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February 2010

EPA’s New Mandatory Greenhouse Gas Emissions Monitoring, Recordkeeping and Reporting Requirements

Beginning on January 1, 2010, facilities subject to EPA’s Mandatory GHG Reporting Rule (40 CFR Section 98.2) are required to monitor GHG-emitting operations and fuel usage in accordance with specific recordkeeping methodologies and file an annual report beginning March 31, 2011.

Sources that may be impacted: Stationary fuel combustion sources including boilers, generators, process heaters, combustion turbines; electrical generating facilities; municipal solid waste landfills; pulp and paper manufacturers; importers and exporters of petroleum products; local natural gas distribution companies, suppliers of industrial GHG; and additional facilities classified under 21 other source categories.

Reporting and recordkeeping thresholds: Different thresholds apply based upon the type of source or source category of your facility:

• Stationary fuel combustion sources, including boilers, generators (non-emergency), process heaters, combustion turbines and other fuel combustion equipment with maximum rated heat input capacity equal to or greater than 30 mmBtu/hr that emit 25,000 metric tons or more of carbon dioxide equivalents (CO2e) per year.
• Electrical generation facilities that are subject to the reporting requirements of 40 CFR Part 75.
• Municipal solid waste landfills that generate methane gas in amounts equal to or greater than 25,000 metric tons of CO2e per year.
• Pulp and paper manufacturers that emit equal to or greater than 25,000 metric tons of CO2e per year.
• Suppliers of coal-based liquid fuels including all producers, importers and exporters (importing or exporting 25,000 metric tons or more of CO2e per year).
• Suppliers of natural gas and natural gas liquids including fractionators and local distribution companies.
• Suppliers of petroleum products including all producers, importers and exporters (importing or exporting 5,000 metric tons or more of CO2e per year).
• Suppliers of fluorinated gases, nitrous oxide and carbon dioxide including all producers, importers and exporters (importing or exporting 25,000 metric tons or more of CO2e per year).

Recordkeeping: Specific recordkeeping requirements apply for each source category. Records must be kept for at least 3 years and in a form that allows for expeditious inspection and review. Qualified facilities are required to begin recordkeeping on January 1, 2010. Specific rules apply for missing data computations. The records should include:

1. A list of all units, operations, processes, and activities for which GHG emission were calculated; and
2. The data used to calculate the GHG emissions for each unit, operation, process, and activity, categorized by fuel or material type.

Emission calculation methodologies: For each source category, the calculation methodology specified in the rule must be followed throughout the entire reporting period or a written explanation of the change in methodology is required.

Written GHG Monitoring Plan: Qualified facilities are required to develop GHG monitoring plans. These plans identify personnel responsible for collecting data, processes and methods used to collect data, quality assurance procedures and methods and maintenance procedures for repairing GHG monitoring equipment.

Reporting: Annual reports (certified by the designated representative) must be submitted electronically to EPA starting March 31, 2011. Abbreviated reporting is allowed under certain conditions.

Enforcement Provisions: Any violation of this rule is considered a violation of the Clean Air Act. Each day of violation constitutes a separate violation. A violation includes but is not limited to: failure to report GHG, failure to accurately collect data for GHG reporting, failure to continuously monitor and test as required, failure to retain records that verify data, and failure to calculate GHG emissions using appropriate methodologies.

For assistance with your facility’s GHG monitoring, recordkeeping and reporting program, or for more information regarding EPA’s mandatory GHG reporting rule, contact Mike Rioux, of St.Germain & Associates, Inc. at (207) 591-7000 ext. 13.

Mike Rioux is a Meteorologist and Senior Regulatory Specialist for St.Germain & Associates, Inc. with more than 20 years of experience in air emission inventories, air permitting and air auditing.

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