Q545. If all of the emissions from an AGR unit are recovered and transferred outside of the facility, does the facility still need to calculate emissions pursuant to Section 98.233(d)(11) and then "reduce" the emission to zero?

Q545. If all of the emissions from an AGR unit are recovered and transferred outside of the facility, does the facility still need to calculate emissions pursuant to 40 CFR 98.233(d)(11) and then "reduce" the emissions to zero? Also , if all of the emissions from an AGR unit are recovered and injected underground (via an acid gas injection well), does the facility need to report zero emissions for the source under Subpart W, or can the facility just report under Subparts PP and UU?

A545. In the regulatory text that is effective though December 31, 2024, 40 CFR 98.233(d)(11) states, “Determine if CO₂ emissions from the AGR unit are recovered and transferred outside the facility. Adjust the CO₂ emissions estimated in paragraphs (d)(1) through (d)(10) of this section downward by the magnitude of CO₂ emissions recovered and transferred outside the facility.” In other words, EPA requires reporters to calculate emissions from AGR units, determine the amount of CO₂ being recovered and transferred outside the facility, and then adjust the AGR emissions downwards by the amount transferred outside of the facility.  Therefore, if 100% of the CO₂ recovered from an AGR unit is transferred outside of the facility, then CO₂ emissions from the AGR unit must be calculated prior to determining the amount being transferred outside the facility.   In addition, per 40 CFR 98.236(d)(1)(iv), “if any CO₂ emissions from the acid gas removal unit were recovered and transferred outside the facility, then you must report the annual quantity of CO₂, in metric tons CO₂, that was recovered and transferred outside the facility under subpart PP of this part.” Finally, if 100% of the CO₂ from an AGR unit is recovered and transferred outside of the facility, then you must still report CO₂ emissions from the AGR unit under subpart W, even though the value reported would be 0 metric tons.

Effective January 1, 2025, 40 CFR 98.233(d)(11) includes provisions describing how to calculate emissions if the AGR is routed to a vapor recovery system. The revision allows reporters who are recovering CO₂ but not transferring it outside the facility to subtract those emissions from the total AGR emissions reported under Subpart W. If an AGR’s CO₂ emissions are recovered and transferred outside the facility, you should continue to calculate emissions as described earlier in this response. In addition, effective January 1, 2025, there is no longer a requirement to indicate whether any CO₂ emissions from the acid gas removal unit are recovered and transferred outside the facility. Instead, 40 CFR 98.236(d)(1)(iv) requires an indication of whether the AGR was routed to a vapor recovery system and if so, whether it was routed to that vapor recovery system for the entire year or only part of the year. Finally, note that while 40 CFR 98.236(d)(1)(iv) no longer specifies that reporting under Subpart PP is required, 40 CFR 98.232(l) does continue to state, “You must report under subpart PP of this part (Suppliers of Carbon Dioxide), CO₂ emissions captured and transferred off site by following the requirements of subpart PP.”

With regards to acid gas injection wells and subparts PP and UU, please see the response to EPA-HQ-OAR-2009-0923-0582-31 in the Response to Comments (pages 1474 - 1476) https://www.regulations.gov/document?D=EPA-HQ-OAR-2009-0923-3608.