## Schmeltz, Rachel

From : 

## S e nt : To : 

## Subject: Attachments :

Hi Aaron, Schmeltz, Rachel Wednesday, October 07

, 2015 10:08 AM Aaron

_ L

_

Szabo@omb.eop.gov
FW: Greenh ous e Gas Reporting Program NPRM

-- Contact Information
2015 Revisions Impacts Assessment

_ 9

_ 18 _1 5.docx

I just wanted to check in that you got this memo , to see if you need anything else at this point, and when you might be ready to schedule a call to go over this proposed rule. Thanks!
Rachel

Rachel Schmeltz
U.S. Environmental Protection Agency schmeltz.rachel@epa.gov
Phone: 202-343-9124
Telework on most Fridays
Alternate phone number for telework days: 301

- 252

- 8060.

From : 

## Schmeltz, Rachel 

## Sent: Wednesday, September 30

, 2015 1:04 PM
To : 

## 'Aaron_L_Szabo@omb.eop.gov'
Cc: Cook, Carole 

## Subject : FW: Greenhouse Gas Reporting Program NPRM

-- Contact Information

Hi Aaron,
Attached is the document you requested. If you need anything e l se for your review of this proposed rule

, please l et me know.
Thanks!
Rachel

Rachel Schmeltz U.S. Environmental Protection Agency schmeltz.rachel@epa.gov
Phone: 202

- 343-9124
Telework on most Fridays Alternate phone number for telework days: 301-252

- 8060.

From: 

## Cook, Carole 

## Sent: Wednesday, September 30, 2015 10:54 AM
To : 

## Schmeltz, Rachel 

## Subject: FW: Greenhouse Gas Reporting P ro gram NPRM

-- Contact Information

1

### From : 

## Szabo

, Aaron [ mailto:Aaron L Szabo@omb.eop.gov]
Sent: 

## Wednesday, September 30, 2015 10:13 AM
To: 

## Cook, Caro l e Subject : 

## Greenhouse Gas Reporting Program N PRM

-- Contact Information

Hi Carole,

I tried to call you, but I believe that there may be some techni c al difficulties. I am the policy analyst leading the review for the Greenhous e Gas Reportin g Program NPRM and I saw that your name was the EPA contact was wondering if we could chat about the path forward for the rule. Please give me a call at the numbe r provided below. Thank you very

mu c h.

Aaron L. 

## Szabo Policy Analyst Offic e of Management and Budget
202 -3 95-3621 Aaron L Szabo@omb.eop.gov

2

### 1

MEMORANDUM

TO : Rachel Schmeltz, Lisa Grogan

- McCulloch, EPA

FROM : Tracy Curtis, Brandon Long, Joe Fanjoy, ERG

DATE : September 18, 2015

SUBJECT : Assessment of Burden Impacts of 201 5 Revisions to the Greenhouse Gas

Reporting Rule

EPA is proposing to revise specific subparts of the Greenhouse Gas Repo rting Rule to streamline and improve implementation of the rule and to improve the quality and co nsistency of
the data collected. These changes are referred to as the “2015 Revisions .”

This memorandum explains how reporters will be affected by the proposed 2015
Revisions and presents the impacts of the proposed changes to reporters . The memorandum is organized as follows:

Section 1 .0 : Background and Introduction for 2015 Revisions Section 2 .0 : Summary of Imp acts Section 3 .0 : Methodology Section 4 .0 : Impacts of Other Technical Revisions and Amendments Section 5.0: Confidentiality Determinations For New Or Revised Reporting Elements

1.0 BACKGROUND AND INTRO DUCTION FOR 2015 REVISIONS Facilities affected by the Greenhouse Gas Reporting Rule must report facility, emissions,
and emissions

- related data to EPA through the electronic Greenhouse Gas Reporting Tool ( e

GGRT )

. These data comprise hundreds of data elements that will inform future policy decisions

. To date, data have been reported for reporting years (RY) 2010 through RY 2014.

EPA is proposing to amend specific provisions in the Greenhouse Gas Reporting Rule to streamline and improve implementation of the rule, improve the quality and consistency of the data collected under the rule, and to clarify or propose minor updates to certain provisions that
have raised questions from reporting entities. These 2015 Revisions would improve the quality and consistency of the data collected, as well as improve the efficiency of the reporting process
for both EPA and re porters. EPA has categorized the proposed changes into four categories :

### 2

 Amendments that would expand current applicability, monito ring, or reporting requirements that are necessary to enhance the quality of the data collected, improve verification of collected data under the Greenhouse Gas Reporting Program ( GHGRP )

, and improve the accuracy of GHGRP data used in the U.S. GHG Inventory (GHG Inventory).

 Revisions to streamline implementation of the rule by reducing or simplifying requirements that would ease burden on reporters and EPA, such as revising requirements to focus GHGRP and reporter resources on rele vant data, removing reporting requirements for specific facilities that report little to no emissions, or removing reported data elements that are no longer neces sary.

 Other amendments, such as amendments to calculation, monitoring, or measurement method s that would address prior petitioner or commenter concerns (e.g., amendments that provide additional flexibility for facilities or that more accurately reflect industry processes and emissions).

 Minor clarifications and corrections that are n eeded to cla rify the rule, including: corrections to errors in terms and definitions in certain equations; clarifications that provide additional information for reporters to better or more fully understand compliance obligations; changes to correct cross references w ithin and between subparts; and other editorial or harmonizing changes that would improve the public’s understanding of the rule.

Some of the amendments in this proposed action are expected to change the burden on
reporters. Revisions to streamline imple mentation are expected to reduce burden on reporters. Revisions that would expand or revise current applicability, monitoring requirements, or reporting requirements are anticipated to increase burden on reporters. Other technical
amendments and minor clar ifications and corrections would have little effect on burden for
reporters.

EPA is proposing to implement the 2015 Revisions over RY 2016, RY 2017, and RY 2018.
This document describes the increase or decrease in burden for each subpart and the total
increm ental burden as changes are implemented in future reporting years.

2.0 SUMMARY OF IMPACTS The 2015 Revisions are anticipated to increase burden in cases where the proposed amendments would expand current applicability, monitoring, or reporting , and are anticipated to decrease burden in cases where the proposed amendments would streamline Part 98 to remove
notification or reporting requirements or simplify the data that must be reported. The proposed changes would be implemented over RY 2016, RY 2017, and R Y 2018

. The burden was subsequently determined based on when the proposed revisions would be implemented in each

year

. One

- time implementation costs would apply for certain revisions to applicability and monitoring revisions that would be implemented in RY 2 017 and RY 2018; therefore, t o

### 3

determine the total annual burden that will be incurred by industry once all revisions are implemented, costs were estimated from RY 2016 through RY2019. The incremental implementation costs for each reporting year are summariz ed in Table 2.1 of this document.
One

- time implementation costs are incorporated into first year costs, while subsequent year costs represent the average annual burden that will be incurred by reporters.

Table 2.1 Total Incremental Burden for Reporting Yea rs 2016

- 2019 ($ 2011 /year)
Cost Summary RY 2016 RY 2017 RY 2018 RY 2019
First Year Costs $9,359 $4,379,195 $121,719

-- Subsequent Year Annual Costs for Changes Implemented in:

2016

-- $9,359 $9,359 $9,359
2017

-- -- $3,770,300 $3,770,300
2018

-- -- -- $94,975 Total Costs by Year (all subparts) $9,359 $4,388,553 $3,901,378 $3,874,634



### To quantify burden of the proposed amendments, we considered the estimated incremental change in burden anticipated from amendments that:

1) Change the reporting requirements by a dd ing , revis ing , or remov ing existing data
elements

. The EPA is proposing to add or revise 12 1 reported data elements in 21 subparts of Part 98 in order to improve the data quality of the GHGRP. EPA is also proposing to remove 18 data elem ents in five subparts to streamline rule requirements.

2) Revise monitoring requirements such that facilities would need to collect additional
data

. EPA is proposing changes to the monitoring requirements of subpart FF of Part 98 (Underground Coal Mines) to remove the option to allow U.S. Mine Safety and Health Administration ( MSHA ) quarterly inspection reports to be used as a source of data for monitoring methane liberated from ventilation systems . Instead, facilities would be required to independently colle ct their own grab samples or use continuous emissions monitoring. EPA is also proposing to increase the frequency of collected grab samples from quarterly to monthly

.
3) R evis e applicability such that additional facilities would be required to report under

P art 98

. EPA is proposing revisions that would expand the applicability of two subparts of Part 98: subpart V (Nitric Acid Production) and subpart OO (Suppliers of Industrial Greenhouse Gases).

The schedule for the proposed revisions and the estimated incr emental burden on reporters for each of these t hree categories of changes are discussed in section 2.1. The

### 4

methodology for estimating the change in burden for the subparts affected by these changes is
discussed in Section 3.0 of this document.

In addition to the above amendments, EPA is propos ing technical revisions and other clarifications to several subparts in the GHG reporting rule that are not anticipated to have a significant impact on burden

. These amendments are discussed further in S ection 4.0 of this
document. EPA is also proposing confidentiality determinations for new or substantially revised reporting data elements , which do not affect the burden on reporters , as presented in S ection 5.0
of this document.

2.1 Implementation Schedule and Su mmary of Burden by Subpart

EPA is proposing to implement the 2015 Revisions over RY 2016, RY 2017, and RY 2018. The proposed changes would be implemented in each reporting year on a subpart basis, with the exception of minor harmonizing revisions to subpart A that would be implemented in RY 2016
and RY 2018. Table 2.2 shows when the proposed revisions for each subpart would become
effective ; note that not all subparts listed in Table 2.2 contain revisions that are anticipated to impact burden.

Table 2. 2 Impleme ntation Schedule by Subpart
Reporting Year Subparts Affected
2016 I, HH, A (harmonizing revisions to §98.6)

2017 A, C, E, F, G, N, O, P, Q, S, U, V, X, Z, AA, CC, DD, FF, II, LL, MM, NN, PP, RR,

TT, UU
2018 V, OO, Y, A (harmonizing revisions to Table A

- 5)



### As noted above, to quantify the burden associated with the proposed amendments, the estimated incremental change in burden was calculated for amendments that : 1) change the reporting requirements by adding, revising, or removing existing data elements; 2) revise applicability such that additional facilities would be required to report; or 3) revise monitoring requirements such that facilities would need to coll ect additional data. Revisions to reporting requirements would be implemented in RY 2016, RY 2017, and RY 2018 on a subpart basis and include annual labor costs. Revisions to monitoring requirements (subpart FF only) would be implemented in RY2017; the burden associated with these proposed revisions includes both
annual burden and o ne

- time implementation costs that would apply for RY201 7. Revisions that affect the applicability of subparts (subparts V and OO only) would be implemented in RY2018;
the burden ass ociated with these proposed revisions includes both annual burden and o ne

- time implementation costs that would apply for RY2018

.

### 5

Table 2. 3 of this document includes the estimated incremental burden by subpart and by each of these three categories of change s, by implementation year. The methodology for estimating the change in burden for these subparts is discussed in Section 3.0 of this document.

Table 2. 3 Incremental Burden by Subpart ($2011)

Subpart Costs for Additional

Reporters Costs for Revisions to Reporting Costs For Revisions to

Monitoring Provisions Total Cost

First Year Subsequent

Year First

Year Subsequent

Year First Year Subsequent Year First Year Subsequent Year Changes Implemented in RY2016
I $0 $0 $ 1,226 $ 1,226 $0 $0 $ 1,226 $ 1,226
HH $0 $0 $8,132 $8,132 $0 $0 $8,132 $8,132 Total Costs for Changes Implemented in RY2016 $9,359 $9,359 Changes Implemented in RY2017
A $0 $0 $ 4,906 $ 4,906 $0 $0 $ 4,906 $ 4,906
C $0 $0 $12,139 $12,139 $0 $0 $12,139 $12,139
E $0 $0 $10 $10 $0 $0 $10 $10
F $0 $0 $73 $73 $0 $0 $73 $73
G $0 $0 $ 228 $ 228 $0 $0 $ 228 $ 228
N $0 $0 $0 $0 $0 $0 $0 $0

O $0 $0 $106 $ 106 $0 $0 $106 $ 106 Q $0 $0 $0 $0 $0 $0 $0 $0

S $0 $0 $744 $ 744 $0 $0 $744 $ 744
U $0 $0 $0 $0 $0 $0 $0 $0

X $0 $0 $1,074 $1, 074 $0 $0 $1,074 $1, 074
Z $0 $0 $40 $ 40 $0 $0 $40 $ 40
AA $0 $0 $0 $0 $0 $0 $0 $0

CC $0 $0 $33 $ 33 $0 $0 $33 $ 33
DD $0 $0 $ 2,000 $ 2,000 $0 $0 $ 2,000 $ 2,000
FF $0 $0 $3,306 $152 $4,350,239 $3,741,344 $4,353,545 $3,74 4

, 650
II $0 $0 $2,562 $2,562 $0 $0 $2,562 $2,562
LL $0 $0

- $17

- $17 $0 $0

- $17

- $17
MM $0 $0 $0 $0 $0 $0 $0 $0

NN $0 $0 $1,752 $1,752 $0 $0 $1,752 $1,752
PP $0 $0 $0 $0 $0 $0 $0 $0

RR $0 $0 $0 $0 $0 $0 $0 $0
TT $0 $0 $0 $0 $0 $0 $0 $0

UU $0 $0 $0 $0 $0 $0 $0 $0 Total Costs for Changes Implemented in RY2017 $4,379,195 $3,770,300 Changes Implemented in RY2018
V $83,544 $66,403 $116 $ 116 $0 $0 $83,659 $ 66,518
Y $0 $0 $1,448 $ 1,448 $0 $0 $1,448 $ 1,448
OO $36,215 $26,612 $397 $397 $0 $0 $36,612 $27,009 Total Costs for Changes Implemented in RY2018 $121,719 $94,975 Total Cost (All Subparts) $119,759 $93,015 $40,275 $40,275 $4,350,239 $3,741,344 $4,510,273 $3,874,634

### 6

To obtain the total annual incremental burden for RY2016 through RY2019 in Table 2.1 of this document, the first

- year and subsequent year costs for all revisions implemented within the reporting year were totaled (e.g., the total incremental burden for RY2018 includes first

- year costs for revisions implemented i n RY2018, and subsequent year costs for revisions implemented in RY2016 and RY2017.)

