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The Standard
October 2009 - Page 1

US EPA Issues Landmark Greenhouse Gas Reporting Rule
On September 22, 2009, the United States Environmental Protection Agency (US EPA) issued its final rule regarding the mandatory reporting of greenhouse gases (GHGs), codified at 40 CFR 98 (the Rule). Simply put, the Rule requires “large” emitters of greenhouse gases (including carbon dioxide [CO₂], methane [CH₄], nitrous oxide [N₂O], perfluorochemicals [PFCs], hydrofluorocarbons [HFCs], and sulfur hexafluoride [SF₆], plus other fluorinated gases) to track and report emissions on an annual basis. It is estimated that approximately 10,000 facilities and suppliers are covered under the Rule, comprising 85% of the GHG emissions in the United States.

smoke stack According to the US EPA, the Rule is not intended to supersede existing state and local regulations. Instead, the purpose of the Rule is “to collect accurate and timely emissions data to inform future policy decisions.”

Affected entities include fossil fuel and industrial gas suppliers, direct GHG emitters (25,000 metric tons or more of carbon dioxide equivalents per year [CO₂e/y]) and manufacturers of heavy duty and off-road vehicles and engines. Emissions data are collected at the facility level, with the exception of fossil fuel suppliers, that report at the corporate level, and must include emissions from all “source categories” as defined, by the Rule. Data collection begins in January 2010, and the first annual report is due to US EPA by March 31, 2011.

In addition to establishing reporting thresholds and source categories, the final Rule specifies the emissions measurement equipment and calculation methodologies that affected entities are required to use when reporting emissions. (Facilities and suppliers are permitted to use “best available” monitoring methods for the first quarter of 2010.) The Rule also includes record-keeping and monitoring requirements; a final report must be signed by a designated representative and submitted electronically to the Agency.

Environmental Standards is currently comparing the Rule’s data collection and record-keeping requirements against established data management processes. Key findings to date are presented below.

The Rule requires that emissions must be aggregated at the facility or corporate level (across source categories) and subsequently broken down by source or supplier category; accordingly, data collection must be consistent and transparent at the entity level and below.
Records and reports must be kept for at least 3 years; therefore, emissions data and calculations must be reproducible. Document management standard operating procedures (SOPs) may need to be updated to reflect the paperwork associated with additional emissions sources and monitoring equipment records.
The regulatory climate may change, including mandatory GHG emissions caps. With a body of consistent, transparent, and reproducible data, a reporter will be able to identify with accuracy the areas of greatest potential emissions reductions.

Environmental Standards will continue to evaluate the Rule as it impacts our clients’ data management processes.

Sample Temperature Preservation Guidance
An Environmental Standards’ client recently received a generic request from its contracted laboratory to authorize the analysis of wastewater samples that lacked proper temperature preservation upon receipt at the laboratory. Quality Assurance Specialist/Principal David R. Blye, CEAC, responded that the laboratory request was definitely unusual and advised the client against agreeing to such a “blanket” request.

The Methods Update Rule (MUR; Federal Register, March 12, 2007 [Volume 72 Number 47]) revised the sample temperature preservation requirement from 4º± 2ºC to less than or equal to 6ºC (not frozen) but failed to provide guidance about exceedance of this criterion. According to Mr. Blye, the receipt of out-of-criterion samples should be handled on a case-by-case basis; the laboratory should contact the client for direction. Samples for volatile organic analysis received at room temperature present a much different scenario than samples received for polychorinated biphenyls (PCBs) analysis received at room temperature. The client should have the option of proceeding with the analysis or cancelling the analysis and re-sampling - depending on the samples and parameters in question.

For additional information about sample temperature preservation or other laboratory issues, contact Mr. Blye at 610-935-5577.

LEED Consulting Services Now Offered
LEED AP Environmental Standards is proud to announce that we now have two Leadership in Energy and Environmental Design (LEED) Accredited Professionals (APs) on staff – Joseph Kraycik and Kathy Zvarick of our Geosciences Department. As LEED APs, Mr. Kraycik and Ms. Zvarick will be helping clients integrate the strategies of sustainable development into Phase I Environmental Site Assessments (ESAs) and brownfield redevelopment projects. Environmental Standards is excited to offer this new, value-added service to our clients and is looking forward to the new LEED APs’ energy and environmental impact audit of our own corporate headquarters in Valley Forge, Pennsylvania.

LEED is a widely respected green building certification system that provides third-party verification that a building was designed and built using strategies aimed at improving performance across energy and environmental metrics such as energy savings, water efficiency, CO₂ emission reduction, improved indoor environmental quality, and stewardship of resources and sensitivity to their impacts. The purchasing of regionally produced, rapidly renewable, or recycled materials; the amount of daylight provided in workspaces; and the use of low volatile organic compound-emitting building materials are only a few of the many factors that can be evaluated for building certification.

Developed by the US Green Building Council (US GBC), LEED provides building owners and operators a concise framework for identifying and implementing practical and measurable green building design, construction, and operation and maintenance solutions. The LEED professional credentialing and building certification processes are managed by the Green Building Certification Institute, which currently has over 17,000 building certification applications in process. LEED building ratings range from basic certification to silver, gold, and platinum certifications.

The LEED market is growing. As of the date of this article, all construction and renovation of federal buildings must be LEED Silver certified. The city of Pasadena, California, Green Building Ordinance requires all privately owned buildings to achieve LEED certification and municipal buildings with 5,000 square feet or more of new construction to achieve LEED Silver certification. In Boston, Massachusetts, all new buildings of more than 50,000 square feet are required to adhere to LEED standards. The green building industry is expected to reach $60 billion by 2010.

Buildings in the United States are responsible for 39% of the nation’s CO₂ emissions, 40% of energy consumption, 13% water consumption, and 15% of the gross domestic product (GDP) per year - making green building a source of significant economic and environmental opportunity. Greater building efficiency can meet 85% of future US demand for energy, and a national commitment to green building has the potential to generate 2.5 million American jobs.

Please contact Mr. Kraycik or Ms. Zvarick at 610-935-5577 if you would like more information about the LEED building certification process.

TVA Safety Slogan Contest
Environmental Standards geoscientist Shaun Gilday was recently chosen as the winner of the Tennessee Valley Authority’s (TVA’s) Kingston Recovery Site Safety Slogan contest. Mr. Gilday’s entry, “Alert Today, Alive Tomorrow” was chosen from a pool of 200. Way to go, Shaun!

Career Opportunities at Environmental Standards
Environmental Standards is actively seeking qualified individuals to fill the following positions in our Valley Forge, Pennsylvania, location:

Entry, Mid- and Senior-Level Environmental Chemists
Environmental Information Technology Manager
Mid-Level Geoscientist

Environmental Standards also has the following openings in our Kingston/Oak Ridge, Tennessee, location:

Senior-Level Environmental Chemist
Senior-Level Geoscientist

For full position descriptions, please visit our Jobs page.

If you are a motivated, hard-working professional who wants to excel in a fast-paced, client-driven environment, we encourage you to submit your resume for consideration. We are an equal opportunity employer and offer a competitive salary and comprehensive benefits package.

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