Greenhouse Gas State to Federal Program
Mapping Study
CAER GHG R&D Project Team Report
October 2, 2017
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Table of Contents
1 Introduction 3
2 Comparison of State and Federal Greenhouse Gas Programs 6
2.1 GHG Program Comparison 7
2.1.1 Summary of Minnesota Greenhouse Gas Program 7
2.1.2 Summary of Massachusetts Greenhouse Gas Program 8
2.1.3 Summary of Oregon's Greenhouse Gas Program 9
2.1.4 Summary of Federal Greenhouse Gas Program 10
2.1.5 Summary Comparison of Programs 11
3 Data Element Comparison Among Programs 18
3.1 Subpart A - General Reporting Requirements 18
3.2 Subpart C - Stationary Combustion 18
3.3 Subpart Q- Iron and Steel 19
3.4 Subpart HH - Municipal Solid Waste Landfills 19
4 Unit-to-Unit Mapping 20
4.1 Minnesota - Iron and Steel 20
4.2 Massachusetts - Stationary Combustion 21
4.3 Oregon - Landfills 21
5 Insights and Implications for a Combined Reporting Framework 22
6 Next Steps 26
Appendix A 28
Appendix B 28
Appendix C 34
Appendix D 37
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1 Introduction
This document is a compilation of the results of a pilot study to map emissions data in the national
Greenhouse Gas (GHG) Reporting Program (GHGRP) to three state mandatory GHG reporting programs.
Work was conducted by the Greenhouse Gas Mapping Study project team, one of five 'first round'
research and development (R&D) projects conducted under the Combined Air Emissions Reporting
(CAER) Product Design Team (PDT) between January and August of 2017.
Together with the work of other project teams under the PDT, the broader goal of this effort was to help
inform what would be needed to support a potential future combined emissions reporting scenario as
envisioned in the CAER project. The use of a common emissions reporting form is part of the broader
CAER project's goal of decreasing reporting burden to facilities by allowing them the ability to reduce
the number of times they must report the same data element to individual programs. The CAER
project's conceptual "proposed future state"1 is shown in Figure 1 and highlighted in red are the two
types of databases this project addressed.
Figure 1. Proposed Future State
Air Emissions - Proposed Future State
ik
Portal*
Previous
emissions I
Attributes
Emissions
Entry
Entry
Prepopulate
facility
attributes
Shared
Facility
Attributes
System
IHIlKirlt
GHGRP
Database
CEDRI, ERT,
WebFlfcE/EFs
NEi Database
Databases
Unified Data
Public Access
¦¦¦smmmMBmm
It is important to note, however, that the proposed future state is a conceptual design at this point, with
many iterative R&D steps needed to progress towards a shared emissions system as envisioned under
CAER. There are current systems in place with many capabilities that CAER teams need to understand
1 The CAER "future state" resulted from a Lean event conducted on Air Emissions Reporting: the future state
should reduce reporting burden to industry and states via a common reporting framework as well as time spent on
"after-the-fact" reconciliation of emissions data by EPA staff.
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and learn from before attempting to integrate into a shared emissions system. Therefore, separate
entry points for state, local, and tribal programs (SLTs), GHG, Toxics Release Inventory (TRI), and the
Compliance and Emissions Data Reporting Interface (CEDRI) should be accommodated as needed,
sharing facility and emissions data where appropriate (see Figure 2).
Figure 2. Proposed Future State with Separate Entry Points for GHG
Proposed CAER Future State
Common Reporting
SLT
Master Facility
Database
Other SLT
Systems
Emissions
Databases
J
r»
Shared
Common Form
Facility Attributes
Emission Data
Unique Program Reporting
Requirements
n_J
CEDRI/WebFIRE
With these points in mind, specific questions to answer in this study were:
• Where is the overlap between the state programs included in this study and the GHGRP
requirements?
o In what ways are they similar and in what ways are they different?
o Where different, how important are these differences?
• What should our next steps be in light of our findings and the broader CAER goal of decreasing
reporting burden to facilities by using a common reporting form?
The scope of this project was limited. It was not possible to address all available GHG SLT programs at
once, or to research all sectors and industries. Therefore, the scope of the project was to identify
commonalities and differences between GHGRP and GHG reporting programs for 3 states, by comparing
their data needs for 3 sectors. Consequently, care should be taken not to generalize the team's findings,
as these cannot be considered universal. Rather, they should be considered as helpful information to
guide next steps in our understanding.
There are important aspects to consider in future PDT work that are outside of the scope of this R&D
project. State and federal GHG program database commonalities and interactions are just one aspect of
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the overall CAER effort as related to GHGs. Three items outside the strict scope of state-federal GHG
program nexus surfaced during the work of this R&D team: facility GHG data sharing (which is already
being addressed with the Facility Registry Service and its new data model), sharing GHGRP data with
states and others in CSV or excel type formats, and combined NEI and GHG reporting.
Yet, these issues are very relevant aspects of CAER to investigate further and are, therefore,
documented in this report. At the time this R&D team had begun work several states and some industry
members had expressed some interest in reporting GHGs with criteria pollutants, for example2.
Additionally, using one input value in time to calculate all emissions means less of a need for "after-the-
fact" reconciliation on the different pollutants, as shall be explained further in the comparison exercise
done at the facility level, and is additionally, very relevant for reconciliation of reported GHG data with
criteria and toxics data by EPA staff. For example, EPA must reconcile toxics, GHG and criteria data from
a facility. But if data from each of those was reported at different times with different input values,
these numbers may not make sense when put together to do any kind of analysis. As was discovered
during the work, having GHGRP data in a csv or excel format would save time for anyone wanting to use
that data in some form of comparison or analysis.
The team whose work is reflected in this document included: the states of Massachusetts, Minnesota
and Oregon, and staff from EPA's GHGRP and the Emissions Inventory and Analysis Group (EIAG). Team
members were:
States:
MA: Jordan Garfinkle
MN: Azra Kovacevic
OR: Stephanie Summers, Elizabeth Elbel
EPA:
GHGRP: Kong Chiu, Brian Cook, Sydnie Lieb
EIAG: Julia Gamas (Team Lead)
The document is divided into three sections. Our comparison progressed starting from the most general
aspects to compare (Section 2), to the most detailed comparison of data elements and reported data for
a facility at the unit level (Section 3). Section 4 contains the facility mapping exercise including a
narrative and unit-to-unit comparison. Section 5 contains lessons learned so far towards a common
emissions reporting form. It was not the goal of this work to reach any consensus of what the common
reporting framework should or shouldn't do, nor to provide any kind of definitive guidance on its design,
but rather, to present the team's findings so far. Section 6 concludes with outstanding questions that
lead to next steps in exploring shared reporting for GHG air emissions data.
2 States that participated in the Lean event that led to CAER where combined emissions reporting emerged as a
solution were: Arizona and North Carolina. Other states who have expressed some interest in this issue are:
Minnesota, Massachusetts, and South Carolina.
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2 Comparison of State and Federal Greenhouse Gas Programs
Currently, 22 U.S. States have some form of greenhouse gas reporting program: 19 have a mandatory
program and 3 have voluntary programs. Table 1 shows these states together with current references
to their programs. While some states are running their own GHG programs, other states rely on EPA
data to generate state reports as a tool towards meeting their GHG emissions goals (e.g. Georgia refers
to GHGRP data whereas Idaho refers to national Greenhouse Gas Emissions Inventory3).
Table 1. U.S. States with Greenhouse Gas Reporting Programs
State
Reference
Legal Basis
California
https://www.arb.ca.gov/cc/reporting/ghg-
California Global Warming Solutions
Act (AB 32, 2006)
rep/regulation/mrr-regulation.htm
Colorado
httos://www. colorado.gov/pacific/cdphe/colorado-
greenhouse-gas-permitting
Executive Order (E.O.) D004-08
Connecticut
http://www.ct.gov/deep/cwp/view.asp?a=4423&a=5
30290
22a-174-31 Regulations of
Connecticut State Agencies (RCSA);
Public Act 04-252: "An Act
Concerning Climate Change"
Delaware
http://regulations.delaware.gOv/AdminCode/title7/l
Administrative Code: Title 7:
000/1100/1147. shtml
1000:1100
Iowa
http://www.iowadnr.gov/Environmental-
Protection/Air-Qualitv/Greenhouse-Gas-Emissions
Iowa Code section 455B.152
Maine
http://www.maine.gov/dep/air/emissions/index.htm
http://www.maine.gov/dep/air/rul
I
es/index.html
Maryland
http://www.mde.state.md.us/programs/Air/Climate
Change/Pages/Reports.aspx
Code of Maryland Regulations
(COMAR) 26.11.01.01, 12, & 14
Massachusetts
http://www.mass.gov/eea/agencies/massdep/climat
Global Warming Solutions Act
e-energv/climate/approvals/ma-greenhouse-gas-
(GWSA) Sections 2 & 10
emissions-reporting-program.html
Minnesota
https://www.pca.state.mn. us/air/emissions-
Minnesota Statutes Chapter
reporting
216H.021
Nevada
https://ndep.nv.gov/air/air-pollutants/greenhouse-
Nevada Revised Statutes (NRS)
gas-emissions
445 B. 137
3 For example, the Idaho Greenhouse Gas Inventory and Reference Case Projections 1990-2005 Report for DEQ
used the following as one of its references: US EPA (2006), Inventory of US Greenhouse Gas Emissions and Sinks:
1990-2004. The Greenhouse Gas Inventory or GHGI is different from the GHGRP.
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State
Reference
Legal Basis
New Jersey
http://www.ni.gov/dep/aaes/sggi.html
New Jersev Administrative Code
(NJAC) 7:27-8, NJAC 7:27-21.3,
New Mexico
https://www.env.nm.gov/air-aualitv/ghg-reporting/
New Mexico Administrative Code
(NMAC) 20.2.73
New York
http://www.dec.nv.gov/chemical/68524.html
Compilation of Codes, Rules and
Regulations of the State of New
York (CRRNY) 6 CRR-NY 242.8.5
Ohio
https://www.theclimateregistrv.org/programs-
Ohio Administrative Code (OAC)
services/voluntarv-reporting/membership-benefits/
4901:1-41-03
Oregon
http://www.oregon.gov/dea/aa/programs/Pages/GH
G.aspx
Oregon's Administrative Rules
(OAR) 340-215-0010
Rhode Island
http://www.dem.ri.gov/programs/air/emissions.php
Air Pollution Control Regulation No.