2.2 S mall Entity Impacts The impacts to small entities due to the revisions was evaluated for each subpart. The small entities directly regulated by these final rule revisions include small businesses across all sectors of the economy encompassed by Part 98, small governmental jurisdictions, and small

non

- profits. D etailed analyses of the cost impact s to small e ntities were performed for subpart V, subpart FF, and subpart OO , where revisions to applicability or monitoring requirements result in a significant increase in burden. A discussion of these analyses is included in the individual subpart impacts in sectio n 4 .0. We determined there will not be a significant economic impact to small entities for these three subparts. For all other subparts affected by the revisions for a dding,

r evising, or r emoving r eporting r equirements , we determined that these facilities will experience
annual impacts of roughly $ 15 per facility. Because this cost is minimal, no small entity impacts are anticipated for facilities subject to the revisions that add, revise, or remove reporting requirements.

3.0 METHODOLOGY FOR ESTI MATING BURDE N

This section describes t he methodologies used to determine cost impacts shown in tables
2.1 and 2.3 of section 2.0.

3.1 Revisions That Add, Revise, or Remove Reporting R equirements EPA is proposing to add or revise 12 1 reported data elements in 21 subparts of Part 98 in order to improve the data quality of the GHGRP and to remove 18 data elements in five subparts to streamline rule requirements (Table 3.1)

. The specific data elements that the EPA is proposing to add, revise, or remove in the 2015 Re visions are included in Section 4.0 of this document.

Table 3.1 GHG Reporting Rule Subparts with Proposed New, Revised, or Removed Data Elements

Subpart GHG Source Category No. of Added Data Elements No. of

Revised Data Elements No. of

Deleted Data Elements

A General Provisions 6

- - C General Stationary Fuel Combustion Sources 3

- -

E Adipic Acid Production 1 0 0

F Aluminum Production 2 0 0

G Ammonia Manufacturing 3 0 0 Commented [TC1]: Note this does not include two data elements in subparts E and V for which burden was not calculated (data elements are only required for alternative method and only in cases where a new approval is needed ).

### 7

Table 3.1 GHG Reporting Rule Subparts with Proposed New, Revised, or Removed Data Elements

Subpart GHG Source Category No. of Added Data Elements No. of

Revised Data Elements No. of

Deleted Data Elements

I Electronics Manufacturing 7 0 0

O HCFC

- 22 Production and HFC

- 23 Destruction 1 10 3

S Lime Manufacturing (non

- CEMS) 3 0 0

V Nitric Acid Production 1 0 0

X Petrochemical Production 3 2 0

Y Petroleum Refineries 7 3 7

Z Phosphoric Acid Production 0 1 0

CC Soda Ash Manufacturing 2 0 0

DD Use of Electric Transmission and Distribution Equipment 7 0 2

FF Underground Coal Mines 5 3 0

HH Municipal Solid Waste Landfills 2 1 1

II Industrial Wastewater Treatment 1 4 0

LL Suppliers of Coal based Liquid Fuels 0 0 5

NN Suppliers of Natural Gas and Natural Gas Liquids 1 0 0

OO Suppliers of Industrial Greenhouse Gases 4 1 0 0

RR Geologic Sequestration of Carbon Dioxide 1 0 0



### The change in burden for existing reporters was calculated for each subpart where a new data element was added, a data element was substantially revised (such that different data is required to reported), and where a data element was removed.

All costs to the regulated industry resulting f or the changes in Table 3 are labor costs (i.e., the cost of labor by facility staff to collect

, calculate, and submit information via e

- GGRT ). The change in technical labor hours associated with proposed revisions that add, revise, or remove reported data elements were calculated by multiplying the number of data elements that were added, revised, o r removed in each subpart (i.e., number of data elements added plus the
number of data elements revised

, minus the number of data elements removed) by the number of hours required to review each data element . EPA assumed 3 minutes of technical labor to
cal culate each data element using readily available data and to submit the value via e

- GGRT as part of the annual report

. Managerial and clerical labor hours were then estimated as 5% and 10% of the total technical hours required, respectively.

For each sub part except subparts A, C, and OO; the incremental change in the hourly labor was then multiplied by the current number of reporters for each subpart (for reporting year

### 8

2013) to obtain total annual hourly estimates by labor category. Because subparts A an d C apply to a large number of reporters , burden was estimated based on the number of reporters that
would be anticipated to be required to report each new data element

. For subpart OO, burden was
estimated based on the number of existing reporters under Part 98 that would report fluorinated
heat transfer fluids that are not also fluorinated GHGs

. For subpart A, the number of reporters wh o would be affected by each of the six new data
eleme nts was estimated as su mmarized in Table 3.2

.

### 9 Table 3.2 Number of Reporters Affected by New Data Elements in Subpart A

Data Element (s) No. Reporters Affected Rationale

40 CFR 98.3(i)( 3 ) and (5) : A notification to the Administrator that announces the cessation of reporting for the process or operation no later than March 31 of the year following such changes. 166 This notification is a one

- time reporting requirement submitted when a process or operation ceases reporting under Part 98. The number of reporters who would be required to report either 40 CFR 98.3(i)(3) or 40 CFR 98.3(i)(5) was determined by review ing the total number of prior year repor ts in which facilities identif ied ceasing operations , or for which facilities ceased reporting processes or operations. 40 CFR 98. 2 ( i )( 6 ) : If an entire facilit y or supplier is merged into another facility or supplier that is already rep orting GHG data under this part

, a notification to the Administrator that announces the discontinuation of reporting and the e

GGRT identification number of the reconstituted faci lity no later than March 31 of the year following such changes

. 51 The requirement to report the e

- GGRT facility ID under which emissions were previously report is required only for facilities or suppliers that have changed ownership in the reporting year and previously reported under Part 98. This requirement is a one

- time reporting requirement. The number of reporters affected was determined by review ing the number of facilities and suppliers that began reporting under a

new e

- GGRT ID in prior reporting y ears. 40 CFR 98.3(c)(4)(iii)(G) and 40 CFR 98.3(c)(5(ii) : For each reported fluorinated GHG and fluorinated heat transfer fluid (HTF), the chemical name. 319 The requirement to report the chemical name, CAS number or SRS number, and the linear chemical formula only applies to facilities and suppliers that are required to report fluorinated GHGs or fluorinated HTFs. This requires all reporters in subparts I, F, L, O, OO, DD, SS, and QQ to report two additional data elements. The number of reporte rs affected is the sum of all reporters for these subparts (based on RY2013). 40 CFR 98.3(c)(4)(iii)(G) and 40 CFR 98.3(c)(5(ii) : For each reported fluorinated GHG and fluorinated heat transfer fluid (HTF), the CAS registry or SRS number

. 40 CFR 98.3(c)(4)(iii)(G) and 40 CFR 98.3(c)(5(ii) : For each reported fluorinated GHG and fluorinated heat transfer fluid (HTF), the linear c hemical formula. 40 CFR 98.4(i)(6) : A list of the subparts that the owners and operators anticipate will be included in the annual GHG report. 310 The requirement to report the list of potentially applicable subparts is required only for an initial certificate of representation that is submitted by a facility or supplier that previously was not registered under Part 98. T he list of subparts is not being proposed to be required for a revised COR , and is a

one

- time requirement

. The number of reporters affected was determined by review ing the number of prior year repor ts in which new facilities submitted an initial certificat e of representation.



### For subpart C, the number of reporters who would be affected by each of the proposed
three new data elements was estimated as summarized in Table 3.3. See Section 4.2 of this document for additional information on the changes to subpart C.

### 10 Table 3.3 Number of Reporters Affected by New Data Elements in Subpart C
Data Element (s) No. Reporters Affected Rationale

40 CFR 98.36(c)(1)(iii) : For each aggregated group of units, the c umulative maximum rated heat input capacity of the
group

. 3,540 The requirement to report the cumulative maximum rated heat input capacity of aggregated groups of units and cumulative maximum rated heat input capacity of uni ts served by a common pipe applies only to those facilities which report using one of these configurations, where the highest maximum rated heat input capacity of any unit as greate r than or equal to 10 mmBtu/hr. T he number of reporters that would be requi red to report either 40 CFR 98.36(c)(1)(iii) or 40 CFR 98.36(c)(3)(ii) was determined by review ing the number of facilities that reported emissions for either an aggregated group of units or for units served by a common pipe in prior year reports. 40 CFR 98.36(c)(3)(ii) : For each group of units served by a common pipe, the

c umulative maximum rated heat input capacity of the units served by the common pipe

40 CFR 98.36(e)(2)(i)(B) : For the Tier 1 calculation methodology, the moisture content used to calculate the wood and wood residuals wet basis HHV for use in Equations C

- 1 and C

- 8

. 132 The requirement to report moisture content applies only to those facilities that calculate wet basis HHV for wood and wood residuals

. The number of reporters affected was determined by identify the number of facilities that reported for wood and wood residuals in the recent reporting year

.



### A review of existing fluorinated gas suppliers indicated that the revised reporting would most likely affect two to three suppl iers of fluorinated HTFs, rather than all current subpart OO
report ers, because all suppliers of these fluorinated HTF are believed to currently report

. No new reporters are expected as a result of this change.

To calculate labor costs, Bureau of Labor St atistics estimates were us ed in an approach consistent with the ICRs associated with the GHGRP currently approved by OMB. 1 

### For all subparts the labor rates are: $59.12 for technical workers, $77.23 for managers, and $31.35 for clerical support. These labor costs were applied to the total annual hour estimates for each labor category to obtain the total costs for each subpart. These costs are summarized in Table 3. 4 of
this document.

1 May 2011 National Industry

- Specific Occupational Employment and Wage Estimates ( http://www.bls.gov/oes/current/oessrci.htm ) and Employer Costs for Employee Compensation for June of 2011 ( http://www.bls.gov/news.release/archives/ecec_09082011.pdf ).

### 11 Table 3. 4 Labor Hours and Costs for New, Revised, and Removed Data Elements by Subpart

Item Subpart

A b A c A d A e C f C g E F G I O S V X Y Z CC DD FF HH II LL NN OO h RR Total
# Affected Facilities a 319 310 166 51 132 3,540 3 11 23 53 4 75 35 65 146 12 5 121 12 5 1,230 155 1 530 3 0 n/a

# New Data Elements 3 1 1 1 1 2 1 2 3 7 1 3 1 3 7 0 2 7 5 2 1 0 1 4 1 1 9 7

# Revised Data Elements 0 0 0 0 0 0 0 0 0 0 10 0 0 2 3 1 0 0 3 1 4 0 0 0 0 2 4

# Deleted Data Elements 0 0 0 0 0 0 0 0 0 0 3 0 0 0 7 0 0 2 0 1 0 5 0 0 0 1 8

Respondent Hours

Technical 48 16 8 3 7 177 0.15 1.10 3.45 18.55 1.60 11.25 1.75 16.25 21.90 0.60 0.50 30.25 50.00 123.00 38.75

- 0.25 26.50 6.00 0.00 6 09

Clerical 5 2 1 0 1 18 0.02 0.11 0.35 1.86 0.16 1.13 0.18 1.63 2.19 0.06 0.05 3.03 5.00 12.30 3.88

- 0.03 2.65 0.60 0.00 6 1 Managerial 2 1 0 0 0 9 0.01 0.06 0. 17 0.93 0.08 0.56 0.09 0.81 1.10 0.03 0.03 1.51 2. 50 6.15 1.94

- 0.01 1.33 0.30 0.00 30

Total 55 18 10 3 8 201 0.17 1.27 3.97 21.33 1.84 12.94 2.01 18.69 25.19 0.69 0.58 34.79 57. 50 141.45 44.56

- 0.29 30.48 6.90 0.00 7 01
Respondent Costs
Technical $ 2,829 $916 $ 491 $151 $390 $ 10,464 $9 $65 $ 204 $ 1,097 $95 $665 $103 $961 $1,295 $35 $30 $ 1,788 $2,9 56 $7,272 $2,291

- $15 $1,567 $355 $0 $ 36, 013

Clerical $ 150 $49 $ 26 $8 $21 $ 555 $0 $3 $ 11 $ 58 $5 $35 $5 $51 $69 $2 $2 $ 95 $15 7 $386 $121

- $1 $83 $19 $0 $1, 910 Managerial $185 $60 $32 $10 $25 $683 $1 $4 $13 $72 $6 $43 $7 $63 $85 $2 $2 $117 $193 $475 $150

- $1 $102 $23 $0 $2,352

Total $3,164 $1,025 $549 $169 $436 $11,703 $10 $73 $228 $1,226 $106 $744 $116 $1,074 $1,448 $40 $33 $2,000 $3,306 $8,132 $2,562

- $17 $1,752 $397 $0 $40,275

a The number of affected reporters for each subpart is based on the number of reporters for RY2013 , except where otherwise noted

. b The total number of affected facilities required to report subpart A data elements § 98.3(c )(4)(iii)(G) and § 98.3(c)(5)(ii) related to identifying the chemical name, CAS registry or SRS number

, and the linear chemical formula. Applicable to facilities [98.3(c)(4)(iii)(G)] and suppliers [98.3(c)(5)(ii)] tha t report under the following subparts: I, F, L, O, OO, DD, SS, and QQ.

c The number of affected facilities required to report the subpart A data element § 98.4(i)(6) related to listing subparts that will be included in their report; applicable only to thos e facilit ies or supplier s that previously was not registered under Part 98 ; affects 310 facilities per reporting year

. d The total number of affected facilities required to report either subpart A data element § 98.2(i) (3) or (5) related to notifying the Administrator the facility or supplier will cease reporting; applicable to 166 facilities.

e The number of affected facilities required to report the subpart A data element § 98. 2 ( i )( 6 ) for a notification to the Administrator that announces the discontinuation of reporting and the e

- GGRT identification number of the reconstituted facility ; applicable to 51 facilities.

f The number of affected facilities required to report t he subpart C data element § 98.36(e)(2)(i)(B) related to re porting moisture content; applicable to 132 facilities.

g The total number of affected facilities required to report either subpart C data element § 98.36(c)(1)(iii) or § 98.36(c)(3)(ii) related to reporting heat input capacity; applicable
to 3,540 facilities

. h Includes the number of existing reporters anticipated to be affected by the addition of new d ata elements to subpart OO (fluorinated HTF producers). N ote that 1 of the 41 new data elements in Table 3.1 would only apply to new reporters under subpart OO. Costs for new reporters under subpart OO are discussed in Section 3.2 of this document.

