DATE: August 2013

TO: Docket EPA-HQ-OAR-2010-0929 

FROM: Lisa Grogan-McCulloch, EPA

SUBJECT: EPA’s Interagency Communications Regarding Development of

“Revisions to Reporting and Recordkeeping Requirements, and 

Proposed Confidentiality Determinations under the Greenhouse Gas 

Reporting Program.”

 

This memorandum summarizes the EPA’s interagency communications regarding 

development of the proposed rulemaking “Revisions to Reporting and Recordkeeping 

Requirements, and Proposed Confidentiality Determinations under the Greenhouse Gas 

Reporting Program.” As specified in the table below, Attachment A includes the EPA’s 

interagency email correspondence. Attachments B through V include the documents 

attached to this email correspondence.

Attachment Topic

A E-mail thread of correspondence with OMB containing

sequence of correspondence and attached filenames.

B E-mail attachment filename 2015 Inputs – Inter-agency 

briefing.pptx

C E-mail attachment FR language on data use, accuracy, and 

verification

D E-mail attachment filename Memo_List of Inputs Proposed 

Not To Report_06272013

E E-mail attachment filename PreambleJuly 11_clean

F E-mail attachment filename PreambleJuly 11_track changes

G E-mail attachment filename Preamble and amendatory text 8-

1-13_clean

H E-mail attachment filename Preamble and amendatory text8-

1-13_track changes since OMB submission

I E-mail attachment filename Step 4 -Alternative Verification 

Methods Analysis_clean

J E-mail attachment filename Step 4 -Alternative 

VerificationMethods Analysis_changes since OMB 

submission
K E-mail attachment filename Preamble and amendatory text_8-

5-2013_clean 

L E-mail attachment filename Preamble and amendatory text_8-

5-2013_changes since 8-1-13 

M E-mail attachment filename 

EO12866_GHGRP_Part_98_2060_AQ81_NRPM_20130516_ 

InteragencyCommentsunderEO13563

N E-mail attachment filename Memo_List of Inputs Proposed 

Not To Report 

O E-mail attachment filename Step 1 - Public Availability 

Analysis

P E-mail attachment filename Step 2 - Harm Analysis

Q E-mail attachment filename Step 3 - Alternative Calculation 

Analysis

R E-mail attachment filename Step 4 -Alternative Verification 

Methods Analysis

S E-mail attachment filename Inputs Verifier Description -

Memo 8.2

T E-mail attachment filename Attachment 1 - User Interface

U E-mail attachment filename Attachment 2 - Data Structure

V E-mail attachment filename Attachment 3 - Code Structure
Attachment A 
From: Grogan-McCulloch, Lisa 

Sent: Wednesday, May 29, 2013 10:07 AM 

To: 'Higgins, Cortney' 

Cc: Karimjee, Anhar 

Subject: RE: Inter-Agency Briefing on GHG Reporting Program: Amendments to Address Inputs to Emission 

Equation Issues; Call in: 866-299-3188; code: 2023439743 

Hi Cortney, 

Here are the slides for the briefing today. Do you have a sense for Agencies that are planning to join? 

Looking forward to talking later today. 

Best, 

Lisa 

Lisa Grogan-McCulloch 

US EPA 

617-918-1481 

grogan-mcculloch.lisa@epa.gov<mailto:greene.cynthia@epa.gov> 

[Attached file: 2015 Inputs – Inter-agency briefing.pptx] 

From: Higgins, Cortney [mailto:Cortney_Higgins@omb.eop.gov] 

Sent: Wednesday, May 29, 2013 9:09 AM 

To: Grogan-McCulloch, Lisa 

Subject: RE: Inter-Agency Briefing on GHG Reporting Program: Amendments to Address Inputs to Emission 

Equation Issues; Call in: 866-299-3188; code: 2023439743 

Hi Lisa, 

Will you be sending any slides ahead of the interagency briefing today? 

Thanks, 

Cortney 

-----Original Appointment----- 

From: Grogan-McCulloch, Lisa [mailto:Grogan-McCulloch.Lisa@epa.gov] 

Sent: Tuesday, May 28, 2013 9:33 AM 

To: Grogan-McCulloch, Lisa; Higgins, Cortney; Bohman, Jennifer; Gunning, Paul; Karimjee, Anhar 

Cc: Higgins, Cortney; VanLare, Paula 

Subject: Inter-Agency Briefing on GHG Reporting Program: Amendments to Address Inputs to Emission Equation 

Issues; Call in: 866-299-3188; code: 2023439743 

When: Wednesday, May 29, 2013 2:00 PM-3:00 PM (UTC-05:00) Eastern Time (US & Canada). 

Where: DCRoom1310L809p16DVDPoly/DC-1310L-OAR 

When: Wednesday, May 29, 2013 2:00 PM-3:00 PM (GMT-05:00) Eastern Time (US & Canada). 

Where: DCRoom1310L809p16DVDPoly/DC-1310L-OAR 

Note: The GMT offset above does not reflect daylight saving time adjustments. 

*~*~*~*~*~*~*~*~*~* 
From: Grogan-McCulloch, Lisa 

Sent: Thursday, June 27, 2013 5:09 PM 

To: 'Higgins, Cortney' 

Cc: Karimjee, Anhar 

Subject: RE: Interagency Comments under EO 12563 on GHG Reporting Tool Inputs 

Hi Cortney, 

Per your request, I'm attaching a document that summarizes past FR language discussing the use of the GHG 

Reporting data and need for robust verification. I am also attaching an updated version of the memo describing 

what would/would not be reported under this proposal. (The previous version inadvertently omitted the subpart W 

data elements from the list of data that would be reported.) 

I am working on putting together a track changes version of the preamble/rule text and expect to get that to you the 

week of July 7th. 

Best, 

Lisa 

Lisa Grogan-McCulloch 

US EPA 

617-918-1481 

grogan-mcculloch.lisa@epa.gov<mailto:greene.cynthia@epa.gov> 

[Attached file: FR language on data use, accuracy, and verification] 

[Attached file: Memo_List of Inputs Proposed Not To Report_06272013] 
From: Grogan-McCulloch, Lisa 

Sent: Thursday, July 11, 2013 9:10 AM 

To: 'Higgins, Cortney' 

Cc: Karimjee, Anhar 

Subject: RE: Interagency Comments under EO 12563 on GHG Reporting Tool Inputs 

Hi Cortney, 

Attached is an updated preamble/rule addressing interagency comments. In addition to changes made to address 

interagency comments, we've also made some additional minor changes (e.g., streamlined regulatory text changes, 

formatted to adhere to FR guidelines). 

If you have any questions, please don't hesitate to contact me. 

Best, 

Lisa 

[Attached file: PreambleJuly 11_clean] 

Lisa Grogan-McCulloch 

US EPA 

617-918-1481 

grogan-mcculloch.lisa@epa.gov<mailto:greene.cynthia@epa.gov> 

From: Higgins, Cortney [mailto:Cortney_Higgins@omb.eop.gov] 

Sent: Thursday, June 13, 2013 6:21 PM 

To: Grogan-McCulloch, Lisa 

Cc: VanLare, Paula 

Subject: Interagency Comments under EO 12563 on GHG Reporting Tool Inputs 

Hi Lisa, 

Attached are interagency comments on the draft rule under EO 12866 and 13563 review. Please let me know if you 

have any questions. 

Regards, 

Cortney 

[Attached file: PreambleJuly 11_track changes] 
From: Grogan-McCulloch, Lisa 

Sent: Thursday, August 01, 2013 10:23 PM 

To: 'Higgins, Cortney' 

Cc: Karimjee, Anhar; Bohman, Jennifer 

Subject: RE: Interagency Comments under EO 12563 on GHG Reporting Tool Inputs 

Hi Cortney, 

Attached are the updated preamble and amendatory text files, clean version and a version that shows the changes 

since OMB submission. 

My colleague, Jen Bohman, will be sending the memo (which provides the IT explanation for how the inputs are not 

saved by EPA) tomorrow. 

Best, 

Lisa 

Lisa Grogan-McCulloch 

US EPA 

617-918-1481 

grogan-mcculloch.lisa@epa.gov<mailto:greene.cynthia@epa.gov> 

[Attached file: Preamble and amendatory text 8-1-13_clean] 

[Attached file: Preamble and amendatory text8-1-13_track changes since OMB submission] 

From: Higgins, Cortney [mailto:Cortney_Higgins@omb.eop.gov] 

Sent: Thursday, July 25, 2013 3:45 PM 

To: Grogan-McCulloch, Lisa 

Cc: Karimjee, Anhar 

Subject: RE: Interagency Comments under EO 12563 on GHG Reporting Tool Inputs 

Hi Lisa, 

Below are a couple of comments - there may also be comments that come over at the end of next week. 

* The discussion of "Regulated Entities" that begins on p. 5 lists all of the source categories subject to the 

GHG Reporting Rule in Table 1, but they should be more clear that all of these source categories are not necessarily 

affected by this rule, but rather only the 24 source categories listed in Table 2 are affected by this rule. 

* The proposed revisions and confidentiality determinations should note the Deferral for CO2 emissions 

from Bioenergy and Other Biogenic Sources under the Prevention of Significant Deterioration (PSD) and Title V 

which is effective until July 2014. EPA has requested the assistance of a Science Advisory Board (SAB) in 

reviewing the accounting of biogenic greenhouse gas (GHG) emissions and determining the extent of emissions 

from various feedstocks. The Revisions to Reporting and Recordkeeping Requirements should explicitly 

acknowledge the ongoing SAB process and the beneficial role of biofuels and biogenic feedstocks. 

Please give me a call if you have any questions. 

Regards, 

Cortney 

202.395.7856 
From: Grogan-McCulloch, Lisa 

Sent: Monday, August 05, 2013 9:23 AM 

To: 'Higgins, Cortney' 

Cc: Karimjee, Anhar 

Subject: RE: Interagency Comments under EO 12563 on GHG Reporting Tool Inputs 

Hi Cortney, 

Sure, see the attached files (a clean version and a version showing changes since OMB submittal). 

Best, 

Lisa 

Lisa Grogan-McCulloch 

US EPA 

617-918-1481 

grogan-mcculloch.lisa@epa.gov 

[Attached file: Step 4 -Alternative Verification Methods Analysis_clean] 

From: Higgins, Cortney [mailto:Cortney_Higgins@omb.eop.gov] 

Sent: Friday, August 02, 2013 7:33 PM 

To: Grogan-McCulloch, Lisa 

Cc: Karimjee, Anhar 

Subject: RE: Interagency Comments under EO 12563 on GHG Reporting Tool Inputs 

Hi Lisa, 

Can you please send me the following document: 

"Evaluation of Alternative Verification Approaches for Greenhouse Gas Reporting Rule Subparts for which 

Reporting of Inputs to Emission Equations was Deferred to March 31, 2015” 

I have no other comments on the draft. 

Regards, 

Cortney 

From: Bohman, Jennifer [mailto:Bohman.Jennifer@epa.gov] 

Sent: Friday, August 02, 2013 2:07 PM 

To: Grogan-McCulloch, Lisa; Higgins, Cortney 

Cc: Karimjee, Anhar 

Subject: RE: Interagency Comments under EO 12563 on GHG Reporting Tool Inputs 

Hi Courtney. 

Attached find the memo describing the IT aspects of the inputs verification tool. Let me know if there are any 

questions. 

Jen Bohman 

US EPA Climate Change Division 

202.343.9548 

[Attached file : Step 4 -Alternative VerificationMethods Analysis_changes since OMB submission] 
From: Grogan-McCulloch, Lisa [mailto:Grogan-McCulloch.Lisa@epa.gov] 

Sent: Monday, August 05, 2013 3:49 PM 

To: Higgins, Cortney 

Cc: Karimjee, Anhar 

Subject: RE: Can you send me the corrected clean version? 

Hi Cortney, 

Here are the updated versions - clean and track changes since 8/1. 

Best, 

Lisa 

[Attached file: Preamble and amendatory text_8-5-2013_clean] 

[Attached file: Preamble and amendatory text_8-5-2013_changes since 8-1-13] 

Lisa Grogan-McCulloch 

US EPA 

617-918-1481 

grogan-mcculloch.lisa@epa.gov<mailto:greene.cynthia@epa.gov> 

From: Higgins, Cortney [mailto:Cortney_Higgins@omb.eop.gov] 

Sent: Monday, August 05, 2013 1:39 PM 

To: Grogan-McCulloch, Lisa 

Subject: Can you send me the corrected clean version? 

Please send me the clean version with the changes you indicated, along with a redline comparison to the 8/1 draft. 

Thanks, 

Cortney 
From: Higgins, Cortney [mailto:Cortney_Higgins@omb.eop.gov] 

Sent: Thursday, June 13, 2013 6:21 PM 

To: Grogan-McCulloch, Lisa 

Cc: VanLare, Paula 

Subject: Interagency Comments under EO 12563 on GHG Reporting Tool Inputs 

Hi Lisa, 

Attached are interagency comments on the draft rule under EO 12866 and 13563 review. Please let me know if you 

have any questions. 

Regards, 

Cortney 

[Attached file: EO12866_GHGRP_Part_98_2060_AQ81_NRPM_20130516_ 

InteragencyCommentsunderEO13563] 
From: Grogan-McCulloch, Lisa 

Sent: Monday, June 03, 2013 8:33 AM 

To: chiggins@omb.eop.gov 

Cc: Karimjee, Anhar; VanLare, Paula 

Subject: E.O. 12866 Review: Interagency Discussion about Proposed Rule - Inputs to Equations 

Hi Cortney, 

Attached are the 5 documents you requested, as follows: 

* Step 1, Public Availability Analysis 

* Step 2, Competitive Harm Analysis 

* Step 3, Alternative Calculation Methods Analysis 

* Step 4, Alternative Verification Methods Analysis 

* Memo of which "Inputs to Equations" would/would not be reported 

You also mentioned that you'd like to see a list of the 26 new data reporting elements that we're proposing to add. 

These are listed in Table 4 of the preamble (p. 27). 

Also, glad to hear that June 10 from 1-2 works for the demo. I will set up a webinar and include the link in the 

meeting invitation that I send. 

Please let me know if you would like any additional information. 

Best, 

Lisa 

Lisa Grogan-McCulloch 

US EPA 

617-918-1481 

grogan-mcculloch.lisa@epa.gov<mailto:greene.cynthia@epa.gov> 

[Attached file: Memo_List of Inputs Proposed Not To Report] 

[Attached file: Step 1 - Public Availability Analysis] 

[Attached file: Step 2 - Harm Analysis] 

[Attached file: Step 3 - Alternative Calculation Analysis] 

[Attached file: Step 4 -Alternative Verification Methods Analysis] 
From: Bohman, Jennifer 

Sent: Friday, August 02, 2013 2:07 PM 

To: Grogan-McCulloch, Lisa; Higgins, Cortney 

Cc: Karimjee, Anhar 

Subject: RE: Interagency Comments under EO 12563 on GHG Reporting Tool Inputs 

Hi Courtney. 

Attached find the memo describing the IT aspects of the inputs verification tool. Let me know if there are any 

questions. 

Jen Bohman 

US EPA Climate Change Division 

202.343.9548 

[Attached file: Inputs Verifier Description - Memo 8.2] 

[Attached file: Attachment 1 - User Interface] 

[Attached file: Attachment 2 - Data Structure] 

[Attached file: Attachment 3 - Code Structure] 
Attachment B 
US EPA Greenhouse Gas Rep g ortin

Program: Revisions to Reportingand Recordkeeping Requirements, Recordkeeping Requirements,

and Proposed Confidentiality

Determinations

US EPA

Inter‐Agency Briefing

May 29 2013 ,

Draft deliberative - do not cite or quote
Overview

• Background on Greenhouse Gas

Reporting Program

• Background on Confidentiality

Determinations

• 2015 Inputs Proposal: Key Provisio

Draft deliberative - do not cite or quote
Overview: U.S. EPA GHG Reporting

Program ( ) GHGRP

Goal of GHGRP : To collect accurate and timely

data on GHG information to inf f orm uture p y olic decisions

• Rule covers 41 source categories for reporting, accou

85‐90% of U.S. GHG emissions.

• Generally, a facility that meets the emissions thresho

25,000 or more metric tons CO2e per year reports to 

program

• Monitoring began in 2010 for most emission sources 

reports due by reports due by September September 30, 2011.

• Reporting only, no control or use requirements. 

3
Confidentiality Determinations:

Overall Approach

• Several EPA programs collect CBI data; genera

determinations made on case‐by‐case basis

• Ag y enc established that case‐by‐case determi

were not practicable for GHG Reporting Progr

the number of reporters (~10,000) and data e

(~2,000)

– Would not result in timely release of non‐C

– Burden on reporters reporters and the agency

• EPA finalized CBI determinations via rulemakin

most GHGRP data reported data reported

Draft, deliberative - do not quote or cite
Inputs to Equations: Overall

Approach

• In 2010, EPA proposed that “inputs to equations” are emis

– Per Clean Air Act, emission data must be made availabl

• High level of stakeholder interest on “inputs to equations”

– Industry: Submitted comments saying many “inputs to 

have disclosure concerns

– NGOs: Submitted comments asserting importance of co

and releasing “inputs to equations” for data verificatio

• EPA deferred deferred reporting reporting of “inputs to equations equations” until 2013 until 2013 

to allow time to evaluate issue

• 2013 analysis comp ; lete EPA determined no further action 

deferral expired March 31, 2013.

Draft, deliberative - do not quote or cite
2015 Inputs Proposal: Key Provisions (1)

• 2015 analysis complete; due to disclosure concerns, EPA

proposing that most 2015 “inputs to equations” would not 

reported; reported; kept as records records instead instead (approximately (approximately 400 repo

repo

elements)

• For the 2015 “inputs to equations “ without disclosure co

deferral would expire and data would be reported (approx

150 reporting elements).

– Approach Approach consistent consistent with 2013 “Inputs to Equations Equations”

– Subparts include:

• Subpart C (Stationary Fuel Combustion) Non‐part 75 

Generating Units

• Subpart W (Petroleum and Natural Gas)

• Subpart Subpart II (Industrial (Industrial Wastewater Wastewater Treatment) Treatment)• Approximately 40 other inputs spanning across seve

subparts 

Draft deliberative - do not cite or quote
2015 Inputs Proposal: Key Provisions (2)

• For subparts with disclosure concerns, EPA proposing a

enhanced enhanced verification verification approach approach starting starting in RY 2014:

– Use of software where reporters required to enter 

to equations equations”. EPA verifies verifies emissions emissions calculations calculations w

w

these “inputs to equations” being reported to EPA

– 26 new data reporting reporting elements elements added for added for verificat

verificat

– Record retention time extended from current requ

of 3 years to 5 years and “inputs to equations equations” mus

mus

in format generated by software.

Draft deliberative - do not cite or quote
2015 Inputs Proposal: Key

Considerations

• Novel approach approach would provide EPA would provide EPA with ability ability 

calculate the emissions based on the equations 

conduct verification checks as data is being p re 

and provide EPA with information necessary to 

further verification once the annual report is su

– Would help target facilities for follow‐up

• EPA developed developed a prototype of prototype of the software software ver

ver

approach for one subpart; will be available on‐

testing g durin p p ro osal comment period

Draft deliberative - do not cite or quote
Contact Information

For further further information information, please contact: contact:

Lisa Grogan Lisa Grogan‐McCullochGreenhouse Gas Reporting Branch, US EPAgrogan‐mcculloch lisa@epa gov mcculloch.lisa@epa.gov617‐918‐1481

Draft deliberative - do not cite or quote
Appendix A: Definition of Emission

Data

40CFR 2 301(a)(2)(i): .301(a)(2)(i):

“(A) Information necessary to determine the identity, amount, fre

concentration, or other characteristics (to the extent related to a

any emission emission which has been emitted emitted by the source (or of any po

po

resulting from any emission by the source), or any combination oforegoing;

(B) Information Information necessary necessary to determine determine the identity identity, amount, freq

freq

concentration, or other characteristics (to the extent related to a

the emissions which, under an applicable standard or limitation, t

authorized authorized to emit (including (including, to the extent necessary necessary for such pu

such pu

description of the manner or rate of operation of the source); and

Draft deliberative - do not cite or quote
Appendix B: Source Categories Covered in

Proposal

C—General Stationary Fuel Combustionexcept Certain Electric Generators2

U—Miscellaneous Uses of Ca

E—Adipic Acid Production V—Nitric Acid Production

F—Aluminum Production X—Petrochemical Productio

G—Ammonia Manufacturing Y—Petroleum RefineriesH—Cement Production Z—Phosphoric Acid Producti

K—Ferroalloy Production AA—Pulp and Paper Manufa

L—Fluorinated Gas Production BB—Silicon Carbide Product

N—Glass Production Production CC—Soda Ash Manufacturin

Manufacturin

O—HCFC–22 Production and HFC–23

Destruction

EE—Titanium Dioxide Produ

P—Hydrogen Production GG—Zinc Production

Q—Iron and Steel Production II—Industrial Wastewater Tre

R—Lead Production TT—Industrial Waste Landfil

S—Lime Manufacturing W‐ Petroleum and Natural GS Lime Manufacturing W Petroleum and Natural G

Systems

Draft deliberative - do not cite or quote
Attachment C 
The following are excerpts from Mandatory Reporting of Greenhouse Gases: Proposal Preamble, 

April 10, 2009, 74 FR 16448 – 16606 

(http://www.epa.gov/ghgreporting/documents/pdf/archived/Preamble_E9-5711.pdf)

74 FR 16455:

The proposed mandatory GHG reporting program would provide EPA, other government agencies, 

and outside stakeholders with economy-wide data on facility-level (and in some cases corporate-level) 

GHG emissions. Accurate and timely information on GHG emissions is essential for informing some 

future climate change policy decisions. Although additional data collection (e.g., for other source 

categories such as indirect emissions or offsets) may be required as the development of climate policies 

evolves, the data collected in this rule would provide useful information for a variety of policies. For 

example, through data collected under this rule, EPA would gain a better understanding of the relative 

emissions of specific industries, and the distribution of emissions from individual facilities within those 

industries. The facility-specific data would also improve our understanding of the factors that influence 

GHG emission rates and actions that facilities are already taking to reduce emissions. In addition, the data 

collected on some source categories such as landfills and manure management, which can be covered by 

the CAA, could also potentially help inform offset program design by providing fundamental data on 

current baseline emissions for these categories. 

Through this rulemaking, EPA would be able to track the trend of emissions from industries and 

facilities within industries over time, particularly in response to policies and potential regulations. The 

data collected by this rule would also improve the U.S. government’s ability to formulate a set of climate 

change policy options and to assess which industries would be affected, and how these industries would 

be affected by the options. Finally, EPA’s experience with other reporting programs is that such 

programs raise awareness of emissions among reporters and other stakeholders, and thus contribute to 

efforts to identify reduction opportunities and carry them out. 

74 FR 16472: 

Rationale for the Emissions Information To Report 

1.General Content of Reports. 

 Generally, we propose that facilities report emissions for all source categories at the facility for which 

methods have been defined in any subpart of proposed 40 CFR part 98. Facilities would report (1) total 

annual GHG emissions in metric tons CO2e and (2) separately present annual mass emissions of each 

individual GHG for each source category at the facility .59 

Reporting of CO2e allows a comparison of 

total GHG emissions across facilities in varying categories which emit different GHGs. Knowledge of 

both individual gases emitted and total CO2e emissions would be valuable for future policy development 

and help EPA quantify the relative contribution of each gas to a source category’s emissions, while 

maintaining the transparency of reporting total mass of individual gases released by facility, unit, or 

process. 

Emissions would be reported at the level (facility, process, unit) at which the emission calculation 

methods are specified in each applicable subpart. For example, if a pulp and paper mill has three boilers 

and a wastewater treatment operation, the facility would report emissions for each boiler (according to the 

methodologies presented in proposed 40 CFR part 98, subpart C), the wastewater treatment operation 

(according to proposed 40 CFR part 98, subpart II), and from chemical recovery units, lime kilns, and 
makeup chemicals (according to proposed 40 CFR part 98, subpart AA). In addition, the report would 

include summary information on certain process operating data that influence the level of emissions and 

that are necessary to calculate GHG emissions and verify those calculations using the methodologies in 

the rule. Examples of these data include fuel type and amount, raw material inputs, or production output. 

The specific process information to report varies for each source category and is specified in each subpart. 

. . . 

...The information that is proposed to be reported reflects the data that could support analyses of 

GHG emissions for future policy development and ensure the data are accurate and comparable across 

source categories. Besides total facility emissions, it benefits policymakers to understand: (1) The specific 

sources of the emissions and the amounts emitted by each unit/ process to effectively interpret the data, 

and (2) the effect of different processes, fuels, and feedstocks on emissions. This level of reporting should 

not be overly burdensome because many of these data already are routinely monitored and recorded by 

facilities for business reasons. The remainder of the reported data would need to be collected to determine 

GHG emissions. 

The following are excerpts from the Final Greenhouse Gas Reporting Program Rule Preamble, 74 

FR 56260 October 30, 2009. (http://www.gpo.gov/fdsys/pkg/FR-2009-10-30/pdf/E9-23315.pdf)

74 FR 56266:

 As discussed in the proposal, emissions from direct emitters should inform decisions about 

whether and how to use CAA section 111 to establish new source performance standards (NSPS) for 

various source categories emitting GHGs, including whether there are any additional categories of sources 

that should be listed under CAA section 111(b). Similarly, the information required of manufacturers of 

mobile sources should support decisions regarding treatment of those sources under CAA sections 202, 

213 or 231. In addition, the information from fuel suppliers would be relevant in analyzing whether to 

proceed, and particular options for how to proceed, under CAA section 211(c) regarding fuels, or to 

inform action concerning downstream sources under a variety of Title I or Title II provisions. The data 

overall also would inform EPA’s implementation of CAA section 103(g) regarding improvements in 

nonregulatory strategies and technologies for preventing or reducing air pollutants (e.g., EPA’s voluntary 

GHG reduction programs such as the non-CO2 partnership programs and ENERGY STAR, described 

below in Section I.D of this preamble and Section II of the proposal preamble (74 FR 16448, April 10, 

2009)). 

74 FR 56265:

D. How does this rule relate to EPA and U.S. government climate change efforts? 

 ...Accurate and timely information on GHG emissions is essential for informing many future 

climate change policy decisions. Although additional data collection (e.g., for other source categories or 

to support additional policy or program needs) will no doubt be required as the development of climate 

policies evolves, the data collected in this rule will provide useful information for a variety of polices. 

Through data collected under this rule, EPA, States and the public will gain a better understanding of the 

relative emissions of specific industries across the nation and the distribution of emissions from 

individual facilities within those industries. The facility specific data will also improve our understanding 

of the factors that influence GHG emission rates and actions that facilities could in the future or already 

take to reduce emissions, including under traditional and more flexible programs. 
 As discussed in more detail in ‘‘Mandatory Greenhouse Gas Reporting Rule: EPA’s Response to 

Public Comments, Legal Issues’’ and elsewhere, EPA is promulgating this rule to gather GHG 

information to assist EPA in assessing how to address GHG emissions and climate change under the 

Clean Air Act. However, we expect that the information will prove useful for other purposes as well. For 

example, using the rich data set provided by this rulemaking, EPA, States and the public will be able to 

track emission trends from industries and facilities within industries over time, particularly in 

response to policies and potential regulations. The data collected by this rule will also improve the U.S. 

government’s ability to formulate climate policies, and to assess which industries might be affected, and 

how these industries might be affected by potential policies. This GHG reporting program supplements 

and complements, rather than duplicates, existing U.S. government programs (e.g., climate 

policy and research programs). For example, EPA anticipates that facilitylevel GHG emissions data will 

lead to improvements in the quality of the Inventory of U.S. Greenhouse Gas Emissions and Sinks 

(Inventory), which EPA prepares annually, with input from several other agencies, and submits to 

the Secretariat of the United Nations Framework Convention on Climate Change (UNFCCC). 

 A number of EPA voluntary partnership programs include a GHG emissions and/or reductions 

reporting component (e.g., Climate Leaders, the Natural Gas STAR program, Energy Star). This 

mandatory reporting program has broader coverage of U.S. GHG emissions than most voluntary 

programs, which typically focus on a specific industry and/or goal (e.g., reduction of CH4 emissions or 

development of corporate inventories). It will improve EPA’s understanding of emissions from facilities 

not currently included in these programs and increase the coverage of these industries. That said, we 

expect ongoing and potential new voluntary programs to continue to play an important role in achieving 

low-cost reductions in GHG emissions. 

74 FR 56268:

3. What has to be included in the annual GHG report? 

Reporters must include the following information in each annual GHG report: 

 Facility name or supplier name (as appropriate) and physical street address 

 including the city, State, and zip code. 

 Year and months covered by the 

 report, and date of report submittal. 

 For facilities that directly emit GHG: 

—Annual facility emissions (excluding biogenic CO2), expressed in metric 

tons of CO2e per year, aggregated for all GHG from all source categories in 

40 CFR part 98, subparts C through JJ that are located at the facility.... 

...—Additional data specified in the applicable subparts for each source 

category. This includes activity data (e.g., fuel use, feedstock inputs) that were used to generate 

the emissions data and additional data to support QA/QC and emissions verification.... 

74 FR 56277:

I. Summary of Comments and Responses on General Content of the 

Annual GHG Report 
This section contains a brief summary of major comments and responses on the emissions information to 

be reported under the general provisions (40 CFR part 98, subpart A)... 

Comment: EPA received a variety of comments on the general content of the annual GHG reports. Some 

commenters objected to the level of detail required in the annual GHG reports. Some suggested reporting 

only facility-level emissions and keeping as records more detailed emissions breakouts (e.g., by 

source category, process line, or unit) and activity data used to calculate emissions. Other commenters 

supported the proposed general reporting requirements. 

Response: After reviewing the comments, we have not made any major changes in the general content of 

the annual GHG reports since proposal. ... 

...Individual rule subparts for each source category, rather than the General Provisions, identify the 

specific data elements to be reported for that source category. Comments received on the need for specific 

data elements are described and responded to in Section III of this preamble and in relevant source 

category volumes of the ‘‘Mandatory Greenhouse Gas Reporting Rule: EPA’s Response to Public 

Comments’’. Where appropriate, the final rule has been modified based on those comments. In general, 

reporting of such data is required primarily to enable emissions verification and ensure the consistency 

and accuracy of data collected under this rule. The information is also needed to support analyses of GHG 

emissions for future CAA policy and program development. Besides total facility emissions, it 

benefits policy makers to understand: (1) The specific sources of emissions and the amounts emitted by 

each unit/process to effectively interpret the data, and (2) the effect of different processes, fuels, and 

feedstocks on emissions. Many of these data are already routinely monitored and recorded by facilities for 

business reasons. 

... 

74 FR 56287:

R. Summary of Comments and Responses on CBI 

This section contains a brief summary of major comments and responses on CBI issues. A large number 

of comments were received covering numerous topics. Responses to significant comments received can 

be found in ‘‘Mandatory Greenhouse Gas Reporting Rule: EPA’s Response to Public Comments, Legal 

Issues.’’ 

Comment: EPA received numerous comments addressing the issue of CBI. Industry commenters 

generally expressed concern that much of the information reported under this rule would be CBI (e.g., 

production and process data). Many commenters also presented arguments regarding why certain 

information would not be ‘‘emissions data’’ under the CAA. Among the various recommendations were 

that the final rule (i) not require the reporting of such information at all, (ii) require only that the source 

maintain such information on site, but not report it to EPA, and/or (iii) clearly state that some classes of 

information are CBI. Some commenters expressed concern about EPA’s ability to maintain the 

confidentiality of CBI, and thus suggested that EPA should provide further detail regarding how we will 

protect CBI from disclosure. The agricultural industry expressed particular concerns about making 

information about the location of facilities public due to concerns about biosecurity and other potential 

threats. Other commenters favored the wide dissemination of information, and argued that the information 

gathered under this rule should be ‘‘emissions data’’ and hence not protected as CBI. 
Response: As discussed in Section II.N of this preamble, EPA is finalizing its proposal that EPA verify 

the information collected by this rule. Data regarding inputs into emissions calculations and monitoring 

are critical elements of that verification process. Because EPA will routinely need this data in order to 

verify the information collected under this rule, we are not adopting the recommendation that sources 

maintain such information on site and only provide it during an inspection or when otherwise 

specifically requested. 

 EPA also recognizes the importance of this issue to both reporters and the public. EPA’s public 

information regulations contain a definition of ‘‘emissions data’’ at 40 CFR 2.301, and EPA has 

discussed in an earlier Federal Register notice what data elements constitute emissions data that cannot 

be withheld as CBI (56 FR 7042–7043, February 21, 1991).... 

Excerpt from 74 FR 56282:

N. Summary of Comments and Responses on Emissions Verification Approach 

This section contains a brief summary of major comments and responses on emissions verification of the 

GHG reports. A large number of comments were received covering numerous topics. Responses to 

significant comments received can be found in ‘‘Mandatory Greenhouse Gas Reporting Rule: EPA’s 

Response to Public Comments, Approach to Verification and Missing Data.’’ 

Comment: Many commenters, including most facilities and suppliers required to report under the rule and 

several other stakeholders, supported EPA’s proposal to require self certification with EPA verification of 

GHG reports. These commenters provided a variety of reasons. Many supported EPA emissions 

verification because the alternative of third party verification would be more costly to reporters. Several 

also commented that EPA emissions verification would provide a consistent and transparent data set... 

 

 ...A smaller number of commenters favored self-certification without independent emissions 

verification. They believed the designated representative provisions in the rule would cause reporters to 

take self certification seriously and ensure the emissions they report are correct. Some also stated that 

independent verification is not needed for a reporting program that does not require emissions 

reductions. 

Response: In selecting the approach to emissions verification, EPA reviewed all of the comments, as well 

as emissions verification requirements and procedures under a number of existing EPA regulatory 

programs and domestic and international GHG reporting programs. Based on this review, EPA considered 

three alternatives: (1) Self certification without independent verification, (2) self-certification with third 

party verification, and (3) self certification with EPA verification. For this particular program, EPA is not 

changing the verification approach from the proposal and is requiring self certification with EPA 

emissions verification. We decided to retain this verification approach because it provides greater 

assurance of accuracy and impartiality than self-certification without verification, and has a number of 

advantages over third party verification for this type of Federal program. Our objective with emissions 

verification in this program is to ensure collection and dissemination of high quality data while providing 

the reporters a ‘‘level playing field’’ in terms of requirements and process. 

 To enable effective review of the large volume of data reported, the rule requires reporters to 

submit data electronically in a standard format through a centralized data system. EPA is developing this 
system and intends to make it available to reporters, along with training and instructional materials, 

before the reporting deadlines. To the extent possible, EPA will leverage existing reporting systems and 

work with other State and regional programs and systems to develop a reporting scheme that minimizes 

the burden on reporters. 

 In implementing the emissions verification under this rule, EPA envisions a two step process. 

First, we will conduct an initial centralized review of the data which will be largely automated. EPA 

intends to build into the data system an electronic data QA program for use by reporters and EPA to help 

assure the completeness and accuracy of data. In addition, to verify reported data and ensure consistency, 

EPA may review facility-level monitoring plans and procedures, and will perform detailed, automated 

checks on data utilizing recent and historical data submittals, comparison against like facilities and/or 

other electronic audit tools where appropriate. Second, EPA intends to follow-up with facilities should 

potential errors, discrepancies, or questions arise through the review of reported data and conduct on-site 

audits of selected facilities. The on-site audits may be conducted by private verifiers contracted by EPA 

or by Federal, State or local personnel, as appropriate. We plan to coordinate closely with the States to 

develop an efficient approach toward on-site auditing that can meet the needs of multiple programs. We 

do not anticipate conducting on-site audits of every facility every year. 

 EPA decided to finalize the rule with EPA emissions verification for several reasons. First, we 

determined that the combination of comprehensive electronic review and a flexible and adaptive program 

of on-site auditing will enable us to effectively target verification resources while also providing the 

necessary consistency and quality in the data. Utilizing the national data set developed under this rule will 

provide unique resources for the review of reports. A centralized emissions verification system provides 

greater ability for EPA to identify trends and outliers in data and thus assist with targeted follow-up 

review, and our approach can evolve over time as we gain experience with GHG reporting. This approach 

also provides opportunity to work closely with and leverage both the experience and ongoing activities of 

States and others already engaged in similar and different types of GHG reporting. 

 Our emissions verification approach in this rule is consistent with other EPA emission reporting 

programs and follows a model similar to the ARP which is a highly successful emissions cap and trade 

program that consistently produces credible, high-quality data. Facilities regulated under ARP must have 

a Designated Representative sign data reports to self-certify that the reported data are accurate. Then, 

facilities and EPA use a series of electronic tools to ensure proper data collection and reporting, including 

establishing a monitoring plan, calibrating equipment to certain specifications, frequent testing and data 

submittal. Similar to what we are intending with this program, EPA conducts site audits on those facilities 

targeted during the electronic review as having been outliers or had anomalies in their reported data. 

These audits are done by EPA personnel, States and/or contractors to EPA. We support these 

audits by providing a field audit manual to both government and private auditors as well as additional 

training to State and Federal auditors. ... 

 

 ...EPA received a smaller number of comments in support of self certification without emissions 

verification. While recognizing that this approach would place a low burden on both reporters and the 

government, it also has major disadvantages. Without any verification of submitted reports, there is far 

greater potential for inconsistent and inaccurate data and this will result in less confidence at EPA and 

with public stakeholders in the data. These disadvantages would make the data collected under this option 

less useful for informing decisions on climate policy and supporting the development of potential future 

policies and regulations. 
Attachment D 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

1 

DATE: May 2013 

TO: Docket EPA-HQ-OAR-2010-0929 

FROM: Lisa Grogan-McCulloch 

SUBJECT: Data Elements Deferred to March 31, 2015: List of Data Elements Proposed 

Not To Be Reported

Table 1 lists the data elements for which reporting is deferred to March 31, 2015 (“inputs to equations”

data elements) that are proposed not to be reported, as specified in the proposed rulemaking “Revisions

to Reporting and Recordkeeping Requirements, and Proposed Confidentiality Determinations under the

Greenhouse Gas Reporting Program.” Table 2 lists the “inputs to equations” data elements that EPA is

not proposing to amend in this action; as a result, these data elements would be reported under the

proposed rulemaking.

Table 1. List of “Inputs to Equations” Data Elements Proposed Not To Be Reported1 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.3(d)(3)(v) For any facility who submitted an abbreviated emissions report under 

§98.3(d)(3)(v), any facility operating data or process information used for 

the GHG emission calculations. 

N/A 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(b)(9)(iii) Estimate of the heat input from each type of fuel listed in Table C-2 that 

was combusted in the unit during the report year. 

C-10 
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2 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(c)(2)(ix) The flue gases from two or more stationary fuel combustion units at a 

facility are combined together and discharged through a common stack or 

duct before exiting to the atmosphere and if CEMS are used to 

continuously monitor CO2 mass emissions at the common stack or duct 

according to the Tier 4 Calculation Methodology, you may report the 

combined emissions from the units sharing the common stack or duct, in 

lieu of separately reporting the GHG emissions from the individual units. 

This monitoring and reporting alternative may also be used when process 

off-gases or a mixture of combustion products and process gases are 

combined together in a common stack or duct before exiting to the 

atmosphere. An estimate of the heat input from each type of fuel listed in 

Table C-2 combusted during the reporting year. 

C-10 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(i) Total quantity of each type of fuel combusted in each unit or group of 

aggregated units (as applicable) during the reporting year, in short tons for 

solid fuels, gallons for liquid fuels and standard cubic feet for gaseous 

fuels, or, if applicable, therms or mmBtu for natural gas. 

C-1 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(i) Total quantity of each type of fuel combusted in each unit or group of 

aggregated units (as applicable) during the reporting year, in short tons for 

solid fuels, gallons for liquid fuels and standard cubic feet for gaseous 

fuels, or, if applicable, therms or mmBtu for natural gas. 

C-1a 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(i) Total quantity of each type of fuel combusted in each unit or group of 

aggregated units (as applicable) during the reporting year, in short tons for 

solid fuels, gallons for liquid fuels and standard cubic feet for gaseous 

fuels, or, if applicable, therms or mmBtu for natural gas. 

C-1b 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

3 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(i) Total quantity of each type of fuel combusted in each unit or group of 

aggregated units (as applicable) during the reporting year, in short tons for 

solid fuels, gallons for liquid fuels and standard cubic feet for gaseous 

fuels, or, if applicable, therms or mmBtu for natural gas. 

C-8 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(ii)(A) For Tier 2: Total quantity of each type of fuel combusted in the unit or 

group of aggregated units (as applicable) during each month of the 

reporting year. Express the quantity of each fuel combusted during the 

measurement period in short tons for solid fuels, gallons for liquid fuels, 

and scf for gaseous fuels. 

C-2b 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(ii)(C) High heat values used in the CO2 emissions calculations for each fuel 

combusted during the reporting year. Report a HHV value for each 

calendar month in which HHV determination is required. If multiple 

values are obtained in a given month, report the arithmetic average value 

for the month. 

C-2b 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(ii)(D) If Eq. C-2c is used: Ratio of the maximum rate heat input capacity to the 

design rated steam output capacity of the unit. 

C-2c 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(ii)(D) If Eq. C-2c is used: Total quantity (i.e., pounds) of steam produced from 

MSW or solid fuel combustion during each month of the reporting year. 

C-2c 
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Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as 

applicable) during each month of the reporting year (Fuel). 

C-13 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as 

applicable) during each month of the reporting year (Fuel). 

C-3 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as 

applicable) during each month of the reporting year (Fuel) 

C-4 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as 

applicable) during each month of the reporting year (Fuel). 

C-5 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as 

applicable) during each month of the reporting year (Fuel). 

C-8 
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Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as 

applicable) during each month of the reporting year (Fuel). 

C-8a 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as 

applicable) during each month of the reporting year (Fuel). 

C-8b 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(iv)(C) The carbon content used in the emission calculations (including both valid 

and substitute data values). For each calendar month of the reporting year 

in which carbon content and, if applicable, molecular weight 

determination is required, report a value of each parameter. If multiple 

values of a parameter are obtained in a given month, report the arithmetic 

average value for the month. (CC). 

C-3 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(iv)(C) The carbon content used in the emission calculations (including both valid 

and substitute data values). For each calendar month of the reporting year 

in which carbon content and, if applicable, molecular weight 

determination is required, report a value of each parameter. If multiple 

values of a parameter are obtained in a given month, report the arithmetic 

average value for the month. (CC). 

C-4 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(iv)(C) The carbon content used in the emission calculations (including both valid 

and substitute data values). For each calendar month of the reporting year 

in which carbon content and, if applicable, molecular weight 

determination is required, report a value of each parameter. If multiple 

values of a parameter are obtained in a given month, report the arithmetic 

average value for the month. (CC). 

C-5 
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6 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(iv)(C) Gas molecular weight values used in the emission calculations (including 

both valid and substitute data values). For each calendar month of the 

reporting year in which carbon content and, if applicable, molecular 

weight determination is required, report a value of each parameter. If 

multiple values of a parameter are obtained in a given month, report the 

arithmetic average value for the month. 

C-5 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(iv)(F) The annual average HHV, when measured HHV data, rather than a default 

HHV from Table C-1 of this subpart, are used to calculate CH4 and N2O 

emissions for a Tier 3 unit, in accordance with §98.33(c)(1). 

C-8 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(ix)(D) For units that combust both fossil fuel and biomass, when biogenic CO2 is 

determined according to §98.33(e)(2), report the carbon-based F-factor 

used in Equation C-13 of this subpart. 

C-13 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(ix)(E) For units that combust both fossil fuel and biomass, when biogenic CO2 is 

determined according to §98.33(e)(2), report the annual average HHV 

value used in Equation C-13 of this subpart. 

C-13 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(ix)(F) For units that combust both fossil fuel and biomass, when biogenic CO2 is 

determined according to §98.33(e)(2), report the total quantity of fossil 

fuel combusted during the reporting year. 

C-13 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

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Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

E §98.56(b) Total annual adipic acid production from unit “z” (Pz). E-2 

E §98.56(b) Total annual adipic acid production from unit “z” (Pz). E-3a 

E §98.56(b) Total annual adipic acid production from unit “z” (Pz). E-3b 

E §98.56(b) Total annual adipic acid production from unit “z” (Pz). E-3c 

E §98.56(b) Total annual adipic acid production from unit “z” (Pz). E-3d 

E §98.56(c) Annual adipic acid production during which N2O abatement technology 

(located after the test point) is operating (Pz,N) . 

E-2 

E §98.56(j)(1) Emission factor for each unit (EFN2Oz). E-3a 

E §98.56(j)(1) Emission factor for each unit (EFN2O). E-3b 

E §98.56(j)(1) Emission factor for each unit (EFN2O). E-3c 

E §98.56(j)(1) Emission factor for each unit (EFN2O). E-3d 

E §98.56(j)(3) Production rate per test run during performance test for each unit (P). E-1 

F §98.66(a) Annual aluminum production. (MP) F-5 

F §98.66(a) Annual aluminum production. (MP) F-6 

F §98.66(c)(2) Anode effect minutes per cell-day. (AEM) F-2 

F §98.66(c)(2) Anode effect overvoltage factor. (EFCF4) F-3 

F §98.66(c)(2) Anode effect frequency. Used to calculate 

AEM and the 

slope coefficients 

used as an input 

in Eq. F-2 

F §98.66(c)(2) Anode effect duration. Used to calculate 

AEM and the 

slope coefficients 

used as an input 

in Eq. F-2 

F §98.66(c)(2) Potline overvoltage. Used to calculate 

the overvoltage 

factor used as an 

input in Eq. F-3 

F §98.66(c)(2) Current efficiency. Used to calculate 

the overvoltage 

factor used as an 

input in Eq. F-3 

F §98.66(c)(3) Smelter-specific slope coefficients. (SCF4) F-2 

F §98.66(c)(3) Overvoltage emission factors. (EFCF4) F-3 

F §98.66(e)(1) Annual anode consumption. (No CEMS) (NAC ) F-5 
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Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

F §98.66(f)(1) Annual paste consumption. (No CEMS) (PC ) F-6 

F §98.66(g) Sulfur content in baked anode (percent weight). (Sa) F-5 

F §98.66(g) Ash content in baked anode (percent weight). (Asha) F-5 

F §98.66(g) Binder content of paste (percent weight). (BC) F-6 

F §98.66(g) Sulfur content of pitch (percent weight). (Sp) F-6 

F §98.66(g) Ash content of pitch (percent weight). (Ashp) F-6 

F §98.66(g) Hydrogen content of pitch (percent weight). (Hp) F-6 

F §98.66(g) Sulfur content in calcined coke (percent weight). (Sc) F-6 

F §98.66(g) Ash content in calcined coke (percent weight). (Ashc) F-6 

F §98.66(g) Carbon in skimmed dust from Soderberg cells (metric ton C/metric ton 

Al) (CD). 

F-6 

F §98.66(g) Initial weight of green anodes (metric tons) (GA). F-7 

F §98.66(g) Annual hydrogen content in green anodes (metric tons) (Hw). F-7 

F §98.66(g) Annual baked anode production (metric tons) (BA). F-7 

F §98.66(g) Annual waste tar collected (metric tons) (WT). F-7 

F §98.66(g) Annual packing coke consumption (metric tons/metric ton baked anode) 

(PCC). 

F-8 

F §98.66(g) Annual baked anode production (metric tons) (BA). F-8 

F §98.66(g) Sulfur content in packing coke (percent weight) (SPc). F-8 

F §98.66(g) Ash content in packing coke (percent weight) (Ashpc). F-8 

G §98.76(b)(2) Monthly quantity of each type of feedstock consumed for ammonia 

manufacturing - Gaseous Feedstock. 

G-1 

G §98.76(b)(2) Monthly quantity of each type of feedstock consumed for ammonia 

manufacturing - Liquid Feedstock. 

G-2 

G §98.76(b)(2) Monthly quantity of each type of feedstock consumed for ammonia 

manufacturing - Solid Feedstock. 

G-3 

G §98.76(b)(7) Carbon content of the gaseous feedstock. G-1 

G §98.76(b)(8) Molecular weight of the gaseous feedstock. G-1 

G §98.76(b)(9) 3 Molar volume conversion factor of the gaseous feedstock. G-1 

G §98.76(b)(10) Carbon content of the liquid feedstock, for month n. G-2 

G §98.76(b)(11) Carbon content of the solid feedstock, for month n. G-3 

H §98.86(b)(2) Monthly clinker production for each kiln (No CEMS). H-2 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

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Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

H §98.86(b)(5) Quarterly quantity of CKD not recycled to the kiln. H-2 

H §98.86(b)(6) Monthly fraction of total CaO in clinker. H-3 

H §98.86(b)(6) Monthly fraction of total MgO in clinker. H-3 

H §98.86(b)(6) Monthly fraction of non-calcined CaO in clinker. H-3 

H §98.86(b)(6) Monthly fraction of non-calcined MgO in clinker. H-3 

H §98.86(b)(8) Quarterly fraction of total CaO in CKD not recycled to the kiln. H-4 

H §98.86(b)(8) Quarterly fraction of total MgO in CKD not recycled to the kiln. H-4 

H §98.86(b)(8) Quarterly fraction of non-calcined CaO in CKD not recycled to the kiln. H-4 

H §98.86(b)(8) Quarterly fraction of non-calcined MgO in CKD not recycled to the kiln. H-4 

H §98.86(b)(10) Monthly kiln-specific clinker CO2 emission factors for each kiln. H-2 

H §98.86(b)(12) Annual organic carbon content of each raw kiln feed or annual organic 

carbon content of each raw material. 

H-5 

H §98.86(b)(13) Annual consumption of each raw kiln feed or annual consumption of each 

raw material. 

H-5 

H §98.86(b)(15) Monthly kiln-specific raw kiln feed to clinker produced factors (if used) 

for each kiln. 

Used to calculate 

clinker 

production by 

facilities using the 

method in 40 

CFR 98.84(d) 

(i.e., kiln-specific 

clinker-to-feed 

factors) 

K §98.116(b) Annual production by product from each EAF (tons) (used as input to Eq 

K-1): Mproductk= Annual mass of alloy product k tapped from EAF 

(tons). 

K-1 

K §98.116(b) Annual production by product from each EAF (tons) (used as input to Eq 

K-3). 

K-3 

K §98.116(e)(4) Annual material quantity for each material included for the calculation of 

annual process CO2 emissions (No CEMS): Mreducing agenti= Annual 

mass of reducing agent i fed, charged, or otherwise introduced into the 

EAF (tons). 

K-1 

K §98.116(e)(4) Annual material quantity for each material included for the calculation of 

annual process CO2 emissions (No CEMS): Melectrodem= Annual mass 

of carbon electrode m consumed in the EAF (tons). 

K-1 

K §98.116(e)(4) Annual material quantity for each material included for the calculation of 

annual process CO2 emissions (No CEMS): Moreh= Annual mass of ore h 

charged to the EAF (tons). 

K-1 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

10 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

K §98.116(e)(4) Annual material quantity for each material included for the calculation of 

annual process CO2 emissions (No CEMS): Mfluxj= Annual mass of flux 

material j fed, charged, or otherwise introduced into the EAF to facilitate 

slag formation (tons). 

K-1 

K §98.116(e)(4) Annual material quantity for each material included for the calculation of 

annual process CO2 emissions (No CEMS): Mnon-product outgoingl= 

Annual mass of non-product outgoing material l removed from EAF 

(tons). 

K-1 

K §98.116(e)(5) Annual average of the carbon content determinations for each material 

included for the calculation of annual process CO2 emissions (No CEMS): 

Creducing agenti= Carbon content in reducing agent i (percent by weight, 

expressed as a decimal fraction). 

K-1 

K §98.116(e)(5) Annual average of the carbon content determinations for each material 

included for the calculation of annual process CO2 emissions (No CEMS): 

Celectrodem= Carbon content of the carbon electrode m (percent by 

weight, expressed as a decimal fraction). 

K-1 

K §98.116(e)(5) Annual average of the carbon content determinations for each material 

included for the calculation of annual process CO2 emissions (No CEMS): 

Coreh= Carbon content in ore h (percent by weight, expressed as a 

decimal fraction). 

K-1 

K §98.116(e)(5) Annual average of the carbon content determinations for each material 

included for the calculation of annual process CO2 emissions (No CEMS): 

Cfluxj= Carbon content in flux material j (percent by weight, expressed as 

a decimal fraction). 

K-1 

K §98.116(e)(5) Annual average of the carbon content determinations for each material 

included for the calculation of annual process CO2 emissions (No CEMS): 

Cproductk= Carbon content in alloy product k . (percent by weight, 

expressed as a decimal fraction). 

K-1 

K §98.116(e)(5) Annual average of the carbon content determinations for each material 

included for the calculation of annual process CO2 emissions (No CEMS): 

Cnon-product outgoingl= Carbon content in non-product outgoing 

material l (percent by weight, expressed as a decimal fraction). 

K-1 

L §98.126(b)(1) Elements of the sum (a, b, c, etc.) (e.g., measured variables in the sum). L-1 

L §98.126(b)(1) 3 eSA (absolute error of the sum, expressed as one half of a 95 percent 

confidence interval). Note that where eSA = the overall absolute error 

calculated for the process emissions you report under §98.126(a)(2), this 

data element was not deferred in the inputs deferral rule (76 FR 53057, 

August 25, 2011), and would be required to be reported. 

L-1 

L §98.126(b)(1) 3 ea, eb, ec = Relative error of a, b, or c, respectively, expressed as one half 

of a 95 percent confidence interval. 

L-1 

L §98.126(b)(1) Elements of the sum (a, b, c, etc.) (e.g., measured variables in the sum). L-2 

L §98.126(b)(1) a+b+c = Sum of the variables measured. L-2 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

11 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

L §98.126(b)(1) 3 eSR (relative error of the sum, expressed as one half of a 95 percent 

confidence interval). Note that where eSR = the overall relative error 

calculated for the process emissions you report under §§98.126(a)(2), this 

data element was not deferred in the inputs deferral rule (76 FR 53057, 

August 25, 2011), and would be required to be reported. 

L-2 

L §98.126(b)(1) 3 eSA (absolute error of the sum, expressed as one half of a 95 percent 

confidence interval). Note that where eSA = the overall absolute error 

calculated for the process emissions you report under §98.126(a)(2), this 

data element was not deferred in the inputs deferral rule (76 FR 53057, 

August 25, 2011) , and would be required to be reported. 

L-2 

L §98.126(b)(1) Elements of the sum (a, b, c, etc.) (e.g., measured variables in the sum). L-3 

L §98.126(b)(1) 3 ea, eb, ec = Relative error of a, b, or c, respectively, expressed as one half 

of a 95 percent confidence interval. 

L-3 

L §98.126(b)(1) 3 ePA (absolute error of the product, expressed as one half of a 95 percent 

confidence interval). Note that where ePA = the overall absolute error 

calculated for the process emissions you report under §98.126(a)(2), this 

data element was not deferred in the inputs deferral rule (76 FR 53057, 

August 25, 2011) , and would be required to be reported. 

L-3 

L §98.126(b)(1) a*b*c = Product of the variables measured. L-3 

L §98.126(b)(1) Measured variables of the product (a, b, c, etc.). L-4 

L §98.126(b)(1) a*b*c = Product of the variables measured. L-4 

L §98.126(b)(1) 3 ePR (relative error of the product, expressed as one half of a 95 percent 

confidence interval). Note that where ePR = the overall relative error 

calculated for the process emissions you report under §98.126(a)(2), this 

data element was not deferred in the inputs deferral rule (76 FR 53057, 

August 25, 2011) , and would be required to be reported. 

L-4 

L §98.126(b)(1) 3 ePA (absolute error of the product, expressed as one half of a 95 percent 

confidence interval). Note that where ePA = the overall absolute error 

calculated for the process emissions you report under §98.126(a)(2), this 

data element was not deferred in the inputs deferral rule (76 FR 53057, 

August 25, 2011) , and would be required to be reported. 

L-4 

L §98.126(b)(2) The balanced chemical equation that describes the reaction used to 

manufacture the fluorinated GHG product and each fluorinated GHG 

transformation product. 

 

L §98.126(b)(6) The mass of each fluorine-containing reactant that is fed into the process. 

(Rd) 

L-6 

L §98.126(b)(7) The mass of each fluorine-containing product produced by the process. (P) L-6 

L §98.126(b)(8)(i) The mass of each fluorine-containing product that is removed from the 

process and fed into the destruction device (metric tons). (Pj) 

L-7 

L §98.126(b)(8)(ii) The mass of each fluorine-containing by-product that is removed from the 

process and fed into the destruction device (metric tons). (Bkj) 

L-7 

L §98.126(b)(8)(iii) The mass of each fluorine-containing reactant that is removed from the 

process and fed into the destruction device (metric tons). (Rdj) 

L-7 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

12 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

L §98.126(b)(8)(iv) The mass of each fluorine-containing by-product that is removed from the 

process and recaptured (metric tons). (Bkl) 

L-7 

L §98.126(b)(8)(v) The demonstrated destruction efficiency of the destruction device for each 

fluorinated GHG fed into the device from the process in greater than trace 

concentrations (fraction). (DEFGHGf= Destruction efficiency of the 

device that has been demonstrated for fluorinated GHG f in stream j 

(fraction).) 

L-8 

L §98.126(b)(9)(i) The mass of fluorine in each stream that is fed into the destruction device 

(metric tons). (cTFj * Sj) 

L-17 

L §98.126(b)(9)(ii) The mass of fluorine that is recaptured (metric tons). (cTFl * Sl) L-17 

L §98.126(b)(9)(iii) The weighted average destruction efficiency of the destruction device 

calculated for each stream under §98.123(b)(16). (DEavgj) 

L-17 

L §98.126(c)(1) The quantity of the process activity used to estimate emissions (e.g., tons 

of product produced or tons of reactant consumed). (ActivityC or 

ActivityU) 

L-21 

L §98.126(c)(1) The quantity of the process activity used to estimate emissions (e.g., tons 

of product produced or tons of reactant consumed). (ActivityC or 

ActivityU) 

L-22 

L §98.126(c)(1) The quantity of the process activity used to estimate emissions (e.g., tons 

of product produced or tons of reactant consumed). (Activity) 

L-26 

L §98.126(c)(1) The quantity of the process activity used to estimate emissions (e.g., tons 

of product produced or tons of reactant consumed). (ActivityU or 

ActivityC) 

L-27 

L §98.126(c)(2) The site-specific, process-vent-specific emission factor(s) for each process 

vent (EFPV). 

L-20 

L §98.126(c)(2) The site-specific, process-vent-specific emission factor(s) for each process 

vent (EFPV–C). 

L-21 

L §98.126(c)(2) The site-specific, process-vent-specific emission calculation factor for 

each process vent. (ECFPV-U). 

L-21 

L §98.126(c)(2) The site-specific, process-vent-specific emission factor(s) for each process 

vent (EFPV–U). 

L-22 

L §98.126(c)(2) The site-specific, process-vent-specific emission factor(s) for each process 

vent. (EFPV) 

L-23 

L §98.126(c)(2) The site-specific, process-vent-specific emission calculation factor for 

each process vent. (ECFPV). 

L-25 

L §98.126(c)(2) The site-specific, process-vent-specific emission calculation factor for 

each process vent (ECFPV). 

L-26 

L §98.126(c)(2) The site-specific, process-vent-specific emission calculation factor for 

each process vent. (ECFPV). 

L-27 

L §98.126(d) Where missing data have been estimated pursuant to §98.125 report, 

estimate of the missing data. 

Varies 

L §98.126(f)(1) Destruction efficiency (DE) of each destruction device for each 

fluorinated GHG whose destruction the facility reflects in §98.123, in 

accordance with §98.124(g)(1)(i) through (iv). (DEFGHGf) 

L-8 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

13 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

L §98.126(f)(1) Destruction efficiency (DE) of each destruction device for each 

fluorinated GHG whose destruction the facility reflects in §98.123, in 

accordance with §98.124(g)(1)(i) through (iv). (DEFGHGf) 

L-18 

L §98.126(f)(1) Destruction efficiency (DE) of each destruction device for each 

fluorinated GHG whose destruction the facility reflects in §98.123, in 

accordance with §98.124(g)(1)(i) through (iv). (DE ) 

L-22 

L §98.126(f)(1) Destruction efficiency (DE) of each destruction device for each 

fluorinated GHG whose destruction the facility reflects in §98.123, in 

accordance with §98.124(g)(1)(i) through (iv) (DE). 

L-27 

L §98.126(f)(1) Destruction efficiency (DE) of each destruction device for each 

fluorinated GHG whose destruction the facility reflects in §98.123, in 

accordance with §98.124(g)(1)(i) through (iv) (DE). 

L-31 

L §98.126(g)(1) The mass of the fluorinated GHG fed into the destruction device. (RED) L-31 

L §98.126(h)(2) If applicable, the heel factor calculated for each container size and type. 

(hfj) 

L-34 

N §98.146(b)(6) Fraction of calcination for carbonate-based raw material. N-1 

N §98.146(b)(2) Annual quantity of carbonate based-raw material charged to each 

continuous glass melting furnace (No CEMS). 

N-1 

N §98.146(b)(4) Carbonate-based mineral mass fraction of carbonate-based raw material 

charged to a furnace. 

N-1 

O §98.156(a)(2) Loss Factor used to account for the loss of HCFC– 22 upstream of the 

measurement (LF used in equation O-3). 

O-3 

O §98.156(a)(7) Annual mass of the HFC-23 generated (G23 in Eq. O-4). O-4 

O §98.156(a)(8) Annual mass of any HFC-23 sent off site for sale (S23 in Eq. O-4). O-4 

O §98.156(a)(9) Annual mass of any HFC-23 sent off site for destruction (OD23 used in Eq. 

O-4). 

O-4 

O §98.156(a)(10) Mass of HFC-23 in storage at the beginning of the year (used to calculate 

I23, which is used in Eq. O-4). 

O-4 

O §98.156(a)(10) Mass of HFC-23 in storage at the end of the year (used to calculate I23, 

which is used in Eq. O-4). 

O-4 

O §98.156(b)(1) Annual mass of HFC-23 fed into the destruction device (FD used in Eq. 

O-8 and O-9). 

O-8 

O §98.156(b)(1) Annual mass of HFC-23 fed into the destruction device (FD used in Eq. 

O-8 and O-9). 

O-9 

O §98.156(b)(2) Annual mass of HFC-23 destroyed (D23 used in Eq. O-8). O-8 

O §98.156(d)(1) If the HFC-23 concentration measured pursuant to §98.154(l) is greater 

than that measured during the performance test that is the basis for the 

destruction efficiency (DE), report flow rate of HFC-23 being fed into the 

destruction device in kg/hr. 

No Equation - 

Used to calculate 

Destruction 

Efficiency 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

14 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

O §98.156(d)(5) If the HFC-23 concentration measured pursuant to §98.154(l) is greater 

than that measured during the performance test that is the basis for the 

destruction efficiency (DE), report the destruction efficiency (DE) 

calculated from paragraphs (d)(1) and (d)(4) of this section. 

O-9 

O §98.156(e)(1) (One time report) Destruction efficiency (DE) (by March 31, 2011 or 

within 60 days of commencing HFC-23 destruction). 

O-9 

P §98.156(b)(2) Monthly consumption of each fuel and feedstock by type used for 

hydrogen production (No CEMS): gaseous. 

P-1 

P §98.156(b)(2) Monthly consumption of each fuel and feedstock by type used for 

hydrogen production (No CEMS) (Fdstkn): Liquid. 

P-2 

P §98.156(b)(2) Monthly consumption of each fuel and feedstock by type used for 

hydrogen production (No CEMS) (Fdstkn): solid. 

P-3 

P §98.156(b)(5) Monthly analyses of carbon content for each fuel and feedstock used in 

hydrogen production: Gaseous. 

P-1 

P §98.156(b)(5) Monthly analyses of carbon content for each fuel and feedstock used in 

hydrogen production: Liquid. 

P-2 

P §98.156(b)(5) Monthly analyses of carbon content for each fuel and feedstock used in 

hydrogen production: Solid. 

P-3 

P §98.156(b)(6) Monthly analyses of the molecular weight of gaseous fuels and 

feedstocks. 

P-1 

Q §98.176(b) Annual quantity taconite pellets produced (No CEMS). Q-1 

Q §98.176(b) Annual quantity coke produced (No CEMS). Q-2 

Q §98.176(b) Annual quantity iron produced (No CEMS and not using the site-specific 

EF method under §98.173(b)(2)). 

Q-2 

Q §98.176(b) Annual quantity raw steel produced (No CEMS and not using the sitespecific EF method under §98.173(b)(2)). Q-2 

Q §98.176(b) Annual quantity sinter produced (No CEMS and not using the site-specific 

EF method under §98.173(b)(2)). 

Q-4 

Q §98.176(b) Annual quantity raw steel produced (No CEMS and not using the sitespecific EF method under §98.173(b)(2)). Q-5 

Q §98.176(b) Annual quantity raw steel produced (No CEMS and not using the sitespecific EF method under §98.173(b)(2)). Q-6 

Q §98.176(b) Annual quantity iron produced (No CEMS and not using the site-specific 

EF method under §98.173(b)(2)). 

Q-7 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions 

(No CEMS) - solid fuel combusted (Csf). 

Q-1 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions 

(No CEMS) -gaseous fuel combusted(Cgf). 

Q-1 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions 

(No CEMS)- liquid fuel combusted (Clf). 

Q-1 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

15 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions 

(No CEMS)- greenball pellets produced (Co). 

Q-1 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions 

(No CEMS) - Fired pellets produced (Cp). 

Q-1 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions 

(No CEMS) - air pollution control residue collected (Cr). 

Q-1 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions 

(No CEMS)- Iron (Ciron). 

Q-2 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions 

(No CEMS)- Scrap (Cscrap). 

Q-2 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions 

(No CEMS)- Flux (Cflux). 

Q-2 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions 

(No CEMS)- Carbonaceous material (Ccarbon). 

Q-2 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions 

(No CEMS) - Steel produced (Csteel). 

Q-2 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions 

(No CEMS) - Slag produced (Cslag). 

Q-2 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions 

(No CEMS) - Air pollution control residue collected (CR). 

Q-2 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions 

(No CEMS)- Coal charged to coke battery (Ccoal). 

Q-3 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions 

(No CEMS) - Coke produced by coke battery (Ccoke). 

Q-3 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions 

(No CEMS) - Air pollution control residue collected from coke battery 

(CR). 

Q-3 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions 

(No CEMS)- Gaseous fuel combusted in the sinter process (Cgf). 

Q-4 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions 

(No CEMS) - sinter feed (CFeed). 

Q-4 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions 

(No CEMS) - sinter (CSinter). 

Q-4 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions 

(No CEMS) - Air pollution control residue collected from sinter process 

(CR). 

Q-4 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions 

(No CEMS)- Iron (Ciron) used in EAF. 

Q-5 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions 

(No CEMS)- Scrap (Cscrap) used in EAF. 

Q-5 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

16 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions 

(No CEMS)- Flux (Cflux) used in EAF. 

Q-5 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions 

(No CEMS)- Carbonaceous material (Ccarbon) used in EAF. 

Q-5 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions 

(No CEMS)- Electrode consumed in EAF (Celectrode). 

Q-5 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions 

(No CEMS) - Steel produced (Csteel) in EAF. 

Q-5 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions 

(No CEMS) - Slag produced (Cslag) in EAF. 

Q-5 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions 

(No CEMS) - Air pollution control residue collected (CR) for EAF. 

Q-5 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions 

(No CEMS) - molten steel before decarburization (Csteelout) in EAF. 

Q-6 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions 

(No CEMS) - molten steel after decarburization (Csteelout) in EAF. 

Q-6 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions 

(No CEMS) - Air pollution control residue collected (CR) for EAF. 

Q-6 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions 

(No CEMS) - Gaseous fuel combusted in the direct reduction furnace (Fg) 

. 

Q-7 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions 

(No CEMS) - iron ore or iron ore pellets fed into the direct reduction 

furnace (Core) . 

Q-7 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions 

(No CEMS)- Carbonaceous material (Ccarbon) used in the direct reduction 

furnace . 

Q-7 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions 

(No CEMS) - Other materials charged to the direct reduction furnace 

(Cother). 

Q-7 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions 

(No CEMS) - Iron produced from direct reduction furnace (Ciron). 

Q-7 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions 

(No CEMS) - Non-metallic materials produced from direct reduction 

furnace (CNM). 

Q-7 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions 

(No CEMS) - Air pollution control residue collected (CR) for direct 

reduction furnace. 

Q-7 

Q §98.176(e)(3) Annual volume of each type of gaseous fuel used to determine CO2

emissions (reported separately for each type in standard cubic feet) (No 

CEMS) - Taconite Indurating Furnace. 

Q-1 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

17 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

Q §98.176(e)(3) Annual volume of each type of liquid fuel used to determine CO2

emissions (reported separately for each type in gallons) (No CEMS). 

Q-1 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to 

determine CO2 emissions (No CEMS)- Annual mass of greenball 

(taconite) pellets fed into the furnace (O). 

Q-1 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to 

determine CO2 emissions (No CEMS)- Annual mass of solid fuel 

combusted (Fs). 

Q-1 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process output used to 

determine CO2 emissions (No CEMS) - Annual mass of air pollution 

control residue (R). 

Q-1 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process output used to 

determine CO2 emissions (No CEMS) - Annual mass of fired pellets 

produced (P). 

Q-1 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to 

determine CO2 emissions (No CEMS)- Annual mass of molten iron 

charged to furnace (Iron). 

Q-2 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to 

determine CO2 emissions (No CEMS)- Annual mass of scrap charged to 

the furnace (Scrap). 

Q-2 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to 

determine CO2 emissions (No CEMS)- Annual mass of flux charged to the 

furnace (Flux). 

Q-2 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to 

determine CO2 emissions (No CEMS)- Annual mass of carbon (e.g., coal, 

coke) charged to furnace (Carbon). 

Q-2 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process output used to 

determine CO2 emissions (No CEMS) - Annual mass of steel produced 

(Steel). 

Q-2 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process output used to 

determine CO2 emissions (No CEMS) - Annual mass of slag produced 

(Slag). 

Q-2 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process output used to 

determine CO2 emissions (No CEMS) - Annual mass of air pollution 

control residue collected (Residue). 

Q-2 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to 

determine CO2 emissions (No CEMS)- Coal charged to battery (Coal). 

Q-3 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process output used to 

determine CO2 emissions (No CEMS) - Annual mass of coke produced 

(Coke). 

Q-3 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process output used to 

determine CO2 emissions (No CEMS) - Annual mass of air pollution 

control residue collected from battery (R). 

Q-3 
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18 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

Q §98.176(e)(3) Annual volume of each type of gaseous fuel used to determine CO2

emissions (reported separately for each type in standard cubic feet) (No 

CEMS) - Sinter process (Fg). 

Q-4 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to 

determine CO2 emissions (No CEMS)- Annual mass of sinter feed 

material (Feed). 

Q-4 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to 

determine CO2 emissions (No CEMS)- Annual mass of sinter Produced 

(Sinter). 

Q-4 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process output used to 

determine CO2 emissions (No CEMS) - Annual mass of air pollution 

control residue collected from sinter process (R). 

Q-4 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to 

determine CO2 emissions (No CEMS)- Annual mass of direct reduced iron 

charged to the EAF (Iron). 

Q-5 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to 

determine CO2 emissions (No CEMS)- Annual mass of Scrap charged to 

the EAF(Scrap). 

Q-5 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to 

determine CO2 emissions (No CEMS)- Annual mass of flux charged to the 

EAF(Flux). 

Q-5 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to 

determine CO2 emissions (No CEMS)- Annual mass of carbon electrode 

consumed in the EAF(Electrode). 

Q-5 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to 

determine CO2 emissions (No CEMS)- Annual mass of carbonaceous 

(coal or coke) material charged to the EAF(Carbon). 

Q-5 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to 

determine CO2 emissions (No CEMS)- Annual mass of steel produced 

(Steel) in EAF. 

Q-5 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process output used to 

determine CO2 emissions (No CEMS) - Annual mass of slag produced 

(Slag) in EAF. 

Q-5 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process output used to 

determine CO2 emissions (No CEMS) - Annual mass of air pollution 

control residue collected (Residue) from EAF. 

Q-5 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to 

determine CO2 emissions (No CEMS)- Annual mass of steel charged to 

the decarburization vessel (Steel). 

Q-6 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process output used to 

determine CO2 emissions (No CEMS) - Annual mass of air pollution 

control residue collected (Residue) from the decarburization vessel. 

Q-6 

Q §98.176(e)(3) Annual volume of each type of gaseous fuel used to determine CO2

emissions (reported separately for each type in standard cubic feet) (No 

CEMS) - direct reduction furnaces (Fg). 

Q-7 
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19 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to 

determine CO2 emissions (No CEMS)- Annual mass of iron ore or iron 

ore pellets charged to the direct reduction furnace (Ore). 

Q-7 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to 

determine CO2 emissions (No CEMS)- Annual mass of carbonaceous 

(coal or coke) material charged to the direct reduction furnace (Carbon). 

Q-7 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to 

determine CO2 emissions (No CEMS)- Annual mass of other material 

charged to the direct reduction furnace (Other). 

Q-7 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to 

determine CO2 emissions (No CEMS)- Annual mass of iron produced 

(Iron) in direct reduction furnace. 

Q-7 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to 

determine CO2 emissions (No CEMS)- Annual mass of non-metallic 

materials produced (NM) in direct reduction furnace. 

Q-7 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process output used to 

determine CO2 emissions (No CEMS) - Annual mass of air pollution 

control residue collected (Residue) from the direct reduction furnace. 

Q-7 

Q §98.176(e)(4) Molecular weight of gaseous fuels (No CEMS) - Taconite Indurating 

Furnace. 

Q-1 

Q §98.176(e)(4) Molecular weight of gaseous fuels (No CEMS) - Sinter Process. Q-4 

Q §98.176(e)(4) Molecular weight of gaseous fuels (No CEMS) - Direct Reduction 

Furnace. 

Q-7 

Q §98.176(f)(2) Average hourly feed rate during the test (No CEMS). No Equation - 

Used as input in 

calc. method 

described in 

§98.173(b)(2)(iii). 

Q §98.176(f)(2) Average hourly production rate during the test (No CEMS). No Equation - 

Used as input in 

calc. method 

described in 

§98.173(b)(2)(iii). 

Q §98.176(f)(3) Site-specific emission factor (No CEMS). No Equation - 

Used as input in 

calc. method 

described in 

§98.173(b)(2)(iv). 

Q §98.176(f)(4) Annual feed rate used to estimate annual CO2 emissions (No CEMS). No Equation - 

Used as input in 

calc. method 

described in 

§98.173(b)(iv). 
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20 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

Q §98.176(f)(4) Annual production rate used to estimate annual CO2 emissions (No 

CEMS). 

No Equation - 

Used as input in 

calc. method 

described in 

§98.173(b)(iv). 

Q §98.176(g) The annual amount of coal charged to the coke ovens (in metric tons). No Equation - 

Used as input in 

calc. method 

described in 

§98.173(c). 

R §98.186(b)(6) Annual material quantity used for the calculation of annual process CO2

emissions (No CEMS) (Ore = Annual mass of lead ore charged to the 

smelting furnace (tons).) 

R-1 

R §98.186(b)(6) Annual material quantity used for the calculation of annual process CO2

emissions (No CEMS) (Scrap = Annual mass of lead scrap charged to the 

smelting furnace (tons).) 

R-1 

R §98.186(b)(6) Annual material quantity used for the calculation of annual process CO2

emissions (No CEMS) (Flux = Annual mass of flux materials (e.g., 

limestone, dolomite) charged to the smelting furnace (tons).) 

R-1 

R §98.186(b)(6) Annual material quantity used for the calculation of annual process CO2

emissions (No CEMS) (Carbon = Annual mass of carbonaceous materials 

(e.g., coal, coke) charged to the smelting furnace (tons).) 

R-1 

R §98.186(b)(6) Annual material quantity used for the calculation of annual process CO2

emissions (No CEMS) (Other = Annual mass of any other material 

containing carbon, other than fuel, fed, charged, or otherwise introduced 

into the smelting furnace (tons).) 

R-1 

R §98.186(b)(7) Annual average of the carbon content determinations for each material 

used for the calculation of annual process CO2 emissions (No CEMS) 

(COre= Carbon content of the lead ore, from the carbon analysis results 

(percent by weight, expressed as a decimal fraction).) 

R-1 

R §98.186(b)(7) Annual average of the carbon content determinations for each material 

used for the calculation of annual process CO2 emissions (No CEMS). 

(CScrap= Carbon content of the lead scrap, from the carbon analysis 

(percent by weight, expressed as a decimal fraction).) 

R-1 

R §98.186(b)(7) Annual average of the carbon content determinations for each material 

used for the calculation of annual process CO2 emissions (No CEMS). 

(CFlux= Carbon content of the flux materials, from the carbon analysis 

(percent by weight, expressed as a decimal fraction).) 

R-1 

R §98.186(b)(7) Annual average of the carbon content determinations for each material 

used for the calculation of annual process CO2 emissions (No CEMS). 

(CCarbon= Carbon content of the carbonaceous materials, from the carbon 

analysis (percent by weight, expressed as a decimal fraction).) 

R-1 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

21 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

R §98.186(b)(7) Annual average of the carbon content determinations for each material 

used for the calculation of annual process CO2 emissions (No CEMS). 

(COther= Carbon content of the other material from the carbon analysis 

results (percent by weight, expressed as a decimal fraction).) 

R-1 

S §98.196(b)(2) Monthly emission factors for each lime type produced. S-4 

S §98.196(b)(3) Monthly emission factors for each calcined byproduct/waste by lime type 

that is sold. (EFLKD,i,n) 

S-4 

S §98.196(b)(5) Monthly results of chemical composition analysis of each type of lime 

product produced (No CEMS). 

No Equation -

described in 

§98.196(b)(5). 

S §98.196(b)(5) Monthly results of chemical composition analysis of each type of calcined 

lime byproducts/wastes sold (No CEMS). 

No Equation -

described in 

§98.196(b)(5). 

S §98.196(b)(6) Annual results of chemical composition analysis of each type of lime 

byproducts/wastes that is not sold (No CEMS). 

No Equation -

described in 

§98.196(b)(6). 

S §98.196(b)(8) Monthly amount of lime product sold, by type (No CEMS). No Equation -

described in 

§98.196(b)(8). 

S §98.196(b)(10) Monthly amount of calcined lime byproduct/waste sold, by type (No 

CEMS). 

No Equation -

described in 

§98.196(b)(10). 

S §98.196(b)(11) Annual amount of calcined lime byproduct/waste that is not sold, by type 

(No CEMS). 

No Equation -

described in 

§98.196(b)(11). 

S §98.196(b)(12) Monthly weight or mass of each lime type produced (No CEMS). S-4 

U §98.216(b) Annual carbonate consumption by carbonate type. U-1 

U §98.216(b) Annual carbonate input by carbonate type. U-2 

U §98.216(e)(1) Annual carbonate consumption by carbonate type. U-1 

U §98.216(e)(2) Annual calcination fractions used in calculations. U-1 

U §98.216(f)(1) Annual carbonate input by carbonate type. U-2 

U §98.216(f)(2) Annual carbonate output by carbonate type. U-2 

V §98.226(d) Annual nitric acid production during which N2O abatement technology is 

operating (tons, 100% acid basis). 

V-2 

V §98.226(m)(1) Emission factor calculated for each nitric acid train (EFN2Ot). V-3a 

V §98.226(m)(1) Emission factor calculated for each nitric acid train (EFN2Ot). V-3b 

V §98.226(m)(1) Emission factor calculated for each nitric acid train (EFN2Ot). V-3c 

V §98.226(m)(1) Emission factor calculated for each nitric acid train (EFN2Ot). V-3d 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

22 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

V §98.226(m)(3) Production rate per test run during performance test for each train. V-1 

X §98.246(a)(4) Indicate whether you used the alternative to sampling and analysis. X-1 

X §98.246(a)(4) Monthly volume values (used in Equations X-1 to X-3) - Volume of 

gaseous feedstock I introduced in month "n" ((Fgf)n).

X-1 

X §98.246(a)(4) Monthly volume values (used in Equations X-1 to X-3) - Volume of 

gaseous product i produced in month "n" ((Pgf)n)

X-1 

X §98.246(a)(4) Monthly carbon content values (used in Equations X-1 to X-3) - Average 

carbon content of the gaseous feedstock I for month "n" ((CCgf)n). 

X-1 

X §98.246(a)(4) Monthly carbon content values (used in Equations X-1 to X-3) - Average 

carbon content of the gaseous product i for month "n" ((CCgp)n). 

X-1 

X §98.246(a)(4) Molecular weights for gaseous feedstocks (used in Equation X-1). X-1 

X §98.246(a)(4) Molecular weights for gaseous products (used in Equation X-1). X-1 

X §98.246(a)(4) Indicate whether you used the alternative to sampling and analysis. X-2 

X §98.246(a)(4) Monthly volume values (used in Equations X-1 to X-3) - Volume of liquid 

feedstock i for month "n" ((Flf)n ). 

X-2 

X §98.246(a)(4) Monthly volume values (used in Equations X-1 to X-3) - Volume of liquid 

product i for month "n" ((Plp)n ) . 

X-2 

X §98.246(a)(4) Monthly mass values (used in Equations X-1 to X-3) - Mass of liquid 

feedstock i for month "n" ((Flf)n ). 

X-2 

X §98.246(a)(4) Monthly mass values (used in Equations X-1 to X-3) - Mass of liquid 

product i for month "n" ((Plp)n ). 

X-2 

X §98.246(a)(4) Monthly carbon content values (used in Equations X-1 to X-3) - Average 

carbon content of the liquid feedstock i for month "n" ((CClf)n). 

X-2 

X §98.246(a)(4) Monthly carbon content values (used in Equations X-1 to X-3) - Average 

carbon content of the liquid product i for month "n" ((CClp)n). 

X-2 

X §98.246(a)(4) Indicate whether you used the alternative to sampling and analysis. X-3 

X §98.246(a)(4) Monthly mass values (used in Equations X-1 to X-3) - Mass of solid 

feedstock I for month "n" ((Fsf)n). 

X-3 

X §98.246(a)(4) Monthly mass values (used in Equations X-1 to X-3) - Mass of solid 

product i for month "n" ((Psp)n). 

X-3 

X §98.246(a)(4) Monthly carbon content values (used in Equations X-1 to X-3) - Average 

carbon content of the solid feedstock i for month "n" ((CClf)n). 

X-3 

X §98.246(a)(4) Monthly carbon content values (used in Equations X-1 to X-3) - Average 

carbon content of the solid product i for month "n" ((CClp)n). 

X-3 

X §98.246(b)(5)(iii) Quantity of each type of fuel used in equation C-8 in §98.33(c) for each 

stationary combustion unit or group of units (as applicable) during the 

reporting year, expressed in short tons for solid fuels, gallons for liquid 

fuels, and scf for gaseous fuels. 

C-8 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

23 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

X §98.246(b)(5)(iv) The HHV (either default or annual average from measured data) used in 

equation C-8 in §98.33(C) for each stationary combustion unit or group 

of units (as applicable). 

C-8 

Y §98.256(e)(6) 3 If using Equation Y-1a: report the molar volume conversion factor (in 

scf/g-mole) for each flare. 

Y-1a 

Y §98.256(e)(7) 3 If using Equation Y-1b: report molar volume conversion factor for each 

flare. 

Y-1b 

Y §98.256(e)(7)(ii) If using Equation Y-1b: report the carbon mole number of each carbon 

containing compound other than CO2 in the flare gas stream for each flare. 

Y-1b 

Y §98.256(e)(9) Annual volume of flare gas combusted during normal operations. Y-3 

Y §98.256(e)(9) Annual average higher heating value of the flare gas (normal). Y-3 

Y §98.256(e)(9) Volume of gas flared during SSM event. Y-3 

Y §98.256(e)(9) Average molecular weight (SSM). Y-3 

Y §98.256(e)(9) Carbon content of the flare gas (SSM). Y-3 

Y §98.256(e)(9) 3 If using Equation Y-3: report the molar volume conversion factor for each 

flare. 

Y-3 

Y §98.256(e)(10) 3 Fraction of carbon in the flare gas contributed by methane (used in 

Equation Y-4). 

Y-4 

Y §98.256(f)(7) 3 If using Equation Y-6: report the molar volume conversion factor. Y-6 

Y §98.256(f)(10) Coke burn-off factor. Y-8 

Y §98.256(f)(10) Annual throughput of unit. Y-8 

Y §98.256(f)(10) Average carbon content of coke. Y-8 

Y §98.256(f)(11) If you use a unit-specific emission factor for CH4: report the unit-specific 

emission factor for CH4 each catalytic cracking units, traditional fluid 

coking units, and catalytic reforming units. 

Used in method 

specified in 

§98.253(c)(4) 

Y §98.256(f)(11) 3 Units of measure for the unit-specific CH4 emission factor. Used in method 

specified in 

§98.253(c)(4) 

Y §98.256(f)(11) Activity data for calculating emissions (input). Used in method 

specified in 

§98.253(c)(4) 

Y §98.256(f)(11) Activity data for calculating emissions (product). Used in method 

specified in 

§98.253(c)(4) 

Y §98.256(f)(12) Activity data for calculating emissions (input). Used in method 

specified in 

§98.253(c)(5) 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

24 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

Y §98.256(f)(12) Activity data for calculating emissions (production). Used in method 

specified in 

§98.253(c)(5) 

Y §98.256(f)(12) If a unit-specific emission factor for N2O was used: report the unitspecific emission factor for N2O each catalytic cracking units, traditional 

fluid coking units, and catalytic reforming units. 

Used in method 

specified in 

§98.253(c)(5) 

Y §98.256(f)(12) 3 Units of measure for the unit-specific N2O emission factor. Used in method 

specified in 

9§8.253(c)(5) 

Y §98.256(f)(13) Average carbon content of coke. Y-11 

Y §98.256(h)(4) 3 If Equation Y-12 is used: report the molar volume conversion factor. Y-12 

Y §98.256(h)(4) If Equation Y-12 is used: Annual volumetric flow to the sulfur recovery 

plant. 

Y-12 

Y §98.256(h)(4) If Equation Y-12 is used: Annual average mole fraction of carbon in the 

sour gas. 

Y-12 

Y §98.256(h)(5) Annual volume of recycled tail gas (if used to calculate recycling 

correction factor). 

If a correction for 

CO2 emissions in 

the tail gas was 

used in Eq. Y-12 

Used in method 

specified in 

§98.253(h)(3) 

Y §98.256(h)(5) Annual average mole fraction of carbon in the tail gas (if used to calculate 

recycling correction factor). 

If a correction for 

CO2 emissions in 

the tail gas was 

used in Eq. Y-12 

Used in method 

specified in 

§98.253(h)(3) 

Y §98.256(i)(5) If you use Eq. Y-13, report the annual mass of green coke fed to the for 

each coke calcining unit. 

Y-13 

Y §98.256(i)(5) If you use Eq. Y-13, report the carbon content of green coke fed to the for 

each coke calcining unit. 

Y-13 

Y §98.256(i)(5) If you use Eq. Y-13, report the annual mass of marketable coke produced 

for each coke calcining unit. 

Y-13 

Y §98.256(i)(5) If you use Eq. Y-13, report the carbon content of marketable coke 

produced for each coke calcining unit. 

Y-13 

Y §98.256(i)(5) If Equation Y-13 used for coke calcining units: report the annual mass of 

coke dust removed from the process through collected in dust collection 

systems. 

Y-13 

Y §98.256(i)(7) For coke calcining: Activity data for calculating emissions (input data). Used in method 

specified in 

§98.253(c)(4) 

Y §98.256(i)(7) For coke calcining: Activity data for calculating emissions (production 

data). 

Used in method 

specified in 

§98.253(c)(4) 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

25 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

Y §98.256(i)(7) For coke calcining: The unit-specific CH4 emission factor. Used in method 

specified in 

§98.253(c)(4) 

Y §98.256(i)(7) 3 For coke calcining: Units of measure for the unit-specific CH4 emission 

factor. 

Used in method 

specified in 

§98.253(c)(4) 

Y §98.256(i)(8) For coke calcining: If a unit specific emission factor was used for the N2O 

factor: report the activity data used for calculating emissions. 

Used in method 

specified in 

§98.253(c)(5) 

Y §98.256(i)(8) For coke calcining: If a unit-specific emission factor for N2O was used, 

report the site-specific emission factor. 

Used in method 

specified in 

§98.253(c)(5) 

Y §98.256(i)(8) 3 For coke calcining: If a unit specific emission factor was used for the N2O 

factor: report the units of measure for the unit-specific factor. 

Used in method 

specified in 

§98.253(c)(5) 

Y §98.256(j)(2) Quantity of asphalt blown for each for each asphalt blowing unit. Y-14 

Y §98.256(j)(2) Quantity of asphalt blown for each for each asphalt blowing unit. Y-15 

Y §98.256(j)(2) Quantity of asphalt blown for each for each asphalt blowing unit. Y-16a 

Y §98.256(j)(2) Quantity of asphalt blown for each for each asphalt blowing unit. Y-16b 

Y §98.256(j)(2) Quantity of asphalt blown for each for each asphalt blowing unit. Y-17 

Y §98.256(j)(5) CO2 emission factor for each asphalt blowing unit. Y-14 

Y §98.256(j)(6) CH4 emission factor for each asphalt blowing unit. Y-15 

Y §98.256(j)(7) If Equation Y-16 is used: report the carbon emission factor. Y-16a 

Y §98.256(j)(8) If Equation Y-16b is used: report the CO2 emission factor used. Y-16b 

Y §98.256(j)(8) If Equation Y-16b is used: report the carbon emission factor. Y-16b 

Y §98.256(j)(9) If you use Eq. Y-17: CH4 emission factor. Y-17 

Y §98.256(k)(3) For delayed coking units: Dimensions of coke drum or vessel. Y-18 

Y §98.256(k)(3) For delayed coking units: Typical gauge pressure of the coking drum 

when first vented to the atmosphere. 

Y-18 

Y §98.256(k)(3) For delayed coking units: Typical void fraction of coke drum or vessel. Y-18 

Y §98.256(k)(3) For delayed coking units: Annual number of coke-cutting cycles of coke 

drum or vessel. 

Y-18 

Y §98.256(k)(3) 3 For delayed coking units: report the molar volume conversion factor for 

each coke drum or vessel. 

Y-18 

Y §98.256(k)(4) For delayed coking units: Height and diameter of the coke drums. Y-18 

Y §98.256(k)(4) For delayed coking units: Cumulative number of vessel openings for all 

delayed coking drums in the set. 

Y-18 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

26 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

Y §98.256(k)(4) For delayed coking units: Typical venting pressure. Y-18 

Y §98.256(k)(4) For delayed coking units: Void fraction. Y-18 

Y §98.256(l)(5) 3 For each process vent: Molar volume conversion factor. Y-19 

Y §98.256(m)(3) Uncontrolled blowdown systems reporting under §98.253 (k): CH4

emission factor used. 

Y-20 

Y §98.256(m)(3) 3 Uncontrolled blowdown systems reporting under §98.253 (k): Molar 

volume conversion factor. 

Y-20 

Y §98.256(m)(3) Uncontrolled blowdown systems reporting under §98.253 (k): Total 

quantity of crude oil plus the quantity of intermediate products received 

from off-site that are processed at the facility in the reporting year. 

Y-20 

Y §98.256(o)(2)(ii) Total quantity of crude oil plus the quantity of intermediate products 

received from off-site that are processed at the facility in the reporting 

year. 

Y-22 

Y §98.256(o)(4)(ii) For storage tanks that process unstabilized crude oil: Quantity of 

unstabilized crude oil received during the calendar year. 

Y-23 

Y §98.256(o)(4)(iii) For storage tanks that process unstabilized crude oil: Average pressure 

differential. 

Y-23 

Y §98.256(o)(4)(iv) 3 For storage tanks that process unstabilized crude oil: Molar volume 

conversion factor. 

Y-23 

Y §98.256(o)(4)(v) For storage tanks that process unstabilized crude oil: Average Mole 

fraction of CH4 in vent gas from the unstabilized crude oil storage tanks. 

Y-23 

Y §98.256(p)(2) For loading operations: Quantity of materials loaded by vessel type that 

have an equilibrium vapor-phase concentration of CH4 of 0.5 volume 

percent or greater. 

Used in methods 

specified in AP42, Section 5.2 

(referenced by 

§98.253(n)) 

Z §98.266(f)(5) Monthly inorganic carbon content of phosphate rock for each wet-process 

phosphoric acid process line for which Equation Z-1a is used (percent by 

weight, expressed as decimal fraction) (No CEMS). 

Z-1a 

Z §98.266(f)(5) Monthly CO2 (ton CO2/ton of phosphate rock) for which Equation Z-1b is 

used (No CEMS). 

Z-1b 

Z §98.266(f)(6) Monthly mass of phosphate rock consumed by origin in production. Z-1a 

Z §98.266(f)(6) Monthly mass of phosphate rock consumed by origin in production. Z-1b 

AA §98.276(b) Annual quantities of fossil fuels used in chemical recovery furnaces. C-1 

AA §98.276(b) Annual quantities of fossil fuels used in chemical recovery furnaces. C-1a 

AA §98.276(b) Annual quantities of fossil fuels used in chemical recovery furnaces. C-1b 

AA §98.276(b) Annual quantities of fossil fuels used in chemical recovery furnaces. C-2a 

AA §98.276(b) Annual quantities of fossil fuels used in chemical recovery furnaces. C-3 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

27 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

AA §98.276(b) Annual quantities of fossil fuels used in chemical recovery combustion 

units. 

C-4 

AA §98.276(b) Annual quantities of fossil fuels used in chemical recovery combustion 

units. 

C-5 

AA §98.276(b) Annual quantities of fossil fuels used in chemical recovery combustion 

units. 

C-8 

AA §98.276(b) Annual quantities of fossil fuels used in chemical recovery combustion 

units. 

C-8a 

AA §98.276(b) Annual quantities of fossil fuels used in chemical recovery combustion 

units. 

C-8b 

AA §98.276(b) Annual quantities of fossil fuels used in chemical recovery combustion 

units. 

C-9a 

AA §98.276(c) Annual mass of the spent liquor solids combusted. AA-1 

AA §98.276(c) Annual mass of the spent liquor solids combusted. AA-2 

AA §98.276(d) High heat value (HHV) of the spent liquor solids used in Equation AA-1. AA-1 

AA §98.276(f) Carbon content of the spent liquor solids used in Equation AA-2. AA-2 

AA §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C-1 

AA §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C-1a 

AA §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C-1b 

AA §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C-2a 

AA §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C-3 

AA §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C-4 

AA §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C-5 

AA §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C-8 

AA §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C-8a 

AA §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C-8b 

AA §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C-9a 

AA §98.276(h) Make-up quantity of CaCO3 used for the reporting year used in Equation 

AA-3. 

AA-3 

AA §98.276(i) Make-up quantity of Na2CO3 used for the reporting year used in Equation 

AA-3. 

AA-3 

BB §98.286(b)(1) Monthly consumption of petroleum coke (No CEMS). BB-2 

BB §98.286(b)(4) Carbon content factor of petroleum coke from the supplier or as measured 

by the applicable method. 

BB-1 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

28 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

BB §98.286(b)(6) CO2 emissions factor for each month. BB-2 

CC §98.296(b)(5) Monthly consumption of trona or liquid alkaline feedstock for each 

manufacturing line (No CEMS) (for facilities using Equation CC-1). 

CC-1 

CC §98.296(b)(6) Monthly production of soda ash for each manufacturing line (tons) (for 

facilities using Equation CC-2). 

CC-2 

CC §98.296(b)(7) Inorganic carbon content factor of soda ash. CC-1 

CC §98.296(b)(7) Inorganic carbon content factor of trona . CC-2 

EE §98.316(b)(6) Monthly calcined petroleum coke consumption for each production line 

(No CEMS). 

EE-2 

EE §98.316(b)(9) Monthly carbon content factor of petroleum coke (percent by weight 

expressed as a decimal fraction) (No CEMS). 

EE-2 

GG §98.336(b)(6) Annual mass of each carbon-containing input material charged to each 

kiln or furnace (No CEMS) - Mass of zinc bearing material. 

GG-1 

GG §98.336(b)(6) Annual mass of each carbon-containing input material charged to each 

kiln or furnace (No CEMS) - Annual mass of flux materials (e.g., 

limestone, dolomite) charged to kiln or furnace “k” (tons). 

GG-1 

GG §98.336(b)(6) Annual mass of each carbon-containing input material charged to each 

kiln or furnace (No CEMS) - Annual mass of carbon electrode consumed 

in furnace “k”. 

GG-1 

GG §98.336(b)(6) Annual mass of each carbon-containing input material charged to each 

kiln or furnace (No CEMS) - Annual mass of other carbonaceous material 

consumed in furnace “k”. 

GG-1 

GG §98.336(b)(7) Carbon content of carbon-containing input materials charged to kilns or 

furnace (including zinc bearing material, flux materials, and other 

carbonaceous materials) from the annual carbon analysis or from 

information provided by the material supplier) for each kiln or furnace 

(percent by weight, expressed as a decimal fraction) (No CEMS) - zinc 

bearing material. 

GG-1 

GG §98.336(b)(7) Carbon content of carbon-containing input materials charged to kilns or 

furnace (including zinc bearing material, flux materials, and other 

carbonaceous materials) from the annual carbon analysis or from 

information provided by the material supplier) for each kiln or furnace 

(percent by weight, expressed as a decimal fraction) (No CEMS) - flux 

materials. 

GG-1 

GG §98.336(b)(7) Carbon content of carbon-containing input materials charged to kilns or 

furnace (including zinc bearing material, flux materials, and other 

carbonaceous materials) from the annual carbon analysis or from 

information provided by the material supplier) for each kiln or furnace 

(percent by weight, expressed as a decimal fraction) (No CEMS) - other 

carbonaceous materials. 

GG-1 

GG §98.296(b)(10) Carbon content of the carbon electrodes used in each furnace from the 

annual carbon analysis or from information provided by the material 

supplier) (percent by weight, expressed as a decimal fraction) (No 

CEMS). 

GG-1 

TT §98.466(c)(3)(i) Total number of years (N) for which disposal and production data are both 

available. 

TT-2 
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29 

Subpart 

Rule Citation in 40 

CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

TT §98.466(c)(3)(ii) The waste disposal quantity for each year used in Equation TT–2 of this 

subpart to calculate the average waste disposal factor (WDF). 

TT-2 

TT §98.466(c)(3)(iii) Average waste disposal factor (WDF) calculated for the waste stream. TT-3 

1

This table excludes the five subpart V “inputs to equations” data elements in §98.226(c) (included in Table A‐7 of subpart A of part 98). In its

memorandum “Evaluation of Competitive Harm from Reporting “Inputs to Equations” Data Elements Deferred to March 31, 2015” (refer to

docket EPA‐HQ‐OAR‐2010‐0929), EPA concluded that these five “inputs to equations” data elements provide production or raw material data,

which would likely cause competitive harm if reported and publicly released. Based on these analysis results, EPA would have included these

data elements in this table as part of its proposal to remove reporting of these data; however, EPA has excluded the data elements from this

table because §98.226(c) is already removed from Subpart V. §98.226(c) was inadvertently removed and reserved in conjunction with the 2010

technical corrections rulemaking (75 FR 79157, December 17, 2010), and, based on the results of its analysis, EPA will take no action to

reinstate this provision. 2 Combustion units connected to devices connected to the local or regional power grid include combustion units subject to subpart C of Part 98

(excludes facilities subject to subpart D of Part 98) that meet the following criteria: (1) the combustion unit is connected to a device that has

been granted access by the Public Utilities Commission to deliver power to the local or regional electric power grid (e.g., electricity generators);

and (2) the combined nameplate capacity (for all such devices at the facility) is greater than or equal to 1 megawatt electric. 3 Data element would not be useful for data verification and would not inform future GHG policy development, in the absence of other data

elements included in this table for which we are proposing to remove the reporting requirement.

Table 2. List of “Inputs to Equations” Data Elements That EPA is Not Amending Under 

the Proposed Revisions to Part 98 (i.e., Data Elements Would Be Reported) 1

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.3(d)(3)(v) For any facility who submitted an abbreviated emissions report under 

§98.3(d)(3)(v), any facility operating data or process information used for 

the GHG emission calculations. 

 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(b)(9)(iii) Estimate of the heat input from each type of fuel listed in Table C-2 that 

was combusted in the unit during the report year. 

C-10 
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30 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(c)(2)(ix) The flue gases from two or more stationary fuel combustion units at a 

facility are combined together and discharged through a common stack or 

duct before exiting to the atmosphere and if CEMS are used to continuously 

monitor CO2 mass emissions at the common stack or duct according to the 

Tier 4 Calculation Methodology, you may report the combined emissions 

from the units sharing the common stack or duct, in lieu of separately 

reporting the GHG emissions from the individual units. This monitoring 

and reporting alternative may also be used when process off-gases or a 

mixture of combustion products and process gases are combined together in 

a common stack or duct before exiting to the atmosphere. An estimate of 

the heat input from each type of fuel listed in Table C-2 combusted during 

the reporting year. 

C-10 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(i) Total quantity of each type of fuel combusted in each unit or group of 

aggregated units (as applicable) during the reporting year, in short tons for 

solid fuels, gallons for liquid fuels and standard cubic feet for gaseous 

fuels, or, if applicable, therms or mmBtu for natural gas. 

C-1 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(i) Total quantity of each type of fuel combusted in each unit or group of 

aggregated units (as applicable) during the reporting year, in short tons for 

solid fuels, gallons for liquid fuels and standard cubic feet for gaseous 

fuels, or, if applicable, therms or mmBtu for natural gas. 

C-1a 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(i) Total quantity of each type of fuel combusted in each unit or group of 

aggregated units (as applicable) during the reporting year, in short tons for 

solid fuels, gallons for liquid fuels and standard cubic feet for gaseous 

fuels, or, if applicable, therms or mmBtu for natural gas. 

C-1b 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(i) Total quantity of each type of fuel combusted in each unit or group of 

aggregated units (as applicable) during the reporting year, in short tons for 

solid fuels, gallons for liquid fuels and standard cubic feet for gaseous 

fuels, or, if applicable, therms or mmBtu for natural gas. 

C-8 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(ii)(A) For Tier 2: Total quantity of each type of fuel combusted in the unit or 

group of aggregated units (as applicable) during each month of the 

reporting year. Express the quantity of each fuel combusted during the 

measurement period in short tons for solid fuels, gallons for liquid fuels, 

and scf for gaseous fuels. 

C-2b 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(ii)(C) High heat values used in the CO2 emissions calculations for each fuel 

combusted during the reporting year. Report a HHV value for each calendar 

month in which HHV determination is required. If multiple values are 

obtained in a given month, report the arithmetic average value for the 

month. 

C-2b 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

31 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(ii)(D) If Eq. C-2c is used: Total quantity (i.e., pounds) of steam produced from 

MSW or solid fuel combustion during each month of the reporting year. 

C-2c 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(ii)(D) If Eq. C-2c is used: Ratio of the maximum rate heat input capacity to the 

design rated steam output capacity of the unit. 

C-2c 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as 

applicable) during each month of the reporting year (Fuel). 

C-13 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as 

applicable) during each month of the reporting year (Fuel). 

C-3 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as 

applicable) during each month of the reporting year (Fuel). 

C-4 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as 

applicable) during each month of the reporting year (Fuel). 

C-5 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as 

applicable) during each month of the reporting year (Fuel). 

C-8 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as 

applicable) during each month of the reporting year (Fuel). 

C-8a 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

32 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as 

applicable) during each month of the reporting year (Fuel). 

C-8b 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(iv)(C) The carbon content used in the emission calculations (including both valid 

and substitute data values). For each calendar month of the reporting year 

in which carbon content and, if applicable, molecular weight determination 

is required, report a value of each parameter. If multiple values of a 

parameter are obtained in a given month, report the arithmetic average 

value for the month. (CC) 

C-3 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(iv)(C) The carbon content used in the emission calculations (including both valid 

and substitute data values). For each calendar month of the reporting year 

in which carbon content and, if applicable, molecular weight determination 

is required, report a value of each parameter. If multiple values of a 

parameter are obtained in a given month, report the arithmetic average 

value for the month. (CC) 

C-4 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(iv)(C) The carbon content used in the emission calculations (including both valid 

and substitute data values). For each calendar month of the reporting year 

in which carbon content and, if applicable, molecular weight determination 

is required, report a value of each parameter. If multiple values of a 

parameter are obtained in a given month, report the arithmetic average 

value for the month. (CC) 

C-5 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(iv)(C) Gas molecular weight values used in the emission calculations (including 

both valid and substitute data values). For each calendar month of the 

reporting year in which carbon content and, if applicable, molecular weight 

determination is required, report a value of each parameter. If multiple 

values of a parameter are obtained in a given month, report the arithmetic 

average value for the month. 

C-5 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(iv)(F) The annual average HHV, when measured HHV data, rather than a default 

HHV from Table C-1 of this subpart, are used to calculate CH4 and N2O 

emissions for a Tier 3 unit, in accordance with §98.33(c)(1). 

C-8 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(ix)(D) For units that combust both fossil fuel and biomass, when biogenic CO2 is 

determined according to §98.33(e)(2), report the carbon-based F-factor 

used in Equation C-13 of this subpart. 

C-13 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(ix)(E) For units that combust both fossil fuel and biomass, when biogenic CO2 is 

determined according to §98.33(e)(2), report the annual average HHV 

value used in Equation C-13 of this subpart. 

C-13 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

33 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(ix)(F) For units that combust both fossil fuel and biomass, when biogenic CO2 is 

determined according to §98.33(e)(2), report the total quantity of fossil fuel 

combusted during the reporting year. 

C-13 

E §98.56(g) Abatement technology destruction efficiency for each abatement 

technology (DF). 

 E-3a 

E §98.56(g) Abatement technology destruction efficiency for each abatement 

technology (DF). 

 E-3c 

E §98.56(g) Abatement technology destruction efficiency for each abatement 

technology (DF). 

E-3b 

E §98.56(h) Abatement utilization factor for each abatement technology (AF ). E-3a 

E §98.56(h) Abatement utilization factor for each abatement technology (AF). E-3c 

E §98.56(j)(4) N2O concentration per test run during performance test for each unit 

(CN2O). 

E-1 

E §98.56(j)(5) Volumetric flow rate per test run during performance test for each unit (Q). E-1 

E §98.56(j)(6) Number of test runs for each unit (n). E-1 

E §98.56(l) Fraction control factor for each abatement technology (percent of total 

emissions from the production unit that are sent to the abatement 

technology) if equation E-3c is used. (FCN) 

E-3c 

E §98.56h Abatement utilization factor for each abatement technology. (AF) E-3b 

H §98.86(b)(11) Quarterly kiln-specific CKD CO2 emission factors for each kiln. H-2 

H §98.86(b)(13) Name of raw kiln feed or raw material. 

L §98.126(b)(10) 3 The fraction of the mass emitted that consists of each fluorine-containing 

reactant (FERd). 

L-11 

L §98.126(b)(10) 3 The fraction of the mass emitted that consists of each fluorine-containing 

reactant. (FERd). 

L-12 

L §98.126(b)(10) 3 The fraction of the mass emitted that consists of each fluorine-containing 

reactant (FERd). 

L-13 

L §98.126(b)(11) 3 The fraction of the mass emitted that consists of the fluorine-containing 

product (FEP). 

L-11 

L §98.126(b)(11) 3 The fraction of the mass emitted that consists of the fluorine-containing 

product. (FEP) 

L-12 

L §98.126(b)(11) 3 The fraction of the mass emitted that consists of the fluorine-containing 

product. (FEP). 

L-13 

L §98.126(b)(12) 3 The fraction of the mass emitted that consists of each fluorine-containing 

by-product (FEBk). 

L-11 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

34 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

L §98.126(b)(12) 3 The fraction of the mass emitted that consists of each fluorine-containing 

by-product. (FEBk) 

L-12 

L §98.126(b)(12) 3 The fraction of the mass emitted that consists of each fluorine-containing 

by-product. (FEBk) 

L-13 

O §98.156(d)(2) If the HFC-23 concentration measured pursuant to §98.154(l) is greater 

than that measured during the performance test that is the basis for the 

destruction efficiency (DE), report concentration (mass fraction) of HFC-23 

at the outlet of the destruction device. 

No Equation - 

Used to calculate 

Destruction 

Efficiency 

O §98.156(d)(3) If the HFC-23 concentration measured pursuant to §98.154(l) is greater 

than that measured during the performance test that is the basis for the 

destruction efficiency (DE), report flow rate at the outlet of the destruction 

device in kg/hr. 

No Equation - 

Used to calculate 

Destruction 

Efficiency 

O §98.156(d)(4) If the HFC-23 concentration measured pursuant to §98.154(l) is greater 

than that measured during the performance test that is the basis for the 

destruction efficiency (DE), report emission rate (in kg/hour) calculated 

from the paragraphs (d)(2) and (d)(3) of this section. 

No Equation - 

Used to calculate 

Destruction 

Efficiency 

Q §98.176(f)(1) Measured average hourly CO2 emission rate during the test (No CEMS). No Equation - 

Used as input to 

method described 

in 

§98.173(b)(2)(iii). 

V §98.226(i) Abatement technology destruction efficiency (DF). V-3a 

V §98.226(i) Abatement technology destruction efficiency (DF). V-3b 

V §98.226(i) Abatement technology destruction efficiency (DF). V-3c 

V §98.226(j) Abatement utilization factor (AF). V-3a 

V §98.226(j) Abatement utilization factor (AF). V-3b 

V §98.226(j) Abatement utilization factor (AF). V-3c 

V §98.226(m)(4) N2O concentration per test run during performance test for each train. V-1 

V §98.226(m)(5) Volumetric flow rate per test run during performance test each train. V-1 

V §98.226(m)(6) Number of test runs during performance test each train. V-1 

V §98.226(p) Fraction control factor for each abatement technology (percent of total 

emissions from the production unit that are sent to the abatement 

technology) if equation V-3c is used. 

V-3c 

W 98.236c1i Actual count of natural gas pneumatic high bleed devices. W‐1

W 98.236c1i Estimated count of natural gas pneumatic high bleed devices. W‐1

W 98.236c1ii Actual count of natural gas pneumatic low bleed devices. W‐1
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

35 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

W 98.236c1ii Estimated count of natural gas pneumatic low bleed devices. W‐1

W 98.236c1iii Actual count of natural gas pneumatic intermittent bleed devices. W‐1

W 98.236c1iii Estimated count of natural gas pneumatic intermittent bleed devices. W‐1

W 98.236c2i Count of natural gas driven pneumatic pumps. W‐2

W 98.236c3i Total throughput of each acid gas removal unit using a meter or engineering

estimate based on process knowledge or best available data.

W‐3

W 98.236c3ii For Calculation Methodology 2 of §98.233(d), annual average fraction of

CO2 content in the vent from each acid gas removal unit.

W‐3

W 98.236c3iii For Calculation Methodology 3 of §98.233(d), annual average volume

fraction of CO2 content of natural gas into each acid gas removal unit.

W‐4A

W 98.236c3iii For Calculation Methodology 3 of §98.233(d), annual average volume

fraction of CO2 content of natural gas into each acid gas removal unit.

W‐4B

W 98.236c3iii For Calculation Methodology 3 of §98.233(d), annual average volume

fraction of CO2 content of natural gas out of each acid gas removal unit.

W‐4A

W 98.236c3iii For Calculation Methodology 3 of §98.233(d), annual average volume

fraction of CO2 content of natural gas out of each acid gas removal unit.

W‐4B

W 98.236c3iv Annual quantity of CO2, that was recovered from each acid gas removal unit

and transferred outside the facility (metric tons CO2e), under subpart PP of

this part.

98.233(d)(11)

W 98.236c4iA For each glycol dehydrator with throughput greater than or equal to 0.4

MMscfd: Glycol dehydrator feed natural gas flow rate in MMscfd,

determined by engineering estimate based on best available data.

Methodology 1

W 98.236c4iB For each glycol dehydrator with throughput greater than or equal to 0.4

MMscfd: Glycol dehydrator absorbent circulation pump type.

Methodology 1

W 98.236c4iC For each glycol dehydrator with throughput greater than or equal to 0.4

MMscfd: Report whether stripper gas is used in glycol dehydrator.

Methodology 1

W 98.236c4iD For each glycol dehydrator with throughput greater than or equal to 0.4

MMscfd: Report whether a flash tank separator is used in glycol dehydrator.

Methodology 1

W 98.236c4iE For each glycol dehydrator with throughput greater than or equal to 0.4

MMscfd: Report type of absorbent.

Methodology 1
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

36 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

W 98.236c4iF For each glycol dehydrator with throughput greater than or equal to 0.4

MMscfd: Total time the glycol dehydrator is operating in hours.

Methodology 1

W 98.236c4iG For each glycol dehydrator with throughput greater than or equal to 0.4

MMscfd: Temperature of the wet natural gas (degrees Fahrenheit).

Methodology 1

W 98.236c4iG For each glycol dehydrator with throughput greater than or equal to 0.4

MMscfd: Pressure of the wet natural gas (psig).

Methodology 1

W 98.236c4iH For each glycol dehydrator with throughput greater than or equal to 0.4

MMscfd: Concentration of CO2 in wet natural gas.

Methodology 1

W 98.236c4iH For each glycol dehydrator with throughput greater than or equal to 0.4

MMscfd: Concentration of CH4 in wet natural gas.

Methodology 1

W 98.236c4iiA For all glycol dehydrator with throughput less than 0.4 MMscfd: Count of

glycol dehydrators.

W‐5

W 98.236c5iD For well venting for liquids unloading, for Calculation Methodology 1, report

the following by each tubing diameter group and pressure group

combination within each sub‐basin category: Average flow rate of the

measured well venting (cubic feet per hour).

W‐7

W 98.236c5iiC For well venting for liquids unloading, for Calculation Methodologies 2 and

3,  report the following for each sub‐basin category: Cumulative number of

unloadings vented to the atmosphere.

W‐8

W 98.236c5iiC For well venting for liquids unloading, for Calculation Methodologies 2 and

3,  report the following for each sub‐basin category: Cumulative number of

unloadings vented to the atmosphere.

W‐9

W 98.236c6iB For well completions and workovers with hydraulic fracturing, report the

following for each sub‐basin and well type (horizontal or vertical)

combination: When using Equation W‐10A, measured flow rate of backflow

during well completion (cubic feet per hour).

W‐10A

W 98.236c6iD For well completions and workovers with hydraulic fracturing, report the

following for each sub‐basin and well type (horizontal or vertical)

combination: When using Equation W‐10A, measured flow rate of backflow

during well workover (cubic feet per hour).

W‐12

W 98.236c6iE For well completions and workovers with hydraulic fracturing, report the

following for each sub‐basin and well type (horizontal or vertical)

combination: When using Equation W‐10A, total number of days of

backflow  from all wells during completions.

W‐10A
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

37 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

W 98.236c6iF For well completions and workovers with hydraulic fracturing, report the

following for each sub‐basin and well type (horizontal or vertical)

combination: When using Equation W‐10A, total number of days of

backflow  from all wells during workovers.

W‐10A

W 98.236c6iG For well completions and workovers with hydraulic fracturing, report the

following for each sub‐basin and well type (horizontal or vertical)

combination: The amount of gas recovered to sales using engineering

estimate based on best available data.

W‐10A

W 98.236c6iH For well workovers with hydraulic fracturing, report the following for each

sub‐basin and well type (horizontal or vertical) combination: The amount of

gas recovered to sales using engineering estimate based on best available

data.

W‐10A

W 98.236c6iiA For well completions and workovers without hydraulic fracturing, report the

following for each sub‐basin and well type (horizontal or vertical)

combination: Total count of completions in calendar year.

W‐13

W 98.236c6iiB For well completions and workovers without hydraulic fracturing, report the

following for each sub‐basin and well type (horizontal or vertical)

combination: Total count of workovers in calendar year that flare gas or

vent gas to the atmosphere.

W‐13

W 98.236c7iA For blowdown vent stack emission source,  for each unique physical volume

that is blown down more than once during the calendar year: Total number

of blowdowns for each unique physical volume in the calendar year. (when

using Eq. W‐14A)

W‐14A

W 98.236c8iF For wellhead gas‐liquid separator with oil throughput greater than or equal

to 10 barrels per day, using Calculation Methodology 1 and 2 of 40 CFR

98.233(j), report by sub‐basin category: Total volume of oil from all

wellhead separators sent to tank(s) in barrels per year.

Methodology 1

(see 98.236j2)

W 98.236c8iF For wellhead gas‐liquid separator with oil throughput greater than or equal

to 10 barrels per day, using Calculation Methodology 1 and 2 of 40 CFR

98.233(j), report by sub‐basin category: Total volume of oil from all

wellhead separators sent to tank(s) in barrels per year.

Methodology 2

(see 98.233j1)

W 98.236c8iK For wellhead gas‐liquid separator with oil throughput greater than or equal

to 10 barrels per day, using Calculation Methodology 1 of 40 CFR 98.233(j),

report by sub‐basin category: Annual CO2 gas quantities that were

recovered (metric tons CO2e), for all wellhead gas‐liquid separators or

storage tanks using Calculation Methodology 1 of §98.233(j).

98.233(j)(6)(i)
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

38 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

W 98.236c8iiA For wells with oil production greater than or equal to 10 barrels per day,

using Calculation Methodology 3 and 4 of 40 CFR 98.233(j), report the

following by sub‐basin category: Total volume of sales oil from all wells

(barrels per year).

Methodology 3

and 4 (see

98.233(j)(3) and

(j)(4))

W 98.236c8iiH For wells with oil production greater than or equal to 10 barrels per day,

using Calculation Methodology 3 and 4 of 40 CFR 98.233(j), report the

following by sub‐basin category: Annual CO2 gas quantities that were

recovered (metric tons CO2e), for Calculation Methodology 3 or 4 of

§98.233(j).

98.233(j)(6)(i)

W 98.236c8iiiA For wellhead gas‐liquid separators and wells with throughput less than 10

barrels per day, using Calculation Methodology 5 of 40 CFR 98.233(j)

Equation W‐15 of 40 CFR 98.233: Number of wellhead separators.

W‐15

W 98.236c8iiiB For wellhead gas‐liquid separators and wells with throughput less than 10

barrels per day, using Calculation Methodology 5 of 40 CFR 98.233(j)

Equation W–15 of 40 CFR 98.233: Number of wells without wellhead

separators.

W‐15

W 98.236c8iiiG For wellhead gas‐liquid separators and wells with throughput less than 10

barrels per day, using Calculation Methodology 5 of 40 CFR 98.233(j)

Equation W‐15 of 40 CFR 98.233: Annual CO2 gas quantities that were

recovered (metric tons CO2e), at the sub‐basin level for Calculation

Methodology 5 of §98.233(j).

98.233(j)(6)(i)

W 98.236c12ii For flare stacks: Volume of gas sent to flare (cubic feet per year). W‐19

W 98.236c12ii For flare stacks: Volume of gas sent to flare (cubic feet per year). W‐20

W 98.236c12ii For flare stacks: Volume of gas sent to flare (cubic feet per year). W‐21

W 98.236c12v For flare stacks: Flare combustion efficiency. W‐19

W 98.236c12v For flare stacks: Flare combustion efficiency. W‐21

W 98.236c13iE For compressors with wet seals in operational mode: Reporter emission

factor for wet seal oil degassing vents in cubic feet per hour (refer to

Equation W‐24 of 40 CFR 98.233).

W‐23

W 98.236c13iF For compressors with wet seals in operational mode: Total time the

compressor is operating (hours).

W‐22

W 98.236c13iF For compressors with wet seals in operational mode: Total time the

compressor is operating (hours).

W‐23
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39 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

W 98.236c13iiA For wet and dry seal centrifugal compressors in operating mode: Total time

the compressor is in operating mode (hours).

W‐23

W 98.236c13iiB For wet and dry seal centrifugal compressors in operating mode: Reporter

emission factor for blowdown vents (cubic feet per hour).

W‐23

W 98.236c13iiiA For wet and dry seal centrifugal compressors: Total time the compressor is

in shutdown, depressurized mode (hours).

W‐22

W 98.236c13iiiA For wet and dry seal centrifugal compressors: Total time the compressor is

in shutdown, depressurized mode (hours).

W‐23

W 98.236c13iiiB For wet and dry seal centrifugal compressors: Reporter emission factor for

isolation valve emissions in shutdown, depressurized mode (cubic feet per

hour).

W‐23

W 98.236c13vA For centrifugal compressors in onshore petroleum and natural gas

production: Count of compressors.

W‐25

W 98.236c14iB For reciprocating compressors rod packing emissions with or without a vent

in operating mode: Total time the reciprocating compressor is in operating

mode (hours).

W‐26

W 98.236c14iB For reciprocating compressors rod packing emissions with or without a vent

in operating mode: Total time the reciprocating compressor is in operating

mode (hours).

W‐27

W 98.236c14iiA For reciprocating compressors blowdown vents not manifold to rod packing

vents, in operating and standby pressurized mode: Total time the

compressor is in standby, pressurized mode (hours).

W‐26

W 98.236c14iiA For reciprocating compressors blowdown vents not manifold to rod packing

vents, in operating and standby pressurized mode: Total time the

compressor is in standby, pressurized mode (hours).

W‐27

W 98.236c14iiB For reciprocating compressors blowdown vents not manifold to rod packing

vents, in operating and standby pressurized mode: Emission factor for

blowdown vents (cubic feet per hour).

W‐27

W 98.236c14iiiA For reciprocating compressors: Total time the compressor is in not

operating, depressurized mode.

W‐26

W 98.236c14iiiA For reciprocating compressors: Total time the compressor is in not

operating, depressurized mode.

W‐27

W 98.236c14iiiB For reciprocating compressors: Reporter emission factor for isolation valve W‐27
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40 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

emissions in not operating, depressurized mode.

W 98.236c14vA For reciprocating compressors in onshore petroleum and natural gas

production: Count of compressors.

W‐29

W 98.236c15iiA For equipment leaks calculated using population counts and factors (refer

to §98.233(r)), report the following:

For source categories 40 CFR 98.230(a)(4), (a)(5), (a)(6), (a)(7), and (a)(8)

total count for each type of leak source in Tables W‐2, W‐3, W‐4, W‐5, and

W‐6 of this subpart for which there is a population emission factor, listed by

major heading and component type.

W‐31

W 98.236c15iiB For equipment leaks calculated using population counts and factors (refer

to §98.233(r)), report the following:

For equipment leaks calculated using population counts and factors: For

onshore production (refer to 40 CFR 98.230 paragraph (a)(2)), total count

for each type of major equipment in Table W‐1B and Table W‐1C of this

subpart, by sub‐basin category.

W‐31

W 98.236c16viii For local distribution companies: Leak factor for meter/regulator run

developed in Equation W‐32 of §98.233.

W‐31

W 98.236c16ix For local distribution companies: Number of miles of unprotected steel

distribution mains.

W‐31

W 98.236c16x For local distribution companies: Number of miles of protected steel

distribution mains.

W‐31

W 98.236c16xi For local distribution companies: Number of miles of plastic distribution

mains.

W‐31

W 98.236c16xii For local distribution companies: Number of miles of cast iron distribution

mains.

W‐31

W 98.236c16xiii For local distribution companies: Number of unprotected steel distribution

services.

W‐31

W 98.236c16xiv For local distribution companies: Number of protected steel distribution

services.

W‐31

W 98.236c16xv For local distribution companies: Number of plastic distribution services.   W‐31

W 98.236c16xvi For local distribution companies:Number of copper distribution services. W‐31

W 98.236c17ii For each EOR injection pump blowdown: Volume of critical phase gas

between isolation valves.

W‐37
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

41 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

W 98.236c17iii For each EOR injection pump blowdown: Number of blowdowns per year. W‐37

W 98.236c17iv For each EOR injection pump blowdown: Critical phase EOR injection gas

density.

W‐37

W 98.236c18i For EOR hydrocarbon liquids dissolved CO2 for each sub‐basin category:

Volume of crude oil produced (barrels per year).

W‐38

W 98.236c18ii For EOR hydrocarbon liquids dissolved CO2 for each sub‐basin category:

Amount of CO2 retained in hydrocarbon liquids (metric tons per barrel),

under standard conditions.

W‐38

W 98.236c19iv For onshore petroleum and natural gas production and natural gas

distribution combustion emissions: Cumulative volume of fuel combusted in

external fuel combustion units with a rated heat capacity larger than 5

mmBtu/hr, by fuel type.

W‐39A

W 98.236c19iv For onshore petroleum and natural gas production and natural gas

distribution combustion emissions: Cumulative volume of fuel combusted in

external fuel combustion units with a rated heat capacity larger than 5

mmBtu/hr, by fuel type.

W‐39B

W 98.236c19iv For onshore petroleum and natural gas production and natural gas

distribution combustion emissions: Cumulative volume of fuel combusted in

external fuel combustion units with a rated heat capacity larger than 5

mmBtu/hr, by fuel type.

W‐40

W 98.236c19vii For onshore petroleum and natural gas production and natural gas

distribution combustion emissions: Cumulative volume of fuel combusted in

internal combustion units with a rated heat capacity larger than 1

mmBtu/hr or 130 horsepower, by fuel type.  

W‐39A

W 98.236c19vii For onshore petroleum and natural gas production and natural gas

distribution combustion emissions: Cumulative volume of fuel combusted in

internal combustion units with a rated heat capacity larger than 1

mmBtu/hr or 130 horsepower, by fuel type.  

W‐39B

W 98.236c19vii For onshore petroleum and natural gas production and natural gas

distribution combustion emissions: Cumulative volume of fuel combusted in

internal combustion units with a rated heat capacity larger than 1

mmBtu/hr or 130 horsepower, by fuel type.  

W‐40

Y §98.256(h)(5) Value of the correction. Used in method 

specified in 

§98.253(h)3) 

Y §98.256(k)(4) For delayed coking units: Mole fraction of methane in coking gas. Y-18 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

42 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

Y §98.256(n)(3) For equipment leaks: Number of each type of emission source listed in 

Equation Y-21 (if using Eq. Y-21). 

Y-21 

Y §98.256(o)(4)(vi) 4 If you did not use Equation Y-23: report the gas generation rate data used to 

estimate cumulative CH4 emissions for storage tanks used to process 

unstabilized crude oil.. 

Used in methods 

specified in 

§98.253(m)(2) 

Y §98.256(o)(4)(vi) 4 If you did not use Equation Y-23: report the tank-specific methane 

composition data used to estimate cumulative CH4 emissions for storage 

tanks used to process unstabilized crude oil. 

Used in methods 

specified in 

§98.253(m)(2) 

Y §98.256(o)(6) 5 Mole fraction of CH4 in vent gas from the unstabilized crude oil storage 

tank. 

Y-23 

Y §98.256(o)(6) 5 Average pressure differential. Y-23 

Y §98.256(o)(6) 5 Quantity of unstabilized crude oil received during the calendar year. Y-23 

Y §98.256(o)(7) 5 Tank-specific methane composition data. Used in methods 

specified in 

§98.253(m)(2) 

Y §98.256(o)(7) 5 Gas generation rate data. Used in methods 

specified in 

§98.253(m)(2) 

AA §98.276(e) Default or site specific emission factor for CO2 used in equation AA-1. AA-1 

AA §98.276(e) Default or site specific emission factor for CH4 used in equation AA-1. AA-1 

AA §98.276(e) Default or site specific emission factor for N2O used in equation AA-1. AA-1 

CC §98.296(b)(10)(i) Stack gas volumetric flow rate during performance test (dscfm) for each 

manufacturing line or stack. 

CC-3 

CC §98.296(b)(10)(ii) Hourly CO2 concentration during performance test (percent CO2) for each 

manufacturing line or stack. 

CC-3 

CC §98.296(b)(10)(iii) CO2 emission factor of process vent flow from mine water for each 

manufacturing line or stack. 

CC-5 

CC §98.296(b)(10)(iv) CO2 emission mass emission rate during performance test (metric 

tons/hour) for each manufacturing line or stack. 

CC-4 

CC §98.296(b)(10)(v) Average process vent flow from mine water stripper/evaporator during 

performance test for each manufacturing line or stack. 

CC-4 

CC §98.296(b)(10)(vi) Annual process vent flow rate from mine stripper/evaporator for each 

manufacturing line or stack. 

CC-5 

II §98.356(d)(2) Cumulative volumetric biogas flow for each week that biogas is collected 

for destruction (if using weekly sampling). 

II-4 

II §98.356(d)(3) Weekly average CH4 concentration for each week that biogas is collected 

for destruction (if using weekly sampling). 

II-4 

II §98.356(d)(4) Weekly average temperature at which flow is measured for biogas collected 

for destruction (if using weekly sampling). 

II-4 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

43 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

II §98.356(d)(5) Weekly average moisture content for each week at which flow is measured 

for biogas collected for destruction (if using weekly sampling). 

II-4 

II §98.356(d)(6) Weekly average pressure for each week at which flow is measured for 

biogas collected for destruction (if using weekly sampling). 

II-4 

1

Of the 85 “inputs to equations” data elements listed in this table, reporting of 16 of these data elements will be addressed under separate EPA

actions, as specified in this table for each such data element. Therefore, EPA is taking no action on these 16 data elements under this proposal. 2 Combustion units connected to devices connected to the local or regional power grid include combustion units subject to subpart C of Part 98

(excludes facilities subject to subpart D of Part 98) that meet the following criteria: (1) the combustion unit is connected to a device that has

been granted access by the Public Utilities Commission to deliver power to the local or regional electric power grid (e.g., electricity generators);

and (2) the combined nameplate capacity (for all such devices at the facility) is greater than or equal to 1 megawatt electric. 3 Reporting of this data element will be addressed under a separate EPA rulemaking; therefore, EPA is taking no action on this data element

under this rulemaking. 4

This data element is proposed to be revised in the March 2013 rulemaking,“2013 Revisions to the Greenhouse Gas Reporting Rule and

Proposed Confidentiality Determinations for New or Substantially Revised Data Elements,” (April 2, 2013, 78 FR 198802); therefore, EPA is

taking no action on this data element under this rulemaking. 5

This data element is proposed to be removed from Part 98 in the March 2013 rulemaking,“2013 Revisions to the Greenhouse Gas Reporting

Rule and Proposed Confidentiality Determinations for New or Substantially Revised Data Elements,” (April 2, 2013, 78 FR 198802); therefore,

EPA is taking no action on this data element under this rulemaking.
Attachment E
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release 

During Review *** 

6560.50 

ENVIRONMENTAL PROTECTION AGENCY 

40 CFR Part 98 

[EPA-HQ-OAR-2010-0929; FRL-9801-2] 

RIN 2060-AQ81 

Revisions to Reporting and Recordkeeping Requirements, and 

Proposed Confidentiality Determinations under the Greenhouse Gas 

Reporting Program 

EO12866_GHGRP Part 98 2060 AQ81 NPRM 20120326 

AGENCY: Environmental Protection Agency (EPA). 

ACTION: Proposed rule. 

SUMMARY: The EPA is proposing amendments to reporting and 

recordkeeping requirements and an alternative verification 

approach for the Greenhouse Gas Reporting Program. This action 

addresses concerns about the potential release of certain data 

that are inputs to emission equations to be reported March 31, 

2015 while maintaining the EPA’s ability to verify emissions and 

ensure compliance with the Greenhouse Gas Reporting Program. In 

addition, the EPA is proposing confidentiality determinations 

for the newly proposed data elements in this action. 

DATES: Comments. Comments must be received on or before [INSERT 

THE DATE 60 DAYS AFTER PUBLICATION OF THIS PROPOSED RULE IN THE 

FEDERAL REGISTER]. 

Public Hearing. The EPA will hold a public hearing on this 

proposed rule if requested. Requests for a hearing must be made 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release 

During Review *** 

Page 2 of 128 

by [INSERT THE DATE 7 DAYS AFTER PUBLICATION OF THIS PROPOSED 

RULE IN THE FEDERAL REGISTER]. Contact the person listed in the 

“FOR FURTHER INFORMATION CONTACT” section by [INSERT THE DATE 7 

DAYS AFTER PUBLICATION OF THIS PROPOSED RULE IN THE FEDERAL 

REGISTER] to request a public hearing. If a hearing is 

requested, the EPA will announce the details, including specific 

dates, times, addresses and contact information for the hearing, 

in a separate Federal Register notice. 

ADDRESSES: Submit your comments, identified by Docket ID No. 

EPA–HQ–OAR–2010-0929, by one of the following methods: 

 Federal eRulemaking Portal: http:// www.regulations.gov. 

Follow the online instructions for submitting comments. 

 Email: GHGReportingCBI@epa.gov 

 Fax: (202) 566–1741. 

 Mail: Environmental Protection Agency, EPA Docket Center 

(EPA/DC), Mailcode 6102T, Attention Docket ID No. EPA–HQ–

OAR–2010-0929, 1200 Pennsylvania Avenue, NW., Washington, 

DC 20460. 

 Hand Delivery: EPA Docket Center, Public Reading Room, EPA 

West Building, Room 3334, 1301 Constitution Avenue, NW., 

Washington, DC 20004. Such deliveries are only accepted 

during the Docket’s normal hours of operation, and special 

arrangements should be made for deliveries of boxed 

information. 

Instructions: Direct your comments to Docket ID No. EPA–HQ–

OAR–2010-0929. The EPA’s policy is that all comments received 

will be included in the public docket without change and may be 

made available online at http://www.regulations.gov, including 

any personal information provided, unless the comment includes 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release 

During Review *** 

Page 3 of 128 

information claimed to be confidential business information 

(CBI) or other information whose disclosure is restricted by 

statute. 

Do not submit information that you consider to be CBI or 

otherwise protected through http://www.regulations.gov or email. 

Send or deliver information identified as CBI to only the mail 

or hand/courier delivery address listed above, attention: Docket 

ID No. EPA–HQ–OAR–2010–0929. The http://www.regulations.gov

website is an “anonymous access” system, which means the EPA 

will not know your identity or contact information unless you 

provide it in the body of your comment. If you send an email 

comment directly to the EPA without going through 

http://www.regulations.gov your email address will be 

automatically captured and included as part of the comment that 

is placed in the public docket and made available on the 

Internet. If you submit an electronic comment, the EPA 

recommends that you include your name and other contact 

information in the body of your comment and with any disk or CD–

ROM you submit. If the EPA cannot read your comment due to 

technical difficulties and cannot contact you for clarification, 

the EPA may not be able to consider your comment. Electronic 

files should avoid the use of special characters, any form of 

encryption, and be free of any defects or viruses. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release 

During Review *** 

Page 4 of 128 

Docket: All documents in the docket are listed in the 

http://www.regulations.gov index. Although listed in the index, 

some information is not publicly available, e.g., CBI or other 

information whose disclosure is restricted by statute. Certain 

other material, such as copyrighted material, will be publicly 

available only in hard copy. Publicly available docket materials 

are available either electronically in 

http://www.regulations.gov or in hard copy at the Air Docket, 

EPA/DC, EPA West, Room B102, 1301 Constitution Ave., NW., 

Washington, DC. This Docket Facility is open from 8:30 a.m. to 

4:30 p.m., Monday through Friday, excluding legal holidays. The 

telephone number for the Public Reading Room is (202) 566–1744, 

and the telephone number for the Air Docket is (202) 566–1742. 

FOR FURTHER GENERAL INFORMATION CONTACT: Carole Cook, Climate 

Change Division, Office of Atmospheric Programs (MC–6207J), 

Environmental Protection Agency, 1200 Pennsylvania Ave., NW., 

Washington, DC 20460; telephone number: (202) 343–9263; fax 

number: (202) 343–2342; email address: GHGreporting@epa.gov. For 

technical information, contact the Greenhouse Gas Reporting Rule 

Helpline at: 

http://www.epa.gov/climatechange/emissions/ghgrule_contactus.htm

. Alternatively, contact Carole Cook at 202–343–9263. 

Worldwide Web (WWW). In addition to being available in the 

docket, an electronic copy of this proposal, memoranda to the 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release 

During Review *** 

Page 5 of 128 

docket, and all other related information will also be available 

through the WWW on EPA’s greenhouse gas reporting rule Web site 

at 

http://www.epa.gov/climatechange/emissions/ghgrulemaking.html. 

SUPPLEMENTARY INFORMATION: 

Additional Information on Submitting Comments: To expedite 

review of your comments by Agency staff, you are encouraged to 

send a separate copy of your comments, in addition to the copy 

you submit to the official docket, to Carole Cook, Climate 

Change Division, Office of Atmospheric Programs (MC–6207J), 

Environmental Protection Agency, 1200 Pennsylvania Ave., NW., 

Washington, DC, 20460, telephone (202) 343–9263, email 

GHGReportingCBI@epa.gov. 

Regulated Entities. This proposed rule revision on 

reporting and recordkeeping requirements and verification 

procedures would affect entities that must submit annual 

greenhouse gas (GHG) reports under the Greenhouse Gas Reporting 

Program (40 CFR part 98). The Administrator has determined that 

40 CFR part 98 is subject to the provisions of Clean Air Act 

(CAA) section 307(d). See CAA section 307(d)(1)(V) (the 

provisions of CAA section 307(d) apply to “such other actions as 

the Administrator may determine”). Entities affected by this 

proposal are owners or operators of facilities that are direct 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release 

During Review *** 

Page 6 of 128 

emitters of greenhouse gases (GHGs), which include those listed 

in Table 1 of this preamble: 

Table 1. Examples of Affected Entities by Category 

Category NAICS Examples of affected facilities 

General 

Stationary Fuel 

Combustion 

Sources 

 Facilities operating boilers, 

process heaters, incinerators, 

turbines, and internal combustion 

engines. 

321 Manufacturers of lumber and wood 

products. 

322 Pulp and paper mills. 

325 Chemical manufacturers. 

324 Petroleum refineries and 

manufacturers of coal products. 

316, 326, 

339 

Manufacturers of rubber and 

miscellaneous plastic products. 

331 Steel works, blast furnaces. 

332 Electroplating, plating, polishing, 

anodizing, and coloring. 

336 Manufacturers of motor vehicle 

parts and accessories. 

221 Electric, gas, and sanitary 

services. 

622 Health services. 

611 Educational services. 

325193 Ethyl alcohol manufacturing 

facilities. 

311611 Meat processing facilities 

311411 Frozen fruit, juice, and vegetable 

manufacturing facilities. 

311421 Fruit and vegetable canning 

facilities. 

Electricity 

Generation 

221112 Fossil-fuel fired electric 

generating units, including units 

owned by Federal and municipal 

governments and units located in 

Indian Country. 

Adipic Acid 

Production 

325199 Adipic acid manufacturing 

facilities. 

Aluminum 

Production 

331312 Primary aluminum production 

facilities 

Ammonia 

Manufacturing 

325311 Anhydrous and aqueous ammonia 

production facilities. 
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Category NAICS Examples of affected facilities 

Cement 

Production 

327310 Portland Cement manufacturing 

plants. 

Ferroalloy 

Production 

331112 Ferroalloys manufacturing 

facilities. 

Fluorinated GHG 

Production 

325120 Industrial gases manufacturing 

facilities. 

Glass Production 327211 Flat glass manufacturing 

facilities. 

327213 Glass container manufacturing 

facilities. 

327212 Other pressed and blown glass and 

glassware manufacturing facilities. 

HCFC-22 

Production and 

HFC-23 

Destruction 

325120 Chlorodifluoromethane manufacturing 

facilities. 

Hydrogen 

Production 

325120 Hydrogen production facilities 

Iron and Steel 

Production 

331111 Integrated iron and steel mills, 

steel companies, sinter plants, 

blast furnaces, basic oxygen 

process furnace shops. 

Lead Production 331419 Primary lead smelting and refining 

facilities. 

331492 Secondary lead smelting and 

refining facilities. 

Lime Production 327410 Calcium oxide, calcium hydroxide, 

dolomitic hydrates manufacturing 

facilities. 

Magnesium 

Production 

331419 Primary lead smelting and refining 

facilities. 

331492 Secondary lead smelting and 

refining facilities. 

Manure 

Management 

112111 

112120 

112210 

112310 

112330 

112320 

Beef cattle feedlots. 

Dairy cattle and milk production 

facilities. 

Hog and pig farms. 

Chicken egg production facilities. 

Turkey Production. 

Broilers and other meat type 

chicken production. 

Municipal Solid 

Waste Landfills 

562212 

221320 

Solids Waste Landfills. 

Sewage treatment facilities. 

Nitric Acid 

Production 

325311 Nitric acid production facilities 
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Category NAICS Examples of affected facilities 

Petrochemical 

Production 

32511 Ethylene dichloride production 

facilities. 

325199 Acrylonitrile, ethylene oxide, 

methanol production facilities. 

325110 Ethylene production facilities. 

325182 Carbon black production facilities. 

Petroleum and 

Natural Gas 

Systems 

486210 Pipeline transportation of natural 

gas. 

221210 Natural gas distribution 

facilities. 

211 Extractors of crude petroleum and 

natural gas. 

211112 Natural gas liquid extraction 

facilities. 

Petroleum 

Refineries 

324110 Petroleum refineries. 

Phosphoric Acid 

Production 

325312 Phosphoric acid manufacturing 

facilities. 

Pulp and Paper 

Manufacturing 

322110 Pulp mills. 

322121 Paper mills. 

322130 Paperboard mills. 

Silicon Carbide 

Production 

327910 Silicon carbide abrasives 

manufacturing facilities. 

Soda Ash 

Manufacturing 

325181 Alkalies and chlorine manufacturing 

facilities. 

212391 Soda ash, natural, mining and/or 

beneficiation. 

Titanium Dioxide 

Production 

325188 Titanium dioxide manufacturing 

facilities. 

Zinc Production 331419 Primary zinc refining facilities. 

331492 Zinc dust reclaiming facilities, 

recovering from scrap and/or 

alloying purchased metals. 

311411 Frozen fruit, juice and vegetable 

manufacturing facilities. 

311421 Fruit and vegetable canning 

facilities. 

Wastewater 

Treatment 

322110 Pulp mills. 

322121 Paper mills. 

322122 Newsprint mills. 

322130 Paperboard mills. 

311611 Meat processing facilities. 

311411 Frozen fruit, juice and vegetable 

manufacturing facilities. 
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Category NAICS Examples of affected facilities 

311421 Fruit and vegetable canning 

facilities. 

325193 Ethanol manufacturing facilities. 

Table 1 of this preamble is not intended to be exhaustive, 

but rather provides a guide for readers regarding facilities and 

suppliers likely to be affected by this action. Types of 

facilities other than those listed in this table may also be 

affected by this action. To determine whether you are affected 

by this action, you should carefully examine the applicability 

criteria found in 40 CFR part 98, subpart A or the relevant 

criteria in the subparts. If you have questions regarding the 

applicability of this action to a particular facility or 

supplier, consult the person listed in the preceding FOR FURTHER 

GENERAL INFORMATION CONTACT section. 

Many facilities that are affected by 40 CFR part 98 have 

GHG emissions from multiple source categories listed in Table 1 

of this preamble. 

Acronyms and Abbreviations. The following acronyms and 

abbreviations are used in this document. 

BAMM Best Available Monitoring Methods 

CAA Clean Air Act 

CO2 carbon dioxide 

CBI confidential business information 

CEMS Continuous Emission Monitoring System 

CFR Code of Federal Regulations 

e-GGRT Electronic Greenhouse Gas Reporting Tool 
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EIA Energy Information Administration 

EPA U.S. Environmental Protection Agency 

FR Federal Register 

GHG greenhouse gas 

GHGRP Greenhouse Gas Reporting Program 

HCFC-22 chlorodifluoromethane 

HFC hydrofluorocarbons 

HQ Headquarters 

ICR Information Collection Request 

MW megawatt 

NAICS North American Industry Classification System 

NTTAA National Technology Transfer and Advancement Act 

OMB Office of Management & Budget 

RFA Regulatory Flexibility Act 

UMRA Unfunded Mandates Reform Act 

U.S. United States 

WWW Worldwide Web 

TABLE OF CONTENTS 

I. Executive Summary and Background

A. Executive Summary

B. Background

C. Subparts Covered in this Proposed Rule

D. Legal Authority

II. Summary of Proposed Changes to Part 98 Reporting and 

Recordkeeping Requirements

A. Proposed Use of Inputs Verification Tool

B. Proposed Revisions to Reporting of Data Elements Deferred 

until 2015

C. Proposed Changes to Recordkeeping Requirements

D. Proposed New Data Elements to be Reported

III. Rationale for Proposed Changes to Reporting and 

Recordkeeping Requirements

A. Proposed Inputs Verification Tool and Amendment to Reporting 

Requirements

B. Proposed Revisions to Recordkeeping Requirements

C. Proposed Requirement to Report Additional Data
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IV. Confidentiality Determination for Proposed New Data Elements 

to be Reported

V. Impacts of the Proposed Rule

A. How were the costs of this proposed rule estimated?

B. Additional Impacts of the Proposed Amendments

VI. Statutory and Executive Order Reviews

A. Executive Order 12866: Regulatory Planning and Review and 

Executive Order 13563: Improving Regulation and Regulatory 

Review

B. Paperwork Reduction Act

C. Regulatory Flexibility Act (RFA)

D. Unfunded Mandates Reform Act (UMRA)

E. Executive Order 13132: Federalism

F. Executive Order 13175: Consultation and Coordination with 

Indian Tribal Governments.

G. Executive Order 13045: Protection of Children from 

Environmental Health Risks and Safety Risks

H. Executive Order 13211: Actions that Significantly Affect 

Energy Supply, Distribution, or Use

I. National Technology Transfer and Advancement Act

J. Executive Order 12898: Federal Actions to Address 

Environmental Justice in Minority Populations and Low-Income 

Populations

I. Executive Summary and Background 

A. Executive Summary 

The Greenhouse Gas Reporting Program (GHGRP) collects 

greenhouse gas data from 41 source categories and currently has 

received 2 to 3 years of data from these sources. Greenhouse gas 

emissions from direct emitters are calculated using a variety of 

methods, including direct measurement, mass balance, and the use 

of emission factors. Reporters not using direct measurement must 

use equations to calculate emissions. The inputs to these 

emission equations often include process or production data that 

are specific to each facility’s operations. These “inputs to 
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emission equations” play an important role in the Agency’s 

ability to verify facility-level emissions and ensure compliance 

with the program. 

On July 7, 2010, the EPA proposed confidentiality 

determinations for the majority of data elements required to be 

reported under the GHGRP, as well as for the majority of source 

categories covered by the program. In the July 7, 2010 action, 

the EPA proposed that data elements categorized as “inputs to 

emission equations” are emission data. The CAA precludes 

“emission data” from being treated as confidential. 

Based on subsequent industry concerns regarding the 

potential release of data elements categorized as “inputs to 

emission equations,” the EPA deferred reporting of these data 

elements (see August 25, 2011 final action, 76 FR 53057) to 

allow the EPA to complete its evaluation of the potential impact 

from the public release of these data elements (see 76 FR 53060) 

and, if appropriate, to propose amendments to Part 98 (see 75 FR 

81355). Based on the analysis conducted, today’s action proposes 

amendments to reporting and recordkeeping requirements and an 

alternative verification approach for certain reporters subject 

to 24 subparts for which the reporting deadline for inputs to 

emission equations was deferred until 2015 and disclosure 

concerns have been identified. Proposed amendments include: 
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 Adding a requirement for certain reporters under 24 

subparts to use an EPA-provided inputs verification tool. 

For these subparts, the designated inputs to emission 

equations for which reporting was deferred to 2015 and 

disclosure concerns have been identified would be entered 

into the tool.1 The tool would calculate the emissions and 

perform electronic verification. The tool would not retain 

the entered inputs (i.e., the inputs would not be reported 

to EPA); instead, the tool would conduct certain checks 

(e.g., accuracy of the inputs) at the time of data entry 

and generate a verification summary. The verification 

summary, which would be accessible to the EPA once the 

annual report is submitted, would provide the EPA with 

information to conduct further verification if necessary. 

 For reporters required to use the inputs verification tool, 

changing the required format for maintaining records of 

these inputs to emission equations. 

 For reporters required to use the inputs verification tool, 

lengthening the record retention period from 3 to 5 years 

for all records maintained under Part 98 (including 

subparts that do not require the use of the tool). 

 For certain reporters required to use the inputs 

verification tool, adding new data elements to be reported 

for the EPA’s verification purposes, and proposing 

confidentiality determinations for the new data elements 

proposed to be reported. 

 For reporters required to use the inputs verification tool, 

removing the requirement to report the inputs to emission 

equations for which reporting was deferred to 2015 and 

disclosure concerns have been identified, and requiring 

these data to be kept as records. 

 Reporting requirements for inputs to equations for which 

disclosure concerns were not identified (and would still be 

 

1

 Under this proposal, the inputs verification tool would not be 

required to be used by reporters for any reported GHG for 

which the reporter uses a CEMS or an EPA-approved alternative 

method (as allowed under sections 98.33(a)(5), 98.53(a)(2), and 

98.223(a)(2) of Part 98) to calculate the reported GHG value, 

rather than using "inputs to equations" data elements and the 

associated EPA-provided calculation methodologies to calculate 

the reported GHG value. 
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useful to EPA) are not proposed to be amended in this action. 

For these inputs to equations, the deferral would expire in 

March 2015, and EPA would collect these data. 

The proposed changes in this action build on the EPA’s 

experience and success with electronic reporting and 

verification during the first 3 years of the GHGRP. By requiring 

the use of the inputs verification tool, which would calculate 

GHG emissions based on the inputs to the emissions equations, 

the EPA would have the ability to identify facilities that 

potentially reported emissions incorrectly. This, combined with 

additional verification checks of the inputs to emission 

equations that the inputs verification tool would conduct 

(during the process of reporters entering data into the inputs 

verification tool), would provide the EPA with information 

necessary to conduct further verification once the annual report 

is submitted. This alternative verification approach, including 

the changes to the recordkeeping requirements and additional 

reporting requirements, would provide an alternative to 

collecting certain data elements for which reporting was 

deferred to March 31, 2015 and disclosure concerns have been 

identified, while maintaining the EPA’s ability to verify data 

and ensure compliance with the GHGRP. 

B. Background
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On October 30, 2009, the EPA published the Greenhouse Gas 

Reporting Rule, 40 CFR part 98, requiring annual reporting of 

GHG data from a broad range of industry sectors (74 FR 56260). 

Under the Greenhouse Gas Reporting Rule and its subsequent 

amendments (hereinafter referred to as “Part 98”), the EPA 

requires annual reporting of data from certain facilities and 

suppliers above specified emission or quantity supplied 

thresholds. On July 7, 2010 (75 FR 39094) and subsequent 

proposals (77 FR 1434, January 10, 2012; 77 FR 10434, February 

22, 2012), we proposed confidentiality determinations for the 

data elements required to be reported. The confidentiality of 

each reported data element was determined using a two-step 

approach: (1) grouping data elements into 11 data categories 

(e.g., inputs to emission equations, emissions, and unit/process 

operating characteristics that are not inputs to emission 

equations for direct emitter source categories); and (2) making 

confidentiality determinations either categorically or on an 

individual data elements basis. Refer to both the July 7, 2010 

proposal (75 FR 39097) and the May 26, 2011 final rule (76 FR 

30785 - 30786) for more detailed descriptions of this process. 

Refer to the May 26, 2011 final rule also for a discussion of 

individual data element confidentiality determinations. We have 

finalized confidentiality determinations for data elements 

except those in the “inputs to emission equations” category (May 
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26, 2011, 76 FR 30782; August 13, 2012, 77 FR 48072; and August 

24, 2012, 77 FR 51477)2

. For data elements in this category, we 

proposed that they meet the definition of “emission data” under 

40 CFR 2.301(a)(2)(i). Because emission data are not entitled to 

confidential treatment under section 114(c) of the Clean Air 

Act, we did not evaluate whether such data elements would 

qualify as CBI, including whether disclosure would likely cause 

substantial competitive harm to the reporting facilities. (75 FR 

39105 and 39108, July 7, 2010). 

Following our proposal that data elements assigned to the 

“inputs to emission equations” category are not entitled to 

confidential treatment, we received numerous industry comments 

asserting that competitive harm would result from public release 

of many of these data elements. We determined that “these 

concerns warranted an in-depth evaluation of the potential 

impact from the release of inputs to emission equations.” (76 FR 

53060; August 25, 2011). In a notice dated December 27, 2010, we 

issued a call for information (75 FR 81354) requesting 

additional information to assist us in conducting our 

evaluation. To allow sufficient time to complete this evaluation 

through notice and comment, we deferred the reporting deadline 

 

2

 There are a small number of data elements (besides data elements categorized as 

“inputs to emission equations”) for which we have not made a final confidentiality 

determinations because we concluded that a determination of confidentiality for the 

data element should be made on a case-by-case facility basis (according to individual 

circumstances of the facility). 
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for data elements assigned to the “inputs to emission equation” 

category. Reporting of certain of these data elements was 

deferred to March 31, 2013, as specified in Table A-6 of subpart 

A; and reporting of the remainder of these data elements was 

deferred to March 31, 2015, as specified in Table A-7 of subpart 

A (see the August 25, 2011 final rule, 76 FR 53077). 

Our process for evaluating competitive harm was documented 

in the final deferral notice (August 25, 2011, 76 FR 53057) and 

the accompanying memorandum entitled “Process for Evaluating and 

Potentially Amending Part 98 Inputs to Emission Equations” 

(Docket ID EPA-HQ-OAR-2010-0929). As discussed in the final 

deferral notice and memorandum, our evaluation involved a fourstep process, as follows: 

 Step 1: Determine whether each data element assigned to the 

“inputs to emission equations” category is already publicly 

available. 

 Step 2: For data elements assigned to the “inputs to 

emission equations” category that are not publicly 

available, evaluate whether disclosure of the information 

is likely to result in substantial competitive harm. 

 Step 3: For data elements assigned to the “inputs to 

emission equations” category that are likely to cause 

substantial competitive harm if disclosed, evaluate 

potential alternative calculation methods. 

 Step 4: For data elements assigned to the “inputs to 

emission equations” category that are likely to cause 

substantial competitive harm if disclosed, evaluate 

potential alternative verification methods. 

Based on each step of the four-step evaluation process, an 

analysis of all data elements for which reporting is deferred to 
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Page 18 of 128 

March 31, 2015 was conducted.3

 The results of the analysis are 

documented in four memoranda, as follows: 

 “Summary of Public Availability of Inputs to Emission 

Equations for Which Reporting was Deferred Until March 31, 

2015.” 

 “Evaluation of Competitive Harm From Reporting 2015 Inputs 

to Equations.” 

 “Summary of Alternative Calculation Methods.” 

 “Summary of Alternative Verification Methods.” 

These memoranda are available in EPA docket ID No. EPA–HQ–

OAR–2010-0929. Based on the results of these analyses, the EPA 

is proposing in today’s action to make certain amendments to 

Part 98. 

C. Subparts Covered in this Proposed Rule

The proposed amendments affect all subparts listed in Table 

2 of this preamble. Table 2 includes most of the subparts with 

inputs to emission equations for which the reporting deadline 

was deferred until 2015. Subpart W (Petroleum and Natural Gas 

Systems), Subpart II (Industrial Wastewater Treatment), and 

subpart C (only certain combustion units associated with devices 

connected and able to deliver power to the local or regional 

electric power grid, as specified in Table 2) are not included 

 

3

 Based on the same four-step process, we also evaluated all data elements for 

which reporting was deferred to March 31, 2013 (Part 98 Table A-6) and took 

no further action. As a result, applicable facilities were required to report 

these data by April 1, 2013. For a discussion of this evaluation, refer to 

the EPA's memorandum "Summary of Evaluation of Greenhouse Gas Reporting 

Program (GHGRP) Part 98 “Inputs to Emission Equations” Data Elements Deferred 

Until 2013" (December 17, 2012), available at 

http://www.epa.gov/ghgreporting/documents/pdf/2012/documents/2013-inputsmemo.pdf. 
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in Table 2 because none of the inputs to emission equations 

required to be reported by reporters in these source categories 

are being amended, as no disclosure concerns were identified. 

Subpart I of part 98 is not included in Table 2 because 

reporting of inputs to emission equations under this subpart 

were addressed under a separate rulemaking proposed on October 

16, 2012 (77 FR 63538). Additionally, parts of these proposed 

rule amendments would affect subparts not listed in Table 2. 

Specifically, for reporters subject to both a subpart listed in 

Table 2 and a subpart of Part 98 not listed in this table, the 

proposed revision to the recordkeeping duration would apply to 

the records required for all Part 98 subparts (to which the 

reporter is subject). Refer to Sections II.C and III.B of this 

preamble for further discussion of this proposed amendment. 

Table 2. Subparts Affected by the Proposed Amendments.1,2

Subpart 

C—General Stationary Fuel 

Combustion except Certain 

Combustion Units Connected to 

Devices that are Connected to the 

Local or Regional Electric Power 

Grid3

S—Lime Manufacturing 

E—Adipic Acid Production U—Miscellaneous Uses of 

Carbonate 

F—Aluminum Production V—Nitric Acid Production 

G—Ammonia Manufacturing X—Petrochemical Production 

H—Cement Production Y—Petroleum Refineries 

K—Ferroalloy Production Z—Phosphoric Acid Production 

L—Fluorinated Gas Production AA—Pulp and Paper 

Manufacturing 
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N—Glass Production BB—Silicon Carbide Production 

O—HCFC–22 Production and HFC–23 

Destruction 

CC—Soda Ash Manufacturing 

P—Hydrogen Production EE—Titanium Dioxide 

Production 

Q—Iron and Steel Production GG—Zinc Production 

R—Lead Production TT—Industrial Waste Landfills 1

 Certain proposed amendments affect other subparts not listed in this table 

as follows: for reporters subject to both a subpart listed in this table and 

a subpart of Part 98 not listed in this table, the proposed revision to the 

recordkeeping duration would apply to the records required for all Part 98 

subparts to which the reporter is subject. 

2

 Under this proposal, the inputs verification tool would not be required to 

be used by reporters for any reported GHG for which the reporter uses a CEMS 

or an EPA-approved alternative method (as allowed under sections 98.33(a)(5), 

98.53(a)(2), and 98.223(a)(2) of Part 98) to calculate the reported GHG 

value, rather than using "inputs to equations" data elements and the 

associated EPA-provided calculation methodologies to calculate the reported 

GHG value.

3 The combustion units not affected by the proposed amendments include those 

meeting the following criteria: (1) the combustion unit is connected to a 

device that has been granted access by the Public Utilities Commission to 

deliver power to the local or regional electric power grid (e.g., electricity 

generators excluding generators connected to combustion units subject to 

subpart D of this part); and (2) the combined nameplate capacity (for all 

such devices at the facility excluding generators connected to combustion 

units subject to subpart D of this part)) is greater than or equal to 1 

megawatt electric. Refer to Section III.A.3 of this preamble for a discussion 

of the EPA’s rationale for proposing that combustion units meeting these 

criteria not be affected by the proposed amendments. 

D. Legal Authority

The EPA is proposing these rule amendments under its 

existing CAA authority provided in CAA section 114. As stated in 

the preamble to the 2009 final GHG reporting rule (74 FR 56260, 

October 30, 2009), CAA section 114(a)(1) provides the EPA broad 

authority to require the information proposed to be gathered by 

this rule because such data would inform and are relevant to the 

EPA’s carrying out a wide variety of CAA provisions. See the 
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preambles to the proposed (74 FR 16448, April 10, 2009) and 

final Part 98 (74 FR 56260) for further information. 

In addition, pursuant to sections 114, 301, and 307 of the 

CAA, the EPA is proposing confidentiality determinations for the 

new data elements proposed in this notice. Section 114(c) of the 

CAA requires that the EPA make publicly available information 

obtained under CAA section 114 except for information (excluding 

emission data) that qualifies for confidential treatment. The 

Administrator has determined that this action (Part 98 amendment 

and confidentiality determinations) is subject to the provisions 

of CAA section 307(d). 

II. Summary of Proposed Changes to Part 98 Reporting and 

Recordkeeping Requirements 

The EPA is proposing revisions to the reporting and 

recordkeeping requirements in Part 98 and alternative 

verification procedures that would apply to certain reporters 

subject to any of the 24 subparts listed in Table 2 of this 

preamble. Section II.A of this preamble summarizes a proposed 

new requirement for these reporters using inputs to emission 

equations for which reporting was deferred to March 31, 2015 

(hereafter referred to as “inputs to equations” data elements) 

to calculate reported GHGs. These reporters would be required to 

use an EPA-provided electronic inputs verification tool to 

calculate emissions using data elements for which reporting was 
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deferred to March 31, 2015 (hereafter referred to as “inputs to 

equations” data elements), allowing the EPA to complete 

electronic verification of reported GHG emissions data without 

the need to collect “inputs to equations” data elements for 

which disclosure concerns have been identified. Section II.B of 

this preamble summarizes the EPA’s proposal to remove, for these 

reporters, the requirement to report many “inputs to equations” 

data elements. Section II.C of this preamble summarizes proposed 

revisions to the recordkeeping requirements for these reporters. 

Section II.D of this preamble summarizes proposed new reporting 

requirements for these reporters. Section III of this preamble 

explains the rationale for the proposed amendments summarized in 

Sections II.A through II.D. Section IV of this preamble presents 

the EPA’s proposed confidentiality determinations for proposed 

new data elements and the EPA’s rationale for these 

determinations. Section V of this preamble presents the cost and 

impacts associated with these proposed amendments. 

A. Proposed Use of Inputs Verification Tool 

The EPA is proposing that facilities subject to the 

subparts listed in Table 2 of this preamble and that use “inputs 

to equations” data elements to calculate reported GHGs use an 

electronic inputs verification tool being developed by the EPA, 

which would calculate and verify GHG emissions. Refer to section 

III.A.1 of this preamble for a web-link to EPA’s “pilot” inputs 
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verification tool for one subpart of Part 98, available during 

the public comment period for this rulemaking. The 

“pilot” demonstrates how the tool would work within e-GGRT, as 

well as the types of verification checks that would be 

conducted. The inputs verification tool would be deployed within 

the EPA’s Electronic Greenhouse Gas Reporting Tool (e-GGRT) and 

would be integrated without interrupting the current electronic 

reporting process. While reporters enter data into e-GGRT that 

are required to be reported in the annual report, reporters 

would also enter into e-GGRT (via the inputs verification tool) 

the “inputs to equations” data elements that the EPA is 

proposing to remove from the reporting requirements. The tool 

would use the entered “inputs to equations” data elements to 

calculate the equation outputs, conduct electronic verification 

checks on the “inputs to equations” data elements, and generate 

a verification summary. The tool would not retain the entered 

“inputs to equations” data elements for which the EPA is 

proposing that the reporting requirement be removed. 

Accordingly, the EPA would not have access to these “inputs to 

equations” data elements. Instead, the EPA would rely on the 

verification summary, which would become accessible to the EPA 

when annual reports are submitted, as a first step for 

conducting verification once the annual report is submitted. 
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Sources subject to multiple subparts under Part 98 would be 

required to use the inputs verification tool for only those 

subparts listed in Table 2 of this preamble. The EPA is 

proposing that reporters use this tool starting with reporting 

year 2014. Refer to Section III.A of this preamble for further 

discussion of this proposed requirement. 

This proposed requirement to use the inputs verification 

tool is specified in 40 CFR 98.5, Subpart A. Reporters would 

determine applicability under this new requirement based on a 

proposed new Table A-8 to Part 98, which lists all equations 

under Part 98 for which the inputs verification tool must be 

used. Reporters calculating reported GHGs using equations listed 

in Table A-8 would be required to enter “inputs to equations” 

data elements that have been removed from the reporting 

requirements into the inputs verification tool. 

B. Proposed Revisions to Reporting of Data Elements Deferred 

until 2015

The EPA is proposing to remove the reporting requirement 

for 435 “inputs to equations” data elements in the subparts 

listed in Table 2 of this preamble. Table 3 of this preamble 

provides a summary of how many data elements would be removed 

from reporting for each subpart. Refer to Table 1 in the 

memorandum “List of ‘Inputs to Equations’ Data Elements Proposed 

Not To Be Reported” (refer to Docket ID No. EPA–HQ–OAR–2010-
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0929) for a complete list of these 435 data elements. For all 

remaining “inputs to equations” data elements not represented in 

Table 3 of this preamble, the EPA is not amending these 

reporting requirements and would, therefore, let the deferral of 

these data elements expire on March 31, 2015. As a result, by 

March 31, 2015, all of the “inputs to equations” data elements 

for subpart W (Petroleum and Natural Gas Systems), Subpart II 

(Industrial Wastewater Treatment), and the additional “inputs to 

equations” data elements for which reporting is not proposed to 

be removed as indicated in Table 3 of this preamble, would be 

reported for future reporting years and for all prior reporting 

years, including reporting year 2014. For a list of these 

“inputs to equations” data elements that would be reported, 

refer to Table 2 of the memorandum cited above. 

Table 3. Subparts For Which Reporting Requirements are Amended 

Subpart

Number of “Inputs to 

Equations” Data 

Elements 

Number of “Inputs 

to Equations” Data 

Elements Proposed 

Not to Be Reported 

C—General Stationary 

Fuel Combustion 

Except Certain 

Combustion Units 

Connected to Devices 

Connected to the 

Local or Regional 

Power Grid2

261 261

E—Adipic Acid 

Production 

21 11 

F—Aluminum Production 29 29 
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Subpart

Number of “Inputs to 

Equations” Data 

Elements 

Number of “Inputs 

to Equations” Data 

Elements Proposed 

Not to Be Reported 

G—Ammonia 

Manufacturing 

8 8 

H—Cement Production 16 14 

K—Ferroalloy 

Production 

13 13 

L—Fluorinated Gas 

Production 

55 46 

N—Glass Production 3 3 

O—HCFC–22 Production 

and HFC–23 

Destruction 

15 12 

P—Hydrogen Production 7 7 

Q—Iron and Steel 

Production 

93 92 

R—Lead Production 10 10 

S—Lime Manufacturing 9 9 

U—Miscellaneous Uses 

of Carbonate 

6 6 

V—Nitric Acid 

Production 

21 10 

X—Petrochemical 

Production 

21 21 

Y—Petroleum 

Refineries 

80 70 

Z—Phosphoric Acid 

Production 

4 4 

AA—Pulp and Paper 

Manufacturing 

31 28 

BB—Silicon Carbide 

Production 

3 3 

CC—Soda Ash 

Manufacturing 

10 4 

EE—Titanium Dioxide 

Production 

2 2 

GG—Zinc Production 8 8 

TT—Industrial Waste 

Landfills 

3 3 
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Page 27 of 128 1 Includes one “inputs to equations” data element, 40 CFR 98.3(d)(3)(v), which 

is specified in subpart A of part 98 and applies to only certain reporters 

under subpart C of part 98. 

2

 The reporting requirements applicable to certain combustion units subject to 

subpart C remain the same under the proposed amendment. Subpart C would 

continue to require reporting of all applicable “inputs to equations” data 

elements for combustion units that meet the following criteria: (1) the 

combustion unit is connected to a device that has been granted access by the 

Public Utilities Commission to deliver power to the local or regional 

electric power grid (e.g., electricity generators excluding generators 

connected to combustion units subject to subpart D of this part); and (2) the 

combined nameplate capacity (for all such devices at the facility excluding 

generators connected to combustion units subject to subpart D of this part) 

is greater than or equal to 1 megawatt electric. Subpart C reporters would 

not report “inputs to equations” data elements for all other types of 

combustion units subject to subpart C. 

In order to ease the burden for facilities, the EPA is 

proposing that the “inputs to equations” data elements that are 

not being amended in this action (and therefore would be 

reported for reporting years prior to reporting year 2014) be 

reported as part of the annual report for reporting year 2014. 

Specifically, when reporters prepare their reporting year 2014 

annual report via e-GGRT, they would be required to include 

these “inputs to equations” data elements for reporting year 

2014 as well as for all applicable previous reporting years. The 

annual report, including these “inputs to equations” data 

elements that would still be reported, would be submitted via eGGRT. This proposed approach would prevent facilities from being 

required to revise, re-certify, and re-submit annual reports for 

each previous reporting year. 

C. Proposed Changes to Recordkeeping Requirements
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For each facility subject to a subpart listed in Table 2 of 

this preamble that uses “inputs to equations” data elements to 

calculate and report GHGs (i.e., subject to using the proposed 

inputs verification tool), the EPA is proposing that the 

facility retain all records, including records for subparts not 

subject to the inputs verification tool requirement, for 5 

years, rather than the current 3-year record retention period. 

In other words, if any facility subject to using the proposed 

inputs verification tool is also subject to a subpart of Part 98 

not listed in Table 2, we propose that records required for 

those other subparts also be maintained for the 5 years. For 

example, if such a facility is required to report under both 

subpart C (in Table 2) and subpart HH (not in Table 2), the 

facility would be required to maintain all records required 

under both subparts for 5 years following submittal of the 

annual report. The EPA is proposing that this 5-year record 

retention requirement begin with records for reporting year 

2010. 

Additionally, we are proposing that, at the time a reporter 

subject to using the proposed inputs verification tool completes 

entry of all “inputs to equations” data elements into the tool, 

the reporter would be required to keep a file generated by the 

tool that lists the entered “inputs to equations” data elements. 

The reporter would be required to maintain a copy of the file as 
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a record of the entered inputs. As currently required in 40 CFR 

98.3(g), subpart A, this file may be maintained in electronic or 

hard copy format. As discussed above, this record would be 

required to be maintained for 5 years. 

Refer to Section III.B of this preamble for further 

discussion of these proposed recordkeeping requirements. 

D. Proposed New Data Elements to be Reported 

The EPA is proposing that reporters subject to using the 

proposed inputs verification tool in subparts E, G, H, P, Q, S, 

V, X, Y, and AA of Part 98, be required to report the additional 

data elements listed per subpart in Table 4 of this preamble. 

Proposed confidentiality determinations for these proposed data 

elements are presented in Section IV of this preamble. 

Table 4. Proposed New Data Elements for Subparts E, G, H, P, Q, 

S, V, X, Y, and AA of Part 98 

Subpart Subpart Name New Data Element Description 

E Adipic Acid 

Production 

Annual quantity of cyclohexane fed 

to all production lines (metric 

tons). 

Annual percent N2O emission 

reduction for all production units 

combined. 

G Ammonia 

Production 

Annual ammonia production (metric 

tons). 

Annual methanol production (metric 

tons), if this quantity is not 

reported under subpart X of Part 98. 

H Cement Production Annual clinker production (metric 

tons). 

Annual average clinker CO2 emission 

factor for the facility, averaged 

across all kilns (metric tons 

CO2/metric ton clinker produced). 
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Subpart Subpart Name New Data Element Description 

Annual average cement kiln dust 

(CKD) CO2 emission factor for the 

facility, averaged across all kilns 

(metric tons CO2/metric ton CKD 

produced). 

P Hydrogen 

Production 

Name and annual quantity (metric 

tons) of each carbon-containing fuel 

and feedstock. 

Annual methanol production (metric 

tons), if this quantity is not 

reported under subpart X of Part 98. 

Q Iron and Steel 

Production 

If you use the carbon mass balance 

method in 40 CFR 98.173(b)(1) to 

determine CO2 emissions: The annual 

mass (metric tons) of all gaseous, 

liquid, and solid fuels (combined) 

used in process units specified in 

Equations Q-1 through Q-7 of Part 

98, calculated as specified in a 

proposed new Equation Q-9 in the 

proposed rule amendments. Do not 

include fuel used in a stationary 

combustion unit where emissions are 

reported under subpart C of this 

part. 

If you use the carbon mass balance 

method in 40 CFR 98.173(b)(1) to 

determine CO2 emissions: The annual 

mass (metric tons) of all non-fuel 

material inputs (combined) specified 

in Equations Q-1 through Q-7 of Part 

98, calculated as specified in a 

proposed new Equation Q-10 in the 

proposed rule amendments. 

If you use the carbon mass balance 

method in 40 CFR 98.173(b)(1) to 

determine CO2 emissions: The annual 

mass (metric tons) of all solid and 

liquid products and byproducts 

(combined) specified in Equations Q1 through Q-7 of Part 98, calculated 

as specified in a proposed new 

Equation Q-11 in the proposed rule 

amendments. 
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Subpart Subpart Name New Data Element Description 

If you use the carbon mass balance 

method in 40 CFR 98.173(b)(1) to 

determine CO2 emissions: The 

weighted average carbon content of 

all gaseous, liquid, and solid fuels 

(combined) included in proposed new 

Equation Q-9, calculated as 

specified in a proposed new Equation 

Q-12 in the proposed rule 

amendments. 

If you use the carbon mass balance 

method in 40 CFR 98.173(b)(1) to 

determine CO2 emissions: The 

weighted average carbon content of 

all non-fuel inputs to all furnaces 

(combined) included in proposed new 

Equation Q-10, calculated as 

specified in a proposed new Equation 

Q-13 in the proposed rule 

amendments. 

If you use the carbon mass balance 

method in 40 CFR 98.173(b)(1) to 

determine CO2 emissions: The 

weighted average carbon content of 

all solid and liquid products and 

byproducts from all furnaces 

(combined) included in a proposed 

new Equation Q-11 in the proposed 

rule amendments, calculated as 

specified in new Equation Q-14. 

S Lime 

Manufacturing 

Annual quantity (metric tons) of 

lime product sold, by type. 

V Nitric Acid 

Production 

Annual percent N2O emission 

reduction for all production units 

combined. 

X Petrochemical 

Production 

If using the mass balance method or 

CEMS method to calculate GHG 

emissions: Name and annual quantity 

(in metric tons) of each carboncontaining feedstock. 

If using the mass balance method or 

CEMS method to calculate GHG 

emissions: Name and annual quantity 

(in metric tons) of each carboncontaining co-product. 
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Subpart Subpart Name New Data Element Description 

Y Petroleum 

Refineries 

Annual quantity of flare gas 

combusted (in MMscf per year) (only 

when using Equation Y-3). 

Annual average molecular weight of 

flare gas combusted (in mmBtu per 

MMscf) (only when using Equation Y3). 

Annual average carbon content of 

flare gas combusted (expressed as a 

decimal fraction)(only when using 

Equation Y-3). 

AA Pulp and Paper 

Manufacturing 

For each pulp mill lime kiln: 

Quantity of calcium oxide (CaO) 

produced (metric tons). 

For each pulp mill lime kiln: 

Percent of annual heat input, 

individually for each fossil fuel 

type. 

For each chemical recovery furnace 

and chemical recovery combustion 

unit for which you are not using 

Equation C-2c to calculate CO2

emissions: Annual mass of steam 

generated (lb steam), individually 

for each fossil fuel type and for 

spent liquor solids. 

For each chemical recovery furnace 

and chemical recovery combustion 

unit for which you are not using 

Equation C-2c to calculate CO2

emissions: Ratio of the unit’s 

maximum rated heat input capacity to 

its design rated steam output 

capacity (mmBtu/lb steam), 

individually for each fossil fuel 

type and for spent liquor solids. 

III. Rationale for Proposed Changes to Reporting and 

Recordkeeping Requirements 

Based on the four-step evaluation described in Section I.B 

of this preamble, in particular the disclosure concerns 
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discussed in “Step 2” of the evaluation and the alternatives 

considered in “Step 3” and “Step 4” of the evaluation to address 

those disclosure concerns, the EPA is proposing an alternative 

verification approach. This approach involves use of an inputs 

verification tool and revisions to the reporting and 

recordkeeping requirements of Part 98. The EPA’s rationale for 

this approach is presented in Sections III.A through C below. 

Section III.A addresses the proposed inputs verification tool 

and revisions to the requirement to report certain “inputs to 

equations” data elements. Section III.B addresses the proposed 

revisions to recordkeeping requirements. Section III.C addresses 

the proposed addition of new reporting requirements. 

A. Proposed Inputs Verification Tool and Amendment to Reporting 

Requirements

The EPA is proposing that facilities using “inputs to 

equations” data elements to calculate reported GHGs under the 

subparts listed in Table 2 of this preamble use an EPA-provided 

electronic inputs verification tool, which would calculate and 

verify GHG emissions. The inputs verification tool would be 

deployed within e-GGRT and integrated without interrupting the 

current electronic reporting process. Reporters would enter 

their “inputs to equations” data elements into the tool within 

the e-GGRT system along with the data required to be reported in 

the annual report (concurrent entry of “inputs to equations” 
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data elements and data required for the annual report would be 

required starting in reporting year 2014, as further discussed 

in Section III.A.2 of this preamble). As a built-in feature of 

the e-GGRT system, the tool would use the entered “inputs to 

equations” data elements to calculate the equation outputs, 

conduct electronic verification checks on the “inputs to 

equations” data elements, and generate a verification summary. 

The tool would not retain the entered “inputs to equations” data 

elements for which the EPA is proposing that the reporting 

requirement be removed.4

 Accordingly, unlike data currently 

reported to the EPA through e-GGRT, the EPA would not have 

access to these “inputs to equations” data elements. 

Any such sources subject to multiple subparts under Part 98 

would be required to use the tool for only those subparts listed 

in Table 2 of this preamble, as discussed in the following 

section. 

1. Detailed Description of Inputs Verification Tool.

The EPA’s current verification approach consists of 

electronic verification checks followed by direct follow-up with 

facilities. For subparts where the reporting of inputs to 

emission equations has been deferred until 2015, these checks 

have been conducted using reported data other than inputs to 

 

4

 Please see section III.A.3 of this preamble for a discussion on which 

“inputs to equations” data elements the EPA is proposing that the reporting 

requirements be removed. 
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emission equations (the reporting of which was deferred). For 

“supplier” subparts5

 (and starting in reporting year 2012 for 

subparts with inputs to emission equations that were deferred 

until 2013), these checks have been conducted using reported 

data that include the data needed to calculate outputs of the 

equations. Reporters under the supplier subparts have been 

entering into e-GGRT the data needed to calculate the annual GHG 

quantities. For reporters under the direct emitter subparts 

listed in Table 2 of this preamble that are using “inputs to 

equations” data elements to calculate reported GHGs, the EPA is 

proposing to use an approach similar to that currently used for 

the supplier subparts, where “inputs to equations” data elements 

would be entered into the inputs verification tool within e-GGRT 

and used to calculate the annual GHG emission values and verify 

these emission values. The difference, however, is that these 

“inputs to equations” data elements would be entered into this 

new inputs verification tool within e-GGRT and would not be 

reported to the EPA. 

To access the inputs verification tool, reporters would log 

into e-GGRT. They would enter data elements required for the 

annual report as well as their “inputs to equations” data 

 

5

 Supplier subparts (subparts LL through PP of Part 98) apply to fossil fuel 

suppliers and industrial gas suppliers. The e-GGRT system currently calculates 

equation outputs for suppliers using reported equations inputs. Subpart MM 

reporters began using e-GGRT for reporting in Reporting Year 2012. 
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elements. The tool would operate securely within e-GGRT, as a 

transient process, which means that “inputs to equations” data 

elements (for which the EPA is proposing that the reporting 

requirement be removed) entered into the tool would be 

temporarily saved in the tool while the reporter is actively 

using the tool, but would not be persisted (i.e., saved) within 

the e-GGRT database. The “inputs to equations” data elements 

would be discarded when the user’s session with e-GGRT ends. 

Refer to the memorandum “Technical Approach and Design for 

Inputs Verification Tool” (refer to Docket ID No. EPA–HQ–OAR–

2010-0929) for a detailed description of EPA’s technical 

approach and design for the inputs verification tool. The 

memorandum describes how the inputs verification tool would use 

entered data only during the reporters’ e-GGRT session and would 

delete all records of entered data when the reporters exits the 

system. 

If the reporter exits the inputs verification tool prior to 

completing data entry or submitting their annual report, the 

tool would generate a file of entered “inputs to equations” data 

elements, and allow the reporter to download the file. This file 

could then be uploaded into the tool when the reporter next uses 

the tool to continue with data entry for the same reporting 

year. This would avoid facilities from needing to re-enter 
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“inputs to equations” data elements that were entered in 

previous e-GGRT sessions. 

After the reporter enters the “inputs to equations” data 

elements into the inputs verification tool, the tool would 

calculate the annual GHG emissions values. The tool would use 

the following information in calculating these values: (1) 

“inputs to equations” data elements (for which reporting under 

this action is proposed to be removed) entered into the tool, 

(2) “inputs to equations” data elements entered into e-GGRT (not 

into the inputs verification tool) (refer to Section III.A.3 of 

this preamble for a discussion of the “inputs to equations” data 

elements that would still be reported under this proposal), (3) 

information entered into e-GGRT identifying which Part 98 

calculation method was selected (if applicable), and (4) the 

selected Part 98 calculation method. Once the annual GHG 

emissions values are calculated, the values would be pre-filled 

into the appropriate reporting fields within e-GGRT. Reporters 

would then have the opportunity to override the annual GHG 

emissions values calculated by the tool with their own 

calculated value. If the reporter chose to override the 

calculated value, this would be reflected in the verification 

summary. 
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Prior to annual report submittal, the inputs verification 

tool would conduct a series of verification checks, including 

the following: 

 Verification checks on the annual GHG emission values 

calculated by the inputs verification tool. As mentioned 

above, reporters would have the opportunity to override and 

revise the value calculated by the tool; however should 

this occur, the tool would note a discrepancy, which would 

prompt the EPA for further review after the reporter 

submits the annual report. 

 Verification checks on entered “inputs to equations” data 

elements. For example, the tool would check: (1) whether 

all required data were entered; (2) whether entered “inputs 

to equations” data element values are within the expected 

ranges for the data elements; and (3) whether expected 

relationships exist between certain “inputs to equations” 

data elements and certain other reported data elements 

(e.g., process raw material or throughput data that are not 

“inputs to equations” data elements). 

Some of these checks would be conducted as the reporter 

enters “inputs to equations” data elements (i.e., using “realtime” checking), and other checks would be conducted after the 

reporter has entered all “inputs to equations” data elements, 

because some algorithms may compare certain “inputs to 

equations” data elements (e.g., production quantity) to GHG 

emission values at the subpart or facility level. 

Also, prior to submittal of the annual report, the inputs 

verification tool would generate a verification summary 

containing the results of the verification checks. The 

verification summary would specify whether any potential errors, 

as described above, were identified, without specifying the 
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“inputs to equations” data elements. The reporter would have an 

opportunity to review the verification summary and make 

necessary revisions to the entered “inputs to equations” data 

elements and the reported data elements. 

For example, a facility subject to subpart G that 

manufactures ammonia using liquid and solid feedstocks is 

currently required under 40 CFR 98.76(b)(1) to report annual CO2

process emissions for each ammonia manufacturing unit. 

Currently, the reporter calculates this reported annual GHG 

emissions value outside of e-GGRT (e.g., using a calculator or 

computer software), using Equations G-2, G-3, and G-4 of Part 

98, and monthly values for the following “inputs to equations” 

data elements: quantity of liquid feedstock, quantity of solid 

feedstock, carbon content value for liquid feedstock, and carbon 

content value for solid feedstock. We are proposing that the 

reporter instead calculate this reported annual GHG emissions 

value using the inputs verification tool, which not only would 

use the same equations and data for calculation, but would also 

conduct verification checks, as follows: 

 The reporter would enter all 48 “inputs to equations” data 

elements” into the inputs verification tool (i.e., monthly 

values for all four “inputs to equations” data elements). 

 The reporter would use the inputs verification tool to 

calculate annual CO2 process emissions. In calculating this 

value, the tool would use Equations G-2, G-3, and G-4 of 

Part 98 and the 48 “inputs to equations” data element 

entries. 
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 Once the annual CO2 process emissions value is calculated, 

the inputs verification tool would automatically conduct 

verification checks on the 48 entered “inputs to equations” 

data elements. For example, the tool might conduct the 

following checks: 

 Real-time checks that all 48 “inputs to equations” data 

elements were entered. 

 Real-time checks that each of the 12 entered values for 

carbon content of liquid feedstock is within the expected 

range for carbon content of liquid feedstock (based on 

industry-wide data). The tool would conduct similar 

comparisons for the 12 entered “inputs to equations” data 

elements for the carbon content value for solid feedstock. 

 Run an algorithm check comparing each of the 12 entered 

values of the quantity of the liquid feedstock to all 

monthly values entered for the year, to determine if 

individual values are within an expected range established 

using all 12 values. The tool would conduct similar 

comparisons for the 12 entered “inputs to equations” data 

elements for the quantity of solid feedstock. This type of 

check would be conducted after the reporter has entered all 

“inputs to equations” data elements. 

 Prior to annual report submittal, the inputs verification 

tool would automatically generate a verification summary, 

which would flag any potential errors, providing an 

opportunity for the reporter to review the verification 

summary and revise entered data. The verification summary 

would note if the reporter has overridden any of the annual 

GHG emissions values calculated by the tool. After the 

reporter completes all revisions to data entries, the tool 

would automatically re-generate the verification summary 

prior to annual report submittal. The EPA would access the 

verification summary (i.e., the same final summary viewed 

by the reporter) following annual report submittal and 

certification. 

 The inputs verification tool would also generate a file 

listing the entered “inputs to equations” data elements 

(for which the EPA is proposing to remove the reporting 

requirements) to be kept by the reporter and maintained as 

a record in a format currently allowed under Part 98 (see 

40 CFR 98.3(g), subpart A). Refer to Section III.B of this 

preamble for further discussion of this proposed amendment 

and the EPA’s rationale for requiring this record. 
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The EPA has developed a “pilot” inputs verification tool 

for one subpart, subpart C, which will be posted at 

http://www.epa.gov/ghgreporting/reporters/training/rulepilot.htm

l, to demonstrate how the tool would work within e-GGRT, as well 

as the types of verification checks that would be conducted. The 

EPA seeks comment on the usability of the tool as well as its 

ability to conduct verification on the “inputs to equations” 

data elements. 

2. Rationale Supporting the Use of the Inputs Verification Tool 

as an Alternative to Collecting Certain “Inputs to Equations” 

Data Elements for Verification Purposes.

In the October 30, 2009 final rule (74 FR 56282 – 56283), 

the EPA described its verification approach as the following 

two-step process: 

 Initial automated review of reported data, using an 

electronic data quality assurance program built into the 

data system, for use by reporters and the EPA to help 

assure the completeness and accuracy of data. 

 Based on the initial review results, follow up with 

facilities regarding potential errors, discrepancies, or 

questions, including on-site audits. 

The EPA is currently using the two-step verification 

process of automated verification checks followed by direct 

follow-up with facilities to verify data currently reported via 

e-GGRT. The EPA is proposing to supplement the current 

verification approach for facilities reporting under the 
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subparts listed in Table 2 of this preamble using the additional 

checks that would be conducted by the inputs verification tool. 

During the first 3 years of the Greenhouse Gas Reporting Program 

(GHGRP), the EPA has had success developing and using an 

electronic reporting and verification system for all subparts 

reporting under the program. During reporting year 2010, the EPA 

developed approximately 1,400 electronic verification checks to 

verify reported data. Based on these verification checks, the 

EPA followed up with approximately 2,360 of the approximately 

6,700 facilities that reported in reporting year 2010, resulting 

in approximately 2,300 facilities resolving verification issues 

by responding to the EPA and/or resubmitting their annual 

report. In reporting year 2011, the EPA programmed an additional 

1,000 checks into e-GGRT for the subparts that were reporting 

for the second year, expanding the number of checks to 2,400. 

The EPA also programmed into e-GGRT, for 2011, approximately 

1,300 checks for the newly-reporting subparts. During reporting 

year 2011, the EPA followed up with approximately 3,440 of the 

approximately 8,000 facilities that reported, resulting in 

approximately 3,000 facilities resolving their verification 

issues. 

For example, for subpart H, the EPA verifies reported GHG 

emissions data using: (1) reported cement production data and 

(2) publicly available industry data on GHG emissions. Using 
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these data, the EPA has established ranges of acceptable 

production and emission values and set up algorithm checks for 

reported GHG emission values. 

The electronic checks used by the GHGRP have served as a 

means for the EPA to verify reported data while minimizing the 

burden on both the EPA and reporters. Electronic verification is 

a critical first step to ensuring the completeness and accuracy 

of reported data and reducing the costs of compliance 

monitoring. 

The inputs verification tool described in Section III.A.1 

of this preamble utilizes the same approach that the EPA 

currently uses for calculating and verifying data submitted for 

supplier subparts (and starting in reporting year 2012, inputs 

to emission equations whose reporting deadline was deferred 

until 2013), except that e-GGRT would not retain the “inputs to 

equations” data elements entered into the tool. Once the annual 

report is submitted, the EPA would review the verification 

summary generated by the inputs verification tool, along with 

verification summaries that are currently generated using data 

currently collected through the annual report. By requiring use 

of the inputs verification tool, the EPA would have the 

additional certainty that reported annual GHG emissions values 

either were calculated correctly (because the values calculated 

by the tool were submitted to the EPA) or that the EPA would be 
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made aware that there were discrepancies between values 

calculated by the tool and values submitted to the EPA. That 

additional certainty, combined with the additional information 

provided by the range and algorithm checks on the “inputs to 

equations” data elements themselves, would provide the EPA with 

information necessary to conduct further verification once the 

annual report is submitted. 

If a potential error with one of the “inputs to equations” 

data elements or with an annual GHG emissions value were 

identified in the verification summary generated by the inputs 

verification tool, the EPA would likely follow up with the 

facility to determine whether an actual error has occurred. 

While this verification approach may result in more direct 

follow-up with facilities than if the “inputs to equations” data 

elements were submitted to the EPA, this approach would 

facilitate verification by identifying potential errors and 

minimizing the number of errors before annual reports are 

submitted. In addition, as discussed elsewhere in the preamble, 

the EPA is retaining the reporting requirement for “inputs to 

equations” data elements for which our four-step evaluation did 

not identify disclosure concerns and is proposing to require 

reporting of additional new data elements to assist the EPA’s 

verification effort. These “inputs to equations” data elements 

for which reporting would be retained and these proposed new 
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reported data elements would allow the EPA to conduct additional 

verification and minimize the number of follow-ups with 

facilities. Lastly, for the reasons specified in section III.B 

of this preamble, the EPA is proposing that facilities retain 

records for 5 years, which would allow the EPA time to perform 

any necessary follow-up with reporters. For the reasons stated 

above, the EPA has determined that the proposed verification 

approach would be adequate to verify the reported emissions for 

reporters using “inputs to equations” data elements to calculate 

reported GHGs under the subparts identified in Table 2 of this 

preamble and is a reasonable alternative to collecting “inputs 

to equations” data elements for which we have identified 

disclosure concerns. 

The EPA is proposing to require the use of the inputs 

verification tool starting in reporting year 2014. The inputs 

verification tool is designed to be used concurrently with 

annual reporting by facilities. By the time the EPA takes any 

final action on this proposed amendment, reporters would have 

likely submitted annual reports for reporting years 2010 through 

2013. While additional verification could be conducted on the 

past years’ data if the inputs verification tool were used for 

these years, given that most of the data would likely already 

have been published and that the use of best available 

monitoring methods (BAMM) for these sectors is relatively low 
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during these years, the EPA has determined that the added 

benefit does not outweigh the burden that would be required for 

facilities to use the inputs verification tool for years prior 

to reporting year 2014. 

3. Reporting of 435 “Inputs to Equations” Data Elements Would 

Not Be Necessary With the Proposed Verification Approach.

The EPA is proposing to remove the reporting requirement 

for 435 “inputs to equations” data elements that are in the 

subparts listed in Table 2 of this preamble. With the proposed 

alternative verification approach described in Section III.A.2 

of this preamble, the EPA would no longer need to rely on the 

collection of these “inputs to equations” data elements to 

verify emissions under those subparts. Not having these data 

elements reported would address concerns relative to potential 

disclosure of these data elements.6

 These 435 data elements are 

specified in Table 1 of the memorandum “List of Inputs to 

Equations Data Elements Proposed Not To Be Reported” (refer to 

Docket ID No. EPA–HQ–OAR–2010-0929). 

The 435 “inputs to equations” data elements for which the 

EPA is proposing to remove the reporting requirement must be 

maintained on-site as records. Because Part 98 already requires 

 

6

we are proposing to remove the reporting requirement because we determined 

that these data elements would not be useful for data verification and would 

not inform future GHG policy development in the absence of other data 

elements for which we are proposing to remove the reporting requirement.
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these “inputs to equations” data elements to be kept as records 

(see 98.3(g)(2), which states that “the data used to calculate 

the GHG emissions for each unit, operation, process, and 

activity, categorized by fuel or material type” must be kept as 

records), the EPA is not proposing in this action to specify 

each of the 435 “inputs to equations” data elements in the 

recordkeeping section of each subpart. The EPA considered 

whether specifying each of these “inputs to equations” data 

elements in the recordkeeping sections of each subpart would 

improve the clarity of the specific records that would be 

required to be retained. Because the EPA is proposing that the 

“inputs to equations” data elements that would not be reported 

must be kept as records in the format generated by the inputs 

verification tool (i.e., file for downloading or printing), the 

EPA determined that the data that must be kept as records would 

be sufficiently clear. The EPA seeks comment on whether 

additional specificity within the recordkeeping requirements of 

each subpart would improve the clarity of the specific records 

that are required to be retained. 

For the purposes of clarifying which data elements must be 

reported for previous reporting years 2010 through 2013, we are 

proposing to revise Table A-7 of Part 98 to remove all 435 data 

elements for which reporting is proposed to be removed. To be 

consistent with a separate action that is proposing to remove 
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additional “inputs to equations” data elements from Part 98 (40 

CFR 98.256(o)(6) and (o)(7))), we are also proposing to remove 

these additional data elements from Table A-7. For the EPA’s 

rationale for removing these additional data elements from Part 

98, refer to the preamble to the April 2, 2013 proposal, “2013 

Revisions to the Greenhouse Gas Reporting Rule and Proposed 

Confidentiality Determinations for New or Substantially Revised 

Data Elements,” (78 FR 19802, April 2, 2013). 

The EPA is retaining reporting of 175 “inputs to equations” 

data elements.7 Refer to Table 2 in the memorandum “List of 

‘Inputs to Equations’ Data Elements Proposed Not To Be Reported” 

(refer to Docket ID No. EPA–HQ–OAR–2010-0929) for a complete 

list of these 175 data elements. The 175 “inputs to equations” 

data elements include certain “inputs to equations” data 

elements for the subparts listed in Table 3 of this preamble, as 

well as all “inputs to equations” data elements for subparts C 

(only for certain combustion units connected to a device that 

delivers power to the local or regional electric power grid)8

, W, 

 

7

 These 175 “inputs to equations” data elements include: (1) nine “inputs to 

equations” data elements in subpart L of part 98 that are not being addressed 

in this rulemaking because they will be addressed in a separate action 

related to subpart L; and (2) five “inputs to equations” data elements in 

subpart Y of part 98 that are not being addressed in this rulemaking because 

they are being addressed in a separate action. Refer to the EPA’s April 2, 

2013 rulemaking (78 FR 19802) for EPA’s proposal that these five inputs be 

removed from reporting. 

8

 Refers to combustion units subject to subpart C meeting the following 

criteria: (1) the combustion unit is connected to a device that has been 

granted access by the Public Utilities Commission to deliver power to the 

local or regional electric power grid (e.g., electricity generators excluding 
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Page 49 of 128 

and II of part 98. For these “inputs to equations” data 

elements, the EPA is not amending these reporting requirements 

and would therefore let the deferral of these data elements 

expire on March 31, 2015. As a result, these “inputs to 

equations” data elements would be reported for future reporting 

years starting with reporting year 2014, as well as for previous 

reporting years (i.e., reporting years 2010 through 2013). Based 

on “Step 2” of our evaluation described in Section I.B of this 

preamble, these data elements would not raise disclosure 

concerns. Having these data elements reported would allow the 

EPA to do additional verification, including conduct year-toyear comparisons, thereby reducing the amount of direct followup required with facilities. For the reason stated above, 

collecting these data elements, even in the absence of 

collecting all “inputs to equations” data elements, would aid in 

the verification process. 

The EPA identified 23 “inputs to equations” data elements 

for which disclosure concerns were not identified based on “Step 

2” of our evaluation; however, the EPA is not retaining these 

reporting requirements. The EPA determined that these 23 data 

elements would not be useful for data verification and would not 

 

generators connected to combustion units subject to subpart D of this part); 

and (2) the combined nameplate capacity (for all such devices at the facility 

excluding generators connected to combustion units subject to subpart D of 

this part)) is greater than or equal to 1 megawatt electric. 
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inform future GHG policy development in the absence of other 

“inputs to equations” data elements for which the reporting 

requirement is proposed to be removed under this 

action. Examples of these 23 “inputs to equations” include 

reporting the selected default molar volume conversion factor 

and reporting the units of measure of a site-specific emission 

factor. These “inputs to equations” are identified in the 

memorandum “List of ‘Inputs to Equations’ Data Elements Proposed 

Not To Be Reported” (refer to Docket ID No. EPA–HQ–OAR–2010-

0929). 

Regarding the 175 retained “inputs to equations” data 

elements, for reporting year 2014 and thereafter, reporters 

would enter the 175 “inputs to equations” data elements for 

which we are retaining the reporting requirement into e-GGRT. 

Starting in reporting year 2014, the e-GGRT system would retain 

these 175 data elements as part of the annual report and they 

would be accessible by the EPA once the reporter submits the 

annual report. In order to ease the burden on facilities, for 

reporting years prior to reporting year 2014, the EPA is 

proposing that these reported “inputs to equations” data 

elements be submitted as part of the reporting year 2014 annual 

report. Specifically, when reporters prepare their reporting 

year 2014 annual report via e-GGRT, they would be required to 

include these “inputs to equations” data elements for reporting 
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Page 51 of 128 

year 2014 as well as for all applicable previous reporting 

years. The annual report, including these “inputs to equations” 

data elements would be submitted via e-GGRT. This approach would 

prevent facilities from being required to revise, re-certify, 

and re-submit annual reports for reporting years 2010, 2011, 

2012, and 2013. 

The proposed revisions to the current reporting 

requirements would apply to all reporters subject to the 

subparts listed in Table 2 of this preamble, including subpart 

C, and using “inputs to equations” data elements to calculate 

reported GHGs. However, as noted in Table 2, we are not 

proposing to amend the reporting requirements for combustion 

units subject to subpart C that meet the following criteria: (1) 

the combustion unit is connected to a device that has been 

granted access by the Public Utilities Commission to deliver 

power to the local or regional electric power grid (e.g., 

electricity generators excluding generators connected to 

combustion units subject to subpart D of this part); and (2) the 

combined nameplate capacity (for all such devices at the 

facility excluding generators connected to combustion units 

subject to subpart D of this part) is greater than or equal to 1 

megawatt electric. The “inputs to equations” data elements for 

these combustion units are among those that did not raise 

disclosure concerns under “Step 2” of our evaluation of the 
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“inputs to equations” data elements (refer to Section I.B of 

this preamble for a discussion of the EPA’s four-step 

evaluation). Refer to the memoranda documenting “Step 2” of our 

evaluation, “Evaluation of Competitive Harm From Reporting 2015 

Inputs to Equations” (Docket ID No. EPA–HQ–OAR–2010-0929), for 

further information on the results of the analysis for these 

combustion units. 

Reporters currently reporting emissions for combustion 

units under subpart C have the option to utilize one or more of 

the reporting options under subpart C that allow the grouping of 

stationary combustion units for the purpose of monitoring, 

calculating, and reporting emissions. The EPA recognizes that 

stationary combustion units grouped in these reporting 

configurations could include both combustion units associated 

with devices that can produce electricity (connected to the grid 

and not connected to the grid) and combustion units not 

associated with devices that can produce electricity. In these 

cases where combustion units are grouped, the EPA has determined 

that there would be no disclosure concerns with reporting of 

“inputs to equations” data elements for the grouped combustion 

units. In reporting combined data for multiple units including 

those associated with a device capable of producing electricity 

and subject to reporting under this proposed action, no unitspecific data would be revealed. Furthermore, should a facility 
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not wish to disclose aggregated data, it would have the option 

to calculate and report emissions using one of the individual 

unit reporting configurations. The EPA seeks comment on this 

conclusion. If you believe that there are any disclosure 

concerns, please provide detailed information about the concern, 

as well as whether reporting on an individual unit basis is a 

feasible reporting option. 

Additionally, the EPA is proposing to revise two paragraphs 

(40 CFR 98.116(e)(6) and 40 CFR 98.186(b)(8)) that reference 

other paragraphs that include “inputs to equations” data 

elements proposed to be removed from Part 98. As a result, we 

are proposing to remove the cross reference while carrying over 

the substantive information in order to maintain the 

requirements in these paragraphs. 

The EPA requests comment on the proposed inputs 

verification tool and verification approach, and the associated 

revision to the current reporting requirements as described in 

this section. 

B. Proposed Revisions to Recordkeeping Requirements

Given the proposed verification approach described in 

Section III.A of this preamble, the EPA considered whether the 

current record retention period and record format requirements 

would be sufficient to allow the EPA to perform data 

verification. We considered: 
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 The time we would need to follow up with reporters to 

further verify reported GHG emissions. 

 The desirability of retaining multiple years of data 

records to allow for appropriate assessment of compliance 

and for analyses of trends for policy analysis purposes. 

 The format of records, and whether the current format would 

be adequate for our verification process. For example, we 

considered whether records of “inputs to equations” data 

elements contained in multiple separate documents (as 

currently allowed under Part 98) would allow an EPA 

inspector to efficiently analyze the consistency of the 

data elements and use the data elements to perform 

calculations to confirm reported GHG emissions. 

Because there may be more direct follow-up activities under 

this alternative verification approach, we are proposing to 

extend the record retention period from 3 to 5 years. We have 

determined that 5 years is reasonable given the large number of 

reporters under the subparts identified in Table 2 of this 

preamble (over 2,000 facilities) and the likely increase in 

follow-up activities. It would be important that relevant 

records are available to the EPA for follow-up activities with 

facilities, including on-site audits if necessary, regarding 

potential errors, discrepancies, or questions. Should an EPA 

inspector visit a facility, it would be important to be able to 

examine not only the current year’s records but those from 

previous years as well, because previous years’ data would 

provide year-to-year comparisons, which are useful for verifying 

the current year’s data. A 5-year record retention period would 

ensure the availability of relevant records for the follow-up 
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activities described above. The EPA is proposing that this 5-

year record retention requirement begin with records for 

reporting year 2010, as discussed in Section III.A.1 of this 

preamble. 

For reporters subject to using the proposed inputs 

verification tool, the EPA is proposing to extend the record 

retention period not only for the subparts listed in Table 2 of 

the preamble, but also for other subparts that apply to 

reporters subject to a subpart in Table 2. Under this proposal, 

any such facility subject to both a subpart listed in Table 2 of 

this preamble and a subpart not listed in Table 2 would be 

required to maintain all records required under both subparts 

for a period of 5 years. For example, if a facility is required 

to use the proposed inputs verification tool under subpart C (in 

Table 2) and to report under subpart HH (not in Table 2), the 

facility would be required to maintain all records required 

under both subparts for 5 years. The EPA is proposing these 

provisions for two reasons. First, the EPA determined that 

during a site visit, if questions arise regarding the accuracy 

of an “inputs to equations” data element, it may be necessary to 

examine other non-input recordkeeping information, such as a 

monitoring plan or recordkeeping information in a different 

subpart, in order to fully investigate the accuracy of the data. 

It is necessary to ensure that all data necessary for 
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verification are available, and this proposed 5-year record 

retention period would provide better assurance of on-site data 

availability. Second, the EPA determined that maintaining 

multiple sets of data records according to different record 

retention periods could possibly cause confusion and result in 

recordkeeping errors. Providing the same record retention 

duration for all subparts, as proposed, would simplify 

recordkeeping and thereby minimize the chance for recordkeeping 

errors. 

In addition, the EPA is proposing revisions to the 

recordkeeping format for “inputs to equations” data elements. 

Currently, reporters have the option to maintain records of 

their “inputs to equations” data elements in one or more 

electronic or hard copy files. The proposed record format 

revision would require reporters to maintain an electronic or 

hard copy of the single file generated by the proposed inputs 

verification tool, listing all “inputs to equations” data 

elements entered into the tool. This proposed record format 

change would ensure that the EPA could readily access these 

data, enabling the EPA to quickly and efficiently perform 

calculations and data checks during site visits. All other 

records required under Part 98 would be maintained in the format 

currently required under Part 98. In combination with the 

proposed reporting requirements discussed in Sections III.A and 
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C of this preamble, these proposed recordkeeping requirements 

would allow the EPA to adequately verify certain reported 

emissions without implicating the disclosure concerns discussed 

in the memorandum “Evaluation of Competitive Harm For Reporting 

2015 Inputs to Equations” 

(refer to Docket ID No. EPA–HQ–OAR–2010-0929). 

In amending 40 CFR part 98, subpart A to add these 

recordkeeping requirements, we are also correcting an error in 

the current version of 40 CFR 98.3(g). In a previous action 

amending this paragraph (76 FR 73866, November 29, 2011), our 

intention was to amend the second sentence of the paragraph 

regarding record retention duration; however, the third sentence 

regarding record format was inadvertently amended. To correct 

this error, we are proposing to remove the second sentence of 40 

CFR 98.3(g) and to reinstate the previous third sentence of 40 

CFR 98.3(g) (regarding format of records). 

We seek comment on whether 5 years is the appropriate 

timeframe for maintaining records for facilities required to use 

the proposed inputs verification tool under a subpart listed in 

Table 2 of this preamble. In addition, we seek comment on the 

proposal to extend the record retention period for these 

reporters, not only for the subparts listed in Table 2 of the 

preamble, but also for other subparts that apply to these 

reporters. 
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C. Proposed Requirement to Report Additional Data

As part of our proposal to no longer require reporting of 

certain “inputs to equations” data elements, we are proposing to 

require that certain reporters using the proposed inputs 

verification tool also report the new data elements specified in 

Table 4 of this preamble. These additional data elements would 

allow the EPA to perform additional verification checks and 

minimize the number of follow-up activities. These data elements 

are quantities that provide information on the activity level at 

the facility, emission factors used, characteristics of carboncontaining streams, and other process information that would 

provide key information for verification, including confirming 

that emissions are appropriate for a given activity-level and 

estimating expected emissions based on data provided. These new 

data reporting elements would also enable the EPA to better 

understand the following aspects concerning reporters in order 

to inform future GHG policy:9

 (1) the GHG emission profile for 

the reporter; (2) the relationship of GHG emissions to 

production output or raw material input within the industry 

sector; and (3) the factors influencing GHG emissions. 

The EPA is proposing to add six new equations (Equations Q9 through Q-14 of part 98) to subpart Q to specify how to 

 

9

 The EPA has previously stated that a goal of collecting data under the GHGRP 

is to inform future GHG policy (refer to the April 10, 2009 proposed rule (74 

FR 16455). 
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calculate and report each of the six new data elements proposed 

to be added to subpart Q of part 98. Table 4 of this preamble 

specifies which equation number correlates with each new 

proposed data element. Refer to the proposed amendments for 

subpart Q for the proposed equations. 

The EPA is proposing confidentiality determinations for 

these proposed new data elements. Those new data elements 

determined to be confidential business information in a final 

rule would be afforded confidential treatment. Refer to the 

following Section IV of this preamble for the EPA’s proposed 

confidentiality determinations for the proposed new data 

elements. 

IV. Confidentiality Determination for Proposed New Data Elements 

to be Reported 

The EPA is proposing confidentiality determinations for 

each new data element listed in Table 4 of this preamble. To 

make these determinations, the EPA proposes to use the same 

approach that the EPA previously used for the 2011 final CBI 

rule (76 FR 30782, May 26, 2011). Specifically, the EPA is 

proposing to assign each new data element listed in Table 4 of 

this preamble to one of 11 direct emitter data categories, based 

on the type and characteristics of the data element. For a 

description of each data category and the type and 

characteristics of data elements assigned to each category, see 
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Sections II.C and II.D of the July 7, 2010 CBI proposal preamble 

(75 FR 39106 – 39130). 

Based on its evaluation of the new data elements, the EPA 

is proposing that each new data element be assigned to one of 

the four following direct emitter data categories: 

 Production/Throughput Data that are Not Inputs to Emission 

Equations. 

 Raw Materials Consumed that are Not Inputs to Emission 

Equations. 

 Unit/Process “Static” Characteristics that are Not Inputs 

to Emission Equations. 

 Unit/ Process Operating Characteristics that are Not Inputs 

to Emission Equations. 

In the 2011 final CBI rule (May 26, 2011, 76 FR 30782), the 

EPA made categorical determinations that all data elements 

assigned to the “Production/Throughput Data that are Not Inputs 

to Emission Equations” and “Raw Materials Consumed that are Not 

Inputs to Emission Equations” data categories are entitled to 

confidential treatment because the data do not meet the 

definition of “emission data” in 40 CFR 2.301(a)(2)(i) and they 

are CBI. 

The EPA is proposing that seven new data elements be 

assigned to the “Production/Throughput Data that are Not Inputs 

to Emission Equations” data category and 10 new data elements be 

assigned to the “Raw Materials Consumed that are Not Inputs to 

Emission Equations” data category, as shown in Table 5 of this 
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preamble, thereby applying the categorical confidentiality 

determinations made for these categories in the 2011 final CBI 

rule (i.e., they are CBI) to the proposed new reporting elements 

assigned to these categories. This proposal is not changing, nor 

soliciting comment on, the categorical confidentiality 

determination for these two data categories. Should the EPA 

finalize the category assignment for these data elements, all 

new data elements assigned to these categories would be 

considered to be entitled to confidential treatment. 

Table 5. Data Elements Proposed to Be Assigned To the 

“Production/Throughput Data that are Not Inputs to Emission 

Equations” and “Raw Materials Consumed that are Not Inputs to 

Emission Equations” Data Categories 

Subpart Proposed Citation Data Element 

“Production/Throughput Data that are Not Inputs to Emission 

Equations” Data Category 

G - Ammonia 

Production 

40 CFR 98.76(c)(14) Annual ammonia 

production (metric 

tons). 

40 CFR 98.76(d)(15) Annual methanol 

production (metric 

tons), if this 

quantity is not 

reported under 

subpart X of Part 98. 

H - Cement Kilns 40 CFR 98.86(b)(16) Annual clinker 

production (metric 

tons). 

P – Hydrogen 

Production 

40 CFR 98.166(e) Annual methanol 

production (metric 

tons), if this 

quantity is not 

reported under 

subpart X of Part 98. 

S - Lime 

Manufacturing 

40 CFR 98.196(b)(18) Annual quantity 

(metric tons) of lime 

product sold, by 
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Subpart Proposed Citation Data Element 

type. 

X – Petrochemical 40 CFR 98.246(a)(13) 

and (b)(10) 

If using the mass 

balance method or 

CEMS method to 

calculate GHG 

emissions: Name and 

annual quantity (in 

metric tons) of each 

carbon-containing coproduct. 

AA - Pulp and 

Paper 

40 CFR 98.276(l)(1) For each pulp mill 

lime kiln: 

Quantity of calcium 

oxide (CaO) produced 

(metric tons). 

“Raw Materials Consumed that are Not Inputs to Emission 

Equations” Data Category 

E - Adipic Acid 

Production 

40 CFR 98.56(m) Annual quantity of 

cyclohexane fed to 

all production lines, 

combined (metric 

tons). 

P - Hydrogen 

Production 

40 CFR 98.166(b)(7) Name and annual 

quantity (metric 

tons) of each carboncontaining fuel and 

feedstock. 

Q - Iron and Steel 40 CFR 98.176(i)(1) If you use the carbon 

mass balance method 

in 40 CFR 

98.173(b)(1) to 

determine CO2

emissions: The annual 

mass (metric tons) of 

all gaseous, liquid, 

and solid fuels 

(combined) used in 

process units 

specified in 

Equations Q-1 through 

Q-7, calculated as 

specified in a new 

Equation Q-9 in the 

proposed rule 

amendments. Do not 
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Subpart Proposed Citation Data Element 

include fuel used in 

a stationary 

combustion unit where 

emissions are 

reported under 

subpart C of this 

part. 

40 CFR 98.176(i)(2) If you use the carbon 

mass balance method 

in 40 CFR 

98.173(b)(1) to 

determine CO2

emissions: The annual 

mass (metric tons) of 

all non-fuel material 

inputs (combined) 

specified in 

Equations Q-1 through 

Q-7, calculated as 

specified in a new 

Equation Q-10 in the 

proposed rule 

amendments. 

40 CFR 98.176(i)(3) If you use the carbon 

mass balance method 

in 40 CFR 

98.173(b)(1) to 

determine CO2

emissions: The annual 

mass (metric tons) of 

all solid and liquid 

products and 

byproducts (combined) 

specified in 

Equations Q-1 through 

Q-7, calculated as 

specified in a new 

Equation Q-11 in the 

proposed rule 

amendments. 

40 CFR 98.176(i)(4) If you use the carbon 

mass balance method 

in 40 CFR 

98.173(b)(1) to 

determine CO2

emissions: The 
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Subpart Proposed Citation Data Element 

weighted average 

carbon content of all 

gaseous, liquid, and 

solid fuels 

(combined) included 

in Equation Q-9, 

calculated as 

specified in a new 

Equation Q-12 in the 

proposed rule 

amendments. 

40 CFR 98.176(i)(5) If you use the carbon 

mass balance method 

in 40 CFR 

98.173(b)(1) to 

determine CO2

emissions: The 

weighted average 

carbon content of all 

non-fuel inputs to 

all furnaces 

(combined) included 

in Equation Q-10, 

calculated as 

specified in a new 

Equation Q-13 in the 

proposed rule 

amendments. 

40 CFR 98.176(i)(6) If you use the carbon 

mass balance method 

in 40 CFR 

98.173(b)(1) to 

determine CO2

emissions: The 

weighted average 

carbon content of all 

solid and liquid 

products and 

byproducts from all 

furnaces (combined) 

included in a new 

Equation Q-11 in the 

proposed rule 

amendments, 

calculated as 

specified in new 
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Subpart Proposed Citation Data Element 

Equation Q-14 in the 

proposed rule 

amendments. 

X – Petrochemical 40 CFR 98.246(a)(12) 

and (b)(9) 

If using the mass 

balance method or 

CEMS method to 

calculate GHG 

emissions: Name and 

annual quantity (in 

metric tons) of each 

carbon-containing 

feedstock. 

AA - Pulp and 

Paper 

40 CFR 98.276(m)(1) For each chemical 

recovery furnace and 

chemical recovery 

combustion unit for 

which you are not 

using Equation C-2c 

to calculate CO2

emissions: Annual 

mass of steam 

generated (lb steam), 

individually for each 

fossil fuel type and 

for spent liquor 

solids. 

The EPA is proposing to assign eight proposed new data 

elements to the “Unit Process Operating Characteristics that are 

Not Inputs to Emission Equations” category and one proposed new 

data element to the “Unit/Process Static Characteristics that 

are Not Inputs to Emission Equations” category. In the 2011 

final CBI rule, the EPA determined that the data elements in 

these categories are not “emission data” (as defined at 40 CFR 

2.301(a)(2)(i)). However, instead of categorical determinations, 

the EPA made confidentiality determinations for individual data 

elements assigned to these two categories. In proposing these 
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determinations, the EPA considered the confidentiality criteria 

at 40 CFR 2.208, in particular whether release of the data is 

likely to cause substantial harm to the business’s competitive 

position. See 40 CFR 2.208(e)(1). The EPA is therefore following 

the same approach in this action for the proposed new reporting 

elements assigned to these two categories. 

Table 6 of this preamble lists the data elements the EPA 

proposes to assign to these two data categories and presents the 

EPA’s rationale for proposing to determine that each does or 

does not qualify as CBI under CAA section 114(c). 

Table 6. Proposed Confidentiality Determinations for Proposed 

New Data Elements Assigned to the “Unit/Process Operating 

Characteristics That Are Not Inputs to Emission Equations” and 

“Unit/Process ‘Static’ Characteristics that Are Not Inputs to 

Emission Equations” Data Categories 

Subpart Citation 

Data 

Element 

Confidentia

lity 

Determinati

on 

Proposed Rationale for 

Confidentiality 

Determination 

“Unit/Process Operating Characteristics That Are Not Inputs to 

Emission Equations” Data Category

E – 

Adipic 

Acid 

Producti

on 

40 CFR 

98.56(n) 

Annual 

percent 

N2O 

emission 

reduction 

for all 

productio

n units 

combined. 

Not CBI The annual facility 

percent N2O reduction 

could not be used to 

calculate adipic acid 

production. The level 

of N2O reductions 

varies by the type of 

abatement technology, 

the environment in 

which the abatement 

technology is 

operating, the age of 

the abatement 

technology, the age of 

the catalyst used, and 

the maintenance level 

of the abatement 
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Subpart Citation 

Data 

Element 

Confidentia

lity 

Determinati

on 

Proposed Rationale for 

Confidentiality 

Determination 

technology. 

H - 

Cement 

Kilns 

40 CFR 

98.86(b)(1

7) 

Annual 

average 

clinker 

CO2

emission 

factor 

for the 

facility, 

averaged 

across 

all kilns 

(metric 

tons 

CO2/metri

c ton 

clinker 

produced)

. 

CBI This data element could 

be used to back 

calculate a facility’s 

clinker production 

data, which would 

result in competitive 

disadvantage. 

40 CFR 

98.86(b)(1

8) 

Annual 

average 

cement 

kiln dust 

(CKD) CO2

emission 

factor 

for the 

facility, 

averaged 

across 

all kilns 

(metric 

tons 

CO2/metri

c ton CKD 

produced)

. 

CBI This data element could 

provide information 

about the efficiency of 

the operation, which 

would result in 

competitive 

disadvantage. 

V – 

Nitric 

Acid 

Producti

on 

40 CFR 

98.226(q) 

Annual 

percent 

N2O 

emission 

reduction 

for all 

productio

n units 

Not CBI The annual facility 

percent N2O reduction 

for all nitric acid 

production trains 

combined could not be 

used to calculate the 

nitric acid production 
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Subpart Citation 

Data 

Element 

Confidentia

lity 

Determinati

on 

Proposed Rationale for 

Confidentiality 

Determination 

combined. value for any 

individual facility. 

The level of N2O 

reductions for each 

individual facility 

varies by the type of 

abatement technology, 

the environment in 

which the abatement 

technology is 

operating, the age of 

the abatement 

technology, the age of 

the catalyst used, and 

the maintenance level 

of the abatement 

technology. 

Additionally, facilitylevel N2O emission 

reduction information 

is already publicly 

available (see docket 

number EPA-HQ-OAR-2010-

0750 and 

http://www.climateactio

nreserve.org). 

Y – 

Petroleu

m 

Refineri

es 

40 CFR 

98.256(e)(

11)(i) 

Annual 

quantity 

of flare 

gas 

combusted 

(in MMscf 

per year) 

(only 

when 

using 

Equation 

Y-3). 

Not CBI This data element does 

not reveal (nor could 

be used to calculate) 

details regarding 

product 

characteristics, actual 

production data, or 

operating efficiency. 

It does not provide 

information that would 

allow competitors to 

infer market share, 

production costs, or 

pricing structures and 

thus gain a competitive 

advantage. The EPA 

applied the same 

rationale in the 2010 

proposed and 2011 final 

CBI rules (75 FR 39113 

and 76 FR 30803 - 
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Page 69 of 128 

Subpart Citation 

Data 

Element 

Confidentia

lity 

Determinati

on 

Proposed Rationale for 

Confidentiality 

Determination 

30806), in support of a 

non-CBI determination 

for reporting of the 

following same data 

element currently 

required to be reported 

if a different equation 

(Equation Y-1a) is 

used: annual volume of 

flare gas combusted 

(scf/year) under 40 CFR 

98.256(e)(6). 

40 CFR 

98.256(e)(

11)(ii) 

Annual 

average 

molecular 

weight of 

flare gas 

combusted 

(in mmBtu 

per 

MMscf) 

(only 

when 

using 

Equation 

Y-3). 

Not CBI This data element does 

not reveal (nor could 

be used to calculate) 

details regarding 

product 

characteristics, actual 

production data, or 

operating efficiency. 

It does not provide 

information that would 

allow competitors to 

infer market share, 

production costs, or 

pricing structures and 

thus gain a competitive 

advantage. The EPA 

applied the same 

rationale in the 2010 

proposed and 2011 final 

CBI rules (75 FR 39113 

76 FR 30803 - 30806), 

in support of a non-CBI 

determination for 

reporting of the 

following same data 

element currently 

required to be reported 

if a different equation 

(Equation Y-1a) is 

used: annual average 

molecular weight of the 

flare gas (kg/kg-mole) 

under 40 CFR 

98.256(e)(6). 
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Subpart Citation 

Data 

Element 

Confidentia

lity 

Determinati

on 

Proposed Rationale for 

Confidentiality 

Determination 

40 CFR 

98.256(e)(

11)(iii) 

Annual 

average 

carbon 

content 

of flare 

gas 

combusted 

(expresse

d as a 

decimal 

fraction)

(only 

when 

using 

Equation 

Y-3). 

Not CBI This data element does 

not reveal (nor could 

be used to calculate) 

details regarding 

product 

characteristics, actual 

production data, or 

operating efficiency. 

It does not provide 

information that would 

allow competitors to 

infer market share, 

production costs, or 

pricing structures and 

thus gain a competitive 

advantage. The EPA 

applied the same 

rationale in the 2010 

proposed and 2011 final 

CBI rules (75 FR 39113 

76 FR 30803 - 30806), 

in support of a non-CBI 

determination for 

reporting of the 

following same data 

element currently 

required to be reported 

if a different equation 

(Equation Y-1a) is 

used: annual average 

carbon content of the 

flare gas (kg carbon/kg 

flare gas) under 40 CFR 

98.256(e)(6). 

AA - 

Pulp and 

Paper 

40 CFR 

98.276(l)(

2) 

For each 

pulp mill 

lime 

kiln: 

Percent 

of annual 

heat 

input, 

individua

lly for 

each 

fossil 

fuel 

Non-CBI Release of this data 

would not result in 

competitive harm 

because lime kiln 

fossil fuel use as a 

fraction of design heat 

input was reported to 

the EPA as part of a 

2011 ICR survey, and 

facilities reporting 

via the survey made no 

CBI claims regarding 

fuel type and percent 
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Subpart Citation 

Data 

Element 

Confidentia

lity 

Determinati

on 

Proposed Rationale for 

Confidentiality 

Determination 

type. of design heat input. 

“Unit/Process ‘Static’ Characteristics that Are Not Inputs to Emission 

Equations” Data Category 

AA - 

Pulp and 

Paper 

40 CFR 

98.276(m)(

2) 

For each 

chemical 

recovery 

furnace 

and 

chemical 

recovery 

combustio

n unit 

for which 

you are 

not using 

Equation 

C-2c to 

calculate 

CO2

emissions

: 

Ratio of 

the 

unit’s 

maximum 

rated 

heat 

input 

capacity 

to its 

design 

rated 

steam 

output 

capacity 

(mmBtu/lb 

steam), 

individua

lly for 

each 

fossil 

fuel type 

and for 

spent 

ND1

 In the final CBI 

rulemaking (76 FR 

30799, May 26, 2011), 

we determined that the 

best approach for 

determining 

confidentiality of 

production capacity is 

not to make a single 

CBI determination 

applicable to all 

facilities within a 

given source category, 

due to differences 

between facilities. For 

all reported data 

elements related to 

production capacity, 

the EPA will make caseby-case determinations 

per reporter, in 

accordance with the 

provisions in 40 CFR 

part 2, subpart B for 

facilities that claim 

these data elements as 

CBI. 
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Page 72 of 128 

Subpart Citation 

Data 

Element 

Confidentia

lity 

Determinati

on 

Proposed Rationale for 

Confidentiality 

Determination 

liquor 

solids. 

1

 ND = No determination was made. 

The EPA is requesting comment on two aspects of these 

confidentiality determinations. First, the EPA seeks comment on 

the proposed data category assignment for each of these data 

elements in Tables 5 and 6. If you believe that the EPA has 

improperly assigned any proposed new data elements to one of the 

data categories, please provide specific comments identifying 

which proposed new data elements may be mis-assigned along with 

a detailed explanation of why you believe them to be incorrectly 

assigned and in which data category you believe they best 

belong. 

Second, for those data elements assigned to the two direct 

emitter data categories without categorical confidentiality 

determinations, the EPA seeks comment on the individual 

confidentiality determinations we are proposing for these data 

elements. If you comment on this issue, please provide specific 

comment along with detailed rationale and supporting information 

on whether such data element does or does not qualify as CBI. 

V. Impacts of the Proposed Rule 

This section examines the cost impacts of the proposed 

rulemaking. A detailed discussion of the impacts may be found in 
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Page 73 of 128 

the memorandum, ”Impacts Analysis of the Proposed 2015 Inputs 

Proposal,” available in EPA docket ID No. EPA–HQ–OAR–2010-0929. 

A. How were the costs of this proposed rule estimated?

1. Proposed Inputs Verification Tool.

The data elements required to be used for calculating the 

annual GHG emissions values and the cost associated with 

collecting these data, have not changed from the estimate made 

during the original rulemaking process. The time associated with 

entry of these “inputs to equations” data elements into e-GGRT 

(including into the new inputs verification tool) is expected to 

be equivalent to the time originally anticipated for data entry. 

Prior to the inputs verification tool, as currently required, 

reporters must use their own calculation tool (e.g., calculator, 

calculation software) to calculate the annual GHG emissions 

values, using the same sets of equations and entering the same 

data elements that they would enter into the tool. 

The EPA does recognize however that there may be some time 

associated with learning the new procedures for the inputs 

verification tool and we have estimated a cost of approximately 

$66 per facility, or $379,000 for the first year for all 

affected facilities. During their first session using the 

proposed inputs verification tool, reporters would need to spend 

approximately 1 hour becoming familiar with how the tool 

operates within e-GGRT. The proposed new requirement to use the 
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Page 74 of 128 

inputs verification tool would not result in any change in the 

respondent activity of entering these data into e-GGRT. Once the 

reporter has become familiar with the tool, EPA does not 

anticipate any additional burden. The cost includes technical, 

clerical, and managerial labor hours. For further information 

about this cost estimate, refer to the memorandum “Assessment of 

Cost Impacts of 2015 Inputs Proposal – Revisions to Reporting, 

Recordkeeping, and Verification Requirements under the 

Greenhouse Gas Reporting Program” and the supporting statement 

for this proposed information collection request, “Supporting 

Statement, Environmental Protection Agency: Revisions to 

Reporting and Recordkeeping Requirements, and Proposed 

Confidentiality Determinations under the Greenhouse Gas 

Reporting Program, OMB control number 2060-[INSERT NEW NUMBER], 

ICR number 2483.01,” both available in docket EPA–HQ–OAR–2010-

0929. 

2. Proposed New Data Elements.

We are proposing to add 26 new data elements that were not 

previously required to be reported under Part 98 (see Section 

II.D of this preamble for further discussion of this proposed 

amendment), to be reported by facilities in certain subparts 

that are required to use the proposed inputs verification tool. 

Of these 26 data elements, nine data elements are related to 

annual production or raw material usage, which are collected by 
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Page 75 of 128 

a facility as a routine part of conducting business. For these 

data elements, we are not proposing that reporters comply with 

specific data collection or monitoring requirements beyond the 

methods commonly used for accounting purposes. The other 17 data 

elements proposed to be reported are calculated values using 

data currently required to be collected to perform emissions 

calculations. For all of these additional data elements, the EPA 

has estimated a nominal additional cost to report the data 

element and fulfill the recordkeeping requirements. The total 

costs associated with reporting and recordkeeping for the 26 

data elements in 10 subparts is $80,000. These costs represent 

the cost for all affected facilities in the first year. 

B. Additional Impacts of the Proposed Amendments

The proposed confidentiality determinations for the new 

data elements would not affect whether and how data are reported 

and, therefore, would not impose any additional burden on 

sources. 

VI. Statutory and Executive Order Reviews 

A. Executive Order 12866: Regulatory Planning and Review and 

Executive Order 13563: Improving Regulation and Regulatory 

Review

Under Executive Order 12866 (58 FR 51735, October 4, 1993), 

this action is a “significant regulatory action” because this 

action raises novel legal or policy issues arising out of legal 
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Page 76 of 128 

mandates, the President’s priorities, or principles set forth in 

the executive order. Accordingly, the EPA submitted this action 

to the Office of Management and Budget (OMB) for review under 

Executive Orders 12866 and 13563 (76 FR 3821, January 21, 2011) 

and any changes made in response to OMB recommendations have 

been documented in the docket for this action. 

B. Paperwork Reduction Act

This action proposes to amend reporting and recordkeeping 

requirements and verification procedures for the GHGRP. In 

addition, the EPA is proposing confidentiality determinations 

for the proposed new data elements in this action. The proposed 

amendments to the reporting requirements in the source categoryspecific subparts are not anticipated to result in significant 

burden for reporters. The new data elements required to be 

reported are expected to be readily available for affected 

facilities, or easily calculated using data already required to 

be collected (e.g., a monthly value is currently reported and an 

annual value is proposed to be reported). 

Impacts associated with the proposed changes to the 

reporting requirements in each subpart are detailed in the 

memorandum “Impacts Analysis of the Proposed 2015 Inputs 

Proposal” (see Docket ID No. EPA-HQ-OAR-2010-0929). The Office 

of Management and Budget (OMB) has previously approved the 

information collection requirements for 40 CFR part 98 under the 
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Page 77 of 128 

provisions of the Paperwork Reduction Act, 44 U.S.C. 3501 et seq

and has assigned OMB control number 2060-0629, ICR 2300.10. OMB 

has approved the information collection requirements for this 

rulemaking and has assigned OMB control number 2060-new, ICR 

2483.01. The OMB control numbers for the EPA’s regulations in 40 

CFR are listed in 40 CFR part 9. 

C. Regulatory Flexibility Act (RFA)

The RFA generally requires an agency to prepare a 

regulatory flexibility analysis of any rule subject to notice 

and comment rulemaking requirements under the Administrative 

Procedure Act or any other statute unless the agency certifies 

that the rule will not have a significant economic impact on a 

substantial number of small entities. Small entities include 

small businesses, small organizations, and small governmental 

jurisdictions. 

For purposes of assessing the impacts of the proposed 

amendments on small entities, “small entity” is defined as: (1) 

A small business as defined by the Small Business 

Administration’s regulations at 13 CFR 121.201; (2) a small 

governmental jurisdiction that is a government of a city, 

county, town, school district or special district with a 

population of less than 50,000; or (3) a small organization that 

is any not-for-profit enterprise which is independently owned 

and operated and is not dominant in its field. This definition 
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Page 78 of 128 

of small entity is consistent with the definition of small 

entity used for Part 98. 

After considering the economic impacts of today’s proposed 

amendments on small entities, I certify that this action will 

not have a significant economic impact on a substantial number 

of small entities. The small entities subject to Part 98 include 

small businesses across all sectors of the economy encompassed 

by Part 98, small governmental jurisdictions, and small nonprofits. The impacts of these proposed amendments are expected 

to be roughly a first-year cost of $66 per facility for learning 

new procedures for the verification tool and an annual cost of 

$100 per facility for the recordkeeping and reporting of 26 new 

data elements. 

The EPA continues to be interested in the potential impacts 

of the proposed rule amendments on small entities and welcomes 

comments on issues related to such impacts. 

D. Unfunded Mandates Reform Act (UMRA)

The proposed amendments and confidentiality determinations 

do not contain a federal mandate that may result in expenditures 

of $100 million or more for State, local, and tribal 

governments, in the aggregate, or the private sector in any one 

year. Thus, the proposed amendments and confidentiality 

determinations are not subject to the requirements of sections 

202 or 205 of UMRA. 
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Page 79 of 128 

This rule is also not subject to the requirements of 

section 203 of UMRA because it contains no regulatory 

requirements that might significantly or uniquely affect small 

governments. This action proposes to amend reporting and 

recordkeeping requirements and verification procedures for the 

GHGRP. In addition, the EPA is proposing confidentiality 

determinations for the proposed new data elements in this 

action. Therefore, this action is not subject to the 

requirements of section 203 of the UMRA. 

E. Executive Order 13132: Federalism

The action does not have federalism implications. It will 

not have substantial direct effects on the states, on the 

relationship between the national government and the states, or 

on the distribution of power and responsibilities among the 

various levels of government, as specified in Executive Order 

13132. The proposed amendments and confidentiality 

determinations apply to facilities that directly emit 

greenhouses gases and fuel and chemicals suppliers. These 

proposed changes do not apply to governmental entities unless 

the government entity owns a facility that directly emits GHGs 

above threshold levels (such as a large stationary combustion 

device), so relatively few government facilities would be 

affected. Moreover, for government facilities that are subject 

to the rule, the proposed revisions will not have a significant 
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Page 80 of 128 

cost impact. This proposed action also does not limit the power 

of states or localities to collect GHG data and/or regulate GHG 

emissions. Thus, Executive Order 13132 does not apply to this 

rule. 

In the spirit of Executive Order 13132, and consistent with 

EPA policy to promote communications between the EPA and state 

and local governments, the EPA specifically solicits comments on 

this proposed action from state and local officials. 

F. Executive Order 13175: Consultation and Coordination with 

Indian Tribal Governments.

This proposed action does not have tribal implications, as 

specified in Executive Order 13175 (65 FR 67249, November 9, 

2000). The proposed amendments and confidentiality 

determinations apply directly to facilities that directly emit 

greenhouses gases or that are suppliers of GHGs. They would not 

have tribal implications unless the tribal entity owns a 

facility that directly emits GHGs above threshold levels (such 

as a landfill or large combustion device). Relatively few tribal 

facilities would be affected. Thus, Executive Order 13175 does 

not apply to this action. 

G. Executive Order 13045: Protection of Children from 

Environmental Health Risks and Safety Risks

The EPA interprets Executive Order 13045 (62 FR 19885, 

April 23, 1997) as applying only to those regulatory actions 
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Page 81 of 128 

that concern health or safety risks, such that the analysis 

required under section 5-501 of the Executive Order has the 

potential to influence the regulation. This proposed action is 

not subject to Executive Order 13045 because it does not 

establish an environmental standard intended to mitigate health 

or safety risks. 

H. Executive Order 13211: Actions that Significantly Affect 

Energy Supply, Distribution, or Use

This proposed action is not a “significant energy action” 

as defined in Executive Order 13211 (66 FR 28355, May 22, 2001), 

because it is not likely to have a significant adverse effect on 

the supply, distribution, or use of energy. Part 98 relates to 

monitoring, reporting, and recordkeeping and does not impact 

energy supply, distribution, or use. This action proposes to

amend reporting and recordkeeping requirements and verification 

procedures for the GHGRP. In addition, the EPA is proposing 

confidentiality determinations for the proposed new data 

elements in this action. These proposed amendments and 

confidentiality determinations do not make any changes to the 

existing monitoring, recordkeeping, or reporting requirements 

under Part 98 that affect the supply, distribution, or use of 

energy. 

I. National Technology Transfer and Advancement Act
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Section 12(d) of the National Technology Transfer and 

Advancement Act of 1995 (NTTAA), Public Law No. 104-113, 12(d) 

(15 U.S.C. 272 note) directs the EPA to use voluntary consensus 

standards in its regulatory activities unless to do so would be 

inconsistent with applicable law or otherwise impractical. 

Voluntary consensus standards are technical standards (e.g., 

materials specifications, test methods, sampling procedures, and 

business practices) that are developed or adopted by voluntary 

consensus standards bodies. NTTAA directs the EPA to provide 

Congress, through OMB, explanations when the Agency decides not 

to use available and applicable voluntary consensus standards. 

This proposed rulemaking does not involve the use of any 

new technical standards. Therefore, the EPA is not considering 

the use of any voluntary consensus standards. 

J. Executive Order 12898: Federal Actions to Address 

Environmental Justice in Minority Populations and Low-Income 

Populations

Executive Order 12898 (59 FR 7629, February 16, 1994) 

establishes federal executive policy on environmental justice. 

Its main provision directs federal agencies, to the greatest 

extent practicable and permitted by law, to make environmental 

justice part of their mission by identifying and addressing, as 

appropriate, disproportionately high and adverse human health or 

environmental effects of their programs, policies, and 
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Page 83 of 128 

activities on minority populations and low-income populations in 

the United States. 

The EPA has determined that these proposed rule amendments 

will not have disproportionately high and adverse human health 

or environmental effects on minority or low-income populations 

because the amendments do not affect the level of protection 

provided to human health or the environment. This is because the 

proposed amendments address information collection and reporting 

and verification procedures. 
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Proposed Rule Amendments and Confidentiality Determinations 

for Certain Data Elements Required under the 

Mandatory Greenhouse Gas Reporting Rule 

Page 84 of 128 

List of Subjects 40 CFR Part 98

Environmental protection, Administrative practice and 

procedure, Greenhouse gases, Reporting and recordkeeping 

requirements. 

Dated: 

 

Bob Perciasepe, 

Acting Administrator. 
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For the reasons stated in the preamble, title 40, chapter 

I, of the Code of Federal Regulations is proposed to be amended 

as follows: 

PART 98—[AMENDED] 

1. The authority citation for part 98 continues to read 

as follows: 

Authority: 42 U.S.C. 7401, et seq. 

Subpart A—[AMENDED] 

2. Section 98.3 is amended by revising paragraphs 

(c)(4)(vii), (d)(3)(v), (g) introductory text, and (g)(2)(i) to 

read as follows: 

§ 98.3 What are the general monitoring, reporting, recordkeeping 

and verification requirements of this part. 

* * * * * 

(c) * * * 

(4) * * * 

(vii) The owner or operator of a facility is not required 

to report the data elements specified in Table A-6 to this 

subpart for calendar years 2010 through 2011 until March 31, 

2013. The owner or operator of a facility is not required to 

report the data elements specified in Table A-7 to this subpart 

for calendar years 2010 through 2013 until March 31, 2015. Data 

elements specified in Table A-7 to this subpart for calendar 
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Page 86 of 128 

years 2010 through 2013 must be submitted as part of the annual 

report for reporting year 2014. 

* * * * * 

(d) * * * 

(3) * * * 

(v) For each combustion unit that is connected to a device 

that has been granted access by the Public Utilities Commission 

to deliver power to the local or regional power grid (e.g., 

electricity generators excluding generators connected to 

combustion units subject to subpart D of this part), and for 

which the combined nameplate capacity for all such devices at 

the facility is greater than or equal to 1 megawatt electric, 

report any facility operating data or process information used 

for the GHG emission calculations. 

* * * * * 

(g) Recordkeeping. An owner or operator that is required to 

report GHGs under this part must keep records as specified in 

this paragraph. Except as otherwise provided in this paragraph, 

retain all required records for at least 3 years from the date 

of submission of the annual GHG report for the reporting year in 

which the record was generated. The records shall be kept in an 

electronic or hard-copy format (as appropriate) and recorded in 

a form that is suitable for expeditious inspection and review. 
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If a reporter is required under § 98.5(b) to use software 

specified by the Administrator to enter data to calculate the 

reported GHGs, all records required under Part 98 must be 

retained by the reporter for 5 years from the date of submission 

of the annual GHG report for the reporting year in which the 

record was generated. Upon request by the Administrator, the 

records required under this section must be made available to 

EPA. Records may be retained off site if the records are readily 

available for expeditious inspection and review. For records 

that are electronically generated or maintained, the equipment 

or software necessary to read the records shall be made 

available, or, if requested by EPA, electronic records shall be 

converted to paper documents. You must retain the following 

records, in addition to those records prescribed in each 

applicable subpart of this part: 

* * * * * 

(2) * * * 

(i) The GHG emissions calculations and methods used. For 

data required by § 98.5(b) to be entered into the software 

specified by the Administrator, maintain the entered data in the 

format generated by the software specified by the Administrator. 

* * * * * 

3. Section 98.5 is revised to read as follows: 
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§ 98.5 How is the report submitted?

(a) Each GHG report and certificate of representation for a 

facility or supplier must be submitted electronically in 

accordance with the requirements of § 98.4 and in a format 

specified by the Administrator. 

(b) For reporting year 2014 and thereafter, for each 

applicable subpart listed in Table A-8 to Part 98, you must 

enter into verification software specified by the Administrator 

the data used as inputs to the emissions calculation equations 

specified in Table A-8 to Part 98, excluding data required to be 

reported in the reporting section of each subpart listed in 

Table A-8 to Part 98.. 

4. Table A-7 to Subpart A of Part 98 is revised to read 

as follows: 

Table A–7 to Subpart A of Part 98—Data Elements That Are Inputs 

to Emission Equations and for Which the Reporting Deadline Is 

March 31, 2015 

Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which 

reporting date is March 31, 2015 

(“All” means all data elements in 

the cited paragraph are not required 

to be reported until March 31, 2015)

A 98.3(d)(3)(v) All. 

C 98.36(b)(9)(iii) Only estimate of the heat input.1

C 98.36(c)(2)(ix) Only estimate of the heat input from 

each type of fuel listed in Table C–

2.1

C 98.36(e)(2)(i) All.1
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which 

reporting date is March 31, 2015 

(“All” means all data elements in 

the cited paragraph are not required 

to be reported until March 31, 2015)

C 98.36(e)(2)(ii)(A) All.1

C 98.36(e)(2)(ii)(C) Only HHV value for each calendar 

month in which HHV determination is 

required.1

C 98.36(e)(2)(ii)(D) All.1

C 98.36(e)(2)(iv)(A) All.1

C 98.36(e)(2)(iv)(C) All.1

C 98.36(e)(2)(iv)(F) All.1

C 98.36(e)(2)(ix)(D) All.1

C 98.36(e)(2)(ix)(E) All.1

C 98.36(e)(2)(ix)(F) All.1

E 98.56(g) All. 

E 98.56(h) All. 

E 98.56(j)(4) All. 

E 98.56(j)(5) All. 

E 98.56(j)(6) All. 

E 98.56(l) All. 

H 98.86(b)(11) All. 

H 98.86(b)(13) Name of raw kiln feed or raw 

material. 

L 98.126(b)(10) All. 

L 98.126(b)(11) All. 

L 98.126(b)(12) All. 

O 98.156(d)(2) All. 

O 98.156(d)(3) All. 

O 98.156(d)(4) All. 

Q 98.176(f)(1) All. 
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which 

reporting date is March 31, 2015 

(“All” means all data elements in 

the cited paragraph are not required 

to be reported until March 31, 2015)

V 98.226(i) All. 

V 98.226(j) All. 

V 98.226(m)(4) All. 

V 98.226(m)(5) All. 

V 98.226(m)(6) All. 

V 98.226(p) All. 

W 98.236(c)(1)(i) All. 

W 98.236(c)(1)(ii) All. 

W 98.236(c)(1)(iii) All. 

W 98.236(c)(2)(i) All. 

W 98.236(c)(3)(i) All. 

W 98.236(c)(3)(ii) All. 

W 98.236(c)(3)(iii) All. 

W 98.236(c)(4)(i)(A) All. 

W 98.236(c)(4)(i)(B) All. 

W 98.236(c)(4)(i)(C) All. 

W 98.236(c)(4)(i)(D) All. 

W 98.236(c)(4)(i)(E) All. 

W 98.236(c)(4)(i)(F) All. 

W 98.236(c)(4)(i)(G) All. 

W 98.236(c)(4)(i)(H) All. 

W 98.236(c)(4)(ii)(A) All. 

W 98.236(c)(5)(iii) All. 

W 98.236(c)(5)(iv) All. 

W 98.236(c)(5)(v) All. 

W 98.236(c)(6)(i)(B) All. 
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which 

reporting date is March 31, 2015 

(“All” means all data elements in 

the cited paragraph are not required 

to be reported until March 31, 2015)

W 98.236(c)(6)(i)(D) All. 

W 98.236(c)(6)(i)(E) All. 

W 98.236(c)(6)(i)(F) All. 

W 98.236(c)(6)(ii)(A) All. 

W 98.236(c)(6)(ii)(B) All. 

W 98.236(c)(7)(i) All. 

W 98.236(c)(8)(i)(B) All. 

W 98.236(c)(8)(i)(C) All. 

W 98.236(c)(8)(i)(F) All. 

W 98.236(c)(8)(ii)(A) All. 

W 98.236(c)(8)(ii)(D) All. 

W 98.236(c)(8)(iii)(A) All. 

W 98.236(c)(8)(iii)(D) All. 

W 98.236(c)(8)(iii)(E) All. 

W 98.236(c)(10)(ii) All. 

W 98.236(c)(10)(iii) All. 

W 98.236(c)(11)(ii) All. 

W 98.236(c)(12)(ii) All. 

W 98.236(c)(12)(iii) All. 

W 98.236(c)(12)(v) All. 

W 98.236(c)(13)(i)(B) All. 

W 98.236(c)(13)(i)(E) All. 

W 98.236(c)(13)(i)(F) All. 

W 98.236(c)(13)(ii)(A) All. 

W 98.236(c)(13)(ii)(B) All. 

W 98.236(c)(13)(iii)(A) All. 
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which 

reporting date is March 31, 2015 

(“All” means all data elements in 

the cited paragraph are not required 

to be reported until March 31, 2015)

W 98.236(c)(13)(iii)(B) All. 

W 98.236(c)(13)(v)(A) All. 

W 98.236(c)(14)(i)(B) All. 

W 98.236(c)(14)(ii)(A) All. 

W 98.236(c)(14)(ii)(B) All. 

W 98.236(c)(14)(iii)(A) All. 

W 98.236(c)(14)(iii)(B) All. 

W 98.236(c)(14)(v)(A) All. 

W 98.236(c)(15)(i)(A) All. 

W 98.236(c)(15)(i)(B) All. 

W 98.236(c)(15)(ii)(A) All. 

W 98.236(c)(15)(ii)(B) All. 

W 98.236(c)(16)(i) All. 

W 98.236(c)(16)(ii) All. 

W 98.236(c)(16)(iii) All. 

W 98.236(c)(16)(iv) All. 

W 98.236(c)(16)(v) All. 

W 98.236(c)(16)(vi) All. 

W 98.236(c)(16)(vii) All. 

W 98.236(c)(16)(viii) All. 

W 98.236(c)(16)(ix) All. 

W 98.236(c)(16)(x) All. 

W 98.236(c)(16)(xi) All. 

W 98.236(c)(16)(xii) All. 

W 98.236(c)(16)(xiii) All. 

W 98.236(c)(16)(xiv) All. 
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which 

reporting date is March 31, 2015 

(“All” means all data elements in 

the cited paragraph are not required 

to be reported until March 31, 2015)

W 98.236(c)(17)(ii) All. 

W 98.236(c)(17)(iii) All. 

W 98.236(c)(17)(iv) All. 

W 98.236(c)(18)(i) All. 

W 98.236(c)(18)(ii) All. 

W 98.236(c)(19)(iv) All. 

W 98.236(c)(19)(vii) All. 

Y 98.256(h)(5) Only value of the correction. 

Y 98.256(k)(4) Only mole fraction of methane in 

coking gas. 

Y 98.256(n)(3) All (if used in Equation Y–21 to 

calculate emissions from equipment 

leaks). 

Y 98.256(o)(4)(vi) Only tank-specific methane 

composition data and gas generation 

rate data. 

AA 98.276(e) All. 

CC 98.296(b)(10)(i) All. 

CC 98.296(b)(10)(ii) All. 

CC 98.296(b)(10)(iii) All. 

CC 98.296(b)(10)(iv) All. 

CC 98.296(b)(10)(v) All. 

CC 98.296(b)(10)(vi) All. 

II 98.356(d)(2) All (if conducting weekly sampling).

II 98.356(d)(3) All (if conducting weekly sampling).

II 98.356(d)(4) Only weekly average temperature (if 

conducting weekly sampling). 

II 98.356(d)(5) Only weekly average moisture content 
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which 

reporting date is March 31, 2015 

(“All” means all data elements in 

the cited paragraph are not required 

to be reported until March 31, 2015)

(if conducting weekly sampling). 

II 98.356(d)(6) Only weekly average pressure (if 

conducting weekly sampling). 

1

 Required to be reported only by combustion units subject to 

subpart C of part 98 that meet the following criteria: (1) the 

combustion unit is connected to a device that has been granted 

access by the Public Utilities Commission to deliver power to 

the local or regional electric power grid (e.g., electricity 

generators excluding generators connected to combustion units 

subject to subpart D of this part); and (2) the combined 

nameplate capacity (for all such devices at the facility) is 

greater than or equal to 1 megawatt electric. 

5. Table A-8 to Subpart A of Part 98 is added to read as 

follows: 

Table A–8 to Subpart A of Part 98—Equations For Which Certain 

Inputs To Equations Must be Entered Into Software Specified By 

the Administrator According to §98.5(b) of Part 98. 

Subpart Equation Number (40 CFR Part 98) 

Subpart C 1 C-1, C-1a, C-1b, C-2b, C-2c, C-3, C-4, C-5, C-8, C8a, C-8b, C-10, C-13 

Subpart E E-1, E-2, E-3a, E-3b, E-3c, E-3d 

Subpart F F-2, F-3, F-5, F-6, F-7, F-8 

Subpart G G-1, G-2, G-3 

Subpart H H-2, H-3, H-4, H-5 

Subpart K K-1, K-3 

Subpart L L-1, L-2, L-3, L-4, L-6, L-7, L-8, L-17, L-18, L-20, 

L-21, L-22, L-23, L-25, L-26, L-27, L-31, L-34 

Subpart N N-1 

Subpart O O-3, O-4, O-8, O-9 

Subpart P P-1, P-2, P-3 

Subpart Q Q-1, Q-2, Q-3, Q-4, Q-5, Q-6, Q-7 

Subpart R R-1 

Subpart S S-4 

Subpart U U-1, U-2 

Subpart V V-2, V-3a, V-3b, V-3c, V-3d 
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Subpart X X-1, X-2, X-3, C-8 

Subpart Y Y-1a, Y-1b, Y-3, Y-4, Y-6, Y-8, Y-11, Y-12, Y-13, Y14, Y-15, Y-16a, Y-16b, Y-17, Y-18, Y-19, Y-20, Y22, Y-23; alternate calculation methods to equations 

Y-9 and Y-10,specified in 98.253(c)(4) and (5) 

Subpart Z Z-1a, Z-1b 

Subpart AA C-1, C-1a, C-1b, C-2a, C-3, C-4, C-5, C-8, C-8a, C8b, C-9a, AA-1, AA-2, AA-3 

Subpart BB BB-1, BB-2 

Subpart CC CC-1, CC-2 

Subpart EE EE-2 

Subpart GG GG-1 

Subpart TT TT-2, TT-3 

1

 Does not include any combustion unit that is connected to a 

device that has been granted access by the Public Utilities 

Commission to deliver power to the local or regional power grid 

(e.g., electricity generators excluding generators connected to 

combustion units subject to subpart D of this part), and for 

which the combined nameplate capacity for all such devices at 

the facility is greater than or equal to 1 megawatt electric.

Subpart C—[AMENDED] 

6. Section 98.36 is amended by: 

a. Revising paragraph (a). 

b. Revising paragraph (b)(9)(iii) and adding paragraph 

(b)(9)(iv). 

c. Revising paragraph (c)(2)(ix) and adding paragraph 

(c)(2)(x). 

d. Revising paragraphs (e)(2)(i), (e)(2)(ii)(A), 

(e)(2)(ii)(C), and (e)(2)(ii)(D); and adding paragraph 

(e)(2)(ii)(E). 
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e. Revising paragraphs (e)(2)(iv)(A), (e)(2)(iv)(C), 

(e)(2)(iv)(F), and (e)(2)(ix)(D) through (F); and 

adding paragraph (f). 

The revisions and additions read as follows: 

§ 98.36 Data reporting requirements.

* * * * * 

(a) In addition to the facility-level information required 

under §98.3, the annual GHG emissions report shall contain the 

unit-level or process-level data specified in paragraphs (b) 

through (f) of this section, as applicable, for each stationary 

fuel combustion source (e.g., individual unit, aggregation of 

units, common pipe, or common stack). 

(b) * * * 

(9) * * * 

(iii) The annual CH4 and N2O emissions for each type of fuel 

listed in Table C–2 of this subpart that was combusted in the 

unit during the report year, expressed in metric tons of each 

gas and in metric tons of CO2e. 

(iv) For each stationary fuel combustion source that meets 

the criteria specified in paragraph (f) of this section, report 

an estimate of the heat input from each type of fuel listed in 

Table C–2 of this subpart that was combusted in the unit during 

the report year. 
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* * * * * 

(c) * * * 

(2) * * * 

(ix) For each type of fuel listed in Table C–2 of this 

subpart that was combusted during the report year in the units 

sharing the common stack or duct during the report year, the 

annual CH4 and N2O mass emissions from the units sharing the 

common stack or duct, expressed in metric tons of each gas and 

in metric tons of CO2 e. 

 (x) For each stationary fuel combustion source that meets 

the criteria specified in paragraph (f) of this section, an 

estimate of the heat input from each type of fuel listed in 

Table C–2 of this subpart that was combusted during the report 

year in the units sharing the common stack or duct during the 

report year. 

* * * * * 

(e) * * * 

(2) * * * 

(i) For the Tier 1 Calculation Methodology, for each 

stationary fuel combustion source that meets the criteria 

specified in paragraph (f) of this section, report the total 

quantity of each type of fuel combusted in the unit or group of 

aggregated units (as applicable) during the reporting year, in 
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Page 98 of 128 

short tons for solid fuels, gallons for liquid fuels and 

standard cubic feet for gaseous fuels, or, if applicable, therms 

or mmBtu for natural gas. 

(ii) * * * 

(A) For each stationary fuel combustion source that meets 

the criteria specified in paragraph (f) of this section, the 

total quantity of each type of fuel combusted in the unit or 

group of aggregated units (as applicable) during each month of 

the reporting year. Express the quantity of each fuel combusted 

during the measurement period in short tons for solid fuels, 

gallons for liquid fuels, and scf for gaseous fuels. 

* * * * * 

(C) For each stationary fuel combustion source that meets 

the criteria specified in paragraph (f) of this section, the 

high heat values used in the CO2 emissions calculations for each 

type of fuel combusted during the reporting year, in mmBtu per 

short ton for solid fuels, mmBtu per gallon for liquid fuels, 

and mmBtu per scf for gaseous fuels. Report a HHV value for each 

calendar month in which HHV determination is required. If 

multiple values are obtained in a given month, report the 

arithmetic average value for the month. Indicate whether each 

reported HHV is a measured value or a substitute data value. 
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(D) For each stationary fuel combustion source that meets 

the criteria specified in paragraph (f) of this section, if 

Equation C–2c of this subpart is used to calculate CO2 mass 

emissions, report the total quantity (i.e., pounds) of steam 

produced from MSW or solid fuel combustion during each month of 

the reporting year, and the ratio of the maximum rate heat input 

capacity to the design rated steam output capacity of the unit, 

in mmBtu per lb of steam. 

(E) For each HHV used in the CO2 emissions calculations for 

each type of fuel combusted during the reporting year, indicate 

whether the HHV is a measured value or a substitute data value. 

* * * * * 

(iv) * * * 

(A) For each stationary fuel combustion source that meets 

the criteria specified in paragraph (f) of this section, the 

quantity of each type of fuel combusted in the unit or group of 

units (as applicable) during each month of the reporting year, 

in short tons for solid fuels, gallons for liquid fuels, and scf 

for gaseous fuels. 

* * * * * 

(C) For each stationary fuel combustion source that meets 

the criteria specified in paragraph (f) of this section, the 

carbon content and, if applicable, gas molecular weight values 
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used in the emission calculations (including both valid and 

substitute data values). For each calendar month of the 

reporting year in which carbon content and, if applicable, 

molecular weight determination is required, report a value of 

each parameter. If multiple values of a parameter are obtained 

in a given month, report the arithmetic average value for the 

month. Express carbon content as a decimal fraction for solid 

fuels, kg C per gallon for liquid fuels, and kg C per kg of fuel 

for gaseous fuels. Express the gas molecular weights in units of 

kg per kg-mole. 

* * * * * 

(F) For each stationary fuel combustion source that meets 

the criteria specified in paragraph (f) of this section, the 

annual average HHV, when measured HHV data, rather than a 

default HHV from Table C–1 of this subpart, are used to 

calculate CH4 and N2O emissions for a Tier 3 unit, in accordance 

with §98.33(c)(1). 

* * * * * 

(ix) * * * 

(D) For each stationary fuel combustion source that meets 

the criteria specified in paragraph (f) of this section, the 

carbon-based F-factor used in Equation C–13 of this subpart, for 

each type of fossil fuel combusted, in scf CO2 per mmBtu. 
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(E) For each stationary fuel combustion source that meets 

the criteria specified in paragraph (f) of this section, the 

annual average HHV value used in Equation C–13 of this subpart, 

for each type of fossil fuel combusted, in Btu/lb, Btu/gal, or 

Btu/scf, as appropriate. 

(F) For each stationary fuel combustion source that meets 

the criteria specified in paragraph (f) of this section, the 

total quantity of each type of fossil fuel combusted during the 

reporting year, in lb, gallons, or scf, as appropriate. 

* * * * * 

(f) For stationary combustion sources using the Tier 1, 

Tier 2, Tier 3, or Tier 4 Calculation Methodologies in §98.33(a) 

to quantify CO2e emissions, report: 

(1) Whether any stationary combustion units are connected 

to devices that have been granted access by the Public Utilities 

Commission to deliver power to the local or regional power grid. 

(2) For all stationary combustion units that meet the 

criteria specified in paragraph (f)(1) of this section, indicate 

whether the combined nameplate capacity for all associated 

devices that are connected to the local or regional power grid 

(excluding generators that are connected to combustion units 

that are subject to subpart D of this part) is greater than or 

equal to than 1 megawatt. 
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Subpart E—[AMENDED] 

7. Section 98.56 is amended by: 

a. Revising the introductory text. 

b. Removing and reserving paragraphs (b), (c), (j)(1), 

and (j)(3). 

c. Adding paragraphs (m) and (n). 

The revisions and additions read as follows: 

§ 98.56 Data reporting requirements.

In addition to the information required by §98.3(c), each 

annual report must contain the information specified in 

paragraphs (a) through (n) of this section at the facility 

level. 

* * * * * 

(m) Annual quantity of cyclohexane fed to all production 

lines combined (metric tons). 

(n) Annual percent N2O emission reduction for all production 

units combined. 

* * * * * 

Subpart F—[AMENDED] 

8. Section 98.66 is amended by: 

a. Removing and reserving paragraphs (a) and (c)(2). 

b. Revising paragraphs (c)(3), (e)(1), and (f)(1). 

c. Removing and reserving paragraph (g). 
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The revisions read as follows: 

§ 98.66 Data reporting requirements.

* * * * * 

(c) * * * 

(3) The last date when the smelter-specific-slope 

coefficients (or overvoltage emission factors) were measured. 

* * * * * 

(e) * * * 

(1) Annual anode consumption if using the method in 

§98.63(g). 

* * * * * 

(f) * * * 

(1) Annual paste consumption if using the method in 

§98.63(g). 

* * * * * 

Subpart G—[AMENDED] 

9. Section 98.76 is amended by: 

a. Revising the introductory text. 

b. Removing and reserving paragraph (b)(2) and paragraphs 

(b)(7) through (11). 

c. Adding paragraphs (c) and (d). 

The revisions and additions read as follows: 

§ 98.76 Data reporting requirements.
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In addition to the information required by §98.3(c), each 

annual report must contain the information specified in 

paragraphs (a) through (d) of this section, as applicable for 

each ammonia manufacturing process unit. 

* * * * * 

(c) Annual ammonia production (metric tons). 

(d) Annual methanol production (metric tons), if this 

quantity is not reported under subpart X of Part 98. 

Subpart H—[AMENDED] 

10. Section 98.86 is amended by: 

a. Removing and reserving paragraphs (b)(2), (b)(5), 

(b)(6), (b)(8), (b)(10), and (12). 

b. Revising paragraphs (b)(13) and (15). 

c. Adding paragraphs (b)(16) through (18). 

The revisions and additions read as follows: 

§ 98.86 Data reporting requirements.

* * * * * 

(b) * * * 

(13) Name of raw kiln feed or raw material. 

* * * * * 

(15) Method used to determine the monthly clinker 

production from each kiln. 

(16) Annual clinker production (metric tons). 
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(17) Annual average clinker CO2 emission factor for the 

facility, averaged across all kilns (metric tons CO2/metric ton 

clinker produced). 

(18) Annual average CKD CO2 emission factor for the 

facility, averaged across all kilns (metric tons CO2/metric ton 

CKD produced). 

Subpart K—[AMENDED] 

11. Section 98.116 is amended by: 

a. Removing and reserving paragraphs (b), (e)(4), and 

(e)(5). 

b. Revising paragraph (e)(6). 

The revisions read as follows: 

§ 98.116 Data reporting requirements.

* * * * * 

(e) * * * 

(6) List the method used for the determination of carbon 

content for each material included for the calculation of annual 

process CO2 emissions for each EAF (e.g., supplier provided 

information, analyses of representative samples you collected). 

* * * * * 

Subpart L—[AMENDED] 

12. Section 98.126 is amended by: 

a. Revising paragraph (b)(1). 
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b. Removing and reserving paragraph (b)(2). 

c. Revising paragraphs (b)(6), (b)(7), and (b)(8)(i) 

through (iv). 

d. Removing and reserving paragraphs (b)(8)(v) and 

(b)(9). 

e. Revising paragraph (c)(1). 

f. Removing and reserving paragraph (c)(2). 

g. Revising paragraph (d). 

h. Removing and reserving paragraphs (f)(1), (g)(1), and 

(h)(2). 

The revisions read as follows: 

§ 98.126 Data reporting requirements.

* * * * * 

(b) * * * 

(1) If you calculate the relative and absolute errors under 

§ 98.123(b)(1), the absolute and relative errors calculated 

under paragraph § 98.123(b)(1). 

* * * * * 

(6) The chemical formula of each fluorine-containing 

reactant that is fed into the process. 

(7) The chemical formula of each fluorine-containing 

product produced by the process. 

(8) * * * 
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(i) The chemical formula of each fluorine-containing 

product that is removed from the process and fed into the 

destruction device. 

(ii) The chemical formula of each fluorine-containing byproduct that is removed from the process and fed into the 

destruction device. 

(iii) The chemical formula of each fluorine-containing 

reactant that is removed from the process and fed into the 

destruction device. 

(iv) The chemical formula of each fluorine-containing byproduct that is removed from the process and recaptured. 

* * * * * 

(c) * * * 

(1) The identity of the process activity used to estimate 

emissions (e.g., product produced or reactant consumed). 

* * * * * 

(d) Reporting for missing data. Where missing data have 

been estimated pursuant to § 98.125, you must report the reason 

the data were missing, the length of time the data were missing, 

and the method used to estimate the missing data. 

* * * * * 

Subpart N—[AMENDED] 
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13. Section 98.146 is amended by revising paragraph (b)(2) 

and removing and reserving paragraphs (b)(4) and (b)(6) to read 

as follows: 

§ 98.146 Data reporting requirements.

* * * * * 

(b) * * * 

(2) Annual quantity of each carbonate-based raw material 

charged (tons) to all furnaces combined. 

* * * * * 

Subpart O—[AMENDED] 

14. Section 98.156 is amended by: 

a. Removing and reserving paragraphs (a)(2), (a)(7) 

through (10), (b)(1), and (b)(2). 

b. Revising paragraph (d) introductory text. 

c. Removing and reserving paragraphs (d)(1), (d)(5), and 

(e)(1). 

The revisions read as follows: 

§ 98.156 Data reporting requirements.

* * * * * 

(d) If the HFC–23 concentration measured pursuant to 

§98.154(l) is greater than that measured during the performance 

test that is the basis for the destruction efficiency (DE), the 

facility shall report the following: 
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* * * * * 

Subpart P—[AMENDED] 

15. Section 98.166 is amended by: 

a. Revising the introductory text. 

b. Removing and reserving paragraphs (b)(2), (b)(5), and 

(b)(6). 

c. Adding paragraphs (b)(7) and (e). 

The revisions and additions read as follows: 

§ 98.166 Data reporting requirements.

In addition to the information required by §98.3(c), each 

annual report must contain the information specified in 

paragraphs (a) or (b) of this section, as appropriate, and 

paragraphs (c) through (e) of this section: 

* * * * * 

(b) * * * 

(7) Name and annual quantity (metric tons) of each carboncontaining fuel and feedstock. 

* * * * * 

(e) Annual methanol production (metric tons), if this 

quantity is not reported under subpart X of Part 98. 

Subpart Q—[AMENDED] 

16. Section 98.176 is amended by: 
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a. Removing and reserving paragraphs (b), (e)(1), (e)(3), 

(e)(4); and adding paragraph (e)(6). 

b. Removing and reserving paragraphs (f)(2) through (4), 

and (g). 

The revisions and additions read as follows: 

§ 98.176 Data reporting requirements.

* * * * * 

(e) * * * 

(6) The information specified in paragraphs (e)(6)(i) 

through (vi) of this section aggregated for all process units 

for which CO2 emissions were determined using the mass balance 

method in § 98.173(b)(1), except as provided in § 98.174(b)(4). 

(i) The annual mass (metric tons) of all gaseous, liquid, 

and solid fuels (combined) used in process units for which CO2

emissions were determined using Equations Q-1 through Q-7 of 

this section, calculated as specified in Equation Q-9 of this 

section. 

ݑܨ݈݁ 	ൌ ቀ∑ ܨ௚, ∗ 	௜ெௐ೔

ெ௏஼

௡

௜ୀଵ ∗ 0.001 ൅ ܨ௟, ∗ ௜ߩ௟, ∗ ௜0.001	൅ ܨ௦,௜ቁ	 (Eq. Q-9) 

Where: 

Fuel = Annual mass of all gaseous, liquid, and solid 

fuels used in process units (metric tons). 

n = Number of process units where fuel is used. 
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Fg,i = Annual volume of gaseous fuel combusted (“(Fg)” in 

Equations Q-1, Q-4 and Q-7 of this section) for 

each process (scf). 

MWi = Molecular weight of gaseous fuel used in each 

process (kg/kg-mole). 

MVC = Molar volume conversion factor at standard 

conditions, as defined in § 98.6. Use 849.5 scf 

per kg mole if you select 68 °F as standard 

temperature and 836.6 scf per kg mole if you 

select 60 °F as standard temperature. 

Fl,i = Annual volume of the liquid fuel combusted (“(Fl)” 

included in Equation Q-1 of this section) for 

each process unit (gallons). 

Fs,i = Annual mass of the solid fuel combusted (“(Fs)” in 

Equation Q-1 of this section) for each process 

unit (metric tons). 

ρl,i = Density of the liquid fuel (kg/gallon). 

0.001 = Conversion factor from kg to metric tons. 

(ii) The annual mass (metric tons) of all non-fuel material 

inputs (combined) specified in Equations Q-1 through Q-7 of this 

section, calculated as specified in Equation Q-10 of this 

section. 

௡௜݈݁݁ݐܵ ൅ ݀݁݋ݎݐ݈݁ܿܧ ൅ ݁݁݀ܨ ൅ ݈ܽ݋ܥ ൅ ݊݋ܾݎܽܥ ൅ ݔݑ݈ܨ ൅ ݌ܽݎܵܿ ൅ ݊݋ݎܫ ൅ ܱ ෍൭ ൌ ܫܨܰ

௡

௜ୀଵ

൱ݎ݄݁ݐܱ ൅ ݁ݎܱ ൅

(Eq. Q-10) 

Where: 

NFI = Annual mass of all non-fuel inputs (to all 

process unit types) specified in Equations Q-1 

through Q-7 of this section (metric tons). 

n = Number of process units, all process types. 

O = Annual mass of greenball (taconite) pellets fed 

to the taconite furnace(s) (metric tons). 
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Iron = Annual mass of molten iron charged to the basic 

oxygen furnace(s) plus annual mass of direct 

reduced iron charged to the EAF(s) (metric tons). 

Scrap = Annual mass of ferrous scrap charged to the basic 

oxygen furnace(s) and EAF(s) (metric tons). 

Flux = Annual mass of flux materials charged to the 

basic oxygen furnace(s) and EAF(s) (metric tons). 

Carbon = Annual mass of carbonaceous materials (e.g., 

coal, coke) charged to the basic oxygen 

furnace(s), EAF(s), and direct reduction 

furnace(s) (metric tons). 

Coal = Annual mass of coal charged to the coke oven 

battery(s) (metric tons). 

Feed = Annual mass of sinter feed material charged to 

the sinter process(es) (metric tons). 

Electrode = Annual mass of carbon electrode consumed in the 

EAF(s) (metric tons). 

Steelin = Annual mass of molten steel charged to the 

decarburization vessels (metric tons). 

Ore = Annual mass of iron ore or iron ore pellets fed 

to the direct reduction furnace(s) (metric tons). 

Other = Annual mass of other materials charged to the 

direction reduction furnace(s) (metric tons). 

(iii) The annual mass (metric tons) of all solid and liquid 

products and byproducts (combined) specified in Equations Q-1 

through Q-7 of this section, calculated as specified in Equation 

Q-11 of this section. 

௡∑ሺ ൌ ݏݐܿݑ݀݋ݎܲ

 (-11Q .ሺEq			ሻ ܯܰ ൅ ݊݋ݎܫ ൅ ݎ݁ݐܵ݅݊ ൅ ݇݁݋ܥ ൅ ݈ܵܽ݃ ൅ ௨௧௢݈݁݁ݐܵ ൅ ܴ ൅ ܲ ୀଵ௜

Where: 

Products = Annual mass of all solid and liquid products and 

by-products (from all process units) specified in 

Equations Q-1 through Q-7 of this section (metric 

tons). 
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n = Number of process units, all types. 

P = Annual mass of fired pellets produced by the 

taconite furnace (metric tons). 

R = Annual mass of air pollution control residue from 

all process units (metric tons). 

Steelout = Annual mass of steel produced by the basic oxygen 

furnace(s), EAF(s) and decarburization vessel(s) 

(metric tons). 

Slag = Annual mass of slag produced by the basic oxygen 

furnace(s) and EAF(s) (metric tons). 

Coke = Annual mass of coke produced by the non-recovery 

coke batteries (metric tons). 

Sinter = Annual mass of sinter produced from the sinter 

process(es) (metric tons). 

Iron = Annual mass of iron produced from the direct 

reduction furnace (metric tons). 

NM = Annual mass of non-metallic materials produced by 

the direct reduction furnace (metric tons). 

(iv) The weighted average carbon content of all gaseous, 

liquid, and solid fuels (combined) included in Equation Q-9 of 

this section, calculated as specified in Equation Q-12 of this 

section. 

ܨܥ௔௩௚ ൌ ቀ	∑ ி೒,೔	∗

ಾೈ೔

ಾೇ಴

೙

೔సభ ∗஼೒೑,೔∗଴.଴଴ଵାி೗,೔∗஼೗೑,೔∗଴.଴଴ଵା	ிೞ,೔∗஼ೞ೑	ቁ

ி௨௘௟ 		 (Eq. Q-12) 

Where: 

CFavg = Weighted average carbon content of all gaseous, 

liquid, and solid fuels included in Equation Q-9 

of this section (weight fraction). 

n = Number of gaseous, liquid, and solid fuel input 

to each process unit as used in Equation Q-9. 

Cgf,i = Average carbon content of the gaseous fuel used 

in each process, from the fuel analysis results 

(kg C per kg of fuel). 
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Clf,i = Carbon content of the liquid fuel used in each 

process, from the fuel analysis results (kg C per 

gallon of fuel. 

Csf = Carbon content of the solid fuel used in each 

process, from the fuel analysis (expressed as a 

decimal fraction, e.g., 95% = 0.95). 

Fuel = Annual mass of all gaseous, liquid, and solid 

fuels used in process units (metric tons), as 

calculated in Equation Q-9 of this section. 

(v) The weighted average carbon content of all non-fuel 

inputs to all process units (combined) included in Equation Q-10 

of this section, calculated as specified in Equation Q-13 of 

this section. 

ܫܥ௔௩௚ ൌ ൫∑ ேிூ೔∗஼ಿಷ಺೔ ೙

೔సభ ൯	

ேிூ 						 (Eq. Q-13) 

Where: 

CIavg = Weighted average carbon content of all non-fuel 

inputs to all process units included in Equation 

Q-10 of this section (weight fraction). 

n = Number of non-fuel inputs to all process units as 

used in Equation Q-10. 

NFIi = Annual mass of each non-fuel input used in 

Equation Q-10 (metric tons). 

CNFIi = Average carbon content of each non-fuel input 

used in Equation Q-10 (expressed as a decimal 

fraction). 

NFI = Total of all non-fuel inputs to all process units 

(metric tons). 

(vi) The weighted average carbon content of all solid and 

liquid products and byproducts from all process units (combined) 

included in Equation Q-11 of this section, calculated as 

specified in Equation Q-14 of this section. 
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ܥܲ௔௩௚ ൌ 	൫∑ ௉௥௢ௗ௨௖௧೔∗஼ು೔ ೙

೔సభ ൯

௉௥௢ௗ௨௖௧௦ (Eq. Q-14) 

Where: 

CPavg = Weighted average carbon content of all solid and 

liquid products and byproducts from all process 

units (weight fraction). 

n = Number of products and byproducts from each 

process unit as used in Equation Q-11. 

Producti = Annual mass of each product or byproduct used in 

Equation Q-11 (metric tons). 

Cp,i = Average carbon content of each product or 

byproduct used in Equation Q-11 (expressed as a 

decimal fraction). 

Products = Mass of all products and byproducts from all 

process units, calculated in Equation Q-11 of 

this section (metric tons). 

* * * * * 

Subpart R—[AMENDED] 

17. Section 98.186 is amended by removing and reserving 

paragraphs (b)(6) and (b)(7); and revising paragraph (b)(8) to 

read as follows: 

§ 98.186 Data reporting procedures.

* * * * * 

(b) * * * 

(8) List the method used for the determination of carbon 

content for each material used for the calculation of annual 

process CO2 emissions using Equation R–1 of this subpart for each 

smelting furnace (e.g., supplier provided information, analyses 

of representative samples you collected). 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release 

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* * * * * 

Subpart S—[AMENDED] 

18. Section 98.196 is amended by: 

a. Revising paragraph (b) introductory text. 

b. Removing and reserving paragraphs (b)(2), (b)(3), 

(b)(5), (b)(6), (b)(8), (b)(10), (b)(11), and (b)(12). 

c. Adding paragraph (b)(18). 

The revisions and additions read as follows: 

§ 98.196 Data reporting requirements.

* * * * * 

(b) If a CEMS is not used to measure CO2 emissions, then you 

must report the information listed in paragraphs (b)(1) through 

(18) of this section. 

* * * * * 

(18) Annual quantity (metric tons) of lime product sold, by 

type. 

Subpart U—[AMENDED] 

19. Section 98.216 is amended by removing and reserving 

paragraphs (b), (e)(1), (e)(2), and (f). 

Subpart V—[AMENDED] 

20. Section 98.226 is amended by: 

a. Revising the introductory text. 
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b. Removing and reserving paragraphs (d), (m)(1), and 

(m)(3). 

c. Adding paragraph (q). 

The revisions and additions read as follows: 

§ 98.226 Data reporting requirements.

In addition to the information required by § 98.3(c), each 

annual report must contain the information specified in 

paragraphs (a) through (q) of this section. 

* * * * * 

(q) Annual percent N2O emission reduction for all production 

units combined. 

Subpart X—[AMENDED] 

21. Section 98.246 is amended by: 

a. Revising paragraph (a) introductory text and 

paragraphs (a)(2) and (a)(4). 

b. Adding paragraphs (a)(12) and (13). 

c. Revising paragraph (b) introductory text. 

d. Removing and reserving paragraphs (b)(5)(iii) and 

(b)(5)(iv). 

e. Adding paragraphs (b)(9) and (b)(10). 

The revisions and additions read as follows: 

§ 98.246 Data reporting requirements.

* * * * * 
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 (a) If you use the mass balance methodology in § 98.243(c), 

you must report the information specified in paragraphs (a)(1) 

through (a)(13) of this section for each type of petrochemical 

produced, reported by process unit. 

* * * * * 

(2) The type of petrochemical produced, names of products, 

and names of carbon-containing feedstocks. 

* * * * * 

(4) The temperature (in °F) at which the gaseous feedstock 

and product volumes used in Equation X–1 of this subpart were 

determined. 

* * * * * 

(12) Name and annual quantity (in metric tons) of each 

carbon-containing feedstock included in Equations X-1, X-2, and 

X-3 of § 98.243 of this subpart. 

(13) Name and annual quantity (in metric tons) of each 

product included in Equations X-1, X-2, and X-3 of § 98.243 of 

this subpart. 

(b) If you measure emissions in accordance with § 

98.243(b), then you must report the information listed in 

paragraphs (b)(1) through (b)(10) of this section. 

* * * * * 
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(9) Name and annual quantity (in metric tons) of each 

carbon-containing feedstock. 

(10) Name and annual quantity (in metric tons) of each 

carbon-containing co-product. 

* * * * * 

Subpart Y—[AMENDED] 

22. Section 98.256 is amended by: 

a. Revising paragraphs (e)(6) and (e)(7) introductory 

text. 

b. Removing and reserving paragraph (e)(7)(ii). 

c. Revising paragraphs (e)(9) and (e)(10). 

d. Adding paragraph (e)(11). 

e. Revising paragraphs (f)(7) and (f)(10) through (13). 

f. Removing and reserving paragraph (h)(4). 

g. Revising paragraphs (h)(5), (i)(5), (i)(7), and 

(i)(8). 

h. Removing and reserving paragraph (j)(2). 

i. Revising paragraphs (j)(5) through (9), (k)(3), 

(k)(4), (l)(5), and (m)(3). 

j. Removing and reserving paragraphs (o)(2)(ii) and 

(o)(4)(ii) through (v). 

k. Revising paragraph (p)(2). 

The revisions and additions read as follows: 
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§ 98.256 Data reporting requirements.

* * * * * 

(e) * * * 

(6) If you use Equation Y–1a of this subpart, an indication 

of whether daily or weekly measurement periods are used, the 

annual volume of flare gas combusted (in scf/year) and the 

annual average molecular weight (in kg/kg-mole), and annual 

average carbon content of the flare gas (in kg carbon per kg 

flare gas). 

(7) If you use Equation Y–1b of this subpart, an indication 

of whether daily or weekly measurement periods are used, the 

annual volume of flare gas combusted (in scf/year), the annual 

average CO2 concentration (volume or mole percent), the number of 

carbon containing compounds other than CO2 in the flare gas 

stream, and for each of the carbon containing compounds other 

than CO2 in the flare gas stream: 

* * * * * 

(9) If you use Equation Y–3 of this subpart, the number of 

SSM events exceeding 500,000 scf/day. 

(10) The basis for the value of the fraction of carbon in 

the flare gas contributed by methane used in Equation Y–4 of 

this subpart. 

(11) If using Equation Y-3, report: 
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(i) Annual quantity of flare gas combusted (in MMscf per 

year). 

(ii) Annual average molecular weight of flare gas combusted 

(in mmBtu per MMscf). 

(iii) Annual average carbon content of flare gas combusted 

(expressed as a decimal fraction). 

(f) * * * 

(7) If you use Equation Y–6 of this subpart, the annual 

average exhaust gas flow rate, %CO2, and %CO. 

