Primer on the New Mandatory Green House Gas rule

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
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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
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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
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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
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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
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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
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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
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9. Sources of CO2

10. 12/3/2009
According to US EPA, methane accounts for 16% of
global greenhouse emissions.
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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.
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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
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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
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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
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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
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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
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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!
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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
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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
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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
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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
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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
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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