# 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 Determin ations 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 corresp ondence. 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; Bo hman, 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 do cument that summarizes past FR langu age discussing the use of the GHG Reporting data and need for robust veri fication. I am also attaching an upd ated 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_Lis t 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 interage ncy 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 cl ear 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 Prev ention 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 de termining 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 fo r 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 VerificationM ethods 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 am endatory 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 indi cated, 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 I nputs Proposed Not To Report] [Attached file: Step 1 - Public Availability Analysis] [Attached file: Step 2 - Harm Analysis] [Attached file: Step 3 - Alte rnative 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 Verifi er Description - Memo 8.2] [Attached file: Attachme nt 1 - User Interface] [Attached file: Attachment 2 - Data Structure] [Attached file: Attachment 3 - Code Structure]

# Attachment BUSEPAGreenhouseGasReportingProgram:RevisionstoReportingandRecordkeeping Requirements,RecordkeepingRequirements,andProposedConfidentialityDeterminationsUSEPAInter‐AgencyBriefingMay201329,1Draft deliberative - do not cite or quoteOverview•BackgroundonGreenhouseGasReportingProgram•BackgroundonConfidentialityDeterminations•2015InputsProposal:KeyProvisions2Draft deliberative - do not cite or quoteOverview:U.S.EPAGHGReportingProgramGHGRP( )Goal ofGHGRP:TocollectaccurateandtimelydataonGHGinformationtoinormuturepolicdecisionsf fy• Rulecovers41sourcecategoriesforreporting,accountingfor85‐90%ofU.S.GHGemissions.• Generally,afacilitythatmeetstheemissionsthresholdof25,000ormoremetrictonsCO2eperyearreportstotheprogram• Monitoringbeganin2010formostemissionsourceswithfirstreports due bySeptember2011.reportsduebySeptember30,• Reportingonly,nocontroloruserequirements.33ConfidentialityDeterminations:OverallApproach• SeveralEPAprogramscollectCBIdata;generallyCBIdeterminationsmadeoncase‐by‐casebasis• Agencestablishedthatcase‐by‐casedeterminationsywerenotpracticableforGHGReportingProgram,giventhenumberofreporters(~10,000)anddataelements(~2,000)– Wouldnotresultintimelyreleaseofnon‐CBIdataBurdenreporters–onreportersandtheagency• EPAfinalizedCBIdeterminationsviarulemakingsformostGHGRPdata reporteddatareportedDraft, deliberative - do not quote or cite4InputstoEquations:OverallApproach• In2010,EPAproposedthat“inputstoequations”areemissiondata– PerCleanAirAct,emissiondatamustbemadeavailabletopublic• Highlevelofstakeholderintereston“inputstoequations”– Industry:Submittedcommentssayingmany“inputstoequations”havedisclosureconcerns– NGOs:Submittedcommentsassertingimportanceofcollectingandreleasing“inputstoequations”fordataverificationpurposes•EPAdeferredreportingof“inputsequations”until 20132015deferredreportingtoequationsuntil2013andtoallowtimetoevaluateissue• 2013analysiscompleteEPAdeterminednofurtheractionnecessary;;deferralexpiredMarch31,2013.Draft, deliberative - do not quote or cite52015InputsProposal:KeyProvisions(1)• 2015analysiscomplete;duetodisclosureconcerns,EPAproposingthatmost2015“inputstoequations”wouldnotbereported;recordsinstead(approximately400reportingreported;keptasrecordsinstead(approximatelyreportingelements)• Forthe2015“inputstoequations“withoutdisclosureconcerns,deferralwouldexpireanddatawouldbereported(approximately150reportingelements).–Approachconsistent“InputsEquations”Approachconsistentwith2013toEquations– Subpartsinclude:• SubpartC(StationaryFuelCombustion)Non‐part75ElectricGeneratingUnits• SubpartW(PetroleumandNaturalGas)•SubpartII(IndustrialWastewaterTreatment)Subpart(IndustrialWastewaterTreatment)• Approximately40otherinputsspanningacrossseveralsubparts6Draft deliberative - do not cite or quote2015InputsProposal:KeyProvisions(2)• Forsubpartswithdisclosureconcerns,EPAproposinganenhancedverificationapproachstartinginRY2014:enhancedverificationapproachstarting– Useofsoftwarewherereportersrequiredtoenter“inputstoequations”EPAverifies emissionscalculationswithoutequations.verifiesemissionscalculationswithoutthese“inputstoequations”beingreportedtoEPA–26newdatareportingelementsadded forverificationreportingelementsaddedforverification– Recordretentiontimeextendedfromcurrentrequirementof3yearsto 5yearsand“inputstoequations”must beequationsmustbekeptinformatgeneratedbysoftware.Draft deliberative - do not cite or quote72015InputsProposal:KeyConsiderations•Novelapproach would provide EPAabilityapproachwouldprovideEPAwithabilitytocalculatetheemissionsbasedontheequationsinputs,conductverificationchecksasdataisbeingreorted,pandprovideEPAwithinformationnecessarytoconductfurtherverificationoncetheannualreportissubmitted– Wouldhelptargetfacilitiesforfollow‐up•EPAdevelopedaprototype ofthesoftwareverificationdevelopedprototypeofsoftwareverificationapproachforonesubpart;willbeavailableon‐linefortestingdurinproosalcommentperiodgpDraft deliberative - do not cite or quote8ContactInformationForfurtherinformationpleasecontact:furtherinformation,contact:Lisa GroganMcCullochLisaGrogan‐GreenhouseGasReportingBranch,USEPAgrogan‐mcculloch lisa@epa govmcculloch.lisa@epa.gov617‐918‐1481Draft deliberative - do not cite or quote9AppendixA:DefinitionofEmissionData40CFR301(a)(2)(i):2.301(a)(2)(i):“(A)Informationnecessarytodeterminetheidentity,amount,frequency,concentration,orothercharacteristics(totheextentrelatedtoairquality)ofanyemissionemittedpollutantemissionwhichhasbeenemittedbythesource(orofanypollutantresultingfromanyemissionbythesource),oranycombinationoftheforegoing;(B)InformationnecessarytodeterminetheidentityamountfrequencyInformationnecessarydetermineidentity,,frequency,concentration,orothercharacteristics(totheextentrelatedtoairquality)oftheemissionswhich,underanapplicablestandardorlimitation,thesourcewasauthorized(includingtothenecessaryforsuch purposesaauthorizedtoemit(including,extentnecessarysuchpurposes,descriptionofthemannerorrateofoperationofthesource);and...”10Draft deliberative - do not cite or quoteAppendixB:SourceCategoriesCoveredinProposalC—GeneralStationaryFuelCombustionexceptCertainElectricGenerators2U—MiscellaneousUsesofCarbonateE—AdipicAcidProduction V—NitricAcidProductionF—AluminumProduction X—PetrochemicalProductionG—AmmoniaManufacturingY—PetroleumRefineriesH—CementProductionZ—PhosphoricAcidProductionK—FerroalloyProduction AA—PulpandPaperManufacturingL—FluorinatedGasProduction BB—SiliconCarbideProductionN—GlassProductionCC—SodaManufacturingProductionAshManufacturingO—HCFC–22ProductionandHFC–23DestructionEE—TitaniumDioxideProductionP—HydrogenProduction GG—ZincProductionQ—IronandSteelProduction II—IndustrialWastewaterTreatmentR—LeadProduction TT—IndustrialWasteLandfillsS—LimeManufacturingW‐PetroleumandNaturalGas11SLimeManufacturingWPetroleumandNaturalGasSystemsDraft 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 ec onomy-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 ad ditional 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 provi de 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 im prove our understanding of the factors that influence

GHG emission rates and actions that facilities are alread y 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 offs et 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 emissi ons 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 experi ence 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 pro posed 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 cat egories which emit different GHGs. Knowledge of both individual gases emitted and tota l 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 wo uld 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 operati ng 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 ensu re 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 reporte d data would need to be collected to determine

GHG emissions.

The following are excerpts from the Final Gree nhouse 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 est ablish new source performance standards (NSPS) for various source categories emitting GHGs, including whet her 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 tr eatment of those sources under CAA sections 202, 213 or 231. In addition, the information from fuel su ppliers 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 va riety 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 part nership 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 w ill 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 fac ility specific data will also improve our understanding

of the factors that influence GHG emission rates and ac tions 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 inform ation will prove useful for other purposes as well. For example, using the rich data set provided by this ru lemaking, 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, ex isting U.S. government programs (e.g., climate policy and research programs). For example, EPA an ticipates 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 Framew ork Convention on Climate Change (UNFCCC). A number of EPA voluntary partnership program s 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., reductio n of CH4 emissions or development of corporate inventories). It will im prove 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 a ppropriate) 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 a pplicable 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 comm ents and responses on the emissions information to be reported under the general provisi ons (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 reco rds more detailed emissions breakouts (e.g., by source category, process line, or unit) and activity da ta used to calculate emissions. Other commenters supported the proposed genera l 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 sour ce category. Comments received on the need for specific data elements are described and responded to in S ection 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 b een modified based on those comments. In general, reporting of such data is required primarily to enable emissions verification a nd ensure the consistency and accuracy of data collected under this rule. The in formation is also needed to support analyses of GHG emissions for future CAA policy and program deve lopment. Besides total facility emissions, it benefits policy makers to understa nd: (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 co mments 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 Ru le: 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 inform ation reported under this rule would be CBI (e.g., production and process data). Many commenters al so presented arguments regarding why certain information would not be ‘‘emissions data’’ under the CAA. Among th e 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 indus try 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 disseminati on of information, and argued that the information gathered under this rule should be ‘‘emissi ons 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 regard ing 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 prov ide 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 comm ents and responses on emissions verification of the GHG reports. A large number of comments were re ceived covering numerous topics. Responses to significant comments received can be found in ‘‘M andatory Greenhouse Gas Reporting Rule: EPA’s Response to Public Comments, Approach to Verification and Missing Data.’’

Comment: Many commenters, including most facilities and s uppliers 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 sel f-certification without independent emissions verification. They believed the designated representati ve provisions in the rule would cause reporters to take self certification seriously and ensure the emissi ons they report are correct. Some also stated that independent verification is not needed for a re porting program that does not require emissions

reductions.

Response: In selecting the approach to emissions verifica tion, EPA reviewed all of the comments, as well as emissions verification requirements and proce dures 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 inde pendent 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 propo sal and is requiring self certification with EPA

emissions verification. We decided to retain th is verification approach because it provides greater assurance of accuracy and impartiality than self-certifi cation 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 qu ality 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 throug h a centralized data system . EPA is developing this

## system and intends to make it available to reporte rs, 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 sy stems to develop a reporting scheme that minimizes the burden on reporters. In implementing the emissions verification unde r 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 additi on, 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. Sec ond, EPA intends to follow-up with facilities should potential errors, discrepancies, or questions arise thr ough 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 auditi ng that can meet the needs of multiple programs. We do not anticipate conducting on-site audi ts of every facility every year.

EPA decided to finalize the rule with EPA emis sions verification for several reasons. First, we determined that the combination of comprehensive el ectronic 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 le verage both the experience and ongoing activities of States and others already engaged in sim ilar 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-qual ity 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 en sure proper data collecti on 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 go vernment 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 an y 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 disadvant ages 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 th e “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 Reported 1

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 abbr eviated 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

# 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 st ationary fuel combustion units at a facility are combined together and discharged through a common stack or duct before exiting to the atmosphe re and if CEMS are used to continuously monitor CO 2 mass emissions at the common stack or duct according to the Tier 4 Calculation Methodology, you may report the
combined emissions from the units sh aring the common stack or duct, in lieu of separately reporting the GHG em issions from the individual units. This monitoring and reporting alternative may also be used when process off-gases or a mixture of combus tion products and process gases are combined together in a common st ack or duct before exiting to the atmosphere. An estimate of the heat i nput 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, ther ms 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, ther ms 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, ther ms 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, ther ms 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 th e 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 CO 2 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 durin g each month of the reporting year. C-2c

# 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 combus ted 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 combus ted 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 combus ted 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 combus ted 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 combus ted in the unit or group of units (as applicable) during each month of the reporting year (Fuel). C-8

# 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 combus ted 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 combus ted 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 emissi on 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 emissi on 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 emissi on 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

# 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)(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 conten t 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 CO 2 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 CO 2 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 CO 2 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

7 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 N 2 O 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 pe rformance 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 minu tes per cell-day. (AEM) F-2

F §98.66(c)(2) Anode effect over voltage 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 overvolta ge. 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

# 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(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 c oke (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 Soderber g cells (metric t on 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 (m etric 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

9 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-cal cined 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 CO 2 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 ra w 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 mate rial included for the calculation of annual process CO 2 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 mate rial included for the calculation of annual process CO 2 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 mate rial included for the calculation of annual process CO 2 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 mate rial included for the calculation of annual process CO 2 emissions (No CEMS): Mfluxj= Annual mass of flux material j fed, charged, or otherwis e introduced into th e EAF to facilitate slag formation (tons). K-1

K §98.116(e)(4) Annual material quantity for each mate rial included for the calculation of annual process CO 2 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 CO 2 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 CO 2 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 CO 2 emissions (No CEMS): Coreh= Carbon content in ore h (per cent 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 CO 2 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 CO 2 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 CO 2 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, e xpressed as one half of a 95 percent confidence interval). Note that where eSA = th e overall absolute error calculated for the process emissions you report under §98.126(a)(2), this
data element was not deferred in th e 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, e xpressed as one half of a 95 percent confidence interval). No te 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 th e 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, e xpressed as one half of a 95 percent confidence interval). Note that where eSA = th e overall absolute error calculated for the process emissions you report under §98.126(a)(2), this
data element was not deferred in th e 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, e xpressed as one half of a 95 percent confidence interval). Note that where ePA = th e overall absolute error calculated for the process emissions you report under §98.126(a)(2), this
data element was not deferred in th e 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, e xpressed as one half of a 95 percent confidence interval). Note that where ePR = th e overall relative error calculated for the process emissions you report under §98.126(a)(2), this
data element was not deferred in th e 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, e xpressed as one half of a 95 percent confidence interval). Note that where ePA = th e overall absolute error calculated for the process emissions you report under §98.126(a)(2), this
data element was not deferred in th e 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 equa tion 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-contai ning reactant that is fed into the process. (Rd) L-6

L §98.126(b)(7) The mass of each fluorine-cont aining 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 destruc tion device (metric tons). (Pj) L-7

L §98.126(b)(8)(ii) The mass of each fluorine-containing by-produc t that is removed from the process and fed into the destruc tion 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 destruc tion 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-produc t 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 efficien cy 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 activ ity 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 activ ity 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 activ ity 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 activ ity 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-ve nt-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-ve nt-specific emission calculation factor for each process vent. (ECFPV). L-25

L §98.126(c)(2) The site-specific, process-ve nt-specific emission calculation factor for each process vent (ECFPV). L-26

L §98.126(c)(2) The site-specific, process-ve nt-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. (RE D ) 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 (G 23 in Eq. O-4). O-4

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

O §98.156(a)(9) Annual mass of any HFC-23 sent off site for destruction (OD 23 used in Eq. O-4). O-4

O §98.156(a)(10) Mass of HFC-23 in storage at the beginni ng of the year (used to calculate
I 23 , 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 I 23 , which is used in Eq. O-4). O-4

O §98.156(b)(1) Annual mass of HFC-23 fed into the de struction 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 de struction 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 performa nce test that is the basis for the destruction efficiency (D E), 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 performa nce 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) Destruc tion 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 fo r each fuel and feedstock used in hydrogen production: Gaseous. P-1

P §98.156(b)(5) Monthly analyses of carbon content fo r each fuel and feedstock used in hydrogen production: Liquid. P-2

P §98.156(b)(5) Monthly analyses of carbon content fo r each fuel and feedstock used in hydrogen production: Solid. P-3

P §98.156(b)(6) Monthly analyses of the molecula r 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 pr oduced (No CEMS and not using the sitespecific EF method under §98.173(b)(2)). Q-2

Q §98.176(b) Annual quantity si nter 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 pr oduced (No CEMS and not using the sitespecific EF method under §98.173(b)(2)). Q-5

Q §98.176(b) Annual quantity raw steel pr oduced (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 CO 2 emissions (No CEMS) - solid fuel combusted (Csf). Q-1

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS) -gaseous fuel combusted(C gf ). Q-1

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- liquid fuel combusted (C lf ). 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 CO 2 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 CO 2 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 CO 2 emissions (No CEMS)- Iron (C iron ). Q-2