* * * * * 

(10) If you use Equation Y–8 of this subpart, the basis for 

the value of the coke burn-off factor, annual throughput of 

unit, and the average carbon content of coke. 

(11) Indicate whether you use a measured value, a unitspecific emission factor, or a default emission factor for CH4

emissions. If you use a unit-specific emission factor for CH4, 

report the basis for the factor. 

(12) Indicate whether you use a measured value, a unitspecific emission factor, or a default emission factor for N2O 

emissions. If you use a unit-specific emission factor for N2O, 

report the basis for the factor. 

(13) If you use Equation Y–11 of this subpart, the number 

of regeneration cycles or measurement periods during the 
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Page 122 of 128 

reporting year and the average coke burn-off quantity per cycle 

or measurement period. 

* * * * * 

(h) * * * 

(5) If you recycle tail gas to the front of the sulfur 

recovery plant, indicate whether the recycled flow rate and 

carbon content are included in the measured data under § 

98.253(f)(2) and (3). Indicate whether a correction for CO2

emissions in the tail gas was used in Equation Y–12. If so, then 

report: 

(i) The value of the correction. 

(ii) If the following data are not used to calculate the 

recycling correction factor, report the information specified in 

paragraphs (h)(5)(ii)(A) through (C) of this section. 

(A) The annual volume of recycled tail gas (in scf/year) 

only. 

(B) The annual average mole fraction of carbon in the tail 

gas (in kg-mole C/kg-mole gas). 

(C) Indicate whether you used the default (95%) or a unit 

specific correction, and if used, report the approach used. 

* * * * * 

(i) * * * 
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(5) If you use Equation Y–13 of this subpart, an indication 

of whether coke dust is recycled to the unit (e.g., all dust is 

recycled, a portion of the dust is recycled, or none of the dust 

is recycled). 

* * * * * 

(7) Indicate whether you use a measured value, a unitspecific emission factor or a default for CH4 emissions. If you 

use a unit-specific emission factor for CH4, report the basis for 

the factor. 

(8) Indicate whether you use a measured value, a unitspecific emission factor, or a default emission factor for N2O 

emissions. If you use a unit-specific emission factor for N2O, 

report the basis for the factor. 

(j) * * * 

(5) If you use Equation Y–14 of this subpart, the basis for 

the CO2 emission factor used. 

(6) If you use Equation Y–15 of this subpart, the basis for 

the CH4 emission factor used. 

(7) If you use Equation Y–16 of this subpart, the basis for 

the carbon emission factor used. 

(8) If you use Equation Y–16b of this subpart, the basis 

for the CO2 emission factor used and the basis for the carbon 

emission factor used. 
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(9) If you use Equation Y–17 of this subpart, the basis for 

the CH4 emission factor used. 

(k) * * * 

(3) The total number of delayed coking units at the 

facility; the total number of delayed coking drums at the 

facility; and, for each coke drum or vessel, the typical drum 

outage (i.e. the unfilled distance from the top of the drum, in 

feet). 

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

dimensions, the number of coking drums in the set, and the mole 

fraction of methane in coking gas (in kg-mole CF4/kg-mole gas, 

wet basis). 

* * * * * 

(l) * * * 

(5) The annual volumetric flow discharged to the atmosphere 

(in scf), and an indication of the measurement or estimation 

method, annual average mole fraction of each GHG above the 

concentration threshold or otherwise required to be reported and 

an indication of the measurement or estimation method, and for 

intermittent vents, the number of venting events and the 

cumulative venting time. 

(m) * * * 
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(3) For uncontrolled blowdown systems reporting under § 

98.253(k), the basis for the value of the methane emission 

factor used for uncontrolled blowdown systems. 

* * * * * 

(p) * * * 

(2) The types of materials loaded that have an equilibrium 

vapor-phase concentration of methane of 0.5 volume percent or 

greater, and the type of vessel (barge, tanker, marine vessel, 

etc.) in which each type of material is loaded. 

* * * * * 

Subpart Z—[AMENDED] 

23. Section 98.266 is amended by removing and reserving 

paragraphs (f)(5) and (f)(6). 

Subpart AA—[AMENDED] 

24. Section 98.276 is amended by: 

a. Revising the introductory paragraph. 

b. Removing and reserving paragraph (b). 

c. Revising paragraph (c). 

d. Removing and reserving paragraphs (d), (f), (g), (h) 

and (i). 

e. Adding paragraphs (l) and (m). 

The revisions and additions read as follows: 

§ 98.276 Data reporting requirements.
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Page 126 of 128 

In addition to the information required by § 98.3(c) and 

the applicable information required by § 98.36, each annual 

report must contain the information in paragraphs (a) through 

(m) of this section as applicable: 

* * * * * 

 (c) Basis for determining the annual mass of the spent 

liquor solids combusted (whether based on T650 om-05 Solids 

Content of Black Liquor, TAPPI (incorporated by reference, see § 

98.7) or an online measurement system). 

* * * * * 

(l) For each pulp mill lime kiln, report the information 

specified in paragraphs (l)(1) and (2) of this section. 

(1) The quantity of calcium oxide (CaO) produced (metric 

tons). 

(2) The percent of annual heat input, individually for each 

fossil fuel type. 

(m) For each chemical recovery furnace and each chemical 

recovery combustion unit for which you are not using Equation C2c to calculate CO2 emissions, report the information specified 

in paragraphs (m)(1) and (2) of this section. 

(1) The annual mass of steam generated (lb steam), 

individually for each fossil fuel type and for spent liquor 

solids. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release 

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Page 127 of 128 

(2) The ratio of the unit’s maximum rated heat input 

capacity to its design rated steam output capacity (mmBtu/lb 

steam), individually for each fossil fuel type and for spent 

liquor solids. 

Subpart BB—[AMENDED] 

25. Section 98.286 is amended by removing and reserving 

paragraphs (b)(1), (b)(4), and (b)(6). 

Subpart CC—[AMENDED] 

26. Section 98.296 is amended by removing and reserving 

paragraphs (b)(5) through (7). 

Subpart EE—[AMENDED] 

27. Section 98.316 is amended by removing and reserving 

paragraphs (b)(6) and (b)(9). 

Subpart GG—[AMENDED] 

28. Section 98.336 is amended by removing and reserving 

paragraphs (b)(6), (b)(7), and (b)(10). 

Subpart TT—[AMENDED] 

29. Section 98.466 is amended by: 

a. Removing and reserving paragraph (c)(3)(i). 

b. Revising paragraph (c)(3)(ii). 

c. Removing and reserving paragraph (c)(3)(iii). 

The revisions read as follows: 

§ 98.466 Data reporting requirements.
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release 

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* * * * * 

(c) * * * 

(3) * * * 

(ii) The year of the data used in Equation TT-2 for the 

waste disposal quantity and production quantity, for each year 

used in Equation TT–2 of this subpart to calculate the average 

waste disposal factor (WDF). 

* * * * *
Attachment F 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release 

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6560.50 

ENVIRONMENTAL PROTECTION AGENCY 

40 CFR Part 98 

[EPA-HQ-OAR-2010-0929; FRL-9801-2 ] 

RIN 2060-AQ81 

Revisions to Reporting and Recordkeeping Requirements, and 

Proposed Confidentiality Determinations under the Greenhouse Gas 

Reporting Program 

EO12866_GHGRP Part 98 2060 AQ81 NPRM 20120326 

AGENCY: Environmental Protection Agency (EPA). 

ACTION: Proposed rule. 

SUMMARY: The EPA is proposing amendments to reporting and 

recordkeeping requirements and an alternative verification 

approach for the Greenhouse Gas Reporting Program. This action 

addresses concerns about the potential release of certain data 

that are inputs to emission equations to be reported March 31, 

2015 while maintaining the EPA’s ability to verify emissions and 

ensure compliance with the Greenhouse Gas Reporting Program. In 

addition, the EPA is proposing confidentiality determinations 

for the newly proposed data elements in this action. 

DATES: Comments. Comments must be received on or before [INSERT 

THE DATE 60 DAYS AFTER PUBLICATION OF THIS PROPOSED RULE IN THE 

FEDERAL REGISTER]. 

Public Hearing. The EPA will hold a public hearing on this 

proposed rule if requested. Requests for a hearing must be made 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release 

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Page 2 of 133 

by [INSERT THE DATE 7 DAYS AFTER PUBLICATION OF THIS PROPOSED 

RULE IN THE FEDERAL REGISTER]. Contact the person listed in the 

“FOR FURTHER INFORMATION CONTACT” section by [INSERT THE DATE 7 

DAYS AFTER PUBLICATION OF THIS PROPOSED RULE IN THE FEDERAL 

REGISTER] to request a public hearing. If a hearing is 

requested, the EPA will announce the details, including specific 

dates, times, addresses and contact information for the hearing, 

in a separate Federal Register notice. 

ADDRESSES: Submit your comments, identified by Docket ID No. 

EPA–HQ–OAR–2010-0929, by one of the following methods: 

 Federal eRulemaking Portal: http:// www.regulations.gov. 

Follow the online instructions for submitting comments. 

 Email: GHGReportingCBI@epa.gov 

 Fax: (202) 566–1741. 

 Mail: Environmental Protection Agency, EPA Docket Center 

(EPA/DC), Mailcode 6102T, Attention Docket ID No. EPA–HQ–

OAR–2010-0929, 1200 Pennsylvania Avenue, NW., Washington, 

DC 20460. 

 Hand Delivery: EPA Docket Center, Public Reading Room, EPA 

West Building, Room 3334, 1301 Constitution Avenue, NW., 

Washington, DC 20004. Such deliveries are only accepted 

during the Docket’s normal hours of operation, and special 

arrangements should be made for deliveries of boxed 

information. 

Instructions: Direct your comments to Docket ID No. EPA–HQ–

OAR–2010-0929. The EPA’s policy is that all comments received 

will be included in the public docket without change and may be 

made available online at http://www.regulations.gov, including 

any personal information provided, unless the comment includes 
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Page 3 of 133 

information claimed to be confidential business information 

(CBI) or other information whose disclosure is restricted by 

statute. 

Do not submit information that you consider to be CBI or 

otherwise protected through http://www.regulations.gov or email. 

Send or deliver information identified as CBI to only the mail 

or hand/courier delivery address listed above, attention: Docket 

ID No. EPA–HQ–OAR–2010–0929. The http://www.regulations.gov

website is an “anonymous access” system, which means the EPA 

will not know your identity or contact information unless you 

provide it in the body of your comment. If you send an email 

comment directly to the EPA without going through 

http://www.regulations.gov your email address will be 

automatically captured and included as part of the comment that 

is placed in the public docket and made available on the 

Internet. If you submit an electronic comment, the EPA 

recommends that you include your name and other contact 

information in the body of your comment and with any disk or CD–

ROM you submit. If the EPA cannot read your comment due to 

technical difficulties and cannot contact you for clarification, 

the EPA may not be able to consider your comment. Electronic 

files should avoid the use of special characters, any form of 

encryption, and be free of any defects or viruses. 
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Docket: All documents in the docket are listed in the 

http://www.regulations.gov index. Although listed in the index, 

some information is not publicly available, e.g., CBI or other 

information whose disclosure is restricted by statute. Certain 

other material, such as copyrighted material, will be publicly 

available only in hard copy. Publicly available docket materials 

are available either electronically in 

http://www.regulations.gov or in hard copy at the Air Docket, 

EPA/DC, EPA West, Room B102, 1301 Constitution Ave., NW., 

Washington, DC. This Docket Facility is open from 8:30 a.m. to 

4:30 p.m., Monday through Friday, excluding legal holidays. The 

telephone number for the Public Reading Room is (202) 566–1744, 

and the telephone number for the Air Docket is (202) 566–1742. 

FOR FURTHER GENERAL INFORMATION CONTACT: Carole Cook, Climate 

Change Division, Office of Atmospheric Programs (MC–6207J), 

Environmental Protection Agency, 1200 Pennsylvania Ave., NW., 

Washington, DC 20460; telephone number: (202) 343–9263; fax 

number: (202) 343–2342; email address: GHGreporting@epa.gov. For 

technical information, contact the Greenhouse Gas Reporting Rule 

Helpline at: 

http://www.epa.gov/climatechange/emissions/ghgrule_contactus.htm

. Alternatively, contact Carole Cook at 202–343–9263. 

Worldwide Web (WWW). In addition to being available in the 

docket, an electronic copy of this proposal, memoranda to the 
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Page 5 of 133 

docket, and all other related information will also be available 

through the WWW on EPA’s greenhouse gas reporting rule Web site 

at 

http://www.epa.gov/climatechange/emissions/ghgrulemaking.html. 

SUPPLEMENTARY INFORMATION: 

Additional Information on Submitting Comments: To expedite 

review of your comments by Agency staff, you are encouraged to 

send a separate copy of your comments, in addition to the copy 

you submit to the official docket, to Carole Cook, Climate 

Change Division, Office of Atmospheric Programs (MC–6207J), 

Environmental Protection Agency, 1200 Pennsylvania Ave., NW., 

Washington, DC, 20460, telephone (202) 343–9263, email 

GHGReportingCBI@epa.gov. 

Regulated Entities. This proposed rule revision on 

reporting and recordkeeping requirements and verification 

procedures would affect entities that must submit annual 

greenhouse gas (GHG) reports under the Greenhouse Gas Reporting 

Program (40 CFR part 98). The Administrator has determined that 

40 CFR part 98 is subject to the provisions of Clean Air Act 

(CAA) section 307(d). See CAA section 307(d)(1)(V) (the 

provisions of CAA section 307(d) apply to “such other actions as 

the Administrator may determine”). Entities affected by this 

proposal are owners or operators of facilities that are direct 
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emitters of greenhouse gases (GHGs), which include those listed 

in Table 1 of this preamble: 

Table 1. Examples of Affected Entities by Category 

Category NAICS Examples of affected facilities 

General 

Stationary Fuel 

Combustion 

Sources 

 Facilities operating boilers, 

process heaters, incinerators, 

turbines, and internal combustion 

engines. 

321 Manufacturers of lumber and wood 

products. 

322 Pulp and paper mills.

325 Chemical manufacturers. 

324 Petroleum refineries and 

manufacturers of coal products. 

316, 326, 

339 

Manufacturers of rubber and 

miscellaneous plastic products. 

331 Steel works, blast furnaces. 

332 Electroplating, plating, polishing, 

anodizing, and coloring. 

336 Manufacturers of motor vehicle 

parts and accessories. 

221 Electric, gas, and sanitary 

services. 

622 Health services. 

611 Educational services. 

325193 Ethyl alcohol manufacturing 

facilities. 

311611 Meat processing facilities 

311411 Frozen fruit, juice, and vegetable 

manufacturing facilities. 

311421 Fruit and vegetable canning 

facilities. 

Electricity 

Generation 

221112 Fossil-fuel fired electric 

generating units, including units 

owned by Federal and municipal 

governments and units located in 

Indian Country. 

Adipic Acid 

Production 

325199 Adipic acid manufacturing 

facilities. 

Aluminum 

Production 

331312 Primary aluminum production 

facilities

Ammonia 

Manufacturing 

325311 Anhydrous and aqueous ammonia 

production facilities. 
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Category NAICS Examples of affected facilities 

Cement 

Production 

327310 Portland Cement manufacturing 

plants. 

Ferroalloy 

Production 

331112 Ferroalloys manufacturing 

facilities. 

Fluorinated GHG 

Production 

325120 Industrial gases manufacturing 

facilities. 

Glass Production 327211 Flat glass manufacturing 

facilities.

327213 Glass container manufacturing 

facilities. 

327212 Other pressed and blown glass and 

glassware manufacturing facilities. 

HCFC-22 

Production and 

HFC-23 

Destruction 

325120 Chlorodifluoromethane manufacturing 

facilities. 

Hydrogen 

Production 

325120 Hydrogen production facilities 

Iron and Steel 

Production 

331111 Integrated iron and steel mills, 

steel companies, sinter plants, 

blast furnaces, basic oxygen 

process furnace shops. 

Lead Production 331419 Primary lead smelting and refining 

facilities. 

331492 Secondary lead smelting and 

refining facilities. 

Lime Production 327410 Calcium oxide, calcium hydroxide, 

dolomitic hydrates manufacturing 

facilities. 

Magnesium 

Production 

331419 Primary lead smelting and refining 

facilities. 

331492 Secondary lead smelting and 

refining facilities. 

Manure 

Management 

112111 

112120 

112210 

112310 

112330 

112320 

Beef cattle feedlots. 

Dairy cattle and milk production 

facilities. 

Hog and pig farms. 

Chicken egg production facilities. 

Turkey Production. 

Broilers and other meat type 

chicken production. 

Municipal Solid 

Waste Landfills 

562212 

221320 

Solids Waste Landfills. 

Sewage treatment facilities. 

Nitric Acid 

Production 

325311 Nitric acid production facilities 
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Category NAICS Examples of affected facilities 

Petrochemical 

Production 

32511 Ethylene dichloride production 

facilities. 

325199 Acrylonitrile, ethylene oxide, 

methanol production facilities. 

325110 Ethylene production facilities.

325182 Carbon black production facilities. 

Petroleum and 

Natural Gas 

Systems 

486210 Pipeline transportation of natural 

gas. 

221210 Natural gas distribution 

facilities. 

211 Extractors of crude petroleum and 

natural gas. 

211112 Natural gas liquid extraction 

facilities. 

Petroleum 

Refineries 

324110 Petroleum refineries. 

Phosphoric Acid 

Production 

325312 Phosphoric acid manufacturing 

facilities. 

Pulp and Paper 

Manufacturing 

322110 Pulp mills. 

322121 Paper mills. 

322130 Paperboard mills. 

Silicon Carbide 

Production 

327910 Silicon carbide abrasives 

manufacturing facilities. 

Soda Ash 

Manufacturing 

325181 Alkalies and chlorine manufacturing 

facilities. 

212391 Soda ash, natural, mining and/or 

beneficiation. 

Titanium Dioxide 

Production 

325188 Titanium dioxide manufacturing 

facilities. 

Zinc Production 331419 Primary zinc refining facilities. 

331492 Zinc dust reclaiming facilities, 

recovering from scrap and/or 

alloying purchased metals. 

311411 Frozen fruit, juice and vegetable 

manufacturing facilities. 

311421 Fruit and vegetable canning 

facilities. 

Wastewater 

Treatment 

322110 Pulp mills.

322121 Paper mills. 

322122 Newsprint mills. 

322130 Paperboard mills. 

311611 Meat processing facilities. 

311411 Frozen fruit, juice and vegetable 

manufacturing facilities. 
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Category NAICS Examples of affected facilities 

311421 Fruit and vegetable canning 

facilities. 

325193 Ethanol manufacturing facilities. 

Table 1 of this preamble is not intended to be exhaustive, 

but rather provides a guide for readers regarding facilities and 

suppliers likely to be affected by this action. Types of 

facilities other than those listed in this table may also be 

affected by this action. To determine whether you are affected 

by this action, you should carefully examine the applicability 

criteria found in 40 CFR part 98, subpart A or the relevant 

criteria in the subparts. If you have questions regarding the 

applicability of this action to a particular facility or 

supplier, consult the person listed in the preceding FOR FURTHER 

GENERAL INFORMATION CONTACT section. 

Many facilities that are affected by 40 CFR part 98 have 

GHG emissions from multiple source categories listed in Table 1 

of this preamble. 

Acronyms and Abbreviations. The following acronyms and 

abbreviations are used in this document. 

BAMM Best Available Monitoring Methods 

CAA Clean Air Act 

CO2 carbon dioxide 

CBI confidential business information 

CEMS Continuous Emission Monitoring System 

CFR Code of Federal Regulations 

e-GGRT Electronic Greenhouse Gas Reporting Tool 
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EIA Energy Information Administration 

EPA U.S. Environmental Protection Agency 

FR Federal Register 

GHG greenhouse gas 

GHGRP Greenhouse Gas Reporting Program 

HCFC-22 chlorodifluoromethane 

HFC hydrofluorocarbons 

HQ Headquarters 

ICR Information Collection Request 

MW megawatt 

NAICS North American Industry Classification System 

NTTAA National Technology Transfer and Advancement Act 

OMB Office of Management & Budget 

RFA Regulatory Flexibility Act 

UMRA Unfunded Mandates Reform Act 

U.S. United States 

WWW Worldwide Web 

TABLE OF CONTENTS 

I. Executive Summary and Background

A. Executive Summary

B. Background

C. Subparts Covered in this Proposed Rule

D. Legal Authority

II. Summary of Proposed Changes to Part 98 Reporting and 

Recordkeeping Requirements

A. Proposed Use of Inputs Verification Tool

B. Proposed Revisions to Reporting of Data Elements Deferred 

until 2015

C. Proposed Changes to Recordkeeping Requirements

D. Proposed New Data Elements to be Reported

III. Rationale for Proposed Changes to Reporting and 

Recordkeeping Requirements

A. Proposed Inputs Verification Tool and Amendment to Reporting 

Requirements

B. Proposed Revisions to Recordkeeping Requirements

C. Proposed Requirement to Report Additional Data
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IV. Confidentiality Determination for Proposed New Data Elements 

to be Reported

V. Impacts of the Proposed Rule

A. How were the costs of this proposed rule estimated?

B. Additional Impacts of the Proposed Amendments

VI. Statutory and Executive Order Reviews

A. Executive Order 12866: Regulatory Planning and Review and 

Executive Order 13563: Improving Regulation and Regulatory 

Review

B. Paperwork Reduction Act

C. Regulatory Flexibility Act (RFA)

D. Unfunded Mandates Reform Act (UMRA)

E. Executive Order 13132: Federalism

F. Executive Order 13175: Consultation and Coordination with 

Indian Tribal Governments.

G. Executive Order 13045: Protection of Children from 

Environmental Health Risks and Safety Risks

H. Executive Order 13211: Actions that Significantly Affect 

Energy Supply, Distribution, or Use

I. National Technology Transfer and Advancement Act

J. Executive Order 12898: Federal Actions to Address 

Environmental Justice in Minority Populations and Low-Income 

Populations

I. Executive Summary and Background 

A. Executive Summary 

The Greenhouse Gas Reporting Program (GHGRP) collects 

greenhouse gas data from 41 source categories and currently has 

received 2two to 3three years of data from these sources. 

Greenhouse gas emissions from direct emitters are calculated 

using a variety of methods, including direct measurement, mass 

balance, and the use of emission factors. Reporters not using 

direct measurement must use equations to calculate emissions. 

The inputs to these emission equations often include process or 

production data that are specific to each facility’s operations. 
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These “inputs to emission equations” play an important role in 

the Agency’s ability to verify facility-level emissions and 

ensure compliance with the program. 

On July 7, 2010, the EPA proposed confidentiality 

determinations for the majority of data elements required to be 

reported under the GHGRP, as well as for the majority of source 

categories covered by the program. In the July 7, 2010 action, 

the EPA proposed that data elements categorized as “inputs to 

emission equations” are emission data. The CAA precludes 

“emission data” from being treated as confidential. 

Based on subsequent industry concerns regarding the 

potential release of data elements categorized as “inputs to 

emission equations,” the EPA deferred reporting of these data 

elements (see August 25, 2011 final action, 76 FR 53057) to 

allow the EPA to complete its evaluation of the potential impact 

from the public release of these data elements (see 76 FR 53060) 

and, if appropriate, to propose amendments to Part 98 (see 75 FR 

81355). Based on the analysis conducted, today’s action proposes 

amendments to reporting and recordkeeping requirements and an 

alternative verification approach for certain reporters subject 

to 24 subparts with inputs to emission equations for which the 

reporting deadline for inputs to emission equations was deferred 

until 2015 and disclosure concerns have been identified. 

Proposed amendments include: 

Comment [A1]: Has EPA finalized 

this? If not, are there plans to 

finalize it? 

EPA – This comment was discussed 

separately. 
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 Adding a requirement for certain reporters under 24 certain 

subparts to use an EPA-provided inputs verification tool. 

For these subparts, Tthe designated inputs to emission 

equations for which reporting was deferred to 2015 and 

disclosure concerns have been identified for these subparts 

would be entered into the tool.1 The tool would calculate 

the emissions and perform electronic verification. The tool 

would not retain the entered inputs (i.e., the inputs would 

not be reported to EPA); instead, the toolit would conduct 

certain checks (e.g., accuracy of the inputs) at the time 

of data entry and generate a verification summary. The 

verification summary, which would be accessible to the EPA 

once the annual report is submitted, would provide the EPA 

with information to conduct further verification if

necessary. 

 For reporters required to use the inputs verification tool, 

changing the required format for maintaining records of 

these inputs to emission equations. 

 For reporters required to use the inputs verification tool, 

lengthening the record retention period from 3 to 5 years 

for all records maintained under Part 98 (including 

subparts that do not require the use of the tool). 

 For certain reporterssubparts that required tothe use of 

the inputs verification tool, adding new data elements to 

be reported for the EPA’s verification purposes, and 

proposing confidentiality determinations for the new data 

elements proposed to be reported. 

 For reporters required to use the inputs verification tool, 

removing the requirement to report the inputs to emission 

equations for which reporting was deferred to 2015 and 

disclosure concerns have been identified, and requiring 

these datam to be kept as records. 

 

1

 Under this proposal, the inputs verification tool would not be 

required to be used by reporters for any reported GHG for 

which the reporter uses a CEMS or an EPA-approved alternative 

method (as allowed under sections 98.33(a)(5), 98.53(a)(2), and 

98.223(a)(2) of Part 98) to calculate the reported GHG value, 

rather than using "inputs to equations" data elements and the 

associated EPA-provided calculation methodologies to calculate 

the reported GHG value. 

Comment [A2]: Please confirm: It 

is not an option for these 

reporters to use direct measurement 

instead of the inputs verification 

tool. 

EPA: The rule revisions do not 

affect reporters that use CEMS to 

calculate reported GHG emissions. 

This has been clarified in the 

first bullet above, footnote 1, and 

several other places in the 

preamble. 
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 Reporting requirements for inputs to equations for which 

disclosure concerns were not identified (and would still be 

useful to EPA) are not proposed to be amended in this action. 

For these inputs to equations, the deferral would expire in 

March 2015, and EPA would collect these data. 

The proposed changes in this action build on the EPA’s 

experience and success with electronic reporting and 

verification during the first 3 years of the GHGRP. By requiring 

the use of the inputs verification tool, which would calculate 

GHG emissions based on the inputs to the emissions equations, 

the EPA would have the ability to identify facilities that 

potentially reported emissions incorrectly. This, combined with 

additional verification checks of the inputs to emission 

equations that the inputs verification tool would conduct 

(during the process of reporters entering data into the inputs 

verification tool), would provide the EPA with information 

necessary to conduct further verification once the annual report 

is submitted. This alternative verification approach, including 

the changes to the recordkeeping requirements and additional 

reporting requirements, would provide an alternative to 

collecting certain data elements for which reporting was 

deferred to March 31, 2015 and disclosure concerns have been 

identified, while maintaining the EPA’s ability to verify data 

and ensure compliance with the GHGRP. 
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B. Background

On October 30, 2009, the EPA published the Greenhouse Gas 

Reporting Rule, 40 CFR part 98, requiring annual reporting of 

GHG data from a broad range of industry sectors (74 FR 56260). 

Under the Greenhouse Gas Reporting Rule and its subsequent 

amendments (hereinafter referred to as “Part 98”), the EPA 

requires annual reporting of data from certain facilities and 

suppliers above specified emission or quantity supplied 

thresholds. On July 7, 2010 (75 FR 39094) and subsequent 

proposals (77 FR 1434, January 10, 2012; 77 FR 10434, February 

22, 2012), we proposed confidentiality determinations for the 

data elements required to be reported. The confidentiality of 

each reported data element was determined using a two-step 

approach: (1) grouping data elements into 11 data categories 

(e.g., inputs to emission equations, emissions, and unit/process 

operating characteristics that are not inputs to emission 

equations for direct emitter source categories); and (2) making 

confidentiality determinations either categorically or on an 

individual data elements basis. Refer to both the July 7, 2010 

proposal (75 FR 39097 and 104) and the May 26, 2011 final rule 

(76 FR 30785 - 30786) for more detailed descriptions of this 

process. Refer to the May 26, 2011 final rule also for a 

discussion of individual data element confidentiality 

determinations. We have finalized confidentiality determinations 
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for data elements except those in the “inputs to emission 

equations” category (May 26, 2011, 76 FR 30782; August 13, 2012, 

77 FR 48072; and August 24, 2012, 77 FR 51477)2

. For data 

elements in this category, we proposed that they meet the 

definition of “emission data” under 40 CFR 2.301(a)(2)(i). 

Because emission data are not entitled to confidential treatment 

under section 114(c) of the Clean Air Act, we did not evaluate 

whether such data elements would qualify as CBI, including 

whether disclosure would likely cause substantial competitive 

harm to the reporting facilities. (75 FR 39105 and 39108, July 

7, 2010). 

Following our proposal that data elements assigned to the 

“inputs to emission equations” category are not entitled to 

confidential treatment, we received numerous industry comments 

asserting that competitive harm would result from public release 

of many of these data elements. We determined that “these 

concerns warranted an in-depth evaluation of the potential 

impact from the release of inputs to emission equations.” (76 FR 

53060; August 25, 2011). In a notice dated December 27, 2010, we 

issued a call for information (75 FR 81354) requesting 

additional information to assist us in conducting our 

 

2

 There are a small number of data elements (besides data elements categorized as 

“inputs to emission equations”) for which we have not made a final confidentiality 

determinations because we concluded that a determination of confidentiality for the 

data element should be made on a case-by-case facility basis (according to individual 

circumstances of the facility). 
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evaluation. To allow sufficient time to complete this evaluation 

through notice and comment, we deferred the reporting deadline 

for data elements assigned to the “inputs to emission equation” 

category. Reporting of certain of these data elements was 

deferred to March 31, 2013, as specified in Table A-6 of subpart 

A; and reporting of the remainder of these data elements was 

deferred to March 31, 2015, as specified in Table A-7 of subpart 

A (see the August 25, 2011 final rule, 76 FR 53077). 

Our process for evaluating competitive harm was documented 

in the final deferral notice (August 25, 2011, 76 FR 53057) and 

the accompanying memorandum entitled “Process for Evaluating and 

Potentially Amending Part 98 Inputs to Emission Equations” 

(Docket ID EPA-HQ-OAR-2010-0929). As discussed in the final 

deferral notice and memorandum, our evaluation involved a fourstep process, as follows: 

 Step 1: Determine whether each data element assigned to the 

“inputs to emission equations” category is already publicly 

available. 

 Step 2: For data elements assigned to the “inputs to 

emission equations” category that are not publicly 

available, evaluate whether disclosure of the information 

is likely to result in substantial competitive harm. 

 Step 3: For data elements assigned to the “inputs to 

emission equations” category that are likely to cause 

substantial competitive harm if disclosed, evaluate 

potential alternative calculation methods. 

 Step 4: For data elements assigned to the “inputs to 

emission equations” category that are likely to cause 

substantial competitive harm if disclosed, evaluate 

potential alternative verification methods. 
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Based on each step of the four-step evaluation process, an 

analysis of all data elements for which reporting is deferred to 

March 31, 2015 was conducted.3 The results of the analysis are 

documented in four memoranda, as follows: 

 “Summary of Public Availability of Inputs to Emission 

Equations for Which Reporting was Deferred Until March 31, 

2015.” 

 “Evaluation of Competitive Harm From Reporting 2015 Inputs 

to Equations.” 

 “Summary of Alternative Calculation Methods.” 

 “Summary of Alternative Verification Methods.” 

These memoranda are available in EPA docket ID No. EPA–HQ–

OAR–2010-0929. Based on the results of these analyses, the EPA 

is proposing in today’s action to make certain amendments to 

Part 98. 

C. Subparts Covered in this Proposed Rule

The proposed amendments affect all subparts listed in Table 

2 of this preamble. Table 2 includes most of the subparts with 

inputs to emission equations for which the reporting deadline 

was deferred until 2015. Subpart W (Petroleum and Natural Gas 

Systems), Subpart II (Industrial Wastewater Treatment), and 

 

3 Based on the same four-step process, wWe also evaluated all data elements 

for which reporting wais deferred to March 31, 2013 (Part 98 Table A-6) based 

on the same four-step process and determined that took no further action was 

necessary. As a result, applicable facilities were required to report these 

data by April 1, 2013. For a discussion of this evaluation, refer to the 

EPA's memorandum "Summary of Evaluation of Greenhouse Gas Reporting Program 

(GHGRP) Part 98 “Inputs to Emission Equations” Data Elements Deferred Until 

2013" (December 17, 2012), available at 

http://www.epa.gov/ghgreporting/documents/pdf/2012/documents/2013-inputsmemo.pdf. 

Comment [A3]: We suggest adding 

further explanation in this 

footnote of what “no further action 

was necessary” and suggest stating 

the reporting result for the 

deferred reporting elements. 

EPA: Clarified and added that 

reporting occurred for these data 

elements. 
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subpart C (only certain combustion units associated with devices 

connected and able to deliver power to the local or regional 

electric power grid, as specified in Table 2) are not included 

in Table 2 because none of the inputs to emission equations 

required to be reported by reporters in these source categories 

are being amended, as no disclosure concerns were identified. 

Subpart I of part 98 is not included in Table 2 because 

reporting of inputs to emission equations under this subpart 

were addressed under a separate rulemaking proposed on October 

16, 2012 (77 FR 63538). Additionally, parts of theseis proposed 

rule amendments certain proposed amendmentswould affect subparts 

not listed in Table 2. Specifically, as follows: for reporters 

subject to both a subpart listed in Table 2 and a subpart of 

Part 98 not listed in this table, the proposed revision to the 

recordkeeping duration would apply to the records required for 

all Part 98 subparts (to which the reporter is subject). Refer 

to Sections II.C and III.B of this preamble for further 

discussion of this proposed amendment. 

Table 2. Subparts Affected by the Proposed Amendments.1,2

Subpart 

C—General Stationary Fuel 

Combustion except Certain 

Combustion Units Connected to 

Devices that are Connected to the 

Local or Regional Electric Power 

Grid2

Grid3

S—Lime Manufacturing 

E—Adipic Acid Production U—Miscellaneous Uses of 

Carbonate 

Comment [A4]: Please consider 

whether there is a more 

straightforward way of making this 

statement. Edits provided for 

consideration. 

Also review footnote 1 to the table 

for consistency with any changes 

here. 

EPA: Made the suggested change with 

a slight modification.
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F—Aluminum Production V—Nitric Acid Production 

G—Ammonia Manufacturing X—Petrochemical Production 

H—Cement Production Y—Petroleum Refineries 

K—Ferroalloy Production Z—Phosphoric Acid Production 

L—Fluorinated Gas Production AA—Pulp and Paper 

Manufacturing 

N—Glass Production BB—Silicon Carbide Production 

O—HCFC–22 Production and HFC–23 

Destruction 

CC—Soda Ash Manufacturing 

P—Hydrogen Production EE—Titanium Dioxide 

Production 

Q—Iron and Steel Production GG—Zinc Production 

R—Lead Production TT—Industrial Waste Landfills 1

 Certain proposed amendments affect other subparts not listed in this table 

as follows: for reporters subject to both a subpart listed in this table and 

a subpart of Part 98 not listed in this table, the proposed revision to the 

recordkeeping duration would apply to the records required for all Part 98 

subparts to which the reporter is subject. 

2

 Under this proposal, the inputs verification tool would not be required to 

be used by reporters for any reported GHG for which the reporter uses a CEMS 

or an EPA-approved alternative method (as allowed under sections 98.33(a)(5), 

98.53(a)(2), and 98.223(a)(2) of Part 98) to calculate the reported GHG 

value, rather than using "inputs to equations" data elements and the 

associated EPA-provided calculation methodologies to calculate the reported 

GHG value.

2 3 The combustion units not affected by the proposed amendments include those 

meeting the following criteria: (1) the combustion unit is connected to a 

device that has been granted access by the Public Utilities Commission to 

deliver power to the local or regional electric power grid (e.g., electricity 

generators excluding generators connected to combustion units subject to 

subpart D of this part); and (2) the combined nameplate capacity (for all 

such devices at the facility excluding generators connected to combustion 

units subject to subpart D of this part)) is greater than or equal to 1 

megawatt electric. Refer to Section III.A.3 of this preamble for a discussion 

of the EPA’s rationale for proposing that combustion units meeting these 

criteria not be affected by the proposed amendments. 

D. Legal Authority

The EPA is proposing these rule amendments under its 

existing CAA authority provided in CAA section 114. As stated in 

the preamble to the 2009 final GHG reporting rule (74 FR 56260, 

October 30, 2009), CAA section 114(a)(1) provides the EPA broad 

authority to require the information proposed to be gathered by 
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this rule because such data would inform and are relevant to the 

EPA’s carrying out a wide variety of CAA provisions. See the 

preambles to the proposed (74 FR 16448, April 10, 2009) and 

final Part 98 (74 FR 56260) for further information. 

In addition, pursuant to sections 114, 301, and 307 of the 

CAA, the EPA is proposing confidentiality determinations for the 

new data elements proposed in this notice. Section 114(c) of the 

CAA requires that the EPA make publicly available information 

obtained under CAA section 114 except for information (excluding 

emission data) that qualifies for confidential treatment. The 

Administrator has determined that this action (Part 98 amendment 

and confidentiality determinations) is subject to the provisions 

of CAA section 307(d). 

II. Summary of Proposed Changes to Part 98 Reporting and 

Recordkeeping Requirements 

The EPA is proposing revisions to the reporting and 

recordkeeping requirements in Part 98 and alternative 

verification procedures that would apply to certain reporters 

subject to any of the 24 subparts listed in Table 2 of this 

preamble. Section II.A of this preamble summarizes a proposed 

new requirement for these reporters using inputs to emission 

equations for which reporting was deferred to March 31, 2015 

(hereafter referred to as “inputs to equations” data elements) 

to calculate reported GHGs. These reporters would be required to 
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use an EPA-provided electronic inputs verification tool to 

calculate emissions using data elements for which reporting was 

deferred to March 31, 2015 (hereafter referred to as “inputs to 

equations” data elements), allowing the EPA to complete 

electronic verification of reported GHG emissions data without 

the need to collect “inputs to equations” data elements for 

which disclosure concerns have been identified. Section II.B of 

this preamble summarizes the EPA’s proposal to remove, for these 

reporters, the requirement to report many “inputs to equations” 

data elements. Section II.C of this preamble summarizes proposed 

revisions to the recordkeeping requirements for these reporters. 

Section II.D of this preamble summarizes proposed new reporting 

requirements for these reporters. Section III of this preamble 

explains the rationale for the proposed amendments summarized in 

Sections II.A through II.D. Section IV of this preamble presents 

the EPA’s proposed confidentiality determinations for proposed 

new data elements and the EPA’s rationale for these 

determinations. Section V of this preamble presents the cost and 

impacts associated with these proposed amendments. 

A. Proposed Use of Inputs Verification Tool 

The EPA is proposing that facilities subject to the 

subparts listed in Table 2 of this preamble and that use “inputs 

to equations” data elements to calculate reported GHGs use an 

electronic inputs verification tool being being developed by the 

Comment [A5]: EPA may want to 

consider noting here that there is 

a prototype available during the 

comment period. The phrase “being 

developed” makes it seem like the 

tool is not yet available in any 

form. 

EPA: Added in text here about the 

“pilot”. I kept the “being” since 

so far it’s only developed for one 

subpart. 
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EPA, which would calculate and verify GHG emissions. Refer to 

section III.A.1 of this preamble for a web-link to EPA’s “pilot” 

inputs verification tool for one subpart of Part 98, available 

during the public comment period for this rulemaking. The 

“pilot” to demonstrates how the tool would work within e-GGRT, 

as well as the types of verification checks that would be 

conducted. The inputs verification tool would be deployed within 

the EPA’s Electronic Greenhouse Gas Reporting Tool (e-GGRT) and 

would be integrated without interrupting the current electronic 

reporting process. While reporters enter data into e-GGRT that 

are required to be reported in the annual report, Rreporters 

would also enter into e-GGRT (via the inputs verification tool) 

the “inputs to equations” data elements that the EPA is 

proposing to remove from the reporting requirements into e-GGRT 

along with the data required to be reported in the annual 

report. The tool would use the entered “inputs to equations” 

data elements to calculate the equation outputs, conduct 

electronic verification checks on the “inputs to equations” data 

elements, and generate a verification summary. The tool would 

not retain the entered “inputs to equations” data elements for 

which the EPA is proposing that the reporting requirement be 

removed. Accordingly, the EPA would not have access to these 

“inputs to equations” data elements. Instead, the EPA would rely 

on the verification summary, which would become accessible to 
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the EPA when annual reports are submitted, as a first step for 

conducting verification once the annual report is submitted. 

Sources subject to multiple subparts under Part 98 would be 

required to use the inputs verification tool for only those 

subparts listed in Table 2 of this preamble. The EPA is 

proposing that reporters use this tool starting with reporting 

year 2014. Refer to Section III.A of this preamble for further 

discussion of this proposed requirement.

This proposed requirement to use the inputs verification 

tool is specified in 40 CFR 98.5, Subpart A. Reporters would 

determine applicability under this new requirement based on a 

proposed new Table A-8 to Part 98, which lists all equations 

under Part 98 for which the inputs verification tool must be 

used. Reporters calculating reported GHGs using equations listed 

in Table A-8 would be required to enter “inputs to equations” 

data elements that have been removed from the reporting 

requirements into the inputs verification tool.

B. Proposed Revisions to Reporting of Data Elements Deferred 

until 2015

The EPA is proposing to remove the reporting requirement 

for 435 “inputs to equations” data elements in the subparts 

listed in Table 2 of this preamble. Table 3 of this preamble 

provides a summary of how many data elements would be removed 

from reporting for eachper subpart. Refer to Table 1 in the 
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memorandum “List of ‘Inputs to Equations’ Data Elements Proposed 

Not To Be Reported” (refer to Docket ID No. EPA–HQ–OAR–2010-

0929) for a complete list of these 435 data elements. For all 

remaining “inputs to equations” data elements not represented in 

Table 3 of this preamble and Table 1 of the memorandum cited 

above, the EPA is not amending these reporting requirements and 

would, therefore, let the deferral of these data elements expire 

on March 31, 2015. As a result, by March 31, 2015, all of the 

“inputs to equations” data elements for subpart W (Petroleum and 

Natural Gas Systems), Subpart II (Industrial Wastewater 

Treatment), and the additional “inputs to equations” data 

elements for which reporting is not proposed to be removed as 

indicated in Table 3 of this preamble, would be reported for 

future reporting years and for all prior reporting years prior 

to, and, including, reporting year 2014. For a list of these 

“inputs to equations” data elements that would be reported, 

refer to Table 2 of the memorandum cited above.

Table 3. Subparts For Which Reporting Requirements are Amended 

Subpart

Number of “Inputs to 

Equations” Data 

Elements 

Number of “Inputs 

to Equations” Data 

Elements Proposed 

Not to Be Reported

C—General Stationary 

Fuel Combustion 

Except Certain 

Combustion Units 

Connected to Devices 

Connected to the 

261

 261
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Subpart

Number of “Inputs to 

Equations” Data 

Elements 

Number of “Inputs 

to Equations” Data 

Elements Proposed 

Not to Be Reported 

Local or Regional 

Power Grid2

E—Adipic Acid 

Production 

21 11 

F—Aluminum Production 29 29 

G—Ammonia 

Manufacturing 

8 8 

H—Cement Production 16 14 

K—Ferroalloy 

Production 

13 13 

L—Fluorinated Gas 

Production 

55 46 

N—Glass Production 3 3 

O—HCFC–22 Production 

and HFC–23 

Destruction 

15 12 

P—Hydrogen Production 7 7 

Q—Iron and Steel 

Production 

93 92 

R—Lead Production 10 10 

S—Lime Manufacturing 9 9 

U—Miscellaneous Uses 

of Carbonate 

6 6 

V—Nitric Acid 

Production 

21 106

X—Petrochemical 

Production 

21 21 

Y—Petroleum 

Refineries 

80 70 

Z—Phosphoric Acid 

Production 

4 4 

AA—Pulp and Paper 

Manufacturing 

31 28 

BB—Silicon Carbide 

Production 

3 3 

CC—Soda Ash 

Manufacturing 

10 4 

EE—Titanium Dioxide 

Production 

2 2 
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Subpart

Number of “Inputs to 

Equations” Data 

Elements 

Number of “Inputs 

to Equations” Data 

Elements Proposed 

Not to Be Reported 

GG—Zinc Production 8 8 

TT—Industrial Waste 

Landfills 

3 3 

1 Includes one “inputs to equations” data element, 40 CFR 98.3(d)(3)(v), which 

is specified in subpart A of part 98 and applies to only certain reporters 

under subpart C of part 98. 

2

 The reporting requirements applicable to certain combustion units subject to 

subpart C remain the same under the proposed amendment. Subpart C would 

continue to require reporting of all applicable “inputs to equations” data 

elements for combustion units that meet the following criteria: (1) the 

combustion unit is connected to a device that has been granted access by the 

Public Utilities Commission to deliver power to the local or regional 

electric power grid (e.g., electricity generators excluding generators 

connected to combustion units subject to subpart D of this part); and (2) the 

combined nameplate capacity (for all such devices at the facility excluding 

generators connected to combustion units subject to subpart D of this part))

is greater than or equal to 1 megawatt electric. Subpart C reporters would 

not report “inputs to equations” data elements for all other types of 

combustion units subject to subpart C. 

In order to ease the burden for facilities, the EPA is 

proposing that these “inputs to equations” data elements that

are not being amended in this action (and therefore would be 

reported for reporting years prior to reporting year 2014) (as 

described above) be reported as part of the annual report for 

reporting year 2014. Specifically, when reporters prepare their 

reporting year 2014 annual report via e-GGRT, they would be 

required to include these “inputs to equations” data elements 

for reporting year 2014 as well as for all applicable previous 

reporting years. The annual report, including these “inputs to 

equations” data elements that would still be reported, would be 

submitted via e-GGRT. This proposed approach would prevent 

Comment [A6]: This is confusing, 

please clarify EPA’s intent by 

specifying more precisely what 

would be required from reporters. 

Is EPA requiring (a) the annual 

report for reporting year 2014; and 

(b) “inputs to equations data” from 

2013 (and prior years), and that 

this information would be included 

as a part of the annual report for 

reporting year 2014? Would the 

information requested in item (b) 

be provided through the inputs 

verification tool, or in a 

different format? (p.48 has 

similar text; revise consistently). 

EPA – Clarified. The inputs 

verification tool would not be used 

for these inputs, because we are 

referring here to the ones that 

we’ve determined do not have 

disclosure concerns, and will be 

reported to EPA, and retained. 
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facilities from being required to revise, re-certify, and resubmit annual reports for each previous reporting year. 

C. Proposed Changes to Recordkeeping Requirements

For each facility subject to a subpart listed in Table 2 of 

this preamble that uses “inputs to equations” data elements to 

calculate and report GHGs (i.e., subject to using the proposed 

inputs verification tool), the EPA is proposing that the 

facility retain all records, including records for subparts not 

subject to the inputs verification tool requirement, for 5 

years, rather than the current 3-year record retention period. 

In other words, if any facility subject to using the proposed 

inputs verification tool a subpart listed in Table 2 is also 

subject to a subpart of Part 98 not listed in Table 2, we 

propose that records required for those other subparts also be 

maintained for the 5 years. For example, if such a facility is 

required to report under both subpart C (in Table 2) and subpart 

HH (not in Table 2), the facility would be required to maintain 

all records required under both subparts for 5 years following 

submittal of the annual report. The EPA is proposing that this 

5-year record retention requirement begin with records for 

reporting year 2010. 

Additionally, we are proposing that, at the time a reporter 

subject to any subpart listed in Table 2 of this preamble that 

is subject to using the proposed inputs verification tool 
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completes entry of all “inputs to equations” data elements into 

the inputs verification tool, the reporter would be required to 

keep a file generated by the tool that lists the entered “inputs 

to equations” data elements. The reporter would be required to 

maintain a copy of the file as a record of the entered inputs. 

As currently required in 40 CFR 98.3(g), subpart A, this file 

may be maintained in electronic or hard copy format. As 

discussed above, this record would be required to be maintained 

for 5 years.

Refer to Section III.B of this preamble for further 

discussion of these proposed recordkeeping requirements. 

D. Proposed New Data Elements to be Reported 

The EPA is proposing that reporters subject to using the 

proposed inputs verification tool in subparts E, G, H, P, Q, S, 

V, X, Y, and AA of Part 98, be required to report the additional 

data elements listed per subpart in Table 4 of this preamble. 

Proposed confidentiality determinations for these proposed data 

elements are presented in Section IV of this preamble. 

Table 4. Proposed New Data Elements for Subparts E, G, H, P, Q, 

S, V, X, Y, and AA of Part 98 

Subpart Subpart Name New Data Element Description 

E Adipic Acid 

Production 

Annual quantity of cyclohexane fed 

to all production lines (metric 

tons). 

Annual percent N2O emission 

reduction for all production units 

combined. 

G Ammonia Annual ammonia production (metric 
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Subpart Subpart Name New Data Element Description 

Production tons). 

Annual methanol production (metric 

tons), if this quantity is not 

reported under subpart X of Part 98. 

H Cement Production Annual clinker production (metric 

tons). 

Annual average clinker CO2 emission 

factor for the facility, averaged 

across all kilns (metric tons 

CO2/metric ton clinker produced). 

Annual average cement kiln dust 

(CKD) CO2 emission factor for the 

facility, averaged across all kilns 

(metric tons CO2/metric ton CKD 

produced). 

P Hydrogen 

Production 

Name and annual quantity (metric 

tons) of each carbon-containing fuel 

and feedstock. 

Annual methanol production (metric 

tons), if this quantity is not 

reported under subpart X of Part 98. 

Q Iron and Steel 

Production 

If you use the carbon mass balance 

method in 40 CFR 98.173(b)(1) to 

determine CO2 emissions: The annual 

mass (metric tons) of all gaseous, 

liquid, and solid fuels (combined) 

used in process units specified in 

Equations Q-1 through Q-7 of Part 

98, calculated as specified in a 

proposed new Equation Q-9 in the 

proposed rule amendments. Do not 

include fuel used in a stationary 

combustion unit where emissions are 

reported under subpart C of this 

part. 

If you use the carbon mass balance 

method in 40 CFR 98.173(b)(1) to 

determine CO2 emissions: The annual 

mass (metric tons) of all non-fuel 

material inputs (combined) specified 

in Equations Q-1 through Q-7 of Part 

98, calculated as specified in a 

proposed new Equation Q-10 in the 

proposed rule amendments. 
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Subpart Subpart Name New Data Element Description 

If you use the carbon mass balance 

method in 40 CFR 98.173(b)(1) to 

determine CO2 emissions: The annual 

mass (metric tons) of all solid and 

liquid products and byproducts 

(combined) specified in Equations Q1 through Q-7 of Part 98, calculated 

as specified in a proposed new 

Equation Q-11 in the proposed rule 

amendments. 

If you use the carbon mass balance 

method in 40 CFR 98.173(b)(1) to 

determine CO2 emissions: The 

weighted average carbon content of 

all gaseous, liquid, and solid fuels 

(combined) included in proposed new 

Equation Q-9, calculated as 

specified in a proposed new Equation 

Q-12 in the proposed rule 

amendments. 

If you use the carbon mass balance 

method in 40 CFR 98.173(b)(1) to 

determine CO2 emissions: The 

weighted average carbon content of 

all non-fuel inputs to all furnaces 

(combined) included in proposed new 

Equation Q-10, calculated as 

specified in a proposed new Equation 

Q-13 in the proposed rule 

amendments. 

If you use the carbon mass balance 

method in 40 CFR 98.173(b)(1) to 

determine CO2 emissions: The 

weighted average carbon content of 

all solid and liquid products and 

byproducts from all furnaces 

(combined) included in a proposed 

new Equation Q-11 in the proposed 

rule amendments, calculated as 

specified in new Equation Q-14. 

S Lime 

Manufacturing 

Annual quantity (metric tons) of 

lime product sold, by type. 

V Nitric Acid 

Production 

Annual percent N2O emission 

reduction for all production units 

combined.
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Subpart Subpart Name New Data Element Description 

X Petrochemical 

Production 

If using the mass balance method or 

CEMS method to calculate GHG 

emissions: Name and annual quantity 

(in metric tons) of each carboncontaining feedstock included in 

Equations X-1, X-2 and X-3. 

If using the mass balance method or 

CEMS method to calculate GHG 

emissions: Name and annual quantity 

(in metric tons) of each carboncontaining co-product included in 

Equations X-1, X-2 and X-3. 

Y Petroleum 

Refineries 

Annual quantity of flare gas 

combusted (in MMscf per year) (only 

when using Equation Y-3). 

Annual average molecular weight of 

flare gas combusted (in mmBtu per 

MMscf) (only when using Equation Y3). 

Annual average carbon content of 

flare gas combusted (expressed as a 

decimal fraction)(only when using 

Equation Y-3). 

AA Pulp and Paper 

Manufacturing 

For each pulp mill lime kiln: 

Quantity of calcium oxide (CaO) 

produced (metric tons). 

For each pulp mill lime kiln: 

Percent of annual heat input, 

individually for each fossil fuel 

type. 

For each chemical recovery furnace 

and chemical recovery combustion 

unit for which you are not using 

Equation C-2c to calculate CO2

emissions: Annual mass of steam 

generated (lb steam), individually 

for each fossil fuel type and for 

spent liquor solids. 

For each chemical recovery furnace 

and chemical recovery combustion 

unit for which you are not using 

Equation C-2c to calculate CO2

emissions: Ratio of the unit’s 

maximum rated heat input capacity to 

its design rated steam output 
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Subpart Subpart Name New Data Element Description 

capacity (mmBtu/lb steam), 

individually for each fossil fuel 

type and for spent liquor solids.

III. Rationale for Proposed Changes to Reporting and 

Recordkeeping Requirements 

Based on the four-step evaluation described in Section I.B 

of this preamble, in particular the disclosure concerns 

discussed in “Step 2” of the evaluation and the alternatives 

considered in “Step 3” and “Step 4” of the evaluation to address 

those disclosure concerns, the EPA is proposing an alternative 

verification approach. This approach involves use of an inputs 

verification tool and revisions to the reporting and 

recordkeeping requirements of Part 98. The EPA’s rationale for 

this approach is presented in Sections III.A through C below. 

Section III.A addresses the proposed inputs verification tool 

and revisions to the requirement to report certain “inputs to 

equations” data elements. Section III.B addresses the proposed 

revisions to recordkeeping requirements. Section III.C addresses 

the proposed addition of new reporting requirements. 

A. Proposed Inputs Verification Tool and Amendment to Reporting 

Requirements

The EPA is proposing that facilities using subject “inputs 

to equations” data elements to calculate reported GHGs underto

the subparts listed in Table 2 of this preamble use an EPA-
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provided electronic inputs verification tool, which would 

calculate and verify GHG emissions. The inputs verification tool 

would be deployed within e-GGRT and integrated without 

interrupting the current electronic reporting process. Reporters 

would enter their “inputs to equations” data elements into the 

tool within the e-GGRT system along with the data required to be 

reported in the annual report (concurrent entry of “inputs to 

equations” data elements and data required for the annual report 

would be required starting in reporting year 2014, as further 

discussed in Section III.A.2 of this preamble). As a built-in 

feature of the e-GGRT system, the tool would use the entered 

“inputs to equations” data elements to calculate the equation 

outputs, conduct electronic verification checks on the “inputs 

to equations” data elements, and generate a verification 

summary. The tool would not retain the entered “inputs to 

equations” data elements for which the EPA is proposing that the 

reporting requirement be removed.4

 Accordingly, unlike data 

currently reported to the EPA through e-GGRT, the EPA would not 

have access to these “inputs to equations” data elements. 

Any such sSources subject to multiple subparts under Part 

98 would be required to use the tool for only those subparts 

 

4

 Please see section III.A.3 of this preamble for a discussion on which 

“inputs to equations” data elements the EPA is proposing that the reporting 

requirements be removed. 
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listed in Table 2 of this preamble, as discussed in the 

following section. 

1. Detailed Description of Inputs Verification Tool.

The EPA’s current verification approach consists of 

electronic verification checks followed by direct follow-up with 

facilities. For subparts where the reporting of inputs to 

emission equations has been deferred until 2015, these checks 

have been conducted using reported data other than inputs to 

emission equations (the reporting of which was deferred). For 

“supplier” subparts5

 (and starting in reporting year 2012 for 

subparts with inputs to emission equations that were deferred 

until 2013), these checks have been conducted using reported 

data that include the data needed to calculate outputs of the 

equations. Reporters under the supplier subparts have been 

entering into e-GGRT the data needed to calculate the annual GHG 

quantities. For reporters under the direct emitter subparts 

listed in Table 2 of this preamble that are using “inputs to 

equations” data elements to calculate reported GHGs, the EPA is 

proposing to use an approach similar to that currently used for 

the supplier subparts, where “inputs to equations” data elements 

would be entered into the inputs verification tool within e-GGRT 

 

5

 Supplier subparts (subparts LL through PP of Part 98) apply to fossil fuel 

suppliers and industrial gas suppliers. The e-GGRT system currently calculates 

equation outputs for suppliers using reported equations inputs. Subpart MM 

reporters began using e-GGRT for reporting in Reporting Year 2012. 

Comment [A7]: Can EPA provide the 

code for this tool in the docket, 

so public commenters can review it 

to make sure no inputs are retained 

by EPA? 

EPA: Yes, we will be adding memo to 

the docket. Please see the 

reference to the memo at the end of 

the paragraph.
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and used to calculate the annual GHG emission values and verify 

these emission values. The difference, however, is that these 

“inputs to equations” data elements would be entered into this 

new inputs verification tool within e-GGRT and would not be 

reported to the EPA. 

To access the inputs verification tool, reporters would log 

into e-GGRT. They would enter data elements required for the 

annual report as well as their “inputs to equations” data 

elements. The tool would operate securely within e-GGRT, as a 

transient process, which means that “inputs to equations” data 

elements (for which the EPA is proposing that the reporting 

requirement be removed) entered into the tool would be 

temporarily saved in the tool while the reporter is actively 

using the tool, but would not be persisted (i.e., saved) within 

the e-GGRT database. The “inputs to equations” data elements 

would be discarded when the user’s session with e-GGRT ends. 

Refer to the memorandum “Technical Approach and Design for 

Inputs Verification Tool” (refer to Docket ID No. EPA–HQ–OAR–

2010-0929) for a detailed description of EPA’s technical 

approach and design for the inputs verification tool. The 

memorandum describes how the inputs verification tool would use 

entered data only during the reporters’ e-GGRT session and would 

delete all records of entered data when the reporters exits the 

system. 
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If the reporter exits the inputs verification tool prior to 

completing data entry or submitting their annual report, the 

tool would generate a file of entered “inputs to equations” data 

elements, and allow the reporter to download the file. This file 

could then be uploaded into the tool when the reporter next uses 

the tool to continue with data entry for the same reporting 

year. This would avoid facilities from needing to re-enter 

“inputs to equations” data elements that were entered in 

previous e-GGRT sessions. 

After the reporter enters the “inputs to equations” data 

elements into the inputs verification tool, the tool would 

calculate the annual GHG emissions values. The tool would use 

the following information in calculating these values: (1) 

“inputs to equations” data elements (for which reporting under 

this action is proposed to be removed) entered into the tool, 

(2) “inputs to equations” data elements entered into e-GGRT (not 

into the inputs verification tool) (refer to Section III.A.3 of 

this preamble for a discussion of the “inputs to equations” data 

elements that would still be reported under this proposal), (3) 

information entered into e-GGRT identifying which Part 98 

calculation method was selected (if applicable), and (4) the 

selected Part 98 calculation method. Once the annual GHG 

emissions values are calculated, the values would be pre-filled 

into the appropriate reporting fields within e-GGRT. Reporters 
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would then have the opportunity to override the annual GHG 

emissions values calculated by the tool with their own 

calculated value. If the reporter chose to override the 

calculated value, this would be reflected in the verification 

summary. 

Prior to annual report submittal, the inputs verification 

tool would conduct a series of verification checks, including 

the following: 

 Verification checks on the annual GHG emission values 

calculated by the inputs verification tool. As mentioned 

above, reporters would have the opportunity to override and 

revise the value calculated by the tool; however should 

this occur, the tool would note a discrepancy, which would 

prompt the EPA for further review after the reporter 

submits the annual report. 

 Verification checks on entered “inputs to equations” data 

elements. For example, the tool would check: (1) whether 

all required data were entered; (2) whether entered “inputs 

to equations” data element values are within the expected 

ranges for the data elements; and (3) whether expected 

relationships exist between certain “inputs to equations” 

data elements and certain other reported data elements 

(e.g., process raw material or throughput data that are not 

“inputs to equations” data elements). 

Some of these checks would be conducted as the reporter 

enters “inputs to equations” data elements (i.e., using “realtime” checking), and other checks would be conducted after the 

reporter has entered all “inputs to equations” data elements, 

because some algorithms may compare certain “inputs to 

equations” data elements (e.g., production quantity) to GHG 

emission values at the subpart or facility level. 
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Also, prior to submittal of the annual report, the inputs 

verification tool would generate a verification summary 

containing the results of the verification checks. The 

verification summary would specify whether any potential errors, 

as described above, were identified, without specifying any 

information about the “inputs to equations” data elements. The 

reporter would have an opportunity to review the verification 

summary and make necessary revisions to the entered “inputs to 

equations” data elements and the reported data elements. 

For example, a facility subject to subpart G that 

manufactures ammonia using liquid and solid feedstocks is 

currently required under 40 CFR 98.76(b)(1) to report annual CO2

process emissions for each ammonia manufacturing unit. 

Currently, the reporter calculates this reported annual GHG 

emissions value outside of e-GGRT (e.g., using a calculator or 

computer software), using Equations G-2, G-3, and G-4 of Part 

98, and monthly values for the following “inputs to equations” 

data elements: quantity of liquid feedstock, quantity of solid 

feedstock, carbon content value for liquid feedstock, and carbon 

content value for solid feedstock. We are proposing that the 

reporter instead calculate this reported annual GHG emissions 

value using the inputs verification tool, which not only would 

use the same equations and data for calculation, but would also 

conduct verification checks, as follows: 
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 The reporter would enter all 48 “inputs to equations” data 

elements” into the inputs verification tool (i.e., monthly 

values for all four “inputs to equations” data elements). 

 The reporter would use the inputs verification tool to 

calculate annual CO2 process emissions. In calculating this 

value, the tool would use Equations G-2, G-3, and G-4 of 

Part 98 and the 48 “inputs to equations” data element 

entries. 

 Once the annual CO2 process emissions value is calculated, 

the inputs verification tool would automatically conduct 

verification checks on the 48 entered “inputs to equations” 

data elements. For example, the tool might conduct the 

following checks: 

 Real-time checks that all 48 “inputs to equations” data 

elements were entered. 

 Real-time checks that each of the 12 entered values for 

carbon content of liquid feedstock is within the expected 

range for carbon content of liquid feedstock (based on 

industry-wide data). The tool would conduct similar 

comparisons for the 12 entered “inputs to equations” data 

elements for the carbon content value for solid feedstock. 

 Run an algorithm check comparing each of the 12 entered 

values of the quantity of the liquid feedstock to all 

monthly values entered for the year, to determine if 

individual values are within an expected range established 

using all 12 values. The tool would conduct similar 

comparisons for the 12 entered “inputs to equations” data 

elements for the quantity of solid feedstock. This type of 

check would be conducted after the reporter has entered all 

“inputs to equations” data elements. 

 Prior to annual report submittal, the inputs verification 

tool would automatically generate a verification summary, 

which would flag any potential errors, providing an 

opportunity for the reporter to review the verification 

summary and revise entered data. The verification summary 

would note if the reporter has overridden any of the annual 

GHG emissions values calculated by the tool. After the 

reporter completes all revisions to data entries, the tool 

would automatically re-generate the verification summary 

prior to annual report submittal. The EPA would access the 

verification summary (i.e., the same final summary viewed 

by the reporter) following annual report submittal and 

certification. 
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 The inputs verification tool would also generate a file 

listing the entered “inputs to equations” data elements 

(for which the EPA is proposing to remove the reporting 

requirements) to be kept by the reporter and maintained as 

a record in a format currently allowed under Part 98 (see 

40 CFR 98.3(g), subpart A). Refer to Section III.B of this 

preamble for further discussion of this proposed amendment 

and the EPA’s rationale for requiring this record. 

The EPA has developed a “pilot” inputs verification tool 

for one subpart, subpart C, which will be posted at 

http://www.epa.gov/ghgreporting/reporters/training/rulepilot.htm

l, to demonstrate how the tool would work within e-GGRT, as well 

as the types of verification checks that would be conducted. The 

EPA seeks comment on the usability of the tool as well as its 

ability to conduct verification on the “inputs to equations” 

data elements. 

2. Rationale Supporting the Use of the Inputs Verification Tool 

as an Alternative to Collecting Certain “Inputs to Equations” 

Data Elements for Verification Purposes.

In the October 30, 2009 final rule (74 FR 56282 – 56283), 

the EPA described its verification approach as the following 

two-step process: 

 Initial automated review of reported data, using an 

electronic data quality assurance program built into the 

data system, for use by reporters and the EPA to help 

assure the completeness and accuracy of data. 

 Based on the initial review results, follow up with 

facilities regarding potential errors, discrepancies, or 

questions, including on-site audits. 
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The EPA is currently using the two-step verification 

process of automated verification checks followed by direct 

follow-up with facilities to verify data currently reported via 

e-GGRT. The EPA is proposing to supplement the current 

verification approach for facilities reporting under the 

subparts listed in Table 2 of this preamble using the additional 

checks that would be conducted by the inputs verification tool. 

During the first 3 years of the Greenhouse Gas Reporting Program 

(GHGRP), the EPA has had success developing and using an 

electronic reporting and verification system for all subparts 

reporting under the program. During reporting year 2010, the EPA 

developed approximately 1,400 electronic verification checks to 

verify reported data. Based on these verification checks, the 

EPA followed up with approximately 2,360 of the approximately 

6,700 facilities that reported in reporting year 2010, resulting 

in approximately 2,300 facilities resolving verification issues 

by responding to the EPA and/or resubmitting their annual 

report. In reporting year 2011, the EPA programmed an additional 

1,000 checks into e-GGRT for the subparts that were reporting 

for the second year, expanding the number of checks to 2,400. 

The EPA also programmed into e-GGRT, for 2011, approximately 

1,300 checks for the newly-reporting subparts. During reporting 

year 2011, the EPA followed up with approximately 3,440 of the 

approximately 8,000 facilities that reported, resulting in 
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Page 43 of 133 

approximately 3,000 facilities resolving their verification 

issues. 

For example, for subpart H, the EPA verifies reported GHG 

emissions data using: (1) reported cement production data and 

(2) publicly available industry data on GHG emissions. Using 

these data, the EPA has established ranges of acceptable 

production and emission values and set up algorithm checks for 

reported GHG emission values. 

The electronic checks used by the GHGRP have served as a 

means for the EPA to verify reported data while minimizing the 

burden on both the EPA and reporters. Electronic verification is 

a critical first step to ensuring the completeness and accuracy 

of reported data and reducing the costs of compliance 

monitoring. 

The inputs verification tool described in Section III.A.1 

of this preamble utilizes the same approach that the EPA 

currently uses for calculating and verifying data submitted for 

supplier subparts (and starting in reporting year 2012, inputs 

to emission equations whose reporting deadline was deferred 

until 2013), except that e-GGRT would not retain the “inputs to 

equations” data elements entered into the tool. Once the annual 

report is submitted, the EPA would review the verification 

summary generated by the inputs verification tool, along with 

verification summaries that are currently generated using data 
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currently collected through the annual report. By requiring use 

of the inputs verification tool, the EPA would have the 

additional certainty that reported annual GHG emissions values 

either were calculated correctly (because the values calculated 

by the tool were submitted to the EPA) or that the EPA would be 

made aware that there were discrepancies between values 

calculated by the tool and values submitted to the EPA. That 

additional certainty, combined with the additional information 

provided by the range and algorithm checks on the “inputs to 

equations” data elements themselves, would provide the EPA with 

information necessary to conduct further verification once the 

annual report is submitted. 

If a potential error with one of the “inputs to equations” 

data elements or with an annual GHG emissions value were 

identified in the verification summary generated by the inputs 

verification tool, the EPA would likely follow up with the 

facility to determine whether an actual error has occurred. 

While this verification approach may result in more direct 

follow-up with facilities than if the “inputs to equations” data 

elements were submitted to the EPA, this approach would 

facilitate verification by identifying potential errors and 

minimizing the number of errors before annual reports are 

submitted. In addition, as discussed elsewhere in the preamble, 

the EPA is retaining the reporting requirement for “inputs to 
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Page 45 of 133 

equations” data elements for which our four-step evaluation did 

not identify disclosure concerns and is proposing to require 

reporting of additional new data elements to assist the EPA’s 

verification effort. These “inputs to equations” data elements 

for which reporting would be retained and these proposed new 

reported data elements would allow the EPA to conduct additional 

verification and minimize the number of follow-ups with 

facilities. Lastly, for the reasons specified in section III.B 

of this preamble, the EPA is proposing that facilities retain 

records for 5 years, which would allow the EPA time to perform 

any necessary follow-up with reporters. For the reasons stated 

above, the EPA has determined that the proposed verification 

approach would be adequate to verify the reported emissions for 

reporters using “inputs to equations” data elements to calculate 

reported GHGs under the subparts identified in Table 2 of this 

preamble and is a reasonable alternative to collecting “inputs 

to equations” data elements for which we have identified 

disclosure concerns. 

The EPA is proposing to require the use of the inputs 

verification tool starting in reporting year 2014. The inputs 

verification tool is designed to be used concurrently with 

annual reporting by facilities. By the time the EPA takes any 

final action on this proposed amendment, reporters would have 

likely submitted annual reports for reporting years 2010 through 

Comment [A8]: Please explain why the 

record retention time needs to be 

lengthened. 

EPA: Revised to refer readers to 

section of preamble with rationale 

is described. 
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2013. While additional verification could be conducted on the 

past years’ data if the inputs verification tool were used for 

these years, given that most of the data would likely already 

have been published and that the use of best available 

monitoring methods (BAMM) for these sectors is relatively low 

during these years, the EPA has determined that the added 

benefit does not outweigh the burden that would be required for 

facilities to use the inputs verification tool for years prior 

to reporting year 2014. 

3. Reporting of 435 “Inputs to Equations” Data Elements Would 

Not Be Necessary With the Proposed Verification Approach.

The EPA is proposing to remove the reporting requirement 

for 435 “inputs to equations” data elements that are in the 

subparts listed in Table 2 of this preamble. With the proposed 

alternative verification approach described in Section III.A.2 

of this preamble, the EPA would no longer need to rely on the 

collection of these “inputs to equations” data elements to 

verify emissions under those subparts. Not having these data 

elements reported would address concerns relative to potential 

disclosure of these data elements.6

 These 435 data elements are 

specified in Table 1 of the memorandum “List of Inputs to 

 

6

Wwe are proposing to remove the reporting requirement for certain “inputs to 

equations” data elements because, while there is not a disclosure concern,

wethe EPA determined that these data elements would not be useful for data 

verification and would not inform future GHG policy development in the 

absence of other data elements for which we are proposing to remove the 

reporting requirement.
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Equations Data Elements Proposed Not To Be Reported” (refer to 

Docket ID No. EPA–HQ–OAR–2010-0929). 

The 435 “inputs to equations” data elements for which the 

EPA is proposing to remove the reporting requirement must be 

maintained on-site as records. Because Part 98 already requires 

these “inputs to equations” data elements to be kept as records 

(see 98.3(g)(2), which states that “the data used to calculate 

the GHG emissions for each unit, operation, process, and 

activity, categorized by fuel or material type” must be kept as 

records), the EPA is not proposing in this action to specifymove

each of the 435 “inputs to equations” data elements into the 

recordkeeping sectionrequirements of each subpart. The EPA 

considered whether specifyingmoving each of these “inputs to 

equations” data elements into the recordkeeping 

sectionsrequirements of each subpart would improve the clarity 

of the specific records that would be required to be retained. 

Because the EPA is proposing that the “inputs to equations” data 

elements that would not be reported must be kept as records in 

the format generated by the inputs verification tool (i.e., file 

for downloading or printing), the EPA determined that the data 

that must be kept as records would be sufficiently clear. The 

EPA seeks comment on whether additional specificity within the 

recordkeeping requirements of each subpart would improve the 
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Page 48 of 133 

clarity of the specific records that are required to be 

retained. 

For the purposes of clarifying which data elements must be 

reported for previous reporting years 2010 through 2013, we are 

proposing to revise Table A-7 of Part 98 to remove all 435 data 

elements for which reporting is proposed to be removed. To be 

consistent with a separate action that is proposing to remove 

additional “inputs to equations” data elements from Part 98 (40 

CFR 98.256(o)(6) and (o)(7))), we are also proposing to remove 

these additional data elements from Table A-7. For the EPA’s 

rationale for removing these additional data elements from Part 

98, refer to the preamble to the April 2, 2013 proposal, “2013 

Revisions to the Greenhouse Gas Reporting Rule and Proposed 

Confidentiality Determinations for New or Substantially Revised 

Data Elements,” (78 FR 19802, April 2, 2013). 

The EPA is retaining reporting of 175153 “inputs to 

equations” data elements.7 Refer to Table 2 in the memorandum 

“List of ‘Inputs to Equations’ Data Elements Proposed Not To Be 

Reported” (refer to Docket ID No. EPA–HQ–OAR–2010-0929) for a 

complete list of these 175 data elements. These 175153 “inputs 

 

7

 These 153 175 “inputs to equations” data elements include: (1) nine “inputs 

to equations” data elements in subpart L of part 98 that are not being 

addressed in this rulemaking because they and will be addressed in a separate 

action related to subpart L; and (2) five “inputs to equations” data elements 

in subpart Y of part 98 that are not being addressed in this rulemaking 

because they are being addressed in a separate action related to subpart Y. 

Refer to were proposed in thethe EPA’s April 2, 2013 rulemaking (78 FR 19802) 

for EPA’s proposal that these five inputsto be removed from reporting. 

Comment [A9]: Please explain why the 

five “inputs to equations” in (2) 

of the FN that were proposed to be 

removed are, in fact, being 

retained. The FN should include an 

explanation or point the reader to 

an explanation. 

EPA: Revised to explain that these 

5 inputs are being addressed in a 

separate action. 
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to equations” data elements include certain “inputs to 

equations” data elements for the subparts listed in Table 3 of 

this preamble, as well as all “inputs to equations” data 

elements for subparts C (only for certain combustion units 

connected to a device that delivers power to the local or 

regional electric power grid)8

, W, and II of part 98. For these 

“inputs to equations” data elements, the EPA is not amending 

these reporting requirements and would therefore let the 

deferral of these data elements expire on March 31, 2015. As a 

result, these “inputs to equations” data elements would be 

reported for future reporting years starting with reporting year 

2014, as well as for previous reporting years (i.e., reporting 

years 2010 through 2013). Based on “Step 2” of our evaluation 

described in Section I.B of this preamble, these data elements 

would not raise disclosure concerns. Having these data elements 

reported would allow the EPA to do additional verification, 

including conduct year-to-year comparisons, thereby reducing the 

amount of direct follow-up required with facilities. For the 

reason stated above, collecting these data elements, even in the 

 

8

 Refers to combustion units subject to subpart C meeting the following 

criteria: (1) the combustion unit is connected to a device that has been 

granted access by the Public Utilities Commission to deliver power to the 

local or regional electric power grid (e.g., electricity generators excluding 

generators connected to combustion units subject to subpart D of this part); 

and (2) the combined nameplate capacity (for all such devices at the facility 

excluding generators connected to combustion units subject to subpart D of 

this part)) is greater than or equal to 1 megawatt electric. 
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absence of collecting all “inputs to equations” data elements, 

would aid in the verification process. 

The EPA identified 23 “inputs to equations” data elements 

for which disclosure concerns were not identified based on “Step 

2” of our evaluation; however, the EPA is not retaining these 

reporting requirements. The EPA determined that these 23 data 

elements would not be useful for data verification and would not 

inform future GHG policy development in the absence of other 

“inputs to equations” data elements for which the reporting 

requirement is proposed to be removed under this 

action. Examples of these 23 “inputs to equations” include 

reporting the selected default molar volume conversion factor 

and reporting the units of measure of a site-specific emission 

factor. These “inputs to equations” are identified in the 

memorandum “List of ‘Inputs to Equations’ Data Elements Proposed 

Not To Be Reported” (refer to Docket ID No. EPA–HQ–OAR–2010-

0929). 

Regarding the 175153 retained “inputs to equations” data 

elements, for reporting year 2014 and thereafter, reporters 

would enter the 175153 “inputs to equations” data elements for 

which we are retaining the reporting requirement into e-GGRT. 

Starting in reporting year 2014, the e-GGRT system would retain 

these 175153 data elements as part of the annual report and they 

would be accessible by the EPA once the reporter submits the 
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annual report. In order to ease the burden on facilities, for 

reporting years prior to reporting year 2014, the EPA is 

proposing that these reported “inputs to equations” data 

elements be submitted as part of the reporting year 2014 annual 

report. Specifically, when reporters prepare their reporting 

year 2014 annual report via e-GGRT, they would be required to 

include these “inputs to equations” data elements for reporting 

year 2014 as well as for all applicable previous reporting 

years. The annual report, including these “inputs to equations” 

data elements would be submitted via e-GGRT. This approach would 

prevent facilities from being required to revise, re-certify, 

and re-submit annual reports for reporting years 2010, 2011, 

2012, and 2013. 

The proposed revisions to the current reporting 

requirements would apply to all reporters subject to the 

subparts listed in Table 2 of this preamble, including subpart 

C, and using “inputs to equations” data elements to calculate 

reported GHGs. However, as noted in Table 2, we are not 

proposing to amend the reporting requirements for combustion 

units subject to subpart C that meet the following criteria: (1) 

the combustion unit is connected to a device that has been 

granted access by the Public Utilities Commission to deliver 

power to the local or regional electric power grid (e.g., 

electricity generators excluding generators connected to 
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Page 52 of 133 

combustion units subject to subpart D of this part); and (2) the 

combined nameplate capacity (for all such devices at the 

facility excluding generators connected to combustion units 

subject to subpart D of this part) is greater than or equal to 1 

megawatt electric. The “inputs to equations” data elements for 

these combustion units are among those that did not raise 

disclosure concerns under “Step 2” of our evaluation of the 

“inputs to equations” data elements (refer to Section I.B of 

this preamble for a discussion of the EPA’s four-step 

evaluation). Refer to the memoranda documenting “Step 2” of our 

evaluation, “Evaluation of Competitive Harm From Reporting 2015 

Inputs to Equations” (Docket ID No. EPA–HQ–OAR–2010-0929), for 

further information on the results of the analysis for these 

combustion units. 

Reporters currently reporting emissions for combustion 

units under subpart C have the option to utilize one or more of 

the reporting options under subpart C that allow the grouping of 

stationary combustion units for the purpose of monitoring, 

calculating, and reporting emissions. The EPA recognizes that 

stationary combustion units grouped in these reporting 

configurations could include both combustion units associated 

with devices that can produce electricity (connected to the grid 

and not connected to the grid) and combustion units not 

associated with devices that can produce electricity. In these 
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Page 53 of 133 

cases where combustion units are grouped, the EPA has determined 

that there would be no disclosure concerns with reporting of 

“inputs to equations” data elements for the grouped combustion 

units. In reporting combined data for multiple units including 

those associated with a device capable of producing electricity 

and subject to reporting under this proposed action, no unitspecific data would be revealed. Furthermore, should a facility 

not wish to disclose aggregated data, it would have the option 

to calculate and report emissions using one of the individual 

unit reporting configurations. The EPA seeks comment on this 

conclusion. If you believe that there are any disclosure 

concerns, please provide detailed information about the concern, 

as well as whether reporting on an individual unit basis is a 

feasible reporting option. 

Additionally, the EPA is proposing to revise two paragraphs 

(40 CFR 98.116(e)(6) and 40 CFR 98.186(b)(8)) that reference 

other paragraphs that include “inputs to equations” data 

elements proposed to be removed from Part 98. As a result, we 

are proposing to remove the cross reference while carrying over 

the substantive information in order to maintain the 

requirements in these paragraphs. 

The EPA requests comment on the proposed inputs 

verification tool and verification approach, and the associated 
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revision to the current reporting requirements as described in 

this section. 

B. Proposed Revisions to Recordkeeping Requirements

Given the proposed verification approach described in 

Section III.A of this preamble, the EPA considered whether the 

current record retention period and record format requirements 

would be sufficient to allow the EPA to perform data 

verification. We considered: 

 The time we would need to follow up with reporters to 

further verify reported GHG emissions. 

 The desirability of retaining multiple years of data 

records to allow for appropriate assessment of compliance 

and for analyses of trends for policy analysis purposes. 

 The format of records, and whether the current format would 

be adequate for our verification process. For example, we 

considered whether records of “inputs to equations” data 

elements contained in multiple separate documents (as 

currently allowed under Part 98) would allow an EPA 

inspector to efficiently analyze the consistency of the 

data elements and use the data elements to perform 

calculations to confirm reported GHG emissions. 

Because there may be more direct follow-up activities under 

this alternative verification approach, we are proposing to 

extend the record retention period from 3 to 5 years. We have 

determined that 5 years is reasonable given the large number of 

reporters under the subparts identified in Table 2 of this 

preamble (over 2,000 facilities) and the likely increase in 

follow-up activities. It would be important that relevant 

records are available to the EPA for follow-up activities with 
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facilities, including on-site audits if necessary, regarding 

potential errors, discrepancies, or questions. Should an EPA 

inspector visit a facility, it would be important to be able to 

examine not only the current year’s records but those from 

previous years as well, because previous years’ data would 

provide year-to-year comparisons, which are useful for verifying 

the current year’s data. A 5-year record retention period would 

ensure the availability of relevant records for the follow-up 

activities described above. The EPA is proposing that this 5-

year record retention requirement begin with records for 

reporting year 2010, as discussed in Section III.A.1 of this 

preamble. 

For reporters subject to using the proposed inputs 

verification tool, tThe EPA is proposing to extend the record 

retention period not only for the subparts listed in Table 2 of 

the preamble, but also for other subparts that apply to 

reporters subject to a subpart in Table 2. Under this proposal, 

any such facility subject to both a subpart listed in Table 2 of 

this preamble and a subpart not listed in Table 2 would be 

required to maintain all records required under both subparts 

for a period of 5 years. For example, if a facility is required 

to use the proposed inputs verification tool report under both 

subpart C (in Table 2) and to report under subpart HH (not in 

Table 2), the facility would be required to maintain all records 

Comment [A10]: What’s the penalty 

for misreporting data or not 

retaining these records for the 

full 5 years? 

EPA: This was discussed separately. 
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required under both subparts for 5 years. The EPA is proposing 

these provisions for two reasons. First, the EPA determined that 

during a site visit, if questions arise regarding the accuracy 

of an “inputs to equations” data element, it may be necessary to 

examine other non-input recordkeeping information, such as a 

monitoring plan or recordkeeping information in a different 

subpart, in order to fully investigate the accuracy of the data. 

It is necessary to ensure that all data necessary for 

verification are available, and this proposed 5-year record 

retention period would provide better assurance of on-site data 

availability. Second, the EPA determined that maintaining 

multiple sets of data records according to different record 

retention periods could possibly cause confusion and result in 

recordkeeping errors. Providing the same record retention 

duration for all subparts, as proposed, would simplify 

recordkeeping and thereby minimize the chance for recordkeeping 

errors. 

In addition, the EPA is proposing revisions to the 

recordkeeping format for “inputs to equations” data elements. 

Currently, reporters have the option to maintain records of 

their “inputs to equations” data elements in one or more 

electronic or hard copy files. The proposed record format 

revision would require reporters to maintain an electronic or 

hard copy of the single file generated by the proposed inputs 
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verification tool, listing all “inputs to equations” data 

elements entered into the tool. This proposed record format 

change would ensure that the EPA could readily access these 

data, enabling the EPA to quickly and efficiently perform 

calculations and data checks during site visits. All other 

records required under Part 98 would be maintained in the format 

currently required under Part 98. In combination with the 

proposed reporting requirements discussed in Sections III.A and 

C of this preamble, these proposed recordkeeping requirements 

would allow the EPA to adequately verify certain reported 

emissions without implicating the disclosure concerns discussed 

in the memorandum “Evaluation of Competitive Harm For Reporting 

2015 Inputs to Equations” 

(refer to Docket ID No. EPA–HQ–OAR–2010-0929). 

In amending 40 CFR part 98, subpart A to add these 

recordkeeping requirements, we are also correcting an error in 

the current version of 40 CFR 98.3(g). In a previous action 

amending this paragraph (76 FR 73866, November 29, 2011), our 

intension intention was to amend the second sentence of the 

paragraph regarding record retention duration; however, the 

third sentence regarding record format was inadvertently 

amended. To correct this error, we are proposing to remove the 

second sentence of 40 CFR 98.3(g) and to reinstate the previous 

third sentence of 40 CFR 98.3(g) (regarding format of records). 
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We seek comment on whether 5 years is the appropriate 

timeframe for maintaining records for facilities required to use 

the proposed inputs verification tool underwith a subpart listed 

in Table 2 of this preamble. In addition, we seek comment on the 

proposal to extend the record retention period for these 

reporters, not only for the subparts listed in Table 2 of the 

preamble, but also for other subparts that apply to these 

reporters subject to a subpart in Table 2. 

C. Proposed Requirement to Report Additional Data

As part of our proposal to no longer require reporting of 

certain “inputs to equations” data elements, we are proposing to 

require that certain reporters using the proposed inputs 

verification tool also report the new data elements specified in 

Table 4 of this preamble. These additional data elements would 

allow the EPA to perform additional verification checks and 

minimize the number of follow-up activities. These data elements 

are quantities that provide information on the activity level at 

the facility, emission factors used, characteristics of carboncontaining streams, and other process information that would 

provide key information for verification, including confirming 

that emissions are appropriate for a given activity-level and 

estimating expected emissions based on data provided. These new 

data reporting elements would also enable the EPA to better 

understand the following aspects concerning reporters in order 
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Page 59 of 133 

to inform future GHG policy:9

 (1) the GHG emission profile for 

the reporter; (2) the relationship of GHG emissions to 

production output or raw material input within the industry 

sector; and (3) the factors influencing GHG emissions. 

The EPA is proposing to add six new equations (Equations Q9 through Q-14 of part 98) to subpart Q to specify how to 

calculate and report each of the six new data elements proposed 

to be added to subpart Q of part 98. Table 4 of this preamble 

specifies which equation number correlates with each new 

proposed data element. Refer to the proposed amendments for 

subpart Q for the proposed equations. 

The EPA is proposing confidentiality determinations for 

these proposed new data elements. Those new data elements 

determined to be confidential business information in a final 

rule would be afforded confidential treatment. Refer to the 

following Section IV of this preamble for the EPA’s proposed 

confidentiality determinations for the proposed new data 

elements. 

IV. Confidentiality Determination for Proposed New Data Elements 

to be Reported 

The EPA is proposing confidentiality determinations for 

each new data element listed in Table 4 of this preamble. To 

 

9

 The EPA has previously stated that a goal of collecting data under the GHGRP 

is to inform future GHG policy (refer to the April 10, 2009 proposed rule (74 

FR 16455). 
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make these determinations, the EPA proposes to use the same 

approach that the EPA previously used for the 2011 final CBI 

rule (76 FR 30782, May 26, 2011). Specifically, the EPA is 

proposing to assign each new data element listed in Table 4 of 

this preamble to one of 11 direct emitter data categories, based 

on the type and characteristics of the data element. For a 

description of each data category and the type and 

characteristics of data elements assigned to each category, see 

Sections II.C and II.D of the July 7, 2010 CBI proposal preamble 

(75 FR 39106 – 39130). 

Based on its evaluation of the new data elements, the EPA 

is proposing that each new data element be assigned to one of 

the four following direct emitter data categories: 

 Production/Throughput Data that are Not Inputs to Emission 

Equations. 

 Raw Materials Consumed that are Not Inputs to Emission 

Equations. 

 Unit/Process “Static” Characteristics that are Not Inputs 

to Emission Equations. 

 Unit/ Process Operating Characteristics that are Not Inputs 

to Emission Equations. 

In the 2011 final CBI rule (May 26, 2011, 76 FR 30782), the 

EPA made categorical determinations that all data elements 

assigned to the “Production/Throughput Data that are Not Inputs 

to Emission Equations” and “Raw Materials Consumed that are Not 

Inputs to Emission Equations” data categories are entitled to 
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confidential treatment because the data do not meet the 

definition of “emission data” in 40 CFR 2.301(a)(2)(i) and they 

are CBI. 

The EPA is proposing that seven new data elements be 

assigned to the “Production/Throughput Data that are Not Inputs 

to Emission Equations” data category and 10 new data elements be 

assigned to the “Raw Materials Consumed that are Not Inputs to 

Emission Equations” data category, as shown in Table 5 of this 

preamble, thereby applying the categorical confidentiality 

determinations made for these categories in the 2011 final CBI 

rule (i.e., they are CBI) to the proposed new reporting elements 

assigned to these categories. This proposal is not changing, nor 

soliciting comment on, the categorical confidentiality 

determination for these two data categories. Should the EPA 

finalize the category assignment for these data elements, all 

new data elements assigned to these categories would be 

considered to be entitled to confidential treatment. 

Table 5. Data Elements Proposed to Be Assigned To the 

“Production/Throughput Data that are Not Inputs to Emission 

Equations” and “Raw Materials Consumed that are Not Inputs to 

Emission Equations” Data Categories 

Subpart Proposed Citation Data Element

“Production/Throughput Data that are Not Inputs to Emission 

Equations” Data Category 

G - Ammonia 

Production 

40 CFR 98.76(c)(14) Annual ammonia 

production (metric 

tons). 

40 CFR 98.76(d)(15) Annual methanol 

production (metric 
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Subpart Proposed Citation Data Element 

tons), if this 

quantity is not 

reported under 

subpart X of Part 98. 

H - Cement Kilns 40 CFR 98.86(b)(16) Annual clinker 

production (metric 

tons). 

P – Hydrogen 

Production 

40 CFR 98.166(e) Annual methanol 

production (metric 

tons), if this 

quantity is not 

reported under 

subpart X of Part 98. 

S - Lime 

Manufacturing 

40 CFR 98.196(b)(18) Annual quantity 

(metric tons) of lime 

product sold, by 

type. 

X – Petrochemical 40 CFR 98.246(a)(13) 

and (b)(10) 

If using the mass 

balance method or 

CEMS method to 

calculate GHG 

emissions: Name and 

annual quantity (in 

metric tons) of each 

carbon-containing coproduct included in 

Equations X-1, X-2 

and X-3. 

AA - Pulp and 

Paper 

40 CFR 98.276(l)(1) For each pulp mill 

lime kiln: 

Quantity of calcium 

oxide (CaO) produced 

(metric tons). 

“Raw Materials Consumed that are Not Inputs to Emission 

Equations” Data Category 

E - Adipic Acid 

Production 

40 CFR 98.56(m) Annual quantity of 

cyclohexane fed to 

all production lines, 

combined (metric 

tons). 

P - Hydrogen 

Production 

40 CFR 98.166(b)(7) Name and annual 

quantity (metric 

tons) of each carboncontaining fuel and 

feedstock. 
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Subpart Proposed Citation Data Element 

Q - Iron and Steel 40 CFR 98.176(i)(1) If you use the carbon 

mass balance method 

in 40 CFR 

98.173(b)(1) to 

determine CO2

emissions: The annual 

mass (metric tons) of 

all gaseous, liquid, 

and solid fuels 

(combined) used in 

process units 

specified in 

Equations Q-1 through 

Q-7, calculated as 

specified in a new 

Equation Q-9 in the 

proposed rule 

amendments. Do not 

include fuel used in 

a stationary 

combustion unit where 

emissions are 

reported under 

subpart C of this 

part. 

40 CFR 98.176(i)(2) If you use the carbon 

mass balance method 

in 40 CFR 

98.173(b)(1) to 

determine CO2

emissions: The annual 

mass (metric tons) of 

all non-fuel material 

inputs (combined) 

specified in 

Equations Q-1 through 

Q-7, calculated as 

specified in a new 

Equation Q-10 in the 

proposed rule 

amendments. 

40 CFR 98.176(i)(3) If you use the carbon 

mass balance method 

in 40 CFR 

98.173(b)(1) to 

determine CO2
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Subpart Proposed Citation Data Element 

emissions: The annual 

mass (metric tons) of 

all solid and liquid 

products and 

byproducts (combined) 

specified in 

Equations Q-1 through 

Q-7, calculated as 

specified in a new 

Equation Q-11 in the 

proposed rule 

amendments. 

40 CFR 98.176(i)(4) If you use the carbon 

mass balance method 

in 40 CFR 

98.173(b)(1) to 

determine CO2

emissions: The 

weighted average 

carbon content of all 

gaseous, liquid, and 

solid fuels 

(combined) included 

in Equation Q-9, 

calculated as 

specified in a new 

Equation Q-12 in the 

proposed rule 

amendments. 

40 CFR 98.176(i)(5) If you use the carbon 

mass balance method 

in 40 CFR 

98.173(b)(1) to 

determine CO2

emissions: The 

weighted average 

carbon content of all 

non-fuel inputs to 

all furnaces 

(combined) included 

in Equation Q-10, 

calculated as 

specified in a new 

Equation Q-13 in the 

proposed rule 

amendments. 
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Page 65 of 133 

Subpart Proposed Citation Data Element 

40 CFR 98.176(i)(6) If you use the carbon 

mass balance method 

in 40 CFR 

98.173(b)(1) to 

determine CO2

emissions: The 

weighted average 

carbon content of all 

solid and liquid 

products and 

byproducts from all 

furnaces (combined) 

included in a new 

Equation Q-11 in the 

proposed rule 

amendments, 

calculated as 

specified in new 

Equation Q-14 in the 

proposed rule 

amendments. 

X – Petrochemical 40 CFR 98.246(a)(12) 

and (b)(9) 

If using the mass 

balance method or 

CEMS method to 

calculate GHG 

emissions: Name and 

annual quantity (in 

metric tons) of each 

carbon-containing 

feedstock included in 

Equations X-1, X-2 

and X-3. 

AA - Pulp and 

Paper 

40 CFR 98.276(m)(1) For each chemical 

recovery furnace and 

chemical recovery 

combustion unit for 

which you are not 

using Equation C-2c 

to calculate CO2

emissions: Annual 

mass of steam 

generated (lb steam), 

individually for each 

fossil fuel type and 

for spent liquor 

solids. 
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The EPA is proposing to assign eight proposed new data 

elements to the “Unit Process Operating Characteristics that are 

Not Inputs to Emission Equations” category and one proposed new 

data element to the “Unit/Process Static Characteristics that 

are Not Inputs to Emission Equations” category. In the 2011 

final CBI rule, the EPA determined that the data elements in 

these categories are not “emission data” (as defined at 40 CFR 

2.301(a)(2)(i)). However, instead of categorical determinations, 

the EPA made confidentiality determinations for individual data 

elements assigned to these two categories. In proposing these 

determinations, the EPA considered the confidentiality criteria 

at 40 CFR 2.208, in particular whether release of the data is 

likely to cause substantial harm to the business’s competitive 

position. See 40 CFR 2.208(e)(1). The EPA is therefore following 

the same approach in this action for the proposed new reporting 

elements assigned to these two categories. 

Table 6 of this preamble lists the data elements the EPA 

proposes to assign to these two data categories and presents the 

EPA’s rationale for proposing to determine that each does or 

does not qualify as CBI under CAA section 114(c). 
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Table 6. Proposed Confidentiality Determinations for Proposed 

New Data Elements Assigned to the “Unit/Process Operating 

Characteristics That Are Not Inputs to Emission Equations” and 

“Unit/Process ‘Static’ Characteristics that Are Not Inputs to 

Emission Equations” Data Categories 

Subpart Citation 

Data 

Element 

Confidentia

lity 

Determinati

on 

Proposed Rationale for 

Confidentiality 

Determination 

“Unit/Process Operating Characteristics That Are Not Inputs to 

Emission Equations” Data Category

E – 

Adipic 

Acid 

Producti

on 

40 CFR 

98.56(n) 

Annual 

percent 

N2O 

emission 

reduction 

for all 

productio

n units 

combined. 

Not CBI The annual facility 

percent N2O reduction 

could not be used to 

calculate adipic acid 

production. The level 

of N2O reductions 

varies by the type of 

abatement technology, 

the environment in 

which the abatement 

technology is 

operating, the age of 

the abatement 

technology, the age of 

the catalyst used, and 

the maintenance level 

of the abatement 

technology. 

H - 

Cement 

Kilns 

40 CFR 

98.86(b)(1

7) 

Annual 

average 

clinker 

CO2

emission 

factor 

for the 

facility, 

averaged 

across 

all kilns 

(metric 

tons 

CO2/metri

c ton 

clinker 

produced)

. 

CBI This data element could 

be used to back 

calculate a facility’s 

clinker production 

data, which would 

result in competitive 

disadvantage. 

40 CFR 

98.86(b)(1

8) 

Annual 

average 

cement 

CBI This data element could 

provide information 

about the efficiency of 
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Subpart Citation 

Data 

Element 

Confidentia

lity 

Determinati

on 

Proposed Rationale for 

Confidentiality 

Determination 

kiln dust 

(CKD) CO2

emission 

factor 

for the 

facility, 

averaged 

across 

all kilns 

(metric 

tons 

CO2/metri

c ton CKD 

produced)

. 

the operation, which 

would result in 

competitive 

disadvantage. 

V – 

Nitric 

Acid 

Producti

on 

40 CFR 

98.226(q) 

Annual 

percent 

N2O 

emission 

reduction 

for all 

productio

n units 

combined. 

Not CBI The annual facility 

percent N2O reduction 

for all nitric acid 

production trains 

combined could not be 

used to calculate the 

nitric acid production 

value for any 

individual facility. 

The level of N2O 

reductions for each 

individual facility 

varies by the type of 

abatement technology, 

the environment in 

which the abatement 

technology is 

operating, the age of 

the abatement 

technology, the age of 

the catalyst used, and 

the maintenance level 

of the abatement 

technology. 

Additionally, facilitylevel N2O emission 

reduction information 

is already publicly 

available (see docket 

number EPA-HQ-OAR-2010-

0750 and 

http://www.climateactio
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Subpart Citation 

Data 

Element 

Confidentia

lity 

Determinati

on 

Proposed Rationale for 

Confidentiality 

Determination 

nreserve.org). 

Y – 

Petroleu

m 

Refineri

es 

40 CFR 

98.256(e)(

11)(i) 

Annual 

quantity 

of flare 

gas 

combusted 

(in MMscf 

per year) 

(only 

when 

using 

Equation 

Y-3). 

Not CBI This data element does 

not reveal (nor could 

be used to calculate) 

details regarding 

product 

characteristics, actual 

production data, or 

operating efficiency. 

It does not provide 

information that would 

allow competitors to 

infer market share, 

production costs, or 

pricing structures and 

thus gain a competitive 

advantage. The EPA 

applied the same 

rationale in the 2010 

proposed and 2011 final 

CBI rules (75 FR 39113 

and 76 FR 30803 - 

30806), in support of a 

non-CBI determination 

for reporting of the 

following same data 

element currently 

required to be reported 

if a different equation 

(Equation Y-1a) is 

used: annual volume of 

flare gas combusted 

(scf/year) under 40 CFR 

98.256(e)(6). 

40 CFR 

98.256(e)(

11)(ii) 

Annual 

average 

molecular 

weight of 

flare gas 

combusted 

(in mmBtu 

per 

MMscf) 

(only 

when 

Not CBI This data element does 

not reveal (nor could 

be used to calculate) 

details regarding 

product 

characteristics, actual 

production data, or 

operating efficiency. 

It does not provide 

information that would 

allow competitors to 
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Subpart Citation 

Data 

Element 

Confidentia

lity 

Determinati

on 

Proposed Rationale for 

Confidentiality 

Determination 

using 

Equation 

Y-3). 

infer market share, 

production costs, or 

pricing structures and 

thus gain a competitive 

advantage. The EPA 

applied the same 

rationale in the 2010 

proposed and 2011 final 

CBI rules (75 FR 39113 

76 FR 30803 - 30806), 

in support of a non-CBI 

determination for 

reporting of the 

following same data 

element currently 

required to be reported 

if a different equation 

(Equation Y-1a) is 

used: annual average 

molecular weight of the 

flare gas (kg/kg-mole) 

under 40 CFR 

98.256(e)(6). 

40 CFR 

98.256(e)(

11)(iii) 

Annual 

average 

carbon 

content 

of flare 

gas 

combusted 

(expresse

d as a 

decimal 

fraction)

(only 

when 

using 

Equation 

Y-3). 

Not CBI This data element does 

not reveal (nor could 

be used to calculate) 

details regarding 

product 

characteristics, actual 

production data, or 

operating efficiency. 

It does not provide 

information that would 

allow competitors to 

infer market share, 

production costs, or 

pricing structures and 

thus gain a competitive 

advantage. The EPA 

applied the same 

rationale in the 2010 

proposed and 2011 final 

CBI rules (75 FR 39113 

76 FR 30803 - 30806), 

in support of a non-CBI 

determination for 

reporting of the 
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Subpart Citation 

Data 

Element 

Confidentia

lity 

Determinati

on 

Proposed Rationale for 

Confidentiality 

Determination 

following same data 

element currently 

required to be reported 

if a different equation 

(Equation Y-1a) is 

used: annual average 

carbon content of the 

flare gas (kg carbon/kg 

flare gas) under 40 CFR 

98.256(e)(6). 

AA - 

Pulp and 

Paper 

40 CFR 

98.276(l)(

2) 

For each 

pulp mill 

lime 

kiln: 

Percent 

of annual 

heat 

input, 

individua

lly for 

each 

fossil 

fuel 

type. 

Non-CBI Release of this data 

would not result in 

competitive harm 

because lime kiln 

fossil fuel use as a 

fraction of design heat 

input was reported to 

the EPA as part of a 

2011 ICR survey, and 

facilities reporting 

via the survey made no 

CBI claims regarding 

fuel type and percent 

of design heat input. 

“Unit/Process ‘Static’ Characteristics that Are Not Inputs to Emission 

Equations” Data Category 

AA - 

Pulp and 

Paper 

40 CFR 

98.276(m)(

2) 

For each 

chemical 

recovery 

furnace 

and 

chemical 

recovery 

combustio

n unit 

for which 

you are 

not using 

Equation 

C-2c to 

calculate 

CO2

emissions

: 

Ratio of 

the 

unit’s 

ND1

 In the final CBI 

rulemaking (76 FR 

30799, May 26, 2011), 

we determined that the 

best approach for 

determining 

confidentiality of 

production capacity is 

not to make a single 

CBI determination 

applicable to all 

facilities within a 

given source category, 

due to differences 

between facilities. For 

all reported data 

elements related to 

production capacity, 

the EPA will make caseby-case determinations 

per reporter, in 
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Subpart Citation 

Data 

Element 

Confidentia

lity 

Determinati

on 

Proposed Rationale for 

Confidentiality 

Determination 

maximum 

rated 

heat 

input 

capacity 

to its 

design 

rated 

steam 

output 

capacity 

(mmBtu/lb 

steam), 

individua

lly for 

each 

fossil 

fuel type 

and for 

spent 

liquor 

solids. 

accordance with the 

provisions in 40 CFR 

part 2, subpart B for 

facilities that claim 

these data elements as 

CBI. 

1

 ND = No determination was made. 

The EPA is requesting comment on two aspects of these 

confidentiality determinations. First, the EPA seeks comment on 

the proposed data category assignment for each of these data 

elements in Tables 5 and 6. If you believe that the EPA has 

improperly assigned any proposed new data elements to one of the 

data categories, please provide specific comments identifying 

which proposed new data elements may be mis-assigned along with 

a detailed explanation of why you believe them to be incorrectly 

assigned and in which data category you believe they best 

belong. 
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Second, for those data elements assigned to the two direct 

emitter data categories without categorical confidentiality 

determinations, the EPA seeks comment on the individual 

confidentiality determinations we are proposing for these data 

elements. If you comment on this issue, please provide specific 

comment along with detailed rationale and supporting information 

on whether such data element does or does not qualify as CBI. 

V. Impacts of the Proposed Rule 

This section examines the cost impacts of the proposed 

rulemaking. A detailed discussion of the impacts may be found in 

the memorandum, ”Impacts Analysis of the Proposed 2015 Inputs 

Proposal,” available in EPA docket ID No. EPA–HQ–OAR–2010-0929. 

A. How were the costs of this proposed rule estimated?

1. Proposed Inputs Verification Tool.

The data elements required to be used for calculating the 

annual GHG emissions values and the cost associated with 

collecting these data, have not changed from the estimate made 

during the original rulemaking process. The time associated with 

entry of these “inputs to equations” data elements into e-GGRT 

(including into the new inputs verification tool) is expected to 

be equivalent to the time originally anticipated for data entry. 

Prior to the inputs verification tool, as currently required, 

reporters must use their own calculation tool (e.g., calculator, 

calculation software) to calculate the annual GHG emissions 
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Page 74 of 133 

values, using the same sets of equations and entering the same 

data elements that they would enter into the tool. 

The EPA does recognize however that there may be some time 

associated with learning the new procedures for the inputs 

verification tool and we have estimated a cost of approximately 

$66 per facility, or $379,000340,000 for the first year for all 

affected facilities. During their first session using the 

proposed inputs verification tool, reporters would need to spend 

approximately 1 hour becoming familiar with how the tool 

operates within e-GGRT. The proposed new requirement to use the 

inputs verification tool would not result in any change in the 

respondent activity of entering these data into e-GGRT. Once the 

reporter has become familiar with the tool, EPA does not 

anticipate any additional burden. The cost includes technical, 

clerical, and managerial labor hours. For further information 

about this cost estimate, refer to the memorandum “Assessment of 

Cost Impacts of 2015 Inputs Proposal – Revisions to Reporting, 

Recordkeeping, and Verification Requirements under the 

Greenhouse Gas Reporting Program” and the supporting statement 

for this proposed information collection request, “Supporting 

Statement, Environmental Protection Agency: Revisions to 

Reporting and Recordkeeping Requirements, and Proposed 

Confidentiality Determinations under the Greenhouse Gas 

Reporting Program, OMB control number 2060-[INSERT NEW NUMBER], 

Comment [A11]: EPA estimates this 

cost for affected facilities and 

$80,000 for recordkeeping and 

reporting (p. 72). It would be 

helpful if EPA could provide 

further explanation on how the cost 

is derived. Specifically, what cost 

elements were included; whether 

facility- or industry-specific 

assumptions were used; whether 

additional labor hours are 

anticipated to comply with the 

rule, and why EPA anticipates that 

costs would only occur in the first 

year of the rule? This information 

may be in a separate document, and 

if so, please reference it. 

EPA: Revised as requested. 
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Page 75 of 133 

ICR number 2483.01,” both available in docket EPA–HQ–OAR–2010-

0929.

2. Proposed New Data Elements.

We are proposing to add 26 new data elements that were not 

previously required to be reported under Part 98 (see Section 

II.D of this preamble for further discussion of this proposed 

amendment), to be reported by facilities in certain subparts 

that are required to use the proposed inputs verification tool. 

Of these 26 data elements, nine data elements are related to 

annual production or raw material usage, which are collected by 

a facility as a routine part of conducting business. For these 

data elements, we are not proposing that reporters comply with 

specific data collection or monitoring requirements beyond the 

methods commonly used for accounting purposes. The other 17 data 

elements proposed to be reported are calculated values using 

data currently required to be collected to perform emissions 

calculations. For all of these additional data elements, the EPA 

has estimated a nominal additional cost to report the data 

element and fulfill the recordkeeping requirements. The total 

costs associated with reporting and recordkeeping for the 26 

data elements in 10 subparts is $80,000. These costs represent 

the cost for all affected facilities in the first year.

B. Additional Impacts of the Proposed Amendments
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The proposed confidentiality determinations for the new 

data elements would not affect whether and how data are reported 

and, therefore, would not impose any additional burden on 

sources. 

VI. Statutory and Executive Order Reviews 

A. Executive Order 12866: Regulatory Planning and Review and 

Executive Order 13563: Improving Regulation and Regulatory 

Review

Under Executive Order 12866 (58 FR 51735, October 4, 1993), 

this action is a “significant regulatory action” because this 

action raises novel legal or policy issues arising out of legal 

mandates, the President’s priorities, or principles set forth in 

the executive order. Accordingly, the EPA submitted this action 

to the Office of Management and Budget (OMB) for review under 

Executive Orders 12866 and 13563 (76 FR 3821, January 21, 2011) 

and any changes made in response to OMB recommendations have 

been documented in the docket for this action. 

B. Paperwork Reduction Act

This action proposes to amend reporting and recordkeeping 

requirements and verification procedures for the GHGRP. In 

addition, the EPA is proposing confidentiality determinations 

for the proposed new data elements in this action. The proposed 

amendments to the reporting requirements in the source categoryspecific subparts are not anticipated to result in significant 
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Page 77 of 133 

burden for reporters. The new data elements required to be 

reported are expected to be readily available for affected 

facilities, or easily calculated using data already required to 

be collected (e.g., a monthly value is currently reported and an 

annual value is proposed to be reported). 

Impacts associated with the proposed changes to the 

reporting requirements in each subpart are detailed in the 

memorandum “Impacts Analysis of the Proposed 2015 Inputs 

Proposal” (see Docket ID No. EPA-HQ-OAR-2010-0929). The Office 

of Management and Budget (OMB) has previously approved the 

information collection requirements for 40 CFR part 98 under the 

provisions of the Paperwork Reduction Act, 44 U.S.C. 3501 et seq

and has assigned OMB control number 2060-0629, ICR 2300.10. OMB 

has approved the information collection requirements for this 

rulemaking and has assigned OMB control number 2060-new, ICR 

2483.01. The OMB control numbers for the EPA’s regulations in 40 

CFR are listed in 40 CFR part 9. 

C. Regulatory Flexibility Act (RFA)

The RFA generally requires an agency to prepare a 

regulatory flexibility analysis of any rule subject to notice 

and comment rulemaking requirements under the Administrative 

Procedure Act or any other statute unless the agency certifies 

that the rule will not have a significant economic impact on a 

substantial number of small entities. Small entities include 
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Page 78 of 133 

small businesses, small organizations, and small governmental 

jurisdictions. 

For purposes of assessing the impacts of the proposed 

amendments on small entities, “small entity” is defined as: (1) 

A small business as defined by the Small Business 

Administration’s regulations at 13 CFR 121.201; (2) a small 

governmental jurisdiction that is a government of a city, 

county, town, school district or special district with a 

population of less than 50,000; or (3) a small organization that 

is any not-for-profit enterprise which is independently owned 

and operated and is not dominant in its field. This definition 

of small entity is consistent with the definition of small 

entity used for Part 98. 

After considering the economic impacts of today’s proposed 

amendments on small entities, I certify that this action will 

not have a significant economic impact on a substantial number 

of small entities. The small entities subject to Part 98 include 

small businesses across all sectors of the economy encompassed 

by Part 98, small governmental jurisdictions, and small nonprofits. The impacts of these proposed amendments are expected 

to be roughly a first-year cost of $6660 per facility for 

learning new procedures for the verification tool and an annual 

cost of $100 per facility for the recordkeeping and reporting of 

26 new data elements. 
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The EPA continues to be interested in the potential impacts 

of the proposed rule amendments on small entities and welcomes 

comments on issues related to such impacts. 

D. Unfunded Mandates Reform Act (UMRA)

The proposed amendments and confidentiality determinations 

do not contain a federal mandate that may result in expenditures 

of $100 million or more for State, local, and tribal 

governments, in the aggregate, or the private sector in any one 

year. Thus, the proposed amendments and confidentiality 

determinations are not subject to the requirements of sections 

202 or 205 of UMRA. 

This rule is also not subject to the requirements of 

section 203 of UMRA because it contains no regulatory 

requirements that might significantly or uniquely affect small 

governments. This action proposes to amend reporting and 

recordkeeping requirements and verification procedures for the 

GHGRP. In addition, the EPA is proposing confidentiality 

determinations for the proposed new data elements in this 

action. Therefore, this action is not subject to the 

requirements of section 203 of the UMRA. 

E. Executive Order 13132: Federalism

The action does not have federalism implications. It will 

not have substantial direct effects on the states, on the 

relationship between the national government and the states, or 
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Page 80 of 133 

on the distribution of power and responsibilities among the 

various levels of government, as specified in Executive Order 

13132. The proposed amendments and confidentiality 

determinations apply to facilities that directly emit 

greenhouses gases and fuel and chemicals suppliers. These 

proposed changes do not apply to governmental entities unless 

the government entity owns a facility that directly emits GHGs 

above threshold levels (such as a large stationary combustion 

device), so relatively few government facilities would be 

affected. Moreover, for government facilities that are subject 

to the rule, the proposed revisions will not have a significant 

cost impact. This proposed action also does not limit the power 

of states or localities to collect GHG data and/or regulate GHG 

emissions. Thus, Executive Order 13132 does not apply to this 

rule. 

In the spirit of Executive Order 13132, and consistent with 

EPA policy to promote communications between the EPA and state 

and local governments, the EPA specifically solicits comments on 

this proposed action from state and local officials. 

F. Executive Order 13175: Consultation and Coordination with 

Indian Tribal Governments.

This proposed action does not have tribal implications, as 

specified in Executive Order 13175 (65 FR 67249, November 9, 

2000). The proposed amendments and confidentiality 
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determinations apply directly to facilities that directly emit 

greenhouses gases or that are suppliers of GHGs. They would not 

have tribal implications unless the tribal entity owns a 

facility that directly emits GHGs above threshold levels (such 

as a landfill or large combustion device). Relatively few tribal 

facilities would be affected. Thus, Executive Order 13175 does 

not apply to this action. 

G. Executive Order 13045: Protection of Children from 

Environmental Health Risks and Safety Risks

The EPA interprets Executive Order 13045 (62 FR 19885, 

April 23, 1997) as applying only to those regulatory actions 

that concern health or safety risks, such that the analysis 

required under section 5-501 of the Executive Order has the 

potential to influence the regulation. This proposed action is 

not subject to Executive Order 13045 because it does not 

establish an environmental standard intended to mitigate health 

or safety risks. 

H. Executive Order 13211: Actions that Significantly Affect 

Energy Supply, Distribution, or Use

This proposed action is not a “significant energy action” 

as defined in Executive Order 13211 (66 FR 28355, May 22, 2001), 

because it is not likely to have a significant adverse effect on 

the supply, distribution, or use of energy. Part 98 relates to 

monitoring, reporting, and recordkeeping and does not impact 
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energy supply, distribution, or use. This action proposes to

amend reporting and recordkeeping requirements and verification 

procedures for the GHGRP. In addition, the EPA is proposing 

confidentiality determinations for the proposed new data 

elements in this action. These proposed amendments and 

confidentiality determinations do not make any changes to the 

existing monitoring, recordkeeping, or reporting requirements 

under Part 98 that affect the supply, distribution, or use of 

energy. 

I. National Technology Transfer and Advancement Act

Section 12(d) of the National Technology Transfer and 

Advancement Act of 1995 (NTTAA), Public Law No. 104-113, 12(d) 

(15 U.S.C. 272 note) directs the EPA to use voluntary consensus 

standards in its regulatory activities unless to do so would be 

inconsistent with applicable law or otherwise impractical. 

Voluntary consensus standards are technical standards (e.g., 

materials specifications, test methods, sampling procedures, and 

business practices) that are developed or adopted by voluntary 

consensus standards bodies. NTTAA directs the EPA to provide 

Congress, through OMB, explanations when the Agency decides not 

to use available and applicable voluntary consensus standards. 

This proposed rulemaking does not involve the use of any 

new technical standards. Therefore, the EPA is not considering 

the use of any voluntary consensus standards. 
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Page 83 of 133 

J. Executive Order 12898: Federal Actions to Address 

Environmental Justice in Minority Populations and Low-Income 

Populations

Executive Order 12898 (59 FR 7629, February 16, 1994) 

establishes federal executive policy on environmental justice. 

Its main provision directs federal agencies, to the greatest 

extent practicable and permitted by law, to make environmental 

justice part of their mission by identifying and addressing, as 

appropriate, disproportionately high and adverse human health or 

environmental effects of their programs, policies, and 

activities on minority populations and low-income populations in 

the United States. 

The EPA has determined that these proposed rule amendments 

will not have disproportionately high and adverse human health 

or environmental effects on minority or low-income populations 

because the amendments do not affect the level of protection 

provided to human health or the environment. This is because the 

proposed amendments address information collection and reporting 

and verification procedures. 
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Proposed Rule Amendments and Confidentiality Determinations 

for Certain Data Elements Required under the 

Mandatory Greenhouse Gas Reporting Rule 

Page 84 of 133 

List of Subjects 40 CFR Part 98

Environmental protection, Administrative practice and 

procedure, Greenhouse gases, Reporting and recordkeeping 

requirements. 

Dated: 

 

Bob Perciasepe, 

Acting Administrator. 
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For the reasons stated in the preamble, title 40, chapter 

I, of the Code of Federal Regulations is proposed to be amended 

as follows: 

PART 98—[AMENDED] 

1. The authority citation for part 98 continues to read 

as follows: 

Authority: 42 U.S.C. 7401, et seq. 

Subpart A—[AMENDED] 

2. Section 98.3 is amended by revising paragraphs 

(c)(4)(vii), (d)(3)(v), (g) introductory text, and (g)(2)(i) to 

read as follows: 

§ 98.3 What are the general monitoring, reporting, recordkeeping 

and verification requirements of this part. 

* * * * * 

(c) * * * 

(4) * * * 

(vii) The owner or operator of a facility is not required 

to report the data elements specified in Table A-6 to this 

subpart for calendar years 2010 through 2011 until March 31, 

2013. The owner or operator of a facility is not required to 

report the data elements specified in Table A-7 to this subpart 

for calendar years 2010 through 2013 until March 31, 2015. Data 

elements specified in Table A-7 to this subpart for calendar 
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years 2010 through 2013 must be submitted as part of the annual 

report for reporting year 2014. 

* * * * * 

(d) * * * 

(3) * * * 

(v) For each combustion unit that is connected to a device 

that has been granted access by the Public Utilities Commission 

to deliver power to the local or regional power grid (e.g., 

electricity generators excluding generators connected to 

combustion units subject to subpart D of this part), and for 

which the combined nameplate capacity for all such devices at 

the facility is greater than or equal to 1 megawatt electric, 

report any facility operating data or process information used 

for the GHG emission calculations.

* * * * *

(g) Recordkeeping. An owner or operator that is required to 

report GHGs under this part must keep records as specified in 

this paragraph. Except as otherwise provided in this paragraph, 

retain all required records for at least 3 years from the date 

of submission of the annual GHG report for the reporting year in 

which the record was generated. The records shall be kept in an 

electronic or hard-copy format (as appropriate) and recorded in 

a form that is suitable for expeditious inspection and review. 
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If a reporter is required under § 98.5(b) to use software 

specified by the Administrator to enter data to calculate the 

reported GHGs, all records required under Part 98 must be 

retained by the reporter for 5 years from the date of submission 

of the annual GHG report for the reporting year in which the 

record was generated. Upon request by the Administrator, the 

records required under this section must be made available to 

EPA. Records may be retained off site if the records are readily 

available for expeditious inspection and review. For records 

that are electronically generated or maintained, the equipment 

or software necessary to read the records shall be made 

available, or, if requested by EPA, electronic records shall be 

converted to paper documents. You must retain the following 

records, in addition to those records prescribed in each 

applicable subpart of this part: 

* * * * * 

(2) * * * 

(i) The GHG emissions calculations and methods used. For 

data required by section § 98.5(b) to be entered into the 

software specified by the Administrator, maintain the entered 

data in the format generated by the software specified by the 

Administrator. 

* * * * * 
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3. Section 98.5 is revised to read as follows: 

§ 98.5 How is the report submitted?

(a) Each GHG report and certificate of representation for a 

facility or supplier must be submitted electronically in 

accordance with the requirements of § 98.4 and in a format 

specified by the Administrator. 

(b) For reporting year 2014 and thereafter, for each 

applicable subpart listed in Table A-8 to Part 98, you must 

enter into verification software specified by the Administrator 

all of the data used as inputs to the emissions calculation 

equations specified in Table A-8 to Part 98, excluding data 

required to be reported in the reporting section of each subpart 

listed in Table A-8 to Part 98.to calculate the reported GHGs 

for the following subparts: C, E, F, G, H, K, L, N, O, P, Q, R, 

S, U, V, X, Y, Z, AA, BB, CC, EE, GG, II, TT. 

4. Table A-7 to Subpart A of Part 98 is revised to read 

as follows: 

Table A–7 to Subpart A of Part 98—Data Elements That Are Inputs 

to Emission Equations and for Which the Reporting Deadline Is 

March 31, 2015 

Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which 

reporting date is March 31, 2015 

(“All” means all data elements in 

the cited paragraph are not required 

to be reported until March 31, 2015) 

A 98.3(d)(3)(v) All. 

C 98.36(b)(9)(iii) Only estimate of the heat input.1
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which 

reporting date is March 31, 2015 

(“All” means all data elements in 

the cited paragraph are not required 

to be reported until March 31, 2015) 

C 98.36(c)(2)(ix) Only estimate of the heat input from 

each type of fuel listed in Table C–

2.1

C 98.36(e)(2)(i) All.1

C 98.36(e)(2)(ii)(A) All.1

C 98.36(e)(2)(ii)(C) Only HHV value for each calendar 

month in which HHV determination is 

required.1

C 98.36(e)(2)(ii)(D) All.1

C 98.36(e)(2)(iv)(A) All.1

C 98.36(e)(2)(iv)(C) All.1

C 98.36(e)(2)(iv)(F) All.1

C 98.36(e)(2)(ix)(D) All.1

C 98.36(e)(2)(ix)(E) All.1

C 98.36(e)(2)(ix)(F) All.1

E 98.56(g) All. 

E 98.56(h) All. 

E 98.56(j)(4) All. 

E 98.56(j)(5) All. 

E 98.56(j)(6) All. 

E 98.56(l) All. 

H 98.86(b)(11) All. 

H 98.86(b)(13) Name of raw kiln feed or raw 

material. 

L 98.126(b)(10) All. 

L 98.126(b)(11) All. 

L 98.126(b)(12) All. 

N 98.146(b)(6) All.
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which 

reporting date is March 31, 2015 

(“All” means all data elements in 

the cited paragraph are not required 

to be reported until March 31, 2015) 

O 98.156(d)(2) All. 

O 98.156(d)(3) All. 

O 98.156(d)(4) All. 

Q 98.176(b) If you determined CO2 emissions using 

the site-specific emission factor

method in § 98.173(b)(2) based on 

the total quantity of raw material 

feed (metric tons of CO2 per metric 

ton of raw material feed), only 

annual quantity taconite pellets, 

coke, iron, and raw steel.

Q 98.176(f)(1) All. 

U 98.216(e)(2) All.

V 98.226(i) All. 

V 98.226(j) All. 

V 98.226(m)(4) All. 

V 98.226(m)(5) All. 

V 98.226(m)(6) All. 

V 98.226(p) All. 

W 98.236(c)(1)(i) All. 

W 98.236(c)(1)(ii) All. 

W 98.236(c)(1)(iii) All. 

W 98.236(c)(2)(i) All. 

W 98.236(c)(3)(i) All. 

W 98.236(c)(3)(ii) All. 

W 98.236(c)(3)(iii) All. 

W 98.236(c)(4)(i)(A) All. 

W 98.236(c)(4)(i)(B) All. 
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which 

reporting date is March 31, 2015 

(“All” means all data elements in 

the cited paragraph are not required 

to be reported until March 31, 2015) 

W 98.236(c)(4)(i)(C) All. 

W 98.236(c)(4)(i)(D) All. 

W 98.236(c)(4)(i)(E) All. 

W 98.236(c)(4)(i)(F) All. 

W 98.236(c)(4)(i)(G) All. 

W 98.236(c)(4)(i)(H) All. 

W 98.236(c)(4)(ii)(A) All. 

W 98.236(c)(5)(iii) All. 

W 98.236(c)(5)(iv) All. 

W 98.236(c)(5)(v) All. 

W 98.236(c)(6)(i)(B) All. 

W 98.236(c)(6)(i)(D) All. 

W 98.236(c)(6)(i)(E) All. 

W 98.236(c)(6)(i)(F) All. 

W 98.236(c)(6)(ii)(A) All. 

W 98.236(c)(6)(ii)(B) All. 

W 98.236(c)(7)(i) All. 

W 98.236(c)(8)(i)(B) All. 

W 98.236(c)(8)(i)(C) All. 

W 98.236(c)(8)(i)(F) All. 

W 98.236(c)(8)(ii)(A) All. 

W 98.236(c)(8)(ii)(D) All. 

W 98.236(c)(8)(iii)(A) All. 

W 98.236(c)(8)(iii)(D) All. 

W 98.236(c)(8)(iii)(E) All. 

W 98.236(c)(10)(ii) All. 
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which 

reporting date is March 31, 2015 

(“All” means all data elements in 

the cited paragraph are not required 

to be reported until March 31, 2015) 

W 98.236(c)(10)(iii) All. 

W 98.236(c)(11)(ii) All. 

W 98.236(c)(12)(ii) All. 

W 98.236(c)(12)(iii) All. 

W 98.236(c)(12)(v) All. 

W 98.236(c)(13)(i)(B) All. 

W 98.236(c)(13)(i)(E) All. 

W 98.236(c)(13)(i)(F) All. 

W 98.236(c)(13)(ii)(A) All. 

W 98.236(c)(13)(ii)(B) All. 

W 98.236(c)(13)(iii)(A) All. 

W 98.236(c)(13)(iii)(B) All. 

W 98.236(c)(13)(v)(A) All. 

W 98.236(c)(14)(i)(B) All. 

W 98.236(c)(14)(ii)(A) All. 

W 98.236(c)(14)(ii)(B) All. 

W 98.236(c)(14)(iii)(A) All. 

W 98.236(c)(14)(iii)(B) All. 

W 98.236(c)(14)(v)(A) All. 

W 98.236(c)(15)(i)(A) All. 

W 98.236(c)(15)(i)(B) All. 

W 98.236(c)(15)(ii)(A) All. 

W 98.236(c)(15)(ii)(B) All. 

W 98.236(c)(16)(i) All. 

W 98.236(c)(16)(ii) All. 

W 98.236(c)(16)(iii) All. 
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which 

reporting date is March 31, 2015 

(“All” means all data elements in 

the cited paragraph are not required 

to be reported until March 31, 2015) 

W 98.236(c)(16)(iv) All. 

W 98.236(c)(16)(v) All. 

W 98.236(c)(16)(vi) All. 

W 98.236(c)(16)(vii) All. 

W 98.236(c)(16)(viii) All. 

W 98.236(c)(16)(ix) All. 

W 98.236(c)(16)(x) All. 

W 98.236(c)(16)(xi) All. 

W 98.236(c)(16)(xii) All. 

W 98.236(c)(16)(xiii) All. 

W 98.236(c)(16)(xiv) All. 

W 98.236(c)(17)(ii) All. 

W 98.236(c)(17)(iii) All. 

W 98.236(c)(17)(iv) All. 

W 98.236(c)(18)(i) All. 

W 98.236(c)(18)(ii) All. 

W 98.236(c)(19)(iv) All. 

W 98.236(c)(19)(vii) All. 

Y 98.256(h)(5) Only value of the correction. 

Y 98.256(k)(4) Only mole fraction of methane in 

coking gas. 

Y 98.256(n)(3) All (if used in Equation Y–21 to 

calculate emissions from equipment 

leaks). 

Y 98.256(o)(4)(vi) Only tank-specific methane 

composition data and gas generation 

rate data. 

AA 98.276(e) All. 
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which 

reporting date is March 31, 2015 

(“All” means all data elements in 

the cited paragraph are not required 

to be reported until March 31, 2015) 

CC 98.296(b)(10)(i) All. 

CC 98.296(b)(10)(ii) All. 

CC 98.296(b)(10)(iii) All. 

CC 98.296(b)(10)(iv) All. 

CC 98.296(b)(10)(v) All. 

CC 98.296(b)(10)(vi) All. 

II 98.356(d)(2) All (if conducting weekly sampling).

II 98.356(d)(3) All (if conducting weekly sampling).

II 98.356(d)(4) Only weekly average temperature (if 

conducting weekly sampling). 

II 98.356(d)(5) Only weekly average moisture content 

(if conducting weekly sampling). 

II 98.356(d)(6) Only weekly average pressure (if 

conducting weekly sampling). 1

 Required to be reported only by combustion units subject to 

subpart C of part 98 that meet the following criteria: (1) the 

combustion unit is connected to a device that has been granted 

access by the Public Utilities Commission to deliver power to 

the local or regional electric power grid (e.g., electricity 

generators excluding generators connected to combustion units 

subject to subpart D of this part); and (2) the combined 

nameplate capacity (for all such devices at the facility) is 

greater than or equal to 1 megawatt electric. 

5. Table A-8 to Subpart A of Part 98 is added to read as 

follows: 

Table A–8 to Subpart A of Part 98—Equations For Which Certain 

Inputs To Equations Must be Entered Into Software Specified By 

the Administrator According to §98.5(b) of Part 98. 

Subpart Equation Number (40 CFR Part 98) 

Subpart C 1 C-1, C-1a, C-1b, C-2b, C-2c, C-3, C-4, C-5, C-8, C-
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8a, C-8b, C-10, C-13 

Subpart E E-1, E-2, E-3a, E-3b, E-3c, E-3d 

Subpart F F-2, F-3, F-5, F-6, F-7, F-8 

Subpart G G-1, G-2, G-3 

Subpart H H-2, H-3, H-4, H-5 

Subpart K K-1, K-3 

Subpart L L-1, L-2, L-3, L-4, L-6, L-7, L-8, L-17, L-18, L-20, 

L-21, L-22, L-23, L-25, L-26, L-27, L-31, L-34 

Subpart N N-1 

Subpart O O-3, O-4, O-8, O-9 

Subpart P P-1, P-2, P-3 

Subpart Q Q-1, Q-2, Q-3, Q-4, Q-5, Q-6, Q-7 

Subpart R R-1 

Subpart S S-4 

Subpart U U-1, U-2 

Subpart V V-2, V-3a, V-3b, V-3c, V-3d 

Subpart X X-1, X-2, X-3, C-8 

Subpart Y Y-1a, Y-1b, Y-3, Y-4, Y-6, Y-8, Y-11, Y-12, Y-13, Y14, Y-15, Y-16a, Y-16b, Y-17, Y-18, Y-19, Y-20, Y22, Y-23; alternate calculation methods to equations 

Y-9 and Y-10,specified in 98.253(c)(4) and (5) 

Subpart Z Z-1a, Z-1b 

Subpart AA C-1, C-1a, C-1b, C-2a, C-3, C-4, C-5, C-8, C-8a, C8b, C-9a, AA-1, AA-2, AA-3 

Subpart BB BB-1, BB-2 

Subpart CC CC-1, CC-2 

Subpart EE EE-2 

Subpart GG GG-1 

Subpart TT TT-2, TT-3 1

 Does not include any combustion unit that is connected to a 

device that has been granted access by the Public Utilities 

Commission to deliver power to the local or regional power grid 

(e.g., electricity generators excluding generators connected to 

combustion units subject to subpart D of this part), and for 

which the combined nameplate capacity for all such devices at 

the facility is greater than or equal to 1 megawatt electric.

Subpart C—[AMENDED] 

5.6. Section 98.36 is amended by: 

a. Revising paragraph (a). 
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a.b. Revising paragraph (b)(9)(iii) and adding paragraph 

(b)(9)(iv). 

b. Adding paragraph (b)(9)(iv).

c. Revising paragraph (c)(2)(ix) and adding paragraph 

(c)(2)(x). 

d. Adding paragraph (c)(2)(x).

e.d. Revising paragraphs (e)(2)(i), (e)(2)(ii)(A), 

(e)(2)(ii)(C), and (e)(2)(ii)(D); and adding paragraph 

(e)(2)(ii)(E). 

f. Adding paragraph (e)(2)(ii)(E).

g.e. Revising paragraphs (e)(2)(iv)(A), (e)(2)(iv)(C), 

(e)(2)(iv)(F), and (e)(2)(ix)(D) through (F); and 

adding paragraph (f). 

h. Adding paragraph (f).

The revisions and additions read as follows: 

§ 98.36 Data reporting requirements.

* * * * * 

(a) In addition to the facility-level information required 

under §98.3, the annual GHG emissions report shall contain the 

unit-level or process-level data specified in paragraphs (b) 

through (f) of this section, as applicable, for each stationary 

fuel combustion source (e.g., individual unit, aggregation of 

units, common pipe, or common stack). 
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(b) * * * 

(9) * * * 

(iii) The annual CH4 and N2O emissions for each type of fuel 

listed in Table C–2 of this subpart that was combusted in the 

unit during the report year, expressed in metric tons of each 

gas and in metric tons of CO2e. 

(iv) For each stationary fuel combustion unit source that 

meets the criteria specified in paragraph (f) of this sectionis 

connected to a device that has been granted access by the Public 

Utilities Commission to deliver power to the local or regional 

power grid (e.g., electricity generators excluding generators 

connected to combustion units subject to subpart D of this 

part), and for which the combined nameplate capacity for all 

such devices at the facility is greater than or equal to 1 

megawatt electric, you must also report an estimate of the heat 

input from each type of fuel listed in Table C–2 of this subpart 

that was combusted in the unit during the report year. 

* * * * * 

(c) * * * 

(2) * * * 

(ix) For each type of fuel listed in Table C–2 of this 

subpart that was combusted during the report year in the units 

sharing the common stack or duct during the report year, the 
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annual CH4 and N2O mass emissions from the units sharing the 

common stack or duct, expressed in metric tons of each gas and 

in metric tons of CO2 e. 

 (x) For each configurationstationary fuel combustion 

source that meets the criteria specified in paragraph (f) of 

this sectioncombustion unit that is connected to a device that 

has been granted access by the Public Utilities Commission to 

deliver power to the local or regional power grid (e.g., 

electricity generators excluding generators connected to 

combustion units subject to subpart D of this part), and for 

which the combined nameplate capacity for all such devices at 

the facility is greater than or equal to 1 megawatt electric, 

you must also report an estimate of the heat input from each 

type of fuel listed in Table C–2 of this subpart that was 

combusted during the report year in the units sharing the common 

stack or duct during the report year. 

* * * * * 

(e) * * * 

(2) * * * 

(i) For the Tier 1 Calculation Methodology, for each 

stationary fuel combustion unit source that meets the criteria 

specified in paragraph (f) of this sectionthat is connected to a 

device that has been granted access by the Public Utilities 
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Commission to deliver power to the local or regional power grid 

(e.g., electricity generators excluding generators connected to 

combustion units subject to subpart D of this part), and for 

which the combined nameplate capacity for all such devices at 

the facility is greater than or equal to 1 megawatt electric, 

report the total quantity of each type of fuel combusted in the 

unit or group of aggregated units (as applicable) during the 

reporting year, in short tons for solid fuels, gallons for 

liquid fuels and standard cubic feet for gaseous fuels, or, if 

applicable, therms or mmBtu for natural gas. 

(ii) * * * 

(A) For each stationary fuel combustion source that meets 

the criteria specified in paragraph (f) of this sectionunit that 

is connected to a device that has been granted access by the 

Public Utilities Commission to deliver power to the local or 

regional power grid (e.g., electricity generators excluding 

generators connected to combustion units subject to subpart D of 

this part), and for which the combined nameplate capacity for 

all such devices at the facility is greater than or equal to 1 

megawatt electric, report the total quantity of each type of 

fuel combusted in the unit or group of aggregated units (as 

applicable) during each month of the reporting year. Express the 

quantity of each fuel combusted during the measurement period in 
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short tons for solid fuels, gallons for liquid fuels, and scf 

for gaseous fuels. 

* * * * * 

(C) For each stationary fuel combustion source that meets 

the criteria specified in paragraph (f) of this sectionunit that 

is connected to a device that has been granted access by the 

Public Utilities Commission to deliver power to the local or 

regional power grid (e.g., electricity generators excluding 

generators connected to combustion units subject to subpart D of 

this part), and for which the combined nameplate capacity for 

all such devices at the facility is greater than or equal to 1 

megawatt electric, report the high heat values used in the CO2

emissions calculations for each type of fuel combusted during 

the reporting year, in mmBtu per short ton for solid fuels, 

mmBtu per gallon for liquid fuels, and mmBtu per scf for gaseous 

fuels. Report a HHV value for each calendar month in which HHV 

determination is required. If multiple values are obtained in a 

given month, report the arithmetic average value for the month. 

Indicate whether each reported HHV is a measured value or a 

substitute data value. 

(D) For each stationary fuel combustion source that meets 

the criteria specified in paragraph (f) of this sectionunit that 

is connected to a device that has been granted access by the 
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Public Utilities Commission to deliver power to the local or 

regional power grid (e.g., electricity generators excluding 

generators connected to combustion units subject to subpart D of 

this part), and for which the combined nameplate capacity for 

all such devices at the facility is greater than or equal to 1 

megawatt electric, if Equation C–2c of this subpart is used to 

calculate CO2 mass emissions, report the total quantity (i.e., 

pounds) of steam produced from MSW or solid fuel combustion 

during each month of the reporting year, and the ratio of the 

maximum rate heat input capacity to the design rated steam 

output capacity of the unit, in mmBtu per lb of steam. 

(E) For each HHV used in the CO2 emissions calculations for 

each type of fuel combusted during the reporting year, indicate 

whether the HHV is a measured value or a substitute data value. 

* * * * * 

(iv) * * * 

(A) For each stationary fuel combustion source that meets 

the criteria specified in paragraph (f) of this sectionunit that 

is connected to a device that has been granted access by the 

Public Utilities Commission to deliver power to the local or 

regional power grid (e.g., electricity generators excluding 

generators connected to combustion units subject to subpart D of 

this part), and for which the combined nameplate capacity for 
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all such devices at the facility is greater than or equal to 1 

megawatt electric, report the quantity of each type of fuel 

combusted in the unit or group of units (as applicable) during 

each month of the reporting year, in short tons for solid fuels, 

gallons for liquid fuels, and scf for gaseous fuels. 

* * * * * 

(C) For each stationary fuel combustion source that meets 

the criteria specified in paragraph (f) of this sectionunit that 

is connected to a device that has been granted access by the 

Public Utilities Commission to deliver power to the local or 

regional power grid (e.g., electricity generators excluding 

generators connected to combustion units subject to subpart D of 

this part), and for which the combined nameplate capacity for 

all such devices at the facility is greater than or equal to 1 

megawatt electric, report the carbon content and, if applicable, 

gas molecular weight values used in the emission calculations 

(including both valid and substitute data values). For each 

calendar month of the reporting year in which carbon content 

and, if applicable, molecular weight determination is required, 

report a value of each parameter. If multiple values of a 

parameter are obtained in a given month, report the arithmetic 

average value for the month. Express carbon content as a decimal 

fraction for solid fuels, kg C per gallon for liquid fuels, and 
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kg C per kg of fuel for gaseous fuels. Express the gas molecular 

weights in units of kg per kg-mole. 

* * * * * 

(F) For each stationary fuel combustion source that meets 

the criteria specified in paragraph (f) of this sectionunit that 

is connected to a device that has been granted access by the 

Public Utilities Commission to deliver power to the local or 

regional power grid (e.g., electricity generators excluding 

generators connected to combustion units subject to subpart D of 

this part), and for which the combined nameplate capacity for 

all such devices at the facility is greater than or equal to 1 

megawatt electric, report the annual average HHV, when measured 

HHV data, rather than a default HHV from Table C–1 of this 

subpart, are used to calculate CH4 and N2O emissions for a Tier 3 

unit, in accordance with §98.33(c)(1). 

* * * * * 

(ix) * * * 

(D) For each stationary fuel combustion source that meets 

the criteria specified in paragraph (f) of this sectionunit that 

is connected to a device that has been granted access by the 

Public Utilities Commission to deliver power to the local or 

regional power grid (e.g., electricity generators excluding 

generators connected to combustion units subject to subpart D of 
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this part), and for which the combined nameplate capacity for 

all such devices at the facility is greater than or equal to 1 

megawatt electric, report the carbon-based F-factor used in 

Equation C–13 of this subpart, for each type of fossil fuel 

combusted, in scf CO2 per mmBtu. 

(E) For each stationary fuel combustion source that meets 

the criteria specified in paragraph (f) of this sectionunit that 

is connected to a device that has been granted access by the 

Public Utilities Commission to deliver power to the local or 

regional power grid (e.g., electricity generators excluding 

generators connected to combustion units subject to subpart D of 

this part), and for which the combined nameplate capacity for 

all such devices at the facility is greater than or equal to 1 

megawatt electric, report the annual average HHV value used in 

Equation C–13 of this subpart, for each type of fossil fuel 

combusted, in Btu/lb, Btu/gal, or Btu/scf, as appropriate. 

(F) For each stationary fuel combustion source that meets 

the criteria specified in paragraph (f) of this sectionunit that 

is connected to a device that has been granted access by the 

Public Utilities Commission to deliver power to the local or 

regional power grid (e.g., electricity generators excluding 

generators connected to combustion units subject to subpart D of 

this part), and for which the combined nameplate capacity for 
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all such devices at the facility is greater than or equal to 1 

megawatt electric, report the total quantity of each type of 

fossil fuel combusted during the reporting year, in lb, gallons, 

or scf, as appropriate. 

* * * * * 

(f) For stationary combustion sources using the Tier 1, 

Tier 2, Tier 3, or Tier 4 Calculation Methodologies in §98.33(a) 

to quantify CO2e emissions, report: 

(1) Whether any stationary combustion units are connected 

to devices that have been granted access by the Public Utilities 

Commission to deliver power to the local or regional power grid. 

(2) For all stationary combustion units that meet the 

criteria specified in paragraph (f)(1) of this section, indicate 

whether the combined nameplate capacity for all associated 

devices that are connected to the local or regional power grid 

(excluding generators that are connected to combustion units 

that are subject to subpart D of this part) is greater than or 

equal to than 1 megawatt. 

Subpart E—[AMENDED] 

6.7. Section 98.56 is amended by: 

a. Revising the introductory text. 

b. Removing and reserving paragraphs (b), (c), (j)(1), 

and (j)(3). 
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c. Adding paragraphs (m) and (n). 

The revisions and additions read as follows: 

§ 98.56 Data reporting requirements.

In addition to the information required by §98.3(c), each 

annual report must contain the information specified in 

paragraphs (a) through (n) of this section at the facility 

level. 

* * * * * 

(m) Annual quantity of cyclohexane fed to all production 

lines combined (metric tons). 

(n) Annual percent N2O emission reduction for all production 

units combined. 

* * * * * 

Subpart F—[AMENDED] 

7.8. Section 98.66 is amended by: 

a. Removing and reserving paragraphs (a) and (c)(2). 

b. Revising paragraphs (c)(3), (e)(1), and (f)(1). 

c. Removing and reserving paragraph (g). 

The revisions read as follows: 

§ 98.66 Data reporting requirements.

* * * * * 

(c) * * * 

(2) [Reserved]
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(3) The last date when the smelter-specific-slope 

coefficients (or overvoltage emission factors) were measured. 

* * * * * 

(e) * * * 

(1) Annual anode consumption if using the method in 

§98.63(g). 

* * * * * 

(f) * * * 

(1) Annual paste consumption if using the method in 

§98.63(g). 

* * * * * 

Subpart G—[AMENDED] 

8.9. Section 98.76 is amended by: 

a. Revising the introductory text. 

b. Removing and reserving paragraph (b)(2) and paragraphs 

(b)(7) through (11). 

c. Adding paragraphs (c) and (d). 

The revisions and additions read as follows: 

§ 98.76 Data reporting requirements.

In addition to the information required by §98.3(c), each 

annual report must contain the information specified in 

paragraphs (a) through (d) of this section, as applicable for 

each ammonia manufacturing process unit. 
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* * * * * 

(c) Annual ammonia production (metric tons). 

(d) Annual methanol production (metric tons), if this 

quantity is not reported under subpart X of Part 98. 

Subpart H—[AMENDED] 

9.10. Section 98.86 is amended by: 

a. Removing and reserving paragraphs (b)(2), (b)(5), 

(b)(6), (b)(8), (b)(10), and (12). 

b. Revising paragraphs (b)(13) and (15). 

c. Adding paragraphs (b)(16) through (18). 

The revisions and additions read as follows: 

§ 98.86 Data reporting requirements.

* * * * * 

(b) * * * 

(12) [Reserved]

(13) Name of raw kiln feed or raw material. 

* * * * * 

(15) Method used to determine the monthly clinker 

production from each kiln. 

(16) Annual clinker production (metric tons). 

(17) Annual average clinker CO2 emission factor for the 

facility, averaged across all kilns (metric tons CO2/metric ton 

clinker produced). 
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(18) Annual average CKD CO2 emission factor for the 

facility, averaged across all kilns (metric tons CO2/metric ton 

CKD produced). 

Subpart K—[AMENDED] 

10.11. Section 98.116 is amended by: 

a. Removing and reserving paragraphs (b), (e)(4), and 

(e)(5). 

b. Revising paragraph (e)(6). 

The revisions read as follows: 

§ 98.116 Data reporting requirements.

* * * * * 

(e) * * * 

(5) [Reserved]

(6) List the method used for the determination of carbon 

content for each material included for the calculation of annual 

process CO2 emissions for each EAF (e.g., supplier provided 

information, analyses of representative samples you collected). 

* * * * * 

Subpart L—[AMENDED] 

11.12. Section 98.126 is amended by: 

a. Revising paragraph (b)(1). 

b. Removing and reserving paragraph (b)(2). 
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c. Revising paragraphs (b)(6), (b)(7), and (b)(8)(i) 

through (iv). 

d. Removing and reserving paragraphs (b)(8)(v) and 

(b)(9). 

e. Revising paragraph (c)(1). 

f. Removing and reserving paragraph (c)(2). 

g. Revising paragraph (d). 

h. Removing and reserving paragraphs (f)(1), (g)(1), and 

(h)(2). 

The revisions read as follows: 

§ 98.126 Data reporting requirements.

* * * * * 

(b) * * * 

(1) If you calculate the relative and absolute errors under 

§ 98.123(b)(1), the absolute and relative errors calculated 

under paragraph § 98.123(b)(1). 

(2) [Reserved]

* * * * * 

(6) The chemical formula of each fluorine-containing 

reactant that is fed into the process (metric tons).

(7) The chemical formula of each fluorine-containing 

product produced by the process.

* * * * *
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(8) * * * 

(i) The chemical formula of each fluorine-containing 

product that is removed from the process and fed into the 

destruction device (metric tons). 

(ii) The chemical formula of each fluorine-containing byproduct that is removed from the process and fed into the 

destruction device (metric tons). 

(iii) The chemical formula of each fluorine-containing 

reactant that is removed from the process and fed into the 

destruction device (metric tons). 

(iv) The chemical formula of each fluorine-containing byproduct that is removed from the process and recaptured (metric 

tons). 

(v) [Reserved]

(9) [Reserved]

* * * * * 

(c) * * * 

(1) The identity of the process activity used to estimate 

emissions (e.g., product produced or reactant consumed). 

(2) [Reserved]

* * * * * 

(d) Reporting for missing data. Where missing data have 

been estimated pursuant to § 98.125, you must report the reason 
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the data were missing, the length of time the data were missing, 

and the method used to estimate the missing data. 

* * * * * 

Subpart N—[AMENDED] 

12.13. Section 98.146 is amended by revising paragraph 

(b)(2) and removing and reserving paragraphs (b)(4) and (b)(6) 

to read as follows: 

§ 98.146 Data reporting requirements.

* * * * * 

(b) * * * 

(2) Annual quantity of each carbonate-based raw material 

charged (tons) to all furnaces combined. 

* * * * * 

Subpart O—[AMENDED] 

13.14. Section 98.156 is amended by: 

a. Removing and reserving paragraphs (a)(2), (a)(7) 

through (10), (b)(1), and (b)(2). 

b. Revising paragraph (d) introductory textparagraph. 

c. Removing and reserving paragraphs (d)(1), (d)(5), and 

(e)(1). 

The revisions read as follows: 

§ 98.156 Data reporting requirements.

* * * * * 
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(d) If the HFC–23 concentration measured pursuant to 

§98.154(l) is greater than that measured during the performance 

test that is the basis for the destruction efficiency (DE), the 

facility shall report the following: 

(1) [Reserved]

* * * * * 

Subpart P—[AMENDED] 

14.15. Section 98.166 is amended by: 

a. Revising the introductory textparagraph. 

b. Removing and reserving paragraphs (b)(2), (b)(5), and 

(b)(6). 

c. Adding paragraphs (b)(7) and (e). 

The revisions and additions read as follows: 

§ 98.166 Data reporting requirements.

In addition to the information required by §98.3(c), each 

annual report must contain the information specified in 

paragraphs (a) or (b) of this section, as appropriate, and 

paragraphs (c) through (e) of this section: 

* * * * * 

(b) * * * 

(5) [Reserved]

(6) [Reserved]
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(7) Name and annual quantity (metric tons) of each carboncontaining fuel and feedstock. 

* * * * * 

(e) Annual methanol production (metric tons), if this 

quantity is not reported under subpart X of Part 98. 

Subpart Q—[AMENDED] 

15.16. Section 98.176 is amended by: 

a. Revising paragraph (b). 

b.a. Removing and reserving paragraphs (b), (e)(1), (e)(3), 

(e)(4), (f)(2) through (4), and (g); and adding paragraph 

(e)(6). 

c.b. Adding paragraph (e)(6).Removing and reserving 

paragraphs (f)(2) through (4), and (g).

The revisions and additions read as follows: 

§ 98.176 Data reporting requirements.

* * * * * 

(b) If a CEMS is used to measure CO2 emissions or if you 

determined CO2 emissions using the site-specific emission factor 

method in § 98.173(b)(2) based on the total quantity of raw 

material feed (metric tons of CO2 per metric ton of raw material 

feed), then you must report the annual production quantity for 

the production unit (in metric tons) for taconite pellets, coke, 

sinter, iron, and raw steel. 
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* * * * *

(e) * * * 

(6) The information specified in paragraphs (e)(6)(i) 

through (vi) of this section aggregated for all process units 

for which CO2 emissions were determined using the mass balance 

method in § 98.173(b)(1), except as provided in § 98.174(b)(4). 

(i) The annual mass (metric tons) of all gaseous, liquid, 

and solid fuels (combined) used in process units for which CO2

emissions were determined using Equations Q-1 through Q-7 of 

this section, calculated as specified in Equation Q-9 of this 

section. 

ݑܨ݈݁ 	ൌ ቀ∑ ܨ௚, ∗ 	௜ெௐ೔

ெ௏஼

௡

௜ୀଵ ∗ 0.001 ൅ ܨ௟, ∗ ௜ߩ௟, ∗ ௜0.001	 ൅ ܨ௦,௜ቁ (Eq. Q-9) 

Where: 

Fuel = Annual mass of all gaseous, liquid, and solid 

fuels used in process units (metric tons). 

n = Number of process units where fuel is used. 

Fg,i = Annual volume of gaseous fuel combusted (“(Fg)” in 

Equations Q-1, Q-4 and Q-7 of this section) for 

each process (scf). 

MWi = Molecular weight of gaseous fuel used in each 

process (kg/kg-mole). 

MVC = Molar volume conversion factor at standard 

conditions, as defined in § 98.6. Use 849.5 scf 

per kg mole if you select 68 °F as standard 

temperature and 836.6 scf per kg mole if you 

select 60 °F as standard temperature. 

Fl,i = Annual volume of the liquid fuel combusted (“(Fl)” 

included in Equation Q-1 of this section) for 

each process unit (gallons). 
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Fs,i = Annual mass of the solid fuel combusted (“(Fs)” in 

Equation Q-1 of this section) for each process 

unit (metric tons). 

ρl,i = Density of the liquid fuel (kg/gallon). 

0.001 = Conversion factor from kg to metric tons. 

(ii) The annual mass (metric tons) of all non-fuel material 

inputs (combined) specified in Equations Q-1 through Q-7 of this 

section, calculated as specified in Equation Q-10 of this 

section. 

௡௜݈݁݁ݐܵ ൅ ݀݁݋ݎݐ݈݁ܿܧ ൅ ݁݁݀ܨ ൅ ݈ܽ݋ܥ ൅ ݊݋ܾݎܽܥ ൅ ݔݑ݈ܨ ൅ ݌ܽݎܵܿ ൅ ݊݋ݎܫ ൅ ܱ෍൭ ൌ ܫܨܰ

௡

௜ୀଵ

൱ݎ݄݁ݐܱ ൅ ݁ݎܱ ൅

(Eq. Q-10) 

Where: 

NFI = Annual mass of all non-fuel inputs (to all 

process unit types) specified in Equations Q-1 

through Q-7 of this section (metric tons). 

n = Number of process units, all process types. 

O = Annual mass of greenball (taconite) pellets fed 

to the taconite furnace(s) (metric tons). 

Iron = Annual mass of molten iron charged to the basic 

oxygen furnace(s) plus annual mass of direct 

reduced iron charged to the EAF(s) (metric tons). 

Scrap = Annual mass of ferrous scrap charged to the basic 

oxygen furnace(s) and EAF(s) (metric tons). 

Flux = Annual mass of flux materials charged to the 

basic oxygen furnace(s) and EAF(s) (metric tons). 

Carbon = Annual mass of carbonaceous materials (e.g., 

coal, coke) charged to the basic oxygen 

furnace(s), EAF(s), and direct reduction 

furnace(s) (metric tons). 

Coal = Annual mass of coal charged to the coke oven 

battery(s) (metric tons). 

Feed = Annual mass of sinter feed material charged to 

the sinter process(es) (metric tons). 
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Electrode = Annual mass of carbon electrode consumed in the 

EAF(s) (metric tons). 

Steelin = Annual mass of molten steel charged to the 

decarburization vessels (metric tons). 

Ore = Annual mass of iron ore or iron ore pellets fed 

to the direct reduction furnace(s) (metric tons). 

Other = Annual mass of other materials charged to the 

direction reduction furnace(s) (metric tons). 

(iii) The annual mass (metric tons) of all solid and liquid 

products and byproducts (combined) specified in Equations Q-1 

through Q-7 of this section, calculated as specified in Equation 

Q-11 of this section. 

௡∑ሺ ൌ ݏݐܿݑ݀݋ݎܲ

 (-11Q .ሺEq			ሻ ܯܰ ൅ ݊݋ݎܫ ൅ ݎ݁ݐܵ݅݊ ൅ ݇݁݋ܥ ൅ ݈ܵܽ݃ ൅ ௨௧௢݈݁݁ݐܵ ൅ ܴ ൅ ܲ ୀଵ௜

Where: 

Products = Annual mass of all solid and liquid products and 

by-products (from all process units) specified in 

Equations Q-1 through Q-7 of this section (metric 

tons). 

n = Number of process units, all types. 

P = Annual mass of fired pellets produced by the 

taconite furnace (metric tons). 

R = Annual mass of air pollution control residue from 

all process units (metric tons). 

Steelout = Annual mass of steel produced by the basic oxygen 

furnace(s), EAF(s) and decarburization vessel(s) 

(metric tons). 

Slag = Annual mass of slag produced by the basic oxygen 

furnace(s) and EAF(s) (metric tons). 

Coke = Annual mass of coke produced by the non-recovery 

coke batteries (metric tons). 

Sinter = Annual mass of sinter produced from the sinter 

process(es) (metric tons). 
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Iron = Annual mass of iron produced from the direct 

reduction furnace (metric tons). 

NM = Annual mass of non-metallic materials produced by 

the direct reduction furnace (metric tons). 

(iv) The weighted average carbon content of all gaseous, 

liquid, and solid fuels (combined) included in Equation Q-9 of 

this section, calculated as specified in Equation Q-12 of this 

section. 

ܨܥ௔௩௚ ൌ ቀ ∑ ி೒,೔	∗

ಾೈ೔

ಾೇ಴

೙

೔సభ ∗஼೒೑,೔∗଴.଴଴ଵାி೗,೔∗஼೗೑,೔∗଴.଴଴ଵା	ிೞ,೔∗஼ೞ೑ ቁ

ி௨௘௟ 		 (Eq. Q-12) 

Where: 

CFavg = Weighted average carbon content of all gaseous, 

liquid, and solid fuels included in Equation Q-9 

of this section (weight fraction). 

n = Number of gaseous, liquid, and solid fuel input 

to each process unit as used in Equation Q-9. 

Cgf,i = Average carbon content of the gaseous fuel used 

in each process, from the fuel analysis results 

(kg C per kg of fuel). 

Clf,i = Carbon content of the liquid fuel used in each 

process, from the fuel analysis results (kg C per 

gallon of fuel. 

Csf = Carbon content of the solid fuel used in each 

process, from the fuel analysis (expressed as a 

decimal fraction, e.g., 95% = 0.95). 

Fuel = Annual mass of all gaseous, liquid, and solid 

fuels used in process units (metric tons), as 

calculated in Equation Q-9 of this section. 

(v) The weighted average carbon content of all non-fuel 

inputs to all process units (combined) included in Equation Q-10 
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of this section, calculated as specified in Equation Q-13 of 

this section. 

ܫܥ௔௩௚ ൌ ൫∑ ேிூ೔∗஼ಿಷ಺೔ ೙

೔సభ ൯

ேிூ 						 (Eq. Q-13) 

Where: 

CIavg = Weighted average carbon content of all non-fuel 

inputs to all process units included in Equation 

Q-10 of this section (weight fraction). 

n = Number of non-fuel inputs to all process units as 

used in Equation Q-10. 

NFIi = Annual mass of each non-fuel input used in 

Equation Q-10 (metric tons). 

CNFIi = Average carbon content of each non-fuel input 

used in Equation Q-10 (expressed as a decimal 

fraction). 

NFI = Total of all non-fuel inputs to all process units 

(metric tons). 

(vi) The weighted average carbon content of all solid and 

liquid products and byproducts from all process units (combined) 

included in Equation Q-11 of this section, calculated as 

specified in Equation Q-14 of this section. 

ܥܲ௔௩௚ ൌ ൫∑ ௉௥௢ௗ௨௖௧೔∗஼ು೔ ೙

೔సభ ൯

௉௥௢ௗ௨௖௧௦ (Eq. Q-14) 

Where: 

CPavg = Weighted average carbon content of all solid and 

liquid products and byproducts from all process 

units (weight fraction). 

n = Number of products and byproducts from each 

process unit as used in Equation Q-11. 

Producti = Annual mass of each product or byproduct used in 

Equation Q-11 (metric tons). 
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Cp,i = Average carbon content of each product or 

byproduct used in Equation Q-11 (expressed as a 

decimal fraction). 

Products = Mass of all products and byproducts from all 

process units, calculated in Equation Q-11 of 

this section (metric tons). 

* * * * * 

Subpart R—[AMENDED] 

16.17. Section 98.186 is amended by removing and 

reserving paragraphs (b)(6) and (b)(7); and revising paragraph 

(b)(8) to read as follows: 

a. Removing and reserving paragraphs (b)(6) and (b)(7).

b. Revising paragraph (b)(8).

§ 98.186 Data reporting procedures.

* * * * * 

(b) * * * 

(6) [Reserved]

(7) [Reserved]

(8) List the method used for the determination of carbon 

content for each material used for the calculation of annual 

process CO2 emissions using Equation R–1 of this subpart for each 

smelting furnace (e.g., supplier provided information, analyses 

of representative samples you collected). 

* * * * * 

Subpart S—[AMENDED] 

17.18. Section 98.196 is amended by: 
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a. Revising paragraph (b) introductory textparagraph. 

b. Removing and reserving paragraphs (b)(2), (b)(3), 

(b)(5), (b)(6), (b)(8), (b)(10), (b)(11), and (b)(12). 

c. Adding paragraph (b)(18). 

The revisions and additions read as follows: 

§ 98.196 Data reporting requirements.

* * * * * 

(b) If a CEMS is not used to measure CO2 emissions, then you 

must report the information listed in paragraphs (b)(1) through 

(18) of this section. 

* * * * * 

(18) Annual quantity (metric tons) of lime product sold, by 

type. 

Subpart U—[AMENDED] 

18.19. Section 98.216 is amended by removing and 

reserving paragraphs (b), (e)(1), (e)(2), and (f)(1), and 

(f)(2). 

Subpart V—[AMENDED] 

19.20. Section 98.226 is amended by: 

a. Revising the introductory textparagraph. 

b. Removing and reserving paragraphs (d), (m)(1), and 

(m)(3). 

c. Adding paragraph (q). 
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The revisions and additions read as follows: 

§ 98.226 Data reporting requirements.

In addition to the information required by § 98.3(c), each 

annual report must contain the information specified in 

paragraphs (a) through (q) of this section. 

* * * * * 

(d) [Reserved]

* * * * *

(q) Annual percent N2O emission reduction for all production 

units combined. 

Subpart X—[AMENDED] 

20.21. Section 98.246 is amended by: 

a. Revising paragraph (a) introductory textparagraph and 

paragraphs (a)(2) and (a)(4). 

b. Adding paragraphs (a)(12) and (13). 

c. Revising paragraph (b) introductory textparagraph. 

d. Removing and reserving paragraphs (b)(5)(iii) and 

(b)(5)(iv). 

e. Adding paragraphs (b)(9) and (b)(10). 

The revisions and additions read as follows: 

§ 98.246 Data reporting requirements.

* * * * * 
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 (a) If you use the mass balance methodology in § 98.243(c), 

you must report the information specified in paragraphs (a)(1) 

through (a)(13) of this section for each type of petrochemical 

produced, reported by process unit.

* * * * * 

(2) The type of petrochemical produced, names of products, 

and names of carbon-containing feedstocks.

* * * * * 

(4) The temperature (in °F) at which the gaseous feedstock 

and product volumes used in Equation X–1 of this subpart were 

determined. 

* * * * * 

(12) Name and annual quantity (in metric tons) of each 

carbon-containing feedstock included in Equations X-1, X-2, and 

X-3 of § 98.243 of this subpart. 

(13) Name and annual quantity (in metric tons) of each 

carbon-containing co-product included in Equations X-1, X-2, and 

X-3 of § 98.243 of this subpart. 

(b) If you measure emissions in accordance with §

98.243(b), then you must report the information listed in 

paragraphs (b)(1) through (b)(10) of this section. 

* * * * * 
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(9) Name and annual quantity (in metric tons) of each 

carbon-containing feedstock. 

(10) Name and annual quantity (in metric tons) of each 

carbon-containing co-product. 

* * * * * 

Subpart Y—[AMENDED] 

21.22. Section 98.256 is amended by: 

a. Revising paragraphs (e)(6) and (e)(7) introductory 

textparagraph. 

b. Removing and reserving paragraph (e)(7)(ii). 

c. Revising paragraphs (e)(9) and (e)(10). 

d. Adding paragraph (e)(11). 

e. Revising paragraphs (f)(7) and (f)(10) through (13). 

f. Removing and reserving paragraph (h)(4). 

g. Revising paragraphs (h)(5), (i)(5), (i)(7), and 

(i)(8). 

h. Removing and reserving paragraph (j)(2). 

i. Revising paragraphs (j)(5) through (9), (k)(3), 

(k)(4), (l)(5), and (m)(3). 

j. Removing and reserving paragraphs (o)(2)(ii) and 

(o)(4)(ii) through (v). 

k. Revising paragraph (p)(2). 

The revisions and additions read as follows: 
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§ 98.256 Data reporting requirements.

* * * * * 

(e) * * * 

(6) If you use Equation Y–1a of this subpart, an indication 

of whether daily or weekly measurement periods are used, the 

annual volume of flare gas combusted (in scf/year) and the 

annual average molecular weight (in kg/kg-mole), and annual 

average carbon content of the flare gas (in kg carbon per kg 

flare gas). 

(7) If you use Equation Y–1b of this subpart, an indication 

of whether daily or weekly measurement periods are used, the 

annual volume of flare gas combusted (in scf/year), the annual 

average CO2 concentration (volume or mole percent), the number of 

carbon containing compounds other than CO2 in the flare gas 

stream, and for each of the carbon containing compounds other 

than CO2 in the flare gas stream: 

* * * * * 

(9) If you use Equation Y–3 of this subpart, the number of 

SSM events exceeding 500,000 scf/day. 

(10) The basis for the value of the fraction of carbon in 

the flare gas contributed by methane used in Equation Y–4 of 

this subpart. 

(11) If using Equation Y-3, report: 
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(i) Annual quantity of flare gas combusted (in MMscf per 

year). 

(ii) Annual average molecular weight of flare gas combusted 

(in mmBtu per MMscf). 

(iii) Annual average carbon content of flare gas combusted 

(expressed as a decimal fraction). 

(f) * * * 

(7) If you use Equation Y–6 of this subpart, the annual 

average exhaust gas flow rate, %CO2, and %CO. 

* * * * * 

(10) If you use Equation Y–8 of this subpart, the basis for 

the value of the coke burn-off factor, annual throughput of 

unit, and the average carbon content of coke. 

(11) Indicate whether you use a measured value, a unitspecific emission factor, or a default emission factor for CH4

emissions. If you use a unit-specific emission factor for CH4, 

report the basis for the factor. 

(12) Indicate whether you use a measured value, a unitspecific emission factor, or a default emission factor for N2O 

emissions. If you use a unit-specific emission factor for N2O, 

report the basis for the factor. 

(13) If you use Equation Y–11 of this subpart, the number 

of regeneration cycles or measurement periods during the 
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Page 127 of 133 

reporting year and the average coke burn-off quantity per cycle 

or measurement period. 

* * * * * 

(h) * * * 

(4) [Reserved]

(5) If you recycle tail gas to the front of the sulfur 

recovery plant, indicate whether the recycled flow rate and 

carbon content are included in the measured data under §

98.253(f)(2) and (3). Indicate whether a correction for CO2

emissions in the tail gas was used in Equation Y–12. If so, then 

report: 

(i) The value of the correction. 

(ii) If the following data are not used to calculate the 

recycling correction factor, report the information specified in 

paragraphs (h)(5)(ii)(A) through (C) of this section. 

(A) The annual volume of recycled tail gas (in scf/year) 

only. 

(B) The annual average mole fraction of carbon in the tail 

gas (in kg-mole C/kg-mole gas). 

(C) Indicate whether you used the default (95%) or a unit 

specific correction, and if used, report the approach used. 

* * * * * 

(i) * * * 
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(5) If you use Equation Y–13 of this subpart, an indication 

of whether coke dust is recycled to the unit (e.g., all dust is 

recycled, a portion of the dust is recycled, or none of the dust 

is recycled). 

* * * * * 

(7) Indicate whether you use a measured value, a unitspecific emission factor or a default for CH4 emissions. If you 

use a unit-specific emission factor for CH4, report the basis for 

the factor. 

(8) Indicate whether you use a measured value, a unitspecific emission factor, or a default emission factor for N2O 

emissions. If you use a unit-specific emission factor for N2O, 

report the basis for the factor. 

(j) * * * 

(5) If you use Equation Y–14 of this subpart, the basis for 

the CO2 emission factor used. 

(6) If you use Equation Y–15 of this subpart, the basis for 

the CH4 emission factor used. 

(7) If you use Equation Y–16 of this subpart, the basis for 

the carbon emission factor used. 

(8) If you use Equation Y–16b of this subpart, the basis 

for the CO2 emission factor used and the basis for the carbon 

emission factor used. 
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(9) If you use Equation Y–17 of this subpart, the basis for 

the CH4 emission factor used. 

(k) * * * 

(3) The total number of delayed coking units at the 

facility; the total number of delayed coking drums at the 

facility; and, for each coke drum or vessel, the typical drum 

outage (i.e. the unfilled distance from the top of the drum, in 

feet). 

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

dimensions, the number of coking drums in the set, and the mole 

fraction of methane in coking gas (in kg-mole CF4/kg-mole gas, 

wet basis). 

* * * * * 

(l) * * * 

(5) The annual volumetric flow discharged to the atmosphere 

(in scf), and an indication of the measurement or estimation 

method, annual average mole fraction of each GHG above the 

concentration threshold or otherwise required to be reported and 

an indication of the measurement or estimation method, and for 

intermittent vents, the number of venting events and the 

cumulative venting time. 

(m) * * * 
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(3) For uncontrolled blowdown systems reporting under §

98.253(k), the basis for the value of the methane emission 

factor used for uncontrolled blowdown systems. 

* * * * * 

(p) * * * 

(2) The types of materials loaded that have an equilibrium 

vapor-phase concentration of methane of 0.5 volume percent or 

greater, and the type of vessel (barge, tanker, marine vessel, 

etc.) in which each type of material is loaded. 

* * * * * 

Subpart Z—[AMENDED] 

22.23. Section 98.266 is amended by removing and 

reserving paragraphs (f)(5) and (f)(6). 

Subpart AA—[AMENDED] 

23.24. Section 98.276 is amended by: 

a. Revising the introductory paragraph. 

b. Removing and reserving paragraph (b). 

c. Revising paragraph (c). 

d. Removing and reserving paragraphs (d), (f), (g), (h) 

and (i). 

e. Adding paragraphs (l) and (m). 

The revisions and additions read as follows: 

§ 98.276 Data reporting requirements.
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In addition to the information required by § 98.3(c) and 

the applicable information required by § 98.36, each annual 

report must contain the information in paragraphs (a) through 

(m) of this section as applicable: 

* * * * * 

(b) [Reserved] 

(c) Basis for determining the annual mass of the spent 

liquor solids combusted (whether based on T650 om-05 Solids 

Content of Black Liquor, TAPPI (incorporated by reference, see §

98.7) or an online measurement system). 

(d) [Reserved]

* * * * * 

(l) For each pulp mill lime kiln, report the information 

specified in paragraphs (l)(1) and (2) of this section. 

(1) The quantity of calcium oxide (CaO) produced (metric 

tons). 

(2) The percent of annual heat input, individually for each 

fossil fuel type. 

(m) For each chemical recovery furnace and each chemical 

recovery combustion unit for which you are not using Equation C2c to calculate CO2 emissions, report the information specified 

in paragraphs (m)(1) and (2) of this section. 
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(1) The annual mass of steam generated (lb steam), 

individually for each fossil fuel type and for spent liquor 

solids. 

(2) The ratio of the unit’s maximum rated heat input 

capacity to its design rated steam output capacity (mmBtu/lb 

steam), individually for each fossil fuel type and for spent 

liquor solids. 

Subpart BB—[AMENDED] 

24.25. Section 98.286 is amended by removing and 

reserving paragraphs (b)(1), (b)(4), and (b)(6). 

Subpart CC—[AMENDED] 

25.26. Section 98.296 is amended by removing and 

reserving paragraphs (b)(5) through (7). 

Subpart EE—[AMENDED] 

26.27. Section 98.316 is amended by removing and 

reserving paragraphs (b)(6) and (b)(9). 

Subpart GG—[AMENDED] 

27.28. Section 98.336 is amended by removing and 

reserving paragraphs (b)(6), (b)(7), and (b)(10). 

Subpart TT—[AMENDED] 

28.29. Section 98.466 is amended by: 

a. Removing and reserving paragraph (c)(3)(i). 

b. Revising paragraph (c)(3)(ii). 
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c. Removing and reserving paragraph (c)(3)(iii). 

The revisions read as follows: 

§ 98.466 Data reporting requirements.

* * * * * 

(c) * * * 

(3) * * * 

(i) [Reserved]

(ii) The year of the data used in Equation TT-2 for the 

waste disposal quantity and production quantity, for each year 

used in Equation TT–2 of this subpart to calculate the average 

waste disposal factor (WDF). 

(iii) [Reserved]

* * * * *
Attachment G 
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6560.50 

ENVIRONMENTAL PROTECTION AGENCY 

40 CFR Part 98 

[EPA-HQ-OAR-2010-0929; FRL-9801-2] 

RIN 2060-AQ81 

Revisions to Reporting and Recordkeeping Requirements, and Proposed Confidentiality 

Determinations under the Greenhouse Gas Reporting Program 

EO12866_GHGRP Part 98 2060 AQ81 NPRM 20120326 

AGENCY: Environmental Protection Agency (EPA). 

ACTION: Proposed rule. 

SUMMARY: The EPA is proposing amendments to reporting and recordkeeping requirements 

and an alternative verification approach for the Greenhouse Gas Reporting Program. This action 

addresses concerns about the potential release of certain data that are inputs to emission 

equations whose reporting deadline was deferred until March 31, 2015 while maintaining the 

EPA’s ability to verify emissions and ensure compliance with the Greenhouse Gas Reporting 

Program. In addition, the EPA is proposing confidentiality determinations for the newly 

proposed data elements in this action. 

DATES: Comments. Comments must be received on or before [INSERT THE DATE 60 DAYS 

AFTER PUBLICATION OF THIS PROPOSED RULE IN THE FEDERAL REGISTER]. 

Public Hearing. The EPA will hold a public hearing on this proposed rule if requested. 

Requests for a hearing must be made by [INSERT THE DATE 7 DAYS AFTER 

PUBLICATION OF THIS PROPOSED RULE IN THE FEDERAL REGISTER]. Contact the 

person listed in the “FOR FURTHER INFORMATION CONTACT” section by [INSERT 

THE DATE 7 DAYS AFTER PUBLICATION OF THIS PROPOSED RULE IN THE 
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Page 2 of 96 

FEDERAL REGISTER] to request a public hearing. If a hearing is requested, the EPA will 

announce the details, including specific dates, times, addresses and contact information for the 

hearing, in a separate Federal Register notice. 

ADDRESSES: Submit your comments, identified by Docket ID No. EPA–HQ–OAR–2010-

0929, by one of the following methods: 

 Federal eRulemaking Portal: http:// www.regulations.gov. Follow the online instructions 

for submitting comments. 

 Email: GHGReportingCBI@epa.gov 

 Fax: (202) 566–1741. 

 Mail: Environmental Protection Agency, EPA Docket Center (EPA/DC), Mailcode 

6102T, Attention Docket ID No. EPA–HQ–OAR–2010-0929, 1200 Pennsylvania 

Avenue, NW., Washington, DC 20460. 

 Hand Delivery: EPA Docket Center, Public Reading Room, EPA West Building, Room 

3334, 1301 Constitution Avenue, NW., Washington, DC 20004. Such deliveries are only 

accepted during the Docket’s normal hours of operation, and special arrangements should 

be made for deliveries of boxed information. 

Instructions: Direct your comments to Docket ID No. EPA–HQ–OAR–2010-0929. The 

EPA’s policy is that all comments received will be included in the public docket without change 

and may be made available online at http://www.regulations.gov, including any personal 

information provided, unless the comment includes information claimed to be confidential 

business information (CBI) or other information whose disclosure is restricted by statute. 

Do not submit information that you consider to be CBI or otherwise protected through 

http://www.regulations.gov or email. Send or deliver information identified as CBI to only the 

mail or hand/courier delivery address listed above, attention: Docket ID No. EPA–HQ–OAR–

2010–0929. The http://www.regulations.gov website is an “anonymous access” system, which 

means the EPA will not know your identity or contact information unless you provide it in the 

body of your comment. If you send an email comment directly to the EPA without going through 

http://www.regulations.gov your email address will be automatically captured and included as 
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part of the comment that is placed in the public docket and made available on the Internet. If you 

submit an electronic comment, the EPA recommends that you include your name and other 

contact information in the body of your comment and with any disk or CD–ROM you submit. If 

the EPA cannot read your comment due to technical difficulties and cannot contact you for 

clarification, the EPA may not be able to consider your comment. Electronic files should avoid 

the use of special characters, any form of encryption, and be free of any defects or viruses. 

Docket: All documents in the docket are listed in the http://www.regulations.gov index. 

Although listed in the index, some information is not publicly available, e.g., CBI or other 

information whose disclosure is restricted by statute. Certain other material, such as copyrighted 

material, will be publicly available only in hard copy. Publicly available docket materials are 

available either electronically in http://www.regulations.gov or in hard copy at the Air Docket, 

EPA/DC, EPA West, Room B102, 1301 Constitution Ave., NW., Washington, DC. This Docket 

Facility is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. 

The telephone number for the Public Reading Room is (202) 566–1744, and the telephone 

number for the Air Docket is (202) 566–1742. 

FOR FURTHER GENERAL INFORMATION CONTACT: Carole Cook, Climate Change 

Division, Office of Atmospheric Programs (MC–6207J), Environmental Protection Agency, 

1200 Pennsylvania Ave., NW., Washington, DC 20460; telephone number: (202) 343–9263; fax 

number: (202) 343–2342; email address: GHGreporting@epa.gov. For technical information, 

contact the Greenhouse Gas Reporting Rule Helpline at: 

http://www.epa.gov/climatechange/emissions/ghgrule_contactus.htm. Alternatively, contact 

Carole Cook at 202–343–9263. 
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Worldwide Web (WWW). In addition to being available in the docket, an electronic copy 

of this proposal, memoranda to the docket, and all other related information will also be 

available through the WWW on EPA’s greenhouse gas reporting rule Web site at 

http://www.epa.gov/climatechange/emissions/ghgrulemaking.html. SUPPLEMENTARY 

INFORMATION: 

Additional Information on Submitting Comments: To expedite review of your comments 

by Agency staff, you are encouraged to send a separate copy of your comments, in addition to 

the copy you submit to the official docket, to Carole Cook, Climate Change Division, Office of 

Atmospheric Programs (MC–6207J), Environmental Protection Agency, 1200 Pennsylvania 

Ave., NW., Washington, DC, 20460, telephone (202) 343–9263, email 

GHGReportingCBI@epa.gov. 

Regulated Entities. This proposed rule revision on reporting and recordkeeping 

requirements and verification procedures would affect entities that must submit annual 

greenhouse gas (GHG) reports under the Greenhouse Gas Reporting Program (40 CFR part 98). 

The Administrator has determined that 40 CFR part 98 is subject to the provisions of Clean Air 

Act (CAA) section 307(d). See CAA section 307(d)(1)(V) (the provisions of CAA section 307(d) 

apply to “such other actions as the Administrator may determine”). Entities affected by this 

proposal are owners or operators of facilities that are direct emitters of greenhouse gases 

(GHGs), which include those listed in Table 1 of this preamble: 

Table 1. Examples of Affected Entities by Category 

Category NAICS Examples of affected facilities 

General Stationary Fuel 

Combustion Sources 

 Facilities operating boilers, process heaters, 

incinerators, turbines, and internal combustion engines. 

321 Manufacturers of lumber and wood products. 

322 Pulp and paper mills. 

325 Chemical manufacturers. 
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Category NAICS Examples of affected facilities 

324 Petroleum refineries and manufacturers of coal 

products. 

316, 326, 

339 

Manufacturers of rubber and miscellaneous plastic 

products. 

331 Steel works, blast furnaces. 

332 Electroplating, plating, polishing, anodizing, and 

coloring. 

336 Manufacturers of motor vehicle parts and accessories. 

221 Electric, gas, and sanitary services. 

622 Health services. 

611 Educational services. 

325193 Ethyl alcohol manufacturing facilities. 

311611 Meat processing facilities 

311411 Frozen fruit, juice, and vegetable manufacturing 

facilities. 

311421 Fruit and vegetable canning facilities. 

Adipic Acid Production 325199 Adipic acid manufacturing facilities. 

Aluminum Production 331312 Primary aluminum production facilities 

Ammonia 

Manufacturing 

325311 Anhydrous and aqueous ammonia production facilities. 

Cement Production 327310 Portland Cement manufacturing plants. 

Ferroalloy Production 331112 Ferroalloys manufacturing facilities. 

Fluorinated GHG 

Production 

325120 Industrial gases manufacturing facilities. 

Glass Production 327211 Flat glass manufacturing facilities. 

327213 Glass container manufacturing facilities. 

327212 Other pressed and blown glass and glassware 

manufacturing facilities. 

HCFC-22 Production 

and HFC-23 

Destruction 

325120 Chlorodifluoromethane manufacturing facilities. 

Hydrogen Production 325120 Hydrogen production facilities 

Iron and Steel 

Production 

331111 Integrated iron and steel mills, steel companies, sinter 

plants, blast furnaces, basic oxygen process furnace 

shops. 

Lead Production 331419 Primary lead smelting and refining facilities. 

331492 Secondary lead smelting and refining facilities. 

Lime Production 327410 Calcium oxide, calcium hydroxide, dolomitic hydrates 

manufacturing facilities. 

Nitric Acid Production 325311 Nitric acid production facilities 

Petrochemical 

Production 

32511 Ethylene dichloride production facilities. 

325199 Acrylonitrile, ethylene oxide, methanol production 

facilities. 

325110 Ethylene production facilities. 
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Category NAICS Examples of affected facilities 

325182 Carbon black production facilities. 

Petroleum and Natural 

Gas Systems 1

486210 Pipeline transportation of natural gas. 

221210 Natural gas distribution facilities. 

211 Extractors of crude petroleum and natural gas. 

211112 Natural gas liquid extraction facilities. 

Petroleum Refineries 324110 Petroleum refineries. 

Phosphoric Acid 

Production 

325312 Phosphoric acid manufacturing facilities. 

Pulp and Paper 

Manufacturing 

322110 Pulp mills. 

322121 Paper mills. 

322130 Paperboard mills. 

Silicon Carbide 

Production 

327910 Silicon carbide abrasives manufacturing facilities. 

Soda Ash 

Manufacturing 

325181 Alkalies and chlorine manufacturing facilities. 

212391 Soda ash, natural, mining and/or beneficiation. 

Titanium Dioxide 

Production 

325188 Titanium dioxide manufacturing facilities. 

Zinc Production 331419 Primary zinc refining facilities. 

331492 Zinc dust reclaiming facilities, recovering from scrap 

and/or alloying purchased metals. 

311411 Frozen fruit, juice and vegetable manufacturing 

facilities. 

311421 Fruit and vegetable canning facilities. 

Wastewater Treatment1 322110 Pulp mills. 

322121 Paper mills. 

322122 Newsprint mills. 

322130 Paperboard mills. 

311611 Meat processing facilities. 

311411 Frozen fruit, juice and vegetable manufacturing 

facilities. 

311421 Fruit and vegetable canning facilities. 

325193 Ethanol manufacturing facilities. 1

 The EPA is not proposing amendments related to these categories; however, these categories were evaluated in the 

EPA’s analysis of the potential impact from the release of inputs to emission equations for which reporting was 

deferred to March 31, 2015. Refer to Section 1.B of this preamble for further discussion of this evaluation. 

Table 1 of this preamble is not intended to be exhaustive, but rather provides a guide for 

readers regarding facilities and suppliers likely to be affected by this action. Types of facilities 

other than those listed in this table may also be affected by this action. To determine whether you 

are affected by this action, you should carefully examine the applicability criteria found in 40 
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CFR part 98, subpart A or the relevant criteria in the subparts. If you have questions regarding 

the applicability of this action to a particular facility or supplier, consult the person listed in the 

preceding FOR FURTHER GENERAL INFORMATION CONTACT section. 

Many facilities that are affected by 40 CFR part 98 have GHG emissions from multiple 

source categories listed in Table 1 of this preamble. 

Acronyms and Abbreviations. The following acronyms and abbreviations are used in this 

document. 

BAMM Best Available Monitoring Methods 

CAA Clean Air Act 

CO2 carbon dioxide 

CBI confidential business information 

CEMS Continuous Emission Monitoring System 

CFR Code of Federal Regulations 

e-GGRT Electronic Greenhouse Gas Reporting Tool 

EPA U.S. Environmental Protection Agency 

FR Federal Register 

GHG greenhouse gas 

GHGRP Greenhouse Gas Reporting Program 

HCFC-22 chlorodifluoromethane 

HFC hydrofluorocarbons 

HQ Headquarters 

ICR Information Collection Request 

MW megawatt 

NAICS North American Industry Classification System 

NTTAA National Technology Transfer and Advancement Act 

OMB Office of Management & Budget 

RFA Regulatory Flexibility Act 

UMRA Unfunded Mandates Reform Act 

U.S. United States 

WWW Worldwide Web 
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TABLE OF CONTENTS 

I. Executive Summary and Background

A. Executive Summary

B. Background

C. Subparts Covered in this Proposed Rule

D. Legal Authority

II. Summary of Proposed Changes to Part 98 Reporting and Recordkeeping Requirements

A. Proposed Use of Inputs Verification Tool

B. Proposed Revisions to Reporting of Data Elements Deferred until 2015

C. Proposed Changes to Recordkeeping Requirements

D. Proposed New Data Elements to be Reported

III. Rationale for Proposed Changes to Reporting and Recordkeeping Requirements

A. Proposed Inputs Verification Tool and Amendment to Reporting Requirements

B. Proposed Revisions to Recordkeeping Requirements

C. Proposed Requirement to Report Additional Data

IV. Confidentiality Determination for Proposed New Data Elements to be Reported

V. Impacts of the Proposed Rule

A. How were the costs of this proposed rule estimated?

B. Additional Impacts of the Proposed Amendments

VI. Statutory and Executive Order Reviews

A. Executive Order 12866: Regulatory Planning and Review and Executive Order 13563: 

Improving Regulation and Regulatory Review

B. Paperwork Reduction Act

C. Regulatory Flexibility Act (RFA)

D. Unfunded Mandates Reform Act (UMRA)

E. Executive Order 13132: Federalism

F. Executive Order 13175: Consultation and Coordination with Indian Tribal Governments.

G. Executive Order 13045: Protection of Children from Environmental Health Risks and Safety 

Risks

H. Executive Order 13211: Actions that Significantly Affect Energy Supply, Distribution, or Use

I. National Technology Transfer and Advancement Act

J. Executive Order 12898: Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations

I. Executive Summary and Background 

A. Executive Summary 

The Greenhouse Gas Reporting Program (GHGRP) collects greenhouse gas data from 41 

source categories and currently has received 2 to 3 years of data from these sources. Greenhouse 

gas emissions from direct emitters are calculated using a variety of methods, including direct 
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measurement, mass balance, and the use of emission factors. Reporters not using direct 

measurement must use equations to calculate emissions. The inputs to these emission equations 

often include process or production data that are specific to each facility’s operations. These 

inputs to emission equations play an important role in the Agency’s ability to verify facility-level 

emissions and ensure compliance with the program. 

On July 7, 2010, the EPA proposed confidentiality determinations for the majority of data 

elements required to be reported under the GHGRP, as well as for the majority of source 

categories covered by the program. In the July 7, 2010 action, the EPA proposed that data 

elements categorized as “inputs to emission equations” are emission data. The CAA precludes 

“emission data” from being treated as confidential. 

Based on subsequent industry concerns regarding the potential release of data elements 

categorized as “inputs to emission equations,” the EPA deferred reporting of these data elements 

(see August 25, 2011 final action, 76 FR 53057) to allow the EPA to complete its evaluation of 

the potential impact from the public release of these data elements (see 76 FR 53060) and, if 

appropriate, to propose amendments to Part 98 (see 75 FR 81355). Based on the analysis 

conducted, today’s action proposes amendments to reporting and recordkeeping requirements 

and an alternative verification approach for certain reporters subject to 24 subparts for which the 

reporting deadline for inputs to emission equations was deferred until 2015 and disclosure 

concerns have been identified. Proposed amendments include: 

 Adding a requirement for certain reporters under 24 subparts to use an EPA-provided 

inputs verification tool. For these subparts, the designated inputs to emission equations 

for which reporting was deferred to 2015 and disclosure concerns have been identified 

would be entered into the tool.1

 The tool would calculate the emissions and perform 

 

1

 Under this proposal, the inputs verification tool would not be required to be used by reporters for any reported GHG for 

which the reporter uses a CEMS or an EPA-approved alternative method (as allowed under sections 98.33(a)(5), 98.53(a)(2), and 

98.223(a)(2) of Part 98) to calculate the reported GHG value, rather than using "inputs to equations" data elements and the 

associated EPA-provided calculation methodologies to calculate the reported GHG value. 
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electronic verification. The tool would not retain the entered inputs (i.e., the inputs would 

not be reported to EPA); instead, the tool would conduct certain checks (e.g., accuracy of 

the inputs) at the time of data entry and generate a verification summary. The verification 

summary, which would be accessible to the EPA once the annual report is submitted, 

would provide the EPA with information to conduct further verification if necessary. 

 For reporters required to use the inputs verification tool, changing the required format for 

maintaining records of these inputs to emission equations. 

 For reporters required to use the inputs verification tool, lengthening the record retention 

period from 3 to 5 years for all records maintained under Part 98 (including subparts that 

do not require the use of the tool). 

 For certain reporters required to use the inputs verification tool, adding new data 

elements to be reported for the EPA’s verification purposes, and proposing 

confidentiality determinations for the new data elements proposed to be reported. 

 For reporters required to use the inputs verification tool, removing the requirement to 

report the inputs to emission equations for which reporting was deferred to 2015 and 

disclosure concerns have been identified, and requiring these data to be kept as records. 

Reporting requirements for inputs to equations for which disclosure concerns were not 

identified (and would still be useful to EPA) are not proposed to be amended in this action. For 

these inputs to equations, the deferral would expire in March 2015, and EPA would collect these 

data. 

The proposed changes in this action build on the EPA’s experience and success with 

electronic reporting and verification during the first 3 years of the GHGRP. By requiring the use 

of the inputs verification tool, which would calculate GHG emissions based on the inputs to the 

emissions equations, the EPA would have the ability to identify facilities that potentially reported 

emissions incorrectly. This, combined with additional verification checks of the inputs to 

emission equations that the inputs verification tool would conduct (during the process of 

reporters entering data into the inputs verification tool), would provide the EPA with information 

necessary to conduct further verification once the annual report is submitted. This alternative 

verification approach, including the changes to the recordkeeping requirements and additional 

reporting requirements, would provide an alternative to collecting certain data elements for 
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which reporting was deferred to March 31, 2015 and disclosure concerns have been identified, 

while maintaining the EPA’s ability to verify data and ensure compliance with the GHGRP. 

B. Background

On October 30, 2009, the EPA published the Greenhouse Gas Reporting Rule, 40 CFR 

part 98, requiring annual reporting of GHG data from a broad range of industry sectors (74 FR 

56260). Under the Greenhouse Gas Reporting Rule and its subsequent amendments (hereinafter 

referred to as “Part 98”), the EPA requires annual reporting of data from certain facilities and 

suppliers above specified emission or quantity supplied thresholds. On July 7, 2010 (75 FR 

39094) and subsequent proposals (77 FR 1434, January 10, 2012; 77 FR 10434, February 22, 

2012), we proposed confidentiality determinations for the data elements required to be reported. 

The confidentiality of each reported data element was determined using a two-step approach: (1) 

grouping data elements into 11 data categories (e.g., inputs to emission equations, emissions, and 

unit/process operating characteristics that are not inputs to emission equations for direct emitter 

source categories); and (2) making confidentiality determinations either categorically or on an 

individual data elements basis. Refer to both the July 7, 2010 proposal (75 FR 39097) and the 

May 26, 2011 final rule (76 FR 30785 - 30786) for more detailed descriptions of this process. 

Refer to the May 26, 2011 final rule also for a discussion of individual data element 

confidentiality determinations. We have finalized confidentiality determinations for data 

elements except those in the “inputs to emission equations” category (May 26, 2011, 76 FR 

30782; August 13, 2012, 77 FR 48072; and August 24, 2012, 77 FR 51477)2

. For data elements 

in this category, we proposed that they meet the definition of “emission data” under 40 CFR 

2.301(a)(2)(i). Because emission data are not entitled to confidential treatment under section 

 

2

 There are a small number of data elements (besides data elements categorized as “inputs to emission equations”) for which we 

have not made a final confidentiality determinations because we concluded that a determination of confidentiality for the data 

element should be made on a case-by-case facility basis (according to individual circumstances of the facility). 
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Page 12 of 96 

114(c) of the Clean Air Act, we did not evaluate whether such data elements would qualify as 

CBI, including whether disclosure would likely cause substantial competitive harm to the 

reporting facilities. (75 FR 39105 and 39108, July 7, 2010). 

Following our proposal that data elements assigned to the “inputs to emission equations” 

category are not entitled to confidential treatment, we received numerous industry comments 

asserting that competitive harm would result from public release of many of these data elements. 

We determined that “these concerns warranted an in-depth evaluation of the potential impact 

from the release of inputs to emission equations.” (76 FR 53060; August 25, 2011). In a notice 

dated December 27, 2010, we issued a call for information (75 FR 81354) requesting additional 

information to assist us in conducting our evaluation. To allow sufficient time to complete this 

evaluation through notice and comment, we deferred the reporting deadline for data elements 

assigned to the “inputs to emission equation” category. Reporting of certain of these data 

elements was deferred to March 31, 2013, as specified in Table A-6 of subpart A; and reporting 

of the remainder of these data elements was deferred to March 31, 2015, as specified in Table A7 of subpart A (see the August 25, 2011 final rule, 76 FR 53057). 

Our process for evaluating competitive harm was documented in the final deferral notice 

(August 25, 2011, 76 FR 53057) and the accompanying memorandum entitled “Process for 

Evaluating and Potentially Amending Part 98 Inputs to Emission Equations” (Docket ID EPAHQ-OAR-2010-0929). As discussed in the final deferral notice and memorandum, our evaluation 

involved a four-step process, as follows: 

 Step 1: Determine whether each data element assigned to the “inputs to emission 

equations” category is already publicly available. 

 Step 2: For data elements assigned to the “inputs to emission equations” category that are 

not publicly available, evaluate whether disclosure of the information is likely to result in 

substantial competitive harm. 
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 Step 3: For data elements assigned to the “inputs to emission equations” category that are 

likely to cause substantial competitive harm if disclosed, evaluate potential alternative 

calculation methods. 

 Step 4: For data elements assigned to the “inputs to emission equations” category that are 

likely to cause substantial competitive harm if disclosed, evaluate potential alternative 

verification methods. 

Based on each step of the four-step evaluation process, an analysis of all data elements 

for which reporting was deferred to March 31, 2015 was conducted.3 The results of the analysis 

are documented in four memoranda, as follows: 

 “Evaluation of Public Availability of Inputs to Emission Equations for which Reporting 

was Deferred to March 31, 2015.” 

 “Evaluation of Competitive Harm from Disclosure of “Inputs to Equations” Data 

Elements Deferred to March 31, 2015 

 “Evaluation of Alternative Calculation Methods.” 

 “Evaluation of Alternative Verification Approaches For Greenhouse Gas Reporting Rule 

Subparts for which Reporting of Inputs to Emission Equations was Deferred to March 31, 

2015.” 

These memoranda are available in EPA docket ID No. EPA–HQ–OAR–2010-0929. 

Based on the results of these analyses, the EPA is proposing in today’s action to make certain 

amendments to Part 98. 

C. Subparts Covered in this Proposed Rule

The proposed amendments affect all subparts listed in Table 2 of this preamble. Table 2 

includes most of the subparts with inputs to emission equations for which the reporting deadline 

was deferred until 2015. Subpart W (Petroleum and Natural Gas Systems), Subpart II (Industrial 

Wastewater Treatment), and subpart C (only certain combustion units associated with certain 

electric generators connected and able to deliver power to the local or regional electric power 

 

3

 Based on the same four-step process, we also evaluated all data elements for which reporting was deferred to 

March 31, 2013 (Part 98 Table A-6) and took no further action. As a result, applicable facilities were required to 

report these data by April 1, 2013. For a discussion of this evaluation, refer to the EPA's memorandum "Summary of 

Evaluation of Greenhouse Gas Reporting Program (GHGRP) Part 98 “Inputs to Emission Equations” Data Elements 

Deferred Until 2013" (December 17, 2012), available at 

http://www.epa.gov/ghgreporting/documents/pdf/2012/documents/2013-inputs-memo.pdf. 
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grid, as specified in Table 2) are not included in Table 2 because none of the inputs to emission 

equations required to be reported by reporters in these source categories are being amended, as 

no disclosure concerns were identified. Subpart I of part 98 is not included in Table 2 because 

reporting of inputs to emission equations under this subpart was addressed under a separate 

rulemaking proposed on October 16, 2012 (77 FR 63538). Additionally, parts of these proposed 

rule amendments would affect subparts not listed in Table 2. Specifically, for reporters subject to 

both a subpart listed in Table 2 and a subpart of Part 98 not listed in this table, the proposed 

revision to the recordkeeping duration would apply to the records required for all Part 98 

subparts (to which the reporter is subject). Refer to Sections II.C and III.B of this preamble for 

further discussion of this proposed amendment. 

Table 2. Subparts Affected by the Proposed Amendments.1,2

Subpart 

C—General Stationary Fuel Combustion except 

Specified Stationary Fuel Combustion Sources 

Connected to Certain Electric Generators that are 

Connected and Able to Deliver Power to the Local 

or Regional Electric Power Grid 3

S—Lime Manufacturing 

E—Adipic Acid Production U—Miscellaneous Uses of Carbonate 

F—Aluminum Production V—Nitric Acid Production 

G—Ammonia Manufacturing X—Petrochemical Production 

H—Cement Production Y—Petroleum Refineries 

K—Ferroalloy Production Z—Phosphoric Acid Production 

L—Fluorinated Gas Production AA—Pulp and Paper Manufacturing 

N—Glass Production BB—Silicon Carbide Production 

O—HCFC–22 Production and HFC–23 

Destruction 

CC—Soda Ash Manufacturing 

P—Hydrogen Production EE—Titanium Dioxide Production 

Q—Iron and Steel Production GG—Zinc Production 

R—Lead Production TT—Industrial Waste Landfills 1

 Certain proposed amendments affect other subparts not listed in this table as follows: for reporters subject to both a 

subpart listed in this table and a subpart of Part 98 not listed in this table, the proposed revision to the recordkeeping 

duration would apply to the records required for all Part 98 subparts to which the reporter is subject. 
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2

 Under this proposal, the inputs verification tool would not be required to be used by reporters for any reported 

GHG for which the reporter uses a CEMS or an EPA-approved alternative method (as allowed under sections 

98.33(a)(5), 98.53(a)(2), and 98.223(a)(2) of Part 98) to calculate the reported GHG value, rather than using "inputs 

to equations" data elements and the associated EPA-provided calculation methodologies to calculate the reported 

GHG value.

3 The stationary fuel combustion sources (e.g., individual units, aggregations of units, common pipes, or common 

stacks) not affected by the proposed amendments include those meeting both of the following criteria: (1) the 

stationary fuel combustion source contains at least one combustion unit connected to a fuel-fired electric generator 

that has been granted access by the Public Utilities Commission to deliver power to the local or regional electric 

power grid (excluding generators connected to combustion units that are subject to subpart D of Part 98); and (2) the 

stationary fuel combustion source is located at a facility for which the sum of the nameplate capacities for all such 

electric generators is greater than or equal to 1 megawatt electric output. Refer to Section III.A.3 of this preamble 

for a discussion of the EPA’s rationale for proposing that combustion units meeting these criteria not be affected by 

the proposed amendments. 

D. Legal Authority

The EPA is proposing these rule amendments under its existing CAA authority provided 

in CAA section 114. As stated in the preamble to the 2009 final GHG reporting rule (74 FR 

56260, October 30, 2009), CAA section 114(a)(1) provides the EPA broad authority to require 

the information proposed to be gathered by this rule because such data would inform and are 

relevant to the EPA’s carrying out a wide variety of CAA provisions. See the preambles to the 

proposed (74 FR 16448, April 10, 2009) and final Part 98 (74 FR 56260) for further information. 

In addition, pursuant to sections 114, 301, and 307 of the CAA, the EPA is proposing 

confidentiality determinations for the new data elements proposed in this notice. Section 114(c) 

of the CAA requires that the EPA make publicly available information obtained under CAA 

section 114 except for information (excluding emission data) that qualifies for confidential 

treatment. The Administrator has determined that this action (Part 98 amendment and 

confidentiality determinations) is subject to the provisions of CAA section 307(d). 

II. Summary of Proposed Changes to Part 98 Reporting and Recordkeeping Requirements 

The EPA is proposing revisions to the reporting and recordkeeping requirements in Part 

98 and alternative verification procedures that would apply to certain reporters subject to any of 

the 24 subparts listed in Table 2 of this preamble. Section II.A of this preamble summarizes a 
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proposed new requirement for these reporters if they use inputs to emission equations for which 

reporting was deferred to March 31, 2015 (hereafter referred to as “inputs to equations” data 

elements) to calculate reported GHGs. Such reporters would be required to use an EPA-provided 

electronic inputs verification tool to calculate emissions using data elements for which reporting 

was deferred to March 31, 2015 (hereafter referred to as “inputs to equations” data elements), 

allowing the EPA to complete electronic verification of reported GHG emissions data without 

the need to collect “inputs to equations” data elements for which disclosure concerns have been 

identified. Section II.B of this preamble summarizes the EPA’s proposal to remove, for these 

reporters, the requirement to report many “inputs to equations” data elements. Section II.C of 

this preamble summarizes proposed revisions to the recordkeeping requirements for these 

reporters. Section II.D of this preamble summarizes proposed new reporting requirements for 

these reporters. Section III of this preamble explains the rationale for the proposed amendments 

summarized in Sections II.A through II.D. Section IV of this preamble presents the EPA’s 

proposed confidentiality determinations for proposed new data elements and the EPA’s rationale 

for these determinations. Section V of this preamble presents the cost and impacts associated 

with these proposed amendments. 

A. Proposed Use of Inputs Verification Tool 

The EPA is proposing that facilities subject to the subparts listed in Table 2 of this 

preamble and that use “inputs to equations” data elements to calculate reported GHGs use an 

electronic inputs verification tool being developed by the EPA, which would calculate and verify 

GHG emissions. Refer to section III.A.1 of this preamble for a web-link to EPA’s “pilot” inputs 

verification tool for one subpart of Part 98, available during the public comment period for this 

rulemaking. The “pilot” demonstrates how the tool would work within e-GGRT, as well as the 
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types of verification checks that would be conducted. The inputs verification tool would be 

deployed within the EPA’s Electronic Greenhouse Gas Reporting Tool (e-GGRT) and would be 

integrated without interrupting the current electronic reporting process. While reporters enter 

data into e-GGRT that are required to be reported in the annual report, reporters would also enter 

into e-GGRT (via the inputs verification tool) the “inputs to equations” data elements that the 

EPA is proposing to remove from the reporting requirements. The tool would use the entered 

“inputs to equations” data elements to calculate the equation outputs, conduct electronic 

verification checks on the “inputs to equations” data elements, and generate a verification 

summary. The tool would not retain the entered “inputs to equations” data elements for which 

the EPA is proposing that the reporting requirement be removed. Accordingly, the EPA would 

not have access to these “inputs to equations” data elements. Instead, the EPA would rely on the 

verification summary, which would become accessible to the EPA when annual reports are 

submitted, as a first step for conducting verification once the annual report is submitted. 

Sources subject to multiple subparts under Part 98 would be required to use the inputs 

verification tool for only those subparts listed in Table 2 of this preamble. The EPA is proposing 

that reporters use this tool starting with reporting year 2014. Refer to Section III.A of this 

preamble for further discussion of this proposed requirement. 

This proposed requirement to use the inputs verification tool is specified in 40 CFR 98.5, 

Subpart A. Reporters would determine applicability under this new requirement based on a 

proposed new Table A-8 to Part 98, which lists all calculation methods under Part 98 for which 

the inputs verification tool must be used. Reporters calculating reported GHGs using a 

calculation method specified in proposed Table A-8 would be required to enter into the inputs 
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verification tool “inputs to equations” data elements that have been removed from the reporting 

requirements. 

B. Proposed Revisions to Reporting of Data Elements Deferred until 2015

The EPA is proposing to remove the reporting requirement for 440 “inputs to equations” 

data elements in the subparts listed in Table 2 of this preamble. Table 3 of this preamble provides 

a summary of how many data elements would be removed from reporting for each subpart. Refer 

to Table 1 in the memorandum “List of ‘Inputs to Equations’ Data Elements Proposed Not To Be 

Reported” (refer to Docket ID No. EPA–HQ–OAR–2010-0929) for a complete list of these 440 

data elements. For all remaining “inputs to equations” data elements not represented in Table 3 

of this preamble, the EPA is not amending these reporting requirements and would, therefore, let 

the deferral of these data elements expire on March 31, 2015. As a result, by March 31, 2015, all 

of the “inputs to equations” data elements for subpart W (Petroleum and Natural Gas Systems), 

Subpart II (Industrial Wastewater Treatment), and the additional “inputs to equations” data 

elements for which reporting is not proposed to be removed as indicated in Table 3 of this 

preamble, would be reported for future reporting years and for all prior reporting years, including 

reporting year 2014. For a list of these “inputs to equations” data elements that would be 

reported, refer to Table 2 of the memorandum cited above. 

Table 3. Subparts for Which Reporting Requirements are Amended 

Subpart

Number of “Inputs to 

Equations” Data Elements 

Number of “Inputs to 

Equations” Data Elements 

Proposed Not to Be 

Reported 

C—General Stationary Fuel 

Combustion Except Specified 

Stationary Fuel Combustion 

Sources Connected to Certain 

Electric Generators Connected 

and Able to Deliver Power to 

the Local or Regional Power 

261 261
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Subpart

Number of “Inputs to 

Equations” Data Elements 

Number of “Inputs to 

Equations” Data Elements 

Proposed Not to Be 

Reported 

Grid2

E—Adipic Acid Production 21 11 

F—Aluminum Production 29 29 

G—Ammonia Manufacturing 8 8 

H—Cement Production 16 14 

K—Ferroalloy Production 13 13 

L—Fluorinated Gas Production 55 46 

N—Glass Production 3 3 

O—HCFC–22 Production and 

HFC–23 Destruction 

15 12 

P—Hydrogen Production 7 7 

Q—Iron and Steel Production 93 92 

R—Lead Production 10 10 

S—Lime Manufacturing 9 9 

U—Miscellaneous Uses of 

Carbonate 

6 6 

V—Nitric Acid Production 21 6 

X—Petrochemical Production 21 21 

Y—Petroleum Refineries 80 75 

Z—Phosphoric Acid Production 4 4 

AA—Pulp and Paper 

Manufacturing 

31 28 

BB—Silicon Carbide 

Production 

3 3 

CC—Soda Ash Manufacturing 10 4 

EE—Titanium Dioxide 

Production 

2 2 

GG—Zinc Production 8 8 

TT—Industrial Waste Landfills 3 3 

1 Includes one “inputs to equations” data element, 40 CFR 98.3(d)(3)(v), which is specified in subpart A of part 98 

and applies to only certain reporters under subpart C of part 98. 2

 The reporting requirements applicable to certain stationary fuel combustion sources (e.g., individual units, 

aggregations of units, common pipes, or common stacks) subject to subpart C remain the same under the proposed 

amendment. Subpart C would continue to require reporting of all applicable “inputs to equations” data elements for 

stationary fuel combustion sources that meet both of the following criteria: (1) the stationary fuel combustion source 

contains at least one combustion unit connected to a fuel-fired electric generator that has been granted access by the 

Public Utilities Commission to deliver power to the local or regional electric power grid (excluding generators 
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Page 20 of 96 

connected to combustion units that are subject to subpart D of this part); and (2) the stationary fuel combustion 

source is located at a facility for which the sum of the combined nameplate capacities for all such electric generators 

is greater than or equal to 1 megawatt electric output. Subpart C reporters would not report “inputs to equations” 

data elements for all other types of stationary fuel combustion sources subject to subpart C. 

In order to ease the burden for facilities, the EPA is proposing that the “inputs to 

equations” data elements that are not being amended in this action (and therefore would be 

reported for reporting years prior to reporting year 2014) be reported as part of the annual report 

for reporting year 2014. Specifically, when reporters prepare their reporting year 2014 annual 

report via e-GGRT, they would be required to include these “inputs to equations” data elements 

for reporting year 2014 as well as for all applicable previous reporting years. The annual report, 

including these “inputs to equations” data elements that would still be reported, would be 

submitted via e-GGRT. This proposed approach would prevent facilities from being required to 

revise, re-certify, and re-submit annual reports for each previous reporting year. 

C. Proposed Changes to Recordkeeping Requirements

For each facility subject to a subpart listed in Table 2 of this preamble that uses “inputs to 

equations” data elements to calculate and report GHGs (i.e., subject to using the proposed inputs 

verification tool), the EPA is proposing that the facility retain all records, including records for 

subparts not subject to the inputs verification tool requirement, for 5 years, rather than the 

current 3-year record retention period. In other words, if any facility subject to using the 

proposed inputs verification tool is also subject to a subpart of Part 98 not listed in Table 2, we 

propose that records required for those other subparts also be maintained for the 5 years. For 

example, if such a facility is required to report under both subpart C (in Table 2) and subpart HH 

(not in Table 2), the facility would be required to maintain all records required under both 

subparts for 5 years following submittal of the annual report. The EPA is proposing that this 5-

year record retention requirement begin with records for reporting year 2010. 
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Additionally, we are proposing that, at the time a reporter subject to using the proposed 

inputs verification tool completes entry of all “inputs to equations” data elements into the tool, 

the reporter would be required to keep a file generated by the tool that lists the entered “inputs to 

equations” data elements. The reporter would be required to maintain a copy of the file as a 

record of the entered inputs. As currently required in 40 CFR 98.3(g), subpart A, this file may be 

maintained in electronic or hard copy format. As discussed above, this record would be required 

to be maintained for 5 years. 

Refer to Section III.B of this preamble for further discussion of these proposed 

recordkeeping requirements. 

D. Proposed New Data Elements to be Reported 

The EPA is proposing that reporters subject to using the proposed inputs verification tool 

in subparts E, G, H, P, Q, S, V, X, Y, and AA of Part 98, be required to report the additional data 

elements listed per subpart in Table 4 of this preamble. Proposed confidentiality determinations 

for these proposed data elements are presented in Section IV of this preamble. 

Table 4. Proposed New Data Elements for Subparts E, G, H, P, Q, S, V, X, Y, and AA of 

Part 98 

Subpart Subpart Name New Data Element Description 

E Adipic Acid Production Annual quantity of cyclohexane fed to all production 

lines (metric tons). 

Annual percent N2O emission reduction for all 

production units combined. 

G Ammonia Production Annual ammonia production (metric tons). 

Annual methanol production (metric tons), if this 

quantity is not reported under subpart X of Part 98. 

H Cement Production Annual clinker production (metric tons). 

Annual average clinker CO2 emission factor for the 

facility, averaged across all kilns (metric tons 

CO2/metric ton clinker produced). 

Annual average cement kiln dust (CKD) CO2
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Subpart Subpart Name New Data Element Description 

emission factor for the facility, averaged across all 

kilns (metric tons CO2/metric ton CKD produced). 

P Hydrogen Production Name and annual quantity (metric tons) of each 

carbon-containing fuel and feedstock. 

Annual methanol production (metric tons), if this 

quantity is not reported under subpart X of Part 98. 

Q Iron and Steel Production If you use the carbon mass balance method in 40 CFR 

98.173(b)(1) to determine CO2 emissions: The annual 

mass (metric tons) of all gaseous, liquid, and solid 

fuels (combined) used in process units specified in 

Equations Q-1 through Q-7 of Part 98, calculated as 

specified in a proposed new Equation Q-9 in the 

proposed rule amendments. Do not include fuel used 

in a stationary combustion unit where emissions are 

reported under subpart C of this part. 

If you use the carbon mass balance method in 40 CFR 

98.173(b)(1) to determine CO2 emissions: The annual 

mass (metric tons) of all non-fuel material inputs 

(combined) specified in Equations Q-1 through Q-7 of 

Part 98, calculated as specified in a proposed new 

Equation Q-10 in the proposed rule amendments. 

If you use the carbon mass balance method in 40 CFR 

98.173(b)(1) to determine CO2 emissions: The annual 

mass (metric tons) of all solid and liquid products and 

byproducts (combined) specified in Equations Q-1 

through Q-7 of Part 98, calculated as specified in a 

proposed new Equation Q-11 in the proposed rule 

amendments. 

If you use the carbon mass balance method in 40 CFR 

98.173(b)(1) to determine CO2 emissions: The 

weighted average carbon content of all gaseous, 

liquid, and solid fuels (combined) included in 

proposed new Equation Q-9, calculated as specified in 

a proposed new Equation Q-12 in the proposed rule 

amendments. 

If you use the carbon mass balance method in 40 CFR 

98.173(b)(1) to determine CO2 emissions: The 

weighted average carbon content of all non-fuel inputs 

to all furnaces (combined) included in proposed new 

Equation Q-10, calculated as specified in a proposed 

new Equation Q-13 in the proposed rule amendments. 

If you use the carbon mass balance method in 40 CFR 
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Subpart Subpart Name New Data Element Description 

98.173(b)(1) to determine CO2 emissions: The 

weighted average carbon content of all solid and 

liquid products and byproducts from all furnaces 

(combined) included in a proposed new Equation Q11 in the proposed rule amendments, calculated as 

specified in new Equation Q-14. 

S Lime Manufacturing Annual quantity (metric tons) of lime product sold, by 

type. 

V Nitric Acid Production Annual percent N2O emission reduction for all 

production units combined. 

X Petrochemical Production If using the mass balance method or CEMS method to 

calculate GHG emissions: Name and annual quantity 

(in metric tons) of each carbon-containing feedstock. 

If using the mass balance method or CEMS method to 

calculate GHG emissions: Name and annual quantity 

(in metric tons) of each carbon-containing co-product. 

Y Petroleum Refineries Annual quantity of flare gas combusted (in MMscf per 

year) (only when using Equation Y-3). 

Annual average molecular weight of flare gas 

combusted (in mmBtu per MMscf) (only when using 

Equation Y-3). 

Annual average carbon content of flare gas combusted 

(expressed as a decimal fraction)(only when using 

Equation Y-3). 

AA Pulp and Paper 

Manufacturing 

For each pulp mill lime kiln: Quantity of calcium 

oxide (CaO) produced (metric tons). 

For each pulp mill lime kiln: Percent of annual heat 

input, individually for each fossil fuel type. 

For each chemical recovery furnace and chemical 

recovery combustion unit for which you are not using 

Equation C-2c to calculate CO2 emissions: Annual 

mass of steam generated (lb steam), individually for 

each fossil fuel type and for spent liquor solids. 

For each chemical recovery furnace and chemical 

recovery combustion unit for which you are not using 

Equation C-2c to calculate CO2 emissions: Ratio of 

the unit’s maximum rated heat input capacity to its 

design rated steam output capacity (mmBtu/lb steam), 

individually for each fossil fuel type and for spent 

liquor solids. 
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III. Rationale for Proposed Changes to Reporting and Recordkeeping Requirements 

Based on the four-step evaluation described in Section I.B of this preamble, in particular 

the disclosure concerns discussed in “Step 2” of the evaluation and the alternatives considered in 

“Step 3” and “Step 4” of the evaluation to address those disclosure concerns, the EPA is 

proposing an alternative verification approach. This approach involves use of an inputs 

verification tool and revisions to the reporting and recordkeeping requirements of Part 98. The 

EPA’s rationale for this approach is presented in Sections III.A through C below. Section III.A 

addresses the proposed inputs verification tool and revisions to the requirement to report certain 

“inputs to equations” data elements. Section III.B addresses the proposed revisions to 

recordkeeping requirements. Section III.C addresses the proposed addition of new reporting 

requirements. 

A. Proposed Inputs Verification Tool and Amendment to Reporting Requirements

The EPA is proposing that facilities using “inputs to equations” data elements to calculate 

reported GHGs under the subparts listed in Table 2 of this preamble use an EPA-provided 

electronic inputs verification tool, which would calculate and verify GHG emissions. The inputs 

verification tool would be deployed within e-GGRT and integrated without interrupting the 

current electronic reporting process. Reporters would enter their “inputs to equations” data 

elements into the tool within the e-GGRT system along with the data required to be reported in 

the annual report (concurrent entry of “inputs to equations” data elements and data required for 

the annual report would be required starting in reporting year 2014, as further discussed in 

Section III.A.2 of this preamble). As a built-in feature of the e-GGRT system, the tool would use 

the entered “inputs to equations” data elements to calculate the equation outputs, conduct 

electronic verification checks on the “inputs to equations” data elements, and generate a 
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Page 25 of 96 

verification summary. The tool would not retain the entered “inputs to equations” data elements 

for which the EPA is proposing that the reporting requirement be removed.4 Accordingly, unlike 

data currently reported to the EPA through e-GGRT, the EPA would not have access to these 

“inputs to equations” data elements. 

Any such sources subject to multiple subparts under Part 98 would be required to use the 

tool for only those subparts listed in Table 2 of this preamble, as discussed in the following 

section. 

1. Detailed Description of Inputs Verification Tool.

The EPA’s current verification approach consists of electronic verification checks 

followed by direct follow-up with facilities. For subparts where the reporting of inputs to 

emission equations has been deferred until 2015, these checks have been conducted using 

reported data other than inputs to emission equations (the reporting of which was deferred). For 

“supplier” subparts5 (and starting in reporting year 2012 for subparts with inputs to emission 

equations that were deferred until 2013), these checks have been conducted using reported data 

that include the data needed to calculate outputs of the equations. Reporters under the supplier 

subparts have been entering into e-GGRT the data needed to calculate the annual GHG 

quantities. For reporters under the direct emitter subparts listed in Table 2 of this preamble that 

are using “inputs to equations” data elements to calculate reported GHGs, the EPA is proposing 

to use an approach similar to that currently used for the supplier subparts, where “inputs to 

equations” data elements would be entered into the inputs verification tool within e-GGRT and 

used to calculate the annual GHG emission values and verify these emission values. The 

 

4

 Please see section III.A.3 of this preamble for a discussion on which “inputs to equations” data elements the EPA 

is proposing that the reporting requirements be removed. 

5

 Supplier subparts (subparts LL through PP of Part 98) apply to fossil fuel suppliers and industrial gas suppliers. The eGGRT system currently calculates equation outputs for suppliers using reported equations inputs. Subpart MM 

reporters began using e-GGRT for reporting in Reporting Year 2012. 
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Page 26 of 96 

difference, however, is that these “inputs to equations” data elements would be entered into this 

new inputs verification tool within e-GGRT and would not be reported to the EPA. 

To access the inputs verification tool, reporters would log into e-GGRT. They would 

enter data elements required for the annual report as well as their “inputs to equations” data 

elements. The tool would operate securely within e-GGRT, as a transient process, which means 

that “inputs to equations” data elements (for which the EPA is proposing that the reporting 

requirement be removed) entered into the tool would be temporarily saved in the tool while the 

reporter is actively using the tool, but would not be persisted (i.e., saved) within the e-GGRT 

database. The “inputs to equations” data elements would be discarded when the user’s session 

with e-GGRT ends. Refer to the memorandum “Technical Approach and Design for Inputs 

Verification Tool” (refer to Docket ID No. EPA–HQ–OAR–2010-0929) for a detailed 

description of EPA’s technical approach and design for the inputs verification tool. The 

memorandum describes how the inputs verification tool would use entered data only during the 

reporters’ e-GGRT session and would delete all records of entered data when the reporters exits 

the system. 

If the reporter exits the inputs verification tool prior to completing data entry or 

submitting their annual report, the tool would generate a file of entered “inputs to equations” data 

elements, and allow the reporter to download the file. This file could then be uploaded into the 

tool when the reporter next uses the tool to continue with data entry for the same reporting year. 

This would avoid facilities from needing to re-enter “inputs to equations” data elements that 

were entered in previous e-GGRT sessions. 

After the reporter enters the “inputs to equations” data elements into the inputs 

verification tool, the tool would calculate the annual GHG emissions values. The tool would use 
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Page 27 of 96 

the following information in calculating these values: (1) “inputs to equations” data elements (for 

which reporting under this action is proposed to be removed) entered into the tool, (2) “inputs to 

equations” data elements entered into e-GGRT (not into the inputs verification tool) (refer to 

Section III.A.3 of this preamble for a discussion of the “inputs to equations” data elements that 

would still be reported under this proposal), (3) information entered into e-GGRT identifying 

which Part 98 calculation method was selected (if applicable), and (4) the selected Part 98 

calculation method. Once the annual GHG emissions values are calculated, the values would be 

pre-filled into the appropriate reporting fields within e-GGRT. Reporters would then have the 

opportunity to override the annual GHG emissions values calculated by the tool with their own 

calculated value. If the reporter chose to override the calculated value, this would be reflected in 

the verification summary. 

Prior to annual report submittal, the inputs verification tool would conduct a series of 

verification checks, including the following: 

 Verification checks on the annual GHG emission values calculated by the inputs 

verification tool. As mentioned above, reporters would have the opportunity to override 

and revise the value calculated by the tool; however should this occur, the tool would 

note a discrepancy, which would prompt the EPA for further review after the reporter 

submits the annual report. 

 Verification checks on entered “inputs to equations” data elements. For example, the tool 

would check: (1) whether all required data were entered; (2) whether entered “inputs to 

equations” data element values are within the expected ranges for the data elements; and 

(3) whether expected relationships exist between certain “inputs to equations” data 

elements and certain other reported data elements (e.g., process raw material or 

throughput data that are not “inputs to equations” data elements). 

Some of these checks would be conducted as the reporter enters “inputs to equations” 

data elements (i.e., using “real-time” checking), and other checks would be conducted after the 

reporter has entered all “inputs to equations” data elements, because some algorithms may 
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compare certain “inputs to equations” data elements (e.g., production quantity) to GHG emission 

values at the subpart or facility level. 

Also, prior to submittal of the annual report, the inputs verification tool would generate a 

verification summary containing the results of the verification checks. The verification summary 

would specify whether any potential errors, as described above, were identified, without 

specifying the “inputs to equations” data elements. The reporter would have an opportunity to 

review the verification summary and make necessary revisions to the entered “inputs to 

equations” data elements and the reported data elements. 

For example, a facility subject to subpart G that manufactures ammonia using liquid and 

solid feedstocks is currently required under 40 CFR 98.76(b)(1) to report annual CO2 process 

emissions for each ammonia manufacturing unit. Currently, the reporter calculates this reported 

annual GHG emissions value outside of e-GGRT (e.g., using a calculator or computer software), 

using Equations G-2, G-3, and G-4 of Part 98, and monthly values for the following “inputs to 

equations” data elements: quantity of liquid feedstock, quantity of solid feedstock, carbon 

content value for liquid feedstock, and carbon content value for solid feedstock. We are 

proposing that the reporter instead calculate this reported annual GHG emissions value using the 

inputs verification tool, which not only would use the same equations and data for calculation, 

but would also conduct verification checks, as follows: 

 The reporter would enter all 48 “inputs to equations” data elements” into the inputs 

verification tool (i.e., monthly values for all four “inputs to equations” data elements). 

 The reporter would use the inputs verification tool to calculate annual CO2 process 

emissions. In calculating this value, the tool would use Equations G-2, G-3, and G-4 of 

Part 98 and the 48 “inputs to equations” data element entries. 

 Once the annual CO2 process emissions value is calculated, the inputs verification tool 

would automatically conduct verification checks on the 48 entered “inputs to equations” 

data elements. For example, the tool might conduct the following checks: 

- Real-time checks that all 48 “inputs to equations” data elements were entered. 
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- Real-time checks that each of the 12 entered values for carbon content of liquid 

feedstock is within the expected range for carbon content of liquid feedstock (based 

on industry-wide data). The tool would conduct similar comparisons for the 12 

entered “inputs to equations” data elements for the carbon content value for solid 

feedstock. 

- Algorithm check comparing each of the 12 entered values of the quantity of the liquid 

feedstock to all monthly values entered for the year, to determine if individual values 

are within an expected range established using all 12 values. The tool would conduct 

similar comparisons for the 12 entered “inputs to equations” data elements for the 

quantity of solid feedstock. This type of check would be conducted after the reporter 

has entered all “inputs to equations” data elements. 

 Prior to annual report submittal, the inputs verification tool would automatically generate 

a verification summary, which would flag any potential errors, providing an opportunity 

for the reporter to review the verification summary and revise entered data. The 

verification summary would note if the reporter has overridden any of the annual GHG 

emissions values calculated by the tool. After the reporter completes all revisions to data 

entries, the tool would automatically re-generate the verification summary prior to annual 

report submittal. The EPA would access the verification summary (i.e., the same final 

summary viewed by the reporter) following annual report submittal and certification. 

 The inputs verification tool would also generate a file listing the entered “inputs to 

equations” data elements (for which the EPA is proposing to remove the reporting 

requirements) to be kept by the reporter and maintained as a record in a format currently 

allowed under Part 98 (see 40 CFR 98.3(g), subpart A). Refer to Section III.B of this 

preamble for further discussion of this proposed amendment and the EPA’s rationale for 

requiring this record. 

The EPA has developed a “pilot” inputs verification tool for one subpart, subpart X, 

which will be posted at http://www.epa.gov/ghgreporting/reporters/training/rulepilot.html, to 

demonstrate how the tool would work within e-GGRT, as well as the types of verification checks 

that would be conducted. The EPA seeks comment on the usability of the tool as well as its 

ability to conduct verification on the “inputs to equations” data elements. The EPA also seeks 

comment on additional approaches considered by EPA for implementation of the inputs 

verification tool; refer to the memorandum “Evaluation of Alternative Verification Approaches 

for Greenhouse Gas Reporting Rule Subparts for which Reporting of Inputs to Emission 

Equations was Deferred to March 31, 2015” (refer to Docket ID No. EPA–HQ–OAR–2010-

0929) for a description of these additional approaches considered. 
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2. Rationale Supporting the Use of the Inputs Verification Tool as an Alternative to 

Collecting Certain “Inputs to Equations” Data Elements for Verification Purposes. 

In the October 30, 2009 final rule (74 FR 56282 – 56283), the EPA described its 

verification approach as the following two-step process: 

 Initial automated review of reported data, using an electronic data quality assurance 

program built into the data system, for use by reporters and the EPA to help assure the 

completeness and accuracy of data. 

 Based on the initial review results, follow up with facilities regarding potential errors, 

discrepancies, or questions, including on-site audits. 

The EPA is currently using the two-step verification process of automated verification 

checks followed by direct follow-up with facilities to verify data currently reported via e-GGRT. 

The EPA is proposing to supplement the current verification approach for facilities reporting 

under the subparts listed in Table 2 of this preamble using the additional checks that would be 

conducted by the inputs verification tool. During the first 3 years of the Greenhouse Gas 

Reporting Program (GHGRP), the EPA has had success developing and using an electronic 

reporting and verification system for all subparts reporting under the program. During reporting 

year 2010, the EPA developed approximately 1,400 electronic verification checks to verify 

reported data. Based on these verification checks, the EPA followed up with approximately 

2,360 of the approximately 6,700 facilities that reported in reporting year 2010, resulting in 

approximately 2,300 facilities resolving verification issues by responding to the EPA and/or 

resubmitting their annual report. In reporting year 2011, the EPA programmed an additional 

1,000 checks into e-GGRT for the subparts that were reporting for the second year, expanding 

the number of checks to 2,400. The EPA also programmed into e-GGRT, for 2011, 

approximately 1,300 checks for the newly-reporting subparts. During reporting year 2011, the 
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EPA followed up with approximately 3,440 of the approximately 8,000 facilities that reported, 

resulting in approximately 3,000 facilities resolving their verification issues. 

For example, for subpart H, the EPA verifies reported GHG emissions data using: (1) 

reported cement production data and (2) publicly available industry data on GHG emissions. 

Using these data, the EPA has established ranges of acceptable production and emission values 

and set up algorithm checks for reported GHG emission values. 

The electronic checks used by the GHGRP have served as a means for the EPA to verify 

reported data while minimizing the burden on both the EPA and reporters. Electronic verification 

is a critical first step to ensuring the completeness and accuracy of reported data and reducing the 

costs of compliance monitoring. 

The inputs verification tool described in Section III.A.1 of this preamble utilizes the same 

approach that the EPA currently uses for calculating and verifying data submitted for supplier 

subparts (and starting in reporting year 2012, inputs to emission equations whose reporting 

deadline was deferred until 2013), except that e-GGRT would not retain the “inputs to 

equations” data elements entered into the tool. Once the annual report is submitted, the EPA 

would review the verification summary generated by the inputs verification tool, along with 

verification summaries that are currently generated using data currently collected through the 

annual report. By requiring use of the inputs verification tool, the EPA would have the additional 

certainty that reported annual GHG emissions values either were calculated correctly (because 

the values calculated by the tool were submitted to the EPA) or that the EPA would be made 

aware that there were discrepancies between values calculated by the tool and values submitted 

to the EPA. That additional certainty, combined with the additional information provided by the 

range and algorithm checks on the “inputs to equations” data elements themselves, would 
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provide the EPA with information necessary to conduct further verification once the annual 

report is submitted. 

If a potential error with one of the “inputs to equations” data elements or with an annual 

GHG emissions value were identified in the verification summary generated by the inputs 

verification tool, the EPA would likely follow up with the facility to determine whether an actual 

error has occurred. While this verification approach may result in more direct follow-up with 

facilities than if the “inputs to equations” data elements were submitted to the EPA, this 

approach would facilitate verification by identifying potential errors and minimizing the number 

of errors before annual reports are submitted. In addition, as discussed elsewhere in the 

preamble, the EPA is retaining the reporting requirement for “inputs to equations” data elements 

for which our four-step evaluation did not identify disclosure concerns and is proposing to 

require reporting of additional new data elements to assist the EPA’s verification effort. These 

“inputs to equations” data elements for which reporting would be retained and these proposed 

new reported data elements would allow the EPA to conduct additional verification and 

minimize the number of follow-ups with facilities. Lastly, for the reasons specified in section 

III.B of this preamble, the EPA is proposing that facilities retain records for 5 years, which 

would allow the EPA time to perform any necessary follow-up with reporters. For the reasons 

stated above, the EPA has determined that the proposed verification approach would be adequate 

to verify the reported emissions for reporters using “inputs to equations” data elements to 

calculate reported GHGs under the subparts identified in Table 2 of this preamble and is a 

reasonable alternative to collecting “inputs to equations” data elements for which we have 

identified disclosure concerns. 
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The EPA is proposing to require the use of the inputs verification tool starting with 

reporting year 2014. The inputs verification tool is designed to be used concurrently with annual 

reporting by facilities. By the time the EPA takes any final action on this proposed amendment, 

reporters would likely have already submitted annual reports for reporting years 2010 through 

2013. While additional verification could be conducted on the past years’ data if the inputs 

verification tool were used for these years, given that most of the data would likely already have 

been published and that the use of best available monitoring methods (BAMM) for these sectors 

is relatively low during these years, the EPA has determined that the added benefit does not 

outweigh the burden that would be required for facilities to use the inputs verification tool for 

years prior to reporting year 2014. 

3. Reporting of 440 “Inputs to Equations” Data Elements Would Not Be Necessary With the 

Proposed Verification Approach.

The EPA is proposing to remove the reporting requirement for 440 “inputs to equations” 

data elements that are in the subparts listed in Table 2 of this preamble. With the proposed 

alternative verification approach described in Section III.A.2 of this preamble, the EPA would no 

longer need to rely on the collection of these “inputs to equations” data elements to verify 

emissions under those subparts. Not having these data elements reported would address concerns 

relative to potential disclosure of these data elements.6

 These 440 data elements are specified in 

Table 1 of the memorandum “List of Inputs to Equations Data Elements Proposed Not To Be 

Reported” (refer to Docket ID No. EPA–HQ–OAR–2010-0929). 

The 440 “inputs to equations” data elements for which the EPA is proposing to remove 

the reporting requirement must be maintained on-site as records. Because Part 98 already 

 

6

we are proposing to remove the reporting requirement because we determined that these data elements would not 

be useful for data verification and would not inform future GHG policy development in the absence of other data 

elements for which we are proposing to remove the reporting requirement.
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requires these “inputs to equations” data elements to be kept as records (see 98.3(g)(2), which 

states that “the data used to calculate the GHG emissions for each unit, operation, process, and 

activity, categorized by fuel or material type” must be kept as records), the EPA is not proposing 

in this action to specify each of the 440 “inputs to equations” data elements in the recordkeeping 

section of each subpart. The EPA considered whether specifying each of these “inputs to 

equations” data elements in the recordkeeping sections of each subpart would improve the clarity 

of the specific records that would be required to be retained. Because the EPA is proposing that 

the “inputs to equations” data elements that would not be reported must be kept as records in the 

format generated by the inputs verification tool (i.e., file for downloading or printing), the EPA 

determined that the data that must be kept as records would be sufficiently clear. The EPA seeks 

comment on whether additional specificity within the recordkeeping requirements of each 

subpart would improve the clarity of the specific records that are required to be retained. 

For the purposes of clarifying which data elements must be reported for previous 

reporting years 2010 through 2013, we are proposing to revise Table A-7 of Part 98 to remove all 

440 data elements for which reporting is proposed to be removed. The data elements that are not 

being removed from Table A-7 would continue to be reporting requirements, and must be 

reported for previous reporting years 2010 through 2013, as appropriate. 

The EPA is retaining reporting of 170 “inputs to equations” data elements.7

 Refer to 

Table 2 in the memorandum “List of ‘Inputs to Equations’ Data Elements Proposed Not To Be 

Reported” (refer to Docket ID No. EPA–HQ–OAR–2010-0929) for a complete list of these 170 

data elements. The 170 “inputs to equations” data elements include certain “inputs to equations” 

 

7

 These 170 “inputs to equations” data elements include: (1) nine “inputs to equations” data elements in subpart L of 

part 98 that are not being addressed in this rulemaking because they will be addressed in a separate action related to 

subpart L; and (2) five “inputs to equations” data elements in subpart Y of part 98 that are not being addressed in 

this rulemaking because they are being addressed in a separate action. Refer to the EPA’s April 2, 2013 rulemaking 

(78 FR 19802) for EPA’s proposal that these five inputs be removed from reporting. 
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data elements for the subparts listed in Table 3 of this preamble, as well as all “inputs to 

equations” data elements for subparts C (only for specified stationary fuel combustion sources 

connected to certain electric generators that deliver power to the local or regional electric power 

grid)8, W, and II of part 98. For these “inputs to equations” data elements, the EPA is not 

amending these reporting requirements and would therefore let the deferral of these data 

elements expire on March 31, 2015. As a result, these “inputs to equations” data elements would 

be reported for future reporting years starting with reporting year 2014, as well as for previous 

reporting years (i.e., reporting years 2010 through 2013). Based on “Step 2” of our evaluation 

described in Section I.B of this preamble, these data elements would not raise disclosure 

concerns. Having these data elements reported would allow the EPA to do additional 

verification, including conduct year-to-year comparisons, thereby reducing the amount of direct 

follow-up required with facilities. For the reason stated above, collecting these data elements, 

even in the absence of collecting all “inputs to equations” data elements, would aid in the 

verification process. 

The EPA identified 23 “inputs to equations” data elements for which disclosure concerns 

were not identified based on “Step 2” of our evaluation; however, the EPA is not retaining these 

reporting requirements. The EPA determined that these 23 data elements would not be useful for 

data verification and would not inform future GHG policy development in the absence of other 

“inputs to equations” data elements for which the reporting requirement is proposed to be 

removed under this action. Examples of these 23 “inputs to equations” include reporting the 

 

8

 Refers to stationary fuel combustion sources (e.g., individual units, aggregations of units, common pipes, or 

common stacks) subject to subpart C meeting both of the following criteria: (1) the stationary fuel combustion 

source contains at least one combustion unit connected to a fuel-fired electric generator that has been granted access 

by the Public Utilities Commission to deliver power to the local or regional electric power grid (excluding 

generators connected to combustion units that are subject to subpart D of this part); and (2) the stationary fuel 

combustion source is located at a facility for which the sum of the nameplate capacities for all such electric 

generators is greater than or equal to 1 megawatt electric output. 
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selected default molar volume conversion factor and reporting the units of measure of a sitespecific emission factor. These “inputs to equations” are identified in the memorandum “List of 

‘Inputs to Equations’ Data Elements Proposed Not To Be Reported” (refer to Docket ID No. 

EPA–HQ–OAR–2010-0929). 

Regarding the 170 retained “inputs to equations” data elements, for reporting year 2014 

and thereafter, reporters would enter the 170 “inputs to equations” data elements for which we 

are retaining the reporting requirement into e-GGRT. Starting in reporting year 2014, the eGGRT system would retain these 170 data elements as part of the annual report and they would 

be accessible by the EPA once the reporter submits the annual report. In order to ease the burden 

on facilities, for reporting years prior to reporting year 2014, the EPA is proposing that these 

reported “inputs to equations” data elements be submitted as part of the reporting year 2014 

annual report. Specifically, when reporters prepare their reporting year 2014 annual report via eGGRT, they would be required to include these “inputs to equations” data elements for reporting 

year 2014 as well as for all applicable previous reporting years. The annual report, including 

these “inputs to equations” data elements would be submitted via e-GGRT. This approach would 

prevent facilities from being required to revise, re-certify, and re-submit annual reports for 

reporting years 2010, 2011, 2012, and 2013. 

The proposed revisions to the current reporting requirements would apply to all reporters 

subject to the subparts listed in Table 2 of this preamble, including subpart C, and using “inputs 

to equations” data elements to calculate reported GHGs. However, as noted in Table 2, we are 

not proposing to amend the reporting requirements for stationary fuel combustion sources subject 

to subpart C (e.g., individual units, aggregations of units, common pipes, or common stacks) that 

meet the following criteria: (1) the stationary fuel combustion source contains at least one 
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combustion unit connected to a fuel-fired electric generator that has been granted access by the 

Public Utilities Commission to deliver power to the local or regional electric power grid 

(excluding generators that are connected to combustion units subject to subpart D of this part); 

and (2) the stationary fuel combustion source is located at a facility for which the sum of 

nameplate capacities for all such electric generators is greater than or equal to 1 megawatt 

electric output. The “inputs to equations” data elements for these stationary fuel combustion 

sources are among those that did not raise disclosure concerns under “Step 2” of our evaluation 

of the “inputs to equations” data elements (refer to Section I.B of this preamble for a discussion 

of the EPA’s four-step evaluation). Refer to the memoranda documenting “Step 2” of our 

evaluation, “Evaluation of Competitive Harm From Reporting 2015 Inputs to Equations” 

(Docket ID No. EPA–HQ–OAR–2010-0929), for further information on the results of the 

analysis for these stationary fuel combustion sources. 

Reporters currently reporting emissions for stationary fuel combustion sources under 

subpart C have the option to utilize one or more of the reporting options under subpart C that 

allow the grouping of stationary combustion units for the purpose of monitoring, calculating, and 

reporting emissions. The EPA recognizes that stationary combustion units grouped in these 

reporting configurations could include both combustion units associated with electric generators 

(excluding generators connected to combustion units subject to subpart D of this part) (connected 

to the grid and not connected to the grid) and combustion units not associated with electric 

generators (excluding generators connected to combustion units subject to subpart D of this part). 

In these cases where combustion units are grouped, the EPA has determined that there would be 

no disclosure concerns with reporting of “inputs to equations” data elements for the grouped 

combustion units. In reporting combined data for multiple units including those associated with 
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an electric generator and subject to reporting under this proposed action, no unit-specific data 

would be revealed. Furthermore, should a facility not wish to disclose aggregated data, it would 

have the option to calculate and report emissions using one of the individual unit reporting 

configurations. The EPA seeks comment on this conclusion. If you believe that there are any 

disclosure concerns, please provide detailed information about the concern, as well as whether 

reporting on an individual unit basis is a feasible reporting option. 

Additionally, the EPA is proposing to revise two paragraphs (40 CFR 98.116(e)(6) and 

40 CFR 98.186(b)(8)) that reference other paragraphs that include “inputs to equations” data 

elements proposed to be removed from Part 98. As a result, we are proposing to remove the cross 

reference while carrying over the substantive information in order to maintain the requirements 

in these paragraphs. 

The EPA requests comment on the proposed inputs verification tool and verification 

approach, and the associated revision to the current reporting requirements as described in this 

section. 

B. Proposed Revisions to Recordkeeping Requirements

Given the proposed verification approach described in Section III.A of this preamble, the 

EPA considered whether the current record retention period and record format requirements 

would be sufficient to allow the EPA to perform data verification. We considered: 

 The time we would need to follow up with reporters to further verify reported GHG 

emissions. 

 The desirability of retaining multiple years of data records to allow for appropriate 

assessment of compliance and for analyses of trends for policy analysis purposes. 

 The format of records, and whether the current format would be adequate for our 

verification process. For example, we considered whether records of “inputs to 

equations” data elements contained in multiple separate documents (as currently allowed 

under Part 98) would allow an EPA inspector to efficiently analyze the consistency of the 

data elements and use the data elements to perform calculations to confirm reported GHG 

emissions. 
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Because there may be more direct follow-up activities under this alternative verification 

approach, we are proposing to extend the record retention period from 3 to 5 years. We have 

determined that 5 years is reasonable given the large number of reporters under the subparts 

identified in Table 2 of this preamble (over 2,000 facilities) and the likely increase in follow-up 

activities. It would be important that relevant records are available to the EPA for follow-up 

activities with facilities, including on-site audits if necessary, regarding potential errors, 

discrepancies, or questions. Should an EPA inspector visit a facility, it would be important to be 

able to examine not only the current year’s records but those from previous years as well, 

because previous years’ data would provide year-to-year comparisons, which are useful for 

verifying the current year’s data. A 5-year record retention period would ensure the availability 

of relevant records for the follow-up activities described above. The EPA is proposing that this 

5-year record retention requirement begin with records for reporting year 2010, as discussed in 

Section III.A.1 of this preamble. 

For reporters subject to using the proposed inputs verification tool, the EPA is proposing 

to extend the record retention period not only for the subparts listed in Table 2 of the preamble, 

but also for other subparts that apply to reporters subject to a subpart in Table 2. Under this 

proposal, any such facility subject to both a subpart listed in Table 2 of this preamble and a 

subpart not listed in Table 2 would be required to maintain all records required under both 

subparts for a period of 5 years. For example, if a facility is required to use the proposed inputs 

verification tool under subpart C (in Table 2) and to report under subpart HH (not in Table 2), 

the facility would be required to maintain all records required under both subparts for 5 years. 

The EPA is proposing these provisions for two reasons. First, the EPA determined that during a 

site visit, if questions arise regarding the accuracy of an “inputs to equations” data element, it 
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may be necessary to examine other non-input recordkeeping information, such as a monitoring 

plan or recordkeeping information in a different subpart, in order to fully investigate the 

accuracy of the data. It is necessary to ensure that all data necessary for verification are available, 

and this proposed 5-year record retention period would provide better assurance of on-site data 

availability. Second, the EPA determined that maintaining multiple sets of data records 

according to different record retention periods could possibly cause confusion and result in 

recordkeeping errors. Providing the same record retention duration for all subparts, as proposed, 

would simplify recordkeeping and thereby minimize the chance for recordkeeping errors. 

In addition, the EPA is proposing revisions to the recordkeeping format for “inputs to 

equations” data elements. Currently, reporters have the option to maintain records of their 

“inputs to equations” data elements in one or more electronic or hard copy files. The proposed 

record format revision would require reporters to maintain an electronic or hard copy of the 

single file generated by the proposed inputs verification tool, listing all “inputs to equations” data 

elements entered into the tool. This proposed record format change would ensure that the EPA 

could readily access these data, enabling the EPA to quickly and efficiently perform calculations 

and data checks during site visits. All other records required under Part 98 would be maintained 

in the format currently required under Part 98. In combination with the proposed reporting 

requirements discussed in Sections III.A and C of this preamble, these proposed recordkeeping 

requirements would allow the EPA to adequately verify certain reported emissions without 

implicating the disclosure concerns discussed in the memorandum “Evaluation of Competitive 

Harm For Reporting 2015 Inputs to Equations” (refer to Docket ID No. EPA–HQ–OAR–2010-

0929). 
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In amending 40 CFR part 98, subpart A to add these recordkeeping requirements, we are 

also correcting an error in the current version of 40 CFR 98.3(g). In a previous action amending 

this paragraph (76 FR 73866, November 29, 2011), our intention was to amend the second 

sentence of the paragraph regarding record retention duration; however, the third sentence 

regarding record format was inadvertently amended. To correct this error, we are proposing to 

remove the second sentence of 40 CFR 98.3(g) and to reinstate the previous third sentence of 40 

CFR 98.3(g) (regarding format of records). 

We seek comment on whether 5 years is the appropriate timeframe for maintaining 

records for facilities required to use the proposed inputs verification tool under a subpart listed in 

Table 2 of this preamble. In addition, we seek comment on the proposal to extend the record 

retention period for these reporters, not only for the subparts listed in Table 2 of the preamble, 

but also for other subparts that apply to these reporters. 

C. Proposed Requirement to Report Additional Data

As part of our proposal to no longer require reporting of certain “inputs to equations” 

data elements, we are proposing to require that certain reporters using the proposed inputs 

verification tool also report the new data elements specified in Table 4 of this preamble. These 

additional data elements would allow the EPA to perform additional verification checks and 

minimize the number of follow-up activities. These data elements are quantities that provide 

information on the activity level at the facility, emission factors used, characteristics of carboncontaining streams, and other process information that would provide key information for 

verification, including confirming that emissions are appropriate for a given activity-level and 

estimating expected emissions based on data provided. These new data reporting elements would 

also enable the EPA to better understand the following aspects concerning reporters in order to 
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inform future GHG policy:9

 (1) the GHG emission profile for the reporter; (2) the relationship of 

GHG emissions to production output or raw material input within the industry sector; and (3) the 

factors influencing GHG emissions. 

The EPA is proposing to add six new equations (Equations Q-9 through Q-14 of part 98) 

to subpart Q to specify how to calculate and report each of the six new data elements proposed to 

be added to subpart Q of part 98. Table 4 of this preamble specifies which equation number 

correlates with each new proposed data element. Refer to the proposed amendments for subpart 

Q for the proposed equations. 

The EPA is proposing confidentiality determinations for these proposed new data 

elements. Those new data elements determined to be confidential business information in a final 

rule would be afforded confidential treatment. Refer to the following Section IV of this preamble 

for the EPA’s proposed confidentiality determinations for the proposed new data elements. 

IV. Confidentiality Determination for Proposed New Data Elements to be Reported 

The EPA is proposing confidentiality determinations for each new data element listed in 

Table 4 of this preamble. To make these determinations, the EPA proposes to use the same 

approach that the EPA previously used for the 2011 final CBI rule (76 FR 30782, May 26, 2011). 

Specifically, the EPA is proposing to assign each new data element listed in Table 4 of this 

preamble to one of 11 direct emitter data categories, based on the type and characteristics of the 

data element. For a description of each data category and the type and characteristics of data 

elements assigned to each category, see Sections II.C and II.D of the July 7, 2010 CBI proposal 

preamble (75 FR 39106 – 39130). 

 

9

 The EPA has previously stated that a goal of collecting data under the GHGRP is to inform future GHG policy 

(refer to the April 10, 2009 proposed rule (74 FR 16455). 
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Based on its evaluation of the new data elements, the EPA is proposing that each new 

data element be assigned to one of the four following direct emitter data categories: 

 Production/Throughput Data that are Not Inputs to Emission Equations. 

 Raw Materials Consumed that are Not Inputs to Emission Equations. 

 Unit/Process “Static” Characteristics that are Not Inputs to Emission Equations. 

 Unit/ Process Operating Characteristics that are Not Inputs to Emission Equations. 

In the 2011 final CBI rule (May 26, 2011, 76 FR 30782), the EPA made categorical 

determinations that all data elements assigned to the “Production/Throughput Data that are Not 

Inputs to Emission Equations” and “Raw Materials Consumed that are Not Inputs to Emission 

Equations” data categories are entitled to confidential treatment because the data do not meet the 

definition of “emission data” in 40 CFR 2.301(a)(2)(i) and they are CBI. 

The EPA is proposing that seven new data elements be assigned to the 

“Production/Throughput Data that are Not Inputs to Emission Equations” data category and 10 

new data elements be assigned to the “Raw Materials Consumed that are Not Inputs to Emission 

Equations” data category, as shown in Table 5 of this preamble, thereby applying the categorical 

confidentiality determinations made for these categories in the 2011 final CBI rule (i.e., they are 

CBI) to the proposed new reporting elements assigned to these categories. This proposal is not 

changing, nor soliciting comment on, the categorical confidentiality determination for these two 

data categories. Should the EPA finalize the category assignment for these data elements, all new 

data elements assigned to these categories would be considered to be entitled to confidential 

treatment. 

Table 5. Data Elements Proposed to Be Assigned To the “Production/Throughput Data 

that are Not Inputs to Emission Equations” and “Raw Materials Consumed that are Not 

Inputs to Emission Equations” Data Categories 

Subpart Proposed Citation Data Element 

“Production/Throughput Data that are Not Inputs to Emission Equations” Data Category 
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Subpart Proposed Citation Data Element 

G - Ammonia Production 40 CFR 98.76(c)(14) Annual ammonia production 

(metric tons). 

40 CFR 98.76(d)(15) Annual methanol production 

(metric tons), if this quantity is 

not reported under subpart X of 

Part 98. 

H - Cement Kilns 40 CFR 98.86(b)(16) Annual clinker production 

(metric tons). 

P – Hydrogen Production 40 CFR 98.166(e) Annual methanol production 

(metric tons), if this quantity is 

not reported under subpart X of 

Part 98. 

S - Lime Manufacturing 40 CFR 98.196(b)(18) Annual quantity (metric tons) of 

lime product sold, by type. 

X – Petrochemical 40 CFR 98.246(a)(13) and 

(b)(10) 

If using the mass balance 

method or CEMS method to 

calculate GHG emissions: 

Name and annual quantity (in 

metric tons) of each carboncontaining co-product. 

AA - Pulp and Paper 40 CFR 98.276(l)(1) For each pulp mill lime kiln: 

Quantity of calcium oxide 

(CaO) produced (metric tons). 

“Raw Materials Consumed that are Not Inputs to Emission Equations” Data Category 

E - Adipic Acid Production 40 CFR 98.56(m) Annual quantity of cyclohexane 

fed to all production lines, 

combined (metric tons). 

P - Hydrogen Production 40 CFR 98.166(b)(7) Name and annual quantity 

(metric tons) of each carboncontaining fuel and feedstock. 
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Subpart Proposed Citation Data Element 

Q - Iron and Steel 40 CFR 98.176(i)(1) If you use the carbon mass 

balance method in 40 CFR 

98.173(b)(1) to determine CO2

emissions: The annual mass 

(metric tons) of all gaseous, 

liquid, and solid fuels 

(combined) used in process 

units specified in Equations Q-1 

through Q-7, calculated as 

specified in a new Equation Q-9 

in the proposed rule 

amendments. Do not include 

fuel used in a stationary 

combustion unit where 

emissions are reported under 

subpart C of this part. 

40 CFR 98.176(i)(2) If you use the carbon mass 

balance method in 40 CFR 

98.173(b)(1) to determine CO2

emissions: The annual mass 

(metric tons) of all non-fuel 

material inputs (combined) 

specified in Equations Q-1 

through Q-7, calculated as 

specified in a new Equation Q10 in the proposed rule 

amendments. 

40 CFR 98.176(i)(3) If you use the carbon mass 

balance method in 40 CFR 

98.173(b)(1) to determine CO2

emissions: The annual mass 

(metric tons) of all solid and 

liquid products and byproducts 

(combined) specified in 

Equations Q-1 through Q-7, 

calculated as specified in a new 

Equation Q-11 in the proposed 

rule amendments. 
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Subpart Proposed Citation Data Element 

40 CFR 98.176(i)(4) If you use the carbon mass 

balance method in 40 CFR 

98.173(b)(1) to determine CO2

emissions: The weighted 

average carbon content of all 

gaseous, liquid, and solid fuels 

(combined) included in 

Equation Q-9, calculated as 

specified in a new Equation Q12 in the proposed rule 

amendments. 

40 CFR 98.176(i)(5) If you use the carbon mass 

balance method in 40 CFR 

98.173(b)(1) to determine CO2

emissions: The weighted 

average carbon content of all 

non-fuel inputs to all furnaces 

(combined) included in 

Equation Q-10, calculated as 

specified in a new Equation Q13 in the proposed rule 

amendments. 

40 CFR 98.176(i)(6) If you use the carbon mass 

balance method in 40 CFR 

98.173(b)(1) to determine CO2

emissions: The weighted 

average carbon content of all 

solid and liquid products and 

byproducts from all furnaces 

(combined) included in a new 

Equation Q-11 in the proposed 

rule amendments, calculated as 

specified in new Equation Q-14 

in the proposed rule 

amendments. 

X – Petrochemical 40 CFR 98.246(a)(12) and (b)(9) If using the mass balance 

method or CEMS method to 

calculate GHG emissions: 

Name and annual quantity (in 

metric tons) of each carboncontaining feedstock. 
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Subpart Proposed Citation Data Element 

AA - Pulp and Paper 40 CFR 98.276(m)(1) For each chemical recovery 

furnace and chemical recovery 

combustion unit for which you 

are not using Equation C-2c to 

calculate CO2 emissions: 

Annual mass of steam 

generated (lb steam), 

individually for each fossil fuel 

type and for spent liquor solids. 

The EPA is proposing to assign eight proposed new data elements to the “Unit Process 

Operating Characteristics that are Not Inputs to Emission Equations” category and one proposed 

new data element to the “Unit/Process Static Characteristics that are Not Inputs to Emission 

Equations” category. In the 2011 final CBI rule, the EPA determined that the data elements in 

these categories are not “emission data” (as defined at 40 CFR 2.301(a)(2)(i)). However, instead 

of categorical determinations, the EPA made confidentiality determinations for individual data 

elements assigned to these two categories. In proposing these determinations, the EPA 

considered the confidentiality criteria at 40 CFR 2.208, in particular whether release of the data 

is likely to cause substantial harm to the business’s competitive position. See 40 CFR 

2.208(e)(1). The EPA is therefore following the same approach in this action for the proposed 

new reporting elements assigned to these two categories. 

Table 6 of this preamble lists the data elements the EPA proposes to assign to these two 

data categories and presents the EPA’s rationale for proposing to determine that each does or 

does not qualify as CBI under CAA section 114(c). 

Table 6. Proposed Confidentiality Determinations for Proposed New Data Elements 

Assigned to the “Unit/Process Operating Characteristics That Are Not Inputs to Emission 

Equations” and “Unit/Process ‘Static’ Characteristics that Are Not Inputs to Emission 

Equations” Data Categories 

Subpart Citation 

Data 

Element 

Confidentiality 

Determination 

Proposed Rationale for 

Confidentiality Determination 
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Subpart Citation 

Data 

Element 

Confidentiality 

Determination 

Proposed Rationale for 

Confidentiality Determination 

“Unit/Process Operating Characteristics That Are Not Inputs to Emission Equations” Data 

Category

E – Adipic 

Acid 

Production 

40 CFR 

98.56(n) 

Annual 

percent N2O 

emission 

reduction for 

all production 

units 

combined. 

Not CBI The annual facility percent N2O 

reduction could not be used to 

calculate adipic acid production. 

The level of N2O reductions 

varies by the type of abatement 

technology, the environment in 

which the abatement technology 

is operating, the age of the 

abatement technology, the age of 

the catalyst used, and the 

maintenance level of the 

abatement technology. 

H - Cement 

Kilns 

40 CFR 

98.86(b)(17) 

Annual 

average 

clinker CO2

emission 

factor for the 

facility, 

averaged 

across all 

kilns (metric 

tons 

CO2/metric 

ton clinker 

produced). 

CBI This data element could be used 

to back calculate a facility’s 

clinker production data, which 

would result in competitive 

disadvantage. 

40 CFR 

98.86(b)(18) 

Annual 

average 

cement kiln 

dust (CKD) 

CO2 emission 

factor for the 

facility, 

averaged 

across all 

kilns (metric 

tons 

CO2/metric 

ton CKD 

produced). 

CBI This data element could provide 

information about the efficiency 

of the operation, which would 

result in competitive 

disadvantage. 

V – Nitric 

Acid 

Production 

40 CFR 

98.226(q) 

Annual 

percent N2O 

emission 

reduction for 

all production 

Not CBI The annual facility percent N2O 

reduction for all nitric acid 

production trains combined 

could not be used to calculate the 

nitric acid production value for 
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Subpart Citation 

Data 

Element 

Confidentiality 

Determination 

Proposed Rationale for 

Confidentiality Determination 

units 

combined. 

any individual facility. The level 

of N2O reductions for each 

individual facility varies by the 

type of abatement technology, the 

environment in which the 

abatement technology is 

operating, the age of the 

abatement technology, the age of 

the catalyst used, and the 

maintenance level of the 

abatement technology. 

Additionally, facility-level N2O 

emission reduction information is 

already publicly available (see 

docket number EPA-HQ-OAR2010-0750 and 

http://www.climateactionreserve.

org). 

Y – 

Petroleum 

Refineries 

40 CFR 

98.256(e)(11)(

i) 

Annual 

quantity of 

flare gas 

combusted 

(in MMscf 

per year) 

(only when 

using 

Equation Y3). 

Not CBI This data element does not reveal 

(nor could be used to calculate) 

details regarding product 

characteristics, actual production 

data, or operating efficiency. It 

does not provide information that 

would allow competitors to infer 

market share, production costs, or 

pricing structures and thus gain a 

competitive advantage. The EPA 

applied the same rationale in the 

2010 proposed and 2011 final 

CBI rules (75 FR 39113 and 76 

FR 30803 - 30806), in support of 

a non-CBI determination for 

reporting of the following same 

data element currently required to 

be reported if a different equation 

(Equation Y-1a) is used: annual 

volume of flare gas combusted 

(scf/year) under 40 CFR 

98.256(e)(6). 

40 CFR 

98.256(e)(11)(

ii) 

Annual 

average 

molecular 

weight of 

flare gas 

combusted 

(in mmBtu 

per MMscf) 

(only when 

Not CBI This data element does not reveal 

(nor could be used to calculate) 

details regarding product 

characteristics, actual production 

data, or operating efficiency. It 

does not provide information that 

would allow competitors to infer 

market share, production costs, or 

pricing structures and thus gain a 
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Subpart Citation 

Data 

Element 

Confidentiality 

Determination 

Proposed Rationale for 

Confidentiality Determination 

using 

Equation Y3). 

competitive advantage. The EPA 

applied the same rationale in the 

2010 proposed and 2011 final 

CBI rules (75 FR 39113 76 FR 

30803 - 30806), in support of a 

non-CBI determination for 

reporting of the following same 

data element currently required to 

be reported if a different equation 

(Equation Y-1a) is used: annual 

average molecular weight of the 

flare gas (kg/kg-mole) under 40 

CFR 98.256(e)(6). 

40 CFR 

98.256(e)(11)(

iii) 

Annual 

average 

carbon 

content of 

flare gas 

combusted 

(expressed as 

a decimal 

fraction)(only 

when using 

Equation Y3). 

Not CBI This data element does not reveal 

(nor could be used to calculate) 

details regarding product 

characteristics, actual production 

data, or operating efficiency. It 

does not provide information that 

would allow competitors to infer 

market share, production costs, or 

pricing structures and thus gain a 

competitive advantage. The EPA 

applied the same rationale in the 

2010 proposed and 2011 final 

CBI rules (75 FR 39113 76 FR 

30803 - 30806), in support of a 

non-CBI determination for 

reporting of the following same 

data element currently required to 

be reported if a different equation 

(Equation Y-1a) is used: annual 

average carbon content of the 

flare gas (kg carbon/kg flare gas) 

under 40 CFR 98.256(e)(6). 

AA - Pulp 

and Paper 

40 CFR 

98.276(l)(2) 

For each pulp 

mill lime 

kiln: Percent 

of annual heat 

input, 

individually 

for each fossil 

fuel type. 

Non-CBI Release of this data would not 

result in competitive harm 

because lime kiln fossil fuel use 

as a fraction of design heat input 

was reported to the EPA as part of 

a 2011 ICR survey, and facilities 

reporting via the survey made no 

CBI claims regarding fuel type 

and percent of design heat input. 

“Unit/Process ‘Static’ Characteristics that Are Not Inputs to Emission Equations” Data Category 

AA - Pulp 

and Paper 

40 CFR 

98.276(m)(2) 

For each 

chemical 

ND1 In the final CBI rulemaking (76 

FR 30799, May 26, 2011), we 
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Subpart Citation 

Data 

Element 

Confidentiality 

Determination 

Proposed Rationale for 

Confidentiality Determination 

recovery 

furnace and 

chemical 

recovery 

combustion 

unit for which 

you are not 

using 

Equation C2c to 

calculate CO2

emissions: 

Ratio of the 

unit’s 

maximum 

rated heat 

input capacity 

to its design 

rated steam 

output 

capacity 

(mmBtu/lb 

steam), 

individually 

for each fossil 

fuel type and 

for spent 

liquor solids. 

determined that the best approach 

for determining confidentiality of 

production capacity is not to make 

a single CBI determination 

applicable to all facilities within a 

given source category, due to 

differences between facilities. For 

all reported data elements related 

to production capacity, the EPA 

will make case-by-case 

determinations per reporter, in 

accordance with the provisions in 

40 CFR part 2, subpart B for 

facilities that claim these data 

elements as CBI. 

1

 ND = No determination was made. 

The EPA is requesting comment on two aspects of these confidentiality determinations. 

First, the EPA seeks comment on the proposed data category assignment for each of these data 

elements in Tables 5 and 6. If you believe that the EPA has improperly assigned any proposed 

new data elements to one of the data categories, please provide specific comments identifying 

which proposed new data elements may be mis-assigned along with a detailed explanation of 

why you believe them to be incorrectly assigned and in which data category you believe they 

best belong. 

Second, for those data elements assigned to the two direct emitter data categories without 

categorical confidentiality determinations, the EPA seeks comment on the individual 
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confidentiality determinations we are proposing for these data elements. If you comment on this 

issue, please provide specific comment along with detailed rationale and supporting information 

on whether such data element does or does not qualify as CBI. 

V. Impacts of the Proposed Rule 

This section examines the cost impacts of the proposed rulemaking. A detailed discussion 

of the impacts may be found in the memorandum, “Impacts Analysis of the Proposed 2015 

Inputs Proposal,” available in EPA docket ID No. EPA–HQ–OAR–2010-0929. 

A. How were the costs of this proposed rule estimated?

1. Proposed Inputs Verification Tool.

The data elements required to be used for calculating the annual GHG emissions values 

and the cost associated with collecting these data have not changed from the estimate made 

during the original rulemaking process. The time associated with entry of these “inputs to 

equations” data elements into e-GGRT (including into the new inputs verification tool) is 

expected to be equivalent to the time originally anticipated for data entry. Prior to the inputs 

verification tool, as currently required, reporters must use their own calculation tool (e.g., 

calculator, calculation software) to calculate the annual GHG emissions values, using the same 

sets of equations and entering the same data elements that they would enter into the tool. 

The EPA does recognize however that there may be some time associated with learning 

the new procedures for the inputs verification tool and we have estimated a cost of 

approximately $66 per facility, or $379,000 for the first year for all affected facilities. During 

their first session using the proposed inputs verification tool, reporters would need to spend 

approximately 1 hour becoming familiar with how the tool operates within e-GGRT. The 

proposed new requirement to use the inputs verification tool would not result in any change in 
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the respondent activity of entering these data into e-GGRT. Once the reporter has become 

familiar with the tool, EPA does not anticipate any additional burden. The cost includes 

technical, clerical, and managerial labor hours. For further information about this cost estimate, 

refer to the memorandum “Assessment of Cost Impacts of 2015 Inputs Proposal – Revisions to 

Reporting, Recordkeeping, and Verification Requirements under the Greenhouse Gas Reporting 

Program” and the supporting statement for this proposed information collection request, 

“Supporting Statement, Environmental Protection Agency: Revisions to Reporting and 

Recordkeeping Requirements, and Proposed Confidentiality Determinations under the 

Greenhouse Gas Reporting Program, OMB control number 2060-[INSERT NEW NUMBER], 

ICR number 2483.01,” both available in docket EPA–HQ–OAR–2010-0929. 

2. Proposed New Data Elements.

We are proposing to add 26 new data elements that were not previously required to be 

reported under Part 98 (see Section II.D of this preamble for further discussion of this proposed 

amendment), to be reported by facilities in certain subparts that are required to use the proposed 

inputs verification tool. Of these 26 data elements, nine data elements are related to annual 

production or raw material usage, which are collected by a facility as a routine part of conducting 

business. For these data elements, we are not proposing that reporters comply with specific data 

collection or monitoring requirements beyond the methods commonly used for accounting 

purposes. The other 17 data elements proposed to be reported are calculated values using data 

currently required to be collected to perform emissions calculations. For all of these additional 

data elements, the EPA has estimated a nominal additional cost to report the data element and 

fulfill the recordkeeping requirements. The total costs associated with reporting and 
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recordkeeping for the 26 data elements in 10 subparts is $80,000. These costs represent the cost 

for all affected facilities in the first year. 

B. Additional Impacts of the Proposed Amendments

The proposed confidentiality determinations for the new data elements would not affect 

whether and how data are reported and, therefore, would not impose any additional burden on 

sources. 

VI. Statutory and Executive Order Reviews 

A. Executive Order 12866: Regulatory Planning and Review and Executive Order 13563: 

Improving Regulation and Regulatory Review

Under Executive Order 12866 (58 FR 51735, October 4, 1993), this action is a 

“significant regulatory action” because this action raises novel legal or policy issues arising out 

of legal mandates, the President’s priorities, or principles set forth in the executive order. 

Accordingly, the EPA submitted this action to the Office of Management and Budget (OMB) for 

review under Executive Orders 12866 and 13563 (76 FR 3821, January 21, 2011) and any 

changes made in response to OMB recommendations have been documented in the docket for 

this action. 

B. Paperwork Reduction Act

This action proposes to amend reporting and recordkeeping requirements and verification 

procedures for the GHGRP. In addition, the EPA is proposing confidentiality determinations for 

the proposed new data elements in this action. The proposed amendments to the reporting 

requirements in the source category-specific subparts are not anticipated to result in significant 

burden for reporters. The new data elements required to be reported are expected to be readily 
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available for affected facilities, or easily calculated using data already required to be collected 

(e.g., a monthly value is currently reported and an annual value is proposed to be reported). 

Impacts associated with the proposed changes to the reporting requirements in each 

subpart are detailed in the memorandum “Impacts Analysis of the Proposed 2015 Inputs 

Proposal” (see Docket ID No. EPA-HQ-OAR-2010-0929). The Office of Management and 

Budget (OMB) has previously approved the information collection requirements for 40 CFR part 

98 under the provisions of the Paperwork Reduction Act, 44 U.S.C. 3501 et seq and has assigned 

OMB control number 2060-0629, ICR 2300.10. OMB has approved the information collection 

requirements for this rulemaking and has assigned OMB control number 2060-new, ICR 

2483.01. The OMB control numbers for the EPA’s regulations in 40 CFR are listed in 40 CFR 

part 9. 

C. Regulatory Flexibility Act (RFA)

The RFA generally requires an agency to prepare a regulatory flexibility analysis of any 

rule subject to notice and comment rulemaking requirements under the Administrative Procedure 

Act or any other statute unless the agency certifies that the rule will not have a significant 

economic impact on a substantial number of small entities. Small entities include small 

businesses, small organizations, and small governmental jurisdictions. 

For purposes of assessing the impacts of the proposed amendments on small entities, 

“small entity” is defined as: (1) A small business as defined by the Small Business 

Administration’s regulations at 13 CFR 121.201; (2) a small governmental jurisdiction that is a 

government of a city, county, town, school district or special district with a population of less 

than 50,000; or (3) a small organization that is any not-for-profit enterprise which is 
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independently owned and operated and is not dominant in its field. This definition of small entity 

is consistent with the definition of small entity used for Part 98. 

After considering the economic impacts of today’s proposed amendments on small 

entities, I certify that this action will not have a significant economic impact on a substantial 

number of small entities. The small entities subject to Part 98 include small businesses across all 

sectors of the economy encompassed by Part 98, small governmental jurisdictions, and small 

non-profits. The impacts of these proposed amendments are expected to be roughly a first-year 

cost of $66 per facility for learning new procedures for the verification tool and an annual cost of 

$100 per facility for the recordkeeping and reporting of 26 new data elements. 

The EPA continues to be interested in the potential impacts of the proposed rule 

amendments on small entities and welcomes comments on issues related to such impacts. 

D. Unfunded Mandates Reform Act (UMRA)

The proposed amendments and confidentiality determinations do not contain a federal 

mandate that may result in expenditures of $100 million or more for State, local, and tribal 

governments, in the aggregate, or the private sector in any one year. Thus, the proposed 

amendments and confidentiality determinations are not subject to the requirements of sections 

202 or 205 of UMRA. 

This rule is also not subject to the requirements of section 203 of UMRA because it 

contains no regulatory requirements that might significantly or uniquely affect small 

governments. This action proposes to amend reporting and recordkeeping requirements and 

verification procedures for the GHGRP. In addition, the EPA is proposing confidentiality 

determinations for the proposed new data elements in this action. Therefore, this action is not 

subject to the requirements of section 203 of the UMRA. 
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E. Executive Order 13132: Federalism

The action does not have federalism implications. It will not have substantial direct 

effects on the states, on the relationship between the national government and the states, or on 

the distribution of power and responsibilities among the various levels of government, as 

specified in Executive Order 13132. The proposed amendments and confidentiality 

determinations apply to facilities that directly emit greenhouses gases and fuel and chemicals 

suppliers. These proposed changes do not apply to governmental entities unless the government 

entity owns a facility that directly emits GHGs above threshold levels (such as a large stationary 

combustion device), so relatively few government facilities would be affected. Moreover, for 

government facilities that are subject to the rule, the proposed revisions will not have a 

significant cost impact. This proposed action also does not limit the power of states or localities 

to collect GHG data and/or regulate GHG emissions. Thus, Executive Order 13132 does not 

apply to this rule. 

In the spirit of Executive Order 13132, and consistent with EPA policy to promote 

communications between the EPA and state and local governments, the EPA specifically solicits 

comments on this proposed action from state and local officials. 

F. Executive Order 13175: Consultation and Coordination with Indian Tribal Governments.

This proposed action does not have tribal implications, as specified in Executive Order 

13175 (65 FR 67249, November 9, 2000). The proposed amendments and confidentiality 

determinations apply directly to facilities that directly emit greenhouses gases or that are 

suppliers of GHGs. They would not have tribal implications unless the tribal entity owns a 

facility that directly emits GHGs above threshold levels (such as a landfill or large combustion 
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device). Relatively few tribal facilities would be affected. Thus, Executive Order 13175 does not 

apply to this action. 

G. Executive Order 13045: Protection of Children from Environmental Health Risks and Safety 

Risks

The EPA interprets Executive Order 13045 (62 FR 19885, April 23, 1997) as applying 

only to those regulatory actions that concern health or safety risks, such that the analysis required 

under section 5-501 of the Executive Order has the potential to influence the regulation. This 

proposed action is not subject to Executive Order 13045 because it does not establish an 

environmental standard intended to mitigate health or safety risks. 

H. Executive Order 13211: Actions that Significantly Affect Energy Supply, Distribution, or Use

This proposed action is not a “significant energy action” as defined in Executive Order 

13211 (66 FR 28355, May 22, 2001), because it is not likely to have a significant adverse effect 

on the supply, distribution, or use of energy. Part 98 relates to monitoring, reporting, and 

recordkeeping and does not impact energy supply, distribution, or use. This action proposes to

amend reporting and recordkeeping requirements and verification procedures for the GHGRP. In 

addition, the EPA is proposing confidentiality determinations for the proposed new data 

elements in this action. These proposed amendments and confidentiality determinations do not 

make any changes to the existing monitoring, recordkeeping, or reporting requirements under 

Part 98 that affect the supply, distribution, or use of energy. 

I. National Technology Transfer and Advancement Act

Section 12(d) of the National Technology Transfer and Advancement Act of 1995 

(NTTAA), Public Law No. 104-113, 12(d) (15 U.S.C. 272 note) directs the EPA to use voluntary 

consensus standards in its regulatory activities unless to do so would be inconsistent with 
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Page 59 of 96 

applicable law or otherwise impractical. Voluntary consensus standards are technical standards 

(e.g., materials specifications, test methods, sampling procedures, and business practices) that are 

developed or adopted by voluntary consensus standards bodies. NTTAA directs the EPA to 

provide Congress, through OMB, explanations when the Agency decides not to use available and 

applicable voluntary consensus standards. 

This proposed rulemaking does not involve the use of any new technical standards. 

Therefore, the EPA is not considering the use of any voluntary consensus standards. 

J. Executive Order 12898: Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations

Executive Order 12898 (59 FR 7629, February 16, 1994) establishes federal executive 

policy on environmental justice. Its main provision directs federal agencies, to the greatest extent 

practicable and permitted by law, to make environmental justice part of their mission by 

identifying and addressing, as appropriate, disproportionately high and adverse human health or 

environmental effects of their programs, policies, and activities on minority populations and lowincome populations in the United States. 

The EPA has determined that these proposed rule amendments will not have 

disproportionately high and adverse human health or environmental effects on minority or lowincome populations because the amendments do not affect the level of protection provided to 

human health or the environment. This is because the proposed amendments address information 

collection and reporting and verification procedures. 
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Proposed Rule Amendments and Confidentiality Determinations 

for Certain Data Elements Required under the 

Mandatory Greenhouse Gas Reporting Rule 

Page 60 of 96 

List of Subjects 40 CFR Part 98 

Environmental protection, Administrative practice and procedure, Greenhouse gases, 

Reporting and recordkeeping requirements. 

Dated: 

 

Gina McCarthy, 

Administrator. 
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For the reasons stated in the preamble, title 40, chapter I, of the Code of Federal 

Regulations is proposed to be amended as follows: 

PART 98—[AMENDED] 

1.The authority citation for part 98 continues to read as follows: 

Authority: 42 U.S.C. 7401, et seq. 

Subpart A—[AMENDED] 

2.Section 98.3 is amended by revising paragraphs (c)(4)(vii), (d)(3)(v), (g) introductory 

text, and (g)(2)(i) to read as follows: 

§ 98.3 What are the general monitoring, reporting, recordkeeping and verification 

requirements of this part. 

* * * * * 

(c) * * * 

(4) * * * 

(vii) The owner or operator of a facility is not required to report the data elements 

specified in Table A-6 to this subpart for calendar years 2010 through 2011 until March 31, 

2013. The owner or operator of a facility is not required to report the data elements specified in 

Table A-7 to this subpart for calendar years 2010 through 2013 until March 31, 2015. Data 

elements specified in Table A-7 to this subpart for calendar years 2010 through 2013 must be 

submitted as part of the annual report for reporting year 2014. 

* * * * * 

(d) * * * 

(3) * * * 
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(v) For each stationary fuel combustion source that that meets the criteria specified in § 

98.36(f) of this part, report any facility operating data or process information used for the GHG 

emission calculations. 

* * * * * 

(g) Recordkeeping. An owner or operator that is required to report GHGs under this part 

must keep records as specified in this paragraph. Except as otherwise provided in this paragraph, 

retain all required records for at least 3 years from the date of submission of the annual GHG 

report for the reporting year in which the record was generated. The records shall be kept in an 

electronic or hard-copy format (as appropriate) and recorded in a form that is suitable for 

expeditious inspection and review. If a reporter is required under § 98.5(b) to use software 

specified by the Administrator to enter data to calculate the reported GHGs, all records required 

under Part 98 must be retained by the reporter for 5 years from the date of submission of the 

annual GHG report for the reporting year in which the record was generated. Upon request by 

the Administrator, the records required under this section must be made available to EPA. 

Records may be retained off site if the records are readily available for expeditious inspection 

and review. For records that are electronically generated or maintained, the equipment or 

software necessary to read the records shall be made available, or, if requested by EPA, 

electronic records shall be converted to paper documents. You must retain the following records, 

in addition to those records prescribed in each applicable subpart of this part: 

* * * * * 

(2) * * * 
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(i) The GHG emissions calculations and methods used. For data required by § 98.5(b) to 

be entered into the software specified by the Administrator, maintain the entered data in the 

format generated by the software specified by the Administrator. 

* * * * * 

3.Section 98.5 is revised to read as follows: 

§ 98.5 How is the report submitted? 

(a) Each GHG report and certificate of representation for a facility or supplier must be 

submitted electronically in accordance with the requirements of § 98.4 and in a format specified 

by the Administrator. 

(b) For reporting year 2014 and thereafter, you must enter into verification software 

specified by the Administrator the data used as inputs to the calculation methods specified in 

Table A-8 to Part 98, excluding data required to be reported in the reporting section of each 

subpart listed in Table A-8 to Part 98. 

4.Table A-7 to Subpart A of Part 98 is revised to read as follows: 

Table A–7 to Subpart A of Part 98—Data Elements That Are Inputs to Emission Equations 

and for Which the Reporting Deadline Is March 31, 2015 

Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which reporting date is 

March 31, 2015 (“All” means all data elements in 

the cited paragraph are not required to be 

reported until March 31, 2015) 

A 98.3(d)(3)(v) All. 

C 98.36(b)(9)(iii) Only estimate of the heat input.1

C 98.36(c)(2)(ix) Only estimate of the heat input from each type of fuel 

listed in Table C–2.1

C 98.36(e)(2)(i) All.1

C 98.36(e)(2)(ii)(A) All.1

C 98.36(e)(2)(ii)(C) Only HHV value for each calendar month in which 

HHV determination is required.1
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which reporting date is 

March 31, 2015 (“All” means all data elements in 

the cited paragraph are not required to be 

reported until March 31, 2015) 

C 98.36(e)(2)(ii)(D) All.1

C 98.36(e)(2)(iv)(A) All.1

C 98.36(e)(2)(iv)(C) All.1

C 98.36(e)(2)(iv)(F) All.1

C 98.36(e)(2)(ix)(D) All.1

C 98.36(e)(2)(ix)(E) All.1

C 98.36(e)(2)(ix)(F) All.1

E 98.56(g) All. 

E 98.56(h) All. 

E 98.56(j)(4) All. 

E 98.56(j)(5) All. 

E 98.56(j)(6) All. 

E 98.56(l) All. 

H 98.86(b)(11) All. 

H 98.86(b)(13) Name of raw kiln feed or raw material. 

L 98.126(b)(10) All. 

L 98.126(b)(11) All. 

L 98.126(b)(12) All. 

O 98.156(d)(2) All. 

O 98.156(d)(3) All. 

O 98.156(d)(4) All. 

Q 98.176(f)(1) All. 

V 98.226(i) All. 

V 98.226(j) All. 

V 98.226(m)(4) All. 

V 98.226(m)(5) All. 

V 98.226(m)(6) All. 
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which reporting date is 

March 31, 2015 (“All” means all data elements in 

the cited paragraph are not required to be 

reported until March 31, 2015) 

V 98.226(p) All. 

W 98.236(c)(1)(i) All. 

W 98.236(c)(1)(ii) All. 

W 98.236(c)(1)(iii) All. 

W 98.236(c)(2)(i) All. 

W 98.236(c)(3)(i) All. 

W 98.236(c)(3)(ii) All. 

W 98.236(c)(3)(iii) All. 

W 98.236(c)(4)(i)(A) All. 

W 98.236(c)(4)(i)(B) All. 

W 98.236(c)(4)(i)(C) All. 

W 98.236(c)(4)(i)(D) All. 

W 98.236(c)(4)(i)(E) All. 

W 98.236(c)(4)(i)(F) All. 

W 98.236(c)(4)(i)(G) All. 

