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Comment 9 for Public Workshop to Discuss Potential Revisions to GHG Mandatory Reporting Regulation (mrr-2014-ws) - 1st Workshop.
First Name: Milan
Last Name: Steube
Email Address: milans@cox.net
Affiliation:
Subject: 95153(y)(2)
Comment:
I suggest an option be added to 95153(y)(2) to allow the use of EPA's Tier 3 methodology to calculate emissions from the combustion of non-pipeline quality natural gas at onshore petroleum and natural gas production facilities. The requirement to use the methodology currently specified in 95153(y)(2) is a result of CARB's adoption of EPA's prescribed Subpart W methodology at 98.233(z) for combustion equipment located on or associated with a single well pad (e.g., portable equipment used in association with well work or a boiler serving a single well pad) as the required methodology for all facility equipment combusting non-pipeline quality natural gas. But because CARB interprets the definition of an onshore petroleum and natural gas production facility more broadly than EPA does in its Subpart W regulation (i.e., CARB includes equipment associated with multiple well pads), the MRR requires use of the 95153(y)(2) methodology for sources that use the Tier 3 methodology for reporting to EPA. This causes additional work on the part of reporters as well as confusion and unnecessary inconsistencies in CARB vs. EPA reporting. In addition, it introduces uncertainty in the calculation by requiring the operator to specify a value of "n", i.e., the "fraction of gas combusted".
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Date and Time Comment Was Submitted: 2014-06-23 13:09:15
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