US EPA Proposed Mandatory Greenhouse Gas Reporting Rule

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1 US EPA Proposed Mandatory Greenhouse Gas Reporting Rule

2 Outline 1. Overview 2. The Basics 3. Affected Source Types 4. Applicability Examples 5. How are the GHG Emissions Calculated? 6. Comments and Issues 2

3 Today s Presentation Why are GHG inventories important? You can t manage what you don t measure Voluntary Programs / Consumers / Image State and Regional programs and development EPA Mandatory GHG Reporting - This is a game changer Mandatory Reporting is the tip of the GHG reduction iceberg Goals of Today Clear the air on scope of US EPA Proposed Reporting Rule Sources covered and calculation methods Note trend toward GHG Management and the future 3

4 The GHG Management Cycle 5. Reduction Projects 1. Assess Drivers 4. Reduction Goal Setting and Planning EPA Mandatory Reporting Rule 2. Inventory Management Plan 3. Inventory 4

5 5

6 US EPA Proposed GHG Reporting Rule Applicability of Rule to Facilities and Operations Compliance Gap Analysis Sources, inventory estimate, current data/new needs Existing Inventory which sources affected at each facility, what are new data needs Data Collection and Monitoring Needs Inventory Database Upgrades Reporting for other programs Mandatory ARB, WCI, and RGGI Voluntary - TCR, CCAR, CDP 6

7 The Basics

8 US EPA Proposed Mandatory Reporting Rule Proposed Rule (1600 Pages) March 10, 2009 released via website Fed Register Notice on April 10, day comment period due on June 9, 2009 Final Rule - June 2009, legis date. Fall 2009 expected. Calendar Year 2010 Emissions Reports due on March 31, 2011 Annual Reporting; Once in Always in (few exceptions) Primarily Facility Level Reporting EPA estimated the cost of reporting = $0.04 per metric ton Calculation Methodologies based on existing programs EPA Verification (not by a 3 rd party) PUBLIC MEETINGS - Public Notice in the Fed Reg April 6 and 7, Arlington, VA April 16, Sacramento, CA 8

9 # of Facilities v. mt CO2e Threshold 85-90% of total national U.S. GHG emissions, from approximately 13,000 facilities, would be covered by the proposed rule 9

10 Reportable Greenhouse Gases Six Kyoto GHGs Carbon dioxide (CO 2 ) Methane (CH 4 ) Nitrous oxide (N 2 O) Hydrofluorocarbons (HFC) Perfluorocarbons (PFC) Sulfur hexafluoride (SF 6 ) PLUS Nitrogen trifluoride (NF 3 ) Hydrofluorinated ethers (HFE) 10

11 What is reported to EPA? Emitters Total facility emissions aggregated for all source categories Metric tonnes CO2e and mt of each GHG GHG and Fuel Suppliers Total emissions aggregated for all supply categories mtco2e and mt of each GHG Certain Specific Facilities Onsite electricity generation in kwh Total lb of synthetic fertilizer produced and total N contained in the fertilizer. Unit- or process-level emissions, activity data, or QA/QC data specified Emission Reports Submitted electronically, format specified by EPA after finalization Each report signed by a designated representative of the owner or operator 11

12 Records Retention and Backup GHG Emissions Calculations List of all units, operations, processes, and activities for which GHG emissions are calculated Data used for each unit, operation, process, and activity categorized by fuel or material type Documentation of the process used to collect the necessary data The calculations and methods used. Emission factors Facility operating data or process information used in calcs Facility Procedures Names and documentation of key facility personnel involved A log book documenting any procedural changes to methods of data measurement Missing data computations Written quality assurance performance plan 12

13 Affected Source Types

14 Emission Source Categories 14

15 Overview: Thresholds for Reporting There are FIVE ways a facility can be included 1. Any Direct Emitter - Operate a facility that contains any of the Source Categories on Table 1 2. Direct Emitter >25k tpy CO2e - Operate a facility that contains any of the Source Categories on Table 2 and emits more than 25,000 mt CO2e / year in Stationary Combustion - Operate a facility that emits more than 25,000 mt CO2e per year from stationary combustion sources 4. Fossil Fuel Supplier - Operate a facility that produces, imports, or exports Fossil Fuels 5. Industrial GHG Supplier - Operate a facility that produces, imports, or exports Industrial GHGs greater than or equal to 25,000 mt CO2e / year 15

