Published on December 10, 2010
EPA’s GHG Reporting Program: p g g Are Your Ready? Joseph Ritter December 7 2010 D b 7, www.bluescapeinc.com
Agenda• Mandatory Reporting Rule (MRR) Timeline• What has changed in 2010 that affects you• Introduction to• The takeaways• What can you do now
BlueScape, Inc. GHG inventory reporting and preparedness National PSD and Title V permitting experience Modeling – AERMOD, CALPUF Emissions inventories
Red-Line MRR Changes• Ma 27th May Subpart MM – Suppliers of Petroleum Products Denaturant that may be in ethanol products affecting calculations Treatment of products that enter the refinery, but are not processed Definition of a batch – API specific gravity and sulfur content determination Must use OTAQREG to report to EPA for those operations not e GGRT operations, e-GGRT• July 20th Subpart A – General Provisions Changed the flow meter accuracy to 6% from 5% Relaxed the requirements for the location of pressure and temp transmitters Fuel billing meters calibrations do not need to be included in the Monitoring Plan and recordkeeping Startup fuel meters are exempt from calibration requirements Gave guidance on what to do if meter calibration failed Limited extension of BAMM into 2011 if shutdown is required
Red-Line MRR Changes• July 20th, cont cont. Subpart C – Stationary Combustion Sources Changed the methodology to calculate CO2 from natural gas combustion if billing billi records provide d t i th d id data in therms Numerous additions to options and requirements under Tier 4 or CEMs monitoring Provided options to obtaining moisture content using site-specific data Significant additions and clarification for facilities in the Acid Rain Program and those that report under Part 75 Provisions for blending of fuels Considerable change or clarification on acceptable fuel sampling frequency and methods Biomass combustion
Red-Line MRR Changes• J l 20th, cont. July Subpart Y – Petroleum Refineries Added the requirement to calculate CH4 and N2O emissions from fuel gas q g Added a new equation to calculate CO2 emissions from flares Amend equations to allow 2 alternatives for “standard condition” 60⁰F and 68 ⁰F Allo use of lo er tier methodologies for units < 350 scfm or heat rate < Allow se lower nits 30 MMBtu/hr Clarified the calculation methodologies for on-site and off-site sulfur recovery plants Many others
What Should I be Doing Now?• Determine your DR, ADR, and Agents – Understand DR responsibilities• Prepare GHG inventory calculation tools – Accumulate facility background information• I would not assume e-GGRT will be easy to use• March 31, 2011 is coming soon ……
What Should I be Doing Now?• Check for e-GGRT coming on-line• Participate in EPA training sessions• Remember submission deadlines – Select DR – January 30 2011 30, – Submit 2010 Inventory – March 31, 2011
Happy Holidays Joseph RitterBlueScape Environmental 858 735 3288 email@example.com www.bluescapeinc.com p
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