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Final GHG Reporting Rule Signed (10/05/09)

EPA's final Greenhouse Gas (GHG) Reporting Rule was signed by the Administrator on September 22, 2009.  This massive rule will require a large swath of industrial sources to start reporting GHG emission data as a precursor to other potential GHG regulations and limits.

Despite receiving many comments that there was inadequate time to prepare, with many sources indicating that they do not currently have all the monitoring equipment required by the rule, the Agency is plowing ahead with its intention to require sources to report GHG emissions starting with 2010.  EPA has only minor concessions with a provision that allows the use of “best available monitoring methods” in lieu of the required monitoring methods for January - March 2010.  In limited situations, facilities can request an extension to use best available data beyond March 2010.  Requests for extensions must be submitted within 30 days after the rule becomes effective and such extensions can only allow best available data to be used for the remainder 2010.

As a whole, the final rule remains similar to the original proposal (see previous article).  Revisions to the GHG reporting rule include:

  • For combustion sources, exemptions have been added for unconventional fuels, flares, hazardous wastes, and emergency equipment.  Options allow aggregate reporting of emissions from smaller units. Monitoring options changed or added and fuel sampling and analysis revised for some subparts. More data reporting requirements for some sources “to allow EPA to verify reported emissions.” Calibration requirements added for various monitoring components including a 5% accuracy specification for flow meters. Provisions added to allow facilities to exit the program if the emissions are < 25,000 tonnes CO2e/year for five years or < 10,000 tonnes CO2e/year for three years. Recordkeeping requirements reduced from five to three years.

  • Provisions added for revising annual GHG reports to correct errors.

Additionally, EPA has deferred finalizing the subparts for:

  • Electronics manufacturing Oil and natural gas systems Ethanol production SF6 from electrical equipment Fluorinated GHG production Underground coal mines Food processing Wastewater treatment Industrial landfills Coal Suppliers

  • Magnesium production

These sources will not be required to report under GHG rule until the respective subparts are promulgated.  EPA has provided no timeline for finalizing these subparts.Electronic reporting will be required for all sources with the first report for 2010 due by March 31, 2011.  EPA has yet to provide information regarding the required format or submission process (anticipated to be similar to the XML reporting requirements recently applied to Part 75 affected sources.  As included in the original GHG reporting rule proposal, facilities with only stationary combustion sources can for 2010 only, submit an “abbreviated GHG report” according to 40 CFR 98.3(d).For electric utilities sources that report emissions under Part 75, there will be no new monitoring but new reporting requirements (and calculation of estimated N2O and CH4 emissions using conservative defaults) under the new program.  However, other sources at the facility may require monitoring. Most large combustion sources, particularly those with any existing CEMS (even concentration analyzers required by regulation, e.g., Part 60, for other pollutants), must use a CO2 and flow monitoring to measure mass emissions.  For combustion units required to install new CEMS equipment, alternative options (i.e., lower tiers) can be used in 2010 if additional time is needed to upgrade. One problematic issue with the rule is that once a facility is determined to be affected under the GHG reporting rule, the CO2 emissions for all sources and equipment (for which monitoring requirements are established) at the facility, regardless of the size of the individual sources.  In other words, there is no de minimus reporting threshold.

For assistance with GHG reporting rule issues, please contact Steve Norfleet at (919) 791-3123 or norfleet@rmb-consulting.com.

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Last Revised: February 05, 2012