1 

MEMORANDUM 

To: Docket EPA-HQ-OAR-2012-0934 

From: Rachel Schmeltz, U.S. EPA, Climate Change Division 

Date: March 1, 2013 

Subject: Proposed data category assignments and confidentiality determinations for new and 

substantially revised data elements in the proposed “2013 Revisions to the 

Greenhouse Gas Reporting Rule and Confidentiality Determinations for New or 

Substantially Revised Data Elements”. 

In this memorandum, we show the proposed data category assignments for new and substantially 

revised data elements in fourteen subparts that are proposed to be added or revised in the 2013 

Revisions to the Greenhouse Gas Reporting Rule and Confidentiality Determinations for New or 

Substantially Revised Data Elements. These subparts include subparts A, H, K, X, Y, Z, AA, FF, 

HH, NN, QQ, RR, TT, and UU. The tables below show the proposed assignment of each data 

reporting element into data categories. The tables also show the proposed confidentiality 

determinations (categorical through category assignment or individual) for these data elements 

except for those assigned to the inputs to equations data category. 

In the May 26, 2011, Final CBI rule (76 FR 30782), the EPA created 22 data categories for part 

98 data elements, assigned individual data elements in 34 subparts to appropriate data categories, 

and issued categorical confidentiality determinations for nine of the direct emitter data 

categories and eight of the supplier data categories. EPA did not make categorical determinations 

for two of the direct emitter data categories (“Unit/Process ‘Static’ Characteristics That are Not 

Inputs to Emission Equations” and “Unit/Process ‘Operating’ Characteristics That are Not Inputs 

to Emission Equations”) and three supplier data categories (GHGs Reported, 

Production/Throughput Quantities and Composition, and Unit/Process Operating 

Characteristics), and the CBI determinations for data elements assigned to those categories were 

made on an element-by-element basis. EPA has been following this approach in subsequent 

rulemakings to make confidentiality determinations for new and substantially revised data 

elements established in subsequent amendments to part 98. EPA did not make any confidentiality 

determination for data elements assigned to the inputs to emission equations category. In this 

action, the EPA is similarly proposing to assign 26 new or substantially revised data elements to 

data categories for which EPA issued categorical confidentiality determinations and apply the 

categorical determinations to the assigned data elements. The EPA is proposing to assign 16 new 

or revised data elements to the “Unit/Process ‘Static’ Characteristics That are Not Inputs to 

Emission Equations” and “Unit/Process Operating Characteristics That are Not Inputs to 

Emission Equations” direct emitter data categories and the “Production/Throughput Quantities 

and Composition” and “Unit/Process Operating Characteristics” supplier data categories and 

make confidentially determinations for these reporting elements individually. We are not 

proposing data categories or confidentiality determinations for 2 data elements where the data 

elements refer to another data element for which a CBI determination has already been finalized. 

The tables below identify the proposed data categories and the confidentiality determination for 
2 

the new or revised data elements in the proposed amendments. EPA is proposing to assign 13 

new or revised data elements to the inputs to emission equations category but is not proposing 

confidentiality determinations for them. 

For descriptions of the data categories and the categorical confidentiality determinations made 

for these categories, see the preambles to the proposed and final rulemakings: Proposed 

Confidentiality Determinations for Data Required Under the Mandatory Greenhouse Gas 

Reporting Rule and Proposed Amendment to Special Rules Governing Certain Information 

Obtained Under the Clean Air Act published on July 7, 2010 (75 FR 39094); and Confidentiality 

Determinations for Data Required under the Mandatory Greenhouse Gas Reporting Rule and 

Amendment to Special Rules Governing Certain Information Obtained under the Clean Air Act

published on May 26, 2011 (76 FR 30782). 

Copies of the proposed and final rules are available on EPA’s website: 

http://www.epa.gov/climatechange/emissions/CBI.html, at the following links: 

http://www.gpo.gov/fdsys/pkg/FR-2010-07-07/pdf/2010-16317.pdf and 

http://www.gpo.gov/fdsys/pkg/FR-2011-05-26/pdf/2011-12930.pdf. 

