So Your Greenhouse Gas (GHG) Monitoring Plan is Complete... Now What?!?

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Courtesy of Courtesy of All4 Inc.

U.S. EPA's Greenhouse Gas Mandatory Reporting Rule (GHG MRR) codified at 40 CFR Part 98 required that facilities subject to the rule have a complete written GHG Monitoring Plan by April 1, 2010. At a minimum, the GHG Monitoring Plan must identify (1) methods used to collect GHG emissions information and supporting data, (2) personnel responsible for collecting the data, and (3) quality assurance, maintenance, and repair methods for all measurement devices used to collect data.

Well, April 1, 2010 has come and gone… so now what?

First off, we’ll state the obvious – make sure that your GHG Monitoring Plan really is complete and in place. The GHG Monitoring Plan is a working document and is not a plan that sits on the shelf and is dusted off on December 31, 2010.  Now is the time to ensure that your facility is implementing the GHG Monitoring Plan. If you wait until year-end, you may find that you cannot collect, or have not collected, the support information identified in your plan. In addition to “living your GHG Monitoring Plan,” there are some other steps that you can take now to ensure that you are meeting the requirements of 40 CFR Part 98.

1. Train your key stakeholders. Provide training to all parties that will play a role in collecting data and calculating parameters/emissions. Like other monitoring programs, the data collection component most likely extends beyond the environmental group. Educate everyone that has a role in executing the GHG Monitoring Plan and distinguish the importance of their respective roles. For example, a facility that operates a multi-fuel boiler may be required to analyze carbon content on a per fuel shipment basis for coal, collect weekly samples from which a monthly composite is analyzed for carbon content for other solid fuels, and analyze the heating value semi-annually for natural gas.

2. Utilize a monthly GHG calculation tool. Implementing a monthly computation will highlight areas to be resolved on a near term basis as opposed to determining at year end that an issue was present (e.g., missing data, improper analytics, calibration issues, etc.) Monthly calculations will also allow your facility to communicate its GHG emissions footprint (per U.S. EPA 40 CFR Part 98 rule) to internal and external stakeholders and put in place a mechanism for risk mitigation, corporate benchmarking, shareholder/supplier reporting, etc.

3. Plan for the next wave of GHG rulemaking. While proposed legislation that would regulate GHG emissions has been slower to evolve than anticipated, it is coming soon! The recent activity at U.S. EPA to regulate GHG emissions from automobiles serves as the first step in the process to regulate GHG emissions on the national basis. Expect that GHG pollutants from stationary sources will be regulated and will be required to be considered in future air quality permitting exercises – as soon as the 2011 calendar year. ALL4 believes that any complex air permitting projects that could extend into the 2011 calendar year should address GHG pollutants as part of the application. This will take us into areas previously not considered such as determining what is Best Available Control Technology (BACT) for CO2 emissions from a natural gas-fired boiler.…... We environmental professionals have some work to do!

4. Let folks know the great things that your company is doing. Summarize the positive things that your company has already done to reduce your company’s GHG footprint – give your marketing folks some ammunition to take your contributions public. People might not be able get their arms around the GHG impact of switching from coal to natural gas. They can, however, understand that the switch from coal to natural gas is equivalent to taking 7,000 cars off the road, or saving 29,000 acres of pine trees. Put projects in terms that people can understand and you will maximize the benefits.

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