W 98.236(c)(4)(i)(H) All. 

W 98.236(c)(4)(ii)(A) All. 

W 98.236(c)(5)(iii) All. 

W 98.236(c)(5)(iv) All. 

W 98.236(c)(5)(v) All. 

W 98.236(c)(6)(i)(B) All. 

W 98.236(c)(6)(i)(D) All. 

W 98.236(c)(6)(i)(E) All. 

W 98.236(c)(6)(i)(F) All. 

W 98.236(c)(6)(ii)(A) All. 

W 98.236(c)(6)(ii)(B) All. 

W 98.236(c)(7)(i) All. 
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which reporting date is 

March 31, 2015 (“All” means all data elements in 

the cited paragraph are not required to be 

reported until March 31, 2015) 

W 98.236(c)(8)(i)(B) All. 

W 98.236(c)(8)(i)(C) All. 

W 98.236(c)(8)(i)(F) All. 

W 98.236(c)(8)(ii)(A) All. 

W 98.236(c)(8)(ii)(D) All. 

W 98.236(c)(8)(iii)(A) All. 

W 98.236(c)(8)(iii)(D) All. 

W 98.236(c)(8)(iii)(E) All. 

W 98.236(c)(10)(ii) All. 

W 98.236(c)(10)(iii) All. 

W 98.236(c)(11)(ii) All. 

W 98.236(c)(12)(ii) All. 

W 98.236(c)(12)(iii) All. 

W 98.236(c)(12)(v) All. 

W 98.236(c)(13)(i)(B) All. 

W 98.236(c)(13)(i)(E) All. 

W 98.236(c)(13)(i)(F) All. 

W 98.236(c)(13)(ii)(A) All. 

W 98.236(c)(13)(ii)(B) All. 

W 98.236(c)(13)(iii)(A) All. 

W 98.236(c)(13)(iii)(B) All. 

W 98.236(c)(13)(v)(A) All. 

W 98.236(c)(14)(i)(B) All. 

W 98.236(c)(14)(ii)(A) All. 

W 98.236(c)(14)(ii)(B) All. 

W 98.236(c)(14)(iii)(A) All. 

W 98.236(c)(14)(iii)(B) All. 
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which reporting date is 

March 31, 2015 (“All” means all data elements in 

the cited paragraph are not required to be 

reported until March 31, 2015) 

W 98.236(c)(14)(v)(A) All. 

W 98.236(c)(15)(i)(A) All. 

W 98.236(c)(15)(i)(B) All. 

W 98.236(c)(15)(ii)(A) All. 

W 98.236(c)(15)(ii)(B) All. 

W 98.236(c)(16)(i) All. 

W 98.236(c)(16)(ii) All. 

W 98.236(c)(16)(iii) All. 

W 98.236(c)(16)(iv) All. 

W 98.236(c)(16)(v) All. 

W 98.236(c)(16)(vi) All. 

W 98.236(c)(16)(vii) All. 

W 98.236(c)(16)(viii) All. 

W 98.236(c)(16)(ix) All. 

W 98.236(c)(16)(x) All. 

W 98.236(c)(16)(xi) All. 

W 98.236(c)(16)(xii) All. 

W 98.236(c)(16)(xiii) All. 

W 98.236(c)(16)(xiv) All. 

W 98.236(c)(17)(ii) All. 

W 98.236(c)(17)(iii) All. 

W 98.236(c)(17)(iv) All. 

W 98.236(c)(18)(i) All. 

W 98.236(c)(18)(ii) All. 

W 98.236(c)(19)(iv) All. 

W 98.236(c)(19)(vii) All. 

Y 98.256(h)(5) Only value of the correction. 
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which reporting date is 

March 31, 2015 (“All” means all data elements in 

the cited paragraph are not required to be 

reported until March 31, 2015) 

Y 98.256(k)(4) Only mole fraction of methane in coking gas. 

Y 98.256(n)(3) All (if used in Equation Y–21 to calculate emissions 

from equipment leaks). 

Y 98.256(o)(4)(vi) Only tank-specific methane composition data and gas 

generation rate data. 

AA 98.276(e) All. 

CC 98.296(b)(10)(i) All. 

CC 98.296(b)(10)(ii) All. 

CC 98.296(b)(10)(iii) All. 

CC 98.296(b)(10)(iv) All. 

CC 98.296(b)(10)(v) All. 

CC 98.296(b)(10)(vi) All. 

II 98.356(d)(2) All (if conducting weekly sampling). 

II 98.356(d)(3) All (if conducting weekly sampling). 

II 98.356(d)(4) Only weekly average temperature (if conducting 

weekly sampling). 

II 98.356(d)(5) Only weekly average moisture content (if conducting 

weekly sampling). 

II 98.356(d)(6) Only weekly average pressure (if conducting weekly 

sampling). 

1

 Required to be reported only by stationary fuel combustion sources (e.g., individual units, 

aggregations of units, common pipes, or common stacks) subject to subpart C of part 98 that 

meet both of the following criteria: (1) the stationary fuel combustion source contains at least 

one combustion unit connected to a fuel-fired electric generator that has been granted access by 

the Public Utilities Commission to deliver power to the local or regional electric power grid 

(excluding generators that are connected to combustion units subject to subpart D of this part); 

and (2) the stationary fuel combustion source is located at a facility for which the sum of the 

nameplate capacities for all such electric generators is greater than or equal to 1 megawatt 

electric output. 

5.Table A-8 to Subpart A of Part 98 is added to read as follows: 
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Table A–8 to Subpart A of Part 98—Calculation Methods For Which Inputs To the 

Calculation Methods Must be Entered Into Verification Software Specified By the 

Administrator. 

Subpart Calculation Method (Equation Number in 40 CFR Part 98 or Description 

of Method) 

Subpart C 1 C-1, C-1a, C-1b, C-2b, C-2c, C-3, C-4, C-5, C-8, C-8a, C-8b, C-10, C-13, the 

calculation method specified in § 98.3(d)(3)(iv) of subpart A of part 98 

Subpart E E-1, E-2, E-3a, E-3b, E-3c, E-3d 

Subpart F F-2 (including the method for calculating the anode effect minutes per cell-day 

(AEM) and slope coefficients (SCF4), F-3 (including the method for 

calculating the overvoltage factor (EFCF4)), F-5, F-6, F-7, F-8 

Subpart G G-1, G-2, G-3 

Subpart H H-2 (including the method in § 98.84(d) of subpart H of part 98 for calculating 

the quantity of clinker produced), H-3, H-4, H-5 

Subpart K K-1, K-3 

Subpart L L-1, L-2, L-3, L-4, L-6, L-7, L-8, L-17, L-18, L-20, L-21, L-22, L-23, L-25, L26, L-27, L-31, L-34 

Subpart N N-1 

Subpart O O-3, O-4, O-8, O-9 (including the calculation method specified in § 

98.154(l)(2) of subpart O of part 98) 

Subpart P P-1, P-2, P-3 

Subpart Q Q-1, Q-2, Q-3, Q-4, Q-5, Q-6, Q-7, the calculation methods specified in § 

98.173(b)(2)(iii), (b)(2)(iv), and (c) of subpart Q of part 98 

Subpart R R-1 

Subpart S S-1, S-2, S-3, S-4 (including the calculation method specified in § 98.194(a) 

Subpart U U-1, U-2 

Subpart V V-2, V-3a, V-3b, V-3c, V-3d 

Subpart X X-1, X-2, X-3, C-8 

Subpart Y Y-1a, Y-1b, Y-3, Y-4, Y-6, Y-8, Y-11, Y-12 (including the method for 

correcting the calculation, if applicable, as specified in § 98.253(f)(5)), Y-13, 

Y-14, Y-15, Y-16a, Y-16b, Y-17, Y-18, Y-19, Y-20, Y-22, Y-23, the methods 

for calculating emissions from coke burn-off specified in § 98.253(c)(4) and 

(5) (alternatives to using Equations Y-9 and Y-10 of Part 98), the calculation 

method specified in § 98.253(n) of subpart Y of part 98 

Subpart Z Z-1a, Z-1b 

Subpart AA C-1, C-1a, C-1b, C-2a, C-3, C-4, C-5, C-8, C-8a, C-8b, C-9a, AA-1, AA-2, 

AA-3 

Subpart BB BB-1, BB-2 

Subpart CC CC-1, CC-2 

Subpart EE EE-2 

Subpart GG GG-1 

Subpart TT TT-2, TT-3 

1

 Does not apply to any stationary fuel combustion sources (e.g., individual units, aggregations of 

units, common pipes, or common stacks) meeting both of the following criteria: (1) the 
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stationary fuel combustion source contains at least one combustion unit connected to a fuel-fired 

electric generator electric (excluding generators that are connected to combustion units subject to 

subpart D of this part); and (2) the stationary fuel combustion source is located at a facility for 

which the sum of the nameplate capacities for all such electric generators is greater than or equal 

to 1 megawatt electric output. 

Subpart C—[AMENDED] 

6.Section 98.36 is amended by: 

a. Revising paragraph (a). 

b. Revising paragraph (b)(9)(iii) and adding paragraph (b)(9)(iv). 

c. Revising paragraph (c)(2)(ix) and adding paragraph (c)(2)(x). 

d. Revising paragraphs (e)(2)(i), (e)(2)(ii)(A), (e)(2)(ii)(C), and (e)(2)(ii)(D); and adding 

paragraph (e)(2)(ii)(E). 

e. Revising paragraphs (e)(2)(iv)(A), (e)(2)(iv)(C), (e)(2)(iv)(F), and (e)(2)(ix)(D) 

through (F); and adding paragraph (f). 

The revisions and additions read as follows: 

§ 98.36 Data reporting requirements. 

* * * * * 

(a) In addition to the facility-level information required under §98.3, the annual GHG 

emissions report shall contain the unit-level or process-level data specified in paragraphs (b) 

through (f) of this section, as applicable, for each stationary fuel combustion source (e.g., 

individual unit, aggregation of units, common pipe, or common stack). 

(b) * * * 

(9) * * * 

(iii) The annual CH4 and N2O emissions for each type of fuel listed in Table C–2 of this 

subpart that was combusted in the unit during the report year, expressed in metric tons of each 

gas and in metric tons of CO2e. 
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(iv) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, report an estimate of the heat input from each type of fuel listed in 

Table C–2 of this subpart that was combusted in the unit during the report year. 

* * * * * 

(c) * * * 

(2) * * * 

(ix) For each type of fuel listed in Table C–2 of this subpart that was combusted during 

the report year in the units sharing the common stack or duct during the report year, the annual 

CH4 and N2O mass emissions from the units sharing the common stack or duct, expressed in 

metric tons of each gas and in metric tons of CO2 e. 

(x) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, an estimate of the heat input from each type of fuel listed in Table 

C–2 of this subpart that was combusted during the report year in the units sharing the common 

stack or duct during the report year. 

* * * * * 

(e) * * * 

(2) * * * 

(i) For the Tier 1 Calculation Methodology, for each stationary fuel combustion source 

that meets the criteria specified in paragraph (f) of this section, report the total quantity of each 

type of fuel combusted in the unit or group of aggregated units (as applicable) during the 

reporting year, in short tons for solid fuels, gallons for liquid fuels and standard cubic feet for 

gaseous fuels, or, if applicable, therms or mmBtu for natural gas. 

(ii) * * * 
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(A) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, the total quantity of each type of fuel combusted in the unit or group 

of aggregated units (as applicable) during each month of the reporting year. Express the quantity 

of each fuel combusted during the measurement period in short tons for solid fuels, gallons for 

liquid fuels, and scf for gaseous fuels. 

* * * * * 

(C) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, the high heat values used in the CO2 emissions calculations for each 

type of fuel combusted during the reporting year, in mmBtu per short ton for solid fuels, mmBtu 

per gallon for liquid fuels, and mmBtu per scf for gaseous fuels. Report a HHV value for each 

calendar month in which HHV determination is required. If multiple values are obtained in a 

given month, report the arithmetic average value for the month. Indicate whether each reported 

HHV is a measured value or a substitute data value. 

(D) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, if Equation C–2c of this subpart is used to calculate CO2 mass 

emissions, report the total quantity (i.e., pounds) of steam produced from MSW or solid fuel 

combustion during each month of the reporting year, and the ratio of the maximum rate heat 

input capacity to the design rated steam output capacity of the unit, in mmBtu per lb of steam. 

(E) For each HHV used in the CO2 emissions calculations for each type of fuel 

combusted during the reporting year, indicate whether the HHV is a measured value or a 

substitute data value. 

* * * * * 

(iv) * * * 
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(A) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, the quantity of each type of fuel combusted in the unit or group of 

units (as applicable) during each month of the reporting year, in short tons for solid fuels, gallons 

for liquid fuels, and scf for gaseous fuels. 

* * * * * 

(C) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, the carbon content and, if applicable, gas molecular weight values 

used in the emission calculations (including both valid and substitute data values). For each 

calendar month of the reporting year in which carbon content and, if applicable, molecular 

weight determination is required, report a value of each parameter. If multiple values of a 

parameter are obtained in a given month, report the arithmetic average value for the month. 

Express carbon content as a decimal fraction for solid fuels, kg C per gallon for liquid fuels, and 

kg C per kg of fuel for gaseous fuels. Express the gas molecular weights in units of kg per kgmole. 

* * * * * 

(F) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, the annual average HHV, when measured HHV data, rather than a 

default HHV from Table C–1 of this subpart, are used to calculate CH4 and N2O emissions for a 

Tier 3 unit, in accordance with §98.33(c)(1). 

* * * * * 

(ix) * * * 
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(D) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, the carbon-based F-factor used in Equation C–13 of this subpart, for 

each type of fossil fuel combusted, in scf CO2 per mmBtu. 

(E) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, the annual average HHV value used in Equation C–13 of this 

subpart, for each type of fossil fuel combusted, in Btu/lb, Btu/gal, or Btu/scf, as appropriate. 

(F) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, the total quantity of each type of fossil fuel combusted during the 

reporting year, in lb, gallons, or scf, as appropriate. 

* * * * * 

(f) Each stationary fuel combustion source (e.g., individual unit, aggregation of units, 

common pipe, or common stack) subject to reporting under paragraph (b), (c), or (d)(2) of this 

section must indicate if both of the following two conditions are met: 

(1) The stationary combustion source contains at least one combustion unit connected to 

a fuel-fired electric generator that has been granted access by the Public Utilities Commission to 

deliver power to the local or regional electric power grid (excluding generators that are 

connected to combustion units that are subject to subpart D of this part). 

(2) The stationary fuel combustion source is located at a facility for which the sum of the 

nameplate capacities for all electric generators specified in paragraph (f)(1) of this section is 

greater than or equal to 1 megawatt electric output. 

Subpart E—[AMENDED] 

7.Section 98.56 is amended by: 

a. Revising the introductory text. 
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b. Removing and reserving paragraphs (b), (c), (j)(1), and (j)(3). 

c. Adding paragraphs (m) and (n). 

The revisions and additions read as follows: 

§ 98.56 Data reporting requirements. 

In addition to the information required by §98.3(c), each annual report must contain the 

information specified in paragraphs (a) through (n) of this section at the facility level. 

* * * * * 

(m) Annual quantity of cyclohexane fed to all production lines combined (metric tons). 

(n) Annual percent N2O emission reduction for all production units combined. 

* * * * * 

Subpart F—[AMENDED] 

8.Section 98.66 is amended by: 

a. Removing and reserving paragraphs (a) and (c)(2). 

b. Revising paragraphs (c)(3), (e)(1), and (f)(1). 

c. Removing and reserving paragraph (g). 

The revisions read as follows: 

§ 98.66 Data reporting requirements. 

* * * * * 

(c) * * * 

(3) The last date when the smelter-specific-slope coefficients (or overvoltage emission 

factors) were measured. 

* * * * * 

(e) * * * 
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(1) Annual anode consumption if using the method in §98.63(g). 

* * * * * 

(f) * * * 

(1) Annual paste consumption if using the method in §98.63(g). 

* * * * * 

Subpart G—[AMENDED] 

9.Section 98.76 is amended by: 

a. Revising the introductory text. 

b. Removing and reserving paragraph (b)(2) and paragraphs (b)(7) through (11). 

c. Adding paragraphs (c) and (d). 

The revisions and additions read as follows: 

§ 98.76 Data reporting requirements. 

In addition to the information required by §98.3(c), each annual report must contain the 

information specified in paragraphs (a) through (d) of this section, as applicable for each 

ammonia manufacturing process unit. 

* * * * * 

(c) Annual ammonia production (metric tons). 

(d) Annual methanol production (metric tons), if this quantity is not reported under 

subpart X of Part 98. 

Subpart H—[AMENDED] 

10. Section 98.86 is amended by: 

a. Removing and reserving paragraphs (b)(2), (b)(5), (b)(6), (b)(8), (b)(10), and (12). 

b. Revising paragraphs (b)(13) and (15). 
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c. Adding paragraphs (b)(16) through (18). 

The revisions and additions read as follows: 

§ 98.86 Data reporting requirements. 

* * * * * 

(b) * * * 

(13) Name of raw kiln feed or raw material. 

* * * * * 

(15) Method used to determine the monthly clinker production from each kiln. 

(16) Annual clinker production (metric tons). 

(17) Annual average clinker CO2 emission factor for the facility, averaged across all kilns 

(metric tons CO2/metric ton clinker produced). 

(18) Annual average CKD CO2 emission factor for the facility, averaged across all kilns 

(metric tons CO2/metric ton CKD produced). 

Subpart K—[AMENDED] 

11. Section 98.116 is amended by: 

a. Removing and reserving paragraphs (b), (e)(4), and (e)(5). 

b. Revising paragraph (e)(6). 

The revisions read as follows: 

§ 98.116 Data reporting requirements. 

* * * * * 

(e) * * * 
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(6) List the method used for the determination of carbon content for each material 

included for the calculation of annual process CO2 emissions for each EAF (e.g., supplier 

provided information, analyses of representative samples you collected). 

* * * * * 

Subpart L—[AMENDED] 

12. Section 98.126 is amended by: 

a. Revising paragraph (b)(1). 

b. Removing and reserving paragraph (b)(2). 

c. Revising paragraphs (b)(6), (b)(7), and (b)(8)(i) through (iv). 

d. Removing and reserving paragraphs (b)(8)(v) and (b)(9). 

e. Revising paragraph (c)(1). 

f. Removing and reserving paragraph (c)(2). 

g. Revising paragraph (d). 

h. Removing and reserving paragraphs (f)(1), (g)(1), and (h)(2). 

The revisions read as follows: 

§ 98.126 Data reporting requirements. 

* * * * * 

(b) * * * 

(1) If you calculate the relative and absolute errors under § 98.123(b)(1), the absolute and 

relative errors calculated under paragraph § 98.123(b)(1). 

* * * * * 

(6) The chemical formula of each fluorine-containing reactant that is fed into the process. 

(7) The chemical formula of each fluorine-containing product produced by the process. 
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Page 79 of 96 

(8) * * * 

(i) The chemical formula of each fluorine-containing product that is removed from the 

process and fed into the destruction device. 

(ii) The chemical formula of each fluorine-containing by-product that is removed from 

the process and fed into the destruction device. 

(iii) The chemical formula of each fluorine-containing reactant that is removed from the 

process and fed into the destruction device. 

(iv) The chemical formula of each fluorine-containing by-product that is removed from 

the process and recaptured. 

* * * * * 

(c) * * * 

(1) The identity of the process activity used to estimate emissions (e.g., product produced 

or reactant consumed). 

* * * * * 

(d) Reporting for missing data. Where missing data have been estimated pursuant to § 

98.125, you must report: 

(1) The reason the data were missing, the length of time the data were missing, and the 

method used to estimate the missing data. 

(2) Estimates of the missing data for all data required to be reported in this section that 

are inputs to calculation methods specified in § 98.123. 

* * * * * 

Subpart N—[AMENDED] 
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13. Section 98.146 is amended by revising paragraph (b)(2) and removing and 

reserving paragraphs (b)(4) and (b)(6) to read as follows: 

§ 98.146 Data reporting requirements. 

* * * * * 

(b) * * * 

(2) Annual quantity of each carbonate-based raw material charged (tons) to all furnaces 

combined. 

* * * * * 

Subpart O—[AMENDED] 

14. Section 98.156 is amended by: 

a. Removing and reserving paragraphs (a)(2), (a)(7) through (10), (b)(1), and (b)(2). 

b. Revising paragraph (d) introductory text. 

c. Removing and reserving paragraphs (d)(1), (d)(5), and (e)(1). 

The revisions read as follows: 

§ 98.156 Data reporting requirements. 

* * * * * 

(d) If the HFC–23 concentration measured pursuant to §98.154(l) is greater than that 

measured during the performance test that is the basis for the destruction efficiency (DE), the 

facility shall report the following: 

* * * * * 

Subpart P—[AMENDED] 

15. Section 98.166 is amended by: 

a. Revising the introductory text. 
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b. Removing and reserving paragraphs (b)(2), (b)(5), and (b)(6). 

c. Adding paragraphs (b)(7) and (e). 

The revisions and additions read as follows: 

§ 98.166 Data reporting requirements. 

In addition to the information required by §98.3(c), each annual report must contain the 

information specified in paragraphs (a) or (b) of this section, as appropriate, and paragraphs (c) 

through (e) of this section: 

* * * * * 

(b) * * * 

(7) Name and annual quantity (metric tons) of each carbon-containing fuel and feedstock. 

* * * * * 

(e) Annual methanol production (metric tons), if this quantity is not reported under 

subpart X of Part 98. 

Subpart Q—[AMENDED] 

16. Section 98.176 is amended by: 

a. Revising paragraph (b). 

b. Removing and reserving paragraphs (e)(1), (e)(3), (e)(4); and adding paragraph (e)(6). 

c. Removing and reserving paragraphs (f)(2) through (4), and (g). 

The revisions and additions read as follows: 

§ 98.176 Data reporting requirements. 

* * * * * 
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(b) If a CEMS is used to measure CO2 emissions, then you must report the annual 

production quantity for the production unit (in metric tons) for taconite pellets, coke, sinter, iron, 

and raw steel. 

* * * * * 

(e) * * * 

(6) The information specified in paragraphs (e)(6)(i) through (vi) of this section 

aggregated for all process units for which CO2 emissions were determined using the mass 

balance method in § 98.173(b)(1), except as provided in § 98.174(b)(4). 

(i) The annual mass (metric tons) of all gaseous, liquid, and solid fuels (combined) used 

in process units for which CO2 emissions were determined using Equations Q-1 through Q-7 of 

this section, calculated as specified in Equation Q-9 of this section. 

ݑܨ݈݁ 	ൌ ቀ∑ ܨ௚, ∗ 	௜ெௐ೔

ெ௏஼

௡

௜ୀଵ ∗ 0.001 ൅ ܨ௟, ∗ ௜ߩ௟, ∗ ௜0.001	൅ ܨ௦,௜ቁ	 (Eq. Q-9) 

Where: 

Fuel = Annual mass of all gaseous, liquid, and solid fuels used in process units 

(metric tons). 

n = Number of process units where fuel is used. 

Fg,i = Annual volume of gaseous fuel combusted (“(Fg)” in Equations Q-1, Q-4 

and Q-7 of this section) for each process (scf). 

MWi = Molecular weight of gaseous fuel used in each process (kg/kg-mole). 

MVC = Molar volume conversion factor at standard conditions, as defined in § 

98.6. Use 849.5 scf per kg mole if you select 68 °F as standard 

temperature and 836.6 scf per kg mole if you select 60 °F as standard 

temperature. 

Fl,i = Annual volume of the liquid fuel combusted (“(Fl)” included in Equation 

Q-1 of this section) for each process unit (gallons). 

Fs,i = Annual mass of the solid fuel combusted (“(Fs)” in Equation Q-1 of this 

section) for each process unit (metric tons). 
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ρl,i = Density of the liquid fuel (kg/gallon). 

0.001 = Conversion factor from kg to metric tons. 

(ii) The annual mass (metric tons) of all non-fuel material inputs (combined) specified in 

Equations Q-1 through Q-7 of this section, calculated as specified in Equation Q-10 of this 

section. 

௡ ௡௜݈݁݁ݐܵ ൅ ݀݁݋ݎݐ݈݁ܿܧ ൅ ݁݁݀ܨ ൅ ݈ܽ݋ܥ ൅ ݊݋ܾݎܽܥ ൅ ݔݑ݈ܨ ൅ ݌ܽݎܵܿ ൅ ݊݋ݎܫ ൅ ܱ ∑ሺ ൌ ܫܨܰ

௜ୀଵ ൅

 (-10Q .Eq (ݎ݄݁ݐܱ൅݁ݎܱ

Where: 

NFI = Annual mass of all non-fuel inputs (to all process unit types) specified in 

Equations Q-1 through Q-7 of this section (metric tons). 

n = Number of process units, all process types. 

O = Annual mass of greenball (taconite) pellets fed to the taconite furnace(s) 

(metric tons). 

Iron = Annual mass of molten iron charged to the basic oxygen furnace(s) plus 

annual mass of direct reduced iron charged to the EAF(s) (metric tons). 

Scrap = Annual mass of ferrous scrap charged to the basic oxygen furnace(s) and 

EAF(s) (metric tons). 

Flux = Annual mass of flux materials charged to the basic oxygen furnace(s) and 

EAF(s) (metric tons). 

Carbon = Annual mass of carbonaceous materials (e.g., coal, coke) charged to the 

basic oxygen furnace(s), EAF(s), and direct reduction furnace(s) (metric 

tons). 

Coal = Annual mass of coal charged to the coke oven battery(s) (metric tons). 

Feed = Annual mass of sinter feed material charged to the sinter process(es) 

(metric tons). 

Electrode = Annual mass of carbon electrode consumed in the EAF(s) (metric tons). 

Steelin = Annual mass of molten steel charged to the decarburization vessels (metric 

tons). 

Ore = Annual mass of iron ore or iron ore pellets fed to the direct reduction 

furnace(s) (metric tons). 
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Other = Annual mass of other materials charged to the direction reduction 

furnace(s) (metric tons). 

(iii) The annual mass (metric tons) of all solid and liquid products and byproducts 

(combined) specified in Equations Q-1 through Q-7 of this section, calculated as specified in 

Equation Q-11 of this section. 

௡∑ሺ ൌ ݏݐܿݑ݀݋ݎܲ

 (-11Q .ሺEq		ሻ ܯܰ ൅ ݊݋ݎܫ ൅ ݎ݁ݐܵ݅݊ ൅ ݇݁݋ܥ ൅ ݈ܵܽ݃ ൅ ௨௧௢݈݁݁ݐܵ ൅ ܴ ൅ ܲ ୀଵ௜

Where: 

Products = Annual mass of all solid and liquid products and by-products (from all 

process units) specified in Equations Q-1 through Q-7 of this section 

(metric tons). 

n = Number of process units, all types. 

P = Annual mass of fired pellets produced by the taconite furnace (metric 

tons). 

R = Annual mass of air pollution control residue from all process units (metric 

tons). 

Steelout = Annual mass of steel produced by the basic oxygen furnace(s), EAF(s) and 

decarburization vessel(s) (metric tons). 

Slag = Annual mass of slag produced by the basic oxygen furnace(s) and EAF(s) 

(metric tons). 

Coke = Annual mass of coke produced by the non-recovery coke batteries (metric 

tons). 

Sinter = Annual mass of sinter produced from the sinter process(es) (metric tons). 

Iron = Annual mass of iron produced from the direct reduction furnace (metric 

tons). 

NM = Annual mass of non-metallic materials produced by the direct reduction 

furnace (metric tons). 

(iv) The weighted average carbon content of all gaseous, liquid, and solid fuels 

(combined) included in Equation Q-9 of this section, calculated as specified in Equation Q-12 of 

this section. 
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ܨܥ௔௩௚ ൌ ቀ	∑ ி೒,೔	∗

ಾೈ೔

ಾೇ಴

೙

೔సభ ∗஼೒೑,೔∗଴.଴଴ଵାி೗,೔∗஼೗೑,೔∗଴.଴଴ଵା	ிೞ,೔∗஼ೞ೑	ቁ

ி௨௘௟ (Eq. Q-12) 

Where: 

CFavg = Weighted average carbon content of all gaseous, liquid, and solid fuels 

included in Equation Q-9 of this section (weight fraction). 

n = Number of gaseous, liquid, and solid fuel input to each process unit as 

used in Equation Q-9. 

Cgf,i = Average carbon content of the gaseous fuel used in each process, from the 

fuel analysis results (kg C per kg of fuel). 

Clf,i = Carbon content of the liquid fuel used in each process, from the fuel 

analysis results (kg C per gallon of fuel. 

Csf = Carbon content of the solid fuel used in each process, from the fuel 

analysis (expressed as a decimal fraction, e.g., 95% = 0.95). 

Fuel = Annual mass of all gaseous, liquid, and solid fuels used in process units 

(metric tons), as calculated in Equation Q-9 of this section. 

(v) The weighted average carbon content of all non-fuel inputs to all process units 

(combined) included in Equation Q-10 of this section, calculated as specified in Equation Q-13 

of this section. 

ܫܥ௔௩௚ ൌ ൫∑ ேிூ೔∗஼ಿಷ಺೔ ೙

೔సభ ൯	

ேிூ 			 (Eq. Q-13) 

Where: 

CIavg = Weighted average carbon content of all non-fuel inputs to all process units 

included in Equation Q-10 of this section (weight fraction). 

n = Number of non-fuel inputs to all process units as used in Equation Q-10. 

NFIi = Annual mass of each non-fuel input used in Equation Q-10 (metric tons). 

CNFIi = Average carbon content of each non-fuel input used in Equation Q-10 

(expressed as a decimal fraction). 

NFI = Total of all non-fuel inputs to all process units (metric tons). 
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(vi) The weighted average carbon content of all solid and liquid products and byproducts 

from all process units (combined) included in Equation Q-11 of this section, calculated as 

specified in Equation Q-14 of this section. 

ܥܲ௔௩௚ ൌ 	൫∑ ௉௥௢ௗ௨௖௧೔∗஼ು೔ ೙

೔సభ ൯

௉௥௢ௗ௨௖௧௦ (Eq. Q-14) 

Where: 

CPavg = Weighted average carbon content of all solid and liquid products and 

byproducts from all process units (weight fraction). 

n = Number of products and byproducts from each process unit as used in 

Equation Q-11. 

Producti = Annual mass of each product or byproduct used in Equation Q-11 (metric 

tons). 

Cp,i = Average carbon content of each product or byproduct used in Equation Q11 (expressed as a decimal fraction). 

Products = Mass of all products and byproducts from all process units, calculated in 

Equation Q-11 of this section (metric tons). 

* * * * * 

Subpart R—[AMENDED] 

17. Section 98.186 is amended by removing and reserving paragraphs (b)(6) and 

(b)(7); and revising paragraph (b)(8) to read as follows: 

§ 98.186 Data reporting procedures. 

* * * * * 

(b) * * * 

(8) List the method used for the determination of carbon content for each material used 

for the calculation of annual process CO2 emissions using Equation R–1 of this subpart for each 
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Page 87 of 96 

smelting furnace (e.g., supplier provided information, analyses of representative samples you 

collected). 

* * * * * 

Subpart S—[AMENDED] 

18. Section 98.196 is amended by: 

a. Revising paragraph (b) introductory text. 

b. Removing and reserving paragraphs (b)(2), (b)(3), (b)(5), (b)(6), (b)(8), (b)(10), 

(b)(11), and (b)(12). 

c. Adding paragraph (b)(18). 

The revisions and additions read as follows: 

§ 98.196 Data reporting requirements. 

* * * * * 

(b) If a CEMS is not used to measure CO2 emissions, then you must report the 

information listed in paragraphs (b)(1) through (18) of this section. 

* * * * * 

(18) Annual quantity (metric tons) of lime product sold, by type. 

Subpart U—[AMENDED] 

19. Section 98.216 is amended by removing and reserving paragraphs (b), (e)(1), 

(e)(2), and (f). 

Subpart V—[AMENDED] 

20. Section 98.226 is amended by: 

a. Revising the introductory text. 

b. Removing and reserving paragraphs (d), (m)(1), and (m)(3). 
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c. Adding paragraph (q). 

The revisions and additions read as follows: 

§ 98.226 Data reporting requirements. 

In addition to the information required by § 98.3(c), each annual report must contain the 

information specified in paragraphs (a) through (q) of this section. 

* * * * * 

(q) Annual percent N2O emission reduction for all production units combined. 

Subpart X—[AMENDED] 

21. Section 98.246 is amended by: 

a. Revising paragraph (a) introductory text and paragraphs (a)(2) and (a)(4). 

b. Adding paragraphs (a)(12) and (13). 

c. Revising paragraph (b) introductory text. 

d. Removing and reserving paragraphs (b)(5)(iii) and (b)(5)(iv). 

Adding paragraphs (b)(9) and (b)(10). 

The revisions and additions read as follows: 

§ 98.246 Data reporting requirements. 

* * * * * 

(a) If you use the mass balance methodology in § 98.243(c), you must report the 

information specified in paragraphs (a)(1) through (a)(13) of this section for each type of 

petrochemical produced, reported by process unit. 

* * * * * 

(2) The type of petrochemical produced, names of products, and names of carboncontaining feedstocks. 
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* * * * * 

(4) The temperature (in °F) at which the gaseous feedstock and product volumes used in 

Equation X–1 of this subpart were determined. 

* * * * * 

(12) Name and annual quantity (in metric tons) of each carbon-containing feedstock 

included in Equations X-1, X-2, and X-3 of § 98.243 of this subpart. 

(13) Name and annual quantity (in metric tons) of each product included in Equations X1, X-2, and X-3 of § 98.243 of this subpart. 

(b) If you measure emissions in accordance with § 98.243(b), then you must report the 

information listed in paragraphs (b)(1) through (b)(10) of this section. 

* * * * * 

(9) Name and annual quantity (in metric tons) of each carbon-containing feedstock. 

(10) Name and annual quantity (in metric tons) of each carbon-containing co-product. 

* * * * * 

Subpart Y—[AMENDED] 

22. Section 98.256 is amended by: 

a. Revising paragraphs (e)(6) and (e)(7) introductory text. 

b. Removing and reserving paragraph (e)(7)(ii). 

c. Revising paragraphs (e)(9) and (e)(10). 

d. Adding paragraph (e)(11). 

e. Revising paragraphs (f)(7) and (f)(10) through (13). 

f. Removing and reserving paragraph (h)(4). 

g. Revising paragraphs (h)(5), (i)(5), (i)(7), and (i)(8). 
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h. Removing and reserving paragraph (j)(2). 

i. Revising paragraphs (j)(5) through (9), (k)(3), (k)(4), (l)(5), and (m)(3). 

j. Removing and reserving paragraphs (o)(2)(ii), (o)(4)(ii) through (v), and (o)(6) and (7). 

k. Revising paragraph (p)(2). 

The revisions and additions read as follows: 

§ 98.256 Data reporting requirements. 

* * * * * 

(e) * * * 

(6) If you use Equation Y–1a of this subpart, an indication of whether daily or weekly 

measurement periods are used, the annual volume of flare gas combusted (in scf/year) and the 

annual average molecular weight (in kg/kg-mole), and annual average carbon content of the flare 

gas (in kg carbon per kg flare gas). 

(7) If you use Equation Y–1b of this subpart, an indication of whether daily or weekly 

measurement periods are used, the annual volume of flare gas combusted (in scf/year), the 

annual average CO2 concentration (volume or mole percent), the number of carbon containing 

compounds other than CO2 in the flare gas stream, and for each of the carbon containing 

compounds other than CO2 in the flare gas stream: 

* * * * * 

(9) If you use Equation Y–3 of this subpart, the number of SSM events exceeding 

500,000 scf/day. 

(10) The basis for the value of the fraction of carbon in the flare gas contributed by 

methane used in Equation Y–4 of this subpart. 

(11) If using Equation Y-3, report: 
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(i) Annual quantity of flare gas combusted (in MMscf per year). 

(ii) Annual average molecular weight of flare gas combusted (in mmBtu per MMscf). 

(iii) Annual average carbon content of flare gas combusted (expressed as a decimal 

fraction). 

(f) * * * 

(7) If you use Equation Y–6 of this subpart, the annual average exhaust gas flow rate, 

%CO2, and %CO. 

* * * * * 

(10) If you use Equation Y–8 of this subpart, the basis for the value of the coke burn-off 

factor, annual throughput of unit, and the average carbon content of coke. 

(11) Indicate whether you use a measured value, a unit-specific emission factor, or a 

default emission factor for CH4 emissions. If you use a unit-specific emission factor for CH4, 

report the basis for the factor. 

(12) Indicate whether you use a measured value, a unit-specific emission factor, or a 

default emission factor for N2O emissions. If you use a unit-specific emission factor for N2O, 

report the basis for the factor. 

(13) If you use Equation Y–11 of this subpart, the number of regeneration cycles or 

measurement periods during the reporting year and the average coke burn-off quantity per cycle 

or measurement period. 

* * * * * 

(h) * * * 

(5) If you recycle tail gas to the front of the sulfur recovery plant, indicate whether the 

recycled flow rate and carbon content are included in the measured data under § 98.253(f)(2) and 
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(3). Indicate whether a correction for CO2 emissions in the tail gas was used in Equation Y–12. If 

so, then report: 

(i) The value of the correction. 

(ii) If the following data are not used to calculate the recycling correction factor, report 

the information specified in paragraphs (h)(5)(ii)(A) through (C) of this section. 

(A) The annual volume of recycled tail gas (in scf/year) only. 

(B) The annual average mole fraction of carbon in the tail gas (in kg-mole C/kg-mole 

gas). 

(C) Indicate whether you used the default (95%) or a unit specific correction, and if used, 

report the approach used. 

* * * * * 

(i) * * * 

(5) If you use Equation Y–13 of this subpart, an indication of whether coke dust is 

recycled to the unit (e.g., all dust is recycled, a portion of the dust is recycled, or none of the dust 

is recycled). 

* * * * * 

(7) Indicate whether you use a measured value, a unit-specific emission factor or a 

default for CH4 emissions. If you use a unit-specific emission factor for CH4, report the basis for 

the factor. 

(8) Indicate whether you use a measured value, a unit-specific emission factor, or a 

default emission factor for N2O emissions. If you use a unit-specific emission factor for N2O, 

report the basis for the factor. 

(j) * * * 
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Page 93 of 96 

(5) If you use Equation Y–14 of this subpart, the basis for the CO2 emission factor used. 

(6) If you use Equation Y–15 of this subpart, the basis for the CH4 emission factor used. 

(7) If you use Equation Y–16 of this subpart, the basis for the carbon emission factor 

used. 

(8) If you use Equation Y–16b of this subpart, the basis for the CO2 emission factor used 

and the basis for the carbon emission factor used. 

(9) If you use Equation Y–17 of this subpart, the basis for the CH4 emission factor used. 

(k) * * * 

(3) The total number of delayed coking units at the facility; the total number of delayed 

coking drums at the facility; and, for each coke drum or vessel, the typical drum outage (i.e. the 

unfilled distance from the top of the drum, in feet). 

(4) For each set of coking drums that are the same dimensions, the number of coking 

drums in the set, and the mole fraction of methane in coking gas (in kg-mole CF4/kg-mole gas, 

wet basis). 

* * * * * 

(l) * * * 

(5) The annual volumetric flow discharged to the atmosphere (in scf), and an indication 

of the measurement or estimation method, annual average mole fraction of each GHG above the 

concentration threshold or otherwise required to be reported and an indication of the 

measurement or estimation method, and for intermittent vents, the number of venting events and 

the cumulative venting time. 

(m) * * * 
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Page 94 of 96 

(3) For uncontrolled blowdown systems reporting under § 98.253(k), the basis for the 

value of the methane emission factor used for uncontrolled blowdown systems. 

* * * * * 

(p) * * * 

(2) The types of materials loaded that have an equilibrium vapor-phase concentration of 

methane of 0.5 volume percent or greater, and the type of vessel (barge, tanker, marine vessel, 

etc.) in which each type of material is loaded. 

* * * * * 

Subpart Z—[AMENDED] 

23. Section 98.266 is amended by removing and reserving paragraphs (f)(5) and 

(f)(6). 

Subpart AA—[AMENDED] 

24. Section 98.276 is amended by: 

a. Revising the introductory paragraph. 

b. Removing and reserving paragraph (b). 

c. Revising paragraph (c). 

d. Removing and reserving paragraphs (d), (f), (g), (h) and (i). 

e. Adding paragraphs (l) and (m). 

The revisions and additions read as follows: 

§ 98.276 Data reporting requirements. 

In addition to the information required by § 98.3(c) and the applicable information 

required by § 98.36, each annual report must contain the information in paragraphs (a) through 

(m) of this section as applicable: 
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* * * * * 

(c) Basis for determining the annual mass of the spent liquor solids combusted (whether 

based on T650 om-05 Solids Content of Black Liquor, TAPPI (incorporated by reference, see § 

98.7) or an online measurement system). 

* * * * * 

(l) For each pulp mill lime kiln, report the information specified in paragraphs (l)(1) and 

(2) of this section. 

(1) The quantity of calcium oxide (CaO) produced (metric tons). 

(2) The percent of annual heat input, individually for each fossil fuel type. 

(m) For each chemical recovery furnace and each chemical recovery combustion unit for 

which you are not using Equation C-2c to calculate CO2 emissions, report the information 

specified in paragraphs (m)(1) and (2) of this section. 

(1) The annual mass of steam generated (lb steam), individually for each fossil fuel type 

and for spent liquor solids. 

(2) The ratio of the unit’s maximum rated heat input capacity to its design rated steam 

output capacity (mmBtu/lb steam), individually for each fossil fuel type and for spent liquor 

solids. 

Subpart BB—[AMENDED] 

25. Section 98.286 is amended by removing and reserving paragraphs (b)(1), (b)(4), 

and (b)(6). 

Subpart CC—[AMENDED] 

26. Section 98.296 is amended by removing and reserving paragraphs (b)(5) through 

(7). 
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Page 96 of 96 

Subpart EE—[AMENDED] 

27. Section 98.316 is amended by removing and reserving paragraphs (b)(6) and 

(b)(9). 

Subpart GG—[AMENDED] 

28. Section 98.336 is amended by removing and reserving paragraphs (b)(6), (b)(7), 

and (b)(10). 

Subpart TT—[AMENDED] 

29. Section 98.466 is amended by: 

a. Removing and reserving paragraph (c)(3)(i). 

b. Revising paragraph (c)(3)(ii). 

c. Removing and reserving paragraph (c)(3)(iii). 

The revisions read as follows: 

§ 98.466 Data reporting requirements. 

* * * * * 

(c) * * * 

(3) * * * 

(ii) The year of the data used in Equation TT-2 for the waste disposal quantity and 

production quantity, for each year used in Equation TT–2 of this subpart to calculate the average 

waste disposal factor (WDF). 

* * * * * 
Attachment H 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Formatted: Font: 11 pt

6560.50 

ENVIRONMENTAL PROTECTION AGENCY 

40 CFR Part 98 

[EPA-HQ-OAR-2010-0929; FRL- 9801-2] 

RIN 2060-AQ81 

Revisions to Reporting and Recordkeeping Requirements, and Proposed Confidentiality 

Determinations under the Greenhouse Gas Reporting Program 

EO12866_GHGRP Part 98 2060 AQ81 NPRM 20120326 

AGENCY: Environmental Protection Agency (EPA). 

ACTION: Proposed rule. 

SUMMARY: The EPA is proposing amendments to reporting and recordkeeping requirements 

and an alternative verification approach for the Greenhouse Gas Reporting Program. This action 

addresses concerns about the potential release of certain data that are inputs to emission 

equations to be reportedwhose reporting deadline was deferred until March 31, 2015 while 

maintaining the EPA’s ability to verify emissions and ensure compliance with the Greenhouse 

Gas Reporting Program. In addition, the EPA is proposing confidentiality determinations for the 

newly proposed data elements in this action. 

DATES: Comments. Comments must be received on or before [INSERT THE DATE 60 DAYS 

AFTER PUBLICATION OF THIS PROPOSED RULE IN THE FEDERAL REGISTER]. 

Public Hearing. The EPA will hold a public hearing on this proposed rule if requested. 

Requests for a hearing must be made by [INSERT THE DATE 7 DAYS AFTER 

PUBLICATION OF THIS PROPOSED RULE IN THE FEDERAL REGISTER]. Contact the 

person listed in the “FOR FURTHER INFORMATION CONTACT” section by [INSERT 

THE DATE 7 DAYS AFTER PUBLICATION OF THIS PROPOSED RULE IN THE 

Style Definition ... [1]

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FEDERAL REGISTER] to request a public hearing. If a hearing is requested, the EPA will 

announce the details, including specific dates, times, addresses and contact information for the 

hearing, in a separate Federal Register notice. 

ADDRESSES: Submit your comments, identified by Docket ID No. EPA–HQ–OAR–2010-

0929, by one of the following methods: 

 Federal eRulemaking Portal: http:// www.regulations.gov. Follow the online instructions 

for submitting comments. 

 Email: GHGReportingCBI@epa.gov 

 Fax: (202) 566–1741. 

 Mail: Environmental Protection Agency, EPA Docket Center (EPA/DC), Mailcode 

6102T, Attention Docket ID No. EPA–HQ–OAR–2010-0929, 1200 Pennsylvania 

Avenue, NW., Washington, DC 20460. 

 Hand Delivery: EPA Docket Center, Public Reading Room, EPA West Building, Room 

3334, 1301 Constitution Avenue, NW., Washington, DC 20004. Such deliveries are only 

accepted during the Docket’s normal hours of operation, and special arrangements should 

be made for deliveries of boxed information. 

Instructions: Direct your comments to Docket ID No. EPA–HQ–OAR–2010-0929. The 

EPA’s policy is that all comments received will be included in the public docket without change 

and may be made available online at http://www.regulations.gov, including any personal 

information provided, unless the comment includes information claimed to be confidential 

business information (CBI) or other information whose disclosure is restricted by statute. 

Do not submit information that you consider to be CBI or otherwise protected through 

http://www.regulations.gov or email. Send or deliver information identified as CBI to only the 

mail or hand/courier delivery address listed above, attention: Docket ID No. EPA–HQ–OAR–

2010–0929. The http://www.regulations.gov website is an “anonymous access” system, which 

means the EPA will not know your identity or contact information unless you provide it in the 

body of your comment. If you send an email comment directly to the EPA without going through 

http://www.regulations.gov your email address will be automatically captured and included as 

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part of the comment that is placed in the public docket and made available on the Internet. If you 

submit an electronic comment, the EPA recommends that you include your name and other 

contact information in the body of your comment and with any disk or CD–ROM you submit. If 

the EPA cannot read your comment due to technical difficulties and cannot contact you for 

clarification, the EPA may not be able to consider your comment. Electronic files should avoid 

the use of special characters, any form of encryption, and be free of any defects or viruses. 

Docket: All documents in the docket are listed in the http://www.regulations.gov index. 

Although listed in the index, some information is not publicly available, e.g., CBI or other 

information whose disclosure is restricted by statute. Certain other material, such as copyrighted 

material, will be publicly available only in hard copy. Publicly available docket materials are 

available either electronically in http://www.regulations.gov or in hard copy at the Air Docket, 

EPA/DC, EPA West, Room B102, 1301 Constitution Ave., NW., Washington, DC. This Docket 

Facility is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. 

The telephone number for the Public Reading Room is (202) 566–1744, and the telephone 

number for the Air Docket is (202) 566–1742. 

FOR FURTHER GENERAL INFORMATION CONTACT: Carole Cook, Climate Change 

Division, Office of Atmospheric Programs (MC–6207J), Environmental Protection Agency, 

1200 Pennsylvania Ave., NW., Washington, DC 20460; telephone number: (202) 343–9263; fax 

number: (202) 343–2342; email address: GHGreporting@epa.gov. For technical information, 

contact the Greenhouse Gas Reporting Rule Helpline at: 

http://www.epa.gov/climatechange/emissions/ghgrule_contactus.htm. Alternatively, contact 

Carole Cook at 202–343–9263. 
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Worldwide Web (WWW). In addition to being available in the docket, an electronic copy 

of this proposal, memoranda to the docket, and all other related information will also be 

available through the WWW on EPA’s greenhouse gas reporting rule Web site at 

http://www.epa.gov/climatechange/emissions/ghgrulemaking.html. SUPPLEMENTARY 

INFORMATION: 

Additional Information on Submitting Comments: To expedite review of your comments 

by Agency staff, you are encouraged to send a separate copy of your comments, in addition to 

the copy you submit to the official docket, to Carole Cook, Climate Change Division, Office of 

Atmospheric Programs (MC–6207J), Environmental Protection Agency, 1200 Pennsylvania 

Ave., NW., Washington, DC, 20460, telephone (202) 343–9263, email 

GHGReportingCBI@epa.gov. 

Regulated Entities. This proposed rule revision on reporting and recordkeeping 

requirements and verification procedures would affect entities that must submit annual 

greenhouse gas (GHG) reports under the Greenhouse Gas Reporting Program (40 CFR part 98). 

The Administrator has determined that 40 CFR part 98 is subject to the provisions of Clean Air 

Act (CAA) section 307(d). See CAA section 307(d)(1)(V) (the provisions of CAA section 307(d) 

apply to “such other actions as the Administrator may determine”). Entities affected by this 

proposal are owners or operators of facilities that are direct emitters of greenhouse gases 

(GHGs), which include those listed in Table 1 of this preamble: 

Table 1. Examples of Affected Entities by Category 

Category NAICS Examples of affected facilities 

General Stationary Fuel 

Combustion Sources 

Facilities operating boilers, process heaters, 

incinerators, turbines, and internal combustion engines. 

321 Manufacturers of lumber and wood products. 

322 Pulp and paper mills. 

325 Chemical manufacturers. 

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Category NAICS Examples of affected facilities 

324 Petroleum refineries and manufacturers of coal 

products.

316, 326, 

339 

Manufacturers of rubber and miscellaneous plastic 

products. 

331 Steel works, blast furnaces.

332 Electroplating, plating, polishing, anodizing, and 

coloring. 

336 Manufacturers of motor vehicle parts and accessories. 

221 Electric, gas, and sanitary services. 

622 Health services.

611 Educational services.

325193 Ethyl alcohol manufacturing facilities.

311611 Meat processing facilities

311411 Frozen fruit, juice, and vegetable manufacturing 

facilities.

311421 Fruit and vegetable canning facilities.

Electricity Generation 221112 Fossil-fuel fired electric generating units, including 

units owned by Federal and municipal governments 

and units located in Indian Country.

Adipic Acid Production 325199 Adipic acid manufacturing facilities. 

Aluminum Production 331312 Primary aluminum production facilities 

Ammonia 

Manufacturing 

325311 Anhydrous and aqueous ammonia production facilities. 

Cement Production 327310 Portland Cement manufacturing plants. 

Ferroalloy Production 331112 Ferroalloys manufacturing facilities. 

Fluorinated GHG 

Production 

325120 Industrial gases manufacturing facilities. 

Glass Production 327211 Flat glass manufacturing facilities.

327213 Glass container manufacturing facilities.

327212 Other pressed and blown glass and glassware 

manufacturing facilities.

HCFC-22 Production 

and HFC-23 

Destruction 

325120 Chlorodifluoromethane manufacturing facilities. 

Hydrogen Production 325120 Hydrogen production facilities 

Iron and Steel 

Production 

331111 Integrated iron and steel mills, steel companies, sinter 

plants, blast furnaces, basic oxygen process furnace 

shops. 

Lead Production 331419 Primary lead smelting and refining facilities. 

331492 Secondary lead smelting and refining facilities. 

Lime Production 327410 Calcium oxide, calcium hydroxide, dolomitic hydrates 

manufacturing facilities. 

Magnesium Production 331419 Primary lead smelting and refining facilities.

331492 Secondary lead smelting and refining facilities.

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Category NAICS Examples of affected facilities 

Manure Management 112111

112120

112210 

112310 

112330

112320 

Beef cattle feedlots.

Dairy cattle and milk production facilities.

Hog and pig farms.

Chicken egg production facilities.

Turkey Production.

Broilers and other meat type chicken production.

Municipal Solid Waste 

Landfills

562212

221320

Solids Waste Landfills.

Sewage treatment facilities.

Nitric Acid Production 325311 Nitric acid production facilities 

Petrochemical 

Production 

32511 Ethylene dichloride production facilities. 

325199 Acrylonitrile, ethylene oxide, methanol production 

facilities.

325110 Ethylene production facilities.

325182 Carbon black production facilities. 

Petroleum and Natural 

Gas Systems 1

486210 Pipeline transportation of natural gas. 

221210 Natural gas distribution facilities. 

211 Extractors of crude petroleum and natural gas. 

211112 Natural gas liquid extraction facilities. 

Petroleum Refineries 324110 Petroleum refineries. 

Phosphoric Acid 

Production 

325312 Phosphoric acid manufacturing facilities. 

Pulp and Paper 

Manufacturing 

322110 Pulp mills. 

322121 Paper mills.

322130 Paperboard mills. 

Silicon Carbide 

Production 

327910 Silicon carbide abrasives manufacturing facilities. 

Soda Ash 

Manufacturing 

325181 Alkalies and chlorine manufacturing facilities. 

212391 Soda ash, natural, mining and/or beneficiation. 

Titanium Dioxide 

Production 

325188 Titanium dioxide manufacturing facilities. 

Zinc Production 331419 Primary zinc refining facilities. 

331492 Zinc dust reclaiming facilities, recovering from scrap 

and/or alloying purchased metals.

311411 Frozen fruit, juice and vegetable manufacturing 

facilities. 

311421 Fruit and vegetable canning facilities.

Wastewater 

TreatmentTreatment1

322110 Pulp mills.

322121 Paper mills.

322122 Newsprint mills.

322130 Paperboard mills. 

311611 Meat processing facilities. 

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Category NAICS Examples of affected facilities 

311411 Frozen fruit, juice and vegetable manufacturing 

facilities.

311421 Fruit and vegetable canning facilities.

325193 Ethanol manufacturing facilities. 1

 The EPA is not proposing amendments related to these categories; however, these categories were evaluated in the 

EPA’s analysis of the potential impact from the release of inputs to emission equations for which reporting was 

deferred to March 31, 2015. Refer to Section 1.B of this preamble for further discussion of this evaluation. 

Table 1 of this preamble is not intended to be exhaustive, but rather provides a guide for 

readers regarding facilities and suppliers likely to be affected by this action. Types of facilities 

other than those listed in this table may also be affected by this action. To determine whether you 

are affected by this action, you should carefully examine the applicability criteria found in 40 

CFR part 98, subpart A or the relevant criteria in the subparts. If you have questions regarding 

the applicability of this action to a particular facility or supplier, consult the person listed in the 

preceding FOR FURTHER GENERAL INFORMATION CONTACT section. 

Many facilities that are affected by 40 CFR part 98 have GHG emissions from multiple 

source categories listed in Table 1 of this preamble. 

Acronyms and Abbreviations. The following acronyms and abbreviations are used in this 

document. 

BAMM Best Available Monitoring Methods 

CAA Clean Air Act 

CO2 carbon dioxide 

CBI confidential business information 

CEMS Continuous Emission Monitoring System 

CFR Code of Federal Regulations 

e-GGRT Electronic Greenhouse Gas Reporting Tool 

EIA Energy Information Administration

EPA U.S. Environmental Protection Agency 

FR Federal Register 

GHG greenhouse gas 

GHGRP Greenhouse Gas Reporting Program 

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HCFC-22 chlorodifluoromethane 

HFC hydrofluorocarbons 

HQ Headquarters 

ICR Information Collection Request 

MW megawatt 

NAICS North American Industry Classification System 

NTTAA National Technology Transfer and Advancement Act 

OMB Office of Management & Budget 

RFA Regulatory Flexibility Act 

UMRA Unfunded Mandates Reform Act 

U.S. United States 

WWW Worldwide Web 

TABLE OF CONTENTS 

I. Executive Summary and Background

A. Executive Summary

B. Background

C. Subparts Covered in this Proposed Rule

D. Legal Authority

II. Summary of Proposed Changes to Part 98 Reporting and Recordkeeping Requirements

A. Proposed Use of Inputs Verification Tool

B. Proposed Revisions to Reporting of Data Elements Deferred until 2015

C. Proposed Changes to Recordkeeping Requirements

D. Proposed New Data Elements to be Reported

III. Rationale for Proposed Changes to Reporting and Recordkeeping Requirements

A. Proposed Inputs Verification Tool and Amendment to Reporting Requirements

B. Proposed Revisions to Recordkeeping Requirements

C. Proposed Requirement to Report Additional Data

IV. Confidentiality Determination for Proposed New Data Elements to be Reported

V. Impacts of the Proposed Rule

A. How were the costs of this proposed rule estimated?

B. Additional Impacts of the Proposed Amendments

VI. Statutory and Executive Order Reviews

A. Executive Order 12866: Regulatory Planning and Review and Executive Order 13563: 

Improving Regulation and Regulatory Review

B. Paperwork Reduction Act

C. Regulatory Flexibility Act (RFA)

D. Unfunded Mandates Reform Act (UMRA)
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E. Executive Order 13132: Federalism

F. Executive Order 13175: Consultation and Coordination with Indian Tribal Governments.

G. Executive Order 13045: Protection of Children from Environmental Health Risks and Safety 

Risks

H. Executive Order 13211: Actions that Significantly Affect Energy Supply, Distribution, or Use

I. National Technology Transfer and Advancement Act

J. Executive Order 12898: Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations

I. Executive Summary and Background

A. Executive Summary

B. Background

C. Subparts Covered in this Proposed Rule

D. Legal Authority

II. Summary of Proposed Changes to Part 98 Reporting and Recordkeeping Requirements

A. Proposed Use of Inputs Verification Tool

B. Proposed Revisions to Reporting of Data Elements Deferred until 2015

C. Proposed Changes to Recordkeeping Requirements

D. Proposed New Data Elements to be Reported

III. Rationale for Proposed Changes to Reporting and Recordkeeping Requirements

A. Proposed Inputs Verification Tool and Amendment to Reporting Requirements

B. Proposed Revisions to Recordkeeping Requirements

C. Proposed Requirement to Report Additional Data

IV. Confidentiality Determination for Proposed New Data Elements to be Reported

V. Impacts of the Proposed Rule

A. How were the costs of this proposed rule estimated?

B. Additional Impacts of the Proposed Amendments

VI. Statutory and Executive Order Reviews

A. Executive Order 12866: Regulatory Planning and Review and Executive Order 13563: 

Improving Regulation and Regulatory Review

B. Paperwork Reduction Act

C. Regulatory Flexibility Act (RFA)

D. Unfunded Mandates Reform Act (UMRA)

E. Executive Order 13132: Federalism

F. Executive Order 13175: Consultation and Coordination with Indian Tribal Governments.

G. Executive Order 13045: Protection of Children from Environmental Health Risks and Safety 

Risks

H. Executive Order 13211: Actions that Significantly Affect Energy Supply, Distribution, or Use

I. National Technology Transfer and Advancement Act

J. Executive Order 12898: Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations

I. Executive Summary and Background 
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A. Executive Summary 

The Greenhouse Gas Reporting Program (GHGRP) collects greenhouse gas data from 41 

source categories and currently has tworeceived 2 to three3 years of data from these sources. 

Greenhouse gas emissions from direct emitters are calculated using a variety of methods, 

including direct measurement, mass balance, and the use of emission factors. Reporters not using 

direct measurement must use equations to calculate emissions. The inputs to these emission 

equations often include process or production data that are specific to each facility’s operations. 

These “inputs to emission equations” play an important role in the Agency’s ability to verify 

facility-level emissions and ensure compliance with the program. 

On July 7, 2010, the EPA proposed confidentiality determinations for the majority of data 

elements required to be reported under the GHGRP, as well as for the majority of source 

categories covered by the program. In the July 7, 2010 action, the EPA proposed that data 

elements categorized as “inputs to emission equations” are emission data. The CAA precludes 

“emission data” from being treated as confidential. 

Based on subsequent industry concerns regarding the potential release of data elements 

categorized as “inputs to emission equations,” the EPA deferred reporting of these data elements 

(see August 25, 2011 final action, 76 FR 53057) to allow the EPA to complete its evaluation of 

the potential impact from the public release of these data elements (see 76 FR 53060) and, if 

appropriate, to propose amendments to Part 98 (see 75 FR 81355). Based on the analysis 

conducted, today’s action proposes amendments to reporting and recordkeeping requirements 

and an alternative verification approach for certain reporters subject to 24 subparts with inputs to 

emission equations for which the reporting deadline for inputs to emission equations was 

deferred until 2015 and disclosure concerns have been identified. Proposed amendments include: 

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 Adding a requirement for certain reporters under certain24 subparts to use an EPAprovided inputs verification tool. The For these subparts, the designated inputs to 

emission equations for these subpartswhich reporting was deferred to 2015 and disclosure 

concerns have been identified would be entered into the tool.1 The tool would calculate 

the emissions and perform electronic verification. The tool would not retain the entered 

inputs (i.e., the inputs would not be reported to EPA); instead, itthe tool would conduct 

certain checks (e.g., accuracy of the inputs) at the time of data entry and generate a 

verification summary. The verification summary, which would be accessible to the EPA 

once the annual report is submitted, would provide the EPA with information to conduct 

further verification if necessary. 

 For reporters required to use the inputs verification tool, changing the required format for 

maintaining records of these inputs to emission equations. 

 For reporters required to use the inputs verification tool, lengthening the record retention 

period from 3 to 5 years for all records maintained under Part 98 (including subparts that 

do not require the use of the tool). 

 For certain subparts that require thereporters required to use of the inputs verification 

tool, adding new data elements to be reported for the EPA’s verification purposes, and 

proposing confidentiality determinations for the new data elements proposed to be 

reported. 

 For reporters required to use the inputs verification tool, removing the requirement to 

report the inputs to emission equations for which reporting was deferred to 2015 and 

disclosure concerns have been identified, and requiring themthese data to be kept as 

records. 

Reporting requirements for inputs to equations for which disclosure concerns were not 

identified (and would still be useful to EPA) are not proposed to be amended in this action. For 

these inputs to equations, the deferral would expire in March 2015, and EPA would collect these 

data. 

The proposed changes in this action build on the EPA’s experience and success with 

electronic reporting and verification during the first 3 years of the GHGRP. By requiring the use 

of the inputs verification tool, which would calculate GHG emissions based on the inputs to the 

emissions equations, the EPA would have the ability to identify facilities that potentially reported 

emissions incorrectly. This, combined with additional verification checks of the inputs to 

 

1

 Under this proposal, the inputs verification tool would not be required to be used by reporters for any reported GHG for 

which the reporter uses a CEMS or an EPA-approved alternative method (as allowed under sections 98.33(a)(5), 98.53(a)(2), and 

98.223(a)(2) of Part 98) to calculate the reported GHG value, rather than using "inputs to equations" data elements and the 

associated EPA-provided calculation methodologies to calculate the reported GHG value. 

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emission equations that the inputs verification tool would conduct (during the process of 

reporters entering data into the inputs verification tool), would provide the EPA with information 

necessary to conduct further verification once the annual report is submitted. This alternative 

verification approach, including the changes to the recordkeeping requirements and additional 

reporting requirements, would provide an alternative to collecting certain data elements for 

which reporting was deferred to March 31, 2015 and disclosure concerns have been identified,

while maintaining the EPA’s ability to verify data and ensure compliance with the GHGRP. 

B. Background

On October 30, 2009, the EPA published the Greenhouse Gas Reporting Rule, 40 CFR 

part 98, requiring annual reporting of GHG data from a broad range of industry sectors (74 FR 

56260). Under the Greenhouse Gas Reporting Rule and its subsequent amendments (hereinafter 

referred to as “Part 98”), the EPA requires annual reporting of data from certain facilities and 

suppliers above specified emission or quantity supplied thresholds. On July 7, 2010 (75 FR 

39094) and subsequent proposals (77 FR 1434, January 10, 2012; 77 FR 10434, February 22, 

2012), we proposed confidentiality determinations for the data elements required to be reported. 

The confidentiality of each reported data element was determined using a two-step approach: (1) 

grouping data elements into 11 data categories (e.g., inputs to emission equations, emissions, and 

unit/process operating characteristics that are not inputs to emission equations for direct emitter 

source categories); and (2) making confidentiality determinations either categorically or on an 

individual data elements basis. Refer to both the July 7, 2010 proposal (75 FR 39097 and 104) 

and the May 26, 2011 final rule (76 FR 30785 - 30786) for more detailed descriptions of this 

process. Refer to the May 26, 2011 final rule also for a discussion of individual data element 

confidentiality determinations. We have finalized confidentiality determinations for data 

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elements except those in the “inputs to emission equations” category (May 26, 2011, 76 FR 

30782; August 13, 2012, 77 FR 48072; and August 24, 2012, 77 FR 51477)2

. For data elements 

in this category, we proposed that they meet the definition of “emission data” under 40 CFR 

2.301(a)(2)(i). Because emission data are not entitled to confidential treatment under section 

114(c) of the Clean Air Act, we did not evaluate whether such data elements would qualify as 

CBI, including whether disclosure would likely cause substantial competitive harm to the 

reporting facilities. (75 FR 39105 and 39108, July 7, 2010). 

Following our proposal that data elements assigned to the “inputs to emission equations” 

category are not entitled to confidential treatment, we received numerous industry comments 

asserting that competitive harm would result from public release of many of these data elements. 

We determined that “these concerns warranted an in-depth evaluation of the potential impact 

from the release of inputs to emission equations.” (76 FR 53060; August 25, 2011). In a notice 

dated December 27, 2010, we issued a call for information (75 FR 81354) requesting additional 

information to assist us in conducting our evaluation. To allow sufficient time to complete this 

evaluation through notice and comment, we deferred the reporting deadline for data elements 

assigned to the “inputs to emission equation” category. Reporting of certain of these data 

elements was deferred to March 31, 2013, as specified in Table A-6 of subpart A; and reporting 

of the remainder of these data elements was deferred to March 31, 2015, as specified in Table A7 of subpart A (see the August 25, 2011 final rule, 76 FR 5307753057). 

Our process for evaluating competitive harm was documented in the final deferral notice 

(August 25, 2011, 76 FR 53057) and the accompanying memorandum entitled “Process for 

Evaluating and Potentially Amending Part 98 Inputs to Emission Equations” (Docket ID EPA-

 

2

 There are a small number of data elements (besides data elements categorized as “inputs to emission equations”) for which we 

have not made a final confidentiality determinations because we concluded that a determination of confidentiality for the data 

element should be made on a case-by-case facility basis (according to individual circumstances of the facility). 
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HQ-OAR-2010-0929). As discussed in the final deferral notice and memorandum, our evaluation 

involved a four-step process, as follows: 

 Step 1: Determine whether each data element assigned to the “inputs to emission 

equations” category is already publicly available. 

 Step 2: For data elements assigned to the “inputs to emission equations” category that are 

not publicly available, evaluate whether disclosure of the information is likely to result in 

substantial competitive harm. 

 Step 3: For data elements assigned to the “inputs to emission equations” category that are 

likely to cause substantial competitive harm if disclosed, evaluate potential alternative 

calculation methods. 

 Step 4: For data elements assigned to the “inputs to emission equations” category that are 

likely to cause substantial competitive harm if disclosed, evaluate potential alternative 

verification methods. 

Based on each step of the four-step evaluation process, an analysis of all data elements 

for which reporting iswas deferred to March 31, 2015 was conducted.3 The results of the analysis 

are documented in four memoranda, as follows: 

 “SummaryEvaluation of Public Availability of Inputs to Emission Equations for 

Whichwhich Reporting was Deferred Untilto March 31, 2015.” 

 “Evaluation of Competitive Harm From Reporting 2015 from Disclosure of “Inputs to 

Equations.”” Data Elements Deferred to March 31, 2015 

 “SummaryEvaluation of Alternative Calculation Methods.” 

 “SummaryEvaluation of Alternative Verification MethodsApproaches For Greenhouse 

Gas Reporting Rule Subparts for which Reporting of Inputs to Emission Equations was 

Deferred to March 31, 2015.” 

These memoranda are available in EPA docket ID No. EPA–HQ–OAR–2010-0929. 

Based on the results of these analyses, the EPA is proposing in today’s action to make certain 

amendments to Part 98. 

C. Subparts Covered in this Proposed Rule

 

3 WeBased on the same four-step process, we also evaluated all data elements for which reporting iswas deferred to 

March 31, 2013 (Part 98 Table A-6) based on the same four-step process and determined thattook no further action

was necessary. As a result, applicable facilities were required to report these data by April 1, 2013. For a discussion 

of this evaluation, refer to the EPA's memorandum "Summary of Evaluation of Greenhouse Gas Reporting Program 

(GHGRP) Part 98 “Inputs to Emission Equations” Data Elements Deferred Until 2013" (December 17, 2012), 

available at http://www.epa.gov/ghgreporting/documents/pdf/2012/documents/2013-inputs-memo.pdf. 

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The proposed amendments affect all subparts listed in Table 2 of this preamble. Table 2 

includes most of the subparts with inputs to emission equations for which the reporting deadline 

was deferred until 2015. Subpart W (Petroleum and Natural Gas Systems), Subpart II (Industrial 

Wastewater Treatment), and subpart C (only certain combustion units associated with 

devicescertain electric generators connected and able to deliver power to the local or regional 

electric power grid, as specified in Table 2) are not included in Table 2 because none of the 

inputs to emission equations required to be reported by reporters in these source categories are 

being amended, as no disclosure concerns were identified. Subpart I of part 98 is not included in 

Table 2 because reporting of inputs to emission equations under this subpart werewas addressed 

under a separate rulemaking proposed on October 16, 2012 (77 FR 63538). Additionally, 

certainparts of these proposed rule amendments would affect subparts not listed in Table 2 as 

follows:. Specifically, for reporters subject to both a subpart listed in Table 2 and a subpart of 

Part 98 not listed in this table, the proposed revision to the recordkeeping duration would apply 

to the records required for all Part 98 subparts (to which the reporter is subject). Refer to 

Sections II.C and III.B of this preamble for further discussion of this proposed amendment. 

Table 2. Subparts Affected by the Proposed Amendments.1,2

Subpart 

C—General Stationary Fuel Combustion except 

Certain Specified Stationary Fuel Combustion 

UnitsSources Connected to DevicesCertain 

Electric Generators that are Connected and Able 

to Deliver Power to the Local or Regional Electric 

Power Grid2Grid 3

S—Lime Manufacturing 

E—Adipic Acid Production U—Miscellaneous Uses of Carbonate 

F—Aluminum Production V—Nitric Acid Production 

G—Ammonia Manufacturing X—Petrochemical Production 

H—Cement Production Y—Petroleum Refineries 

K—Ferroalloy Production Z—Phosphoric Acid Production 

L—Fluorinated Gas Production AA—Pulp and Paper Manufacturing 

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Subpart 

N—Glass Production BB—Silicon Carbide Production 

O—HCFC–22 Production and HFC–23 

Destruction 

CC—Soda Ash Manufacturing 

P—Hydrogen Production EE—Titanium Dioxide Production 

Q—Iron and Steel Production GG—Zinc Production 

R—Lead Production TT—Industrial Waste Landfills 1

 Certain proposed amendments affect other subparts not listed in this table as follows: for reporters subject to both a 

subpart listed in this table and a subpart of Part 98 not listed in this table, the proposed revision to the recordkeeping 

duration would apply to the records required for all Part 98 subparts to which the reporter is subject. 

2 Under this proposal, the inputs verification tool would not be required to be used by reporters for any reported 

GHG for which the reporter uses a CEMS or an EPA-approved alternative method (as allowed under sections 

98.33(a)(5), 98.53(a)(2), and 98.223(a)(2) of Part 98) to calculate the reported GHG value, rather than using "inputs 

to equations" data elements and the associated EPA-provided calculation methodologies to calculate the reported 

GHG value.

3 The stationary fuel combustion sources (e.g., individual units, aggregations of units, common pipes, or common 

stacks) not affected by the proposed amendments include those meeting both of the following criteria: (1) the 

stationary fuel combustion source contains at least one combustion unit is connected to a devicefuel-fired electric 

generator that has been granted access by the Public Utilities Commission to deliver power to the local or regional 

electric power grid (e.g., electricity generators excluding generators connected to combustion units that are subject 

to subpart D of this partPart 98); and (2) the combinedstationary fuel combustion source is located at a facility for 

which the sum of the nameplate capacity (capacities for all such devices at the facility excluding generators 

connected to combustion units subject to subpart D of this part)) electric generators is greater than or equal to 1 

megawatt electric output. Refer to Section III.A.3 of this preamble for a discussion of the EPA’s rationale for 

proposing that combustion units meeting these criteria not be affected by the proposed amendments. 

D. Legal Authority

The EPA is proposing these rule amendments under its existing CAA authority provided 

in CAA section 114. As stated in the preamble to the 2009 final GHG reporting rule (74 FR 

56260, October 30, 2009), CAA section 114(a)(1) provides the EPA broad authority to require 

the information proposed to be gathered by this rule because such data would inform and are 

relevant to the EPA’s carrying out a wide variety of CAA provisions. See the preambles to the 

proposed (74 FR 16448, April 10, 2009) and final Part 98 (74 FR 56260) for further information. 

In addition, pursuant to sections 114, 301, and 307 of the CAA, the EPA is proposing 

confidentiality determinations for the new data elements proposed in this notice. Section 114(c) 

of the CAA requires that the EPA make publicly available information obtained under CAA 

section 114 except for information (excluding emission data) that qualifies for confidential 

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treatment. The Administrator has determined that this action (Part 98 amendment and 

confidentiality determinations) is subject to the provisions of CAA section 307(d). 

II. Summary of Proposed Changes to Part 98 Reporting and Recordkeeping Requirements 

The EPA is proposing revisions to the reporting and recordkeeping requirements in Part 

98 and alternative verification procedures that would apply to certain reporters subject to any of 

the 24 subparts listed in Table 2 of this preamble. Section II.A of this preamble summarizes a 

proposed new requirement for these reporters if they use inputs to emission equations for which 

reporting was deferred to March 31, 2015 (hereafter referred to as “inputs to equations” data 

elements) to calculate reported GHGs. Such reporters would be required to use an EPA-provided 

electronic inputs verification tool to calculate emissions using data elements for which reporting 

was deferred to March 31, 2015 (hereafter referred to as “inputs to equations” data elements), 

allowing the EPA to complete electronic verification of reported GHG emissions data without 

the need to collect “inputs to equations” data elements for which disclosure concerns have been 

identified. Section II.B of this preamble summarizes the EPA’s proposal to remove, for these 

reporters, the requirement to report many “inputs to equations” data elements. Section II.C of 

this preamble summarizes proposed revisions to the recordkeeping requirements for these 

reporters. Section II.D of this preamble summarizes proposed new reporting requirements for 

these reporters. Section III of this preamble explains the rationale for the proposed amendments 

summarized in Sections II.A through II.D. Section IV of this preamble presents the EPA’s 

proposed confidentiality determinations for proposed new data elements and the EPA’s rationale 

for these determinations. Section V of this preamble presents the cost and impacts associated 

with these proposed amendments. 

A. Proposed Use of Inputs Verification Tool 

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The EPA is proposing that facilities subject to the subparts listed in Table 2 of this 

preamble and that use “inputs to equations” data elements to calculate reported GHGs use an 

electronic inputs verification tool being developed by the EPA, which would calculate and verify 

GHG emissions. Refer to section III.A.1 of this preamble for a web-link to EPA’s “pilot” inputs 

verification tool for one subpart of Part 98, available during the public comment period for this 

rulemaking. The “pilot” demonstrates how the tool would work within e-GGRT, as well as the 

types of verification checks that would be conducted. The inputs verification tool would be 

deployed within the EPA’s Electronic Greenhouse Gas Reporting Tool (e-GGRT) and would be 

integrated without interrupting the current electronic reporting process. Reporters would 

enterWhile reporters enter data into e-GGRT that are required to be reported in the annual report, 

reporters would also enter into e-GGRT (via the inputs verification tool) the “inputs to 

equations” data elements that the EPA is proposing to remove from the reporting requirements

into e-GGRT along with the data required to be reported in the annual report.. The tool would 

use the entered “inputs to equations” data elements to calculate the equation outputs, conduct 

electronic verification checks on the “inputs to equations” data elements, and generate a 

verification summary. The tool would not retain the entered “inputs to equations” data elements 

for which the EPA is proposing that the reporting requirement be removed. Accordingly, the 

EPA would not have access to these “inputs to equations” data elements. Instead, the EPA would 

rely on the verification summary, which would become accessible to the EPA when annual 

reports are submitted, as a first step for conducting verification once the annual report is 

submitted. 

Sources subject to multiple subparts under Part 98 would be required to use the inputs 

verification tool for only those subparts listed in Table 2 of this preamble. The EPA is proposing 

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that reporters use this tool starting with reporting year 2014. Refer to Section III.A of this 

preamble for further discussion of this proposed requirement. 

This proposed requirement to use the inputs verification tool is specified in 40 CFR 98.5, 

Subpart A. Reporters would determine applicability under this new requirement based on a 

proposed new Table A-8 to Part 98, which lists all calculation methods under Part 98 for which 

the inputs verification tool must be used. Reporters calculating reported GHGs using a 

calculation method specified in proposed Table A-8 would be required to enter into the inputs 

verification tool “inputs to equations” data elements that have been removed from the reporting 

requirements. 

B. Proposed Revisions to Reporting of Data Elements Deferred until 2015

The EPA is proposing to remove the reporting requirement for 435440 “inputs to 

equations” data elements in the subparts listed in Table 2 of this preamble. Table 3 of this 

preamble provides a summary of how many data elements would be removed from reporting 

perfor each subpart. Refer to Table 1 in the memorandum “List of ‘Inputs to Equations’ Data 

Elements Proposed Not To Be Reported” (refer to Docket ID No. EPA–HQ–OAR–2010-0929) 

for a complete list of these 435440 data elements. For all remaining “inputs to equations” data 

elements not represented in Table 3 of this preamble and Table 1 of the memorandum cited 

above, the EPA is not amending these reporting requirements and would, therefore, let the 

deferral of these data elements expire on March 31, 2015. As a result, by March 31, 2015, all of 

the “inputs to equations” data elements for subpart W (Petroleum and Natural Gas Systems), 

Subpart II (Industrial Wastewater Treatment), and the additional “inputs to equations” data 

elements for which reporting is not proposed to be removed as indicated in Table 3 of this 

preamble, would be reported for future reporting years and for all prior reporting years prior to, 

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and, including, reporting year 2014. For a list of these “inputs to equations” data elements that 

would be reported, refer to Table 2 of the memorandum cited above.

Table 3. Subparts Forfor Which Reporting Requirements are Amended 

Subpart

Number of “Inputs to 

Equations” Data Elements 

Number of “Inputs to 

Equations” Data Elements 

Proposed Not to Be 

Reported 

C—General Stationary Fuel 

Combustion Except Certain 

Specified Stationary Fuel 

Combustion UnitsSources

Connected to DevicesCertain 

Electric Generators Connected 

and Able to Deliver Power to 

the Local or Regional Power 

Grid2

261

 261

E—Adipic Acid Production 21 11 

F—Aluminum Production 29 29 

G—Ammonia Manufacturing 8 8 

H—Cement Production 16 14 

K—Ferroalloy Production 13 13 

L—Fluorinated Gas Production 55 46 

N—Glass Production 3 3 

O—HCFC–22 Production and 

HFC–23 Destruction

15 12 

P—Hydrogen Production 7 7 

Q—Iron and Steel Production 93 92 

R—Lead Production 10 10 

S—Lime Manufacturing 9 9 

U—Miscellaneous Uses of 

Carbonate 

6 6 

V—Nitric Acid Production 21 6 

X—Petrochemical Production 21 21 

Y—Petroleum Refineries 80 7075

Z—Phosphoric Acid Production 4 4 

AA—Pulp and Paper 

Manufacturing 

31 28 

BB—Silicon Carbide 3 3 
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Subpart

Number of “Inputs to 

Equations” Data Elements 

Number of “Inputs to 

Equations” Data Elements 

Proposed Not to Be 

Reported 

Production 

CC—Soda Ash Manufacturing 10 4 

EE—Titanium Dioxide 

Production 

2 2 

GG—Zinc Production 8 8 

TT—Industrial Waste Landfills 3 3 

1 Includes one “inputs to equations” data element, 40 CFR 98.3(d)(3)(v), which is specified in subpart A of part 98 

and applies to only certain reporters under subpart C of part 98. 

2

 The reporting requirements applicable to certain combustion unitsstationary fuel combustion sources (e.g., 

individual units, aggregations of units, common pipes, or common stacks) subject to subpart C remain the same 

under the proposed amendment. Subpart C would continue to require reporting of all applicable “inputs to 

equations” data elements for stationary fuel combustion unitssources that meet both of the following criteria: (1) the 

stationary fuel combustion source contains at least one combustion unit is connected to a devicefuel-fired electric 

generator that has been granted access by the Public Utilities Commission to deliver power to the local or regional 

electric power grid (e.g., electricity generators excluding generators connected to combustion units that are subject 

to subpart D of this part); and (2) the stationary fuel combustion source is located at a facility for which the sum of 

the combined nameplate capacity (capacities for all such devices at the facility excludingelectric generators 

connected to combustion units subject to subpart D of this part)) is greater than or equal to 1 megawatt electric

output. Subpart C reporters would not report “inputs to equations” data elements for all other types of stationary fuel 

combustion unitssources subject to subpart C. 

In order to ease the burden for facilities, the EPA is proposing that the “inputs to 

equations” data elements that are not being amended in this action (and therefore would be 

reported for reporting years prior to reporting year 2014 (as described above) be reported as part 

of the annual report for reporting year 2014. Specifically, when reporters prepare their reporting 

year 2014 annual report via e-GGRT, they would be required to include these “inputs to 

equations” data elements for reporting year 2014 as well as for all applicable previous reporting 

years. The annual report, including these “inputs to equations” data elements that would still be 

reported, would be submitted via e-GGRT. This proposed approach would prevent facilities from 

being required to revise, re-certify, and re-submit annual reports for each previous reporting year. 

C. Proposed Changes to Recordkeeping Requirements

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For each facility subject to a subpart listed in Table 2 of this preamble, that uses “inputs 

to equations” data elements to calculate and report GHGs (i.e., subject to using the proposed 

inputs verification tool), the EPA is proposing that the facility retain all records, including 

records for subparts not subject to the inputs verification tool requirement, for 5 years, rather 

than the current 3-year record retention period. In other words, if any facility subject to a subpart 

listed in Table 2using the proposed inputs verification tool is also subject to a subpart of Part 98 

not listed in Table 2, we propose that records required for those other subparts also be 

maintained for the 5 years. For example, if such a facility is required to report under both subpart 

C (in Table 2) and subpart HH (not in Table 2), the facility would be required to maintain all 

records required under both subparts for 5 years following submittal of the annual report. The 

EPA is proposing that this 5-year record retention requirement begin with records for reporting 

year 2010. 

Additionally, we are proposing that, at the time a reporter subject to any subpart listed in 

Table 2 of this preambleusing the proposed inputs verification tool completes entry of all “inputs 

to equations” data elements into the inputs verification tool, the reporter would be required to 

keep a file generated by the tool that lists the entered “inputs to equations” data elements. The 

reporter would be required to maintain a copy of the file as a record of the entered inputs. As 

currently required in 40 CFR 98.3(g), subpart A, this file may be maintained in electronic or hard 

copy format. As discussed above, this record would be required to be maintained for 5 years.

Refer to Section III.B of this preamble for further discussion of these proposed 

recordkeeping requirements. 

D. Proposed New Data Elements to be Reported 

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The EPA is proposing that reporters subject to using the proposed inputs verification tool 

in subparts E, G, H, P, Q, S, V, X, Y, and AA of Part 98, be required to report the additional data 

elements listed per subpart in Table 4 of this preamble. Proposed confidentiality determinations 

for these proposed data elements are presented in Section IV of this preamble. 

Table 4. Proposed New Data Elements for Subparts E, G, H, P, Q, S, V, X, Y, and AA of 

Part 98 

Subpart Subpart Name New Data Element Description 

E Adipic Acid Production Annual quantity of cyclohexane fed to all production 

lines (metric tons). 

Annual percent N2O emission reduction for all 

production units combined. 

G Ammonia Production Annual ammonia production (metric tons). 

Annual methanol production (metric tons), if this 

quantity is not reported under subpart X of Part 98. 

H Cement Production Annual clinker production (metric tons). 

Annual average clinker CO2 emission factor for the 

facility, averaged across all kilns (metric tons 

CO2/metric ton clinker produced). 

Annual average cement kiln dust (CKD) CO2

emission factor for the facility, averaged across all 

kilns (metric tons CO2/metric ton CKD produced). 

P Hydrogen Production Name and annual quantity (metric tons) of each 

carbon-containing fuel and feedstock. 

Annual methanol production (metric tons), if this 

quantity is not reported under subpart X of Part 98. 

Q Iron and Steel Production If you use the carbon mass balance method in 40 CFR 

98.173(b)(1) to determine CO2 emissions: The annual 

mass (metric tons) of all gaseous, liquid, and solid 

fuels (combined) used in process units specified in 

Equations Q-1 through Q-7 of Part 98, calculated as 

specified in a proposed new Equation Q-9 in the 

proposed rule amendments. Do not include fuel used 

in a stationary combustion unit where emissions are 

reported under subpart C of this part. 

If you use the carbon mass balance method in 40 CFR 

98.173(b)(1) to determine CO2 emissions: The annual 

mass (metric tons) of all non-fuel material inputs 

(combined) specified in Equations Q-1 through Q-7 of 

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Subpart Subpart Name New Data Element Description 

Part 98, calculated as specified in a proposed new 

Equation Q-10 in the proposed rule amendments. 

If you use the carbon mass balance method in 40 CFR 

98.173(b)(1) to determine CO2 emissions: The annual 

mass (metric tons) of all solid and liquid products and 

byproducts (combined) specified in Equations Q-1 

through Q-7 of Part 98, calculated as specified in a 

proposed new Equation Q-11 in the proposed rule 

amendments. 

If you use the carbon mass balance method in 40 CFR 

98.173(b)(1) to determine CO2 emissions: The 

weighted average carbon content of all gaseous, 

liquid, and solid fuels (combined) included in 

proposed new Equation Q-9, calculated as specified in 

a proposed new Equation Q-12 in the proposed rule 

amendments. 

If you use the carbon mass balance method in 40 CFR 

98.173(b)(1) to determine CO2 emissions: The 

weighted average carbon content of all non-fuel inputs 

to all furnaces (combined) included in proposed new 

Equation Q-10, calculated as specified in a proposed 

new Equation Q-13 in the proposed rule amendments. 

If you use the carbon mass balance method in 40 CFR 

98.173(b)(1) to determine CO2 emissions: The 

weighted average carbon content of all solid and 

liquid products and byproducts from all furnaces 

(combined) included in a proposed new Equation Q11 in the proposed rule amendments, calculated as 

specified in new Equation Q-14. 

S Lime Manufacturing Annual quantity (metric tons) of lime product sold, by 

type. 

V Nitric Acid Production Annual percent N2O emission reduction for all 

production units combined. 

X Petrochemical Production If using the mass balance method or CEMS method to 

calculate GHG emissions: Name and annual quantity 

(in metric tons) of each carbon-containing feedstock

included in Equations X-1, X-2 and X-3..

If using the mass balance method or CEMS method to 

calculate GHG emissions: Name and annual quantity 

(in metric tons) of each carbon-containing co-product

included in Equations X-1, X-2 and X-3..

Y Petroleum Refineries Annual quantity of flare gas combusted (in MMscf per 

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Subpart Subpart Name New Data Element Description 

year) (only when using Equation Y-3). 

Annual average molecular weight of flare gas 

combusted (in mmBtu per MMscf) (only when using 

Equation Y-3). 

Annual average carbon content of flare gas combusted 

(expressed as a decimal fraction)(only when using 

Equation Y-3). 

AA Pulp and Paper 

Manufacturing 

For each pulp mill lime kiln: Quantity of calcium 

oxide (CaO) produced (metric tons). 

For each pulp mill lime kiln: Percent of annual heat 

input, individually for each fossil fuel type. 

For each chemical recovery furnace and chemical 

recovery combustion unit for which you are not using 

Equation C-2c to calculate CO2 emissions: Annual 

mass of steam generated (lb steam), individually for 

each fossil fuel type and for spent liquor solids. 

For each chemical recovery furnace and chemical 

recovery combustion unit for which you are not using 

Equation C-2c to calculate CO2 emissions: Ratio of 

the unit’s maximum rated heat input capacity to its 

design rated steam output capacity (mmBtu/lb steam), 

individually for each fossil fuel type and for spent 

liquor solids. 

III. Rationale for Proposed Changes to Reporting and Recordkeeping Requirements 

Based on the four-step evaluation described in Section I.B of this preamble, in particular 

the disclosure concerns discussed in “Step 2” of the evaluation and the alternatives considered in 

“Step 3” and “Step 4” of the evaluation to address those disclosure concerns, the EPA is 

proposing an alternative verification approach. This approach involves use of an inputs 

verification tool and revisions to the reporting and recordkeeping requirements of Part 98. The 

EPA’s rationale for this approach is presented in Sections III.A through C below. Section III.A 

addresses the proposed inputs verification tool and revisions to the requirement to report certain 

“inputs to equations” data elements. Section III.B addresses the proposed revisions to 

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recordkeeping requirements. Section III.C addresses the proposed addition of new reporting 

requirements. 

A. Proposed Inputs Verification Tool and Amendment to Reporting Requirements

The EPA is proposing that facilities subjectusing “inputs to equations” data elements to 

calculate reported GHGs under the subparts listed in Table 2 of this preamble use an EPAprovided electronic inputs verification tool, which would calculate and verify GHG emissions. 

The inputs verification tool would be deployed within e-GGRT and integrated without 

interrupting the current electronic reporting process. Reporters would enter their “inputs to 

equations” data elements into the tool within the e-GGRT system along with the data required to 

be reported in the annual report (concurrent entry of “inputs to equations” data elements and data 

required for the annual report would be required starting in reporting year 2014, as further 

discussed in Section III.A.2 of this preamble). As a built-in feature of the e-GGRT system, the 

tool would use the entered “inputs to equations” data elements to calculate the equation outputs, 

conduct electronic verification checks on the “inputs to equations” data elements, and generate a 

verification summary. The tool would not retain the entered “inputs to equations” data elements 

for which the EPA is proposing that the reporting requirement be removed.4

 Accordingly, unlike 

data currently reported to the EPA through e-GGRT, the EPA would not have access to these 

“inputs to equations” data elements. 

SourcesAny such sources subject to multiple subparts under Part 98 would be required to 

use the tool for only those subparts listed in Table 2 of this preamble, as discussed in the 

following section. 

1. Detailed Description of Inputs Verification Tool.

 

4

 Please see section III.A.3 of this preamble for a discussion on which “inputs to equations” data elements the EPA 

is proposing that the reporting requirementrequirements be removed. 

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The EPA’s current verification approach consists of electronic verification checks 

followed by direct follow-up with facilities. For subparts where the reporting of inputs to 

emission equations has been deferred until 2015, these checks have been conducted using 

reported data other than inputs to emission equations (the reporting of which was deferred). For 

“supplier” subparts5

 (and starting in reporting year 2012 for subparts with inputs to emission 

equations that were deferred until 2013), these checks have been conducted using reported data 

that include the data needed to calculate outputs of the equations. Reporters under the supplier 

subparts have been entering into e-GGRT the data needed to calculate the annual GHG 

quantities. For reporters under the direct emitter subparts listed in Table 2 of this preamble that 

are using “inputs to equations” data elements to calculate reported GHGs, the EPA is proposing 

to use an approach similar to that currently used for the supplier subparts, where “inputs to 

equations” data elements would be entered into the inputs verification tool within e-GGRT and 

used to calculate the annual GHG emission values and verify these emission values. The 

difference, however, is that these “inputs to equations” data elements would be entered into this 

new inputs verification tool within e-GGRT and would not be reported to the EPA. 

To access the inputs verification tool, reporters would log into e-GGRT. They would 

enter data elements required for the annual report as well as their “inputs to equations” data 

elements. The tool would operate securely within e-GGRT, as a transient process, which means 

that “inputs to equations” data elements (for which the EPA is proposing that the reporting 

requirement be removed) entered into the tool would be temporarily saved in the tool while the 

reporter is actively using the tool, but would not be persisted (i.e., saved) within the e-GGRT 

database. The “inputs to equations” data elements would be discarded when the user’s session 

 

5

 Supplier subparts (subparts LL through PP of Part 98) apply to fossil fuel suppliers and industrial gas suppliers. The eGGRT system currently calculates equation outputs for suppliers using reported equations inputs. Subpart MM 

reporters began using e-GGRT for reporting in Reporting Year 2012. 

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with e-GGRT ends. Refer to the memorandum “Technical Approach and Design for Inputs 

Verification Tool” (refer to Docket ID No. EPA–HQ–OAR–2010-0929) for a detailed 

description of EPA’s technical approach and design for the inputs verification tool. The 

memorandum describes how the inputs verification tool would use entered data only during the 

reporters’ e-GGRT session and would delete all records of entered data when the reporters exits 

the system. 

If the reporter exits the inputs verification tool prior to completing data entry or 

submitting their annual report, the tool would generate a file of entered “inputs to equations” data 

elements, and allow the reporter to download the file. This file could then be uploaded into the 

tool when the reporter next uses the tool. to continue with data entry for the same reporting year.

This would avoid facilities from needing to re-enter “inputs to equations” data elements that 

were entered in previous e-GGRT sessions. 

After the reporter enters the “inputs to equations” data elements into the inputs 

verification tool, the tool would calculate the annual GHG emissions values. The tool would use 

the following information in calculating these values: (1) “inputs to equations” data elements (for 

which reporting under this action is proposed to be removed) entered into the tool, (2) “inputs to 

equations” data elements entered into e-GGRT (not into the inputs verification tool) (refer to 

Section III.A.3 of this preamble for a discussion of the “inputs to equations” data elements that 

would still be reported under this proposal), (3) information entered into e-GGRT identifying 

which Part 98 calculation method was selected (if applicable), and (4) the selected Part 98 

calculation method. Once the annual GHG emissions values are calculated, the values would be 

pre-filled into the appropriate reporting fields within e-GGRT. Reporters would then have the 

opportunity to override the annual GHG emissions values calculated by the tool with their own 
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calculated value. If the reporter chose to override the calculated value, this would be reflected in 

the verification summary. 

Prior to annual report submittal, the inputs verification tool would conduct a series of 

verification checks, including the following: 

 Verification checks on the annual GHG emission values calculated by the inputs 

verification tool. As mentioned above, reporters would have the opportunity to override 

and revise the value calculated by the tool; however should this occur, the tool would 

note a discrepancy, which would prompt the EPA for further review after the reporter 

submits the annual report. 

 Verification checks on entered “inputs to equations” data elements. For example, the tool 

would check: (1) whether all required data were entered; (2) whether entered “inputs to 

equations” data element values are within the expected ranges for the data elements; and 

(3) whether expected relationships exist between certain “inputs to equations” data 

elements and certain other reported data elements (e.g., process raw material or 

throughput data that are not “inputs to equations” data elements). 

Some of these checks would be conducted as the reporter enters “inputs to equations” 

data elements (i.e., using “real-time” checking), and other checks would be conducted after the 

reporter has entered all “inputs to equations” data elements, because some algorithms may 

compare certain “inputs to equations” data elements (e.g., production quantity) to GHG emission 

values at the subpart or facility level. 

Also, prior to submittal of the annual report, the inputs verification tool would generate a 

verification summary containing the results of the verification checks. The verification summary 

would specify whether any potential errors, as described above, were identified, without 

specifying any information about the “inputs to equations” data elements. The reporter would 

have an opportunity to review the verification summary and make necessary revisions to the 

entered “inputs to equations” data elements and the reported data elements. 

For example, a facility subject to subpart G that manufactures ammonia using liquid and 

solid feedstocks is currently required under 40 CFR 98.76(b)(1) to report annual CO2 process 

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emissions for each ammonia manufacturing unit. Currently, the reporter calculates this reported 

annual GHG emissions value outside of e-GGRT (e.g., using a calculator or computer software), 

using Equations G-2, G-3, and G-4 of Part 98, and monthly values for the following “inputs to 

equations” data elements: quantity of liquid feedstock, quantity of solid feedstock, carbon 

content value for liquid feedstock, and carbon content value for solid feedstock. We are 

proposing that the reporter instead calculate this reported annual GHG emissions value using the 

inputs verification tool, which not only would use the same equations and data for calculation, 

but would also conduct verification checks, as follows: 

 The reporter would enter all 48 “inputs to equations” data elements” into the inputs 

verification tool (i.e., monthly values for all four “inputs to equations” data elements). 

 The reporter would use the inputs verification tool to calculate annual CO2 process 

emissions. In calculating this value, the tool would use Equations G-2, G-3, and G-4 of 

Part 98 and the 48 “inputs to equations” data element entries. 

 Once the annual CO2 process emissions value is calculated, the inputs verification tool 

would automatically conduct verification checks on the 48 entered “inputs to equations” 

data elements. For example, the tool might conduct the following checks: 

 - Real-time checks that all 48 “inputs to equations” data elements were entered. 

 - Real-time checks that each of the 12 entered values for carbon content of liquid 

feedstock is within the expected range for carbon content of liquid feedstock (based 

on industry-wide data). The tool would conduct similar comparisons for the 12 

entered “inputs to equations” data elements for the carbon content value for solid 

feedstock. 

 - Run an algorithmAlgorithm check comparing each of the 12 entered values of the 

quantity of the liquid feedstock to all monthly values entered for the year, to 

determine if individual values are within an expected range established using all 12 

values. The tool would conduct similar comparisons for the 12 entered “inputs to 

equations” data elements for the quantity of solid feedstock. This type of check would 

be conducted after the reporter has entered all “inputs to equations” data elements. 

 Prior to annual report submittal, the inputs verification tool would automatically generate 

a verification summary, which would flag any potential errors, providing an opportunity 

for the reporter to review the verification summary and revise entered data. The 

verification summary would note if the reporter has overridden any of the annual GHG 

emissions values calculated by the tool. After the reporter completes all revisions to data 

entries, the tool would automatically re-generate the verification summary prior to annual 

report submittal. The EPA would access the verification summary (i.e., the same final 

summary viewed by the reporter) following annual report submittal and certification. 

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 The inputs verification tool would also generate a file listing the entered “inputs to 

equations” data elements (for which the EPA is proposing to remove the reporting 

requirements) to be kept by the reporter and maintained as a record in a format currently 

allowed under Part 98 (see 40 CFR 98.3(g), subpart A). Refer to Section III.B of this 

preamble for further discussion of this proposed amendment and the EPA’s rationale for 

requiring this record. 

The EPA has developed a “pilot” inputs verification tool for one subpart, subpart CX, 

which will be posted at http://www.epa.gov/ghgreporting/reporters/training/rulepilot.html, to 

demonstrate how the tool would work within e-GGRT, as well as the types of verification checks 

that would be conducted. The EPA seeks comment on the usability of the tool as well as its 

ability to conduct verification on the “inputs to equations” data elements. The EPA also seeks 

comment on additional approaches considered by EPA for implementation of the inputs 

verification tool; refer to the memorandum “Evaluation of Alternative Verification Approaches 

for Greenhouse Gas Reporting Rule Subparts for which Reporting of Inputs to Emission 

Equations was Deferred to March 31, 2015” (refer to Docket ID No. EPA–HQ–OAR–2010-

0929) for a description of these additional approaches considered. 

2. Rationale Supporting the Use of the Inputs Verification Tool as an Alternative to 

Collecting Certain “Inputs to Equations” Data Elements for Verification Purposes. 

In the October 30, 2009 final rule (74 FR 56282 – 56283), the EPA described its 

verification approach as the following two-step process: 

 Initial automated review of reported data, using an electronic data quality assurance 

program built into the data system, for use by reporters and the EPA to help assure the 

completeness and accuracy of data. 

 Based on the initial review results, follow up with facilities regarding potential errors, 

discrepancies, or questions, including on-site audits. 

The EPA is currently using the two-step verification process of automated verification 

checks followed by direct follow-up with facilities to verify data currently reported via e-GGRT. 

The EPA is proposing to supplement the current verification approach for facilities reporting 

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under the subparts listed in Table 2 of this preamble using the additional checks that would be 

conducted by the inputs verification tool. During the first 3 years of the Greenhouse Gas 

Reporting Program (GHGRP), the EPA has had success developing and using an electronic 

reporting and verification system for all subparts reporting under the program. During reporting 

year 2010, the EPA developed approximately 1,400 electronic verification checks to verify 

reported data. Based on these verification checks, the EPA followed up with approximately 

2,360 of the approximately 6,700 facilities that reported in reporting year 2010, resulting in 

approximately 2,300 facilities resolving verification issues by responding to the EPA and/or 

resubmitting their annual report. In reporting year 2011, the EPA programmed an additional 

1,000 checks into e-GGRT for the subparts that were reporting for the second year, expanding 

the number of checks to 2,400. The EPA also programmed into e-GGRT, for 2011, 

approximately 1,300 checks for the newly-reporting subparts. During reporting year 2011, the 

EPA followed up with approximately 3,440 of the approximately 8,000 facilities that reported, 

resulting in approximately 3,000 facilities resolving their verification issues. 

For example, for subpart H, the EPA verifies reported GHG emissions data using: (1) 

reported cement production data and (2) publicly available industry data on GHG emissions. 

Using these data, the EPA has established ranges of acceptable production and emission values 

and set up algorithm checks for reported GHG emission values. 

The electronic checks used by the GHGRP have served as a means for the EPA to verify 

reported data while minimizing the burden on both the EPA and reporters. Electronic verification 

is a critical first step to ensuring the completeness and accuracy of reported data and reducing the 

costs of compliance monitoring. 
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The inputs verification tool described in Section III.A.1 of this preamble utilizes the same 

approach that the EPA currently uses for calculating and verifying data submitted for supplier 

subparts (and starting in reporting year 2012, inputs to emission equations whose reporting 

deadline was deferred until 2013), except that e-GGRT would not retain the “inputs to 

equations” data elements entered into the tool. Once the annual report is submitted, the EPA 

would review the verification summary generated by the inputs verification tool, along with 

verification summaries that are currently generated using data currently collected through the 

annual report. By requiring use of the inputs verification tool, the EPA would have the additional 

certainty that reported annual GHG emissions values either were calculated correctly (because 

the values calculated by the tool were submitted to the EPA) or that the EPA would be made 

aware that there were discrepancies between values calculated by the tool and values submitted 

to the EPA. That additional certainty, combined with the additional information provided by the 

range and algorithm checks on the “inputs to equations” data elements themselves, would 

provide the EPA with information necessary to conduct further verification once the annual 

report is submitted. 

If a potential error with one of the “inputs to equations” data elements or with an annual 

GHG emissions value were identified in the verification summary generated by the inputs 

verification tool, the EPA would likely follow up with the facility to determine whether an actual 

error has occurred. While this verification approach may result in more direct follow-up with 

facilities than if the “inputs to equations” data elements were submitted to the EPA, this 

approach would facilitate verification by identifying potential errors and minimizing the number 

of errors before annual reports are submitted. In addition, as discussed elsewhere in the 

preamble, the EPA is retaining the reporting requirement for “inputs to equations” data elements 
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for which our four-step evaluation did not identify disclosure concerns and is proposing to 

require reporting of additional new data elements to assist the EPA’s verification effort. These 

“inputs to equations” data elements for which reporting would be retained and these proposed 

new reported data elements would allow the EPA to conduct additional verification and 

minimize the number of follow-ups with facilities. LastlyLastly, for the reasons specified in 

section III.B of this preamble, the EPA is proposing that facilities retain records for 5 years, 

which would allow the EPA time to perform any necessary follow-up with reporters. For the 

reasons stated above, the EPA has determined that the proposed verification approach would be 

adequate to verify the reported emissions for reporters using “inputs to equations” data elements 

to calculate reported GHGs under the subparts identified in Table 2 of this preamble and is a 

reasonable alternative to collecting “inputs to equations” data elements for which we have 

identified disclosure concerns. 

The EPA is proposing to require the use of the inputs verification tool starting inwith

reporting year 2014. The inputs verification tool is designed to be used concurrently with annual 

reporting by facilities. By the time the EPA takes any final action on this proposed amendment, 

reporters would have likely have already submitted annual reports for reporting years 2010 

through 2013. While additional verification could be conducted on the past years’ data if the 

inputs verification tool were used for these years, given that most of the data would likely 

already have been published and that the use of best available monitoring methods (BAMM) for 

these sectors is relatively low during these years, the EPA has determined that the added benefit 

does not outweigh the burden that would be required for facilities to use the inputs verification 

tool for years prior to reporting year 2014. 
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3. Reporting of 435440 “Inputs to Equations” Data Elements Would Not Be Necessary With the 

Proposed Verification Approach.

The EPA is proposing to remove the reporting requirement for 435440 “inputs to 

equations” data elements that are in the subparts listed in Table 2 of this preamble. With the 

proposed alternative verification approach described in Section III.A.2 of this preamble, the EPA 

would no longer need to rely on the collection of these “inputs to equations” data elements to 

verify emissions under those subparts. Not having these data elements reported would address 

concerns relative to potential disclosure of these data elements.6

 These 435440 data elements are 

specified in Table 1 of the memorandum “List of Inputs to Equations Data Elements Proposed 

Not To Be Reported” (refer to Docket ID No. EPA–HQ–OAR–2010-0929). 

The 435440 “inputs to equations” data elements for which the EPA is proposing to 

remove the reporting requirement must be maintained on-site as records. Because Part 98 already 

requires these “inputs to equations” data elements to be kept as records (see 98.3(g)(2), which 

states that “the data used to calculate the GHG emissions for each unit, operation, process, and 

activity, categorized by fuel or material type” must be kept as records), the EPA is not proposing 

in this action to movespecify each of the 435440 “inputs to equations” data elements toin the 

recordkeeping requirementssection of each subpart. The EPA considered whether 

movingspecifying each of these “inputs to equations” data elements toin the recordkeeping 

requirementssections of each subpart would improve the clarity of the specific records that 

would be required to be retained. Because the EPA is proposing that the “inputs to equations” 

data elements that would not be reported must be kept as records in the format generated by the 

 

6

Wewe are proposing to remove the reporting requirement for certain “inputs to equations” data elements because, 

while there is not a disclosure concern, the EPA we determined that these data elements would not be useful for data 

verification and would not inform future GHG policy development in the absence of other data elements for which 

we are proposing to remove the reporting requirement.

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inputs verification tool (i.e., file for downloading or printing), the EPA determined that the data 

that must be kept as records would be sufficiently clear. The EPA seeks comment on whether 

additional specificity within the recordkeeping requirements of each subpart would improve the 

clarity of the specific records that are required to be retained. 

For the purposes of clarifying which data elements must be reported for previous 

reporting years 2010 through 2013, we are proposing to revise Table A-7 of Part 98 to remove all 

435440 data elements for which reporting is proposed to be removed. To be consistent with a 

separate action that is proposing to remove additional “inputs to equations” The data elements 

from Part 98 (40 CFR 98.256(o)(6) and (o)(7))), we that are also proposing to remove these

additional data elementsnot being removed from Table A-7. For the EPA’s rationale would 

continue to be reporting requirements, and must be reported for removing these additional data 

elements from Part 98, refer to the preamble to the April 2,previous reporting years 2010 through

2013 proposal, “2013 Revisions to the Greenhouse Gas Reporting Rule and Proposed 

Confidentiality Determinations for New or Substantially Revised Data Elements,” (78 FR 

19802)., as appropriate. 

The EPA is retaining reporting of 153170 “inputs to equations” data elements.7 These 

153Refer to Table 2 in the memorandum “List of ‘Inputs to Equations’ Data Elements Proposed 

Not To Be Reported” (refer to Docket ID No. EPA–HQ–OAR–2010-0929) for a complete list of 

these 170 data elements. The 170 “inputs to equations” data elements include certain “inputs to 

equations” data elements for the subparts listed in Table 3 of this preamble, as well as all “inputs 

to equations” data elements for subparts C (only for certain specified stationary fuel combustion 

 

7

 These 153170 “inputs to equations” data elements include: (1) nine “inputs to equations” data elements in subpart 

L of part 98 that are not being addressed in this rulemaking andbecause they will be addressed in a separate action 

related to subpart L; and (2) five “inputs to equations” data elements in subpart Y of part 98 that were proposedare 

not being addressed in this rulemaking because they are being addressed in a separate action. Refer to the EPA’s 

April 2, 2013 rulemaking (78 FR 19802) to for EPA’s proposal that these five inputs be removed from reporting. 

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unitssources connected to a devicecertain electric generators that deliversdeliver power to the 

local or regional electric power grid)8, W, and II of part 98. For these “inputs to equations” data 

elements, the EPA is not amending these reporting requirements and would therefore let the 

deferral of these data elements expire on March 31, 2015. As a result, these “inputs to equations” 

data elements would be reported for future reporting years starting with reporting year 2014, as 

well as for previous reporting years (i.e., reporting years 2010 through 2013). Based on “Step 2” 

of our evaluation described in Section I.B of this preamble, these data elements would not raise 

disclosure concerns. Having these data elements reported would allow the EPA to do additional 

verification, including conduct year-to-year comparisons, thereby reducing the amount of direct 

follow-up required with facilities. For the reason stated above, collecting these data elements, 

even in the absence of collecting all “inputs to equations” data elements, would aid in the 

verification process. 

The EPA identified 23 “inputs to equations” data elements for which disclosure concerns 

were not identified based on “Step 2” of our evaluation; however, the EPA is not retaining these 

reporting requirements. The EPA determined that these 23 data elements would not be useful for 

data verification and would not inform future GHG policy development in the absence of other 

“inputs to equations” data elements for which the reporting requirement is proposed to be 

removed under this action. Examples of these 23 “inputs to equations” include reporting the 

selected default molar volume conversion factor and reporting the units of measure of a sitespecific emission factor. These “inputs to equations” are identified in the memorandum “List of 

 

8

 Refers to stationary fuel combustion sources (e.g., individual units, aggregations of units, common pipes, or 

common stacks) subject to subpart C meeting both of the following criteria: (1) the stationary fuel combustion 

source contains at least one combustion unit is connected to a devicefuel-fired electric generator that has been 

granted access by the Public Utilities Commission to deliver power to the local or regional electric power grid (e.g., 

electricity generators excluding generators connected to combustion units that are subject to subpart D of this part); 

and (2) the combinedstationary fuel combustion source is located at a facility for which the sum of the nameplate 

capacity (capacities for all such devices at the facility excluding generators connected to combustion units subject to 

subpart D of this part)) electric generators is greater than or equal to 1 megawatt electric output. 

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‘Inputs to Equations’ Data Elements Proposed Not To Be Reported” (refer to Docket ID No. 

EPA–HQ–OAR–2010-0929). 

Regarding the 153170 retained “inputs to equations” data elements, for reporting year 

2014 and thereafter, reporters would enter the 153170 “inputs to equations” data elements for 

which we are retaining the reporting requirement into e-GGRT. Starting in reporting year 2014, 

the e-GGRT system would retain these 153170 data elements as part of the annual report and

they would be accessible by the EPA once the reporter submits the annual report. In order to ease 

the burden on facilities, for reporting years prior to reporting year 2014, the EPA is proposing 

that these reported “inputs to equations” data elements be submitted as part of the reporting year 

2014 annual report. ThisSpecifically, when reporters prepare their reporting year 2014 annual 

report via e-GGRT, they would be required to include these “inputs to equations” data elements 

for reporting year 2014 as well as for all applicable previous reporting years. The annual report, 

including these “inputs to equations” data elements would be submitted via e-GGRT. This 

approach would prevent facilities from being required to revise, re-certify, and re-submit annual 

reports for reporting years 2010, 2011, 2012, and 2013. 

The proposed revisions to the current reporting requirements would apply to all reporters 

subject to the subparts listed in Table 2 of this preamble, including subpart C., and using “inputs 

to equations” data elements to calculate reported GHGs. However, as noted in Table 2, we are 

not proposing to amend the reporting requirements for stationary fuel combustion unitssources

subject to subpart C (e.g., individual units, aggregations of units, common pipes, or common 

stacks) that meet the following criteria: (1) the stationary fuel combustion source contains at least 

one combustion unit is connected to a devicefuel-fired electric generator that has been granted 

access by the Public Utilities Commission to deliver power to the local or regional electric power 
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grid (e.g., electricity generators excluding generators that are connected to combustion units 

subject to subpart D of this part); and (2) the combinedstationary fuel combustion source is 

located at a facility for which the sum of nameplate capacity (capacities for all such devices at 

the facility excluding generators connected to combustion units subject to subpart D of this part)

electric generators is greater than or equal to 1 megawatt electric output. The “inputs to 

equations” data elements for these stationary fuel combustion unitssources are among those that 

did not raise disclosure concerns under “Step 2” of our evaluation of the “inputs to equations” 

data elements (refer to Section I.B of this preamble for a discussion of the EPA’s four-step 

evaluation). Refer to the memoranda documenting “Step 2” of our evaluation, “Evaluation of 

Competitive Harm From Reporting 2015 Inputs to Equations” (Docket ID No. EPA–HQ–OAR–

2010-0929), for further information on the results of the analysis for these stationary fuel 

combustion unitssources. 

Reporters currently reporting emissions for stationary fuel combustion unitssources under 

subpart C have the option to utilize one or more of the reporting options under subpart C that 

allow the grouping of stationary combustion units for the purpose of monitoring, calculating, and 

reporting emissions. The EPA recognizes that stationary combustion units grouped in these 

reporting configurations could include both combustion units associated with devices that can 

produce electricityelectric generators (excluding generators connected to combustion units 

subject to subpart D of this part) (connected to the grid and not connected to the grid) and 

combustion units not associated with devices that can produce electricity.electric generators 

(excluding generators connected to combustion units subject to subpart D of this part). In these 

cases where combustion units are grouped, the EPA has determined that there would be no 

disclosure concerns with reporting of “inputs to equations” data elements for the grouped 
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combustion units. In reporting combined data for multiple units including those associated with a 

device capable of producing electricityan electric generator and subject to reporting under this 

proposed action, no unit-specific data would be revealed. Furthermore, should a facility not wish 

to disclose aggregated data, it would have the option to calculate and report emissions using one 

of the individual unit reporting configurations. The EPA seeks comment on this conclusion. If 

you believe that there are any disclosure concerns, please provide detailed information about the 

concern, as well as whether reporting on an individual unit basis is a feasible reporting option. 

Additionally, the EPA is proposing to revise two paragraphs (40 CFR 98.116(e)(6) and 

40 CFR 98.186(b)(8)) that reference other paragraphs that include “inputs to equations” data 

elements proposed to be removed from Part 98. As a result, we are proposing to remove the cross 

reference while carrying over the substantive information in order to maintain the requirements 

in these paragraphs. 

The EPA requests comment on the proposed inputs verification tool and verification 

approach, and the associated revision to the current reporting requirements as described in this 

section. 

B. Proposed Revisions to Recordkeeping Requirements

Given the proposed verification approach described in Section III.A of this preamble, the 

EPA considered whether the current record retention period and record format requirements 

would be sufficient to allow the EPA to perform data verification. We considered: 

 The time we would need to follow up with reporters to further verify reported GHG 

emissions. 

 The desirability of retaining multiple years of data records to allow for appropriate 

assessment of compliance and for analyses of trends for policy analysis purposes. 

 The format of records, and whether the current format would be adequate for our 

verification process. For example, we considered whether records of “inputs to 

equations” data elements contained in multiple separate documents (as currently allowed 

under Part 98) would allow an EPA inspector to efficiently analyze the consistency of the 

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data elements and use the data elements to perform calculations to confirm reported GHG 

emissions. 

Because there may be more direct follow-up activities under this alternative verification 

approach, we are proposing to extend the record retention period from 3 to 5 years. We have 

determined that 5 years is reasonable given the large number of reporters under the subparts 

identified in Table 2 of this preamble (over 2,000 facilities) and the likely increase in follow-up 

activities. It would be important that relevant records are available to the EPA for follow-up 

activities with facilities, including on-site audits if necessary, regarding potential errors, 

discrepancies, or questions. Should an EPA inspector visit a facility, it would be important to be 

able to examine not only the current year’s records but those from previous years as well, 

because previous years’ data would provide year-to-year comparisons, which are useful for 

verifying the current year’s data. A 5-year record retention period would ensure the availability 

of relevant records for the follow-up activities described above. The EPA is proposing that this 

5-year record retention requirement begin with records for reporting year 2010, as discussed in 

Section III.A.1 of this preamble. 

TheFor reporters subject to using the proposed inputs verification tool, the EPA is 

proposing to extend the record retention period not only for the subparts listed in Table 2 of the 

preamble, but also for other subparts that apply to reporters subject to a subpart in Table 2. 

Under this proposal, aany such facility subject to both a subpart listed in Table 2 of this preamble 

and a subpart not listed in Table 2 would be required to maintain all records required under both 

subparts for a period of 5 years. For example, if a facility is required to report underuse the 

proposed inputs verification tool under both subpart C (in Table 2) and to report under subpart 

HH (not in Table 2), the facility would be required to maintain all records required under both 

subparts for 5 years. The EPA is proposing these provisions for two reasons. First, the EPA 

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determined that during a site visit, if questions arise regarding the accuracy of an “inputs to 

equations” data element, it may be necessary to examine other non-input recordkeeping 

information, such as a monitoring plan or recordkeeping information in a different subpart, in 

order to fully investigate the accuracy of the data. It is necessary to ensure that all data necessary 

for verification are available, and this proposed 5-year record retention period would provide 

better assurance of on-site data availability. Second, the EPA determined that maintaining 

multiple sets of data records according to different record retention periods could possibly cause 

confusion and result in recordkeeping errors. Providing the same record retention duration for all 

subparts, as proposed, would simplify recordkeeping and thereby minimize the chance for 

recordkeeping errors. 

In addition, the EPA is proposing revisions to the recordkeeping format for “inputs to 

equations” data elements. Currently, reporters have the option to maintain records of their 

“inputs to equations” data elements in one or more electronic or hard copy files. The proposed 

record format revision would require reporters to maintain an electronic or hard copy of the 

single file generated by the proposed inputs verification tool, listing all “inputs to equations” data 

elements entered into the tool. This proposed record format change would ensure that the EPA 

could readily access these data, enabling the EPA to quickly and efficiently perform calculations 

and data checks during site visits. All other records required under Part 98 would be maintained 

in the format currently required under Part 98. In combination with the proposed reporting 

requirements discussed in Sections III.A and C of this preamble, these proposed recordkeeping 

requirements would allow the EPA to adequately verify certain reported emissions without 

implicating the disclosure concerns discussed in the memorandum “Evaluation of Competitive 

Harm For Reporting 2015 Inputs to Equations” 
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(refer to Docket ID No. EPA–HQ–OAR–2010-0929). 

In amending 40 CFR part 98, subpart A to add these recordkeeping requirements, we are 

also correcting an error in the current version of 40 CFR 98.3(g). In a previous action amending 

this paragraph (76 FR 73866, November 29, 2011), our intensionintention was to amend the 

second sentence of the paragraph regarding record retention duration; however, the third 

sentence regarding record format was inadvertently amended. To correct this error, we are 

proposing to remove the second sentence of 40 CFR 98.3(g) and to reinstate the previous third 

sentence of 40 CFR 98.3(g) (regarding format of records). 

We seek comment on whether 5 years is the appropriate timeframe for maintaining 

records for facilities withrequired to use the proposed inputs verification tool under a subpart 

listed in Table 2 of this preamble. In addition, we seek comment on the proposal to extend the 

record retention period for these reporters, not only for the subparts listed in Table 2 of the 

preamble, but also for other subparts that apply to these reporters subject to a subpart in Table 2. 

C. Proposed Requirement to Report Additional Data

As part of our proposal to no longer require reporting of certain “inputs to equations” 

data elements, we are proposing to require that certain reporters using the proposed inputs 

verification tool also report the new data elements specified in Table 4 of this preamble. These 

additional data elements would allow the EPA to perform additional verification checks and 

minimize the number of follow-up activities. These data elements are quantities that provide 

information on the activity level at the facility, emission factors used, characteristics of carboncontaining streams, and other process information that would provide key information for 

verification, including confirming that emissions are appropriate for a given activity-level and 

estimating expected emissions based on data provided. These new data reporting elements would 

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also enable the EPA to better understand the following aspects concerning reporters in order to 

inform future GHG policy:9

 (1) the GHG emission profile for the reporter; (2) the relationship of 

GHG emissions to production output or raw material input within the industry sector; and (3) the 

factors influencing GHG emissions. 

The EPA is proposing to add six new equations (Equations Q-9 through Q-14 of part 98) 

to subpart Q to specify how to calculate and report each of the six new data elements proposed to 

be added to subpart Q of part 98. Table 4 of this preamble specifies which equation number 

correlates with each new proposed data element. Refer to the proposed amendments for subpart 

Q for the proposed equations. 

The EPA is proposing confidentiality determinations for these proposed new data 

elements. Those new data elements determined to be confidential business information in a final 

rule would be afforded confidential treatment. Refer to the following Section IV of this preamble 

for the EPA’s proposed confidentiality determinations for the proposed new data elements. 

IV. Confidentiality Determination for Proposed New Data Elements to be Reported 

The EPA is proposing confidentiality determinations for each new data element listed in 

Table 4 of this preamble. To make these determinations, the EPA proposes to use the same 

approach that the EPA previously used for the 2011 final CBI rule (76 FR 30782, May 26, 2011). 

Specifically, the EPA is proposing to assign each new data element listed in Table 4 of this 

preamble to one of 11 direct emitter data categories, based on the type and characteristics of the 

data element. For a description of each data category and the type and characteristics of data 

elements assigned to each category, see Sections II.C and II.D of the July 7, 2010 CBI proposal 

preamble (75 FR 39106 – 39130). 

 

9

 The EPA has previously stated that a goal of collecting data under the GHGRP is to inform future GHG policy 

(refer to the April 10, 2009 proposed rule (74 FR 16455). 

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Based on its evaluation of the new data elements, the EPA is proposing that each new 

data element be assigned to one of the four following direct emitter data categories: 

 Production/Throughput Data that are Not Inputs to Emission Equations. 

 Raw Materials Consumed that are Not Inputs to Emission Equations. 

 Unit/Process “Static” Characteristics that are Not Inputs to Emission Equations. 

 Unit/ Process Operating Characteristics that are Not Inputs to Emission Equations. 

In the 2011 final CBI rule (May 26, 2011, 76 FR 30782), the EPA made categorical 

determinations that all data elements assigned to the “Production/Throughput Data that are Not 

Inputs to Emission Equations” and “Raw Materials Consumed that are Not Inputs to Emission 

Equations” data categories are entitled to confidential treatment because the data do not meet the 

definition of “emission data” in 40 CFR 2.301(a)(2)(i) and they are CBI. 

The EPA is proposing that seven new data elements be assigned to the 

“Production/Throughput Data that are Not Inputs to Emission Equations” data category and 10 

new data elements be assigned to the “Raw Materials Consumed that are Not Inputs to Emission 

Equations” data category, as shown in Table 5 of this preamble, thereby applying the categorical 

confidentiality determinations made for these categories in the 2011 final CBI rule (i.e., they are 

CBI) to the proposed new reporting elements assigned to these categories. This proposal is not 

changing, nor soliciting comment on, the categorical confidentiality determination for these two 

data categories. Should the EPA finalize the category assignment for these data elements, all new 

data elements assigned to these categories would be considered to be entitled to confidential 

treatment. 

Table 5. Data Elements Proposed to Be Assigned To the “Production/Throughput Data 

that are Not Inputs to Emission Equations” and “Raw Materials Consumed that are Not 

Inputs to Emission Equations” Data Categories 

Subpart Proposed Citation Data Element 

“Production/Throughput Data that are Not Inputs to Emission Equations” Data Category

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Subpart Proposed Citation Data Element 

G - Ammonia Production 40 CFR 98.76(c)(14) Annual ammonia production 

(metric tons). 

40 CFR 98.76(d)(15) Annual methanol production 

(metric tons), if this quantity is 

not reported under subpart X of 

Part 98. 

H - Cement Kilns 40 CFR 98.86(b)(16) Annual clinker production 

(metric tons). 

P – Hydrogen Production 40 CFR 98.166(e) Annual methanol production 

(metric tons), if this quantity is 

not reported under subpart X of 

Part 98.

S - Lime Manufacturing 40 CFR 98.196(b)(18) Annual quantity (metric tons) of 

lime product sold, by type.

X – Petrochemical 40 CFR 98.246(a)(13) and 

(b)(10) 

If using the mass balance 

method or CEMS method to 

calculate GHG emissions: 

Name and annual quantity (in 

metric tons) of each carboncontaining co-product included 

in Equations X-1, X-2 and X-3..

AA - Pulp and Paper 40 CFR 98.276(l)(1) For each pulp mill lime kiln: 

Quantity of calcium oxide 

(CaO) produced (metric tons).

“Raw Materials Consumed that are Not Inputs to Emission Equations” Data Category

E - Adipic Acid Production 40 CFR 98.56(m) Annual quantity of cyclohexane 

fed to all production lines, 

combined (metric tons). 

P - Hydrogen Production 40 CFR 98.166(b)(7) Name and annual quantity 

(metric tons) of each carboncontaining fuel and feedstock. 

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Subpart Proposed Citation Data Element 

Q - Iron and Steel 40 CFR 98.176(i)(1) If you use the carbon mass 

balance method in 40 CFR 

98.173(b)(1) to determine CO2

emissions: The annual mass 

(metric tons) of all gaseous, 

liquid, and solid fuels 

(combined) used in process 

units specified in Equations Q-1 

through Q-7, calculated as 

specified in a new Equation Q-9 

in the proposed rule 

amendments. Do not include 

fuel used in a stationary 

combustion unit where 

emissions are reported under 

subpart C of this part. 

40 CFR 98.176(i)(2) If you use the carbon mass 

balance method in 40 CFR 

98.173(b)(1) to determine CO2

emissions: The annual mass 

(metric tons) of all non-fuel 

material inputs (combined) 

specified in Equations Q-1 

through Q-7, calculated as 

specified in a new Equation Q10 in the proposed rule 

amendments. 

40 CFR 98.176(i)(3) If you use the carbon mass 

balance method in 40 CFR 

98.173(b)(1) to determine CO2

emissions: The annual mass 

(metric tons) of all solid and 

liquid products and byproducts 

(combined) specified in 

Equations Q-1 through Q-7, 

calculated as specified in a new 

Equation Q-11 in the proposed 

rule amendments. 

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Subpart Proposed Citation Data Element 

40 CFR 98.176(i)(4) If you use the carbon mass 

balance method in 40 CFR 

98.173(b)(1) to determine CO2

emissions: The weighted 

average carbon content of all 

gaseous, liquid, and solid fuels 

(combined) included in 

Equation Q-9, calculated as 

specified in a new Equation Q12 in the proposed rule 

amendments. 

40 CFR 98.176(i)(5) If you use the carbon mass 

balance method in 40 CFR 

98.173(b)(1) to determine CO2

emissions: The weighted 

average carbon content of all 

non-fuel inputs to all furnaces 

(combined) included in 

Equation Q-10, calculated as 

specified in a new Equation Q13 in the proposed rule 

amendments. 

40 CFR 98.176(i)(6) If you use the carbon mass 

balance method in 40 CFR 

98.173(b)(1) to determine CO2

emissions: The weighted 

average carbon content of all 

solid and liquid products and 

byproducts from all furnaces 

(combined) included in a new 

Equation Q-11 in the proposed 

rule amendments, calculated as 

specified in new Equation Q-14 

in the proposed rule 

amendments. 

X – Petrochemical 40 CFR 98.246(a)(12) and (b)(9) If using the mass balance 

method or CEMS method to 

calculate GHG emissions: 

Name and annual quantity (in 

metric tons) of each carboncontaining feedstock included 

in Equations X-1, X-2 and X-3..

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Subpart Proposed Citation Data Element 

AA - Pulp and Paper 40 CFR 98.276(m)(1) For each chemical recovery 

furnace and chemical recovery 

combustion unit for which you 

are not using Equation C-2c to 

calculate CO2 emissions: 

Annual mass of steam 

generated (lb steam), 

individually for each fossil fuel 

type and for spent liquor solids. 

The EPA is proposing to assign eight proposed new data elements to the “Unit Process 

Operating Characteristics that are Not Inputs to Emission Equations” category and one proposed 

new data element to the “Unit/Process Static Characteristics that are Not Inputs to Emission 

Equations” category. In the 2011 final CBI rule, the EPA determined that the data elements in 

these categories are not “emission data” (as defined at 40 CFR 2.301(a)(2)(i)). However, instead 

of categorical determinations, the EPA made confidentiality determinations for individual data 

elements assigned to these two categories. In proposing these determinations, the EPA 

considered the confidentiality criteria at 40 CFR 2.208, in particular whether release of the data 

is likely to cause substantial harm to the business’s competitive position. See 40 CFR 

2.208(e)(1). The EPA is therefore following the same approach in this action for the proposed 

new reporting elements assigned to these two categories. 

Table 6 of this preamble lists the data elements the EPA proposes to assign to these two 

data categories and presents the EPA’s rationale for proposing to determine that each does or 

does not qualify as CBI under CAA section 114(c). 

Table 6. Proposed Confidentiality Determinations for Proposed New Data Elements 

Assigned to the “Unit/Process Operating Characteristics That Are Not Inputs to Emission 

Equations” and “Unit/Process ‘Static’ Characteristics that Are Not Inputs to Emission 

Equations” Data Categories 

Subpart Citation 

Data 

Element 

Confidentiality 

Determination

Proposed Rationale for 

Confidentiality Determination

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Subpart Citation 

Data 

Element 

Confidentiality 

Determination 

Proposed Rationale for 

Confidentiality Determination 

“Unit/Process Operating Characteristics That Are Not Inputs to Emission Equations” Data 

Category

E – Adipic 

Acid 

Production 

40 CFR 

98.56(n) 

Annual 

percent N2O 

emission 

reduction for 

all production 

units 

combined. 

Not CBI The annual facility percent N2O 

reduction could not be used to 

calculate adipic acid production. 

The level of N2O reductions 

varies by the type of abatement 

technology, the environment in 

which the abatement technology 

is operating, the age of the 

abatement technology, the age of 

the catalyst used, and the 

maintenance level of the 

abatement technology.

H - Cement 

Kilns 

40 CFR 

98.86(b)(17) 

Annual 

average 

clinker CO2

emission 

factor for the 

facility, 

averaged 

across all 

kilns (metric 

tons 

CO2/metric 

ton clinker 

produced). 

CBI This data element could be used 

to back calculate a facility’s 

clinker production data, which 

would result in competitive 

disadvantage. 

40 CFR 

98.86(b)(18) 

Annual 

average 

cement kiln 

dust (CKD) 

CO2 emission 

factor for the 

facility, 

averaged 

across all 

kilns (metric 

tons 

CO2/metric 

ton CKD 

produced). 

CBI This data element could provide 

information about the efficiency 

of the operation, which would 

result in competitive 

disadvantage. 

V – Nitric 

Acid 

Production 

40 CFR 

98.226(q) 

Annual 

percent N2O 

emission 

reduction for 

all production 

Not CBI The annual facility percent N2O 

reduction for all nitric acid 

production trains combined 

could not be used to calculate the 

nitric acid production value for 

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Subpart Citation 

Data 

Element 

Confidentiality 

Determination 

Proposed Rationale for 

Confidentiality Determination 

units 

combined. 

any individual facility. The level 

of N2O reductions for each 

individual facility varies by the 

type of abatement technology, the 

environment in which the 

abatement technology is 

operating, the age of the 

abatement technology, the age of 

the catalyst used, and the 

maintenance level of the 

abatement technology. 

Additionally, facility-level N2O 

emission reduction information is 

already publicly available (see 

docket number EPA-HQ-OAR2010-0750 and 

http://www.climateactionreserve.

org).

Y – 

Petroleum 

Refineries 

40 CFR 

98.256(e)(11)(

i) 

Annual 

quantity of 

flare gas 

combusted 

(in MMscf 

per year) 

(only when 

using 

Equation Y3). 

Not CBI This data element does not reveal 

(nor could be used to calculate) 

details regarding product 

characteristics, actual production 

data, or operating efficiency. It 

does not provide information that 

would allow competitors to infer 

market share, production costs, or 

pricing structures and thus gain a 

competitive advantage. The EPA 

applied the same rationale in the 

2010 proposed and 2011 final 

CBI rules (75 FR 39113 and 76 

FR 30803 - 30806), in support of 

a non-CBI determination for 

reporting of the following same 

data element currently required to 

be reported if a different equation 

(Equation Y-1a) is used: annual 

volume of flare gas combusted 

(scf/year) under 40 CFR 

98.256(e)(6).

40 CFR 

98.256(e)(11)(

ii) 

Annual 

average 

molecular 

weight of 

flare gas 

combusted 

(in mmBtu 

per MMscf) 

(only when 

Not CBI This data element does not reveal 

(nor could be used to calculate) 

details regarding product 

characteristics, actual production 

data, or operating efficiency. It 

does not provide information that 

would allow competitors to infer 

market share, production costs, or 

pricing structures and thus gain a 

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Subpart Citation 

Data 

Element 

Confidentiality 

Determination 

Proposed Rationale for 

Confidentiality Determination 

using 

Equation Y3). 

competitive advantage. The EPA 

applied the same rationale in the 

2010 proposed and 2011 final 

CBI rules (75 FR 39113 76 FR 

30803 - 30806), in support of a 

non-CBI determination for 

reporting of the following same 

data element currently required to 

be reported if a different equation 

(Equation Y-1a) is used: annual 

average molecular weight of the 

flare gas (kg/kg-mole) under 40 

CFR 98.256(e)(6).

40 CFR 

98.256(e)(11)(

iii) 

Annual 

average 

carbon 

content of 

flare gas 

combusted 

(expressed as 

a decimal 

fraction)(only 

when using 

Equation Y3). 

Not CBI This data element does not reveal 

(nor could be used to calculate) 

details regarding product 

characteristics, actual production 

data, or operating efficiency. It 

does not provide information that 

would allow competitors to infer 

market share, production costs, or 

pricing structures and thus gain a 

competitive advantage. The EPA 

applied the same rationale in the 

2010 proposed and 2011 final 

CBI rules (75 FR 39113 76 FR 

30803 - 30806), in support of a 

non-CBI determination for 

reporting of the following same 

data element currently required to 

be reported if a different equation 

(Equation Y-1a) is used: annual 

average carbon content of the 

flare gas (kg carbon/kg flare gas) 

under 40 CFR 98.256(e)(6).

AA - Pulp 

and Paper 

40 CFR 

98.276(l)(2) 

For each pulp 

mill lime 

kiln: Percent 

of annual heat 

input, 

individually 

for each fossil 

fuel type. 

Non-CBI Release of this data would not 

result in competitive harm 

because lime kiln fossil fuel use 

as a fraction of design heat input 

was reported to the EPA as part of 

a 2011 ICR survey, and facilities 

reporting via the survey made no 

CBI claims regarding fuel type 

and percent of design heat input. 

“Unit/Process ‘Static’ Characteristics that Are Not Inputs to Emission Equations” Data Category 

AA - Pulp 

and Paper 

40 CFR 

98.276(m)(2) 

For each 

chemical 

ND1 In the final CBI rulemaking (76 

FR 30799, May 26, 2011), we 
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Subpart Citation 

Data 

Element 

Confidentiality 

Determination 

Proposed Rationale for 

Confidentiality Determination 

recovery 

furnace and 

chemical 

recovery 

combustion 

unit for which 

you are not 

using 

Equation C2c to 

calculate CO2

emissions: 

Ratio of the 

unit’s 

maximum 

rated heat 

input capacity 

to its design 

rated steam 

output 

capacity 

(mmBtu/lb 

steam), 

individually 

for each fossil 

fuel type and 

for spent 

liquor solids. 

determined that the best approach 

for determining confidentiality of 

production capacity is not to make 

a single CBI determination 

applicable to all facilities within a 

given source category, due to 

differences between facilities. For 

all reported data elements related 

to production capacity, the EPA 

will make case-by-case 

determinations per reporter, in 

accordance with the provisions in 

40 CFR part 2, subpart B for 

facilities that claim these data 

elements as CBI. 

1

 ND = No determination was made. 

The EPA is requesting comment on two aspects of these confidentiality determinations. 

First, the EPA seeks comment on the proposed data category assignment for each of these data 

elements in Tables 5 and 6. If you believe that the EPA has improperly assigned any proposed 

new data elements to one of the data categories, please provide specific comments identifying 

which proposed new data elements may be mis-assigned along with a detailed explanation of 

why you believe them to be incorrectly assigned and in which data category you believe they 

best belong. 

Second, for those data elements assigned to the two direct emitter data categories without 

categorical confidentiality determinations, the EPA seeks comment on the individual 

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confidentiality determinations we are proposing for these data elements. If you comment on this 

issue, please provide specific comment along with detailed rationale and supporting information 

on whether such data element does or does not qualify as CBI. 

V. Impacts of the Proposed Rule 

This section examines the cost impacts of the proposed rulemaking. A detailed discussion 

of the impacts may be found in the memorandum, ”“Impacts Analysis of the Proposed 2015 

Inputs Proposal,” available in EPA docket ID No. EPA–HQ–OAR–2010-0929. 

A. How were the costs of this proposed rule estimated?

1. Proposed Inputs Verification Tool.

The data elements required to be used for calculating the annual GHG emissions values 

and the cost associated with collecting these data, have not changed from the estimate made 

during the original rulemaking process. The time associated with entry of these “inputs to 

equations” data elements into e-GGRT (including into the new inputs verification tool) is 

expected to be equivalent to the time originally anticipated for data entry. Prior to the inputs 

verification tool, as currently required, reporters must use their own calculation tool (e.g., 

calculator, calculation software) to calculate the annual GHG emissions values, using the same 

sets of equations and entering the same data elements that they would enter into the tool. 

The EPA does recognize however that there may be some time associated with learning 

the new procedures for the inputs verification tool and we have estimated a cost of 

approximately $340,000 for the first year for all affected facilities. 66 per facility, or $379,000 

for the first year for all affected facilities. During their first session using the proposed inputs 

verification tool, reporters would need to spend approximately 1 hour becoming familiar with 

how the tool operates within e-GGRT. The proposed new requirement to use the inputs 

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verification tool would not result in any change in the respondent activity of entering these data 

into e-GGRT. Once the reporter has become familiar with the tool, EPA does not anticipate any 

additional burden. The cost includes technical, clerical, and managerial labor hours. For further 

information about this cost estimate, refer to the memorandum “Assessment of Cost Impacts of 

2015 Inputs Proposal – Revisions to Reporting, Recordkeeping, and Verification Requirements 

under the Greenhouse Gas Reporting Program” and the supporting statement for this proposed 

information collection request, “Supporting Statement, Environmental Protection Agency: 

Revisions to Reporting and Recordkeeping Requirements, and Proposed Confidentiality 

Determinations under the Greenhouse Gas Reporting Program, OMB control number 2060-

[INSERT NEW NUMBER], ICR number 2483.01,” both available in docket EPA–HQ–OAR–

2010-0929.

2. Proposed New Data Elements.

We are proposing to add 26 new data elements that were not previously required to be 

reported under Part 98 (see Section II.D of this preamble for further discussion of this proposed 

amendment).), to be reported by facilities in certain subparts that are required to use the proposed 

inputs verification tool. Of these 26 data elements, nine data elements are related to annual 

production or raw material usage, which are collected by a facility as a routine part of conducting 

business. For these data elements, we are not proposing that reporters comply with specific data 

collection or monitoring requirements beyond the methods commonly used for accounting 

purposes. The other 17 data elements proposed to be reported are calculated values using data 

currently required to be collected to perform emissions calculations. For all of these additional 

data elements, the EPA has estimated a nominal additional cost to report the data element and 

fulfill the recordkeeping requirements. The total costs associated with reporting and 

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recordkeeping for the 26 data elements in 10 subparts is $80,000. These costs represent the cost 

for all affected facilities in the first year.

B. Additional Impacts of the Proposed Amendments

The proposed confidentiality determinations for the new data elements would not affect 

whether and how data are reported and, therefore, would not impose any additional burden on 

sources. 

VI. Statutory and Executive Order Reviews 

A. Executive Order 12866: Regulatory Planning and Review and Executive Order 13563: 

Improving Regulation and Regulatory Review

Under Executive Order 12866 (58 FR 51735, October 4, 1993), this action is a 

“significant regulatory action” because this action raises novel legal or policy issues arising out 

of legal mandates, the President’s priorities, or principles set forth in the executive order. 

Accordingly, the EPA submitted this action to the Office of Management and Budget (OMB) for 

review under Executive Orders 12866 and 13563 (76 FR 3821, January 21, 2011) and any 

changes made in response to OMB recommendations have been documented in the docket for 

this action. 

B. Paperwork Reduction Act

This action proposes to amend reporting and recordkeeping requirements and verification 

procedures for the GHGRP. In addition, the EPA is proposing confidentiality determinations for 

the proposed new data elements in this action. The proposed amendments to the reporting 

requirements in the source category-specific subparts are not anticipated to result in significant 

burden for reporters. The new data elements required to be reported are expected to be readily 

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available for affected facilities, or easily calculated using data already required to be collected 

(e.g., a monthly value is currently reported and an annual value is proposed to be reported). 

Impacts associated with the proposed changes to the reporting requirements in each 

subpart are detailed in the memorandum “Impacts Analysis of the Proposed 2015 Inputs 

Proposal” (see Docket ID No. EPA-HQ-OAR-2010-0929). The Office of Management and 

Budget (OMB) has previously approved the information collection requirements for 40 CFR part 

98 under the provisions of the Paperwork Reduction Act, 44 U.S.C. 3501 et seq and has assigned 

OMB control number 2060-0629, ICR 2300.10. OMB has approved the information collection 

requirements for this rulemaking and has assigned OMB control number 2060-new, ICR 

2483.01. The OMB control numbers for the EPA’s regulations in 40 CFR are listed in 40 CFR 

part 9. 

C. Regulatory Flexibility Act (RFA)

The RFA generally requires an agency to prepare a regulatory flexibility analysis of any 

rule subject to notice and comment rulemaking requirements under the Administrative Procedure 

Act or any other statute unless the agency certifies that the rule will not have a significant 

economic impact on a substantial number of small entities. Small entities include small 

businesses, small organizations, and small governmental jurisdictions. 

For purposes of assessing the impacts of the proposed amendments on small entities, 

“small entity” is defined as: (1) A small business as defined by the Small Business 

Administration’s regulations at 13 CFR 121.201; (2) a small governmental jurisdiction that is a 

government of a city, county, town, school district or special district with a population of less 

than 50,000; or (3) a small organization that is any not-for-profit enterprise which is 

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independently owned and operated and is not dominant in its field. This definition of small entity 

is consistent with the definition of small entity used for Part 98. 

After considering the economic impacts of today’s proposed amendments on small 

entities, I certify that this action will not have a significant economic impact on a substantial 

number of small entities. The small entities subject to Part 98 include small businesses across all 

sectors of the economy encompassed by Part 98, small governmental jurisdictions, and small 

non-profits. The impacts of these proposed amendments are expected to be roughly a first-year 

cost of $6066 per facility for learning new procedures for the verification tool and an annual cost 

of $100 per facility for the recordkeeping and reporting of 26 new data elements. 

The EPA continues to be interested in the potential impacts of the proposed rule 

amendments on small entities and welcomes comments on issues related to such impacts. 

D. Unfunded Mandates Reform Act (UMRA)

The proposed amendments and confidentiality determinations do not contain a federal 

mandate that may result in expenditures of $100 million or more for State, local, and tribal 

governments, in the aggregate, or the private sector in any one year. Thus, the proposed 

amendments and confidentiality determinations are not subject to the requirements of sections 

202 or 205 of UMRA. 

This rule is also not subject to the requirements of section 203 of UMRA because it 

contains no regulatory requirements that might significantly or uniquely affect small 

governments. This action proposes to amend reporting and recordkeeping requirements and 

verification procedures for the GHGRP. In addition, the EPA is proposing confidentiality 

determinations for the proposed new data elements in this action. Therefore, this action is not 

subject to the requirements of section 203 of the UMRA. 

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E. Executive Order 13132: Federalism

The action does not have federalism implications. It will not have substantial direct 

effects on the states, on the relationship between the national government and the states, or on 

the distribution of power and responsibilities among the various levels of government, as 

specified in Executive Order 13132. The proposed amendments and confidentiality 

determinations apply to facilities that directly emit greenhouses gases and fuel and chemicals 

suppliers. These proposed changes do not apply to governmental entities unless the government 

entity owns a facility that directly emits GHGs above threshold levels (such as a large stationary 

combustion device), so relatively few government facilities would be affected. Moreover, for 

government facilities that are subject to the rule, the proposed revisions will not have a 

significant cost impact. This proposed action also does not limit the power of states or localities 

to collect GHG data and/or regulate GHG emissions. Thus, Executive Order 13132 does not 

apply to this rule. 

In the spirit of Executive Order 13132, and consistent with EPA policy to promote 

communications between the EPA and state and local governments, the EPA specifically solicits 

comments on this proposed action from state and local officials. 

F. Executive Order 13175: Consultation and Coordination with Indian Tribal Governments.

This proposed action does not have tribal implications, as specified in Executive Order 

13175 (65 FR 67249, November 9, 2000). The proposed amendments and confidentiality 

determinations apply directly to facilities that directly emit greenhouses gases or that are 

suppliers of GHGs. They would not have tribal implications unless the tribal entity owns a 

facility that directly emits GHGs above threshold levels (such as a landfill or large combustion 

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device). Relatively few tribal facilities would be affected. Thus, Executive Order 13175 does not 

apply to this action. 

G. Executive Order 13045: Protection of Children from Environmental Health Risks and Safety 

Risks

The EPA interprets Executive Order 13045 (62 FR 19885, April 23, 1997) as applying 

only to those regulatory actions that concern health or safety risks, such that the analysis required 

under section 5-501 of the Executive Order has the potential to influence the regulation. This 

proposed action is not subject to Executive Order 13045 because it does not establish an 

environmental standard intended to mitigate health or safety risks. 

H. Executive Order 13211: Actions that Significantly Affect Energy Supply, Distribution, or Use

This proposed action is not a “significant energy action” as defined in Executive Order 

13211 (66 FR 28355, May 22, 2001), because it is not likely to have a significant adverse effect 

on the supply, distribution, or use of energy. Part 98 relates to monitoring, reporting, and 

recordkeeping and does not impact energy supply, distribution, or use. This action proposes to

amend reporting and recordkeeping requirements and verification procedures for the GHGRP. In 

addition, the EPA is proposing confidentiality determinations for the proposed new data 

elements in this action. These proposed amendments and confidentiality determinations do not 

make any changes to the existing monitoring, recordkeeping, or reporting requirements under 

Part 98 that affect the supply, distribution, or use of energy. 

I. National Technology Transfer and Advancement Act

Section 12(d) of the National Technology Transfer and Advancement Act of 1995 

(NTTAA), Public Law No. 104-113, 12(d) (15 U.S.C. 272 note) directs the EPA to use voluntary 

consensus standards in its regulatory activities unless to do so would be inconsistent with 

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applicable law or otherwise impractical. Voluntary consensus standards are technical standards 

(e.g., materials specifications, test methods, sampling procedures, and business practices) that are 

developed or adopted by voluntary consensus standards bodies. NTTAA directs the EPA to 

provide Congress, through OMB, explanations when the Agency decides not to use available and 

applicable voluntary consensus standards. 

This proposed rulemaking does not involve the use of any new technical standards. 

Therefore, the EPA is not considering the use of any voluntary consensus standards. 

J. Executive Order 12898: Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations

Executive Order 12898 (59 FR 7629, February 16, 1994) establishes federal executive 

policy on environmental justice. Its main provision directs federal agencies, to the greatest extent 

practicable and permitted by law, to make environmental justice part of their mission by 

identifying and addressing, as appropriate, disproportionately high and adverse human health or 

environmental effects of their programs, policies, and activities on minority populations and lowincome populations in the United States. 

The EPA has determined that these proposed rule amendments will not have 

disproportionately high and adverse human health or environmental effects on minority or lowincome populations because the amendments do not affect the level of protection provided to 

human health or the environment. This is because the proposed amendments address information 

collection and reporting and verification procedures. 

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Proposed Rule Amendments and Confidentiality Determinations 

for Certain Data Elements Required under the 

Mandatory Greenhouse Gas Reporting Rule 

Page 62 of 103 

List of Subjects 40 CFR Part 98 

Environmental protection, Administrative practice and procedure, Greenhouse gases, 

Reporting and recordkeeping requirements. 

Dated: 

 

Bob Perciasepe, 

Acting Gina McCarthy, 

Administrator. 

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For the reasons stated in the preamble, title 40, chapter I, of the Code of Federal 

Regulations is proposed to be amended as follows: 

PART 98—[AMENDED] 

1.The authority citation for part 98 continues to read as follows: 

Authority: 42 U.S.C. 7401, et seq.

Subpart A—[AMENDED] 

2.Section 98.3 is amended by revising paragraphs (c)(4)(vii), (d)(3)(v), (g) introductory 

text, and (g)(2)(i) to read as follows: 

§ 98.3 What are the general monitoring, reporting, recordkeeping and verification 

requirements of this part. 

* * * * * 

(c) * * * 

(4) * * * 

(vii) The owner or operator of a facility is not required to report the data elements 

specified in Table A-6 to this subpart for calendar years 2010 through 2011 until March 31, 

2013. The owner or operator of a facility is not required to report the data elements specified in 

Table A-7 to this subpart for calendar years 2010 through 2013 until March 31, 2015. Data 

elements specified in Table A-7 to this subpart for calendar years 2010 through 2013 must be 

submitted as part of the annual report for reporting year 2014. 

* * * * * 

(d) * * * 

(3) * * * 

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(v) For each stationary fuel combustion unitsource that is connected to a device that has 

been granted access bymeets the Public Utilities Commission to deliver power to the local or 

regional power grid (e.g., electricity generators excluding generators connected to combustion 

units subject to subpart Dcriteria specified in § 98.36(f) of this part), and for which the combined 

nameplate capacity for all such devices at the facility is greater than or equal to 1 megawatt 

electric, report any facility operating data or process information used for the GHG emission 

calculations. 

* * * * * 

(g) Recordkeeping. An owner or operator that is required to report GHGs under this part 

must keep records as specified in this paragraph. Except as otherwise provided in this paragraph, 

retain all required records for at least 3 years from the date of submission of the annual GHG 

report for the reporting year in which the record was generated. The records shall be kept in an 

electronic or hard-copy format (as appropriate) and recorded in a form that is suitable for 

expeditious inspection and review. If a reporter is required under § 98.5(b) to use software 

specified by the Administrator to enter data to calculate the reported GHGs, all records required 

under Part 98 must be retained by the reporter for 5 years from the date of submission of the 

annual GHG report for the reporting year in which the record was generated. Upon request by 

the Administrator, the records required under this section must be made available to EPA. 

Records may be retained off site if the records are readily available for expeditious inspection 

and review. For records that are electronically generated or maintained, the equipment or 

software necessary to read the records shall be made available, or, if requested by EPA, 

electronic records shall be converted to paper documents. You must retain the following records, 

in addition to those records prescribed in each applicable subpart of this part: 

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* * * * * 

(2) * * * 

(i) The GHG emissions calculations and methods used. For data required by section§

98.5(b) to be entered into the software specified by the Administrator, maintain the entered data 

in the format generated by the software specified by the Administrator. 

* * * * * 

3.Section 98.5 is revised to read as follows: 

§ 98.5 How is the report submitted? 

(a) Each GHG report and certificate of representation for a facility or supplier must be 

submitted electronically in accordance with the requirements of § 98.4 and in a format specified 

by the Administrator. 

(b) For reporting year 2014 and thereafter, you must enter into verification software 

specified by the Administrator all of the data used as inputs to calculate the calculation methods 

specified in Table A-8 to Part 98, excluding data required to be reported GHGs forin the 

following subparts: C, E, F, G, H, K, L, N, O, P, Q, R, S, U, V, X, Y, Z, AA, BB, CC, EE, GG, 

II, TTreporting section of each subpart listed in Table A-8 to Part 98. 

4.Table A-7 to Subpart A of Part 98 is revised to read as follows: 

Table A–7 to Subpart A of Part 98—Data Elements That Are Inputs to Emission Equations 

and for Which the Reporting Deadline Is March 31, 2015 

Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which reporting date is 

March 31, 2015 (“All” means all data elements in 

the cited paragraph are not required to be 

reported until March 31, 2015) 

A 98.3(d)(3)(v) All. 

C 98.36(b)(9)(iii) Only estimate of the heat input.1

C 98.36(c)(2)(ix) Only estimate of the heat input from each type of fuel 

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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which reporting date is 

March 31, 2015 (“All” means all data elements in 

the cited paragraph are not required to be 

reported until March 31, 2015) 

listed in Table C–2.1

C 98.36(e)(2)(i) All.1

C 98.36(e)(2)(ii)(A) All.1

C 98.36(e)(2)(ii)(C) Only HHV value for each calendar month in which 

HHV determination is required.1

C 98.36(e)(2)(ii)(D) All.1

C 98.36(e)(2)(iv)(A) All.1

C 98.36(e)(2)(iv)(C) All.1

C 98.36(e)(2)(iv)(F) All.1

C 98.36(e)(2)(ix)(D) All.1

C 98.36(e)(2)(ix)(E) All.1

C 98.36(e)(2)(ix)(F) All.1

E 98.56(g) All. 

E 98.56(h) All. 

E 98.56(j)(4) All. 

E 98.56(j)(5) All. 

E 98.56(j)(6) All. 

E 98.56(l) All. 

H 98.86(b)(11) All. 

H 98.86(b)(13) Name of raw kiln feed or raw material.

L 98.126(b)(10) All. 

L 98.126(b)(11) All. 

L 98.126(b)(12) All. 

N 98.146(b)(6) All.

O 98.156(d)(2) All. 

O 98.156(d)(3) All. 

O 98.156(d)(4) All. 

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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which reporting date is 

March 31, 2015 (“All” means all data elements in 

the cited paragraph are not required to be 

reported until March 31, 2015) 

Q 98.176(b) If you determined CO2 emissions using the sitespecific emission factor method in §98.173(b)(2) 

based on the total quantity of raw material feed 

(metric tons of CO2 per metric ton of raw material 

feed), only annual quantity taconite pellets, coke, iron, 

and raw steel.

Q 98.176(f)(1) All. 

U 98.216(e)(2) All.

V 98.226(i) All. 

V 98.226(j) All. 

V 98.226(m)(4) All. 

V 98.226(m)(5) All. 

V 98.226(m)(6) All. 

V 98.226(p) All. 

W 98.236(c)(1)(i) All. 

W 98.236(c)(1)(ii) All. 

W 98.236(c)(1)(iii) All. 

W 98.236(c)(2)(i) All. 

W 98.236(c)(3)(i) All. 

W 98.236(c)(3)(ii) All. 

W 98.236(c)(3)(iii) All. 

W 98.236(c)(4)(i)(A) All. 

W 98.236(c)(4)(i)(B) All. 

W 98.236(c)(4)(i)(C) All. 

W 98.236(c)(4)(i)(D) All. 

W 98.236(c)(4)(i)(E) All. 

W 98.236(c)(4)(i)(F) All. 

W 98.236(c)(4)(i)(G) All. 

W 98.236(c)(4)(i)(H) All. 

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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which reporting date is 

March 31, 2015 (“All” means all data elements in 

the cited paragraph are not required to be 

reported until March 31, 2015) 

W 98.236(c)(4)(ii)(A) All. 

W 98.236(c)(5)(iii) All. 

W 98.236(c)(5)(iv) All. 

W 98.236(c)(5)(v) All. 

W 98.236(c)(6)(i)(B) All. 

W 98.236(c)(6)(i)(D) All. 

W 98.236(c)(6)(i)(E) All. 

W 98.236(c)(6)(i)(F) All. 

W 98.236(c)(6)(ii)(A) All. 

W 98.236(c)(6)(ii)(B) All. 

W 98.236(c)(7)(i) All. 

W 98.236(c)(8)(i)(B) All. 

W 98.236(c)(8)(i)(C) All. 

W 98.236(c)(8)(i)(F) All. 

W 98.236(c)(8)(ii)(A) All. 

W 98.236(c)(8)(ii)(D) All. 

W 98.236(c)(8)(iii)(A) All. 

W 98.236(c)(8)(iii)(D) All. 

W 98.236(c)(8)(iii)(E) All. 

W 98.236(c)(10)(ii) All. 

W 98.236(c)(10)(iii) All. 

W 98.236(c)(11)(ii) All. 

W 98.236(c)(12)(ii) All. 

W 98.236(c)(12)(iii) All. 

W 98.236(c)(12)(v) All. 

W 98.236(c)(13)(i)(B) All. 

W 98.236(c)(13)(i)(E) All. 

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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which reporting date is 

March 31, 2015 (“All” means all data elements in 

the cited paragraph are not required to be 

reported until March 31, 2015) 

W 98.236(c)(13)(i)(F) All. 

W 98.236(c)(13)(ii)(A) All. 

W 98.236(c)(13)(ii)(B) All. 

W 98.236(c)(13)(iii)(A) All. 

W 98.236(c)(13)(iii)(B) All. 

W 98.236(c)(13)(v)(A) All. 

W 98.236(c)(14)(i)(B) All. 

W 98.236(c)(14)(ii)(A) All. 

W 98.236(c)(14)(ii)(B) All. 

W 98.236(c)(14)(iii)(A) All. 

W 98.236(c)(14)(iii)(B) All. 

W 98.236(c)(14)(v)(A) All. 

W 98.236(c)(15)(i)(A) All. 

W 98.236(c)(15)(i)(B) All. 

W 98.236(c)(15)(ii)(A) All. 

W 98.236(c)(15)(ii)(B) All. 

W 98.236(c)(16)(i) All. 

W 98.236(c)(16)(ii) All. 

W 98.236(c)(16)(iii) All. 

W 98.236(c)(16)(iv) All. 

W 98.236(c)(16)(v) All. 

W 98.236(c)(16)(vi) All. 

W 98.236(c)(16)(vii) All. 

W 98.236(c)(16)(viii) All. 

W 98.236(c)(16)(ix) All. 

W 98.236(c)(16)(x) All. 

W 98.236(c)(16)(xi) All. 

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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which reporting date is 

March 31, 2015 (“All” means all data elements in 

the cited paragraph are not required to be 

reported until March 31, 2015) 

W 98.236(c)(16)(xii) All. 

W 98.236(c)(16)(xiii) All. 

W 98.236(c)(16)(xiv) All. 

W 98.236(c)(17)(ii) All. 

W 98.236(c)(17)(iii) All. 

W 98.236(c)(17)(iv) All. 

W 98.236(c)(18)(i) All. 

W 98.236(c)(18)(ii) All. 

W 98.236(c)(19)(iv) All. 

W 98.236(c)(19)(vii) All. 

Y 98.256(h)(5) Only value of the correction. 

Y 98.256(k)(4) Only mole fraction of methane in coking gas. 

Y 98.256(n)(3) All (if used in Equation Y–21 to calculate emissions 

from equipment leaks). 

Y 98.256(o)(4)(vi) Only tank-specific methane composition data and gas 

generation rate data. 

AA 98.276(e) All. 

CC 98.296(b)(10)(i) All. 

CC 98.296(b)(10)(ii) All. 

CC 98.296(b)(10)(iii) All. 

CC 98.296(b)(10)(iv) All. 

CC 98.296(b)(10)(v) All. 

CC 98.296(b)(10)(vi) All. 

II 98.356(d)(2) All (if conducting weekly sampling). 

II 98.356(d)(3) All (if conducting weekly sampling). 

II 98.356(d)(4) Only weekly average temperature (if conducting 

weekly sampling). 

II 98.356(d)(5) Only weekly average moisture content (if conducting 

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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which reporting date is 

March 31, 2015 (“All” means all data elements in 

the cited paragraph are not required to be 

reported until March 31, 2015) 

weekly sampling). 

II 98.356(d)(6) Only weekly average pressure (if conducting weekly 

sampling). 1

 Required to be reported only by stationary fuel combustion sources (e.g., individual units, 

aggregations of units, common pipes, or common stacks) subject to subpart C of part 98 that 

meet both of the following criteria: (1) the stationary fuel combustion source contains at least 

one combustion unit is connected to a devicefuel-fired electric generator that has been granted 

access by the Public Utilities Commission to deliver power to the local or regional electric power 

grid (e.g., electricity generators excluding generators that are connected to combustion units 

subject to subpart D of this part); and (2) the combinedstationary fuel combustion source is 

located at a facility for which the sum of the nameplate capacity (capacities for all such devices

at the facility) electric generators is greater than or equal to 1 megawatt electric. output. 

5.Table A-8 to Subpart A of Part 98 is added to read as follows: 

Table A–8 to Subpart A of Part 98—Calculation Methods For Which Inputs To the 

Calculation Methods Must be Entered Into Verification Software Specified By the 

Administrator. 

Subpart Calculation Method (Equation Number in 40 CFR Part 98 or Description 

of Method) 

Subpart C 1 C-1, C-1a, C-1b, C-2b, C-2c, C-3, C-4, C-5, C-8, C-8a, C-8b, C-10, C-13, the 

calculation method specified in § 98.3(d)(3)(iv) of subpart A of part 98 

Subpart E E-1, E-2, E-3a, E-3b, E-3c, E-3d 

Subpart F F-2 (including the method for calculating the anode effect minutes per cell-day 

(AEM) and slope coefficients (SCF4), F-3 (including the method for 

calculating the overvoltage factor (EFCF4)), F-5, F-6, F-7, F-8 

Subpart G G-1, G-2, G-3 

Subpart H H-2 (including the method in § 98.84(d) of subpart H of part 98 for calculating 

the quantity of clinker produced), H-3, H-4, H-5 

Subpart K K-1, K-3 

Subpart L L-1, L-2, L-3, L-4, L-6, L-7, L-8, L-17, L-18, L-20, L-21, L-22, L-23, L-25, L26, L-27, L-31, L-34 

Subpart N N-1 

Subpart O O-3, O-4, O-8, O-9 (including the calculation method specified in § 

98.154(l)(2) of subpart O of part 98) 

Subpart P P-1, P-2, P-3 

Subpart Q Q-1, Q-2, Q-3, Q-4, Q-5, Q-6, Q-7, the calculation methods specified in § 

98.173(b)(2)(iii), (b)(2)(iv), and (c) of subpart Q of part 98 

Subpart R R-1 

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Subpart Calculation Method (Equation Number in 40 CFR Part 98 or Description 

of Method) 

Subpart S S-1, S-2, S-3, S-4 (including the calculation method specified in § 98.194(a)

Subpart U U-1, U-2 

Subpart V V-2, V-3a, V-3b, V-3c, V-3d 

Subpart X X-1, X-2, X-3, C-8 

Subpart Y Y-1a, Y-1b, Y-3, Y-4, Y-6, Y-8, Y-11, Y-12 (including the method for 

correcting the calculation, if applicable, as specified in § 98.253(f)(5)), Y-13, 

Y-14, Y-15, Y-16a, Y-16b, Y-17, Y-18, Y-19, Y-20, Y-22, Y-23, the methods 

for calculating emissions from coke burn-off specified in § 98.253(c)(4) and 

(5) (alternatives to using Equations Y-9 and Y-10 of Part 98), the calculation 

method specified in § 98.253(n) of subpart Y of part 98 

Subpart Z Z-1a, Z-1b 

Subpart AA C-1, C-1a, C-1b, C-2a, C-3, C-4, C-5, C-8, C-8a, C-8b, C-9a, AA-1, AA-2, 

AA-3 

Subpart BB BB-1, BB-2 

Subpart CC CC-1, CC-2 

Subpart EE EE-2 

Subpart GG GG-1 

Subpart TT TT-2, TT-3 1

 Does not apply to any stationary fuel combustion sources (e.g., individual units, aggregations of 

units, common pipes, or common stacks) meeting both of the following criteria: (1) the 

stationary fuel combustion source contains at least one combustion unit connected to a fuel-fired 

electric generator electric (excluding generators that are connected to combustion units subject to 

subpart D of this part); and (2) the stationary fuel combustion source is located at a facility for 

which the sum of the nameplate capacities for all such electric generators is greater than or equal 

to 1 megawatt electric output. 

Subpart C—[AMENDED] 

5.6. Section 98.36 is amended by: 

a. Revising paragraph (a). 

a. b. Revising paragraph (b)(9)(iii).

b. Adding) and adding paragraph (b)(9)(iv). 

c. c. Revising paragraph (c)(2)(ix).

d. Adding) and adding paragraph (c)(2)(x). 

e. d. Revising paragraphs (e)(2)(i), (e)(2)(ii)(A), 

(e)(2)(ii)(C), and (e)(2)(ii)(D).

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f. Adding); and adding paragraph (e)(2)(ii)(E). 

g. e. Revising paragraphs (e)(2)(iv)(A), (e)(2)(iv)(C), 

(e)(2)(iv)(F), and (e)(2)(ix)(D) through (F).

h. Adding); and adding paragraph (f). 

The revisions and additions read as follows: 

§ 98.36 Data reporting requirements. 

* * * * * 

(a) In addition to the facility-level information required under §98.3, the annual GHG 

emissions report shall contain the unit-level or process-level data specified in paragraphs (b) 

through (f) of this section, as applicable, for each stationary fuel combustion source (e.g., 

individual unit, aggregation of units, common pipe, or common stack). 

(b) * * * 

(9) * * * 

(iii) The annual CH4 and N2O emissions for each type of fuel listed in Table C–2 of this 

subpart that was combusted in the unit during the report year, expressed in metric tons of each 

gas and in metric tons of CO2e. 

(iv) For each combustion unit that is connected to a device that has been granted access 

by the Public Utilities Commission to deliver power to the local or regional power grid (e.g., 

electricity generators excluding generators connected to combustion units subject to subpart D of 

this part), and for which the combined nameplate capacity for all such devices at the facility is 

greater than or equal to 1 megawatt electric, you must also(iv) For each stationary fuel 

combustion source that meets the criteria specified in paragraph (f) of this section, report an 

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estimate of the heat input from each type of fuel listed in Table C–2 of this subpart that was 

combusted in the unit during the report year. 

* * * * * 

(c) * * * 

(2) * * * 

(ix) For each type of fuel listed in Table C–2 of this subpart that was combusted during 

the report year in the units sharing the common stack or duct during the report year, the annual 

CH4 and N2O mass emissions from the units sharing the common stack or duct, expressed in 

metric tons of each gas and in metric tons of CO2 e. 

(x) For each combustion unit that is connected to a device that has been granted access 

by the Public Utilities Commission to deliver power to the local or regional power grid (e.g., 

electricity generators excluding generators connected to combustion units subject to subpart D of 

this part), and for which the combined nameplate capacity for all such devices at the facility is 

greater than or equal to 1 megawatt electric, you must also report(x) For each stationary fuel 

combustion source that meets the criteria specified in paragraph (f) of this section, an estimate of 

the heat input from each type of fuel listed in Table C–2 of this subpart that was combusted 

during the report year in the units sharing the common stack or duct during the report year. 

* * * * * 

(e) * * * 

(2) * * * 

(i) For the Tier 1 Calculation Methodology, for each combustion unit that is connected to 

a device that has been granted access by the Public Utilities Commission to deliver power to the 

local or regional power grid (e.g., electricity generators excluding generators connected to 

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combustion units subject to subpart D of this part), and for which the combined nameplate 

capacity for all such devices at the facility is greater than or equal to 1 megawatt 

electricstationary fuel combustion source that meets the criteria specified in paragraph (f) of this 

section, report the total quantity of each type of fuel combusted in the unit or group of 

aggregated units (as applicable) during the reporting year, in short tons for solid fuels, gallons for 

liquid fuels and standard cubic feet for gaseous fuels, or, if applicable, therms or mmBtu for 

natural gas. 

(ii) * * * 

(A) For each combustion unit that is connected to a device that has been granted access 

by the Public Utilities Commission to deliver power to the local or regional power grid (e.g., 

electricity generators excluding generators connected to combustion units subject to subpart D of 

this part), and for which the combined nameplate capacity for all such devices at the facility is 

greater than or equal to 1 megawatt electric, report(A) For each stationary fuel combustion 

source that meets the criteria specified in paragraph (f) of this section, the total quantity of each 

type of fuel combusted in the unit or group of aggregated units (as applicable) during each month 

of the reporting year. Express the quantity of each fuel combusted during the measurement 

period in short tons for solid fuels, gallons for liquid fuels, and scf for gaseous fuels. 

* * * * * 

(C) For each combustion unit that is connected to a device that has been granted access 

by the Public Utilities Commission to deliver power to the local or regional power grid (e.g., 

electricity generators excluding generators connected to combustion units subject to subpart D of 

this part), and for which the combined nameplate capacity for all such devices at the facility is 

greater than or equal to 1 megawatt electric, report(C) For each stationary fuel combustion 

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source that meets the criteria specified in paragraph (f) of this section, the high heat values used 

in the CO2 emissions calculations for each type of fuel combusted during the reporting year, in 

mmBtu per short ton for solid fuels, mmBtu per gallon for liquid fuels, and mmBtu per scf for 

gaseous fuels. Report a HHV value for each calendar month in which HHV determination is 

required. If multiple values are obtained in a given month, report the arithmetic average value for 

the month. Indicate whether each reported HHV is a measured value or a substitute data value. 

(D) For each combustion unit that is connected to a device that has been granted access 

by the Public Utilities Commission to deliver power to the local or regional power grid (e.g., 

electricity generators excluding generators connected to combustion units subject to subpart D of 

this part), and for which the combined nameplate capacity for all such devices at the facility is 

greater than or equal to 1 megawatt electric(D) For each stationary fuel combustion source that 

meets the criteria specified in paragraph (f) of this section, if Equation C–2c of this subpart is 

used to calculate CO2 mass emissions, report the total quantity (i.e., pounds) of steam produced 

from MSW or solid fuel combustion during each month of the reporting year, and the ratio of the 

maximum rate heat input capacity to the design rated steam output capacity of the unit, in 

mmBtu per lb of steam. 

(E) For each HHV used in the CO2 emissions calculations for each type of fuel 

combusted during the reporting year, indicate whether the HHV is a measured value or a 

substitute data value. 

* * * * * 

(iv) * * * 

(A) For each combustion unit that is connected to a device that has been granted access 

by the Public Utilities Commission to deliver power to the local or regional power grid (e.g., 

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electricity generators excluding generators connected to combustion units subject to subpart D of 

this part), and for which the combined nameplate capacity for all such devices at the facility is 

greater than or equal to 1 megawatt electric, report(A) For each stationary fuel combustion 

source that meets the criteria specified in paragraph (f) of this section, the quantity of each type 

of fuel combusted in the unit or group of units (as applicable) during each month of the reporting 

year, in short tons for solid fuels, gallons for liquid fuels, and scf for gaseous fuels. 

* * * * * 

(C) For each combustion unit that is connected to a device that has been granted access 

by the Public Utilities Commission to deliver power to the local or regional power grid (e.g., 

electricity generators excluding generators connected to combustion units subject to subpart D of 

this part), and for which the combined nameplate capacity for all such devices at the facility is 

greater than or equal to 1 megawatt electric, report(C) For each stationary fuel combustion 

source that meets the criteria specified in paragraph (f) of this section, the carbon content and, if 

applicable, gas molecular weight values used in the emission calculations (including both valid 

and substitute data values). For each calendar month of the reporting year in which carbon 

content and, if applicable, molecular weight determination is required, report a value of each 

parameter. If multiple values of a parameter are obtained in a given month, report the arithmetic 

average value for the month. Express carbon content as a decimal fraction for solid fuels, kg C 

per gallon for liquid fuels, and kg C per kg of fuel for gaseous fuels. Express the gas molecular 

weights in units of kg per kg-mole. 

* * * * * 

(F) For each combustion unit that is connected to a device that has been granted access by 

the Public Utilities Commission to deliver power to the local or regional power grid (e.g., 

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electricity generators excluding generators connected to combustion units subject to subpart D of 

this part), and for which the combined nameplate capacity for all such devices at the facility is 

greater than or equal to 1 megawatt electric, report(F) For each stationary fuel combustion source 

that meets the criteria specified in paragraph (f) of this section, the annual average HHV, when 

measured HHV data, rather than a default HHV from Table C–1 of this subpart, are used to 

calculate CH4 and N2O emissions for a Tier 3 unit, in accordance with §98.33(c)(1). 

* * * * * 

(ix) * * * 

(D) For each combustion unit that is connected to a device that has been granted access 

by the Public Utilities Commission to deliver power to the local or regional power grid (e.g., 

electricity generators excluding generators connected to combustion units subject to subpart D of 

this part), and for which the combined nameplate capacity for all such devices at the facility is 

greater than or equal to 1 megawatt electric, report(D) For each stationary fuel combustion 

source that meets the criteria specified in paragraph (f) of this section, the carbon-based F-factor 

used in Equation C–13 of this subpart, for each type of fossil fuel combusted, in scf CO2 per 

mmBtu. 

(E) For each combustion unit that is connected to a device that has been granted access 

by the Public Utilities Commission to deliver power to the local or regional power grid (e.g., 

electricity generators excluding generators connected to combustion units subject to subpart D of 

this part), and for which the combined nameplate capacity for all such devices at the facility is 

greater than or equal to 1 megawatt electric, report(E) For each stationary fuel combustion 

source that meets the criteria specified in paragraph (f) of this section, the annual average HHV 

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value used in Equation C–13 of this subpart, for each type of fossil fuel combusted, in Btu/lb, 

Btu/gal, or Btu/scf, as appropriate. 

(F) For each combustion unit that is connected to a device that has been granted access by 

the Public Utilities Commission to deliver power to the local or regional power grid (e.g., 

electricity generators excluding generators connected to combustion units subject to subpart D of 

this part), and for which the combined nameplate capacity for all such devices at the facility is 

greater than or equal to 1 megawatt electric, report(F) For each stationary fuel combustion source 

that meets the criteria specified in paragraph (f) of this section, the total quantity of each type of 

fossil fuel combusted during the reporting year, in lb, gallons, or scf, as appropriate. 

* * * * * 

(f) For stationary combustion sources using the Tier 1, Tier 2, Tier 3, or Tier 4 

Calculation Methodologies in §98.33(a) to quantify CO2e emissions, reportEach stationary fuel 

combustion source (e.g., individual unit, aggregation of units, common pipe, or common stack) 

subject to reporting under paragraph (b), (c), or (d)(2) of this section must indicate if both of the 

following two conditions are met: 

(1) Whether anyThe stationary combustion units are source 

contains at least one combustion unit connected to devicesa 

fuel-fired electric generator that havehas been granted access 

by the Public Utilities Commission to deliver power to the local 

or regional power grid.

(2) For all stationary combustion units that meet the criteria specified in paragraph (f)(1) 

of this section, indicate whether the combined nameplate capacity for all associated devices that 

are connected to the local or regionalelectric power grid (excluding generators that are connected 

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to combustion units that are subject to subpart D of this part) is greater than or equal to than 1 

megawatt.).

(2) The stationary fuel combustion source is located at a facility for which the sum of the 

nameplate capacities for all electric generators specified in paragraph (f)(1) of this section is 

greater than or equal to 1 megawatt electric output. 

Subpart E—[AMENDED] 

6.7. Section 98.56 is amended by: 

a. a. Revising the introductory text. 

b. b. Removing and reserving paragraphs (b), (c), (j)(1), and (j)(3). 

c. c. Adding paragraphs (m) and (n). 

The revisions and additions read as follows: 

§ 98.56 Data reporting requirements. 

In addition to the information required by §98.3(c), each annual report must contain the 

information specified in paragraphs (a) through (n) of this section at the facility level. 

* * * * * 

(m) Annual quantity of cyclohexane fed to all production lines combined (metric tons). 

(n) Annual percent N2O emission reduction for all production units combined. 

* * * * * 

Subpart F—[AMENDED] 

7.8. Section 98.66 is amended by: 

a. a. Removing and reserving paragraphs (a) and (c)(2). 

b. b. Revising paragraphparagraphs (c)(3), (e)(1), and (f)(1). 

c. c. Removing and reserving paragraph (g). 

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The revisions read as follows: 

§ 98.66 Data reporting requirements. 

* * * * * 

(c) * * * 

(2) [Reserved]

(3) The last date when the smelter-specific-slope coefficients (or overvoltage emission 

factors) were measured. 

* * * * * 

(e) * * * 

(1) Annual anode consumption if using the method in §98.63(g). 

* * * * * 

(f) * * * 

(1) Annual paste consumption if using the method in §98.63(g). 

* * * * * 

Subpart G—[AMENDED] 

8.9. Section 98.76 is amended by: 

a. a. Revising the introductory text. 

b. b. Removing and reserving paragraph (b)(2) and paragraphs (b)(7) through 

(11). 

c. c. Adding paragraphs (c) and (d). 

The revisions and additions read as follows: 

§ 98.76 Data reporting requirements. 

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In addition to the information required by §98.3(c), each annual report must contain the 

information specified in paragraphs (a) through (d) of this section, as applicable for each 

ammonia manufacturing process unit. 

* * * * * 

(c) Annual ammonia production (metric tons). 

(d) Annual methanol production (metric tons), if this quantity is not reported under 

subpart X of Part 98. 

Subpart H—[AMENDED] 

9.10. Section 98.86 is amended by: 

a. a. Removing and reserving paragraphs (b)(2), (b)(5), (b)(6), (b)(8), (b)(10), and 

(12). 

b. b. Revising paragraphs (b)(13) and (15). 

c. c. Adding paragraphs (b)(16) through (18). 

The revisions and additions read as follows: 

§ 98.86 Data reporting requirements. 

* * * * * 

(b) * * * 

(12) [Reserved]

(13) Name of raw kiln feed or raw material. 

* * * * * 

(15) Method used to determine the monthly clinker production from each kiln. 

(16) Annual clinker production (metric tons). 

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(17) Annual average clinker CO2 emission factor for the facility, averaged across all kilns 

(metric tons CO2/metric ton clinker produced). 

(18) Annual average CKD CO2 emission factor for the facility, averaged across all kilns 

(metric tons CO2/metric ton CKD produced). 

Subpart K—[AMENDED] 

10.11. Section 98.116 is amended by: 

a. a. Removing and reserving paragraphs (b), (e)(4), and (e)(5). 

b. b. Revising paragraph (e)(6). 

The revisions read as follows: 

§ 98.116 Data reporting requirements. 

* * * * * 

(e) * * * 

(5) [Reserved]

(6) List the method used for the determination of carbon content for each material 

included for the calculation of annual process CO2 emissions for each EAF (e.g., supplier 

provided information, analyses of representative samples you collected). 

* * * * * 

Subpart L—[AMENDED] 

11.12. Section 98.126 is amended by: 

a. a. Revising paragraph (b)(1). 

b. b. Removing and reserving paragraph (b)(2). 

c. c. Revising paragraphs (b)(6)), (b)(7), and (b)(8)(i) through (iv). 

d. d. Removing and reserving paragraphs (b)(8)(v) and (b)(9). 

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e. e. Revising paragraph (c)(1). 

f. f. Removing and reserving paragraph (c)(2). 

g. g. Revising paragraph (d). 

h. h. Removing and reserving paragraphs (f)(1), (g)(1), and (h)(2). 

The revisions read as follows: 

§ 98.126 Data reporting requirements. 

* * * * * 

(b) * * * 

(1) If you calculate the relative and absolute errors under § 98.123(b)(1), the absolute and 

relative errors calculated under paragraph § 98.123(b)(1). 

(2) [Reserved]

* * * * * 

(6) The chemical formula of each fluorine-containing reactant that is fed into the process

(metric tons)..

* * * * *

(7) The chemical formula of each fluorine-containing product produced by the process. 

(8) * * * 

(i) The chemical formula of each fluorine-containing product that is removed from the 

process and fed into the destruction device (metric tons)..

(ii) The chemical formula of each fluorine-containing by-product that is removed from 

the process and fed into the destruction device (metric tons)..

(iii) The chemical formula of each fluorine-containing reactant that is removed from the 

process and fed into the destruction device (metric tons)..

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(iv) The chemical formula of each fluorine-containing by-product that is removed from 

the process and recaptured (metric tons)..

(v) [Reserved]

(9) [Reserved]

* * * * * 

(c) * * * 

(1) The identity of the process activity used to estimate emissions (e.g., product produced 

or reactant consumed). 

(2) [Reserved]

* * * * * 

(d) Reporting for missing data. Where missing data have been estimated pursuant to §

98.125, you must report the: 

(1) The reason the data were missing, the length of time the data were missing, and the 

method used to estimate the missing data. 

(2) Estimates of the missing data for all data required to be reported in this section that 

are inputs to calculation methods specified in § 98.123. 

* * * * * 

Subpart N—[AMENDED] 

12.13. Section 98.146 is amended by revising paragraph (b)(2) and removing and 

reserving paragraphparagraphs (b)(4) and (b)(6) to read as follows: 

§ 98.146 Data reporting requirements. 

* * * * * 

(b) * * * 

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(2) Annual quantity of each carbonate-based raw material charged (tons) to all furnaces 

combined. 

* * * * * 

Subpart O—[AMENDED] 

13.14. Section 98.156 is amended by: 

a. a. Removing and reserving paragraphs (a)(2), (a)(7) through (10), (b)(1), and 

(b)(2). 

b. b. Revising paragraph (d) introductory paragraphtext. 

c. c. Removing and reserving paragraphs (d)(1), (d)(5), and (e)(1). 

The revisions read as follows: 

§ 98.156 Data reporting requirements. 

* * * * * 

(d) If the HFC–23 concentration measured pursuant to §98.154(l) is greater than that 

measured during the performance test that is the basis for the destruction efficiency (DE), the 

facility shall report the following: 

(1) [Reserved]

* * * * * 

Subpart P—[AMENDED] 

14.15. Section 98.166 is amended by: 

a. a. Revising the introductory paragraphtext. 

b. b. Removing and reserving paragraphs (b)(2), (b)(5), and (b)(6). 

c. c. Adding paragraphs (b)(7) and (e). 

The revisions and additions read as follows: 

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§ 98.166 Data reporting requirements. 

In addition to the information required by §98.3(c), each annual report must contain the 

information specified in paragraphs (a) or (b) of this section, as appropriate, and paragraphs (c) 

through (e) of this section: 

* * * * * 

(b) * * * 

(5) [Reserved]

(6) [Reserved]

(7) Name and annual quantity (metric tons) of each carbon-containing fuel and feedstock. 

* * * * * 

(e) Annual methanol production (metric tons), if this quantity is not reported under 

subpart X of Part 98. 

Subpart Q—[AMENDED] 

15.16. Section 98.176 is amended by: 

a. a. Revising paragraph (b).

b. Removing and reserving paragraphs (e)(1), (e)(3), (e)(4),); and adding paragraph 

(e)(6). 

b. c. Removing and reserving paragraphs (f)(2) through (4), and (g).

c. Adding paragraph (e)(6).

The revisions and additions read as follows: 

§ 98.176 Data reporting requirements. 

* * * * * 

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(b) If a CEMS is used to measure CO2 emissions or if you determined CO2 emissions 

using the site-specific emission factor method in §98.173(b)(2) based on the total quantity of raw 

material feed (metric tons of CO2 per metric ton of raw material feed),, then you must report the 

annual production quantity for the production unit (in metric tons) for taconite pellets, coke, 

sinter, iron, and raw steel. 

* * * * * 

(e) * * * 

(6) The information specified in paragraphs (e)(6)(i) through (vi) of this section 

aggregated for all process units for which CO2 emissions were determined using the mass 

balance method in § 98.173(b)(1), except as provided in § 98.174(b)(4). 

(i) The annual mass (metric tons) of all gaseous, liquid, and solid fuels (combined) used 

in process units for which CO2 emissions were determined using Equations Q-1 through Q-7 of 

this section, calculated as specified in Equation Q-9 of this section. 

ݑܨ݈݁ 	ൌ ቀ∑ ܨ௚, ∗ 	௜ெௐ೔

ெ௏஼

௡

௜ୀଵ ∗ 0.001 ൅ ܨ௟, ∗ ௜ߩ௟, ∗ ௜0.001	 ൅ ܨ௦,௜ቁ (Eq. Q-9) 

Where: 

Fuel = Annual mass of all gaseous, liquid, and solid fuels used in process units 

(metric tons). 

n = Number of process units where fuel is used. 

Fg,i = Annual volume of gaseous fuel combusted (“(Fg)” in Equations Q-1, Q-4 

and Q-7 of this section) for each process (scf). 

MWi = Molecular weight of gaseous fuel used in each process (kg/kg-mole). 

MVC = Molar volume conversion factor at standard conditions, as defined in §

98.6. Use 849.5 scf per kg mole if you select 68 °F as standard 

temperature and 836.6 scf per kg mole if you select 60 °F as standard 

temperature. 

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Fl,i = Annual volume of the liquid fuel combusted (“(Fl)” included in Equation 

Q-1 of this section) for each process unit (gallons). 

Fs,i = Annual mass of the solid fuel combusted (“(Fs)” in Equation Q-1 of this 

section) for each process unit (metric tons). 

ρl,i = Density of the liquid fuel (kg/gallon). 

0.001 = Conversion factor from kg to metric tons. 

(ii) The annual mass (metric tons) of all non-fuel material inputs (combined) specified in 

Equations Q-1 through Q-7 of this section, calculated as specified in Equation Q-10 of this 

section. 

௡௜݈݁݁ݐܵ ൅ ݀݁݋ݎݐ݈݁ܿܧ ൅ ݁݁݀ܨ ൅ ݈ܽ݋ܥ ൅ ݊݋ܾݎܽܥ ൅ ݔݑ݈ܨ ൅ ݌ܽݎܵܿ ൅ ݊݋ݎܫ ൅ ܱ ෍൭ ൌ ܫܨܰ

௡

௜ୀଵ

൱ݎ݄݁ݐܱ ൅ ݁ݎܱ ൅

 (Eq. Q-10) 

Where: 

NFI = Annual mass of all non-fuel inputs (to all process unit types) specified in 

Equations Q-1 through Q-7 of this section (metric tons). 

n = Number of process units, all process types. 

O = Annual mass of greenball (taconite) pellets fed to the taconite furnace(s) 

(metric tons). 

Iron = Annual mass of molten iron charged to the basic oxygen furnace(s) plus 

annual mass of direct reduced iron charged to the EAF(s) (metric tons). 

Scrap = Annual mass of ferrous scrap charged to the basic oxygen furnace(s) and 

EAF(s) (metric tons). 

Flux = Annual mass of flux materials charged to the basic oxygen furnace(s) and 

EAF(s) (metric tons). 

Carbon = Annual mass of carbonaceous materials (e.g., coal, coke) charged to the 

basic oxygen furnace(s), EAF(s), and direct reduction furnace(s) (metric 

tons). 

Coal = Annual mass of coal charged to the coke oven battery(s) (metric tons). 

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6.44"

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Feed = Annual mass of sinter feed material charged to the sinter process(es) 

(metric tons). 

Electrode = Annual mass of carbon electrode consumed in the EAF(s) (metric tons). 

Steelin = Annual mass of molten steel charged to the decarburization vessels (metric 

tons). 

Ore = Annual mass of iron ore or iron ore pellets fed to the direct reduction 

furnace(s) (metric tons). 

Other = Annual mass of other materials charged to the direction reduction 

furnace(s) (metric tons). 

(iii) The annual mass (metric tons) of all solid and liquid products and byproducts 

(combined) specified in Equations Q-1 through Q-7 of this section, calculated as specified in 

Equation Q-11 of this section. 

௡∑ሺ ൌ ݏݐܿݑ݀݋ݎܲ

 (-11Q .ሺEq		 ሻ ܯܰ ൅ ݊݋ݎܫ ൅ ݎ݁ݐܵ݅݊ ൅ ݇݁݋ܥ ൅ ݈ܵܽ݃ ൅ ௨௧௢݈݁݁ݐܵ ൅ ܴ ൅ ܲ ୀଵ௜

Where: 

Products = Annual mass of all solid and liquid products and by-products (from all 

process units) specified in Equations Q-1 through Q-7 of this section 

(metric tons). 

n = Number of process units, all types. 

P = Annual mass of fired pellets produced by the taconite furnace (metric 

tons). 

R = Annual mass of air pollution control residue from all process units (metric 

tons). 

Steelout = Annual mass of steel produced by the basic oxygen furnace(s), EAF(s) and 

decarburization vessel(s) (metric tons). 

Slag = Annual mass of slag produced by the basic oxygen furnace(s) and EAF(s) 

(metric tons). 

Coke = Annual mass of coke produced by the non-recovery coke batteries (metric 

tons). 

Sinter = Annual mass of sinter produced from the sinter process(es) (metric tons). 

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Iron = Annual mass of iron produced from the direct reduction furnace (metric 

tons). 

NM = Annual mass of non-metallic materials produced by the direct reduction 

furnace (metric tons). 

(iv) The weighted average carbon content of all gaseous, liquid, and solid fuels 

(combined) included in Equation Q-9 of this section, calculated as specified in Equation Q-12 of 

this section. 

ܨܥ௔௩௚ ൌ ቀ ∑ ி೒,೔	∗

ಾೈ೔

ಾೇ಴

೙

೔సభ ∗஼೒೑,೔∗଴.଴଴ଵାி೗,೔∗஼೗೑,೔∗଴.଴଴ଵା	ிೞ,೔∗஼ೞ೑ ቁ

ி௨௘௟ (Eq. Q-12) 

Where: 

CFavg = Weighted average carbon content of all gaseous, liquid, and solid fuels 

included in Equation Q-9 of this section (weight fraction). 

n = Number of gaseous, liquid, and solid fuel input to each process unit as 

used in Equation Q-9. 

Cgf,i = Average carbon content of the gaseous fuel used in each process, from the 

fuel analysis results (kg C per kg of fuel). 

Clf,i = Carbon content of the liquid fuel used in each process, from the fuel 

analysis results (kg C per gallon of fuel. 

Csf = Carbon content of the solid fuel used in each process, from the fuel 

analysis (expressed as a decimal fraction, e.g., 95% = 0.95). 

Fuel = Annual mass of all gaseous, liquid, and solid fuels used in process units 

(metric tons), as calculated in Equation Q-9 of this section. 

(v) The weighted average carbon content of all non-fuel inputs to all process units 

(combined) included in Equation Q-10 of this section, calculated as specified in Equation Q-13 

of this section. 

ܫܥ௔௩௚ ൌ ൫∑ ேிூ೔∗஼ಿಷ಺೔ ೙

೔సభ ൯

ேிூ 			 (Eq. Q-13) 

Where: 

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CIavg = Weighted average carbon content of all non-fuel inputs to all process units 

included in Equation Q-10 of this section (weight fraction). 

n = Number of non-fuel inputs to all process units as used in Equation Q-10. 

NFIi = Annual mass of each non-fuel input used in Equation Q-10 (metric tons). 

CNFIi = Average carbon content of each non-fuel input used in Equation Q-10 

(expressed as a decimal fraction). 

NFI = Total of all non-fuel inputs to all process units (metric tons). 

(vi) The weighted average carbon content of all solid and liquid products and byproducts 

from all process units (combined) included in Equation Q-11 of this section, calculated as 

specified in Equation Q-14 of this section. 

ܥܲ௔௩௚ ൌ ൫∑ ௉௥௢ௗ௨௖௧೔∗஼ು೔ ೙

೔సభ ൯

௉௥௢ௗ௨௖௧௦ (Eq. Q-14) 

Where: 

CPavg = Weighted average carbon content of all solid and liquid products and 

byproducts from all process units (weight fraction). 

n = Number of products and byproducts from each process unit as used in 

Equation Q-11. 

Producti = Annual mass of each product or byproduct used in Equation Q-11 (metric 

tons). 

Cp,i = Average carbon content of each product or byproduct used in Equation Q11 (expressed as a decimal fraction). 

Products = Mass of all products and byproducts from all process units, calculated in 

Equation Q-11 of this section (metric tons). 

* * * * * 

Subpart R—[AMENDED] 

16.17. Section 98.186 is amended by removing and reserving paragraphs (b)(6) and 

(b)(7); and revising paragraph (b)(8) to read as follows: 

a. Removing and reserving paragraphs (b)(6) and (b)(7).

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b. Revising paragraph (b)(8).

§ 98.186 Data reporting procedures. 

* * * * * 

(b) * * * 

(6) [Reserved]

(7) [Reserved]

(8) List the method used for the determination of carbon content for each material used 

for the calculation of annual process CO2 emissions using Equation R–1 of this subpart for each 

smelting furnace (e.g., supplier provided information, analyses of representative samples you 

collected). 

* * * * * 

Subpart S—[AMENDED] 

17.18. Section 98.196 is amended by: 

a. a. Revising paragraph (b) introductory paragraphtext. 

b. b. Removing and reserving paragraphs (b)(2), (b)(3), (b)(5), (b)(6), (b)(8), 

(b)(10), (b)(11), and (b)(12). 

c. c. Adding paragraph (b)(18). 

The revisions and additions read as follows: 

§ 98.196 Data reporting requirements. 

* * * * * 

(b) If a CEMS is not used to measure CO2 emissions, then you must report the 

information listed in paragraphs (b)(1) through (18) of this section. 

* * * * * 

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(18) Annual quantity (metric tons) of lime product sold, by type. 

Subpart U—[AMENDED] 

18.19. Section 98.216 is amended by removing and reserving paragraphs (b), (e)(1), 

(f)(1e)(2), and (f)(2). 

Subpart V—[AMENDED] 

19.20. Section 98.226 is amended by: 

a. a. Revising the introductory paragraphtext. 

b. b. Removing and reserving paragraphs (d), (m)(1), and (m)(3). 

c. c. Adding paragraph (q). 

The revisions and additions read as follows: 

§ 98.226 Data reporting requirements. 

In addition to the information required by § 98.3(c), each annual report must contain the 

information specified in paragraphs (a) through (q) of this section. 

* * * * *

(d) [Reserved]

* * * * * 

(q) Annual percent N2O emission reduction for all production units combined. 

Subpart X—[AMENDED] 

20.21. Section 98.246 is amended by: 

a. a. Revising paragraph (a) introductory paragraphtext and paragraphparagraphs 

(a)(2) and (a)(4). 

b. b. Adding paragraphs (a)(12) and (13). 

c. c. Revising paragraph (b) introductory paragraphtext. 

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d. d. Removing and reserving paragraphs (b)(5)(iii) and (b)(5)(iv). 

e. Adding paragraphs (b)(9) and (b)(10). 

The revisions and additions read as follows: 

§ 98.246 Data reporting requirements. 

* * * * * 

(a) If you use the mass balance methodology in § 98.243(c), you must report the 

information specified in paragraphs (a)(1) through (a)(13) of this section for each type of 

petrochemical produced, reported by process unit. 

* * * * * 

(2) The type of petrochemical produced, names of products, and names of carboncontaining feedstocks. 

* * * * * 

(4) The temperature (in °F) at which the gaseous feedstock and product volumes used in 

Equation X–1 of this subpart were determined. 

* * * * * 

(12) Name and annual quantity (in metric tons) of each carbon-containing feedstock 

included in Equations X-1, X-2, and X-3 of § 98.243 of this subpart. 

(13) Name and annual quantity (in metric tons) of each carbon-containing co-product 

included in Equations X-1, X-2, and X-3 of § 98.243 of this subpart. 

(b) If you measure emissions in accordance with § 98.243(b), then you must report the 

information listed in paragraphs (b)(1) through (b)(10) of this section. 

* * * * * 

(9) Name and annual quantity (in metric tons) of each carbon-containing feedstock. 

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(10) Name and annual quantity (in metric tons) of each carbon-containing co-product. 

* * * * * 

Subpart Y—[AMENDED] 

21.22. Section 98.256 is amended by: 

a. a. Revising paragraphs (e)(6) and (e)(7) introductory paragraphtext. 

b. b. Removing and reserving paragraph (e)(7)(ii). 

c. c. Revising paragraphs (e)(9) and (e)(10). 

d. d. Adding paragraph (e)(11). 

e. e. Revising paragraphs (f)(7) and (f)(10) through (13). 

f. f. Removing and reserving paragraph (h)(4). 

g. g. Revising paragraphs (h)(5), (i)(5), (i)(7), and (i)(8). 

h. h. Removing and reserving paragraph (j)(2). 

i. i. Revising paragraphs (j)(5) through (9), (k)(3), (k)(4), (l)(5), and (m)(3). 

j. j. Removing and reserving paragraphs (o)(2)(ii) and), (o)(4)(ii) through (v), and 

(o)(6) and (7). 

k. k. Revising paragraph (p)(2). 

The revisions and additions read as follows: 

§ 98.256 Data reporting requirements. 

* * * * * 

(e) * * * 

(6) If you use Equation Y–1a of this subpart, an indication of whether daily or weekly 

measurement periods are used, the annual volume of flare gas combusted (in scf/year) and the 

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or numbering

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annual average molecular weight (in kg/kg-mole), and annual average carbon content of the flare 

gas (in kg carbon per kg flare gas). 

(7) If you use Equation Y–1b of this subpart, an indication of whether daily or weekly 

measurement periods are used, the annual volume of flare gas combusted (in scf/year), the 

annual average CO2 concentration (volume or mole percent), the number of carbon containing 

compounds other than CO2 in the flare gas stream, and for each of the carbon containing 

compounds other than CO2 in the flare gas stream: 

* * * * * 

(9) If you use Equation Y–3 of this subpart, the number of SSM events exceeding 

500,000 scf/day. 

(10) The basis for the value of the fraction of carbon in the flare gas contributed by 

methane used in Equation Y–4 of this subpart. 

(11) If using Equation Y-3, report: 

(i) Annual quantity of flare gas combusted (in MMscf per year). 

(ii) Annual average molecular weight of flare gas combusted (in mmBtu per MMscf). 

(iii) Annual average carbon content of flare gas combusted (expressed as a decimal 

fraction). 

(f) * * * 

(7) If you use Equation Y–6 of this subpart, the annual average exhaust gas flow rate, 

%CO2, and %CO. 

* * * * * 

(10) If you use Equation Y–8 of this subpart, the basis for the value of the coke burn-off 

factor, annual throughput of unit, and the average carbon content of coke. 

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(11) Indicate whether you use a measured value, a unit-specific emission factor, or a 

default emission factor for CH4 emissions. If you use a unit-specific emission factor for CH4, 

report the basis for the factor. 

(12) Indicate whether you use a measured value, a unit-specific emission factor, or a 

default emission factor for N2O emissions. If you use a unit-specific emission factor for N2O, 

report the basis for the factor. 

(13) If you use Equation Y–11 of this subpart, the number of regeneration cycles or 

measurement periods during the reporting year and the average coke burn-off quantity per cycle 

or measurement period. 

* * * * * 

(h) * * * 

(4) [Reserved]

(5) If you recycle tail gas to the front of the sulfur recovery plant, indicate whether the 

recycled flow rate and carbon content are included in the measured data under § 98.253(f)(2) and 

(3). Indicate whether a correction for CO2 emissions in the tail gas was used in Equation Y–12. If 

so, then report: 

(i) The value of the correction. 

(ii) If the following data are not used to calculate the recycling correction factor, report 

the information specified in paragraphs (h)(5)(ii)(A) through (C) of this section. 

(A) The annual volume of recycled tail gas (in scf/year) only. 

(B) The annual average mole fraction of carbon in the tail gas (in kg-mole C/kg-mole 

gas). 

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(C) Indicate whether you used the default (95%) or a unit specific correction, and if used, 

report the approach used. 

* * * * * 

(i) * * * 

(5) If you use Equation Y–13 of this subpart, an indication of whether coke dust is 

recycled to the unit (e.g., all dust is recycled, a portion of the dust is recycled, or none of the dust 

is recycled). 

* * * * * 

(7) Indicate whether you use a measured value, a unit-specific emission factor or a 

default for CH4 emissions. If you use a unit-specific emission factor for CH4, report the basis for 

the factor. 

(8) Indicate whether you use a measured value, a unit-specific emission factor, or a 

default emission factor for N2O emissions. If you use a unit-specific emission factor for N2O, 

report the basis for the factor. 

(j) * * * 

(5) If you use Equation Y–14 of this subpart, the basis for the CO2 emission factor used. 

(6) If you use Equation Y–15 of this subpart, the basis for the CH4 emission factor used. 

(7) If you use Equation Y–16 of this subpart, the basis for the carbon emission factor 

used. 

(8) If you use Equation Y–16b of this subpart, the basis for the CO2 emission factor used 

and the basis for the carbon emission factor used. 

(9) If you use Equation Y–17 of this subpart, the basis for the CH4 emission factor used. 

(k) * * * 

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(3) The total number of delayed coking units at the facility; the total number of delayed 

coking drums at the facility; and, for each coke drum or vessel, the typical drum outage (i.e. the 

unfilled distance from the top of the drum, in feet). 

(4) For each set of coking drums that are the same dimensions, the number of coking 

drums in the set, and the mole fraction of methane in coking gas (in kg-mole CF4/kg-mole gas, 

wet basis). 

* * * * * 

(l) * * * 

(5) The annual volumetric flow discharged to the atmosphere (in scf), and an indication 

of the measurement or estimation method, annual average mole fraction of each GHG above the 

concentration threshold or otherwise required to be reported and an indication of the 

measurement or estimation method, and for intermittent vents, the number of venting events and 

the cumulative venting time. 

(m) * * * 

(3) For uncontrolled blowdown systems reporting under § 98.253(k), the basis for the 

value of the methane emission factor used for uncontrolled blowdown systems. 

* * * * * 

(p) * * * 

(2) The types of materials loaded that have an equilibrium vapor-phase concentration of 

methane of 0.5 volume percent or greater, and the type of vessel (barge, tanker, marine vessel, 

etc.) in which each type of material is loaded. 

* * * * * 

Subpart Z—[AMENDED] 

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22.23. Section 98.266 is amended by removing and reserving paragraphs (f)(5) and 

(f)(6). 

Subpart AA—[AMENDED] 

23.24. Section 98.276 is amended by: 

a. a. Revising the introductory paragraph. 

b. b. Removing and reserving paragraph (b). 

c. c. Revising paragraph (c). 

d. d. Removing and reserving paragraphs (d), (f), (g), (h) and (i). 

e. e. Adding paragraphs (l) and (m). 

The revisions and additions read as follows: 

§ 98.276 Data reporting requirements. 

In addition to the information required by § 98.3(c) and the applicable information 

required by § 98.36, each annual report must contain the information in paragraphs (a) through 

(m) of this section as applicable: 

* * * * * 

(b) [Reserved]

(c) Basis for determining the annual mass of the spent liquor solids combusted (whether 

based on T650 om-05 Solids Content of Black Liquor, TAPPI (incorporated by reference, see §

98.7) or an online measurement system). 

(d) [Reserved]

* * * * * 

(l) For each pulp mill lime kiln, report the information specified in paragraphs (l)(1) and 

(2) of this section. 

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(1) The quantity of calcium oxide (CaO) produced (metric tons). 

(2) The percent of annual heat input, individually for each fossil fuel type. 

(m) For each chemical recovery furnace and each chemical recovery combustion unit for 

which you are not using Equation C-2c to calculate CO2 emissions, report the information 

specified in paragraphs (m)(1) and (2) of this section. 

(1) The annual mass of steam generated (lb steam), individually for each fossil fuel type 

and for spent liquor solids. 

(2) The ratio of the unit’s maximum rated heat input capacity to its design rated steam 

output capacity (mmBtu/lb steam), individually for each fossil fuel type and for spent liquor 

solids. 

Subpart BB—[AMENDED] 

24.25. Section 98.286 is amended by removing and reserving paragraphs (b)(1), (b)(4), 

and (b)(6). 

Subpart CC—[AMENDED] 

25.26. Section 98.296 is amended by removing and reserving paragraphs (b)(5) through 

(7). 

Subpart EE—[AMENDED] 

26.27. Section 98.316 is amended by removing and reserving paragraphs (b)(6) and 

(b)(9). 

Subpart GG—[AMENDED] 

27.28. Section 98.336 is amended by removing and reserving paragraphs (b)(6), (b)(7), 

and (b)(10). 

Subpart TT—[AMENDED] 
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28.29. Section 98.466 is amended by: 

a. a. Removing and reserving paragraph (c)(3)(i). 

b. b. Revising paragraph (c)(3)(ii). 

c. c. Removing and reserving paragraph (c)(3)(iii). 

The revisions read as follows: 

§ 98.466 Data reporting requirements. 

* * * * * 

(c) * * * 

(3) * * * 

(i) [Reserved]

(ii) The year of the data used in Equation TT-2 for the waste disposal quantity and 

production quantity, for each year used in Equation TT–2 of this subpart to calculate the average 

waste disposal factor (WDF). 

(iii) [Reserved]

* * * * ** * * * * 

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Attachment I
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1 

TECHNICAL MEMORANDUM 

DATE: August 2013 

TO: Docket EPA-HQ-OAR-2010-0929 

FROM: Lisa Grogan-McCulloch

SUBJECT: Evaluation of Alternative Verification Approaches For Greenhouse Gas 

Reporting Rule Subparts for which Reporting of Inputs to Emission 

Equations was Deferred to March 31, 2015 

1.0 Introduction and Purpose of Analysis 

In the August 25, 2011 final rule deferring reporting to March 31, 2015 of certain inputs to 

emission equations under 40 CFR part 98 (76 FR 53057), EPA expressed its intent to further 

evaluate these inputs to emission equations (hereafter referred to as “’inputs to equations’ data 

elements”). EPA outlined a four-step process for this evaluation in the August 25, 2011 final rule 

and in a supporting memorandum entitled “Process for Evaluating and Potentially Amending 

Part 98 Inputs to Emission Equations” (docket EPA-HQ-OAR-2010-0929). The purpose of this 

memorandum is to describe the review undertaken for the fourth step of the evaluation process: 

EPA’s analysis of alternative verification methods that would not require reporting of the “inputs 

to equations” data elements. This review evaluates alternative verification methods for 25 

subparts, based on the results of steps one through three of the four-step process. The review was 

not undertaken for subparts W and II because the EPA’s evaluation of these inputs under Step 2 

did not identify the need to proceed to the next steps.1

Section 2.0 of this memorandum summarizes EPA’s current verification process. Section 3.0 of 

this memorandum summarizes the review of alternative verification approaches suggested in 

comments to the Call for Information, which was issued on December 27, 2013 (75 FR 81366) to 

request additional information to conduct its evaluation of “inputs to equations” data elements. 

Section 4.0 discusses an alternative verification method that consists of an electronic verification 

tool developed by EPA, enhanced recordkeeping requirements, and additional reporting 

requirements. 

 

1

 The review was not conducted for “inputs to equations” in subpart I because reporting of the “inputs to equations” 

data elements for that subpart was addressed in a separate proposed action [see 77 FR 63538]. Additionally, the 

evaluation of the subpart C “inputs to equations” in this memorandum encompasses the one subpart A “input to 

equation” data element. As a result, the one subpart A “input to equation” data element is not listed explicitly in this 

memorandum. 
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2 

2.0 EPA’s Current Verification Process 

During the first 3 years of the Greenhouse Gas Reporting Program (GHGRP), EPA has had 

success developing and using an electronic reporting and verification system for all subparts 

reporting under the program. The current verification approach for the GHGRP consists of 

requiring facility self-certification of the annual reports along with EPA conducting electronic 

verification checks of the data entered into e-GGRT, followed by direct follow-up with facilities 

if necessary. For subparts where the reporting of inputs to emission equations was deferred until 

2015, these checks have been conducted using reported data other than inputs to emission 

equations (the reporting of which was deferred). For “supplier” subparts2 (and starting in 

reporting year 2012 for subparts with inputs to emission equations that were deferred until 2013), 

these checks have been conducted using reported data that include the data needed to calculate 

outputs of the equations. Reporters under these subparts have been entering into e-GGRT the 

data needed to calculate the annual GHG quantities. 

During reporting year 2010, EPA developed approximately 1,400 electronic verification checks 

to verify reported data. Based on these verification checks, EPA followed up with facilities 

regarding potential data quality errors for approximately 2,360 of the approximately 6,700 

facilities that reported in reporting year 2010. In reporting year 2011, EPA programmed an 

additional 1,000 checks into e-GGRT for the subparts that were reporting for the second year, 

expanding the number of checks to 2,400. EPA also programmed into e-GGRT, for 2011, 

approximately 1,300 checks for the newly-reporting subparts. During reporting year 2011, EPA 

followed up with approximately 3,440 of the approximately 8,000 facilities that reported. 

3.0 Evaluation of Alternative Verification Methods Suggested by Commenters 

The Call for Information notice specifically requested commenter input on alternative 

verification approaches that would not require reporting to EPA those data elements for which 

reporting may cause competitive harm. In response, EPA received input from 16 commenters 

suggesting alternative verification methods. The comments expressed support for the following 

verification methods: (1) self-certification, (2) EPA compliance inspection/audits only, (3) 

implementation of third party auditing or third party verification, and (4) a verification approach 

similar to EPA’s Toxic Release Inventory (TRI). These verification approaches are discussed in 

sections 3.1 through 3.4. 

3.1 Self-certification 

Given the complexity of the GHG monitoring and reporting requirements, the large number of 

reporters (over 8,000), and the need for high quality data, self-certification alone is not sufficient 

 

2

 Supplier subparts (subparts LL through PP of Part 98) apply to fossil fuel suppliers and industrial gas suppliers. The eGGRT system currently calculates equation outputs for suppliers using reported equations inputs. Subpart MM 

reporters began using e-GGRT for reporting in Reporting Year 2012. 
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3 

to ensure that GHG emissions are being reporting accurately. EPA’s experience with reviewing 

the 2010 and 2011 reporting year annual reports showed that there have been errors made in 

GHG emissions reporting. Self-certification alone would not address these errors. As mentioned 

in section 2.0 of this memorandum, EPA’s verification process for the 2010 and 2011 reporting 

years resulted in EPA identifying thousands of potential reporting errors and reporters 

resubmitting numerous corrected reports. Based on this experience, self-certification alone, 

without EPA verification, would result in a significantly reduced ability to verify emissions and 

ensure compliance with the GHGRP. 

3.2 EPA Compliance Inspections/Audits 

Given that more than 8,000 facilities and suppliers in more than 40 source categories submit 

annual reports, it would be possible for EPA to visit only a very small fraction of the reporting 

facilities in any given year (e.g., even if EPA visited 100 facilities, that would be only 1.25 

percent of reporters). Therefore, relying solely on on-site compliance inspections as the primary 

method of verifying reported GHG data is impractical and would not be cost effective. Even if 

on-site audits were to identify, and result in correction of, monitoring and reporting problems at 

some of the visited facilities, there would be numerous other facilities that would not have been 

visited and that potentially would have made significant errors that would not have been 

identified and corrected. In order to ensure compliance, EPA’s verification approach needs to 

collect enough information about all facilities to allow sufficient assessment of the data quality 

prior to performing on-site audits. For example, EPA’s current verification approach allows EPA 

to identify many reporting errors and allow for their resolution without the time and expense of 

on-site visits. Using the information obtained through this process, compliance inspections are 

better targeted toward facilities or sectors most likely to have significant, unresolved verification 

issues. 

3.3 Third Party Verification 

Commenters on the Call for Information suggested third party verification as an alternative 

verification method. EPA had previously considered third party verification, but decided against 

its implementation. Refer to EPA’s full rationale for not selecting third party verification in the 

October 30, 2009 final rule (74 FR 56260). The following is a summary of this rationale, as well 

as an explanation of why EPA has determined that these reasons still apply: 

 The costs to the reporters of hiring third party verifiers would be substantial, given the 

more than 8,000 reporters under the GHGRP. If EPA were to adopt third party 

verification at this juncture, the cost to the reporters would be the same as originally 

estimated, which was thousands of dollars per reporting facility. While EPA received 

some comments on the Call for Information supporting third party verification, the vast 

majority of reporters did not submit comments supporting this approach. 
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4 

 A centralized emissions verification system, as opposed to third party verification (which 

is de-centralized), provides a greater ability for EPA to identify trends and outliers in data 

and thereby assist with targeted follow-up review. The data collected through the 

GHGRP, beyond collected inputs to emission equations, are used for verification 

purposes as well as to inform future GHG policy development. EPA has utilized the 

national data set to verify the reported emissions as well as to gain a fuller picture of the 

emissions profile of the different sectors, and will continue to do so in the future. 

 Developing the third party verification approach would require EPA to establish and 

develop emissions verification protocols and a system to qualify and accredit third party 

verifiers, as well as to develop and administer a process to ensure that verifiers hired by 

reporting facilities do not have conflicts of interest. Such a program would require EPA 

to review numerous individual conflict of interest screening determinations made each 

time a reporter hires a third party verifier, which would be time-consuming. Even if EPA 

were to partner with an existing program or organization to accredit verifiers, EPA would 

still need to develop the criteria and systems described above to implement the GHGRP 

and ensure high quality emissions verification given the unique reporting requirements of 

the GHGRP. If EPA were to adopt third party verification at this juncture, EPA would 

still have to develop the infrastructure described above to support it. Not only would this 

take several years to put into place, this approach would not build upon the success of the 

thousands of verification checks that EPA has developed over the first few years of the 

program. 

 Third party verification would potentially result in delays in the publication of the annual 

data and could result in facilities responding to inquiries from both EPA and third party 

verifiers. Under a third party verification system, a facility would contract with a third 

party verifier and provide the verifier detailed data (by March 31) so that the third party 

could perform the verification. The third party verifiers would perform on-site visits to 

many of the facilities as part of the verification process. After conducting the verification 

according to required protocols, the third party verifier would submit their findings to the 

facility with errors identified, which the facility could then correct. For existing third 

party GHG verification programs, this verification process generally takes three to six 

months. Given the large number of facilities (over 8,000) that would need to have third 

party verifications conducted, sufficient time would need to be allowed for this step. 

After receiving the data that has undergone third party verification, EPA would review 

the data prior to release. EPA would then perform additional electronic checks on the full 

set of reported data because using such checks and statistical analyses on the entire data 

set would likely reveal inconsistencies and errors in addition to those identified by the 

third party verifier. If EPA identified additional potential reporting errors, EPA would 

then contact the facility to resolve the issue. It would be inefficient for EPA to perform 

verification of the data reported by facilities at the same time as the third party 

verification is ongoing, because EPA and the third party verifier would likely be 

communicating duplicative, or possibly conflicting, requests to the same facility 

regarding potential errors. As a result, this verification would likely be conducted after 

third party verification is complete. If EPA allows the same 4-month period it has in 

previous years for these EPA verification activities prior to publication/release of data, 
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then data would be released eight to ten months after the March 31 reporting date. This 

approach would not only potentially lengthen the time it would take to publish data, but 

would also potentially require facilities to respond to both third party verifiers as well as 

EPA. 

3.4 Verification in EPA’s Toxic Release Inventory (TRI) Program 

The TRI program requires annual facility level reporting of the amount of toxic chemicals 

released to the environment or otherwise managed as wastes. Some aspects of the TRI program 

are similar to the GHGRP. The TRI reports contain a signed self-certification that the 

information reported is accurate. Each facility must also keep records of how emissions were 

calculated, including supporting materials, documents, calculations, worksheets, and other 

information used. This approach is similar to the self-certification approached described in 

section 3.2, and has the same disadvantages if not used in combination with other verification 

methods. In addition, to improve the quality of the TRI data, EPA provides extensive training 

and assistance to reporters, free electronic software to facilitate electronic submission of data, 

conducts electronic data checks, and contact facilities to resolve reporting errors. However, the 

TRI is a different type of program than the GHGRP in that it does not require specific 

monitoring and calculation approaches, but rather requires that estimates be based on the best 

available information. TRI estimates can be based on monitoring, emission factors, mass 

balance, and/or other methods for over 600 chemicals and chemical categories. In contrast, the 

GHGRP prescribes a set of specific calculation methods, or equations, for individual source 

categories, processes, and emission units, so that data collected from multiple facilities are 

consistent and comparable. The data entered into these equations, which are “inputs to 

equations” data elements, often include process or production data specific to each facility’s 

operations. These “inputs to equations” data elements play an important role in EPA’s ability to 

verify GHGRP emissions and ensure compliance with the program. Therefore, given the 

additional specification provided by the GHGRP, it is necessary that EPA assess whether 

calculations were conducted correctly and according to the appropriate equation specified in Part 

98, as well as conduct additional verification checks (e.g., assessing whether appropriate 

monitoring methods were used). While there is some similarity in the verification approaches of 

the two programs, direct application of the approach used for verification of the TRI program 

would result in a significantly reduced ability to verify emissions and ensure compliance with the 

GHGRP. 

4.0 Summary and Evaluation of an Alternative Verification Method Using an Inputs 

Verification Tool, Enhanced Recordkeeping, and Additional Reporting 

During EPA’s consideration of alternative verification methods, EPA evaluated an approach 

involving the use of an electronic inputs verification tool, enhanced recordkeeping requirements, 

and additional reporting requirements. Section 4.1 describes the inputs verification tool and 

options considered for implementation, section 4.2 describes the enhanced verification 
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6 

requirements, section 4.3 describes the additional reporting requirements, and section 4.4 

reviews the effectiveness of this verification approach at verifying emissions and ensuring 

compliance with the GHGRP. 

4.1 Description of Inputs Verification Tool and Options for Implementation 

EPA evaluated the option of using a verification approach similar to the verification approach 

currently used for the supplier subparts, where data needed to calculate the outputs of the 

equations are entered into e-GGRT and used to calculate the annual GHG emission values, 

followed by EPA verification of these emission values. EPA considered using a similar approach 

whereby “inputs to equations” data elements would be entered into a new inputs verification tool 

within e-GGRT in such a way that the “inputs to equations” data elements could be used for data 

verification, but not be reported to EPA. EPA considered several approaches for implementing 

this concept. The options are discussed below. 

Inputs Verification Tool – Deployed within E-GGRT with Inputs Saved Locally by Users

The first option EPA considered was to have an inputs verification tool be deployed within eGGRT with the inputs to equations saved locally by the reporters. This option would be 

integrated without interrupting the current electronic reporting process. Under this approach, to 

access this inputs verification tool, reporters would log into e-GGRT. They would enter data 

elements required for the annual report as well as specified “inputs to equations” data elements. 

The tool would operate securely within e-GGRT, as a transient process, which means that data 

entered into the tool would be temporarily saved in the tool while the reporter is actively using 

the tool, but would not be persisted (i.e., saved) within the e-GGRT database. Data entered into 

the tool would be discarded when the user’s session with e-GGRT ends. 

If the reporter were to exit the inputs verification tool prior to completing data entry or 

submitting their annual report, the tool would generate a file of entered “inputs to equations” data 

elements, and allow the reporter to download the file. The reporter would have the option to 

upload this file into the tool when they next use the tool. This option would avoid facilities from 

needing to re-enter “inputs to equations” data elements that were entered in previous e-GGRT 

sessions. 

After the reporter enters specified “inputs to equations” data elements into the inputs verification 

tool, the tool would calculate the annual GHG emissions values. The tool would use the 

following information in calculating these values: (1) “inputs to equations” data elements, (2) 

information entered into e-GGRT identifying which Part 98 calculation method was selected (if 

applicable), and (3) the selected Part 98 calculation method. Once the annual GHG emissions 

values are calculated, the values would be pre-filled into the appropriate reporting fields within 

e-GGRT. Reporters would then have the opportunity to override the annual GHG emissions 

values calculated by the tool with their own calculated value. 
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Prior to annual report submittal, the inputs verification tool would conduct a series of verification 

checks, including the following: 

 Verification checks on the annual GHG emission values calculated by the inputs 

verification tool. Reporters would have the opportunity to override and revise the values 

calculated by the tool; however should this occur, the tool would note this decision, as 

well as any discrepancy, which would prompt EPA for further review after the reporter 

submits the annual report. 

 Verification checks on entered “inputs to equations” data elements. For example, the tool 

would check: (1) whether all required data were entered; (2) whether entered “inputs to 

equations” data element values are within the expected ranges for the data elements; and 

(3) whether expected relationships exist between certain “inputs to equations” data 

elements and certain other reported data elements (e.g., process raw material or 

throughput data that are not “inputs to equations” data elements). 

Some of these checks would be conducted as the reporter enters “inputs to equations” data 

elements (i.e., using “real-time” checking), and other checks would be conducted after the 

reporter has entered all specified “inputs to equations” data elements, because some algorithms 

may compare certain “inputs to equations” data elements (e.g., production quantity) to GHG 

emission values at the subpart or facility level. Also, prior to submittal of the annual report, the 

inputs verification tool would generate a verification summary containing the results of the 

verification checks. The verification summary would specify whether any potential errors, as 

described above, were identified, without specifying any information about the “inputs to 

equations” data elements. The reporter would have an opportunity to review the verification 

summary and make necessary revisions to the entered “inputs to equations” data elements and 

the reported data elements. Additionally, the tool would generate a file listing all entered “inputs 

to equations” data elements to be kept by the reporter as a record of these data (refer to section 

4.2 for further discussion of this recordkeeping requirement). 

Inputs Verification Tool – Deployed within E-GGRT with Inputs Encrypted and Saved at EPA

EPA also considered having inputs to equations data elements entered into an inputs verification 

tool within e-GGRT, encrypting the inputs to equations data, and storing the encrypted data at 

EPA. This option would have the same functionality as the inputs verification tool deployed 

within e-GGRT with the inputs to equations saved locally. The difference in approach is that the 

data would be stored at EPA in an encrypted manner. The data would be indecipherable to EPA 

and could only be decrypted with the key that would be held by representatives for that 

facility. The inputs to emissions equations data would not be submitted to EPA as part of the 

annual report. Like the first option discussed, the inputs verification tool in this option would 

run verification checks on the inputs to equations data elements, calculate emissions, and submit 
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the verification summary to EPA. Additionally, like the first option, the tool would generate a 

file listing all entered “inputs to equations” data elements to be kept by the reporter as a record of 

these data (refer to section 4.2 for further discussion of this recordkeeping requirement) 

EPA identified some benefits with the encryption option. First, users would be able to enter a 

portion of their inputs to equation data elements, log out, and then resume data entry in a later 

session without having to save inputs to equations data elements locally each time. Second, 

multiple users would be able to work on a facility’s inputs to equations concurrently or 

independently without needing to coordinate which downloaded inputs to equation file is the 

most recent file; however, as described below, multiple users would need to coordinate/share the 

encryption key so that each user could access the data entered into the inputs verification tool. 

EPA also identified several limitations with the encryption option. One factor is that members of 

the GHG reporting community may be uncomfortable with having the “inputs to equations” data 

elements stored at the EPA (in an encrypted manner). Another consideration is the encryption 

key would have to be managed by the user; if the key were lost, the data could not be recovered 

by EPA support. If this occurred, users would have to re-enter inputs to equations into the inputs 

verification tool, resulting in potentially frustrated users. A third limitation is that if a reporter 

has multiple users and/or facilities, the users would have to coordinate the facility-specific 

encryption keys among various users across multiple facilities. In order to access the data entered 

into the inputs verification tool, each user from a facility would need to know the encryption key. 

Lastly, the encryption key would be a separate “password” from the general e-GGRT log-in 

process, and users may be confused with the need to maintain two passwords, one for e-GGRT, 

and a different one for the inputs verification tool. This could result in an increased need for EPA 

to support the use of e-GGRT and the inputs verification tool. 

Inputs Verification Tool – Application Installed and Run on User’s Computer

EPA considered having the inputs verification tool be a compiled application that would need to 

be installed on an individual user’s desktop computer rather than using a web-based system. In 

this option, EPA would develop and distribute a desktop, client-side application that reporters 

would download, install, and use locally. The user would enter the inputs to equations data 

elements into the desktop application, which would perform the appropriate verification checks 

and calculations. The application would save inputs to the user’s local computer or drive and 

would transmit only the verification summary (which, as mentioned above, would not contain 

inputs to equations) to e-GGRT. Additionally, like the first two options, the tool would generate 

a file listing all entered “inputs to equations” data elements to be kept by the reporter as a record 

of these data (refer to section 4.2 for further discussion of this recordkeeping requirement). 
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A benefit of the desktop application is that all inputs to equations data elements would be 

managed by users on their own computers and no inputs to equations data elements would be 

transmitted to EPA. 

EPA identified several challenges inherent in this option, as follows. 

o Limits in functionality: A desktop application may limit the scope of verification that 

EPA could perform. EPA would not be able to easily run verification checks between the 

inputs data and the information reported to EPA through the GHGRP annual report. For 

example, in subpart X, facilities report annual production in the GHG report and monthly 

production as an input, but the data could not easily be compared if they are stored in 

different places. In addition, it would be difficult for EPA to add to or revise the 

verification checks in the application, because it would require individual users to 

perform periodic application updates requiring administrative privileges. EPA would 

need to limit the number of updates in the software, which may limit EPA from 

improving the process as enhancements are identified. 

o Burden to users: The desktop application approach would likely increase the burden to 

users. First, users would need to have administrator privileges for their machines to 

install a local, client-side application. In many corporate environments, this is not 

possible without the assistance of information technology (IT) professionals and/or 

exceptions to existing IT security policies. It is likely that the application would need to 

be updated at least once each year; for example, to add verification checks or to refine 

ranges. In these cases, users would need to download and install the new version. Third, 

it would be labor-intensive and difficult for EPA to develop a standalone application that 

replicates logic already present in e-GGRT, which assists users in such ways as guiding 

them to use the correct equations. This would most likely result in increased burden to 

users due to additional necessary follow-up by EPA during the post-submission 

verification process. 

o Burden to EPA: Developing a desktop application would likely increase the cost to EPA. 

EPA would need to develop versions of the application that are specific to different 

operating systems and then update the applications whenever the operating system 

changes. Also, if the software had problems or bugs, EPA would have to update the 

application, post the new release, and ask users to download and install it. There would 

be a significant increase in the burden to answer questions that users typically experience 

during installation. Additionally, EPA would need to develop a method to ensure the 

facilities are using the correct version of the software as updates occur. 

 
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4.2 Description of Enhanced Recordkeeping Requirements 

Because there may be more direct follow-up verification activities with the use of the inputs 

verification tool, EPA considered two enhancements to recordkeeping requirements. First, EPA 

considered extending the record retention period from 3 to 5 years. It would be important that 

relevant records are available to EPA for follow-up activities with facilities, including on-site 

audits if necessary, regarding potential errors, discrepancies, or questions. Should an EPA 

inspector visit a facility, it would be important to be able to examine not only the current year’s 

records, but also those from previous years, because previous years’ data would provide year-toyear comparisons, which are useful for verifying the current year’s data. A 5-year record 

retention period would ensure the availability of relevant records for the follow-up activities 

described above. 

Second, EPA considered revisions to the recordkeeping format for “inputs to equations” data 

elements. Currently, reporters have the option to maintain records of their “inputs to equations” 

data elements in one or more electronic or hard copy files. Requiring reporters to maintain an 

electronic or hard copy of the single file generated by the inputs verification tool (i.e., a file 

listing all “inputs to equations” data elements entered into the tool) would ensure that EPA could 

readily access these data during site visits, enabling EPA to quickly and efficiently perform 

calculations and data checks. 

4.3 Description of Additional Reporting Requirements 

To improve the efficiency of the data verification process under this alternative approach using 

the inputs verification tool described in section 4.1 and the enhanced recordkeeping described in 

section 4.2, EPA considered supplementing the information available to EPA under the GHGRP 

by requiring reporting of additional data. Certain additional data would enable EPA to perform 

additional verification checks, thereby minimizing the number of follow-up activities. Such data 

would provide information on the activity level at the facility, emission factors, characteristics of 

carbon-containing streams, and other process information that provide key information for 

verification (e.g., data confirming that emissions are appropriate for a given activity-level, and 

data estimating expected emissions based on data provided). 

4.4 Review of Effectiveness of Using an Inputs Verification Tool, Enhanced 

Recordkeeping, and Additional Reporting To Accomplish Data Verification 

In the October 30, 2009 final rule (74 FR 56282 – 56283), EPA described its verification 

approach as the following two-step process: 

 Initial automated review of reported data, using an electronic data quality assurance 

program built into the data system, for use by reporters and EPA to help assure the 

completeness and accuracy of data. 
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 Based on the initial review results, follow up with facilities regarding potential errors, 

discrepancies, or questions, including on-site audits. 

The use of the inputs verification tool to conduct verification checks on the “inputs to equations” 

data elements (as described in section 4.1) would build on EPA’s experience with electronic 

reporting and verification during the first two years of the GHGRP. As discussed in more detail 

in section 2.0, for reporting years 2010 and 2011, EPA used electronic verification checks to 

verify data and follow up with thousands of facilities. For 2011 alone, based on 3,700 types of 

checks, EPA followed up with approximately 3,440 of the approximately 7,900 reporting 

facilities. 

The inputs verification tool utilizes the same approach that EPA currently uses for calculating 

and verifying data submitted for supplier subparts (and starting in reporting year 2012, inputs to 

emission equations for which the reporting deadline was deferred until 2013), except that eGGRT would not retain the “inputs to equations” data elements entered into the tool, as 

described in section 4.1. Once the annual report is submitted, EPA would review the verification 

summary generated by the inputs verification tool, along with verification summaries that are 

currently generated using data currently collected through the annual report. By requiring use of 

the inputs verification tool, EPA would have the additional certainty that reported annual GHG 

emissions values either were calculated correctly (because the values calculated by the tool were 

submitted to EPA) or that EPA would be made aware that there were discrepancies between 

values calculated by the tool and values submitted to EPA. This additional certainty, combined 

with the additional information provided by the range and algorithm verification checks 

conducted on the “inputs to equations” data elements themselves, would provide EPA with the 

information necessary to conduct further verification once the annual report is submitted. 

Once data verification within the inputs verification tool is completed and the annual report is 

submitted, EPA would conduct the same verification checks that it currently conducts (following 

annual report submittal) on data reported via e-GGRT and additional verification checks using 

the information provided by the additional reporting requirements. Regarding any needed followup with facilities, the enhanced recordkeeping requirements described in section 4.2 (i.e., 5-year 

retention period and uniform format) would ensure that EPA has adequate time to efficiently 

examine the “inputs to equations” data elements on-site. 
Attachment J 
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1 

TECHNICAL MEMORANDUM 

DATE: April August 2013 

TO: Docket EPA-HQ-OAR-2010-0929 

FROM: Lisa Grogan-McCulloch

SUBJECT: AnalysisEvaluation of Alternative Verification Approaches For Greenhouse 

Gas Reporting Rule Subparts for which Reporting of Inputs to Emission 

Equations was Deferred to March 31, 2015 

1.0 Introduction and Purpose of Analysis 

In the August 25, 2011 final rule deferring reporting to March 31, 2015 of certain inputs to 

emission equations under 40 CFR part 98 (76 FR 53057), EPA expressed its intent to further 

evaluate these inputs to emission equations (hereafter referred to as “’inputs to equations’ data 

elements”). EPA outlined a four-step process for this evaluation in the August 25, 2011 final rule 

and in a supporting memorandum entitled “Process for Evaluating and Potentially Amending 

Part 98 Inputs to Emission Equations” (docket EPA-HQ-OAR-2010-0929). The purpose of this 

memorandum is to describe the review undertaken for the fourth step of the evaluation process: 

EPA’s analysis of alternative verification methods that would not require reporting of the “inputs 

to equations” data elements. This review evaluates alternative verification methods for 25 

subparts, based on the results of steps one through three of the four-step process. The review was 

not undertaken for subparts W and II because the EPA’s evaluation of these inputs under Step 2 

did not identify the need to proceed to the next steps.1

Section 2.0 of this memorandum summarizes EPA’s current verification process. Section 3.0 of 

this memorandum summarizes the review of alternative verification approaches suggested in 

comments to the Call for Information, which was issued on December 27, 2013 (75 FR 81366) to 

request additional information to conduct its evaluation of “inputs to equations” data elements. 

Section 4.0 discusses an alternative verification method that consists of an electronic verification 

tool developed by EPA, enhanced recordkeeping requirements, and additional reporting 

requirements. Section 5.0 provides a summary of the analysis.

 

1

 The review was not conducted for “inputs to equations” in subpart I because reporting of the “inputs to equations” 

data elements for that subpart was addressed in a separate proposed action [see 77 FR 63538]. Additionally, the 

evaluation of the subpart C “inputs to equations” in this memorandum encompasses the one subpart A “input to 

equation” data element. As a result, the one subpart A “input to equation” data element is not listed explicitly in this 

memorandum. 
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2 

2.0 EPA’s Current Verification Process 

During the first 3 years of the Greenhouse Gas Reporting Program (GHGRP), EPA has had 

success developing and using an electronic reporting and verification system for all subparts 

reporting under the program. The current verification approach for the GHGRP consists of 

requiring facility self-certification of the annual reports along with EPA conducting electronic 

verification checks of the data entered into e-GGRT, followed by direct follow-up with facilities 

if necessary. For subparts where the reporting of inputs to emission equations was deferred until 

2015, these checks have been conducted using reported data other than inputs to emission 

equations (the reporting of which was deferred). For “supplier” subparts2 (and starting in 

reporting year 2012 for subparts with inputs to emission equations that were deferred until 2013), 

these checks have been conducted using reported data that include the data needed to calculate 

outputs of the equations. Reporters under these subparts have been entering into e-GGRT the 

data needed to calculate the annual GHG quantities. 

During reporting year 2010, EPA developed approximately 1,400 electronic verification checks 

to verify reported data. Based on these verification checks, EPA followed up with facilities 

regarding potential data quality errors for approximately 2,360 of the approximately 6,700 

facilities that reported in reporting year 2010. In reporting year 2011, EPA programmed an 

additional 1,000 checks into e-GGRT for the subparts that were reporting for the second year, 

expanding the number of checks to 2,400. EPA also programmed into e-GGRT, for 2011, 

approximately 1,300 checks for the newly-reporting subparts. During reporting year 2011, EPA 

followed up with approximately 3,440 of the approximately 8,000 facilities that reported. 

3.0 Evaluation of Alternative Verification Methods Suggested by Commenters 

The Call for Information notice specifically requested commenter input on alternative 

verification approaches that would not require reporting to EPA those data elements for which 

reporting may cause competitive harm. In response, EPA received input from 16 commenters 

suggesting alternative verification methods. The comments expressed support for the following 

verification methods: (1) self-certification, (2) EPA compliance inspection/audits only, (3) 

implementation of third party auditing or third party verification, and (4) a verification approach 

similar to EPA’s Toxic Release Inventory (TRI). These verification approaches are discussed in 

sections 3.1 through 3.4. 

3.1 Self-certification 

Given the complexity of the GHG monitoring and reporting requirements, the large number of 

reporters (over 8,000), and the need for high quality data, self-certification alone is not sufficient 

 

2

 Supplier subparts (subparts LL through PP of Part 98) apply to fossil fuel suppliers and industrial gas suppliers. The eGGRT system currently calculates equation outputs for suppliers using reported equations inputs. Subpart MM 

reporters began using e-GGRT for reporting in Reporting Year 2012. 
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3 

to ensure that GHG emissions are being reporting accurately. EPA’s experience with reviewing 

the 2010 and 2011 reporting year annual reports showed that there have been errors made in 

GHG emissions reporting. Self-certification alone would not address these errors. As mentioned 

in section 2.0 of this memorandum, EPA’s verification process for the 2010 and 2011 reporting 

years resulted in EPA identifying thousands of potential reporting errors and reporters 

resubmitting numerous corrected reports. Based on this experience, EPA maintains its original 

conclusion (refer to the October 30, 2009 final rule that initiated the GHGRP, 74 FR 56260) that 

self-certification is not sufficient to effectivelyalone, without EPA verification, would result in a 

significantly reduced ability to verify emissions and ensure compliance with the GHGRP. 

3.2 EPA Compliance Inspections/Audits 

Given that more than 8,000 facilities and suppliers in more than 40 source categories submit 

annual reports, it would be possible for EPA to visit only a very small fraction of the reporting 

facilities in any given year (e.g., even if EPA visited 100 facilities, that would be only 1.25 

percent of reporters). Therefore, relying solely on on-site compliance inspections as the primary 

method of verifying reported GHG data is impractical and would not be cost effective. Even if 

on-site audits were to identify, and result in correction of, monitoring and reporting problems at 

some of the visited facilities, there would be numerous other facilities that would not have been 

visited and that potentially would have made significant errors that would not have been 

identified and corrected. In order to ensure compliance, EPA’s verification approach needs to 

collect enough information about all facilities to allow sufficient assessment of the data quality 

prior to performing on-site audits. For example, EPA’s current verification approach allows EPA 

to identify many reporting errors and allow for their resolution without the time and expense of 

on-site visits. Using the information obtained through this process, compliance inspections are 

better targeted toward facilities or sectors most likely to have significant, unresolved verification 

issues. 

3.3 Third Party Verification 

Commenters on the Call for Information suggested third party verification as an alternative 

verification method. EPA had previously considered third party verification, but decided against 

its implementation. Refer to EPA’s full rationale for not selecting third party verification in the 

October 30, 2009 final rule (74 FR 56260). The following is a summary of this rationale, as well 

as an explanation of why EPA has determined that these reasons still apply: 

 The costs to the reporters of hiring third party verifiers would be substantial, given the 

more than 8,000 reporters under the GHGRP. If EPA were to adopt third party 

verification at this juncture, the cost to the reporters would be the same as originally 

estimated, which was thousands of dollars per reporting facility. While EPA received 

some comments on the Call for Information supporting third party verification, the vast 

majority of reporters did not submit comments supporting this approach. 
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4 

 A centralized emissions verification system, as opposed to third party verification (which 

is de-centralized), provides a greater ability for EPA to identify trends and outliers in data 

and thereby assist with targeted follow-up review. The data collected through the 

GHGRP, beyond collected inputs to emission equations, are used for verification 

purposes as well as to inform future GHG policy development. EPA has utilized the 

national data set to verify the reported emissions as well as to gain a fuller picture of the 

emissions profile of the different sectors, and will continue to do so in the future. 

 Developing the third party verification approach would require EPA to establish and 

develop emissions verification protocols and a system to qualify and accredit third party 

verifiers, as well as to develop and administer a process to ensure that verifiers hired by 

reporting facilities do not have conflicts of interest. Such a program would require EPA 

to review numerous individual conflict of interest screening determinations made each 

time a reporter hires a third party verifier, which would be time-consuming. Even if EPA 

were to partner with an existing program or organization to accredit verifiers, EPA would 

still need to develop the criteria and systems described above to implement the GHGRP 

and ensure high quality emissions verification given the unique reporting requirements of 

the GHGRP. If EPA were to adopt third party verification at this juncture, EPA would 

still have to develop the infrastructure described above to support it. Not only would this 

take several years to put into place, this approach would not build upon the success of the 

thousands of verification checks that EPA has developed over the first few years of the 

program. 

 Third party verification would potentially result in delays in the publication of the annual 

data and could result in facilities responding to inquiries from both EPA and third party 

verifiers. Under a third party verification system, a facility would contract with a third 

party verifier and provide the verifier detailed data (by March 31) so that the third party 

could perform the verification. The third party verifiers would perform on-site visits to 

many of the facilities as part of the verification process. After conducting the verification 

according to required protocols, the third party verifier would submit their findings to the 

facility with errors identified, which the facility could then correct. For existing third 

party GHG verification programs, this verification process generally takes three to six 

months. Given the large number of facilities (over 8,000) that would need to have third 

party verifications conducted, sufficient time would need to be allowed for this step. 

After receiving the data that has undergone third party verification, EPA would review 

the data prior to release. EPA would then perform additional electronic checks on the full 

set of reported data because using such checks and statistical analyses on the entire data 

set would likely reveal inconsistencies and errors in addition to those identified by the 

third party verifier. If EPA identified additional potential reporting errors, EPA would 

then contact the facility to resolve the issue. It would be inefficient for EPA to perform 

verification of the data reported by facilities at the same time as the third party 

verification is ongoing, because EPA and the third party verifier would likely be 

communicating duplicative, or possibly conflicting, requests to the same facility 

regarding potential errors. As a result, this verification would likely be conducted after 

third party verification is complete. If EPA allows the same 4-month period it has in 
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5 

previous years for these EPA verification activities prior to publication/release of data, 

then data would be released eight to ten months after the March 31 reporting date. This 

approach would not only potentially lengthen the time it would take to publish data, but 

would also potentially require facilities to respond to both third party verifiers as well as 

EPA. 

3.4 Verification in EPA’s Toxic Release Inventory (TRI) Program 

The TRI program requires annual facility level reporting of the amount of toxic chemicals 

released to the environment or otherwise managed as wastes. Some aspects of the TRI program 

are similar to the GHGRP. The TRI reports contain a signed self-certification that the 

information reported is accurate. Each facility must also keep records of how emissions were 

calculated, including supporting materials, documents, calculations, worksheets, and other 

information used. This approach is similar to the self-certification approached described in 

section 3.2, and has the same disadvantages if not used in combination with other verification 

methods. In addition, to improve the quality of the TRI data, EPA provides extensive training 

and assistance to reporters, free electronic software to facilitate electronic submission of data, 

conducts electronic data checks, and contact facilities to resolve reporting errors. However, the 

TRI is a different type of program than the GHGRP in that it does not require specific 

monitoring and calculation approaches, but rather requires that estimates be based on the best 

available information. TRI estimates can be based on monitoring, emission factors, mass 

balance, and/or other methods for over 600 chemicals and chemical categories. In contrast, the 

GHGRP prescribes a set of specific calculation methods, or equations, for individual source 

categories, processes, and emission units, so that data collected from multiple facilities are 

consistent and comparable. The data entered into these equations, which are “inputs to 

equations” data elements, often include process or production data specific to each facility’s 

operations. These “inputs to equations” data elements play an important role in EPA’s ability to 

verify GHGRP emissions and ensure compliance with the program. Therefore, given the 

additional specification provided by the GHGRP, it is necessary that EPA assess whether 

calculations were conducted correctly and according to the appropriate equation specified in Part 

98, as well as conduct additional verification checks (e.g., assessing whether appropriate 

monitoring methods were used). In conclusion, EPA determined that, whileWhile there is some 

similarity in the verification approaches of the two programs, direct application of the approach 

used for verification of the TRI program is not appropriate forwould result in a significantly 

reduced ability to verify emissions and ensure compliance with the GHGRP. 

4.0 Summary and Evaluation of an Alternative Verification Method Using an Inputs 

Verification Tool, Enhanced Recordkeeping, and Additional Reporting 

During EPA’s consideration of alternative verification methods, EPA evaluated an approach 

involving the use of an electronic inputs verification tool, enhanced recordkeeping requirements, 

and additional reporting requirements. Section 4.1 describes the inputs verification tool and 
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6 

options considered for implementation, section 4.2 describes the enhanced verification 

requirements, section 4.3 describes the additional reporting requirements, and section 4.4 

reviews the effectiveness of this verification approach at verifying emissions and ensuring 

compliance with the GHGRP. 

4.1 Description of Inputs Verification Tool and Options for Implementation

EPA evaluated the option of using a verification approach similar to the verification approach 

currently used for the supplier subparts, where data needed to calculate the outputs of the 

equations are entered into e-GGRT and used to calculate the annual GHG emission values, 

followed by EPA verification of these emission values. EPA considered using a similar approach 

whereby “inputs to equations” data elements would be entered into a new inputs verification tool 

within e-GGRT in such a way that the “inputs to equations” data elements could be used for data 

verification, but not be reported to EPA. EPA considered several approaches for implementing 

this concept. The options are discussed below.

SuchInputs Verification Tool – Deployed within E-GGRT with Inputs Saved Locally by Users

The first option EPA considered was to have an inputs verification tool could be deployed within 

e-GGRT andwith the inputs to equations saved locally by the reporters. This option would be

integrated without interrupting the current electronic reporting process. To Under this approach, 

to access this inputs verification tool, reporters would log into e-GGRT. They would enter data 

elements required for the annual report as well as specified “inputs to equations” data elements. 

The tool would operate securely within e-GGRT, as a transient process, which means that data 

entered into the tool would be temporarily saved in the tool while the reporter is actively using 

the tool, but would not be persisted (i.e., saved) within the e-GGRT database. Data entered into 

the tool would be discarded when the user’s session with e-GGRT ends. 

If the reporter were to exit the inputs verification tool prior to completing data entry or 

submitting their annual report, the tool would generate a file of entered “inputs to equations” data 

elements, and allow the reporter to download the file. The reporter would have the option to 

upload this file into the tool when they next use the tool. This option would avoid facilities from 

needing to re-enter “inputs to equations” data elements that were entered in previous e-GGRT 

sessions. 

After the reporter enters specified “inputs to equations” data elements into the inputs verification 

tool, the tool would calculate the annual GHG emissions values. The tool would use the 

following information in calculating these values: (1) “inputs to equations” data elements, (2) 

information entered into e-GGRT identifying which Part 98 calculation method was selected (if 

applicable), and (3) the selected Part 98 calculation method. Once the annual GHG emissions 

values are calculated, the values would be pre-filled into the appropriate reporting fields within 
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7 

e-GGRT. Reporters would then have the opportunity to override the annual GHG emissions 

values calculated by the tool with their own calculated value. 

Prior to annual report submittal, the inputs verification tool would conduct a series of verification 

checks, including the following: 

 Verification checks on the annual GHG emission values calculated by the inputs 

verification tool. Reporters would have the opportunity to override and revise the values 

calculated by the tool; however should this occur, the tool would note this decision, as 

well as any discrepancy, which would prompt EPA for further review after the reporter 

submits the annual report. 

 Verification checks on entered “inputs to equations” data elements. For example, the tool 

would check: (1) whether all required data were entered; (2) whether entered “inputs to 

equations” data element values are within the expected ranges for the data elements; and 

(3) whether expected relationships exist between certain “inputs to equations” data 

elements and certain other reported data elements (e.g., process raw material or 

throughput data that are not “inputs to equations” data elements). 

Some of these checks would be conducted as the reporter enters “inputs to equations” data 

elements (i.e., using “real-time” checking), and other checks would be conducted after the 

reporter has entered all specified “inputs to equations” data elements, because some algorithms 

may compare certain “inputs to equations” data elements (e.g., production quantity) to GHG 

emission values at the subpart or facility level. Also, prior to submittal of the annual report, the 

inputs verification tool would generate a verification summary containing the results of the 

verification checks. The verification summary would specify whether any potential errors, as 

described above, were identified, without specifying any information about the “inputs to 

equations” data elements. The reporter would have an opportunity to review the verification 

summary and make necessary revisions to the entered “inputs to equations” data elements and 

the reported data elements. Additionally, the tool would generate a file listing all entered “inputs 

to equations” data elements to be kept by the reporter as a record of these data (refer to section 

4.2 for further discussion of this recordkeeping requirement). 

Inputs Verification Tool – Deployed within E-GGRT with Inputs Encrypted and Saved at EPA

EPA also considered having inputs to equations data elements entered into an inputs verification 

tool within e-GGRT, encrypting the inputs to equations data, and storing the encrypted data at 

EPA. This option would have the same functionality as the inputs verification tool deployed 

within e-GGRT with the inputs to equations saved locally. The difference in approach is that the 

data would be stored at EPA in an encrypted manner. The data would be indecipherable to EPA 

and could only be decrypted with the key that would be held by representatives for that 

facility. The inputs to emissions equations data would not be submitted to EPA as part of the 

Formatted: Underline
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8 

annual report. Like the first option discussed, the inputs verification tool in this option would 

run verification checks on the inputs to equations data elements, calculate emissions, and submit 

the verification summary to EPA. Additionally, like the first option, the tool would generate a 

file listing all entered “inputs to equations” data elements to be kept by the reporter as a record of 

these data (refer to section 4.2 for further discussion of this recordkeeping requirement) 

EPA identified some benefits with the encryption option. First, users would be able to enter a 

portion of their inputs to equation data elements, log out, and then resume data entry in a later 

session without having to save inputs to equations data elements locally each time. Second, 

multiple users would be able to work on a facility’s inputs to equations concurrently or 

independently without needing to coordinate which downloaded inputs to equation file is the 

most recent file; however, as described below, multiple users would need to coordinate/share the 

encryption key so that each user could access the data entered into the inputs verification tool. 

EPA also identified several limitations with the encryption option. One factor is that members of 

the GHG reporting community may be uncomfortable with having the “inputs to equations” data 

elements stored at the EPA (in an encrypted manner). Another consideration is the encryption 

key would have to be managed by the user; if the key were lost, the data could not be recovered 

by EPA support. If this occurred, users would have to re-enter inputs to equations into the inputs 

verification tool, resulting in potentially frustrated users. A third limitation is that if a reporter 

has multiple users and/or facilities, the users would have to coordinate the facility-specific 

encryption keys among various users across multiple facilities. In order to access the data entered 

into the inputs verification tool, each user from a facility would need to know the encryption key. 

Lastly, the encryption key would be a separate “password” from the general e-GGRT log-in 

process, and users may be confused with the need to maintain two passwords, one for e-GGRT, 

and a different one for the inputs verification tool. This could result in an increased need for EPA 

to support the use of e-GGRT and the inputs verification tool. 

Inputs Verification Tool – Application Installed and Run on User’s Computer

EPA considered having the inputs verification tool be a compiled application that would need to 

be installed on an individual user’s desktop computer rather than using a web-based system. In 

this option, EPA would develop and distribute a desktop, client-side application that reporters 

would download, install, and use locally. The user would enter the inputs to equations data 

elements into the desktop application, which would perform the appropriate verification checks 

and calculations. The application would save inputs to the user’s local computer or drive and 

would transmit only the verification summary (which, as mentioned above, would not contain 

inputs to equations) to e-GGRT. Additionally, like the first two options, the tool would generate 

a file listing all entered “inputs to equations” data elements to be kept by the reporter as a record 

of these data (refer to section 4.2 for further discussion of this recordkeeping requirement). 
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A benefit of the desktop application is that all inputs to equations data elements would be 

managed by users on their own computers and no inputs to equations data elements would be 

transmitted to EPA. 

EPA identified several challenges inherent in this option, as follows. 

o Limits in functionality: A desktop application may limit the scope of verification that 

EPA could perform. EPA would not be able to easily run verification checks between the 

inputs data and the information reported to EPA through the GHGRP annual report. For 

example, in subpart X, facilities report annual production in the GHG report and monthly 

production as an input, but the data could not easily be compared if they are stored in 

different places. In addition, it would be difficult for EPA to add to or revise the 

verification checks in the application, because it would require individual users to 

perform periodic application updates requiring administrative privileges. EPA would 

need to limit the number of updates in the software, which may limit EPA from 

improving the process as enhancements are identified. 

o Burden to users: The desktop application approach would likely increase the burden to 

users. First, users would need to have administrator privileges for their machines to 

install a local, client-side application. In many corporate environments, this is not 

possible without the assistance of information technology (IT) professionals and/or 

exceptions to existing IT security policies. It is likely that the application would need to 

be updated at least once each year; for example, to add verification checks or to refine 

ranges. In these cases, users would need to download and install the new version. Third, 

it would be labor-intensive and difficult for EPA to develop a standalone application that 

replicates logic already present in e-GGRT, which assists users in such ways as guiding 

them to use the correct equations. This would most likely result in increased burden to 

users due to additional necessary follow-up by EPA during the post-submission 

verification process. 

o Burden to EPA: Developing a desktop application would likely increase the cost to EPA. 

EPA would need to develop versions of the application that are specific to different 

operating systems and then update the applications whenever the operating system 

changes. Also, if the software had problems or bugs, EPA would have to update the 

application, post the new release, and ask users to download and install it. There would 

be a significant increase in the burden to answer questions that users typically experience 

during installation. Additionally, EPA would need to develop a method to ensure the 

facilities are using the correct version of the software as updates occur. 

4.2 Description of Enhanced Recordkeeping Requirements 
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10 

Because there may be more direct follow-up verification activities with the use of the inputs 

verification tool, EPA considered two enhancements to recordkeeping requirements. First, EPA 

considered extending the record retention period from 3 to 5 years. It would be important that 

relevant records are available to EPA for follow-up activities with facilities, including on-site 

audits if necessary, regarding potential errors, discrepancies, or questions. Should an EPA 

inspector visit a facility, it would be important to be able to examine not only the current year’s 

records, but also those from previous years, because previous years’ data would provide year-toyear comparisons, which are useful for verifying the current year’s data. A 5-year record 

retention period would ensure the availability of relevant records for the follow-up activities 

described above. 

Second, EPA considered revisions to the recordkeeping format for “inputs to equations” data 

elements. Currently, reporters have the option to maintain records of their “inputs to equations” 

data elements in one or more electronic or hard copy files. Requiring reporters to maintain an 

electronic or hard copy of the single file generated by the inputs verification tool (i.e., a file 

listing all “inputs to equations” data elements entered into the tool) would ensure that EPA could 

readily access these data during site visits, enabling EPA to quickly and efficiently perform 

calculations and data checks. 

4.3 Description of Additional Reporting Requirements 

To improve the efficiency of the data verification process under this alternative approach using 

the inputs verification tool described in section 4.1 and the enhanced recordkeeping described in 

section 4.2, EPA considered supplementing the information available to EPA under the GHGRP 

by requiring reporting of additional data. Certain additional data would enable EPA to perform 

additional verification checks, thereby minimizing the number of follow-up activities. Such data 

would provide information on the activity level at the facility, emission factors, characteristics of 

carbon-containing streams, and other process information that provide key information for 

verification (e.g., data confirming that emissions are appropriate for a given activity-level, and 

data estimating expected emissions based on data provided). 

4.4 Review of Effectiveness of Using an Inputs Verification Tool, Enhanced 

Recordkeeping, and Additional Reporting To Accomplish Data Verification 

In the October 30, 2009 final rule (74 FR 56282 – 56283), EPA described its verification 

approach as the following two-step process: 

 Initial automated review of reported data, using an electronic data quality assurance 

program built into the data system, for use by reporters and EPA to help assure the 

completeness and accuracy of data. 

 Based on the initial review results, follow up with facilities regarding potential errors, 

discrepancies, or questions, including on-site audits. 
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11 

The use of the inputs verification tool to conduct verification checks on the “inputs to equations” 

data elements (as described in section 4.1) would build on EPA’s experience with electronic 

reporting and verification during the first two years of the GHGRP. As discussed in more detail 

in section 2.0, for reporting years 2010 and 2011, EPA used electronic verification checks to 

verify data and follow up with thousands of facilities. For 2011 alone, based on 3,700 types of 

checks, EPA followed up with approximately 3,440 of the approximately 7,900 reporting 

facilities. 

The inputs verification tool utilizes the same approach that EPA currently uses for calculating 

and verifying data submitted for supplier subparts (and starting in reporting year 2012, inputs to 

emission equations for which the reporting deadline was deferred until 2013), except that eGGRT would not retain the “inputs to equations” data elements entered into the tool, as 

described in section 4.1. Once the annual report is submitted, EPA would review the verification 

summary generated by the inputs verification tool, along with verification summaries that are 

currently generated using data currently collected through the annual report. By requiring use of 

the inputs verification tool, EPA would have the additional certainty that reported annual GHG 

emissions values either were calculated correctly (because the values calculated by the tool were 

submitted to EPA) or that EPA would be made aware that there were discrepancies between 

values calculated by the tool and values submitted to EPA. This additional certainty, combined 

with the additional information provided by the range and algorithm verification checks 

conducted on the “inputs to equations” data elements themselves, would provide EPA with the 

information necessary to conduct further verification once the annual report is submitted. 

Once data verification within the inputs verification tool is completed and the annual report is 

submitted, EPA would conduct the same verification checks that it currently conducts (following 

annual report submittal) on data reported via e-GGRT and additional verification checks using 

the information provided by the additional reporting requirements. Regarding any needed followup with facilities, the enhanced recordkeeping requirements described in section 4.2 (i.e., 5-year 

retention period and uniform format) would ensure that EPA has adequate time to efficiently 

examine the “inputs to equations” data elements on-site. 

5.0 Summary

EPA identified the alternative verification approach consisting of the use of the inputs 

verification tool, enhanced recordkeeping, and additional reporting as a viable alternative 

approach to verifying data reported under the 25 subparts being evaluated in this memorandum. 

This approach would ensure effective verification of reported emissions and compliance with the 

program.
Attachment K 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

6560.50 

ENVIRONMENTAL PROTECTION AGENCY 

40 CFR Part 98 

[EPA-HQ-OAR-2010-0929; FRL-9801-2] 

RIN 2060-AQ81 

Revisions to Reporting and Recordkeeping Requirements, and Proposed Confidentiality 

Determinations under the Greenhouse Gas Reporting Program 

EO12866_GHGRP Part 98 2060 AQ81 NPRM 20120326 

AGENCY: Environmental Protection Agency (EPA). 

ACTION: Proposed rule. 

SUMMARY: The EPA is proposing amendments to reporting and recordkeeping requirements 

and an alternative verification approach for the Greenhouse Gas Reporting Program. This action 

addresses concerns about the potential release of certain data that are inputs to emission 

equations for which the reporting deadline was deferred until March 31, 2015 while maintaining 

the EPA’s ability to verify emissions and ensure compliance with the Greenhouse Gas Reporting 

Program. In addition, the EPA is proposing confidentiality determinations for the newly 

proposed data elements in this action. 

DATES: Comments. Comments must be received on or before [INSERT THE DATE 60 DAYS 

AFTER PUBLICATION OF THIS PROPOSED RULE IN THE FEDERAL REGISTER]. 

Public Hearing. The EPA will hold a public hearing on this proposed rule if requested. 

Requests for a hearing must be made by [INSERT THE DATE 7 DAYS AFTER 

PUBLICATION OF THIS PROPOSED RULE IN THE FEDERAL REGISTER]. Contact the 

person listed in the “FOR FURTHER INFORMATION CONTACT” section by [INSERT 

THE DATE 7 DAYS AFTER PUBLICATION OF THIS PROPOSED RULE IN THE 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

Page 2 of 98 

FEDERAL REGISTER] to request a public hearing. If a hearing is requested, the EPA will 

announce the details, including specific dates, times, addresses and contact information for the 

hearing, in a separate Federal Register notice. 

ADDRESSES: Submit your comments, identified by Docket ID No. EPA–HQ–OAR–2010-

0929, by one of the following methods: 

 Federal eRulemaking Portal: http:// www.regulations.gov. Follow the online instructions 

for submitting comments. 

 Email: GHGReportingCBI@epa.gov 

 Fax: (202) 566–1741. 

 Mail: Environmental Protection Agency, EPA Docket Center (EPA/DC), Mailcode 

6102T, Attention Docket ID No. EPA–HQ–OAR–2010-0929, 1200 Pennsylvania 

Avenue, NW., Washington, DC 20460. 

 Hand Delivery: EPA Docket Center, Public Reading Room, EPA West Building, Room 

3334, 1301 Constitution Avenue, NW., Washington, DC 20004. Such deliveries are only 

accepted during the Docket’s normal hours of operation, and special arrangements should 

be made for deliveries of boxed information. 

Instructions: Direct your comments to Docket ID No. EPA–HQ–OAR–2010-0929. The 

EPA’s policy is that all comments received will be included in the public docket without change 

and may be made available online at http://www.regulations.gov, including any personal 

information provided, unless the comment includes information claimed to be confidential 

business information (CBI) or other information whose disclosure is restricted by statute. 
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Page 3 of 98 

Do not submit information that you consider to be CBI or otherwise protected through 

http://www.regulations.gov or email. Send or deliver information identified as CBI to only the 

mail or hand/courier delivery address listed above, attention: Docket ID No. EPA–HQ–OAR–

2010–0929. The http://www.regulations.gov website is an “anonymous access” system, which 

means the EPA will not know your identity or contact information unless you provide it in the 

body of your comment. If you send an email comment directly to the EPA without going through 

http://www.regulations.gov your email address will be automatically captured and included as 

part of the comment that is placed in the public docket and made available on the Internet. If you 

submit an electronic comment, the EPA recommends that you include your name and other 

contact information in the body of your comment and with any disk or CD–ROM you submit. If 

the EPA cannot read your comment due to technical difficulties and cannot contact you for 

clarification, the EPA may not be able to consider your comment. Electronic files should avoid 

the use of special characters, any form of encryption, and be free of any defects or viruses. 

Docket: All documents in the docket are listed in the http://www.regulations.gov index. 

Although listed in the index, some information is not publicly available, e.g., CBI or other 

information whose disclosure is restricted by statute. Certain other material, such as copyrighted 

material, will be publicly available only in hard copy. Publicly available docket materials are 

available either electronically in http://www.regulations.gov or in hard copy at the Air Docket, 

EPA/DC, EPA West, Room B102, 1301 Constitution Ave., NW., Washington, DC. This Docket 

Facility is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. 

The telephone number for the Public Reading Room is (202) 566–1744, and the telephone 

number for the Air Docket is (202) 566–1742. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

Page 4 of 98 

FOR FURTHER GENERAL INFORMATION CONTACT: Carole Cook, Climate Change 

Division, Office of Atmospheric Programs (MC–6207J), Environmental Protection Agency, 

1200 Pennsylvania Ave., NW., Washington, DC 20460; telephone number: (202) 343–9263; fax 

number: (202) 343–2342; email address: GHGreporting@epa.gov. For technical information, 

contact the Greenhouse Gas Reporting Rule Helpline at: 

http://www.epa.gov/climatechange/emissions/ghgrule_contactus.htm. Alternatively, contact 

Carole Cook at 202–343–9263. 

Worldwide Web (WWW). In addition to being available in the docket, an electronic copy 

of this proposal, memoranda to the docket, and all other related information will also be 

available through the WWW on EPA’s greenhouse gas reporting rule Web site at 

http://www.epa.gov/climatechange/emissions/ghgrulemaking.html. 

SUPPLEMENTARY INFORMATION: 

Additional Information on Submitting Comments: To expedite review of your comments 

by Agency staff, you are encouraged to send a separate copy of your comments, in addition to 

the copy you submit to the official docket, to Carole Cook, Climate Change Division, Office of 

Atmospheric Programs (MC–6207J), Environmental Protection Agency, 1200 Pennsylvania 

Ave., NW., Washington, DC, 20460, telephone (202) 343–9263, email 

GHGReportingCBI@epa.gov. 

Regulated Entities. This proposed rule revision on reporting and recordkeeping 

requirements and verification procedures would affect entities that must submit annual 

greenhouse gas (GHG) reports under the Greenhouse Gas Reporting Program (40 CFR part 98). 

The Administrator has determined that 40 CFR part 98 is subject to the provisions of Clean Air 

Act (CAA) section 307(d). See CAA section 307(d)(1)(V) (the provisions of CAA section 307(d) 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 

Page 5 of 98 

apply to “such other actions as the Administrator may determine”). Entities affected by this 

proposal are owners or operators of facilities that are direct emitters of greenhouse gases 

(GHGs), which include those listed in Table 1 of this preamble: 

Table 1. Examples of Affected Entities by Category 

Category NAICS Examples of affected facilities 

General Stationary Fuel 

Combustion Sources 

 Facilities operating boilers, process heaters, 

incinerators, turbines, and internal combustion engines. 

321 Manufacturers of lumber and wood products. 

322 Pulp and paper mills. 

325 Chemical manufacturers. 

324 Petroleum refineries and manufacturers of coal 

products. 

316, 326, 

339 

Manufacturers of rubber and miscellaneous plastic 

products. 

331 Steel works, blast furnaces. 

332 Electroplating, plating, polishing, anodizing, and 

coloring. 

336 Manufacturers of motor vehicle parts and accessories. 

221 Electric, gas, and sanitary services. 

622 Health services. 

611 Educational services. 

325193 Ethyl alcohol manufacturing facilities. 

311611 Meat processing facilities 

311411 Frozen fruit, juice, and vegetable manufacturing 

facilities. 

311421 Fruit and vegetable canning facilities. 

Adipic Acid Production 325199 Adipic acid manufacturing facilities. 

Aluminum Production 331312 Primary aluminum production facilities 

Ammonia 

Manufacturing 

325311 Anhydrous and aqueous ammonia production facilities. 

Cement Production 327310 Portland Cement manufacturing plants. 

Ferroalloy Production 331112 Ferroalloys manufacturing facilities. 

Fluorinated GHG 

Production 

325120 Industrial gases manufacturing facilities. 

Glass Production 327211 Flat glass manufacturing facilities. 

327213 Glass container manufacturing facilities. 

327212 Other pressed and blown glass and glassware 

manufacturing facilities. 

HCFC-22 Production 

and HFC-23 

Destruction 

325120 Chlorodifluoromethane manufacturing facilities. 
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Category NAICS Examples of affected facilities 

Hydrogen Production 325120 Hydrogen production facilities 

Iron and Steel 

Production 

331111 Integrated iron and steel mills, steel companies, sinter 

plants, blast furnaces, basic oxygen process furnace 

shops. 

Lead Production 331419 Primary lead smelting and refining facilities. 

331492 Secondary lead smelting and refining facilities. 

Lime Production 327410 Calcium oxide, calcium hydroxide, dolomitic hydrates 

manufacturing facilities. 

Nitric Acid Production 325311 Nitric acid production facilities 

Petrochemical 

Production 

32511 Ethylene dichloride production facilities. 

325199 Acrylonitrile, ethylene oxide, methanol production 

facilities. 

325110 Ethylene production facilities. 

325182 Carbon black production facilities. 

Petroleum and Natural 

Gas Systems 1

486210 Pipeline transportation of natural gas. 

221210 Natural gas distribution facilities. 

211 Extractors of crude petroleum and natural gas. 

211112 Natural gas liquid extraction facilities. 

Petroleum Refineries 324110 Petroleum refineries. 

Phosphoric Acid 

Production 

325312 Phosphoric acid manufacturing facilities. 

Pulp and Paper 

Manufacturing 

322110 Pulp mills. 

322121 Paper mills. 

322130 Paperboard mills. 

Silicon Carbide 

Production 

327910 Silicon carbide abrasives manufacturing facilities. 

Soda Ash 

Manufacturing 

325181 Alkalies and chlorine manufacturing facilities. 

212391 Soda ash, natural, mining and/or beneficiation. 

Titanium Dioxide 

Production 

325188 Titanium dioxide manufacturing facilities. 

Zinc Production 331419 Primary zinc refining facilities. 

331492 Zinc dust reclaiming facilities, recovering from scrap 

and/or alloying purchased metals. 

311411 Frozen fruit, juice and vegetable manufacturing 

facilities. 

311421 Fruit and vegetable canning facilities. 

Wastewater Treatment1 322110 Pulp mills. 

322121 Paper mills. 

322122 Newsprint mills. 

322130 Paperboard mills. 

311611 Meat processing facilities. 

311411 Frozen fruit, juice and vegetable manufacturing 

facilities. 

311421 Fruit and vegetable canning facilities. 
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Category NAICS Examples of affected facilities 

325193 Ethanol manufacturing facilities. 1

 The EPA is not proposing amendments related to these categories; however, these categories were evaluated in the 

EPA’s analysis of the potential impact from the release of inputs to emission equations for which reporting was 

deferred to March 31, 2015. Refer to Section 1.B of this preamble for further discussion of this evaluation. 

Table 1 of this preamble is not intended to be exhaustive, but rather provides a guide for 

readers regarding facilities and suppliers likely to be affected by this action. Types of facilities 

other than those listed in this table may also be affected by this action. To determine whether you 

are affected by this action, you should carefully examine the applicability criteria found in 40 

CFR part 98, subpart A or the relevant criteria in the subparts. If you have questions regarding 

the applicability of this action to a particular facility or supplier, consult the person listed in the 

preceding FOR FURTHER GENERAL INFORMATION CONTACT section. 

Many facilities that are affected by 40 CFR part 98 have GHG emissions from multiple 

source categories listed in Table 1 of this preamble. 

Acronyms and Abbreviations. The following acronyms and abbreviations are used in this 

document. 

BAMM Best Available Monitoring Methods 

CAA Clean Air Act 

CO2 carbon dioxide 

CBI confidential business information 

CEMS Continuous Emission Monitoring System 

CFR Code of Federal Regulations 

e-GGRT Electronic Greenhouse Gas Reporting Tool 

EPA U.S. Environmental Protection Agency 

FR Federal Register 

GHG greenhouse gas 

GHGRP Greenhouse Gas Reporting Program 

HCFC-22 chlorodifluoromethane 

HFC hydrofluorocarbons 

HQ Headquarters 
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ICR Information Collection Request 

MW megawatt 

NAICS North American Industry Classification System 

NTTAA National Technology Transfer and Advancement Act 

OMB Office of Management & Budget 

RFA Regulatory Flexibility Act 

UMRA Unfunded Mandates Reform Act 

U.S. United States 

WWW Worldwide Web 

TABLE OF CONTENTS 

I. Executive Summary and Background

A. Executive Summary

B. Background

C. Subparts Covered in this Proposed Rule

D. Legal Authority

II. Summary of Proposed Changes to Part 98 Reporting and Recordkeeping Requirements

A. Proposed Use of Inputs Verification Tool

B. Proposed Revisions to Reporting of Data Elements Deferred until 2015

C. Proposed Changes to Recordkeeping Requirements

D. Proposed New Data Elements to be Reported

III. Rationale for Proposed Changes to Reporting and Recordkeeping Requirements

A. Proposed Inputs Verification Tool and Amendment to Reporting Requirements

B. Proposed Revisions to Recordkeeping Requirements

C. Proposed Requirement to Report Additional Data

IV. Confidentiality Determination for Proposed New Data Elements to be Reported

V. Impacts of the Proposed Rule

A. How were the costs of this proposed rule estimated?

B. Additional Impacts of the Proposed Amendments

VI. Statutory and Executive Order Reviews

A. Executive Order 12866: Regulatory Planning and Review and Executive Order 13563: 

Improving Regulation and Regulatory Review

B. Paperwork Reduction Act

C. Regulatory Flexibility Act (RFA)

D. Unfunded Mandates Reform Act (UMRA)

E. Executive Order 13132: Federalism

F. Executive Order 13175: Consultation and Coordination with Indian Tribal Governments.

G. Executive Order 13045: Protection of Children from Environmental Health Risks and Safety 

Risks
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Page 9 of 98 

H. Executive Order 13211: Actions that Significantly Affect Energy Supply, Distribution, or Use

I. National Technology Transfer and Advancement Act

J. Executive Order 12898: Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations

I. Executive Summary and Background 

A. Executive Summary 

The Greenhouse Gas Reporting Program (GHGRP) collects greenhouse gas data from 41 

source categories and currently has received 2 to 3 years of data from these sources. Greenhouse 

gas emissions from direct emitters are calculated using a variety of methods, including direct 

measurement, mass balance, and the use of emission factors. Reporters not using direct 

measurement must use equations to calculate emissions. The inputs to these emission equations 

often include process or production data that are specific to each facility’s operations. These 

inputs to emission equations play an important role in the Agency’s ability to verify facility-level 

emissions and ensure compliance with the program. 

On July 7, 2010, the EPA proposed confidentiality determinations for the majority of data 

elements required to be reported under the GHGRP, as well as for the majority of source 

categories covered by the program. In the July 7, 2010 action, the EPA proposed that data 

elements categorized as “inputs to emission equations” are emission data. The CAA precludes 

“emission data” from being treated as confidential. 

Based on subsequent industry concerns regarding the potential release of data elements 

categorized as “inputs to emission equations,” the EPA deferred reporting of these data elements 

(see August 25, 2011 final action, 76 FR 53057) to allow the EPA to complete its evaluation of 

the potential impact from the public release of these data elements (see 76 FR 53060) and, if 

appropriate, to propose amendments to Part 98 (see 75 FR 81355). Based on the analysis 

conducted, today’s action proposes amendments to reporting and recordkeeping requirements 
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and an alternative verification approach for certain reporters subject to 24 subparts for which the 

reporting deadline for inputs to emission equations was deferred until 2015 and disclosure 

concerns have been identified. Proposed amendments include: 

 Adding a requirement for certain reporters under 24 subparts to use an EPA-provided 

inputs verification tool. For these subparts, the designated inputs to emission equations 

for which reporting was deferred to 2015 and disclosure concerns have been identified 

would be entered into the tool.1 The tool would calculate the emissions and perform 

electronic verification. The tool would not retain the entered inputs (i.e., the inputs would 

not be reported to EPA); instead, the tool would conduct certain checks (e.g., accuracy of 

the inputs) at the time of data entry and generate a verification summary. The verification 

summary, which would be accessible to the EPA once the annual report is submitted, 

would provide the EPA with information to conduct further verification if necessary. 

 For reporters required to use the inputs verification tool, changing the required format for 

maintaining records of these inputs to emission equations. 

 For reporters required to use the inputs verification tool, lengthening the record retention 

period from 3 to 5 years for all records maintained under Part 98 (including subparts that 

do not require the use of the tool). 

 For certain reporters required to use the inputs verification tool, adding new data 

elements to be reported for the EPA’s verification purposes, and proposing 

confidentiality determinations for the new data elements proposed to be reported. 

 

1

 Under this proposal, the inputs verification tool would not be required to be used by reporters for any reported GHG for 

which the reporter uses a CEMS or an EPA-approved alternative method (as allowed under sections 98.33(a)(5), 98.53(a)(2), and 

98.223(a)(2) of Part 98) to calculate the reported GHG value, rather than using "inputs to equations" data elements and the 

associated EPA-provided calculation methodologies to calculate the reported GHG value. 
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 For reporters required to use the inputs verification tool, removing the requirement to 

report the inputs to emission equations for which reporting was deferred to 2015 and 

disclosure concerns have been identified, and requiring these data to be kept as records. 

Reporting requirements for inputs to equations for which disclosure concerns were not 

identified (and would still be useful to EPA) are not proposed to be amended in this action. For 

these inputs to equations, the deferral would expire in March 2015, and the EPA would collect 

these data. 

The proposed changes in this action build on the EPA’s experience and success with 

electronic reporting and verification during the first 3 years of the GHGRP. By requiring the use 

of the inputs verification tool, which would calculate GHG emissions based on the inputs to the 

emissions equations, the EPA would have the ability to identify facilities that potentially reported 

emissions incorrectly. This, combined with additional verification checks of the inputs to 

emission equations that the inputs verification tool would conduct (during the process of 

reporters entering data into the inputs verification tool), would provide the EPA with information 

necessary to conduct further verification once the annual report is submitted. This alternative 

verification approach, including the changes to the recordkeeping requirements and additional 

reporting requirements, would provide an alternative to collecting certain data elements for 

which reporting was deferred to March 31, 2015 and disclosure concerns have been identified, 

while maintaining the EPA’s ability to verify data and ensure compliance with the GHGRP. 

B. Background

On October 30, 2009, the EPA published the Greenhouse Gas Reporting Rule, 40 CFR 

part 98, requiring annual reporting of GHG data from a broad range of industry sectors (74 FR 

56260). Under the Greenhouse Gas Reporting Rule and its subsequent amendments (hereinafter 
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referred to as “Part 98”), the EPA requires annual reporting of data from certain facilities and 

suppliers above specified emission or quantity supplied thresholds. On July 7, 2010 (75 FR 

39094) and subsequent proposals (77 FR 1434, January 10, 2012; 77 FR 10434, February 22, 

2012), we proposed confidentiality determinations for the data elements required to be reported. 

The confidentiality of each reported data element was determined using a two-step approach: (1) 

grouping data elements into 11 data categories (e.g., inputs to emission equations, emissions, and 

unit/process operating characteristics that are not inputs to emission equations for direct emitter 

source categories); and (2) making confidentiality determinations either categorically or on an 

individual data elements basis. Refer to both the July 7, 2010 proposal (75 FR 39097) and the 

May 26, 2011 final rule (76 FR 30785 - 30786) for more detailed descriptions of this process. 

Refer to the May 26, 2011 final rule also for a discussion of individual data element 

confidentiality determinations. We have finalized confidentiality determinations for data 

elements except those in the “inputs to emission equations” category (May 26, 2011, 76 FR 

30782; August 13, 2012, 77 FR 48072; and August 24, 2012, 77 FR 51477)2

. For data elements 

in this category, we proposed that they meet the definition of “emission data” under 40 CFR 

2.301(a)(2)(i). Because emission data are not entitled to confidential treatment under section 

114(c) of the Clean Air Act, we did not evaluate whether such data elements would qualify as 

CBI, including whether disclosure would likely cause substantial competitive harm to the 

reporting facilities. (75 FR 39105 and 39108, July 7, 2010). 

Following our proposal that data elements assigned to the “inputs to emission equations” 

category are not entitled to confidential treatment, we received numerous industry comments 

asserting that competitive harm would result from public release of many of these data elements. 

 

2

 There are a small number of data elements (besides data elements categorized as “inputs to emission equations”) for which we 

have not made a final confidentiality determinations because we concluded that a determination of confidentiality for the data 

element should be made on a case-by-case facility basis (according to individual circumstances of the facility). 
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We determined that “these concerns warranted an in-depth evaluation of the potential impact 

from the release of inputs to emission equations.” (76 FR 53060; August 25, 2011). In a notice 

dated December 27, 2010, we issued a call for information (75 FR 81354) requesting additional 

information to assist us in conducting our evaluation. To allow sufficient time to complete this 

evaluation through notice and comment, we deferred the reporting deadline for data elements 

assigned to the “inputs to emission equation” category. Reporting of certain of these data 

elements was deferred to March 31, 2013, as specified in Table A-6 of subpart A; and reporting 

of the remainder of these data elements was deferred to March 31, 2015, as specified in Table A7 of subpart A (see the August 25, 2011 final rule, 76 FR 53057). 

Our process for evaluating competitive harm was documented in the final deferral notice 

(August 25, 2011, 76 FR 53057) and the accompanying memorandum entitled “Process for 

Evaluating and Potentially Amending Part 98 Inputs to Emission Equations” (Docket ID EPAHQ-OAR-2010-0929). As discussed in the final deferral notice and memorandum, our evaluation 

involved a four-step process, as follows: 

 Step 1: Determine whether each data element assigned to the “inputs to emission 

equations” category is already publicly available. 

 Step 2: For data elements assigned to the “inputs to emission equations” category that are 

not publicly available, evaluate whether disclosure of the information is likely to result in 

substantial competitive harm. 

 Step 3: For data elements assigned to the “inputs to emission equations” category that are 

likely to cause substantial competitive harm if disclosed, evaluate potential alternative 

calculation methods. 
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 Step 4: For data elements assigned to the “inputs to emission equations” category that are 

likely to cause substantial competitive harm if disclosed, evaluate potential alternative 

verification methods. 

Based on each step of the four-step evaluation process, an analysis of all data elements 

for which reporting was deferred to March 31, 2015 was conducted.3

 The results of the analysis 

are documented in four memoranda, as follows: 

 “Evaluation of Public Availability of Inputs to Emission Equations for which Reporting 

was Deferred to March 31, 2015.” 

 “Evaluation of Competitive Harm from Disclosure of ’Inputs to Equations’ Data 

Elements Deferred to March 31, 2015” 

 “Evaluation of Alternative Calculation Methods.” 

 “Evaluation of Alternative Verification Approaches For Greenhouse Gas Reporting Rule 

Subparts for which Reporting of Inputs to Emission Equations was Deferred to March 31, 

2015.” 

These memoranda are available in EPA docket ID No. EPA–HQ–OAR–2010-0929. 

Based on the results of these analyses, the EPA is proposing in today’s action to make certain 

amendments to Part 98. 

