Don’t get caught off guard – Subpart W Revisions

With the beginning of the reporting year 2025 approaching, don’t get caught off guard by the future inventory emissions from the recent Subpart W revisions. Insightful planning today is crucial to effectively reducing future emissions in ways that fit within your operational objectives.

Subpart W revisions were enacted to address potential data gaps and suspected underreporting of emissions calculated using the originally published methodologies and emission factors. The update included adding previously overlooked emissions categories, applying stricter emissions factors, and implementing methodologies that rely on continuous real time data already being collected at many oil and gas facilities.

Here are some important summaries for our clients to consider:

New emission sources operators need to account for:

  • Any Large Release Event captured and reported to the EPA (Super Emitter Program from OOOOb)
  • Engine crankcase venting
  • Produced water tanks
  • Nitrogen Removal Units
  • Mud degassing from drilling in oil producing zones
  • Methane slip from combustion units
  • Blowdown venting

Broader calculation methodologies to incorporate:

Equipment Type

New Methodology

Pneumatic Devices

Direct emission measurement,

Emission factors changed

Pneumatic Pumps

Direct emission measurement

Dehydrators

Measurement + engineering calculations

Completions & Workover with hydraulic fracturing

Direct emission measurement

Hydrocarbon liquids storage tanks

Measurement + engineering calculations

Associated natural gas

Direct emission measurement

Centrifugal compressors

Direct emission measurement

Reciprocating compressors

Direct emission measurement

Equipment leaks

Direct emission measurement,

Measurement + engineering calculations

Emission factors changed

New uses of existing inspection data, particularly at oil and produced water tanks include:

  • Refining open thief hatch data by using OGI inspection data to supplement AVO inspection observations and reduce the total estimated time open to atmosphere.

Ensolum will continue to provide updates and useful resources for operators as they consider compliance planning for 2025. Subsequent updates will focus on specific aspects of oil and gas operations.

What are you looking for?