US EPA Proposes Changes to 40 CFR 98 Subpart W

The United States Environmental Protection Agency (US EPA) proposes to change 40 CFR 98 subpart W ( Greenhouse Gas Reporting – Petroleum and Natural Gas Systems). See, 81 Fed. Reg. 4987 (January 29, 2016). Certain equipment and processes related to onshore natural gas process, onshore natural gas transmission compression, underground natural gas storage, LNG storage, and LNG import and export will be affected by the proposed rule change. Comments on the proposed rule are due February 29, 2016.  

Additional leak detection and repair requirements are being added affecting onshore natural gas process, onshore natural gas transmission compression, underground natural gas storage, LNG storage, and LNG import and export equipment. These proposed changes include but are not limited to optional use of optical gas imaging instruments. US EPA is also proposing changes to the relevant emission factors.

Under this proposal, facilities with an NSPS subpart OOOOa affected well site or compressor station fugitive emissions source would use the data derived from the proposed NSPS subpart OOOOa fugitive emissions requirements along with the subpart W equipment leak survey calculation methodology and leaker emission factors to calculate and report their GHG emissions to the GHGRP.  Other sources at subpart W facilities not covered by the proposed NSPS subpart OOOOa fugitive emissions standards (e.g., sources subject to state regulations and sources participating in the Methane Challenge Program or other voluntarily implemented program) could voluntarily use the proposed leak detection methods to calculate and report their GHG emissions to the GHGRP.

Laura Goldfarb helps clients resolve their environmental policy, regulation, and enforcement problems. Prior to joining Steptoe & Johnson, Ms. Goldfarb was Assistant Counsel at the West Virginia Department of Environmental Protection, where she represented the agency in a variety of matters relating to the state's environmental programs, and drafted regulatory and statutory environmental provisions for the State of West Virginia.
 
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