C. Subparts Covered in this Proposed Rule

 

3

 Based on the same four-step process, we also evaluated all data elements for which reporting was deferred to 

March 31, 2013 (Table A-6 to Part 98) and took no further action. As a result, applicable facilities were required to 

report these data by April 1, 2013. For a discussion of this evaluation, refer to the EPA's memorandum "Summary of 

Evaluation of Greenhouse Gas Reporting Program (GHGRP) Part 98 “Inputs to Emission Equations” Data Elements 

Deferred Until 2013" (December 17, 2012), available at 

http://www.epa.gov/ghgreporting/documents/pdf/2012/documents/2013-inputs-memo.pdf. 
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The proposed amendments affect all subparts listed in Table 2 of this preamble. Table 2 

includes most of the subparts with inputs to emission equations for which the reporting deadline 

was deferred until 2015. Subpart W (Petroleum and Natural Gas Systems), subpart II (Industrial 

Wastewater Treatment), and subpart C (only certain combustion units associated with certain 

electric generators connected and able to deliver power to the local or regional electric power 

grid, as specified in Table 2) are not included in Table 2 because none of the inputs to emission 

equations required to be reported by reporters in these source categories are being amended, as 

no disclosure concerns were identified. Subpart I of Part 98 is not included in Table 2 because 

reporting of inputs to emission equations under this subpart was addressed under a separate 

rulemaking proposed on October 16, 2012 (77 FR 63538). Additionally, parts of these proposed 

rule amendments would affect subparts not listed in Table 2. Specifically, for reporters subject to 

both a subpart listed in Table 2 and a subpart of Part 98 not listed in this table, the proposed 

revision to the recordkeeping duration would apply to the records required for all Part 98 

subparts (to which the reporter is subject). Refer to Sections II.C and III.B of this preamble for 

further discussion of this proposed amendment. 

Table 2. Subparts Affected by the Proposed Amendments.1,2

Subpart 

C—General Stationary Fuel Combustion except 

Specified Stationary Fuel Combustion Sources 

Connected to Certain Electric Generators that are 

Connected and Able to Deliver Power to the Local 

or Regional Electric Power Grid 3

S—Lime Manufacturing 

E—Adipic Acid Production U—Miscellaneous Uses of Carbonate 

F—Aluminum Production V—Nitric Acid Production 

G—Ammonia Manufacturing X—Petrochemical Production 

H—Cement Production Y—Petroleum Refineries 

K—Ferroalloy Production Z—Phosphoric Acid Production 

L—Fluorinated Gas Production AA—Pulp and Paper Manufacturing 

N—Glass Production BB—Silicon Carbide Production 
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Subpart 

O—HCFC–22 Production and HFC–23 

Destruction 

CC—Soda Ash Manufacturing 

P—Hydrogen Production EE—Titanium Dioxide Production 

Q—Iron and Steel Production GG—Zinc Production 

R—Lead Production TT—Industrial Waste Landfills 1

 Certain proposed amendments affect other subparts not listed in this table as follows: for reporters subject to both a 

subpart listed in this table and a subpart of Part 98 not listed in this table, the proposed revision to the recordkeeping 

duration would apply to the records required for all Part 98 subparts to which the reporter is subject. 2

 Under this proposal, the inputs verification tool would not be required to be used by reporters for any reported 

GHG for which the reporter uses a CEMS or an EPA-approved alternative method (as allowed under 40 CFR 

98.33(a)(5), 98.53(a)(2), and 98.223(a)(2)) to calculate the reported GHG value, rather than using "inputs to 

equations" data elements and the associated EPA-provided calculation methodologies to calculate the reported GHG 

value.

3 The stationary fuel combustion sources (e.g., individual units, aggregations of units, common pipes, or common 

stacks) not affected by the proposed amendments include those meeting both of the following criteria: (1) the 

stationary fuel combustion source contains at least one combustion unit connected to a fuel-fired electric generator 

that has been granted access by the Public Utilities Commission to deliver power to the local or regional electric 

power grid (excluding generators connected to combustion units that are subject to subpart D of Part 98); and (2) the 

stationary fuel combustion source is located at a facility for which the sum of the nameplate capacities for all such 

electric generators is greater than or equal to 1 megawatt electric output. Refer to Section III.A.3 of this preamble 

for a discussion of the EPA’s rationale for proposing that combustion units meeting these criteria not be affected by 

the proposed amendments. 

D. Legal Authority

The EPA is proposing these rule amendments under its existing CAA authority provided 

in CAA section 114. As stated in the preamble to the 2009 final GHG reporting rule (74 FR 

56260, October 30, 2009), CAA section 114(a)(1) provides the EPA broad authority to require 

the information proposed to be gathered by this rule because such data would inform and are 

relevant to the EPA’s carrying out a wide variety of CAA provisions. See the preambles to the 

proposed (74 FR 16448, April 10, 2009) and final Part 98 (74 FR 56260, October 30, 2009) for 

further information. 

In addition, pursuant to sections 114, 301, and 307 of the CAA, the EPA is proposing 

confidentiality determinations for the new data elements proposed in this notice. Section 114(c) 

of the CAA requires that the EPA make publicly available information obtained under CAA 

section 114 except for information (excluding emission data) that qualifies for confidential 
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treatment. The Administrator has determined that this action (Part 98 amendment and 

confidentiality determinations) is subject to the provisions of CAA section 307(d). 

II. Summary of Proposed Changes to Part 98 Reporting and Recordkeeping Requirements 

The EPA is proposing revisions to the reporting and recordkeeping requirements in Part 

98 and alternative verification procedures that would apply to certain reporters subject to any of 

the 24 subparts listed in Table 2 of this preamble. Section II.A of this preamble summarizes a 

proposed new requirement for these reporters if they use inputs to emission equations for which 

reporting was deferred to March 31, 2015 (hereafter referred to as “inputs to equations” data 

elements) to calculate reported GHGs. Such reporters would be required to use an EPA-provided 

electronic inputs verification tool to calculate emissions using data elements for which reporting 

was deferred to March 31, 2015 (hereafter referred to as “inputs to equations” data elements), 

allowing the EPA to complete electronic verification of reported GHG emissions data without 

the need to collect “inputs to equations” data elements for which disclosure concerns have been 

identified. Section II.B of this preamble summarizes the EPA’s proposal to remove, for these 

reporters, the requirement to report many “inputs to equations” data elements. Section II.C of 

this preamble summarizes proposed revisions to the recordkeeping requirements for these 

reporters. Section II.D of this preamble summarizes proposed new reporting requirements for 

these reporters. Section III of this preamble explains the rationale for the proposed amendments 

summarized in Sections II.A through II.D of this preamble. Section IV of this preamble presents 

the EPA’s proposed confidentiality determinations for proposed new data elements and the 

EPA’s rationale for these determinations. Section V of this preamble presents the cost and 

impacts associated with these proposed amendments. 

A. Proposed Use of Inputs Verification Tool 
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The EPA is proposing that facilities subject to the subparts listed in Table 2 of this 

preamble and that use “inputs to equations” data elements to calculate reported GHGs use an 

electronic inputs verification tool being developed by the EPA, which would calculate and verify 

GHG emissions. Refer to Section III.A.1 of this preamble for a web-link to the EPA’s “pilot” 

inputs verification tool for one subpart of Part 98, available during the public comment period for 

this rulemaking. The “pilot” demonstrates how the tool would work within the EPA’s Electronic 

Greenhouse Gas Reporting Tool (e-GGRT), as well as the types of verification checks that 

would be conducted. The inputs verification tool would be deployed within e-GGRT and would 

be integrated without interrupting the current electronic reporting process. While reporters enter 

data into e-GGRT that are required to be reported in the annual report, reporters would also enter 

into e-GGRT (via the inputs verification tool) the “inputs to equations” data elements that the 

EPA is proposing to remove from the reporting requirements. The tool would use the entered 

“inputs to equations” data elements to calculate the equation outputs, conduct electronic 

verification checks on the “inputs to equations” data elements, and generate a verification 

summary. The tool would not retain the entered “inputs to equations” data elements for which 

the EPA is proposing that the reporting requirement be removed. Accordingly, the EPA would 

not have access to these “inputs to equations” data elements. Instead, the EPA would rely on the 

verification summary, which would become accessible to the EPA when annual reports are 

submitted, as a first step for conducting verification once the annual report is submitted. 

Sources subject to multiple subparts under Part 98 would be required to use the inputs 

verification tool for only those subparts listed in Table 2 of this preamble. The EPA is proposing 

that reporters use this tool starting with reporting year 2014. Refer to Section III.A of this 

preamble for further discussion of this proposed requirement. 
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This proposed requirement to use the inputs verification tool is specified in 40 CFR 98.5, 

subpart A. Reporters would determine applicability under this new requirement based on a 

proposed new Table A-8 to Part 98, which lists all calculation methods under Part 98 for which 

the inputs verification tool must be used. Reporters calculating reported GHGs using a 

calculation method specified in proposed Table A-8 would be required to enter into the inputs 

verification tool “inputs to equations” data elements that have been removed from the reporting 

requirements. 

B. Proposed Revisions to Reporting of Data Elements Deferred until 2015

The EPA is proposing to remove the reporting requirement for 440 “inputs to equations” 

data elements in the subparts listed in Table 2 of this preamble. Table 3 of this preamble provides 

a summary of how many data elements would be removed from reporting for each subpart. Refer 

to Table 1 in the memorandum “List of ‘Inputs to Equations’ Data Elements Proposed Not To Be 

Reported” (refer to Docket ID No. EPA–HQ–OAR–2010-0929) for a complete list of these 440 

data elements. For all remaining “inputs to equations” data elements not represented in Table 3 

of this preamble, the EPA is not amending these reporting requirements and would, therefore, let 

the deferral of these data elements expire on March 31, 2015. As a result, by March 31, 2015, all 

of the “inputs to equations” data elements for subpart W (Petroleum and Natural Gas Systems), 

Subpart II (Industrial Wastewater Treatment), and the additional “inputs to equations” data 

elements for which reporting is not proposed to be removed as indicated in Table 3 of this 

preamble, would be reported for future reporting years and for all prior reporting years, including 

reporting year 2014. For a list of these “inputs to equations” data elements that would be 

reported, refer to Table 2 of the memorandum cited above. 
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Table 3. Subparts for Which Reporting Requirements are Amended 

Subpart

Number of “Inputs to 

Equations” Data Elements 

Number of “Inputs to 

Equations” Data Elements 

Proposed Not to Be 

Reported 

C—General Stationary Fuel 

Combustion Except Specified 

Stationary Fuel Combustion 

Sources Connected to Certain 

Electric Generators Connected 

and Able to Deliver Power to 

the Local or Regional Power 

Grid2

261

 261

E—Adipic Acid Production 21 11 

F—Aluminum Production 29 29 

G—Ammonia Manufacturing 8 8 

H—Cement Production 16 14 

K—Ferroalloy Production 13 13 

L—Fluorinated Gas Production 55 46 

N—Glass Production 3 3 

O—HCFC–22 Production and 

HFC–23 Destruction 

15 12 

P—Hydrogen Production 7 7 

Q—Iron and Steel Production 93 92 

R—Lead Production 10 10 

S—Lime Manufacturing 9 9 

U—Miscellaneous Uses of 

Carbonate 

6 6 

V—Nitric Acid Production 21 6 

X—Petrochemical Production 21 21 

Y—Petroleum Refineries 80 75 

Z—Phosphoric Acid Production 4 4 

AA—Pulp and Paper 

Manufacturing 

31 28 

BB—Silicon Carbide 

Production 

3 3 

CC—Soda Ash Manufacturing 10 4 

EE—Titanium Dioxide 

Production 

2 2 

GG—Zinc Production 8 8 

TT—Industrial Waste Landfills 3 3 
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1 Includes one “inputs to equations” data element, 40 CFR 98.3(d)(3)(v), which is specified in subpart A of Part 98 

and applies to only certain reporters under subpart C of Part 98. 2

 The reporting requirements applicable to certain stationary fuel combustion sources (e.g., individual units, 

aggregations of units, common pipes, or common stacks) subject to subpart C remain the same under the proposed 

amendment. Subpart C would continue to require reporting of all applicable “inputs to equations” data elements for 

stationary fuel combustion sources that meet both of the following criteria: (1) the stationary fuel combustion source 

contains at least one combustion unit connected to a fuel-fired electric generator that has been granted access by the 

Public Utilities Commission to deliver power to the local or regional electric power grid (excluding generators 

connected to combustion units that are subject to subpart D of this part); and (2) the stationary fuel combustion 

source is located at a facility for which the sum of the combined nameplate capacities for all such electric generators 

is greater than or equal to 1 megawatt electric output. Subpart C reporters would not report “inputs to equations” 

data elements for all other types of stationary fuel combustion sources subject to subpart C. 

In order to ease the burden for facilities, the EPA is proposing that the “inputs to 

equations” data elements that are not being amended in this action (and therefore would be 

reported for reporting years prior to reporting year 2014) be reported as part of the annual report 

for reporting year 2014. Specifically, when reporters prepare their reporting year 2014 annual 

report via e-GGRT, they would be required to include these “inputs to equations” data elements 

for reporting year 2014 as well as for all applicable previous reporting years. The annual report, 

including these “inputs to equations” data elements that would still be reported, would be 

submitted via e-GGRT. This proposed approach would prevent facilities from being required to 

revise, re-certify, and re-submit annual reports for each previous reporting year. 

C. Proposed Changes to Recordkeeping Requirements

For each facility subject to a subpart listed in Table 2 of this preamble that uses “inputs to 

equations” data elements to calculate and report GHGs (i.e., subject to using the proposed inputs 

verification tool), the EPA is proposing that the facility retain all records, including records for 

subparts not subject to the inputs verification tool requirement, for 5 years, rather than the 

current 3-year record retention period. In other words, if any facility subject to using the 

proposed inputs verification tool is also subject to a subpart of Part 98 not listed in Table 2, we 

propose that records required for those other subparts also be maintained for the 5 years. For 
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example, if such a facility is required to report under both subpart C (in Table 2) and subpart HH 

(not in Table 2), the facility would be required to maintain all records required under both 

subparts for 5 years following submittal of the annual report. The EPA is proposing that this 5-

year record retention requirement begin with records for reporting year 2010. 

Additionally, we are proposing that, at the time a reporter subject to using the proposed 

inputs verification tool completes entry of all “inputs to equations” data elements into the tool, 

the reporter would be required to keep a file generated by the tool that lists the entered “inputs to 

equations” data elements. The reporter would be required to maintain a copy of the file as a 

record of the entered inputs. As currently required in 40 CFR 98.3(g), subpart A, this file may be 

maintained in electronic or hard copy format. As discussed above, this record would be required 

to be maintained for 5 years. 

Refer to Section III.B of this preamble for further discussion of these proposed 

recordkeeping requirements. 

D. Proposed New Data Elements to be Reported 

The EPA is proposing that reporters subject to using the proposed inputs verification tool 

in subparts E, G, H, P, Q, S, V, X, Y, and AA of Part 98, be required to report the additional data 

elements listed per subpart in Table 4 of this preamble. Proposed confidentiality determinations 

for these proposed data elements are presented in Section IV of this preamble. 

Table 4. Proposed New Data Elements for Subparts E, G, H, P, Q, S, V, X, Y, and AA of 

Part 98 

Subpart Subpart Name New Data Element Description 

E Adipic Acid Production Annual quantity of cyclohexane fed to all production 

lines (metric tons). 

Annual percent N2O emission reduction for all 

production units combined. 

G Ammonia Production Annual ammonia production (metric tons). 
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Subpart Subpart Name New Data Element Description 

Annual methanol production (metric tons), if this 

quantity is not reported under subpart X of Part 98. 

H Cement Production Annual clinker production (metric tons). 

Annual average clinker CO2 emission factor for the 

facility, averaged across all kilns (metric tons 

CO2/metric ton clinker produced). 

Annual average cement kiln dust (CKD) CO2

emission factor for the facility, averaged across all 

kilns (metric tons CO2/metric ton CKD produced). 

P Hydrogen Production Name and annual quantity (metric tons) of each 

carbon-containing fuel and feedstock. 

Annual methanol production (metric tons), if this 

quantity is not reported under subpart X of Part 98. 

Q Iron and Steel Production If you use the carbon mass balance method in 40 CFR 

98.173(b)(1) to determine CO2 emissions: The annual 

mass (metric tons) of all gaseous, liquid, and solid 

fuels (combined) used in process units specified in 

Equations Q-1 through Q-7 of Part 98, calculated as 

specified in a proposed new Equation Q-9 in the 

proposed rule amendments. Do not include fuel used 

in a stationary combustion unit where emissions are 

reported under subpart C of this part. 

If you use the carbon mass balance method in 40 CFR 

98.173(b)(1) to determine CO2 emissions: The annual 

mass (metric tons) of all non-fuel material inputs 

(combined) specified in Equations Q-1 through Q-7 of 

Part 98, calculated as specified in a proposed new 

Equation Q-10 in the proposed rule amendments. 

If you use the carbon mass balance method in 40 CFR 

98.173(b)(1) to determine CO2 emissions: The annual 

mass (metric tons) of all solid and liquid products and 

byproducts (combined) specified in Equations Q-1 

through Q-7 of Part 98, calculated as specified in a 

proposed new Equation Q-11 in the proposed rule 

amendments. 

If you use the carbon mass balance method in 40 CFR 

98.173(b)(1) to determine CO2 emissions: The 

weighted average carbon content of all gaseous, 

liquid, and solid fuels (combined) included in 

proposed new Equation Q-9, calculated as specified in 

a proposed new Equation Q-12 in the proposed rule 

amendments. 
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Subpart Subpart Name New Data Element Description 

If you use the carbon mass balance method in 40 CFR 

98.173(b)(1) to determine CO2 emissions: The 

weighted average carbon content of all non-fuel inputs 

to all furnaces (combined) included in proposed new 

Equation Q-10, calculated as specified in a proposed 

new Equation Q-13 in the proposed rule amendments. 

If you use the carbon mass balance method in 40 CFR 

98.173(b)(1) to determine CO2 emissions: The 

weighted average carbon content of all solid and 

liquid products and byproducts from all furnaces 

(combined) included in a proposed new Equation Q11 in the proposed rule amendments, calculated as 

specified in new Equation Q-14. 

S Lime Manufacturing Annual quantity (metric tons) of lime product sold, by 

type. 

V Nitric Acid Production Annual percent N2O emission reduction for all 

production units combined. 

X Petrochemical Production If using the mass balance method or CEMS method to 

calculate GHG emissions: Name and annual quantity 

(in metric tons) of each carbon-containing feedstock. 

If using the mass balance method or CEMS method to 

calculate GHG emissions: Name and annual quantity 

(in metric tons) of each carbon-containing co-product. 

Y Petroleum Refineries Annual quantity of flare gas combusted (in MMscf per 

year) (only when using Equation Y-3). 

Annual average molecular weight of flare gas 

combusted (in mmBtu per MMscf) (only when using 

Equation Y-3). 

Annual average carbon content of flare gas combusted 

(expressed as a decimal fraction)(only when using 

Equation Y-3). 

AA Pulp and Paper 

Manufacturing 

For each pulp mill lime kiln: Quantity of calcium 

oxide (CaO) produced (metric tons). 

For each pulp mill lime kiln: Percent of annual heat 

input, individually for each fossil fuel type. 

For each chemical recovery furnace and chemical 

recovery combustion unit for which you are not using 

Equation C-2c to calculate CO2 emissions: Annual 

mass of steam generated (lb steam), individually for 

each fossil fuel type and for spent liquor solids. 

For each chemical recovery furnace and chemical 
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Subpart Subpart Name New Data Element Description 

recovery combustion unit for which you are not using 

Equation C-2c to calculate CO2 emissions: Ratio of 

the unit’s maximum rated heat input capacity to its 

design rated steam output capacity (mmBtu/lb steam), 

individually for each fossil fuel type and for spent 

liquor solids. 

III. Rationale for Proposed Changes to Reporting and Recordkeeping Requirements 

Based on the four-step evaluation described in Section I.B of this preamble, in particular 

the disclosure concerns discussed in “Step 2” of the evaluation and the alternatives considered in 

“Step 3” and “Step 4” of the evaluation to address those disclosure concerns, the EPA is 

proposing an alternative verification approach. This approach involves use of an inputs 

verification tool and revisions to the reporting and recordkeeping requirements of Part 98. The 

EPA’s rationale for this approach is presented in Sections III.A through C below. Section III.A 

addresses the proposed inputs verification tool and revisions to the requirement to report certain 

“inputs to equations” data elements. Section III.B addresses the proposed revisions to 

recordkeeping requirements. Section III.C addresses the proposed addition of new reporting 

requirements. 

A. Proposed Inputs Verification Tool and Amendment to Reporting Requirements

The EPA is proposing that facilities using “inputs to equations” data elements to calculate 

reported GHGs under the subparts listed in Table 2 of this preamble use an EPA-provided 

electronic inputs verification tool, which would calculate and verify GHG emissions. The inputs 

verification tool would be deployed within e-GGRT and integrated without interrupting the 

current electronic reporting process. Reporters would enter their “inputs to equations” data 

elements into the tool within the e-GGRT system along with the data required to be reported in 

the annual report (concurrent entry of “inputs to equations” data elements and data required for 
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the annual report would be required starting in reporting year 2014, as further discussed in 

Section III.A.2 of this preamble). As a built-in feature of the e-GGRT system, the tool would use 

the entered “inputs to equations” data elements to calculate the equation outputs, conduct 

electronic verification checks on the “inputs to equations” data elements, and generate a 

verification summary. The tool would not retain the entered “inputs to equations” data elements 

for which the EPA is proposing that the reporting requirement be removed.4

 Accordingly, unlike 

data currently reported to the EPA through e-GGRT, the EPA would not have access to these 

“inputs to equations” data elements. 

Any such sources subject to multiple subparts under Part 98 would be required to use the 

tool for only those subparts listed in Table 2 of this preamble, as discussed in the following 

section. 

1. Detailed Description of Inputs Verification Tool.

The EPA’s current verification approach consists of electronic verification checks 

followed by direct follow-up with facilities. For subparts where the reporting of inputs to 

emission equations has been deferred until 2015, these checks have been conducted using 

reported data other than inputs to emission equations (the reporting of which was deferred). For 

“supplier” subparts5 (and starting in reporting year 2012 for subparts with inputs to emission 

equations that were deferred until 2013), these checks have been conducted using reported data 

that include the data needed to calculate outputs of the equations. Reporters under the supplier 

subparts have been entering into e-GGRT the data needed to calculate the annual GHG 

quantities. For reporters under the direct emitter subparts listed in Table 2 of this preamble that 

 

4

 Please see section III.A.3 of this preamble for a discussion on which “inputs to equations” data elements the EPA 

is proposing that the reporting requirements be removed. 

5

 Supplier subparts (subparts LL through PP of Part 98) apply to fossil fuel suppliers and industrial gas suppliers. The eGGRT system currently calculates equation outputs for suppliers using reported equations inputs. Subpart MM 

reporters began using e-GGRT for reporting in Reporting Year 2012. 
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are using “inputs to equations” data elements to calculate reported GHGs, the EPA is proposing 

to use an approach similar to that currently used for the supplier subparts, where “inputs to 

equations” data elements would be entered into the inputs verification tool within e-GGRT and 

used to calculate the annual GHG emission values and verify these emission values. The 

difference, however, is that these “inputs to equations” data elements would be entered into this 

new inputs verification tool within e-GGRT and would not be reported to the EPA. 

To access the inputs verification tool, reporters would log into e-GGRT. They would 

enter data elements required for the annual report as well as their “inputs to equations” data 

elements. The tool would operate securely within e-GGRT, as a transient process, which means 

that “inputs to equations” data elements (for which the EPA is proposing that the reporting 

requirement be removed) entered into the tool would be temporarily saved in the tool while the 

reporter is actively using the tool, but would not be persisted (i.e., saved) within the e-GGRT 

database. The “inputs to equations” data elements would be discarded when the user’s session 

with e-GGRT ends. Refer to the memorandum “Technical Approach and Design for Inputs 

Verification Tool” (refer to Docket ID No. EPA–HQ–OAR–2010-0929) for a detailed 

description of EPA’s technical approach and design for the inputs verification tool. The 

memorandum describes how the inputs verification tool would use entered data only during the 

reporters’ e-GGRT session and would delete all records of entered data when the reporters exits 

the system. 

If the reporter exits the inputs verification tool prior to completing data entry or 

submitting their annual report, the tool would generate a file of entered “inputs to equations” data 

elements, and allow the reporter to download the file. This file could then be uploaded into the 

tool when the reporter next uses the tool to continue with data entry for the same reporting year. 
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This would avoid facilities from needing to re-enter “inputs to equations” data elements that 

were entered in previous e-GGRT sessions. 

After the reporter enters the “inputs to equations” data elements into the inputs 

verification tool, the tool would calculate the annual GHG emissions values. The tool would use 

the following information in calculating these values: (1) “inputs to equations” data elements (for 

which reporting under this action is proposed to be removed) entered into the tool, (2) “inputs to 

equations” data elements entered into e-GGRT (not into the inputs verification tool) (refer to 

Section III.A.3 of this preamble for a discussion of the “inputs to equations” data elements that 

would still be reported under this proposal), (3) information entered into e-GGRT identifying 

which Part 98 calculation method was selected (if applicable), and (4) the selected Part 98 

calculation method. Once the annual GHG emissions values are calculated, the values would be 

pre-filled into the appropriate reporting fields within e-GGRT. Reporters would then have the 

opportunity to override the annual GHG emissions values calculated by the tool with their own 

calculated value. If the reporter chose to override the calculated value, this would be reflected in 

the verification summary. 

Prior to annual report submittal, the inputs verification tool would conduct a series of 

verification checks, including the following: 

 Verification checks on the annual GHG emission values calculated by the inputs 

verification tool. As mentioned above, reporters would have the opportunity to override 

and revise the value calculated by the tool; however should this occur, the tool would 

note a discrepancy, which would prompt the EPA for further review after the reporter 

submits the annual report. 

 Verification checks on entered “inputs to equations” data elements. For example, the tool 

would check: (1) whether all required data were entered; (2) whether entered “inputs to 

equations” data element values are within the expected ranges for the data elements; and 

(3) whether expected relationships exist between certain “inputs to equations” data 

elements and certain other reported data elements (e.g., process raw material or 

throughput data that are not “inputs to equations” data elements). 
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Some of these checks would be conducted as the reporter enters “inputs to equations” 

data elements (i.e., using “real-time” checking), and other checks would be conducted after the 

reporter has entered all “inputs to equations” data elements, because some algorithms may 

compare certain “inputs to equations” data elements (e.g., production quantity) to GHG emission 

values at the subpart or facility level. 

Also, prior to submittal of the annual report, the inputs verification tool would generate a 

verification summary containing the results of the verification checks. The verification summary 

would specify whether any potential errors, as described above, were identified, without 

specifying the “inputs to equations” data elements. The reporter would have an opportunity to 

review the verification summary and make necessary revisions to the entered “inputs to 

equations” data elements and the reported data elements. 

For example, a facility subject to subpart G that manufactures ammonia using liquid and 

solid feedstocks is currently required under 40 CFR 98.76(b)(1) to report annual CO2 process 

emissions for each ammonia manufacturing unit. Currently, the reporter calculates this reported 

annual GHG emissions value outside of e-GGRT (e.g., using a calculator or computer software), 

using Equations G-2, G-3, and G-4 of Part 98, and monthly values for the following “inputs to 

equations” data elements: quantity of liquid feedstock, quantity of solid feedstock, carbon 

content value for liquid feedstock, and carbon content value for solid feedstock. We are 

proposing that the reporter instead calculate this reported annual GHG emissions value using the 

inputs verification tool, which not only would use the same equations and data for calculation, 

but would also conduct verification checks, as follows: 

 The reporter would enter all 48 “inputs to equations” data elements” into the inputs 

verification tool (i.e., monthly values for all four “inputs to equations” data elements). 
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 The reporter would use the inputs verification tool to calculate annual CO2 process 

emissions. In calculating this value, the tool would use Equations G-2, G-3, and G-4 of 

Part 98 and the 48 “inputs to equations” data element entries. 

 Once the annual CO2 process emissions value is calculated, the inputs verification tool 

would automatically conduct verification checks on the 48 entered “inputs to equations” 

data elements. For example, the tool might conduct the following checks: 

- Real-time checks that all 48 “inputs to equations” data elements were entered. 

- Real-time checks that each of the 12 entered values for carbon content of liquid 

feedstock is within the expected range for carbon content of liquid feedstock (based 

on industry-wide data). The tool would conduct similar comparisons for the 12 

entered “inputs to equations” data elements for the carbon content value for solid 

feedstock. 

- Algorithm check comparing each of the 12 entered values of the quantity of the liquid 

feedstock to all monthly values entered for the year, to determine if individual values 

are within an expected range established using all 12 values. The tool would conduct 

similar comparisons for the 12 entered “inputs to equations” data elements for the 

quantity of solid feedstock. This type of check would be conducted after the reporter 

has entered all “inputs to equations” data elements. 

 Prior to annual report submittal, the inputs verification tool would automatically generate 

a verification summary, which would flag any potential errors, providing an opportunity 

for the reporter to review the verification summary and revise entered data. The 

verification summary would note if the reporter has overridden any of the annual GHG 

emissions values calculated by the tool. After the reporter completes all revisions to data 
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entries, the tool would automatically re-generate the verification summary prior to annual 

report submittal. The EPA would access the verification summary (i.e., the same final 

summary viewed by the reporter) following annual report submittal and certification. 

 The inputs verification tool would also generate a file listing the entered “inputs to 

equations” data elements (for which the EPA is proposing to remove the reporting 

requirements) to be kept by the reporter and maintained as a record in a format currently 

allowed under Part 98 (see 40 CFR 98.3(g), subpart A). Refer to Section III.B of this 

preamble for further discussion of this proposed amendment and the EPA’s rationale for 

requiring this record. 

The EPA has developed a “pilot” inputs verification tool for one subpart, subpart X, 

which will be posted at http://www.epa.gov/ghgreporting/reporters/training/rulepilot.html, to 

demonstrate how the tool would work within e-GGRT, as well as the types of verification checks 

that would be conducted. The EPA seeks comment on the usability of the tool as well as its 

ability to conduct verification on the “inputs to equations” data elements. The EPA also seeks 

comment on additional approaches considered by the EPA for implementation of the inputs 

verification tool; refer to the memorandum “Evaluation of Alternative Verification Approaches 

for Greenhouse Gas Reporting Rule Subparts for which Reporting of Inputs to Emission 

Equations was Deferred to March 31, 2015” (refer to Docket ID No. EPA–HQ–OAR–2010-

0929) for a description of these additional approaches considered. 

2. Rationale Supporting the Use of the Inputs Verification Tool as an Alternative to 

Collecting Certain “Inputs to Equations” Data Elements for Verification Purposes. 

In the October 30, 2009 final rule (74 FR 56282 – 56283), the EPA described its 

verification approach as the following two-step process: 
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 Initial automated review of reported data, using an electronic data quality assurance 

program built into the data system, for use by reporters and the EPA to help assure the 

completeness and accuracy of data. 

 Based on the initial review results, follow up with facilities regarding potential errors, 

discrepancies, or questions, including on-site audits. 

The EPA is currently using the two-step verification process of automated verification 

checks followed by direct follow-up with facilities to verify data currently reported via e-GGRT. 

The EPA is proposing to supplement the current verification approach for facilities using “inputs 

to equations” data elements to calculate reported GHGs under the subparts listed in Table 2 of 

this preamble using the additional checks that would be conducted by the inputs verification tool. 

During the first 3 years of the Greenhouse Gas Reporting Program (GHGRP), the EPA has had 

success developing and using an electronic reporting and verification system for all subparts 

reporting under the program. During reporting year 2010, the EPA developed approximately 

1,400 electronic verification checks to verify reported data. Based on these verification checks, 

the EPA followed up with approximately 2,360 of the approximately 6,700 facilities that 

reported in reporting year 2010, resulting in approximately 2,300 facilities resolving verification 

issues by responding to the EPA and/or resubmitting their annual report. In reporting year 2011, 

the EPA programmed an additional 1,000 checks into e-GGRT for the subparts that were 

reporting for the second year, expanding the number of checks to 2,400. The EPA also 

programmed into e-GGRT, for 2011, approximately 1,300 checks for the newly-reporting 

subparts. During reporting year 2011, the EPA followed up with approximately 3,440 of the 

approximately 8,000 facilities that reported, resulting in approximately 3,000 facilities resolving 

their verification issues. 
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For example, for subpart H, the EPA verifies reported GHG emissions data using: (1) 

reported cement production data and (2) publicly available industry data on GHG emissions. 

Using these data, the EPA has established ranges of acceptable production and emission values 

and set up algorithm checks for reported GHG emission values. 

The electronic checks used by the GHGRP have served as a means for the EPA to verify 

reported data while minimizing the burden on both the EPA and reporters. Electronic verification 

is a critical first step to ensuring the completeness and accuracy of reported data and reducing the 

costs of compliance monitoring. 

The inputs verification tool described in Section III.A.1 of this preamble utilizes the same 

approach that the EPA currently uses for calculating and verifying data submitted for supplier 

subparts (and starting in reporting year 2012, inputs to emission equations whose reporting 

deadline was deferred until 2013), except that e-GGRT would not retain the “inputs to 

equations” data elements entered into the tool. Once the annual report is submitted, the EPA 

would review the verification summary generated by the inputs verification tool, along with 

verification summaries that are currently generated using data currently collected through the 

annual report. By requiring use of the inputs verification tool, the EPA would have the additional 

certainty that reported annual GHG emissions values either were calculated correctly (because 

the values calculated by the tool were submitted to the EPA) or that the EPA would be made 

aware that there were discrepancies between values calculated by the tool and values submitted 

to the EPA. That additional certainty, combined with the additional information provided by the 

range and algorithm checks on the “inputs to equations” data elements themselves, would 

provide the EPA with information necessary to conduct further verification once the annual 

report is submitted. 
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If a potential error with one of the “inputs to equations” data elements or with an annual 

GHG emissions value were identified in the verification summary generated by the inputs 

verification tool, the EPA would likely follow up with the facility to determine whether an actual 

error has occurred. While this verification approach may result in more direct follow-up with 

facilities than if the “inputs to equations” data elements were submitted to the EPA, this 

approach would facilitate verification by identifying potential errors and minimizing the number 

of errors before annual reports are submitted. In addition, as discussed elsewhere in the 

preamble, the EPA is retaining the reporting requirement for “inputs to equations” data elements 

for which our four-step evaluation did not identify disclosure concerns and is proposing to 

require reporting of additional new data elements to assist the EPA’s verification effort. These 

“inputs to equations” data elements for which reporting would be retained and these proposed 

new reported data elements would allow the EPA to conduct additional verification and 

minimize the number of follow-ups with facilities. Lastly, for the reasons specified in Section 

III.B of this preamble, the EPA is proposing that facilities retain records for 5 years, which 

would allow the EPA time to perform any necessary follow-up with reporters. For the reasons 

stated above, the EPA has determined that the proposed verification approach would be adequate 

to verify the reported emissions for reporters using “inputs to equations” data elements to 

calculate reported GHGs under the subparts identified in Table 2 of this preamble and is a 

reasonable alternative to collecting “inputs to equations” data elements for which we have 

identified disclosure concerns. 

The EPA is proposing to require the use of the inputs verification tool starting with 

reporting year 2014. The inputs verification tool is designed to be used concurrently with annual 

reporting by facilities. By the time the EPA takes any final action on this proposed amendment, 
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reporters would likely have already submitted annual reports for reporting years 2010 through 

2013. While additional verification could be conducted on the past years’ data if the inputs 

verification tool were used for these years, given that most of the data would likely already have 

been published and that the use of best available monitoring methods (BAMM) for these sectors 

is relatively low during these years, the EPA has determined that the added benefit does not 

outweigh the burden that would be required for facilities to use the inputs verification tool for 

years prior to reporting year 2014. 

3. Reporting of 440 “Inputs to Equations” Data Elements Would Not Be Necessary With the 

Proposed Verification Approach.

The EPA is proposing to remove the reporting requirement for 440 “inputs to equations” 

data elements that are in the subparts listed in Table 2 of this preamble. With the proposed 

alternative verification approach described in Section III.A.2 of this preamble, the EPA would no 

longer need to rely on the collection of these “inputs to equations” data elements to verify 

emissions under those subparts. Not having these data elements reported would address concerns 

relative to potential disclosure of these data elements.6 These 440 data elements are specified in 

Table 1 of the memorandum “List of Inputs to Equations Data Elements Proposed Not To Be 

Reported” (refer to Docket ID No. EPA–HQ–OAR–2010-0929). 

The 440 “inputs to equations” data elements for which the EPA is proposing to remove 

the reporting requirement must be maintained on-site as records. Because Part 98 already 

requires these “inputs to equations” data elements to be kept as records (see 40 CFR 98.3(g)(2), 

which states that “the data used to calculate the GHG emissions for each unit, operation, process, 

 

6

For 23 of these “inputs to equations” data elements, we are proposing to remove the reporting requirement because, 

while there is not a disclosure concern, the EPA determined that these data elements would not be useful for data 

verification and would not inform future GHG policy development in the absence of other data elements for which 

we are proposing to remove the reporting requirement. See section III.A.3 of this preamble for additional discussion 

on this topic.
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and activity, categorized by fuel or material type” must be kept as records), the EPA is not 

proposing in this action to specify each of the 440 “inputs to equations” data elements in the 

recordkeeping section of each subpart. The EPA considered whether specifying each of these 

“inputs to equations” data elements in the recordkeeping sections of each subpart would improve 

the clarity of the specific records that would be required to be retained. Because the EPA is 

proposing that the “inputs to equations” data elements that would not be reported must be kept as 

records in the format generated by the inputs verification tool (i.e., file for downloading or 

printing), the EPA determined that the data that must be kept as records would be sufficiently 

clear. The EPA seeks comment on whether additional specificity within the recordkeeping 

requirements of each subpart would improve the clarity of the specific records that are required 

to be retained. 

For the purposes of clarifying which data elements must be reported for previous 

reporting years 2010 through 2013, we are proposing to revise Table A-7 of Part 98 to remove all 

440 data elements for which reporting is proposed to be removed. The data elements that are not 

being removed from Table A-7 would continue to be reporting requirements, and would be 

reported for previous reporting years 2010 through 2013, as appropriate.The EPA is retaining

reporting of 170 “inputs to equations” data elements.7

 Refer to Table 2 in the memorandum “List 

of ‘Inputs to Equations’ Data Elements Proposed Not To Be Reported” (refer to Docket ID No. 

EPA–HQ–OAR–2010-0929) for a complete list of these 170 data elements. The 170 “inputs to 

equations” data elements include certain “inputs to equations” data elements for the subparts 

listed in Table 3 of this preamble, as well as all “inputs to equations” data elements for subparts 

C (only for specified stationary fuel combustion sources connected to certain electric generators 

 

7

 These 170 “inputs to equations” data elements include nine “inputs to equations” data elements in subpart L of part 

98 that are not being addressed in this rulemaking because they will be addressed in a separate action related to 

subpart L. 
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that deliver power to the local or regional electric power grid)8

, W, and II of part 98. For these 

“inputs to equations” data elements, the EPA is not amending these reporting requirements and 

would therefore let the deferral of these data elements expire on March 31, 2015. As a result, 

these “inputs to equations” data elements would be reported for future reporting years starting 

with reporting year 2014, as well as for previous reporting years (i.e., reporting years 2010 

through 2013). Based on “Step 2” of our evaluation described in Section I.B of this preamble, 

these data elements would not raise disclosure concerns. Having these data elements reported 

would allow the EPA to do additional verification, including conduct year-to-year comparisons, 

thereby reducing the amount of direct follow-up required with facilities. For the reason stated 

above, collecting these data elements, even in the absence of collecting all “inputs to equations” 

data elements, would aid in the verification process. 

The EPA identified 23 “inputs to equations” data elements for which disclosure concerns 

were not identified based on “Step 2” of our evaluation; however, the EPA is not retaining these 

reporting requirements. The EPA determined that these 23 data elements would not be useful for 

data verification and would not inform future GHG policy development in the absence of other 

“inputs to equations” data elements for which the reporting requirement is proposed to be 

removed under this action. Examples of these 23 “inputs to equations” include reporting the 

selected default molar volume conversion factor and reporting the units of measure of a sitespecific emission factor. These “inputs to equations” are identified in the memorandum “List of 

 

8

 Refers to stationary fuel combustion sources (e.g., individual units, aggregations of units, common pipes, or 

common stacks) subject to subpart C meeting both of the following criteria: (1) the stationary fuel combustion 

source contains at least one combustion unit connected to a fuel-fired electric generator that has been granted access 

by the Public Utilities Commission to deliver power to the local or regional electric power grid (excluding 

generators connected to combustion units that are subject to subpart D of this part); and (2) the stationary fuel 

combustion source is located at a facility for which the sum of the nameplate capacities for all such electric 

generators is greater than or equal to 1 megawatt electric output. 
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‘Inputs to Equations’ Data Elements Proposed Not To Be Reported” (refer to Docket ID No. 

EPA–HQ–OAR–2010-0929). 

Regarding the 170 retained “inputs to equations” data elements, for reporting year 2014 

and thereafter, reporters would enter the 170 “inputs to equations” data elements for which we 

are retaining the reporting requirement into e-GGRT. Starting in reporting year 2014, the eGGRT system would retain these 170 data elements as part of the annual report and they would 

be accessible by the EPA once the reporter submits the annual report. In order to ease the burden 

on facilities, for reporting years prior to reporting year 2014, the EPA is proposing that these 

reported “inputs to equations” data elements be submitted as part of the reporting year 2014 

annual report. Specifically, when reporters prepare their reporting year 2014 annual report via eGGRT, they would be required to include these “inputs to equations” data elements for reporting 

year 2014 as well as for all applicable previous reporting years. The annual report, including 

these “inputs to equations” data elements would be submitted via e-GGRT. This approach would 

prevent facilities from being required to revise, re-certify, and re-submit annual reports for 

reporting years 2010, 2011, 2012, and 2013. 

The proposed revisions to the current reporting requirements would apply to all reporters 

subject to the subparts listed in Table 2 of this preamble, including subpart C, and using “inputs 

to equations” data elements to calculate reported GHGs. However, as noted in Table 2, we are 

not proposing to amend the reporting requirements for stationary fuel combustion sources subject 

to subpart C (e.g., individual units, aggregations of units, common pipes, or common stacks) that 

meet the following criteria: (1) the stationary fuel combustion source contains at least one 

combustion unit connected to a fuel-fired electric generator that has been granted access by the 

Public Utilities Commission to deliver power to the local or regional electric power grid 
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(excluding generators that are connected to combustion units subject to subpart D of this part); 

and (2) the stationary fuel combustion source is located at a facility for which the sum of 

nameplate capacities for all such electric generators is greater than or equal to 1 megawatt 

electric output. The “inputs to equations” data elements for these stationary fuel combustion 

sources are among those that did not raise disclosure concerns under “Step 2” of our evaluation 

of the “inputs to equations” data elements (refer to Section I.B of this preamble for a discussion 

of the EPA’s four-step evaluation). Refer to the memoranda documenting “Step 2” of our 

evaluation, “Evaluation of Competitive Harm From Reporting 2015 Inputs to Equations” 

(Docket ID No. EPA–HQ–OAR–2010-0929), for further information on the results of the 

analysis for these stationary fuel combustion sources. 

Reporters currently reporting emissions for stationary fuel combustion sources under 

subpart C have the option to utilize one or more of the reporting options under subpart C that 

allow the grouping of stationary combustion units for the purpose of monitoring, calculating, and 

reporting emissions. The EPA recognizes that stationary combustion units grouped in these 

reporting configurations could include both combustion units associated with electric generators 

(excluding generators connected to combustion units subject to subpart D of this part) (connected 

to the grid and not connected to the grid) and combustion units not associated with electric 

generators (excluding generators connected to combustion units subject to subpart D of this part). 

In these cases where combustion units are grouped, the EPA has determined that there would be 

no disclosure concerns with reporting of “inputs to equations” data elements for the grouped 

combustion units. In reporting combined data for multiple units including those associated with 

an electric generator and subject to reporting under this proposed action, no unit-specific data 

would be revealed. Furthermore, should a facility not wish to disclose aggregated data, it would 
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have the option to calculate and report emissions using one of the individual unit reporting 

configurations. The EPA seeks comment on this conclusion. If you believe that there are any 

disclosure concerns, please provide detailed information about the concern, as well as whether 

reporting on an individual unit basis is a feasible reporting option. 

Additionally, the EPA is proposing to revise two paragraphs (40 CFR 98.116(e)(6) and 

40 CFR 98.186(b)(8)) that reference other paragraphs that include “inputs to equations” data 

elements proposed to be removed from Part 98. As a result, we are proposing to remove the cross 

reference while carrying over the substantive information in order to maintain the requirements 

in these paragraphs. 

The EPA requests comment on the proposed inputs verification tool and verification 

approach, and the associated revision to the current reporting requirements as described in this 

section. 

B. Proposed Revisions to Recordkeeping Requirements

Given the proposed verification approach described in Section III.A of this preamble, the 

EPA considered whether the current record retention period and record format requirements 

would be sufficient to allow the EPA to perform data verification. We considered: 

 The time we would need to follow up with reporters to further verify reported GHG 

emissions. 

 The desirability of retaining multiple years of data records to allow for appropriate 

assessment of compliance and for analyses of trends for policy analysis purposes. 

 The format of records, and whether the current format would be adequate for our 

verification process. For example, we considered whether records of “inputs to 

equations” data elements contained in multiple separate documents (as currently allowed 
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under Part 98) would allow an EPA inspector to efficiently analyze the consistency of the 

data elements and use the data elements to perform calculations to confirm reported GHG 

emissions. 

Because there may be more direct follow-up activities under this alternative verification 

approach, we are proposing to extend the record retention period from 3 to 5 years. We have 

determined that 5 years is reasonable given the large number of reporters under the subparts 

identified in Table 2 of this preamble (over 2,000 facilities) and the likely increase in follow-up 

activities. It would be important that relevant records are available to the EPA for follow-up 

activities with facilities, including on-site audits if necessary, regarding potential errors, 

discrepancies, or questions. Should an EPA inspector visit a facility, it would be important to be 

able to examine not only the current year’s records but those from previous years as well, 

because previous years’ data would provide year-to-year comparisons, which are useful for 

verifying the current year’s data. A 5-year record retention period would ensure the availability 

of relevant records for the follow-up activities described above. The EPA is proposing that this 

5-year record retention requirement begin with records for reporting year 2010, as discussed in 

Section III.A.2 of this preamble. 

For reporters subject to using the proposed inputs verification tool, the EPA is proposing 

to extend the record retention period not only for the subparts listed in Table 2 of the preamble, 

but also for other subparts that apply to reporters subject to a subpart in Table 2. Under this 

proposal, any such facility subject to both a subpart listed in Table 2 of this preamble and a 

subpart not listed in Table 2 would be required to maintain all records required under both 

subparts for a period of 5 years. For example, if a facility is required to use the proposed inputs 

verification tool under subpart C (in Table 2) and to report under subpart HH (not in Table 2), 
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the facility would be required to maintain all records required under both subparts for 5 years. 

The EPA is proposing these provisions for two reasons. First, the EPA determined that during a 

site visit, if questions arise regarding the accuracy of an “inputs to equations” data element, it 

may be necessary to examine other non-input recordkeeping information, such as a monitoring 

plan or recordkeeping information in a different subpart, in order to fully investigate the 

accuracy of the data. It is necessary to ensure that all data necessary for verification are available, 

and this proposed 5-year record retention period would provide better assurance of on-site data 

availability. Second, the EPA determined that maintaining multiple sets of data records 

according to different record retention periods could possibly cause confusion and result in 

recordkeeping errors. Providing the same record retention duration for all subparts, as proposed, 

would simplify recordkeeping and thereby minimize the chance for recordkeeping errors. 

In addition, the EPA is proposing revisions to the recordkeeping format for “inputs to 

equations” data elements. Currently, reporters have the option to maintain records of their 

“inputs to equations” data elements in one or more electronic or hard copy files. The proposed 

record format revision would require reporters to maintain an electronic or hard copy of the 

single file generated by the proposed inputs verification tool, listing all “inputs to equations” data 

elements entered into the tool. This proposed record format change would ensure that the EPA 

could readily access these data, enabling the EPA to quickly and efficiently perform calculations 

and data checks during site visits. All other records required under Part 98 would be maintained 

in the format currently required under Part 98. In combination with the proposed reporting 

requirements discussed in Sections III.A and C of this preamble, these proposed recordkeeping 

requirements would allow the EPA to adequately verify certain reported emissions without 

implicating the disclosure concerns discussed in the memorandum “Evaluation of Competitive 
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Harm For Reporting 2015 Inputs to Equations” (refer to Docket ID No. EPA–HQ–OAR–2010-

0929). 

In amending 40 CFR part 98, subpart A to add these recordkeeping requirements, we are 

also correcting an error in the current version of 40 CFR 98.3(g). In a previous action amending 

this paragraph (76 FR 73866, November 29, 2011), our intention was to amend the second 

sentence of the paragraph regarding record retention duration; however, the third sentence 

regarding record format was inadvertently amended. To correct this error, we are proposing to 

remove the second sentence of 40 CFR 98.3(g) and to reinstate the previous third sentence of 40 

CFR 98.3(g) (regarding format of records). 

We seek comment on whether 5 years is the appropriate timeframe for maintaining 

records for facilities required to use the proposed inputs verification tool under a subpart listed in 

Table 2 of this preamble. In addition, we seek comment on the proposal to extend the record 

retention period for these reporters, not only for the subparts listed in Table 2 of the preamble, 

but also for other subparts that apply to these reporters. 

C. Proposed Requirement to Report Additional Data

As part of our proposal to no longer require reporting of certain “inputs to equations” 

data elements, we are proposing to require that certain reporters using the proposed inputs 

verification tool also report the new data elements specified in Table 4 of this preamble. These 

additional data elements would allow the EPA to perform additional verification checks and 

minimize the number of follow-up activities. These data elements are quantities that provide 

information on the activity level at the facility, emission factors used, characteristics of carboncontaining streams, and other process information that would provide key information for 

verification, including confirming that emissions are appropriate for a given activity-level and 
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estimating expected emissions based on data provided. These new data reporting elements would 

also enable the EPA to better understand the following aspects concerning reporters in order to 

inform future GHG policy:9 (1) the GHG emission profile for the reporter; (2) the relationship of 

GHG emissions to production output or raw material input within the industry sector; and (3) the 

factors influencing GHG emissions. 

The EPA is proposing to add six new equations (Equations Q-9 through Q-14 of part 98) 

to subpart Q to specify how to calculate and report each of the six new data elements proposed to 

be added to subpart Q of part 98. Table 4 of this preamble specifies which equation number 

correlates with each new proposed data element. Refer to the proposed amendments for subpart 

Q for the proposed equations. 

The EPA is proposing confidentiality determinations for these proposed new data 

elements. Those new data elements determined to be confidential business information in a final 

rule would be afforded confidential treatment. Refer to the following Section IV of this preamble 

for the EPA’s proposed confidentiality determinations for the proposed new data elements. 

IV. Confidentiality Determination for Proposed New Data Elements to be Reported 

The EPA is proposing confidentiality determinations for each new data element listed in 

Table 4 of this preamble. To make these determinations, the EPA proposes to use the same 

approach that the EPA previously used for the 2011 final CBI rule (76 FR 30782, May 26, 2011). 

Specifically, the EPA is proposing to assign each new data element listed in Table 4 of this 

preamble to one of 11 direct emitter data categories, based on the type and characteristics of the 

data element. For a description of each data category and the type and characteristics of data 

 

9

 The EPA has previously stated that a goal of collecting data under the GHGRP is to inform future GHG policy 

(refer to the April 10, 2009 proposed rule (74 FR 16455). 
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elements assigned to each category, see Sections II.C and II.D of the July 7, 2010 CBI proposal 

preamble (75 FR 39106 – 39130). 

Based on its evaluation of the new data elements, the EPA is proposing that each new 

data element be assigned to one of the four following direct emitter data categories: 

 Production/Throughput Data that are Not Inputs to Emission Equations. 

 Raw Materials Consumed that are Not Inputs to Emission Equations. 

 Unit/Process “Static” Characteristics that are Not Inputs to Emission Equations. 

 Unit/ Process Operating Characteristics that are Not Inputs to Emission Equations. 

In the 2011 final CBI rule (May 26, 2011, 76 FR 30782), the EPA made categorical 

determinations that all data elements assigned to the “Production/Throughput Data that are Not 

Inputs to Emission Equations” and “Raw Materials Consumed that are Not Inputs to Emission 

Equations” data categories are entitled to confidential treatment because the data do not meet the 

definition of “emission data” in 40 CFR 2.301(a)(2)(i) and they are CBI. 

The EPA is proposing that seven new data elements be assigned to the 

“Production/Throughput Data that are Not Inputs to Emission Equations” data category and 10 

new data elements be assigned to the “Raw Materials Consumed that are Not Inputs to Emission 

Equations” data category, as shown in Table 5 of this preamble, thereby applying the categorical 

confidentiality determinations made for these categories in the 2011 final CBI rule (i.e., they are 

CBI) to the proposed new reporting elements assigned to these categories. This proposal is not 

changing, nor soliciting comment on, the categorical confidentiality determination for these two 

data categories. Should the EPA finalize the category assignment for these data elements, all new 
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data elements assigned to these categories would be considered to be entitled to confidential 

treatment. 

Table 5. Data Elements Proposed to Be Assigned To the “Production/Throughput Data 

that are Not Inputs to Emission Equations” and “Raw Materials Consumed that are Not 

Inputs to Emission Equations” Data Categories 

Subpart Proposed Citation Data Element 

“Production/Throughput Data that are Not Inputs to Emission Equations” Data Category 

G - Ammonia Production 40 CFR 98.76(b)(14) Annual ammonia production 

(metric tons). 

40 CFR 98.76(b)(15) Annual methanol production 

(metric tons), if this quantity is 

not reported under subpart X of 

Part 98. 

H - Cement Kilns 40 CFR 98.86(b)(16) Annual clinker production 

(metric tons). 

P – Hydrogen Production 40 CFR 98.166(e) Annual methanol production 

(metric tons), if this quantity is 

not reported under subpart X of 

Part 98. 

S - Lime Manufacturing 40 CFR 98.196(b)(18) Annual quantity (metric tons) of 

lime product sold, by type. 

X – Petrochemical 40 CFR 98.246(a)(13) and 

(b)(10) 

If using the mass balance 

method or CEMS method to 

calculate GHG emissions: 

Name and annual quantity (in 

metric tons) of each carboncontaining co-product. 

AA - Pulp and Paper 40 CFR 98.276(l)(1) For each pulp mill lime kiln: 

Quantity of calcium oxide 

(CaO) produced (metric tons). 

“Raw Materials Consumed that are Not Inputs to Emission Equations” Data Category 

E - Adipic Acid Production 40 CFR 98.56(m) Annual quantity of cyclohexane 

fed to all production lines, 

combined (metric tons). 

P - Hydrogen Production 40 CFR 98.166(b)(7) Name and annual quantity 

(metric tons) of each carboncontaining fuel and feedstock. 
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Subpart Proposed Citation Data Element 

Q - Iron and Steel 40 CFR 98.176(e)(6)(i) If you use the carbon mass 

balance method in 40 CFR 

98.173(b)(1) to determine CO2

emissions: The annual mass 

(metric tons) of all gaseous, 

liquid, and solid fuels 

(combined) used in process 

units specified in Equations Q-1 

through Q-7, calculated as 

specified in a new Equation Q-9 

in the proposed rule 

amendments. Does not include 

fuel used in a stationary 

combustion unit where 

emissions are reported under 

subpart C of this part. 

40 CFR 98.176(e)(6)(ii) If you use the carbon mass 

balance method in 40 CFR 

98.173(b)(1) to determine CO2

emissions: The annual mass 

(metric tons) of all non-fuel 

material inputs (combined) 

specified in Equations Q-1 

through Q-7, calculated as 

specified in a new Equation Q10 in the proposed rule 

amendments. 

40 CFR 98.176(e)(6)(iii) If you use the carbon mass 

balance method in 40 CFR 

98.173(b)(1) to determine CO2

emissions: The annual mass 

(metric tons) of all solid and 

liquid products and byproducts 

(combined) specified in 

Equations Q-1 through Q-7, 

calculated as specified in a new 

Equation Q-11 in the proposed 

rule amendments. 
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Subpart Proposed Citation Data Element 

40 CFR 98.176(e)(6)(iv) If you use the carbon mass 

balance method in 40 CFR 

98.173(b)(1) to determine CO2

emissions: The weighted 

average carbon content of all 

gaseous, liquid, and solid fuels 

(combined) included in 

Equation Q-9, calculated as 

specified in a new Equation Q12 in the proposed rule 

amendments. 

40 CFR 98.176(e)(6)(v) If you use the carbon mass 

balance method in 40 CFR 

98.173(b)(1) to determine CO2

emissions: The weighted 

average carbon content of all 

non-fuel inputs to all furnaces 

(combined) included in 

Equation Q-10, calculated as 

specified in a new Equation Q13 in the proposed rule 

amendments. 

40 CFR 98.176(e)(6)(vi) If you use the carbon mass 

balance method in 40 CFR 

98.173(b)(1) to determine CO2

emissions: The weighted 

average carbon content of all 

solid and liquid products and 

byproducts from all furnaces 

(combined) included in a new 

Equation Q-11 in the proposed 

rule amendments, calculated as 

specified in new Equation Q-14 

in the proposed rule 

amendments. 

X – Petrochemical 40 CFR 98.246(a)(12) and (b)(9) If using the mass balance 

method or CEMS method to 

calculate GHG emissions: 

Name and annual quantity (in 

metric tons) of each carboncontaining feedstock. 
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Subpart Proposed Citation Data Element 

AA - Pulp and Paper 40 CFR 98.276(m)(1) For each chemical recovery 

furnace and chemical recovery 

combustion unit for which you 

are not using Equation C-2c to 

calculate CO2 emissions: 

Annual mass of steam 

generated (lb steam), 

individually for each fossil fuel 

type and for spent liquor solids. 

The EPA is proposing to assign eight proposed new data elements to the “Unit Process 

Operating Characteristics that are Not Inputs to Emission Equations” category and one proposed 

new data element to the “Unit/Process Static Characteristics that are Not Inputs to Emission 

Equations” category. In the 2011 final CBI rule, the EPA determined that the data elements in 

these categories are not “emission data” (as defined at 40 CFR 2.301(a)(2)(i)). However, instead 

of categorical determinations, the EPA made confidentiality determinations for individual data 

elements assigned to these two categories. In proposing these determinations, the EPA 

considered the confidentiality criteria at 40 CFR 2.208, in particular whether release of the data 

is likely to cause substantial harm to the business’s competitive position. See 40 CFR 

2.208(e)(1). The EPA is therefore following the same approach in this action for the proposed 

new reporting elements assigned to these two categories. 

Table 6 of this preamble lists the data elements the EPA proposes to assign to these two 

data categories and presents the EPA’s rationale for proposing to determine that each does or 

does not qualify as CBI under CAA section 114(c). 

Table 6. Proposed Confidentiality Determinations for Proposed New Data Elements 

Assigned to the “Unit/Process Operating Characteristics That Are Not Inputs to Emission 

Equations” and “Unit/Process ‘Static’ Characteristics that Are Not Inputs to Emission 

Equations” Data Categories 

Subpart Citation 

Data 

Element 

Confidentiality 

Determination 

Proposed Rationale for 

Confidentiality Determination 
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Subpart Citation 

Data 

Element 

Confidentiality 

Determination 

Proposed Rationale for 

Confidentiality Determination 

“Unit/Process Operating Characteristics That Are Not Inputs to Emission Equations” Data 

Category

E – Adipic 

Acid 

Production 

40 CFR 

98.56(n) 

Annual 

percent N2O 

emission 

reduction for 

all production 

units 

combined. 

Not CBI The annual facility percent N2O 

reduction could not be used to 

calculate adipic acid production. 

The level of N2O reductions 

varies by the type of abatement 

technology, the environment in 

which the abatement technology 

is operating, the age of the 

abatement technology, the age of 

the catalyst used, and the 

maintenance level of the 

abatement technology. 

H - Cement 

Kilns 

40 CFR 

98.86(b)(17) 

Annual 

average 

clinker CO2

emission 

factor for the 

facility, 

averaged 

across all 

kilns (metric 

tons 

CO2/metric 

ton clinker 

produced). 

CBI This data element could be used 

to back calculate a facility’s 

clinker production data, which 

would result in competitive 

disadvantage. 

40 CFR 

98.86(b)(18) 

Annual 

average 

cement kiln 

dust (CKD) 

CO2 emission 

factor for the 

facility, 

averaged 

across all 

kilns (metric 

tons 

CO2/metric 

ton CKD 

produced). 

CBI This data element could provide 

information about the efficiency 

of the operation, which would 

result in competitive 

disadvantage. 

V – Nitric 

Acid 

Production 

40 CFR 

98.226(q) 

Annual 

percent N2O 

emission 

reduction for 

all production 

Not CBI The annual facility percent N2O 

reduction for all nitric acid 

production trains combined 

could not be used to calculate the 

nitric acid production value for 
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Subpart Citation 

Data 

Element 

Confidentiality 

Determination 

Proposed Rationale for 

Confidentiality Determination 

units 

combined. 

any individual facility. The level 

of N2O reductions for each 

individual facility varies by the 

type of abatement technology, the 

environment in which the 

abatement technology is 

operating, the age of the 

abatement technology, the age of 

the catalyst used, and the 

maintenance level of the 

abatement technology. 

Additionally, facility-level N2O 

emission reduction information is 

already publicly available (see 

docket number EPA-HQ-OAR2010-0750 and 

http://www.climateactionreserve.

org). 

Y – 

Petroleum 

Refineries 

40 CFR 

98.256(e)(11)(

i) 

Annual 

quantity of 

flare gas 

combusted 

(in MMscf 

per year) 

(only when 

using 

Equation Y3). 

Not CBI This data element does not reveal 

(nor could be used to calculate) 

details regarding product 

characteristics, actual production 

data, or operating efficiency. It 

does not provide information that 

would allow competitors to infer 

market share, production costs, or 

pricing structures and thus gain a 

competitive advantage. The EPA 

applied the same rationale in the 

2010 proposed and 2011 final 

CBI rules (75 FR 39113 and 76 

FR 30803 - 30806), in support of 

a non-CBI determination for 

reporting of the following same 

data element currently required to 

be reported if a different equation 

(Equation Y-1a) is used: annual 

volume of flare gas combusted 

(scf/year) under 40 CFR 

98.256(e)(6). 

40 CFR 

98.256(e)(11)(

ii) 

Annual 

average 

molecular 

weight of 

flare gas 

combusted 

(in mmBtu 

per MMscf) 

(only when 

Not CBI This data element does not reveal 

(nor could be used to calculate) 

details regarding product 

characteristics, actual production 

data, or operating efficiency. It 

does not provide information that 

would allow competitors to infer 

market share, production costs, or 

pricing structures and thus gain a 
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Subpart Citation 

Data 

Element 

Confidentiality 

Determination 

Proposed Rationale for 

Confidentiality Determination 

using 

Equation Y3). 

competitive advantage. The EPA 

applied the same rationale in the 

2010 proposed and 2011 final 

CBI rules (75 FR 39113 76 FR 

30803 - 30806), in support of a 

non-CBI determination for 

reporting of the following same 

data element currently required to 

be reported if a different equation 

(Equation Y-1a) is used: annual 

average molecular weight of the 

flare gas (kg/kg-mole) under 40 

CFR 98.256(e)(6). 

40 CFR 

98.256(e)(11)(

iii) 

Annual 

average 

carbon 

content of 

flare gas 

combusted 

(expressed as 

a decimal 

fraction)(only 

when using 

Equation Y3). 

Not CBI This data element does not reveal 

(nor could be used to calculate) 

details regarding product 

characteristics, actual production 

data, or operating efficiency. It 

does not provide information that 

would allow competitors to infer 

market share, production costs, or 

pricing structures and thus gain a 

competitive advantage. The EPA 

applied the same rationale in the 

2010 proposed and 2011 final 

CBI rules (75 FR 39113 76 FR 

30803 - 30806), in support of a 

non-CBI determination for 

reporting of the following same 

data element currently required to 

be reported if a different equation 

(Equation Y-1a) is used: annual 

average carbon content of the 

flare gas (kg carbon/kg flare gas) 

under 40 CFR 98.256(e)(6). 

AA - Pulp 

and Paper 

40 CFR 

98.276(l)(2) 

For each pulp 

mill lime 

kiln: Percent 

of annual heat 

input, 

individually 

for each fossil 

fuel type. 

Non-CBI Release of this data would not 

result in competitive harm 

because lime kiln fossil fuel use 

as a fraction of design heat input 

was reported to the EPA as part of 

a 2011 ICR survey, and facilities 

reporting via the survey made no 

CBI claims regarding fuel type 

and percent of design heat input. 

“Unit/Process ‘Static’ Characteristics that Are Not Inputs to Emission Equations” Data Category 

AA - Pulp 

and Paper 

40 CFR 

98.276(m)(2) 

For each 

chemical 

ND1 In the final CBI rulemaking (76 

FR 30799, May 26, 2011), we 
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Subpart Citation 

Data 

Element 

Confidentiality 

Determination 

Proposed Rationale for 

Confidentiality Determination 

recovery 

furnace and 

chemical 

recovery 

combustion 

unit for which 

you are not 

using 

Equation C2c to 

calculate CO2

emissions: 

Ratio of the 

unit’s 

maximum 

rated heat 

input capacity 

to its design 

rated steam 

output 

capacity 

(mmBtu/lb 

steam), 

individually 

for each fossil 

fuel type and 

for spent 

liquor solids. 

determined that the best approach 

for determining confidentiality of 

production capacity is not to make 

a single CBI determination 

applicable to all facilities within a 

given source category, due to 

differences between facilities. For 

all reported data elements related 

to production capacity, the EPA 

will make case-by-case 

determinations per reporter, in 

accordance with the provisions in 

40 CFR part 2, subpart B for 

facilities that claim these data 

elements as CBI. 

1

 ND = No determination is being proposed. 

The EPA is requesting comment on two aspects of these confidentiality determinations. 

First, the EPA seeks comment on the proposed data category assignment for each of these data 

elements in Tables 5 and 6 of this preamble. If you believe that the EPA has improperly assigned 

any proposed new data elements to one of the data categories, please provide specific comments 

identifying which proposed new data elements may be mis-assigned along with a detailed 

explanation of why you believe them to be incorrectly assigned and in which data category you 

believe they best belong. 

Second, for those data elements included in Table 6 of this preamble and assigned to the 

two direct emitter data categories without categorical confidentiality determinations, the EPA 
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seeks comment on the individual confidentiality determinations we are proposing for these data 

elements. If you comment on this issue, please provide specific comment along with detailed 

rationale and supporting information on whether such data element does or does not qualify as 

CBI. 

V. Impacts of the Proposed Rule 

This section examines the cost impacts of the proposed rulemaking. A detailed discussion 

of the impacts may be found in the memorandum, “Impacts Analysis of the Proposed 2015 

Inputs Proposal,” available in EPA docket ID No. EPA–HQ–OAR–2010-0929. 

A. How were the costs of this proposed rule estimated?

1. Proposed Inputs Verification Tool.

The data elements required to be used for calculating the annual GHG emissions values 

and the cost associated with collecting these data have not changed from the estimate made 

during the original rulemaking process. The time associated with entry of these “inputs to 

equations” data elements into e-GGRT (including into the new inputs verification tool) is 

expected to be equivalent to the time originally anticipated for data entry. Prior to the inputs 

verification tool, as currently required, reporters must use their own calculation tool (e.g., 

calculator, calculation software) to calculate the annual GHG emissions values, using the same 

sets of equations and entering the same data elements that they would enter into the tool. 

The EPA does recognize however that there may be some time associated with learning 

the new procedures for the inputs verification tool and we have estimated a cost of 

approximately $66 per facility, or $379,000 for the first year for all affected facilities. During 

their first session using the proposed inputs verification tool, reporters would need to spend 

approximately 1 hour becoming familiar with how the tool operates within e-GGRT. The 
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proposed new requirement to use the inputs verification tool would not result in any change in 

the respondent activity of entering these data into e-GGRT. Once the reporter has become 

familiar with the tool, EPA does not anticipate any additional burden. The cost includes 

technical, clerical, and managerial labor hours. For further information about this cost estimate, 

refer to the memorandum “Assessment of Cost Impacts of 2015 Inputs Proposal – Revisions to 

Reporting, Recordkeeping, and Verification Requirements under the Greenhouse Gas Reporting 

Program” and the supporting statement for this proposed information collection request, 

“Supporting Statement, Environmental Protection Agency: Revisions to Reporting and 

Recordkeeping Requirements, and Proposed Confidentiality Determinations under the 

Greenhouse Gas Reporting Program, OMB control number 2060-new, ICR number 2483.01,” 

both available in docket EPA–HQ–OAR–2010-0929. 

2. Proposed New Data Elements.

We are proposing to add 26 new data elements that were not previously required to be 

reported under Part 98 (see Section II.D of this preamble for further discussion of this proposed 

amendment), to be reported by facilities in certain subparts that are required to use the proposed 

inputs verification tool. Of these 26 data elements, nine data elements are related to annual 

production or raw material usage, which are collected by a facility as a routine part of conducting 

business. For these data elements, we are not proposing that reporters comply with specific data 

collection or monitoring requirements beyond the methods commonly used for accounting 

purposes. The other 17 data elements proposed to be reported are calculated values using data 

currently required to be collected to perform emissions calculations. For all of these additional 

data elements, the EPA has estimated a nominal additional cost to report the data element and 

fulfill the recordkeeping requirements. The total costs associated with reporting and 
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recordkeeping for the 26 data elements in 10 subparts is $80,000. These costs represent the cost 

for all affected facilities in the first year. 

B. Additional Impacts of the Proposed Amendments

The proposed confidentiality determinations for the new data elements would not affect 

whether and how data are reported and, therefore, would not impose any additional burden on 

sources. 

VI. Statutory and Executive Order Reviews 

A. Executive Order 12866: Regulatory Planning and Review and Executive Order 13563: 

Improving Regulation and Regulatory Review

Under Executive Order 12866 (58 FR 51735, October 4, 1993), this action is a 

“significant regulatory action” because this action raises novel legal or policy issues arising out 

of legal mandates, the President’s priorities, or principles set forth in the executive order. 

Accordingly, the EPA submitted this action to the Office of Management and Budget (OMB) for 

review under Executive Orders 12866 and 13563 (76 FR 3821, January 21, 2011) and any 

changes made in response to OMB recommendations have been documented in the docket for 

this action. 

B. Paperwork Reduction Act

This action proposes to amend reporting and recordkeeping requirements and verification 

procedures for the GHGRP. In addition, the EPA is proposing confidentiality determinations for 

the proposed new data elements in this action. The proposed amendments to the reporting 

requirements in the source category-specific subparts are not anticipated to result in significant 

burden for reporters. The new data elements required to be reported are expected to be readily 
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available for affected facilities, or easily calculated using data already required to be collected 

(e.g., a monthly value is currently reported and an annual value is proposed to be reported). 

Impacts associated with the proposed changes to the reporting requirements in each 

subpart are detailed in the memorandum “Impacts Analysis of the Proposed 2015 Inputs 

Proposal” (see Docket ID No. EPA-HQ-OAR-2010-0929). The Office of Management and 

Budget (OMB) has previously approved the information collection requirements for 40 CFR part 

98 under the provisions of the Paperwork Reduction Act, 44 U.S.C. 3501 et seq and has assigned 

OMB control number 2060-0629, ICR 2300.10. OMB has approved the information collection 

requirements for this rulemaking and has assigned OMB control number 2060-new, ICR 

2483.01. The OMB control numbers for the EPA’s regulations in 40 CFR are listed in 40 CFR 

part 9. 

C. Regulatory Flexibility Act (RFA)

The RFA generally requires an agency to prepare a regulatory flexibility analysis of any 

rule subject to notice and comment rulemaking requirements under the Administrative Procedure 

Act or any other statute unless the agency certifies that the rule will not have a significant 

economic impact on a substantial number of small entities. Small entities include small 

businesses, small organizations, and small governmental jurisdictions. 

For purposes of assessing the impacts of today’s proposed rule amendments on small 

entities, small entity is defined as: (1) a small business as defined by the Small Business 

Administration’s (SBA) regulations at 13 CFR 121.201; (2) a small governmental jurisdiction 

that is a government of a city, county, town, school district or special district with a population of 

less than 50,000; or (3) a small organization that is any not-for-profit enterprise which is 

independently owned and operated and is not dominant in its field. After considering the 
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economic impacts of today’s proposed amendments on small entities, I certify that this action 

will not have a significant economic impact on a substantial number of small entities. The small 

entities directly regulated by these proposed rule amendments include small businesses across all 

sectors of the economy encompassed by Part 98, small governmental jurisdictions, and small 

non-profits. We have determined that these facilities will experience impacts of roughly a firstyear cost of $66 per facility for learning new procedures for the verification tool and an annual 

cost of $100 per facility for the recordkeeping and reporting of 26 new data elements. 

Although these proposed rule amendments will not have a significant economic impact 

on a substantial number of small entities, the EPA nonetheless has tried to reduce the impact of 

this rule on small entities. The EPA supports a “help desk” for the Greenhouse Gas Reporting 

Program, which would be available to answer questions on the provisions in this rulemaking.

We continue to be interested in the potential impacts of the proposed rule amendments on 

small entities and welcome comments on issues related to such impacts. 

D. Unfunded Mandates Reform Act (UMRA)

The proposed amendments and confidentiality determinations do not contain a federal 

mandate that may result in expenditures of $100 million or more for State, local, and tribal 

governments, in the aggregate, or the private sector in any one year. Thus, the proposed 

amendments and confidentiality determinations are not subject to the requirements of sections 

202 or 205 of UMRA. 

This rule is also not subject to the requirements of section 203 of UMRA because it 

contains no regulatory requirements that might significantly or uniquely affect small 

governments. This action proposes to amend reporting and recordkeeping requirements and 

verification procedures for the GHGRP. In addition, the EPA is proposing confidentiality 
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Page 59 of 98 

determinations for the proposed new data elements in this action. Therefore, this action is not 

subject to the requirements of section 203 of the UMRA. 

E. Executive Order 13132: Federalism

The action does not have federalism implications. It will not have substantial direct 

effects on the states, on the relationship between the national government and the States, or on 

the distribution of power and responsibilities among the various levels of government, as 

specified in Executive Order 13132. The proposed amendments and confidentiality 

determinations apply to facilities that directly emit greenhouses gases and fuel and chemicals 

suppliers. These proposed changes do not apply to governmental entities unless the government 

entity owns a facility that directly emits GHGs above threshold levels (such as a large stationary 

combustion device), so relatively few government facilities would be affected. Moreover, for 

government facilities that are subject to the rule, the proposed revisions will not have a 

significant cost impact. This proposed action also does not limit the power of states or localities 

to collect GHG data and/or regulate GHG emissions. Thus, Executive Order 13132 does not 

apply to this rule. 

In the spirit of Executive Order 13132, and consistent with EPA policy to promote 

communications between the EPA and State and local governments, the EPA specifically solicits 

comments on this proposed action from State and local officials. 

F. Executive Order 13175: Consultation and Coordination with Indian Tribal Governments.

This proposed action does not have tribal implications, as specified in Executive Order 

13175 (65 FR 67249, November 9, 2000). The proposed amendments and confidentiality 

determinations apply directly to facilities that directly emit greenhouses gases or that are 

suppliers of GHGs. They would not have tribal implications unless the tribal entity owns a 
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Page 60 of 98 

facility that directly emits GHGs above threshold levels (such as a landfill or large combustion 

device). Relatively few tribal facilities would be affected. Thus, Executive Order 13175 does not 

apply to this action. 

G. Executive Order 13045: Protection of Children from Environmental Health Risks and Safety 

Risks

The EPA interprets Executive Order 13045 (62 FR 19885, April 23, 1997) as applying 

only to those regulatory actions that concern health or safety risks, such that the analysis required 

under section 5-501 of the Executive Order has the potential to influence the regulation. This 

proposed action is not subject to Executive Order 13045 because it does not establish an 

environmental standard intended to mitigate health or safety risks. 

H. Executive Order 13211: Actions that Significantly Affect Energy Supply, Distribution, or Use

This proposed action is not a “significant energy action” as defined in Executive Order 

13211 (66 FR 28355, May 22, 2001), because it is not likely to have a significant adverse effect 

on the supply, distribution, or use of energy. Part 98 relates to monitoring, reporting, and 

recordkeeping and does not impact energy supply, distribution, or use. This action proposes to

amend reporting and recordkeeping requirements and verification procedures for the GHGRP. In 

addition, the EPA is proposing confidentiality determinations for the proposed new data 

elements in this action. These proposed amendments and confidentiality determinations do not 

make any changes to the existing monitoring, recordkeeping, or reporting requirements under 

Part 98 that affect the supply, distribution, or use of energy. 

I. National Technology Transfer and Advancement Act

Section 12(d) of the National Technology Transfer and Advancement Act of 1995 

(NTTAA), Public Law No. 104-113, 12(d) (15 U.S.C. 272 note) directs the EPA to use voluntary 
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Page 61 of 98 

consensus standards in its regulatory activities unless to do so would be inconsistent with 

applicable law or otherwise impractical. Voluntary consensus standards are technical standards 

(e.g., materials specifications, test methods, sampling procedures, and business practices) that are 

developed or adopted by voluntary consensus standards bodies. NTTAA directs the EPA to 

provide Congress, through OMB, explanations when the Agency decides not to use available and 

applicable voluntary consensus standards. 

This proposed rulemaking does not involve any new technical standards. Therefore, the 

EPA is not considering the use of any voluntary consensus standards. 

J. Executive Order 12898: Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations

Executive Order 12898 (59 FR 7629, February 16, 1994) establishes federal executive 

policy on environmental justice. Its main provision directs federal agencies, to the greatest extent 

practicable and permitted by law, to make environmental justice part of their mission by 

identifying and addressing, as appropriate, disproportionately high and adverse human health or 

environmental effects of their programs, policies, and activities on minority populations and lowincome populations in the United States. 

The EPA has determined that these proposed rule amendments will not have 

disproportionately high and adverse human health or environmental effects on minority or lowincome populations because the amendments do not affect the level of protection provided to 

human health or the environment. This is because the proposed amendments address information 

collection and reporting and verification procedures. 
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Proposed Rule Amendments and Confidentiality Determinations 

for Certain Data Elements Required under the 

Mandatory Greenhouse Gas Reporting Rule 

Page 62 of 98 

List of Subjects 40 CFR Part 98 

Environmental protection, Administrative practice and procedure, Greenhouse gases, 

Reporting and recordkeeping requirements. 

Dated: 

 

Gina McCarthy, 

Administrator. 
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For the reasons stated in the preamble, title 40, chapter I, of the Code of Federal 

Regulations is proposed to be amended as follows: 

PART 98—MANDATORY GREENHOUSE GAS REPORTING 

1.The authority citation for part 98 continues to read as follows: 

Authority: 42 U.S.C. 7401, et seq. 

Subpart A—[AMENDED] 

2.Section 98.3 is amended by revising paragraphs (c)(4)(vii), (d)(3)(v), (g) introductory 

text, and (g)(2)(i) to read as follows: 

§ 98.3 What are the general monitoring, reporting, recordkeeping and verification 

requirements of this part. 

* * * * * 

(c) * * * 

(4) * * * 

(vii) The owner or operator of a facility is not required to report the data elements 

specified in Table A-6 to this subpart for calendar years 2010 through 2011 until March 31, 

2013. The owner or operator of a facility is not required to report the data elements specified in 

Table A-7 to this subpart for calendar years 2010 through 2013 until March 31, 2015. Data 

elements specified in Table A-7 to this subpart for calendar years 2010 through 2013 must be 

submitted as part of the annual report for reporting year 2014. 

* * * * * 

(d) * * * 

(3) * * * 
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(v) For each stationary fuel combustion source that that meets the criteria specified in § 

98.36(f) of this part, report any facility operating data or process information used for the GHG 

emission calculations. 

* * * * * 

(g) Recordkeeping. An owner or operator that is required to report GHGs under this part 

must keep records as specified in this paragraph. Except as otherwise provided in this paragraph, 

retain all required records for at least 3 years from the date of submission of the annual GHG 

report for the reporting year in which the record was generated. The records shall be kept in an 

electronic or hard-copy format (as appropriate) and recorded in a form that is suitable for 

expeditious inspection and review. If a reporter is required under § 98.5(b) to use software 

specified by the Administrator to enter data to calculate the reported GHGs, all records required 

under Part 98 must be retained by the reporter for 5 years from the date of submission of the 

annual GHG report for the reporting year in which the record was generated. Upon request by 

the Administrator, the records required under this section must be made available to EPA. 

Records may be retained off site if the records are readily available for expeditious inspection 

and review. For records that are electronically generated or maintained, the equipment or 

software necessary to read the records shall be made available, or, if requested by EPA, 

electronic records shall be converted to paper documents. You must retain the following records, 

in addition to those records prescribed in each applicable subpart of this part: 

* * * * * 

(2) * * * 
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(i) The GHG emissions calculations and methods used. For data required by § 98.5(b) to 

be entered into the software specified by the Administrator, maintain the entered data in the 

format generated by the software specified by the Administrator. 

* * * * * 

3.Section 98.5 is revised to read as follows: 

§ 98.5 How is the report submitted? 

(a) Each GHG report and certificate of representation for a facility or supplier must be 

submitted electronically in accordance with the requirements of § 98.4 and in a format specified 

by the Administrator. 

(b) For reporting year 2014 and thereafter, you must enter into verification software 

specified by the Administrator the data used as inputs to the calculation methods specified in 

Table A-8 to Part 98, excluding data required to be reported in the reporting section of each 

subpart listed in Table A-8 to Part 98. 

4.Table A-7 to Subpart A of Part 98 is revised to read as follows: 

Table A–7 to Subpart A of Part 98—Data Elements That Are Inputs to Emission Equations 

and for Which the Reporting Deadline Is March 31, 2015 

Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which reporting date is 

March 31, 2015 (“All” means all data elements in 

the cited paragraph are not required to be 

reported until March 31, 2015) 

A 98.3(d)(3)(v) All. 

C 98.36(b)(9)(iii) Only estimate of the heat input.1

C 98.36(c)(2)(ix) Only estimate of the heat input from each type of fuel 

listed in Table C–2.1

C 98.36(e)(2)(i) All.1

C 98.36(e)(2)(ii)(A) All.1

C 98.36(e)(2)(ii)(C) Only HHV value for each calendar month in which 

HHV determination is required.1
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which reporting date is 

March 31, 2015 (“All” means all data elements in 

the cited paragraph are not required to be 

reported until March 31, 2015) 

C 98.36(e)(2)(ii)(D) All.1

C 98.36(e)(2)(iv)(A) All.1

C 98.36(e)(2)(iv)(C) All.1

C 98.36(e)(2)(iv)(F) All.1

C 98.36(e)(2)(ix)(D) All.1

C 98.36(e)(2)(ix)(E) All.1

C 98.36(e)(2)(ix)(F) All.1

E 98.56(g) All. 

E 98.56(h) All. 

E 98.56(j)(4) All. 

E 98.56(j)(5) All. 

E 98.56(j)(6) All. 

E 98.56(l) All. 

H 98.86(b)(11) All. 

H 98.86(b)(13) Name of raw kiln feed or raw material. 

L 98.126(b)(10) All. 

L 98.126(b)(11) All. 

L 98.126(b)(12) All. 

O 98.156(d)(2) All. 

O 98.156(d)(3) All. 

O 98.156(d)(4) All. 

Q 98.176(f)(1) All. 

V 98.226(i) All. 

V 98.226(j) All. 

V 98.226(m)(4) All. 

V 98.226(m)(5) All. 

V 98.226(m)(6) All. 
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which reporting date is 

March 31, 2015 (“All” means all data elements in 

the cited paragraph are not required to be 

reported until March 31, 2015) 

V 98.226(p) All. 

W 98.236(c)(1)(i) All. 

W 98.236(c)(1)(ii) All. 

W 98.236(c)(1)(iii) All. 

W 98.236(c)(2)(i) All. 

W 98.236(c)(3)(i) All. 

W 98.236(c)(3)(ii) All. 

W 98.236(c)(3)(iii) All. 

W 98.236(c)(4)(i)(A) All. 

W 98.236(c)(4)(i)(B) All. 

W 98.236(c)(4)(i)(C) All. 

W 98.236(c)(4)(i)(D) All. 

W 98.236(c)(4)(i)(E) All. 

W 98.236(c)(4)(i)(F) All. 

W 98.236(c)(4)(i)(G) All. 

W 98.236(c)(4)(i)(H) All. 

W 98.236(c)(4)(ii)(A) All. 

W 98.236(c)(5)(iii) All. 

W 98.236(c)(5)(iv) All. 

W 98.236(c)(5)(v) All. 

W 98.236(c)(6)(i)(B) All. 

W 98.236(c)(6)(i)(D) All. 

W 98.236(c)(6)(i)(E) All. 

W 98.236(c)(6)(i)(F) All. 

W 98.236(c)(6)(ii)(A) All. 

W 98.236(c)(6)(ii)(B) All. 

W 98.236(c)(7)(i) All. 
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which reporting date is 

March 31, 2015 (“All” means all data elements in 

the cited paragraph are not required to be 

reported until March 31, 2015) 

W 98.236(c)(8)(i)(B) All. 

W 98.236(c)(8)(i)(C) All. 

W 98.236(c)(8)(i)(F) All. 

W 98.236(c)(8)(ii)(A) All. 

W 98.236(c)(8)(ii)(D) All. 

W 98.236(c)(8)(iii)(A) All. 

W 98.236(c)(8)(iii)(D) All. 

W 98.236(c)(8)(iii)(E) All. 

W 98.236(c)(10)(ii) All. 

W 98.236(c)(10)(iii) All. 

W 98.236(c)(11)(ii) All. 

W 98.236(c)(12)(ii) All. 

W 98.236(c)(12)(iii) All. 

W 98.236(c)(12)(v) All. 

W 98.236(c)(13)(i)(B) All. 

W 98.236(c)(13)(i)(E) All. 

W 98.236(c)(13)(i)(F) All. 

W 98.236(c)(13)(ii)(A) All. 

W 98.236(c)(13)(ii)(B) All. 

W 98.236(c)(13)(iii)(A) All. 

W 98.236(c)(13)(iii)(B) All. 

W 98.236(c)(13)(v)(A) All. 

W 98.236(c)(14)(i)(B) All. 

W 98.236(c)(14)(ii)(A) All. 

W 98.236(c)(14)(ii)(B) All. 

W 98.236(c)(14)(iii)(A) All. 

W 98.236(c)(14)(iii)(B) All. 
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which reporting date is 

March 31, 2015 (“All” means all data elements in 

the cited paragraph are not required to be 

reported until March 31, 2015) 

W 98.236(c)(14)(v)(A) All. 

W 98.236(c)(15)(i)(A) All. 

W 98.236(c)(15)(i)(B) All. 

W 98.236(c)(15)(ii)(A) All. 

W 98.236(c)(15)(ii)(B) All. 

W 98.236(c)(16)(i) All. 

W 98.236(c)(16)(ii) All. 

W 98.236(c)(16)(iii) All. 

W 98.236(c)(16)(iv) All. 

W 98.236(c)(16)(v) All. 

W 98.236(c)(16)(vi) All. 

W 98.236(c)(16)(vii) All. 

W 98.236(c)(16)(viii) All. 

W 98.236(c)(16)(ix) All. 

W 98.236(c)(16)(x) All. 

W 98.236(c)(16)(xi) All. 

W 98.236(c)(16)(xii) All. 

W 98.236(c)(16)(xiii) All. 

W 98.236(c)(16)(xiv) All. 

W 98.236(c)(17)(ii) All. 

W 98.236(c)(17)(iii) All. 

W 98.236(c)(17)(iv) All. 

W 98.236(c)(18)(i) All. 

W 98.236(c)(18)(ii) All. 

W 98.236(c)(19)(iv) All. 

W 98.236(c)(19)(vii) All. 

Y 98.256(h)(5) Only value of the correction. 
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which reporting date is 

March 31, 2015 (“All” means all data elements in 

the cited paragraph are not required to be 

reported until March 31, 2015) 

Y 98.256(k)(4) Only mole fraction of methane in coking gas. 

Y 98.256(n)(3) All (if used in Equation Y–21 to calculate emissions 

from equipment leaks). 

Y 98.256(o)(4)(vi) Only tank-specific methane composition data and gas 

generation rate data. 

AA 98.276(e) All. 

CC 98.296(b)(10)(i) All. 

CC 98.296(b)(10)(ii) All. 

CC 98.296(b)(10)(iii) All. 

CC 98.296(b)(10)(iv) All. 

CC 98.296(b)(10)(v) All. 

CC 98.296(b)(10)(vi) All. 

II 98.356(d)(2) All (if conducting weekly sampling). 

II 98.356(d)(3) All (if conducting weekly sampling). 

II 98.356(d)(4) Only weekly average temperature (if conducting 

weekly sampling). 

II 98.356(d)(5) Only weekly average moisture content (if conducting 

weekly sampling). 

II 98.356(d)(6) Only weekly average pressure (if conducting weekly 

sampling). 

1

 Required to be reported only by stationary fuel combustion sources (e.g., individual units, 

aggregations of units, common pipes, or common stacks) subject to subpart C of part 98 that 

meet both of the following criteria: (1) the stationary fuel combustion source contains at least 

one combustion unit connected to a fuel-fired electric generator that has been granted access by 

the Public Utilities Commission to deliver power to the local or regional electric power grid 

(excluding generators that are connected to combustion units subject to subpart D of this part); 

and (2) the stationary fuel combustion source is located at a facility for which the sum of the 

nameplate capacities for all such electric generators is greater than or equal to 1 megawatt 

electric output. 

5.Table A-8 to Subpart A of Part 98 is added to read as follows: 
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Table A–8 to Subpart A of Part 98—Calculation Methods For Which Inputs To the 

Calculation Methods Must be Entered Into Verification Software Specified By the 

Administrator. 

Subpart Calculation Method (Equation Number in 40 CFR Part 98 or Description 

of Method) 

Subpart C 1 C-1, C-1a, C-1b, C-2b, C-2c, C-3, C-4, C-5, C-8, C-8a, C-8b, C-10, C-13, the 

calculation method specified in § 98.3(d)(3)(iv) of subpart A of part 98 

Subpart E E-1, E-2, E-3a, E-3b, E-3c, E-3d 

Subpart F F-2 (including the method for calculating the anode effect minutes per cell-day 

(AEM) and slope coefficients (SCF4), F-3 (including the method for 

calculating the overvoltage factor (EFCF4)), F-5, F-6, F-7, F-8 

Subpart G G-1, G-2, G-3 

Subpart H H-2 (including the method in § 98.84(d) of subpart H of part 98 for calculating 

the quantity of clinker produced), H-3, H-4, H-5 

Subpart K K-1, K-3 

Subpart L L-1, L-2, L-3, L-4, L-6, L-7, L-8, L-17, L-18, L-20, L-21, L-22, L-23, L-25, L26, L-27, L-31, L-34 

Subpart N N-1 

Subpart O O-3, O-4, O-8, O-9 (including the calculation method specified in § 

98.154(l)(2) of subpart O of part 98) 

Subpart P P-1, P-2, P-3 

Subpart Q Q-1, Q-2, Q-3, Q-4, Q-5, Q-6, Q-7, the calculation methods specified in § 

98.173(b)(2)(iii), (b)(2)(iv), and (c) of subpart Q of part 98 

Subpart R R-1 

Subpart S S-1, S-2, S-3, S-4 (including the calculation method specified in § 98.194(a) 

Subpart U U-1, U-2 

Subpart V V-2, V-3a, V-3b, V-3c, V-3d 

Subpart X X-1, X-2, X-3, C-8 

Subpart Y Y-1a, Y-1b, Y-3, Y-4, Y-6, Y-8, Y-11, Y-12 (including the method for 

correcting the calculation, if applicable, as specified in § 98.253(f)(5)), Y-13, 

Y-14, Y-15, Y-16a, Y-16b, Y-17, Y-18, Y-19, Y-20, Y-22, Y-23, the methods 

for calculating emissions from coke burn-off specified in § 98.253(c)(4) and 

(5) (alternatives to using Equations Y-9 and Y-10 of Part 98), the calculation 

method specified in § 98.253(n) of subpart Y of part 98 

Subpart Z Z-1a, Z-1b 

Subpart AA C-1, C-1a, C-1b, C-2a, C-3, C-4, C-5, C-8, C-8a, C-8b, C-9a, AA-1, AA-2, 

AA-3 

Subpart BB BB-1, BB-2 

Subpart CC CC-1, CC-2 

Subpart EE EE-2 

Subpart GG GG-1 

Subpart TT TT-2, TT-3 

1

 Does not apply to any stationary fuel combustion sources (e.g., individual units, aggregations of 

units, common pipes, or common stacks) meeting both of the following criteria: (1) the 
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stationary fuel combustion source contains at least one combustion unit connected to a fuel-fired 

electric generator electric (excluding generators that are connected to combustion units subject to 

subpart D of this part); and (2) the stationary fuel combustion source is located at a facility for 

which the sum of the nameplate capacities for all such electric generators is greater than or equal 

to 1 megawatt electric output. 

Subpart C—[AMENDED] 

6.Section 98.36 is amended by: 

a. Revising paragraph (a); 

b. Revising paragraph (b)(9)(iii) and adding paragraph (b)(9)(iv); 

c. Revising paragraph (c)(2)(ix) and adding paragraph (c)(2)(x); 

d. Revising paragraphs (e)(2)(i), (e)(2)(ii)(A), (e)(2)(ii)(C), and (e)(2)(ii)(D); and adding 

paragraph (e)(2)(ii)(E); and 

e. Revising paragraphs (e)(2)(iv)(A), (e)(2)(iv)(C), (e)(2)(iv)(F), and (e)(2)(ix)(D) 

through (F); and adding paragraph (f). 

The revisions and additions read as follows: 

§ 98.36 Data reporting requirements. 

* * * * * 

(a) In addition to the facility-level information required under §98.3, the annual GHG 

emissions report shall contain the unit-level or process-level data specified in paragraphs (b) 

through (f) of this section, as applicable, for each stationary fuel combustion source (e.g., 

individual unit, aggregation of units, common pipe, or common stack). 

(b) * * * 

(9) * * * 

(iii) The annual CH4 and N2O emissions for each type of fuel listed in Table C–2 of this 

subpart that was combusted in the unit during the report year, expressed in metric tons of each 

gas and in metric tons of CO2e. 
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(iv) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, report an estimate of the heat input from each type of fuel listed in 

Table C–2 of this subpart that was combusted in the unit during the report year. 

* * * * * 

(c) * * * 

(2) * * * 

(ix) For each type of fuel listed in Table C–2 of this subpart that was combusted during 

the report year in the units sharing the common stack or duct during the report year, the annual 

CH4 and N2O mass emissions from the units sharing the common stack or duct, expressed in 

metric tons of each gas and in metric tons of CO2 e. 

(x) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, an estimate of the heat input from each type of fuel listed in Table 

C–2 of this subpart that was combusted during the report year in the units sharing the common 

stack or duct during the report year. 

* * * * * 

(e) * * * 

(2) * * * 

(i) For the Tier 1 Calculation Methodology, for each stationary fuel combustion source 

that meets the criteria specified in paragraph (f) of this section, report the total quantity of each 

type of fuel combusted in the unit or group of aggregated units (as applicable) during the 

reporting year, in short tons for solid fuels, gallons for liquid fuels and standard cubic feet for 

gaseous fuels, or, if applicable, therms or mmBtu for natural gas. 

(ii) * * * 
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(A) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, the total quantity of each type of fuel combusted in the unit or group 

of aggregated units (as applicable) during each month of the reporting year. Express the quantity 

of each fuel combusted during the measurement period in short tons for solid fuels, gallons for 

liquid fuels, and scf for gaseous fuels. 

* * * * * 

(C) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, the high heat values used in the CO2 emissions calculations for each 

type of fuel combusted during the reporting year, in mmBtu per short ton for solid fuels, mmBtu 

per gallon for liquid fuels, and mmBtu per scf for gaseous fuels. Report a HHV value for each 

calendar month in which HHV determination is required. If multiple values are obtained in a 

given month, report the arithmetic average value for the month. Indicate whether each reported 

HHV is a measured value or a substitute data value. 

(D) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, if Equation C–2c of this subpart is used to calculate CO2 mass 

emissions, report the total quantity (i.e., pounds) of steam produced from MSW or solid fuel 

combustion during each month of the reporting year, and the ratio of the maximum rate heat 

input capacity to the design rated steam output capacity of the unit, in mmBtu per lb of steam. 

(E) For each HHV used in the CO2 emissions calculations for each type of fuel 

combusted during the reporting year, indicate whether the HHV is a measured value or a 

substitute data value. 

* * * * * 

(iv) * * * 
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(A) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, the quantity of each type of fuel combusted in the unit or group of 

units (as applicable) during each month of the reporting year, in short tons for solid fuels, gallons 

for liquid fuels, and scf for gaseous fuels. 

* * * * * 

(C) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, the carbon content and, if applicable, gas molecular weight values 

used in the emission calculations (including both valid and substitute data values). For each 

calendar month of the reporting year in which carbon content and, if applicable, molecular 

weight determination is required, report a value of each parameter. If multiple values of a 

parameter are obtained in a given month, report the arithmetic average value for the month. 

Express carbon content as a decimal fraction for solid fuels, kg C per gallon for liquid fuels, and 

kg C per kg of fuel for gaseous fuels. Express the gas molecular weights in units of kg per kgmole. 

* * * * * 

(F) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, the annual average HHV, when measured HHV data, rather than a 

default HHV from Table C–1 of this subpart, are used to calculate CH4 and N2O emissions for a 

Tier 3 unit, in accordance with §98.33(c)(1). 

* * * * * 

(ix) * * * 
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(D) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, the carbon-based F-factor used in Equation C–13 of this subpart, for 

each type of fossil fuel combusted, in scf CO2 per mmBtu. 

(E) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, the annual average HHV value used in Equation C–13 of this 

subpart, for each type of fossil fuel combusted, in Btu/lb, Btu/gal, or Btu/scf, as appropriate. 

(F) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, the total quantity of each type of fossil fuel combusted during the 

reporting year, in lb, gallons, or scf, as appropriate. 

* * * * * 

(f) Each stationary fuel combustion source (e.g., individual unit, aggregation of units, 

common pipe, or common stack) subject to reporting under paragraph (b), (c), or (d)(2) of this 

section must indicate if both of the following two conditions are met: 

(1) The stationary combustion source contains at least one combustion unit connected to 

a fuel-fired electric generator that has been granted access by the Public Utilities Commission to 

deliver power to the local or regional electric power grid (excluding generators that are 

connected to combustion units that are subject to subpart D of this part). 

(2) The stationary fuel combustion source is located at a facility for which the sum of the 

nameplate capacities for all electric generators specified in paragraph (f)(1) of this section is 

greater than or equal to 1 megawatt electric output. 

Subpart E—[AMENDED] 

7.Section 98.56 is amended by: 

a. Revising the introductory text; 
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b. Removing and reserving paragraphs (b), (c), (j)(1), and (j)(3); and 

c. Adding paragraphs (m) and (n). 

The revisions and additions read as follows: 

§ 98.56 Data reporting requirements. 

In addition to the information required by §98.3(c), each annual report must contain the 

information specified in paragraphs (a) through (n) of this section at the facility level. 

* * * * * 

(m) Annual quantity of cyclohexane fed to all production lines combined (metric tons). 

(n) Annual percent N2O emission reduction for all production units combined. 

* * * * * 

Subpart F—[AMENDED] 

8.Section 98.66 is amended by: 

a. Removing and reserving paragraphs (a) and (c)(2); 

b. Revising paragraphs (c)(3), (e)(1), and (f)(1); and 

c. Removing and reserving paragraph (g). 

The revisions read as follows: 

§ 98.66 Data reporting requirements. 

* * * * * 

(c) * * * 

(3) The last date when the smelter-specific-slope coefficients (or overvoltage emission 

factors) were measured. 

* * * * * 

(e) * * * 
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(1) Annual anode consumption if using the method in §98.63(g). 

* * * * * 

(f) * * * 

(1) Annual paste consumption if using the method in §98.63(g). 

* * * * * 

Subpart G—[AMENDED] 

9.Section 98.76 is amended by: 

a. Removing and reserving paragraph (b)(2) and paragraphs (b)(7) through (11); and 

b. Adding paragraphs (b)(14) and (15). 

The revisions and additions read as follows: 

§ 98.76 Data reporting requirements. 

* * * * * 

(b) * * * 

(14) Annual ammonia production (metric tons). 

(15) Annual methanol production (metric tons), if this quantity is not reported under 

subpart X of Part 98. 

Subpart H—[AMENDED] 

10. Section 98.86 is amended by: 

a. Removing and reserving paragraphs (b)(2), (b)(5), (b)(6), (b)(8), (b)(10), and (12); 

b. Revising paragraphs (b)(13) and (15); and 

c. Adding paragraphs (b)(16) through (18). 

The revisions and additions read as follows: 

§ 98.86 Data reporting requirements. 
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* * * * * 

(b) * * * 

(13) Name of raw kiln feed or raw material. 

* * * * * 

(15) Method used to determine the monthly clinker production from each kiln. 

(16) Annual clinker production (metric tons). 

(17) Annual average clinker CO2 emission factor for the facility, averaged across all kilns 

(metric tons CO2/metric ton clinker produced). 

(18) Annual average CKD CO2 emission factor for the facility, averaged across all kilns 

(metric tons CO2/metric ton CKD produced). 

Subpart K—[AMENDED] 

11. Section 98.116 is amended by: 

a. Removing and reserving paragraphs (b), (e)(4), and (e)(5); and 

b. Revising paragraph (e)(6). 

The revisions read as follows: 

§ 98.116 Data reporting requirements. 

* * * * * 

(e) * * * 

(6) List the method used for the determination of carbon content for each material 

included for the calculation of annual process CO2 emissions for each EAF (e.g., supplier 

provided information, analyses of representative samples you collected). 

* * * * * 

Subpart L—[AMENDED] 
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12. Section 98.126 is amended by: 

a. Revising paragraph (b)(1); 

b. Removing and reserving paragraph (b)(2); 

c. Revising paragraphs (b)(6), (b)(7), and (b)(8)(i) through (iv); 

d. Removing and reserving paragraphs (b)(8)(v) and (b)(9); 

e. Revising paragraph (c)(1); 

f. Removing and reserving paragraph (c)(2); 

g. Revising paragraph (d); and 

h. Removing and reserving paragraphs (f)(1), (g)(1), and (h)(2). 

The revisions read as follows: 

§ 98.126 Data reporting requirements. 

* * * * * 

(b) * * * 

(1) If you calculate the relative and absolute errors under § 98.123(b)(1), the absolute and 

relative errors calculated under paragraph § 98.123(b)(1). 

* * * * * 

(6) The chemical formula of each fluorine-containing reactant that is fed into the process. 

(7) The chemical formula of each fluorine-containing product produced by the process. 

(8) * * * 

(i) The chemical formula of each fluorine-containing product that is removed from the 

process and fed into the destruction device. 

(ii) The chemical formula of each fluorine-containing by-product that is removed from 

the process and fed into the destruction device. 
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(iii) The chemical formula of each fluorine-containing reactant that is removed from the 

process and fed into the destruction device. 

(iv) The chemical formula of each fluorine-containing by-product that is removed from 

the process and recaptured. 

* * * * * 

(c) * * * 

(1) The identity of the process activity used to estimate emissions (e.g., product produced 

or reactant consumed). 

* * * * * 

(d) Reporting for missing data. Where missing data have been estimated pursuant to § 

98.125, you must report: 

(1) The reason the data were missing, the length of time the data were missing, and the 

method used to estimate the missing data. 

(2) Estimates of the missing data for all missing data associated with data elements 

required to be reported in this section. 

* * * * * 

Subpart N—[AMENDED] 

13. Section 98.146 is amended by revising paragraph (b)(2) and removing and 

reserving paragraphs (b)(4) and (b)(6) to read as follows: 

§ 98.146 Data reporting requirements. 

* * * * * 

(b) * * * 
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(2) Annual quantity of each carbonate-based raw material charged (tons) to all furnaces 

combined. 

* * * * * 

Subpart O—[AMENDED] 

14. Section 98.156 is amended by: 

a. Removing and reserving paragraphs (a)(2), (a)(7) through (10), (b)(1), and (b)(2); 

b. Revising paragraph (d) introductory text; and 

c. Removing and reserving paragraphs (d)(1), (d)(5), and (e)(1). 

The revisions read as follows: 

§ 98.156 Data reporting requirements. 

* * * * * 

(d) If the HFC–23 concentration measured pursuant to §98.154(l) is greater than that 

measured during the performance test that is the basis for the destruction efficiency (DE), the 

facility shall report the following: 

* * * * * 

Subpart P—[AMENDED] 

15. Section 98.166 is amended by: 

a. Revising the introductory text; 

b. Removing and reserving paragraphs (b)(2), (b)(5), and (b)(6); and 

c. Adding paragraphs (b)(7) and (e). 

The revisions and additions read as follows: 

§ 98.166 Data reporting requirements. 
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In addition to the information required by §98.3(c), each annual report must contain the 

information specified in paragraphs (a) or (b) of this section, as appropriate, and paragraphs (c) 

through (e) of this section: 

* * * * * 

(b) * * * 

(7) Name and annual quantity (metric tons) of each carbon-containing fuel and feedstock. 

* * * * * 

(e) Annual methanol production (metric tons), if this quantity is not reported under 

subpart X of Part 98. 

Subpart Q—[AMENDED] 

16. Section 98.176 is amended by: 

a. Revising paragraph (b); 

b. Removing and reserving paragraphs (e)(1), (e)(3), (e)(4); and adding paragraph (e)(6); 

and 

c. Removing and reserving paragraphs (f)(2) through (4), and (g). 

The revisions and additions read as follows: 

§ 98.176 Data reporting requirements. 

* * * * * 

(b) If a CEMS is used to measure CO2 emissions, then you must report the annual 

production quantity for the production unit (in metric tons) for taconite pellets, coke, sinter, iron, 

and raw steel. 

* * * * * 

(e) * * * 
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(6) The information specified in paragraphs (e)(6)(i) through (vi) of this section 

aggregated for all process units for which CO2 emissions were determined using the mass 

balance method in § 98.173(b)(1), except as provided in § 98.174(b)(4). 

(i) The annual mass (metric tons) of all gaseous, liquid, and solid fuels (combined) used 

in process units for which CO2 emissions were determined using Equations Q-1 through Q-7 of 

this section, calculated as specified in Equation Q-9 of this section. 

ݑܨ݈݁ 	ൌ ቀ∑ ܨ௚, ∗ 	௜ெௐ೔

ெ௏஼

௡

௜ୀଵ ∗ 0.001 ൅ ܨ௟, ∗ ௜ߩ௟, ∗ ௜0.001	൅ ܨ௦,௜ቁ	 (Eq. Q-9) 

Where: 

Fuel = Annual mass of all gaseous, liquid, and solid fuels used in process units 

(metric tons). 

n = Number of process units where fuel is used. 

Fg,i = Annual volume of gaseous fuel combusted (“(Fg)” in Equations Q-1, Q-4 

and Q-7 of this section) for each process (scf). 

MWi = Molecular weight of gaseous fuel used in each process (kg/kg-mole). 

MVC = Molar volume conversion factor at standard conditions, as defined in § 

98.6. Use 849.5 scf per kg mole if you select 68 °F as standard 

temperature and 836.6 scf per kg mole if you select 60 °F as standard 

temperature. 

Fl,i = Annual volume of the liquid fuel combusted (“(Fl)” included in Equation 

Q-1 of this section) for each process unit (gallons). 

Fs,i = Annual mass of the solid fuel combusted (“(Fs)” in Equation Q-1 of this 

section) for each process unit (metric tons). 

ρl,i = Density of the liquid fuel (kg/gallon). 

0.001 = Conversion factor from kg to metric tons. 

(ii) The annual mass (metric tons) of all non-fuel material inputs (combined) specified in 

Equations Q-1 through Q-7 of this section, calculated as specified in Equation Q-10 of this 

section. 
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௡ ௡௜݈݁݁ݐܵ ൅ ݀݁݋ݎݐ݈݁ܿܧ ൅ ݁݁݀ܨ ൅ ݈ܽ݋ܥ ൅ ݊݋ܾݎܽܥ ൅ ݔݑ݈ܨ ൅ ݌ܽݎܵܿ ൅ ݊݋ݎܫ ൅ ܱ ∑ሺ ൌ ܫܨܰ

௜ୀଵ ൅

 (-10Q .Eq (ݎ݄݁ݐܱ൅݁ݎܱ

Where: 

NFI = Annual mass of all non-fuel inputs (to all process unit types) specified in 

Equations Q-1 through Q-7 of this section (metric tons). 

n = Number of process units, all process types. 

O = Annual mass of greenball (taconite) pellets fed to the taconite furnace(s) 

(metric tons). 

Iron = Annual mass of molten iron charged to the basic oxygen furnace(s) plus 

annual mass of direct reduced iron charged to the EAF(s) (metric tons). 

Scrap = Annual mass of ferrous scrap charged to the basic oxygen furnace(s) and 

EAF(s) (metric tons). 

Flux = Annual mass of flux materials charged to the basic oxygen furnace(s) and 

EAF(s) (metric tons). 

Carbon = Annual mass of carbonaceous materials (e.g., coal, coke) charged to the 

basic oxygen furnace(s), EAF(s), and direct reduction furnace(s) (metric 

tons). 

Coal = Annual mass of coal charged to the coke oven battery(s) (metric tons). 

Feed = Annual mass of sinter feed material charged to the sinter process(es) 

(metric tons). 

Electrode = Annual mass of carbon electrode consumed in the EAF(s) (metric tons). 

Steelin = Annual mass of molten steel charged to the decarburization vessels (metric 

tons). 

Ore = Annual mass of iron ore or iron ore pellets fed to the direct reduction 

furnace(s) (metric tons). 

Other = Annual mass of other materials charged to the direction reduction 

furnace(s) (metric tons). 

(iii) The annual mass (metric tons) of all solid and liquid products and byproducts 

(combined) specified in Equations Q-1 through Q-7 of this section, calculated as specified in 

Equation Q-11 of this section. 
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௡∑ሺ ൌ ݏݐܿݑ݀݋ݎܲ

 (-11Q .ሺEq		ሻ ܯܰ ൅ ݊݋ݎܫ ൅ ݎ݁ݐܵ݅݊ ൅ ݇݁݋ܥ ൅ ݈ܵܽ݃ ൅ ௨௧௢݈݁݁ݐܵ ൅ ܴ ൅ ܲ ୀଵ௜

Where: 

Products = Annual mass of all solid and liquid products and by-products (from all 

process units) specified in Equations Q-1 through Q-7 of this section 

(metric tons). 

n = Number of process units, all types. 

P = Annual mass of fired pellets produced by the taconite furnace (metric 

tons). 

R = Annual mass of air pollution control residue from all process units (metric 

tons). 

Steelout = Annual mass of steel produced by the basic oxygen furnace(s), EAF(s) and 

decarburization vessel(s) (metric tons). 

Slag = Annual mass of slag produced by the basic oxygen furnace(s) and EAF(s) 

(metric tons). 

Coke = Annual mass of coke produced by the non-recovery coke batteries (metric 

tons). 

Sinter = Annual mass of sinter produced from the sinter process(es) (metric tons). 

Iron = Annual mass of iron produced from the direct reduction furnace (metric 

tons). 

NM = Annual mass of non-metallic materials produced by the direct reduction 

furnace (metric tons). 

(iv) The weighted average carbon content of all gaseous, liquid, and solid fuels 

(combined) included in Equation Q-9 of this section, calculated as specified in Equation Q-12 of 

this section. 

ܨܥ௔௩௚ ൌ ቀ	∑ ி೒,೔	∗

ಾೈ೔

ಾೇ಴

೙

೔సభ ∗஼೒೑,೔∗଴.଴଴ଵାி೗,೔∗஼೗೑,೔∗଴.଴଴ଵା	ிೞ,೔∗஼ೞ೑	ቁ

ி௨௘௟ (Eq. Q-12) 

Where: 

CFavg = Weighted average carbon content of all gaseous, liquid, and solid fuels 

included in Equation Q-9 of this section (weight fraction). 
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n = Number of gaseous, liquid, and solid fuel input to each process unit as 

used in Equation Q-9. 

Cgf,i = Average carbon content of the gaseous fuel used in each process, from the 

fuel analysis results (kg C per kg of fuel). 

Clf,i = Carbon content of the liquid fuel used in each process, from the fuel 

analysis results (kg C per gallon of fuel. 

Csf = Carbon content of the solid fuel used in each process, from the fuel 

analysis (expressed as a decimal fraction, e.g., 95% = 0.95). 

Fuel = Annual mass of all gaseous, liquid, and solid fuels used in process units 

(metric tons), as calculated in Equation Q-9 of this section. 

(v) The weighted average carbon content of all non-fuel inputs to all process units 

(combined) included in Equation Q-10 of this section, calculated as specified in Equation Q-13 

of this section. 

ܫܥ௔௩௚ ൌ ൫∑ ேிூ೔∗஼ಿಷ಺೔ ೙

೔సభ ൯	

ேிூ 			 (Eq. Q-13) 

Where: 

CIavg = Weighted average carbon content of all non-fuel inputs to all process units 

included in Equation Q-10 of this section (weight fraction). 

n = Number of non-fuel inputs to all process units as used in Equation Q-10. 

NFIi = Annual mass of each non-fuel input used in Equation Q-10 (metric tons). 

CNFIi = Average carbon content of each non-fuel input used in Equation Q-10 

(expressed as a decimal fraction). 

NFI = Total of all non-fuel inputs to all process units (metric tons). 

(vi) The weighted average carbon content of all solid and liquid products and byproducts 

from all process units (combined) included in Equation Q-11 of this section, calculated as 

specified in Equation Q-14 of this section. 

ܥܲ௔௩௚ ൌ 	൫∑ ௉௥௢ௗ௨௖௧೔∗஼ು೔ ೙

೔సభ ൯

௉௥௢ௗ௨௖௧௦ (Eq. Q-14) 
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Where: 

CPavg = Weighted average carbon content of all solid and liquid products and 

byproducts from all process units (weight fraction). 

n = Number of products and byproducts from each process unit as used in 

Equation Q-11. 

Producti = Annual mass of each product or byproduct used in Equation Q-11 (metric 

tons). 

Cp,i = Average carbon content of each product or byproduct used in Equation Q11 (expressed as a decimal fraction). 

Products = Mass of all products and byproducts from all process units, calculated in 

Equation Q-11 of this section (metric tons). 

* * * * * 

Subpart R—[AMENDED] 

17. Section 98.186 is amended by removing and reserving paragraphs (b)(6) and 

(b)(7); and revising paragraph (b)(8) to read as follows: 

§ 98.186 Data reporting procedures. 

* * * * * 

(b) * * * 

(8) List the method used for the determination of carbon content for each material used 

for the calculation of annual process CO2 emissions using Equation R–1 of this subpart for each 

smelting furnace (e.g., supplier provided information, analyses of representative samples you 

collected). 

* * * * * 

Subpart S—[AMENDED] 

18. Section 98.196 is amended by: 

a. Revising paragraph (b) introductory text; 
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b. Removing and reserving paragraphs (b)(2), (b)(3), (b)(5), (b)(6), (b)(8), (b)(10), 

(b)(11), and (b)(12); and 

c. Adding paragraph (b)(18). 

The revisions and additions read as follows: 

§ 98.196 Data reporting requirements. 

* * * * * 

(b) If a CEMS is not used to measure CO2 emissions, then you must report the 

information listed in paragraphs (b)(1) through (18) of this section. 

* * * * * 

(18) Annual quantity (metric tons) of lime product sold, by type. 

Subpart U—[AMENDED] 

19. Section 98.216 is amended by removing and reserving paragraphs (b), (e)(1), 

(e)(2), and (f). 

Subpart V—[AMENDED] 

20. Section 98.226 is amended by: 

a. Revising the introductory text; 

b. Removing and reserving paragraphs (d), (m)(1), and (m)(3); and 

c. Adding paragraph (q). 

The revisions and additions read as follows: 

§ 98.226 Data reporting requirements. 

In addition to the information required by § 98.3(c), each annual report must contain the 

information specified in paragraphs (a) through (q) of this section. 

* * * * * 
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(q) Annual percent N2O emission reduction for all production units combined. 

Subpart X—[AMENDED] 

21. Section 98.246 is amended by: 

a. Revising paragraph (a) introductory text and paragraphs (a)(2) and (a)(4); 

b. Adding paragraphs (a)(12) and (13); 

c. Revising paragraph (b) introductory text; 

d. Removing and reserving paragraphs (b)(5)(iii) and (b)(5)(iv); and 

e. Adding paragraphs (b)(9) and (b)(10). 

The revisions and additions read as follows: 

§ 98.246 Data reporting requirements. 

* * * * * 

(a) If you use the mass balance methodology in § 98.243(c), you must report the 

information specified in paragraphs (a)(1) through (a)(13) of this section for each type of 

petrochemical produced, reported by process unit. 

* * * * * 

(2) The type of petrochemical produced, names of products, and names of carboncontaining feedstocks. 

* * * * * 

(4) The temperature (in °F) at which the gaseous feedstock and product volumes used in 

Equation X–1 of this subpart were determined. 

* * * * * 

(12) Name and annual quantity (in metric tons) of each carbon-containing feedstock 

included in Equations X-1, X-2, and X-3 of § 98.243 of this subpart. 
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(13) Name and annual quantity (in metric tons) of each product included in Equations X1, X-2, and X-3 of § 98.243 of this subpart. 

(b) If you measure emissions in accordance with § 98.243(b), then you must report the 

information listed in paragraphs (b)(1) through (b)(10) of this section. 

* * * * * 

(9) Name and annual quantity (in metric tons) of each carbon-containing feedstock. 

(10) Name and annual quantity (in metric tons) of each carbon-containing co-product. 

* * * * * 

Subpart Y—[AMENDED] 

22. Section 98.256 is amended by: 

a. Revising paragraphs (e)(6) and (e)(7) introductory text; 

b. Removing and reserving paragraph (e)(7)(ii); 

c. Revising paragraphs (e)(9) and (e)(10); 

d. Adding paragraph (e)(11); 

e. Revising paragraphs (f)(7) and (f)(10) through (13); 

f. Removing and reserving paragraph (h)(4); 

g. Revising paragraphs (h)(5), (i)(5), (i)(7), and (i)(8); 

h. Removing and reserving paragraph (j)(2); 

i. Revising paragraphs (j)(5) through (9), (k)(3), (k)(4), (l)(5), and (m)(3); 

j. Removing and reserving paragraphs (o)(2)(ii), (o)(4)(ii) through (v), and (o)(6) and (7); 

and 

k. Revising paragraph (p)(2). 

The revisions and additions read as follows: 
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§ 98.256 Data reporting requirements. 

* * * * * 

(e) * * * 

(6) If you use Equation Y–1a of this subpart, an indication of whether daily or weekly 

measurement periods are used, the annual volume of flare gas combusted (in scf/year) and the 

annual average molecular weight (in kg/kg-mole), and annual average carbon content of the flare 

gas (in kg carbon per kg flare gas). 

(7) If you use Equation Y–1b of this subpart, an indication of whether daily or weekly 

measurement periods are used, the annual volume of flare gas combusted (in scf/year), the 

annual average CO2 concentration (volume or mole percent), the number of carbon containing 

compounds other than CO2 in the flare gas stream, and for each of the carbon containing 

compounds other than CO2 in the flare gas stream: 

* * * * * 

(9) If you use Equation Y–3 of this subpart, the number of SSM events exceeding 

500,000 scf/day. 

(10) The basis for the value of the fraction of carbon in the flare gas contributed by 

methane used in Equation Y–4 of this subpart. 

(11) If using Equation Y-3, report: 

(i) Annual quantity of flare gas combusted (in MMscf per year). 

(ii) Annual average molecular weight of flare gas combusted (in mmBtu per MMscf). 

(iii) Annual average carbon content of flare gas combusted (expressed as a decimal 

fraction). 

(f) * * * 
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(7) If you use Equation Y–6 of this subpart, the annual average exhaust gas flow rate, 

%CO2, and %CO. 

* * * * * 

(10) If you use Equation Y–8 of this subpart, the basis for the value of the coke burn-off 

factor, annual throughput of unit, and the average carbon content of coke. 

(11) Indicate whether you use a measured value, a unit-specific emission factor, or a 

default emission factor for CH4 emissions. If you use a unit-specific emission factor for CH4, 

report the basis for the factor. 

(12) Indicate whether you use a measured value, a unit-specific emission factor, or a 

default emission factor for N2O emissions. If you use a unit-specific emission factor for N2O, 

report the basis for the factor. 

(13) If you use Equation Y–11 of this subpart, the number of regeneration cycles or 

measurement periods during the reporting year and the average coke burn-off quantity per cycle 

or measurement period. 

* * * * * 

(h) * * * 

(5) If you recycle tail gas to the front of the sulfur recovery plant, indicate whether the 

recycled flow rate and carbon content are included in the measured data under § 98.253(f)(2) and 

(3). Indicate whether a correction for CO2 emissions in the tail gas was used in Equation Y–12. If 

so, then report: 

(i) The value of the correction. 

(ii) If the following data are not used to calculate the recycling correction factor, report 

the information specified in paragraphs (h)(5)(ii)(A) through (C) of this section. 
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(A) The annual volume of recycled tail gas (in scf/year) only. 

(B) The annual average mole fraction of carbon in the tail gas (in kg-mole C/kg-mole 

gas). 

(C) Indicate whether you used the default (95%) or a unit specific correction, and if used, 

report the approach used. 

* * * * * 

(i) * * * 

(5) If you use Equation Y–13 of this subpart, an indication of whether coke dust is 

recycled to the unit (e.g., all dust is recycled, a portion of the dust is recycled, or none of the dust 

is recycled). 

* * * * * 

(7) Indicate whether you use a measured value, a unit-specific emission factor or a 

default for CH4 emissions. If you use a unit-specific emission factor for CH4, report the basis for 

the factor. 

(8) Indicate whether you use a measured value, a unit-specific emission factor, or a 

default emission factor for N2O emissions. If you use a unit-specific emission factor for N2O, 

report the basis for the factor. 

(j) * * * 

(5) If you use Equation Y–14 of this subpart, the basis for the CO2 emission factor used. 

(6) If you use Equation Y–15 of this subpart, the basis for the CH4 emission factor used. 

(7) If you use Equation Y–16 of this subpart, the basis for the carbon emission factor 

used. 
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(8) If you use Equation Y–16b of this subpart, the basis for the CO2 emission factor used 

and the basis for the carbon emission factor used. 

(9) If you use Equation Y–17 of this subpart, the basis for the CH4 emission factor used. 

(k) * * * 

(3) The total number of delayed coking units at the facility; the total number of delayed 

coking drums at the facility; and, for each coke drum or vessel, the typical drum outage (i.e. the 

unfilled distance from the top of the drum, in feet). 

(4) For each set of coking drums that are the same dimensions, the number of coking 

drums in the set, and the mole fraction of methane in coking gas (in kg-mole CF4/kg-mole gas, 

wet basis). 

* * * * * 

(l) * * * 

(5) The annual volumetric flow discharged to the atmosphere (in scf), and an indication 

of the measurement or estimation method, annual average mole fraction of each GHG above the 

concentration threshold or otherwise required to be reported and an indication of the 

measurement or estimation method, and for intermittent vents, the number of venting events and 

the cumulative venting time. 

(m) * * * 

(3) For uncontrolled blowdown systems reporting under § 98.253(k), the basis for the 

value of the methane emission factor used for uncontrolled blowdown systems. 

* * * * * 

(p) * * * 
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(2) The types of materials loaded that have an equilibrium vapor-phase concentration of 

methane of 0.5 volume percent or greater, and the type of vessel (barge, tanker, marine vessel, 

etc.) in which each type of material is loaded. 

* * * * * 

Subpart Z—[AMENDED] 

23. Section 98.266 is amended by removing and reserving paragraphs (f)(5) and 

(f)(6). 

Subpart AA—[AMENDED] 

24. Section 98.276 is amended by: 

a. Revising the introductory paragraph; 

b. Removing and reserving paragraph (b); 

c. Revising paragraph (c); 

d. Removing and reserving paragraphs (d), (f), (g), (h) and (i); and 

e. Adding paragraphs (l) and (m). 

The revisions and additions read as follows: 

§ 98.276 Data reporting requirements. 

In addition to the information required by § 98.3(c) and the applicable information 

required by § 98.36, each annual report must contain the information in paragraphs (a) through 

(m) of this section as applicable: 

* * * * * 

(c) Basis for determining the annual mass of the spent liquor solids combusted (whether 

based on T650 om-05 Solids Content of Black Liquor, TAPPI (incorporated by reference, see § 

98.7) or an online measurement system). 
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* * * * * 

(l) For each pulp mill lime kiln, report the information specified in paragraphs (l)(1) and 

(2) of this section. 

(1) The quantity of calcium oxide (CaO) produced (metric tons). 

(2) The percent of annual heat input, individually for each fossil fuel type. 

(m) For each chemical recovery furnace and each chemical recovery combustion unit for 

which you are not using Equation C-2c to calculate CO2 emissions, report the information 

specified in paragraphs (m)(1) and (2) of this section. 

(1) The annual mass of steam generated (lb steam), individually for each fossil fuel type 

and for spent liquor solids. 

(2) The ratio of the unit’s maximum rated heat input capacity to its design rated steam 

output capacity (mmBtu/lb steam), individually for each fossil fuel type and for spent liquor 

solids. 

Subpart BB—[AMENDED] 

25. Section 98.286 is amended by removing and reserving paragraphs (b)(1), (b)(4), 

and (b)(6). 

Subpart CC—[AMENDED] 

26. Section 98.296 is amended by removing and reserving paragraphs (b)(5) through 

(7). 

Subpart EE—[AMENDED] 

27. Section 98.316 is amended by removing and reserving paragraphs (b)(6) and 

(b)(9). 

Subpart GG—[AMENDED] 
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28. Section 98.336 is amended by removing and reserving paragraphs (b)(6), (b)(7), 

and (b)(10). 

Subpart TT—[AMENDED] 

29. Section 98.466 is amended by: 

a. Removing and reserving paragraph (c)(3)(i); 

b. Revising paragraph (c)(3)(ii); and 

c. Removing and reserving paragraph (c)(3)(iii). 

The revisions read as follows: 

§ 98.466 Data reporting requirements. 

* * * * * 

(c) * * * 

(3) * * * 

(ii) The year of the data used in Equation TT-2 for the waste disposal quantity and 

production quantity, for each year used in Equation TT–2 of this subpart to calculate the average 

waste disposal factor (WDF). 

* * * * * 
 Attachment L 
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6560.50 

ENVIRONMENTAL PROTECTION AGENCY 

40 CFR Part 98 

[EPA-HQ-OAR-2010-0929; FRL-9801-2] 

RIN 2060-AQ81 

Revisions to Reporting and Recordkeeping Requirements, and Proposed Confidentiality 

Determinations under the Greenhouse Gas Reporting Program 

EO12866_GHGRP Part 98 2060 AQ81 NPRM 20120326 

AGENCY: Environmental Protection Agency (EPA). 

ACTION: Proposed rule. 

SUMMARY: The EPA is proposing amendments to reporting and recordkeeping requirements 

and an alternative verification approach for the Greenhouse Gas Reporting Program. This action 

addresses concerns about the potential release of certain data that are inputs to emission 

equations whosefor which the reporting deadline was deferred until March 31, 2015 while 

maintaining the EPA’s ability to verify emissions and ensure compliance with the Greenhouse 

Gas Reporting Program. In addition, the EPA is proposing confidentiality determinations for the 

newly proposed data elements in this action. 

DATES: Comments. Comments must be received on or before [INSERT THE DATE 60 DAYS 

AFTER PUBLICATION OF THIS PROPOSED RULE IN THE FEDERAL REGISTER]. 

Public Hearing. The EPA will hold a public hearing on this proposed rule if requested. 

Requests for a hearing must be made by [INSERT THE DATE 7 DAYS AFTER 

PUBLICATION OF THIS PROPOSED RULE IN THE FEDERAL REGISTER]. Contact the 

person listed in the “FOR FURTHER INFORMATION CONTACT” section by [INSERT 

THE DATE 7 DAYS AFTER PUBLICATION OF THIS PROPOSED RULE IN THE 
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FEDERAL REGISTER] to request a public hearing. If a hearing is requested, the EPA will 

announce the details, including specific dates, times, addresses and contact information for the 

hearing, in a separate Federal Register notice. 

ADDRESSES: Submit your comments, identified by Docket ID No. EPA–HQ–OAR–2010-

0929, by one of the following methods: 

 Federal eRulemaking Portal: http:// www.regulations.gov. Follow the online instructions 

for submitting comments. 

 Email: GHGReportingCBI@epa.gov 

 Fax: (202) 566–1741. 

 Mail: Environmental Protection Agency, EPA Docket Center (EPA/DC), Mailcode 

6102T, Attention Docket ID No. EPA–HQ–OAR–2010-0929, 1200 Pennsylvania 

Avenue, NW., Washington, DC 20460. 

 Hand Delivery: EPA Docket Center, Public Reading Room, EPA West Building, Room 

3334, 1301 Constitution Avenue, NW., Washington, DC 20004. Such deliveries are only 

accepted during the Docket’s normal hours of operation, and special arrangements should 

be made for deliveries of boxed information. 

Instructions: Direct your comments to Docket ID No. EPA–HQ–OAR–2010-0929. The 

EPA’s policy is that all comments received will be included in the public docket without change 

and may be made available online at http://www.regulations.gov, including any personal 

information provided, unless the comment includes information claimed to be confidential 

business information (CBI) or other information whose disclosure is restricted by statute. 

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Do not submit information that you consider to be CBI or otherwise protected through 

http://www.regulations.gov or email. Send or deliver information identified as CBI to only the 

mail or hand/courier delivery address listed above, attention: Docket ID No. EPA–HQ–OAR–

2010–0929. The http://www.regulations.gov website is an “anonymous access” system, which 

means the EPA will not know your identity or contact information unless you provide it in the 

body of your comment. If you send an email comment directly to the EPA without going through 

http://www.regulations.gov your email address will be automatically captured and included as 

part of the comment that is placed in the public docket and made available on the Internet. If you 

submit an electronic comment, the EPA recommends that you include your name and other 

contact information in the body of your comment and with any disk or CD–ROM you submit. If 

the EPA cannot read your comment due to technical difficulties and cannot contact you for 

clarification, the EPA may not be able to consider your comment. Electronic files should avoid 

the use of special characters, any form of encryption, and be free of any defects or viruses. 

Docket: All documents in the docket are listed in the http://www.regulations.gov index. 

Although listed in the index, some information is not publicly available, e.g., CBI or other 

information whose disclosure is restricted by statute. Certain other material, such as copyrighted 

material, will be publicly available only in hard copy. Publicly available docket materials are 

available either electronically in http://www.regulations.gov or in hard copy at the Air Docket, 

EPA/DC, EPA West, Room B102, 1301 Constitution Ave., NW., Washington, DC. This Docket 

Facility is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. 

The telephone number for the Public Reading Room is (202) 566–1744, and the telephone 

number for the Air Docket is (202) 566–1742. 
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FOR FURTHER GENERAL INFORMATION CONTACT: Carole Cook, Climate Change 

Division, Office of Atmospheric Programs (MC–6207J), Environmental Protection Agency, 

1200 Pennsylvania Ave., NW., Washington, DC 20460; telephone number: (202) 343–9263; fax 

number: (202) 343–2342; email address: GHGreporting@epa.gov. For technical information, 

contact the Greenhouse Gas Reporting Rule Helpline at: 

http://www.epa.gov/climatechange/emissions/ghgrule_contactus.htm. Alternatively, contact 

Carole Cook at 202–343–9263. 

Worldwide Web (WWW). In addition to being available in the docket, an electronic copy 

of this proposal, memoranda to the docket, and all other related information will also be 

available through the WWW on EPA’s greenhouse gas reporting rule Web site at 

http://www.epa.gov/climatechange/emissions/ghgrulemaking.html.

http://www.epa.gov/climatechange/emissions/ghgrulemaking.html. 

SUPPLEMENTARY INFORMATION: 

Additional Information on Submitting Comments: To expedite review of your comments 

by Agency staff, you are encouraged to send a separate copy of your comments, in addition to 

the copy you submit to the official docket, to Carole Cook, Climate Change Division, Office of 

Atmospheric Programs (MC–6207J), Environmental Protection Agency, 1200 Pennsylvania 

Ave., NW., Washington, DC, 20460, telephone (202) 343–9263, email 

GHGReportingCBI@epa.gov. 

Regulated Entities. This proposed rule revision on reporting and recordkeeping 

requirements and verification procedures would affect entities that must submit annual 

greenhouse gas (GHG) reports under the Greenhouse Gas Reporting Program (40 CFR part 98). 

The Administrator has determined that 40 CFR part 98 is subject to the provisions of Clean Air 

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Act (CAA) section 307(d). See CAA section 307(d)(1)(V) (the provisions of CAA section 307(d) 

apply to “such other actions as the Administrator may determine”). Entities affected by this 

proposal are owners or operators of facilities that are direct emitters of greenhouse gases 

(GHGs), which include those listed in Table 1 of this preamble: 

Table 1. Examples of Affected Entities by Category 

Category NAICS Examples of affected facilities 

General Stationary Fuel 

Combustion Sources 

 Facilities operating boilers, process heaters, 

incinerators, turbines, and internal combustion engines. 

321 Manufacturers of lumber and wood products. 

322 Pulp and paper mills. 

325 Chemical manufacturers. 

324 Petroleum refineries and manufacturers of coal 

products. 

316, 326, 

339 

Manufacturers of rubber and miscellaneous plastic 

products. 

331 Steel works, blast furnaces.

332 Electroplating, plating, polishing, anodizing, and 

coloring. 

336 Manufacturers of motor vehicle parts and accessories. 

221 Electric, gas, and sanitary services. 

622 Health services.

611 Educational services.

325193 Ethyl alcohol manufacturing facilities. 

311611 Meat processing facilities 

311411 Frozen fruit, juice, and vegetable manufacturing 

facilities.

311421 Fruit and vegetable canning facilities.

Adipic Acid Production 325199 Adipic acid manufacturing facilities. 

Aluminum Production 331312 Primary aluminum production facilities 

Ammonia 

Manufacturing 

325311 Anhydrous and aqueous ammonia production facilities. 

Cement Production 327310 Portland Cement manufacturing plants.

Ferroalloy Production 331112 Ferroalloys manufacturing facilities. 

Fluorinated GHG 

Production 

325120 Industrial gases manufacturing facilities. 

Glass Production 327211 Flat glass manufacturing facilities.

327213 Glass container manufacturing facilities.

327212 Other pressed and blown glass and glassware 

manufacturing facilities.
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Category NAICS Examples of affected facilities 

HCFC-22 Production 

and HFC-23 

Destruction 

325120 Chlorodifluoromethane manufacturing facilities. 

Hydrogen Production 325120 Hydrogen production facilities 

Iron and Steel 

Production 

331111 Integrated iron and steel mills, steel companies, sinter 

plants, blast furnaces, basic oxygen process furnace 

shops. 

Lead Production 331419 Primary lead smelting and refining facilities.

331492 Secondary lead smelting and refining facilities. 

Lime Production 327410 Calcium oxide, calcium hydroxide, dolomitic hydrates 

manufacturing facilities.

Nitric Acid Production 325311 Nitric acid production facilities

Petrochemical 

Production 

32511 Ethylene dichloride production facilities.

325199 Acrylonitrile, ethylene oxide, methanol production 

facilities.

325110 Ethylene production facilities.

325182 Carbon black production facilities.

Petroleum and Natural 

Gas Systems 1

486210 Pipeline transportation of natural gas.

221210 Natural gas distribution facilities. 

211 Extractors of crude petroleum and natural gas. 

211112 Natural gas liquid extraction facilities. 

Petroleum Refineries 324110 Petroleum refineries. 

Phosphoric Acid 

Production 

325312 Phosphoric acid manufacturing facilities. 

Pulp and Paper 

Manufacturing 

322110 Pulp mills. 

322121 Paper mills. 

322130 Paperboard mills. 

Silicon Carbide 

Production 

327910 Silicon carbide abrasives manufacturing facilities. 

Soda Ash 

Manufacturing 

325181 Alkalies and chlorine manufacturing facilities. 

212391 Soda ash, natural, mining and/or beneficiation. 

Titanium Dioxide 

Production 

325188 Titanium dioxide manufacturing facilities. 

Zinc Production 331419 Primary zinc refining facilities.

331492 Zinc dust reclaiming facilities, recovering from scrap 

and/or alloying purchased metals.

311411 Frozen fruit, juice and vegetable manufacturing 

facilities. 

311421 Fruit and vegetable canning facilities. 

Wastewater Treatment1 322110 Pulp mills. 

322121 Paper mills.

322122 Newsprint mills.

322130 Paperboard mills.

311611 Meat processing facilities.
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Category NAICS Examples of affected facilities 

311411 Frozen fruit, juice and vegetable manufacturing 

facilities.

311421 Fruit and vegetable canning facilities.

325193 Ethanol manufacturing facilities. 1

 The EPA is not proposing amendments related to these categories; however, these categories were evaluated in the 

EPA’s analysis of the potential impact from the release of inputs to emission equations for which reporting was 

deferred to March 31, 2015. Refer to Section 1.B of this preamble for further discussion of this evaluation. 

Table 1 of this preamble is not intended to be exhaustive, but rather provides a guide for 

readers regarding facilities and suppliers likely to be affected by this action. Types of facilities 

other than those listed in this table may also be affected by this action. To determine whether you 

are affected by this action, you should carefully examine the applicability criteria found in 40 

CFR part 98, subpart A or the relevant criteria in the subparts. If you have questions regarding 

the applicability of this action to a particular facility or supplier, consult the person listed in the 

preceding FOR FURTHER GENERAL INFORMATION CONTACT section. 

Many facilities that are affected by 40 CFR part 98 have GHG emissions from multiple 

source categories listed in Table 1 of this preamble. 

Acronyms and Abbreviations. The following acronyms and abbreviations are used in this 

document. 

BAMM Best Available Monitoring Methods 

CAA Clean Air Act 

CO2 carbon dioxide 

CBI confidential business information 

CEMS Continuous Emission Monitoring System 

CFR Code of Federal Regulations 

e-GGRT Electronic Greenhouse Gas Reporting Tool 

EPA U.S. Environmental Protection Agency 

FR Federal Register 

GHG greenhouse gas 

GHGRP Greenhouse Gas Reporting Program 

HCFC-22 chlorodifluoromethane 
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HFC hydrofluorocarbons 

HQ Headquarters 

ICR Information Collection Request 

MW megawatt 

NAICS North American Industry Classification System 

NTTAA National Technology Transfer and Advancement Act 

OMB Office of Management & Budget 

RFA Regulatory Flexibility Act 

UMRA Unfunded Mandates Reform Act 

U.S. United States 

WWW Worldwide Web 

TABLE OF CONTENTS 

I. Executive Summary and Background

A. Executive Summary

B. Background

C. Subparts Covered in this Proposed Rule

D. Legal Authority

II. Summary of Proposed Changes to Part 98 Reporting and Recordkeeping Requirements

A. Proposed Use of Inputs Verification Tool

B. Proposed Revisions to Reporting of Data Elements Deferred until 2015

C. Proposed Changes to Recordkeeping Requirements

D. Proposed New Data Elements to be Reported

III. Rationale for Proposed Changes to Reporting and Recordkeeping Requirements

A. Proposed Inputs Verification Tool and Amendment to Reporting Requirements

B. Proposed Revisions to Recordkeeping Requirements

C. Proposed Requirement to Report Additional Data

IV. Confidentiality Determination for Proposed New Data Elements to be Reported

V. Impacts of the Proposed Rule

A. How were the costs of this proposed rule estimated?

B. Additional Impacts of the Proposed Amendments

VI. Statutory and Executive Order Reviews

A. Executive Order 12866: Regulatory Planning and Review and Executive Order 13563: 

Improving Regulation and Regulatory Review

B. Paperwork Reduction Act

C. Regulatory Flexibility Act (RFA)

D. Unfunded Mandates Reform Act (UMRA)

E. Executive Order 13132: Federalism

F. Executive Order 13175: Consultation and Coordination with Indian Tribal Governments.
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G. Executive Order 13045: Protection of Children from Environmental Health Risks and Safety 

Risks

H. Executive Order 13211: Actions that Significantly Affect Energy Supply, Distribution, or Use

I. National Technology Transfer and Advancement Act

J. Executive Order 12898: Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations

I. Executive Summary and Background 

A. Executive Summary 

The Greenhouse Gas Reporting Program (GHGRP) collects greenhouse gas data from 41 

source categories and currently has received 2 to 3 years of data from these sources. Greenhouse 

gas emissions from direct emitters are calculated using a variety of methods, including direct 

measurement, mass balance, and the use of emission factors. Reporters not using direct 

measurement must use equations to calculate emissions. The inputs to these emission equations 

often include process or production data that are specific to each facility’s operations. These 

inputs to emission equations play an important role in the Agency’s ability to verify facility-level 

emissions and ensure compliance with the program. 

On July 7, 2010, the EPA proposed confidentiality determinations for the majority of data 

elements required to be reported under the GHGRP, as well as for the majority of source 

categories covered by the program. In the July 7, 2010 action, the EPA proposed that data 

elements categorized as “inputs to emission equations” are emission data. The CAA precludes 

“emission data” from being treated as confidential. 

Based on subsequent industry concerns regarding the potential release of data elements 

categorized as “inputs to emission equations,” the EPA deferred reporting of these data elements 

(see August 25, 2011 final action, 76 FR 53057) to allow the EPA to complete its evaluation of 

the potential impact from the public release of these data elements (see 76 FR 53060) and, if 

appropriate, to propose amendments to Part 98 (see 75 FR 81355). Based on the analysis 
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conducted, today’s action proposes amendments to reporting and recordkeeping requirements 

and an alternative verification approach for certain reporters subject to 24 subparts for which the 

reporting deadline for inputs to emission equations was deferred until 2015 and disclosure 

concerns have been identified. Proposed amendments include: 

 Adding a requirement for certain reporters under 24 subparts to use an EPA-provided 

inputs verification tool. For these subparts, the designated inputs to emission equations 

for which reporting was deferred to 2015 and disclosure concerns have been identified 

would be entered into the tool.1

 The tool would calculate the emissions and perform 

electronic verification. The tool would not retain the entered inputs (i.e., the inputs would 

not be reported to EPA); instead, the tool would conduct certain checks (e.g., accuracy of 

the inputs) at the time of data entry and generate a verification summary. The verification 

summary, which would be accessible to the EPA once the annual report is submitted, 

would provide the EPA with information to conduct further verification if necessary. 

 For reporters required to use the inputs verification tool, changing the required format for 

maintaining records of these inputs to emission equations. 

 For reporters required to use the inputs verification tool, lengthening the record retention 

period from 3 to 5 years for all records maintained under Part 98 (including subparts that 

do not require the use of the tool). 

 For certain reporters required to use the inputs verification tool, adding new data 

elements to be reported for the EPA’s verification purposes, and proposing 

confidentiality determinations for the new data elements proposed to be reported. 

 

1

 Under this proposal, the inputs verification tool would not be required to be used by reporters for any reported GHG for 

which the reporter uses a CEMS or an EPA-approved alternative method (as allowed under sections 98.33(a)(5), 98.53(a)(2), and 

98.223(a)(2) of Part 98) to calculate the reported GHG value, rather than using "inputs to equations" data elements and the 

associated EPA-provided calculation methodologies to calculate the reported GHG value. 

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 For reporters required to use the inputs verification tool, removing the requirement to 

report the inputs to emission equations for which reporting was deferred to 2015 and 

disclosure concerns have been identified, and requiring these data to be kept as records. 

Reporting requirements for inputs to equations for which disclosure concerns were not 

identified (and would still be useful to EPA) are not proposed to be amended in this action. For 

these inputs to equations, the deferral would expire in March 2015, and the EPA would collect 

these data. 

The proposed changes in this action build on the EPA’s experience and success with 

electronic reporting and verification during the first 3 years of the GHGRP. By requiring the use 

of the inputs verification tool, which would calculate GHG emissions based on the inputs to the 

emissions equations, the EPA would have the ability to identify facilities that potentially reported 

emissions incorrectly. This, combined with additional verification checks of the inputs to 

emission equations that the inputs verification tool would conduct (during the process of 

reporters entering data into the inputs verification tool), would provide the EPA with information 

necessary to conduct further verification once the annual report is submitted. This alternative 

verification approach, including the changes to the recordkeeping requirements and additional 

reporting requirements, would provide an alternative to collecting certain data elements for 

which reporting was deferred to March 31, 2015 and disclosure concerns have been identified, 

while maintaining the EPA’s ability to verify data and ensure compliance with the GHGRP. 

B. Background

On October 30, 2009, the EPA published the Greenhouse Gas Reporting Rule, 40 CFR 

part 98, requiring annual reporting of GHG data from a broad range of industry sectors (74 FR 

56260). Under the Greenhouse Gas Reporting Rule and its subsequent amendments (hereinafter 
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referred to as “Part 98”), the EPA requires annual reporting of data from certain facilities and 

suppliers above specified emission or quantity supplied thresholds. On July 7, 2010 (75 FR 

39094) and subsequent proposals (77 FR 1434, January 10, 2012; 77 FR 10434, February 22, 

2012), we proposed confidentiality determinations for the data elements required to be reported. 

The confidentiality of each reported data element was determined using a two-step approach: (1) 

grouping data elements into 11 data categories (e.g., inputs to emission equations, emissions, and 

unit/process operating characteristics that are not inputs to emission equations for direct emitter 

source categories); and (2) making confidentiality determinations either categorically or on an 

individual data elements basis. Refer to both the July 7, 2010 proposal (75 FR 39097) and the 

May 26, 2011 final rule (76 FR 30785 - 30786) for more detailed descriptions of this process. 

Refer to the May 26, 2011 final rule also for a discussion of individual data element 

confidentiality determinations. We have finalized confidentiality determinations for data 

elements except those in the “inputs to emission equations” category (May 26, 2011, 76 FR 

30782; August 13, 2012, 77 FR 48072; and August 24, 2012, 77 FR 51477)2

. For data elements 

in this category, we proposed that they meet the definition of “emission data” under 40 CFR 

2.301(a)(2)(i). Because emission data are not entitled to confidential treatment under section 

114(c) of the Clean Air Act, we did not evaluate whether such data elements would qualify as 

CBI, including whether disclosure would likely cause substantial competitive harm to the 

reporting facilities. (75 FR 39105 and 39108, July 7, 2010). 

Following our proposal that data elements assigned to the “inputs to emission equations” 

category are not entitled to confidential treatment, we received numerous industry comments 

asserting that competitive harm would result from public release of many of these data elements. 

 

2

 There are a small number of data elements (besides data elements categorized as “inputs to emission equations”) for which we 

have not made a final confidentiality determinations because we concluded that a determination of confidentiality for the data 

element should be made on a case-by-case facility basis (according to individual circumstances of the facility). 
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We determined that “these concerns warranted an in-depth evaluation of the potential impact 

from the release of inputs to emission equations.” (76 FR 53060; August 25, 2011). In a notice 

dated December 27, 2010, we issued a call for information (75 FR 81354) requesting additional 

information to assist us in conducting our evaluation. To allow sufficient time to complete this 

evaluation through notice and comment, we deferred the reporting deadline for data elements 

assigned to the “inputs to emission equation” category. Reporting of certain of these data 

elements was deferred to March 31, 2013, as specified in Table A-6 of subpart A; and reporting 

of the remainder of these data elements was deferred to March 31, 2015, as specified in Table A7 of subpart A (see the August 25, 2011 final rule, 76 FR 53057). 

Our process for evaluating competitive harm was documented in the final deferral notice 

(August 25, 2011, 76 FR 53057) and the accompanying memorandum entitled “Process for 

Evaluating and Potentially Amending Part 98 Inputs to Emission Equations” (Docket ID EPAHQ-OAR-2010-0929). As discussed in the final deferral notice and memorandum, our evaluation 

involved a four-step process, as follows: 

 Step 1: Determine whether each data element assigned to the “inputs to emission 

equations” category is already publicly available. 

 Step 2: For data elements assigned to the “inputs to emission equations” category that are 

not publicly available, evaluate whether disclosure of the information is likely to result in 

substantial competitive harm. 

 Step 3: For data elements assigned to the “inputs to emission equations” category that are 

likely to cause substantial competitive harm if disclosed, evaluate potential alternative 

calculation methods. 

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 Step 4: For data elements assigned to the “inputs to emission equations” category that are 

likely to cause substantial competitive harm if disclosed, evaluate potential alternative 

verification methods. 

Based on each step of the four-step evaluation process, an analysis of all data elements 

for which reporting was deferred to March 31, 2015 was conducted.3

 The results of the analysis 

are documented in four memoranda, as follows: 

 “Evaluation of Public Availability of Inputs to Emission Equations for which Reporting 

was Deferred to March 31, 2015.” 

 “Evaluation of Competitive Harm from Disclosure of “Inputs’Inputs to 

Equations”Equations’ Data Elements Deferred to March 31, 2015” 

 “Evaluation of Alternative Calculation Methods.” 

 “Evaluation of Alternative Verification Approaches For Greenhouse Gas Reporting Rule 

Subparts for which Reporting of Inputs to Emission Equations was Deferred to March 31, 

2015.” 

These memoranda are available in EPA docket ID No. EPA–HQ–OAR–2010-0929. 

Based on the results of these analyses, the EPA is proposing in today’s action to make certain 

amendments to Part 98. 

C. Subparts Covered in this Proposed Rule

 

3

 Based on the same four-step process, we also evaluated all data elements for which reporting was deferred to 

March 31, 2013 (Part 98 Table A-6 to Part 98) and took no further action. As a result, applicable facilities were 

required to report these data by April 1, 2013. For a discussion of this evaluation, refer to the EPA's memorandum 

"Summary of Evaluation of Greenhouse Gas Reporting Program (GHGRP) Part 98 “Inputs to Emission Equations” 

Data Elements Deferred Until 2013" (December 17, 2012), available at 

http://www.epa.gov/ghgreporting/documents/pdf/2012/documents/2013-inputs-memo.pdf. 

Formatted: Line spacing: Double
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The proposed amendments affect all subparts listed in Table 2 of this preamble. Table 2 

includes most of the subparts with inputs to emission equations for which the reporting deadline 

was deferred until 2015. Subpart W (Petroleum and Natural Gas Systems), Subpartsubpart II 

(Industrial Wastewater Treatment), and subpart C (only certain combustion units associated with 

certain electric generators connected and able to deliver power to the local or regional electric 

power grid, as specified in Table 2) are not included in Table 2 because none of the inputs to 

emission equations required to be reported by reporters in these source categories are being 

amended, as no disclosure concerns were identified. Subpart I of partPart 98 is not included in 

Table 2 because reporting of inputs to emission equations under this subpart was addressed under 

a separate rulemaking proposed on October 16, 2012 (77 FR 63538). Additionally, parts of these 

proposed rule amendments would affect subparts not listed in Table 2. Specifically, for reporters 

subject to both a subpart listed in Table 2 and a subpart of Part 98 not listed in this table, the 

proposed revision to the recordkeeping duration would apply to the records required for all Part 

98 subparts (to which the reporter is subject). Refer to Sections II.C and III.B of this preamble 

for further discussion of this proposed amendment. 

Table 2. Subparts Affected by the Proposed Amendments.1,2

Subpart 

C—General Stationary Fuel Combustion except 

Specified Stationary Fuel Combustion Sources 

Connected to Certain Electric Generators that are 

Connected and Able to Deliver Power to the Local 

or Regional Electric Power Grid 3

S—Lime Manufacturing 

E—Adipic Acid Production U—Miscellaneous Uses of Carbonate 

F—Aluminum Production V—Nitric Acid Production 

G—Ammonia Manufacturing X—Petrochemical Production 

H—Cement Production Y—Petroleum Refineries 

K—Ferroalloy Production Z—Phosphoric Acid Production 

L—Fluorinated Gas Production AA—Pulp and Paper Manufacturing 

N—Glass Production BB—Silicon Carbide Production 
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Subpart 

O—HCFC–22 Production and HFC–23 

Destruction 

CC—Soda Ash Manufacturing 

P—Hydrogen Production EE—Titanium Dioxide Production 

Q—Iron and Steel Production GG—Zinc Production 

R—Lead Production TT—Industrial Waste Landfills 1

 Certain proposed amendments affect other subparts not listed in this table as follows: for reporters subject to both a 

subpart listed in this table and a subpart of Part 98 not listed in this table, the proposed revision to the recordkeeping 

duration would apply to the records required for all Part 98 subparts to which the reporter is subject. 

2

 Under this proposal, the inputs verification tool would not be required to be used by reporters for any reported 

GHG for which the reporter uses a CEMS or an EPA-approved alternative method (as allowed under sections40 

CFR 98.33(a)(5), 98.53(a)(2), and 98.223(a)(2) of Part 98))) to calculate the reported GHG value, rather than using 

"inputs to equations" data elements and the associated EPA-provided calculation methodologies to calculate 

the reported GHG value.

3 The stationary fuel combustion sources (e.g., individual units, aggregations of units, common pipes, or common 

stacks) not affected by the proposed amendments include those meeting both of the following criteria: (1) the 

stationary fuel combustion source contains at least one combustion unit connected to a fuel-fired electric generator 

that has been granted access by the Public Utilities Commission to deliver power to the local or regional electric 

power grid (excluding generators connected to combustion units that are subject to subpart D of Part 98); and (2) the 

stationary fuel combustion source is located at a facility for which the sum of the nameplate capacities for all such 

electric generators is greater than or equal to 1 megawatt electric output. Refer to Section III.A.3 of this preamble 

for a discussion of the EPA’s rationale for proposing that combustion units meeting these criteria not be affected by 

the proposed amendments. 

D. Legal Authority

The EPA is proposing these rule amendments under its existing CAA authority provided 

in CAA section 114. As stated in the preamble to the 2009 final GHG reporting rule (74 FR 

56260, October 30, 2009), CAA section 114(a)(1) provides the EPA broad authority to require 

the information proposed to be gathered by this rule because such data would inform and are 

relevant to the EPA’s carrying out a wide variety of CAA provisions. See the preambles to the 

proposed (74 FR 16448, April 10, 2009) and final Part 98 (74 FR 56260, October 30, 2009) for 

further information. 

In addition, pursuant to sections 114, 301, and 307 of the CAA, the EPA is proposing 

confidentiality determinations for the new data elements proposed in this notice. Section 114(c) 

of the CAA requires that the EPA make publicly available information obtained under CAA 

section 114 except for information (excluding emission data) that qualifies for confidential 
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treatment. The Administrator has determined that this action (Part 98 amendment and 

confidentiality determinations) is subject to the provisions of CAA section 307(d). 

II. Summary of Proposed Changes to Part 98 Reporting and Recordkeeping Requirements 

The EPA is proposing revisions to the reporting and recordkeeping requirements in Part 

98 and alternative verification procedures that would apply to certain reporters subject to any of 

the 24 subparts listed in Table 2 of this preamble. Section II.A of this preamble summarizes a 

proposed new requirement for these reporters if they use inputs to emission equations for which 

reporting was deferred to March 31, 2015 (hereafter referred to as “inputs to equations” data 

elements) to calculate reported GHGs. Such reporters would be required to use an EPA-provided 

electronic inputs verification tool to calculate emissions using data elements for which reporting 

was deferred to March 31, 2015 (hereafter referred to as “inputs to equations” data elements), 

allowing the EPA to complete electronic verification of reported GHG emissions data without 

the need to collect “inputs to equations” data elements for which disclosure concerns have been 

identified. Section II.B of this preamble summarizes the EPA’s proposal to remove, for these 

reporters, the requirement to report many “inputs to equations” data elements. Section II.C of 

this preamble summarizes proposed revisions to the recordkeeping requirements for these 

reporters. Section II.D of this preamble summarizes proposed new reporting requirements for 

these reporters. Section III of this preamble explains the rationale for the proposed amendments 

summarized in Sections II.A through II.D. of this preamble. Section IV of this preamble presents 

the EPA’s proposed confidentiality determinations for proposed new data elements and the 

EPA’s rationale for these determinations. Section V of this preamble presents the cost and 

impacts associated with these proposed amendments. 

A. Proposed Use of Inputs Verification Tool 
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The EPA is proposing that facilities subject to the subparts listed in Table 2 of this 

preamble and that use “inputs to equations” data elements to calculate reported GHGs use an 

electronic inputs verification tool being developed by the EPA, which would calculate and verify 

GHG emissions. Refer to sectionSection III.A.1 of this preamble for a web-link to the EPA’s 

“pilot” inputs verification tool for one subpart of Part 98, available during the public comment 

period for this rulemaking. The “pilot” demonstrates how the tool would work within eGGRT,the EPA’s Electronic Greenhouse Gas Reporting Tool (e-GGRT), as well as the types of 

verification checks that would be conducted. The inputs verification tool would be deployed 

within the EPA’s Electronic Greenhouse Gas Reporting Tool (e-GGRT)e-GGRT and would be 

integrated without interrupting the current electronic reporting process. While reporters enter 

data into e-GGRT that are required to be reported in the annual report, reporters would also enter 

into e-GGRT (via the inputs verification tool) the “inputs to equations” data elements that the 

EPA is proposing to remove from the reporting requirements. The tool would use the entered 

“inputs to equations” data elements to calculate the equation outputs, conduct electronic 

verification checks on the “inputs to equations” data elements, and generate a verification 

summary. The tool would not retain the entered “inputs to equations” data elements for which 

the EPA is proposing that the reporting requirement be removed. Accordingly, the EPA would 

not have access to these “inputs to equations” data elements. Instead, the EPA would rely on the 

verification summary, which would become accessible to the EPA when annual reports are 

submitted, as a first step for conducting verification once the annual report is submitted. 

Sources subject to multiple subparts under Part 98 would be required to use the inputs 

verification tool for only those subparts listed in Table 2 of this preamble. The EPA is proposing 
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that reporters use this tool starting with reporting year 2014. Refer to Section III.A of this 

preamble for further discussion of this proposed requirement. 

This proposed requirement to use the inputs verification tool is specified in 40 CFR 98.5, 

Subpartsubpart A. Reporters would determine applicability under this new requirement based on 

a proposed new Table A-8 to Part 98, which lists all calculation methods under Part 98 for which 

the inputs verification tool must be used. Reporters calculating reported GHGs using a 

calculation method specified in proposed Table A-8 would be required to enter into the inputs 

verification tool “inputs to equations” data elements that have been removed from the reporting 

requirements. 

B. Proposed Revisions to Reporting of Data Elements Deferred until 2015

The EPA is proposing to remove the reporting requirement for 440 “inputs to equations” 

data elements in the subparts listed in Table 2 of this preamble. Table 3 of this preamble provides 

a summary of how many data elements would be removed from reporting for each subpart. Refer 

to Table 1 in the memorandum “List of ‘Inputs to Equations’ Data Elements Proposed Not To Be 

Reported” (refer to Docket ID No. EPA–HQ–OAR–2010-0929) for a complete list of these 440 

data elements. For all remaining “inputs to equations” data elements not represented in Table 3 

of this preamble, the EPA is not amending these reporting requirements and would, therefore, let 

the deferral of these data elements expire on March 31, 2015. As a result, by March 31, 2015, all 

of the “inputs to equations” data elements for subpart W (Petroleum and Natural Gas Systems), 

Subpart II (Industrial Wastewater Treatment), and the additional “inputs to equations” data 

elements for which reporting is not proposed to be removed as indicated in Table 3 of this 

preamble, would be reported for future reporting years and for all prior reporting years, including 
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Page 20 of 100 

reporting year 2014. For a list of these “inputs to equations” data elements that would be 

reported, refer to Table 2 of the memorandum cited above. 

Table 3. Subparts for Which Reporting Requirements are Amended 

Subpart

Number of “Inputs to 

Equations” Data Elements 

Number of “Inputs to 

Equations” Data Elements 

Proposed Not to Be 

Reported 

C—General Stationary Fuel 

Combustion Except Specified 

Stationary Fuel Combustion 

Sources Connected to Certain 

Electric Generators Connected 

and Able to Deliver Power to 

the Local or Regional Power 

Grid2

261

 261

E—Adipic Acid Production 21 11 

F—Aluminum Production 29 29 

G—Ammonia Manufacturing 8 8 

H—Cement Production 16 14 

K—Ferroalloy Production 13 13 

L—Fluorinated Gas Production 55 46 

N—Glass Production 3 3 

O—HCFC–22 Production and 

HFC–23 Destruction 

15 12 

P—Hydrogen Production 7 7 

Q—Iron and Steel Production 93 92 

R—Lead Production 10 10 

S—Lime Manufacturing 9 9 

U—Miscellaneous Uses of 

Carbonate 

6 6 

V—Nitric Acid Production 21 6 

X—Petrochemical Production 21 21 

Y—Petroleum Refineries 80 75 

Z—Phosphoric Acid Production 4 4 

AA—Pulp and Paper 

Manufacturing 

31 28 

BB—Silicon Carbide 

Production 

3 3 

CC—Soda Ash Manufacturing 10 4 
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Subpart

Number of “Inputs to 

Equations” Data Elements 

Number of “Inputs to 

Equations” Data Elements 

Proposed Not to Be 

Reported 

EE—Titanium Dioxide 

Production 

2 2 

GG—Zinc Production 8 8 

TT—Industrial Waste Landfills 3 3 

1 Includes one “inputs to equations” data element, 40 CFR 98.3(d)(3)(v), which is specified in subpart A of partPart

98 and applies to only certain reporters under subpart C of partPart 98. 2

 The reporting requirements applicable to certain stationary fuel combustion sources (e.g., individual units, 

aggregations of units, common pipes, or common stacks) subject to subpart C remain the same under the proposed 

amendment. Subpart C would continue to require reporting of all applicable “inputs to equations” data elements for 

stationary fuel combustion sources that meet both of the following criteria: (1) the stationary fuel combustion source 

contains at least one combustion unit connected to a fuel-fired electric generator that has been granted access by the 

Public Utilities Commission to deliver power to the local or regional electric power grid (excluding generators 

connected to combustion units that are subject to subpart D of this part); and (2) the stationary fuel combustion 

source is located at a facility for which the sum of the combined nameplate capacities for all such electric generators 

is greater than or equal to 1 megawatt electric output. Subpart C reporters would not report “inputs to equations” 

data elements for all other types of stationary fuel combustion sources subject to subpart C. 

In order to ease the burden for facilities, the EPA is proposing that the “inputs to 

equations” data elements that are not being amended in this action (and therefore would be 

reported for reporting years prior to reporting year 2014) be reported as part of the annual report 

for reporting year 2014. Specifically, when reporters prepare their reporting year 2014 annual 

report via e-GGRT, they would be required to include these “inputs to equations” data elements 

for reporting year 2014 as well as for all applicable previous reporting years. The annual report, 

including these “inputs to equations” data elements that would still be reported, would be 

submitted via e-GGRT. This proposed approach would prevent facilities from being required to 

revise, re-certify, and re-submit annual reports for each previous reporting year. 

C. Proposed Changes to Recordkeeping Requirements

For each facility subject to a subpart listed in Table 2 of this preamble that uses “inputs to 

equations” data elements to calculate and report GHGs (i.e., subject to using the proposed inputs 

verification tool), the EPA is proposing that the facility retain all records, including records for 
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Page 22 of 100 

subparts not subject to the inputs verification tool requirement, for 5 years, rather than the 

current 3-year record retention period. In other words, if any facility subject to using the 

proposed inputs verification tool is also subject to a subpart of Part 98 not listed in Table 2, we 

propose that records required for those other subparts also be maintained for the 5 years. For 

example, if such a facility is required to report under both subpart C (in Table 2) and subpart HH 

(not in Table 2), the facility would be required to maintain all records required under both 

subparts for 5 years following submittal of the annual report. The EPA is proposing that this 5-

year record retention requirement begin with records for reporting year 2010. 

Additionally, we are proposing that, at the time a reporter subject to using the proposed 

inputs verification tool completes entry of all “inputs to equations” data elements into the tool, 

the reporter would be required to keep a file generated by the tool that lists the entered “inputs to 

equations” data elements. The reporter would be required to maintain a copy of the file as a 

record of the entered inputs. As currently required in 40 CFR 98.3(g), subpart A, this file may be 

maintained in electronic or hard copy format. As discussed above, this record would be required 

to be maintained for 5 years. 

Refer to Section III.B of this preamble for further discussion of these proposed 

recordkeeping requirements. 

D. Proposed New Data Elements to be Reported 

The EPA is proposing that reporters subject to using the proposed inputs verification tool 

in subparts E, G, H, P, Q, S, V, X, Y, and AA of Part 98, be required to report the additional data 

elements listed per subpart in Table 4 of this preamble. Proposed confidentiality determinations 

for these proposed data elements are presented in Section IV of this preamble. 
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Table 4. Proposed New Data Elements for Subparts E, G, H, P, Q, S, V, X, Y, and AA of 

Part 98 

Subpart Subpart Name New Data Element Description 

E Adipic Acid Production Annual quantity of cyclohexane fed to all production 

lines (metric tons). 

Annual percent N2O emission reduction for all 

production units combined. 

G Ammonia Production Annual ammonia production (metric tons). 

Annual methanol production (metric tons), if this 

quantity is not reported under subpart X of Part 98. 

H Cement Production Annual clinker production (metric tons). 

Annual average clinker CO2 emission factor for the 

facility, averaged across all kilns (metric tons 

CO2/metric ton clinker produced). 

Annual average cement kiln dust (CKD) CO2

emission factor for the facility, averaged across all 

kilns (metric tons CO2/metric ton CKD produced). 

P Hydrogen Production Name and annual quantity (metric tons) of each 

carbon-containing fuel and feedstock. 

Annual methanol production (metric tons), if this 

quantity is not reported under subpart X of Part 98. 

Q Iron and Steel Production If you use the carbon mass balance method in 40 CFR 

98.173(b)(1) to determine CO2 emissions: The annual 

mass (metric tons) of all gaseous, liquid, and solid 

fuels (combined) used in process units specified in 

Equations Q-1 through Q-7 of Part 98, calculated as 

specified in a proposed new Equation Q-9 in the 

proposed rule amendments. Do not include fuel used 

in a stationary combustion unit where emissions are 

reported under subpart C of this part. 

If you use the carbon mass balance method in 40 CFR 

98.173(b)(1) to determine CO2 emissions: The annual 

mass (metric tons) of all non-fuel material inputs 

(combined) specified in Equations Q-1 through Q-7 of 

Part 98, calculated as specified in a proposed new 

Equation Q-10 in the proposed rule amendments. 

If you use the carbon mass balance method in 40 CFR 

98.173(b)(1) to determine CO2 emissions: The annual 

mass (metric tons) of all solid and liquid products and 

byproducts (combined) specified in Equations Q-1 

through Q-7 of Part 98, calculated as specified in a 

proposed new Equation Q-11 in the proposed rule 
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Subpart Subpart Name New Data Element Description 

amendments. 

If you use the carbon mass balance method in 40 CFR 

98.173(b)(1) to determine CO2 emissions: The 

weighted average carbon content of all gaseous, 

liquid, and solid fuels (combined) included in 

proposed new Equation Q-9, calculated as specified in 

a proposed new Equation Q-12 in the proposed rule 

amendments. 

If you use the carbon mass balance method in 40 CFR 

98.173(b)(1) to determine CO2 emissions: The 

weighted average carbon content of all non-fuel inputs 

to all furnaces (combined) included in proposed new 

Equation Q-10, calculated as specified in a proposed 

new Equation Q-13 in the proposed rule amendments. 

If you use the carbon mass balance method in 40 CFR 

98.173(b)(1) to determine CO2 emissions: The 

weighted average carbon content of all solid and 

liquid products and byproducts from all furnaces 

(combined) included in a proposed new Equation Q11 in the proposed rule amendments, calculated as 

specified in new Equation Q-14. 

S Lime Manufacturing Annual quantity (metric tons) of lime product sold, by 

type. 

V Nitric Acid Production Annual percent N2O emission reduction for all 

production units combined. 

X Petrochemical Production If using the mass balance method or CEMS method to 

calculate GHG emissions: Name and annual quantity 

(in metric tons) of each carbon-containing feedstock. 

If using the mass balance method or CEMS method to 

calculate GHG emissions: Name and annual quantity 

(in metric tons) of each carbon-containing co-product. 

Y Petroleum Refineries Annual quantity of flare gas combusted (in MMscf per 

year) (only when using Equation Y-3). 

Annual average molecular weight of flare gas 

combusted (in mmBtu per MMscf) (only when using 

Equation Y-3). 

Annual average carbon content of flare gas combusted 

(expressed as a decimal fraction)(only when using 

Equation Y-3). 

AA Pulp and Paper 

Manufacturing 

For each pulp mill lime kiln: Quantity of calcium 

oxide (CaO) produced (metric tons). 
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Subpart Subpart Name New Data Element Description 

For each pulp mill lime kiln: Percent of annual heat 

input, individually for each fossil fuel type. 

For each chemical recovery furnace and chemical 

recovery combustion unit for which you are not using 

Equation C-2c to calculate CO2 emissions: Annual 

mass of steam generated (lb steam), individually for 

each fossil fuel type and for spent liquor solids. 

For each chemical recovery furnace and chemical 

recovery combustion unit for which you are not using 

Equation C-2c to calculate CO2 emissions: Ratio of 

the unit’s maximum rated heat input capacity to its 

design rated steam output capacity (mmBtu/lb steam), 

individually for each fossil fuel type and for spent 

liquor solids. 

III. Rationale for Proposed Changes to Reporting and Recordkeeping Requirements 

Based on the four-step evaluation described in Section I.B of this preamble, in particular 

the disclosure concerns discussed in “Step 2” of the evaluation and the alternatives considered in 

“Step 3” and “Step 4” of the evaluation to address those disclosure concerns, the EPA is 

proposing an alternative verification approach. This approach involves use of an inputs 

verification tool and revisions to the reporting and recordkeeping requirements of Part 98. The 

EPA’s rationale for this approach is presented in Sections III.A through C below. Section III.A 

addresses the proposed inputs verification tool and revisions to the requirement to report certain 

“inputs to equations” data elements. Section III.B addresses the proposed revisions to 

recordkeeping requirements. Section III.C addresses the proposed addition of new reporting 

requirements. 

A. Proposed Inputs Verification Tool and Amendment to Reporting Requirements

The EPA is proposing that facilities using “inputs to equations” data elements to calculate 

reported GHGs under the subparts listed in Table 2 of this preamble use an EPA-provided 

electronic inputs verification tool, which would calculate and verify GHG emissions. The inputs 
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Page 26 of 100 

verification tool would be deployed within e-GGRT and integrated without interrupting the 

current electronic reporting process. Reporters would enter their “inputs to equations” data 

elements into the tool within the e-GGRT system along with the data required to be reported in 

the annual report (concurrent entry of “inputs to equations” data elements and data required for 

the annual report would be required starting in reporting year 2014, as further discussed in 

Section III.A.2 of this preamble). As a built-in feature of the e-GGRT system, the tool would use 

the entered “inputs to equations” data elements to calculate the equation outputs, conduct 

electronic verification checks on the “inputs to equations” data elements, and generate a 

verification summary. The tool would not retain the entered “inputs to equations” data elements 

for which the EPA is proposing that the reporting requirement be removed.4

 Accordingly, unlike 

data currently reported to the EPA through e-GGRT, the EPA would not have access to these 

“inputs to equations” data elements. 

Any such sources subject to multiple subparts under Part 98 would be required to use the 

tool for only those subparts listed in Table 2 of this preamble, as discussed in the following 

section. 

1. Detailed Description of Inputs Verification Tool.

The EPA’s current verification approach consists of electronic verification checks 

followed by direct follow-up with facilities. For subparts where the reporting of inputs to 

emission equations has been deferred until 2015, these checks have been conducted using 

reported data other than inputs to emission equations (the reporting of which was deferred). For 

 

4

 Please see section III.A.3 of this preamble for a discussion on which “inputs to equations” data elements the EPA 

is proposing that the reporting requirements be removed. 
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Page 27 of 100 

“supplier” subparts5

 (and starting in reporting year 2012 for subparts with inputs to emission 

equations that were deferred until 2013), these checks have been conducted using reported data 

that include the data needed to calculate outputs of the equations. Reporters under the supplier 

subparts have been entering into e-GGRT the data needed to calculate the annual GHG 

quantities. For reporters under the direct emitter subparts listed in Table 2 of this preamble that 

are using “inputs to equations” data elements to calculate reported GHGs, the EPA is proposing 

to use an approach similar to that currently used for the supplier subparts, where “inputs to 

equations” data elements would be entered into the inputs verification tool within e-GGRT and 

used to calculate the annual GHG emission values and verify these emission values. The 

difference, however, is that these “inputs to equations” data elements would be entered into this 

new inputs verification tool within e-GGRT and would not be reported to the EPA. 

To access the inputs verification tool, reporters would log into e-GGRT. They would 

enter data elements required for the annual report as well as their “inputs to equations” data 

elements. The tool would operate securely within e-GGRT, as a transient process, which means 

that “inputs to equations” data elements (for which the EPA is proposing that the reporting 

requirement be removed) entered into the tool would be temporarily saved in the tool while the 

reporter is actively using the tool, but would not be persisted (i.e., saved) within the e-GGRT 

database. The “inputs to equations” data elements would be discarded when the user’s session 

with e-GGRT ends. Refer to the memorandum “Technical Approach and Design for Inputs 

Verification Tool” (refer to Docket ID No. EPA–HQ–OAR–2010-0929) for a detailed 

description of EPA’s technical approach and design for the inputs verification tool. The 

memorandum describes how the inputs verification tool would use entered data only during the 

 

5

 Supplier subparts (subparts LL through PP of Part 98) apply to fossil fuel suppliers and industrial gas suppliers. The eGGRT system currently calculates equation outputs for suppliers using reported equations inputs. Subpart MM 

reporters began using e-GGRT for reporting in Reporting Year 2012. 
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Page 28 of 100 

reporters’ e-GGRT session and would delete all records of entered data when the reporters exits 

the system. 

If the reporter exits the inputs verification tool prior to completing data entry or 

submitting their annual report, the tool would generate a file of entered “inputs to equations” data 

elements, and allow the reporter to download the file. This file could then be uploaded into the 

tool when the reporter next uses the tool to continue with data entry for the same reporting year. 

This would avoid facilities from needing to re-enter “inputs to equations” data elements that 

were entered in previous e-GGRT sessions. 

After the reporter enters the “inputs to equations” data elements into the inputs 

verification tool, the tool would calculate the annual GHG emissions values. The tool would use 

the following information in calculating these values: (1) “inputs to equations” data elements (for 

which reporting under this action is proposed to be removed) entered into the tool, (2) “inputs to 

equations” data elements entered into e-GGRT (not into the inputs verification tool) (refer to 

Section III.A.3 of this preamble for a discussion of the “inputs to equations” data elements that 

would still be reported under this proposal), (3) information entered into e-GGRT identifying 

which Part 98 calculation method was selected (if applicable), and (4) the selected Part 98 

calculation method. Once the annual GHG emissions values are calculated, the values would be 

pre-filled into the appropriate reporting fields within e-GGRT. Reporters would then have the 

opportunity to override the annual GHG emissions values calculated by the tool with their own 

calculated value. If the reporter chose to override the calculated value, this would be reflected in 

the verification summary. 

Prior to annual report submittal, the inputs verification tool would conduct a series of 

verification checks, including the following: 
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Page 29 of 100 

 Verification checks on the annual GHG emission values calculated by the inputs 

verification tool. As mentioned above, reporters would have the opportunity to override 

and revise the value calculated by the tool; however should this occur, the tool would 

note a discrepancy, which would prompt the EPA for further review after the reporter 

submits the annual report. 

 Verification checks on entered “inputs to equations” data elements. For example, the tool 

would check: (1) whether all required data were entered; (2) whether entered “inputs to 

equations” data element values are within the expected ranges for the data elements; and 

(3) whether expected relationships exist between certain “inputs to equations” data 

elements and certain other reported data elements (e.g., process raw material or 

throughput data that are not “inputs to equations” data elements). 

Some of these checks would be conducted as the reporter enters “inputs to equations” 

data elements (i.e., using “real-time” checking), and other checks would be conducted after the 

reporter has entered all “inputs to equations” data elements, because some algorithms may 

compare certain “inputs to equations” data elements (e.g., production quantity) to GHG emission 

values at the subpart or facility level. 

Also, prior to submittal of the annual report, the inputs verification tool would generate a 

verification summary containing the results of the verification checks. The verification summary 

would specify whether any potential errors, as described above, were identified, without 

specifying the “inputs to equations” data elements. The reporter would have an opportunity to 

review the verification summary and make necessary revisions to the entered “inputs to 

equations” data elements and the reported data elements. 

For example, a facility subject to subpart G that manufactures ammonia using liquid and 

solid feedstocks is currently required under 40 CFR 98.76(b)(1) to report annual CO2 process 

emissions for each ammonia manufacturing unit. Currently, the reporter calculates this reported 

annual GHG emissions value outside of e-GGRT (e.g., using a calculator or computer software), 

using Equations G-2, G-3, and G-4 of Part 98, and monthly values for the following “inputs to 

equations” data elements: quantity of liquid feedstock, quantity of solid feedstock, carbon 
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content value for liquid feedstock, and carbon content value for solid feedstock. We are 

proposing that the reporter instead calculate this reported annual GHG emissions value using the 

inputs verification tool, which not only would use the same equations and data for calculation, 

but would also conduct verification checks, as follows: 

 The reporter would enter all 48 “inputs to equations” data elements” into the inputs 

verification tool (i.e., monthly values for all four “inputs to equations” data elements). 

 The reporter would use the inputs verification tool to calculate annual CO2 process 

emissions. In calculating this value, the tool would use Equations G-2, G-3, and G-4 of 

Part 98 and the 48 “inputs to equations” data element entries. 

 Once the annual CO2 process emissions value is calculated, the inputs verification tool 

would automatically conduct verification checks on the 48 entered “inputs to equations” 

data elements. For example, the tool might conduct the following checks: 

- Real-time checks that all 48 “inputs to equations” data elements were entered. 

- Real-time checks that each of the 12 entered values for carbon content of liquid 

feedstock is within the expected range for carbon content of liquid feedstock (based 

on industry-wide data). The tool would conduct similar comparisons for the 12 

entered “inputs to equations” data elements for the carbon content value for solid 

feedstock. 

- Algorithm check comparing each of the 12 entered values of the quantity of the liquid 

feedstock to all monthly values entered for the year, to determine if individual values 

are within an expected range established using all 12 values. The tool would conduct 

similar comparisons for the 12 entered “inputs to equations” data elements for the 

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quantity of solid feedstock. This type of check would be conducted after the reporter 

has entered all “inputs to equations” data elements. 

 Prior to annual report submittal, the inputs verification tool would automatically generate 

a verification summary, which would flag any potential errors, providing an opportunity 

for the reporter to review the verification summary and revise entered data. The 

verification summary would note if the reporter has overridden any of the annual GHG 

emissions values calculated by the tool. After the reporter completes all revisions to data 

entries, the tool would automatically re-generate the verification summary prior to annual 

report submittal. The EPA would access the verification summary (i.e., the same final 

summary viewed by the reporter) following annual report submittal and certification. 

 The inputs verification tool would also generate a file listing the entered “inputs to 

equations” data elements (for which the EPA is proposing to remove the reporting 

requirements) to be kept by the reporter and maintained as a record in a format currently 

allowed under Part 98 (see 40 CFR 98.3(g), subpart A). Refer to Section III.B of this 

preamble for further discussion of this proposed amendment and the EPA’s rationale for 

requiring this record. 

The EPA has developed a “pilot” inputs verification tool for one subpart, subpart X, 

which will be posted at http://www.epa.gov/ghgreporting/reporters/training/rulepilot.html, to 

demonstrate how the tool would work within e-GGRT, as well as the types of verification checks 

that would be conducted. The EPA seeks comment on the usability of the tool as well as its 

ability to conduct verification on the “inputs to equations” data elements. The EPA also seeks 

comment on additional approaches considered by the EPA for implementation of the inputs 

verification tool; refer to the memorandum “Evaluation of Alternative Verification Approaches 

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for Greenhouse Gas Reporting Rule Subparts for which Reporting of Inputs to Emission 

Equations was Deferred to March 31, 2015” (refer to Docket ID No. EPA–HQ–OAR–2010-

0929) for a description of these additional approaches considered. 

2. Rationale Supporting the Use of the Inputs Verification Tool as an Alternative to 

Collecting Certain “Inputs to Equations” Data Elements for Verification Purposes. 

In the October 30, 2009 final rule (74 FR 56282 – 56283), the EPA described its 

verification approach as the following two-step process: 

 Initial automated review of reported data, using an electronic data quality assurance 

program built into the data system, for use by reporters and the EPA to help assure the 

completeness and accuracy of data. 

 Based on the initial review results, follow up with facilities regarding potential errors, 

discrepancies, or questions, including on-site audits. 

The EPA is currently using the two-step verification process of automated verification 

checks followed by direct follow-up with facilities to verify data currently reported via e-GGRT. 

The EPA is proposing to supplement the current verification approach for facilities 

reportingusing “inputs to equations” data elements to calculate reported GHGs under the 

subparts listed in Table 2 of this preamble using the additional checks that would be conducted 

by the inputs verification tool. During the first 3 years of the Greenhouse Gas Reporting Program 

(GHGRP), the EPA has had success developing and using an electronic reporting and 

verification system for all subparts reporting under the program. During reporting year 2010, the 

EPA developed approximately 1,400 electronic verification checks to verify reported data. Based 

on these verification checks, the EPA followed up with approximately 2,360 of the 

approximately 6,700 facilities that reported in reporting year 2010, resulting in approximately 

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2,300 facilities resolving verification issues by responding to the EPA and/or resubmitting their 

annual report. In reporting year 2011, the EPA programmed an additional 1,000 checks into eGGRT for the subparts that were reporting for the second year, expanding the number of checks 

to 2,400. The EPA also programmed into e-GGRT, for 2011, approximately 1,300 checks for the 

newly-reporting subparts. During reporting year 2011, the EPA followed up with approximately 

3,440 of the approximately 8,000 facilities that reported, resulting in approximately 3,000 

facilities resolving their verification issues. 

For example, for subpart H, the EPA verifies reported GHG emissions data using: (1) 

reported cement production data and (2) publicly available industry data on GHG emissions. 

Using these data, the EPA has established ranges of acceptable production and emission values 

and set up algorithm checks for reported GHG emission values. 

The electronic checks used by the GHGRP have served as a means for the EPA to verify 

reported data while minimizing the burden on both the EPA and reporters. Electronic verification 

is a critical first step to ensuring the completeness and accuracy of reported data and reducing the 

costs of compliance monitoring. 

The inputs verification tool described in Section III.A.1 of this preamble utilizes the same 

approach that the EPA currently uses for calculating and verifying data submitted for supplier 

subparts (and starting in reporting year 2012, inputs to emission equations whose reporting 

deadline was deferred until 2013), except that e-GGRT would not retain the “inputs to 

equations” data elements entered into the tool. Once the annual report is submitted, the EPA 

would review the verification summary generated by the inputs verification tool, along with 

verification summaries that are currently generated using data currently collected through the 

annual report. By requiring use of the inputs verification tool, the EPA would have the additional 
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certainty that reported annual GHG emissions values either were calculated correctly (because 

the values calculated by the tool were submitted to the EPA) or that the EPA would be made 

aware that there were discrepancies between values calculated by the tool and values submitted 

to the EPA. That additional certainty, combined with the additional information provided by the 

range and algorithm checks on the “inputs to equations” data elements themselves, would 

provide the EPA with information necessary to conduct further verification once the annual 

report is submitted. 

If a potential error with one of the “inputs to equations” data elements or with an annual 

GHG emissions value were identified in the verification summary generated by the inputs 

verification tool, the EPA would likely follow up with the facility to determine whether an actual 

error has occurred. While this verification approach may result in more direct follow-up with 

facilities than if the “inputs to equations” data elements were submitted to the EPA, this 

approach would facilitate verification by identifying potential errors and minimizing the number 

of errors before annual reports are submitted. In addition, as discussed elsewhere in the 

preamble, the EPA is retaining the reporting requirement for “inputs to equations” data elements 

for which our four-step evaluation did not identify disclosure concerns and is proposing to 

require reporting of additional new data elements to assist the EPA’s verification effort. These 

“inputs to equations” data elements for which reporting would be retained and these proposed 

new reported data elements would allow the EPA to conduct additional verification and 

minimize the number of follow-ups with facilities. Lastly, for the reasons specified in 

sectionSection III.B of this preamble, the EPA is proposing that facilities retain records for 5 

years, which would allow the EPA time to perform any necessary follow-up with reporters. For 

the reasons stated above, the EPA has determined that the proposed verification approach would 
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be adequate to verify the reported emissions for reporters using “inputs to equations” data 

elements to calculate reported GHGs under the subparts identified in Table 2 of this preamble 

and is a reasonable alternative to collecting “inputs to equations” data elements for which we 

have identified disclosure concerns. 

The EPA is proposing to require the use of the inputs verification tool starting with 

reporting year 2014. The inputs verification tool is designed to be used concurrently with annual 

reporting by facilities. By the time the EPA takes any final action on this proposed amendment, 

reporters would likely have already submitted annual reports for reporting years 2010 through 

2013. While additional verification could be conducted on the past years’ data if the inputs 

verification tool were used for these years, given that most of the data would likely already have 

been published and that the use of best available monitoring methods (BAMM) for these sectors 

is relatively low during these years, the EPA has determined that the added benefit does not 

outweigh the burden that would be required for facilities to use the inputs verification tool for 

years prior to reporting year 2014. 

3. Reporting of 440 “Inputs to Equations” Data Elements Would Not Be Necessary With the 

Proposed Verification Approach.

The EPA is proposing to remove the reporting requirement for 440 “inputs to equations” 

data elements that are in the subparts listed in Table 2 of this preamble. With the proposed 

alternative verification approach described in Section III.A.2 of this preamble, the EPA would no 

longer need to rely on the collection of these “inputs to equations” data elements to verify 

emissions under those subparts. Not having these data elements reported would address concerns 

relative to potential disclosure of these data elements.6

 These 440 data elements are specified in 

 

6

For 23 of these “inputs to equations” data elements, we are proposing to remove the reporting requirement because

we, while there is not a disclosure concern, the EPA determined that these data elements would not be useful for 
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Table 1 of the memorandum “List of Inputs to Equations Data Elements Proposed Not To Be 

Reported” (refer to Docket ID No. EPA–HQ–OAR–2010-0929). 

The 440 “inputs to equations” data elements for which the EPA is proposing to remove 

the reporting requirement must be maintained on-site as records. Because Part 98 already 

requires these “inputs to equations” data elements to be kept as records (see 40 CFR 98.3(g)(2), 

which states that “the data used to calculate the GHG emissions for each unit, operation, process, 

and activity, categorized by fuel or material type” must be kept as records), the EPA is not 

proposing in this action to specify each of the 440 “inputs to equations” data elements in the 

recordkeeping section of each subpart. The EPA considered whether specifying each of these 

“inputs to equations” data elements in the recordkeeping sections of each subpart would improve 

the clarity of the specific records that would be required to be retained. Because the EPA is 

proposing that the “inputs to equations” data elements that would not be reported must be kept as 

records in the format generated by the inputs verification tool (i.e., file for downloading or 

printing), the EPA determined that the data that must be kept as records would be sufficiently 

clear. The EPA seeks comment on whether additional specificity within the recordkeeping 

requirements of each subpart would improve the clarity of the specific records that are required 

to be retained. 

For the purposes of clarifying which data elements must be reported for previous 

reporting years 2010 through 2013, we are proposing to revise Table A-7 of Part 98 to remove all 

440 data elements for which reporting is proposed to be removed. The data elements that are not 

 

data verification and would not inform future GHG policy development in the absence of other data elements for 

which we are proposing to remove the reporting requirement. See section III.A.3 of this preamble for additional 

discussion on this topic.
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being removed from Table A-7 would continue to be reporting requirements, and mustwould be 

reported for previous reporting years 2010 through 2013, as appropriate. 

The EPA is retaining reporting of 170 “inputs to equations” data elements.7 Refer to 

Table 2 in the memorandum “List of ‘Inputs to Equations’ Data Elements Proposed Not To Be 

Reported” (refer to Docket ID No. EPA–HQ–OAR–2010-0929) for a complete list of these 170 

data elements. The 170 “inputs to equations” data elements include certain “inputs to equations” 

data elements for the subparts listed in Table 3 of this preamble, as well as all “inputs to 

equations” data elements for subparts C (only for specified stationary fuel combustion sources 

connected to certain electric generators that deliver power to the local or regional electric power 

grid)8

, W, and II of part 98. For these “inputs to equations” data elements, the EPA is not 

amending these reporting requirements and would therefore let the deferral of these data 

elements expire on March 31, 2015. As a result, these “inputs to equations” data elements would 

be reported for future reporting years starting with reporting year 2014, as well as for previous 

reporting years (i.e., reporting years 2010 through 2013). Based on “Step 2” of our evaluation 

described in Section I.B of this preamble, these data elements would not raise disclosure 

concerns. Having these data elements reported would allow the EPA to do additional 

verification, including conduct year-to-year comparisons, thereby reducing the amount of direct 

follow-up required with facilities. For the reason stated above, collecting these data elements, 

 

7

 These 170 “inputs to equations” data elements include: (1) nine “inputs to equations” data elements in subpart L of 

part 98 that are not being addressed in this rulemaking because they will be addressed in a separate action related to 

subpart L; and (2) five “inputs to equations” data elements in subpart Y of part 98 that are not being addressed in 

this rulemaking because they are being addressed in a separate action. Refer to the EPA’s April 2, 2013 rulemaking 

(78 FR 19802) for EPA’s proposal that these five inputs be removed from reporting.. 8

 Refers to stationary fuel combustion sources (e.g., individual units, aggregations of units, common pipes, or 

common stacks) subject to subpart C meeting both of the following criteria: (1) the stationary fuel combustion 

source contains at least one combustion unit connected to a fuel-fired electric generator that has been granted access 

by the Public Utilities Commission to deliver power to the local or regional electric power grid (excluding 

generators connected to combustion units that are subject to subpart D of this part); and (2) the stationary fuel 

combustion source is located at a facility for which the sum of the nameplate capacities for all such electric 

generators is greater than or equal to 1 megawatt electric output. 
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even in the absence of collecting all “inputs to equations” data elements, would aid in the 

verification process. 

The EPA identified 23 “inputs to equations” data elements for which disclosure concerns 

were not identified based on “Step 2” of our evaluation; however, the EPA is not retaining these 

reporting requirements. The EPA determined that these 23 data elements would not be useful for 

data verification and would not inform future GHG policy development in the absence of other 

“inputs to equations” data elements for which the reporting requirement is proposed to be 

removed under this action. Examples of these 23 “inputs to equations” include reporting the 

selected default molar volume conversion factor and reporting the units of measure of a sitespecific emission factor. These “inputs to equations” are identified in the memorandum “List of 

‘Inputs to Equations’ Data Elements Proposed Not To Be Reported” (refer to Docket ID No. 

EPA–HQ–OAR–2010-0929). 

Regarding the 170 retained “inputs to equations” data elements, for reporting year 2014 

and thereafter, reporters would enter the 170 “inputs to equations” data elements for which we 

are retaining the reporting requirement into e-GGRT. Starting in reporting year 2014, the eGGRT system would retain these 170 data elements as part of the annual report and they would 

be accessible by the EPA once the reporter submits the annual report. In order to ease the burden 

on facilities, for reporting years prior to reporting year 2014, the EPA is proposing that these 

reported “inputs to equations” data elements be submitted as part of the reporting year 2014 

annual report. Specifically, when reporters prepare their reporting year 2014 annual report via eGGRT, they would be required to include these “inputs to equations” data elements for reporting 

year 2014 as well as for all applicable previous reporting years. The annual report, including 

these “inputs to equations” data elements would be submitted via e-GGRT. This approach would 
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prevent facilities from being required to revise, re-certify, and re-submit annual reports for 

reporting years 2010, 2011, 2012, and 2013.

The proposed revisions to the current reporting requirements would apply to all reporters 

subject to the subparts listed in Table 2 of this preamble, including subpart C, and using “inputs 

to equations” data elements to calculate reported GHGs. However, as noted in Table 2, we are 

not proposing to amend the reporting requirements for stationary fuel combustion sources subject 

to subpart C (e.g., individual units, aggregations of units, common pipes, or common stacks) that 

meet the following criteria: (1) the stationary fuel combustion source contains at least one 

combustion unit connected to a fuel-fired electric generator that has been granted access by the 

Public Utilities Commission to deliver power to the local or regional electric power grid 

(excluding generators that are connected to combustion units subject to subpart D of this part); 

and (2) the stationary fuel combustion source is located at a facility for which the sum of 

nameplate capacities for all such electric generators is greater than or equal to 1 megawatt 

electric output. The “inputs to equations” data elements for these stationary fuel combustion 

sources are among those that did not raise disclosure concerns under “Step 2” of our evaluation 

of the “inputs to equations” data elements (refer to Section I.B of this preamble for a discussion 

of the EPA’s four-step evaluation). Refer to the memoranda documenting “Step 2” of our 

evaluation, “Evaluation of Competitive Harm From Reporting 2015 Inputs to Equations” 

(Docket ID No. EPA–HQ–OAR–2010-0929), for further information on the results of the 

analysis for these stationary fuel combustion sources. 

Reporters currently reporting emissions for stationary fuel combustion sources under 

subpart C have the option to utilize one or more of the reporting options under subpart C that 

allow the grouping of stationary combustion units for the purpose of monitoring, calculating, and 
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reporting emissions. The EPA recognizes that stationary combustion units grouped in these 

reporting configurations could include both combustion units associated with electric generators 

(excluding generators connected to combustion units subject to subpart D of this part) (connected 

to the grid and not connected to the grid) and combustion units not associated with electric 

generators (excluding generators connected to combustion units subject to subpart D of this part). 

In these cases where combustion units are grouped, the EPA has determined that there would be 

no disclosure concerns with reporting of “inputs to equations” data elements for the grouped 

combustion units. In reporting combined data for multiple units including those associated with 

an electric generator and subject to reporting under this proposed action, no unit-specific data 

would be revealed. Furthermore, should a facility not wish to disclose aggregated data, it would 

have the option to calculate and report emissions using one of the individual unit reporting 

configurations. The EPA seeks comment on this conclusion. If you believe that there are any 

disclosure concerns, please provide detailed information about the concern, as well as whether 

reporting on an individual unit basis is a feasible reporting option. 

Additionally, the EPA is proposing to revise two paragraphs (40 CFR 98.116(e)(6) and 

40 CFR 98.186(b)(8)) that reference other paragraphs that include “inputs to equations” data 

elements proposed to be removed from Part 98. As a result, we are proposing to remove the cross 

reference while carrying over the substantive information in order to maintain the requirements 

in these paragraphs. 

The EPA requests comment on the proposed inputs verification tool and verification 

approach, and the associated revision to the current reporting requirements as described in this 

section. 

B. Proposed Revisions to Recordkeeping Requirements
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Given the proposed verification approach described in Section III.A of this preamble, the 

EPA considered whether the current record retention period and record format requirements 

would be sufficient to allow the EPA to perform data verification. We considered: 

 The time we would need to follow up with reporters to further verify reported GHG 

emissions. 

 The desirability of retaining multiple years of data records to allow for appropriate 

assessment of compliance and for analyses of trends for policy analysis purposes. 

 The format of records, and whether the current format would be adequate for our 

verification process. For example, we considered whether records of “inputs to 

equations” data elements contained in multiple separate documents (as currently allowed 

under Part 98) would allow an EPA inspector to efficiently analyze the consistency of the 

data elements and use the data elements to perform calculations to confirm reported GHG 

emissions. 

Because there may be more direct follow-up activities under this alternative verification 

approach, we are proposing to extend the record retention period from 3 to 5 years. We have 

determined that 5 years is reasonable given the large number of reporters under the subparts 

identified in Table 2 of this preamble (over 2,000 facilities) and the likely increase in follow-up 

activities. It would be important that relevant records are available to the EPA for follow-up 

activities with facilities, including on-site audits if necessary, regarding potential errors, 

discrepancies, or questions. Should an EPA inspector visit a facility, it would be important to be 

able to examine not only the current year’s records but those from previous years as well, 

because previous years’ data would provide year-to-year comparisons, which are useful for 

verifying the current year’s data. A 5-year record retention period would ensure the availability 

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of relevant records for the follow-up activities described above. The EPA is proposing that this 

5-year record retention requirement begin with records for reporting year 2010, as discussed in 

Section III.A.12 of this preamble. 

For reporters subject to using the proposed inputs verification tool, the EPA is proposing 

to extend the record retention period not only for the subparts listed in Table 2 of the preamble, 

but also for other subparts that apply to reporters subject to a subpart in Table 2. Under this 

proposal, any such facility subject to both a subpart listed in Table 2 of this preamble and a 

subpart not listed in Table 2 would be required to maintain all records required under both 

subparts for a period of 5 years. For example, if a facility is required to use the proposed inputs 

verification tool under subpart C (in Table 2) and to report under subpart HH (not in Table 2), 

the facility would be required to maintain all records required under both subparts for 5 years. 

The EPA is proposing these provisions for two reasons. First, the EPA determined that during a 

site visit, if questions arise regarding the accuracy of an “inputs to equations” data element, it 

may be necessary to examine other non-input recordkeeping information, such as a monitoring 

plan or recordkeeping information in a different subpart, in order to fully investigate the 

accuracy of the data. It is necessary to ensure that all data necessary for verification are available, 

and this proposed 5-year record retention period would provide better assurance of on-site data 

availability. Second, the EPA determined that maintaining multiple sets of data records 

according to different record retention periods could possibly cause confusion and result in 

recordkeeping errors. Providing the same record retention duration for all subparts, as proposed, 

would simplify recordkeeping and thereby minimize the chance for recordkeeping errors. 

In addition, the EPA is proposing revisions to the recordkeeping format for “inputs to 

equations” data elements. Currently, reporters have the option to maintain records of their 
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“inputs to equations” data elements in one or more electronic or hard copy files. The proposed 

record format revision would require reporters to maintain an electronic or hard copy of the 

single file generated by the proposed inputs verification tool, listing all “inputs to equations” data 

elements entered into the tool. This proposed record format change would ensure that the EPA 

could readily access these data, enabling the EPA to quickly and efficiently perform calculations 

and data checks during site visits. All other records required under Part 98 would be maintained 

in the format currently required under Part 98. In combination with the proposed reporting 

requirements discussed in Sections III.A and C of this preamble, these proposed recordkeeping 

requirements would allow the EPA to adequately verify certain reported emissions without 

implicating the disclosure concerns discussed in the memorandum “Evaluation of Competitive 

Harm For Reporting 2015 Inputs to Equations” (refer to Docket ID No. EPA–HQ–OAR–2010-

0929). 

In amending 40 CFR part 98, subpart A to add these recordkeeping requirements, we are 

also correcting an error in the current version of 40 CFR 98.3(g). In a previous action amending 

this paragraph (76 FR 73866, November 29, 2011), our intention was to amend the second 

sentence of the paragraph regarding record retention duration; however, the third sentence 

regarding record format was inadvertently amended. To correct this error, we are proposing to 

remove the second sentence of 40 CFR 98.3(g) and to reinstate the previous third sentence of 40 

CFR 98.3(g) (regarding format of records). 

We seek comment on whether 5 years is the appropriate timeframe for maintaining 

records for facilities required to use the proposed inputs verification tool under a subpart listed in 

Table 2 of this preamble. In addition, we seek comment on the proposal to extend the record 
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retention period for these reporters, not only for the subparts listed in Table 2 of the preamble, 

but also for other subparts that apply to these reporters. 

C. Proposed Requirement to Report Additional Data

As part of our proposal to no longer require reporting of certain “inputs to equations” 

data elements, we are proposing to require that certain reporters using the proposed inputs 

verification tool also report the new data elements specified in Table 4 of this preamble. These 

additional data elements would allow the EPA to perform additional verification checks and 

minimize the number of follow-up activities. These data elements are quantities that provide 

information on the activity level at the facility, emission factors used, characteristics of carboncontaining streams, and other process information that would provide key information for 

verification, including confirming that emissions are appropriate for a given activity-level and 

estimating expected emissions based on data provided. These new data reporting elements would 

also enable the EPA to better understand the following aspects concerning reporters in order to 

inform future GHG policy:9

 (1) the GHG emission profile for the reporter; (2) the relationship of 

GHG emissions to production output or raw material input within the industry sector; and (3) the 

factors influencing GHG emissions. 

The EPA is proposing to add six new equations (Equations Q-9 through Q-14 of part 98) 

to subpart Q to specify how to calculate and report each of the six new data elements proposed to 

be added to subpart Q of part 98. Table 4 of this preamble specifies which equation number 

correlates with each new proposed data element. Refer to the proposed amendments for subpart 

Q for the proposed equations. 

 

9

 The EPA has previously stated that a goal of collecting data under the GHGRP is to inform future GHG policy 

(refer to the April 10, 2009 proposed rule (74 FR 16455). 
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The EPA is proposing confidentiality determinations for these proposed new data 

elements. Those new data elements determined to be confidential business information in a final 

rule would be afforded confidential treatment. Refer to the following Section IV of this preamble 

for the EPA’s proposed confidentiality determinations for the proposed new data elements. 

IV. Confidentiality Determination for Proposed New Data Elements to be Reported 

The EPA is proposing confidentiality determinations for each new data element listed in 

Table 4 of this preamble. To make these determinations, the EPA proposes to use the same 

approach that the EPA previously used for the 2011 final CBI rule (76 FR 30782, May 26, 2011). 

Specifically, the EPA is proposing to assign each new data element listed in Table 4 of this 

preamble to one of 11 direct emitter data categories, based on the type and characteristics of the 

data element. For a description of each data category and the type and characteristics of data 

elements assigned to each category, see Sections II.C and II.D of the July 7, 2010 CBI proposal 

preamble (75 FR 39106 – 39130). 

Based on its evaluation of the new data elements, the EPA is proposing that each new 

data element be assigned to one of the four following direct emitter data categories: 

 Production/Throughput Data that are Not Inputs to Emission Equations. 

 Raw Materials Consumed that are Not Inputs to Emission Equations. 

 Unit/Process “Static” Characteristics that are Not Inputs to Emission Equations. 

 Unit/ Process Operating Characteristics that are Not Inputs to Emission Equations. 

In the 2011 final CBI rule (May 26, 2011, 76 FR 30782), the EPA made categorical 

determinations that all data elements assigned to the “Production/Throughput Data that are Not 

Inputs to Emission Equations” and “Raw Materials Consumed that are Not Inputs to Emission 

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Equations” data categories are entitled to confidential treatment because the data do not meet the 

definition of “emission data” in 40 CFR 2.301(a)(2)(i) and they are CBI. 

The EPA is proposing that seven new data elements be assigned to the 

“Production/Throughput Data that are Not Inputs to Emission Equations” data category and 10 

new data elements be assigned to the “Raw Materials Consumed that are Not Inputs to Emission 

Equations” data category, as shown in Table 5 of this preamble, thereby applying the categorical 

confidentiality determinations made for these categories in the 2011 final CBI rule (i.e., they are 

CBI) to the proposed new reporting elements assigned to these categories. This proposal is not 

changing, nor soliciting comment on, the categorical confidentiality determination for these two 

data categories. Should the EPA finalize the category assignment for these data elements, all new 

data elements assigned to these categories would be considered to be entitled to confidential 

treatment. 

Table 5. Data Elements Proposed to Be Assigned To the “Production/Throughput Data 

that are Not Inputs to Emission Equations” and “Raw Materials Consumed that are Not 

Inputs to Emission Equations” Data Categories 

Subpart Proposed Citation Data Element 

“Production/Throughput Data that are Not Inputs to Emission Equations” Data Category 

G - Ammonia Production 40 CFR 98.76(cb)(14) Annual ammonia production 

(metric tons). 

40 CFR 98.76(db)(15) Annual methanol production 

(metric tons), if this quantity is 

not reported under subpart X of 

Part 98. 

H - Cement Kilns 40 CFR 98.86(b)(16) Annual clinker production 

(metric tons). 

P – Hydrogen Production 40 CFR 98.166(e) Annual methanol production 

(metric tons), if this quantity is 

not reported under subpart X of 

Part 98. 

S - Lime Manufacturing 40 CFR 98.196(b)(18) Annual quantity (metric tons) of 

lime product sold, by type. 
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Subpart Proposed Citation Data Element 

X – Petrochemical 40 CFR 98.246(a)(13) and 

(b)(10) 

If using the mass balance 

method or CEMS method to 

calculate GHG emissions: 

Name and annual quantity (in 

metric tons) of each carboncontaining co-product. 

AA - Pulp and Paper 40 CFR 98.276(l)(1) For each pulp mill lime kiln: 

Quantity of calcium oxide 

(CaO) produced (metric tons).

“Raw Materials Consumed that are Not Inputs to Emission Equations” Data Category 

E - Adipic Acid Production 40 CFR 98.56(m) Annual quantity of cyclohexane 

fed to all production lines, 

combined (metric tons). 

P - Hydrogen Production 40 CFR 98.166(b)(7) Name and annual quantity 

(metric tons) of each carboncontaining fuel and feedstock. 

Q - Iron and Steel 40 CFR 98.176(e)(6)(i)(1) If you use the carbon mass 

balance method in 40 CFR 

98.173(b)(1) to determine CO2

emissions: The annual mass 

(metric tons) of all gaseous, 

liquid, and solid fuels 

(combined) used in process 

units specified in Equations Q-1 

through Q-7, calculated as 

specified in a new Equation Q-9 

in the proposed rule 

amendments. DoDoes not 

include fuel used in a stationary 

combustion unit where 

emissions are reported under 

subpart C of this part. 

40 CFR 98.176(i)(2e)(6)(ii) If you use the carbon mass 

balance method in 40 CFR 

98.173(b)(1) to determine CO2

emissions: The annual mass 

(metric tons) of all non-fuel 

material inputs (combined) 

specified in Equations Q-1 

through Q-7, calculated as 

specified in a new Equation Q10 in the proposed rule 

amendments. 
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Subpart Proposed Citation Data Element 

40 CFR 98.176(i)(3e)(6)(iii) If you use the carbon mass 

balance method in 40 CFR 

98.173(b)(1) to determine CO2

emissions: The annual mass 

(metric tons) of all solid and 

liquid products and byproducts 

(combined) specified in 

Equations Q-1 through Q-7, 

calculated as specified in a new 

Equation Q-11 in the proposed 

rule amendments. 

40 CFR 98.176(i)(4e)(6)(iv) If you use the carbon mass 

balance method in 40 CFR 

98.173(b)(1) to determine CO2

emissions: The weighted 

average carbon content of all 

gaseous, liquid, and solid fuels 

(combined) included in 

Equation Q-9, calculated as 

specified in a new Equation Q12 in the proposed rule 

amendments. 

40 CFR 98.176(i)(5e)(6)(v) If you use the carbon mass 

balance method in 40 CFR 

98.173(b)(1) to determine CO2

emissions: The weighted 

average carbon content of all 

non-fuel inputs to all furnaces 

(combined) included in 

Equation Q-10, calculated as 

specified in a new Equation Q13 in the proposed rule 

amendments. 
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Subpart Proposed Citation Data Element 

40 CFR 98.176(ie)(6)(vi) If you use the carbon mass 

balance method in 40 CFR 

98.173(b)(1) to determine CO2

emissions: The weighted 

average carbon content of all 

solid and liquid products and 

byproducts from all furnaces 

(combined) included in a new 

Equation Q-11 in the proposed 

rule amendments, calculated as 

specified in new Equation Q-14 

in the proposed rule 

amendments. 

X – Petrochemical 40 CFR 98.246(a)(12) and (b)(9) If using the mass balance 

method or CEMS method to 

calculate GHG emissions: 

Name and annual quantity (in 

metric tons) of each carboncontaining feedstock.

AA - Pulp and Paper 40 CFR 98.276(m)(1) For each chemical recovery 

furnace and chemical recovery 

combustion unit for which you 

are not using Equation C-2c to 

calculate CO2 emissions: 

Annual mass of steam 

generated (lb steam), 

individually for each fossil fuel 

type and for spent liquor solids. 

The EPA is proposing to assign eight proposed new data elements to the “Unit Process 

Operating Characteristics that are Not Inputs to Emission Equations” category and one proposed 

new data element to the “Unit/Process Static Characteristics that are Not Inputs to Emission 

Equations” category. In the 2011 final CBI rule, the EPA determined that the data elements in 

these categories are not “emission data” (as defined at 40 CFR 2.301(a)(2)(i)). However, instead 

of categorical determinations, the EPA made confidentiality determinations for individual data 

elements assigned to these two categories. In proposing these determinations, the EPA 

considered the confidentiality criteria at 40 CFR 2.208, in particular whether release of the data 
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is likely to cause substantial harm to the business’s competitive position. See 40 CFR 

2.208(e)(1). The EPA is therefore following the same approach in this action for the proposed 

new reporting elements assigned to these two categories. 

Table 6 of this preamble lists the data elements the EPA proposes to assign to these two 

data categories and presents the EPA’s rationale for proposing to determine that each does or 

does not qualify as CBI under CAA section 114(c). 

Table 6. Proposed Confidentiality Determinations for Proposed New Data Elements 

Assigned to the “Unit/Process Operating Characteristics That Are Not Inputs to Emission 

Equations” and “Unit/Process ‘Static’ Characteristics that Are Not Inputs to Emission 

Equations” Data Categories 

Subpart Citation 

Data 

Element 

Confidentiality 

Determination 

Proposed Rationale for 

Confidentiality Determination 

“Unit/Process Operating Characteristics That Are Not Inputs to Emission Equations” Data 

Category

E – Adipic 

Acid 

Production 

40 CFR 

98.56(n) 

Annual 

percent N2O 

emission 

reduction for 

all production 

units 

combined. 

Not CBI The annual facility percent N2O 

reduction could not be used to 

calculate adipic acid production. 

The level of N2O reductions 

varies by the type of abatement 

technology, the environment in 

which the abatement technology 

is operating, the age of the 

abatement technology, the age of 

the catalyst used, and the 

maintenance level of the 

abatement technology.

H - Cement 

Kilns 

40 CFR 

98.86(b)(17) 

Annual 

average 

clinker CO2

emission 

factor for the 

facility, 

averaged 

across all 

kilns (metric 

tons 

CO2/metric 

ton clinker 

produced). 

CBI This data element could be used 

to back calculate a facility’s 

clinker production data, which 

would result in competitive 

disadvantage. 
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Subpart Citation 

Data 

Element 

Confidentiality 

Determination 

Proposed Rationale for 

Confidentiality Determination 

40 CFR 

98.86(b)(18) 

Annual 

average 

cement kiln 

dust (CKD) 

CO2 emission 

factor for the 

facility, 

averaged 

across all 

kilns (metric 

tons 

CO2/metric 

ton CKD 

produced). 

CBI This data element could provide 

information about the efficiency 

of the operation, which would 

result in competitive 

disadvantage. 

V – Nitric 

Acid 

Production 

40 CFR 

98.226(q) 

Annual 

percent N2O 

emission 

reduction for 

all production 

units 

combined. 

Not CBI The annual facility percent N2O 

reduction for all nitric acid 

production trains combined 

could not be used to calculate the 

nitric acid production value for 

any individual facility. The level 

of N2O reductions for each 

individual facility varies by the 

type of abatement technology, the 

environment in which the 

abatement technology is 

operating, the age of the 

abatement technology, the age of 

the catalyst used, and the 

maintenance level of the 

abatement technology. 

Additionally, facility-level N2O 

emission reduction information is 

already publicly available (see 

docket number EPA-HQ-OAR2010-0750 and 

http://www.climateactionreserve.

org).

Y – 

Petroleum 

Refineries 

40 CFR 

98.256(e)(11)(

i) 

Annual 

quantity of 

flare gas 

combusted 

(in MMscf 

per year) 

(only when 

using 

Equation Y3). 

Not CBI This data element does not reveal 

(nor could be used to calculate) 

details regarding product 

characteristics, actual production 

data, or operating efficiency. It 

does not provide information that 

would allow competitors to infer 

market share, production costs, or 

pricing structures and thus gain a 

competitive advantage. The EPA 

applied the same rationale in the 
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Subpart Citation 

Data 

Element 

Confidentiality 

Determination 

Proposed Rationale for 

Confidentiality Determination 

2010 proposed and 2011 final 

CBI rules (75 FR 39113 and 76 

FR 30803 - 30806), in support of 

a non-CBI determination for 

reporting of the following same 

data element currently required to 

be reported if a different equation 

(Equation Y-1a) is used: annual 

volume of flare gas combusted 

(scf/year) under 40 CFR 

98.256(e)(6).

40 CFR 

98.256(e)(11)(

ii) 

Annual 

average 

molecular 

weight of 

flare gas 

combusted 

(in mmBtu 

per MMscf) 

(only when 

using 

Equation Y3). 

Not CBI This data element does not reveal 

(nor could be used to calculate) 

details regarding product 

characteristics, actual production 

data, or operating efficiency. It 

does not provide information that 

would allow competitors to infer 

market share, production costs, or 

pricing structures and thus gain a 

competitive advantage. The EPA 

applied the same rationale in the 

2010 proposed and 2011 final 

CBI rules (75 FR 39113 76 FR 

30803 - 30806), in support of a 

non-CBI determination for 

reporting of the following same 

data element currently required to 

be reported if a different equation 

(Equation Y-1a) is used: annual 

average molecular weight of the 

flare gas (kg/kg-mole) under 40 

CFR 98.256(e)(6).

40 CFR 

98.256(e)(11)(

iii) 

Annual 

average 

carbon 

content of 

flare gas 

combusted 

(expressed as 

a decimal 

fraction)(only 

when using 

Equation Y3). 

Not CBI This data element does not reveal 

(nor could be used to calculate) 

details regarding product 

characteristics, actual production 

data, or operating efficiency. It 

does not provide information that 

would allow competitors to infer 

market share, production costs, or 

pricing structures and thus gain a 

competitive advantage. The EPA 

applied the same rationale in the 

2010 proposed and 2011 final 

CBI rules (75 FR 39113 76 FR 

30803 - 30806), in support of a 

non-CBI determination for 

reporting of the following same
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Page 53 of 100 

Subpart Citation 

Data 

Element 

Confidentiality 

Determination 

Proposed Rationale for 

Confidentiality Determination 

data element currently required to 

be reported if a different equation 

(Equation Y-1a) is used: annual 

average carbon content of the 

flare gas (kg carbon/kg flare gas) 

under 40 CFR 98.256(e)(6).

AA - Pulp 

and Paper 

40 CFR 

98.276(l)(2) 

For each pulp 

mill lime 

kiln: Percent 

of annual heat 

input, 

individually 

for each fossil 

fuel type. 

Non-CBI Release of this data would not 

result in competitive harm 

because lime kiln fossil fuel use 

as a fraction of design heat input 

was reported to the EPA as part of 

a 2011 ICR survey, and facilities 

reporting via the survey made no 

CBI claims regarding fuel type 

and percent of design heat input. 

“Unit/Process ‘Static’ Characteristics that Are Not Inputs to Emission Equations” Data Category 

AA - Pulp 

and Paper 

40 CFR 

98.276(m)(2) 

For each 

chemical 

recovery 

furnace and 

chemical 

recovery 

combustion 

unit for which 

you are not 

using 

Equation C2c to 

calculate CO2

emissions: 

Ratio of the 

unit’s 

maximum 

rated heat 

input capacity 

to its design 

rated steam 

output 

capacity 

(mmBtu/lb 

steam), 

individually 

for each fossil 

fuel type and 

for spent 

liquor solids. 

ND1

 In the final CBI rulemaking (76 

FR 30799, May 26, 2011), we 

determined that the best approach 

for determining confidentiality of 

production capacity is not to make 

a single CBI determination 

applicable to all facilities within a 

given source category, due to 

differences between facilities. For 

all reported data elements related 

to production capacity, the EPA 

will make case-by-case 

determinations per reporter, in 

accordance with the provisions in 

40 CFR part 2, subpart B for 

facilities that claim these data 

elements as CBI. 

1

 ND = No determination was made.is being proposed. 
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The EPA is requesting comment on two aspects of these confidentiality determinations. 

First, the EPA seeks comment on the proposed data category assignment for each of these data 

elements in Tables 5 and 6. of this preamble. If you believe that the EPA has improperly 

assigned any proposed new data elements to one of the data categories, please provide specific 

comments identifying which proposed new data elements may be mis-assigned along with a 

detailed explanation of why you believe them to be incorrectly assigned and in which data 

category you believe they best belong. 

Second, for those data elements included in Table 6 of this preamble and assigned to the 

two direct emitter data categories without categorical confidentiality determinations, the EPA 

seeks comment on the individual confidentiality determinations we are proposing for these data 

elements. If you comment on this issue, please provide specific comment along with detailed 

rationale and supporting information on whether such data element does or does not qualify as 

CBI. 

V. Impacts of the Proposed Rule 

This section examines the cost impacts of the proposed rulemaking. A detailed discussion 

of the impacts may be found in the memorandum, “Impacts Analysis of the Proposed 2015 

Inputs Proposal,” available in EPA docket ID No. EPA–HQ–OAR–2010-0929. 

A. How were the costs of this proposed rule estimated?

1. Proposed Inputs Verification Tool.

The data elements required to be used for calculating the annual GHG emissions values 

and the cost associated with collecting these data have not changed from the estimate made 

during the original rulemaking process. The time associated with entry of these “inputs to 

equations” data elements into e-GGRT (including into the new inputs verification tool) is 
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expected to be equivalent to the time originally anticipated for data entry. Prior to the inputs 

verification tool, as currently required, reporters must use their own calculation tool (e.g., 

calculator, calculation software) to calculate the annual GHG emissions values, using the same 

sets of equations and entering the same data elements that they would enter into the tool. 

The EPA does recognize however that there may be some time associated with learning 

the new procedures for the inputs verification tool and we have estimated a cost of 

approximately $66 per facility, or $379,000 for the first year for all affected facilities. During 

their first session using the proposed inputs verification tool, reporters would need to spend 

approximately 1 hour becoming familiar with how the tool operates within e-GGRT. The 

proposed new requirement to use the inputs verification tool would not result in any change in 

the respondent activity of entering these data into e-GGRT. Once the reporter has become 

familiar with the tool, EPA does not anticipate any additional burden. The cost includes 

technical, clerical, and managerial labor hours. For further information about this cost estimate, 

refer to the memorandum “Assessment of Cost Impacts of 2015 Inputs Proposal – Revisions to 

Reporting, Recordkeeping, and Verification Requirements under the Greenhouse Gas Reporting 

Program” and the supporting statement for this proposed information collection request, 

“Supporting Statement, Environmental Protection Agency: Revisions to Reporting and 

Recordkeeping Requirements, and Proposed Confidentiality Determinations under the 

Greenhouse Gas Reporting Program, OMB control number 2060-[INSERT NEW NUMBER],-

new, ICR number 2483.01,” both available in docket EPA–HQ–OAR–2010-0929. 

2. Proposed New Data Elements.

We are proposing to add 26 new data elements that were not previously required to be 

reported under Part 98 (see Section II.D of this preamble for further discussion of this proposed 
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amendment), to be reported by facilities in certain subparts that are required to use the proposed 

inputs verification tool. Of these 26 data elements, nine data elements are related to annual 

production or raw material usage, which are collected by a facility as a routine part of conducting 

business. For these data elements, we are not proposing that reporters comply with specific data 

collection or monitoring requirements beyond the methods commonly used for accounting 

purposes. The other 17 data elements proposed to be reported are calculated values using data 

currently required to be collected to perform emissions calculations. For all of these additional 

data elements, the EPA has estimated a nominal additional cost to report the data element and 

fulfill the recordkeeping requirements. The total costs associated with reporting and 

recordkeeping for the 26 data elements in 10 subparts is $80,000. These costs represent the cost 

for all affected facilities in the first year. 

B. Additional Impacts of the Proposed Amendments

The proposed confidentiality determinations for the new data elements would not affect 

whether and how data are reported and, therefore, would not impose any additional burden on 

sources. 

VI. Statutory and Executive Order Reviews 

A. Executive Order 12866: Regulatory Planning and Review and Executive Order 13563: 

Improving Regulation and Regulatory Review

Under Executive Order 12866 (58 FR 51735, October 4, 1993), this action is a 

“significant regulatory action” because this action raises novel legal or policy issues arising out 

of legal mandates, the President’s priorities, or principles set forth in the executive order. 

Accordingly, the EPA submitted this action to the Office of Management and Budget (OMB) for 

review under Executive Orders 12866 and 13563 (76 FR 3821, January 21, 2011) and any 
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changes made in response to OMB recommendations have been documented in the docket for 

this action. 

B. Paperwork Reduction Act

This action proposes to amend reporting and recordkeeping requirements and verification 

procedures for the GHGRP. In addition, the EPA is proposing confidentiality determinations for 

the proposed new data elements in this action. The proposed amendments to the reporting 

requirements in the source category-specific subparts are not anticipated to result in significant 

burden for reporters. The new data elements required to be reported are expected to be readily 

available for affected facilities, or easily calculated using data already required to be collected 

(e.g., a monthly value is currently reported and an annual value is proposed to be reported). 

Impacts associated with the proposed changes to the reporting requirements in each 

subpart are detailed in the memorandum “Impacts Analysis of the Proposed 2015 Inputs 

Proposal” (see Docket ID No. EPA-HQ-OAR-2010-0929). The Office of Management and 

Budget (OMB) has previously approved the information collection requirements for 40 CFR part 

98 under the provisions of the Paperwork Reduction Act, 44 U.S.C. 3501 et seq and has assigned 

OMB control number 2060-0629, ICR 2300.10. OMB has approved the information collection 

requirements for this rulemaking and has assigned OMB control number 2060-new, ICR 

2483.01. The OMB control numbers for the EPA’s regulations in 40 CFR are listed in 40 CFR 

part 9. 

C. Regulatory Flexibility Act (RFA)

The RFA generally requires an agency to prepare a regulatory flexibility analysis of any 

rule subject to notice and comment rulemaking requirements under the Administrative Procedure 

Act or any other statute unless the agency certifies that the rule will not have a significant 
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Page 58 of 100 

economic impact on a substantial number of small entities. Small entities include small 

businesses, small organizations, and small governmental jurisdictions. 

For purposes of assessing the impacts of thetoday’s proposed rule amendments on small 

entities, “small entity” is defined as: (1) Aa small business as defined by the Small Business 

Administration’s (SBA) regulations at 13 CFR 121.201; (2) a small governmental jurisdiction 

that is a government of a city, county, town, school district or special district with a population of 

less than 50,000; or (3) a small organization that is any not-for-profit enterprise which is 

independently owned and operated and is not dominant in its field. This definition of small entity 

is consistent with the definition of small entity used for Part 98.

After considering the economic impacts of today’s proposed amendments on small 

entities, I certify that this action will not have a significant economic impact on a substantial 

number of small entities. The small entities subject to Part 98directly regulated by these 

proposed rule amendments include small businesses across all sectors of the economy 

encompassed by Part 98, small governmental jurisdictions, and small non-profits. TheWe have 

determined that these facilities will experience impacts of these proposed amendments are 

expected to be roughly a first-year cost of $66 per facility for learning new procedures for the 

verification tool and an annual cost of $100 per facility for the recordkeeping and reporting of 26 

new data elements. 

The EPA continuesAlthough these proposed rule amendments will not have a significant 

economic impact on a substantial number of small entities, the EPA nonetheless has tried to 

reduce the impact of this rule on small entities. The EPA supports a “help desk” for the 

Greenhouse Gas Reporting Program, which would be available to answer questions on the 

provisions in this rulemaking.
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Page 59 of 100 

We continue to be interested in the potential impacts of the proposed rule amendments on 

small entities and welcomeswelcome comments on issues related to such impacts. 

D. Unfunded Mandates Reform Act (UMRA)

The proposed amendments and confidentiality determinations do not contain a federal 

mandate that may result in expenditures of $100 million or more for State, local, and tribal 

governments, in the aggregate, or the private sector in any one year. Thus, the proposed 

amendments and confidentiality determinations are not subject to the requirements of sections 

202 or 205 of UMRA. 

This rule is also not subject to the requirements of section 203 of UMRA because it 

contains no regulatory requirements that might significantly or uniquely affect small 

governments. This action proposes to amend reporting and recordkeeping requirements and 

verification procedures for the GHGRP. In addition, the EPA is proposing confidentiality 

determinations for the proposed new data elements in this action. Therefore, this action is not 

subject to the requirements of section 203 of the UMRA. 

E. Executive Order 13132: Federalism

The action does not have federalism implications. It will not have substantial direct 

effects on the states, on the relationship between the national government and the statesStates, or 

on the distribution of power and responsibilities among the various levels of government, as 

specified in Executive Order 13132. The proposed amendments and confidentiality 

determinations apply to facilities that directly emit greenhouses gases and fuel and chemicals 

suppliers. These proposed changes do not apply to governmental entities unless the government 

entity owns a facility that directly emits GHGs above threshold levels (such as a large stationary 

combustion device), so relatively few government facilities would be affected. Moreover, for 
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Page 60 of 100 

government facilities that are subject to the rule, the proposed revisions will not have a 

significant cost impact. This proposed action also does not limit the power of states or localities 

to collect GHG data and/or regulate GHG emissions. Thus, Executive Order 13132 does not 

apply to this rule. 

In the spirit of Executive Order 13132, and consistent with EPA policy to promote 

communications between the EPA and stateState and local governments, the EPA specifically 

solicits comments on this proposed action from stateState and local officials. 

F. Executive Order 13175: Consultation and Coordination with Indian Tribal Governments.

This proposed action does not have tribal implications, as specified in Executive Order 

13175 (65 FR 67249, November 9, 2000). The proposed amendments and confidentiality 

determinations apply directly to facilities that directly emit greenhouses gases or that are 

suppliers of GHGs. They would not have tribal implications unless the tribal entity owns a 

facility that directly emits GHGs above threshold levels (such as a landfill or large combustion 

device). Relatively few tribal facilities would be affected. Thus, Executive Order 13175 does not 

apply to this action. 

G. Executive Order 13045: Protection of Children from Environmental Health Risks and Safety 

Risks

The EPA interprets Executive Order 13045 (62 FR 19885, April 23, 1997) as applying 

only to those regulatory actions that concern health or safety risks, such that the analysis required 

under section 5-501 of the Executive Order has the potential to influence the regulation. This 

proposed action is not subject to Executive Order 13045 because it does not establish an 

environmental standard intended to mitigate health or safety risks. 

H. Executive Order 13211: Actions that Significantly Affect Energy Supply, Distribution, or Use
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Page 61 of 100 

This proposed action is not a “significant energy action” as defined in Executive Order 

13211 (66 FR 28355, May 22, 2001), because it is not likely to have a significant adverse effect 

on the supply, distribution, or use of energy. Part 98 relates to monitoring, reporting, and 

recordkeeping and does not impact energy supply, distribution, or use. This action proposes to

amend reporting and recordkeeping requirements and verification procedures for the GHGRP. In 

addition, the EPA is proposing confidentiality determinations for the proposed new data 

elements in this action. These proposed amendments and confidentiality determinations do not 

make any changes to the existing monitoring, recordkeeping, or reporting requirements under 

Part 98 that affect the supply, distribution, or use of energy. 

I. National Technology Transfer and Advancement Act

Section 12(d) of the National Technology Transfer and Advancement Act of 1995 

(NTTAA), Public Law No. 104-113, 12(d) (15 U.S.C. 272 note) directs the EPA to use voluntary 

consensus standards in its regulatory activities unless to do so would be inconsistent with 

applicable law or otherwise impractical. Voluntary consensus standards are technical standards 

(e.g., materials specifications, test methods, sampling procedures, and business practices) that are 

developed or adopted by voluntary consensus standards bodies. NTTAA directs the EPA to 

provide Congress, through OMB, explanations when the Agency decides not to use available and 

applicable voluntary consensus standards. 

This proposed rulemaking does not involve the use of any new technical standards. 

Therefore, the EPA is not considering the use of any voluntary consensus standards. 

J. Executive Order 12898: Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations
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Executive Order 12898 (59 FR 7629, February 16, 1994) establishes federal executive 

policy on environmental justice. Its main provision directs federal agencies, to the greatest extent 

practicable and permitted by law, to make environmental justice part of their mission by 

identifying and addressing, as appropriate, disproportionately high and adverse human health or 

environmental effects of their programs, policies, and activities on minority populations and lowincome populations in the United States. 

The EPA has determined that these proposed rule amendments will not have 

disproportionately high and adverse human health or environmental effects on minority or lowincome populations because the amendments do not affect the level of protection provided to 

human health or the environment. This is because the proposed amendments address information 

collection and reporting and verification procedures. 
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Proposed Rule Amendments and Confidentiality Determinations 

for Certain Data Elements Required under the 

Mandatory Greenhouse Gas Reporting Rule 

Page 63 of 100 

List of Subjects 40 CFR Part 98 

Environmental protection, Administrative practice and procedure, Greenhouse gases, 

Reporting and recordkeeping requirements. 

Dated: 

 

Gina McCarthy, 

Administrator. 
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Page 64 of 100 

For the reasons stated in the preamble, title 40, chapter I, of the Code of Federal 

Regulations is proposed to be amended as follows: 

PART 98—[AMENDED]—MANDATORY GREENHOUSE GAS REPORTING

1.The authority citation for part 98 continues to read as follows: 

Authority: 42 U.S.C. 7401, et seq. 

Subpart A—[AMENDED] 

2.Section 98.3 is amended by revising paragraphs (c)(4)(vii), (d)(3)(v), (g) introductory 

text, and (g)(2)(i) to read as follows: 

§ 98.3 What are the general monitoring, reporting, recordkeeping and verification 

requirements of this part. 

* * * * * 

(c) * * * 

(4) * * * 

(vii) The owner or operator of a facility is not required to report the data elements 

specified in Table A-6 to this subpart for calendar years 2010 through 2011 until March 31, 

2013. The owner or operator of a facility is not required to report the data elements specified in 

Table A-7 to this subpart for calendar years 2010 through 2013 until March 31, 2015. Data 

elements specified in Table A-7 to this subpart for calendar years 2010 through 2013 must be 

submitted as part of the annual report for reporting year 2014. 

* * * * * 

(d) * * * 

(3) * * * 
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(v) For each stationary fuel combustion source that that meets the criteria specified in § 

98.36(f) of this part, report any facility operating data or process information used for the GHG 

emission calculations. 

* * * * * 

(g) Recordkeeping. An owner or operator that is required to report GHGs under this part 

must keep records as specified in this paragraph. Except as otherwise provided in this paragraph, 

retain all required records for at least 3 years from the date of submission of the annual GHG 

report for the reporting year in which the record was generated. The records shall be kept in an 

electronic or hard-copy format (as appropriate) and recorded in a form that is suitable for 

expeditious inspection and review. If a reporter is required under § 98.5(b) to use software 

specified by the Administrator to enter data to calculate the reported GHGs, all records required 

under Part 98 must be retained by the reporter for 5 years from the date of submission of the 

annual GHG report for the reporting year in which the record was generated. Upon request by 

the Administrator, the records required under this section must be made available to EPA. 

Records may be retained off site if the records are readily available for expeditious inspection 

and review. For records that are electronically generated or maintained, the equipment or 

software necessary to read the records shall be made available, or, if requested by EPA, 

electronic records shall be converted to paper documents. You must retain the following records, 

in addition to those records prescribed in each applicable subpart of this part: 

* * * * * 

(2) * * * 
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(i) The GHG emissions calculations and methods used. For data required by § 98.5(b) to 

be entered into the software specified by the Administrator, maintain the entered data in the 

format generated by the software specified by the Administrator. 

* * * * * 

3.Section 98.5 is revised to read as follows: 

§ 98.5 How is the report submitted? 

(a) Each GHG report and certificate of representation for a facility or supplier must be 

submitted electronically in accordance with the requirements of § 98.4 and in a format specified 

by the Administrator. 

(b) For reporting year 2014 and thereafter, you must enter into verification software 

specified by the Administrator the data used as inputs to the calculation methods specified in 

Table A-8 to Part 98, excluding data required to be reported in the reporting section of each 

subpart listed in Table A-8 to Part 98. 

4.Table A-7 to Subpart A of Part 98 is revised to read as follows: 

Table A–7 to Subpart A of Part 98—Data Elements That Are Inputs to Emission Equations 

and for Which the Reporting Deadline Is March 31, 2015 

Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which reporting date is 

March 31, 2015 (“All” means all data elements in 

the cited paragraph are not required to be 

reported until March 31, 2015) 

A 98.3(d)(3)(v) All. 

C 98.36(b)(9)(iii) Only estimate of the heat input.1

C 98.36(c)(2)(ix) Only estimate of the heat input from each type of fuel 

listed in Table C–2.1

C 98.36(e)(2)(i) All.1

C 98.36(e)(2)(ii)(A) All.1

C 98.36(e)(2)(ii)(C) Only HHV value for each calendar month in which 

HHV determination is required.1
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which reporting date is 

March 31, 2015 (“All” means all data elements in 

the cited paragraph are not required to be 

reported until March 31, 2015) 

C 98.36(e)(2)(ii)(D) All.1

C 98.36(e)(2)(iv)(A) All.1

C 98.36(e)(2)(iv)(C) All.1

C 98.36(e)(2)(iv)(F) All.1

C 98.36(e)(2)(ix)(D) All.1

C 98.36(e)(2)(ix)(E) All.1

C 98.36(e)(2)(ix)(F) All.1

E 98.56(g) All. 

E 98.56(h) All. 

E 98.56(j)(4) All. 

E 98.56(j)(5) All. 

E 98.56(j)(6) All. 

E 98.56(l) All. 

H 98.86(b)(11) All. 

H 98.86(b)(13) Name of raw kiln feed or raw material.

L 98.126(b)(10) All. 

L 98.126(b)(11) All. 

L 98.126(b)(12) All. 

O 98.156(d)(2) All. 

O 98.156(d)(3) All. 

O 98.156(d)(4) All. 

Q 98.176(f)(1) All. 

V 98.226(i) All. 

V 98.226(j) All. 

V 98.226(m)(4) All. 

V 98.226(m)(5) All. 

V 98.226(m)(6) All. 
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which reporting date is 

March 31, 2015 (“All” means all data elements in 

the cited paragraph are not required to be 

reported until March 31, 2015) 

V 98.226(p) All. 

W 98.236(c)(1)(i) All. 

W 98.236(c)(1)(ii) All. 

W 98.236(c)(1)(iii) All. 

W 98.236(c)(2)(i) All. 

W 98.236(c)(3)(i) All. 

W 98.236(c)(3)(ii) All. 

W 98.236(c)(3)(iii) All. 

W 98.236(c)(4)(i)(A) All. 

W 98.236(c)(4)(i)(B) All. 

W 98.236(c)(4)(i)(C) All. 

W 98.236(c)(4)(i)(D) All. 

W 98.236(c)(4)(i)(E) All. 

W 98.236(c)(4)(i)(F) All. 

W 98.236(c)(4)(i)(G) All. 

W 98.236(c)(4)(i)(H) All. 

W 98.236(c)(4)(ii)(A) All. 

W 98.236(c)(5)(iii) All. 

W 98.236(c)(5)(iv) All. 

W 98.236(c)(5)(v) All. 

W 98.236(c)(6)(i)(B) All. 

W 98.236(c)(6)(i)(D) All. 

W 98.236(c)(6)(i)(E) All. 

W 98.236(c)(6)(i)(F) All. 

W 98.236(c)(6)(ii)(A) All. 

W 98.236(c)(6)(ii)(B) All. 

W 98.236(c)(7)(i) All. 
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which reporting date is 

March 31, 2015 (“All” means all data elements in 

the cited paragraph are not required to be 

reported until March 31, 2015) 

W 98.236(c)(8)(i)(B) All. 

W 98.236(c)(8)(i)(C) All. 

W 98.236(c)(8)(i)(F) All. 

W 98.236(c)(8)(ii)(A) All. 

W 98.236(c)(8)(ii)(D) All. 

W 98.236(c)(8)(iii)(A) All. 

W 98.236(c)(8)(iii)(D) All. 

W 98.236(c)(8)(iii)(E) All. 

W 98.236(c)(10)(ii) All. 

W 98.236(c)(10)(iii) All. 

W 98.236(c)(11)(ii) All. 

W 98.236(c)(12)(ii) All. 

W 98.236(c)(12)(iii) All. 

W 98.236(c)(12)(v) All. 

W 98.236(c)(13)(i)(B) All. 

W 98.236(c)(13)(i)(E) All. 

W 98.236(c)(13)(i)(F) All. 

W 98.236(c)(13)(ii)(A) All. 

W 98.236(c)(13)(ii)(B) All. 

W 98.236(c)(13)(iii)(A) All. 

W 98.236(c)(13)(iii)(B) All. 

W 98.236(c)(13)(v)(A) All. 

W 98.236(c)(14)(i)(B) All. 

W 98.236(c)(14)(ii)(A) All. 

W 98.236(c)(14)(ii)(B) All. 

W 98.236(c)(14)(iii)(A) All. 

W 98.236(c)(14)(iii)(B) All. 
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which reporting date is 

March 31, 2015 (“All” means all data elements in 

the cited paragraph are not required to be 

reported until March 31, 2015) 

W 98.236(c)(14)(v)(A) All. 

W 98.236(c)(15)(i)(A) All. 

W 98.236(c)(15)(i)(B) All. 

W 98.236(c)(15)(ii)(A) All. 

W 98.236(c)(15)(ii)(B) All. 

W 98.236(c)(16)(i) All. 

W 98.236(c)(16)(ii) All. 

W 98.236(c)(16)(iii) All. 

W 98.236(c)(16)(iv) All. 

W 98.236(c)(16)(v) All. 

W 98.236(c)(16)(vi) All. 

W 98.236(c)(16)(vii) All. 

W 98.236(c)(16)(viii) All. 

W 98.236(c)(16)(ix) All. 

W 98.236(c)(16)(x) All. 

W 98.236(c)(16)(xi) All. 

W 98.236(c)(16)(xii) All. 

W 98.236(c)(16)(xiii) All. 

W 98.236(c)(16)(xiv) All. 

W 98.236(c)(17)(ii) All. 

W 98.236(c)(17)(iii) All. 

W 98.236(c)(17)(iv) All. 

W 98.236(c)(18)(i) All. 

W 98.236(c)(18)(ii) All. 

W 98.236(c)(19)(iv) All. 

W 98.236(c)(19)(vii) All. 

Y 98.256(h)(5) Only value of the correction. 
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which reporting date is 

March 31, 2015 (“All” means all data elements in 

the cited paragraph are not required to be 

reported until March 31, 2015) 

Y 98.256(k)(4) Only mole fraction of methane in coking gas. 

Y 98.256(n)(3) All (if used in Equation Y–21 to calculate emissions 

from equipment leaks).

Y 98.256(o)(4)(vi) Only tank-specific methane composition data and gas 

generation rate data. 

AA 98.276(e) All. 

CC 98.296(b)(10)(i) All. 

CC 98.296(b)(10)(ii) All. 

CC 98.296(b)(10)(iii) All. 

CC 98.296(b)(10)(iv) All. 

CC 98.296(b)(10)(v) All. 

CC 98.296(b)(10)(vi) All. 

II 98.356(d)(2) All (if conducting weekly sampling). 

II 98.356(d)(3) All (if conducting weekly sampling). 

II 98.356(d)(4) Only weekly average temperature (if conducting 

weekly sampling).

II 98.356(d)(5) Only weekly average moisture content (if conducting 

weekly sampling). 

II 98.356(d)(6) Only weekly average pressure (if conducting weekly 

sampling). 1

 Required to be reported only by stationary fuel combustion sources (e.g., individual units, 

aggregations of units, common pipes, or common stacks) subject to subpart C of part 98 that 

meet both of the following criteria: (1) the stationary fuel combustion source contains at least 

one combustion unit connected to a fuel-fired electric generator that has been granted access by 

the Public Utilities Commission to deliver power to the local or regional electric power grid 

(excluding generators that are connected to combustion units subject to subpart D of this part); 

and (2) the stationary fuel combustion source is located at a facility for which the sum of the 

nameplate capacities for all such electric generators is greater than or equal to 1 megawatt 

electric output. 

5.Table A-8 to Subpart A of Part 98 is added to read as follows: 
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Table A–8 to Subpart A of Part 98—Calculation Methods For Which Inputs To the 

Calculation Methods Must be Entered Into Verification Software Specified By the 

Administrator. 

Subpart Calculation Method (Equation Number in 40 CFR Part 98 or Description 

of Method) 

Subpart C 1 C-1, C-1a, C-1b, C-2b, C-2c, C-3, C-4, C-5, C-8, C-8a, C-8b, C-10, C-13, the 

calculation method specified in § 98.3(d)(3)(iv) of subpart A of part 98 

Subpart E E-1, E-2, E-3a, E-3b, E-3c, E-3d 

Subpart F F-2 (including the method for calculating the anode effect minutes per cell-day 

(AEM) and slope coefficients (SCF4), F-3 (including the method for 

calculating the overvoltage factor (EFCF4)), F-5, F-6, F-7, F-8 

Subpart G G-1, G-2, G-3 

Subpart H H-2 (including the method in § 98.84(d) of subpart H of part 98 for calculating 

the quantity of clinker produced), H-3, H-4, H-5 

Subpart K K-1, K-3 

Subpart L L-1, L-2, L-3, L-4, L-6, L-7, L-8, L-17, L-18, L-20, L-21, L-22, L-23, L-25, L26, L-27, L-31, L-34 

Subpart N N-1 

Subpart O O-3, O-4, O-8, O-9 (including the calculation method specified in § 

98.154(l)(2) of subpart O of part 98) 

Subpart P P-1, P-2, P-3 

Subpart Q Q-1, Q-2, Q-3, Q-4, Q-5, Q-6, Q-7, the calculation methods specified in § 

98.173(b)(2)(iii), (b)(2)(iv), and (c) of subpart Q of part 98 

Subpart R R-1 

Subpart S S-1, S-2, S-3, S-4 (including the calculation method specified in § 98.194(a) 

Subpart U U-1, U-2 

Subpart V V-2, V-3a, V-3b, V-3c, V-3d 

Subpart X X-1, X-2, X-3, C-8 

Subpart Y Y-1a, Y-1b, Y-3, Y-4, Y-6, Y-8, Y-11, Y-12 (including the method for 

correcting the calculation, if applicable, as specified in § 98.253(f)(5)), Y-13, 

Y-14, Y-15, Y-16a, Y-16b, Y-17, Y-18, Y-19, Y-20, Y-22, Y-23, the methods 

for calculating emissions from coke burn-off specified in § 98.253(c)(4) and 

(5) (alternatives to using Equations Y-9 and Y-10 of Part 98), the calculation 

method specified in § 98.253(n) of subpart Y of part 98 

Subpart Z Z-1a, Z-1b 

Subpart AA C-1, C-1a, C-1b, C-2a, C-3, C-4, C-5, C-8, C-8a, C-8b, C-9a, AA-1, AA-2, 

AA-3 

Subpart BB BB-1, BB-2 

Subpart CC CC-1, CC-2 

Subpart EE EE-2 

Subpart GG GG-1 

Subpart TT TT-2, TT-3 

1

 Does not apply to any stationary fuel combustion sources (e.g., individual units, aggregations of 

units, common pipes, or common stacks) meeting both of the following criteria: (1) the 
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stationary fuel combustion source contains at least one combustion unit connected to a fuel-fired 

electric generator electric (excluding generators that are connected to combustion units subject to 

subpart D of this part); and (2) the stationary fuel combustion source is located at a facility for 

which the sum of the nameplate capacities for all such electric generators is greater than or equal 

to 1 megawatt electric output. 

Subpart C—[AMENDED] 

6.Section 98.36 is amended by: 

a. Revising paragraph (a).);

b. Revising paragraph (b)(9)(iii) and adding paragraph (b)(9)(iv).);

c. Revising paragraph (c)(2)(ix) and adding paragraph (c)(2)(x).);

d. Revising paragraphs (e)(2)(i), (e)(2)(ii)(A), (e)(2)(ii)(C), and (e)(2)(ii)(D); and adding 

paragraph (e)(2)(ii)(E).); and

e. Revising paragraphs (e)(2)(iv)(A), (e)(2)(iv)(C), (e)(2)(iv)(F), and (e)(2)(ix)(D) 

through (F); and adding paragraph (f). 

The revisions and additions read as follows: 

§ 98.36 Data reporting requirements. 

* * * * * 

(a) In addition to the facility-level information required under §98.3, the annual GHG 

emissions report shall contain the unit-level or process-level data specified in paragraphs (b) 

through (f) of this section, as applicable, for each stationary fuel combustion source (e.g., 

individual unit, aggregation of units, common pipe, or common stack). 

(b) * * * 

(9) * * * 

(iii) The annual CH4 and N2O emissions for each type of fuel listed in Table C–2 of this 

subpart that was combusted in the unit during the report year, expressed in metric tons of each 

gas and in metric tons of CO2e. 
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(iv) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, report an estimate of the heat input from each type of fuel listed in 

Table C–2 of this subpart that was combusted in the unit during the report year. 

* * * * * 

(c) * * * 

(2) * * * 

(ix) For each type of fuel listed in Table C–2 of this subpart that was combusted during 

the report year in the units sharing the common stack or duct during the report year, the annual 

CH4 and N2O mass emissions from the units sharing the common stack or duct, expressed in 

metric tons of each gas and in metric tons of CO2 e. 

(x) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, an estimate of the heat input from each type of fuel listed in Table 

C–2 of this subpart that was combusted during the report year in the units sharing the common 

stack or duct during the report year. 

* * * * * 

(e) * * * 

(2) * * * 

(i) For the Tier 1 Calculation Methodology, for each stationary fuel combustion source 

that meets the criteria specified in paragraph (f) of this section, report the total quantity of each 

type of fuel combusted in the unit or group of aggregated units (as applicable) during the 

reporting year, in short tons for solid fuels, gallons for liquid fuels and standard cubic feet for 

gaseous fuels, or, if applicable, therms or mmBtu for natural gas. 

(ii) * * * 
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(A) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, the total quantity of each type of fuel combusted in the unit or group 

of aggregated units (as applicable) during each month of the reporting year. Express the quantity 

of each fuel combusted during the measurement period in short tons for solid fuels, gallons for 

liquid fuels, and scf for gaseous fuels. 

* * * * * 

(C) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, the high heat values used in the CO2 emissions calculations for each 

type of fuel combusted during the reporting year, in mmBtu per short ton for solid fuels, mmBtu 

per gallon for liquid fuels, and mmBtu per scf for gaseous fuels. Report a HHV value for each 

calendar month in which HHV determination is required. If multiple values are obtained in a 

given month, report the arithmetic average value for the month. Indicate whether each reported 

HHV is a measured value or a substitute data value. 

(D) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, if Equation C–2c of this subpart is used to calculate CO2 mass 

emissions, report the total quantity (i.e., pounds) of steam produced from MSW or solid fuel 

combustion during each month of the reporting year, and the ratio of the maximum rate heat 

input capacity to the design rated steam output capacity of the unit, in mmBtu per lb of steam. 

(E) For each HHV used in the CO2 emissions calculations for each type of fuel 

combusted during the reporting year, indicate whether the HHV is a measured value or a 

substitute data value. 

* * * * * 

(iv) * * * 
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(A) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, the quantity of each type of fuel combusted in the unit or group of 

units (as applicable) during each month of the reporting year, in short tons for solid fuels, gallons 

for liquid fuels, and scf for gaseous fuels. 

* * * * * 

(C) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, the carbon content and, if applicable, gas molecular weight values 

used in the emission calculations (including both valid and substitute data values). For each 

calendar month of the reporting year in which carbon content and, if applicable, molecular 

weight determination is required, report a value of each parameter. If multiple values of a 

parameter are obtained in a given month, report the arithmetic average value for the month. 

Express carbon content as a decimal fraction for solid fuels, kg C per gallon for liquid fuels, and 

kg C per kg of fuel for gaseous fuels. Express the gas molecular weights in units of kg per kgmole. 

* * * * * 

(F) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, the annual average HHV, when measured HHV data, rather than a 

default HHV from Table C–1 of this subpart, are used to calculate CH4 and N2O emissions for a 

Tier 3 unit, in accordance with §98.33(c)(1). 

* * * * * 

(ix) * * * 
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(D) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, the carbon-based F-factor used in Equation C–13 of this subpart, for 

each type of fossil fuel combusted, in scf CO2 per mmBtu. 

(E) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, the annual average HHV value used in Equation C–13 of this 

subpart, for each type of fossil fuel combusted, in Btu/lb, Btu/gal, or Btu/scf, as appropriate. 

(F) For each stationary fuel combustion source that meets the criteria specified in 

paragraph (f) of this section, the total quantity of each type of fossil fuel combusted during the 

reporting year, in lb, gallons, or scf, as appropriate. 

* * * * * 

(f) Each stationary fuel combustion source (e.g., individual unit, aggregation of units, 

common pipe, or common stack) subject to reporting under paragraph (b), (c), or (d)(2) of this 

section must indicate if both of the following two conditions are met: 

(1) The stationary combustion source contains at least one combustion unit connected to 

a fuel-fired electric generator that has been granted access by the Public Utilities Commission to 

deliver power to the local or regional electric power grid (excluding generators that are 

connected to combustion units that are subject to subpart D of this part). 

(2) The stationary fuel combustion source is located at a facility for which the sum of the 

nameplate capacities for all electric generators specified in paragraph (f)(1) of this section is 

greater than or equal to 1 megawatt electric output. 

Subpart E—[AMENDED] 

7.Section 98.56 is amended by: 

a. Revising the introductory text.;
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b. Removing and reserving paragraphs (b), (c), (j)(1), and (j)(3).); and

c. Adding paragraphs (m) and (n). 

The revisions and additions read as follows: 

§ 98.56 Data reporting requirements. 

In addition to the information required by §98.3(c), each annual report must contain the 

information specified in paragraphs (a) through (n) of this section at the facility level. 

* * * * * 

(m) Annual quantity of cyclohexane fed to all production lines combined (metric tons). 

(n) Annual percent N2O emission reduction for all production units combined. 

* * * * * 

Subpart F—[AMENDED] 

8.Section 98.66 is amended by: 

a. Removing and reserving paragraphs (a) and (c)(2).); 

b. Revising paragraphs (c)(3), (e)(1), and (f)(1).); and

c. Removing and reserving paragraph (g). 

The revisions read as follows: 

§ 98.66 Data reporting requirements. 

* * * * * 

(c) * * * 

(3) The last date when the smelter-specific-slope coefficients (or overvoltage emission 

factors) were measured. 

* * * * * 

(e) * * * 
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(1) Annual anode consumption if using the method in §98.63(g). 

* * * * * 

(f) * * * 

(1) Annual paste consumption if using the method in §98.63(g). 

* * * * * 

Subpart G—[AMENDED] 

9.Section 98.76 is amended by: 

a. Revising the introductory text.Removing and reserving paragraph (b)(2) and 

paragraphs (b)(7) through (11); and

b. Removing and reserving paragraph (b)(2) and paragraphs (b)(7) through (11).

c. Adding paragraphs (cb)(14) and (d15). 

The revisions and additions read as follows: 

§ 98.76 Data reporting requirements. 

In addition to the information required by §98.3(c), each annual report must contain the 

information specified in paragraphs (a) through (d) of this section, as applicable for each 

ammonia manufacturing process unit.

* * * * *

(c* * * * * 

(b) * * * 

(14) Annual ammonia production (metric tons). 

(d15) Annual methanol production (metric tons), if this quantity is not reported under 

subpart X of Part 98. 

Subpart H—[AMENDED] 
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10. Section 98.86 is amended by: 

a. Removing and reserving paragraphs (b)(2), (b)(5), (b)(6), (b)(8), (b)(10), and (12).);

b. Revising paragraphs (b)(13) and (15).); and

c. Adding paragraphs (b)(16) through (18). 

The revisions and additions read as follows: 

§ 98.86 Data reporting requirements. 

* * * * * 

(b) * * * 

(13) Name of raw kiln feed or raw material. 

* * * * * 

(15) Method used to determine the monthly clinker production from each kiln. 

(16) Annual clinker production (metric tons). 

(17) Annual average clinker CO2 emission factor for the facility, averaged across all kilns 

(metric tons CO2/metric ton clinker produced). 

(18) Annual average CKD CO2 emission factor for the facility, averaged across all kilns 

(metric tons CO2/metric ton CKD produced). 

Subpart K—[AMENDED] 

11. Section 98.116 is amended by: 

a. Removing and reserving paragraphs (b), (e)(4), and (e)(5).); and

b. Revising paragraph (e)(6). 

The revisions read as follows: 

§ 98.116 Data reporting requirements. 

* * * * * 
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(e) * * * 

(6) List the method used for the determination of carbon content for each material 

included for the calculation of annual process CO2 emissions for each EAF (e.g., supplier 

provided information, analyses of representative samples you collected). 

* * * * * 

Subpart L—[AMENDED] 

12. Section 98.126 is amended by: 

a. Revising paragraph (b)(1).);

b. Removing and reserving paragraph (b)(2).);

c. Revising paragraphs (b)(6), (b)(7), and (b)(8)(i) through (iv).);

d. Removing and reserving paragraphs (b)(8)(v) and (b)(9).);

e. Revising paragraph (c)(1).);

f. Removing and reserving paragraph (c)(2).);

g. Revising paragraph (d).); and

h. Removing and reserving paragraphs (f)(1), (g)(1), and (h)(2). 

The revisions read as follows: 

§ 98.126 Data reporting requirements. 

* * * * * 

(b) * * * 

(1) If you calculate the relative and absolute errors under § 98.123(b)(1), the absolute and 

relative errors calculated under paragraph § 98.123(b)(1). 

* * * * * 

(6) The chemical formula of each fluorine-containing reactant that is fed into the process. 
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(7) The chemical formula of each fluorine-containing product produced by the process. 

(8) * * * 

(i) The chemical formula of each fluorine-containing product that is removed from the 

process and fed into the destruction device. 

(ii) The chemical formula of each fluorine-containing by-product that is removed from 

the process and fed into the destruction device. 

(iii) The chemical formula of each fluorine-containing reactant that is removed from the 

process and fed into the destruction device. 

(iv) The chemical formula of each fluorine-containing by-product that is removed from 

the process and recaptured. 

* * * * * 

(c) * * * 

(1) The identity of the process activity used to estimate emissions (e.g., product produced 

or reactant consumed). 

* * * * * 

(d) Reporting for missing data. Where missing data have been estimated pursuant to § 

98.125, you must report: 

(1) The reason the data were missing, the length of time the data were missing, and the 

method used to estimate the missing data. 

(2) Estimates of the missing data for all missing data associated with data elements 

required to be reported in this section that are inputs to calculation methods specified in §

98.123. 

* * * * * 
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Subpart N—[AMENDED] 

13. Section 98.146 is amended by revising paragraph (b)(2) and removing and 

reserving paragraphs (b)(4) and (b)(6) to read as follows: 

§ 98.146 Data reporting requirements. 

* * * * * 

(b) * * * 

(2) Annual quantity of each carbonate-based raw material charged (tons) to all furnaces 

combined. 

* * * * * 

Subpart O—[AMENDED] 

14. Section 98.156 is amended by: 

a. Removing and reserving paragraphs (a)(2), (a)(7) through (10), (b)(1), and (b)(2).);

b. Revising paragraph (d) introductory text.; and

c. Removing and reserving paragraphs (d)(1), (d)(5), and (e)(1). 

The revisions read as follows: 

§ 98.156 Data reporting requirements. 

* * * * * 

(d) If the HFC–23 concentration measured pursuant to §98.154(l) is greater than that 

measured during the performance test that is the basis for the destruction efficiency (DE), the 

facility shall report the following: 

* * * * * 

Subpart P—[AMENDED] 

15. Section 98.166 is amended by: 
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Page 84 of 100 

a. Revising the introductory text.;

b. Removing and reserving paragraphs (b)(2), (b)(5), and (b)(6).); and

c. Adding paragraphs (b)(7) and (e). 

The revisions and additions read as follows: 

§ 98.166 Data reporting requirements. 

In addition to the information required by §98.3(c), each annual report must contain the 

information specified in paragraphs (a) or (b) of this section, as appropriate, and paragraphs (c) 

through (e) of this section: 

* * * * * 

(b) * * * 

(7) Name and annual quantity (metric tons) of each carbon-containing fuel and feedstock. 

* * * * * 

(e) Annual methanol production (metric tons), if this quantity is not reported under 

subpart X of Part 98. 

Subpart Q—[AMENDED] 

16. Section 98.176 is amended by: 

a. Revising paragraph (b).);

b. Removing and reserving paragraphs (e)(1), (e)(3), (e)(4); and adding paragraph 

(e)(6).); and 

c. Removing and reserving paragraphs (f)(2) through (4), and (g). 

The revisions and additions read as follows: 

§ 98.176 Data reporting requirements. 

* * * * * 
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Page 85 of 100 

(b) If a CEMS is used to measure CO2 emissions, then you must report the annual 

production quantity for the production unit (in metric tons) for taconite pellets, coke, sinter, iron, 

and raw steel. 

* * * * * 

(e) * * * 

(6) The information specified in paragraphs (e)(6)(i) through (vi) of this section 

aggregated for all process units for which CO2 emissions were determined using the mass 

balance method in § 98.173(b)(1), except as provided in § 98.174(b)(4). 

(i) The annual mass (metric tons) of all gaseous, liquid, and solid fuels (combined) used 

in process units for which CO2 emissions were determined using Equations Q-1 through Q-7 of 

this section, calculated as specified in Equation Q-9 of this section. 

ݑܨ݈݁ 	ൌ ቀ∑ ܨ௚, ∗ 	௜ெௐ೔

ெ௏஼

௡

௜ୀଵ ∗ 0.001 ൅ ܨ௟, ∗ ௜ߩ௟, ∗ ௜0.001	 ൅ ܨ௦,௜ቁ (Eq. Q-9) 

Where: 

Fuel = Annual mass of all gaseous, liquid, and solid fuels used in process units 

(metric tons). 

n = Number of process units where fuel is used. 

Fg,i = Annual volume of gaseous fuel combusted (“(Fg)” in Equations Q-1, Q-4 

and Q-7 of this section) for each process (scf). 

MWi = Molecular weight of gaseous fuel used in each process (kg/kg-mole). 

MVC = Molar volume conversion factor at standard conditions, as defined in § 

98.6. Use 849.5 scf per kg mole if you select 68 °F as standard 

temperature and 836.6 scf per kg mole if you select 60 °F as standard 

temperature. 

Fl,i = Annual volume of the liquid fuel combusted (“(Fl)” included in Equation 

Q-1 of this section) for each process unit (gallons). 

Fs,i = Annual mass of the solid fuel combusted (“(Fs)” in Equation Q-1 of this 

section) for each process unit (metric tons). 
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ρl,i = Density of the liquid fuel (kg/gallon). 

0.001 = Conversion factor from kg to metric tons. 

(ii) The annual mass (metric tons) of all non-fuel material inputs (combined) specified in 

Equations Q-1 through Q-7 of this section, calculated as specified in Equation Q-10 of this 

section. 

௡ ௡௜݈݁݁ݐܵ ൅ ݀݁݋ݎݐ݈݁ܿܧ ൅ ݁݁݀ܨ ൅ ݈ܽ݋ܥ ൅ ݊݋ܾݎܽܥ ൅ ݔݑ݈ܨ ൅ ݌ܽݎܵܿ ൅ ݊݋ݎܫ ൅ ܱ ∑ሺ ൌ ܫܨܰ

௜ୀଵ ൅

 (-10Q .Eq (ݎ݄݁ݐܱ൅݁ݎܱ

Where: 

NFI = Annual mass of all non-fuel inputs (to all process unit types) specified in 

Equations Q-1 through Q-7 of this section (metric tons). 

n = Number of process units, all process types. 

O = Annual mass of greenball (taconite) pellets fed to the taconite furnace(s) 

(metric tons). 

Iron = Annual mass of molten iron charged to the basic oxygen furnace(s) plus 

annual mass of direct reduced iron charged to the EAF(s) (metric tons). 

Scrap = Annual mass of ferrous scrap charged to the basic oxygen furnace(s) and 

EAF(s) (metric tons). 

Flux = Annual mass of flux materials charged to the basic oxygen furnace(s) and 

EAF(s) (metric tons). 

Carbon = Annual mass of carbonaceous materials (e.g., coal, coke) charged to the 

basic oxygen furnace(s), EAF(s), and direct reduction furnace(s) (metric 

tons). 

Coal = Annual mass of coal charged to the coke oven battery(s) (metric tons). 

Feed = Annual mass of sinter feed material charged to the sinter process(es) 

(metric tons). 

Electrode = Annual mass of carbon electrode consumed in the EAF(s) (metric tons). 

Steelin = Annual mass of molten steel charged to the decarburization vessels (metric 

tons). 

Ore = Annual mass of iron ore or iron ore pellets fed to the direct reduction 

furnace(s) (metric tons). 
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Other = Annual mass of other materials charged to the direction reduction 

furnace(s) (metric tons). 

(iii) The annual mass (metric tons) of all solid and liquid products and byproducts 

(combined) specified in Equations Q-1 through Q-7 of this section, calculated as specified in 

Equation Q-11 of this section. 

௡∑ሺ ൌ ݏݐܿݑ݀݋ݎܲ

 (-11Q .ሺEq		ሻ ܯܰ ൅ ݊݋ݎܫ ൅ ݎ݁ݐܵ݅݊ ൅ ݇݁݋ܥ ൅ ݈ܵܽ݃ ൅ ௨௧௢݈݁݁ݐܵ ൅ ܴ ൅ ܲ ୀଵ௜

Where: 

Products = Annual mass of all solid and liquid products and by-products (from all 

process units) specified in Equations Q-1 through Q-7 of this section 

(metric tons). 

n = Number of process units, all types. 

P = Annual mass of fired pellets produced by the taconite furnace (metric 

tons). 

R = Annual mass of air pollution control residue from all process units (metric 

tons). 

Steelout = Annual mass of steel produced by the basic oxygen furnace(s), EAF(s) and 

decarburization vessel(s) (metric tons). 

Slag = Annual mass of slag produced by the basic oxygen furnace(s) and EAF(s) 

(metric tons). 

Coke = Annual mass of coke produced by the non-recovery coke batteries (metric 

tons). 

Sinter = Annual mass of sinter produced from the sinter process(es) (metric tons). 

Iron = Annual mass of iron produced from the direct reduction furnace (metric 

tons). 

NM = Annual mass of non-metallic materials produced by the direct reduction 

furnace (metric tons). 

(iv) The weighted average carbon content of all gaseous, liquid, and solid fuels 

(combined) included in Equation Q-9 of this section, calculated as specified in Equation Q-12 of 

this section. 
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ܨܥ௔௩௚ ൌ ቀ ∑ ி೒,೔	∗

ಾೈ೔

ಾೇ಴

೙

೔సభ ∗஼೒೑,೔∗଴.଴଴ଵାி೗,೔∗஼೗೑,೔∗଴.଴଴ଵା	ிೞ,೔∗஼ೞ೑ ቁ

ி௨௘௟ (Eq. Q-12) 

Where: 

CFavg = Weighted average carbon content of all gaseous, liquid, and solid fuels 

included in Equation Q-9 of this section (weight fraction). 

n = Number of gaseous, liquid, and solid fuel input to each process unit as 

used in Equation Q-9. 

Cgf,i = Average carbon content of the gaseous fuel used in each process, from the 

fuel analysis results (kg C per kg of fuel). 

Clf,i = Carbon content of the liquid fuel used in each process, from the fuel 

analysis results (kg C per gallon of fuel. 

Csf = Carbon content of the solid fuel used in each process, from the fuel 

analysis (expressed as a decimal fraction, e.g., 95% = 0.95). 

Fuel = Annual mass of all gaseous, liquid, and solid fuels used in process units 

(metric tons), as calculated in Equation Q-9 of this section. 

(v) The weighted average carbon content of all non-fuel inputs to all process units 

(combined) included in Equation Q-10 of this section, calculated as specified in Equation Q-13 

of this section. 

ܫܥ௔௩௚ ൌ ൫∑ ேிூ೔∗஼ಿಷ಺೔ ೙

೔సభ ൯

ேிூ 			 (Eq. Q-13) 

Where: 

CIavg = Weighted average carbon content of all non-fuel inputs to all process units 

included in Equation Q-10 of this section (weight fraction). 

n = Number of non-fuel inputs to all process units as used in Equation Q-10. 

NFIi = Annual mass of each non-fuel input used in Equation Q-10 (metric tons). 

CNFIi = Average carbon content of each non-fuel input used in Equation Q-10 

(expressed as a decimal fraction). 

NFI = Total of all non-fuel inputs to all process units (metric tons). 
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Page 89 of 100 

(vi) The weighted average carbon content of all solid and liquid products and byproducts 

from all process units (combined) included in Equation Q-11 of this section, calculated as 

specified in Equation Q-14 of this section. 

ܥܲ௔௩௚ ൌ ൫∑ ௉௥௢ௗ௨௖௧೔∗஼ು೔ ೙

೔సభ ൯

௉௥௢ௗ௨௖௧௦ (Eq. Q-14) 

Where: 

CPavg = Weighted average carbon content of all solid and liquid products and 

byproducts from all process units (weight fraction). 

n = Number of products and byproducts from each process unit as used in 

Equation Q-11. 

Producti = Annual mass of each product or byproduct used in Equation Q-11 (metric 

tons). 

Cp,i = Average carbon content of each product or byproduct used in Equation Q11 (expressed as a decimal fraction). 

Products = Mass of all products and byproducts from all process units, calculated in 

Equation Q-11 of this section (metric tons). 

* * * * * 

Subpart R—[AMENDED] 

17. Section 98.186 is amended by removing and reserving paragraphs (b)(6) and 

(b)(7); and revising paragraph (b)(8) to read as follows: 

§ 98.186 Data reporting procedures. 

* * * * * 

(b) * * * 

(8) List the method used for the determination of carbon content for each material used 

for the calculation of annual process CO2 emissions using Equation R–1 of this subpart for each 
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Page 90 of 100 

smelting furnace (e.g., supplier provided information, analyses of representative samples you 

collected). 

* * * * * 

Subpart S—[AMENDED] 

18. Section 98.196 is amended by: 

a. Revising paragraph (b) introductory text.;

b. Removing and reserving paragraphs (b)(2), (b)(3), (b)(5), (b)(6), (b)(8), (b)(10), 

(b)(11), and (b)(12).); and

c. Adding paragraph (b)(18). 

The revisions and additions read as follows: 

§ 98.196 Data reporting requirements. 

* * * * * 

(b) If a CEMS is not used to measure CO2 emissions, then you must report the 

information listed in paragraphs (b)(1) through (18) of this section. 

* * * * * 

(18) Annual quantity (metric tons) of lime product sold, by type. 

Subpart U—[AMENDED] 

19. Section 98.216 is amended by removing and reserving paragraphs (b), (e)(1), 

(e)(2), and (f). 

Subpart V—[AMENDED] 

20. Section 98.226 is amended by: 

a. Revising the introductory text.;

b. Removing and reserving paragraphs (d), (m)(1), and (m)(3).); and 
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c. Adding paragraph (q). 

The revisions and additions read as follows: 

§ 98.226 Data reporting requirements. 

In addition to the information required by § 98.3(c), each annual report must contain the 

information specified in paragraphs (a) through (q) of this section. 

* * * * * 

(q) Annual percent N2O emission reduction for all production units combined. 

Subpart X—[AMENDED] 

21. Section 98.246 is amended by: 

a. Revising paragraph (a) introductory text and paragraphs (a)(2) and (a)(4).);

b. Adding paragraphs (a)(12) and (13).);

c. Revising paragraph (b) introductory text.;

d. Removing and reserving paragraphs (b)(5)(iii) and (b)(5)(iv).); and

e. Adding paragraphs (b)(9) and (b)(10). 

The revisions and additions read as follows: 

§ 98.246 Data reporting requirements. 

* * * * * 

(a) If you use the mass balance methodology in § 98.243(c), you must report the 

information specified in paragraphs (a)(1) through (a)(13) of this section for each type of 

petrochemical produced, reported by process unit. 

* * * * * 

(2) The type of petrochemical produced, names of products, and names of carboncontaining feedstocks. 
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* * * * * 

(4) The temperature (in °F) at which the gaseous feedstock and product volumes used in 

Equation X–1 of this subpart were determined. 

* * * * * 

(12) Name and annual quantity (in metric tons) of each carbon-containing feedstock 

included in Equations X-1, X-2, and X-3 of § 98.243 of this subpart. 

(13) Name and annual quantity (in metric tons) of each product included in Equations X1, X-2, and X-3 of § 98.243 of this subpart. 

(b) If you measure emissions in accordance with § 98.243(b), then you must report the 

information listed in paragraphs (b)(1) through (b)(10) of this section. 

* * * * * 

(9) Name and annual quantity (in metric tons) of each carbon-containing feedstock. 

(10) Name and annual quantity (in metric tons) of each carbon-containing co-product. 

* * * * * 

Subpart Y—[AMENDED] 

22. Section 98.256 is amended by: 

a. Revising paragraphs (e)(6) and (e)(7) introductory text.;

b. Removing and reserving paragraph (e)(7)(ii).);

c. Revising paragraphs (e)(9) and (e)(10).);

d. Adding paragraph (e)(11).);

e. Revising paragraphs (f)(7) and (f)(10) through (13).);

f. Removing and reserving paragraph (h)(4).);

g. Revising paragraphs (h)(5), (i)(5), (i)(7), and (i)(8).);
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h. Removing and reserving paragraph (j)(2).);

i. Revising paragraphs (j)(5) through (9), (k)(3), (k)(4), (l)(5), and (m)(3).);

j. Removing and reserving paragraphs (o)(2)(ii), (o)(4)(ii) through (v), and (o)(6) and 

(7).); and 

k. Revising paragraph (p)(2). 

The revisions and additions read as follows: 

§ 98.256 Data reporting requirements. 

* * * * * 

(e) * * * 

(6) If you use Equation Y–1a of this subpart, an indication of whether daily or weekly 

measurement periods are used, the annual volume of flare gas combusted (in scf/year) and the 

annual average molecular weight (in kg/kg-mole), and annual average carbon content of the flare 

gas (in kg carbon per kg flare gas). 

(7) If you use Equation Y–1b of this subpart, an indication of whether daily or weekly 

measurement periods are used, the annual volume of flare gas combusted (in scf/year), the 

annual average CO2 concentration (volume or mole percent), the number of carbon containing 

compounds other than CO2 in the flare gas stream, and for each of the carbon containing 

compounds other than CO2 in the flare gas stream: 

* * * * * 

(9) If you use Equation Y–3 of this subpart, the number of SSM events exceeding 

500,000 scf/day. 

(10) The basis for the value of the fraction of carbon in the flare gas contributed by 

methane used in Equation Y–4 of this subpart. 
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(11) If using Equation Y-3, report: 

(i) Annual quantity of flare gas combusted (in MMscf per year). 

(ii) Annual average molecular weight of flare gas combusted (in mmBtu per MMscf). 

(iii) Annual average carbon content of flare gas combusted (expressed as a decimal 

fraction). 

(f) * * * 

(7) If you use Equation Y–6 of this subpart, the annual average exhaust gas flow rate, 

%CO2, and %CO. 

* * * * * 

(10) If you use Equation Y–8 of this subpart, the basis for the value of the coke burn-off 

factor, annual throughput of unit, and the average carbon content of coke. 

(11) Indicate whether you use a measured value, a unit-specific emission factor, or a 

default emission factor for CH4 emissions. If you use a unit-specific emission factor for CH4, 

report the basis for the factor. 

(12) Indicate whether you use a measured value, a unit-specific emission factor, or a 

default emission factor for N2O emissions. If you use a unit-specific emission factor for N2O, 

report the basis for the factor. 

(13) If you use Equation Y–11 of this subpart, the number of regeneration cycles or 

measurement periods during the reporting year and the average coke burn-off quantity per cycle 

or measurement period. 

* * * * * 

(h) * * * 
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(5) If you recycle tail gas to the front of the sulfur recovery plant, indicate whether the 

recycled flow rate and carbon content are included in the measured data under § 98.253(f)(2) and 

(3). Indicate whether a correction for CO2 emissions in the tail gas was used in Equation Y–12. If 

so, then report: 

(i) The value of the correction. 

(ii) If the following data are not used to calculate the recycling correction factor, report 

the information specified in paragraphs (h)(5)(ii)(A) through (C) of this section. 

(A) The annual volume of recycled tail gas (in scf/year) only. 

(B) The annual average mole fraction of carbon in the tail gas (in kg-mole C/kg-mole 

gas). 

(C) Indicate whether you used the default (95%) or a unit specific correction, and if used, 

report the approach used. 

* * * * * 

(i) * * * 

(5) If you use Equation Y–13 of this subpart, an indication of whether coke dust is 

recycled to the unit (e.g., all dust is recycled, a portion of the dust is recycled, or none of the dust 

is recycled). 

* * * * * 

(7) Indicate whether you use a measured value, a unit-specific emission factor or a 

default for CH4 emissions. If you use a unit-specific emission factor for CH4, report the basis for 

the factor. 
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(8) Indicate whether you use a measured value, a unit-specific emission factor, or a 

default emission factor for N2O emissions. If you use a unit-specific emission factor for N2O, 

report the basis for the factor. 

(j) * * * 

(5) If you use Equation Y–14 of this subpart, the basis for the CO2 emission factor used. 

(6) If you use Equation Y–15 of this subpart, the basis for the CH4 emission factor used. 

(7) If you use Equation Y–16 of this subpart, the basis for the carbon emission factor 

used. 

(8) If you use Equation Y–16b of this subpart, the basis for the CO2 emission factor used 

and the basis for the carbon emission factor used. 

(9) If you use Equation Y–17 of this subpart, the basis for the CH4 emission factor used. 

(k) * * * 

(3) The total number of delayed coking units at the facility; the total number of delayed 

coking drums at the facility; and, for each coke drum or vessel, the typical drum outage (i.e. the 

unfilled distance from the top of the drum, in feet). 

(4) For each set of coking drums that are the same dimensions, the number of coking 

drums in the set, and the mole fraction of methane in coking gas (in kg-mole CF4/kg-mole gas, 

wet basis). 

* * * * * 

(l) * * * 

(5) The annual volumetric flow discharged to the atmosphere (in scf), and an indication 

of the measurement or estimation method, annual average mole fraction of each GHG above the 

concentration threshold or otherwise required to be reported and an indication of the 
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Page 97 of 100 

measurement or estimation method, and for intermittent vents, the number of venting events and 

the cumulative venting time. 

(m) * * * 

(3) For uncontrolled blowdown systems reporting under § 98.253(k), the basis for the 

value of the methane emission factor used for uncontrolled blowdown systems. 

* * * * * 

(p) * * * 

(2) The types of materials loaded that have an equilibrium vapor-phase concentration of 

methane of 0.5 volume percent or greater, and the type of vessel (barge, tanker, marine vessel, 

etc.) in which each type of material is loaded. 

* * * * * 

Subpart Z—[AMENDED] 

23. Section 98.266 is amended by removing and reserving paragraphs (f)(5) and 

(f)(6). 

Subpart AA—[AMENDED] 

24. Section 98.276 is amended by: 

a. Revising the introductory paragraph.;

b. Removing and reserving paragraph (b).);

c. Revising paragraph (c).);

d. Removing and reserving paragraphs (d), (f), (g), (h) and (i).); and

e. Adding paragraphs (l) and (m). 

The revisions and additions read as follows: 

§ 98.276 Data reporting requirements. 
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Page 98 of 100 

In addition to the information required by § 98.3(c) and the applicable information 

required by § 98.36, each annual report must contain the information in paragraphs (a) through 

(m) of this section as applicable: 

* * * * * 

(c) Basis for determining the annual mass of the spent liquor solids combusted (whether 

based on T650 om-05 Solids Content of Black Liquor, TAPPI (incorporated by reference, see § 

98.7) or an online measurement system). 

* * * * * 

(l) For each pulp mill lime kiln, report the information specified in paragraphs (l)(1) and 

(2) of this section. 

(1) The quantity of calcium oxide (CaO) produced (metric tons). 

(2) The percent of annual heat input, individually for each fossil fuel type. 

(m) For each chemical recovery furnace and each chemical recovery combustion unit for 

which you are not using Equation C-2c to calculate CO2 emissions, report the information 

specified in paragraphs (m)(1) and (2) of this section. 

(1) The annual mass of steam generated (lb steam), individually for each fossil fuel type 

and for spent liquor solids. 

(2) The ratio of the unit’s maximum rated heat input capacity to its design rated steam 

output capacity (mmBtu/lb steam), individually for each fossil fuel type and for spent liquor 

solids. 

Subpart BB—[AMENDED] 

25. Section 98.286 is amended by removing and reserving paragraphs (b)(1), (b)(4), 

and (b)(6). 
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Subpart CC—[AMENDED] 

26. Section 98.296 is amended by removing and reserving paragraphs (b)(5) through 

(7). 

Subpart EE—[AMENDED] 

27. Section 98.316 is amended by removing and reserving paragraphs (b)(6) and 

(b)(9). 

Subpart GG—[AMENDED] 

28. Section 98.336 is amended by removing and reserving paragraphs (b)(6), (b)(7), 

and (b)(10). 

Subpart TT—[AMENDED] 

29. Section 98.466 is amended by: 

a. Removing and reserving paragraph (c)(3)(i).);

b. Revising paragraph (c)(3)(ii).); and

c. Removing and reserving paragraph (c)(3)(iii). 

The revisions read as follows: 

§ 98.466 Data reporting requirements. 

* * * * * 

(c) * * * 

(3) * * * 

(ii) The year of the data used in Equation TT-2 for the waste disposal quantity and 

production quantity, for each year used in Equation TT–2 of this subpart to calculate the average 

waste disposal factor (WDF). 

* * * * * 
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Attachment M 
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6560.50 

ENVIRONMENTAL PROTECTION AGENCY 

40 CFR Part 98 

[EPA-HQ-OAR-2010-0929; FRL- ] 

RIN 2060-AQ81 

Revisions to Reporting and Recordkeeping Requirements, and 

Proposed Confidentiality Determinations under the Greenhouse Gas 

Reporting Program 

EO12866_GHGRP Part 98 2060 AQ81 NPRM 20120326 

AGENCY: Environmental Protection Agency (EPA). 

ACTION: Proposed rule. 

