### MEMORANDUM

To: Docket # EPA

- HQ

- OAR

- 2011

- 0512

From: Mark d e Figueiredo, EPA/CCD

Date: November 10 , 201 4

Subject: Minor Technical Corrections to Subpart W, Greenhouse Gas Reporting Rule: 2014 Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems; Final Rule

The EPA is finaliz ing revisions to the petroleum and natural gas systems source category of the Greenhouse Gas Reporting Rule (40 CFR p art 98 , subpart W) . The changes revise calculation methods, amend monitoring and data reporting requirements, clarify certain terms and definit ions, and correct technical and editorial errors identified during the course of implementation. The purpose of this memorandum is to provide a detailed list of minor or clarifying changes that are not discussed in the preamble s to either the final or pro posed amendments to subpart W ( “ Greenhouse Gas Reporting Rule: 2014 Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems; Final Rule ” )

. T able 1 contains a list of the minor change s , the current rule language for the requiremen t, and the revised rule language. A n explanation for the change is included

. These changes are minor clarifications to better reflect the EPA’s intent and include simple corrections to calculation terms or cross

- references that do not revise the output of the calculations, harmonizing changes within the subpart (such as changes to terminology), simple editorial and minor error corrections, or removal of redundant
text. R evisions to the reporting section of subpart W are not included in this memorandum, but are discussed in a separate document included in this docket entitled

, “ Final Revisions to the Subpart W Reporting Requirements in the Greenhouse Gas Reporting Rule: 2014 Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems; F inal Rule

. ”

1

### Table 1. Minor Technical Corrections

Final Rule

Citation Current Text Revised Text Reason for Change § 98.232(c)(11), (d)(1), (e)(1), (f)(1),(g)(1), (h)(1) Reciprocating compressor rod packing venting

. Reciprocating compressor venting

. Harmonizing edit

§98. 232(i)(1) (1) Meters, regulators, and associated equipment at above grade transmission

distribution transfer stations, including equipment leaks from connectors, block valves, control valves, pressure relief valves, orifice meters, regulators, and open ended lines. (1) Equipment leaks from connectors, block valves, control valves, pressure relief valves, orifice meters,

re gulators, and open

- ended lines at above grade transmission

- distribution transfer stations. Clarifying edit

§98. 232(i)(2) and (i)(4) (2) Eq uipment leaks from vaults at... (2) Equipment leaks at... Clarifying edit

§98. 232(i)(3) (3) Meters, regulators, and associated equipment at above grade metering

regulating station. (3) Equipment leaks at above grade metering

- regulating stations that are not above grade transmission

- distribution transfer stations. Clarifying edit

§98. 232(i)(5) (5) Pipeline main equipmen t leaks. (5) Distribution main equipment leaks. Clarifying edit

§98. 232(i)(6) (6) Service line equipment leaks. (6) Distribution services equipment leaks. Clarifying edit

§98. 233 throughout Methodologies Methods Clarifying edit

CEMS Continuous emissions monitoring system (CEMS) Clarifying edit

General Stationary Fuel Combustion General Stationary Fuel Combustion Sources Clarifying edit

§98. 233(a) and (c) Equation W

- 1 and W

- 2 calculate mass emissions in CO 2 e

. Removed t erm “ Conv i ” so that E quations W

- 1 and W

- 2 calculate volumetric emissions instead of mass emissions in CO 2 e. Global warming potential for methane removed from calculation.



### 2

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change §98.233(a) and (c) introductory paragraphs (a) Natural gas pneumatic device venting. Calculate CH 4 and CO 2 emissions from continuous high bleed, continuous low bleed, and intermittent bleed natural gas pneumatic devices using Equation W

- 1 of t his section. (a) Natural gas pneumatic device venting. Calculate CH 4 and CO 2 volumetric emissions from continuous high bleed, continuous low bleed, and intermittent bleed natural gas pneumatic devices using Equation W

- 1 of this section. Clarified that calc ulated results in both paragraphs are volumetric emissions, and additional clarifying edit in paragraph (c).

(c) Natural gas driven pneumatic pump venting. Calculate CH 4 and CO 2 emissions from natural gas driven pneumatic pump venting using Equation W

- 2 of this section. Natural gas driven pneumatic pumps covered in paragraph (e) of this section do not have to report emissions under paragraph (c) of this section. (c) Natural gas d riven pneumatic pump venting. Calculate CH 4 and CO 2 volumetric emissions from natural gas driven pneumatic pump venting using Equation W

- 2 of this section. Natural gas driven pneumatic pumps covered in paragraph (e) of this section do not have to report

em issions under this paragraph (c). §98.233(a) and (c); Terms Mass t,i ” in Equation W

- 1and

“ Mass i ” in Equation W

- 2 Mass t,i = Annual total mass GHG emissions in metric tons CO 2 e per year from a natural gas pneumatic device vent of type “ t ,” for GHG i
. (Eq. W

- 1) E s,i = Annual total volumetric GHG emissions at standard conditions in standard cubic feet per year from natural gas pneumatic device vents, of types “ t ” (continuous high bleed, continuous low bleed, intermittent bleed), for GHG i

. Changed equatio n terms from “ Mass t,i ” (Equation W

- 1) and

“ Mass i ” (Equation W

2) to “ E s,i ” and revised units from mass to volumetric at standard condition s (EPA is revis ing the reporting of annual emissions from each source from units of metric tons of CO 2 e to metric tons of each reported GHG). Mass i = Annual total mass GHG emissions in metric tons CO 2 e per year from all natural
gas p ump venting, for GHG i
. (Eq. W

- 2) E s,i = Annual total volumetric GHG emissions at standard conditions in standard cubic feet per year from all natural gas driven pneumatic pump venting for GHG i
. §98.233(a) and (c); Terms “ T t ” in Equation W

- 1 and

“ T ” in Equation W

- 2 T t = Average estimated number of hours in the operating year the devices

, of each type t, were operational. Default is 8760 hours

. T t = Average estimated number of hours in the operating year the devices

, of each type “ t ,” were operational using engineering estimates based on best available data. Default is 8760 hours

. Clarifying edit

T = Average estimated number of hours in the operating year the pumps were operational. Default is 8760 hours. T = Average estimated number of hours in the operating year the pumps were operational using engineering estimates based on best available data. Defa ult is 8760 hours

.



### 3

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change §98.233 (a) and (c); Term “ EF t ” in Equation W

- 1 and

“ EF ” in Equation W

- 2 EF t = Population emission factors for natural gas pneumatic device ventin g listed in Tables... EF t = Population emission factors for natural gas pneumatic device vents (in standard cubic feet per hour per device) of e ach type “ t ” listed in Tables... Clarifying edit

EF = Population emission s factors for natural gas pneumatic pump venting listed in Tables

... EF = Population emissions factors for natural gas driven pneumatic pumps (in standard cubic feet per hour per pump) listed in Table... §98. 233(c); Term

“ Count ” in Equation W

- 2 Count = Total number of natural gas pneumatic pumps Count = Total number of natural gas driven pneumatic
pumps. Clarifying edit

§98. 233(a)(4) and (c)(2) None Calculate both CH 4 and CO 2 mass emissions from volumetric emissions using calculations in paragraph (v) of this section. Added (a)(4) and (c)(2) to convert volumetric to mass emissions.

§98. 233(d)(2)
Term “ Vol CO2 ” in Equation W

- 3 Vol CO2 = Volume fraction of CO 2 content in vent gas out of the AGR unit as determined in (d)(6) of this section. Vol CO2 = Annual average volumetric fraction of CO 2 content in vent gas flowing out of the AGR unit as determined in paragraph (d)(6) of this section. Clarified that the term should be an annual
average

§98. 233(d)(3)
Term “ Vol I ” in Equations W

- 4A and W

- 4B Vol I = Volume fraction of CO 2 content in natural gas into the AGR unit... Vol I = Annual average volumetric fraction of CO 2 content in natural gas flowing into the AGR unit... Clarified that the term should be an annual
average

§98. 233(d)(3); Term “ Vol o ” in Equations W

- 4A and W

- 4B Vol o = V olume fraction of CO 2 content in natural gas out of the AGR unit... Vol o = Annual average volumetric fraction of CO 2 content in natural gas flowing out of the AGR unit... Clarified that the term should be an annual
average

§98. 233(d)(4) AspenTech HYSYS ® , and API 4679 AMINECalc AspenTech HYSYS ® , or API 4679 AMINECalc Clarifying edit

§98. 233(d)(5) Record the gas flow rate of the inlet and outlet natural gas stream of an AGR unit... For Calculation Method 3, determine the gas flow rate of the inlet when using Equation W

- 4A of this section or the gas flow rate of the outlet when using Equation W

- 4B of this section for the natural gas stream of an AGR unit... Clarified instructions so that they refer to specific equations a nd calculation methods



### 4

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change §98. 233(d)(6) I f continuous gas analyzer is not available on the vent stack, either install a continuous gas analyzer or take quarterly gas samples from the vent gas stream to determine Vol CO2 acc ording to methods set forth in §98. 234(b). For Calculation Method 2, if a continuous gas analyzer is not available on the vent stack, either install a continuous gas analyzer or take quarterly gas samples from the vent gas
stream for each quarter that the AGR unit is operating to determine Vol CO2 in Equation W

- 3 of this section according
to the methods set forth in §98.234(b). §98. 233(d)(7) If a continuous gas analyzer is installed on the inlet gas stream, then the continuous gas analyzer results must be used. If continuous gas analyzer is not available, either install a continuous gas analyzer or take quarterly gas samples from the inlet gas stream to determine Vol I according to methods set forth in §98.234(b). For Calculation Method 3, if a continuous gas analyzer is installed on the inlet gas stream, then the continuous gas analyzer results must be used. If a continuous gas analyzer is not available, either install a continuous gas analyzer or take quarterly ga s samples from the inlet gas stream for each quarter that the AGR unit is operating to determine Vol I in Equation W

- 4A or W

- 4B of this section

, according to the methods set forth in §98.234(b). §98. 233(d)(8) Determine volume fraction of CO 2 content in na tural gas out of the AGR unit using one of the methods specified in
pa ragraph (d)(8) of this section. For Calculation Method 3, determine annual average volumetric fraction of CO 2 content in natural gas flowing out of the AGR unit using one of the methods specified in paragraph s (d)(8) (i) through (d)(8)(iii) of this section. §98. 233(d)(8)(ii) (ii) If a continuous gas analyzer is not available or installed, quarterly gas samples may be taken from the outlet gas stream to determine Vol O according to methods set forth in §98.234(b). (ii) If a continuous gas analyzer is not available or installed, quarterly gas samples may be taken from the outlet gas stream for each quarter that the AGR unit is operating to determine Vol O in Equation W

4A or W

- 4B of this section

, according to the methods set forth in §98.234(b). Clarifying edits



### 5

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change §98. 233(d)(8)(iii) Use sales line quality specification for CO 2 in natural gas. If a continuous gas analyzer is not available or installed, you may use sales line quality specification for CO 2 in natural
gas. Clarifying edit

§98. 233(d)(9) Calculate CO 2 volumetric emissions at standard conditions using calculations in paragraph (t) of this section. Calculate annual volumetric CO 2 emissions at standard condit ions using calculations in paragraph (t) of this section. Clarified that the result is annual emissions.

