LEARN MORE ABOUT EPA’S MANDATORY GREENHOUSE GAS REPORTING RULE REQUIREMENTS FOR NATURAL GAS TRANSMISSION AND UNDERGROUND STORAGE AT THE INGAA FOUNDATION AND PRCI WORKSHOP
The U.S. EPA released the Greenhouse Gas (GHG) Mandatory Reporting Rule (MRR) in October 2009. The rule includes GHG reporting requirements for stationary combustion sources under Subpart C of 40 CFR, Part 98. Facilities with 25,000 metric tons or more of CO2 equivalent GHG emissions are required to report. EPA did not include vented and fugitive emissions in the 2009 rule, but on April 12, 2010 EPA re-proposed Subpart W of the MRR to address reporting of fugitive and vented GHG emissions for petroleum and natural gas systems. EPA plans to finalize Subpart W in the fall of 2010 and require reporting of the 2011 inventory for all natural gas industry segments from exploration and production through distribution. The proposed rule identifies requirements by segment, including natural gas transmission and underground storage. Subpart W emission sources for transmission include pneumatic devices, compressor venting, blowdown venting, storage tank venting (from dump valve leakage), and fugitive emissions. Emission estimation methods include vent measurement, engineering calculations, and emission factor approaches based on component counts and identification of leaking components.
EPA intends to require reporting of 2011 emissions by March 31, 2012 so operators will need to be prepared to implement Subpart W shortly after the final rule is released in late 2010. This workshop will review Subpart W requirements for the natural gas transmission and underground storage segments and provide “compliance checklists” to facilitate rule compliance. Subpart C reporting of combustion GHG emissions already applies, with 2010 emission reports required by March 31, 2011. Although companies have been addressing Subpart C, these requirements will also be discussed and compliance checklists provided.
INGAA provided extensive comments on the proposed Subpart W rule. The Workshop will address Final Rule requirements for transmission and storage. Based on the proposed rule, topics include:
· Facility applicability determination, including any “streamlined” methods in the Final Rule;
· Review of estimation methods for seven transmission and five underground storage source types;
· Measurement and leak survey requirements, mode-based testing, and use of consensus methods or industry practices;
· Documentation requirements, QA/QC requirements and deadlines, and the GHG Monitoring Plan;
· Final Rule allowances for phase-in, consideration of safety concerns, or interim use of “best data”;
· Review of Subpart C requirements and compliance checklists.
WORKSHOP DATES AND LOCATIONS:
January 19 and 20 in Atlanta, Georgia
REGISTRATION INFORMATION:
Registration for the January workshop is open to INGAA, INGAA Foundation and PRCI members, with a nominal fee of $200 . If you are not a member of one of these groups, please contact Kate Nett at knett@ingaa.org to inquire about availability of space. INGAA will send a PayPal link to those that have registered for the registration fee the week of January 4th. If you must be invoiced please let us know and we can provide that service as well. The registration schedule is as follows:
Additional registration and hotel details include:
Atlanta Marriott Marquis
265 Peachtree Center Avenue
Atlanta, GA 30303
We have secured a room rate of $159 per night for January 18th – 20th. If you would like to make a reservation please call (800) 266-9432 and refer to the Interstate Natural Gas Association of America 2011 Conference at the Atlanta Marriott Marquis by January 11, 2011.
You can also make a reservation by using the following link.
https://resweb.passkey.com/Resweb.do?mode=welcome_gi_new&groupID=3256461
The meeting registration fee is $200 per person. Please click on the link below to pay.
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