Greenhouse Gas Monitoring Plan (Template)

Transcription

1 Greenhouse Gas Monitoring Plan (Template) McWane, Inc. December 8, 2009 The attached model Greenhouse Gas Emissions Monitoring Plan template was provided to AFS by McWane, Inc. as a courtesy and is intended to be used a guide for metal casting operations in developing a facility specific monitoring plan. Please note that use of the model monitoring plan template will not necessarily guarantee compliance with all applicable regulatory requirements for your facility. You should consult the final GHG Emissions Reporting rule to make sure that your individual facility monitoring plan addresses all of the requirements applicable to your facility s operations.

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3 Table of Contents 1.1. Plan Purpose and Scope 1.2. Authorization and Responsibilities of the Designated Representative 1.3. Positions of Responsibility for Collection of Emissions Data 1.4. Identification of GHG Emission Sources 1.5. Summary of Applicable Requirements 1.6. Description of Processes and Methods to Collect Data and Calculate Actual GHG Emissions for Each Source 1.7. Procedures Used to Ensure the Accuracy of the Fuel Usage Estimates 1.8. Procedures and Methods that are Used for Quality Assurance,, and Repair of Monitoring Systems, Flow Meters, and Other Instrumentation 1.9. Annual GHG Emission Reporting Requirements Methods for Addressing Periods of Missing or Erroneous Data from GHG Monitoring Systems Summary of Recordkeeping Requirements Appendices Page 3 of 10

4 Green House Gas Monitoring Plan (Template) 1.1. Plan Purpose and Scope This plan is intended to meet the requirements for a Green House Gas Monitoring (GHG) Plan contained in 40 CFR Part 98.3(g)(5). In addition this plan outlines the methods and procedures necessary to ensure that all reports, data collected and emission calculations made are consistent with pertinent requirements of the Mandatory Green House Gas Reporting Rule (40 CFR Part 98 ) Authorization and Responsibilities of the Designated Representative is the Designated Representative for this facility A certificate of representation in accordance with the requirements of 40 CFR Part 98.4 will be submitted to EPA electronically in a format specified by the agency no later than January 31, This certificate will be attached to this plan as Appendix I. With any change in the Designated Representative a new certificate of representation will be submitted to EPA prior to the submission of any reports or other information. This new certificate will also be included in Appendix I The Designated Representative shall represent and, by his or her representations, actions, inactions, or submissions, legally bind the facility in all matters pertaining to this Rule Positions of Responsibility for Collection of Emissions Data Table 1 below lists the GHG emission data to be collected by the facility, the frequency of data collection, and identifies the individuals responsible for collecting this data by job titles. Page 4 of 10

5 Table 1 (Example) Title Department Responsibilities Frequency Environmental Environmental Develop, implement, maintain, and update GHGMP As needed Melt Melt Dept. Collect coke usage Daily Melt Melt Dept. Maintain coke usage records and forward them to Environmental Manger Monthly Calibrate scale for coke measurement Annually MP2 Systems Maintain calibration, maintenance, and repair records As needed Conduct Preventative of scale for coke measurement and repair as necessary Quarterly Purchasing Purchasing Collect other fuel usage records Monthly Purchasing Purchasing Maintain all fuel purchasing records and forward them to Environmental Manger Monthly Calibrate flow gauges used for fuels measurement Annually Conduct Preventative of flow gauges used for fuel measurement and repair as necessary Quarterly 1.4. Identification of GHG Emission Sources The following is a list of GHG emission sources at the facility; (List all stationary sources of carbon dioxide (CO 2 ), methane (CH 4 ), nitrous oxide (N 2 O); e.g. fossil fuel combustion) Natural Gas combustion occurs in the processes listed below. However, since all of these processes are served by a common gas meter(s) these processes are treated as a single source. Please note that this methodology will include minor exempt sources and will slightly overestimate GHG emissions Cupola (Afterburner) Annealing Ovens Drying/Curing Ovens Torches/Lances Comfort Heating Coke combustion occurs in the Cupola; Other Fuels at Stationary Sources Input other facility specific fuels that maybe used for example No. 2 Fuel Oil/Diesel for use in annealing ovens during natural gas curtailment or use of acetylene for mold blackening Summary of Applicable Requirements All sources at this facility are covered by Subpart C General Stationary Fuel Combustion Sources (40 CFR Part 98.2[a][3]) and the general provisions of Page 5 of 10

