In May we published an article on EPA’s proposed Greenhouse Gas (GHG) Reporting Rule. The final Rule was signed on September 22, 2009, and will go into effect 60 days after Federal Register publication. It applies to an estimated 10,000 facilities in the 50 states, the District of Columbia and U.S. possessions and territories (i.e., Guam, Puerto Rico, Virgin Islands, American Samoa).
The final Rule requires facilities and suppliers of fossil fuels or industrial GHGs that emit 25,000 metric tons or more per year of GHGs and manufacturers of vehicles and engines to submit annual reports to EPA. The Agency equates 25,000 metric tons of CO2-equivalent to the emissions from 131 rail cars of coal, 58,000 barrels of oil or 4,600 passenger vehicles or the annual energy use of 2,200 homes.
GHGs include carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFC), perfluorocarbons (PFC), sulfur hexafluoride (SF6) and other fluorinated gases including nitrogen trifluoride (NF3) and hydrofluorinated ethers (HFE). Covered facilities must begin monitoring and recordkeeping on January 1, 2010, and submit the first annual report to EPA by March 31, 2011 for the 2010 calendar year. Vehicle and engine sectors must submit reports beginning with model year 2011.
If required monitoring equipment cannot feasibly be obtained and installed before January 1, 2010, the Rule allows use of emission factors or engineering estimates only through March 2010. Extensions are possible, but none past 2010. Reporting must be electronic and to a central EPA registry, with facilities self-certifying their data. A report can be revised by the facility within 45 days of either internal discovery of an error or notification by EPA of an error.
“Table 1” facilities must report emissions from any listed source including aluminum and cement production, ammonia manufacturing, electricity generation, agricultural manure management, municipal solid waste landfills that accepted waste after 1979, petrochemical production and petroleum refineries if they meet the 25,000-ton threshold.
“Table 2” facilities emit 25,000 metric tons or more of CO2-equivalent in combined emissions from stationary fuel combustion, miscellaneous carbonate use and seven other source categories. These include production of ferroalloys, glass, hydrogen, iron, steel, lead, pulp, paper and zinc.
“Table 3” facilities may meet the threshold due to stationary combustion sources such as boilers, stationary engines, process heaters, combustion turbines or other fuel combustion equipment. EPA specifies that if the maximum rated heat capacity for all stationary fuel combustion equipment is less than 30 million Btu per hour, the facility is presumed to emit less than 25,000 tons and does not have to calculate or report emissions.
“Table 4” suppliers of fossil fuels are producers, importers and exporters of petroleum products and coal-based liquid fuels. They must report the amount of fuel they “supply” into the economy each year and the emissions associated with complete oxidation of those fuels. There is no threshold quantity for natural gas suppliers, fractionators (includes ethane, propane, normal butane, isobutene or pentanes) and local distribution companies, so all of those are covered. However, companies that operate interstate or intrastate pipelines are not part of this source category.
“Table 5” suppliers of industrial GHGs are producers, importers and exporters of industrial GHGs (fluorinated gases, N2O, CO2). If the cumulative amount of GHGs they supplied meets the 25,000-ton threshold, they must report the annual volume of GHGs supplied into the economy and the emissions associated with complete release of the product(s).
A covered facility can stop reporting after three consecutive years of emissions below 15,000 tons, five consecutive years of emissions below 25,000 tons or if the GHG source shuts down. However, regardless of reporting or operating status, reports must be retained for at least three years in electronic or hard-copy format.
In addition to FAQs, EPA has published detailed information sheets for each sector and an “applicability tool” that can be used to screen your facility for coverage.
Facilities not covered?
Though initially included, certain facility categories ended up exempt from reporting under the final Rule. These include electronics manufacturing, ethanol production, fluorinated GHG production, food processing, industrial landfills, magnesium production, oil and natural gas systems, SF6 from electrical equipment, underground coal mines, wastewater treatment and coal suppliers. However, stationary fuel combustion sources at ethanol production and food processing facilities are subject to reporting if emissions exceed the 25,000-ton threshold.
Dr. Scott Harris is the Global Risk Manager for IESO, LLC. His experience covers over 27 years of Environmental, Health and Safety Management in Federal and State government, consulting, general industry and University instruction. He received his Ph.D. in Environmental Science, with a specialization in Disaster and Emergency Management, from Oklahoma State University, and holds degrees in Geology (B.S.) and Public Health (MPH) from Western Kentucky University. Before joining IESO Scott was a Federal On-Scene Coordinator for EPA Region 6 and a member of their Emergency Readiness Team. He held DOD “Top Secret” and DOE “Q” security clearances, and directed multi-agency emergency response, planning and recovery activities for chemical, biological and radiological releases and exercises within the five-state region.
Last 6 posts by admin
- IESO Presenting at Clean Gulf Conference - October 26th, 2011
- The Free "OSHA in Healthcare" Webinar - October 14th, 2011
- IESO Presenting at AOHP 2011 Conference - September 26th, 2011
- Arc Flash Train-the-Trainer Course - September 13th, 2011
- IESO Presenting at 2011 PureSafety Conference - August 2nd, 2011
- IESO Presenting at the 2011 TN Safety Congress - July 25th, 2011