Make sure your monitoring and recordkeeping systems are first class
The EPA has “finalized” its GHG calculation and reporting rule (see a summary in http://www.ccesworld.com/news). I put that in quotes because EPA put about a dozen industrial categories on hold pending further review before their finalization. But even those industries must comply soon with Subpart C (Combustion). And of course, Congress is debating a GHG emission reduction bill, including a cap and trade program affecting a wide range of industries. If you think such a rule will not pass because of what’s going on with health care reform, have another thought coming. A number of Republicans are on board in principle with such a climate change bill – enough that a compromise is expected to occur that will be filibuster-proof.
An important principle of these rules will be the requirement that records and procedures used to calculate GHG emissions and reductions be air-tight (excuse the pun). Especially given the fact that this will lead to potential accounting and offset issues (GHG emissions will be “currency”). This is the time to ensure that your monitoring or calculation systems that measure GHG emissions are accurate, thorough, and undergo the necessary QA/QC procedures (such as proper maintenance and calibration) and that your recordkeeping systems contain all relevant information and treat data appropriately. Now is the time to invest in upgrading these systems. You don’t want to scramble later on and, more important, risk putting your Responsible Official on the hot seat for potential faulty data submitted to the USEPA because of a system error.
CCES has the expertise to assist you in assessing your current monitoring and recordkeeping systems and advise you on cost-effective upgrades, if necessary, to comply with current standards. See our website: http://www.ccesworld.com
Marc Karell, P.E., CEM
Posted: November 5th, 2009 under Uncategorized.
Tags: compliance, GHG emissions, monitoring, recordkeeping, systems