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Greenhouse Gas Mandatory Reporting Rule Update (12/08/09)

Greenhouse gas (GHG) emissions reporting begins in 2010.  The dates listed below are critical to complying with the mandatory reporting rule.  Notwithstanding the approach taken, greenhouse gas monitoring must begin by January 1, 2010.  Each facility should evaluate existing monitoring procedures and documentation to determine if extensions for the installation of monitoring equipment will be necessary.  If a facility will not be able to fully comply with the GHG requirements by April 1, 2010, a request for extension (including documentation of why the monitoring equipment cannot be obtained or installed) must be submitted by January 28, 2010.  Flow meters and other devices that measure data used to calculate GHG emissions should be calibrated to an accuracy of 5 percent by January 1, 2010.  If best available monitoring methods are used for the first quarter of 2010, the source must comply with the GHG calibration requirements by April 1, 2010.  The GHG Monitoring Plan (which is similar to a Quality Assurance Plan) should be completed by January 1, 2010.  If best available monitoring methods are used for the first quarter of 2010, the source must have the Monitoring Plan completed by April 1, 2010.  When developing the Monitoring Plan, a few special considerations are discussed below.

  • Facilities that contain Part 75 sources must also consider monitoring and calculation procedures for sources and processes that aren’t currently covered by existing Part 75 CEMS requirements (i.e., auxiliary boilers, diesel generators that do not meet the definition of an emergency generator, startup fuel for boilers, sorbent dryers use for fluidized bed boilers).

  • Emergency generators may be exempted only if they meet the 98.6 definition, which will not be the case for all generators that are currently referred to by the utility as “emergency generators”.

  • For Part 75 sources, fuel flow meters and sampling procedures will be needed to quantify startup fuels (e.g., PNG or light oil on a coal-fired unit) for the purposes of calculating methane and nitrous oxide emissions.  (There are not any de-minimis fuel exemptions.)  This may require sources to calibrate and maintain fuel flow meters in addition to the stack CEMS currently being used for Part 75 reporting.

  • Facilities that contain non-Part 75 solid fuel combustion sources may be required to install additional CEMS to comply with Tier 4 reporting.

  • Facilities that contain non-Part 75 combustion sources must include fuel flow monitoring, fuel flow quality assurance, fuel sampling, and fuel analysis procedures for combustion sources.

  • Facilities that contain non-combustion sources must document the quality assurance of flow measurement devices, gas composition monitors, and heating value monitors for sources other than stationary combustion (i.e., flares, catalytic cracking units, sulfur recovery units).

Any facility using “company records” to report GHG emissions must document the procedures that are used to ensure the accuracy of “company records” including calibration procedures and the estimated accuracy of the measurements and the technical basis for estimates.  A facility must be aware that “company records” used for GHG reporting are not simply logs of measured values.

Although use of best available monitoring methods is allowed from January 1, 2010 through March 31, 2010, additional documentation and reporting will be required in the 2010 annual GHG report which must be submitted by March 31, 2011.  In particular, the 2010 GHG report will need to include a written explanation of any changes in emission calculation methodologies implemented during the reporting period, a brief description of each “best available monitoring method” used, the parameter(s) measured using the method, and the time period during which the “best available monitoring method” was used.  A copy of the GHG rule is available from our website FTP library.  RMB has extensive experience in the monitoring and sampling procedures and quality assurance activities incorporated in the GHG rule and is available to discuss the monitoring options for your facility.  RMB can assist your facility in ensuring that source documentation (e.g., Monitoring Plans, calibrations, certifications and reports) incorporate the requirements of the GHG rule within the time constraints of the rule.  For further assistance, please contact Russell Berry at (919) 791-3126, Dru Sanders at (919) 791-3128 or Bethany White at (919) 791-3135.

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Last Revised: February 06, 2012