Greenhouse Gas Reporting Rule

Andrew D. Shroads, QEPRegional Director, SC&A, Inc.

P.O. Box 1276 • Westerville, OH 43086

(614) 432-2557

ashroads@scainc.com

EXPLAINED

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Presentation Funding

All expenses associated with this training seminar were paid for by a grant from the Ohio Environmental Education Fund, with matching funds from S. Cohen & Associates.

Additional support provided by:

www.epa.ohio.gov/eef

Wood County Park District

your natural places for funwww.woodcountyparkdistrict.org

www.cvnpa.org

www.scainc.com

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What are Greenhouse Gases?

Gases that absorb thermal infrared radiation (heat), making the Earth about 59º F warmer than without the gasesThere are several greenhouse gases (GHGs); six are regulated by this rule:1. Carbon Dioxide (CO2)2. Methane (CH4)3. Nitrous Oxide (N2O)4. Perfluorocabons (PFC)5. Hydrofluorocarbons (HFC)6. Sulfur Hexafluoride (SF6)

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Not All Greenhouse Gases Are Equal

Each GHG has a capacity to absorb heat, known as global warming potential (GWP): Carbon Dioxide (CO2): 1 Methane (CH4): 21 Nitrous Oxide (N2O): 310 Hydrofluorocarbons (HFC): 11–14,900 Perfluorocabons (PFC): 6,500–17,340 Sulfur Hexafluoride (SF6): 23,900

Total GHG emissions are listed in carbon dioxide equivalent (CO2e) emissions - GHG multiplied by its GWP; 40 CFR 98 Table A-1

1 21 310 11

14,900

6,500

17,340

23,900

CO

2

CH

4

N2O

HF

E-2

63fb

2

HF

E-1

25

PF

C-1

4

PF

C c

-C3F

6

SF

6

GW

P

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Example: GHG & GWP

My home burns 100,000 cf/year N.G., emitting:12,001.12 lbs. CO2

0.20 lbs. CH4

0.02 lbs. N2O From 40 CFR 98, Tables A-1, C-1, C-2

To calculate the total CO2e emissions, multiply each pollutant by its GWP (CO2 = 1, CH4 = 21, and N2O = 310).

12,001.12 lbs. CO2 × 1 = 12,001 lbs. 0.20 lbs. CH4 × 21 = 4 lbs. 0.02 lbs. N2O × 310 = 6 lbs. Total CO2e 12,011 lbs. (6 U.S. short tons)

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Greenhouse Gas Timeline - I

1863John Tyndall lectures about Earth’s atmosphere exhibiting a “greenhouse effect”

1896Svante Arrhenius develops theory relating carbon dioxide (CO2) concentration to temperature changes

1958Dr. Charles Keeling begins measuring atmospheric CO2

1990International Panel for Climate Change Report: Emissions from humans are substantially increasing greenhouse gas concentration and warming the Earth

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Greenhouse Gas Timeline - II

1997Kyoto Protocol ratified – legally binding commitments to reduce GHG emissions

2005Kyoto Protocol takes effect

2007Bulletin of Atomic Scientists moves Doomsday clock to 11:55 PM, due to global warming

2009Environmental Protection Agency (EPA) proposes greenhouse gas regulations

March 31, 2011First GHG emissions report (C.Y. 2010) due to EPA

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Reason for Regulating – Global Temperature

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Federal Greenhouse Gas Reporting Rule

U.S. EPA was directed by Congress to enact a regulation requiring GHG emissions reports, “above appropriate thresholds in all sectors of the economy of the United States.” FY2008 H.R. 2764; Public Law 110–161Title 40 of the Code of Federal Regulations, Part 98, (40 CFR 98) was issued in December, 2009Calendar year 2010 will be the first reportCalendar year emissions will be reported by March 31 of the following year, (i.e. 2010 report due March 31, 2011)

March 31, 2011

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Federal GHG Reporting Rule Overview

25 categories of commercial / industrial / institutional sources, with an additional 4 categories proposed5 categories for producers / suppliers, with 2 proposedCategories specify monitoring and record keepingGHG emissions will be reported in each applicable category and as a total for the facilityGHG reporting rule does not contain emissions restrictions or reduction requirementsReport will be online; currently unavailableGHG reporting rule proposed and data verified by EPA Office of Atmospheric Programs (OAPS), not Office of Air Quality Planning & Standards (OAQPS)

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Do I Have to Report?