SUMMARY: The EPA is proposing amendments to reporting and 

recordkeeping requirements and an alternative verification 

approach for the Greenhouse Gas Reporting Program. This action 

addresses concerns about the potential release of certain data 

that are inputs to emission equations to be reported March 31, 

2015 while maintaining the EPA’s ability to verify emissions and 

ensure compliance with the Greenhouse Gas Reporting Program. In 

addition, the EPA is proposing confidentiality determinations 

for the newly proposed data elements in this action. 

DATES: Comments. Comments must be received on or before [INSERT 

THE DATE 60 DAYS AFTER PUBLICATION OF THIS PROPOSED RULE IN THE 

FEDERAL REGISTER]. 

Public Hearing. The EPA will hold a public hearing on this 

proposed rule if requested. Requests for a hearing must be made 
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by [INSERT THE DATE 7 DAYS AFTER PUBLICATION OF THIS PROPOSED 

RULE IN THE FEDERAL REGISTER]. Contact the person listed in the 

“FOR FURTHER INFORMATION CONTACT” section by [INSERT THE DATE 7 

DAYS AFTER PUBLICATION OF THIS PROPOSED RULE IN THE FEDERAL 

REGISTER] to request a public hearing. If a hearing is 

requested, the EPA will announce the details, including specific 

dates, times, addresses and contact information for the hearing, 

in a separate Federal Register notice. 

ADDRESSES: Submit your comments, identified by Docket ID No. 

EPA–HQ–OAR–2010-0929, by one of the following methods: 

 Federal eRulemaking Portal: http:// www.regulations.gov. 

Follow the online instructions for submitting comments. 

 Email: GHGReportingCBI@epa.gov 

 Fax: (202) 566–1741. 

 Mail: Environmental Protection Agency, EPA Docket Center 

(EPA/DC), Mailcode 6102T, Attention Docket ID No. EPA–HQ–

OAR–2010-0929, 1200 Pennsylvania Avenue, NW., Washington, 

DC 20460. 

 Hand Delivery: EPA Docket Center, Public Reading Room, EPA 

West Building, Room 3334, 1301 Constitution Avenue, NW., 

Washington, DC 20004. Such deliveries are only accepted 

during the Docket’s normal hours of operation, and special 

arrangements should be made for deliveries of boxed 

information. 

Instructions: Direct your comments to Docket ID No. EPA–HQ–

OAR–2010-0929. The EPA’s policy is that all comments received 

will be included in the public docket without change and may be 

made available online at http://www.regulations.gov, including 

any personal information provided, unless the comment includes 
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information claimed to be confidential business information 

(CBI) or other information whose disclosure is restricted by 

statute. 

Do not submit information that you consider to be CBI or 

otherwise protected through http://www.regulations.gov or email. 

Send or deliver information identified as CBI to only the mail 

or hand/courier delivery address listed above, attention: Docket 

ID No. EPA–HQ–OAR–2010–0929. The http://www.regulations.gov

website is an “anonymous access” system, which means the EPA 

will not know your identity or contact information unless you 

provide it in the body of your comment. If you send an email 

comment directly to the EPA without going through 

http://www.regulations.gov your email address will be 

automatically captured and included as part of the comment that 

is placed in the public docket and made available on the 

Internet. If you submit an electronic comment, the EPA 

recommends that you include your name and other contact 

information in the body of your comment and with any disk or CD–

ROM you submit. If the EPA cannot read your comment due to 

technical difficulties and cannot contact you for clarification, 

the EPA may not be able to consider your comment. Electronic 

files should avoid the use of special characters, any form of 

encryption, and be free of any defects or viruses. 
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Docket: All documents in the docket are listed in the 

http://www.regulations.gov index. Although listed in the index, 

some information is not publicly available, e.g., CBI or other 

information whose disclosure is restricted by statute. Certain 

other material, such as copyrighted material, will be publicly 

available only in hard copy. Publicly available docket materials 

are available either electronically in 

http://www.regulations.gov or in hard copy at the Air Docket, 

EPA/DC, EPA West, Room B102, 1301 Constitution Ave., NW., 

Washington, DC. This Docket Facility is open from 8:30 a.m. to 

4:30 p.m., Monday through Friday, excluding legal holidays. The 

telephone number for the Public Reading Room is (202) 566–1744, 

and the telephone number for the Air Docket is (202) 566–1742. 

FOR FURTHER GENERAL INFORMATION CONTACT: Carole Cook, Climate 

Change Division, Office of Atmospheric Programs (MC–6207J), 

Environmental Protection Agency, 1200 Pennsylvania Ave., NW., 

Washington, DC 20460; telephone number: (202) 343–9263; fax 

number: (202) 343–2342; email address: GHGreporting@epa.gov. For 

technical information, contact the Greenhouse Gas Reporting Rule 

Helpline at: 

http://www.epa.gov/climatechange/emissions/ghgrule_contactus.htm

. Alternatively, contact Carole Cook at 202–343–9263. 

Worldwide Web (WWW). In addition to being available in the 

docket, an electronic copy of this proposal, memoranda to the 
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docket, and all other related information will also be available 

through the WWW on EPA’s greenhouse gas reporting rule Web site 

at 

http://www.epa.gov/climatechange/emissions/ghgrulemaking.html. 

SUPPLEMENTARY INFORMATION: 

Additional Information on Submitting Comments: To expedite 

review of your comments by Agency staff, you are encouraged to 

send a separate copy of your comments, in addition to the copy 

you submit to the official docket, to Carole Cook, Climate 

Change Division, Office of Atmospheric Programs (MC–6207J), 

Environmental Protection Agency, 1200 Pennsylvania Ave., NW., 

Washington, DC, 20460, telephone (202) 343–9263, email 

GHGReportingCBI@epa.gov. 

Regulated Entities. This proposed rule revision on 

reporting and recordkeeping requirements and verification 

procedures would affect entities that must submit annual 

greenhouse gas (GHG) reports under the Greenhouse Gas Reporting 

Program (40 CFR part 98). The Administrator has determined that 

40 CFR part 98 is subject to the provisions of Clean Air Act 

(CAA) section 307(d). See CAA section 307(d)(1)(V) (the 

provisions of CAA section 307(d) apply to “such other actions as 

the Administrator may determine”). Entities affected by this 

proposal are owners or operators of facilities that are direct 
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emitters of greenhouse gases (GHGs), which include those listed 

in Table 1 of this preamble: 

Table 1. Examples of Affected Entities by Category 

Category NAICS Examples of affected facilities 

General 

Stationary Fuel 

Combustion 

Sources 

 Facilities operating boilers, 

process heaters, incinerators, 

turbines, and internal combustion 

engines. 

321 Manufacturers of lumber and wood 

products. 

322 Pulp and paper mills.

325 Chemical manufacturers. 

324 Petroleum refineries and 

manufacturers of coal products. 

316, 326, 

339 

Manufacturers of rubber and 

miscellaneous plastic products. 

331 Steel works, blast furnaces. 

332 Electroplating, plating, polishing, 

anodizing, and coloring. 

336 Manufacturers of motor vehicle 

parts and accessories. 

221 Electric, gas, and sanitary 

services. 

622 Health services. 

611 Educational services. 

325193 Ethyl alcohol manufacturing 

facilities. 

311611 Meat processing facilities 

311411 Frozen fruit, juice, and vegetable 

manufacturing facilities. 

311421 Fruit and vegetable canning 

facilities. 

Electricity 

Generation 

221112 Fossil-fuel fired electric 

generating units, including units 

owned by Federal and municipal 

governments and units located in 

Indian Country. 

Adipic Acid 

Production 

325199 Adipic acid manufacturing 

facilities. 

Aluminum 

Production 

331312 Primary aluminum production 

facilities

Ammonia 

Manufacturing 

325311 Anhydrous and aqueous ammonia 

production facilities. 
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Category NAICS Examples of affected facilities 

Cement 

Production 

327310 Portland Cement manufacturing 

plants. 

Ferroalloy 

Production 

331112 Ferroalloys manufacturing 

facilities. 

Fluorinated GHG 

Production 

325120 Industrial gases manufacturing 

facilities. 

Glass Production 327211 Flat glass manufacturing 

facilities.

327213 Glass container manufacturing 

facilities. 

327212 Other pressed and blown glass and 

glassware manufacturing facilities. 

HCFC-22 

Production and 

HFC-23 

Destruction 

325120 Chlorodifluoromethane manufacturing 

facilities. 

Hydrogen 

Production 

325120 Hydrogen production facilities 

Iron and Steel 

Production 

331111 Integrated iron and steel mills, 

steel companies, sinter plants, 

blast furnaces, basic oxygen 

process furnace shops. 

Lead Production 331419 Primary lead smelting and refining 

facilities. 

331492 Secondary lead smelting and 

refining facilities. 

Lime Production 327410 Calcium oxide, calcium hydroxide, 

dolomitic hydrates manufacturing 

facilities. 

Magnesium 

Production 

331419 Primary lead smelting and refining 

facilities. 

331492 Secondary lead smelting and 

refining facilities. 

Manure 

Management 

112111 

112120 

112210 

112310 

112330 

112320 

Beef cattle feedlots. 

Dairy cattle and milk production 

facilities. 

Hog and pig farms. 

Chicken egg production facilities. 

Turkey Production. 

Broilers and other meat type 

chicken production. 

Municipal Solid 

Waste Landfills 

562212 

221320 

Solids Waste Landfills. 

Sewage treatment facilities. 

Nitric Acid 

Production 

325311 Nitric acid production facilities 
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Category NAICS Examples of affected facilities 

Petrochemical 

Production 

32511 Ethylene dichloride production 

facilities. 

325199 Acrylonitrile, ethylene oxide, 

methanol production facilities. 

325110 Ethylene production facilities.

325182 Carbon black production facilities. 

Petroleum and 

Natural Gas 

Systems 

486210 Pipeline transportation of natural 

gas. 

221210 Natural gas distribution 

facilities. 

211 Extractors of crude petroleum and 

natural gas. 

211112 Natural gas liquid extraction 

facilities. 

Petroleum 

Refineries 

324110 Petroleum refineries. 

Phosphoric Acid 

Production 

325312 Phosphoric acid manufacturing 

facilities. 

Pulp and Paper 

Manufacturing 

322110 Pulp mills. 

322121 Paper mills. 

322130 Paperboard mills. 

Silicon Carbide 

Production 

327910 Silicon carbide abrasives 

manufacturing facilities. 

Soda Ash 

Manufacturing 

325181 Alkalies and chlorine manufacturing 

facilities. 

212391 Soda ash, natural, mining and/or 

beneficiation. 

Titanium Dioxide 

Production 

325188 Titanium dioxide manufacturing 

facilities. 

Zinc Production 331419 Primary zinc refining facilities. 

331492 Zinc dust reclaiming facilities, 

recovering from scrap and/or 

alloying purchased metals. 

311411 Frozen fruit, juice and vegetable 

manufacturing facilities. 

311421 Fruit and vegetable canning 

facilities. 

Wastewater 

Treatment 

322110 Pulp mills.

322121 Paper mills. 

322122 Newsprint mills. 

322130 Paperboard mills. 

311611 Meat processing facilities. 

311411 Frozen fruit, juice and vegetable 

manufacturing facilities. 
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Category NAICS Examples of affected facilities 

311421 Fruit and vegetable canning 

facilities. 

325193 Ethanol manufacturing facilities. 

Table 1 of this preamble is not intended to be exhaustive, 

but rather provides a guide for readers regarding facilities and 

suppliers likely to be affected by this action. Types of 

facilities other than those listed in this table may also be 

affected by this action. To determine whether you are affected 

by this action, you should carefully examine the applicability 

criteria found in 40 CFR part 98, subpart A or the relevant 

criteria in the subparts. If you have questions regarding the 

applicability of this action to a particular facility or 

supplier, consult the person listed in the preceding FOR FURTHER 

GENERAL INFORMATION CONTACT section. 

Many facilities that are affected by 40 CFR part 98 have 

GHG emissions from multiple source categories listed in Table 1 

of this preamble. 

Acronyms and Abbreviations. The following acronyms and 

abbreviations are used in this document. 

BAMM Best Available Monitoring Methods 

CAA Clean Air Act 

CO2 carbon dioxide 

CBI confidential business information 

CEMS Continuous Emission Monitoring System 

CFR Code of Federal Regulations 

e-GGRT Electronic Greenhouse Gas Reporting Tool 
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EIA Energy Information Administration 

EPA U.S. Environmental Protection Agency 

FR Federal Register 

GHG greenhouse gas 

GHGRP Greenhouse Gas Reporting Program 

HCFC-22 chlorodifluoromethane 

HFC hydrofluorocarbons 

HQ Headquarters 

ICR Information Collection Request 

MW megawatt 

NAICS North American Industry Classification System 

NTTAA National Technology Transfer and Advancement Act 

OMB Office of Management & Budget 

RFA Regulatory Flexibility Act 

UMRA Unfunded Mandates Reform Act 

U.S. United States 

WWW Worldwide Web 

TABLE OF CONTENTS 

I. Executive Summary and Background

A. Executive Summary

B. Background

C. Subparts Covered in this Proposed Rule

D. Legal Authority

II. Summary of Proposed Changes to Part 98 Reporting and 

Recordkeeping Requirements

A. Proposed Use of Inputs Verification Tool

B. Proposed Revisions to Reporting of Data Elements Deferred 

until 2015

C. Proposed Changes to Recordkeeping Requirements

D. Proposed New Data Elements to be Reported

III. Rationale for Proposed Changes to Reporting and 

Recordkeeping Requirements

A. Proposed Inputs Verification Tool and Amendment to Reporting 

Requirements

B. Proposed Revisions to Recordkeeping Requirements

C. Proposed Requirement to Report Additional Data
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IV. Confidentiality Determination for Proposed New Data Elements 

to be Reported

V. Impacts of the Proposed Rule

A. How were the costs of this proposed rule estimated?

B. Additional Impacts of the Proposed Amendments

VI. Statutory and Executive Order Reviews

A. Executive Order 12866: Regulatory Planning and Review and 

Executive Order 13563: Improving Regulation and Regulatory 

Review

B. Paperwork Reduction Act

C. Regulatory Flexibility Act (RFA)

D. Unfunded Mandates Reform Act (UMRA)

E. Executive Order 13132: Federalism

F. Executive Order 13175: Consultation and Coordination with 

Indian Tribal Governments.

G. Executive Order 13045: Protection of Children from 

Environmental Health Risks and Safety Risks

H. Executive Order 13211: Actions that Significantly Affect 

Energy Supply, Distribution, or Use

I. National Technology Transfer and Advancement Act

J. Executive Order 12898: Federal Actions to Address 

Environmental Justice in Minority Populations and Low-Income 

Populations

I. Executive Summary and Background 

A. Executive Summary 

The Greenhouse Gas Reporting Program (GHGRP) collects 

greenhouse gas data from 41 source categories and currently has 

two to three years of data from these sources. Greenhouse gas 

emissions from direct emitters are calculated using a variety of 

methods, including direct measurement, mass balance, and the use 

of emission factors. Reporters not using direct measurement must 

use equations to calculate emissions. The inputs to these 

emission equations often include process or production data that 

are specific to each facility’s operations. These “inputs to 
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emission equations” play an important role in the Agency’s 

ability to verify facility-level emissions and ensure compliance 

with the program. 

On July 7, 2010, the EPA proposed confidentiality 

determinations for the majority of data elements required to be 

reported under the GHGRP, as well as for the majority of source 

categories covered by the program. In the July 7, 2010 action, 

the EPA proposed that data elements categorized as “inputs to 

emission equations” are emission data. The CAA precludes 

“emission data” from being treated as confidential. 

Based on subsequent industry concerns regarding the 

potential release of data elements categorized as “inputs to 

emission equations,” the EPA deferred reporting of these data 

elements (see August 25, 2011 final action, 76 FR 53057) to 

allow the EPA to complete its evaluation of the potential impact 

from the public release of these data elements (see 76 FR 53060) 

and, if appropriate, to propose amendments to Part 98 (see 75 FR 

81355). Based on the analysis conducted, today’s action proposes 

amendments to reporting and recordkeeping requirements and an 

alternative verification approach for reporters subject to 24 

subparts with inputs to emission equations for which the 

reporting deadline was deferred until 2015 and disclosure 

concerns have been identified. Proposed amendments include: 

Comment [A1]: Has EPA finalized 

this? If not, are there plans to 

finalize it? 
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 Adding a requirement for reporters under certain subparts 

to use an EPA-provided inputs verification tool. The 

designated inputs to emission equations for these subparts 

would be entered into the tool. The tool would calculate 

the emissions and perform electronic verification. The tool 

would not retain the entered inputs (i.e., the inputs would 

not be reported to EPA); instead, it would conduct certain 

checks (e.g., accuracy of the inputs) at the time of data 

entry and generate a verification summary. The verification 

summary, which would be accessible to the EPA once the 

annual report is submitted, would provide the EPA with 

information to conduct further verification if necessary. 

 For reporters required to use the inputs verification tool, 

changing the format for maintaining records of these inputs 

to emission equations. 

 For reporters required to use the inputs verification tool, 

lengthening the record retention period from 3 to 5 years 

for all records maintained under Part 98 (including 

subparts that do not require the use of the tool). 

 For certain subparts that require the use of the inputs 

verification tool, adding new data elements to be reported 

for the EPA’s verification purposes, and proposing 

confidentiality determinations for the new data elements 

proposed to be reported. 

 For reporters required to use the inputs verification tool, 

removing the requirement to report the inputs to emission 

equations for which reporting was deferred to 2015 and 

disclosure concerns have been identified, and requiring 

them to be kept as records. 

 Reporting requirements for inputs to equations for which 

disclosure concerns were not identified (and would still be 

useful to EPA) are not proposed to be amended in this action. 

For these inputs to equations, the deferral would expire in 

March 2015, and EPA would collect these data. 

The proposed changes in this action build on the EPA’s 

experience and success with electronic reporting and 

verification during the first 3 years of the GHGRP. By requiring 

Comment [A2]: Please confirm: It 

is not an option for these 

reporters to use direct measurement 

instead of the inputs verification 

tool. 
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the use of the inputs verification tool, which would calculate 

GHG emissions based on the inputs to the emissions equations, 

the EPA would have the ability to identify facilities that 

potentially reported emissions incorrectly. This, combined with 

additional verification checks of the inputs to emission 

equations that the inputs verification tool would conduct 

(during the process of reporters entering data into the inputs 

verification tool), would provide the EPA with information 

necessary to conduct further verification once the annual report 

is submitted. This alternative verification approach, including 

the changes to the recordkeeping requirements and additional 

reporting requirements, would provide an alternative to 

collecting certain data elements for which reporting was 

deferred to March 31, 2015 and disclosure concerns have been 

identified while maintaining the EPA’s ability to verify data 

and ensure compliance with the GHGRP. 

B. Background

On October 30, 2009, the EPA published the Greenhouse Gas 

Reporting Rule, 40 CFR part 98, requiring annual reporting of 

GHG data from a broad range of industry sectors (74 FR 56260). 

Under the Greenhouse Gas Reporting Rule and its subsequent 

amendments (hereinafter referred to as “Part 98”), the EPA 

requires annual reporting of data from certain facilities and 

suppliers above specified emission or quantity supplied 
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thresholds. On July 7, 2010 (75 FR 39094) and subsequent 

proposals (77 FR 1434, 77 FR 10434), we proposed confidentiality 

determinations for the data elements required to be reported. 

The confidentiality of each reported data element was determined 

using a two-step approach: (1) grouping data elements into 11 

data categories (e.g., inputs to emission equations, emissions, 

and unit/process operating characteristics that are not inputs 

to emission equations for direct emitter source categories); and 

(2) making confidentiality determinations either categorically 

or on an individual data elements basis. Refer to both the July 

7, 2010 proposal (75 FR 39097 and 104) and the May 26, 2011 

final rule (76 FR 30785 - 30786) for more detailed descriptions 

of this process. Refer to the May 26, 2011 final rule also for a 

discussion of individual data element confidentiality 

determinations. We have finalized confidentiality determinations 

for data elements except those in the “inputs to emission 

equations” category (May 26, 2011, 76 FR 30782; August 13, 2012, 

77 FR 48072; and August 24, 2012, 77 FR 51477)1

. For data 

elements in this category, we proposed that they meet the 

definition of “emission data” under 40 CFR 2.301(a)(2)(i). 

Because emission data are not entitled to confidential treatment 

 

1

 There are a small number of data elements (besides data elements categorized as 

“inputs to emission equations”) for which we have not made a final confidentiality 

determinations because we concluded that a determination of confidentiality for the 

data element should be made on a case-by-case facility basis (according to individual 

circumstances of the facility). 
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under section 114(c) of the Clean Air Act, we did not evaluate 

whether such data elements would qualify as CBI, including 

whether disclosure would likely cause substantial competitive 

harm to the reporting facilities. (75 FR 39105 and 39108, July 

7, 2010). 

Following our proposal that data elements assigned to the 

“inputs to emission equations” category are not entitled to 

confidential treatment, we received numerous industry comments 

asserting that competitive harm would result from public release 

of many of these data elements. We determined that “these 

concerns warranted an in-depth evaluation of the potential 

impact from the release of inputs to emission equations.” (76 FR 

53060; August 25, 2011). In a notice dated December 27, 2010, we 

issued a call for information (75 FR 81354) requesting 

additional information to assist us in conducting our 

evaluation. To allow sufficient time to complete this evaluation 

through notice and comment, we deferred the reporting deadline 

for data elements assigned to the “inputs to emission equation” 

category. Reporting of certain of these data elements was 

deferred to March 31, 2013, as specified in Table A-6 of subpart 

A; and reporting of the remainder of these data elements was 

deferred to March 31, 2015, as specified in Table A-7 of subpart 

A (see the August 25, 2011 final rule, 76 FR 53077). 
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Our process for evaluating competitive harm was documented 

in the final deferral notice (August 25, 2011, 76 FR 53057) and 

the accompanying memorandum entitled “Process for Evaluating and 

Potentially Amending Part 98 Inputs to Emission Equations” 

(Docket ID EPA-HQ-OAR-2010-0929). As discussed in the final 

deferral notice and memorandum, our evaluation involved a fourstep process, as follows: 

 Step 1: Determine whether each data element assigned to the 

“inputs to emission equations” category is already publicly 

available. 

 Step 2: For data elements assigned to the “inputs to 

emission equations” category that are not publicly 

available, evaluate whether disclosure of the information 

is likely to result in substantial competitive harm. 

 Step 3: For data elements assigned to the “inputs to 

emission equations” category that are likely to cause 

substantial competitive harm if disclosed, evaluate 

potential alternative calculation methods. 

 Step 4: For data elements assigned to the “inputs to 

emission equations” category that are likely to cause 

substantial competitive harm if disclosed, evaluate 

potential alternative verification methods. 

Based on each step of the four-step evaluation process, an 

analysis of all data elements for which reporting is deferred to 

March 31, 2015 was conducted.2 The results of the analysis are 

documented in four memoranda, as follows: 

 

2

 We also evaluated all data elements for which reporting is deferred to March 

31, 2013 (Part 98 Table A-6) based on the same four-step process and 

determined that no further action was necessary. For a discussion of this 

evaluation, refer to the EPA's memorandum "Summary of Evaluation of 

Greenhouse Gas Reporting Program (GHGRP) Part 98 “Inputs to Emission 

Equations” Data Elements Deferred Until 2013" (December 17, 2012), 

available at 

Comment [A3]: We suggest adding 

further explanation in this 

footnote of what “no further action 

was necessary” and suggest stating 

the reporting result for the 

deferred reporting elements. 
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 “Summary of Public Availability of Inputs to Emission 

Equations for Which Reporting was Deferred Until March 31, 

2015.” 

 “Evaluation of Competitive Harm From Reporting 2015 Inputs 

to Equations.” 

 “Summary of Alternative Calculation Methods.” 

 “Summary of Alternative Verification Methods.” 

These memoranda are available in EPA docket ID No. EPA–HQ–

OAR–2010-0929. Based on the results of these analyses, the EPA 

is proposing in today’s action to make certain amendments to 

Part 98. 

C. Subparts Covered in this Proposed Rule

The proposed amendments affect all subparts listed in Table 

2 of this preamble. Table 2 includes most of the subparts with 

inputs to emission equations for which the reporting deadline 

was deferred until 2015. Subpart W (Petroleum and Natural Gas 

Systems), Subpart II (Industrial Wastewater Treatment), and 

subpart C (only certain combustion units associated with devices 

connected and able to deliver power to the local or regional 

electric power grid, as specified in Table 2) are not included 

in Table 2 because none of the inputs to emission equations 

required to be reported by reporters in these source categories 

are being amended, as no disclosure concerns were identified. 

Subpart I of part 98 is not included in Table 2 because 

 

http://www.epa.gov/ghgreporting/documents/pdf/2012/documents/2013-inputsmemo.pdf. 
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reporting of inputs to emission equations under this subpart 

were addressed under a separate rulemaking proposed on October 

16, 2012 (77 FR 63538). Additionally, parts of this proposed 

rule certain proposed amendmentswould affect subparts not listed 

in Table 2. Specifically, as follows: for reporters subject to 

both a subpart listed in Table 2 and a subpart of Part 98 not 

listed in this table, the proposed revision to the recordkeeping 

duration would apply to the records required for all Part 98 

subparts (to which the reporter is subject). Refer to Sections 

II.C and III.B of this preamble for further discussion of this 

proposed amendment. 

Table 2. Subparts Affected by the Proposed Amendments.1

Subpart 

C—General Stationary Fuel 

Combustion except Certain 

Combustion Units Connected to 

Devices that are Connected to the 

Local or Regional Electric Power 

Grid2

S—Lime Manufacturing 

E—Adipic Acid Production U—Miscellaneous Uses of 

Carbonate 

F—Aluminum Production V—Nitric Acid Production 

G—Ammonia Manufacturing X—Petrochemical Production 

H—Cement Production Y—Petroleum Refineries 

K—Ferroalloy Production Z—Phosphoric Acid Production 

L—Fluorinated Gas Production AA—Pulp and Paper 

Manufacturing 

N—Glass Production BB—Silicon Carbide Production 

O—HCFC–22 Production and HFC–23 

Destruction 

CC—Soda Ash Manufacturing 

P—Hydrogen Production EE—Titanium Dioxide 

Production 

Q—Iron and Steel Production GG—Zinc Production 

Comment [A4]: Please consider 

whether there is a more 

straightforward way of making this 

statement. Edits provided for 

consideration. 

Also review footnote 1 to the table 

for consistency with any changes 

here. 
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R—Lead Production TT—Industrial Waste Landfills 

1

 Certain proposed amendments affect other subparts not listed in this table 

as follows: for reporters subject to both a subpart listed in this table and 

a subpart of Part 98 not listed in this table, the proposed revision to the 

recordkeeping duration would apply to the records required for all Part 98 

subparts to which the reporter is subject. 

2 The combustion units not affected by the proposed amendments include those 

meeting the following criteria: (1) the combustion unit is connected to a 

device that has been granted access by the Public Utilities Commission to 

deliver power to the local or regional electric power grid (e.g., electricity 

generators excluding generators connected to combustion units subject to 

subpart D of this part); and (2) the combined nameplate capacity (for all 

such devices at the facility excluding generators connected to combustion 

units subject to subpart D of this part)) is greater than or equal to 1 

megawatt electric. Refer to Section III.A.3 of this preamble for a discussion 

of the EPA’s rationale for proposing that combustion units meeting these 

criteria not be affected by the proposed amendments. 

D. Legal Authority

The EPA is proposing these rule amendments under its 

existing CAA authority provided in CAA section 114. As stated in 

the preamble to the 2009 final GHG reporting rule (74 FR 56260, 

October 30, 2009), CAA section 114(a)(1) provides the EPA broad 

authority to require the information proposed to be gathered by 

this rule because such data would inform and are relevant to the 

EPA’s carrying out a wide variety of CAA provisions. See the 

preambles to the proposed (74 FR 16448, April 10, 2009) and 

final Part 98 (74 FR 56260) for further information. 

In addition, pursuant to sections 114, 301, and 307 of the 

CAA, the EPA is proposing confidentiality determinations for the 

new data elements proposed in this notice. Section 114(c) of the 

CAA requires that the EPA make publicly available information 

obtained under CAA section 114 except for information (excluding 

emission data) that qualifies for confidential treatment. The 
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Page 21 of 125 

Administrator has determined that this action (Part 98 amendment 

and confidentiality determinations) is subject to the provisions 

of CAA section 307(d). 

II. Summary of Proposed Changes to Part 98 Reporting and 

Recordkeeping Requirements 

The EPA is proposing revisions to the reporting and 

recordkeeping requirements in Part 98 and alternative 

verification procedures that would apply to reporters subject to 

any of the 24 subparts listed in Table 2 of this preamble. 

Section II.A of this preamble summarizes a proposed new 

requirement for these reporters to use an EPA-provided 

electronic inputs verification tool to calculate emissions using 

data elements for which reporting was deferred to March 31, 2015 

(hereafter referred to as “inputs to equations” data elements), 

allowing the EPA to complete electronic verification of reported 

GHG emissions data without the need to collect “inputs to 

equations” data elements for which disclosure concerns have been 

identified. Section II.B of this preamble summarizes the EPA’s 

proposal to remove, for these reporters, the requirement to 

report many “inputs to equations” data elements. Section II.C of 

this preamble summarizes proposed revisions to the recordkeeping 

requirements for these reporters. Section II.D of this preamble 

summarizes proposed new reporting requirements for these 

reporters. Section III of this preamble explains the rationale 
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for the proposed amendments summarized in Sections II.A through 

II.D. Section IV of this preamble presents the EPA’s proposed 

confidentiality determinations for proposed new data elements 

and the EPA’s rationale for these determinations. Section V of 

this preamble presents the cost and impacts associated with 

these proposed amendments. 

A. Proposed Use of Inputs Verification Tool 

The EPA is proposing that facilities subject to the 

subparts listed in Table 2 of this preamble use an electronic 

inputs verification tool being developed by the EPA, which would 

calculate and verify GHG emissions. The inputs verification tool 

would be deployed within the EPA’s Electronic Greenhouse Gas 

Reporting Tool (e-GGRT) and would be integrated without 

interrupting the current electronic reporting process. Reporters 

would enter the “inputs to equations” data elements that the EPA 

is proposing to remove from the reporting requirements into eGGRT along with the data required to be reported in the annual 

report. The tool would use the entered “inputs to equations” 

data elements to calculate the equation outputs, conduct 

electronic verification checks on the “inputs to equations” data 

elements, and generate a verification summary. The tool would 

not retain the entered “inputs to equations” data elements for 

which the EPA is proposing that the reporting requirement be 

removed. Accordingly, the EPA would not have access to these 

Comment [A5]: EPA may want to 

consider noting here that there is 

a prototype available during the 

comment period. The phrase “being 

developed” makes it seem like the 

tool is not yet available in any 

form. 
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“inputs to equations” data elements. Instead, the EPA would rely 

on the verification summary, which would become accessible to 

the EPA when annual reports are submitted, as a first step for 

conducting verification once the annual report is submitted. 

Sources subject to multiple subparts under Part 98 would be 

required to use the inputs verification tool for only those 

subparts listed in Table 2 of this preamble. The EPA is 

proposing that reporters use this tool starting with reporting 

year 2014. Refer to Section III.A of this preamble for further 

discussion of this proposed requirement. 

B. Proposed Revisions to Reporting of Data Elements Deferred 

until 2015

The EPA is proposing to remove the reporting requirement 

for 435 “inputs to equations” data elements in the subparts 

listed in Table 2 of this preamble. Table 3 of this preamble 

provides a summary of how many data elements would be removed 

from reporting per subpart. Refer to Table 1 in the memorandum 

“List of ‘Inputs to Equations’ Data Elements Proposed Not To Be 

Reported” (refer to Docket ID No. EPA–HQ–OAR–2010-0929) for a 

complete list of these 435 data elements. For all remaining 

“inputs to equations” data elements not represented in Table 3 

of this preamble and Table 1 of the memorandum cited above, the 

EPA is not amending these reporting requirements and would, 

therefore, let the deferral of these data elements expire on 
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March 31, 2015. As a result, by March 31, 2015, all of the 

“inputs to equations” data elements for subpart W (Petroleum and 

Natural Gas Systems), Subpart II (Industrial Wastewater 

Treatment), and the additional “inputs to equations” data 

elements for which reporting is not proposed to be removed as 

indicated in Table 3 of this preamble, would be reported for 

future reporting years and for all reporting years prior to, and 

including, reporting year 2014. 

Table 3. Subparts For Which Reporting Requirements are Amended 

Subpart

Number of “Inputs to 

Equations” Data 

Elements 

Number of “Inputs 

to Equations” Data 

Elements Proposed 

Not to Be Reported 

C—General Stationary 

Fuel Combustion 

Except Certain 

Combustion Units 

Connected to Devices 

Connected to the 

Local or Regional 

Power Grid2

261

 261

E—Adipic Acid 

Production 

21 11 

F—Aluminum Production 29 29 

G—Ammonia 

Manufacturing 

8 8 

H—Cement Production 16 14 

K—Ferroalloy 

Production 

13 13 

L—Fluorinated Gas 

Production 

55 46 

N—Glass Production 3 3 

O—HCFC–22 Production 

and HFC–23 

Destruction 

15 12 
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Subpart

Number of “Inputs to 

Equations” Data 

Elements 

Number of “Inputs 

to Equations” Data 

Elements Proposed 

Not to Be Reported 

P—Hydrogen Production 7 7 

Q—Iron and Steel 

Production 

93 92 

R—Lead Production 10 10 

S—Lime Manufacturing 9 9 

U—Miscellaneous Uses 

of Carbonate 

6 6 

V—Nitric Acid 

Production 

21 6 

X—Petrochemical 

Production 

21 21 

Y—Petroleum 

Refineries 

80 70 

Z—Phosphoric Acid 

Production 

4 4 

AA—Pulp and Paper 

Manufacturing 

31 28 

BB—Silicon Carbide 

Production 

3 3 

CC—Soda Ash 

Manufacturing 

10 4 

EE—Titanium Dioxide 

Production 

2 2 

GG—Zinc Production 8 8 

TT—Industrial Waste 

Landfills 

3 3 

1 Includes one “inputs to equations” data element, 40 CFR 98.3(d)(3)(v), which 

is specified in subpart A of part 98 and applies to only certain reporters 

under subpart C of part 98. 

2

 The reporting requirements applicable to certain combustion units subject to 

subpart C remain the same under the proposed amendment. Subpart C would 

continue to require reporting of all applicable “inputs to equations” data 

elements for combustion units that meet the following criteria: (1) the 

combustion unit is connected to a device that has been granted access by the 

Public Utilities Commission to deliver power to the local or regional 

electric power grid (e.g., electricity generators excluding generators 

connected to combustion units subject to subpart D of this part); and (2) the 

combined nameplate capacity (for all such devices at the facility excluding 

generators connected to combustion units subject to subpart D of this part)) 

is greater than or equal to 1 megawatt electric. Subpart C reporters would 

not report “inputs to equations” data elements for all other types of 

combustion units subject to subpart C. 
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In order to ease the burden for facilities, the EPA is 

proposing that the “inputs to equations” data elements that 

would be reported for reporting years prior to reporting year 

2014 (as described above) be reported as part of the annual 

report for reporting year 2014. This would prevent facilities 

from being required to revise, re-certify, and re-submit annual 

reports for each previous reporting year. 

C. Proposed Changes to Recordkeeping Requirements

For each facility subject to a subpart listed in Table 2 of 

this preamble, the EPA is proposing that the facility retain all 

records, including records for subparts not subject to the 

inputs verification tool requirement, for 5 years, rather than 

the current 3-year record retention period. In other words, if 

any facility subject to a subpart listed in Table 2 is also 

subject to a subpart of Part 98 not listed in Table 2, we 

propose that records required for those other subparts also be 

maintained for the 5 years. For example, if a facility is 

required to report under both subpart C (in Table 2) and subpart 

HH (not in Table 2), the facility would be required to maintain 

all records required under both subparts for 5 years following 

submittal of the annual report. The EPA is proposing that this 

5-year record retention requirement begin with records for 

reporting year 2010. 

Comment [A6]: This is confusing, 

please clarify EPA’s intent by 

specifying more precisely what 

would be required from reporters. 

Is EPA requiring (a) the annual 

report for reporting year 2014; and 

(b) “inputs to equations data” from 

2013 (and prior years), and that 

this information would be included 

as a part of the annual report for 

reporting year 2014? Would the 

information requested in item (b) 

be provided through the inputs 

verification tool, or in a 

different format? (p.48 has 

similar text; revise consistently) 
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Additionally, we are proposing that, at the time a reporter 

subject to any subpart listed in Table 2 of this preamble 

completes entry of all “inputs to equations” data elements into 

the inputs verification tool, the reporter would be required to 

keep a file generated by the tool that lists the entered “inputs 

to equations” data elements. The reporter would be required to 

maintain a copy of the file as a record of the entered inputs. 

As currently required in 40 CFR 98.3(g), subpart A, this file 

may be maintained in electronic or hard copy format. 

Refer to Section III.B of this preamble for further 

discussion of these proposed recordkeeping requirements. 

D. Proposed New Data Elements to be Reported 

The EPA is proposing that reporters subject to subparts E, 

G, H, P, Q, S, V, X, Y, and AA of Part 98 be required to report 

the additional data elements listed per subpart in Table 4 of 

this preamble. Proposed confidentiality determinations for these 

proposed data elements are presented in Section IV of this 

preamble. 

Table 4. Proposed New Data Elements for Subparts E, G, H, P, Q, 

S, V, X, Y, and AA of Part 98 

Subpart Subpart Name New Data Element Description 

E Adipic Acid 

Production 

Annual quantity of cyclohexane fed 

to all production lines (metric 

tons). 

Annual percent N2O emission 

reduction for all production units 

combined. 

G Ammonia Annual ammonia production (metric 

Comment [A7]: Add the 5-year record 

retention requirement here, for 

clarity. 
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Subpart Subpart Name New Data Element Description 

Production tons). 

Annual methanol production (metric 

tons), if this quantity is not 

reported under subpart X of Part 98. 

H Cement Production Annual clinker production (metric 

tons). 

Annual average clinker CO2 emission 

factor for the facility, averaged 

across all kilns (metric tons 

CO2/metric ton clinker produced). 

Annual average cement kiln dust 

(CKD) CO2 emission factor for the 

facility, averaged across all kilns 

(metric tons CO2/metric ton CKD 

produced). 

P Hydrogen 

Production 

Name and annual quantity (metric 

tons) of each carbon-containing fuel 

and feedstock. 

Annual methanol production (metric 

tons), if this quantity is not 

reported under subpart X of Part 98. 

Q Iron and Steel 

Production 

If you use the carbon mass balance 

method in 40 CFR 98.173(b)(1) to 

determine CO2 emissions: The annual 

mass (metric tons) of all gaseous, 

liquid, and solid fuels (combined) 

used in process units specified in 

Equations Q-1 through Q-7 of Part 

98, calculated as specified in a 

proposed new Equation Q-9 in the 

proposed rule amendments. Do not 

include fuel used in a stationary 

combustion unit where emissions are 

reported under subpart C of this 

part. 

If you use the carbon mass balance 

method in 40 CFR 98.173(b)(1) to 

determine CO2 emissions: The annual 

mass (metric tons) of all non-fuel 

material inputs (combined) specified 

in Equations Q-1 through Q-7 of Part 

98, calculated as specified in a 

proposed new Equation Q-10 in the 

proposed rule amendments. 
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Subpart Subpart Name New Data Element Description 

If you use the carbon mass balance 

method in 40 CFR 98.173(b)(1) to 

determine CO2 emissions: The annual 

mass (metric tons) of all solid and 

liquid products and byproducts 

(combined) specified in Equations Q1 through Q-7 of Part 98, calculated 

as specified in a proposed new 

Equation Q-11 in the proposed rule 

amendments. 

If you use the carbon mass balance 

method in 40 CFR 98.173(b)(1) to 

determine CO2 emissions: The 

weighted average carbon content of 

all gaseous, liquid, and solid fuels 

(combined) included in proposed new 

Equation Q-9, calculated as 

specified in a proposed new Equation 

Q-12 in the proposed rule 

amendments. 

If you use the carbon mass balance 

method in 40 CFR 98.173(b)(1) to 

determine CO2 emissions: The 

weighted average carbon content of 

all non-fuel inputs to all furnaces 

(combined) included in proposed new 

Equation Q-10, calculated as 

specified in a proposed new Equation 

Q-13 in the proposed rule 

amendments. 

If you use the carbon mass balance 

method in 40 CFR 98.173(b)(1) to 

determine CO2 emissions: The 

weighted average carbon content of 

all solid and liquid products and 

byproducts from all furnaces 

(combined) included in a proposed 

new Equation Q-11 in the proposed 

rule amendments, calculated as 

specified in new Equation Q-14. 

S Lime 

Manufacturing 

Annual quantity (metric tons) of 

lime product sold, by type. 

V Nitric Acid 

Production 

Annual percent N2O emission 

reduction for all production units 

combined.
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Subpart Subpart Name New Data Element Description 

X Petrochemical 

Production 

If using the mass balance method or 

CEMS method to calculate GHG 

emissions: Name and annual quantity 

(in metric tons) of each carboncontaining feedstock included in 

Equations X-1, X-2 and X-3. 

If using the mass balance method or 

CEMS method to calculate GHG 

emissions: Name and annual quantity 

(in metric tons) of each carboncontaining co-product included in 

Equations X-1, X-2 and X-3. 

Y Petroleum 

Refineries 

Annual quantity of flare gas 

combusted (in MMscf per year) (only 

when using Equation Y-3). 

Annual average molecular weight of 

flare gas combusted (in mmBtu per 

MMscf) (only when using Equation Y3). 

Annual average carbon content of 

flare gas combusted (expressed as a 

decimal fraction)(only when using 

Equation Y-3). 

AA Pulp and Paper 

Manufacturing 

For each pulp mill lime kiln: 

Quantity of calcium oxide (CaO) 

produced (metric tons). 

For each pulp mill lime kiln: 

Percent of annual heat input, 

individually for each fossil fuel 

type. 

For each chemical recovery furnace 

and chemical recovery combustion 

unit for which you are not using 

Equation C-2c to calculate CO2

emissions: Annual mass of steam 

generated (lb steam), individually 

for each fossil fuel type and for 

spent liquor solids. 

For each chemical recovery furnace 

and chemical recovery combustion 

unit for which you are not using 

Equation C-2c to calculate CO2

emissions: Ratio of the unit’s 

maximum rated heat input capacity to 

its design rated steam output 
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Subpart Subpart Name New Data Element Description 

capacity (mmBtu/lb steam), 

individually for each fossil fuel 

type and for spent liquor solids.

III. Rationale for Proposed Changes to Reporting and 

Recordkeeping Requirements 

Based on the four-step evaluation described in Section I.B 

of this preamble, in particular the disclosure concerns 

discussed in “Step 2” of the evaluation and the alternatives 

considered in “Step 3” and “Step 4” of the evaluation to address 

those disclosure concerns, the EPA is proposing an alternative 

verification approach. This approach involves use of an inputs 

verification tool and revisions to the reporting and 

recordkeeping requirements of Part 98. The EPA’s rationale for 

this approach is presented in Sections III.A through C below. 

Section III.A addresses the proposed inputs verification tool 

and revisions to the requirement to report certain “inputs to 

equations” data elements. Section III.B addresses the proposed 

revisions to recordkeeping requirements. Section III.C addresses 

the proposed addition of new reporting requirements. 

A. Proposed Inputs Verification Tool and Amendment to Reporting 

Requirements

The EPA is proposing that facilities subject to the 

subparts listed in Table 2 of this preamble use an EPA-provided 

electronic inputs verification tool, which would calculate and 
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verify GHG emissions. The inputs verification tool would be 

deployed within e-GGRT and integrated without interrupting the 

current electronic reporting process. Reporters would enter 

their “inputs to equations” data elements into the tool within 

the e-GGRT system along with the data required to be reported in 

the annual report (concurrent entry of “inputs to equations” 

data elements and data required for the annual report would be 

required starting in reporting year 2014, as further discussed 

in Section III.A.2 of this preamble). As a built-in feature of 

the e-GGRT system, the tool would use the entered “inputs to 

equations” data elements to calculate the equation outputs, 

conduct electronic verification checks on the “inputs to 

equations” data elements, and generate a verification summary. 

The tool would not retain the entered “inputs to equations” data 

elements for which the EPA is proposing that the reporting 

requirement be removed.3

 Accordingly, unlike data currently 

reported to the EPA through e-GGRT, the EPA would not have 

access to these “inputs to equations” data elements. 

Sources subject to multiple subparts under Part 98 would be 

required to use the tool for only those subparts listed in Table 

2 of this preamble, as discussed in the following section. 

1. Detailed Description of Inputs Verification Tool.

 

3

 Please see section III.A.3 of this preamble for a discussion on which 

“inputs to equations” data elements the EPA is proposing that the reporting 

requirement be removed. 

Comment [A8]: Can EPA provide the 

code for this tool in the docket, 

so public commenters can review it 

to make sure no inputs are retained 

by EPA? 
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The EPA’s current verification approach consists of 

electronic verification checks followed by direct follow-up with 

facilities. For subparts where the reporting of inputs to 

emission equations has been deferred until 2015, these checks 

have been conducted using reported data other than inputs to 

emission equations (the reporting of which was deferred). For 

“supplier” subparts4

 (and starting in reporting year 2012 for 

subparts with inputs to emission equations that were deferred 

until 2013), these checks have been conducted using reported 

data that include the data needed to calculate outputs of the 

equations. Reporters under the supplier subparts have been 

entering into e-GGRT the data needed to calculate the annual GHG 

quantities. For the direct emitter subparts listed in Table 2 of 

this preamble, the EPA is proposing to use an approach similar 

to that currently used for the supplier subparts, where “inputs 

to equations” data elements would be entered into the inputs 

verification tool within e-GGRT and used to calculate the annual 

GHG emission values and verify these emission values. The 

difference, however, is that these “inputs to equations” data 

elements would be entered into this new inputs verification tool 

within e-GGRT and would not be reported to the EPA. 

 

4

 Supplier subparts (subparts LL through PP of Part 98) apply to fossil fuel 

suppliers and industrial gas suppliers. The e-GGRT system currently calculates 

equation outputs for suppliers using reported equations inputs. Subpart MM 

reporters began using e-GGRT for reporting in Reporting Year 2012. 
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To access the inputs verification tool, reporters would log 

into e-GGRT. They would enter data elements required for the 

annual report as well as their “inputs to equations” data 

elements. The tool would operate securely within e-GGRT, as a 

transient process, which means that “inputs to equations” data 

elements (for which the EPA is proposing that the reporting 

requirement be removed) entered into the tool would be 

temporarily saved in the tool while the reporter is actively 

using the tool, but would not be persisted (i.e., saved) within 

the e-GGRT database. The “inputs to equations” data elements 

would be discarded when the user’s session with e-GGRT ends. 

If the reporter exits the inputs verification tool prior to 

completing data entry or submitting their annual report, the 

tool would generate a file of entered “inputs to equations” data 

elements, and allow the reporter to download the file. This file 

could then be uploaded into the tool when the reporter next uses 

the tool. This would avoid facilities from needing to re-enter 

“inputs to equations” data elements that were entered in 

previous e-GGRT sessions. 

After the reporter enters the “inputs to equations” data 

elements into the inputs verification tool, the tool would 

calculate the annual GHG emissions values. The tool would use 

the following information in calculating these values: (1) 

“inputs to equations” data elements entered into the tool, (2) 
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“inputs to equations” data elements entered into e-GGRT (not 

into the inputs verification tool) (refer to Section III.A.3 of 

this preamble for a discussion of the “inputs to equations” data 

elements that would still be reported), (3) information entered 

into e-GGRT identifying which Part 98 calculation method was 

selected (if applicable), and (4) the selected Part 98 

calculation method. Once the annual GHG emissions values are 

calculated, the values would be pre-filled into the appropriate 

reporting fields within e-GGRT. Reporters would then have the 

opportunity to override the annual GHG emissions values 

calculated by the tool with their own calculated value. If the 

reporter chose to override the calculated value, this would be 

reflected in the verification summary. 

Prior to annual report submittal, the inputs verification 

tool would conduct a series of verification checks, including 

the following: 

 Verification checks on the annual GHG emission values 

calculated by the inputs verification tool. As mentioned 

above, reporters would have the opportunity to override and 

revise the value calculated by the tool; however should 

this occur, the tool would note a discrepancy, which would 

prompt the EPA for further review after the reporter 

submits the annual report. 

 Verification checks on entered “inputs to equations” data 

elements. For example, the tool would check: (1) whether 

all required data were entered; (2) whether entered “inputs 

to equations” data element values are within the expected 

ranges for the data elements; and (3) whether expected 

relationships exist between certain “inputs to equations” 

data elements and certain other reported data elements 
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(e.g., process raw material or throughput data that are not 

“inputs to equations” data elements). 

Some of these checks would be conducted as the reporter 

enters “inputs to equations” data elements (i.e., using “realtime” checking), and other checks would be conducted after the 

reporter has entered all “inputs to equations” data elements, 

because some algorithms may compare certain “inputs to 

equations” data elements (e.g., production quantity) to GHG 

emission values at the subpart or facility level. 

Also, prior to submittal of the annual report, the inputs 

verification tool would generate a verification summary 

containing the results of the verification checks. The 

verification summary would specify whether any potential errors, 

as described above, were identified, without specifying any 

information about the “inputs to equations” data elements. The 

reporter would have an opportunity to review the verification 

summary and make necessary revisions to the entered “inputs to 

equations” data elements and the reported data elements. 

For example, a facility subject to subpart G that 

manufactures ammonia using liquid and solid feedstocks is 

currently required under 40 CFR 98.76(b)(1) to report annual CO2

process emissions for each ammonia manufacturing unit. 

Currently, the reporter calculates this reported annual GHG 

emissions value outside of e-GGRT (e.g., using a calculator or 
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computer software), using Equations G-2, G-3, and G-4 of Part 

98, and monthly values for the following “inputs to equations” 

data elements: quantity of liquid feedstock, quantity of solid 

feedstock, carbon content value for liquid feedstock, and carbon 

content value for solid feedstock. We are proposing that the 

reporter instead calculate this reported annual GHG emissions 

value using the inputs verification tool, which not only would 

use the same equations and data for calculation, but would also 

conduct verification checks, as follows: 

 The reporter would enter all 48 “inputs to equations” data 

elements” into the inputs verification tool (i.e., monthly 

values for all four “inputs to equations” data elements). 

 The reporter would use the inputs verification tool to 

calculate annual CO2 process emissions. In calculating this 

value, the tool would use Equations G-2, G-3, and G-4 of 

Part 98 and the 48 “inputs to equations” data element 

entries. 

 Once the annual CO2 process emissions value is calculated, 

the inputs verification tool would automatically conduct 

verification checks on the 48 entered “inputs to equations” 

data elements. For example, the tool might conduct the 

following checks: 

 Real-time checks that all 48 “inputs to equations” data 

elements were entered. 

 Real-time checks that each of the 12 entered values for 

carbon content of liquid feedstock is within the expected 

range for carbon content of liquid feedstock (based on 

industry-wide data). The tool would conduct similar 

comparisons for the 12 entered “inputs to equations” data 

elements for the carbon content value for solid feedstock. 

 Run an algorithm check comparing each of the 12 entered 

values of the quantity of the liquid feedstock to all 

monthly values entered for the year, to determine if 

individual values are within an expected range established 

using all 12 values. The tool would conduct similar 

comparisons for the 12 entered “inputs to equations” data 
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elements for the quantity of solid feedstock. This type of 

check would be conducted after the reporter has entered all 

“inputs to equations” data elements. 

 Prior to annual report submittal, the inputs verification 

tool would automatically generate a verification summary, 

which would flag any potential errors, providing an 

opportunity for the reporter to review the verification 

summary and revise entered data. The verification summary 

would note if the reporter has overridden any of the annual 

GHG emissions values calculated by the tool. After the 

reporter completes all revisions to data entries, the tool 

would automatically re-generate the verification summary 

prior to annual report submittal. The EPA would access the 

verification summary (i.e., the same final summary viewed 

by the reporter) following annual report submittal and 

certification. 

 The inputs verification tool would also generate a file 

listing the entered “inputs to equations” data elements 

(for which the EPA is proposing to remove the reporting 

requirements) to be kept by the reporter and maintained as 

a record in a format currently allowed under Part 98 (see 

40 CFR 98.3(g), subpart A). Refer to Section III.B of this 

preamble for further discussion of this proposed amendment 

and the EPA’s rationale for requiring this record. 

The EPA has developed a “pilot” inputs verification tool 

for one subpart, subpart C, which will be posted at 

http://www.epa.gov/ghgreporting/reporters/training/rulepilot.htm

l, to demonstrate how the tool would work within e-GGRT, as well 

as the types of verification checks that would be conducted. The 

EPA seeks comment on the usability of the tool as well as its 

ability to conduct verification on the “inputs to equations” 

data elements. 

2. Rationale Supporting the Use of the Inputs Verification Tool 

as an Alternative to Collecting Certain “Inputs to Equations” 

Data Elements for Verification Purposes.
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In the October 30, 2009 final rule (74 FR 56282 – 56283), 

the EPA described its verification approach as the following 

two-step process: 

 Initial automated review of reported data, using an 

electronic data quality assurance program built into the 

data system, for use by reporters and the EPA to help 

assure the completeness and accuracy of data. 

 Based on the initial review results, follow up with 

facilities regarding potential errors, discrepancies, or 

questions, including on-site audits. 

The EPA is currently using the two-step verification 

process of automated verification checks followed by direct 

follow-up with facilities to verify data currently reported via 

e-GGRT. The EPA is proposing to supplement the current 

verification approach for facilities reporting under the 

subparts listed in Table 2 of this preamble using the additional 

checks that would be conducted by the inputs verification tool. 

During the first 3 years of the Greenhouse Gas Reporting Program 

(GHGRP), the EPA has had success developing and using an 

electronic reporting and verification system for all subparts 

reporting under the program. During reporting year 2010, the EPA 

developed approximately 1,400 electronic verification checks to 

verify reported data. Based on these verification checks, the 

EPA followed up with approximately 2,360 of the approximately 

6,700 facilities that reported in reporting year 2010, resulting 

in approximately 2,300 facilities resolving verification issues 
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by responding to the EPA and/or resubmitting their annual 

report. In reporting year 2011, the EPA programmed an additional 

1,000 checks into e-GGRT for the subparts that were reporting 

for the second year, expanding the number of checks to 2,400. 

The EPA also programmed into e-GGRT, for 2011, approximately 

1,300 checks for the newly-reporting subparts. During reporting 

year 2011, the EPA followed up with approximately 3,440 of the 

approximately 8,000 facilities that reported, resulting in 

approximately 3,000 facilities resolving their verification 

issues. 

For example, for subpart H, the EPA verifies reported GHG 

emissions data using: (1) reported cement production data and 

(2) publicly available industry data on GHG emissions. Using 

these data, the EPA has established ranges of acceptable 

production and emission values and set up algorithm checks for 

reported GHG emission values. 

The electronic checks used by the GHGRP have served as a 

means for the EPA to verify reported data while minimizing the 

burden on both the EPA and reporters. Electronic verification is 

a critical first step to ensuring the completeness and accuracy 

of reported data and reducing the costs of compliance 

monitoring. 

The inputs verification tool described in Section III.A.1 

of this preamble utilizes the same approach that the EPA 
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currently uses for calculating and verifying data submitted for 

supplier subparts (and starting in reporting year 2012, inputs 

to emission equations whose reporting deadline was deferred 

until 2013), except that e-GGRT would not retain the “inputs to 

equations” data elements entered into the tool. Once the annual 

report is submitted, the EPA would review the verification 

summary generated by the inputs verification tool, along with 

verification summaries that are currently generated using data 

currently collected through the annual report. By requiring use 

of the inputs verification tool, the EPA would have the 

additional certainty that reported annual GHG emissions values 

either were calculated correctly (because the values calculated 

by the tool were submitted to the EPA) or that the EPA would be 

made aware that there were discrepancies between values 

calculated by the tool and values submitted to the EPA. That 

additional certainty, combined with the additional information 

provided by the range and algorithm checks on the “inputs to 

equations” data elements themselves, would provide the EPA with 

information necessary to conduct further verification once the 

annual report is submitted. 

If a potential error with one of the “inputs to equations” 

data elements or with an annual GHG emissions value were 

identified in the verification summary generated by the inputs 

verification tool, the EPA would likely follow up with the 
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facility to determine whether an actual error has occurred. 

While this verification approach may result in more direct 

follow-up with facilities than if the “inputs to equations” data 

elements were submitted to the EPA, this approach would 

facilitate verification by identifying potential errors and 

minimizing the number of errors before annual reports are 

submitted. In addition, as discussed elsewhere in the preamble, 

the EPA is retaining the reporting requirement for “inputs to 

equations” data elements for which our four-step evaluation did 

not identify disclosure concerns and is proposing to require 

reporting of additional new data elements to assist the EPA’s 

verification effort. These “inputs to equations” data elements 

for which reporting would be retained and these proposed new 

reported data elements would allow the EPA to conduct additional 

verification and minimize the number of follow-ups with 

facilities. Lastly, the EPA is proposing that facilities retain 

records for 5 years, which would allow the EPA time to perform 

any necessary follow-up with reporters. For the reasons stated 

above, the EPA has determined that the proposed verification 

approach would be adequate to verify the reported emissions for 

the subparts identified in Table 2 of this preamble and is a 

reasonable alternative to collecting inputs for which we have 

identified disclosure concerns. 

Comment [A9]: Please explain why the 

record retention time needs to be 

lengthened. 
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The EPA is proposing to require the use of the inputs 

verification tool starting in reporting year 2014. The inputs 

verification tool is designed to be used concurrently with 

annual reporting by facilities. By the time the EPA takes any 

final action on this proposed amendment, reporters would have 

likely submitted annual reports for reporting years 2010 through 

2013. While additional verification could be conducted on the 

past years’ data if the inputs verification tool were used for 

these years, given that most of the data would likely already 

have been published and that the use of best available 

monitoring methods (BAMM) for these sectors is relatively low 

during these years, the EPA has determined that the added 

benefit does not outweigh the burden that would be required for 

facilities to use the inputs verification tool for years prior 

to reporting year 2014. 

3. Reporting of 435 “Inputs to Equations” Data Elements Would 

Not Be Necessary With the Proposed Verification Approach.

The EPA is proposing to remove the reporting requirement 

for 435 “inputs to equations” data elements that are in the 

subparts listed in Table 2 of this preamble. With the proposed 

alternative verification approach described in Section III.A.2 

of this preamble, the EPA would no longer need to rely on the 

collection of these “inputs to equations” data elements to 

verify emissions under those subparts. Not having these data 
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elements reported would address concerns relative to potential 

disclosure of these data elements.5

 These 435 data elements are 

specified in Table 1 of the memorandum “List of Inputs to 

Equations Data Elements Proposed Not To Be Reported” (refer to 

Docket ID No. EPA–HQ–OAR–2010-0929). 

The 435 “inputs to equations” data elements for which the 

EPA is proposing to remove the reporting requirement must be 

maintained on-site as records. Because Part 98 already requires 

these “inputs to equations” data elements to be kept as records 

(see 98.3(g)(2), which states that “the data used to calculate 

the GHG emissions for each unit, operation, process, and 

activity, categorized by fuel or material type” must be kept as 

records), the EPA is not proposing in this action to move each 

of the 435 “inputs to equations” data elements to the 

recordkeeping requirements of each subpart. The EPA considered 

whether moving each of these “inputs to equations” data elements 

to the recordkeeping requirements of each subpart would improve 

the clarity of the specific records that would be required to be 

retained. Because the EPA is proposing that the “inputs to 

equations” data elements that would not be reported must be kept 

as records in the format generated by the inputs verification 

 

5

We are proposing to remove the reporting requirement for certain “inputs to 

equations” data elements because, while there is not a disclosure concern, 

the EPA determined that these data elements would not be useful for data 

verification and would not inform future GHG policy development in the 

absence of other data elements for which we are proposing to remove the 

reporting requirement.
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tool (i.e., file for downloading or printing), the EPA 

determined that the data that must be kept as records would be 

sufficiently clear. The EPA seeks comment on whether additional 

specificity within the recordkeeping requirements of each 

subpart would improve the clarity of the specific records that 

are required to be retained. 

For the purposes of clarifying which data elements must be 

reported for previous reporting years 2010 through 2013, we are 

proposing to revise Table A-7 of Part 98 to remove all 435 data 

elements for which reporting is proposed to be removed. To be 

consistent with a separate action that is proposing to remove 

additional “inputs to equations” data elements from Part 98 (40 

CFR 98.256(o)(6) and (o)(7))), we are also proposing to remove 

these additional data elements from Table A-7. For the EPA’s 

rationale for removing these additional data elements from Part 

98, refer to the preamble to the April 2, 2013 proposal, “2013 

Revisions to the Greenhouse Gas Reporting Rule and Proposed 

Confidentiality Determinations for New or Substantially Revised 

Data Elements,” (78 FR 19802). 

The EPA is retaining reporting of 153 “inputs to equations” 

data elements.6 These 153 “inputs to equations” data elements 

 

6

 These 153 “inputs to equations” data elements include: (1) nine “inputs to 

equations” data elements in subpart L of part 98 that are not being addressed 

in this rulemaking and will be addressed in a separate action related to 

subpart L; and (2) five “inputs to equations” data elements in subpart Y of 

Comment [A10]: Please explain why 

the five “inputs to equations” in 

(2) of the FN that were proposed to 

be removed are, in fact, being 

retained. The FN should include an 

explanation or point the reader to 

an explanation. 
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include certain “inputs to equations” data elements for the 

subparts listed in Table 3 of this preamble, as well as all 

“inputs to equations” data elements for subparts C (only for 

certain combustion units connected to a device that delivers 

power to the local or regional electric power grid)7

, W, and II 

of part 98. For these “inputs to equations” data elements, the 

EPA is not amending these reporting requirements and would 

therefore let the deferral of these data elements expire on 

March 31, 2015. As a result, these “inputs to equations” data 

elements would be reported for future reporting years starting 

with reporting year 2014, as well as for previous reporting 

years (i.e., reporting years 2010 through 2013). Based on “Step 

2” of our evaluation described in Section I.B of this preamble, 

these data elements would not raise disclosure concerns. Having 

these data elements reported would allow the EPA to do 

additional verification, including conduct year-to-year 

comparisons, thereby reducing the amount of direct follow-up 

required with facilities. For the reason stated above, 

 

part 98 that were proposed in the April 2, 2013 rulemaking (78 FR 19802) to 

be removed from reporting. 

7

 Refers to combustion units subject to subpart C meeting the following 

criteria: (1) the combustion unit is connected to a device that has been 

granted access by the Public Utilities Commission to deliver power to the 

local or regional electric power grid (e.g., electricity generators excluding 

generators connected to combustion units subject to subpart D of this part); 

and (2) the combined nameplate capacity (for all such devices at the facility 

excluding generators connected to combustion units subject to subpart D of 

this part)) is greater than or equal to 1 megawatt electric. 
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collecting these data elements, even in the absence of 

collecting all “inputs to equations” data elements, would aid in 

the verification process. 

The EPA identified 23 “inputs to equations” data elements 

for which disclosure concerns were not identified based on “Step 

2” of our evaluation; however, the EPA is not retaining these 

reporting requirements. The EPA determined that these 23 data 

elements would not be useful for data verification and would not 

inform future GHG policy development in the absence of other 

“inputs to equations” data elements for which the reporting 

requirement is proposed to be removed under this 

action. Examples of these 23 “inputs to equations” include 

reporting the selected default molar volume conversion factor 

and reporting the units of measure of a site-specific emission 

factor. These “inputs to equations” are identified in the 

memorandum “List of ‘Inputs to Equations’ Data Elements Proposed 

Not To Be Reported” (refer to Docket ID No. EPA–HQ–OAR–2010-

0929). 

Regarding the 153 retained “inputs to equations” data 

elements, for reporting year 2014 and thereafter, reporters 

would enter the 153 “inputs to equations” data elements for 

which we are retaining the reporting requirement into e-GGRT. 

Starting in reporting year 2014, the e-GGRT system would retain 

these 153 data elements as part of the annual report and 
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accessible by the EPA once the reporter submits the annual 

report. In order to ease the burden on facilities, for reporting 

years prior to reporting year 2014, the EPA is proposing that 

these reported “inputs to equations” data elements be submitted 

as part of the reporting year 2014 annual report. This would 

prevent facilities from being required to revise, re-certify, 

and re-submit annual reports for reporting years 2010, 2011, 

2012, and 2013. 

The proposed revisions to the current reporting 

requirements would apply to all reporters subject to the 

subparts listed in Table 2 of this preamble, including subpart 

C. However, as noted in Table 2, we are not proposing to amend 

the reporting requirements for combustion units subject to 

subpart C that meet the following criteria: (1) the combustion 

unit is connected to a device that has been granted access by 

the Public Utilities Commission to deliver power to the local or 

regional electric power grid (e.g., electricity generators 

excluding generators connected to combustion units subject to 

subpart D of this part); and (2) the combined nameplate capacity 

(for all such devices at the facility excluding generators 

connected to combustion units subject to subpart D of this part) 

is greater than or equal to 1 megawatt electric. The “inputs to 

equations” data elements for these combustion units are among 

those that did not raise disclosure concerns under “Step 2” of 
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our evaluation of the “inputs to equations” data elements (refer 

to Section I.B of this preamble for a discussion of the EPA’s 

four-step evaluation). Refer to the memoranda documenting “Step 

2” of our evaluation, “Evaluation of Competitive Harm From 

Reporting 2015 Inputs to Equations” (Docket ID No. EPA–HQ–OAR–

2010-0929), for further information on the results of the 

analysis for these combustion units. 

Reporters currently reporting emissions for combustion 

units under subpart C have the option to utilize one or more of 

the reporting options under subpart C that allow the grouping of 

stationary combustion units for the purpose of monitoring, 

calculating, and reporting emissions. The EPA recognizes that 

stationary combustion units grouped in these reporting 

configurations could include both combustion units associated 

with devices that can produce electricity (connected to the grid 

and not connected to the grid) and combustion units not 

associated with devices that can produce electricity. In these 

cases where combustion units are grouped, the EPA has determined 

that there would be no disclosure concerns with reporting of 

“inputs to equations” data elements for the grouped combustion 

units. In reporting combined data for multiple units including 

those associated with a device capable of producing electricity 

and subject to reporting under this proposed action, no unitspecific data would be revealed. Furthermore, should a facility 
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not wish to disclose aggregated data, it would have the option 

to calculate and report emissions using one of the individual 

unit reporting configurations. The EPA seeks comment on this 

conclusion. If you believe that there are any disclosure 

concerns, please provide detailed information about the concern, 

as well as whether reporting on an individual unit basis is a 

feasible reporting option. 

Additionally, the EPA is proposing to revise two paragraphs 

(40 CFR 98.116(e)(6) and 40 CFR 98.186(b)(8)) that reference 

other paragraphs that include “inputs to equations” data 

elements proposed to be removed from Part 98. As a result, we 

are proposing to remove the cross reference while carrying over 

the substantive information in order to maintain the 

requirements in these paragraphs. 

The EPA requests comment on the proposed inputs 

verification tool and verification approach, and the associated 

revision to the current reporting requirements as described in 

this section. 

B. Proposed Revisions to Recordkeeping Requirements

Given the proposed verification approach described in 

Section III.A of this preamble, the EPA considered whether the 

current record retention period and record format requirements 

would be sufficient to allow the EPA to perform data 

verification. We considered: 
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 The time we would need to follow up with reporters to 

further verify reported GHG emissions. 

 The desirability of retaining multiple years of data 

records to allow for appropriate assessment of compliance 

and for analyses of trends for policy analysis purposes. 

 The format of records, and whether the current format would 

be adequate for our verification process. For example, we 

considered whether records of “inputs to equations” data 

elements contained in multiple separate documents (as 

currently allowed under Part 98) would allow an EPA 

inspector to efficiently analyze the consistency of the 

data elements and use the data elements to perform 

calculations to confirm reported GHG emissions. 

Because there may be more direct follow-up activities under 

this alternative verification approach, we are proposing to 

extend the record retention period from 3 to 5 years. We have 

determined that 5 years is reasonable given the large number of 

reporters under the subparts identified in Table 2 of this 

preamble (over 2,000 facilities) and the likely increase in 

follow-up activities. It would be important that relevant 

records are available to the EPA for follow-up activities with 

facilities, including on-site audits if necessary, regarding 

potential errors, discrepancies, or questions. Should an EPA 

inspector visit a facility, it would be important to be able to 

examine not only the current year’s records but those from 

previous years as well, because previous years’ data would 

provide year-to-year comparisons, which are useful for verifying 

the current year’s data. A 5-year record retention period would 

ensure the availability of relevant records for the follow-up 

Comment [A11]: What’s the penalty 

for misreporting data or not 

retaining these records for the 

full 5 years? 
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activities described above. The EPA is proposing that this 5-

year record retention requirement begin with records for 

reporting year 2010, as discussed in Section III.A.1 of this 

preamble. 

The EPA is proposing to extend the record retention period 

not only for the subparts listed in Table 2 of the preamble, but 

also for other subparts that apply to reporters subject to a 

subpart in Table 2. Under this proposal, a facility subject to 

both a subpart listed in Table 2 of this preamble and a subpart 

not listed in Table 2 would be required to maintain all records 

required under both subparts for a period of 5 years. For 

example, if a facility is required to report under both subpart 

C (in Table 2) and subpart HH (not in Table 2), the facility 

would be required to maintain all records required under both 

subparts for 5 years. The EPA is proposing these provisions for 

two reasons. First, the EPA determined that during a site visit, 

if questions arise regarding the accuracy of an “inputs to 

equations” data element, it may be necessary to examine other 

non-input recordkeeping information, such as a monitoring plan 

or recordkeeping information in a different subpart, in order to 

fully investigate the accuracy of the data. It is necessary to 

ensure that all data necessary for verification are available, 

and this proposed 5-year record retention period would provide 

better assurance of on-site data availability. Second, the EPA 
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determined that maintaining multiple sets of data records 

according to different record retention periods could possibly 

cause confusion and result in recordkeeping errors. Providing 

the same record retention duration for all subparts, as 

proposed, would simplify recordkeeping and thereby minimize the 

chance for recordkeeping errors. 

In addition, the EPA is proposing revisions to the 

recordkeeping format for “inputs to equations” data elements. 

Currently, reporters have the option to maintain records of 

their “inputs to equations” data elements in one or more 

electronic or hard copy files. The proposed record format 

revision would require reporters to maintain an electronic or 

hard copy of the single file generated by the proposed inputs 

verification tool, listing all “inputs to equations” data 

elements entered into the tool. This proposed record format 

change would ensure that the EPA could readily access these 

data, enabling the EPA to quickly and efficiently perform 

calculations and data checks during site visits. All other 

records required under Part 98 would be maintained in the format 

currently required under Part 98. In combination with the 

proposed reporting requirements discussed in Sections III.A and 

C of this preamble, these proposed recordkeeping requirements 

would allow the EPA to adequately verify certain reported 

emissions without implicating the disclosure concerns discussed 
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in the memorandum “Evaluation of Competitive Harm For Reporting 

2015 Inputs to Equations” 

(refer to Docket ID No. EPA–HQ–OAR–2010-0929). 

In amending 40 CFR part 98, subpart A to add these 

recordkeeping requirements, we are also correcting an error in 

the current version of 40 CFR 98.3(g). In a previous action 

amending this paragraph (76 FR 73866, November 29, 2011), our 

intension intention was to amend the second sentence of the 

paragraph regarding record retention duration; however, the 

third sentence regarding record format was inadvertently 

amended. To correct this error, we are proposing to remove the 

second sentence of 40 CFR 98.3(g) and to reinstate the previous 

third sentence of 40 CFR 98.3(g) (regarding format of records). 

We seek comment on whether 5 years is the appropriate 

timeframe for maintaining records for facilities with a subpart 

listed in Table 2 of this preamble. In addition, we seek comment 

on the proposal to extend the record retention period not only 

for the subparts listed in Table 2 of the preamble, but also for 

other subparts that apply to reporters subject to a subpart in 

Table 2. 

C. Proposed Requirement to Report Additional Data

As part of our proposal to no longer require reporting of 

certain “inputs to equations” data elements, we are proposing to 

require that certain reporters using the proposed inputs 

Comment [A12]: Typo. 
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verification tool also report the new data elements specified in 

Table 4 of this preamble. These additional data elements would 

allow the EPA to perform additional verification checks and 

minimize the number of follow-up activities. These data elements 

are quantities that provide information on the activity level at 

the facility, emission factors used, characteristics of carboncontaining streams, and other process information that would 

provide key information for verification, including confirming 

that emissions are appropriate for a given activity-level and 

estimating expected emissions based on data provided. These new 

data reporting elements would also enable the EPA to better 

understand the following aspects concerning reporters in order 

to inform future GHG policy:8

 (1) the GHG emission profile for 

the reporter; (2) the relationship of GHG emissions to 

production output or raw material input within the industry 

sector; and (3) the factors influencing GHG emissions. 

The EPA is proposing to add six new equations (Equations Q9 through Q-14 of part 98) to subpart Q to specify how to 

calculate and report each of the six new data elements proposed 

to be added to subpart Q of part 98. Table 4 of this preamble 

specifies which equation number correlates with each new 

 

8

 The EPA has previously stated that a goal of collecting data under the GHGRP 

is to inform future GHG policy (refer to the April 10, 2009 proposed rule (74 

FR 16455). 
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proposed data element. Refer to the proposed amendments for 

subpart Q for the proposed equations. 

The EPA is proposing confidentiality determinations for 

these proposed new data elements. Those new data elements 

determined to be confidential business information in a final 

rule would be afforded confidential treatment. Refer to the 

following Section IV of this preamble for the EPA’s proposed 

confidentiality determinations for the proposed new data 

elements. 

IV. Confidentiality Determination for Proposed New Data Elements 

to be Reported 

The EPA is proposing confidentiality determinations for 

each new data element listed in Table 4 of this preamble. To 

make these determinations, the EPA proposes to use the same 

approach that the EPA previously used for the 2011 final CBI 

rule (76 FR 30782, May 26, 2011). Specifically, the EPA is 

proposing to assign each new data element listed in Table 4 of 

this preamble to one of 11 direct emitter data categories, based 

on the type and characteristics of the data element. For a 

description of each data category and the type and 

characteristics of data elements assigned to each category, see 

Sections II.C and II.D of the July 7, 2010 CBI proposal preamble 

(75 FR 39106 – 39130). 
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Based on its evaluation of the new data elements, the EPA 

is proposing that each new data element be assigned to one of 

the four following direct emitter data categories: 

 Production/Throughput Data that are Not Inputs to Emission 

Equations. 

 Raw Materials Consumed that are Not Inputs to Emission 

Equations. 

 Unit/Process “Static” Characteristics that are Not Inputs 

to Emission Equations. 

 Unit/ Process Operating Characteristics that are Not Inputs 

to Emission Equations. 

In the 2011 final CBI rule (May 26, 2011, 76 FR 30782), the 

EPA made categorical determinations that all data elements 

assigned to the “Production/Throughput Data that are Not Inputs 

to Emission Equations” and “Raw Materials Consumed that are Not 

Inputs to Emission Equations” data categories are entitled to 

confidential treatment because the data do not meet the 

definition of “emission data” in 40 CFR 2.301(a)(2)(i) and they 

are CBI. 

The EPA is proposing that seven new data elements be 

assigned to the “Production/Throughput Data that are Not Inputs 

to Emission Equations” data category and 10 new data elements be 

assigned to the “Raw Materials Consumed that are Not Inputs to 

Emission Equations” data category, as shown in Table 5 of this 

preamble, thereby applying the categorical confidentiality 

determinations made for these categories in the 2011 final CBI 
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rule (i.e., they are CBI) to the proposed new reporting elements 

assigned to these categories. This proposal is not changing, nor 

soliciting comment on, the categorical confidentiality 

determination for these two data categories. Should the EPA 

finalize the category assignment for these data elements, all 

new data elements assigned to these categories would be 

considered to be entitled to confidential treatment. 

Table 5. Data Elements Proposed to Be Assigned To the 

“Production/Throughput Data that are Not Inputs to Emission 

Equations” and “Raw Materials Consumed that are Not Inputs to 

Emission Equations” Data Categories 

Subpart Proposed Citation Data Element 

“Production/Throughput Data that are Not Inputs to Emission 

Equations” Data Category 

G - Ammonia 

Production 

40 CFR 98.76(c)(14) Annual ammonia 

production (metric 

tons). 

40 CFR 98.76(d)(15) Annual methanol 

production (metric 

tons), if this 

quantity is not 

reported under 

subpart X of Part 98. 

H - Cement Kilns 40 CFR 98.86(b)(16) Annual clinker 

production (metric 

tons).

P – Hydrogen 

Production 

40 CFR 98.166(e) Annual methanol 

production (metric 

tons), if this 

quantity is not 

reported under 

subpart X of Part 98. 

S - Lime 

Manufacturing 

40 CFR 98.196(b)(18) Annual quantity 

(metric tons) of lime 

product sold, by 

type. 

X – Petrochemical 40 CFR 98.246(a)(13) 

and (b)(10) 

If using the mass 

balance method or 

CEMS method to 
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Subpart Proposed Citation Data Element 

calculate GHG 

emissions: Name and 

annual quantity (in 

metric tons) of each 

carbon-containing coproduct included in 

Equations X-1, X-2 

and X-3. 

AA - Pulp and 

Paper 

40 CFR 98.276(l)(1) For each pulp mill 

lime kiln: 

Quantity of calcium 

oxide (CaO) produced 

(metric tons). 

“Raw Materials Consumed that are Not Inputs to Emission 

Equations” Data Category 

E - Adipic Acid 

Production 

40 CFR 98.56(m) Annual quantity of 

cyclohexane fed to 

all production lines, 

combined (metric 

tons). 

P - Hydrogen 

Production 

40 CFR 98.166(b)(7) Name and annual 

quantity (metric 

tons) of each carboncontaining fuel and 

feedstock. 

Q - Iron and Steel 40 CFR 98.176(i)(1) If you use the carbon 

mass balance method 

in 40 CFR 

98.173(b)(1) to 

determine CO2

emissions: The annual 

mass (metric tons) of 

all gaseous, liquid, 

and solid fuels 

(combined) used in 

process units 

specified in 

Equations Q-1 through 

Q-7, calculated as 

specified in a new 

Equation Q-9 in the 

proposed rule 

amendments. Do not 

include fuel used in 

a stationary 

combustion unit where 
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Subpart Proposed Citation Data Element 

emissions are 

reported under 

subpart C of this 

part. 

40 CFR 98.176(i)(2) If you use the carbon 

mass balance method 

in 40 CFR 

98.173(b)(1) to 

determine CO2

emissions: The annual 

mass (metric tons) of 

all non-fuel material 

inputs (combined) 

specified in 

Equations Q-1 through 

Q-7, calculated as 

specified in a new 

Equation Q-10 in the 

proposed rule 

amendments. 

40 CFR 98.176(i)(3) If you use the carbon 

mass balance method 

in 40 CFR 

98.173(b)(1) to 

determine CO2

emissions: The annual 

mass (metric tons) of 

all solid and liquid 

products and 

byproducts (combined) 

specified in 

Equations Q-1 through 

Q-7, calculated as 

specified in a new 

Equation Q-11 in the 

proposed rule 

amendments. 

40 CFR 98.176(i)(4) If you use the carbon 

mass balance method 

in 40 CFR 

98.173(b)(1) to 

determine CO2

emissions: The 

weighted average 

carbon content of all 

gaseous, liquid, and 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release 

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Page 61 of 125 

Subpart Proposed Citation Data Element 

solid fuels 

(combined) included 

in Equation Q-9, 

calculated as 

specified in a new 

Equation Q-12 in the 

proposed rule 

amendments. 

40 CFR 98.176(i)(5) If you use the carbon 

mass balance method 

in 40 CFR 

98.173(b)(1) to 

determine CO2

emissions: The 

weighted average 

carbon content of all 

non-fuel inputs to 

all furnaces 

(combined) included 

in Equation Q-10, 

calculated as 

specified in a new 

Equation Q-13 in the 

proposed rule 

amendments. 

40 CFR 98.176(i)(6) If you use the carbon 

mass balance method 

in 40 CFR 

98.173(b)(1) to 

determine CO2

emissions: The 

weighted average 

carbon content of all 

solid and liquid 

products and 

byproducts from all 

furnaces (combined) 

included in a new 

Equation Q-11 in the 

proposed rule 

amendments, 

calculated as 

specified in new 

Equation Q-14 in the 

proposed rule 

amendments. 
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Page 62 of 125 

Subpart Proposed Citation Data Element 

X – Petrochemical 40 CFR 98.246(a)(12) 

and (b)(9) 

If using the mass 

balance method or 

CEMS method to 

calculate GHG 

emissions: Name and 

annual quantity (in 

metric tons) of each 

carbon-containing 

feedstock included in 

Equations X-1, X-2 

and X-3. 

AA - Pulp and 

Paper 

40 CFR 98.276(m)(1) For each chemical 

recovery furnace and 

chemical recovery 

combustion unit for 

which you are not 

using Equation C-2c 

to calculate CO2

emissions: Annual 

mass of steam 

generated (lb steam), 

individually for each 

fossil fuel type and 

for spent liquor 

solids. 

The EPA is proposing to assign eight proposed new data 

elements to the “Unit Process Operating Characteristics that are 

Not Inputs to Emission Equations” category and one proposed new 

data element to the “Unit/Process Static Characteristics that 

are Not Inputs to Emission Equations” category. In the 2011 

final CBI rule, the EPA determined that the data elements in 

these categories are not “emission data” (as defined at 40 CFR 

2.301(a)(2)(i)). However, instead of categorical determinations, 

the EPA made confidentiality determinations for individual data 

elements assigned to these two categories. In proposing these 
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Page 63 of 125 

determinations, the EPA considered the confidentiality criteria 

at 40 CFR 2.208, in particular whether release of the data is 

likely to cause substantial harm to the business’s competitive 

position. See 40 CFR 2.208(e)(1). The EPA is therefore following 

the same approach in this action for the proposed new reporting 

elements assigned to these two categories. 

Table 6 of this preamble lists the data elements the EPA 

proposes to assign to these two data categories and presents the 

EPA’s rationale for proposing to determine that each does or 

does not qualify as CBI under CAA section 114(c). 

Table 6. Proposed Confidentiality Determinations for Proposed 

New Data Elements Assigned to the “Unit/Process Operating 

Characteristics That Are Not Inputs to Emission Equations” and 

“Unit/Process ‘Static’ Characteristics that Are Not Inputs to 

Emission Equations” Data Categories 

Subpart Citation 

Data 

Element 

Confidentia

lity 

Determinati

on 

Proposed Rationale for 

Confidentiality 

Determination 

“Unit/Process Operating Characteristics That Are Not Inputs to 

Emission Equations” Data Category

E – 

Adipic 

Acid 

Producti

on 

40 CFR 

98.56(n) 

Annual 

percent 

N2O 

emission 

reduction 

for all 

productio

n units 

combined. 

Not CBI The annual facility 

percent N2O reduction 

could not be used to 

calculate adipic acid 

production. The level 

of N2O reductions 

varies by the type of 

abatement technology, 

the environment in 

which the abatement 

technology is 

operating, the age of 

the abatement 

technology, the age of 

the catalyst used, and 

the maintenance level 

of the abatement 
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Subpart Citation 

Data 

Element 

Confidentia

lity 

Determinati

on 

Proposed Rationale for 

Confidentiality 

Determination 

technology. 

H - 

Cement 

Kilns 

40 CFR 

98.86(b)(1

7) 

Annual 

average 

clinker 

CO2

emission 

factor 

for the 

facility, 

averaged 

across 

all kilns 

(metric 

tons 

CO2/metri

c ton 

clinker 

produced)

. 

CBI This data element could 

be used to back 

calculate a facility’s 

clinker production 

data, which would 

result in competitive 

disadvantage. 

40 CFR 

98.86(b)(1

8) 

Annual 

average 

cement 

kiln dust 

(CKD) CO2

emission 

factor 

for the 

facility, 

averaged 

across 

all kilns 

(metric 

tons 

CO2/metri

c ton CKD 

produced)

. 

CBI This data element could 

provide information 

about the efficiency of 

the operation, which 

would result in 

competitive 

disadvantage. 

V – 

Nitric 

Acid 

Producti

on 

40 CFR 

98.226(q) 

Annual 

percent 

N2O 

emission 

reduction 

for all 

productio

n units 

Not CBI The annual facility 

percent N2O reduction 

for all nitric acid 

production trains 

combined could not be 

used to calculate the 

nitric acid production 
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Page 65 of 125 

Subpart Citation 

Data 

Element 

Confidentia

lity 

Determinati

on 

Proposed Rationale for 

Confidentiality 

Determination 

combined. value for any 

individual facility. 

The level of N2O 

reductions for each 

individual facility 

varies by the type of 

abatement technology, 

the environment in 

which the abatement 

technology is 

operating, the age of 

the abatement 

technology, the age of 

the catalyst used, and 

the maintenance level 

of the abatement 

technology. 

Additionally, facilitylevel N2O emission 

reduction information 

is already publicly 

available (see docket 

number EPA-HQ-OAR-2010-

0750 and 

http://www.climateactio

nreserve.org). 

Y – 

Petroleu

m 

Refineri

es 

40 CFR 

98.256(e)(

11)(i) 

Annual 

quantity 

of flare 

gas 

combusted 

(in MMscf 

per year) 

(only 

when 

using 

Equation 

Y-3). 

Not CBI This data element does 

not reveal (nor could 

be used to calculate) 

details regarding 

product 

characteristics, actual 

production data, or 

operating efficiency. 

It does not provide 

information that would 

allow competitors to 

infer market share, 

production costs, or 

pricing structures and 

thus gain a competitive 

advantage. The EPA 

applied the same 

rationale in the 2010 

proposed and 2011 final 

CBI rules (75 FR 39113 

and 76 FR 30803 - 
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Page 66 of 125 

Subpart Citation 

Data 

Element 

Confidentia

lity 

Determinati

on 

Proposed Rationale for 

Confidentiality 

Determination 

30806), in support of a 

non-CBI determination 

for reporting of the 

following same data 

element currently 

required to be reported 

if a different equation 

(Equation Y-1a) is 

used: annual volume of 

flare gas combusted 

(scf/year) under 40 CFR 

98.256(e)(6). 

40 CFR 

98.256(e)(

11)(ii) 

Annual 

average 

molecular 

weight of 

flare gas 

combusted 

(in mmBtu 

per 

MMscf) 

(only 

when 

using 

Equation 

Y-3). 

Not CBI This data element does 

not reveal (nor could 

be used to calculate) 

details regarding 

product 

characteristics, actual 

production data, or 

operating efficiency. 

It does not provide 

information that would 

allow competitors to 

infer market share, 

production costs, or 

pricing structures and 

thus gain a competitive 

advantage. The EPA 

applied the same 

rationale in the 2010 

proposed and 2011 final 

CBI rules (75 FR 39113 

76 FR 30803 - 30806), 

in support of a non-CBI 

determination for 

reporting of the 

following same data 

element currently 

required to be reported 

if a different equation 

(Equation Y-1a) is 

used: annual average 

molecular weight of the 

flare gas (kg/kg-mole) 

under 40 CFR 

98.256(e)(6). 
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Subpart Citation 

Data 

Element 

Confidentia

lity 

Determinati

on 

Proposed Rationale for 

Confidentiality 

Determination 

40 CFR 

98.256(e)(

11)(iii) 

Annual 

average 

carbon 

content 

of flare 

gas 

combusted 

(expresse

d as a 

decimal 

fraction)

(only 

when 

using 

Equation 

Y-3). 

Not CBI This data element does 

not reveal (nor could 

be used to calculate) 

details regarding 

product 

characteristics, actual 

production data, or 

operating efficiency. 

It does not provide 

information that would 

allow competitors to 

infer market share, 

production costs, or 

pricing structures and 

thus gain a competitive 

advantage. The EPA 

applied the same 

rationale in the 2010 

proposed and 2011 final 

CBI rules (75 FR 39113 

76 FR 30803 - 30806), 

in support of a non-CBI 

determination for 

reporting of the 

following same data 

element currently 

required to be reported 

if a different equation 

(Equation Y-1a) is 

used: annual average 

carbon content of the 

flare gas (kg carbon/kg 

flare gas) under 40 CFR 

98.256(e)(6). 

AA - 

Pulp and 

Paper 

40 CFR 

98.276(l)(

2) 

For each 

pulp mill 

lime 

kiln: 

Percent 

of annual 

heat 

input, 

individua

lly for 

each 

fossil 

fuel 

Non-CBI Release of this data 

would not result in 

competitive harm 

because lime kiln 

fossil fuel use as a 

fraction of design heat 

input was reported to 

the EPA as part of a 

2011 ICR survey, and 

facilities reporting 

via the survey made no 

CBI claims regarding 

fuel type and percent 
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Page 68 of 125 

Subpart Citation 

Data 

Element 

Confidentia

lity 

Determinati

on 

Proposed Rationale for 

Confidentiality 

Determination 

type. of design heat input. 

“Unit/Process ‘Static’ Characteristics that Are Not Inputs to Emission 

Equations” Data Category 

AA - 

Pulp and 

Paper 

40 CFR 

98.276(m)(

2) 

For each 

chemical 

recovery 

furnace 

and 

chemical 

recovery 

combustio

n unit 

for which 

you are 

not using 

Equation 

C-2c to 

calculate 

CO2

emissions

: 

Ratio of 

the 

unit’s 

maximum 

rated 

heat 

input 

capacity 

to its 

design 

rated 

steam 

output 

capacity 

(mmBtu/lb 

steam), 

individua

lly for 

each 

fossil 

fuel type 

and for 

spent 

ND1

 In the final CBI 

rulemaking (76 FR 

30799, May 26, 2011), 

we determined that the 

best approach for 

determining 

confidentiality of 

production capacity is 

not to make a single 

CBI determination 

applicable to all 

facilities within a 

given source category, 

due to differences 

between facilities. For 

all reported data 

elements related to 

production capacity, 

the EPA will make caseby-case determinations 

per reporter, in 

accordance with the 

provisions in 40 CFR 

part 2, subpart B for 

facilities that claim 

these data elements as 

CBI. 
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Page 69 of 125 

Subpart Citation 

Data 

Element 

Confidentia

lity 

Determinati

on 

Proposed Rationale for 

Confidentiality 

Determination 

liquor 

solids. 

1

 ND = No determination was made. 

The EPA is requesting comment on two aspects of these 

confidentiality determinations. First, the EPA seeks comment on 

the proposed data category assignment for each of these data 

elements in Tables 5 and 6. If you believe that the EPA has 

improperly assigned any proposed new data elements to one of the 

data categories, please provide specific comments identifying 

which proposed new data elements may be mis-assigned along with 

a detailed explanation of why you believe them to be incorrectly 

assigned and in which data category you believe they best 

belong. 

Second, for those data elements assigned to the two direct 

emitter data categories without categorical confidentiality 

determinations, the EPA seeks comment on the individual 

confidentiality determinations we are proposing for these data 

elements. If you comment on this issue, please provide specific 

comment along with detailed rationale and supporting information 

on whether such data element does or does not qualify as CBI. 

V. Impacts of the Proposed Rule 

This section examines the cost impacts of the proposed 

rulemaking. A detailed discussion of the impacts may be found in 
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Page 70 of 125 

the memorandum, ”Impacts Analysis of the Proposed 2015 Inputs 

Proposal,” available in EPA docket ID No. EPA–HQ–OAR–2010-0929. 

A. How were the costs of this proposed rule estimated?

1. Proposed Inputs Verification Tool.

The data elements required to be used for calculating the 

annual GHG emissions values and the cost associated with 

collecting these data, have not changed from the estimate made 

during the original rulemaking process. The time associated with 

entry of these “inputs to equations” data elements into e-GGRT 

(including into the new inputs verification tool) is expected to 

be equivalent to the time originally anticipated for data entry. 

Prior to the inputs verification tool, as currently required, 

reporters must use their own calculation tool (e.g., calculator, 

calculation software) to calculate the annual GHG emissions 

values, using the same sets of equations and entering the same 

data elements that they would enter into the tool. 

The EPA does recognize however that there may be some time 

associated with learning the new procedures for the inputs 

verification tool and we have estimated a cost of approximately 

$340,000 for the first year for all affected facilities. 

2. Proposed New Data Elements.

We are proposing to add 26 new data elements that were not 

previously required to be reported under Part 98 (see Section 

II.D of this preamble for further discussion of this proposed 

Comment [A13]: EPA estimates this 

cost for affected facilities and 

$80,000 for recordkeeping and 

reporting (p. 72). It would be 

helpful if EPA could provide 

further explanation on how the cost 

is derived. Specifically, what cost 

elements were included; whether 

facility- or industry-specific 

assumptions were used; whether 

additional labor hours are 

anticipated to comply with the 

rule, and why EPA anticipates that 

costs would only occur in the first 

year of the rule? This information 

may be in a separate document, and 

if so, please reference it. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release 

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Page 71 of 125 

amendment). Of these 26 data elements, nine data elements are 

related to annual production or raw material usage, which are 

collected by a facility as a routine part of conducting 

business. For these data elements, we are not proposing that 

reporters comply with specific data collection or monitoring 

requirements beyond the methods commonly used for accounting 

purposes. The other 17 data elements proposed to be reported are 

calculated values using data currently required to be collected 

to perform emissions calculations. For all of these additional 

data elements, the EPA has estimated a nominal additional cost 

to report the data element and fulfill the recordkeeping 

requirements. The total costs associated with reporting and 

recordkeeping for the 26 data elements in 10 subparts is 

$80,000. 

B. Additional Impacts of the Proposed Amendments

The proposed confidentiality determinations for the new 

data elements would not affect whether and how data are reported 

and, therefore, would not impose any additional burden on 

sources. 

VI. Statutory and Executive Order Reviews 

A. Executive Order 12866: Regulatory Planning and Review and 

Executive Order 13563: Improving Regulation and Regulatory 

Review
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Page 72 of 125 

Under Executive Order 12866 (58 FR 51735, October 4, 1993), 

this action is a “significant regulatory action” because this 

action raises novel legal or policy issues arising out of legal 

mandates, the President’s priorities, or principles set forth in 

the executive order. Accordingly, the EPA submitted this action 

to the Office of Management and Budget (OMB) for review under 

Executive Orders 12866 and 13563 (76 FR 3821, January 21, 2011) 

and any changes made in response to OMB recommendations have 

been documented in the docket for this action. 

B. Paperwork Reduction Act

This action proposes to amend reporting and recordkeeping 

requirements and verification procedures for the GHGRP. In 

addition, the EPA is proposing confidentiality determinations 

for the proposed new data elements in this action. The proposed 

amendments to the reporting requirements in the source categoryspecific subparts are not anticipated to result in significant 

burden for reporters. The new data elements required to be 

reported are expected to be readily available for affected 

facilities, or easily calculated using data already required to 

be collected (e.g., a monthly value is currently reported and an 

annual value is proposed to be reported). 

Impacts associated with the proposed changes to the 

reporting requirements in each subpart are detailed in the 

memorandum “Impacts Analysis of the Proposed 2015 Inputs 
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Page 73 of 125 

Proposal” (see Docket ID No. EPA-HQ-OAR-2010-0929). The Office 

of Management and Budget (OMB) has previously approved the 

information collection requirements for 40 CFR part 98 under the 

provisions of the Paperwork Reduction Act, 44 U.S.C. 3501 et seq

and has assigned OMB control number 2060-0629, ICR 2300.10. OMB 

has approved the information collection requirements for this 

rulemaking and has assigned OMB control number 2060-new, ICR 

2483.01. The OMB control numbers for the EPA’s regulations in 40 

CFR are listed in 40 CFR part 9. 

C. Regulatory Flexibility Act (RFA)

The RFA generally requires an agency to prepare a 

regulatory flexibility analysis of any rule subject to notice 

and comment rulemaking requirements under the Administrative 

Procedure Act or any other statute unless the agency certifies 

that the rule will not have a significant economic impact on a 

substantial number of small entities. Small entities include 

small businesses, small organizations, and small governmental 

jurisdictions. 

For purposes of assessing the impacts of the proposed 

amendments on small entities, “small entity” is defined as: (1) 

A small business as defined by the Small Business 

Administration’s regulations at 13 CFR 121.201; (2) a small 

governmental jurisdiction that is a government of a city, 

county, town, school district or special district with a 
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Page 74 of 125 

population of less than 50,000; or (3) a small organization that 

is any not-for-profit enterprise which is independently owned 

and operated and is not dominant in its field. This definition 

of small entity is consistent with the definition of small 

entity used for Part 98. 

After considering the economic impacts of today’s proposed 

amendments on small entities, I certify that this action will 

not have a significant economic impact on a substantial number 

of small entities. The small entities subject to Part 98 include 

small businesses across all sectors of the economy encompassed 

by Part 98, small governmental jurisdictions, and small nonprofits. The impacts of these proposed amendments are expected 

to be roughly a first-year cost of $60 per facility for learning 

new procedures for the verification tool and an annual cost of 

$100 per facility for the recordkeeping and reporting of 26 new 

data elements. 

The EPA continues to be interested in the potential impacts 

of the proposed rule amendments on small entities and welcomes 

comments on issues related to such impacts. 

D. Unfunded Mandates Reform Act (UMRA)

The proposed amendments and confidentiality determinations 

do not contain a federal mandate that may result in expenditures 

of $100 million or more for State, local, and tribal 

governments, in the aggregate, or the private sector in any one 
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year. Thus, the proposed amendments and confidentiality 

determinations are not subject to the requirements of sections 

202 or 205 of UMRA. 

This rule is also not subject to the requirements of 

section 203 of UMRA because it contains no regulatory 

requirements that might significantly or uniquely affect small 

governments. This action proposes to amend reporting and 

recordkeeping requirements and verification procedures for the 

GHGRP. In addition, the EPA is proposing confidentiality 

determinations for the proposed new data elements in this 

action. Therefore, this action is not subject to the 

requirements of section 203 of the UMRA. 

E. Executive Order 13132: Federalism

The action does not have federalism implications. It will 

not have substantial direct effects on the states, on the 

relationship between the national government and the states, or 

on the distribution of power and responsibilities among the 

various levels of government, as specified in Executive Order 

13132. The proposed amendments and confidentiality 

determinations apply to facilities that directly emit 

greenhouses gases and fuel and chemicals suppliers. These 

proposed changes do not apply to governmental entities unless 

the government entity owns a facility that directly emits GHGs 

above threshold levels (such as a large stationary combustion 
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Page 76 of 125 

device), so relatively few government facilities would be 

affected. Moreover, for government facilities that are subject 

to the rule, the proposed revisions will not have a significant 

cost impact. This proposed action also does not limit the power 

of states or localities to collect GHG data and/or regulate GHG 

emissions. Thus, Executive Order 13132 does not apply to this 

rule. 

In the spirit of Executive Order 13132, and consistent with 

EPA policy to promote communications between the EPA and state 

and local governments, the EPA specifically solicits comments on 

this proposed action from state and local officials. 

F. Executive Order 13175: Consultation and Coordination with 

Indian Tribal Governments.

This proposed action does not have tribal implications, as 

specified in Executive Order 13175 (65 FR 67249, November 9, 

2000). The proposed amendments and confidentiality 

determinations apply directly to facilities that directly emit 

greenhouses gases or that are suppliers of GHGs. They would not 

have tribal implications unless the tribal entity owns a 

facility that directly emits GHGs above threshold levels (such 

as a landfill or large combustion device). Relatively few tribal 

facilities would be affected. Thus, Executive Order 13175 does 

not apply to this action. 
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G. Executive Order 13045: Protection of Children from 

Environmental Health Risks and Safety Risks

The EPA interprets Executive Order 13045 (62 FR 19885, 

April 23, 1997) as applying only to those regulatory actions 

that concern health or safety risks, such that the analysis 

required under section 5-501 of the Executive Order has the 

potential to influence the regulation. This proposed action is 

not subject to Executive Order 13045 because it does not 

establish an environmental standard intended to mitigate health 

or safety risks. 

H. Executive Order 13211: Actions that Significantly Affect 

Energy Supply, Distribution, or Use

This proposed action is not a “significant energy action” 

as defined in Executive Order 13211 (66 FR 28355, May 22, 2001), 

because it is not likely to have a significant adverse effect on 

the supply, distribution, or use of energy. Part 98 relates to 

monitoring, reporting, and recordkeeping and does not impact 

energy supply, distribution, or use. This action proposes to

amend reporting and recordkeeping requirements and verification 

procedures for the GHGRP. In addition, the EPA is proposing 

confidentiality determinations for the proposed new data 

elements in this action. These proposed amendments and 

confidentiality determinations do not make any changes to the 

existing monitoring, recordkeeping, or reporting requirements 
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Page 78 of 125 

under Part 98 that affect the supply, distribution, or use of 

energy. 

I. National Technology Transfer and Advancement Act

Section 12(d) of the National Technology Transfer and 

Advancement Act of 1995 (NTTAA), Public Law No. 104-113, 12(d) 

(15 U.S.C. 272 note) directs the EPA to use voluntary consensus 

standards in its regulatory activities unless to do so would be 

inconsistent with applicable law or otherwise impractical. 

Voluntary consensus standards are technical standards (e.g., 

materials specifications, test methods, sampling procedures, and 

business practices) that are developed or adopted by voluntary 

consensus standards bodies. NTTAA directs the EPA to provide 

Congress, through OMB, explanations when the Agency decides not 

to use available and applicable voluntary consensus standards. 

This proposed rulemaking does not involve the use of any 

new technical standards. Therefore, the EPA is not considering 

the use of any voluntary consensus standards. 

J. Executive Order 12898: Federal Actions to Address 

Environmental Justice in Minority Populations and Low-Income 

Populations

Executive Order 12898 (59 FR 7629, February 16, 1994) 

establishes federal executive policy on environmental justice. 

Its main provision directs federal agencies, to the greatest 

extent practicable and permitted by law, to make environmental 
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Page 79 of 125 

justice part of their mission by identifying and addressing, as 

appropriate, disproportionately high and adverse human health or 

environmental effects of their programs, policies, and 

activities on minority populations and low-income populations in 

the United States. 

The EPA has determined that these proposed rule amendments 

will not have disproportionately high and adverse human health 

or environmental effects on minority or low-income populations 

because the amendments do not affect the level of protection 

provided to human health or the environment. This is because the 

proposed amendments address information collection and reporting 

and verification procedures. 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release 

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Proposed Rule Amendments and Confidentiality Determinations 

for Certain Data Elements Required under the 

Mandatory Greenhouse Gas Reporting Rule 

Page 80 of 125 

List of Subjects 40 CFR Part 98

Environmental protection, Administrative practice and 

procedure, Greenhouse gases, Reporting and recordkeeping 

requirements. 

Dated: 

 

Bob Perciasepe, 

Acting Administrator. 
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Page 81 of 125 

For the reasons stated in the preamble, title 40, chapter 

I, of the Code of Federal Regulations is proposed to be amended 

as follows: 

PART 98—[AMENDED] 

1. The authority citation for part 98 continues to read 

as follows: 

Authority: 42 U.S.C. 7401, et seq. 

Subpart A—[AMENDED] 

2. Section 98.3 is amended by revising paragraphs 

(c)(4)(vii), (d)(3)(v), (g) introductory text, and (g)(2)(i) to 

read as follows: 

§ 98.3 What are the general monitoring, reporting, recordkeeping 

and verification requirements of this part. 

* * * * * 

(c) * * * 

(4) * * * 

(vii) The owner or operator of a facility is not required 

to report the data elements specified in Table A-6 to this 

subpart for calendar years 2010 through 2011 until March 31, 

2013. The owner or operator of a facility is not required to 

report the data elements specified in Table A-7 to this subpart 

for calendar years 2010 through 2013 until March 31, 2015. Data 

elements specified in Table A-7 to this subpart for calendar 
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Page 82 of 125 

years 2010 through 2013 must be submitted as part of the annual 

report for reporting year 2014. 

* * * * * 

(d) * * * 

(3) * * * 

(v) For each combustion unit that is connected to a device 

that has been granted access by the Public Utilities Commission 

to deliver power to the local or regional power grid (e.g., 

electricity generators excluding generators connected to 

combustion units subject to subpart D of this part), and for 

which the combined nameplate capacity for all such devices at 

the facility is greater than or equal to 1 megawatt electric, 

report any facility operating data or process information used 

for the GHG emission calculations. 

(g) Recordkeeping. An owner or operator that is required to 

report GHGs under this part must keep records as specified in 

this paragraph. Except as otherwise provided in this paragraph, 

retain all required records for at least 3 years from the date 

of submission of the annual GHG report for the reporting year in 

which the record was generated. The records shall be kept in an 

electronic or hard-copy format (as appropriate) and recorded in 

a form that is suitable for expeditious inspection and review. 

If a reporter is required under § 98.5(b) to use software 
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specified by the Administrator to enter data to calculate the 

reported GHGs, all records required under Part 98 must be 

retained by the reporter for 5 years from the date of submission 

of the annual GHG report for the reporting year in which the 

record was generated. Upon request by the Administrator, the 

records required under this section must be made available to 

EPA. Records may be retained off site if the records are readily 

available for expeditious inspection and review. For records 

that are electronically generated or maintained, the equipment 

or software necessary to read the records shall be made 

available, or, if requested by EPA, electronic records shall be 

converted to paper documents. You must retain the following 

records, in addition to those records prescribed in each 

applicable subpart of this part: 

* * * * * 

(2) * * * 

(i) The GHG emissions calculations and methods used. For 

data required by section 98.5(b) to be entered into the software 

specified by the Administrator, maintain the entered data in the 

format generated by the software specified by the Administrator. 

* * * * * 

3. Section 98.5 is revised to read as follows: 

§ 98.5 How is the report submitted?
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(a) Each GHG report and certificate of representation for a 

facility or supplier must be submitted electronically in 

accordance with the requirements of § 98.4 and in a format 

specified by the Administrator. 

(b) For reporting year 2014 and thereafter, you must enter 

into software specified by the Administrator all of the data 

used to calculate the reported GHGs for the following subparts: 

C, E, F, G, H, K, L, N, O, P, Q, R, S, U, V, X, Y, Z, AA, BB, 

CC, EE, GG, II, TT. 

4. Table A-7 is revised to read as follows: 

Table A–7 to Subpart A of Part 98—Data Elements That Are Inputs 

to Emission Equations and for Which the Reporting Deadline Is 

March 31, 2015 

Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which 

reporting date is March 31, 2015 

(“All” means all data elements in 

the cited paragraph are not required 

to be reported until March 31, 2015) 

A 98.3(d)(3)(v) All. 

C 98.36(b)(9)(iii) Only estimate of the heat input.1

C 98.36(c)(2)(ix) Only estimate of the heat input from 

each type of fuel listed in Table C–

2.1

C 98.36(e)(2)(i) All.1

C 98.36(e)(2)(ii)(A) All.1

C 98.36(e)(2)(ii)(C) Only HHV value for each calendar 

month in which HHV determination is 

required.1

C 98.36(e)(2)(ii)(D) All.1

C 98.36(e)(2)(iv)(A) All.1
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which 

reporting date is March 31, 2015 

(“All” means all data elements in 

the cited paragraph are not required 

to be reported until March 31, 2015) 

C 98.36(e)(2)(iv)(C) All.1

C 98.36(e)(2)(iv)(F) All.1

C 98.36(e)(2)(ix)(D) All.1

C 98.36(e)(2)(ix)(E) All.1

C 98.36(e)(2)(ix)(F) All.1

E 98.56(g) All. 

E 98.56(h) All. 

E 98.56(j)(4) All. 

E 98.56(j)(5) All. 

E 98.56(j)(6) All. 

E 98.56(l) All. 

H 98.86(b)(11) All. 

H 98.86(b)(13) Name of raw kiln feed or raw 

material. 

L 98.126(b)(10) All. 

L 98.126(b)(11) All. 

L 98.126(b)(12) All. 

N 98.146(b)(6) All. 

O 98.156(d)(2) All. 

O 98.156(d)(3) All. 

O 98.156(d)(4) All. 

Q 98.176(b) If you determined CO2 emissions using 

the site-specific emission factor 

method in §98.173(b)(2) based on the 

total quantity of raw material feed 

(metric tons of CO2 per metric ton 

of raw material feed), only annual 

quantity taconite pellets, coke, 

iron, and raw steel. 
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which 

reporting date is March 31, 2015 

(“All” means all data elements in 

the cited paragraph are not required 

to be reported until March 31, 2015) 

Q 98.176(f)(1) All. 

U 98.216(e)(2) All. 

V 98.226(i) All. 

V 98.226(j) All. 

V 98.226(m)(4) All. 

V 98.226(m)(5) All. 

V 98.226(m)(6) All. 

V 98.226(p) All. 

W 98.236(c)(1)(i) All. 

W 98.236(c)(1)(ii) All. 

W 98.236(c)(1)(iii) All. 

W 98.236(c)(2)(i) All. 

W 98.236(c)(3)(i) All. 

W 98.236(c)(3)(ii) All. 

W 98.236(c)(3)(iii) All. 

W 98.236(c)(4)(i)(A) All. 

W 98.236(c)(4)(i)(B) All. 

W 98.236(c)(4)(i)(C) All. 

W 98.236(c)(4)(i)(D) All. 

W 98.236(c)(4)(i)(E) All. 

W 98.236(c)(4)(i)(F) All. 

W 98.236(c)(4)(i)(G) All. 

W 98.236(c)(4)(i)(H) All. 

W 98.236(c)(4)(ii)(A) All. 

W 98.236(c)(5)(iii) All. 

W 98.236(c)(5)(iv) All. 
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which 

reporting date is March 31, 2015 

(“All” means all data elements in 

the cited paragraph are not required 

to be reported until March 31, 2015) 

W 98.236(c)(5)(v) All. 

W 98.236(c)(6)(i)(B) All. 

W 98.236(c)(6)(i)(D) All. 

W 98.236(c)(6)(i)(E) All. 

W 98.236(c)(6)(i)(F) All. 

W 98.236(c)(6)(ii)(A) All. 

W 98.236(c)(6)(ii)(B) All. 

W 98.236(c)(7)(i) All. 

W 98.236(c)(8)(i)(B) All. 

W 98.236(c)(8)(i)(C) All. 

W 98.236(c)(8)(i)(F) All. 

W 98.236(c)(8)(ii)(A) All. 

W 98.236(c)(8)(ii)(D) All. 

W 98.236(c)(8)(iii)(A) All. 

W 98.236(c)(8)(iii)(D) All. 

W 98.236(c)(8)(iii)(E) All. 

W 98.236(c)(10)(ii) All. 

W 98.236(c)(10)(iii) All. 

W 98.236(c)(11)(ii) All. 

W 98.236(c)(12)(ii) All. 

W 98.236(c)(12)(iii) All. 

W 98.236(c)(12)(v) All. 

W 98.236(c)(13)(i)(B) All. 

W 98.236(c)(13)(i)(E) All. 

W 98.236(c)(13)(i)(F) All. 

W 98.236(c)(13)(ii)(A) All. 
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which 

reporting date is March 31, 2015 

(“All” means all data elements in 

the cited paragraph are not required 

to be reported until March 31, 2015) 

W 98.236(c)(13)(ii)(B) All. 

W 98.236(c)(13)(iii)(A) All. 

W 98.236(c)(13)(iii)(B) All. 

W 98.236(c)(13)(v)(A) All. 

W 98.236(c)(14)(i)(B) All. 

W 98.236(c)(14)(ii)(A) All. 

W 98.236(c)(14)(ii)(B) All. 

W 98.236(c)(14)(iii)(A) All. 

W 98.236(c)(14)(iii)(B) All. 

W 98.236(c)(14)(v)(A) All. 

W 98.236(c)(15)(i)(A) All. 

W 98.236(c)(15)(i)(B) All. 

W 98.236(c)(15)(ii)(A) All. 

W 98.236(c)(15)(ii)(B) All. 

W 98.236(c)(16)(i) All. 

W 98.236(c)(16)(ii) All. 

W 98.236(c)(16)(iii) All. 

W 98.236(c)(16)(iv) All. 

W 98.236(c)(16)(v) All. 

W 98.236(c)(16)(vi) All. 

W 98.236(c)(16)(vii) All. 

W 98.236(c)(16)(viii) All. 

W 98.236(c)(16)(ix) All. 

W 98.236(c)(16)(x) All. 

W 98.236(c)(16)(xi) All. 

W 98.236(c)(16)(xii) All. 
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which 

reporting date is March 31, 2015 

(“All” means all data elements in 

the cited paragraph are not required 

to be reported until March 31, 2015) 

W 98.236(c)(16)(xiii) All. 

W 98.236(c)(16)(xiv) All. 

W 98.236(c)(17)(ii) All. 

W 98.236(c)(17)(iii) All. 

W 98.236(c)(17)(iv) All. 

W 98.236(c)(18)(i) All. 

W 98.236(c)(18)(ii) All. 

W 98.236(c)(19)(iv) All. 

W 98.236(c)(19)(vii) All. 

Y 98.256(h)(5) Only value of the correction. 

Y 98.256(k)(4) Only mole fraction of methane in 

coking gas. 

Y 98.256(n)(3) All (if used in Equation Y–21 to 

calculate emissions from equipment 

leaks). 

Y 98.256(o)(4)(vi) Only tank-specific methane 

composition data and gas generation 

rate data. 

AA 98.276(e) All. 

CC 98.296(b)(10)(i) All. 

CC 98.296(b)(10)(ii) All. 

CC 98.296(b)(10)(iii) All. 

CC 98.296(b)(10)(iv) All. 

CC 98.296(b)(10)(v) All. 

CC 98.296(b)(10)(vi) All. 

II 98.356(d)(2) All (if conducting weekly sampling).

II 98.356(d)(3) All (if conducting weekly sampling).

II 98.356(d)(4) Only weekly average temperature (if 
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Subpart 

Rule citation 

(40 CFR part 98) 

Specific data elements for which 

reporting date is March 31, 2015 

(“All” means all data elements in 

the cited paragraph are not required 

to be reported until March 31, 2015) 

conducting weekly sampling). 

II 98.356(d)(5) Only weekly average moisture content 

(if conducting weekly sampling). 

II 98.356(d)(6) Only weekly average pressure (if 

conducting weekly sampling). 1

 Required to be reported only by combustion units subject to 

subpart C of part 98 that meet the following criteria: (1) the 

combustion unit is connected to a device that has been granted 

access by the Public Utilities Commission to deliver power to 

the local or regional electric power grid (e.g., electricity 

generators excluding generators connected to combustion units 

subject to subpart D of this part); and (2) the combined 

nameplate capacity (for all such devices at the facility) is 

greater than or equal to 1 megawatt electric. 

Subpart C—[AMENDED] 

5. Section 98.36 is amended by: 

a. Revising paragraph (b)(9)(iii). 

b. Adding paragraph (b)(9)(iv). 

c. Revising paragraph (c)(2)(ix). 

d. Adding paragraph (c)(2)(x). 

e. Revising paragraphs (e)(2)(i), (e)(2)(ii)(A), 

(e)(2)(ii)(C), and (e)(2)(ii)(D). 

f. Adding paragraph (e)(2)(ii)(E). 

g. Revising paragraphs (e)(2)(iv)(A), (e)(2)(iv)(C), 

(e)(2)(iv)(F), and (e)(2)(ix)(D) through (F). 

h. Adding paragraph (f). 
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§ 98.36 Data reporting requirements.

* * * * * 

(b) * * * 

(9) * * * 

(iii) The annual CH4 and N2O emissions for each type of fuel 

listed in Table C–2 of this subpart that was combusted in the 

unit during the report year, expressed in metric tons of each 

gas and in metric tons of CO2e. 

(iv) For each combustion unit that is connected to a device 

that has been granted access by the Public Utilities Commission 

to deliver power to the local or regional power grid (e.g., 

electricity generators excluding generators connected to 

combustion units subject to subpart D of this part), and for 

which the combined nameplate capacity for all such devices at 

the facility is greater than or equal to 1 megawatt electric, 

you must also report an estimate of the heat input from each 

type of fuel listed in Table C–2 of this subpart that was 

combusted in the unit during the report year. 

* * * * * 

(c) * * * 

(2) * * * 

(ix) For each type of fuel listed in Table C–2 of this 

subpart that was combusted during the report year in the units 
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sharing the common stack or duct during the report year, the 

annual CH4 and N2O mass emissions from the units sharing the 

common stack or duct, expressed in metric tons of each gas and 

in metric tons of CO2 e. 

 (x) For each combustion unit that is connected to a device 

that has been granted access by the Public Utilities Commission 

to deliver power to the local or regional power grid (e.g., 

electricity generators excluding generators connected to 

combustion units subject to subpart D of this part), and for 

which the combined nameplate capacity for all such devices at 

the facility is greater than or equal to 1 megawatt electric, 

you must also report an estimate of the heat input from each 

type of fuel listed in Table C–2 of this subpart that was 

combusted during the report year in the units sharing the common 

stack or duct during the report year. 

* * * * * 

(e) * * * 

(2) * * * 

(i) For the Tier 1 Calculation Methodology, for each 

combustion unit that is connected to a device that has been 

granted access by the Public Utilities Commission to deliver 

power to the local or regional power grid (e.g., electricity 

generators excluding generators connected to combustion units 
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subject to subpart D of this part), and for which the combined 

nameplate capacity for all such devices at the facility is 

greater than or equal to 1 megawatt electric, report the total 

quantity of each type of fuel combusted in the unit or group of 

aggregated units (as applicable) during the reporting year, in 

short tons for solid fuels, gallons for liquid fuels and 

standard cubic feet for gaseous fuels, or, if applicable, therms 

or mmBtu for natural gas. 

(ii) * * * 

(A) For each combustion unit that is connected to a device 

that has been granted access by the Public Utilities Commission 

to deliver power to the local or regional power grid (e.g., 

electricity generators excluding generators connected to 

combustion units subject to subpart D of this part), and for 

which the combined nameplate capacity for all such devices at 

the facility is greater than or equal to 1 megawatt electric, 

report the total quantity of each type of fuel combusted in the 

unit or group of aggregated units (as applicable) during each 

month of the reporting year. Express the quantity of each fuel 

combusted during the measurement period in short tons for solid 

fuels, gallons for liquid fuels, and scf for gaseous fuels. 

* * * * * 
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(C) For each combustion unit that is connected to a device 

that has been granted access by the Public Utilities Commission 

to deliver power to the local or regional power grid (e.g., 

electricity generators excluding generators connected to 

combustion units subject to subpart D of this part), and for 

which the combined nameplate capacity for all such devices at 

the facility is greater than or equal to 1 megawatt electric, 

report the high heat values used in the CO2 emissions 

calculations for each type of fuel combusted during the 

reporting year, in mmBtu per short ton for solid fuels, mmBtu 

per gallon for liquid fuels, and mmBtu per scf for gaseous 

fuels. Report a HHV value for each calendar month in which HHV 

determination is required. If multiple values are obtained in a 

given month, report the arithmetic average value for the month. 

Indicate whether each reported HHV is a measured value or a 

substitute data value. 

(D) For each combustion unit that is connected to a device 

that has been granted access by the Public Utilities Commission 

to deliver power to the local or regional power grid (e.g., 

electricity generators excluding generators connected to 

combustion units subject to subpart D of this part), and for 

which the combined nameplate capacity for all such devices at 

the facility is greater than or equal to 1 megawatt electric, if 
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Equation C–2c of this subpart is used to calculate CO2 mass 

emissions, report the total quantity (i.e., pounds) of steam 

produced from MSW or solid fuel combustion during each month of 

the reporting year, and the ratio of the maximum rate heat input 

capacity to the design rated steam output capacity of the unit, 

in mmBtu per lb of steam. 

(E) For each HHV used in the CO2 emissions calculations for 

each type of fuel combusted during the reporting year, indicate 

whether the HHV is a measured value or a substitute data value. 

* * * * * 

(iv) * * * 

(A) For each combustion unit that is connected to a device 

that has been granted access by the Public Utilities Commission 

to deliver power to the local or regional power grid (e.g., 

electricity generators excluding generators connected to 

combustion units subject to subpart D of this part), and for 

which the combined nameplate capacity for all such devices at 

the facility is greater than or equal to 1 megawatt electric, 

report the quantity of each type of fuel combusted in the unit 

or group of units (as applicable) during each month of the 

reporting year, in short tons for solid fuels, gallons for 

liquid fuels, and scf for gaseous fuels. 

* * * * * 
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(C) For each combustion unit that is connected to a device 

that has been granted access by the Public Utilities Commission 

to deliver power to the local or regional power grid (e.g., 

electricity generators excluding generators connected to 

combustion units subject to subpart D of this part), and for 

which the combined nameplate capacity for all such devices at 

the facility is greater than or equal to 1 megawatt electric, 

report the carbon content and, if applicable, gas molecular 

weight values used in the emission calculations (including both 

valid and substitute data values). For each calendar month of 

the reporting year in which carbon content and, if applicable, 

molecular weight determination is required, report a value of 

each parameter. If multiple values of a parameter are obtained 

in a given month, report the arithmetic average value for the 

month. Express carbon content as a decimal fraction for solid 

fuels, kg C per gallon for liquid fuels, and kg C per kg of fuel 

for gaseous fuels. Express the gas molecular weights in units of 

kg per kg-mole. 

* * * * * 

(F) For each combustion unit that is connected to a device 

that has been granted access by the Public Utilities Commission 

to deliver power to the local or regional power grid (e.g., 

electricity generators excluding generators connected to 
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Page 97 of 125 

combustion units subject to subpart D of this part), and for 

which the combined nameplate capacity for all such devices at 

the facility is greater than or equal to 1 megawatt electric, 

report the annual average HHV, when measured HHV data, rather 

than a default HHV from Table C–1 of this subpart, are used to 

calculate CH4 and N2O emissions for a Tier 3 unit, in accordance 

with §98.33(c)(1). 

* * * * * 

(ix) * * * 

(D) For each combustion unit that is connected to a device 

that has been granted access by the Public Utilities Commission 

to deliver power to the local or regional power grid (e.g., 

electricity generators excluding generators connected to 

combustion units subject to subpart D of this part), and for 

which the combined nameplate capacity for all such devices at 

the facility is greater than or equal to 1 megawatt electric, 

report the carbon-based F-factor used in Equation C–13 of this 

subpart, for each type of fossil fuel combusted, in scf CO2 per 

mmBtu. 

(E) For each combustion unit that is connected to a device 

that has been granted access by the Public Utilities Commission 

to deliver power to the local or regional power grid (e.g., 

electricity generators excluding generators connected to 
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Page 98 of 125 

combustion units subject to subpart D of this part), and for 

which the combined nameplate capacity for all such devices at 

the facility is greater than or equal to 1 megawatt electric, 

report the annual average HHV value used in Equation C–13 of 

this subpart, for each type of fossil fuel combusted, in Btu/lb, 

Btu/gal, or Btu/scf, as appropriate. 

(F) For each combustion unit that is connected to a device 

that has been granted access by the Public Utilities Commission 

to deliver power to the local or regional power grid (e.g., 

electricity generators excluding generators connected to 

combustion units subject to subpart D of this part), and for 

which the combined nameplate capacity for all such devices at 

the facility is greater than or equal to 1 megawatt electric, 

report the total quantity of each type of fossil fuel combusted 

during the reporting year, in lb, gallons, or scf, as 

appropriate. 

* * * * * 

(f) For stationary combustion sources using the Tier 1, 

Tier 2, Tier 3, or Tier 4 Calculation Methodologies in §98.33(a) 

to quantify CO2e emissions, report: 

(1) Whether any stationary combustion units are connected 

to devices that have been granted access by the Public Utilities 

Commission to deliver power to the local or regional power grid. 
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(2) For all stationary combustion units that meet the 

criteria specified in paragraph (f)(1) of this section, indicate 

whether the combined nameplate capacity for all associated 

devices that are connected to the local or regional power grid 

(excluding generators that are connected to combustion units 

that are subject to subpart D of this part) is greater than or 

equal to than 1 megawatt. 

Subpart E—[AMENDED] 

6. Section 98.56 is amended by: 

a. Revising the introductory text. 

b. Removing and reserving paragraphs (b), (c), (j)(1), 

and (j)(3). 

c. Adding paragraphs (m) and (n). 

§ 98.56 Data reporting requirements.

In addition to the information required by §98.3(c), each 

annual report must contain the information specified in 

paragraphs (a) through (n) of this section at the facility 

level. 

* * * * * 

(m) Annual quantity of cyclohexane fed to all production 

lines combined (metric tons). 

(n) Annual percent N2O emission reduction for all production 

units combined. 
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* * * * * 

Subpart F—[AMENDED] 

7. Section 98.66 is amended by: 

a. Removing and reserving paragraphs (a) and (c)(2). 

b. Revising paragraph (c)(3), (e)(1), and (f)(1). 

c. Removing and reserving paragraph (g). 

§ 98.66 Data reporting requirements.

* * * * * 

(c) * * * 

(2) [Reserved] 

(3) The last date when the smelter-specific-slope 

coefficients (or overvoltage emission factors) were measured. 

* * * * * 

(e) * * * 

(1) Annual anode consumption if using the method in 

§98.63(g). 

* * * * * 

(f) * * * 

(1) Annual paste consumption if using the method in 

§98.63(g). 

* * * * * 

Subpart G—[AMENDED] 

8. Section 98.76 is amended by: 
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a. Revising the introductory text. 

b. Removing and reserving paragraph (b)(2) and paragraphs 

(b)(7) through (11). 

c. Adding paragraphs (c) and (d). 

§ 98.76 Data reporting requirements.

In addition to the information required by §98.3(c), each 

annual report must contain the information specified in 

paragraphs (a) through (d) of this section, as applicable for 

each ammonia manufacturing process unit. 

* * * * * 

(c) Annual ammonia production (metric tons). 

(d) Annual methanol production (metric tons), if this 

quantity is not reported under subpart X of Part 98. 

Subpart H—[AMENDED] 

9. Section 98.86 is amended by: 

a. Removing and reserving paragraphs (b)(2), (b)(5), 

(b)(6), (b)(8), (b)(10), and (12). 

b. Revising paragraphs (b)(13) and (15). 

c. Adding paragraphs (b)(16) through (18). 

§ 98.86 Data reporting requirements.

* * * * * 

(b) * * * 

(12) [Reserved] 
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(13) Name of raw kiln feed or raw material. 

* * * * * 

(15) Method used to determine the monthly clinker 

production from each kiln. 

(16) Annual clinker production (metric tons). 

(17) Annual average clinker CO2 emission factor for the 

facility, averaged across all kilns (metric tons CO2/metric ton 

clinker produced). 

(18) Annual average CKD CO2 emission factor for the 

facility, averaged across all kilns (metric tons CO2/metric ton 

CKD produced). 

Subpart K—[AMENDED] 

10. Section 98.116 is amended by: 

a. Removing and reserving paragraphs (b), (e)(4), and 

(e)(5). 

b. Revising paragraph (e)(6). 

§ 98.116 Data reporting requirements.

* * * * * 

(e) * * * 

(5) [Reserved] 

(6) List the method used for the determination of carbon 

content for each material included for the calculation of annual 
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Page 103 of 125 

process CO2 emissions for each EAF (e.g., supplier provided 

information, analyses of representative samples you collected). 

* * * * * 

Subpart L—[AMENDED] 

11. Section 98.126 is amended by: 

a. Revising paragraph (b)(1). 

b. Removing and reserving paragraph (b)(2). 

c. Revising paragraphs (b)(6) and (b)(8)(i) through (iv). 

d. Removing and reserving paragraphs (b)(8)(v) and 

(b)(9). 

e. Revising paragraph (c)(1). 

f. Removing and reserving paragraph (c)(2). 

g. Revising paragraph (d). 

h. Removing and reserving paragraphs (f)(1), (g)(1), and 

(h)(2). 

§ 98.126 Data reporting requirements.

* * * * * 

(b) * * * 

(1) If you calculate the relative and absolute errors under 

98.123(b)(1), the absolute and relative errors calculated under 

paragraph §98.123(b)(1). 

(2) [Reserved] 

* * * * * 
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(6) The chemical formula of each fluorine-containing 

reactant that is fed into the process (metric tons). 

* * * * * 

(8) * * * 

(i) The chemical formula of each fluorine-containing 

product that is removed from the process and fed into the 

destruction device (metric tons). 

(ii) The chemical formula of each fluorine-containing byproduct that is removed from the process and fed into the 

destruction device (metric tons). 

(iii) The chemical formula of each fluorine-containing 

reactant that is removed from the process and fed into the 

destruction device (metric tons). 

(iv) The chemical formula of each fluorine-containing byproduct that is removed from the process and recaptured (metric 

tons). 

(v) [Reserved] 

(9) [Reserved] 

* * * * * 

(c) * * * 

(1) The identity of the process activity used to estimate 

emissions (e.g., product produced or reactant consumed). 

(2) [Reserved] 
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* * * * * 

(d) Reporting for missing data. Where missing data have 

been estimated pursuant to §98.125, you must report the reason 

the data were missing, the length of time the data were missing, 

and the method used to estimate the missing data. 

* * * * * 

Subpart N—[AMENDED] 

12. Section 98.146 is amended by revising paragraph (b)(2) 

and removing and reserving paragraph (b)(4) to read as follows: 

§ 98.146 Data reporting requirements.

* * * * * 

(b) * * * 

(2) Annual quantity of each carbonate-based raw material 

charged (tons) to all furnaces combined. 

* * * * * 

Subpart O—[AMENDED] 

13. Section 98.156 is amended by: 

a. Removing and reserving paragraphs (a)(2), (a)(7) 

through (10), (b)(1), and (b)(2). 

b. Revising (d) introductory paragraph. 

c. Removing and reserving paragraphs (d)(1), (d)(5), and 

(e)(1). 

§ 98.156 Data reporting requirements.
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* * * * * 

(d) If the HFC–23 concentration measured pursuant to 

§98.154(l) is greater than that measured during the performance 

test that is the basis for the destruction efficiency (DE), the 

facility shall report the following: 

(1) [Reserved] 

* * * * * 

Subpart P—[AMENDED] 

14. Section 98.166 is amended by: 

a. Revising the introductory paragraph. 

b. Removing and reserving paragraphs (b)(2), (b)(5), and 

(b)(6). 

c. Adding paragraphs (b)(7) and (e). 

§ 98.166 Data reporting requirements.

In addition to the information required by §98.3(c), each 

annual report must contain the information specified in 

paragraphs (a) or (b) of this section, as appropriate, and 

paragraphs (c) through (e) of this section: 

* * * * * 

(b) * * * 

(5) [Reserved] 

(6) [Reserved] 
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(7) Name and annual quantity (metric tons) of each carboncontaining fuel and feedstock. 

* * * * * 

(e) Annual methanol production (metric tons), if this 

quantity is not reported under subpart X of Part 98. 

Subpart Q—[AMENDED] 

15. Section 98.176 is amended by: 

a. Revising paragraph (b). 

b. Removing and reserving paragraphs (e)(1), (e)(3), 

(e)(4), (f)(2) through (4), and (g). 

c. Adding paragraph (e)(6). 

§ 98.176 Data reporting requirements.

* * * * * 

(b) If a CEMS is used to measure CO2 emissions or if you 

determined CO2 emissions using the site-specific emission factor 

method in §98.173(b)(2) based on the total quantity of raw 

material feed (metric tons of CO2 per metric ton of raw material 

feed), then you must report the annual production quantity for 

the production unit (in metric tons) for taconite pellets, coke, 

sinter, iron, and raw steel. 

* * * * * 

(e) * * * 
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(6) The information specified in paragraphs (e)(6)(i) 

through (vi) of this section aggregated for all process units 

for which CO2 emissions were determined using the mass balance 

method in §98.173(b)(1), except as provided in §98.174(b)(4). 

(i) The annual mass (metric tons) of all gaseous, liquid, 

and solid fuels (combined) used in process units for which CO2

emissions were determined using Equations Q-1 through Q-7 of 

this section, calculated as specified in Equation Q-9 of this 

section. 

ݑܨ݈݁ 	ൌ ቀ∑ ܨ௚, ∗ 	௜ெௐ೔

ெ௏஼

௡

௜ୀଵ ∗ 0.001 ൅ ܨ௟, ∗ ௜ߩ௟, ∗ ௜0.001	 ൅ ܨ௦,௜ቁ (Eq. Q-9) 

Where: 

Fuel = Annual mass of all gaseous, liquid, and solid 

fuels used in process units (metric tons). 

n = Number of process units where fuel is used. 

Fg,i = Annual volume of gaseous fuel combusted (“(Fg)” in 

Equations Q-1, Q-4 and Q-7 of this section) for 

each process (scf). 

MWi = Molecular weight of gaseous fuel used in each 

process (kg/kg-mole). 

MVC = Molar volume conversion factor at standard 

conditions, as defined in §98.6. Use 849.5 scf 

per kg mole if you select 68 °F as standard 

temperature and 836.6 scf per kg mole if you 

select 60 °F as standard temperature. 

Fl,i = Annual volume of the liquid fuel combusted (“(Fl)” 

included in Equation Q-1 of this section) for 

each process unit (gallons). 

Fs,i = Annual mass of the solid fuel combusted (“(Fs)” in 

Equation Q-1 of this section) for each process 

unit (metric tons). 
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ρl,i = Density of the liquid fuel (kg/gallon). 

0.001 = Conversion factor from kg to metric tons. 

(ii) The annual mass (metric tons) of all non-fuel material 

inputs (combined) specified in Equations Q-1 through Q-7 of this 

section, calculated as specified in Equation Q-10 of this 

section. 

௡௜݈݁݁ݐܵ ൅ ݀݁݋ݎݐ݈݁ܿܧ ൅ ݁݁݀ܨ ൅ ݈ܽ݋ܥ ൅ ݊݋ܾݎܽܥ ൅ ݔݑ݈ܨ ൅ ݌ܽݎܵܿ ൅ ݊݋ݎܫ ൅ ܱ ෍൭ ൌ ܫܨܰ

௡

௜ୀଵ

൱ݎ݄݁ݐܱ ൅ ݁ݎܱ ൅

(Eq. Q-10) 

Where: 

NFI = Annual mass of all non-fuel inputs (to all 

process unit types) specified in Equations Q-1 

through Q-7 of this section (metric tons). 

n = Number of process units, all process types. 

O = Annual mass of greenball (taconite) pellets fed 

to the taconite furnace(s) (metric tons). 

Iron = Annual mass of molten iron charged to the basic 

oxygen furnace(s) plus annual mass of direct 

reduced iron charged to the EAF(s) (metric tons). 

Scrap = Annual mass of ferrous scrap charged to the basic 

oxygen furnace(s) and EAF(s) (metric tons). 

Flux = Annual mass of flux materials charged to the 

basic oxygen furnace(s) and EAF(s) (metric tons). 

Carbon = Annual mass of carbonaceous materials (e.g., 

coal, coke) charged to the basic oxygen 

furnace(s), EAF(s), and direct reduction 

furnace(s) (metric tons). 

Coal = Annual mass of coal charged to the coke oven 

battery(s) (metric tons). 

Feed = Annual mass of sinter feed material charged to 

the sinter process(es) (metric tons). 

Electrode = Annual mass of carbon electrode consumed in the 

EAF(s) (metric tons). 
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Steelin = Annual mass of molten steel charged to the 

decarburization vessels (metric tons). 

Ore = Annual mass of iron ore or iron ore pellets fed 

to the direct reduction furnace(s) (metric tons). 

Other = Annual mass of other materials charged to the 

direction reduction furnace(s) (metric tons). 

(iii) The annual mass (metric tons) of all solid and liquid 

products and byproducts (combined) specified in Equations Q-1 

through Q-7 of this section, calculated as specified in Equation 

Q-11 of this section. 

௡∑ሺ ൌ ݏݐܿݑ݀݋ݎܲ

 (-11Q .ሺEq			ሻ ܯܰ ൅ ݊݋ݎܫ ൅ ݎ݁ݐܵ݅݊ ൅ ݇݁݋ܥ ൅ ݈ܵܽ݃ ൅ ௨௧௢݈݁݁ݐܵ ൅ ܴ ൅ ܲ ୀଵ௜

Where: 

Products = Annual mass of all solid and liquid products and 

by-products (from all process units) specified in 

Equations Q-1 through Q-7 of this section (metric 

tons). 

n = Number of process units, all types. 

P = Annual mass of fired pellets produced by the 

taconite furnace (metric tons). 

R = Annual mass of air pollution control residue from 

all process units (metric tons). 

Steelout = Annual mass of steel produced by the basic oxygen 

furnace(s), EAF(s) and decarburization vessel(s) 

(metric tons). 

Slag = Annual mass of slag produced by the basic oxygen 

furnace(s) and EAF(s) (metric tons). 

Coke = Annual mass of coke produced by the non-recovery 

coke batteries (metric tons). 

Sinter = Annual mass of sinter produced from the sinter 

process(es) (metric tons). 

Iron = Annual mass of iron produced from the direct 

reduction furnace (metric tons). 
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NM = Annual mass of non-metallic materials produced by 

the direct reduction furnace (metric tons). 

(iv) The weighted average carbon content of all gaseous, 

liquid, and solid fuels (combined) included in Equation Q-9 of 

this section, calculated as specified in Equation Q-12 of this 

section. 

ܨܥ௔௩௚ ൌ ቀ	∑ ி೒,೔	∗

ಾೈ೔

ಾೇ಴

೙

೔సభ ∗஼೒೑,೔∗଴.଴଴ଵାி೗,೔∗஼೗೑,೔∗଴.଴଴ଵା	ிೞ,೔∗஼ೞ೑	ቁ

ி௨௘௟ 		 (Eq. Q-12) 

Where: 

CFavg = Weighted average carbon content of all gaseous, 

liquid, and solid fuels included in Equation Q-9 

of this section (weight fraction). 

n = Number of gaseous, liquid, and solid fuel input 

to each process unit as used in Equation Q-9. 

Cgf,i = Average carbon content of the gaseous fuel used 

in each process, from the fuel analysis results 

(kg C per kg of fuel). 

Clf,i = Carbon content of the liquid fuel used in each 

process, from the fuel analysis results (kg C per 

gallon of fuel. 

Csf = Carbon content of the solid fuel used in each 

process, from the fuel analysis (expressed as a 

decimal fraction, e.g., 95% = 0.95). 

Fuel = Annual mass of all gaseous, liquid, and solid 

fuels used in process units (metric tons), as 

calculated in Equation Q-9 of this section. 

(v) The weighted average carbon content of all non-fuel 

inputs to all process units (combined) included in Equation Q-10 

of this section, calculated as specified in Equation Q-13 of 

this section. 
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ܫܥ௔௩௚ ൌ ൫∑ ேிூ೔∗஼ಿಷ಺೔ ೙

೔సభ ൯	

ேிூ 						 (Eq. Q-13) 

Where: 

CIavg = Weighted average carbon content of all non-fuel 

inputs to all process units included in Equation 

Q-10 of this section (weight fraction). 

n = Number of non-fuel inputs to all process units as 

used in Equation Q-10. 

NFIi = Annual mass of each non-fuel input used in 

Equation Q-10 (metric tons). 

CNFIi = Average carbon content of each non-fuel input 

used in Equation Q-10 (expressed as a decimal 

fraction). 

NFI = Total of all non-fuel inputs to all process units 

(metric tons). 

(vi) The weighted average carbon content of all solid and 

liquid products and byproducts from all process units (combined) 

included in Equation Q-11 of this section, calculated as 

specified in Equation Q-14 of this section. 

ܥܲ௔௩௚ ൌ 	൫∑ ௉௥௢ௗ௨௖௧೔∗஼ು೔ ೙

೔సభ ൯

௉௥௢ௗ௨௖௧௦ (Eq. Q-14) 

Where: 

CPavg = Weighted average carbon content of all solid and 

liquid products and byproducts from all process 

units (weight fraction). 

n = Number of products and byproducts from each 

process unit as used in Equation Q-11. 

Producti = Annual mass of each product or byproduct used in 

Equation Q-11 (metric tons). 

Cp,i = Average carbon content of each product or 

byproduct used in Equation Q-11 (expressed as a 

decimal fraction). 
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Products = Mass of all products and byproducts from all 

process units, calculated in Equation Q-11 of 

this section (metric tons). 

* * * * * 

Subpart R—[AMENDED] 

16. Section 98.186 is amended by: 

a. Removing and reserving paragraphs (b)(6) and (b)(7). 

b. Revising paragraph (b)(8). 

§ 98.186 Data reporting procedures.

* * * * * 

(b) * * * 

(6) [Reserved] 

(7) [Reserved] 

(8) List the method used for the determination of carbon 

content for each material used for the calculation of annual 

process CO2 emissions using Equation R–1 of this subpart for each 

smelting furnace (e.g., supplier provided information, analyses 

of representative samples you collected). 

* * * * * 

Subpart S—[AMENDED] 

17. Section 98.196 is amended by: 

a. Revising (b) introductory paragraph. 

b. Removing and reserving paragraphs (b)(2), (b)(3), 

(b)(5), (b)(6), (b)(8), (b)(10), (b)(11), and (b)(12). 
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c. Adding paragraph (b)(18). 

§ 98.196 Data reporting requirements.

* * * * * 

(b) If a CEMS is not used to measure CO2 emissions, then you 

must report the information listed in paragraphs (b)(1) through 

(18) of this section. 

* * * * * 

(18) Annual quantity (metric tons) of lime product sold, by 

type. 

Subpart U—[AMENDED] 

18. Section 98.216 is amended by removing and reserving 

paragraphs (b), (e)(1), (f)(1), and (f)(2). 

Subpart V—[AMENDED] 

19. Section 98.226 is amended by: 

a. Revising the introductory paragraph. 

b. Removing and reserving paragraphs (d), (m)(1), and 

(m)(3). 

c. Adding paragraph (q). 

§ 98.226 Data reporting requirements.

In addition to the information required by §98.3(c), each 

annual report must contain the information specified in 

paragraphs (a) through (q) of this section. 

* * * * * 
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(d) [Reserved] 

* * * * * 

(q) Annual percent N2O emission reduction for all production 

units combined. 

Subpart X—[AMENDED] 

20. Section 98.246 is amended by: 

a. Revising (a) introductory paragraph and paragraph 

(a)(4). 

b. Adding paragraphs (a)(12) and (13). 

c. Revising (b) introductory paragraph. 

d. Removing and reserving paragraphs (b)(5)(iii) and 

(b)(5)(iv). 

e. Adding paragraphs (b)(9) and (b)(10). 

§ 98.246 Data reporting requirements.

* * * * * 

(a) If you use the mass balance methodology in §98.243(c), 

you must report the information specified in paragraphs (a)(1) 

through (a)(13) of this section for each type of petrochemical 

produced, reported by process unit. 

* * * * * 

(4) The temperature (in °F) at which the gaseous feedstock 

and product volumes used in Equation X–1 of this subpart were 

determined. 
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* * * * * 

(12) Name and annual quantity (in metric tons) of each 

carbon-containing feedstock included in Equations X-1, X-2, and 

X-3 of §98.243 of this subpart. 

(13) Name and annual quantity (in metric tons) of each 

carbon-containing co-product included in Equations X-1, X-2, and 

X-3 of §98.243 of this subpart. 

(b) If you measure emissions in accordance with §98.243(b), 

then you must report the information listed in paragraphs (b)(1) 

through (b)(10) of this section. 

* * * * * 

(9) Name and annual quantity (in metric tons) of each 

carbon-containing feedstock. 

(10) Name and annual quantity (in metric tons) of each 

carbon-containing co-product. 

* * * * * 

Subpart Y—[AMENDED] 

21. Section 98.256 is amended by: 

a. Revising paragraphs (e)(6) and (e)(7) introductory 

paragraph. 

b. Removing and reserving paragraph (e)(7)(ii). 

c. Revising paragraphs (e)(9) and (e)(10). 

d. Adding paragraph (e)(11). 
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e. Revising paragraphs (f)(7) and (f)(10) through (13). 

f. Removing and reserving paragraph (h)(4). 

g. Revising paragraphs (h)(5), (i)(5), (i)(7), and 

(i)(8). 

h. Removing and reserving paragraph (j)(2). 

i. Revising paragraphs (j)(5) through (9), (k)(3), 

(k)(4), (l)(5), and (m)(3). 

j. Removing and reserving paragraphs (o)(2)(ii) and 

(o)(4)(ii) through (v). 

k. Revising paragraph (p)(2). 

§ 98.256 Data reporting requirements.

* * * * * 

(e) * * * 

(6) If you use Equation Y–1a of this subpart, an indication 

of whether daily or weekly measurement periods are used, the 

annual volume of flare gas combusted (in scf/year) and the 

annual average molecular weight (in kg/kg-mole), and annual 

average carbon content of the flare gas (in kg carbon per kg 

flare gas). 

(7) If you use Equation Y–1b of this subpart, an indication 

of whether daily or weekly measurement periods are used, the 

annual volume of flare gas combusted (in scf/year), the annual 

average CO2 concentration (volume or mole percent), the number of 
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carbon containing compounds other than CO2 in the flare gas 

stream, and for each of the carbon containing compounds other 

than CO2 in the flare gas stream: 

* * * * * 

(9) If you use Equation Y–3 of this subpart, the number of 

SSM events exceeding 500,000 scf/day. 

(10) The basis for the value of the fraction of carbon in 

the flare gas contributed by methane used in Equation Y–4 of 

this subpart. 

(11) If using Equation Y-3, report: 

(i) Annual quantity of flare gas combusted (in MMscf per 

year). 

(ii) Annual average molecular weight of flare gas combusted 

(in mmBtu per MMscf). 

(iii) Annual average carbon content of flare gas combusted 

(expressed as a decimal fraction). 

(f) * * * 

(7) If you use Equation Y–6 of this subpart, the annual 

average exhaust gas flow rate, %CO2, and %CO. 

* * * * * 

(10) If you use Equation Y–8 of this subpart, the basis for 

the value of the coke burn-off factor, annual throughput of 

unit, and the average carbon content of coke. 
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(11) Indicate whether you use a measured value, a unitspecific emission factor, or a default emission factor for CH4

emissions. If you use a unit-specific emission factor for CH4, 

report the basis for the factor. 

(12) Indicate whether you use a measured value, a unitspecific emission factor, or a default emission factor for N2O 

emissions. If you use a unit-specific emission factor for N2O, 

report the basis for the factor. 

(13) If you use Equation Y–11 of this subpart, the number 

of regeneration cycles or measurement periods during the 

reporting year and the average coke burn-off quantity per cycle 

or measurement period. 

* * * * * 

(h) * * * 

(4) [Reserved] 

(5) If you recycle tail gas to the front of the sulfur 

recovery plant, indicate whether the recycled flow rate and 

carbon content are included in the measured data under 

§98.253(f)(2) and (3). Indicate whether a correction for CO2

emissions in the tail gas was used in Equation Y–12. If so, then 

report: 

(i) The value of the correction. 
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(ii) If the following data are not used to calculate the 

recycling correction factor, report the information specified in 

paragraphs (h)(5)(ii)(A) through (C) of this section. 

(A) The annual volume of recycled tail gas (in scf/year) 

only. 

(B) The annual average mole fraction of carbon in the tail 

gas (in kg-mole C/kg-mole gas). 

(C) Indicate whether you used the default (95%) or a unit 

specific correction, and if used, report the approach used. 

* * * * * 

(i) * * * 

(5) If you use Equation Y–13 of this subpart, an indication 

of whether coke dust is recycled to the unit (e.g., all dust is 

recycled, a portion of the dust is recycled, or none of the dust 

is recycled). 

* * * * * 

(7) Indicate whether you use a measured value, a unitspecific emission factor or a default for CH4 emissions. If you 

use a unit-specific emission factor for CH4, report the basis for 

the factor. 

(8) Indicate whether you use a measured value, a unitspecific emission factor, or a default emission factor for N2O 
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emissions. If you use a unit-specific emission factor for N2O, 

report the basis for the factor. 

(j) * * * 

(5) If you use Equation Y–14 of this subpart, the basis for 

the CO2 emission factor used. 

(6) If you use Equation Y–15 of this subpart, the basis for 

the CH4 emission factor used. 

(7) If you use Equation Y–16 of this subpart, the basis for 

the carbon emission factor used. 

(8) If you use Equation Y–16b of this subpart, the basis 

for the CO2 emission factor used and the basis for the carbon 

emission factor used. 

(9) If you use Equation Y–17 of this subpart, the basis for 

the CH4 emission factor used. 

(k) * * * 

(3) The total number of delayed coking units at the 

facility; the total number of delayed coking drums at the 

facility; and, for each coke drum or vessel, the typical drum 

outage (i.e. the unfilled distance from the top of the drum, in 

feet). 

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

dimensions, the number of coking drums in the set, and the mole 
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Page 122 of 125 

fraction of methane in coking gas (in kg-mole CF4/kg-mole gas, 

wet basis). 

* * * * * 

(l) * * * 

(5) The annual volumetric flow discharged to the atmosphere 

(in scf), and an indication of the measurement or estimation 

method, annual average mole fraction of each GHG above the 

concentration threshold or otherwise required to be reported and 

an indication of the measurement or estimation method, and for 

intermittent vents, the number of venting events and the 

cumulative venting time. 

(m) * * * 

(3) For uncontrolled blowdown systems reporting under 

§98.253(k), the basis for the value of the methane emission 

factor used for uncontrolled blowdown systems. 

* * * * * 

(p) * * * 

(2) The types of materials loaded that have an equilibrium 

vapor-phase concentration of methane of 0.5 volume percent or 

greater, and the type of vessel (barge, tanker, marine vessel, 

etc.) in which each type of material is loaded. 

* * * * * 

Subpart Z—[AMENDED] 
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22. Section 98.266 is amended by removing and reserving 

paragraphs (f)(5) and (f)(6). 

Subpart AA—[AMENDED] 

23. Section 98.276 is amended by: 

a. Revising the introductory paragraph. 

b. Removing and reserving paragraph (b). 

c. Revising paragraph (c). 

d. Removing and reserving paragraphs (d), (f), (g), (h) 

and (i). 

e. Adding paragraphs (l) and (m). 

§ 98.276 Data reporting requirements.

In addition to the information required by §98.3(c) and the 

applicable information required by §98.36, each annual report 

must contain the information in paragraphs (a) through (m) of 

this section as applicable: 

* * * * * 

(b) [Reserved] 

(c) Basis for determining the annual mass of the spent 

liquor solids combusted (whether based on T650 om-05 Solids 

Content of Black Liquor, TAPPI (incorporated by reference, see 

§98.7) or an online measurement system). 

(d) [Reserved] 

* * * * * 
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(l) For each pulp mill lime kiln, report the information 

specified in paragraphs (l)(1) and (2) of this section. 

(1) The quantity of calcium oxide (CaO) produced (metric 

tons). 

(2) The percent of annual heat input, individually for each 

fossil fuel type. 

(m) For each chemical recovery furnace and each chemical 

recovery combustion unit for which you are not using Equation C2c to calculate CO2 emissions, report the information specified 

in paragraphs (m)(1) and (2) of this section. 

(1) The annual mass of steam generated (lb steam), 

individually for each fossil fuel type and for spent liquor 

solids. 

(2) The ratio of the unit’s maximum rated heat input 

capacity to its design rated steam output capacity (mmBtu/lb 

steam), individually for each fossil fuel type and for spent 

liquor solids. 

Subpart BB—[AMENDED] 

24. Section 98.286 is amended by removing and reserving 

paragraphs (b)(1), (b)(4), and (b)(6). 

Subpart CC—[AMENDED] 

25. Section 98.296 is amended by removing and reserving 

paragraphs (b)(5) through (7). 
*** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release 

During Review ***

Page 125 of 125 

Subpart EE—[AMENDED] 

26. Section 98.316 is amended by removing and reserving 

paragraphs (b)(6) and (b)(9). 

Subpart GG—[AMENDED] 

27. Section 98.336 is amended by removing and reserving 

paragraphs (b)(6), (b)(7), and (b)(10). 

Subpart TT—[AMENDED] 

28. Section 98.466 is amended by: 

a. Removing and reserving paragraph (c)(3)(i). 

b. Revising paragraph (c)(3)(ii). 

c. Removing and reserving paragraph (c)(3)(iii). 

§ 98.466 Data reporting requirements.

* * * * * 

(c) * * * 

(3) * * * 

(i) [Reserved] 

(ii) The year of the data used in Equation TT-2 for the 

waste disposal quantity and production quantity, for each year 

used in Equation TT–2 of this subpart to calculate the average 

waste disposal factor (WDF). 

(iii) [Reserved] 

* * * * *
Attachment N 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

1 

DATE: May 2013 

TO: Docket EPA-HQ-OAR-2010-0929 

FROM: Lisa Grogan-McCulloch 

SUBJECT: Data Elements Deferred to March 31, 2015: List of Data Elements Proposed 

Not To Be Reported

Table 1 lists the data elements for which reporting is deferred to March 31, 2015 (“inputs to equations”

data elements) that are proposed not to be reported, as specified in the proposed rulemaking “Revisions

to Reporting and Recordkeeping Requirements, and Proposed Confidentiality Determinations under the

Greenhouse Gas Reporting Program.” Table 2 lists the “inputs to equations” data elements that EPA is

not proposing to amend in this action; as a result, these data elements would be reported under the

proposed rulemaking.

Table 1. List of “Inputs to Equations” Data Elements Proposed Not To Be Reported1 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.3(d)(3)(v) For any facility who submitted an abbreviated emissions report under 

§98.3(d)(3)(v), any facility operating data or process information used for 

the GHG emission calculations. 

 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(b)(9)(iii) Estimate of the heat input from each type of fuel listed in Table C-2 that was 

combusted in the unit during the report year. 

C-10 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

2 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(c)(2)(ix) The flue gases from two or more stationary fuel combustion units at a facility 

are combined together and discharged through a common stack or duct 

before exiting to the atmosphere and if CEMS are used to continuously 

monitor CO2 mass emissions at the common stack or duct according to the 

Tier 4 Calculation Methodology, you may report the combined emissions 

from the units sharing the common stack or duct, in lieu of separately 

reporting the GHG emissions from the individual units. This monitoring and 

reporting alternative may also be used when process off-gases or a mixture 

of combustion products and process gases are combined together in a 

common stack or duct before exiting to the atmosphere. An estimate of the 

heat input from each type of fuel listed in Table C-2 combusted during the 

reporting year. 

C-10 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(i) Total quantity of each type of fuel combusted in each unit or group of 

aggregated units (as applicable) during the reporting year, in short tons for 

solid fuels, gallons for liquid fuels and standard cubic feet for gaseous fuels, 

or, if applicable, therms or mmBtu for natural gas. 

C-1 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(i) Total quantity of each type of fuel combusted in each unit or group of 

aggregated units (as applicable) during the reporting year, in short tons for 

solid fuels, gallons for liquid fuels and standard cubic feet for gaseous fuels, 

or, if applicable, therms or mmBtu for natural gas. 

C-1a 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(i) Total quantity of each type of fuel combusted in each unit or group of 

aggregated units (as applicable) during the reporting year, in short tons for 

solid fuels, gallons for liquid fuels and standard cubic feet for gaseous fuels, 

or, if applicable, therms or mmBtu for natural gas. 

C-1b 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(i) Total quantity of each type of fuel combusted in each unit or group of 

aggregated units (as applicable) during the reporting year, in short tons for 

solid fuels, gallons for liquid fuels and standard cubic feet for gaseous fuels, 

or, if applicable, therms or mmBtu for natural gas. 

C-8 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

3 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(ii)(A) For Tier 2: Total quantity of each type of fuel combusted in the unit or group 

of aggregated units (as applicable) during each month of the reporting year. 

Express the quantity of each fuel combusted during the measurement period 

in short tons for solid fuels, gallons for liquid fuels, and scf for gaseous fuels. 

C-2b 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(ii)(C) High heat values used in the CO2 emissions calculations for each fuel 

combusted during the reporting year. Report a HHV value for each calendar 

month in which HHV determination is required. If multiple values are 

obtained in a given month, report the arithmetic average value for the month. 

C-2b 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(ii)(D) If Eq. C-2c is used: Ratio of the maximum rate heat input capacity to the 

design rated steam output capacity of the unit. 

C-2c 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(ii)(D) If Eq. C-2c is used: Total quantity (i.e., pounds) of steam produced from 

MSW or solid fuel combustion during each month of the reporting year. 

C-2c 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as 

applicable) during each month of the reporting year (Fuel). 

C-13 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

4 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as 

applicable) during each month of the reporting year (Fuel). 

C-3 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as 

applicable) during each month of the reporting year (Fuel) 

C-4 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as 

applicable) during each month of the reporting year (Fuel). 

C-5 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as 

applicable) during each month of the reporting year (Fuel). 

C-8 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as 

applicable) during each month of the reporting year (Fuel). 

C-8a 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

5 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as 

applicable) during each month of the reporting year (Fuel). 

C-8b 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(iv)(C) The carbon content used in the emission calculations (including both valid 

and substitute data values). For each calendar month of the reporting year in 

which carbon content and, if applicable, molecular weight determination is 

required, report a value of each parameter. If multiple values of a parameter 

are obtained in a given month, report the arithmetic average value for the 

month. (CC). 

C-3 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(iv)(C) The carbon content used in the emission calculations (including both valid 

and substitute data values). For each calendar month of the reporting year in 

which carbon content and, if applicable, molecular weight determination is 

required, report a value of each parameter. If multiple values of a parameter 

are obtained in a given month, report the arithmetic average value for the 

month. (CC). 

C-4 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(iv)(C) The carbon content used in the emission calculations (including both valid 

and substitute data values). For each calendar month of the reporting year in 

which carbon content and, if applicable, molecular weight determination is 

required, report a value of each parameter. If multiple values of a parameter 

are obtained in a given month, report the arithmetic average value for the 

month. (CC). 

C-5 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(iv)(C) Gas molecular weight values used in the emission calculations (including 

both valid and substitute data values). For each calendar month of the 

reporting year in which carbon content and, if applicable, molecular weight 

determination is required, report a value of each parameter. If multiple 

values of a parameter are obtained in a given month, report the arithmetic 

average value for the month. 

C-5 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

6 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(iv)(F) The annual average HHV, when measured HHV data, rather than a default 

HHV from Table C-1 of this subpart, are used to calculate CH4 and N2O 

emissions for a Tier 3 unit, in accordance with §98.33(c)(1). 

C-8 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(ix)(D) For units that combust both fossil fuel and biomass, when biogenic CO2 is 

determined according to §98.33(e)(2), report the carbon-based F-factor used 

in Equation C-13 of this subpart. 

C-13 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(ix)(E) For units that combust both fossil fuel and biomass, when biogenic CO2 is 

determined according to §98.33(e)(2), report the annual average HHV value 

used in Equation C-13 of this subpart. 

C-13 

C (Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid) 2

§98.36(e)(2)(ix)(F) For units that combust both fossil fuel and biomass, when biogenic CO2 is 

determined according to §98.33(e)(2), report the total quantity of fossil fuel 

combusted during the reporting year. 

C-13 

E §98.56(b) Total annual adipic acid production from unit “z” (Pz). E-2 

E §98.56(b) Total annual adipic acid production from unit “z” (Pz). E-3a 

E §98.56(b) Total annual adipic acid production from unit “z” (Pz). E-3b 

E §98.56(b) Total annual adipic acid production from unit “z” (Pz). E-3c 

E §98.56(b) Total annual adipic acid production from unit “z” (Pz). E-3d 

E §98.56(c) Annual adipic acid production during which N2O abatement technology 

(located after the test point) is operating (Pz,N) . 

E-2 

E §98.56(j)(1) Emission factor for each unit (EFN2Oz). E-3a 

E §98.56(j)(1) Emission factor for each unit (EFN2O). E-3b 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

7 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

E §98.56(j)(1) Emission factor for each unit (EFN2O). E-3c 

E §98.56(j)(1) Emission factor for each unit (EFN2O). E-3d 

E §98.56(j)(3) Production rate per test run during performance test for each unit (P). E-1 

F §98.66(a) Annual aluminum production. (MP) F-5 

F §98.66(a) Annual aluminum production. (MP) F-6 

F §98.66(c)(2) Anode effect minutes per cell-day. (AEM) F-2 

F §98.66(c)(2) Anode effect overvoltage factor. (EFCF4) F-3 

F §98.66(c)(2) Anode effect frequency. Used to calculate 

AEM and the 

slope coefficients 

used as an input 

in Eq. F-2 

F §98.66(c)(2) Anode effect duration. Used to calculate 

AEM and the 

slope coefficients 

used as an input 

in Eq. F-2 

F §98.66(c)(2) Potline overvoltage. Used to calculate 

the overvoltage 

factor used as an 

input in Eq. F-3 

F §98.66(c)(2) Current efficiency. Used to calculate 

the overvoltage 

factor used as an 

input in Eq. F-3 

F §98.66(c)(3) Smelter-specific slope coefficients. (SCF4) F-2 

F §98.66(c)(3) Overvoltage emission factors. (EFCF4) F-3 

F §98.66(e)(1) Annual anode consumption. (No CEMS) (NAC ) F-5 

F §98.66(f)(1) Annual paste consumption. (No CEMS) (PC ) F-6 

F §98.66(g) Sulfur content in baked anode (percent weight). (Sa) F-5 

F §98.66(g) Ash content in baked anode (percent weight). (Asha) F-5 

F §98.66(g) Binder content of paste (percent weight). (BC) F-6 

F §98.66(g) Sulfur content of pitch (percent weight). (Sp) F-6 

F §98.66(g) Ash content of pitch (percent weight). (Ashp) F-6 

F §98.66(g) Hydrogen content of pitch (percent weight). (Hp) F-6 

F §98.66(g) Sulfur content in calcined coke (percent weight). (Sc) F-6 

F §98.66(g) Ash content in calcined coke (percent weight). (Ashc) F-6 

F §98.66(g) Carbon in skimmed dust from Soderberg cells (metric ton C/metric ton Al) 

(CD). 

F-6 

F §98.66(g) Initial weight of green anodes (metric tons) (GA). F-7 

F §98.66(g) Annual hydrogen content in green anodes (metric tons) (Hw). F-7 

F §98.66(g) Annual baked anode production (metric tons) (BA). F-7 

F §98.66(g) Annual waste tar collected (metric tons) (WT). F-7 

F §98.66(g) Annual packing coke consumption (metric tons/metric ton baked anode) 

(PCC). 

F-8 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

8 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

F §98.66(g) Annual baked anode production (metric tons) (BA). F-8 

F §98.66(g) Sulfur content in packing coke (percent weight) (SPc). F-8 

F §98.66(g) Ash content in packing coke (percent weight) (Ashpc). F-8 

G §98.76(b)(2) Monthly quantity of each type of feedstock consumed for ammonia 

manufacturing - Gaseous Feedstock. 

G-1 

G §98.76(b)(2) Monthly quantity of each type of feedstock consumed for ammonia 

manufacturing - Liquid Feedstock. 

G-2 

G §98.76(b)(2) Monthly quantity of each type of feedstock consumed for ammonia 

manufacturing - Solid Feedstock. 

G-3 

G §98.76(b)(7) Carbon content of the gaseous feedstock. G-1 

G §98.76(b)(8) Molecular weight of the gaseous feedstock. G-1 

G §98.76(b)(9) Molar volume conversion factor of the gaseous feedstock.2 G-1 

G §98.76(b)(10) Carbon content of the liquid feedstock, for month n. G-2 

G §98.76(b)(11) Carbon content of the solid feedstock, for month n. G-3 

H §98.86(b)(2) Monthly clinker production for each kiln (No CEMS). H-2 

H §98.86(b)(5) Quarterly quantity of CKD not recycled to the kiln. H-2 

H §98.86(b)(6) Monthly fraction of total CaO in clinker. H-3 

H §98.86(b)(6) Monthly fraction of total MgO in clinker. H-3 

H §98.86(b)(6) Monthly fraction of non-calcined CaO in clinker. H-3 

H §98.86(b)(6) Monthly fraction of non-calcined MgO in clinker. H-3 

H §98.86(b)(8) Quarterly fraction of total CaO in CKD not recycled to the kiln. H-4 

H §98.86(b)(8) Quarterly fraction of total MgO in CKD not recycled to the kiln. H-4 

H §98.86(b)(8) Quarterly fraction of non-calcined CaO in CKD not recycled to the kiln. H-4 

H §98.86(b)(8) Quarterly fraction of non-calcined MgO in CKD not recycled to the kiln. H-4 

H §98.86(b)(10) Monthly kiln-specific clinker CO2 emission factors for each kiln. H-2 

H §98.86(b)(12) Annual organic carbon content of each raw kiln feed or annual organic 

carbon content of each raw material. 

H-5 

H §98.86(b)(13) Annual consumption of each raw kiln feed or annual consumption of each 

raw material. 

H-5 

H §98.86(b)(15) Monthly kiln-specific raw kiln feed to clinker produced factors (if used) for 

each kiln. 

Used to calculate 

clinker 

production by 

facilities using 

the method in 40 

CFR 98.84(d) 

(i.e., kiln-specific 

clinker-to-feed 

factors) 

K §98.116(b) Annual production by product from each EAF (tons) (used as input to Eq K1): Mproductk= Annual mass of alloy product k tapped from EAF (tons). K-1 

K §98.116(b) Annual production by product from each EAF (tons) (used as input to Eq K3). K-3 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

9 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

K §98.116(e)(4) Annual material quantity for each material included for the calculation of 

annual process CO2 emissions (No CEMS): Mreducing agenti= Annual mass 

of reducing agent i fed, charged, or otherwise introduced into the EAF (tons). 

K-1 

K §98.116(e)(4) Annual material quantity for each material included for the calculation of 

annual process CO2 emissions (No CEMS): Melectrodem= Annual mass of 

carbon electrode m consumed in the EAF (tons). 

K-1 

K §98.116(e)(4) Annual material quantity for each material included for the calculation of 

annual process CO2 emissions (No CEMS): Moreh= Annual mass of ore h 

charged to the EAF (tons). 

K-1 

K §98.116(e)(4) Annual material quantity for each material included for the calculation of 

annual process CO2 emissions (No CEMS): Mfluxj= Annual mass of flux 

material j fed, charged, or otherwise introduced into the EAF to facilitate 

slag formation (tons). 

K-1 

K §98.116(e)(4) Annual material quantity for each material included for the calculation of 

annual process CO2 emissions (No CEMS): Mnon-product outgoingl= 

Annual mass of non-product outgoing material l removed from EAF (tons). 

K-1 

K §98.116(e)(5) Annual average of the carbon content determinations for each material 

included for the calculation of annual process CO2 emissions (No CEMS): 

Creducing agenti= Carbon content in reducing agent i (percent by weight, 

expressed as a decimal fraction). 

K-1 

K §98.116(e)(5) Annual average of the carbon content determinations for each material 

included for the calculation of annual process CO2 emissions (No CEMS): 

Celectrodem= Carbon content of the carbon electrode m (percent by weight, 

expressed as a decimal fraction). 

K-1 

K §98.116(e)(5) Annual average of the carbon content determinations for each material 

included for the calculation of annual process CO2 emissions (No CEMS): 

Coreh= Carbon content in ore h (percent by weight, expressed as a decimal 

fraction). 

K-1 

K §98.116(e)(5) Annual average of the carbon content determinations for each material 

included for the calculation of annual process CO2 emissions (No CEMS): 

Cfluxj= Carbon content in flux material j (percent by weight, expressed as a 

decimal fraction). 

K-1 

K §98.116(e)(5) Annual average of the carbon content determinations for each material 

included for the calculation of annual process CO2 emissions (No CEMS): 

Cproductk= Carbon content in alloy product k . (percent by weight, 

expressed as a decimal fraction). 

K-1 

K §98.116(e)(5) Annual average of the carbon content determinations for each material 

included for the calculation of annual process CO2 emissions (No CEMS): 

Cnon-product outgoingl= Carbon content in non-product outgoing material l 

(percent by weight, expressed as a decimal fraction). 

K-1 

L §98.126(b)(1) Elements of the sum (a, b, c, etc.) (e.g., measured variables in the sum). L-1 

L §98.126(b)(1) 3 eSA (absolute error of the sum, expressed as one half of a 95 percent 

confidence interval). Note that where eSA = the overall absolute error 

calculated for the process emissions you report under §98.126(a)(2), this data 

element was not deferred in the inputs deferral rule (76 FR 53057, August 

25, 2011), and would be required to be reported. 

L-1 

L §98.126(b)(1) 3 ea, eb, ec = Relative error of a, b, or c, respectively, expressed as one half of 

a 95 percent confidence interval. 

L-1 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

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Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

L §98.126(b)(1) Elements of the sum (a, b, c, etc.) (e.g., measured variables in the sum). L-2 

L §98.126(b)(1) a+b+c = Sum of the variables measured. L-2 

L §98.126(b)(1) 3 eSR (relative error of the sum, expressed as one half of a 95 percent 

confidence interval). Note that where eSR = the overall relative error 

calculated for the process emissions you report under §§98.126(a)(2), this 

data element was not deferred in the inputs deferral rule (76 FR 53057, 

August 25, 2011), and would be required to be reported. 

L-2 

L §98.126(b)(1) 3 eSA (absolute error of the sum, expressed as one half of a 95 percent 

confidence interval). Note that where eSA = the overall absolute error 

calculated for the process emissions you report under §98.126(a)(2), this data 

element was not deferred in the inputs deferral rule (76 FR 53057, August 

25, 2011) , and would be required to be reported. 

L-2 

L §98.126(b)(1) Elements of the sum (a, b, c, etc.) (e.g., measured variables in the sum). L-3 

L §98.126(b)(1) 3 ea, eb, ec = Relative error of a, b, or c, respectively, expressed as one half of 

a 95 percent confidence interval. 

L-3 

L §98.126(b)(1) 3 ePA (absolute error of the product, expressed as one half of a 95 percent 

confidence interval). Note that where ePA = the overall absolute error 

calculated for the process emissions you report under §98.126(a)(2), this data 

element was not deferred in the inputs deferral rule (76 FR 53057, August 

25, 2011) , and would be required to be reported. 

L-3 

L §98.126(b)(1) a*b*c = Product of the variables measured. L-3 

L §98.126(b)(1) Measured variables of the product (a, b, c, etc.). L-4 

L §98.126(b)(1) a*b*c = Product of the variables measured. L-4 

L §98.126(b)(1) 3 ePR (relative error of the product, expressed as one half of a 95 percent 

confidence interval). Note that where ePR = the overall relative error 

calculated for the process emissions you report under §98.126(a)(2), this data 

element was not deferred in the inputs deferral rule (76 FR 53057, August 

25, 2011) , and would be required to be reported. 

L-4 

L §98.126(b)(1) 3 ePA (absolute error of the product, expressed as one half of a 95 percent 

confidence interval). Note that where ePA = the overall absolute error 

calculated for the process emissions you report under §98.126(a)(2), this data 

element was not deferred in the inputs deferral rule (76 FR 53057, August 

25, 2011) , and would be required to be reported. 

L-4 

L §98.126(b)(2) The balanced chemical equation that describes the reaction used to 

manufacture the fluorinated GHG product and each fluorinated GHG 

transformation product. 

 

L §98.126(b)(6) The mass of each fluorine-containing reactant that is fed into the process. 

(Rd) 

L-6 

L §98.126(b)(7) The mass of each fluorine-containing product produced by the process. (P) L-6 

L §98.126(b)(8)(i) The mass of each fluorine-containing product that is removed from the 

process and fed into the destruction device (metric tons). (Pj) 

L-7 

L §98.126(b)(8)(ii) The mass of each fluorine-containing by-product that is removed from the 

process and fed into the destruction device (metric tons). (Bkj) 

L-7 

L §98.126(b)(8)(iii) The mass of each fluorine-containing reactant that is removed from the 

process and fed into the destruction device (metric tons). (Rdj) 

L-7 

L §98.126(b)(8)(iv) The mass of each fluorine-containing by-product that is removed from the 

process and recaptured (metric tons). (Bkl) 

L-7 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

11 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

L §98.126(b)(8)(v) The demonstrated destruction efficiency of the destruction device for each 

fluorinated GHG fed into the device from the process in greater than trace 

concentrations (fraction). (DEFGHGf= Destruction efficiency of the device 

that has been demonstrated for fluorinated GHG f in stream j (fraction).) 

L-8 

L §98.126(b)(9)(i) The mass of fluorine in each stream that is fed into the destruction device 

(metric tons). (cTFj * Sj) 

L-17 

L §98.126(b)(9)(ii) The mass of fluorine that is recaptured (metric tons). (cTFl * Sl) L-17 

L §98.126(b)(9)(iii) The weighted average destruction efficiency of the destruction device 

calculated for each stream under §98.123(b)(16). (DEavgj) 

L-17 

L §98.126(c)(1) The quantity of the process activity used to estimate emissions (e.g., tons of 

product produced or tons of reactant consumed). (ActivityC or ActivityU) 

L-21 

L §98.126(c)(1) The quantity of the process activity used to estimate emissions (e.g., tons of 

product produced or tons of reactant consumed). (ActivityC or ActivityU) 

L-22 

L §98.126(c)(1) The quantity of the process activity used to estimate emissions (e.g., tons of 

product produced or tons of reactant consumed). (Activity) 

L-26 

L §98.126(c)(1) The quantity of the process activity used to estimate emissions (e.g., tons of 

product produced or tons of reactant consumed). (ActivityU or ActivityC) 

L-27 

L §98.126(c)(2) The site-specific, process-vent-specific emission factor(s) for each process 

vent (EFPV). 

L-20 

L §98.126(c)(2) The site-specific, process-vent-specific emission factor(s) for each process 

vent (EFPV–C). 

L-21 

L §98.126(c)(2) The site-specific, process-vent-specific emission calculation factor for each 

process vent. (ECFPV-U). 

L-21 

L §98.126(c)(2) The site-specific, process-vent-specific emission factor(s) for each process 

vent (EFPV–U). 

L-22 

L §98.126(c)(2) The site-specific, process-vent-specific emission factor(s) for each process 

vent. (EFPV) 

L-23 

L §98.126(c)(2) The site-specific, process-vent-specific emission calculation factor for each 

process vent. (ECFPV). 

L-25 

L §98.126(c)(2) The site-specific, process-vent-specific emission calculation factor for each 

process vent (ECFPV). 

L-26 

L §98.126(c)(2) The site-specific, process-vent-specific emission calculation factor for each 

process vent. (ECFPV). 

L-27 

L §98.126(d) Where missing data have been estimated pursuant to §98.125 report, 

estimate of the missing data. 

Varies 

L §98.126(f)(1) Destruction efficiency (DE) of each destruction device for each fluorinated 

GHG whose destruction the facility reflects in §98.123, in accordance with 

§98.124(g)(1)(i) through (iv). (DEFGHGf) 

L-8 

L §98.126(f)(1) Destruction efficiency (DE) of each destruction device for each fluorinated 

GHG whose destruction the facility reflects in §98.123, in accordance with 

§98.124(g)(1)(i) through (iv). (DEFGHGf) 

L-18 

L §98.126(f)(1) Destruction efficiency (DE) of each destruction device for each fluorinated 

GHG whose destruction the facility reflects in §98.123, in accordance with 

§98.124(g)(1)(i) through (iv). (DE ) 

L-22 

L §98.126(f)(1) Destruction efficiency (DE) of each destruction device for each fluorinated 

GHG whose destruction the facility reflects in §98.123, in accordance with 

§98.124(g)(1)(i) through (iv) (DE). 

L-27 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

12 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

L §98.126(f)(1) Destruction efficiency (DE) of each destruction device for each fluorinated 

GHG whose destruction the facility reflects in §98.123, in accordance with 

§98.124(g)(1)(i) through (iv) (DE). 

L-31 

L §98.126(g)(1) The mass of the fluorinated GHG fed into the destruction device. (RED) L-31 

L §98.126(h)(2) If applicable, the heel factor calculated for each container size and type. (hfj) L-34 

N §98.146(b)(6) Fraction of calcination for carbonate-based raw material. N-1 

N §98.146(b)(2) Annual quantity of carbonate based-raw material charged to each continuous 

glass melting furnace (No CEMS). 

N-1 

N §98.146(b)(4) Carbonate-based mineral mass fraction of carbonate-based raw material 

charged to a furnace. 

N-1 

O §98.156(a)(2) Loss Factor used to account for the loss of HCFC– 22 upstream of the 

measurement (LF used in equation O-3). 

O-3 

O §98.156(a)(7) Annual mass of the HFC-23 generated (G23 in Eq. O-4). O-4 

O §98.156(a)(8) Annual mass of any HFC-23 sent off site for sale (S23 in Eq. O-4). O-4 

O §98.156(a)(9) Annual mass of any HFC-23 sent off site for destruction (OD23 used in Eq. 

O-4). 

O-4 

O §98.156(a)(10) Mass of HFC-23 in storage at the beginning of the year (used to calculate I23, 

which is used in Eq. O-4). 

O-4 

O §98.156(a)(10) Mass of HFC-23 in storage at the end of the year (used to calculate I23, which 

is used in Eq. O-4). 

O-4 

O §98.156(b)(1) Annual mass of HFC-23 fed into the destruction device (FD used in Eq. O-8 

and O-9). 

O-8 

O §98.156(b)(1) Annual mass of HFC-23 fed into the destruction device (FD used in Eq. O-8 

and O-9). 

O-9 

O §98.156(b)(2) Annual mass of HFC-23 destroyed (D23 used in Eq. O-8). O-8 

O §98.156(d)(1) If the HFC-23 concentration measured pursuant to §98.154(l) is greater than 

that measured during the performance test that is the basis for the destruction 

efficiency (DE), report flow rate of HFC-23 being fed into the destruction 

device in kg/hr. 

No Equation - 

Used to calculate 

Destruction 

Efficiency 

O §98.156(d)(5) If the HFC-23 concentration measured pursuant to §98.154(l) is greater than 

that measured during the performance test that is the basis for the destruction 

efficiency (DE), report the destruction efficiency (DE) calculated from 

paragraphs (d)(1) and (d)(4) of this section. 

O-9 

O §98.156(e)(1) (One time report) Destruction efficiency (DE) (by March 31, 2011 or within 

60 days of commencing HFC-23 destruction). 

O-9 

P §98.156(b)(2) Monthly consumption of each fuel and feedstock by type used for hydrogen 

production (No CEMS): gaseous. 

P-1 

P §98.156(b)(2) Monthly consumption of each fuel and feedstock by type used for hydrogen 

production (No CEMS) (Fdstkn): Liquid. 

P-2 

P §98.156(b)(2) Monthly consumption of each fuel and feedstock by type used for hydrogen 

production (No CEMS) (Fdstkn): solid. 

P-3 

P §98.156(b)(5) Monthly analyses of carbon content for each fuel and feedstock used in 

hydrogen production: Gaseous. 

P-1 

P §98.156(b)(5) Monthly analyses of carbon content for each fuel and feedstock used in 

hydrogen production: Liquid. 

P-2 

P §98.156(b)(5) Monthly analyses of carbon content for each fuel and feedstock used in 

hydrogen production: Solid. 

P-3 

P §98.156(b)(6) Monthly analyses of the molecular weight of gaseous fuels and feedstocks. P-1 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

13 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

Q §98.176(b) Annual quantity taconite pellets produced (No CEMS). Q-1 

Q §98.176(b) Annual quantity coke produced (No CEMS). Q-2 

Q §98.176(b) Annual quantity iron produced (No CEMS and not using the site-specific EF 

method under §98.173(b)(2)). 

Q-2 

Q §98.176(b) Annual quantity raw steel produced (No CEMS and not using the sitespecific EF method under §98.173(b)(2)). Q-2 

Q §98.176(b) Annual quantity sinter produced (No CEMS and not using the site-specific 

EF method under §98.173(b)(2)). 

Q-4 

Q §98.176(b) Annual quantity raw steel produced (No CEMS and not using the sitespecific EF method under §98.173(b)(2)). Q-5 

Q §98.176(b) Annual quantity raw steel produced (No CEMS and not using the sitespecific EF method under §98.173(b)(2)). Q-6 

Q §98.176(b) Annual quantity iron produced (No CEMS and not using the site-specific EF 

method under §98.173(b)(2)). 

Q-7 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No 

CEMS) - solid fuel combusted (Csf). 

Q-1 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No 

CEMS) -gaseous fuel combusted(Cgf). 

Q-1 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No 

CEMS)- liquid fuel combusted (Clf). 

Q-1 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No 

CEMS)- greenball pellets produced (Co). 

Q-1 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No 

CEMS) - Fired pellets produced (Cp). 

Q-1 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No 

CEMS) - air pollution control residue collected (Cr). 

Q-1 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No 

CEMS)- Iron (Ciron). 

Q-2 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No 

CEMS)- Scrap (Cscrap). 

Q-2 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No 

CEMS)- Flux (Cflux). 

Q-2 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No 

CEMS)- Carbonaceous material (Ccarbon). 

Q-2 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No 

CEMS) - Steel produced (Csteel). 

Q-2 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No 

CEMS) - Slag produced (Cslag). 

Q-2 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No 

CEMS) - Air pollution control residue collected (CR). 

Q-2 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No 

CEMS)- Coal charged to coke battery (Ccoal). 

Q-3 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No 

CEMS) - Coke produced by coke battery (Ccoke). 

Q-3 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No 

CEMS) - Air pollution control residue collected from coke battery (CR). 

Q-3 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

14 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No 

CEMS)- Gaseous fuel combusted in the sinter process (Cgf). 

Q-4 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No 

CEMS) - sinter feed (CFeed). 

Q-4 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No 

CEMS) - sinter (CSinter). 

Q-4 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No 

CEMS) - Air pollution control residue collected from sinter process (CR). 

Q-4 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No 

CEMS)- Iron (Ciron) used in EAF. 

Q-5 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No 

CEMS)- Scrap (Cscrap) used in EAF. 

Q-5 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No 

CEMS)- Flux (Cflux) used in EAF. 

Q-5 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No 

CEMS)- Carbonaceous material (Ccarbon) used in EAF. 

Q-5 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No 

CEMS)- Electrode consumed in EAF (Celectrode). 

Q-5 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No 

CEMS) - Steel produced (Csteel) in EAF. 

Q-5 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No 

CEMS) - Slag produced (Cslag) in EAF. 

Q-5 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No 

CEMS) - Air pollution control residue collected (CR) for EAF. 

Q-5 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No 

CEMS) - molten steel before decarburization (Csteelout) in EAF. 

Q-6 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No 

CEMS) - molten steel after decarburization (Csteelout) in EAF. 

Q-6 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No 

CEMS) - Air pollution control residue collected (CR) for EAF. 

Q-6 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No 

CEMS) - Gaseous fuel combusted in the direct reduction furnace (Fg) . 

Q-7 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No 

CEMS) - iron ore or iron ore pellets fed into the direct reduction furnace 

(Core) . 

Q-7 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No 

CEMS)- Carbonaceous material (Ccarbon) used in the direct reduction furnace 

. 

Q-7 

Q §98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No 

CEMS) - Other materials charged to the direct reduction furnace (Cother). 

Q-7 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No 

CEMS) - Iron produced from direct reduction furnace (Ciron). 

Q-7 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No 

CEMS) - Non-metallic materials produced from direct reduction furnace 

(CNM). 

Q-7 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

15 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

Q §98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No 

CEMS) - Air pollution control residue collected (CR) for direct reduction 

furnace. 

Q-7 

Q §98.176(e)(3) Annual volume of each type of gaseous fuel used to determine CO2

emissions (reported separately for each type in standard cubic feet) (No 

CEMS) - Taconite Indurating Furnace. 

Q-1 

Q §98.176(e)(3) Annual volume of each type of liquid fuel used to determine CO2 emissions 

(reported separately for each type in gallons) (No CEMS). 

Q-1 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine 

CO2 emissions (No CEMS)- Annual mass of greenball (taconite) pellets fed 

into the furnace (O). 

Q-1 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine 

CO2 emissions (No CEMS)- Annual mass of solid fuel combusted (Fs). 

Q-1 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine 

CO2 emissions (No CEMS) - Annual mass of air pollution control residue 

(R). 

Q-1 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine 

CO2 emissions (No CEMS) - Annual mass of fired pellets produced (P). 

Q-1 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine 

CO2 emissions (No CEMS)- Annual mass of molten iron charged to furnace 

(Iron). 

Q-2 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine 

CO2 emissions (No CEMS)- Annual mass of scrap charged to the furnace 

(Scrap). 

Q-2 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine 

CO2 emissions (No CEMS)- Annual mass of flux charged to the furnace 

(Flux). 

Q-2 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine 

CO2 emissions (No CEMS)- Annual mass of carbon (e.g., coal, coke) 

charged to furnace (Carbon). 

Q-2 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine 

CO2 emissions (No CEMS) - Annual mass of steel produced (Steel). 

Q-2 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine 

CO2 emissions (No CEMS) - Annual mass of slag produced (Slag). 

Q-2 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine 

CO2 emissions (No CEMS) - Annual mass of air pollution control residue 

collected (Residue). 

Q-2 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine 

CO2 emissions (No CEMS)- Coal charged to battery (Coal). 

Q-3 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine 

CO2 emissions (No CEMS) - Annual mass of coke produced (Coke). 

Q-3 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine 

CO2 emissions (No CEMS) - Annual mass of air pollution control residue 

collected from battery (R). 

Q-3 

Q §98.176(e)(3) Annual volume of each type of gaseous fuel used to determine CO2

emissions (reported separately for each type in standard cubic feet) (No 

CEMS) - Sinter process (Fg). 

Q-4 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

16 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine 

CO2 emissions (No CEMS)- Annual mass of sinter feed material (Feed). 

Q-4 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine 

CO2 emissions (No CEMS)- Annual mass of sinter Produced (Sinter). 

Q-4 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine 

CO2 emissions (No CEMS) - Annual mass of air pollution control residue 

collected from sinter process (R). 

Q-4 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine 

CO2 emissions (No CEMS)- Annual mass of direct reduced iron charged to 

the EAF (Iron). 

Q-5 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine 

CO2 emissions (No CEMS)- Annual mass of Scrap charged to the 

EAF(Scrap). 

Q-5 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine 

CO2 emissions (No CEMS)- Annual mass of flux charged to the EAF(Flux). 

Q-5 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine 

CO2 emissions (No CEMS)- Annual mass of carbon electrode consumed in 

the EAF(Electrode). 

Q-5 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine 

CO2 emissions (No CEMS)- Annual mass of carbonaceous (coal or coke) 

material charged to the EAF(Carbon). 

Q-5 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine 

CO2 emissions (No CEMS)- Annual mass of steel produced (Steel) in EAF. 

Q-5 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine 

CO2 emissions (No CEMS) - Annual mass of slag produced (Slag) in EAF. 

Q-5 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine 

CO2 emissions (No CEMS) - Annual mass of air pollution control residue 

collected (Residue) from EAF. 

Q-5 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine 

CO2 emissions (No CEMS)- Annual mass of steel charged to the 

decarburization vessel (Steel). 

Q-6 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine 

CO2 emissions (No CEMS) - Annual mass of air pollution control residue 

collected (Residue) from the decarburization vessel. 

Q-6 

Q §98.176(e)(3) Annual volume of each type of gaseous fuel used to determine CO2

emissions (reported separately for each type in standard cubic feet) (No 

CEMS) - direct reduction furnaces (Fg). 

Q-7 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine 

CO2 emissions (No CEMS)- Annual mass of iron ore or iron ore pellets 

charged to the direct reduction furnace (Ore). 

Q-7 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine 

CO2 emissions (No CEMS)- Annual mass of carbonaceous (coal or coke) 

material charged to the direct reduction furnace (Carbon). 

Q-7 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine 

CO2 emissions (No CEMS)- Annual mass of other material charged to the 

direct reduction furnace (Other). 

Q-7 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

17 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine 

CO2 emissions (No CEMS)- Annual mass of iron produced (Iron) in direct 

reduction furnace. 

Q-7 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine 

CO2 emissions (No CEMS)- Annual mass of non-metallic materials produced 

(NM) in direct reduction furnace. 

Q-7 

Q §98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine 

CO2 emissions (No CEMS) - Annual mass of air pollution control residue 

collected (Residue) from the direct reduction furnace. 

Q-7 

Q §98.176(e)(4) Molecular weight of gaseous fuels (No CEMS) - Taconite Indurating 

Furnace. 

Q-1 

Q §98.176(e)(4) Molecular weight of gaseous fuels (No CEMS) - Sinter Process. Q-4 

Q §98.176(e)(4) Molecular weight of gaseous fuels (No CEMS) - Direct Reduction Furnace. Q-7 

Q §98.176(f)(2) Average hourly feed rate during the test (No CEMS). No Equation - 

Used as input in 

calc. method 

described in 

§98.173(b)(iii). 

Q §98.176(f)(2) Average hourly production rate during the test (No CEMS). No Equation - 

Used as input in 

calc. method 

described in 

§98.173(b)(iii). 

Q §98.176(f)(3) Site-specific emission factor (No CEMS). No Equation - 

Used as input in 

calc. method 

described in 

§98.173(b)(2)(iv). 

Q §98.176(f)(4) Annual feed rate used to estimate annual CO2 emissions (No CEMS). No Equation - 

Used as input in 

calc. method 

described in 

§98.173(b)(iv). 

Q §98.176(f)(4) Annual production rate used to estimate annual CO2 emissions (No CEMS). No Equation - 

Used as input in 

calc. method 

described in 

§98.173(b)(iv). 

Q §98.176(g) The annual amount of coal charged to the coke ovens (in metric tons). No Equation - 

Used as input in 

calc. method 

described in 

§98.173(c). 

R §98.186(b)(6) Annual material quantity used for the calculation of annual process CO2

emissions (No CEMS) (Ore = Annual mass of lead ore charged to the 

smelting furnace (tons).) 

R-1 

R §98.186(b)(6) Annual material quantity used for the calculation of annual process CO2

emissions (No CEMS) (Scrap = Annual mass of lead scrap charged to the 

smelting furnace (tons).) 

R-1 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

18 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

R §98.186(b)(6) Annual material quantity used for the calculation of annual process CO2

emissions (No CEMS) (Flux = Annual mass of flux materials (e.g., 

limestone, dolomite) charged to the smelting furnace (tons).) 

R-1 

R §98.186(b)(6) Annual material quantity used for the calculation of annual process CO2

emissions (No CEMS) (Carbon = Annual mass of carbonaceous materials 

(e.g., coal, coke) charged to the smelting furnace (tons).) 

R-1 

R §98.186(b)(6) Annual material quantity used for the calculation of annual process CO2

emissions (No CEMS) (Other = Annual mass of any other material 

containing carbon, other than fuel, fed, charged, or otherwise introduced into 

the smelting furnace (tons).) 

R-1 

R §98.186(b)(7) Annual average of the carbon content determinations for each material used 

for the calculation of annual process CO2 emissions (No CEMS) (COre= 

Carbon content of the lead ore, from the carbon analysis results (percent by 

weight, expressed as a decimal fraction).) 

R-1 

R §98.186(b)(7) Annual average of the carbon content determinations for each material used 

for the calculation of annual process CO2 emissions (No CEMS). (CScrap= 

Carbon content of the lead scrap, from the carbon analysis (percent by 

weight, expressed as a decimal fraction).) 

R-1 

R §98.186(b)(7) Annual average of the carbon content determinations for each material used 

for the calculation of annual process CO2 emissions (No CEMS). (CFlux= 

Carbon content of the flux materials, from the carbon analysis (percent by 

weight, expressed as a decimal fraction).) 

R-1 

R §98.186(b)(7) Annual average of the carbon content determinations for each material used 

for the calculation of annual process CO2 emissions (No CEMS). (CCarbon= 

Carbon content of the carbonaceous materials, from the carbon analysis 

(percent by weight, expressed as a decimal fraction).) 

R-1 

R §98.186(b)(7) Annual average of the carbon content determinations for each material used 

for the calculation of annual process CO2 emissions (No CEMS). (COther= 

Carbon content of the other material from the carbon analysis results 

(percent by weight, expressed as a decimal fraction).) 

R-1 

S §98.196(b)(2) Monthly emission factors for each lime type produced. S-4 

S §98.196(b)(3) Monthly emission factors for each calcined byproduct/waste by lime type 

that is sold. (EFLKD,i,n) 

S-4 

S §98.196(b)(5) Monthly results of chemical composition analysis of each type of lime 

product produced (No CEMS). 

No Equation -

described in 

§98.196(b)(5). 

S §98.196(b)(5) Monthly results of chemical composition analysis of each type of calcined 

lime byproducts/wastes sold (No CEMS). 

No Equation -

described in 

§98.196(b)(5). 

S §98.196(b)(6) Annual results of chemical composition analysis of each type of lime 

byproducts/wastes that is not sold (No CEMS). 

No Equation -

described in 

§98.196(b)(6). 

S §98.196(b)(8) Monthly amount of lime product sold, by type (No CEMS). No Equation -

described in 

§98.196(b)(8). 

S §98.196(b)(10) Monthly amount of calcined lime byproduct/waste sold, by type (No 

CEMS). 

No Equation -

described in 

§98.196(b)(10). 

S §98.196(b)(11) Annual amount of calcined lime byproduct/waste that is not sold, by type 

(No CEMS). 

No Equation -

described in 

§98.196(b)(11). 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

19 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

S §98.196(b)(12) Monthly weight or mass of each lime type produced (No CEMS). S-4 

U §98.216(b) Annual carbonate consumption by carbonate type. U-1 

U §98.216(b) Annual carbonate input by carbonate type. U-2 

U §98.216(e)(1) Annual carbonate consumption by carbonate type. U-1 

U §98.216(e)(2) Annual calcination fractions used in calculations. U-1 

U §98.216(f)(1) Annual carbonate input by carbonate type. U-2 

U §98.216(f)(2) Annual carbonate output by carbonate type. U-2 

V §98.226(d) Annual nitric acid production during which N2O abatement technology is 

operating (tons, 100% acid basis). 

V-2 

V §98.226(m)(1) Emission factor calculated for each nitric acid train (EFN2Ot). V-3a 

V §98.226(m)(1) Emission factor calculated for each nitric acid train (EFN2Ot). V-3b 

V §98.226(m)(1) Emission factor calculated for each nitric acid train (EFN2Ot). V-3c 

V §98.226(m)(1) Emission factor calculated for each nitric acid train (EFN2Ot). V-3d 

V §98.226(m)(3) Production rate per test run during performance test for each train. V-1 

X §98.246(a)(4) Indicate whether you used the alternative to sampling and analysis. X-1 

X §98.246(a)(4) Monthly volume values (used in Equations X-1 to X-3) - Volume of gaseous 

feedstock I introduced in month "n" ((Fgf)n).

X-1 

X §98.246(a)(4) Monthly volume values (used in Equations X-1 to X-3) - Volume of gaseous 

product i produced in month "n" ((Pgf)n)

X-1 

X §98.246(a)(4) Monthly carbon content values (used in Equations X-1 to X-3) - Average 

carbon content of the gaseous feedstock I for month "n" ((CCgf)n). 

X-1 

X §98.246(a)(4) Monthly carbon content values (used in Equations X-1 to X-3) - Average 

carbon content of the gaseous product i for month "n" ((CCgp)n). 

X-1 

X §98.246(a)(4) Molecular weights for gaseous feedstocks (used in Equation X-1). X-1 

X §98.246(a)(4) Molecular weights for gaseous products (used in Equation X-1). X-1 

X §98.246(a)(4) Indicate whether you used the alternative to sampling and analysis. X-2 

X §98.246(a)(4) Monthly volume values (used in Equations X-1 to X-3) - Volume of liquid 

feedstock i for month "n" ((Flf)n ). 

X-2 

X §98.246(a)(4) Monthly volume values (used in Equations X-1 to X-3) - Volume of liquid 

product i for month "n" ((Plp)n ) . 

X-2 

X §98.246(a)(4) Monthly mass values (used in Equations X-1 to X-3) - Mass of liquid 

feedstock i for month "n" ((Flf)n ). 

X-2 

X §98.246(a)(4) Monthly mass values (used in Equations X-1 to X-3) - Mass of liquid 

product i for month "n" ((Plp)n ). 

X-2 

X §98.246(a)(4) Monthly carbon content values (used in Equations X-1 to X-3) - Average 

carbon content of the liquid feedstock i for month "n" ((CClf)n). 

X-2 

X §98.246(a)(4) Monthly carbon content values (used in Equations X-1 to X-3) - Average 

carbon content of the liquid product i for month "n" ((CClp)n). 

X-2 

X §98.246(a)(4) Indicate whether you used the alternative to sampling and analysis. X-3 

X §98.246(a)(4) Monthly mass values (used in Equations X-1 to X-3) - Mass of solid 

feedstock I for month "n" ((Fsf)n). 

X-3 

X §98.246(a)(4) Monthly mass values (used in Equations X-1 to X-3) - Mass of solid product 

i for month "n" ((Psp)n). 

X-3 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

20 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

X §98.246(a)(4) Monthly carbon content values (used in Equations X-1 to X-3) - Average 

carbon content of the solid feedstock i for month "n" ((CClf)n). 

X-3 

X §98.246(a)(4) Monthly carbon content values (used in Equations X-1 to X-3) - Average 

carbon content of the solid product i for month "n" ((CClp)n). 

X-3 

X §98.246(b)(5)(iii) Quantity of each type of fuel used in equation C-8 in §98.33(c) for each 

stationary combustion unit or group of units (as applicable) during the 

reporting year, expressed in short tons for solid fuels, gallons for liquid fuels, 

and scf for gaseous fuels. 

C-8 

X §98.246(b)(5)(iv) The HHV (either default or annual average from measured data) used in 

equation C-8 in §98.33(C) for each stationary combustion unit or group of 

units (as applicable). 

C-8 

Y §98.256(e)(6) 3 If using Equation Y-1a: report the molar volume conversion factor (in scf/gmole) for each flare. Y-1a 

Y §98.256(e)(7) 3 If using Equation Y-1b: report molar volume conversion factor for each 

flare. 

Y-1b 

Y §98.256(e)(7)(ii) If using Equation Y-1b: report the carbon mole number of each carbon 

containing compound other than CO2 in the flare gas stream for each flare. 

Y-1b 

Y §98.256(e)(9) Annual volume of flare gas combusted during normal operations. Y-3 

Y §98.256(e)(9) Annual average higher heating value of the flare gas (normal). Y-3 

Y §98.256(e)(9) Volume of gas flared during SSM event. Y-3 

Y §98.256(e)(9) Average molecular weight (SSM). Y-3 

Y §98.256(e)(9) Carbon content of the flare gas (SSM). Y-3 

Y §98.256(e)(9) 3 If using Equation Y-3: report the molar volume conversion factor for each 

flare. 

Y-3 

Y §98.256(e)(10) 3 Fraction of carbon in the flare gas contributed by methane (used in Equation 

Y-4). 

Y-4 

Y §98.256(f)(7) 3 If using Equation Y-6: report the molar volume conversion factor. Y-6 

Y §98.256(f)(10) Coke burn-off factor. Y-8 

Y §98.256(f)(10) Annual throughput of unit. Y-8 

Y §98.256(f)(10) Average carbon content of coke. Y-8 

Y §98.256(f)(11) If you use a unit-specific emission factor for CH4: report the unit-specific 

emission factor for CH4 each catalytic cracking units, traditional fluid 

coking units, and catalytic reforming units. 

Used in method 

specified in 

§98.253(c)(4) 

Y §98.256(f)(11) 3 Units of measure for the unit-specific CH4 emission factor. Used in method 

specified in 

§98.253(c)(4) 

Y §98.256(f)(11) Activity data for calculating emissions (input). Used in method 

specified in 

§98.255(c)(4) 

Y §98.256(f)(11) Activity data for calculating emissions (product). Used in method 

specified in 

§98.255(c)(4) 

Y §98.256(f)(12) Activity data for calculating emissions (input). Used in method 

specified in 

§98.255(c)(5) 

Y §98.256(f)(12) Activity data for calculating emissions (production). Used in method 

specified in 

§98.255(c)(5) 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

21 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

Y §98.256(f)(12) If a unit-specific emission factor for N2O was used: report the unit-specific 

emission factor for N2O each catalytic cracking units, traditional fluid 

coking units, and catalytic reforming units. 

Used in method 

specified in 

§98.253(c)(5) 

Y §98.256(f)(12) 3 Units of measure for the unit-specific N2O emission factor. Used in method 

specified in 

9§8.253(c)(5) 

Y §98.256(f)(13) Average carbon content of coke. Y-11 

Y §98.256(h)(4) 3 If Equation Y-12 is used: report the molar volume conversion factor. Y-12 

Y §98.256(h)(4) If Equation Y-12 is used: Annual volumetric flow to the sulfur recovery 

plant. 

Y-12 

Y §98.256(h)(4) If Equation Y-12 is used: Annual average mole fraction of carbon in the sour 

gas. 

Y-12 

Y §98.256(h)(5) Annual volume of recycled tail gas (if used to calculate recycling correction 

factor). 

Used in method 

specified in 

§98.253(h)3) 

Y §98.256(h)(5) Annual average mole fraction of carbon in the tail gas (if used to calculate 

recycling correction factor). 

Used in method 

specified in 

§98.253(h)3) 

Y §98.256(i)(5) If you use Eq. Y-13, report the annual mass of green coke fed to the for each 

coke calcining unit. 

Y-13 

Y §98.256(i)(5) If you use Eq. Y-13, report the carbon content of green coke fed to the for 

each coke calcining unit. 

Y-13 

Y §98.256(i)(5) If you use Eq. Y-13, report the annual mass of marketable coke produced for 

each coke calcining unit. 

Y-13 

Y §98.256(i)(5) If you use Eq. Y-13, report the carbon content of marketable coke produced 

for each coke calcining unit. 

Y-13 

Y §98.256(i)(5) If Equation Y-13 used for coke calcining units: report the annual mass of 

coke dust removed from the process through collected in dust collection 

systems. 

Y-13 

Y §98.256(i)(7) For coke calcining: Activity data for calculating emissions (input data). Used in method 

specified in 

§98.253(c)(4) 

Y §98.256(i)(7) For coke calcining: Activity data for calculating emissions (production data). Used in method 

specified in 

§98.253(c)(4) 

Y §98.256(i)(7) For coke calcining: The unit-specific CH4 emission factor. Used in method 

specified in 

§98.253(c)(4) 

Y §98.256(i)(7) For coke calcining: Units of measure for the unit-specific CH4 emission 

factor.2

Used in method 

specified in 

§98.253(c)(4) 

Y §98.256(i)(8) For coke calcining: If a unit specific emission factor was used for the N2O 

factor: report the activity data used for calculating emissions. 

Used in method 

specified in 

§98.253(c)(5) 

Y §98.256(i)(8) For coke calcining: If a unit-specific emission factor for N2O was used, 

report the site-specific emission factor. 

Used in method 

specified in 

§98.253(c)(5) 

Y §98.256(i)(8) 3 For coke calcining: If a unit specific emission factor was used for the N2O 

factor: report the units of measure for the unit-specific factor. 

Used in method 

specified in 

§98.253(c)(5) 

Y §98.256(j)(2) Quantity of asphalt blown for each for each asphalt blowing unit. Y-14 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

22 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

Y §98.256(j)(2) Quantity of asphalt blown for each for each asphalt blowing unit. Y-15 

Y §98.256(j)(2) Quantity of asphalt blown for each for each asphalt blowing unit. Y-16a 

Y §98.256(j)(2) Quantity of asphalt blown for each for each asphalt blowing unit. Y-16b 

Y §98.256(j)(2) Quantity of asphalt blown for each for each asphalt blowing unit. Y-17 

Y §98.256(j)(5) CO2 emission factor for each asphalt blowing unit. Y-14 

Y §98.256(j)(6) CH4 emission factor for each asphalt blowing unit. Y-15 

Y §98.256(j)(7) If Equation Y-16 is used: report the carbon emission factor. Y-16a 

Y §98.256(j)(8) If Equation Y-16b is used: report the CO2 emission factor used. Y-16b 

Y §98.256(j)(8) If Equation Y-16b is used: report the carbon emission factor. Y-16b 

Y §98.256(j)(9) If you use Eq. Y-17: CH4 emission factor. Y-17 

Y §98.256(k)(3) For delayed coking units: Dimensions of coke drum or vessel. Y-18 

Y §98.256(k)(3) For delayed coking units: Typical gauge pressure of the coking drum when 

first vented to the atmosphere. 

Y-18 

Y §98.256(k)(3) For delayed coking units: Typical void fraction of coke drum or vessel. Y-18 

Y §98.256(k)(3) For delayed coking units: Annual number of coke-cutting cycles of coke 

drum or vessel. 

Y-18 

Y §98.256(k)(3) 3 For delayed coking units: report the molar volume conversion factor for each 

coke drum or vessel. 

Y-18 

Y §98.256(k)(4) For delayed coking units: Height and diameter of the coke drums. Y-18 

Y §98.256(k)(4) For delayed coking units: Cumulative number of vessel openings for all 

delayed coking drums in the set. 

Y-18 

Y §98.256(k)(4) For delayed coking units: Typical venting pressure. Y-18 

Y §98.256(k)(4) For delayed coking units: Void fraction. Y-18 

Y §98.256(l)(5) 3 For each process vent: Molar volume conversion factor. Y-19 

Y §98.256(m)(3) Uncontrolled blowdown systems reporting under §98.253 (k): CH4 emission 

factor used. 

Y-20 

Y §98.256(m)(3) 3 Uncontrolled blowdown systems reporting under §98.253 (k): Molar volume 

conversion factor. 

Y-20 

Y §98.256(m)(3) Uncontrolled blowdown systems reporting under §98.253 (k): Total quantity 

of crude oil plus the quantity of intermediate products received from off-site 

that are processed at the facility in the reporting year. 

Y-20 

Y §98.256(o)(2)(ii) Total quantity of crude oil plus the quantity of intermediate products 

received from off-site that are processed at the facility in the reporting year. 

Y-22 

Y §98.256(o)(4)(ii) For storage tanks that process unstabilized crude oil: Quantity of unstabilized 

crude oil received during the calendar year. 

Y-23 

Y §98.256(o)(4)(iii) For storage tanks that process unstabilized crude oil: Average pressure 

differential. 

Y-23 

Y §98.256(o)(4)(iv) 3 For storage tanks that process unstabilized crude oil: Molar volume 

conversion factor. 

Y-23 

Y §98.256(o)(4)(v) For storage tanks that process unstabilized crude oil: Average Mole fraction 

of CH4 in vent gas from the unstabilized crude oil storage tanks. 

Y-23 

Y §98.256(p)(2) For loading operations: Quantity of materials loaded by vessel type that have 

an equilibrium vapor-phase concentration of CH4 of 0.5 volume percent or 

greater. 

Used in methods 

specified in AP42, Section 5.2 

(referenced by 

§98.253(n)) 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

23 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

Z §98.266(f)(5) Monthly inorganic carbon content of phosphate rock for each wet-process 

phosphoric acid process line for which Equation Z-1a is used (percent by 

weight, expressed as decimal fraction) (No CEMS). 

Z-1a 

Z §98.266(f)(5) Monthly CO2 (ton CO2/ton of phosphate rock) for which Equation Z-1b is 

used (No CEMS). 

Z-1b 

Z §98.266(f)(6) Monthly mass of phosphate rock consumed by origin in production. Z-1a 

Z §98.266(f)(6) Monthly mass of phosphate rock consumed by origin in production. Z-1b 

AA §98.276(b) Annual quantities of fossil fuels used in chemical recovery furnaces. C-1 

AA §98.276(b) Annual quantities of fossil fuels used in chemical recovery furnaces. C-1a 

AA §98.276(b) Annual quantities of fossil fuels used in chemical recovery furnaces. C-1b 

AA §98.276(b) Annual quantities of fossil fuels used in chemical recovery furnaces. C-2a 

AA §98.276(b) Annual quantities of fossil fuels used in chemical recovery furnaces. C-3 

AA §98.276(b) Annual quantities of fossil fuels used in chemical recovery combustion units. C-4 

AA §98.276(b) Annual quantities of fossil fuels used in chemical recovery combustion units. C-5 

AA §98.276(b) Annual quantities of fossil fuels used in chemical recovery combustion units. C-8 

AA §98.276(b) Annual quantities of fossil fuels used in chemical recovery combustion units. C-8a 

AA §98.276(b) Annual quantities of fossil fuels used in chemical recovery combustion units. C-8b 

AA §98.276(b) Annual quantities of fossil fuels used in chemical recovery combustion units. C-9a 

AA §98.276(c) Annual mass of the spent liquor solids combusted. AA-1 

AA §98.276(c) Annual mass of the spent liquor solids combusted. AA-2 

AA §98.276(d) High heat value (HHV) of the spent liquor solids used in Equation AA-1. AA-1 

AA §98.276(f) Carbon content of the spent liquor solids used in Equation AA-2. AA-2 

AA §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C-1 

AA §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C-1a 

AA §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C-1b 

AA §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C-2a 

AA §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C-3 

AA §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C-4 

AA §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C-5 

AA §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C-8 

AA §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C-8a 

AA §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C-8b 

AA §98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns. C-9a 

AA §98.276(h) Make-up quantity of CaCO3 used for the reporting year used in Equation 

AA-3. 

AA-3 

AA §98.276(i) Make-up quantity of Na2CO3 used for the reporting year used in Equation 

AA-3. 

AA-3 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

24 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

BB §98.286(b)(1) Monthly consumption of petroleum coke (No CEMS). BB-2 

BB §98.286(b)(4) Carbon content factor of petroleum coke from the supplier or as measured by 

the applicable method. 

BB-1 

BB §98.286(b)(6) CO2 emissions factor for each month. BB-2 

CC §98.296(b)(5) Monthly consumption of trona or liquid alkaline feedstock for each 

manufacturing line (No CEMS) (for facilities using Equation CC-1). 

CC-1 

CC §98.296(b)(6) Monthly production of soda ash for each manufacturing line (tons) (for 

facilities using Equation CC-2). 

CC-2 

CC §98.296(b)(7) Inorganic carbon content factor of soda ash. CC-1 

CC §98.296(b)(7) Inorganic carbon content factor of trona . CC-2 

EE §98.316(b)(6) Monthly calcined petroleum coke consumption for each production line (No 

CEMS). 

EE-2 

EE §98.316(b)(9) Monthly carbon content factor of petroleum coke (percent by weight 

expressed as a decimal fraction) (No CEMS). 

EE-2 

GG §98.336(b)(6) Annual mass of each carbon-containing input material charged to each kiln 

or furnace (No CEMS) - Mass of zinc bearing material. 

GG-1 

GG §98.336(b)(6) Annual mass of each carbon-containing input material charged to each kiln 

or furnace (No CEMS) - Annual mass of flux materials (e.g., limestone, 

dolomite) charged to kiln or furnace “k” (tons). 

GG-1 

GG §98.336(b)(6) Annual mass of each carbon-containing input material charged to each kiln 

or furnace (No CEMS) - Annual mass of carbon electrode consumed in 

furnace “k”. 

GG-1 

GG §98.336(b)(6) Annual mass of each carbon-containing input material charged to each kiln 

or furnace (No CEMS) - Annual mass of other carbonaceous material 

consumed in furnace “k”. 

GG-1 

GG §98.336(b)(7) Carbon content of carbon-containing input materials charged to kilns or 

furnace (including zinc bearing material, flux materials, and other 

carbonaceous materials) from the annual carbon analysis or from information 

provided by the material supplier) for each kiln or furnace (percent by 

weight, expressed as a decimal fraction) (No CEMS) - zinc bearing material. 

GG-1 

GG §98.336(b)(7) Carbon content of carbon-containing input materials charged to kilns or 

furnace (including zinc bearing material, flux materials, and other 

carbonaceous materials) from the annual carbon analysis or from information 

provided by the material supplier) for each kiln or furnace (percent by 

weight, expressed as a decimal fraction) (No CEMS) - flux materials. 

GG-1 

GG §98.336(b)(7) Carbon content of carbon-containing input materials charged to kilns or 

furnace (including zinc bearing material, flux materials, and other 

carbonaceous materials) from the annual carbon analysis or from information 

provided by the material supplier) for each kiln or furnace (percent by 

weight, expressed as a decimal fraction) (No CEMS) - other carbonaceous 

materials. 

GG-1 

GG §98.296(b)(10) Carbon content of the carbon electrodes used in each furnace from the 

annual carbon analysis or from information provided by the material 

supplier) (percent by weight, expressed as a decimal fraction) (No CEMS). 

GG-1 

TT §98.466(c)(3)(i) Total number of years (N) for which disposal and production data are both 

available. 

TT-2 

TT §98.466(c)(3)(ii) The waste disposal quantity for each year used in Equation TT–2 of this 

subpart to calculate the average waste disposal factor (WDF). 

TT-2 

TT §98.466(c)(3)(iii) Average waste disposal factor (WDF) calculated for the waste stream. TT-3 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

25 

1 This table excludes the five subpart V “inputs to equations” data elements in §98.226(c) (included in Table A-7 of subpart A of

part 98). In its memorandum “Evaluation of Competitive Harm from Reporting “Inputs to Equations” Data Elements Deferred to 

March 31, 2015” (refer to docket EPA-HQ-OAR-2010-0929), EPA identified these five “inputs to equations” data elements as 

production or raw material data, which were identified as having disclosure concerns. Based on these analysis results, EPA would 

have included these data elements in this table as part of its proposal to remove reporting of these data; however, EPA has 

excluded the data elements from this table because §98.226(c) is already removed from Subpart V. §98.226(c) was inadvertently 

removed and reserved in conjunction with the 2010 technical corrections rulemaking (75 FR 79157, December 17, 2010); based 

on the results of its analysis, EPA is not taking any action to reinstate this provision. 2

 Combustion units connected to devices connected to the local or regional power grid include combustion units subject to 

subpart C of Part 98 (excludes facilities subject to subpart D of Part 98) that meet the following criteria: (1) the combustion unit 

is connected to a device that has been granted access by the Public Utilities Commission to deliver power to the local or regional 

electric power grid (e.g., electricity generators); and (2) the combined nameplate capacity (for all such devices at the facility) is 

greater than or equal to 1 megawatt electric. 

3

 Data element would not be useful for data verification and would not inform future GHG policy development, in the absence of 

other data elements included in this table for which we are proposing to remove the reporting requirement. 

Table 2. List of “Inputs to Equations” Data Elements That EPA is Not Amending Under 

the Proposed Revisions to Part 98 (i.e., Data Elements Would Be Reported 1

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.3(d)(3)(v) For any facility who submitted an abbreviated emissions report under 

§98.3(d)(3)(v), any facility operating data or process information used for 

the GHG emission calculations. 

 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(b)(9)(iii) Estimate of the heat input from each type of fuel listed in Table C-2 that was 

combusted in the unit during the report year. 

C-10 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(c)(2)(ix) The flue gases from two or more stationary fuel combustion units at a 

facility are combined together and discharged through a common stack or 

duct before exiting to the atmosphere and if CEMS are used to continuously 

monitor CO2 mass emissions at the common stack or duct according to the 

Tier 4 Calculation Methodology, you may report the combined emissions 

from the units sharing the common stack or duct, in lieu of separately 

reporting the GHG emissions from the individual units. This monitoring and 

reporting alternative may also be used when process off-gases or a mixture 

of combustion products and process gases are combined together in a 

common stack or duct before exiting to the atmosphere. An estimate of the 

heat input from each type of fuel listed in Table C-2 combusted during the 

reporting year. 

C-10 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(i) Total quantity of each type of fuel combusted in each unit or group of 

aggregated units (as applicable) during the reporting year, in short tons for 

solid fuels, gallons for liquid fuels and standard cubic feet for gaseous fuels, 

or, if applicable, therms or mmBtu for natural gas. 

C-1 
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26 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(i) Total quantity of each type of fuel combusted in each unit or group of 

aggregated units (as applicable) during the reporting year, in short tons for 

solid fuels, gallons for liquid fuels and standard cubic feet for gaseous fuels, 

or, if applicable, therms or mmBtu for natural gas. 

C-1a 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(i) Total quantity of each type of fuel combusted in each unit or group of 

aggregated units (as applicable) during the reporting year, in short tons for 

solid fuels, gallons for liquid fuels and standard cubic feet for gaseous fuels, 

or, if applicable, therms or mmBtu for natural gas. 

C-1b 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(i) Total quantity of each type of fuel combusted in each unit or group of 

aggregated units (as applicable) during the reporting year, in short tons for 

solid fuels, gallons for liquid fuels and standard cubic feet for gaseous fuels, 

or, if applicable, therms or mmBtu for natural gas. 

C-8 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(ii)(A) For Tier 2: Total quantity of each type of fuel combusted in the unit or group 

of aggregated units (as applicable) during each month of the reporting year. 

Express the quantity of each fuel combusted during the measurement period 

in short tons for solid fuels, gallons for liquid fuels, and scf for gaseous 

fuels. 

C-2b 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(ii)(C) High heat values used in the CO2 emissions calculations for each fuel 

combusted during the reporting year. Report a HHV value for each calendar 

month in which HHV determination is required. If multiple values are 

obtained in a given month, report the arithmetic average value for the month. 

C-2b 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(ii)(D) If Eq. C-2c is used: Total quantity (i.e., pounds) of steam produced from 

MSW or solid fuel combustion during each month of the reporting year. 

C-2c 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(ii)(D) If Eq. C-2c is used: Ratio of the maximum rate heat input capacity to the 

design rated steam output capacity of the unit. 

C-2c 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as 

applicable) during each month of the reporting year (Fuel). 

C-13 
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27 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as 

applicable) during each month of the reporting year (Fuel). 

C-3 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as 

applicable) during each month of the reporting year (Fuel). 

C-4 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as 

applicable) during each month of the reporting year (Fuel). 

C-5 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as 

applicable) during each month of the reporting year (Fuel). 

C-8 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as 

applicable) during each month of the reporting year (Fuel). 

C-8a 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as 

applicable) during each month of the reporting year (Fuel). 

C-8b 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(iv)(C) The carbon content used in the emission calculations (including both valid 

and substitute data values). For each calendar month of the reporting year in 

which carbon content and, if applicable, molecular weight determination is 

required, report a value of each parameter. If multiple values of a parameter 

are obtained in a given month, report the arithmetic average value for the 

month. (CC) 

C-3 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(iv)(C) The carbon content used in the emission calculations (including both valid 

and substitute data values). For each calendar month of the reporting year in 

which carbon content and, if applicable, molecular weight determination is 

required, report a value of each parameter. If multiple values of a parameter 

are obtained in a given month, report the arithmetic average value for the 

month. (CC) 

C-4 
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28 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(iv)(C) The carbon content used in the emission calculations (including both valid 

and substitute data values). For each calendar month of the reporting year in 

which carbon content and, if applicable, molecular weight determination is 

required, report a value of each parameter. If multiple values of a parameter 

are obtained in a given month, report the arithmetic average value for the 

month. (CC) 

C-5 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(iv)(C) Gas molecular weight values used in the emission calculations (including 

both valid and substitute data values). For each calendar month of the 

reporting year in which carbon content and, if applicable, molecular weight 

determination is required, report a value of each parameter. If multiple 

values of a parameter are obtained in a given month, report the arithmetic 

average value for the month. 

C-5 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(iv)(F) The annual average HHV, when measured HHV data, rather than a default 

HHV from Table C-1 of this subpart, are used to calculate CH4 and N2O 

emissions for a Tier 3 unit, in accordance with §98.33(c)(1). 

C-8 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(ix)(D) For units that combust both fossil fuel and biomass, when biogenic CO2 is 

determined according to §98.33(e)(2), report the carbon-based F-factor used 

in Equation C-13 of this subpart. 

C-13 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(ix)(E) For units that combust both fossil fuel and biomass, when biogenic CO2 is 

determined according to §98.33(e)(2), report the annual average HHV value 

used in Equation C-13 of this subpart. 

C-13 

C (Combustion 

units connected 

to devices 

connected to the 

local or regional 

power grid)2

§98.36(e)(2)(ix)(F) For units that combust both fossil fuel and biomass, when biogenic CO2 is 

determined according to §98.33(e)(2), report the total quantity of fossil fuel 

combusted during the reporting year. 

C-13 

E §98.56(g) Abatement technology destruction efficiency for each abatement technology 

(DF). 

 E-3a 

E §98.56(g) Abatement technology destruction efficiency for each abatement technology 

(DF). 

 E-3c 

E §98.56(g) Abatement technology destruction efficiency for each abatement technology 

(DF). 

E-3b 

E §98.56(h) Abatement utilization factor for each abatement technology (AF ). E-3a 

E §98.56(h) Abatement utilization factor for each abatement technology (AF). E-3c 

E §98.56(j)(4) N2O concentration per test run during performance test for each unit 

(CN2O). 

E-1 

E §98.56(j)(5) Volumetric flow rate per test run during performance test for each unit (Q). E-1 

E §98.56(j)(6) Number of test runs for each unit (n). E-1 
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29 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

E §98.56(l) Fraction control factor for each abatement technology (percent of total 

emissions from the production unit that are sent to the abatement 

technology) if equation E-3c is used. (FCN) 

E-3c 

E §98.56h Abatement utilization factor for each abatement technology. (AF) E-3b 

H §98.86(b)(11) Quarterly kiln-specific CKD CO2 emission factors for each kiln. H-2 

H §98.86(b)(13) Name of raw kiln feed or raw material. 

L §98.126(b)(10) 3 The fraction of the mass emitted that consists of each fluorine-containing 

reactant (FERd). 

L-11 

L §98.126(b)(10) 3 The fraction of the mass emitted that consists of each fluorine-containing 

reactant. (FERd). 

L-12 

L §98.126(b)(10) 3 The fraction of the mass emitted that consists of each fluorine-containing 

reactant (FERd). 

L-13 

L §98.126(b)(11) 3 The fraction of the mass emitted that consists of the fluorine-containing 

product (FEP). 

L-11 

L §98.126(b)(11) 3 The fraction of the mass emitted that consists of the fluorine-containing 

product. (FEP) 

L-12 

L §98.126(b)(11) 3 The fraction of the mass emitted that consists of the fluorine-containing 

product. (FEP). 

L-13 

L §98.126(b)(12) 3 The fraction of the mass emitted that consists of each fluorine-containing byproduct (FEBk). L-11 

L §98.126(b)(12) 3 The fraction of the mass emitted that consists of each fluorine-containing byproduct. (FEBk) L-12 

L §98.126(b)(12) 3 The fraction of the mass emitted that consists of each fluorine-containing byproduct. (FEBk) L-13 

O §98.156(d)(2) If the HFC-23 concentration measured pursuant to §98.154(l) is greater than 

that measured during the performance test that is the basis for the destruction 

efficiency (DE), report concentration (mass fraction) of HFC-23 at the outlet 

of the destruction device. 

No Equation - 

Used to calculate 

Destruction 

Efficiency 

O §98.156(d)(3) If the HFC-23 concentration measured pursuant to §98.154(l) is greater than 

that measured during the performance test that is the basis for the destruction 

efficiency (DE), report flow rate at the outlet of the destruction device in 

kg/hr. 

No Equation - 

Used to calculate 

Destruction 

Efficiency 

O §98.156(d)(4) If the HFC-23 concentration measured pursuant to §98.154(l) is greater than 

that measured during the performance test that is the basis for the destruction 

efficiency (DE), report emission rate (in kg/hour) calculated from the 

paragraphs (d)(2) and (d)(3) of this section. 

No Equation - 

Used to calculate 

Destruction 

Efficiency 

Q §98.176(f)(1) Measured average hourly CO2 emission rate during the test (No CEMS). No Equation - 

Used as input to 

method described 

in 

§98.173(b)(2)(iii). 

V §98.226(i) Abatement technology destruction efficiency (DF). V-3a 

V §98.226(i) Abatement technology destruction efficiency (DF). V-3b 

V §98.226(i) Abatement technology destruction efficiency (DF). V-3c 

V §98.226(j) Abatement utilization factor (AF). V-3a 

V §98.226(j) Abatement utilization factor (AF). V-3b 

V §98.226(j) Abatement utilization factor (AF). V-3c 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

30 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

V §98.226(m)(4) N2O concentration per test run during performance test for each train. V-1 

V §98.226(m)(5) Volumetric flow rate per test run during performance test each train. V-1 

V §98.226(m)(6) Number of test runs during performance test each train. V-1 

V §98.226(p) Fraction control factor for each abatement technology (percent of total 

emissions from the production unit that are sent to the abatement 

technology) if equation V-3c is used. 

V-3c 

Y §98.256(h)(5) Value of the correction. Used in method 

specified in 

§98.253(h)3) 

Y §98.256(k)(4) For delayed coking units: Mole fraction of methane in coking gas. Y-18 

Y §98.256(n)(3) For equipment leaks: Number of each type of emission source listed in 

Equation Y-21 (if using Eq. Y-21). 

Y-21 

Y §98.256(o)(4)(vi) 4 If you did not use Equation Y-23: report the gas generation rate data used to 

estimate cumulative CH4 emissions for storage tanks used to process 

unstabilized crude oil.. 

Used in methods 

specified in 

§98.253(m)(2) 

Y §98.256(o)(4)(vi) 4 If you did not use Equation Y-23: report the tank-specific methane 

composition data used to estimate cumulative CH4 emissions for storage 

tanks used to process unstabilized crude oil. 

Used in methods 

specified in 

§98.253(m)(2) 

Y §98.256(o)(6) 5 Mole fraction of CH4 in vent gas from the unstabilized crude oil storage 

tank. 

Y-23 

Y §98.256(o)(6) 5 Average pressure differential. Y-23 

Y §98.256(o)(6) 5 Quantity of unstabilized crude oil received during the calendar year. Y-23 

Y §98.256(o)(7) 5 Tank-specific methane composition data. Used in methods 

specified in 

§98.253(m)(2) 

Y §98.256(o)(7) 5 Gas generation rate data. Used in methods 

specified in 

§98.253(m)(2) 

AA §98.276(e) Default or site specific emission factor for CO2 used in equation AA-1. AA-1 

AA §98.276(e) Default or site specific emission factor for CH4 used in equation AA-1. AA-1 

AA §98.276(e) Default or site specific emission factor for N2O used in equation AA-1. AA-1 

CC §98.296(b)(10)(i) Stack gas volumetric flow rate during performance test (dscfm) for each 

manufacturing line or stack. 

CC-3 

CC §98.296(b)(10)(ii) Hourly CO2 concentration during performance test (percent CO2) for each 

manufacturing line or stack. 

CC-3 

CC §98.296(b)(10)(iii) CO2 emission factor of process vent flow from mine water for each 

manufacturing line or stack. 

CC-5 

CC §98.296(b)(10)(iv) CO2 emission mass emission rate during performance test (metric tons/hour) 

for each manufacturing line or stack. 

CC-4 

CC §98.296(b)(10)(v) Average process vent flow from mine water stripper/evaporator during 

performance test for each manufacturing line or stack. 

CC-4 

CC §98.296(b)(10)(vi) Annual process vent flow rate from mine stripper/evaporator for each 

manufacturing line or stack. 

CC-5 

II §98.356(d)(2) Cumulative volumetric biogas flow for each week that biogas is collected for 

destruction (if using weekly sampling). 

II-4 

II §98.356(d)(3) Weekly average CH4 concentration for each week that biogas is collected 

for destruction (if using weekly sampling). 

II-4 
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31 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . 

II §98.356(d)(4) Weekly average temperature at which flow is measured for biogas collected 

for destruction (if using weekly sampling). 

II-4 

II §98.356(d)(5) Weekly average moisture content for each week at which flow is measured 

for biogas collected for destruction (if using weekly sampling). 

II-4 

II §98.356(d)(6) Weekly average pressure for each week at which flow is measured for 

biogas collected for destruction (if using weekly sampling). 

II-4 

1

Of the 85 “inputs to equations” data elements listed in this table, reporting of 16 of these data elements will be addressed under separate EPA

actions, as specified in this table for each such data element. Therefore, EPA is taking no action on these 16 data elements under this proposal. 2 Combustion units connected to devices connected to the local or regional power grid include combustion units subject to subpart C of Part 98

(excludes facilities subject to subpart D of Part 98) that meet the following criteria: (1) the combustion unit is connected to a device that has

been granted access by the Public Utilities Commission to deliver power to the local or regional electric power grid (e.g., electricity generators);

and (2) the combined nameplate capacity (for all such devices at the facility) is greater than or equal to 1 megawatt electric. 3 Reporting of this data element will be addressed under a separate EPA rulemaking; therefore, EPA is taking no action on this data element

under this rulemaking. 4

This data element is proposed to be revised in the March 2013 rulemaking,“2013 Revisions to the Greenhouse Gas Reporting Rule and

Proposed Confidentiality Determinations for New or Substantially Revised Data Elements,” (April 2, 2013, 78 FR 198802); therefore, EPA is 

taking no action on this data element under this rulemaking. 5

This data element is proposed to be removed from Part 98 in the March 2013 rulemaking,“2013 Revisions to the Greenhouse Gas Reporting

Rule and Proposed Confidentiality Determinations for New or Substantially Revised Data Elements,” (April 2, 2013, 78 FR 198802); therefore,

EPA is taking no action on this data element under this rulemaking.
Attachment O 
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1 

TECHNICAL MEMORANDUM 

DATE: April 2013 

TO: Docket EPA-HQ-OAR-2010-0929 

FROM: Lisa Grogan-McCulloch, U.S. EPA

SUBJECT: Summary of Data Collected to Support Determination of Public Availability 

of Inputs to Emission Equations for which Reporting was Deferred to March 

31, 2015 

1.0 Introduction and Purpose of Analysis 

In the August 25, 2011 final rule deferring reporting to March 31, 2015 of certain inputs 

to emission equations under 40 CFR part 98 (76 FR 53057), EPA expressed its intent to further 

evaluate the inputs to emission equations to determine which, if any, could result in competitive 

harm if made publicly available. EPA outlined a four-step process for this evaluation in the final 

rule, and in a supporting memorandum entitled “Process for Evaluating and Potentially 

Amending Part 98 Inputs to Emission Equations” (docket EPA-HQ-OAR-2010-0929). 

The purpose of this memorandum is to describe the review undertaken for the first step of 

the evaluation process: EPA’s analysis of public availability of the inputs to emission equations 

deferred to March 31, 2015 (hereafter referred to as “inputs to equations”). The review was 

undertaken for 27 of the 28 subparts of the greenhouse gas reporting program (GHGRP) with 

“inputs to equations” data elements.1

 

Section 2.0 of this memorandum presents the procedures used to collect and review input 

data. Section 3.0 presents a summary of the information sources reviewed. Section 4.0 presents a 

summary of the 2015 data inputs that were evaluated to be the same as publicly available 

information. Appendix A lists the 2015 data inputs. Appendix B provides detail on the data 

gathered from each of the sources reviewed for the subparts analyzed. Appendix C provides 

additional detail on data gathered to evaluate references cited by commenters to various GHGRP 

Federal Register notices that data on the “inputs to equations” data elements were publicly 

available. 

 

 

1

 The review was not conducted for 2015 data inputs in subpart I because reporting of the “inputs to equations” data 

elements for that subpart was addressed in a separate proposed action [see 77 FR 63538]. Additionally, the 

evaluation of the subpart C “inputs to equations” in this memorandum encompasses the one subpart A “input to 

equation” data element. As a result, the one subpart A “input to equation” is not listed explicitly in this 

memorandum. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

2 

2.0 Procedure for Collecting Supporting Data 

A search was conducted to identify publicly available data that are identical to the “inputs 

to equations” data elements. Data sources that were reviewed included federal, local, and state 

inventory databases (e.g., clean air markets division (CAMD) for the acid rain program and the 

national emissions inventory (NEI); rulemaking dockets; Title V permits; trade and technical 

journals; internet searches; and sources identified in comments to the call for information or 

Federal Register deferral notices. Section 3.0 presents a detailed summary of the sources 

reviewed. 

Data were evaluated on whether they were the same as the “inputs to equations” data 

elements. Information was also gathered to help characterize whether publicly available data are 

representative of part 98 reporters. This characterization consisted of identifying: 

 The number of reporters represented by the data; 

 The age of the data; and 

 The frequency of data availability (i.e., whether the data were publicly available on a 

one-time basis or are publicly available on a recurring basis). 

3.0 Sources Reviewed 

As noted in Section 2.0, various sources of information were reviewed to determine the 

public availability or non-availability of each “inputs to equations” data elements. Sections 3.1 

through 3.6 discuss the specific sources of data reviewed for this evaluation. Tables 4-1 through 

4-3 in section 4.0 summarize the results of the data gathering. 

3.1 Regulatory Development Dockets 

Dockets containing supporting information used to develop air regulations, such as 

National Emission Standards for Hazardous Air Pollutants (NESHAP) and New Source 

Performance Standards (NSPS), were reviewed to identify data that are the same as the “inputs to 

equations” data elements. As shown in Table 3-1, the EPA identified dockets relevant to 15 of 

the 27 industry subparts included in this review. 

The age of the data varies between 1992 and 2009, depending on the years the regulation 

was under development. Section 4.0 summarizes the information found in the regulatory 

development dockets that is the same as the “inputs to equations” data elements. References for 

information and data from rule development dockets are listed as items A-1 through A-134 in 

Section 5.0. 

Table 3-1. Summary of Regulatory Development Dockets Identified as Applicable for Each 

GHG Subpart 

Subpart Dockets Reviewed Docket Number 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

3 

Subpart Dockets Reviewed Docket Number 

C NESHAP for Industrial, Commercial, and 

Institutional Boilers and Process Heaters - Area 

Sources (40 CFR part 63 subpart JJJJJJ) 

EPA-HQ-OAR-2006-0790 

NESHAP for Industrial, Commercial, and 

Institutional Boilers and Process Heaters - Major 

Sources (40 CFR part 63 subpart DDDDD) 

EPA-HQ-OAR-2002-0058 

E No applicable docket identified 

F NESHAP for Primary Aluminum (40 CFR part 63 

subpart LL) 

A-92-60; 

EPA-HQ-OAR-2002-0032 

G No applicable docket identified 

H NESHAP for Portland Cement Manufacturing (40 

CFR part 63 subpart LLL) 

A-92-53; 

EPA-HQ-OAR-2002-0051 

K NESHAP for Ferroalloys Manufacturing – Area 

Sources (40 CFR part 63 subpart YYYYYY) 

EPA-HQ-OAR-2008-0154 

NESHAP from Ferroalloys Production: 

Ferromanganese and Silicomanganese (40 CFR part 

63 subpart XXX) 

EPA-HQ-OAR-2004-0375, 

EPA-HQ-OAR-2010-0895 

L No applicable docket identified 

N NESHAP for Glass Manufacturing – Area Sources 

(40 CFR part 63 subpart SSSSSS) 

EPA-HQ-OAR-2006-0360 

O No applicable docket identified 

P No applicable docket identified 

Q NESHAP for Electric Arc Furnace Steelmaking 

Facilities - Area Sources (40 CFR part 63 subpart 

YYYYY) 

EPA-HQ-OAR- 2004-0083 

R NESHAP for Primary Lead Smelting (40 CFR part 

63 subpart TTT) 

A-97-33; 

EPA-HQ-OAR-2004-0305 

NESHAP for Secondary Lead Smelting Amendments 

Based on the Risk and Technology Review (40 CFR 

part 63 subpart X) 

A-92-43; 

EPA-HQ-OAR-2011-0344; 

S NESHAP for Lime Manufacturing (40 CFR part 63 

subpart AAAAA) 

A-95-41; 

EPA-HQ-OAR-2002-0052 

U No applicable docket identified 

V NSPS for Nitric Acid Plants (40 CFR part 60 subpart 

G) 

EPA-HQ-OECA-2009-0525; 

EPA-HQ-OECA-2006-0437; 

EPA-HQ-OECA-2003-0030 

W NESHAP for Oil and Natural Gas Production, 

including Area Sources (40 CFR part 63 subpart HH) 

A-94-04; 

EPA-HQ-OAR-2004-0238; 

EPA-HQ-OAR-2004-0383 

NESHAP for Natural Gas Transmission and Storage 

(40 CFR part 63 subpart HHH) 

A-94-04; 

EPA-HQ-OAR-2004-0238; 

EPA-HQ-OAR-2004-0383 

NSPS for New Stationary Sources of Oil and Natural 

Gas Production and Natural Gas Transmission and 

EPA-HQ-OAR-2010-0505 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

4 

Subpart Dockets Reviewed Docket Number 

Distribution (40 CFR 60 subpart OOOO) 

X NESHAP for Ethylene Processes (40 CFR part 63 

subparts YY and UU) 

A-2000-14; 

EPA-HQ-OAR-2004-0411 

Y NSPS for Petroleum Refineries (40 CFR part 60 

subpart J) 

EPA-HQ- OAR-2007-0011 

Z NESHAP for Phosphoric Acid / Phosphate Fertilizers 

(40 CFR part 63 subpart AA) 

A-94-02; 

EPA-HQ-OAR-2004-0382 

AA NESHAP for Pulp and Paper (40 CFR part 63 

subpart S) 

A-92-40; 

EPA-OAR-2002-0045; 

EPA-HQ-OAR-2007-0544 

NSPS for Kraft Pulp Mills (40 CFR part 60 subpart 

BB) 

EPA-HQ-OECA-2011-0242; 

EPA-HQ-OAR-2007-0544 

BB No applicable docket identified 

CC No applicable docket identified 

EE No applicable docket identified 

GG NESHAP for Nonferrous Foundries: Aluminum, 

Copper, and Other – Area Sources (40 CFR part 63 

subpart ZZZZZZ) 

EPA-HQ-OAR-2008-0236 

NESHAP for 4 Area Source Categories (Including 

amendments to National Emission Standards for 

Hazardous Air Pollutants for Primary Copper 

Smelting and Secondary Copper Smelting, and 

Primary nonferrous metals-Zinc, Cadmium, and 

Beryllium) 

EPA-HQ-OAR-2006-0510 

II No applicable docket identified 

TT No applicable docket identified 

3.2 Title V Operating Permits 

Most large emission sources, and some smaller sources, are required to obtain Title V 

operating permits. Title V operating permits that were available online were reviewed for public 

availability of the “inputs to equations” data elements. Title V permits were not reviewed for 

states that did not have them available online. For most subparts, permits were reviewed for at 

least 10 percent of the facilities reporting under each applicable subpart (if available online). Due 

to the large number of sources subject to subparts C and AA, the number of permits reviewed 

was capped at 10 for subpart C and 15 for subpart AA. For industry sectors in which reporters 

are located in multiple states, Title V permits were reviewed for facilities in most, if not all, 

applicable states. Table 3-2 summarizes the number of Title V permits reviewed for each GHG 

subpart and the states for which the permits were obtained. Section 4.0 summarizes the 

information found in the Title V permits that is the same as the “inputs to equations” data 

elements. A complete list of Title V permits reviewed is provided as items B-1 through B-197 in 

Section 5.0. 

 
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Table 3-2. Summary of Title V Permits Reviewed for each Subpart 

Subpart 

Permits Reviewed1

Number States 

C 10 AK, AR, CA, CO, IN, MO, NC, NY, RI, VA 

E 2 FL, TX 

F 3 NY, OH 

G 9 GA, IA, OH, OK, TX, VA, WY 

H 11 AZ, CO, FL, GA, ID, IN, ME, MI, MO, OH, OR 

K 1 OH 

L 4 AR, IL, NC 

N 10 AR, GA, IL, IN, MI, MO, NY, OH, OK, WI 

O 1 WV 

P 10 CA, IN, TX 

Q 10 AL, AR, CO, FL, IN, MI, NC, OH, UT, VA 

R 3 IN, NY 

S 10 AR, AZ, ID, IN, MO, OH, UT, VA, WI, WV 

U 10 CA, GA, ID, LA, MN, NC, OH, TX, WI 

V 10 AR, FL, GA, IA, ID, OH, OK, TX, UT, WY 

W 2-242 AK, AZ, CA, CO, FL, IA, IL, IN, LA, MI, MN, MO, MS, NC, NM, NY, OH, OK, 

TX, UT, VA, WI, WV, WY 

X 8 IA, IL, OH, OK, TX 

Y 13 AK, AR, CO, GA, IL, IN, MI, OK, TX, WI, WV, WY 

Z 5 FL, ID, NC, WY 

AA 15 AR, FL, GA, ID, IL, ME, MI, NC, NY, OH, OK, TX, VA, WI, WV 

BB 1 IL 

CC 3 WY 

EE 4 OH, MS 

GG 1 IL 

II 12 AR, CO, FL, IA, IN, SD, VA, WA 

TT 10 AR, FL, GA, ID, IN, ME, VA, WI 

1 Title V permits that were not available online were not reviewed. 

2 The number of permits reviewed varied for each of the “inputs to equations” data elements ranged from 2 to 24. 

3.3 Federal Databases 

The following six federal databases were reviewed for data identical to “inputs to 

equations” data elements: 

 National Emissions Inventory (NEI) – Includes comprehensive estimates of air emissions 

of criteria and hazardous air pollutants from all emission sources and compiles 

information collected from states, the TRI program, acid rain program, and EPA 

regulatory programs; 
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 Clean Air Markets Division (CAMD) Acid Rain Program database – Includes data from 

various market-based regulatory programs designed to improve air quality, particularly 

the acid rain program; 

 Emission and Generation Integrated Database (eGRID) – Includes information on 

environmental characteristics of electric power generation in the United States; 

 Toxic Release Inventory (TRI) Program – Includes information on disposal and release of 

toxic chemicals from U.S. facilities and how facilities manage those chemicals through 

recycling, energy recovery, and treatment; 

 Department of Energy (DOE)/Energy Information Administration (EIA) data – Includes 

information on the usage of fuel in each industry sector and by source; and 

 Office of Enforcement and Compliance Assurance (OECA) Enforcement and 

Compliance History Online (ECHO) tool – Includes compliance and enforcement 

information for regulated facilities nationwide. 

The information in these databases is published on a recurring basis. For NEI, data from 2008 

were reviewed. For all other federal databases, data available in 2011 for reporting year 2010 

were reviewed. Section 4.0 summarizes the information found in federal databases that is the 

same as the “inputs to equations” data elements. References for the federal databases listed 

above are provided as items C-1 through C-6 in Section 5.0. 

3.4 State and Regional Databases 

Online regional and state databases that publish data related to the industry sectors 

required to report “inputs to equations” data elements were also reviewed. Online databases were 

identified for three regions and 18 states that have considered adopting or have adopted 

mandatory GHG reporting programs. The following regional databases were reviewed: 

 The Climate Registry (TCR) – A voluntary collaboration between states that provides 

information on GHG emissions and methods to calculate and verify emissions; 

 Western Climate Initiative (WCI) – A cap and trade program with collaboration between 

Canadian provinces, Mexican states, and western U.S. states that includes information on 

GHG emissions; and 

 Regional Greenhouse Gas Initiative (RGGI) – A market-based regulatory program to 

reduce GHGs cooperatively between the states of CT, DE, ME, MD, MA, NH, NY, RI, 

and VT. 

Online databases published by the following states were reviewed: MA, CA, NJ, ME, IA, FL, 

HI, CT, CO, DE, MD, NC, NM, NV, OR, WA, WI, WV. 

These data are published on a recurring basis. For all regional and state databases, data 

available in 2011 were reviewed. Section 4.0 summarizes the information found in state and 

regional databases that is the same as the “inputs to equations” data elements. References for the 

regional databases listed above are provided as items D-1 through D-3 in Section 5.0. 

3.5 Journals 
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Trade and technical journals that publish data related to the industry sectors were also 

reviewed. Table 3-3 lists the trade journals associated with the industry subpart of interest that 

were identified. For each journal, the most current issue, samples of issues from 2011, and issues 

that provide an annual review or summary of information were reviewed. In general, information 

provided in the journals is provided on a one-time basis. Section 4.0 summarizes the information 

found in trade and technical journals that is the same as the “inputs to equations” data elements. 

References for trade and technical journals that were reviewed and were determined to have 

applicable information are listed as items E-1 through E-3 in Section 5.0. 

Table 3-3. Summary of Trade Journals Identified and Reviewed for Each Subpart 

Subpart Journal Name 

C Power Engineering Magazine 

Powergrid International 

E None Identified 

F Aluminum Today 

Light Metal Age 

Aluminum World 

Journal of Alloys and Compounds 

G None Identified 

H Cement and Concrete Composites 

World Cement 

Cement Americas 

Cement and Concrete Research 

Global Cement 

K Journal of Alloys and Compounds 

American Metal Market (USA) 

L None Identified 

N Glass and Ceramics, Glass Science and Technology 

O None Identified 

P Catalysis Today 

Q Iron and Steel Technology 

Foundry Management and Technology 

American Machinist 

Forging Magazine 

Advanced Materials and Processes 

Institute of Materials, Minerals, and Mining 

R None Identified 
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Subpart Journal Name 

S None Identified 

U None Identified 

V None Identified 

 
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W Hydrocarbon Processing 

World Oil 

Touch Oil and Gas 

Oil and Gas Journal 

X Hydrocarbon Processing 

World Oil 

Touch Oil and Gas 

Oil and Gas Journal 

Y Hydrocarbon Processing 

Touch Oil and Gas 

World Oil 

Oil and Gas Journal 

Z None Identified 

AA TAPPI 

Pulp and Paper International 

Paper Age 

Pulp and Paper Week 

Paperboard Packaging 

Timberline 

BB None Identified 

CC None Identified 

EE None Identified 

GG None Identified 

II Water & Wastes Digest 

Journal of Air and Waste Management Association (JAWMA) 

Waste Management 

Waste & Recycling News 

Waste Age 

Water Science & Technology 

Water and Environmental Management 

American Water Works Association Journal 

Pumps & Systems 

TT None Identified 

3.6 Other Internet Sources 

For subpart W, information was also found in various Internet sources that contained 

relevant information on the oil and gas industry, but not in a database. The following websites 

were identified: 
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 The EPA’s Natural Gas STAR Program - www.epa.gov/gasstar

 American Petroleum Institute: Industry Statistics - www.api.org/statistics

 DOI’s Bureau of Ocean Energy Management, Regulation and Enforcement - 

www.gomr.boemre.gov

 DOT’s Pipeline and Hazardous Materials Safety Administration: Data and Statistics - 

www.phmsa.dot.gov

 Energy Association of Pennsylvania - www.energypa.org

 Pennsylvania Public Utility Commission - www.puc.state.pa.us

 American Gas Association - www.cycla.com/opsiswc

 South Jersey Gas Company - www.southjerseygas.com

References for the websites presented above are listed as items F-1 through F-12 in Section 5.0. 

3.7 Comments on the Call for Information and Deferral Notice 

Public comments were submitted on the EPA’s December 27, 2010 deferral proposal and 

call for information [75 FR 81338; 75 FR 81350]. Only one commenter, Sierra Club, provided 

references for “inputs to equations” data elements that were publicly available. The Sierra Club 

comments indicated that data were publicly available for some of the “inputs to equations” data 

elements in five of the subparts: C, H, Q, W, and Y. In each instance that a specific source was 

cited to demonstrate public availability or non-availability, the cited source was reviewed to 

confirm whether the source did provide information on the “inputs to equations” data elements, 

and to assess whether the data in the source were sufficient for assessing public availability. 

Section 4.0 summarizes the review of the sources cited by Sierra Club and Appendix C contains 

a detailed review of the sources referenced in the Sierra Club comment letter. 

4.0 Summary of Results 

Table 4-1 summarizes the number of publicly released data that are identical to the inputs 

to equations. Detailed analyses for all the subparts, including age of the data, whether the data 

were a one-time occurrence or on-going, the number of sources reporting the data, and the exact 

reference for the data source, are provided in Appendix B. In Appendix B, separate tables were 

developed for subpart C because sources subject to subpart C are often also reporters for other 

subparts, and the level of information publicly available for the subpart C “inputs to equations” 

data elements varies by the industry sector. For example, information publicly available for the 

refining industry (subject to subpart Y) is significantly different than information publicly 

available for the lime industry (subject to subpart S) due to differing sector-specific regulations 

and trade publications. For electric generators, Table B-1D summarizes the information required 

to be reported in the DOE/EIA forms and information that is made publicly available from 

DOE/EIA from the forms. 

 Appendix C contains the list of “inputs to equations” data elements cited by Sierra Club 

in their comment letter to the Call for Information Notice [EPA-HQ-OAR-2010-0964-0029 and 

EPA-HQ-OAR-2010-0929-0029] as being publicly available as well as EPA’s analysis of their 

public availability. Appendix C shows that 37 data elements were concurred to be publicly 

available for some reporters for a specific time period. Of the 37 data elements, nine of the data 
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elements are constants used in equations, 24 of the data elements were evaluated in this 

memorandum (see Appendix B) to be publicly available on a recurring basis for a minority of 

reporters or on a one-time basis, and four of the data elements had not been identified as being 

publicly available, but were determined to be available for a small number of sources based on 

the commenter reference cited. 

As shown in Table 4-1, one data element in subpart W was determined to be publicly available 

on a recurring basis for a majority of sources. As a result, EPA proceeded to Step 2 of the 

evaluation, the analysis of the competitive harm that would result from reporting of “inputs to 

equations” data elements, for all 27 subparts.
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Table 4-1. Summary of Publicly Released Data Identical to Inputs to Equations 

Subpart 

# Sourcesa 

From 2011 

Reports 

# Inputs to 

Equations 

# Data Elements Reported 

Recurring Basis 

for a Majority of 

Reporters 

Recurring Basis 

for a Minority 

of Reporters One-Time Basis 

C 1,985b 25 0 17 3 

E 3 21 0 0 0 

F 10 29 0 2 0 

G 22 8 0 0 0 

H 96 15 0 1 1 

K 10 13 0 0 2 

L 16 53 0 0 0 

N 110 3 0 0 0 

O 5 15 0 0 0 

P 103 7 0 0 0 

Q 128 93 0 0 4 

R 13 10 0 0 5 

S 73 9 0 0 0 

U 18 6 0 0 0 

V 36 21 0 0 3 

W 1,549 90 1 7 27 

X 64 21 0 1 0 

Y 145 80 0 2 6 

Z 13 4 0 0 0 

AA 110 31 0 24 0 

BB 1 3 0 0 0 

CC 4 10 0 0 1 

EE 7 2 0 0 0 

GG 6 8 0 0 0 

II 151 5 0 0 0 

TT 173 3 0 0 0 

Total 1 54 52 a

Counts are based on RY2011 reports. 

b

Count is for facilities that are subject only to subpart C reporting. However, information in other columns is for 

counts in each industry sector. A total of 5,391, facilities reported under subpart C. 
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5.0 References

A-1. "Gilberton Power Company, John B Rich Memorial Power Station Unit CFB1, Frackville, Pennsylvania, 

Process Data." Gilberton Power Company. 40 CFR part 60 subpart D, Da, Db, Dc and 40 CFR part 63, 

subpart UUUUU. Docket ID: EPA-HQ-OAR-2009-0234-0643. February 16, 2011. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2009-0234-0643. 

A-2. "Columbia Aluminum Corporation Multiple Metals and Semi-Volatile Organic Compounds Testing Paste 

Plant - Heaf Unit Stack, Goldendale, Washington, September 1, 1994." AmTest-Air Quality, Inc. 40 CFR 

part 63 subpart LL. Docket ID: EPA-HQ-OAR-2002-0032-0157. November 3, 1994. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0032-0157. 

A-3. "Columbia Falls Aluminum Company Emission Testing, Columbia Falls, Montana - December 9-16, 

1996." AmTest-Air Quality, Inc. 40 CFR part 63 subpart LL. Docket ID: EPA-HQ-OAR-2002-0032-0223. 

January 24, 1997. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0032-

0223. 

A-4. "Draft Final Report Emissions From Lime Manufacturing Eastern Ridge Lime Company (Volume 1 of 2) 

Report and Appendices A--B) Attachment 2 of 3. A-95-41 II-A-7." 40 CFR part 63 subpart AAAAA. 

Docket ID: EPA-HQ-OAR-2002-0052-0019. December, 1996. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0052-0019. 

A-5. "Emission Test Report, Method 5/POM and 13B Testing Vo. I, Kaiser Aluminum and Chemical 

Corporation." AmTest-Air Quality, Inc. 40 CFR part 63 subpart LL. Docket ID: EPA-HQ-OAR-2002-

0032-0027. September 14, 1994. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQOAR-2002-0032-0027. 

A-6. "Emission Test Report, Method 5/POM and 13B Testing, Noranda Aluminum Inc., New Madrid, Missouri, 

September 14-20, 1994." AmTest-Air Quality, Inc. 40 CFR part 63 subpart LL. Docket ID: EPA-HQOAR-2002-0032-0161. January 10, 1995. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0032-0161. 

A-7. "Emission Test Report, Method 5/POM and 13B Testing, Noranda Aluminum, Inc. New Madrid, Missouri, 

September 14-20, 1994." AmTest-Air Quality, Inc. 40 CFR part 63 subpart LL. Docket ID: EPA-HQOAR-2002-0032-0159. January 10, 1995. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0032-0159. 

A-8. "Emissions Measurement Test Report Northwest Aluminum Company." Northwest Aluminum Company. 

40 CFR part 63 subpart LL. Docket ID: EPA-HQ-OAR-2002-0032-0023. June, 1994. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0032-0023. 

A-9. "Essroc Cement Corporation Section 114 Responses and Correspondence." Essroc Cement Corporation. 40 

CFR part 63 subpart LLL. Docket ID: EPA-HQ-OAR-2002-0051-1942. May 18, 2007. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0051-1942. 

A-10. "Gopher Resource LLC Stack Test Data." 40 CFR part 63 subpart X. Docket ID: EPA-HQ-OAR-2011-

0344-0067. September 30, 2010. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQOAR-2011-0344-0067. 

A-11. "HOVENSA Coker Steam Vent Report." URS Corporation. 40 CFR part 60 subpart J. Docket ID: EPAHQ-OAR-2007-0011-0272. September 8, 2008. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2007-0011-0272. 
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A-12. "ICR - Carbide Industries." 40 CFR part 63 subpart YYYYYY. Docket ID: EPA-HQ-OAR-2008-0154-

0014. July 21, 2006. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2008-

0154-0014. 

A-13. "ICR - CCMA (CC Metals and Alloys, LLC)." 40 CFR part 63 subpart YYYYYY. Docket ID: EPA-HQOAR-2008-0154-0015. October 6, 2006. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2008-0154-0015. 

A-14. "Information Collection Request (ICR) - Elkem Metals, Pryor, OK." 40 CFR part 63 subpart YYYYYY. 

Docket ID: EPA-HQ-OAR-2008-0154-0016. January 9, 2007. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2008-0154-0016. 

A-15. "Information Collection Request (ICR) - Globe Metallurgical, Beverly, OH." 40 CFR part 63 subpart 

YYYYYY. Docket ID: EPA-HQ-OAR-2008-0154-0018. September 27, 2006. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2008-0154-0018. 

A-16. "Information Collection Request (ICR) - Globe Metallurgical, Selma, AL." 40 CFR part 63 subpart 

YYYYYY. Docket ID: EPA-HQ-OAR-2008-0154-0019. September 27, 2006. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2008-0154-0019. 

A-17. "Information Collection Request (ICR) - Supplemental Information for Bear Metallurgical." 40 CFR part 

63 subpart YYYYYY. Docket ID: EPA-HQ-OAR-2008-0154-0022. July 3, 2006. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2008-0154-0022. 

A-18. "Information Collection Request (ICR) - Tennessee Alloys." 40 CFR part 63 subpart YYYYYY. Docket 

ID: EPA-HQ-OAR-2008-0154-0023. September 27, 2006. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2008-0154-0023. 

A-19. "Information Collection Request (ICR) - West Virginia Alloy." 40 CFR part 63 subpart YYYYYY. Docket 

ID: EPA-HQ-OAR-2008-0154-0024. September 27, 2006. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2008-0154-0024. 

A-20. "Information Collection Request (ICR) - Global Titanium." 40 CFR part 63 subpart YYYYYY. Docket ID: 

EPA-HQ-OAR-2008-0154-0017. September 22, 2006. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2008-0154-0017. 

A-21. "Information Collection Request (ICR) Response - AGY, Aiken, SC, Part 1 of 3." 40 CFR part 63 subpart 

SSSSSS. Docket ID: EPA-HQ-OAR-2006-0360-0068. December 10, 2004. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2006-0360-0068. 

A-22. "Information Collection Request (ICR) Response - AGY, Huntingdon, PA, Part 1 of 2." 40 CFR part 63 

subpart SSSSSS. Docket ID: EPA-HQ-OAR-2006-0360-0069. December 10, 2004. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2006-0360-0069. 

A-23. "Information Collection Request (ICR) Response - General Electric (GE) Consumer & Industrial, Logan, 

Ohio." 40 CFR part 63 subpart SSSSSS. Docket ID: EPA-HQ-OAR-2006-0360-0049. November 3, 2004. 

Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2006-0360-0049. 

A-24. "Information Collection Request (ICR) Response - Guardian Industries Corp, Corsicana, TX." 40 CFR part 

63 subpart SSSSSS. Docket ID: EPA-HQ-OAR-2006-0360-0057. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2006-0360-0057. 

A-25. "Information Collection Request (ICR) Response - Guardian Industries Corporation, Carleton, MI." 40 

CFR part 63 subpart SSSSSS. Docket ID: EPA-HQ-OAR-2006-0360-0056. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2006-0360-0056. 
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A-26. "Information Collection Request (ICR) Response - Guardian Industries Corporation, Geneva, NY." 40 CFR 

part 63 subpart SSSSSS. Docket ID: EPA-HQ-OAR-2006-0360-0060. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2006-0360-0060. 

A-27. "Information Collection Request (ICR) Response - Guardian Industries Corporation, Richburg, SC." 40 

CFR part 63 subpart SSSSSS. Docket ID: EPA-HQ-OAR-2006-0360-0062. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2006-0360-0062. 

A-28. "Information Collection Request (ICR) Response - Guardian Industries Corporation; DeWitt, IA." 40 CFR 

part 63 subpart SSSSSS. Docket ID: EPA-HQ-OAR-2006-0360-0058. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2006-0360-0058. 

A-29. "Information Collection Request (ICR) Response - Osram Sylvania, Inc., Exeter, NH." 40 CFR part 63 

subpart SSSSSS. Docket ID: EPA-HQ-OAR-2006-0360-0054. November 15, 2004. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2006-0360-0054. 

A-30. "Information Collection Request (ICR) Response - Osram Sylvania, Inc., Wellsboro, PA." 40 CFR part 63 

subpart SSSSSS. Docket ID: EPA-HQ-OAR-2006-0360-0055. November 5, 2004. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2006-0360-0055. 

A-31. "Information Collection Request (ICR) Response - PPG Industries, Wichita Falls, TX." 40 CFR part 63 

subpart SSSSSS. Docket ID: EPA-HQ-OAR-2006-0360-0067. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2006-0360-0067. 

A-32. "Letter to Mary Tom Kissell, USEPA re: Completed survey response for the Crawfordsville, IN location. 

Part 1 of 4." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0054. December 2, 

2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-0054. 

A-33. "Letter and attachment, J . Wood, EPAOAQPS:ESD:MICG, to A. Seeger, National Lime Association, June 

20, 1997." 40 CFR part 63 subpart AAAAA. Docket ID: EPA-HQ-OAR-2002-0052-0212. June 20, 1997. 

Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0052-0212. 

A-34. "Letter and attachment, J. Wood, EPAMIGG, to A. Seeger, Morgan, Lewis, and Bockius, July 16, 1996, 

enclosing spreadsheets containing and summarizing non-CH responses to the National Lime Association 

EPA questionnaire. II-C-20." 40 CFR part 63 subpart AAAAA. Docket ID: EPA-HQ-OAR-2002-0052-

0196. July 16, 1996. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-

0052-0196. 

A-35. "Letter and attachment, J. Wood, EPAOAQPS:ESD:MICG, to P. Fulier-Pratt, Western Sugar Company, 

March 18, 1997, enclosing draft meeting meetings for review and comments (For final meeting minutes, 

see II-E-24) - II-C-28." 40 CFR part 63 subpart AAAAA. Docket ID: EPA-HQ-OAR-2002-0052-0204. 

March 18, 1997. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0052-

0204. 

A-36. "Letter and attachment, W. Lamason, EPAEMC, to D. Christiansen, Chemical Lime Company, February 

12, 1998, enclosing draft site test plan for Alabaster and Montevallo, Alabama facilities for comment." 40 

CFR part 63 subpart AAAAA. Docket ID: EPA-HQ-OAR-2002-0052-0233. February 12, 1998. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0052-0233. 

A-37. "Letter and attachment, W. Lamason, EPAEMC, to L. Potts, DravoCorporation, February 19, 1998, 

enclosing draft site test plan for Saginaw, Alabama facility for comment." 40 CFR part 63 subpart 

AAAAA. Docket ID: EPA-HQ-OAR-2002-0052-0234. February 19, 1998. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0052-0234. 
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A-38. "Letter and Attachments Completed Survey Response from M. Peters, CMC Steel Group. Response is for 

the TX, AL, and SC locations of SMI. (Part 1 of 3)." 40 CFR part 63 subpart YYYYY. Docket ID: EPAHQ-OAR-2004-0083-0043. November 22, 2005. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-0043. 

A-39. "Letter and Attachments: Completed Survey Response from A. Gilpin, Oregon Steel Mills. Response is for 

the Portland, OR location. (Part 1 of 2)." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR2004-0083-0039. November 22, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPAHQ-OAR-2004-0083-0039. 

A-40. "Letter and Attachments: Completed Survey Response from A. Gilpin, Oregon Steel Mills. Response is for 

the Portland, OR location. (Part 2 of 2)." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR2004-0083-0040. November 22, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPAHQ-OAR-2004-0083-0040. 

A-41. "Letter and Attachments: Completed Survey Response from A. Read, Gerdau Ameristeel. Response is for 

the North Carolina location." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-

0037. November 22, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR2004-0083-0037. 

A-42. "Letter and Attachments: Completed Survey Response from C. Avent, North Star Steel Iowa. Response is 

for the Wilton, IA location." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-

0065. January 18, 2006. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-

0083-0065. 

A-43. "Letter and Attachments: Completed Survey Response from C. Avent, North Star Steel. Response is for the 

St. Paul, MN location." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0066. 

January 31, 2006. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-

0066. 

A-44. "Letter and Attachments: Completed Survey Response from C. Avent, North Star Steel. Response is for the 

St. Paul, MN location." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0067. 

January 31, 2006. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-

0067. 

A-45. "Letter and Attachments: Completed Survey Response from C. Avent, North Star Steel. Response is for the 

Vidor, TX location." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0042. 

November 22, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-

0083-0042. 

A-46. "Letter and Attachments: Completed Survey Response from C. Avent, North Star Steel. Response is for the 

Wilton, IA location." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0064. 

January 18, 2006. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-

0064. 

A-47. "Letter and Attachments: Completed Survey Response from C. Miles, Gerdau Ameristeel. Response is for 

the Knoxville, TN location." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-

0038. November 22, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR2004-0083-0038. 

A-48. "Letter and Attachments: Completed Survey Response from J. Wesselman, for IPSCO Steel (Alabama) 

Inc." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0034. October 28, 2005. 

Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-0034. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

17 

A-49. "Letter and Attachments: Completed Survey Response from J. Wesselman, for IPSCO Steel Inc., 

Muscatine, IA location." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0030. 

October 28, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-

0030. 

A-50. "Letter and Attachments: Completed Survey Response from J. Wesselman, for IPSCO Steel Inc., 

Muscatine, IA location." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0031. 

October 28, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-

0031. 

A-51. "Letter and Attachments: Completed Survey Response from J. Wesselman, for IPSCO Steel Inc., 

Muscatine, IA location." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0032. 

October 28, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-

0032. 

A-52. "Letter and Attachments: Completed Survey Response from J. Wesselman, for IPSCO Steel Inc., 

Muscatine, IA location." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0033. 

October 28, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-

0033. 

A-53. "Letter and Attachments: Completed Survey Response from J. Wold, Gerdau Ameristeel. Response is for 

the Jacksonville, Florida location." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-

0083-0041. November 22, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQOAR-2004-0083-0041. 

A-54. "Letter and Attachments: Completed Survey Response from M. Dorman, MacSteel Quanex, for Fort Smith, 

AR location." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0014. October 28, 

2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-0014. 

A-55. "Letter and Attachments: Completed Survey Response from M. Dorman, MacSteel Quanex, for Jackson, 

MI location." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0015. October 28, 

2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-0015. 

A-56. "Letter and Attachments: Completed Survey Response from M. Peters, CMC Steel Group. Response is for 

the TX, AL, and SC locations of SMI. (Part 2 of 3)." 40 CFR part 63 subpart YYYYY. Docket ID: EPAHQ-OAR-2004-0083-0044. November 22, 2005. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-0044. 

A-57. "Letter and Attachments: Completed Survey Response from M. Peters, CMC Steel Group. Response is for 

the TX, AL, and SC locations of SMI. (Part 3 of 3)." 40 CFR part 63 subpart YYYYY. Docket ID: EPAHQ-OAR-2004-0083-0045. November 22, 2005. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-0045. 

A-58. "Letter and Attachments: Completed Survey Response from S. Crews, Gerdau Ameristeel. Response is for 

the Co-Steel operations. (Part 1 of 3)." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-

0083-0047. November 22, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQOAR-2004-0083-0047. 

A-59. "Letter and Attachments: Completed Survey Response from S. Crews, Gerdau Ameristeel. Response is for 

the Co-Steel operations. (Part 2 of 3)." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-

0083-0048. November 22, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQOAR-2004-0083-0048. 

A-60. "Letter and Attachments: Completed Survey Response from S. Crews, Gerdau Ameristeel. Response is for 

the Co-Steel operations. (Part 3 of 3)." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

18 

0083-0049. November 22, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQOAR-2004-0083-0049. 

A-61. "Letter and Attachments: Completed Survey Response from S. King, Gerdau Ameristeel. Response is for 

the Jackson, TN location." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0036. 

November 22, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-

0083-0036. 

A-62. "Letter and Attachments: Completed Survey Response from S. Rowlan, Nucor. Response is for the 

Plymouth, UT location." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0057. 

November 26, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-

0083-0057. 

A-63. "Letter and Attachments: Completed Survey Response from S. Rowlan, Nucor. Response is for the 

Plymouth, UT location." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0058. 

December 12, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-

0083-0058. 

A-64. "Letter and Attachments: Completed Survey Response from S. Rowlan, Nucor. Response is for the 

Plymouth, UT location." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0061. 

November 30, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-

0083-0061. 

A-65. "Letter and Attachments: Completed Survey Response from S. Rowlan, Nucor. Response is for the 

Plymouth, UT location." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0062. 

November 30, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-

0083-0062. 

A-66. "Letter and Attachments: Completed Survey Response from The Timken Company, for Faircrest Steel 

Plant in Canton, OH." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0016. 

October 28, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-

0016. 

A-67. "Letter and Attachments: Completed Survey Response from The Timken Company, for Faircrest Steel 

Plant in Canton, OH." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0017. 

October 28, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-

0017. 

A-68. "Letter and Attachments: Completed Survey Response from The Timken Company, for Faircrest Steel 

Plant in Canton, OH." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0018. 

October 28, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-

0018. 

A-69. "Letter and Attachments: Completed Survey Response from The Timken Company, for Faircrest Steel 

Plant in Canton, OH." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0019. 

October 28, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-

0019. 

A-70. "Letter and Attachments: Completed Survey Response from The Timken Company, for Faircrest Steel 

Plant in Canton, OH." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0020. 

October 28, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-

0020. 

A-71. "Letter and Attachments: Completed Survey Response from The Timken Company, for Harrison Steel 

Plant in Canton, OH." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0022. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

19 

November 26, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-

0083-0022. 

A-72. "Letter and Attachments: Completed Survey Response from The Timken Company, for Harrison Steel 

Plant in Canton, OH." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0023. 

October 28, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-

0023. 

A-73. "Letter and Attachments: Completed Survey Response from The Timken Company, for Harrison Steel 

Plant in Canton, OH." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0024. 

October 27, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-

0024. 

A-74. "Letter and Attachments: Completed Survey Response from The Timken Company, for Harrison Steel 

Plant in Canton, OH." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0025. 

October 28, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-

0025. 

A-75. "Letter and Attachments: Completed Survey Response from The Timken Company, for Harrison Steel 

Plant in Canton, OH." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0026. 

October 28, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-

0026. 

A-76. "Letter and Attachments: Completed Survey Response from The Timken Company, for Harrison Steel 

Plant in Canton, OH." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0027. 

October 28, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-

0027. 

A-77. "Letter and Attachments: Completed Survey Response from The Timken Company, for Harrison Steel 

Plant in Canton, OH." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0028. 

October 28, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-

0028. 

A-78. "Letter and Attachments: Completed Survey Response from The Timken Company, for Harrison Steel 

Plant in Canton, OH." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0029. 

October 28, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-

0029. 

A-79. "Letter from T. Matz, Lehigh Cement Co., to K. Barnett, USEPA--Section 114 request response, Mercury 

and THC Data-Tehachapi, CA Plant Part 1." Lehigh Southwest Cement Companv. 40 CFR part 63 subpart 

LLL. Docket ID: EPA-HQ-OAR-2002-0051-1956. August 6, 2007. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0051-1956. 

A-80. "Letter from Timothy L. Matz, Director of Environmental Affairs, Lehigh Cement Company to Keith 

Barnett, USEPA - Section 114 Request Response, Mercury and THC Data - Union Bridge, MD Plant." 

Lehigh Cement Companv. 40 CFR part 63 subpart LLL. Docket ID: EPA-HQ-OAR-2002-0051-1963. 

August 2, 2007. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0051-

1963. 

A-81. "Letter from Timothy L. Matz, Director of Environmental Affairs, Lehigh Cement Company to Keith 

Barnett, USEPA - Section 114 Request Response, Mercury and THC Data - York, PA Plant." Lehigh 

Cement Companv. 40 CFR part 63 subpart LLL. Docket ID: EPA-HQ-OAR-2002-0051-1965. August 6, 

2007. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0051-1965. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

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A-82. "Letter from Timothy L. Matz, Director of Environmental Affairs, Lehigh Cement Company to Keith 

Barnett, USEPA - Section 114 Request Response, Mercury and THC Data-Leeds, AL Plant." Lehigh 

Cement Companv. 40 CFR part 63 subpart LLL. Docket ID: EPA-HQ-OAR-2002-0051-1960. August 3, 

2007. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0051-1960. 

A-83. "Letter from Timothy L. Matz, Director of Environmental Affairs, Lehigh Cement Company to Keith 

Barnett, USEPA - Section 114 Request Response, Mercury and THC Data-Waco, TX Plant." Lehigh 

Cement Companv. 40 CFR part 63 subpart LLL. Docket ID: EPA-HQ-OAR-2002-0051-1964. August 6, 

2007. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0051-1964. 

A-84. "Letter from Timothy L. Matz, Director of Environmental Affairs, Lehigh Cement Company to Keith 

Barnett, USEPA -Section 114 Request Response, Mercury and THC Data - Evansville, PA Plant." Lehigh 

Cement Companv. 40 CFR part 63 subpart LLL. Docket ID: EPA-HQ-OAR-2002-0051-1958. August 2, 

2007. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0051-1958. 

A-85. "Letter from Timothy L. Matz, Lehigh Cement Company, to Keith Barnett, USEPA-Section 114 request 

response, Mercury and THC Data-Redding, CA Plant Part 1." Lehigh Southwest Cement Companv. 40 

CFR part 63 subpart LLL. Docket ID: EPA-HQ-OAR-2002-0051-1957. August 6, 2007. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0051-1957. 

A-86. "Letter from Tomothy L. Matz, Director of Environmental Affairs, Lehigh Cement Company to Keith 

Barnett, USEPA - Section 114 Request Response, Mercury and THC Data - Mason City, IA Plant." Lehigh 

Cement Companv. 40 CFR part 63 subpart LLL. Docket ID: EPA-HQ-OAR-2002-0051-1961. August 7, 

2007. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0051-1961. 

A-87. "Letter regarding completed survey response for Nucor Steel Corporation, Nucor Plate Mill, Cofield, North 

Carolina location." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0051. 

December 2, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-

0083-0051. 

A-89. "Letter regarding completed survey response for the Armorel, AR location." 40 CFR part 63 subpart 

YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0050. December 2, 2005. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-0050. 

A-90. "Letter regarding completed survey response for the Darlington, SC location." 40 CFR part 63 subpart 

YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0052. December 2, 2005. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-0052. 

A-91. "Letter regarding completed survey response for the Huger, SC location." 40 CFR part 63 subpart YYYYY. 

Docket ID: EPA-HQ-OAR-2004-0083-0053. December 2, 2005. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-0053. 

A-92. "Letter regarding completed survey response for the Jewett, TX location." 40 CFR part 63 subpart 

YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0056. December 2, 2005. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-0056. 

A-93. "Letter to Bruce C. Jordan, USEPA, from Tom Bach, KN Energy, Inc, re: Transmission Dehydrator Data 

Request KN Interstate Gas Transmission Company [A-94-04 IV-G-27]." KN Energy, Inc. 40 CFR part 63 

subpart HH. Docket ID: EPA-HQ-OAR-2004-0383-0020. October 14, 1998. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0383-0020. 

A-94. "Letter to Bruce C. Jordan, USEPA, from Tom Bach, KN Energy, Inc., re: Transmission Dehydrator Data 

Request Stingray Pipeline Company [A-94-04 IV-G-28]." KN Energy, Inc. 40 CFR part 63 subpart HH. 

Docket ID: EPA-HQ-OAR-2004-0383-0021. October 14, 1998. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0383-0021. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

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A-95. "Letter to Bruce Jordan, USEPA, from J. W. Fishback, II, Kerr-McGee Corporation, re: Compiled 

Information on Sources and Quantities of Hazardous Air Pollutant (HAP) Emissions and Associated 

Emission Reduction Techniques Associated with the Oil and Natural Gas Production Source Category [A94-04 II D-10]." Kerr-McGee Corporation. 40 CFR part 63 subpart HH. Docket ID: EPA-HQ-OAR-2004-

0383-0024. August 5, 1993. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR2004-0383-0024. 

A-96. "Letter to Keith Barnett, USEPA, from Michael L. Pelan, Lafarge North America Inc." Lafarge North 

America. 40 CFR part 63 subpart LLL. Docket ID: EPA-HQ-OAR-2002-0051-2098. August 7, 2007. 

Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0051-2098. 

A-97. "Letter to Mary Tom Kissel." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-

0063. December 11, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR2004-0083-0063. 

A-98. "Letter to Mary Tom Kissell, USEPA re: Completed Survey Response for the Norfolk, NE Location." 40 

CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0055. December 2, 2005. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-0055. 

A-99. "Letter to Mary Tom Kissell, USEPA, from Deborah L. Calderazzo, Director, Environmental Affairs, 

Allegheny Ludlum." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0046. 

November 22, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-

0083-0046. 

A-100. "Letter and Attachments: Completed Survey Response from J. Wesselman, for IPSCO Steel (Alabama) Inc. 

(Part 2 of 2)." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0035. November 

22, 2005. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-0035. 

A-101. "Lime Manufacturing Emissions Test Report (Volume 1 of 3) Report. A-95-41 II-A-6." 40 CFR part 63 

subpart AAAAA. Docket ID: EPA-HQ-OAR-2002-0052-0012. October, 1996. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0052-0012. 

A-102. "Lime Manufacturing Emissions Test Report (Volume 2 of 3) Appendices A and B. A-95-41 II-A-5." 40 

CFR part 63 subpart AAAAA. Docket ID: EPA-HQ-OAR-2002-0052-0007. October, 1996. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0052-0007. 

A-102. "Lime Manufacturing Emissions Test Report (Volume 2 of 3) Appendices A and B. A-95-41 II-A-6." 40 

CFR part 63 subpart AAAAA. Docket ID: EPA-HQ-OAR-2002-0052-0013. October, 1996. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0052-0013. 

A-103. "Lone Star DBA Buzzi Unicem USA Inc. NON-CBI 114 Response, dated 03 August 2007." Lone Star 

Industries d/b/a Buzzi Unicem USA. 40 CFR part 63 subpart LLL. Docket ID: EPA-HQ-OAR-2002-0051-

1930. August 3, 2007. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-

0051-1930. 

A-104. "Manual Testing Lime Kiln No. 1 Scrubber Inlet and Stack Chemical Lime Company (Alabaster, Alabama) 

A-95-41 II-A-14." 40 CFR part 63 subpart AAAAA. Docket ID: EPA-HQ-OAR-2002-0052-0034. April, 

2000. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0052-0034. 

A-105. "Memorandum and attachments, D. Chester, RTI, to J. Wood, EPAMICG, July, 15, 1996, Non-CBI 

summary spreadsheets of lime industry questionnaire responses (18 Tables total) A-95-41 II-B-14." 40 

CFR part 63 subpart AAAAA. Docket ID: EPA-HQ-OAR-2002-0052-0080. July 15, 1996. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0052-0080. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

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A-106. "Memorandum, E. Heath, RTI, J. Wood, EPAMICG, August 9, 1995, Site Survey of Wimpey Minerals 

USA, Incorporated, Anville, Pennsylvania Site on March 30, 1995. A-95-41 II-B-4." 40 CFR part 63 

subpart AAAAA. Docket ID: EPA-HQ-OAR-2002-0052-0070. August 9, 1995. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0052-0070. 

A-107. "Natural Gas Production NSPS – Technology Reviews." EC/R Incorporated (Bradley Nelson). 40 CFR 60 

subpart OOOO. Docket ID: EPA-HQ-OAR-2010-0505-0060. July 28, 2011. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2010-0505-0060. 

A-108. "Notes from meeting between Carl Younger, Bill Schimming and Brad Peacock of PCS Phopshate, Jim 

Crowder and David Painter." 40 CFR part 63 subpart AA. Docket ID: EPA-HQ-OAR-2004-0382-0007. 

January 23, 1997. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0382-

0007. 

A-109. "Oil and Natural Gas Production Maximum Achievable Control Technology (MACT) and Natural Gas 

Transmission and Storage MACT – Technology Review." EC/R Incorporated (Bradley Nelson). 40 CFR 60 

subpart OOOO. Docket ID: EPA-HQ-OAR-2010-0505-0062. July 28, 2011. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2010-0505-0062. 

A-110. "Part of E.O. 12866 Review: USEPA Staff Response: Doe Run Consent Decree Pertaining to Primary Lead 

RTR. RIN 2060-AQ42. January 24, 2011." 40 CFR part 63 subpart TTT. Docket ID: EPA-HQ-OAR-2004-

0305-0021. November 24, 2011. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQOAR-2004-0305-0021. 

A-111. "Report, Lime Manufacturing Emissions Test Report at Eastern Ridge Lime Company, Ripplemead, 

Virginia, EPA:OAQPS:EMAD:EMCSCGB, Publication number EMC Report 96-LlM-1,3 volumes total, 

October 1996, Final dated September 1997. A-95-41 II-A-5." 40 CFR part 63 subpart AAAAA. Docket ID: 

EPA-HQ-OAR-2002-0052-0006. October, 1996. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0052-0006. 

A-112. "Response to Section 114 Data Requests-Ash Grove Cement - Leamington, Utah." Ash Grove Cement 

Company. 40 CFR part 63 subpart LLL. Docket ID: EPA-HQ-OAR-2002-0051-2115. March 14, 2008. 

Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0051-2115. 

