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Q545. This question relates to Subpart W, Acid Gas Removal Vents. Section 98.233(d)(11) states "Determine if emissions from the AGR unit are recovered and transferred outside the facility. Adjust the emission estimated in paragraphs (d)(1) through (d)(10) of this section downward by the magnitude of emission recovered and transferred outside the facility." If all of the emissions from an AGR unit are recovered and transferred outside of the facility, does the facility still need to calculate emissions pursuant to Section 98.233(d)(11) and then "reduce" the emission to zero?
Also, if all of the emissions from an AGR units are recovered and injected underground (via an Acid Gas Injection Well), does the facility need to report zero emissions for the source under Subpart W? Or can the facility just report under Subparts PP and UU?
{longname}

A545.

...

EPA

...

requires

...

reporters

...

to

...

calculate

...

emissions

...

from

...

AGR

...

units

...

and

...

then

...

adjust

...

them

...

downwards

...

by

...

the

...

amount

...

transferred

...

outside

...

of

...

the

...

facility.

...

Therefore,

...

if

...

100%

...

of

...

the

...

CO2

...

recovered

...

from

...

an

...

AGR

...

unit

...

is

...

transferred

...

outside

...

of

...

the

...

facility,

...

then

...

CO2

...

emissions

...

from

...

the

...

AGR

...

unit

...

must

...

be

...

calculated

...

prior

...

to

...

determining

...

the

...

amount

...

being

...

transferred

...

outside

...

the

...

facility.

...

Note

...

that

...

§98.236(c)(3)

...

requires

...

separate

...

reporting

...

of

...

both

...

the

...

AGR

...

emissions

...

and

...

emissions

...

recovered

...

and

...

transferred

...

outside

...

the

...

facility,

...

even

...

if

...

the

...

values

...

are

...

the

...

same.

...

With

...

regards

...

to

...

acid

...

gas

...

injection

...

wells

...

and

...

subparts

...

PP

...

and

...

UU,

...

please

...

see

...

the

...

response

...

to

...

EPA-HQ-OAR-2009-0923-0582-31

...

in

...

the

...

Response

...

to

...

Comments

...

(pages

...

1474

...

-

...

1476)

...

http://www.epa.gov/ghgreporting/documents/pdf/2010/Subpart-W_RTC_part2.pdf.

...

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Source: EPA, Frequently Asked Questions, Petroleum and Natural Gas Systems, July 2011, [http://www.epa.gov/climatechange/emissions/downloads11/documents/Subpart-W-additional-faq.pdf]. Updated to clarify

Approval / Publishing History: Version 3, Revised to update URLs per direction from K. Sibold, 9/27/2012

Expiration: none

Relevant Subpart: W, Acid Gas Removal
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