§98. 233(d)(10) Mass CO 2 emissions shall be calculated from volumetric CO 2 emissions using calculations in paragraph (v) of this section. Calculate annual mass CO 2 emissions using calculations in paragraph (v) of this section. Clarified that the result is annual emissions.

§98. 233(d)(11) Determine if emissions from the AGR unit are recovered and transferred outside the facility. Adjust the emission estimated in paragraphs (d)(1) through (d)(10) of this section downward by the magnitude of emission recovered and transferred outside the facility. Determine if CO 2 emissions from the AGR unit are recovered and transferred outside the facility. Adjust t he CO 2 emissions estimated in paragraphs (d)(1) through (d)(10) of this section downward by the magnitude of CO 2 emissions recovered and transferred outside the facility. Clarifying edit



### 6

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change §98. 233(e)(1) (1) Calculation Methodology 1. Calculate annual mass emissions from dehydrator vents with annual average daily throughput greater than or equal to 0.4 million standard cubic feet per day using a software program, such as AspenTech HYSYS® or GRI

- GLYCalc, that uses the Peng

- Robinson equation of state to calcul ate the equilibrium coefficient, speciates CH 4 and CO 2 emissions from dehydrators, and has provisions to include regenerator control devices, a separator flash tank, stripping gas and a gas injection pump or gas assist pump. A minimum of the following
para meters determined by engineering estimate based on best available data must be used to characterize emissions from dehydrators: (1) Calculation Method 1. Calculate annual mass emissions from glycol dehydrators that have an annual average of daily natural gas throughput that is greater than or equal to 0.4 million standard cubic feet per day by using a software program, such as AspenTech HYSYS® or GRI

- GLYCalc TM , that uses the Peng

- Robinson equation of
state to ca lculate the equilibrium coefficient, speciates CH 4 and CO 2 emissions from dehydrators, and has provisions to include regenerator control devices, a separator flash tank, stripping gas and a gas injection pump or gas assist pump. The following parameters mu st be determined by engineering estimate based on best available data and must be used at a minimum to characterize emissions from dehydrators: Clarifying edits

§98. 233(e)(1)(iv) (iv) Absorbent circulation pump type (natural gas pneumatic/air pneumatic/el ectric). (iv) Absorbent circulation pump type (e.g., natural gas pneumatic/air pneumatic/electric). Clarifying edit

§98. 233(e)(1)(vi) (vi) Absorbent type: including triethylene glycol (TEG), diethylene glycol (DEG) or ethylene glycol (EG). (vi) Absorbent type (e.g., triethylene glycol (TEG), diethylene glycol (DEG) or ethylene glycol (EG)). Clarifying edit



### 7

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change §98.233(e)(1)(xi), (e)(1)(xi)(A), and (e)(1)(xi)(B) xi) Wet natural gas composition. Determine this parameter by selecting one of the methods described under
paragr aph (e)(1)(xi) of this section. (xi) Wet natural gas composition. Determine this parameter using one of the methods described in paragraphs (e)(1)(xi)(A) through (e)(1)(xi)(D) of this section. Harmonizing edit

(A) Use the wet natural gas composition as defined in paragraph (u)(2)(i) or (u)(2)(ii) of this section. (A) Use the GHG mole fraction as defined in paragraph (u)(2)(i) or (u)(2)(ii) of this section. (B) If wet natural gas composition cannot be determined using paragraph (u)(2)(i) or (u)(2)(ii) of this section, sele ct a representative analysis. (B) If the GHG mole fraction cannot be determined using paragraph (u)(2)(i) or (u)(2)(ii) of this section, sele ct a representative analysis.

§98. 233(e)(2) (2) Calculation Methodology 2. Calculate annual CH 4 and CO2 emissions from glycol dehydrators with annual average daily throughput less than 0.4 million standard cubic feet per day using Equation W

- 5 of this section: (2) Calculation Method 2. Calculate annual volumetric emissions from g lycol dehydrators that have an annual average of daily natural gas throughput that is less than 0.4 million standard cubic feet per day using Equation W

- 5 of this section: Clarifies that result is annual volumetric emissions.

Term “ Count ” in Equation W

- 5 Count = Total number of glycol dehydrators with throughput less than 0.4 million standard cubic feet per day. Count = Total number of glycol dehydrators that have an annual average of daily natural gas throughput that is less than 0.4 million standard cubi c feet per day. Clarifying edits

Term “ P ” in Equation W

- 6 P π Corrects typo (to Greek letter ). §98. 233(f) (f) Well venting for liquids unloadings. Calculate CO 2 and CH 4 emissions from well venting for liquids unloading using one of the calculation methodologies described in paragraphs (f)(1), (f)(2) or (f)(3) of this section. (f) Well venting for liquids unloadings. Calculate annual volumetric natural gas emissions from well venting for liquids unloading using one of the calculation methods described in paragraphs (f)(1), (f)(2), or (f)(3) of this section. Calculate annual CH 4 and CO 2 volumetric and mass emissions using the method described in paragraph (f)(4) of this sec tion. Clarifies that results of (f)(1), (f)(2), and (f)(3) are annual volumetric natural gas emissions and provides (f)(4) for calculation of annual CH 4 and CO 2 volumetric and mass emissions.



### 8

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change §98. 233(f)(1)(i) (i) Determine the well vent average flow rate as specified under paragraph (f)(1)(i) of this section for at least one well in a unique well tubing diameter group and pressure group combination in each sub

- basin category. (i) Determine the well vent average flow rate ( “ FR ” in Equation W

- 7A of this sec tion) as specified in paragraphs (f)(1)(i)(A) through (f)(1)(i)(C) of this section for at least one well in a unique well tubing diameter group and pressure group combination in each sub

- basin category. Calculate emissions from wells with plunger lifts and wells without plunger lifts separately. Clarifies instructions so that they refer to specific equation terms and calculation methods

§98. 233(f)(1)(i)(A) (A) The average flow rate per hour of venting is calculated for each unique tubing diameter group and pressure group combination in each sub

- basin category by dividing the recorded total flow by the recorded time (in hours) for all measured liquid unloading events with venting to the atmosphere. (A) Calculate the average flow rate per hour of venting for each unique tubing diameter group and pressure group combination in each sub

- basin category by dividing the recorded total annual flow by the recorded time (in hours) for all measured liquid unloading events with venting to the atmosphere. Clarifies that recorded total flow is total annual flow.

§98. 233(f)(1)(i)(B) (B) This average flow rate per hour is applied to all wells in the same pressure group that have the same tubing diameter group, for the number of hours of venting these wells. (B) Apply the av erage hourly flow rate calculated under paragraph (f)(1)(i)(A) of this section to all wells in the same pressure group that have the same tubing diameter group, for the number of hours of venting these wells. Clarifying edits

§98. 233(f)(1)(i)(C) (C) A new average flow rate is calculated every other calendar year for each reporting sub

- basin category starting the first calendar year of data collection. For a new producing sub

- basin category, an average flow rate is calculated beginning in the first year of production. (C) Calculate a new average flow rate every other calendar year starting with the first calendar year of data collection. For a new producing sub

- basin category, calculate an average flow rate beginning i n the first year of production. Harmonizing edit with changes to term “ FR ” in Equation W

- 7.

§98. 233(f)(2) and (f)(3); Term “ E s ,n ” of Equations W

- 8 and W

- 9 E s ,n = Annual natural gas emissions at standard conditions, in cubic feet/year. E s = Annual natural gas emissions for each sub

- basin at standard conditions, s, in cubic feet per year. Clarifying edits



### 9

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change §98. 233(f)(2) and (f)(3); Terms “ p ” and “ q ” of Equations W

- 8 and W

- 9 None p = Wells 1 through W with well venting for liquids unloading for each sub

- basin.

