Navigating the GHG Reporting Maze

Know what to expect and how to prepare for upcoming greenhouse gas emissions regulations.
By Rich Hovan | March 10, 2011

Greenhouse gas (GHG) reporting rules vary region to region, state by state,  and sometimes, even town to town. To make matters more confusing, the U.S. EPA’s national GHG reporting requirements are in flux and will continue to change over the coming years. Because these reporting rules lay the groundwork for upcoming GHG emissions-control regulations, including common industrial emissions, it’s important to have some foresight into what an ethanol producer can expect and what it can do now to prepare for future reporting requirements.

Off the Hook, for Now

The EPA mandatory GHG reporting rule, 40 Code of Federal Regulations (CFR) Part 98, as first promulgated on Oct. 30, 2009, was estimated to cover about 85 percent of total U.S. emissions. It applied to more than 10,000 facilities in 31 source categories, such as iron and steel, glass, cement, engines, pulp and paper. Coverage of certain industrial sectors, however, was postponed to allow the EPA time to consider additional commentary and options. 

Source catagories not included in the rule for 2010 reporting include: Electronics manufacturing, ethanol production, florinated GHG production, food processing, magnesium production, oil and natural gas systems, sulfur hexafluride for electronic equipment, underground coal mines, industrial landfills, wastewater treatment and suppliers of coal.

Stationary Source Requirements

Leaders for facilities not yet required to follow the rule for 2010 should be aware, however, that they might still be required to report their GHG emissions on stationary combustion sources, if the emissions could exceed 25,000 metric tons of CO2 equivalent per year (mt CO2e).

Facilities that contain stationary fuel combustion units, but do not contain a combustion source in any other category covered by the rule, are not required to submit a report if their aggregate maximum rated heat input capacity from all stationary fuel combustion units is less than shown on the accompanying table. No industry, manufacturer or commercial application is exempt from stationary combustion-source reporting if they surpass the measurements in the table on page 72.

So, what exactly are stationary combustion fuel sources? They’re devices that burn any solid, liquid or gaseous fuel generally to produce electricity, steam, useful heat or energy for industrial, commercial or institutional use, or to  reduce the volume of waste by removing combustible matter.

These devices include, but are not limited to:
•    Boilers
•    Combustion turbines
•    Stationary internal combustion engines
•    Incinerators
•    Process heaters

The rule excludes flares (unless otherwise required by another sub-part), portable equipment, emergency generators, emergency equipment, agricultural irrigation pumps and combustion of hazardous waste (except for cofired fuels).

Electricity generating units that are subject to the EPA’s Acid Rain Program (40 CFR Part 75) or that report CO2 emissions year-round through Part 75 are covered under 40 CFR Part 98, Sub-part D (Electricity Generation).

If a facility contains only general stationary fuel combustion sources, in lieu of annual reporting, it can submit an abbreviated report for 2010 if the GHG emissions from existing facilities were in operation as of Jan. 1. The abbreviated report will include only total GHG emissions aggregated for all stationary combustion units. If this is the case, it must report annual carbon dioxide (CO2), methane (CH4) and nitrous oxide (N2O) emissions from each fuel combustion unit. For each unit, CO2, CH4 and N2O emissions must be reported separately for each type of fuel combusted, including biomass fuels. In addition, these facilities must report any CO2 emissions from sorbent use in air-pollution control equipment.

Monitor and Report

Emission sources subject to the GHG reporting rule for 2010 can use a hybrid approach to GHG monitoring.

Certain units already are required to collect and report emission data using continuous emissions monitors (CEMS) under other EPA programs such as the Acid Rain Program, New Source Performance Standards, National Emission Standards for Hazardous Air Pollutants and state implementation plans. CEMS use is optional for other source categories not subject to these EPA programs.

The EPA is allowing sources to use a source category-specific GHG calculation method. Monitoring is based on other parameters and fuel use, which might vary given the specific source category, such as mass balance, site-specific emissions factor or default emissions factor.

All sources have to monitor emissions effective Jan. 1. Mandatory reporting of all 2010 GHG emissions will need to follow the design format stated in 40 CFR Part 98 by March 31.

Author: Rich Hovan
Manager, Rockwell Software Environmental Solutions
(512) 438-1598
rahovan@ra.rockwell.com