There are four categories of facilities:I. Facilities “on the list,” large producers of GHG

emissions (e.g. power plants, refineries)II. Facilities “on the other list” and emit ≥25,000 metric tons

(MT) of CO2e/year, (e.g. glass production)III. Facilities with a maximum rated heat input capacity of

≥30 MMBTU/hour from stationary combustion units and emissions of ≥25,000 MT CO2e/year

IV. A supplier, importer, exporter, or producer of natural gas, petroleum products, industrial GHGs (e.g. CO2)

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Reporting Category I – Large Emitters

Any of the following operations emitting GHGs:- Electricity Generation (Subject to 40 CFR, Part 75)- Adipic, Nitric, or Phosphoric Acid Production- Aluminum, Cement, HCFC-22, Petrochemical, Silicon

Carbide, Soda Ash, and Titanium Dioxide Production- Ammonia and Lime Manufacturing- Petroleum Refineries- Processes Destroying >2.14 MT HFC-23 per year and

not co-located with an HCFC-22 Production Facility- Municipal Solid Waste Landfill ≥25,000 MT CO2e/year- Manure Management Systems ≥25,000 MT CO2e/year

Congress prohibited EPA from implementing this part

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Reporting Category II – Medium EmittersFacilities emitting ≥25,000 MT CO2e/year combined from all of the following operations:- Stationary Fuel Combustion- Miscellaneous Use of Carbonates- Ferroalloy Production- Glass Production- Hydrogen Production- Iron and Steel Production- Lead Production- Pulp and Paper Manufacturing- Zinc Production

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Reporting Category III – Fuel CombustionFacilities emitting ≥25,000 MT CO2e/year from all stationary fuel combustion sources and the aggregate maximum rated heat input capacity of all of the stationary combustion units at the facility is 30 million British thermal units per hour (MMBTU/hour) or greater.

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Reporting Category IV – Suppliers

Suppliers, importers, and exporters of any of the following products:- Coal-to-liquid products- Petroleum products- Natural gas and natural gas liquids- Industrial greenhouse gas, including carbon dioxide

Importer/Exporter subject only if ≥25,000 MT CO2e The following production and supply operations:- Petroleum refineries distilling crude oil- Natural gas fractionators- Local natural gas distribution companies- Industrial greenhouse gas producers

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GHG Reporting Applicability - I

Category I:If a process is listed, the rule is applicableCategory II:Rule is applicable if combined emissions from all listed processes are ≥25,000 MT CO2e/yearCategory III:Rule is applicable if stationary fuel combustion are ≥30 MMBTU/hour and emitting ≥25,000 MT CO2e/yearCategory IV (Importer/Exporter):Material supplied must cause ≥25,000 MT CO2e/yearCategory IV (Producer):If material is produced or supplied, rule is applicable

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GHG Reporting Applicability - II

Source in Category 1?

No

Yes

Source in Category 2?

Stationary Combustion?

No

Yes

Yes

Emit ≥25,000 MT/year CO2e?

Maximum Aggregate Heat

Input ≥30 MMBTU/hr?

Subject to RuleYes

Yes

Not Subject to Rule

No

No

No

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What Sources Do I Include?

Reported GHG emissions may differ from GHG emissions used to determine category applicability

Category I:Emissions report must include any source in all 25 categoriesCategory II:Emissions report must include any source in all 25 categoriesCategory III:Emissions report for stationary fuel combustion onlyCategory IV:Emissions from any material in all 5 supplier categories

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Example: GHG Sources & Calculations

Iron & Steel Production Facility1. Applicability: Calculate GHG emissions from steel processing and stationary fuel combustion sources2. Report:- Integrated Iron & Steel Processing- Stationary Combustion Sources- Electrical Equipment (proposed)- Wastewater Treatment (proposed)- Industrial Landfill (proposed)

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Reporting Exemptions

Research & development activities: Activities conducted in process units or at laboratory bench-scale settings whose purpose is to conduct research and development for new processes, technologies, or products and whose purpose is not for the manufacture of products for commercial sale.

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Defining Facility

Per the GHG reporting rule, a facility is defined as:Physical property, plant, building, structure, source, or stationary equipment;On contiguous or adjacent properties;In actual physical contact or separated solely by public roadway or other public right of way; andUnder common ownership or common control

This definition differs from Title V and National Emissions Standards for Hazardous Air Pollutant definitions for facilities that include properties several miles apart.

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Determine GHG Reporting Applicability - IEmissions InventoryWhat operations are emitting GHGs at the facility?

