By Robynn Andracsek, P.E., Contributing Editor, and Mary Hauner-Davis, Burns & McDonnell
The Environmental Protection Agency’s mandatory greenhouse gas (GHG) reporting rule was issued Sept. 22, 2009 and this year is the first reporting year. The bottom line is that if you are subject to acid rain reporting or if you have combined heat input of 30 MMBtu/hr, you are subject to this rule, but many other applicability criteria exist.
Do you know if the rule applies to your facility? If so, are you ready to comply? Although the first reporting deadline isn’t until March 2011, you must start monitoring emissions in January 2010 and have your monitoring plan in place by April 1.
EPA advertises that this “comprehensive, nationwide emissions data will help in the fight against climate change.” However, the rule entails reporting only and contains no GHG limits or control requirements. At least 10,000 facilities will be required to report their greenhouse gas emissions under this rule. If you haven’t read all 700 pages and you are strictly an electric utility, you probably need to read only a couple of subparts: A, C and D. If your company is also considered a “supplier” of coal, natural gas, oil or even CO2 (for enhanced oil recovery), you should take a look at other pertinent subparts. (EPA’s applicability tool can be found online at http://www.epa.gov/climatechange/emissions/GHG-calculator/index.html.)
Regardless of the amount of carbon dioxide equivalents (CO2e) that an electrical generator emits, all facilities that report CO2 emissions year-round through the acid rain provisions (40 CFR part 75) are also required to report greenhouse gas emissions under this program. Other source categories need to report only if their emissions exceed actual (not potential) emissions of 25,000 metric tons of CO2 equivalents per year. You might recognize the 25,000 metric tons as the same threshold for the proposed CO2 Prevention of Significant Deterioration (PSD) tailoring rule. Reporting for electric utilities is fairly straightforward: Ongoing use of already in-place continuous emission monitors data for CO2 emissions and fairly easy calculations for methane and nitrous oxide. If your unit happens to co-combust biomass, however, you will need to do a bit more calculations and report these emissions separately.
Other combustion units that might be on-site at your facility are not excluded, unless they are for emergency purposes, such as an emergency generator or fire pump. Space heaters, auxiliary boilers and other non-mobile, non-emergency combustion sources do need to be included, following calculation methods (four different tiers) in Subpart C.
In addition to the usual EPA requirements of records and signing for verification, each facility needs to have its own monitoring plan. This is the written plan that must be on-site in case you are ever audited by the EPA under this rule. It does not actually need to be submitted. This plan will contain information about who, what, why, when and how the greenhouse gas reporting rule is being implemented at the facility. The good news? This plan may reference existing documents such as continuous emissions monitors (CEMs), relative accuracy test audit (RATA) stack test results, maintenance records and calculation spreadsheets, and it may be electronic.
Just because you currently report CO2 under acid rain doesn’t mean you are already set for this new rule. There likely will be additional records to keep, or at least organize, to comply with this rule. You need to develop your monitoring plan to understand what records you will need to keep, including any compliance testing and maintenance that might be required. The reporting required under this rule is distinct and separate from the CO2 emission reporting you might do under acid rain. In addition, emissions are reported in different units (short tons under acid rain and metric tons under the GHG reporting rule).
So, for now, your best preparation would be to (1) determine if the rule applies to your facility, (2) determine how you will monitor greenhouse gas emissions and (3) develop your monitoring plan so you can start following it now as opposed to writing up what you may or not have done to comply with the rule.
Some inherent double-reporting of emissions exists in the program. Suppliers of fossil fuels and industrial GHGs must report emissions from the downstream use of their product by the end user. End users (power plants and industrial facilities) also must report the amount of product they actually combust or use. This double counting allows EPA to exempt small emitters, such as owners of commercial buildings and individual car and home owners.
On a positive note, the rule’s requirements currently do not have to be incorporated into your facility’s Title V permit. Additionally, EPA states in the preamble that the rule does not render GHGs “PSD regulated pollutants” or contradict the EPA’s PSD interpretive memo that GHGs are not “regulated pollutants.” This Bush-era memo is currently under “reconsideration” (translation, soon to be reversed). However, as of Dec. 7, 2009, GHGs are considered “criteria pollutants,” a subtle but critical difference. So for now, this rule is just one more record keeping and reporting requirement you need to meet.