EPA Proposed Mandatory Greenhouse Gas Reporting Rule

The purpose of the rule is to collect “comprehensive and accurate” data on GHG emissions that can be used to inform future policy decisions The purpose of the rule is to collect “comprehensive and accurate” data on GHG emissions that can be used to inform future policy decisions No direction on the development of emission reduction or control No direction on the development of emission reduction or control It is not meant to be a registry tracking individual projects or reductions It is not meant to be a registry tracking individual projects or reductions After it is published in the Federal Register, there will be a 60 day comment period (probably w/ additional 30 days) After it is published in the Federal Register, there will be a 60 day comment period (probably w/ additional 30 days) EPA wants to publish the final rule before the end of the year EPA wants to publish the final rule before the end of the year The proposed rule and preamble are extensive (1400+ pages) The proposed rule and preamble are extensive (1400+ pages) In addition In addition Technical Support Documents Technical Support Documents Regulatory Impact Statement Regulatory Impact Statement Overview of the Reporting Rule

Regulated Gases Mandatory reporting of GHGs would require reporting of annual emissions of: Mandatory reporting of GHGs would require reporting of annual emissions of: Carbon Dioxide (CO 2 ) Carbon Dioxide (CO 2 ) Methane (CH 4 ) Methane (CH 4 ) Nitrous Oxide (N 2 O) Nitrous Oxide (N 2 O) Sulfur Hexafluoride (SF 6 ) Sulfur Hexafluoride (SF 6 ) Hydrofluorocarbons (HFCs) Hydrofluorocarbons (HFCs) Perfluorochemicals (PFCs) Perfluorochemicals (PFCs) Other Fluorinated Gases (e.g. NF 3, HFEs) Other Fluorinated Gases (e.g. NF 3, HFEs)

Proposed Sectors and Sources

Schedule for Reporting Facilities and suppliers would begin collecting data on January 1, 2010 Facilities and suppliers would begin collecting data on January 1, 2010 First emissions report would be due on March 31, 2011 First emissions report would be due on March 31, 2011 New vehicles and engine manufacturers would start reporting w/ the 2011 model year New vehicles and engine manufacturers would start reporting w/ the 2011 model year Reports would be submitted annually Reports would be submitted annually

What Information Would be Reported? Total GHG emissions in MT of CO 2 E from all source and supply categories: Total GHG emissions in MT of CO 2 E from all source and supply categories: Gas Gas Breakdown emissions w/in each source category (e.g. unit or process level) Breakdown emissions w/in each source category (e.g. unit or process level) Activity data Activity data

How Would Reports be Submitted? Facilities would report directly to the EPA Facilities would report directly to the EPA Electronic reporting Electronic reporting Self-certification by Designated Representative Self-certification by Designated Representative

Stationary Combustion

Who Reports? Facilities w/ stationary fuel combustion sources that have emissions greater then 25,000 MT CO 2 E Facilities w/ stationary fuel combustion sources that have emissions greater then 25,000 MT CO 2 E In combination w/ other source categories process emissions In combination w/ other source categories process emissions CO 2, N 2 O and CH 4 would be reported CO 2, N 2 O and CH 4 would be reported *Table only includes facilities w/ stationary combustion equipment not covered in other subparts of the rule **CO2 emissions from biomass are not considered as part of the determination of the threshold level

CO 2 From Fuel Combustion Based on the fuel combusted and the size of the stationary equipment Based on the fuel combusted and the size of the stationary equipment Facilities w/ and aggregate maximum heat input capacity of less then 30 mmBtu/hr are automatically exempt from the proposed rule Facilities w/ and aggregate maximum heat input capacity of less then 30 mmBtu/hr are automatically exempt from the proposed rule 4-tiered approach 4-tiered approach Tier 4 –large stationary combustion units fired w/ solid fuels and have existing CEMS equipment Tier 4 –large stationary combustion units fired w/ solid fuels and have existing CEMS equipment Tier 3 –large stationary combustion units fired w/ liquids or gaseous fuels Tier 3 –large stationary combustion units fired w/ liquids or gaseous fuels Tiers 1 and 2 – simplified emissions calculations Tiers 1 and 2 – simplified emissions calculations

