Emission Measurement, Reporting, and Verification for Energy and

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					                       Emission Measurement,
                    Reporting, and Verification for
                      Energy and Carbon Data
                            Management


                     China Conference on Greenhouse Gas Emissions
                    Data Management in Energy Intensive Industries and
                                   the Power Sector


Jeremy Schreifels   ICAP – Plenary 1                     2009 October
    US EPA
   CO2 measurement, reporting, and verification
     by the US power sector (1994 – present)
MONITORING
  The [EPA Administrator] shall promulgate regulations [by 1992 May]
  to require that all affected sources subject to [the Acid Rain
  Program] shall also monitor carbon dioxide emissions…

PUBLIC AVAILABILITY OF CARBON DIOXIDE INFORMATION
  For each unit required to monitor and provide carbon dioxide
  data…the Administrator shall compute the unit’s aggregate annual
  total carbon dioxide emissions, incorporate such data into a
  computer data base, and make such aggregate annual data
  available to the public.

                     Section 821 of the Clean Air Act Amendments of 1990
               Reporting requirements
• Hourly data
   – SO2, NOX, CO2 emissions
   –   Heat input
   –   Operating load (MWh or 1,000 pounds steam)
   –   Oil and gas fuel flow
   –   Moisture data
• Quality assurance test data
• Monitoring system re-certification and maintenance
  event data
• Unit fuel type data
• Control equipment data
• Facility information (industry codes, boiler types)
• Monitoring and quality assurance plans
               Monitoring process
• EPA specifies measurement methodologies and QA/QC
  requirements
• Sources develop monitoring plan and quality assurance
  plan consistent with selected measurement methodology
• Sources install, certify, & maintain measurement
  equipment
• Sources perform QA/QC testing for measurement
  equipment at prescribed intervals
• Sources report emission and activity data to EPA
• EPA audits and verifies all emission data
• EPA publishes emission data
 Principles of CO2 measurement, reporting,
               and verification
• Measurement methods should create incentives for greater
  accuracy , precision, and completeness
    – Missing or invalid data has consequences
    – Improved performance has benefits
• Different measurement methods may be necessary for different
  source types (e.g., allowing simplified measurement approaches for
  low emitters) when appropriate
    – Uncertainty is addressed through the use of conservative estimation
      methods to ensure that emissions are not underreported
• Reporting requirements should be standardized to facilitate
  consistency, comparability, and automation
• A complete record of total emissions from each power plant
• Frequent and timely emission reporting to facilitate compliance
  assessment
Approved CO2 measurement methodologies
• Continuous emission monitoring systems (CEMS)
   – Direct measurement of SO2, NOX, and CO2 emissions in stack
   – Measurement of flue gas flow in stack
• Fuel flow monitoring
   – Fuel flow meter and fuel analysis for the sulfur, carbon, and heat
     content of the fuel
• Low Mass Emission Units (LME)
   – Use default emission factor and operating conditions


       Methods with less accuracy or greater uncertainty use
     conservative methods that do not underestimate emissions
CO2 Measurement Methods
        All Units




CO2 Measurement Methods
     All Emissions
                          CO2 monitoring method by fuel (2008)
                 Emission reporting timeline
              Q1 emissions Q2 emissions Q3 emissions Q4 emissions
                reporting    reporting    reporting    reporting
                 deadline     deadline     deadline     deadline



  J F M A M J                         J A S O N D J F M

                                                              Allowance
        Every hour of emissions data quality                    transfer
       assured, audited, and posted to EPA’s                  deadline /
          website; Feedback provided to                      Compliance
                     reporters                               assessment
                                                               (true-up)
Throughout the year: EPA collects over 40 million data records, processes special petitions
and data resubmissions, analyzes data, provides feedback and technical assistance for
emission measurement and reporting, and works with states to jointly conduct on-site audits
at selected facilities
               Verification program
• A systematic, thorough, and uniformly applied
  approach to ensure high-quality, accurate,
  timely, transparent, and complete data
  –   Equipment performance standards
  –   Quality assurance tests
  –   Documented procedures and methodologies
  –   Comprehensive electronic auditing
  –   Independent field audits (random and targeted)
  –   Mechanism to solve unique monitoring and reporting
      issues
 Electronic audit and analysis of emission reports
• Compare monitoring plans, QA test history, and
  emissions data to rule requirements
• Look for mathematical and methodological errors
• Look for statistical anomalies
                     14.50
                     14.00
                     13.50
                     13.00
 CO2 Concentration




                     12.50
                     12.00
                     11.50
                                                                                                                            Out of control
                     11.00
                     10.50
                                                                                                                            measurements
                     10.00
                      9.50
                                         Daily Ave CO2            Audit UCL                   Audit LCL
                      9.00
                             6/12/2006




                                           8/1/2006




                                                      9/20/2006




                                                                     11/9/2006




                                                                                 12/29/2006




                                                                                                     2/17/2007




                                                                                                                 4/8/2007




                                                                                                                            5/28/2007




                                                                                                                                        7/17/2007




                                                                                                                                                    9/5/2007




                                                                                                                                                               10/25/2007
 Electronic audit and analysis of emission reports

• Compare monitoring plans, QA test history, and
  emissions data to rule requirements
• Look for mathematical and methodological errors
• Look for statistical anomalies
                     14.50
                     14.00
                     13.50
                     13.00
 CO2 Concentration




                     12.50
                     12.00
                     11.50
                                                                                                                            Out of control
                     11.00
                     10.50
                                                                                                                            measurements
                     10.00
                      9.50
                                         Daily Ave CO2            Audit UCL                   Audit LCL
                      9.00
                             6/12/2006




                                           8/1/2006




                                                      9/20/2006




                                                                     11/9/2006




                                                                                 12/29/2006




                                                                                                     2/17/2007




                                                                                                                 4/8/2007




                                                                                                                            5/28/2007




                                                                                                                                        7/17/2007




                                                                                                                                                    9/5/2007




                                                                                                                                                               10/25/2007
Data analysis
       Display of information:
SO2 and sulfate deposition 1990-2008
 Display of information:
CO2 emissions 1995-2008
                         Lessons learned
•   Measurement flexibility can reduce costs, but it is not appropriate for all
    sources or sectors
•   Properly designed incentives can improve emission data accuracy
•   Frequent measurements allow for better compliance, analysis, and QA
•   Clear, consistent, and prescriptive rules for measuring emissions,
    QA/QC, addressing missing or invalid data, and reporting
•   Measurement programs must adapt to new information,
    instrumentation/technology, and science
•   Measurement programs must have mechanisms to deal with unusual or
    unique situations
•   Electronic reporting reduces burden on industry and government,
    increases timeliness of data, and facilitates electronic QA/QC and
    auditing
•   Data transparency is important, but not sufficient; data must be
    presented in an easy-to-understand and meaningful format
           For More Information

Visit the clean air markets web site to view
  – Emission data and allowance information
  – Cap and trade program information
  – Program rules and guidelines
  – Studies and reports
  – International cooperation activities

            http://www.epa.gov/airmarkets/