Summary: Goals, Amendments, and Important Dates

On July 6^th the EPA released a proposal to amend the Greenhouse Gas Reporting Program (GHGRP) source category requirements for Petroleum and Natural Gas Systems. Once the proposal is published in the Federal Register, there will be a 60-day public comment period.

The proposed changes to subpart W (40 CFR part 98) are a continuation of the actions mandated in the 2022 Inflation Reduction Act and EPA authority under the Clean Air Act (CAA), Section 114.

The proposed program revisions for Subpart W have two goals:

1. To expand the data sets used in greenhouse gas reporting.
2. To improve the accuracy of the reported data.

The revisions (with one exception) would take effect on January 1^st, 2025, with changes implemented during 2025, and reporting due on March 31^st, 2026.

The exception is for reporting the quantities of natural gas, crude oil, and condensate products sent to sale in the calendar year from wells permanently removed from production – meaning plugged and abandoned wells. In this case, the rule changes will be effective on January 1^st, 2025, with the quantity information included in the 2024 reporting year submission due by March 31^st, 2025.

The amendments to the GHGRP include four primary changes, intended to:

• Address facility methane reporting gaps by adding new sources to be reported (such as “other large release events”) to better capture abnormal and irregular emission events.
• Use more accurate methodologies for calculating methane/GHG emissions and include additional empirical data.
• Collect more detailed data for improved data verification and transparency.
• Clarify, correct, and amend requirements to allow better public understanding of the rule and to promote full compliance by mandated emission reporters.

The EPA is also determining whether submitted emissions data (under the proposed revisions) would be considered confidential.

Devil in the Details: Equipment and Calculations

These changes will mean more detailed reporting from the industry. Under the proposed rule, new sources to be reported may include nitrogen removal units, produced water tanks, and crankcase venting. Reporting may also be required for blowdown vent stacks, natural gas pneumatic device venting, dehydrator vents, and acid gas removal units. Some industry segments are not currently subject to reporting requirements for these components.

New or revised calculation methodologies may also be added to make GHGRP data more accurate by accounting for emissions at individual facility/site level, rather than at basin, sub-basin, or county levels.

Currently, there are five general categories of calculation methods:

• Direct emissions measurement.
• Engineering calculations.
• Combination - measurement and engineering calculation.
• Leak detection with a leaker emission factor.
• Population counts and population emission factors.

Facility owners and operators will be allowed to submit their observed emissions data for building the framework for the future implementation of CAA Section 136, which will levy charges based on methane emissions (2024 reporting).

EPA is also proposing other technical amendments, corrections, and clarifications to requirements to improve understanding of the rule by reflecting EPA’s intent in data collection and rule implementation.

Methane Megatrend: Proactive Mitigation

While regulations are not yet final, companies can take steps now to minimize known issues with leaks and emissions – modernizing equipment, sealing wells, and conducting inspections (on-site and remote). Proactive and responsible emissions reductions based on identified, known sources will put your company in control of data and protect resources.

Wellhead emissions represent one of the largest sources of fugitive methane emissions and recent innovations in downhole leak sealing technology now enables reliable, cost-effective remediation that produces an immediate environmental impact while reducing liability. BioSqueeze is a novel solution to permanently seal the most problematic methane leaks in oil and gas wells utilizing innovative biomineralization technology.