Energy and Environment MonitorThe U.S. Environmental Protection Agency (EPA) announced on June 29, 2010, that it is finalizing requirements under its national mandatory greenhouse gas (GHG) reporting program for underground coal mines, industrial wastewater treatment systems, industrial waste landfills and magnesium production facilities. EPA intends to use the data from these sectors to “provide a better understanding of GHG emissions” and that the data “will help EPA and businesses develop effective policies and programs to reduce them.”
EPA noted that methane is the primary GHG emitted from coal mines, industrial wastewater treatment systems and industrial landfills and that it is more than 20 times as potent as carbon dioxide at warming the atmosphere. The EPA announcement continued to say that the main fluorinated GHG emitted from magnesium production is sulfur hexafluoride, “which has an even greater warming potential than methane, and can stay in the atmosphere for thousands of years.”
These affected source categories must begin collecting emissions data on January 1, 2011, and submit initial annual reports to EPA by March 31, 2012.
EPA also, in a separate proposed rule, opened a public comment period regarding which industry related GHG information would be made publicly available and which would be considered confidential. All emission data are public under the Clean Air Act, However; some non-emission data may be considered confidential if it relates to information which, if made public, could harm the competitiveness of a business. EPA provided as an example of data that may be confidential data under its proposal information reported by fossil fuel and industrial gas suppliers related to production quantities and raw materials.
The GHG reporting program requires suppliers of fossil fuels or industrial GHGs and large direct emitters of greenhouse gases to report to EPA. EPA asserts that collecting GHG data “will allow businesses to track emissions and identify cost effective ways to reduce emissions.”
Under the Greenhouse Gas Reporting Program, owners and operators of facilities that are subject to quarterly sampling of mine ventilation systems by the Mine Safety and Health Administration (MSHA) must report emissions from underground coal mines and all other source categories located at the mine for which methods are defined in the rule. Owners and operators are required to collect emission data; calculate GHG emissions; and follow the specified procedures for quality assurance, missing data, recordkeeping, and reporting. Total annual methane emissions are to be calculated as the sum of quarterly methane that is liberated from ventilation wells and shafts and degasification systems, less the quantity that is collected and destroyed.
Each underground coal mine meeting the MSHA threshold must monitor the following parameters for their mine ventilation air:
1) Quarterly volumetric flow rate of gas for each ventilation monitoring point;
2) Quarterly methane concentration for each ventilation monitoring point;
3) Quarterly temperature values at the time, location, and conditions for which measurements are made;
4) Quarterly pressure values at the time location, and conditions for which measurements are made; and
5) Quarterly moisture content at the time, location, and conditions for which measurements are made.
Each underground coal mine using a degasification system (deployed before, during, or after mining operations) must also monitor the following parameters:
1) Weekly volumetric flow of methane liberated from each degasification monitoring point;
2) Weekly methane concentration from each degasification monitoring point;
3) Weekly temperature values at the time, location, and conditions for which measurements are made;
4) Weekly pressure values at the time, location, and conditions for which measurements are made; and
5) Weekly moisture content at the time, location, and conditions for which measurements are made.
For methane liberated from degasification systems, companies are not required to monitor each well. Rather, Continuous Emissions Monitoring Systems (CEMS) may be used to monitor aggregate methane from more than one well, as long as methane from all wells is monitored and the methodology for estimating total emissions from all wells is documented.
Each underground coal mine where methane is destroyed or transported offsite for destruction must monitor the following parameters:
1) Continuous volumetric flow of gas at each destruction device or point of offsite transport for destruction;
2) Continuous methane concentrations of gas at each destruction device or point of offsite transport for destruction;
3) Continuous temperature values of gas at each destruction device or point of offsite transport for destruction;
4) Continuous pressure values of gas at each destruction device or point of offsite transport for destruction; and
5) Continuous moisture content of gas at each destruction device or point of offsite transport for destruction.
A 60-day public comment period on the proposed rules will begin when the notice is published in the federal register. For more information on the final rule to add reporting requirements for four source categories, see:
http://www.epa.gov/climatechange/emissions/remaining-source-categories.html, and for more information on the proposal on data confidentiality, see:
http://www.epa.gov/climatechange/emissions/CBI.html
This article was co-authored by Skipp Kropp and Matthew S. Tyree, Jackson Kelly PLLC. For more information on the authors see (Kropp) here and (Tyree) here.
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