Petrochemical Production
                                                                                     United States
Final Rule: Mandatory Reporting of Greenhouse Gases

Under the Mandatory Reporting of Greenhouse Gases (GHGs) rule, owners or operators of facilities that
produce petrochemicals (as defined below) must 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 are required to calculate GHG emissions by one of three alternative methods 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, subpartMM
(Suppliers of Petroleum Products) to determine if they must also report emissions under 40 CFRpart 98,
subpartMM.

How Is This Source Category Defined?

Petrochemical production consists of each process that produces acrylonitrile, carbon black, ethylene,
ethylene dichloride, ethylene oxide, or methanol, except the following are excluded from the
petrochemical production source category:

       Processes that produce a petrochemical as a byproduct.

       A direct chlorination process that is operated independently of an oxychlorination process to
       produce ethylene dichloride.

       A facility that makes methanol, hydrogen, and/or ammonia from synthesis gas if the annual mass
       production of either hydrogen recovered as product or ammonia exceeds the annual mass
       production of methanol.

       Processes that produce bone black.

       Processes that produce a petrochemical from biobased feedstock.

What GHGs Must Be Reported?

Petrochemical production facilities must report the following gases:
       Carbon dioxide (CO2) process  emissions from each petrochemical unit. Process emissions include
       CO2 generated by reaction in the process, and CO2, methane (CH^, and nitrous oxide (N2O)
       generated by combustion of process off-gas in stationary combustion units and flares.
       CO2, CUt, and N2O emissions  from burning supplemental fuel in stationary combustion units that
       also burn process off-gas.
       CO2 captured and reported under 40 CFR part 98, subpart PP (Suppliers of Carbon Dioxide) by
       following the requirements under subpart PP.

In addition, each facility must report GHG emissions for any other source categories for which calculation
methods are provided in other subparts of the rule.
40 CFR 98, subpart X                            1                             EPA-430-F-09-023R
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How Should GHG Emissions Be Calculated?

Owners or operators must estimate the GHG emissions from each petrochemical process unit. Process
emissions include CO2, CH4, and N2O emissions generated by chemical reactions in the process and
combustion emissions of process off-gas and liquid wastes. Within a process unit, only one of the
following three approaches may be used.
       Continuous Emission Monitoring System (CEMS). If all process vent emissions and emissions
       from combustion of process off-gas are routed to one or more stacks, and CEMS are used on each
       stack to measure CO2 emissions (except for flare stacks), then the owner must report by following
       the Tier 4 methodology of 40 CFR part 98, subpart C. For each stack (excluding flare stacks) that
       includes emissions from combustion of petrochemical process  off-gas, calculate CFI4 and N2O
       emissions using emission factors in Table C-2 in subpart C and the Tier 3 methodology in subpart
       C. For each flare stack, calculate CO2, CFI4 and N2O emissions using the methodology specified
       in 40 CFR 98.253, subpart Y (Petroleum Refineries).
       Mass Balance. Except as allowed below for ethylene processes, process units without applicable
       CEMS must use a mass balance approach for each petrochemical process unit to estimate process
       emissions of CO2 for each calendar month. (Separate estimates for CFI4 and N2O emissions are
       not required.) To complete the mass balance, measure:
           o   Volume or mass of each gaseous and liquid feedstock and product for each calendar
               month.
           o   Mass rate of each solid feedstock and product for each calendar month.
           o   Carbon content of each feedstock and product based on monthly samples.
       Ethylene Processes. For ethylene processes only, because nearly all process emissions from this
       process are from the combustion of process off-gas, the final rule allows estimation of emissions
       from all stationary combustion units that burn process off-gas (with or without supplemental fuel)
       in accordance with the Tier 3  or Tier 4 procedures in 40 CFR part 98, subpart C. In addition, this
       option requires CO2, CH/t, and N2O emissions from each flare to be estimated using the
       procedures in 40 CFR 98.253(b) (Petroleum Refineries).

A checklist for data that must be monitored is available at:
www.epa.gov/climatechange/emissions/downloads/checklists/petrochemproduction.pdf

What Information Must Be  Reported?
In addition to the information required by the General Provisions at 40 CFR 98.3(c), each annual report
must include the following information:

If a CEMS is used to measure CO2 emissions, then you must report the relevant information required
under 40  CFR part 98, subpart C and the following information listed below:
       The petrochemical process unit ID or other appropriate descriptor, and the type of petrochemical
       produced.
       The CO2 emissions from each stack and the combined CO2 emissions from all stacks (except flare
       stacks) that handle process vent emissions and emissions from stationary combustion units that
       burn process off-gas for the petrochemical process unit.
       The CFLt and N2O emissions from each stack and the combined CFLt and N2O emissions from all
       stationary combustion units that burn process off-gas from the  petrochemical process unit; the
       cumulative annual heat input used in 40 CFR 98.33 (c); and the annual fuel flow value(s).
       The ID or other appropriate descriptor of each stationary combustion unit that burns process off-
       gas.
       Information listed in 40 CFR 98.256(e) for each flare that burns process off-gas.
       The annual quantity of each type of petrochemical produced from each process unit (metric tons).
40 CFR 98, subpart X                            2                             EPA-430-F-09-023R
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For processes that use the mass balance methodology, the following information must be reported for
each petrochemical process unit and each type of petrochemical product:
      The petrochemical process unit ID number or other appropriate descriptor.
      The type of petrochemical produced, names of other products, and names of carbon-containing
       feedstocks.
      Annual CO2 emissions calculated.
      Each of the monthly volume, mass, and carbon content values used in your calculations.
      The molecular weights for gaseous feedstocks and products used in your calculations.
      Annual quantity of each type of petrochemical produced from each process unit (metric tons).
      The name of each method listed in 40 CFR 98.244 used to determine a measured parameter.
      The dates and summarized results of the calibrations of each measurement device.
      Identification of each combustion unit that burned both process off-gas and supplemental fuel.
      If you comply with the alternative to sampling and analysis specified in 40 CFR 98.243(c)(4), the
       amount of time during which off-specification product was produced, the volume or mass of off-
       specification product produced, and if applicable, the date of any process change that reduced the
       composition to less than 99.5 percent.

If you use the combustion methodology specified in 40 CFR 98.243(d), you must report the following
information:
      For each stationary combustion unit that burns ethylene process off-gas (or group of stationary
       sources with a common pipe), the relevant information listed in 40 CFR 98.36 for the selected
       Tier 3 or Tier 4 methodology. If a stationary combustion source serves multiple ethylene process
       units or units other than the ethylene process unit, estimate based on engineering judgment the
       fraction of fuel energy and emissions attributable to each ethylene process unit.
      Information listed in 40 CFR 98.256(e) for each flare that burns ethylene process off-gas.
      Name and annual quantity of each feedstock.
      Annual quantity of ethylene produced from each process unit (metric tons).

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(g),epa.gov.
40 CFR 98, subpart X                             3                              EPA-430-F-09-023R
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