A-113. "Response to Section 114 Data Requests-Ash Grove Cement-Durkee." Ash Grove Cement Company. 40 

CFR part 63 subpart LLL. Docket ID: EPA-HQ-OAR-2002-0051-3572. February 25, 2011. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0051-3572. 

A-114. "Response to Section 114 Data Requests-Ash Grove Cement-Inkom, Idaho." Ash Grove Cement Company. 

40 CFR part 63 subpart LLL. Docket ID: EPA-HQ-OAR-2002-0051-2113. March 14, 2008. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0051-2113. 

A-115. "Response to Section 114 Data Requests-Ash Grove Cement-Montana City, Montana." Ash Grove Cement 

Company. 40 CFR part 63 subpart LLL. Docket ID: EPA-HQ-OAR-2002-0051-2116. March 14, 2008. 

Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0051-2116. 

A-116. "Response to Section 114 Data Requests-Ash Grove Cement-Seattle." Ash Grove Cement Company. 40 

CFR part 63 subpart LLL. Docket ID: EPA-HQ-OAR-2002-0051-2117. March 14, 2008. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0051-2117. 

A-117. "Response to Section 114 Data Requests-Ash Grove Cement-Texas LP." Ash Grove Texas, L.P. 40 CFR 

part 63 subpart LLL. Docket ID: EPA-HQ-OAR-2002-0051-2111. March 13, 2008. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0051-2111. 
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A-118. "Response to Section 114 for Holicim Limited, Holcim (US) Inc. NON-CBI response, dated 15 January 

2008." Holcim (Texas). 40 CFR part 63 subpart LLL. Docket ID: EPA-HQ-OAR-2002-0051-1943. January 

14, 2008. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0051-1943. 

A-119. "Response to Section 114 Request - LaFarge Sugar Creek Plant Mercury and TOC Feed Data." Lafarge 

North America. 40 CFR part 63 subpart LLL. Docket ID: EPA-HQ-OAR-2002-0051-1932. February 27, 

2008. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0051-1932. 

A-120. "Response to Section 114 Request - LaFarge Whitehall Plant Mercury and TOC Feed Data." Lafarge North 

America. 40 CFR part 63 subpart LLL. Docket ID: EPA-HQ-OAR-2002-0051-1933. February 7, 2008. 

Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0051-1933. 

A-121. "Secondary Lead ICR Form Responses (CD)." 40 CFR part 63 subpart X. Docket ID: EPA-HQ-OAR2011-0344-0113. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2011-0344-

0113. 

A-122. "Section 114 Response - Ash Grove Cement Company - Louisville Plant, Nebraska." Ash Grove Cement 

Company. 40 CFR part 63 subpart LLL. Docket ID: EPA-HQ-OAR-2002-0051-2130. July 25, 2007. 

Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0051-2130. 

A-123. "Section 114 Responses in the Ethylene MACT Docket (A-98-22) for 11 facilities in LA & TX." 40 CFR 

part 63 subpart XX. Docket ID: EPA-HQ-OAR-2004-0313-0003. June 19, 1905. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0313-0003. 

A-124. "Site Visit - RTI Alloys." 40 CFR part 63 subpart YYYYYY. Docket ID: EPA-HQ-OAR-2008-0154-0027. 

January 13, 2006. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2008-0154-

0027. 

A-125. "Source Test Data." 40 CFR part 60 subpart J. Docket ID: EPA-HQ-OAR-2007-0011-0119. June 11, 2007. 

Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2007-0011-0119. 

A-126. "Source Test Report conducted at Chevron / Texaco Refinery, El Segundo, California -- VOC, CO, and PM 

Emissions from a Coke Drum Steam Vent." South Coast Air Quality Management District (CA). 40 CFR 

part 60 subpart J. Docket ID: EPA-HQ-OAR-2007-0011-0187. May 14, 2004. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2007-0011-0187. 

A-127. "Source Test Report conducted at Conoco-Phillips Refinery, Carson, California -- VOC, Speciated HCs, 

Aromatic HCs, CO, and PM Emissions from a Coke Drum Steam Vent." South Coast Air Quality 

Management District (CA). 40 CFR part 60 subpart J. Docket ID: EPA-HQ-OAR-2007-0011-0186. July 

23, 2004. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2007-0011-0186. 

A-128. "Source Test Report conducted at Exxon Mobil Refinery, Torrance, California -- VOC, Speciated HCs, 

Aromatic HCs, CO, and PM Emissions from a Coke Drum Steam Vent." South Coast Air Quality 

Management District (CA). 40 CFR part 60 subpart J. Docket ID: EPA-HQ-OAR-2007-0011-0188. March 

4, 2004. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2007-0011-0188. 

A-129. "Source Test Report conducted at Shell Oil Refinery, Wilmington, California -- VOC, CO, and PM 

Emissions from a Coke Drum Steam Vent." South Coast Air Quality Management District (CA). 40 CFR 

part 60 subpart J. Docket ID: EPA-HQ-OAR-2007-0011-0189. July 1, 2004. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2007-0011-0189. 

A-130. "State of Missouri Department of Natural Resources: Permit to Contract re: granting Mississippi Lime a 

permit to contract." 40 CFR part 63 subpart AAAAA. Docket ID: EPA-HQ-OAR-2002-0052-0495. 

February 17, 1998. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-

0052-0495. 
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A-131. "Summary of Information Collection Request (ICR) Response - Doe Run Resources Corporation, 

Herculaneum, Missouri. November 19, 2010." 40 CFR part 63 subpart TTT. Docket ID: EPA-HQ-OAR2004-0305-0005. November 19, 2010. Available: http://www.regulations.gov/#!documentDetail;D=EPAHQ-OAR-2004-0305-0005. 

A-132. "Test Report sent as part of The Timken Company's April 2004 survey response. Report is for the Faircrest 

and Harrison Steel Plants in Canton, OH (dated April 2001)." 40 CFR part 63 subpart YYYYY. Docket ID: 

EPA-HQ-OAR-2004-0083-0021. October 28, 2005. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-0021. 

A-133. "TXI Operations LP Hunter Cement Plant Section 114 Response, dated July 2007." TXI Operations, LP. 40 

CFR part 63 subpart LLL. Docket ID: EPA-HQ-OAR-2002-0051-1928. July 1, 2007. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0051-1928. 

A-134. "TXI Operations LP, Midlothian Cement Plant, Section 114 Response, dated July 2007." TXI Operations, 

LP. 40 CFR part 63 subpart LLL. Docket ID: EPA-HQ-OAR-2002-0051-1929. July 1, 2007. Available: 

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-0051-1929. 

B-1. Alaska Department of Environmental Conservation. Title V Permit for BP Exploration (Alaska) Inc. - 

Central Compressor Plant, Prudhoe Bay, Alaska. Permit ID: 166TVP01. Available: http://dec.alaska.gov/. 

B-2. Alaska Department of Environmental Conservation. Title V Permit for BP Exploration (Alaska) Inc., 

Central Gas Facility, Prudhoe Bay, Alaska. Permit ID: 270TVP01. Available: http://dec.alaska.gov/. 

B-3. Alaska Department of Environmental Conservation. Title V Permit for BP Exploration (Alaska) Inc., 

Northstar Caribou Crossing Compressor Facility, Prudhoe Bay, Alaska. Permit ID: AQ0427TVP02. 

Available: http://dec.alaska.gov/. 

B-4. Alaska Department of Environmental Conservation. Title V Permit for Fairbanks Natural Gas, LLC - 

Liquefied Natural Gas Plant #1, Big Lake, Alaska. Permit ID: AQ0855TVP02. Available: 

http://dec.alaska.gov/. 

B-5. Alaska Department of Environmental Conservation. Title V Permit for Flint Hills Resources Alaska, LLC - 

North Pole Refinery, North Pole, Alaska. Permit ID: AQOO71TVPO2. Available: http://dec.alaska.gov/. 

B-6. Alaska Department of Environmental Conservation. Title V Permit for Marathon Oil Company, Kenai Gas 

Field Pad 34-31, Kenai Peninsula Borough, Alaska. Permit ID: AQ0087TVP02. Available: 

http://dec.alaska.gov/. 

B-7. Arizona Department of Environmental Quality. Title V Permit for Arizona Portland Cement Company - 

Rillito Cement Plant, Rillito, Arizona. Permit ID: M190310P1-00. Available: http://www.azdeq.gov/. 

B-8. Arizona Department of Environmental Quality. Title V Permit for Chemical Lime Company, Douglas Lime 

Plant, Douglas, Arizona. Permit ID: 1000044. Available: http://www.azdeq.gov/. 

B-9. Arizona Department of Environmental Quality. Title V Permit for El Paso Natural Gas Company - Tucson 

Compressor Station, Marana, Arizona. Permit ID: OP#17. Available: http://www.azdeq.gov/. 

B-10. Arkansas Department of Environmental Quality. Title V Permit for Arkansas Glass Container Corporation, 

Jonesboro, Arkansas. Permit ID: 1440-AOP-R4. Available: http://www.adeq.state.ar.us/. 

B-11. Arkansas Department of Environmental Quality. Title V Permit for Arkansas Lime Company, Batesville, 

Arkansas. Permit ID: 0045-AOP-R5. Available: http://www.adeq.state.ar.us/. 
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B-12. Arkansas Department of Environmental Quality. Title V Permit for CenterPoint Energy Gas Transmission 

Co. - Dunn Compressor Station, Paris, Arkansas. Permit ID: 1209-AOP-R5. Available: 

http://www.adeq.state.ar.us/. 

B-13. Arkansas Department of Environmental Quality. Title V Permit for E.I. duPont de Nemours & Co., EI 

Dorado Plant, El Dorado. Permit ID: 2233-A. Available: http://www.adeq.state.ar.us/. 

B-14. Arkansas Department of Environmental Quality. Title V Permit for EI Dorado Chemical Company, EI 

Dorado, Arizona. Permit ID: 0573-AOP-Rll. Available: http://www.adeq.state.ar.us/. 

B-15. Arkansas Department of Environmental Quality. Title V Permit for Green Bay Packaging, Inc. - AR Kraft 

Division, Morrilton, Arkansas. Permit ID: 0224-AOP-R12. Available: http://www.adeq.state.ar.us/. 

B-16. Arkansas Department of Environmental Quality. Title V Permit for Lion Oil Company, EI Dorado, 

Arkansas. Permit ID: 0868-AOP-R8. Available: http://www.adeq.state.ar.us/. 

B-17. Arkansas Department of Environmental Quality. Title V Permit for Nucor-Yamato Steel Company, 

Blytheville, Arkansas. Permit ID: 0883-AOP-R9. Available: http://www.adeq.state.ar.us/. 

B-18. Arkansas Department of Environmental Quality. Title V Permit for Tyson Foods, Incorporated - River 

Valley Animal Foods, Scranton, Arkansas. Permit ID: 0792-AR-5. Available: http://www.adeq.state.ar.us/. 

B-19. California Air Resources Board. Title V Permit for Air Liquid Large Industries, US LP, Rodeo, California. 

Permit ID: B7419. Available: http://www.arb.ca.gov/homepage.htm. 

B-20. California Air Resources Board. Title V Permit for Calpine Pittsburg Power Plant, Pittsburg, California. 

Permit ID: B1928. Available: http://www.arb.ca.gov/homepage.htm. 

B-21. California Air Resources Board. Title V Permit for Celite Corporation – Lompoc Plant, Lompoc, 

California. Permit ID: OP5840. Available: http://www.arb.ca.gov/homepage.htm. 

B-22. California Air Resources Board. Title V Permit for Southern California Gas Company – La Goleta Facility, 

Goleta, California. Permit ID: 5984. Available: http://www.arb.ca.gov/homepage.htm. 

B-23. California Air Resources Board. Title V Permit for Tesoro Refining and Marketing Company, Martinez, 

California. Permit ID: B2758 & B2759. Available: http://www.arb.ca.gov/homepage.htm. 

B-24. California Air Resources Board. Title V Permit for Venoco, Inc., Carpinteria, California. Permit ID: 7996. 

Available: http://www.arb.ca.gov/homepage.htm. 

B-25. Colorado Department of Public Health and Environment. Title V Permit for CEMEX, Inc. - Lyons Cement 

Plant, Lyons, Colorado. Permit ID: 95OPBO082. Available: http://www.colorado.gov/cs/Satellite/CDPHEMain/CBON/1251583470000. 

B-26. Colorado Department of Public Health and Environment. Title V Permit for CF&I Steel dba Rocky 

Mountain Steel Mills - Seamless Mill, Pueblo, Colorado. Permit ID: 95OPPB089. Available: 

http://www.colorado.gov/cs/Satellite/CDPHE-Main/CBON/1251583470000. 

B-27. Colorado Department of Public Health and Environment. Title V Permit for Colorado Interstate Gas 

Company - Cheyenne Compressor Station, Rockport, Colorado. Permit ID: 95OPWE090. Available: 

http://www.colorado.gov/cs/Satellite/CDPHE-Main/CBON/1251583470000. 

B-28. Colorado Department of Public Health and Environment. Title V Permit for Duke Energy Field Services, 

LP - Ladder Creek Helium Plant, Cheyenne Wells, Colorado. Permit ID: 99OPCY216. Available: 

http://www.colorado.gov/cs/Satellite/CDPHE-Main/CBON/1251583470000. 
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B-29. Colorado Department of Public Health and Environment. Title V Permit for Duke Energy Field Services, 

LP - Roggen Gas Plant, Weld County, Colorado. Permit ID: 95OPWE055. Available: 

http://www.colorado.gov/cs/Satellite/CDPHE-Main/CBON/1251583470000. 

B-30. Colorado Department of Public Health and Environment. Title V Permit for Duke Energy Field Services, 

LP - Spindle Gas Processing Plant, Ft Lupton, Colorado. Permit ID: 95OPWE039. Available: 

http://www.colorado.gov/cs/Satellite/CDPHE-Main/CBON/1251583470000. 

B-31. Colorado Department of Public Health and Environment. Title V Permit for EnCana Oil & Gas (USA), Inc. 

- Dragon Trail Gas Processing Plant, Rangely, Colorado. Permit ID: 95OPRB044. Available: 

http://www.colorado.gov/cs/Satellite/CDPHE-Main/CBON/1251583470000. 

B-32. Colorado Department of Public Health and Environment. Title V Permit for EnCana Oil & Gas (USA), Inc. 

- Hunter Mesa Compressor Station, Garfield County, Colorado. Permit ID: 03OPGA267. Available: 

http://www.colorado.gov/cs/Satellite/CDPHE-Main/CBON/1251583470000. 

B-33. Colorado Department of Public Health and Environment. Title V Permit for Northwest Pipeline GP, 

Pleasant View Compressor Station, Montezuma County, Colorado. Permit ID: 95OPMN085. Available: 

http://www.colorado.gov/cs/Satellite/CDPHE-Main/CBON/1251583470000. 

B-34. Colorado Department of Public Health and Environment. Title V Permit for Suncor Energy (U.S.A.) Inc., 

Commerce City, Colorado. Permit ID: 95OPAD108. Available: 

http://www.colorado.gov/cs/Satellite/CDPHE-Main/CBON/1251583470000. 

B-35. Florida Department of Environmental Protection. Title V Permit for AmeriSteel Corporation - Baldwin 

Mill, Baldwin , Florida. Permit ID: 0310157-002-AV. Available: http://www.dep.state.fl.us/. 

B-36. Florida Department of Environmental Protection. Title V Permit for CEMEX, Inc. - Brooksville Cement 

Plant, Brooksville, Florida. Permit ID: 0530010-015-AV. Available: http://www.dep.state.fl.us/. 

B-37. Florida Department of Environmental Protection. Title V Permit for CFI Industries, Inc. – Plant City 

Phosphate Complex, Plant City, Florida. Permit ID: 0570005-017-AV. Available: 

http://www.dep.state.fl.us/. 

B-38. Florida Department of Environmental Protection. Title V Permit for Georgia-Pacific Corporation – Palatka 

Mill, Palatka, Florida. Permit ID: 1070005-031-AV. Available: http://www.dep.state.fl.us/. 

B-39. Florida Department of Environmental Protection. Title V Permit for Gulfstream Natural Gas System, 

L.L.C., Compressor Station 420, Palmetto, Florida. Permit ID: 0810215-004-AV. Available: 

http://www.dep.state.fl.us/. 

B-40. Florida Department of Environmental Protection. Title V Permit for Solutia Incorporated - Pensacola Plant, 

Pensacola, Florida. Permit ID: 0330040-018-AV. Available: http://www.dep.state.fl.us/. 

B-41. Florida Department of Environmental Protection. Title V Permit for Trademark Nitrogen Corp., Tampa, 

Florida. Permit ID: 0570025-006-AO. Available: http://www.dep.state.fl.us/. 

B-42. Georgia Department of Natural Resources, Environmental Protection Division. Title V Permit for CEMEX 

Southeast, LLC, Clinchfield, Georgia. Permit ID: 3241-153-0003-V-05-0. Available: 

http://www.gadnr.org/. 

B-43. Georgia Department of Natural Resources, Environmental Protection Division. Title V Permit for 

CertainTeed Corporation - Peachtree City, Peachtree City, Georgia. Permit ID: 2952-113-0013-V-01-0. 

Available: http://www.gadnr.org/. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

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B-44. Georgia Department of Natural Resources, Environmental Protection Division. Title V Permit for NuStar 

Asphalt Refining, LLC, Savannah, Georgia. Permit ID: 2911-051-0012-V-04-0. Available: 

http://www.gadnr.org/. 

B-45. Georgia Department of Natural Resources, Environmental Protection Division. Title V Permit for PCS 

Nitrogen Fertilizer - Augusta Plant, Augusta, Georgia. Permit ID: 2873-245-0002-V-02-0. Available: 

http://www.gadnr.org/. 

B-46. Georgia Department of Natural Resources, Environmental Protection Division. Title V Permit for Rayonier 

Performance Fibers, LLC – Jesup Pulp Mill, Jesup, Georgia. Permit ID: 2631-305-0001-V-02-0. Available: 

http://www.gadnr.org/. 

B-47. Georgia Department of Natural Resources, Environmental Protection Division. Title V Permit for The 

NutraSweet Company, Augusta, Georgia. Permit ID: 2869-245-0136-V-02-0. Available: 

http://www.gadnr.org/. 

B-48. Idaho Department of Environmental Quality. Title V Permit for Ash Grove Cement Co., Inkom, Idaho. 

Permit ID: T1-2007.0035. Available: http://www.deq.idaho.gov/. 

B-49. Idaho Department of Environmental Quality. Title V Permit for Clearwater Paper Corporation – Consumer 

Products, Lewiston, Idaho. Permit ID: T1-2007.0105. Available: http://www.deq.idaho.gov/. 

B-50. Idaho Department of Environmental Quality. Title V Permit for J. R. Simplot Co., Pocatello, Idaho. Permit 

ID: TI-040313. Available: http://www.deq.idaho.gov/. 

B-51. Idaho Department of Environmental Quality. Title V Permit for Nu-West Industries, Inc., Agrium Conda 

Phosphate Operations, Soda Springs, Idaho. Permit ID: TI-060308. Available: http://www.deq.idaho.gov/. 

B-52. Idaho Department of Environmental Quality. Title V Permit for The Amalgamated Sugar Co. LLC, Nampa, 

Idaho. Permit ID: TI-050020. Available: http://www.deq.idaho.gov/. 

B-53. Illinois Environmental Protection Agency. Title V Permit for 3M Cordova – Specialty Materials 

Manufacturing Division, Cordova, Illinois. Permit ID: 161807AAA. Available: http://www.epa.state.il.us/. 

B-54. Illinois Environmental Protection Agency. Title V Permit for Equistar Chemicals, LP, Morris, Illinois. 

Permit ID: 063800AAC. Available: http://www.epa.state.il.us/. 

B-55. Illinois Environmental Protection Agency. Title V Permit for Exolon-ESK Company, Hennepin, Illinois. 

Permit ID: 155801AAC. Available: http://www.epa.state.il.us/. 

B-56. Illinois Environmental Protection Agency. Title V Permit for Exxon Midwest Terminal, Channahon, 

Illinois. Permit ID: 197800AAR. Available: http://www.epa.state.il.us/. 

B-57. Illinois Environmental Protection Agency. Title V Permit for Honeywell International, Inc., Metropolis, 

Illinois. Permit ID: 127854AAD. Available: http://www.epa.state.il.us/. 

B-58. Illinois Environmental Protection Agency. Title V Permit for Horsehead Resource Development Co., Inc., 

Chicago, Illinois. Permit ID: 031600AFV. Available: http://www.epa.state.il.us/. 

B-59. Illinois Environmental Protection Agency. Title V Permit for Johns Manville, Inc. – Rockdale Plant, 

Rockdale, Illinois. Permit ID: 197809AAF. Available: http://www.epa.state.il.us/. 

B-60. Illinois Environmental Protection Agency. Title V Permit for Northern Natural Gas Company, East 

Dubuque, Illinois. Permit ID: 085809AAG. Available: http://www.epa.state.il.us/. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

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B-61. Illinois Environmental Protection Agency. Title V Permit for Saint-Gobain Containers, Inc., Lincoln, 

Illinois. Permit ID: 107035AAX. Available: http://www.epa.state.il.us/. 

B-62. Indiana Department of Environmental Management. Title V Permit for Anchor Glass Container 

Corporation, Winchester, Indiana. Permit ID: T135-27245-00012. Available: http://www.in.gov/idem/. 

B-63. Indiana Department of Environmental Management. Title V Permit for ArcelorMittal Burns Harbor, LLC, 

Burns Harbor, Indiana. Permit ID: T127-6301-00001. Available: http://www.in.gov/idem/. 

B-64. Indiana Department of Environmental Management. Title V Permit for BP Products North America Inc., 

Whiting Business Unit, Whiting, Indiana. Permit ID: T089-6741-00453. Available: 

http://www.in.gov/idem/. 

B-65. Indiana Department of Environmental Management. Title V Permit for Citizens Gas and Coke Utility - 

LNG North, Indianapolis, Indiana. Permit ID: F097-18805-00141. Available: http://www.in.gov/idem/. 

B-66. Indiana Department of Environmental Management. Title V Permit for Exide Technologies, Muncie, 

Indiana. Permit ID: T035-22352-00028. Available: http://www.in.gov/idem/. 

B-67. Indiana Department of Environmental Management. Title V Permit for Green Plains Bluffton, LLC, 

Bluffton, Indiana. Permit ID: T179-29393-00033. Available: http://www.in.gov/idem/. 

B-68. Indiana Department of Environmental Management. Title V Permit for Iroquois Bio-Energy Company, 

LLC, Rensselaer, Indiana. Permit ID: F073-26405-00037. Available: http://www.in.gov/idem/. 

B-69. Indiana Department of Environmental Management. Title V Permit for Lone Star Industries, Inc. dba Buzzi 

Unicem USA, Greencastle, Indiana. Permit ID: T133-26830-00002. Available: http://www.in.gov/idem/. 

B-70. Indiana Department of Environmental Management. Title V Permit for Mittal Steel USA Inc. - Indiana 

Harbor East, East Chicago, Indiana. Permit ID: T089-6577-00316. Available: http://www.in.gov/idem/. 

B-71. Indiana Department of Environmental Management. Title V Permit for Praxair, Inc., East Chicago, Indiana. 

Permit ID: T089-21430-00330. Available: http://www.in.gov/idem/. 

B-72. Indiana Department of Environmental Management. Title V Permit for Quemetco, Inc., Indianapolis, 

Indiana. Permit ID: T097-27020-00079. Available: http://www.in.gov/idem/. 

B-73. Indiana Department of Environmental Management. Title V Permit for Tyson Foods, Inc. - Corydon 

Facility, Corydon, Indiana. Permit ID: M061-27383-00029. Available: http://www.in.gov/idem/. 

B-74. Iowa Department of Natural Resources. Title V Permit for Equistar Chemicals, LP, Clinton, Iowa. Permit 

ID: 04-TV-008R1. Available: http://www.iowadnr.gov/. 

B-75. Iowa Department of Natural Resources. Title V Permit for Gerdau Ameristeel US, Inc., Wilton, Iowa. 

Permit ID: 03-TV-006R1. Available: http://www.iowadnr.gov/. 

B-76. Iowa Department of Natural Resources. Title V Permit for Global Ethanol LLC - Lakota, Lakota, Iowa. 

Permit ID: 10-TV-001. Available: http://www.iowadnr.gov/. 

B-77. Iowa Department of Natural Resources. Title V Permit for Green Valley Chemical Corporation, Creston, 

Iowa. Permit ID: 99-TV-002R2. Available: http://www.iowadnr.gov/. 

B-78. Iowa Department of Natural Resources. Title V Permit for Koch Nitrogen Company, Fort Dodge, Iowa. 

Permit ID: 00-TV-010R1. Available: http://www.iowadnr.gov/. 
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B-79. Iowa Department of Natural Resources. Title V Permit for Natural Gas Pipeline Company of America 

Station 109, Harper, Iowa. Permit ID: 00-TV-049R1. Available: http://www.iowadnr.gov/. 

B-80. Iowa Department of Natural Resources. Title V Permit for Terra Nitrogen - Port Neal Complex, Sergeant 

Bluff, Iowa. Permit ID: 99-TV-024R2. Available: http://www.iowadnr.gov/. 

B-81. Louisiana Department of Environmental Quality. Title V Permit for Air Products and Chemicals, Inc. – 

New Orleans Facility, New Orleans, Louisiana. Permit ID: 2140-00016-V7. Available: 

http://www.deq.louisiana.gov/portal/. 

B-82. Louisiana Department of Environmental Quality. Title V Permit for Air Products and Chemicals, Inc. – 

SMR Facility, Convent, Louisiana. Permit ID: 2560-00073-03. Available: 

http://www.deq.louisiana.gov/portal/. 

B-83. Louisiana Department of Environmental Quality. Title V Permit for Calumet Shreveport Refinery, 

Shreveport, Louisiana. Permit ID: 3065-V0. Available: http://www.deq.louisiana.gov/portal/. 

B-84. Louisiana Department of Environmental Quality. Title V Permit for Forest Oil Corporation, Bayou 

Postillion Production Facility, Jeanerette, Louisiana. Permit ID: 1260-00080-02. Available: 

http://www.deq.louisiana.gov/portal/. 

B-85. Louisiana Department of Environmental Quality. Title V Permit for Forest Oil Corporation, Common Point 

No. 2 Facility, Houma, Louisiana. Permit ID: 2880-00166-V1. Available: 

http://www.deq.louisiana.gov/portal/. 

B-86. Louisiana Department of Environmental Quality. Title V Permit for Forest Oil Corporation, West White 

Lake 540-A Facility, Pecan Island, Louisiana. Permit ID: 2490-00142-V4. Available: 

http://www.deq.louisiana.gov/portal/. 

B-87. Louisiana Department of Environmental Quality. Title V Permit for Norco Chemical Plant – West Site, 

Shell Chemical LP, Norco, Louisiana. Permit ID: 2889-V1. Available: 

http://www.deq.louisiana.gov/portal/. 

B-88. Louisiana Department of Environmental Quality. Title V Permit for PPG Industrials, Inc. – Lake Charles 

Complex, Westlake, Louisiana. Permit ID: 2106-V4. Available: http://www.deq.louisiana.gov/portal/. 

B-89. Louisiana Department of Environmental Quality. Title V Permit for SASOL North America Inc. – Lake 

Charles Complex, West Lake, Louisiana. Permit ID: 2743-V2. Available: 

http://www.deq.louisiana.gov/portal/. 

B-90. Maine Department of Environmental Protection. Title V Permit for Dragon Products Company, Inc., 

Thomaston, Maine. Permit ID: A-326-70-A-I. Available: http://www.maine.gov/dep/. 

B-91. Maine Department of Environmental Protection. Title V Permit for Verso Paper, Jay, Maine. Permit ID: A203-70-A-I. Available: http://www.maine.gov/dep/. 

B-92. Michigan Department of Environmental Quality. Title V Permit for Guardian Industrial Corporation, 

Carleton, Michigan. Permit ID: MI-ROP-B1877-2009. Available: http://www.michigan.gov/deq. 

B-93. Michigan Department of Environmental Quality. Title V Permit for Marathon Petroleum Company, LLC., 

Detroit, Michigan. Permit ID: 199700013c. Available: http://www.michigan.gov/deq. 

B-94. Michigan Department of Environmental Quality. Title V Permit for Menominee Paper Company, 

Menominee, Michigan. Permit ID: MI-ROP-B1855-2011. Available: http://www.michigan.gov/deq. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

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B-95. Michigan Department of Environmental Quality. Title V Permit for Michigan Consolidated Gas Company, 

Columbus Compressor Station, Columbus, Michigan. Permit ID: MI-ROP-B6480-2007. Available: 

http://www.michigan.gov/deq. 

B-96. Michigan Department of Environmental Quality. Title V Permit for Severstal Dearborn, LLC, Dearborn, 

Michigan. Permit ID: MI-ROP-A8640-200X. Available: http://www.michigan.gov/deq. 

B-97. Michigan Department of Environmental Quality. Title V Permit for St. Marys Cement, Inc. (US), 

Charlevoix, Michigan. Permit ID: MI-ROP-B1559-2008. Available: http://www.michigan.gov/deq. 

B-98. Minnesota Pollution Control Agency. Title V Permit for Alliance Pipeline - Albert Lea 25-A, Albert Lea, 

Minnesota. Permit ID: 04700059- 005. Available: http://www.pca.state.mn.us/. 

B-99. Minnesota Pollution Control Agency. Title V Permit for Southern Minnesota Beet Sugar Coop, Renville, 

Minnesota. Permit ID: 12900014- 006. Available: http://www.pca.state.mn.us/. 

B-100. Mississippi Department of Environmental Quality. Title V Permit for E.I. duPont de Nemours & Company 

- DeLisle Plant, Pass Christian, Mississippi. Permit ID: 1020-00115. Available: 

http://www.deq.state.ms.us/. 

B-101. Mississippi Department of Environmental Quality. Title V Permit for Southern Natural Gas Company, 

Louisville Compressor Station, Winston, Mississippi. Permit ID: 2980-00008. Available: 

http://www.deq.state.ms.us/. 

B-102. Mississippi Department of Environmental Quality. Title V Permit for Tronox LLC, Hamilton Facility, 

Hamilton, Mississippi. Permit ID: 1840-00035. Available: http://www.deq.state.ms.us/. 

B-103. Missouri Department of Natural Resources. Title V Permit for Buzzi Unicem USA, Inc. - Cape Girardeau 

Plant, Cape Girardeau, Missouri. Permit ID: OP2010-028. Available: http://www.dnr.mo.gov/. 

B-104. Missouri Department of Natural Resources. Title V Permit for Chemical Lime Company, Ste. Genevieve, 

Missouri. Permit ID: OP2010-016. Available: http://www.dnr.mo.gov/. 

B-105. Missouri Department of Natural Resources. Title V Permit for Marshall Municipal Utilities Power Plant, 

Marshall, Missouri. Permit ID: OP2010-095. Available: http://www.dnr.mo.gov/. 

B-106. Missouri Department of Natural Resources. Title V Permit for MoGas Pipeline LLC, Curryville 

Compressor Station, Curryville, Missouri. Permit ID: 022008-001. Available: http://www.dnr.mo.gov/. 

B-107. Missouri Department of Natural Resources. Title V Permit for Saint-Gobain Containers, Pevely, Missouri. 

Permit ID: OP2007-035A. Available: http://www.dnr.mo.gov/. 

B-108. New Mexico Environment Department. Title V Permit for Conoco, Inc. - Wingate Fractionating Plant, 

Gallup, New Mexico. Permit ID: NN-OP 00-08. Available: http://www.nmenv.state.nm.us/. 

B-109. New York State Department of Environmental Conservation. Title V Permit for ALCOA Massena 

Operations (West Plant), Massena, New York. Permit ID: 6-4058-00003/00365. Available: 

http://www.dec.ny.gov/. 

B-110. New York State Department of Environmental Conservation. Title V Permit for Anchor Glass Container 

Corp, Elmira Heights, New York. Permit ID: 8-0704-00036/00041. Available: http://www.dec.ny.gov/. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

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B-111. New York State Department of Environmental Conservation. Title V Permit for Dominion Transmission 

Inc., Woodhull Station, Woodhull, New York. Permit ID: 8-4682-00006/00034. Available: 

http://www.dec.ny.gov/. 

B-112. New York State Department of Environmental Conservation. Title V Permit for Revere Smelting & 

Refining Corp, Middletown, New York. Permit ID: 3-3352-00145/00049. Available: 

http://www.dec.ny.gov/. 

B-113. New York State Department of Environmental Conservation. Title V Permit for Reynolds Metals St 

Lawrence Reduction Plant, Massena, New York. Permit ID: 6-4058-00024/00077. Available: 

http://www.dec.ny.gov/. 

B-114. New York State Department of Environmental Conservation. Title V Permit for US Gypsum Co - Oakfield 

Plant, Oakfield, New York. Permit ID: 8-1838-00007/00035. Available: http://www.dec.ny.gov/. 

B-115. North Carolina Department of Environment and Natural Resources. Title V Permit for Cargill, Inc., 

Fayetteville, North Carolina. Permit ID: 03903T36. Available: http://portal.ncdenr.org/web/guest. 

B-116. North Carolina Department of Environment and Natural Resources. Title V Permit for E.I. du Pont de 

Nemours & Co., LLC DBA, DuPont Company – Fayetteville Works, Duart Township, North Carolina. 

Permit ID: 03735T32. Available: http://portal.ncdenr.org/web/guest. 

B-117. North Carolina Department of Environment and Natural Resources. Title V Permit for Elementis 

Chromium, Castle Hayne, North Carolina. Permit ID: 02937T33. Available: 

http://portal.ncdenr.org/web/guest. 

B-118. North Carolina Department of Environment and Natural Resources. Title V Permit for International Paper, 

Riegelwood, North Carolina. Permit ID: 03138R36. Available: http://portal.ncdenr.org/web/guest. 

B-119. North Carolina Department of Environment and Natural Resources. Title V Permit for Nucor Steel – 

Hertford County Steel Mill, Cofield, North Carolina. Permit ID: 08680T16. Available: 

http://portal.ncdenr.org/web/guest. 

B-120. North Carolina Department of Environment and Natural Resources. Title V Permit for PCS Phosphate 

Company, Inc., Aurora, North Carolina. Permit ID: 04176T46. Available: 

http://portal.ncdenr.org/web/guest. 

B-121. North Carolina Department of Environment and Natural Resources. Title V Permit for Piedmont Natural 

Gas – Concord Compressor, Concord, North Carolina. Permit ID: 09604T04. Available: 

http://portal.ncdenr.org/web/guest. 

B-122. Ohio Environmental Protection Agency. Title V Permit for Agrium North Bend Nitrogen Operations, North 

Bend, Ohio. Permit ID: P0105169. Available: http://www.epa.state.oh.us/. 

B-123. Ohio Environmental Protection Agency. Title V Permit for ArcelorMittal Tubular Products Shelby Inc., 

Shelby, Ohio. Permit ID: P0087591. Available: http://www.epa.state.oh.us/. 

B-124. Ohio Environmental Protection Agency. Title V Permit for Carmeuse Lime, Inc - Grand River Operations, 

Grand River, Ohio. Permit ID: P0084911. Available: http://www.epa.state.oh.us/. 

B-125. Ohio Environmental Protection Agency. Title V Permit for Dominion - Washington Compressor Station, 

Washington Court House, Ohio. Permit ID: P0082545. Available: http://www.epa.state.oh.us/. 

B-126. Ohio Environmental Protection Agency. Title V Permit for ESSROC Cement Corp, Middlebranch, Ohio. 

Permit ID: P0100926. Available: http://www.epa.state.oh.us/. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

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B-127. Ohio Environmental Protection Agency. Title V Permit for GE Lighting Inc - Bucyrus Lamp Plant, 

Bucyrus, Ohio. Permit ID: P0086836. Available: http://www.epa.state.oh.us/. 

B-128. Ohio Environmental Protection Agency. Title V Permit for Globe Metallurgical Inc., Waterford, Ohio. 

Permit ID: P0090960. Available: http://www.epa.state.oh.us/. 

B-129. Ohio Environmental Protection Agency. Title V Permit for GM Defiance Casting Operations, Defiance, 

Ohio. Permit ID: P0105131. Available: http://www.epa.state.oh.us/. 

B-130. Ohio Environmental Protection Agency. Title V Permit for Ineos USA LLC, Lima, Ohio. Permit ID: 

P0086747. Available: http://www.epa.state.oh.us/. 

B-131. Ohio Environmental Protection Agency. Title V Permit for Millennium Inorganic Chemicals, Inc. Plant 2, 

Ashtabula, Ohio. Permit ID: P0084095. Available: http://www.epa.state.oh.us/. 

B-132. Ohio Environmental Protection Agency. Title V Permit for Millennium Inorganic Chemicals, Inc. Plant 1, 

Ashtabula, Ohio. Permit ID: P0084099. Available: http://www.epa.state.oh.us/. 

B-133. Ohio Environmental Protection Agency. Title V Permit for Orion Engineered Carbons LLC, Belpre, Ohio. 

Permit ID: P0091042. Available: http://www.epa.state.oh.us/. 

B-134. Ohio Environmental Protection Agency. Title V Permit for Ormet Primary Aluminum Corp., Hannibal, 

Ohio. Permit ID: P0089794. Available: http://www.epa.state.oh.us/. 

B-135. Ohio Environmental Protection Agency. Title V Permit for PCS Nitrogen Ohio, L.P., Lima, Ohio. Permit 

ID: P0108791. Available: http://www.epa.state.oh.us/. 

B-136. Ohio Environmental Protection Agency. Title V Permit for Smart Papers - Hamilton Mill, Hamilton, Ohio. 

Permit ID: P0105122. Available: http://www.epa.state.oh.us/. 

B-137. Oklahoma Department of Environmental Quality. Title V Permit for Anchor Glass - Henryetta Glass 

Container Plant, Henryetta, Oklahoma. Permit ID: 99-114-TV. Available: http://www.deq.state.ok.us/. 

B-138. Oklahoma Department of Environmental Quality. Title V Permit for ConocoPhillips Company - Ponca City 

Refinery, Ponca City, Oklahoma. Permit ID: 98-104-TV. Available: http://www.deq.state.ok.us/. 

B-139. Oklahoma Department of Environmental Quality. Title V Permit for Continental Carbon Corporation, 

Ponca City, Oklahoma. Permit ID: 98-176-TV. Available: http://www.deq.state.ok.us/. 

B-140. Oklahoma Department of Environmental Quality. Title V Permit for Enogex Products Corporation 

(Enogex) - Wetumka Gas Processing Plant, Wetumka, Oklahoma. Permit ID: 97-118-C. Available: 

http://www.deq.state.ok.us/. 

B-141. Oklahoma Department of Environmental Quality. Title V Permit for Georgia-Pacific Corporation, 

Muskogee, Oklahoma. Permit ID: 99-113-TV. Available: http://www.deq.state.ok.us/. 

B-142. Oklahoma Department of Environmental Quality. Title V Permit for Koch Nitrogen Company - Enid 

Nitrogen Plant, Enid, Oklahoma. Permit ID: 99-092-TV. Available: http://www.deq.state.ok.us/. 

B-143. Oregon Department of Environmental Quality. Title V Permit for Ash Grove Cement Co., Durkee, Oregon. 

Permit ID: 01-0029. Available: http://www.oregon.gov/DEQ/Pages/index.aspx. 

B-144. Rhode Island Department of Environmental Management. Title V Permit for Brown University, 

Providence, Rhode Island. Permit ID: RI-09-06 (R3). Available: http://www.dem.ri.gov/index.htm. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

33 

B-145. South Dakota Department of Environment and Natural Resources. Title V Permit for Dakota Ethanol, 

Wentworth, South Dakota. Permit ID: 28.0501-43. Available: http://denr.sd.gov/. 

B-146. Texas Commission on Environmental Quality. Title V Permit for Agrium U.S., Inc. - Borger Nitrogen 

Operations, Borger, Texas. Permit ID: RN101865715. Available: http://www.tceq.state.tx.us/. 

B-147. Texas Commission on Environmental Quality. Title V Permit for Air Products LLC, Pasadena, Texas. 

Permit ID: O2309. Available: http://www.tceq.state.tx.us/. 

B-148. Texas Commission on Environmental Quality. Title V Permit for Cabot Corporation, Pampa, Texas. Permit 

ID: O1623. Available: http://www.tceq.state.tx.us/. 

B-149. Texas Commission on Environmental Quality. Title V Permit for Chevron U.S.A. Inc. - Ozona Gas 

Processing Plant, Ozona, Texas. Permit ID: O2677. Available: http://www.tceq.state.tx.us/. 

B-150. Texas Commission on Environmental Quality. Title V Permit for CITGO Refining and Chemicals 

Company, L.P. - Corpus Christi Refinery - West Plant, Corpus Christi, Texas. Permit ID: O1420. 

Available: http://www.tceq.state.tx.us/. 

B-151. Texas Commission on Environmental Quality. Title V Permit for Delek Refining Tyler Refinery, Tyler, 

Texas. Permit ID: O1257. Available: http://www.tceq.state.tx.us/. 

B-152. Texas Commission on Environmental Quality. Title V Permit for Duke Energy Field Services, LP – Three 

Rivers Gas Plant, George West, Texas. Permit ID: 39169. Available: http://www.tceq.state.tx.us/. 

B-153. Texas Commission on Environmental Quality. Title V Permit for E I Du Pont De Nemours And Company, 

Orange, Texas. Permit ID: O1901. Available: http://www.tceq.state.tx.us/. 

B-154. Texas Commission on Environmental Quality. Title V Permit for E I Du Pont de Nemours and Company, 

Victoria, Texas. Permit ID: O1903. Available: http://www.tceq.state.tx.us/. 

B-155. Texas Commission on Environmental Quality. Title V Permit for El Dorado Nitrogen L.P. - Baytown 

Nitric Acid Plant, Baytown, Texas. Permit ID: O1700. Available: http://www.tceq.state.tx.us/. 

B-156. Texas Commission on Environmental Quality. Title V Permit for El Paso Natural Gas Company, Plains 

Compressor Station, Yoakum County, Texas. Permit ID: O3176. Available: http://www.tceq.state.tx.us/. 

B-157. Texas Commission on Environmental Quality. Title V Permit for Energen Resources Corporation, 

Andrews, Texas. Permit ID: 96024. Available: http://www.tceq.state.tx.us/. 

B-158. Texas Commission on Environmental Quality. Title V Permit for International Paper Company, Queen 

City, Texas. Permit ID: O1378. Available: http://www.tceq.state.tx.us/. 

B-159. Texas Commission on Environmental Quality. Title V Permit for Linn Operating Inc., Big Spring, Texas. 

Permit ID: 98168. Available: http://www.tceq.state.tx.us/. 

B-160. Texas Commission on Environmental Quality. Title V Permit for Lufkin Industries Inc., Lufkin, Texas. 

Permit ID: O1854. Available: http://www.tceq.state.tx.us/. 

B-161. Texas Commission on Environmental Quality. Title V Permit for Southern Union Pipeline, Ltd. - Mi Vida 

Plant, Ward County, Texas. Permit ID: O3186. Available: http://www.tceq.state.tx.us/. 

B-162. Texas Commission on Environmental Quality. Title V Permit for The Dow Chemical Company, Freeport, 

Texas. Permit ID: O2220. Available: http://www.tceq.state.tx.us/. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

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B-163. Utah Department of Environmental Quality. Title V Permit for El Paso Field Operations Company, 

Altamont Main Gas Processing Plant, Altamont, Utah. Permit ID: 1300006002. Available: 

http://www.deq.utah.gov/. 

B-164. Utah Department of Environmental Quality. Title V Permit for EnCana Oil & Gas (USA) Incorporated - 

Lisbon Natural Gas Processing Plant, Moab, Utah. Permit ID: 3700014001. Available: 

http://www.deq.utah.gov/. 

B-165. Utah Department of Environmental Quality. Title V Permit for Geneva Nitrogen LLC., Vineyard, Utah. 

Permit ID: 4900082003. Available: http://www.deq.utah.gov/. 

B-166. Utah Department of Environmental Quality. Title V Permit for Graymont Western US Incorporated - 

Cricket Mountain Plant, Delta, Utah. Permit ID: 2700005002. Available: http://www.deq.utah.gov/. 

B-167. Utah Department of Environmental Quality. Title V Permit for Kern River Gas Transmission Company, 

Veyo Compressor Station, Veyo, Utah. Permit ID: 5300050001. Available: http://www.deq.utah.gov/. 

B-168. Utah Department of Environmental Quality. Title V Permit for Nucor Bar Mill Group - Plymouth Division, 

Plymouth, Utah. Permit ID: 300002002. Available: http://www.deq.utah.gov/. 

B-169. Utah Department of Environmental Quality. Title V Permit for Questar Pipeline Company, 

Kastler/Marushack Compressor Station, Daggett County, Utah. Permit ID: 900001002. Available: 

http://www.deq.utah.gov/. 

B-170. Virginia Department of Environmental Quality. Title V Permit for Chemical Lime Company, Kimballton 

Plant, Ripplemead, Virginia. Permit ID: VA-20225. Available: http://www.deq.state.va.us/. 

B-171. Virginia Department of Environmental Quality. Title V Permit for Covanta Fairfax, Inc., Lorton, Virginia. 

Permit ID: NVRO71920. Available: http://www.deq.state.va.us/. 

B-172. Virginia Department of Environmental Quality. Title V Permit for East Tennessee Natural Gas, LLC, 

Glade Spring, Virginia. Permit ID: SWRO10979. Available: http://www.deq.state.va.us/. 

B-173. Virginia Department of Environmental Quality. Title V Permit for Honeywell International Inc. – Hopewell 

Plant, Hopewell, Virginia. Permit ID: PRO50232. Available: http://www.deq.state.va.us/. 

B-174. Virginia Department of Environmental Quality. Title V Permit for Jewell Coke Company, L.P., Vansant, 

Virginia. Permit ID: SWRO10200. Available: http://www.deq.state.va.us/. 

B-175. Virginia Department of Environmental Quality. Title V Permit for Smurfit-Stone Container Enterprises, 

Inc., Hopewell, Virginia. Permit ID: PRO-50370. Available: http://www.deq.state.va.us/. 

B-176. West Virginia Department of Environmental Protection. Title V Permit for Columbia Gas Transmission 

Corporation, Glady Compressor Station, Glady, West Virginia. Permit ID: R30-NGGP-2007-08300017. 

Available: http://www.dep.wv.gov/Pages/default.aspx. 

B-177. West Virginia Department of Environmental Protection. Title V Permit for Dominion Transmission, Inc., 

Yellow Creek Station, Big Springs, West Virginia. Permit ID: R30-01300001-2011. Available: 

http://www.dep.wv.gov/Pages/default.aspx. 

B-178. West Virginia Department of Environmental Protection. Title V Permit for E. I. du Pont de Nemours & Co. 

- Washington Works, Washington, West Virginia. Permit ID: R30-10700001-2010. Available: 

http://www.dep.wv.gov/Pages/default.aspx. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

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B-179. West Virginia Department of Environmental Protection. Title V Permit for Ergon - West Virginia, Inc., 

Newell, West Virginia. Permit ID: R30-02900008-2010. Available: 

http://www.dep.wv.gov/Pages/default.aspx. 

B-180. West Virginia Department of Environmental Protection. Title V Permit for Greer Industries, Inc. d.b.a. 

Greer Lime Company, Riverton, West Virginia. Permit ID: R30-07100001-2009. Available: 

http://www.dep.wv.gov/Pages/default.aspx. 

B-181. West Virginia Department of Environmental Protection. Title V Permit for SFK Pulp Recycling U.S., Inc. - 

Fairmont Division, Fairmont, West Virginia. Permit ID: R30-04900043-2008. Available: 

http://www.dep.wv.gov/Pages/default.aspx. 

B-182. Wisconsin Department of Natural Resources. Title V Permit for Cardinal FG, Menomonie, Wisconsin. 

Permit ID: 617049840-P10. Available: http://dnr.wi.gov/. 

B-183. Wisconsin Department of Natural Resources. Title V Permit for Graymont (WI) Inc., Superior, Wisconsin. 

Permit ID: 816036430-P01. Available: http://dnr.wi.gov/. 

B-184. Wisconsin Department of Natural Resources. Title V Permit for Jennie-O Turkey Store - Barron Division, 

Barron, Wisconsin. Permit ID: 603007900-F20. Available: http://dnr.wi.gov/. 

B-185. Wisconsin Department of Natural Resources. Title V Permit for Murphy Oil USA, Inc., Superior, 

Wisconsin. Permit ID: 816009590-P01. Available: http://dnr.wi.gov/. 

B-186. Wisconsin Department of Natural Resources. Title V Permit for Neenah Paper, Inc., Neenah, Wisconsin. 

Permit ID: 471031000-P10. Available: http://dnr.wi.gov/. 

B-187. Wisconsin Department of Natural Resources. Title V Permit for Saint-Gobain Containers. Inc., Burlington, 

Wisconsin. Permit ID: 252005930-P10. Available: http://dnr.wi.gov/. 

B-188. Wisconsin Department of Natural Resources. Title V Permit for Viking Gas Transmission Co #2222, 

Osceola, Wisconsin. Permit ID: 649014410-P20. Available: http://dnr.wi.gov/. 

B-189. Wyoming Department of Environmental Quality. Title V Permit for Dyno Nobel, Inc. - Cheyenne Plant, 

Cheyenne, Wyoming. Permit ID: 30-206. Available: http://deq.state.wy.us/. 

B-190. Wyoming Department of Environmental Quality. Title V Permit for EnCana Oil & Gas (USA) Inc. - 

Pavillion Compressor Station, Pavillion, Wyoming. Permit ID: 3-1-063. Available: http://deq.state.wy.us/. 

B-191. Wyoming Department of Environmental Quality. Title V Permit for Encore Energy Partners Operating, 

LLC - Elk Basin Gas Plant, Powell, Wyoming. Permit ID: 3-2-045-1. Available: http://deq.state.wy.us/. 

B-192. Wyoming Department of Environmental Quality. Title V Permit for Frontier Refining Inc. - Cheyenne 

Refinery, Cheyenne, Wyoming. Permit ID: 3-0-149-2. Available: http://deq.state.wy.us/. 

B-193. Wyoming Department of Environmental Quality. Title V Permit for General Chemical (Soda Ash) Partners 

- Green River Works, Green River, Wyoming. Permit ID: 3-1 -123-1. Available: http://deq.state.wy.us/. 

B-194. Wyoming Department of Environmental Quality. Title V Permit for Jonah Gas Gathering Company, Bird 

Canyon Compressor Station, Calpet, Wyoming. Permit ID: 3-1-201. Available: http://deq.state.wy.us/. 

B-195. Wyoming Department of Environmental Quality. Title V Permit for OCI Wyoming, L.P. - Big Island Mine 

& Refinery, Green River, Wyoming. Permit ID: 3-1-119. Available: http://deq.state.wy.us/. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

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B-196. Wyoming Department of Environmental Quality. Title V Permit for Simplot Phosphates LLC, Rock 

Springs Fertilizer Complex, Rock Springs, Wyoming. Permit ID: 3-1-125. Available: 

http://deq.state.wy.us/. 

B-197. Wyoming Department of Environmental Quality. Title V Permit for Solvay Soda Ash Joint Venture, Inc. - 

Green River Plant, Green River, Wyoming. Permit ID: 3-0-126-2. Available: http://deq.state.wy.us/.

C-1. U.S. EPA, 2008. 2008 National Emissions Inventory. Available: 

http://www.epa.gov/ttn/chief/eiinformation.html. 

C-2. U.S. EPA, 2011. Clean Air Markets Division (CAMD) Acid Rain Program Database. Available: 

http://ampd.epa.gov/ampd/QueryToolie.html. 

C-3. U.S. EPA, 2012. Emissions and Generation Resource Integrated Database (eGRID). Available: 

http://www.epa.gov/cleanenergy/energy-resources/egrid/index.html. 

C-4. U.S. EPA, 2010. Toxic Release Inventory. Available: http://www.epa.gov/tri/index.htm. 

C-5. U.S. Energy Information Administration, 2011. Available http://www.eia.gov/. 

C-6. U.S. EPA, 2012. Enforcement and Compliance History Online (ECHO). Available: http://www.epaecho.gov/echo/index.html. 

D-1. The Climate Registry, 2011. Available: http://www.theclimateregistry.org/. 

D-2. Western Climate Initiative, 2011. Available: http://www.westernclimateinitiative.org/index.php. 

D-3. Regional Greenhouse Gas Initiative (RGGI), 2011. Available: http://www.rggi.org/. 

E-1. “2011 Survey of Top 200 U.S. Oil and Gas Companies.” Oil and Gas Journal. 2011. Available: 

http://www.ogj.com/ogj-survey-downloads.html. 

E-2. “2011 Worldwide Production.” Oil and Gas Journal. 2011. Available: http://www.ogj.com/ogj-surveydownloads.html. 

E-3. “2008 Worldwide EOR Survey.” Oil and Gas Journal. 2008. Available: http://www.ogj.com/ogj-surveydownloads.html. 

F-1. Gas Technology Institute. “Identification and Evaluation of Opportunities to Reduce Methane Losses at 

Four Gas Processing Plants." June 20, 2002. Available: 

http://www.epa.gov/gasstar/documents/four_plants.pdf. 

F-2. Gas Research Institute (GRI) and U.S. EPA. “Methane Emissions from the Natural Gas Industry, Volume 

7: Blow and Purge Activities.” June 1996. Tables 5-1, 5-2, 5-5, and 5-6. Available: 

http://www.epa.gov/gasstar/documents/emissions_report/7_blowandpurge.pdf. 

F-3. U.S. EPA, ConocoPhillips Petroleum Company, New Mexico Environment Department, and New Mexico 

Oil & Gas Association. "Reducing Methane Emissions from Production Wells: Reduced Emission 

Completions." Producers Technology Transfer Workshop, Farmington, New Mexico. May 11, 2010. 

Available: http://www.epa.gov/gasstar/documents/workshops/farmington2010/08_recs_farmington_nm_final.pdf. 

F-4. U.S. EPA. "Cost-Effective Directed Inspection and Maintenance Control Opportunities at Five Gas 

Processing Plants and Upstream Gathering Compressor Stations and Well Sites." Table 5. March 2006. 

Available: http://www.epa.gov/gasstar/documents/clearstone_II_03_2006.pdf. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

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F-5. American Petroleum Institute (API). Industry Statistics, Quarterly Well Completion Report. Available: 

http://www.api.org/Publications-Standards-and-Statistics/Industry-Statistics/Data-Subscriptions.aspx. 

F-6. Bureau of Ocean Energy Management, Regulation and Enforcement. "Free ASCII Data Files." Available: 

http://www.gomr.boemre.gov/homepg/pubinfo/freeasci/freedesc.html. 

F-7. Bureau of Ocean Energy Management, Regulation and Enforcement. "OGOR A - Well Production Data." 

Available: http://www.gomr.boemre.gov/homepg/pubinfo/repcat/product/Production-A.html. 

F-8. U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration. Data and 

Statistics, Distribution, Transmission, and Liquid Annual Data, 2010 Gas Distribution Annual Data. 

Available: http://www.phmsa.dot.gov/pipeline/library/data-stats. 

F-9. Energy Association of Pennsylvania. “Before the Pennsylvania House Consumer Affairs Committee: 

Testimony of Terrance J. Fitzpatrick, President & CEO, Regarding House Bill 1294.” April 28, 2011. 

Available: 

http://www.energypa.org/assets/files/MediaCenter/8_Apr%2028%202011%20Test%20on%20HB%201294

%20(ARM).pdf. 

F-10. Pennsylvania Public Utility Commission, Paul Metro, Chief of Gas Safety Division. “Pennsylvania State 

Hazardous Materials & Pipeline Safety Meeting.” March 2008. Available: 

http://www.puc.state.pa.us/transport/gassafe/pdf/Presentation-Hazardous_Materials032008.pdf. 

F-11. American Gas Association, Lori S. Traweek. “Characterization of Gas Distribution Systems.” September 

21, 2005. Available: 

http://www.cycla.com/opsiswc/docs/s8/p0068/AGA_characterization_092105_Presentation.pdf. 

F-12. South Jersey Gas Company. “Direct Testimony of Charles F. Dippo, Vice President of Engineering 

Services & System Integrity.” January 2010. Available: http://www.southjerseygas.com/for-myhome/pdfs/base-rate-case/C_F_Dippo-%20FINAL.pdf.

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

38 

Appendix A 

List of “inputs to equations” data elements 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

39 

Subpart 

Citation Data Element 

Data Element is used as 

Input to Equation . . . Number of Facilitiesa 

A 98.3(d)(3)(v) Facility operating data or process information used for the GHG emission calculations, for 

abbreviated emissions report option available for RY 2010 only. N/A 

932 

C 98.36(b)(9)(iii) Estimate of the heat input from each type of fuel listed in Table C-2 that was combusted in 

the unit during the report year C-10 

1985 

C 98.36(c)(2)(ix) The flue gases from two or more stationary fuel combustion units at a facility are combined 

together and discharged through a common stack or duct before exiting to the atmosphere and 

if CEMS are used to continuously monitor CO2 mass emissions at the common stack or duct 

according to the Tier 4 Calculation Methodology, you may report the combined emissions 

from the units sharing the common stack or duct, in lieu of separately reporting the GHG 

emissions from the individual units. This monitoring and reporting alternative may also be 

used when process off-gases or a mixture of combustion products and process gases are 

combined together in a common stack or duct before exiting to the atmosphere. An estimate 

of the heat input from each type of fuel listed in Table C-2 combusted during the reporting 

year. 

C-10 

1985 

C 98.36(e)(2)(i) Total quantity of each type of fuel combusted in each unit or group of aggregated units (as 

applicable) during the reporting year, in short tons for solid fuels, gallons for liquid fuels and 

standard cubic feet for gaseous fuels, or, if applicable, therms or mmBtu for natural gas. C-1 

1985 

C 98.36(e)(2)(i) Total quantity of each type of fuel combusted in each unit or group of aggregated units (as 

applicable) during the reporting year, in short tons for solid fuels, gallons for liquid fuels and 

standard cubic feet for gaseous fuels, or, if applicable, therms or mmBtu for natural gas. C-1a 

1985 

C 98.36(e)(2)(i) Total quantity of each type of fuel combusted in each unit or group of aggregated units (as 

applicable) during the reporting year, in short tons for solid fuels, gallons for liquid fuels and 

standard cubic feet for gaseous fuels, or, if applicable, therms or mmBtu for natural gas. C-1b 

1985 

C 98.36(e)(2)(i) Total quantity of each type of fuel combusted in each unit or group of aggregated units (as 

applicable) during the reporting year, in short tons for solid fuels, gallons for liquid fuels and 

standard cubic feet for gaseous fuels, or, if applicable, therms or mmBtu for natural gas. C-8 

1985 

C 98.36(e)(2)(ii)(A) For Tier 2: Total quantity of each type of fuel combusted in the unit or group of aggregated 

units (as applicable) during each month of the reporting year. Express the quantity of each 

fuel combusted during the measurement period in short tons for solid fuels, gallons for liquid 

fuels, and scf for gaseous fuels. 

C-2b 

1985 

C 98.36(e)(2)(ii)(C) High heat values used in the CO2 emissions calculations for each fuel combusted during the 

reporting year. Report a HHV value for each calendar month in which HHV determination is 

required. If multiple values are obtained in a given month, report the arithmetic average 

value for the month. 

C-2b 

1985 

C 98.36(e)(2)(ii)(D) If Eq. C-2c is used: Total quantity (i.e., pounds) of steam produced from MSW or solid fuel 

combustion during each month of the reporting year, C-2c 

1985 

C 98.36(e)(2)(ii)(D) If Eq. C-2c is used: Ratio of the maximum rate heat input capacity to the design rated steam 

output capacity of the unit C-2c 

1985 

C 98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as applicable) during 

each month of the reporting year (Fuel) C-3 

1985 

C 98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as applicable) during 

each month of the reporting year (Fuel) C-4 

1985 

C 98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as applicable) during 

each month of the reporting year (Fuel) C-5 

1985 

C 98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as applicable) during 

each month of the reporting year (Fuel) C-8 

1985 

C 98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as applicable) during 

each month of the reporting year (Fuel) C-8a 

1985 

C 98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as applicable) during 

each month of the reporting year (Fuel) C-8b 

1985 

C 98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as applicable) during 

each month of the reporting year (Fuel) C-13 

1985 

C 98.36(e)(2)(iv)(C) The carbon content used in the emission calculations (including both valid and substitute data 

values). For each calendar month of the reporting year in which carbon content and, if 

applicable, molecular weight determination is required, report a value of each parameter. If 

multiple values of a parameter are obtained in a given month, report the arithmetic average 

value for the month. (CC) 

C-3 

1985 

C 98.36(e)(2)(iv)(C) The carbon content used in the emission calculations (including both valid and substitute data 

values). For each calendar month of the reporting year in which carbon content and, if 

applicable, molecular weight determination is required, report a value of each parameter. If 

multiple values of a parameter are obtained in a given month, report the arithmetic average 

value for the month. (CC) 

C-4 

1985 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

40 

Subpart 

Citation Data Element 

Data Element is used as 

Input to Equation . . . Number of Facilitiesa 

C 98.36(e)(2)(iv)(C) The carbon content used in the emission calculations (including both valid and substitute data 

values). For each calendar month of the reporting year in which carbon content and, if 

applicable, molecular weight determination is required, report a value of each parameter. If 

multiple values of a parameter are obtained in a given month, report the arithmetic average 

value for the month. (CC) 

C-5 

1985 

C 98.36(e)(2)(iv)(C) Gas molecular weight values used in the emission calculations (including both valid and 

substitute data values). For each calendar month of the reporting year in which carbon 

content and, if applicable, molecular weight determination is required, report a value of each 

parameter. If multiple values of a parameter are obtained in a given month, report the 

arithmetic average value for the month. 

C-5 

1985 

C 98.36(e)(2)(iv)(F) The annual average HHV, when measured HHV data, rather than a default HHV from Table 

C-1 of this subpart, are used to calculate CH4 and N2O emissions for a Tier 3 unit, in 

accordance with §98.33(c)(1). 

C-8 

1985 

C 98.36(e)(2)(ix)(D) For units that combust both fossil fuel and biomass, when biogenic CO2 is determined 

according to §98.33(e)(2), report the carbon-based F-factor used in Equation C-13 of this 

subpart 

C-13 

1985 

C 98.36(e)(2)(ix)(E) For units that combust both fossil fuel and biomass, when biogenic CO2 is determined 

according to §98.33(e)(2), report the annual average HHV value used in Equation C-13 of 

this subpart 

C-13 

1985 

C 98.36(e)(2)(ix)(F) For units that combust both fossil fuel and biomass, when biogenic CO2 is determined 

according to §98.33(e)(2), report the total quantity of fossil fuel combusted during the 

reporting year. 

C-13 

1985 

E 98.56(b) Total annual adipic acid production from unit “z” (Pz) E-2 3 

E 98.56(b) Total annual adipic acid production from unit “z” (Pz) E-3a 3 

E 98.56(b) Total annual adipic acid production from unit “z” (Pz) E-3b 3 

E 98.56(b) Total annual adipic acid production from unit “z” (Pz) E-3c 3 

E 98.56(b) Total annual adipic acid production from unit “z” (Pz) E-3d 3 

E 98.56(c) 

Annual adipic acid production during which N2O abatement technology (located after the test 

point) is operating (Pz,N) E-2 

3 

E 98.56(g) Abatement technology destruction efficiency for each abatement technology (DF) E-3a 3 

E 98.56(g) Abatement technology destruction efficiency for each abatement technology (DFN) E-3b 3 

E 98.56(g) Abatement technology destruction efficiency for each abatement technology (DFN) E-3c 3 

E 98.56(h) Abatement utilization factor for each abatement technology (AF) E-3a 3 

E 98.56(h) Abatement utilization factor for each abatement technology (AFN) E-3b 3 

E 98.56(h) Abatement utilization factor for each abatement technology (AFN) E-3c 3 

E 98.56(j)(1) Emission factor for each unit (EFN2Oz) E-3a 3 

E 98.56(j)(1) Emission factor for each unit (EFN2O) E-3b 3 

E 98.56(j)(1) Emission factor for each unit (EFN2O) E-3c 3 

E 98.56(j)(1) Emission factor for each unit (EFN2O) E-3d 3 

E 98.56(j)(3) Production rate per test run during performance test for each unit (P) E-1 3 

E 98.56(j)(4) N2O concentration per test run during performance test for each unit (CN2O) E-1 3 

E 98.56(j)(5) Volumetric flow rate per test run during performance test for each unit (Q) E-1 3 

E 

98.56(l) Fraction control factor for each abatement technology (percent of total emissions from the 

production unit that are sent to the abatement technology) if equation E-3c is used. (FCN) E-3c 

3 

E 98.56(j)(6) Number of test runs for each unit (n) E-1 3 

F 98.66(a) Annual aluminum production (MP) F-5 10 

F 98.66(a) Annual aluminum production (MP) F-6 10 

F 98.66(c)(2) Anode effect minutes per cell-day (AEM) F-2 10 

F 98.66(c)(2) Anode effect overvoltage factor (EFCF4) F-3 10 

F 98.66(c)(2) Anode effect frequency 

Used to calculate the 

slope coefficients used as 

an input in Eq. F-2 

10 

F 98.66(c)(2) Potline overvoltage 

Used to calculate the 

overvoltage factor used 

as an input in Eq. F-3 

10 

F 98.66(c)(2) Anode effect duration 

Used to calculate the 

slope coefficients used as 

an input in Eq. F-2 

10 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

41 

Subpart 

Citation Data Element 

Data Element is used as 

Input to Equation . . . Number of Facilitiesa 

F 98.66(c)(2) Current efficiency 

Used to calculate the 

overvoltage factor used 

as an input in Eq. F-3 

10 

F 98.66(c)(3) Smelter-specific slope coefficients (SCF4) F-2 10 

F 98.66(c)(3) Overvoltage emission factors (EFCF4) F-3 10 

F 98.66(e)(1) Annual anode consumption (No CEMS) (NAC) F-5 10 

F 98.66(f)(1) Annual paste consumption (No CEMS) (PC) F-6 10 

F 98.66(g) Sulfur content in baked anode (percent weight) (Sa) F-5 10 

F 98.66(g) Ash content in baked anode (percent weight) (Asha) F-5 10 

F 98.66(g) Binder content of paste (percent weight) (BC) F-6 10 

F 98.66(g) Sulfur content of pitch (percent weight) (Sp) F-6 10 

F 98.66(g) Ash content of pitch (percent weight). (Ashp) F-6 10 

F 98.66(g) Hydrogen content of pitch (percent weight) (Hp) F-6 10 

F 98.66(g) Sulfur content in calcined coke (percent weight) (Sc) F-6 10 

F 98.66(g) Ash content in calcined coke (percent weight) (Ashc) F-6 10 

F 98.66(g) Carbon in skimmed dust from Sderberg cells (metric ton C/metric ton Al) (CD) F-6 10 

F 98.66(g) Initial weight of green anodes (metric tons) (GA) F-7 10 

F 98.66(g) Annual hydrogen content in green anodes (metric tons) (Hw) F-7 10 

F 98.66(g) Annual baked anode production (metric tons) (BA) F-7 10 

F 98.66(g) Annual waste tar collected (metric tons) (WT) F-7 10 

F 98.66(g) Annual packing coke consumption (metric tons/metric ton baked anode) (PCC) F-8 10 

F 98.66(g) Annual baked anode production (metric tons) (BA) F-8 10 

F 98.66(g) Sulfur content in packing coke (percent weight) (SPc) 

F-8 

10 

F 98.66(g) Ash content in packing coke (percent weight) (Ashpc) F-8 10 

G 98.76(b)(2) Monthly quantity of each type of feedstock consumed for ammonia manufacturing - Gaseous 

Feedstock G-1 

22 

G 98.76(b)(2) Monthly quantity of each type of feedstock consumed for ammonia manufacturing - Liquid 

Feedstock G-2 

22 

G 98.76(b)(2) Monthly quantity of each type of feedstock consumed for ammonia manufacturing - Solid 

Feedstock G-3 

22 

G 98.76(b)(7) Carbon content of the gaseous feedstock G-1 22 

G 98.76(b)(8) Molecular weight of the gaseous feedstock G-1 22 

G 98.76(b)(9) Molar volume conversion factor of the gaseous feedstock G-1 22 

G 98.76(b)(10) Carbon content of the liquid feedstock, for month n G-2 22 

G 98.76(b)(11) Carbon content of the solid feedstock, for month n G-3 22 

H 98.86(b)(2) Monthly clinker production for each kiln (No CEMS) H-2 96 

H 98.86(b)(5) Quarterly quantity of CKD not recycled to the kiln H-2 96 

H 98.86(b)(6) Monthly fraction of total CaO in clinker H-3 96 

H 98.86(b)(6) Monthly fraction of total MgO in clinker H-3 96 

H 98.86(b)(6) Monthly fraction of non-calcined CaO in clinker H-3 96 

H 98.86(b)(6) Monthly fraction of non-calcined MgO in clinker H-3 96 

H 98.86(b)(8) Quarterly fraction of total CaO in CKD not recycled to the kiln H-4 96 

H 98.86(b)(8) Quarterly fraction of total MgO in CKD not recycled to the kiln H-4 96 

H 98.86(b)(8) Quarterly fraction of non-calcined CaO in CKD not recycled to the kiln H-4 96 

H 98.86(b)(8) Quarterly fraction of non-calcined MgO in CKD not recycled to the kiln H-4 96 

H 98.86(b)(10) Monthly kiln-specific clinker CO2 emission factors for each kiln H-2 96 

H 98.86(b)(11) Quarterly kiln-specific CKD CO2 emission factors for each kiln H-2 96 

H 98.86(b)(12) Annual organic carbon content of each raw kiln feed or annual organic carbon content of 

each raw material H-5 

96 

H 98.86(b)(13) Annual consumption of each raw kiln feed or annual consumption of each raw material H-5 96 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

42 

Subpart 

Citation Data Element 

Data Element is used as 

Input to Equation . . . Number of Facilitiesa 

H 98.86(b)(15) Monthly kiln-specific clinker factors (if used) for each kiln Used to calculate clinker 

production by facilities 

using the method in 40 

CFR 98.84(d) (i.e., kilnspecific clinker-to-feed 

factors) 

96 

K 98.116(b) Annual production by product from each EAF (tons) (used as input to Eq K-1): Mproductk= 

Annual mass of alloy product k tapped from EAF (tons). K-1 

10 

K 98.116(b) Annual production by product from each EAF (tons) (used as input to Eq K-3). K-3 10 

K 98.116(e)(4) Annual material quantity for each material included for the calculation of annual process CO2

emissions (No CEMS): Mreducing agenti= Annual mass of reducing agent i fed, charged, or 

otherwise introduced into the EAF (tons). K-1 

10 

K 98.116(e)(4) Annual material quantity for each material included for the calculation of annual process CO2

emissions (No CEMS): Melectrodem= Annual mass of carbon electrode m consumed in the 

EAF (tons). 

K-1 

10 

K 98.116(e)(4) Annual material quantity for each material included for the calculation of annual process CO2

emissions (No CEMS): Moreh= Annual mass of ore h charged to the EAF (tons). K-1 

10 

K 98.116(e)(4) Annual material quantity for each material included for the calculation of annual process CO2

emissions (No CEMS): Mfluxj= Annual mass of flux material j fed, charged, or otherwise 

introduced into the EAF to facilitate slag formation (tons). 

K-1 

10 

K 98.116(e)(4) Annual material quantity for each material included for the calculation of annual process CO2

emissions (No CEMS): Mnon-product outgoingl= Annual mass of non-product outgoing 

material l removed from EAF (tons). 

K-1 

10 

K 98.116(e)(5) Annual average of the carbon content determinations for each material included for the 

calculation of annual process CO2 emissions (No CEMS): Creducing agenti= Carbon content 

in reducing agent i (percent by weight, expressed as a decimal fraction). K-1 

10 

K 98.116(e)(5) Annual average of the carbon content determinations for each material included for the 

calculation of annual process CO2 emissions (No CEMS): Celectrodem= Carbon content of 

the carbon electrode m (percent by weight, expressed as a decimal fraction). K-1 

10 

K 98.116(e)(5) Annual average of the carbon content determinations for each material included for the 

calculation of annual process CO2 emissions (No CEMS): Coreh= Carbon content in ore h 

(percent by weight, expressed as a decimal fraction). 

K-1 

10 

K 98.116(e)(5) Annual average of the carbon content determinations for each material included for the 

calculation of annual process CO2 emissions (No CEMS): Cfluxj= Carbon content in flux 

material j (percent by weight, expressed as a decimal fraction). 

K-1 

10 

K 98.116(e)(5) Annual average of the carbon content determinations for each material included for the 

calculation of annual process CO2 emissions (No CEMS): Cproductk= Carbon content in 

alloy product k. (percent by weight, expressed as a decimal fraction). 

K-1 

10 

K 98.116(e)(5) Annual average of the carbon content determinations for each material included for the 

calculation of annual process CO2 emissions (No CEMS): Cnon-product outgoingl= Carbon 

content in non-product outgoing material l (percent by weight, expressed as a decimal 

fraction). 

K-1 

10 

L 98.126(b)(1) The data (including quantities and their accuracies and precisions) used in these calculations. 

eSA= Absolute error of the sum, expressed as one half of a 95 percent confidence interval. L-1 

16 

L 98.126(b)(1) The data (including quantities and their accuracies and precisions) used in these calculations. 

ea= Relative error of a, expressed as one half of a 95 percent confidence interval. L-1 

16

L 98.126(b)(1) The data (including quantities and their accuracies and precisions) used in these calculations. 

eb= Relative error of b, expressed as one half of a 95 percent confidence interval. L-1 

16

L 98.126(b)(1) The data (including quantities and their accuracies and precisions) used in these 

calculations.ec= Relative error of c, expressed as one half of a 95 percent confidence interval. L-1 

16

L 98.126(b)(1) The data (including quantities and their accuracies and precisions) used in these calculations. 

eSR= Relative error of the sum, expressed as one half of a 95 percent confidence interval. L-2 

16

L 98.126(b)(1) The data (including quantities and their accuracies and precisions) used in these calculations. 

eSA= Absolute error of the sum, expressed as one half of a 95 percent confidence interval. L-2 

16
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

43 

Subpart 

Citation Data Element 

Data Element is used as 

Input to Equation . . . Number of Facilitiesa 

L 98.126(b)(1) The data (including quantities and their accuracies and precisions) used in these calculations. 

a+b+c = Sum of the variables measured. L-2 

16

L 98.126(b)(1) The data (including quantities and their accuracies and precisions) used in these calculations. 

ea= Relative error of a, expressed as one half of a 95 percent confidence interval. L-3 

16

L 98.126(b)(1) The data (including quantities and their accuracies and precisions) used in these calculations. 

eb= Relative error of b, expressed as one half of a 95 percent confidence interval. L-3 

16

L 98.126(b)(1) The data (including quantities and their accuracies and precisions) used in these calculations. 

ec= Relative error of c, expressed as one half of a 95 percent confidence interval. L-3 

16

L 98.126(b)(1) The data (including quantities and their accuracies and precisions) used in these calculations. 

ePR= Relative error of the product, expressed as one half of a 95 percent confidence interval. L-4 

16

L 98.126(b)(1) The data (including quantities and their accuracies and precisions) used in these calculations. 

ePA= Absolute error of the product, expressed as one half of a 95 percent confidence 

interval. 

L-4 

16

L 98.126(b)(1) The data (including quantities and their accuracies and precisions) used in these calculations. 

a*b*c = Product of the variables measured. L-4 

16

L 98.126(b)(2) The balanced chemical equation that describes the reaction used to manufacture the 

fluorinated GHG product and each fluorinated GHG transformation product. - 16

L 98.126(b)(6) The mass of each fluorine-containing reactant that is fed into the process. (Rd) L-6 16

L 98.126(b)(8)(i) The mass of each fluorine-containing product that is removed from the process and fed into 

the destruction device (metric tons). (Pj) L-7 

16

L 98.126(b)(8)(ii) The mass of each fluorine-containing by-product that is removed from the process and fed 

into the destruction device (metric tons). (Bkj) L-7 

16

L 98.126(b)(8)(iii) The mass of each fluorine-containing reactant that is removed from the process and fed into 

the destruction device (metric tons). (Rdj) L-7 

16

L 98.126(b)(8)(iv) The mass of each fluorine-containing by-product that is removed from the process and 

recaptured (metric tons). (Bkl) L-7 

16

L 98.126(b)(8)(v) The demonstrated destruction efficiency of the destruction device for each fluorinated GHG 

fed into the device from the process in greater than trace concentrations (fraction). 

(DEFGHGf= Destruction efficiency of the device that has been demonstrated for fluorinated 

GHG f in stream j (fraction).) 

L-8 

16

L 98.126(b)(9)(i) The mass of fluorine in each stream that is fed into the destruction device (metric tons). 

(cTFj) L-17 

16

L 98.126(b)(9)(ii) The mass of fluorine that is recaptured (metric tons). (cTFl) L-17 16

L 98.126(b)(9)(iii) The weighted average destruction efficiency of the destruction device calculated for each 

stream under §98.123(b)(16). (Deavgj) L-17 

16

L 98.126(b)(10) The fraction of the mass emitted that consists of each fluorine-containing reactant. (ERpFGHGf) L-5 16

L 98.126(b)(10) The fraction of the mass emitted that consists of each fluorine-containing reactant (FERd) L-11 16

L 98.126(b)(10) The fraction of the mass emitted that consists of each fluorine-containing reactant. (FERd) L-12 16

L 98.126(b)(10) The fraction of the mass emitted that consists of each fluorine-containing reactant (FERd) L-13 16

L 98.126(b)(11) The fraction of the mass emitted that consists of the fluorine-containing product. (EPpFGHGf) L-5 16

L 98.126(b)(11) The fraction of the mass emitted that consists of the fluorine-containing product (FEP) L-11 16

L 98.126(b)(11) The fraction of the mass emitted that consists of the fluorine-containing product. (FEBk) L-12 16

L 98.126(b)(11) The fraction of the mass emitted that consists of the fluorine-containing product. (FEP) L-13 16

L 98.126(b)(12) The fraction of the mass emitted that consists of each fluorine-containing by-product (EBpFGHGf) L-5 16

L 98.126(b)(12) The fraction of the mass emitted that consists of each fluorine-containing by-product (FEBk) L-11 16

L 98.126(b)(12) The fraction of the mass emitted that consists of each fluorine-containing by-product. (FEBk) L-12 16

L 98.126(b)(12) The fraction of the mass emitted that consists of each fluorine-containing by-product. (FEBk) L-13 16

L 98.126(c)(1) The quantity of the process activity used to estimate emissions (e.g., tons of product produced 

or tons of reactant consumed). (ActivityEmissionTest) L-20 

16

L 98.126(c)(1) The quantity of the process activity used to estimate emissions (e.g., tons of product produced 

or tons of reactant consumed). (ActivityC) L-21 

16
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

44 

Subpart 

Citation Data Element 

Data Element is used as 

Input to Equation . . . Number of Facilitiesa 

L 98.126(c)(1) The quantity of the process activity used to estimate emissions (e.g., tons of product produced 

or tons of reactant consumed). (ActivityC) L-22 

16

L 98.126(c)(2) The site-specific, process-vent-specific emission factor(s) or emission calculation factor for 

each process vent (EFPV) L-20 

16

L 98.126(c)(2) The site-specific, process-vent-specific emission factor(s) or emission calculation factor for 

each process vent (EFPV–C) L-21 

16

L 98.126(c)(2) The site-specific, process-vent-specific emission factor(s) or emission calculation factor for 

each process vent (EFPV–U) L-22 

16

L 98.126(c)(2) The site-specific, process-vent-specific emission factor(s) or emission calculation factor for 

each process vent (EFPV) L-23 

16

L 98.126(c)(2) The site-specific, process-vent-specific emission factor(s) or emission calculation factor for 

each process vent (ECFPV) L-25 

16

L 98.126(c)(2) The site-specific, process-vent-specific emission factor(s) or emission calculation factor for 

each process vent (ECFPV) L-26 

16

L 98.126(c)(2) The site-specific, process-vent-specific emission factor(s) or emission calculation factor for 

each process vent (ECFPV) L-27 

16

L 98.126(d) Where missing data have been estimated pursuant to §98.125 report, estimate of the missing 

data Varies 

16

L 98.126(f)(1) Destruction efficiency (DE) of each destruction device for each fluorinated GHG whose 

destruction the facility reflects in §98.123, in accordance with §98.124(g)(1)(i) through (iv). 

(DEavgj) 

L-17 

16

L 98.126(f)(1) Destruction efficiency (DE) of each destruction device for each fluorinated GHG whose 

destruction the facility reflects in §98.123, in accordance with §98.124(g)(1)(i) through (iv). 

(DEFGHGf) 

L-18 

16

L 98.126(f)(1) Destruction efficiency (DE) of each destruction device for each fluorinated GHG whose 

destruction the facility reflects in §98.123, in accordance with §98.124(g)(1)(i) through (iv). 

(DE) 

L-22 

16

L 98.126(f)(1) Destruction efficiency (DE) of each destruction device for each fluorinated GHG whose 

destruction the facility reflects in §98.123, in accordance with §98.124(g)(1)(i) through (iv). 

(DE) 

L-27 

16

L 98.126(f)(1) Destruction efficiency (DE) of each destruction device for each fluorinated GHG whose 

destruction the facility reflects in §98.123, in accordance with §98.124(g)(1)(i) through (iv) 

(DE) 

L-31 

16

L 98.126(g)(1) The mass of the fluorinated GHG fed into the destruction device. (RED) L-31 16

L 98.126(h)(2) If applicable, the heel factor calculated for each container size and type. (hfj) L-34 16

N 98.146(b)(2) Annual quantity of carbonate based-raw material charged to each continuous glass melting 

furnace (No CEMS) N-1 

110 

N 98.146(b)(4) Carbonate-based mineral mass fraction of carbonate-based raw material charged to a furnace N-1 110 

N 98.146(b)(6) Fraction of calcination for carbonate-based raw material N-1 110 

O 98.156(a)(2) Loss Factor used to account for the loss of HCFC– 22 upstream of the measurement (LF used 

in equation O-3) O-3 

5 

O 98.156(a)(7) Annual mass of the HFC-23 generated (G23 in Eq. O-4) O-4 5 

O 98.156(a)(8) Annual mass of any HFC-23 sent off site for sale (S23 in Eq. O-4) O-4 5 

O 98.156(a)(9) Annual mass of any HFC-23 sent off site for destruction (OD23 usedin Eq. O-4) O-4 5 

O 98.156(a)(10) Mass of HFC-23 in storage at the beginning of the year (used to calculate I23, which is used in 

Eq. O-4) O-4 

5 

O 98.156(a)(10) Mass of HFC-23 in storage at the end of the year (used to calculate I23, which is used in Eq. 

O-4) O-4 

5 

O 98.156(b)(1) Annual mass of HFC-23 fed into the destruction device (FD used in Eq. O-8 and O-9) O-8 5 

O 98.156(b)(1) Annual mass of HFC-23 fed into the destruction device (FD used in Eq. O-8 and O-9) O-9 5 

O 98.156(b)(2) Annual mass of HFC-23 destroyed (D23 used in Eq. O-8) O-8 5 

O 98.156(d)(1) If the HFC-23 concentration measured pursuant to §98.154(l) is greater than that measured 

during the performance test that is the basis for the destruction efficiency (DE), report flow 

rate of HFC-23 being fed into the destruction device in kg/hr. 

No Equation - Used to 

calculate Destruction 

Efficiency 

5 

O 98.156(d)(2) If the HFC-23 concentration measured pursuant to §98.154(l) is greater than that measured 

during the performance test that is the basis for the destruction efficiency (DE), report 

concentration (mass fraction) of HFC-23 at the outlet of the destruction device. 

No Equation - Used to 

calculate Destruction 

Efficiency 

5 

O 98.156(d)(3) If the HFC-23 concentration measured pursuant to §98.154(l) is greater than that measured 

during the performance test that is the basis for the destruction efficiency (DE), report flow 

rate at the outlet of the destruction device in kg/hr. 

No Equation - Used to 

calculate Destruction 

Efficiency 

5 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

45 

Subpart 

Citation Data Element 

Data Element is used as 

Input to Equation . . . Number of Facilitiesa 

O 98.156(d)(4) If the HFC-23 concentration measured pursuant to §98.154(l) is greater than that measured 

during the performance test that is the basis for the destruction efficiency (DE), report 

emission rate (in kg/hour) calculated from the paragraphs (d)(2) and (d)(3) of this section. 

No Equation - Used to 

calculate Destruction 

Efficiency 

5 

O 98.156(d)(5) If the HFC-23 concentration measured pursuant to §98.154(l) is greater than that measured 

during the performance test that is the basis for the destruction efficiency (DE), report the 

destruction efficiency (DE) calculated from paragraphs (d)(1) and (d)(4) of this section. O-9 

5 

O 98.156(e)(1) (One time report) Destruction efficiency (DE) (by March 31, 2011 or within 60 days of 

commencing HFC-23 destruction). O-9 

5 

P 98.166(b)(2) Monthly consumption of each fuel and feedstock by type used for hydrogen production (No 

CEMS): gaseous P-1 

103 

P 98.166(b)(2) Monthly consumption of each fuel and feedstock by type used for hydrogen production (No 

CEMS) (Fdstkn): liquid P-2 

103 

P 98.166(b)(2) Monthly consumption of each fuel and feedstock by type used for hydrogen production (No 

CEMS) (Fdstkn): solid P-3 

103 

P 98.166(b)(5) Monthly analyses of carbon content for each fuel and feedstock used in hydrogen production: 

Gaseous P-1 

103 

P 98.166(b)(5) Monthly analyses of carbon content for each fuel and feedstock used in hydrogen production: 

Liquid P-2 

103 

P 98.166(b)(5) Monthly analyses of carbon content for each fuel and feedstock used in hydrogen production: 

Solid P-3 

103 

P 98.166(b)(6) Monthly analyses of the molecular weight of gaseous fuels and feedstocks P-1 103 

Q 98.176(b) Annual quantity taconite pellets produced (No CEMS) Q-1 128 

Q 98.176(b) Annual quantity coke produced (No CEMS) Q-2 128 

Q 98.176(b) Annual quantity sinter produced (No CEMS) Q-4 128 

Q 98.176(b) Annual quantity iron produced (No CEMS) Q-2 128 

Q 98.176(b) Annual quantity iron produced (No CEMS) Q-7 128 

Q 98.176(b) Annual quantity raw steel produced (No CEMS) Q-2 128 

Q 98.176(b) Annual quantity raw steel produced (No CEMS) Q-5 128 

Q 98.176(b) Annual quantity raw steel produced (No CEMS) Q-6 128 

Q 98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No CEMS) - solid 

fuel combusted (Csf) Q-1 

128 

Q 98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No CEMS) -gaseous 

fuel combusted (Cgf) Q-1 

128 

Q 98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No CEMS)- liquid 

fuel combusted (Clf) Q-1 

128 

Q 98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No CEMS)- 

greenball pellets produced (Co) Q-1 

128 

Q 98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No CEMS)- Iron 

(Ciron) Q-2 

128 

Q 98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No CEMS)- Scrap 

(Cscrap) Q-2 

128 

Q 98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No CEMS)- Flux 

(Cflux) Q-2 

128 

Q 98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No CEMS)- 

Carbonaceous material (Ccarbon) Q-2 

128 

Q 98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No CEMS)- Coal 

charged to coke battery (Ccoal) Q-3 

128 

Q 98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No CEMS)- Gaseous 

fuel combusted in the sinter process (Cgf) Q-4 

128 

Q 98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No CEMS) - sinter 

feed (CFeed) Q-4 

128 

Q 98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No CEMS)- Iron 

(Ciron) used in EAF Q-5 

128 

Q 98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No CEMS)- Scrap 

(Cscrap) used in EAF Q-5 

128 

Q 98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No CEMS)- Flux 

(Cflux) used in EAF Q-5 

128 

Q 98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No CEMS)- 

Carbonaceous material (Ccarbon) used in EAF Q-5 

128 

Q 98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No CEMS)- 

Electrode consumed in EAF (Celectrode) Q-5 

128 

Q 98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No CEMS) - molton 

steel before decarburization (Csteelout) in EAF Q-6 

128 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

46 

Subpart 

Citation Data Element 

Data Element is used as 

Input to Equation . . . Number of Facilitiesa 

Q 98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No CEMS) - 

Gaseous fuel combusted in the direct reduction furnace (Fg) Q-7 

128 

Q 98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No CEMS) - iron ore 

or iron ore pellets fed into the direct reduction furnace (Core) Q-7 

128 

Q 98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No CEMS)- 

Carbonaceous material (Ccarbon) used in the direct reduction furnace Q-7 

128 

Q 98.176(e)(1) Carbon content of each process input used to determine CO2 emissions (No CEMS) - Other 

materials charged to the direct reduction furnace (Cother) Q-7 

128 

Q 98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No CEMS) - Fired 

pellets produced (Cp) Q-1 

128 

Q 98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No CEMS) - air 

pollution control residue collected (Cr) Q-1 

128 

Q 98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No CEMS) - Steel 

produced (Csteel) Q-2 

128 

Q 98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No CEMS) - Slag 

produced (Cslag) Q-2 

128 

Q 98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No CEMS) - Air 

pollution control residue collected (CR) Q-2 

128 

Q 98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No CEMS) - Coke 

produced by coke battery (Ccoke) Q-3 

128 

Q 98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No CEMS) - Air 

pollution control residue collected from coke battery (CR) Q-3 

128 

Q 98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No CEMS) - sinter 

feed (CFeed) Q-4 

128 

Q 98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No CEMS) - Air 

pollution control residue collected from sinter process (CR) Q-4 

128 

Q 98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No CEMS) - Steel 

produced (Csteel) in EAF Q-5 

128 

Q 98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No CEMS) - Slag 

produced (Cslag) in EAF Q-5 

128 

Q 98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No CEMS) - Air 

pollution control residue collected (CR) for EAF Q-5 

128 

Q 98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No CEMS) - 

molton steel after decarburization (Csteelout) in EAF Q-6 

128 

Q 98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No CEMS) - Air 

pollution control residue collected (CR) for EAF Q-6 

128 

Q 98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No CEMS) - Iron 

produced from direct reduction furnace (Ciron) Q-7 

128 

Q 98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No CEMS) - Nonmetallic materials produced from direct reduction furnace (CNM) Q-7 

128 

Q 98.176(e)(1) Carbon content of each process output used to determine CO2 emissions (No CEMS) - Air 

pollution control residue collected (CR) for direct reduction furnace Q-7 

128 

Q 98.176(e)(3) Annual volume of each type of gaseous fuel used to determine CO2 emissions (reported 

separately for each type in standard cubic feet) (No CEMS) - Taconite Indurating Furnace Q-1 

128 

Q 98.176(e)(3) Annual volume of each type of gaseous fuel used to determine CO2 emissions (reported 

separately for each type in standard cubic feet) (No CEMS) - Sinter process (Fg) Q-4 

128 

Q 98.176(e)(3) Annual volume of each type of gaseous fuel used to determine CO2 emissions (reported 

separately for each type in standard cubic feet) (No CEMS) - direct reduction furnaces (Fg) Q-7 

128 

Q 98.176(e)(3) Annual volume of each type of liquid fuel used to determine CO2 emissions (reported 

separately for each type in gallons) (No CEMS) Q-1 

128 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine CO2 emissions 

(No CEMS)- Annual mass of greenball (taconite) pellets fed into the furnace (O) Q-1 

128 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine CO2 emissions 

(No CEMS)- Annual mass of solid fuel combusted (Fs) Q-1 

128 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine CO2 emissions 

(No CEMS)- Annual mass of molton iron charged to furnace (Iron) Q-2 

128 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine CO2 emissions 

(No CEMS)- Annual mass of scrap charged to the furnace (Scrap) Q-2 

128 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine CO2 emissions 

(No CEMS)- Annual mass of flux charged to the furnace (Flux) Q-2 

128 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine CO2 emissions 

(No CEMS)- Annual mass of carbon (e.g., coal, coke) charged to furnace (Carbon) Q-2 

128 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

47 

Subpart 

Citation Data Element 

Data Element is used as 

Input to Equation . . . Number of Facilitiesa 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine CO2 emissions 

(No CEMS)- Coal charged to battery (Coal) Q-3 

128 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine CO2 emissions 

(No CEMS)- Annual mass of sinter feed material (Feed) Q-4 

128 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine CO2 emissions 

(No CEMS)- Annual mass of direct reduced iron charged to the EAF (Iron) Q-5 128 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine CO2 emissions 

(No CEMS)- Annual mass of Scrap charged to the EAF(Scrap) Q-5 

128 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine CO2 emissions 

(No CEMS)- Annual mass of flux charged to the EAF(Flux) Q-5 

128 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine CO2 emissions 

(No CEMS)- Annual mass of carbon electrode consumed in the EAF(Electrode) Q-5 

128 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine CO2 emissions 

(No CEMS)- Annual mass of carbonaceous (coal or coke) material charged to the 

EAF(Carbon) 

Q-5 

128 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine CO2 emissions 

(No CEMS)- Annual mass of steel charged to the decarburization vessel (Steel) Q-6 

128 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine CO2 emissions 

(No CEMS)- Annual mass of iron ore or iron ore pellets charged to the direct reduction 

furnace (Ore) 

Q-7 

128 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine CO2 emissions 

(No CEMS)- Annual mass of carbonaceous (coal or coke) material charged to the direct 

reduction furnace (Carbon) 

Q-7 

128 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine CO2 emissions 

(No CEMS)- Annual mass of other material charged to the direct reduction furnace (Other) Q-7 

128 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine CO2 emissions 

(No CEMS) - Annual mass of air pollution control residue (R). Q-1 

128 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine CO2 emissions 

(No CEMS) - Annual mass of fired pellets produced (P) Q-1 

128 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine CO2 emissions 

(No CEMS) - Annual mass of steel produced (Steel) Q-2 

128 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine CO2 emissions 

(No CEMS) - Annual mass of slag produced (Slag) Q-2 

128 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine CO2 emissions 

(No CEMS) - Annual mass of air pollution control residue collected (Residue) Q-2 

128 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine CO2 emissions 

(No CEMS) - Annual mass of coke produced (Coke) Q-3 

128 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine CO2 emissions 

(No CEMS) - Annual mass of air pollution control residue collected from battery (R) Q-3 

128 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine CO2 emissions 

(No CEMS)- Annual mass of sinter Produced (Sinter) Q-4 

128 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine CO2 emissions 

(No CEMS) - Annual mass of air pollution control residue collected from sinter process (R) Q-4 

128 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine CO2 emissions 

(No CEMS)- Annual mass of steel produced (Steel) in EAF Q-5 

128 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine CO2 emissions 

(No CEMS) - Annual mass of slag produced (Slag) in EAF Q-5 

128 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine CO2 emissions 

(No CEMS) - Annual mass of air pollution control residue collected (Residue) from EAF Q-5 

128 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine CO2 emissions 

(No CEMS) - Annual mass of air pollution control residue collected (Residue) from the 

decarburization vessel 

Q-6 

128 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine CO2 emissions 

(No CEMS)- Annual mass of iron produced (Iron) in direct reduction furnace Q-7 

128 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine CO2 emissions 

(No CEMS)- Annual mass of non-metallic materials produced (NM) in direct reduction 

furnace 

Q-7 

128 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

48 

Subpart 

Citation Data Element 

Data Element is used as 

Input to Equation . . . Number of Facilitiesa 

Q 98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine CO2 emissions 

(No CEMS) - Annual mass of air pollution control residue collected (Residue) from the direct 

reduction furnace 

Q-7 

128 

Q 98.176(e)(4) Molecular weight of gaseous fuels (No CEMS) - Taconite Indurating Furnace Q-1 128 

Q 98.176(e)(4) Molecular weight of gaseous fuels (No CEMS) - Sinter Process Q-4 128 

Q 98.176(e)(4) Molecular weight of gaseous fuels (No CEMS) - Direct Reduction Furnace Q-7 128 

Q 98.176(f)(1) Measured average hourly CO2 emission rate during the test (No CEMS) No Equation - Used as 

input to method 

described in 

98.173(b)(iii). 

128 

Q 98.176(f)(2) Average hourly feed rate during the test (No CEMS) No Equation - Used as 

input in calc. method 

described in 

98.173(b)(iii). 

128 

Q 98.176(f)(2) Average hourly production rate during the test (No CEMS) No Equation - Used as 

input in calc. method 

described in 

98.173(b)(iii). 

128 

Q 98.176(f)(3) Site-specific emission factor (No CEMS) No Equation - Used as 

input in calc. method 

described in 

98.173(b)(iv). 

128 

Q 98.176(f)(4) Annual feed rate used to estimate annual CO2 emissions (No CEMS) No Equation - Used as 

input in calc. method 

described in 

98.173(b)(iv). 

128 

Q 98.176(f)(4) Annual production rate used to estimate annual CO2 emissions (No CEMS) No Equation - Used as 

input in calc. method 

described in 

98.173(b)(iv). 

128 

Q 98.176(g) The annual amount of coal charged to the coke ovens (in metric tons). No Equation - Used as 

input in calc. method 

described in 98.173(c). 

128 

R 98.186(b)(6) Annual material quantity used for the calculation of annual process CO2 emissions (No 

CEMS) (Ore = Annual mass of lead ore charged to the smelting furnace (tons).) R-1 

13 

R 98.186(b)(6) Annual material quantity used for the calculation of annual process CO2 emissions (No 

CEMS) (Scrap = Annual mass of lead scrap charged to the smelting furnace (tons).) 

R-1 

13 

R 98.186(b)(6) Annual material quantity used for the calculation of annual process CO2 emissions (No 

CEMS) (Flux = Annual mass of flux materials (e.g., limestone, dolomite) charged to the 

smelting furnace (tons).) R-1 

13 

R 98.186(b)(6) Annual material quantity used for the calculation of annual process CO2 emissions (No 

CEMS) (Carbon = Annual mass of carbonaceous materials (e.g., coal, coke) charged to the 

smelting furnace (tons).) R-1 

13 

R 98.186(b)(6) Annual material quantity used for the calculation of annual process CO2 emissions (No 

CEMS) (Other = Annual mass of any other material containing carbon, other than fuel, fed, 

charged, or otherwise introduced into the smelting furnace (tons).) R-1 

13 

R 98.186(b)(7) Annual average of the carbon content determinations for each material used for the 

calculation of annual process CO2 emissions (No CEMS) (COre= Carbon content of the lead 

ore, from the carbon analysis results (percent by weight, expressed as a decimal fraction).) 

R-1 

13 

R 98.186(b)(7) Annual average of the carbon content determinations for each material used for the 

calculation of annual process CO2 emissions (No CEMS). (CScrap= Carbon content of the 

lead scrap, from the carbon analysis (percent by weight, expressed as a decimal fraction).) 

R-1 

13 

R 98.186(b)(7) Annual average of the carbon content determinations for each material used for the 

calculation of annual process CO2 emissions (No CEMS). (CFlux= Carbon content of the 

flux materials, from the carbon analysis (percent by weight, expressed as a decimal fraction).) 

R-1 

13 

R 98.186(b)(7) Annual average of the carbon content determinations for each material used for the 

calculation of annual process CO2 emissions (No CEMS). (CCarbon= Carbon content of the 

carbonaceous materials, from the carbon analysis (percent by weight, expressed as a decimal 

fraction).) R-1 

13 

R 98.186(b)(7) Annual average of the carbon content determinations for each material used for the 

calculation of annual process CO2 emissions (No CEMS). (COther= Carbon content of the 

other material from the carbon analysis results (percent by weight, expressed as a decimal 

fraction).) R-1 

13 

S 98.196(b)(2) Monthly emission factors for each lime type produced. S-1 73 

S 98.196(b)(2) Monthly emission factors for each lime type produced. S-4 73 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

49 

Subpart 

Citation Data Element 

Data Element is used as 

Input to Equation . . . Number of Facilitiesa 

S 98.196(b)(3) Monthly emission factors for each calcined byproduct/waste by lime type that is sold. 

(EFLKD,i,n) S-2 

73 

S 98.196(b)(3) Monthly emission factors for each calcined byproduct/waste by lime type that is sold. 

(EFLKD,i,n) S-4 

73 

S 98.196(b)(5) Monthly results of chemical composition analysis of each type of lime product produced (No 

CEMS) 

No Equation -described 

in 98.196(b)(5). 

73 

S 98.196(b)(5) Monthly results of chemical composition analysis of each type of calcined lime 

byproducts/wastes sold (No CEMS) 

No Equation -described 

in 98.196(b)(5). 

73 

S 98.196(b)(6) Annual results of chemical composition analysis of each type of lime byproducts/wastes that 

is not sold (No CEMS) 

No Equation -described 

in 98.196(b)(6). 

73 

S 98.196(b)(8) Monthly amount of lime product sold, by type (No CEMS) No Equation -described 

in 98.196(b)(8). 

73 

S 98.196(b)(10) Monthly amount of calcined lime byproduct/waste sold, by type (No CEMS) No Equation -described 

in 98.196(b)(10). 

73 

S 98.196(b)(11) Annual amount of calcined lime byproduct/waste that is not sold, by type (No CEMS) No Equation -described 

in 98.196(b)(11). 

73 

S 98.196(b)(12) Monthly weight or mass of each lime type produced (No CEMS) S-4 73 

U 98.216(b) Annual carbonate consumption by carbonate type U-1 18 

U 98.216(e)(1) Annual carbonate consumption by carbonate type U-1 18 

U 98.216(e)(2) Annual calcination fractions used in calculations U-1 18 

U 98.216(b) Annual carbonate input by carbonate type U-2 18 

U 98.216(f)(1) Annual carbonate input by carbonate type U-2 18 

U 98.216(f)(2) Annual carbonate output by carbonate type U-2 18 

V 98.226(c) Annual nitric acid production from each nitric acid train (tons, 100% acid basis) (Pt) V-2 36 

V 98.226(c) Annual nitric acid production from each nitric acid train (tons, 100% acid basis) (Pt) V-3a 36 

V 98.226(c) Annual nitric acid production from each nitric acid train (tons, 100% acid basis) (Pt) V-3b 36 

V 98.226(c) Annual nitric acid production from each nitric acid train (tons, 100% acid basis) (Pt) V-3c 36 

V 98.226(c) Annual nitric acid production from each nitric acid train (tons, 100% acid basis) (Pt) V-3d 36 

V 98.226(d) Annual nitric acid production during which N2O abatement technology is operating (tons, 

100% acid basis) V-2 

36 

V 98.226(i) Abatement technology destruction efficiency (DF) V-3a 36 

V 98.226(i) Abatement technology destruction efficiency (DF) V-3b 36 

V 98.226(i) Abatement technology destruction efficiency (DF) V-3c 36 

V 98.226(j) Abatement utilization factor (AF) V-3a 36 

V 98.226(j) Abatement utilization factor (AF) V-3b 36 

V 98.226(j) Abatement utilization factor (AF) V-3c 36 

V 98.226(m)(1) Emission factor calculated for each nitric acid train (EFN2Ot) V-3a 36 

V 98.226(m)(1) Emission factor calculated for each nitric acid train (EFN2Ot) V-3b 36 

V 98.226(m)(1) Emission factor calculated for each nitric acid train (EFN2Ot) V-3c 36 

V 98.226(m)(1) Emission factor calculated for each nitric acid train (EFN2Ot) V-3d 36 

V 98.226(m)(3) Production rate per test run during performance test for each train. V-1 36 

V 98.226(m)(4) N2O concentration per test run during performance test for each train. V-1 36 

V 98.226(m)(5) Volumetric flow rate per test run during performance test each train. V-1 36 

V 98.226(m)(6) Number of test runs during performance test each train. V-1 36 

V 98.226(p) Fraction control factor for each abatement technology (percent of total emissions from the 

production unit that are sent to the abatement technology) if equation V-3c is used. V-3c 

36 

W 98.236(c)(1)(i) Actual count of natural gas pneumatic high bleed devices. W-1 873 

W 98.236(c)(1)(i) Estimated count of natural gas pneumatic high bleed devices. W-1 873 

W 98.236(c)(1)(ii) Actual count of natural gas pneumatic low bleed devices. W-1 873 

W 98.236(c)(1)(ii) Estimated count of natural gas pneumatic low bleed devices. W-1 873 

W 98.236(c)(1)(iii) Actual count of natural gas pneumatic intermittent bleed devices. W-1 873 

W 98.236(c)(1)(iii) Estimated count of natural gas pneumatic intermittent bleed devices. W-1 873 

W 98.236(c)(2)(i) Count of natural gas driven pneumatic pumps. W-2 873 

W 98.236(c)(3)(i) Total throughput of each acid gas removal unit using a meter or engineering estimate based 

on process knowledge or best available data. 

W-3 186 

W 98.236(c)(3)(ii) For Calculation Methodology 2 of §98.233(d), annual average fraction of CO2 content in the 

vent from each acid gas removal unit. 

W-3 186 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

50 

Subpart 

Citation Data Element 

Data Element is used as 

Input to Equation . . . Number of Facilitiesa 

W 98.236(c)(3)(iii) For Calculation Methodology 3 of §98.233(d), annual average volume fraction of CO2

content of natural gas into each acid gas removal unit. 

W-4A 186 

W 98.236(c)(3)(iii) For Calculation Methodology 3 of §98.233(d), annual average volume fraction of CO2 

content of natural gas into each acid gas removal unit. 

W-4B 186 

W 98.236(c)(3)(iii) For Calculation Methodology 3 of §98.233(d), annual average volume fraction of CO2 

content of natural gas out of each acid gas removal unit. 

W-4A 186 

W 98.236(c)(3)(iii) For Calculation Methodology 3 of §98.233(d), annual average volume fraction of CO2 

content of natural gas out of each acid gas removal unit. 

W-4B 186 

W 98.236(c)(3)(iv) Annual quantity of CO2, that was recovered from each acid gas removal unit and transferred 

outside the facility (metric tons CO2e), under subpart PP of this part. 

98.233(d)(11) 186 

W 98.236(c)(4)(i)(A) For each glycol dehydrator with throughput greater than or equal to 0.4 MMscfd: Glycol 

dehydrator feed natural gas flow rate in MMscfd, determined by engineering estimate based 

on best available data. 

Methodology 1 186 

W 98.236(c)(4)(i)(B) For each glycol dehydrator with throughput greater than or equal to 0.4 MMscfd: Glycol 

dehydrator absorbent circulation pump type. 

Methodology 1 186 

W 98.236(c)(4)(i)(C) For each glycol dehydrator with throughput greater than or equal to 0.4 MMscfd: Report 

whether stripper gas is used in glycol dehydrator. 

Methodology 1 186 

W 98.236(c)(4)(i)(D) For each glycol dehydrator with throughput greater than or equal to 0.4 MMscfd: Report 

whether a flash tank separator is used in glycol dehydrator. 

Methodology 1 186 

W 98.236(c)(4)(i)(E) For each glycol dehydrator with throughput greater than or equal to 0.4 MMscfd: Report type 

of absorbent. 

Methodology 1 186 

W 98.236(c)(4)(i)(F) For each glycol dehydrator with throughput greater than or equal to 0.4 MMscfd: Total time 

the glycol dehydrator is operating in hours. 

Methodology 1 186 

W 98.236(c)(4)(i)(G) For each glycol dehydrator with throughput greater than or equal to 0.4 MMscfd: 

Temperature of the wet natural gas (degrees Fahrenheit). 

Methodology 1 186 

W 98.236(c)(4)(i)(G) For each glycol dehydrator with throughput greater than or equal to 0.4 MMscfd: Pressure of 

the wet natural gas (psig). 

Methodology 1 186 

W 98.236(c)(4)(i)(H) For each glycol dehydrator with throughput greater than or equal to 0.4 MMscfd: 

Concentration of CO2 in wet natural gas. 

Methodology 1 186 

W 98.236(c)(4)(i)(H) For each glycol dehydrator with throughput greater than or equal to 0.4 MMscfd: 

Concentration of CH4 in wet natural gas. 

Methodology 1 186 

W 98.236(c)(4)(ii)(A) For all glycol dehydrator with throughput less than 0.4 MMscfd: Count of glycol dehydrators. W-5 186 

W 98.236(c)(5)(i)(D) For well venting for liquids unloading, for Calculation Methodology 1, report the following 

by each tubing diameter group and pressure group combination within each sub-basin 

category: Average flow rate of the measured well venting (cubic feet per hour). 

W-7 873 

W 98.236(c)(5)(ii)(C) For well venting for liquids unloading, for Calculation Methodologies 2 and 3, report the 

following for each sub-basin category: Cumulative number of unloadings vented to the 

atmosphere. 

W-8 873 

W 98.236(c)(5)(ii)(C) For well venting for liquids unloading, for Calculation Methodologies 2 and 3, report the 

following for each sub-basin category: Cumulative number of unloadings vented to the 

atmosphere. 

W-9 873 

W 98.236(c)(6)(i)(B) For well completions and workovers with hydraulic fracturing, report the following for each 

sub-basin and well type (horizontal or vertical) combination: When using Equation W-10A, 

measured flow rate of backflow during well completion (cubic feet per hour). 

W-10A 873 

W 98.236(c)(6)(i)(D) For well completions and workovers with hydraulic fracturing, report the following for each 

sub-basin and well type (horizontal or vertical) combination: When using Equation W-10A, 

measured flow rate of backflow during well workover (cubic feet per hour). 

W-12 873 

W 98.236(c)(6)(i)(E) For well completions and workovers with hydraulic fracturing, report the following for each 

sub-basin and well type (horizontal or vertical) combination: When using Equation W-10A, 

total number of days of backflow from all wells during completions. 

W-10A 873 

W 98.236(c)(6)(i)(F) For well completions and workovers with hydraulic fracturing, report the following for each 

sub-basin and well type (horizontal or vertical) combination: When using Equation W-10A, 

total number of days of backflow from all wells during workovers. 

W-10A 873 

W 98.236(c)(6)(i)(G) For well completions and workovers with hydraulic fracturing, report the following for each 

sub-basin and well type (horizontal or vertical) combination: The amount of gas recovered to 

sales using engineering estimate based on best available data. 

W-10A 873 

W 98.236(c)(6)(i)(H) For well workovers with hydraulic fracturing, report the following for each sub-basin and 

well type (horizontal or vertical) combination: The amount of gas recovered to sales using 

engineering estimate based on best available data. 

W-10A 873 

W 98.236(c)(6)(ii)(A) For well completions and workovers without hydraulic fracturing, report the following for 

each sub-basin and well type (horizontal or vertical) combination: Total count of completions 

in calendar year. 

W-13 873 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

51 

Subpart 

Citation Data Element 

Data Element is used as 

Input to Equation . . . Number of Facilitiesa 

W 98.236(c)(6)(ii)(B) For well completions and workovers without hydraulic fracturing, report the following for 

each sub-basin and well type (horizontal or vertical) combination: Total count of workovers 

in calendar year that flare gas or vent gas to the atmosphere. 

W-13 873 

W 98.236(c)(7)(i)(A) For blowdown vent stack emission source, for each unique physical volume that is blown 

down more than once during the calendar year: Total number of blowdowns for each unique 

physical volume in the calendar year. (when using Eq. W-14A) 

W-14A 873 

W 98.236(c)(8)(i)(F) For wellhead gas-liquid separator with oil throughput greater than or equal to 10 barrels per 

day, using Calculation Methodology 1 and 2 of 40 CFR 98.233(j), report by sub-basin 

category: Total volume of oil from all wellhead separators sent to tank(s) in barrels per year. 

Methodology 1 (see 

98.236j2) 

873 

W 98.236(c)(8)(i)(F) For wellhead gas-liquid separator with oil throughput greater than or equal to 10 barrels per 

day, using Calculation Methodology 1 and 2 of 40 CFR 98.233(j), report by sub-basin 

category: Total volume of oil from all wellhead separators sent to tank(s) in barrels per year. 

Methodology 2 (see 

98.233j1) 

873 

W 98.236(c)(8)(i)(K) For wellhead gas-liquid separator with oil throughput greater than or equal to 10 barrels per 

day, using Calculation Methodology 1 of 40 CFR 98.233(j), report by sub-basin category: 

Annual CO2 gas quantities that were recovered (metric tons CO2e), for all wellhead gas-liquid 

separators or storage tanks using Calculation Methodology 1 of §98.233(j). 

98.233(j)(6)(i) 873 

W 98.236(c)(8)(ii)(A) For wells with oil production greater than or equal to 10 barrels per day, using Calculation 

Methodology 3 and 4 of 40 CFR 98.233(j), report the following by sub-basin category: Total 

volume of sales oil from all wells (barrels per year). 

Methodology 3 and 4 

[see 98.233(j)(3) and 

(j)(4)] 

873 

W 98.236(c)(8)(ii)(H) For wells with oil production greater than or equal to 10 barrels per day, using Calculation 

Methodology 3 and 4 of 40 CFR 98.233(j), report the following by sub-basin category: 

Annual CO2 gas quantities that were recovered (metric tons CO2e), for Calculation 

Methodology 3 or 4 of §98.233(j). 

98.233(j)(6)(i) 873 

W 98.236(c)(8)(iii)(A) For wellhead gas-liquid separators and wells with throughput less than 10 barrels per day, 

using Calculation Methodology 5 of 40 CFR 98.233(j) Equation W-15 of 40 CFR 98.233: 

Number of wellhead separators. 

W-15 873 

W 98.236(c)(8)(iii)(B) For wellhead gas-liquid separators and wells with throughput less than 10 barrels per day, 

using Calculation Methodology 5 of 40 CFR 98.233(j) Equation W–15 of 40 CFR 98.233: 

Number of wells without wellhead separators. 

W-15 873 

W 98.236(c)(8)(iii)(G) For wellhead gas-liquid separators and wells with throughput less than 10 barrels per day, 

using Calculation Methodology 5 of 40 CFR 98.233(j) Equation W-15 of 40 CFR 98.233: 

Annual CO2 gas quantities that were recovered (metric tons CO2e), at the sub-basin level for 

Calculation Methodology 5 of §98.233(j). 

98.233(j)(6)(i) 873 

W 98.236(c)(12)(ii) For flare stacks: Volume of gas sent to flare (cubic feet per year). W-19 1059 

W 98.236(c)(12)(ii) For flare stacks: Volume of gas sent to flare (cubic feet per year). W-20 1059 

W 98.236(c)(12)(ii) For flare stacks: Volume of gas sent to flare (cubic feet per year). W-21 1059 

W 98.236(c)(12)(v) For flare stacks: Flare combustion efficiency. W-19 1059 

W 98.236(c)(12)(v) For flare stacks: Flare combustion efficiency. W-21 1059 

W 98.236(c)(13)(i)(E) For compressors with wet seals in operational mode: Reporter emission factor for wet seal oil 

degassing vents in cubic feet per hour (refer to Equation W-24 of 40 CFR 98.233). 

W-23 200 

W 98.236(c)(13)(i)(F) For compressors with wet seals in operational mode: Total time the compressor is operating 

(hours). 

W-22 200 

W 98.236(c)(13)(i)(F) For compressors with wet seals in operational mode: Total time the compressor is operating 

(hours). 

W-23 200 

W 98.236(c)(13)(ii)(A) For wet and dry seal centrifugal compressors in operating mode: Total time the compressor is 

in operating mode (hours). 

W-23 200 

W 98.236(c)(13)(ii)(B) For wet and dry seal centrifugal compressors in operating mode: Reporter emission factor for 

blowdown vents (cubic feet per hour). 

W-23 200 

W 98.236(c)(13)(iii)(A) For wet and dry seal centrifugal compressors: Total time the compressor is in shutdown, 

depressurized mode (hours). 

W-22 200 

W 98.236(c)(13)(iii)(A) For wet and dry seal centrifugal compressors: Total time the compressor is in shutdown, 

depressurized mode (hours). 

W-23 200 

W 98.236(c)(13)(iii)(B) For wet and dry seal centrifugal compressors: Reporter emission factor for isolation valve 

emissions in shutdown, depressurized mode (cubic feet per hour). 

W-23 200 

W 98.236(c)(13)(v)(A) For centrifugal compressors in onshore petroleum and natural gas production: Count of 

compressors. 

W-25 200 

W 98.236(c)(14)(i)(B) For reciprocating compressors rod packing emissions with or without a vent in operating 

mode: Total time the reciprocating compressor is in operating mode (hours). 

W-26 200 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

52 

Subpart 

Citation Data Element 

Data Element is used as 

Input to Equation . . . Number of Facilitiesa 

W 98.236(c)(14)(i)(B) For reciprocating compressors rod packing emissions with or without a vent in operating 

mode: Total time the reciprocating compressor is in operating mode (hours). 

W-27 200 

W 98.236(c)(14)(ii)(A) For reciprocating compressors blowdown vents not manifold to rod packing vents, in 

operating and standby pressurized mode: Total time the compressor is in standby, pressurized 

mode (hours). 

W-26 200 

W 98.236(c)(14)(ii)(A) For reciprocating compressors blowdown vents not manifold to rod packing vents, in 

operating and standby pressurized mode: Total time the compressor is in standby, pressurized 

mode (hours). 

W-27 200 

W 98.236(c)(14)(ii)(B) For reciprocating compressors blowdown vents not manifold to rod packing vents, in 

operating and standby pressurized mode: Emission factor for blowdown vents (cubic feet per 

hour). 

W-27 200 

W 98.236(c)(14)(iii)(A) For reciprocating compressors: Total time the compressor is in not operating, depressurized 

mode. 

W-26 200 

W 98.236(c)(14)(iii)(A) For reciprocating compressors: Total time the compressor is in not operating, depressurized 

mode. 

W-27 200 

W 98.236(c)(14)(iii)(B) For reciprocating compressors: Reporter emission factor for isolation valve emissions in not 

operating, depressurized mode. 

W-27 200 

W 98.236(c)(14)(v)(A) For reciprocating compressors in onshore petroleum and natural gas production: Count of 

compressors. 

W-29 200 

W 98.236(c)(15)(ii)(A) For equipment leaks calculated using population counts and factors [refer to §98.233(r)], 

report the following: 

For source categories 40 CFR 98.230(a)(4), (a)(5), (a)(6), (a)(7), and (a)(8) total count for 

each type of leak source in Tables W-2, W-3, W-4, W-5, and W-6 of this subpart for which 

there is a population emission factor, listed by major heading and component type. 

 W-31 873 

W 98.236(c)(15)(ii)(B) For equipment leaks calculated using population counts and factors [refer to §98.233(r)], 

report the following: 

For equipment leaks calculated using population counts and factors: For onshore production 

[refer to 40 CFR 98.230(a)(2)], total count for each type of major equipment in Table W-1B 

and Table W-1C of this subpart, by sub-basin category. 

 W-31 873 

W 98.236(c)(16)(viii) For local distribution companies: Leak factor for meter/regulator run developed in Equation 

W-32 of §98.233. 

W-31 150 

W 98.236(c)(16)(ix) For local distribution companies: Number of miles of unprotected steel distribution mains. W-31 150 

W 98.236(c)(16)(x) For local distribution companies: Number of miles of protected steel distribution mains. W-31 150 

W 98.236(c)(16)(xi) For local distribution companies: Number of miles of plastic distribution mains. W-31 150 

W 98.236(c)(16)(xii) For local distribution companies: Number of miles of cast iron distribution mains. W-31 150 

W 98.236(c)(16)(xiii) For local distribution companies: Number of unprotected steel distribution services. W-31 150 

W 98.236(c)(16)(xiv) For local distribution companies: Number of protected steel distribution services. W-31 150 

W 98.236(c)(16)(xv) For local distribution companies: Number of plastic distribution services. W-31 150 

W 98.236(c)(16)(xvi) For local distribution companies: Number of copper distribution services. W-31 150 

W 98.236(c)(17)(ii) For each EOR injection pump blowdown: Volume of critical phase gas between isolation 

valves. 

W-37 N/A 

W 98.236(c)(17)(iii) For each EOR injection pump blowdown: Number of blowdowns per year. W-37 N/A 

W 98.236(c)(17)(iv) For each EOR injection pump blowdown: Critical phase EOR injection gas density. W-37 N/A 

W 98.236(c)(18)(i) For EOR hydrocarbon liquids dissolved CO2 for each sub-basin category: Volume of crude 

oil produced (barrels per year). 

W-38 N/A 

W 98.236(c)(18)(ii) For EOR hydrocarbon liquids dissolved CO2 for each sub-basin category: Amount of CO2

retained in hydrocarbon liquids (metric tons per barrel), under standard conditions. 

W-38 N/A 

W 98.236(c)(19)(iv) For onshore petroleum and natural gas production and natural gas distribution combustion 

emissions: Cumulative volume of fuel combusted in external fuel combustion units with a 

rated heat capacity larger than 5 mmBtu/hr, by fuel type. 

W-39A 873 

W 98.236(c)(19)(iv) For onshore petroleum and natural gas production and natural gas distribution combustion 

emissions: Cumulative volume of fuel combusted in external fuel combustion units with a 

rated heat capacity larger than 5 mmBtu/hr, by fuel type. 

W-39B 873 

W 98.236(c)(19)(iv) For onshore petroleum and natural gas production and natural gas distribution combustion 

emissions: Cumulative volume of fuel combusted in external fuel combustion units with a 

rated heat capacity larger than 5 mmBtu/hr, by fuel type. 

W-40 873 

W 98.236(c)(19)(vii) For onshore petroleum and natural gas production and natural gas distribution combustion 

emissions: Cumulative volume of fuel combusted in internal combustion units with a rated 

heat capacity larger than 1 mmBtu/hr or 130 horsepower, by fuel type. 

W-39A 873 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

53 

Subpart 

Citation Data Element 

Data Element is used as 

Input to Equation . . . Number of Facilitiesa 

W 98.236(c)(19)(vii) For onshore petroleum and natural gas production and natural gas distribution combustion 

emissions: Cumulative volume of fuel combusted in internal combustion units with a rated 

heat capacity larger than 1 mmBtu/hr or 130 horsepower, by fuel type. 

W-39B 873 

W 98.236(c)(19)(vii) For onshore petroleum and natural gas production and natural gas distribution combustion 

emissions: Cumulative volume of fuel combusted in internal combustion units with a rated 

heat capacity larger than 1 mmBtu/hr or 130 horsepower, by fuel type. 

W-40 873 

X 98.246(a)(4) Monthly volume values (used in Equations X-1 to X-3) - Volume of gaseous feedstock I 

introduced in month "n" ((Fgf)n) X-1 

64 

X 98.246(a)(4) Monthly volume values (used in Equations X-1 to X-3) - Volume of gaseous product i 

produced in month "n" ((Pgf)n) X-1 

64 

X 98.246(a)(4) Monthly volume values (used in Equations X-1 to X-3) - Volume of liquid feedstock i for 

month "n" ((Flf)n) X-2 

64 

X 98.246(a)(4) Monthly volume values (used in Equations X-1 to X-3) - Volume of liquid product i for 

month "n" ((Plp)n) X-2 

64 

X 98.246(a)(4) Monthly mass values (used in Equations X-1 to X-3) - Mass of liquid feedstock i for month 

"n" ((Flf)n) X-2 

64 

X 98.246(a)(4) Monthly mass values (used in Equations X-1 to X-3) - Mass of liquid product i for month "n" 

((Plp)n) X-2 

64 

X 98.246(a)(4) Monthly mass values (used in Equations X-1 to X-3) - Mass of solid feedstock I for month 

"n" ((Fsf)n) X-3 

64 

X 98.246(a)(4) Monthly mass values (used in Equations X-1 to X-3) - Mass of solid product i for month "n" 

((Psp)n) X-3 

64 

X 98.246(a)(4) Monthly carbon content values (used in Equations X-1 to X-3) - Average carbon content of 

the gaseous feedstock I for month "n" ((CCgf)n) X-1 

64 

X 98.246(a)(4) Monthly carbon content values (used in Equations X-1 to X-3) - Average carbon content of 

the gaseous product i for month "n" ((CCgp)n) X-1 

64 

X 98.246(a)(4) Monthly carbon content values (used in Equations X-1 to X-3) - Average carbon content of 

the liquid feedstock i for month "n" ((CClf)n) X-2 

64 

X 98.246(a)(4) Monthly carbon content values (used in Equations X-1 to X-3) - Average carbon content of 

the liquid product i for month "n" ((CClp)n) X-2 

64 

X 98.246(a)(4) Monthly carbon content values (used in Equations X-1 to X-3) - Average carbon content of 

the solid feedstock i for month "n" ((CClf)n) X-3 

64 

X 98.246(a)(4) Monthly carbon content values (used in Equations X-1 to X-3) - Average carbon content of 

the solid product i for month "n" ((CClp)n) X-3 

64 

X 98.246(a)(4) Molecular weights for gaseous feedstocks (used in Equation X-1) X-1 64 

X 98.246(a)(4) Molecular weights for gaseous products (used in Equation X-1) X-1 64 

X 98.246(a)(4) Indicate whether you used the alternative to sampling and analysis X-1 64 

X 98.246(a)(4) Indicate whether you used the alternative to sampling and analysis X-2 64 

X 98.246(a)(4) Indicate whether you used the alternative to sampling and analysis X-3 64 

X 98.246(b)(5)(iii) Quantity of each type of fuel used in equation C-8 in 98.33(c) for each stationary combustion 

unit or group of units (as applicable) during the reporting year, expressed in short tons for 

solid fuels, gallons for liquid fuels, and scf for gaseous fuels. 

C-8 

64 

X 98.246(b)(5)(iv) The HHV (either default or annual average from measured data) used in equation C-8 in 

98.33(C) for each stationary combustion unit or group of units (as applicable). C-8 

64 

Y 98.256(e)(6) 

If using Equation Y-1a: report the molar volume conversion factor (in scf/g-mole) for each 

flare. Y-1a 

145 

Y 98.256(e)(7) If using Equation Y-1b: report molar volume conversion factor for each flare. Y-1b 145 

Y 98.256(e)(7)(ii) 

If using Equation Y-1b: report the carbon mole number of each carbon containing compound 

other than CO2 in the flare gas stream for each flare. Y-1b 

145 

Y 98.256(e)(9) Annual volume of flare gas combusted during normal operations Y-3 145 

Y 98.256(e)(9) Annual average higher heating value of the flare gas Y-3 145 

Y 98.256(e)(9) Volume of gas flared during SSM event Y-3 145 

Y 98.256(e)(9) Average molecular weight Y-3 145 

Y 98.256(e)(9) Carbon content of the flare gas Y-3 145 

Y 98.256(e)(9) If using Equation Y-3: report the molar volume conversion factor for each flare. Y-3 145 

Y 98.256(e)(10) Fraction of carbon in the flare gas contributed by methane (used in Equation Y-4) Y-4 145 

Y 98.256(f)(7) If using Equation Y-6: report the molar volume conversion factor. Y-6 145 

Y 98.256(f)(10) Coke burn-off factor Y-8 145 

Y 98.256(f)(10) Annual throughput of unit Y-8 145 

Y 98.256(f)(10) Average carbon content of coke Y-8 145 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

54 

Subpart 

Citation Data Element 

Data Element is used as 

Input to Equation . . . Number of Facilitiesa 

Y 98.256(f)(11) 

Units of measure for the unit-specific CH4 emission factor Used in method specified 

in 98.253(c)(4) 

145 

Y 98.256(f)(11) 

Activity data for calculating emissions Used in method specified 

in 98.255(c)(4) 

145 

Y 98.256(f)(11) 

If you use a unit-specific emission factor for CH4: report the unit-specific emission factor for 

CH4 each catalytic cracking units, traditional fluid coking units, and catalytic reforming units Used in method specified 

in 98.253(c)(4) 

145 

Y 98.256(f)(12) 

If a unit-specific emission factor for N2O was used: report the unit-specific emission factor 

for N2O each catalytic cracking units, traditional fluid coking units, and catalytic reforming 

units Used in method specified 

in 98.253(c)(5) 

145 

Y 98.256(f)(12) 

Units of measure for the unit-specific N2O emission factor Used in method specified 

in 98.253(c)(5) 

145 

Y 98.256(f)(12) 

Activity data for calculating emissions Used in method specified 

in 98.255(c)(5) 

145 

Y 98.256(f)(13) Average carbon content of coke Y-11 145 

Y 98.256(h)(4) If Equation Y-12 is used: Annual volumetric flow to the sulfur recovery plant Y-12 145 

Y 98.256(h)(4) If Equation Y-12 is used: Annual average mole fraction of carbon in the sour gas Y-12 145 

Y 98.256(h)(4) If Equation Y-12 is used: report the molar volume conversion factor Y-12 145 

Y 98.256(h)(5) 

Value of the correction Used in method specified 

in 98.253(h)(3) 

145 

Y 98.256(h)(5) 

Annual volume of recycled tail gas (if used to calculate recycling correction factor) Used in method specified 

in 98.253(h)(3) 

145 

Y 98.256(h)(5) 

Annual average mole fraction of carbon in the tail gas (if used to calculate recycling 

correction factor) Used in method specified 

in 98.253(h)(3) 

145 

Y 98.256(i)(5) 

If you use Eq. Y-13, report the annual mass of green coke fed to the for each coke calcining 

unit Y-13 

145 

Y 98.256(i)(5) 

If you use Eq. Y-13, report the carbon content of green coke fed to the for each coke 

calcining unit Y-13 

145 

Y 98.256(i)(5) 

If you use Eq. Y-13, report the annual mass of marketable coke produced for each coke 

calcining unit Y-13 

145 

Y 98.256(i)(5) 

If you use Eq. Y-13, report the carbon content of marketable coke produced for each coke 

calcining unit Y-13 

145 

Y 98.256(i)(5) 

If Equation Y-13 used for coke calcining units: report the annual mass of coke dust removed 

from the process through collected in dust collection systems Y-13 

145 

Y 98.256(i)(7) 

For coke calcining: The unit-specific CH4 emission factor Used in method specified 

in 98.253(c)(4) 

145 

Y 98.256(i)(7) 

For coke calcining: Units of measure for the unit-specific CH4 emission factor Used in method specified 

in 98.253(c)(4) 

145 

Y 98.256(i)(7) 

For coke calcining: Activity data for calculating emissions Used in method specified 

in 98.253(c)(4) 

145 

Y 98.256(i)(8) 

For coke calcining: If a unit specific emission factor was used for the N2O factor: report the 

units of measure for the unit-specific factor Used in method specified 

in 98.253(c)(5) 

145 

Y 98.256(i)(8) 

For coke calcining: If a unit specific emission factor was used for the N2O factor: report the 

activity data used for calculating emissions Used in method specified 

in 98.253(c)(5) 

145 

Y 98.256(i)(8) 

For coke calcining: If a unit-specific emission factor for N2O was used, report the sitespecific emission factor Used in method specified 

in 98.253(c)(5) 

145 

Y 98.256(j)(2) Quantity of asphalt blown for each for each asphalt blowing unit Y-14 145 

Y 98.256(j)(2) Quantity of asphalt blown for each for each asphalt blowing unit Y-15 145 

Y 98.256(j)(2) Quantity of asphalt blown for each for each asphalt blowing unit Y-16a 145 

Y 98.256(j)(2) Quantity of asphalt blown for each for each asphalt blowing unit Y-16b 145 

Y 98.256(j)(2) Quantity of asphalt blown for each for each asphalt blowing unit Y-17 145 

Y 98.256(j)(5) CO2 emission factor for each asphalt blowing unit Y-14 145 

Y 98.256(j)(6) CH4 emission factor for each asphalt blowing unit Y-15 145 

Y 98.256(j)(7) If Equation Y-16 is used: report the carbon emission factor Y-16a 145 

Y 98.256(j)(8) If Equation Y-16b is used: report the CO2 emission factor used Y-16b 145 

Y 98.256(j)(8) If Equation Y-16b is used: report the carbon emission factor Y-16b 145 

Y 98.256(j)(9) If you use Eq. Y-17: CH4 emission factor Y-17 145 

Y 98.256(k)(3) For delayed coking units: Dimensions of coke drum or vessel Y-18 145 

Y 98.256(k)(3) 

For delayed coking units: Typical gauge pressure of the coking drum when first vented to the 

atmosphere Y-18 

145 

Y 98.256(k)(3) For delayed coking units: Typical void fraction of coke drum or vessel Y-18 145 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

55 

Subpart 

Citation Data Element 

Data Element is used as 

Input to Equation . . . Number of Facilitiesa 

Y 98.256(k)(3) 

For delayed coking units: Annual number of coke-cutting cycles of coke drum or vessel 

Y-18 

145 

Y 98.256(k)(3) 

For delayed coking units: report the molar volume conversion factor for each coke drum or 

vessel. Y-18 

145 

Y 98.256(k)(4) For delayed coking units: Height and diameter of the coke drums Y-18 145 

Y 98.256(k)(4) 

For delayed coking units: Cumulative number of vessel openings for all delayed coking 

drums in the set Y-18 

145 

Y 98.256(k)(4) For delayed coking units: Typical venting pressure Y-18 145 

Y 98.256(k)(4) For delayed coking units: Void fraction Y-18 145 

Y 98.256(k)(4) For delayed coking units: Mole fraction of methane in coking gas Y-18 145 

Y 98.256(l)(5) For each process vent: Molar volume conversion factor Y-19 145 

Y 98.256(m)(3) 

Uncontrolled blowdown systems reporting under 98.253 (k): Total quantity of crude oil plus 

the quantity of intermediate products received from off-site that are processed at the facility 

in the reporting year Y-20 

145 

Y 98.256(m)(3) 

Uncontrolled blowdown systems reporting under 98.253 (k): CH4 emission factor used 

Y-20 

145 

Y 98.256(m)(3) 

Uncontrolled blowdown systems reporting under 98.253 (k): Molar volume conversion factor 

Y-20 

145 

Y 98.256(n)(3) 

For equipment leaks: Number of each type of emission source listed in Equation Y-21 (if 

using Eq. Y-21) Y-21 

145 

Y 98.256(n)(3) 

For equipment leaks: Number of each type of emission source listed in Equation Y-21 (if not 

using Eq. Y-21) Using method specified 

in 98.253(l)(1) 

145 

Y 98.256(o)(2)(ii) 

Total quantity of crude oil plus the quantity of intermediate products received from off-site 

that are processed at the facility in the reporting year Y-22 

145 

Y 98.256(o)(4)(ii) 

For storage tanks that process unstabilized crude oil: Quantity of unstabilized crude oil 

received during the calendar year Y-23 

145 

Y 98.256(o)(4)(iii) 

For storage tanks that process unstabilized crude oil: Average pressure differential 

Y-23 

145 

Y 98.256(o)(4)(iv) 

For storage tanks that process unstabilized crude oil: Molar volume conversion factor 

Y-23 

145 

Y 98.256(o)(4)(v) 

For storage tanks that process unstabilized crude oil: Average Mole fraction of CH4 in vent 

gas from the unstabilized crude oil storage tanks Y-23 

145 

Y 98.256(o)(4)(vi) 

If you did not use Equation Y-23: report the tank-specific methane composition data used to 

estimate cumulative CH4 emissions for storage tanks used to process unstabilized cruide oil. Used in methods 

specified in 98.253(m)(2) 

145 

Y 98.256(o)(4)(vi) 

If you did not use Equation Y-23: report the gas generation rate data used to estimate 

cumulative CH4 emissions for storage tanks used to process unstabilized cruide oil. 

Used in methods 

specified in 98.253(m)(2) 

145 

Y 98.256(o)(6) Quantity of unstabilized crude oil received during the calendar year Y-23 145 

Y 98.256(o)(6) Average pressure differential Y-23 145 

Y 98.256(o)(6) Mole fraction of CH4 in vent gas from the unstabilized crude oil storage tank Y-23 145 

Y 98.256(o)(7) 

Tank-specific methane composition data Used in methods 

specified in 98.253(m)(2) 

145 

Y 98.256(o)(7) 

Gas generation rate data Used in methods 

specified in 98.253(m)(2) 

145 

Y 98.256(p)(2) 

For loading operations: Quantity of materials loaded by vessel type that have an equilibrium 

vapor-phase concentration of CH4 of 0.5 volume percent or greater 

Used in methods 

specified in AP-42, 

Section 5.2 [referenced 

by 98.253(n)] 

145 

Z 98.266(f)(5) Monthly inorganic carbon content of phosphate rock for each wet-process phosphoric acid 

process line for which Equation Z-1a is used (percent by weight, expessed as decimal 

fraction) (No CEMS) 

Z-1a 

13 

Z 98.266(f)(5) Monthly CO2 (ton CO2/ton of phosphate rock) for which Equation Z-1b is used (No CEMS) Z-1b 13 

Z 98.266(f)(6) Monthly mass of phosphate rock consumed by origin in production Z-1a 13 

Z 98.266(f)(6) Monthly mass of phosphate rock consumed by origin in production Z-1b 13 

AA 98.276(b) Annual quantities of fossil fuels used in chemical recovery furnaces C-1 110 

AA 98.276(b) Annual quantities of fossil fuels used in chemical recovery furnaces C-1a 110 

AA 98.276(b) Annual quantities of fossil fuels used in chemical recovery furnaces C-1b 110 

AA 98.276(b) Annual quantities of fossil fuels used in chemical recovery furnaces C-2a 110 

AA 98.276(b) Annual quantities of fossil fuels used in chemical recovery furnaces C-3 110 

AA 98.276(b) Annual quantities of fossil fuels used in chemical recovery combustion units C-4 110 

AA 98.276(b) Annual quantities of fossil fuels used in chemical recovery combustion units C-5 110 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

56 

Subpart 

Citation Data Element 

Data Element is used as 

Input to Equation . . . Number of Facilitiesa 

AA 98.276(b) Annual quantities of fossil fuels used in chemical recovery combustion units C-8 110 

AA 98.276(b) Annual quantities of fossil fuels used in chemical recovery combustion units C-8a 110 

AA 98.276(b) Annual quantities of fossil fuels used in chemical recovery combustion units C-8b 110 

AA 98.276(b) Annual quantities of fossil fuels used in chemical recovery combustion units C-9a 110 

AA 98.276(c) Annual mass of the spent liquor solids combusted AA-1 110 

AA 98.276(c) Annual mass of the spent liquor solids combusted AA-2 110 

AA 98.276(d) High heat value (HHV) of the spent liquor solids used in Equation AA-1 AA-1 110 

AA 98.276(e) Default or site specific emission factor for CO2 used in equation AA-1 AA-1 110 

AA 98.276(e) Default or site specific emission factor for CH4 used in equation AA-1 AA-1 110 

AA 98.276(e) Default or site specific emission factor for N2O used in equation AA-1 AA-1 110 

AA 98.276(f) Carbon content of the spent liquor solids used in Equation AA-2 AA-2 110 

AA 98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns C-1 110 

AA 98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns C-1a 110 

AA 98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns C-1b 110 

AA 98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns C-2a 110 

AA 98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns C-3 110 

AA 98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns C-4 110 

AA 98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns C-5 110 

AA 98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns C-8 110 

AA 98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns C-8a 110 

AA 98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns C-8b 110 

AA 98.276(g) Annual quantities of fossil fuels used in pulp mill lime kilns C-9a 110 

AA 98.276(h) Make-up quantity of CaCO3 used for the reporting year used in Equation AA-3 AA-3 110 

AA 98.276(i) Make-up quantity of Na2CO3 used for the reporting year used in Equation AA-3 AA-3 110 

BB 98.286(b)(1) Monthly consumption of petroleum coke (No CEMS) BB-2 1 

BB 98.286(b)(4) Carbon content factor of petroleum coke from the supplier or as measured by the applicable 

method BB-1 

1 

BB 98.286(b)(6) CO2 emissions factor for for each month BB-2 1 

CC 98.296(b)(5) Monthly consumption of trona or liquid alkaline feedstock for each manufacturing line (No 

CEMS) (for facilities using Equation CC-1) CC-1 

4 

CC 98.296(b)(6) Monthly production of soda ash for each manufacuturing line (tons) (for facilities using 

Equation CC-2) CC-2 

4 

CC 98.296(b)(7) Inorganic carbon content factor of trona or soda ash CC-1 4 

CC 98.296(b)(7) Inorganic carbon content factor of trona or soda ash CC-2 4 

CC 98.296(b)(10)(i) Stack gas volumetric flow rate during performance test (dscfm) for each manufacturing line 

or stack. CC-3 

4 

CC 98.296(b)(10)(ii) Hourly CO2 concentration during performance test (percent CO2) for each manufacturing line 

or stack CC-3 

4 

CC 98.296(b)(10)(iii) CO2 emission factor of process vent flow from mine water for each manufacturing line or 

stack CC-5 

4 

CC 98.296(b)(10)(iv) CO2 emission mass emission rate during performance test (metric tons/hour) for each 

manufacturing line or stack. CC-4 

4 

CC 98.296(b)(10)(v) Average process vent flow from mine water stripper/evaporator during performance test for 

each manufacturing line or stack CC-4 

4 

CC 98.296(b)(10)(vi) Annual process vent flow rate from mine stripper/evaporator for each manufacturing line or 

stack CC-5 

4 

EE 98.316(b)(6) Monthly calcined petroleum coke consumption for each production line (No CEMS) EE-2 7 

EE 98.316(b)(9) 

Monthly carbon content factor of petroleum coke (percent by weight expressed as a decimal 

fraction) (No CEMS) 

EE-2 

7 

GG 98.336(b)(6) 

Annual mass of each carbon-containing input material charged to each kiln or furnace (No 

CEMS) - Mass of zinc bearing material 

GG-1 

6 

GG 98.336(b)(6) 

Annual mass of each carbon-containing input material charged to each kiln or furnace (No 

CEMS) - Annual mass of flux materials (e.g., limestone, dolomite) charged to kiln or furnace 

“k” (tons) 

GG-1 

6 

GG 98.336(b)(6) 

Annual mass of each carbon-containing input material charged to each kiln or furnace (No 

CEMS) - Annual mass of carbon electrode consumed in furnace “k” 

GG-1 

6 

GG 98.336(b)(6) 

Annual mass of each carbon-containing input material charged to each kiln or furnace (No 

CEMS) - Annual mass of carbon electrode consumed in furnace “k” 

GG-1 

6 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

57 

Subpart 

Citation Data Element 

Data Element is used as 

Input to Equation . . . Number of Facilitiesa 

GG 98.336(b)(7) 

Carbon content of carbon-containing input materials charged to kilns or furnace (including 

zinc bearing material, flux materials, and other carbonaceous materials) from the annual 

carbon analysis or from information provided by the material supplier) for each kiln or 

furnace (percent by weight, expressed as a decimal fraction) (No CEMS) - zinc bearing 

material 

GG-1 

6 

GG 98.336(b)(7) 

Carbon content of carbon-containing input materials charged to kilns or furnace (including 

zinc bearing material, flux materials, and other carbonaceous materials) from the annual 

carbon analysis or from information provided by the material supplier) for each kiln or 

furnace (percent by weight, expressed as a decimal fraction) (No CEMS) - flux materials 

GG-1 

6 

GG 98.336(b)(7) 

Carbon content of carbon-containing input materials charged to kilns or furnace (including 

zinc bearing material, flux materials, and other carbonaceous materials) from the annual 

carbon analysis or from information provided by the material supplier) for each kiln or 

furnace (percent by weight, expressed as a decimal fraction) (No CEMS) - other 

carbonaceous materials 

GG-1 

6 

GG 98.336(b)(10) 

Carbon content of the carbon electrodes used in each furnace from the annual carbon analysis 

or from information provided by the material supplier) (percent by weight, expressed as a 

decimal fraction) (No CEMS) 

GG-1 

6 

II 98.356(d)(2) Cumulative volumetric biogas flow for each week that biogas is collected for destruction. (if 

using weekly sampling) II-4 

151 

II 98.356(d)(3) Weekly average CH4 concentration for each week that biogas is collected for 

destruction. (if using weekly sampling) II-4 

151 

II 98.356(d)(4) Weekly average temperature at which flow is measured for biogas collected for destruction 

(if using weekly sampling) II-4 

151 

II 98.356(d)(5) Weekly average moisture content for each week at which 

flow is measured for biogas collected for destruction (if using weekly sampling) II-4 

151 

II 98.356(d)(6) Weekly average pressure for each week at which flow is measured for biogas collected for 

destruction (if using weekly sampling) II-4 

151 

TT 98.466(c)(3)(i) Total number of years (N) for which disposal and production data are both available. TT-2 173 

TT 98.466(c)(3)(ii) The waste disposal quantity and production quantity for each year used in Equation TT–2 of 

this subpart to calculate the average waste disposal factor (WDF). 

TT-2 173 

TT 98.466(c)(3)(iii) Average waste disposal factor (WDF) calculated for the waste stream. TT-2 173 

a

 Counts are based on RY2011.
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

58 

Appendix B 

Detailed Summary of Publicly Available Data that are the Same as the “inputs to equations” data 

elements 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

59 

Table B-1. Public Availability of ”Inputs to Equations” for Subpart C 

Source Description of Sources Reviewed Results 

Permits 10 Title V permits (1% of identified sources) 

from 10 states1

No data elements were identified as 

being publicly available 

NEI/Federal 

databases 

Subpart C is referenced in 26 other industrial 

process subparts2

 that have data elements 

deferred to 2015. For each subpart, the 

following items were searched: 

 2005 and 2008 NEI based on NAICS 

code and combustion SCCs 

 CAMD, eGRID, TRI, DOE/EIA, and 

OECA ECHO databases based on 

registered GHGRP facilities3

Table B-1A summarizes the results from 

searching the 2005 and 2008 NEI for 

each subpart 

Table B-1B summarizes the results from 

searching the other federal databases for 

each subpart 

Table B-1D summarizes the results from 

reviewing the EIA forms. 

State/Regional 

databases 

Subpart C is referenced in 22 other subparts 

that have data elements deferred to 2015. For 

each subpart, the following items were 

searched: 

 online inventory databases for The 

Climate Registry, Western Climate 

Initiative, Regional Greenhouse Gas 

Initiative 

 websites of 18 states4 that have or were 

considering mandatory reporting 

programs 

No data elements were identified as 

being publicly available 

Rule dockets 

(MACT/NSPS) 

The following databases were searched to 

support the NESHAP for Industrial, 

Commercial, and Institutional Boiler Area 

Sources (Docket# OAR-2006-0790) and the 

NESHAP for Industrial, Commercial, and 

Institutional Boilers and Process Heaters - 

Major Source (Docket# OAR-2002-0058): 

 emissions_database_boilers_heatersv6.mdb

 survey_database_2008_resultsv2.mdb 

Table B-1C summarizes the results from 

searching these dockets for each subpart 

Journals Power Engineering Magazine, Powergrid 

International. 

No data elements were identified as 

being publicly available 1

 AK, AR, CA, CO, IN, MO, NC, NY, RI, VA 

2

 Subparts C, E, F, G, H, K, L, N, O, P, Q, R, S, U, V, W, X, Y, Z, AA, BB, CC, EE, GG, II, TT 3

 CAMD = Clean air markets division acid rain database; eGRID = Emissions & generation resource integrated database containing 

environmental characteristics of electrical power generated in the U.S.; DOE/EIA = Department of Energy energy information agency database; 

TRI = Toxic release inventory database; OECA ECHO = office of enforcement and compliance assurance enforcement and compliance history 

online database. 

4

 CA, CT, CO, DE, FL, HI, IA, MA, MD, ME, NC, NJ, NM, NV, OR, WA, WI, WV 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

60 

Table B-1A. Number of Facilities in the 2008 NEI that Report Combustion Data Identical to Subpart C 

Equations” (Summarized By Subpart) 

Data element with 

citation

Subpart

E F G H K L N O P Q R S U V W X Y Z AA BB CC EE 

Total quantity of each type of fuel combusted during the reporting year [98.36(e)(2)(i), eq. C-1, C-1a, C-1b, C8] 

0 1 3 7 2 1 7 1 5 19 0 6 2 0 a 1 7 4 27 0 0 2 

HHV for each fuel combusted, annual basis [98.36(e)(2)(iv)(F), eq. C-8] 

0 0 1 0 1 0 8 0 2 8 0 0 1 7 a 0 4 3 8 0 0 0 

Blank cells denote the data element is not publicly available. No other data elements were identical to the publicly available information. aAn analysis of exact facility matches between the GHGRP and NEI was not completed due to the large number of facilities in this subpart. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

61 

Table B-1B. Number of Facilities In Other Federal Databases (DOE, CAMD, eGRID)(a) That Report Com

Identical to Subpart C ”Inputs to Equations” (Summarized By Subpart) 

Data element with citation Subpart E F G H K L N O P Q R S U V X Y Z 

Estimate of the heat input from each type

of fuel [98.36(b)(9)(iii), eq. C‐10;

98.36(c)(2)(ix), eq. C‐10]

 3 1 3 3 11 2 25 58 

Total quantity of each type of fuel

combusted during the reporting year

[98.36(e)(2)(i), eq. C‐1, C‐1a, C‐1b]

 6 1 3 3 11 2 25 54 

Total quantity of each type of fuel

combusted during each month of the

reporting year [98.36(e)(2)(ii)(A), eq. C‐2b;

98.36(e)(2)(iv)(A), eq. C‐3, C‐4, C‐5, C‐8, C‐8a, C‐8b, C‐9a, C‐13]

 6 1 3 3 11 2 25 54 

Total quantity of fossil fuel combusted for each fuel combusted at units that combust both fossil fuel and biomass, annual basis [98.36(e)(2)(ix)(F), eq. C‐13]

 3 1 3 3 9 1 23 51 

Blank cells denote the data element is not publicly available. No other data elements were identical to the publicly available information.  (a) DOE = DOE Energy information administration database; CAMD = clean air markets division reports for units subject to the acid rain program; eGR

Integrated Database containing environmental characteristics of electrical power generated in the United States. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

62 

Table B-1C. Number of Facilities In The Boiler Rule Development Dockets(c) That Report Combustion Da

to Subpart C ”Inputs to Equations” (Summarized By Subpart) 

Data element with citation 

Subpart (a)

F, K, Q, R,

GG

(331-primary 

metals 3-digit 

NAICS) 

H, N, S 

(327-nonmetallic 

minerals 3-digit 

NAICS)

E, G, L, O, P, V, X,

Z, BB, CC, EE

(325‐chemical

manufacturing 3‐digit

NAICS)

Y AA

HHV for each fuel combusted, annual basis [98.36(e)(2)(iv)(F), eq. C-8] 10(b) 11(b) 88(b) 21 121Total quantity (i.e., pounds) of steam produced from MSW or solid fuel combustion during each month of the reporting year [98.36(e)(2)(ii)(D), eq. C-2c] 

24

HHV for each fuel combusted at units that combust both fossil fuel and biomass, annual basis [98.36(e)(2)(ix)(E), eq. C-13] 

 2(b) 1(b) 51

Other data elements (d)Blank cells denote the data element is not publicly available. No other data elements were identical to the publicly available information. 

(a) The NAICS codes were used to align facilities in the boiler MACT database to part 98 subparts. Only three-digit NAICS codes were provided instead of the full NAICS codes; therefore, only general categories are known and it is not possible to determine if a data element is specifically available for a single subpart (other than for subparts Y and AA). (b) Facilities may have reported HHV, data element is available for some subparts that are part of general 3-digit NAICS in Boiler database.  (c) Dockets reviewed were the Industrial, Commercial, and Institutional Boiler Area Sources NESHAP (Docket# OAR-2006-0790) and the NESHAP 

for Industrial, Commercial, and Institutional Boilers and Process Heaters - Major Source (Docket# OAR-2002-0058): (d) The following data elements are not publicly available in any subparts: 

 Ratio of the maximum rated heat input capacity to the design rated steam output capacity of the unit [98.36(e)(2)(ii)(D), eq. C-2c] 

 The carbon content used in the emission calculations (including both valid and substitute data values). For each calendar month of the 

reporting year in which carbon content and, if applicable, molecular weight determination is required, report a value of each parameter 

[98.36(e)(2)(iv)(C), eq. C-3, C-4, C-5] 

 Gas molecular weight values used in the emission calculations (including both valid and substitute data values). For each calendar month of 

the reporting year in which carbon content and, if applicable, molecular weight determination is required, report a value of each parameter. I

multiple values of a parameter are obtained in a given month, report the arithmetic average value for the month [98.36(e)(2)(iv)(C), eq. C-5] 

 For units that combust both fossil fuel and biomass, when biogenic CO2 is determined according to §98.33(e)(2), report the carbon-based Ffactor [98.36(e)(2)(ix)(D), eq. C-13] 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

63 

Table B-1D. Summary of Information Reported and Publicly Available in EIA Forms for Electric Genera

Subpart Citation Data Element 

Data Element is 

used as Input to 

Equation . . . 

Required to be Reported (R) in EIA Form for Facility (F), Unit (U), or Aggregated Units (A)1

C 98.36(b)(9)(iii) Estimate of the heat input from each type of fuel listed in Table C-2 that was combusted in the 

unit during the report year C-10 

2 

C 98.36(c)(2)(ix) The flue gases from two or more stationary fuel combustion units at a facility are combined 

together and discharged through a common stack or duct before exiting to the atmosphere and if CEMS are used to continuously monitor CO2 mass emissions at the common stack or duct 

according to the Tier 4 Calculation Methodology, you may report the combined emissions from the units sharing the common stack or duct, in lieu of separately reporting the GHG emissions from the individual units. This monitoring and reporting alternative may also be used when process off-gases or a mixture of combustion products and process gases are combined together in a common stack or duct before exiting to the atmosphere. An estimate of the heat input from each type of fuel listed in Table C-2 combusted during the reporting year. 

C-10 

C 98.36(e)(2)(i) Total quantity of each type of fuel combusted in each unit or group of aggregated units (as 

applicable) during the reporting year, in short tons for solid fuels, gallons for liquid fuels and standard cubic feet for gaseous fuels, or, if applicable, therms or mmBtu for natural gas. 

C-1 

2 

C 98.36(e)(2)(i) Total quantity of each type of fuel combusted in each unit or group of aggregated units (as 

applicable) during the reporting year, in short tons for solid fuels, gallons for liquid fuels and standard cubic feet for gaseous fuels, or, if applicable, therms or mmBtu for natural gas. 

C-1a 

2 

C 98.36(e)(2)(i) Total quantity of each type of fuel combusted in each unit or group of aggregated units (as 

applicable) during the reporting year, in short tons for solid fuels, gallons for liquid fuels and standard cubic feet for gaseous fuels, or, if applicable, therms or mmBtu for natural gas. 

C-1b 

2 

C 98.36(e)(2)(i) Total quantity of each type of fuel combusted in each unit or group of aggregated units (as 

applicable) during the reporting year, in short tons for solid fuels, gallons for liquid fuels and standard cubic feet for gaseous fuels, or, if applicable, therms or mmBtu for natural gas. 

C-8 

2 

C 98.36(e)(2)(ii)(A) For Tier 2: Total quantity of each type of fuel combusted in the unit or group of aggregated units 

(as applicable) during each month of the reporting year. Express the quantity of each fuel combusted during the measurement period in short tons for solid fuels, gallons for liquid fuels, and scf for gaseous fuels. 

C-2b 

F, U, A 

C 98.36(e)(2)(ii)(C) High heat values used in the CO2 emissions calculations for each fuel combusted during the 

reporting year. Report a HHV value for each calendar month in which HHV determination is required. If multiple values are obtained in a given month, report the arithmetic average value for the month. 

C-2b 

F, U, A 

C 98.36(e)(2)(ii)(D) If Eq. C-2c is used: Total quantity (i.e., pounds) of steam produced from MSW or solid fuel 

combustion during each month of the reporting year, C-2c 

C 98.36(e)(2)(ii)(D) If Eq. C-2c is used: Ratio of the maximum rate heat input capacity to the design rated steam 

output capacity of the unit C-2c 

C 98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as applicable) during each 

month of the reporting year (Fuel) C-3 F, U, A 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

64 

Subpart Citation Data Element 

Data Element is 

used as Input to 

Equation . . . 

Required to be Reported (R) in EIA Form for Facility (F), Unit (U), or Aggregated Units (A)1

C 98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as applicable) during each 

month of the reporting year (Fuel) C-4 F,U, A 

C 98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as applicable) during each 

month of the reporting year (Fuel) C-5 F, U, A 

C 98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as applicable) during each 

month of the reporting year (Fuel) C-8 F, U, A 

C 98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as applicable) during each 

month of the reporting year (Fuel) C-8a F, U, A 

C 98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as applicable) during each 

month of the reporting year (Fuel) C-8b F, U, A 

C 98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as applicable) during each 

month of the reporting year (Fuel) C-13 F, U, A 

C 98.36(e)(2)(iv)(C) The carbon content used in the emission calculations (including both valid and substitute data 

values). For each calendar month of the reporting year in which carbon content and, if applicable, 

molecular weight determination is required, report a value of each parameter. If multiple values of a parameter are obtained in a given month, report the arithmetic average value for the month. (CC) 

C-3 

C 98.36(e)(2)(iv)(C) The carbon content used in the emission calculations (including both valid and substitute data 

values). For each calendar month of the reporting year in which carbon content and, if applicable, 

molecular weight determination is required, report a value of each parameter. If multiple values of a parameter are obtained in a given month, report the arithmetic average value for the month. (CC) 

C-4 

C 98.36(e)(2)(iv)(C) The carbon content used in the emission calculations (including both valid and substitute data 

values). For each calendar month of the reporting year in which carbon content and, if applicable, 

molecular weight determination is required, report a value of each parameter. If multiple values of a parameter are obtained in a given month, report the arithmetic average value for the month. (CC) 

C-5 

C 98.36(e)(2)(iv)(C) Gas molecular weight values used in the emission calculations (including both valid and substitute 

data values). For each calendar month of the reporting year in which carbon content and, if applicable, molecular weight determination is required, report a value of each parameter. If multiple values of a parameter are obtained in a given month, report the arithmetic average value for the month. 

C-5 

C 98.36(e)(2)(iv)(F) The annual average HHV, when measured HHV data, rather than a default HHV from Table C-1 

of this subpart, are used to calculate CH4 and N2O emissions for a Tier 3 unit, in accordance with 

§98.33(c)(1). 

C-8 

2 

C 98.36(e)(2)(ix)(D) For units that combust both fossil fuel and biomass, when biogenic CO2 is determined according 

to §98.33(e)(2), report the carbon-based F-factor used in Equation C-13 of this subpart C-13 

C 98.36(e)(2)(ix)(E) For units that combust both fossil fuel and biomass, when biogenic CO2 is determined according 

to §98.33(e)(2), report the annual average HHV value used in Equation C-13 of this subpart C-13 

2 

C 98.36(e)(2)(ix)(F) For units that combust both fossil fuel and biomass, when biogenic CO2 is determined according 

to §98.33(e)(2), report the total quantity of fossil fuel combusted during the reporting year. C-13 

2 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

65 

1 Facility (F) wide data are required to be reported for plants with total nameplate capacity ≥ 50 MW; Unit (U) information is required 

boilers at plants with steam turbines (or combined cycle plants for supplementary firing of HRSG units) that have a nameplate capacity 

(A) unit information (e.g., report natural gas consumed by all combustion turbines as one value and diesel fuel consumed by all IC engigas turbines (including combined cycle plants), IC engines, and steam-electric plants < 10 MW. 

2 Information is required to be reported on a monthly basis and can be calculated for annual inputs. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

66 

Table B-2. Public Availability of ”Inputs to Equations” for Subpart E 

Source Description of Sources Reviewed Results 

Permits 2 Title V permits (based on 2 

affected facilities reporting to 

GHGRP) from 2 states1

No data elements were identified as 

being publicly available 

NEI/Federal 

databases 

NEI, CAMD, eGRID, TRI, 

DOE/EIA, and OECA ECHO 

databases 

No data elements were identified as 

being publicly available 

State/Regional 

databases 

Online inventory databases for 

The Climate Registry, Western 

Climate Initiative, Regional 

Greenhouse Gas Initiative, and 18 

states that have or were 

considering mandatory reporting 

programs

2

No data elements were identified as 

being publicly available 

Rule dockets 

(MACT/NSPS) 

No rule development docket 

identified 

Not applicable 

Journals No trade journals identified Not applicable 

1

 FL, TX 

2

 CA, CT, CO, DE, FL, HI, IA, MA, MD, ME, NC, NJ, NM, NV, OR, WA, WI, WV 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

67 

Table B-3. Public Availability of ”Inputs to Equations” for Subpart F 

Source Description of Sources Reviewed Results 

Permits 3 Title V permits (21% of 

identified sources) from 2 states1

No data elements were identified as 

being publicly available 

NEI/Federal 

databases 

NEI, CAMD, eGRID, TRI, 

DOE/EIA, and OECA ECHO 

databases 

3 of the 10 2011 GHGRP reporters report 

molten aluminum production to NEI. 

98.66(a), Eqns. F-5 and F-6. 

State/Regional 

databases 

Online inventory databases for 

The Climate Registry, Western 

Climate Initiative, Regional 

Greenhouse Gas Initiative, and 18 

states that have or were 

considering mandatory reporting 

programs

2

No data elements were identified as 

being publicly available 

Rule dockets 

(MACT/NSPS) 

Primary Aluminum Reduction 

Plants NESHAP 

 Section 114 responses 

No data elements were identified as 

being publicly available 

Journals Aluminum Today, 

Light Metal Age, Aluminum 

World, Journal of Alloys and 

Compounds 

No data elements were identified as 

being publicly available

1

 NY, OH 

2

 CA, CT, CO, DE, FL, HI, IA, MA, MD, ME, NC, NJ, NM, NV, OR, WA, WI, WV 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

68 

Table B-4. Public Availability of ”Inputs to Equations” for Subpart G 

Source Description of Sources Reviewed Results 

Permits 9 Title V permits (39% of 

identified sources) from 7 states1

No data elements were identified as 

being publicly available 

NEI/Federal 

databases 

NEI, CAMD, eGRID, TRI, 

DOE/EIA, and OECA ECHO 

databases 

No data elements were identified as 

being publicly available 

State/Regional 

databases 

Online inventory databases for 

The Climate Registry, Western 

Climate Initiative, Regional 

Greenhouse Gas Initiative, and 18 

states that have or were 

considering mandatory reporting 

programs

2

No data elements were identified as 

being publicly available 

Rule dockets 

(MACT/NSPS) 

No rule development docket 

identified 

Not applicable 

Journals No trade journals identified Not applicable 

1

 GA, IA, OH, OK, TX, VA, WY 

2

 CA, CT, CO, DE, FL, HI, IA, MA, MD, ME, NC, NJ, NM, NV, OR, WA, WI, WV
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

69 

Table B-5. Public Availability of ”Inputs to Equations” for Subpart H 

Source Description of Sources Reviewed Results 

Permits 11 Title V permits (10% of 

identified sources) from 10 states1

No data elements were identified as 

being publicly available 

NEI/Federal 

databases 

NEI, CAMD, eGRID, TRI, 

DOE/EIA, and OECA ECHO 

databases 

Annual consumption of each raw kiln 

feed or annual consumption of each raw 

material [98.86(b)(13), Eqn. H-5] 

reported for 21 facilities with kilns.3

 

State/Regional 

databases 

Online inventory databases for 

The Climate Registry, Western 

Climate Initiative, Regional 

Greenhouse Gas Initiative, and 18 

states that have or were 

considering mandatory reporting 

programs

2

No data elements were identified as 

being publicly available 

Rule dockets 

(MACT/NSPS) 

Portland Cement Manufacturing 

NESHAP 

 Section 114 responses from 9 

companies representing 37 

facilities 

 5 companies considered some 

information as CBI. The data 

elements considered CBI varied 

from company to company. In 

general, raw material 

information (e.g., info on 

individual constituents) was 

considered CBI. 

 Survey was not focused toward 

getting detailed clinker 

production data 

 Data are from one-time data 

collection/sampling 

1 data element reported is the same as 

inputs 

 19 facilities reported annual usage for 

each raw material [98.86(b)(13), eq. 

H-5] 

Journals Cement and Concrete Composites, 

World Cement, Cement Americas, 

Cement and Concrete Research, 

Global Cement 

No data elements were identified as 

being publicly available 

1

 AZ, CO, FL, GA, ID, IN, ME, MI, MO, OR 

2

 CA, CT, CO, DE, FL, HI, IA, MA, MD, ME, NC, NJ, NM, NV, OR, WA, WI, WV 

3

 Exact facility matches between NEI and 2011 GHGRP reporters were not assessed. The 21 facilities occur out of 707 facilities 

that meet the broader NAICS code search for the Subpart.
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

70 

Table B-6. Public Availability of ”Inputs to Equations” for Subpart K 

Source Description of Sources 

Reviewed 

Results 

Permits 1 Title V permit from Ohio No data elements were identified as being 

publicly available 

NEI/Federal 

databases 

NEI, CAMD, eGRID, TRI, 

DOE/EIA, and OECA 

ECHO databases 

No data elements were identified as being 

publicly available 

State/Regional 

databases 

Online inventory databases 

for The Climate Registry, 

Western Climate Initiative, 

Regional Greenhouse Gas 

Initiative, and 18 states that 

have or were considering 

mandatory reporting 

programs

1

No data elements were identified as being 

publicly available 

Rule dockets 

(MACT/NSPS) 

40 CFR part 63 subpart 

XXX, NESHAP from 

Ferroalloys Production: 

Ferromanganese and 

Silicomanganese 

 Section 114 responses 

from 2 plants (i.e., EPAHQ-OAR-2004-0375, 

EPA-HQ-OAR-2010-

0895) 

40 CFR part 63 subpart 

YYYYYY, NESHAP for 

Area Sources: Ferroalloys 

Production Facilities 

 Section 114 responses 

from 10 plants (Docket 

EPA-HQ-OAR-2008-

0154). 

Data are from one-time data 

collection/sampling 

Information reported (from 11 facilities) is 

the same as 2 data elements: 

 Annual mass of alloy product for each EAF 

98.116(b) (eq. K-1 and K-3) 

Journals Journal of Alloys and 

Compounds, American 

Metal Market (USA) 

No data elements were identified as being 

publicly available 

1

 CA, CT, CO, DE, FL, HI, IA, MA, MD, ME, NC, NJ, NM, NV, OR, WA, WI, WV
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

71 

Table B-7. Public Availability of ”Inputs to Equations” for Subpart L 

Source Description of Sources 

Reviewed 

Results 

Permits 4 Title V permits (21% of 

identified sources) from 3 

states1

No data elements were identified as being 

publicly available 

NEI/Federal 

databases 

NEI, CAMD, eGRID, TRI, 

DOE/EIA, and OECA 

ECHO databases 

No data elements were identified as being 

publicly available 

State/Regional 

databases 

Online inventory databases 

for The Climate Registry, 

Western Climate Initiative, 

Regional Greenhouse Gas 

Initiative, and 18 states that 

have or were considering 

mandatory reporting 

programs

2

No data elements were identified as being 

publicly available 

Rule dockets 

(MACT/NSPS) 

No rule development docket 

identified 

Not applicable 

Journals No trade journals identified Not applicable 

1

 AR, IL, NC. There are only 16 potential affected facilities. Facilities in MI, TX, and NY do not have Title V permits. The 

facilities in AL, MN, PA, KY, NJ, SC, and LA do not have permits available online.

2

 CA, CT, CO, DE, FL, HI, IA, MA, MD, ME, NC, NJ, NM, NV, OR, WA, WI, WV 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

72 

Table B-8. Public Availability of ”Inputs to Equations” for Subpart N 

Source Description of Sources Reviewed Results 

Permits 10 Title V permits (18% of 

identified sources) from 10 states1

No data elements were identified as 

being publicly available 

NEI/Federal 

databases 

NEI, CAMD, eGRID, TRI, 

DOE/EIA, and OECA ECHO 

databases 

No data elements were identified as 

being publicly available 

State/Regional 

databases 

Online inventory databases for 

The Climate Registry, Western 

Climate Initiative, Regional 

Greenhouse Gas Initiative, and 18 

states that have or were 

considering mandatory reporting 

programs

2

No data elements were identified as 

being publicly available 

Rule dockets 

(MACT/NSPS) 

Glass Manufacturing NESHAP 

(Area Sources) 

 Section 114 responses from 11 

respondents 

No data elements were identified as 

being publicly available 

Journals Glass and Ceramics, Glass Science 

and Technology 

No data elements were identified as 

being publicly available 

1

 AR, GA, IL, IN, MI, MO, NY, OH, OK, WI 

2

 CA, CT, CO, DE, FL, HI, IA, MA, MD, ME, NC, NJ, NM, NV, OR, WA, WI, WV
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

73 

Table B-9. Public Availability of ”Inputs to Equations” for Subpart O 

Source Description of Sources Reviewed Results 

Permits 1 Title V permit (of 4 identified 

sources) from 1 state (WV)1

No data elements were identified as 

being publicly available 

NEI/Federal 

databases 

NEI, CAMD, eGRID, TRI, 

DOE/EIA, and OECA ECHO 

databases 

No data elements were identified as 

being publicly available 

State/Regional 

databases 

Online inventory databases for 

The Climate Registry, Western 

Climate Initiative, Regional 

Greenhouse Gas Initiative, and 18 

states that have or were 

considering mandatory reporting 

programs

2

No data elements were identified as 

being publicly available 

Rule dockets 

(MACT/NSPS) 

No rule development docket 

identified 

Not applicable 

Journals No trade journals identified Not applicable 

1

 The remaining 3 facilities located in AI, KY, and LA do not have permits available online. 

2

 CA, CT, CO, DE, FL, HI, IA, MA, MD, ME, NC, NJ, NM, NV, OR, WA, WI, WV 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

74 

Table B-10. Public Availability of ”Inputs to Equations” for Subpart P 

Source Description of Sources Reviewed Results 

Permits 10 Title V permits from 3 states1 No data elements were identified as 

being publicly available 

NEI/Federal 

databases 

NEI, CAMD, eGRID, TRI, 

DOE/EIA, and OECA ECHO 

databases 

No data elements were identified as 

being publicly available. 

State/Regional 

databases 

Online inventory databases for 

The Climate Registry, Western 

Climate Initiative, Regional 

Greenhouse Gas Initiative, and 18 

states that have or were 

considering mandatory reporting 

programs

2

No data elements were identified as 

being publicly available 

Rule dockets 

(MACT/NSPS) 

No rule development docket 

identified 

Not applicable 

Journals Catalysis Today No data elements were identified as 

being publicly available 1

 CA, IN, TX 

2

 CA, CT, CO, DE, FL, HI, IA, MA, MD, ME, NC, NJ, NM, NV, OR, WA, WI, WV 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

75 

Table B-11. Public Availability of ”Inputs to Equations” for Subpart Q 

Source Description of Sources Reviewed Results 

Permits 10 Title V permits from 10 states1 No data elements were identified as 

being publicly available 

NEI/Federal 

databases 

NEI, CAMD, eGRID, TRI, 

DOE/EIA, and OECA ECHO 

databases 

No data elements from GHGRP facilities 

were identified as being publicly 

available.3

State/Regional 

databases 

Online inventory databases for 

The Climate Registry, Western 

Climate Initiative, Regional 

Greenhouse Gas Initiative, and 18 

states that have or were 

considering mandatory reporting 

programs2

No data elements were identified as 

being publicly available 

Rule dockets 

(MACT/NSPS) 

NESHAP for Stainless and 

Nonstainless Steel Electric Arc 

Furnaces (EAF) Manufacturing 

 Section 114 responses from 9 

companies representing 27 

plants and 38 EAFs 

 Data are from one-time data 

collection/sampling 

 Responses are from 2003 

 Data are from one-time data 

collection/sampling 

4 data elements reported (from 25 

facilities) are the same as inputs: 

 In 98.176(b), annual raw steel 

produced (eq.Q-2, Q-5, and Q-6). 

 Average hourly feed or production rate 

during the stack test [98.176(f)(2)]. 

Journals Iron and Steel Technology, 

Foundry Management and 

Technology, American Machinist, 

Forging Magazine, Advanced 

Materials and Processes, Institute 

of Materials, Minerals, and Mining

No data elements were identified as 

being publicly available 

1

 AL, AR, CO, FL, IN, MI, NC, OH, UT, VA 

2

 CA, CT, CO, DE, FL, HI, IA, MA, MD, ME, NC, NJ, NM, NV, OR, WA, WI, WV 

3 From a broader NAICS code search: 4 facilities report annual quantity raw steel produced (No CEMS) [98.176(b) Eqns. Q-2, 

Q-5, Q-6]; 8 facilities report Annual quantity iron produced (No CEMS) [98.176(b) Eqns. Q-2, Q-7]; 

8 facilities report Annual quantity coke produced (No CEMS) [98.176(b) Eqns. Q-2] 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

76 

Table B-12. Public Availability of ”Inputs to Equations” for Subpart R 

Source Description of Sources 

Reviewed 

Results 

Permits 3 Title V permits (of 7 identified 

sources) from 2 states (IN and 

NY)

No data elements were identified as being 

publicly available 

NEI/Federal 

databases 

NEI, CAMD, eGRID, TRI, 

DOE/EIA, and OECA ECHO 

databases 

No data elements were identified as being 

publicly available 

State/Regional 

databases 

Online inventory databases for 

The Climate Registry, Western 

Climate Initiative, Regional 

Greenhouse Gas Initiative, and 

18 states that have or were 

considering mandatory reporting 

programs 

1

No data elements were identified as being 

publicly available 

Rule dockets 

(MACT/NSPS) 

Primary Lead Smelting 

NESHAP 

 Section 114 responses 

Secondary Lead Smelting 

NESHAP 

 Section 114 responses 

 Data are from one-time data 

collection/sampling 

Information reported is the same as 5 

data elements 

 The amount of ore shipped to the facility 

for processing by mine (from 1 facility) 

and the amount of material charged to 

the smelter by type (for 5 facilities) are 

the same as data inputs to eq. R-1 in 

98.186(b)(6), the annual material 

quantity used for calculation of process 

CO2 emissions based on annual mass of: 

o lead ore charged to the smelting 

furnace (tons). 

o lead scrap charged to the smelting 

furnace (tons). 

o flux materials (e.g., limestone, 

dolomite) charged to the smelting 

furnace (tons). 

o carbonaceous materials (e.g., coal, 

coke) charged to the smelting 

furnace (tons). 

o any other material containing 

carbon, other than fuel, fed, charged, 

or otherwise introduced into the 

smelting furnace (tons). 

Journals No trade journals identified Not applicable 

1

 CA, CT, CO, DE, FL, HI, IA, MA, MD, ME, NC, NJ, NM, NV, OR, WA, WI, WV 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

77 

Table B-13. Public Availability of ”Inputs to Equations” for Subpart S 

Source Description of Sources 

Reviewed 

Results 

Permits 10 Title V permits (11% of 

identified sources) from 10 states1

No data elements were identified as being 

publicly available 

NEI/Federal 

databases 

NEI, CAMD, eGRID, TRI, 

DOE/EIA, and OECA ECHO 

databases 

No data elements were identified as being 

publicly available 

State/Regional 

databases 

Online inventory databases for 

The Climate Registry, Western 

Climate Initiative, Regional 

Greenhouse Gas Initiative, and 18 

states that have or were 

considering mandatory reporting 

programs

2

No data elements were identified as being 

publicly available 

Rule dockets 

(MACT/NSPS) 

Lime Manufacturing Plants 

NESHAP 

 Docket items EPA-HQ-OAR2002-0052-0080 & EPA-HQOAR-2002-0052-0196, which 

present a summary of non-CBI 

information obtained from a 

survey of lime manufacturers 

No data elements were identified as being 

publicly available 

Journals No trade journals identified No data elements were identified as being 

publicly available 1 AR, AZ, ID, IN, MO, OH, UT, VA, WI, WV

2

 CA, CT, CO, DE, FL, HI, IA, MA, MD, ME, NC, NJ, NM, NV, OR, WA, WI, WV 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

78 

Table B-14. Public Availability of ”Inputs to Equations” for Subpart U 

Source Description of Sources Reviewed Results 

Permits 10 Title V permits from 9 states1 No data elements were identified as 

being publicly available 

NEI/Federal 

databases 

NEI, CAMD, eGRID, TRI, 

DOE/EIA, and OECA ECHO 

databases 

No data elements were identified as 

being publicly available 

State/Regional 

databases 

Online inventory databases for 

The Climate Registry, Western 

Climate Initiative, Regional 

Greenhouse Gas Initiative, and 18 

states that have or were 

considering mandatory reporting 

programs2

No data elements were identified as 

being publicly available 

Rule dockets 

(MACT/NSPS) 

No rule development docket 

identified 

Not applicable 

Journals No trade journals identified Not applicable 

1

 CA, GA, ID, LA, MN, NC, OH, TX, WI 

2

 CA, CT, CO, DE, FL, HI, IA, MA, MD, ME, NC, NJ, NM, NV, OR, WA, WI, WV 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

79 

Table B-15. Public Availability of ”Inputs to Equations” for Subpart V 

Source Description of Sources Reviewed Results 

Permits 10 Title V permits (22% of 

identified sources) from 10 states1

2 permits contained data that are exactly 

the same as 3 GHGRP data elements: 

 Abatement technology destruction 

efficiency [98.266(i), eq. V-3a, V-3b, 

V-3c] 

NEI/Federal 

databases 

NEI, CAMD, eGRID, TRI, 

DOE/EIA, and OECA ECHO 

databases 

No data elements were identified as 

being publicly available 

State/Regional 

databases 

Online inventory databases for 

The Climate Registry, Western 

Climate Initiative, Regional 

Greenhouse Gas Initiative, and 18 

states that have or were 

considering mandatory reporting 

programs2

No data elements were identified as 

being publicly available 

Rule dockets 

(MACT/NSPS) 

NSPS for Nitric Acid Plants 

dockets identified: 

EPA-HQ-OECA-2009-0525 

EPA-HQ-OECA-2006-0437 

EPA-HQ-OECA-2003-0030 

Dockets only include ICRs and 

paperwork reduction/burden claims. No 

plant level information provided. 

Journals No trade journals identified Not applicable 

1

 AR, FL, GA, IA, ID, OH, OK, TX, UT, WY 

2

 CA, CT, CO, DE, FL, HI, IA, MA, MD, ME, NC, NJ, NM, NV, OR, WA, WI, WV 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

80 

Table B-16. Public Availability of ”Inputs to Equations” for Subpart W 

Source Description of Sources Reviewed Results 

Permits Ranges from 2 to 24 Title V permits from 

24 states1

Some permits contained data that are exactly the 

same as 18 data elements: 

 Whether flash tank separator is used in glycol 

dehydrator [98.236(c)(4)(i)(D)] – 4 permits 

 Count of glycol dehydrators 

[98.236(c)(4)(ii)(A)] – 14 permits 

 Total volume of sales oil from all wells 

[98.236(c)(8)(ii)(A)] – 1 permit 

 Volume of gas sent to flare [98.236(c)(12)(ii), 

eq. W-19, W-20, W-21] – 1 permit 

 Flare combustion efficiency [98.236(c)(12)(v), 

eq. W-19, W-21] – 1 permit 

 Count of centrifugal compressors 

[98.236(c)(13)(v)(A)] – 7 permits 

 Count of reciprocating compressors 

[98.236(c)(14)(v)(A)] – 14 permits 

 Count for each type of equipment leak source 

[98.236(c)(15)(ii)(A)] and for each type of 

major equipment [98.236(c)(15)(ii)(B)] – 3 

permits 

 Volume of fuel combusted in external fuel 

combustion units [98.236(c)(19)(iv), eq. W39A, W-39B, W-40] and internal fuel 

combustion units [98.236(c)(19)(vii), eq. W39A, W-39B, W-40] – 10 permits

NEI/Federal 

databases 

NEI, CAMD, eGRID, TRI, DOE/EIA, 

and OECA ECHO databases 

NEI reported data on 168 facilities in relevant 

NAICS codes for flare stacks3

: Volume of gas 

sent to flare (cubic feet per 

year).[98.236(c)(12)(ii), Eqns. W-19, W-20, and 

W-21]

State/Regional 

databases 

Online inventory databases for The 

Climate Registry, Western Climate 

Initiative, Regional Greenhouse Gas 

Initiative, DOI/BOEM's 2008 Gulfwide 

Emission Inventory, and 18 states that 

have or were considering mandatory 

reporting programs2

Gulfwide Emission Inventory contained data that 

are exactly the same as 7 data elements: 

 Count of natural gas driven pneumatic pumps 

[98.236(c)(2)(i)] 

 Total throughput of each AGR unit 

[98.236(c)(3)(i)] – Amine gas sweetening unit 

data for 4 facilities 

 Glycol dehydrator feed natural gas flow rate 

[98.236(c)(4)(i)(A)] – Throughput data for 

304 facilities 

 Count of glycol dehydrators 

[98.236(c)(4)(ii)(A)] 

 Volume of gas sent to flare [98.236(c)(12)(ii), 

eq. W-19, W-20, W-21] – Throughput data for 

102 facilities 

Rule dockets 

(MACT/NSPS) 

 Oil and Natural Gas Production and 

Natural Gas Transmission and Storage 

NESHAPs (Data are from one-time 

Dockets contained data that are exactly the same 

as 9 data elements: 

 Glycol dehydrator feed natural gas flow rate 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

81 

Source Description of Sources Reviewed Results 

data collection/sampling) 

 2 surveys contained triethylene glycol 

dehydrator data for 23 units 

 1 survey contained quantity of 

produced water from disposal wells 

for 3 facilities 

Oil and Natural Gas Production and 

Natural Gas Transmission and 

Distribution NSPS (Data are from onetime data collection/sampling) 

 Technology review document 

contained sulfur recovery data for 21 

units at 15 facilities, glycol dehydrator 

data for 19 units at 9 facilities, and 

storage tank data for a tank at 1 

facility 

[98.236(c)(4)(i)(A)] – 14 facilities 

 For glycol dehydrators, absorbent circulation 

pump type [98.236(c)(4)(i)(B)], Whether 

stripper gas is used [98.236(c)(4)(i)(C)], 

Whether flash tank separator is used 

[98.236(c)(4)(i)(D)], Type of absorbent 

[98.236(c)(4)(i)(E)], Total time operating 

[98.236(c)(4)(i)(F)], Wet natural gas 

temperature and pressure [98.236(c)(4)(i)(G)], 

Concentration of CO2 [98.236(c)(4)(i)(H)], 

and Concentration of CH4 [98.236(c)(4)(i)(H)] 

– 8 facilities

Journals Hydrocarbon Processing, World Oil, 

Touch Oil and Gas, Oil and Gas Journal 

No data elements were identified as being 

publicly available 

1 AK, AZ, CA, CO, FL, IA, IL, IN, LA, MI, MN, MO, MS, NC, NM, NY, OH, OK, TX, UT, VA, WI, WV, WY 2

 CA, CT, CO, DE, FL, HI, IA, MA, MD, ME, NC, NJ, NM, NV, OR, WA, WI, WV 

3

 Exact facility matches between the 1,550 subpart W facilities in GHGRP and NEI were not assessed. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

82 

Table B-17. Public Availability of ”Inputs to Equations” for Subpart X 

Source Description of Sources Reviewed Results 

Permits 8 Title V permits (10% of 

identified sources) from 5 states1

No data elements were identified as 

being publicly available 

NEI/Federal 

databases 

NEI, CAMD, eGRID, TRI, 

DOE/EIA, and OECA ECHO 

databases 

1 data element reported is the same as 

inputs, the quantity of each type of fuel 

used for each stationary combustion unit 

or group of units during the reporting 

year. 

[98.246(b)(5)(iii), eq. C-8] 

 NEI contains information from 23 

facilities (registered in the GHGRP) 

on the annual consumption of natural 

gas at the unit level. 

 NEI contains information from 1 

facility (registered in the GHGRP) on 

the quantity of fuel used for each 

stationary combustion unit or group of 

units during the reporting year. 

State/Regional 

databases 

Online inventory databases for 

The Climate Registry, Western 

Climate Initiative, Regional 

Greenhouse Gas Initiative, and 18 

states that have or were 

considering mandatory reporting 

programs

2

No data elements were identified as 

being publicly available 

Rule dockets 

(MACT/NSPS) 

Ethylene Processes NESHAP 

 Section 114 responses from 11 

facilities 

 Data collected in 1997 one-time 

survey. Not available 

electronically. 

No data elements were identified as 

being publicly available 

Journals Hydrocarbon Processing, World 

Oil, Touch Oil and Gas, Oil and 

Gas Journal 

No data elements were identified as 

being publicly available 

1

 IA, IL, OH, OK, TX 

2

 CA, CT, CO, DE, FL, HI, IA, MA, MD, ME, NC, NJ, NM, NV, OR, WA, WI, WV 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

83 

Table B-18. Public Availability of ”Inputs to Equations” for Subpart Y 

Source Description of Sources 

Reviewed 

Results 

Permits 13 Title V permits from 12 

states1 6 permits provided the information on the 

number of catalytic cracking units, coking units, 

hydrotreating units, and hydrogen plants 

[98.256(n)(3), eq. Y-21] 

 The permits did not provide the number of all the units 

listed in equation Y-21.

NEI/Federal 

databases 

NEI, CAMD, eGRID, TRI, 

DOE/EIA, and OECA ECHO 

databases 

2 data elements reported in NEI are the same as 

inputs, 

 Annual throughput of the unit 

[98.256(f)(10), eq. Y-8] was reported for 

cracking units at 16 facilities matched 

with GHGRP. 

 Annual average higher heating value of 

the flare gas [(98.256(e)(9), Eqn Y-3] 

was reported for 1 facility matched with 

GHGRP. 

State/Regional 

databases 

Online inventory databases for 

The Climate Registry, Western 

Climate Initiative, Regional 

Greenhouse Gas Initiative, and 

18 states that have or were 

considering mandatory 

reporting programs 2

No data elements were identified as being publicly 

available 

Rule dockets 

(MACT/NSPS) 

Petroleum Refinery NSPS 

docket (subpart J) 

 Source test reports from 5 

facilities 

 Data are from one-time data 

collection/sampling

5 data elements reported are the same as inputs: 

 Dimensions of coke drum or vessel [98.256(k)(3), eq. Y-18] 

 Typical gauge pressure of the coking drum when first vented 

to the atmosphere [98.256(k)(3), eq. Y-18] 

 Annual number of coke-cutting cycles of coke drum or vessel 

[98.256(k)(3), eq. Y-18] 

 Height and diameter of coke drums [98.256(k)(4), eq. Y-18] 

 Typical venting pressure of delayed coking units 

[98.256(k)(4), eq. Y-18] 

Journals Hydrocarbon Processing, 

World Oil, Touch Oil and Gas, 

Oil and Gas Journal 

No data elements were identified as being publicly 

available 

1

 AK, AR, CO, GA, IL, IN, MI, OK, TX, WI, WV, WY 

2

 CA, CT, CO, DE, FL, HI, IA, MA, MD, ME, NC, NJ, NM, NV, OR, WA, WI, WV 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

84 

Table B-19. Public Availability of ”Inputs to Equations” for Subpart Z 

Source Description of Sources Reviewed Results 

Permits 5 Title V permits (33% of 

identified sources) from 4 states1

No data elements were identified as 

being publicly available 

NEI/Federal 

databases 

NEI, CAMD, eGRID, TRI, 

DOE/EIA, and OECA ECHO 

databases 

No data elements were identified as 

being publicly available 

State/Regional 

databases 

Online inventory databases for 

The Climate Registry, Western 

Climate Initiative, Regional 

Greenhouse Gas Initiative, and 18 

states that have or were 

considering mandatory reporting 

programs

2

No data elements were identified as 

being publicly available 

Rule dockets 

(MACT/NSPS) 

Phosphoric Acid Manufacturing 

NESHAP: 

 Meeting notes in supporting 

documentation 

No data elements were identified as 

being publicly available

Journals No trade journals identified Not applicable 

1

 FL, ID, NC, WY 

2

 CA, CT, CO, DE, FL, HI, IA, MA, MD, ME, NC, NJ, NM, NV, OR, WA, WI, WV 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

85 

Table B-20. Public Availability of ”Inputs to Equations” for Subpart AA 

Source Description of Sources Reviewed Results 

Permits 15 Title V permits (10% of 

identified sources) from 15 states1

No data elements were identified as being 

publicly available 

NEI/Federal 

databases 

NEI, CAMD, eGRID, TRI, 

DOE/EIA, and OECA ECHO 

databases 

From the NEI: 

 9 facilities out of 110 reported 

annual fuel consumption data in 

lime kilns.[98.276(g), Eqns. C-1, C1a, C-1b, C-2a, C-3, C-4, C-5, C-8, 

C-8a, C-8b, C-9a] 

 9 facilities out of 110 reported 

quantity of black liquor solids 

combusted [98.276(c), Eqn. AA-1 

and AA-2] 

 1 facility out of 110 reported annual 

quantity of fossil fuel consumption 

in chemical recovery furnace 

[98.276(b) Eqns. C-1, C-1a, C-1b, 

C-2a, C-3, C-4, C-5, C-8, C-8a, C8b, C-9a]] 

State/Regional 

databases 

Online inventory databases for 

The Climate Registry, Western 

Climate Initiative, Regional 

Greenhouse Gas Initiative, and 18 

states that have or were 

considering mandatory reporting 

programs2

No data elements were identified as being 

publicly available 

Rule dockets 

(MACT/NSPS) 

Pulp and Paper NESHAP 

 Section 114 responses 

 Data elements related to fuel 

use in recovery boilers and lime 

kilns were requested in the 

survey, but no information is 

provided in the docket. 

Unknown whether data were 

considered CBI. 

No data elements were identified in the 

docket as being publicly available 

Journals TAPPI, Pulp and Paper 

International, Paper Age, Pulp and 

Paper Week, Paperboard 

Packaging, Timberline 

No data elements were identified as being 

publicly available 

1

 AR, FL, GA, ID, IL, ME, MI, NC, NY, OH, OK, TX, VA, WI, WV 

2

 CA, CT, CO, DE, FL, HI, IA, MA, MD, ME, NC, NJ, NM, NV, OR, WA, WI, WV 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

86 

Table B-21. Public Availability of ”Inputs to Equations” for Subpart BB 

Source Description of Sources Reviewed Results 

Permits 1 Title V permit (100% of 

identified sources) from 1 state1

No data elements were identified as 

being publicly available 

NEI/Federal 

databases 

NEI, CAMD, eGRID, TRI, 

DOE/EIA, and OECA ECHO 

databases 

No data elements were identified as 

being publicly available 

State/Regional 

databases 

Online inventory databases for 

The Climate Registry, Western 

Climate Initiative, Regional 

Greenhouse Gas Initiative, and 18 

states that have or were 

considering mandatory reporting 

programs2

No data elements were identified as 

being publicly available 

Rule dockets 

(MACT/NSPS) 

No rule development docket 

identified 

Not applicable 

Journals No trade journals identified Not applicable 

1

 IL 

2

 CA, CT, CO, DE, FL, HI, IA, MA, MD, ME, NC, NJ, NM, NV, OR, WA, WI, WV 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

87 

Table B-22. Public Availability of ”Inputs to Equations” for Subpart CC 

Source Description of Sources Reviewed Results 

Permits 3 Title V permits from 1 state1 The Title V permit review package for 

these three permits contains 2006 and 

2007 stack test results that provide 

information on 1 data element that is the 

same as an input: 

 stack gas volumetric flow rate during 

performance tests for each line or 

stack [98.296(b)(10)(i), eq. CC-3] 

NEI/Federal 

databases 

NEI, CAMD, eGRID, TRI, 

DOE/EIA, and OECA ECHO 

databases 

No data elements were identified as 

being publicly available 

State/Regional 

databases 

Online inventory databases for 

The Climate Registry, Western 

Climate Initiative, Regional 

Greenhouse Gas Initiative, and 18 

states that have or were 

considering mandatory reporting 

programs

2

No data elements were identified as 

being publicly available 

Rule dockets 

(MACT/NSPS) 

No rule development docket 

identified 

Not applicable 

Journals No trade journals identified Not applicable 

1

 Only 3 affected facilities and all of them are located in WY 

2

 CA, CT, CO, DE, FL, HI, IA, MA, MD, ME, NC, NJ, NM, NV, OR, WA, WI, WV 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

88 

Table B-23. Public Availability of ”Inputs to Equations” for Subpart EE 

Source Description of Sources Reviewed Results 

Permits 4 Title V permits (50% of identified 

sources) from 2 states1

No data elements were identified as 

being publicly available 

NEI/Federal 

databases 

NEI, CAMD, eGRID, TRI, DOE/EIA, 

and OECA ECHO databases 

No data elements were identified as 

being publicly available 

State/Regional 

databases 

Online inventory databases for The 

Climate Registry, Western Climate 

Initiative, Regional Greenhouse Gas 

Initiative, and 18 states that have or 

were considering mandatory reporting 

programs

2

No data elements were identified as 

being publicly available 

Rule dockets 

(MACT/NSPS) 

No rule development docket identified Not applicable 

Journals No trade journals identified Not applicable 

1

 OH, MS. Facilities located in other states do not have TV permits available online. 

2

 CA, CT, CO, DE, FL, HI, IA, MA, MD, ME, NC, NJ, NM, NV, OR, WA, WI, WV 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

89 

Table B-24. Public Availability of ”Inputs to Equations” for Subpart GG 

Source Description of Sources Reviewed Results 

Permits 1 Title V permit (20% of identified 

sources) from 1 state1

No data elements were identified 

as being publicly available 

NEI/Federal 

databases 

NEI, CAMD, eGRID, TRI, DOE/EIA, and 

OECA ECHO databases No data elements were identified 

as being publicly available in 

facilities matched between the 

GHGRP and NEI.

State/Regional 

databases 

Online inventory databases for The 

Climate Registry, Western Climate 

Initiative, Regional Greenhouse Gas 

Initiative, and 18 states that have or were 

considering mandatory reporting programs2

No data elements were identified 

as being publicly available 

Rule dockets 

(MACT/NSPS) 

 NESHAP for Area Sources: Polyvinyl Chloride and 

Copolymers Production, Primary Copper Smelting, 

Secondary Copper Smelting, and Primary Nonferrous 

Metals-- Zinc, Cadmium, and Beryllium (EPA-HQOAR-2006-0510) 

 NESHAP: Area Source Standards for Aluminum, 

Copper, and Other Nonferrous Foundries (EPA-HQOAR-2008-0236) 

No information found in either 

docket 

Journals No trade journals identified Not applicable 

1

 IL 

2

 CA, CT, CO, DE, FL, HI, IA, MA, MD, ME, NC, NJ, NM, NV, OR, WA, WI, WV
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

90 

Table B-25. Public Availability of ”Inputs to Equations” for Subpart II 

Source Description of Sources Reviewed Results 

Permits 12 Title V permit from 8 states1 No data elements were identified 

as being publicly available 

NEI/Federal 

databases 

NEI, CAMD, eGRID, TRI, DOE/EIA, and 

OECA ECHO databases 

No data elements were identified 

as being publicly available 

State/Regional 

databases 

Online inventory databases for The 

Climate Registry, Western Climate 

Initiative, Regional Greenhouse Gas 

Initiative, and 18 states that have or were 

considering mandatory reporting programs2

No data elements were identified 

as being publicly available 

Rule dockets 

(MACT/NSPS) 

No rule development docket identified Not applicable 

Journals Water & Wastes Digest, JAWMA, Waste 

Management, Waste & Recycling News, 

Waste Age, Water Science & Technology, 

Water and Environmental Management, 

American Water Works Association 

Journal, Pumps & Systems 

No data elements were identified 

as being publicly available 

1

 Reviewed the following potentially affected facilities: 4 paper mills in AR, FL, VA, WA; 3 refineries in AR, CO, IN; 3 ethanol

plants in IA, IN, SD, and 2 food processing plants in AR and IN. 

2

 CA, CT, CO, DE, FL, HI, IA, MA, MD, ME, NC, NJ, NM, NV, OR, WA, WI, WV 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

91 

Table B-26. Public Availability of ”Inputs to Equations” for Subpart TT 

Source Description of Sources Reviewed Results 

Permits Reviewed 7 paper mill permits in 

AR, FL, GA, ID, ME, VA, and WI 

and reviewed 3 food processing 

plant permits in AR, IN, and WI. 

No data elements were identified as 

being publicly available 

NEI/Federal 

databases 

NEI, CAMD, eGRID, TRI, 

DOE/EIA, and OECA ECHO 

databases 

No data elements were identified as 

being publicly available 

State/Regional 

databases 

3 state agencies (CA, CO, WI) 

publish annual tonnage reports. 

Part 98 requires historical disposal 

records. States publish only the 

past 10 to 25 years online. 

No data elements were identified as 

being publicly available 

Rule dockets 

(MACT/NSPS) 

No rule development docket 

identified 

Not applicable 

Journals No trade journals identified Not applicable 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

92 

Appendix C 

Review of Sources Cited By Sierra Club that Provide Publicly Available Information for 

the 2015 Data Inputs 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

93 

Review of Sources Cited By Sierra Club that Provide Publicly Available Information for the 2015 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

C

98.36(b)(9)(iii)

Estimate of heat

input

Ex. C1 (Spreadsheet).

Worksheet "Process Data

Organics Testing"

Column M.

Survey

response

Example where sources havereported this information

previously

Y N

Data ava

Survey re

input (M

that inclu

data colle

source is availabili

C

98.36(c)(2)(i)(x)

An estimate of the

heat input from each

type of fuel

Ex. C1 (Spreadsheet).

Worksheet "Process Data

Organics Testing"

Column M.

Surveyresponse

Example where sources havereported this information

before

N N

Data ava

Survey re

input (M

that includata colle

C

98.36(e)(2)(i)

Total quantity ofeach type of fuel

combusted

Ex. C3, p. vii. U.S.

Department of

EnergyEnergyInformationAdministrationForm EIA‐767

(2005),STEAM‐ELECTRICPLANTOPERATIONAND DESIGNREPORT

Common reporting

requirement in all permits

Y N

Data ava

plants wiconnecte

evaluated 

analysis. 

C

98.36(e)(2)(ii)(A)

Total monthlyquantity of each type

of fuel combusted

Ex. C3, p. vii. U.S.

Department of

EnergyEnergy

InformationAdministration

Form EIA‐767(2005),STEAM‐

Common reporting

requirement in all permits

Y N

Data ava

plants wi

connecte

evaluated 

analysis. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

94 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

ELECTRICPLANTOPERATIONAND DESIGNREPORT

C

98.36(e)(2)(

ii)(C)

Monthly high heat

values used in the

CO2 emissions

calculations for each

type of fuel

combusted

Ex. C3, p. vii.; See also p.

xxii.

U.S.Department of

EnergyEnergyInformationAdministrationForm EIA‐767(2005),STEAM‐ELECTRICPLANTOPERATIONAND DESIGNREPORT

Heating values for commonfuels are available in standard

reference

Y N

Data ava

plants wi

connecteevaluated 

analysis. 

C Ex. C4. Survey

response

Heating values for commonfuels are available in standardreference N N

Data ava

Survey re

Value (HH

ICR three 

match fo

C

98.36(e)(2)(ii)(D)

Total quantity (i.e.,pounds) of steam

produced from MSW

or solid fuelcombustion duringthe year,

Ex. C1 (Spreadsheet).

Worksheet "Process Data

Organics Testing"

Column N.

Survey

response

N N

Data ava

Survey re

lbs steam

day perio

annual q

C

98.36(e)(2)(ii)(D)

Ratio of the

maximum rate heatinput capacity to the

design rated steam

output capacity of

the unit

None cited Not provided Arithmetic calculation.

N N

No evide
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

95 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

C

98.36(e)(2)(iv)(A)

Quantity of each

type of fuelcombusted duringeach month

Ex. C1 (Spreadsheet).

Worksheet "Process Data

Organics Testing"

Column C.

Survey

response

Previously reported

N N

Data ava

consump

period fo

quantity 

C

98.36(e)(2)(iv)(A)

Ex. C‐3.

U.S.Department of

EnergyEnergyInformationAdministrationForm EIA‐767

(2005),STEAM‐ELECTRICPLANTOPERATIONAND DESIGNREPORT

Previously reported

Y N

Data ava

plants wi

connecte

evaluated 

analysis. 

C

98.36(e)(2)(iv)(C)

ALL The carbon

content used in the

emission calculations(including both valid

and substitute data

values).

Seehttp://bioenergy.ornl.gov/papers/misc/energy_conv.html

website Carbon content for most fuels

are available in standard

references N N

Average 

and bioebut indiv

available

C

98.36(e)(2)(iv)(C)

ALL gas molecular

weight values used in

the emissioncalculations(including both valid

and substitute data

values).

Seehttp://www.engineeringtoolbox.com/molecular‐weight‐gas‐vapor‐d_1156.html

website Gas molecular weights are

available in standard

references

N N

Referenc

pure fuel

additives 

specific favailable 

used.

C

98.36(e)(2)(iv)(C)

Monthly average

values for carboncontent used in the

emission calculations(including both valid

and substitute data

Seehttp://bioenergy.ornl.gov/papers/misc/energy_conv.html

website Carbon content for most fuels

are available in standard

references N N

Average 

and bioebut indiv

average v
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

96 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

values).

C

98.36(e)(2)(iv)(C)

Monthly average

values for gasmolecular weight

values used in the

emission calculations(including both valid

and substitute data

values).

Seehttp://www.engineeringtoolbox.com/molecular‐weight‐gas‐vapor‐d_1156.html

website Gas molecular weights are

available in standard

references

N N

Referenc

pure fuel

additives 

specific favailable 

C

98.36(e)(2)(iv)(F)

The annual average

measured HHV data

used to calculate CH4

and N2O emissions

No reference provided Not provided HHV data for common fuels

are available in standardreferences. Y N

Default Hmeasure

availablethe publiAppendix 

C

98.36(e)(2)(ix)(D)

Carbon‐based F‐factor used in

Equation C‐13 of thissubpart for eachfossil fuel

Ex. C4., EPA Method 19 Survey

response

Available in regulations as

provided in the equation

N N

Carbon b

referencespecific b

C

98.36(e)(2)(ix)(E)

Annual average HHV

value used in

Equation C‐13 of thissubpart for eachfossil fuel

No reference provided Not provided Arithmetic calculation.

N N

Facility sp

availabledetermin

C

98.36(e)(2)(ix)(F)

Total quantity offossil fuel combusted

during the reporting

year

No reference provided Not provided Arithmetic calculation.

N N

No specif

could on

values re

C 98.36(e)(2)(

x)(A)

Results of each

quarterly sample

analysis

Ex. C1 (Spreadsheet).

Worksheet "Process Data

Organics Testing"

Column C.

Surveyresponse

Fuel composition is alreadybeing reported

N N

Data ava

Survey re

firing rate quarterly 

available period.
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

97 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

C Ex. C‐3

US DOE/EIA Form EIA‐767

U.S.Department of

EnergyEnergyInformationAdministrationForm EIA‐767

(2005),STEAM‐ELECTRICPLANTOPERATIONAND DESIGNREPORT

Fuel composition is alreadybeing reported

Y N

Data ava

plants wi

connecte

evaluated 

analysis. 

C 98.36(e)(2)(

xi)98.36(e)(2)(xi)

Results of each

quarterly sample

analysisResults of quarterlysample analysis

Ex. C1 (Spreadsheet).

Worksheet "Process Data

Organics Testing"

Column C.

Surveyresponse

Fuel composition is alreadybeing reported

N N

Data ava

Survey re

firing rate 

quarterly 

available period.

Ex. C‐3US DOE/EIA Form EIA‐767

U.S.Department of

EnergyEnergyInformationAdministrationForm EIA‐767(2005),STEAM‐ELECTRICPLANTOPERATIONAND DESIGNREPORT

Fuel composition is alreadybeing reported

N N

Data avaplants wi

connecteevaluated 

analysis. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

98 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

H 98.86(b)(2) Monthly clinker

production (NoCEMS)

Ex. CEM1: Holcim

Romania paper 2002,p.23

Romanianstudy paper

titled "JI ‐ 

Project forreduction of

CO2 emissions

at Alesd

Cement PlantandCampulungCement Plant"

Can be calculated or estimated

from cement production by

assuming typical factor or by

direct measurement.Reported in Europe.

N N

Monthly 

available

actual cli

Romania

capacitie

H 98.86(b)(5) Quarterly quantity of

CKD not recycled tothe kiln

Ex. CEM6: Ashgrove

Durkee (example) EPA‐HQ‐OAR‐2002‐0051‐

3572, p.4

Section 114request forAsh Grove

CementCompany'sfacility inDurkee, OR;documentlocated indocket for

Portland

Cement

ManufacturingNESHAP (A‐92‐

53)

Similar to previously reported

by companies as part of

NESHAP ICR

N N

Data avaSurvey rereturn du

provide erecycled 

H 98.86(b)(6) Monthly fraction of

total CaO in clinker

Ex. CEM1: Holcim

Romania paper 2002,p.26

Romanianstudy papertitled "JI ‐ 

Project for

reduction ofCO2 emissions

at Alesd

Cement PlantandCampulungCement Plant"

Essentially annual averagereported and in public domain

N N

Monthly 

not availafrom clin

each of t
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

99 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

H 98.86(b)(6) Monthly fraction of

total MgO in clinker

Ex. CEM1: Holcim

Romania paper 2002,p.26

Romanianstudy papertitled "JI ‐ 

Project for

reduction ofCO2 emissions

at Alesd

Cement PlantandCampulungCement Plant"

Essentially annual averagereported and in public domain

N N

Monthly 

not availafrom clin

for each 26].

H 98.86(b)(6) Monthly fraction of

non‐calcined CaO in

clinker

Ex. CEM1: Holcim

Romania paper 2002,p.26

Romanianstudy papertitled "JI ‐ 

Project for

reduction ofCO2 emissions

at Alesd

Cement PlantandCampulungCement Plant"

Essentially annual average

reported and in public domain

N N

Monthly clinker no

percent 

is providefacilities 

H 98.86(b)(6) Monthly fraction of

non‐calcined MgO in

clinker

Ex. CEM1: Holcim

Romania paper 2002,p.26

Romanianstudy papertitled "JI ‐ 

Project for

reduction ofCO2 emissions

at Alesd

Cement PlantandCampulungCement Plant"

Essentially annual averagereported and in public domain

N N

Monthly 

in clinker percent 

is providfacilities 

H 98.86(b)(8) Quarterly fraction of

total CaO in CKD not

recycled to the kiln

Ex. CEM7: Prof. Walsh

Powerpoint, Dalhousie

University

PowerPointslides titled"Investigationinto the Use of

CKD for

WastewaterTreatment";

Already reported and in public

domain

N N

Data avaquarterly 

the CaO c

from 6 fapreviousPeethamcontent (
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

100 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Presented at

PortlandCementAssociation'sManufacturingTechnicalCommitteeMeeting byM.E. Walshand C.B. Lake,Dept. of Civil& ResourceEngineering,DalhousieUniversity(Nova Scotia,Canada)

sample loTodres et 

%) of 3 C

locations indicate i

H 98.86(b)(8) Quarterly fraction of

total MgO in CKD not

recycled to the kiln

Ex. CEM7: Prof. Walsh

Powerpoint, Dalhousie

University

PowerPointslides titled"Investigationinto the Use of

CKD for

WastewaterTreatment";Presented at

Portland

CementAssociation'sManufacturingTechnical

CommitteeMeeting byM.E. Walsh

and C.B. Lake,

Dept. of Civil

& Resource

Engineering,DalhousieUniversity(Nova Scotia,

Already reported and in publicdomain

N N

Data avaquarterly 

of CKD sa

19]; Inclufrom PeeMgO con

(no sampand Todrcontent (sample lo21].Does kiln.
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

101 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Canada)

H 98.86(b)(8) Quarterly fraction of

non‐calcined CaO in

CKD not recycled to

the kiln

Ex. CEM7: Prof. Walsh

Powerpoint, Dalhousie

University

PowerPointslides titled"Investigationinto the Use of

CKD for

WastewaterTreatment";Presented at

Portland

CementAssociation'sManufacturingTechnical

CommitteeMeeting byM.E. Walsh

and C.B. Lake,

Dept. of Civil

& Resource

Engineering,DalhousieUniversity(Nova Scotia,Canada)

Already reported and in publicdomain

N N

Data avaquarterly 

of CKD sa

19]; Inclufrom Pee

MgO con

(no sampand Todrcontent (sample lo21].Does kiln.
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

102 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

H 98.86(b)(8) Quarterly fraction of

non‐calcined MgO in

CKD not recycled to

the kiln

Ex. CEM7: Prof. Walsh

Powerpoint, Dalhousie

University

PowerPointslides titled"Investigationinto the Use of

CKD for

WastewaterTreatment";Presented at

Portland

CementAssociation'sManufacturingTechnical

CommitteeMeeting byM.E. Walsh

and C.B. Lake,

Dept. of Civil

& Resource

Engineering,DalhousieUniversity(Nova Scotia,Canada)

Already reported and in publicdomain

N N

Data avaquarterly 

of CKD sa

19]; Inclufrom Pee

MgO con

(no sampand Todrcontent (sample lo

Does not 

H

98.86(b)(10)

Monthly kiln‐specificclinker CO2 emission

factors

None cited Not provided CO2 data is from CEMS and is

therefore emissions.Production data from

recordkeeping.

No data

provided N

No evide

H

98.86(b)(11)

Quarterly kiln‐specific CKD CO2

emission factors

None cited Not provided CO2 data is from CEMS and is

therefore emissions.Production data from

recordkeeping.

no data

provided N

No evide
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

103 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

H

98.86(b)(12)

Annual organiccarbon content ofeach raw kiln feed or

annual organic

carbon content ofeach raw material

Ex. CEM6: Ashgrove

Durkee (example) EPA‐HQ‐OAR‐2002‐0051‐

3572, last several pages.

Section 114

request forAsh Grove

CementCompany'sfacility inDurkee, OR;documentlocated indocket for

PortlandCement

Manufacturing

NESHAP (A‐92‐53)

Previously reported by

companies as part of NESHAPsICR

Y N

Data avaSurvey recontent (

(limeston

sampling 

total); Re

ppm) also samples tis evaluatanalysis. 

H

98.86(b)(13)

Annual consumption

of each raw kiln feed

or annualconsumption of each

raw materials

Ex. CEM6: Ashgrove

Durkee (example) EPA‐HQ‐OAR‐2002‐0051‐

3572, p.4

Section 114request forAsh Grove

CementCompany'sfacility in

Durkee, OR;

documentlocated indocket for

PortlandCementManufacturing

NESHAP (A‐92‐

53)

Previously reported by

companies as part of NESHAPsICR

Y N

Data avaSurvey rematerials 

(iron sousource is availabili

H

98.86(b)(15)

Monthly kiln‐specificclinker factors (if

used) for each kiln

Ex. CEM1: Holcim

Romania paper 2002,p.23

Romanianstudy papertitled "JI ‐ 

Project forreduction of

CO2 emissions

at Alesd

Cement PlantandCampulung

Reported previously for kilns

in Europe.

N N

Monthly 

availableprovided 

facilities 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

104 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Cement Plant"

Q 98.176(b) Annual production

quantity for products

Ex. S1: EPA‐HQ‐OAR‐

2004‐008‐0058 NucorPlymouth, p. 8/86 (pdf).Ex. S2, p.2/76 (pdf).

Stack testresults andassociatedrequirementsfor Title V

operationpermit forNucor Steel(PO box 100,

WestCemetery

Road,Plymouth UT

84330),

Previously publicly reported

Y N

Data avaStack tes

ferroalloy requirem

standardamount o

three yea

productiosource is availabili

SurveyResponse

Previously publicly reported

Y N

Data avaSurvey reproductio

hourly prbaghouse114 requHQ‐OAR‐evaluated 

analysis. 

Q

98.176(e)(1)

Carbon content of

process inputs to

determine CO2

emissions

Material safety datasheet (MSDS) (did notoffer a specific MSDS as

an example, but referred

to MSDS for coal or coke)

Materialsafety datasheet (MSDS)

Generally known (for coal, pet

coke, scrap, iron ore,

limestone, fluxes, etc.) fromMSDSs.

N N

Carbon c

not availa

material percent winformat

are requi

compone
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

105 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Q

98.176(e)(1)

Carbon content of

process outputs to

determine CO2

emissions

Material safety datasheet (MSDS) (did notoffer a specific sheet as

an example)

Materialsafety data

sheet (MSDS)

Generally known (for steels,

slag, etc.). From MSDSs.

N N

Carbon c

not availamaterial 

percent w

informat

are requi

compone

Q

98.176(e)(3)

Annual volume of

each type of gaseous

fuel used todetermine CO2

emissions (reportedseparately for eachtype in standardcubic feet)

Utility bills Not provided Known from utility bills, for

example

N N

Annual vfacility (nPart 98) w

Utility bilavailable

Q

98.176(e)(3)

Annual volume of

each type of liquid

fuel used to

determine CO2

emissions (reportedseparately for eachtype in gallons)

Utility bills Not provided Known from utility bills, for

example

N N

Volume oavailable

to the fac

supplier not gene

Q

98.176(e)(3)

Annual mass (in

metric tons) of each

all other process

inputs and outputsused to determine

CO 2 emissions

None Not provided This is too general. No need

for lesser contributing inputs

and outputs for the mass

balance. N N

No evide

Q

98.176(e)(4)

Molecular weight of

gaseous fuels

None Not provided Basic chemistry

N N

Molecula

is basic c

found in 

composit

the facilit
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

106 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Q

98.176(f)(1)

Measured averagehourly CO2 emission

rate during the test

None Not provided Direct Emissions Data

N N

No evide

Q

98.176(f)(2)

Average hourly feed

or production rate

Ex. S1: EPA‐HQ‐OAR‐

2004‐008‐0058 NucorPlymouth, p. 8/86 (pdf).

Stack test

results

Previously publicly reported

Y N

Data avaStack tes

ferroalloy requirem

standard

hourly fe

source is availabili

Q

98.176(f)(3)

Site‐specific emissionfactor

None Not provided Derived from calculation using

data above and below N N

Data elem

are requiare not p

Q

98.176(f)(4)

Annual feed or

production rate usedto estimate annualCO2 emissions

Ex. S1: EPA‐HQ‐OAR‐

2004‐008‐0058 NucorPlymouth, p. 8/86 (pdf).

Stack test

results

Previously publicly reported

N N

Data avaStack tes

ferroalloy requirem

standardamount o

three yea

productio

Q 98.176(g) The annual amount

of coal charged tothe coke ovens (inmetric tons).

Deliveries Not provided Can be ascertained by tracking

deliveries (trains, trucks, etc.

and by making reasonable

assumptions)

N N

No evide

Deliverie

available 

Q 98.176(h) For flares burning

coke oven gas or

blast furnace gas, the

information specifiedin §98.256(e) of

subpart Y (PetroleumRefineries) of this

part.1

See references at

98.256(e)

See references

at 98.256(e)

See refineries

See 98.256(e) See 98.256(e)

See 98.25

W 98.236(c)(1 )(i)

Actual count of

natural gas

pneumatic high

bleed devices.

National EmissionStandards (NESHAP)Subpart HH and NSPSSubpart KKK

Regulation EPA requires fugitive

emissions reporting for the oil

and gas industry under the

NationalEmission Standards for

N N

Subpart H

report in

equipmeprogram

bleed dev
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

107 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Hazardous Air Pollutants(NESHAP), Subpart HH for Oiland Gas and NSPS Subpart KKK

for gas processing plants.

in the rul

W 98.236(c)(1 )(i)

Estimated count of

natural gas

pneumatic high

bleed devices.

National EmissionStandards (NESHAP)Subpart HH and NSPSSubpart KKK

Regulation EPA requires fugitive

emissions reporting for the oil

and gas industry under the

NationalEmission Standards for

Hazardous Air Pollutants(NESHAP), Subpart HH for Oil

and Gas and NSPS Subpart KKK

for gas processing plants.

N N

Subpart H

report in

equipmeprogram

bleed devin the rul

W 98.236(c)(1 )(ii)

Actual count of

natural gas

pneumatic low bleed

devices.

National EmissionStandards (NESHAP)Subpart HH and NSPS

Subpart KKK

Regulation EPA requires fugitive

emissions reporting for the oil

and gas industry under the

NationalEmission Standards for

Hazardous Air Pollutants(NESHAP), Subpart HH for Oil

and Gas and NSPS Subpart KKK

for gas processing plants.

N N

Subpart H

report in

equipmeprogram

bleed devin the rul

W 98.236(c)(1 )(ii)

Estimated count of

natural gas

pneumatic low bleed

devices.

National EmissionStandards (NESHAP)Subpart HH and NSPS

Subpart KKK

Regulation EPA requires fugitive

emissions reporting for the oil

and gas industry under the

NationalEmission Standards for

Hazardous Air Pollutants(NESHAP), Subpart HH for Oil

and Gas and NSPS Subpart KKK

for gas processing plants.

N N

Subpart H

report in

equipmeprogram

bleed devin the rul

W 98.236(c)(1 )(iii)

Actual count of

natural gas

pneumaticintermittent bleed

devices.

National EmissionStandards (NESHAP)Subpart HH and NSPS

Subpart KKK

Regulation EPA requires fugitive

emissions reporting for the oil

and gas industry under the

NationalEmission Standards for

Hazardous Air Pollutants(NESHAP), Subpart HH for Oil

and Gas and NSPS Subpart KKK

N N

Subpart H

report in

equipmeprogramintermitt

specifica
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

108 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

for gas processing plants.

W 98.236(c)(1 )(iii)

Estimated count of

natural gas

pneumaticintermittent bleed

devices.

National EmissionStandards (NESHAP)Subpart HH and NSPS

Subpart KKK

Regulation EPA requires fugitive

emissions reporting for the oil

and gas industry under the

NationalEmission Standards for

Hazardous Air Pollutants(NESHAP), Subpart HH for Oil

and Gas and NSPS Subpart KKK

for gas processing plants.

N N

Subpart H

report in

equipmeprogramintermitt

specifica

W 98.236(c)(2 )(i) Count of natural gas driven pneumatic pumps.

National EmissionStandards (NESHAP)Subpart HH and NSPSSubpart KKK

Regulation EPA requires fugitive

emissions reporting for the oil

and gas industry under the

NationalEmission Standards for

Hazardous Air Pollutants(NESHAP), Subpart HH for Oil

and Gas and NSPS Subpart KKK

for gas processing plants.

N N

Subpart Hreport in

equipmeprogramequipme

type is no

evaluated see Appe

Attachment No. 5‐1BOEMRE AirEmissionReporting.pdf[Title 30: Mineral

Resources; PART 250—

OIL AND GAS ANDSULPHUR OPERATIONSIN THE OUTERCONTINENTAL SHELF;Subpart B—Plans andInformation; Contents of

Development andProduction Plans (DPP)

and DevelopmentOperations CoordinationDocuments (DOCD)]

eCFR;BOEMRERegulations at30 CFR

250.513

Y N

Data on n

collected 

facilities 

gulfwide evaluated see Appe
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

109 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

W 98.236(c)(3 )(i)

Total throughput of

each acid gas

removal unit using ameter or engineering

estimate based on

process knowledge

or best available

data.

Attachment No. 4‐1

North Dakota Amine Unit

Appl.PDF (PERMITAPPLICATION ‐ NATURALGAS PROCESSINGSWEETENINGOPERATIONS, NORTHDAKOTA DEPARTMENTOF HEALTH DIVISION OFAIR QUALITY)

Operating

PermitApplications

Some states require amine

unit data to be reported totheir department of publichealth, for example

N N

Data repounit, not 

New Source PerformanceStandard Subpart LL

Regulation Subpart LL requires reporting

for gas sweetening units and

sulfur recovery units.

N N

NSPS sub

performaProcessin

to oil and 

Attachment No. 5‐1BOEMRE AirEmissionReporting.pdf[Title 30: Mineral

Resources; PART 250—

OIL AND GAS ANDSULPHUR OPERATIONSIN THE OUTERCONTINENTAL SHELF;Subpart B—Plans andInformation; Contents of

Development andProduction Plans (DPP)

and DevelopmentOperations CoordinationDocuments (DOCD)]

eCFR;BOEMRERegulations at30 CFR

250.513

Y N

Throughp

publicly ainventory

public avB.
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

110 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

W 98.236(c)(3 )(ii)

For CalculationMethodology 2 of

§98.233(d), annualaverage fraction of

CO2 content in the

vent from each acid

gas removal unit.

Attachment No. 4‐1

North Dakota Amine Unit

Appl.PDF (PERMITAPPLICATION ‐ NATURALGAS PROCESSINGSWEETENINGOPERATIONS, NORTHDAKOTA DEPARTMENTOF HEALTH DIVISION OFAIR QUALITY)

OperatingPermitApplications

The CO2 content of the ventedgas in not proprietary business

data and will not create an

economic or strategicdisadvantage to a company ifdisclosed to the public at this

time. The CO2 content may bereported to local, state orfederal agencies as part of a

project description or bypermit

N N

Permit ap

concentr

concentr

W 98.236(c)(3 )(iii)

For CalculationMethodology 3 of§98.233(d), annualaverage volumefraction of CO2

content of natural

gas into each acidgas removal unit.

Attachment No. 4‐1North Dakota Amine Unit

Appl.PDF (PERMIT

APPLICATION ‐ NATURALGAS PROCESSING

SWEETENINGOPERATIONS, NORTHDAKOTA DEPARTMENT

OF HEALTH DIVISION OFAIR QUALITY)

OperatingPermitApplications

The CO2 content of the ventedgas in not proprietary business

data and will not create an

economic or strategicdisadvantage to a company ifdisclosed to the public at this

time. The CO2 content may bereported to local, state orfederal agencies as part of a

project description or bypermit

N N

Permit ap

concentr

concentr

W 98.236(c)(3 )(iv)

Annual quantity of

CO2, that was

recovered from each

acid gas removal unit

and transferredoutside the facility(metric tons CO2e),

under subpart PP of

this part.

Attachment No. 4‐1North Dakota Amine Unit

Appl.PDF (PERMIT

APPLICATION ‐ NATURALGAS PROCESSING

SWEETENINGOPERATIONS, NORTHDAKOTA DEPARTMENT

OF HEALTH DIVISION OFAIR QUALITY)

OperatingPermitApplications

The CO2 content of the ventedgas in not proprietary business

data and will not create aneconomic or strategic

disadvantage to a company ifdisclosed to the public at this

time. The CO2 content may bereported to local, state orfederal agencies as part of a

project description or bypermit

N N

Permit ap

reporting 

transferr

W 98.236(c)(4 )(i)(A)

For each glycol

dehydrator withthroughput greaterthan or equal to 0.4MMscfd: Glycol

Attachment No. 1‐5 UtahGas DispositionReport.pdf (State of Utah

Monthly Oil and GasDisposition Report)

Report Form Glycol dehydrator venting data

is typically reported to an airpermitting authority orincluded in the gas disposition

reports.

N N

Glycol derequired 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

111 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

dehydrator feednatural gas flow rate

in MMscfd,

determined by

engineering estimatebased on bestavailable data.

Attachment No. 1‐6

Louisiana Gas DispositionReport.pdf (State of

Louisiana Monthly Oiland Gas DispositionReport)

Report Form Glycol dehydrator venting data

is typically reported to an air

permitting authority orincluded in the gas disposition

reports.

N N

Glycol derequired 

Attachment No. 1‐7Alaska Gas Disposition

Reporting.xls (Alaska

Department of Revenue

(ADOR) AS 43.55Monthly InformationReport)

Report Form Glycol dehydrator venting data

is typically reported to an airpermitting authority orincluded in the gas dispositionreports.

N N

Glycol derequired 

Attachment No. 1‐9North Dakota Gas and

Composition.pdf(OIL/GAS PRODUCTION

FACILITY REGISTRATION,NORTH DAKOTADEPARTMENT OFHEALTH, DIVISION OF AIR

QUALITY)

OperatingPermitApplications

Glycol dehydrator venting datais typically reported to an airpermitting authority orincluded in the gas dispositionreports. N N

Glycol de

required 

Attachment No. 2‐6ColoradoAirPermitApp.PDF(Operating PermitApplication, ColoradoDepartment of PublicHealth and Environment,Air Pollution ControlDivision)

OperatingPermitApplications

Glycol dehydrator venting datais typically reported to an air

permitting authority orincluded in the gas dispositionreports. N N

Form 200Natural g

Data on r

(MMBtu/glycol typ

pressure, 

composit
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

112 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Attachment No. 5‐1BOEMRE AirEmissionReporting.pdf[Title 30: Mineral

Resources; PART 250—

OIL AND GAS ANDSULPHUR OPERATIONSIN THE OUTERCONTINENTAL SHELF;Subpart B—Plans andInformation; Contents of

Development andProduction Plans (DPP)

and DevelopmentOperations CoordinationDocuments (DOCD)]

eCFR;BOEMRERegulations at30 CFR

250.513

BOEMRE Regulations at 30 CFR

250.513 requires air emission

reporting, including the basis

for all

calculations

Y Y

Total gas 

Requires descriptioequipmecombuststorage u

evaluated 

see Appe

Attachment No. 5‐2ColoradoAirPermitApp.pdf(Operating PermitApplication; ColoradoDepartment of PublicHealth and EnvironmentAir Pollution ControlDivision)

OperatingPermitApplications

Colorado Department ofPublic Health and

Environment, Air Pollution

Control Division,Operating Permit Applications,requires detailed informationon gas dehydrator equipment

N N

Natural g

this appli

concerns regeneraglycol circontrol tetemperatrequired

Attachment No. 5‐3North DakotaGlycolDehydratorReport.pdf (PERMITAPPLICATION ‐ GLYCOLDEHYDRATION UNITS

NORTH DAKOTADEPARTMENT OFHEALTH DIVISION OF AIR

QUALITY)

OperatingPermitApplications

North Dakota Department of

Public Health, Division of AirQuality, Operating PermitApplications, requires detailed

information on gas dehydrator

equipment N N

This is a o

Actual th

the perm

annual repermit ap

report ththroughpglycol de

W 98.236(c)(4 )(i)(B)

For each glycol

dehydrator withthroughput greaterthan or equal to 0.4MMscfd: Glycol

Attachment No. 1‐5 UtahGas DispositionReport.pdf (State of Utah

Monthly Oil and GasDisposition Report)

Report Form Glycol dehydrator venting data

is typically reported to an airpermitting authority orincluded in the gas disposition

reports.

N N

Glycol depump typ
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

113 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

dehydratorabsorbent circulationpump type.

Attachment No. 1‐6Louisiana Gas DispositionReport.pdf (State ofLouisiana Monthly Oil

and Gas Disposition

Report)

Report Form Glycol dehydrator venting data

is typically reported to an air

permitting authority orincluded in the gas disposition

reports.

N N

Glycol de

pump typ

Attachment No. 1‐7Alaska Gas Disposition

Reporting.xls (Alaska

Department of Revenue

(ADOR) AS 43.55Monthly InformationReport)

Report Form Glycol dehydrator venting data

is typically reported to an airpermitting authority orincluded in the gas dispositionreports.

N N

Glycol depump typ

Attachment No. 1‐9North Dakota Gas and

Composition.pdf(OIL/GAS PRODUCTION

FACILITY REGISTRATION,NORTH DAKOTADEPARTMENT OFHEALTH, DIVISION OF AIR

QUALITY)

OperatingPermitApplications

Glycol dehydrator venting datais typically reported to an airpermitting authority orincluded in the gas dispositionreports. N N

Glycol depump typ

Attachment No. 2‐6ColoradoAirPermitApp.PDF(Operating PermitApplication, ColoradoDepartment of PublicHealth and Environment,Air Pollution ControlDivision)

OperatingPermitApplications

Glycol dehydrator venting datais typically reported to an air

permitting authority orincluded in the gas dispositionreports. N N

Glycol depump typ

applicatiodehydratheating rcirculatio

technolo

temperatrequired
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

114 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Attachment No. 5‐1BOEMRE AirEmissionReporting.pdf[Title 30: Mineral

Resources; PART 250—

OIL AND GAS ANDSULPHUR OPERATIONSIN THE OUTERCONTINENTAL SHELF;Subpart B—Plans andInformation; Contents of

Development andProduction Plans (DPP)

and DevelopmentOperations CoordinationDocuments (DOCD)]

eCFR;BOEMRERegulations at30 CFR

250.513

BOEMRE Regulations at 30 CFR

250.513 requires air emission

reporting, including the basis

for all

calculations

N N

Pump typRequires descriptioequipmecombuststorage u

Attachment No. 5‐2ColoradoAirPermitApp.pdf(Operating PermitApplication; ColoradoDepartment of PublicHealth and EnvironmentAir Pollution ControlDivision)

OperatingPermitApplications

Colorado Department ofPublic Health and

Environment, Air Pollution

Control Division,Operating Permit Applications,requires detailed informationon gas dehydrator equipment

N N

Pump typ

applicatio

dehydratheating rcirculatio

technolo

temperatrequired

Attachment No. 5‐3North DakotaGlycolDehydratorReport.pdf (PERMITAPPLICATION ‐ GLYCOLDEHYDRATION UNITS

NORTH DAKOTADEPARTMENT OFHEALTH DIVISION OF AIR

QUALITY)

OperatingPermitApplications

North Dakota Department of

Public Health, Division of AirQuality, Operating PermitApplications, requires detailed

information on gas dehydrator

equipment N N

Pump typ

applicatiorequires 

capacity, emission

W 98.236(c)(4 )(i)(C)

For each glycoldehydrator withthroughput greaterthan or equal to 0.4MMscfd: Report

Attachment No. 1‐5 UtahGas DispositionReport.pdf (State of Utah

Monthly Oil and GasDisposition Report)

Report Form Glycol dehydrator venting data

is typically reported to an airpermitting authority orincluded in the gas disposition

reports.

N N

Report d

glycol de
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

115 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

whether stripper gasis used in glycol

dehydrator.

Attachment No. 1‐6Louisiana Gas DispositionReport.pdf (State of

Louisiana Monthly Oiland Gas DispositionReport)

Report Form Glycol dehydrator venting data

is typically reported to an air

permitting authority orincluded in the gas disposition

reports.

N N

Report d

glycol de

Attachment No. 1‐7Alaska Gas Disposition

Reporting.xls (Alaska

Department of Revenue

(ADOR) AS 43.55Monthly InformationReport)

Report Form Glycol dehydrator venting data

is typically reported to an airpermitting authority orincluded in the gas dispositionreports.

N N

Report d

glycol de

Attachment No. 1‐9North Dakota Gas and

Composition.pdf(OIL/GAS PRODUCTION

FACILITY REGISTRATION,NORTH DAKOTADEPARTMENT OFHEALTH, DIVISION OF AIR

QUALITY)

OperatingPermitApplications

Glycol dehydrator venting datais typically reported to an airpermitting authority orincluded in the gas dispositionreports. N N

Report d

glycol de

Attachment No. 2‐6ColoradoAirPermitApp.PDF(Operating PermitApplication, ColoradoDepartment of PublicHealth and Environment,Air Pollution ControlDivision)

OperatingPermitApplications

Glycol dehydrator venting datais typically reported to an air

permitting authority orincluded in the gas dispositionreports. N N

Stripper g

the perm

concerns regeneraglycol circontrol tetemperatrequired
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

116 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Attachment No. 5‐1BOEMRE AirEmissionReporting.pdf[Title 30: Mineral

Resources; PART 250—

OIL AND GAS ANDSULPHUR OPERATIONSIN THE OUTERCONTINENTAL SHELF;Subpart B—Plans andInformation; Contents of

Development andProduction Plans (DPP)

and DevelopmentOperations CoordinationDocuments (DOCD)]

eCFR;BOEMRERegulations at30 CFR

250.513

BOEMRE Regulations at 30 CFR

250.513 requires air emission

reporting, including the basis

for all

calculations

Y N

Use of stpublicly a

inventory

public avB.

Attachment No. 5‐2ColoradoAirPermitApp.pdf(Operating PermitApplication; ColoradoDepartment of PublicHealth and EnvironmentAir Pollution ControlDivision)

OperatingPermitApplications

Colorado Department ofPublic Health and

Environment, Air Pollution

Control Division,Operating Permit Applications,requires detailed informationon gas dehydrator equipment

N N

The use othe perm

concerns regeneraglycol circontrol tetemperatrequired

Attachment No. 5‐3North DakotaGlycolDehydratorReport.pdf (PERMITAPPLICATION ‐ GLYCOLDEHYDRATION UNITS

NORTH DAKOTADEPARTMENT OFHEALTH DIVISION OF AIR

QUALITY)

OperatingPermitApplications

North Dakota Department of

Public Health, Division of AirQuality, Operating PermitApplications, requires detailed

information on gas dehydrator

equipment N N

The use o

the permapplicatio

the desig

and VOC 

dehydrat

W 98.236(c)(4 )(i)(D)

For each glycol

dehydrator withthroughput greaterthan or equal to 0.4MMscfd: Report

Attachment No. 1‐5 UtahGas DispositionReport.pdf (State of Utah

Monthly Oil and GasDisposition Report)

Report Form Glycol dehydrator venting data

is typically reported to an airpermitting authority orincluded in the gas disposition

reports.

N N

Report d

glycol de
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

117 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

whether a flash tank

separator is used inglycol dehydrator.

Attachment No. 1‐6Louisiana Gas DispositionReport.pdf (State of

Louisiana Monthly Oiland Gas DispositionReport)

Report Form Glycol dehydrator venting data

is typically reported to an air

permitting authority orincluded in the gas disposition

reports.

N N

Report d

glycol de

Attachment No. 1‐7Alaska Gas Disposition

Reporting.xls (Alaska

Department of Revenue

(ADOR) AS 43.55Monthly InformationReport)

Report Form Glycol dehydrator venting data

is typically reported to an airpermitting authority orincluded in the gas dispositionreports.

N N

Report d

glycol de

Attachment No. 1‐9North Dakota Gas and

Composition.pdf(OIL/GAS PRODUCTION

FACILITY REGISTRATION,NORTH DAKOTADEPARTMENT OFHEALTH, DIVISION OF AIR

QUALITY)

OperatingPermitApplications

Glycol dehydrator venting datais typically reported to an airpermitting authority orincluded in the gas dispositionreports. N N

Report d

glycol de

Attachment No. 2‐6 andAttachment No. 5‐2.

ColoradoAirPermitApp.PDF(Operating PermitApplication, ColoradoDepartment of PublicHealth and Environment,Air Pollution Control

Division)

OperatingPermitApplications

Glycol dehydrator venting datais typically reported to an airpermitting authority orincluded in the gas dispositionreports. Y N

Data elem

permit apmajority 

concerns 

tank is reelement analysis, 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

118 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Attachment No. 5‐1BOEMRE AirEmissionReporting.pdf[Title 30: Mineral

Resources; PART 250—

OIL AND GAS ANDSULPHUR OPERATIONSIN THE OUTERCONTINENTAL SHELF;Subpart B—Plans andInformation; Contents of

Development andProduction Plans (DPP)

and DevelopmentOperations CoordinationDocuments (DOCD)]

eCFR;BOEMRERegulations at30 CFR

250.513

BOEMRE Regulations at 30 CFR

250.513 requires air emission

reporting, including the basis

for all

calculations

Y N

Use of a f

but is not gulfwide 

evaluated see Appe

Attachment No. 5‐3North DakotaGlycolDehydratorReport.pdf (PERMITAPPLICATION ‐ GLYCOLDEHYDRATION UNITS

NORTH DAKOTADEPARTMENT OFHEALTH DIVISION OF AIR

QUALITY)

OperatingPermitApplications

North Dakota Department of

Public Health, Division of AirQuality, Operating PermitApplications, requires detailed

information on gas dehydrator

equipment N N

Use of a f

permit apreport ththroughpglycol de

W 98.236(c)(4 )(i)(E)

For each glycol

dehydrator withthroughput greaterthan or equal to 0.4MMscfd: Report type

of absorbent.

Attachment No. 1‐5 UtahGas DispositionReport.pdf (State of Utah

Monthly Oil and GasDisposition Report)

Report Form Glycol dehydrator venting data

is typically reported to an airpermitting authority or

included in the gas dispositionreports.

N N

Report d

glycol de

Attachment No. 1‐6Louisiana Gas DispositionReport.pdf (State ofLouisiana Monthly Oil

and Gas DispositionReport)

Report Form Glycol dehydrator venting data

is typically reported to an airpermitting authority orincluded in the gas dispositionreports.

N N

Report d

glycol de
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

119 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Attachment No. 1‐7Alaska Gas Disposition

Reporting.xls (Alaska

Department of Revenue

(ADOR) AS 43.55Monthly InformationReport)

Report Form Glycol dehydrator venting data

is typically reported to an airpermitting authority orincluded in the gas dispositionreports.

N N

Report d

glycol de

Attachment No. 1‐9North Dakota Gas and

Composition.pdf(OIL/GAS PRODUCTION

FACILITY REGISTRATION,NORTH DAKOTADEPARTMENT OFHEALTH, DIVISION OF AIR

QUALITY)

OperatingPermitApplications

Glycol dehydrator venting datais typically reported to an airpermitting authority orincluded in the gas dispositionreports. N N

Report d

glycol de

Attachment No. 2‐6 andAttachment No. 5‐2.

ColoradoAirPermitApp.PDF(Operating Permit

Application, ColoradoDepartment of PublicHealth and Environment,Air Pollution Control

Division)

OperatingPermitApplications

Glycol dehydrator venting datais typically reported to an airpermitting authority orincluded in the gas dispositionreports. Y N

Permit ap

reporters 

reporters

dehydrat

Data eva

analysis, 

Attachment No. 5‐1BOEMRE AirEmissionReporting.pdf[Title 30: Mineral

Resources; PART 250—

OIL AND GAS ANDSULPHUR OPERATIONSIN THE OUTERCONTINENTAL SHELF;Subpart B—Plans andInformation; Contents of

Development andProduction Plans (DPP)

and Development

eCFR;BOEMRERegulations at30 CFR

250.513

BOEMRE Regulations at 30 CFR250.513 requires air emission

reporting, including the basis

for all

calculations

N N

Type of gassumed operator processecombuststorage u
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

120 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Operations CoordinationDocuments (DOCD)]Attachment No. 5‐3North DakotaGlycolDehydratorReport.pdf (PERMITAPPLICATION ‐ GLYCOLDEHYDRATION UNITS

NORTH DAKOTADEPARTMENT OFHEALTH DIVISION OF AIR

QUALITY)

OperatingPermitApplications

North Dakota Department of

Public Health, Division of AirQuality, Operating PermitApplications, requires detailed

information on gas dehydrator

equipment Y N

Permit ap

reporters 

reportersappears t

requires 

capacity, emission

W 98.236(c)(4 )(i)(F)

For each glycol

dehydrator withthroughput greaterthan or equal to 0.4MMscfd: Total time

the glycol dehydrator

is operating in hours.

Attachment No. 1‐5 UtahGas DispositionReport.pdf (State of Utah

Monthly Oil and GasDisposition Report)

Report Form Glycol dehydrator venting data

is typically reported to an air

permitting authority orincluded in the gas dispositionreports.

N N

Report d

glycol de

Attachment No. 1‐6Louisiana Gas DispositionReport.pdf (State ofLouisiana Monthly Oil

and Gas DispositionReport)

Report Form Glycol dehydrator venting data

is typically reported to an airpermitting authority orincluded in the gas dispositionreports.

N N

Report d

glycol de

Attachment No. 1‐7Alaska Gas Disposition

Reporting.xls (Alaska

Department of Revenue

(ADOR) AS 43.55Monthly InformationReport)

Report Form Glycol dehydrator venting data

is typically reported to an airpermitting authority orincluded in the gas dispositionreports.

N N

Report d

glycol de
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

121 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Attachment No. 1‐9North Dakota Gas and

Composition.pdf(OIL/GAS PRODUCTION

FACILITY REGISTRATION,NORTH DAKOTADEPARTMENT OFHEALTH, DIVISION OF AIR

QUALITY)

OperatingPermitApplications

Glycol dehydrator venting datais typically reported to an airpermitting authority orincluded in the gas dispositionreports. N N

Report d

glycol de

Attachment No. 2‐6 andAttachment No. 5‐2.

ColoradoAirPermitApp.PDF(Operating PermitApplication, ColoradoDepartment of PublicHealth and Environment,Air Pollution Control

Division)

OperatingPermitApplications

Glycol dehydrator venting datais typically reported to an airpermitting authority orincluded in the gas dispositionreports. N N

Form 200

Actual timnot repo

Attachment No. 5‐1BOEMRE AirEmissionReporting.pdf[Title 30: Mineral

Resources; PART 250—

OIL AND GAS ANDSULPHUR OPERATIONSIN THE OUTERCONTINENTAL SHELF;Subpart B—Plans andInformation; Contents of

Development andProduction Plans (DPP)

and DevelopmentOperations CoordinationDocuments (DOCD)]

eCFR;BOEMRERegulations at30 CFR

250.513

BOEMRE Regulations at 30 CFR

250.513 requires air emission

reporting, including the basis

for all

calculations

N N

Time unit emissionvolume, 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

122 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Attachment No. 5‐3North DakotaGlycolDehydratorReport.pdf (PERMITAPPLICATION ‐ GLYCOLDEHYDRATION UNITS

NORTH DAKOTADEPARTMENT OFHEALTH DIVISION OF AIR

QUALITY)

OperatingPermitApplications

North Dakota Department of

Public Health, Division of AirQuality, Operating PermitApplications, requires detailed

information on gas dehydrator

equipment N N

Actual tim

annually 

Form req

design caVOC emisunits.

W 98.236(c)(4 )(i)(G)

For each glycol

dehydrator withthroughput greaterthan or equal to 0.4MMscfd:Temperature of thewet natural gas(degrees Fahrenheit).

Attachment No. 1‐5 Utah

Gas DispositionReport.pdf (State of Utah

Monthly Oil and GasDisposition Report)

Report Form Glycol dehydrator venting data

is typically reported to an air

permitting authority orincluded in the gas dispositionreports.

N N

Report d

glycol de

Attachment No. 1‐6Louisiana Gas DispositionReport.pdf (State ofLouisiana Monthly Oil

and Gas DispositionReport)

Report Form Glycol dehydrator venting data

is typically reported to an airpermitting authority orincluded in the gas dispositionreports.

N N

Report d

glycol de

Attachment No. 1‐7Alaska Gas Disposition

Reporting.xls (Alaska

Department of Revenue

(ADOR) AS 43.55Monthly InformationReport)

Report Form Glycol dehydrator venting data

is typically reported to an airpermitting authority orincluded in the gas dispositionreports.

N N

Report d

glycol de

Attachment No. 1‐9North Dakota Gas and

Composition.pdf(OIL/GAS PRODUCTION

FACILITY REGISTRATION,NORTH DAKOTADEPARTMENT OFHEALTH, DIVISION OF AIR

QUALITY)

OperatingPermitApplications

Glycol dehydrator venting datais typically reported to an airpermitting authority orincluded in the gas dispositionreports. N N

Report d

glycol de
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

123 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Attachment No. 2‐6ColoradoAirPermitApp.PDF(Operating PermitApplication, ColoradoDepartment of PublicHealth and Environment,Air Pollution ControlDivision)

OperatingPermitApplications

Glycol dehydrator venting datais typically reported to an air

permitting authority orincluded in the gas dispositionreports. N N

Form 200Gas temp

annual re

data on r

(MMBtu/glycol typ

pressure, 

composit

Attachment No. 5‐1BOEMRE AirEmissionReporting.pdf[Title 30: Mineral

Resources; PART 250—

OIL AND GAS ANDSULPHUR OPERATIONSIN THE OUTERCONTINENTAL SHELF;Subpart B—Plans andInformation; Contents of

Development andProduction Plans (DPP)

and DevelopmentOperations CoordinationDocuments (DOCD)]

eCFR;BOEMRERegulations at30 CFR

250.513

BOEMRE Regulations at 30 CFR

250.513 requires air emission

reporting, including the basis

for all

calculations

Y N

Wet gas t

BOEM, b

the gulfw

evaluated see Appe

Attachment No. 5‐2ColoradoAirPermitApp.pdf(Operating PermitApplication; ColoradoDepartment of PublicHealth and EnvironmentAir Pollution ControlDivision)

OperatingPermitApplications

Colorado Department ofPublic Health and

Environment, Air Pollution

Control Division,Operating Permit Applications,requires detailed informationon gas dehydrator equipment

N N

Form 200Annual re

not requregeneraglycol circontrol tetemperatrequired

Attachment No. 5‐3North DakotaGlycolDehydratorReport.pdf (PERMITAPPLICATION ‐ GLYCOLDEHYDRATION UNITS

OperatingPermitApplications

North Dakota Department of

Public Health, Division of AirQuality, Operating PermitApplications, requires detailed

information on gas dehydrator

equipment

N N

Gas temppermit apreport th

throughpglycol de
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

124 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

NORTH DAKOTADEPARTMENT OFHEALTH DIVISION OF AIRQUALITY)

W 98.236(c)(4 )(i)(G)

For each glycol

dehydrator withthroughput greaterthan or equal to 0.4MMscfd: Pressure of

the wet natural gas

(psig).

Attachment No. 1‐5 UtahGas DispositionReport.pdf (State of Utah

Monthly Oil and GasDisposition Report)

Report Form Glycol dehydrator venting data

is typically reported to an air

permitting authority orincluded in the gas dispositionreports.

N N

Report d

glycol de

Attachment No. 1‐6Louisiana Gas DispositionReport.pdf (State ofLouisiana Monthly Oil

and Gas DispositionReport)

Report Form Glycol dehydrator venting data

is typically reported to an airpermitting authority orincluded in the gas dispositionreports.

N N

Report d

glycol de

Attachment No. 1‐7Alaska Gas Disposition

Reporting.xls (Alaska

Department of Revenue

(ADOR) AS 43.55Monthly InformationReport)

Report Form Glycol dehydrator venting data

is typically reported to an airpermitting authority orincluded in the gas dispositionreports.

N N

Report d

glycol de

Attachment No. 1‐9North Dakota Gas and

Composition.pdf(OIL/GAS PRODUCTION

FACILITY REGISTRATION,NORTH DAKOTADEPARTMENT OFHEALTH, DIVISION OF AIR

QUALITY)

OperatingPermitApplications

Glycol dehydrator venting datais typically reported to an airpermitting authority orincluded in the gas dispositionreports. N N

Report d

glycol de

Attachment No. 2‐6 andAttachment 5‐2.

ColoradoAirPermitApp.PDF(Operating PermitApplication, ColoradoDepartment of Public

Operating

PermitApplications

Glycol dehydrator venting datais typically reported to an airpermitting authority orincluded in the gas dispositionreports.

N N

Gas press

reporting 

307 concrequires 

heating rcirculatio

technolo
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

125 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Health and Environment,Air Pollution Control

Division)

temperatrequired

Attachment No. 5‐1BOEMRE AirEmissionReporting.pdf[Title 30: Mineral

Resources; PART 250—

OIL AND GAS ANDSULPHUR OPERATIONSIN THE OUTERCONTINENTAL SHELF;Subpart B—Plans andInformation; Contents of

Development andProduction Plans (DPP)

and DevelopmentOperations CoordinationDocuments (DOCD)]

eCFR;BOEMRERegulations at30 CFR

250.513

BOEMRE Regulations at 30 CFR

250.513 requires air emission

reporting, including the basis

for all

calculations

Y N

Pressure element 

analysis, 

Attachment No. 5‐3North DakotaGlycolDehydratorReport.pdf (PERMITAPPLICATION ‐ GLYCOLDEHYDRATION UNITS

NORTH DAKOTADEPARTMENT OFHEALTH DIVISION OF AIR

QUALITY)

OperatingPermitApplications

North Dakota Department of

Public Health, Division of AirQuality, Operating PermitApplications, requires detailed

information on gas dehydrator

equipment N N

Gas press

applicatio

the desigand VOC 

dehydrat

W 98.236(c)(4 )(i)(H)

For each glycoldehydrator withthroughput greaterthan or equal to 0.4MMscfd:

Attachment No. 1‐5 UtahGas DispositionReport.pdf (State of Utah

Monthly Oil and GasDisposition Report)

Report Form Glycol dehydrator venting data

is typically reported to an airpermitting authority orincluded in the gas disposition

reports.

N N

Report d

glycol de
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

126 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Concentration of CO2

in wet natural gas.

Attachment No. 1‐6Louisiana Gas DispositionReport.pdf (State of

Louisiana Monthly Oiland Gas DispositionReport)

Report Form Glycol dehydrator venting data

is typically reported to an air

permitting authority orincluded in the gas dispositionreports.

N N

Report d

glycol de

Attachment No. 1‐7Alaska Gas Disposition

Reporting.xls (Alaska

Department of Revenue

(ADOR) AS 43.55Monthly InformationReport)

Report Form Glycol dehydrator venting data

is typically reported to an airpermitting authority orincluded in the gas dispositionreports.

N N

Report d

glycol de

Attachment No. 1‐9North Dakota Gas and

Composition.pdf(OIL/GAS PRODUCTION

FACILITY REGISTRATION,NORTH DAKOTADEPARTMENT OFHEALTH, DIVISION OF AIR

QUALITY)

OperatingPermitApplications

Glycol dehydrator venting datais typically reported to an airpermitting authority orincluded in the gas dispositionreports. N N

Report d

glycol de

Attachment No. 2‐6ColoradoAirPermitApp.PDF(Operating PermitApplication, ColoradoDepartment of PublicHealth and Environment,Air Pollution ControlDivision)

OperatingPermitApplications

Glycol dehydrator venting datais typically reported to an air

permitting authority orincluded in the gas dispositionreports. N N

Gas inlet applicatio

required

dehydratregeneraglycol cir

control tetemperatrequired

Attachment No. 2‐9 BLMTestData.pdf (Title 43:Public Lands: Interior;

PART 3160—ONSHOREOIL AND GASOPERATIONS; Subpart

3162—Requirements forOperating Rights Ownersand Operators)

eCFR; BLM

Regulations at43 CFR

3162.4‐1

Glycol dehydrator venting datais typically reported to an airpermitting authority orincluded in the gas disposition

reports. Y B

Gas comp

required 

completirequired

recurring is publiclevaluated 

see Appe
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

127 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Attachment No. 5‐1BOEMRE AirEmissionReporting.pdf[Title 30: Mineral

Resources; PART 250—

OIL AND GAS ANDSULPHUR OPERATIONSIN THE OUTERCONTINENTAL SHELF;Subpart B—Plans andInformation; Contents of

Development andProduction Plans (DPP)

and DevelopmentOperations CoordinationDocuments (DOCD)]

eCFR;BOEMRERegulations at30 CFR

250.513

BOEMRE Regulations at 30 CFR

250.513 requires air emission

reporting, including the basis

for all

calculations

N N

Gas comp

referenceanalysis i

Attachment No. 5‐2ColoradoAirPermitApp.pdf(Operating PermitApplication; ColoradoDepartment of PublicHealth and EnvironmentAir Pollution ControlDivision)

OperatingPermitApplications

Colorado Department ofPublic Health and

Environment, Air Pollution

Control Division,Operating Permit Applications,requires detailed informationon gas dehydrator equipment

N N

Gas inlet 

applicatio

required

dehydrat

data on r

(MMBtu/glycol typ

pressure, 

composit

Attachment No. 5‐3North DakotaGlycolDehydratorReport.pdf (PERMITAPPLICATION ‐ GLYCOLDEHYDRATION UNITS

NORTH DAKOTADEPARTMENT OFHEALTH DIVISION OF AIR

QUALITY)

OperatingPermitApplications

North Dakota Department of

Public Health, Division of AirQuality, Operating PermitApplications, requires detailed

information on gas dehydrator

equipment N N

Gas comp

permit ap

applicatio

the desigand VOC 

dehydrat

W 98.236(c)(4 )(i)(H)

For each glycoldehydrator withthroughput greaterthan or equal to 0.4MMscfd:

Attachment No. 1‐5 UtahGas DispositionReport.pdf (State of Utah

Monthly Oil and GasDisposition Report)

Report Form Glycol dehydrator venting data

is typically reported to an airpermitting authority orincluded in the gas disposition

reports.

N N

Report d

glycol de
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

128 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Concentration of CH4

in wet natural gas.

Attachment No. 1‐6Louisiana Gas Disposition

Report.pdf (State ofLouisiana Monthly Oil

and Gas DispositionReport)

Report Form Glycol dehydrator venting data

is typically reported to an air

permitting authority orincluded in the gas dispositionreports.

N N

Report d

glycol de

Attachment No. 1‐7Alaska Gas Disposition

Reporting.xls (Alaska

Department of Revenue

(ADOR) AS 43.55Monthly InformationReport)

Report Form Glycol dehydrator venting data

is typically reported to an airpermitting authority orincluded in the gas dispositionreports.

N N

Report d

glycol de

Attachment No. 1‐9North Dakota Gas and

Composition.pdf(OIL/GAS PRODUCTION

FACILITY REGISTRATION,NORTH DAKOTADEPARTMENT OFHEALTH, DIVISION OF AIR

QUALITY)

OperatingPermitApplications

Glycol dehydrator venting datais typically reported to an airpermitting authority orincluded in the gas dispositionreports. N N

Report d

glycol de

Attachment No. 2‐6 andAttachment 5‐2.

ColoradoAirPermitApp.PDF(Operating Permit

Application, ColoradoDepartment of PublicHealth and Environment,Air Pollution Control

Division)

OperatingPermitApplications

Glycol dehydrator venting datais typically reported to an airpermitting authority orincluded in the gas dispositionreports. N N

Applicati

only. Gas for the ap

required

dehydrat

data on r

(MMBtu/glycol typ

pressure, 

composit
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

129 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Attachment No. 5‐1BOEMRE AirEmissionReporting.pdf[Title 30: Mineral

Resources; PART 250—

OIL AND GAS ANDSULPHUR OPERATIONSIN THE OUTERCONTINENTAL SHELF;Subpart B—Plans andInformation; Contents of

Development andProduction Plans (DPP)

and DevelopmentOperations CoordinationDocuments (DOCD)]

eCFR;BOEMRERegulations at30 CFR

250.513

BOEMRE Regulations at 30 CFR

250.513 requires air emission

reporting, including the basis

for all

calculations

N N

Gas comp

surrogate 

estimate

Attachment No. 5‐3North DakotaGlycolDehydratorReport.pdf (PERMITAPPLICATION ‐ GLYCOLDEHYDRATION UNITS

NORTH DAKOTADEPARTMENT OFHEALTH DIVISION OF AIR

QUALITY)

OperatingPermitApplications

North Dakota Department of

Public Health, Division of AirQuality, Operating PermitApplications, requires detailed

information on gas dehydrator

equipment N N

Gas comppermit ap

report ththroughpglycol de

W 98.236(c)(4 )(ii)(A)

For all glycol

dehydrator withthroughput less than

0.4 MMscfd: Count

of glycoldehydrators.

Attachment No. 1‐5 UtahGas DispositionReport.pdf (State of Utah

Monthly Oil and GasDisposition Report)

Report Form Glycol dehydrator venting data

is typically reported to an airpermitting authority orincluded in the gas disposition

reports.

N N

Report d

glycol de

Attachment No. 1‐6Louisiana Gas DispositionReport.pdf (State ofLouisiana Monthly Oil

and Gas DispositionReport)

Report Form Glycol dehydrator venting data

is typically reported to an airpermitting authority orincluded in the gas dispositionreports.

N N

Report d

glycol de
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

130 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Attachment No. 1‐7Alaska Gas Disposition

Reporting.xls (Alaska

Department of Revenue

(ADOR) AS 43.55Monthly InformationReport)

Report Form Glycol dehydrator venting data

is typically reported to an airpermitting authority orincluded in the gas dispositionreports.

N N

Report d

glycol de

Attachment No. 1‐9North Dakota Gas and

Composition.pdf(OIL/GAS PRODUCTION

FACILITY REGISTRATION,NORTH DAKOTADEPARTMENT OFHEALTH, DIVISION OF AIR

QUALITY)

OperatingPermitApplications

Glycol dehydrator venting datais typically reported to an airpermitting authority orincluded in the gas dispositionreports. N N

Report d

glycol de

Attachment No. 2‐6 andAttachment 5‐2.

ColoradoAirPermitApp.PDF(Operating Permit

Application, ColoradoDepartment of PublicHealth and Environment,Air Pollution Control

Division)

OperatingPermitApplications

Colorado Department ofPublic Health and

Environment, Air Pollution

Control Division,Operating Permit Applications,requires detailed informationon gas dehydrator equipment

Y N

Permit ap

reporters 

reporters

dehydratpermittepublic avB.

Attachment No. 5‐1BOEMRE AirEmissionReporting.pdf[Title 30: Mineral

Resources; PART 250—

OIL AND GAS ANDSULPHUR OPERATIONSIN THE OUTERCONTINENTAL SHELF;Subpart B—Plans andInformation; Contents of

Development andProduction Plans (DPP)

and Development

eCFR;BOEMRERegulations at30 CFR

250.513

BOEMRE Regulations at 30 CFR250.513 requires air emission

reporting, including the basis

for all

calculations

Y N

Number reported 

of report

public avB.
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

131 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Operations CoordinationDocuments (DOCD)]Attachment No. 5‐3North DakotaGlycolDehydratorReport.pdf (PERMITAPPLICATION ‐ GLYCOLDEHYDRATION UNITS

NORTH DAKOTADEPARTMENT OFHEALTH DIVISION OF AIR

QUALITY)

OperatingPermitApplications

North Dakota Department of

Public Health, Division of AirQuality, Operating PermitApplications, requires detailed

information on gas dehydrator

equipment Y N

Permit ap

reporters 

reportersis reportepublic avB. .

W 98.236(c)(6 )(i)(B)

For well completions

and workovers with

hydraulic fracturing,

report the followingfor each sub‐basin

and well type(horizontal orvertical)combination: When

using Equation W‐

10A, measured flow

rate of backflow

during wellcompletion (cubic

feet per hour).

Attachment No. 2‐4ADNR WellReporting.pdf

(State of Alaska DNR,

Division of Oil and Gas,Well Data Submittal

RequirementJanuary 2011)

Reportingrequirements Alaska Department of Natural

Resources (ADNR) requires

well record and completion

reporting,including casing size, flowrates and records of

stimulation and workover

activities and

information on oil and gas

composition

N N

Reportinparamete

but does measurewell com
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

132 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

W 98.236(c)(6 )(i)(E)

For well completions

and workovers with

hydraulic fracturing,

report the followingfor each sub‐basin

and well type(horizontal orvertical)combination: When

using Equation W‐

10A, total number ofdays of backflow

from all wells duringcompletions.

Attachment No. 2‐3 NYS

DrillingCompletionReport.pdf (NEW YORK STATEDEPARTMENT OF

ENVIRONMENTALCONSERVATION,

DIVISION OF MINERAL

RESOURCES, BUREAU OF

OIL AND GASREGULATION WELLDRILLING ANDCOMPLETION REPORT)

Report Form New York State Department of

Environmental Conservation

(NYSDEC) requires well recordandcompletion reporting,including casing size, flowrates and records of

stimulation and workoveractivities

N N

Report re

commencompletinot requ

Attachment No. 5‐1BOEMRE AirEmissionReporting.pdf[Title 30: Mineral

Resources; PART 250—

OIL AND GAS ANDSULPHUR OPERATIONSIN THE OUTERCONTINENTAL SHELF;Subpart B—Plans andInformation; Contents of

Development andProduction Plans (DPP)

and DevelopmentOperations CoordinationDocuments (DOCD)]

eCFR;BOEMRERegulations at30 CFR

250.513

BOEMRE Regulations at 30 CFR

250.513 require reporting of

well completion operations

N N

Number specifica
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

133 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Attachment No. 7‐1Wyoming WellCompletion Report.pdf

(WY ‐ EXAMPLE WELLCOMPLETIONS (“GREEN

COMPLETIONS”) PERMIT

– March 2010)

examplePermit

Wyoming requires detailedinformation on well ventingand a “green completions”permit(Attachment No. 7‐1),

including records identifying

and summarizing totalvolumes of hydrocarbon

liquids (bbls) and natural gas

(MMCF) recovered (flared,

vented, stored in tanks,pits, trucks or othercontainment, or sold togathering lines, storage or

containment vessels or

trucks) from the well bore

during completion/re‐

completion activities,maintained on a per wellbasis.

N N

Total num

specificatotal emi

and com

W 98.236(c)(6 )(ii)(A)

For well completions

and workoverswithout hydraulic

fracturing, report the

following for each

sub‐basin and welltype (horizontal or

vertical)combination: Totalcount of completions

in calendar year.

Attachment No. 2‐1 TRRC

DrillingCompletionReport.pdf (RAILROAD

COMMISSION OF TEXAS

Summary of Drilling,

Completion and PluggingReports Processed

January 2009)

MonthlySummaryReport

Texas Rail Road Commission(TRRC), Summary of Drilling,

Completion and PluggingReports showing thatoperators report drilling andcompletion activity data.

N N

Number 

monthly 

not repoinformat

Attachment No. 2‐2 PADrillingCompletionReportingReq.pdf (State of

Pennsylvania Well

Reporting Rule)

Reporting Rule Pennsylvania Department of

Environmental Quality (DEQ)

requires well record andcompletion reporting,

including casing size, flowrates and records of

stimulation and workover

activities.See 25 PA Code Chapter 78(§§78.121 Annual ProductionReport ‐78.122 Well Record

and

Y N

Well com

for a maj
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

134 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Completion Report)

Attachment No. 2‐3 NYSDrillingCompletionReport.pdf (NEW YORK STATEDEPARTMENT OFENVIRONMENTALCONSERVATION,DIVISION OF MINERAL

RESOURCES, BUREAU OF

OIL AND GASREGULATION WELLDRILLING ANDCOMPLETION REPORT)

Report Form New York State Department of

Environmental Conservation

(NYSDEC) requires well recordandcompletion reporting,including casing size, flowrates and records of

stimulation and workover

activities

Y N

Well com

for a maj

Attachment No. 2‐4ADNR WellReporting.pdf(State of Alaska DNR,Division of Oil and Gas,

Well Data Submittal

RequirementJanuary 2011)

Report form Alaska Department of Natural

Resources (ADNR) requires

well record and completion

reporting,including casing size, flowrates and records of

stimulation and workover

activities andinformation on oil and gas

composition

Y N

Well com

for a maj

Attachment No. 2‐7BOEMREDrillComplReportReq.pdf(Title 30: Mineral

Resources; PART 250—OIL AND GAS ANDSULPHUR OPERATIONSIN THE OUTERCONTINENTAL SHELF;

Subpart E—Oil and GasWell‐Completion

eCFR;BOEMRERegulations at30 CFR

250.513

BOEMRE Regulations at 30 CFR250.513 require reporting of

well completion operations

Y N

Well com

but are ngulfwide evaluated see Appe
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

135 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Operations)Attachment No. 2‐8 BLMDrillComplReport.pdf(Title 43: Public Lands:Interior; PART 3160—

ONSHORE OIL AND GAS

OPERATIONS; Subpart

3162—Requirements forOperating Rights Ownersand Operators)

eCFR; BLM

Regulations at43 CFR

3162.4‐1

BLM Regulations at 43 CFR

3162.4‐1 require reporting of

well completion operations

Y N

Well com

on a recu

data is fo

Attachment No. 2‐10 APIQuarterlyWellCompletionReportAd.pdf (API product

description)

website The American Petroleum

Institute (API) compiles and

reports publically availabledata on wellcompletion activity in itsQuarterly Well CompletionReport

Y N

No indicarecurring 

reported estimate

and foota

recent qu

in public Appendix 

W 98.236(c)(6

)(ii)(B)

For well completions

and workoverswithout hydraulic

fracturing, report the

following for each

sub‐basin and welltype (horizontal or

vertical)combination: Totalcount of workovers

in calendar year thatflare gas or vent gas

Attachment No. 1‐8 MMSCFRFuelFlareReporting.pdf(Bureau of Ocean Energy

Management (BOEMRE)

reporting rule)

eCFR; title 30,Part 250.Subpart K;250.1163 N N

Records 

gas is flar

required

Attachment No. 7‐1Wyoming WellCompletion Report.pdf

(WY ‐ EXAMPLE WELLCOMPLETIONS (“GREEN

COMPLETIONS”) PERMIT

Report Wyoming requires detailed

information on well venting

and a “green completions”permit N N

Total cou

required, 

required 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

136 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

to the atmosphere. – March 2010)

Attachment No. 7‐2 TRCCGasVentReport.pdf(STATEWIDE RULE 32EXCEPTION DATA SHEET)

Regulation Texas Rail Road Commission

(TRRC), requires detailed

information on well venting

and flaring N N

Permit m

venting obe given. 

reported

extracted 

reported

W 98.236(c)(7 )(i)(A)

For blowdown vent

stack emissionsource, for eachunique physical

volume that is blown

down more than

once during the

calendar year: Totalnumber ofblowdowns for each

unique physical

volume in thecalendar year. (when

using Eq. W‐14A)

Attachment No. 1‐10

Wyoming BlowdownVent

Permit.pdf (STATE OF

WYOMING, Department

of Environmental Quality

‐ Air Quality Division,Blowdown/VentingPermit Application)

Blowdown/Venting PermitApplication

Wyoming requires detailsinformation on blowdown and

other gas venting

N N

Emissions 

blowdowsummary reported

W 98.236(c)(8 )(i)(F)

For wellhead gas‐liquid separator with

oil throughputgreater than or equal

to 10 barrels per day,

using Calculation

Methodology 1 and 2

of 40 CFR 98.233(j),

report by sub‐basin

category: Total

volume of oil from all

wellhead separators

sent to tank(s) inbarrels per year.

Attachment No. 1‐9

North Dakota Gas and

Composition.pdf(OIL/GAS PRODUCTION

FACILITY REGISTRATION,NORTH DAKOTADEPARTMENT OFHEALTH, DIVISION OF AIR

QUALITY)

OperatingPermitApplications

North Dakota Department of

Public Health, Division of AirQuality, Operating PermitApplications, requires detailedinformation on tanks.

N N

Permit do

volume o
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

137 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

W 98.236(c)(8 )(i)(K)

For wellhead gas‐

liquid separator with

oil throughputgreater than or equal

to 10 barrels per day,

using Calculation

Methodology 1 of 40CFR 98.233(j), reportby sub‐basin

category: Annual CO2

gas quantities thatwere recovered(metric tons CO2e),

for all wellhead gas‐liquid separators orstorage tanks using

CalculationMethodology 1 of§98.233(j).

Attachment No. 1‐9North Dakota Gas and

Composition.pdf(OIL/GAS PRODUCTION

FACILITY REGISTRATION,NORTH DAKOTADEPARTMENT OFHEALTH, DIVISION OF AIR

QUALITY)

OperatingPermitApplications

North Dakota Department of

Public Health, Division of AirQuality, Operating Permit

Applications, requires detailed

information on tanks.

N N

Permit retank gas 

annual re

W 98.236(c)(8

)(ii)(A)

For wells with oil

production greater

than or equal to 10

barrels per day, using

CalculationMethodology 3 and 4

of 40 CFR 98.233(j),

report the followingby sub‐basin

category: Total

volume of sales oilfrom all wells

(barrels per year).

Attachment No. 1‐5 UtahGas Disposition

Report.pdf (State of Utah

Monthly Oil and GasDisposition Report)

Gasdispositionreport

Gas disposition reports state

whether the gas was produced

and sold, used as fuel, flaredor vented. There are differentroyalty and tax treatments forvarious gas disposition

methods. And, in some states

flared and vented gases must

pay additional emission fees.

Gas disposition data is

publically available, and may

only be held confidential on an

exploration well

Y N

Volumes 

reported 

reporters

public avB.

Attachment No. 1‐6Louisiana Gas DispositionReport.pdf (State ofLouisiana Monthly Oil

and Gas DispositionReport)

Gasdispositionreport Y N

Total vol

for a majelement 

analysis, 

Attachment No. 1‐7Alaska Gas Disposition

Reporting.xls (Alaska

Department of Revenue

(ADOR) AS 43.55Monthly InformationReport)

Gasdispositionreport

Y N

Total vol

company majority 

available

public av

B.
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

138 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Attachment No. 1‐11 and1‐12 U.S. Department ofEnergy, EnergyInformationAdministration (EIA) gas

disposition reporting

N N

Aggregat

by compa

W 98.236(c)(8 )(iii)(A)

For wellhead gas‐

liquid separators and

wells with

throughput less than

10 barrels per day,

using Calculation

Methodology 5 of 40CFR 98.233(j)Equation W‐15 of 40

CFR 98.233: Number

of wellheadseparators.

Attachment No. 1‐9

North Dakota Gas and

Composition.pdf(OIL/GAS PRODUCTION

FACILITY REGISTRATION,

NORTH DAKOTA

DEPARTMENT OFHEALTH, DIVISION OF AIR

QUALITY)

OperatingPermitApplications

North Dakota Department of

Public Health, Division of AirQuality, Operating Permit

Applications, requires detailedinformation on tanks N N

The num

not repo

Attachment No. 2‐6ColoradoAirPermitApp.PDF(Operating PermitApplication, ColoradoDepartment of PublicHealth and Environment,Air Pollution ControlDivision)

OperatingPermitApplications

Colorado Department ofPublic Health and

Environment, Air Pollution

Control Division,Operating Permit Applications,requires detailed informationon tank equipment

N N

All tanks 

500 gallogreater t

not be spwellhead 

concerns 

is reportedimensio

(gal/yr) is 

Attachment No. 5‐1BOEMRE AirEmissionReporting.pdf[Title 30: Mineral

Resources; PART 250—

OIL AND GAS ANDSULPHUR OPERATIONSIN THE OUTERCONTINENTAL SHELF;Subpart B—Plans andInformation; Contents of

Development andProduction Plans (DPP)

and DevelopmentOperations CoordinationDocuments (DOCD)]

eCFR;BOEMRERegulations at30 CFR

250.513

BOEMRE regulations at 30 CFR

250.513 requires air emission

reporting, including the basisforall calculations, including tankemissions

Y N

Informat

into EPA’into the g

informat

in the gu

evaluated 

analysis. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

139 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Attachment No. 6‐1ColoradoAirPermitApp.pdf(Operating PermitApplication ColoradoDepartment of PublicHealth and EnvironmentAir Pollution ControlDivision)

OperatingPermitApplications

Colorado Department ofPublic Health and

Environment, Air Pollution

Control Division,Operating Permit Applications,requires detailed informationon tank equipment

N N

Form 200

All tanks 

500 gallogreater t

is reporte

specifica

separato

dimensio

(gal/yr) is 

Attachment No. 6‐3North DakotaTankReporting.pdf[PERMIT APPLICATION ‐ VOLATILE ORGANICCOMPOUNDS STORAGETANK; NORTH DAKOTADEPARTMENT OFHEALTH DIVISION OF AIRQUALITY SFN 8535 (12‐

05) (AP‐112)]

OperatingPermitApplications

North Dakota Department of

Public Health, Division of AirQuality, Operating PermitApplications, requires detailedinformation on tanks

N N

The perm

the tank 

separato

data on tof roof, t(vented t

unit, flare

data on t

pressure, 

average t

emission

40 CFR 112 Spill

Prevention, Control and

Countermeasure Plan

Regulation EPA requires reporting of tank

specification information in afacility’s Spill Prevention,Controland Countermeasure (SPCC)

plan (40 CFR 112).

Y N

Not recuplan be d

most faci

oil conta
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

140 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

W 98.236(c)(1 2)(ii)

For flare stacks:

Volume of gas sent

to flare (cubic feet

per year).

Attachment No. 1‐1 TRRC

O&G ReportingRequirements.pdf (TexasRail Road Commission(TRRC) productionstatistics website)

Instruction foronline datareporting

TRRC requires reporting of

fuel, flare, and vented gas.

N N

The data 

volume ovolume o

Attachment No. 1‐2 TRRC

Gas Flared VentedReport.pdf (Texas Rail

Road Commission (TRRC),

Oil and Gas Production

Report Instructions)

OnlineSummaryReport

TRRC produces a report thatincludes the amount of flared

and vented gas.

N N

The data 

volume o

volume o

aggregat

Attachment No. 1‐4Alaska2004_Gas_Disposition_Final.pdf (Alaska Oil andGas ConservationCommission (AOGCC)2004 Annual Report onGas Disposition)

AnnualSummaryReport

AOGCC requires operators toreport gas disposition on amonthly basis, includinginformation on the amount of

gas used for fuel, flare, vented

or used for pilot/purge.

N N

The data 

volume ovolume o

Attachment No. 1‐5 UtahGas DispositionReport.pdf (State of Utah

Monthly Oil and GasDisposition Report)

Report Form State of Utah Department of

Natural Resources, Division of

Oil, Gas and Mining, requiresmonthly gas disposition report

information on the amount of

gas used for fuel, flare, or

vented

N N

The data 

volume ovolume o

Attachment No. 1‐6Louisiana Gas DispositionReport.pdf (State ofLouisiana Monthly Oil

and Gas DispositionReport)

Report Form State of Louisiana Office of

Conservation requires monthlygas disposition report

information onthe amount of gas used for

fuel, flare, or vented

Y N

Recurring 

reporters 

VENTED evaluated see Appe
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

141 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Attachment No. 1‐7Alaska Gas Disposition

Reporting.xls (Alaska

Department of Revenue

(ADOR) AS 43.55Monthly InformationReport)

Report Form Alaska Department of

Revenue (ADOR) requiresoperators to report gas

disposition on a monthlybasis, including information onthe amount of gas used for

fuel, flare, vented or used for

pilot/purge

Y N

Recurring 

reporters 

(MCF). D

availabili

Attachment No. 1‐8 MMSCFRFuelFlareReporting.pdf(Bureau of Ocean Energy

Management (BOEMRE)reporting rule)

eCFR; title 30,Part 250.Subpart K;250.1163

BOEMRE requires operators toreport gas disposition to itsoffshore emission trackingsystem GOADS and under the

reporting requirements of 30

CFR 250.1163

Y N

Data elem

is requireinformatgulfwide sources. amount oelement analysis, 

Attachment No. 1‐9North Dakota Gas and

Composition.pdf(OIL/GAS PRODUCTION

FACILITY REGISTRATION,NORTH DAKOTADEPARTMENT OFHEALTH, DIVISION OF AIR

QUALITY)

OperatingPermitApplications

North Dakota Department of

Public Health, Division of AirQuality, Operating Permit

Applications, requires detailedinformation on gas disposition

and composition

N N

Data elem

flared, esnot requ

an annua

Attachment No. 4‐1North Dakota Amine Unit

Appl.PDF (PERMITAPPLICATION ‐ NATURALGAS PROCESSINGSWEETENINGOPERATIONS, NORTHDAKOTA DEPARTMENT

OF HEALTH DIVISION OFAIR QUALITY)

OperatingPermitApplications

N N

Average 

reportedflare volu
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

142 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Attachment No. 5‐1BOEMRE AirEmissionReporting.pdf[Title 30: Mineral

Resources; PART 250—

OIL AND GAS ANDSULPHUR OPERATIONSIN THE OUTERCONTINENTAL SHELF;Subpart B—Plans andInformation; Contents of

Development andProduction Plans (DPP)

and DevelopmentOperations CoordinationDocuments (DOCD)]

eCFR;BOEMRERegulations at30 CFR

250.513

Y N

Data elem

is requireinformatgulfwide sources.. 

reported

public avB.

Attachment No. 7‐2 TRCCGasVentReport.pdf(STATEWIDE RULE 32EXCEPTION DATA SHEET)

Report Form

Y N

Exception The type 

and if it i

element analysis, 

Attachment No. 8‐2 TRRC

MonthlyProductionReport.pdf (TRCC:INSTRUCTIONS FORM PR:

MONTHLY PRODUCTIONREPORT)

Reportinginstructions

N N

Volumes 

code and 

W 98.236(c)(1 2)(v) For flare stacks: Flare combustion efficiency.

Attachment No. 1‐1 TRRC

O&G ReportingRequirements.pdf (TexasRail Road Commission(TRRC) productionstatistics website)

Instruction for

online datareporting

TRRC requires reporting of

fuel, flare, and vented gas

N N

Combust

data elem

volume o

Attachment No. 1‐5 Utah

Gas DispositionReport.pdf (State of Utah

Monthly Oil and GasDisposition Report)

Report Form State of Utah Department of

Natural Resources, Division of

Oil, Gas and Mining, requiresmonthly gas disposition report

information on the amount of

gas used for fuel, flare, or

vented

N N

Combust

data elemvolume o
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

143 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Attachment No. 1‐6Louisiana Gas DispositionReport.pdf (State ofLouisiana Monthly Oil

and Gas DispositionReport)

Report Form State of Louisiana Office of

Conservation requires monthlygas disposition report

information onthe amount of gas used for

fuel, flare, or vented

N N

Combust

Data elem

vented to 

Attachment No. 1‐7Alaska Gas Disposition

Reporting.xls (Alaska

Department of Revenue

(ADOR) AS 43.55Monthly InformationReport)

Report Form Alaska Department of

Revenue (ADOR) requiresoperators to report gas

disposition on a monthlybasis, including information onthe amount of gas used for

fuel, flare, vented or used for

pilot/purge

N N

Combust

Data elemvolumes.

Attachment No. 2‐6ColoradoAirPermitApp.PDF(Operating PermitApplication, ColoradoDepartment of PublicHealth and Environment,Air Pollution ControlDivision)

OperatingPermitApplications

Y N

Combust

Colorado 

concerns specifica

inlet con

concentr

required

Attachment No. 5‐1BOEMRE AirEmissionReporting.pdf[Title 30: Mineral

Resources; PART 250—

OIL AND GAS ANDSULPHUR OPERATIONSIN THE OUTERCONTINENTAL SHELF;Subpart B—Plans andInformation; Contents of

Development andProduction Plans (DPP)

and DevelopmentOperations CoordinationDocuments (DOCD)]

eCFR;BOEMRERegulations at30 CFR

250.513

BOEMRE requires operators to

report gas disposition to its

offshore emission trackingsystem GOADS and under the

reporting requirements of 30CFR 250.1163

N N

Data on c

collected in the gu

inventory data elem
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

144 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

W 98.236(c)(1 3)(v)(A)

For centrifugal

compressors in

onshore petroleum

and natural gas

production: Count of

compressors.

Attachment No. 1‐9North Dakota Gas and

Composition.pdf(OIL/GAS PRODUCTION

FACILITY REGISTRATION,

NORTH DAKOTADEPARTMENT OFHEALTH, DIVISION OF AIR

QUALITY)

OperatingPermitApplications

North Dakota Department of

Public Health, Division of AirQuality, Operating PermitApplications, requires detailed

information on gas disposition

and composition

N N

Data elem

whose co

HP), cenreported 

W 98.236(c)(1 4)(v)(A)

For reciprocating

compressors in

onshore petroleum

and natural gas

production: Count of

compressors.

Attachment No. 1‐9North Dakota Gas and

Composition.pdf(OIL/GAS PRODUCTION

FACILITY REGISTRATION,

NORTH DAKOTADEPARTMENT OFHEALTH, DIVISION OF AIR

QUALITY)

OperatingPermitApplications

North Dakota Department of

Public Health, Division of AirQuality, Operating PermitApplications, requires detailed

information on gas disposition

and composition

N N

Data elem

whose co

HP), cenreported 

W 98.236(c)(1 9)(iv)

For onshorepetroleum andnatural gas

production andnatural gas

distributioncombustionemissions:Cumulative volume

of fuel combusted in

external fuelcombustion unitswith a rated heat

capacity larger than 5

mmBtu/hr, by fueltype.

