American Oil and Gas Reporter - May 2016 - 56

SpecialReport: Compression & Production Optimization
a single well pad or associated with a single
well pad used in production. This can include
pipelines and separators located on the pad.
However, the gathering and boosting
segment, by definition, includes gathering
pipelines and other equipment used to
collect liquids and/or natural gas from onshore gas or oil production wells, and to
compress, condition or transport the oil/natural gas to a processing facility, transmission
pipeline or distribution pipeline.
On a multiwell pad, the gathering and
boosting segment begins at the point
where the flow from two or more wells
is combined, so pipelines and separators
located downstream of these combination
points are now considered part of gathering
and boosting, even if they are physically
located on the well pad.
Also beginning in 2016, facilities that
meet the definition of the gathering and
boosting segment will include stationary
and portable fuel combustion equipment
that may have been reported previously
under Subpart C as "general stationary fuel
combustion sources." Keep in mind that
because of the rule's definitions, an operator's

56 THE AMERICAN OIL & GAS REPORTER

combustion sources that previously were
subject to Subpart C may be covered by
the gathering and boosting segment starting
this year. In such events, the EPA has stated
that for reporting year 2015, operators
should continue to report under Subpart C,
but that the combustion emission should
be included under gathering and boosting
starting in reporting year 2016.
In January 2016, the EPA proposed additional Subpart W revisions that added
new leak detection monitoring methods,
leaking equipment emission factors, reporting
requirements, and confidentiality determinations. The purpose of the proposed equipment leak requirements is to align leak detection methods with the recently proposed
Subpart OOOOa. As such, if Subpart
OOOOa (when final) is amended to incorporate new technologies or monitoring
methods, Subpart W requirements will be
updated automatically by reference.
The proposed leak detection provisions
would be required only for sources reporting under Subpart W that are also
subject to Subpart OOOOa. Facilities
with a Subpart OOOOa-affected source

would calculate and report their GHG
emissions by using the data derived from
the Subpart OOOOa fugitive emissions
requirements, the Subpart W equipment
leak survey calculations, and leaker emission factors. For sources reporting under
Subpart W that are not subject to Subpart
OOOOa (i.e., flares, dehydrators, etc.),
the proposed leak detection methods
could be used voluntarily.
Meeting The Challenge
Given that companies potentially have
hundreds or thousands of wells, gathering
lines and associated equipment, thousands
of datasets need to be collected to report
GHG emissions. The sheer volume of
information collected not only represents
emissions data, but also the potential for
noncompliance.
Successful entities look at this process
as an opportunity to not only track GHG
emissions, but also to establish management systems to ensure compliance with
the myriad operating requirements. Since
each entity's operation and size are unique,
systems differ in approach, data collection,
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American Oil and Gas Reporter - May 2016

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