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National Grid LNG Operations – EPA MRR Subpart W Compliance Experience. 40 CFR 98 – Mandatory Reporting of Greenhouse Gases – Subpart W – LNG Storage. Topics to Cover. National Grid: who we are EPA MRR Impacted Portions of National Grid Subpart W Experience for LNG Ops

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National Grid LNG Operations – EPA MRR Subpart W Compliance Experience

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National grid lng operations epa mrr subpart w compliance experience l.jpg

National Grid LNG Operations – EPA MRR Subpart W Compliance Experience

40 CFR 98 – Mandatory Reporting of Greenhouse Gases –

Subpart W – LNG Storage


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Topics to Cover

  • National Grid: who we are

  • EPA MRR

    • Impacted Portions of National Grid

  • Subpart W Experience for LNG Ops

    • Planning/Preparation

    • Reality Check

    • Surveys

    • Compliance Evaluation


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    National Grid: who we are

    US Operations


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    An international electricity and gas company

    • … based in the UK and northeastern US

      • We play a vital role in delivering gas and electricity to millions of people safely, reliably and efficiently

    • One of the world’s largest investor-owned utilities

    • Approximately 19 million industrial, commercial and domestic customers

    • Almost 28,000 employees

      • 63% work in the US; 37% work in the UK

      • 77% males; 23% females; 13.5% ethnic minorities


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    Our Gas Distribution business - US

    • In the US, our Gas Distribution business consists of gas networks in upstate New York, New York City, Long Island, Massachusetts, New Hampshire and Rhode Island

    • Delivers gas to 3.5 million consumers

    Gas Distribution US – operating area


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    Our Electricity Distribution & Generation business - US

    • We supply electricity to approximately 3.4 million customers in the northeastern US

    • We also own generation plants with a capacity of over 4,000 megawatts

    Electricity Distribution & Generation – operating area

    • Electricity distribution area

    • Long Island Power Authority area

    • Generation


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    Our Transmission business - US

    • In the US, we provide the transmission of electricity in the northeastern US as owner and operator of high voltage electricity transmission networks in upstate New York, Massachusetts, Rhode Island, New Hampshire and Vermont

    Transmission US – electricity networks


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    Our commitment to the environment

    • Company-wide environment policy

    • Includes explicit commitment to protect and enhance the environment

    • Sets goals for continuous improvement and focuses on most important environmental issues and opportunities


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    Our commitment to climate change

    • Embed target of 80% GHG reduction against 1990 baseline by 2050

    • Reshaping markets by aligning regulatory and public policy incentives

    • Help others to meet climate change challenge and embrace energy efficiency

    • Business plan for carbon emissions reduction including:

      • Research and development

      • Adaptation studies

      • Design-in low carbon solutions

      • SF6 reduction group

      • Energy users group, fleet

      • Carbon budgets

      • Shadow price of carbon


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    EPA Mandatory GHG Reporting Rule Compliance at National Grid


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    40 CFR Part 98 – Applicable to National Grid

    • Subpart C – General Stationary Fuel Combustion Sources

      • Multiple stationary fuel combustion sources at Subpart D facilities

  • Subpart D – Electricity Generation

    • (9) Electricity Generation Sources

  • Subpart W – Petroleum & Natural Gas Systems

    • (1) Onshore Natural Gas Production Facility (Potential)

    • (16) LNG Storage Facilities (Potential)

    • (7) Natural Gas LDCs

  • Subpart DD – Electrical Transmission & Distribution Equipment Use

    • (2) Electric Power Systems

  • Subpart NN – Suppliers of NG & LNG

    • (7) Natural Gas LDC


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    EPA Mandatory GHG Reporting Rule Compliance at National Grid

    LNG Subpart W Planning/Preparation


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    LNG Storage 98.232 (g)&(j)

    • Reciprocating Compressor Rod Packing Venting

    • Centrifugal Compressor Venting

    • Equipment Leaks from:

      • Valves

      • Pump Seals

      • Connectors

      • Vapor Recovery Compressors

      • Other

    • GHG Emissions from each flare

    Data Requirements


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    Leak DetectionMeasurement Methods 98.234

    Optical Gas Imaging

    EPA Method 21

    Infrared Laser Beam

    Acoustic Device


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    LNG Ops Approach

    • Used Optical Gas Imaging – the FLIR’s GasFindIR camera

      • Reasoning:

        • Efficient,

        • Able to capture wide areas of facilities quickly,

        • Video capture,

        • Date/time stamped proof,

        • Cost comparable to other technologies when using contractor.

    • Surveyed all 16 LNG facilities over the course of 2 weeks

      • 22 total leaks found across all facilities

      • No facility close to tripping the reporting threshold


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    EPA Mandatory GHG Reporting Rule Compliance at National Grid

    LNG Subpart W Reality Check


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    Threshold Reality Check

    • 25,000 metric ton CO2e reporting threshold for each LNG storage facility

    • We back calculated what natural gas would have to be lost through fugitive or vented means using the equations provided in Subpart W

    • Equivalent to the venting of roughly 68 LNG transport trucks each year

    Using Eq. W-36 from Subpart W


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    EPA Mandatory GHG Reporting Rule Compliance at National Grid

    Surveys


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    Survey Approach

    • Broke LNG facility into discreet areas for efficient surveying of large areas:

      • Boil-off compressor room (twice in different modes)

      • LNG Vaporizers

      • Truck Station

      • LNG Pump out

      • Tank Top Relief Valves

      • Send Out

  • By doing one or two camera/tripod setups in each area we were able to see wide areas and then pinpoint any leaks and count leaking components

  • Surveys took about 2 hours to complete at a typical facility


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    Sample Report

    vapors detected


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    Sample Report

    vapors detected


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    Sample Report

    no vapors detected


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    Sample Report

    no vapors detected


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    Sample Report

    no vapors detected


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    Sample Compliance Results


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    Conclusions

    • As expected, none of the facilities will come close to the Subpart W reporting threshold

    • We now have documented proof that our plants have very few leaks (22 instances of leaking or venting gas across 16 facilities)

      • Compressor distance pieces are the most prone to leak or vent

  • We also observed the efficiency of visually seeing leaking gas across a wide area of the facility instead of the typical method of searching with a CGI


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    Questions?


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