ENV-09-56 Case Study: EPA Mandatory Reporting Rule Gap Assessment

Description:

This paper presents a case study of Tesoro Golden Eagle Refinery (GER) efforts to implement a greenhouse gas (GHG) emissions reporting and management system that meets California and US-wide reporting needs and positions them for future cap-and-trade in the US. The paper provides a comparison of the proposed EPA mandatory GHG reporting rule requirements with the requirements of California AB-32 reporting, voluntary reporting to the California Climate Action Registry (CCAR), and the revised American Petroleum Institute (API) Compendium and SANGEA. Contrasts to common practice reporting methodologies, measurement frequency, quality assurance procedures, and documentation are highlighted by the Tesoro GHG Reporting Program. Based on Tesoro’s and ERM’s work and lessons learned from this project, this paper suggests practical guidance on what a refinery should be doing to prepare for the EPA reporting rule and future Cap and Trade regulations.