John Schneider
Air Quality Specialist
1252 Commerce Drive
Laramie, WY  82070
970-834-1853
jschneider@trihydro.com


Trihydro provides environmental, engineering, energy, transportation, and water resources services to public and private clients. From its initial start-up as a two-man firm in 1984, Trihydro has grown into a successful, dynamic firm of over 270 employees with 13 offices nationwide.

 

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May 2009

Summary of Greenhouse Gas Reporting Requirements for Ethanol Production

ALERT: Your facility may be one of the 13,000 facilities in the US potentially impacted by EPA’s proposed greenhouse gas emissions regulations.

On March 10, 2009, the Environmental Protection Agency (EPA) proposed rule 40 CFR 98, which would require mandatory reporting of greenhouse gas (GHG) emissions from large sources in the United States. The proposed rule was published in the Federal Register on April 10, 2009, and the public comment period is open until June 9, 2009. The rule would require collecting and reporting comprehensive emissions data from certain facilities, suppliers of fossil fuels and industrial GHGs, manufacturers of vehicles and engines, and some facilities that emit 25,000 metric tons per year or more of GHGs. The purpose of this memorandum is to provide a brief overview of the proposed rule relative to this industrial sector.

General Provisions - 40 CFR Part 98
If enacted, the rule would require reporting of annual emissions of carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), sulfur hexafluoride (SF6), hydrofluorocarbons (HFCs), perfluorochemicals (PFCs), and other fluorinated gases (e.g., nitrogen trifluoride, hydrofluorinated ethers [HFEs]). The rule would apply to certain facilities that emit GHGs and to suppliers of fossil fuels.

Background - Ethanol Production
Currently, there are 169 operating ethanol production facilities in the United States and 15 additional facilities under construction. If enacted, the proposed rule would require owners or operators of ethanol production processes that emit greater than 25,000 metric tons of GHGs, expressed as CO2 equivalents (CO2e), from stationary combustion, on-site landfills, on-site wastewater treatment, and other source categories to report these emissions starting 2011 for the 2010 calendar year.

Who Would Report?
A facility that meets the source category criteria outlined in 40 CFR 98.2(a)(1) or (2) would be required to report emissions from all source categories at the facility for which calculation methodologies are provided in any subpart of the proposed rule. Ethanol production is a source category outlined in 40 CFR 98.2(a)(2), which would require certain facilities to report if they emit greater than 25,000 metric tons of CO2e.

Under the proposed rule, facilities that do not contain any source categories in 40 CFR 98.2(a)(1) or (2) but still exceed the 25,000 metric tons of CO2e annual threshold from stationary combustion (in any calendar year beginning in 2010) would be required to report emissions from stationary combustion sources only. If the aggregate maximum rated heat input capacity of all stationary combustion equipment is less than 30 million Btu/hr, then the facility is presumed to emit less than 25,000 metric tons of CO2e annually, and the facility would not have to calculate or report emissions.

The proposed rule also includes requirements for suppliers of fossil fuels, such as natural gas, coal, coal-based liquid fuels, natural gas liquids, and other petroleum products, and suppliers of industrial GHGs such as CO2, NO2, and fluorinated hydrocarbons.

Subpart J – Ethanol Production
The proposed rule defines ethanol production as:

“…a facility that produces ethanol from the fermentation of sugar, starch, grain, or biomass feedstocks; or produces ethanol synthetically from ethylene or hydrogen and carbon monoxide.”

In a typical ethanol facility, approximately 1/3 of GHG emissions originate from fossil fuel combustion and the remaining 2/3 from fermentation.

Reporting of CO2, N20, and CH4 emissions from on-site stationary combustion would follow the calculation procedures, monitoring and quality assurance/quality control (QA/QC) methods, missing data requirements, reporting requirements, and recordkeeping requirements listed in Subpart C. Four calculation procedures are provided for stationary combustion sources. To determine which calculation procedure would be required, please refer to Trihydro’s General Stationary Fuel Combustion Sources Tiered Data Monitoring Flow Diagram for CO2 Emissions (Attachment A). Additionally, CH4 emissions from on-site landfills would be reported according to the requirements of Subpart HH and CH4 emissions from on-site wastewater treatment would be reported according to Subpart II.

GHGs from dry mill ethanol facilities come from two primary sources: fermentation and fossil fuel combustion. Fossil fuels are combusted for activities such as drying of distiller grains and heating of process water. The dry mill production process consists of grinding corn into flour before processing. This process creates two primary by-products: distiller grain soluble (DGS), which can be sold as cattle feed, and CO2, which can be used for food processing and bottling.

Monitoring of Emissions
The proposed rule considers three monitoring methods to estimate GHG emissions. These methods include:

  1. Use of engineering calculations and/or default parameters
  2. Monitoring of process parameters (such as fuel consumption quantities and carbon content)
  3. Direct emission measurements using continuous emissions monitoring system (CEMS) for all emission sources

Under the proposed rule, if a facility is required to use an existing CEMS to meet the requirements outlined in Part 98, Subpart C, it would use the CEMS data to estimate CO2 emissions from the source. For facilities that do not have CEMS that meet the requirements as outlined by Subpart C, the proposed method for emission calculations is monitoring of process parameters.

Recordkeeping / Reporting
Under the proposed rule, an annual GHG emissions report would be submitted by March 31 of each calendar year for emissions in the previous calendar year. Existing facilities that commenced operation prior to January 1, 2010 would report emissions for calendar year 2010 and each subsequent calendar year. New facilities that commence operation on or after January 1, 2010, would report emissions for the first calendar year which the facility operates starting with the first operating month and ending on December 31. Under the proposed rule approximately 86 percent of existing ethanol production facilities would be required to submit the first annual GHG emissions report by March 31, 2011, for the 2010 calendar year.

Each annual GHG report would be certified by the facility to be true, accurate, and complete. EPA would have the jurisdiction to perform selective random audits of all facilities in respective EPA regions. Furthermore, the proposed rule would require a QA/QC document and demonstrated emission source calculation procedures. Facility record maintenance would be required for 5 years.