CCES News For You

February 5, 2010
The USEPA Mandatory Reporting of Greenhouse Gas (GHG) Rule (40CFR Part 98) requires affected facilities to collect data based on its rigorous standards beginning on January 1, 2010 for reporting by each March 31 for the previous calendar year. The rule resulted in a flood of inquiries. The USEPA recently issued the following clarifications:
1. Abbreviated reporting. The USEPA said that facilities can submit an abbreviated emissions report by March 31, 2011 for calendar year 2010 only if the facility emits GHGs from stationary combustion sources only and is not in a listed All-in category and emits less than the threshold of 25,000 metric tons per year of CO2e. If a program emits less than the threshold but is in a listed category, a full report in 2011 is required. This clarification concerns reporting. Emissions must be calculated using appropriate methods listed in Part 98. The abbreviated report must include total facility GHG emissions aggregated for all stationary com-bustion units (not for each combustion unit) and expressed in metric tons of CO2, CH4, N2O, and CO2e. Such facilities must submit a full report by March 31, 2012.
2. Best Available Monitoring Methods (BAMM). Because of the fast turnaround between rule finalization and effective date of data collection, the USEPA is temporarily allowing a facility to substitute methods, such as ones currently existing, for the required ones. These BAMM methods may be used without pre-approval by the USEPA. However, proper calculation methods must be used. Any facility wishing to use BAMM past March 31, 2010 must have already submitted to the agency a written request with an explanation (i.e., unavailability of needed equipment). All proper methods must be in place by January 1, 2011.
3. Equipment Calibration. For facilities monitoring GHG emissions, calibration of flow meters and other monitoring equipment to meet 5% accuracy standards must have taken place before April 1, 2010. Initial calibration may be delayed past this date for either of two reasons: (1) if equipment was already calibrated under a Part 98-approved method before it took effect and the previous calibration is still active or (2) if initial calibration would cause a disruption of process operations. In this case, it must be performed during the next scheduled maintenance period.
4. Monitoring Plans. All affected facilities that perform monitoring must prepare a monitoring plan by April 1, 2010. It does not need to be submitted to or approved by the USEPA, but must be kept on site for USEPA review during audits. The monitoring plan must include process descriptions and methods used to collect necessary data for the GHG emission calculations, including BAMM procedures.