16 Decision Flow Chart 16

17 Table 1 Any Direct Emitter Operate a facility that contains any of the following Source Categories Production of: Adipic Acid Lime Aluminum Ammonia Cement Petrochemical Products Nitric Acid Phosphoric Acid Silicon Carbide Soda Ash Titanium Dioxide Petroleum Refineries Electric Power Systems Exceed 7838 kg SF6 or PFC Electricity Generating Facilities Acid Rain program or >25k mtpy Electronics Manufacturing Production capacity threshold HCFC-22 Production HFC-23 Destruction (Activity threshold) Underground Coal Mines (MSHA) Manure Management CH4 and N2O > 25k mtpy CO2e Landfills Generate CH4 > 25k mtpy CO2e MUST REPORT all GHG Emissions 17

18 Table 2 -- Direct Emitter >25k tpy CO 2 e Operate a facility that contains any of the following Source Categories on and emits more than 25,000 mt CO2e / year in 2010 Production of: Electronics Solar PV Iron and Steel Ethanol Lead Ferroalloy Magnesium Fluorinated GHGs Glass Hydrogen Zinc Electricity Generation Industrial Landfills Oil and Natural Gas Systems Food Processing Pulp and Paper Manufacturing Industrial Wastewater MUST REPORT all GHG Emissions 18

19 Table 3 Stationary Combustion Operate a facility that emits more than 25,000 mt CO2e from one of the following stationary combustion sources Boilers Stationary Engines Process Heaters Combustion Turbines Other Fuel Combustion Equipment MUST REPORT GHG Emissions from Stationary Combustion Only 19

20 Table 4 Fossil Fuel Suppliers Operate a facility that produces, imports, or exports Fossil Fuels Coal Coal-based Liquid Fuels Natural Gas Natural Gas Liquids Petroleum Products MUST REPORT the Volume of Fuel Sold and the GHG Emissions Associated with the Complete Oxidation of that Fuel 20

21 Table 5 Industrial GHG Suppliers Operate a facility that produces, imports, or exports Industrial GHGs greater than or equal to 25,000 mt CO2e / year Fluorinated Gases Nitrous Oxide Carbon Dioxide MUST REPORT the Volume of Product Sold and the GHG Emissions Associated with the Complete Release of the Product 21

22 Exempt Sectors and Categories Mobile source fleet operators Natural gas distribution sector Indirect emissions from the purchase of electricity Fugitive emissions from natural gas pipeline segments between compressor stations, or crude oil pipelines Fugitive CH4 and CO2 emissions from onshore petroleum and natural gas production 22

23 Applicability Examples

24 Examples: Table 1 Any Direct Emitter Petrochemical Plant Emits - 19,000 mtpy CO 2 e in combined emissions from wastewater treatment and combustion Do they report? - Yes Why? Facility is within a Source Category in Table 1, so they must report emissions regardless of size. Solid Waste Landfill Generates - 2,000 mtpy CH 4 (equal to 42,000 mtpy CO 2 e) but collects and combusts 75% of the CH 4, emitting only 10,000 mtpy CO 2 e. Do they report? - Yes Why? For a solid waste landfill, the 25,000 mtpy CO 2 e threshold is based on gas generation, not net mtpy CO2e emissions. 24

25 Examples: Table 2 Direct Emitter > 25,000 tpy CO 2 e Pulp / Paper Mill Emits - 22,000 mtpy CO 2 e in combined emissions from wastewater treatment, combustion, digesters, and carbonates? Do they report? - No Why? Facility is within a Source Category in Table 2, but they are below the reporting threshold of 25,000 mtpy CO 2 e. Peanut Butter Manufacturing Plant Emits -15,000 mtpy CO 2 e from a natural gas fired boiler, 9,000 mtpy CO 2 e from wastewater treatment and 2,000 tpy CO 2 e from a wood fired boiler. Do they report? - No Why? Facility is within a source category in Table 2, but biogenic fuels do not contribute towards the 25,000 mtpy CO 2 e threshold. 25