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Scrap (C scrap ). Q-2

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Flux (C flux ). Q-2

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Carbonaceous material (C carbon ). Q-2

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Steel produced (C steel ). Q-2

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Slag produced (C slag ). Q-2

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Air pollution control residue collected (C R ). Q-2

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Coal charged to coke battery (C coal ). Q-3

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Coke produced by coke battery (C coke ). Q-3

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Air pollution control resi due collected from coke battery (C R ). Q-3

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Gaseous fuel combusted in the sinter process (C gf ). Q-4

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS) - sinter feed (C Feed ). Q-4

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - sinter (C Sinter ). Q-4

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Air pollution control residue collected from sinter process (C R ). Q-4

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Iron (C iron ) used in EAF. Q-5

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Scrap (C scrap ) 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 CO 2 emissions (No CEMS)- Flux (C flux ) used in EAF. Q-5

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Carbonaceous material (C carbon ) used in EAF. Q-5

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Electrode consumed in EAF (C electrode ). Q-5

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Steel produced (C steel ) in EAF. Q-5

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Slag produced (C slag ) in EAF. Q-5

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Air pollution control residue collected (C R ) for EAF. Q-5

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS) - molten steel before decarburization (C steelout ) in EAF. Q-6

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - molten steel after decarburization (C steelout ) in EAF. Q-6

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Air pollution control residue collected (C R ) for EAF. Q-6

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS) - Gaseous fuel combusted in the direct reduction furnace (F g )

. Q-7

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS) - iron ore or iron ore pellets fed into the direct reduction furnace (C

ore ) . Q-7

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Carbonaceous material (C carbon ) used in the direct reduction
furnace . Q-7

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS) - Other materials charged to the direct reduction furnace (C other ). Q-7

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Iron produced from direct reduction furnace (C iron ). Q-7

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Non-metallic materials produced from direct reduction furnace (C NM ). Q-7

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Air pollution control residue collected (C R ) for direct
reduction furnace. Q-7

Q §98.176(e)(3) Annual volume of each type of gaseous fuel used to determine CO 2 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 CO 2 emissions (reported separately for ea ch 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 emissions (No CEMS) - Annual mass of air pollution control residue collected from battery (R). Q-3

# 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 . . .

Q §98.176(e)(3) Annual volume of each type of gaseous fuel used to determine CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 ch arged to the EAF(Carbon). Q-5

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to
determine CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 emissions (reported separately for each type in standard cubic feet) (No CEMS) - direct reduction furnaces (Fg). Q-7

# 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 . . .

Q §98.176(e)(3) Annual mass (in metric tons) of each other process input used to
determine CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 fuel s (No CEMS) - Taconite Indurating
Furnace. Q-1

Q §98.176(e)(4) Molecular weight of gaseous fuel s (No CEMS) - Sinter Process. Q-4

Q §98.176(e)(4) Molecular weight of gaseous fu els (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 CO 2 emissions (No CEMS). No Equation - Used as input in
calc. method
described in §98.173(b)(iv).

# 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 . . .

Q §98.176(f)(4) Annual production rate used to estimate annual CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 emissions (No CEMS) (Other = A nnual 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 factor s 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 compositi on 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 compositi on 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 compositi on 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 b yproduct/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/w aste 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 consumpti on by carbonate type. U-1

U §98.216(b) Annual carbonate input by carbonate type. U-2

U §98.216(e)(1) Annual carbonate consumpti on by carbonate type. U-1

U §98.216(e)(2) Annual calcination frac tions 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 N 2 O abatement technology is operating (tons, 100% acid basis). V-2

V §98.226(m)(1) Emission factor calculated fo r 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 fo r 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 pe rformance 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" ((F gf ) 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" ((P gf ) 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 feed stocks (used in Equation X-1). X-1

X §98.246(a)(4) Molecular weights for gaseous pr oducts (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" ((F lf )

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" ((P lp )

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" ((F lf )

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" ((P lp )

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" ((CC lf )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" ((F sf )

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" ((P sp )

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" ((CC lf )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 st ationary 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 mola r volume conversion factor for each
flare. Y-1b

Y §98.256(e)(7)(ii) If using Equation Y-1b: report th e carbon mole number of each carbon containing compound other than CO 2 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 heati ng 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 mo lar 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 th e 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 CH 4 emission factor. Used in method specified in §98.253(c)(4)

Y §98.256(f)(11) Activity data for calcul ating emissions (input). Used in method specified in §98.253(c)(4)

Y §98.256(f)(11) Activity data fo r calculating emissions (product). Used in method specified in §98.253(c)(4)

Y §98.256(f)(12) Activity data for calcul ating 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 calcula ting 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 N 2 O 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: Annua l 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 fo r 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 CH 4 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 CH 4 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 un it-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) CO 2 emission factor for each asphalt blowing unit. Y-14

Y §98.256(j)(6) CH 4 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 CO 2 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: CH 4 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: Cumu lative 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): CH 4 emission factor used. Y-20

Y §98.256(m)(3) 3 Uncontrolled blowdown systems re porting under §98.253 (k): Molar
volume conversion factor. Y-20

Y §98.256(m)(3) Uncontrolled blowdown systems re porting 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 uns tabilized crude oil: Quantity of unstabilized crude oil received during the calendar year. Y-23

Y §98.256(o)(4)(iii) For storage tanks that pro cess unstabilized crude oil: Average pressure
differential. Y-23

Y §98.256(o)(4)(iv) 3 For storage tanks that process uns tabilized crude oil: Molar volume
conversion factor. Y-23

Y §98.256(o)(4)(v) For storage tanks that process uns tabilized crude oil: Average Mole
fraction of CH 4 in vent gas from the unstabilized crude oil storage tanks. Y-23

Y §98.256(p)(2) For loading operations: Quantity of ma terials loaded by vessel type that have an equilibrium vapor- phase concentration of CH 4 of 0.5 volume percent or greater. Used in methodsspecified 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 deci mal fraction) (No CEMS). Z-1a

Z §98.266(f)(5) Monthly CO 2 (ton CO 2 /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 ro ck 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 CaCO 3 used for the reporting year used in Equation
AA-3. AA-3

AA §98.276(i) Make-up quantity of Na 2 CO 3 used for the reporting year used in Equation
AA-3. AA-3

BB §98.286(b)(1) Monthly consumption of pe troleum 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) CO 2 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 petr oleum 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 ma ss 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 d ecimal 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 d ecimal fraction) (No CEMS) - other
carbonaceous materials. GG-1

GG §98.296(b)(10) Carbon content of the carbon electrode s 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) fo r which disposal and production data are both
available. TT-2

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

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 fact or (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

‐ 09 29), 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; howev er, 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 tak e 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 U tilities 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 abbr eviated 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

# 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 . . .

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 mo re stationary fuel combustion units at a facility are combined together and discharged through a common stack or duct before exiting to the atmosphere a nd if CEMS are used to continuously
monitor CO 2 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 pro cess 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, ther ms 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, ther ms 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, ther ms 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, ther ms 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 th e 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 CO 2 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: Tota l quantity (i.e., pounds) of steam produced from
MSW or solid fuel combustion durin g 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 th e emission calculations (including both valid and substitute data values). For each calendar month of the reporting year in which carbon content and, if appli cable, molecular weight determination is required, report a value of each parameter. If multiple values of a parameter are obtained in a given mo nth, 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 th e emission calculations (including both valid and substitute data values). For each calendar month of the reporting year in which carbon content and, if appli cable, molecular weight determination is required, report a value of each parameter. If multiple values of a parameter are obtained in a given mo nth, 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 th e emission calculations (including both valid and substitute data values). For each calendar month of the reporting year in which carbon content and, if appli cable, molecular weight determination is required, report a value of each parameter. If multiple values of a parameter are obtained in a given mo nth, 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 aver age HHV, when measured HHV da ta, 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 CO 2 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 CO 2 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 CO 2 is determined according to §98.33(e)(2), re port the total quantity of fossil fuel combusted during the reporting year. C-13

E §98.56(g) Abatement technology destru ction efficiency for each abatement technology (DF). E-3a

E §98.56(g) Abatement technology destru ction efficiency for each abatement technology (DF). E-3c

E §98.56(g) Abatement technology destru ction efficiency for each abatement technology (DF). E-3b

E §98.56(h) Abatement utilization factor fo r 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) N 2 O concentration per test run during performance test for each unit (CN2O). E-1

E §98.56(j)(5) Volumetric flow rate per test r un 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 th at are sent to the abatement technology) if equation E-3c is used. (FC N ) E-3c

E §98.56h Abatement utilization factor fo r each abatement technology. (AF) E-3b

H §98.86(b)(11) Quarterly kiln-specific CKD CO 2 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 performa nce test that is the basis for the destruction efficiency (DE), report c oncentration (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 performa nce 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 performa nce 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 CO 2 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 utiliz ation factor (AF). V-3a

V §98.226(j) Abatement utiliz ation factor (AF). V-3b

V §98.226(j) Abatement utiliz ation factor (AF). V-3c

V §98.226(m)(4) N 2 O 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 t echnology (percent of total emissions from the production unit th at 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 usin g 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 §9 8.233(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

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

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

# 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 . . .

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

‐ ba sin 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 CH 4 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 CO 2 used in equation AA-1. AA-1

AA §98.276(e) Default or site specific emission factor for CH 4 used in equation AA-1. AA-1

AA §98.276(e) Default or site specific emission factor for N 2 O used in equation AA-1. AA-1

CC §98.296(b)(10)(i) Stack gas volumetric flow ra te during performance test (dscfm) for each manufacturing line or stack. CC-3

CC §98.296(b)(10)(ii) Hourly CO 2 concentration during perf ormance test (percent CO 2 ) for each manufacturing line or stack. CC-3

CC §98.296(b)(10)(iii) CO 2 emission factor of process vent flow from mine water for each manufacturing line or stack. CC-5

CC §98.296(b)(10)(iv) CO 2 emission mass emission rate dur ing 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) Annua l 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 destructi on (if using weekly sampling). II-4

II §98.356(d)(6) Weekly averag e 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 U tilities 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 rule making.

# 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 E**  **xamples 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.

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 7 of 128
**Category NAICS E**  **xamples 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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 8 of 128
**Category NAICS E**  **xamples 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.

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 9 of 128
**Category NAICS E**  **xamples 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

CO 2 

# carbon dioxide

CBI confidential business information

CEMS Continuous Emission Monitoring System

CFR Code of Federal Regulations

e-GGRT Electronic Greenhouse Gas Reporting Tool

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 10 of 128 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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 11 of 128 **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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 12 of 128 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:

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 13 of 128

 

# 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.

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 14 of 128 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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 15 of 128 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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 16 of 128 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).

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 17 of 128 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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** 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 athttp://www.epa.gov/ghgreporting/documents/pdf/2012/documents/2013-inputsmemo.pdf.

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 19 of 128 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
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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 20 of 128
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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 21 of 128 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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 22 of 128 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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 23 of 128 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.

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 24 of 128 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-

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 25 of 128 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 Grid 2 

# 26 1 

# 26 1



# E—Adipic Acid
Production 21 11

F—Aluminum Production 29 29

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 26 of 128

**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

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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 28 of 128 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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 29 of 128 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 N 2 

# O 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 CO 2 

# emission factor for the facility, averaged across all kilns (metric tons

CO 2 

# /metric ton clinker produced).

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 30 of 128 **Subpart Subpart Name New Data Element Description** Annual average cement kiln dust (CKD) CO 2 

# emission factor for the facility, averaged across all kilns (metric tons CO 2 

# /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 CO 2 

# 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 CO 2 

# 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 CO 2 

# 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.

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 31 of 128 **Subpart Subpart Name New Data Element Description**
If you use the carbon mass balance method in 40 CFR 98.173(b)(1) to
determine CO 2 

# 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 CO 2 

# 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 CO 2 

# 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 N 2 

# O 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.

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 32 of 128 **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 perMMscf) (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 CO 2 

# 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 CO 2 

# 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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 33 of 128 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”

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 34 of 128 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.

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 35 of 128 emission equations (the reporting of which was deferred). For

“supplier” subparts 5 

# (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.

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 36 of 128 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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 37 of 128 “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.

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 38 of 128 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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 39 of 128 “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 CO 2



# 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 CO 2 

# 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.

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 40 of 128

 

# Once the annual CO 2 

# 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.

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 41 of 128 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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 42 of 128 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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 43 of 128 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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 44 of 128 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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 45 of 128 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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 46 of 128 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.

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 47 of 128 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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 48 of 128 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 **r** eporting 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

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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 50 of 128 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

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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 52 of 128 “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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 53 of 128 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:

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 54 of 128

 

# 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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 55 of 128 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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 56 of 128 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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 57 of 128 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.

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 58 of 128 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).

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 59 of 128 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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 60 of 128 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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 61 of 128 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 D**  **ata 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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 62 of 128 **Subpart Proposed Citation D**  **ata 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 eachcarbon-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 (metrictons) 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 CO 2 

# 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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 63 of 128 **Subpart Proposed Citation D**  **ata 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 CO 2 

# 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 CO 2 

# 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 CO 2 

# emissions: The

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 64 of 128 **Subpart Proposed Citation D**  **ata 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 CO 2 

# 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 CO 2 

# 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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 65 of 128 **Subpart Proposed Citation D**  **ata 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 CO 2 

# 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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 66 of 128 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

N 2 

## O
emission
reduction

for all productio
n units
combined. Not CBI The annual facility percent N 2 

## O reduction

could not be used to calculate adipic acid production. The level

of N 2 

## O 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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 67 of 128

**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

CO 2 

## emission

factor

for the facility, averaged

across all kilns (metric

tons

CO 2 

## /metri

c ton
clinker produced)

. CBI T his 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) CO 2 

## emission

factor

for the facility, averaged

across all kilns (metric

tons

CO 2 

## /metri

c ton CKD produced)

. CBI T his data element could provide information

a bout the efficiency of the operation, which
would result in competitive disadvantage

**.**

V –
Nitric
Acid
Producti

on 40 CFR 98.226(q) Annual percent

N 2 

## O
emission
reduction

for all productio
n units Not CBI The annual facility percent N 2 

## O reduction


# for all nitric acid production trains
combined could not be

used to calculate the nitric acid production

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 68 of 128

**Subpart Citation Data** 
**Element Confidentia**  **lity**
**Determinati**

**on Proposed Rationale for**  **Confidentiality**
**Determination**

combined. value for any individual facility.

The level of N 2 

## O
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 N 2 

## O 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

c haracteristics, 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

t hus gain a competitive advantage. The EPA applied the same
rationale in the 2010

p roposed and 2011 final CBI rules (75 FR 39113
and 76 FR 30803 -

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 69 of 128

**Subpart Citation Data** 
**Element Confidentia**  **lity**
**Determinati**

**on Proposed Rationale for**  **Confidentiality**
**Determination**

3 0806), in support of a
non-CBI determination for reporting of the following same data element currently

r equired to be reported

i f 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

c haracteristics, 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

t hus gain a competitive advantage. The EPA applied the same
rationale in the 2010

p roposed and 2011 final CBI rules (75 FR 39113 76 FR 30803 - 30806), in support of a non- C BI
determination for reporting of the following same data element currently

r equired to be reported

i f a different equation (Equation Y-1a) is used: annual average

m olecular weight of the flare gas (kg/kg-mole)

under 40 CFR 98.256(e)(6).

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 70 of 128

**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

t hus gain a competitive advantage. The EPA applied the same
rationale in the 2010

p roposed and 2011 final CBI rules (75 FR 39113 76 FR 30803 - 30806), in support of a non- C BI
determination for reporting of the following same data element currently

r equired to be reported

i f a different equation (Equation Y-1a) is used: annual average

carbon content of the

f lare gas (kg carbon/kg

f lare 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

f raction 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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 71 of 128

**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

CO 2 

## 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 ND 1 

## 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

b etween 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.

