e-GGRT Inputs Verifier Tool – Helpful or Headache?
Posted: March 20th, 2015Author: All4 Staff
This year, U.S. EPA rolled out their new additions to the e-GGRT reporting system for Annual Greenhouse Gas (GHG) Reports for those submitting under 40 CFR Part 98. One of the biggest updates was the addition of the Inputs Verifier Tool (IVT) for a handful (22 to be exact) of Part 98 subparts. As with any new addition to a process, there can be some bumps to work through during the first time. I’d like to talk about my experience with IVT this year and some of the things I ran into along the way.
The main purpose of IVT is to give facilities greater confidentiality when reporting. Essentially, IVT allows you to enter in certain key inputs to equations that you used to calculate your GHG emissions (i.e., emission factors, throughputs, heating values, etc.), then e-GGRT verifies these inputs and calculates an emission rate based on your inputs. Ideally, the value e-GGRT calculates should match your own, but if it doesn’t then you do have the option to over-write e-GGRT. The difference here is that those input values will not be saved or submitted to U.S. EPA. The only piece submitted will be the final calculated emission value. One thing that is important to remember when using IVT is to save and export your input data every time you log off of e-GGRT. Since e-GGRT is not allowed to save your input data for you, you must upload your inputs data from the previous session each time you log on to the system. The e-GGRT system will only accept the most recent exported file. If you don’t have that file available, you will be forced to re-enter all of your inputs. It is also important to remember to save this file in an easily accessible location once you are finished because as a requirement, it must be maintained as a record for five (5) years.
Another caveat that comes along with IVT is for facilities reporting under Subpart C – General Stationary Fuel Combustion Sources. Subpart C is different because the reporter has the option to use IVT or to actually report their inputs. Facilities who choose to report their inputs must also back-report those inputs for years 2010-2013. When entering the e-GGRT reporting page for Subpart C, you will be prompted to answer two (2) questions to determine if you are eligible to use IVT:
- The source contains at least one combustion unit that is connected to a fuel-fired electric generator owned or operated by an entity that is subject to regulation of customer billing rates by the public utility commission; and
- The source is located at a facility for which the sum of the nameplate capacities for all such electric generators is greater than or equal to 1 MW electrical output.
If the answers to both of these questions are “Yes”, then the facility cannot use IVT and must back-report.
Now you might be asking yourself, “Why do I have to answer these IVT questions if I operate a source equipped with a continuous emission monitoring system (CEMS) that will not have any equation inputs?” It may seem counterintuitive but you still have to answer the IVT questions. Since the CEMS will already be listed with the source (CEMS option is chosen when adding a source to the report), e-GGRT will automatically send you to the correct reporting sheet that does not include equation input fields once you answer the preliminary questions.
Overall, I think IVT is a helpful addition to e-GGRT. It can be a little bit tricky to get used to at first but once you work past the initial kinks it can be a very beneficial tool for facilities and reporters when completing Annual GHG Reports.
As a friendly reminder, your Annual GHG Reports for reporting year 2014 are due by March 31, 2015.