26 Example: Table 3 Stationary Combustion >25,000 tpy CO 2 e Blender Assembly Plant Emits - 30,000 mtpy CO 2 e from a coal fired boiler? Do they report? - Yes Why? Facility source category is not in Tables 1 or 2 but is over the threshold for stationary combustion Beauty Products Manufacturing Plant Emits - 24,500 mtpy CO 2 e from natural gas fired heaters? Do they report? - No Why? Facility source category is not in Tables 1 or 2 and is under the threshold for stationary combustion 26

27 How are the How are the GHG Emissions Calculated?

28 Example: Stationary Combustion CO 2 4 Tiers Increasing Tiers demand more data, detail, and accuracy Details on the following slides CH 4 and N 2 O Units Covered in the Acid Rain Program and that report heat input under 40 CFR Part 75 Annual measured heat input * Default Emissions Factor All other units Annual fuel usage * HHV (df or msrd) * Default Emissions Factor Report Hourly, Daily, Monthly, or Annual data based on Tier requirements 28

29 Stationary Combustion: CO 2 Tier Calculation Requirements Tier 1: Tier 2: Tier 3: Tier 4: 1. Fuel usage records 2. Default HHV 3. Default EF 1. Monthly Fuel usage records 2. Monthly / weekly sampled and measured HHV 3. Default EF 1. Fuel measured directly 2. Measured fuel carbon content (depending on fuel) 1. Hourly Continuous Emissions Monitoring System (CEMS) Measurement 2. May need to update existing CEMS to meet the requirement Increasing Data Requirements and Accuracy

30 General Stationary Combustion CO 2 Tier Decision Tree Does the Unit have a max rated input capacity of greater than or less than 250 MMBTU/hr? 200 mmbtu/hr Does the Unit have a stack flow monitor and CO2 Monitor that are tested, required and certified? NO > 250 MMBTU/hr YES Does the Unit have a CEMS that is required, tested, and certified? YES Does the unit combust solid fossil fuel as primary or secondary fuel and has it operated for > 1,000 hrs in any year since 2005? NO YES Tier 4 Is HHV is determined from monthly testing or made available from manufacturer? NO Are default HHV and emissions factors available? YES Is a default Carbon Content Emissions factor available? NO YES Tier 2 NO NO Tier 3 Tier 1

31 Comments and Issues

32 EPA Requests for Comment, 1 Can existing EPA programs meet same reporting goals? Should the program be ongoing indefinitely, sunset or be conditional? Are the threshold limits appropriate or should other emissions or capacity based thresholds be applied? Are the proposed methodologies appropriate or are there alternatives to improve accuracy that are feasible and cost effective? Is EPA verification appropriate? Is there an alternative approach to adopt that will meet the same goals? 32

33 EPA Requests for Comment, 2 How should considerations of actual and potential emissions be incorporated into the proposed threshold? Should EPA include reporting for operators of mobile source fleets? Should facilities be required to report the quantity of electricity generated onsite (renewable and nonrenewable)? Should facilities also be required to report annual purchased electricity (kwh)? 33

34 General Comments and Issues Harmonization with existing programs? Implications for existing air quality permits Facilities already reporting similar data in existing programs TRI, Title V permits, Acid Rain, etc. Annual due dates - consistent with other programs (Qrtly v. Annual) Is EPA s cost estimate for implementing the rule underestimated for some source categories or industries? Do specific data reporting requests need to be reduced? Where considered onerous or unnecessary Mandated measurements appropriate for a reporting rule? Example: fugitives from compressor stations 34

35 Issues for Sources to Consider

36 Issues to Consider GHG Inventory Management Plans Sources Calculations Data requirements Sampling / Analysis requirements Inventory data collection and data management EMIS Facility Measurement upgrades Inventory for 2010; Report in 2011 Business planning Cost of Compliance Future Reductions Integrated Carbon / Asset Management 36

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