Mandatory Reporting of Greenhouse Gases Regulation (40 CFR 98): Background, General Requirements, and Timeframes
CES Climate Change Committee
December 3, 2009
Presentation to:
Patrick Nortz, CPG, PE, NTH Consultants, Ltd.
Kathy Gargasz, Lincoln Electric
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Purpose of Presentation on theGreenhouse Gases Regulation
• Why this new rule?
• Overview of greenhouse gases (GHG)
• Who needs to report GHG emissions
• What is required and by when?
• Provide a couple "industry" examples
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What!!! Another Rule? Why?
Per the rule preamble, here are a few reasons:
• Assist US EPA in assessing how to address GHG emissions and climate change under the Clean Air Act
• GHG information will help EPA assess how to address GHG emissions
• Track emission trends
• Improve the U.S. government’s ability to formulate GHG policy
This rule precedes likely requirement for GHG Emissions Controls
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Greenhouse Gas Reporting Rule
• Can I Stop Reporting?– Basic Premise is Once In Always In– Exceptions:
• Less than 25,000 Metric Tons CO2e each year for 5 years
• Less than 15,000 Metric Tons CO2e each year for 3 years
– Once Threshold Reached, Must Report Again
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All right, so you’re stuck. What is it that has to be done?Determine the Emissions of GHG Compounds:
Those with Emission Equations/Factors In the Rule
• CO2
• Methane
• Nitrous Oxide (N2O)
Others
• Chlorofluorocarbons (CFCs)/Hydrofluorocarbons (HFCs)
• A few others listed in Table A-1 of rule
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Global Warming and CO2e
• How Much is 25,000 Metric Tons of CO2e?– Annual GHG Emissions from Energy Use of
2,300 Homes– Annual GHG Emissions from 4,600 Cars
• What is a Metric Ton of CO2e?– The tons of CO2 emissions with the same
global warming potential (GWP) as one ton of another GHG
• What is Global Warming Potential?– A measure of how much a given GHG
contributes to global warming
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Non-CO2 Greenhouse Gases Have Global Warming Potentials
Carbon Dioxide Equivalent (CO2e) is the relative GHG depleting effect of a chemical as compared to CO2 (where CO2e = 1)
Examples:
• CO2e of methane is 21
• N2O (nitrous oxide) is 310
• CO2e of Sulfur Hexafluoride is 23,900
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Global Warming and CO2eExamples
– 1 ton of N2O = 310 tons of CO2e– A facility emits 5,00 tons of CH4 and 100
tons of N2O• 500 x 21 = 10,500 tons• 100 x 310 = 31,000 tons• Total CO2e of Facility is 41,500 tons
Sources of CO2
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According to US EPA, methane accounts for 16% of global greenhouse emissions.
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Who Needs to Report?
• “Long List” (17 categories) of Industrial Owners/operators in rule
• “Short List” of facilities that exceed 25,000 ton CO2e GHG emissions from combined stationary fuel combustion, miscellaneous use of carbonate, and all other sources in the same list.
• See later slides.
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“Long List”GHG Owner/Operator List — Required to Submit
• Electricity generation • Adipic acid production• Aluminum production• Ammonia manufacturing • Cement production • HCFC-22 production• HFC-23 destruction
processes that are not collocated with a HCFC-22 production (with specific thresholds)
• Lime manufacturing • Nitric acid production
• Petrochemical production • Petroleum refineries • Phosphoric acid production • Silicon carbide production • Soda ash production • Titanium dioxide production• Municipal solid waste
landfills over thresholds (CH4only)
• Manure management systems over thresholds (CH4 and N20)
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“Short List”GHG Owner/Operator List—Required to Submit Under Certain Conditions*• Ferroalloy Production
• Glass Production
• Hydrogen Production
• Iron and Steel Production
• Lead Production
• Pulp and Paper Manufacturing
• Zinc Production
*25K Metric tons CO2e from stationary fuel, misc. uses of carbonate, and all source categories listed above
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Who Needs to Report (continued)?
Others not included in previous lists:
• Facilities with:
• >30 mm BTU/hr aggregate maximum heat input; and
• Facilities where combined stationary sources emit >25,000 ton CO2e (Lincoln Electric)
• Various Suppliers and Importers/Exporters of GHG chemicals
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Emissions Calculations Required
Use Industry-specific or other acceptable means. For example:
• Flow Meters• Emission factors based off stack
tests• Scales• Temperature Sensing Devices
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Annual ReportDue by March 31 for previous year (by 2011 for 2010 ) Components (highlights):
• Facility Information• Timeframes for data collection and submittal• Calculations of annual emissions of GHG (e.g.,
CO2e, Methane, N2O, and more)• Changes in emission calculation methods• Best available monitoring method, description,
and timeframe• Certification• Other as required by facility type (may be
extensive, see later slides)• Probable electronic filing to USEPA• USEPA may delegate to local/states
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GHG Monitoring Requirements (1 of 2)Best Available Monitoring Methods for any parameter that cannot be reasonably measured
• New requirements to be met by Q1 2010
• Extension Request by December 29, 2009
• Extension requires remedy: how will you monitor in interim?...install equipment?
