September 30, 2011, marked an important date for the new mandatory Greenhouse Gas Reporting Program (GHGRP) of the U.S. Environmental Protection Agency (EPA). It was the first nationwide deadline for companies to report their annual greenhouse gas (GHG) emissions levels. More than 10,000 industrial facilities across the U.S. had to submit data for the year 2010.
With the first report deadline complete, many plant managers are starting to breathe a little easier and feel the challenges and confusion surrounding the process are behind them. However, the deadline to report the inventory for 2011 is March 31, 2012. For those facilities that will be reporting inventory for the first time, it's essential they establish a GHG emissions monitoring plan to obtain and submit accurate data.
The EPA's Mandatory Reporting of GHGs Rule (40 CFR Part 98) is the basis of the GHGRP, and is the first nationwide regulation requiring companies to report their GHG emissions data and other relevant information annually, starting with 2010 calendar year emissions. The rule applies to certain industry-specific sources and facilities that emit at least 25,000 metric tons of GHGs per year.
This federal GHGRP is separate from any state-mandated GHG reporting programs or air emission reporting required by greenhouse gas permitting programs. The reporting requirements under each program may have similar elements but also can differ significantly.
The goal of the GHGRP is to give federal authorities an accurate depiction of who is emitting GHGs and at what level. The information reported to the EPA under this program will become public knowledge and the data will help shape future carbon-control policy decisions by the EPA.
The first challenge many companies face is understanding all the requirements. The initial focus of the GHGRP is on stationary combustion sources at all industrial facilities, and includes additional emission sources for specific industry sectors (as identified in the GHG Rule subparts). A facility must determine if it is subject to any of the specific industry sector subparts based on type of processes on-site.
THE MONITORING PLAN
An important element of the program is developing and implementing a reliable written monitoring plan that describes how the facility will comply with the requirements. An effective monitoring plan defines the GHG emission source; processes and schedules for collecting emissions data; calculation methodology; and quality assurance for these data. It's the key to simplifying the data collection process and increasing reporting accuracy. A site must keep the monitoring plan current and modify it as necessary to reflect changes in regulatory requirements, production processes, monitoring instrumentation, and quality assurance procedures. The monitoring plan itself is a recordkeeping requirement only if the facility exceeds the 25,000-mt/yr reporting threshold, or if it contains specific source categories that must report emissions. The monitoring plan need not be submitted to the EPA; however, it should be compiled in a format that can be audited by the agency if requested.
Setting up a successful monitoring plan involves a few important steps, including identifying sources of GHGs; determining the proper methods for monitoring; collecting the data; and selecting the procedures and methods for calculating and quality-checking the data from each measurement device or method.
Successfully developing and implementing the monitoring plan requires a team with a wide variety of skills and expertise. The team may include, but is not limited to, purchasing, accounting, operations, maintenance, information systems, environmental services, quality, engineering and outside resources.
Many companies augment their internal team with outside resources. Because understanding current regulations, reporting, monitoring and permitting require special skills, these firms, rather than adding to staff, use an experienced outside expert who knows how EPA wants the information structured and how to compile it efficiently. Another approach is to use an outside resource to train staff to handle some of the activities such as calibrating measurement devices and analyzing data.