American Oil and Gas Reporter - May 2016 - 58

into their appropriate AAPG hydrocarbon
basins and collecting relevant sub-basin
flowback to production rate information;
* Segmenting well pads in appropriate
reporting segments; and
* Identifying function groups that
maintain required data.
As an example of identifying function
groups to maintain data, the design group
may maintain well pad equipment details
for leakage emissions, while the production
group may maintain throughput and flaring
information. The objective is to identify
sources that can provide the required data.
It is not uncommon for these data sources
to be from completely disparate systems.
However, the focus at this step is to make
sure data from these systems can be
bridged into a centralized database.
The final step is reporting. Annual
GHG reports must be submitted electronically. Once submitted, reports are
evaluated by electronic validation and
verification checks. If potential errors are
identified, EPA will notify the reporter,
who can either describe why the flagged
issue is not an error, or correct the flagged
issue and resubmit the report.
As the regulatory regime evolves and
agencies increase enforcement, a wellthought-out program that embraces the
operator's organizational structure, operations, and field personnel, coupled with
a robust tracking system, will lead to
compliant operations. A system itself will
not be successful without management
buy-in. It is imperative for management
to promote and emphasize interdepartmental collaboration to ensure information
is provided to compliance staff in a timely
and complete fashion.
❒

THOMAS S.
SEGULJIC

Thomas S. Seguljic is a vice president
with HRP Associates Inc. in Clifton Park,
N.Y. He has more than 30 years of experience in environmental engineering consulting, including advising industrial
and oil and gas clients throughout the
United States. Seguljic has worked with
clients to identify clean air permitting/operating requirements, and to implement
compliance strategies to ensure compliance and reduce compliance costs. He
holds a B.S. in mechanical engineering
from Colorado State University.

JOHN P.
MARTIN

John P. Martin is the founder of JPMartin Energy Strategy LLC in Saratoga
Springs, N.Y. The company provides
consulting, strategic planning, and policy

analysis to the energy industry, academic
institutions, and governments. Prior to
forming the consultancy, Martin spent
17 years working on energy research
and policy issues at the New York State
Energy Research and Development Authority. He holds a B.S. in geology, an
M.S. in economics, and a Ph.D. in environmental studies from Rensselaer
Polytechnic Institute. Martin also holds
an M.B.A. from Miami University.

GARY J.
STIEGEL JR.

Gary J. Stiegel Jr. is a senior permitting engineer with EdgeMarc Energy
Holdings LLC in Canonsburg, Pa. He
is responsible for all permitting and
environmental compliance associated
with the company's exploration and
production activities in Pennsylvania
and Ohio. Stiegel has 13 years of experience in dealing with numerous environmental aspects of the energy sector.
He holds a B.S. and an M.S. in chemical
engineering from the University of Pittsburgh.

States Get Jump On Leak Detection
CLIFTON PARK, N.Y.-Wyoming,
Colorado, Pennsylvania and Ohio were
the first of several states to require leak
detection and repair of well pads and
compressor stations using optical gas
imaging (OGI) or approved Method 21.
Typically, the states require that a
leak detection test be conducted initially
within 30 to 60 days of startup and
then periodically thereafter, ranging
from quarterly to annually. Any noted
leakers must be repaired within 15 days
and retested to verify repairs. Interestingly, most states define what a leak is
based on a leakage rate (i.e., connector:
10,000 parts per million utilizing Method
21). Pennsylvania, however, defines a
repair as no detectable emissions or
bubbles utilizing Method 21, etc.
Now the EPA has decided to enter
58 THE AMERICAN OIL & GAS REPORTER

the game. As part of Subpart OOOOa,
EPA is proposing leak detection and
repair requirements, and is using the leak
detection information for calculating emissions under Subpart W. As proposed,
Subpart OOOOa would require operators
of well pads and compressor stations to
conduct initial and semiannual leak detection tests using optical gas imaging.
However, if leaks are detected from more
than 3 percent of components, testing
must be conducted quarterly.
Components with leakage rates greater
than 500 ppm above background utilizing
Method 21 must be repaired within 15 days
(more time may be allowed to repair more
complex components) and resurveyed within
15 days of repair to ensure the repair has
been successful (i.e., no fugitive emissions
are imaged using OGI or less than 500 ppm

above background when using Method
21).
Since studies have found that the
majority of emissions are from a few
components that have high leak rates,
and Subpart OOOOa will require repairing these high-leakage components,
fugitive emissions will be reduced. However, the reduced GHG emissions will
not be reported or tracked within GHG
reports since Subpart W utilizes component counts and emissions factors.
Therefore, to track changes in GHG
emissions from year to year to show
reduced emissions, the EPA specifies
that operators use the actual number of
leaks identified and the proposed leaker
emission factors to determine their
equipment leak emissions, instead of
the default population emission factors.❒



American Oil and Gas Reporter - May 2016

Table of Contents for the Digital Edition of American Oil and Gas Reporter - May 2016

Contents
American Oil and Gas Reporter - May 2016 - Cover1
American Oil and Gas Reporter - May 2016 - Cover2
American Oil and Gas Reporter - May 2016 - Contents
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American Oil and Gas Reporter - May 2016 - Cover3
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