EPA signed the final Mandatory Reporting of Greenhouse Gases (GHG) Rule on September 22, 2009. It should be published in the Federal Register in the next month. The rule requires that facilities that emit 25,000 metric tons or more per year of GHG emissions submit annual reports to the EPA. In 2010, the primary reporting obligation for pipeline operators will be reporting GHG emissions from fuel combustion sources (Subpart C) from facilities emitting above the GHG emission threshold. Some handy rules of thumb for activities that would emit 25,000 metric tons of GHG emissions are:
- burning 2.8MM gallons motor gasoline,
- 2.5MM gallons diesel fuel, or 457MM scf of natural gas (about $2M worth per year, at $5 / kscf); or
- running an engine (or engines), assuming 35% efficiency, on diesel fuel full time for a year at 5,000 HP, or on natural gas at 7,000 HP.
A monitoring plan will be required at each location to document
procedures for collecting data for GHG emission calculations, as well as QA/QC
The first reports are due March 31, 2011 for 2010 emissions. The primary reporting obligation will be for GHG emissions from combustion sources (Subpart C), i.e., engines, turbines, heaters, boilers, based on fuel consumption (flares are not included). There is more detail in the rule related to fuel measurement.
The EPA has delayed finalization of “Subpart W” for Oil and Natural Gas Systems. As a result, there is no requirement to submit reports for 2010 emissions from fugitives, tanks, vents, dehydrators, flares, treaters, etc. EPA may re-issue Subpart W as a proposed rule for public comment late this year or early 2010, with the goal to have this subpart finalized such that data collection can begin on January 1, 2011.
Data for the January – March 2010 period has a lower standard and allows using “best available data.” This allows 3 additional months to put the required measurement equipment in place. If more than 3 months are needed, an extension is available to use “best available data” through Dec. 31, 2010. Any requests for an extension must be submitted within 30 days after the rule is published in the Federal Register.
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