NO Does Unit Have Existing CEMS? YES NO 2 Do CEMS and Unit Meet Certain Conditions? 1 Tier 4: Use CEMS Similar to 40 CFR 75 YES Does Unit Burn Wood Biomass Fuels? Is Unit >250 MMBtu/hr Heat Input? Is Measured High Heating Value (HHV) Available? Tier 1 3 : Use Default HHV and CO 2 Emission Factor Tier 2 2 : Use Measured HHV and CO 2 Emission Factor Tier 3 3 : Measure Fuel Carbon Content Is a CO 2 Emission Factor for the Fuel Provided in Rule? Tier 3 3 : Measure Fuel Carbon Content Are Emission Factors and HHV for Fuel Provided in the Rule? NO YES NO YES NO YES General Stationary Fuel Combustion Requirements for CO 2 Proposed 40 CFR 98 Subpart C 1 Conditions for requiring CEMS: - >250 MMBtu/hr or >250 tons/day MWC. - Operates >1,000 hours/year. - Has Part 60 or Part 75 or state-certified gas monitor or flow rate monitor. - Meets QA/QC requirements as above. OR - <250 MMBtu/hr or <250 tons/day MWC. - Operates >1,000 hours/year. - Has Part 60 or Part 75 or state-certified certified gas monitor and flow rate monitor. - Meets QA/QC requirements as above. 2 MSW units that do not use CEMS would use Tier 2. 3 Reporters have the option of using any higher tier methodology. NO YES

Tier 4 Requires the use of certified CEMS for: Requires the use of certified CEMS for: Units that use solid fossil fuels w/ a maximum heat input capacity > 250 mmBtu/hr or a unit that combusts > 250 tons MSW/day Units that use solid fossil fuels w/ a maximum heat input capacity > 250 mmBtu/hr or a unit that combusts > 250 tons MSW/day Units combusting MSW would need to use a CO 2 monitor to calculate emissions Units combusting MSW would need to use a CO 2 monitor to calculate emissions Smaller fossil fuel-fired units (≤ 250 mmBtu/hr or 250 tons MSW/day) if all monitors needed to calculate CO 2 emission are already installed Smaller fossil fuel-fired units (≤ 250 mmBtu/hr or 250 tons MSW/day) if all monitors needed to calculate CO 2 emission are already installed Unit has operated for > 1000 hr in any calendar year since 2005 Unit has operated for > 1000 hr in any calendar year since 2005 CEMS are required by Federal or State rules or operating permit CEMS are required by Federal or State rules or operating permit CEMS are certified by meet the requirements of part 75 or part 60 CEMS are certified by meet the requirements of part 75 or part 60 CEMS must include gas or flow monitors CEMS must include gas or flow monitors EPA is allowing until January 1, 2011 to install CEMS to meet the Tier 4 requirements, until that time affected units would be allowed to use Tier 3 methodology EPA is allowing until January 1, 2011 to install CEMS to meet the Tier 4 requirements, until that time affected units would be allowed to use Tier 3 methodology Combustion units that are subject to the reporting requirements under the ARP would continue to measure CO 2 mass emissions (using the 40 CFR part 75 methods) and continue quarterly reporting of CO 2 emissions (cumulative short tons would be converted to MT) Combustion units that are subject to the reporting requirements under the ARP would continue to measure CO 2 mass emissions (using the 40 CFR part 75 methods) and continue quarterly reporting of CO 2 emissions (cumulative short tons would be converted to MT)

