Odds and Ends, Archive 4
EPA Issues FINAL RULE
On September 22 the EPA announced the FINAL rule on Greenhouse Gas Reporting. This has been updated to include basic provisions of the FINAL RULE, but as we read more about the new rule and more details emerge, this page may evolve to reflect important new information.
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Greenhouse Gas Reporting
Disclaimer – No two facilities are alike and there are several hundred pages of rule that need to be considered. Use this information as a guide, but do your homework when applying this general information to any specific facility or source.
If you have comments or corrections to the information presented, please contact me at jack@sevensistersenviro.com
Greenhouse Gases
The primary gases to be regulated by the rule and their associated Global Warming Potential (GWP) as defined in the rule (there are slightly different values floating around in the literature):
1. Carbon Dioxide (CO2); GWP = 1
2. Methane (CH4); GWP = 21
3. Nitrous Oxide (N2O); GWP = 310 (not to be confused with NOx, a criteria pollutant)
4. Sulfur Hexafluoride (SF6); GWP = 23,900
5. Several dozen species of other fluorinated gases, mostly hydrocarbon gases, used as refrigerants and in other industrial processes; GWP varies between 11 – 17,700
The GWP will be used to quantify emissions in terms of Carbon Dioxide Equivalent (CO2e) – for example, three (3) metric tons (MT) of methane will be reported as 63 MT of CO2e (3 MT x 21 GWP = 63.
GHG Reporting in the Oil and Gas Industry
The FINAL RULE, announced on September 22, 2009, deferred reporting for many upstream oil and gas facilities. Subpart W (Oil and Natural Gas Systems) was deferred because of potential 'double reporting' issues and the lack of clarity in the DRAFT RULE. However many oil and gas facilities will be required to report under one or more of some of the other subparts. For example:
1. Subpart C – General Stationary Fuel Combustion Sources (engines, boilers, heaters, etc.). Any facility with emissions of at least 25,000 metric tonnes of CO2e from combustion sources (engines, boilers, etc.) will be required to report under this subpart.
2. Subpart NN – Suppliers of Natural Gas and Natural Gas Liquids (NGL) – the natural gas suppliers targeted are local distribution companies only - not upstream or midstream gas plants. However, gas plants that fractionate NGLs into commercial products (e.g., propane, butane, etc.) will likely be subject to reporting under this part, but plants that produce y-grade NGLs that are further fractionated at another facility will not be required to report under NN.
4. Subpart PP – Suppliers of Carbon Dioxide – upstream production (wellhead) facilities that supply CO2 will be required to report under PP. However, CO2 compression, pipeline, or storage facilities as well as operators who recycle CO2 for enhanced oil recovery purposes are not covered by this subpart.
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If you have any questions or comments, don't hesitate to contact me at jack@sevensistersenviro.com.
