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April 14, 2011

Greenhouse Gas Monitoring Workshop

The INGAA Foundation and PRCI are jointly sponsoring a project to characterize Greenhouse Gas (GHG) Measurement Methods, Procedures and Reporting Systems to enable cost-effective compliance with the recently issued Greenhouse Gas Monitoring Rule. In November of 2010, the EPA finalized subpart W of their GHG Reporting Rule that requires gas pipelines to report annually on their emissions (combustion emissions under Subpart C and fugitive emissions under Subpart W of the rule). Unfortunately, reporting compliance is challenging due to the lack of experience with the testing requirements and reporting protocols in the rule. This situation creates great uncertainty and risk for pipelines who must comply with this rule in 2011, and three training workshops have been planned to facilitate operator compliance. The first Workshop was held in Houston on December 14-15, 2010 and attended by ~100 industry personnel. The second workshop was held in Atlanta, GA, January 19-20, 2011 with ~30 in attendance, and with participation by leak detection instrument vendors, whose equipment is specified for use by the EPA.

The contractor of the INGAA/PRCI project, Innovative Environmental Solutions, provided information on the methods and standard operating procedures that are required under the rule, identified technical gaps in the rule requirements, and provided a checklist for compliance. The Workshop primarily focused on the rather complicated Subpart W, though implementation guidance was provided for the more straightforward subpart C. Prescriptive test methods required by EPA and their proper implementation were outlined, and the specific source testing requirements and emissions estimation methods were reviewed. Panel discussions provided a forum for operators to examine common compliance issues and potential approaches. A set of issues were identified that require future dialogue with EPA to clarify various aspects of the rule.

The final Workshop is tentatively scheduled for early fourth quarter of 2011, and this will cover changes to compliance methods and strategies that will result from the ongoing refinement and clarification of the Rule. Significant efforts are underway to encourage the EPA to improve the ability of operators to comply with this regulation.

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