Q507. How do we report emissions from separate facilities that inject or withdraw gas from the same underground storage reservoir?

A507. Underground storage and compression and transmission compression are two separate industry segments.  A “facility”, as defined in 40 CFR 98.6, must determine if it contains any of the industry segments listed in subpart W and compare its emissions from all applicable industry segments against the 25,000 mtCO2e threshold defined in 40 CFR 98.2(a)(2) to determine applicability.  For a response to the question related to multipurpose facilities and dual purpose equipment, please see the response to EPA-HQ-OAR-2009-0923-1024-14 (see pp. 1606-1608 in http://www.epa.gov/ghgreporting/documents/pdf/2010/Subpart-W_RTC_part2.pdf).  If multiple owners or operators use the same underground storage operation, one designated representative must be appointed for reporting purposes.