This action establishes requirements to reduce vented and fugitive emissions of methane from both new and existing natural gas facilities in the State of Maryland. Affected facilities include all new and existing natural gas compressor stations, natural gas underground storage facilities and LNG facilities.
The regulation establishes leak detection and repair (LDAR) requirements for affected facilities. Owners/operators must develop and submit a leak monitoring plan, conduct leak monitoring surveys at prescribed intervals using optical gas imaging for leak detection or EPA Method 21, repair or replace leaking components within 30 days of discovery (Regulation 03). The Maryland Department of the Environment has also committed to considering any new or emerging leak detection technology or alternative practices for monitoring for leaks.
The regulation also establishes methane control requirements for continuous bleed pneumatic devices, requiring that by 1 Jan 2022, all continuous bleed devices have a bleed rate less than 6 cubic feet per hour, and that by 1 Jan 2023, all continuous bleed devices shall be converted to electric or compressed air-powered devices (Regulation 04). Under the regulation, owners/operators must also adopt a mitigation strategy for reciprocating compressors, including either routing emissions from rod packing to a process or control device or measuring the flow rate and replacing rod packing systems that emit greater than 1.0 cubic feet per minute (Regulation 05).
The regulation also establishes reporting and recordkeeping requirements. Specifically, owners and operators of affected facilities, shall maintain, submit and make available upon request a copy of leak detection records (Regulation.07 (A)). Owners/operators must also post a quarterly report summary to a publicly available website (Regulation.07 (A)(1)(c)). Specific reporting requirements are also in place for natural gas-powered continuous bleed pneumatic devices (Regulation.07 (A)(2)), and reciprocating natural gas compressors (Regulation.07 (A)(3)).
Blowdown notification plans are to be submitted to the Department for approval by affected facilities of any blowdown event in excess of 1,000,000 standard cubic feet (Regulation.07). For such events, affected facilities must make information publicly available in accordance with the facility’s approved blowdown notification plan. This information must be made publicly available 7 days prior to the blowdown event and an explanation of the reason of the blowdown shall be provided to the Department (Regulation.07 (B)(3) and (4)).
The regulation also requires all natural gas facilities to report greenhouse gas emissions data to the Department, regardless of the emissions threshold under the federal Greenhouse Gas Reporting Program (GHGRP). Emissions are to be calculated according to the procedures applicable to the GHGRP (Regulation.07 (B)(7)).