Q518. How are we to treat GHG reporting applicability offshore LNG where the offshore terminal is basically buoy out in the ocean where a ship connects, regasifies the LNG onboard and injects natural gas under pressure into the pipeline?

A518. The LNG import and export terminal source category includes offshore equipment that receives imported LNG via ocean transport, stores LNG, re-gasifies LNG, and delivers re-gasified natural gas to a natural gas transmission or distribution system.  The floating vessels described above, not the ships, are considered LNG import terminal facilities.  Applicability would be determined by determining the estimated emissions and comparing against the threshold in 40 CFR 98.2(a)(2).