The continued regulation of greenhouse gases (GHGs) in all sectors of the economy will continue in the future. Expect more direct regulatory command and control regulations (e.g., NSPS OOOOa), voluntary initiatives and other methods (e.g., taxes) to further reduce GHGs.
Based on this, it is prudent for all companies to quantify and track their GHG emissions to prepare for future governmental impacts. This issue not only affects traditional industries that emit GHGs but also affects all sectors of the economy that consume products and services that generate GHGs.
Many companies elect to prepare a voluntary GHG emission inventory for their business operations. Since these are voluntary GHG emission inventories, the data can be submitted to a reporting agency or not reported and kept as an in-house document as a historical record or for planning purposes.
Reasons to do Prepare a Voluntary GHG Inventory
- A company-wide emissions inventory can assist in preparing and implementing a business sustainability plan.
- Identify potential targets for future reduction. For example, use VRUs to control storage tanks now venting to the atmosphere or using flares/combustors as a control device.
- Prepare for expansion of existing command and control regulations to reduce GHGs.
- Know potential liabilities regarding:
- GHG pollution permit or emission fees are enacted by the federal government or by states permitting agencies.
- Carbon taxes, if enacted.
- Quantify and track baseline GHG emissions and year-to-year emission reductions for carbon emissions trading systems.
- Submit GHG inventory data to investors, as needed.
- Submit data to a voluntary GHG reporting system.
- Demonstrate the company’s commitment to voluntary actions to reduce air pollution.
Elements of a Company-Wide Voluntary GHG Emission Inventory
The Greenhouse Gas Protocol’s “A Corporate Accounting and Reporting Standard,” the following are elements of a voluntary GHG emissions inventory.
- Scope 1: Direct GHG emissions from sources at facilities owned or controlled by a company. Scope 1 emissions are the typical GHG inventory required by EPA mandatory GHG reporting plus company owned vehicle emissions.
- Scope 2: Electricity indirect GHG emissions from the generation of purchased electricity consumed by the company. Scope 2 emissions are not included in EPA mandatory GHG emission reporting.
- Scope 3: Other indirect GHG emissions – optional reporting other indirect emissions such as product use, employee business travel, waste disposal, outsource activities, production of purchased materials, contractor owned vehicles. Scope 3 emissions are not included in EPA mandatory GHG emission reporting.
Methods for Calculating GHG Emissions
Typical calculation methods and emission factors used include those found in the following:
- USEPA’s methods in 40 CFR 98 Subparts C and W for oil and gas operations
- ICAO Carbon Emission Calculator for aircraft travel
- EPA Center for Corporate Climate Leadership GHG Emission Factors Hub
- Center for Corporate Climate Leadership Simplified GHG Emissions Calculator
- The Climate Registrycalculation tools
Voluntary Reporting Methods
- Energy Information Agency (EIA) Section 1605(b) program for Voluntary Reporting of Greenhouse Gases
- The Climate Registry voluntary and compliance GHG reporting programs
- CDP (formerly Carbon Disclosure Project)
GHG Trading Systems
- Regional Greenhouse Gas Initiative (RGGI)
- Western Climate Initiative, Inc. (WCI, Inc.)
- California Air Resources Board (CARB) Cap-and-Trade Program
The data from the emission inventory can help a company do reduce GHG emissions on a voluntary basis and prepare for future regulations. Voluntary emission reductions are typically only those reductions not required by regulation or the use of a more effective emission control device not required by regulation.
A company would need testing and monitoring records to demonstrate baseline GHG emissions and ongoing reductions. This is especially important for GHG trading systems.
Some ideas for voluntary reductions include:
- Establish standard design or work practices to reduce facility GHG emissions. For oil and gas operations this could include:
- Use VRUs to minimize storage tank methane emissions at existing and new facilities.
- Use VRUs instead of a flare to control storage tanks methane emissions
- Conduct periodic leak detection inspections and repair of fugitive leaks. This can include operator audio, visual and olfactory (AVO) inspections; optical camera imaging (OGI) or instrument inspection such as EPA Method 21.
- Use leak detection system such as UWSTM Hatch Sense available from HY-BON/EDI.
- Use stack tested vapor combustion units (VCU) that have destruction and removal efficiencies (DRE) higher than the typically allowed 98% DRE of candle stick flares.
- Use electric, solar powered and compressed air pneumatic pumps instead of natural gas pneumatic pumps.
- Optimize and minimize fuel used by internal combustion engines, heater, burners and boilers.
- Determine how can reduce Scope 2 and Scope 3 emissions which are not a direct result of the company’s activities. This can include reducing electricity use at offices, carpooling, and use of alternative products that have lower GHG emissions associated with use or production.
- The Greenhouse Gas Protocol, A Corporate Accounting and Reporting Standard by World Resources Institute. http://www.ghgprotocol.org/
- EPA Center for Corporate Climate Leadership: https://www.epa.gov/climateleadership
- EPA’s Voluntary Methane Programs for the Oil and Natural Gas Industry https://www.epa.gov/natural-gas-star-program
- ONE Future Coalition to reduce methane emissions from natural gas value chain. http://www.onefuture.us/
HY-BON/EDI’s Complete Solution
HY-BON/EDI’s engineered vapor recovery units (VRU), vapor recovery towers (VRT) and enclosed vapor combustion units (VCU) along with our IQR and Leak Detection and Repair (LDAR) services offer a complete package for operators to reduce their greenhouse gas emissions. Our testing and monitoring systems can set your baseline GHG emissions and track the reductions with real-time data.
If you have any questions on information presented above, please contact Jeff Voorhis at [email protected] .or