Questions and Clarifications on Greenhouse Gas Reporting Rules

I caught up with Emerson’s Tom O’Banion to get the latest on the U.S. Environmental Protection Agency (EPA)
Mandatory Greenhouse Gas (GHG) Emissions Reporting Rule. Tom is the Director of the chemical industries in the Micro Motion Coriolis Flow & Density Measurement business.

Tom shared some issue raised and discussed from the Mandatory GHG Reporting Rule workshop at the National Petrochemical & Refiners Association (NPRA) meeting in Houston earlier this year.

Tom noted that refiners had a great number of questions about the rules and the actions they needed to take. These GHG rules became effective at the end of 2009. On the rule’s milestones, the EPA states:

On September 22, 2009, the rule was signed by the Administrator and was published in the Federal Register on October 30, 2009. The final rule goes into effect December 29, 2009. As discussed below, the rule requires reporters to begin monitoring on January 1, 2010. The first reports will be due on March 31, 2011.

Approximately 10,000 U.S. sites are affected–representing an enormous safety, health and environmental set of considerations with which plants and mills must contend. During the workshop, the EPA clarified a question about the use of mass flow measurement devices for liquid fuel flow measurement, responding:

Fuel flow meters that measure mass flow rates may be used for liquid fuels, if the fuel density is used to convert the readings to volumetric flow rates.

Perhaps the most discussion centered on the use of mass flow measurement beyond liquids. Currently, the EPA restricts mass flow measurements to liquids. The American Petroleum Institute (API) members wanted a clarification from the EPA on the suitability for mass meters in measuring flows of gaseous streams. The API believes gaseous streams mass flow measurement should be permitted and would like to see this changed. Measurement of gases right now needs to be performed with flow meters measuring differential pressure (DP), total pressure, and temperature to apply pressure-temperature compensation to the measured flow rates.

The EPA regulations are written to leverage “consensus standards” such as API, AGA, ASME, etc. In the various sections of 40 CFR part 98, all of the Coriolis standards are referenced (AGA-11 / API MPMS Ch 14.9, ASME PTC, etc.) There is an API Task Group forming to write a new API document that will describe flow technologies for use in GHG fuel gas applications. It will be all the major technologies such as DP/orifice, vortex, turbine, Coriolis, thermal, etc. The request for this task group has been approved and the membership is being formed.

On a question about meter calibration error exceeding the rule’s 5% performance specification, the EPA indicated that if the error exceeds 5% to use the best available monitoring method (BAMM) and an extension could be granted for the remainder of 2010 if an extension was requested by April 1. The meter would need to be modified or replaced before the extension expired to comply with the rules.

Tom shared that Meter Verification is of great interest to refiners and other process manufacturers impacted by these regulations. Meter Verification is allowed under the EPA approach of following “manufacturer recommended practice” and is both a labor savings as well as a safety benefit to not have to break the line–even orifice measurement must be physically inspected every 3 years.

One only has to look at the Frequently Asked Questions page to note the complexity and issues refiners’ and other process manufacturers’ face with compliance. Tom suggests visiting the GHG Compliance area of the Micro Motion Community to connect with others to ask and answer questions about the measurement and collection of the information required for GHG reporting.

There is also a Greenhouse Gas Compliance Readiness section on the Micro Motion website that highlights the issues and solutions to meet these regulations.

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