### 12

3.2 Revisions T hat Expand C urre nt A pplicability EPA is proposing 2015 Revisions that would expand the applicability of two subparts of Part 98, including V (Nitric Acid Production) and OO (Suppliers of Industrial Greenhouse Gases). These changes are anticipated to result in a small number of new reporters under Part 98 for each of these subparts.

3.2.1.1 Ide ntifying New Reporters For subpart V, EPA is proposing to change the definition of the source category to require reporting from all reporters that produce nitric acid, regardless of the nitric acid strength. The source category definition for subpart V in Part 98 is currently based on the New Source Performance Standard (NSPS) in 40 CFR Part 60, which is only applicable to weak nitric acid (specifically between 30 percent and 70 percent in strength). When the GHGRP was published in 2009, only one nitric ac id plant in the United States produced nitric acid greater than 70 percent in strength (i.e., strong nitric acid). In the interim, further research has indicated the existence of three other nitric acid trains capable of producing strong nitric acid, inclu ding one existing plant and two potential plants becoming operational as early as the end of 2015 (s ee the memorandum, “Re: Strong Nitric Acid Facilities in the U.S.” from Natalie Tang, EPA to Alexis McKittrick and Mausami Desai, EPA, dated January 29, 201 5, in Docket Id. No. EPA

- HQ

- OAR

- 20 15

- 0526 )

. Therefore, four new reporters are anticipated to report under subpart V as a result of the proposed changes. T here is no anticipated impact on a substantial number of small businesses as a result of these change s (see Section 4.11 of this document for a discussion of small entity impacts.)

For subpart OO, EPA is proposing two revisions to the definition of the source category

. First, EPA is proposing to include facilities that destroy 25,000 mtCO2e or more of ind ustrial greenhouse gases and/or fluorinated heat transfer fluids annually , but that do not currently report as a producer, importer, or exporter under the rule

. By requiring facilities that destroy fluorinated GHGs to report that destruction, an estimate d 5

- 10 destruction facilities would be newly required to report under subpart OO . This estimate is based on the number of facilities that report
destruction of ozone

- depleting substances (ODSs) to EPA under the Stratospheric Protection Program. Because fluor inated GHGs are chemically similar to ODSs, are manufactured and imported by many of the same facilities and companies that manufacture and import ODSs, and are used in many of the same applications as ODSs, the set of facilities destroying fluorinated
GHG s is likely to be similar to the set of facilities destroying ODSs. These facilities include hazardous waste treatment facilities that use a variety of different destruction technologies such as plasma arc and combustion. Facilities destroying very small q uantities of ODSs were excluded from the total because similar quantities of fluorinated GHGs appeared unlikely to equal or exceed the proposed 25,000 mtCO2e threshold (using an average GWP of 2000). For the

### 13

purposes of estimating burden, an average of 8 n ew reporters were assumed to be required to report under Part 98. T here is no anticipated impact on small businesses as a result of these changes (see Section 4.23 of this document for a discussion of small entity impacts.)

The proposed amendments would al so require facilities that produce, import, transform, export, or destroy fluorinated heat transfer fluids (FHTFs) that are not also fluorinated GHGs (under the subpart A definition) to report under subpart OO. Suppliers of fluorinated HTFs would be subjec t to the same thresholds as suppliers of fluorinated GHGs. That is, there would be no threshold for producers of fluorinated HTFs, but the threshold for importers, exporters, and destroyers of fluorinated HTFs would be 25,000 mtCO 2 

### e of fluorinated HTFs or GHGs . We anticipate that few, if any, suppliers of fluorinated HTFs would be required to begin reporting under this provision because all suppliers of fluorinated HTFs are believed to report under subpart OO already. One possible exception is facilities th at destroy but do not produce or import fluorinated HTFs, but this group of facilities is included in the set of destructi on facilities discussed above. Therefore, no additional reporters were assumed to be required to report based on the proposed changes. The costs for existing suppliers to report additional information for
fluorinated heat transfer fluids are accounted for in section 3.1 of this document.

3.2.1.2 Estimating Cost Impacts

The cost impacts for new reporters subject to subparts V and OO were calcul ated by multiplying the average costs per facility and the number of new facilities estimated to be subject to each subpart. Average costs per facility were calculated using data from the most recent information collection request for the GHG RP (May 2013) 2 

### and the amendments to reporting and recordkeeping requirements promulgated in October 2014

. 3



### Appendix G to the most recent information collection request for the GHG RP was used to obtain the first year average cost per facility that is incurred from rep orting under subparts V
and OO. One

- time costs for respondents from Appendix G

- 3 ($1,100 per facility , $ 2011) were added to the subpart V ($19,700 per facility, $ 2011) and subpart OO ($3,400 per facility , $ 2011 dollars) costs provided in Appendix G

- 3, resp ectively. 4

2 Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program. OMB Control No. 2060

- 0629

. EPA ICR No. 2300.10 . May 2013.

3 Supporting Statement: Revisions to Reporting and Recordkeeping Requirements, and Proposed Confidentiality Determinations under the Greenhouse Gas Reporting Progr am, OMB control number 2060

- 0629, ICR number 2300.12. August 2013.

4 One

- time costs from Appendix G

- 3 of the Supporting Statement apply to all Part 98 reporters and r eflect the initial
coverage determination (ICR No. 2300 .02) and burden for understanding t he "Reconsideration" rule (ICR No. 2300

. 06 ) that would apply to first

- time reporters.

### 14

Cost details from Exhibit 6.1 of the most recent information collection request for the
GHG RP (U.S. EPA, 2013) were used to determine the subsequent years average cost per facility for subpart V ($16,500 per facility in 2011 dollars) and subpar t OO ($3,300 per facility in 2011 dollars) . These average costs per facility include labor costs (i.e., the cost of labor by facility
staff to meet the rule’s information coll ection requirements) and non

- labor (capital, and operation and maintenance) costs . Additional details of the data, methods, and assumptions underlying these costs are documented in the May 2013 information collection request

. For subpart V reporters, average first year and subsequent year costs per facility also
include costs obtained from Table 1 of the information collection request for the “Revisions to Reporting and Recordkeeping Requirements, and Proposed Confidentiality Determinations under the Greenhouse Gas Reporting Program” (August, 2013). 5 

### These average costs per facility
in clude first year labor costs to comply with initial training for the Inputs Verification Tool ($66 per facility) and first year and subsequent year costs to comply with annual reporting of new data elements ($33 per facility).

To obtain costs for new reporters under subparts V and OO, the average cost per facility was applied to the number of new facilities anticipated to report under the proposed
amendments. Table 3. 5 summarizes the impacts to new facilities required to report subpart V and
OO emissions.

Table 3. 5

. Cost Impacts to Reporters that would be Newly Subject to Subpart s V or OO

Subpart Number of

New Reporters Due to Applicability Revisions Incremental Cost Impact By Facility (2011$ per year) Incremental Cost Impact For All New Reporters (2011$ per year)

First Year a Subsequent

Years b First Year a Subsequent Years b

V

– Nitric Acid Production 4 $20, 886 $16, 601 $ 83, 5 44 $ 66, 403

OO

– Industrial GHG Suppliers 8 $ 4, 527 $ 3, 327 $ 36, 215 $ 26, 612

Total Incremental Costs from Changes to Applicability $ 119, 759 $ 9 3, 015

a First year total cost, and cost per facility, are based on: 1. Th e “One

- Time Costs” from the current burden & cost table in Appendix G

- 3 of the Supporting Statement Part A: Information Collection Request for t he Greenhouse Gas Reporting Program (U.S. EPA, 2013)

. L abor and O&M costs were updated to 2011 dollars using the Bureau of Labor Statisti cs Employment Cost Index ($1,100 per facility ). 2. T he subpart

- specific total labor, capital, and O&M costs for “V: Nitric Acid Production” and “OO. Industrial Gas Suppliers” from the “C urrent B urden and C ost ” table in Appendix G

- 3, respectively. These costs and the “One

- Time C osts” are based on an estimated 45 respondents (in lieu of 37) for subpart V and 167 respondents (in lieu of 49) for subpart OO. These costs were updated to 2011 dollars

5 See Greenhouse Gas Reporting Program (Revisions to Reporting and Recordkeeping Requirements, and Proposed Confidentiality Determinations Proposed Rule); OMB control n umber 2060

- 0629; ICR number 2300.12.

### 15 using the Bureau of Labor Statisti cs Employment Cost Index and Chemical Engineering Pl ant Cost Index (CEPCI). ($19,700 per subpart V facility and $3,400 per subpart OO facility. ) 3. For subpart V, the estimate includes first year labor costs to comply with initial training for the Inputs Verification Tool ($66 per facility) and first year cos ts to comply with annual reporting of new data elements ($33 per facility) per ICR 2300.12.
b Th ese data w ere extracted from Exhibit 6 .1 of the Supporting Statement Part A: Information Collection Request for t he Greenhouse Gas Reporting Program (U.S. EPA, 2013).



### 3.3 Revisions T hat E xpand C urrent Monitoring R equirements EPA is proposing changes to the monitoring requirements of subpart FF of Part 98 (Underground Coal Mines) . Currently, reporters have the option to use data from MSHA quarterly inspection repor ts, independently collect quarterly grab samples, or use continuous emissions monitoring (CEMS). EPA is proposing to remove the option to allow MSHA quarterly inspection reports to be used as a source of data for monitoring methane liberated from
ventilati on systems . Instead, facilities would be required to collect their own grab samples or to

use CEMS . EPA is also proposing to increase the frequency of collected grab samples from quarterly to monthly.

A cost analysis was performed by Advanced Resources Int ernational, Inc. (ARI) to estimate the burden to comply with the cost of quarterly, monthly and weekly grab samples for
an individual mine and on a nationwide basis. 6 

### The analysis also estimates the costs for facilities
that would use CEMS. The ARI analys is accounts for differences in costs between mines that already take quarterly grab samples and those that use MSHA data or are new reporting mines. Currently, about 50 percent of subpart FF reporters collect quarterly gas samples. For reporters
that are c urrently collecting quarterly data, the ARI analysis assumes an increase from quarterly sampling (4 samples/year) to a monthly basis (an additional 8 samples). For mines that currently
use MSHA data and new reporting mines , the annual incremental costs for taking grab samples was estimated as the cost of taking the samples, less the avoided cost of obtaining, interpreting and reporting MSHA data.

For the proposed rulemaking, the incremental costs to the regulated industry resulting
from changes to the moni toring requirements for Underground Coal Mines are based on the cost methodology and assumptions provided by ARI for the collection of independent monthly grab samples in ventilation air. It was assumed that facilities would not install a CEMS as a result of the monitoring changes. The costs resulting from removing the use of MSHA quarterly data and changing the collection frequency of grab samples from quarterly to monthly include additional labor costs, capital costs (e.g., the costs of anemometers or sample kits, for reporters that are not currently conducting sampling), and the cost asso ciated with gas sample analysis . Hourly labor

6 See “ARI Estimate of Burden to Comply with Proposed Changes to 40 CFR 98.324(b)(1)”, Advanced Resources International, Inc. , June 11, 2015.

### 16

costs were estimated based on the number of labor hours for developing the sampling methodology and purchasing the device s, and the number of hours required for sampling. For mines that already take grab samples, it was assumed that they have an adequate monitoring plan in place with the necessary equipment, thus there are no additional labor hours associated with developing a methodology and purchasing equipment and no additional capital costs.

Using the cost methodology and assumptions provided by ARI, l abor, operating and maintenance (O&M), and capital costs were estimated in $2011. To calculate labor costs, labor
rates p ublished by the Bureau of Labor Statistics were used

. T he labor rates are: $59.12 for technical workers, $77.23 for managers, and $31.35 for clerical support. These labor rates were applied to the total annual hour estimates for each labor category to obta in the total incremental

costs. The O&M and capital costs are based on costs from the original 2009 rule, inflated from $2006 to $2011 using the Consumer Price Index.

Tables 3.6 and 3.7 of this document show the annual incremental costs from taking
monthl y grab samples for individual mines and the annual industry

- wide cost burden.

Table 3.6 Annual Incremental Cost Per Mine for Monthly Sampling Cost Category Year 1 Subsequent Years

Annual i ncremental cost per mine where the mine is currentl y taking quarterly grab samples
Labor a $6,621 $6,621

O & M b $13,392 $13,392 Capitol c $0 $0

Total $20,013 $20,013
Annual i ncremental cost per mine where the mine is currently using MSHA data and new reporting mines
Labor a $23,902 $14,534

O & M b $20,088 $20,088 Capitol c $4,463 $4,463

Total $48,453 $39,085

a Labor costs include costs for developing sampling methodology, accompanying inspectors, send ing samples, and purchasing devices. For mines that already take grab samples, it was assumed that they have already developed a methodology and have an adequate monitoring plan in place with the necessary equipment; thus there are no additional labor hours associated with developing a method ology or purchasing devices

. b O&M costs include the cost for gas analysis for 3 samples on a monthly basis (12 samples). W here a mine is already taking qua r terly grab samples, costs were adjusted to correspond with the additional number of samples that

w ould be incurred if monthly samples were required (9 samples)

. d Capital costs include the cost of 4 air sample kits and 2 anemometers. Where a mine is already taking grab samples, it was assumed that all necessary equipment was in place; thus there are no additional capital costs

a ss ociated with purchasing equipment

.

