EPA evaluates ethanol as GHG source category

By Kris Bevill | January 04, 2010
The U.S. EPA's decision to require thousands of industrial facilities to begin reporting greenhouse gas (GHG) emissions in 2010 created much confusion in the ethanol industry as producers tried to determine if their facilities would be affected by the rule. The EPA's final rule states that any facility that emits more than 25,000 tons per year of carbon dioxide equivalent (CO2e) from stationary combustion sources is required to report emissions to the EPA. However, initial reports that ethanol had been omitted from the EPA's list of source categories led some producers to believe they had been exempted from the reporting requirements.

During a Nov. 19 training session conducted by the EPA for ethanol industry members, agency officials clarified that ethanol was only temporarily exempted as a source category while it continues to review industry practices, specifically those including co-location with landfills. The 11 source categories under review, including ethanol, are expected to be source categories in the future, according to the EPA, and officials made clear to producers that if they do not have to report emissions in 2010, they should reassess the rule for 2011 as they will probably be added to the list of source categories for that year.

It remained unclear in mid-December exactly how many ethanol facilities will be required to report emissions in 2010. Estimates ranged from just 84 facilities to nearly all 184 plants. The EPA created an online estimating tool to aid in determining if specific facilities would be required to participate and provided calculations that determine what stationary combustion units will emit 25,000 tons of CO2e annually during its training session. Trigger amounts for various units include:
>A coal-fired unit that uses 10,800 tons of fuel annually
>A fuel oil unit that uses 2.3 million gallons of fuel annually
>A natural gas unit that consumes 460 million cubic feet of fuel annually

Producers who determined their facilities met one of the 25,000 tons of CO2e triggers were required to begin data collection using the best available monitoring methods on Jan. 1. By March 31, all participants must begin using the EPA's required monitoring methods. Data collection must be complete at the end of 2010, certificates of representation need to be filed with the EPA by Jan. 30, 2011 and 2010 emissions reports are due on March 31, 2011.

During the ethanol-specific training session, several questions were posed to the EPA on the use of flow meters as a method of calculating GHG emissions. While all emissions from stationary combustion sources must be accounted for, EPA officials confirmed that there are provisions in the rule that allow standard billing meters to be used to determine the amount of gas used and GHG emissions can be calculated based upon those readings. Because of that provision, producers are not required to install flow meters on every stationary gas source, because the billing meter will measure the intake of gas.

Additionally, direct emissions of CO2 into the atmosphere as a result of the ethanol fermentation process will not have to be reported, according to EPA officials. There is no methodology for reporting emissions from fermentation, so the only instance in which a producer would be required to report those emissions would be as a supplier of CO2either via sequestration or by transferring it to a facility off-site. If the ethanol producer utilizes the CO2 for an on-site process, it will not be required to include those CO2 emissions in its report.

To monitor the EPA's assessment of ethanol as a source category for GHG emissions reporting, visit www.epa.gov.