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FAQ > Rule Subparts > Subpart W. Petroleum and Natural Gas Systems > Subpart W - General > Q667. How do I determine applicability for Subpart W facilities with stationary combustion sources?
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Q667. How do I determine applicability for Subpart W facilities with stationary combustion sources?

A667. Subpart W facilities with stationary combustion sources are subject to reporting if they meet the requirement of 98.2.

A facility that only has Subpart C sources is required to report if the conditions specified in 98.2(a)(3)(i)-(iii) are met. 98.2(a)(3)(ii) specifies that a facility is only required to report if aggregate maximum rated heat input capacity is 30 mmBtu/hr or greater. Where a facility is subject to both Subpart C and Subpart W the applicability requirements are specified in 98.2(a)(2) instead of 98.2(a)(3).

98.2(a)(2) specifies that, where the facility contains any source category that is listed in Table A-4, the threshold is emissions greater than 25,000 metric tons of CO2e per year emitted from a combination of source categories listed in Table A-3 and Table A-4, Subpart C, and Subpart U. The exemption for aggregated 30 mmBtu/hr combustion units only applies when the facility is subject to Subpart C only, not for when a facility contains Subpart C and any other relevant Subpart. In addition, per 98.2(a)(1), if a facility contains any of the subparts listed in Table A-3, their report must cover emissions from all applicable source categories listed in Table A-3 and Table A-4, Subpart C, and Subpart U.

In the situation where the facility is an onshore petroleum and natural gas production facility, as defined in 98.238, report only emissions from the sources listed at §98.232(c)(1)-(22).  Any combustion emissions would be calculated per §98.232(c)(22). §98.232(c)(22) states:

You must use the methods in §98.233(z) and report under this subpart the emissions of CO2, CH4, and N2O from stationary or portable fuel combustion equipment that cannot move on roadways under its own power and drive train, and that is located at an onshore petroleum and natural gas production facility as defined in §98.238. Stationary or portable equipment are the following equipment, which are integral to the extraction, processing, or movement of oil or natural gas: well drilling and completion equipment, workover equipment, natural gas dehydrators, natural gas compressors, electrical generators, steam boilers, and process heaters.

Stationary combustion equipment not integral to the extraction, processing, or movement of oil or natural gas are generally not deemed to be part of an onshore petroleum and natural gas production facility.

In the situation where the facility is an natural gas distribution facility, the combustion emissions would be calculated per §98.232(i)(7). §98.232(i)(7) states:

Report under subpart W of this part the emissions of CO2, CH4, and N2O emissions from stationary fuel combustion sources following the methods in §98.233(z)

§98.233(z) allows onshore petroleum and natural gas production and natural gas distribution facilities to exclude external fuel combustion sources with a rated heat capacity less than or equal to 5 mmBtu/hr or internal fuel combustion sources, other than compressor drivers, with a rated heat capacity less than or equal to 1 mmBtu/hr (or the equivalent of 130 horsepower) from the threshold determinations and reporting.

Subpart W facilities that are not onshore petroleum and natural gas production or natural gas distribution facilities, report their stationary combustion emissions under Subpart C and determine applicability based on the source categories listed in §98.2.

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Source: Drafted new by July 25 2012

Approval / Publishing History: Reviewed and Approved by D. Jacobson and M Rohwer on 8/5/2012, pending EPA Final Review

Expiration: January 2013

Relevant Subpart/Component: Subpart W General

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