46
Vermont
http://climatechange.vermont.gov/climate-
pollution-goals
Vermont Statutes Annotated, 10
V.S.A. § 582
Washington
http://www.ecv.wa.gov/programs/air/permit regist
Washington Administrative Code
er/ghg/ghg.html
(WAC) 173-441
Wisconsin
http://dnr.wi.gov/topic/airemissions/historical.html
Wisconsin Administrative Code
(WAC) Department of Natural
Resources (NR) 438.03
New Hampshire
https://www.des.nh.g0v/0rganizati0n/divisi0ns/air/t
sb/tps/climate/ghgr.htm
Voluntary
North Carolina
https://dea.nc.gov/about/divisions/air-aualitv/air-
Voluntary
aualitv-data/emissions-inventories/emission-
inventories-tools
West Virginia
http://www.dep.wv.gov/daa/planning/Pages/Green
houseGas.aspx
Voluntary
2.1 GHG Program Comparison
In this section, each state GHG program participating on the R&D project team is described, as is the
federal GHGRP. Then a high level comparison is done for all four programs.
2.1.1 Summary of Minnesota Greenhouse Gas Program
The Minnesota greenhouse gas program has two parts:
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(1) The state legislature set several reduction goals in 2007 under the Next Energy Generation Act.
The goal called for 15% reduction in GHG emissions by 2015 from 2005 levels, and for 2025 and 2050
emissions levels to be 30% and 80%, respectively, below the 2005 emission levels. The statute also
called for a statewide GHG emission inventory to include emissions of carbon dioxide (C02), methane
(CH4), nitrous oxide (N20), hydrofluorocarbons (HCFCs), perfluorocarbons (PFCs), and sulfur hexafluoride
(SF6) emitted by anthropogenic sources within the state, from the generation of electricity imported
from outside the state and consumed in Minnesota.
(2) Minnesota GHG reporting system requires facilities with a Title V permit, an Option D
Registration Permit (small facilities such as schools)) and facilities holding a capped permit to report
GHG emissions to the Minnesota Pollution Control Agency (MPCA). Minnesota has permitting or statute
reporting requirements for most permit types so MN staff asked all facilities with an air quality permit to
report GHG emissions. The program went into effect in 2011 for small facilities and for everyone else in
2012. The MPCA asks that facilities report emissions at the process level from all permitted units. Each
process is associated with a source classification code (SCC). To make reporting easier MPCA has generic
emission factors for C02, CH4 and N20. Mandatory Reporting Program emission factors for fuel
combustion have been mapped to individual SCCs. If facilities have GHG emissions from non-permitted
units, they can report them under a generic emission unit labeled "Non-permitted GHG emissions."
Facilities can report process emissions with several calculation methods including stack test, continuous
monitoring, material balance or some sort of emission factor. About 1,400 facilities are collected in the
annual emissions inventory, many of those emit small amounts of GHGs, with some 150 facilities that
report more than 10,000 tons of carbon dioxide equivalent (C02e). The reporting deadline is April 1. The
MN Greenhouse gas webpage can be found at: https://www.pca.state.mn.us/air/greenhouse-gas-
emissions-minnesota-0.
2.1.2 Summary of Massachusetts Greenhouse Gas Program
The Global Warming Solutions Act (2008) requires GHG emissions reductions from each sector of the
economy to a total of 25% below 1990 baseline levels in 2020 and an 80% reduction by 2050. It
required that the Massachusetts Department of Environmental Protection (MassDEP) promulgate
mandatory GHG reporting regulations.
Facilities required to report are those that hold a Massachusetts air operating permit (Title V of the U.S.
Clean Air act and 310 CMR 7.00, Appendix C), or those whose aggregate annual emissions exceed 5,000
short tons C02e. The first emissions year reported was 2009. The regulation contains a "once-in-always-
in" requirement, so some facilities report very low emissions (however, there is an exemption
procedure).
Applicability and compliance are at the facility level, but reporting is at the unit or process level. Major
sectors captured include:
o Electric Generating Units (EGUs, fossil and waste-to-energy)
o Institutions (hospitals, universities, public housing, etc.)
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o Landfills
GHGs reported include: C02 (fossil and biogenic reported separately), CH4, N20, SF6, HFCs and PFCs.
About 300 facilities report. In 2015, the 25 largest emitters accounted for 76% of total C02e reported
under the program. Over 90% of total emissions are from stationary combustion.
The reporting deadline is April 15.
More information on the MA GHG reporting program can be found at:
http://www.mass.gov/eea/agencies/massdep/climate-energy/climate/approvals/ma-greenhouse-gaS"
emissions-reporting-program.html
2.1.3 Summary of Oregon's Greenhouse Gas Program
Oregon's Greenhouse Gas Reporting program collects data from petroleum importers, natural gas
suppliers, landfills, electric utilities and air quality permit holders. The air quality permit holders
reporting program is the portion of Oregon's program that most closely parallels EPA's 40 CFR Part 98.
Below are the general details of that program:
• First emissions year reported - 2010
• Facilities report actual annual emissions
• Applicability:
o Facilities with an air permit (Air Contaminant Discharge Permit or Title V permit) that
emit over 2,500 MTC02e in a calendar year,
o If a facility falls below the threshold for three consecutive years, it may cease reporting
• Applicability and compliance are at the facility level. Reporting varies by source, some sources
report fuel types and volumes, others aggregate process emissions which may or may not
contain unit level information.
• In 2015 Oregon's reporting rule was updated to parallel the quantification methodology of EPA's
GHG reporting rule. Sources are required to report all onsite combustion according to Subpart C
and process emissions from any process covered by Part 98 Subparts D through UU.
o Sources report both biogenic and anthropogenic emissions and must report C02, CH4,
N20, and fluorinated GHGs as defined in rule which is currently the same as EPA's
definition in rule.
o In 2015 we had 260 permitted facilities report GHG emissions to the program,
o The majority of the facilities report stationary combustion
o Major sectors for process emissions include:
¦ Semiconductor manufacturing
¦ Cement manufacturing
¦ Pulp and paper
¦ Landfills
• Reporting deadline is March 31st following the calendar year. The data is audited internally and
posted annually to the website.
• All reporting is completed through an online reporting tool, EZ-Filer.
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Data from the program is used to fulfill requests to support the Oregon Global Warming Commission,
our partner agencies and the general public. A portion of this data is also used to update the statewide
greenhouse gas inventory. For more specific details on reporting protocols can be found at:
http://www.oregon.eov/dea/aa/programs/Paees/GHG-Reporting.aspx.
2.1.4 Summary of Federal Greenhouse Gas Program
The GHGRP (codified at 40 CFR Part 98) requires reporting of greenhouse gas (GHG) data and other
relevant information from large GHG emission sources, fuel and industrial gas suppliers, and C02
injection sites in the United States. This data can be used by businesses and others to track and compare
facilities' greenhouse gas emissions, identify opportunities to cut pollution, minimize wasted energy,
and save money. States, cities, and other communities can use EPA's greenhouse gas data to find high-
emitting facilities in their area, compare emissions between similar facilities, and develop common-
sense climate policies.
A total of 41 categories of reporters are covered by the GHGRP. Facilities determine whether they are
required to report based on the types of industrial operations located at the facility, their emission
levels, or other factors. Facilities are generally required to submit annual reports under Part 98 if:
• GHG emissions from covered sources exceed 25,000 metric tons C02e per year.
• Supply of certain products would result in over 25,000 metric tons C02e of GHG emissions if
those products were released, combusted, or oxidized.
• The facility receives 25,000 metric tons or more of C02 for underground injection.
A list of covered types of industrial operations and informational resources can be found at:
https://www.epa.gov/eligreporting/resoyrces-subpart-glig-reportirig
Approximately 8,000 facilities are required to report their emissions annually (as of 2015). Total
reported emissions from these facilities are about 3 billion metric tons C02e, which is about 50 percent
of total U.S. GHG emissions. Additional GHGs are accounted for by approximately 1,000 suppliers. In
total, data covering 85-90 percent of U.S. GHG emissions are reported. A complete accounting of total
U.S. GHG emissions is available through a separate EPA report, the U.S. Greenhouse Gas Inventory.
These inventories are different and more information can be found in:
https://www.epa.gov/ghereportine/ereenhouse-eas-reportine-proeram-and-us-inventorv-greenhouse-
gas-emissions-and-sinksi.
Facilities in most source categories subject to Part 98 began reporting for the 2010 reporting year while
additional types of industrial operations began reporting for reporting year 2011. As of October 2016,
GHGRP data are now publicly available for 2010 through 2015. Facilities calculate their emissions using
methodologies that are specified at 40 CFR Part 98. and they report their data to EPA using the
electronic Greenhouse Gas Reporting Tool (e-GGRT). Annual reports covering emissions from the prior
calendar year are due by March 31st of each year. Once data are submitted, EPA conducts a multi-step
verification process to ensure reported data are accurate, complete, and consistent.
In terms of pollutants covered, all greenhouse gases identified by the IPCC that are included in national
inventory reports: C02, methane, nitrous oxide and F-GHGs (SF6, NF3, HFCs, PFCs, etc.). The GHGRP
program also requires reporting of biogenic C02. Biogenic C02 doesn't 'count' toward a facility's
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determination as to whether they have to report (25,000 metric ton C02e threshold) but if they're
required to report due to emissions of other GHGs they must report biogenic C02 as well.
Reporting of emissions is required at the unit/process level. Units can be aggregated and their
emissions totals reported as one.
"Facility" means any physical property, plant, building, structure, source, or stationary equipment
located on one or more contiguous or adjacent properties in actual physical contact or separated solely
by a public roadway or other public right-of-way and under common ownership or common control,
that emits or may emit any greenhouse gas. Operators of military installations may classify such
installations as more than a single facility based on distinct and independent functional groupings within
contiguous military properties. There are a few exceptions for "area sources" such as onshore oil & gas
production, SF6from electrical distribution systems and fugitive methane leaks from natural gas
distribution systems but this is the general definition for most source types.
