Q546. 98.233(d)(11) - Acid gas removal vents. When calculating emissions from acid gas removal vents, the regulation reads, "determine if emissions from the AGR unit are recovered and transferred outside the facility. Adjust the emission estimated downward by the magnitude of emission recovered and transferred outside the facility." Many operators perform on-site injection of acid gas - Our clients request that the EPA clarify that those performing on-site acid gas injection can also estimate their emissions downward.
A546. Reporters performing on-site injection of acid gas may not adjust emissions downward. §98.233(d)(11) clearly states that you may only adjust emissions estimates downwards for emissions recovered and transferred OUTSIDE the facility. Please see 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.
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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
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Approval / Publishing History: Version 2, Revised to update URLs per direction from K. Sibold, 9/27/2012
Expiration: none
Relevant Subpart: W, Acid Gas Removal