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

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

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

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

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

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

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

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

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

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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 82 of 128 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

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

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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review ***
**Page** 85 of 128

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. D 

# ata

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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**Page** 87 of 128

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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**Page** 88 of 128

§ 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) S**  **pecific data elements for which reporting date is March 31, 2015**  **(“All” means all data elements in**

**t he 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) O nly 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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**Page** 89 of 128

**Subpart Rule citation**  **(40 CFR part 98) S**  **pecific data elements for which reporting date is March 31, 2015**  **(“All” means all data elements in**

**t he 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.

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review ***
**Page** 90 of 128

**Subpart Rule citation**  **(40 CFR part 98) S**  **pecific data elements for which reporting date is March 31, 2015**  **(“All” means all data elements in**

**t he 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.

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review ***
**Page** 91 of 128

**Subpart Rule citation**  **(40 CFR part 98) S**  **pecific data elements for which reporting date is March 31, 2015**  **(“All” means all data elements in**

**t he 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.

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review ***
**Page** 92 of 128

**Subpart Rule citation**  **(40 CFR part 98) S**  **pecific data elements for which reporting date is March 31, 2015**  **(“All” means all data elements in**

**t he 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.

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review ***
**Page** 93 of 128

**Subpart Rule citation**  **(40 CFR part 98) S**  **pecific data elements for which reporting date is March 31, 2015**  **(“All” means all data elements in**

**t he 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) O nly weekly average moisture content

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review ***
**Page** 94 of 128

**Subpart Rule citation**  **(40 CFR part 98) S**  **pecific data elements for which reporting date is March 31, 2015**  **(“All” means all data elements in**

**t he 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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**Page** 95 of 128

Subpart X X-1, X-2, X-3, C-8Subpart 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-1bSubpart 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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**Page** 96 of 128

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 CH 4 

# and N 2 

# O 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 CO 2 

# e.

(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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**Page** 97 of 128

* * * * *

(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 CH 4 

# and N 2 

# O mass emissions from the units sharing the

common stack or duct, expressed in metric tons of each gas and

in metric tons of CO 2 

# 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

# *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review ***
**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 CO 2 

# 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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**Page** 99 of 128

(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 CO 2 

# 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 CO 2 

# 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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**Page** 100 of 128

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 CH 4 

# and N 2 

# O 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 CO 2 

# 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 CO 2e 

# 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 N 2 

# O 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 CO 2 

# emission factor for the

facility, averaged across all kilns (metric tons CO 2 

# /metric ton

clinker produced).

(18) Annual average CKD CO 2 

# emission factor for the

facility, averaged across all kilns (metric tons CO 2 

# /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 CO 2 

# 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 CO 2 

# 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 CO 2



# 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	൅ ܨ ௦,௜ 

# 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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F g,i 

# = Annual volume of gaseous fuel combusted (“(F g 

# )” in Equations Q-1, Q-4 and Q-7 of this section) for each process (scf).

MW i 

# = 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.

F l,i 

# = Annual volume of the liquid fuel combusted (“(F l 

# )” included in Equation Q-1 of this section) for each process unit (gallons).

F s,i 

# = Annual mass of the solid fuel combusted (“(F s 

# )” in Equation Q-1 of this section) for each process unit (metric tons).

ρ l,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).

Steel in 

# = 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.

ൌ ݏݐܿݑ݀݋ݎܲ ∑ሺ ݈݁݁ݐܵ ൅ ܴ ൅ ܲ ௨௧௢ 

# ܯܰ ൅ ݊݋ݎܫ ൅ ݎ݁ݐܵ݅݊ ൅ ݇݁݋ܥ ൅ ݈ܵܽ݃ ൅ ௡ ୀଵ௜ 

# ሻ ሺ (-11Q .Eq

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).

Steel out 

# = 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:

CF avg 

# = 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.

C gf,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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C lf,i 

# = Carbon content of the liquid fuel used in each process, from the fuel analysis results (kg C per gallon of fuel.

C sf 

# = 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:

CI avg 

# = 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.

NFI i 

# = Annual mass of each non-fuel input used in Equation Q-10 (metric tons).

C NFIi 

# = 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:

CP avg 

# = 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.

Product i 

# = Annual mass of each product or byproduct used in Equation Q-11 (metric tons).

C p,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 CO 2 

# emissions using Equation R–1 of this subpart for each

smelting furnace (e.g. , supplier provided information, analyses

of representative samples you collected).

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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 CO 2 

# 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 N 2 

# O 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 CO 2 

# concentration (volume or mole percent), the number of

carbon containing compounds other than CO 2 

# in the flare gas

stream, and for each of the carbon containing compounds other

than CO 2 

# 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, %CO 2 

# , 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 CH 4



# emissions. If you use a unit-specific emission factor for CH 4 

# ,

report the basis for the factor.

(12) Indicate whether you use a measured value, a unitspecific emission factor, or a default emission factor for N 2 

# O

emissions. If you use a unit-specific emission factor for N 2 

# O,

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 CO 2



# 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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**Page** 123 of 128

(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 CH 4 

# emissions. If you

use a unit-specific emission factor for CH 4 

# , report the basis for

the factor.

(8) Indicate whether you use a measured value, a unitspecific emission factor, or a default emission factor for N 2 

# O

emissions. If you use a unit-specific emission factor for N 2 

# O,

report the basis for the factor.

(j) * * *

(5) If you use Equation Y–14 of this subpart, the basis for

the CO 2 

# emission factor used.

(6) If you use Equation Y–15 of this subpart, the basis for

the CH 4 

# 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 CO 2 

# emission factor used and the basis for the carbon

emission factor used.

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**Page** 124 of 128

(9) If you use Equation Y–17 of this subpart, the basis for

the CH 4 

# 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 CF 4 

# /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** 125 of 128

(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.

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

**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 CO 2 

# 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.

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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.

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**Page** 128 of 128

* * * * *

(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 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 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

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

### *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 4 of 133

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 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

### *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 6 of 133 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.

### *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 7 of 133
**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

### *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 8 of 133
**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.

### *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 9 of 133
**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

CO 2 

### carbon dioxide

CBI confidential business information

CEMS Continuous Emission Monitoring System

CFR Code of Federal Regulations

e-GGRT Electronic Greenhouse Gas Reporting Tool

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

Page 10 of 133 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

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

Page 11 of 133 **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.

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

Page 12 of 133 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.

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

Page 13 of 133

 

### Adding a requirement for certain reporters under 24 certain subparts to use an EPA-provided inputs verification tool. For these subparts, T t he 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 require d 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

the se 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.

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

Page 14 of 133 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.

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

Page 15 of 133 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

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

Page 16 of 133 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).

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

Page 17 of 133 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.

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

Page 18 of 133 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, wW e also evaluated all data elements for which reporting wai s 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 athttp://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.

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

Page 19 of 133 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 amendments would 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
Grid 2 

### Grid 3 

### 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.

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

Page 20 of 133
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

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

Page 21 of 133
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

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

Page 22 of 133 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.

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

Page 23 of 133 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, R r eporters

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

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

Page 24 of 133 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

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

Page 25 of 133 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 t**  **o Be Reported** C—General Stationary
Fuel Combustion Except Certain
Combustion Units
Connected to Devices

Connected to the 26 1 

### 26 1

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

Page 26 of 133

**Subpart Number of “Inputs to**  **Equations” Data**

**Elements Number of “Inputs**  **to Equations” Data Elements Proposed**  **Not to Be Reported** Local or Regional
Power Grid 2


### 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

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

Page 27 of 133

**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 the se “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.

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

Page 28 of 133facilities 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

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

Page 29 of 133 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 N 2 

### O emission reduction for all production units
combined.

G Ammonia Annual ammonia production (metric

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

Page 30 of 133 **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 CO 2 

### emission factor for the facility, averaged across all kilns (metric tons

CO 2 

### /metric ton clinker produced). Annual average cement kiln dust (CKD) CO 2 

### emission factor for the facility, averaged across all kilns (metric tons CO 2 

### /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 CO 2 

### 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 CO 2 

### 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.

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

Page 31 of 133 **Subpart Subpart Name New Data Element Description** If you use the carbon mass balance method in 40 CFR 98.173(b)(1) to
determine CO 2 

### 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 CO 2 

### 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 CO 2 

### 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 CO 2 

### 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 N 2 

### O emission reduction for all production units
combined.

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

Page 32 of 133 **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 perMMscf) (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 CO 2 

### 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 CO 2 

### emissions: Ratio of the unit’s maximum rated heat input capacity to its design rated steam output

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

Page 33 of 133 **Subpart Subpart Name New Data Element Description** capacity (mmBtu/lb steam), individually for each fossil fuel type and for spent li q uor 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-

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

Page 34 of 133 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 sS ources 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 requirement s be removed.

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

Page 35 of 133 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” subparts 5 

### (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.

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

Page 36 of 133 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.

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

Page 37 of 133 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

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

Page 38 of 133 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.

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

Page 39 of 133 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 CO 2



### 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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Page 40 of 133

 

### 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 CO 2 

### 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 CO 2 

### 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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Page 41 of 133

 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.

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

Page 42 of 133 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

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

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

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

Page 44 of 133 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

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

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]: P lease explain why the
record retention time needs to be lengthened.

EPA: Revised to refer readers to section of preamble with rationale
is described.

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

Page 46 of 133
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 W w e are proposing to remove the reporting requirement for certain “inputs to
equat ions” 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.

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

Page 47 of 133 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

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

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 **r** eporting 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. The se 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 a nd 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 subpar t Y

. Refer to were proposed in the the EPA’s April 2, 2013 rulemaking (78 FR 19802) for EPA’s proposal that these five inputsto be removed from reporting. Comment [A9]: P lease 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.

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

Page 49 of 133 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.

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

Page 50 of 133 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

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

Page 51 of 133 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

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

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

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

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

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

Page 54 of 133 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

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

Page 55 of 133 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, tT he 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 ny 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.

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

Page 56 of 133 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

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

Page 57 of 133 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).

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

Page 58 of 133 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

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

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).

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

Page 60 of 133 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

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

Page 61 of 133
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 D**  **ata 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

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

Page 62 of 133 **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 eachcarbon-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 (metrictons) of each carboncontaining fuel and

feedstock.

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

Page 63 of 133 **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 CO 2 

### 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 CO 2 

### 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 CO 2

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

Page 64 of 133 **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 CO 2 

### 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 CO 2 

### 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.

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

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 CO 2 

### 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 CO 2 

### emissions: 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 During Review ***

Page 66 of 133

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).

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

Page 67 of 133 **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

N 2 

### O
emission
reduction

for all productio
n units
combined. Not CBI The annual facility percent N 2 

### O reduction

could not be used to calculate adipic acid production. The level

of N 2 

### O 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

CO 2 

### emission

factor

for the facility, averaged

across all kilns (metric

tons

CO 2 

### /metri

c ton
clinker produced)

. CBI T his 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 T his data element could provide information

a bout the efficiency of

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

Page 68 of 133

**Subpart Citation Data** 
**Element Confidentia**  **lity**
**Determinati**

**on Proposed Rationale for**  **Confidentiality**
**Determination**

kiln dust (CKD) CO 2 

### emission

factor

for the facility, averaged

across all kilns (metric

tons

CO 2 

### /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

N 2 

### O
emission
reduction

for all productio
n units
combined. Not CBI The annual facility percent N 2 

### O 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 N 2 

### O
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 N 2 

### O emission
reduction information is already publicly available (see docket number EPA-HQ-OAR-2010-
0750 and http://www.climateactio

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

Page 69 of 133

**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

c haracteristics, 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

t hus gain a competitive advantage. The EPA applied the same
rationale in the 2010

p roposed and 2011 final CBI rules (75 FR 39113
and 76 FR 30803 -
3 0806), in support of a
non-CBI determination for reporting of the following same data element currently

r equired to be reported

i f 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

c haracteristics, actual production data, or operating efficiency. It does not provide
information that would

a llow competitors to

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

Page 70 of 133

**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

t hus gain a competitive advantage. The EPA applied the same
rationale in the 2010

p roposed and 2011 final CBI rules (75 FR 39113 76 FR 30803 - 30806), in support of a non- C BI
determination for reporting of the following same data element currently

r equired to be reported

i f a different equation (Equation Y-1a) is used: annual average

m olecular 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

c haracteristics, 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

t hus gain a competitive advantage. The EPA applied the same
rationale in the 2010

p roposed and 2011 final CBI rules (75 FR 39113 76 FR 30803 - 30806), in support of a non- C BI
determination for reporting of the

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

Page 71 of 133

**Subpart Citation Data** 
**Element Confidentia**  **lity**
**Determinati**

**on Proposed Rationale for**  **Confidentiality**
**Determination** following same data element currently

r equired to be reported

i f a different equation (Equation Y-1a) is used: annual average

carbon content of the

f lare gas (kg carbon/kg

f lare 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

f raction 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

CO 2 

### emissions

: Ratio of

the
unit’s ND 1 

### 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

b etween facilities. For all reported data

elements related to production capacity,
the EPA will make caseby-case determinations per reporter, in

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

Page 72 of 133

**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.

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

Page 73 of 133 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

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

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.

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

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

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

Page 76 of 133 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

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

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

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

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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Page 79 of 133 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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Page 81 of 133 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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Page 82 of 133 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.

### *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** **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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**Page** 85 of 133

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. D 

### ata

elements specified in Table A-7 to this subpart for calendar

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**Page** 86 of 133

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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**Page** 87 of 133

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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**Page** 88 of 133

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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**Page** 89 of 133

**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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**Page** 90 of 133

**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 CO 2 

### e missions using
the site

- specific emission factor
method in § 98.173(b)(2) based on the total quantity of raw material feed (metric tons of CO 2 

### 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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**Page** 91 of 133

**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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**Page** 92 of 133

**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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**Page** 93 of 133

**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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**Page** 94 of 133

**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 CH 4 

### and N 2 

### O 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 CO 2 

### e.

(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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**Page** 98 of 133

annual CH 4 

### and N 2 

### O mass emissions from the units sharing the

common stack or duct, expressed in metric tons of each gas and

in metric tons of CO 2 

### e.

(x) For each configuration stationary 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 u nits 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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**Page** 99 of 133

Commission to deliver power to the local or regional power grid

(e.g., electricity generators exclud ing 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

region al 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 ele ctric
, 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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**Page** 100 of 133

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 th e

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 su ch devices at the facility is greater than or equal to 1

megawatt electric
, report the high heat values used in the CO 2



### 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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**Page** 101 of 133

Pub lic 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 de vices at the facility is greater than or equal to 1

megawatt electric , if Equation C–2c of this subpart is used to

calculate CO 2 

### 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 CO 2 

### 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 dev ice 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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**Page** 102 of 133

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 gran ted 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 cap acity 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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**Page** 103 of 133

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 CH 4 

### and N 2 

### O 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 generator s 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 CO 2 

### 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 name plate 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

reg ional 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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**Page** 105 of 133

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 CO 2e 

### 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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**Page** 106 of 133

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 N 2 

### O 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 paragraph s (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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**Page** 107 of 133

(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 CO 2 

### emission factor for the

facility, averaged across all kilns (metric tons CO 2 

### /metric ton

clinker produced).

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**Page** 109 of 133

(18) Annual average CKD CO 2 

### emission factor for the

facility, averaged across all kilns (metric tons CO 2 

### /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 CO 2 

### 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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**Page** 112 of 133

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 paragraph s (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 textpar agraph

.

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 CO 2 

### emissions or if you

determined CO 2 

### 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 CO 2 

### per metric ton of raw material

feed), then you must repor t 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 CO 2 

### 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 CO 2



### 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	 ൅ ܨ ௦,௜ 

### 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.

F g,i 

### = Annual volume of gaseous fuel combusted (“(F g 

### )” in Equations Q-1, Q-4 and Q-7 of this section) for each process (scf).

MW i 

### = 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.

F l,i 

### = Annual volume of the liquid fuel combusted (“(F l 

### )” included in Equation Q-1 of this section) for each process unit (gallons).

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F s,i 

### = Annual mass of the solid fuel combusted (“(F s 

### )” in Equation Q-1 of this section) for each process unit (metric tons).

ρ l,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.

ൌ ܫܨܰ ෍൭ ݈݁݁ݐܵ ൅ ݀݁݋ݎݐ݈݁ܿܧ ൅ ݁݁݀ܨ ൅ ݈ܽ݋ܥ ൅ ݊݋ܾݎܽܥ ൅ ݔݑ݈ܨ ൅ ݌ܽݎܵܿ ൅ ݊݋ݎܫ ൅ ܱ ௡௜ ௡

௜ୀଵ ݎ݄݁ݐܱ ൅ ݁ݎܱ ൅ ൱



### (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).

Steel in 

### = 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.

ൌ ݏݐܿݑ݀݋ݎܲ ∑ሺ ݈݁݁ݐܵ ൅ ܴ ൅ ܲ ௨௧௢ 

### ܯܰ ൅ ݊݋ݎܫ ൅ ݎ݁ݐܵ݅݊ ൅ ݇݁݋ܥ ൅ ݈ܵܽ݃ ൅ ௡ ୀଵ௜ 

### ሻ ሺ (-11Q .Eq

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).