### 17

Table 3.7 Annual Ind u s try

- wide Incremental Cost Burden for Monthly Sampling

Current Monitoring Number of Mines Year 1 Subsequent Years

Annual incremental cost for mines already taking quarterly grab samples

60 $1,200,800 $1,200,800 Annual incremental cost for mines currently using MSHA data and new reporting mines

65 $3,149,439 $2,540,544
Total Cost 125 $4,350,239 $3,741,344 Weighted Average Annual Cost Per Mine $34,801 $29, 931



### 4.0 IMPACTS BY INDIVIDUAL SUBPAR T

Th is section describes the impacts to reporters under each subpart that is proposed for
revision in the 2015 Revisions

. Specifically, this section summarizes for each subpart :

1) S ubstantive techni cal revisions that impact burden . This includes revisions to reporting requirements

, revisions that expand applicability , and revisions that expand monitoring provisions for which costs were estimated in Section 3.0 of this document. This section provides additional information on the se revisions (e.g., lists new, revised, or removed reporting requirements).

2) S ubstantive technical revisions that are anticipated to have no or minimal impact on
burden

. This includes revisions that are intended to streamline the rule requirements,
othe r technical amendments that would improve the quality of the rule or better align the rule with industry operations , and clarifications. This section provides a brief description of the revisions and an explanation of the impact on burden.

The remaining le ss substantive minor corrections, clarifications, and harmonizing
revisions are summarized in the memorandum, “ Table of 2015 Revisions to the Greenhouse Gas Reporting Rule ” ( “ Table of Revisions ” )

, available in the docket for this rulemaking . T hese changes are expected to result in no impact on the burden incurred by reporters.

4.1 Subpart A

– General Provisions Revisions to Subpart A that Impact Burden

. EPA is proposing revisions that would add
six new data elements to subpart A , as shown in Table 4.1

. These data elements are information that reporters are expected to have readily available, therefore, burden was estimated as
described in Section 3.1 of this document.

### 18 Table 4.1 New, Revised, or Removed Data Elements in Subpart A

Citation Data Element (s) New, Revised, or Removed 98.3(i)(3) and (5) A notification to the Administrator that announces the cessation of

reporting for the process or operation no later than March 31 of the year following such changes. New

98. 2 ( i )( 6 ) If an entire facility or supplier is merged into another facility or

supplier that is already rep orting GHG data under this part

, a notification to the Administrator that announces the discontinuation of reporting and the e

- GGRT identification number of the reconstituted facility no later than March 31 of the year following such changes

. New

98.3(c)(4)(iii)(G) ; 98.3(c)(5 ) (ii) For each reported fluorinated GHG and fluorinated heat transfer

fluid (HTF), the chemical name. New

98.3(c)(4)(iii)(G) ; 98.3(c)(5(ii) For each reported fluorinated GHG and fluorinated heat transfer

fluid (HTF), the CAS registry or SRS number

. New

98.3(c)(4)(iii)(G); 98.3(c)(5(ii) For each reported fluorinated GHG and fluorinated heat transfer

fluid (HTF), the linear c hemical formula. N ew

98.4(i)(6) A list of the subparts that the owners and operators anticipate will

be included in the annual GHG report. New



### Revisions to Subpart A with No or Minimal Impact on Burden

. EPA is proposing several amendments to simplify and streamline the requirements of subpart A that are expected to have no impact or a minimal impact (decrease) on burden.

 EPA is proposing to revise 40 CFR 98.2(i) to clarify when “ off

- ramp ” provisions apply to suppliers and direct emitters

. This change is a clarification to the existing requirements and is not expected to have an impact on burden.

 EPA is proposing to revise 40 CFR 98.2(i)(3) to clarifying when “off

- ramp” provisions apply for :

 A process or operation that ceases operation in the reporting years

 A bandoned un derground coal mines

 F acilities and suppliers where the operations are changed such that a
process or operation no longer meets the “ Definition of Source Category ”

. These provisions are anticipated to generally decrease burden for reporters by specifying that reporters are no longer required to report for a particular process or operation, but would require the owner or operator to submit a one

- time notification to the Administrator that announces the cessation of reporting and explains the reasons for the cessation of operation

.

 EPA is proposing to amend 40 CFR 98.3(h)(4) to remov e the requirement that a reporter must submit a request for an extens ion beyond 75

- days at least 5

- days prior to their current due date. The proposed change would streamline the reporting requirements, however, because the reporter would still be required to submit a

### 19 request for an extension prior to the end of their curren t due date, no change in burden is expected.

 EPA is proposi ng to a mend the definition s of “gas collection system” and “ v entilation hole or shaft” in 40 CFR 98.6. The proposed change s are clarifications and would have no impact on burden.

 EPA is also proposing several minor corrections and clarifications to subpart A of Part 98, including clarifications to definitions, editorial changes, and clarifications to reporting requirements. These minor revisions are summarized in the Table of Revisions , a nd wo uld have no impact on burden.

4.2 Subpart C

- General Stationary Fuel Combustion Sources Revisions to Subpart C that Impact Burden. The proposed revisions would add three
new data element s to s ubpart C, as shown in Table 4.2. These data elements are information that reporters are expected to have readily available, therefore, burden was estimated as described in
Section 3.1 of this document.

Table 4.2 New, Revised, or Removed Data Elements in Subpart C

Citation Data Element (s) New, Revised, or Remov ed 98.36(c)(1)(iii) For each aggregated group of units, the c umulative maximum

rated heat input capacity of the group

. New

98.36(c)(3)(ii) For each group of units served by a common pipe, the c umulative

maximum rated heat input capacity of the units served by the common pipe New

98.36(e)(2)(i)(B) For the Tier 1 calculation methodology, the moisture content

used to calculate the wood and wood residuals wet basis HHV for use in Equations C

- 1 and C

- 8

. New



### Revisions to Subpart C with No or Minimal Impact on Burden

. EPA is proposing revisions to the requirements of subpart C to 1) clarify the reporting requirements when HHV is received less frequently than monthly for certain sources, 2) streamline the conversion factors
used to convert short tons to metric tons, and 3) to revise Tables C

- 1 and C

- 2 to more clearly define emission factors for certain petroleum products. These changes are minor clarifications of the existing rule requirements, and would present no significant impact on burden. EPA is al so proposing minor corrections and clarifications to subpart C of Part 98, including editorial changes. These minor revisions are summarized in the Table of Revisions, a nd would have no impact on burden.

4.3 Subpart E

– Adipic Acid Production

Revisions to Sub

part E that Impact Burden

. EPA is proposing revisions that would add one new data element to subpart E , as shown in Table 4.3

. This data element requires

### 20

information that reporters are expected to have readily available, therefore, burden was estimated

as described in Section 3.1 of this document.

Table 4.3 New, Revised, or Removed Data Elements in Subpart E

Citation Data Element (s) New, Revised, or Removed 98. 56(f) Date of installation of abatement technology. New



### Revisions to Subpart E with No or Minimal Impact on Burden

. EPA is proposing one amendment to simplify and streamline the requirements of subpart E. EPA is proposing to revise 40 CFR 98.53(a)(2) to conditionally remove the annual approval request by the reporter and the annual request appr oval by EPA for reporters us ing an alternative method to calculate nitrous oxide (N 2 

### O) emissions from the production of adipic acid

, where the method has not changed from the previous reporting year

. T his proposed change is anticipated to generally reduce burden
to reporters using the alternative calculation method, however, t he reporter would be required to notify EPA that they are using an already approved alternative testing method when they submit their annual report. By requiring requests only for new approvals or for methods that have changed since prior approval, EPA burden required to review and approve the methods would
also be reduced. Because this change applies only to reporters who elect to use an alternative

c alculation method, this change is expected to have no significant impact on burden. There are no other changes to subpart E in the proposed rule.

4.4 Subpart F

– A luminum Production Revisions to Subpart F that Impact Burden

. EPA is proposing two new data elem ents in subpart F, as shown in Table 4.4. These data elements are information that reporters are expected to have readily available, therefore, burden was estimated as described in Section 3.1 of this
document.

Table 4.4 New, Revised, or Removed Data Elements in Subpart F

Citation Data Element (s) New, Revised, or Removed 98. 66(c)(2) The following PFC

- specific information on an annual basis: (2)

Anode effect minutes per cell

- day (AE

- mins/cell

- day), anode effect frequency (AE/cell

- day), anode effect duration (minutes). (Or anode effect overvoltage factor ((kg CF4/metric ton Al)/(mV/cell day)), potline overvoltage (mV/cell day), current efficiency (%).) New

98. 66(c)(3) Smelter

- specific slope coefficient (or overvoltage emission factors) New



### Revisions to Subpart F with No or Minimal Impact on Burden

. EPA is also proposing

one minor c orrection to subpart F of Part 98 . Th is minor revision i s summarized in the Table of
Revisions

, and would have no impact on burden.

### 21

4.5 Subpart G

– Ammonia Manufacturing Revisions to Subpart G that Impact Burden

. EPA is proposing to add three data
elements to improve the quality of data collected under subpart G , as shown in Table 4.5

. These data elements are information that reporters ar e expected to have readily available, therefore,
burden was estimated as described in Section 3.1 of this document.

Table 4.5 New, Revised, or Removed Data Elements in Subpart G

Citation Data Element (s) New, Revised, or Removed 98.76(a)(3) Annual ammonia production (metric tons, sum of all process

units reported within subpart G). New

98. 76(b)(2) Annual quantity of each type of feedstock consumed for

ammonia manufacturing New

98. 76 ( b )( 7 ) Annual average carbon content of each type of feedstock. N ew



### Revisions to Subpart G with No or Minimal Impact on Burden

. EPA is also proposing
minor corrections and clarifications to subpart G

. This includes proposed revisions to 40 CFR
98.74 (f) and 40 CFR 98.76(b)(15) to clarify EPA’s intentions related to the reporting of annual ammonia production and annual methanol production. The proposed amendments are clarifications and would have no impact on burden. There are no additional proposed changes to subpart G.

4.6 Subpart I

– Electronics Manufacturing Revisions to Subpart I that Impact Burden.

The proposed amendments would add 7 data reporting requirements to the content of the
annual report for subpart I reporters, as shown in Table 4.6 . These data elements are information that reporters are expected to have readily available, therefore, burden was estimated as
described in Section 3.1 of this document.

Table 4.6 New, Revised, or Removed Data Elements in Subpart I

Citation Data Element (s) New, Revised, or Removed For the triennial technology report, for any utilization, by

- product formation rate, and/or destruction or removal efficiency data submitted, the... 98.96(y)(2)(iv) M ethods used for the measurements. New 98.96(y)(2)(iv) W afer size. New 98.96(y)(2)(iv) Film type being manufactured. New 98.96(y)(2)(iv) S ubstrate type. New 98.96(y)(2)(iv) L inewidth or technology node. New 98.96(y)(2)(iv) Process type or process subtype for chamber clean

processes

. New

98.96(y)(2)(iv) I nput gases used and measured

. New

### 22

Revisions to Subpart I with No or Minimal Impact on Burden

. EPA is proposing to revise Equation I

- 24 to incorporate two changes :

 Revise the equation so that the average fraction destroyed or removed is weighted by the estimated uncontrolled emissions of that gas from different process types, instead of calculating the weighted

- average fraction of gas destroyed or removed weighted by the consumption of that gas in different produces types.

 Create a second equation (Equation I

- 24B) to calculate the weighte d

- average fraction of fluorinated GHG byproduct gas k destroyed or removed in abatement systems in each fab using the stack testing methodology.

The revisions to Equation I

- 24 would not require reporters to collect new data or inputs, therefore, there is no anticipated increase in burden from the proposed changes.

EPA is also proposing several minor corrections and clarification to subpart I of Part 98, including editorial changes, harmonizing changes, and clarifications to reporting requirements.
These mi nor revisions are summarized in the Table of Revisions and would have no impact on
burden.

4.7 Subpart N

– Glass Production EPA is proposing to clarify that a default value of 1.0 can be used for the fraction of
calcination and the carbonate mass fraction for each carbonate type contained in the raw materials charged to the furnace. The proposed amendments would also revise 40 CFR
98. 144(b), 40 CFR 98. 144(c), 40 CFR 98. 144(d), 40 CFR 98.146(b)(5), and 40 CFR 98.146(b)(7) to clarify that no further testing is re quired if the default value of 1.0 is used. EPA
is also proposing minor corrections and clarification to subpart N of Part 98 , which are summarized in the Table of Revisions . None of the proposed changes to subpart N would have an impact on burden.

4.8 Subpart O

– HCFC

- 22 Production and HFC

- 23 Destruction Revisions to Subpart O that Impact Burden. EPA is proposing two revisions to subpart O to collect more accurate and informative data: (1) r einstate reporting of the method
used to calculate the revised destru ction efficiency, and (2) require facilities to report HCFC

- 22 production and HFC

- 23 emissions for each HCFC

- 22 production process rather than for the
facil ity as a whole. The proposed amendments would add one new reporting requirement

, revise
10 existing reporting requirements

, and remove three reporting requirements as shown in Table
4.7. The new and revised data elements are information that reporters are expected to have readily available. Burden was estimated for these data elements as described in Se ction 3.1 of
this document.

