In 2009, the U.S. Environmental Protection Agency enacted a rule requiring the mandatory reporting of greenhouse gases (GHGs) from significant emissions sources across the nation. Facilities emitting 25,000 metric tons or more of carbon dioxide equivalent (CO2e) annually must comply with the comprehensive reporting framework outlined in 40 CFR Part 98 Subpart W, referred to as the Greenhouse Gas Reporting Program. The program is intended to provide a detailed and accurate portrayal of emissions from key market sectors and guide development of policies and initiatives to curb GHG emissions.
Compliance with Subpart W is intricate and rigorous, particularly for energy companies like Summit Midstream Corporation, which must meticulously report emissions from its extensive network of petroleum and natural-gas gathering and boosting basins, as well as natural-gas processing plants. Summit relies on Barr’s comprehensive emissions-reporting services to simplify compliance and help ensure timely and accurate reporting.
Our assistance incorporates cutting-edge tools and expert analysis to address every aspect of the program, from data collection to final submittals, including:
- Staying ahead of regulations. Barr keeps a vigilant eye on the EPA’s constantly evolving Subpart W regulations to confirm ongoing compliance with updates and requirements.
- Managing large-scale data. Operational data from multiple external data sets—covering runtime, throughput, and fuel use—is meticulously gathered and processed.
- Data review and gap analysis. Throughout the year, Barr reviews data housed in Summit’s Intelex Asset Compliance Tracking System (ACTS) to identify gaps and discrepancies, generate emission results, and reduce last-minute corrections.
- Accurate emission calculations. Our team employs EPA methodologies to precisely calculate emissions of methane (CH4), carbon dioxide (CO2), and nitrous oxide (N2O) from numerous types of equipment.
- Quality assurance and quality control. Performing rigorous QA/QC checks lets us identify and resolve incomplete or incorrect calculations, supporting data integrity and lowering the risk of noncompliance.
- SQL expertise for report generation. By leveraging advanced SQL Oracle reporting capabilities, Barr automates the generation of reports in the format required by the EPA’s Electronic Greenhouse Gas Reporting Tool (e-GGRT)—saving time and reducing the potential for errors.
- Trend analysis for continuous improvement. We compare the current year’s emission data with historical data to identify discrepancies and opportunities for improvement.
- Detailed documentation. Barr documents every aspect of the data-collection and -reporting process, from source identification to calculation methodologies and quality checks, providing a robust and defensible monitoring plan.
- Supporting regulatory communications. Our services include helping Summit address inquiries from the EPA through the e-GGRT tool, promoting clear and accurate responses.
Adding to the challenge of complying with Subpart W is the EPA’s annual March 31 reporting deadline, which requires a swift and precise reporting effort for the previous year’s emissions data. Because Barr has in-depth familiarity with both the regulatory framework and Summit’s data, however, we can help the company effectively mitigate deadline pressure and help ensure a seamless submittal process.
Our longstanding partnership with Summit Midstream goes beyond providing baseline technical expertise. Barr has earned the company’s business by combining compliance knowledge with a collaborative, client-focused approach to meeting complex regulatory requirements.