1. Review current air permits. Look for sources burning fuel or emitting carbon monoxide, sulfur dioxide, and/or nitrogen oxides; these could be GHG sources.

2. Review purchase records. If SF6, PFC, and HFC are being purchased, they are likely being emitted.

3. There are 25 categories (subparts) of GHG sources in the rule. Each subpart details what sources in that category are required to report GHG emissions.

Only include if in the rule

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Determine GHG Reporting Applicability - IIEmissions CalculationsWhat amount of GHGs are being emitted?

1. Each of the 25 subparts details what types of GHGs are being emitted and how to calculate CO2e. Only calculate emission using the emissions factors and calculations included in the rule.

2. The online EPA applicability calculator includes calculations for stationary source combustion and municipal solid waste landfills.

If it is not in the rule,do not calculate

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Resource: Fuel Combustion Factors

Since stationary fuel combustion is one of the largest source categories, the following are emissions factors for selected fuels: (From 40 CFR 98 Table A-1, C-1, and C-2)

Natural Gas: 5.456×10-5 MT CO2e/cubic foot#2 Fuel Oil: 1.024×10-2 MT CO2e/gallon#6 Fuel Oil: 1.130×10-2 MT CO2e/gallon

The following amounts of fuels combusted generates 25,000 MT CO2e:

Natural Gas: 458.2 million (MM) cubic feet/year#2 Fuel Oil: 2,441,223 gallons/year#6 Fuel Oil: 2,212,121 gallons/year

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Resource: EPA GHG Applicability Tool

www.epa.gov/climatechange/emissions/GHG-calculator

Select source categories from the list, calculate annual CO2e emissions, and the results will detail rule applicability and appropriate subparts. EPA GHG hotline: 877-GHG-1188

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Discontinuing Reporting

Emissions must be reported each year, even if emissions are reduced below 25,000 MT CO2e; however, there are three possible methods whereby a facility can reduce emissions and cease reporting:1. Emissions are less than 25,000 MT CO2e

for five consecutive years;2. Emissions are less than 15,000 MT CO2e

for three consecutive years; or3. ALL applicable GHG-emitting processes cease to operate; not applicable to municipal solid waste landfills.

Instead of a final report, a cessation notification is submitted.

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Signing the Report - I

Designated Representative (DR): an individual having responsibility for the overall operation of the facility

Plant manager; Superintendent; Operator of a well or a well field; Position of equivalent responsibility; or Position having overall responsibility for environmental

matters for the company. If subject to 40 CFR 75, must be same individual.

Can delegate alternate designated representative (ADR) Can be the same as the “responsible official” for Title V

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Signing the Report - II

Certificate of Representation:Submitted by the DR and ADR to EPA at least 60 days prior to a GHG due date (January 28, 2011);Separate from the GHG Report;Lists the owners or operators for the facility;EPA will be developing a form;Certifies that the DR and ADR have a written “document of agreement” with the owners or operators of the facility;DR and ADR actions are binding upon the facility owners and operators.

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Signing the Report - III

Agent:The DR or ADR can further delegate to an agent;An agent submits the report on behalf of the DR or ADR;Agent can be anyone within or outside the organization;Agent is given authorization to EPA by DR or ADR;EPA will develop a form authorizing agent to submit data to EPA.

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Recordkeeping Requirements

The following records are required: Every unit for which GHG emissions were calculated Data used in GHG calculations, required in a Subpart Copies of the annual GHG reports submitted Any missing data computations Written GHG monitoring plan Certification results and maintenance records for

instruments required in a Subpart Any additional records required in a SubpartAll records must be maintained onsite and readily accessible for three years

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Additional Recordkeeping Requirements

Each Subpart requires additional recordkeeping specific to the SubpartAny information collected to estimate GHG emissions within a Subpart must be maintained with the GHG emissions report for at least three yearsAny instances where data was extrapolated for missing data periods, along with the methodology used to extrapolate the missing data

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GHG Monitoring Plan

Each facility must develop a written GHG Monitoring Plan (GHGMP) that details the following procedures:1. Positions responsible for collecting GHG data2. Processes / methods for collecting GHG data3. Procedures used for quality assurance, maintenance,

and repair of monitoring systems and equipment4. Delegation Agreement and Certificate of Representation

The GHGMP can reference existing documents, provided that the requirements are easily identified.

EPA can request a copy of the GHGMP or review the GHGMP during an audit.

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Enforcement

U.S. EPA is the sole enforcer of these regulations; the Ohio EPA or local air agencies have not been given the power to enforce this rule, at this time. Currently, Ohio does not have a GHG reporting requirement.

