Comment Log Display

Comment Log Display

Below is the comment you selected to display.
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".

Attachment:

Original File Name:

Date and Time Comment Was Submitted: 2014-06-23 13:09:15



If you have any questions or comments please contact Office of the Ombudsman at (916) 327-1266.


Board Comments Home

preload