This webpage should provide a good introduction into the GHGRP program (reporting threshold, etc.):
https://www.epa.gov/ghgreportirig/learn-about-greerihouse-gas-reportirig-program-ghgrp
2.1.5 Summary Comparison of Programs
In 2015, about 2,700 facilities were reporting their greenhouse gas emission to the three PDT states.
Table 2 shows the total facilities reporting to each state, and from those, how many were reporting to
the federal program as well.
Table 2. Facilities Reporting Greenhouse Gases in OR, MN, and MA
Year 2015
OR
MA
MN
TOTAL
Total GHG Reporting Facilities
260
300
2,200
2,760
Facilities Also Reporting to EPA
55
84
150
289
% in Common
21%
28%
7%
10%
Figure 3 is a graphical representation of the number of reporting facilities from Table 2, where the size
of the rectangle is representative of the number of facilities. Minnesota (blue) has the largest total of
reporting facilities (2,700) and Oregon and Massachusetts have almost the same amount (260 and 300
respectively). The areas within the smaller rectangles marked with a dark gray border, represent the
number of facilities also reporting to the GHGRP. While Oregon and MA have more than 20% of their
facilities also reporting to GHGRP, MN only has 7% of their total facilities also reporting to the federal
GHG program.
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Figure 3. Facilities reporting Greenhouse Gases in OR, MN, and MA
Oregon
Minnesota
GHG Reporting Program
Massachusetts
Some programs have things in common with others and there are also many differences. Table 3 is a
summary comparison of programs.
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Table 3. Comparison of State and Federal GHG Programs
Criteria
Oregon
Minnesota
Massachusetts
EPA Federal
Basis
Greenhouse Gas Reporting
Rule. Started in 2010, facilities
with an Air Contaminant
Discharge Permit or Title V
permit.
Data supports the Oregon
Global Warming Commission,
partner agencies and the
general public. Data is used to
update the statewide
greenhouse gas inventory.
First Part: Next Energy
Generation Act with
specific reduction targets.
Calls for statewide
emissions inventory.
Second Part: Minnesota
GHG reporting system
requires facilities with a
Title V permit, an Option
D Registration Permit
(small facilities (i.e.,
schools)) and facilities
holding a Capped permit
to report GHG emissions
to MPCA. All facilities
with an air quality permit
report GHG emissions
(small facilities in 2011 &
everyone else in 2012).
Global Warming Solutions
Act(2008)
40 CFR Part 98
Reporters
Petroleum importers, natural
gas suppliers, landfills, electric
utilities and air quality permit
holders AND those exceeding
the threshold
All facilities with an air
quality permit report
GHGs; there are rule and
stature requirements for
title V, small registration
permits, and capped
Facility holds a MA air
operating permit or
exceeds threshold
Large sources/direct
emitters (exceeding
emissions threshold); fuel
and industrial gas
suppliers (whose supply of
certain products would
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Criteria
Oregon
Minnesota
Massachusetts
EPA Federal
permits. MN does not
exceed the threshold if
have a threshold.
those products were
released, combusted, or
oxidized); and C02
injection sites (amount of
C02 for underground
injection exceeding the
threshold).
Threshold
2,500 metric tons of C02e in a
Based on holding permit.
Aggregate annual
25,000 metric tons of
calendar year for AQ permit
emissions exceed 5,000
C02e
holders.
short tons of C02e
Pollutants
C02 (fossil and biogenic
C02 (fossil, and biogenic is
C02 (fossil and biogenic
C02 (fossil and biogenic
reported separately),
reported as C02-B),
reported separately),
reported separately),
CH4,
ch4,
ch4,
ch4,
N20,
N20,
N20,
N20,
hydrofluorocarbons (HFCs),
HFCs,
HFCs
HFCs,
perfluorocarbons (PFCs),
PFCs,
PFCs
PFCs,
sulfur hexafluoride (SF6),
SFs
SFs,
SFs,
nitrogen trifluoride (NF3)
nf3,
Other fully fluorinated
GHGs, HFEs, very short-
lived compounds, other).
Geographic Scope
Electric utilities report
Statewide anthropogenic
Imported emissions are
Don't have reporting
EGUs
electricity use on a statewide
sources & emissions from
calculated in the
requirements for tracking
level (includes imported
imported electricity
inventory, nobody who
electricity coming from
electricity).
generated outside state
imports has to report
those. Electricity
consumption isn't
included in GHG
reporting. Scope 1
emissions are captured at
the generator level,
report their emissions.
outside the country.
There are requirements
on imports and exports of
fuels.
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Criteria
Oregon
Minnesota
Massachusetts
EPA Federal
Level of reporting
Varies by source:
Some report fuel types and
volumes, others aggregate
process emissions (may or may
not contain unit level
information)
Process level (SCC) for
each unit.
Unit or process level, to
the degree practicable.
Unit/process. Can
aggregate units as a single
unit. Can aggregate
emissions for a common
stack.
"Facility" Definition
Source as defined by the Clean
Air Act (CAA), 42 U.S. Code
Chapter 85, Subchapter III,
7602.
Entity holding an air
quality permit
Facility means a building,
structure or installation
located on contiguous or
adjacent properties of an
entity, or a natural gas
facility.
Any physical property,
plant, building, structure,
source, or stationary
equipment located on one
or more contiguous or
adjacent properties in
actual physical contact or
separated solely by a
public roadway or other
public right-of-way and
under common ownership
or common control, that
emits or may emit any
greenhouse gas.
Operators of military
installations may classify
such installations as more
than a single facility based
on distinct and
independent functional
groupings within
contiguous military
properties.
Relevant sectors for
comparison
Stationary combustion,
semiconductor manufacturing,
cement manufacturing, pulp
and paper, landfills
Taconite (production in
iron and steel or mining),
ethanol, general
stationary combustion
EGUs (fossil and waste-to-
energy), Institutions
(hospitals, universities,
All
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Criteria
Oregon
Minnesota
Massachusetts
EPA Federal
public housing, etc.),
Landfills
Methods
In 2015 parallels EPA'sGHG
rule methodology: Sources are
required to report all onsite
combustion according to
Subpart C and process
emissions from any process
covered by Part 98 Subparts D
through UU
Several calculation
methods including: stack
test, continuous
monitoring, material
balance or some sort of
emission factor. MPCA
has generic emission
factors for C02, CH4 and
N20. Mandatory
Reporting Program
emission factors for fuel
combustion have been
mapped to individual
SCCs. If facilities have
GHG emissions from non-
permitted units, they can
report them under a
generic emission unit
labeled "Non-permitted
GHG emissions."
Rely on GRP and Part 98.
As described in 40 CFR
Part 98.
GWP and EF Updates
Can recalculate emissions with
new emissions factors. Some
submissions are totals
calculated outside the system
and use of EPA data is needed
for recalculating.
GWP are assigned by the
agency, and they follow
the latest IPCC report.
They can resubmit
emissions online for the
current reporting year,
including changing
emission factors and
calculation methodology.
If changes need to be
made for prior years, they
Use data that is available
in the climate registry
system.
Use AR4 factors. (IPCC 4th
Assessment Report)
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Criteria
Oregon
Minnesota
Massachusetts
EPA Federal
have to resubmit a paper
copy.
Deadline
March 31st of the calendar year
April 1st of the calendar
April 15th of the calendar
March 31st of the calendar
following reporting year
year following reporting
year following reporting
year following reporting
year
year
year
Reporting System
EZ-Filer
Online reporting system
CEDR
Climate Registry
Information System (CRIS)
managed by The Climate
Registry, but is switching
to a new state specific
platform currently
undergoing review.
e-GGRT
GWP data
AR4 factors
AR4 factors
AR4 factors
Use AR4 factors (IPCC 4th
Assessment Report)
Emission Factor Data
Emission factors from 40 CFR
Generic emission factors
Whatever is in the climate
As described in 40 CFR
Part 98 Subpart C for
from MRR are available or
registry system is used.
Part 98.
combustion; facility
they can input site specific
determines emission factor for
factors
process emissions.
17
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3 1 i i i i ' i ' i k 1 | > i 11 Ai« > 'I p i !1 'grams
The program comparison allows for some high level conclusions about commonalities and differences
among programs and how to think about the common reporting framework in light of those. However,
details about differences might not become obvious from the previous exercise. A data element
comparison was done to reveal any relevant details about program differences.
The team discussed which sectors would be informative to compare and chose:
• General Reporting Requirements (GHGRP Subpart A) was included because it applies to all
facilities reporting to any of the sectors.
• Stationary combustion (GHGRP Subpart C), was chosen because it is a broad sector that is
somewhat straightforward to report and would likely have commonalities among different
states and the federal program.
• Iron and Steel (Subpart Q), and Municipal Solid Waste Landfills (Subpart HH), were included
because they each contain some nuances that might be insightful in terms the ability of the
common reporting framework to deal with them.
Each data element required by GHGRP for each of these sectors was compared to data elements
required by the states. A total of 388 data elements were compared. Each state noted if the data
element exists or doesn't exist as a state program requirement. The state noted if there was a data
element that exists for the state but not for the GHGRP. If a data element is required by both, but there
is some difference in the requirement, that difference was explained. Appendix A (excel file) contains
the data element comparison under the "C Q HH A data elements" tab. Some items are highlighted here
for discussion. The discussion is not intended to be exhaustive, but to highlight some of the issues that
arose during the comparison.
3.1 Su bpa irt A - Gein era II Reportii ing R . irn ein ts
Out of the data elements compared, 73 data elements in Subpart A were identified as being unique to
GHGRP and were related to the use of Best Available Monitoring Methods (BAMM), which is not
required by any of the states, and was relevant in 2010 and 2011. These can be found in the Appendix A
excel file under tab "Other A data elements". In some cases more detail is required by some programs,
but not others (e.g. fluorinated gases are reported separately in GHGRP, MN and MA, but not OR).
3.2 Subpart C - Stationary Combustion
From the comparison in Subpart C it was noted that some data elements can exist in one program and
not another, and even if they do exist in both, they might be slightly different in their definition or
required characterization. Examples include:
18
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• OR doesn't require a unit ID but the other programs do.
• The maximum rated heat input capacity of the unit in mmBtu/hr is required by GHGRP and MN
but not OR and MA.
