by Marc Karell, P.E., CEM

EPA has published its final federal mandatory greenhouse gas (GHG) estimation and reporting rule. Most affected industries will be required to begin to collect appropriate data beginning in calendar year 2010 and report emissions for that year in 2011 and annual emissions thereafter.

Therefore, with precious little time remaining this year to set up your systems and procedures before appropriate data must be collected and handled, it is imperative that you understand the rule's requirements and prepare for it NOW.

EPA said that the program will apply to approximately 10,000 facilities accounting for about 85 percent of national GHG emissions. These include several dozen industrial categories, as well as any facility that emits 25,000 metric tons or more of CO2 equivalents per year. EPA has stated it wants accurate emissions data as it will use the inventory as a precursor to potential future mandatory carbon cap and trade rules.

Key Provisions

EPA made a number of changes from the proposed rule published in April 2009 based on public comment. One of the largest is leaving 12 industry segments on hold. These facilities must still calculate GHG emissions from combustion per Subpart C. The rule excludes facilities from reporting if GHG emissions if shown to be below 25,000 metric tons/year for 5 straight years or below 15,000 metric tons/year for 3 straight years.

The rule requires accurate GHG emissions (in metric tons/year) to be developed at the facility level, with some exceptions, such as suppliers of fossil fuels and industrial gases, which must report on the corporate level and assume all of their product sold is utilized. Emissions of the main, recognized six GHGs (CO2, CH4, N2O, SF6, HFCs, and PFCs) must be addressed. CO2 emissions must be divided between biogenic (from combustion of biomass) and all other fuel sources. Ongoing annual emissions (beginning CY 2010) must be calculated and submitted in an electronic report to the USEPA by March 31 of each year (beginning in 2011). The report must be describe the methodology and contain a monitoring plan. It must be certified by a facility Designated Representative that the information submitted is true, accurate and prepared in accordance with 40 CFR Part 98.

Because of the late date of the finalization of the rule, for the period of January 1 through March 31, 2010, best available monitoring (BAM) methods may be used for parameters that cannot reasonably be monitored using the methodology defined. Beginning April 1, 2010, BAM can only be used if pre-approved by the USEPA in writing; by December 1, all published monitoring methods must be in place.

How to Prepare

If your facility has been on the fence about this rule, well, it’s time to get off right now. There is precious little time before the rule goes into effect, January 1, 2010.

Here are some steps to prepare for complying with the GHG reporting rule:

1. Does this new rule, in fact, apply to your facility? Go through the list of industrial categories in Subpart A. Also, determine whether your facility (covered by a category or not) meets the annual 25,000 metric ton CO2 equivalent emission limit or not. Most GHG emissions derive from combustion. Table C-1 contains emission factors for different fuels for the initial estimate. Determine other GHG emissions (i.e., methane loss) before concluding whether the threshold is met.
2. Obtain a full understanding of the emission calculation procedures. Read through the applicable section(s) and gain an understanding of the nature of the required monitoring, data collection, and calculation methodologies. It is possible that either new monitoring equipment will be needed or existing equipment will need to be used differently. Make sure that any selected equipment or procedures meet the section’s QA/QC guidelines and fits in with your facility and personnel.
3. Ensure that the new procedures or technology can be used in your facility. Proper purchase orders, instructions, training, etc. must be attained so that a new monitoring or data collection process can be incorporated into SOPs smoothly.

4. Perform a "practice run" before the end of 2009. If the procedures for data collection can be incorporated very soon, perform a run of data collection this year – perhaps for one week or one month. Use the data to calculate GHG emissions and determine whether the procedures are working smoothly and producing the high quality GHG emission data required by EPA.

5. Create or refine your software to store activity and GHG emission data. You have gone through a lot of trouble to collect the proper data. Now it’s important to reliably store the data for easy access and records. Also, ensure that it can issue reports useful to you for submittal to the USEPA and for your internal purposes.

And finally, inform your colleagues of the important aspects of this rule, ranging from the Designated Representative and managers to floor staff who will be collecting data so that the entire data collection, emission calculation, and reporting processes will go smoothly.

The final rule is effective December 29, 2009. For more information, see the rule.

Marc Karell is a licensed professional engineer and a Certified Energy Manager. He is the founder of Climate Change & Environmental Services, LLC. Mr. Karell has over 20 years’ experience in the climate change field, performing carbon footprints and energy and green building evaluations, and in the air pollution engineering field, performing emissions inventories, audits, permitting, and evaluations and design of air pollution control equipment for a variety of types of facilities around the country.

Contact Marc Karell at 914-584-6720 or karell@ccesworld.com. You can also visit Climate Change and Environmental Services, LLC.