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.
Hydrogen 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 contain hydrogen production processes (as defined below) and that
emit 25,000 metric tons of GHGs per year or more (expressed as carbon dioxide equivalents)
from stationary combustion, miscellaneous use of carbonates, and other source categories (see
information sheet on General Provisions) would report emissions from all source categories
located at the facility for which emission calculation methods are defined in the rule. Owners or
operators would collect emission data; calculate GHG emissions; and follow the specified
procedures for quality assurance, missing data, recordkeeping, and reporting.
How Is This Source Category Defined?
Under the proposal, the hydrogen production source consists of process units that produce hydrogen by
oxidation or other transformation of feedstock and transfer the hydrogen produced off site . Hydrogen
production facilities located at petroleum refineries are included in this source category if they are not
owned by or under the direct control of the refinery owner.
What GHGs Would Be Reported?
The proposal calls for hydrogen production facilities to report the following emissions:
• Carbon dioxide (CO2) process emissions from hydrogen oxidation.
• CO2 collected and either used on site or transferred off site by following the requirements of 40
CFRpart 98, subpart PP (Suppliers of Carbon Dioxide).
In addition, each facility would report GHG emissions for other source categories for which calculation
methods are provided in the rule. For example, facilities would report CO2, nitrous oxide (N2O), and
methane (CH4) emissions from each stationary combustion unit on site by following the requirements of
40 CFRpart 98, subpart C (General Stationary Fuel Combustion Sources). Please refer to the relevant
information sheet for a summary of the proposal for calculating and reporting emissions from any other
source categories at the facility.
How Would GHG Emissions Be Calculated?
For CO2 emissions from hydrogen production, the proposal calls for hydrogen production facilities to use
one of two methods, as appropriate:
• Hydrogen production processes with certain types of continuous emissions monitors (CEMS) in
place would report using the CEMS and follow the methodology of 40 CFR part 98, subpart C to
report total CO2 emissions from calcination and fuel combustion. At other hydrogen production
processes, the use of CEMS would be optional.
• Facilities without CEMS would calculate CO2 emissions using the following:
o Measurements of monthly feedstocks and fuel consumed.
March 2009 1 EPA-430-F-09-027
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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.
o Carbon content of the feedstock measured monthly.
o Molecular weight of the feedstock.
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 hydrogen production facility to report the following information:
• Annual emissions of CO2 from all hydrogen production processes combined.
• Total annual feedstock consumed for hydrogen production.
• Total annual hydrogen produced.
• Total annual ammonia produced, if applicable.
• Monthly analysis of carbon content for each feedstock used for hydrogen production.
Facilities that use CEMS would also report the data specified in 40 CFR 98.34(d) of subpart C (General
Stationary Fuel Combustion Sources).
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 2 EPA-430-F-09-027
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