• Some states align their requirements with those of the GHGRP while others do not. For
example, for each type of fuel combusted OR requires the use of Tier 1 methodology or Tier 4 if
they have Continuous Emissions Monitoring Systems (CEMS). The other states don't have that
requirement.
• MA and OR don't require separate reporting of biogenic C02when using CEMS.
• The GHGRP and MN require the maximum rated heat input capacity at the unit level, but is not
required by either OR or MA.
• OR and MN don't have the option to report total emissions for aggregated units, as opposed to
individual units. GHGRP and MA allow for the aggregation of emissions from several units, for
example, that vent to a single stack or are served by a common metered natural gas stream.
• The GHGRP asks for monthly quantity of fuel combusted but states only require the annual
value.
3.3 S u b p a irt Q - II r o in a in d St e e II
The comparison for this subpart excluded MA since it has no Iron and Steel facilities that would report
emissions. Examples of data element differences and similarities are:
• All programs require annual C02 emissions for all units except de-carbonization vessels.
• Only the GHGRP requires information about the method used to determine carbon
content (from lab analysis, not for CEMS) for all units except de-carbonization vessels
that are not argon-oxygen de-carbonization vessels. Some states obtain this
information through supplemental information that the facility can submit.
3.4 Subpart II Ill ! - Municipal Solid Waste Landfills
The landfills comparison highlighted differences such as GHGRP requiring more detail in some cases and
some programs requiring information that others don't. For example:
• The GHGRP requires the year in which the landfill started accepting waste for disposal,
landfill capacity, and details about leachate, but the three states don't have that
requirement.
• The volumetric flow of landfill gas collected for destruction is required in MN and
GHGRP but not in MA or OR.
• The annual quantity of recovered methane is required in OR and GHGRP but not MA or
MN.
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4 Unit-to-Unit Mapping
During team discussions staff from states explained that they use GHGRP data to validate GHG
emissions submissions to their own programs. While data elements are not identical in some cases,
there are enough similarities for the GHGRP to be helpful in weeding out submissions that look
incorrect: for example, emissions off by several orders of magnitude.
This section includes highlights from the unit-to-unit mapping exercise by the states. Each state
provided a narrative of how GHGRP data is used to validate data submitted to the state's GHG program.
Then, each state selected one facility that submitted GHG emissions data to both the state GHG
program and the EPA's GHGRP. The narratives and details are provided in Appendices B (Minnesota -
Iron and Steel), C (Massachusetts - Stationary Combustion) and D (Oregon - Landfills). This section
highlights some findings from each comparison.
During this exercise, the states indicated that data pulled from the GHGRP Flight site and Envirofacts is
not in a format that lends itself to doing a side-by-side, emissions-by-unit comparison easily. This insight
points to a different aspect of the combined reporting, outside the scope of this R&D team, that is, none
the less, relevant to the CAER effort: the ability for combined reporting to allow for GHGRP sub-facility
level data extraction in a readily usable format that does not require further manual or electronic post-
processing (such as in excel format instead of pdf). This point is further discussed in Section 5.
4.1 Minnesota - Iron and Steel
Minnesota's unit-to-unit comparison was for an Iron and Steel facility for the year 2015. In that
comparison the following differences between emissions reported to the state and to GHGRP arose:
Methodology:
• Boiler emissions (reported to Subpart C): Generic emissions factors were applied for
emissions reported to the state but the tier 3 methodology was used for GHGRP.
• A taconite industrial furnace (reported to Subpart Q): emissions reported to the state
were calculated via the "in-process fuel use" method using generic emissions factors
(SCC), but estimates submitted to GHGRP were based on a mass balance equation of
taconite pellet production- results can be very different.
• Units of measure: nominal short tons were used to report to the state versus metric tons for
GHGRP.
• Aggregation of sub-facility data: One emissions value for taconite production was reported to
EPA but multiple processes for the same emission unit were reported to state
• Facility definition: One unit reported as part of the facility in GHGRP but not part of the facility
in the state - definition of "facility"
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4.2 Massachusetts - Stationary Combustion
The Massachusetts' unit-to-unit comparison was for a stationary combustion facility in the year 2016.
Highlights from that comparison are:
Methodology:
• The same data is reported to both federal and state programs since the methodologies are
derived from GHGRP for unit and process methodologies.
• In some cases, the state emissions factor is customized (state specific) and thus, different from
that of GHGRP.
• MA tends to use emissions factors derived from The Climate Registry's General Reporting
Protocol, which in many cases provides more technology specific emissions factors than EPA.
Source definitions:
• MA requires additional information for sources not reported to GHGRP. With the shift in
reporting systems, these differences may no longer exist (i.e. emissions from onsite motor
vehicles, refrigerants, and other small sources).
Units of measure:
• If the facility becomes confused about which emission factor to use, or which units of measure
to use, it may report incorrectly.
4.3 Oregon - Land fill Is
OR's unit-to-unit comparison was for a Landfill facility for the year 2015. Highlights of the comparison
are:
Methodology:
• Facilities can report either as combustion sources (fuel based) using IPCC AR4 emissions factors,
or their own heating values. Conversely, they can report process emissions.
• In some cases, flare emissions were included in unit reporting to OR, but not to GHGRP.
Source definitions:
• Some units were reported together to OR, and separately to the state making a comparison at
the unit level difficult. In that case, the state requested supplemental information, for example,
to verify fuel use.
21
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5 lii , b,': iit1 (.'lit M J, k'1 1 "in >\ ii iriiin Mi .hi- 'orI<
The team observed that there is some general overlap among programs, for example, in terms of the
pollutants required, the types of facilities reporting, and that most programs require some sub-facility
(unit/process) reporting. However, there are also various requirements and reporting methods unique
to each program that a common emissions reporting form would have to address. Both from the
comparison exercise, as well as from group discussions, the following items emerged as relevant for the
common reporting framework. Each item discussed points to a question or capability the common
reporting framework would have to address:
Burden: A common reporting emissions form or system SHOULD avoid duplicate entry of data/facility
info wherever possible. Facilities reporting to both are having to submit data separately to their state
system AND the GHGRP. To address this, one option is to enhance the interaction between the state
and GHGRP, where they have facilities reporting to both. However, in the broader context of CAER,
"burden" involves more than the state and GHGRP interactions so the definition of burden needs to be
looked into. If 10% of facilities in a state are reporting to both programs, this "burden" may not appear
large depending on what metric is used to define "burden" and how significant that burden is to that
10% of facilities. If the burden is minimal then the common emissions form may not be necessary.
Data Elements. In terms of a common emissions form, if some data elements are unique to one
program then one option would be for the form to be set up to obtain the data for GHGRP but for the
state this information would not be requested/sent. Another option would be to not include strictly
unique program data elements as part of the common emissions form at all if they are not seen as a
shared emissions data element. Understanding that these would have to be reported elsewhere to
meet the relevant program's requirements.
Biogenic fuels. What is considered a biogenic fuel may vary between different programs. For example,
GHGRP provides a list of biomass fuels with corresponding emissions factors in table C-l of Part 98. C02
emissions from these fuels are considered biogenic emissions. Part 98 provides a definition for biomass
in §98.6.
How might the common form be able to determine if a fuel is biogenic for one program and not
another? And then allocate its emissions according to the specific program requirements?
Input formats. When facilities are asked to report emissions the units of measure can be different (e.g.
short versus metric tons). GHGRP incorporates data as reported and conducts the necessary
conversions internally within the system.
For a common emissions form an option would be for the facility to report in whatever units of measure
it wants to and for the form to also conduct the relevant conversions internally. Another option would
be to request that the data be entered in specific units and for the conversion to be performed
beforehand. Ease and speed for the user could be factored in, together with some thought to reduction
in potential errors if the system performs the calculations versus outside system calculations. It would
be helpful if the data outputs included emissions factors (EFs), conversion factors, and other
methodology-specific variables.
Compatibility with current reporting systems: GHGRP and MA had "ground up" reporting systems built
for electronic reporting. MA is moving towards this approach using the criteria reporting system but
22
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they are finding there is no perfect overlap. MN is using the criteria pollutant reporting system already
in place for GHG reporting. OR has a GHG reporting system (EZ-Filer) that automates calculation
processes for fuel combustion and retains facility information (so a reporter doesn't have to re-enter it
every reporting instance).
How could the common form accommodate different electronic reporting systems that already exist in
some states? How could it better align with other reporting, such as for criteria pollutants. In other
cases, some states might not have electronic reporting systems to work with and might be able to
simply adopt the common form. For states that do have systems, some helpful features could be to
have the data be exportable in spreadsheet format, ideally Excel. What features of current systems
already in place could the common form take advantage of?
Subpart reporting. Whether a facility reports to one subpart or another is not always straightforward.
For GHGRP in very general terms, reporters that do not employ a CEMS report their combustion
emissions to Subpart C and their process emissions to the applicable corresponding subpart. However,
for reporters that do employ a CEMS report combined process and combustion emissions under the
applicable subpart associated with the industrial process. There are some nuances for specific industries
like pulp and paper and cement. For OR it is very similar. In general, MN and MA have an approach of
reporting at a unit level so combustion units report as combustion and process units as process. We had
previously learned that MN has any permitted units reporting individually. Permits include all pollutants
(criteria air pollutants (CAPs), hazardous air pollutants (HAPs) and GHG).
How could the common form keep track of the relevant emissions reporting and to which subpart they
should be "sent"? One option is for the form to keep track of the sub-facility data via FRS and then
allow the user to select what components of the facility they are reporting to and submit these to the
relevant subpart. For example, if for the state they must report at the unit level, they would do so, then,
depending on the parameters by which they are reporting, these components might be grouped to the
level and subpart that GHGRP would require.
Confidential Business Information (CBI). For all programs, the emissions data reported is public and is
not CBI. A facility can request protection of its data when applying for a permit on grounds that it is CBI,
but this happens in a handful of cases. For example, in MN out of 2,200 facilities reporting only 15 have
asked for their data to be considered CBI. Confidentiality can be at the process level. MA has the option
for a facility to request its data be CBI but they have not received a request yet.
While emissions data may not be CBI, activity or input data to perform emissions estimates calculations
may be CBI. For the GHGRP in some cases there are CBI considerations. For example, for some iron and
steel facilities taconite production is considered CBI. However, activity data required to estimate
emissions can be considered CBI and should not be disclosed publicly.
