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APGA comment on EPA greenhouse gas reporting rule

Oilfield Technology,

In the August 4th, Federal register EPA is proposing changes to the GHG reporting rules. Included in the proposal is a one time extension of the 2012 reporting deadline for facilities and suppliers subject to source categories for which data collection begin January 1st 2011 which includes reporting fugitive emissions of methane under subpart W. The new deadline is September 28th 2012. All facilities and suppliers subject to reporting would still be required to report their GHG information for all other subparts by March 31st 2012.

Inexplicably, EPA did not address the errors in Equation W-32 for calculating estimated emission factors for non-custody transfer gate stations. APGA has pointed out to EPA that equation W-32, which is intended to be the average, hourly leak rates from an operator’s custody transfer gate stations, actually calculates a sum of the annual emissions from there facilities. As a result Equation W-32 results in over estimating leak rates by a factor of at least 8760, the number of hours in a year.

APGA will be filing comments with EPA pointing out this and other concerns with Subpart W. The operations and safety committee is currently reviewing the proposed rule. Comments are due to the EPA by no later than September 19th 2011.

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