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Q593. Under §98.232(e), emissions from flares are not a required source for calculation and reporting. Under section §98.233(o)(9), however, emissions from flares associated with centrifugal compressors must be reported. There are multiple cases throughout Subpart W where these confusions exist (i.e. section §98.233(k)(4), which is specific to the transmission compression industry segment). Please clarify which section of the rule is the correct guiding action.
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A593. Under §98.232(e), emissions from flare stacks are not required to be reported as a separate emission source for onshore natural gas transmission compression facilities. However, this does not exclude the reporting of flared emissions from the other emission sources listed in §98.232(e) if they are routed to a flare. The flare source type in §98.233(n) covers only emissions that are not reported in association with any of the other source types in §98.233; see §98.233(n)(10). For example, if transmission storage tank emissions are going to a flare, then the rule requires the adjustment of transmission storage tank emissions sent to flare per §98.233(k)(4). The flared transmission storage tank emissions, however, have to be reported as transmission storage tank emissions under §98.236(c)(9).
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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]. Modified per M. Eaddy 7/26/2012
Approval / Publishing History: Version 2
Expiration : none
Relevant Subpart: W, Flaring
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