This document was developed for the Proposed Mandatory GHG Reporting Rule.
For the final document, please visit the final Mandatory Reporting of
Greenhouse Gases Rule.
Petroleum Product Suppliers
United Slates
Proposed Rule: Mandatory Reporting of Greenhouse Gases Environmental Protection
Under the proposed Mandatory Reporting of Greenhouse Gases (GHGs) rule, all owners or operators of
petroleum refineries and importers and exporters of petroleum products that meet the applicability
requirements of the rule (see information sheet on General Provisions) would report the GHG emissions
associated with the complete combustion or oxidation of the products they place in commerce. Refinery
owners or operators, importers, exporters, and petroleum product suppliers would collect data on their
products; calculate the potential GHG emissions associated with these products; and follow the specified
procedures for ensuring data quality, amending missing data, and meeting recordkeeping and reporting
requirements.
Owners or operators of refineries and petroleum product suppliers should also review the information
sheet for petroleum refineries to identify other potential direct emissions that they may be required to
report under the proposal.
How Is This Source Category Defined?
Under the proposal, suppliers of petroleum products consist of:
• Petroleum refiners that produce gasoline; kerosene; distillate fuel oils; residual fuel oils; lubricants;
asphalt (bitumen); or other products through distillation of petroleum or through redistillation, cracking, or
reforming of unfinished petroleum derivatives.
• Importers who bring petroleum products into the United States from a foreign country, including any
blender or refiner of refined or semi-refined petroleum products. Importers include those who are primarily
liable for the payment of any duties on the merchandise or an authorized agent acting on their behalf.
Importers also include, as appropriate, the consignee, the importer of record, the actual owner, or the
transferee.
• Exporters who transfer petroleum products from the United States to another country or to an affiliate in
another country, including any blender or refiner of refined or semi-refined petroleum products. Exporters
do not include those who transfer products to U.S. military bases and to ships for on-board use.
What GHGs Would Be Reported?
The proposal calls for suppliers of petroleum products to report annually:
• Carbon dioxide (CO2) emissions that would result from the complete combustion or oxidation of each
petroleum product and natural gas liquid produced, used as feedstock, imported, or exported during the
calendar year.
• CO2 emissions that would result from the complete combustion or oxidation of any biomass co-processed
with petroleum feedstocks, for refiners.
Suppliers of petroleum products would not be required to report data on potential emissions of other GHGs from the
use of their products, such as methane or hydrofluorocarbons (HFCs).
How Would GHG Emissions Be Calculated?
March 2009 1 EPA-430-F-09-014
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This document was developed for the Proposed Mandatory GHG Reporting Rule.
For the final document, please visit the final Mandatory Reporting of
Greenhouse Gases Rule.
Under the proposal, owners or operators may choose one of two methods to calculate potential CO2 emissions from
each petroleum product and natural gas liquid:
• Method 1: Using the default CO2 emission factors (metric tons CO2 emitted per barrel) provided in the
proposed regulations for each petroleum product and natural gas liquid; or
• Method 2: Developing an emission factor for a given petroleum product or natural gas liquid using direct
measurements of density and carbon share (i.e., percent carbon by mass), or using a combination of direct
measurements and default factors for density and carbon share.
To calculate potential CO2 emissions from biomass co-processed with petroleum feedstock, reporters would use a
CO2 emission factor (metric tons of CO2 emitted per barrel) that is provided in the proposed regulations for each
biomass product or feedstock.
In calculating total CO2 emissions from all petroleum products and natural gas liquids, refiners would subtract the
potential CO2 emissions from non-crude feedstocks and biomass feedstocks that are co-processed or blended with
petroleum feedstocks to produce a petroleum product.
What Information Would Be Reported?
In addition to the information required by the General Provisions at 40 CFR 98.3(c), the proposal calls for petroleum
refiners to report the following information for each of their refineries:
• Total CO2 emissions in metric tons from all petroleum products and natural gas liquids.
• CO2 emissions in metric tons for each petroleum product and natural gas liquid (ex refinery gate), and the
total volume of each.
• CO2 emissions in metric tons for each petroleum product or natural gas liquid that enters the refinery
annually as a feedstock to be further refined or otherwise used on site, and the total volume of each. If
reporters cannot determine whether a feedstock is a petroleum product or a natural gas liquid, it would be
reported as a petroleum product.
• CO2 emissions in metric tons from each type of biomass feedstock to be co-processed with petroleum
feedstocks, and the total volume of each biomass feedstock.
• The volume of the biomass-based component of each petroleum product that was produced by blending a
petroleum-based product with a biomass-based product.
• The density and mass carbon share for any petroleum product or natural gas liquid for which these were
directly measured as part of calculating CO2 emissions, and the measurement method used.
• The total volume of each distillate fuel oil product or feedstock that contains less than 15 parts per million
(ppm) of sulfur content and is free from marker solvent yellow 124 and dye solvent red 164.
• All of the following information for all crude oil feedstocks used at the refinery: batch volume (in standard
barrels); API gravity of the batch; sulfur content of the batch; and country of origin.
Petroleum product importers and exporters would report all of the following information at the corporate level:
• CO2 emissions in metric tons for each imported and exported petroleum product and natural gas liquid, and
the total volume of each product. If reporters cannot determine whether a material is a petroleum product or
a natural gas liquid, it would be reported as a petroleum product.
• The total sum of CO2 emissions in metric tons for all imported and exported products.
• The volume of the biomass-based component of each reported petroleum product that was produced by
blending petroleum-based and biomass-based products.
• The density and mass carbon share for any petroleum product or natural gas liquid that was directly
measured to calculate CO2 emissions, and the measurement method used.
• The total volume of each distillate fuel oil product that contains less than 15 ppm sulfur content and is free
from marker solvent yellow 124 and dye solvent red 164.
March 2009 2 EPA-430-F-09-014
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This document was developed for the Proposed Mandatory GHG Reporting Rule.
For the final document, please visit the final Mandatory Reporting of
Greenhouse Gases Rule.
For More Information
This series of information sheets is intended to assist reporting facilities/owners in understanding key provisions of
the proposed rule. However, these information sheets are not intended to be a substitution for the rule. Visit EPA's
Web site (www.epa.gov/climatechange/emissions/ghgrulemaking.html') for more information, including the
proposed preamble and rule and additional information sheets on specific industries, or go to
to access the rulemaking docket (EPA-HQ OAR-2008-0508). For questions that cannot be
answered through the Web site or docket, call 1-877-GHG-l 188.
March 2009 3 EPA-430-F-09-014
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