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Final GHG Reporting Rule Published (10/30/09)

The Greenhouse Gas (GHG) Reporting Rule was published today (10/30/09) in the Federal Register.  The massive rule will require thousands of industrial sources to start reporting GHG emission data starting in the very near future.  The sources that will shortly need to address the GHG reporting rule include, but are not limited to:

  • Stationary Combustion Sources

  • Electricity Generation

  • Petroleum Refineries 

  • Petrochemical Plants

  • Cement Production

  • Lime and Soda Ash Production

  • Pulp and Paper Production

  • Ammonia Manufacturing Glass Production

  • Fluorocarbon Production

  • Hydrogen Production

  • Metals Refining/Production

  • Acid Production

  • Vehicle Manufacturing

  • CO2 Suppliers

  • Natural Gas Suppliers

  • Waste Landfills

As indicated earlier, EPA is sticking with its irrational decision to require sources to report GHG emissions starting in 2010.  Facilities will need to identify the affected sources to develop monitoring plans, and begin documenting and recording the information required under the rule to monitor GHG emissions.  Once a facility is affected then all sources at that site that are covered by the rule, regardless of size, become affected.  This means that, with a few exceptions, nearly all combustion equipment at the site will require reporting.  In some cases, the rule may allow a source to use existing monitoring equipment for GHG reporting but will require new QA to document the accuracy of the equipment.  In other cases, additional monitoring will be needed, including CEMS for some sources.  Reporting will be required on an annual basis in accordance with a yet to be released format and submission process.  As a minor concession, the rule allows "best available monitoring methods" to be used for the first three months of 2010.  Sources may request an extension to use best available data until the end of 2010 if they can document why the required monitoring equipment cannot be obtained or installed by April 2010.  However, any request for extension must be submitted by January 28, 2010, and the rule requires documentation and description of any changes to the monitoring approach (even "best available").

A copy of the GHG rule is available from our FTP library.   If you have questions regarding the GHG reporting rule, please contact Steve Norfleet at (919) 791-3123 or norfleet@rmb-consulting.com.

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Last Revised: February 06, 2012