EPA will conduct reviews and audits of the GHG emissions reports and applicable facilities and ensures that data submitted as part of the GHG report matches emissions reports.

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End of General Subpart

Intermission

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Subpart C: Stationary Fuel Combustion - IApplicability:

All stationary units that combust fuels (e.g. boilers, engines, process heaters, incinerators)Does not include: Portable sources Emergency generators (emergency

use only; no load reduction) Flares, unless specified in another

Subpart (e.g. Petroleum Refinery) Hazardous waste combustion

(unless another fuel is used)EPA website has an emissions calculator for Subpart C

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Subpart C: Stationary Fuel Combustion - IIGHG to report: CO2, CH4, and N2O Calculation Methods (Tiers):

1. Fuel Usage × Default Heat Factor × GHG FactorDefault heat factor – average heating value per amount of fuel, (e.g. MMBTU/CF); Table C-1

2. Fuel Usage × Measured Heat Factor × GHG FactorMeasured heat factor - heating value per amount of fuel

3. Fuel Usage × Fuel Carbon Content × 44 (CO2)/12 (C)Measured carbon content - percent of carbon in fuel

4. Continuous Emissions Monitoring System (CEMS)Measured carbon emissions rate exiting stack

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Subpart C: Stationary Fuel Combustion - IIIUsing Calculation Method Tier 1

Unit Maximum Rated Heat Capacity ≤250 MMBTU/hourFuel used is listed in Table C-1: Gases:

Natural Gas, Blast Furnace Gas, Coke Oven Gas Petroleum Products:

Fuel Oil, Kerosene, LPG, Gasoline Solids:

Coal, Municipal Solid Waste, Tires Biomass:

Peat, Rendered Animal Fat, Wood, Biogas, BiodieselCannot use if fuel heating value is analyzed

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Subpart C: Stationary Fuel Combustion - IVUsing Calculation Method Tier 2

Unit Maximum Rated Heat Capacity ≤250 MMBTU/hr or >250 MMBTU/hr, if firing natural gas or distillate fuel oilFuel used is listed in Table C-1Municipal Solid Waste (MSW) units that produce steam or are rated ≤250 tons per day (tpd) of MSW

Using Calculation Method Tier 3Any unit that cannot use Method 1 or 2 and is not equipped with a CO2 CEMS (Method 4)

Using Calculation Method Tier 4Units equipped with a CO2 CEMS must use Tier 4

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Subpart C: Stationary Fuel Combustion - VFuel Analysis (Tiers 2 & 3):

Periodic fuel analyses for fuels listed in §98.34(a) Natural Gas – Semiannual analyses Coal & Fuel Oil – One from each delivery Liquid & Gas (not Fuel Oil or Natural Gas) – Once per

calendar quarter Solid (not Coal) – Weekly samples analyzed monthlyFrom Ohio EPA air permit: For each shipment of oil received for burning in this emissions unit, the permittee shall collect … a representative grab sample of oil and maintain records of the … analyses for sulfur content and heat content…

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Subpart C: Stationary Fuel Combustion - VIAdditional Fuel Analysis Requirements:

Fuel sampling is only required if the unit operates within the time period for fuel analysis (e.g. calendar quarter)For blended fuels, either use a weighted heating value, based on the proportions of fuels within the blend or have a representative blended fuel sample analyzedOil or gas flow meters (Tier 3) must be calibratedFuel billing meters (if provided by a separate owner) can be used in lieu of oil or gas flow metersFor missing analysis data, use the average of the before and after values.

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Subpart C: Stationary Fuel Combustion - VIIMiscellaneous Requirements:

If two or more fuels are fired in the same unit, different Tiers can be used for each fuel, (i.e. Tier 2 for distillate fuel oil and Tier 1 for natural gas)If Tier 4 is used, no other Tier may be usedThere are two alternative methods for Tier 4 units that are not subject to Acid Rain provisions or the CO2 emissions data provisions of 40 CFR 75To calculate CH4 and N2O emissions, use the appropriate GHG emissions factor. Tiers 1 and 3 use the Tier 1 Calculation Method. Tiers 2 and 4 use the Tier 2 Calculation Method

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Subpart C: Stationary Fuel Combustion - VIIISorbent Control Technologies:

If sorbent injection (fluidized bed, acid-gas emissions control, or wet flue gas desulfurization) is used on the source, sorbent CO2 emissions must be includedGHG emissions are calculated by multiplying the amount of sorbent used by the stoichiometric ratio of sulfur reacting with carbon (assumed to be 1:1)