... q = Unloading event. Clarifi es terms not previously defined

§98. 233(f)(2) and (f)(3); Term “ V p ” of Equations W

- 8 and W

- 9 V p = Number of unloading events per year per well, p. V p = Total number of unloading events in the monitoring period per well, p. Corrects equation term
to reflect the number of unloading events in each monitoring period. §98. 233(f)(2) and (f)(3); Term “ SFR p ” of Equations W

- 8 and W

- 9 SFR p = Average flow

- line rate of gas for well, p, at standard conditions in cubic feet per hour. Use Equation W

- 33 to calculat e the average flow

- line rate at standard conditions. SFR p = Average flow

- line rate of gas for well, p, at standard conditions in cubic feet per hour. Use Equation W

- 33 of this section to calculate the average flow

- line rate at standard conditions. Clarifyi ng edit

§98. 233(f)(3)(i) and (ii) Reserved None Removes reserved paragraphs §98. 233(f)(4) (4) Both CH 4 and CO 2 volumetric and mass emissions shall be calculated from volumetric natural gas emissions using calculations in paragraphs (u) and (v) of this section. (4) Calculate CH 4 and CO 2 volumetric and mass emissions from volumetric natural gas emissions using calcu lations in paragraphs (u) and (v) of this section. Applies active voice

§98. 233(g) introductory paragraph; §98. 233(g)(3) (g) Gas well venting during completions and workovers from hydraulic fracturing

. Calculate CH 4 , CO 2 and N 2 O annual emissions from gas well venting during completions involving hydraulic fracturing in wells and well workovers using Equation W

- 10A or Equation W

- 10B of this section. Equation W

- 10A applies to well venting when the backflow rate is measured or calculated, Equation W

- 10B appli es when the backflow vent or flare volume is measured. Use Equation W

10A if the flow rate for backflow during well completions and workovers from hydraulic fracturing is known for the specified (g) Gas well venting during completions and workovers with hydraulic fracturing

. Calculate annual v olumetric natural gas emissions from gas well venting during completions and workovers involving hydraulic fracturing using Equation W

- 10A or Equation W

- 10B of this section. Equation W

- 10A applies to well venting when the flowback rate is measured from a s pecified number of example completions or workovers and Equation W

10B applies when the flowback vent or flare volume is measured for each completion or workover. Completion and workover activities are separated into two periods, an initial period when flo wback is Clarifies instructions; clarifies that results of (g)(1) and (g)(2) are annual volumetric natural gas emissions and clarifies (g)(3) for calculation of annual CH 4 and CO 2 volumetric and mass emissions.



### 10

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change number of wells per paragraph (g)(1) in a sub

basin and well type (horizontal or vertical) combination. Use Equation W

- 10B if the flow volume for backflow during well completions and workovers from hydraulic fracturing is known for all wells in a sub

basin and well type (horizontal or vertical) combination. Both CH 4 and CO 2 volumetric and mass emissions shall be calculated from volumetric total gas emissions using calculations in paragraphs (u) and (v) of this section. routed to open pits or tanks and a subsequent period when gas content is sufficient to route the flowback to a separator or when the gas content is sufficient to allow measurement by the devices specified in paragraph (g)(1) of this section, regar dless of whether a separator is actually utilized. If you elect to use Equation W

- 10A of this section, you must follow the procedures specified in paragraph (g)(1) of this section. Emissions must be calculated separately for completions and workovers, for each sub

- basin, and for each well type combination identified in paragraph (g)(2) of this section. You must calculate CH 4 and CO 2 volumetric and mass emissions as specified in paragraph (g)(3) of this section. If emissions from gas well venting during
comp letions and workovers with hydraulic fracturing are routed to a flare, you must calculate CH 4 , CO 2 , and N 2 O annual emissions as specified in paragraph (g)(4) of this section.

Term “ E s,n ” in Equations W

- 10A and W

- 10B E s,n = Annual volumetric total gas emissions in cubic feet at standard conditions from gas well venting during completions or workovers following hydraulic fracturing for each sub

- basin and well type (horizontal vs. vertical) combination. E s,n = Annual volumetric natural gas emissions in standard cubic feet from gas well venting during completions or workovers following hydraulic fracturing for each sub

- basin and well type combination. Clarifying edits

Term “ W ” in equations W

- 10A and W

- 10B W = Total number of wells completed or worked over using hydraulic fracturing in a sub

- basin and well type (horizontal vs. vertical) combination. W = Total number of wells completed or worked over using hydraulic fracturing in a sub

- basin and well type combination. Clarifying edits



### 11

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change

Term “ FRM s ” of Equation W

- 10A FRM s = Ratio of flowback during well completions and workovers from hydraulic fracturing to 30

- day production rate from Equation W

- 12. FRM s = Ratio of average flowback, during the period when sufficient quantities of
g as are present to enable separation, of well completions and workovers from hydraulic fracturing to 30

- day production
rate for the sub

- basin and well type combination, calculated using procedures specified in paragraph (g)(1)(iii) of this section, expresse d in standard cubic feet per hour. Harmonizing edits with changes to Equation W

- 10A

Term “ EnF s,p ” in equations W

- 10A and W

- 10B EnF s,p = Volume of CO 2 or N 2 injected gas in cubic feet at standard conditions that was injected into the reservoir during an energized fracture job for each well p. If the fracture process did not inject gas into the reservoir, then EnF s,p is 0. If injected gas is CO 2 then EnF s,p is 0. EnF s,p = Volume of N 2 injected gas in cubic feet at standard conditions that was injected into the reservoir during an energized fracture job for each well, p, as determined by using an appropriate meter according to methods described in §98. 234(b), or by using receipts of gas purchases that are used for the energized fracture job. Convert to standard conditions using paragraph (t) of this section. If the fracture process did not inject gas into the reservoir or if the injected gas is CO 2 then EnF s,p is 0. Clarifies acceptable measurement methods



### 12

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change §98. 233(g)(1)(i) Calculation Methodology 1

. When using Equation W

10A, for each measured well completion(s) in each gas producing sub

- basin category and well type (horizontal or vertical) combination and for

ea ch measured well workover(s) in each gas producing sub

- basin category and well type (horizontal or vertical) combination, a recording flow meter (digital or analog) shall be installed on the vent line, ahead of a flare or vent if used, to measure the backf low rate

acc ording to methods set forth in §98. 234(b). Calculation Method 1

. You must use Equation W

- 12A as specified in paragraph (g)(1)(iii) of this section to determine the value of FRM s . You must use Equation W

- 12B as specified in paragraph (g)(1)(iv) of this section to determine the value of FRM i
. The procedures specified in paragraphs (g)(1)(v) and (g)(1)(vi) also apply. When making flowback measurements for use in Equations W

- 12A and W

- 12B of this section, you must use a recording flow meter (digital or analog) installed on the vent line, ahead of a flare or vent, to measure the flowback rates in units of standard cubic feet per hour according to methods set forth in §98.234(b). Harmonizing changes with edits to Equation W

- 10A

§98. 233(g)(1)(ii) (ii) Calculation Methodology 2

. When using Equation W

10A, for each calculated horizontal well completion and each calculated vertical well completion in each gas producing sub

- basin category and for each calculated well horizontal workover and for each calcula ted vertical well workover in each gas producing sub

- basin category, record the well flowing pressure upstream (and downstream in subsonic flow) of a well choke according to methods set forth in §98.234(b) to calculate the well backflow during well complet ions and workovers from hydraulic fracturing. Calculate emissions using Equation W

- 11A of this section for subsonic flow or Equation W

- 11B of this section for sonic flow. Use best engineering estimate based on best available data (ii) Calculation Method 2

. You must use Equation W

- 12A as
sp ecified in paragraph (g)(1)(iii) of this section to determine the value of FRM s . You must use Equation W

- 12B as specified in paragraph (g)(1)(iv) of this section to determine the value of FRM i
. The procedures specified in paragraphs (g)(1)(v) and (g)(1)(vi ) also apply. When calculating the flowback rates for use in Equations W

- 12A and W

- 12B of this section based on well parameters, you must record the well flowing pressure immediately upstream (and immediately downstream in subsonic flow) of a well choke ac cording to methods set forth in §98.234(b) to calculate the well flowback. The upstream pressure must be surface pressure and reservoir pressure cannot be assumed. The downstream pressure must be measured after the choke Harmonizing changes with edits to Equation W

- 10 A



### 13

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change along with Equation W

- 11C of this section to determine whether the predominant flow is sonic or subsonic. If the value of R in Equation W

11C is greater than or equal to 2, then flow is sonic; otherwise, flow is subsonic. and atmospheric pressure cannot be assumed. Calculate flowback rate using Equation W

- 11A of this section for subsonic flow or Equation W

11B of this section for sonic flow. You must use best engineering estimates based on best available data along with Equation W

- 11C of this section to dete rmine whether the predominant flow is sonic or subsonic. If the value of R in Equation W

- 11C of this section is greater than or equal to 2, then flow is sonic ; otherwise, flow is subsonic. C onvert c alculated FR a values from actual conditions upstream of th e restriction orifice to standard conditions (FR s,p and FR i,p ) for use in Equations W

- 12A and W

- 12B of this section using Equation W

- 33 in paragraph (t) of this section.

Term “ FR a ” of Equation s W

- 11A and W

- 11B FR a = Average flow rate in cubic feet per hour, under actual subsonic flow conditions. FR a = Flowback rate in actual cubic feet per hour, under actual subsonic flow conditions. Harmonizing edits with chan ges to Equation s W

- 12 A and W

- 12 B

Terms “ P 1 ,” “ T u ,” and “ P 2 ” of Equation W

- 11A P 1 = Upstream pressure (psia). P 1 = Pressure immediately upstream of the choke (psia). Clarifying edits

T u = Upstrea m temperature (degrees Kelvin). T u = Temperature immediately upstream of the choke (degrees Kelvin).

P 2 = Downstream pressure (psia). P 2 = Pressure immediately downstream of the choke (psia).

Term “ T u ” of Equation W

- 11B T u = Upstream temperature (degrees Kelvin). T u = Temperature immediately upstream of the choke (degrees Kelvin). Clarifying edits

Terms “ P 1 ” and

“ P 2 ” of Equation W

- 11C P 1 = Pressure upstream of the restriction orifice in pounds per square inch absolute. P 1 = Pressure immediately upstream of the choke (psia). Clarifying edits

P 2 = Pressure downstream of the restriction orifice in pounds per square inch absolute. P 2 = Pressure immediately downstream of the choke (psia).