In consideration of the common emissions form, one issue to consider is whether the state faces CBI
constraints that must be adopted and the relevant business rules must be incorporated into the
common form. If the input data to do all relevant emissions calculations for both federal and state
program is CBI, then the common form would have to be able to use that data and possibly store it for
the facility (if that data is unlikely to change much from one year to the next), but not disclose it to
state/local/tribal (SLTs) agencies or EPA (GHGRP has this capability).
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Details in calculations. How detailed the reported data needs to be depends on the sector and
program. For example, EPA asks for more detail than MN for materials balance calculations.
How could the common form account for these differences? A common form could keep the most
detailed level data necessary. If one program (e.g. GHGRP) requires more detail, then the calculations
could be done at that level of detail within the common form, and the totals shared with the program
requiring less detail, (e.g. state). This would imply the facility entering some activity data for the
common form to process.
Actual Emissions vs. Potential to Emit. Most plants in MN are Title V and all Title V report GHGs. They
report actual emissions as opposed to potential to emit.
If some program reporting is based on potential to emit versus actual emissions, the common form
could intake the report based on PTE but not need to transmit the data to the program based on actual
emissions. The combined form might also keep track of the capacity of the facility, for example.
Methodology: In some cases, the methodology being used by programs is different. If the programs are
happy to accept one methodology, then the common form could either intake the data calculated
according to that methodology, or help the facility calculate its emissions by providing the necessary
equations, conversion factors, emissions factors and parameters for the calculation. This could be akin
to some web-based tax preparation services allowing the user to report both federal and state taxes. If
different methodologies are required, the common form would have to be able to calculate emissions
for each program according to its methodology. Ideally, the facility would only have to provide its
activity data one time and the combined form would perform all necessary calculations.
So far, the discussion has centered on data submissions by reporting industries within the scope of the
R&D project, dealing strictly with the interactions between GHGRP and state GHG programs. However,
as mentioned in the introduction, some items outside the scope of the study but relevant to CAER
emerged during the PDT work:
Facility Aspects: It is important to note that, from the CAER proposed future state vision, the shared
facility data would be handled via interactions between SLT facility data management systems and the
federal Facility Registry Service (FRS) and it's new data model. Work to this effect is already in progress
as part of the Facility Integrated Planning Team (IPT). However, facility elements that emerged as part
of this R&D project are documented here, since the group was tasked to report its findings.
Reporting Facilities: Reporting thresholds are different for each program. Some are based on
one criteria and others require more than one criteria such as size, emissions, potential to emit
or the existence of an air permit.
A combined reporting emissions form would have to be able to keep track of the thresholds,
intake data for all facilities but only deliver a subset of facilities relevant to each program to
federal and state, respectively.
Exiting Facilities. GHGRP has data elements for facilities who no longer need to report if they
meet certain criteria.
The common emissions form would have to be able to keep track of the reporting criteria for
each program.
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Definition of Facility: In some cases the definition of "facility" might be different between the
federal and the state program. So a unit or process that is considered part of a facility in one
program, may not be part of it in another.
The combined form would have to be able to keep track of the definition of facility for each
program.
Facility and Sub-facility Granularity. Some states (OR) as well as GHGRP allow for
units/processes to be grouped and reported as one, including up to the facility level, e.g. units
being fed by the same fuel line and/or units emitting to the same stack. Usually these units are
very similar in technology. Other states (MA, MN) have separate reporting for individual units.
MA allows the level of granularity to the most detailed degree possible. MN requires unit
reporting for permitted units. Units that are non-permitted can be added and reported as a
group.
How could the combined form accommodate different levels of reporting? (e.g. pull sub-facility
data from the Facility Registry System (FRS), allow the user to select the units/group of units it is
reporting to). The data should be at the level of granularity required by the more specific of the
state and federal requirements. For example, data required at the process or unit level by one
program, but at the facility level for another, would be processed so that the detailed data is
delivered to the first, and aggregated data to the second.
Combined GHG and NEI data: With respect to reporting "burden, it is also related to the submission of
other types of emissions data and the same facility data, which was beyond the scope of this study. So
reporting burden of facilities to GHG reporting programs (state and federal) has to be considered in the
context of reporting of other pollutants and duplication of reporting of facility data as well (see "Facility
Aspects" above).
Data Retrieval. However, during team discussions, states reported using GHGRP data for quality checks,
as explained in Section 4. While this is technically outside the scope of the PDT, it is nonetheless an
issue within the scope of CAER and was thus captured in this report. GHGRP data is used to compare
with data submitted to the states to find significant differences and make sure that there is some
consistency in what is being reported. If data elements and methods are not identical but the
comparison is helpful, then a benefit would be to provide the data in a format that would streamline the
comparison. To this effect, OR provided the following suggestions:
1. Provide the ability to download the more detailed "Reported Data" report in a .csv format
2. Provide a table with grouped emissions under subpart C by fuel type
3. Make a jump to for the specific areas that people may be looking to verify (i.e. total gas
collected by destruction systems)
a. The current report structure makes it difficult to find
b. Clearer labels would help as well
c. For landfills, reporting the amount of methane recovered in scf instead of or in addition
to metric tons
There are benefits to this for EPA as well. Within OAQPS, one important step in rulemaking has to do
with issuing regulatory impact analyses (RIAs) for major rules, including the National Ambient Air Quality
25
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Standards (NAAQS) for criteria pollutants. These RIA's are mandated. A significant portion of each
analysis involves calculating benefits of pollutant reductions in terms of human health and the
environment. Co-benefits are the benefits of the reductions from other pollutants that happen
concurrently with reductions of the target pollutant. For example, a reduction in NOx from more energy
efficient equipment might also lead to reductions of S02 and C02. Data retrieval that allows GHG data to
be incorporated into flat files with National Emissions Inventory (NEI) data, for example, would allow
EPA to conduct co-benefits analysis that include GHGs.
6 Next Steps
As described in Section 5, these findings are a first step towards understanding if and how a common
reporting form could be used to alleviate GHG reporting burden to industry, states and the federal
government. Some outstanding questions to investigate in a next phase of this project could include:
Further comparison between State and Federal GHG programs:
• Do our findings apply to other states? If not, what are the differences?
• Do our findings apply to all the other sectors?
• What features of a shared emissions reporting platform would promote reduced burden (and
avoid increased burden) for input data that can be used to report to both programs, respecting
CBI considerations?
Further CAER GHG emission-related items
• If states are already using same reporting system to collect both GHG and El (criteria) data,
could GHGRP data be incorporated into NEI through common reporting?
• How might states with facilities reporting to both federal and state programs retrieve
data in a format that would allow unit-to unit comparisons of what was reported to
both, for their QA checks?. A similar concept would apply to data required to be paired
with NEI data (for EPA co-benefits analyses, e.g.).
Potential next steps could include:
• A survey to understand which other state/local/tribal (SLT) agencies have GHG reporting
programs and a comparison of these GHG programs to the EPA's GHGRP,
• A comparison of additional sectors.
• A pilot whereby a state might receive GHGRP directly and thus only need to supplement any
additional data for facilities below their threshold.
• Whether there are other SLTs that would be interested in being able to obtain GHG data for
their states or are planning to do so, and have/don't have electronic reporting systems of their
own to collect this information.
26
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27
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Appendix A
Please refer to Excel File titled "Appendix A GHG PDT Data Element Comparison.xlsx" for the detailed
data element comparison between state and federal GHG programs. Q
Appendix B
Minnesota Narrative and Unit-to-Unit Comparison for Iron and Steel
Iron and steel facilities report GHG emissions to Minnesota Pollution Control Agency (MPCA) along with
CAPs on an annual basis. Many iron and steel facilities that report to MPCA also report to EPA under the
Greenhouse Gas Reporting Program.
Several rules and statuses cover GHG reporting in MN, for example, facilities that hold a federal title V
permit are required to report. Facilities report GHG emissions from all permitted units within the facility.
Emissions are reported at process level for each unit. Each process is associated with a SCC. Facilities
report emissions based on several calculation methods including engineering judgement, stack test,
continuous monitoring, site specific emission factor, material balance, and generic emission factor
among others.
MPCA reporting system includes generic GHG emission factors for C02, CH4 and N20. These emission
factors were augmented from EPA GHG Reporting Program (subpart C) and assigned to combustion
SCCs. For example, a combustion SCC for natural gas (10200602) was assigned C02, CH4, and N20
emissions factors to match those listed for Natural Gas in tables C-l and C- of 40 CFR 98. The emission
factor units for each pollutant were converted from 'Kg of pollutant/MMbtu' to 'LBs of
pollutant/MMBtu' (see an example below). In the Compliance Emissions Data Reporting Interface
(CEDRI) (the MPCA reporting system) database, if facilities assign an SCC (10200602) to a unit, GHGs will
automatically be calculated using the emissions factors provided in Table A 1 below.
Table A 1. Emissions Factors for Iron and Steel
SCC:10200602
C02 116.98 LB C02/MMBTU
CH4 0.0022 LB CH4/MMBTU
N20 0.00022 LB N20/MMBTU
For comparison between MPCA and EPA emissions, I choose to look at a taconite facility Northshore
Mining - Silver Bay. The facility reports to EPA under both subpart C (Stationary Combustion) and under
subpart Q (Iron and Steel Production). Below are two screenshots (
28
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Figure A 1 and Figure A 2) from the submitted reports showing the information reported in different
formats. Both screetshots show combustion emisions for 'Power Boiler 2'.
