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The supplemental rule -- which will be made final sometime later this year, after the agency examines comments -- focuses more on significant sources of fugitive emissions of methane within the natural gas transmission industry. That is the good news. The bad news is that the type of monitoring of those sources that would be required will be much more costly than warranted, according to Beal. "While we are happy EPA at least limited monitoring to certain components, we still maintain that the program is not the way to get measurement of fugitive emissions," she states.
Fiji C. George, director, Climate Change Strategies, El Paso Corp., says much the same thing.
"While EPA accepted some of our comments directing the focus of the proposal on major emitting sources, compliance with the rule for our production and transmission segments will be challenging due to the vast number of emission components to be monitored," he offers. El Paso, like INGAA and other individual companies, will be pressing EPA to make changes in the final rule.
One of the industry's major objections is that the supplemental would require direct measurement -- the most expensive technology -- for five emission sources: storage tanks (transmission) when scrubber dump valves are detected leaking, centrifugal compressor wet seal oil degassing vents, large reciprocating compressor rod packing vents, large compressor blowdown vent valve leaks and large compressor blowdown vent (unit isolation valve leaks), the latter two when leakage is detected.
For direct measurement, EPA proposes that the following technologies be used: high volume samplers, meters (such as rotameters, turbine meters, hot wire anemometers and others), and/or calibrated bags. Other sources which would require monitoring, though not by direct methods, include: reciprocating and centrifugal compressors, including compressor and station blowdowns, centrifugal compressor wet and dry seals, wet seal oil degassing vents, reciprocating compressor rod packing vents, unit isolation valves, blowdown valves, compressor scrubber dump valves and gas pneumatic continuous bleed devices.