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Q470. Is it necessary to monitor of "hours operated" for "natural gas, diesel, and dual-fired turbines" as required in Subpart W via GOADS.

Disclaimer This information is intended to provide general and administrative information about 40 CFR Part 98. It does not represent legal advice. This information does not have legally binding effect or expressly or implicitly create, expand, or limit any legal rights, obligations, responsibilities, expectations, or benefits in regard to any person. Facility owners or operators and suppliers are responsible for determining how they would be affected by the requirements of 40 CFR Part 98.

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.

Updated on January 13, 2012
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