Q514. How should we report a facility that combines onshore petroleum and natural gas production and natural gas storage by injecting natural gas for the purposes of both enhanced oil recoveray and storage?

A514. What constitutes a facility, how to determine the reporting threshold, and reporting of emissions from collocated and dual purpose equipment is as follows: 1) As a first step the reporter must determine the emissions from all equipment listed in 98.232(c) for onshore petroleum and production.  Per section 98.231(a) only sources listed in 98.232(c) need to be considered for threshold determination for onshore petroleum and natural gas production. 98.238 defines “facility” for the purposes of onshore petroleum and natural gas systems.  Per the requirements of 98.3 each “facility” must submit a GHG report for all source categories at that “facility”.  2) Note that while identifying onshore production emissions sources reporters have to determine whether the source is “on the well pad or associated with a well pad”.  The location of production wells within other facilities is inconsequential to this determination.  Sources on a well pad or associated with a well pad across the entire reporting basin have to be taken into consideration.  If your emissions from onshore petroleum and natural gas production are equal to or greater than 25,000mtCO2e, then onshore petroleum and natural gas production facilities report as a separate facility and include all emissions sources listed in 98.232(c).  3) Except for onshore petroleum and natural gas production and natural gas distribution, which have unique facility definitions, all other segments subject to subpart W are considered in the threshold determination for a single facility.  You would also include emissions from other source categories at your facility (e.g., stationary combustion).  If there are emissions sources that are dual purpose then the rule requires this piece of equipment to be reported under the majority use industry segment based on guidance provided in EPA-HQ-OAR-2009-0923-1024-14 (pp. 1606-1608).  4) For collocated industry segments, which cannot occur in the case of onshore petroleum and natural gas production and natural gas distribution due to the requirements in 98.231(a), EPA has provided guidance on emissions reporting in EPA-HQ-OAR-2009-0923-1024-14.  Based on the information provided, the facility cannot be reported as onshore production and natural gas processing combined (see point 1 above).  For all the other segments, the report should use guidance in points 2-3 above to determine the segment under which the facility should be categorized.