Tier 3 Required for liquid or gaseous fossil fuel-fired units w/ a maximum heat input capacity ≥ 250 mmBtu/hr and for solid fossil fuel-fired units that are not subject to tier 4 provisions Required for liquid or gaseous fossil fuel-fired units w/ a maximum heat input capacity ≥ 250 mmBtu/hr and for solid fossil fuel-fired units that are not subject to tier 4 provisions Requires periodic determination of the carbon content* of the fuel and direct measurement of the amount of fuel combusted Requires periodic determination of the carbon content* of the fuel and direct measurement of the amount of fuel combusted May be used to calculate facility wide CO 2 emissions when the same liquid/gaseous fuel is used across the facility May be used to calculate facility wide CO 2 emissions when the same liquid/gaseous fuel is used across the facility FuelFrequency Method of Measurement Natural Gas Monthly Calibrated Fuel Flow Meters Liquid Fuels Monthly Calibrated Fuel Flow Meters Solid Fuels Monthly Company Records Other Gaseous Fuels Daily Calibrated Fuel Flow Meters * Fuel sampling and analysis would be required only for those days/months when fuel is combusted in the unit All oil and gas flow meters would have to be calibrated prior to the first reporting year Monthly molecular weight determinations are required for gaseous fuels

Tier 2 Requires that the HHVs of each fuel combusted be measured monthly Requires that the HHVs of each fuel combusted be measured monthly Required for units w/ heat input capacities of ≤ 250 mmBtu/hr for which EPA has provided default CO 2 emission factors Required for units w/ heat input capacities of ≤ 250 mmBtu/hr for which EPA has provided default CO 2 emission factors Fuel consumption would be based on company records Fuel consumption would be based on company records

Tier 1 CO 2 emissions would be calculated using the quantity of each type of fuel combusted during the year, in conjunction w/ fuel specific default CO 2 emission factors and HHVs CO 2 emissions would be calculated using the quantity of each type of fuel combusted during the year, in conjunction w/ fuel specific default CO 2 emission factors and HHVs Fuel combusted would be determined from company records Fuel combusted would be determined from company records CO 2 emission factors and HHVs are national-level default factors CO 2 emission factors and HHVs are national-level default factors Tier 1 method may be used by any small unit if EPA has provided the fuel specific HHV and emission factor Tier 1 method may be used by any small unit if EPA has provided the fuel specific HHV and emission factor If owner routinely performs fuel sampling and analysis on a monthly basis (or more frequently) to determine HHV and other properties of the fuel, or if HHV data are provided by fuel supplier then Tier 2 method would have to be used If owner routinely performs fuel sampling and analysis on a monthly basis (or more frequently) to determine HHV and other properties of the fuel, or if HHV data are provided by fuel supplier then Tier 2 method would have to be used

CO 2 Emissions from Biomass Fuel Combustion Units that combust biomass fuels will have to report annual biogenic CO 2 emissions separately Units that combust biomass fuels will have to report annual biogenic CO 2 emissions separately This is consistent w/ IPCC and US GHG inventory framework This is consistent w/ IPCC and US GHG inventory framework Where Tier 4 is not required, reporters can use Tier 1 method for fuels in which default CO 2 emission factors and HHVs are provided Where Tier 4 is not required, reporters can use Tier 1 method for fuels in which default CO 2 emission factors and HHVs are provided If no default values are provided then reports have to use Tiers 2 or 3 If no default values are provided then reports have to use Tiers 2 or 3 For units required to use Tier 4, the rule has procedures to calculate the porting of CO 2 that is from fossil fuel vs. biogenic fuels For units required to use Tier 4, the rule has procedures to calculate the porting of CO 2 that is from fossil fuel vs. biogenic fuels For MSW, the rule has procedures to determine the portion of the CO 2 that is from biogenic fuel using the ASTM method For MSW, the rule has procedures to determine the portion of the CO 2 that is from biogenic fuel using the ASTM method

CH 4 and N 2 O Emissions Units subject to the ARP would calculate emissions from continuous measurements of fuel heat input and fuel specific emission factors Units subject to the ARP would calculate emissions from continuous measurements of fuel heat input and fuel specific emission factors Simplified emissions calculation methods Simplified emissions calculation methods Emissions would be estimated using the EPA- provided default factors and annual heat input Emissions would be estimated using the EPA- provided default factors and annual heat input

CO 2 Emissions from Sorbent Calculate CO 2 emissions from fluidized bed unit w/ sorbent injection controls or FDG using ratio of CO 2 released upon capture of acid gas Calculate CO 2 emissions from fluidized bed unit w/ sorbent injection controls or FDG using ratio of CO 2 released upon capture of acid gas

