Tuesday, October 6, 2009

Final EPA Greenhouse Gas GHG Rules - Emission Reporting

EPA has issued its final rule that mandates annual reporting of greenhouse gas (GHG) emissions from several sectors of US industry. Effective Jan. 1, 2010, many US industrial facilities will have to start tracking their greenhouse gas emissions. The gas emissions that will have to be tracked include carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons, sulfur hexafluoride (SF6) and others.

The EPA estimates that about 13,000 industrial facilities nationwide will be regulated under this new rule. Specific industries that will be required to track and report GHG emissions include electric power generation, cement manufacturing, glass makers, iron/steel/ferroalloy producers, lime producers, oil refiners, petrochemical processors, pulp and paper, most suppliers of industrial gases and others.

In addition, large stationary fuel combustion sources like industrial boilers, furnaces and ovens will be affected regardless of the industry in which they are used. This requirement falls only on facilities with aggregate stationary fuel combustion sources that have a total rated capacity of 30 million BTU/hr or greater and that have the potential to emit over 25,000 MTs of CO2 equivalent (CO2e) per year. However, the rule applies regardless of fuel type (coal, natural gas, propane, heating oil, residual fuel, bio-fuels, etc.).

Affected facilities will have to submit their first reports to the EPA for the calendar year 2010 by March 31, 2011 and annually thereafter. These facilities will have to come up with estimates of their GHG emissions and most will have to speciate their emissions (i.e., they cannot just group all GHGs together). EPA is expected to develop some estimating tools but these are not yet available except for certain industries. EPA is offering a series of webinars on the Rule and how to comply with it.

Caltha LLP provides specialized expertise to clients nationwide in the evaluation air, wastewater and hazardous waste rules, developing compliance procedures, and preparing cost-effective compliance programs.

For further information contact Caltha LLP at
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