently in effect).

EPA’s GHGRP proposal for the oil and gas (O&G) sector was published in the March 10, 2014, FR.