### 14

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change §98. 233(g)(1)(iii) For Equation W

- 10A, the ratio of backflow rate during well completions and workovers from hydraulic fracturing to 30

- day production rate is calculated using Equation W

- 12 of this section. For Equation W

- 10A of this section, calculate FRM s using Equation W

- 12A of this section. Harmonizing edits with change s to Equation W

- 10A

Terms “ FRM s ” and

“ FR s,p ” of Equation W

- 12A FRM s = Ratio of flowback rate during well completions and workovers from hydraulic fracturing to 30

- day production rate. FRM s = Ratio of average flowback rate

, during the period of time when sufficient quantities of gas are present to enable separation

, of well completions and workovers from hydraulic fracturing to 30

- day production rate for each sub

- basin and well type combination

. Harmonizing edits with changes to Equation W

- 10A

FR s,p = Measured flowback rate from Calculation Methodology 1 described in paragraph (g)(1)(i) of this section or calculated flow rate from Calculation Methodology 2 described in paragraph (g)(1)(ii) of this section in standard cubic feet per hour for well(s) p for each sub

- basin and well type (horizontal or vertical) combination. Measured and calculated FR a values shall be converted from actual conditions (FR a ) to standard conditions (FR s,p ) for each well p using Equation W

- 33 in paragraph (t) of this section. You may not use flow volume as used in Equation W

- 10B converted to a flow rate for this parameter. FR s,p = Measured average flowback rate from Calculation Method 1 described in paragraph (g)(1)(i) of this section or calculated average flowback rate from Calculation Method 2 d escribed in paragraph (g)(1)(ii) of this section, during the separation period in standard cubic feet per hour for well(s) p for each sub

- basin and well type combination. Convert

m easured and calculated FR a values from actual conditions upstream of the res triction orifice (FR a ) to standard conditions (FR s,p ) for each well p using Equation W

- 33 in paragraph (t) of this section. You may not use flow volume as used in Equation W

- 10B converted to a flow rate for this parameter.



### 15

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change §98. 233(g)(1)(iv) None For Equation W

- 10A of this section, calculate FRM i using Equation W

- 12B of this section.

, 1

, 1 N

i p
p i N

s p p FR
FRM
PR =

= = 

# ∑

∑ (Eq. W

- 12B)

Where:
FRM i = Ratio of flowback gas rate while flowing to open tanks/pits during well completions and workovers from hydraulic fracturing to 30

- day production rate.
FR i,p = Initial measured gas flowback rate from Calculation Method 1 described in paragraph (g)(1)(i) of this section or initial calculated flow rate from Calculation Method 2 described in paragraph (g) (1)(ii) of this section in standard cubic feet per hour for well(s), p, for each sub

- basin and well type combination. Measured and calculated FR i,p values must be based on flow conditions at the beginning of the separation period and must be expressed at

s tandard conditions.
PR s,p = Average production flow rate during the first 30

- days of production after completions of newly drilled gas wells or gas well workovers using hydraulic fracturing, in standard cubic feet per hour of each well, p, that

was measure d in the sub

- basin and well type combination. N = Number of measured or calculated well completions or workovers using hydraulic fracturing in a sub

- basin and well type combination. Harmonizing edits with changes to Equation W

- 10A



### 16

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change §98.233(g)(1)(v) and (vi) (iv) For Equation W

- 10A, the ratio of backflow rate during well completions and workovers from hydraulic fracturing to 30

- day production rate for horizontal and vertical wells are applied to all horizontal and vertical well completions in the gas prod ucing sub

- basin and well type combination and to all horizontal and vertical well workovers, respectively, in the gas producing sub

- basin and well type combination for the total number of hours of backflow for each of these wells. (v) For Equation W

- 10A of this section, the ratio of flowback rate during well completions and workovers from hydraulic fracturing to 30

- day production rate for horizontal and vertical wells are applied to all horizontal and vertical well completions in the gas producing sub

- basin and well type combination and to all horizontal and vertical well workovers, respectively, in the gas producing sub

- basin and well type combination for the total number of hours of flowback and for the first 30 day average production rate for each of thes e wells. Renumbered and revised to harmoni ze with edits to Equation W

- 10A

(v) For Equation W

- 10A, new flow rates for horizontal and vertical gas well completions and horizontal and vertical gas well workovers in each sub

- basin category shall be calculated once every two years starting in the first calendar year of data collection. (vi) For Equation W

- 12A and W

- 12B of this section, calculate new flowback rates for horizontal and vertical gas well completions an d horizontal and vertical gas well workovers in each sub

- basin category once every two years starting in the first calendar year of data collection.



### 17

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change §98.233(g)(4) (5) Calculate annual emissions from gas well venting during well completions and workovers from hydraulic fracturing to flares as follows: (4) Calculate annual emissions from gas well venting during well completions and workovers from hydraulic fracturing where all or a portion of the gas is flared as specified in paragraphs (g)(4)(i) and (g)(4 )(ii) of this section. Renumbered; clarifies calculation method where a portion of the gas is flared

(i) Use total gas well venting volume during well completions and workovers as determined in paragraph (g) of this section. (i) Use the volumetric total natural gas emissions vented to the atmosphere during well completions and workovers as determined in paragraph (g) of this section to calculate volumetric and mass emissions using paragraphs (u) and (v) of this section. (ii) Use the calculation methodology of flare stacks in paragraph (n) of this section to determine gas well venting during well completions and workovers using hydraulic fracturing emissions from the flare. This adjustment to emissions from completions usi ng flaring versus completions without flaring accounts for the conversion of CH 4 to CO 2 in the flare. (ii) Use the calculation method of flare stacks in paragraph (n) of this section to adjust emissions for the portion of gas flared during well completions and workovers using hydraulic fracturing. This adjustment to emissions from completions using flaring, versus completions without flaring, accounts for the conversion of CH 4 to CO 2 in the flare and for the formation on N 2 O during flaring.



### 18

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change §98. 233(h) introductory paragraph Calculate CH 4 , CO 2 and N 2 O emissions from each gas well venting during well completions and workovers and not involving hydraulic fracturing using Equation W

13 of this section. Calculate annual volumetric natural gas emissions from each gas well venting during workovers without hydraulic fracturing using Equation W

13A of this section. Calculate annual volumetric natural gas emissions from each gas well venting during completions without hydraulic fracturing using Equation W

- 13B of this section. You must convert annual volumetric natural gas emissions to CH 4 and CO 2 volumetric and mass emissions as specified in paragraph (h)(1) of this section. If emissions from gas well venting during completions and workovers without hydraulic fracturing are routed to a flare, you must calculate CH 4 , CO 2 , and N 2 O annual emissions as specified in paragraph (h)(2) of this section. Edits clarify instructions; clarifies that results of Equations W

- 13A and W

- 13B are annual

v olumetr ic natural gas emissions

Term “ Tp ” of Equation W

- 13 T p = Time each well completion without hydraulic fracturing, p, was venting in hours during the year. T p = Time that gas is vented to either the atmosphere or a flare for each well, p, undergoing completion without hydraulic fracturing, in hours during the
year. Clarifying edits

§98.233(h)(1) (1) Volumetric emissions for both CH 4 and CO 2 shall be calculated from volumetric natural gas emissions using calculations in paragraph (u) of this section. Mass emissions for both CH 4 and CO 2 shall be calculated from volumetric natural gas emissions using calculations in paragraphs (v) of this section. (1) Calculate bo th CH 4 and CO 2 volumetric emissions from natural gas volumetric emissions using calculations in paragraph (u) of this section. Calculate both CH 4 and CO 2 mass emissions from volumetric emissions vented to the atmosphere using calculations in paragraph (v) of this section. C larifies calculation of annual CH 4 and CO 2 volumetric and mass emissions



### 19

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change §98.233(h)(2) (2) Calculate annual emissions from gas well venting during well completions and workovers not involving hydraulic fracturing to flares as follows: (2) Calculate annual emissions of CH 4 , CO 2 , and N 2 O from gas well venting to flares during well completions and workovers not involving hydraulic fracturing as specified in paragraphs (h)(2)(i) and (h)(2)(ii) of this section. Clarifying edits

(i) Use the gas well venting volume during well completions and workovers as determined in paragraph (h) of this section. (i) Use the gas well venting volume and gas composition during well completions and workovers that are flared as determined using the methods
spe cified in paragraphs (h) and (h)(1) of this section. (ii) Use the calculation methodology of flare stacks in paragraph (n) of this section to determine gas well venting during well completions and workovers emissions without hydraulic fracturing from the flare. (ii) Use the calculation method of flare stacks in paragraph (n) of this section to determine emissions from the flare for gas well venting to a flare during completions and workovers without hydrauli c fracturing.



### 20

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change §98. 233(i) Blowdown vent stacks

. Calculate CO 2 and CH 4 blowdown vent stack emissions from depressurizing equipment(s) to reduce system pressure for planned or emergency shutdowns resulting from human intervention or to take equipment out of service for maintenance (excluding depressurizing to a flare,

over

- pr essure relief, operating pressure control venting and blowdown of non

- GHG gases; desiccant dehydrator blowdown venting before reloading is covered in paragraph (e)(5) of this section) as follows: Blowdown vent stacks

. Calculate CO 2 and CH 4 blowdown vent st ack emissions from the depressurization of equipment to reduce system pressure for planned or emergency shutdowns resulting from human intervention or to take equipment out of service for maintenance as specified in either paragraph (i)(2) or (i)(3) of thi s section. You may use the method in paragraph (i)(2) of this section for some blowdown vent stacks at your facility and the method in paragraph (i)(3) of this section for other blowdown vent stacks at your facility. Equipment with a unique physical volume of less than 50 cubic feet as determined in paragraph (i)(1) of this section are not subject to the requirements in paragraphs (i)(2) through (i)(4) this section. The requirements in this paragraph (i) do not apply to blowdown vent stack emissions from de pressurizing to a flare, over

- pressure relief, operating pressure control venting, blowdown of non

GHG gases, and desiccant dehydrator blowdown venting before reloading. Clarifies that some blowdown emissions may be calculated using the unique physical vol umes and equipment or event type method, while other blowdown emissions may be determined by using a flow meter. Also clarifies that requirements in this section do not apply to equipment with a physical vo lume of less than 50 cubic feet

