September 2022 Vol. 77 No. 9
Washington Watch
Newest EPA Methane Proposal Hits Pipelines Hard
Stephen Barlas | Washington, D.C. Editor
The United States Senate bill on climate change, which includes a fee on pipeline emissions of methane, puts a new emphasis on the Environmental Protection Agency’s (EPA) two rulemakings on greenhouse gas emissions (GHG).
If the new methane fee passes Congress, and that is not certain, it would probably be tied to interstate pipeline compliance with the two rulemakings: one from 2021, which imposes new methane controls, and the newest one from June 2022, which imposes new recordkeeping and reporting requirements.
EPA’s proposed GHG emission reporting rule came out in June quietly and without fanfare That proposal would drastically increase natural gas sector measuring, calculation and reporting requirements for methane and, undoubtedly, serve as a stimulus for emission reductions of methane from compressors. Natural gas groups immediately complained about the initial two-month comment period and the EPA extended it to Oct. 6, 2022.
The GHG reporting rule was initially established in 2009. But the Biden EPA wants to make significant, prescriptive methane emission calculation changes heavily imposed on a single industry. Natural gas is covered in the 2009 rule by what is called Subpart W (Petroleum and Natural Gas Systems), which includes four categories: onshore petroleum and natural gas production, onshore petroleum and natural gas gathering and boosting, natural gas distribution, and onshore natural gas transmission pipeline.
Its decision to “improve” – in the Biden EPA’s words – the 12-year-old GHG rule will allow it to “incorporate new data or updated scientific knowledge; reflect new emissions sources; improve analysis and verification of collected data; provide additional data to complement or inform other EPA programs; or streamline calculation, monitoring, or reporting to provide flexibility or increase the efficiency of data collection.”
EPA’s cost estimates show that sources subject to Subpart W will bear approximately an 82-percent incremental burden associated with the proposed rule. That equates to an annual cost, almost exclusively for administrative labor, of $1.2 million a year, according to the EPA. The proposed rule affects more than 2,300 Subpart W reporters, reflects 504 new data elements and 153 revised data elements.
Regarding interstate pipelines, the proposal contemplates numerous – potentially onerous – new requirements on compressor emissions. Interstate Natural Gas Association of American (INGAA) member companies operate over 5,400 natural gas compressors at more than 1,300 compressor stations and storage facilities.
When Scott Yager, vice president-environment, INGAA, wrote to the EPA asking for an extension of the initial 60-day comment deadline, he argued some of the proposed emissions factors have increased by 150 to 400 percent. He termed those increases “enormous.”
Making matters worse for pipelines is the fact this proposal cites, in places, a second new, proposed rule issued by the Biden EPA in November 2021: “Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review.”
That proposed rule would require emissions guidelines for state implementation that would apply a 95-percent volatile organic compound (VOC) and methane reduction requirement from centrifugal wet seals to all existing sources, as of Nov. 15, 2021. However, it has not been finalized.
It, too, has major implications for compressor emissions of methane. Michael J. Pitta, vice president, Kinder Morgan Inc., whose pipelines account for about 40 percent of the natural gas used by consumers in the U.S., told the EPA that despite the company’s substantial experience with wet seals, it, like many of its peers, has no experience capturing or controlling emissions from wet seals by 95 percent. KM has consistently installed only dry seals on its centrifugal compressors.
Dry versus wet seals also comes into play in the new proposed requirements for GHG reporting, which are detailed, technical and cover centrifugal and reciprocating compressors. The June 2022 proposal adds dry seal vents to the defined compressor sources for centrifugal compressors and requires measurement of volumetric emissions from the dry seal vents in both operating and standby-pressurized modes.
Another change would require measurement of volumetric emissions from the wet seal oil degassing vent and volumetric emissions from blowdown valve leakage through the blowdown vent, when the compressor is found in add standby-pressurized-mode. Rod packing emissions for reciprocating compressors would have to be measured when found in the standby-pressurized mode.
To get an idea of how truly technical the proposed June rule is, the EPA says it wants to address uncombusted methane emissions from compressor drivers by requiring pipelines “to use the CH4 emission factors in Table W-9 to subpart W rather than the default CH4 emission factor for natural gas in Table C-2 to subpart C.”
And if that were not technical enough, the EPA goes on to say, “the default CH4 emission factor for natural gas may only be used for natural gas-fired combustion units that are not compressor drivers.”
Comments