Q489. If a natural gas processing plant is co-located with an underground storage facility and they share compression, can they report as one combined facility?

A489. If the natural gas processing plant and the underground storage operations are part of the same facility, as defined in 98.6 you would report as one facility and submit one annual GHG report for these operations.  EPA has provided guidance on how reporters should report for co-located industry segments and dual purpose equipment, please see the comment response number EPA-HQ-OAR-2009-0923-1024-14, Response To Comments (1606 - 1608) http://www.epa.gov/ghgreporting/documents/pdf/2010/Subpart-W_RTC_part2.pdf.


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