§98. 233(i)(1) (1) Calculate the unique physical volume (including pipelines, compressor case or cylinders, manifolds, suction bottles, discharge bottles, and vessels) between isolation valves determined by engineering estimates based on best available data. (1) Method for calculating unique physical volumes . You must calculate each unique physical volume (including pipelines, compressor case or cylinders, manifolds, suction bottles, discharge bottles, and vessels) between isolation valves, in cubic feet, by using engineerin g estimates based on best available data. Clarifies measurement units



### 21

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change
N/A (i) (2) If the unique physical volume between isolation valves is greater than or equal to 50 cubic feet, retain logs of the number of blowdowns for each unique physical volume (including but not limited to compressors, vessels, pipelines, headers, fractionators, and tanks). Unique physical volumes smaller than 50 cubic feet are exempt from reporting under paragraph (i) of this section. None Harmonizing change with edits to Equat ions W

- 14A and W

- 14B

§98. 233(i)(4) (4) Calculate both CH 4 and CO 2 volumetric and mass emissions using calculations in paragraph (u) and (v) of this section. (4) Method for converting from natural gas emissions to GHG volumetric and mass emissions

. Calculate both CH 4 and CO 2 volumetric and mass emissions using the methods specified in paragraphs (u) and (v) of this section. Clarifying edits

§98. 233(j) (j)

... not owned or operated by the reporter), calculate annual CH 4 and CO 2 emissions using any of t he calculation methodologies described in this paragraph (j). (1) Calculation Methodology 1

. For separators with annual average daily throughput of oil greater than or equal to 10 barrels per day. Calculate... (2) Calculation Methodology 2

. Calculate annual CH 4 and CO 2 emissions from onshore production storage tanks for wellhead gas

- liquid separators with annual average daily throughput of oil greater than or equal to 10 barrels per day by.... (3) Calculation Methodology 3

. For wells with annual average daily oil production greater than or equal to 10 barrels per day that flow directly to atmospheric storage tanks without passing (j)

... not owned or operated by the reporter), as specified in this paragraph (j). For wells flowing to gas

- liquid separators with annual average daily throughput of oil greater than or equal to 10 barrels per day, calculate annual CH 4 and CO 2 using Calculation Method 1 or 2 as specified in paragraphs (j)(1) and (j)(2) of this section. For wells flowing directly to atmospheric storage tanks without passing through a wellhead separator with throughput greater than or equal to 10 barrels per day, calculate annual C H 4 and CO 2 emissions using Calculation Method 2 as specified in paragraph (j)(2) of this section. For wells flowing to gas

- liquid separators or directly to atmospheric storage tanks with throughput less than 10 barrels per day, use Calculation Method 3 as specified in paragraph (j)(3) of this section. If you use Calculation Method Clarifies and consolidates instructions for use of calculation methods by removing and combining text from (j)(1) introductory, (j)(2) introd uctory, (j)(3) introductory, and (j)(4) paragraphs. Clarifies instructions in (j) intro to account for situations where part of the gas is recovered or flared



### 22

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change through a wellhead separator, calculate annual CH 4 and CO 2 emissions by either of the methods in paragraph (j)(3) of this section: ... (4) Calculation Methodology 4

. For wells with annual average daily oil production greater than or equal to 10 barrels per day that flow to a separator not at the well pad, calculate annual CH 4 and CO 2 emissions by either of the methods in paragraph (j)(4) of this section: ... (5) Calculation Methodology 5

. For well pad gas

- liquid separators and for wells flowing off a well pad without passing through a
gas

- liquid separator with annual average daily throughput of oil less than 10 barrels per day use.... 1 or 2, y ou must also calculate emissions that may have occurred due to dump valves not closing properly using the method specified in paragraphs (j)(6) of this section. If emissi ons from atmospheric pressure fixed roof storage tanks are routed to a vapor recovery system, you must adjust the emissions downward according to paragraph (j)(4) of this section. If emissions from atmospheric pressure fixed roof storage tanks are routed t o a flare, you must calculate CH 4 , CO 2 , and N 2 O annual emissions as specified in paragraph (j)(5) of this section.

§98. 233(j)(1)(vii) (vii) Separator oil composition and Reid vapor pressure. If this data is not available, determine these parameters by selecting one of the methods described under paragraph (j)(1) (vii) of this section. (vii) Separator oil composition and Reid vapor pressure. If this data is not available, determine these parameters by using one

o f the methods described in paragraphs (j)(1)(vii)(A) through (j)(1)(vii)(C) of this section. Corrects reference

§98. 233(j)( 7 ) (9) ...emissions from volumetric natural gas emissions... (7) ...emissions from natural gas volumetric emissions... Grammatical correction and renumbered section

Term “ E n ” in Equation W

- 16 Storage tank emissions as determined in Calculation Methods 1, 2, or 3 in paragraphs (j)(1), (j)(2) and (j)(3) of this section (with wellhead separators) in standard cubic feet per year. Storage tank emissions as determined in paragraphs (j)(1), (j)(2) and, if applicable, (j)(4) of this section in standard cubic feet per year. Clarifying edit s

§98.233(l)(5) (5) ...emissions from volumetric natural gas emissions... (5) ...emissions from natural
gas volumetric emissions... Grammatical correction



### 23

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change §98.233(k), (l), and (m) introductory paragraphs (k)

.... calculate CH 4 , CO 2 and N 2 O annual emissions from compressor scrubber dump valve leakage as follows. (k)

... calculate CH 4 and CO 2 annual emissions from
comp ressor scrubber dump valve leakage as specified in paragraphs (k)(1) through (k)( 4 ) of this section. If emissions from compressor scrubber dump valve leakage are routed to a flare, you must calculate CH 4 , CO 2 , and N 2 O annual emissions as specified in parag raph (k)( 5 ) of this section. Clarifies instructions; clarifies N 2 O to be calculated f rom emissions routed to a flare

(l)

.... Calculate CH 4, CO 2 and N 2 O (when flared) well testing venting and flaring emissions as follows: (l)

.. . Calculate CH 4 and CO 2 annual emissions from well testing venting as specified in paragraphs (l)(1) through (l)(5) of this section. If emissions from well testing venting are routed to a flare, you must calculate CH 4 , CO 2 , and N 2 O annual emissions as specified in paragraph (l)( 6) of this section. (m)

... Calculate CH 4 , CO 2 and N 2 O (when flared) associated gas venting and flaring emissions not in conjunction with well testing (refer to paragraph (l): Well testing venting and flaring of this section) as follows: (m)

... Calculate CH 4 and CO 2 annual emissions from associated gas venting not in conjunction with well testing (refer to paragraph (l): Well testing venting and flaring of this section) as specified in paragraphs (m)(1) through (m)(4) of this section. If emissio ns from associated gas venting are routed to a flare, you must calculate CH 4 , CO 2 , and N 2 O annual emissions as specified in paragraph (m)(5) of this section.



### 24

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change §98. 233(k)(1) (k)(1) Monitor the tank vapor vent stack annually for emissions using an optical gas imaging instrument according to methods set forth in §98.234(a)(1) or by directly measuring the tank vent using a flow meter or high volume sampler according to methods in §98.234(b) through (d) for a duration of 5 minutes, or a calibrated bag accordin g to methods in §98.234(b). Or you may annually monitor leakage through compressor scrubber dump valve(s) into the tank using an acoustic leak detection device according to methods set forth in §98.234(a)(5). (1) Except as specified in paragraph (k)(1)(iv) of this section, you must monitor the tank vapor vent stack annually for emissions using one of the methods specified in paragraphs (k)(1)(i) through (k)(1)(iii) of this section. (i) Use an optical gas imaging instrument according to methods set forth in §98.234(a)(1). (ii) Measure the tank vent directly using a flow meter or high volume sampler according to methods in §98.234(b) or (d) for a duration of 5 minutes. (iii) Measure the tank vent using a calibrated bag according to methods in §98.234(c) for a duration of 5 minutes or until the bag is full, whichever is shorter. (iv) You may annually monitor leakage through compressor scrubber dump valve(s) into the tank using an acoustic leak detection device according to methods set forth in §98.234(a)(5). Cl arifying edits



### 25

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change §98.233(k)(2) and (k)(2)(i) (2) If the tank vapors from the vent stack are continuous for 5 minutes, or the acoustic leak detection device detects a leak, then use one of the following two methods in paragraph (k)(2) of this section to quantify annual emissions : (2) If the tank vapors from the vent stack are continuous for 5 minutes, or the optical gas imaging instrument or acoustic leak det ection device detects a leak, then you must use one of the methods in either paragraph (k)(2)(i) or (k)(2)(ii) of this section. Clarifying edits; corrects references

(i) Use a meter, such as a turbine meter, calibrated bag, or high flow sampler to estimate tank vapor volumes from the vent stack according to methods set forth in §98.234(b) through (d)....If the vent is directly measured for five minutes under paragraph §98.233(k)(1) of this section to detect continuous leakage, this serves as the measu rement. (i) Use a flow meter, such as a turbine meter, calibrated bag, or high volume sampler to estimate tank vapor volumes from the vent stack according to methods set forth in §98.234(b) through (d)....If the vent is directly measured for five minutes und er paragraph (k)(1)(ii) or (k)(1)(iii) of this section to detect continuous leakage, this serves as the
measurement. §98.233(k)(4) and (k)(4)(i) (2)(iii) Use the appropriate gas composition in paragraph (u)(2)(iii) of this section. (4) Use the requirements specified in paragraphs (k)(4)(i) and (k)(4)(ii) of this section to quantify annual emissions. (i) Use the appropriate gas composition in paragraph (u)(2)(iii) of this section. Renumbered to (k)(4)(i)

§98. 233(k)( 4 )(i i ) (2) (iv) Calculate GHG volumetric and mass emissions at standard conditions.... (4) (i i ) Calculate CH 4 and CO 2 volumetric and mass emissions at standard conditions... Clarifying edits