 
3 

Appendix A-1 

Proposed Data Category Assignments for Direct Emitters [Subparts A, H

List of Proposed Data Category Assignments 

Subpart 

 Rule Citation for Data Reporting 

Element (proposed for new data 

elements; no change from previous 

citation for revised data elements) Data Element Description New or r

A 98.3(c)(1) If the facility does not have a physical street 

address, then the facility must provide the latitude and longitude representing the location of facility operations in decimal degree format. 

Revises reelement to facilities wa physical to report tlatitude anlongitude. 

A 98.3(c)(13) ORIS code for each power generation unit that has 

been assigned an ORIS code by the Energy Information Administration. 

New 

H 98.86(a)(2) Annual facility cement production. Revised so 

reporting annual facwide basis of monthlbasis 

K 98.116(e) Annual process CH4 emissions (in metric tons) 

from each EAF used for the production of any ferroalloy listed in Table K–1 of subpart K of 40 CFR part 98 (metric tons). 

New 
4 

Subpart 

 Rule Citation for Data Reporting 

Element (proposed for new data 

elements; no change from previous 

citation for revised data elements) Data Element Description New or r

X 98.246(a)(6) Name of each method listed in §98.244(b)(4) used 

to determine carbon content or molecular weight and a description of each type of device (e.g., flow meter, weighing device) and identification of methods (i.e., method number, title, or other description) used to determine flow or mass in accordance with §98.244(b)(1) through (3). 

Revised to reporting requiremeadd requirto report descriptiodevice usemeasure flmass. 

X 98.246(a)(8) Identification of each combustion unit that burned 

both process off-gas and supplemental fuel, including combustion units that are not part of the petrochemical process unit. 

Revised to reporter minclude combustiothat are nothe petrocprocess un

X 98.246(b)(4) For each CEMS monitoring location that meets the 

conditions in paragraph (b)(2) or (3) of this section, provide an estimate based on engineering judgment of the fraction of the total CO2 emissions that is attributable to the petrochemical process unit. 

Revised to to the conin (b)(2) a(b)(3) and specify repof total Cemissions attributablpetrochemprocess un(process acombustio
5 

Subpart 

 Rule Citation for Data Reporting 

Element (proposed for new data 

elements; no change from previous 

citation for revised data elements) Data Element Description New or r

X 98.246(b)(5) For each CEMS monitoring location that meets the 

conditions in paragraph (b)(2) of this section, report the CH4 and N2O emissions expressed in metric tons of each gas. 

Revised to to the conin (b)(2), aclarify emof CH4 anbe reporteeach CEMmonitorinlocation. 

X 98.246(b)(5) For each CEMS monitoring location, provide an 

estimate based on engineering judgment of the fraction of the total CH4 and N2O emissions that is attributable to combustion of off-gas from the petrochemical process unit 

Revised to the fractioCH4 and Nattributablcombustiogas, rather the fractioemissions

Y 98.256(j)(10) If you use Equation Y-19 of this subpart, the 

relevant information required under paragraph (l)(5) of this section. 

New 

Y 98.256(k)(6) If you use Equation Y-19 of this subpart, the 

relevant information required under paragraph (l)(5) of this section for each set of coke drums or vessels of the same size. 

New 

Z 98.266(b) Annual phosphoric acid production capacity. Revised to 

production capacity inof permittproduction capacity. 

1 This data element refers to another data element for which a CBI determination has already been finalized; see (76 FR 30801, May 26

2 A confidentiality determination has not been made for this data element. Capacity data elements may be competitively sensitive but m
6 

Subpart 

 Rule Citation for Data Reporting 

Element (proposed for new data 

elements; no change from previous 

citation for revised data elements) Data Element Description New or r

Z 98.266(f)(8) Number of times missing data procedures were 

used to estimate CO2 contents of the phosphate rock (months) (if applicable). 

New 

AA 98.276(k)(1) Annual production of unbleached virgin pulp 

produced onsite during the reporting year. 

Revised to products r

AA 98.276(k)(2) Annual production of paper products exiting the 

paper machine(s), prior to application of any offmachine coatings during the reporting year. 

