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:
December 14 and 15, 2010 in Houston, Texas
INGAA plans to host additional workshops January and February of 2011
Registration for the December workshop is limited to INGAA and INGAA Foundation pipeline operators and PRCI pipeline members, with a nominal fee of $200 (Future workshops will be open to all PRCI and INGAA Foundations members). INGAA will send a PayPal link to those that have registered for the registration fee the week of November 29th. If you must be invoiced please let us know and we can provide that service as well. The registration schedule is as follows:
October 26th – November 12th: Pipeline operators (maximum 2 per company – 4 if you are a member of both PRCI and INGAA/INGAA Foundation)
November 13th – 26th: Pipeline operators may register additional registrants on a first-come, first-serve basis pending availability
November 27th – December 6th: All members of PRCI, INGAA, and the INGAA Foundation may register on a first-come, first-serve basis pending availability
Additional registration and hotel details include:
5060 West Alabama
Houston, TX 77056
We have secured a room rate of $169 per night for December 12th – 14th. If you would like to make a reservation please call (888) 627-8514 and refer to group code (INL10) at the Westin Galleria by November 26, 2010.
You may also click the following link and it will bring you to the event’s webpage and you make a reservation that way. http://www.starwoodmeeting.com/Book/INL10
The meeting registration fee is $200 per person. Please click on the link below to pay.