The Greenhouse Gas Reporting Program (GHGRP) is a critical component of the United States Environmental Protection Agency’s (EPA) efforts to monitor and manage greenhouse gas (GHG) emissions. Subpart W of the GHGRP specifically addresses the petroleum and natural gas systems sector. This article provides an overview of the key requirements and provisions of Subpart W, as outlined in the Code of Federal Regulations (CFR).
Overview
Subpart W of Part 98 of the CFR mandates reporting of GHG emissions from facilities involved in the petroleum and natural gas industry. This subpart aims to collect data that can be used to understand and manage emissions from these sectors, which are significant sources of methane (CH₄) and carbon dioxide (CO₂).
Facilities that fall under the following categories are required to report under Subpart W:
- Onshore Petroleum and Natural Gas Production: Operations involved in the extraction of crude oil and natural gas.
- Offshore Petroleum and Natural Gas Production: Activities conducted in offshore platforms.
- Natural Gas Processing: Facilities where natural gas liquids are extracted from raw gas.
- Natural Gas Transmission Compression: Stations that compress natural gas for transportation through pipelines.
- Natural Gas Transmission Pipelines: Operators of pipelines transporting natural gas.
- Natural Gas Distribution: Local distribution companies delivering gas to consumers.
- Underground Natural Gas Storage: Facilities storing natural gas underground.
- LNG Storage and Import/Export: Operations involving liquefied natural gas (LNG) storage and transfer.
Reporting Thresholds
Facilities are required to report if they emit 25,000 metric tons or more of CO₂ equivalent per year. This threshold ensures that the reporting focuses on significant sources of emissions.
Reporting Requirements
Emission Sources
Subpart W requires facilities to report emissions from various sources, including but not limited to:
- Combustion Emissions: Emissions from burning fossil fuels for energy.
- Venting and Flaring: Emissions from intentional releases and burning of gases.
- Equipment Leaks: Emissions from leaks in equipment such as valves and connectors.
- Storage Tanks: Emissions from tanks storing petroleum or natural gas.
Calculation Methods
Facilities must use specific calculation methods to estimate emissions, which may include:
- Direct Measurement: Using instruments to measure emissions directly.
- Engineering Estimates: Calculations based on engineering principles.
- Emission Factors: Standardized factors applied to activity data to estimate emissions.
Monitoring and Recordkeeping
Facilities are required to:
- Maintain records of all data used to calculate emissions for at least three years.
- Use approved monitoring methods to ensure accuracy and consistency.
- Submit annual reports to the EPA by March 31st of the following year.
Verification and Compliance
The EPA may conduct audits and inspections to verify the accuracy of reported data. Facilities found to be non-compliant may face enforcement actions, including fines and mandatory corrective measures.
Summary
Subpart W of the GHGRP is a crucial regulation for managing GHG emissions from the petroleum and natural gas sectors. By requiring detailed reporting and maintaining stringent standards for measurement and verification, the EPA seeks to enhance transparency and accountability in emissions reporting. Compliance with these requirements can also help facilities identify opportunities for reducing emissions and improving operational efficiency.
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