Revised to products r

FF 98.326(i) If the quarterly CH4 concentration is based on 

CEMS or weekly sampling. 

New 

FF 98.326(o) The moisture correction factor (if applicable) used 

in Equation FF–1 and FF–3. 

New 

FF 98.326(r)(2) Start date of each well and shaft. New FF 98.326(r)(2) Close date of each well and shaft. New FF 98.326(r)(3) Number of days each well or shaft was in 

operation during the reporting year. 

New 

FF 98.326(t) Quarterly CH4 routed to each destruction device or 

offsite transfer point 

New 

FF 98.326(u) Mine Safety and Health Administration (MSHA) 

identification 

New 

HH 98.346(h) Oxidation fraction used in the calculation for 

methane generation for landfills without gas collection systems 

New 

HH 98.346(i)(8) Oxidation fraction used in Equation HH-5 for 

landfills with gas collection systems. 

New 

HH 98.346(i)(10) Oxidation fraction used in Equation HH-7 for 

landfills with gas collection systems. 

New 
7 

Subpart 

 Rule Citation for Data Reporting 

Element (proposed for new data 

elements; no change from previous 

citation for revised data elements) Data Element Description New or r

HH 98.346(i)(11) Oxidation fraction used in Equation HH-6 for 

landfills with gas collection systems. 

New 

HH 98.346(i)(12) Oxidation fraction used in Equation HH-8 for 

landfills with gas collection systems. 

New 

TT 98.466(b)(1) The number of waste steams (including “Other 

Industrial Solid Waste (not otherwise listed)” and “Inerts ”) for which Equation TT–1 of this subpart is used to calculate modeled CH4 generation. 

Revised to include inwaste stre

TT 98.466(c)(5)(i) WIP at start of reporting year , or design capacity 

for closed landfills 

New 

TT 98.466(c)(5)(ii) The cumulative quantity of waste placed in the 

landfill 

New 

TT 98.466(c)(5)(iii) YrLast New TT 98.466(c)(5)(iv) YrOpen New TT 98.466(c)(5)(v) NYrData New 
8 

Subpart 

 Rule Citation for Data Reporting 

Element (proposed for new data 

elements; no change from previous 

citation for revised data elements) Data Element Description New or r

TT 98.466(d)(3) For each waste stream, indication as to whether 

the DOCx was a default value from Table TT-1 or a value determined through measurement. 

Revised to that the daelement mreported fwaste stre

TT 98.466(h) For landfills with gas collection systems, methane 

generation, using equation TT-6 

Revised to this requirshould be calculated Equation T

TT 98.466(h) For landfills with gas collection systems, oxidation 

factor 

New 

Appendix A-2 

Proposed Data Category Assignments for Suppliers3 [Subpar

List of Proposed Data Category Assignments 

Subpart 

 Rule Citation for Data Reporting 

Element (proposed for new data 

elements; no change from previous 

citation for revised data elements) Data Element Description New or r

3 Supplier data does not meet the definition of emission data; see Confidentiality Determinations for Data Required Under the Mandato

Governing Certain Information Obtained Under the Clean Air Act (76 FR 30785, My 26, 2011) 
9 

Subpart 

 Rule Citation for Data Reporting 

Element (proposed for new data 

elements; no change from previous 

citation for revised data elements) Data Element Description New or r

NN 98.406(a)(4)(i) NGL Fractionator: Annual quantity (in barrels) of 

y-grade, o-grade, or other bulk NGLs received. 

Revised to quantity amaterials received. 

NN 98.406(a)(4)(ii) NGL Fractionator: Annual quantity (in barrels) of 

y-grade, o-grade, or other bulk NGLs supplied to downstream users that are not fractionated by the reporter. 

Revised to quantity amaterials downstrea

NN 98.406(b)(2) LCDs: Annual volume in Mscf of natural gas 

placed into storage or liquified and stored (Fuel 1 in Equation NN-5a). 

Revised to harmonize reporting requiremecalculation changes. 

NN 98.406(b)(3) LCDs: Annual volume in Mscf of vaporized 

liquefied natural gas (LNG) produced at on-system vaporization facilities for delivery on the distribution system (Fuel2 in Equation NN-5a). 

