(97c) Challenges of Evaluating Regulatory Compliance with the GHG Mandatory Reporting Rule

Compliance with the “Mandatory Reporting of Greenhouse Gases: Petroleum and Natural Gas Systems” for the gas processing and gathering industry has been challenging in many ways.  Not only has the rule implementation timeframe been aggressive, but these new rules apply to a large number of facilities and sources that have not previously been required to be tracked and quantified. 

This presentation will investigate the approach that was taken to identify the requirements and achieve regulatory compliance at major oil and gas operating company with Subparts C and W of the rule.  The challenges include: 

• Legacy facilities – what measurements are available and what meets the rule?
• Facility Definition Conflicts – Subparts C and W
• Measurements and Tracking
  • Rod Packing Venting Rates
  • Compressor and station blowdowns as well as starter gas using natural gas
  • Flaring events
  • Compressor station treating and glycol dehydrator vents
  • Data Collection
  • Data Retention

 The solutions adopted to address compliance will be discussed.