Compliance

Greenhouse Gas Reporting for Oil and Gas: Who Files, What Numbers Move and When the Deadline Hits

Greenhouse gas reporting turns site activity into a federal submission. Large oil and gas facilities report carbon dioxide, methane and nitrous oxide from combustion, venting and equipment leaks. The rule uses subparts that separate well sites from processing plants and transmission facilities.

Reportable sources and subparts

Stationary combustion, compressor engines and glycol dehydrators are common reportable units. Pneumatic devices, well completions and storage tanks also fall under specific subparts. An operator has to identify each affected facility, apply the correct emission factor or monitor, and document the calculation. A report that uses the wrong emission factor for a reciprocating compressor is not a rounding error. It is an incorrect report. Supporting documentation includes run hour logs, fuel records and, where applicable, continuous monitoring data. Regulators can trace a reported number back to the meter or hour meter that produced it.

Monitoring, QA QC and verification

Some sources use continuous monitoring. Others use measured parameters such as fuel use, throughput or operating hours. The operator keeps the meter or hour meter log and ties it to the report. QA QC procedures include calibration records, data review and outlier investigation. Regulators and third parties can review methodology and underlying data during verification. Missing a calibration record or a unit conversion factor can change an emissions estimate materially.

Deadlines, resubmissions and public records

The report is due annually. Late submissions and resubmissions follow a set process. Once submitted, the report becomes part of the public record and can influence enforcement and state inventories. Operators keep the final report, supporting spreadsheets and the underlying raw data. An operator who can explain a spike in emissions with meter logs and maintenance records is in a better position than one who can only point to the final number. GHG reports and equipment inspection logs are exactly the kind of structured field data tracked in OpsFlo, ticket, dispatch, timesheet, approvals and document software built for field crews.

Sources and further reading

• eCFR 40 CFR 98: GHG reporting
• EPA: Controlling air pollution from oil and gas
• eCFR 40 CFR 60.18: General compliance requirements
• eCFR 40 CFR 60.5415: Well completions and pneumatics