### 23 Table 4.7 New, Revised, or Removed Data Elements in Subpart O

Citation Data Element(s) New, Revised, or Removed

98.156(a)(1) The HCFC

- 22 production facility shall report the following

information from each HCFC

- 22 production process: Annual mass of HCFC

- 22 produced in metric tons. Revised from a facility

level basis to a process

level basis

98.156(a)(3) The HCFC

- 22 production facility shall report the following

information from each HCFC

- 22 production process: Annual mass of reactants fed into the process in metric tons of
reactant. Revised from a facility

level basis to a process

level basis

98.156(a)(4) The HCFC

- 22 production facility shall report the following

information from each HCFC

- 22 production process: Mass (in metric tons) of materials other than HCFC

- 22 and HFC

23 (i.e., unreacted reactants, HCl and other by

- products) that occur in more than trace concentrations and that are permanently removed from the process. Revised from a facility

level basis to a process

level basis

98.156(a)(5) The HCFC

- 22 production facility shall report the following

information from each HCFC

- 22 production process: The method for tracking startups, shutdowns, and malfunctions and HFC

- 23 generation/emissions during these events. Revised from a facility

level basis to a process

level basis

98.156(a)(6) The HCFC

- 22 production facility shall report the following

information from each HCFC

- 22 production process: The names of facilities to which any HFC

- 23 was sent for destruction Rev ised from a facility

level basis to a process

level basis

98.156(a)(6) The HCFC

- 22 production facility shall report the following

information from ea ch HCFC

- 22 production process: The addresses of facilities to which any HFC

- 23 was sent for destruction Re vised from a facility

level basis to a process

level basis

98.156(a)(6) The HCFC

- 22 production facility shall report the following

information from each HCFC

- 22 production process: The quantities of HFC

- 23 (metric tons) sent to each. Revised from a facility

level basis to a process

level basis

98.156(a)(11) The HCFC

- 22 production facility shall report the following

information from each HCFC

- 22 production process: Annual mass of HFC

- 23 emitted in metric tons. Revised from a facility

level basis to a process

level basis

98.156(a)(12) The HCFC

- 22 production facility shall report the following

information from each HCFC

- 22 production process: Annual mass of HFC

- 23 emitted from equipment leaks in metric
tons. Revised from a facility

level basis to a pro cess

level basis

98.156(a)(13) The HCFC

- 22 production facility shall report the following

information from each HCFC

- 22 production process: Annual mass of HFC

- 23 emitted from process vents in metric tons. Revised from a facility

level basis to a process

l evel basis

98.156(d) Method used to calculate revised destruction efficiency,

specifying whether § 98.154(l)(1) or (l)(2) has been used for the calculation New

98.156(d)(2) (existing) Concentration (mass fraction) of HFC

- 23 at the outlet of the

destruction device. Removed

98.156(d)(3) (existing) Flow rate at the outlet of the destruction device in kg/hr. Removed

98.156(d)(4) (existing) Emission rate (in kg/hr) calculated from paragraphs (d)(2)

and (d)(3) of this section. Removed

### 24

4.9 Subpart Q

– Iron and Steel Production EPA is proposing two minor amendments to subpart Q. U nder 40 CFR 98.172(b)

, facilities that report to subpart Q are referred to provisions in subpart Y for reporting CO 2 

### , CH 4 

### , and N 2 

### O emissions from flares. Section 4.13 of this m emo describes proposed revisions to subpart Y that would clarify that facilities should exclude pilot gas from the flare gas GHG
emissions. The quantity of GHG emissions associated with pilot gas is very small relative to the
total GHG emissions from a fla re at iron and steel facilities , and clarifying that these facilities do
not need to monitor pilot gas may minimally reduce burden on some facilities

. EPA is also proposing one minor corrections to subpart Q of Part 98 , which is summarized in the Table of
Revisions . None of the proposed ch anges to subpart Q would have a significant impact on
burden.

4.10 Subpart S

– Lime Manufacturing EPA is proposing to revise subpart S to require reporting of three new data elements , as shown in Ta ble 4.8. These data elements are information that reporters are expected to have readily available, therefore, burden was estimated as described in Section 3.1 of this document. There are no other changes to subpart S in the proposed rule.

Table 4.8 New, Revised, or Removed Data Elements in Subpart S

Citation Data Element(s) New, Revised, or Removed 98.196(b)(19) Annual emission factors for each lime product type produced

. New 98.196(b)(20) Annual emission factors for each calcined byproduct or waste

by lime type that is sold

. New

98.196(b)(21) Annual average results of chemical composition analysis of

each type of lime product produced and calcined product or waste sold

. New



### 4.11 Subpart V

– Nitric Acid Production Revisions to Subpart V that Impact Burden

. EPA is proposing two amendments to subpart V that would impact burden , including revisions to the definition of the source category
that affect s the applicability of Part 98 to certain ni tric acid production facilities and the addition of one reporting r equirement.

Revisions to applicability. EPA is proposing to change the definition of the source category in 40 CFR 98.220 to require reporting from all reporters that produce nitric acid, regardless of the nitric acid strength. These changes are anticipate d to result in four new reporters under subpart V, which would result in an increase in burden for this subpart. The methodology for determining new reporters and the cost impacts for n ew reporters subject to subpart V are described in Section 3. 2 of this document.

### 25

Revisions to reporting requirements. The EPA is proposing the addition of one data
element to subpart V as shown in Table 4.9. This data element requires information that reporters are expected to have readily available, therefore, burden was es timated as described in Section
3.1 of this document.

Table 4.9 New, Revised, or Removed Data Elements in Subpart V

Citation Data Element (s) New, Revised, or Removed 98. 226(h) Date of installation of abatement technology. New



### Revisions to Subpart V with No or Minimal Impact on Burden

. EPA is proposing to
revise 40 CFR 98.22 3(a)(2) to conditionally remove the annual approval request by the reporter and the annual request approval by EPA for reporters that use an alternative method to calculate
nitrous oxide (N 2 

### O) emissions f rom the production of nitric acid, where the method has not changed from the previous reporting year. T his proposed change is anticipated to generally
reduce burden to reporters using the alternative calculation method, however, t he reporter would be required to notify EPA that they are using an already approved alternative testing method in their submittal of the annual report

. By requiring requests only for new approvals or for methods that have changed since prior approval, EPA bu rden required to review and approve the methods
would also be reduced. Because this change applies only to reporters who elect to use an alternative calculation method, this change is expected to have no significant impact on burden.

There are no addition al changes to subpart V in the proposed rule.

Small Entity Impact Analysis

. The small entity economic impact for nitric acid facilities was measured using the “sales tests” approach (represented as cost

- to

- receipt ratios) for the
NAICS code associated with the affected subpart in the Regulatory Impact Analysis for the GHG Reporting Rule . The same approach is used in this analysis for the additional facilities subject to subpart V due to the revisions. If the ratio of rule implementation cost to sales is les s than 1
percent , the impact is not considered to be significant. 7



### Based on the 20 12 economic census database published by U.S. Bureau of the Census, the receipts (sales), number of establishments, and the average receipts for different size s of Nitrogeno us Fertilizer Manufacturing facilities ( with a NAICS code of 325311) are summarized
in Table 4.10 . The average receipts information is adjusted from 20 12 dollars to 2011 dollars based on the consumer price index published by Bureau of Labor Statistics.

7 U.S. EPA. Regulatory Impact Analysis for the Mandatory Reporting of Greenho use Gas Emissions Final Rule (GHG Reporting). See Docket ID: EPA

- HQ

- OAR

- 2008

- 0508

- 2229. September 2009.

### 26

Table 4.10 Receipts, Number of Establishments, and Average Receipts for Nitrogenous Fertilizer Manufacturing (NAICS code of 325311)

Owned by Enterprises with:

1

- 19 Employees 20

- 99

Employees 100

- 499

Employees 500

- 999

Employees 1,000

- 1,499

Employees Receipts (2012$) $494,368,000 $558,945,000 $59,915,000 $97,966,000

- (a)
Number of Establishments 95 25 5 8 7 Average Receipts for Each Establishment (2012$) $5,203,874 $22,357,800 $11,983,000 $12,245,750

- Average Receipts for Each Establishment (2011$) $5,102,356 $21,921,643 $11,749,235 $12,006,859

- (a) Note from 2012 economic census database

- Data withheld and value set to 0 to avoid disclosing data for individual businesses.



### According to the cost information listed in Table 3.5 , the rule implementation costs for subpart V are $20,886 for the first year and $16,601 for subsequent years (in 2011 dollars). The sales tests (cost

- to

- receipt ratios) results are shown in Table 4.11 for the first year and subsequent

years.

Table 4.11 Sa les Tests for Subpart V F acilities Owned by Enterprises with:

1

- 19 Employees 20

- 99

Employees 100

- 499

Employees 500

- 999

Employees 1,000

- 1,499

Employees
Sales Test

- First Year 0.41% 0.10% 0.18% 0.17%

- Sales Test

- Subsequent Years 0.33% 0.08% 0.14% 0.14%

-



### The results in Table 4.11 show that the costs for the rule revisions for facilities subject to subpart V are below 1 percent of the sales for all size of Nitrogenous Fertilizer Manufacturing
facilities with a NAICS code of 325311. Therefore, it was determined that there is not a significant impact on a substantial number of small businesses subject to reporting under subpart

V as a result of this action.

4.12 Subpart X

– Petrochemical Production Revisions to Subpart X that Impact Burden. EPA is proposing to amend the subpart X reporting requirements add three new data elements and to revise two data e lements, as shown in
Table 4. 12 . These data elements are information that reporters are expected to have readily
avail able, therefore, burden was estimated as described in Section 3.1 of this document.

### 27 Table 4. 1 2 New, Revised, or Removed Data Elements in Subpart X
Citation Data Element(s) New, Revised, or Removed 98.246(a)(5) If you use the mass ba lance methodology in §98.243(c):

Annual quantity of each type of petrochemical produced from each process unit (metric tons). If your petrochemical process is an integrated ethylene dichloride and vinyl chloride monomer process, report either the measured ethylene dichloride production (metric tons) or both the measured quantity of vinyl chloride monomer production (metric tons) and an estimate of the ethylene dichloride production (metric tons). New

98.246(a)(14) Annual average of the measurements of the carbon

conten t of each feedstock and product: (i) For feedstocks and products that are gaseous or solid, report this quantity in kg carbon per kg of feedstock or product. (ii) For liquid feedstocks and products, report this quantity either in units of kg c arbon per kg of feedstock or production or kg C per gallon of feedstock or product. New

98.246(a)(15) For each gaseous feedstock and product, the annual

average of the measurements of molecular weight in units of kg per kg mole. New

98.246(b)(3) For CEMS used on stacks that are not used on stationary

combustion units, report the information required under §98.36(b)(6), (b)(7), (b)(9)(i), (b)(9)(ii) and (e)(2)(vi). Revised to clarif y the information to be reported

.
98.246(b)(8) If you measure emissions in accordance with

§98.243(b): Annual quantity of each type of petrochemical produced from each process unit (metric
to ns). If your petrochemical process is an integrated ethylene dichloride and vinyl chloride monomer process, report either the measured ethy lene dichloride production (metric tons) or both the measured quantity of vinyl chloride monomer production (metric tons) and an estimate of the ethylene dichloride product (metric tons). Revised to allow operators of an integrated ethylene dichloride and vinyl chloride

monomer process to report either the measured quantity of EDC produced or both the measured quantity of VCM and an estimate of the amount of EDC produced as an intermediate in the process

.



### Revisions to Subpart X with No or Minimal Impact o n Burden

. EPA is proposing several amendments to simplify and s treamline the requirements of subpart X. U nder 40 CFR 98.243(c), facilities that report to subpart X are referred to provisions in subpart Y for reporting
CO 2 

### , CH 4 

### , and N 2 

### O emissions from flares. S ection 4 .1 3 of this memo describes proposed revisions to subpart Y that would clarify that facilities should exclude pilot gas from the flare gas
GHG emissions. T he quantity of GHG emissions associated with pilot gas is very small relative to the total GHG emissions from a flare at petrochemical facilities, and clarifying that these
facilities do not need to monitor pilot gas may minimally reduce burden on some facilities

.

EPA is also proposing to revise s ubpart X to clarify how i ntegrated EDC manufacturers would perform the mass balance calculations. Subpart X currently requires integrated EDC manufacturers to perform the mass balance around operations involved in the production of the

### 28

EDC, including situations where EDC is produc ed as an intermediate in the production of VCM. Under the existing rule, integrated EDC and VCM manufacturers could incur burden from modifying the ir process es to enable measurement of an intermediate EDC stream

. EPA is proposing to revise 40 CFR 98.240(a) to allow integrated EDC manufacturers to perform the mass balance over the entire integrated process. The proposed amendments are anticipated to reduce the compliance burden by not requiring monitoring equipment and/or sampling and analysis of an intermediate EDC stream. A few facilities may have a liquid waste stream from the VCM operations that is not combusted that would need to be measured and included in the
mass balance. The potential increase in burden for measurement of these streams is expected to be more than offset by the reduction for not measuring the intermediate EDC stream because not all facilities will have a liquid waste stream that is not combusted, and a waste stream is an output that would be m ore readily measured than an intermediate that is not stored.

EPA is also proposing several minor correction s and clarification to subpart X of Part 98, including editorial changes, harmonizing changes, and clarifications to reporting requirements.
These m inor revisions are summarized in the Table of Revisions and would not impact burden for reporters

.

4.13 Subpart Y

– Petrochemical Production

Revisions to Subpart Y that Impact Burden

. The proposed changes to subpart Y would amend the reporting requirements to add seven data elements, revise three data elements, and remove seven data elements, as shown in Table 4. 13

. The new and revised data elements are information that reporters are expected to have readily available. B urden was estimated for these
data elemen ts as described in Section 3.1 of this document.

Table 4. 1 3 New, Revised, or Removed Data Elements in Subpart Y
Citation Data Element(s) New, Revised, or Removed 98.256(e)(3) An indication of whether or not the flare is serviced by a

flare gas recovery system New

98.256(e)(6) If you use Equation Y

- 1a of §98.253, either the annual

volume of flare gas combusted (in scf/year) and the annual average molecular weight (in kg/kg

- mole), or, the annual mass of flare gas combusted (in kg/yr) Revised to allow the volume of flare gas combusted to be reported either in units of standard cubic feet per year or kilograms per year

. 98.256(k)(1) For each delayed coking unit, the unit ID number. New 98.256(k)(2) For each delayed coking unit, maximum rated

throughput of the unit, in bbl/stream day New

98.256(k)(3) For each delayed coking unit, Annual quantity of coke

produced in the unit during the reporting year, in metric
tons New

98.256(k)(4) The calculated annual CH4 emissions (in metric tons of

CH4) for the delayed coking unit Revised from cumulative facility

- basis to unit

- basis. 98.256(k)(5) The total number of delayed coking vessels (or coke

drums) associated with the delayed coking unit Revised from cumulative facility

- basis to unit

- basis.