Figure A 1. EPA GHGRP Data
Unit Details:
Unit Name : Northshore Power Boiler 2
Unit Type : OB (Boiler, other)
Unit Description :
Individual Unit Details:
Use Ivt Indicator: Y
Maximum Rated Heat Input Capacity: 765 (mmBtu/hr)
Emission Details:
Annual CO2 mass emissions from sorbent: 0 (Metric Tons)
Annual Biogenic C02 Emissions: 0 (metric tons)
Tier Fuel Details:
Fuel : Subbituminous
Tier Name : Tier 3 (Equation C-3, solid fuel)
Tier Methodology Start Date : 2015-01-01
Tier Methodology End Date : 2015-12-31
Fuel Emission Details ;
Total C02 emissions
Total CH4 emissions
Total N20 emissions
Total CH4 emissions C02e
Total N20 emissions C02e
388729.0 (Metric Tons)
44.10 (Metric Tons)
6.414 (Metric Tons)
1102.4 (Metric Tons)
1911.3 (Metric Tons)
Carbon Content Substitute Data Information :
Total number of valid carbon content determinations : 12
Total number of carbon content substitute data values : 0
Frequency of carbon content determinations : Monthly
Total number of operating hours in the reporting year for which missing data substitution was used for fuel usage : 0
Figure A 2. MPCA Reporting
Units > EU0Q2 (EQUI151 > EU0Q2PD001 > Process Activities - SCC: 10100222
Throughput Material
Amount
Units
Parm Type Heat Content Units
Per Material Units Ash % Sulfur %
Carbon % Data Source
Performance Type
Cm,™,!
Type
I COAL.SUBBIT
|235258
|| TON
l> II II
II 11508 II0-22
|OPERATOR
1ACTUAL
IIR II
X
EQUIPMENT
6801
HR
[|
AGENCY
ACTUAL
R
X.i
HEAT
4058201
E6BTU
1
OPERATOR
ACTUAL
R
1 <1 1 .~!
»3* Add Activity
Process Specific Emission Factors
Type
Pollutant
Amount
Units
Throughput Material
Units
Op Source
Ctj
Measure 1
Measure 2
Rei
Start Date
End Date
Comment
X
E
LEAD
4.19E-6
LB
HEAT
E6BTU
F USEPA
r
(none)
(none)
U
1/1/2015
AP-42 (9/98) Tab_^
X
E
PM10-FIL
10.7
LB
EQUIPMENT
HR
F STACK TEST
F
FLTR.FABRH
(none)
U
1/1/2013
Assumed PM10-I
X
E
PM-FIL
10.7
LB
EQUIPMENT
HR
F STACK TEST
F
FLTR.FABRH
(none)
U
1/1/2013
Stack Test 02/12
A
E
PM-CON
4.6
LB
EQUIPMENT
HR
F STACK TEST
r
(none)
(none)
U
1/1/2013
Stack Test 02/12 T
<1
I
±r
«!}• Add Emission Factor
Process Emissions > Pollutant Category Filter | GHG I"* Display Only Highest Priority Emissions
A C02
X METHANE
A NITROUS OXID
||235258 TON COAL.SUBBlTfl)
235258 TON COAL.SUBBIT (I)
235258 TON COAL.SUBBIT (I)
|| SLT EF NCE
SLT EF NCE
SLT EF NCE
Jot
214 22 LB .< E6BTU HEAT - U 1..'1:2013 [SLT] [sta] ||*34674
0.022 LB IEGBTU HEAT - U 1/1/2014 {SLT] [sta] 44.64
0.00331 LB / EGBTU HEAT - U 1/1/2014 (SLT] [sta] 6.716
Activity
Fugitive
~ Add Emissions ii Calculate Emissions
The screenshots provide information collected by both programs. Values reported are different for
several reasons; one being MPCA GHG estimates relied on generic emission factors, while they did tier 3
29
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methodology to estimate emissions reported to EPA; secondly MPCA emissions are reported in nominal
short tons and those reported to EPA are in metric tons.
Next, I looked at information reported for Subpart Q. Below are screenshots of information reported to
both programs (Figure A 3 and Figure A 4).
Figure A 3. EPA GHGRP (Subpart Q)
Hrajgu Ldiuun UI uypiuuuLU,. u
No Cems Unit Details:
Unit Name: Northshore Taconite Line 11
Unit Description:
Unit Type: Taconite Indurating Furnace
C02Emissions: 47790.3 (Metric Tons)
Name
Type
Classification
# of Times Carbon Content Substituted
Carbon Content Basis
Other Carbon Content Basis
Annual Quantity Substituted Data Method
0
Supplier
0
ASTM D5373-08
0
ASTM D5373-08
0
ASTM D5373-08
Figure A 4. MPCA Reporting
Units > EU1Q4 (EQUI27) > EU104PDQQ! > Process Activities -SCC: 30302381
Throughput Material
Amount
Units
Parm Type Heat Content Units
Per Material Units Ash % Sulfur % Carbon % Data Source
Performance Type
Comment
Type
A HEAT
503675
E6BTU
| I
OPERATOR
ACTUAL
R
a PELLETS
958509
TON
0
OPERATOR
ACTUAL
R
-¦ || EQUIPMENT
||7212
IIHR |
11 II II
II II II II II agency
II ACTUAL
IIR II
•2- Add Activity
This shows the information MPCA received on number of pellets produced by "Taconite Line 11, process
one" however, the facility also reports in process fuel use. Below is a screenshot of that information
(Figure A 5).
Figure A 5. MPCA Reporting (In-process Fue! Use)
Units > EU104 (EQUI27) > EU1Q4PDQQ3 > Process Activities - SCC 39000699
Throughput Material
Amount
Units
F*arm Type Heat Content Units
Per Material Units Ash % Sulfur % Carbon % Data Source
Performance Type
*"9 Comment 1
I.-II NATURAL GAS
H465
|| E6FT3
][| || ||
[operator
|ACTUAL
R
I Pollutant Category Filter I
G r Display Only Highest Priority Emissions
Cti Tot Ctl Emission Factor
a|| CQ2
II465 E6FT3 NATURAL GAS (!)
1SLT EF NCE
nni 1116 98 LB1E6BTU HEAT -u 1/1/2013 [SLT] [sta] |28558
X METHANE
a NITROUS OXID
465 E6FT3 NATURAL GAS (I)
465 E6FT3 NATURAL GAS (I)
_
-------
For taconite production GHG emissions are estimated based on in process fuel use. Emissions are
calculated based on generic emission factors and are reported in nominal short tons.
EPA estimates are based on mass balance equation of taconite pallets. An additional difference between
the two reporting programs is the facility reported one emissions value for taconite production line to
EPA, while MPCA emissions are broken into multiple processes for the same emission unit. Table A 2 is a
comparison of EPA and MPCA data:
Table A 2. EPA and MPCA Unit-to-Unit Comparison
Unit
Northshore Power Boiler 2:
Subbituminous
GHGRP Total
Emissions
388729 Metric
Tons (MT) C02;
44.1 MT CH4,
6.414 MT N20
State GHG
Program Total
Emissions
434674 Short Tons
(ST) C02; 44.64 ST
CH4, 6.716 ST N20
Reason for difference
Methodology. EPA
value estimated via
tier 3; MPCA number
estimated using
generic emission
factors. Also reported
in different units.
Northshore Power Boiler 2: Natural
Gas
544 Metric Tons
(MT) C02, .01
MT CH4, .001
MT N20
601.9 Short Tons
(ST) C02, .011 ST
CH4, .001 ST N20
Methodology. EPA
value estimated via
tier 3; MPCA number
estimated using
generic emission
factors. Also reported
in different units.
GP Northshore Plant Heaters
5646.7 Metric
Tons (MT) C02,
.11 MTCH4,
.011 MT N20
Heaters are not
reported to MPCA
Northshore Babbitt Boiler
209.7 Metric
Tons (MT) C02,
.01 MTCH4,
.002 MT N20
Northshore
Babbitt is a
separate facility
and they report
GHGs for a
number of units.
Northshore Power Boiler 1:
Subbituminous
174648.1 Metric
Tons (MT) C02,
195703 Short Tons
(ST) C02, 20.1 ST
CH4, 3.04 ST N20
Methodology. EPA
value estimated via
tier 3; MPCA number
estimated using
31
-------
Unit
GHGRP Total
Emissions
State GHG
Program Total
Emissions
Reason for difference
19.85 MT CH4,
2.888 MT N20
Northshore Power Boiler 1: Natural
Gas
25437.9 Metric
Tons (MT) C02,
.54 MT CH4,
.054 MT N20
31291 Short Tons
(ST) C02, .5885 ST
CH4, .05885 ST
N20
Northshore Power Boiler 1: Distillate 29.5 Metric
Oil
Tons (MT) C02
33.1 Short Tons
(ST) C02, .001342
ST CH4, 0.000268
ST
Northshore Taconite Line 11
47790.3 Metric
Tons (MT) C02
57116 Short Tons
(ST) C02, 1.0742
STCH4, .10742 ST
N20
Northshore Taconite Line 12
44356.6 Metric
Tons (MT) C02
53124 Short Tons
(ST) C02, .999 ST
CH4, .10742 ST
N20
generic emission
factors. Also reported
in different units.
Methodology. EPA
value estimated via
tier 3; MPCA number
estimated using
generic emission
factors. Also reported
in different units.
Emissions reported in
different units
EPA estimated Co2
emissions from
taconite pallets based
on mass-balance
equation. MPCA
estimates GHG
emissions from in
process fuel use. The
facility used NG and
estimated emissions
from generic emission
factors
EPA estimated C02
emissions from
taconite pallets based
on mass-balance
equation. MPCA
estimates GHG
emissions from in
process fuel use. The
facility used NG and
estimated emissions
from generic emission
factors
32
-------
Unit
Northshore Taconite Line 6
GHGRP Total
Emissions
21105.6 Metric
Tons (MT) C02
State GHG
Program Total
Emissions
24819 Short Tons
(ST) C02, .4668 ST
CH4, 0.04668 ST
N20
Northshore Taconite Line 5
4621.9 Metric
Tons (MT) C02
5526 Short Tons
(ST) C02, .10395
STCH4, .010395 ST
N20
Reason for difference
EPA estimated C02
emissions from
taconite pallets based
on mass-balance
equation. MPCA
estimates GHG
emissions from in
process fuel use. The
facility used NG and
estimated emissions
from generic emission
factors
EPA estimated C02
emissions from
taconite pallets based
on mass balance
equation. MPCA
estimates GHG
emissions from in
process fuel use. The
facility used NG and
estimated emissions
from generic emission
factors
33
-------
Appendix C
Massachusetts Narrative and Unit-to-Unit Comparison for
Stationary Combustion
The MassDEP GHG Reporting Program is currently working to integrate GHG reporting into the existing
in-house platform used to collect other air pollution data from facilities (eDEP). From the program's
inception through emission year 2015, GHG emission reports were submitted using the Climate Registry
Information System (CRIS), maintained by The Climate Registry (TCR). Beginning with reports for
emission year 2016 (delayed until late 2017), reports will be submitted through eDEP instead. Due to
technical differences between the platforms, this transition is likely to result in minor changes to the
universe of emissions sources that can be reported. Currently, the MassDEP GHG reporting regulation
requires facilities to report emissions from on-site motor vehicles, refrigerants, and other small sources
that may not be accepted by eDEP.
