Mandatory Greenhouse Gas Reporting Rule. Mr. Charles Frushour U.S. EPA Clean Air Markets Division EPRI CEM User Group Meeting Cleveland, Ohio May 2010. Disclaimer.
Mr. Charles Frushour
Clean Air Markets Division
EPRI CEM User Group Meeting
On October 30, 2009, prompted by a Congressional appropriations bill, EPA published a final rule, 40 CFR Part 98, which requires the reporting of greenhouse gas (GHG) emissions from various industries in the American economy, including electricity generation, petroleum refining, cement manufacturing, and many others. Suppliers of coal-based liquid fuels, petroleum products, natural gas and natural gas liquids are also required to report under this rule.
The vast majority of the reportable GHG emissions under Part 98 are from stationary fuel combustion sources such as boilers, combustion turbines, engines, incinerators, space heaters etc. Owners and operators are required to calculate and report annual emissions of CO2, CH4, and N2O from these sources, using the methods specified in the rule.
Note: The proposed requirement to report sulfur hexafluoride (SF6) emissions from electrical equipment (Subpart DD) was not finalized in the October 30, 2009 rule. On April 12, 2010, a supplement to the text of the original Subpart DD proposal was published in the Federal Register (See 75 FR 18651). The substance of the supplemental proposal is embedded in the preamble, and addresses the definition of a “facility” with respect to Subpart DD.
In Part 98, the term “source category” generally refers to a specific industry (e.g., electricity generation, petroleum refining, etc.)
The GHG emissions calculation and reporting requirements for each source category are presented in a separate “Subpart” of Part 98. For example, the requirements for electricity generation are found in Subpart D.
Although stationary fuel combustion (Subpart C) is classified as a separate source category, it is actually a “cross-cutting” category, common to many other subparts.
A facility can and will most likely be comprised of multiple source categories. For instance, a facility may have both electricity generation (Subpart D) and stationary fuel combustion units (Subpart C) within its boundaries.
Q: May the DR assign agents to submit the Part 98 GHG emissions reports on his behalf, as is allowed for Part 75 electronic reporting?
Q: How long must I retain records under Part 98?
A: A minimum of three years--- see §98.3(g).
Q: May I retain records electronically and at an off-site location?
A: Yes, provided the records are readily available for review by inspectors and auditors.
Q: I operate a facility with Acid Rain and/or RGGI units that operate infrequently and the entire facility emits less than 25,ooo metric tons of CO2e on an annual basis. Am I required to report GHG emissions under Part 98?
A: Yes. Acid Rain Program and RGGI units are subject to Subpart D of Part 98, which is one of the source categories that automatically triggers Part 98 applicability, regardless of the facility’s annual GHG emissions. See §98.2(a)(1)(i).
Q: Part 98 exempts “portable” equipment from GHG emissions reporting. How do I determine if my equipment is “portable”?
A: See the definition of “portable” in §98.6. Equipment that resides at the same location (within a facility) for more than 12 consecutive months is not considered to be portable, unless the equipment is designed to be moved from one location to another within the facility.
Subpart C applies:
To the calculation and reporting of GHG emissions from stationary fuel combustion sources (such as boilers, simple and combined-cycle combustion turbines, engines, incinerators, and process heaters).
Subpart C does not apply to:
Subpart D electricity generating units
Emergency generators and emergency equipment
Hazardous waste combustion (unless CEMS are used to monitor CO2 mass emissions)
EPA has clarified in hotline responses that reporting of CO2 emissions from pilots is not required
Q: May I use Tier 2 to calculate CO2 mass emissions if HHV data are available at the required frequency specified in §98.34(a)(2), but the method used to determine the HHV is not one of the methods listed in §98.34(a)(6) ?
A: At the present time, no.
Q: With respect to stationary combustion sources, is “waste oil” considered to be an unconventional fuel, since it is not included in Table C-1?
A: No. For the time being, calculate GHG emissions from the combustion of waste oil using the emission factors in Table C-1 for “Other Oil”.
Q: If I use Tier 1 or 2 to calculate CO2 mass emissions and measure the annual natural gas consumption using a fuel flow meter, does the flow meter have to meet the calibration requirements of §98.3(i)?
A: No. The calibration requirements of §98.3(i) do not apply to Tier 1, which specifies that “company records” are to be used to quantify fuel usage.
Q: If I choose to use the alternative CO2 mass emissions calculation method in §98.33(a)(5) for a non-Acid Rain unit that is subject to CAIR, may I use my Part 75 DAHS to generate a CO2 mass emissions data stream and include it in my quarterly Part 75 electronic data reports ? If so, does this satisfy my Part 98 obligation to report CO2 mass emissions?
A: You may add a CO2 mass emissions data stream to your quarterly Part 75 electronic data reports, even though you are not required to report CO2 mass emissions under CAIR (see the ECMPS instructions for implementing this option, posted on the CAMD website).
However, simply reporting CO2 mass emissions in your Part 75 electronic reports does not satisfy the Part 98 CO2 mass emissions reporting requirements. The cumulative annual CO2 mass emissions from the Part 75 report must be converted from short tons to metric tons and included in the annual Part 98 GHG emissions report. The electronic data system for generating the GHG emissions reports is currently under development.
To apply Part 98 at a typical electricity generating facility: