This summer, EPA proposed several updates and amendments to the GHG Mandatory Reporting Rule (40 CFR Part 98). This activity is consistent with EPA’s stated intention to issue amendments and re-propose subparts (i.e., those subparts that were initially reserved upon finalization of the rule last October) by the end of 2010. EPA’s published revisions in the Federal Register on June 15, 2010, and these revisions in general, do not change the overall requirements of the rule. Rather, these amendments were intended to improve clarity and ensure consistency across the calculation, monitoring, and data reporting requirements. EPA next issued updates on June 28, 2010 where additional subparts were finalized, including Subpart T – Magnesium Production, Subpart FF – Under- ground Coal Mine, Subpart II – Industrial Wastewater Treatment, and Subpart TT – Industrial Waste Landfills. EPA published additional amendments in the Federal Register on August 11, 2010, which consist of clarifications and technical changes to the final rule, including extensive updates to Subpart C for Stationary Combustion Sources. These recent amendments are meant to complement, not override, the first round of amendments published on June 15, 2010. A summary of all these amendments is available at trinityconsultants.com/MRR.
The Subpart C amendments for Stationary Combustion Sources affect most facilities that must comply with this rule. The table to the right summarizes the Subpart C amendments that were published in the Federal Register on August 11, 2010.
Assuming these changes to the Mandatory GHG Reporting Rule are finalized in 2010 as expected, all of these amendments will apply to data reported to EPA in March 2011. Understanding these changes may affect your monitoring and recordkeeping activities or emission calculation approaches immediately upon finalization of the proposed rules. Therefore, it is prudent to evaluate whether these corrections affect any of your determinations or methods for complying with the rule, as soon as the proposed rules are finalized.