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.
Petrochemical Production
- United Slates
Proposed Rule: Mandatory Reporting of Greenhouse Gases Environmental Protection
Under the proposed Mandatory Reporting of Greenhouse Gases (GHGs) rule, owners or
operators of facilities that produce petrochemicals (as defined below) would report emissions
from petrochemical processes and all other source categories located at the facility for which
methods are defined in the rule. Owners or operators would collect feedstock and product data
or emission data; calculate GHG emissions; and follow the specified procedures for quality
assurance, missing data, recordkeeping, and reporting.
Facilities that produce petrochemicals should review the requirements of 40 CFRpart 98,
subpart MM (Suppliers of Petroleum Products) to determine if they would also report emissions
under 40 CFRpart 98, subpart MM.
How Is This Source Category Defined?
Under the proposal, petrochemical production consists of processes that produce acrylonitrile, carbon
black, ethylene, ethylene dichloride, ethylene oxide, or methanol as an intended product, except when any
of these six petrochemicals is not the primary product of an integrated process. An example of an
integrated process is the production of both hydrogen and methanol from synthesis gas by steam
reforming of methane. If methanol is the primary product, then the process would be classified as
petrochemical production.
What GHGs Would Be Reported?
The proposal calls for petrochemical production facilities to report the following gases:
• Carbon dioxide (CO2) emissions from each petrochemical process unit.
• CO2 captured from process off-gas, by following the procedures in 40 CFR part 98, subpart PP
(Suppliers of Carbon Dioxide).
• CO2, methane (CFL^, and nitrous oxide (N2O) emissions from each stationary combustion unit by
following the procedures in 40 CFR part 98, subpart C (General Stationary Fuel Combustion
Sources). Units that burn off-gas from a petrochemical process would report CO2, CFI4, and N2O
emissions according to subpart C for the combustion of supplemental fuel; CFI4 and N2O
emissions from off-gas combustion would use the emission factors for refinery gas in 40 CFR
part 98, subpart C. The information sheet on general stationary fuel combustion sources
summarizes the proposal for calculating and reporting emissions from stationary combustion
units.
• CFI4 emissions for each onsite wastewater treatment system using the procedures in subpart II
(Wastewater Treatment).
In addition, each facility would report GHG emissions for any other source categories for which
calculation methods are provided in other subparts of the rule.
March 2009 1 EPA-430-F-09-023
-------
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.
How Would GHG Emissions Be Calculated?
Under the proposal, owners or operators would estimate the GHG emissions from each petrochemical
process unit by using either a continuous emission monitoring system (CEMS) or a mass balance
approach:
• CEMS. Processes units with certain types of CEMS in place would report using the CEMS to
calculate total CO2 emissions and by following the methodology of 40 CFR part 98, subpart C
(except for flare stacks). CO2, CH4, and N2O emissions would be estimated for each flare stack
using the methodology specified in 40 CFR 98.253 of subpart Y (Petroleum Refineries).
• Mass Balance. Process units without applicable CEMS would use a mass balance approach for
each petrochemical process unit to estimate process emissions of CO2 for each calendar week. To
complete the mass balance, measure:
o Volume of each gaseous and liquid feedstock and product continuously with a flow
meter.
o Mass rate of each solid feedstock and product for each calendar week.
o Carbon content of each feedstock and product based on weekly samples.
Owners or operators of integrated processes that use the mass balance approach would include
terms in the mass balance equations for any additional carbon-containing products.
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
each annual report to include the following information:
• If a CEMS is used to determine emissions from process vents, the verification data specified for
the Tier 4 calculation methodology in 40 CFR 98.36(d)(iv) of subpart C would be reported.
• For processes that use the mass balance methodology, the following information would be
reported for each petrochemical process unit and each type of petrochemical product:
o Identification of the petrochemical process.
o Annual CO2 emissions calculated.
o Methods used to determine feedstock and product flows and carbon contents.
o Number of actual and substitute data points for each measured parameter.
o Annual quantity of each feedstock consumed.
o Annual quantity of each product and byproduct produced, including all products from
integrated processes that are part of the petrochemical production source category.
o Each carbon content measurement for each feedstock, product, and byproduct.
o All calculations, measurements, equipment calibrations, certifications, and other
information used to assess the uncertainty in emission estimates and the underlying
volumetric flow rates, mass flow rates, and carbon contents of feedstocks and products.
o Identification of any combustion units that burned process off-gas.
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
March 2009 2 EPA-430-F-09-023
-------
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 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-09-023
------- |