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.
The first step of a successful monitoring plan is to identify and document sources that produce GHGs and describe what's included or excluded in the relevant industry source category. Many facilities at this time only will need to report stationary combustion sources such as boilers, process heaters, small heaters and combustion turbines. Reporting of emissions from pilot lights isn't required. GHG Rule updates, finalized in September 2011, exempt emissions from emergency generators and equipment.
A site also must evaluate the GHG Rule's industry-sector-specific emission sources, if applicable, for inclusion or exclusion from the list of identified sources. For example, the technical clarifications, finalized in September 2011, require a petrochemical production facility to include and report GHG emissions from process vent stacks not associated with stationary combustion units. The site must trace such process vent stacks back to the process being vented that's generating the GHG emissions. Other specific industry sectors, like suppliers of industrial GHG as a final product, needn't report emissions from the destruction of fluorinated GHGs removed during the production process as byproducts or other wastes.
The source determines which covered GHGs must be documented — for example, CO2, CH4 and N2O are required for stationary combustion sources while CO2 and CH4 are required for asphalt blowing.
Tools that teams can use to identify GHG emission sources include process flow diagrams, piping and instrumentation drawings, equipment lists, stack location diagrams, as well as total process byproducts or wastes generated throughout the site. The team should conduct a walkdown and visual verification of the facility and sources because diagrams and drawings may not always be accurate or up to date.
The next step is to determine the monitoring methods and measuring device or procedure based on the specific source. Various methods can measure GHGs; it's imperative to use ones that not only are accurate but also suit a facility's operations. Sometimes installing a monitoring device will require shutting down the process. The EPA has provisions in the rule for utilizing best available monitoring methods until the facility has a scheduled shutdown. A plant must identify these interim methods in the plan along with the schedule for implementing permanent ones.
A site may develop measuring strategies based on the source and source categories listed in the rule subparts. The specific calculation methodologies for each source type will help determine what data must be collected. Examples of potential measuring methods and strategies include:
• Grouping or aggregating smaller stationary combustion units combined with larger units if they share common fuel sources. Consider physical proximity of grouped units when sharing a measuring device.
• Material balance.
• Direct measurement of GHGs via continuous emissions monitoring systems (CEMS) already in place to comply with other EPA programs such as the Acid Rain Program that applies to most power plants.
• Indirect measurement using process parameters such as fuel consumption, material throughput, heat and temperature, pressure, or mass or volumetric flow rates that will require specific calculations to determine the GHG emissions.
Consider updating only measurement sensors or transmitters for newer, more-accurate devices instead of replacing the system, to reduce the cost of upgrades. Also consider wireless transmitters where capital costs and potential production disruptions to install a hardwired system aren't cost effective.
• Invoices or purchasing records for utilities such as natural gas. Don't use these "as is" for a material utilized both as a fuel and as a raw material in processes that don't generate GHG unless the amounts for each purpose are clearly separated.
• Personnel and instrumentation for collecting data. Location of the measuring device readout and the amount of labor required to gather and utilize the data may favor automatic data collection instead.
• Automatic data collection through the use of process control software. A site only may need some reprogramming to obtain and use data collected for other purposes.
A facility also must build quality assurance (QA) requirements for the data collected into the plan. This must include the following details:
• Frequency of data collection (based on source category) and any change in monitoring required based on production changes.
• Calibration of meters or data collection equipment. Consider opting for instrumentation that can be remotely calibrated when replacement is required.
• Certification and QA testing of CEMS, if utilized.
• Maintenance and repair of meters and instrumentation.
• Preservation of instrumentation records and certifications.
• Record of missing data events and data computations.
The methodologies required in the monitoring plan also include the specific emission factors and calculation methodology used to determine the GHG emissions by source.
The monitoring plan must outline data collection, calculation and data maintenance procedures. Devote considerable thought to how to handle and store data. Spreadsheets may be appropriate for some facilities but may be too labor intensive and difficult to maintain for sites with many processes. A large plant should consider using environmental management software that allows data analysis on a facility and corporate level. In any case, a facility must maintain the data in an organized, accessible and auditable form. The plan should outline where data from each source is to be stored and maintained. The site must keep data for at least three years.
A facility must review and analyze the data on a regular basis — at a minimum monthly — throughout the year. This will enable spotting trends in emissions that may warn of potential operational problems.
The time required to set up a monitoring approach greatly depends on the size of a facility and the dedication of the team. It can take approximately three to four months to identify sources, establish the best monitoring approach, calibrate equipment and collect data. It's important to develop a detailed schedule for each step of the process that will assure adequate time to meet EPA deadlines.
GHG Report submittal for GHG emissions must be via the electronic greenhouse gas reporting tool (e-GGRT) available online at https://ghgreporting.epa.gov/ghg/login.do. Users must register online for access through the EPA's CDX server. The electronic certification of the report requires a signatory for the site to register and be verified. A plant must register — a process that takes several weeks — prior to filing a report, and should maintain records of the data reported.
A facility can stop monitoring and reporting GHG emissions to the EPA if its emissions are below 25,000 mt/yr for five consecutive years, or under 15,000 mt/yr for three consecutive years. However, the site must notify the EPA and satisfactorily explain how it reduced emissions.
THE REGULATORY FUTURE
There's little doubt that the EPA intends to eventually mandate that companies reduce their emissions regardless of whether they are seeking permits. It would be wise for a company to examine its current emission levels and evaluate possible ways of reducing them now so it can incorporate suitable investments into future capital budgets.
In addition, as part of the new regulations, a company's emission levels will become public knowledge. So, a firm must consider how the public's knowledge of its emissions will impact aspects of its business, including its relationships with customers, partners and vendors. Reducing GHG emissions now certainly will help a company improve its public image and distinguish it as an environmental sustainability leader.
ANNA KOPERCZAK is a senior environmental specialist at SSOE Group, Toledo, Ohio. Email her at Anna.Koperczak@ssoe.com.