Q522. Are LNG storage sites located adjacent to subpart D facilities under “common control” required to report emissions under the subpart D “facility” or should the LDC report the emissions under subpart W?

A521. Based on the information provided, the questioner would report as a single facility under 40 CFR 98. The single facility would be required to report emissions separately for subparts C, D and W in the EPA electronic greenhouse gas reporting system (eGGRT). In regard to specific sources, subpart W requires the reporting of process and emissions from any source listed in 98.232(g) sent to a flare from LNG storage facilities, as defined in 40 CFR 98.230, under subpart W according to the calculation procedures outlined in 98.233. Additional applicable emissions are to be reported under subpart D according to the methods described in subpart D. Finally, stationary combustion emissions are to be reported under subpart C.

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

Approval / Publishing History: Version 1

Expiration : none

Relevant Subpart: W
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