Greenhouse Gas (GHG) Reporting Rule - afsinc.net with GHG-Schifo.pdf · American Foundry Society -22nd EHS Conference August 23 -25, 2010, Nashville, TN Greenhouse Gas (GHG) Reporting

American Foundry SocietyAmerican Foundry Society--22nd EHS Conference22nd EHS Conference

August 23August 23--25, 2010, Nashville, TN25, 2010, Nashville, TN

Greenhouse Gas (GHG)Reporting Rule

Jim Schifo, PE, VP

[email protected]

KERAMIDA Inc.



Discussion Items

�Climate Change –Background

�Greenhouse Gas (GHG) Reporting Requirements –EPA

�AFS Recommendations



Remember

Kyoto GHGs & Global Warming Potentials

GWP – Effect compared to Carbon Dioxide

� CO2 1

� CH4 23

� N2O 296

� HFCs Varies, most 1,000s

� PFCs Varies, most 1,000

� SF6 22,200 Intergovernmental Panel on Climate Change - Third Assessment Report

Carbon Dioxide Equivalents (CO2e) are calculated using the above ratios.



Greenhouse Gas Reporting Rule –

EPA � GHG Reporting Program Mandated by Congress December 2007

� Final Rule Signed September 22, 2009

� Published October 30, 2009 Federal Register

� Effective December 28, 2009



GHG Reporting Rule

� EPA Chose to Capture 25,000 Metric Tons CO2e Emitters

� EPA Estimates Rule Will Affect 13,000 Sources,

� GHG Reporting Rule is estimated to capture 85-90% of GHG Emissions



GHG Reporting Rule

Upstream Production

� Emissions From Products That Reporters Supply� Engines (except Light Duty Vehicles)

� Coal-to-Liquids Suppliers

� Petroleum Product Suppliers

� Natural Gas and Natural Gas Liquids Suppliers

� Fluorinated GHG and N2O Suppliers

� CO2 Suppliers

6



GHG Reporting Rule

Downstream Sources

� 17 Categories of Sources Regardless (All-in)

� Electric Generation that report CO2 under ARP

� Aluminum Production

� HCFC -22 Production

� HFC-23 Destruction Processes (not co-located with

HCFC-22 Production & that destroys more than 2.14

metric tons HCF-23

� -----------

7



GHG Reporting Rule

Downstream Sources (cont.)

� 7 Categories of Sources That Emit 25,000 MT CO2e

(Threshold Categories)

� Ferroalloy Production

� Glass Production

� Hydrogen Production

� Iron & Steel Production

� Lead Production

� Pulp & Paper Production

� Zinc Production

8



GHG Reporting RuleDownstream Sources (cont.)

40 CFR 98.30 General Stationary Fuel Combustion

� Stationary Fuel Combustion with total heat capacity

>30 MMBtu/hr

� 25,000 metric tons of CO2e or more per year

� Certain source categories have deferred

requirements.

9

Metalcasting Facilities Fit into the Stationary

Combustion Category for GHG Reporting



GHG Reporting Rule


� Not one of the 36 previously listed

� Need only report CO2, CH4, and N2O from fuel combustion

� Need not report other sources of GHG, e.g. HFC

� Emergency and Portable Equipment Exempt

10




� Includes a Four Tier Structure of emission calculations.

� Metalcasting facilities will likely use the Tier 1 approach

involving the use of emission factors from Table C-1.

(But could use Tier 2 with HHV Determinations)

� Emissions can be combined in some cases for

reporting purposes. (Natural Gas emissions based on

main facility meter representing all natural gas fired

sources.)



GHG Reporting Rule – General

Requirements

12

� Report 2010 Emissions by March 31, 2011

� Designated Representative, and Alternate, submits Certificate of Representation to EPA. (January 30, 2010 – 60 days prior to Reporting Date)

� CO2 From Biogenic Fuels Excluded from Applicability (CH4 and N2O Count), But Reported Separately When Applicable

� Annual Reporting

� Once In, Always In, Now With Escape Hatch

� Self Certification

� EPA is Verifier



GHG Reporting Rule – Monitoring

Requirements

� GHG inventory requirements went into affect on

January 1, 2010 and Monitoring Requirements

also needed to be in place and documented.

� Temporary “Best Practice” monitoring plans

allowed to be used until March 31, 2010. (Until

required monitoring equipment is installed.)



Additional Sources Proposed

April 12, 2010 Federal Register

� Oil and Gas Industry

� Carbon Dioxide Sequestration Sites

� Numerous Fluorinated GHG

Categories

� Corporate Parent, NAICS Codes,

Cogeneration



Numerous Technical Corrections

Signed May 27, 2010

� Affects Most Subparts, But Not Stationary Fuel

Combustion

� Corrections to cross references,

� Additional information to better understand

compliance obligations,

� Amendments to equations to better reflect actual

operating conditions,

� Corrections to better match data reporting to

emissions calculations



Additional Source Categories Re-proposed

Signed May 27, 2010

� Electronics Manufacturing

� Fluorinated Gas Production

� Importers/Exporters Pre-charge GHG

and Foam

� SF6 and Perfluorocarbons from

Electrical Equipment Manufacturing

or Refurbishment



Additional Source Categories Finalized

Signed June 28, 2010

� Magnesium Production

� Underground Coal Mines

� Industrial Waste Water Treatment

� Industrial Waste Landfills



Treatment of Confidential Business

Information Proposal Signed June 28, 2010

� §114(c) All information submitted to EPA shall be

available to the public

� Except trade Secrets and CBI, “likely to cause

substantial harm to business’s competitive position”

� Except “emissions data” cannot be considered CBI

� 40 CFR2, Subpart B EPA generally makes case-by-

case decisions



Treatment of Confidential Business

Information Proposal Signed June 28, 2010

Emissions Data

� Information necessary to determine the amount and

characteristics of any pollutant emitted by the source

� Information necessary to determine the amount and

characteristics of any pollutant authorized to be

emitted by a source

� General description of the location and nature of a

source



So what do I do now?

� If you know you are above 25,000 metric

tons of CO2e then you should be well along

with the program.

� If you don’t know, then figure it out. Use the

GHG Emissions Calculator on AFS Web

Site to Estimate your likely GHG emissions

for 2010.



GHG Reporting Rule – Monitoring

Requirements – What to do NOW? If your in:

� Document your Monitoring Plan.

� Monthly accounting of fuel use.

� Monitoring method

� Natural Gas Meter readings

� Coke usage

� Liquid Fuels

� Listing of Description, ID, Fuel Rating of Emission Units

� Calibration Procedures for Measurement Devices

� Coke Scales -----

� Maintain Monitoring Plan on Site

� FOLLOW THE PLAN



What Size Metalcasting Facility will be

reporting?

� Al Diecasting Facility will be reporting at

about 25,500 tons of casting shipped per

year.

� Iron Greensand Foundry with Cupola

Melting will report at about 43,000 tons

ship.



Questions?

Greenhouse Gas (GHG)

Reporting Rule

Documents

Greenhouse Gas (GHG) Reporting Rule - afsinc.net with GHG-Schifo.pdf · American Foundry Society -22nd EHS Conference August 23 -25, 2010, Nashville, TN Greenhouse Gas (GHG) Reporting