Suppliers  of Natural Gas and Natural Gas Liquids
Final Rule: Mandatory Reporting of Greenhouse Gases                              Agency

Under the Mandatory Reporting of Greenhouse Gases (GHGs) rule, suppliers of natural gas and natural
gas liquids (NGLs) must report the emissions that would result from the complete combustion or
oxidation of the products that they place in commerce. Suppliers of natural gas and NGLs are required to
collect data on their products; calculate the GHG emissions associated with these products; and follow
the specified procedures for ensuring data quality, amending missing data, and meeting recordkeeping
and reporting requirements.

Natural gas fractionators should also note other potential source categories that are required to report
emissions under the proposed rule.

How Is This Source Category Defined?

Suppliers of natural gas and NGLs are defined as natural gas liquids fractionators and local natural gas
distribution companies (LDCs), as follows:
    •   Natural gas liquids fractionators are installations that fractionate NGLs into their constituent
       liquid products (ethane, propane, normal butane, isobutene, or pentanes plus) for supply to
       downstream facilities.
    •   Local distribution companies are companies that own or operate distribution pipelines that
       physically deliver natural gas to end users and that are regulated as separate operating companies
       by state public utility commissions, or that operate as independent municipally owned distribution
       systems. Companies that operate interstate or intrastate pipelines are not part of this source
       category.

This supply category does not include the following facilities:

    •   Field gathering and boosting stations.
    •   Natural gas processing plants that separate NGLs from natural gas and produce bulk or y-grade
       NGLs but do not fractionate these NGLs into their constituent products.
    •   Facilities that meet the definition of refineries and report under subpart MM (Suppliers of
       Petroleum Products).
    •   Facilities that meet the definition of petrochemical plants and report under subpart X
       (Petrochemical Production).

What GHGs Must Be Reported?

Natural gas fractionators must report carbon dioxide (CO2) emissions that would result from the complete
combustion or oxidation of the annual quantity of ethane, propane, normal butane, isobutane, and
pentanes plus that is sold or delivered to others.

Local distribution companies must report CO2 emissions that would result from the complete combustion
or oxidation of the annual volumes of natural gas provided to end users on their distribution systems.
                                                                                      United States
                                                                                      Environmsntel Protection
40 CFR 98, subpart NN                           1                             EPA-430-F-09-004R
September 2009

-------
How Should GHG Emissions Be Calculated?

Two different methods can be used to calculate CO2 emissions that would result from the complete
oxidation or combustion of the product supplied:
    •  Calculation Methodology 1: Calculate CO2 mass emissions from a natural gas or NGL product
       by multiplying the volume of product by its higher heating value (HHV) and its CO2 emission
       factor (EF). Use either measured or default fuel HHVs and CO2 EFs.
    •  Calculation Methodology 2: Calculate CO2 mass emissions from a natural gas or NGL product
       by multiplying the volume of product by its CO2 EF. Use either measured or default CO2 EFs.

A checklist for data that must be monitored is available at:
www.epa.gov/climatechange/emissions/downloads/checklists/suppliersnaturalgas.pdf.

What Information Must Be Reported?

In addition to the information required by the General Provisions at 40 CFR 98.3(c), each NGL
fractionator must report the following information:
    •  Annual CO2 emissions in metric tons associated with all NGLs supplied, excluding emissions
       from quantities of NGL received from other fractionators.
    •  Annual CO2 emissions in metric tons associated the total quantities of NGL that are supplied to
       facilities, reported in the following product categories:
       o   Ethane
       o   Propane
       o   Normal butane
       o   Isobutene
       o   Pentanes plus
    •  Annual quantities in barrels (bbl) of ethane, propane, normal butane, isobutane, and pentanes plus
       and the specific industry standard used to measure these quantities.
    •  Annual quantities in bbl received from other NGL fractionators of ethane, propane, normal
       butane, isobutane, and pentanes plus.
    •  Annual volume in millions of standard cubic feet (Mscf) of natural gas received for processing.
    •  Annual quantity in bbl of y-grade, bulk NGLs received from others for fractionation.
    •  Annual quantity in bbl of propane that the NGL fractionator odorizes at the facility and delivers
       to others.
    •  Developed EFs and HHVs and the industry standard(s) used to develop them, if the NGL
       fractionator developed site-specific EFs or HFTVs.
    •  Number of days in the reporting year for which substitute data procedures were used to measure
       quantity, develop HHVs, and develop EFs.

In addition to the information required by the General Provisions at 40 CFR 98.3(c), each LDC must
report the following information at the corporate level:
    •  Annual CO2 mass emissions in metric tons associated with gas delivered to each meter that
       receives 460,000 Mscf or more per year.
    •  Annual CO2 mass emissions in metric tons associated with gas delivered to all meters that receive
       less than 460,000 Mscf per year (excluding emissions from gas delivered to  other pipelines or
       LDCs and gas stored for future deliveries.)
    •  Annual CO2 mass emissions in metric tons that would result from the complete combustion or
       oxidation of the seven  reported volumes that follow.
40 CFR 98, subpart NN                           2                             EPA-430-F-09-004R
September 2009

-------
    •   Annual volume in Mscf of natural gas received at its city gate stations for redelivery on its
       distribution system, including for use by the LDC, and the specific industry standard used to
       measure this volume.
    •   Annual volume in Mscf of natural gas that is used for deliveries in the reporting year that was not
       otherwise accounted for in the above reported volume. This primarily includes natural gas
       previously stored on-system or liquefied and stored, which is removed from storage and used for
       deliveries to customers or other LDCs by the LDC within the reporting year. This also includes
       natural gas that bypassed the city gate and was delivered directly to LDC systems from  producers
       or natural gas processing plants from local production.
    •   Annual volume in Mscf of natural gas withdrawn from on-system storage for delivery on the
       distribution system.
    •   Annual volume in Mscf of natural gas placed into storage, including gas liquefied and placed into
       storage.
    •   Annual volume in Mscf of natural gas delivered directly to LDC systems from producers or
       natural gas processing plants from local production.
    •   Annual volume in Mscf of natural gas delivered to downstream gas transmission pipelines and
       other LDCs.
    •   Annual volume in Mscf of natural gas delivered to each  meter registering supply equal to or
       greater than 460,000 Mcsf during the calendar year and the customer name, address, meter
       number, and EIA identification number (if known) of each meter reading used.
    •   Developed EFs and HHVs and the industry standard(s) used to develop them, if the LDC
       developed site-specific EFs or HHVs.
    •   Annual volume in Mscf of natural gas delivered to each  of the following end-user categories:
           o  Residential consumers.
           o  Commercial consumers.
           o  Industrial consumers.
           o  Electricity-generating facilities.
    •   Number of days in the reporting year for which substitute data procedures were used to  measure
       quantity, develop HHVs, and develop EFs.

For More Information

This document is provided solely for informational purposes. It does not provide legal advice, have
legally binding effect, or expressly or implicitly create, expand, or limit any legal rights, obligations,
responsibilities, expectations, or benefits in regard to any person. The series of information sheets is
intended to assist reporting facilities/owners in understanding key provisions of the final rule.

Visit EPA's Web site (www.epa.gov/climatechange/emissions/ghgrulemaking.html') for more
information, including the final preamble and rule, additional information sheets on specific industries,
the schedule for training sessions, and other documents and tools. For questions that cannot be answered
through the Web  site, please contact us at: ghgmrr@epa.gov.
40 CFR 98, subpart NN                            3                             EPA-430-F-09-004R
September 2009

-------