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GHG Mandatory Reporting Rule – Implications for PSD Review for GHG September 2012

GHG Mandatory Reporting Rule – Implications for PSD Review for GHG September 2012. Ramesh Narasimhan ERM. Mandatory GHG Reporting Challenges. Determining Facility Boundaries Contractor Sources and/or Data Mandatory Measurements for Input Data Required Quality Assurance for Measurements

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GHG Mandatory Reporting Rule – Implications for PSD Review for GHG September 2012

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  1. GHG Mandatory Reporting Rule – Implications for PSD Review for GHGSeptember 2012 Ramesh Narasimhan ERM

  2. Mandatory GHG Reporting Challenges Determining Facility Boundaries Contractor Sources and/or Data Mandatory Measurements for Input Data Required Quality Assurance for Measurements Adapting to Rule Changes and EPA Guidance

  3. Lessons Learned for Flow Meter Data • Applicable to Subparts C, P, Y, etc. • Compensate Gas Flow from Actual to Standard Conditions per §98.3(i) • Local vs. Remote Location • Pressure and Temperature Transmitters • Existing Corrections may not be Local • Identify Remote Locations • Perform Local Measurements • Develop Statistical Correlations

  4. Fuel Gas Tier 3 - Data Flow Map

  5. Fuel Flow Compensation

  6. PSD Implications of GHG MRR – Major Source Determination E.g. Facility NG Transmission Compressor Station IN Current Air Permit PSD Major Source Determination for GHG IN GHG MRR If >25k mt CO2e Out GHG MRR • Gas Turbine • Gas Turbine Condensate Tank Emergency Generator OUT Current Air Permit Compressor Compressor NG Pneumatics Subject to Subpart C and Subpart W Blowdowns

  7. PSD Implications of GHG MRR PSD Major Source Determination (i.e. PTE >100k tpy CO2e) Convert actual emissions to potential Emissions Can federally enforceable conditions or synthetic limitations be applied to stay minor? Tailoring Rule guidance on determining PTE Input Data for Historical GHG Baseline Company records versus measured data Address changes in measurement accuracy Compliance Demonstration of GHG BACT Limits GHG MRR Monitoring and Calculation Methods

  8. Accuracy from Bottom-up Report Emissions to Agency and Use for PSD Evaluation GHG Emissions Calculations Missing Data Substitution Efficiency Analyze and Aggregate Data Implement Data Management Program Raw Data Collection Company Records, Instruments, Measurements Apply Rule Interpretations Implement QA/QC Program and Training Manage Compliance Risk Accuracy

  9. ERM Contact Information Ramesh Narasimhan Ramesh.narasimhan@erm.com 504.846.9215 Air and Climate Change Consultants +200 in North America

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