Q522. Are LNG storage sites located adjacent to subpart D facilities under “common control” required to report emissions under the subpart D “facility” or should the facility report the emissions as a separate subpart W facility?

A522. Based on the information provided, the questioner would report as a single facility under 40 CFR 98. The single facility would be required to report emissions separately for subparts C, D and W in the EPA electronic greenhouse gas reporting system (e-GGRT). In regard to specific sources, subpart W requires the reporting of emissions from compressor venting, equipment leaks, and flares for reporting through RY2024. Beginning in RY2025, subpart W requires the reporting of emissions from compressor venting, equipment leaks, flares, other large release events, blowdown vent stacks, acid gas removal unit vents and nitrogen removal unit vents, and crankcase vents, as required by 40 CFR 98.232(g)(1) through (11  ) according to the calculation procedures outlined in 40 CFR 98.233. Additional applicable emissions are to be reported under subpart D according to the methods described in subpart D. Finally, stationary combustion emissions are to be reported under subpart C