Q546. Can facilities performing on-site acid gas injection estimate their emissions downward according to the provisions in 40 CFR 98.233(d)(11)?

A546. Until December 31, 2024 (i.e., through Reporting Year 2024), reporters performing on-site injection of acid gas may not adjust emissions downward. 40 CFR 98.233(d)(11) clearly states that you may only adjust emissions estimates downwards for emissions recovered and transferred outside the facility.  However, effective January 1, 2025 (i.e., beginning with Reporting Year 2025), 40 CFR 98.233(d)(11) describes how to calculate emissions for any AGR routed to a vapor recovery system, regardless of whether the recovered gas is transferred outside the facility, injected underground, or sent elsewhere in the facility (e.g., routed back to the process). The final provisions require the reporters to determine emissions from the vent prior to the vapor recovery system and then adjust those emissions to only report the emissions that are not recovered and are released directly to the atmosphere. The revised provisions in 40 CFR 98.233(d)(11) for calculation of emissions from AGRs routed to vapor recovery systems are similar to the provisions for dehydrators and atmospheric storage tanks routed to vapor recovery systems.