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Example – Fuel BurningGHG vs. Next Highest Pollutant

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Subpart D: Electricity Generation

Applicability:Stationary electricity generating units subject to Acid Rain (Title IV) or 40 CFR 75 requirementsDoes not include portable sources or emergency generators used for emergency purposes only

GHG to report: CO2, CH4, and N2O

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Subpart K: Ferroalloy Production

Applicability:Any facility using pyrometallurgical techniques to produce ferrochromium, ferromanganese, ferrovanadium, ferromolybdenum, ferronickel, ferrosilicon, ferrotitanium, ferrotungsten, silicomanganese, or silicon metal

GHG to report: CO2, CH4, and N2O

Calculation Methods:For process emissions, a CEMS is requiredFor electric arc furnace (EAF) emissions, either a CEMS or a mass balance equation may be used.

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Subpart N: Glass Production

Applicability:Facility manufacturing flat glass, container glass, pressed & blown glass, or wool fiberglass by melting a mixture of raw materials and forming them into shapesExperimental or research & development glass furnaces are not applicable to this Subpart

GHG to report: CO2, CH4, and N2O

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Subpart N: Glass Production - II

Calculation Methods:Mass balance - carbonate in raw materials (% by weight) multiplied by amount of carbonate containing raw material charged in each furnace multiplied by the GHG emissions factor and the calcination fractionMass balance - GHG emissions from stationary fuel combustion in glass furnaces - use Subpart CEmploy a CEMS

Data Collection:Raw material suppliers or chemical analysis provides the carbonate fraction of raw materialsX-ray fluorescence test for calcination fraction

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Subpart P: Hydrogen Production

Applicability:Facilities that produce hydrogen for commercial saleUnits producing hydrogen by reforming, gasification, oxidation, reaction, or other feedstock transformation

GHG to report: CO2 CH4 and N2O

Calculation Methods:Employ a CEMSMass balance - feedstock volume multiplied by average carbon content

H2

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Subpart Q: Iron & Steel Production - I

Applicability:Taconite iron ore processing, integrated iron and steel manufacturing, and cokemaking or electric arc furnace (EAF) steelmaking not co-located with integrated iron and steel manufacturingIntegrated iron and steel manufacturing includes Basic Oxygen Furnaces (BOF), sinter process, decarburization vessel, and direct reduction furnaceBlast furnace / coke oven gas flares, report as stationary fuel combustion, calculated using Subparts C & Y

GHG to report: CO2, N2O, and CH4

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Subpart Q: Iron & Steel Production - II

Calculation Methods:Employ a CEMSMass Balance - calculate CO2 emissions from each applicable process by multiplying all process inputs by carbon content for each material, excluding carbon in product, waste materials, and collected by air pollution control equipmentSite-specific emissions factor - conduct an air emissions test to measure CO2 emissions from all applicable process exhaust stacks, based on feed or production rate. Emissions factor is emissions rate divided by feed or production rate.

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Subpart U: Miscellaneous Carbonate Use - IApplicability:

Processes consuming ≥2,000 tons per year of carbonates, heated to allow a calcination reaction• Limestone • Dolomite• Ankerite • Magnesite• Siderite • Rhodochrosite• Sodium Carbonate • Barium & Potassium

Carbonates (proposed)

Does not include carbonates used in the manufacture of cement, glass, ferroalloys, iron & steel, lead, lime, soda ash, phosphoric acid, pulp & paper, sodium bicarbonate, sodium hydroxide, zinc, or sorbent control technology.

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Subpart U: Miscellaneous Carbonate Use - IIGHG to report: CO2

Calculation Methods:Calcination fraction - mass of carbonate consumed multiplied by GHG emissions factor (Table U-1) multiplied by fractionation calcination for carbonateMass Balance – mass of output carbonate multiplied by GHG emissions factor (Table U-1) subtracted from mass of input carbonate multiplied by GHG emissions factor (Table U-1)

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Subpart AA: Pulp & Paper Manufacturing-IApplicability:

Facilities that produce “market” pulp, manufacture pulp and paper, produce paper products from purchased pulp, produce secondary fiber from recycled paper, convert paper into paperboard products, or operate coating and laminating processesGHG emissions calculated from chemical recovery furnaces at kraft and soda mills, sulfite facilities, stand-alone semi-chemical facilities; pulp-mill kilns and kraft and soda facilities; and systems for adding makeup chemicals at chemical pulp mills.

