Greenhouse Gas Emissions

Policy

The University of Chicago has developed a Greenhouse Gas (GHG) Monitoring Plan to meet the requirements of 40 Code of Federal Regulations (CFR) 98.3(g)(5).  The GHG Monitoring Plan, maintained internally by Environmental Health and Safety, outlines the methods and procedures necessary to ensure that all reports, data collected, and emission calculations meet the requirements of the 40 CFR 98 as mandated by the Environmental Protection Agency (EPA).  As of January 2016, the recordkeeping and annual report is transitioning the Title V Environmental Consultant, Mostardi Platt.

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Authority and Responsibility

Environmental Consultant (Mostardi Platt) is responsible for:

  • Ensuring overall compliance with the Mandatory GHG Reporting Regulation, 40 CFR 98;
  • Creating and maintaining a Greenhouse Gas Monitoring Plan;
  • Collecting annual natural gas usage from all GHG emission sources from Facilities Services, Energy and Utilities Management - Energy Manager and University of Chicago Medicine's Energy Manager;
  • Collecting annual natural gas usage from select residential properties that are not supported by the University's utility plants;
  • Collecting high heat value (HHV) data of the natural gas from Facilities Services, Energy and Utilities Management - Energy Manager;
  • Collecting annual fuel oil usage from all GHG emission sources from Facilities Services, Steam Plant and Distribution - Manager or Assistant Manager;
  • Collecting HHV and sulfur content data of the fuel oil from Facilities Services, Steam Plant and Distribution - Manager or Assistant Manager;
  • Completing emissions calculations for carbon dioxide (CO2), carbon dioxide equivalent (CO2e), methane (CH4), and nitrous oxide (N2O);
  • Providing a certificate of representation at least 60 days before the deadline for the initial emission report, per 98.4(d);
  • Registering an Agent that will collect data, calculate emissions and enter results into the EPA's electronic greenhouse gas reporting tool (e-GGRT);
  • Registering a Designated Representative and an Alternate Designated Representative who shall be responsible for certifying, signing, and submitting the annual GHG report no later than March 31 of each calendar year for the GHG emissions in the previous calendar year; and
  • Retaining all required records for at least five years.

Facilities Services-Operations, Engineering and Utilities (Energy Manager) is responsible for:

  • Collecting and maintaining natural gas usage from the fuel supplier (currently People's Gas);
  • Verifying that the HHV appears on every invoice from the fuel supplier;
  • Providing the environmental consultant with the natural gas usage as reported on fuel supplier's invoice in standard cubic feet, for all GHG emission sources monthly for campus buildings; and
  • Providing the environmental consultant with HHV data of the natural gas used upon request, at least annually.

Facilities Services-Operations Group, Engineering and Utilities (Manager or Assistant Manager for West and South Plant) is responsible for:

  • Collecting and maintaining fuel oil usage data from the fuel supplier (currently Paulson Oil Company- POCO Oil);
  • Verifying that the HHV and sulfur content appears on every invoice from the fuel oil supplier;
  • Providing the environmental consultant with monthly fuel oil usage, in gallons as measured by fuel supplier's flowmeters, for all GHG emission sources monthly; and
  • Providing the environmental consultant with HHV data of the fuel oil upon request, at least annually.

Physical Plant (Energy Manager) for the University Chicago Medicine is responsible for:

  • Collecting and maintaining natural gas usage from the fuel supplier (currently People's Gas);
  • Verifying that the HHV appears on every invoice from the fuel supplier;
  • Providing the environmental consultant with annual natural gas usage as reported on fuel supplier's invoice, in standard cubic feet, for all GHG emission sources upon request, at least annually; and
  • Providing the environmental consultant with HHV data of the natural gas used upon request, at least annually.

University of Chicago Medicine's and Biological Sciences Division- Facilities, Design and Construction Project Managers are responsible for:

  • Notifying the environmental consultant when a new combustion source, regardless of size, (i.e. boiler, heater, kitchen range, etc.) is planned for installation within the Medical Center;
  • Notifying the environmental consultant if a new property containing an existing combustion source is purchased; and
  • Furnish meter number and inform Physical Plant Energy Manager, to ensure monthly tracking of fuel utilization commences.

Facilities Services, Capital Project Delivery Project Managers are responsible for:

  • Notifying the environmental consultant when a new combustion source, regardless of size, (i.e. boiler, heater, kitchen range etc.) is planned for installation on the campus and/or applicable residential properties.
  • Notifying the environmental consultant if a new property containing and existing combustion source is purchased; and
  • Furnish meter number and inform the Facilities Services Energy Manager, to ensure monthly tracking of fuel utilization commences.

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Scope

The University of Chicago is required to comply with 40 CFR 98 due to its stationary fuel combustion sources (boilers, heaters, etc.).  Applicability is triggered because the University's boilers have an aggregate maximum rated heat input capacity of greater than 30 million British Thermal Units per hour (mmBTU/hr), and emit greater than 25,000 metric tons of equivalent carbon dioxide (CO2e) per year.

The EPA defines "facility" as any physical property, plant, building, structure, or stationary equipment located on one or more contiguous or adjacent properties in actual physical contact or separated solely by a public roadway or other public right-of-way and under common ownership or common control, that emits or may emit any greenhouse gas.  The campus has been defined as 61st Street on the south, 55th Street on the north, Cottage Grove Avenue on the west and Stony Island Avenue on the east.

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Annual Report

The annual GHG report must be submitted to the United State Environmental Protection Agency (USEPA) no later than March 31 of each calendar year for GHG emissions in the previous calendar year.  The report must be submitted electronically, per 40 CFR 98.5, by logging into the e-GGRT system.

The GHG data shall be incorporated into the Annual Emissions Report (AER), due May 1st to the IEPA and EPA.

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Recordkeeping

The University shall retain required records for at least five years.  Electronic or hard-copy format are acceptable, as appropriate.  Required records include:

  1. List of all units, operations, processes, and activities for which GHG emissions were calculated;
  2. Data used to calculate emissions for each unit, operation, process, and activity.  Categorize by fuel or material type:
  • GHG emissions calculations and methods used;
  • Analytical results for development of site-specific emissions factors (currently not applicable to the University and/or Medical Center);
  • Results of all required analyses for HHV, carbon content, and other required fuel or feed stock parameters;
  • Facility operating data or process information used for the calculations; and
  • The natural gas and fuel oil totals must be taken from the applicable utility company's invoice.  The legally required QA/QC GHG Manual and calculation method can only be utilized if data is collected from the respective utility company's flow meters.  At this time, the University and the Medical Center's flow meters do not meet the testing standards to provide accurate/acceptable data.  The respective departments shall maintain a copy of the fuel invoices for five years.

Further required records include:

  1. Annual GHG reports;
  2. Missing data computations.  For each missing data event, also retain a record of the duration of the event, actions taken to restore malfunctioning monitoring equipment, cause of the event, actions taken to prevent or minimize occurrence in the future;
  3. Maintain and review written GHG Monitoring Plan;
  4. If applicable, retain results of all required certification and quality assurance tests of continuous monitoring systems, fuel flow meters, and other instrumentation used to provide GHG data; and
  5. Maintenance records for all continuous monitoring systems, flow meters, and other instrumentation used to provide GHG data.

Created:  June 2010

Reviewed: January 2016

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