EPA’s Final Greenhouse Gas Mandatory Reporting Rule (GHG MRR)

What do you need to do now?

The Mandatory Reporting of Greenhouse Gases Rule was published in the federal register on October 30, 2009 and thereby the effective date is December 29, 2009.  Several provisions must be addressed in the very near term, including certain monitoring requirements. 

Next Steps?

•   Determine and document rule applicability for all potential sources at your facility.

•   Define calculation methods to be used for all applicable sources.

•   Prepare a written GHG monitoring plan which includes assigning personnel responsibility, documenting each monitor and flow meter used for GHG calculations, and their calibration requirements and frequencies.

•   Calibrate applicable monitoring equipment as required.

•   Install any required monitoring equipment (note that CO2 CEMS certification includes a RATA test and must be completed prior to January 1, 2010).

•   Define data management practices and determine responsible parties in order to begin collecting data on January 1, 2010.

•   Establish a “Designated Representative” for each facility according to § 98.4 and submit a certificate of representation at least 60 days before the deadline for the initial GHG report.

•   Determine if “Best Available Monitoring Methods” will be used past March 31, 2010, and if so, submit a written request before January 28, 2010.

Best Available Monitoring Methods (2010 only)

•    New to the rule, this provision allows reporters to use “best available monitoring methods” from January 1 to March 31, 2010 for any parameter that cannot reasonably be measured according to applicable subpart rule requirements (i.e. can’t get the equipment installed in time).

•   Extensions to the March 31 deadline will be allowed, but only if a written request is submitted within 30 days of the effective date of the rule or by January 28, 2010.

•   The rule indicates that acceptable reasons for extension include:

– The inability to receive the necessary equipment in time.

– The inability to install the necessary equipment in time.

– The inability to install without a process unit shutdown.

Accuracy Requirements

•   All flow meters and other devices (e.g. belt scales, tank level gauges, etc.) that will measure data used to calculate GHG emissions must meet accuracy and calibration requirements of §98.3(i).

•   The measurement devices must be calibrated prior to April 1, 2010 to within 5% accuracy. For each orifice, nozzle, and venturi flow meter transmitter, the Calibration Error (CE) value at each measurement point must not exceed 2.0 percent of full-scale.

•   Can delay initial calibrations of existing flow meters if a shutdown would be necessary.

•   Fuel Billing Meters are exempt from calibration requirements of the rule.

•   Your QA procedures should include a check of flow meters for proper installation.

Additional information is available on the EPA website:  http://www.epa.gov/climatechange/emissions/ghgrulemaking.html

•    Specific source categories are identified in the regulations. Each source category is assigned a unique Subpart. The USEPA has provided additional information sheets for most of these source category industries on its website: 

            http://www.epa.gov/climatechange/emissions/ghg_infosheets.html

•    Technical Support Documents are at: http://www.epa.gov/climatechange/emissions/ghg_tsd.html

•     A simplified on-line applicability tool can be used to assist potential reporters assess whether they are required to report: 

            http://www.epa.gov/climatechange/emissions/GHG-calculator/index.html