Hydrogen Production
United States
Final Rule: Mandatory Reporting of Greenhouse Gases ^aimrriental Prot9ction
Under the 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 or more of
GHGs per year (expressed as carbon dioxide equivalents) from hydrogen production processes,
stationary combustion, miscellaneous use of carbonates, and other source categories (see information
sheet on General Provisions) must report emissions from all source categories located at the facility for
which emission calculation methods are defined in the rule. Owners or operators are required to 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?
The hydrogen production source category consists of process units that produce hydrogen by reforming,
gasification, oxidation, reaction, or other transformation of feedstock, and that sell the hydrogen as a
product. Hydrogen production units that are located at a petroleum refinery are included in this source
category if they are not owned by or under the direct control of the refinery owner. Hydrogen production
units that are owned by a petroleum refinery must report under subpart Y (Petroleum Refineries).
What GHGs Must Be Reported?
Hydrogen production facilities must report the following emissions:
• Carbon dioxide (CO2) process emissions from each hydrogen production process unit.
• CO2, methane (CFL^, and nitrous oxide (N2O) combustion emissions from each hydrogen
production process unit. Calculate and report these combustion emissions under 40 CFR 98,
subpart C (General Stationary Fuel Combustion Sources) by following the requirements of
subpart C.
• CO2, CH4, and N2O emissions from each stationary combustion unit other than hydrogen
production process units. Calculate and report these emissions under 40 CFR 98, subpart C by
following the requirements of subpart C.
• CO2 collected and either used on site or transferred off site by following the requirements of 40
CFR part 98, subpart PP (Suppliers of Carbon Dioxide).
In addition, each facility must report GHG emissions for other source categories for which calculation
methods are provided in the rule. Please refer to the relevant information sheet for a summary of the rule
requirements for calculating and reporting emissions from other source categories at the facility.
How Must GHG Emissions Be Calculated?
Report CO2 emissions from hydrogen production using one of the following two methods:
• Install and operate a continuous emission monitoring system (CEMS) to measure combined
process and combustion CO2 emissions according to the Tier 4 calculation methodology specified
in 40 CFR part 98, subpart C.
• Calculate process CO2 emissions by measuring the following:
o Feedstocks and fuel consumed each month.
40 CFR 98, subpart P 1 EPA-430-F-09-027R
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o Average carbon content of the fuel and feedstock for each month.
o Molecular weight of the fuel and feedstock.
However, if process CO2 emissions from hydrogen production are vented through the same stack as a
combustion unit or process equipment that uses a CEMS to follow Tier 4 methodology to report CO2
emissions, then the CEMS must be used to measure and report combined CO2 emissions from that stack
instead of the calculation procedure described in approach 2 above.
A checklist for data that must be monitored is available at:
www.epa.gov/climatechange/emissions/downloads/checklists/hvdrogenproduction.pdf
What Information Must Be Reported?
In addition to the information required by the General Provisions at 40 CFR 98.3(c), each hydrogen
production facility must report the following information:
If a CEMS is used to measure CO2 emissions, report under this subpart the relevant information required
under 40 CFR part 98, subpart C and the following information listed below:
• Unit identification number and annual CO2 process emissions (metric tons) for each process unit.
• Annual quantity of hydrogen produced (metric tons) for each process unit and all units combined.
• Annual quantity of ammonia produced (metric tons), if applicable, for each process unit and for
all units combined.
If a CEMS is not used to measure CO2 emissions, report the following information for each hydrogen
production process unit:
• Unit identification number and annual CO2 process emissions (metric tons).
• Monthly consumption of each fuel and feedstock used for hydrogen production and its type
(standard square feet of gaseous fuels and feedstocks; gallons of liquid fuels and feedstocks;
kilograms of solid fuels and feedstocks).
• Annual quantity of hydrogen produced (metric tons).
• Annual quantity of ammonia produced, if applicable (metric tons).
• Monthly analyses of carbon content for each fuel and feedstock used in hydrogen production.
• Monthly analyses of the molecular weight of gaseous fuels and feedstocks (kg/kg-mole) used.
• Quarterly quantity of CO2 collected and transferred off site in either gas, liquid, or solid forms
(kg), following the requirements of subpart PP of this part.
• Annual quantity of carbon other than CO2 collected and transferred off site in either gas, liquid, or
solid forms (kg carbon).
For More Information
This document is provided solely for informational purposes. It does not provide legal advice, have
legally binding effect, or expressly or implicitly create, expand, or limit any legal rights, obligations,
responsibilities, expectations, or benefits in regard to any person. The series of information sheets is
intended to assist reporting facilities/owners in understanding key provisions of the final rule.
Visit EPA's Web site (www.epa.gov/climatechange/emissions/ghgrulemaking.html) for more
information, including the final preamble and rule, additional information sheets on specific industries,
the schedule for training sessions, and other documents and tools. For questions that cannot be answered
through the Web site, please contact us at: ghgmrr(giepa.gov.
40 CFR 98, subpart P 2 EPA-430-F-09-027R
September 2009
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