GHG to report: CO2, CH4, and N2O

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Subpart AA: Pulp & Paper Manufacturing-IICalculation Methods:

All Facilities - Subpart C, Tier I for fossil-fuel combustionKraft or Soda Facilities – Calculate biomass emissions by multiplying spent liquor solids mass combusted by its heating value and GHG emissions factor (Table AA-1)Sulfite or Stand-alone Semi-chemical - Calculate biogenic emissions by multiplying spent liquor solids mass combusted by carbon contentPulp mill lime kiln - Biogenic emissions are included in chemical recovery furnace emissions calculationsMakeup chemical use - amount of makeup chemicals added multiplied by ratios of molecular weight of calcium carbonate and sodium carbonate to CO2

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Subpart HH: Landfills - I

Applicability:Municipal solid waste (MSW) landfills that accepted waste on or after January 1, 1980Does not include hazardous waste landfills, dedicated construction and demolition landfills, or industrial landfillsProcess include landfills, landfill gas collection systems, and landfill gas destruction devices (including flares)

GHG to report: CO2, N2O, CH4 and CH4 destruction

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Subpart HH: Landfills - II

Calculation Methods:Emissions are reported as modeled emissions rates, based on length of time landfill has operatedIf tipping fee receipts or other historical records are unavailable, the landfill can estimate amount of waste: Assume waste is equivalent to the first year quantity Estimate the population served and utilize national

waste generation averages (Table HH-2) Assume a constant average annual waste disposedEmissions factors and other data for the air emissions model are provided in Table HH-1

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Subpart HH: Landfills - III

Calculation Methods (continued):For gas collection systems, the amount of CH4 destroyed is calculated with data obtained either from a continuous gas collection monitoring system or personnel monitored parameters obtained on a weekly basisThe amount of CH4 recovered is calculated from the daily average CH4 concentration in the gas recovered, converted into daily CH4 recovery valuesTotal CH4 emissions are the generation rate minus the oxidation rate (assumed to be 10%) minus CH4 recoveryFlare CO2 emissions are not counted

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Overview

Five things to remember:1. Only calculate emissions for processes in the rule2. Calculate GHG emissions by using the methods outlined

in the rule ONLY3. The GHG emissions calculated to determine rule

applicability (i.e. 25,000 metric tons CO2e) may be different from GHG emissions calculated for the report

4. New sources of air pollution are regulated; SF6, PFC, and HFC are new regulated air pollutants from this rule

5. Document, record, and save

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Any Questions?

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More GHG Regulations-I

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More GHG Regulations - II

Proposed Subparts for the GHG Reporting Rule:1. Subpart W - Petroleum and Natural Gas Systems2. Subpart RR - Carbon Dioxide Injection and Geologic

Sequestration3. Subpart I - Electronics Manufacturing4. Subpart L - Fluorinated Gas Production5. Subpart QQ - Imports and Exports of Equipment Pre-

charged with Fluorinated GHGs or Closed-cell Foams6. Subpart DD – Use of Electric Transmission and

Distribution Equipment7. Subpart SS - Manufacture of Electric Transmission and

Distribution Equipment

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More GHG Regulations - III

June 15 Modifications to GHG Reporting Rule:Affected Subparts: E, H, K, N, O, P, Q, S, V, Z, CC, EE, GG, HH, LL, MM, and NNChanges to correct cross referencesAdditional information to better or more fully understand compliance obligations in a specific provisionAmendments to certain equations to better reflect actual operating conditionsCorrections to terms and definitions in certain equationsCorrections to data reporting requirements so that they more closely conform to the information used to perform emission calculations

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More GHG Regulations - IV

Tailoring Rule (GHG under Clean Air Act):EPA has issued a final rule regulating GHGs as air pollutants and requiring permits to emit themGHGs will be regulated in the federal permits: Title V (operating permit) & Prevention of Significant Deterioration (installation permit)If there are sources of GHG at the facility, sources will become part of permit(s)Permits will be required for sources that are not currently in issued permitsReview existing sources and ensure all air pollution sources categorized appropriately

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More GHG Regulations - V

Congressional Reaction:On June 10, the Senate defeated a proposal from Sen. Lisa Murkowski, disapproving of EPA ruling that CO2 poses a threat to human healthSen. John Rockefeller has proposed a bill in the Senate delaying EPA from enforcing its Tailoring Rule for two years. A companion bill was proposed in the HouseSen. Joe Lieberman and Sen. John Kerry proposed a bill where GHG would be regulated separate from the Clean Air Act

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Thank You

The End