6 Subpart A (40 CFR Part 98.1) Aggregation of Units Because the facility contains two or more units (e.g., comfort heating, annealing oven, afterburners, etc.), each of which has a maximum rated heat input capacity of 250 mmbtu/hr or less and burn only natural gas, the facility will report the combined GHG emissions for the group of units in lieu of reporting GHG emissions from the individual units for natural gas combustion (40 CFR Part 98.36[c][1]) GHGs to report (40 CFR Part 98.32) The facility will report CO 2, CH 4, and N 2 O mass emissions from each stationary fuel combustion unit Description of Processes and Methods to Collect Data and Calculate Actual GHG Emissions for Each Source Methods of Data Collection Natural Gas The facility will determine natural gas usage based on collecting monthly invoices from the natural gas supplier. The natural gas usage amounts will be recorded and used to calculate the emissions (If the facility collects the data through other methods then the facility will describe their process for collecting data) Coke The facility will determine the coke usage based on the melt department charge records that are collected daily. These results will be summarized monthly and used to calculate emissions. The coke usage is measured by a scale that is used for determining the amount material that is charged into the cupola. The scale is calibrated at least annually to ensure accuracy of the charge weights Other Fuels at Stationary Sources (Indicate what other sources the facility has and the means for collect the usage rates for each source) Method for Calculating Emissions (40 CFR Part 98.33) The facility will use the Tier 1 calculation methodology for the following reasons: Facility uses a fuel listed in Table C 1 of 40 CFR Part 98 and it is combusted in a unit with a maximum rated heat input capacity of 250 mmbtu/ hr or less; Fuel sampling and analysis for the fuel High Heat Value (HHV) are not routinely performed; and Results of HHV sampling and analysis are not routinely received from the fuel supplier at the minimum frequency (i.e. weekly) specified in 40 CFR 98.34(a), or at a greater frequency When the above conditions are not applicable for any reason, the facility will modify this plan to revise GHG calculation methodology The facility will calculate the annual CO2 mass emissions for each type of fuel by using Equation C 1 of 40 CFR Part 98. CO 2 = 1x10-3 _ Fuel _ HHV _ EF Page 6 of 10

7 Where: CO 2 = Annual CO 2 mass emissions for the specific fuel type (metric tons). Fuel = Mass or volume of fuel combusted per year, from company records as defined in 40 CFR Part 98.6 (express mass in short tons for solid fuel, volume in standard cubic feet for gaseous fuel, and volume in gallons for liquid fuel) HHV = Default high heat value of the fuel, from Table C 1 of 40 CFR Part 98 (mmbtu per mass or mmbtu per volume, as applicable) EF = Fuel-specific default CO 2 emission factor, from Table C 1 of 40 CFR Part 98 (kg CO 2 /mmbtu) 1 _ 10-3 = Conversion factor from kilograms to metric tons The facility will calculate the annual CH4 and N2O mass emissions only for units that are required to report CO2 emissions using the calculation methodologies of this subpart and for only those fuels that are listed in Table C 2 of 40 CFR Part 98. Where: CH 4 or N 2 O = 1x10-3 _ Fuel _ HHV _ EF CH 4 or N 2 O = Annual CH 4 or N 2 O from the combustion of a particular type of fuel (metric tons) Fuel = Mass or volume of the fuel combusted, either from company records or directly measured by a fuel flow meter, as applicable (mass or volume per year) HHV = Default high heat value of the fuel, from Table C 1 of 40 CFR Part 98 (mmbtu per mass or mmbtu per volume, as applicable). EF = Fuel-specific default emission factor for CH 4 or N 2 O, from Table C 2 of this subpart (kg CH 4 or N 2 O per mmbtu) 1 _ 10-3 = Conversion factor from kilograms to metric tons When a facility uses fuels that are not listed in Table C 2 of 40 CFR Part 98 or fails to meet any of the 3 requirements in section , the facility will modify this plan to revise GHG calculation methodology Procedures Used to Ensure the Accuracy of the Fuel Usage Estimates Natural Gas Usage is determined by using the monthly invoices from the supplier. The supplier is responsible for calibrating the meter that determines the usage rate at our facility. This process is adequate for determining the facilities usage rates The accuracy of the coke usage is maintained by calibrating the charge scales at least annually. The facility will develop site specific procedure/work instruction for the calibration of the charge scales. (The facility will not use vendor supplied invoices for determining coke usage rates due to the ability to store the raw material onsite) Page 7 of 10

