Q489. How should I report emissions if my facility has operations in more than one Subpart W industry segment?

A489. For six industry segments, (offshore petroleum and natural gas production, onshore natural gas processing, onshore natural gas transmission compression, underground natural gas storage, liquefied natural gas (LNG) storage, and LNG import and export equipment), there may be cases where a facility’s operations meet the definition of more than one industry segment under subpart W. If this type of co-location occurs for these industry segments, reporters have two options for reporting emissions:

The EPA recommends that reporters use the segment descriptions in 40 CFR 98.230 and the applicable emission source types listed in 40 CFR 98.232 to assign each single purpose emission source to the appropriate industry segment. Where an emission source serves a dual purpose, such as a transmission compressor operating part time as a gas storage compressor, the rule requires this piece of equipment to be reported under the majority use industry segment. EPA concluded that most of the potential dual-purpose equipment will have the same emissions reporting requirements in either industry segment, so reporting under only one majority use segment will avoid double counting even though a given emission source type may appear in the facility report for more than one segment.

Alternatively, reporters may determine total emissions for each emission source type that is listed in 40 CFR 98.232 for the industry segments represented at the co-located facility. When a particular emission source type is listed in 40 CFR 98.232 for more than one of the applicable industry segments, the total emissions for the emission source type would be included only in the industry segment that generated the majority of the emissions for that emission source type. (For example, if onshore natural gas transmission compression and underground natural gas storage are the two co-located segments, all emissions from reciprocating compressors would be reported under one segment or the other, whichever has the highest emissions.) Thus, each emission source type will be included in only one of the industry segments, and double-counting of emissions will not occur.

Note that the other four industry segments (onshore petroleum and natural gas production, natural gas distribution, onshore petroleum and natural gas gathering and boosting, and onshore natural gas transmission pipeline) have unique definitions of facility in subpart W and have separate reporting threshold requirements in 40 CFR 98.231(a). Therefore, facilities in these segments may not be co-located with other industry segments in subpart W, and these facilities should be registered separately within e-GGRT.

The 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) https://www.regulations.gov/document?D=EPA-HQ-OAR-2009-0923-3608 and at https://www. .com/confluence/display/help/Subpart+W+Facility+Registration#SubpartWFacilityRegistration-Co-locatedindustrysegmentsanddualpurposeequipment.