Q495. Which takes precedence for determining the Subpart W applicability of a natural gas processing facility- the 25,000 MT CO2e threshold (under 98.2(a)(2)) or the 25 MMscf per day throughput (under 98.230(a)(3))?
A495. Since the throughput of the facility was identified in the question as 30 MMscf per day throughput capacity, this exceeds the exclusion identified in the §98.230(a)(3) for processing facilities that do not fractionate. Therefore, this facility falls under the onshore natural gas processing industry segment definition as defined in §98.230(a)(3) and these emissions would be included in the applicability determination for your facility. (If the throughput were less than 25 MMscf this source would not have been considered in the applicability determination for the facility.) However, based on the information provided, since the processing facility has less than 25,000 metric tons CO2e in combined emissions from stationary combustion, flaring, vented, and fugitive sources, the facility does not need to report under subpart W.A495. Both the 25,000 metric ton CO2e threshold (from §98.2(a)(2)) and the 25 MMscf per day annual average throughput (from §98.230(a)(3)) are considered when determining subpart W applicability for a natural gas processing facility.| Wiki Markup |
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Source: EPA, Frequently Asked Questions, Petroleum and Natural Gas Systems, July 2011, |
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