Steel out 

### = 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:

CF avg 

### = 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.

C gf,i 

### = Average carbon content of the gaseous fuel used in each process, from the fuel analysis results (kg C per kg of fuel).

C lf,i 

### = Carbon content of the liquid fuel used in each process, from the fuel analysis results (kg C per gallon of fuel.

C sf 

### = 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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**Page** 119 of 133

of this section, calculated as specified in Equation Q-13 of

this section.

ܫܥ ௔௩௚ 

### ൌ ൫ ∑ ேிூ ೔ ∗஼ ಿಷ಺೔ ೙ ೔సభ ൯

ேிூ 

### (Eq. Q-13)

Where:

CI avg 

### = 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.

NFI i 

### = Annual mass of each non-fuel input used in Equation Q-10 (metric tons).

C NFIi 

### = 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:

CP avg 

### = 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.

Product i 

### = Annual mass of each product or byproduct used in Equation Q-11 (metric tons).

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**Page** 120 of 133

C p,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 CO 2 

### 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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**Page** 121 of 133

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 CO 2 

### 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 N 2 

### O 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

paragraph s (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 CO 2 

### concentration (volume or mole percent), the number of

carbon containing compounds other than CO 2 

### in the flare gas

stream, and for each of the carbon containing compounds other

than CO 2 

### 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, %CO 2 

### , 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 CH 4



### emissions. If you use a unit-specific emission factor for CH 4 

### ,

report the basis for the factor.

(12) Indicate whether you use a measured value, a unitspecific emission factor, or a default emission factor for N 2 

### O

emissions. If you use a unit-specific emission factor for N 2 

### O,

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 CO 2



### 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 CH 4 

### emissions. If you

use a unit-specific emission factor for CH 4 

### , report the basis for

the factor.

(8) Indicate whether you use a measured value, a unitspecific emission factor, or a default emission factor for N 2 

### O

emissions. If you use a unit-specific emission factor for N 2 

### O,

report the basis for the factor.

(j) * * *

(5) If you use Equation Y–14 of this subpart, the basis for

the CO 2 

### emission factor used.

(6) If you use Equation Y–15 of this subpart, the basis for

the CH 4 

### 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 CO 2 

### 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 CH 4 

### 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 CF 4 

### /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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**Page** 131 of 133

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 CO 2 

### emissions, report the information specified

in paragraphs (m)(1) and (2) of this section.

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**Page** 132 of 133

(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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**Page** 133 of 133

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

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



# 6560.50

ENVIRONMENTAL PRO TECTION 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 pot ential release of certain data that are inputs to emission

equations whose reporting deadline was defe rred 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 96

FEDERAL REGISTER ] to request a public hearing. If a hearing is requested, the EPA will

announce the details, including specif ic 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 Read ing Room, EPA West Building, Room 3334, 1301 Constitution Avenue, NW., Washingt on, 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 onlin e at http://www.regulations.gov , including any personal

information provided, unless the comment include s information claimed to be confidential

business information (CBI) or other information whose disclosure is re stricted by statute.

Do not submit information that you consider to be CBI or otherw ise protected through

http://www.regulations.gov or email. Send or deliver inform ation identified as CBI to only the

mail or hand/courier delivery address listed a bove, 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 co ntact 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 automa tically captured and included as

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

# Page 3 of 96

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 recomme nds that you include your name and other

contact information in the body of your comment a nd with any disk or CD–ROM you submit. If

the EPA cannot read your comment due to tec hnical difficulties and cannot contact you for

clarification, the EPA may not be able to cons ider your comment. Electr onic 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 li sted in the http://www.regulations.gov index.

Although listed in the index, some information is not publicly availabl e, e.g., CBI or other

information whose disclosure is re stricted by statute. Certain othe r material, such as copyrighted

material, will be publicly available only in ha rd 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 Constituti on 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 Read ing 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 (M C–6207J), Environmental Protection Agency,

1200 Pennsylvania Ave., NW., Washington, DC 20460; telephone number: (202) 343–9263; fax

number: (202) 343–2342; email address: GHGre porting@epa.gov. For technical information,

contact the Greenhouse Gas Re porting Rule Helpline at:

http://www.epa.gov/climatechange /emissions/ghgrule_contactus.htm . Alternatively, contact

Carole Cook at 202–343–9263.

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# Page 4 of 96

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 greenho use 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 se parate copy of your comments, in addition to

the copy you submit to the official docket, to Ca role 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 woul d affect entities that must submit annual

greenhouse gas (GHG) reports under the Greenhous e 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 C AA section 307(d)(1)(V) (the pr ovisions of CAA section 307(d)

apply to “such other actions as the Administra tor 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 boi lers, process heaters, incinerators, turbines, and in ternal combus tion engines. 321 Manufacturers of lumber and wood products. 322 Pulp and paper mills.
325 Chemical manufacturers.

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# Page 5 of 96

Category NAICS Examples of affected facilities
324 Petroleum refineries an d manufacturers of coal products. 316, 326,
339 Manufacturers of rubber a nd 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 manuf acturing 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 manufactur ing facilities. Aluminum Production 331312 Primary al uminum production facilities
Ammonia Manufacturing 325311 Anhydrous and aqueous amm onia production facilities.

Cement Production 327310 Portland Ce ment manufacturing plants. Ferroalloy Production 331112 Ferroall oys manufacturing facilities.
Fluorinated GHG
Production 325120 Industrial gases manufacturing facilities.

Glass Production 327211 Flat gla ss 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 Hydr ogen production facilities
Iron and Steel
Production 331111 Integrated iron and steel m ills, 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 Nitr ic 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 transportati on of natural gas. 221210 Natural gas distribution facilities. 211 Extractors of crude petroleum and natural gas. 211112 Natural gas liquid ex traction 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 zi nc refining facilities. 331492 Zinc dust reclaiming facilities, recovering from scrap and/or alloying purchased metals. 311411 Frozen fruit, juice a nd vegetable manufacturing
facilities. 311421 Fruit and vegetable canning facilities.

Wastewater Treatment 1 

# 322110 Pulp mills. 322121 Paper mills. 322122 Newsprint mills. 322130 Paperboard mills. 311611 Meat processing facilities. 311411 Frozen fruit, juice a nd vegetable manufacturing
facilities. 311421 Fruit and vegetable canning facilities. 325193 Ethanol manufacturing facilities.

1 

## The EPA is not proposing amendments related to these ca tegories; however, these categories were evaluated in the EPA’s analysis of the potential impact from the releas e 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 s uppliers 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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# Page 7 of 96

CFR part 98, subpart A or the rele vant 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 IN FORMATION CONTACT section.

Many facilities that are affected by 40 CF R part 98 have GHG emissions from multiple

source categories listed in Table 1 of this preamble.

Acronyms and Abbreviations

. The following acronyms and abbr eviations are used in this

document.

BAMM Best Available Monitoring Methods

CAA Clean Air Act

CO 2 

# 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

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UMRA Unfunded Mandates Reform Act

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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 Verificat ion Tool and Amendment to Reporting Requirements B. Proposed Revisions to Recordkeeping Requirements C. Proposed Requirement to Report Additional Data

IV. Confidentiality Determination for Prop osed New Data Elemen ts 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 Planni ng and Review and Executive Order 13563: Improving Regulation a nd 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 Coor dination 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 En ergy 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 em ission factors. Reporte rs not using direct

measurement must use equations to calculate em issions. The inputs to these emission equations

often include process or producti on data that are specific to ea ch 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 e quations” are emission da ta. The CAA precludes

“emission data” from being tr eated as confidential.

Based on subsequent industry concerns regard ing the potential release of data elements

categorized as “inputs to emission equations,” th e EPA deferred reporting of these data elements

(see August 25, 2011 final action, 76 FR 53057) to a llow 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 record keeping requirements

and an alternative verification a pproach for certain repor ters subject to 24 subparts for which the

reporting deadline for inputs to emission equa tions 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 th ese subparts, the designated inputs to emission equations for which reporting was deferred to 2015 and di sclosure 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 verificat ion 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 unde r sections 98.33(a)(5), 98.53(a)(2), and 98.223(a)(2) of Part 98) to calculate the reported GHG value, rath er than using "inputs to equations" data elements and the associated EPA-provided calculation methodolo gies to calculate the reported GHG value.

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electronic verification. The tool would not retain the entered i nputs (i.e., the inputs would not be reported to EPA); instead, the tool would conduct certain chec ks (e.g., accuracy of the inputs) at the time of data entry and generate a verifi cation summary. The verification summary, which would be accessible to the EPA once the annual report is submitted, would provide the EPA with informati on to conduct furt her verification if necessary.

 

# For reporters required to use th e inputs verification tool, chan ging the required format for maintaining records of these inputs to emission equations.

 

# For reporters required to use th e inputs verification tool, le ngthening the record retention period from 3 to 5 years for all records main tained 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 EP A’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 emissi on 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) ar e not proposed to be amended in this action. For

these inputs to equations, the de ferral 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 verificati on during the first 3 years of the GHGRP. By requiring the use

of the inputs verification tool, which would calculate GHG emissi ons 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 a dditional verification checks of the inputs to

emission equations that the i nputs verification tool would conduct (during th e process of

reporters entering data into the inputs verification tool ), would provide the EPA with information

necessary to conduct further verification once th e annual report is submitted. This alternative

verification approach, including the changes to the recordkeeping requirements and additional

reporting requirements, would provide an alterna tive 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 th e 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 EP A requires annual reporting of da ta from certain facilities and

suppliers above specified emission or quantity supplied thresholds. On July 7, 2010 (75 FR

39094) and subsequent proposal s (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) maki ng confidentiality determinations either categorically or on an

individual data elements basis. Refer to bot h 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 fo r a discussion of individual data element

confidentiality determinations. We have finaliz ed 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 ent itled to confidential treatment under section

2 

### There are a small number of data elements (besides data elements cat egorized as “inputs to emissi on 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 individu al circumstances of the facility).

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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 a ssigned to the “inputs to emission equations”

category are not entitled to confidential treat ment, we received numerous industry comments

asserting that competitive harm would result from public release of many of these data elements.

We determined that “these conc erns warranted an in-depth ev aluation 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 in formation (75 FR 81354) requesting additional

information to assist us in conducting our evalua tion. 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 specif ied 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 accompanyi ng 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 el ement assigned to the “inputs to emission equations” category is alr eady publicly available.

 

# Step 2: For data elements assigned to the “i nputs to emission equatio ns” category that are not publicly available, evaluate whether disclosure of the inform ation is likely to result in substantial competitive harm.

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 

# Step 3: For data elements assigned to the “i nputs to emission equatio ns” category that are likely to cause substantial competitive harm if disclosed, evaluate potential alternative
calculation methods.

 Step 4: For data elements assigned to the “i nputs to emission equatio ns” 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 I nputs to Emission Equations for which Reporting was Deferred to March 31, 2015.”

 

# “Evaluation of Competitive Harm from Di sclosure of “Inputs to Equations” Data Elements Deferred to March 31, 2015

 

# “Evaluation of Alternativ e Calculation Methods.”

 “Evaluation of Alternative Verification A pproaches 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 lis ted in Table 2 of this preamble. Table 2

includes most of the subparts with inputs to emission equations for whic h the reporting deadline

was deferred until 2015. Subpart W (Petroleum and Natural Gas Systems), Subpart II (Industrial

Wastewater Treatment), and subpa rt C (only certain combustion un its associated with certain

electric generators connected and able to deli ver 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 ac tion. 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 ca tegories 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 th is table, the proposed

revision to the recordkeeping dur ation would apply to the reco rds 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—Mis cellaneous Uses of Carbonate

F—Aluminum Production V—Nitric Acid Production
G—Ammonia Manufacturing X—Petrochemical Production

H—Cement Production Y—Pe troleum 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—Tita nium Dioxide Production
Q—Iron and Steel Produc tion GG—Zinc Production

R—Lead Production TT—Industrial Waste Landfills

1 

## Certain proposed amendments affect other subparts not liste d 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-ap proved 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 met hodologies 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 meeti ng 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 Pub lic Utilities Commissio n 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 preambl e to the 2009 final GHG reporting rule (74 FR

56260, October 30, 2009), CAA section 114(a)(1) provi des 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 vari ety 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, a nd 307 of the CAA, the EPA is proposing

confidentiality determinations fo r the new data elements proposed in this notice. Section 114(c)

of the CAA requires that the EPA make publicly available in formation obtained under CAA

section 114 except for information (excluding em ission data) that quali fies for confidential

treatment. The Administrator has determined that this action (Part 98 amendment and

confidentiality determinati ons) is subject to the provi sions of CAA section 307(d).

II. Summary of Proposed Changes to Part 98 Reporting and Recordkeeping Requirements

The EPA is proposing revisions to the reporti ng and recordkeeping requirements in Part

98 and alternative verification procedures that woul d apply to certain report ers subject to any of

the 24 subparts listed in Table 2 of this preambl e. Section II.A of this preamble summarizes a

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proposed new requirement for these reporters if th ey 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 re quired to use an EPA-provided

electronic inputs verification tool to calculate emissions using da ta 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 verifi cation of reported GHG emissions data without

the need to collect “inputs to equations” data el ements for which disclosure concerns have been

identified. Section II.B of this preamble summar izes 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 summar izes proposed new repor ting requirements for

these reporters. Section III of this preamble expl ains the rationale for the proposed amendments

summarized in Sections II.A through II.D. Sec tion 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 pream ble 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 c onducted. 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 re port, reporters w ould also enter

into e-GGRT (via the inputs veri fication tool) the “inputs to equa tions” 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 calcu late the equation output s, 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 require ment be removed. Accordingly, the EPA would

not have access to these “inputs to equations” data elements. In stead, the EPA would rely on the

verification summary, which would become acce ssible to the EPA when annual reports are

submitted, as a first step for conducting veri fication 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 s ubparts listed in Table 2 of this preamble. The EPA is proposing

that reporters use this tool starting with repor ting year 2014. Refer to Section III.A of this

preamble for further discussion of this proposed requirement.

This proposed requirement to use the inputs ve rification tool is sp ecified 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 a ll calculation methods unde r Part 98 for which

the inputs verification tool must be use d. Reporters calculating reported GHGs using a

calculation method specified in pr oposed Table A-8 would be requi red 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 reporti ng 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 “L ist of ‘Inputs to Equa tions’ 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 equati ons” data elements not represented in Table 3

of this preamble, the EPA is not amending thes e reporting requirements a nd 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 Report ing 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 26 1 

# 26 1

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Subpart Number of “Inputs to Equations” Data Elements Number of “Inputs to Equations” Data Elements Proposed Not to Be Reported
Grid 2



# 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 report ers 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-f ired 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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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 faciliti es, the EPA is proposin g that the “inputs to

equations” data elements that are not being am ended in this action (a nd 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 repor ters prepare their re porting year 2014 annual

report via e-GGRT, they would be required to in clude these “inputs to equations” data elements

for reporting year 2014 as well as for all applicable previous repor ting years. The annual report,

including these “inputs to equations” data elem ents that would still be reported, would be

submitted via e-GGRT. This proposed approach woul d prevent facilities from being required to

revise, re-certify, and re-submit annual repo rts for each previous reporting year.

C. Proposed Changes to Recordkeeping Requirements

For each facility subject to a s ubpart listed in Table 2 of this preamble that uses “inputs to

equations” data elements to calculate and repor t GHGs (i.e., subject to using the proposed inputs

verification tool), the EPA is propos ing that the facility retain a ll records, includ ing records for

subparts not subject to the input s verification tool requirement, for 5 years, rather than the

current 3-year record retention period. In othe r 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 subp arts also be maintained for the 5 years. For

example, if such a facility is required to report under both subp art C (in Table 2) and subpart HH

(not in Table 2), the facility would be require d 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 begi n with records for reporting year 2010.

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Additionally, we are proposing that, at the time a reporter su bject 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 en tered “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 require d 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 report ers subject to using the prop osed 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 pres ented 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 N 2 

# O emission reduction for all production units combined.

G Ammonia Production Annual amm onia production (metric tons).
Annual methanol production (metric tons), if this quantity is not reported under subpart X of Part 98.