Attachment No. 1‐1 TRRC

O&G ReportingRequirements.pdf (TexasRail Road Commission(TRRC) production

statistics website)

Instruction for

online datareporting

TRRC requires reporting of

fuel, flare, and vented gas

N N

Data elemgiven to ofuel. Size specified

Attachment No. 1‐3 TACProducer reportingrequirements.

Title 34, Part 1

chapter 3,subchapter B,Rule 3.17; Tax

AdministrationNatural Gas

TAC requires reporting of

production used by theoperator for lease operations N N

Data elemgiven to ofuel. Size 

specified

Attachment No. 1‐4Alaska2004_Gas_Disposition_Final.pdf (Alaska Oil andGas ConservationCommission (AOGCC)2004 Annual Report onGas Disposition)

AnnualSummaryReport

AOGCC requires operators toreport gas disposition on amonthly basis, includinginformation on the amount of

gas used for fuel, flare, vented

or used for pilot/purge.

N N

The data 

gas used unit not s
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

145 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Attachment No. 1‐5 UtahGas DispositionReport.pdf (State of Utah

Monthly Oil and GasDisposition Report)

Report Form State of Utah Department of

Natural Resources, Division of

Oil, Gas and Mining, requiresmonthly gas disposition report

information on the amount of

gas used for fuel, flare, or

vented

N N

The data 

gas used 

unit not s

Attachment No. 1‐6Louisiana Gas DispositionReport.pdf (State ofLouisiana Monthly Oil

and Gas DispositionReport)

Report Form State of Louisiana Office of

Conservation requires monthlygas disposition report

information onthe amount of gas used for

fuel, flare, or vented

N N

The data volume o

operation

specified

Attachment No. 1‐7Alaska Gas Disposition

Reporting.xls (Alaska

Department of Revenue

(ADOR) AS 43.55Monthly InformationReport)

Report Form Alaska Department of

Revenue (ADOR) requiresoperators to report gas

disposition on a monthlybasis, including information onthe amount of gas used for

fuel, flare, vented or used for

pilot/purge

N N

The data 

volume o

operation

specified 

Attachment No. 1‐9North Dakota Gas and

Composition.pdf(OIL/GAS PRODUCTION

FACILITY REGISTRATION,NORTH DAKOTADEPARTMENT OFHEALTH, DIVISION OF AIR

QUALITY)

OperatingPermitApplications

North Dakota Department of

Public Health, Division of AirQuality, Operating Permit

Applications, requires detailedinformation on gas disposition

and composition

N N

The data 

volume o

operation

specified

Attachment No. 8‐2 TRRC

MonthlyProductionReport.pdf (TRCC:INSTRUCTIONS FORM PR:

MONTHLY PRODUCTIONREPORT)

Reportinginstructions

N N

Data elem

Size of co
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

146 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

W 98.236(c)(1 9)(vii)

For onshore

petroleum andnatural gas

production andnatural gas

distributioncombustionemissions:Cumulative volume

of fuel combusted in

internal combustion

units with a rated

heat capacity largerthan 1 mmBtu/hr or

130 horsepower, by

fuel type.

Attachment No. 1‐1 TRRC

O&G ReportingRequirements.pdf (TexasRail Road Commission(TRRC) production

statistics website)

Instruction foronline data

reporting

TRRC requires reporting of

fuel, flare, and vented gas

N N

Data elemgiven to ofuel. Size specified

Attachment No. 1‐3 TACProducer reportingrequirements.

Title 34, Part 1

chapter 3,subchapter B,Rule 3.17; Tax

AdministrationNatural Gas

TAC requires reporting of

production used by the

operator for lease operations N N

Data elemgiven to ofuel. Size 

specified

Attachment No. 1‐4Alaska2004_Gas_Disposition_Final.pdf (Alaska Oil andGas ConservationCommission (AOGCC)2004 Annual Report onGas Disposition)

AnnualSummaryReport

AOGCC requires operators toreport gas disposition on amonthly basis, includinginformation on the amount of

gas used for fuel, flare, vented

or used for pilot/purge.

N N

The data 

gas used unit not s

Attachment No. 1‐5 UtahGas DispositionReport.pdf (State of Utah

Monthly Oil and GasDisposition Report)

Report Form State of Utah Department of

Natural Resources, Division of

Oil, Gas and Mining, requiresmonthly gas disposition report

information on the amount of

gas used for fuel, flare, or

vented

N N

The data 

gas used 

unit not s

Attachment No. 1‐6Louisiana Gas DispositionReport.pdf (State ofLouisiana Monthly Oil

and Gas DispositionReport)

Report Form State of Louisiana Office of

Conservation requires monthlygas disposition report

information onthe amount of gas used for

fuel, flare, or vented

N N

The data volume o

operation

specified

Attachment No. 1‐7Alaska Gas Disposition

Reporting.xls (Alaska

Department of Revenue

(ADOR) AS 43.55Monthly InformationReport)

Report Form Alaska Department of

Revenue (ADOR) requiresoperators to report gas

disposition on a monthlybasis, including information onthe amount of gas used for

fuel, flare, vented or used for

N N

The data 

volume o

operation

specified
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

147 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

pilot/purge

Attachment No. 1‐9North Dakota Gas and

Composition.pdf(OIL/GAS PRODUCTION

FACILITY REGISTRATION,NORTH DAKOTADEPARTMENT OFHEALTH, DIVISION OF AIR

QUALITY)

OperatingPermitApplications

North Dakota Department of

Public Health, Division of AirQuality, Operating Permit

Applications, requires detailedinformation on gas disposition

and composition

N N

The data 

volume o

operation

specified

Attachment No. 1‐11U.S. Department ofEnergy, EnergyInformationAdministrationMonthly Natural GasProduction Report

Report form

Instruction

U.S. Department of Energy,Energy InformationAdministration (EIA) requires

detailed monthlygas disposition reporting and

annual gas disposition

reporting

N N

The data volume o

Size of co

Attachment No. 8‐2 TRRC

MonthlyProductionReport.pdf (TRCC:INSTRUCTIONS FORM PR:

MONTHLY PRODUCTIONREPORT)

Reportinginstructions

Texas Rail Road Commissionrequires a monthly production

report.

N N

Data elemgiven to ofuel. Size 

specified
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

148 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Y

98.256(e)(6)

If using Equation Y‐1a: report the molar

volume conversionfactor (in scf/g‐mole)for each flare.

None constant Some of the deferred

elements are

simply constant conversion

factors that would not vary

from facility to facility Y Y

Constant 

volume c

mole at 6square inscf/kg‐m

Y

98.256(e)(7)

If using Equation Y‐1b: report molar

volume conversionfactor for each flare.

None constant Some of the deferred

elements are

simply constant conversion

factors that would not vary

from facility to facility

Y Y

Constant 

volume c

mole at 6

square inscf/kg‐m

Y

98.256(e)(7)(ii)

If using Equation Y‐

1b: report the carbon

mole number of each

carbon containing

compound other

than CO2 in the flare

gas stream for eachflare.

Ex. R2: BAAQMD

Regulation 12, Rule 11,401.2.

Local Rule on

performancestandards,includes FlareDataReporting

Requirements.

N N

Referencreporting methane 

provide i

optional. 

informat
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

149 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Y

98.256(e)(9)

Annual volume of

flare gas combusted

during normaloperations

Ex. R2: BAAQMDRegulation 12, Rule 11,401.1.Ex. R3: Seehttp://hank.baaqmd.gov/enf/flares/

Local Rule on

performancestandards,includes Flare

DataReportingRequirements.

Publicly available ‐ see forexample the monthly flarereports submitted by the Bay

Area refineries

Y N

Data ava

only and 

Website 

flare voluat all timobtain an

need to s

Y

98.256(e)(9)

Annual average

higher heating value

of the flare gas

Ex. R2: BAAQMDRegulation 12, Rule 11,401.9.

Local Rule on

performancestandards,includes FlareData

ReportingRequirements.

Similar information (lowerheating value) is publiclyavailable.

N N

Data avaflare gas; 

hydrocar

required

Y

98.256(e)(9)

Volume of gas flared

during SSM event

Ex. R3: Seehttp://hank.baaqmd.gov/enf/flares/

Bay Area Air

QualityManagement

District

website

Publicly available ‐ see forexample the monthly flarereports submitted by the Bay

Area refineries Y N

Data ava

only and 

Website 

flare voluat all timobtain an

need to s

Y

98.256(e)(9)

Average molecular

weight

Ex. R3: Seehttp://hank.baaqmd.gov/enf/flares/

Bay Area Air

QualityManagementDistrictwebsite

Publicly available ‐ see forexample the monthly flarereports submitted by the Bay

Area refineries

N N

Data ava

moleculaincludes 

emission

Sulfur Dio
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

150 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Y

98.256(e)(9)

Carbon content of

the flare gas

No reference No document Publicly available ‐ see for

example the monthly flarereports submitted by the Bay

Area refineries

N N

Data ava

content o

includes 

emission

Sulfur Dio

Y

98.256(e)(9)

If using Equation Y‐3:

report the molarvolume conversion

factor for each flare.

No reference No document Some of the deferred

elements are

simply constant conversion

factors that would not vary

from facility to facility

Y Y

Constant 

volume cmole at 6

square inscf/kg‐m

Y

98.256(e)(10)

Fraction of carbon in

the flare gas

contributed by

methane (used in

Equation Y‐4)

Ex. R2: BAAQMDRegulation 12, Rule 11,401.2.

Local Rule on

performancestandards,includes Flare

DataReportingRequirements.

Can be calculated from

composition data.

N N

Although 

reported 

content ofor Bay A

rule requ

hydrocar

Y 98.256(f)(7)

If using Equation Y‐6:

report the molarvolume conversion

factor.

No reference No document Some of the deferred

elements are

simply constant conversion

factors that would not vary

from facility to facility

Y Y

Constant 

volume c

mole at 6

square inscf/kg‐m
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

151 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Y

98.256(f)(10)

Coke burn‐off factor Ex. R4, p.400

BAAQMD Major FacilityReview Permit; Chevron

Products Company

Draft Permit Title V recordkeeping

requirement

N N

Requiremonly and 

Permit re

burn‐off 

coke bur

reported

Y

98.256(f)(10)

Annual throughput

of unit

Ex. R5, p.6

Chevron Richmond

Analysis, CBE Comments

on Chevron 1/25/08 FEIR

Part 1. RefineryFeedstock Switch.

Response to

comments

Publicly available via other

permit reporting requirements

N N

Documen

available average t

Y

98.256(f)(10)

Average carbon

content of coke

No specific reference

provided Not Applicable

Default provided N N Data ava

content, 

Y

98.256(f)(11)

Units of measure for

the unit‐specific CH4

emission factor

No specific reference

provided No document

Not business sensitive

N N

This is a uthe actua

Y

98.256(f)(11)

Activity data forcalculating emissions

Not provided No document Too general N N No evide

Y

98.256(f)(11)

If you use a unit‐specific emissionfactor for CH4: report

the unit‐specificemission factor forCH4 each catalytic

cracking units,

traditional fluidcoking units, and

catalytic reforming

units

Not provided No document Calculated value

N N

No evide

Y

98.256(f)(12)

If a unit‐specific

emission factor forN2O was used: report

the unit‐specificemission factor forN2O each catalytic

Not provided No document Calculated value

N N

No evide
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

152 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

cracking units,traditional fluid

coking units, and

catalytic reforming

units

Y

98.256(f)(12)

Units of measure for

the unit‐specific N2O

emission factor

No specific reference

provided

No document Not business sensitive

N N

This is a uthe actua

Y

98.256(f)(12)

Activity data forcalculating emissions

No specific reference

provided

No document Not business sensitive

N N

No evide

Y

98.256(f)(13)

Average carbon

content of coke

Not provided No document Generally well known within a

range N N

Data ava

content, 

Y

98.256(h)(4)

If Equation Y‐12 is

used: Annual

volumetric flow to

the sulfur recoveryplant

No specific reference

listed for this item. Ex.

R4 Chevron Richmond

Permit reviewed

Permit

Title V permits

N N

Permit fr

Chevron flow to su

Y

98.256(h)(4)

If Equation Y‐12 is

used: report the

molar volumeconversion factor

Some of the deferredelements are

simply constant conversion

factors that would not vary

from facility to facility

Y Y

Constant 

volume c

mole at 6

square inscf/kg‐m

Y

98.256(h)(4)

If Equation Y‐12 is

used: Annual average

mole fraction of

carbon in the sour

gas

R6: Ensuring Consistent

Greenhouse GasEmissions Estimates,Ritter et al

Article;cepmagazine.org

Data elements that areimportant for the estimation

and verification of emissions

are equally as important as the

calculated emissions estimates

N N

No evide

Referencon report

and examtheoretic

Y

98.256(h)(5)

Value of the

correction

R6: Ensuring Consistent

Greenhouse GasEmissions Estimates,Ritter et al

Article;cepmagazine.org

Data elements that areimportant for the estimation

and verification of emissionsare equally as important as the

calculated emissions estimates

N N

No evide

Referenc

on report

and examtheoretic

Y

98.256(h)(5)

Annual volume of

recycled tail gas (ifused to calculate

recycling correctionfactor)

R6: Ensuring Consistent

Greenhouse GasEmissions Estimates,Ritter et al

Article;cepmagazine.org

Data elements that areimportant for the estimation

and verification of emissions

are equally as important as the

calculated emissions estimates

N N

No evide

Referencon report

and examtheoretic
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

153 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Y

98.256(h)(5)

Annual average mole

fraction of carbon inthe tail gas (if used tocalculate recycling

correction factor)

R6: Ensuring Consistent

Greenhouse GasEmissions Estimates,Ritter et al

Article;cepmagazine.org

Data elements that areimportant for the estimation

and verification of emissionsare equally as important as the

calculated emissions estimates

N N

No evide

Referencon report

and examtheoretic

Y 98.256(i)(5)

If you use Eq. Y‐13,

report the annualmass of green cokefed to the for eachcoke calcining unit

R6: Ensuring Consistent

Greenhouse GasEmissions Estimates,Ritter et al

Article;cepmagazine.org

Data elements that areimportant for the estimation

and verification of emissions

are equally as important as the

calculated emissions estimates

N N

No evide

Referencon report

and examtheoretic

Y 98.256(i)(5)

If you use Eq. Y‐13,

report the carboncontent of green

coke fed to the foreach coke calciningunit

R6: Ensuring Consistent

Greenhouse GasEmissions Estimates,EnvironmentalManagement, Ritter et al

Article;cepmagazine.org

Data elements that areimportant for the estimation

and verification of emissionsare equally as important as the

calculated emissions estimates

N N

No evide

Referenc

on report

and examtheoretic

Y 98.256(i)(5)

If you use Eq. Y‐13,

report the annualmass of marketable

coke produced for

each coke calciningunit

R6: Ensuring Consistent

Greenhouse GasEmissions Estimates,Ritter et al

Article;cepmagazine.org

Data elements that areimportant for the estimation

and verification of emissionsare equally as important as the

calculated emissions estimates

N N

No evide

Referencon report

and examtheoretic

Y 98.256(i)(5)

If you use Eq. Y‐13,

report the carboncontent ofmarketable cokeproduced for each

coke calcining unit

R6: Ensuring Consistent

Greenhouse GasEmissions Estimate,Ritter et al s

Article;cepmagazine.org

Data elements that areimportant for the estimation

and verification of emissionsare equally as important as the

calculated emissions estimates

N N

No evide

Referencon report

and examtheoretic

Y 98.256(i)(5)

If Equation Y‐13 usedfor coke calcining

units: report theannual mass of coke

dust removed from

the process throughcollected in dust

collection systems

R6: Ensuring Consistent

Greenhouse GasEmissions Estimates,Ritter et al

Article;cepmagazine.org

Data elements that areimportant for the estimation

and verification of emissions

are equally as important as the

calculated emissions estimates N N

No evide

Referencon report

and examtheoretic

Y 98.256(i)(7)

For coke calcining:The unit‐specific CH4

emission factor

No specific reference

provided No document

Calculated value

N N

No evide
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

154 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Y 98.256(i)(7)

For coke calcining:Units of measure for

the unit‐specific CH4

emission factor

No specific reference

provided

No document Not business sensitive

N N

This data 

Y 98.256(i)(7)

For coke calcining:Activity data forcalculating emissions

No specific reference

provided

No document Not business sensitive

N N

No evide

Y 98.256(i)(8)

For coke calcining: Ifa unit specific

emission factor was

used for the N2O

factor: report theunits of measure forthe unit‐specificfactor

No specific reference

provided

No document N N

This data 

Y 98.256(i)(8)

For coke calcining: Ifa unit specific

emission factor was

used for the N2O

factor: report theactivity data used forcalculating emissions

No specific reference

provided

No document Not business sensitive

N N

No evide

Y 98.256(i)(8)

For coke calcining: Ifa unit‐specific

emission factor for

N2O was used, report

the site‐specificemission factor

No specific reference

provided

No document Not business sensitive

N N

No evide

Y 98.256(j)(2)

Quantity of asphaltblown for each foreach asphalt blowing

unit

R6: Ensuring Consistent

Greenhouse GasEmissions Estimates,Ritter et al

Article;cepmagazine.org

Data elements that areimportant for the estimation

and verification of emissions

are equally as important as the

calculated emissions estimates

N N

No evide

Referencon report

and examtheoretic

Y 98.256(j)(2)

Quantity of asphaltblown for each foreach asphalt blowing

unit

R6: Ensuring Consistent

Greenhouse GasEmissions Estimates,Ritter et al

Article;cepmagazine.org

Data elements that areimportant for the estimation

and verification of emissions

are equally as important as the

calculated emissions estimates

N N

No evide

Referencon report

and examtheoretic
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

155 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Y 98.256(j)(2)

Quantity of asphaltblown for each foreach asphalt blowing

unit

R6: Ensuring Consistent

Greenhouse GasEmissions Estimates,Ritter et al

Article;cepmagazine.org

Data elements that areimportant for the estimation

and verification of emissions

are equally as important as the

calculated emissions estimates

N N

No evide

Referencon report

and examtheoretic

Y 98.256(j)(2)

Quantity of asphaltblown for each foreach asphalt blowing

unit

R6: Ensuring Consistent

Greenhouse GasEmissions Estimates,Ritter et al

Article;cepmagazine.org

Data elements that areimportant for the estimation

and verification of emissions

are equally as important as the

calculated emissions estimates

N N

No evide

Referencon report

and examtheoretic

Y 98.256(j)(2)

Quantity of asphaltblown for each foreach asphalt blowing

unit

R6: Ensuring Consistent

Greenhouse GasEmissions Estimates,Ritter et al

Article;cepmagazine.org

Data elements that areimportant for the estimation

and verification of emissions

are equally as important as the

calculated emissions estimates

N N

No evide

Referencon report

and examtheoretic

Y 98.256(j)(5)

CO2 emission factor

for each asphalt

blowing unit

No specific reference

provided No document

Calculated value

N N

No evide

Y 98.256(j)(6)

CH4 emission factor

for each asphalt

blowing unit

No specific reference

provided No document

Calculated value

N N

No evide

Y 98.256(j)(7)

If Equation Y‐16 is

used: report the

carbon emission

factor

No specific reference

provided

No document Calculated value

N N

No evide

Y 98.256(j)(8)

If Equation Y‐16b is

used: report the CO2

emission factor used

No specific reference

provided

No document Calculated value

N N

No evide

Y 98.256(j)(8)

If Equation Y‐16b is

used: report the

carbon emission

factor

No specific reference

provided

No document Calculated value

N N

No evide

Y 98.256(j)(9)

If you use Eq. Y‐17:

CH4 emission factor

No specific reference

provided

No document Calculated value

N N

No evide

Y

98.256(k)(3)

For delayed coking

units: Dimensions of

coke drum or vessel

No specific reference

provided

No document Publicly reported as modeling

input N N

No evide
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

156 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Y

98.256(k)(3)

For delayed coking

units: Typical gauge

pressure of the

coking drum when

first vented to the

atmosphere

R6: Ensuring Consistent

Greenhouse GasEmissions Estimates,Ritter et al

Article;cepmagazine.org

Data elements that areimportant for the estimation

and verification of emissions

are equally as important as the

calculated emissions estimates

N N

No evide

Referencon report

and examtheoretic

Y

98.256(k)(3)

For delayed coking

units: Typical voidfraction of coke

drum or vessel

No specific reference

provided

No document Default suggested

N N

No evide

Y

98.256(k)(3)

For delayed coking

units: Annual

number of coke‐

cutting cycles of cokedrum or vessel

R6: Ensuring Consistent

Greenhouse GasEmissions Estimates,Ritter et al

Article;

cepmagazine.

org

Data elements that areimportant for the estimation

and verification of emissions

are equally as important as the

calculated emissions estimates

N N

No evide

Referencon report

and examtheoretic

Y

98.256(k)(3)

For delayed coking

units: report themolar volumeconversion factor for

each coke drum or

vessel.

No specific reference

provided

No document Constant

Y Y

Constant 

volume c

mole at 6square inscf/kg‐m

Y

98.256(k)(4)

For delayed coking

units: Height anddiameter of the coke

drums

No specific reference

provided

No document Publicly reported as modeling

input N N

No evide

Y

98.256(k)(4)

For delayed coking

units: Cumulativenumber of vessel

openings for all

delayed coking

drums in the set

No specific reference

provided. Ex. R4reviewed.

No document Title V permits

N N

Data collreporters 

Regulatio

monitoriRecordkereporting 

Y

98.256(k)(4)

For delayed coking

units: Typical venting

pressure

R6: Ensuring Consistent

Greenhouse GasEmissions Estimates,Ritter et al

Article;cepmagazine.org

Data elements that areimportant for the estimation

and verification of emissions

are equally as important as the

calculated emissions estimates

N N

Referencon report

and examtheoretic

Y

98.256(k)(4)

For delayed coking

units: Void fraction

No specific reference

provided

No document Default suggested N N No evide
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

157 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Y

98.256(k)(4)

For delayed coking

units: Mole fraction

of methane in cokinggas

No specific reference

provided

No document Default suggested

N N

No evide

Y 98.256(l)(5)

For each processvent: Molar volume

conversion factor

No reference No document Some of the deferred

elements are

simply constant conversion

factors that would not vary

from facility to facility

Y Y

Constant 

volume c

mole at 6square in

scf/kg‐m

Y

98.256(m)(3)

Uncontrolledblowdown systems

reporting under

98.253 (k): Totalquantity of crude oil

plus the quantity of

intermediate

products received

from off‐site that are

processed at thefacility in the

reporting year

R6: Ensuring Consistent

Greenhouse GasEmissions Estimates,Ritter et al

Article;cepmagazine.org

Data elements that are

important for the estimation

and verification of emissionsare equally as important as thecalculated emissions estimates

N N

Referencon report

and exam

theoretic

Y

98.256(m)(3)

Uncontrolledblowdown systems

reporting under

98.253 (k): CH4

emission factor used

No specific reference

provided

No document

Default suggested

N N

No evide

Y

98.256(m)(3)

Uncontrolledblowdown systems

reporting under

98.253 (k): Molar

volume conversion

factor

No specific reference

provided

No document Constant

Y Y

Constant 

volume c

mole at 6square inscf/kg‐m

Y

98.256(n)(3)

For equipment leaks:Number of each type

of emission source

listed in Equation Y‐

21 (if using Eq. Y‐21)

No specific reference

provided

Article;cepmagazine.org

Publicly available in Title V

permits

Y N

Title V pe

number o

on a one

evaluated 

analysis. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

158 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Y

98.256(o)(2)(ii)

Total quantity ofcrude oil plus the

quantity of

intermediate

products received

from off‐site that are

processed at thefacility in the

reporting year

R6: Ritter et al paper Article;

cepmagazineorg

Data elements that areimportant for the estimationand verification of emissions

are equally as important as thecalculated emissions estimates N N

No evide

Y

98.256(o)(4)(ii)

For storage tanks

that process

unstabilized crude

oil: Quantity of

unstabilized crude oil

received during the

calendar year

R6: Ritter et al paper Article;

cepmagazine.org

Data elements that areimportant for the estimationand verification of emissions

are equally as important as thecalculated emissions estimates

N N

No evide

Y

98.256(o)(4)(iii)

For storage tanks

that process

unstabilized crude

oil: Average pressure

differential

R6: Ritter et al paper Article;

cepmagazine.org

Data elements that areimportant for the estimationand verification of emissions

are equally as important as thecalculated emissions estimates

N N

No evide

Y

98.256(o)(4)(iv)

For storage tanks

that process

unstabilized crude

oil: Molar volumeconversion factor

No specific reference

provided

No document Constant

Y Y

Constant 

volume c

mole at 6square inscf/kg‐m

Y

98.256(o)(4)(v)

For storage tanks

that process

unstabilized crude

oil: Average Molefraction of CH4 in

vent gas from the

unstabilized crude oil

storage tanks

R6: Ensuring Consistent

Greenhouse Gas

Emissions Estimates,Ritter et al

Article;cepmagazine.org

Data elements that areimportant for the estimationand verification of emissionsare equally as important as the

calculated emissions estimates N N

No speci

Y

98.256(o)(4)(vi)

If you did not useEquation Y‐23: report

the tank‐specific

methanecomposition data

R6: Ensuring Consistent

Greenhouse GasEmissions Estimates,Ritter et al

Article;cepmagazine.org

Data elements that areimportant for the estimation

and verification of emissionsare equally as important as the

calculated emissions estimates

N N

Provides 

reporting example sources.
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

159 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

used to estimatecumulative CH4emissions for storage

tanks used to process

unstabilized crude

oil.

Y

98.256(o)(4)(vi)

If you did not useEquation Y‐23: report

the gas generation

rate data used to

estimate cumulativeCH4 emissions for

storage tanks used to

process unstabilizedcrude oil.

R6: Ensuring Consistent

Greenhouse GasEmissions Estimates,Ritter et al

Article;cepmagazine.org

Data elements that are

important for the estimationand verification of emissionsare equally as important as thecalculated emissions estimates N N

Provides 

reporting 

example 

sources.

Y

98.256(o)(6)

Quantity of

unstabilized crude oil

received during the

calendar year

R6: Ensuring Consistent

Greenhouse GasEmissions Estimates,Ritter et al

Article;cepmagazine.org

Data elements that areimportant for the estimation

and verification of emissionsare equally as important as the

calculated emissions estimates

N N

Provides 

reporting 

example sources.

Y

98.256(o)(6)

Average pressure

differential

R6: Ensuring Consistent

Greenhouse GasEmissions Estimates,Ritter et al

Article;cepmagazine.org

Data elements that areimportant for the estimation

and verification of emissions

are equally as important as the

calculated emissions estimates

N N

Provides reporting example 

sources.

Y

98.256(o)(6)

Mole fraction of CH4

in vent gas from the

unstabilized crude oil

storage tank

No specific reference

provided No document

Default suggested

N N

No evide

Y

98.256(o)(7)

Tank‐specific

methanecomposition data

R6: Ensuring Consistent

Greenhouse GasEmissions Estimates,Ritter et al

Article;cepmagazine.org

Data elements that areimportant for the estimation

and verification of emissionsare equally as important as the

calculated emissions estimates

N N

Provides 

reporting 

example 

sources.

Y

98.256(o)(7)

Gas generation ratedata

No specific referenceprovided No document

Emissions

N N

No evide
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

160 

Subpart Reporting

Section

Data Element Reference Cited by

Commenter

Type of

Document

Commenter Justification forWhy Data is Publicly Available

Is Available

Data Exactly

the Same as

GHGRP Data

Element?

Is Data Element

Publicly

Available

Recurring for

Majority of

Reporters

Evaluati

Y

98.256(p)(2)

For loading

operations: Quantityof materials loaded

by vessel type that

have an equilibrium

vapor‐phaseconcentration of CH4

of 0.5 volume

percent or greater

R6: Ensuring Consistent

Greenhouse GasEmissions Estimates,Ritter et al

Article;cepmagazine.org

Data elements that areimportant for the estimationand verification of emissionsare equally as important as thecalculated emissions estimates N N

Provides reporting example 

sources.
Attachment P 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

1

TECHNICAL MEMORANDUM 

DATE: May 2013 

TO: Docket EPA-HQ-OAR-2010-0929 

FROM: Lisa Grogan-McCulloch

SUBJECT: Evaluation of Competitive Harm from Reporting “Inputs to Equations” Data 

Elements Deferred to March 31, 2015

Introduction and Purpose of Analysis 

In the August 25, 2011 final rule deferring reporting of certain inputs to emission equations 

under 40 CFR part 98 (76 FR 53057) (hereafter referred to as “’inputs to equations’ data 

elements”) until March 31, 2015, EPA expressed its intent to further evaluate the “inputs to 

equations” data elements to determine which, if any, could result in competitive harm if made 

publicly available. EPA outlined a four-step process for this evaluation in the final rule and in a 

supporting memorandum entitled “Process for Evaluating and Potentially Amending Part 98 

Inputs to Emission Equations” (docket EPA-HQ-OAR-2010-0929). 

The purpose of this memorandum is to describe the review undertaken for the second step of this 

evaluation process: EPA’s analysis of the competitive harm that would likely result from 

reporting of “inputs to equations” data elements. This review was undertaken for 27 of the 28 

subparts of the Greenhouse Gas Reporting Program (GHGRP) with “inputs to equations.” 1 

This analysis of competitive harm includes: 

 Part One: An evaluation of the current market structures for sectors required to report 

“inputs to equations” data elements, to determine whether conditions exist within the 

market structures such that the release of the data could result in competitive harm, and 

 Part Two: For those sectors for which the market structure analysis determined that 

reporting of the “inputs to equations” data elements could result in competitive harm, an 

evaluation of each individual “inputs to equations” data elements to determine whether its 

release would be likely to cause competitive harm. 

                                                           

1 The review was not conducted for 2015 data inputs in subpart I because reporting of the “inputs to equations” data elements for 

that subpart was addressed in a separate proposed action [see 77 FR 63538]. Additionally, the evaluation of the subpart C 

“inputs to equations” in this memorandum encompasses the one subpart A “input to equation” data element. As a result, the 

one subpart A “input to equation” is not listed explicitly in this memorandum. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

2

EPA’s evaluation of current market structures is presented in Part One of this memorandum. For 

all sectors in which the market structure analysis summarized in Part One determined that the 

conditions exist within the market such that firms could use released “inputs to equations” data 

elements to gain a competitive advantage, EPA proceeded to evaluate each individual “inputs to 

equations” data element. Part Two of this memorandum presents an evaluation of each 

individual “inputs to equations” data element to determine whether potential release would be 

likely to cause substantial competitive harm. 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

3

Part 1: Evaluation of Market Structures 

1.0 Introduction 

The following section describes the overall process used to assess the market structures that exist 

within the different subparts of 40 CFR part 98 with “inputs to equations” data elements, to 

determine whether conditions exist within the market such that competitive harm could occur 

should “inputs to equations” data elements be released to the public. Section 2.0 summarizes the 

connection between market structure and the potential for information to cause competitive 

harm. Section 3.0 presents the process used for the assessment. Section 4.0 presents the results of 

the market structure assessment for each subpart evaluated. Section 5.0 presents a summary of 

the overall results of this analysis.

2.0 Importance of Market Structure 

Market structure affects firms’ ability to use information about other firms in their market. 

Market structure is defined in terms of the number of firms supplying a commodity in the 

market, and the degree of control that individual firms have over the price they obtain for their 

product. The market, in turn, is defined in terms of the commodity marketed and the geographic 

scope of the market. 

Competitive markets are characterized by many suppliers and products that are identical or 

nearly identical, in terms of product characteristics that users value. In such markets, firms are 

“price takers”; that is, they are unable to influence the market price, and must determine their 

profit-maximizing production level as a function of the price set by the market. In such markets, 

strategic behavior is not possible because there are too many competitors, making it impossible 

for them to make decisions based on their competitors’ actions, and thereby affect market price. 

Thus, for firms to be able to use information either to cause competitive harm or to coordinate 

their pricing with competitors, the number of firms in the market must be small enough that 

firms can identify their competitors, and identify critical information about their competitors’ 

operations. Markets with a relatively small number of firms are termed "concentrated." 

In the following section, we describe methods for assessing whether markets are concentrated. 

We then examine several sectors covered by the GHGRP, to determine their level of 

concentration. 

3.0 Process for Assessing Market Structures and Potential for Competitive Harm 

Economists assess market concentration using measures that characterize the share of the market 

served by the largest firms. Specific tools used include the Herfindahl-Hirschman Index (HHI). 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

4

For a given market, the HHI is calculated by squaring the market share of each firm competing in 

the market, then summing the squared shares. 

HHI = isi

2 , where si = the market share of the ith firm. 

Potential values of the HHI range from near zero (if each of the top 50 firms has one-50th if the 

output of the group (50*(1/50^2)), to 10,000, if one firm has 100 percent of the value 

(100^2=10,000). The HHI reflects both the number of firms in the market and the relative size of 

the firms, and assumes larger values, (1) the smaller the number of firms in the market and (2) 

the greater the disparity in size between the firms. The U.S. Department of Justice (DOJ) and the 

Federal Trade Commission (FTC)2 use the HHI to identify markets where there are potential 

anti-trust concerns. They consider markets with an HHI below 1,000 to be unconcentrated; 

markets with HHI between 1,000 and 1,800 are considered moderately concentrated, and 

markets with HHI above 1,800 to be highly concentrated. The Census Bureau computes and 

publishes HHI for the manufacturing sectors, defined using North American Industry 

Classification System codes or NAICS codes.3 

Economists define markets at the product or process level because customers make purchasing 

decisions for specific products or services. While identifying a concentrated or moderately 

concentrated NAICS is sufficient to identify subparts in which facilities are aware of their 

competitors, and thus subparts for which revealing sensitive information would have the 

potential to lead to competitive harm, it is not the only indicator that a market may have the 

potential to lead to competitive harm should sensitive information be released. Some sectors 

(defined at the 6-digit NAICS code level) that are not concentrated at the national sector level 

may produce some products for which there are sufficiently few firms producing the product that 

they are aware of each other’s operations and may behave strategically. In these cases, 

publication of some data could result in either reduced competition or competitive harm. 

Similarly, some products are traded in regional, rather than national markets; for these, even if 

the sector does not appear concentrated or moderately concentrated at the national level based 

upon its HHI, regional markets, which have fewer firms on the supply side compared to the 

national sector, may be concentrated. In addition, some NAICS may include multiple industry 

sectors, only one of which is covered by a subpart. If this is the case, the industry sector may 

have concentrated or moderately concentrated markets even if the overall NAICS is not 

concentrated or moderately concentrated. As a result, for subparts for which the national-level 

NAICS assessment indicates that the sector may be unconcentrated, EPA performed additional 

assessments. 

Thus, EPA’s analysis followed a tiered approach: 

                                                           

2 Department of Justice. Use of HHI. http://www.justice.gov/atr/public/divisionmanual.html , and Federal Trade Commission 

(FTC), 2004. The Petroleum Industry: Mergers, Structural Change, and Antitrust Enforcement. 

http://www.ftc.gov/opa/2004/08/oilmergersrpt.shtm

3 Census Bureau. Economic Census, Concentration Ratios, 2007. http://www.census.gov/econ/concentration.html
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

5

1. For each subpart, EPA examined associated NAICS codes to determine if the entire 

NAICS is concentrated or moderately concentrated at the national level. 

2. If multiple NAICS are associated with a subpart, and not all NAICS are in the same 

concentration category, EPA determined whether a majority of the facilities reported 

concentrated or moderately concentrated NAICS. 

3. If all the national NAICS associated with a subpart are unconcentrated, or a majority of 

facilities report under unconcentrated NAICS, EPA determined whether: 

a. The markets for the goods produced by firms in the subpart are regional, or 

b. The NAICS is broader than the affected market, or there are sub-sector markets 

within a sector, such as markets for specialty products. 

If EPA found that either of the criteria under the third tier above is true for a subpart, EPA 

examined the market itself (either regional or sub-sector/product-specific) to determine if it is 

concentrated or moderately concentrated. If EPA found that none of the above criteria is true for 

a subpart, EPA determined that the market is unconcentrated, and that the risk of competitive 

harm or diminished competition resulting from the release of “inputs to equations” data elements 

for the subpart would be minimal. If EPA found that any of the above criteria is true for a 

subpart, EPA determined that the market is concentrated, such that the firms subject to the 

subpart are likely able to identify their competitors. For each such subpart, EPA proceeded to 

evaluate each “inputs to equations” data elements within the subpart to determine if its release 

would be likely to cause competitive harm. Refer to Part 2 of this memorandum for this analysis. 

For three of the subparts, subparts C (Combustion), II (Industrial Wastewater Treatment), and TT 

(Industrial Landfills), the subparts represent a process that may take place at facilities in a 

number of industry sectors. Another subpart, subpart U (Miscellaneous Uses of Carbonates), also 

includes a variety of industry sectors. The markets in which these facilities compete, and for 

which concentration must be assessed, are the markets for the goods or services they produce. To 

evaluate the concentration in these markets, therefore, EPA identified the NAICS codes for the 

industry sectors reported by these facilities, and examined their concentration. 

For sectors that did not have manufacturing NAICS codes, subparts W (Petroleum and Natural 

Gas Systems) and CC (Soda Ash), HHI values were not available. As a result, EPA conducted a 

qualitative analysis of the market structure. 

4.0 Results of Analysis 

EPA calculated HHI values using NAICS codes reported by facilities for reporting year 2011. 

For the 27 subparts for which this analysis was conducted, EPA identified 296 unique NAICS 

codes that facilities reported. Of these 296, 200 are manufacturing sector NAICS codes, for 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

6

which HHI information is compiled by the Census Bureau. Subparts CC and W4 did not have 

manufacturing NAICS reported, and thus HHI values were not available. As a result, for these 

subparts, EPA conducted a qualitative analysis. 

Section 4.1 presents the results of the analysis of concentration at the national sector (NAICS 

code) level. Section 4.2 presents the results of the analysis of concentration at the regional, 

product, or process level. Section 4.3 presents the results of the analysis of subparts representing 

processes from many Sectors (i.e., subparts C, U, II, and TT). Section 4.4 presents the results of 

the analysis of non-manufacturing Sectors (i.e., subparts W and CC). 

4.1 Analysis of Concentration at the National Sector (NAICS-code) Level 

To begin its assessment of the potential for the release of the “inputs to equations” data elements 

to lead to reduced competition or competitive harm, EPA determined the level of sector 

concentration at the national NAICS code level. If EPA determined that the NAICS code 

identified by a majority of firms in a subpart is concentrated or moderately concentrated at the 

national NAICS code level, EPA concluded that the firms in the subpart are likely are aware of 

each other’s actions. EPA focused its assessment on the 200 manufacturing sector NAICS codes 

associated with GHG reporting facilities. 

Appendix A lists concentration ratios for the 6-digit NAICS codes cited by facilities, as well as 

values of the Herfindahl-Hirschman Index (HHI) published by the U.S. Census Bureau for 

affected manufacturing NAICS codes. In addition, Appendix A presents information about the 

number of reporting facilities in a subpart that identified each NAICS. This information allowed 

EPA to identify which NAICS codes within a subpart represent the majority of reporting 

facilities.5 

 At the subpart level, EPA considered a subpart to be associated with concentrated or moderately 

concentrated markets if a majority of the firms reporting under that subpart identified themselves 

with NAICS codes that are concentrated or moderately concentrated. Recognizing that it is 

actually the market or the sector that is concentrated, for convenience throughout the rest of this 

document, EPA refers to such subparts as concentrated or moderately concentrated. Using this 

criterion, EPA found that the following subparts are at least moderately concentrated based on 

the NAICS codes associated with them: subparts F, G, L, N, O, S, V, Z, AA, BB, and EE. As a 

result, EPA further evaluated these subparts by examining individual data elements to determine 

if harm would be likely to occur. Refer to the Part 2 of this memorandum for this evaluation. 

                                                           

4 Three of the 1,549 facilities reporting under subpart W in 2011 reported manufacturing NAICS codes. See section 4.4 for 

further discussion. 

5 Some facilitiesreported multiple NAICS; thus, facilities may be counted several times within a subpart, and the sum of NAICS 

cited by facilities within a subpart may exceed the number of facilities reporting under that subpart. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

7

4.2 Analysis of Concentration at the Regional, Product, or Process Level 

For sectors for which the Census Bureau data indicates HHI in the unconcentrated range, EPA 

undertook further analysis. The markets for the goods they produce were examined to determine 

if the markets for some or all of the goods are concentrated within a particular NAICS, or if the 

goods are traded in regional markets, which would have fewer firms than the national markets 

and thus are more likely to be concentrated; see the analysis below. 

Subpart E, Adipic Acid Producers. Production of adipic acid falls under NAICS 325199, All 

Other Basic Inorganic Chemical Manufacturing; this is a very broad NAICS code, encompassing 

production of many different inorganic chemicals. Adipic acid production is a small subset of the 

overall NAICS. Thus, EPA examined adipic acid producers specifically, rather than relying on a 

NAICS-level assessment. Three facilities reported under subpart E for Reporting Year 2011. 

Even without firm-level data, the HHI is useful because with only three plants, the lowest value 

the HHI could have is 3,267.6 Because this source category does not have a threshold for 

applicability, all adipic acid producers in the U.S. are reporting under the GHGRP. Thus, EPA 

concluded that the market for adipic acid is concentrated at the national level. As a result, EPA 

further evaluated the “inputs to equations” data elements in Subpart E by examining individual 

data elements to determine if harm would be likely to occur. Refer to Part 2 of this memorandum 

for this evaluation. 

Subpart H: Portland Cement Sector. Subpart H is the Portland cement industry. Nationally, the 

HHI for the cement industry is 609.9; the four largest firms produce 40.8% of value of 

shipments, according to the 2007 Economic Census. In addition, Appendix 1 shows that the 

NAICS codes reported by GHGRP facilities in 2011 are unconcentrated. Therefore, EPA 

proceeded to assess whether regional markets are concentrated. 

High cement transportation cost relative to product value leads to regional cement markets with a 

small number of competing firms. In previous analyses supporting EPA rule making, the cement 

industry has been modeled as regional, and imperfectly competitive.7 That is, market 

concentration within a regional market is sufficiently high that firms are aware of competitors. 

For example, this analysis identified 20 regional markets for gray cement (a subset of this 

sector), with the number of plants in each market ranging from one to nine6

; such markets are 

clearly concentrated at the regional level. 

In such markets, firms may have the ability to influence market prices by their production 

choices. In addition, firms are more likely to behave strategically based on their knowledge of 

other (competing) producers’ behavior. In addition, they would be aware of their competitors’ 

                                                           

6 Assuming each firm has an equal one-third share of the market results in an HHI of 3,267 (3 x 332

). In fact,the threshold of 

1,000 for moderately concentrated markets translates to a minimum of 10 firms. 

7 See EPA’s Regulatory Impact Analysis: Amendments to the National Emissions Standards for Hazardous Air Pollutants and 

New Source Performance Standards for the Portland Cement Industry, August 2010, Section 2.3. 

http://www.epa.gov/ttnecas1/regdata/RIAs/portlandcementfinalria.pdf, EPA-HQ-OAR-2002-0051-3477. 
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identity and interested in production and market information about their competitors. It is 

important to note that facilities in the cement industry may produce a variety of cement products. 

Some cement products are homogeneous (e.g. gray cement) and are traded in regional markets; 

others such as white, Type III and Type V represent niche products with different markets, with 

few firms but possibly serving a larger geographic area.8 

As a result of these assessments, EPA concluded that the structure of the markets that exist 

within this source category warrant further evaluation of the “inputs to equations” data elements 

in subpart H. Therefore, EPA further evaluated the “inputs to equations” data elements by 

examining each individual data element to determine if harm would be likely to occur. Refer to 

Part 2 of this memorandum for this evaluation. 

Subpart K, Ferroalloys. According to the 2010 Statistics of U.S. Business9, there are 19 firms 

nationwide that produce ferroalloys. Of the 10 firms reporting under subpart K, nine selected 

NAICS 331112, for which no HHI information is available from the Census. As a result, we 

conducted a qualitative assessment of the market structure. Firms in an industry with only 19 

firms would be aware of their competitors. In addition, if a sector that has 19 firms nationwide 

includes a few firms with relatively large market share (as opposed to a sector where all firms are 

similar size, and each has roughly 1/19 share of the market), the sector is likely to be 

concentrated. As a result, EPA concluded that the structure of the market that exists within this 

source category warrants further evaluation of the “inputs to equations” in subpart K. Therefore, 

EPA further evaluated the “inputs to equations” data elements by examining each individual data 

element to determine if harm would be likely to occur. Refer to Part 2 of this memorandum for 

this evaluation. 

Subpart P: Hydrogen Production. Most hydrogen is produced at petroleum refineries and 

ammonia production facilities, generally for captive use. Because these sectors are considered at 

least moderately concentrated (see discussion for subpart Y, below), we concluded that the 

structure of the markets that exist within this source category warrant further evaluation of the 

“inputs to equations” data elements in subpart P. Therefore, EPA further evaluated the “inputs to 

equations” data elements by examining each individual data element to determine if harm would 

be likely to occur. Refer to Part 2 of this memorandum for this evaluation. 

Subpart Q: Iron and Steel Sector. EPA assessed the market structure of the iron and steel sector, 

using HHI data from the Census Bureau and other information. Steel production is generally 

characterized by economies of scale, resulting in markets dominated by a few large firms. 

                                                           

8 EPA’s Regulatory Impact Analysis: National Emissions Standards for Hazardous Air Pollutants from the Portland Cement 

Industry, April 2009, shows that only 4 plants nationwide produced white cement in 2005. See Appendix A of the 2009 RIA for 

list of plants in each cement market in 2005. http://www.epa.gov/ttnecas1/regdata/RIAs/portlandcementria_4-20-09.pdf. 

9 U.S. Census Bureau. 2010 Statistics of U.S. Businesses. http://www.census.gov/econ/susb/. Accessed March 5, 2013. 
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Economies of scale favor large furnaces (high capital investment costs) and pose entry barriers. 

High transportation cost relative to product value is associated with regional steel markets with a 

small number of competing firms. As a result, firms may have the ability to influence market 

prices by their production choices. In addition, firms are more likely to behave strategically 

based on their knowledge of other (competing) producers’ behavior. Nationally, the majority of 

facilities reporting under this source category had a NAICS code that was unconcentrated. , for 

the reasons mentioned above, the national NAICS-level assessment may be misleading. Some 

steel products are homogeneous and are traded in regional markets; others represent niche 

products with relatively few firms, serving different markets (possibly different geographic 

dimensions). Both regional markets and niche markets have relatively small numbers of 

producers, indicating at least moderate market concentration. 

EPA computed HHI at the process, region, and parent company level, using data from the 

American Iron and Steel Institute. The American Iron and Steel Institute provides limited steel 

production and process data available on its website10. The data show a total of almost 124 

million tons of steel produced, 73 million tons in EAFs and 50 million tons in basic oxygen 

furnaces (BOFs). EPA constructed HHI values using this production data, disaggregating by 

state, parent company, and process. The results indicated that there are 116 facilities located in 

31 states, and production is not concentrated nationally, as indicated by relatively low HHI 

values. However, when data are grouped by state or parent company, the HHI values show at 

least moderate concentration, with the exception of EAFs, which are unconcentrated even at the 

state level. As a result, when EPA accounted for the distinctions of region, parent company 

ownership, and steelmaking process EPA concluded that the structure of the markets that exists 

within this source category warrant further evaluation of the “inputs to equations” data elements 

in subpart Q. Therefore, EPA further evaluated the “inputs to equations” data elements by 

examining each individual data element to determine if harm would be likely to occur. Refer to 

Part 2 of this memorandum for this evaluation. 

Subparts R (Lead Smelting) and GG (Zinc Smelting). EPA determined that markets served by 

firms reporting under subparts R and GG are concentrated at the national level. Both subpart R 

(lead smelting) and subpart GG (zinc smelting) fall under NAICS 331410, Nonferrous Metal 

(except Aluminum) Smelting and Refining. In addition to lead and zinc, many other nonferrous 

metals are included under NAICS 331410. Thus, EPA examined the markets for lead and zinc 

individually. For subpart R, there is only one primary lead smelter, and seven firms with 14 

secondary smelters nationwide (USGS, 2010a). For subpart GG, there is only one primary zinc 

smelter and two secondary smelters nationwide (USGS, 2010b). Thus, firms in both of these 

subparts produce commodities whose markets are concentrated nationally. As a result, EPA 

concluded that the structure of the markets that exist within these source categories warrant 

further evaluation of the “inputs to equations” data elements. Therefore, EPA further evaluated 

                                                           

10 ] http://www.steel.org/en/Making%20Steel/Where%20Its%20Made.aspx
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the “inputs to equations” data elements by examining each individual data element to determine 

if harm would be likely to occur. Refer to Part 2 of this memorandum for this evaluation. 

Subpart X: Petrochemicals. In 2011, 64 petrochemical manufacturing facilities identified 14 

NAICS codes. Of these, two NAICS, identified by 19 facilities, are concentrated based on their 

HHI values. Facilities within this subpart produce one of six products: carbon black, methane, 

acrylonitrile, ethylene, ethylene oxide, and ethylene dichloride. EPA examined the markets for 

these products, and found that none of them had more than 17 firms, and most had ten or fewer.11

As a result, EPA concluded that the structure of the markets that exist within this source category 

warrant further evaluation of the “inputs to equations” data elements in subpart X. Therefore, 

EPA further evaluated the “inputs to equations” data elements by examining each individual data 

element to determine if harm would be likely to occur. Refer to Part 2 of this memorandum for 

this evaluation. 

Subpart Y: Petroleum Refinery Sector. There are two types of barriers to entry facing firms 

wanting to enter the refining industry. First, there are significant economies of scale in refinery 

operations, so firms would need to start a fairly large-scale operation or they would face higher 

unit costs than their competitors. Second, legal barriers may also present obstacles (e.g., patented 

processes). 

Nationally, the HHI for the refinery industry is 807; the four largest firms produce 47.5% of 

value of shipments, according to the 2007 Economic Census. While 807 is not considered 

concentrated, the industry has become more concentrated over time, even when considered 

nation-wide (HHI in 1996 was 412, in 2000 the HHI was 611, and in 2007 it was 807). 

Concentration has occurred through mergers, which has reduced the number of refinery 

companies in the U.S. Examining HHIs by the five PADDs (Petroleum Administrative Districts 

for Defense”12, the Federal Trade Commission (FTC, 2004) found that PADD V (the West Coast 

including Alaska and Hawaii) was moderately concentrated (HHI=1,246 in 2003). 

Individual petroleum products are relatively homogeneous, although different firms produce a 

different mix of products, and some produce specialty products for which there are few other 

producers. The U.S. Department of Energy collects data on refineries in a petroleum supply 

survey which is published as an annual Petroleum Capacity Report. 13 EPA reviewed the latest 

data (2012) containing 31 separate products and processes at 95 different facilities owned by 63 

different firms. To better characterize the petroleum market, EPA analyzed this data at the 

product/process level, applying the HHI measure to test for market concentration. The result of 

calculating the HHI at the product/process level for petroleum refineries shows that activity for 

                                                           

11U.S. Environmental Protection Agency. Technical Support Document for the Petrochemical Production Sector: Proposed Rule 

for Mandatory Reporting of Greenhouse Gases. September 9, 2008. 

http://www.epa.gov/ghgreporting/documents/pdf/archived/tsd/TSD%20PetroChem_EPA_09-09-08.pdf 

12 http://www.eia.gov/oog/info/twip/padddef.html 

13 http://www.eia.gov/petroleum/refinerycapacity/ 
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several key products/processes is at least moderately concentrated. The data includes capacity 

data for 3 thermal cracking processes (visbreaking, fluid coking, other) and together there are 

only 9 facilities nationwide with this capability (HHI = 5,568, 2,463, and 10,000 respectively). 

Similarly, desulfurization and catalytic hydrocracking are processes where there is at least 

moderate concentration (HHI 1,023, 5,109 respectively). Additionally, production of isooctane 

(isomerization) is concentrated with a HHI of 7,813. Overall, of the 31 products/processes 

captured in the DOE data, 7 of them are at least moderately concentrated. 

Because the petroleum refinery industry is moderately concentrated in PADD V and because the 

markets for some petroleum products were at least moderately concentrated, EPA concluded that 

the structure of the markets that exist within this source category warrant further evaluation of 

the “inputs to equations” data elements in subpart Y. Therefore, EPA further evaluated the 

“inputs to equations” data elements by examining each individual data element to determine if 

harm would be likely to occur. Refer to Part 2 of this memorandum for this evaluation.

4.3 Analysis of Subparts Representing Processes from Many Sectors

Subparts C, II, TT, and U have reporters from a large number of sectors. As opposed to many of 

the other source categories reporting under the Greenhouse Gas Reporting Program, these source 

categories are not defined by the types of products manufactured, or produced, at the facility. 

Instead, these subparts are defined by production processes or waste management processes (C, 

II, and TT) or inputs used (U). As a result, it is not possible to make a determination based on the 

subpart as a whole. Instead, whether information related to these source categories has the 

potential to cause competitive harm depends on the concentration of the markets in which the 

facilities sell their products rather than on the total number of facilities reporting under each 

source category. Thus, EPA determined that it would be necessary to identify the markets 

affected, and examine their market structure. 

For these subparts, EPA was able to conduct the first step of the evaluation, to examine the 

national-level HHI for the NAICS codes reported by facilities. However, for the NAICS codes 

where the national level 6-digit NAICS indicated unconcentrated HHIs, EPA did not proceed 

with evaluating each of the NAICS codes to determine whether regional or product-specific 

concentration occurred. Because these facilities come from a wide variety of sectors for which 

EPA does not have specific information beyond the 6-digit NAICS code provided, and because 

many of the NAICS reported for these sectors are not manufacturing NAICS codes, further 

analysis of each of these sectors would be resource-intensive, and would be likely to have a large 

uncertainty without obtaining additional information from the facilities on the specific markets in 

which these facilities operate. 

A summary of the results for the HHIs computed for these subparts is provided, by subpart, in 

Table 1. Refer to Appendix A for a complete list of the HHIs for NAICS codes reported by these 

facilities. EPA’s analysis of HHIs for manufacturing NAICS codes listed by facilities in these 
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subparts shows that some of the affected markets for goods produced by facilities in each of 

these subparts are concentrated or moderately concentrated. For these facilities, therefore, 

publishing the information contained in the “inputs to equations” data elements could potentially 

cause competitive harm or reduce competition. Due to the limitations of the market structure 

analysis for these subparts, and because the results of the analysis demonstrate that some of the 

facilities that report under these subparts are in sectors that are at least moderately concentrated 

at the national level, EPA proceeded to evaluate the individual data elements to determine if 

harm would likely occur (refer to Part Two of this memorandum). 

Table 1. Summary of National Level Herfindahl-Hirschman Index (HHI) for the Industry 

Sectors Subject to Subparts C, II, TT, and U 

Subpart # of NAICS 

Reported 

# of Reporters # of Facility 

reports of 

NAICS with 

HHIs,1,2

# of facility 

reports of 

NAICS with at 

least moderately 

concentrated 

HHIs1

Subpart C 295 5,780 2,382 985 

Subpart II 24 155 181 39 

Subpart TT 52 173 196 117 

Subpart U 13 18 20 8 

1

The number of facility reports may exceed the number of facilities, because some facilities report multiple NAICS codes. 

2

Includes only facility reports of NAICS codes with non-missing HHI values. 

4.4 Analysis of Non-Manufacturing Sectors 

As shown in Appendix A, HHIs were not available for subpart W14 (Petroleum and Natural Gas) 

and subpart CC (soda ash manufacturing). As a result, a qualitative analysis of the market 

structures that exist within these source categories was conducted. 

Subpart W: Petroleum and Natural Gas. 

                                                           

14 Of the 1,549 facilities that reported under subpart W in 2011, three facilities reported manufacturing NAICS codes for which 

HHIs are available and were moderately concentrated. Of these, one facility with a NAICS of 325181 (alkalies and chlorine 

manufacturing), reported a small amount of emissions under LNG storage. EPA determined that this LNG storage process is 

separable from the remainder of the facility and is unrelated to the alkalies and chlorine manufacturing market. EPA believes 

that the NAICS for the remaining two facilities were reported in error. 
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Subpart W includes facilities operating in eight related segments of the petroleum and natural gas 

sector. Because subpart W is not a manufacturing sector, HHIs were not available for the vast 

majority of facilities. As a result, EPA conducted a qualitative analysis of the segments within 

this sector. 

For each segment, EPA examined the market structure to determine if revelation of “inputs to 

equations” data elements by firms in that segment had the potential to cause competitive harm or 

reduce competition. For source categories that are in the manufacturing sector, as shown in 

Sections 4.1 and 4.2 of this memorandum, EPA examined concentration at the national level, as 

well as at the regional, product, or process level. Because of the unique nature of the subpart W 

source category with a relatively large number of producers selling a relatively homogeneous 

product, EPA determined that it would not be appropriate to assess the market structure at the 

product or process level. As a result, EPA considered the market structure of each segment as 

well as the types of information that are collected through this source category. EPA’s findings 

for each subpart W segment are reported below. 

Onshore Petroleum and Natural Gas Production 

The onshore petroleum and natural gas production segment covers emissions related to 

onshore production wellheads. The market structure for petroleum and natural gas was 

considered separately for this segment. Onshore petroleum production is a regionally 

concentrated market, with wells located in fixed geological formations. Decisions on where 

to drill wells may be based on proprietary information during the early development of a 

formation when lease prices have not stabilized and operators are taking risks by drilling 

explorations wells in formations that do not have proven production records. After several 

wells have been drilled in an area, information about production becomes publically 

available and the advantage incurred by the operator drilling exploration wells is lost. 

However, once a well has been drilled, decisions to produce are based on market prices and 

the ability to control flow from the well. Although this could pose a potential data sensitivity 

with respect to exploration wells, this issue is addressed by the fact that onshore production 

data is reported at a sub-basin level, as defined by county boundaries, and which is a large 

enough scale that disclosure of the data collected under subpart W would not reveal any 

proprietary information about the facility or cost to do business. As the likelihood of harm 

can be characterized for all information collected for this segment, EPA did not proceed to 

evaluate each “input to equation” data element in this segment. 

The onshore natural gas production market overlaps many of the geological formations of 

petroleum production. Furthermore, the market itself is structured the same, with a large 

number of operators within each formation. Like onshore oil production, disclosure of data 

for onshore natural gas production at the sub-basin level would also not reveal any 

proprietary information about the facility or cost to do business. As the likelihood of harm 
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can be characterized for all information collected for this segment, EPA did not proceed to 

evaluate each “input to equation” data element in this segment. 

Offshore Petroleum and Natural Gas Production 

Offshore petroleum and natural gas production includes emissions from offshore production 

platforms and does not include emissions from drilling and exploration that is not associated 

with production platforms. The products created on offshore production platforms are 

delivered into the same market as onshore petroleum and natural gas production, which is a 

competitive market. The reported data is specific to a latitude and longitude as identified by 

the facility but the data reported in offshore production does not include information specific 

to the formations from which hydrocarbons are being extracted and only information 

concerning the operations of the platform are reported. The operational information does not 

include information that the operator will find proprietary to the well and as a result, the 

information reported under offshore petroleum and natural gas production would not reveal 

any proprietary information about the facility or cost to do business. As the likelihood of 

harm can be characterized for all information collected for this segment, EPA did not 

proceed to evaluate each “input to equation” data element in this segment. 

Natural Gas Processing 

Natural gas processors are regionally located close to production wellheads. The market itself 

is large, with roughly 500 firms. These firms are located in close proximity to given natural 

gas plays. However, we do not believe that this regional concentration would pose data 

sensitivity issues because the “inputs to equations” data elements in this segment would not 

reveal any proprietary information about the facility, cost of natural gas, or cost to do 

business. As the likelihood of harm can be characterized for all information collected for this 

segment, EPA did not proceed to evaluate each “input to equation” data element in this 

segment. 

Natural Gas Transmission Compression 

Natural gas transmission compression operators transport natural gas from processors to end 

users. Firms are regionally concentrated, having control over particular segments of the 

pipeline infrastructure. Although the number of firms and the regional concentration could 

pose data sensitivity issues, we do not believe this is an issue for three reasons: (1) there are 

few technological secrets related to pipeline construction and natural gas transmission; 

technological innovation is mainly in the area of pipeline security; (2), the rate charged for 

transport is highly regulated, preventing use of the data for strategic price competition; and 

(3) once pipeline and compression are built in a given corridor, there is little incentive for a 

competitor to build additional pipeline and compression along the same route. As a result, the 

“inputs to equations” data elements in this segment would not reveal any proprietary 

information about the facility or cost to do business. As the likelihood of harm can be 
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characterized for all information collected for this segment, EPA did not proceed to evaluate 

each “input to equation” data element in this segment. 

Natural Gas Distribution 

Natural gas distributers own and operate the distribution mains and services and function as 

the middle man between transmission lines and end-users. This market is regionally located 

with distributers having exclusive access to specific cities and other localities. Both publiclyand privately-owned companies are highly regulated, unable to charge market based rates for 

service. The regulation by government and the monopoly rights distributors hold over given 

regions prevents competitors’ use of the data for strategic purposes. As a result, the “inputs to 

equations” data elements in this segment would not reveal any proprietary information about 

the facility or cost to do business. As the likelihood of harm can be characterized for all 

information collected for this segment, EPA did not proceed to evaluate each “input to 

equation” data element in this segment. 

Underground Natural Gas Storage 

Underground natural gas storage is used to smooth out volatility in consumption and use of 

natural gas. The market is regional; facilities are located either near major distribution centers 

or near oil and gas fields. Even with the regional market structure, competitors are not known 

to engage in strategic competition in building storage facilities. First, facilities are built in 

response to other upstream factors, such as increased gas supply coming to distributors, not 

to undermine other competitors. Second, storage firms are constrained by the geographical 

and geological requirements needed for underground storage, preventing firms from moving 

in and increasing their market share. Finally, storage technology is widely known and not 

used to garner a competitive advantage. As a result, the “inputs to equations” data elements 

in this segment would not reveal any proprietary information about the facility or cost to do 

business. As the likelihood of harm can be characterized for all information collected for this 

segment, EPA did not proceed to evaluate each “input to equation” data element in this 

segment. 

Liquefied Natural Gas Storage 

Liquefied Natural Gas (LNG) storage operates much the same as underground natural gas 

storage, with storage used to smooth volatility related to consumption. The small size of the 

LNG storage market could create the possibilities for disruptive competitive undercutting; 

however, there we determined that this is unlikely for the following two reasons. First, LNG 

storage is primarily owned by highly regulated distributors, preventing competitive firms 

from undercutting the market. Second, LNG storage occurs in response to increase supply 

upstream or decreased demand downstream, and is not responsive to cost advantages. As a 

result, the “inputs to equations” data elements in this segment would not reveal any 

proprietary information about the facility or cost to do business. As the likelihood of harm 
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can be characterized for all information collected for this segment, EPA did not proceed to 

evaluate each “input to equation” data element in this segment. 

Liquefied Natural Gas Import/Export 

Currently the U.S. has only twelve LNG import terminals and one LNG export terminal. 

There are nine onshore import terminals and three offshore import terminals. LNG 

technology is not proprietary. The technology is relatively simple and has been around for 

many years. The market is regional and small with import terminals located along the Gulf 

and East coasts. Although there are a small number of facilities that import and/or export 

LNG, they may be viewed as a part of the larger natural gas supply sector that is a much 

larger market. The product delivered or consumed by LNG Import/Export is identical to the 

product generated in onshore and offshore natural gas production. Functionally, Import and 

Export terminals may be considered as a large producer or consumer of natural gas. Import 

and Export terminals are generally located in regions of supply restrictions or excess to 

maximize price margins. However, the trading prices of natural gas is publically available 

and the building of new import and export terminals is limited by capital and permitting, not 

by market structure. Therefore, release of information about import/export terminals would 

not change the operations of other firms in the market. As a result, the “inputs to equations” 

data elements in this segment would not reveal any proprietary information about the facility 

or cost to do business. As the likelihood of harm can be characterized for all information 

collected for this segment, EPA did not proceed to evaluate each “input to equation” data 

element in this segment. 

In summary, EPA determined that, for all of the industry segments within Subpart W, either the 

data are reported at a level of geographical aggregation that protects individual well information, 

or the markets in which the affected firms operate are structured in ways that disclosure of 

“inputs to equations” data elements would not be likely to cause competitive harm. As a result, 

EPA did not further evaluate the “inputs to equations” data elements in Subpart W. 

Subpart CC, Soda Ash. The four facilities reporting under subpart CC in 2011 identified NAICS 

212391, Potash, Soda, and Borate Mineral Mining. This is not a manufacturing NAICS, so HHI 

is not published for it. However, there are only 18 firms in this sector nationwide.15 If a sector 

that has 18 firms nationwide includes a few firms with relatively large market share (as opposed 

to a sector where all firms are similar size, and each has roughly 1/18 share of the market), it is 

likely to be concentrated. As a result, EPA concluded that the structure of the markets that exist 

within this source category warrant further evaluation of the “inputs to equations” data elements 

in subpart CC. Therefore, EPA further evaluated the “inputs to equations” data elements by 

examining each individual data element to determine if harm would be likely to occur. Refer to 

Part 2 of this memorandum for this evaluation. 

                                                           

15 U.S.Census Bureau. Statistics of U.S. Businesses, 2010. NAICS 212391. http://www.census.gov/econ/susb/ 
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5.0 Summary 

In this part, EPA examined the market structures for subparts with “inputs to equations” data 

elements to determine whether conditions exist within the market structure such that release of 

these data could result in competitive harm. EPA determined that such conditions exist within 

the market structures for all of the subparts examined except for facilities reporting under subpart 

W. As a result, EPA did not further evaluate competitive harm for facilities reporting under 

subpart W. For the “inputs to equations” data elements in the remaining 26 subparts examined, 

EPA further evaluated the data elements by examining each individual data element to determine 

if harm would be likely to occur. Refer to Part 2 of this memorandum for this evaluation. 
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Part Two: Evaluation of Individual Data Elements 

1.0 Introduction 

As discussed in Part One of this memorandum, EPA determined that conditions exist within the 

market structures such that competitive harm could occur should certain types of information be 

released for all of the subparts examined in this memorandum except for facilities reporting 

under subpart W. As a result, no further evaluation of competitive harm was conducted for this 

source category. The remaining “inputs to equations” data elements in 26 subparts were further 

evaluated by examining individual data elements to determine if harm would be likely to occur. 

2.0 Evaluation of Harm 

Based on EPA’s previous consideration of competitive harm (see proposed CBI rule, 75 FR 

39115 – 39116, July 7, 2010), EPA’s previous consideration of comments received on the 

proposed CBI rule (see final CBI rule, 76 FR 30806, May 26, 2011), and EPA’s more recent 

consideration of comments received on the Call for Information (75 FR 81366, December 27, 

2010), EPA identified certain types of data that would reveal information that likely cause 

competitive harm, if reported and publicly released. These data include: 

 The quantity or composition of raw materials or products; or 

 Process design, process performance and operation, and cost to do business. 

Additionally, EPA determined that many other “inputs to equations” data elements, which alone 

would not reveal information that could cause competitive harm, would reveal the types of data 

specified above if known together with certain additional data elements (i.e., multiple reported 

“inputs to equations” data elements would be needed to back-calculate the types of data specified 

above). 

Under this evaluation, each individual “inputs to equations” data element was evaluated to 

determine whether it includes any of these types of data, as further discussed below. In all, 525 

“inputs to equations” data elements (excluding “inputs to equations” for facilities subject to 

subpart W) were reviewed according to the process described in this section. Refer to Appendix 

B for results of the analysis for each of the 525 data elements. 

2.1 Quantity and Composition of Raw Materials or Products 

EPA has determined in previous GHGRP actions that publicly releasing facility-specific data on 

the quantity or composition of raw materials or products would likely cause competitive harm. In 

these previous actions, EPA finalized CBI determinations for such data currently reported under 

Part 98 (e.g., production rates that are currently collected under Part 98, but not used to calculate 

GHG emissions). As further discussed in the proposed CBI rule, disclosing a facility’s 

production or throughput data would be detrimental to a firm’s competitiveness by revealing 

confidential process information and operational and marketing strategies, as follows: 
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 Annual production quantities, used in conjunction with other publicly available data 

related to capacity, provide insight into a firm’s operational strengths and weaknesses. 

Competitors could determine at what percent capacity a firm is operating, which can 

reveal information on the financial and competitive strength of the firm; 

 Disclosing a facility’s production or throughput quantities and product compositions 

could give competitors insight into a firm’s local and regional market conditions and 

expansion plans, enabling competitors to devise strategies to prevent expansion and to 

steal market share in specific locations; and 

 Disclosing a facility’s feedstock quantities and composition and reactants fed into 

particular processes at a facility could provide insight into a facility’s operational 

strengths and weaknesses, expose a firm’s competitive and marketing strategies, or 

reveal a firm’s suppliers and sourcing strategies. 

Refer to the preamble to the proposed CBI determinations (75 FR 39115 – 39116, July 7, 2010) 

for a more detailed discussion on why reporting production and raw material information would 

be likely to cause competitive harm. 

Under this evaluation, we identified all “inputs to equations” data elements that require reporting 

of data related to the quantity or composition of raw materials or products. We evaluated these 

data elements to identify any attributes in the data elements that would distinguish them as less 

likely to cause competitive harm if released than those data elements previously determined to be 

CBI (see reference above to previously proposed CBI determinations). We concluded that all 

such data elements identified under this analysis would be as likely to cause competitive harm as 

those previously identified. 

Data elements determined to include a requirement to report the quantity or composition of raw 

materials or products are identified in Appendix B. 

2.2 Data Related to Process Design, Process Performance and Operation, and Cost to Do 

Business 

Based on a review of comments on the Call for Information (75 FR 81366, December 27, 2010) 

and on previous actions under the GHGRP, EPA has determined that data related to process 

design, process performance and operation, and cost to do business would reveal the following 

information: 

 Disclosing process design information could be detrimental to a firm’s competitiveness 

by revealing design efficiency of the unit, providing insight to a firm’s operational 

strengths and weaknesses (e.g., disclosing the ratio of the maximum rate heat input 

capacity to the design rated steam output capacity of a combustion unit (not connected to 

the electric power grid) would disclose the design efficiency of the unit; 

 Disclosing process performance and operation information could be detrimental to a 

firm’s competitiveness by revealing process efficiency, providing insight to a firm’s 

operational strengths and weaknesses (e.g., disclosing an aluminum production facility’s 

cell performance would disclose current production efficiency);and 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

20

 Disclosing information related to the cost to do business could be detrimental to a firm’s 

competitiveness by providing insight to a firm’s operational strengths and weaknesses 

(e.g., disclosing an HCFC production facility’s loss factor, which accounts for the loss 

of HCFC-22 upstream of a measurement, would reveal the amount of product that is 

lost). 

Data elements determined to include a requirement to report the type of information described 

above are identified in Appendix B. 

2.3 Other Data that Would Likely Reveal the Types of Data Specified Above if Certain 

Additional Data Are Also Known 

An additional evaluation was conducted to determine whether each “inputs to equations” data 

element not related to the quantity or composition of raw materials or products (see section 2.1), 

in combination with currently reported data elements and other “inputs to equations” data 

elements could be used to back-calculate the types of data specified in sections 2.1 and 2.2 (e.g., 

production quantity, cost to do business). For example, for a nitric acid production facility, the 

abatement technology destruction efficiency, if reported alone, would not reveal any information 

that would likely cause harm; however, if reported together with the abatement utilization factor, 

emission factor, and reported N2O emissions, it could be used to back-calculate an estimate of 

the mass of nitric acid produced, which is the type of data identified in section 2.1 of this 

memorandum. Data elements determined to reveal proprietary information in this way are 

identified in Appendix B. 

 For any such data elements identified, EPA also determined if such harm could be avoided by 

removing the reporting requirement for certain additional data elements. For example, if the 

abatement utilization factor were reported (as required under §98.226(j)), together with annual 

N2O emissions from nitric acid production (in §98.3(c)(4)), the emission factor (in 

§98.226(m)(1)), and the destruction efficiency (in §98.226(i)), these data together could be used 

to calculate the mass of nitric acid produced. However, if reporting of the emission factor were 

removed, the abatement utilization factor could be reported without revealing proprietary 

information about nitric acid production. Any such “inputs to equations” data elements are 

identified in Appendix B. 

3.0 Summary 

Based on the results of Part One and Part two of this memorandum, EPA proceeded to Step 3 of 

the evaluation for 25 of the 27 subparts evaluated in this memorandum. EPA did not proceed to 

Step 3 of the evaluation for subpart W (Petroleum and Natural Gas Systems) and Subpart II 

(Industrial Wastewater Treatment). 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

21

Appendix A 

Subpart Sector Concentration Assessment, National NAICS Code Level
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

22

Table A-1. Subpart Sector Concentration Assessment, National NAICS Code Level 

Subpart NAICS 

Number of 

Subpart C 

Facilities Affected 

by 2015 Deferral 1

HHI, 

VOS 2

HHI, 

VA 2 Finding 

C Combustion 111419 1 N/A N/A N/A 

C Combustion 111930 1 N/A N/A N/A 

C Combustion 112340 1 N/A N/A N/A 

C Combustion 113310 1 N/A N/A N/A 

C Combustion 115114 3 N/A N/A N/A 

C Combustion 211111 453 N/A N/A N/A 

C Combustion 211112 232 N/A N/A N/A 

C Combustion 212111 6 N/A N/A N/A 

C Combustion 212112 28 N/A N/A N/A 

C Combustion 212113 2 N/A N/A N/A 

C Combustion 212210 8 N/A N/A N/A 

C Combustion 212221 5 N/A N/A N/A 

C Combustion 212222 1 N/A N/A N/A 

C Combustion 212231 2 N/A N/A N/A 

C Combustion 212234 5 N/A N/A N/A 

C Combustion 212311 1 N/A N/A N/A 

C Combustion 212312 7 N/A N/A N/A 

C Combustion 212313 1 N/A N/A N/A 

C Combustion 212322 2 N/A N/A N/A 

C Combustion 212324 14 N/A N/A N/A 

C Combustion 212325 9 N/A N/A N/A 

C Combustion 212391 10 N/A N/A N/A 

C Combustion 212392 2 N/A N/A N/A 

C Combustion 212399 8 N/A N/A N/A 

C Combustion 213112 81 N/A N/A N/A 

C Combustion 213113 1 N/A N/A N/A 

C Combustion 213115 1 N/A N/A N/A 

C Combustion 221111 2 N/A N/A N/A 

C Combustion 221112 1008 N/A N/A N/A 

C Combustion 221113 3 N/A N/A N/A 

C Combustion 221119 37 N/A N/A N/A 

C Combustion 221121 1 N/A N/A N/A 

C Combustion 221122 11 N/A N/A N/A 

C Combustion 221210 222 N/A N/A N/A 

C Combustion 221310 9 N/A N/A N/A 

C Combustion 221320 7 N/A N/A N/A 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

23

Subpart NAICS 

Number of 

Subpart C 

Facilities Affected 

by 2015 Deferral 1

HHI, 

VOS 2

HHI, 

VA 2 Finding 

C Combustion 221330 72 N/A N/A N/A 

C Combustion 237120 2 N/A N/A N/A 

C Combustion 311119 6 285.4 290.2 Unconcentrated 

C Combustion 311213 6 N/A N/A N/A 

C Combustion 311221 23 2,338.2 2,291.2 Concentrated 

C Combustion 311222 41 1,930.8 2,496.1 Concentrated 

C Combustion 311223 3 2,752.7 2,221.5 Concentrated 

C Combustion 311225 11 1,030.3 950.2 Moderately Concentrated 

C Combustion 311230 10 2,425.5 2,909.0 Concentrated 

C Combustion 311311 2 N/A N/A N/A 

C Combustion 311312 5 N/A N/A N/A 

C Combustion 311313 22 N/A N/A N/A 

C Combustion 311330 1 1,547.6 1,730.0 Moderately Concentrated 

C Combustion 311411 23 586.6 648.1 Unconcentrated 

C Combustion 311421 22 254.8 295.2 Unconcentrated 

C Combustion 311422 7 2,885.1 D Concentrated 

C Combustion 311423 4 486.3 500.3 Unconcentrated 

C Combustion 311511 3 1,075.3 1,265.7 Moderately Concentrated 

C Combustion 311512 2 2,283.3 2,170.1 Concentrated 

C Combustion 311513 6 379.3 308.2 Unconcentrated 

C Combustion 311514 13 651.8 1,548.8 Moderately Concentrated 

C Combustion 311611 33 1,046.5 644.0 Moderately Concentrated 

C Combustion 311612 13 258.1 330.3 Unconcentrated 

C Combustion 311613 39 645.6 800.5 Unconcentrated 

C Combustion 311615 18 737.6 937.0 Unconcentrated 

C Combustion 311711 1 1,254.9 1,107.8 Moderately Concentrated 

C Combustion 311821 1 1,607.2 1,987.3 Concentrated 

C Combustion 311911 1 413.4 716.1 Unconcentrated 

C Combustion 311919 7 D D N/A 

C Combustion 311920 3 763.1 939.2 Unconcentrated 

C Combustion 311942 9 479.5 701.5 Unconcentrated 

C Combustion 311991 1 273.0 257.4 Unconcentrated 

C Combustion 311999 7 168.2 161.7 Unconcentrated 

C Combustion 312120 19 D D N/A 

C Combustion 312130 1 584.0 595.1 Unconcentrated 

C Combustion 312140 8 1,519.4 2,373.6 Concentrated 

C Combustion 312221 2 N/A N/A N/A 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

24

Subpart NAICS 

Number of 

Subpart C 

Facilities Affected 

by 2015 Deferral 1

HHI, 

VOS 2

HHI, 

VA 2 Finding 

C Combustion 312229 1 2,744.6 D Concentrated 

C Combustion 313210 1 253.9 259.0 Unconcentrated 

C Combustion 313230 1 778.2 1,043.9 Moderately Concentrated 

C Combustion 313311 5 209.5 247.3 Unconcentrated 

C Combustion 313312 3 277.2 292.9 Unconcentrated 

C Combustion 314110 5 1,649.7 1,728.5 Moderately Concentrated 

C Combustion 315191 1 537.5 633.9 Unconcentrated 

C Combustion 316110 2 560.3 466.8 Unconcentrated 

C Combustion 321113 9 98.3 59.8 Unconcentrated 

C Combustion 321114 1 385.7 293.7 Unconcentrated 

C Combustion 321211 2 415.1 311.8 Unconcentrated 

C Combustion 321212 3 1,233.3 1,408.3 Moderately Concentrated 

C Combustion 321219 13 345.0 322.8 Unconcentrated 

C Combustion 321999 1 65.1 90.1 Unconcentrated 

C Combustion 322110 58 1,023.5 1,235.7 Moderately Concentrated 

C Combustion 322121 122 758.9 1,036.2 Moderately Concentrated 

C Combustion 322122 9 X X N/A 

C Combustion 322130 69 713.1 768.6 Unconcentrated 

C Combustion 322213 1 696.2 527.7 Unconcentrated 

C Combustion 322222 3 630.1 1,274.5 Moderately Concentrated 

C Combustion 322224 1 1,043.0 1,117.7 Moderately Concentrated 

C Combustion 322291 7 1,317.8 1,789.4 Moderately Concentrated 

C Combustion 322299 1 187.7 256.3 Unconcentrated 

C Combustion 323110 3 96.6 86.6 Unconcentrated 

C Combustion 323111 3 1,359.5 1,430.7 Moderately Concentrated 

C Combustion 324110 146 806.5 811.6 Unconcentrated 

C Combustion 324121 2 188.4 206.4 Unconcentrated 

C Combustion 324191 4 794.5 1,902.5 Concentrated 

C Combustion 324199 31 739.8 617.1 Unconcentrated 

C Combustion 325110 45 2,535.2 D Concentrated 

C Combustion 325120 37 1,415.2 1,377.8 Moderately Concentrated 

C Combustion 325131 7 1,265.0 1,293.6 Moderately Concentrated 

C Combustion 325132 3 837.6 803.9 Unconcentrated 

C Combustion 325181 13 2,391.7 2,428.2 Concentrated 

C Combustion 325182 16 N/A N/A N/A 

C Combustion 325188 63 223.5 303.4 Unconcentrated 

C Combustion 325191 6 2,389.8 D Concentrated 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

25

Subpart NAICS 

Number of 

Subpart C 

Facilities Affected 

by 2015 Deferral 1

HHI, 

VOS 2

HHI, 

VA 2 Finding 

C Combustion 325192 19 2,328.9 D Concentrated 

C Combustion 325193 172 275.1 298.0 Unconcentrated 

C Combustion 325199 111 360.5 289.0 Unconcentrated 

C Combustion 325211 96 400.4 546.4 Unconcentrated 

C Combustion 325212 10 727.8 717.4 Unconcentrated 

C Combustion 325221 2 N/A N/A N/A 

C Combustion 325222 12 2,071.1 2,246.5 Concentrated 

C Combustion 325311 36 1,135.6 1,214.9 Moderately Concentrated 

C Combustion 325312 17 D 2,777.2 Concentrated 

C Combustion 325320 9 1,109.1 1,632.2 Moderately Concentrated 

C Combustion 325411 12 1,423.7 1,299.9 Moderately Concentrated 

C Combustion 325412 26 456.8 532.6 Unconcentrated 

C Combustion 325413 2 759.9 792.3 Unconcentrated 

C Combustion 325414 9 946.9 890.5 Unconcentrated 

C Combustion 325510 4 539.8 504.9 Unconcentrated 

C Combustion 325520 2 234.8 276.6 Unconcentrated 

C Combustion 325611 6 2,025.3 2,362.8 Concentrated 

C Combustion 325612 3 1,164.4 1,346.0 Moderately Concentrated 

C Combustion 325613 8 2,353.1 859.5 Concentrated 

C Combustion 325620 1 1,220.6 751.2 Moderately Concentrated 

C Combustion 325910 1 906.0 1,188.8 Moderately Concentrated 

C Combustion 325920 2 920.7 1,037.2 Moderately Concentrated 

C Combustion 325991 2 290.0 313.0 Unconcentrated 

C Combustion 325992 3 1,888.0 2,202.9 Concentrated 

C Combustion 325998 19 158.4 212.6 Unconcentrated 

C Combustion 326113 8 185.7 228.4 Unconcentrated 

C Combustion 326121 3 333.3 409.6 Unconcentrated 

C Combustion 326130 1 485.9 666.1 Unconcentrated 

C Combustion 326140 3 783.5 667.2 Unconcentrated 

C Combustion 326191 1 356.8 320.3 Unconcentrated 

C Combustion 326199 2 26.3 26.7 Unconcentrated 

C Combustion 326211 19 1,734.7 1,893.2 Concentrated 

C Combustion 326291 1 274.5 254.6 Unconcentrated 

C Combustion 326299 1 292.8 89.4 Unconcentrated 

C Combustion 327111 2 D D N/A 

C Combustion 327121 2 616.0 681.5 Unconcentrated 

C Combustion 327122 6 1,542.2 1,824.0 Concentrated 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

26

Subpart NAICS 

Number of 

Subpart C 

Facilities Affected 

by 2015 Deferral 1

HHI, 

VOS 2

HHI, 

VA 2 Finding 

C Combustion 327125 2 819.2 932.7 Unconcentrated 

C Combustion 327211 27 N/A N/A N/A 

C Combustion 327212 23 516.8 582.6 Unconcentrated 

C Combustion 327213 44 2,506.6 2,468.8 Concentrated 

C Combustion 327215 5 332.0 341.6 Unconcentrated 

C Combustion 327310 81 609.9 651.3 Unconcentrated 

C Combustion 327390 1 127.7 140.7 Unconcentrated 

C Combustion 327410 49 1,424.1 1,394.2 Moderately Concentrated 

C Combustion 327420 43 1,553.6 1,492.1 Moderately Concentrated 

C Combustion 327910 3 1,662.4 2,197.7 Concentrated 

C Combustion 327992 10 615.8 648.0 Unconcentrated 

C Combustion 327993 22 936.4 1,031.9 Moderately Concentrated 

C Combustion 327999 5 651.8 666.0 Unconcentrated 

C Combustion 331111 117 785.6 906.8 Unconcentrated 

C Combustion 331112 11 N/A N/A N/A 

C Combustion 331210 8 435.6 741.5 Unconcentrated 

C Combustion 331221 13 402.1 441.8 Unconcentrated 

C Combustion 331222 2 296.9 312.4 Unconcentrated 

C Combustion 331311 6 N/A N/A N/A 

C Combustion 331312 11 2,250.3 D Concentrated 

C Combustion 331314 22 930.8 2,019.9 Concentrated 

C Combustion 331315 14 1,995.3 1,852.0 Concentrated 

C Combustion 331316 6 433.3 394.7 Unconcentrated 

C Combustion 331319 2 1,119.8 1,391.6 Moderately Concentrated 

C Combustion 331411 4 N/A N/A N/A 

C Combustion 331419 9 598.6 1,080.3 Moderately Concentrated 

C Combustion 331421 3 1,134.3 910.9 Moderately Concentrated 

C Combustion 331423 2 1,217.4 1,849.4 Concentrated 

C Combustion 331491 4 818.3 727.7 Unconcentrated 

C Combustion 331492 21 344.0 345.6 Unconcentrated 

C Combustion 331511 28 337.5 324.7 Unconcentrated 

C Combustion 331513 3 458.1 542.1 Unconcentrated 

C Combustion 331521 7 371.7 364.5 Unconcentrated 

C Combustion 331522 2 366.2 417.3 Unconcentrated 

C Combustion 331524 5 288.8 306.4 Unconcentrated 

C Combustion 331528 2 624.4 763.8 Unconcentrated 

C Combustion 332111 7 203.0 194.2 Unconcentrated 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

27

Subpart NAICS 

Number of 

Subpart C 

Facilities Affected 

by 2015 Deferral 1

HHI, 

VOS 2

HHI, 

VA 2 Finding 

C Combustion 332112 4 888.4 1,034.3 Moderately Concentrated 

C Combustion 332211 1 1,373.0 1,571.5 Moderately Concentrated 

C Combustion 332323 1 93.1 70.5 Unconcentrated 

C Combustion 332618 1 65.6 57.9 Unconcentrated 

C Combustion 332811 2 264.5 186.8 Unconcentrated 

C Combustion 332812 5 181.9 140.0 Unconcentrated 

C Combustion 332813 2 61.0 19.6 Unconcentrated 

C Combustion 332913 1 1,532.2 1,810.9 Concentrated 

C Combustion 332991 1 1,834.1 1,893.2 Concentrated 

C Combustion 332992 2 2,446.7 D Concentrated 

C Combustion 332993 1 2,015.9 2,220.3 Concentrated 

C Combustion 332996 1 215.5 197.2 Unconcentrated 

C Combustion 332998 1 1,312.0 1,611.5 Moderately Concentrated 

C Combustion 332999 2 25.3 23.9 Unconcentrated 

C Combustion 333111 2 1,828.5 2,371.9 Concentrated 

C Combustion 333120 4 1,143.3 1,076.5 Moderately Concentrated 

C Combustion 333131 2 546.1 624.3 Unconcentrated 

C Combustion 333315 1 1,831.1 1,873.4 Concentrated 

C Combustion 333415 1 510.7 527.4 Unconcentrated 

C Combustion 333511 1 21.0 17.9 Unconcentrated 

C Combustion 333514 1 53.1 34.2 Unconcentrated 

C Combustion 333516 2 1,139.4 1,066.8 Moderately Concentrated 

C Combustion 333611 1 1,937.0 1,464.6 Concentrated 

C Combustion 333612 2 352.0 347.9 Unconcentrated 

C Combustion 333618 6 1,022.1 1,089.4 Moderately Concentrated 

C Combustion 333992 1 1,051.7 1,127.5 Moderately Concentrated 

C Combustion 334411 3 1,402.1 1,535.7 Moderately Concentrated 

C Combustion 334413 49 1,283.6 1,929.1 Concentrated 

C Combustion 334515 1 544.5 623.3 Unconcentrated 

C Combustion 335224 2 N/A N/A N/A 

C Combustion 335313 3 718.8 693.8 Unconcentrated 

C Combustion 335929 1 479.8 423.3 Unconcentrated 

C Combustion 335991 2 620.6 650.3 Unconcentrated 

C Combustion 336111 18 1,448.8 1,548.7 Moderately Concentrated 

C Combustion 336112 19 2,679.5 D Concentrated 

C Combustion 336211 1 243.0 202.1 Unconcentrated 

C Combustion 336312 3 931.4 712.4 Unconcentrated 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

28

Subpart NAICS 

Number of 

Subpart C 

Facilities Affected 

by 2015 Deferral 1

HHI, 

VOS 2

HHI, 

VA 2 Finding 

C Combustion 336330 2 541.1 626.3 Unconcentrated 

C Combustion 336350 7 554.3 560.7 Unconcentrated 

C Combustion 336360 1 1,369.8 864.2 Moderately Concentrated 

C Combustion 336370 4 385.8 456.6 Unconcentrated 

C Combustion 336399 4 80.9 71.2 Unconcentrated 

C Combustion 336411 11 D D N/A 

C Combustion 336412 6 2,421.8 2,304.8 Concentrated 

C Combustion 336413 5 674.4 752.7 Unconcentrated 

C Combustion 336414 1 N/A N/A N/A 

C Combustion 336415 3 N/A N/A N/A 

C Combustion 336510 3 951.6 1,177.7 Moderately Concentrated 

C Combustion 336611 2 1,545.7 1,838.9 Concentrated 

C Combustion 336992 4 2,477.1 2,575.9 Concentrated 

C Combustion 337211 1 550.7 565.8 Unconcentrated 

C Combustion 337214 1 1,285.2 1,442.8 Moderately Concentrated 

C Combustion 339112 1 245.2 267.4 Unconcentrated 

C Combustion 339999 4 274.5 386.1 Unconcentrated 

C Combustion 423110 2 N/A N/A N/A 

C Combustion 423120 1 N/A N/A N/A 

C Combustion 423320 1 N/A N/A N/A 

C Combustion 423720 1 N/A N/A N/A 

C Combustion 423990 1 N/A N/A N/A 

C Combustion 424690 2 N/A N/A N/A 

C Combustion 424710 5 N/A N/A N/A 

C Combustion 424910 1 N/A N/A N/A 

C Combustion 481111 2 N/A N/A N/A 

C Combustion 484220 1 N/A N/A N/A 

C Combustion 486110 5 N/A N/A N/A 

C Combustion 486210 504 N/A N/A N/A 

C Combustion 486990 3 N/A N/A N/A 

C Combustion 488119 4 N/A N/A N/A 

C Combustion 488190 2 N/A N/A N/A 

C Combustion 488210 1 N/A N/A N/A 

C Combustion 488310 1 N/A N/A N/A 

C Combustion 493110 1 N/A N/A N/A 

C Combustion 493190 2 N/A N/A N/A 

C Combustion 525920 1 N/A N/A N/A 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

29

Subpart NAICS 

Number of 

Subpart C 

Facilities Affected 

by 2015 Deferral 1

HHI, 

VOS 2

HHI, 

VA 2 Finding 

C Combustion 531110 2 N/A N/A N/A 

C Combustion 531120 1 N/A N/A N/A 

C Combustion 541380 3 N/A N/A N/A 

C Combustion 541611 1 N/A N/A N/A 

C Combustion 541711 6 N/A N/A N/A 

C Combustion 541712 15 N/A N/A N/A 

C Combustion 541940 1 N/A N/A N/A 

C Combustion 541990 1 N/A N/A N/A 

C Combustion 551114 1 N/A N/A N/A 

C Combustion 561210 4 N/A N/A N/A 

C Combustion 561990 1 N/A N/A N/A 

C Combustion 562111 1 N/A N/A N/A 

C Combustion 562211 6 N/A N/A N/A 

C Combustion 562212 595 N/A N/A N/A 

C Combustion 562213 74 N/A N/A N/A 

C Combustion 562910 2 N/A N/A N/A 

C Combustion 562920 3 N/A N/A N/A 

C Combustion 562998 1 N/A N/A N/A 

C Combustion 611310 113 N/A N/A N/A 

C Combustion 611610 1 N/A N/A N/A 

C Combustion 621111 1 N/A N/A N/A 

C Combustion 622110 25 N/A N/A N/A 

C Combustion 713110 1 N/A N/A N/A 

C Combustion 721120 4 N/A N/A N/A 

C Combustion 722110 1 N/A N/A N/A 

C Combustion 811111 2 N/A N/A N/A 

C Combustion 812921 1 N/A N/A N/A 

C Combustion 813990 2 N/A N/A N/A 

C Combustion 921120 2 N/A N/A N/A 

C Combustion 921150 1 N/A N/A N/A 

C Combustion 921190 3 N/A N/A N/A 

C Combustion 922140 3 N/A N/A N/A 

C Combustion 923110 3 N/A N/A N/A 

C Combustion 924110 1 N/A N/A N/A 

C Combustion 926130 1 N/A N/A N/A 

C Combustion 926140 1 N/A N/A N/A 

C Combustion 928110 50 N/A N/A N/A 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

30

Subpart NAICS 

Number of 

Subpart C 

Facilities Affected 

by 2015 Deferral 1

HHI, 

VOS 2

HHI, 

VA 2 Finding 

E Adipic Acid 325120 1 1,415.2 1,377.8 Moderately Concentrated 

E Adipic Acid 325199 3 360.5 289.0 Unconcentrated 

E Adipic Acid 325211 1 400.4 546.4 Unconcentrated 

E Adipic Acid 325311 1 1,135.6 1,214.9 Moderately Concentrated 

F Aluminum 221112 1 N/A N/A N/A 

F Aluminum 331312 11 2,250.3 D Concentrated 

F Aluminum 331314 1 930.8 2,019.9 Concentrated 

F Aluminum 331316 1 433.3 394.7 Unconcentrated 

F Aluminum 331319 1 1,119.8 1,391.6 Moderately Concentrated 

G Ammonia 221210 1 N/A N/A N/A 

G Ammonia 221330 1 N/A N/A N/A 

G Ammonia 325120 1 1,415.2 1,377.8 Moderately Concentrated 

G Ammonia 325188 1 223.5 303.4 Unconcentrated 

G Ammonia 325199 1 360.5 289.0 Unconcentrated 

G Ammonia 325311 20 1,135.6 1,214.9 Moderately Concentrated 

G Ammonia 325312 1 D 2,777.2 Concentrated 

H Cement 212312 3 N/A N/A N/A 

H Cement 327310 96 609.9 651.3 Unconcentrated 

H Cement 327999 1 651.8 666.0 Unconcentrated 

H Cement 562211 2 274.5 386.1 Unconcentrated 

K Ferroalloy 325120 1 N/A N/A N/A 

K Ferroalloy 325199 1 360.5 289.0 Unconcentrated 

K Ferroalloy 331112 9 N/A N/A N/A 

L Fluorinated Gas 325110 1 2,535.2 D Concentrated 

L Fluorinated Gas 325120 12 1,415.2 1,377.8 Moderately Concentrated 

L Fluorinated Gas 325188 3 223.5 303.4 Unconcentrated 

L Fluorinated Gas 325199 1 360.5 289.0 Unconcentrated 

L Fluorinated Gas 325211 7 400.4 546.4 Unconcentrated 

L Fluorinated Gas 325222 1 2,071.1 2,246.5 Concentrated 

L Fluorinated Gas 325613 2 2,353.1 859.5 Concentrated 

L Fluorinated Gas 325998 4 158.4 212.6 Unconcentrated 

L Fluorinated Gas 326113 1 185.7 228.4 Unconcentrated 

L Fluorinated Gas 326121 1 333.3 409.6 Unconcentrated 

L Fluorinated Gas 327910 1 1,662.4 2,197.7 Concentrated 

L Fluorinated Gas 562211 1 N/A N/A N/A 

N Glass 325613 1 2,353.1 859.5 Concentrated 

N Glass 325998 1 158.4 212.6 Unconcentrated 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

31

Subpart NAICS 

Number of 

Subpart C 

Facilities Affected 

by 2015 Deferral 1

HHI, 

VOS 2

HHI, 

VA 2 Finding 

N Glass 326113 2 185.7 228.4 Unconcentrated 

N Glass 326121 1 333.3 409.6 Unconcentrated 

N Glass 326299 1 292.8 89.4 Unconcentrated 

N Glass 327111 1 D D N/A 

N Glass 327211 27 N/A N/A N/A 

N Glass 327212 23 516.8 582.6 Unconcentrated 

N Glass 327213 44 2,506.6 2,468.8 Concentrated 

N Glass 327215 1 332.0 341.6 Unconcentrated 

N Glass 327910 1 1,662.4 2,197.7 Concentrated 

N Glass 327993 15 936.4 1,031.9 Moderately Concentrated 

N Glass 331511 1 337.5 324.7 Unconcentrated 

N Glass 332913 1 1,532.2 1,810.9 Concentrated 

N Glass 332998 1 1,312.0 1,611.5 Moderately Concentrated 

N Glass 333618 1 1,022.1 1,089.4 Moderately Concentrated 

N Glass 562211 1 N/A N/A N/A 

O HCFR-22, HCFC-23 325110 1 2,535.2 D Concentrated 

O HCFR-22, HCFC-23 325120 5 1,415.2 1,377.8 Moderately Concentrated 

O HCFR-22, HCFC-23 325188 2 223.5 303.4 Unconcentrated 

O HCFR-22, HCFC-23 325211 3 400.4 546.4 Unconcentrated 

O HCFR-22, HCFC-23 325222 1 2,071.1 2,246.5 Concentrated 

O HCFR-22, HCFC-23 325998 1 158.4 212.6 Unconcentrated 

P Hydrogen 324110 57 806.5 811.6 Unconcentrated 

P Hydrogen 324191 1 794.5 1,902.5 Concentrated 

P Hydrogen 324199 1 739.8 617.1 Unconcentrated 

P Hydrogen 325110 2 2,535.2 D Concentrated 

P Hydrogen 325120 45 1,415.2 1,377.8 Moderately Concentrated 

P Hydrogen 325188 1 223.5 303.4 Unconcentrated 

P Hydrogen 325199 4 360.5 289.0 Unconcentrated 

P Hydrogen 325211 1 400.4 546.4 Unconcentrated 

P Hydrogen 325311 1 1,135.6 1,214.9 Moderately Concentrated 

P Hydrogen 325613 1 2,353.1 859.5 Concentrated 

P Hydrogen 325998 1 158.4 212.6 Unconcentrated 

P Hydrogen 424710 1 N/A N/A N/A 

Q Iron &Steel 212210 8 N/A N/A N/A 

Q Iron &Steel 324199 12 739.8 617.1 Unconcentrated 

Q Iron &Steel 331111 102 785.6 906.8 Unconcentrated 

Q Iron &Steel 331112 1 N/A N/A N/A 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

32

Subpart NAICS 

Number of 

Subpart C 

Facilities Affected 

by 2015 Deferral 1

HHI, 

VOS 2

HHI, 

VA 2 Finding 

Q Iron &Steel 331221 7 402.1 441.8 Unconcentrated 

Q Iron &Steel 331222 2 296.9 312.4 Unconcentrated 

Q Iron &Steel 331419 1 598.6 1,080.3 Moderately Concentrated 

Q Iron &Steel 331511 1 337.5 324.7 Unconcentrated 

Q Iron &Steel 332618 1 65.6 57.9 Unconcentrated 

Q Iron &Steel 333516 2 1,139.4 1,066.8 Moderately Concentrated 

Q Iron &Steel 336611 1 1,545.7 1,838.9 Concentrated 

R Lead 331419 1 598.6 1,080.3 Moderately Concentrated 

R Lead 331492 12 344.0 345.6 Unconcentrated 

S Lime 212312 4 N/A N/A N/A 

S Lime 212391 1 N/A N/A N/A 

S Lime 311313 21 N/A N/A N/A 

S Lime 327125 1 819.2 932.7 Unconcentrated 

S Lime 327410 49 1,424.1 1,394.2 Moderately Concentrated 

S Lime 331111 1 785.6 906.8 Unconcentrated 

U Carbonate 212392 1 N/A N/A N/A 

U Carbonate 212399 1 N/A N/A N/A 

U Carbonate 221112 1 N/A N/A N/A 

U Carbonate 325181 1 2,391.7 2,428.2 Concentrated 

U Carbonate 325188 5 223.5 303.4 Unconcentrated 

U Carbonate 325199 2 360.5 289.0 Unconcentrated 

U Carbonate 325311 3 1,135.6 1,214.9 Moderately Concentrated 

U Carbonate 325312 2 D 2,777.2 Concentrated 

U Carbonate 327211 3 N/A N/A N/A 

U Carbonate 327213 2 2,506.6 2,468.8 Concentrated 

U Carbonate 331511 2 337.5 324.7 Unconcentrated 

U Carbonate 331524 1 288.8 306.4 Unconcentrated 

U Carbonate 333612 1 352.0 347.9 Unconcentrated 

V Nitric Acid 325110 1 2,535.2 D Concentrated 

V Nitric Acid 325120 1 1,415.2 1,377.8 Moderately Concentrated 

V Nitric Acid 325188 1 223.5 303.4 Unconcentrated 

V Nitric Acid 325192 1 2,328.9 D Concentrated 

V Nitric Acid 325199 4 360.5 289.0 Unconcentrated 

V Nitric Acid 325211 1 400.4 546.4 Unconcentrated 

V Nitric Acid 325311 30 1,135.6 1,214.9 Moderately Concentrated 

V Nitric Acid 325920 1 920.7 1,037.2 Moderately Concentrated 

V Nitric Acid 424690 1 N/A N/A N/A 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

33

Subpart NAICS 

Number of 

Subpart C 

Facilities Affected 

by 2015 Deferral 1

HHI, 

VOS 2

HHI, 

VA 2 Finding 

V Nitric Acid 424910 1 N/A N/A N/A 

W Petroleum & Natural Gas 211111 689 N/A N/A N/A 

W Petroleum & Natural Gas 211112 201 N/A N/A N/A 

W Petroleum & Natural Gas 213112 21 N/A N/A N/A 

W Petroleum & Natural Gas 221111 1 N/A N/A N/A 

W Petroleum & Natural Gas 221112 6 N/A N/A N/A 

W Petroleum & Natural Gas 221121 3 N/A N/A N/A 

W Petroleum & Natural Gas 221122 5 N/A N/A N/A 

W Petroleum & Natural Gas 221210 193 N/A N/A N/A 

W Petroleum & Natural Gas 237120 1 N/A N/A N/A 

W Petroleum & Natural Gas 325110 2 2,535.2 D Concentrated 

W Petroleum & Natural Gas 325181 1 2,391.7 2,428.2 Concentrated 

W Petroleum & Natural Gas 486210 471 N/A N/A N/A 

X Petrochem 221112 3 N/A N/A N/A 

X Petrochem 221330 1 N/A N/A N/A 

X Petrochem 324110 5 806.5 811.6 Unconcentrated 

X Petrochem 324191 1 794.5 1,902.5 Concentrated 

X Petrochem 325110 21 2,535.2 D Concentrated 

X Petrochem 325120 2 1,415.2 1,377.8 Moderately Concentrated 

X Petrochem 325181 7 2,391.7 2,428.2 Concentrated 

X Petrochem 325182 16 N/A N/A N/A 

X Petrochem 325188 4 223.5 303.4 Unconcentrated 

X Petrochem 325199 25 360.5 289.0 Unconcentrated 

X Petrochem 325211 13 400.4 546.4 Unconcentrated 

X Petrochem 325212 1 727.8 717.4 Unconcentrated 

X Petrochem 325998 1 158.4 212.6 Unconcentrated 

X Petrochem 424710 1 N/A N/A N/A 

Y Petroleum Refineries 211111 2 N/A N/A N/A 

Y Petroleum Refineries 237120 1 N/A N/A N/A 

Y Petroleum Refineries 324110 143 806.5 811.6 Unconcentrated 

Y Petroleum Refineries 324121 2 188.4 206.4 Unconcentrated 

Y Petroleum Refineries 324191 2 794.5 1,902.5 Concentrated 

Y Petroleum Refineries 324199 2 739.8 617.1 Unconcentrated 

Y Petroleum Refineries 325110 6 2,535.2 D Concentrated 

Y Petroleum Refineries 325120 1 1,415.2 1,377.8 Moderately Concentrated 

Y Petroleum Refineries 325212 1 727.8 717.4 Unconcentrated 

Y Petroleum Refineries 424710 3 N/A N/A N/A 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

34

Subpart NAICS 

Number of 

Subpart C 

Facilities Affected 

by 2015 Deferral 1

HHI, 

VOS 2

HHI, 

VA 2 Finding 

Y Petroleum Refineries 561210 1 N/A N/A N/A 

Z Phosphoric Acid 311119 1 285.4 290.2 Unconcentrated 

Z Phosphoric Acid 325188 1 223.5 303.4 Unconcentrated 

Z Phosphoric Acid 325311 2 1,135.6 1,214.9 Moderately Concentrated 

Z Phosphoric Acid 325312 12 D 2,777.2 Concentrated 

AA Pulp & Paper 321113 1 98.3 59.8 Unconcentrated 

AA Pulp & Paper 321999 1 65.1 90.1 Unconcentrated 

AA Pulp & Paper 322110 52 1,023.5 1,235.7 Moderately Concentrated 

AA Pulp & Paper 322121 53 758.9 1,036.2 Moderately Concentrated 

AA Pulp & Paper 322122 4 N/A N/A N/A 

AA Pulp & Paper 322130 36 713.1 768.6 Unconcentrated 

AA Pulp & Paper 322222 1 630.1 1,274.5 Moderately Concentrated 

AA Pulp & Paper 325191 1 2,389.8 D Concentrated 

AA Pulp & Paper 325998 1 158.4 212.6 Unconcentrated 

AA Pulp & Paper 423990 1 274.5 386.1 Unconcentrated 

BB Silicon Carbide 327910 1 1,662.4 2,197.7 Concentrated 

CC Soda Ash 212391 4 N/A N/A N/A 

EE Titanium Dioxide 325131 6 1,265.0 1,293.6 Moderately Concentrated 

EE Titanium Dioxide 325188 1 223.5 303.4 Unconcentrated 

GG Zinc 331492 6 344.0 345.6 Unconcentrated 

HH Municipal Landfills 221112 1 N/A N/A N/A 

HH Municipal Landfills 221119 2 N/A N/A N/A 

HH Municipal Landfills 562111 6 N/A N/A N/A 

HH Municipal Landfills 562211 2 N/A N/A N/A 

HH Municipal Landfills 562212 1194 N/A N/A N/A 

HH Municipal Landfills 562213 4 N/A N/A N/A 

HH Municipal Landfills 562920 2 N/A N/A N/A 

HH Municipal Landfills 921190 1 N/A N/A N/A 

HH Municipal Landfills 924110 2 N/A N/A N/A 

HH Municipal Landfills 928110 6 N/A N/A N/A 

II Industrial Wastewater 112340 1 N/A N/A N/A 

II Industrial Wastewater 221112 1 N/A N/A N/A 

II Industrial Wastewater 311119 1 285.4 290.2 Unconcentrated 

II Industrial Wastewater 311221 8 2,338.2 2,291.2 Concentrated 

II Industrial Wastewater 311222 1 1,930.8 2,496.1 Concentrated 

II Industrial Wastewater 311225 1 1,030.3 950.2 Moderately Concentrated 

II Industrial Wastewater 311411 7 586.6 648.1 Unconcentrated 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

35

Subpart NAICS 

Number of 

Subpart C 

Facilities Affected 

by 2015 Deferral 1

HHI, 

VOS 2

HHI, 

VA 2 Finding 

II Industrial Wastewater 311421 2 254.8 295.2 Unconcentrated 

II Industrial Wastewater 311422 1 2,885.1 D Concentrated 

II Industrial Wastewater 311611 21 1,046.5 644.0 Moderately Concentrated 

II Industrial Wastewater 311612 5 258.1 330.3 Unconcentrated 

II Industrial Wastewater 311613 17 645.6 800.5 Unconcentrated 

II Industrial Wastewater 311615 14 737.6 937.0 Unconcentrated 

II Industrial Wastewater 311919 1 N/A N/A N/A 

II Industrial Wastewater 312120 1 N/A N/A N/A 

II Industrial Wastewater 312140 2 1,519.4 2,373.6 Concentrated 

II Industrial Wastewater 316110 1 560.3 466.8 Unconcentrated 

II Industrial Wastewater 322110 2 1,023.5 1,235.7 Moderately Concentrated 

II Industrial Wastewater 322121 2 758.9 1,036.2 Moderately Concentrated 

II Industrial Wastewater 322130 8 713.1 768.6 Unconcentrated 

II Industrial Wastewater 325191 1 2,389.8 D Concentrated 

II Industrial Wastewater 325193 87 275.1 298.0 Unconcentrated 

II Industrial Wastewater 562219 2 N/A N/A N/A 

II Industrial Wastewater 811111 1 N/A N/A N/A 

TT Industrial Landfills 111930 1 N/A N/A N/A 

TT Industrial Landfills 212234 1 N/A N/A N/A 

TT Industrial Landfills 221112 6 N/A N/A N/A 

TT Industrial Landfills 221113 1 N/A N/A N/A 

TT Industrial Landfills 311221 2 2,338.2 2,291.2 Concentrated 

TT Industrial Landfills 311223 1 2,752.7 2,221.5 Concentrated 

TT Industrial Landfills 311311 1 N/A N/A N/A 

TT Industrial Landfills 311313 9 N/A N/A N/A 

TT Industrial Landfills 321113 1 98.3 59.8 Unconcentrated 

TT Industrial Landfills 321212 1 1,233.3 1,408.3 Moderately Concentrated 

TT Industrial Landfills 321219 2 345.0 322.8 Unconcentrated 

TT Industrial Landfills 321999 1 65.1 90.1 Unconcentrated 

TT Industrial Landfills 322110 38 1,023.5 1,235.7 Moderately Concentrated 

TT Industrial Landfills 322121 51 758.9 1,036.2 Moderately Concentrated 

TT Industrial Landfills 322122 4 N/A N/A N/A 

TT Industrial Landfills 322130 30 713.1 768.6 Unconcentrated 

TT Industrial Landfills 322222 1 630.1 1,274.5 Moderately Concentrated 

TT Industrial Landfills 322291 2 1,317.8 1,789.4 Moderately Concentrated 

TT Industrial Landfills 324110 4 806.5 811.6 Unconcentrated 

TT Industrial Landfills 325110 3 2,535.2 D Concentrated 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

36

Subpart NAICS 

Number of 

Subpart C 

Facilities Affected 

by 2015 Deferral 1

HHI, 

VOS 2

HHI, 

VA 2 Finding 

TT Industrial Landfills 325120 2 1,415.2 1,377.8 Moderately Concentrated 

TT Industrial Landfills 325181 1 2,391.7 2,428.2 Concentrated 

TT Industrial Landfills 325188 1 223.5 303.4 Unconcentrated 

TT Industrial Landfills 325191 1 2,389.8 D Concentrated 

TT Industrial Landfills 325192 1 2,328.9 D Concentrated 

TT Industrial Landfills 325193 1 275.1 298.0 Unconcentrated 

TT Industrial Landfills 325199 11 360.5 289.0 Unconcentrated 

TT Industrial Landfills 325211 9 400.4 546.4 Unconcentrated 

TT Industrial Landfills 325221 1 N/A N/A N/A 

TT Industrial Landfills 325311 1 1,135.6 1,214.9 Moderately Concentrated 

TT Industrial Landfills 325320 1 1,109.1 1,632.2 Moderately Concentrated 

TT Industrial Landfills 325412 1 456.8 532.6 Unconcentrated 

TT Industrial Landfills 325998 3 158.4 212.6 Unconcentrated 

TT Industrial Landfills 327111 1 D D N/A 

TT Industrial Landfills 331111 5 785.6 906.8 Unconcentrated 

TT Industrial Landfills 331311 1 N/A N/A Concentrated 

TT Industrial Landfills 331312 3 2,250.3 D Concentrated 

TT Industrial Landfills 331314 2 930.8 2,019.9 Unconcentrated 

TT Industrial Landfills 331316 1 433.3 394.7 Moderately Concentrated 

TT Industrial Landfills 331319 1 1,119.8 1,391.6 Moderately Concentrated 

TT Industrial Landfills 331411 1 N/A N/A N/A 

TT Industrial Landfills 331511 5 337.5 324.7 Unconcentrated 

TT Industrial Landfills 331513 1 458.1 542.1 Unconcentrated 

TT Industrial Landfills 331521 1 371.7 364.5 Unconcentrated 

TT Industrial Landfills 331524 1 288.8 306.4 Unconcentrated 

TT Industrial Landfills 332112 1 888.4 1,034.3 Moderately Concentrated 

TT Industrial Landfills 332913 1 1,532.2 1,810.9 Concentrated 

TT Industrial Landfills 332998 1 1,312.0 1,611.5 Moderately Concentrated 

TT Industrial Landfills 333315 1 1,831.1 1,873.4 Concentrated 

TT Industrial Landfills 333618 1 1,022.1 1,089.4 Moderately Concentrated 

TT Industrial Landfills 562212 16 N/A N/A N/A 

TT Industrial Landfills 562910 1 N/A N/A N/A 

1 Facilities may report more than one NAICS code; thus, the sum of the number of NAICS codes reported by 

facilities in a subpart may exceed the total number of facilities reporting under that subpart.

2

 HHI: Herfindahl-Hirschman index This index is calculated by summing the squares of the individual company 

percentages for the 50 largest companies or the universe, whichever is lower. Values less than 1000 are considered 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

37

unconcentrated, values between 1000 and 1800 are considered moderately concentrated, and values over 1800 are 

considered concentrated. VOS is Value of Shipments; VA is Value Added. 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

38

Appendix B 

Results of the Evaluation of Competitive Harm from Reporting Data Elements Deferred to 

March 31, 2015 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

39

Table B-1. Results of the Evaluation of Competitive Harm from Reporting Data Elements 

Deferred to March 31, 2015 

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

C 

(Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid) 1

§98.3(d)(3)(v) For any facility who submitted an 

abbreviated emissions report under 

§98.3(d)(3)(v), any facility 

operating data or process 

information used for the GHG 

emission calculations. 

 Provides data related to process design; 

process performance, and operation; 

and/or cost to do business, as described in 

section 2.2 of Part Two of this 

memorandum. Specifically, indicates the 

quantity of fuel used in the process, which 

could reveal information about the cost to 

produce products. For specialty fuels that 

are byproducts of the production process, 

information about fuel characteristics 

indicates the composition of the process 

byproduct, which could reveal information 

about process efficiency and cost to 

produce a product. 

C 

(Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid) 1

§98.36(b)(9)(iii) Estimate of the heat input from 

each type of fuel listed in Table C2 that was combusted in the unit 

during the report year. 

C-10 Provides data related to process design; 

process performance, and operation; 

and/or cost to do business, as described in 

section 2.2 of Part Two of this 

memorandum. Specifically, for specialty 

fuels that are byproducts of the production 

process, indicates the composition of the 

process byproduct, which could reveal 

information about process efficiency and 

cost to produce a product. 

C 

(Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid) 1

§98.36(c)(2)(ix) The flue gases from two or more 

stationary fuel combustion units at 

a facility are combined together 

and discharged through a common 

stack or duct before exiting to the 

atmosphere and if CEMS are used 

to continuously monitor CO2 mass 

emissions at the common stack or 

duct according to the Tier 4 

Calculation Methodology, you 

may report the combined 

emissions from the units sharing 

the common stack or duct, in lieu 

of separately reporting the GHG 

emissions from the individual 

units. This monitoring and 

reporting alternative may also be 

used when process off-gases or a 

mixture of combustion products 

and process gases are combined 

together in a common stack or duct 

before exiting to the atmosphere. 

An estimate of the heat input from 

each type of fuel listed in Table C2 combusted during the reporting 

year. 

C-10 Provides data related to process design; 

process performance, and operation; 

and/or cost to do business, as described in 

section 2.2 of Part Two of this 

memorandum. Specifically, indicates the 

quantity of fuel used in the process, which 

could reveal information about the cost to 

produce products. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

40

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

C 

(Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid) 1

§98.36(e)(2)(i) 

§98.36(e)(2)(ii)(A) 

§98.36(e)(2)(iv)(A) 

Total quantity of each type of fuel 

combusted in each unit or group of 

aggregated units (as applicable). 

C-1,C-1a,C-1b,C8,C-2b,C-13,C3,C-4,C-5,C-8,C8a,C-8b 

In certain cases provides production or raw 

material data described in section 2.1 of 

Part Two of this memorandum. Also, in 

certain cases provides data related to 

process design; process performance, and 

operation; and/or cost to do business, as 

described in section 2.2 of Part Two of this 

memorandum. Specifically, could reveal 

information about the cost to produce 

products. 

C 

(Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid) 1

§98.36(e)(2)(ii)(C) High heat values used in the CO2

emissions calculations for each 

fuel combusted during the 

reporting year. Report a HHV 

value for each calendar month in 

which HHV determination is 

required. If multiple values are 

obtained in a given month, report 

the arithmetic average value for the 

month. 

C-2b Provides data related to process design; 

process performance, and operation; 

and/or cost to do business, as described in 

section 2.2 of Part Two of this 

memorandum. Specifically, for specialty 

fuels that are byproducts of the production 

process, indicates the composition of the 

process byproduct, which could reveal 

information about process efficiency and 

cost to produce a product. 

C 

(Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid) 1

§98.36(e)(2)(ii)(D) If Eq. C-2c is used: Ratio of the 

maximum rate heat input capacity 

to the design rated steam output 

capacity of the unit. 

C-2c Provides data related to process design; 

process performance, and operation; 

and/or cost to do business, as described in 

section 2.2 of Part Two of this 

memorandum. Specifically, indicates the 

efficiency of the unit, which could reveal 

information about the cost to produce the 

steam.. 

C 

(Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid) 1

§98.36(e)(2)(ii)(D) If Eq. C-2c is used: Total quantity 

(i.e., pounds) of steam produced 

from MSW or solid fuel 

combustion during each month of 

the reporting year. 

C-2c Provides data related to process design; 

process performance, and operation; 

and/or cost to do business, as described in 

section 2.2 of Part Two of this 

memorandum. Specifically, indicates the 

energy generated from MSW or solid fuel, 

which could reveal information about the 

cost to produce energy for the process. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

41

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

C 

(Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid) 1

§98.36(e)(2)(iv)(C) The carbon content used in the 

emission calculations (including 

both valid and substitute data 

values). For each calendar month 

of the reporting year in which 

carbon content and, if applicable, 

molecular weight determination is 

required, report a value of each 

parameter. If multiple values of a 

parameter are obtained in a given 

month, report the arithmetic 

average value for the month. (CC). 

C-3 Provides data related to process design; 

process performance, and operation; 

and/or cost to do business, as described in 

section 2.2 of Part Two of this 

memorandum. Specifically, for specialty 

fuels that are byproducts of the production 

process, indicates the composition of the 

process byproduct, which could reveal 

information about process efficiency and 

cost to produce a product. 

C 

(Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid) 1

§98.36(e)(2)(iv)(C) The carbon content used in the 

emission calculations (including 

both valid and substitute data 

values). For each calendar month 

of the reporting year in which 

carbon content and, if applicable, 

molecular weight determination is 

required, report a value of each 

parameter. If multiple values of a 

parameter are obtained in a given 

month, report the arithmetic 

average value for the month. (CC). 

C-4 Provides data related to process design; 

process performance, and operation; 

and/or cost to do business, as described in 

section 2.2 of Part Two of this 

memorandum. Specifically, for specialty 

fuels that are byproducts of the production 

process, indicates the composition of the 

process byproduct, which could reveal 

information about process efficiency and 

cost to produce a product. 

C 

(Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid) 1

§98.36(e)(2)(iv)(C) The carbon content used in the 

emission calculations (including 

both valid and substitute data 

values). For each calendar month 

of the reporting year in which 

carbon content and, if applicable, 

molecular weight determination is 

required, report a value of each 

parameter. If multiple values of a 

parameter are obtained in a given 

month, report the arithmetic 

average value for the month. (CC). 

C-5 Provides data related to process design; 

process performance, and operation; 

and/or cost to do business, as described in 

section 2.2 of Part Two of this 

memorandum. Specifically, for specialty 

fuels that are byproducts of the production 

process, indicates the composition of the 

process byproduct, which could reveal 

information about process efficiency and 

cost to produce a product. 

C 

(Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid) 1

§98.36(e)(2)(iv)(C) Gas molecular weight values used 

in the emission calculations 

(including both valid and substitute 

data values). For each calendar 

month of the reporting year in 

which carbon content and, if 

applicable, molecular weight 

determination is required, report a 

value of each parameter. If 

multiple values of a parameter are 

obtained in a given month, report 

the arithmetic average value for the 

month. 

C-5 Provides data related to process design; 

process performance, and operation; 

and/or cost to do business, as described in 

section 2.2 of Part Two of this 

memorandum. Specifically, for specialty 

fuels that are byproducts of the production 

process, indicates the composition of the 

process byproduct, which could reveal 

information about process efficiency and 

cost to produce a product. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

42

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

C 

(Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid) 1

§98.36(e)(2)(iv)(F) The annual average HHV, when 

measured HHV data, rather than a 

default HHV from Table C-1 of 

this subpart, are used to calculate 

CH4 and N2O emissions for a Tier 

3 unit, in accordance with 

§98.33(c)(1). 

C-8 Provides data related to process design; 

process performance, and operation; 

and/or cost to do business, as described in 

section 2.2 of Part Two of this 

memorandum. Specifically, for specialty 

fuels that are byproducts of the production 

process, indicates the composition of the 

process byproduct, which could reveal 

information about process efficiency and 

cost to produce a product. 

C 

(Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid) 1

§98.36(e)(2)(ix)(D) For units that combust both fossil 

fuel and biomass, when biogenic 

CO2 is determined according to 

§98.33(e)(2), report the carbonbased F-factor used in Equation C13 of this subpart. 

C-13 Provides data related to process design; 

process performance, and operation; 

and/or cost to do business, as described in 

section 2.2 of Part Two of this 

memorandum. Specifically, for specialty 

fuels that are byproducts of the production 

process, indicates the composition of the 

process byproduct, which could reveal 

information about process efficiency and 

cost to produce a product. 

C 

(Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid) 1

§98.36(e)(2)(ix)(E) For units that combust both fossil 

fuel and biomass, when biogenic 

CO2 is determined according to 

§98.33(e)(2), report the annual 

average HHV value used in 

Equation C-13 of this subpart. 

C-13 Provides data related to process design; 

process performance, and operation; 

and/or cost to do business, as described in 

section 2.2 of Part Two of this 

memorandum. Specifically, for specialty 

fuels that are byproducts of the production 

process, indicates the composition of the 

process byproduct, which could reveal 

information about process efficiency and 

cost to produce a product. 

C 

(Combustion 

units at 

industrial 

sources, 

excluding 

combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid) 1

§98.36(e)(2)(ix)(F) For units that combust both fossil 

fuel and biomass, when biogenic 

CO2 is determined according to 

§98.33(e)(2), report the total 

quantity of fossil fuel combusted 

during the reporting year. 

C-13 In certain cases, provides data related to 

process design; process performance, and 

operation; and/or cost to do business, as 

described in section 2.2 of Part Two of this 

memorandum. Specifically, indicates the 

quantity of fuel used in the process, which, 

in certain cases, could reveal information 

about unique fuel mixes or production 

quantities. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

43

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

C 

(Combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid)1

§98.3(d)(3)(v) For any facility who submitted an 

abbreviated emissions report under 

§98.3(d)(3)(v), any facility 

operating data or process 

information used for the GHG 

emission calculations. 

 Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Site-specific fuel 

characteristics for these units do not vary 

significantly from publicly-known average 

values. For facilities with these 

combustion units, certain fuel use and fuel 

characterization data for the units are 

reported and publicly released via the 

EIAAdditionally for the electric utilities, 

this sector has experienced a high level of 

transparency due to the practice of passing 

fuel costs through to paying customers. 

C 

(Combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid)1

§98.36(b)(9)(iii) Estimate of the heat input from 

each type of fuel listed in Table C2 that was combusted in the unit 

during the report year. 

C-10 For facilities with these types of 

combustion units, facility-level heat input 

from each type of fuel is publicly available 

because it can be calculated based on other 

data reported and publicly released via 

EIA. As required to be reported under Part 

98, an estimate of the heat input from each 

type of fuel for the combustion unit(s) 

would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Site-specific fuel 

characteristics for these units do not vary 

significantly from publicly-known average 

values. Additionally for the electric 

utilities, this sector has experienced a high 

level of transparency due to the practice of 

passing fuel costs through to paying 

customers. 

C 

(Combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid)1

§98.36(c)(2)(ix) The flue gases from two or more 

stationary fuel combustion units at 

a facility are combined together 

and discharged through a common 

stack or duct before exiting to the 

atmosphere and if CEMS are used 

to continuously monitor CO2 mass 

emissions at the common stack or 

duct according to the Tier 4 

Calculation Methodology, you 

may report the combined 

emissions from the units sharing 

the common stack or duct, in lieu 

of separately reporting the GHG 

emissions from the individual 

units. This monitoring and 

reporting alternative may also be 

used when process off-gases or a 

mixture of combustion products 

and process gases are combined 

together in a common stack or duct 

before exiting to the atmosphere. 

An estimate of the heat input from 

each type of fuel listed in Table C2 combusted during the reporting 

year. 

C-10 Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Site-specific fuel 

characteristics do not vary significantly 

from publicly-known average values. 

Additionally for the electric utilities, this 

sector has experienced a high level of 

transparency due to the practice of passing 

fuel costs through to paying customers. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

44

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

C 

(Combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid)1

§98.36(e)(2)(i) Total quantity of each type of fuel 

combusted in each unit or group of 

aggregated units (as applicable) 

during the reporting year, in short 

tons for solid fuels, gallons for 

liquid fuels and standard cubic feet 

for gaseous fuels, or, if applicable, 

therms or mmBtu for natural gas. 

C-1 For facilities with these types of 

combustion units, facility-level quantity of 

each type of fuel combusted is publicly 

released by EIA. As required to be 

reported under Part 98, quantity of each 

type of fuel combusted for the combustion 

unit(s) would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Additionally for the electric 

utilities, this sector has experienced a high 

level of transparency due to the practice of 

passing fuel costs through to paying 

customers. 

C 

(Combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid)1

§98.36(e)(2)(i) Total quantity of each type of fuel 

combusted in each unit or group of 

aggregated units (as applicable) 

during the reporting year, in short 

tons for solid fuels, gallons for 

liquid fuels and standard cubic feet 

for gaseous fuels, or, if applicable, 

therms or mmBtu for natural gas. 

C-1a For facilities with these types of 

combustion units, facility-level quantity of 

each type of fuel combusted is publicly 

released by EIA. As required to be 

reported under Part 98, quantity of each 

type of fuel combusted for the combustion 

unit(s) would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Additionally for the electric 

utilities, this sector has experienced a high 

level of transparency due to the practice of 

passing fuel costs through to paying 

customers. 

C 

(Combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid)1

§98.36(e)(2)(i) Total quantity of each type of fuel 

combusted in each unit or group of 

aggregated units (as applicable) 

during the reporting year, in short 

tons for solid fuels, gallons for 

liquid fuels and standard cubic feet 

for gaseous fuels, or, if applicable, 

therms or mmBtu for natural gas. 

C-1b For facilities with these types of 

combustion units, facility-level quantity of 

each type of fuel combusted is publicly 

released by EIA. As required to be 

reported under Part 98, quantity of each 

type of fuel combusted for the combustion 

unit(s) would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Additionally for the electric 

utilities, this sector has experienced a high 

level of transparency due to the practice of 

passing fuel costs through to paying 

customers. 

C 

(Combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid)1

§98.36(e)(2)(i) Total quantity of each type of fuel 

combusted in each unit or group of 

aggregated units (as applicable) 

during the reporting year, in short 

tons for solid fuels, gallons for 

liquid fuels and standard cubic feet 

for gaseous fuels, or, if applicable, 

therms or mmBtu for natural gas. 

C-8 For facilities with these types of 

combustion units, facility-level quantity of 

each type of fuel combusted is publicly 

released by EIA. As required to be 

reported under Part 98, quantity of each 

type of fuel combusted for the combustion 

unit(s) would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Additionally for the electric 

utilities, this sector has experienced a high 

level of transparency due to the practice of 

passing fuel costs through to paying 

customers. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

45

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

C 

(Combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid)1

§98.36(e)(2)(ii)(A) For Tier 2: Total quantity of each 

type of fuel combusted in the unit 

or group of aggregated units (as 

applicable) during each month of 

the reporting year. Express the 

quantity of each fuel combusted 

during the measurement period in 

short tons for solid fuels, gallons 

for liquid fuels, and scf for gaseous 

fuels. 

C-2b For facilities with these types of 

combustion units, facility-level quantity of 

each type of fuel combusted is publicly 

released by EIA. As required to be 

reported under Part 98, quantity of each 

type of fuel combusted for the combustion 

unit(s) would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Additionally for the electric 

utilities, this sector has experienced a high 

level of transparency due to the practice of 

passing fuel costs through to paying 

customers. 

C 

(Combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid)1

§98.36(e)(2)(ii)(C) High heat values used in the CO2

emissions calculations for each 

fuel combusted during the 

reporting year. Report a HHV 

value for each calendar month in 

which HHV determination is 

required. If multiple values are 

obtained in a given month, report 

the arithmetic average value for the 

month. 

C-2b Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Site-specific fuel 

characteristics do not vary significantly 

from publicly-known average values. 

Additionally for the electric utilities, this 

sector has experienced a high level of 

transparency due to the practice of passing 

fuel costs through to paying customers. 

C 

(Combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid)1

§98.36(e)(2)(ii)(D) If Eq. C-2c is used: Total quantity 

(i.e., pounds) of steam produced 

from MSW or solid fuel 

combustion during each month of 

the reporting year. 

C-2c Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. MSW combustors are typically 

operated by municipalities. Additionally 

for the electric utilities, this sector has 

experienced a high level of transparency 

due to the practice of passing fuel costs 

through to paying customers. 

C 

(Combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid)1

§98.36(e)(2)(ii)(D) If Eq. C-2c is used: Ratio of the 

maximum rate heat input capacity 

to the design rated steam output 

capacity of the unit. 

C-2c Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Can be determined from 

equipment model information that is 

publicly available from manufacturers of 

the electricity generating equipment. 

Additionally for the electric utilities, this 

sector has experienced a high level of 

transparency due to the practice of passing 

fuel costs through to paying customers. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

46

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

C 

(Combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid)1

§98.36(e)(2)(iv)(A) Quantity of each type of fuel 

combusted in the unit or group of 

units (as applicable) during each 

month of the reporting year (Fuel). 

C-13 For facilities with these types of 

combustion units, facility-level quantity of 

each type of fuel combusted is publicly 

released by EIA. As required to be 

reported under Part 98, quantity of each 

type of fuel combusted for the combustion 

unit(s) would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Additionally for the electric 

utilities, this sector has experienced a high 

level of transparency due to the practice of 

passing fuel costs through to paying 

customers. 

C 

(Combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid)1

§98.36(e)(2)(iv)(A) Quantity of each type of fuel 

combusted in the unit or group of 

units (as applicable) during each 

month of the reporting year (Fuel). 

C-3 For facilities with these types of 

combustion units, facility-level quantity of 

each type of fuel combusted is publicly 

released by EIA. As required to be 

reported under Part 98, quantity of each 

type of fuel combusted for the combustion 

unit(s) would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Additionally for the electric 

utilities, this sector has experienced a high 

level of transparency due to the practice of 

passing fuel costs through to paying 

customers. 

C 

(Combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid)1

§98.36(e)(2)(iv)(A) Quantity of each type of fuel 

combusted in the unit or group of 

units (as applicable) during each 

month of the reporting year (Fuel). 

C-4 For facilities with these types of 

combustion units, facility-level quantity of 

each type of fuel combusted is publicly 

released by EIA. As required to be 

reported under Part 98, quantity of each 

type of fuel combusted for the combustion 

unit(s) would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Additionally for the electric 

utilities, this sector has experienced a high 

level of transparency due to the practice of 

passing fuel costs through to paying 

customers. 

C 

(Combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid)1

§98.36(e)(2)(iv)(A) Quantity of each type of fuel 

combusted in the unit or group of 

units (as applicable) during each 

month of the reporting year (Fuel). 

C-5 For facilities with these types of 

combustion units, facility-level quantity of 

each type of fuel combusted is publicly 

released by EIA. As required to be 

reported under Part 98, quantity of each 

type of fuel combusted for the combustion 

unit(s) would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Additionally for the electric 

utilities, this sector has experienced a high 

level of transparency due to the practice of 

passing fuel costs through to paying 

customers. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

47

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

C 

(Combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid)1

§98.36(e)(2)(iv)(A) Quantity of each type of fuel 

combusted in the unit or group of 

units (as applicable) during each 

month of the reporting year (Fuel). 

C-8 For facilities with these types of 

combustion units, facility-level quantity of 

each type of fuel combusted is publicly 

released by EIA. As required to be 

reported under Part 98, quantity of each 

type of fuel combusted for the combustion 

unit(s) would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Additionally for the electric 

utilities, this sector has experienced a high 

level of transparency due to the practice of 

passing fuel costs through to paying 

customers. 

C 

(Combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid)1

§98.36(e)(2)(iv)(A) Quantity of each type of fuel 

combusted in the unit or group of 

units (as applicable) during each 

month of the reporting year (Fuel). 

C-8a For facilities with these types of 

combustion units, facility-level quantity of 

each type of fuel combusted is publicly 

released by EIA. As required to be 

reported under Part 98, quantity of each 

type of fuel combusted for the combustion 

unit(s) would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Additionally for the electric 

utilities, this sector has experienced a high 

level of transparency due to the practice of 

passing fuel costs through to paying 

customers. 

C 

(Combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid)1

§98.36(e)(2)(iv)(A) Quantity of each type of fuel 

combusted in the unit or group of 

units (as applicable) during each 

month of the reporting year (Fuel). 

C-8b For facilities with these types of 

combustion units, facility-level quantity of 

each type of fuel combusted is publicly 

released by EIA. As required to be 

reported under Part 98, quantity of each 

type of fuel combusted for the combustion 

unit(s) would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Additionally for the electric 

utilities, this sector has experienced a high 

level of transparency due to the practice of 

passing fuel costs through to paying 

customers. 

C 

(Combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid)1

§98.36(e)(2)(iv)(C) The carbon content used in the 

emission calculations (including 

both valid and substitute data 

values). For each calendar month 

of the reporting year in which 

carbon content and, if applicable, 

molecular weight determination is 

required, report a value of each 

parameter. If multiple values of a 

parameter are obtained in a given 

month, report the arithmetic 

average value for the month. (CC) 

C-3 Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Site-specific fuel 

characteristics do not vary significantly 

from publicly-known average values. 

Additionally for the electric utilities, this 

sector has experienced a high level of 

transparency due to the practice of passing 

fuel costs through to paying customers. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

48

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

C 

(Combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid)1

§98.36(e)(2)(iv)(C) The carbon content used in the 

emission calculations (including 

both valid and substitute data 

values). For each calendar month 

of the reporting year in which 

carbon content and, if applicable, 

molecular weight determination is 

required, report a value of each 

parameter. If multiple values of a 

parameter are obtained in a given 

month, report the arithmetic 

average value for the month. (CC) 

C-4 Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Site-specific fuel 

characteristics do not vary significantly 

from publicly-known average values. 

Additionally for the electric utilities, this 

sector has experienced a high level of 

transparency due to the practice of passing 

fuel costs through to paying customers. 

C 

(Combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid)1

§98.36(e)(2)(iv)(C) The carbon content used in the 

emission calculations (including 

both valid and substitute data 

values). For each calendar month 

of the reporting year in which 

carbon content and, if applicable, 

molecular weight determination is 

required, report a value of each 

parameter. If multiple values of a 

parameter are obtained in a given 

month, report the arithmetic 

average value for the month. (CC) 

C-5 Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Site-specific fuel 

characteristics do not vary significantly 

from publicly-known average values. 

Additionally for the electric utilities, this 

sector has experienced a high level of 

transparency due to the practice of passing 

fuel costs through to paying customers. 

C 

(Combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid)1

§98.36(e)(2)(iv)(C) Gas molecular weight values used 

in the emission calculations 

(including both valid and substitute 

data values). For each calendar 

month of the reporting year in 

which carbon content and, if 

applicable, molecular weight 

determination is required, report a 

value of each parameter. If 

multiple values of a parameter are 

obtained in a given month, report 

the arithmetic average value for the 

month. 

C-5 Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Site-specific fuel 

characteristics do not vary significantly 

from publicly-known average values. 

Additionally for the electric utilities, this 

sector has experienced a high level of 

transparency due to the practice of passing 

fuel costs through to paying customers. 

C 

(Combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid)1

§98.36(e)(2)(iv)(F) The annual average HHV, when 

measured HHV data, rather than a 

default HHV from Table C-1 of 

this subpart, are used to calculate 

CH4 and N2O emissions for a Tier 

3 unit, in accordance with 

§98.33(c)(1). 

C-8 For facilities with these types of 

combustion units, facility-level HHV data 

are publicly available because they can be 

calculated based on other data reported and 

publicly released via EIA. As required to 

be reported under Part 98, the HHV data 

for the combustion unit(s) would not 

reveal any proprietary information about 

facility or process performance, design, 

and operation; cost to do business; raw 

material usage; or production. Site-specific 

fuel characteristics do not vary 

significantly from publicly-known average 

values. Additionally for the electric 

utilities, this sector has experienced a high 

level of transparency due to the practice of 

passing fuel costs through to paying 

customers. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

49

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

C 

(Combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid)1

§98.36(e)(2)(ix)(D) For units that combust both fossil 

fuel and biomass, when biogenic 

CO2 is determined according to 

§98.33(e)(2), report the carbonbased F-factor used in Equation C13 of this subpart. 

C-13 Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Site-specific fuel 

characteristics do not vary significantly 

from publicly-known average values. 

Additionally for the electric utilities, this 

sector has experienced a high level of 

transparency due to the practice of passing 

fuel costs through to paying customers. 

C 

(Combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid)1

§98.36(e)(2)(ix)(E) For units that combust both fossil 

fuel and biomass, when biogenic 

CO2 is determined according to 

§98.33(e)(2), report the annual 

average HHV value used in 

Equation C-13 of this subpart. 

C-13 For facilities with these types of 

combustion units, facility-level HHV data 

are publicly available because they can be 

calculated based on other data reported and 

publicly released via EIA. As required to 

be reported under Part 98, the HHV data 

for the combustion unit(s) would not 

reveal any proprietary information about 

facility or process performance, design, 

and operation; cost to do business; raw 

material usage; or production. Site-specific 

fuel characteristics do not vary 

significantly from publicly-known average 

values. Additionally for the electric 

utilities, this sector has experienced a high 

level of transparency due to the practice of 

passing fuel costs through to paying 

customers. 

C 

(Combustion 

units 

connected to 

devices 

connected to 

the local or 

regional power 

grid)1

§98.36(e)(2)(ix)(F) For units that combust both fossil 

fuel and biomass, when biogenic 

CO2 is determined according to 

§98.33(e)(2), report the total 

quantity of fossil fuel combusted 

during the reporting year. 

C-13 For facilities with these types of 

combustion units, facility-level HHV data 

are publicly available because they can be 

calculated based on other data reported and 

publicly released via EIA. As required to 

be reported under Part 98, the HHV data 

for the combustion unit(s) would not 

reveal any proprietary information about 

facility or process performance, design, 

and operation; cost to do business; raw 

material usage; or production. Site-specific 

fuel characteristics do not vary 

significantly from publicly-known average 

values. Additionally for the electric 

utilities, this sector has experienced a high 

level of transparency due to the practice of 

passing fuel costs through to paying 

customers. 

E §98.56(b) Total annual adipic acid 

production from unit “z” (Pz). 

E-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

E §98.56(b) Total annual adipic acid 

production from unit “z” (Pz). 

E-3a Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

E §98.56(b) Total annual adipic acid 

production from unit “z” (Pz). 

E-3b Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

50

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

E §98.56(b) Total annual adipic acid 

production from unit “z” (Pz). 

E-3c Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

E §98.56(b) Total annual adipic acid 

production from unit “z” (Pz). 

E-3d Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

E §98.56(c) Annual adipic acid production 

during which N2O abatement 

technology (located after the test 

point) is operating (Pz,N) . 

E-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

E §98.56(g) Abatement technology destruction 

efficiency for each abatement 

technology (DF). 

 E-3a Provides data described in section 2.3 in 

Part Two of this memorandum that could 

be used to calculate the mass of adipic acid 

produced if all of the following data are 

also known: annual N2O mass emissions 

from adipic acid production (as currently 

reported under 40 CFR 98.3(c)(4) and 

made publicly available) 5, EFs (as 

required to be reported in 40 CFR 40 CFR 

98.56(j)(1)), and AF (as required to be 

reported in 40 CFR 98.56(h)). However, if 

the EFs were not reported, would not 

reveal any proprietary information about 

facility or process performance, design, 

and operation; cost to do business; raw 

material usage; or production. 

E §98.56(g) Abatement technology destruction 

efficiency for each abatement 

technology (DF). 

 E-3c Provides data described in section 2.3 in 

Part Two of this memorandum that could 

be used to calculate the mass of adipic acid 

produced if all of the following data are 

also known: annual N2O mass emissions 

from adipic acid production (as currently 

reported under 40 CFR 98.3(c)(4) and 

made publicly available) 5, EFs (as 

required to be reported in 40 CFR 

98.56(j)(1)), the AF (as required to be 

reported in 40 CFR 98.56(h)), and the 

fraction control factor (as required to be 

reported in 40 CFR 98.56(l). However, if 

the EFs were not reported, would not 

reveal any proprietary information about 

facility or process performance, design, 

and operation; cost to do business; raw 

material usage; or production. 

E §98.56(g) Abatement technology destruction 

efficiency for each abatement 

technology (DF). 

E-3b Provides data described in section 2.3 in 

Part Two of this memorandum that could 

be used to calculate the mass of adipic acid 

produced if all of the following data are 

also known: annual N2O mass emissions 

from adipic acid production (as currently 

reported under 40 CFR 98.3(c)(4) and 

made publicly available) 5, EFs (as 

required to be reported in 40 CFR 

98.56(j)(1)), and AF (as required to be 

reported in 40 CFR 98.56(h)). However, if 

the EFs were not reported, would not 

reveal any proprietary information about 

facility or process performance, design, 

and operation; cost to do business; raw 

material usage; or production. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

51

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

E §98.56(h) Abatement utilization factor for 

each abatement technology (AF ). 

E-3a Provides data described in section 2.3 in 

Part Two of this memorandum that could 

be used to calculate the mass of adipic acid 

produced if all of the following data are 

also known: annual N2O mass emissions 

from adipic acid production (as currently 

reported under 40 CFR 98.3(c)(4) and 

made publicly available) 5, EFs (as 

required to be reported in 40 CFR 

98.56(j)(1)), and the DF (as required to be 

reported in 40 CFR 98.56(g)). However, if 

the DF were not reported, would not reveal 

any proprietary information about facility 

or process performance, design, and 

operation; cost to do business; raw 

material usage; or production. 

E §98.56(h) Abatement utilization factor for 

each abatement technology (AF). 

E-3c Provides data described in section 2.3 in 

Part Two of this memorandum that could 

be used to calculate the mass of adipic acid 

produced if all of the following data are 

also known: annual N2O mass emissions 

from adipic acid production (as currently 

reported under 98.3(c)(4) and made 

publicly available) 5, EFs (as required to be 

reported in 40 CFR 98.56(j)(1)), the DF 

(as required to be reported in 40 CFR 

98.56(g)), and the fraction control factor 

(as required to be reported in 40 CFR 

98.56(l). However, if the EFs were not 

reported, would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. 

E §98.56(j)(1) Emission factor for each unit 

(EFN2Oz). 

 E-3a Provides data described in section 2.3 in 

Part Two of this memorandum that could 

be used to calculate the mass of adipic acid 

produced if all of the following data are 

also known: annual N2O mass 

emissions from adipic acid production (as 

currently reported under 40 CFR 

98.3(c)(4) and made publicly available) 5, 

DF (as required to be reported in 40 CFR 

98.56(g)), and AF (as required to be 

reported in 40 CFR 98.56(h)). However, if 

the DF or AF were not reported, would not 

reveal any proprietary information about 

facility or process performance, design, 

and operation; cost to do business; raw 

material usage; or production. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

52

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

E §98.56(j)(1) Emission factor for each unit 

(EFN2O). 

E-3b Provides data described in section 2.3 in 

Part Two of this memorandum that could 

be used to calculate the mass of adipic acid 

produced if all of the following data are 

also known: annual N2O mass emissions 

from adipic acid production (as currently 

reported under 40 CFR 98.3(c)(4) and 

made publicly available) 5, DF (as 

required to be reported in 40 CFR 

98.56(g)), and AF (as required to be 

reported in 40 CFR 98.56(h)). However, if 

the DFN or AF were not reported, would 

not reveal any proprietary information 

about facility or process performance, 

design, and operation; cost to do business; 

raw material usage; or production. 

E §98.56(j)(1) Emission factor for each unit 

(EFN2O). 

E-3c Provides data described in section 2.3 in 

Part Two of this memorandum that could 

be used to calculate the mass of adipic acid 

produced if all of the following data are 

also known: annual N2O mass emissions 

from adipic acid production (as currently 

reported under 40 CFR 98.3(c)(4) and 

made publicly available) 5, DFN (as 

required to be reported in 40 CFR 

98.56(g)), AF (as required to be reported 

in 40 CFR 98.56(h)), and fraction control 

factor (as required to be reported in 40 

CFR 98.56(l). However, if the DF or AF 

were not reported, would not reveal any 

proprietary information about facility or 

process performance, design, and 

operation; cost to do business; raw 

material usage; or production. 

E §98.56(j)(1) Emission factor for each unit 

(EFN2O). 

E-3d Provides data described in section 2.3 in 

Part Two of this memorandum that could 

be used to calculate the mass of adipic acid 

produced if the annual N2O mass 

emissions from adipic acid production (as 

currently reported under 40 CFR 

98.3(c)(4) and made publicly available) 5 is 

also known. 

E §98.56(j)(3) Production rate per test run during 

performance test for each unit (P). 

E-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

53

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

E §98.56(j)(4) N2O concentration per test run 

during performance test for each 

unit (CN2O). 

E-1 Provides data described in section 2.3 in 

Part Two of this memorandum that could 

be used to calculate the mass of adipic acid 

produced if all of the following data are 

also known: EFs (as required to be 

reported in 40 CFR 98.56(j)(1)), 

volumetric flow rate of effluent gas during 

the performance test (as required to be 

reported in 40 CFR 98.56(j)(5)), and 

number of test runs (as required to be 

reported in 40 CFR 98.56(j)(6). However, 

if the EFs were not reported, would not 

reveal any proprietary information about 

facility or process performance, design, 

and operation; cost to do business; raw 

material usage; or production. 

E §98.56(j)(5) Volumetric flow rate per test run 

during performance test for each 

unit (Q). 

E-1 Provides data described in section 2.3 in 

Part Two of this memorandum that could 

be used to calculate the mass of adipic acid 

produced if all of the following data are 

also known: EFs (as required to be 

reported in 40 CFR 98.56(j)(1)), N2O 

concentration per test run during 

performance test (as required to be 

reported in 40 CFR 98.56(j)(4)), and 

number of test runs (as required to be 

reported in 40 CFR 98.56(j)(6). However, 

if the EFs were not reported, would not 

reveal any proprietary information about 

facility or process performance, design, 

and operation; cost to do business; raw 

material usage; or production. 

E §98.56(j)(6) Number of test runs for each unit 

(n). 

E-1 Provides data described in section 2.3 in 

Part Two of this memorandum that could 

be used to calculate the mass of adipic acid 

produced if all of the following data are 

also known: EFs (as required to be 

reported in 40 CFR 98.56(j)(1)), N2O 

concentration per test run during 

performance test (as required to be 

reported in 40 CFR 98.56(j)(4)), and 

volumetric flow rate per test run during 

performance test (as required to be 

reported in 40 CFR 98.56(j)(5). However, 

if the EFs were not reported, would not 

reveal any proprietary information about 

facility or process performance, design, 

and operation; cost to do business; raw 

material usage; or production. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

54

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

E §98.56(l) Fraction control factor for each 

abatement technology (percent of 

total emissions from the 

production unit that are sent to the 

abatement technology) if equation 

E-3c is used. (FCN) 

E-3c Provides data described in section 2.3 in 

Part Two of this memorandum that could 

be used to calculate the mass of adipic acid 

produced if all of the following data are 

also known: annual N2O mass emissions 

from adipic acid production (as currently 

reported under 40 CFR 98.3(c)(4) and 

made publicly available) 5, EFs (as 

required to be reported in 98.56(j)(1)), 

DFN (as required to be reported in 40 CFR 

98.56), and the abatement utilization factor 

(as required to be reported in 40 CFR 

98.56(h)). However, if the EFs were not 

reported, would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. 

E §98.56h Abatement utilization factor for 

each abatement technology. (AF) 

 E-3b Provides data described in section 2.3 in 

Part Two of this memorandum that could 

be used to calculate the mass of adipic acid 

produced if all of the following data are 

also known: annual N2O mass emissions 

from adipic acid production (as currently 

reported under 40 CFR 98.3(c)(4) and 

made publicly available) 5, EFs (as 

required to be reported in 40 CFR 

98.56(j)(1)), and the DF (as required to be 

reported in 40 CFR 98.56(g)). However, if 

the EFs were not reported, would not 

reveal any proprietary information about 

facility or process performance, design, 

and operation; cost to do business; raw 

material usage; or production. 

F §98.66(a) Annual aluminum production. 

(MP) 

F-5 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

F §98.66(a) Annual aluminum production. 

(MP) 

F-6 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

F §98.66(c)(2) Anode effect minutes per cell-day. 

(AEM) 

F-2 Could reveal information about the process 

efficiency. Also, provides data described 

in section 2.3 of Part Two of this 

memorandum that could be used to 

calculate the mass of aluminum produced 

if both the slope coefficient (as required to 

be reported in 40 CFR 98.66(c)(3) or using 

a default value provided in Table F-1 and 

reported GHG emissions (as currently 

reported under 40 CFR 98.3(c)(4) and 

made publicly available) 5 are also known. 

F §98.66(c)(2) Anode effect overvoltage factor. 

(EFCF4) 

F-3 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the mass of aluminum 

produced if reported GHG emissions (as 

currently reported under 40 CFR 

98.3(c)(4) and made publicly available) 5

are also known. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

55

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

F §98.66(c)(2) Anode effect frequency. Used to calculate 

AEM and the 

slope coefficients 

used as an input 

in Eq. F-2 

Provides data related to process efficiency, 

as described in section 2.2 of Part Two of 

this memorandum. Also, provides data 

described in section 2.3 of Part Two of this 

memorandum that could be used to 

calculate the mass of aluminum produced 

if both the slope coefficient (as required to 

be reported in 40 CFR 98.66(c)(3)) or 

using a default value provided in Table F1) and reported GHG emissions (as 

currently reported under 40 CFR 

98.3(c)(4) and made publicly available) 5 

are also known. 

F §98.66(c)(2) Anode effect duration. Used to calculate 

AEM and the 

slope coefficients 

used as an input 

in Eq. F-2 

Provides data related to process efficiency, 

as described in section 2.2 of Part Two of 

this memorandum. Also, provides data 

described in section 2.3 of Part Two of this 

memorandum that could be used to 

calculate the mass of aluminum produced 

if the both the slope coefficient (as 

required to be reported in 40 CFR 

98.66(c)(3) or using a default value 

provided in Table F-1) and reported GHG 

emissions (as currently reported under 40 

CFR 98.3(c)(4) and made publicly 

available) 5 are also known. 

F §98.66(c)(2) Potline overvoltage. Used to calculate 

the overvoltage 

factor used as an 

input in Eq. F-3 

Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the mass of aluminum 

produced if reported GHG emissions (as 

currently reported under 40 CFR 

98.3(c)(4) and made publicly available) 5 

are also known. 

F §98.66(c)(2) Current efficiency. Used to calculate 

the overvoltage 

factor used as an 

input in Eq. F-3 

Provides data related to process design; 

process performance, and operation; 

and/or cost to do business, as described in 

section 2.2 of Part Two of this 

memorandum. Specifically, could provide 

some indication of cell performance and 

production efficiency. 

F §98.66(c)(3) Smelter-specific slope coefficients. 

(SCF4) 

F-2 Provides data related to process efficiency, 

as described in section 2.2 of Part Two of 

this memorandum. Also, provides data 

described in section 2.3 of Part Two of this 

memorandum that could be used to 

calculate the mass of aluminum produced 

if both the AEM (as required to be 

reported in 40 CFR 98.66(c)(2)) and 

reported GHG emissions (as currently 

reported under 40 CFR 98.3(c)(4) and 

made publicly available) 5 are also known. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

56

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

F §98.66(c)(3) Overvoltage emission factors. 

(EFCF4) 

F-3 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the mass of aluminum 

produced if reported GHG emissions (as 

currently reported under 40 CFR98.3(c)(4) 

and made publicly available) 5 are also 

known. 

F §98.66(e)(1) Annual anode consumption. (No 

CEMS) (NAC ) 

F-5 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

F §98.66(f)(1) Annual paste consumption. (No 

CEMS) (PC ) 

F-6 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

F §98.66(g) Sulfur content in baked anode 

(percent weight). (Sa) 

F-5 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

F §98.66(g) Ash content in baked anode 

(percent weight). (Asha) 

F-5 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

F §98.66(g) Binder content of paste (percent 

weight). (BC)

F-6 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

F §98.66(g) Sulfur content of pitch (percent 

weight). (Sp) 

F-6 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

F §98.66(g) Ash content of pitch (percent 

weight). (Ashp) 

F-6 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

F §98.66(g) Hydrogen content of pitch (percent 

weight). (Hp) 

F-6 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

F §98.66(g) Sulfur content in calcined coke 

(percent weight). (Sc) 

F-6 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

F §98.66(g) Ash content in calcined coke 

(percent weight). (Ashc) 

F-6 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

F §98.66(g) Carbon in skimmed dust from 

Soderberg cells (metric ton 

C/metric ton Al) (CD). 

F-6 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

F §98.66(g) Initial weight of green anodes 

(metric tons) (GA). 

F-7 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

F §98.66(g) Annual hydrogen content in green 

anodes (metric tons) (Hw). 

F-7 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

F §98.66(g) Annual baked anode production 

(metric tons) (BA). 

F-7 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

F §98.66(g) Annual waste tar collected (metric 

tons) (WT). 

F-7 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

57

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

F §98.66(g) Annual packing coke consumption 

(metric tons/metric ton baked 

anode) (PCC). 

F-8 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

F §98.66(g) Annual baked anode production 

(metric tons) (BA). 

F-8 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

F §98.66(g) Sulfur content in packing coke 

(percent weight) (SPc). 

F-8 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

F §98.66(g) Ash content in packing coke 

(percent weight) (Ashpc). 

F-8 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

G §98.76(b)(2) Monthly quantity of each type of 

feedstock consumed for ammonia 

manufacturing - Gaseous 

Feedstock. 

G-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

G §98.76(b)(2) Monthly quantity of each type of 

feedstock consumed for ammonia 

manufacturing - Liquid Feedstock. 

G-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

G §98.76(b)(2) Monthly quantity of each type of 

feedstock consumed for ammonia 

manufacturing - Solid Feedstock. 

G-3 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

G §98.76(b)(7) Carbon content of the gaseous 

feedstock. 

G-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

G §98.76(b)(8) Molecular weight of the gaseous 

feedstock. 

G-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

G §98.76(b)(9) Molar volume conversion factor of 

the gaseous feedstock. 

G-1 Is a constant value widely known within 

the industry and publicly available. 

Otherwise, does not include, and could not 

be used to calculate, data or information 

about facility or process performance, 

design, and operation; cost to do business; 

raw material usage; or production . 

G §98.76(b)(10) Carbon content of the liquid 

feedstock, for month n. 

G-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

G §98.76(b)(11) Carbon content of the solid 

feedstock, for month n. 

G-3 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

H §98.86(b)(2) Monthly clinker production for 

each kiln (No CEMS). 

H-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

H §98.86(b)(5) Quarterly quantity of CKD not 

recycled to the kiln. 

H-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

H §98.86(b)(6) Monthly fraction of total CaO in 

clinker. 

H-3 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

H §98.86(b)(6) Monthly fraction of total MgO in 

clinker. 

H-3 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
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58

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

H §98.86(b)(6) Monthly fraction of non-calcined 

CaO in clinker. 

H-3 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

H §98.86(b)(6) Monthly fraction of non-calcined 

MgO in clinker. 

H-3 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

H §98.86(b)(8) Quarterly fraction of total CaO in 

CKD not recycled to the kiln. 

H-4 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

H §98.86(b)(8) Quarterly fraction of total MgO in 

CKD not recycled to the kiln. 

H-4 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

H §98.86(b)(8) Quarterly fraction of non-calcined 

CaO in CKD not recycled to the 

kiln. 

H-4 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

H §98.86(b)(8) Quarterly fraction of non-calcined 

MgO in CKD not recycled to the 

kiln. 

H-4 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

H §98.86(b)(10) Monthly kiln-specific clinker CO2

emission factors for each kiln. 

H-2 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the mass of clinker 

produced if reported GHG emissions (as 

currently reported under 40 CFR 

§98.3(c)(4) and made publicly available) 5, 

are also known. 

H §98.86(b)(11) Quarterly kiln-specific CKD CO2

emission factors for each kiln. 

H-2 Provides data described in section 2.3 in 

Part Two of this memorandum that could 

be used to calculate the mass of clinker 

produced if all of the following data are 

also known:CKD not recycled to the kiln 

(as required to be reported in 40 CFR 

98.86(b)(5)), CO2 emissions (as currently 

required to be reported under 40 CFR 

98.3(c)(4) and made publicly available) 5, 

kiln-specific clinker emission factorm (as 

required to be reported in40 CFR 

98.86(b)(10)), and kiln-specific CKD 

emission factor (as required to be reported 

in 40 CFR 98.86(b)(11)). The CKD 

emission factor represents a minor portion 

of reported emissions and would reveal 

minimal information about total process 

output. However, if the kiln-specific 

clinker emission factor or kiln-specific 

CKD emission factor were not reported, 

would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. 

H §98.86(b)(12) Annual organic carbon content of 

each raw kiln feed or annual 

organic carbon content of each 

raw material. 

H-5 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

59

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

H §98.86(b)(13) Annual consumption of each raw 

kiln feed or annual consumption of 

each raw material. 

H-5 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

H §98.86(b)(13) Name of raw kiln feed or raw 

material. 

 Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. 

H §98.86(b)(15) Monthly kiln-specific raw kiln 

feed to clinker produced factors (if 

used) for each kiln. 

Used to calculate 

clinker 

production by 

facilities using the 

method in 40 

CFR 98.84(d) 

(i.e., kiln-specific 

clinker-to-feed 

factors) 

 Provides data related to process design; 

process performance, and operation; 

and/or cost to do business, as described in 

section 2.2 of Part Two of this 

memorandum. Specifically, indicates the 

design efficiency of the unit. 

K §98.116(b) Annual production by product 

from each EAF (tons) (used as 

input to Eq K-1): Mproductk= 

Annual mass of alloy product k 

tapped from EAF (tons). 

K-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

K §98.116(b) Annual production by product 

from each EAF (tons) (used as 

input to Eq K-3). 

K-3 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

K §98.116(e)(4) Annual material quantity for each 

material included for the 

calculation of annual process CO2

emissions (No CEMS): Mreducing 

agenti= Annual mass of reducing 

agent i fed, charged, or otherwise 

introduced into the EAF (tons). 

K-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

K §98.116(e)(4) Annual material quantity for each 

material included for the 

calculation of annual process CO2

emissions (No CEMS): 

Melectrodem= Annual mass of 

carbon electrode m consumed in 

the EAF (tons). 

K-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

K §98.116(e)(4) Annual material quantity for each 

material included for the 

calculation of annual process CO2

emissions (No CEMS): Moreh= 

Annual mass of ore h charged to 

the EAF (tons). 

K-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

K §98.116(e)(4) Annual material quantity for each 

material included for the 

calculation of annual process CO2

emissions (No CEMS): Mfluxj= 

Annual mass of flux material j fed, 

charged, or otherwise introduced 

into the EAF to facilitate slag 

formation (tons). 

K-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
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60

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

K §98.116(e)(4) Annual material quantity for each 

material included for the 

calculation of annual process CO2

emissions (No CEMS): Mnonproduct outgoingl= Annual mass 

of non-product outgoing material l 

removed from EAF (tons). 

K-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

K §98.116(e)(5) Annual average of the carbon 

content determinations for each 

material included for the 

calculation of annual process CO2

emissions (No CEMS): Creducing 

agenti= Carbon content in reducing 

agent i (percent by weight, 

expressed as a decimal fraction). 

K-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

K §98.116(e)(5) Annual average of the carbon 

content determinations for each 

material included for the 

calculation of annual process CO2

emissions (No CEMS): 

Celectrodem= Carbon content of 

the carbon electrode m (percent by 

weight, expressed as a decimal 

fraction). 

K-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

K §98.116(e)(5) Annual average of the carbon 

content determinations for each 

material included for the 

calculation of annual process CO2

emissions (No CEMS): Coreh= 

Carbon content in ore h (percent 

by weight, expressed as a decimal 

fraction). 

K-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

K §98.116(e)(5) Annual average of the carbon 

content determinations for each 

material included for the 

calculation of annual process CO2

emissions (No CEMS): Cfluxj= 

Carbon content in flux material j 

(percent by weight, expressed as a 

decimal fraction). 

K-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

K §98.116(e)(5) Annual average of the carbon 

content determinations for each 

material included for the 

calculation of annual process CO2

emissions (No CEMS): 

Cproductk= Carbon content in 

alloy product k . (percent by 

weight, expressed as a decimal 

fraction). 

K-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
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61

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

K §98.116(e)(5) Annual average of the carbon 

content determinations for each 

material included for the 

calculation of annual process CO2

emissions (No CEMS): Cnonproduct outgoingl= Carbon content 

in non-product outgoing material l 

(percent by weight, expressed as a 

decimal fraction). 

K-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

L §98.126(b)(1) Elements of the sum (a, b, c, etc.) 

(e.g., measured variables in the 

sum). 

L-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

L §98.126(b)(1) eSA (absolute error of the sum, 

expressed as one half of a 95 

percent confidence interval). Note 

that where eSA = the overall 

absolute error calculated for the 

process emissions you report under 

§98.126(a)(2), this data element 

was not deferred in the inputs 

deferral rule (76 FR 53057, August 

25, 2011), and would be required 

to be reported. 

L-1 Does not include, and could not be used to 

calculate, data or information about facility 

or process performance, design, and 

operation; cost to do business; raw 

material usage; or production. 2

L §98.126(b)(1) ea, eb, ec = Relative error of a, b, 

or c, respectively, expressed as one 

half of a 95 percent confidence 

interval. 

L-1 Does not include, and could not be used to 

calculate, data or information about facility 

or process performance, design, and 

operation; cost to do business; raw 

material usage; or production. 2

L §98.126(b)(1) Elements of the sum (a, b, c, etc.) 

(e.g., measured variables in the 

sum). 

L-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

L §98.126(b)(1) a+b+c = Sum of the variables 

measured. 

L-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

L §98.126(b)(1) eSR (relative error of the sum, 

expressed as one half of a 95 

percent confidence interval). Note 

that where eSR = the overall 

relative error calculated for the 

process emissions you report under 

§§98.126(a)(2), this data element 

was not deferred in the inputs 

deferral rule (76 FR 53057, August 

25, 2011), and would be required 

to be reported. 

L-2 Does not include, and could not be used to 

calculate, data or information about facility 

or process performance, design, and 

operation; cost to do business; raw 

material usage; or production. 2

L §98.126(b)(1) eSA (absolute error of the sum, 

expressed as one half of a 95 

percent confidence interval). Note 

that where eSA = the overall 

absolute error calculated for the 

process emissions you report under 

§98.126(a)(2), this data element 

was not deferred in the inputs 

deferral rule (76 FR 53057, August 

25, 2011) , and would be required 

to be reported. 

L-2 Does not include, and could not be used to 

calculate, data or information about facility 

or process performance, design, and 

operation; cost to do business; raw 

material usage; or production . 2
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62

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

L §98.126(b)(1) Elements of the sum (a, b, c, etc.) 

(e.g., measured variables in the 

sum). 

L-3 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

L §98.126(b)(1) ea, eb, ec = Relative error of a, b, 

or c, respectively, expressed as one 

half of a 95 percent confidence 

interval. 

L-3 Does not include, and could not be used to 

calculate, data or information (about 

facility or process performance, design, 

and operation; cost to do business; raw 

material usage; or production) that would 

reveal information that could cause 

competitive harm. 2

L §98.126(b)(1) ePA (absolute error of the product, 

expressed as one half of a 95 

percent confidence interval). Note 

that where ePA = the overall 

absolute error calculated for the 

process emissions you report under 

§98.126(a)(2), this data element 

was not deferred in the inputs 

deferral rule (76 FR 53057, August 

25, 2011) , and would be required 

to be reported. 

L-3 Does not include, and could not be used to 

calculate, data or information about facility 

or process performance, design, and 

operation; cost to do business; raw 

material usage; or production . 2

L §98.126(b)(1) a*b*c = Product of the variables 

measured. 

L-3 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

L §98.126(b)(1) Measured variables of the product 

(a, b, c, etc.). 

L-4 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

L §98.126(b)(1) a*b*c = Product of the variables 

measured. 

L-4 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

L §98.126(b)(1) ePR (relative error of the product, 

expressed as one half of a 95 

percent confidence interval). Note 

that where ePR = the overall 

relative error calculated for the 

process emissions you report under 

§98.126(a)(2), this data element 

was not deferred in the inputs 

deferral rule (76 FR 53057, August 

25, 2011) , and would be required 

to be reported. 

L-4 Does not include, and could not be used to 

calculate, data or information about facility 

or process performance, design, and 

operation; cost to do business; raw 

material usage; or production.2

L §98.126(b)(1) ePA (absolute error of the product, 

expressed as one half of a 95 

percent confidence interval). Note 

that where ePA = the overall 

absolute error calculated for the 

process emissions you report under 

§98.126(a)(2), this data element 

was not deferred in the inputs 

deferral rule (76 FR 53057, August 

25, 2011) , and would be required 

to be reported. 

L-4 Does not include, and could not be used to 

calculate, data or information about facility 

or process performance, design, and 

operation; cost to do business; raw 

material usage; or production. 2
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

63

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

L §98.126(b)(2) The balanced chemical equation 

that describes the reaction used to 

manufacture the fluorinated GHG 

product and each fluorinated GHG 

transformation product. 

 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

L §98.126(b)(6) The mass of each fluorinecontaining reactant that is fed into 

the process. (Rd) 

L-6 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

L §98.126(b)(7) The mass of each fluorinecontaining product produced by 

the process. (P) 

L-6 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

L §98.126(b)(8)(i) The mass of each fluorinecontaining product that is removed 

from the process and fed into the 

destruction device (metric tons). 

(Pj) 

L-7 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

L §98.126(b)(8)(ii) The mass of each fluorinecontaining by-product that is 

removed from the process and fed 

into the destruction device (metric 

tons). (Bkj) 

L-7 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

L §98.126(b)(8)(iii) The mass of each fluorinecontaining reactant that is removed 

from the process and fed into the 

destruction device (metric tons). 

(Rdj) 

L-7 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

L §98.126(b)(8)(iv) The mass of each fluorinecontaining by-product that is 

removed from the process and 

recaptured (metric tons). (Bkl) 

L-7 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

L §98.126(b)(8)(v) The demonstrated destruction 

efficiency of the destruction device 

for each fluorinated GHG fed into 

the device from the process in 

greater than trace concentrations 

(fraction). (DEFGHGf= 

Destruction efficiency of the 

device that has been demonstrated 

for fluorinated GHG f in stream j 

(fraction).) 

L-8 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the amount of 

fluorinated GHG in a waste stream 

removed from the process and sent to a 

destruction device, if the following 

information is also known: (1) annual 

emissions of each fluorinated GHG (as 

required to be reported under 40 CFR 

98.126(a)(2)); and (2) that the emissions 

consist exclusively of post-destruction 

device emissions (information that a 

competitor knowledgeable of some aspects 

of the facility and/or of fluorine chemistry 

might deduce). 2

 

L §98.126(b)(9)(i) The mass of fluorine in each 

stream that is fed into the 

destruction device (metric tons). 

(cTFj * Sj) 

L-17 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

L §98.126(b)(9)(ii) The mass of fluorine that is 

recaptured (metric tons). (cTFl * 

Sl) 

L-17 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

64

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

L §98.126(b)(9)(iii) The weighted average destruction 

efficiency of the destruction device 

calculated for each stream under 

§98.123(b)(16). (DEavgj) 

L-17 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the concentration of 

fluorine-containing reactants, products or 

byproducts in waste streams if the 

following information is also known: (1) 

annual emissions of each fluorinated GHG 

(as required to be reported under 40 CFR 

98.126(a)(2)); (2) that only one stream 

with only one fluorine compound is sent to 

the destruction device; (information that a 

competitor knowledgeable of some aspects 

of the facility and/or of fluorine chemistry 

might deduce). 2

L §98.126(b)(10) The fraction of the mass emitted 

that consists of each fluorinecontaining reactant (FERd). 

L-11 This data element is not addressed because 

this is a reported emissions value, which is 

addressed in a separate action related to 

subpart L of part 98. 

L §98.126(b)(10) The fraction of the mass emitted 

that consists of each fluorinecontaining reactant. (FERd). 

L-12 This data element is not addressed because 

this is a reported emissions value, which is 

addressed in a separate action related to 

subpart L of part 98. 

L §98.126(b)(10) The fraction of the mass emitted 

that consists of each fluorinecontaining reactant (FERd). 

L-13 This data element is not addressed because 

this is a reported emissions value, which is 

addressed in a separate action related to 

subpart L of part 98. 

L §98.126(b)(11) The fraction of the mass emitted 

that consists of the fluorinecontaining product (FEP). 

L-11 This data element is not addressed because 

this is a reported emissions value, which is 

addressed in a separate action related to 

subpart L of part 98. 

L §98.126(b)(11) The fraction of the mass emitted 

that consists of the fluorinecontaining product. (FEP) 

L-12 This data element is not addressed because 

this is a reported emissions value, which is 

addressed in a separate action related to 

subpart L of part 98. 

L §98.126(b)(11) The fraction of the mass emitted 

that consists of the fluorinecontaining product. (FEP). 

L-13 This data element is not addressed because 

this is a reported emissions value, which is 

addressed in a separate action related to 

subpart L of part 98. 

L §98.126(b)(12) The fraction of the mass emitted 

that consists of each fluorinecontaining by-product (FEBk). 

L-11 This data element is not addressed because 

this is a reported emissions value, which is 

addressed in a separate action related to 

subpart L of part 98. 

L §98.126(b)(12) The fraction of the mass emitted 

that consists of each fluorinecontaining by-product. (FEBk) 

L-12 This data element is not addressed because 

this is a reported emissions value, which is 

addressed in a separate action related to 

subpart L of part 98. 

L §98.126(b)(12) The fraction of the mass emitted 

that consists of each fluorinecontaining by-product. (FEBk) 

L-13 This data element is not addressed because 

this is a reported emissions value, which is 

addressed in a separate action related to 

subpart L of part 98. 
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65

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

L §98.126(c)(1) The quantity of the process activity 

used to estimate emissions (e.g., 

tons of product produced or tons of 

reactant consumed). (ActivityC or 

ActivityU) 

L-21 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

L §98.126(c)(1) The quantity of the process activity 

used to estimate emissions (e.g., 

tons of product produced or tons of 

reactant consumed). (ActivityC or 

ActivityU) 

L-22 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

L §98.126(c)(1) The quantity of the process activity 

used to estimate emissions (e.g., 

tons of product produced or tons of 

reactant consumed). (Activity) 

L-26 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

L §98.126(c)(1) The quantity of the process activity 

used to estimate emissions (e.g., 

tons of product produced or tons of 

reactant consumed). (ActivityU or 

ActivityC) 

L-27 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

L §98.126(c)(2) The site-specific, process-ventspecific emission factor(s) for each 

process vent (EFPV). 

L-20 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the process feed rate, 

production process rate, or other process 

activity rate if the mass of fluorinated 

GHG emitted from the process vent (as 

required to be reported in 40 CFR 

98.126(c)(3)) is also known. 2

L §98.126(c)(2) The site-specific, process-ventspecific emission factor(s) for each 

process vent (EFPV–C). 

L-21 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the process feed rate, 

production process rate, or other process 

activity rate if the mass of fluorinated 

GHG emitted from the process vent (as 

required to be reported in 40 CFR 

98.126(c)(3)) is also known. 2

L §98.126(c)(2) The site-specific, process-ventspecific emission calculation factor 

for each process vent. (ECFPV-U). 

L-21 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the process feed rate, 

production process rate, or other process 

activity rate if the mass of fluorinated 

GHG emitted from the process vent (as 

required to be reported in 40 CFR 

98.126(c)(3)) is also known. 2

L §98.126(c)(2) The site-specific, process-ventspecific emission factor(s) for each 

process vent (EFPV–U). 

L-22 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the process feed rate, 

production process rate, or other process 

activity rate if the mass of fluorinated 

GHG emitted from the process vent (as 

required to be reported in 40 CFR 

98.126(c)(3)) is also known. 2
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

66

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

L §98.126(c)(2) The site-specific, process-ventspecific emission factor(s) for each 

process vent. (EFPV) 

L-23 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the process feed rate, 

production process rate, or other process 

activity rate if the mass of fluorinated 

GHG emitted from the process vent (as 

required to be reported in 40 CFR 

98.126(c)(3)) is also known. 2

L §98.126(c)(2) The site-specific, process-ventspecific emission calculation factor 

for each process vent. (ECFPV). 

L-25 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the process feed rate, 

production process rate, or other process 

activity rate if the mass of fluorinated 

GHG emitted from the process vent (as 

required to be reported in 40 CFR 

98.126(c)(3)) is also known. 2

L §98.126(c)(2) The site-specific, process-ventspecific emission calculation factor 

for each process vent (ECFPV). 

L-26 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the process feed rate, 

production process rate, or other process 

activity rate if the mass of fluorinated 

GHG emitted from the process vent (as 

required to be reported in 40 CFR 

98.126(c)(3)) is also known. 2

L §98.126(c)(2) The site-specific, process-ventspecific emission calculation factor 

for each process vent. (ECFPV). 

L-27 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the process feed rate, 

production process rate, or other process 

activity rate if the mass of fluorinated 

GHG emitted from the process vent (as 

required to be reported in 40 CFR 

98.126(c)(3)) is also known. 2

L §98.126(d) Where missing data have been 

estimated pursuant to §98.125 

report, estimate of the missing 

data. 

Varies Provides data (missing data could include 

the data specified in 40 CFR 98.126(b) and 

(c)), which could be used (as specified for 

those citations in this table) to calculate the 

process feed rate, production process rate, 

or other process activity rate; or the mass 

of fluorinated GHG entering the 

destruction device. 2

L §98.126(f)(1) Destruction efficiency (DE) of 

each destruction device for each 

fluorinated GHG whose 

destruction the facility reflects in 

§98.123, in accordance with 

§98.124(g)(1)(i) through (iv). 

(DEFGHGf) 

L-8 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the amount of 

fluorinated GHG in a waste stream 

removed from the process and sent to a 

destruction device, if the following 

information is also known: (1) annual 

emissions of each fluorinated GHG (as 

required to be reported under 40 CFR 

98.126(a)(2)); and (2) that the emissions 

consist exclusively of post-destruction 

device emissions (information that a 

competitor knowledgeable of some aspects 

of the facility and/or of fluorine chemistry 

might deduce). 2
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67

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

L §98.126(f)(1) Destruction efficiency (DE) of 

each destruction device for each 

fluorinated GHG whose 

destruction the facility reflects in 

§98.123, in accordance with 

§98.124(g)(1)(i) through (iv). 

(DEFGHGf) 

L-18 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the amount of 

fluorinated GHG in a destroyed stream 

removed from the process and sent to a 

destruction device, if the following 

information is also known: (1) annual 

emissions of each fluorinated GHG (as 

required to be reported under 40 CFR 

98.126(a)(2); (2) that only one stream with 

only one fluorine compound is sent to the 

destruction device (information that a 

competitor knowledgeable of some aspects 

of the facility and/or of fluorine chemistry 

might deduce). 2

L §98.126(f)(1) Destruction efficiency (DE) of 

each destruction device for each 

fluorinated GHG whose 

destruction the facility reflects in 

§98.123, in accordance with 

§98.124(g)(1)(i) through (iv). (DE 

) 

L-22 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the process feed rate, 

production process rate, or other process 

activity rate if the emission factor for 

fluorinated GHG emitted from process 

vents (as required to be reported in 40 CFR 

98.126(c)(2)) and the mass of fluorinated 

GHG emitted from the process vents (as 

required to be reported in 40 CFR 

98.126(c)(3)) are also known. 2

L §98.126(f)(1) Destruction efficiency (DE) of 

each destruction device for each 

fluorinated GHG whose 

destruction the facility reflects in 

§98.123, in accordance with 

§98.124(g)(1)(i) through (iv) (DE). 

L-27 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the process feed rate, 

production process rate, or other process 

activity rate if the emission factor for 

fluorinated GHG emitted from process 

vents (as required to be reported in 40 CFR 

98.126(c)(2)) and the mass of fluorinated 

GHG emitted from the process vents (as 

required to be reported in 40 CFR 

98.126(c)(3)) are also known.2

L §98.126(f)(1) Destruction efficiency (DE) of 

each destruction device for each 

fluorinated GHG whose 

destruction the facility reflects in 

§98.123, in accordance with 

§98.124(g)(1)(i) through (iv) (DE). 

L-31 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the mass of fluorinated 

GHGs that were previously produced (and 

that are fed annually into the destruction 

device) if the mass of fluorinated GHGs 

emitted annually from destruction of 

fluorinated GHGs that were previously 

produced (as required to be reported in 40 

CFR 98.126(g)(2)) is also known. 2

L §98.126(g)(1) The mass of the fluorinated GHG 

fed into the destruction device. 

(RED) 

L-31 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
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68

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

L §98.126(h)(2) If applicable, the heel factor 

calculated for each container size 

and type. (hfj) 

L-34 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the number of tanks 

processed if the emissions from each type 

of container (as required to be reported in 

40 CFR 98.126(h)(1 )) are also known. 

The number of each type of tank processed 

and the size of the tanks could provide 

insight into product sales. 2

N §98.146(b)(6) Fraction of calcination for 

carbonate-based raw material. 

N-1 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the recipe for the glass 

produced (i.e., the product of the annual 

average mass fraction of carbonate-based 

mineral in carbonate-based raw material 

and the annual mass of carbonate-based 

raw material) if the CO2 emissions (as 

currently reported under 40 CFR 

98.3(c)(4) and made publicly available) 5

are also known. 

N §98.146(b)(2) Annual quantity of carbonate 

based-raw material charged to each 

continuous glass melting furnace 

(No CEMS). 

N-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

N §98.146(b)(4) Carbonate-based mineral mass 

fraction of carbonate-based raw 

material charged to a furnace. 

N-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

O §98.156(a)(2) Loss Factor used to account for the 

loss of HCFC– 22 upstream of the 

measurement (LF used in equation 

O-3). 

O-3 Provides data related to process design; 

process performance, and operation; 

and/or cost to do business, as described in 

section 2.2 of Part Two of this 

memorandum. Specifically, indicates 

process performance and efficiency, as 

well as cost to do business (i.e., how much 

of a facility’s product is lost). 

O §98.156(a)(7) Annual mass of the HFC-23 

generated (G23 in Eq. O-4). 

O-4 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

O §98.156(a)(8) Annual mass of any HFC-23 sent 

off site for sale (S23 in Eq. O-4). 

O-4 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

O §98.156(a)(9) Annual mass of any HFC-23 sent 

off site for destruction (OD23 used 

in Eq. O-4). 

O-4 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

O §98.156(a)(10) Mass of HFC-23 in storage at the 

beginning of the year (used to 

calculate I23, which is used in Eq. 

O-4). 

O-4 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

O §98.156(a)(10) Mass of HFC-23 in storage at the 

end of the year (used to calculate 

I23, which is used in Eq. O-4). 

O-4 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

O §98.156(b)(1) Annual mass of HFC-23 fed into 

the destruction device (FD used in 

Eq. O-8 and O-9). 

O-8 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

69

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

O §98.156(b)(1) Annual mass of HFC-23 fed into 

the destruction device (FD used in 

Eq. O-8 and O-9). 

O-9 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

O §98.156(b)(2) Annual mass of HFC-23 destroyed 

(D23 used in Eq. O-8). 

O-8 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

O §98.156(d)(1) If the HFC-23 concentration 

measured pursuant to §98.154(l) is 

greater than that measured during 

the performance test that is the 

basis for the destruction efficiency 

(DE), report flow rate of HFC-23 

being fed into the destruction 

device in kg/hr. 

No Equation - 

Used to calculate 

Destruction 

Efficiency 

Provides data related to process design; 

process performance, and operation; 

and/or cost to do business, as described in 

section 2.2 of Part Two of this 

memorandum. Specifically, if the facility 

produces HCFC-22 onsite, information 

about the HCFC-23 production rate reveals 

information about process efficiency, 

revealing information about the HCFC-22 

production rate. 

O §98.156(d)(2) If the HFC-23 concentration 

measured pursuant to §98.154(l) is 

greater than that measured during 

the performance test that is the 

basis for the destruction efficiency 

(DE), report concentration (mass 

fraction) of HFC-23 at the outlet of 

the destruction device. 

No Equation - 

Used to calculate 

Destruction 

Efficiency 

Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to estimate HCFC-23 production if 

the following data are also known: flow 

rate of HFC-23 being fed into the 

destruction device (as required to be 

reported in 40 CFR 98.156(d)(1)), flow 

rate at the outlet of the destruction device 

(as required to be reported in 40 CFR 

98.156(d)(3) (or emission rate as required 

to be reported in 40 CFR 98.156(d)(4)). If 

the facility produces HCFC-22 onsite, this 

HCFC-23 production rate reveals 

information about process efficiency, 

revealing information about the HCFC-22 

production rate. However, if the 

destruction efficiency (and flow rate of 

HFC-23 fed into the destruction device, 

which is used to calculate the destruction 

efficiency) were not reported, would not 

reveal any proprietary information about 

facility or process performance, design, 

and operation; cost to do business; raw 

material usage; or production. 

O §98.156(d)(3) If the HFC-23 concentration 

measured pursuant to §98.154(l) is 

greater than that measured during 

the performance test that is the 

basis for the destruction efficiency 

(DE), report flow rate at the outlet 

of the destruction device in kg/hr. 

No Equation - 

Used to calculate 

Destruction 

Efficiency 

Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to estimate HCFC-23 production if 

the destruction efficiency (as required to 

be reported in 40 CFR 98.156(d)(5)) is 

also known. If the facility produces 

HCFC-22 onsite, this HCFC-23 production 

rate reveals information about process 

efficiency, revealing information about the 

HCFC-22 production rate. However, if the 

destruction efficiency (and flow rate of 

HFC-23 fed into the destruction device, 

which is used to calculate the destruction 

efficiency), were not reported, would not 

reveal any proprietary information about 

facility or process performance, design, 

and operation; cost to do business; raw 

material usage; or production. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

70

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

O §98.156(d)(4) If the HFC-23 concentration 

measured pursuant to §98.154(l) is 

greater than that measured during 

the performance test that is the 

basis for the destruction efficiency 

(DE), report emission rate (in 

kg/hour) calculated from the 

paragraphs (d)(2) and (d)(3) of this 

section. 

No Equation - 

Used to calculate 

Destruction 

Efficiency 

Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to estimate HCFC-23 production if 

the destruction efficiency (as required to 

be reported in 40 CFR 98.156(d)(5)) is 

also known. If the facility produces 

HCFC-22 onsite, this HCFC-23 production 

rate reveals information about process 

efficiency, revealing information about the 

HCFC-22 production rate. However, if the 

destruction efficiency were not reported, 

would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. 

O §98.156(d)(5) If the HFC-23 concentration 

measured pursuant to §98.154(l) is 

greater than that measured during 

the performance test that is the 

basis for the destruction efficiency 

(DE), report the destruction 

efficiency (DE) calculated from 

paragraphs (d)(1) and (d)(4) of this 

section. 

O-9 Provides information about process 

efficiency, revealing information about the 

HCFC-22 production rate, if the facility 

produces HCFC-22 onsite. Also, provides 

data described in section 2.3 of Part Two 

of this memorandum that could be used to 

estimate HCFC-23 production if the 

HCFC-23 production rate is known. 

O §98.156(e)(1) (One time report) Destruction 

efficiency (DE) (by March 31, 

2011 or within 60 days of 

commencing HFC-23 destruction). 

O-9 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to estimate HCFC-23 production if 

the HCFC-23 production rate can be 

estimated. If the facility produces HCFC22 onsite, this HCFC-23 production rate 

reveals information about process 

efficiency, revealing information about the 

HCFC-22 production rate. 

P §98.156(b)(2) Monthly consumption of each fuel 

and feedstock by type used for 

hydrogen production (No CEMS): 

gaseous. 

P-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

P §98.156(b)(2) Monthly consumption of each fuel 

and feedstock by type used for 

hydrogen production (No CEMS) 

(Fdstkn): Liquid. 

P-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

P §98.156(b)(2) Monthly consumption of each fuel 

and feedstock by type used for 

hydrogen production (No CEMS) 

(Fdstkn): solid. 

P-3 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

P §98.156(b)(5) Monthly analyses of carbon 

content for each fuel and feedstock 

used in hydrogen production: 

Gaseous. 

P-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

P §98.156(b)(5) Monthly analyses of carbon 

content for each fuel and feedstock 

used in hydrogen production: 

Liquid. 

P-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

P §98.156(b)(5) Monthly analyses of carbon 

content for each fuel and feedstock 

used in hydrogen production: 

Solid. 

P-3 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

71

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

P §98.156(b)(6) Monthly analyses of the molecular 

weight of gaseous fuels and 

feedstocks. 

P-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(b) Annual quantity taconite pellets 

produced (No CEMS). 

Q-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(b) Annual quantity coke produced 

(No CEMS). 

Q-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(b) Annual quantity iron produced (No 

CEMS and not using the sitespecific EF method under 

§98.173(b)(2)). 

Q-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(b) Annual quantity raw steel 

produced (No CEMS and not using 

the site-specific EF method under 

§98.173(b)(2)). 

Q-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(b) Annual quantity sinter produced 

(No CEMS and not using the sitespecific EF method under 

§98.173(b)(2)). 

Q-4 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(b) Annual quantity raw steel 

produced (No CEMS and not using 

the site-specific EF method under 

§98.173(b)(2)). 

Q-5 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(b) Annual quantity raw steel 

produced (No CEMS and not using 

the site-specific EF method under 

§98.173(b)(2)). 

Q-6 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(b) Annual quantity iron produced (No 

CEMS and not using the sitespecific EF method under 

§98.173(b)(2)). 

Q-7 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

input used to determine CO2

emissions (No CEMS) - solid fuel 

combusted (Csf). 

Q-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

input used to determine CO2

emissions (No CEMS) -gaseous 

fuel combusted(Cgf). 

Q-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

input used to determine CO2

emissions (No CEMS)- liquid fuel 

combusted (Clf). 

Q-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

input used to determine CO2

emissions (No CEMS)- greenball 

pellets produced (Co). 

Q-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

72

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

Q §98.176(e)(1) Carbon content of each process 

output used to determine CO2 

emissions (No CEMS) - Fired 

pellets produced (Cp). 

Q-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

output used to determine CO2

emissions (No CEMS) - air 

pollution control residue collected 

(Cr). 

Q-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

input used to determine CO2

emissions (No CEMS)- Iron (Ciron). 

Q-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

input used to determine CO2

emissions (No CEMS)- Scrap 

(Cscrap). 

Q-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

input used to determine CO2

emissions (No CEMS)- Flux 

(Cflux). 

Q-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

input used to determine CO2

emissions (No CEMS)- 

Carbonaceous material (Ccarbon). 

Q-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

output used to determine CO2

emissions (No CEMS) - Steel 

produced (Csteel).. 

Q-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

output used to determine CO2

emissions (No CEMS) - Slag 

produced (Cslag). 

Q-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

output used to determine CO2

emissions (No CEMS) - Air 

pollution control residue collected 

(CR). 

Q-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

input used to determine CO2

emissions (No CEMS)- Coal 

charged to coke battery (Ccoal). 

Q-3 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

output used to determine CO2

emissions (No CEMS) - Coke 

produced by coke battery (Ccoke). 

Q-3 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

output used to determine CO2

emissions (No CEMS) - Air 

pollution control residue collected 

from coke battery (CR). 

Q-3 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

73

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

Q §98.176(e)(1) Carbon content of each process 

input used to determine CO2

emissions (No CEMS)- Gaseous 

fuel combusted in the sinter 

process (Cgf). 

Q-4 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

input used to determine CO2

emissions (No CEMS) - sinter feed 

(CFeed). 

Q-4 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

output used to determine CO2

emissions (No CEMS) - sinter 

(CSinter). 

Q-4 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

output used to determine CO2

emissions (No CEMS) - Air 

pollution control residue collected 

from sinter process (CR). 

Q-4 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

input used to determine CO2

emissions (No CEMS)- Iron (Ciron) 

used in EAF. 

Q-5 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

input used to determine CO2

emissions (No CEMS)- Scrap 

(Cscrap) used in EAF. 

Q-5 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

input used to determine CO2

emissions (No CEMS)- Flux (Cflux) 

used in EAF. 

Q-5 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

input used to determine CO2

emissions (No CEMS)- 

Carbonaceous material (Ccarbon) 

used in EAF. 

Q-5 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

input used to determine CO2

emissions (No CEMS)- Electrode 

consumed in EAF (Celectrode). 

Q-5 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

output used to determine CO2

emissions (No CEMS) - Steel 

produced (Csteel) in EAF. 

Q-5 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

output used to determine CO2

emissions (No CEMS) - Slag 

produced (Cslag) in EAF. 

Q-5 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

74

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

Q §98.176(e)(1) Carbon content of each process 

output used to determine CO2

emissions (No CEMS) - Air 

pollution control residue collected 

(CR) for EAF. 

Q-5 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

input used to determine CO2

emissions (No CEMS) - molten 

steel before decarburization 

(Csteelout) in EAF. 

Q-6 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

output used to determine CO2

emissions (No CEMS) - molten 

steel after decarburization (Csteelout) 

in EAF. 

Q-6 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

output used to determine CO2

emissions (No CEMS) - Air 

pollution control residue collected 

(CR) for EAF. 

Q-6 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

input used to determine CO2

emissions (No CEMS) - Gaseous 

fuel combusted in the direct 

reduction furnace (Fg) . 

Q-7 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

input used to determine CO2

emissions (No CEMS) - iron ore or 

iron ore pellets fed into the direct 

reduction furnace (Core) . 

Q-7 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

input used to determine CO2

emissions (No CEMS)- 

Carbonaceous material (Ccarbon) 

used in the direct reduction furnace 

. 

Q-7 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

input used to determine CO2

emissions (No CEMS) - Other 

materials charged to the direct 

reduction furnace (Cother). 

Q-7 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

output used to determine CO2

emissions (No CEMS) - Iron 

produced from direct reduction 

furnace (Ciron). 

Q-7 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(1) Carbon content of each process 

output used to determine CO2

emissions (No CEMS) - Nonmetallic materials produced from 

direct reduction furnace (CNM). 

Q-7 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

75

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

Q §98.176(e)(1) Carbon content of each process 

output used to determine CO2

emissions (No CEMS) - Air 

pollution control residue collected 

(CR) for direct reduction furnace. 

Q-7 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual volume of each type of 

gaseous fuel used to determine 

CO2 emissions (reported separately 

for each type in standard cubic 

feet) (No CEMS) - Taconite 

Indurating Furnace. 

Q-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual volume of each type of 

liquid fuel used to determine CO2

emissions (reported separately for 

each type in gallons) (No CEMS). 

Q-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process input used to 

determine CO2 emissions (No 

CEMS)- Annual mass of greenball 

(taconite) pellets fed into the 

furnace (O). 

Q-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process input used to 

determine CO2 emissions (No 

CEMS)- Annual mass of solid fuel 

combusted (Fs). 

Q-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process output used to 

determine CO2 emissions (No 

CEMS) - Annual mass of air 

pollution control residue (R). 

Q-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process output used to 

determine CO2 emissions (No 

CEMS) - Annual mass of fired 

pellets produced (P). 

Q-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process input used to 

determine CO2 emissions (No 

CEMS)- Annual mass of molten 

iron charged to furnace (Iron). 

Q-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process input used to 

determine CO2 emissions (No 

CEMS)- Annual mass of scrap 

charged to the furnace (Scrap). 

Q-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process input used to 

determine CO2 emissions (No 

CEMS)- Annual mass of flux 

charged to the furnace (Flux). 

Q-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

76

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process input used to 

determine CO2 emissions (No 

CEMS)- Annual mass of carbon 

(e.g., coal, coke) charged to 

furnace (Carbon). 

Q-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process output used to 

determine CO2 emissions (No 

CEMS) - Annual mass of steel 

produced (Steel). 

Q-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process output used to 

determine CO2 emissions (No 

CEMS) - Annual mass of slag 

produced (Slag). 

Q-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process output used to 

determine CO2 emissions (No 

CEMS) - Annual mass of air 

pollution control residue collected 

(Residue). 

Q-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process input used to 

determine CO2 emissions (No 

CEMS)- Coal charged to battery 

(Coal). 

Q-3 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process output used to 

determine CO2 emissions (No 

CEMS) - Annual mass of coke 

produced (Coke). 

Q-3 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process output used to 

determine CO2 emissions (No 

CEMS) - Annual mass of air 

pollution control residue collected 

from battery (R). 

Q-3 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual volume of each type of 

gaseous fuel used to determine 

CO2 emissions (reported separately 

for each type in standard cubic 

feet) (No CEMS) - Sinter process 

(Fg). 

Q-4 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process input used to 

determine CO2 emissions (No 

CEMS)- Annual mass of sinter 

feed material (Feed). 

Q-4 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

77

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process input used to 

determine CO2 emissions (No 

CEMS)- Annual mass of sinter 

Produced (Sinter). 

Q-4 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process output used to 

determine CO2 emissions (No 

CEMS) - Annual mass of air 

pollution control residue collected 

from sinter process (R). 

Q-4 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process input used to 

determine CO2 emissions (No 

CEMS)- Annual mass of direct 

reduced iron charged to the EAF 

(Iron). 

Q-5 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process input used to 

determine CO2 emissions (No 

CEMS)- Annual mass of Scrap 

charged to the EAF(Scrap). 

Q-5 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process input used to 

determine CO2 emissions (No 

CEMS)- Annual mass of flux 

charged to the EAF(Flux). 

Q-5 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process input used to 

determine CO2 emissions (No 

CEMS)- Annual mass of carbon 

electrode consumed in the 

EAF(Electrode). 

Q-5 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process input used to 

determine CO2 emissions (No 

CEMS)- Annual mass of 

carbonaceous (coal or coke) 

material charged to the 

EAF(Carbon). 

Q-5 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process input used to 

determine CO2 emissions (No 

CEMS)- Annual mass of steel 

produced (Steel) in EAF. 

Q-5 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process output used to 

determine CO2 emissions (No 

CEMS) - Annual mass of slag 

produced (Slag) in EAF. 

Q-5 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

78

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process output used to 

determine CO2 emissions (No 

CEMS) - Annual mass of air 

pollution control residue collected 

(Residue) from EAF. 

Q-5 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process input used to 

determine CO2 emissions (No 

CEMS)- Annual mass of steel 

charged to the decarburization 

vessel (Steel). 

Q-6 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process output used to 

determine CO2 emissions (No 

CEMS) - Annual mass of air 

pollution control residue collected 

(Residue) from the decarburization 

vessel. 

Q-6 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual volume of each type of 

gaseous fuel used to determine 

CO2 emissions (reported separately 

for each type in standard cubic 

feet) (No CEMS) - direct reduction 

furnaces (Fg). 

Q-7 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process input used to 

determine CO2 emissions (No 

CEMS)- Annual mass of iron ore 

or iron ore pellets charged to the 

direct reduction furnace (Ore). 

Q-7 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process input used to 

determine CO2 emissions (No 

CEMS)- Annual mass of 

carbonaceous (coal or coke) 

material charged to the direct 

reduction furnace (Carbon). 

Q-7 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process input used to 

determine CO2 emissions (No 

CEMS)- Annual mass of other 

material charged to the direct 

reduction furnace (Other). 

Q-7 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process input used to 

determine CO2 emissions (No 

CEMS)- Annual mass of iron 

produced (Iron) in direct reduction 

furnace. 

Q-7 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

79

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process input used to 

determine CO2 emissions (No 

CEMS)- Annual mass of nonmetallic materials produced (NM) 

in direct reduction furnace. 

Q-7 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(3) Annual mass (in metric tons) of 

each other process output used to 

determine CO2 emissions (No 

CEMS) - Annual mass of air 

pollution control residue collected 

(Residue) from the direct reduction 

furnace. 

Q-7 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(4) Molecular weight of gaseous fuels 

(No CEMS) - Taconite Indurating 

Furnace. 

Q-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(4) Molecular weight of gaseous fuels 

(No CEMS) - Sinter Process. 

Q-4 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(e)(4) Molecular weight of gaseous fuels 

(No CEMS) - Direct Reduction 

Furnace. 

Q-7 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(f)(1) Measured average hourly CO2

emission rate during the test (No 

CEMS). 

No Equation - 

Used as input to 

method described 

in 

§98.173(b)(2)(iii). 

Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate iron and steel 

production rate if the EF (as required to be 

reported in 40 CFR 98.176(f)(3)) is also 

known. However, if the EF were not 

reported, would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. 

Q §98.176(f)(2) Average hourly feed rate during 

the test (No CEMS). 

No Equation - 

Used as input in 

calc. method 

described in 

§98.173(b)(iii). 

Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(f)(2) Average hourly production rate 

during the test (No CEMS). 

No Equation - 

Used as input in 

calc. method 

described in 

§98.173(b)(iii). 

Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(f)(3) Site-specific emission factor (No 

CEMS). 

No Equation - 

Used as input in 

calc. method 

described in 

§98.173(b)(2)(iv). 

Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the iron and steel 

production if one of the following is also 

known: the measured average hourly CO2

emission rate during the test (as required to 

be reported in 40 CFR 98.176(f)(1)); or 

CO2 mass emissions (as currently reported 

under 40 CFR 98.3(c)(4) and made 

publicly available) 5. 

Q §98.176(f)(4) Annual feed rate used to estimate 

annual CO2 emissions (No CEMS). 

No Equation - 

Used as input in 

calc. method 

described in 

§98.173(b)(iv). 

Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

80

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

Q §98.176(f)(4) Annual production rate used to 

estimate annual CO2 emissions (No 

CEMS). 

No Equation - 

Used as input in 

calc. method 

described in 

§98.173(b)(iv). 

Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Q §98.176(g) The annual amount of coal charged 

to the coke ovens (in metric tons). 

No Equation - 

Used as input in 

calc. method 

described in 

§98.173(c). 

Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

R §98.186(b)(6) Annual material quantity used for 

the calculation of annual process 

CO2 emissions (No CEMS) (Ore = 

Annual mass of lead ore charged to 

the smelting furnace (tons).) 

R-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

R §98.186(b)(6) Annual material quantity used for 

the calculation of annual process 

CO2 emissions (No CEMS) (Scrap 

= Annual mass of lead scrap 

charged to the smelting furnace 

(tons).) 

R-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

R §98.186(b)(6) Annual material quantity used for 

the calculation of annual process 

CO2 emissions (No CEMS) (Flux 

= Annual mass of flux materials 

(e.g., limestone, dolomite) charged 

to the smelting furnace (tons).) 

R-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

R §98.186(b)(6) Annual material quantity used for 

the calculation of annual process 

CO2 emissions (No CEMS) 

(Carbon = Annual mass of 

carbonaceous materials (e.g., coal, 

coke) charged to the smelting 

furnace (tons).) 

R-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

R §98.186(b)(6) Annual material quantity used for 

the calculation of annual process 

CO2 emissions (No CEMS) (Other 

= Annual mass of any other 

material containing carbon, other 

than fuel, fed, charged, or 

otherwise introduced into the 

smelting furnace (tons).) 

R-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

R §98.186(b)(7) Annual average of the carbon 

content determinations for each 

material used for the calculation of 

annual process CO2 emissions (No 

CEMS) (COre= Carbon content of 

the lead ore, from the carbon 

analysis results (percent by weight, 

expressed as a decimal fraction).) 

R-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

81

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

R §98.186(b)(7) Annual average of the carbon 

content determinations for each 

material used for the calculation of 

annual process CO2 emissions (No 

CEMS). (CScrap= Carbon content 

of the lead scrap, from the carbon 

analysis (percent by weight, 

expressed as a decimal fraction).) 

R-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

R §98.186(b)(7) Annual average of the carbon 

content determinations for each 

material used for the calculation of 

annual process CO2 emissions (No 

CEMS). (CFlux= Carbon content 

of the flux materials, from the 

carbon analysis (percent by weight, 

expressed as a decimal fraction).) 

R-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

R §98.186(b)(7) Annual average of the carbon 

content determinations for each 

material used for the calculation of 

annual process CO2 emissions (No 

CEMS). (CCarbon= Carbon 

content of the carbonaceous 

materials, from the carbon analysis 

(percent by weight, expressed as a 

decimal fraction).) 

R-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

R §98.186(b)(7) Annual average of the carbon 

content determinations for each 

material used for the calculation of 

annual process CO2 emissions (No 

CEMS). (COther= Carbon content 

of the other material from the 

carbon analysis results (percent by 

weight, expressed as a decimal 

fraction).) 

R-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

S §98.196(b)(2) Monthly emission factors for each 

lime type produced. 

 S-4 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the production rate for 

each lime product if annual CO2 process 

emissions (as currently reported under 40 

CFR 98.3(c)(4) and made publicly 

available) 5 is known. 

S §98.196(b)(3) Monthly emission factors for each 

calcined byproduct/waste by lime 

type that is sold. (EFLKD,i,n) 

S-4 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the weight or mass of 

calcined byproducts/waste sold if annual 

CO2 process emissions (as currently 

reported under 40 CFR 98.3(c)(4) and 

made publicly available) 5 is known. 

S §98.196(b)(5) Monthly results of chemical 

composition analysis of each type 

of lime product produced (No 

CEMS). 

No Equation -

described in 

§98.196(b)(5). 

Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

82

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

S §98.196(b)(5) Monthly results of chemical 

composition analysis of each type 

of calcined lime byproducts/wastes 

sold (No CEMS). 

No Equation -

described in 

§98.196(b)(5). 

Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

S §98.196(b)(6) Annual results of chemical 

composition analysis of each type 

of lime byproducts/wastes that is 

not sold (No CEMS). 

No Equation -

described in 

§98.196(b)(6). 

Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

S §98.196(b)(8) Monthly amount of lime product 

sold, by type (No CEMS). 

No Equation -

described in 

§98.196(b)(8). 

Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

S §98.196(b)(10) Monthly amount of calcined lime 

byproduct/waste sold, by type (No 

CEMS). 

No Equation -

described in 

§98.196(b)(10). 

Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

S §98.196(b)(11) Annual amount of calcined lime 

byproduct/waste that is not sold, 

by type (No CEMS). 

No Equation -

described in 

§98.196(b)(11). 

Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

S §98.196(b)(12) Monthly weight or mass of each 

lime type produced (No CEMS). 

S-4 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

U §98.216(b) Annual carbonate consumption by 

carbonate type. 

U-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

U §98.216(b) Annual carbonate input by 

carbonate type. 

U-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

U §98.216(e)(1) Annual carbonate consumption by 

carbonate type. 

U-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

U §98.216(e)(2) Annual calcination fractions used 

in calculations. 

U-1 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the annual mass of 

each carbonate type consumed if the CO2 

emissions (as currently reported under 40 

CFR 98.3(c)(4) and made publicly 

available) 5 are also known. 

U §98.216(f)(1) Annual carbonate input by 

carbonate type. 

U-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

U §98.216(f)(2) Annual carbonate output by 

carbonate type. 

U-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

V §98.226(c) Annual nitric acid production from 

each nitric acid train (tons, 100% 

acid basis) (Pt). 

V-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

V §98.226(c) Annual nitric acid production from 

each nitric acid train (tons, 100% 

acid basis) (Pt) 

V-3a Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

83

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

V §98.226(c) Annual nitric acid production from 

each nitric acid train (tons, 100% 

acid basis) (Pt). 

V-3b Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

V §98.226(c) Annual nitric acid production from 

each nitric acid train (tons, 100% 

acid basis) (Pt). 

V-3c Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

V §98.226(c) Annual nitric acid production from 

each nitric acid train (tons, 100% 

acid basis) (Pt). 

V-3d Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

V §98.226(d) Annual nitric acid production 

during which N2O abatement 

technology is operating (tons, 

100% acid basis). 

V-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

V §98.226(i) Abatement technology destruction 

efficiency (DF). 

V-3a Provides data described in section 2.3 in 

Part Two of this memorandum that could 

be used to calculate the mass of adipic acid 

produced if all of the following data are 

also known: annual N2O mass emissions 

from nitric acid production (as currently 

reported under 40 CFR 98.3(c)(4) and 

made publicly available) 5, EFs (as 

required to be reported in 40 CFR 

98.226(m)(1)) and the abatement 

utilization factor (as required to be 

reported in 40 CFR 98.226(j)). However, if 

the EFs were not reported, would not 

reveal any proprietary information about 

facility or process performance, design, 

and operation; cost to do business; raw 

material usage; or production. 

V §98.226(i) Abatement technology destruction 

efficiency (DF). 

V-3b Provides data described in section 2.3 in 

Part Two of this memorandum that could 

be used to calculate the mass of adipic acid 

produced if all of the following data are 

also known: annual N2O mass emissions 

from nitric acid production (as currently 

reported under 40 CFR 98.3(c)(4) and 

made publicly available) 5, EFs (as 

required to be reported in 40 CFR 

98.226(m)(1)) and the abatement 

utilization factor (as required to be 

reported in 40 CFR 98.226(j)). However, if 

the EFs were not reported, would not 

reveal any proprietary information about 

facility or process performance, design, 

and operation; cost to do business; raw 

material usage; or production. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

84

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

V §98.226(i) Abatement technology destruction 

efficiency (DF). 

V-3c Provides data described in section 2.3 in 

Part Two of this memorandum that could 

be used to calculate the mass of adipic acid 

produced if all of the following data are 

also known: annual N2O mass emissions 

from nitric acid production (as currently 

reported under 40 CFR 98.3(c)(4) and 

made publicly available) 5, EFs (as 

required to be reported in 40 CFR 

98.226(m)(1)), the abatement utilization 

factor (as required to be reported in 40 

CFR 98.226(j)), and the fraction control 

factor (as required to be reported in 40 

CFR 98.226(p). However, if the EFs were 

not reported, would not reveal any 

proprietary information about facility or 

process performance, design, and 

operation; cost to do business; raw 

material usage; or production. 

V §98.226(j) Abatement utilization factor (AF). V-3a Provides data described in section 2.3 in 

Part Two of this memorandum that could 

be used to calculate the mass of nitric acid 

produced if all of the following data are 

also known: annual N2O mass emissions 

from nitric acid production (as currently 

reported under 40 CFR 98.3(c)(4) and 

made publicly available) 5, EFs (as 

required to be reported in 40 CFR 

98.226(m)(1)), and the destruction 

efficiency (as required to be reported in 40 

CFR 98.226(i)). However, if the EFs were 

not reported, would not reveal any 

proprietary information about facility or 

process performance, design, and 

operation; cost to do business; raw 

material usage; or production. 

V §98.226(j) Abatement utilization factor (AF). V-3b Provides data described in section 2.3 in 

Part Two of this memorandum that could 

be used to calculate the mass of nitric acid 

produced if all of the following data are 

also known: annual N2O mass emissions 

from nitric acid production (as currently 

reported under 40 CFR 98.3(c)(4) and 

made publicly available) 5, EFs (as 

required to be reported in 40 CFR 

98.226(m)(1)), and the destruction 

efficiency (as required to be reported in 40 

CFR 98.226(i)). However, if the EFs were 

not reported, would not reveal any 

proprietary information about facility or 

process performance, design, and 

operation; cost to do business; raw 

material usage; or production. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

85

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

V §98.226(j) Abatement utilization factor (AF). V-3c Provides data described in section 2.3 in 

Part Two of this memorandum that could 

be used to calculate the mass of adipic acid 

produced if all of the following data are 

also known: annual N2O mass emissions 

from nitric acid production (as currently 

reported under 40 CFR 98.3(c)(4) and 

made publicly available) 5, EFs (as 

required to be reported in 40 CFR 

98.226(m)(1)), destruction efficiency (as 

required to be reported in 40 CFR 

98.226(i)), and the fraction control factor 

(as required to be reported in 40 CFR 

98.226(p). However, if the EFs were not 

reported, would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. 

V §98.226(m)(1) Emission factor calculated for each 

nitric acid train (EFN2Ot). 

V-3a Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the mass of nitric acid 

produced if all of the following data are 

also known: annual N2O mass emissions 

from nitric acid production (as currently 

reported under 40 CFR 98.3(c)(4) and 

made publicly available) 5, destruction 

efficiency (as required to be reported in 40 

CFR 98.226(i)), and abatement utilization 

factor (as required to be reported in 40 

CFR 98.226(j)). However, if the 

destruction efficiency or abatement 

utilization factor were not reported, would 

not reveal any proprietary information 

about facility or process performance, 

design, and operation; cost to do business; 

raw material usage; or production. 

V §98.226(m)(1) Emission factor calculated for each 

nitric acid train (EFN2Ot). 

V-3b Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the mass of nitric acid 

produced if all of the following data are 

also known: annual N2O mass emissions 

from nitric acid production (as currently 

reported under 40 CFR 98.3(c)(4) and 

made publicly available) 5, destruction 

efficiency (as required to be reported in 40 

CFR 98.226(i)), and abatement utilization 

factor (as required to be reported in 40 

CFR 98.226(j)). However, if the 

destruction efficiency or abatement 

utilization factor were not reported, would 

not reveal any proprietary information 

about facility or process performance, 

design, and operation; cost to do business; 

raw material usage; or production. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

86

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

V §98.226(m)(1) Emission factor calculated for each 

nitric acid train (EFN2Ot). 

 V-3c Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the mass of nitric acid 

produced if all of the following data are 

also known: annual N2O mass emissions 

from nitric acid production (as currently 

reported under 40 CFR 98.3(c)(4) and 

made publicly available) 5, destruction 

efficiency (as required to be reported in 40 

CFR 98.226(i)), abatement utilization 

factor (as required to be reported in 40 

CFR 98.226(j)), and fraction control factor 

(as required to be reported in 40 CFR 

98.226(p)). However, if the destruction 

efficiency or abatement utilization factor, 

were not reported, would not reveal any 

proprietary information about facility or 

process performance, design, and 

operation; cost to do business; raw 

material usage; or production. 

V §98.226(m)(1) Emission factor calculated for each 

nitric acid train (EFN2Ot). 

V-3d Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the mass of nitric acid 

produced if the annual N2O mass 

emissions from nitric acid production (as 

currently reported under 40 CFR 

98.3(c)(4) and made publicly available) 5 is 

also known. 

V §98.226(m)(3) Production rate per test run during 

performance test for each train. 

V-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

V §98.226(m)(4) N2O concentration per test run 

during performance test for each 

train. 

V-1 Provides data described in section 2.3 in 

Part Two of this memorandum that could 

be used to calculate the production rate of 

nitric acid if all of the following data are 

also known: EFs (as required to be 

reported in 40 CFR 98.226(m)(1)), 

volumetric flow rate of effluent gas during 

the performance test (as required to be 

reported in 40 CFR 98.226(m)(5)), and 

number of test runs (as required to be 

reported in 40 CFR 98.226(m)(6). 

However, if the EFs were not reported, 

would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

87

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

V §98.226(m)(5) Volumetric flow rate per test run 

during performance test each train. 

V-1 Provides data described in section 2.3 in 

Part Two of this memorandum that could 

be used to calculate the production rate of 

nitric acid if the all following data are also 

known: EFs (as required to be reported in 

40 CFR 98.226(m)(1)), N2O concentration 

per test run during performance test (as 

required to be reported in 40 CFR 

98.226(m)(4)), and number of test runs (as 

required to be reported in 40 CFR 

98.56(m)(6). However, if the EFs were not 

reported, would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. 

V §98.226(m)(6) Number of test runs during 

performance test each train. 

V-1 Provides data described in section 2.3 in 

Part Two of this memorandum that could 

be used to calculate the production rate of 

nitric acid if all of the following data are 

also known: EFs (as required to be 

reported in 40 CFR 98.226(m)(1)), N2O 

concentration per test run during 

performance test (as required to be 

reported in 40 CFR 98.226(m)(4)), and 

volumetric flow rate per test run during 

performance test (as required to be 

reported in 40 CFR 98.226(m)(5). 

However, if the EFs were not reported, 

would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. 

V §98.226(p) Fraction control factor for each 

abatement technology (percent of 

total emissions from the 

production unit that are sent to the 

abatement technology) if equation 

V-3c is used. 

V-3c Provides data described in section 2.3 in 

Part Two of this memorandum that could 

be used to calculate the production rate of 

nitric acid if all of the following data are 

also known: annual N2O mass emissions 

from adipic acid production (as currently 

reported under 40 CFR 98.3(c)(4) and 

made publicly available) 5, EFs (as 

required to be reported in 40 CFR 

98.226(m)(1)), destruction efficiency (as 

required to be reported in 40 CFR 

98.226(i)), and the abatement utilization 

factor (as required to be reported in 40 

CFR 98.226(j)). However, if the EFs were 

not reported, would not reveal any 

proprietary information about facility or 

process performance, design, and 

operation; cost to do business; raw 

material usage; or production. 

X §98.246(a)(4) Indicate whether you used the 

alternative to sampling and 

analysis. 

X-1 Provides data related to production/raw 

materials, process design; process 

performance, and operation; and/or cost to 

do business, as described in sections 2.1 

and 2.2 of Part Two of this memorandum. 

Specifically, indicates whether the 

concentration of a specific compound in a 

feedstock, byproduct, or product of a 

petrochemical process is greater than 

99.5%. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

88

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

X §98.246(a)(4) Monthly volume values (used in 

Equations X-1 to X-3) - Volume of 

gaseous feedstock I introduced in 

month "n" ((Fgf)n).

X-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

X §98.246(a)(4) Monthly volume values (used in 

Equations X-1 to X-3) - Volume of 

gaseous product i produced in 

month "n" ((Pgf)n)

X-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

X §98.246(a)(4) Monthly carbon content values 

(used in Equations X-1 to X-3) - 

Average carbon content of the 

gaseous feedstock I for month "n" 

((CCgf)n). 

X-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

X §98.246(a)(4) Monthly carbon content values 

(used in Equations X-1 to X-3) - 

Average carbon content of the 

gaseous product i for month "n" 

((CCgp)n). 

X-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

X §98.246(a)(4) Molecular weights for gaseous 

feedstocks (used in Equation X-1). 

X-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

X §98.246(a)(4) Molecular weights for gaseous 

products (used in Equation X-1). 

X-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

X §98.246(a)(4) Indicate whether you used the 

alternative to sampling and 

analysis. 

X-2 Provides data related to production/raw 

materials, process design; process 

performance, and operation; and/or cost to 

do business, as described in sections 2.1 

and 2.2 of Part Two of this memorandum. 

Specifically, indicates whether the 

concentration of a specific compound in a 

feedstock, byproduct, or product of a 

petrochemical process is greater than 

99.5%. 

X §98.246(a)(4) Monthly volume values (used in 

Equations X-1 to X-3) - Volume of 

liquid feedstock i for month "n" 

((Flf)n ). 

X-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

X §98.246(a)(4) Monthly volume values (used in 

Equations X-1 to X-3) - Volume of 

liquid product i for month "n" 

((Plp)n ) . 

X-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

X §98.246(a)(4) Monthly mass values (used in 

Equations X-1 to X-3) - Mass of 

liquid feedstock i for month "n" 

((Flf)n ). 

X-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

X §98.246(a)(4) Monthly mass values (used in 

Equations X-1 to X-3) - Mass of 

liquid product i for month "n" 

((Plp)n ). 

X-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

89

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

X §98.246(a)(4) Monthly carbon content values 

(used in Equations X-1 to X-3) - 

Average carbon content of the 

liquid feedstock i for month "n" 

((CClf)n). 

X-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

X §98.246(a)(4) Monthly carbon content values 

(used in Equations X-1 to X-3) - 

Average carbon content of the 

liquid product i for month "n" 

((CClp)n). 

X-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

X §98.246(a)(4) Indicate whether you used the 

alternative to sampling and 

analysis. 

X-3 Provides data related to production/raw 

materials, process design; process 

performance, and operation; and/or cost to 

do business, as described in sections 2.1 

and 2.2 of Part Two of this memorandum. 

Specifically, indicates whether the 

concentration of a specific compound in a 

feedstock, byproduct, or product of a 

petrochemical process is greater than 

99.5%. 

X §98.246(a)(4) Monthly mass values (used in 

Equations X-1 to X-3) - Mass of 

solid feedstock I for month "n" 

((Fsf)n). 

X-3 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

X §98.246(a)(4) Monthly mass values (used in 

Equations X-1 to X-3) - Mass of 

solid product i for month "n" 

((Psp)n). 

X-3 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

X §98.246(a)(4) Monthly carbon content values 

(used in Equations X-1 to X-3) - 

Average carbon content of the 

solid feedstock i for month "n" 

((CClf)n). 

X-3 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

X §98.246(a)(4) Monthly carbon content values 

(used in Equations X-1 to X-3) - 

Average carbon content of the 

solid product i for month "n" 

((CClp)n). 

X-3 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

X §98.246(b)(5)(iii) Quantity of each type of fuel used 

in equation C-8 in §98.33(c) for 

each stationary combustion unit or 

group of units (as applicable) 

during the reporting year, 

expressed in short tons for solid 

fuels, gallons for liquid fuels, and 

scf for gaseous fuels. 

C-8 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

X §98.246(b)(5)(iv) The HHV (either default or annual 

average from measured data) used 

in equation C-8 in §98.33(C) for 

each stationary combustion unit or 

group of units (as applicable). 

C-8 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

90

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

Y §98.256(e)(6) If using Equation Y-1a: report the 

molar volume conversion factor (in 

scf/g-mole) for each flare. 

Y-1a Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Is a constant value widely 

known within the industry and publicly 

available. 

Y §98.256(e)(7) If using Equation Y-1b: report 

molar volume conversion factor 

for each flare. 

Y-1b Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Is a constant value widely 

known within the industry and publicly 

available. 

Y §98.256(e)(7)(ii) If using Equation Y-1b: report the 

carbon mole number of each 

carbon containing compound other 

than CO2 in the flare gas stream for 

each flare. 

Y-1b Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Y §98.256(e)(9) Annual volume of flare gas 

combusted during normal 

operations. 

Y-3 Provides data described in section 2.3 in 

Part Two of this memorandum that could 

be used to calculate the volume of gas 

flared during an SSM event if the 

following additional data are also known: 

the higher heating value, molecular 

weight, and carbon content of the flare gas 

(all required to be reported under 40 CFR 

98.256(e)(9)). This information could 

reveal information on the performance and 

operation of process units. 

Y §98.256(e)(9) Annual average higher heating 

value of the flare gas (normal). 

Y-3 Provides data described in section 2.3 in 

Part Two of this memorandum that could 

be used to calculate the amount of gas 

flared during an SSM event if the 

following additional data are also known: 

the volume of gas flared during normal 

operations, carbon content, and molecular 

weight of the flare gas (all required to be 

reported under 40 CFR 98.256(e)(9)). This 

information could reveal information on 

the performance and operation of process 

units. 

Y §98.256(e)(9) Volume of gas flared during SSM 

event. 

Y-3 Provides data related to process design; 

process performance, and operation; 

and/or cost to do business, as described in 

section 2.2 of Part Two of this 

memorandum. Specifically, reveals 

information about amount of waste gas 

sent to the flare for combustion during an 

SSM event, which could reveal 

information on the performance and 

operation of process units. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

91

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

Y §98.256(e)(9) Average molecular weight (SSM). Y-3 Provides data described in section 2.3 in 

Part Two of this memorandum that could 

be used to calculate the amount of gas 

flared during an SSM event if the 

following additional data are also known: 

the volume of gas flared during normal 

operations, the higher heating value, and 

the carbon content of the flare gas (all 

required to be reported under 40 CFR 

98.256(e)(9)). 

Y §98.256(e)(9) Carbon content of the flare gas 

(SSM). 

Y-3 Provides data described in section 2.3 in 

Part Two of this memorandum that could 

be used to calculate the volume of gas 

flared during an SSM event if the 

following additional data are also known: 

the amount of gas flared during normal 

operations, the higher heating value, and 

the molecular weight of the flare gas (all 

required to be reported under 40 CFR 

98.256(e)(9)). 

Y §98.256(e)(9) If using Equation Y-3: report the 

molar volume conversion factor 

for each flare. 

Y-3 Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Is a constant value widely 

known within the industry and publicly 

available. 

Y §98.256(e)(10) Fraction of carbon in the flare gas 

contributed by methane (used in 

Equation Y-4). 

Y-4 Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Is a default value provided in 

40 CFR 98.256(b)(2), a measured value, or 

an engineering estimate. 

Y §98.256(f)(7) If using Equation Y-6: report the 

molar volume conversion factor. 

Y-6 Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Is a constant value widely 

known within the industry and publicly 

available. 

Y §98.256(f)(10) Coke burn-off factor. Y-8 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the annual production 

from catalytic cracking unit regenerators 

and fluid coking units if CO2 mass 

emissions (as currently required to be 

reported under 40 CFR 98.252(b) and 

made publicly avaiable)5

, are also known. 

Y §98.256(f)(10) Annual throughput of unit. Y-8 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

92

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

Y §98.256(f)(10) Average carbon content of coke. Y-8 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Y §98.256(f)(11) If you use a unit-specific emission 

factor for CH4: report the unitspecific emission factor for CH4 

each catalytic cracking units, 

traditional fluid coking units, and 

catalytic reforming units. 

Used in method 

specified in 

§98.253(c)(4) 

Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate either production or 

raw material consumption (depending on 

whether the facility uses an emission factor 

based on production throughput or raw 

material consumption) if the N2O 

emissions (as currently required to be 

reported under 40 CFR 98.252(e) and 

made publicly avaiable)5 are also known. 

Y §98.256(f)(11) Units of measure for the unitspecific CH4 emission factor. 

Used in method 

specified in 

§98.253(c)(4) 

Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Provides only the units of 

measure for the emission factor. 

Y §98.256(f)(11) Activity data for calculating 

emissions (input). 

Used in method 

specified in 

§98.255(c)(4) 

Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Y §98.256(f)(11) Activity data for calculating 

emissions (product). 

Used in method 

specified in 

§98.255(c)(4) 

Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Y §98.256(f)(12) Activity data for calculating 

emissions (input). 

Used in method 

specified in 

§98.255(c)(5) 

Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Y §98.256(f)(12) Activity data for calculating 

emissions (production). 

Used in method 

specified in 

§98.255(c)(5) 

Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Y §98.256(f)(12) If a unit-specific emission factor 

for N2O was used: report the unitspecific emission factor for N2O 

each catalytic cracking units, 

traditional fluid coking units, and 

catalytic reforming units. 

Used in method 

specified in 

§98.253(c)(5) 

Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate either production or 

raw material consumption (depending on 

whether the facility uses an emission factor 

based on production throughput or raw 

material consumption) if the N2O 

emissions (as currently required to be 

reported under 40 CFR §98.252(e) and 

made publicly avaiable)5

 are also known. 

Y §98.256(f)(12) Units of measure for the unitspecific N2O emission factor. 

Used in method 

specified in 

9§8.253(c)(5) 

Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Provides only the units of 

measure for the emission factor. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

93

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

Y §98.256(f)(13) Average carbon content of coke. Y-11 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Y §98.256(h)(4) If Equation Y-12 is used: report 

the molar volume conversion 

factor. 

Y-12 Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Is a constant value widely 

known within the industry and publicly 

available. 

Y §98.256(h)(4) If Equation Y-12 is used: Annual 

volumetric flow to the sulfur 

recovery plant. 

Y-12 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Y §98.256(h)(4) If Equation Y-12 is used: Annual 

average mole fraction of carbon in 

the sour gas. 

Y-12 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Y §98.256(h)(5) Annual volume of recycled tail gas 

(if used to calculate recycling 

correction factor). 

Used in method 

specified in 

§98.253(h)3) 

Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Y §98.256(h)(5) Annual average mole fraction of 

carbon in the tail gas (if used to 

calculate recycling correction 

factor). 

Used in method 

specified in 

§98.253(h)3) 

Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Y §98.256(h)(5) Value of the correction. Used in method 

specified in 

§98.253(h)3) 

Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Provides only information 

about quantity of carbon in tail gas 

recycled to the sulfur recovery plant. 

Y §98.256(i)(5) If you use Eq. Y-13, report the 

annual mass of green coke fed to 

the for each coke calcining unit 

Y-13 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Y §98.256(i)(5) If you use Eq. Y-13, report the 

carbon content of green coke fed to 

the for each coke calcining unit. 

Y-13 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Y §98.256(i)(5) If you use Eq. Y-13, report the 

annual mass of marketable coke 

produced for each coke calcining 

unit. 

Y-13 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Y §98.256(i)(5) If you use Eq. Y-13, report the 

carbon content of marketable coke 

produced for each coke calcining 

unit. 

Y-13 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Y §98.256(i)(5) If Equation Y-13 used for coke 

calcining units: report the annual 

mass of coke dust removed from 

the process through collected in 

dust collection systems. 

Y-13 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

94

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

Y §98.256(i)(7) For coke calcining: Activity data 

for calculating emissions (input 

data). 

Used in method 

specified in 

§98.253(c)(4) 

Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Y §98.256(i)(7) For coke calcining: Activity data 

for calculating emissions 

(production data). 

Used in method 

specified in 

§98.253(c)(4) 

Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Y §98.256(i)(7) For coke calcining: The unitspecific CH4 emission factor. 

Used in method 

specified in 

§98.253(c)(4) 

Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate either production or 

raw material consumption (depending on 

whether the facility uses an emission factor 

based on production throughput or raw 

material consumption) if the CH4

emissions (as currently required to be 

reported under 40 CFR 98.252(e) and 

made publicly avaiable)5 are also known. 

Y §98.256(i)(7) For coke calcining: Units of 

measure for the unit-specific CH4

emission factor. 

Used in method 

specified in 

§98.253(c)(4) 

Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Provides only the units of 

measure for the emission factor. 

Y §98.256(i)(8) For coke calcining: If a unit 

specific emission factor was used 

for the N2O factor: report the 

activity data used for calculating 

emissions. 

Used in method 

specified in 

§98.253(c)(5) 

Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Y §98.256(i)(8) For coke calcining: If a unitspecific emission factor for N2O 

was used, report the site-specific 

emission factor. 

Used in method 

specified in 

§98.253(c)(5) 

Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate either production or 

raw material consumption (depending on 

whether the facility uses an emission factor 

based on production throughput or raw 

material consumption) if the N2O 

emissions (as currently required to be 

reported under 40 CFR 98.252(e) and 

made publicly avaiable)5 are also known. 

Y §98.256(i)(8) For coke calcining: If a unit 

specific emission factor was used 

for the N2O factor: report the units 

of measure for the unit-specific 

factor . 

Used in method 

specified in 

§98.253(c)(5) 

Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Provides only the units of 

measure for the emission factor. 

Y §98.256(j)(2) Quantity of asphalt blown for each 

for each asphalt blowing unit. 

Y-14 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Y §98.256(j)(2) Quantity of asphalt blown for each 

for each asphalt blowing unit. 

Y-15 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

95

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

Y §98.256(j)(2) Quantity of asphalt blown for each 

for each asphalt blowing unit. 

Y-16a Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Y §98.256(j)(2) Quantity of asphalt blown for each 

for each asphalt blowing unit. 

Y-16b Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Y §98.256(j)(2) Quantity of asphalt blown for each 

for each asphalt blowing unit. 

Y-17 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Y §98.256(j)(5) CO2 emission factor for each 

asphalt blowing unit. 

Y-14 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the annual asphalt 

production if the CO2 emissions (as 

currently required to be reported under 40 

CFR 98.252(f) and made publicly 

avaiable)5 are also known. 

Y §98.256(j)(6) CH4 emission factor for each 

asphalt blowing unit. 

Y-15 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the annual asphalt 

production if the CH4 emissions (as 

currently required to be reported under 40 

CFR 98.252(f) and made publicly 

avaiable)5

 are also known. 

Y §98.256(j)(7) If Equation Y-16 is used: report 

the carbon emission factor. 

Y-16a Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the annual asphalt 

production if the CO2 emissions (as 

currently required to be reported under 40 

CFR 98.252(f) and made publicly 

avaiable)5

 are also known. 

Y §98.256(j)(8) If Equation Y-16b is used: report 

the CO2 emission factor used. 

Y-16b Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the annual asphalt 

production if both the CO2 emissions (as 

currently required to be reported under 40 

CFR 98.252(f) and made publicly 

avaiable)5

and the carbon emission factor 

“CEFAB” (required to be reported under 40 

CFR 98.256(j)(8)) are also known. 

Y §98.256(j)(8) If Equation Y-16b is used: report 

the carbon emission factor. 

Y-16b Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the annual asphalt 

production if both the CO2 emissions (as 

currently required to be reported under 40 

CFR 98.252(f) and made publicly 

avaiable)5

and the CO2 emission factor 

“EFAB,CO2” (required to be reported under 

40 CFR 98.256(j)(8)) are also known. 

Additionally, if the uncontrolled emissions 

represented by the CO2 emisison factor 

“EFAB,CO2” are very low, could estimate 

annual asphalt production if only this 

carbon factor and the CO2 emisisons are 

known. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

96

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

Y §98.256(j)(9) If you use Eq. Y-17: CH4 emission 

factor. 

Y-17 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the annual asphalt 

production if the CO2 emissions (as 

currently required to be reported under 40 

CFR 98.252(f) and made publicly 

avaiable)5 are also known. 

Y §98.256(k)(3) For delayed coking units: 

Dimensions of coke drum or 

vessel. 

Y-18 Provides data related to process design; 

process performance, and operation; 

and/or cost to do business, as described in 

section 2.2 of Part Two of this 

memorandum. Specifically, could reveal 

information about the design and operation 

of the coking unit. 

Y §98.256(k)(3) For delayed coking units: Typical 

gauge pressure of the coking drum 

when first vented to the 

atmosphere. 

Y-18 Provides data related to process design; 

process performance, and operation; 

and/or cost to do business, as described in 

section 2.2 of Part Two of this 

memorandum. Specifically, could reveal 

information about the design and operation 

of the coking unit. 

Y §98.256(k)(3) For delayed coking units: Typical 

void fraction of coke drum or 

vessel. 

Y-18 Provides data related to process design; 

process performance, and operation; 

and/or cost to do business, as described in 

section 2.2 of Part Two of this 

memorandum. Specifically, could reveal 

information about the design and operation 

of the coking unit. 

Y §98.256(k)(3) For delayed coking units: Annual 

number of coke-cutting cycles of 

coke drum or vessel. 

Y-18 Provides data related to process design; 

process performance, and operation; 

and/or cost to do business, as described in 

section 2.2 of Part Two of this 

memorandum. Specifically, could reveal 

information about the design and operation 

of the coking unit. 

Y §98.256(k)(3) For delayed coking units: report 

the molar volume conversion 

factor for each coke drum or 

vessel. 

Y-18 Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Is a constant value widely 

known within the industry and publicly 

available. 

Y §98.256(k)(4) For delayed coking units: Height 

and diameter of the coke drums. 

Y-18 Provides data related to process design; 

process performance, and operation; 

and/or cost to do business, as described in 

section 2.2 of Part Two of this 

memorandum. Specifically, could reveal 

information about the design and operation 

of the coking unit. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

97

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

Y §98.256(k)(4) For delayed coking units: 

Cumulative number of vessel 

openings for all delayed coking 

drums in the set. 

Y-18 Provides data related to process design; 

process performance, and operation; 

and/or cost to do business, as described in 

section 2.2 of Part Two of this 

memorandum. Specifically, could reveal 

information about the design and operation 

of the coking unit. 

Y §98.256(k)(4) For delayed coking units: Typical 

venting pressure. 

Y-18 Provides data related to process design; 

process performance, and operation; 

and/or cost to do business, as described in 

section 2.2 of Part Two of this 

memorandum. Specifically, could reveal 

information about the design and operation 

of the coking unit. 

Y §98.256(k)(4) For delayed coking units: Void 

fraction. 

Y-18 Provides data related to process design; 

process performance, and operation; 

and/or cost to do business, as described in 

section 2.2 of Part Two of this 

memorandum. Specifically, could reveal 

information about the design and operation 

of the coking unit. 

Y §98.256(k)(4) For delayed coking units: Mole 

fraction of methane in coking gas. 

Y-18 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate various other data 

related to process design and operation of 

the cokling units (e.g., typical void fraction 

of the coke drum, height and diameter of 

the coke vessel). For examples this data 

element could be used to calculate typical 

void fraction of the coke vessel if the 

following data are also known: CH4 

emissions (as currently required to be 

reported under 40 CFR 98.252(f) and 

made publicly avaiable)5

, cumulative 

number of vessel openings for all delayed 

coking drums in the set (as required to be 

reported in 40 CFR 98.256(k)(4), height 

and diameter of the coking vessel (as 

required to be reported in 40 CFR 

98.256(k)(4), typical venting pressure (as 

required to be reported in 40 CFR 

98.256(k)(4), and the void fraction (as 

required to be reported in 40 CFR 

98.256(k)(4). However, if the cumulative 

number of vessel openings for all delayed 

coking drums in the set were not reported, 

would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. 

Y §98.256(l)(5) For each process vent: Molar 

volume conversion factor. 

Y-19 Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Is a constant value widely 

known within the industry and publicly 

available. 
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98

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

Y §98.256(m)(3) Uncontrolled blowdown systems 

reporting under §98.253 (k): CH4

emission factor used. 

Y-20 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the quantity of crude 

oil and intermediate products received 

from offsite if the CO2 emissions (as 

currently required to be reported under 40 

CFR 98.252(g) and made publicly 

avaiable)5 are also known. 

Y §98.256(m)(3) Uncontrolled blowdown systems 

reporting under §98.253 (k): Molar 

volume conversion factor. 

Y-20 Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Is a constant value widely 

known within the industry and publicly 

available. 

Y §98.256(m)(3) Uncontrolled blowdown systems 

reporting under §98.253 (k): Total 

quantity of crude oil plus the 

quantity of intermediate products 

received from off-site that are 

processed at the facility in the 

reporting year. 

Y-20 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Y §98.256(n)(3) For equipment leaks: Number of 

each type of emission source listed 

in Equation Y-21 (if using Eq. Y21). 

Y-21 Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. These data (e.g., types of units, 

number of units) are already generally 

publicly available in permits and permit 

applications, such that these reported data 

would not reveal any additional 

information. 

Y §98.256(o)(2)(ii) Total quantity of crude oil plus the 

quantity of intermediate products 

received from off-site that are 

processed at the facility in the 

reporting year. 

Y-22 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Y §98.256(o)(4)(ii) For storage tanks that process 

unstabilized crude oil: Quantity of 

unstabilized crude oil received 

during the calendar year. 

Y-23 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
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99

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

Y §98.256(o)(4)(iii) For storage tanks that process 

unstabilized crude oil: Average 

pressure differential. 

Y-23 Provides data related to process design; 

process performance, and operation; 

and/or cost to do business, as described in 

section 2.2 of Part Two of this 

memorandum. Specifically, could reveal 

the type of crude oil processed, which can 

provide information regarding the 

production process and business costs. 

Additionally, provides data described in 

section 2.3 of Part Two of this 

memorandum that could be used to 

calculate the quantity of unstabilized crude 

oil received if both the average mole 

fraction of CH4 in the vent gas (required to 

be reported under 40 CFR 98.252(g)) and 

the tank-specific methane composition 

data (required to be reported under 40 CFR 

98.256(o)(4)(v)) are also known. 

Y §98.256(o)(4)(iv) For storage tanks that process 

unstabilized crude oil: Molar 

volume conversion factor.. 

Y-23 Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Is a constant value widely 

known within the industry and publicly 

available. 

Y §98.256(o)(4)(v) For storage tanks that process 

unstabilized crude oil: Average 

Mole fraction of CH4 in vent gas 

from the unstabilized crude oil 

storage tanks. 

Y-23 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Y §98.256(o)(4)(vi) If you did not use Equation Y-23: 

report the gas generation rate data 

used to estimate cumulative CH4 

emissions for storage tanks used to 

process unstabilized crude oil.. 

Used in methods 

specified in 

§98.253(m)(2) 

If reported in pounds per unit of time (e.g., 

lbs/hour), provides data described in 

section 2.3 of Part Two of this 

memorandum that could be used to 

calculate unstabilized crude received at 

facility if CH4 emissions (as currently 

required to be reported under 40 CFR 

98.256(o)(3) and made publicly avaiable)5

and methane composition data (required to 

be reported under 40 CFR 

98.256(o)(4)(vi)) are also known and the 

gas generation rate is reported in lbs/barrel 

of unstabilized crude. 3

 

Y §98.256(o)(4)(vi) If you did not use Equation Y-23: 

report the tank-specific methane 

composition data used to estimate 

cumulative CH4 emissions for 

storage tanks used to process 

unstabilized crude oil. 

Used in methods 

specified in 

§98.253(m)(2) 

Provides data described in section 2.3 of 

Part Two of this memorandum that 

provides the proportion of methane in gas 

exhausted from the storage tanks, which 

could be used to estimate unstabilized 

crude received at facility only if both CH4

emissions (as currently required to be 

reported under 40 CFR 98.256(o)(3) and 

made publicly avaiable)5

 and gas 

generation reported in pounds of gas per 

barrel of unstabilized crude oil (required to 

be reported under 40 CFR 

98.256(o)(4)(vi)) are also known.3

 

Y §98.256(o)(6) Mole fraction of CH4 in vent gas 

from the unstabilized crude oil 

storage tank. 

Y-23 See analysis for 40 CFR 98.256(o)(4)(v).4

 
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100

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

Y §98.256(o)(6) Average pressure differential. Y-23 See analysis for 40 CFR 

98.256(o)(4)(iii).4

 

Y §98.256(o)(6) Quantity of unstabilized crude oil 

received during the calendar year. 

Y-23 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Y §98.256(o)(7) Tank-specific methane 

composition data. 

Used in methods 

specified in 

§98.253(m)(2) 

See analysis for 40 CFR 98.256(o)(4)(vi).4 

Y §98.256(o)(7) Gas generation rate data. Used in methods 

specified in 

§98.253(m)(2) 

 See analysis for 40 CFR 

98.256(o)(4)(vi).4

 

Y §98.256(p)(2) For loading operations: Quantity of 

materials loaded by vessel type 

that have an equilibrium vaporphase concentration of CH4 of 0.5 

volume percent or greater. 

Used in methods 

specified in AP42, Section 5.2 

(referenced by 

§98.253(n)) 

Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Z §98.266(f)(5) Monthly inorganic carbon content 

of phosphate rock for each wetprocess phosphoric acid process 

line for which Equation Z-1a is 

used (percent by weight, expressed 

as decimal fraction) (No CEMS). 

Z-1a Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Z §98.266(f)(5) Monthly CO2 (ton CO2/ton of 

phosphate rock) for which 

Equation Z-1b is used (No CEMS). 

Z-1b Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the amount of 

phosphate rock consumed if the N2O 

emissions (as currently reported under 40 

CFR 98.3(c)(4) and made publicly 

available) 5 are also known. 

Z §98.266(f)(6) Monthly mass of phosphate rock 

consumed by origin in production. 

Z-1a Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

Z §98.266(f)(6) Monthly mass of phosphate rock 

consumed by origin in production. 

Z-1b Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

AA §98.276(b) Annual quantities of fossil fuels 

used in chemical recovery 

furnaces. 

C-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

AA §98.276(b) Annual quantities of fossil fuels 

used in chemical recovery 

furnaces. 

C-1a Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

AA §98.276(b) Annual quantities of fossil fuels 

used in chemical recovery 

furnaces. 

C-1b Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

101

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

AA §98.276(b) Annual quantities of fossil fuels 

used in chemical recovery 

furnaces. 

C-2a Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

AA §98.276(b) Annual quantities of fossil fuels 

used in chemical recovery 

furnaces. 

C-3 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

AA §98.276(b) Annual quantities of fossil fuels 

used in chemical recovery 

combustion units. 

C-4 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

AA §98.276(b) Annual quantities of fossil fuels 

used in chemical recovery 

combustion units. 

C-5 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

AA §98.276(b) Annual quantities of fossil fuels 

used in chemical recovery 

combustion units. 

C-8 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

AA §98.276(b) Annual quantities of fossil fuels 

used in chemical recovery 

combustion units. 

C-8a Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

AA §98.276(b) Annual quantities of fossil fuels 

used in chemical recovery 

combustion units. 

C-8b Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

AA §98.276(b) Annual quantities of fossil fuels 

used in chemical recovery 

combustion units. 

C-9a Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

AA §98.276(c) Annual mass of the spent liquor 

solids combusted. 

AA-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

AA §98.276(c) Annual mass of the spent liquor 

solids combusted. 

AA-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

AA §98.276(d) High heat value (HHV) of the 

spent liquor solids used in 

Equation AA-1. 

AA-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

AA §98.276(e) Default or site specific emission 

factor for CO2 used in equation 

AA-1. 

AA-1 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the mass of spent 

liquor solids combusted if the following 

data are also known: CO2 emissions (as 

currently reported under 40 CFR 

98.3(c)(4) and made publicly available) 5 

and HHV (as required to be reported in 40 

CFR 98.276(d). However, if the HHV 

were not reported, would not reveal any 

proprietary information about facility or 

process performance, design, and 

operation; cost to do business; raw 

material usage; or production. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review

102

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

AA §98.276(e) Default or site specific emission 

factor for CH4 used in equation 

AA-1. 

AA-1 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the mass of spent 

liquor solids combusted if the following 

data are also known: CH4 emissions (as 

currently reported under 40 CFR 

98.3(c)(4) and made publicly available) 5 

and HHV (as required to be reported in 40 

CFR 98.276(d). However, if the HHV 

were not reported, would not reveal any 

proprietary information about facility or 

process performance, design, and 

operation; cost to do business; raw 

material usage; or production. 

AA §98.276(e) Default or site specific emission 

factor for N2O used in equation 

AA-1. 

AA-1 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to calculate the mass of spent 

liquor solids combusted if the following 

data are also known: N2O emissions (as 

currently reported under 40 CFR 

98.3(c)(4) and made publicly available) 5 

and HHV (as required to be reported in 40 

CFR 98.276(d). However, if the HHV 

were not reported, would not reveal any 

proprietary information about facility or 

process performance, design, and 

operation; cost to do business; raw 

material usage; or production. 

AA §98.276(f) Carbon content of the spent liquor 

solids used in Equation AA-2. 

AA-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

AA §98.276(g) Annual quantities of fossil fuels 

used in pulp mill lime kilns. 

C-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

AA §98.276(g) Annual quantities of fossil fuels 

used in pulp mill lime kilns. 

C-1a Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

AA §98.276(g) Annual quantities of fossil fuels 

used in pulp mill lime kilns. 

C-1b Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

AA §98.276(g) Annual quantities of fossil fuels 

used in pulp mill lime kilns. 

C-2a Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

AA §98.276(g) Annual quantities of fossil fuels 

used in pulp mill lime kilns. 

C-3 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

AA §98.276(g) Annual quantities of fossil fuels 

used in pulp mill lime kilns. 

C-4 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

AA §98.276(g) Annual quantities of fossil fuels 

used in pulp mill lime kilns. 

C-5 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

AA §98.276(g) Annual quantities of fossil fuels 

used in pulp mill lime kilns. 

C-8 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
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103

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

AA §98.276(g) Annual quantities of fossil fuels 

used in pulp mill lime kilns. 

C-8a Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

AA §98.276(g) Annual quantities of fossil fuels 

used in pulp mill lime kilns. 

C-8b Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

AA §98.276(g) Annual quantities of fossil fuels 

used in pulp mill lime kilns. 

C-9a Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

AA §98.276(h) Make-up quantity of CaCO3 used 

for the reporting year used in 

Equation AA-3. 

AA-3 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

AA §98.276(i) Make-up quantity of Na2CO3 used 

for the reporting year used in 

Equation AA-3. 

AA-3 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

BB §98.286(b)(1) Monthly consumption of 

petroleum coke (No CEMS). 

BB-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

BB §98.286(b)(4) Carbon content factor of petroleum 

coke from the supplier or as 

measured by the applicable 

method. 

BB-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

BB §98.286(b)(6) CO2 emissions factor for each 

month. 

BB-2 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to estimate the amount of 

petroleum coke consumed if the CO2

emissions (as currently reported under 40 

CFR 98.3(c)(4) and made publicly 

available) 5 are also known. 

CC §98.296(b)(5) Monthly consumption of trona or 

liquid alkaline feedstock for each 

manufacturing line (No CEMS) 

(for facilities using Equation CC1). 

CC-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

CC §98.296(b)(6) Monthly production of soda ash for 

each manufacturing line (tons) (for 

facilities using Equation CC-2). 

CC-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

CC §98.296(b)(7) Inorganic carbon content factor of 

soda ash. 

CC-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

CC §98.296(b)(7) Inorganic carbon content factor of 

trona . 

CC-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

CC §98.296(b)(10)(i) Stack gas volumetric flow rate 

during performance test (dscfm) 

for each manufacturing line or 

stack. 

CC-3 Provides information about the exhaust gas 

flow rate during the performance test and 

would not reveal any proprietary 

infomation about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. 
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104

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

CC §98.296(b)(10)(ii) Hourly CO2 concentration during 

performance test (percent CO2) for 

each manufacturing line or stack. 

CC-3 Provides information about the CO2

concentration in exhaust gas stream 

measured during the performance test and 

§98.would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. 

CC §98.296(b)(10)(iii) CO2 emission factor of process 

vent flow from mine water for 

each manufacturing line or stack. 

CC-5 Does not include, and could not be used to 

calculate, data or information (about 

facility or process performance, design, 

and operation; cost to do business; raw 

material usage; or production) that would 

reveal information that could cause 

competitive harm. 

CC §98.296(b)(10)(iv) CO2 emission mass emission rate 

during performance test (metric 

tons/hour) for each manufacturing 

line or stack. 

CC-4 Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Data cannot be used to 

calculate the annual production or raw 

material consumption since the production 

and raw material usage during the 

performance test is not reported. 

CC §98.296(b)(10)(v) Average process vent flow from 

mine water stripper/evaporator 

during performance test for each 

manufacturing line or stack. 

CC-4 Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Data cannot be used to 

calculate annual production or raw 

material consumption since the production 

rate and raw material consumption during 

the performance test is not reported. 

CC §98.296(b)(10)(vi) Annual process vent flow rate from 

mine stripper/evaporator for each 

manufacturing line or stack. 

CC-5 Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. Could be used to calculate 

hours of operation if the average process 

vent flow rate measured during the 

performance test (reported under 40 CFR 

296(b)(10)(v)) is known; however, hours 

of operation cannot be used to calculate 

production since the production rate during 

the performance test is not reported. 

EE §98.316(b)(6) Monthly calcined petroleum coke 

consumption for each production 

line (No CEMS). 

EE-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

EE §98.316(b)(9) Monthly carbon content factor of 

petroleum coke (percent by weight 

expressed as a decimal fraction) 

(No CEMS). 

EE-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
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105

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

GG §98.336(b)(6) Annual mass of each carboncontaining input material charged 

to each kiln or furnace (No CEMS) 

- Mass of zinc bearing material. 

GG-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

GG §98.336(b)(6) Annual mass of each carboncontaining input material charged 

to each kiln or furnace (No CEMS) 

- Annual mass of flux materials 

(e.g., limestone, dolomite) charged 

to kiln or furnace “k” (tons). 

GG-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

GG §98.336(b)(6) Annual mass of each carboncontaining input material charged 

to each kiln or furnace (No CEMS) 

- Annual mass of carbon electrode 

consumed in furnace “k”. 

GG-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

GG §98.336(b)(6) Annual mass of each carboncontaining input material charged 

to each kiln or furnace (No CEMS) 

- Annual mass of other 

carbonaceous material consumed 

in furnace “k”. 

GG-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

GG §98.336(b)(7) Carbon content of carboncontaining input materials charged 

to kilns or furnace (including zinc 

bearing material, flux materials, 

and other carbonaceous materials) 

from the annual carbon analysis or 

from information provided by the 

material supplier) for each kiln or 

furnace (percent by weight, 

expressed as a decimal fraction) 

(No CEMS) - zinc bearing 

material. 

GG-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

GG §98.336(b)(7) Carbon content of carboncontaining input materials charged 

to kilns or furnace (including zinc 

bearing material, flux materials, 

and other carbonaceous materials) 

from the annual carbon analysis or 

from information provided by the 

material supplier) for each kiln or 

furnace (percent by weight, 

expressed as a decimal fraction) 

(No CEMS) - flux materials. 

GG-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

GG §98.336(b)(7) Carbon content of carboncontaining input materials charged 

to kilns or furnace (including zinc 

bearing material, flux materials, 

and other carbonaceous materials) 

from the annual carbon analysis or 

from information provided by the 

material supplier) for each kiln or 

furnace (percent by weight, 

expressed as a decimal fraction) 

(No CEMS) - other carbonaceous 

materials. 

GG-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 
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106

Subpart 

Rule Citation in 

40 CFR Part 98 Data Element Description 

Data Element is 

used as Input to 

Equation . . . Analysis Results 

GG §98.296(b)(10) Carbon content of the carbon 

electrodes used in each furnace 

from the annual carbon analysis or 

from information provided by the 

material supplier) (percent by 

weight, expressed as a decimal 

fraction) (No CEMS). 

GG-1 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

II §98.356(d)(2) Cumulative volumetric biogas flow 

for each week that biogas is 

collected for destruction (if using 

weekly sampling). 

II-4 Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. 

II §98.356(d)(3) Weekly average CH4 

concentration for each week that 

biogas is collected for destruction 

(if using weekly sampling). 

II-4 Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. 

II §98.356(d)(4) Weekly average temperature at 

which flow is measured for biogas 

collected for destruction (if using 

weekly sampling). 

II-4 Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. 

II §98.356(d)(5) Weekly average moisture content 

for each week at which flow is 

measured for biogas collected for 

destruction (if using weekly 

sampling). 

II-4 Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. 

II §98.356(d)(6) Weekly average pressure for each 

week at which flow is measured 

for biogas collected for destruction 

(if using weekly sampling). 

II-4 Would not reveal any proprietary 

information about facility or process 

performance, design, and operation; cost to 

do business; raw material usage; or 

production. 

TT §98.466(c)(3)(i) Total number of years (N) for 

which disposal and production data 

are both available. 

TT-2 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to estimate either production 

quantities or raw material consumption if 

both the quantity of waste disposed in the 

landfill (reported under 40 CFR 

98.466(c)(3)(ii) and (d)(2)) and average 

waste disposal factor (reported under 40 

CFR 98.466(c)(3)(iii)) are also known. 

TT §98.466(c)(3)(ii) The waste disposal quantity for 

each year used in Equation TT–2 

of this subpart to calculate the 

average waste disposal factor 

(WDF). 

TT-2 Provides production or raw material data 

described in section 2.1 of Part Two of this 

memorandum. 

TT §98.466(c)(3)(iii) Average waste disposal factor 

(WDF) calculated for the waste 

stream. 

TT-3 Provides data described in section 2.3 of 

Part Two of this memorandum that could 

be used to estimate either production 

quantities or raw material consumption if 

the amount of waste disposed of in the 

landfill (reported under 40 CFR 

98.466(d)(2) is also known. 
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107

1 Combustion units connected to devices connected to the local or regional power grid include combustion units subject to subpart C of Part 98

(excludes facilities subject to subpart D of Part 98) that meet the following criteria: (1) the combustion unit is connected to a device that has

been granted access by the Public Utilities Commission to deliver power to the local or regional electric power grid (e.g., electricity generators);

and (2) the combined nameplate capacity (for all such devices at the facility) is greater than or equal to 1 megawatt electric. 2

These results are based on the existing subpart L rule (e.g., requires process‐specific, chemical specific reporting at 40 CFR 98.126(a)(2)), which

may be amended in a future separate action related to subpart L of Part 98. 3 EPA has proposed in a separate rulemaking (March 2013): (1)  to revise the provision such that annual gas generation rate be revised to be

reported in standard cubic feet per year (scf/yr) and (2) that this revised data element be assigned a CBI determination of "non‐CBI." If these

proposed changes are finalized, then the specified potential harm would no longer apply. 4 EPA has proposed in a separate rulemaking (March 2013) to remove this provision because it is redundant to a provision specified in 40 CFR

98.256(o)(4)(iii)‐(vi). If this proposed change is finalized, then the specified potential harm would no longer apply. 5 In the May 26, 2011 final CBI determination notice (76 FR 30782), EPA grouped the direct‐emitter data reporting elements into 11 data

categories and assigned CBI determinations on either a category or individual data elements basis. One of the categories established was

“Emissions,” which contains all emissions required to be reported by direct emitters under Part 98 (e.g., annual CO2e emissions, emissions by

GHG and source category, emissions by GHG pollutant). All data elements within this category were determined to be “emission data,” which

under CAA section 114(c) are not entitled to confidential treatment. As a result, data elements that have been assigned to the “Emissions”

category (refer to the final CBI rulemakings: May 26, 2011, 76 FR 30782; August 13, 2012, 77 FR 48072; August 24, 2012, 77 FR 51477) have

been made publicly available on the Greenhouse Gas Reporting Program website."
Attachment Q 
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1 

TECHNICAL MEMORANDUM 

DATE: May 2013 

TO: Docket EPA-HQ-OAR-2010-0929 

FROM: Lisa Grogan-McCulloch, U.S. EPA

SUBJECT: Evaluation of Alternative Calculation Methods 

1.0 Introduction and Purpose of Analysis 

In the August 25, 2011 final rule deferring reporting to March 31, 2015 of certain inputs 

to emission equations under 40 CFR part 98 (76 FR 53057), EPA expressed its intent to further 

evaluate the inputs to emission equations. EPA outlined a four-step process for this evaluation in 

the final rule, and in a supporting memorandum entitled “Process for Evaluating and Potentially 

Amending Part 98 Inputs to Emission Equations” (docket EPA-HQ-OAR-2010-0929). 

The purpose of this memorandum is to describe the review undertaken for the third step 

of the evaluation process: EPA’s analysis of alternative calculation methods . The analysis of 

alternative calculation methods is divided into two reviews: (1) review of alternative greenhouse 

gas (GHG) emission equations, and (2) review of application of direct measurement using 

continuous emissions monitoring systems (CEMS). The alternative calculation analysis was 

undertaken for 25 of the 28 subparts of the greenhouse gas reporting program (GHGRP), for 

which reporting of inputs to equations has been deferred to March 31, 2015 (hereafter referred to 

as “inputs to equations”). The review was not undertaken for subparts W and II because the 

EPA’s evaluation of these inputs under Step 2 did not identify the need to proceed to Step 3.a

Please see memorandum “Evaluation of Competitive Harm from Reporting “Inputs to 

Equations” Data Elements Deferred to March 31, 2015” for the results of Step 2 of the analysis. 

Section 2.0 of this memorandum presents the procedures used to collect and review 

alternative calculation equations, and the results of the review. Section 3.0 presents the 

procedures used to collect information on and evaluate application of direct measurement of 

emissions using CEMS, and summarizes the results of the evaluation. Section 4 provides a 

summary of the analysis. Appendix A presents detailed evaluations of all the alternative 

calculation equations reviewed for each subpart. Appendix B presents a detailed characterization 

of facilities and processes using CEMS for each of the subparts. Appendix C provides detailed 

cost estimates of requiring CO2 CEMS. 

2.0 Alternative Calculation Equations 

 

a

 The review was not conducted for “inputs to equations” in subpart I because reporting of the “inputs to equations” 

data elements for that subpart was addressed in a separate proposed action [see 77 FR 63538]. Additionally, the 

evaluation of the subpart C “inputs to equations” in this memorandum encompasses the one subpart A “input to 

equation” data element. As a result, the one subpart A “input to equation” data element is not listed explicitly in this 

memorandum. 
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2 

 Section 2.0 of this memorandum evaluates alternative equations to calculate GHG 

emissions. Section 2.1 discusses the procedures used to identify alternative calculation equations, 

section 2.2 discusses the data sources reviewed to obtain the alternative calculation equations, 

and section 2.3 summarizes the results of the review. 

2.1 Procedures for Identifying and Reviewing Alternative Calculation Equations 

Alternative calculation equations were identified based on three sources of information: 

(1) previous calculation equations that were evaluated during the development of the GHGRP, 

(2) calculations used in non-EPA GHG reporting programs since the GHGRP was developed, 

and (3) methods suggested by public commenters in response to the Call for Information notice 

[75 FR 81338]. Each alternative calculation was evaluated to determine if it was the same as the 

method chosen in the GHGRP. For calculations different than what is required in the GHGRP, 

the alternative calculation equations were evaluated to determine whether equation inputs are the 

same as the “inputs to equations” data elements, and therefore, would not resolve the disclosure 

concerns identified in Step 2 of the analysis. Additionally, the equations that are different were 

also evaluated as to whether they would decrease accuracy or increase uncertainty in the 

calculated emissions based on information provided in the sources reviewed. For those 

calculation equations that were identified as using inputs different than the “inputs to equations” 

data elements, and also have similar or lower uncertainty and similar or higher accuracy in 

emissions estimation than the current method, costs were estimated if sufficient cost information 

was available. The cost of the alternative was then compared to the current method. 

2.2 Data Sources Reviewed 

 As discussed in section 2.1, three sources of information were analyzed. Calculation 

equations that the EPA had previously considered but not included in the final rule were 

identified in the technical support documents (TSDs)1-25 for each of the subparts and the 

preambles to the proposed and final GHGRP. The original sources of the calculation methods 

were then reviewed to determine if the calculation methods had been updated since the 

development of the GHGRP and to obtain more detailed information. The original sources 

consisted of the following:26-42

 Annual Inventory of U.S. GHG Emissions and Sinks (U.S. Inv) 

 Climate Leaders protocols (CL) 

 U.S. Department of Energy (DOE) 1605(b) reporting program 

 The Climate Registry (TCR) 

 State programs (California Climate Action Registry (CCAR), California Air Resources 

Board (CARB) cap and trade program, New Mexico) 

 Regional Programs (Regional Greenhouse Gas Initiative [RGGI]) 

 Western Climate Initiative (WCI) 

 2006 Intergovernmental Panel on Climate Change (IPCC) Guidelines 

 European Union Emissions Trading System (EU ETS) 
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 Country-specific GHG reporting programs (Australia National Greenhouse Gas 

Reporting Program (ANGGRP), Canada) 

 World Resources Institute/World Business Council for Sustainable Development 

(WRI/WBCSD) protocols 

 American Petroleum Institute (API) protocols 

 American Iron and Steel Institute 

 European Bank For Reconstruction and Development 

Methods used in newer non-EPA GHG programs since the GHGRP was developed were 

evaluated. These include:43-44

 U.N. Framework on Climate Change - Clean Development Mechanism (CDM) 

 Australian Emissions Trading Scheme 

Lastly, the EPA’s Call for Information notice solicited input from commenters on 

alternative calculation methods. Commenters suggested alternative calculation methods for 5 

subparts: K, P, Q, R, and X.45-48

2.3 Results of Analysis 

 Table 2-1 summarizes the results of evaluating alternative calculation equations. The 

table indicates that for all of the subparts except subparts X and Y, the alternative calculation 

equations either used many of the same inputs to the calculation equations as the ”inputs to 

equations”, used new inputs that are the same type of reporting elements that the EPA 

determined have disclosure concerns49, mandated process configurations (which is not the intent 

of the GHGRP), or increased uncertainty or decreased accuracy in emission estimates. Because 

of this result, no further evaluation of costs was undertaken for these alternative calculations. For 

alternatives that were identified as viable in Subparts X and Y, further analysis indicated they 

resulted in a high cost to implement. Appendix A contains detailed evaluations for each subpart 

and for each alternative calculation method identified. 

Table 2-1. Summary of Evaluation of Alternative Calculation Equations 

Subpart 

of Part 

98 

Viable 

Alternative 

Identified 

(Y/N) 

Evaluation of Alternative Calculation Equationsa

Uses Same 

2015 

Inputs to 

Equationsb

Uses Same 

Type of 

Inputs 

that do not 

Alleviate 

Disclosure 

Concernsc

Mandate

s Process 

Designd

Increased 

Uncertainty/ 

Decreased 

Accuracy 

High Cost 

to 

Implemente

C N √ NA 

E N √ √ NA 

F N √ √ NA 

G N √ √ √ NA 

H N √ √ √ NA 
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K N √ √ NA 

L N √ √ NA 

N N √ √ NA 

O N √ √ NA 

P N √ √ NA 

Q N √ √ NA 

R N √ √ NA 

S N √ √ √ NA 

U N √ √ NA 

V N √ √ NA 

X N √ √ √ √

Y N √ √ √ √

Z N √ √ NA 

AA N √ √ NA 

BB N √ √ NA 

CC N √ NA 

EE N √ √ √ NA 

GG N √ √ √ NA 

TT N √ √ NA 

NA = Not analyzed because other criteria disqualified alternative. a

The table generally summarizes reasons why the alternative calculation methods were considered to not be viable 

options. Appendix A contains detailed evaluations for each alternative calculation method reviewed for each 

subpart. 

b

The alternative calculations used many of the same inputs to the calculation equations as the “inputs to equations” 

data elements (and therefore, provided no benefit in comparison to the current method). 

c The alternative calculations used new data elements that are the same type of reporting elements that the EPA 

determined to have disclosure concerns (see the memorandum “Evaluation of Harm from Reporting 2015 Inputs to 

Equations”). 

d

The alternative calculations mandated process configurations (which is not the intent of the GHGRP). e

Costs were only analyzed for equations that did not have data elements for which disclosure concerns were 

identified, had low uncertainty, and had high accuracy. 

3.0 Direct Emissions Monitoring Using Continuous Emissions Monitoring Systems 

Section 3.0 of this memorandum evaluates the use of CEMS for each subpart instead of 

calculation equations for GHG reporting. For the evaluation of CEMs, we initially applied the 

same criteria that were used for the Alternative Calculation Equations. Because CEMS are 

directly measuring emissions, no equation inputs are used. As a result, the use of CEMS would 

alleviate the disclosure concerns identified in Step 2 of the analysis. In addition, use of the 

CEMS does not result in increased uncertainty or decreased accuracy. However, CEMS are 

generally higher cost than the other methodologies in the GHGRP, and the majority of reporters 

that reported to the GHGRP in 2011 did not use CEMS. In addition, they cannot be used for 

fugitive emission sources that are not routed through a stack. This review characterizes the 

facilities (or process units in a facility) that currently use CO2 CEMS (or N2O or methane CEMS 

if applicable), the facilities that use another form of CEMS that may be upgraded for use in the 
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5 

GHGRP, and the cost impacts of applying the upgrades. Section 3.1 describes the evaluation 

performed, and section 3.2 summarizes the results of the review. 

3.1 Description of Evaluation Performed 

The GHGRP requires the use of a CO2 CEMS only if a facility already has CEMS for 

another regulation and meets certain additional criteria [i.e., the six conditions specified in 

subpart C 98.33(b)(4)(ii)]. Such facilities would not need to build a structure or install a 

sampling system in order to measure CO2 emissions using a CEMS. Most of the subparts with 

“inputs to equations” data elements allow CEMS as an option to determine CO2 emissions (some 

also allow N2O with approval). 

Characterization of Facilities and Process Units

The first step in the evaluation of applying GHG CEMS for each subpart was to develop 

an up-to-date characterization of the facilities and process units subject to each subpart and the 

number that use CEMS. The data reported to the EPA through annual report submissions in the 

GHGRP50 provides the most up-to-date information on facility counts, as well as actual usage of 

GHG CEMS. Many facilities also use non-GHG CEMS (that can be converted to GHG CEMS), 

which are not accounted for in the GHGRP. Therefore, for this analysis, we also used 

information in the GHGRP regulatory impacts analysis (RIA)51, the GHGRP background 

technical support documents (TSD), and information in other EPA databases (particularly 

databases used in the development of air rules and regulations, such as new source performance 

standards (NSPS) or national emission standards for hazardous air pollutants (NESHAP)), to 

obtain information on facilities and process units with non-GHG CEMS. 

Estimating Current and Potential CEMS usage 

Where information was available in the GHGRP indicating reporters using CEMS for 

CO2, CH4, and N2O in facilities, those data were used to identify the actual number of facilities 

or process units that currently use CO2 CEMS (or N2O or methane, if applicable). 

NSPS and NESHAP rule requirements that apply to GHGRP reporters may also require 

CEMS usage not related to GHGs. These regulations do not generally require CO2 CEMS 

because they regulate criteria pollutants and air toxics. However, the CEMS installed to meet the 

rules may be modified to be used for GHG reporting, which would lower the overall cost of 

installing the CEMS. Table 3-1 summarizes the NSPS and NESHAP applicable to sources 

subject to each subpart with “inputs to equations” data elements, and identifies the NSPS and 

NESHAP that have CEMS as an option or requirement. The CEMS standards in the NESHAPs 

and NSPS were used to develop a count of potential facilities or process units that may have 

equipment installed that could be modified for use in the GHGRP. Appendix B contains detailed 

summaries of applicability of the air rules for sources or processes in each subpart. 

 
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Table 3-1. NSPS and NESHAP Applicable to GHGRP reporters with “inputs to 

equations” data elements 

Subpart 

of Part 

98 

NESHAP/NSPS Subparts Revieweda Are CEMS an option or requirement 

under the NSPS and/or NESHAP and, if 

so, can they be used for GHGRP? 

C NSPS: Subpart Db Yes 

NESHAP: Subpart DDDDD Yes 

NESHAP: Subparts CCC and DDD Yes 

E NSPS: Subpart NNN Yes; however CEMS is not required; it is 

one of several compliance options NSPS: Subpart RRR 

F NSPS: Subpart S No 

NESHAP: Subpart LL No 

G None Not applicable 

H NSPS: Subpart LL Yes 

NSPS: Subpart F Yes 

NESHAP: Subpart EEE Yes 

K NSPS: Subpart Z No 

NESHAP: Subpart XXX No 

NESHAP: Subpart YYYYYY No 

L NESHAP: Subpart FFFF Yes 

N NSPS: Subpart CC No 

NSPS: Subpart PPP No 

NSPS: Subpart NNN No 

NESHAP: Subpart HHHH No 

NESHAP: Subpart SSSSSS No 

NESHAP: Subpart N (Part 61) No 

O NESHAP: Subpart FFFF Yes; however CEMS is not required; it is 

one of several compliance options 

P NESHAP: Subpart CC No 

Q NESHAP: Subpart RRRRR No 

NESHAP: Subpart FFFFF No 

NESHAP: Subpart L No 

NESHAP: Subpart CCCCC No 

NSPS: Subpart AA and AAa No 

NESHAP: Subpart YYYYY No 

R NSPS: Subpart L No 

NSPS: Subpart R Yes; however CEMS is not required for new 

sources only 

NESHAP: Subpart X No 

S NSPS: Subpart HH No 

NESHAP: Subpart AAAAA No 

U None Not applicable 

V NSPS: Subpart G Yes 
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Subpart 

of Part 

98 

NESHAP/NSPS Subparts Revieweda Are CEMS an option or requirement 

under the NSPS and/or NESHAP and, if 

so, can they be used for GHGRP? 

X NSPS: Subpart III Yes; however CEMS is not required; it is 

NSPS: Subpart NNN one of several compliance options 

NSPS: Subpart RRR 

NESHAP: Subpart F 

NESHAP: Subpart G 

NESHAP: Subpart YY No 

Y NSPS: Subpart J Yes 

NESHAP: Subpart CC No 

NESHAP: Subpart UUU Yes 

Z NSPS: Subpart T No 

NESHAP: Subpart AA No 

AA NSPS: Subpart BB Yes for Kraft and Semichemical mills; No 

for others. 

NESHAP: Subpart S No 

NESHAP: Subpart MM No 

BB None Not applicable 

CC NSPS: Subpart OOO No 

NSPS: Subpart UUU No 

EE NSPS: Subpart LL No 

GG NSPS: Subpart Q No 

NSPS: Subpart LL No 

NESHAP: Subpart GGGGGG No 

NESHAP: Subpart TTTTTT No 

TT None Not applicable a

NSPS subparts are in 40 CFR part 60; NESHAP subparts are in 40 CFR part 63. 

Estimating Cost Impacts

Depending on the type of monitoring requirements in the NSPS or NESHAP regulations, 

the modifications needed to install a CO2 CEMS for the purpose of monitoring for the GHGRP 

may be minimal, such as adding a CO2 analyzer only, or more costly, such as adding a CO2

analyzer, flow meter, and infrastructure. In order to accurately assess the cost impacts of 

requiring CEMS for the GHGRP, the potential number of facilities that, due to the requirements 

in NSPS and NESHAP, would be able to install a CO2 CEMS at a reduced cost was evaluated. 

Based on the requirements in the rules, the GHGRP subparts, and the process/facility count and 

CEMS information (discussed earlier), the following CEMS usages were identified: 

 Source has CO2 CEMS 

 Source has non-CO2 GHG CEMS (such as N2O CEMS) or has non-GHG CEMS (such as 

NOX or CO monitors) 

 Source has no CEMS 
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 After the CEMS characterization was completed, the cost impacts of requiring CO2 

CEMS were estimated for each subpart based on the number of facilities (or sources) or units (or 

processes) that would need to upgrade existing monitoring equipment to meet the requirements 

of the GHGRP. Cost information in the RIA was reviewed and separated into the components 

necessary for CO2 CEMS.51 Based on the type of CEMS used, five CEMS usage scenarios were 

developed. The costs associated with adding equipment to meet the GHGRP monitoring 

requirements for sources/units in each of the five CEMS usage scenarios were developed from 

the CEMS component costs. Table 3-2 summarizes the costs and equipment necessary for each 

scenario. For Scenarios 2 and 3, costs were assigned considering specific rule requirements that 

are presented in Appendix B and information in the RIA. 

Table 3-2. Summary of Costs for CO2 CEMS Modifications 

Scenario 

# Scenario

Total annual 

cost/application

1 Source has no CEMS -- Add CO2 analyzer, flow meter, and 

infrastructure $ 70,265 

2 Source has CEMS for other pollutants -- Add CO2 analyzer 

and flow meter $ 56,040 

3 Source has CEMS for other pollutants -- Add CO2 analyzer 

only $ 20,593 

4 Source has CEMS for other pollutants -- Add flow monitor 

only $ 24,511 

5 Source has CO2 CEMS No Cost 

3.2 Results of Analysis 

 Table 3-3 summarizes the results of the characterization analysis. The table shows for 

each subpart whether information was collected on a facility, unit or process basis. The table 

summarizes the actual number of facilities subject to the subpart that use CO2 CEMs, non-CO2

GHG CEMS, or non-GHG CEMS. The table also shows the potential number of sources that 

may have the same monitoring equipment based on a review of requirements in NSPS or 

NESHAP, and assumptions regarding which facilities would use CEMS. The potential number 

includes both the actual number and additional units/facilities that result from reviewing the 

NSPS or NESHAP. In some cases, a potential estimate could not be made based on the 

evaluation of the air rules, but an actual number was identified based on data sources reviewed. 

Appendix B contains detailed summaries of the CEMS characterization analysis for each 

subpart. 
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9 

Table 3-3. Summary of CEMS Characterization for Each Subpart with “Inputs to 

Equations” 

Subpart Basis Number

Subject to

Subparta

Reporting CO2

CEMS in GHGRP

Reporting non‐

CO2 GHG CEMS in

GHGRP

l

Reporting non‐GHG CEMS in

NSPS/NESHAP

Actual Potential

C Facilities 1,985 177 NA NA NA

Units 14,197 311 NA 1056 1151

E Facilities 3 NA NA NA NA

F Facilities 10 NA NA NA NA

G Facilities 22 NA NA NA NA

H Facilities 96 82 0b 14c 14c

Units 140 112 0b 0d 28e

K Facilities 10 NA NA NA NA

L Facilities 16 NA 1 NA NA

N Facilities 110 3 NA NA NA

Units NA 3 NA NA NA

O Facilities 5 NA NA NA NA

P Facilities 103 3 NA NA NA

Units NA 3 NA NA NA

Q Facilities 128 11 NA NA NA

Units 165 14 NA NA NA

R Facilities 13 NA NA NA NA

S Facilities 73 1 NA NA NA

U Facilities 18 NA NA NA NA

V Facilities 36 NA NA 20g NA

Units 65 NA NA 36g NA

X Facilities 64 2 NA NA NA

Units NA 2 NA NA NA

Y‐ 

Catalytic

Cracking

and Sulfur

Recovery

Facilities

145 21 NA NA 104h

Process

Units

317 26 NA NA 317i

Y ‐ Other

Process

Unitsj Facilities

145 0 0 0 0

Process

Units

1,580 0 0 0 0

Z Facilities 13 NA NA 7k 7k

AA Facilities 110 0l NA 89m NA

Units 330m 0l NA 266m NA

BB Facilities 1 NA NA NA NA
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CC Facilities 4 1 NA NA NA

Units NA 1 NA NA NA

EE Facilities 7 NA NA NA NA

GG Facilities 6 NA NA NA NA

TT Facilities 173 NA NA NA NA

NA = No estimate available 

a

 Number of facilities that reported to the GHGRP in 2011. b

 No units or facilities are known to be using non-CO2 GHG CEMS (e.g., for CH4 or N2O). c

 Used 96 as the actual and high estimate of the number of operating plants, minus the 82 that reported to GHGRP in 2011 that 

they are using CO2 CEMS. d

 The count of units with non-GHG CEMS (102) in Table 4-3 of the RIA for the GHG RP is lower than the number that reported 

to GHGRP in 2011 that they are using CO2 CEMS (112). Therefore, we cannot assume that any additional facilities have nonGHG CEMS installed. 

e

 Based on assuming that all kilns will have a non-GHG CEMS to comply with the NESHAP, and using the estimated number of 

units (140) in the “Summary of Environmental and Cost Impacts for Final Portland Cement NESHAP and NSPS” (August 6, 

2010), minus the 112 that reported to GHGRP in 2011 that they are using CO2 CEMS. g

 Based on data reported as a part of the 1990-2006 Inventory of U.S. Greenhouse Gas Emissions and Sinks, which are shown in 

the TSD to subpart V. A high estimate was not generated since the inventory data were reported by the facility and presumed to 

be the actual count of units with NOX CEMS. h

 Count of facilities which have catalytic cracking and/or sulfur recovery processes. Some facilities have both. i

 Unit count assumes all catalytic cracking processes have catalyst regenerators (130+187), and all will use CEMS to comply with

the NESHAP/NSPS. 

j Includes fluid coking, coke calcining, catalytic reforming, flares, loading operations, and other process vents. Stationary 

combustion units are covered under subpart C. 

k

.Counts are based on data reported in the NESHAP ICR responses. 

l No facilities reported to GHGRP in 2011 that they were using a CEMS to report GHG emissions. m The NCASI survey provided process unit data and the 2009 RIA estimated that units were subject to Tier 4 requirements. 

However, these count data and the count for facilities that reported to GHGRP in 2011 (110) could not be directly related. 

Therefore, based on the data, unit and facility counts were estimated. 

Table 3-4 summarizes the estimate of capital and annual cost impacts for each subpart if 

CO2 CEMS are required for sources or process units subject to the GHGRP. The table does not 

show the cost of applying N2O or CH4 CEMS. The table presents the cost to upgrade monitoring 

equipment (existing equipment for actual sources and likely equipment for potential sources 

based on the air rules) and the cost to add full CO2 CEMS for facilities that are subject to the 

GHGRP, but do not have CEMS. Table 3-4 summarizes costs based on actual counts of 

units/facilities with CEMS, and potential counts of units/facilities with CEMS based on NSPS 

and NESHAP rule requirements. Potential costs incorporate information from actual number of 

units/facilities where information is known as well as the additional potential number of 

units/facilities that may be using CEMS based on NESHAP and NSPS rule requirements. See 

Appendix B for detailed information for each subpart. Appendix C contains detailed cost 

estimates for each subpart and each CEMS scenario. Appendix C also contains cost estimates for 

all three types of GHG CEMS (CO2, N2O, and CH4).

Table 3-4. Summary of Cost Impacts From Requiring CEMS for GHGRP Subparts 

Subpart of 

Part 98 

Capital Cost Estimate For Using 

CEMS ($) 

Total Annual Cost Estimate for 

Using CEMS ($/yr) 

Actuala Potentialb Actuala Potentialb
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11 

C $1,680,248,013   $1,689,440,545 $960,678,190 $966,001,990

E $ ‐  $ ‐  $ ‐  $ ‐ 

F $1,229,981   $1,229,981 $702,650 $702,650

G $2,705,958   $2,705,958 $1,545,830 $1,545,830

H $4,004,048   $560,101 $2,544,024 $576,604

K $1,229,981   $1,229,981 $702,650 $702,650

L $ ‐  $ ‐  $ ‐  $ ‐ 

N $13,160,798   $13,160,798 $7,518,355 $7,518,355

O $ ‐  $ ‐  $ ‐  $ ‐ 

P $12,299,811   $12,299,811 $7,026,500 $7,026,500

Q $18,572,715   $18,572,715 $10,610,015 $10,610,015

R $1,598,975   $1,598,975 $913,445 $913,445

S $8,855,864   $ ‐  $5,059,080 $ ‐ 

U $ 2,213,966 $ 2,213,966 $ 1,264,770 $ 1,264,770

V $ ‐  $ ‐  $ ‐  $ ‐ 

X $7,625,883   $7,871,879 $4,356,430 $4,496,960

Y $191,139,063   $175,521,765 $109,191,810 $101,365,847

Z $878,014   $878,014 $565,741 $565,741

AA $33,613,009   $33,613,009 $19,404,705 $19,404,705

BB $122,998   $122,998 $70,265 $70,265

CC $368,994   $368,994 $210,795 $210,795

EE $860,987   $860,987 $491,855 $491,855

GG $737,989   $737,989 $421,590 $421,590

TT $ ‐  $ ‐  $ ‐  $ ‐ 

Total $1,981,467,047   $1,962,044,020 $1,133,278,700 $1,123,378,467 a

Costs are based on the actual number of units/facilities for which information was available indicating current use 

of CEMS under the GHGRP. See Appendix B for detailed information for each subpart. 

b

Costs are based on potential number of units/facilities that may be using CEMS based on NESHAP and NSPS rule 

requirements. Costs include actual number of units/facilities based on reporting to the GHGRP as well as the 

additional potential number of units/facilities that may be using CEMS based on NESHAP and NSPS rule 

requirements. See Appendix B for detailed information for each subpart. 

