Holding Steady

Although no federal GHG regulations currently exist, EPA reports that nationwide CO2 emissions have risen very little in the 2000s. As noted in the table, CO2 has increased only about 2% over the first eight years of the decade and has gone down significantly in the metallurgical-industry segments shown. Evidence suggests that the U.S. production of these metals has also decreased, but the CO2 reductions are about two to three times greater than the declines in material output, indicating that these sectors have achieved significant energy-efficiency improvements.

Applicability

To help facilities determine whether the new reporting rules apply to their operations, EPA developed a simple flowchart, which is reproduced to the left.

The chart cites three tables that identify manufacturing processes and equipment that typically emit GHG. The source categories listed in Table 1 include aluminum, cement and titanium-dioxide production. Table 2 categories include ferroalloy, glass, iron and steel, lead, and zinc production. The combustion units cited in Table 3 include boilers, process heaters, gas turbines and “other stationary fuel-combustion equipment.”

Monitoring

EPA has also set up four “tiers” by which companies can compute CO2 emissions. These include company records of fuel usage, direct measurements of fuel consumption and continuous emission-monitoring systems (CEMS) for CO2. Not all tiers are applicable to all facilities at all times, so the rule should be reviewed for applicable details.

Facilities must not only submit their 2010 GHG report before March 31, 2011, but they also will be required to retain supporting records for at least three years. Records to be retained include lists of GHG-emitting unit operations, raw data used to compute GHG emissions, a data monitoring plan and maintenance records for monitoring instruments.

The EPA website is still being populated with information as the commencement of required reporting grows nearer. To remain current, readers are encouraged to check it periodically at www.epa.gov/climatechange/emissions/ghgrulemaking.html.