The Environmental Protection Agency (EPA) has recently proposed a new GHG emissions program designed to further regulate the amount of greenhouse gas produced in the US. The proposed Prevention of Significant Deterioration and Title V Greenhouse Gas Tailoring Rule would require large facilities to obtain operating permits for their greenhouse gas (GHG) emissions. Large facilities are defined as those emitting more than 25,000 tons per year CO2e. According to the EPA these large facilities make up nearly 70% of US GHG emissions. Additionally newly constructed facilities and significantly modified facilities would be required to use the best available control technology to minimize GHG emissions under the proposed rule.

Under Title V, the EPA is proposing an applicability threshold of 25,000 tons per year (tpy) CO2e for existing facilities. Facilities with emissions of less than 25,000 tpy CO2e would not be required to obtain an operating permit.

Under Prevention of Significant Deterioration, a program designed to minimize emissions from new or modified sources, the major stationary source threshold is 25,000 tpy CO2e. This is the threshold used to determine if a new facility or a major modification to an existing facility would require a PSD permit. The significance threshold is set at 10,000 to 25,000 tpy CO2e.  A PSD permit would be required if an existing facility makes modifications that increase emissions inside the range set.

The proposed rule includes the six main greenhouse gases; carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs) and sulphur hexafluoride (SF6).  If the proposed rule is adopted, the rule would take effect in the spring of 2010. 

*Jonna McConaughy is Intelex's Air Emissions Specialist and is based out of Intelex's satellite location in Pittsburgh PA

The Envinronmental Protection Agency (EPA) has announced its new mandatory GHG reporting program will commence on January 1st 2010 with reports being due in 2011. The new mandatory GHG rule from the EPA brings some changes from the originally proposed rule.   Some of the changes are outlined below.

INDUSTRIES INCLUDED
Excluded from reporting are the following industries:

Electronics manufacturing Ethanol production Fluorinated GHG production Food processing Industrial landfills Magnesium production Oil and natural gas systems SF6 from electrical equipment Underground coal mines Wastewater treatment Suppliers of coal

Industries required to report include those facilities emitting more than 25,000 metric tons CO2e per year.  These industries may include fossil fuel and natural gas suppliers, vehicle and engine makers (excluding light duty vehicles/engines), cement manufacturers, paper manufacturers, chemical manufacturers and others.

MONITORING OR BEST AVAILABLE DATA
Best available data may be used for Q1 2010 in lieu of required monitoring. Extensions for use of best available data may be requested within the year 2010 but not beyond this time.

QUALITY ASSURANCE
Calibration requirements for flow meters and monitors were added.  Accuracy to 5% is specified.

REPORT SUBMITTALS
The mandatory rule specifies reports are to be submitted to the EPA. Data collection was not delegated to the states.
The EPA is working to update the consolidated emissions reporting schema (CERS), the data schema used in submittals of Emission Inventories, to include GHG data.  This standardized data format will assist in data exchange between federal, state, and local agencies as well as other GHG registries and protocols.
Reports may be submitted in an XML format via web based system that is currently under construction.

DATA RETENTION
Records must be kept for 3 years under the mandatory rule.  This is down from 5 years in the proposed rule.

END OF REPORTING
Should a facility reduce their GHG emissions under the 25,000 tons CO2e per year limit for 5 consecutive years, they may cease annual GHG reporting to the EPA.  Should a facility reduce their GHG emissions under 15,000 metric tons CO2e per year for 3 consecutive years, they may cease to report GHG emissions.  Should a facility cease GHG emitting activities or shut down completely, reporting is not required.

 *Jonna McConaughy is Intelex's Air Emissions Specialist and is based out of Intelex's satellite location in Pittsburgh PA