H Cement Production Annual clin ker production (metric tons).
Annual average clinker CO 2 

# emission factor for the facility, averaged across all kilns (metric tons
CO 2 

# /metric ton clinker produced).
Annual average cement kiln dust (CKD) CO 2

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Subpart Subpart Name New Data Element Description

emission factor for the faci lity, averaged across all kilns (metric tons CO 2 

# /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 th e carbon mass balance method in 40 CFR 98.173(b)(1) to determine CO 2 

# 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 CO 2 

# emissions: The annual mass (metric tons) of all non-fuel material inputs (combined) specified in E quations 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 CO 2 

# 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, calcu lated 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 CO 2 

# 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 CO 2 

# emissions: The weighted average carbon c ontent 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 CO 2 

# 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 N 2 

# O 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 k iln: 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 fo r which you are not using Equation C-2c to calculate CO 2 

# 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 fo r which you are not using Equation C-2c to calculate CO 2 

# emissions: Ratio of the unit’s maximum rated heat input capacity to its design rated steam output cap acity (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 th is 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 a ddress those disclosure concerns, the EPA is

proposing an alternative verification approac h. This approach involves use of an inputs

verification tool and revisions to the reporting and recordkeepi ng 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 verifi cation tool and revisions to th e requirement to report certain

“inputs to equations” data elements. Secti on III.B addresses the proposed revisions to

recordkeeping requirements. Section III.C addresses the proposed addition of new reporting

requirements.

A. Proposed Inputs Verificat ion Tool and Amendment to Reporting Requirements

The EPA is proposing that facili ties 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 de ployed 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 requ ired to be reported in

the annual report (concurrent entry of “inputs to equations” data elements and data required for

the annual report would be requi red starting in reporting year 2014, as further discussed in

Section III.A.2 of this preamble). As a built-in f eature 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 elemen ts, and generate a

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verification summary. The tool w ould not retain the entered “input s 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-GGR T, 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 c onsists of electroni c verification checks

followed by direct follow-up with facilities. Fo r subparts where the re porting 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 repor ting of which was deferred). For

“supplier” subparts 5 

# (and starting in reporting year 2012 for subparts with inputs to emission

equations that were deferred unt il 2013), these checks have been conducted using reported data

that include the data needed to calculate outpu ts of the equations. Re porters under the supplier

subparts have been entering into e-GGRT th e data needed to calculate the annual GHG

quantities. For reporters under the direct emitter subparts listed in Ta ble 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 us ed 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 va lues and verify these emission values. The

4 

## Please see section III.A.3 of this preamble for a discussion on which “i nputs 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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difference, however, is that these “inputs to equa tions” 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, reporte rs would log into e-GGRT. They would

enter data elements required for the annual repor t 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 w ould 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 verificati on tool would use entere d 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 verificati on tool prior to comp leting data entry or

submitting their annual report, the tool would genera te a file of entered “inputs to equations” data

elements, and allow the reporter to download the f ile. 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-e nter “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 woul d calculate the annual GHG emissions values. The tool would use

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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 th is 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 va lues 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 va lues calculated by the tool with their own

calculated value. If the reporter chose to override th e calculated value, this would be reflected in

the verification summary.

Prior to annual report submittal, the inputs verification tool woul d conduct a series of

verification checks, in cluding the following:

 

# Verification checks on the annual GHG emi ssion values calculated by the inputs verification tool. As mentioned above, reporte rs would have the opportunity to override
and revise the value calculat ed by the tool; however should this occur, the tool would note a discrepancy, which would prompt the EP A for further review after the reporter submits the annual report.

 Verification checks on entered “inputs to equatio ns” data elements. For example, the tool would check: (1) whether all re quired data were entered; (2) whether entered “inputs to equations” data element values are within th e expected ranges for the data elements; and (3) whether expected relationships exist be tween 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 el ements (e.g., production quantity) to GHG emission

values at the subpart or facility level.

Also, prior to submittal of the annual report, the inputs verifi cation tool would generate a

verification summary containing th e results of the verification ch ecks. The verification summary

would specify whether any potential errors, as described above, we re identified, without

specifying the “inputs to equations” data elemen ts. The reporter would have an opportunity to

review the verification summary and make n ecessary revisions to the entered “inputs to

equations” data elements and the reported data elements.

For example, a facility subject to subpart G that manufactures a mmonia using liquid and

solid feedstocks is currently required under 40 CFR 98.76(b)(1) to report annual CO 2 

# process

emissions for each ammonia manufacturing unit. Cu rrently, 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, a nd 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 veri fication tool to calculate annual CO 2 

# process emissions. In calculating this value, the to ol would use Equations G-2, G-3, and G-4 of Part 98 and the 48 “inputs to equa tions” data element entries.

 

# Once the annual CO 2 

# process emissions value is calcu lated, the inputs verification tool would automatically conduct verification check s 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 en tered values for carbon content of liquid feedstock is within the expected range fo r carbon content of liquid feedstock (based on industry-wide data). The tool woul d conduct similar comparisons for the 12 entered “inputs to equations” data elemen ts for the carbon content value for solid
feedstock.

- Algorithm check comparing each of the 12 ente red 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 “input s to equations” data elements for the quantity of solid feedstock. This type of ch eck would be conducte d after the reporter has entered all “inputs to equations” data elements.

 

# Prior to annual report submittal, the inputs ve rification tool would automatically generate a verification summary, which would flag any potential errors, providing an opportunity for the reporter to review the verificat ion summary and revise entered data. The verification summary would note if the repo rter 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-gener ate the verification summary prior to annual report submittal. The EPA would access the ve rification summary (i.e., the same final summary viewed by the reporter) following annual report submittal and certification.

 The inputs verification tool would also gene rate 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 ma intained as a record in a format currently allowed under Part 98 (see 40 CFR 98.3(g), subp art A). Refer to Section III.B of this preamble for further discussion of this propos ed amendment and the EPA’s rationale for requiring this record.

The EPA has developed a “pilot” inputs veri fication tool for one subpart, subpart X,

which will be posted at http://www.epa.gov/ghgre porting/reporters/training/rulepilot.html, to

demonstrate how the tool would work within e-GGR T, 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 el ements. The EPA also seeks

comment on additional approaches considered by EPA for implementation of the inputs

verification tool; refer to the memorandum “Evaluation of Altern ative Verification Approaches

for Greenhouse Gas Reporting Rule Subparts fo r 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 addi tional 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 electr onic 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 ve rification 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 fo r facilities reporting

under the subparts listed in Table 2 of this preamble using the a dditional checks that would be

conducted by the inputs verifi cation 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 prog ram. During reporting

year 2010, the EPA developed approximately 1,400 el ectronic verification checks to verify

reported data. Based on these verification check s, the EPA followed up with approximately

2,360 of the approximately 6,700 faci lities that reported in repor ting year 2010, resulting in

approximately 2,300 facilities reso lving 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-repor ting subparts. During re porting 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 veri fication issues.

For example, for subpart H, the EPA verifi es reported GHG emissi ons data using: (1)

reported cement production data and (2) public ly available industry data on GHG emissions.

Using these data, the EPA has established rang es 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 en suring the completeness and accuracy of reported data and reducing the

costs of compliance monitoring.

The inputs verification tool desc ribed in Section III.A.1 of this preamble utilizes the same

approach that the EPA currently uses for calcu lating and verifying data submitted for supplier

subparts (and starting in repor ting 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 generate d by the inputs verification tool, along with

verification summaries that are currently genera ted using data currently collected through the

annual report. By requiring use of the inputs veri fication tool, the EPA wo uld 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 eq uations” 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 lik ely 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” da ta elements were submitted to the EPA, this

approach would facilitate verification by identi fying 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 requ irement for “inputs to equations” data elements

for which our four-step evaluation did not iden tify 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 re porting would be retained and these proposed

new reported data elements would allow th e EPA to conduct additional verification and

minimize the number of follow-ups with facilities. Lastly, for th e 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 necessa ry follow-up with reporters. For the reasons

stated above, the EPA has determined that the pr oposed 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 identif ied in Table 2 of this preamble and is a

reasonable alternative to collec ting “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 verifi cation tool is designed to be used concurrently with annual

reporting by facilities. By the time the EPA ta kes 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 th ese years, given that most of th e data would likely already have

been published and that the use of best availa ble monitoring methods (BAMM) for these sectors

is relatively low during these years, the EPA ha s determined that the added benefit does not

outweigh the burden that would be required for faci lities to use the input s verification tool for

years prior to reporting year 2014.

3. Reporting of 440 “Inputs to Equations” Data El ements Would Not Be Necessary With the

Proposed Verification Approach.

The EPA is proposing to remove the reporti ng 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 Se ction III.A.2 of this preamble, the EPA would no

longer need to rely on th e collection of these “i nputs to equations” data elements to verify

emissions under those subparts. Not having these da ta 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 becau se 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 e ach 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 se ctions of each subpart would improve the clarity

of the specific records that woul d be required to be retained. B ecause 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 veri fication tool (i.e., file for do wnloading 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 requi red 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 y ears 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 beca use 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 fo r specified stationary fuel combustion sources

connected to certain electric generators that deliv er 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, th ese “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, th ese data elements would not raise disclosure

concerns. Having these data elements repor ted would allow the EPA to do additional

verification, including conduct yea r-to-year comparisons, thereby reducing the amount of direct

follow-up required with facilities. For the reason stated above, co llecting these data elements,

even in the absence of collec ting 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 eval uation; however, the EPA is not retaining these

reporting requirements. The EPA determined that th ese 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 th e 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 th e sum of the nameplate capacities for all such electric generators is greater than or e qual 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 equatio ns” 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 equatio ns” 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 annua l report and they would

be accessible by the EPA once the reporter submits th e annual report. In order to ease the burden

on facilities, for reporting years prior to re porting 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 prepar e 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 app licable 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 re vise, re-certify, and re -submit annual reports for

reporting years 2010, 2011, 2012, and 2013.

The proposed revisions to the current reporti ng 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 reporte d GHGs. However, as noted in Table 2, we are

not proposing to amend the reporting requirements fo r 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 be en 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 subjec t 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 genera tors 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 fu rther 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 th e purpose of monitoring, calculating, and

reporting emissions. The EPA rec ognizes that stationary combus tion units grouped in these

reporting configurations could in clude both combustion units associ ated 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 combus tion units not associated with electric

generators (excluding generators co nnected to combustion units subjec t to subpart D of this part).

In these cases where combustion units are groupe d, the EPA has determined that there would be

no disclosure concerns with re porting of “inputs to equations” data elements for the grouped

combustion units. In reporting combined data fo r multiple units including those associated with

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an electric generator and subject to reporting under this proposed acti on, no unit-specific data

would be revealed. Furthermore, should a facility not wish to disclose a ggregated data, it would

have the option to calculate a nd 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 provi de detailed information about the concern, as well as whether

reporting on an individual unit basi s 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 inform ation in order to maintain the requirements

in these paragraphs.

The EPA requests comment on the proposed in puts verification tool and verification

approach, and the associated revision to the curre nt 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 re tention period and record format requirements

would be sufficient to allow the EPA to perform data verifica tion. 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 cu rrent format would be adequate for our verification process. For example, we c onsidered 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 th e 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 ac tivities under this a lternative 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 repor ters 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, incl uding on-site audits if necessa ry, regarding po tential errors,

discrepancies, or questions. Should an EPA inspector visit a facility, it woul d be important to be

able to examine not only the cu rrent year’s records but those from previous years as well,

because previous years’ data would provide ye ar-to-year comparisons, which are useful for

verifying the current year’s data . A 5-year record retention peri od would ensure the availability

of relevant records for the follo w-up activities describe d above. The EPA is proposing that this

5-year record retention require ment begin with records for re porting year 2010, as discussed in

Section III.A.1 of this preamble.

For reporters subject to using the proposed i nputs verification tool, the EPA is proposing

to extend the record rete ntion period not only for the subparts listed in Table 2 of the preamble,

but also for other subparts that apply to reporte rs subject to a subpart in Table 2. Under this

proposal, any such facility subject to both a subp art listed in Table 2 of this preamble and a

subpart not listed in Table 2 would be require d to maintain all reco rds 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 unde r subpart HH (not in Table 2),

the facility would be re quired to maintain all records required under both subparts for 5 years.

The EPA is proposing these provisions for two reas ons. First, the EPA determined that during a

site visit, if questions arise regarding the accuracy of an “input s to equations” data element, it

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may be necessary to examine other non-input re cordkeeping information, such as a monitoring

plan or recordkeeping information in a differe nt 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 th e same record retention durati on for all subparts, as proposed,

would simplify recordkeeping and thereby mini mize the chance for recordkeeping errors.

In addition, the EPA is proposi ng revisions to the recordkeep ing format for “inputs to

equations” data elements. Currently, reporters ha ve the option to mainta in records of their

“inputs to equations” data elements in one or mo re electronic or hard copy files. The proposed

record format revision would requi re reporters to maintain an el ectronic or hard copy of the

single file generated by the proposed inputs verifi cation tool, listing all “i nputs to equations” data

elements entered into the tool. This proposed r ecord 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 vis its. All other records re quired 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 discusse d 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 re quirements, 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 amende d. 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 verifica tion 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 th e 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 th at certain reporters us ing 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. Thes e data elements are qua ntities that provide

information on the activity level at the facility, emission factor s used, characteristics of carboncontaining streams, and other process informa tion that would provide key information for

verification, including co nfirming that emissions are appropria te for a given activity-level and

estimating expected emissions based on data prov ided. These new data reporting elements would

also enable the EPA to better understand the follo wing 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 th e industry sect or; and (3) the

factors influencing GHG emissions.

The EPA is proposing to add six new equatio ns (Equations Q-9 through Q-14 of part 98)

to subpart Q to specify how to cal culate 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. Refe r to the following Section IV of this preamble

for the EPA’s proposed confidentiality determinat ions for the proposed new data elements.

IV. Confidentiality Determination for Propos ed 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 dete rminations, 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 ca tegory 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 el ements, 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 th at 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 Material s Consumed that are Not Inputs to Emission

Equations” data categories are enti tled to confidential treatment b ecause the data do not meet the

definition of “emission data” in 40 CF R 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 E quations” data category and 10

new data elements be assigned to the “Raw Mate rials Consumed that are Not Inputs to Emission

Equations” data category, as shown in Table 5 of this preamble, thereby applying the categorical

confidentiality determinations ma de for these categories in the 2011 final CBI rule (i.e., they are

CBI) to the proposed new reporting elements assigne d to these categories. This proposal is not

changing, nor soliciting comment on, the categorical confidentiality determ ination for these two

data categories. Should the EPA fi nalize the category assignment fo r these data elements, all new

data elements assigned to these categories woul d be considered to be entitled to confidential

treatment.

Table 5. Data Elements Proposed to Be A ssigned 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)(1 8) 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 (inmetric 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 I nputs 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 CO 2 

# 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 CO 2 

# emissions: The annual mass (metric tons) of all non-fuel material inputs (combined) specified in Equations Q-1 through Q-7, calculated asspecified 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 CO 2 

# 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 CO 2 

# emissions: The weighted average carbon content of all gaseous, liquid, and solid fuels (combined) included in Equation Q-9, calculated asspecified 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 CO 2 

# emissions: The weighted average carbon content of all non-fuel inputs to all furnaces (combined) included in Equation Q-10, calculated asspecified 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 CO 2 

# 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 (inmetric 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 CO 2 

# 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 Equa tions” category and one proposed

new data element to the “Unit/Process Static Ch aracteristics that are Not Inputs to Emission

Equations” category. In the 2011 fina l CBI rule, the EPA determined that the data elements in

these categories are not “emission data” (as defi ned 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 de terminations, the EPA

considered the confidentiality criteria at 40 CF R 2.208, in particular whether release of the data

is likely to cause substantial harm to th e business’s competitive position. See 40 CFR

2.208(e)(1). The EPA is therefore following the sa me approach in this action for the proposed

new reporting elements assigne d to these two categories.

