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American Foundry SocietyAmerican Foundry Society--22nd EHS Conference22nd EHS Conference
August 23August 23--25, 2010, Nashville, TN25, 2010, Nashville, TN
Greenhouse Gas (GHG)Reporting Rule
Jim Schifo, PE, VP
[email protected]
KERAMIDA Inc.
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American Foundry SocietyAmerican Foundry Society--22nd EHS Conference22nd EHS Conference
August 23August 23--25, 2010, Nashville, TN25, 2010, Nashville, TN
Discussion Items
�Climate Change –Background
�Greenhouse Gas (GHG) Reporting Requirements –EPA
�AFS Recommendations
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American Foundry SocietyAmerican Foundry Society--22nd EHS Conference22nd EHS Conference
August 23August 23--25, 2010, Nashville, TN25, 2010, Nashville, TN
Remember
Kyoto GHGs & Global Warming Potentials
GWP – Effect compared to Carbon Dioxide
� CO2 1
� CH4 23
� N2O 296
� HFCs Varies, most 1,000s
� PFCs Varies, most 1,000
� SF6 22,200 Intergovernmental Panel on Climate Change - Third Assessment Report
Carbon Dioxide Equivalents (CO2e) are calculated using the above ratios.
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American Foundry SocietyAmerican Foundry Society--22nd EHS Conference22nd EHS Conference
August 23August 23--25, 2010, Nashville, TN25, 2010, Nashville, TN
Greenhouse Gas Reporting Rule –
EPA � GHG Reporting Program Mandated by Congress December 2007
� Final Rule Signed September 22, 2009
� Published October 30, 2009 Federal Register
� Effective December 28, 2009
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American Foundry SocietyAmerican Foundry Society--22nd EHS Conference22nd EHS Conference
August 23August 23--25, 2010, Nashville, TN25, 2010, Nashville, TN
GHG Reporting Rule
� EPA Chose to Capture 25,000 Metric Tons CO2e Emitters
� EPA Estimates Rule Will Affect 13,000 Sources,
� GHG Reporting Rule is estimated to capture 85-90% of GHG Emissions
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American Foundry SocietyAmerican Foundry Society--22nd EHS Conference22nd EHS Conference
August 23August 23--25, 2010, Nashville, TN25, 2010, Nashville, TN
GHG Reporting Rule
Upstream Production
� Emissions From Products That Reporters Supply� Engines (except Light Duty Vehicles)
� Coal-to-Liquids Suppliers
� Petroleum Product Suppliers
� Natural Gas and Natural Gas Liquids Suppliers
� Fluorinated GHG and N2O Suppliers
� CO2 Suppliers
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American Foundry SocietyAmerican Foundry Society--22nd EHS Conference22nd EHS Conference
August 23August 23--25, 2010, Nashville, TN25, 2010, Nashville, TN
GHG Reporting Rule
Downstream Sources
� 17 Categories of Sources Regardless (All-in)
� Electric Generation that report CO2 under ARP
� Aluminum Production
� HCFC -22 Production
� HFC-23 Destruction Processes (not co-located with
HCFC-22 Production & that destroys more than 2.14
metric tons HCF-23
� -----------
7
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American Foundry SocietyAmerican Foundry Society--22nd EHS Conference22nd EHS Conference
August 23August 23--25, 2010, Nashville, TN25, 2010, Nashville, TN
GHG Reporting Rule
Downstream Sources (cont.)
� 7 Categories of Sources That Emit 25,000 MT CO2e
(Threshold Categories)
� Ferroalloy Production
� Glass Production
� Hydrogen Production
� Iron & Steel Production
� Lead Production
� Pulp & Paper Production
� Zinc Production
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American Foundry SocietyAmerican Foundry Society--22nd EHS Conference22nd EHS Conference
August 23August 23--25, 2010, Nashville, TN25, 2010, Nashville, TN
GHG Reporting RuleDownstream Sources (cont.)
40 CFR 98.30 General Stationary Fuel Combustion
� Stationary Fuel Combustion with total heat capacity
>30 MMBtu/hr
� 25,000 metric tons of CO2e or more per year
� Certain source categories have deferred
requirements.
9
Metalcasting Facilities Fit into the Stationary
Combustion Category for GHG Reporting
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American Foundry SocietyAmerican Foundry Society--22nd EHS Conference22nd EHS Conference
August 23August 23--25, 2010, Nashville, TN25, 2010, Nashville, TN
GHG Reporting Rule
40 CFR 98.30 General Stationary Fuel Combustion
� Not one of the 36 previously listed
� Need only report CO2, CH4, and N2O from fuel combustion
� Need not report other sources of GHG, e.g. HFC
� Emergency and Portable Equipment Exempt
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American Foundry SocietyAmerican Foundry Society--22nd EHS Conference22nd EHS Conference
August 23August 23--25, 2010, Nashville, TN25, 2010, Nashville, TN
40 CFR 98.30 General Stationary Fuel Combustion
� Includes a Four Tier Structure of emission calculations.
� Metalcasting facilities will likely use the Tier 1 approach
involving the use of emission factors from Table C-1.
(But could use Tier 2 with HHV Determinations)
� Emissions can be combined in some cases for
reporting purposes. (Natural Gas emissions based on
main facility meter representing all natural gas fired
sources.)