Procedures for Estimating Missing Data The rule requires the use of substitute data whenever a parameter that is used to calculate GHG emissions is unavailable The rule requires the use of substitute data whenever a parameter that is used to calculate GHG emissions is unavailable Tiers 2 or 3 Tiers 2 or 3 If HHV, fuel carbon content of fuel molecular weight data are missing, the substitute data value would be the average of the parameter immediately before and after the missing data period If HHV, fuel carbon content of fuel molecular weight data are missing, the substitute data value would be the average of the parameter immediately before and after the missing data period Tiers 3 or 4 Tiers 3 or 4 If fuel or gas flow rate data is missing, the substitute data values would be the best available estimates of these parameters, based on process and operating data If fuel or gas flow rate data is missing, the substitute data values would be the best available estimates of these parameters, based on process and operating data

Selection of Data Reporting Requirements Facility-level reporting requirements proposed under 40 CFR part 98 subpart A Facility-level reporting requirements proposed under 40 CFR part 98 subpart A Unit-level information Unit-level information Unit type Unit type Maximum heat input Maximum heat input Type of fuels combusted Type of fuels combusted Methodology used to calculate emissions Methodology used to calculate emissions Total annual GHG emissions Total annual GHG emissions Additional reporting requirements depending on the Tier methodology used: Additional reporting requirements depending on the Tier methodology used: Tier 1 – Yearly fuel usage Tier 1 – Yearly fuel usage Tier 2 – Monthly fuel usage, HHV inputs and sources of information, yearly MSW calc. input info Tier 2 – Monthly fuel usage, HHV inputs and sources of information, yearly MSW calc. input info Tier 3 – Monthly/daily fuel usage, carbon content values, molecular weight measurements, result of all fuel flow meter calibrations, methods used for carbon content determinations, flow meter calibrations and oil tank drop measurements Tier 3 – Monthly/daily fuel usage, carbon content values, molecular weight measurements, result of all fuel flow meter calibrations, methods used for carbon content determinations, flow meter calibrations and oil tank drop measurements Tier 4 – Operating days/hour; daily CO2 mass emission totals, substitute data information for CO2 concentrations, which CEMS certification and QA procedures are used, stack flow rate and moisture content Tier 4 – Operating days/hour; daily CO2 mass emission totals, substitute data information for CO2 concentrations, which CEMS certification and QA procedures are used, stack flow rate and moisture content Alternatives to unit level report Alternatives to unit level report Aggregate groups of small units (combined heat input ≤ 250 mmBtu/hr) Aggregate groups of small units (combined heat input ≤ 250 mmBtu/hr) Common stacks monitored w/ CEMS Common stacks monitored w/ CEMS Common pipeline configuration shared by oil or gaseous fuel combusting unit, firing the same fuel fed through a common supply line Common pipeline configuration shared by oil or gaseous fuel combusting unit, firing the same fuel fed through a common supply line

Selection of the Records That Must Be Retained Record keeping requirement proposed under 40 CFR part 98, subpart A Record keeping requirement proposed under 40 CFR part 98, subpart A Records must be kept for a period of 5 years Records must be kept for a period of 5 years

EPA Requests Comment on… Reporting of emissions from portable equipment or generating units designated as emergency generators in issued permits Reporting of emissions from portable equipment or generating units designated as emergency generators in issued permits Integration of fuel supplier requirements (e.g. fuel HHVs) w/ both the tier 1 and 2 calculation methodologies Integration of fuel supplier requirements (e.g. fuel HHVs) w/ both the tier 1 and 2 calculation methodologies Use of more technology-specific CH 4 and N 2 O emission factors that could be applied in unit-level calculations Use of more technology-specific CH 4 and N 2 O emission factors that could be applied in unit-level calculations Exemption for facilities that have an aggregate combined heat input capacity of less then 30 mmBtu/hr from stationary combustion units Exemption for facilities that have an aggregate combined heat input capacity of less then 30 mmBtu/hr from stationary combustion units