Q516. For liquefied natural gas facility equipment that is in gas service, is only the equipment listed in Table W-5 (Vapor Recovery Compressor) required to be reported if it is found to be leaking as defined in the rule?

A516. LNG facilities will not be surveying the valves, connectors, and other components that are in Gas Service under 98.233(q).  At an LNG facility, a compressor that recovers vapor, but is designed so that it does not have reportable emissions of methane-containing gas, such as a flooded screw compressor, or one with seals purged with pressurized nitrogen, will not be reported, in accordance with the rule and the EPA’s response in Response to Public Comments, EPA-HQ-OAR-2009-0923-1026-7 (see pp. 45-46 in http://www.epa.gov/ghgreporting/documents/pdf/2010/Subpart-W_RTC_part1.pdf).  Vapor recovery compressors use a population emission factor, hence there is no leak detection required.  Reporters have to count the number of vapor recovery compressors and use the population emission factor.