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American Foundry SocietyAmerican Foundry Society--22nd EHS Conference22nd EHS Conference
August 23August 23--25, 2010, Nashville, TN25, 2010, Nashville, TN
GHG Reporting Rule – General
Requirements
12
� Report 2010 Emissions by March 31, 2011
� Designated Representative, and Alternate, submits Certificate of Representation to EPA. (January 30, 2010 – 60 days prior to Reporting Date)
� CO2 From Biogenic Fuels Excluded from Applicability (CH4 and N2O Count), But Reported Separately When Applicable
� Annual Reporting
� Once In, Always In, Now With Escape Hatch
� Self Certification
� EPA is Verifier
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American Foundry SocietyAmerican Foundry Society--22nd EHS Conference22nd EHS Conference
August 23August 23--25, 2010, Nashville, TN25, 2010, Nashville, TN
GHG Reporting Rule – Monitoring
Requirements
� GHG inventory requirements went into affect on
January 1, 2010 and Monitoring Requirements
also needed to be in place and documented.
� Temporary “Best Practice” monitoring plans
allowed to be used until March 31, 2010. (Until
required monitoring equipment is installed.)
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American Foundry SocietyAmerican Foundry Society--22nd EHS Conference22nd EHS Conference
August 23August 23--25, 2010, Nashville, TN25, 2010, Nashville, TN
Additional Sources Proposed
April 12, 2010 Federal Register
� Oil and Gas Industry
� Carbon Dioxide Sequestration Sites
� Numerous Fluorinated GHG
Categories
� Corporate Parent, NAICS Codes,
Cogeneration
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American Foundry SocietyAmerican Foundry Society--22nd EHS Conference22nd EHS Conference
August 23August 23--25, 2010, Nashville, TN25, 2010, Nashville, TN
Numerous Technical Corrections
Signed May 27, 2010
� Affects Most Subparts, But Not Stationary Fuel
Combustion
� Corrections to cross references,
� Additional information to better understand
compliance obligations,
� Amendments to equations to better reflect actual
operating conditions,
� Corrections to better match data reporting to
emissions calculations
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American Foundry SocietyAmerican Foundry Society--22nd EHS Conference22nd EHS Conference
August 23August 23--25, 2010, Nashville, TN25, 2010, Nashville, TN
Additional Source Categories Re-proposed
Signed May 27, 2010
� Electronics Manufacturing
� Fluorinated Gas Production
� Importers/Exporters Pre-charge GHG
and Foam
� SF6 and Perfluorocarbons from
Electrical Equipment Manufacturing
or Refurbishment
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American Foundry SocietyAmerican Foundry Society--22nd EHS Conference22nd EHS Conference
August 23August 23--25, 2010, Nashville, TN25, 2010, Nashville, TN
Additional Source Categories Finalized
Signed June 28, 2010
� Magnesium Production
� Underground Coal Mines
� Industrial Waste Water Treatment
� Industrial Waste Landfills
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American Foundry SocietyAmerican Foundry Society--22nd EHS Conference22nd EHS Conference
August 23August 23--25, 2010, Nashville, TN25, 2010, Nashville, TN
Treatment of Confidential Business
Information Proposal Signed June 28, 2010
� §114(c) All information submitted to EPA shall be
available to the public
� Except trade Secrets and CBI, “likely to cause
substantial harm to business’s competitive position”
� Except “emissions data” cannot be considered CBI
� 40 CFR2, Subpart B EPA generally makes case-by-
case decisions
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American Foundry SocietyAmerican Foundry Society--22nd EHS Conference22nd EHS Conference
August 23August 23--25, 2010, Nashville, TN25, 2010, Nashville, TN
Treatment of Confidential Business
Information Proposal Signed June 28, 2010
Emissions Data
� Information necessary to determine the amount and
characteristics of any pollutant emitted by the source
� Information necessary to determine the amount and
characteristics of any pollutant authorized to be
emitted by a source
� General description of the location and nature of a
source
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American Foundry SocietyAmerican Foundry Society--22nd EHS Conference22nd EHS Conference
August 23August 23--25, 2010, Nashville, TN25, 2010, Nashville, TN
So what do I do now?
� If you know you are above 25,000 metric
tons of CO2e then you should be well along
with the program.
� If you don’t know, then figure it out. Use the
GHG Emissions Calculator on AFS Web
Site to Estimate your likely GHG emissions
for 2010.
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American Foundry SocietyAmerican Foundry Society--22nd EHS Conference22nd EHS Conference
August 23August 23--25, 2010, Nashville, TN25, 2010, Nashville, TN
GHG Reporting Rule – Monitoring
Requirements – What to do NOW? If your in:
� Document your Monitoring Plan.
� Monthly accounting of fuel use.
� Monitoring method
� Natural Gas Meter readings
� Coke usage
� Liquid Fuels
� Listing of Description, ID, Fuel Rating of Emission Units
� Calibration Procedures for Measurement Devices
� Coke Scales -----
� Maintain Monitoring Plan on Site
� FOLLOW THE PLAN
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American Foundry SocietyAmerican Foundry Society--22nd EHS Conference22nd EHS Conference
August 23August 23--25, 2010, Nashville, TN25, 2010, Nashville, TN
What Size Metalcasting Facility will be
reporting?
� Al Diecasting Facility will be reporting at
about 25,500 tons of casting shipped per
year.
� Iron Greensand Foundry with Cupola
Melting will report at about 43,000 tons
ship.
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American Foundry SocietyAmerican Foundry Society--22nd EHS Conference22nd EHS Conference
August 23August 23--25, 2010, Nashville, TN25, 2010, Nashville, TN
Questions?
Greenhouse Gas (GHG)
Reporting Rule