For MassDEP GHG reporters that also report to EPA under Subpart C, the same information regarding
stationary combustion units is reported to both programs. Below are two screenshots (Figure A 6 and
Figure A 7) from reports submitted by UMass - Amherst showing the same information in different
formats. Both screenshots show C02, CH4 and N20 emission from natural gas consumption by "Boiler
#200."
Figure A 6. Emissions Displayed on EPA FLIGHT
Unit Name : Boiler #200
Unit Type : OB (Boiler, other)
Unit Description :
Individual Unit Details:
Use Ivt Indicator: N
Maximum Rated Heat Input Capacity: 179.7 (mmBtu/hr)
Emission Details:
Annual CO2 mass emissions from sorbent: 0 (Metric Tons)
Annual Biogenic C02 Emissions: 0 (metric tons)
Tier Fuel Details:
Fuel : Natural Gas (Weighted U.S. Average)
Tier Name : Tier 2 (Equation C-2a)
Tier Methodology Start Date : 2015-01-01
Tier Methodology End Date : 2015-12-31
Frequency of HHV determinations : Semiannually
January
February
March
April
May
June
July
August
September
October
November
December
N
N
N
N
N
N
N
N
N
N
N
N
Total C02 emissions
Total CH4 emissions
Total N20 emissions
Total CH4 emissions C02e
Total N20 emissions C02e
12859.6 (Metric Tons)
0.24 (Metric Tons)
0.024 (Metric Tons)
6.1 (Metric Tons)
7.2 (Metric Tons)
Equation C2a/C9a Inputs :
Fuel Quantity : 236400000 (scf/year)
Use Default High Heat Value : true
High Heat Value : 0.00102521 (mmBtu/scf)
34
-------
Figure A 7. Emissions Displayed on MassDEP Submission Report
I
BOILER #2Q0-HP (EMISSION UNIT ^Stegragy CQ2 12,859.621612,859.6.. Emission Factor Commercial Boilers Natural Gas MWitu fegSSIfy
Scope 1
SC'LEft «OQC-HP 'EM SC 0\ U'Jif ^Sta'onar* CH4 Q 2 IP'2 4 5?£G Et iss -n Facto C.rm wl Be era Matu a' Sas 0 <» g/VVBtu
" Scop« 1
3ULER #2Q£ hP iEM j'Jlh U.MT St.' s,^C 0 21? 2 tT 61944 En rr-n Factn Ccnm,c jal ecer- Natl 3r* 1 . ij0 V!mb ° 0 * ^t/UEM
#16Ai Combusaon - B»u / SCF MMBtu *
Jvup'C ;
In this case, the fuel quantity and C02 emissions reported to both programs are identical, as seen above.
However, the CH4 and N20 emissions are reported differently to each program; this is most likely a data
entry error.4 Regarding methodology, the Massachusetts regulation references TCR's General Reporting
Protocol (GRP) for unit- and process-specific methodologies; the GRP is largely derived from EPA
methodologies, so emissions that are reported to both programs are typically identical.
The Massachusetts program requires reporting of additional emissions beyond what is required by
Subpart C. Massachusetts reporters have historically reported emissions from motor vehicles operated
by the facility owners, refrigerants from on-site equipment, and other small sources. The differences
between the EPA and MassDEP submission reports are largely due to the additional sources reported to
MassDEP rather than to differences in calculation methodologies (Table A 3). As noted above, some of
these additional sources may no longer be required through eDEP, which would bring the two programs
closer together.
Table A 3. Unit-to-Unit Comparison of Data Reported to Both Programs
Unit
GHGRP Total
Emissions
State GHG Program
Total Emissions
Reason for difference
Boiler #200-HP
(#16A): Natural Gas
12,859.6 Metric Tons
(MT) C02; 0.24 MT CH4;
0.024 MT N20
12,859.6 MT C02, 0.22
MTCH4; 0.218 MT N20
Same for C02; CH4 EFs
differ slightly (GRP); N20
EF error in state report
Boiler #300-LP
(#16B): Natural Gas
13,498.4 Metric Tons
(MT) C02, 0.25 MT CH4;
0.025 MT N20
13,498.5 MT C02; 0.23
MT CH4; 0.23 MT N20
Same (?) for C02; CH4
EFs differ slightly (GRP);
N20 EF error in state
report
Boiler #400-LP
(#16B): Natural Gas
7,543.3 Metric Tons (MT)
C02, 0.14 MT CH4; 0.014
MT N20
7,543.3 MT C02; 0.13 MT
CH4; 0.13 MTN20
Same for C02; CH4 EFs
differ slightly (GRP); N20
EF error in state report
4 Facilities often submit the EPA reports several weeks before submitting to MassDEP. Occasionally, facilities have
noted confusion about differences in units or conversion factors between the two programs that can cause errors
when submitting to MassDEP.
35
-------
Unit
GHGRP Total
Emissions
State GHG Program
Total Emissions
Reason for difference
Combustion
Turbine Generator
(#15A): Natural Gas
51,517.6 Metric Tons
(MT) C02, 0.97 MT CH4;
0.097 MT l\l20
51,517.6 MT CO2; 3.69
MT CH4; 0.87 MT N2O
Same for CO2; Very
different EFs for CH4,
N2O
Dining Commons -
NG Cooking
Equipment: Natural
Gas
526.7 Metric Tons (MT)
CO2, 0.01 MT CH4; 0.001
MT l\l20
526.7 MT CO2; 0.05 MT
CH4; 0.001 MT N2O
Same for CChand N2O;
different EF for CO2.
EU#28-Small
Boilers: Natural Gas
654.2 Metric Tons (MT)
CO2, 0.01 MT CH4; 0.001
MT l\l20
427.03 MT CO2; 0.01 MT
CH4; 0.007 MT N2O
Same for CH4;Different
fuel quantities reported
(different units)
HRSG w/ Duct
Burner (#15B):
Natural Gas
13,649.3 Metric Tons
(MT) CO2, 0.26 MT CH4;
0.026 MT l\l20
13,649.3 MT C02; 0.23
MT CH4; 0.23 MT l\l20
Same for CO2; CH4 EFs
differ slightly (GRP); N2O
EF error in state report
Space heating:
Natural Gas
718.9 Metric Tons (MT)
CO2, 0.01 MT CH4; 0.001
MT l\l20
718.9 MT CO2; 0.1 MT
CH4; 0.001 MT l\l20
Same for CChand N2O,
different EFs for CH4
Boiler #200-HP
(#16A): Fuel Oil #2
146.4 Metric Tons (MT)
CO2, 0.01 MT CH4; 0.001
MT l\l20
155 MT CO2; 0.00042 MT
CH4; 0.001 MT N2O
Same for N2O; For MA,
used customized EF for
#2 oil
Boiler #300-LP
(#16B): Fuel Oil #2
4229.8 Metric Tons (MT)
CO2, 0.17 MT CH4; 0.034
MT l\l20
4478.1 MT CO2; 0.012 MT
CH4; 0.024 MT N2O
For MA, used
customized EF for #2 oil
Boiler #400-LP
(#16B): Fuel Oil #2
3037.3 Metric Tons (MT)
CO2, 0.12 MT CH4; 0.025
MT N2O
3215.54 MT C02; 0.009
MTCH4; 0.017 MTN2O
For MA, used
customized EF for #2 oil
Combustion
Turbine Generator
(#15A): Fuel Oil #2
2310.3 Metric Tons (MT)
CO2, 0.09 MT CH4; 0.019
MT N2O
2445.9 MT C02; 0.1 MT
CH4; 0.0198 MT N2O
For MA, used
customized EF for #2 oil;
CH4 and N2O EFs differ
slightly (GRP);
Small Boiler (3
Units): Fuel Oil #2
93.9 (MT) CO2, 0 MT CH4;
0.001 MT l\l20
99.4 MT CO2; 0.01344 MT
CH4; 0.001 MT N2O
Same for N2O; No CH4
reported to EPA; For
MA, used customized EF
for #2 oil
Propane Space
heating
92.3 (MT) CO2, 0 MT CH4;
0.001 MT l\l20
90.2 MT CO2; 0.01468 MT
CH4; 0.001 MT l\l20
Same for N2O; No CH4
reported to EPA.
Note: Many of the small discrepancies are due to minor differences between the emission factors (EFs) used by
each program. The Massachusetts GHG Reporting Program points to The Climate Registry's General Reporting
Protocol (GRP) for EFs; in several cases, the GRP provides more technology-specific EFs by fuel than EPA.
36
-------
D
Oregon Narrative and Unit-to-Unit Comparison for
Landfills
Municipal Solid Waste Landfill reporting is complex in Oregon. If our facilities report to EPA, they are
only required to send us the summary of the report from EPA. However, we encourage them to report
through our application, EZ Filer, as well.
If they do not report to EPA because they are below the threshold (of 25,000 metric tons of C02e), they
are required to use EZ-Filer to report to the state. This is only true if they are above our threshold of
2,500 metric tons C02e and if they have an air quality permit. Even if they do hold an air quality permit,
they do not need to report fugitive emissions from the landfill. DEQ can use the data from their solid
waste permit to calculate fugitive emissions and to reduce the reporting burden on the facility, we do
not require them to report using EZ Filer. If they don't hold an air quality permit they are not required
to report. We use the data for their facility from the solid waste permit to determine their GHG related
emissions.
Facilities can report in EZ-Filer using several different methods. One is reporting combustion devices
(Subpart C). Using this option, facilities will enter the fuel being used and EZ-Filer will calculate the
emissions from that fuel for C02, CH4, and N20 using IPCC AR4 emission factors. If they have their own
heating value, they can report the fuel in mmBTU, otherwise, the heating value is the default from the
IPCC AR4.