• No extension beyond December 31, 2010
Written GHG Monitoring Plan required!
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GHG Monitoring Requirements (2 of 2)
• Calibration Accuracy
o 5% accuracy required by April 1, 2010
o Accuracy exceptions possible for outages
• Must Designate a Representative to Certify GHG Plan (60 Days Ahead)
• Common pipe and calibrated meter alleviates requirement for multiple-source calculations
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Tiers of Emission Determination (1 of 2)
• Tier 1: simplest; use default emission factors
• Tier 2: Calculate high heating value with equation
• Tier 3: Base emissions off of carbon content of fuel or materials
• Tier 4: Utilize continuous emission monitors (CEMs) to measure
• Alternate Methods
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Tiers of Emission Determination (2 of 2)
• Review each emission unit to determine which tier can be used/will be used.
• Monitoring and QA/QC requirements – very prescriptive
• Emission Factors: Tables C-1 and C-2
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A Few Specific RequirementsSubpart Q – Iron and Steel Production
• Mass Balance Methodo Use meters and scales for inputs and outputso Testing carbon content of inputs and outputs,
over 1% of total
• Site Specific Emission Factor Methodo Stack test – once per yearo Related to quantity of product or raw materials
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How Onerous it Can Be: Summary List of Requirements of Subpart HH – Municipal Solid Waste Landfills
ReportCH4 generationCH4 destruction – collection and combustionFollow Subpart C (General Stationary Fuel Combustion Sources): CO2, CO4, and N2O
Utilize Landfill Generation Equations (HH-1 through HH-9) to calculate:Annual methane generation rate (without and with oxidation)Annual Waste Acceptance RateAnnual quantity of recovered methaneAnnual methane emissionsCollection efficiencyMethane concentration (accounting for NMOCs)
Calculations will likely require the following input data: Tipping fee receipts (metric tons)Estimate of waste composition (e.g. diapers, garden waste, bulk waste, etc.)Degradable organic carbon fractions of waste (DOC) and Fraction of DOC dissimilated (DOCf)Fraction of methane in LF Gas from measurements (F)Rate constants (Table HH-1)Waste acceptance rate (WAR)Per capita waste disposal rates (Table HH-2)Percentage of generated waste that is landfilledLandfill capacityYears in which landfills first and last received wasteDaily average volumetric flow rate of landfill gasDaily average moisture content of landfill gasDaily average CH4 concentration of landfill gasTemperature at which gas flow is measured (daily)Pressure at which gas flow is measured (daily)Destruction efficiency (<0.99)Collection efficiency from landfillFraction of hours of operation of methane destruction device
Monitoring, QA/QC, Records:Quantity of waste landfilled must be determined using accepted mass measuring equipt. (NIST Handbook 44)Must use one of six options to estimate gas composition (gas chromotagraphy or gaseous organic concentration analyzers like GEM 2000)Must use an acceptable measuring device (flow meter) biannually calibrated in accordance with rule biannually (or as recommended by manufacturer).Temperature measurement devices calibrated per procedures and frequencies recommended by manufacturerDocumentation of procedures and calibration records, including accuracy, for instruments or devices that measure waste disposalquantities, gas flow, gas composition, gas temperature, and gas pressure.
Data Reporting Requirements:Landfill open or closedFirst year accepted wasteLast year (or estimated last year) LF accepted wasteLF capacityLeachate recirculation used?Annual disposal quantityMethod for estimating disposal quanitity and reason method usedWaste composition:
MuniucipalBiosolids or biological sludgesOther (refined categories)
For each waste type:DOCDecay rate
Fraction of CH4 in LF gasLF Surface area and cover details (see rule 98.346 fModeled methane generation rateFor LFs without GCCSs, the annual methane emissionsFor LFs with GCCS:
Gas collected for destructionCH4 concentration of collection gasMonthly avg tempMonthly avg pressureIndication as to where destruction occurs
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How Simple it Can Be: “Other” Facilities CategoryLincoln Electric:
• Euclid Campus – Not in the “Long” or “Short” list of industries.
o Does have >30 mmBTU/hr aggregate maximum heat input
o Does emit >25,000 ton CO2e from combined stationary sources.
• All sources are on a common pipe (1 reading).
• Meter is calibrated by Dominion.
• Gas is tested for high heating value by Dominion. (Although Lincoln Electric can use Tier 1 calculation methods –listed emissions factors– the means are there to use Tier 2, which is more accurate.)
• Mentor Campus – Under the Threshold. Will not need to report.
QUESTIONS?
Patrick Nortz, CPG, PENTH Consultants, Ltd.
Kathy GargaszLincoln Electric216-383-4147
US EPA web site on "Final Mandatory Reporting of Greenhouse Gases Rule":
http://www.epa.gov/climatechange/emissions/ghgrulemaking.html
