Q617. Does EPA offer guidance on how to estimate a worst case scenario for GHG emissions from transmission storage tanks for purpose of determining applicability?

A617. EPA does not have sufficient data to characterize an average emissions factor for scrubber dump valve leakage through transmission storage tanks.  Therefore, the calculation tool does not have this source built in. Hence, it is left to the facility to consider whether this is a significant source, including use of an acoustic detection device that has algorithms to quantify through-valve leakage from scrubber dump valves to determine applicability.