Q470. Subpart W, via GOADS, requires monitoring of "hours operated" for "natural gas, diesel, and dual-fired turbines". Since emissions are calculated based on fuel use only, why is it necessary to monitor hours operated? For dual-fired turbines, is it necessary to monitor hours operated on each fuel, or just the total?
A470. You must follow the methods in the rule. In response to industry comments regarding burden, EPA finalized requirements to use Bureau of Ocean Management (BOEM) GOADS reporting methods for all offshore facilities under Subpart W. As GOADS is under BOEM jurisdiction, EPA has no authority regarding GOADS guidelines or methods.