Kim Dirks Tyson Foods, Inc.

Transcription

1 Kim Dirks Tyson Foods, Inc.

2 Annual reporting of greenhouse gas (GHG) emissions to USEPA is now a regulatory requirement Several deadlines to be met in 2010 if this applies to you First report is due March 31, 2011 for the 2010 calendar year

3 CO 2 (carbon dioxide) CH 4 (methane) N 2 O (nitrous oxide) Fluorinated GHGs - HFCs (hydrofluorocarbons) - PFCs (perfluorocarbons) -SF 6 (sulfur hexafluoride) - Other fluorinated gases (see definition in 40 CFR 98.6) The sum of these, factoring in their global warming potential (GWP), equals CO 2 e (CO 2 equivalent)

4 Owners and operators of any facility that contains a source category listed in the regulation

5 Any physical property, plant, building, structure, source, or stationary equipment located on one or more contiguous or adjacent properties in actual physical contact or separated solely by a public roadway or other public right-of-way and under common ownership or common control, that emits or may emit any greenhouse gas.

6 1. 17 all-in source categories (Table 1) 2. 7 source categories with emissions of 25,000 mtpy CO 2 e (Table 2) 3. Stationary combustion units with emissions of 25,000 mtpy CO 2 e (Table 3) 4. Suppliers of fossil fuels (Table 4) 5. Suppliers of industrial GHGs (Table 5)

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12 USEPA has an Applicability Tool at s/ghg-calculator/index.html USEPA Source Category Information Sheets at s/ghg_infosheets.html Default CO 2 emission factors and high heat values for various types of fuels (Table C-1)

13 If you only burn natural gas, to reach 25,000 metric tons of CO 2 e you would need to burn almost 459 MMCF of gas in a year This equates to running more than 50 MMBTU per hour, 24 hours a day, for 365 days Note that CO 2 emissions from biomassderived fuels, e.g. biogas or rendered fat, are not counted for threshold determination purposes (CH 4 & N 2 O still apply)

14 A facility burns: a. 300,000,000 scf of natural gas b. 250,000 gallons of #2 fuel oil c. 200,000,000 scf of biogas d. 10,000 gallons of tallow Does the facility trip the 25,000 metric tons of CO 2 e threshold?

15 Formula: CO2, CH4, or N2O (as metric tons per year CO2e) = Annual fuel use x HHV x CO2, CH4, or N2O emission factor X GWP Example for natural gas combustion: HHV = 1.028E 3 MMBTU/scf CO2 emission factor = kg CO2/MMBTU CH4 emission factor = 1.0E 3 kg CH4/MMBTU N2O emission factor = 1.0E 4 kg N2O/MMBTU GWP = 1 for CO2, 21 for CH4, and 310 for N2O CO2 metric tons per year = 300,000,000 scf x 1.028E 03 MMBTU/scf x kg CO2/MMBTU x 1 metric ton/1000 kg x 1 GWP = 16,351 CH4 metric tons per year = 300,000,000 scf x 1.028E 03 MMBTU/scf x 1.0E 3 kg CH4/MMBTU x 1 metric ton/1000 kg x 21 GWP = 6 N2O metric tons per year = 300,000,000 scf x 1.028E 03 MMBTU/scf x 1.0E 4 kg N2O/MMBTU x 1 metric ton/1000 kg x 310 GWP = 10 Calculation summary: Fuel CO2 CH4 N2O Natural gas 16, #2 Fuel oil 2, Biogas 8, Tallow 89 <0.1 <0.1 CO2e tons 18, Remember, CO2 from biomass based fuels is not included when determining if you exceed the 25,000 mtpy threshold Metric tons applicable to threshold = (18,903 mtpy CO2) + (19 mtpy CH4) + (49 mtpy N2O) = 18,971

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17 Start gathering data January 1, 2010, e.g. fuel usage Develop a monitoring plan by April 1, 2010 Install monitoring equipment (as applicable) by April 1, 2010 unless extension petition filed with USEPA by January 28, 2010 Calibrate meters (as applicable) by April 1, 2010 Prepare a Document of Agreement granting signatory authority Prepare and submit a Certificate of Representation identifying the representative for the facility at least 60 days prior to March 31, 2011 Submit first report by March 31, 2011

18 Depends on several factors, including equipment heat input, what is used for fuel, and what other air emission programs you are regulate under

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20 Tier 1 uses emission factor, annual fuel use, and default high heating value (HHV) Tier 2 uses emission factor, annual fuel use, and measured HHV Tier 3 uses annual fuel use and measured carbon content of fuel Tier 4 uses continuous emission monitoring system (CEMs) data Need to closely review your individual circumstances, but Tier 1 and Tier 2 calculation methods will be most common

21 If a facility has a billing meter for natural gas distributed to the combustion units throughout the facility, and if these combustion units also have their own meters, is there an obligation under the rule to use the individual unit meters and with this the more stringent calibration requirements for each meter? You would not be required to use the individual unit meters provided you qualify to report under either 40 CFR 98.36(c)(1) (i.e., aggregation of units) or 40 CFR 98.36(c)(3) (i.e., common pipe configuration). However, you must use the highest applicable Tier method to calculate emissions from all of the grouped combustion units. Is there a recurring fuel flow meter calibration requirement for Tier 1 and Tier 2 units? EPA does not intend for the calibration requirements of 98.3 (i) to apply to any units where the rule allows the use of company records to quantify fuel usage or other parameters. Therefore, initial and ongoing calibration requirements do not apply to units using Tier 1 and Tier 2, or to solid fuel-fired units using Tier 3. Although there are no specific calibration requirements for Tier 1 and Tier 2, your GHG monitoring plan must include descriptions of the procedures and methods used for quality assurance, maintenance, repair of all flow meters and any other instrumentation used to measure fuel consumption. For additional information on the content of the GHG Monitoring Plan, please see 40 CFR 98.3(g)(5) and Section M.2 in the preamble. Ref: USEPA s Frequently Asked Questions: Mandatory Reporting of Greenhouse Gases Rule

22 If you are only reporting stationary fuel combustion sources, there are special provisions for 2010, e.g. abbreviated reporting s/ghgrulemaking.html Keep records for three years Be prepared to show why you didn t have to report May have to file separate regional or state reports

23 If annual reports show CO 2 e <25,000 metric tons per year for five consecutive years If annual reports show CO 2 e <15,000 metric tons per year for three consecutive years If you shut down all processes, units, operations, etc. covered by the rule Notify USEPA

24 Questions?