Q510. If a company owns and operates an underground storage facility but the associated storage wellheads are owned jointly with a second company but operated by the second company, should the respective operators to submit separate emission reports?

A510. Please refer to the definition of “facility” in 98.6. Based on the information provided, it would appear that company A would be required to submit one emissions report for the underground storage and the associated wellheads. Please refer to the response to comment EPA-HQ-OAR-2009-0923-1024-16 regarding reporting by designated representatives (see pp. 928-929 in 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/ghgreporting/documents/pdf/2011/documents/Subpart-W-additional-faq.pdf].

Approval / Publishing History: Version 1

Expiration : none

Relevant Subpart: W
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