• 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.