Revised to harmonize reporting requiremecalculation changes. 

NN 98.406(b)(3) LCDs: Annual volume in Mscf of natural gas 

withdrawn from on-system storage for delivery on the distribution system (Fuel2 in Equation NN-5a). 

New 

NN 98.406(b)(5) LCDs: Annual volume in Mscf of natural gas that 

bypassed the city gates and was supplied through the LDC distribution system. This includes natural gas from producers and natural gas processing plants from local production, or natural gas that was vaporized upon receipt and delivered, and any other source that bypassed the city gate (Fuelz in Equation NN-5b). 

Revised to harmonize reporting requiremecalculation changes. 
10 

Subpart 

 Rule Citation for Data Reporting 

Element (proposed for new data 

elements; no change from previous 

citation for revised data elements) Data Element Description New or r

NN 98.406(b)(7) LCDs: Annual volume in Mscf of natural gas 

delivered by the LDC to each sales or transportation customer’s facility that received from the LDC deliveries equal to or greater than 460,000 Mscf during the calendar year, if known; otherwise, the annual volume in Mscf of natural gas delivered by the LDC to each meter registering supply equal to or greater than 460,000 Mscf during the calendar year. 

Revised to amount deto each satransportacustomer’facility. 

NN 98.406(b)(12) LCDs: Meter number for each end-user reported in 

paragraph (b)(7). 

Revised to end-user iof meter r

NN 98.406(b)(12) LCDs: Whether the quantity of natural gas 

reported in paragraph (b)(7) is the total quantity delivered or the quantity delivered to a specific meter. 

New 

QQ 98.436(a)(6)(iii) If the reporter does not know the identity and the 

mass of the F-GHGs within the closed cell foam: For closed cell foams that are not imported inside of equipment, the density in CO2e of the F-GHGs in the foam. 

Revised to mass to de

QQ 98.436(b)(6)(iii) If the reporter does not know the identity and the 

mass of the F-GHGs within the closed cell foam: For closed cell foams that are not exported inside of equipment, the density in CO2e of the F-GHGs in the foam. 

Revised to mass to de

RR 98.446(b)(5) The standard or method used to calculate each 

value in paragraphs (b)(1), (b)(2), and (b)(3) of 40 CFR 98.446. 

Revised to include pa(b)(3). 

UU 98.476(b)(5) The standard or method used to calculate each 

value in paragraphs (b)(1), (b)(2), and (b)(3) of 40 CFR 98.476. 

Revised to include pa(b)(3). 
11 

Subpart 

 Rule Citation for Data Reporting 

Element (proposed for new data 

elements; no change from previous 

citation for revised data elements) Data Element Description New or r

UU 98.476(e)(1) Whether the facility received a Research and 

Development project exemption from reporting under 40 CFR Part 98 subpart RR for the reporting year. 

New 

UU 98.476(e)(1) If you received a Research and Development 

project exemption from reporting under 40 CFR Part 98 subpart RR for the reporting year, the start date of the exemption. 

New 

UU 98.476(e)(1) If you received a Research and Development 

project exemption from reporting under 40 CFR Part 98 subpart RR for the reporting year, the end date of the exemption. 

New 

UU 98.476(e)(2) Whether the facility includes a well or group of 

wells where a CO2 stream was injected into subsurface geologic formations to enhance the recovery of oil during the reporting year. 

New 

UU 98.476(e)(3) Whether the facility includes a well or group of 

wells where a CO2 stream was injected into subsurface geologic formations to enhance the recovery of natural gas during the reporting year. 

New 

UU 98.476(e)(4) Whether the facility includes a well or group of 

wells where a CO2 stream was injected into subsurface geologic formations for acid gas disposal during the reporting year. 

New 

UU 98.476(e)(5) Whether the facility includes a well or group of 

wells where a CO2 stream was injected for a purpose other than those listed in (e)(1)through (4) of 40 CFR 98.476. 

New 

UU 98.476(e)(5) The purpose of the injection, if you injected CO2

for a purpose of than those listed in paragraph (e)(1) through (4) of 40 CFR 98.476. 

New