### 29 Table 4. 1 3 New, Revised, or Removed Data Elements in Subpart Y
Citation Data Element(s) New, Revised, or Removed 98.256(k)(6) The basis for the typical dry mass of coke in the delayed

coking unit vessel at the end of the coking cycle (mass measurements from company records or calculated using Equation Y

- 18a). New

98.256(k)(7) An indication of the method used to estimate the

average temperature of the coke bed, T initial (overhead temperature and Equation Y

- 18c or pressure correlation and Equation Y

- 18d). New

98.256(k)(8) An indication of whether a unit

- specific methane

emissions factor or the default methane emission factor was used for the delayed coking unit. New

98.256(k)(2) (existing) A description of the method used to calculate the CH4

emissions for each unit (e.g., reference section and equation number). Removed

98.256(k)(3) (existing) For each coke drum or vessel, the typical drum outage Removed

98.256(k)(4) (existing) For each set of coking drums that are the same

dimensions, the number of coking drums in the set

. Removed

98.256(k)(4) (existing) For each set of coking drums that are the same

dimensions, the mole fraction of methane in coking gas

. Removed

98.256(k)(5) (existing) The basis for the volumetric void fraction of the coke

vessel prior to steaming

. Removed

98.256(k)(5) (existing) The basis for the mole fraction of methane in the coking

ga s. Removed

98. 256(k)(6) (existing) 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. Removed



### Revisions to Subpart Y with No or Minimal Impact on Burden

. EPA is proposing to improve the quality of the data collected under subpart Y by revising the calculation m ethod for delayed coking units ( DCU s ) . Specifically, EPA is proposing to revise the methodology used to
calculate CH 4 

### emissions from delayed coking units in Equation Y

- 18 from a simple gas expansion model to a steam generation model . The proposed methodology uses a heat balance on
the DCU coke drum vessel contents to estimate the volume of steam produced during the DCU decoking operations , which is proportional to the quantity of methane emitted. This method allows reporters to determine the mass of coke in the coke drum based on company records or based on drum dimensions and drum outage (parameters already required to be recorded under

t he current rule).

The proposed revisions also require reporters to determine the mass of water in the coke drum based on the height of water in the coke drum and the mass of coke in the coke drum. Reporters would use one of two methods to estimate the ave rage temperature of the coke bed contents: 1) a method based on the measured overhead temperature of the drum, and 2) a method

### 30

based on the overhead pressure using a temperature

- pressure correlation equation provided in the rule. EPA has not previously req uired temperature monitoring for the DCU in subpart Y, but the previous methodology required the vessel pressure prior to venting to be monitored and used as an input to the previous equation. The use of the temperature

- pressure correlation would allow

rep orters to use current pressure monitoring and recordkeeping practices to obtain the information needed to implement the new methodology, and would not require any the installation or use of any new monitoring systems.

EPA is also proposing to allow facili ties that have DCU vent gas measurements to use these measurements to develop a unit

- specific methane emissions factor for the DCU. This allows reporters that have previously used the combined Equation Y

- 18/Y

- 19 method (as well as other reporters) to use t he measurement data available to provide an improved, site

- specific
emissions estimate. If a unit

- specific methane emissions factor is not available, reporters would

use a default methane emissions factor for DCU of 7.9 kg methane

. Because no additional

mo nitoring or data collection would be required by the proposed changes to the DCU calculation methodology, no significant increase in burden is expected from the revisions.

To reduce reporter burden, the EPA is also proposing to clarify in this rulemaking that pilot gas, which is considered the gas used to maintain a pilot flame at the flare tip, may be excluded from the quantity of flare gas used to perform GHG emissions calculations. Clarifying that these facilities are not required to monitor the quanti ty of pilot gas may minimally reduce
burden on some facilities.

EPA is also proposing several minor corrections, and clarifications to subpart Y. These
minor revisions are summarized in the Table of Revisions and would have no impact on the burden to repo rters.

4.14 Subpart Z

– Phosphoric Acid Production EPA is proposing to revise one data element of subpart Z that wo uld impact burden for reporters, as shown in Table 4. 14

. This data element requires information that reporters are expected to have readily avail able, therefore, burden was estimated as described in Section 3.1 of
this document. There are no additional changes to subpart Z in the proposed rule.

Table 4. 1 4 New, Revised, or Removed Data Elements in Subpart Z
Citation Data Element (s) New, Revised, or Removed 98.266(f)(3) Annual phosphoric acid production capacity

(tons) for each wet

- process phosphoric acid process line. Revised from annual permitted production to annual production.

### 31

4.15 Subpart AA

– Pulp and Paper Manufacturing The EPA is not proposing any changes to subpart AA that would impact burden for
reporters. The proposed a mendment s to subpart AA would streamline the reporting requirements and improve implementation

. EPA is proposing to:

 C larify that Tier 4 CEMS are not used to report emissions under subpart AA. Subpart AA reporters have not used the Tier 4 CEMS methodology during any previous reporting year, and are not expected to do so given the mixture of biogenic and fossil

fuel CO 2 emissions in the exhaust streams f rom subpart AA emission units. This clarification is anticipated to reduce the EPA burden required to maintain e

- GGRT CEMS web forms and associated verification checks and documentation

, and would make no significant changes in burden for reporters.

 A mend the missing data provisions in 40 CFR 98.275(b) to allow reporters to use the daily mass of spent liquor solids fired reported under the NESHAP for Chemical Recovery Combustion Sources at Kraft, Soda, Sulfite, and Stand

- Alone Semichemical Pulp Mills (40 C FR 63.866(c)(1) of subpart MM) as an alternative to the maximum rate for the combustion unit

. The proposed amendments would retain the original requirements of 40 CFR 98.275(b) in addition to proposing the alternative to use the value recorded under 40 CFR 63.866(c)(1)

, to avoid requiring reconfiguration of data systems in mills that may have configured their data reporting systems to supply maximum values for subpart AA. Therefore, these changes are anticipated to present no impact on the burden to reporte rs.

 Clarifying edits to the labels in Table AA

- 2 t o clarify that the columns for “kraft lime kilns” refers specifically to “kraft rotary lime kilns

, ” and to add a footnote to Table AA

- 2 indicating that fluid bed calciners are an example of kraft calciners. These changes are minor clarifications and would not impact the burden to reporters.

4.16 Subpart CC

– Soda Ash Manufacturing

Revisions to Subpart CC that Impa ct Burden

. EPA is proposing to add two reporting requirements to subpart CC as shown in Table 4. 15

. These data elements are information that reporters are expected to have readily available, therefore, burden was estimated as described in
Section 3.1 of th is document.

Table 4. 1 5 New, Revised, or Removed Data Elements in Subpart CC

Citation Data Element(s) New, Revised, or Removed 98.296(a)(1) For each soda ash manufacturing facility, if a CEMS is used to

measure CO2 emissions, annual consumption of trona or liquid alkaline feedstock (tons) New

98.296(a)(5) For each soda ash manufacturing facility, if a CEMS is not

used to measure CO2 emissions, annual consumption of trona or liquid alkaline feedstock at the facility level (tons) New

### 32

Revisions to Subpart CC with No or Minimal Impact on Burden

. EPA is proposing one minor correction to subpart CC. This minor revision is summa rized in the Table of Revisions. The proposed change would have no impact on burden.

4.17 Subpart DD

– Electrical Transmission and D istribution Equipment Use Revisions to Subpart DD that Impact Burden. EPA is proposing revisions that would
add seven data elements and remove two data elements from the reporting requirements of subpart DD , as shown in Table 4. 16

. These data elements are information that reporters are expected to have readily available, therefore, burden was estimated as described in Section 3.1 of
this document. There are no additional changes to subpart DD in the proposed rule.

Table 4. 1 6 New, Rev ised, or Removed Data Elements in Subpart DD

Citation Data Element(s) New, Revised, or Removed 98.306(a)(2) Nameplate capacity of equipment (pounds) containing SF 6 and nameplate

capacity of equipment (pounds) containing each PFC for each electric power system, by chemical: (2) New hermetically sealed

- pressure switchgear during the year. New

98.306(a)(3) Nameplate capacity of equipment (pounds) containing SF 6 and nameplate

capacity of equipment (pounds) containing each PFC for each electric power system, by chemical: (3) New SF 6 - or PFC

- insulated equipment other than hermetically sealed

- pressure switchgear during the year. New

98.306(a)(4) Nameplate capacity of equipment (pounds) containing SF 6 and nameplate

capacity of equipment (pounds) containing each PFC for each electric power system, by chemical: (4) Retired hermetically sealed

- pressure switchgear during the year. New

98.306(a)(5) Nameplate capacity of equipment (pounds) containing SF 6 and nameplate

capacity of equipment (pounds) containing each PFC for each electric power system, by chemical: (5) Retired SF 6 - or PFC

- insulated equipment other than hermetically sealed

- pressure switchgear during the year. New

98.306(m) State(s) or territory in which the facility lies. New 98.306(m) T otal miles of transmission and distribution lines located within each

state or territory New

98.306(n) The following numbers of pieces of equipment:

(1) New hermetically sealed

- pressure switchgear during the year. (2) New SF 6 - or PFC

- insulated equipment other than hermetically sealed

pressure switchgear during the year. (3) Retired hermetically sealed

- pressure switchgear during the year. (4) Retired SF 6 - or PFC

- insulated equipment other than hermetically sealed

- pressure switchgear during the year. New

98.306(a)(2) Nameplate capacity of equipment (pounds) containing SF6 and

nameplate capacity of equipment (pounds) containing each PFC for each electric power system, by chemical: (2) New during the year (all SF6

- insulated equipment, including hermetically sealed

- pressure switchgear)

. Removed

98.306(a)( 3 ) Nameplate capacity of equipment (pounds) containing SF6 and

nameplate capacity of equipment (pounds) containing each PFC for each electric power system, by chemical: (2) Retired during the year (all SF6

- insulated equipment, including hermetically sealed

- pressure switchgear)

. Removed

### 33

4.18 Subpart FF

– Underground Coal Mines Revisions to Subpart FF that Impa ct Burden

. We are proposing several changes to subpart FF that will impact burden, including changes to monitoring requirements and adding and revising data elements to improve the quality of data received by the GHGRP

. Revisions that expand monitoring requirements . EPA is proposing to amend 40 CFR 98.324(b) to no longer allow MSHA quarterly inspection reports to be used as a source of data for monitoring methane liberated from ventilation systems. Instead, the facility will be required
to use either of the two other methods to monitor methane released from mine ventilation
systems: independently collected grab samples or continuous emissions monitoring systems (CEMS). Second, EPA is proposing to increase the frequency with which grab samples must be
tak en, from quarterly to monthly. Because the proposed changes could require reporters to implement their own sampling and would increase the frequency of the monitoring, an increase in burden has been calculated for these changes. The burden increase anticip ated from these monitoring revisions is discussed in Section 3.3 of this document.

The EPA is proposing additional changes throughout subpart FF that are necessary to ensure consistency with the proposal to require monthly , rather than quarterly, grab sam ples. For example, EPA is revising 40 CFR 98.323(a) to replace the requirement to calculate quarterly
CH 4 

### liberated from ventilation shafts with a requirement to calculate monthly CH 4 

### liberated and revising 40 CFR 98.323(a)(2) to clarify when measurements must be taken. These changes do not present any additional burden.

Revisions to reporting requirements . EPA is proposing revisions to subpart FF that would add five data elements and revise three data elements in the reporting requirements, as shown in

T able 4. 17

. Burden was estimated for these data elements as described in Section 3.1 of this
document.

Table 4. 1 7 New, Revised, or Removed Data Elements in Subpart FF

Citation Data Element(s) New, Revised, or Removed 98.326(a) Monthly CH4 liberated from each ventilation monitoring point,

(metric tons CH4). Revised from quarterly to monthly 98.326(f) Monthly volumetric flow rate for each ventilation monitoring

point and units of measure (scfm or acfm), date and location of each measurement, and method of measurement (monthly sampling or continuous monitoring), used in Equation FF

- 1 of this subpart Revised from quarterly to monthly

98.326(f) Specify whether the volumetric flow rate measurement at each

ventilation monitoring point is on dry basis or wet basis; or, if a flow meter is used, indicate whether or not the flow meter automatically corrects for moisture content. New

98.326(g) Monthly CH4 concentration for each ventilation monitoring

point, dates and locations of each measurement, and method of

m easurement (sampling or continuous monitoring). Revised from quarterly to monthly

### 34 Table 4. 1 7 New, Revised, or Removed Data Elements in Subpart FF

Citation Data Element(s) New, Revised, or Removed 98.326(g) Specify whether the CH4 concentration measurement at each

ventilation monitoring point is on dry basis or wet basis. New

98.326(h) Specify whether the volumetric flow rate measurement at each

degasification monitoring point is on dry basis or wet basis; or, if a flow meter is used, indicate whether or not the flow meter automatically corrects for moisture content. New

98.326(i) Specify whether the CH4 concentratio n measurement at each

degasification monitoring point is on dry basis or wet basis. New

98.326(u) Annual coal production in short tons for the reporting year. New



### Revisions to Subpart F

F with No or Minimal Impact on Burden

. EPA is proposing
several changes to subpart FF that will streamline reporting of GHG emissions.

EPA is proposing to amend 40 CFR 98.326(o) to limit reporting of moisture content only
in those cases where the volumetric flow rate and CH 4 

### concentration from a specific mine ventilation or degasification monitoring point are not measured on the same dry or wet basis, or, in the case that a flow meter is used, if the flow meter does not automatically correct for moisture
content. The revision s to 40 CFR 98.326(o) are clarifications and are anticipated to minimally
decrease burden for reporters. EPA is proposing several related amendments in 40 CFR 98.323, which lists the requirements for calculating GHG emissions. The changes to 40 CFR 98.323 are being proposed to ensure consistency with the proposed change to 40 CFR 98.326(o), and do not
present any change in burden.

