Q545. This question relates to Subpart W, Acid Gas Removal Vents. Section 98.233(d)(11) states "Determine if emissions from the AGR unit are recovered and transferred outside the facility. Adjust the emission estimated in paragraphs (d)(1) through (d)(10) of this section downward by the magnitude of emission recovered and transferred outside the facility." If all of the emissions from an AGR unit are recovered and transferred outside of the facility, does the facility still need to calculate emissions pursuant to Section 98.233(d)(11) and then "reduce" the emission to zero? Also, if all of the emissions from an AGR units are recovered and injected underground (via an Acid Gas Injection Well), does the facility need to report zero emissions for the source under Subpart W? Or can the facility just report under Subparts PP and UU?

A545. EPA requires reporters to calculate emissions from AGR units and then adjust them downwards by the amount transferred outside of the facility. Therefore, if 100% of the CO2 recovered from an AGR unit is transferred outside of the facility, then CO2 emissions from the AGR unit must be calculated prior to determining the amount being transferred outside the facility. Note that §98.236(c)(3) requires separate reporting of both the AGR emissions and emissions recovered and transferred outside the facility, even if the values are the same.

With regards to acid gas injection wells and subparts PP and UU, please see the response to EPA-HQ-OAR-2009-0923-0582-31 in the Response to Comments (pages 1474 - 1476) http://www.epa.gov/ghgreporting/documents/pdf/2010/Subpart-W_RTC_part2.pdf.