EPA Greenhouse Gas Reporting Rules and Flow Measurement

You only have to do a Google News search on EPA greenhouse gas reporting rules to know this is a large issue on the minds of U.S. process manufacturers.

The U.S. Environmental Protection Agency (EPA) has released a mandate, 40 CFR Part 98 requiring the monitoring and reporting of greenhouse gas (GHG) emissions effective January 1st 2010. These regulations are more than 1200 pages in length. Emerson’s Micro Motion division has highlighted some of the key considerations in an EPA Greenhouse Gas (GHG) Reporting Rules FAQs web page. Tom O’Banion, chemical industry director for the Micro Motion team, shared some of the key issues these regulations introduce.

The most significant parts of the new regulations for most manufacturers apply to the emissions of carbon dioxide (CO2) and nitrous oxide (N2O) resulting from the burning of fossil fuels. Methane (CH4) is another source typically caused by leaks in pipelines, caverns, etc. In addition to combustion, N2O is produced from other sources including landfills and feedlots. Some of the carbon dioxide equivalents (CO2e) sources that manufacturers now must measure include fuel oil, fuel gas, natural gas flow and BTU, refinery fuel gas, landfill gas, and black liquor. Other sources that may be measured include refrigerant gases such as chlorofluorocarbons (CFCs) and perfluorocarbons (PFCs), which have extremely high GHG values.

The CO2e concept is described in the FAQs:

GHGs each have their own heat‐trapping ability. GHG’s other than CO2 have a multiplier associated with them that accounts for their greater ability to trap heat. (This multiplier is called “Global Warming Potential” or GWP). For example, CH4 has a multiplier of 21, meaning 1 metric ton of CH4 is the same as 21 metric tons expressed in CO2e. Customers will convert emissions of each GHG to CO2e and add them together to see if they exceed the reporting threshold.

The 40 CFR Part 98 regulations impact approximately 10,000 U.S. facilities. On its impact:

Every Emerson end‐user customer in the U.S. will have to follow the “applicability” instructions [EPA applicability calculator] within the new rules to determine if they have to report. It seems the vast majority of large end‐users will have to create and implement a reporting system. ALL Refineries and Petrochemical manufacturers are subject to the new rules, regardless of their capacity. The same is true of any plant making: Adipic Acid, Aluminum, Ammonia, Cement, Lime, Nitric Acid, Phosphoric Acid, Silicon Carbide, Soda Ash, Titanium Dioxide, and several other chemicals. Most other plants have several “stationary combustion units” and will have to report if the aggregate emissions of all these units (boilers, furnaces, etc.) exceeds 25,000 metric tons/year CO2e.

Micro Motion Coriolis flow and density meters measure direct mass flow of both liquid (to 0.05% accuracy) and gas (to 0.35%) from a single device. The guidelines currently call for 5% or better but are expected to tighten in the coming years. The vast majority of these measurements are made on fuel lines to boilers and furnaces.

To help satisfy the regulation’s “manufacturer recommended best practice“, these devices have on-line meter verification. This verification process helps you determine the performance of the sensor and electronics while the meter remains on line. Compared with conventional off-line verification approaches, this can also significantly reduce ongoing maintenance and calibration costs. Records management required for on-line regulatory reporting as well as routine calibration and troubleshooting is streamlined.

Given the significance of these regulations to U.S. process manufacturers, I’ll do future posts looking at some of the other technologies that can be applied to help comply with these reporting rules.

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