EPA is proposing minor revisions that are intended to clarify specific provisions in subpart FF. EPA is proposing to remove “If applicable” in 40 CFR 98.324(h) to clarify that the provision requiring the owner or operator to document the procedures used to ensure the accuracy of gas flow rate, gas composition, temperature, pressure, and moisture content measurements is a requireme nt for all reporters, because grab samples and CEMS would be the only acceptable monitoring methods if the amendments to 40 CFR 98.3(b) are finalized as proposed. These changes are clarifications of the existing rule requirements and would not add any addi tional burden for reporters

Finally, the proposed revisions include several minor corrections and clarifications to subpart FF, including editorial changes and clarifications to reporting requirements. These additional minor amendments, corrections, and cl arifications are summarized in the Table of
Revisions and would have no impact on the burden to reporters

. Small Entity Impact Analysis

. The small entity economic impact for underground coal
mines was measured using the “sales tests” approach (represented as cost

- to

- receipt ratios) for the NAICS code associated with the affected subpart in the Economic Impact Analysis for

### 35

Subparts FF. The same approach is used in this analysis for the facilities subject to the subpart

FF revisions. If the ratio of rule imp lementation cost to sales is less than 1 percent, the impact is not considered to be significant. 8



### Based on the 2012 economic census database published by U.S. Bureau of the Census, the receipts (sales), number of establishments, and the average receipts for different sizes of Bituminous Coal Underground Mining facilities ( with a NAICS code of 212112) a re summarized
in Table 4.18 . The average receipts information is adjusted from 2012 dollars to 2011 dollars based on the consumer price index published by Bureau of Labor Statistics.

Table 4.18 Receipts, Number of Establishments, and Average Receipts for B ituminous Coal

Underground Mining (NAICS code of 212112) Owned by Enterprises with:
1

- 19 Employees 20

- 99

Employees 100

- 499

Employees 500

- 999

Employees 1,000

- 1,499

Employees Receipts (2012$) $246,342,000 $552,942,000 $1,676,236,000 $324,514,000

- (a)
Number of Establishments 102 56 33 5 8 Average Receipts for Each Establishment (2012$) $2,415,118 $9,873,964 $50,795,030 $64,902,800

-
Average Receipts for Each Establishment (2011$) $2,368,003 $9,681,342 $49,804,118 $63,636,672

-

(a) Note from 2012 economic census database

- Data withheld and value set to 0 to avoid disclosing data for individual businesses.



### According to the cost information listed in Table 3.7 , the rule implementation costs for subpart F F are $ 34,80 1 for the first year and $ 29,301 for subsequent years (in 2011 dollars). The sales tests (cost

- to

- receipt ratios) results are shown in Table 4.19 for the first year and subsequent

years.

Table 4.19 . Sales Tests for S ubpart FF F acilities Owned by Enterprises with:
1

- 19 Employees 20

- 99

Employees 100

- 499

Employees 500

- 999

Employees 1,000

- 1,499

Employees
Sales Test

- First Year 1.47% 0.36% 0.07% 0.05%

- Sales Test

- Subsequent Years 1.26% 0.31% 0.06% 0.05%

-



### The results in Table 4.19 show that the costs for the rule revisions for facilities subject to subpart FF are below 1 percent of the sales for size categories with greater than 20 employees for

8 U.S. EPA. Economic Impact Analysis for the Mandatory reporting of Greenhouse Gas Emissions: Subparts T, FF, TT, and II. See Docket ID: EPA

- HQ

- OAR

- 2008

- 0508

- 2313. June 2010.

### 36

Bituminous Coal Underground Mining facilities with a NAICS code of 212112

. The sales test exceeded 1 percent for the 1

- 19 employees size category for subpart FF. The sales test for this size category was also exceeded in the original EIA and the EPA noted that mines owned by enterprises with less than 19 employees would be unlikely to be covered by this rule. The same
ration ale applies here, and as such, we do not anticipate any impacts on small entities for subpart FF reporters.

4.19 Subpart HH

– Municipal Solid Waste Landfills Revisions to Subpart HH that Impact Burden. EPA is proposing several amendments to subpart HH that would revise one data element

, add two data elements

, and remove one element in the reporting requirements, as shown in Table 4. 20

. The new and revised data elements are information that reporters are expected to have readily available. Burden was estimate d for these
data elements as described in Section 3.1 of this document.

Table 4. 20 New, Revised, or Removed Data Elements in Subpart HH

Citation Data Element(s) New, Revised, or Removed 98.346(i)(5)(iii)(B) The annual operating hours where active gas flow was sent to the

destruction device. Revised from annual operating hours for each destruction devic e to annual hours that active gas flow was sent to each destruction device 98.346(i)(7) A n indication of whether the gas collection efficiency was

determined on an area

- weighted average basis (Option 1) or a volume

- weighted average basis (Option 2) New

98.346(i)(13) Methane emissions for the landfill (i.e., the subpart HH total

methane emissions). Choose the methane emissions from either Equation HH

- 6 of this subpart or Equation HH

- 8 of this subpart that best represents the emissions from the landfill. If the quantity of recovered CH4 from Equation HH

- 4 of this subpart is used as the value of G CH4 in Equation HH

- 6 of this subpart, use the methane emissions calculated using Equation HH

- 8 of this subpart as the methane emissions for the landfill. New

98.346(f) (existing) If multiple cover types are used, the surface area associated with

each cover t ype. Removed



### Revisions to Subpart HH with No or Minimal Impact

. EPA is proposing several technical amendments for subpart HH. These amendments are expected to have minimal or no impact to reporters. EPA is proposing:

 Revisions to Table HH

- 3 to allow landfill owners or operators to determine the weighted average collection efficiency for their landfill using either an area

- based weighting approach or a volume

- based weighting approach.

### 37

 Revising the description of area t ype A5 in Table HH

- 3 to allow alternative final covers to use a collection efficiency greater than 75 percent, and adding a definition of “alternative final cover”.

 S everal changes to Table HH

- 4 to revise and clarify the soil cover requirements

, including revis ing the phrase “... for a majority of the landfill area containing waste...” to read “... for at least 50 percent of the landfill area containing waste...”

, and revis ing the requirement for “... a soil cover of at least 24 inches ...” to read “ ... intermediate or interim soil cover ...”

 A change to 40 CFR 98.358 to define intermediate or interim soil cover to mean “the placement of material over waste in a landfill for a perio d of time prior to disposal of additional waste and/or final closure as defined by state regulation, permit, guidance or written plan, or state accepted best management practice.”

 To a dd a footnote to Table HH

- 4 stating that where a landfill is located in a state that does not have an intermediate or interim cover requirement, the landfill must have a soil cover of 12 inches or greater to use an oxidation fraction of 0.25 or 0.35.

 To clarify the oxidation fractions that apply to landfills based on soil co ver. The proposed revisions would require l andfills that have passive or active vent systems that service greater than 50

- percent of the landfill area containing waste or landfills that have only passive or active vent systems to use the default 10 percent oxidation fraction in their emission calculations. EPA is also proposing to require the use of 10 percent oxidation fraction for landfills with passive or active venting or for landfills with less than 12 inches of soil cover or for landfills with less th an 12 inches of soil

cover (that do not also have a geomembrane cover).

 To add d efinitions of “passive vent” and “active venting” to further clarify the rule requirements as they pertain to landfill gas collection system flow and composition monitoring an d the use of soil oxidation fractions

. Because the proposed revisions only provide clarification of the existing requirements, there is no anticipated increase in burden from these changes.

The propos ed revisions also include several minor corrections and clarifications to subpart HH, including editorial changes and clarifications to reporting requirements. These additional minor amendments, corrections, and clarifications are summarized in the Table of
Revisions and would have no impact on the burden to r eporters

.

4.20 Subpart II

– Industrial Wastewater Treatment

Revisions to Subpart II that Impact Burden. The EPA is proposing revisions to the reporting requirements of subpart II that would add one data elemen t and revise four data
elements , as shown in Table 4. 21

. These data elements are information that reporters are

### 38

expected to have readily available, therefore, burden was estimated as described in Section 3.1 of
this document.

Table 4. 21 New, Revised, or Removed Data Elements in Subpart II

Citation Data Element(s) New, Revised, or Removed 98.356(a) The anaerobic processes used in the industrial wastewater

treatment system to treat industrial wastewater and industrial wastewater treatment sludge Revised to clarify reporting as separate data element.
98.356(a) The average depth in meters of each anaerobic lagoon Revised to clarify reporting as separate data element. 98.356(a) Indicate whether biogas generated by each anaerobic process is

recovered Revised to clarify reporting as separate data element. 98.356(a) Provide a unique identifier for each anaerobic process. Each

anaerobic processes must be identified as one of the following: (1) Anaerobic reactor. (2) Anaerobic deep lagoon (depth more than 2 meters). (3) Anaerobic shallow lagoon (d epth less than 2 meters). (4) Anaerobic sludge digester. Revised to clarify reporting as separate data element.

98.356(b)(6) For each anaerobic wastewater treatment process (reactor, deep

lagoon, or sh allow lagoon) you must report: If the facility performs an ethanol production processing operation as defined in §98.358 of this subpart, you must indicate if the facility uses a wet milling process or a dry milling process. New



### Revisions to Subpart II with No or Minimal Impact on Burden. EPA is proposing an amendment to 40 CFR 98.358 to add a definition of the term weekly average. The proposed
amendments would resolve uncertainties in the reporting requirements regarding how to calculate weekly averages for chemical oxygen demand/5

- day biochemical oxygen demand ( COD/BOD5 ) concentration, CH 4 

### concentration, biogas temperature, biogas moisture content, and biogas pressure, and present no impact on burden for reporters.

The EPA is also proposing to add definitions for the terms wet mill ing and dry milling to 40 CFR 98.358 to clarify what is meant by the new data elements in 40 CFR 98.356(b)(6) in
Table 4.21 above.

4.21 Subpart LL

– Suppliers of Coal

- based Liquid Fuels Revisions to Subpart LL that Impact Burden. EPA is proposing to remove fiv e reporting requirements from subpart LL as shown in Table 4. 22

. The change in burden from the removal
of these data elements was estimated as described in Section 3.1 of this document.

Table 4. 22 New, Revised, or Removed Data Elements in Subpart LL

Citation Data Element(s) New, Revised, or Removed 98.386(a)(4) Each standard method or other industry standard practice used to Removed

### 39 measure each quantity reported in paragraph (a)(2) of this section.

98.386(a)(8) Each standard method or other industry standard practice used to

measure each quantity reported in paragraph (a)( 6 ) of this section. Removed

98.386(a)(15) Each standard method or other industry standard practice used to

measure each quantity reported in paragraph (a)( 14 ) of this section. Removed

98.386(b)(4) Each standard method or other industry standard practice used to

measure each quantity reported in paragraph ( b )( 2 ) of this section. Removed

98.386(c)(4) Each standard method or other industry standard practice used to

measure each quantity reported in paragraph ( c )( 2 ) of this section. Removed



### Revisions to Subpart LL with No or Minimal Impact on Burden. The EPA is also proposing several minor corrections and clarification to subpart LL of Part 98, including editorial changes, harmonizing changes, and clarifications to reporting requirements. These minor
revisions are summarized in the Table of Revisions and would have no impact on burden to reporters

.

4.22 Subpart NN

– Suppliers of Natural G as and Natural Gas Liquids Revisions to Subpart NN that Impact Burden. The EPA is proposing to add one new reporting requirement to subpart NN as shown in Table 4. 23

. This data element requires information that reporters are expected to have readily available, therefore, burden was estimated
as described in Section 3.1 of this document.

Table 4. 23 New, Revised, or Removed Data Elements in Subpart NN

Citation Data Ele ment (s) New, Revised, or Removed 98.406(b)(14) The name of the U.S. state or territory covered in

this report submission. New



### Revisions to Subpart NN with No or Minimal Impact on Burden

. EPA is also proposing several minor corrections and clarification to subpart NN , including editorial changes, harmonizing changes, and clarifications to reporting requirements. These minor revisions are
summarized in the Table of Revisions and would have no impact on burden to reporters

.

4.23 Subpart OO

— Suppliers of Industrial Greenhouse Gases Revisions to Subpart OO that Impact Burden. EPA is proposing three amendments to subpart OO that would impact burden , including two revisions to the definition of the source category that affect the applicability of Part 98 to fluorinated gas suppliers

, and changes to the reporting requirements to require reporting of fluorinated heat transfer fluids that are not fluorinated greenhouse gases.

Revisions to applicability. The p roposed amendments include two revisions to the definition of the source category. First, EPA is proposing to revise 40 CFR 98.410(a) to i nclude

### 40

facilities that destroy 25,000 mtCO2e or more of fluorinated GHGs and fluorinated HTFs annually. This expansio n of the definition of the subpart OO source category would impact only facilities that destroy previously produced fluorinated GHGs and that are not already required to report any residual emissions of the destroyed fluorinated GHGs under another subpart. These changes are anticipated to result in 5

- 10 new reporters under subpart OO which would result in an increase in burden for this subpart.

The propos ed amendments to 40 CFR 98.410(a) would also revise subpart OO to include entities that produce, impor t, transform, export, or destroy fluorinated HTFs that are not also
fluorinated GHGs under the subpart A definition , and to require monitoring and reporting of these activities from all suppliers that engage in them. Suppliers of fluorinated HTFs would be subject to the same thresholds as suppliers of fluorinated GHGs ; there would be no threshold for producers of fluorinated HTFs, but the threshold for importers, exporters, and destroyers of fluorinated HTFs would be 25,000 mtCO 2 

### e of fluorinated HTFs or GHG s. There are no new suppliers of fluorinated HTFs anticipated to be required to begin reporting per the proposed changes.

The methodology for determining new reporters and the cost impacts for n ew reporters subject to subpart OO based on the proposed changes to applicability are described in Section 3.2
of this document.

