New Year Brings New MRR Subpart W Amendments



EPA has once again amended Subpart W for Petroleum and Natural Gas Systems under the Mandatory GHG Reporting Rule (40 CFR Part 98).  EPA finalized the amendments on October 22, 2015, and they became effective on January 1, 2016.  The Subpart W amendments include the following changes: 

  • Requires reporting of GHGs from completions and workovers of oil wells with hydraulic fracturing (part of existing onshore industry segment)
  • Adds requirements for two new industry segments:
    • Onshore Petroleum and Natural Gas Gathering and Boosting
    • Onshore NG Transmission Pipelines (for transmission pipeline blowdowns between compressor stations)    
  • Requires reporting of well identification numbers for oil and gas well-specific information (reported in Onshore P&NG segment)
  • Finalizes confidentiality determinations for the new data elements associated with these amendments  

What do these amendments mean for your facility in 2016?  The amendments revise some monitoring requirements and emission calculations that affect calendar year 2016 emissions.  That means the changes do not affect your upcoming annual report due by March 31, 2016, which covers calendar year 2015 emissions (i.e.,existing calculation methodologies apply for reporting year 2015). 

The amendments apply only to monitoring and emission calculations performed beginning in calendar year 2016.  Thus the annual report submitted in March 2017 (covering calendar year 2016 emissions) will be the first report which reflects the new requirements.  

If you cannot follow the new monitoring requirements in 2016, the rule allows use of Best Available Monitoring Methods (BAMM) for 2016 only.  This allows the facility to transition to the new requirements by 2017.  Reporters can use BAMM in 2016 without requesting approval from EPA; however,EPA is not accepting extensions for using BAMM beyond 2016.  Note that BAMM does not apply to the well identification numbers requirement. 

Also, don’t forget to update your Monitoring Plans to reflect any changes in data collection, quality assurance, or calculation methods as required by 40 CFR 98.3(g)(5).  

For additional support regarding GHG reporting, contact Georgette Reeves at greeves@trinityconsultants.com or Aimee Andrews at aandrews@trinityconsultants.com.