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Nth Power Point Ghg Regulation 2009

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Primer on the New Mandatory Green House Gas rule

Primer on the New Mandatory Green House Gas rule


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  • 1. Presentation to: CES Climate Change Committee Mandatory Reporting of Greenhouse Gases Regulation (40 CFR 98): Background, General Requirements, and Timeframes Patrick Nortz, CPG, PE, NTH Consultants, Ltd. Kathy Gargasz, Lincoln Electric December 3, 2009
  • 2. 12/3/2009 Purpose of Presentation on the Greenhouse Gases Regulation • Why this new rule? • Overview of greenhouse gases (GHG) • Who needs to report GHG emissions • What is required and by when? • Provide a couple "industry" examples 2
  • 3. 12/3/2009 What!!! Another Rule? Why? Per the rule preamble, here are a few reasons: • Assist US EPA in assessing how to address GHG emissions and climate change under the Clean Air Act • GHG information will help EPA assess how to address GHG emissions • Track emission trends • Improve the U.S. government’s ability to formulate GHG policy This rule precedes likely requirement for GHG Emissions Controls 3
  • 4. Greenhouse Gas Reporting Rule • Can I Stop Reporting? – Basic Premise is Once In Always In – Exceptions: • Less than 25,000 Metric Tons CO2e each year for 5 years • Less than 15,000 Metric Tons CO2e each year for 3 years – Once Threshold Reached, Must Report Again 4
  • 5. 12/3/2009 All right, so you’re stuck. What is it that has to be done? Determine the Emissions of GHG Compounds: Those with Emission Equations/Factors In the Rule • CO2 • Methane • Nitrous Oxide (N2O) Others • Chlorofluorocarbons (CFCs)/Hydrofluorocarbons (HFCs) • A few others listed in Table A-1 of rule 5
  • 6. Global Warming and CO2e • How Much is 25,000 Metric Tons of CO2e? – Annual GHG Emissions from Energy Use of 2,300 Homes – Annual GHG Emissions from 4,600 Cars • What is a Metric Ton of CO2e? – The tons of CO2 emissions with the same global warming potential (GWP) as one ton of another GHG • What is Global Warming Potential? – A measure of how much a given GHG contributes to global warming 6
  • 7. 12/3/2009 Non-CO2 Greenhouse Gases Have Global Warming Potentials Carbon Dioxide Equivalent (CO2e) is the relative GHG depleting effect of a chemical as compared to CO2 (where CO2e = 1) Examples: • CO2e of methane is 21 • N2O (nitrous oxide) is 310 • CO2e of Sulfur Hexafluoride is 23,900 7
  • 8. Global Warming and CO2e Examples – 1 ton of N2O = 310 tons of CO2e – A facility emits 5,00 tons of CH4 and 100 tons of N2O • 500 x 21 = 10,500 tons • 100 x 310 = 31,000 tons • Total CO2e of Facility is 41,500 tons 8
  • 9. Sources of CO2
  • 10. 12/3/2009 According to US EPA, methane accounts for 16% of global greenhouse emissions. 10
  • 11. 12/3/2009 Who Needs to Report? • “Long List” (17 categories) of Industrial Owners/operators in rule • “Short List” of facilities that exceed 25,000 ton CO2e GHG emissions from combined stationary fuel combustion, miscellaneous use of carbonate, and all other sources in the same list. • See later slides. 11
  • 12. 12/3/2009 “Long List” GHG Owner/Operator List — Required to Submit • Electricity generation • Petrochemical production • Adipic acid production • Petroleum refineries • Aluminum production • Phosphoric acid production • Ammonia manufacturing • Silicon carbide production • Cement production • Soda ash production • HCFC-22 production • Titanium dioxide production • HFC-23 destruction • Municipal solid waste processes that are not landfills over thresholds (CH4 collocated with a HCFC- only) 22 production (with • Manure management specific thresholds) systems over thresholds • Lime manufacturing (CH4 and N20) • Nitric acid production 12
  • 13. 12/3/2009 “Short List” GHG Owner/Operator List—Required to Submit Under Certain Conditions* • Ferroalloy Production • Glass Production • Hydrogen Production • Iron and Steel Production • Lead Production • Pulp and Paper Manufacturing • Zinc Production *25K Metric tons CO2e from stationary fuel, misc. uses of carbonate, and all source categories 13 listed above
  • 14. 12/3/2009 Who Needs to Report (continued)? Others not included in previous lists: • Facilities with: • >30 mm BTU/hr aggregate maximum heat input; and • Facilities where combined stationary sources emit >25,000 ton CO2e (Lincoln Electric) • Various Suppliers and Importers/Exporters of GHG chemicals 14
  • 15. 12/3/2009 Emissions Calculations Required Use Industry-specific or other acceptable means. For example: • Flow Meters • Emission factors based off stack tests • Scales • Temperature Sensing Devices 15
  • 16. 12/3/2009 Annual Report Due by March 31 for previous year (by 2011 for 2010 ) Components (highlights): • Facility Information • Timeframes for data collection and submittal • Calculations of annual emissions of GHG (e.g., CO2e, Methane, N2O, and more) • Changes in emission calculation methods • Best available monitoring method, description, and timeframe • Certification • Other as required by facility type (may be extensive, see later slides) • Probable electronic filing to USEPA • USEPA may delegate to local/states 16