Table 6 of this preamble lists the data elements the EPA pr oposes 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 Determin ations for Proposed New Data Elements Assigned to the “Unit/Process Operating Char acteristics That Are Not Inputs to Emission Equations” and “Unit/Process ‘Static’ Charac teristics 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 N 2 

## O
emission
reduction for all production
units
combined. Not CBI The annual facility percent N 2 

## O
reduction could not be used to calculate adipic acid production.
The level of N 2 

## O 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 CO 2 

## emission
factor for the facility, averaged
across all kilns (metric

tons CO 2 

## /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)
CO 2 

## emission
factor for the facility, averaged
across all kilns (metric

tons CO 2 

## /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 N 2 

## O
emission
reduction for all production Not CBI The annual facility percent N 2 

## O
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 N 2 

## O 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 N 2 

## O
emission reduction information is already publicly available (seedocket 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 usingEquation 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 usingEquation 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 usingEquation 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 No t Inputs to Emission Equations” Data Category

AA - Pulp and Paper 40 CFR 98.276(m)(2) For each
chemical ND 1 

## 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 usingEquation C2c to
calculate CO 2 

## 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 da ta category assignment for each of these data

elements in Tables 5 and 6. If you believe th at the EPA has improperl y assigned any proposed

new data elements to one of the data categor ies, please provide specific comments identifying

which proposed new data elements may be mis-a ssigned 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 da ta 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 a nd 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 memora ndum, “Impacts Analysis of the Proposed 2015

Inputs Proposal,” available in EP A 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 da ta 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 (includi ng 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 el ements 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 verificati on tool and we have estimated a cost of

approximately $66 per facility, or $379,000 for the fi rst year for all affect ed facilities. During

their first session using the propos ed inputs verification tool, re porters would need to spend

approximately 1 hour becoming familiar with ho w the tool operates within e-GGRT. The

proposed new requirement to use the inputs verifi cation tool would not re sult 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 informa tion about this cost estimate,

refer to the memorandum “Assessment of Cost Impacts of 2015 Inputs Proposal – Revisions to

Reporting, Recordkeeping, and Verification Re quirements under the Greenhouse Gas Reporting

Program” and the supporting statement for this proposed information collection request,

“Supporting Statement, Environmental Protec tion Agency: Revisions to Reporting and

Recordkeeping Requirements, and Proposed Confidentiality Determinations under the

Greenhouse Gas Reporting Program, OMB cont rol number 2060-[INSERT NEW NUMBER],

ICR number 2483.01,” both availabl e in docket EPA–HQ–OAR–2010-0929.

2. Proposed New Data Elements.

We are proposing to add 26 new data elements that were not previ ously required to be

reported under Part 98 (see Section II.D of this preamble for furt her discussion of this proposed

amendment), to be reported by f acilities in certain subparts that are required to use the proposed

inputs verification tool. Of thes e 26 data elements, nine data elements are related to annual

production or raw material usage, which are collec ted by a facility as a ro utine part of conducting

business. For these data elements, we are not pro posing 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 em issions 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 su bparts is $80,000. These costs represent the cost

for all affected faciliti es in the first year.

B. Additional Impacts of the Proposed Amendments

The proposed confidentiality determinations fo r 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 Execu tive Order Reviews

A. Executive Order 12866: Regulatory Planni ng and Review and Executive Order 13563:

Improving Regulation a nd Regulatory Review

Under Executive Order 12866 (58 FR 51735, October 4, 1993), this action is a

“significant regulatory action” b ecause 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 recommendati ons have been documented in the docket for

this action.

B. Paperwork Reduction Act

This action proposes to amend reporting and recordkeeping requireme nts and verification

procedures for the GHGRP. In addition, the EPA is proposing confidentiality determinations for

the proposed new data elements in this ac tion. The proposed amendments to the reporting

requirements in the source category-specific subpar ts are not anticipated to result in significant

burden for reporters. The new data elements requir ed 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 change s to the reporting re quirements in each

subpart are detailed in the memorandum “I mpacts Analysis of the Proposed 2015 Inputs

Proposal” (see Docket ID N o. EPA-HQ-OAR-2010-0929). The Of fice of Management and

Budget (OMB) has previously approved the inform ation collection requirements for 40 CFR part

98 under the provisions of th e 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 regul ations in 40 CFR are listed in 40 CFR

part 9.

C. Regulatory Flexibility Act (RFA)

The RFA generally requires an agency to prep are a regulatory flexibil ity analysis of any

rule subject to notice and comment rulemaking requirements under the Administrative Procedure

Act or any other statute unless the agency certifie s that the rule will not have a significant

economic impact on a substantial number of sm all entities. Small en tities include small

businesses, small organizations, a nd small governmental jurisdictions.

For purposes of assessing the impacts of th e 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 ha ve 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 r ecordkeeping and reporting of 26 new data elements.

The EPA continues to be interested in th e potential impacts of the proposed rule

amendments on small entities and welcomes comm ents 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 privat e sector in any one year. Thus, the proposed

amendments and confidentiality determinations ar e not subject to the requirements of sections

202 or 205 of UMRA.

This rule is also not subject to the requi rements of section 203 of UMRA because it

contains no regulatory require ments that might significantly or uniquely affect small

governments. This action proposes to amend reporting and recordkeeping requirements and

verification procedures for the GHGRP. In a ddition, 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 implicat ions. 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 propos ed amendments and confidentiality

determinations apply to facilities that direc tly 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 leve ls (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 propos ed 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 Or der 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 fro m state and local officials.

F. Executive Order 13175: Consultation and Coor dination with Indian Tribal Governments.

This proposed action does not have tribal im plications, as specified in Executive Order

13175 (65 FR 67249, November 9, 2000). The proposed amendments and confidentiality

determinations apply directly to facilities that directly em it 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 threshol d levels (such as a landfill or large combustion

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device). Relatively few tribal facilities would be affected. T hus, 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 Executiv e Order has the potential to in fluence 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 En ergy 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 likel y to have a significant adverse effect

on the supply, distribution, or use of energy. Pa rt 98 relates to mon itoring, reporting, and

recordkeeping and does not impact energy supply, distribution, or use. Th is action proposes to

amend reporting and recordkeeping requirements and verification pr ocedures for the GHGRP. In

addition, the EPA is proposing confidentiality determinations for the proposed new data

elements in this action. These proposed amendmen ts 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 Nati onal 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 regul atory activities unless to do so would be inconsistent with

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applicable law or otherwise impractical. Volunt ary consensus standards are technical standards

(e.g., materials specifications, test methods, samp ling procedures, and busi ness 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 th e 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. It s main provision directs federal ag encies, to the greatest extent

practicable and permitted by law, to make environmental justice part of their mission by

identifying and addressing, as appropriate, disp roportionately high and adverse human health or

environmental effects of their programs, policie s, 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 advers e human health or environmen tal 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 becau se the proposed amendments address information

collection and reporting a nd verification procedures.

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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, ti tle 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 paragra phs (c)(4)(vii), (d)(3)( v), (g) introductory

text, and (g)(2)(i) to read as follows:

§ 98.3 What are the general monitoring, rep orting, 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 faci lity is not required to report th e data elements specified in

Table A-7 to this subpart for cale ndar years 2010 through 2013 until March 31, 2015. D 

# ata

elements specified in Table A-7 to this s ubpart 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 cr iteria specified in §

98.36(f) of this part, report any facility operati ng data or process information used for the GHG

emission calculations.

* * * * *

(g) Recordkeeping . An owner or operator that is re quired to report GHGs under this part

must keep records as specified in this paragraph. Except as otherw ise 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 wh ich the record was generated. The records shall be kept in an

electronic or hard-copy format (a s appropriate) and reco rded 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 fo r 5 years from the date of submission of the

annual GHG report for the reporting year in whic h 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 record s 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 method s 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 representa tion for a facility or supplier must be

submitted electronically in accordan ce 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 calculati on 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 Elemen ts 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 fo r 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 Equa tion 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 cond ucting weekly sampling).

II 98.356(d)(3) All (if cond ucting weekly sampling).

II 98.356(d)(4) Only weekly aver age 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 averag e pressure (if conducting weekly sampling).

1 

# Required to be reported only by stationary fu el 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 stat ionary fuel combustion source contains at least
one combustion unit connected to a fuel-fired elec tric 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 subjec t 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 genera tors 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 calcula ting the anode effect minutes per cell-day (AEM) and slope coefficients (SCF 4), 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, th e 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 calcula tion, if applicable, as spec ified 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 bur n-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 combusti on sources (e.g., individual units, aggregations of units, common pipes, or common stacks) mee ting 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 (exclu ding generators that are connected to combustion units subject to subpart D of this part); and (2 ) the stationary fuel combustion s ource is located at a facility for which the sum of the nameplate capacities for all su ch 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 un its, common pipe, or common stack).

(b) * * *

(9) * * *

(iii) The annual CH 4 

# and N 2 

# O 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 CO 2 

# e.

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(iv) For each stationary fuel combustion s ource 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 combus ted in the unit during the report year.

* * * * *

(c) * * *

(2) * * *

(ix) For each type of fuel lis ted in Table C–2 of this subpa rt that was combusted during

the report year in the units sharing the common stack or duct during the report year, the annual

CH 4 

# and N 2 

# O mass emissions from the units sharing the common stack or duct, expressed in

metric tons of each gas and in metric tons of CO 2 

# e.

(x) For each stationary fuel combustion s ource 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, fo r 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, gallo ns 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 sour ce 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 ye ar. Express the quantity

of each fuel combusted during the measurement peri od in short tons for solid fuels, gallons for

liquid fuels, and scf for gaseous fuels.

* * * * *

(C) For each stationary fuel combustion sour ce that meets the criteria specified in

paragraph (f) of this section, the high heat values used in the CO 2 

# 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 re quired. 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 sour ce that meets the criteria specified in

paragraph (f) of this section, if Equation C–2c of this subpart is used to calculate CO 2 

# mass

emissions, report the total quantity (i.e. , pounds) of steam produced from MSW or solid fuel

combustion during each month of the reporting ye ar, 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 CO 2 

# 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 sour ce that meets the criteria specified in

paragraph (f) of this section, th e quantity of each type of fuel combusted in the unit or group of

units (as applicable) during each month of the repor ting year, in short tons for solid fuels, gallons

for liquid fuels, and scf for gaseous fuels.

* * * * *

(C) For each stationary fuel combustion sour ce 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 valu e of each parameter. If multiple values of a

parameter are obtained in a given month, repor t the arithmetic averag e value for the month.

Express carbon content as a decimal fraction for so lid 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 sour ce that meets the criteria specified in

paragraph (f) of this section, the annual averag e HHV, when measured HHV data, rather than a

default HHV from Table C–1 of this subpart, are used to calculate CH 4 

# and N 2 

# O emissions for a

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

* * * * *

(ix) * * *

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(D) For each stationary fuel combustion sour ce 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 CO 2 

# per mmBtu.

(E) For each stationary fuel combustion s ource that meets the criteria specified in

paragraph (f) of this section, the annual av erage 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 sour ce that meets the criteria specified in

paragraph (f) of this section, th e 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 reporti ng 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 combus tion 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 lo cated at a facility for which the sum of the

nameplate capacities for all electric generators specified in paragr aph (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 a ll production lines combin ed (metric tons).

(n) Annual percent N 2 

# O emission reduction for all production units combined.

* * * * *

Subpart F—[AMENDED]

8.Section 98.66 is amended by:

a. Removing and reserving pa ragraphs (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 (o r 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 produc tion (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 para graphs (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 m onthly clinker production from each kiln.

(16) Annual clinker prod uction (metric tons).

(17) Annual average clinker CO 2 

# emission factor for the faci lity, averaged across all kilns

(metric tons CO 2 

# /metric ton clinker produced).

(18) Annual average CKD CO 2 

# emission factor for the facil ity, averaged across all kilns

(metric tons CO 2 

# /metric ton CKD produced).

Subpart K—[AMENDED]

11. Section 98.116 is amended by:

a. Removing and reserving paragr aphs (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 determin ation of carbon content for each material

included for the calculation of annual process CO 2 

# emissions for each EAF (e.g. , supplier

provided information, analyses of re presentative samples you collected).

* * * * *

Subpart L—[AMENDED]

12. Section 98.126 is amended by:

a. Revising paragraph (b)(1).

b. Removing and reservi ng paragraph (b)(2).

c. Revising paragraphs (b)(6), (b )(7), and (b)(8)( i) through (iv).

d. Removing and reserving para graphs (b)(8)(v) and (b)(9).

e. Revising paragraph (c)(1).

f. Removing and reserv ing paragraph (c)(2).

g. Revising paragraph (d).

h. Removing and reserving paragrap hs (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 unde r paragraph § 98.123(b)(1).

* * * * *

(6) The chemical formula of each fluorine-contai ning reactant that is fed into the process.

(7) The chemical formula of each fluorine-c ontaining product produced by the process.

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(8) * * *

(i) The chemical formula of each fluorine-c ontaining product that is removed from the

process and fed into the destruction device.

(ii) The chemical formula of each fluorine- containing by-product th at is removed from

the process and fed into the destruction device.

(iii) The chemical formula of each fluorine-c ontaining 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 leng th 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 me thods 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) a nd (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 paragrap hs (d)(1), (d)(5), and (e)(1).

The revisions read as follows:

§ 98.156 Data reporting requirements.

* * * * *

(d) If the HFC–23 concentration measured pur suant to §98.154(l) is greater than that

measured during the performance test that is th e 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 paragrap hs (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 appropr iate, and paragraphs (c)

through (e) of th is 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 addi ng paragraph (e)(6).

c. Removing and reserving paragr aphs (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 CO 2 

# 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 (v i) of this section

aggregated for all process units for which CO 2 

# 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 t ons) of all gaseous, liquid, and solid fuels (combined) used

in process units for which CO 2 

# 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	൅ ܨ ௦,௜ 

# 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 un its where fuel is used.

F g,i 

# = Annual volume of gaseous fuel combusted (“(F g 

# )” in Equations Q-1, Q-4 and Q-7 of this section) for each process (scf).

MW i 

# = 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.

F l,i 

# = Annual volume of the liquid fuel combusted (“(F l 

# )” included in Equation Q-1 of this section) for e ach process unit (gallons).

F s,i 

# = Annual mass of the solid fuel combusted (“(F
s 

# )” in Equation Q-1 of this section) for each process unit (metric tons).

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ρ l,i = 

# Density of the liquid fuel (kg/gallon).

0.001 = Conversion factor fr om kg to metric tons.

(ii) The annual mass (metric tons) of all non-f uel material inputs (combined) specified in

Equations Q-1 through Q-7 of this section, calcu lated as specified in Equation Q-10 of this

section.

ൌ ܫܨܰ ∑ሺ ݈݁݁ݐܵ ൅ ݀݁݋ݎݐ݈݁ܿܧ ൅ ݁݁݀ܨ ൅ ݈ܽ݋ܥ ൅ ݊݋ܾݎܽܥ ൅ ݔݑ݈ܨ ൅ ݌ܽݎܵܿ ൅ ݊݋ݎܫ ൅ ܱ ௡௜ ௡ ௜ୀଵ 

# ൅

݁ݎܱ ൅ ݎ݄݁ݐܱ .Eq ( (-10Q

Where:

NFI = Annual mass of all non-fuel inputs (t o all process unit types) specified in Equations Q-1 through Q-7 of th is section (metric tons).

n = Number of process units, all process types.

O = Annual mass of greenball (taconite) pe llets fed to the taconite furnace(s) (metric tons).

Iron = Annual mass of molten iron charge d to the basic oxygen furnace(s) plus
annual mass of direct reduced iron char ged 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 char ged to the basic oxygen furnace(s) and EAF(s) (metric tons).

Carbon = Annual mass of carbonaceous mate rials (e.g., coal, coke) charged to the basic oxygen furnace(s), EAF(s), and dire ct 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 mate rial charged to the sinter process(es) (metric tons).

Electrode = Annual mass of carbon electrode consumed in the EAF(s) (metric tons).

Steel in 

# = Annual mass of molten steel charged to the decarburizat ion vessels (metric tons).

Ore = Annual mass of iron ore or iron or e pellets fed to the direct reduction furnace(s) (metric tons).

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Other = Annual mass of other material s charged to the direction reduction furnace(s) (metric tons).

(iii) The annual mass (metric tons) of a ll solid and liquid pro ducts and byproducts

(combined) specified in Equations Q-1 through Q-7 of this secti on, calculated as specified in

Equation Q-11 of this section.

ൌ ݏݐܿݑ݀݋ݎܲ ∑ሺ ݈݁݁ݐܵ ൅ ܴ ൅ ܲ ௨௧௢ 

# ܯܰ ൅ ݊݋ݎܫ ൅ ݎ݁ݐܵ݅݊ ൅ ݇݁݋ܥ ൅ ݈ܵܽ݃ ൅ ௡ ୀଵ௜ 

# ሻ ሺ (-11Q .Eq

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).