, r enumbered to (k)(4)(ii)

§98. 233(k)(3) (3) If the leaking dump valve(s) is fixed following leak d etection, the annual emissions shall be calculated from the beginning of the calendar year to the time the valve(s) is repaired

. (3) If a leaking dump valve is identified, the leak must be counted as having occurred since the beginning of the calendar year , or from the previous test that did not detect leaking in the same calendar year. If the leaking dump valve is fixed following leak detection, the leak duration will end upon being repaired. If a leaking dump valve is identified and not repaired, the leak must be counted as having occurred through the rest of the calendar year. Clarifying edits, including what to do if an earlier test showed no leak, and how to determine end of leak duration



### 26

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change §98. 233(k)( 5 ) (4) Calculate annual emissions from storage tanks to flares as follows: ( 5 ) Calculate annual emissions from storage tanks to flares as specified in paragraphs (k)( 5 )(i) and (k)( 5 )(ii) of this section. Corrects reference s and renumbers (k)(4) to (k)(5)

§98.233(l)(2) and §98.233(m)(2) (l)(2) ... according t o one of the two procedures in paragraph (l)(2) of this section to determine GOR: (l)(2) ... according to one of the procedures specified in paragraph (l)(2)(i) or (l)(2)(ii) of this section to determine GOR. Clarifying edits

(m)(2) ...then use one of the two procedures in paragraph (m)(2) of this section to determine GOR: (m)(2) ....then you must use one of the procedures specified in paragraphs (m)(2)(i) or (m)(2)(ii) of this section to determine GOR. §98. 233(l)(2)(ii) and §98. 233(m)(2)(ii) (ii) Or you may use an industry standard pract ice as described in §98.234(b). (ii) You may use an industry standard practice as described in §98.234(b). Applies active voice

§98. 233(l)(3) (3) Estimate venting emissions using Equation W

17A or Equation W

- 17B of this section. (3) Estimate venting emissions using Equation W

- 17A (for oil wells) or Equation W

- 17B (for gas wells) of this section. Clarifying edits

Terms “ FR ” and

“ D ” of Equations W

- 17A and W

- 17B FR = Flow rate in barrels of oil per day for the oil well(s) b eing tested.

... D = Number of days during the year, the well(s) is tested. FR = Average annual flow rate in barrels of oil per day for the oil well(s) being tested.

... D = Number of days during the calendar year that the well(s) is tested. Clarifying edits

§98. 233(l)(5) (5) Calculate both CH 4 and CO 2 volumetric and mass emissions from volumetric natural gas emissions using calculations in paragraphs (u) and (v) of this section. (5) Calculate both CH 4 and CO 2 volumetric and mass emissions from natural gas volumetric emissions using calculations in paragraphs (u) and (v) of this section. Clarifying edit



### 27

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change §98.233(l)(6) and §98.233(m)(5) (l)(6) Calculate emissions from well testing to flares as follows: (l)(6) Calculate emissions from well testing if emissions are routed to a flare as specified in paragraphs (l)(6)(i) and (l)(6)(ii) of this section. Corrects references; §98. 233(m)(6) is renumbered to (m)(5)

(i) Use the well testing emissions volume and gas

com position as determined in paragraphs (l)(1) through (3) of this section. (i) Use the well testing emissions volume and gas composition as determined in paragraphs (l)(1) through (4) of this section. (m)(6) Calculate emissions from associated natural gas to flares as follows: (m)(5) Calculate emissions from associated natural gas if emissions are routed to a flare as specified in paragraphs (m)(5)(i) and (m)(5)(ii) of this section. (i) Use the associated natural gas volume and gas composition as determined in paragraph (m)( 1) through (4) of this section. (i) Use the associated natural gas volume and gas composition as determined in paragraph (m)(1) through (m)(4) of this section. §98. 233(m)(1) (1) ... If GOR from each well is not available, the GOR from a cluster of wells in the same sub

- basin category shall be used. (1) ... If GOR from each well is not available, use the GOR from a cluster of wells in the same sub

- basin category. Applies active voice

Term “ V p,q ” of Equation W

- 18 V p,q = Volume of oil produced, for well p in sub

basin q, in barrels in the calendar year during which associated gas was vented or flared. V p,q = Volume of oil produced, for well p in sub

- basin q, in barrels in the calendar year during time periods in which

a ssociated gas was vented or flared. Clarifying edits

§98. 233(n) (n) Flare stack emissions

. Calculate CO 2 , CH 4 , and N 2 O emissions from a flare stack as follows: (n) Flare stack emissions

. Calculate CO 2 , CH 4 , and N 2 O emissions from a flare stack as specified in paragraphs (n)(1) through (n)(9) of this section. Clarifying edits

§98. 233(n)(1) (1) ...If you do not have a continuous flow measurement device on the flare, you can install a flow measuring device on the flare or use engineering calculations based on process knowledge, company records, and best available data. (1) ...If you do not have a continuous flow measurement device on the flare, you can use engineering calculations based on process knowledge, company records, and best available data. C larifying edit, corrects typo



### 28

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change §98.233(n)(2) (2) ... you must use the appropriate gas compositions for each stream of hydrocarbons going to the flare as follows: (2) ... you must use the appropriate gas compositions for each stream of hydrocarbons going to the flare as specified in paragraphs (n)(2)(i) through (n)(2)(iii) of this section. Clarifying edits

(i) For onshore natural gas production, determine natural gas composition using (u)(2)(i) of this section. (i) For onshore natural gas production, determine the GHG mole fraction using paragraph (u)(2)(i) of this section. (ii) For onshore natural gas processing, when the stream going to flare is natural gas, use the GHG mole percent in feed natural gas for all streams upstream of the de

methanizer or dew point control, and GHG mole percent in facility specific residue gas to transmission pipeline systems for all emissions sources downstream of the de

methanizer overhead or dew point control for onshore natural gas processing facilities. For onshore natural gas processing plants that solely fractionate a liquid stream, use the GHG mole percent in feed natu ral gas liquid for all streams. (ii) For onshore natural gas processing, when the stream going to flare is natural gas, use the GHG mole fraction i n feed natural gas for all streams upstream of the de

- methanizer or dew point control, and GHG mole fraction in facility specific residue gas to transmission pipeline systems for all emissions sources downstream of the de

methanizer overhead or dew point c ontrol for onshore natural gas processing facilities. For onshore natural gas processing plants that solely fractionate a liquid stream, use the GHG mole fraction in feed natural gas liquid for all streams.

§98.233(n)(2)(iii) (iii) For any applicable industry segment, ... (iii) For any industry segment required to report flare stack emissions under §98.232, ... Clarifying edits

Terms “ V s ,”

“ X CH4 ,” “ X CO2 ,” and

“ Y j ” of Equations W

- 19 and W

- 20 V a = Volume of gas sent to flare in cubic feet, during the
year.

... V s = Volume of gas sent to flare in standard cubic feet, during the year as determined in paragraph (n)(1) of this section.

... Specifies requirements for determining each parameter and clarifies that the volume of gas is to be at standard conditions

. X CH4 = Mole fraction of CH 4 in gas to the flare. X CH4 = Mole fraction of CH 4 in the feed gas to the flare as determined in paragraph (n)(2) of this section.



### 29

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change

X CO2 = Mole fraction of CO 2 in gas to the flare.... X CO2 = Mole fraction of CO 2 in the feed gas to the flare as determined in paragraph (n)(2) of this section.

Y

j = Mole fraction of gas hydrocarbon constituents j (such as methane, ethane, propane, butane, and pentanes

- plus). ...Y j = Mole fraction of hydrocarbon constituents j (such as methane, ethane, propane, butane, and pentanes

plus) in the feed gas to the flare as determined in paragraph (n)(1) of this section.

N/A (n)(7) [Reserved] None Removes reserved requirements and renumbers following paragraphs §98. 233(n)( 8 ) (9) If you operate and maintain a CEMS that has both a CO 2 concentration monitor and volumetric flow rate monitor, you must calculate only CO 2 emissions for the flare. ... If a CEMS is used to calculate flare stack emissions, the requirements specified in paragraphs (n)(1) through (n)(7) are not required. If a CO 2 concentration monitor and volumetric flow rate monitor are not available, you may elect to install a CO 2 concentration monitor and a volumetric flow rate monitor that comply with all of the requirements specified for the Tier 4 Calculation Methodology in subpart C of this part (General Stationary Fuel Combustion). (8) If you operate and maintain a CEMS that has both a CO 2 concentration monitor and volu metric flow rate monitor for the combustion gases from the flare, you must calculate only CO 2 emissions for the flare. ...If a CEMS is used to calculate flare stack emissions, the requirements specified in paragraphs (n)(1) through (n)(7) are not required. R enumbers paragraph and removes redundant text

§98. 233(q) Leak detection and leaker emission factors . You must use the methods described in §98.234(a) to conduct leak detection(s) of equipment leaks from all component types listed in §98.232(d)(7), (e)(7), (f)(5), (g)(3), (h)(4), and (i)(1). This paragraph (q) applies to component types in streams with gas content Equipment leak surveys

. You must use the methods described in §98.234(a) to conduct leak detection(s) of equipment leaks from all component types listed in §98.232(d)(7), (e)(7), (f)(5), (g)(3), (h)(4), and (i)(1). This paragraph (q) applies to
comp onent types in streams with gas content greater than Makes terminology consistent with corresponding reporting section ( §98. 236(q)); clarifying edits



### 30

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change greater than 10 percent CH 4 plus CO 2 by weight. Component types in streams with gas content less than 10 percent CH 4 plus CO 2 by weight do not ne ed to be reported. Tubing systems equal to or less than one half inch diameter are exempt from the requirements of this paragraph (q) and do not need to be reported. If equipment leaks are detected for sources listed in this paragraph (q), calculate equipm ent leak emissions per component type per reporting facility using Equations W

- 30A or W

- 30B of this section for each component type. Use Equation W

- 30A for industry segments listed in 98.230(a)(3)

- (a)(7). Use Equation W

- 30B for industry segments in 98.230( a)(8). 10 percent CH 4 plus CO 2 by weight. Component types in streams with gas content less than or equal to 10 percent CH 4 plus CO 2 by weight are exempt from the requirements of this paragraph (q) and do not ne ed to be reported. Tubing systems equal to or less than one half inch diameter are exempt from the requirements of this paragraph (q) and do not need to be reported. Fo r industry segments listed in § 98.230(a)(3) through (a)(8), if equipment leaks are detec ted for component types listed in this paragraph (q), then you must calculate equipment leak emissions per component type per reporting facility using Equation W

- 30 of this section. For the industry segment listed i n § 98.230(a)(8), the results from Equatio n W

- 30 are used to calculate population emission factors on a meter/regulator run basis using Equation W

- 31 of this section. If you chose to conduct equipment leak surveys at all above grade transmission distribution transfer stations over multiple years, “ n, ” according to paragraph (q)(8)(i) of this section, then you must calculate the emissions from all above grade transmission

- distribution transfer stations as specified in paragraph (q)(9) of this section.