  • 17. 12/3/2009 GHG Monitoring Requirements (1 of 2) Best Available Monitoring Methods for any parameter that cannot be reasonably measured • New requirements to be met by Q1 2010 • Extension Request by December 29, 2009 • Extension requires remedy: how will you monitor in interim?...install equipment? • No extension beyond December 31, 2010 Written GHG Monitoring Plan required! 17
  • 18. 12/3/2009 GHG Monitoring Requirements (2 of 2) • Calibration Accuracy o 5% accuracy required by April 1, 2010 o Accuracy exceptions possible for outages • Must Designate a Representative to Certify GHG Plan (60 Days Ahead) • Common pipe and calibrated meter alleviates requirement for multiple-source calculations 18
  • 19. 12/3/2009 Tiers of Emission Determination (1 of 2) • Tier 1: simplest; use default emission factors • Tier 2: Calculate high heating value with equation • Tier 3: Base emissions off of carbon content of fuel or materials • Tier 4: Utilize continuous emission monitors (CEMs) to measure • Alternate Methods 19
  • 20. 12/3/2009 Tiers of Emission Determination (2 of 2) • Review each emission unit to determine which tier can be used/will be used. • Monitoring and QA/QC requirements – very prescriptive • Emission Factors: Tables C-1 and C-2 20
  • 21. 12/3/2009 A Few Specific Requirements Subpart Q – Iron and Steel Production • Mass Balance Method o Use meters and scales for inputs and outputs o Testing carbon content of inputs and outputs, over 1% of total • Site Specific Emission Factor Method o Stack test – once per year o Related to quantity of product or raw materials 21
  • 22. 12/3/2009 How Onerous it Can Be: Summary List of Requirements of Subpart HH – Municipal Solid Waste Landfills Report Monitoring, QA/QC, Records: CH4 generation Quantity of waste landfilled must be determined using accepted mass CH4 destruction – collection and combustion measuring equipt. (NIST Handbook 44) Follow Subpart C (General Stationary Fuel Combustion Sources): Must use one of six options to estimate gas composition (gas CO2, CO4, and N2O chromotagraphy or gaseous organic concentration analyzers like GEM 2000) Utilize Landfill Generation Equations (HH-1 through HH-9) to calculate: Must use an acceptable measuring device (flow meter) biannually Annual methane generation rate (without and with oxidation) calibrated in accordance with rule biannually (or as recommended by Annual Waste Acceptance Rate manufacturer). Annual quantity of recovered methane Temperature measurement devices calibrated per procedures and Annual methane emissions frequencies recommended by manufacturer Collection efficiency Documentation of procedures and calibration records, including Methane concentration (accounting for NMOCs) accuracy, for instruments or devices that measure waste disposal quantities, gas flow, gas composition, gas temperature, and gas Calculations will likely require the following input data: pressure. Tipping fee receipts (metric tons) Estimate of waste composition (e.g. diapers, garden waste, bulk Data Reporting Requirements: waste, etc.) Landfill open or closed Degradable organic carbon fractions of waste (DOC) and First year accepted waste Fraction of DOC dissimilated (DOCf) Last year (or estimated last year) LF accepted waste Fraction of methane in LF Gas from measurements (F) LF capacity Rate constants (Table HH-1) Leachate recirculation used? Waste acceptance rate (WAR) Annual disposal quantity Per capita waste disposal rates (Table HH-2) Method for estimating disposal quanitity and reason method used Percentage of generated waste that is landfilled Waste composition: Landfill capacity Muniucipal Years in which landfills first and last received waste Biosolids or biological sludges Daily average volumetric flow rate of landfill gas Other (refined categories) Daily average moisture content of landfill gas For each waste type: Daily average CH4 concentration of landfill gas DOC Temperature at which gas flow is measured (daily) Decay rate Pressure at which gas flow is measured (daily) Fraction of CH4 in LF gas Destruction efficiency (<0.99) LF Surface area and cover details (see rule 98.346 f Collection efficiency from landfill Modeled methane generation rate Fraction of hours of operation of methane destruction device For LFs without GCCSs, the annual methane emissions For LFs with GCCS: Gas collected for destruction CH4 concentration of collection gas Monthly avg temp 22 Monthly avg pressure Indication as to where destruction occurs
  • 23. 12/3/2009 How Simple it Can Be: “Other” Facilities Category Lincoln Electric: • Euclid Campus – Not in the “Long” or “Short” list of industries. o Does have >30 mmBTU/hr aggregate maximum heat input o Does emit >25,000 ton CO2e from combined stationary sources. • All sources are on a common pipe (1 reading). • Meter is calibrated by Dominion. • Gas is tested for high heating value by Dominion. (Although Lincoln Electric can use Tier 1 calculation methods –listed emissions factors– the means are there to use Tier 2, which is more accurate.) • Mentor Campus – Under the Threshold. Will not need to 23 report.
  • 24. QUESTIONS? US EPA web site on "Final Mandatory Reporting of Greenhouse Gases Rule": http://www.epa.gov/climatechange/emissions/ghgrulemaking.html Patrick Nortz, CPG, PE Kathy Gargasz NTH Consultants, Ltd. Lincoln Electric 216-344-4048 216-383-4147 pnortz@nthconsultants.com kathy_gargasz@lincolnelectric.com