P.O. Box 1276 Westerville, OH (614)

Transcription

1 Applying our technical expertise to a more sustainable world Greenhouse Gas Reporting: More Tips & Tricks Andrew D. Shroads, QEP Regional Director, inc. P.O. Box 1276 Westerville, OH (614) ashroads@scainc.com This presentation is for informational purposes only and is not intended to be relied upon for determination of the requirements for any particular project or need. Appropriate professionals should be consulted for a particular project.

2 GHG Reporting Rule Overview Mandatory Greenhouse Gas (GHG) Reporting, Title 40 of the Code of Federal Regulations, Part 98 (40 CFR 98) Only air rule authorized by an appropriations bill One Stop Shop for GHG reporting: 1. Emissions factors; 2. Computational methods; 3. Missing data computations; and 4. Data quality control/assurance. Includes six GHGs: carbon dioxide (CO 2 ), methane (CH 4 ), nitrous oxide (N 2 O), and sulfur hexafluoride (SF 6 ); and all of the perfluorocarbons (PFC) and hydrofluorocarbons (HFC) ashroads@scainc.com 2

3 GHG Reporting Rule Applicability Who must report? 42 categories for suppliers, industry, agriculture, and utilities EPA may add to the reporting list Two categories of sources: 1. Facilities & suppliers On The List (Table A 3 or A 5) 2. Facilities with 25,000 metric tons (MT) of annual CO 2 equivalent emissions (CO 2 e/year) from sources in Table A 4 What types of facilities are included? Fuel burning equipment, natural gas & petroleum systems, refineries, manufacturing, landfills, acid production Many activities and sources that may not emit air pollution must report GHG emissions (e.g., wastewater treatment, electrical equipment, CO 2 gas suppliers, etc.) ashroads@scainc.com 3

4 GHG Reporting Rule Responsible Official Designated Representative (DR): [ 98.4] Does not have to be same as certified official under Ohio and Federal Air Regulations Can be environmental manager or plant manager VS. Alternate Designated Representative: Backup, in case DR cannot submit report Agent: Agents can submit report on behalf of DR or ADR Use this category for consultants, other environmental staff, and/or corporate environmental staff ashroads@scainc.com 4

5 GHG Reporting Rule Submission Due to the time it takes to add subparts to e GGRT (the reporting program) EPA has delayed certain categories for the 2011 report: 1. If subject only to subparts issued before January 1, 2011, submit the GHG emissions report on March 31 April 2, If subject only to subparts issued in calendar year 2011, submit the GHG emissions report on September 28, If subject to BOTH subparts issued before January 1, 2011 and in 2011, submit an extension notice by April 2, 2012 AND submit the GHG emissions report on September 28, GHG Subparts: I, L, T, W, DD, FF, II, QQ, RR, SS, TT, UU Unless already registered with e GGRT, you must register at least 60 days before a due date! SC&A ashroads@scainc.com 5

6 GHG Reporting Rule Requirements

7 Finding Sources of GHG Review existing air permits Sources emitting carbon monoxide (CO) or nitrogen oxides (NO X ) also emit CO 2 and N 2 O Look for sources burning fuel CO 2, CH 4 and N 2 O are formed during fuel combustion Review purchase records SF 6, PFC or HFC purchases to replace material lost to air Review reporting categories in each subpart of 40 CFR 98 Each Subpart includes equipment required to report Identify all potential sources of GHG, even if not in 40 CFR 98 EPA may add future GHG reporting requirements Information also useful for GHG Tailoring Rule ashroads@scainc.com 7

8 Fuel Burning Thresholds Fuel Combustion: Emissions factors for selected fuels, in metric tons of carbon dioxide equivalent (MT CO 2 e) emissions: Natural Gas: MT CO 2 e/cubic foot #2 Fuel Oil: MT CO 2 e/gallon #6 Fuel Oil: MT CO 2 e/gallon Amount of fuel combusted to generate 25,000 MT CO 2 e: Natural Gas: million (MM) cubic feet/year #2 Fuel Oil: 2,441,223 gallons/year #6 Fuel Oil: 2,212,121 gallons/year All values calculated from 98 Tables A 1, C 1 & C ashroads@scainc.com 8

9 Fuel Burning Grouping Aggregation: [ 98.36(c)] You may group combustion units if all combustion units are 250 million British Thermal Units per hour(mmbtu/hour), use the same fuel(s), and not Tier 4 Report combined emissions from combustion units sharing the same emissions monitor (Tier 4) Report together combustion units sharing a common fuel pipe using applicable calculation Tier for size and type of fuel combusted. Exempt sources are included if on same pipeline! If 95% of shared fuel is used by large combustion units, all GHG emissions can be attributed to the large sources ashroads@scainc.com 9

10 Fuel Burning Tips & Tricks Note on Fuel Combustion: M = thousand (Roman numeral); MM = million Use different calculation methods (Tiers) to estimate GHG emissions from different fuels, even on the same source Always use the lowest Tier (least recordkeeping & calculating) For natural gas burning units <250 MMBTU/hr, use Tier 1 If you receive the heating value (heat generated per amount of fuel burned) or have an Ohio EPA air permit that requires you keep the heating value for the fuel, you must use Tiers 2 or 3 If you have an emissions monitor (CEMS), you must use Tier ashroads@scainc.com 10

11 Other Tips & Tricks Stack Tests: Site specific emissions factor can be developed from stack test for another pollutant. CO 2 emissions are obtained using U.S. EPA Method 3, which is usually conducted during any stack tests to determine CO 2 exhaust gas concentration Record keeping: 98 allows for electronic data storage Must be able to access data during inspection 3 reporting years from report submittal date, (3 previous calendar years and current year) Additional Assistance: The EPA provides an applicability tool at calculator/ ashroads@scainc.com 11

12 Reminders GHG Monitoring Plan Does your plan include a GHG emissions report due date in March or September? Does your plan list the DR by name or by title? Did you calculate your GHG emissions using the methods specified in the plan? Data comparison EPA will compare GHG emissions data with other federal databases and Ohio air emissions data (including fuel use) Values must match or EPA will request clarification ashroads@scainc.com 12