Term “ T p,z ” in Equation W

- 30 The total time the surveyed component “ z ,” component type “ p ” was found leaking and operational, in hours. ... The total time the surveyed component “ z ,” component type “ p ,” was assumed to be leaking and operational, in hours. ... Clarifying edit



### 31

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change §98. 233(q)(1) You must select to conduct either one leak detection survey in a calendar year or multiple complete leak detection surveys in a calendar year. The number of leak detection surveys selected must be conducted during the calendar year. You must conduct either one leak detection survey in a calendar year or multiple complete leak detection surveys in a calendar year. The leak detection surveys selected must be conducte d during the calendar year. Grammatical corrections

§98. 233(q)(3) and (q)(4) ... facilities shall use the appropriate default leaker emission factors listed in Table ... of this subpart for equipment leaks detected from valves, connectors, open ended lines, p ressure relief valves, and meters. ... facilities must use the appropriate default total hydrocarbon leaker emission factors for compressor components in gas service and

non

- compressor components in gas service listed in Table ... of this subpart. Clarifying e dits

§98.233(q)(5) and (r)(3) (q)(5) Underground natural gas storage facilities for storage stations shall use the appropriate default leaker emission factors listed in Table W

- 4 of this subpart for equipment leaks detected from valves, connectors, open ended lines, pressure relief valves, and meters. (q)(5) Underground natural gas storage facilities must use the appropriate default total hydrocarbon leaker emission factors for storage stations in gas service listed in Table W

- 4 of this subpart. Clarifyin g edits

(r)(3) Underground natural gas storage facilities for storage wellheads shall use the appropriate default population emission factors listed in Table W

- 4 of this subpart for equipment leak from connectors, valves, pressure relief valves, and
open ended lines. (r)(3) Underground natural gas storage facilities must use the appropriate default total hydrocarbon population emission factors for storage wellheads in gas service listed in Table W

- 4 of this subpart.

§98.233(q)(6) and (r)(4) (q)(6) ... shall use the appropriate default leaker emission factors listed in Table W

- 5 of this subpart for equipment leaks detected from valves, pump seals, connectors, and other. (q)(6) ... must use the appropriate default methane leaker emission factors for LNG sto rage components in gas service listed in Table W

- 5 of this subpart. Clarifying edits



### 32

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change (r)(4) ... shall use the appropriate default population emission factors listed in Table W

- 5 of this subpart for equipment leak from vapor
recovery compressors. (r)(4) ... must use the appropriate default methane population emission factor for LNG storage compressors in gas service listed in Table W

- 5 of this subpart. §98.233(q)(7) and (r)(5) (q)(7) ... shall use the appropriate default leaker emission factors listed in Table W

- 6 of this subpart for equipment leaks detected from valves, pump seals, connectors, and other. (q)(7) ... must use the appropriate default methane leaker emission factors for LNG terminals components i n LNG service listed in Table W

- 6 of this subpart. Clarifying edits

(r)(5) ... shall use the appropriate default population emission factor listed in Table W

- 6 of this subpart for equipment leak from vapor
recovery compressors. (r)(5) ... must use the appropriate default methane population emission factor for LNG terminal compressors in gas service listed in Table W

- 6 of this subpart. §98. 233(q)(8) Natural gas distribution facilities for above grade transmission

- distribution transfer stations, shall use the appropriate default leaker emission factors listed in Table W

- 7 of this subpart for equipment leaks detected from connectors, block valves, control valves, pressure relief valves, orifice meters, regulators, and open ended lines. Leak detection at natural gas distribution facilities is only required at above grade stations that qualify as transmission

distribution transfer stations. Below grade transmission

distribution transfer stations and all metering

- regulating stations that do meet the definition of transmission

distribution transfer sta tions are not required to perform component leak detection under this section. Natural gas distribution facilities must use Equation W

30 of this section and the default methane leaker emission factors for transmission

- distribution transfer station compone nts in gas service listed in Table W

- 7 of this subpart to calculate component emissions from annual equipment leak surveys conducted at above grade transmission

- distribution transfer stations. Natural gas distribution facilities are required to perform equ ipment leak surveys only at above grade stations that qualify as transmission

- distribution transfer stations. Below grade transmission

- distribution transfer stations and all metering

- regulating stations that do not meet the definition of transmission

- distr ibution transfer stations are not required to perform equipment leak surveys under this section. Clarifying edits; grammatical correction



### 33

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change §98. 233(q)(8)(i) Natural gas distribution facilities may choose to conduct leak detection at the T

- D transfer stations over multiple years, not exceeding a five year period to cover all T

- D transfer stations. If the facility chooses to use the multiple year option then the number of T

- D transfer stations that are monitored in each year should be approximately equa l across all years in the cycle without monitoring the same station twice during the multiple year
survey. Natural gas distribution facilities may choose to conduct equipment leak surveys at all above grade transmission

- distribution transfer stations over multiple
years “ n ,” not exceeding a five year period to cover all above grade transmission

- distribution transfer stations. If the facility chooses to use the multiple year option then the number of transmission

- distribution transfer stations that are monit ored in each year should be approximately equal across all years in the cycle. Clarifying edits

§98. 233(r) Population count and emission factors . This paragraph applies to emissions sources listed in §98.232 (c)(21), (f)(5), (g)(3), (h)(4), (i)(2), (i)(3) , (i)(4), (i)(5), and (i)(6) on streams with gas content greater than 10 percent CH 4 plus CO 2 by weight. Emissions sources in streams with gas content less than 10 percent CH 4 plus CO 2 by weight do not need to be reported. Tubing systems equal to or less t han one half inch diameter are exempt from the requirements of paragraph (r) of this section and do not need to be reported. Calculate emissions from all sources listed in this paragraph using Equation W

31 of this section. Equipment leaks by population

co unt

. This paragraph applies to emissions sources listed in §98.232 (c)(21), (f)(5), (g)(3), (h)(4), (i)(2), (i)(3), (i)(4), (i)(5), and (i)(6) on streams with gas content greater than 10 percent CH 4 plus CO 2 by weight. Emissions sources in streams with gas content less than or equal to 10 percent CH 4 plus CO 2 by weight are exempt from the requirements of this paragraph ( r ) and do not need to be reported. Tubing systems equal to or less than one half inch diameter are exempt from the requirements of paragrap h (r) of this section and do not need to be reported. You must calculate emissions from all emission sources listed in this paragraph using Equation W

32A of this section, except for natural gas distribution facili ty emission sources listed in § 98.232 (i)( 3). Natural gas distribution facility emission sources listed in §98.232 (i)(3) must calculate emissions using Equation W

- 32B and according to paragraph (r)(6) (ii) of this section. Makes terminology consistent with corresponding reporting section ( §98. 236 (r)); clarifying edits



### 34

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change §98. 233(r) Equations Eq. W

- 31 Eq. W

- 32A and Eq. W

- 32B Renumbered; harmonizing change with edits to §98. 233(q) §98. 233(r)(2) Onshore petroleum and natural gas production facilities shall use the appropriate default population emission factors listed in Table W

- 1A of this subpart for equipment leaks from valves, connectors, open ended lines, pressure relief valves, pump, flanges, and other. Major... Onshore petroleum and natural gas production facilities must use the appropriate default whole gas population emission factors listed in Table W

- 1A of this subpart. Major... Clarifying edit

§98. 233(r)(6) ... shall use the appropriate emission factors as described in paragraph (r)(6) of this section. ... must use the appropriate methane emission factors as described in paragraph s (r)(6) (i) and (r)(6)(ii) of this section. Clarifying edits

§98. 233(r)(6)(i) ... shall use the appropriate default population emission factors listed in Table W

- 7 of this subpart. Below grade T

- D transfer stations shall use the emission factor for below grade metering

- regulating stations. ... must use the appropriate default methane populatio n emission factors listed in Table W

- 7 of this subpart. Below grade transmission

- distribution transfer stations must use the emission factor for below grade metering

- regulating stations. Clarifying edits



### 35

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change §98. 233(r)(6)(ii) Emissions from all above grade me tering

- regulating stations (including above grade TD transfer stations) shall be calculated by applying the emission factor calculated in Equation W

- 32 and the total count of meter/regulator runs at all above grade metering

regulating stations (inclusive

o f TD transfer stations) to Equation W

- 31. The facility wide emission factor in Equation W

- 32 will be calculated by using the total volumetric GHG emissions at standard conditions for all equipment leak sources calculated in Equation W

- 30B in paragraph (q)( 8) of this section and the count of meter/regulator runs located at above grade transmission

distribution transfer stations that were monitored over the years that constitute one complete cycle as per paragraph (q)(8)(i) of this section. A meter on a regul ator run is considered one meter/regulator run. Reporters that do not have above grade T

- D transfer stations shall report a count of above grade metering

regulating stations only and do not have to comply with §98.236(c)(16)(xix). Above grade metering

regu lating stations that are not above grade transmission

distribution transfer stations must use the meter/regulator run population emission factor calculated in Equation W