8 For Other Fuels The facility will develop a site specific procedure/work instruction based on the most accurate means of tracking the usage rates. (For sources that use vendor supplied invoices to determine usage rates, the invoices may be used if the usage is accurate for determining the throughput for the defined frequency. If this is accurate then the facility is not required to develop a procedure for determining the accuracy of the usage for this source.) 1.8. Procedures and Methods that are Used for Quality Assurance,, and Repair of Monitoring Systems, Flow Meters, and Other Instrumentation All flow meters and other measurement devices (e.g., scales) that measure data used to calculate GHG emissions will be calibrated prior to April 1, 2010 and annually thereafter using the procedures specified in Table All calibrations will be performed according to the manufacturer s recommended procedures or an appropriate industry consensus standard All measurement devices shall be calibrated to an accuracy of 5 percent All fuel billing meters that are not owned by the facility are exempted from the calibration requirements. Page 8 of 10

9 Monitoring Equipment Parameter Measured Table 2 (Example) Calibration Method Frequency of Calibration Scale Coke Used Annually Flow meter Other fuel used Annually Accuracy of Monitoring Equipment Technical Basis for the Accuracy Determination 1.9. Annual GHG Emission Reporting Requirements Report Submission Due Date The initial report to EPA for 2010 will be submitted electronically in accordance with the requirements of 40 CFR Part 98.4 and in a format specified by the agency no later than March 31, Subsequent reports are due March 31 of each year for the preceding year. Reports will be attached to this plan in Appendix II Contents of Report Facility identifying information; Facility name and physical street address including the city, state, and zip code Year and months covered by the report Submittal date Annual emissions of each GHG for each source category in metric tons of CO 2 equivalents (CO 2 e) Other emissions data required by Subpart C (e.g., by unit or process line) Verification data required by Subpart C (e.g., data used to calculate emissions) Description of best available methods used (if applicable) Data elements for which a missing data procedure was used Certification Requirements Each Annual Report will be signed by the facility s Designated Representative and will contain the following certification statement: I am authorized to make this submission on behalf of the owners and operators of the facility or supplier, as applicable, for which the submission is made. I certify under penalty of law that I have personally examined, and am familiar with, the statements and information submitted in this document and all its attachments. Based on my inquiry of those individuals with primary responsibility for obtaining the information, I certify that the statements and information are to the best of my knowledge and belief true, accurate, and complete. I am aware that there are significant penalties for submitting false statements and information or omitting required statements and information, including the possibility of fine or imprisonment Submission of Corrected Report Page 9 of 10

10 A corrected report should be submitted to EPA within 45 days of discovering an error in the report Methods for Addressing Periods of Missing or Erroneous Data from GHG Monitoring Systems Natural Gas Purchase Records There should be no need to address missing or erroneous data for these records because the information is readily available from the natural gas supplier Daily Coke Charge Records In the event that daily coke charge records are missing or found to be in error, the daily coke usage will be estimated by multiplying the average coke usage per ton of metal melted for the past 30 days of production by the metal throughput for the day in question. If the metal throughput is also missing or in error then that number would be estimated by multiplying the number of pipe of each size and class of pipe produced that day by their reference weight Other Plant Specific Records if Applicable To be developed by the facility to address specific records not covered above Summary of Recordkeeping Requirements All required records will retained for 3 years. Required records are listed below List of all emission sources and associated processes for which GHG emissions were calculated All data used to calculate the GHG emissions for each source The annual GHG reports Missing data computations Written GHG Monitoring Plan Certification and QA tests and calibration records for measurement equipment Appendices Appendix I Certification of Representation Appendix II Annual Emissions Reports Page 10 of 10