4.0 Summary 

Based on the results of this analysis, EPA proceeded to Step 4 of the evaluation for all of the 25 

of the 28 subparts evaluated in this memorandum. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

12 

5.0 References 

1. U.S. EPA. "Technical Support Document for Stationary Fuel Combustion Emissions: 

Proposed Rule for Mandatory Reporting of Greenhouse Gases." Office of Air and 

Radiation. January 30, 2009. Available: 

http://www.epa.gov/ghgreporting/documents/pdf/archived/tsd/TSD%20Stationary%20Co

mbustion%202-02-09.pdf. 

2. U.S. EPA. "Technical Support Document for the Adipic Acid Production Sector: 

Proposed Rule for Mandatory Reporting of Greenhouse Gases." Office of Air and 

Radiation. January 22, 2009. Available: 

http://www.epa.gov/ghgreporting/documents/pdf/archived/tsd/TSD%20Adipic_EPA%20

2-12-09.pdf. 

3. U.S. EPA. "Technical Support Document for Process Emissions from Primary Production 

of Aluminum: Proposed Rule for Mandatory Reporting of Greenhouse Gases." Office of 

Air and Radiation. February 4, 2009. Available: 

http://www.epa.gov/ghgreporting/documents/pdf/archived/tsd/TSD%20Aluminum_2009

0204.pdf. 

4. U.S. EPA. "Technical Support Document for the Ammonia Production Sector: Proposed 

Rule for Mandatory Reporting of Greenhouse Gases." Office of Air and Radiation. 

January 22, 2009. Available: 

http://www.epa.gov/ghgreporting/documents/pdf/archived/tsd/TSD%20Ammonia%20_E

PA%201-22-09.pdf. 

5. U.S. EPA. "Technical Support Document for Process Emissions from Cement: Proposed 

Rule for Mandatory Reporting of Greenhouse Gases." Office of Air and Radiation. 

January 28, 2009. Available: 

http://www.epa.gov/ghgreporting/documents/pdf/archived/tsd/TSD%20Cement%20_EP

A%201-28-09.pdf. 

6. U.S. EPA. "Technical Support Document for the Ferroalloy Production Sector: Proposed 

Rule for Mandatory Reporting of Greenhouse Gases." Office of Air and Radiation. 

January 22, 2009. Available: 

http://www.epa.gov/ghgreporting/documents/pdf/archived/tsd/TSD%20Ferroalloys%20_

EPA%201-22-09.pdf. 

7. U.S. EPA. "Technical Support Document for Emissions from Production of Fluorinated 

Gases: Final Rule for Mandatory Reporting of Greenhouse Gases." Office of Air and 

Radiation. November 5, 2010. Available: 

http://www.epa.gov/ghgreporting/documents/pdf/2010/Subpart-L_TSD.pdf. 

8. U.S. EPA. "Technical Support Document for the Glass Manufacturing Sector: Proposed 

Rule for Mandatory Reporting of Greenhouse Gases." Office of Air and Radiation. 

January 22, 2009. Available: 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

13 

http://www.epa.gov/ghgreporting/documents/pdf/archived/tsd/TSD%20Glass__EPA%20

1-22-09.pdf. 

9. U.S. EPA. "Technical Support Document for Emissions of HFC-23 from Production of 

HCFC-22: Proposed Rule for Mandatory Reporting of Greenhouse Gases." Office of Air 

and Radiation. February 6, 2009. Available: 

http://www.epa.gov/ghgreporting/documents/pdf/archived/tsd/TSD%20HFC23_20090206.pdf. 

10. U.S. EPA. "Technical Support Document for Hydrogen Production: Proposed Rule for 

Mandatory Reporting of Greenhouse Gases." Office of Air and Radiation. August 5, 

2008. Available: 

http://www.epa.gov/ghgreporting/documents/pdf/archived/tsd/TSD%20HydrogenProduct

ion%20EPA_2-02-09.pdf. 

11. U.S. EPA. "Technical Support Document for the Iron and Steel Sector: Proposed Rule for 

Mandatory Reporting of Greenhouse Gases." Office of Air and Radiation. August 28, 

2009. Available: 

http://www.epa.gov/ghgreporting/documents/pdf/archived/tsd/TSD%20Iron%20and%20

Steel%20_EPA%209-8-08.pdf. 

12. U.S. EPA. "Technical Support Document for the Lead Production Sector: Proposed Rule 

for Mandatory Reporting of Greenhouse Gases." Office of Air and Radiation. January 22, 

2009. Available: 

http://www.epa.gov/ghgreporting/documents/pdf/archived/tsd/TSD%20Lead%20%20_E

PA%201-22-09.pdf. 

13. U.S. EPA. "Technical Support Document for the Lime Manufacturing Sector: Proposed 

Rule for Mandatory Reporting of Greenhouse Gases." Office of Air and Radiation. 

January 22, 2009. Available: 

http://www.epa.gov/ghgreporting/documents/pdf/archived/tsd/TSD%20Lime%20_EPA%

201-22-09.pdf. 

14. U.S. EPA. "Technical Support Document for the Miscellaneous Uses of Carbonate 

Sector: Proposed Rule for Mandatory Reporting of Greenhouse Gases." Office of Air and 

Radiation. January 22, 2009. Available: 

http://www.epa.gov/ghgreporting/documents/pdf/archived/tsd/TSD%20MiscellaneousCar

bornates_EPA%201-22-09.pdf. 

15. U.S. EPA. "Technical Support Document for the Nitric Acid Production Sector: Proposed 

Rule for Mandatory Reporting of Greenhouse Gases." Office of Air and Radiation. 

January 22, 2009. Available: 

http://www.epa.gov/ghgreporting/documents/pdf/archived/tsd/TSD%20Nitric%20Acid%

20_EPA%201-22-09.pdf. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

14 

16. U.S. EPA. "Technical Support Document for the Petrochemical Production Sector: 

Proposed Rule for Mandatory Reporting of Greenhouse Gases." Office of Air and 

Radiation. September 9, 2008. Available: 

http://www.epa.gov/ghgreporting/documents/pdf/archived/tsd/TSD%20PetroChem_EPA

_09-09-08.pdf. 

17. U.S. EPA. "Technical Support Document for the Petroleum Refining Sector: Proposed 

Rule for Mandatory Reporting of Greenhouse Gases." Office of Air and Radiation. 

September 8, 2008. Available: 

http://www.epa.gov/ghgreporting/documents/pdf/archived/tsd/TSD%20Petroleum%20Re

finery_EPA_01-22-09.pdf. 

18. U.S. EPA. "Technical Support Document for the Phosphoric Acid Production Sector: 

Proposed Rule for Mandatory Reporting of Greenhouse Gases." Office of Air and 

Radiation. February 20, 2009. Available: 

http://www.epa.gov/ghgreporting/documents/pdf/archived/tsd/TSD%20Phosphoric%20-

%20_EPA%202-18-09.pdf. 

19. U.S. EPA. "Technical Support Document for the Pulp and Paper Sector: Proposed Rule 

for Mandatory Reporting of Greenhouse Gases." Office of Air and Radiation. February 

11, 2009. Available: 

http://www.epa.gov/ghgreporting/documents/pdf/archived/tsd/TSD%20Pulp%20and%20

Paper%202_11_09.pdf. 

20. U.S. EPA. "Technical Support Document for the Silicon Carbide Production Sector: 

Proposed Rule for Mandatory Reporting of Greenhouse Gases." Office of Air and 

Radiation. January 22, 2009. Available: 

http://www.epa.gov/ghgreporting/documents/pdf/archived/tsd/TSD%20Silicon%20Carbi

de%20_EPA%201-22-09.pdf. 

21. U.S. EPA. "Technical Support Document for the Soda Ash Manufacturing Sector: 

Proposed Rule for Mandatory Reporting of Greenhouse Gases." Office of Air and 

Radiation. January 22, 2009. Available: 

http://www.epa.gov/ghgreporting/documents/pdf/archived/tsd/TSD%20Soda%20Ash%2

0_EPA%201-22-09.pdf. 

22. U.S. EPA. "Technical Support Document for the Titanium Dioxide Production Sector: 

Proposed Rule for Mandatory Reporting of Greenhouse Gases." Office of Air and 

Radiation. January 22, 2009. Available: 

http://www.epa.gov/ghgreporting/documents/pdf/archived/tsd/TSD%20Titanium%20Dio

xide_EPA%201-22-09.pdf. 

23. U.S. EPA. "Technical Support Document for the Zinc Production Sector: Proposed Rule 

for Mandatory Reporting of Greenhouse Gases." Office of Air and Radiation. January 22, 

2009. Available: 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

15 

http://www.epa.gov/ghgreporting/documents/pdf/archived/tsd/TSD%20Zinc%20%20_EP

A%201-22-09.pdf. 

24. U.S. EPA. "Technical Support Document for Industrial Wastewater Treatment: Final 

Rule for Mandatory Reporting of Greenhouse Gases." Climate Change Division Office of 

Atmospheric Programs. June, 2010. Available: 

http://www.epa.gov/ghgreporting/documents/pdf/2010/Subpart-II_TSD.pdf. 

25. U.S. EPA. "Technical Support Document for the Industrial Waste Landfill Sector: Final 

Rule for Mandatory Reporting of Greenhouse Gases." Climate Change Division Office of 

Atmospheric Programs. June 9, 2010. Available: 

http://www.epa.gov/ghgreporting/documents/pdf/archived/tsd/TSD%20Landfills_EPA_0

2%2004%2009_2.pdf. 

26. "Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2006." April, 2008. EPA 

430-R-08-005. Available: 

http://www.epa.gov/climatechange/ghgemissions/usinventoryreport/archive.html. 

27. Climate Leaders Greenhouse Gas Inventory Protocol. Available: 

http://www.epa.gov/climateleadership/guidance/index.html. 

28. Voluntary Reporting of Greenhouse Gases Program. June 1, 2006. Available: 

http://www.eia.gov/oiaf/1605/index.html. 

29. The Climate Registry Reporting Protocols. May 2008. Available: 

http://www.theclimateregistry.org/resources/protocols/general-reporting-protocol/. 

30. California Climate Action Registry. August 2008. Available: 

http://www.climateregistry.org/tools/protocols/general-reporting-protocol.html. 

31. California Air Resources Board Cap and Trade Program. Available: 

http://www.arb.ca.gov/cc/capandtrade/capandtrade.htm. 

32. New Mexico Environment Department - Greenhouse Gases Reporting. Available: 

http://www.nmenv.state.nm.us/aqb/GHG/ghgrr_index.html. 

33. Regional Greenhouse Gas Initiative. Available: http://www.rggi.org/. 

34. Western Climate Initiative. Available: 

http://www.westernclimateinitiative.org/index.php. 

35. Eggleston H.S., Buendia L., Miwa K., Ngara T. and Tanabe K. (eds). "2006 IPCC 

Guidelines for National Greenhouse Gas Inventories." Prepared by the National 

Greenhouse Gas Inventories Programme. The Intergovernmental Panel on Climate 

Change (IPCC), 2006. Available: http://www.ipccnggip.iges.or.jp/public/2006gl/index.html. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

16 

36. Official Journal of the European Union, Commission Decision 29 January 2004. 

Available: 

http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2004:059:0001:0074:EN:P

DF. 

37. Australian Government - Clean Energy Regulator - National Greenhouse and Energy 

Reporting: Guidelines. Available: http://www.cleanenergyregulator.gov.au/NationalGreenhouse-and-Energy-Reporting/Fact-sheets-FAQs-andguidelines/Guidelines/Pages/default.aspx. 

38. Environment Canada - Canada's Greenhouse Gas Emissions Monitoring, Reporting and 

Verification of Greenhouse Gas Sources and Sinks. Available: http://www.ec.gc.ca/gesghg/default.asp?lang=En&n=1357a041-1. 

39. World Resources Institute and World Business Council for Sustainable Development 

Greenhouse Gas Protocol. Available: http://www.ghgprotocol.org/. 

40. "Compendium of Greenhouse Gas Emissions Methodologies for the Oil and Natural Gas 

Industry." American Petroleum Institute (API). August 2009. Available: 

http://www.api.org/environment-health-and-safety/climate-change/whatsnew/compendium-ghg-methodologies-oil-and-gas-industry.aspx. 

41. European Bank for Reconstruction and Development. Available: 

http://www.ebrd.com/pages/homepage.shtml#&panel1-4. 

42. American Iron and Steel Institute. Available: http://www.steel.org/. 

43. United Nations Framework Convention on Climate Change. Available: 

http://cdm.unfccc.int/methodologies/index.html. 

44. "Clean Energy Legislative Package." Australian Government Department of Climate 

Change and Energy Efficiency. Available: http://www.cleanenergyfuture.gov.au/cleanenergy-future/our-plan/. 

45. Comment on the Mandatory Greenhouse Gas Reporting Rule from Dow Corning, EPAHQ-OAR-2008-0508-0562. 

46. Comment on the Call For Information from the American Chemistry Council, EPA-HQOAR-2010-0964-0015. 

47. Comment on the Call For Information from Association of Battery Recyclers, EPA-HQOAR-2010-0964-0019 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

17 

48. Comment on the Call For Information from Clean Air Task Force, Environmental 

Defense Fund, Natural Resources Defense Council, and Sierra Club, EPA-HQ-OAR2010-0964-0029. 

49. “Evaluation of Competitive Harm from Reporting ‘Inputs to Equations’ Data Elements 

Deferred to March 31, 2015”. Memorandum from EPA to Docket EPA-HQ-OAR-2010-

0929. April, 2013. 

50. U.S. EPA. Greenhouse Gas Reporting Program." RY2011.R.50 UA1-1. Available: 

http://www.epa.gov/ghgreporting/reporters/datasystem/index.html. 

51. U.S. EPA. "Regulatory Impact Analysis for the Mandatory Reporting of Greenhouse Gas 

Emissions Final Rule (GHG Reporting)." Docket ID: EPA-HQ-OAR-2008-0508-2229. 

September 2009. Available: http://www.regulations.gov/#!documentDetail;D=EPA-HQOAR-2008-0508-2229.
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

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Appendix A1 

Summary Evaluation of Alternative Calculation Equations 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

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Table A1-1. Summary of the Evaluation of Alternative Calculation Equations For Each Subpart 

Subpart Description Summary of Evaluation of Alternative Calculations 

C Combustion No calculation methodologies were identified that would be an appropriate alternative. 

In general, calculation methods reviewed are the same as the current methods required, 

which are based on the IPCC methods. The alternative methods would still require fuel 

information (e.g., fuel input, fuel purchases, heat content, etc.) for the calculations; 

according to Step 2 of the analysis, disclosure concerns were identified for this 

information.a

 

E Adipic Acid No calculation methodologies were identified that would be an appropriate alternative. 

Methodologies are similar to 2 IPCC methods. The IPCC Tier 1 methodology 

calculates emissions using facility-level data rather than unit-level data and results in 

lower accuracy in estimating emissions. IPCC Tier 2 methodology is similar to the Tier 

1 methodology, except default factors are used instead of facility-specific information 

resulting in lower accuracy than Tier 1. Both methods still require facility production 

information as an input; according to Step 2 of the analysis, disclosure concerns were 

identified for this information.a

 

F Aluminum No calculation methodologies were identified that would be an appropriate alternative. 

3 methods were identified. Two (IPCC Tier 1 for CF4 and C2F6 and IPCC Tier 1 for 

CO2 emitted during electrolysis) use default emission factors which result in greater 

uncertainty than the current method. The third for calculating CF4 and C2F6 from 

smelter specific anode effects is the IPCC Tier 2 method, which also has high 

uncertainty compared to estimating emissions with the current method for CF4 and 

C2F6, ±50 percent. The alternatives still use production data; according to Step 2 of the 

analysis, disclosure concerns were identified for this information.a 

G Ammonia No calculation methodologies were identified that would be an appropriate alternative. 

Several alternative calculation methods were identified, but all are based on 3 IPCC 

methodologies: IPCC Tier 1, 2, and 3. The IPCC Tier 1 and 2 methods are not 

considered viable alternative calculation methods because they would result in higher 

uncertainty than the current method and would still require reporting of ammonia 

production and feedstock information, which, according to Step 2 of the analysis, 

disclosure concerns were identified.a

 The Tier 3 method is not considered a viable 

alternative because it would also require reporting of current “inputs to equations” data 

elements which, according to Step 2 of the analysis, disclosure concerns were 

identified.a

 

H Cement Kilns No calculation methodologies were identified that would be an appropriate alternative. 

Calculation methodologies used in various GHG reporting programs and protocols can 

be grouped into 3 categories: (1) calculation of emissions based on clinker production, 

(2) calculation of emissions based on cement production, (3) calculation of emissions 

based on carbonate input to the kiln. 

The clinker calculation methods reviewed are variations on the current method using 

more general emission factors (national or default factors) and/or not calculating 

emissions from some emission sources (e.g., raw materials). The alternatives eliminate 

the need for some of the current “inputs to equations” data elements. However, they 

still require clinker production; according to Step 2 of the analysis, disclosure concerns 

were identified for this information.a

 The alternative methods are all less accurate, 

with higher uncertainty levels depending on how general the emission factors used are 

to calculate GHG emissions. Calculation method (2) is no longer considered 

appropriate because it has a much higher uncertainty in emissions. Calculation method 

(3) would require more detailed inputs to be reported for raw materials for the kiln 

(unless defaults are used); raw material information was identified as having 

disclosure concerns in Step 2 of the analysis.a

 Use of calculation method (3) would 

result in more significant revisions to the reporting rule. The EPA previously 

determined this option could potentially be more costly and would not reduce the 
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Subpart Description Summary of Evaluation of Alternative Calculations 

uncertainty in emissions calculations. 

K Ferroalloy No calculation methodologies were identified that would be an appropriate alternative. 

For CO2, other methods reviewed included using production or process input data with 

an emission factor; mass balance with less site-specific data; and mass balance with 

more generic carbon content data. All alternative methods reviewed still use 

production data and/or process input data; according to Step 2 of the analysis, 

disclosure concerns were identified for this information.a

 No other methods were 

identified for CH4. 

L Fluorinated Gas 

Production 

No calculation methodologies were identified that would be an appropriate alternative. 

Two methods from IPCC were reviewed. However, the methods either use default 

factors and result in a high uncertainty in emission estimates or still require some of 

the same “inputs to equations” data elements which, according to Step 2 of the 

analysis, disclosure concerns were identified.a

 

N Glass No calculation methodologies were identified that would be an appropriate alternative. 

Alternative calculation methodologies for this subpart are categorized as either inputbased (using raw material information) or output based (using production information). 

The output-based methods have a higher uncertainty and use default values. Annual 

glass production for each furnace and total for the facility are reported under 

98.146(b)(3) but and were determined to be CBI in 76 FR 30782 (May 26, 2011). 

Therefore, the output-based methods would not avoid the disclosure concerns. All 

input-based methodologies are based on IPCC Tier 3 calculations. Differences between 

different programs are due to different defaults. Estimates using Tier 3 will be higher 

than the current method. The input equations still use “inputs to equations” data 

elements, which, according to Step 2 of the analysis, disclosure concerns were 

identified.a

 

O CFC No calculation methodologies were identified that would be an appropriate alternative. 

Alternative methods include calculating emissions using HCFC-22 production data 

with a default or site-specific emission factor, and parameter monitoring data (using 

process operating rate as a proxy for HFC-23 emissions). The alternative methods 

reviewed still use production data and/or process input data which, according to Step 2 

of the analysis, disclosure concerns were identified.a The alternative methods result in 

increased uncertainty. 

P Hydrogen No calculation methodologies were identified that would be an appropriate alternative. 

Commenters on the call for information suggested calculating emissions using 

aggregated fuel and feedstock consumption data to obscure specific information. This 

method would still require monthly analyses of carbon content for each fuel and 

feedstock; according to Step 2 of the analysis, disclosure concerns were identified for 

this information.a Commenters also suggested calculating emissions on a carbon feed 

basis and not require disaggregation of fuel/feedstock by type. There is insufficient 

information or analysis provided by the commenters to assess the accuracy of this 

methodology. The method would not reveal any of the “inputs to equations” data 

elements for which disclosure concerns were identified, but would require new 

calculation algorithms. One newer method from CDM is limited in use and would not 

apply to all reporters in this subpart. Alternative calculation methodologies reviewed 

previously for the GHGRP primarily use emission factors (default or site-specific). 

These methodologies are less accurate than the current method. Other methods use 

hydrogen production information, which, according to Step 2 of the analysis, 

disclosure concerns were identified.a

Q Iron and Steel No calculation methodologies were identified that would be an appropriate alternative. 

Alternative calculation methodologies used in various GHG reporting programs and 

protocols can be grouped into 5 categories: (1) calculation of emissions using 

production based emission factors, (2) calculation of emissions using input based 

emission factors, (3) calculation of emissions using default carbon weight fractions, (4) 

process unit mass balance calculation that excludes small contributors, and (5) plant-
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Subpart Description Summary of Evaluation of Alternative Calculations 

wide CO2 mass balance for integrated mills only. The alternative methods (1) through 

(4) eliminate the need for some of the current data elements. However, they still 

require other data elements to be reported, such as production information or 

ingredient information, which, according to Step 2 of the analysis, disclosure concerns 

were identified.a

 . Method (5) was previously determined by the EPA to not be 

appropriate because verification is needed on a process basis rather than a facility 

basis. Facility-wide estimates also have a higher uncertainty than process based 

calculations. 

R Lead No calculation methodologies were identified that would be an appropriate alternative. 

Other methods reviewed included using production or process input data with an 

emission factor or default carbon content data. The alternative methods reviewed still 

use production data and/or process input data which, according to Step 2 of the 

analysis, disclosure concerns were identified.a

 The alternative methods result in 

increased uncertainty in emission estimates. 

S Lime No calculation methodologies were identified that would be an appropriate alternative. 

The EPA previously considered allowing a process input based methodology (based on 

feedstock) at proposal, but decided not to proceed with that alternative in the final 

GHGRP. The process input based methodology requires feedstock based information 

(e.g., mass of lime, mass of carbonate consumed); according to Step 2 of the analysis, 

disclosure concerns were identified for this information.a

 Several of the alternatives 

use a process output based methodology using production information; according to 

Step 2 of the analysis, disclosure concerns were identified for this information. A third 

methodology reviewed uses the mass balance of carbonates in the inputs and outputs; 

according to Step 2 of the analysis, disclosure concerns were identified for this 

information.a 

U Carbonate No calculation methodologies were identified that would be an appropriate alternative. 

Two alternative calculation methods were identified: IPCC Tier 1 and Tier 2. The 

IPCC Tier 1 method uses emission factors based on the total mass of carbonate 

consumed in limestone and dolomite. Default values are used for the fraction of the 

carbonate comprised of limestone and dolomite. The calculation method results in a 

high uncertainty in emissions compared to the current method and still requires using 

overall carbonate consumed as an input; according to Step 2 of the analysis, disclosure 

concerns were identified for this information.a

 The IPCC Tier 2 methodology is the 

same as Tier 1, except the fraction of carbonate in the limestone versus dolomite 

consumed is not a default value. This methodology is more accurate than Tier 1, but 

still less accurate than current method. It also requires using the mass of carbonates 

consumed by carbonate type; according to Step 2 of the analysis, disclosure concerns 

were identified for this information.a

 

V Nitric Acid No calculation methodologies were identified that would be an appropriate alternative. 

Several alternative calculation methods were identified, all of which are similar to 

IPCC Tier 1 and Tier 2 methodologies. Both IPCC methodologies calculate emissions 

using plant level emission factors. Tier 2 is more refined in that emissions are also 

calculated by different control technologies used. Both methodologies still require 

using production information; according to Step 2 of the analysis, disclosure concerns 

were identified for this information.a

 Both have a higher level of uncertainty than the 

current method. 

X Petrochemical No calculation methodologies were identified that would be an appropriate alternative. 

Three alternative calculation methodologies were identified. One is the IPCC Tier 1 

methodology, which calculates emissions using default emission factors for CO2 and 

CH4 (published by IPCC) multiplied by the production of each product. The method 

still uses plant specific production rates; according to Step 2 of the analysis, disclosure 

concerns were identified for this information.a

 . Additionally, the level of uncertainty is 

high compared to current method (10-60% higher for CO2; 30-80% higher for CH4). 

The second alternative requires routing of process vent emissions to stacks for direct 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

22 

Subpart Description Summary of Evaluation of Alternative Calculations 

and continuous measurements of CO2 emissions from each process stack (except 

flares) and each combustion source stack. While more accurate and introducing less 

uncertainty than the current method, it requires mandating process configurations that 

are not the intent of the GHGRP. However, the use of CEMS is evaluated in section 

3.0 as part of the CEMS analysis. A third methodology was suggested by a commenter 

to the Call for Information notice. The commenter suggested allowing the use of 

subpart PP methodologies, which require direct measurements using gas analyzers on a 

quarterly basis. The alternative has a high level of accuracy because it is based on 

source specific data. It may likely be more costly due to quarterly measurements. 

Additional analyses of the methodology would need to be undertaken to fully evaluate 

it, including assessing availability of equipment, applicability of analyzers for sources 

in this subpart, and cost. 

Y Refineries No calculation methodologies were identified that would be an appropriate alternative. 

IPCC’s Tier 1 and Tier 2 approaches use default emission factors to calculate GHG 

emissions from non-combustion sources at refineries and would provide less reliable 

emissions data for the entire refinery and no data on emissions from individual units. 

The following is a summary of the alternative calculation methods that were evaluated 

for individual emission points covered by subpart Y. 

Flares: Two alternative approaches were identified for calculating CO2 emissions. The 

first alternative approach uses default emission factors multiplied by the amount of 

flare gas burned. The second method uses test data (either from facility or vendor 

testing). However, both of these methods would be unlikely to yield accurate results 

since waste gas composition is highly variable especially during unit startup, 

shutdown, and malfunctions. 

Catalytic Cracking Units and Fluid Coking Units: part 98 currently includes all three 

possible calculation methods. 

Asphalt Blowing: One alternative method is based on default emission factors for 

calculating the emissions of CO2 and CH4 from asphalt blowing operations. Part 98 

calculation methods for both controlled and uncontrolled asphalt blowing operations 

rely on site-specific emission factors from facility-specific test data (though default 

emission factors are also provided for facilities that do not have the necessary test 

data). Allowing all users to use default emission factors instead of site-specific 

emission factors result in less accurate GHG emission estimates and would not avoid 

the use of “inputs to equations” data elements data; according to Step 2 of the analysis, 

disclosure concerns were identified for this information.a

 Equipment Leaks: Two 

alternative methods were identified for estimating emissions from equipment leaks. 

The first alternative method uses the crude feedstock throughput and a default emission 

factor to estimate fugitive emissions. This approach will yield less accurate results than 

the methods currently included in part 98. Furthermore, according to Step 2 of the 

analysisa

, disclosure concerns were identified with crude feedstock throughput data. 

The second alternative method would require refineries to measure the flow rates of 

each leaking component (i.e., flanges, connectors, pumps, compressors, valves, 

pressure relief valves, etc) using Hi-Flow SamplersTM, calibrated bag, or other 

measurement methods. The measured flow rate for each leaking component is 

multiplied by the time period during which the component is known to have been 

leaking, and the result adjusted for the uncertainty in the measurement of the flow rate. 

The total emissions for the refinery are the sum emissions for all leaking components. 

Due to the large number of components that would have to be regularly monitored and 

the difficulty of conducting such measurements for some inaccessible components, this 

approach is likely to be difficult and costly to implement. 

Storage Tanks: For storage tanks used to store unstabilized fuel oil, 3 alternatives were 

identified. The first uses default emission factors multiplied by the quantity of crude oil 

to calculate the CH4 emissions from flashing losses and are based on data from 

upstream oil and gas production facilities rather than on data from refinery storage 

tanks. The second approach uses computer simulation programs to estimate emissions 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

23 

Subpart Description Summary of Evaluation of Alternative Calculations 

from flashing losses. The third approach is to use a correlation equation, such as the 

Vasquez-Beggs Equation, standing correlation, or EUB rule of thumb. However, all of 

these methods would require one or more of the same inputs used in the existing part 

98 methods (e.g., tank-specific methane composition data, quantity of unstabilized 

crude oil received, etc.); according to Step 2 of the analysis, disclosure concerns were 

identified for this information.a

Other Emission Sources: There were no new alternative calculation methods identified 

for the flares, catalytic reforming units, sulfur recovery units, coke calcining, process 

vents, blowdowns, working and breathing losses from storage tanks not used to store 

unstabilized crude oil, and loading operations. All of the previously identified 

calculation methods considered by the EPA were incorporated into part 98. 

Z Phosphoric 

Acid 

No calculation methodologies were identified that would be an appropriate alternative. 

Only 1 alternative calculation methodology was identified. The methodology requires 

using default factors based on regional chemical composition of phosphate rock to 

calculate emissions. The methodology was considered and not used in the GHGRP 

because it was much less accurate than the method selected. Additionally, the 

alternative methodology would still require monthly phosphate rock consumption; 

according to Step 2 of the analysis, disclosure concerns were identified for this 

information.a

 

AA Pulp and Paper No calculation methodologies were identified that would be an appropriate alternative. 

The major source of GHG emissions from facilities in this subpart are combustion 

sources - lime kilns, recovery boilers, and power boilers. Emissions from power boilers 

are covered under the subpart C analysis. Two alternative calculation methodologies 

for the biogenic component in recovery furnaces were identified. Both are based on 

using default factors. One is based on using default values for HHV instead of sitespecific values and the method is only applicable to kraft or soda mills. The second is 

based on multiplying the total energy of spent liquor combusted and emission factors 

relating energy to emissions. Neither is very accurate and both have high uncertainty in 

emissions. The first method also uses some of the same “inputs to equations” data 

elements which, according to Step 2 of the analysis, disclosure concerns were 

identified.a

 The second method does not allow emissions to be verified on an 

equipment basis, and applies only to the facility as a whole. 

BB Silicon Carbide No calculation methodologies were identified that would be an appropriate alternative. 

Two alternative calculation methods were identified, based on using the IPCC Tier 1 

calculation methodology. One option is to use an input-based (using raw material 

information) approach using default emission factors from IPCC, and the petroleum 

coke input. The option would still use many of the same data elements as inputs that 

the current method uses; according to Step 2 of the analysis, disclosure concerns were 

identified for this information.a

 The second option is to use an output-based (using 

production information) approach using default emission factors from IPCC, and the 

silicon carbide production. However, silicon carbide production information, which is 

reported under 98.286(a)(2) and (b)(2), was determined to be entitled to confidential 

treatment in 76 FR 30782 (May 26, 2011). 

CC Soda Ash No calculation methodologies were identified that would be an appropriate alternative. 

Two alternative calculation methodologies were identified that were previously 

considered but not adopted in the GHGRP. Both are based on the IPCC Tier 2 

methodology. One would use default factors applied to the facility. The other would 

use site-specific factors. Both have a slight decrease in emissions accuracy estimates. 

However, both still require quantity of trona used or soda ash produced as inputs; 

according to Step 2 of the analysis, disclosure concerns were identified for this 

information.a

 

EE Titanium 

Dioxide 

No calculation methodologies were identified that would be an appropriate alternative. 

Two alternative calculation methods were identified. One option is to use the IPCC 

Tier 1 approach, which calculates emissions using a default emission factor and 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

24 

Subpart Description Summary of Evaluation of Alternative Calculations 

production information. However, production information, which is reported under 

98.316(a)(3) and (b)(4), was determined to be CBI in 76 FR 30782 (May 26, 2011). 

This option also increases uncertainty. The second option is to estimate emissions 

based on the carbon reducing agent. Emissions would be estimated by multiplying the 

tonnage of carbon reducing agent and 2 default factors. The uncertainty of this option 

has not been determined, but is likely much higher than the current method because 2 

default factors are used rather than site-specific information. 

GG Zinc No calculation methodologies were identified that would be an appropriate alternative. 

Five alternative calculation methods were identified. Several of the options (IPCC Tier 

1 and Tier 2, U.S. inventory) use default emission factors which would introduce 

higher uncertainty in emissions and are more appropriate for aggregated process 

information on a sector-wide or nationwide basis. One of the methods would also 

require production information which, according to Step 2 of the analysis, disclosure 

concerns were identified.a

 . One other method is similar in that default emission factors 

are used, but the calculation of emissions is based on the quantity of carbon used in the 

production of metal. This method has a lower uncertainty, but it is still is not as 

accurate as the current method. 

TT Industrial 

Landfills 

No calculation methodologies were identified that would be an appropriate alternative. 

One alternative calculation method was identified. Reporters would use the existing 

part 98 CH4 calculation methodology with default factors. This would result in a higher 

uncertainty in emissions than the current method due to the default factor. In addition , 

it requires reporting of some “inputs to equations” data elements which, according to 

Step 2 of the analysis, disclosure concerns were identified.a

 a For additional details on the alternative calculation equations evaluated, please see Appendix A2. For the Step 2 analysis, please 

see “Evaluation of Competitive Harm from Reporting ‘Inputs to Equations’ Data Elements Deferred to March 31, 2015” 

memorandum. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

25 

Appendix A2 

Detailed Evaluation of Alternative Calculation Equations 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

26 

Appendix A2. Subpart C – Evaluation of Alternative Calculation Equations 

Alternative Analysis 

Methods in the Call for 

Information 

None identified. 

Methods previously 

considered but not adopted in 

final GHGRP 

Source1

 ID Description 

CARB 1 Same as 40 CFR part 75: CEMS. 

2 Calculate emissions similar to IPCC methods using fuel consumption and 

carbon or heat content. Still requires fuel input information for calculations, 

which was identified as having disclosure concerns in Step 2 of the 

analysis. 

CCAR 1 Similar to IPCC methods. Still requires information on fuel burned in 

calculations, which was identified as having disclosure concerns in Step 2 

of the analysis 

2 Same as 40 CFR part 75: CEMS. 

TCR 1 Calculate emissions similar to IPCC methods. Still require fuel input data 

in calculations, which was identified as having disclosure concerns in Step 

2 of the analysis. 

2 Same as 40 CFR part 75: CEMS. 

CCX 1 CEMS 

2 Calculate emissions using WRI/WBCSD protocols. Still requires fuel input 

data in calculations, which was identified as having disclosure concerns in 

Step 2 of the analysis 

RGGI Same as 40 CFR part 75: CEMS, with additional net energy output 

monitoring. 

DOE 1 Same as 40 CFR part 75: CEMS. 

2 Mass balance using fuel burned based on measured purchases or 

consumption and default or facility specific factors. Similar to IPCC 

methods. Still requires fuel input information which was identified as 

having disclosure concerns in Step 2 of the analysis. . 

40 CFR 

part 75 

 CO2 CEMS combined with stack flow monitor or calculate mass emissions 

using fuel sampling for percent carbon content and fuel flow monitoring. 

CL 1 Same as 40 CFR part 75: CEMS. 

2 Similar to IPCC calculation methods. 

EU ETS Emissions calculated using mass balance approach similar to Tier 3. Still 

requires fuel and heat content information as inputs which were identified 

as having disclosure concerns in Step 2 of the analysis. . 

ANGERS Tier 

1 

CEMS. 

Tier 

2 

Similar to IPCC Tier 2, but uses EF based on direct sampling and analysis. 

Still requires fuel feed information as inputs and requires fuel specific 

inputs to calculate EF which were identified as having disclosure concerns 

in Step 2 of the analysis. . 

Tier 

3 

Similar to IPCC Tier 2, but uses EF based on representative sampling. Still 

requires fuel feed information which was identified as having disclosure 

concerns in Step 2 of the analysis. . 

Tier 

4 

Similar to IPCC Tier 1. Still requires fuel feed information. 

CA GHG 1 References IPCC Tier 3 approaches. 

2 CEMS when a CO2 diluent monitor is installed for measurements of other 

pollutants. 

EU ETS 1 Emissions calculated using mass balance approach similar to Tier 3. Still 

requires fuel and heat content information as inputs which was identified as 

having disclosure concerns in Step 2 of the analysis. . 

2 CO2 CEMS allowed if combined with a stack flow monitor and requires 

supplementary calculations. 

Protocols and programs 

created after GHGRP 

None identified. 

1

 CARB = California Air Resources Board Mandatory Reporting Rule; CCAR = California Climate Action Registry; TCR = The Climate Registry; CCX = Chicago 

Climate Exchange; RGGI = Regional Greenhouse Gas Initiative; DOE = U.S. DOE 1605 (b) program; CL = U.S EPA Climate Leaders; EU ETS = European Union 

Emissions Trading Scheme; ANGERS = Australian National GHG and Energy Reporting System; CA GHG = Canadian GHG National Reporting Program. 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

27 

Appendix A2. Subpart E – Evaluation of Alternative Calculation Equations 

Alternative Analysis 

Methods in the Call for 

Information 

None identified. 

Methods previously 

considered but not adopted 

in final GHGRP 

Source1

 ID Description 

IPCC Tier 

1 

Multiplies facility-level production times the highest default emissions 

factor in IPCC Tier 1, which assumes no abatement of N2O emissions. 

Much lower accuracy than current method, still requires production data 

which was identified as having disclosure concerns in Step 2 of the 

analysis. . 

Tier 

2 

Similar to Tier 1. Uses technology-specific default factors to account for 

abatement. Lower accuracy than current method and still requires 

production information which was identified as having disclosure 

concerns in Step 2 of the analysis. . 

WRI/WBCSD 2 Same as IPCC Tier 2. 

3 Same as IPCC Tier 1. 

U.S. Inv Same as IPCC Tier 2. 

TCR Tier 

B 

Same as IPCC Tier 2. 

DOE B Similar to IPCC Tier 2, but uses actual destruction factors and not 

defaults. More accurate than IPCC Tier 2 but still uses many of current 

“inputs to equations” data elements and is not as accurate as current 

method which were identified as having disclosure concerns in Step 2 of 

the analysis. . 

C Similar to IPCC Tier 2. 

Protocols and programs 

created after GHGRP 

None identified. 

1

 IPCC = Intergovernmental Panel on Climate Change, 2006; U.S. Inv = U.S. National Inventory Report, 2008 Method; WRI/WBCSD = World Resources 

Institute/World Business Council for Sustainable Development; DOE = Department of Energy’s 1605 (b) Voluntary Reporting Program; TCR = The Climate 

Registry. 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

28 

Appendix A2. Subpart F – Evaluation of Alternative Calculation Equations 

Alternative Analysis 

Methods in the Call for 

Information 

None identified. 

Methods previously 

considered but not adopted 

in final GHGRP 

Source1

 ID Description 

IPCC Tier 1 -

General 

Uses default emission factors for CF4 and C2F6 and production 

information. Significant uncertainty and still uses production data which 

was identified as having disclosure concerns in Step 2 of the analysis. . 

Tier 2 –

Smelter 

specific 

anode 

effects 

Uses factors for CF4 and C2F6. High uncertainty compared to estimating 

emissions with the current method for CF4 and C2F6, about ±50 percent. 

Could develop new emission factors for CF4 and C2F6 to reduce the 

uncertainty of the methodology, but the method still uses quantity of 

aluminum produced which was identified as having disclosure concerns 

in Step 2 of the analysis. . 

Tier 1 - 

Electrolysis 

Uses default emission factors for CO2 and production information. 

Higher uncertainty compared to current method (5 – 10%) and still uses 

production data which was identified as having disclosure concerns in 

Step 2 of the analysis. . 

Protocols and programs 

created after GHGRP 

None identified. 

1

 IPCC = Intergovernmental Panel on Climate Change, 2006. 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

29 

Appendix A2. Subpart G – Evaluation of Alternative Calculation Equations 

Alternative Analysis 

Methods in the Call for 

Information 

None identified. 

Methods previously 

considered but not adopted 

in final GHGRP 

Source1

 ID Description 

IPCC Tier 

1 

Uses default factor per unit of output multiplied by facility-level 

ammonia production. Introduces one additional input (ammonia 

production) which was identified as having disclosure concerns in Step 

2 of the analysis. Higher uncertainty in emissions than the current 

method due to defaults used. 

Tier 

2 

Same as IPCC Tier 1 except that it estimates emissions per fuel type, 

using ammonia production disaggregated by fuel input and process type. 

Introduces one additional input (ammonia production) which was 

identified as having disclosure concerns in Step 2 of the analysis. Still 

requires feedstock information which was identified as having 

disclosure concerns in Step 2 of the analysis. Results in higher 

uncertainty in emissions than the current method due to defaults used. 

Tier 

3 

Same as IPCC Tier 2 method, except uses actual total fuel requirement 

rather than default. Allows both default and measured carbon content 

and carbon oxidation factors. Introduces two additional inputs (total fuel 

requirement per plant and carbon oxidation factor) that are the same 

type of information identified as having disclosure concerns in Step 2 of 

the analysis. Still requires feedstock information, which was identified 

as having disclosure concerns in Step 2 of the analysis. Very accurate 

method only if actual carbon content and carbon oxidation factors are 

used. 

WRI/WBCSD 2 Same as IPCC Tier 2 if no facility-specific fuel requirement is available 

and default factors are used. 

3 Same as IPCC Tier 3 if facility-specific fuel requirement is available to 

calculate emissions. 

U.S. Inv Same as IPCC Tier 2. 

DOE B 

Rated 

Similar to IPCC Tier 2. It allows actual or default carbon content value 

and calculates annual, facility-wide emissions. If actual (not default) 

factors are used, then the method introduces little uncertainty; however, 

calculates only facility-level estimate. 

TCR-GRP Tier 

A2 

Same as IPCC Tier 2. 

Protocols and programs 

created after GHGRP 

None identified. 

1

 IPCC = Intergovernmental Panel on Climate Change, 2006; WRI/WBCSD = The World Resource Institute and World Business Council for Sustainable 

Development’s Greenhouse Gas Protocol; TCR-GRP = The Climate Registry General Reporting Protocol For the Voluntary Reporting Program, May 2008; DOE = 

Department of Energy 1605(b) Voluntary Reporting Program – Ammonia; U.S. Inv = U.S. National Inventory Report, 2008 Method. 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

30 

Appendix A2. Subpart H – Evaluation of Alternative Calculation Equations 

Alternative Analysis 

Methods in the 

Call for 

Information 

No calculation methods identified. 

Methods 

previously 

considered but 

not adopted in 

final GHGRP 

Source1 ID Method 

Type2

Description 

IPCC Tier 

1 

Cement Default factors; Clinker production inferred from cement 

production. 

Not recommended; high uncertainty. 

IPCC Tier 

2 

Clinker National factor; higher uncertainty than current method. 

IPCC Tier 

3 

Carbonate Default EF for carbonates. Potentially more costly; larger # 

of new inputs. 

U.S Inv Clinker IPCC Tier 2 w/default factors. 

WRI/WBCS

D 

1A Clinker Similar to IPCC Tier 2 w/CKD EF. 

WRI/WBCS

D 

1B Clinker Similar to WRI/WBCSD, 1A but w/default factors. 

WRI/WBCS

D 

2A Cement Site/corporate clinker/cement ratio. 

Not recommended; high uncertainty. 

WRI/WBCS

D 

2B Cement Same as WRI/WBCSD, 2A but w/default factors. 

CA AB32 Clinker Same as WRI/WBCSD, 1A. 

CCAR A Clinker Same as WRI/WBCSD, 1A. 

CCAR B Clinker Same as WRI/WBCSD, 1B. 

CCAR A Cement Same as WRI/WBCSD, 2A. 

CCAR B Cement Same as WRI/WBCSD, 2A, but w/more default factors. 

DOE A Clinker Uses clinker production w/site specific ratios of clinker 

content. 

DOE B Clinker Same as DOE, A but with default factors. 

DOE A Cement Same as WRI/WBCSD, 2A. 

DOE B Cement Same as WRI/WBCSD, 2A but w/default factors. 

DOE C Cement Not recommended; high uncertainty. Default factor x 

cement production. 

CL 1A Clinker Same as WRI/WBCSD, 1A but doesn’t report raw material 

emissions. 

CL 1B Clinker Same as WRI/WBCSD, 1B. 

CL 2A Cement Same as WRI/WBCSD, 2A. 

CL 2B Cement Same as WRI/WBCSD, 2A but w/default factors. 

CL 3 Carbonate Same as IPCC Tier 3. 

EU ETS A Carbonate Same as IPCC Tier 3, but w/more default factors. 

EU ETS B1 Clinker Same as WRI/WBCSD, 1A. 

EU ETS B2 Clinker Same as WRI/WBCSD, 1B. 

NM Clinker Same as WRI/WBCSD, 1A. 

TCR Clinker Same as WRI/WBCSD, 1A but doesn’t report raw material 

emissions. 

TCR Clinker Same as WRI/WBCSD, 1B. 

TCR Carbonate Same as IPCC Tier 3. 

Protocols and 

programs 

created after 

GHGRP 

No new calculation methods identified. 

1

 IPCC = Intergovernmental Panel on Climate Change, 2006; U.S. Inv = U.S. National Inventory Report, 2008 Method; WRI/WBCSD = World Resources 

Institute/World Business Council for Sustainable Development; CA AB32 = CA Mandatory Reporting Program; CCAR = California Climate Action Registry; 

DOE = Department of Energy’s 1605 (b) Voluntary Reporting Program; CL = EPA Climate Leaders; EU ETS = European Union Emission Trading System; NM = 

New Mexico Mandatory GHG Reporting Program; TCR = The Climate Registry. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

31 

2

 Cement method relies on information about the composition and quantity of raw materials consumed, the quantity of clinker incorporated into the cement, and the 

quantity of cement produced. It calculates CO2 emissions based on the amount of raw materials and their carbonate content. This approach directs companies to 

collect data on cement production, the raw material ratio to produce clinker and the CaCO3 equivalent content of the raw materials, thus allowing companies to 

monitor changes in emissions due to modifying the cement manufacturing process. 

Clinker Production-Based method is a mass balance approach based on the quantity of clinker produced. It calculates CO2 emissions based on the volume and 

composition of clinker produced as well as the amount of cement kiln dust (CKD) not recycled to the kiln. This approach has become an industry standard due to 

all companies knowing clinker production and the CaO/MgO content data. 

Carbonate Input Approach method is based on the collection of disaggregated data on the types (compositions) and quantities of carbonate(s) consumed to produce 

clinker, as well as the respective emission factor(s) of the carbonate(s) consumed. It includes an adjustment to subtract any uncalcined carbonate within CKD not 

returned to the kiln. 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

32 

Appendix A2. Subpart K – Evaluation of Alternative Calculation Equations 

Alternative Analysis 

Methods in the Call 

for Information 

Source1

 ID Description 

Dow 

Corning 

1 Same as current method for CO2, except excludes from the mass balance 

inputs contributing less than 5% of plant wide emissions. This exclusion is 

allowed in Subpart K if <1% of total mass of carbon in or out. Method still 

requires using “inputs to equations” data elements which were identified as 

having disclosure concerns in Step 2 of the analysis. Small reduction in 

burden and negligible reduction in accuracy. 

Dow 

Corning 

2 Same as current method for CO2, except with more flexibility in how carbon 

content is reported (e.g., supplier, independent laboratory, IPCC). Still uses 

mass of each process input and process outputs which were identified as 

having disclosure concerns in Step 2 of the analysis.. Unknown reduction in 

accuracy. 

Methods previously 

considered but not 

adopted in final 

GHGRP 

IPCC CO2 Tier 

1 

Uses mass of process outputs (product and nonproduct) and productionbased emission factors. Still uses production data which was identified as 

having disclosure concerns in Step 2 of the analysis. Method decreases 

accuracy of estimates 25-50%. 

IPCC CO2 Tier 

2 

Similar to current method but uses default emission factors instead of 

facility specific carbon content. Still uses mass of each process input which 

was identified as having disclosure concerns in Step 2 of the analysis. 

Methods use of defaults decreases accuracy of estimates by 15-40%. 

ANGGR

P 

 Uses quantity of carbon material, energy content of carbon material, and 

emission factor based on energy content. Use of default factors would 

decrease accuracy of estimates by 15-40%. Use of facility specific factors 

would be similar to current method. Still requires knowing carbon content of 

materials and amount of materials which was identified as having disclosure 

concerns in Step 2 of the analysis. . 

U.S. Inv Same as IPCC CO2 Tier 1. 

IPCC CH4 Tier 

1 

Use mass of product and generic production-based emission factors. Still 

uses production data which was identified as having disclosure concerns in 

Step 2 of the analysis. Method decreases accuracy of estimates by 40%. 

Protocols and 

programs created 

after GHGRP 

No programs were identified. 

1

 IPCC = Intergovernmental Panel on Climate Change, 2006; Dow Corning – Comments submitted under Call for Information (DCN: EPA-HQ-OAR-2008-0508-

0562); ANGGRP = Australian National Government Greenhouse and Energy Reporting Program; U.S. Inv = U.S. EPA Inventory for Greenhouse Gas Emissions 

and Sinks. 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

33 

Appendix A2. Subpart L – Evaluation of Alternative Calculation Equations 

Alternative Analysis 

Methods in the 

Call for 

Information 

No calculation methods identified. 

Methods 

previously 

considered but 

not adopted in 

final GHGRP 

Sourc

e

1

ID Method 

Type 

Description 

IPCC Tier 1 Default 

emission 

factor and 

production 

data 

Uses default F-gas generation factor and mass of F-gas produced. 

High uncertainty due to emission variability (0.8 to 2% of 

production).  

IPCC Tier 3A Direct process 

measurement 

Uses frequent or continuous measurement of the concentration and 

flow-rate (i.e., CEMS) from the vents at an individual plant to 

obtain instantaneous F-gas emission rate. Total quantity of F-gas 

released is the annual sum of measured instantaneous releases. 

IPCC Tier 3B Parameter 

monitoring 

Uses process operating rate (e.g., feedstock flow rate, F-gas 

production rate) as proxy for F-gas emission rate. Still uses process 

data (e.g., feedstock flow rate, production rate) which were 

identified as having disclosure concerns in Step 2 of the analysis 

Protocols and 

programs 

created after 

GHGRP 

No new calculation methods identified. 

1

 IPCC = Intergovernmental Panel on Climate Change, 2006. 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

34 

Appendix A2. Subpart N – Evaluation of Alternative Calculation Equations 

The current calculation methodology is a modified version of IPCC Tier 3. Process CO2 emissions are 

calculated using a carbon mass balance for each continuous glass melting furnace. The equation is based on: 

mass fraction of carbonate mineral in each raw material, mass of carbonate raw material charged, default 

emission factor for carbonate-based raw material (shown in Table N-1 of the rule), and fraction of 

calcination achieved for each raw material. 

Alternative Analysis 

Methods in the 

Call for 

Information 

No calculation methods identified. 

Methods 

previously 

considered but 

not adopted in 

final GHGRP 

Source1

 ID Metho

d 

Type 

Description 

IPCC Tier 

1 

Output Uses a default emission factor based on typical raw material mixtures 

and total glass production data. Significant decrease in accuracy of 

emission estimates (60% from current method). 

IPCC Tier 

2 

Output Uses default emission factors and cullet ratios, and production 

information for specific types of glass produced. Accuracy of emission 

estimates decreases by 10% from current method. 

IPCC Tier 

3 

Input Similar to current method. Does not limit calculation to mass fraction 

of carbonate-based mineral in carbonate-based raw material. Resulting 

estimates will be higher than current method. Still uses “inputs to 

equations” data elements which were identified as having disclosure 

concerns in Step 2 of the analysis. . 

U.S Inv Output Similar to IPC C Tier 1 and 2. Uses default carbon weight fractions for 

each raw material charged which were identified as having disclosure 

concerns in Step 2 of the analysis. . 

DOE Input Same as IPCC Tier 3. Still uses “inputs to equations” data elements 

which were identified as having disclosure concerns in Step 2 of the 

analysis. . 

ANMGGR

P 

D Input Similar to IPCC Tier 3. Uses different calcination fraction. Still uses 

“inputs to equations” data elements which were identified as having 

disclosure concerns in Step 2 of the analysis. . 

ANMGGR

P 

H Input Same as IPCC Tier 3. Still uses “inputs to equations” data elements 

which were identified as having disclosure concerns in Step 2 of the 

analysis. 

EU ETS A Input Same as IPCC Tier 3. Still uses “inputs to equations” data elements 

which were identified as having disclosure concerns in Step 2 of the 

analysis.. 

EU ETS B Input Similar to IPCC Tier 3. Uses default fraction of calcination for 

carbonate-based raw material. Still uses “inputs to equations” data 

elements which were identified as having disclosure concerns in Step 2 

of the analysis. 

EB Input Same as IPCC Tier 3. Still uses “inputs to equations” data elements. 

Protocols and 

programs 

created after 

GHGRP 

No new calculation methods identified. 

1

 IPCC = Intergovernmental Panel on Climate Change, 2006; U.S. Inv = U.S. National Inventory Report, 2008 Method; DOE = Department of Energy’s 1605 (b) 

Voluntary Reporting Program; EU ETS = European Union Emission Trading System; ANMGGRP = Australian National Mandatory Greenhouse Gas Reporting 

Program; EB = European Bank for Reconstruction and Development. 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

35 

Appendix A2. Subpart O – Evaluation of Alternative Calculation Equations 

Alternative Analysis 

Methods in 

the Call for 

Information 

No calculation methods identified. 

Methods 

previously 

considered 

but not 

adopted in 

final 

GHGRP 

Source 1

ID Description 

IPCC Tier 

1 

Uses default HFC-23 generation factor and mass of HCFC-22 produced. For control devices, 

uses estimated destruction efficiency. Still requires production data which was identified as 

having disclosure concerns in Step 2 of the analysis. Higher uncertainty in emissions than 

the current method due to default factor (using a default emission factor of 4 percent yields 

50 percent uncertainty). 

IPCC Tier 

2 

Uses site-specific HFC-23 generation factor (based on records of carbon and fluorine 

efficiencies), mass of HCFC-22 produced, and data on fraction of year process vent stream 

was released untreated which were identified as having disclosure concerns in Step 2 of the 

analysis.. Uncertainty varies according to sampling frequency (daily sampling yields 1 – 2 

percent uncertainty). 

IPCC Tier 

3A 

Simplified version of current method (uses concentration of HFC-23 in the gas vented from 

process, mass flow of process stream, mass flow of HFC-23/other product stream, and 

fraction HFC-23 in HCFC-22/other stream.) Methods allow continuous and less frequent 

monitoring. Still requires 2015 input data which were identified as having disclosure 

concerns in Step 2 of the analysis. Uncertainty due to measurement frequency (current 

method requires weekly) and exclusion of HFC-23 destroyed offsite, sold, and stored. 

IPCC Tier 

3B 

Uses process operating rate as proxy for HFC-23 emitted. Still uses two current “inputs to 

equations” data elements (i.e., fraction HFC-23 in HCFC-22/other stream and mass flow of 

HFC-23/other product stream) which were identified as having disclosure concerns in Step 2 

of the analysis 

U.S. 

Inv 

 Same as IPCC Tier 3B. 

WRI/W

BCSD 

2 Similar to IPCC Tier 3A. Accounts for onsite HFC-23 destruction (fraction abated and 

control utilization data) 

WRI/W

BCSD 

3 Similar to IPCC Tier 3A. WRI method uses default factors for the loss in production 

efficiency of HCFC-22, carbon and fluorine content factors, and carbon and fluorine balance 

efficiencies. 

WRI/W

BCSD 

4 Same as IPCC Tier 1. 

DOE Similar to IPCC Tier 3A. Accounts for onsite HFC-23 destruction (fraction abated and 

control utilization data) 

TCR Tier 

B 

Similar to IPCC Tier 2. 

TCR Tier 

C 

Similar to IPCC Tier 1. TCR method accounts for HFC-23 destroyed by collecting fraction 

abated and control device utilization data. 

Protocols 

and 

programs 

created 

after 

GHGRP 

No new calculation methods identified. 

1

 IPCC = 2006 Guidelines for National Greenhouse Gas Inventories; U.S. Inv = U.S. National Inventory Report 2008 Method (U.S. Inventory of Greenhouse Gas 

Emissions and Sinks 1990-2006); WRI/WBCSD = World Resources Institute & World Business Council for Sustainable Development. Greenhouse Gas Protocol: 

HCFC-22 Emissions from Production of HCFC-22, Version 2.0. December 2007; DOE = Department of Energy’s 1605(b) Voluntary Reporting Program; TCR = 

The Climate Registry.

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

36 

Appendix A2. Subpart P – Evaluation of Alternative Calculation Equations 

Alternative Analysis 

Methods in the 

Call for 

Information 

Commenter 1

Description 

ACC Calculate emissions using aggregated fuel and feedstock consumption data to obscure specific 

information. Method would still require monthly analyses of carbon content for each fuel and 

feedstock which were identified as having disclosure concerns in Step 2 of the analysis.. 

Method is less accurate than current method. 

ACC Calculate emissions on a carbon feed basis and not require disaggregation of fuel/feedstock by 

type. Insufficient information or analysis provided to assess the accuracy of the methodology. 

Method would not reveal any of the “inputs to equations” data elements that were identified 

as having disclosure concerns in Step 2 of the analysis, but would require new calculation 

algorithms. 

Methods 

previously 

considered but 

not adopted in 

final GHGRP 

Source1 ID Description 

EU ETS Tier 

1 

Uses default emission factor. Less accurate than current method. 

EU ETS Tier 

2 

Uses a facility specific emission factor calculated from carbon content of feed gas. 

Still requires composition information which was identified as having disclosure 

concerns in Step 2 of the analysis. More accurate than Tier 1 but less accurate than 

current method. 

DOE A Based on fuel burned and the ratio of CO2 to fuel determined from fuel analysis. Still 

requires fuel input and composition information which were identified as having 

disclosure concerns in Step 2 of the analysis. 

DOE B Uses default emission factors based on fuel. Less accurate than the current method 

and still requires fuel consumption information which were identified as having 

disclosure concerns in Step 2 of the analysis. 

API 1 Uses production rate and simplified stoichiometric ratios. Method requires reporting 

of data element determined to be in 76 FR 30782 (May 26, 2011). 

API 2 Uses a default emission factor and feedstock volume. Less accurate than current 

method and still requires feedstock information which was identified as having 

disclosure concerns in Step 2 of the analysis. 

CARB 1 Similar to current method, but only accounts for carbon in feedstock. Less 

comprehensive and accurate than the current method. 

IPCC Tier 

1 

Based on hydrogen production and facility specific proportionality factor. Less 

accurate than current method and still requires production information which was 

identified as having disclosure concerns in Step 2 of the analysis. 

Protocols and 

programs 

created after 

GHGRP 

CDM provides a different calculation methodology based on using biogas to displace LPG as a feedstock and 

fuel in a hydrogen production unit. Method is limited in use. Method has high accuracy and low uncertainty as 

the calculated emissions are related to a monetary value under CDM. 

1

 ACC = American Chemistry Council; IPCC = Intergovernmental Panel on Climate Change, 2006; DOE = Department of Energy; EU ETS = European Union 

Emission Trading System; API = American Petroleum Institute; CARB = California Air Resources Board; CDM = Clean Development Mechanism. 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

37 

Appendix A2. Subpart Q – Evaluation of Alternative Calculation Equations 

Alternative Analysis 

Methods in the 

Call for 

Information 

Two methods identified by Sierra Club are similar to methods previously considered but not adopted in the 

final GHGRP: (1) a simple mass balance assuming all the carbon input to the process converts to CO2; and 

(2) exclude small contributors from the mass balance for EAFs only. These are addressed in the following 

summary. 

Methods 

previously 

considered but 

not adopted in 

final GHGRP 

Source1

 ID Description 

CL Section 

2.2 

Exclude small contributors from mass balance (e.g., CL: slag out of an EAF 

furnace, DOE: APCD residue from a decarburization vessel). 

 Allowed under GHGRP if <1% of total mass of carbon in or out; concept also 

recommended by AISI. 

 Small reduction in burden and negligible reduction in accuracy. 

 Retains 2015 data elements which were identified as having disclosure 

concerns in Step 2 of the analysis. 

DOE Section 

1.E.4.1.6.

3 

IPCC Tier 1 Use production based emission factors instead of site-specific information and 

information on inputs. 

 Not comprehensive, i.e., IPCC listed only 5 of the 7 processes in GHGRP 

 Hides recipes/ingredients, but not production rate which was identified as 

having disclosure concerns in Step 2 of the analysis. 

 Decreases accuracy of estimates by 20%. 

AISI Fenceline 

principle 

Use input based emission factors instead of site-specific information and 

information on production. 

 Not comprehensive, e.g., excludes scrap to BOF or EAF and materials 

produced on-site like sinter. 

 Hides production rates, but not recipes/ingredients which was identified as 

having disclosure concerns in Step 2 of the analysis. 

 Decreases accuracy of estimates by 25%. 

IPCC Tier 2 Use default carbon weight fraction instead of carbon content of inputs and 

products. 

 Hides site specific carbon content, but still requires production rate and 

recipes/ingredients which were identified as having disclosure concerns in Step 

2 of the analysis.. 

 Preamble indicates analysis of carbon content is not burdensome. 

 IPCC claims accuracy decreases by 5%, but preamble indicates that use of 

defaults is more appropriate for a sector wide or national total. 

WRI/W

BSCD 

Tier 1 

CL All 

EU 

ETS 

ANNEX 

VI 

If mill is integrated; conduct a plant-wide CO2 mass balance (ignore movement of 

energy sources within plant boundaries) instead of by process. 

 Preamble indicates process level info is needed for verification and to identify 

reduction opportunities; so verification issues with option. 

 Composite totals are used. 

AISI Fenceline 

principle 

CL Section 

2.1 

DOE Section 

1.E.4.1.6.

5 

Protocols and 

programs 

created after 

GHGRP 

4 programs were identified. However, the methods used to calculate emissions are the same as the methods 

previously considered but not adopted in the final GHGRP or are identical to methods in the GHGRP. 

Therefore, no further analyses of these are presented in this table. The 4 programs are: 

 Australian Government – NGER technical guidelines, section 4.67 (similar to CL, section 2.2) 

 Australian Government – NGER technical guidelines, section 4.66 (similar to IPCC Tier 2) 

 UN, Framework on Climate Change – Clean Development Mechanisms; AMS-III.V.: Decrease 

of coke (similar to IPCC Tier 1) 

 CARB (same as GHGRP) 1

 IPCC = Intergovernmental Panel on Climate Change, 2006; WRI/WBCSD = World Resources Institute/World Business Council for Sustainable Development; 

DOE = Department of Energy; CL = EPA Climate Leaders; EU ETS = European Union Emission Trading System; AISI = American Iron and Steel Institute. 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

38 

Appendix A2. Subpart R – Evaluation of Alternative Calculation Equations 

Alternative Analysis 

Methods in the 

Call for 

Information 

The Association of Battery Recyclers suggested using default carbon content, rather than measured carbon 

content, for secondary lead smelters, as the feed material is predominantly used in lead-acid batteries. Using a 

default carbon content value would result in ±10% uncertainty compared to the current method. However, the 

annual mass of each carbon-containing material is the same type of information identified as having disclosure 

concerns in Step 2 of the analysis. 

Methods 

previously 

considered but 

not adopted in 

final GHGRP 

Source ID Description 

IPCC Tier 1 Uses default emission factor by production type (imperial smelting furnace, direct 

smelting furnace). Uses production data, which was identified as having disclosure 

concerns in Step 2 of the analysis, and results in a ±45% increase in uncertainty. 

IPCC Tier 2 Similar to IPCC Tier 1 except emission factors are based on country-specific 

information on the use of reducing agents, furnace types, and other process 

materials, and default carbon contents. Method is more accurate than IPCC Tier 1, 

but is less accurate than current method and also requires production information, 

which was identified as having disclosure concerns in Step 2 of the analysis.. 

Stack test Uses emissions data from a stack test to develop site-specific emission factors that 

is applied to the quantity of feed or product material. Appropriate for facilities 

where process inputs and operating parameters are consistent. This option was not 

adopted because of the potential for significant variation at smelters in the feed to 

the furnace and process operating parameters. 

U.S. Inv Same as IPCC Tier 1. 

ANMGGRP Similar to current method, but is based on energy content. Still requires 

information on quantity and carbon content of feed to smelter, which were 

identified as having disclosure concerns in Step 2 of the analysis.. 

Env Canada Use current method for metal ore and reducing agents charged to the furnace only. 

For any other non-fuel process input materials, use emission factors. This method 

would still require reporting of raw material and carbon content data for metal ore 

which were identified as having disclosure concerns in Step 2 of the analysis.. It 

would underestimate emissions, and has an unknown uncertainty compared to the 

current method. Would need to develop emission factors. 

Protocols and 

programs 

created after 

GHGRP 

No new calculation methods identified. 

1

 IPCC = Intergovernmental Panel on Climate Change, 2006; ANMGGRP = Australian National Mandatory Greenhouse Gas Reporting Program; Env Canada = 

Environment Canada; U.S. Inv = U.S .Inventory of Greenhouse Gases. 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

39 

Appendix A2. Subpart S – Evaluation of Alternative Calculation Equations 

Alternative Analysis 

Methods in the 

Call for 

Information 

None identified 

Methods 

previously 

considered but 

not adopted in 

final GHGRP 

Source1

 ID Method 

Type2

Description 

IPCC Tier 

1 

Output Uses default emission factors for each of the 3 types of lime produced. 

Still requires production information which was identified as having 

disclosure concerns in Step 2 of the analysis and has a high uncertainty. 

IPCC Tier 

2 

Output Uses default emission factors based on lime type correcting for the 

amount of calcined byproduct/waste produced. Still requires production 

information which was identified as having disclosure concerns in Step 

2 of the analysis and has a high uncertainty. 

IPCC Tier 

3 

Input Uses measured quantities of carbonate inputs to the kiln and emission 

factors and calcinations fractions to the carbonates consumed. Low 

uncertainty in emissions but requires feedstock information which was 

identified as having disclosure concerns in Step 2 of the analysis. 

U.S. Inv Output Same as IPCC Tier 2. 

WRI/ 

WBCSD 

1 Output Similar to IPCC Tier 2, but encourages more plant-specific data. 

WRI/ 

WBCSD 

2 Input Same as IPCC Tier 3. 

EU ETS 1A Mass 

balance 

Based on a carbonate mass balance and emission factor. Still requires 

composition and product information which were identified as having 

disclosure concerns in Step 2 of the analysis. 

EU ETS 1B Output Based on identifying MgO and CaO in the lime produced. Still requires 

composition and product information which were identified as having 

disclosure concerns in Step 2 of the analysis.. 

EU ETS 2A Input Based on carbonate input to kilns only. Has a higher uncertainty than 

IPCC Tier 3 and requires feedstock information which was identified as 

having disclosure concerns in Step 2 of the analysis.. 

EU ETS 2B Output Same as EU ETS 1B. 

TCR 1, 3 Input Same as IPCC Tier 3, allows plant-specific data. 

TCR 2, 4 Output Same as IPCC Tier 3, allows plant-specific data. 

Protocols and 

programs 

created after 

GHGRP 

This alternative is for a new methodology for producing lime. It is not widely used (or used at all) and not 

appropriate for consideration. The CDM provides a methodology for hydraulic lime production uses fossil fuel 

usage and electricity usage to estimate emissions. This method is for a new method of producing hydraulic lime 

for construction purposes by blending conventional hydraulic lime with alternative material additives. 1

 IPCC = Intergovernmental Panel on Climate Change, 2006; U.S. Inv = U.S. National Inventory Report, 2008 Method; WRI/WBCSD = World Resources 

Institute/World Business Council for Sustainable Development; EU ETS = European Union Emission Trading System; TCR = The Climate Registry; CDM = 

Clean Development Mechanism 

2

 Emissions calculated based on inputs to kiln, outputs from kiln, or mass balance of inputs and outputs. 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

40 

Appendix A2. Subpart U – Evaluation of Alternative Calculation Equations 

Alternative Analysis 

Methods in the 

Call for 

Information 

None identified. 

Methods 

previously 

considered but 

not adopted in 

final GHGRP 

Source1

 ID Description 

IPCC Tier 

1 

Uses emission factors based on the mass of carbonate consumed. Considers only 

limestone and dolomite are used and assigns default fraction partitioning the use of 

them. High uncertainty in emissions. Still requires knowing overall carbonate 

consumed which was identified as having disclosure concerns in Step 2 of the 

analysis. 

IPCC Tier 

2 

Same as Tier 1, except the fraction of limestone versus dolomite consumed is not a 

default value. More accurate than Tier 1, but still less accurate than current method 

and also requires using mass carbonates consumed by carbonate type, which was 

identified as having disclosure concerns in Step 2 of the analysis.. 

ANMGGRP Same as current method. 

Protocols and 

programs 

created after 

GHGRP 

None identified. 

1

 IPCC = Intergovernmental Panel on Climate Change, 2006; ANMGGRP = Australian National Mandatory Greenhouse Gas Reporting Program. 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

41 

Appendix A2. Subpart V – Evaluation of Alternative Calculation Equations 

Alternative Analysis 

Methods in the 

Call for 

Information 

None identified. 

Methods 

previously 

considered but 

not adopted in 

final GHGRP 

Source1

 ID Description 

IPCC Tier 

1 

Uses default emission factors and assumes no abatement. Facility level based 

rather than unit based. Still requires production information which was identified 

as having disclosure concerns in Step 2 of the analysis and has a high uncertainty 

in estimates. 

IPCC Tier 

2 

Similar to current method. Uses plant-level production data disaggregated by 

technology and default emission factors and destruction factors on a site-specific 

basis. Still requires using production information which was identified as having 

disclosure concerns in Step 2 of the analysis. 

WRI/WBCS

D 

2 Similar to IPCC Tier 2. 

WRI/WBCS

D 

3 Similar to IPCC Tier 1. 

U.S. INV Uses default factor for calculating N2O emissions. No inputs are used that had 

disclosure concerns identified in Step 2of the analysis, but accuracy is severely 

reduced and is more appropriate for national estimates. Facility level data are not 

collected. 

TCR Tier 

B 

Similar to IPCC Tier 2. 

DOE B Similar to IPCC Tier 2. 

DOE C Similar to IPCC Tier 2, except uses other published emission factors rather than 

IPCC for uncontrolled and non-selective catalytic reduction control technologies. 

Protocols and 

programs 

created after 

GHGRP 

None identified. 

1

 IPCC = Intergovernmental Panel on Climate Change, 2006; U.S. Inv = U.S. National Inventory Report, 2008 Method; WRI/WBCSD = World Resources 

Institute/World Business Council for Sustainable Development; DOE = Department of Energy; TCR = The Climate Registry. 

 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

42 

Appendix A2. Subpart X – Evaluation of Alternative Calculation Equations 

Alternative 

Analysis 

Source Method Description 

Methods in the 

Call for 

Information 

American 

Chemistry 

Council 

Gas 

composition 

meter 

Commenter suggested allowing the use of subpart PP methodologies, which 

require direct measurements using gas analyzers. 

 Quarterly monitoring is required 

 High accuracy due to source specific information 

Methods 

previously 

considered but 

not adopted in 

final GHGRP 

IPCC Tier 1 Emission 

factor 

Use default emission factors for CO2 and CH4 published by IPCC multiplied 

by the production of each product. 

 Still uses plant specific production rates, which were identified as having 

disclosure concerns in Step 2 of the analysis. 

 Low cost to implement 

 Level of uncertainty is high compared to current method (10-60% for 

CO2; 30-80% for CH4) 

 Default factors cannot reflect site-specific differences in characteristics 

such as the type of feedstock, operating conditions, etc. 

 More appropriate for sector wide estimates 

IPCC Tier 3, 

modified 

Direct 

measurements 

Requires routing of process vent emissions to stacks for direct and continuous 

measurements of CO2 emissions from each process stack (except flares) and 

each combustion source stack. 

 More costly 

 Mandates process configuration changes, which is not the intent of the 

GHGRP 

 Flare emissions based on emission factor 

 CH4 and N2O emissions from combustion sources would be calculated 

using subpart C procedures. 

 More accurate and less uncertainty than current option 

 Similar to IPCC Tier 3 approach, except IPCC indicates that process vent 

emissions may be either estimated or measured, and IPCC CH4 estimation 

methods for flares is more rigorous 

Protocols and 

programs 

created after 

GHGRP 

No new calculation methods identified. 

1

 IPCC = Intergovernmental Panel on Climate Change, 2006. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

43 

Appendix A2. Subpart Y – Evaluation of Alternative Calculation Equations 

Flares

Alternative 

Analysis 

Source Method Description 

Methods in the 

Call for 

Information 

No new calculation methods identified. 

Methods 

previously 

considered but 

not adopted in 

final GHGRP 

API, CARB, 

DOE, EU, 

and IPCC 

Default 

emission 

factors 

Use quantity of waste gas burned and default emission factors. Still uses plant 

specific production rates; according to Step 2 of the analysis, disclosure 

concerns were identified with this information. 

 Low cost to implement. 

 Level of uncertainty is higher compared to using measured carbon content 

or HHV data because the composition of waste gas sent to flares is known 

to vary considerably due to process upsets, maintenance activities, etc. 

However, the default emission factor approach is thought to be reasonably 

accurate during normal operation. 

 More appropriate for sector wide estimates. 

API Test data Uses vendor or facility test data to calculate CO2 and CH4 emissions (N2O are 

considered negligible by API). 

 More accurate than default emission factors; however, level of uncertainty 

is higher compared to using measured carbon content or HHV data 

because composition of waste gas sent to flares is known to vary 

considerably due to process upsets, maintenance activities, etc. 

Protocols and 

programs 

created after 

GHGRP 

No new calculation methods identified. 

1

 IPCC = Intergovernmental Panel on Climate Change, 2006; U.S. Inv = U.S. National Inventory Report, 2008 Method; WRI/WBCSD = World Resources 

Institute/World Business Council for Sustainable Development; EU ETS = European Union Emission Trading System; API = American Petroleum Institute; CARB 

= California Air Resources Board. 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

44 

Catalytic Cracking Units and Fluid Coking Units 

Alternative Analysis 

Methods in the Call for 

Information 

No new calculation methods identified. 

Methods previously considered 

but not adopted in final 

GHGRP 

The previously considered methods are included in part 98. However, larger units are not allowed 

to use emission factors to calculate CO2 emissions (allowed only for units with throughputs less 

than 10,000 bbls/stream day), the only input reported for larger units is the molar volume 

conversion factor. Small units can use mass balance, CEMS, or emission factors (either sitespecific or default). 

Protocols and programs created 

after GHGRP 

No new calculation methods identified. 

Sulfur Recovery 

Alternative Analysis 

Methods in the Call for 

Information 

No new calculation methods identified. 

Methods previously considered 

but not adopted in final 

GHGRP 

All of the previously considered methods are included in part 98. 

Protocols and programs created 

after GHGRP 

No new calculation methods identified. 

Coke Calcining 

Alternative Analysis 

Methods in the Call for 

Information 

No new calculation methods identified. 

Methods previously considered 

but not adopted in final 

GHGRP 

All of the previously considered methods are included in part 98. 

Protocols and programs created 

after GHGRP 

No new calculation methods identified. 

Asphalt Blowing 

Alternative 

Analysis 

Source Method Description 

Methods in the 

Call for 

Information 

No new calculation methods identified. 

Methods 

previously 

considered but 

not adopted in 

final GHGRP 

API and 

CARB 

Default 

emission 

factors 

Use quantity of asphalt blown and default emission factors for calculating the 

emissions of CO2 and CH4 from asphalt blowing operations. Part 98 

calculations methods for both controlled and uncontrolled asphalt blowing 

operations relies on site-specific emission factors from facility-specific test 

data (though default emission factors are also provided for facilities that do 

not have the necessary test data). 

 Still uses plant specific production rates, which was identified as having 

disclosure concerns in Step 2 of the analysis. 

 Low cost to implement 

 Level of uncertainty is higher compared to using the site-specific emission 

factor approach in the rule 

 Default factors cannot reflect site-specific differences in characteristics 

such as operating conditions, etc. 

 More appropriate for sector wide estimates 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

45 

Protocols and 

programs 

created after 

GHGRP 

No new calculation methods identified. 

1

 API = American Petroleum Institute; CARB = California Air Resources Board. 

Delayed Coking Units 

Alternative 

Analysis 

Source Method Description 

Methods in the 

Call for 

Information 

No new calculation methods identified. 

Methods 

previously 

considered but 

not adopted in 

final GHGRP 

EU ETS Mass balance No equation provided 

Protocols and 

programs 

created after 

GHGRP 

No new calculation methods identified. 

1 EU ETS = European Union Emission Trading System.

Process Vents 

Alternative Analysis 

Methods in the Call for 

Information 

No new calculation methods identified. 

Methods previously considered 

but not adopted in final 

GHGRP 

All of the previously considered methods are included in part 98. 

Protocols and programs created 

after GHGRP 

No new calculation methods identified. 

Blowdowns 

Alternative Analysis 

Methods in the Call for 

Information 

No new calculation methods identified. 

Methods previously considered 

but not adopted in final 

GHGRP 

All of the previously considered methods are included in part 98. 

Protocols and programs created 

after GHGRP 

No new calculation methods identified. 

Equipment Leaks 

Alternative 

Analysis 

Source Method Description 

Methods in the 

Call for 

Information 

No new calculation methods identified. 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

46 

Methods 

previously 

considered but 

not adopted in 

final GHGRP 

API Default 

emission factor 

Use default emission factors for amount of crude feedstock and default 

emission factors. 

 Still uses plant specific production rates, which was identified as having 

disclosure concerns in Step 2 of the analysis. 

 Low cost to implement 

 Level of uncertainty is high compared to the current methods 

 Default factors cannot reflect site-specific differences in characteristics 

such as operating conditions, effectiveness of LDAR programs, etc. 

 More appropriate for sector wide estimates 

Protocols and 

programs 

created after 

GHGRP 

UNFCCC Direct 

measurements 

Measure the flow rates of the physical leaks using Hi-Flow SamplersTM, 

calibrated bag, or other suitable flow measurements technology and calculate 

the emissions using the rate x time period of leaking. 

 More accurate and less uncertainty than current option. 

 More costly due to large number of components to monitor. 

 May not be practical to monitor some components due to safety and 

accessibility issues. 

 Data used to calculate emissions does not contain information 

determined to have disclosure concerns in Step 2 of the analysis. 1

 API = American Petroleum Institute; UNFCCC = United Nations Framework Convention on Climate Change 

Storage Tanks – Unstablized Crude Oil 

Alternative 

Analysis 

Source Method Description 

Methods in the 

Call for 

Information 

No new calculation methods identified. 

Methods 

previously 

considered but not 

adopted in final 

GHGRP 

API Default 

emission factor 

Use default emission factors for CH4 published by API multiplied by the 

quantity of crude oil. 

 Still uses the amount of unstabilized crude delivered, which was 

identified as having disclosure concerns in Step 2 of the analysis. 

 Low cost to implement 

 Level of uncertainty is unknown but would likely be high compared to 

current methods 

 Default factors cannot reflect site-specific differences in characteristics 

such as the type of crude, operating conditions, etc. 

 More appropriate for sector wide estimates 

API API E&P 

TANKS 

program 

API E&P TANKS program, which uses pressure differential, API gravity, 

Reid vapor pressure, composition of the crude oil, and crude oil throughput. 

 Less accurate than current options 

 Would still require site specific information on methane composition 

data and quantity of unstabilized crude oil received, which was identified 

as having disclosure concerns in Step 2 of the analysis. 

API Correlation 

equations 

Similar to one of the current methods. API recommends the Vasquez-Beggs 

Equation, standing correlation, or EUB rule of thumb. 

 No information regarding accuracy provided. 

 Would still require site specific information on methane composition 

data and quantity of unstabilized crude oil received, which was identified 

as having disclosure concerns in Step 2 of the analysis. 

API Other process 

simulators 

No specific method provided. 

Protocols and 

programs created 

after GHGRP 

No new calculation methods identified. 

1

 API = American Petroleum Institute.
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

47 

Storage Tanks – Products Other than Unstabilized Crude Oil 

Alternative Analysis 

Methods in the Call for 

Information 

No new calculation methods identified. 

Methods previously considered 

but not adopted in final GHGRP 

All of the previously considered methods are included in part 98. 

Protocols and programs created 

after GHGRP 

No new calculation methods identified. 

Crude Oil, Intermediate, and Product Loading Operations 

Alternative Analysis 

Methods in the Call for 

Information 

No new calculation methods identified. 

Methods previously considered 

but not adopted in final GHGRP 

All of the previously considered methods are included in part 98. 

Protocols and programs created 

after GHGRP 

No new calculation methods identified. 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

48 

Appendix A2. Subpart Z – Evaluation of Alternative Calculation Equations 

Alternative Analysis 

Methods in the 

Call for 

Information 

None identified. 

Methods 

previously 

considered but 

not adopted in 

final GHGRP 

Source1

 ID Description 

U.S. Inv Option 1 Uses default factors based on regional chemical composition of phosphate rock. 

Less accurate than current method, but still requires monthly phosphate rock 

consumption, which was identified as having disclosure concerns in Step 2 of the 

analysis. 

Protocols and 

programs 

created after 

GHGRP 

None identified. 

1

 U.S. Inv = U.S. Greenhouse Gas Emissions and Sinks: 1990-2006. USEPA 430-R-08-005. 

 
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49 

Appendix A2. Subpart AA – Evaluation of Alternative Calculation Equations 

Alternative Analysis 

Methods in the 

Call for 

Information 

No calculation methods identified. 

Methods 

previously 

considered but 

not adopted in 

final GHGRP 

Emission 

Source 

Data Source Method 

Type2

Description 

 No alternative calculation methodologies identified for makeup chemicals. 

 All other emissions are from combustion sources. 

 Emissions from power boilers are based on fossil fuel information and the calculation methodology in 

subpart C is referenced. No alternative methodologies were reviewed for these sources as they will be 

covered under the subpart C analysis. 

 Subpart AA requires reporting of fossil fuel and biogenic emissions from recovery furnaces and lime kilns. 

The fossil fuel component of the emissions are calculated using methods in subpart C. Biogenic emissions 

are not calculated from lime kilns, as the emissions are accounted for in the recovery furnace calculations. 

Alternative calculation methodologies for the biogenic component in recovery furnaces are presented 

below. 

Recovery 

furnace 

GHG TSD Emission 

factor 

Method would allow use of default values for HHV for 

calculating emissions from kraft or soda recovery furnaces 

instead of site-specific data. 

 Has high uncertainty and lower accuracy. 

 Still requires black liquor solids federates as an input 

which was identified as having disclosure concerns in 

Step 2 of the analysis. 

 Dismissed at proposal because most facilities already 

analyze for HHV. 

 Not applicable to sulfite or stand-alone semi-chemical 

facilities. 

Recovery 

furnace 

operations 

WRI/WBCSDI

/ICFPA/NCAS

I spreadsheet 

Emission 

factor 

Calculates total GHG emissions from a facility based on total 

energy of spent liquor combusted on lower heating value 

basis. 

 High uncertainty in emissions. 

 Difficult to verify results because no emissions per 

equipment. 

Protocols and 

programs 

created after 

GHGRP 

CARB program refers to Subpart AA for calculations. 

1

 GHG TSD = GHG technical support documents ; WRI/WBCSD = World Resources Institute/World Business Council for Sustainable Development; 

ICFPA/NCASI = International Council on Forest and Paper Association/National Council for Air and Stream Improvement; CARB = California Air Resources 

Board. 

 
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50 

Appendix A2. Subpart BB – Evaluation of Alternative Calculation Equations 

Alternative Analysis 

Methods in the 

Call for 

Information 

None identified. 

Methods 

previously 

considered but 

not adopted in 

final GHGRP 

Source1 ID Description 

IPCC Tier 1 Output based approach (using production information) and using default CO2 and 

CH4 emission factors from the 2006 IPCC guidelines, and silicon carbide output. 

Uncertainty estimated to 10%. Requires production as an input to the emissions 

calculation, which was identified as having disclosure concerns in Step 2 of the 

analysis. 

IPCC Tier 1 Input based approach (using feedstock information) using default CO2 and CH4

emission factors from the 2006 IPCC guidelines, and petroleum coke input. 

Uncertainty estimated to be 10% and still requires same inputs as current method 

which were identified as having disclosure concerns in Step 2 of the analysis.. 

Protocols and 

programs 

created after 

GHGRP 

None identified. 

1

 IPCC = Intergovernmental Panel on Climate Change, 2006. 

 
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51 

Appendix A2. Subpart CC – Evaluation of Alternative Calculation Equations 

Alternative Analysis 

Methods in the 

Call for 

Information 

None identified. 

Methods 

previously 

considered but 

not adopted in 

final GHGRP 

Source1

 ID Description 

IPCC Tier 2D Use default factors. Slight decrease in accuracy, but quantity of trona used or soda 

ash produced is still an input, which were identified as having disclosure concerns 

in Step 2 of the analysis. 

IPCC Tier 2S Uses an annual site-specific emission factor to estimate emissions. Annual stack test 

information may not capture variability in emissions associated with consumption 

of various fuels. Still requires quantity of trona used or soda ash produced as an 

input, which were identified as having disclosure concerns in Step 2 of the analysis. 

Protocols and 

programs 

created after 

GHGRP 

None identified. 

1

 IPCC = Intergovernmental Panel on Climate Change, 2006. 

 
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52 

Appendix A2. Subpart EE – Evaluation of Alternative Calculation Equations 

Alternative Analysis 

Methods in the 

Call for 

Information 

None identified. 

Methods 

previously 

considered but 

not adopted in 

final GHGRP 

Source1

 ID Description 

IPCC Tier 1 Uses default emission factor and production information, which was identified as 

having disclosure concerns in Step 2 of the analysis.. Uncertainty is estimated to 

be 15%. 

ANMGGRP Uses default energy content and 2 default emission factors in combination with 

the total tonnage of the carbon reducing agent. Higher emissions uncertainty 

because default factors are used. 

Protocols and 

programs 

created after 

GHGRP 

None identified. 

1

 IPCC = Intergovernmental Panel on Climate Change, 2006; ANMGGRP = Australian National Mandatory Greenhouse Gas Reporting Program. 

 
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53 

Appendix A2. Subpart GG – Evaluation of Alternative Calculation Equations 

Alternative Analysis 

Methods in the 

Call for 

Information 

None identified. 

Methods 

previously 

considered but 

not adopted in 

final GHGRP 

Source1

 ID Description 

IPCC Tier 

1 

Uses default emission factor per unit of output and national productivity data. Has a 

high uncertainty. More appropriate for aggregated process information on a sectorwide or nationwide basis. If applied on a facility basis, would require production 

data which was identified as having disclosure concerns in Step 2 of the analysis.. 

IPCC Tier 

1a 

Same as Tier 1, but uses default emission factor specific to production processes. 

Better uncertainty, but still more appropriate for sector-wide or nationwide basis. If 

applied on a facility basis, would require production data which was identified as 

having disclosure concerns in Step 2 of the analysis.. 

IPCC Tier 

2 

Similar to Tier 1, but accounts for reducing agents, furnaces, and other process 

materials that affect emissions using emission factors based on aggregated plant 

statistics. More accurate than Tier 1 but would require production data which was 

identified as having disclosure concerns in Step 2 of the analysis.. Uncertainty is 

estimated to be 15%. 

U.S. Inv Uses default emission factors. High uncertainty in emission estimates. More 

appropriate for aggregated process information on a sector-wide or nationwide 

basis. 

ANGGRP Estimated based on the quantity of each carbon reductant used in production, the 

energy content of the reduction and a default fuel emission factor. The basic method 

has a high uncertainty in results. 

Protocols and 

programs 

created after 

GHGRP 

None identified. 

1

 IPCC = Intergovernmental Panel on Climate Change, 2006; U.S. Inv = U.S. National Inventory Report, 2008 Method; ANGGRP = Australian National 

Government Greenhouse and Energy Reporting Program. 

 
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54 

Appendix A2. Subpart TT – Evaluation of Alternative Calculation Equations 

Alternative Analysis 

Methods in 

the Call for 

Information 

None identified. 

Methods 

previously 

considered 

but not 

adopted in 

final 

GHGRP 

Source1

 ID Description 

U.S. Inv Reporters use the existing part 98 CH4 calculation methodology. Higher uncertainty in 

emissions than the current method due to default factor. Still requires reporting of “inputs to 

equations” data elements that were identified as having disclosure concerns in Step 2 

of the analysis. 

Protocols 

and 

programs 

created after 

GHGRP 

None identified. 

1

 U.S. Inv = U.S. National Inventory Report 2008 Method (U.S. Inventory of Greenhouse Gas Emissions and Sinks 1990-2006). 

 
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55 

Appendix B 

Summary of CEMS Characterization for Each Subpart with Inputs to Equations
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56 

Appendix B. General Stationary Fuel Combustion Sources – Subpart C

Industry Background

Stationary fuel combustion comprises many sources, including boilers, heaters, engines, 

furnaces, kilns, ovens, flares, incinerators, dryers, and any other equipment or machinery that 

burns fuel. From two regulatory databases, counts for certain sources are available: there are 

14,142 industrial, commercial, and institutional boilers and 55 CISWI units. Based on 2011 

annual report submissions, there were 1,985 facilities that reported to GHGRP under subpart C. 

Under subpart C, sources must provide emission estimates for CO2, CH4, and N2O for each 

combustion unit. Emissions must be reported separately for each type of fuel combusted. Sources 

may use emission factors, annual fuel usage data, and in some subparts use CEMS to calculate 

emissions. 

Applicable NSPS and NESHAP for Combustion Sources

Table C-1. Applicable NESHAP and NSPS Rules 

NESHAP/NSPS Subparts Reviewed Monitoring Required 

by the NESHAP or 

NSPS 

Would 

Monitoring 

Equipment 

Relevant to Part 

98 be Installed to 

Comply With 

NESHAP or 

NSPS? 

Were Data on 

CEMS Counts 

Available in 

NESHAP or 

NSPS docket? 

Subpart DDDDD - Boiler MACT PM CEMS 

Yes Yes 

Subpart Db - Boiler NSPS PM, NOX, SO2 CEMS 

Yes Yes 

Subparts CCCC and DDDD - CISWI NSPS 

and Emissions Guidelines 

PM, NOX, SO2 CEMS 

Yes Yes 

As shown in Table C-1, multiple CEMS are required for boilers and incinerators. The installation 

of this equipment is directly relatable to the installation of a GHG CEMS; all major equipment 

would already be installed and only the GHG CEMS analyzer would be necessary. 

Summary of Available Data on Facilities Reporting the Use of CEMS

Non-GHG CEMS data for subpart C facilities were available in two databases compiled for 

rulemaking purposes - the Boiler MACT database and CISWI database. These databases showed 

what CEMS were installed at the unit level. This included CEMS for PM, CO, NOX, and SO2. 

Table C-2 provides the total number of units which have at least one CEMS installed. In 

addition, with new requirements in the Boiler MACT, there are an additional 95 units which 

would install a CEMS; this value is also shown in Table C-2. There were 177 facilities that 

reported under the GHGRP using a total of 311 CO2 CEMS. 

 
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57 

Table C-2. CEMS Data from GHGRP and Regulatory databases 

Boiler MACT Boiler MACT CISWI NSPS GHGRP 

Total Boiler Count/Count 

of Boilers with non-GHG 

CEMS 

Count of Additional 

Boilers Installing nonGHG CEMS to 

Comply 

Total Incinerator 

Count/Count of 

Incinerators with nonGHG CEMS 

Count of Facilities with 

CO2 CEMS/Total 

Count of CO2 CEMS 

14,142/1025 95 55/31 177/311 

 Subpart C CEMS Count

Table C-3 summarizes the actual data collected for facilities using CO2 CEMS, non-CO2 GHG 

CEMS, and non-GHG CEMS. The potential count for non-GHG CEMS is based on the 95 

facilities which would install CEMS after finalization of the Boiler MACT. 

Table C-3. Subpart C CEMS Counts 

Basis CO2 CEMS for 

GHGRP 

Reporting non-CO2

GHG CEMS for 

GHGRP 

Reporting non-GHG CEMS for 

Other EPA Programs 

Actual 

Facilities 177a

 NA - 

Units 311b

 NA 1,056 

NA = No information available. 

a Number of facilities reporting to GHGRP in 2011 that they are using a CEMS to report CO2 emissions. 

b

 The total number of CO2 CEMS at the facilities which reported CO2 CEMS. 

. 
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58 

Appendix B. Adipic Acid Production – Subpart E

Industry Background

Based on 2011 annual report submissions, there were 3 facilities that reported to GHGRP under 

subpart E. 

Under subpart E, facilities estimate N2O process emissions from all adipic acid production units 

combined. For N2O emissions, facilities may either use a site-specific emission factor applied to 

the annual adipic acid production, or directly measure the emissions using an EPA-approved 

alternative method to the site-specific emission factor. 

Applicable NSPS and NESHAP for Adipic Acid Plants

Table E-1. Applicable NESHAP and NSPS Rules 

NESHAP/NSPS Subparts Reviewed Monitoring Required 

by the NESHAP or 

NSPS 

Would 

Monitoring 

Equipment 

Relevant to Part 

98 be Installed to 

Comply With 

NESHAP or 

NSPS? 

Were Data on 

CEMS Counts 

Available in 

NESHAP or 

NSPS docket? 

Subpart NNN—NSPS for VOC Emissions 

From Synthetic Organic Chemical 

Manufacturing Industry (SOCMI) Distillation 

Operations 

If facility complies with 

TRE limit (>1 and not 

using VOC control 

device) and have an 

absorber, condenser, or 

carbon adsorber then 

organic monitoring is 

option 

Yes No 

Subpart RRR—NSPS for VOC Emissions 

From Synthetic Organic Chemical 

Manufacturing Industry (SOCMI) Reactor 

Processes 

If facility complies with 

TRE limit (>1 and not 

using VOC control 

device) and have an 

absorber, condenser, or 

carbon adsorber then 

organic monitoring is 

option 

Yes No 

The relevant monitoring from both the NESHAP and NSPS is organic monitoring. An organic 

monitoring device is used to indicate the concentration level of organic compounds exiting the 

recovery device based on a detection principle such as infra-red, photoionization, or thermal 

conductivity and each is equipped with a continuous recorder. Although the organic monitoring 

would have CEMS related equipment installed, it is only an option and is dependent on the 

method of compliance and control device; it is unlikely that facilities will use this method of 

compliance due to cost, and would likely use other options instead (e.g., temperature 

monitoring). Due to the amount of unknown variables, for this analysis it was assumed that no 

equipment is installed which would facilitate the installation of GHG CEMS. 

 
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59 

Summary of Available Data on Facilities Reporting the Use of CEMS

No facility counts for the use of CO2 CEMS were reported through GHGRP. Subpart E facilities 

may also use an N2O CEMS alternative monitoring option provided approval is granted. 

Subpart E CEMS Count

Table E-2 summarizes the actual data collected for facilities using N2O CEMS and non-GHG 

CEMS. No facilities were identified with pre-existing N2O CEMS and CO2 CEMS are not 

required for this subpart. No assumption could be made for a potential count based on lack of 

information on control devices. 

Table E-2. Subpart E CEMS Counts 

Basis CO2 CEMS for the 

GHGRP 

Reporting non-CO2

GHG CEMS for the 

GHGRP 

Reporting non-GHG CEMS for 

Other EPA Programs 

Actual Potentiala

Facilities NA NA NA NA 

Units NA NA NA NA 

NA = No information available. 

a

Potential facilities or process units that may have equipment installed that could be modified for use in the GHGRP.
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60 

Appendix B. Aluminum Production – Subpart F

Industry Background

Based on 2011 annual report submissions, there were 10 facilities that reported to GHGRP under 

subpart F. 

Under subpart F, facilities estimate CF4 and C2F6 process emissions from anode effects in all 

prebake and Søderberg electrolysis cells combined. Facilities also estimate CO2 emissions from 

anode consumption and on-site anode baking. For CF4 emissions, facilities must calculate the 

emissions using a mass balance approach. Emissions of C2F6 must be calculated from the CF4

emissions using a tested ratio of C2F6 to CF4 production. For CO2 emissions, facilities may either 

use a mass balance approach for separate process and combustion emissions, or use a CEMS to 

determine combined process and combustion emissions. 

Applicable NSPS and NESHAP for Aluminum Plants

Table F-1. Applicable NESHAP and NSPS Rules 

NESHAP/NSPS Subparts 

Reviewed 

Monitoring Required 

by the NESHAP or 

NSPS 

Would Monitoring 

Equipment Relevant to 

Part 98 be Installed to 

Comply With NESHAP 

or NSPS? 

Were Data on 

CEMS Counts 

Available in 

NESHAP or 

NSPS docket? 

Subpart S—NSPS for Primary 

Aluminum Reduction Plants 

(No relevant monitoring 

requirements) No No 

Subpart LL—NESHAP for Primary 

Aluminum Reduction Plants 

(No relevant monitoring 

requirements) No No 

The applicable NESHAP and NSPS for this subpart do not require monitoring which is related to 

CEMS equipment and would thus not facilitate the installation of GHG CEMS. 

Summary of Available Data on Facilities Reporting the Use of CEMS

No data on CEMS usage in other EPA programs that would be applicable to subpart F facilities 

were available. A majority of the control devices used to comply with the NESHAP are 

scrubbers which do not typically require monitoring relevant to CEMS. No facility counts for use 

of CO2 CEMS were reported to the GHGRP. 

Subpart F CEMS Count

Table F-2 summarizes the actual data collected for facilities using CO2 CEMS, non-CO2 GHG 

CEMS, and non-GHG CEMS. No facilities were identified with pre-existing CEMS. No 

assumption could be made for a potential count based on lack of information on control devices. 

 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

61 

Table F-2. Subpart F CEMS Counts 

Basis CO2 CEMS for 

GHGRP 

Reporting non-CO2

GHG CEMS for 

GHGRP 

Reporting non-GHG CEMS for 

Other EPA Programs 

Actual Potentiala

Facilities NA NA NA NA 

Units NA NA NA NA 

NA = No information available. 

a

Potential facilities or process units that may have equipment installed that could be modified for use in the GHGRP.

 
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62 

Appendix B. Ammonia Manufacturing – Subpart G

Industry Background

Based on 2011 annual report submissions, there were 22 facilities that reported to GHGRP under 

subpart G. 

Under subpart G, facilities estimate CO2 process emissions from each ammonia manufacturing 

unit, and CO2 emissions collected and either used on-site or transferred off-site following the 

requirements of subpart PP (CO2 suppliers). For estimating CO2 process emissions, facilities may 

either use a mass balance approach or use a CEMS. 

Applicable NSPS and NESHAP for Ammonia Manufacturers

There is no NSPS or NESHAP specifically applicable to ammonia manufacturers. 

Summary of Available Data on Facilities Reporting the Use of CEMS 

No data on CEMS counts applicable to subpart G facilities were available. 

Subpart G CEMS Count

Table G-1 summarizes the actual data collected for facilities using CO2 CEMS, non-CO2 GHG 

CEMS, and non-GHG CEMS. No facilities were identified with pre-existing CO2 CEMS. No 

assumption could be made for a potential count based on lack of information on control devices 

and monitoring requirements. 

Table G-1. Subpart G CEMS Counts 

Basis CO2 CEMS for 

GHGRP 

Reporting non-CO2

GHG CEMS for 

GHGRP 

Reporting non-GHG CEMS for 

Other EPA Programs 

Actual Potentiala

Facilities NA NA NA NA 

Units NA NA NA NA 

NA = No information available. 

a

Potential facilities or process units that may have equipment installed that could be modified for use in the GHGRP.

 
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63 

Appendix B. Cement Production – Subpart H

Industry Background

The Portland Cement Association’s 2004 plant level summary included 107 integrated cement plants that 

house both kilns for producing clinker and mills for grinding cement from clinker. This latter number 

excludes plants that only grind clinker and do not have kilns. The ‘Summary of Environmental and Cost 

Impacts for Final Portland Cement NESHAP and NSPS’ (August 6, 2010) estimates there are 100 plants 

with 140 kilns. Based on 2011 annual report submissions, there were 96 facilities that reported to GHGRP 

under subpart H. These counts are used for the total facility and total unit counts (96 plants with 140 

kilns). 

Under subpart H, facilities estimate CO2 process emissions from calcination in each kiln and CO2

combustion emissions from each kiln. They are also required to estimate and report CH4 and N2O 

combustion emissions from each kiln. For CO2 emissions, facilities may either use a mass balance 

approach for separate process and combustion emissions, or use a CEMS to determine combined process 

and combustion emissions. 

Applicable NSPS and NESHAP for Cement Plants

Table H-1. Applicable NESHAP and NSPS Rules 

NESHAP/NSPS Subparts 

Reviewed 

Monitoring Required by the 

NESHAP or NSPS 

Would 

Monitoring 

Equipment 

Relevant to Part 

98 be Installed to 

Comply With 

NESHAP or 

NSPS? 

Were Data on 

CEMS Counts 

Available in 

NESHAP or 

NSPS docket? 

Subpart LLL—NESHAP for the 

Portland Cement Manufacturing 

Industrya

 

Hg CEMS, PM CEMS, THC CEMS; 

HCl CEMS if not using a scrubber; 

Flow rate monitor if using a PM or 

Hg CEMS. 

Yes No 

Subpart EEE—NESHAP for 

Hazardous Waste Combustors 

(applies to both major and area 

sources) 

CO CEMS or THC CEMS, both 

using an O2 CEMS to correct to 

constant O2. Yes No 

Subpart F—NSPS for Portland 

Cement Plants 

PM CEMS, NOX CEMS, SO2

CEMS, including flow a rate monitor 

to determine mass emission rates. 

(CEMS requirements apply only to 

kilns constructed, reconstructed, or 

modified after 2008) 

Yes No 

a Applies to each kiln including alkali bypasses at all major and area sources, except for kilns that burn hazardous 

waste and are subject to and regulated under 40 CFR 63, subpart EEE.
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64 

Summary of Available GHGRP and Other Data on Facilities Reporting the Use of CEMS

Table H-2. CEMS Data from Databases 

GHGRP Cement NSPS Database 

Count of Facilities with CO2

CEMS/Total Count of CO2 CEMS 

Total Kiln Count/Count of Kilns with 

CEMS; Total Facility Count/Count of 

Facilities with non-CO2 CEMS 

82/112 121/50; 64/36 

 The cement NSPS database only provides CEMS counts for SO2, NOX, and THC CEMS, while 

data on Hg, PM, and HCl CEMS were not provided. As such, the count from the cement database 

is a low estimate. 

 In comparison to the cement database, the GHGRP database contains an additional 46 facilities 

with CEMS data. 

 From the ‘Summary of Environmental and Cost Impacts for Final Portland Cement NESHAP and 

NSPS’ (August 6, 2010) there are 100 plants with 140 kilns. 

 The data from GHGRP and the cement database are combined for the recommended CEMS count 

to provide both a facility and unit level estimate. 

 Since Hg, PM, and THC CEMS are applicable according to the NESHAP, although 

documentation for this is not available, we also assumed that all kilns have CEMS for a potential 

estimate. 

Subpart H CEMS Count

Table H-3 summarizes the actual data collected for facilities and units using CO2 CEMS, non-CO2 GHG 

CEMS, and non-GHG CEMS. The table also shows a potential estimate of CEMS usage based on 

assumptions regarding the applicability of NSPS and NESHAP requirements. 

Table H-3. Subpart H Facility and Unit CEMS Counts 

Basis CO2 CEMS for 

GHGRP 

Reporting non-CO2

GHG CEMS for 

GHGRP 

Reporting non-GHG CEMS for 

Other EPA Programs 

Actual Potentialf

Facilities 82a 0c 0c 14d

Units 112b 0c 0c 28e

NA = No estimate is available. 

a Number of facilities reporting to GHGRP in 2011 that they are using a CEMS to report CO2 emissions. 

b

 The total number of CO2 CEMS at the facilities which reported CO2 CEMS. c

 No units or facilities are known to be using non-CO2 GHG CEMS (e.g., for CH4 or N2O). 

d

 Based on assuming that all kilns will have a non-GHG CEMS to comply with the NESHAP, and using 96 as the 

number of operating plants, minus the 82 that reported to GHGRP that they are using GHG CEMS. 

e

 Based on assuming that all kilns will have a non-GHG CEMS to comply with the NESHAP, and using the 

estimated number of units (140) in the “Summary of Environmental and Cost Impacts for Final Portland Cement 

NESHAP and NSPS” (August 6, 2010), minus the 112 that reported to GHGRP that they are using GHG CEMS. f

Potential facilities or process units that may have equipment installed that could be modified for use in the GHGRP.
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65 

Appendix B. Ferroalloy Production – Subpart K

Industry Background

Based on 2011 annual report submissions, there were 10 facilities that reported to GHGRP under 

subpart K. 

Under subpart K, facilities estimate CO2 process emissions from each electric arc furnace that is 

used for any type of ferroalloy production. Facilities also estimate CH4 emissions from each 

electric arc furnace that is used for the production of silicon metal or ferrosilicon (65%, 75%, or 

90%). For estimating CO2 process emissions, facilities may either use a mass balance approach 

or use a CEMS. Emissions of CH4 must be estimated by multiplying the annual production of 

silicon metal or ferrosilicon and applying an applicable emission factor provided in the subpart. 

Applicable NSPS and NESHAP for Ferroalloy Plants

Table K-1. Applicable NESHAP and NSPS Rules 

NESHAP/NSPS Subparts Reviewed Monitoring Required 

by the NESHAP or 

NSPS 

Would 

Monitoring 

Equipment 

Relevant to Part 

98 be Installed to 

Comply With 

NESHAP or 

NSPS? 

Were Data on 

CEMS Counts 

Available in 

NESHAP or 

NSPS docket? 

Subpart Z—NSPS for Ferroalloy Production 

Facilities 

To ensure furnace hood 

capture efficiency, 

sources must monitor 

volumetric flow rate in 

ducts from furnace 

hoods 

No No 

Subpart XXX—NESHAP for Ferroalloys 

Production: Ferromanganese and 

Silicomanganese

If a source has a venturi 

scrubber, the source has 

the option of monitoring 

the flow rate through 

each separately ducted 

hood or at the inlet to the 

control device 

No No 

Subpart YYYYYY—NESHAP for Area 

Sources: Ferroalloys Production Facilities

(No relevant monitoring 

requirements) No No 

While monitoring of flow rate is required, the location of the flow monitors is not appropriate for 

monitoring flow as it relates to CEMS. For this analysis it was assumed that no equipment is 

installed which would facilitate the installation of GHG CEMS. 

Summary of Available Data on Facilities Reporting the Use of CEMS

No data on CEMS counts applicable to subpart K facilities were available. 
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Subpart K CEMS Count

Table K-2 summarizes the actual data collected for facilities using CO2 CEMS, non-CO2 GHG 

CEMS, and non-GHG CEMS. No facilities were identified with pre-existing CEMS. No 

assumption could be made for a potential count based on lack of information on control devices. 

Table K-2. Subpart K CEMS Counts 

Basis CO2 CEMS for 

GHGRP 

Reporting non-CO2

GHG CEMS for 

GHGRP 

Reporting non-GHG CEMS for 

Other EPA Programs 

Actual Potentiala

Facilities NA NA NA NA 

Units NA NA NA NA 

NA = No information available. 

a

Potential facilities or process units that may have equipment installed that could be modified for use in the GHGRP.

 
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67 

Appendix B. Fluorinated Gas Production – Subpart L

Industry Background

Based on 2011 annual report submissions, there were 16 facilities that reported to GHGRP under 

subpart L. 

Under subpart L, facilities estimate emissions of HFCs, PFCs, SF6, NF3, and HFEs from each 

fluorinated gas production process and all fluorinated gas production processes combined, each 

fluorinated gas transformation process that is not a part of a fluorinated gas production process, 

each fluorinated GHG destruction process that is not a part of a fluorinated gas production 

process, and venting of residual fluorinated GHGs from contains returned to the field. For 

estimating fluorinated GHG emissions, facilities must use either a mass balance approach or an 

emission factor or emission calculator factor approach. 

Applicable NSPS and NESHAP for Fluorinated Gas Production Plants

Table L-1. Applicable NESHAP and NSPS Rules 

NESHAP/NSPS Subparts Reviewed Monitoring Required 

by the NESHAP or 

NSPS 

Would 

Monitoring 

Equipment 

Relevant to Part 

98 be Installed to 

Comply With 

NESHAP or 

NSPS? 

Were Data on 

CEMS Counts 

Available in 

NESHAP or 

NSPS docket? 

Subpart FFFF—NESHAP for Miscellaneous 

Organic Chemical Manufacturing 

CEMS is option; CPMS 

required dependent on 

control device 

Yes No 

Subpart L facilities may have CEMS installed to monitor HF emissions. However, this is only an 

alternative and no data were provided to determine how many (if any) would comply using this 

method. Since more economical options are available it is not anticipated any facilities would 

comply using CEMS. In addition, CPMS requirements would not be applicable to installation of 

CEMS equipment (e.g., CPMS includes monitoring temperature or liquid flow rate). 

Summary of Available Data on Facilities Reporting the Use of CEMS

From the response to comments document for Subpart L, there was a specific request for 

allowance of CEMS to monitor fluorinated gases. The commenter stated that FTIR CEMS were 

a mature technology and were currently used in the fluorinated gas manufacturing industry. 

Specific discussion on current installations was provided with discussion on how all equipment 

was able to withstand the corrosive environment. The commenter stated that five FTIR CEMS 

were installed at this facility. Note that discussion on CEMS installations was specific to a 

particular facility; the commenter did not imply that all facilities used CEMS. In the EPA’s 

response it was noted that CEMS would not be required partly due to the unknown costs. 

Subpart L CEMS Count
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Table L-2 summarizes the actual data collected for facilities using CO2 CEMS, non-CO2 GHG 

CEMS, and non-GHG CEMS. Based on the public comment, one facility was identified as 

having a CEMS installed to measure fluorinated gases. No other data on CEMS installations 

were available. 

Table L-2. Subpart L CEMS Counts 

Basis CO2 CEMS for 

GHGRP 

Reporting non-CO2

GHG CEMS for 

GHGRP 

Reporting non-GHG CEMS for 

Other EPA Programs 

Actual Potentiala

Facilities NA 1 NA NA 

Units NA 5 NA NA 

NA = No information available. 

a

Potential facilities or process units that may have equipment installed that could be modified for use in the GHGRP.

 
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Appendix B. Glass Production – Subpart N

Industry Background

Based on 2011 annual report submissions, there were 110 facilities that reported to GHGRP 

under subpart N. 

Under subpart N, facilities estimate CO2 process emissions from each continuous glass melting 

furnace and CO2 combustion emissions from each continuous glass melting furnace. They are 

also required to estimate and report CH4 and N2O combustion emissions from each continuous 

glass melting furnace. For CO2 emissions, facilities may either use a mass balance approach for 

separate process and combustion emissions, or use a CEMS to determine combined process and 

combustion emissions. 

Applicable NSPS and NESHAP for Glass Plants

Table N-1. Applicable NESHAP and NSPS Rules 

NESHAP/NSPS Subparts Reviewed Monitoring Required 

by the NESHAP or 

NSPS 

Would 

Monitoring 

Equipment 

Relevant to Part 

98 be Installed to 

Comply With 

NESHAP or 

NSPS? 

Were Data on 

CEMS Counts 

Available in 

NESHAP or 

NSPS docket? 

Subpart CC—NSPS for Glass Manufacturing 

Plants 

(No relevant monitoring 

requirements) No No 

Subpart PPP—NSPS for Wool Fiberglass 

Insulation Manufacturing Plants

(No relevant monitoring 

requirements) No No 

Subpart NNN—NESHAP for Wool Fiberglass 

Manufacturing

(No relevant monitoring 

requirements) No No 

Subpart HHHH—NESHAP for Wet-Formed 

Fiberglass Mat Production 

(No relevant monitoring 

requirements) No No 

Subpart SSSSSS—NESHAP for Glass 

Manufacturing Area Sources 

(No relevant monitoring 

requirements) No No 

Subpart N—National Emission Standard for 

Inorganic Arsenic Emissions From Glass 

Manufacturing Plants 

(No relevant monitoring 

requirements) No No 

The applicable NESHAP and NSPS for this subpart do not require monitoring which is related to 

CEMS equipment and would thus not facilitate the installation of GHG CEMS. 

Summary of Available Data on Facilities Reporting the Use of CEMS
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There were three facilities which reported CO2 CEMS in GHGRP and each only reported one 

CEMS.

Subpart N CEMS Count

Table N-2 summarizes the actual data collected for facilities using CO2 CEMS, non-CO2 GHG 

CEMS, and non-GHG CEMS. The only source with data regarding CEMS installations was the 

CO2 CEMS counts from GHGRP. No assumption could be made for a potential count based on 

rule requirements. 

Table N-2. Subpart N CEMS Counts 

Basis CO2 CEMS for 

GHGRP 

Reporting non-CO2

GHG CEMS for 

GHGRP 

Reporting non-GHG CEMS for 

Other EPA Programs 

Actual Potentialc

Facilities 3a

 NA NA NA 

Units 3b

 NA NA NA 

NA = No information available. 

a Number of facilities reporting to GHGRP in 2011 that they are using a CEMS to report CO2 emissions. 

b

 The total number of CO2 CEMS at the facilities which reported CO2 CEMS. c

Potential facilities or process units that may have equipment installed that could be modified for use in the GHGRP.
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71 

Appendix B. HCFC-22 Production and HFC-23 Destruction Plants – Subpart O

Industry Background

Based on 2011 annual report submissions, there were 5 facilities that reported to GHGRP under 

subpart O. 

Under subpart O, facilities estimate HFC-23 process emissions from all HCFC-22 production 

processes and HFC-23 destruction processes at the facility. For estimating HFC-23 process 

emissions, facilities must use a mass balance approach for all HCFC-22 production processes 

and HFC-23 destruction processes. 

Applicable NSPS and NESHAP for HCFC-22 Production and HFC-23 Destruction Plants

Table O-1. Applicable NESHAP and NSPS Rules 

NESHAP/NSPS Subparts Reviewed Monitoring Required 

by the NESHAP or 

NSPS 

Would 

Monitoring 

Equipment 

Relevant to Part 

98 be Installed to 

Comply With 

NESHAP or 

NSPS? 

Were Data on 

CEMS Counts 

Available in 

NESHAP or 

NSPS docket? 

Subpart FFFF—NESHAP for Miscellaneous 

Organic Chemical Manufacturing 

CEMS is option; CPMS 

required dependent on 

control device 

Yes No 

Subpart O facilities may have CEMS installed to monitor HF emissions. However, this is only an 

alternative and no data were provided to determine how many (if any) would comply using this 

method. Since more economical options are available it is not anticipated any facilities would 

comply using CEMS. In addition, CPMS requirements would not be applicable to installation of 

CEMS equipment (e.g., CPMS includes monitoring temperature for thermal oxidizers which was 

a control device specifically mentioned in subpart O rule language). 

Summary of Available Data on Facilities Reporting the Use of CEMS

No facility counts for use of CEMS were available. Of note, subpart L facilities specifically 

requested the use of CEMS to measure fluorinated gases. However, a similar request was not 

made for subpart O. Since FTIR CEMS were shown to measure fluorinated gases in the Subpart 

L comments, it may also be feasible for subpart O. The ability of the CEMS to directly measure 

HFC-23 was not discussed and as such its applicability to subpart O is unknown. 

 
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Subpart O CEMS Count

Table O-2 summarizes the actual data collected for facilities using CO2 CEMS, non-CO2 GHG 

CEMS, and non-GHG CEMS. No facilities were identified with pre-existing CEMS. No 

assumption could be made for a potential count based on lack of information. 

Table O-2. Subpart O CEMS Counts 

Basis CO2 CEMS for 

GHGRP 

Reporting non-CO2

GHG CEMS for 

GHGRP 

Reporting non-GHG CEMS for 

Other EPA Programs 

Actual Potentiala

Facilities NA NA NA NA 

Units NA NA NA NA 

NA = No information available. 

a

Potential facilities or process units that may have equipment installed that could be modified for use in the GHGRP.

 
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73 

Appendix B. Hydrogen Production – Subpart P

Industry Background

Based on 2011 annual report submissions, there were 103 facilities that reported to GHGRP 

under subpart P. 

Under subpart P, facilities estimate CO2 process and combustion emissions from each hydrogen 

production unit. CO2 collected and either used on site or transferred off site must also be 

estimated. Facilities also estimate CH4 and N2O combustion emissions from each hydrogen 

production unit. For CO2 emissions, facilities may either use a mass balance approach for 

separate process and combustion emissions, or use a CEMS to determine combined process and 

combustion emissions. 

Applicable NSPS and NESHAP for Hydrogen Production Plants

Table P-1. Applicable NESHAP and NSPS Rules 

NESHAP/NSPS Subparts Reviewed Monitoring Required 

by the NESHAP or 

NSPS 

Would 

Monitoring 

Equipment 

Relevant to Part 

98 be Installed to 

Comply With 

NESHAP or 

NSPS? 

Were Data on 

CEMS Counts 

Available in 

NESHAP or 

NSPS docket? 

Subpart CC—NESHAP for Petroleum 

Refineries 

(No relevant monitoring 

requirements) No No 

The applicable NESHAP for this subpart does not require monitoring which is related to CEMS 

equipment and would thus not facilitate the installation of GHG CEMS. 

Summary of Available Data on Facilities Reporting the Use of CEMS

There were three facilities which reported CO2 CEMS in GHGRP and each reported only one 

CEMS. 

Subpart P CEMS Count

Table P-2 summarizes the actual data collected for facilities using CO2 CEMS, non-CO2 GHG 

CEMS, and non-GHG CEMS. The only source with data regarding CEMS installations was the 

CO2 CEMS counts from GHGRP. No assumption could be made for a potential count based on 

rule requirements. 

Table P-2. Subpart P CEMS Counts 

Basis CO2 CEMS for 

GHGRP 

Reporting non-CO2

GHG CEMS for 

GHGRP 

Reporting non-GHG CEMS for 

Other EPA Programs 

Actual Potentialc

Facilities 3a

 NA NA NA 
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Units 3b

 NA NA NA 

NA = No information available. 

a Number of facilities reporting to GHGRP in 2011 that they are using a CEMS to report CO2 emissions. 

b

 The total number of CO2 CEMS at the facilities which reported CO2 CEMS. c

Potential facilities or process units that may have equipment installed that could be modified for use in the GHGRP.

 
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Appendix B. Iron and Steel Production – Subpart Q

Industry Background

 The iron and steel production source category under subpart Q consists of facilities with any of the 

following processes: 

 Taconite iron ore processing. 

 Integrated iron and steel manufacturing (production of steel from iron ore or iron ore pellets). 

 Coke making not co-located with an integrated iron and steel manufacturing process. 

 Electric arc furnace (EAF) steelmaking not co-located with an integrated iron and steel 

manufacturing process. 

Under subpart Q, process CO2 emissions are estimated from the following processes at an iron and steel 

facility: 

 Taconite indurating furnaces 

 Basic oxygen process furnaces (BOPF) 

 Non-recovery coke oven batteries 

 Sintering process 

 Electric arc furnaces (EAF) 

 Argon-oxygen decarburization (AOD) vessels 

 Direct reduction ironmaking (DRI) furnaces 

Facilities are required to determine process CO2 emissions using either a carbon mass balance method, a 

site-specific emission factor, or by a CO2 CEMS that meets the Tier 4 calculation methodology 

requirements of subpart C. Facilities are not required to determine CH4, N2O or other process GHG 

emissions from the sources subject to subpart Q. For other stationary combustion units located at iron and 

steel facilities, the facility must estimate and report GHG emissions under subpart C. 

Based on 2011 annual report submissions, there were 128 facilities that reported to GHGRP under subpart 

Q. 

Applicable NSPS and NESHAP for Iron and Steel Facilities

The NSPS and NESHAP were reviewed that are applicable to the processes for which GHG emissions 

must be determined under subpart Q. We evaluated whether complying with the monitoring requirements 

in those rules would require the use of a non-GHG or GHG CEMS that could be used to estimate GHG 

emissions, or that would require associated equipment, such as flow meters, that would facilitate and 

reduce the cost of using a GHG CEMS to comply with subpart Q. The results of that analysis are 

summarized in Table Q-1. 
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Table Q-1. Summary of NSPS and NESHAP Monitoring Requirements Applicable to Subpart Q Processes 

and Facilities 

Iron and Steel 

Process Category 

Applicable 

NSPS or 

NESHAP 

Relevant Monitoring Required by 

the NSPS or NESHAP 

Would Monitoring 

Equipment Relevant 

to Part 98 be 

Installed to Comply 

With NSPS or 

NESHAP? 

Were Data on 

CEMS Counts 

Available in 

NESHAP or 

NSPS docket? 

Taconite 

indurating 

furnaces 

40 CFR 63, 

subpart RRRRR 

(major sources) 

(No relevant monitoring requirements) 

No No 

Basic oxygen 

process furnaces 

40 CFR 63, 

subpart FFFFFa 

(major sources) 

To ensure furnace hood capture 

efficiency, sources have the option to 

monitor volumetric flow rate in ducts 

from furnace hoods or at the inlet to 

the control device; or to monitor 

system fan amperes and damper 

position. 

Some facilities may 

monitor flow rate, but 

the flow rate monitors 

probably would not 

meet the specifications 

for a CEMS flow 

monitor. 

No 

Non-recovery 

coke oven 

batteries 

40 CFR 63, 

subpart L 

(area and major 

sources) 

(No relevant monitoring requirements) 

No No 

40 CFR 63, 

subpart CCCCC 

(major sources) 

Pushing operations capture hoods: 

monitor volumetric flow rate at inlet 

to control, monitor system fan 

amperes, or monitor static pressure in 

capture device. 

Some facilities may 

monitor flow rate, but 

the flow rate monitors 

probably would not 

meet the specifications 

for a CEMS flow 

monitor. 

No 

Sintering process 40 CFR 63, 

subpart FFFFFa 

(major sources) 

To ensure furnace hood capture 

efficiency, sources have the option to 

monitor volumetric flow rate in ducts 

from furnace hoods or at the inlet to 

the control device; or to monitor 

system fan amperes and damper 

position. 

Some facilities may 

monitor flow rate, but 

the flow rate monitors 

probably would not 

meet the specifications 

for a CEMS flow 

monitor. 

No 

Electric arc 

furnaces (EAF) 

40 CFR 60, 

subparts AA 

and AAa 

To ensure EAF furnace hood capture 

efficiency, sources have the option to 

monitor volumetric flow rate in ducts 

from furnace hoods or at the inlet to 

the control device; or to monitor 

system fan amperes and damper 

position. Flow rate monitors only need 

to have ±10% accuracy and may be 

calibrated according to manufacturer’s 

specifications. 

Flow monitors 

specified by AA and 

AAa probably would 

not meet the 

specifications for a 

CEMS flow monitor. No 

40 CFR 63, 

subpart 

YYYYY 

(area sources) 

(No relevant monitoring requirements) 

No No 

Argon-oxygen 

decarburization 

vessels 

40 CFR 60, 

subpart AAa 

To ensure hood capture efficiency, 

sources have the option to monitor 

volumetric flow rate in ducts from 

furnace hoods or at the inlet to the 

Flow monitors 

specified by AAa 

probably would not 

meet the specifications 

No 
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77 

control device; or to monitor system 

fan amperes and damper position. 

Flow rate monitors only need to have 

±10% accuracy and may be calibrated 

according to manufacturer’s 

specifications. 

for a CEMS flow 

monitor. 

40 CFR 63, 

subpart 

YYYYY 

(area sources) 

(No relevant monitoring requirements) 

No No 

Direct reduction 

furnaces No applicable NSPS or NESHAP were identified 

a 40 CFR 63, subpart FFFFF also regulates emissions from steel making blast furnaces, but these are not included in 

the processes in 40 CFR part 98, subpart Q. Subpart Q includes blast furnaces among the units that produce GHG 

emissions only from fuel combustion and not from raw materials. Therefore, GHG emissions would be estimated 

under subpart C and not under subpart Q. 

None of the applicable NSPS or NESHAP required the use of monitoring equipment that could be used as a GHG 

CEMS, or that would facilitate the use of GHG CEMS. As shown in Table Q-2, some of the rules included an 

option to monitor volumetric flow rates in ducts to ensure that a sufficient volume of air is being drawn into furnace 

hoods to maintain good capture efficiency. These same rules also included an option to monitor system fan amperes 

and damper position as an alternative to flow rate. It is not known if the flow rate monitors used to comply would 

meet the performance specifications needed for a flow rate monitor used as part of a GHG CEMS, either based on 

location or on the accuracy and calibration requirements. Furthermore, the applicable rules do not specify that the 

flow rate monitors meet any applicable EPA performance specification, such as EPA Performance Specification 6 

for flow rate, or be calibrated against an EPA stack testing reference method. Therefore, we could assume that these 

rules do not establish monitoring requirements that would facilitate the use of CEMS to determine GHG emissions. 

Summary of Available GHGRP Data on Facilities Reporting the Use of CEMS

A total of 11 subpart Q facilities have reported to GHGRP as using a CO2 CEMS with a total of 14 CEMS. These 

11 facilities are owned by two companies; two facilities are owned by ArcelorMittal and nine by Nucor. 

 One of the ArcellorMittal facilities (Indiana) is an integrated steel facility, and the other (Pennsylvania) is 

an EAF facility, based on online company information. 

 The nine facilities owned by Nucor all appear to be EAF facilities, based on online company information. 

 The non-CBI information provided by the EPA from GHGRP does not indicate which process units at each 

facility are using a CEMS to determine GHG emissions, or the number of units. 

 We assume that the majority of process units with CEMS are EAFs or AODs, because these are the only 

units present at EAF facilities for which GHG emissions must be determined under subpart Q. 

 We do not know which units at the ArcellorMittal facility are using a CEMS. 
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78 

Subpart Q CEMS Count

Table Q-2 summarizes the actual data collected for facilities and units using CO2 CEMS, non-CO2 GHG 

CEMS, and non-GHG CEMS. The table also shows a potential estimate of CEMS usage based on 

assumptions regarding the applicability of NSPS and NESHAP requirements and using the background 

information. 

Table Q-2. Subpart Q CEMS Counts 

Basis CO2 CEMS for 

GHGRP 

Reporting non-CO2

GHG CEMS for 

GHGRP 

Reporting non-GHG CEMS for 

Other EPA Programs 

Actual Potentialc

Facilities 11a

 NA NA NA 

Units 14b

 NA NA NA 

NA = No information available. 

a Number of facilities reporting to GHGRP in 2011 that they are using a CEMS to report CO2 emissions. 

b

 The total number of CO2 CEMS at the facilities which reported CO2 CEMS. c

Potential facilities or process units that may have equipment installed that could be modified for use in the GHGRP.
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Appendix B. Lead Production – Subpart R

Industry Background

Based on 2011 annual report submissions, there were 13 facilities that reported to GHGRP under 

subpart R. 

Under subpart R, facilities estimate CO2 process emissions from each smelting furnace and CO2

combustion emissions from each smelting furnace. They are also required to estimate and report 

CH4 and N2O combustion emissions from each smelting furnace. For CO2 emissions, facilities 

may either use a mass balance approach for separate process and combustion emissions, or use a 

CEMS to determine combined process and combustion emissions. 

Applicable NSPS and NESHAP for Lead Plants

Table R-1. Applicable NESHAP and NSPS Rules 

NESHAP/NSPS Subparts Reviewed Monitoring Required 

by the NESHAP or 

NSPS 

Would Monitoring 

Equipment Relevant to 

Part 98 be Installed to 

Comply With 

NESHAP or NSPS? 

Were Data on 

CEMS Counts 

Available in 

NESHAP or 

NSPS docket? 

Subpart L—NSPS for Secondary Lead 

Smelters 

(No relevant monitoring 

requirements) No No 

Subpart R—NSPS for Primary Lead 

Smelters

SO2 CEMS required for 

all primary lead 

smelters 

Yes No 

Subpart X—NESHAP from Secondary 

Lead Smelting

(No relevant monitoring 

requirements) No No 

Subpart TTT—NESHAP for Primary 

Lead Smelting 

Sources must monitor 

volumetric flow rate 

through each separately 

ducted hood or at the 

inlet to the control 

device 

Yes No 

The NSPS and NESHAP for secondary lead smelters do not contain any relevant monitoring 

requirements. The NSPS for primary lead smelters requires SO2 monitoring, but applies only to 

primary lead smelters constructed after October 16, 1974. There have been no lead smelters 

constructed since 1974. Specifics of the one primary lead smelter in the United States are not 

known, and thus we are not certain if the facility operates an SO2 CEMS. 

Summary of Available Data on Facilities Reporting the Use of CEMS

No data on CEMS counts applicable to subpart R facilities were available. 

Subpart R CEMS Count

Table R-2 summarizes the actual data collected for facilities using CO2 CEMS, non-CO2 GHG 

CEMS, and non-GHG CEMS. No facilities were identified with pre-existing CO2 CEMS. No 
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80 

assumption could be made for a potential count based on lack of information on control devices 

and monitoring requirements. 

Table R-2. Subpart R CEMS Counts 

Basis CO2 CEMS for 

GHGRP 

Reporting non-CO2 GHG 

CEMS for GHGRP 

Reporting non-GHG CEMS for 

Other EPA Programs 

Actual Potentiala

Facilities NA NA NA NA 

Units NA NA NA NA 

NA = No information available. 

a

Potential facilities or process units that may have equipment installed that could be modified for use in the GHGRP.

 
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Appendix B. Lime Manufacturing – Subpart S

Industry Background

Based on 2011 annual report submissions, there were 73 facilities that reported to GHGRP under 

subpart S. 

Under subpart S, facilities estimate CO2 process emissions from each lime kiln and CO2

combustion emissions from each lime kiln. They are also required to estimate and report CH4

and N2O combustion emissions from each lime kiln. For CO2 emissions, facilities may either use 

a mass balance approach for separate process and combustion emissions, or use a CEMS to 

determine combined process and combustion emissions. 

Applicable NSPS and NESHAP for Lime Plants

Table S-1. Applicable NESHAP and NSPS Rules 

NESHAP/NSPS Subparts Reviewed Monitoring Required 

by the NESHAP or 

NSPS 

Would 

Monitoring 

Equipment 

Relevant to Part 

98 be Installed to 

Comply With 

NESHAP or 

NSPS? 

Were Data on 

CEMS Counts 

Available in 

NESHAP or 

NSPS docket? 

Subpart HH—NSPS for Lime Manufacturing 

Plants 

(No relevant monitoring 

requirements) No No 

Subpart AAAAA—NESHAP for Lime 

Manufacturing Plants

(No relevant monitoring 

requirements) No No 

The applicable NESHAP and NSPS for this subpart do not require monitoring which is related to 

CEMS equipment and would thus not facilitate the installation of GHG CEMS. 

Summary of Available Data on Facilities Reporting the Use of CEMS

One facility was reported to use CO2 CEMS in the 2011 GHGRP. The RIA for part 98 identified 

that all facilities would meet the Tier 4 criteria to install CEMS. Therefore, the remaining 73 

facilities are assumed to meet Tier 4 criteria. 

Subpart S CEMS Count

Table S-2 summarizes the actual data collected for facilities using CO2 CEMS, non-CO2 GHG 

CEMS, and non-GHG CEMS. The table also shows a potential estimate of CEMS usage based 

on assumptions regarding the applicability of NSPS and NESHAP requirements and using the 

background information. 

Table S-2. Subpart S CEMS Counts 

Basis CO2 CEMS for 

GHGRP 

Reporting non-CO2

GHG CEMS for 

Reporting non-GHG CEMS for 

Other EPA Programs 
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GHGRP Actual Potentialb

Facilities 1a

 NA NA NA 

Units NA NA NA NA 

NA = No information available. 

a

 Number of facilities that reported to GHGRP in 2011 that they were using a CEMS to report CO2 emissions. 

b

Potential facilities or process units that may have equipment installed that could be modified for use in the GHGRP.
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83 

Appendix B. Miscellaneous Uses of Carbonates Facilities – Subpart U

Industry Background

Based on 2011 annual report submissions, there were 18 facilities that reported to GHGRP under 

subpart U. 

Under subpart U, facilities estimate CO2 process emissions for all miscellaneous carbonate use at 

the facility. For estimating CO2 process emissions, facilities must use a mass balance approach. 

Applicable NSPS and NESHAP for the Miscellaneous Use of Carbonates

There is no NSPS or NESHAP specifically applicable to miscellaneous use of carbonates. 

Summary of Available Data on Facilities Reporting the Use of CEMS

No data on CEMS counts applicable to subpart U facilities were available. 

Subpart U CEMS Count

Table U-1 summarizes the actual data collected for facilities using CO2 CEMS, non-CO2 GHG 

CEMS, and non-GHG CEMS. No facilities were identified with pre-existing CO2 CEMS. No 

assumption could be made for a potential count based on lack of information on control devices 

and monitoring requirements. 

Table U-1. Subpart BB CEMS Counts 

Basis CO2 CEMS for 

GHGRP 

Reporting non-CO2 GHG 

CEMS for GHGRP 

Reporting non-GHG 

CEMS for Other EPA 

Programs 

Potentiala

Facilities NA NA NA 

Units NA NA NA 

NA = No information available. 

a

Potential facilities or process units that may have equipment installed that could be modified for use in the GHGRP.

 
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Appendix B. Nitric Acid Production – Subpart V

Industry Background

In the TSD for subpart V, the EPA estimated that 45 nitric acid production plants with a total of 

65 production units were operating in the United States, based on the 1990-2006 Inventory of 

U.S. Greenhouse Gas Emissions and Sinks. These 45 plants are spread across 25 states, and 18 of 

the plants qualify as small businesses. Based on 2011 annual report submissions, there were 36 

facilities that reported to GHGRP under subpart V. 

Under subpart V, facilities estimate N2O process emissions from each nitric acid train. For N2O 

emissions, facilities may either use a mass balance and emission factor approach, or use a CEMS 

to directly measure process emissions. 

Applicable NSPS and NESHAP for Nitric Acid Plants

Table V-1. Applicable NESHAP and NSPS Rules 

NESHAP/NSPS Subparts 

Reviewed 

Monitoring Required by the 

NESHAP or NSPS 

Would Monitoring 

Equipment Relevant to 

Part 98 be Installed to 

Comply With NESHAP 

or NSPS? 

Were Data on 

CEMS Counts 

Available in 

NESHAP or 

NSPS docket? 

Subpart G—Standards of 

Performance for Nitric Acid 

Plants 

NOX CEMS required for units 

constructed or modified after 

August 17, 1971 Yes No 

Each emission point for nitric acid production shall install NOX CEMS if constructed or 

modified after 1971; no alternatives are provided. 

Summary of Available Data on Facilities Reporting the Use of CEMS

Table V-2. Available CEMS Data 

1990-2006 Inventory of U.S. GHG Emissions and Sinks (from TSD) 

Total Unit Count/Count of Units with NOx CEMS; Total Facility Count/Count of Facilities with NOx 

CEMS 

65/36; 45/20 

As shown in the TSD to subpart V, several facilities have NOX CEMS installed. Of the 45 nitric 

acid production plants, 20 nitric acid production plants employ CEMS for NOX emissions. At 

these 20 nitric acid plants there are 36 processes which have NOX CEMS; this is approximately 

58 percent of the total processes. It is presumed that the processes which do not have NOX

CEMS installed were built prior to 1971. No facilities reported CO2 CEMS through GHGRP. 

 
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Subpart V CEMS Count

Table V-3 summarizes the actual data collected for facilities using CO2 CEMS, non-CO2 GHG 

CEMS, and non-GHG CEMS. The table also shows a potential estimate of CEMS usage based 

on assumptions regarding the applicability of NSPS and NESHAP requirements and using the 

background information. 

Table V-3. Subpart V CEMS Counts 

Basis CO2 CEMS for 

GHGRP 

Reporting non-CO2

GHG CEMS for 

GHGRP 

Reporting non-GHG CEMS 

for Other EPA Programs 

Actual Potentialb

Facilities NA NA 20 a NA 

Units NA NA 36a NA 

NA = No information available. 

a

 Based on data reported as a part of the 1990-2006 Inventory of U.S. Greenhouse Gas Emissions and Sinks, which is 

shown in the TSD to subpart V. A potential estimate was not generated since the inventory data were reported by the 

facility and presumed to be the actual count of units with NOX CEMS. 

b

Potential facilities or process units that may have equipment installed that could be modified for use in the GHGRP.
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Appendix B. Petrochemical Production – Subpart X

Industry Background

The petrochemical production subcategory consists of each process that produces: 

 Acrylonitrile 

 Carbon black 

 Ethylene 

 Ethylene Dichloride 

 Ethylene Oxide 

 Methanol 

Each petrochemical facility must report CO2 process emissions and CO2, CH4, and N2O emissions 

generated by combustion of process off-gas in stationary combustion units and flares. GHG estimates are 

also necessary for CO2, CH4, and N2O emissions from burning supplemental fuel in stationary 

combustion units that also burn process off-gas. If Tier 4 criteria are met then CO2 emissions must be 

estimated by CEMS, otherwise the mass balance method is required. For CH4 and N2O the emission 

factor method is used. For ethylene processes only CO2 emissions may be estimated using Tier 3 or Tier 4 

for combustion of process off-gas. 

Based on 2011 annual report submissions, there were 64 facilities that reported to GHGRP under subpart 

X. 

Applicable NSPS and NESHAP for Petrochemical Plants and Facility Counts

Table X-1 shows the applicable NESHAP and NSPS for each facility type. Table X-2 shows the 

monitoring required by each of the NESHAP and NSPS and whether this monitoring is relevant to 

installing GHG CEMS. 

Table X-1. Applicable NESHAP/NSPS to Petrochemical Facilities for Subpart X 

Petrochemical Number of facilities Applicable NESHAP/NSPS 

NESHAP NSPS 

Acrylonitrile 5 Subparts F, G Subparts III, NNN, RRR 

Carbon Black 21 Subpart YY 

Ethylene 39 Subpart YY Subparts NNN, RRR 

Ethylene Dichloride 16 Subparts F, G Subparts III, NNN, RRR 

Ethylene Oxide 12 Subparts F, G Subparts III, NNN, RRR 

Methanol 5 Subparts F, G Subparts III, NNN, RRR 

 
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Table X-2. Applicable NESHAP and NSPS Rules 

NESHAP/NSPS Subparts Reviewed Monitoring Required 

by the NESHAP or 

NSPS 

Would 

Monitoring 

Equipment 

Relevant to Part 

98 be Installed to 

Comply With 

NESHAP or 

NSPS? 

Were Data on 

CEMS Counts 

Available in 

NESHAP or 

NSPS docket? 

(HON) 

Subpart F—NESHAP From the Synthetic 

Organic Chemical Manufacturing Industry 

 Subpart G—NESHAP From the Synthetic 

Organic Chemical Manufacturing Industry for 

Process Vents, Storage Vessels, Transfer 

Operations, and Wastewater 

Organic monitoring is an 

option if a recovery 

device is installed for 

process vents with a 

TRE index value greater 

than 1.0 

Yes No 

Subpart YY—NESHAP for Source 

Categories: Generic Maximum Achievable 

Control Technology Standards 

No relevant monitoring 

No No 

Subpart III—NSPS for Volatile Organic 

Compound (VOC) Emissions From the 

Synthetic Organic Chemical Manufacturing 

Industry (SOCMI) Air Oxidation Unit 

Processes 

If facility complies with 

TRE limit (>1 and not 

using VOC control 

device) and have an 

absorber, condenser, or 

carbon adsorber then 

organic monitoring is 

option 

Yes No 

Subpart NNN—NSPS for Volatile Organic 

Compound (VOC) Emissions From Synthetic 

Organic Chemical Manufacturing Industry 

(SOCMI) Distillation Operations 

If facility complies with 

TRE limit (>1 and not 

using VOC control 

device) and have an 

absorber, condenser, or 

carbon adsorber then 

organic monitoring is 

option 

Yes No 

Subpart RRR—NSPS for Volatile Organic 

Compound Emissions From Synthetic Organic 

Chemical Manufacturing Industry (SOCMI) 

Reactor Processes 

If facility complies with 

TRE limit (>1 and not 

using VOC control 

device) and have an 

absorber, condenser, or 

carbon adsorber then 

organic monitoring is 

option 

Yes No 

The relevant monitoring from both the NESHAP and NSPS is organic monitoring. An organic monitoring 

device is used to indicate the concentration level of organic compounds exiting the recovery device based 

on a detection principle such as infra-red, photoionization, or thermal conductivity and each is equipped 

with a continuous recorder. Although the organic monitoring would have CEMS related equipment 

installed, it is only an option and is dependent on the method of compliance and control device; it is 

unlikely that facilities will use this method of compliance due to cost, and would likely use other options 

instead (e.g., temperature monitoring). Due to the amount of unknown variables, for this analysis it was 

assumed that no equipment is installed which would facilitate the installation of GHG CEMS. 

Summary of Available GHGRP Data on Facilities Reporting the Use of CEMS
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There were two facilities which reported CO2 CEMS in GHGRP and each only reported one CEMS. The 

products at these two petrochemical facilities were not identified. 

Subpart X CEMS Count

Table X-3 summarizes the actual data collected for facilities and units using CO2 CEMS, non-CO2 GHG 

CEMS, and non-GHG CEMS. The only source with data regarding CEMS installations was the CO2

CEMS counts from GHGRP. No assumption could be made for a potential count based on rule 

requirements. 

Table X-3. Subpart X CEMS Counts 

Basis CO2 CEMS for 

GHGRP 

Reporting non-CO2

GHG CEMS for 

GHGRP 

Reporting non-GHG CEMS 

for Other EPA Programs 

Actual Potentialc

Facilities 2a NA NA NA 

Units 2b NA NA NA 

NA = No information available. 

a Number of facilities reporting to GHGRP in 2011 that they are using a CEMS to report CO2 emissions. 

b

 The total number of CO2 CEMS at the facilities which reported CO2 CEMS. c

Potential facilities or process units that may have equipment installed that could be modified for use in the GHGRP.

Also note that in comments to the GHGRP, commenters stated that for ethylene plants specifically there 

are no CEMS currently installed. 

 
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Appendix B. Petroleum Refineries – Subpart Y

Industry Background

Under subpart Y, petroleum refineries are classified as those which produce gasoline, gasoline blending 

stocks, naphtha, kerosene, distillate fuel oils, residual fuel oils, lubricants, or asphalt. When reporting 

their GHG emissions the following processes at each facility must report data for: 

 Flares 

 Catalytic cracking 

 Fluid coking 

 Coke calcining 

 Delayed coking 

 Catalytic reforming 

 Sulfur recovery 

 Asphalt blowing 

 Equipment leaks 

 Storage tanks 

 Other process vents 

 Uncontrolled blowdown systems 

 Loading operations 

 Stationary combustion 

The database developed for the refinery NESHAP contains a total of 148 refineries, excluding the 2 

refineries in U.S. territories. Based on 2011 annual report submissions, there were 145 facilities that 

reported to GHGRP under subpart Y. 

Applicable NSPS and NESHAP for Petroleum Refineries, Refinery Database Counts, and GHG 

Reporting Requirements

Table Y-1 provides a general overview of the NESHAP and NSPS rules applicable to petroleum 

refineries and the applicable CEMS requirements. Table Y-2 shows the specific CEMS requirements for 

each applicable refinery process (based on NESHAP/NSPS requirements), and also shows the greenhouse 

gases which must be reported under subpart Y for each process. Table Y-2 also shows process unit counts 

based on information in the petroleum refinery NESHAP database. The petroleum refinery database was 

provided by the EPA/OAQPS. Data detailing how many CEMS are installed were not available in the 

database, but process unit information was available that correlated with the NESHAP/NSPS rules. 

 
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Table Y-1. Applicable NESHAP and NSPS Rules 

NESHAP/NSPS Subparts Reviewed Monitoring Required by the 

NESHAP or NSPS 

 Subpart CC—NESHAP for Petroleum Refineries No relevant monitoring 

Subpart UUU—NESHAP for Petroleum Refineries: Catalytic Cracking Units, 

Catalytic Reforming Units, and Sulfur Recovery Units 

Flow rate, CO CEMS, O2

monitor 

Subpart J—NSPS for Petroleum Refineries Flow rate, CO CEMS, O2

monitor, SO2 monitor 

Table Y-2. GHGs Reported for Each Refinery Process, Process Unit Counts, and Monitoring 

Information from Applicable NESHAP/NSPS Rules 

Refinery Process 

Greenhouse Gases Which Shall 

Be Reported For Subpart Y 

Facilities 

Count of Process 

Units from 

Refinery 

NESHAP 

Database 

Is Process 

Required in 

NESHAP/NSPS 

to Have CEMS 

Monitoring? 

Monitoring 

Requirements per 

NESHAP/NSPS 

CO2 CH4 N2O 

Flares Y Y Y 439 N NA 

Catalytic Cracking Y Y Y 130 Y 

CO monitoring if 

catalytic cracking unit 

catalyst regenerators 

were constructed, 

reconstructed, or 

modified after 1973. 

Otherwise monitor O2, 

temperature, or 

operation of flare pilot. 

Flow monitoring 

required if modified 

before 1973 and control 

device is an ESP. 

Fluid Coking Y Y Y 

132a

N NA 

Coke Calcining Y Y Y N NA 

Delayed Coking N Y N N NA 

Catalytic Reforming Y Y Y 120 N NA 

Sulfur Recovery Y N N 187 Y SO2 and O2 monitors 

Asphalt Blowing Y Y N N NA 

Equipment Leaks N Y N 2593 N NA 

Storage Tanks N Y N 8107 N NA 

Other Process Vents Y Y Y 588 N NA 

Uncontrolled 

Blowdown Systems N Y N N NA 

Stationary Combustion Y Y Y 3228 N NA 

Loading Operations N Y N 301 N NA 

 Total Count of Process Units 15825 

Count of Process Units With Applicable Monitoring 317 

 Count of Process Units for CEMS Installation 1,580 

Includes fluid coking, coke calcining, 

catalytic reforming, flares, loading 

operations, and other process vents a

 The refinery database only provides a count for ‘coking unit vents’. This count was applied to all processes which refer to coke 

operations. 
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The refinery database provided a total facility count of 148 refineries, and contains 317 catalytic cracking 

and sulfur recovery units. For catalytic cracking processes, CO CEMS are only applicable to catalytic 

cracking unit catalyst regenerators. Each catalytic cracking process has an associated catalyst regenerator; 

the value of 130 will be used as a potential estimate. The 130 units are at 88 facilities. 187 sulfur recovery 

units are in place at 75 facilities; all 187 units must have an SO2/O2 monitor associated with it. For CEMS 

installation cost estimates, a unit count of 1,580 was used and only considers those processes which are 

relevant to CEMS. For example, a CEMS would not be used to monitor equipment leak emissions. 

Summary of Available GHGRP and Boiler Data on Facilities Reporting the Use of CEMS

There were 21 facilities that reported the use of CO2 CEMS within GHGRP, with a total of 24 CO2

CEMS. From the boiler MACT database, a total of 2,096 units were reported with 346 of those currently 

operating non-GHG CEMS. For the boiler data, it is not known if subpart Y process emissions are 

exhausted through the same stacks as boilers and without this determination we will not include the boiler 

data in the subpart Y CEMS counts. 

 

Subpart Y CEMS Count

Table Y-3 summarizes the actual data collected for facilities and units using CO2 CEMS, non-CO2 GHG 

CEMS, and non-GHG CEMS. The table also shows a potential estimate of CEMS usage based on 

assumptions regarding the applicability of NSPS and NESHAP requirements. 

Table Y-3. Subpart Y CEMS Counts 

Process Basis CO2 CEMS for 

GHGRP 

Reporting nonCO2 GHG CEMS 

for GHGRP 

Reporting non-GHG CEMS for Other 

EPA Programs 

Actual Potentialf

Catalytic 

Cracking and 

Sulfur 

Recovery 

Facilities 21a

 NA NA 104c

Units 

26b

 NA NA 317d

All Other 

Process Units 

(except 

stationary 

combustion)e

Facilities 0 0 0 0 

Units 

0 0 0 0 

NA = No information available. 

a Number of facilities reporting to GHGRP in 2011 that they are using a CEMS to report CO2 emissions. 

b

 The total number of CO2 CEMS at the facilities which reported CO2 CEMS in GHGRP. c

 Count of facilities which have catalytic cracking and/or sulfur recovery processes. Some facilities have both. 

d

 Unit count assumes all catalytic cracking processes have catalyst regenerators (130+187), and all will use CEMS to 

comply with the NESHAP/NSPS. 

e

 Includes fluid coking, coke calcining, catalytic reforming, asphalt blowing, other process vents. Stationary 

combustion units are covered under subpart C. 

f

Potential facilities or process units that may have equipment installed that could be modified for use in the GHGRP.

   
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Appendix B. Phosphoric Acid Production – Subpart Z

Industry Background

Based on 2011 annual report submissions, there were 13 facilities that reported to GHGRP under 

subpart Z. 

Under subpart Z, facilities estimate CO2 process emissions from each wet-process phosphoric 

acid process line. For CO2 emissions, facilities may either use a mass balance approach or use a 

CEMS to directly measure process emissions. 

Applicable NSPS and NESHAP for Phosphoric Acid Plants

Table Z-1. Applicable NESHAP and NSPS Rules 

NESHAP/NSPS Subparts Reviewed Monitoring Required 

by the NESHAP or 

NSPS 

Would 

Monitoring 

Equipment 

Relevant to Part 

98 be Installed to 

Comply With 

NESHAP or 

NSPS? 

Were Data on 

CEMS Counts 

Available in 

NESHAP or 

NSPS docket? 

Subpart AA—NESHAP From Phosphoric 

Acid Manufacturing Plants 

(No relevant monitoring 

requirements) No No 

Subpart T—Standards of Performance for the 

Phosphate Fertilizer Industry: Wet-Process 

Phosphoric Acid Plants 

(No relevant monitoring 

requirements) No No 

The applicable NESHAP and NSPS for this subpart do not require monitoring which is related to 

CEMS equipment and would thus not facilitate the installation of GHG CEMS. 

Summary of Available Data on Facilities Reporting the Use of CEMS

Based on the ICR survey responses associated with NESHAP development, it is unlikely that 

any of the non-combustion processes use CO2 CEMS. Phosphoric acid process emissions are 

combined with combustion emissions for calciners and dryers at 7 facilities. The ICR indicates 

that the 7 measure O2 instead of CO2. 

Subpart Z CEMS Count

Table Z-2 summarizes the actual data collected for facilities using CO2 CEMS, non-CO2 GHG 

CEMS, and non-GHG CEMS. The table also shows a potential estimate of CEMS usage based 

on assumptions regarding the applicability of NSPS and NESHAP requirements and using the 

background information. 

 
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Table Z-2. Subpart Z CEMS Counts 

Basis CO2 CEMS for 

GHGRP 

Reporting non-CO2

GHG CEMS for 

GHGRP 

Reporting non-GHG CEMS for 

Other EPA Programs 

Actual Potentialb

Facilities NA NA 7a 7a

Units NA NA NA NA 

NA = No information available. 

a

 Counts are based on data reported in the NESHAP ICR responses. 

b

Potential facilities or process units that may have equipment installed that could be modified for use in the GHGRP.
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Appendix B. Pulp and Paper Manufacturing – Subpart AA

Industry Background

The pulp and paper manufacturing source category under subpart AA consists of facilities that do the 

following: 

 Produce market pulp (i.e., stand-alone pulp facilities), 

 Manufacture pulp and paper (i.e., integrated facilities), 

 Produce paper products from purchased pulp, 

 Produce secondary fiber from recycled paper, 

 Convert paper into paperboard products (e.g., containers), or 

 Operate coating and laminating processes. 

Under subpart AA, process emissions are estimated from the following emission units: 

 Chemical recovery furnaces at kraft and soda mills (including recovery furnaces that burn spent 

pulping liquor produced by both the kraft and semichemical process). 

 Chemical recovery combustion units at sulfite facilities. 

 Chemical recovery combustion units at stand-alone semichemical facilities. 

 Pulp mill lime kilns at kraft and soda facilities. 

 Systems for adding makeup chemicals (CaCO3, Na2CO3) in the chemical recovery areas of 

chemical pulp mills. 

Approximately 425 pulp and paper mills operated stationary combustion units (e.g., boilers, gas turbines, 

lime kilns, recovery furnaces, thermal oxidizers) in 2005, based on an industry survey by the National 

Council for Air and Stream Improvement (NCASI) (NCASI 2006). The results of this survey were cited 

in the TSD for subpart AA of part 98. The survey also reported the number of units by the process unit 

categories that are included in subpart AA. The survey estimated about 400 units would be subject to 

GHG emissions reporting under subpart AA. Based on 2011 annual report submissions, there were 110 

facilities that reported to GHGRP under subpart AA. 

Applicable GHGRP, NSPS, and NESHAP Monitoring Requirements for Pulp and Paper Facilities

Table AA-1 summarizes the number of process units identified by the NCASI survey, and also 

summarizes the monitoring requirements for pulp and paper facilities under subpart AA of part 

98, and under the relevant NSPS and NESHAP. 

 
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Table AA-1. Summary of Emission Units and Relevant GHGRP, NSPS, and NESHAP Monitoring 

Requirements Applicable to Subpart AA Facilities 

Mill Type 

Subject to 

Subpart AA 

Process Units 

Subject to 

Subpart AA 

GHG to be 

Monitored 

Under 

Subpart AA 

Estimated 

Number 

of Units 

(NCASI 

Survey)a

Monitoring 

Required by 40 

CFR 60, 

subpart BBb

Monitoring 

Required by 

40 CFR 63, 

subpart S 

Monitoring 

Required by 

40 CFR 63, 

subpart MM 

Kraft or Soda 

Mill 

Each chemical 

recovery 

furnace 

CO2, biogenic 

CO2, CH4, 

N2O 168 

Total reduced 

sulfur (TRS) 

CEMS, O2

CEMS, percent 

volume dry basis 

[60.284(a)(2)] 

No relevant 

monitoring 

No relevant 

monitoring 

Kraft or Soda 

Mill 

Lime Kilns, 

fossil fuel 

combustion 

CO2, biogenic 

CO2, CH4, 

N2O 164 

TRS CEMS, O2

CEMS, percent 

volume dry basis 

[60.284(a)(2)] 

No relevant 

monitoring 

No relevant 

monitoring 

Sulfite Pulp 

Mills 

Each chemical 

recovery 

furnace 

CO2, biogenic 

CO2, CH4, 

N2O 

13 

No relevant 

monitoring 

No relevant 

monitoring 

No relevant 

monitoring 

Stand Alone 

Semichemical 

Mills 

Each chemical 

recovery 

furnace 

CO2, biogenic 

CO2, CH4, 

N2O 

12 

No relevant 

monitoring 

No relevant 

monitoring 

No relevant 

monitoring 

Chemical 

pulp mills 

Makeup 

chemical 

addition to 

chemical 

recovery area 

CO2 

≤55 

No relevant 

monitoring 

No relevant 

monitoring 

No relevant 

monitoring 

Total estimated number of units ≤412 a From TSD for subpart AA, Table 3-1, on page 8; based on an industry survey by the National Council for Air and 

Stream Improvement (NCASI) (NCASI 2006. Pulp and Paper Mill Emissions of SO2, NOX, and Particulate Matter 

in 2005. NCASI Special Report No. 06-07. December 2006.) 

b

 Applies to any kraft pulp mill facility that commenced construction or modification after September 24, 1976. 

Although the applicable NSPS and NESHAP for the pulp and paper industry do require monitoring using 

non-GHG CEMS, information on the number of units performing that monitoring was not available. The 

NSPS (subpart BB) requires oxygen monitoring only for chemical recovery furnaces and pulp mill lime 

kilns at kraft pulp mills. The two Pulp and Paper NESHAP (subparts S and MM) do not require any 

relevant non-GHG CEMS monitoring, except that subpart S allows for an alternative of using a CEMS to 

monitor total HAP or methanol emissions, but we do not have information on the number of facilities that 

have taken this alternative. 

Under the subpart BB NSPS, all of the chemical recovery furnaces and lime kilns at kraft or soda mills 

that have been built or modified since September 24, 1976 should have CEMS for total reduced sulfur 

(TRS), O2, and moisture. This could be a maximum of 332 units (168 + 164), based on the information 

from the NCASI survey. The presence of a TRS, O2, and moisture CEMS would mean that these units 

would also have the basic CEMS infrastructure in place, such as platforms, sampling lines, and data 
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acquisition systems, and this would lower the cost of adding GHG CEMS equipment, such as a CO2

analyzer and flow monitor, at these facilities. 

Summary of Data on Facilities Reporting the Use of CEMS

Data on the number of affected process units at pulp and paper facilities using CEMS (either GHG or 

non-GHG) are available from the GHGRP database, and from data that were collected to develop the 

standards for commercial/industrial solid waste incinerators (CISWI) and the boiler and process heater 

NESHAP. Table AA-2 summarizes these data for the total number of units and those with a CEMS. 

Table AA-2. Summary of CEMS Data from Other EPA Databases 

GHGRP CISWI Database Boiler and Process Heater 

NESHAP Database 

Count of Facilities Which Reported 

CO2 CEMS as Option Within 

GHGRP 

Total Unit Count/Count of Energy 

Recovery Units (ERUs) and Kilns 

with CEMS; Total Facility 

Count/Count of Facilities with nonGHG CEMS 

Total Unit Count/Count of 

Boilers and Process 

Heaters with non-GHG 

CEMS 

-- 

13/9; 9/6 

None of the units appear to be in the 

source category for subpart AA. 

533/160 

No facilities using a GHG CEMS to estimate CO2 emissions were reported through GHGRP. 

In the CISWI and the boiler and process heater survey data, we can identify units that are located at pulp 

and paper facilities using the three-digit NAICS (322, paper manufacturing). From the CISWI data we 

identified nine energy recovery units (ERUs) or kilns at pulp and paper facilities that have some sort of 

CEMS; however, none of the units appear to be process units in the source category for subpart AA. 

In the boiler and process heater NESHAP database, we identified a total of 533 units at pulp and paper 

facilities, and 160 of these units have some sort of CEMS. However, we cannot determine from the 

information in those survey data whether any of those units are process units in the source category for 

subpart AA. 

Subpart AA CEMS Count

Table AA-4 summarizes the actual data collected for facilities and units using CO2 CEMS, non-CO2 GHG 

CEMS, and non-GHG CEMS. The table also shows a potential estimate of CEMS usage based on 

assumptions regarding the applicability of NSPS and NESHAP requirements and using the background 

information. 

Table AA-4. Subpart AA CEMS Counts 

Basis CO2 CEMS for 

GHGRP 

Reporting non-CO2

GHG CEMS for 

GHGRP 

Reporting non-GHG CEMS for 

Other EPA Programs 

Actual Potentialb
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Facilities NA NA NA NA 

Units NA NA 266a 266a

NA = No information available 

a The NCASI survey provided process unit data and the 2009 RIA estimated that units were subject to Tier 4 requirements. 

However, these count data and the count for facilities that reported to GHGRP in 2011 (110) could not be directly related. 

Therefore, based on the data, unit and facility counts were estimated. 

b

Potential facilities or process units that may have equipment installed that could be modified for use in the GHGRP.

Based on the NSPS requirements, a large percentage of subpart AA units are likely to have TRS and O2

CEMS and, therefore, already have some basic infrastructure for a CEMS that could be used to estimate 

GHG emissions with the addition of a flow meter and CO2 analyzer. Similarly, the RIA estimates that a 

large portion of the sources will meet Tier 4 requirements. However, because the number of facilities 

reporting to GHGRP (110) is substantially lower than the number reported through the NCASI survey 

(425), an adjustment to the unit data was necessary. It was estimated that each facility would have at least 

three units; this is based on data from the NCASI survey. Therefore, 330 total units were estimated for the 

110 facilities. Of these, approximately 80% of the units were assumed to have a CEMS installed. This 

was calculated as the number of units at kraft and soda mills (168+164 = 332) which may have CEMS to 

comply with subpart BB, divided by the total unit count (412). Performing this calculation yields 

approximately 266 units with non-GHG CEMS. 

 
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Appendix B. Silicon Carbide Production – Subpart BB

Industry Background

Based on 2011 annual report submissions, there were 1 facility that reported to GHGRP under 

subpart BB. 

Under subpart BB, facilities estimate CO2 and CH4 process emissions from all silicon carbide 

process units or furnaces combined. For estimating CO2 process emissions, facilities may either 

use a mass balance approach or use a CEMS. Process emissions of CH4 are estimated using 

emission factors relevant to the monthly amount of petroleum coke consumed at the facility. 

Applicable NSPS and NESHAP for Silicon Carbide Manufacturers

There is no NSPS or NESHAP specifically applicable to silicon carbide manufacturers. 

Summary of Available Data on Facilities Reporting the Use of CEMS

No data on CEMS counts applicable to subpart BB facilities were available. 

Subpart BB CEMS Count

Table BB-1 summarizes the actual data collected for facilities using CO2 CEMS, non-CO2 GHG 

CEMS, and non-GHG CEMS. No facilities were identified with pre-existing CO2 CEMS. No 

assumption could be made for a potential count based on lack of information on control devices 

and monitoring requirements. 

Table BB-1. Subpart BB CEMS Counts 

Basis CO2 CEMS for 

GHGRP 

Reporting non-CO2

GHG CEMS for 

GHGRP 

Reporting non-GHG CEMS for 

Other EPA Programs 

Actual Potentiala

Facilities NA NA NA NA 

Units NA NA NA NA 

NA = No information available. 

a

Potential facilities or process units that may have equipment installed that could be modified for use in the GHGRP.

 
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Appendix B. Soda Ash Manufacturing – Subpart CC

Industry Background

Based on 2011 annual report submissions, there were 4 facilities that reported to GHGRP under 

subpart CC. 

Under subpart CC, facilities estimate CO2 process emissions from each soda ash manufacturing 

line and CO2 combustion emissions from each soda ash manufacturing line. They are also 

required to estimate and report CH4 and N2O combustion emissions from each soda ash 

manufacturing line. For CO2 emissions, facilities may use a mass balance or emission factor 

approach to estimate separate process and combustion emissions, or use a CEMS to determine 

combined process and combustion emissions. 

Applicable NSPS and NESHAP for Soda Ash Plants

Table CC-1. Applicable NESHAP and NSPS Rules 

NESHAP/NSPS Subparts Reviewed Monitoring Required 

by the NESHAP or 

NSPS 

Would 

Monitoring 

Equipment 

Relevant to Part 

98 be Installed to 

Comply With 

NESHAP or 

NSPS? 

Were Data on 

CEMS Counts 

Available in 

NESHAP or 

NSPS docket? 

Subpart OOO—Standards of Performance for 

Nonmetallic Mineral Processing Plants 

(No relevant monitoring 

requirements) No No 

Subpart UUU—Standards of Performance for 

Calciners and Dryers in Mineral Industries

(No relevant monitoring 

requirements) No No 

The applicable NESHAP and NSPS for this subpart do not require monitoring which is related to 

CEMS equipment and would thus not facilitate the installation of GHG CEMS. 

Summary of Available Data on Facilities Reporting the Use of CEMS

One facility reported the use of one CO2 CEMS to report emissions. 

Subpart CC CEMS Count

Table CC-2 summarizes the actual data collected for facilities using CO2 CEMS, non-CO2 GHG 

CEMS, and non-GHG CEMS. No facilities were identified with pre-existing CO2 CEMS. No 

assumption could be made for a potential count based on lack of information on control devices 

and monitoring requirements. 

 
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Table CC-2. Subpart CC CEMS Counts 

Basis CO2 CEMS for 

GHGRP 

Reporting non-CO2

GHG CEMS for 

GHGRP 

Reporting non-GHG CEMS for 

Other EPA Programs 

Actual Potentialc

Facilities 1a

 NA NA NA 

Units 1b

 NA NA NA 

NA = No information available. 

a Number of facilities reporting to GHGRP in 2011 that they are using a CEMS to report CO2 emissions. 

b

 The total number of CO2 CEMS at the facilities which reported CO2 CEMS. c

Potential facilities or process units that may have equipment installed that could be modified for use in the GHGRP. 

 
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Appendix B. Titanium Dioxide Production – Subpart EE

Industry Background

Based on 2011 annual report submissions, there were 7 facilities that reported to GHGRP under 

subpart EE. 

Under subpart EE, facilities estimate CO2 process emissions from each chloride process line. For 

estimating CO2 process emissions, facilities may either use a mass balance approach or use a 

CEMS. 

Applicable NSPS and NESHAP for Titanium Dioxide Plants

Table EE-1. Applicable NESHAP and NSPS Rules 

NESHAP/NSPS Subparts 

Reviewed 

Monitoring Required 

by the NESHAP or 

NSPS 

Would Monitoring 

Equipment Relevant to 

Part 98 be Installed to 

Comply With NESHAP 

or NSPS? 

Were Data on 

CEMS Counts 

Available in 

NESHAP or 

NSPS docket? 

Subpart LL—Standards of 

Performance for Metallic Mineral 

Processing Plants 

(No relevant monitoring 

requirements) No No 

The applicable NESHAP and NSPS for this subpart do not require monitoring which is related to 

CEMS equipment and would thus not facilitate the installation of GHG CEMS. 

Summary of Available Data on Facilities Reporting the Use of CEMS

No data on CEMS counts applicable to subpart EE facilities were available. 

Subpart EE CEMS Count

Table EE-2 summarizes the actual data collected for facilities using CO2 CEMS, non-CO2 GHG 

CEMS, and non-GHG CEMS. No facilities were identified with pre-existing CO2 CEMS. No 

assumption could be made for a potential count based on lack of information on control devices 

and monitoring requirements. 

Table EE-2. Subpart EE CEMS Counts 

Basis CO2 CEMS for 

GHGRP 

Reporting non-CO2

GHG CEMS for 

GHGRP 

Reporting non-GHG CEMS 

for Other EPA Programs 

Actual Potentiala

Facilities NA NA NA NA 

Units NA NA NA NA 

NA = No information available. a

Potential facilities or process units that may have equipment installed that could be modified for use in the GHGRP.
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Appendix B. Zinc Production – Subpart GG

Industry Background

Based on 2011 annual report submissions, there were 6 facilities that reported to GHGRP under 

subpart GG. 

Under subpart GG, facilities estimate CO2 process emissions from each Waelz kiln and 

electrothermic furnace, and CO2 combustion emissions from each Waelz kiln and electrothermic 

furnace. They are also required to estimate and report CH4 and N2O combustion emissions from 

each Waelz kiln and electrothermic furnace. For CO2 emissions, facilities may use a mass 

balance or emission factor approach to estimate separate process and combustion emissions, or 

use a CEMS to determine combined process and combustion emissions. 

Applicable NSPS and NESHAP for Zinc Plants

Table GG-1. Applicable NESHAP and NSPS Rules 

NESHAP/NSPS Subparts Reviewed Monitoring Required 

by the NESHAP or 

NSPS 

Would 

Monitoring 

Equipment 

Relevant to Part 

98 be Installed to 

Comply With 

NESHAP or 

NSPS? 

Were Data on 

CEMS Counts 

Available in 

NESHAP or 

NSPS docket? 

Subpart Q—Standards of Performance for 

Primary Zinc Smelters 

SO2 CEMS required for 

facilities constructed or 

modified after October 

16, 1974 

No No 

Subpart LL—Standards of Performance for 

Metallic Mineral Processing Plants

(No relevant monitoring 

requirements) No No 

Subpart GGGGGG—NESHAP for Primary 

Nonferrous Metals Area Sources—Zinc, 

Cadmium, and Beryllium 

(No relevant monitoring 

requirements) No No 

Subpart TTTTTT—NESHAP for Secondary 

Nonferrous Metals Processing Area Sources 

(No relevant monitoring 

requirements) No No 

SO2 CEMS is only applicable for roasters at primary zinc smelters which are not applicable to 

GHG reporting and are thus not related to GHG CEMS installation. 

Summary of Available Data on Facilities Reporting the Use of CEMS

No data on CEMS counts applicable to subpart GG facilities were available. 

 
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Subpart GG CEMS Count

Table GG-2 summarizes the actual data collected for facilities using CO2 CEMS, non-CO2 GHG 

CEMS, and non-GHG CEMS. No facilities were identified with pre-existing CO2 CEMS. No 

assumption could be made for a potential count based on lack of information on control devices 

and monitoring requirements. 

Table GG-2. Subpart CC CEMS Counts 

Basis CO2 CEMS for 

GHGRP 

Reporting non-CO2

GHG CEMS for 

GHGRP 

Reporting non-GHG CEMS for 

Other EPA Programs 

Actual Potentiala

Facilities NA NA NA NA 

Units NA NA NA NA 

NA = No information available. 

a

Potential facilities or process units that may have equipment installed that could be modified for use in the GHGRP.

 
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Appendix B. Industrial Waste Landfills – Subpart TT

Industry Background

Based on 2011 annual report submissions, there were 173 facilities that reported to GHGRP 

under subpart TT. 

Under subpart TT, facilities must estimate annual CH4 generation, emission, and destruction 

from the landfill. For estimating CH4 generation, facilities may measure the generation directly 

or estimate a value based on historic annual waste disposal quantities. Facilities that collect and 

control landfill gas must calculate CH4 emissions using two methods: First, a mass balance 

method using the equations provided in subpart TT; and second, by applying a gas collection 

efficiency to the measured amount of CH4 recovered. 

Applicable NSPS and NESHAP for Industrial Waste Landfills

There are no NSPS or NESHAP which are applicable to industrial waste landfills. The definition 

of industrial waste landfills for purposes of the GHGRP specifically excludes municipal waste 

landfills, so part 60 subpart WWW (NSPS for MSW Landfills) is not applicable. 

Summary of Available Data on Facilities Reporting the Use of CEMS

No data on CEMS counts applicable to subpart TT facilities were available. It is noted in subpart 

TT that industrial waste landfills may collect methane with a gas collection system. If they do the 

rule requires them to report the annual CH4 recovered. The method of recording the amount of 

methane recovered using the gas collection system is unknown, so the applicability of CH4

CEMS is also unknown. For these purposes it will be assumed that no facility uses CEMS to 

monitor CH4 recovery. Also, for those industrial waste landfills which have gas collection 

systems, the facility is required to monitor the flow rate and temperature; the applicability of this 

equipment to installing CEMS (e.g., is the flow monitor located at a position which would also 

meet flow monitor requirements for CEMS) is also unknown. 

Subpart TT CEMS Count

Table TT-1 summarizes the actual data collected for facilities using CO2 CEMS, non-CO2 GHG 

CEMS, and non-GHG CEMS. No facilities were identified with pre-existing CH4 CEMS. No 

assumption could be made for a potential count based on lack of information. 

Table TT-1. RSubpart TT CEMS Counts 

Basis CO2 CEMS for 

GHGRP 

Reporting non-CO2

GHG CEMS for 

GHGRP 

Reporting non-GHG CEMS for 

Other EPA Programs 

Actual Potentiala

Facilities NA NA NA NA 

Units NA NA NA NA 
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NA = No information available. 

a

Potential facilities or process units that may have equipment installed that could be modified for use in the GHGRP.

 
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Appendix C 

Detailed CEMS Costing for Subparts with “Inputs to Equations” 

 
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Appendix C 

Detailed GHG CEMS Cost Analysis 

==================================================================== 

C.1 GHG CEMS Cost Assumptions 

To determine the economic impact of installing GHG CEMS for each subpart, a determination of 

the applicable population of sources for each subpart was needed. This included the total count 

of facilities and process units in each subpart and the count of CEMS which are currently 

installed. Data for current CEMS included installations of GHG CEMS (CO2, CH4, or N2O) and 

non-GHG CEMS (NOX, PM, CO, etc.). When determining the GHG CEMS cost for each 

subpart, data at the process unit level is the most relevant. A facility may have multiple process 

units and thus multiple emission sources (e.g., multiple stacks) which would each need their own 

CEMS. However, for some subparts this level of detail was not available and only facility counts 

were known. In those instances, only the facility count was used to determine the CEMS cost; 

while this may underestimate costs for certain subparts, due to a lack of data, it was not possible 

to provide a reliable count for number of process units. To determine counts the following 

sources were used: GHGRP data, part 98 GHG technical support documents for each subpart, a 

review of applicable NESHAP and NSPS rule requirements and associated databases and 

supporting documentation for each subpart, and the part 98 GHG Regulatory Impact Analysis 

(RIA). See Appendix B for a review of the information obtained. 

 

To keep this CEMS cost analysis consistent with the GHG RIA, the same method of 

determining capital and annual costs was used. As shown in section 3.1, the following CEMS 

usages were identified: 

 Source has CO2 CEMS 

 Source has non-CO2 GHG CEMS (such as N2O CEMS) or has non-GHG CEMS (such as 

NOX or CO monitors) 

 Source has no CEMS 

Five different cost scenarios were identified from the usage information and are summarized in 

Table C-1. Cost scenario 1 is a complete GHG CEMS installation for sources which do not have 

any CEMS related equipment installed. Cost scenarios 2 through 4 are reduced costs for sources 

which have current CEMS installations and would need to install minimal equipment (e.g., a 

CO2 analyzer and/or flow meter). The decision to apply scenarios 2, 3, or 4 costs to a particular 

subpart is based off applicable NSPS/NESHAP regulation knowledge and information provided 

in the GHG RIA. It was determined that no facilities/process units met the requirements for 

scenario 4 (see Appendix B for regulatory review results for each subpart). Therefore, no costs 

were estimated for scenario 4. Scenario 5 is a facility/process unit that already has CO2 CEMs 

and no costs are calculated. 

 
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Table C-1. Summary of Costs for CO2 CEMS Modifications 

Scenario 

# Scenario

Total annual 

costs

1 Source has no CEMS -- Add CO2 analyzer, flow meter, and 

infrastructure $ 70,265 

2 Source has CEMS for other pollutants -- Add CO2 analyzer 

and flow meter $ 56,040 

3 Source has CEMS for other pollutants -- Add CO2 analyzer 

only $ 20,593 

4a Source has CEMS for other pollutants -- Add flow monitor 

only $ 24,511 

5 Source has CO2 CEMS No Cost a

No facilities/process units were determined to meet the scenario. 

 

Within each scenario, multiple cost scenarios were calculated because each subpart may require 

one analyzer or a combination of analyzers to measure GHGs. The most common GHG to report 

is CO2, however CH4 and N2O are also applicable depending on the subpart. While the GHG 

RIA provided a cost estimate for a CO2 CEMS, CH4 and N2O CEMS costs were not available. 

For this analysis, vendors were contacted and cost estimates were developed for these methods 

as well. With these additional data, costs were estimated for installing each CEMS analyzer on a 

stand-alone basis and costs were also calculated for installing all three analyzers at one source or 

a combination of two analyzers at one source. Subpart O requires reporting of fluorinated gases; 

the applicability of CEMS for fluorinated gases was not analyzed, and therefore no costs were 

calculated for subpart O. Table C-2 summarizes the vendor cost information. 

Costs for each subpart were determined based on the count information identified (see Appendix 

B for subpart-specific details) and the scenario cost options. Costs were determined based on the 

following hierarchy: 

 If no current CEMS installations were identified then the total facility/process unit count 

was multiplied by the scenario 1 cost for installing the appropriate GHG CEMS. 

 If current non-CO2 CEMS installations were identified for a subpart then either scenario 

2 or 3 costs were applied for these counts depending on the type of CEMS identified. For 

facility/process units without current non-CO2 CEMs, the scenario 1 costs were applied. 

These two costs were added together to get the total cost for the facility. 

 For subparts which have a CO2 CEMS installed but would also report CH4 and/or N2O, 

only the cost associated with installing a CH4 and/or N2O analyzer was incorporated, and 

no costs for CO2 analyzers were included. 

Costs are shown for each subpart based on two count options: actual and potential CEMS counts. 

The actual count and associated CEMS costs correspond to the actual CEMS installation counts 

which were able to be identified from the various sources discussed previously. The potential 
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110 

count and associated CEMS costs correspond to the potential CEMS installation counts which 

were estimated based on requirements in NSPS and NESHAP rules. The potential counts include 

the actual counts plus the additional units/facilities that may be affected by NSPS or NESHAP 

requirements. The costs associated with the actual count resulted in higher costs than the 

potential count scenario, as fewer current CEMS installations were estimated which results in a 

higher number of scenario 1 (complete installation) costs. For the costs associated with the 

potential count, the resulting costs were lower than the actual count scenario because more 

CEMS installations were estimated which resulted in fewer units in scenario 1 and more in 

scenarios 2 or 3. For many subparts, the actual and potential CEMS counts are identical, 

however. 

Table C-2. Summary of Vendor Cost Information Collected 

Equipment

Altech

Environmental

CEMS Experts

(GK Associates) EnviroServ

Cemtek

Environmental Average

Average

(Rounded)

CO2 analyzer $5,000 (a) $15,000‐$20,000 $12,000   $7,917   $12,472   $13,000  

N2O analyzer $5,000 (a) $15,000‐$20,000 $15,000   $10,096   $14,199   $14,000  

CH4 analyzer $5,000 (a) $15,000‐$20,000 $12,000   $18,019   $15,840   $16,000  

Sampling system  ‐‐  ‐‐  ‐‐  $9,766   $9,766   $10,000  

DAS, including

software $30,000‐$40,000  ‐‐  ‐‐  $19,931   $27,466   $28,000  

Flow monitors $27,000   $15,000‐$20,000 ‐‐  $26,250   $23,583   $24,000  

Notes:

‐ When cost ranges were provided, the average of the range was used to estimate costs.

(a) Did not include Altech analyzer costs in average per note from Altech that their analyzer costs are typically

lower than normal due to the method by which they price their equipment.

C.2 GHG CEMS Cost Results 

Based on the counts for each subpart and their breakdown into counts for each scenario, costs for 

installing GHG CEMS were estimated. Section C.2 summarizes the estimated costs for each 

subpart and the overall cost to industry. 

Tables C-3 through C-11 show the resultant total capital investment and annualized CEMS costs 

(actual and potential) for each subpart, the number of sources with existing GHG or non-GHG 

CEMS for each subpart, and the division of affected sources into the four cost scenarios for each 

subpart. Tables C-3 and C-4 summarize capital and annual costs for installation of CO2 CEMS 

only (similar to the GHG RIA). Tables C-5 through C-7 summarize the count information for 

actual and potential units/facilities with CEMS control, and the assumptions used in the count 

determination. Tables C-8 through C-11 provide data on all three types of GHG CEMS (CO2, 

N2O, and CH4). Tables C-8 and C-9 show the capital and annual cost estimates based on actual 

counts. Tables C-10 and C-11 show the capital and annual cost estimates based on potential 

counts. 

For subparts which require multiple GHG CEMS, distributing the total unit installation cost 

between two or three CEMS is not appropriate; there are redundant component costs associated 
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111 

with CO2, CH4, and N2O CEMS. If a facility were to install CEMS for all three GHGs, for 

example, the total cost incurred by the facility would not equal the sum of the CO2, CH4, and 

N2O individual monitor costs. Instead, cost estimates were developed based on vendor quotes for 

each possible combination of CO2, CH4, and N2O CEMS for each cost scenario. For this reason, 

the CO2, N2O, and CH4 costs in Tables C-8 through C-11 do not equal the total cost column; the 

CO2, N2O, and CH4 costs shown are the cost for installing individual GHG CEMS while the total 

cost is the more representative cost for installing multiple GHG CEMS. 
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112 

Table C-3. Capital Cost Breakdown into Each Costing Scenario for Installation of CO2 CEMS Only, Based on Actual Counts and 

Subpart

Capital Investment

Scenario 1 Scenario 2 Scenario 3 Total

Actuala Potentialb Actuala Potentialb Actuala Potentialb Actuala Potentia

C $1,578,065,753 $1,578,065,753 $102,182,259 $111,374,792 $0 $0 $1,680,248,013 $1,689,440

E $ ‐  $ ‐  $ ‐ $ ‐ $ ‐ $ ‐  $ ‐ 

F $1,229,981 $1,229,981 $ ‐ $ ‐ $ ‐ $ ‐  $1,229,981 $1,229

G $2,705,958 $2,705,958 $ ‐ $ ‐ $ ‐ $ ‐  $2,705,958 $2,705H $3,443,947 $ ‐  $ ‐ $ ‐ $560,101 $560,101 $4,004,048 $560

K $1,229,981 $1,229,981 $ ‐ $ ‐ $ ‐ $ ‐  $1,229,981 $1,229

L $ ‐  $ ‐  $ ‐ $ ‐ $ ‐ $ ‐  $ ‐ 

N $13,160,798 $13,160,798 $ ‐ $ ‐ $ ‐ $ ‐  $13,160,798 $13,160

O $ ‐  $ ‐  $ ‐ $ ‐ $ ‐ $ ‐  $ ‐ 

P $12,299,811 $12,299,811 $ ‐ $ ‐ $ ‐ $ ‐  $12,299,811 $12,299

Q $18,572,715 $18,572,715 $ ‐ $ ‐ $ ‐ $ ‐  $18,572,715 $18,572

R $1,598,975 $1,598,975 $ ‐ $ ‐ $ ‐ $ ‐  $1,598,975 $1,598

S $8,855,864 $ ‐  $ ‐ $ ‐ $ ‐ $ ‐  $8,855,864 

U $2,213,966 $2,213,966 $0 $0 $0 $0 $2,213,966 $2,213

V $ ‐  $ ‐  $ ‐ $ ‐ $ ‐ $ ‐  $ ‐ 

X $7,625,883 $7,871,879 $ ‐ $ ‐ $ ‐ $ ‐  $7,625,883 $7,871

Y $191,139,063 $155,346,613 $ ‐ $18,094,775 $ ‐ $2,080,376 $191,139,063 $175,521

Z $737,989 $737,989 $ ‐ $ ‐ $140,025 $140,025 $878,014 $878

AA $7,881,432 $7,881,432 $25,731,576 $25,731,576 $ ‐ $ ‐  $33,613,009 $33,613

BB $122,998 $122,998 $ ‐ $ ‐ $ ‐ $ ‐  $122,998 $122

CC $368,994 $368,994 $ ‐ $ ‐ $ ‐ $ ‐  $368,994 $368

EE $860,987 $860,987 $ ‐ $ ‐ $ ‐ $ ‐  $860,987 $860

GG $737,989 $737,989 $ ‐ $ ‐ $ ‐ $ ‐  $737,989 $737

TT $ ‐  $ ‐  $ ‐ $ ‐ $ ‐ $ ‐  $ ‐ 

TOTAL $1,852,853,085 $1,800,578,888 $127,913,836 $158,684,630 $700,127 $2,780,503 $1,981,467,047 $1,962,044

aCosts are based on the actual number of units/facilities for which information was available indicating current use of CEMS. See Appendix B 

subpart. 

bCosts are based on potential number of units/facilities that may be using CEMS based on NESHAP and NSPS rule requirements. Costs includ

where information is known as well as the additional potential number of units/facilities that may be using CEMS based on NESHAP and NSP

Appendix B for detailed information for each subpart. 
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Table C-4. Annual Cost Breakdown into Each Costing Scenario for Installation of CO2 CEMS Only, Based on Actual 

Subpart

Annual Cost

Scenario 1 Scenario 2 Scenario 3 Total

Actuala Potentialb Actuala Potentialb Actuala Potentialb Actuala Potenti

C $901,499,950 $901,499,950 $59,178,240 $64,502,040 $ ‐ $ ‐  $960,678,190 $966,00

E $ ‐  $ ‐  $ ‐ $ ‐ $ ‐ $ ‐  $ ‐ 

F $702,650 $702,650 $ ‐ $ ‐ $ ‐ $ ‐  $702,650 $70

G $1,545,830 $1,545,830 $ ‐ $ ‐ $ ‐ $ ‐  $1,545,830 $1,54H $1,967,420 $ ‐  $ ‐ $ ‐ $576,604 $576,604 $2,544,024 $57

K $702,650 $702,650 $ ‐ $ ‐ $ ‐ $ ‐  $702,650 $70

L $ ‐  $ ‐  $ ‐ $ ‐ $ ‐ $ ‐  $ ‐ 

N $7,518,355 $7,518,355 $ ‐ $ ‐ $ ‐ $ ‐  $7,518,355 $7,51

O $ ‐  $ ‐  $ ‐ $ ‐ $ ‐ $ ‐  $ ‐ 

P $7,026,500 $7,026,500 $ ‐ $ ‐ $ ‐ $ ‐  $7,026,500 $7,02

Q $10,610,015 $10,610,015 $ ‐ $ ‐ $ ‐ $ ‐  $10,610,015 $10,61

R $913,445 $913,445 $ ‐ $ ‐ $ ‐ $ ‐  $913,445 $91

S $5,059,080 $ ‐  $ ‐ $ ‐ $ ‐ $ ‐  $5,059,080 

U $1,264,770 $1,264,770 $0 $0 $0 $0 $1,264,770 $1,26

V $ ‐  $ ‐  $ ‐ $ ‐ $ ‐ $ ‐  $ ‐ 

X $4,356,430 $4,496,960 $ ‐ $ ‐ $ ‐ $ ‐  $4,356,430 $4,49

Y $109,191,810 $88,744,695 $ ‐ $10,479,480 $ ‐ $2,141,672 $109,191,810 $101,36

Z $421,590 $421,590 $ ‐ $ ‐ $144,151 $144,151 $565,741 $56

AA $4,502,417 $4,502,417 $14,902,287 $14,902,287 $ ‐ $ ‐  $19,404,705 $19,40

BB $70,265 $70,265 $ ‐ $ ‐ $ ‐ $ ‐  $70,265 $7

CC $210,795 $210,795 $ ‐ $ ‐ $ ‐ $ ‐  $210,795 $21

EE $491,855 $491,855 $ ‐ $ ‐ $ ‐ $ ‐  $491,855 $49

GG $421,590 $421,590 $ ‐ $ ‐ $ ‐ $ ‐  $421,590 $42

TT $ ‐  $ ‐  $ ‐ $ ‐ $ ‐ $ ‐  $ ‐ 

TOTAL $1,058,477,417 $1,031,144,332 $74,080,527 $89,883,807 $720,755 $2,862,427 $1,133,278,700 $1,123,37

aCosts are based on the actual number of units/facilities for which information was available indicating current use of CEMS. See Appendix B 

subpart. 

bCosts are based on potential number of units/facilities that may be using CEMS based on NESHAP and NSPS rule requirements. Costs includ

where information is known as well as the additional potential number of units/facilities that may be using CEMS based on NESHAP and NSP

Appendix B for detailed information for each subpart.
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Table C-5. Total Facility and Units Counts and Current CEMS Installation Countsa

Subpart

Number of Affected... Does Subpart Require Reporting Emissions of: Number with CO2 CEMS Number with non‐CO2 GH

CEMS 

Facilities Units CO2? N2O? CH4? Facilities Units Facilities Units 

C 1,985 14,197 YES YES YES 177 311 unknown unknown 

E 3 3 NO YES NO unknown unknown unknown unknown 

F 10 10 YES NO NO unknown unknown unknown unknown 

G 22 22 YES NO NO unknown unknown unknown unknown 

H 96 140 YES YES YES 82 112 0 0 

K 10 10 YES NO YES unknown unknown unknown unknown 

L 16 16 NO NO NO unknown unknown 1 5 

N 110 110 YES YES YES 3 3 unknown unknown 

O 5 5 NO NO NO unknown unknown unknown unknown 

P 103 103 YES YES YES 3 3 unknown unknown 

Q 128 165 YES YES YES 11 14 unknown unknown 

R 13 13 YES YES YES unknown unknown unknown unknown 

S 73 73 YES YES YES 1 to 73 1 to 73 unknown unknown 

U 18 18 YES NO NO unknown unknown unknown unknown 

V 36 65 NO YES NO unknown unknown 0 0 

X 64 64 YES YES YES 2 2 unknown unknown 

Y 145 1,580 YES YES YES 21 26 unknown unknown 

Z 13 13 YES NO NO unknown unknown unknown unknown 

AA 110 330 YES YES YES unknown 0 to 36 unknown unknown 

BB 1 1 YES NO YES unknown unknown unknown unknown 

CC 4 4 YES YES YES 1 1 unknown unknown 

EE 7 7 YES NO NO unknown unknown unknown unknown 

GG 6 6 YES YES YES unknown unknown unknown unknown 

TT 173 173 NO NO YES unknown unknown unknown unknown 

a See Appendix B for detailed summary for each subpart. 
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Table C-6. Counts Used to Determine Costs for Each Scenario, Actual CEMS countsa

Subpart

Number in Scenario 1 Number in Scenario 2 Number in 

Facilities Units Facilities Units Facilities 

CO2 N2O CH4 Total CO2 N2O CH4 Total CO2 N2O CH4 Total CO2 N2O CH4 Total CO2 N2O CH4

Tota

l CO

C NA NA NA NA 12,830 12,830 12,830 12,830 NA NA NA NA 1,056 1,056 1,056 1,056 0 177 177 177 0 

E 0 3 0 3 0 3 0 3 0 0 0 0 0 0 0 0 0 0 0 0 0 

F 10 0 0 10 10 0 0 10 0 0 0 0 0 0 0 0 0 0 0 0 0 

G 22 0 0 22 22 0 0 22 0 0 0 0 0 0 0 0 0 0 0 0 0 H 14 14 14 14 28 28 28 28 0 0 0 0 0 0 0 0 14 82 82 82 2

K 10 0 10 10 10 0 10 10 0 0 0 0 0 0 0 0 0 0 0 0 0 

L 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

N 107 107 107 107 107 107 107 107 0 0 0 0 0 0 0 0 0 3 3 3 0 

O 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

P 100 100 100 100 100 100 100 100 0 0 0 0 0 0 0 0 0 3 3 3 0 

Q 117 117 117 117 151 151 151 151 0 0 0 0 0 0 0 0 0 11 11 11 0 

R 13 13 13 13 13 13 13 13 0 0 0 0 0 0 0 0 0 0 0 0 0 

S 72 72 72 72 72 72 72 72 0 0 0 0 0 0 0 0 0 1 1 1 0 

U 18 0 0 18 18 0 0 18 0 0 0 0 0 0 0 0 0 0 0 0 0 

V 0 16 0 16 0 29 0 29 0 0 0 0 0 0 0 0 0 20 0 20 0 

X 62 62 62 62 62 62 62 62 0 0 0 0 0 0 0 0 0 2 2 2 0 

Y NA NA NA NA 1,554 1,554 1,554 1,554 0 0 0 0 0 0 0 0 NA NA NA NA 0 

Z 6 0 0 6 6 0 0 6 0 0 0 0 0 0 0 0 7 0 0 7 7 

AA 21 21 21 21 64 64 64 64 89 89 89 89 266 266 266 266 0 0 0 0 0 

BB 1 0 1 1 1 0 1 1 0 0 0 0 0 0 0 0 0 0 0 0 0 

CC 3 3 3 3 3 3 3 3 0 0 0 0 0 0 0 0 0 1 1 1 0 

EE 7 0 0 7 7 0 0 7 0 0 0 0 0 0 0 0 0 0 0 0 0 

GG 6 6 6 6 6 6 6 6 0 0 0 0 0 0 0 0 0 0 0 0 0 

TT 0 0 173 173 0 0 173 173 0 0 0 0 0 0 0 0 0 0 0 0 0 

a See Appendix B for detailed summary for each subpart. 

NA = Data not available on basis. 
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116 

Table C-6 (cont.) Notes Explaining the Actual CEMS Count Distribution for Each Subpart 

Subpart NOTES – Actual CEMS Counts

C Boiler and CISWI databases reviewed to get count of units with CEMS (1,056). None of the relevant regulations require CO2 or flow monitors, b

CEMS systems for other pollutants. Assumed that all 1,056 Tier 4 units would be in scenario 2 and units with known CO2 CEMS would be in scen

E Current CEMS installation unknown; assumed all facilities/units in scenario 1.

F Current CEMS installation unknown; assumed all facilities/units in scenario 1.

G Current CEMS installation unknown; assumed all facilities/units in scenario 1.

H Assumed units with current CEMS installations would be in scenario 3.

K Current CEMS installation unknown; assumed all facilities/units in scenario 1.

L CO2, N2O, and CH4 not required to be reported for this subpart, thus no associated costs or unit counts.

N Scenario 3 costs applied to facilities with CO2 CEMS, others assumed to be in scenario 1. Assumption made that the facilities with CO2 CEMS ha

O CO2, N2O, nor CH4 required to be reported for this subpart, thus no associated costs or unit counts.

P Scenario 3 costs applied to facilities with CO2 CEMS, others assumed to be in scenario 1. Assumption made that the facilities with CO2 CEMS ha

Q Scenario 3 costs applied to facilities with CO2 CEMS, others assumed to be in scenario 1. Assumption made that the facilities with CO2 CEMS ha

R Current CEMS installation unknown; assumed all facilities/units in scenario 1.

S

The RIA for part 98 identified all facilities being applicable to Tier 4 requirements and would thus install a CO2 CEMS. Note, however, that this c

exclusive to subpart S emissions sources and, for example, some of the identified units may fall under subpart C. For the actuals count, it was as

would be in scenario 1 (except the 1 facility with a known CO2 CEMS).

U Current CEMS installation unknown; assumed all facilities/units in scenario 1.

V Scenario 3 costs applied to facilities with CEMS, others assumed to be in scenario 1.

X Scenario 3 costs applied to facilities with CO2 CEMS, others assumed to be in scenario 1. Assumption made that the facilities with CO2 CEMS ha

Y Scenario 3 costs applied to facilities with CO2 CEMS, others assumed to be in scenario 1. For actual CEMS count, assumed zero facilities have no

installed.

Z Scenario 3 costs applied to facilities with CEMS, others assumed to be in scenario 1.

AA Scenario 2 costs applied for facilities with CEMS; based off GHG RIA estimate that most facilities would meet this for Tier IV requirements.

BB Current CEMS installation unknown; assumed all facilities/units in scenario 1.

CC Scenario 3 costs applied to facilities with CO2 CEMS, others assumed to be in scenario 1. Assumption made that the facilities with CO2 CEMS ha

EE Current CEMS installation unknown; assumed all facilities/units in scenario 1.

GG Current CEMS installation unknown; assumed all facilities/units in scenario 1.

TT Current CEMS installation unknown; assumed all facilities/units in scenario 1.
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117 

Table C-7. Counts Used to Determine Costs for Each Scenario, Potential CEMS Countsa

Subpart

Number in Scenario 1 Number in Scenario 2 Nu

Facilities Units Facilities Units Facilities 

CO2 N2O CH4 Total CO2 N2O CH4 Total CO2 N2O CH4 Total CO2 N2O CH4 Total CO2 N2O CH4 

C NA NA NA NA 12,830 12,830 12,830 12,830 NA NA NA NA 1,151 1,151 1,151 1,151 0 177 177 

E 0 3 0 3 0 3 0 3 0 0 0 0 0 0 0 0 0 0 0 

F 10 0 0 10 10 0 0 10 0 0 0 0 0 0 0 0 0 0 0 

G 22 0 0 22 22 0 0 22 0 0 0 0 0 0 0 0 0 0 0 

H 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 18 96 96 

K 10 0 10 10 10 0 10 10 0 0 0 0 0 0 0 0 0 0 0 

L 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

N 107 107 107 107 107 107 107 107 0 0 0 0 0 0 0 0 0 3 3 

O 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 

P 100 100 100 100 100 100 100 100 0 0 0 0 0 0 0 0 0 3 3 

Q 117 117 117 117 151 151 151 151 0 0 0 0 0 0 0 0 0 11 11 

R 13 13 13 13 13 13 13 13 0 0 0 0 0 0 0 0 0 0 0 

S 0 0 0 0 0 0 0 0 0 73 73 73 0 73 73 73 0 0 0 

U 18 0 0 18 18 0 0 18 0 0 0 0 0 0 0 0 0 0 0 

V 0 16 0 16 0 29 0 29 0 0 0 0 0 0 0 0 0 20 0 

X 64 64 64 64 64 64 64 64 0 0 0 0 0 0 0 0 0 2 2 

Y NA NA NA NA 1,263 1,263 1,263 1,263 NA NA NA NA 187 187 187 187 NA NA NA 

Z 6 0 0 6 6 0 0 6 0 0 0 0 0 0 0 0 7 0 0 

AA 21 21 21 21 28 28 28 28 89 89 89 89 302 302 302 302 0 0 0 

BB 1 0 1 1 1 0 1 1 0 0 0 0 0 0 0 0 0 0 0 

CC 3 3 3 3 3 3 3 3 0 0 0 0 0 0 0 0 0 1 1 

EE 7 0 0 7 7 0 0 7 0 0 0 0 0 0 0 0 0 0 0 

GG 6 6 6 6 6 6 6 6 0 0 0 0 0 0 0 0 0 0 0 

TT 0 0 173 173 0 0 173 173 0 0 0 0 0 0 0 0 0 0 0 

a See Appendix B for detailed summary for each subpart. 

NA = Data not available on basis. 
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118 

Table C-7 (cont.) Notes Explaining the Potential CEMS Count Distribution for Each Subpart 

Subpart NOTES – Potential CEMS counts

C Boiler and CISWI databases reviewed to get count of units with CEMS (1,151). None of the relevant regulations require CO2 or flow monitors, b

CEMS systems for other pollutants. Assumed that all 1,151 Tier 4 units would be in scenario 2 and units with known CO2 CEMS would be in scen

E Current CEMS installation unknown; assumed all facilities/units in scenario 1.

F Current CEMS installation unknown; assumed all facilities/units in scenario 1.

G Current CEMS installation unknown; assumed all facilities/units in scenario 1.

H Assumed units with current CEMS installations would be in scenario 3.

K Current CEMS installation unknown; assumed all facilities/units in scenario 1.

L CO2, N2O, and CH4 not required to be reported for this subpart, thus no associated costs or unit counts.

N Scenario 3 costs applied to facilities with CO2 CEMS, others assumed to be in scenario 1. Assumption made that the facilities with CO2 CEMS ha

O CO2, N2O, nor CH4 required to be reported for this subpart, thus no associated costs or unit counts.

P Scenario 3 costs applied to facilities with CO2 CEMS, others assumed to be in scenario 1. Assumption made that the facilities with CO2 CEMS ha

Q Scenario 3 costs applied to facilities with CO2 CEMS, others assumed to be in scenario 1. Assumption made that the facilities with CO2 CEMS ha

R Current CEMS installation unknown; assumed all facilities/units in scenario 1.

S

The RIA for part 98 identified all facilities being applicable to Tier 4 requirements and would thus install a CO2 CEMS. Note, however, that this c

exclusive to subpart S emissions sources and, for example, some of the identified units may fall under subpart C. For the potential count, it was 

would be in scenario 2, per the RIA.

U Current CEMS installation unknown; assumed all facilities/units in scenario 1.

V Scenario 3 costs applied to facilities with CEMS, others assumed to be in scenario 1.

X Scenario 3 costs applied to facilities with CO2 CEMS, others assumed to be in scenario 1. Assumption made that the facilities with CO2 CEMS ha

Y Scenario 3 costs applied to facilities with CO2 CEMS, others assumed to be in scenario 1. For potential CEMS count, distributed non‐GHG CEMS 

based on engineering judgment.

Z Scenario 3 costs applied to facilities with CEMS, others assumed to be in scenario 1.

AA Scenario 2 costs applied for facilities with CEMS; based off GHG RIA estimate that most facilities would meet this for Tier IV requirements.

BB Current CEMS installation unknown; assumed all facilities/units in scenario 1.

CC Current CEMS installation unknown; assumed all facilities/units in scenario 1.

EE Current CEMS installation unknown; assumed all facilities/units in scenario 1.

GG Current CEMS installation unknown; assumed all facilities/units in scenario 1.

TT Current CEMS installation unknown; assumed all facilities/units in scenario 1.
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119 

Table C-8. Capital Costs (million dollars) for Each Scenario, Based on Actual CEMS Countsa

Subpart

Capital Costs (Million Dollars)

Scenario 1 Scenario 2 Scenario 3 Total ‐ All

CO2 N2O CH4 Total CO2 N2O CH4 Total CO2 N2O CH4 Total Scenarios

C $ 1,578 $ 1,603 $ 1,640 $ 1,960 $ 102 $ 104 $ 107 $ 134 $       ‐    $ 6.8 $ 7.7 $ 11.9 $ 2,106

E $          ‐    $ 0.37 $          ‐    $ 0.37 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $          ‐   $          ‐    $          ‐   $ 0.4

F $ 1.2 $          ‐    $          ‐    $ 1.2 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $          ‐   $          ‐    $          ‐   $ 1.2

G $ 2.7 $          ‐    $          ‐    $ 2.7 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $          ‐   $          ‐    $          ‐   $ 2.7H $ 3.4 $ 3.5 $ 3.6 $ 4.3 $          ‐   $          ‐   $          ‐   $          ‐   $ 0.56 $ 2.5 $ 2.8 $ 5.6 $ 9.9

K $ 1.2 $          ‐    $ 1.3 $ 1.4 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $          ‐   $          ‐    $          ‐   $ 1.4

L $          ‐    $          ‐    $          ‐    $          ‐    $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $          ‐   $          ‐    $          ‐   $            ‐  

N $ 13.2 $ 13.4 $ 13.7 $ 16.3 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $ 0.066 $ 0.074 $ 0.11 $ 16.5

O $          ‐    $          ‐    $          ‐    $          ‐    $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $          ‐   $          ‐    $          ‐   $            ‐  

P $ 12.3 $ 12.5 $ 12.8 $ 15.3 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $ 0.066 $ 0.074 $ 0.11 $ 15.4

Q $ 18.6 $ 18.9 $ 19.3 $ 23.1 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $ 0.31 $ 0.35 $ 0.54 $ 23.6

R $ 1.6 $ 1.6 $ 1.7 $ 2.0 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $          ‐   $          ‐    $          ‐   $ 2.0

S $ 8.9 $ 9.0 $ 9.2 $ 11.0 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $ 0.022 $ 0.025 $ 0.038 $ 11.0

U $ 2.2 $          ‐    $          ‐    $ 2.2 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $          ‐   $          ‐    $          ‐   $ 2.2

V $          ‐    $ 3.6 $          ‐    $ 3.6 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $ 0.79 $          ‐    $ 0.79 $ 4.4

X $ 7.6 $ 7.7 $ 7.9 $ 9.5 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $ 0.044 $ 0.050 $ 0.077 $ 9.6

Y $ 191 $ 194 $ 199 $ 237 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $ 0.57 $ 0.65 $ 1.00 $ 238.5

Z $ 0.74 $          ‐    $          ‐    $ 0.74 $          ‐   $          ‐   $          ‐   $          ‐   $ 0.14 $          ‐   $          ‐    $ 0.14 $ 0.88

AA $ 7.9 $ 8.0 $ 8.2 $ 9.8 $ 25.7 $ 26.2 $ 27.0 $ 33.7 $       ‐    $          ‐   $          ‐    $          ‐   $ 43.4

BB $ 0.12 $          ‐    $ 0.13 $ 0.14 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $          ‐   $          ‐    $          ‐   $ 0.14

CC $ 0.37 $ 0.37 $ 0.38 $ 0.46 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $ 0.022 $ 0.025 $ 0.038 $ 0.50

EE $ 0.86 $          ‐    $          ‐    $ 0.86 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $          ‐   $          ‐    $          ‐   $ 0.86

GG $ 0.74 $ 0.75 $ 0.77 $ 0.92 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $          ‐   $          ‐    $          ‐   $ 0.92

TT $          ‐    $          ‐    $ 22.1 $ 22.1 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $          ‐   $          ‐    $          ‐   $ 22.1

TOTAL $ 1,853 $ 1,877 $ 1,940 $ 2,325 $ 127.7 $ 130.2 $ 134 $ 167.7 $ 0.70 $ 11.2 $ 11.7 $ 20.3 $ 2,513

a See Appendix B for detailed summary for each subpart. 
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120 

Table C-9. Annual Costs (million dollars) for Each Scenario, Based on Actual CEMS Countsa

Subpart

Annual Costs (Million Dollars)

Scenario 1 Scenario 2 Scenario 3 Total ‐ All

CO2 N2O CH4 Total CO2 N2O CH4 Total CO2 N2O CH4 Total Scenarios

C $ 901 $ 911 $ 915 $ 950 $ 59.2 $ 61.4 $ 61.7 $ 64.6 $       ‐    $ 6.6 $ 6.7 $ 7.1 $ 1,022

E $          ‐    $ 0.21 $          ‐    $ 0.21 $       ‐   $       ‐   $       ‐   $       ‐   $       ‐    $          ‐    $          ‐    $          ‐   $ 0.21

F $ 0.70 $          ‐    $          ‐    $ 0.70 $       ‐   $       ‐   $       ‐   $       ‐   $       ‐    $          ‐    $          ‐    $          ‐   $ 0.70

G $ 1.5 $          ‐    $          ‐    $ 1.5 $       ‐   $       ‐   $       ‐   $       ‐   $       ‐    $          ‐    $          ‐    $          ‐   $ 1.5

H $ 2.0 $ 2.0 $ 2.0 $ 2.1 $       ‐   $       ‐   $       ‐   $       ‐   $ 0.6 $ 2.4 $ 2.4 $ 2.7 $ 4.8

K $ 0.70 $          ‐    $ 0.71 $ 0.73 $       ‐   $       ‐   $       ‐   $       ‐   $       ‐    $          ‐    $          ‐    $          ‐   $ 0.73

L $          ‐    $          ‐    $          ‐    $          ‐    $       ‐   $       ‐   $       ‐   $       ‐   $       ‐    $          ‐    $          ‐    $          ‐   $            ‐  

N $ 7.5 $ 7.6 $ 7.6 $ 7.9 $       ‐   $       ‐   $       ‐   $       ‐   $       ‐    $ 0.06 $ 0.06 $ 0.07 $ 8.0

O $          ‐    $          ‐    $          ‐    $          ‐    $       ‐   $       ‐   $       ‐   $       ‐   $       ‐    $          ‐    $          ‐    $          ‐   $            ‐  

P $ 7.0 $ 7.1 $ 7.1 $ 7.4 $       ‐   $       ‐   $       ‐   $       ‐   $       ‐    $ 0.06 $ 0.06 $ 0.07 $ 7.5

Q $ 10.6 $ 10.7 $ 10.8 $ 11.2 $       ‐   $       ‐   $       ‐   $       ‐   $       ‐    $ 0.30 $ 0.30 $ 0.32 $ 11.5

R $ 0.91 $ 0.92 $ 0.93 $ 0.96 $       ‐   $       ‐   $       ‐   $       ‐   $       ‐    $          ‐    $          ‐    $          ‐   $ 0.96

S $ 5.1 $ 5.1 $ 5.1 $ 5.3 $       ‐   $       ‐   $       ‐   $       ‐   $       ‐    $ 0.021 $ 0.021 $ 0.023 $ 5.4

U $ 1.3 $          ‐    $          ‐    $ 1.3 $       ‐   $       ‐   $       ‐   $       ‐   $       ‐    $          ‐    $          ‐    $          ‐   $ 1.3

V $          ‐    $ 2.1 $          ‐    $ 2.1 $       ‐   $       ‐   $       ‐   $       ‐   $       ‐    $ 0.76 $          ‐    $ 0.76 $ 2.8

X $ 4.4 $ 4.4 $ 4.4 $ 4.6 $       ‐   $       ‐   $       ‐   $       ‐   $       ‐    $ 0.042 $ 0.043 $ 0.046 $ 4.6

Y $ 109 $ 110 $ 111 $ 115 $       ‐   $       ‐   $       ‐   $       ‐   $       ‐    $ 0.55 $ 0.56 $ 0.60 $ 115.6

Z $ 0.42 $          ‐    $          ‐    $ 0.42 $       ‐   $       ‐   $       ‐   $       ‐   $ 0.14 $          ‐    $          ‐    $ 0.14 $ 0.57

AA $ 4.5 $ 4.5 $ 4.6 $ 4.7 $ 14.9 $ 15.5 $ 15.5 $ 16.3 $       ‐    $          ‐    $          ‐    $          ‐   $ 21.0

BB $ 0.07 $          ‐    $ 0.07 $ 0.07 $       ‐   $       ‐   $       ‐   $       ‐   $       ‐    $          ‐    $          ‐    $          ‐   $ 0.07

CC $ 0.21 $ 0.21 $ 0.21 $ 0.22 $       ‐   $       ‐   $       ‐   $       ‐   $       ‐    $ 0.021 $ 0.021 $ 0.023 $ 0.25

EE $ 0.49 $          ‐    $          ‐    $ 0.49 $       ‐   $       ‐   $       ‐   $       ‐   $       ‐    $          ‐    $          ‐    $          ‐   $ 0.49

GG $ 0.42 $ 0.43 $ 0.43 $ 0.44 $       ‐   $       ‐   $       ‐   $       ‐   $       ‐    $          ‐    $          ‐    $          ‐   $ 0.44

TT $          ‐    $          ‐    $ 12.3 $ 12.3 $       ‐   $       ‐   $       ‐   $       ‐   $       ‐    $          ‐    $          ‐    $          ‐   $ 12.3

TOTAL $ 1,058 $ 1,066 $ 1,082 $ 1,129 $ 74.1 $ 76.8 $ 77.3 $ 80.9 $ 0.74 $ 10.8 $ 10.2 $ 11.9 $ 1,223

a See Appendix B for detailed summary for each subpart. 
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121 

Table C-10. Capital Costs (million dollars) for Each Scenario, Based on Potential CEMS Countsa

Subpart

Capital Costs (Million Dollars)

Scenario 1 Scenario 2 Scenario 3 Total ‐ All

CO2 N2O CH4 Total CO2 N2O CH4 Total CO2 N2O CH4 Total Scenarios

C $ 1,578 $ 1,603 $ 1,640 $ 1,960 $ 111 $ 114 $ 117 $ 146 $       ‐    $ 6.8 $ 7.7 $ 11.9 $ 2,118

E $          ‐    $ 0.37 $          ‐    $ 0.37 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $          ‐   $          ‐   $          ‐   $ 0.4

F $ 1.2 $          ‐    $          ‐    $ 1.2 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $          ‐   $          ‐   $          ‐   $ 1.2

G $ 2.7 $          ‐    $          ‐    $ 2.7 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $          ‐   $          ‐   $          ‐   $ 2.7

H $          ‐    $          ‐    $          ‐    $          ‐    $          ‐   $          ‐   $          ‐   $          ‐   $ 0.56 $ 3.1 $ 3.5 $ 7.0 $ 7.0

K $ 1.2 $          ‐    $ 1.3 $ 1.4 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $          ‐   $          ‐   $          ‐   $ 1.4

L $          ‐    $          ‐    $          ‐    $          ‐    $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $          ‐   $          ‐   $          ‐   $               ‐  

N $ 13.2 $ 13.4 $ 13.7 $ 16.3 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $ 0.066 $ 0.074 $ 0.11 $ 16.5

O $          ‐    $          ‐    $          ‐    $          ‐    $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $          ‐   $          ‐   $          ‐   $               ‐  

P $ 12.3 $ 12.5 $ 12.8 $ 15.3 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $ 0.066 $ 0.074 $ 0.11 $ 15.4

Q $ 18.6 $ 18.9 $ 19.3 $ 23.1 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $ 0.31 $ 0.35 $ 0.54 $ 23.6

R $ 1.6 $ 1.6 $ 1.7 $ 2.0 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $          ‐   $          ‐   $          ‐   $ 2.0

S $          ‐    $          ‐    $          ‐    $          ‐    $          ‐   $ 7.2 $ 7.4 $ 8.4 $       ‐    $          ‐   $          ‐   $          ‐   $ 8.4

U $ 2.2 $          ‐    $          ‐    $ 2.2 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $          ‐   $          ‐   $          ‐   $ 2.2

V $          ‐    $ 3.6 $          ‐    $ 3.6 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $ 0.79 $          ‐   $ 0.79 $ 4.4

X $ 7.9 $ 8.0 $ 8.2 $ 9.8 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $ 0.044 $ 0.050 $ 0.077 $ 9.9

Y $ 155 $ 158 $ 161 $ 193 $ 18.1 $ 18.5 $ 19.0 $ 23.7 $ 2.08 $ 2.85 $ 3.23 $ 6.48 $ 223.1

Z $ 0.74 $          ‐    $          ‐    $ 0.74 $          ‐   $          ‐   $          ‐   $          ‐   $ 0.14 $          ‐   $          ‐   $ 0.14 $ 0.88

AA $ 3.5 $ 3.5 $ 3.6 $ 4.3 $ 29.2 $ 29.8 $ 30.7 $ 38.2 $       ‐    $          ‐   $          ‐   $          ‐   $ 42.5

BB $ 0.12 $          ‐    $ 0.13 $ 0.14 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $          ‐   $          ‐   $          ‐   $ 0.14

CC $ 0.37 $ 0.37 $ 0.38 $ 0.46 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $ 0.022 $ 0.025 $ 0.038 $ 0.50

EE $ 0.86 $          ‐    $          ‐    $ 0.86 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $          ‐   $          ‐   $          ‐   $ 0.86

GG $ 0.74 $ 0.75 $ 0.77 $ 0.92 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $          ‐   $          ‐   $          ‐   $ 0.92

TT $          ‐    $          ‐    $ 22.1 $ 22.1 $          ‐   $          ‐   $          ‐   $          ‐   $       ‐    $          ‐   $          ‐   $          ‐   $ 22.1

TOTAL $ 1,801 $ 1,823 $ 1,885 $ 2,260 $ 158.7 $ 169.0 $ 174.4 $ 216.4 $ 2.8 $ 14.0 $ 15.0 $ 27.2 $ 2,504

a See Appendix B for detailed summary for each subpart. 
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122 

Table C-11. Annual Costs (million dollars) for Each Scenario, Based on Potential CEMS Countsa

Subpart

Annual Costs (Million Dollars)

Scenario 1 Scenario 2 Scenario 3 Total ‐ All

CO2 N2O CH4 Total CO2 N2O CH4 Total CO2 N2O CH4 Total Scenarios

C $ 901 $ 911 $ 915 $ 950 $ 64.5 $ 66.9 $ 67.3 $ 70.4 $       ‐    $ 6.6 $ 6.7 $ 7.1 $ 1,027

E $          ‐    $ 0.21 $          ‐    $ 0.21 $       ‐    $       ‐    $          ‐   $          ‐   $       ‐    $          ‐    $          ‐   $          ‐    $ 0.21

F $ 0.70 $          ‐    $          ‐    $ 0.70 $       ‐    $       ‐    $          ‐   $          ‐   $       ‐    $          ‐    $          ‐   $          ‐    $ 0.70

G $ 1.5 $          ‐    $          ‐    $ 1.5 $       ‐    $       ‐    $          ‐   $          ‐   $       ‐    $          ‐    $          ‐   $          ‐    $ 1.5

H $          ‐    $          ‐    $          ‐    $          ‐    $       ‐    $       ‐    $          ‐   $          ‐   $ 0.6 $ 3.0 $ 3.0 $ 3.4 $ 3.4

K $ 0.70 $          ‐    $ 0.71 $ 0.73 $       ‐    $       ‐    $          ‐   $          ‐   $       ‐    $          ‐    $          ‐   $          ‐    $ 0.73

L $          ‐    $          ‐    $          ‐    $          ‐    $       ‐    $       ‐    $          ‐   $          ‐   $       ‐    $          ‐    $          ‐   $          ‐    $             ‐  

N $ 7.5 $ 7.6 $ 7.6 $ 7.9 $       ‐    $       ‐    $          ‐   $          ‐   $       ‐    $ 0.06 $ 0.06 $ 0.07 $ 8.0

O $          ‐    $          ‐    $          ‐    $          ‐    $       ‐    $       ‐    $          ‐   $          ‐   $       ‐    $          ‐    $          ‐   $          ‐    $             ‐  

P $ 7.0 $ 7.1 $ 7.1 $ 7.4 $       ‐    $       ‐    $          ‐   $          ‐   $       ‐    $ 0.06 $ 0.06 $ 0.07 $ 7.5

Q $ 10.6 $ 10.7 $ 10.8 $ 11.2 $       ‐    $       ‐    $          ‐   $          ‐   $       ‐    $ 0.30 $ 0.30 $ 0.32 $ 11.5

R $ 0.91 $ 0.92 $ 0.93 $ 0.96 $       ‐    $       ‐    $          ‐   $          ‐   $       ‐    $          ‐    $          ‐   $          ‐    $ 0.96

S $          ‐    $          ‐    $          ‐    $          ‐    $       ‐    $ 4.2 $ 4.3 $ 4.4 $       ‐    $          ‐    $          ‐   $          ‐    $ 4.4

U $ 1.3 $          ‐    $          ‐    $ 1.3 $       ‐    $       ‐    $          ‐   $          ‐   $       ‐    $          ‐    $          ‐   $          ‐    $ 1.3

V $          ‐    $ 2.1 $          ‐    $ 2.1 $       ‐    $       ‐    $          ‐   $          ‐   $       ‐    $ 0.76 $          ‐   $ 0.76 $ 2.8

X $ 4.5 $ 4.5 $ 4.6 $ 4.7 $       ‐    $       ‐    $          ‐   $          ‐   $       ‐    $ 0.042 $0.043 $ 0.046 $ 4.8

Y $ 89 $ 90 $ 90 $ 94 $ 10.5 $ 10.9 $ 10.9 $ 11.4 $ 2.14 $ 2.75 $ 2.79 $ 3.15 $ 108.1

Z $ 0.42 $          ‐    $          ‐    $ 0.42 $       ‐    $       ‐    $          ‐   $          ‐   $ 0.14 $          ‐    $          ‐   $ 0.14 $ 0.57

AA $ 2.0 $ 2.0 $ 2.0 $ 2.1 $ 16.9 $ 17.6 $ 17.6 $ 18.5 $       ‐    $          ‐    $          ‐   $          ‐    $ 20.6

BB $ 0.07 $          ‐    $ 0.07 $ 0.07 $       ‐    $       ‐    $          ‐   $          ‐   $       ‐    $          ‐    $          ‐   $          ‐    $ 0.07

CC $ 0.21 $ 0.21 $ 0.21 $ 0.22 $       ‐    $       ‐    $          ‐   $          ‐   $       ‐    $ 0.021 $0.021 $ 0.023 $ 0.25

EE $ 0.49 $          ‐    $          ‐    $ 0.49 $       ‐    $       ‐    $          ‐   $          ‐   $       ‐    $          ‐    $          ‐   $          ‐    $ 0.49

GG $ 0.42 $ 0.43 $ 0.43 $ 0.44 $       ‐    $       ‐    $          ‐   $          ‐   $       ‐    $          ‐    $          ‐   $          ‐    $ 0.44

TT $          ‐    $          ‐    $ 12.3 $ 12.3 $       ‐    $       ‐    $          ‐   $          ‐   $       ‐    $          ‐    $          ‐   $          ‐    $ 12.3

TOTAL $ 1,029 $ 1,036 $ 1,052 $ 1,099 $ 91.9 $ 99.6 $ 100.1 $ 104.7 $ 2.9 $ 13.5 $ 13.0 $ 15.1 $ 1,217

a See Appendix B for detailed summary for each subpart. 
Attachment R 
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TECHNICAL MEMORANDUM 

DATE: April 2013 

TO: Docket EPA-HQ-OAR-2010-0929 

FROM: Lisa Grogan-McCulloch

SUBJECT: Analysis of Alternative Verification Approaches For Greenhouse Gas 

Reporting Rule Subparts for which Reporting of Inputs to Emission 

Equations was Deferred to March 31, 2015 

1.0 Introduction and Purpose of Analysis 

In the August 25, 2011 final rule deferring reporting to March 31, 2015 of certain inputs to 

emission equations under 40 CFR part 98 (76 FR 53057), EPA expressed its intent to further 

evaluate these inputs to emission equations (hereafter referred to as “’inputs to equations’ data 

elements”). EPA outlined a four-step process for this evaluation in the August 25, 2011 final rule 

and in a supporting memorandum entitled “Process for Evaluating and Potentially Amending 

Part 98 Inputs to Emission Equations” (docket EPA-HQ-OAR-2010-0929). The purpose of this 

memorandum is to describe the review undertaken for the fourth step of the evaluation process: 

EPA’s analysis of alternative verification methods that would not require reporting of the “inputs 

to equations” data elements. This review evaluates alternative verification methods for 25 

subparts, based on the results of steps one through three of the four-step process. The review was 

not undertaken for subparts W and II because the EPA’s evaluation of these inputs under Step 2 

did not identify the need to proceed to the next steps.1

Section 2.0 of this memorandum summarizes EPA’s current verification process. Section 3.0 of 

this memorandum summarizes the review of alternative verification approaches suggested in 

comments to the Call for Information, which was issued on December 27, 2013 (75 FR 81366) to 

request additional information to conduct its evaluation of “inputs to equations” data elements. 

Section 4.0 discusses an alternative verification method that consists of an electronic verification 

tool developed by EPA, enhanced recordkeeping requirements, and additional reporting 

requirements. Section 5.0 provides a summary of the analysis. 

 

1

 The review was not conducted for “inputs to equations” in subpart I because reporting of the “inputs to equations” 

data elements for that subpart was addressed in a separate proposed action [see 77 FR 63538]. Additionally, the 

evaluation of the subpart C “inputs to equations” in this memorandum encompasses the one subpart A “input to 

equation” data element. As a result, the one subpart A “input to equation” data element is not listed explicitly in this 

memorandum. 
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2 

2.0 EPA’s Current Verification Process 

During the first 3 years of the Greenhouse Gas Reporting Program (GHGRP), EPA has had 

success developing and using an electronic reporting and verification system for all subparts 

reporting under the program. The current verification approach for the GHGRP consists of 

requiring facility self-certification of the annual reports along with EPA conducting electronic 

verification checks of the data entered into e-GGRT, followed by direct follow-up with facilities 

if necessary. For subparts where the reporting of inputs to emission equations was deferred until 

2015, these checks have been conducted using reported data other than inputs to emission 

equations (the reporting of which was deferred). For “supplier” subparts2 (and starting in 

reporting year 2012 for subparts with inputs to emission equations that were deferred until 2013), 

these checks have been conducted using reported data that include the data needed to calculate 

outputs of the equations. Reporters under these subparts have been entering into e-GGRT the 

data needed to calculate the annual GHG quantities. 

During reporting year 2010, EPA developed approximately 1,400 electronic verification checks 

to verify reported data. Based on these verification checks, EPA followed up with facilities 

regarding potential data quality errors for approximately 2,360 of the approximately 6,700 

facilities that reported in reporting year 2010. In reporting year 2011, EPA programmed an 

additional 1,000 checks into e-GGRT for the subparts that were reporting for the second year, 

expanding the number of checks to 2,400. EPA also programmed into e-GGRT, for 2011, 

approximately 1,300 checks for the newly-reporting subparts. During reporting year 2011, EPA 

followed up with approximately 3,440 of the approximately 8,000 facilities that reported. 

3.0 Evaluation of Alternative Verification Methods Suggested by Commenters 

The Call for Information notice specifically requested commenter input on alternative 

verification approaches that would not require reporting to EPA those data elements for which 

reporting may cause competitive harm. In response, EPA received input from 16 commenters 

suggesting alternative verification methods. The comments expressed support for the following 

verification methods: (1) self-certification, (2) EPA compliance inspection/audits only, (3) 

implementation of third party auditing or third party verification, and (4) a verification approach 

similar to EPA’s Toxic Release Inventory (TRI). These verification approaches are discussed in 

sections 3.1 through 3.4. 

3.1 Self-certification 

Given the complexity of the GHG monitoring and reporting requirements, the large number of 

reporters (over 8,000), and the need for high quality data, self-certification alone is not sufficient 

 

2

 Supplier subparts (subparts LL through PP of Part 98) apply to fossil fuel suppliers and industrial gas suppliers. The eGGRT system currently calculates equation outputs for suppliers using reported equations inputs. Subpart MM 

reporters began using e-GGRT for reporting in Reporting Year 2012. 
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3 

to ensure that GHG emissions are being reporting accurately. EPA’s experience with reviewing 

the 2010 and 2011 reporting year annual reports showed that there have been errors made in 

GHG emissions reporting. Self-certification alone would not address these errors. As mentioned 

in section 2.0 of this memorandum, EPA’s verification process for the 2010 and 2011 reporting 

years resulted in EPA identifying thousands of potential reporting errors and reporters 

resubmitting numerous corrected reports. Based on this experience, EPA maintains its original 

conclusion (refer to the October 30, 2009 final rule that initiated the GHGRP, 74 FR 56260) that 

self-certification is not sufficient to effectively verify emissions and ensure compliance with the 

GHGRP. 

3.2 EPA Compliance Inspections/Audits 

Given that more than 8,000 facilities and suppliers in more than 40 source categories submit 

annual reports, it would be possible for EPA to visit only a very small fraction of the reporting 

facilities in any given year (e.g., even if EPA visited 100 facilities, that would be only 1.25 

percent of reporters). Therefore, relying solely on on-site compliance inspections as the primary 

method of verifying reported GHG data is impractical and would not be cost effective. Even if 

on-site audits were to identify, and result in correction of, monitoring and reporting problems at 

some of the visited facilities, there would be numerous other facilities that would not have been 

visited and that potentially would have made significant errors that would not have been 

identified and corrected. In order to ensure compliance, EPA’s verification approach needs to 

collect enough information about all facilities to allow sufficient assessment of the data quality 

prior to performing on-site audits. For example, EPA’s current verification approach allows EPA 

to identify many reporting errors and allow for their resolution without the time and expense of 

on-site visits. Using the information obtained through this process, compliance inspections are 

better targeted toward facilities or sectors most likely to have significant, unresolved verification 

issues. 

3.3 Third Party Verification 

Commenters on the Call for Information suggested third party verification as an alternative 

verification method. EPA had previously considered third party verification, but decided against 

its implementation. Refer to EPA’s full rationale for not selecting third party verification in the 

October 30, 2009 final rule (74 FR 56260). The following is a summary of this rationale, as well 

as an explanation of why EPA has determined that these reasons still apply: 

 The costs to the reporters of hiring third party verifiers would be substantial, given the 

more than 8,000 reporters under the GHGRP. If EPA were to adopt third party 

verification at this juncture, the cost to the reporters would be the same as originally 

estimated, which was thousands of dollars per reporting facility. While EPA received 

some comments on the Call for Information supporting third party verification, the vast 

majority of reporters did not submit comments supporting this approach. 
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4 

 A centralized emissions verification system, as opposed to third party verification (which 

is de-centralized), provides a greater ability for EPA to identify trends and outliers in data 

and thereby assist with targeted follow-up review. The data collected through the 

GHGRP, beyond collected inputs to emission equations, are used for verification 

purposes as well as to inform future GHG policy development. EPA has utilized the 

national data set to verify the reported emissions as well as to gain a fuller picture of the 

emissions profile of the different sectors, and will continue to do so in the future. 

 Developing the third party verification approach would require EPA to establish and 

develop emissions verification protocols and a system to qualify and accredit third party 

verifiers, as well as to develop and administer a process to ensure that verifiers hired by 

reporting facilities do not have conflicts of interest. Such a program would require EPA 

to review numerous individual conflict of interest screening determinations made each 

time a reporter hires a third party verifier, which would be time-consuming. Even if EPA 

were to partner with an existing program or organization to accredit verifiers, EPA would 

still need to develop the criteria and systems described above to implement the GHGRP 

and ensure high quality emissions verification given the unique reporting requirements of 

the GHGRP. If EPA were to adopt third party verification at this juncture, EPA would 

still have to develop the infrastructure described above to support it. Not only would this 

take several years to put into place, this approach would not build upon the success of the 

thousands of verification checks that EPA has developed over the first few years of the 

program. 

 Third party verification would potentially result in delays in the publication of the annual 

data and could result in facilities responding to inquiries from both EPA and third party 

verifiers. Under a third party verification system, a facility would contract with a third 

party verifier and provide the verifier detailed data (by March 31) so that the third party 

could perform the verification. The third party verifiers would perform on-site visits to 

many of the facilities as part of the verification process. After conducting the verification 

according to required protocols, the third party verifier would submit their findings to the 

facility with errors identified, which the facility could then correct. For existing third 

party GHG verification programs, this verification process generally takes three to six 

months. Given the large number of facilities (over 8,000) that would need to have third 

party verifications conducted, sufficient time would need to be allowed for this step. 

After receiving the data that has undergone third party verification, EPA would review 

the data prior to release. EPA would then perform additional electronic checks on the full 

set of reported data because using such checks and statistical analyses on the entire data 

set would likely reveal inconsistencies and errors in addition to those identified by the 

third party verifier. If EPA identified additional potential reporting errors, EPA would 

then contact the facility to resolve the issue. It would be inefficient for EPA to perform 

verification of the data reported by facilities at the same time as the third party 

verification is ongoing, because EPA and the third party verifier would likely be 

communicating duplicative, or possibly conflicting, requests to the same facility 

regarding potential errors. As a result, this verification would likely be conducted after 

third party verification is complete. If EPA allows the same 4-month period it has in 
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5 

previous years for these EPA verification activities prior to publication/release of data, 

then data would be released eight to ten months after the March 31 reporting date. This 

approach would not only potentially lengthen the time it would take to publish data, but 

would also potentially require facilities to respond to both third party verifiers as well as 

EPA. 

3.4 Verification in EPA’s Toxic Release Inventory (TRI) Program 

The TRI program requires annual facility level reporting of the amount of toxic chemicals 

released to the environment or otherwise managed as wastes. Some aspects of the TRI program 

are similar to the GHGRP. The TRI reports contain a signed self-certification that the 

information reported is accurate. Each facility must also keep records of how emissions were 

calculated, including supporting materials, documents, calculations, worksheets, and other 

information used. This approach is similar to the self-certification approached described in 

section 3.2, and has the same disadvantages if not used in combination with other verification 

methods. In addition, to improve the quality of the TRI data, EPA provides extensive training 

and assistance to reporters, free electronic software to facilitate electronic submission of data, 

conducts electronic data checks, and contact facilities to resolve reporting errors. However, the 

TRI is a different type of program than the GHGRP in that it does not require specific 

monitoring and calculation approaches, but rather requires that estimates be based on the best 

available information. TRI estimates can be based on monitoring, emission factors, mass 

balance, and/or other methods for over 600 chemicals and chemical categories. In contrast, the 

GHGRP prescribes a set of specific calculation methods, or equations, for individual source 

categories, processes, and emission units, so that data collected from multiple facilities are 

consistent and comparable. The data entered into these equations, which are “inputs to 

equations” data elements, often include process or production data specific to each facility’s 

operations. These “inputs to equations” data elements play an important role in EPA’s ability to 

verify GHGRP emissions and ensure compliance with the program. Therefore, given the 

additional specification provided by the GHGRP, it is necessary that EPA assess whether 

calculations were conducted correctly and according to the appropriate equation specified in Part 

98, as well as conduct additional verification checks (e.g., assessing whether appropriate 

monitoring methods were used). In conclusion, EPA determined that, while there is some 

similarity in the verification approaches of the two programs, direct application of the approach 

used for verification of the TRI program is not appropriate for the GHGRP. 

4.0 Summary and Evaluation of an Alternative Verification Method Using an Inputs 

Verification Tool, Enhanced Recordkeeping, and Additional Reporting 

During EPA’s consideration of alternative verification methods, EPA evaluated an approach 

involving the use of an electronic inputs verification tool, enhanced recordkeeping requirements, 

and additional reporting requirements. Section 4.1 describes the inputs verification tool, section 

4.2 describes the enhanced verification requirements, section 4.3 describes the additional 
E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review 

6 

reporting requirements, and section 4.4 reviews the effectiveness of this verification approach at 

verifying emissions and ensuring compliance with the GHGRP. 

4.1 Description of Inputs Verification Tool 

EPA evaluated the option of using a verification approach similar to the verification approach 

currently used for the supplier subparts, where data needed to calculate the outputs of the 

equations are entered into e-GGRT and used to calculate the annual GHG emission values, 

followed by EPA verification of these emission values. EPA considered using a similar approach 

whereby “inputs to equations” data elements would be entered into a new inputs verification tool 

within e-GGRT in such a way that the “inputs to equations” data elements could be used for data 

verification, but not be reported to EPA. 

Such an inputs verification tool could be deployed within e-GGRT and integrated without 

interrupting the current electronic reporting process. To access this inputs verification tool, 

reporters would log into e-GGRT. They would enter data elements required for the annual report 

as well as specified “inputs to equations” data elements. The tool would operate securely within 

e-GGRT, as a transient process, which means that data entered into the tool would be 

temporarily saved in the tool while the reporter is actively using the tool, but would not be 

persisted (i.e., saved) within the e-GGRT database. Data entered into the tool would be discarded 

when the user’s session with e-GGRT ends. 

If the reporter were to exit the inputs verification tool prior to completing data entry or 

submitting their annual report, the tool would generate a file of entered “inputs to equations” data 

elements, and allow the reporter to download the file. The reporter would have the option to 

upload this file into the tool when they next use the tool. This option would avoid facilities from 

needing to re-enter “inputs to equations” data elements that were entered in previous e-GGRT 

sessions. 

After the reporter enters specified “inputs to equations” data elements into the inputs verification 

tool, the tool would calculate the annual GHG emissions values. The tool would use the 

following information in calculating these values: (1) “inputs to equations” data elements, (2) 

information entered into e-GGRT identifying which Part 98 calculation method was selected (if 

applicable), and (3) the selected Part 98 calculation method. Once the annual GHG emissions 

values are calculated, the values would be pre-filled into the appropriate reporting fields within 

e-GGRT. Reporters would then have the opportunity to override the annual GHG emissions 

values calculated by the tool with their own calculated value. 

Prior to annual report submittal, the inputs verification tool would conduct a series of verification 

checks, including the following: 
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 Verification checks on the annual GHG emission values calculated by the inputs 

verification tool. Reporters would have the opportunity to override and revise the values 

calculated by the tool; however should this occur, the tool would note this decision, as 

well as any discrepancy, which would prompt EPA for further review after the reporter 

submits the annual report. 

 Verification checks on entered “inputs to equations” data elements. For example, the tool 

would check: (1) whether all required data were entered; (2) whether entered “inputs to 

equations” data element values are within the expected ranges for the data elements; and 

(3) whether expected relationships exist between certain “inputs to equations” data 

elements and certain other reported data elements (e.g., process raw material or 

throughput data that are not “inputs to equations” data elements). 

Some of these checks would be conducted as the reporter enters “inputs to equations” data 

elements (i.e., using “real-time” checking), and other checks would be conducted after the 

reporter has entered all specified “inputs to equations” data elements, because some algorithms 

may compare certain “inputs to equations” data elements (e.g., production quantity) to GHG 

emission values at the subpart or facility level. Also, prior to submittal of the annual report, the 

inputs verification tool would generate a verification summary containing the results of the 

verification checks. The verification summary would specify whether any potential errors, as 

described above, were identified, without specifying any information about the “inputs to 

equations” data elements. The reporter would have an opportunity to review the verification 

summary and make necessary revisions to the entered “inputs to equations” data elements and 

the reported data elements. Additionally, the tool would generate a file listing all entered “inputs 

to equations” data elements to be kept by the reporter as a record of these data (refer to section 

4.2 for further discussion of this recordkeeping requirement). 

4.2 Description of Enhanced Recordkeeping Requirements 

Because there may be more direct follow-up verification activities with the use of the inputs 

verification tool, EPA considered two enhancements to recordkeeping requirements. First, EPA 

considered extending the record retention period from 3 to 5 years. It would be important that 

relevant records are available to EPA for follow-up activities with facilities, including on-site 

audits if necessary, regarding potential errors, discrepancies, or questions. Should an EPA 

inspector visit a facility, it would be important to be able to examine not only the current year’s 

records, but also those from previous years, because previous years’ data would provide year-toyear comparisons, which are useful for verifying the current year’s data. A 5-year record 

retention period would ensure the availability of relevant records for the follow-up activities 

described above. 

Second, EPA considered revisions to the recordkeeping format for “inputs to equations” data 

elements. Currently, reporters have the option to maintain records of their “inputs to equations” 
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8 

data elements in one or more electronic or hard copy files. Requiring reporters to maintain an 

electronic or hard copy of the single file generated by the inputs verification tool (i.e., a file 

listing all “inputs to equations” data elements entered into the tool) would ensure that EPA could 

readily access these data during site visits, enabling EPA to quickly and efficiently perform 

calculations and data checks. 

4.3 Description of Additional Reporting Requirements 

To improve the efficiency of the data verification process under this alternative approach using 

the inputs verification tool described in section 4.1 and the enhanced recordkeeping described in 

section 4.2, EPA considered supplementing the information available to EPA under the GHGRP 

by requiring reporting of additional data. Certain additional data would enable EPA to perform 

additional verification checks, thereby minimizing the number of follow-up activities. Such data 

would provide information on the activity level at the facility, emission factors, characteristics of 

carbon-containing streams, and other process information that provide key information for 

verification (e.g., data confirming that emissions are appropriate for a given activity-level, and 

data estimating expected emissions based on data provided). 

4.4 Review of Effectiveness of Using an Inputs Verification Tool, Enhanced 

Recordkeeping, and Additional Reporting To Accomplish Data Verification 

In the October 30, 2009 final rule (74 FR 56282 – 56283), EPA described its verification 

approach as the following two-step process: 

 Initial automated review of reported data, using an electronic data quality assurance 

program built into the data system, for use by reporters and EPA to help assure the 

completeness and accuracy of data. 

 Based on the initial review results, follow up with facilities regarding potential errors, 

discrepancies, or questions, including on-site audits. 

The use of the inputs verification tool to conduct verification checks on the “inputs to equations” 

data elements (as described in section 4.1) would build on EPA’s experience with electronic 

reporting and verification during the first two years of the GHGRP. As discussed in more detail 

in section 2.0, for reporting years 2010 and 2011, EPA used electronic verification checks to 

verify data and follow up with thousands of facilities. For 2011 alone, based on 3,700 types of 

checks, EPA followed up with approximately 3,440 of the approximately 7,900 reporting 

facilities. 

The inputs verification tool utilizes the same approach that EPA currently uses for calculating 

and verifying data submitted for supplier subparts (and starting in reporting year 2012, inputs to 

emission equations for which the reporting deadline was deferred until 2013), except that eGGRT would not retain the “inputs to equations” data elements entered into the tool, as 
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9 

described in section 4.1. Once the annual report is submitted, EPA would review the verification 

summary generated by the inputs verification tool, along with verification summaries that are 

currently generated using data currently collected through the annual report. By requiring use of 

the inputs verification tool, EPA would have the additional certainty that reported annual GHG 

emissions values either were calculated correctly (because the values calculated by the tool were 

submitted to EPA) or that EPA would be made aware that there were discrepancies between 

values calculated by the tool and values submitted to EPA. This additional certainty, combined 

with the additional information provided by the range and algorithm verification checks 

conducted on the “inputs to equations” data elements themselves, would provide EPA with the 

information necessary to conduct further verification once the annual report is submitted. 

Once data verification within the inputs verification tool is completed and the annual report is 

submitted, EPA would conduct the same verification checks that it currently conducts (following 

annual report submittal) on data reported via e-GGRT and additional verification checks using 

the information provided by the additional reporting requirements. Regarding any needed followup with facilities, the enhanced recordkeeping requirements described in section 4.2 (i.e., 5-year 

retention period and uniform format) would ensure that EPA has adequate time to efficiently 

examine the “inputs to equations” data elements on-site. 

5.0 Summary 

EPA identified the alternative verification approach consisting of the use of the inputs 

verification tool, enhanced recordkeeping, and additional reporting as a viable alternative 

approach to verifying data reported under the 25 subparts being evaluated in this memorandum. 

This approach would ensure effective verification of reported emissions and compliance with the 

program. 
Attachment S 
TECHNICAL MEMORANDUM 

DATE: July 31, 2013 

TO: Docket EPA-HQ-OAR-2010-0929 

FROM: Jennifer Bohman, Climate Change Division, US EPA

SUBJECT: Technical Approach and Design of the Inputs Verification Tool 

1. Introduction and Purpose 

The purpose of this memorandum is to provide a detailed description of EPA’s technical 

approach and design for the inputs verification tool. Section 2 describes how users would 

interact with the inputs verification tool under e-GGRT’s two reporting options as well as the 

basic function of the tool. Section 3 describes the database design for the e-GGRT application 

and data structure for the inputs verification tool. Section 4 describes how the inputs verification 

tool manages data for the two reporting options. 

2. Description

The inputs verification tool would accommodate the two reporting options currently available in 

e-GGRT: entry of data on web forms and the upload of data in XML files. This section 

describes how users would interact with the inputs verification tool for both of these reporting 

options as well as the basic function of the tool. 

For the web form reporting option, users would enter their annual GHG report information in the 

e-GGRT application and their inputs to emission equations in the inputs verification tool. The 

inputs verification tool would calculate emission results, conduct verification checks on the 

inputs to emission equations, and generate a verification summary listing the results of the 

verification check. The inputs to equations would not be saved and would be immediately 

deleted when the user logs out, closes the browser window, or if the user’s session times out due 

to an extended period (e.g., 25 minutes) of inactivity (see Section 4 of this memorandum for 

additional details). Only the verification summary as well as the data reporting elements 

required in the annual GHG report would be saved to the e-GGRT database and accessible 

during subsequent user sessions. 

The inputs verification tool would be a module within the e-GGRT application. To access the 

inputs verification tool, users would log in to e-GGRT with their username and password, select 

their facility, and navigate to the “Data Reporting” section of e-GGRT. Within this section of 

the application, users would be clearly directed to enter the inputs verification tool interface 

when they are required to enter inputs. The inputs verification tool would then present web 

forms where users would enter their inputs to equations. The inputs verification tool screens 
would differ in appearance from the regular e-GGRT screens, as a visual cue to users that they 

are entering data in the inputs verification tool module and that the data is handled differently. 

The inputs verification tool would perform checks to verify that the inputs to equations data is 

complete, that data elements are within the expected ranges, and whether expected relationships 

exist between inputs to equations data and other data entered for the facility that is part of the 

annual GHG report. The inputs verification tool would also calculate emissions values, which 

would automatically be included into the annual GHG report unless the facility elects to enter an 

alternate result. Attachment 1 includes several screen captures of the inputs verification tool 

module within e-GGRT. 

For the XML upload reporting option, users would upload an XML file containing their entire 

annual report data submission that conforms to the published e-GGRT XML Reporting Schema. 

Additionally, users would upload a separate XML file containing a complete set of inputs to 

equations data that conforms to the inputs verification tool XML schema (see Section 3 of this 

memorandum for additional information on the inputs verification tool schema). Similar to the 

web form reporting option, the inputs verification tool would calculate emission results based on 

the inputs file uploaded, conduct verification checks on the inputs to emission equations, 

compare calculated results to those included in the annual report XML file, and generate a 

verification summary listing the results of the verification check. The inputs to equations XML 

file would not be saved and would be immediately deleted when the user logs out, closes the 

browser window, or if the user’s session times out due to an extended period (e.g., 25 minutes) 

of inactivity (see Section 4 of this memorandum for additional details on this process). Only the 

verification summary as well as annual GHG report XML file would be saved to the e-GGRT 

database and accessible during subsequent user sessions. 

 

For the XML upload option, there would be no inputs verification tool screens. Instead, users 

would be prompted to upload their annual report XML file, upload their inputs to equations 

XML file, and the inputs verification tool processes the files in the background. When 

completed, users would be taken to a summary screen that presents a comprehensive verification 

summary for review. 

3. Design 

This section describes the database design for the e-GGRT application and the inputs verification 

tool. This design ensures that data entered into or used by the inputs verification tool is not 

saved to the e-GGRT database. This section also describes how this design is used for the two 

reporting options. 

The e-GGRT application and the inputs verification tool have separate data structures. The data 

structure for the e-GGRT application defines how data in the annual report is organized and 

stored. Therefore, the e-GGRT data structure only provides for storage of annual report data 

elements and associated metadata elements (e.g., date/timestamps, status values, etc.). The data 

structure for the inputs verification tool defines how the inputs to equations are organized and 

only provides for in-memory handling of inputs to equations and associated metadata elements. 

The segregation of the two data structures ensures that annual report data is not comingled with 

inputs to equations. 
For the web forms reporting option, users enter annual report data into e-GGRT web forms. 

These annual report data are persisted to an Oracle relational database maintained on an EPA 

server at the Agency’s National Computing Center as the user navigates through the e-GGRT 

web application and takes certain actions (e.g., clicking a “SAVE” or “NEXT” button). Users 

enter inputs into the inputs verification tool, but the data are not saved to the Oracle relational 

database (see Section 4 of this memorandum for additional details). Upon generating an annual 

report, annual report data stored in the relational database is retrieved and formatted in 

accordance with the published e-GGRT XML Reporting Schema. The reporting schema does 

NOT contain any data element definitions for inputs to equations, ensuring that annual GHG 

reports exclude inputs to equations. 

For the XML reporting option, users would upload two XML files, one file with the annual GHG 

report data (comporting with the e-GGRT data structure) and one file with inputs to equations 

(comporting with the inputs verification tool data structure). Data from each file would be 

loaded into their corresponding and separate data structures. If a user attempted to upload an 

XML annual report file containing extraneous/additional data elements, it would be rejected as 

invalid. EPA would conduct verification checks on the inputs to equations stored temporarily in 

session memory and generate a verification summary. EPA would not save the inputs to 

equations file. EPA would only save the file with the annual GHG report data and the resulting 

verification summary. 

Attachment 2 shows the e-GGRT data structure and demonstrates that no table or column exists 

to store the inputs to equations data elements. It also contains the data structure for the inputs 

verification tool prototype developed for subpart X, mass balance methodology. 

4. Data Management 

This section describes how the inputs verification tool manages data for the two reporting 

options. 

For the web form reporting option, users would enter data into the inputs verification tool web 

forms. As the user enters this data, it is temporarily stored to an area of the application server 

called the session. The session is a temporary, in-memory structure of the server hosting the eGGRT application. A separate, unique session is launched with each login. The session is 

terminated when the user logs out or when the inactive period is reached. It is not possible for 

another, unauthorized user to share the same session, even by logging in with the same username 

and password of a user who is currently logged in. By design, Java Web application servers such 

as those used by the inputs verification tool prohibit users from viewing another user’s session. 

Each session is only visible to the user connected to the inputs verification tool and the e-GGRT 

application. E-GGRT uses two load-balanced application servers and a separate database server. 

Session data is not persisted (saved) to disk memory on the application or database server and is 

not replicated in any way. When a session ends, session data is immediately and permanently 

deleted. It does not persist in any form. For example, session data is not sent to a recycle bin or 

deleted items folder. Because the inputs to equations data are not saved to the database or disk, 
the data is not overwritten, copied, replicated, or backed up. No permanent cookies are used by 

the inputs verification tool. Note that the e-GGRT database is backed up daily and may 

periodically be replicated. However, as discussed above, the database does not contain inputs to 

equations, so no copies of the inputs data are either created or maintained. 

EPA anticipates that some users would not be able to enter all their inputs to equations into the 

inputs verification tool web forms during one sitting. Alternately, some users may want to 

update or correct inputs that were entered during a prior session without having to re-enter all 

their inputs to equations. Because the inputs verification tool does not save data, users would be 

responsible for saving and uploading their inputs data if they do not plan to enter all inputs to 

equations as well as submit their annual report in the one e-GGRT session. The inputs 

verification tool will assist users in this process. During each session, users will have the option 

to export their inputs data that is currently in session or to import a previously exported inputs 

data file. If a user chooses the export option, the inputs verification tool would create a zip file 

containing an XML file and a human-readable HTML file of their data that the user could save to 

their computer or network file system. The XML and HTML files only exist in session memory 

and would be deleted immediately when the session ends. 

For the XML reporting option, users would upload the inputs verification tool file as described in 

Sections 2 and 3 of this memorandum. As with the web forms reporting option, the inputs 

verification tool would temporarily store the data to the session. The inputs verification tool 

would then manage the data in the same way as described for the web form reporting option. 

Attachment 3 shows the code structure for the inputs verification tool loading the inputs XML 

(for those using the XML reporting method) and the code that uses the data without persisting 

the data at any point. 
Attachment T 
Attachment 1 - Screen Captures of Inputs Verification Tool 
Page 1 

Purpose: This attachment provides a brief overview of how the inputs verification tool functions from the user’s 

perspective (for the web forms reporting option). 

To access the inputs verification tool, users would log in to e-GGRT with their username and password, select 

their facility, and navigate to the “Data Reporting” section of e-GGRT. In the screenshot below, the user has 

selected the “Data Reporting” tab and also entered the Subpart X reporting module. They have added a 

petrochemical processing unit that has been named “Methanol Unit 101” and they have added one carboncontaining feedstock and one carbon-containing product for the process unit. 

 Figure 1. e-GGRT Data Reporting Screen

From this screen, the user would use the button labeled “Use Inputs Verifier to calculate | GO” to access the 

inputs verification module and enter equation inputs for the feedstock(s) and product(s) they have added. 

 
Page 2 

The screens in the inputs verification tool module are different in appearance and are indicated by a label in the 

title bar. 

Figure 2. Inputs Verifier Tool Screen 

The user will enter data in the inputs fields. Please note that every field for inputs to equations states that the 

data “will not be stored by EPA”. 

 
Page 3 

The user will continue entering inputs to equations. 

Figure 3. Enter Inputs and Calculate 

After entering inputs to equations, the user would click the “SAVE” button, shown in Figure 3. 

The inputs verification tool will calculate the result of the equation for which the user is entering inputs. 

 
Page 4 

Figure 4. Before Exporting An Inputs Data File

In the FACILITY’S INPUTS VERIFIER FILE section of the screen, the message states “Inputs Data Not 

Saved” (indicated in Figure 4). 

The user would click “Save Inputs Data Locally” (indicated in Figure 4) to export the inputs data and save the 

inputs data file to their computer. 

 
Page 5 

Figure 5. After Exporting An Inputs Data File

The message will change to “Inputs Data Loaded” and the information in the “Exported By (Date)” field will be 

updated (indicated in Figure 5). 

The user can log out of e-GGRT (shown in the red outline) and then log in again later to continue entering data 

by loading the inputs data file that they saved to their computer. 

 
Page 6 

Figure 6. e-GGRT Login Screen 

The user can log in again with their e-GGRT username and password to resume entering inputs data. 

 
Page 7 

After logging in again, the user would navigate to the Data Reporting section of e-GRRT. As described 

previously, the user would click the “Use Inputs Verifier to calculate | GO” button to open the inputs 

verification tool module. 

Figure 8 shows the inputs verification tool screen before the user has loaded an inputs data file. 

Figure 7. Inputs Verifier Screen Before Loading An Inputs Data File 

As shown in Figure 7, the inputs fields are blank. This is because the system did not store inputs data from the 

user’s previous session. 

In the FACILITY’S INPUTS VERIFIER FILE section of the screen, the message states “Inputs Data Not 

Loaded”. To load an inputs data file, the user would click the link labeled “Temporarily Load Inputs Data. 

 
Page 8 

The user would browse to and select the inputs data file saved to their local computer. The user would then 

click the “Import” button to load the file to the inputs verification tool. 

Figure 8. Loading A Saved Inputs Data File 

 
Page 9 

Figure 9. After Loading An Inputs Data File 

After importing the inputs file, the message will change to “Inputs Data Loaded” and the inputs fields will be 

populated with information from the inputs data file that the user imported. 
Attachment U 
Attachment 2. Data Structure 

 
Database Structure 

Figure 1 contains a sample annual GHG report (in XML) for Subpart X that is properly formatted. This file 

would be submitted to EPA and saved in the e-GGRT database. Note that there are no equation inputs contained 

in the annual report file structure. Figure 2 contains a sample Inputs Verification Tool file (in XML) for Subpart 

X that is properly formatted. This file would be generated and used by the Inputs Verification Tool. This file 

would not be saved to the eGGRT database. This file would be saved and maintained by reporters on their local 

machines. Figure 1 and Figure 2 demonstrate that inputs data would not be intermixed with annual report data, 

but kept in separate data structures. Only the annual report data (as seen in Figure 1) would be saved by EPA. 

Figure 1: XML Structure for Subpart X Annual GHG Report 

- <GHG xmlns="http://www.ccdsupport.com/schema/ghg">

- <FacilitySiteInformation>

<CertificationStatement>The designated representative or alternate designated representative must 

sign (i.e., agree to) this certification statement. If you are an agent and you click on "SUBMIT", 

you are not agreeing to the certification statement, but are submitting the certification 

statement on behalf of the designated representative or alternate designated representative 

who is agreeing to the certification statement. An agent is only authorized to make the 

electronic submission on behalf of the designated representative, not to sign (i.e., agree to) the 

certification statement.</CertificationStatement> 

<ReportingYear>2012</ReportingYear> 

- <FacilitySiteDetails>

- <FacilitySite>

<FacilitySiteIdentifier>509238</FacilitySiteIdentifier> 

<FacilitySiteName>Peregrinus Industries</FacilitySiteName> 

</FacilitySite>

- <LocationAddress>

<LocationAddressText>100 Oak</LocationAddressText> 

<LocalityName>McLean</LocalityName> 

- <StateIdentity>

<StateCode>VA</StateCode> 

</StateIdentity>

<AddressPostalCode>22124</AddressPostalCode> 

</LocationAddress>

<CogenerationUnitEmissionsIndicator>N</CogenerationUnitEmissionsIndicator> 

<PrimaryNAICSCode>112111</PrimaryNAICSCode> 

- <ParentCompanyDetails>

- <ParentCompany>

<ParentCompanyLegalName>US GOVERNMENT</ParentCompanyLegalName> 

</ParentCompany>

</ParentCompanyDetails>

<TotalNonBiogenicCO2eFacilitySubpartsCtoJJ massUOM="Metric 

Tons">306892.8</TotalNonBiogenicCO2eFacilitySubpartsCtoJJ> 

<TotalBiogenicCO2FacilitySubpartsCtoJJ massUOM="Metric 

Tons">0</TotalBiogenicCO2FacilitySubpartsCtoJJ> 

<TotalCO2eSupplierSubpartsKKtoPP massUOM="Metric Tons">0</TotalCO2eSupplierSubpartsKKtoPP> 

- <SubPartInformation>

- <SubPartX>

- <GHGasInfoDetails>

<GHGasName>Biogenic Carbon dioxide</GHGasName> 

- <GHGasQuantity massUOM="Metric Tons">

<CalculatedValue>0</CalculatedValue> 
</GHGasQuantity>

</GHGasInfoDetails>

- <GHGasInfoDetails>

<GHGasName>Methane</GHGasName> 

- <GHGasQuantity massUOM="Metric Tons">

<CalculatedValue>0</CalculatedValue> 

</GHGasQuantity>

</GHGasInfoDetails>

- <GHGasInfoDetails>

<GHGasName>Nitrous Oxide</GHGasName> 

- <GHGasQuantity massUOM="Metric Tons">

<CalculatedValue>0</CalculatedValue> 

</GHGasQuantity>

</GHGasInfoDetails>

- <GHGasInfoDetails>

<GHGasName>Carbon Dioxide</GHGasName> 

- <GHGasQuantity massUOM="Metric Tons">

<CalculatedValue>3849.1</CalculatedValue> 

</GHGasQuantity>

</GHGasInfoDetails>

- <CEMSDetails>

- <CEMSUnitDetails>

- <UnitIdentification>

<UnitName>xCEMS</UnitName> 

<UnitType>Petrochemical process unit</UnitType> 

</UnitIdentification>

- <XProductDetails>

<PetroChemicalProductType>Methanol</PetroChemicalProductType> 

- <ProductQuantity massUOM="Metric Tons">

<MeasureValue>11111</MeasureValue> 

</ProductQuantity>

</XProductDetails>

</CEMSUnitDetails>

</CEMSDetails>

- <MassBalanceDetails>

- <UnitIdentification>

<UnitName>Methanol Unit 101</UnitName> 

<UnitDescription>methanol production unit</UnitDescription> 

<UnitType>Petrochemical process unit</UnitType> 

</UnitIdentification>

- <AnnualCO2Emissions massUOM="Metric Tons">

<CalculatedValue>33101.1</CalculatedValue> 

</AnnualCO2Emissions>

<CombustionUnitIdentifiers>None</CombustionUnitIdentifiers> 

- <ProductFeedStockDetails>

<ProductOrFeedstockIndicator>Feedstock</ProductOrFeedstockIndicator> 

<Type>Natural gas</Type> 

<PhysicalState>Gaseous</PhysicalState> 

- <FlowMeterDetails>

<ManufacturersRecommendedMethod>Twice weekly 

measurements</ManufacturersRecommendedMethod> 

<CalibrationMethod>Twice weekly calibrations</CalibrationMethod> 

</FlowMeterDetails>

- <AnnualQuantity massUOM="Metric Tons">

<MeasureValue>500250</MeasureValue> 
</AnnualQuantity>

- <MonthlyDetails>

<MonthName>January</MonthName> 

- <OtherProductFeedStockDetails>

- <VolumeorMass>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</VolumeorMass>

<VolumeorMassMethod>Tank level measurements</VolumeorMassMethod> 

- <CarbonContent>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</CarbonContent>

<CarbonContentMethod>ASTM D5373-08</CarbonContentMethod> 

- <MolecularWeight>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</MolecularWeight>

<MolecularWeightMethod>Calculated based on chemical formula and atomic 

weights</MolecularWeightMethod> 

<VolumeTemperatureBasis>60 degrees Fahrenheit</VolumeTemperatureBasis> 

</OtherProductFeedStockDetails>

</MonthlyDetails>

- <MonthlyDetails>

<MonthName>February</MonthName> 

- <OtherProductFeedStockDetails>

- <VolumeorMass>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</VolumeorMass>

<VolumeorMassMethod>Tank level measurements</VolumeorMassMethod> 

- <CarbonContent>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</CarbonContent>

<CarbonContentMethod>ASTM D5373-08</CarbonContentMethod> 

- <MolecularWeight>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</MolecularWeight>

<MolecularWeightMethod>Calculated based on chemical formula and atomic 

weights</MolecularWeightMethod> 

<VolumeTemperatureBasis>60 degrees Fahrenheit</VolumeTemperatureBasis> 

</OtherProductFeedStockDetails>

</MonthlyDetails>

- <MonthlyDetails>

<MonthName>March</MonthName> 

- <OtherProductFeedStockDetails>

- <VolumeorMass>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</VolumeorMass>

<VolumeorMassMethod>Tank level measurements</VolumeorMassMethod> 

- <CarbonContent>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</CarbonContent>

<CarbonContentMethod>ASTM D5373-08</CarbonContentMethod> 

- <MolecularWeight>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</MolecularWeight>

<MolecularWeightMethod>Calculated based on chemical formula and atomic 

weights</MolecularWeightMethod> 
<VolumeTemperatureBasis>60 degrees Fahrenheit</VolumeTemperatureBasis> 

</OtherProductFeedStockDetails>

</MonthlyDetails>

- <MonthlyDetails>

<MonthName>April</MonthName> 

- <OtherProductFeedStockDetails>

- <VolumeorMass>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</VolumeorMass>

<VolumeorMassMethod>Tank level measurements</VolumeorMassMethod> 

- <CarbonContent>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</CarbonContent>

<CarbonContentMethod>ASTM D5373-08</CarbonContentMethod> 

- <MolecularWeight>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</MolecularWeight>

<MolecularWeightMethod>Calculated based on chemical formula and atomic 

weights</MolecularWeightMethod> 

<VolumeTemperatureBasis>60 degrees Fahrenheit</VolumeTemperatureBasis> 

</OtherProductFeedStockDetails>

</MonthlyDetails>

- <MonthlyDetails>

<MonthName>May</MonthName> 

- <OtherProductFeedStockDetails>

- <VolumeorMass>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</VolumeorMass>

<VolumeorMassMethod>Tank level measurements</VolumeorMassMethod> 

- <CarbonContent>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</CarbonContent>

<CarbonContentMethod>ASTM D5373-08</CarbonContentMethod> 

- <MolecularWeight>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</MolecularWeight>

<MolecularWeightMethod>Calculated based on chemical formula and atomic 

weights</MolecularWeightMethod> 

<VolumeTemperatureBasis>60 degrees Fahrenheit</VolumeTemperatureBasis> 

</OtherProductFeedStockDetails>

</MonthlyDetails>

- <MonthlyDetails>

<MonthName>June</MonthName> 

- <OtherProductFeedStockDetails>

- <VolumeorMass>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</VolumeorMass>

<VolumeorMassMethod>Tank level measurements</VolumeorMassMethod> 

- <CarbonContent>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</CarbonContent>

<CarbonContentMethod>ASTM D5373-08</CarbonContentMethod> 

- <MolecularWeight>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</MolecularWeight>
<MolecularWeightMethod>Calculated based on chemical formula and atomic 

weights</MolecularWeightMethod> 

<VolumeTemperatureBasis>60 degrees Fahrenheit</VolumeTemperatureBasis> 

</OtherProductFeedStockDetails>

</MonthlyDetails>

- <MonthlyDetails>

<MonthName>July</MonthName> 

- <OtherProductFeedStockDetails>

- <VolumeorMass>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</VolumeorMass>

<VolumeorMassMethod>Tank level measurements</VolumeorMassMethod> 

- <CarbonContent>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</CarbonContent>

<CarbonContentMethod>ASTM D5373-08</CarbonContentMethod> 

- <MolecularWeight>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</MolecularWeight>

<MolecularWeightMethod>Calculated based on chemical formula and atomic 

weights</MolecularWeightMethod> 

<VolumeTemperatureBasis>60 degrees Fahrenheit</VolumeTemperatureBasis> 

</OtherProductFeedStockDetails>

</MonthlyDetails>

- <MonthlyDetails>

<MonthName>August</MonthName> 

- <OtherProductFeedStockDetails>

- <VolumeorMass>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</VolumeorMass>

<VolumeorMassMethod>Tank level measurements</VolumeorMassMethod> 

- <CarbonContent>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</CarbonContent>

<CarbonContentMethod>ASTM D5373-08</CarbonContentMethod> 

- <MolecularWeight>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</MolecularWeight>

<MolecularWeightMethod>Calculated based on chemical formula and atomic 

weights</MolecularWeightMethod> 

<VolumeTemperatureBasis>60 degrees Fahrenheit</VolumeTemperatureBasis> 

</OtherProductFeedStockDetails>

</MonthlyDetails>

- <MonthlyDetails>

<MonthName>September</MonthName> 

- <OtherProductFeedStockDetails>

- <VolumeorMass>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</VolumeorMass>

<VolumeorMassMethod>Tank level measurements</VolumeorMassMethod> 

- <CarbonContent>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</CarbonContent>

<CarbonContentMethod>ASTM D5373-08</CarbonContentMethod> 

- <MolecularWeight>
<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</MolecularWeight>

<MolecularWeightMethod>Calculated based on chemical formula and atomic 

weights</MolecularWeightMethod> 

<VolumeTemperatureBasis>60 degrees Fahrenheit</VolumeTemperatureBasis> 

</OtherProductFeedStockDetails>

</MonthlyDetails>

- <MonthlyDetails>

<MonthName>October</MonthName> 

- <OtherProductFeedStockDetails>

- <VolumeorMass>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</VolumeorMass>

<VolumeorMassMethod>Tank level measurements</VolumeorMassMethod> 

- <CarbonContent>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</CarbonContent>

<CarbonContentMethod>ASTM D5373-08</CarbonContentMethod> 

- <MolecularWeight>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</MolecularWeight>

<MolecularWeightMethod>Calculated based on chemical formula and atomic 

weights</MolecularWeightMethod> 

<VolumeTemperatureBasis>60 degrees Fahrenheit</VolumeTemperatureBasis> 

</OtherProductFeedStockDetails>

</MonthlyDetails>

- <MonthlyDetails>

<MonthName>November</MonthName> 

- <OtherProductFeedStockDetails>

- <VolumeorMass>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</VolumeorMass>

<VolumeorMassMethod>Tank level measurements</VolumeorMassMethod> 

- <CarbonContent>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</CarbonContent>

<CarbonContentMethod>ASTM D5373-08</CarbonContentMethod> 

- <MolecularWeight>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</MolecularWeight>

<MolecularWeightMethod>Calculated based on chemical formula and atomic 

weights</MolecularWeightMethod> 

<VolumeTemperatureBasis>60 degrees Fahrenheit</VolumeTemperatureBasis> 

</OtherProductFeedStockDetails>

</MonthlyDetails>

- <MonthlyDetails>

<MonthName>December</MonthName> 

- <OtherProductFeedStockDetails>

- <VolumeorMass>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</VolumeorMass>

<VolumeorMassMethod>Tank level measurements</VolumeorMassMethod> 

- <CarbonContent>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</CarbonContent>
<CarbonContentMethod>ASTM D5373-08</CarbonContentMethod> 

- <MolecularWeight>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</MolecularWeight>

<MolecularWeightMethod>Calculated based on chemical formula and atomic 

weights</MolecularWeightMethod> 

<VolumeTemperatureBasis>60 degrees Fahrenheit</VolumeTemperatureBasis> 

</OtherProductFeedStockDetails>

</MonthlyDetails>

</ProductFeedStockDetails>

- <ProductFeedStockDetails>

<ProductOrFeedstockIndicator>Product</ProductOrFeedstockIndicator> 

<Type>Methanol</Type> 

<PhysicalState>Liquid</PhysicalState> 

- <FlowMeterDetails>

<ManufacturersRecommendedMethod>twice monthly 

measurements</ManufacturersRecommendedMethod> 

<CalibrationMethod>twice monthly calibrations</CalibrationMethod> 

</FlowMeterDetails>

- <AnnualQuantity massUOM="Metric Tons">

<MeasureValue>678260</MeasureValue> 

</AnnualQuantity>

- <MonthlyDetails>

<MonthName>January</MonthName> 

- <OtherProductFeedStockDetails>

- <VolumeorMass>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</VolumeorMass>

<VolumeorMassMethod>Tank level measurements</VolumeorMassMethod> 

- <CarbonContent>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</CarbonContent>

<CarbonContentMethod>SW-846 Method 9060A</CarbonContentMethod> 

- <MolecularWeight>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</MolecularWeight>

</OtherProductFeedStockDetails>

</MonthlyDetails>

- <MonthlyDetails>

<MonthName>February</MonthName> 

- <OtherProductFeedStockDetails>

- <VolumeorMass>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</VolumeorMass>

<VolumeorMassMethod>Tank level measurements</VolumeorMassMethod> 

- <CarbonContent>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</CarbonContent>

<CarbonContentMethod>SW-846 Method 9060A</CarbonContentMethod> 

- <MolecularWeight>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</MolecularWeight>

</OtherProductFeedStockDetails>

</MonthlyDetails>

- <MonthlyDetails>
<MonthName>March</MonthName> 

- <OtherProductFeedStockDetails>

- <VolumeorMass>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</VolumeorMass>

<VolumeorMassMethod>Tank level measurements</VolumeorMassMethod> 

- <CarbonContent>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</CarbonContent>

<CarbonContentMethod>SW-846 Method 9060A</CarbonContentMethod> 

- <MolecularWeight>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</MolecularWeight>

</OtherProductFeedStockDetails>

</MonthlyDetails>

- <MonthlyDetails>

<MonthName>April</MonthName> 

- <OtherProductFeedStockDetails>

- <VolumeorMass>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</VolumeorMass>

<VolumeorMassMethod>Tank level measurements</VolumeorMassMethod> 

- <CarbonContent>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</CarbonContent>

<CarbonContentMethod>SW-846 Method 9060A</CarbonContentMethod> 

- <MolecularWeight>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</MolecularWeight>

</OtherProductFeedStockDetails>

</MonthlyDetails>

- <MonthlyDetails>

<MonthName>May</MonthName> 

- <OtherProductFeedStockDetails>

- <VolumeorMass>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</VolumeorMass>

<VolumeorMassMethod>Tank level measurements</VolumeorMassMethod> 

- <CarbonContent>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</CarbonContent>

<CarbonContentMethod>SW-846 Method 9060A</CarbonContentMethod> 

- <MolecularWeight>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</MolecularWeight>

</OtherProductFeedStockDetails>

</MonthlyDetails>

- <MonthlyDetails>

<MonthName>June</MonthName> 

- <OtherProductFeedStockDetails>

- <VolumeorMass>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</VolumeorMass>

<VolumeorMassMethod>Tank level measurements</VolumeorMassMethod> 

- <CarbonContent>
<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</CarbonContent>

<CarbonContentMethod>SW-846 Method 9060A</CarbonContentMethod> 

- <MolecularWeight>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</MolecularWeight>

</OtherProductFeedStockDetails>

</MonthlyDetails>

- <MonthlyDetails>

<MonthName>July</MonthName> 

- <OtherProductFeedStockDetails>

- <VolumeorMass>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</VolumeorMass>

<VolumeorMassMethod>Tank level measurements</VolumeorMassMethod> 

- <CarbonContent>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</CarbonContent>

<CarbonContentMethod>SW-846 Method 9060A</CarbonContentMethod> 

- <MolecularWeight>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</MolecularWeight>

</OtherProductFeedStockDetails>

</MonthlyDetails>

- <MonthlyDetails>

<MonthName>August</MonthName> 

- <OtherProductFeedStockDetails>

- <VolumeorMass>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</VolumeorMass>

<VolumeorMassMethod>Tank level measurements</VolumeorMassMethod> 

- <CarbonContent>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</CarbonContent>

<CarbonContentMethod>SW-846 Method 9060A</CarbonContentMethod> 

- <MolecularWeight>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</MolecularWeight>

</OtherProductFeedStockDetails>

</MonthlyDetails>

- <MonthlyDetails>

<MonthName>September</MonthName> 

- <OtherProductFeedStockDetails>

- <VolumeorMass>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</VolumeorMass>

<VolumeorMassMethod>Tank level measurements</VolumeorMassMethod> 

- <CarbonContent>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</CarbonContent>

<CarbonContentMethod>SW-846 Method 9060A</CarbonContentMethod> 

- <MolecularWeight>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</MolecularWeight>

</OtherProductFeedStockDetails>
</MonthlyDetails>

- <MonthlyDetails>

<MonthName>October</MonthName> 

- <OtherProductFeedStockDetails>

- <VolumeorMass>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</VolumeorMass>

<VolumeorMassMethod>Tank level measurements</VolumeorMassMethod> 

- <CarbonContent>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</CarbonContent>

<CarbonContentMethod>SW-846 Method 9060A</CarbonContentMethod> 

- <MolecularWeight>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</MolecularWeight>

</OtherProductFeedStockDetails>

</MonthlyDetails>

- <MonthlyDetails>

<MonthName>November</MonthName> 

- <OtherProductFeedStockDetails>

- <VolumeorMass>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</VolumeorMass>

<VolumeorMassMethod>Tank level measurements</VolumeorMassMethod> 

- <CarbonContent>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</CarbonContent>

<CarbonContentMethod>SW-846 Method 9060A</CarbonContentMethod> 

- <MolecularWeight>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</MolecularWeight>

</OtherProductFeedStockDetails>

</MonthlyDetails>

- <MonthlyDetails>

<MonthName>December</MonthName> 

- <OtherProductFeedStockDetails>

- <VolumeorMass>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</VolumeorMass>

<VolumeorMassMethod>Tank level measurements</VolumeorMassMethod> 

- <CarbonContent>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</CarbonContent>

<CarbonContentMethod>SW-846 Method 9060A</CarbonContentMethod> 

- <MolecularWeight>

<IsSubstitutedIndicator>N</IsSubstitutedIndicator> 

</MolecularWeight>

</OtherProductFeedStockDetails>

</MonthlyDetails>

</ProductFeedStockDetails>

- <XProductDetails>

<PetroChemicalProductType>Methanol</PetroChemicalProductType> 

</XProductDetails>

- <OffSpecProductMassorVolume volUOM="Gallons">

<MeasureValue>56880</MeasureValue> 
</OffSpecProductMassorVolume>

<NumberofDaysOffSpecProductProduced>2</NumberofDaysOffSpecProductProduced> 

- <AdditionalDetails>

- <CarbonContentofWasteWater fractionUOM="decimal fraction">

<MeasureValue>0.05</MeasureValue> 

</CarbonContentofWasteWater>

- <AnnualAverageWasteWaterFlow UnitsofMeasure="gal">

<MeasureValue>56548800</MeasureValue> 

</AnnualAverageWasteWaterFlow>

</AdditionalDetails>

</MassBalanceDetails>

</SubPartX>

</SubPartInformation>

</FacilitySiteDetails>

<StartDate>2012-01-01</StartDate> 

<EndDate>2012-12-31</EndDate> 

<DateTimeReportGenerated>2013-08-02T10:34:59</DateTimeReportGenerated> 

- <SubpartBAMMDetails>

<SubpartName>C</SubpartName> 

<WasBAMMUsed>Y</WasBAMMUsed> 

<BAMMUsedDescription>test</BAMMUsedDescription> 

<BAMMUseStartDate>2012-12-01</BAMMUseStartDate> 

<BAMMUseEndDate>2012-12-31</BAMMUseEndDate> 

</SubpartBAMMDetails>

- <SubpartBAMMDetails>

<SubpartName>X</SubpartName> 

</SubpartBAMMDetails>

</FacilitySiteInformation>

</GHG>

 
Figure 2: XML Structure for Subpart X Equation Inputs File 

<Facility name="Peregrinus Industries" reportingYear="2014" lastUpdateDate="2013-08-

02T09:18:23.907-04:00"> 

 <Subparts> 

 <Subpart name="X"> 

 <Units> 

 <Unit name="Methanol Unit 101" id="0"> 

 <Inputs> 

 <InputX4 name="Methanol Unit 101"> 

 <CO2Val>33101.07282811380</CO2Val> 

 <InputX1> 

 <Feedstocks> 

 <Feedstock name="Natural gas" id="0" MVC="836.6"> 

 <Months> 

 <Month> 

 <key>January</key> 

 <value> 

 <index>0</index> 

 <Volume>21890000</Volume> 

 <CC>0.71</CC> 

 <MW>45.6</MW> 

 </value> 

 </Month> 

 <Month> 

 <key>February</key> 

 <value> 

 <index>1</index> 

 <Volume>21890000</Volume> 

 <CC>0.71</CC> 

 <MW>45.6</MW> 

 </value> 

 </Month> 

 <Month> 

 <key>March</key> 

 <value> 

 <index>2</index> 

 <Volume>21890000</Volume> 

 <CC>0.71</CC> 

 <MW>45.6</MW> 

 </value> 

 </Month> 

 <Month> 

 <key>April</key> 

 <value> 

 <index>3</index> 

 <Volume>21890000</Volume> 

 <CC>0.71</CC> 

 <MW>45.6</MW> 

 </value> 

 </Month> 

 <Month> 

 <key>May</key> 

 <value> 

 <index>4</index> 

 <Volume>21890000</Volume> 

 <CC>0.71</CC> 

 <MW>45.6</MW> 

 </value> 

 </Month> 

 <Month> 
 <key>June</key> 

 <value> 

 <index>5</index> 

 <Volume>21890000</Volume> 

 <CC>0.71</CC> 

 <MW>45.6</MW> 

 </value> 

 </Month> 

 <Month> 

 <key>July</key> 

 <value> 

 <index>6</index> 

 <Volume>21890000</Volume> 

 <CC>0.71</CC> 

 <MW>45.6</MW> 

 </value> 

 </Month> 

 <Month> 

 <key>August</key> 

 <value> 

 <index>7</index> 

 <Volume>21890000</Volume> 

 <CC>0.71</CC> 

 <MW>45.6</MW> 

 </value> 

 </Month> 

 <Month> 

 <key>September</key> 

 <value> 

 <index>8</index> 

 <Volume>21890000</Volume> 

 <CC>0.71</CC> 

 <MW>45.6</MW> 

 </value> 

 </Month> 

 <Month> 

 <key>October</key> 

 <value> 

 <index>9</index> 

 <Volume>21890000</Volume> 

 <CC>0.71</CC> 

 <MW>45.6</MW> 

 </value> 

 </Month> 

 <Month> 

 <key>November</key> 

 <value> 

 <index>10</index> 

 <Volume>21979000</Volume> 

 <CC>0.70</CC> 

 <MW>45.6</MW> 

 </value> 

 </Month> 

 <Month> 

 <key>December</key> 

 <value> 

 <index>11</index> 

 <Volume>30689000</Volume> 

 <CC>0.71</CC> 

 <MW>45.6</MW> 

 </value> 

 </Month> 

 </Months> 
 </Feedstock> 

 </Feedstocks> 

 </InputX1> 

 <InputX2> 

 <Products> 

 <Product name="Methanol" id="0"> 

 <Months> 

 <Month> 

 <key>January</key> 

 <value> 

 <index>0</index> 

 <Volume>50000</Volume> 

 <CC>2.45</CC> 

 </value> 

 </Month> 

 <Month> 

 <key>February</key> 

 <value> 

 <index>0</index> 

 <Volume>50000</Volume> 

 <CC>2.45</CC> 

 </value> 

 </Month> 

 <Month> 

 <key>March</key> 

 <value> 

 <index>0</index> 

 <Volume>50000</Volume> 

 <CC>2.45</CC> 

 </value> 

 </Month> 

 <Month> 

 <key>April</key> 

 <value> 

 <index>0</index> 

 <Volume>50000</Volume> 

 <CC>2.45</CC> 

 </value> 

 </Month> 

 <Month> 

 <key>May</key> 

 <value> 

 <index>0</index> 

 <Volume>50000</Volume> 

 <CC>2.45</CC> 

 </value> 

 </Month> 

 <Month> 

 <key>June</key> 

 <value> 

 <index>0</index> 

 <Volume>50000</Volume> 

 <CC>2.45</CC> 

 </value> 

 </Month> 

 <Month> 

 <key>July</key> 

 <value> 

 <index>0</index> 

 <Volume>50000</Volume> 

 <CC>2.45</CC> 

 </value> 

 </Month> 
 <Month> 

 <key>August</key> 

 <value> 

 <index>0</index> 

 <Volume>50000</Volume> 

 <CC>2.45</CC> 

 </value> 

 </Month> 

 <Month> 

 <key>September</key> 

 <value> 

 <index>0</index> 

 <Volume>50000</Volume> 

 <CC>2.45</CC> 

 </value> 

 </Month> 

 <Month> 

 <key>October</key> 

 <value> 

 <index>0</index> 

 <Volume>50000</Volume> 

 <CC>2.45</CC> 

 </value> 

 </Month> 

 <Month> 

 <key>November</key> 

 <value> 

 <index>0</index> 

 <Volume>50000</Volume> 

 <CC>2.45</CC> 

 </value> 

 </Month> 

 <Month> 

 <key>December</key> 

 <value> 

 <index>0</index> 

 <Volume>50000</Volume> 

 <CC>2.45</CC> 

 </value> 

 </Month> 

 </Months> 

 </Product> 

 </Products> 

 </InputX2> 

 <InputX3/> 

 </InputX4> 

 </Inputs> 

 </Unit> 

 </Units> 

 </Subpart> 

 </Subparts> 

</Facility> 
Attachment V 
1 

Attachment 3. Code Structure 

 
2 

Figures 1 and 2 demonstrate that the eGGRT code does not write data from the Inputs 

Verification Tool file into any database during the export or import process.

Figure 1. Export Process 

In Figure 1, the code highlighted in gray and outlined in yellow shows that the system writes data 

directly to the HTTP response which produces the file the user saves to their computer. 
3 

Figure 2. Import Process 

In Figure 2, the code highlighted in gray and outlined in yellow shows that the system stores the 

Java object in session after reading the user-supplied file. The location for storage is designated 

in the last line shown within the outlined area in Figure 2: “session.setAttribute(“inputDto”, 

x4);”. 

These figures illustrate the code used by uses who have elected to use the e-GGRT web forms to 

perform data entry. The code used to support direct XML uploads of annual report and inputs 

data is similar to that illustrated above.