The GHG Monitoring Plan Due Date is Approaching. Will You Be Ready?
Posted: February 4th, 2010Author: All4 Staff
U.S. EPA’s Greenhouse Gas Mandatory Reporting Rule (GHG MMR) codified at 40 CFR Part 98 requires that facilities subject to the rule have a complete written GHG Monitoring Plan by April 1, 2010. At a minimum, a GHG Monitoring Plan must identify:
- The methods used to collect GHG emissions information and supporting data,
- The personnel responsible for collecting the data, and
- The quality assurance, maintenance, and repair methods for all measurement devices used to collect data.
Facilities must maintain their written GHG Monitoring Plan onsite in an electronic or hard-copy format. If requested by U.S. EPA, a facility’s GHG Monitoring Plan must be made available expeditiously for inspection and review.
The GHG MRR is a new rule, currently made up of 30 different subparts that apply to a wide variety of facilities. Developing a GHG Monitoring Plan is the first step of implementation for facilities that are affected by this new rule. This first step involves a thorough analysis of the facility-specific characteristics and operation of combustion units and process units as they relate to the requirements of the GHG MRR. The GHG Monitoring Plan must present how all of the required detailed information about fuels and process parameters is generated, managed, and confirmed.
As with anything so detailed and new, as facilities venture into the GHG MRR for the first time to develop their GHG Monitoring Plans, questions and confusion will ensue. As voluminous as it is, the GHG MRR does not address with certainty how its requirements apply to all of the different ways facilities operate their equipment. In anticipation of, and in response to, questions in this regard from the regulated community, U.S. EPA has endeavored to make available a great deal of support information. Answers to frequently asked questions (FAQs), information sheets, checklists, form templates, technical support documents, and numerous documents explaining responses to comments on the rule as it was proposed are available on U.S. EPA’s website. Unfortunately, the sheer volume of material made available can make it that much harder to find the specific information that individual facilities need to answer their questions. This is all the more reason not to wait until the last minute to develop a required GHG Monitoring Plan.