Revisions to reporting requirements. Consistent with the proposed changes to the applicability of subpart OO , EPA is proposing to revise the scope of reporting to include
fluorinated HTFs

. The proposed revis ions to the reporting requirements would add reporting of
fluorinated HTFs to 41 data elements , as shown in Table 4. 24

.

Table 4. 24

. New Data Elements Proposed to Be Added to Subpart OO

Citation Proposed Data Element Each fluorinated GHG, fluorinated HTF, or nitrous oxide production facility shall report the following information: 98.416(a)(1) Mass in metric tons of each . . . fluorinated HTF . . . produced at that facility by

process, except for amounts that are captured solely to be shipped off site for destruction.
98.416(a)(2) Mass in metric tons of each fluorinated HTF . . . transformed at that facility, by

process. 98.416(a)(3) Mass in metric tons of . . . fluorinated HTF that is destroyed at that facility and that

was previously produced as defined at § 98.410(b). Quantities to be reported under this paragraph (a)(3) of this section include but are not limited to quantities that are shipped to the facility by another facility for destruction and q uantities that are returned to the facility for reclamation but are found to be irretrievably contaminated and are therefore destroyed. 98.416(a)(5) Total mass in metric tons of each. . . fluorinated HTF. . . sent to another facility for

transformation.

### 41 Table 4. 24

. New Data Elements Proposed to Be Added to Subpart OO

Citation Proposed Data Element 98.416(a)(6) Total mass in metric tons of each . . . fluorinated HTF sent to another facility for

destruction, except. . . fluorinated HTFs that are not included in the mass produced in § 98.413(a) because they are removed from the production process as b y

products or other wastes. Quantities to be reported under this paragraph (a)(6) could include, for example, fluorinated GHGs that are returned to the facility for reclamation but are found to be irretrievably contaminated and are therefore sent to anothe r facility for destruction.
98.416(a)(7) Total mass in metric tons of each . . . fluorinated HTF that is sent to another facility

for destruction and that is not included in the mass produced in § 98.413(a) because it is removed from the production process as a byproduct or other waste. 98.416(a)(10) Mass in metric tons of any . . .fluorinated HTF . . . fed into the transformation

process, by process.

98.416(a)(11) Mass in metric tons of . . . fluorinated HTF that is fed into the destruction device

and that was previously produced as defined at § 98.410(b). Quantities to be reported under this paragraph (a)(11) of this section include but are not limited to quantities that are shipped to the facility by another facility for destruction and quantitie s that are returned to the facility for reclamation but are found to be irretrievably contaminated and are therefore destroyed.

98.416(a)(12) Mass in metric tons of . . . fluorinated HTF . . . that is measured coming out of the

production process, by proc ess. 98.416(a)(13) Mass in metric tons of each used . . . fluorinated HTF . . . added back into the

production process (e.g., for reclamation), including returned heels in containers that are weighed to measure the mass in §98.414(a), by process.
98.416(a)(14) Names and addresses of facilities to which any . . . fluorinated HTFs were sent for

transformation. 98.416(a)(14) Quantities (metric tons) of ... each . . . fluorinated HTF that were sent to each for

transformation. 98.416(a)(15) Names and addresses of facilities to which any ... fluorinated HTFs were sent for

destruction. 98.416(a)(15) Quantities (metric tons) of each . . . fluorinated HTF that were sent to each for

destruction. Any facility that destroys ... fluorinated HTFs shall submit a one - time report containing the following information ...for each destruction process : 98.416(b)(1) Destruction efficiency (DE). 98.416(b)(2) Methods used to determine the destruction efficiency. 98.416(b)(3) Methods used to record the mass of . . . fluorinated HTF destroyed.
98.416(b)(4) Chemical identity of the fluorinated GHG(s) used in the performance test conducted

to determine DE. 98.416(b)(5) Name of all applicable federal or state regulations that may apply to the destruction

process. 98.416(b)(6) If any process changes affect unit destruction efficiency or the methods used to

record mass of . . . fluorinated HTF destroyed, then a revised report must be submitted to reflect the changes. Each bulk importer of . . .fluorinated HTFs . . . shall submit an annual report that summarizes its imports at the corporate level, except for shipments including less than twenty

- five kilograms of fluorinated GHGs, fluorinated HTFs, or nitrous oxide, transshipments, and heels that meet the conditions s et forth at §98.417(e). The report shall contain the following information for each import:

### 42 Table 4. 24

. New Data Elements Proposed to Be Added to Subpart OO

Citation Proposed Data Element 98.416(c)(1) Total mass in metric tons of . . . each . . . fluorinated HTF imported in bulk,

including each... fluorinated HTF constituent of the. . . fluorinated HTF product that makes up between 0.5 percent and 100 percent of the product by mass. 98.416(c)(2) Total mass in metric tons of . . . fluorinated HTF imported in bulk and sold or

transferred to persons other than the importer for use in processes resulting in the transformation or destruction of the chemical. 98.416(c)(3) Date on which the... fluorinated HTFs . . . were imported. 98.416(c)(4) Port of entry through which the . . . fluorinated HTFs . . . passed. 98.416(c)(5) Country from which the imported ... fluorinated HTFs . . . were imported. 98.416(c)(6) Commodity code of the ... fluorinated HTFs ...shipped. 98.416(c)(7) Importer number for the shipment. 98.416(c)(8) Total mass in metric tons of each . . .fluorinated HTF destroyed by the importer. 98.416(c)(9) Names and addresses of facilities. 98.416(c)(9) Quantities of fluorinated HTFs sold or transferred to each facilities for

transformation. 98.416(c)(10) If applicable, the names and addresses of the persons and facilities to which the . . .

fluorinated HTFs were sold or transferred for destruction. 98.416(c)(10) If applicable, the quantities (metric tons) of each . . . fluorinated HTF that were sold

or transferred to each facility for destruction. Each bulk exporter of fluorinated GHGs, fluorinated HTFs, or nitrous oxide shall submit an annual report that summarizes its exports at the corporate level, except for shipments including less than twenty

- five kilograms of fluorinated GHGs, fluorinated HTFs, or nitrous oxide, t ransshipments, and heels. The report shall contain the following information for each export: 98.416(d)(1) Total mass in metric tons of . . . each . . .fluorinated HTF exported in bulk.
98.416(d)(2) Names and addresses of the exporter and the recipient of the exports. 98.416(d)(3) Exporter's Employee Identification Number. 98.416(d)(4) Commodity code of the . . . fluorinated HTFs . . . shipped. 98.416(d)(5) Date on which, and the port from which, the . . . fluorinated HTFs . . . were exported

from the United States or its territories. 98.416(d)(6) Country to which the . . . fluorinated HTFs . . . were exported. 98.416(i) Each facility that destroys fluorinated GHGs or fluorinated HTFs but does not

otherwise report under this section shall report the mass in metric tons of each fluorinated GHG or fluorinated HTF that is destroyed at that facility and that was previously produced as defined at § 98.410(b) or (d), as applicable. Quantities to be reported under this paragraph (i) include but are not limit ed to quantities that are shipped to the facility by another facility for destruction and quantities that are returned to the facility for reclamation but are found to be irretrievably contaminated and are therefore destroyed. 98.416(j) If the facility commences production of a fluorinated HTF product that was not

included in the initial report or performs a repeat measurement under § 98.414(n) that shows that the identities or concentrations of the fluorinated HTF or fluorinated GHG constituents of a fl uorinated HTF product have changed, then the new or changed concentrations must be provided in a revised report. 98.416(j) If the facility commences production of a fluorinated HTF product that was not

included in the initial report or performs a repeat measurement under § 98.414(n) that shows that the identities or concentrations of the fluorinated HTF or fluorinated GHG constituents of a fluorinated HTF product have changed, the date of the change must be provided in a revised report.

### 43

Because all suppliers of fluorinated HTF are believed to currently report under subpart OO, i t is anticipated that the revised reporting would involve reporting supplies of only

one to 12 additional compounds by two to three suppliers of fluorinated HTFs , rather than the entire reporting field . The refore, the burden increase from the addition of reporting 40 d ata
elements is estimated for three reporters

. The methodology for estimating the proposed costs and the impacts are presented in Section 3.1 of this document. Th e proposed reporting changes include one additional new data element (40 CFR 98.416(i)) that would only apply to facilities that destroy fluorinated GHGs or fluorinated HTFs but do not otherwise repor t under subpart
OO. This data element is similar to exis ting data elements in subpart OO, and the burden for this
data element is assumed to be included in the cost impacts for n ew reporters subject to subpart
OO as described in Section 3.2 of this document.

Small Entity Impact Analysis

. The small entity econ omic impact for suppliers of industrial greenhouse gases was measured using the “sales tests” approach (represented as cost

to

- receipt ratios) for the NAICS code associated with the affected subpart in the Regulatory Impact Analysis for the GHG Reporting Rule

. The same approach is used in this analysis for the additional facilities subject to subpart OO due to the revisions. If the ratio of rule implementation cost to sales is less than 1 percent, the impact is not considered to be significant. 10



### Based on the 2012 economic census database published by U.S. Bureau of the Census, the receipts (sales), number of establishments, and the average receipts for different sizes of Industrial Gas Manufacturing facilities ( with a NAICS code of 325120) are summarized i n Table
4.25 . The average receipts information is adjusted from 2012 dollars to 2011 dollars based on the consumer price index published by Bureau of Labor Statistics.

Table 4.25 Receipts, Number of Establishments, and Average Receipts for Industrial Gas M anufacturing (NAICS code of 325120)

Owned by Enterprises with:
1

- 19 Employees 20

- 99

Employees 100

- 499

Employees 500

- 999

Employees 1,000

- 1,499

Employees Receipts (2012$) $111,567,000 $116,335,000

- (a)

- (a)

- (a)
Number of Establishments 53 5 14 12 48 Average Receipts for Each Establishment (2012$) $2,105,038 $23,267,000

- - - Average Receipts for Each Establishment (2011$) $2,063,973 $22,813,106

- - - (a) Note from 2012 economic census database

- Data withheld and value set to 0 to avoid disclosing data for individual businesses.

### 44

According to the cost information listed in Table 3.5 , the rule implementation cost s for subpart OO are $ 4,527 for the first year and $ 3,327 for subsequent years (in 2011 dollars). The sales tests (cost

- to

- recei pt ratios) results are shown in Table 4.26 for the first year and subsequent

years.

Table 4.26 Sales Tests for Subpart OO Facilities Owned by Enterprises with:

1

- 19 Employees 20

- 99

Employees 100

- 499

Employees 500

- 999

Employees 1,000

- 1,499

Employees
Sales Test

- First Year 0.22% 0.02%

- - - Sales Test

- Subsequent Years 0.16% 0.01%

- - -



### The results in Table 4 .26 show that the costs for the rule revisions for facilities subject to subpart OO are below 1 percent of the sales for all size s of Industrial Gas Manufacturing
facilities with a NAICS code of 325120 that have data . Therefore, it was determined that there is not a significant impact on a substantial number of small businesses subject to reporting under subpart OO as a result of this ac tion.

4.24 Subpart RR

– Geologic Sequestration of Carbon Dioxide EPA is proposing one r evision to s ubpart RR that would i mpact b urden. The EPA is proposing to add one data reporting element , as shown in Table 4. 27

. This data element requires
information that re porters are expected to have readily available, therefore, burden was estimated
as described in Section 3.1 of this document. There are no additional pr oposed changes to this subpart.

Table 4. 2 7 New, Revised, or Removed Data Elements in Subpart RR

Citation Data Element (s) New, Revised, or Removed 

### 98.446(g) Whether the CO2 stream is being injected in to subsurface

geologic formations to enhance the recovery of oil or natural gas. New



### 4.25 Subpart TT

— Industrial Waste Landfills The EPA is proposing several amendments to Table TT

- 1 to subpart TT that would improve the quality of the data collected under the GHGRP. These proposed revisions are anticipated have no or minimal impact on the burden for reporters.

The EPA is proposing to provide additional default DOC values for the pulp and paper industry for the purposes of improving the accuracy of the methane emissions estimates reported under subpart TT. The proposed revisions would provide default DOC values for the four

### 45

specific pulp and paper industry waste types previously listed , including Boiler Ash, Wastewater Sludge, Kraft Recovery Wastes, and Other Pulp and Paper Wastes . In addition, the revisions
would include a footnote to Table TT

- 1 to explain that Kraft Recovery Wastes include green liquor dregs, slaker grits, and lime mud, which may also be referred to collectively as causticizing or recausticizing wastes. Because these are changes to default values used in calculating emissions, the proposed revisions are anticipated t o have no impact on reporters. In some cases, the proposed revisions may reduce burden for some facilities currently using site

specific factors.

EPA is also proposing one minor correction to subpart TT . Th is minor revision is
summarized in the Table of R evisions and would have no impact on burden.

4.26 Other Minor Revisions, Clarifications, and Corrections

In addition to the substantive amendments presented in this Section 4, we are proposing minor revisions, clarifications, and corrections to subparts P, U, MM, PP, and UU of Part 98. The proposed changes to these subparts are provided in the Table of Revisions, and include clarifying requirements to better reflect the EPA’s in tent, corrections to calculation terms or

cross

- references that do not revise the output of calculations, harmonizing changes within a subpart (such as changes to terminology), simple typographical errors, and other minor corrections (e.g., removal of redu ndant text). The proposed changes would have no impact on the burden to reporters.

5.0 CONFIDENTIALITY DETE RMINATIONS FOR NEW O R CHANGED REPORTING E LEMENTS In addition to proposing changes to streamline and improve implementation of the rule and to improve the quality and consistency data , EPA is proposing confidentiality determinations for new or substantially revised reporting data elements

. EPA is also proposing confidentiality determinations for existing data elements for which a confidentiality determinati on has not previously been proposed, or where the EPA has determined that the current determination is no longer appropriate

, in subparts I, Z, MM, NN, PP, and RR

. The proposed confidentiality determinations do not affect the burden on reporters, and thus no burden was estimated for the
determinations.