GHG Reporting – Electronics Manufacturing (Subpart I) – Are you prepared?

Cotter, P.E., David
(Capaccio Environmental Engineering, Inc.)

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Electronics manufacturers that fall under the reporting requirements of the EPA’s mandatory greenhouse gas reporting regulation (40 CFR 98, Subpart I: Electronics Manufacturing) are required to file their first greenhouse gas (GHG) report to the EPA by September 28, 2012. This presentation will review what you need to know and do in order to be prepared to submit the report. The presentation will provide a brief overview of applicability, describe what processes and GHG’s need to be reported, how to use the facility’s GHG monitoring plan and best available monitoring methods (BAMMs) identified in the plan to calculate GHG emissions. The presentation will also provide a summary of the equations and data needed to perform the calculations required under Subpart I. The main focus of the presentation will be a review of the emission calculation equations. This will also include a discussion on the variables used in the equations, the use of default and measured factors, and the options for taking credit for abatement equipment use. Variables to be reviewed will include: cylinder heel factors, process-utilization and by-product formation rate factors, recipe-specific utilization and by-product formation rate factors, apportioning factors, and N2O utilization factors. For the apportioning factors, a discussion on the requirement to develop a facility-specific engineering model will be done. The abatement discussion will include the use of the default destruction and removal factor of 60%, as well as the procedures to follow if measured factors will be used. In addition to reporting of GHG emissions from electronic manufacturing activities, Subpart I also requires the reporting of carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O) emissions from stationary combustion equipment in accordance with the requirements of Subpart C (General Stationary Fuel Combustion Sources). An overview of the Subpart C requirement will be given. In conclusion, an overview of EPA’s electronic greenhouse gas reporting (e-GGRT) system will be done. This discussion will describe how to set up a designated representative to report on the e-GRRT system and the basic steps of opening a submittal, setting up a facility for reporting, entering data and submitting a report.

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