- 31. Natural gas distribution facilities that do not have above grade transmission

dist ribution transfer stations are not required to calculate emissions for above grade metering

- regulating stations and are not required to report GHG emissions in §98.236(r)(2)(v)

. Harmonizing edits with changes to §98. 233(q)

§98. 233(s)(2) Offshore production facilities that are not under BOEMRE jurisdiction shall use monitoring methods and calculation methodologies published by BOEMRE referenced in 30 CFR 250.302 through 304 to calculate and report emissions (GOADS). Offshore production facilities
t hat are not under BOEMRE jurisdiction shall use the most recent monitoring methods and calculation methods published by BOEMRE referenced in 30 CFR 250.302 through 304 to calculate and report annual emissions (GOADS). Clarifying edits



### 36

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change §98. 233(s)(2)(i) For any calendar year that does not overlap with the most recent BOEMRE emissions study publication, report the most recent reported emissions data with emissions adjusted... For any calendar year that does not overlap with the most recent BOEMRE emissions stud y publication, you may report the most recently reported emissions data submitted to demonstrate compliance with this subpart of part 98, with emissions adjusted ... Clarifying edits

§98. 233(s)(3) ... shall once in every 4 years use the most recent BOEMRE data collection and emissions estimation methods to report emission from the facility

sources. ... shall once in every 4 years use the most recent BOEMRE data collection and emissions estimation methods to es timate emissions. These emission estimates would be used to report emissions from the facility sources as required in paragraph (1)(i) of this section. Clarifying edits

§98. 233(s)(4)

... shall use the most recent BOEMRE data collection and emissions estimat ion methods published by BOEMRE referenced in 30 CFR 250.302 through 304 to calculate and report emissions (GOADS) to report emissions. ... must use the most recent BOEMRE data collection and emissions estimation methods published by BOEMRE referenced in 30 CFR 250.302 through 304 to calculate and report emissions. Applies active language and c orrect s typographical error

§98. 233(t) (t) Volumetric emissions.

... (t) GHG Volumetric emissions using actual conditions.

... Clarifying edits

§98. 233(u) (u) GHG volumetric emissions

. Calculate GHG volumetric emissions at standard conditions as specified in paragraphs (u)(1) and (2) of this section, with mole fraction of GHGs in the natural gas determined by engineering estimate based on best available data unless otherwise specified. (u) GHG volumetric emissions at standard conditions. Calculate GHG volumetric emissions at standard conditions as specified in paragraphs (u)(1) and (2) of this section. Clarifying edits

§98. 233(u)(2)(iii), (u)(2)(iv), (u)(2) (v), (u) (2) (v i ) , and (u)(2)(vii) ... You may use a d efault 95 percent methane and 1 percent carbon dioxide fraction for GHG mole fraction in natural gas. ... You may use either a default 95 percent methane and 1 percent carbon dioxide fraction for GHG mole fraction in natural gas or site specific engineering estimates based on best available data. Clarifying edits

Term “ P i ” of Equation W

- 36 P i ρ i Corrects typo (to Greek letter)



### 37

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change §98.233(w) (w)

... Calculate CO 2 pump blowdown emissions as follows: (w)

... Calculate CO 2 pump blowdown emissions from each EOR injection pump system as follows: Clarifying edits

(1) Calculate the total volume in cubic feet ... (1) Calculate the total injection pump system volume in cubic feet ... (3) Calculate the total annual venting emissions using Equation W

- 37 of this section: (3) Calculate the total annual CO 2 emissions from each EOR injection pump system using Equation W

- 37 of this section:

Terms “ Mass CO2 ,”

“ N ,” and “ V v ” of Equation W

- 37 Mass CO2 = Annual EOR injection gas venting emissions in metric tons from blowdowns. Mass CO2 = Annual EOR injection pump system emissions in metric tons from blowdowns. Clarifies terminology

N = Number of blowdowns for the equipment in the calendar year. N = Number of blowdowns for the EOR injection pump system in the calendar year.

V v = Total volume in cubic feet of blowdown equipment chambers (including pipelines, manifolds and vessels) between isolation valves. V v = Total volume in cubic feet of EOR injection pump system chambers (including pipelines, manifolds and vessels) between isolation valves. §98.233(x), (x)(1), and term “ S hl ” of Equation W

- 38 (x) ... Calculate dissolved CO 2 in hydrocarbon liquids produced through EOR operations as follows: (x) ... Calculate CO 2 emissions downstream of the storage tank from dissolved CO 2 in hydrocarbon liquids produced through EOR operations as follows: Clarifying edits

(1) ... Annual samples must be taken according to methods set forth in §98.234(b)... (1) ... Annual samples of hydrocarbon liquids downstream of the storage tank must be taken according to methods set forth in §98.234(b)

... (2)... S hl = Amount of CO 2 retained in hydrocarbon liquids in metric tons per barrel, under standard conditions. (2)... S hl = Amount of CO 2 retained in hydrocarbon liquids downstream of the storage tank, in metric tons per barrel, under standard conditions. §98.233(z)(1)(i) and (ii) All part 98 rule references in paragraphs (i) and (ii) Added § symbol (e.g., “ for that tier listed in §98.33 ” ) Corrects typographical

error and rule citation

error (ii) ...requirements specified in 98.236(c)(19) and not... (ii) ...requirements specified in §98.236(z) and not...



### 38

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change

Term “ V a ” of Equations W

- 39A and W

- 39B V a = Volume of gas sent to combustion unit in cubic feet, during the year. V a = Volume of gas sent to combustion unit in actual cubic feet, during the year. Clarifying edit

Terms “ Y CO2 ,” “ Y j ” and “ Y CH4 ” of Equations W

- 39A and W

- 39B Concentration of... Mole fraction of... Clarifying edit

Term “ HHV ” of Equation W

- 40 HHV = For the higher heating value for field gas or process vent gas, use 1.235 × 10 −3 mmBtu/scf for HHV. HHV = Higher heating value

o f fuel, mmBtu/unit of fuel (in units consistent with the fuel quantity combusted). For the higher heating value for field gas or process vent gas, you may use either a default higher heating value of 1.235 × 10 −3 mmBtu/scf for HHV or a site

specific higher heating value. For natural gas that is not of pipeline quality or that has a high heat value less than 950 Btu per standard cubic foot, use a site

- specific higher heating value

. Clarifying edit

§98. 234(a) You must use any of the methods described as follows in this paragraph to conduct leak detection(s) of equipment leaks and through

valve leakage fr om all source types listed in § 98.233(k), (o), (p) and (q) that occur during a calendar year, except as provided in paragraph (a)(4) of this section. You must use any of the methods described as follows in this paragraph to conduct leak detection(s) of equipment leaks and through

- valve leakage from all source types listed in §98.233(k), (o), (p) and (q) that occur during a calendar year. Corrects reference

error

§98. 234(d)(1) (1) A technician following manufacturer instructions shall conduct measurements, including equipment manufacturer operating procedures and measurement methodologies relevant to using a high volume sampler... (1) A technician following

ma nufacturer instructions shall conduct measurements, including equipment manufacturer operating procedures and measurement methods relevant to using a high volume sampler... Harmonizing edit



### 39

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change §98. 234(h) [Reserved] (h) For well venting for liquids unloading, i f a monitoring period other than the full calendar year is used to determine the cumulative amount of time in hours of venting for each well (the term

“ T p ” in Equation W

- 7a and W

7b of §98.233) or the number of unloading events per well (the term “ V p ” in E quations W

8 and W

- 9 of §98.233), then the monitoring period must begin before February 1 of the reporting year and must not end before December 1 of the reporting year. The end of one monitoring period must immediately precede the start of the next monito ring period for the next reporting year. All production days must be monitored and all venting accounted for. Harmonizing edit with changes to §98. 233(f).

§98. 238 Component means each metal to metal joint or seal of non

welded connection separated by a compression gasket, screwed thread (with or without thread sealing compound), metal to metal compression, or fluid barrier through which natural gas or liquid can escape to th e atmosphere. Equipment leak means those emissions which could not reasonably pass through a stack, chimney, vent, or other functionally

- equivalent opening. Equipment leak detection means the process of identifying emissions from equipment, components, and other point sources. None (these definitions removed in amendments) Harmonizing edits with changes to §98. 233(q) and (r)



### 40

### Table 1. Minor Technical Corrections (continued)

Final Rule

Citation Current Text Revised Text Reason for Change §98.238 Meter/regulator run means a series of components used in regulating pressure or metering natural gas flow or both. Meter/regulator run means a series of components used in regulating pressure or metering natural gas flow

, or both , in the natural gas distribution industry segment . At least one meter, at least on e regulator, or any combination of both on a single run of piping is considered one meter/regulator

run. Grammatical revisions; harmonizing edits

Sub

- basin category, for onshore natural gas production, means ... Oil, high permeability gas, shale gas, coal seam, or other tight reservoir rock... Wells that produce fro m high permeability gas, shale gas, coal seam, or other tight reservoir rock are considered gas wells ... All wells that produce hydrocarbon liquids and do not meet the definition of a gas well in this sub

- basin category definition are considered to be in th e oil formation. All emission sources that handle condensate from gas wells in high permeability gas, shale gas, or tight reservoir rock formations are considered to be in the formation that the gas well belongs to and not in the oil formation. Sub

- basin c ategory, for onshore natural gas production,

means ...Oil, high permeability gas, shale gas, coal seam, or other tight gas reservoir rock... Wells that produce only from high permeability gas, shale gas, coal seam, or other tight gas reservoir rock are conside red gas wells ... All wells that produce hydrocarbon liquids (with or without gas) and do not meet the definition of a gas well in this sub

- basin category definition are considered to be in the oil formation. All emission sources that handle condensate fro m gas wells in high permeability gas, shale gas, or tight gas reservoir rock formations are considered to be in the formation that the gas well belongs to and not in the oil formation.



### 41