July 2010 – Four New GHG Sources Required to Report Emissions After Final Rule Signed

EPA Administrator, Lisa Jackson, signed the final rule for Mandatory Reporting of Greenhouse Gas (GHG) emissions on June 28, 2010, finalizing the April 2009 proposal for the GHG reporting program.

How Will My Company Be Affected?

The identified GHG sources will be required to begin collecting emissions data on January 1, 2011 and submit the first annual reports to the EPA on March 31, 2012.

Companies should determine if they are subject to the rule and, if so, begin to prepare for these reporting requirements now.  First, identify if your operations are subject to the source categories below, and then determine if they have emitted more than 25,000 metric tons of carbon dioxide equivalent (CO2e) per year.

Sources Categories

Changes will require reporting from four new sources with the following thresholds for reporting GHGs:

1. Magnesium Production

  • Facilities that emit 25,000 metric tons of CO2e or more in combined emissions from their sources annually.

2. Underground Coal Mines

  • No emissions threshold for reporting.
  • Must report if subject to quarterly or more frequent sampling of mine ventilation systems by MSHA.

3. Industrial Wastewater Treatment

Facilities that perform:

  • pulp and paper manufacturing
  • food processing (fruits, vegetables, meat and poultry processing only)
  • ethanol production
  • petroleum refining
  • use anaerobic processes to treat industrial wastewater and wastewater treatment sludge

AND have aggregate emissions from all source categories covered by the rule in the amount of 25,000 metric tons of CO2e or more are required to report their industrial wastewater treatment emissions along with any other emissions from covered source categories.

4. Industrial Waste Landfills

  • Landfills that accepted waste on or after January 1, 1980, accepts organic waste, is located at a facility whose total landfill design capacity is greater than or equal to 300,000 metric tons, and is located at a facility whose aggregate emissions from all source categories covered by the rule is greater than or equal to 25,000 metric tons of CO2e.

For a complete list of sources that are required to report emissions, please visit the EPA’s resource table http://www.epa.gov/climatechange/emissions/subpart.html.

Sources not included as distinct subparts in 40 CFR 98:*

  • Ethanol Production
  • Food Processing
  • Suppliers of Coal

*May still be required to report under other subparts if meet reporting threshold of 25,000 tons CO2e.


EHS Support reviews GHG emissions for companies to determine if their facilities are subject to reporting under the GHG Mandatory Reporting Rule.  The product of our high-level review includes:

  • Identification of applicable source categories
  • Documentation of the rule’s background based on which source categories apply
  • Calculation of emissions using methods provided in the GHG Mandatory Reporting Rule, if applicable
  • A final conclusion regarding applicability of the rule, and
  • A detailed description of the process we used to reach our conclusion.

If reporting is required, you can use can use the information as the basis for a GHG compliance plan at your facility. If reporting is not required, you will be given the documentation from the comprehensive review to maintain on file.

If you would like more information about how we can conduct a high-level review of potential GHG emissions and the applicability of the GHG Mandatory Reporting Rule to your company, particularly with recent amendment to the Final Rule, please contact Jessica Tierney at 412-779-1094 andjessica.tierney@ehs-support.com or Amy Bauer at 251-533-5949 and amy.bauer@ehs-support.com




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