Steel out 

# = 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 fr om 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 mate rials 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:

CF avg 

# = Weighted average carbon content of all gaseous, liquid, and solid fuels included in Equation Q-9 of th is section (weight fraction).

n = Number of gaseous, liquid, and solid fuel input to each process unit as used in Equation Q-9.

C gf,i 

# = Average carbon content of the gaseous fuel used in each process, from the fuel analysis results (kg C per kg of fuel).

C lf,i 

# = Carbon content of the liquid fuel used in each process, from the fuel analysis results (kg C per gallon of fuel.

C sf 

# = 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 al l non-fuel inputs to all process units

(combined) included in Equation Q-10 of this se ction, calculated as specified in Equation Q-13

of this section.

ܫܥ ௔௩௚ 

# ൌ ൫ ∑ ேிூ ೔ 

### ∗஼ ಿಷ಺೔ ೙ ೔సభ 

### ൯

ேிூ 

# (Eq. Q-13)

Where:

CI avg 

# = Weighted average carbon content of all non-fuel inputs to all process units included in Equation Q-10 of th is section (weight fraction).

n = Number of non-fuel inputs to all process units as used in Equation Q-10.

NFI i 

# = Annual mass of each non-fuel input used in Equation Q-10 (metric tons).

C NFIi 

# = 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 (combine d) 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:

CP avg 

# = 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.

Product i 

# = Annual mass of each product or byp roduct used in Equation Q-11 (metric tons).

C p,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 se ction (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 determinati on of carbon content for each material used

for the calculation of annual process CO 2 

# emissions using Equation R–1 of this subpart for each

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smelting furnace (e.g. , supplier provided info rmation, 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 CO 2 

# 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 paragrap hs (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 N 2 

# O emission reduction for all production units combined.

Subpart X—[AMENDED]

21. Section 98.246 is amended by:

a. Revising paragraph (a) introductory te xt and paragraphs (a)(2) and (a)(4).

b. Adding paragraphs (a)(12) and (13).

c. Revising paragraph (b) introductory text.

d. Removing and reserving paragrap hs (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 methodol ogy in § 98.243(c), you must report the

information specified in paragraphs (a)(1) thr ough (a)(13) of this se ction for each type of

petrochemical produced, re ported 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 ga seous 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 t ons) of each product included in Equations X1, X-2, and X-3 of § 98.243 of this subpart.

(b) If you measure emissions in accordan ce 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 t ons) 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 reserv ing 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 para graphs (o)(2)(ii), (o)(4 )(ii) through (v), a nd (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 CO 2 

# concentration (volume or mole pe rcent), the number of carbon containing

compounds other than CO 2 

# in the flare gas stream, and for each of the carbon containing

compounds other than CO 2 

# in the flare gas stream:

* * * * *

(9) If you use Equation Y–3 of this subpa rt, the number of SSM events exceeding

500,000 scf/day.

(10) The basis for the value of the fracti on 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 flar e 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,

%CO 2 

# , 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 va lue, a unit-specific emission factor, or a

default emission factor for CH 4 

# emissions. If you use a unit-specific emission factor for CH 4 

# ,

report the basis for the factor.

(12) Indicate whether you use a measured va lue, a unit-specific emission factor, or a

default emission factor for N 2 

# O emissions. If you use a unit-specific emission factor for N 2 

# O,

report the basis for the factor.

(13) If you use Equation Y–11 of this subpart , the number of rege neration 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 th e 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 CO 2 

# emissions in the tail gas wa s used in Equation Y–12. If

so, then report:

(i) The value of the correction.

(ii) If the following data ar e not used to calculate the r ecycling correction factor, report

the information specified in paragraphs (h )(5)(ii)(A) thr ough (C) of this section.

(A) The annual volume of recycl ed 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 po rtion of the dust is recy cled, or none of the dust

is recycled).

* * * * *

(7) Indicate whether you use a measured va lue, a unit-specific emission factor or a

default for CH 4 

# emissions. If you use a unit-specific emission factor for CH 4 

# , report the basis for

the factor.

(8) Indicate whether you use a measured va lue, a unit-specific emission factor, or a

default emission factor for N 2 

# O emissions. If you use a unit-specific emission factor for N 2 

# O,

report the basis for the factor.

(j) * * *

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(5) If you use Equation Y–14 of th is subpart, the basis for the CO 2 

# emission factor used.

(6) If you use Equation Y–15 of th is subpart, the basis for the CH 4 

# 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 th is subpart, the basis for the CO 2 

# emission factor used

and the basis for the carbon emission factor used.

(9) If you use Equation Y–17 of th is subpart, the basis for the CH 4 

# 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 CF 4 

# /kg-mole gas,

wet basis).

* * * * *

(l) * * *

(5) The annual volumetric flow discharged to the atmosphere (in sc f), and an indication

of the measurement or estimation method, annual average mole fraction of each GHG above the

concentration threshold or ot herwise required to be reporte d and an indication of the

measurement or estimation method, and for intermitte nt vents, the number of venting events and

the cumulative venting time.

(m) * * *

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(3) For uncontrolled blowdown systems re porting 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 gr eater, 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 a nd 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 contai n 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 Li quor, TAPPI (incorporated by reference, see §

98.7) or an online measurement system).

* * * * *

(l) For each pulp mill lime kiln, report the info rmation 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 ea ch chemical recovery combustion unit for

which you are not using Equation C-2c to calculate CO 2 

# emissions, report the information

specified in paragraphs (m)(1) and (2) of this section.

(1) The annual mass of steam generated (lb st eam), individually for each fossil fuel type

and for spent liquor solids.

(2) The ratio of the unit’s maximum rated he at input capacity to its design rated steam

output capacity (mmBtu/lb steam), individually fo r 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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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 reserv ing paragraph (c)(3)(i).

b. Revising paragraph (c)(3)(ii).

c. Removing and reservi ng paragraph (c)(3)(iii).

The revisions read as follows:

§ 98.466 Data reporting requirements.

* * * * *

(c) * * *

(3) * * *

(ii) The year of the data used in Equa tion 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

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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 th e Greenhouse Gas Reporting Program. This action

addresses concerns about the potential release of certain data that are inputs to emission

equations to be reported whose reporting deadline was deferred until March 31, 2015 while

maintaining the EPA’s ability to verify emissi ons 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]

Formatted: ___GHG PARAGRAPH

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### Page 2 of 103 Formatted: Font: 11 pt



### 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, EP A Docket Center (EPA/DC), Mailcode 6102T, Attention Docket ID No. EP A–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 onli ne 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: Dock et 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 co ntact 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 Formatted: ___GHG PARAGRAPH

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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 tec hnical 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 encr yption, 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 re stricted 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), Environmenta l 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 greenhou se 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. Formatted Table

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### Cate g or y NAICS Exam p les 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 manuf acturing 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. Formatted Table

Formatted Table

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### Cate g or y NAICS Exam p les 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 facilit ies, recovering from scrap and/or alloying purchased metals.

311411 Frozen fruit, juice and vegetable manufacturing
facilities.

311421 Fruit and vegetable canning facilities.

Wastewater
Treatment Treatment 1 

### 322110 Pulp mills.

322121 Paper mills.

322122 Newsprint mills.

322130 Paperboard mills.

311611 Meat processi ng facilities. Formatted Table

Formatted Table

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### Cate g or y NAICS Exam p les 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 ca tegories; however, these categories were evaluated in the EPA’s analysis of the potential impact from the releas e 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 su ppliers 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 IN FORMATION 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

CO 2 

### 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 Formatted Table

Formatted: ___GHG PARAGRAPH

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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 Propos ed 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 Add itional 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 Revie w 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 C oordination with Indian Tribal Governments.
G. Executive Order 13045: Protection of Children from Enviro nmental Health Risks and Safety
Risks H. Executive Order 13211: Actions that Significan tly Affect Energy Supply, Distribution, or Use I. National Technology Tra nsfer 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 Planni ng 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 C oordination with Indian Tribal Governments.
G. Executive Order 13045: Protection of Children from Environmental Health Risks and Safety
Risks H. Executive Order 13211: Actions that Significan tly 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 (GHGR P) collects greenhouse gas data from 41

source categories and currently has two received 2 to three 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,” th e 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 inpu ts 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: Formatted: No underline

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###  

### Adding a requirement for certain reporters under certain 24 subparts to use an EPAprovided inputs verification tool. The For these subparts, the designated inputs to emission equations for these subparts 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, it 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 i nputs verification tool, changing the required format for maintaining records of these inputs to emission equations.

 

### For reporters required to use the inputs verifi cation 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 reporters 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 veri fication 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 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 expi re 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 fi rst 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 abilit y to identify facilities that potentially reported

emissions incorrectly. This, combined with a dditional 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. Formatted: _Bullet-GHG Preamble

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### emission equations that the inputs verification tool would conduct (during the process of

reporters entering data into the inputs verificati on 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 altern ative 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 fr om 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 in puts 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 finali zed confidentiality determinations for data Formatted: No underline

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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 a ssigned 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 evalua tion. 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 5307 7 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 In puts 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 co mpetitive 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 co mpetitive 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 was deferred to March 31, 2015 was conducted. 3 

### The results of the analysis

are documented in four memoranda, as follows:

 

### “ Summary Evaluation of Public Availability of Inputs to Emission Equations for
Which which Reporting was Deferred Until to March 31, 2015.”

 

### “Evaluation of Competitive Harm From Reporting 2015 from Disclosure of “ Inputs to Equations .” ” Data Elements Deferred to March 31, 2015

 

### “ Summary Evaluation of Alternative Calculation Methods.”

 “ Summary Evaluation of Alternative Verification Methods 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 We Based on the same four-step process, we also evaluated all data elements for which reporting is was 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 requ ired to report these data by April 1, 2013 . For a discussion of this evaluation, refer to the EPA's memorandum "Sum mary 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: ___GHG PARAGRAPH

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### The proposed amendments affect all subparts li sted 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

d evice s 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 report ed 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 was addressed

under a separate rulemaking proposed on October 16, 2012 (77 FR 63538). Additionally,

certain parts 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 subpart s (to which the reporter is subject). Refer to

Sections II.C and III.B of this preamble for fu rther 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
Units Sources Connected to Devices Certain
Electric Generators that are Connected and Able
to Deliver Power to the Local or Regional Electric
Power Gri d 2 

### Gri d 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 Formatted: ___GHG PARAGRAPH

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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, th e 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 a ssociated EPA-provided calculation meth odologies 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 device 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 ( e.g., electricity generators excluding generators connected to combustion units that are subject to subpart D of this part Part 98 ); and (2) the combined stationary fuel combustion source is located at a facility for
which the sum of the nameplate capac ity ( 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 Pa rt 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 el ements 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 Formatted Table

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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 preambl e. 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 (hereaft er 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 veri fication 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 summ arizes 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 summar izes proposed new reporting requirements for

these reporters. Section III of this preamble expl ains the rationale for the proposed amendments

summarized in Sections II.A through II.D. S ection 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 pream ble presents the cost and impacts associated

with these proposed amendments.

A. Proposed Use of Inputs Verification Tool Formatted: ___GHG PARAGRAPH

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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 Greenhous e Gas Reporting Tool (e-GGRT) and would be

integrated without interrupting the current electronic reporting process. Reporters would

enter While reporters enter data into e-GGRT that ar e required to be reported in the annual report,

reporters would also enter into e-GGR T (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 co nducting 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 Formatted: ___GHG PARAGRAPH

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### that reporters use this tool starting with repor ting 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 applicab ility 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 435 440 “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

per for each subpart. Refer to Table 1 in the memoran dum “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 435 440 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 re quirements 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 For 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 Specified Stationary Fuel
Combustion Units Sources
Connected to Devices Certain
Electric Generators Connected
and Able to Deliver Power to the Local or Regional Power
Gri d 2 

### 26 1 

### 26 1



### 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 Destructio n 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 70 75 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 units 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 unit s sources that meet both of the following criteria: (1) the stationary fuel combustion source contains at least one combustion unit is connected to a device 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 ( 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 excluding electric 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 units sources subject to subpart C.



### In order to ease the burden for facilitie s, 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 w ould 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 Formatted: ___GHG PARAGRAPH

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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 2 using the proposed inputs verification tool is also subject to a subpart of Part 98

not listed in Table 2, we propose that reco rds 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), th e 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 using 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 Formatted: ___GHG PARAGRAPH

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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 Subpar ts 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 N 2 

### O 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 CO 2 

### emission factor for the facility, averaged across all kilns (metric tons
CO 2 

### /metric ton clinker produced).
Annual average cement kiln dust (CKD) CO 2 

### emission factor for the facility, averaged across all kilns (metric tons CO 2 

### /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 CO 2 

### 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 CO 2 

### emissions: The annual mass (metric tons) of all non-fuel material inputs (combined) specified in Equations Q-1 through Q-7 of Formatted: ___GHG PARAGRAPH

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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 CO 2 

### 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 CO 2 

### 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 CO 2 

### 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 CO 2 

### 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 N 2 

### O 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 Formatted: Space Before: 2 pt, After: 2 pt

Formatted Table

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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 CO 2 

### emissions: Annual mass of steam generated (l b 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 CO 2 

### emissions: Ratio of the unit’s maximum rated heat input capacity to its design rated steam output cap acity (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 veri fication tool and revisions to the requirement to report certain

“inputs to equations” data elements. Section III.B addresses the proposed revisions to Formatted: Space Before: 2 pt, After: 2 pt

Formatted Table

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### recordkeeping requirements. Section III.C addr esses the proposed addition of new reporting

requirements.

A. Proposed Inputs Verification Tool and Amendment to Reporting Requirements

The EPA is proposing that facilities subject using “inputs to equations” data elements to

calculate reported GHGs underthe subparts listed in Table 2 of this preamble use an EPAprovided electronic inputs verification tool, wh ich 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 entr y 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 “input s 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.

Sources 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.

4 Please see section III.A.3 of this preamble for a discussi on on which “inputs to equations” data elements the EPA is proposing that the reporting requirement requirements be removed. Formatted: No underline

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### The EPA’s current verification approach c onsists 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” subparts 5 

### (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 us ed 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 va lues 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, repo rters 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. Formatted: ___GHG PARAGRAPH

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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-ent er “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 va lues: (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 (notinto 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, report ers 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 equa tions” 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 be tween 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 elem ents (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 elem ents 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 CO 2 

### process Formatted: ___GHG PARAGRAPH

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### emissions for each ammonia manufacturing unit. Curr ently, 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 a ll four “inputs to equations” data elements).

 

### The reporter would use the inputs verification tool to calculate annual CO 2 

### 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 CO 2 

### 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 eq uations” 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 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-gener ate 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. Formatted: Bulleted + Level: 1 + Aligned at:
0.5" + Indent at: 0.75"

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###  The inputs verification tool would also gene rate 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), su bpart 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 X

,

which will be posted at http://www.epa.gov/ghgre porting/reporters/traini ng/rulepilot.html, to

demonstrate how the tool would work within e-GG RT, 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 th e “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 Ve rification 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, us ing 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 facilitie s to verify data currently reported via e-GGRT.

The EPA is proposing to supplement the current verification approach for facilities reporting Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH, Left

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### under the subparts listed in Table 2 of this pr eamble 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 facilitie s resolving their verification issues.

For example, for subpart H, the EPA verifi es 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 bot h 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 Sec tion 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 ve rification tool, the EPA would have the additional

certainty that reported annual GHG emissions valu es 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” da ta elements were submitted to the EPA, this

approach would facilitate verification by identi fying 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 iden tify 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 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 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 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 facilitie s to use the inputs verification

tool for years prior to reporting year 2014.

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### 3. Reporting of 435 440 “Inputs to Equations” Data Elements Would Not Be Necessary With the

Proposed Verification Approach.