The other way they can report is choosing process emissions. This is where facilities report the process
emissions associated with the specific subpart they are reporting under. Process emissions can be
biogenic or anthropogenic and require the specific subpart the facility is reporting under be listed (in the
case of municipal landfills, Subpart HH). They may also use this method if they are reporting tier 4
calculations, choosing subpart C as the subpart to report under. If they use this method they calculate
any emissions themselves and then enter the total in C02e.
Figure A 8 is a screen shot of an exported report from a landfill that reported using EZ-Filer. The facility
has combined comfort heaters using similar fuels, control devices, and listed the landfill emissions
separately. With everything grouped in this way, it can be difficult to determine what is included in the
5 units. The grouping that occurs in EZ-Filer often does not follow how units are reported in their annual
reports for their air quality permits to DEQ or how they are reported to EPA. Below is Table A 4 showing
a direct comparison between Oregon and EPA reported emissions
37
-------
Figure A 8. EZ Filer Landfill Report Example
Greenhouse Gas Emissions Calculation Details
Columbia Ridge Landfill
Facility: 11-0001 - Waste Management Disposal Services of Oregon, Inc. Emissions Year: 2015
Emissions
Unit/Device ID
Fuel/Process
Annual Rate
Energy Content
Pollutant
Emission
Factor
Emission
Factor Unit
Emissions
Emissions Unit GWP
C02e
C02e Unit
Comfort Heaters
Kerosene 52,560 mmbtu 5.67 mmbtu/barrel
1
CH4
0.0030
kg/mm btu
0.158
metric ton
25
3.942
metric ton
C02
75.2000
kg/mm btu
3,952.512
metric ton
1
3952.512
metric ton
N20
0.0006
kg/mm btu
0.032
metric ton
298
9.398
metric ton
Sub total:
3965.852
metric ton
Comfort Heating
Propane |46,866 mmbtu |3.8227 mmbtu/barrel |
CH4
0.0030
kg/mm btu
0.141
metric ton
25
3.515
metric ton
C02
62.8700
kg/mm btu
2,946.465
metric ton
1
2946.465
metric ton
N20
0.0006
kg/mm btu
0.028
metric ton
298
8.380
metric ton
Sub total:
2958.360
metric ton
Control Devices
Biogas
(methane)
2,868,346,400 cf
485 mmbtu/mmcf
CH4
0.0032
kg/mm btu
4.452
metric ton
25
111.292
metric ton
C02
52.0700
kg/mm btu
72,437.077
metric ton
1
72437.077
metric ton
N20
0.0006
kg/mm btu
0.876
metric ton
298
261.174
metric ton
Sub total:
72809.543
metric ton
Municipal Waste Landfill
Process-Bio 309,052 metric ton
1
CH4
kg/mm btu
0.000
metric ton
1
0.000
metric ton
C02
1.0000
kg/mm btu
309052.000
metric ton
1
309,052.000
metric ton
N20
kg/mm btu
0.000
metric ton
1
0.000
metric ton
Sub total:
309,052.000
metric ton
Comfort Heaters
Residual Oil
#6
3.066 mmbtu
6.3 mmbtu/barrel
CH4
0.0030
kg/mm btu
0.009
metric ton
25
0.230
metric ton
C02
75.1000
kg/mm btu
230.257
metric ton
1
230.257
metric ton
N20
0.0006
kg/mm btu
0.002
metric ton
298
0.548
metric ton
Sub total: 1
231.035
metric ton
| Total emissions for this facility!
389016.789
metric ton
38
-------
Table A 4. Direct Emissions Comparison by Unit for EPA
Units
Fuel Type
Oregon
UOM
EPA
UOM
EPA
conver
ted
Oregon
COz
EPA COz
Oregon
ch4
EPA
ch4
Oregon
n2o
EPA
NzO
Notes
Comfort
Heaters
Kerosene
52,560
mmBTU
389,333.4
gallons
52,560
3,952.51
3,952.60
0.158
0.160
0.032
0.030
this is the only set of units
whose fuel and emissions carry
over perfectly
Comfort
Heaters
Propane
46,866
mmBTU
18,627,18
6
scf
46,568
2,946.47
2,879.50
0.141
no
value
0.028
no
value
assuming conversion
difference is causing the
difference in total fuel and
emissions CH4 and N2O
emissions read 0 in
spreadsheet sent by Kong
(perhaps too small?)
Control
Devices
(generators)
Biogas
2,868,346,4
00
cf
2,016,711
,000
scf
N/A
72,437.0
8
56,961.2
0
4.452
3.5
0.876
0.69
This should be the two
generators burning landfill gas,
however, the facility included
flares in their reporting to
Oregon which is why the
numbers do not match
between EPA and Oregon
Municipal
Waste
Landfill
Biogas
309,052
CO 2e
301,685
CO 2e
it appears the facility took this
number from the top ofthe
facility site details page, it is
the C02e emissions from
facility subparts C-ll, SS, and TT
in metric tons, it includes
everything except the two
generators burning landfill gas
as the generators are the only
biogenic emissions from the
facility. What should have
been reported here were the
methane emissions coming
from the landfill that were not
captured by the flare. This is
301,685 mtC02e and is noted
in the less detailed breakout
on EPA's website but nowhere
else. It was quite difficult to
compare this to the EPA report
and figure out what the facility
should have reported here.
Comfort
Heaters
Residual
Oil #6
3,066
mmBTU
22,217
gallons
3,332
230.26
226.9
0.009
0.01
0.002
0.002
used conversion of
6.3mmBTU/barrel to convert
39
-------
Process for Verifying Emissions
1) Compare the units to see how the facility is reporting to us versus the EPA.
a. In the example above, comfort heaters were reported as Subpart C emissions, grouped by
fuel burned. These are not grouped for EPA, details of fuel use and emissions are listed
separately for each unit.
i. For this particular facility, I requested that they turn in supplemental information. I
did this because all of the comfort heaters were listed separately (see Figure A 9) in
the EPA report while they were aggregated by fuel type for our report and for
verification of the fuel usage. This made it much easier to verify totals of fuels
burned versus doing it using the EPA report because the format of the report detail
from EPA does not allow for easy copy/paste into a spreadsheet or a .csv download.
Figure A 9. Example of Unit Listing in EPA Report
Unit Details:
Unit Name : PROPHTR031
Unit Type : CH (Comfort heater)
Unit Description :
Individual Unit Details:
Use Ivt Indicator: N
Maximum Rated Heat Input Capacity: 0,1 0 (mmBtu/hr)
Emission Details:
Annual CO2 mass emissions from sorbent: 0 (Metric Tons)
Annual Biogenic C02 Emissions: 0 (metric tons)
Tier Fuel Details:
Fuel ' Propane Gas
Tier Name : Tier 1 (Equation C-l)
Tier Methodology Start Date : 2015-01-01
Tier Methodology End Date : 2015-12-31
Fuel Emission Details :
Total C02 emissions
Total CH4 emissions
Total 1*120 em
53,8 (Metric Tons)
0 (Metric Tons)
0 (Metric Tons)
Equation C1/C8 inputs :
Fuel Quantity : 348171,7 (scf/year)
Unit Name : PROPHTR032
Unit Type : CH (Comfort heater)
Unit Description :
Individual Unit Details:
Use Ivt Indicator: IM
Maximum Rated Heat Input Capacity: 0.1 0 (mmBtu/hr)
Emission Details:
Annual CO2 mass emissions from sorbent: 0 (Metric Tons)
Annual Biogenic C02 Emissions: 0 (metric tons)
b. Control Devices were also combined in reporting to us. The facility included two engines
that run off of landfill gas under this heading. The numbers did not match up with what was
reported to EPA.
i. In talking to the facility, I found that they included all of the flare gas that had been
collected (including portions that went to engines on-site and flares) in this section.
The flares should have been reported separately as biogenic process emissions -
only the C02 from those emissions are biogenic. The CH4 and N20 from the flares
should have been reported separately as anthropogenic process emissions. In
addition, the engines should have been separated out and reported as units under
subpart C.
40
-------
c. Municipal Waste Landfill CH4 emissions were reported separately as process emissions.
i. These emissions were reported as biogenic. These emissions should be reported as
anthropogenic.
ii. Municipal waste landfill reporting (emissions from landfill not captured by a
collection system) can be a confusing area when verifying with EPA's reported
numbers. The facility can choose between two different ways to calculate these
emissions for the EPA reporting and the results can be quite different. Reporters
often report different emissions to us than they do to EPA.
1. It appears that what happened here is that the facility reported all the
emissions, including stationary combustion emissions, in this section (see
Figure A 10). The only portion that should have been reported here were
the 301,685 C02e methane emissions coming off of the landfill and not
being captured by the flares.
Figure A 10. Total Facility Emissions Reported to EPA GHGRP
Emissions by Source/Pfrocess in metric tons C02e
(AR4 CUflPs, excluding Biogenic C02)
Stationary Comcustion
7,3 87
Muri : L>a 1 Laidfil s
301,685
.aicfir in 55 ors estimated '¦ om
notSe'ed n-stha'ie gene-a: on and
c!-ier 'actors
120,978
_an: fi- -emjss or.s estimated from
renere recovery, destruction
aid other 'actors
301,685
_anofi s '.vitb active land fi: gas col'ect oi systeTS
TLSt calculate and report CHG e-nissic-is in two ways,
res'.rts cfeach a>e d splayed iere. Only or.s of
these rubbers fin most cases the larger value) is used
as the eTt'ss ens from the landfill. Learn more about
2) After reviewing the submissions and talking to the facility contact, I did not have them re-submit for
this year. We used the data from EPA for the emissions for this facility in our annual report.
However, in 2017, the facility will be reviewed again and made to change any issues that are found.
Updates EPA could make that would make comparison easier
1. Provide the ability download the more detailed 'Reported Data' report in a .csv format
2. Provide a table with grouped emissions under subpart C by fuel type
3. Include landfill flares under subpart C for clearer reporting of N20 and C02 from their combustion
4. Make a jump to for the specific areas that people may be looking to verify (i.e. total gas collected by
destruction systems)
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a. The current report structure makes it difficult to find
b. Clearer labels would help as well
c. Reporting the amount of methane recovered in standard cubic feet (scf) instead of/in
addition to metric tons
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