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Q480. How should the daily oil throughput be determined for onshore production storage tanks in 98.233(j)(1) to compare to the threshold of 10 barrels/day? Is it based on design capacity, maximum daily throughput, or annual average actual daily throughput? Is the throughput re-evaluated annually? If the throughput decreases below this threshold, are the equipment excluded from report under Subpart W?
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A480.

...

It

...

is

...

EPA’s intent

...

that

...

the

...

10

...

barrels

...

per

...

day

...

of

...

oil

...

throughput

...

referenced

...

in

...

98.233(j)

...

be

...

based

...

on

...

annual

...

average

...

daily

...

throughput.

...

On

...

an

...

annual

...

basis,

...

the

...

owner/operator

...

must

...

evaluate

...

whether

...

individual

...

well

...

pad

...

produced

...

hydrocarbon

...

liquids

...

falls

...

above

...

or

...

below

...

the

...

equipment

...

threshold

...

and

...

use

...

monitoring

...

methods

...

appropriately.

...

For

...

less

...

than

...

10

...

barrels

...

per

...

day

...

of

...

oil

...

throughput

...

on

...

an

...

annual

...

average

...

daily

...

basis,

...

the

...

reporter

...

must

...

determine

...

if

...

98.233(j)(5)

...

applies.

...

 

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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]. 

Approval / Publishing History: Version 2, Modified and published per M Eaddy on 4/23/2012

Expiration : none

Relevant Subpart: W
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