GHG/Fugitive Emissions Legislation & Rulemakings: Impact On Design & Operations Of Compression Facilities

Problem Statement
With New GHG initiatives, including proposed GHG reporting rule and current Waxman Markey bill that is working its way through Congress, the gas transmission industry will have to account for and perhaps take mitigation action related to fugitive emissions, which account for approximately 50% of the industry’s GHG footprint. Broadly speaking, fugitive emissions include leaks from sources such as rod packing, valves, actuators and venting events. There is a need to take a step back from the current design and operational thinking that has become best practice in the industry and consider what such practices should look like if and when this new legislation and related rulemakings are in place.

Proposed Effort 
The study will focus in two key areas, including: 1) design of new or expanded facilities, and 2) operations of existing facilities. For each of these areas, the effort will include:

• Characterization of current best practice;
• Estimated impact of new regulatory requirements;
• Identification and prioritization of issues resulting from impact relative to current best practice;
• Identification of new or alternative approaches that address these issues, as well as preliminary assessment regarding technical and economic effectiveness of such; and
• Conclusions and recommendations for next steps.

Study Status Update
Staff is developing an Request For Proposals (RFP) expected to be released in March, 2010.