October 28, 2009
Last week I attended a webinar on the EPA’s mandatory reporting of greenhouse gases (GHGs) rule, hosted by U.S. Steel and Wenck. The presenters did a great job of highlighting all of the important points from the rule, and the areas that could be confusing. Here are my top 10 most important points that processing facilities should be aware of:
- You may or may not have to report emissions, depending on the tiered source categories that apply to your facility and the amount of GHG your facility emits. The first thing to do is determine which source category you fall under using the flow chart and tables contained in the General Provisions for the EPA’s Mandatory Reporting of Greenhouse Gases.
Note that facilities with source categories in Table 1 will always need to report, regardless of any other factor.
- All facilities need to calculate GHG emissions. Even if you don’t need to report because you fall below the 25,000-metric ton threshold, you must have documentation on-site that shows you have accurately calculated your total GHG emissions.
- The following gases must be included in greenhouse gas calculations: carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFC), perfluorochemicals (PFC) and sulfur hexafluoride (SF6), as well as other fluorinated gases (e.g. nitrogen trifluoride and hydrofluorinated ethers).
- All gases will be reported in metric tons in CO2 equivalence (CO2e), using a conversion factor based on the global warming potential (GWP) of each gas:
Source: U.S. Energy, Wenck
- Reporting is due to start on January 1, 2010. However, if you are not ready to start on this date because metering and monitoring equipment is yet to be installed, you can apply for an extension, which allows you to begin monitoring on April 1 2010. Applications for an extension must be received by January 30, 2010.
- Reports for 2010 are due March 31, 2011.
- Some facilities are currently exempt from reporting, for example food processors, wastewater treatment plants and ethanol producers. However, all “exempt” facilities are still accountable for their GHG combustion emissions under the tier 3 classification. This is the example given during the webinar:
Source: U.S. Energy, Wenck
- One of the most confusing elements of the rule surrounds emissions from biomass. It is true that CO2 emissions from biomass combustion are exempt, but the other greenhouse gases that are emitted are not — usually small amounts of nitrous oxide and methane gas.
- After a facility starts reporting, it must continue to do so even if it falls under the 25,000-metric ton threshold. A facility can exit the program if it reports five consecutive years of GHG emissions under 25,000 metric tons or 3 consecutive years of emissions under 15,000 metric tons.
- Facilities do not need to report emissions from fleet vehicles, as this will be accounted for through upstream reporting by suppliers of petroleum products and coal-based liquid fuels.
- BONUS FACT: The EPA will do spot checks and take enforcement for non-compliance.
The webinar provided by U.S. Energy and Wenck is just one of many services being provided to supply processors with the resources they need to comply with this new rule. For example, Fluid Components International (FCI) has launched a GHG Reporting Fast Track Initiative to assist with the gas flowmeters required to measure GHGs. Also, look out for FCI’s “By The Book” article on this subject in our Januray/February print edition.
Here are some more resources that will help you figure out what is required of your facility:
- EPA Mandatory Reporting of Greenhouse Gases Rule home page.
- EPA Greenhouse Gas Equivalencies Calculator.
- EPA GHG Reporting Facility Applicability Tool.
- Information Sheets for Each of the Source Categories Covered in the Rule.
- The four webinar presenters are happy to answer any questions you have. Their contact details are:
Bill Brown [email protected].
Beau Griffey [email protected].
Denise Kazmierczak [email protected].
Mike Shoemaker [email protected].
The impact that this rule will have on industry is a double-edged sword: The EPA will get data that is vital to future Clean Air Act and cap-and-trade legislation, but the burden put onto companies is obvious. By implementing a threshold that removes the bottom 20 percent of emitters from the rule, the smallest companies will avoid some of the costs associated with reporting. But the effect on the remaining 80 percent of industry is yet to be seen.
What does the EPA’s mandatory reporting of GHGs rule mean for your facility? Drop me a line at [email protected].