The EPA is proposing to remove the reporting requirement for 435 440 “inputs to

equations” data elements that are in the subparts listed in Table 2 of this preamble. With the

proposed alternative verification approach describe d 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 435 440 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 435 440 “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 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 specify each of the 435 440 “inputs to equations” data elements to in the

recordkeeping requirements section of each subpart. The EPA considered whether

moving specifying each of these “inputs to equations” data elements to in the recordkeeping

requirements 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

6 We 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 we determined that these data elements would not be useful for data verification and would not inform future GHG policy developm ent in the absence of othe r data elements for which we are proposing to remove the reporting requirement. Formatted: No underline

Formatted: ___GHG PARAGRAPH

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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

435 440 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 elements not 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 , r efer 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 153 170 “inputs to equations” data elements. 7 

### These

153 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 certain specified stationary fuel combustion

7 These 153 170 “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 and 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 were proposed 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) to for EPA’s proposal that these five inputs be removed from reporting. Formatted: Font: Not Bold

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### units sources connected to a device certain electric generators that deliver s 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 report ing 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 comp arisons, thereby reducing the amount of direct

follow-up required with faciliti es. 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 equation s” 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 device 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 ( e.g., electricity generators excluding generators connected to combustion units that are subject to subpart D of this part); and (2) the combined stationary 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 gene rators connected to combustion units subject to subpart D of this part)) electric generators is greater than or equal to 1 megawatt electric output

. Formatted: footnote Char

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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 1 53 170 retained “inputs to equations” data elements, for reporting year

2014 and thereafter, reporters would enter the 153 170 “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 153 170 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 elem ents be submitted as part of the reporting year

2014 annual report. This Specifically, when reporters prepare their reporting year 2014 annual

report via e-GGRT, they would be required to in clude these “inputs to equations” data elements

for reporting year 2014 as well as for all applicab le previous reporting years. The annual report,

including these “inputs to equations” data el ements 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 repor ting 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 units 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 is connected to a device fuel-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 combined stationary 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 su bject 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 units 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 units sources

.

Reporters currently reporting emissions for stationary fuel combustion units 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 devices that can

produce electricity 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 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 elec tricity an electric generator and subject to reporting under this

proposed action, no unit-specific data would be re vealed. Furthermore, shou ld 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 concer ns, please provide detailed information about the

concern, as well as whether reporting on an indivi dual 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 descri bed 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 Formatted: No underline

Formatted: ___GHG PARAGRAPH

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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 2,0 00 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 a udits if necessary, regarding potential errors,

discrepancies, or questions. Should an EPA inspect or visit a facility, it would be important to be

able to examine not only the current year’s r ecords but those from previous years as well,

because previous years’ data would provide ye ar-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 r ecords for reporting year 2010, as discussed in

Section III.A.1 of this preamble.

The 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, a 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 ex ample, if a facility is required to report under use 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 th ese provisions for two reasons. First, the EPA Formatted: ___GHG PARAGRAPH

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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 differ ent record retention periods could possibly cause

confusion and result in recordkeeping errors. Prov iding 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 verifi cation 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 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 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 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 th at 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 informa tion 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 provi ded. These new data reporting elements would Formatted: ___GHG PARAGRAPH

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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 determinat ions 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 collecti ng data under the GHGRP is to inform future GHG policy (refer to the April 10, 2009 proposed rule (74 FR 16455). Formatted: ___GHG PARAGRAPH

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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 Material s Consumed that are Not Inputs to Emission

Equations” data categories are en titled to confidential treatment because the data do not meet the

definition of “emission data” in 40 CF R 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 Mate rials 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 assign ed 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 woul d 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 Equa tions” Data Categories
Subpart Proposed Citation Data Element “Production/Throughput Data that are Not Inputs to Emission Equations” Data Category Formatted: ___GHG PARAGRAPH

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Formatted Table

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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 (inmetric 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. Formatted Table

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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 CO 2 

### 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 CO 2 

### emissions: The annual mass (metric tons) of all non-fuel material inputs (combined) specified in Equations Q-1 through Q-7, calculated asspecified 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 CO 2 

### 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. Formatted Table

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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 CO 2 

### emissions: The weighted average carbon content of all gaseous, liquid, and solid fuels (combined) included in Equation Q-9, calculated asspecified 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 CO 2 

### emissions: The weighted average carbon content of all non-fuel inputs to all furnaces (combined) included in Equation Q-10, calculated asspecified 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 CO 2 

### 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 (inmetric tons) of each carboncontaining feedstock included in Equations X

- 1, X

- 2 and X

- 3.

. Formatted Table

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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 CO 2 

### 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 Ch aracteristics 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 define d 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 elemen ts 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’ Charac teristics that Are Not Inputs to Emission Equations” Data Categories

Sub p art Citation Data
Element Confidentiality
Determination Proposed Rationale for
Confidentialit y Determination Formatted Table

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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 N 2 

### O
emission
reduction for all production
units
combined. Not CBI The annual facility percent N 2 

### O
reduction could not be used to calculate adipic acid production.
The level of N 2 

### O 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 CO 2 

### emission
factor for the facility, averaged
across all kilns (metric

tons CO 2 

### /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)
CO 2 

### emission
factor for the facility, averaged
across all kilns (metric

tons CO 2 

### /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 N 2 

### O
emission
reduction for all production Not CBI The annual facility percent N 2 

### O
reduction 

### for all nitric acid production trains combined
could not be used to calculate the nitric acid production value for Formatted: ___GHG PARAGRAPH, Left

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### Subpart Citation Data
Element Confidentiality
Determination Proposed Rationale for Confidentiality Determination
units
combined. any individual facility. The level
of N 2 

### O 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 N 2 

### O
emission reduction information is already publicly available (seedocket 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 usingEquation 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 Formatted: Font: Times New Roman

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### Subpart Citation Data
Element Confidentiality
Determination Proposed Rationale for Confidentiality Determination usingEquation 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 usingEquation 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 ND 1 

### 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 usingEquation C2c to
calculate CO 2 

### 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-a ssigned 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 th e two direct emitter data categories without

categorical confidentiality determinations, the EPA seeks comment on the individual Formatted: footnote

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### confidentiality determinations we are proposing fo r 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, report ers 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 fo r all affected facilities. 66 per facility, or $379,000

for the first year for all affected facilities. Du ring 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 Formatted: ___GHG PARAGRAPH

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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, cl erical, 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 Re quirements, 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 su bparts 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 pro posing 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 emi ssions 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 Formatted: No underline

Formatted: ___GHG PARAGRAPH

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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 Formatted: No underline

Formatted: ___GHG PARAGRAPH

Formatted: No underline

Formatted: ___GHG PARAGRAPH

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### available for affected facilities, or easily calcul ated 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 prep are 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 certifi es that the rule will not have a significant

economic impact on a substantial number of small entities. Small entities include small

businesses, small organizations, a nd 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 Formatted: No underline

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### independently owned and operated and is not domina nt 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 $ 60 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 ar e 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 mi ght significantly or uniquely affect small

governments. This action proposes to amend reporting and recordkeeping requirements and

verification procedures for the GHGRP. In addi tion, 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. Formatted: No underline

Formatted: ___GHG PARAGRAPH

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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 direct ly 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 th at 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 threshol d levels (such as a landfill or large combustion Formatted: No underline

Formatted: ___GHG PARAGRAPH

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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 Significan tly Affect Energy Supply, Distribution, or Use

This proposed action is not a “significant en ergy 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 Formatted: No underline

Formatted: ___GHG PARAGRAPH

Formatted: No underline

Formatted: ___GHG PARAGRAPH

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### applicable law or otherwise impractical. Volunt ary consensus standards are technical standards

(e.g., materials specifications, test methods, sa mpling 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. Formatted: No underline

Formatted: ___GHG PARAGRAPH

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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. Formatted: No underline

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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 re quired to report the data elements specified in

Table A-7 to this subpart for calendar years 2010 through 2013 until March 31, 2015. D 

### ata

elements specified in Table A-7 to this subpa rt for calendar years 2010 through 2013 must be

submitted as part of the annual report for reporting year 2014.

* * * * *

(d) * * *

(3) * * * Formatted: ___GHG PARAGRAPH

Formatted: Font: Not Bold

Formatted: ___GHG_SECTION

Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH, Tab stops: 0.81", Left + 1.13", Left

Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH, Tab stops: 0.81", Left + 1.13", Left

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### (v) For each stationary fuel combustion unit source that is connected to a device that has

been granted access by meets 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 criteria specified in § 98.36(f) of this part ), and for which the combined

nameplate capacity for all such devices at the faci lity 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: Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

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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 for in 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 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 Formatted: ___GHG PARAGRAPH, Tab stops: 0.81", Left + 1.13", Left

Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

Formatted Table

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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. Formatted Table

Formatted Table

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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 CO 2 

### 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 CO 2 

### 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. Formatted Table

Formatted Table

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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. Formatted Table

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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. Formatted Table

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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 Formatted Table

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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 device 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 ( e.g., electric ity generator s excluding generators that are connected to combustion units subject to subpart D of this part); and (2) the combined stationary 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 Formatted Table

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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) meet ing both of the following criteria: (1) the stationary fuel combustion source contains at le ast one combustion unit connected to a fuel-fired electric generator electric (exclu ding generators that are connected to combustion units subject to subpart D of this part); and (2) the stationary fu el combustion source is located at a facility for which the sum of the nameplate capacities for all su ch 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 ). Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

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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, fo r each stationary fuel combustion source (e.g.,

individual unit, aggregation of units, common pipe, or common stack).

(b) * * *

(9) * * *

(iii) The annual CH 4 

### and N 2 

### O 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 CO 2 

### e.

(iv) For each combustion unit that is connected to a device that has been granted access

by the Public Utilities Commiss ion to deliver power to the local or regional power grid (e.g.,

electricity generators excluding generators connect ed 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 sp ecified in paragraph (f) of this section, report an Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

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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

CH 4 

### and N 2 

### O mass emissions from the units sharing the common stack or duct, expressed in

metric tons of each gas and in metric tons of CO 2 

### e.

(x) For each combustion unit that is connected to a device that has been grante d access

by the Public Utilities Commission to deliver power to the local or regional power grid (e.g.,

electricity generators excluding generators connect ed to combustion units subject to subpart D of

this part), and for which the combined nameplate capac ity 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 sp ecified 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 Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

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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

electric 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 reporti ng 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 connect ed 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 megawa tt 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 tha t 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 connect ed to combustion units subject to subpart D of

this part), and for which the combine d 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 Formatted: ___GHG PARAGRAPH

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### source that meets the criteria specified in paragraph (f) of this section, the high heat values used

in the CO 2 

### emissions calculations for each type of fu el 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 give n 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 conne cted 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 connect ed to combustion units subject to subpart D of

this part), and f or 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 CO 2 

### 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 CO 2 

### 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 ha s been granted access

by the Public Utilities Commission to deliver power to the local or regional power grid (e.g., Formatted: ___GHG PARAGRAPH

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### electricity generators excluding generators connect ed to combustion units subject to subpart D of

this part), and for which the combined na meplate 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 connect ed 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 loc al or regional power grid (e.g., Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

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### electricity generators excluding generators connect ed 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 CH 4 

### and N 2 

### O 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 Commissi on to deliver power to the l ocal or regional power grid (e.g.,

electricity generators excluding generators connect ed 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 CO 2 

### 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 com bustion 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 Formatted: ___GHG PARAGRAPH

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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 d evice that has been granted access by

the Public Utilities Commission to deliver powe r to the local or regional power grid (e.g.,

electricity generators excluding generators connect ed to combustion units subject to subpart D of

this part), and for which th e 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 th e Tier 1, Tier 2, Tier 3, or Tier 4

Calculation Methodologies in §98.33(a) to quantify CO 2e 

### emi ssions, report Each stationary fuel

combustion source (e.g., individual unit, aggr egation 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 any The stationary combustion units are source

contains at least one combustion unit connected to device s a

fuel-fired electric generator that have has 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 namepl ate capacity for all associated devices that

are connected to the local or regional electric power grid (excluding generators that are connected Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

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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 electr ic generators specified in para graph (f)(1) of th is 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 N 2 

### O 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 paragraph paragraphs (c)(3), (e)(1), and (f)(1).

c. c. Removing and reserving paragraph (g). Formatted: ___GHG PARAGRAPH, No bullets or numbering

Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

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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. Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

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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). Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH, No bullets or numbering

Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

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### (17) Annual average clinker CO 2 

### emission factor for the facilit y, averaged across all kilns

(metric tons CO 2 

### /metric ton clinker produced).

(18) Annual average CKD CO 2 

### emission factor for the facility, averaged across all kilns

(metric tons CO 2 

### /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 CO 2 

### 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). Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

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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 relativ e 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-con taining 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).

. Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

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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 paragraph paragraphs (b)(4 ) and (b)(6 ) to read as follows:

§ 98.146 Data reporting requirements.

* * * * *

(b) * * * Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

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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 paragraph text

.

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 paragraph text

.

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: Formatted: ___GHG PARAGRAPH, No bullets or numbering

Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH, No bullets or numbering

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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.

* * * * * Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH, No bullets or numbering

Formatted: ___GHG PARAGRAPH, No bullets or numbering

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### (b) If a CEMS is used to measure CO 2 

### emissions or if you determined CO 2 

### 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 CO 2 

### 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 CO 2 

### 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 CO 2 

### 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	 ൅ ܨ ௦,௜ 

### 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.

F g,i 

### = Annual volume of gaseous fuel combusted (“(F g 

### )” in Equations Q-1, Q-4 and Q-7 of this section) for each process (scf).

MW i 

### = 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. Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

Formatted: where

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### F l,i 

### = Annual volume of the liquid fuel combusted (“(F l 

### )” included in Equation Q-1 of this section) for each process unit (gallons).

F s,i 

### = Annual mass of the solid fuel combusted (“(F
s 

### )” in Equation Q-1 of this section) for each process unit (metric tons).

ρ l,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.

ൌ ܫܨܰ ൭ ݈݁݁ݐܵ ൅ ݀݁݋ݎݐ݈݁ܿܧ ൅ ݁݁݀ܨ ൅ ݈ܽ݋ܥ ൅ ݊݋ܾݎܽܥ ൅ ݔݑ݈ܨ ൅ ݌ܽݎܵܿ ൅ ݊݋ݎܫ ൅ ܱ ෍

௡௜ ௡

௜ୀଵ



### ݎ݄݁ݐܱ ൅ ݁ݎܱ ൅ ൱

(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 di rect reduction furnace(s) (metric tons).

Coal = Annual mass of coal charged to the coke oven battery(s) (metric tons). Formatted: ___GHG PARAGRAPH

Formatted: Font: 12 pt

Formatted: Font: 12 pt

Formatted: Font: 12 pt

Formatted: Font: 12 pt

Formatted: Font: 12 pt

Formatted: Font: 12 pt

Formatted: Font: 12 pt

Formatted: _GHG equation, Tab stops: Not at
6.44"

Formatted: where

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### Feed = Annual mass of sinter feed mate rial charged to the sinter process(es) (metric tons).

Electrode = Annual mass of carbon electrode consumed in the EAF(s) (metric tons).

Steel in 

### = 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.

ൌ ݏݐܿݑ݀݋ݎܲ ∑ሺ ݈݁݁ݐܵ ൅ ܴ ൅ ܲ ௨௧௢ 

### ܯܰ ൅ ݊݋ݎܫ ൅ ݎ݁ݐܵ݅݊ ൅ ݇݁݋ܥ ൅ ݈ܵܽ݃ ൅ ௡ ୀଵ௜ 

### ሻ ሺ (-11Q .Eq

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).

Steel out 

### = 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 fro m the sinter process(es) (metric tons). Formatted: ___GHG PARAGRAPH

Formatted: where

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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 sect ion, calculated as specified in Equation Q-12 of

this section.

ܨܥ ௔௩௚ 

### ൌ ቀ ∑ ி ೒,೔ ∗ ಾೈ ೔ ಾೇ಴ ೙ ೔సభ ∗஼ ೒೑,೔ ∗଴.଴଴ଵାி ೗,೔ ∗஼ ೗೑,೔ ∗଴.଴଴ଵା	ி ೞ,೔ ∗஼ ೞ೑ ቁ

ி௨௘௟ 

### (Eq. Q-12)

Where:

CF avg 

### = 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.

C gf,i 

### = Average carbon content of the gaseous fuel used in each process, from the fuel analysis results (kg C per kg of fuel).

C lf,i 

### = Carbon content of the liquid fuel used in each process, from the fuel analysis results (kg C per gallon of fuel.

C sf 

### = 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 sect ion, calculated as specified in Equation Q-13

of this section.

ܫܥ ௔௩௚ 

### ൌ ൫ ∑ ேிூ ೔ ∗஼ ಿಷ಺೔ ೙ ೔సభ ൯

ேிூ 

### (Eq. Q-13)

Where: Formatted: ___GHG PARAGRAPH

Formatted: where

Formatted: ___GHG PARAGRAPH

Formatted: where

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### CI avg 

### = 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.

NFI i 

### = Annual mass of each non-fuel input used in Equation Q-10 (metric tons).

C NFIi 

### = 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:

CP avg 

### = 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.

Product i 

### = Annual mass of each product or byproduct used in Equation Q-11 (metric tons).

C p,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 paragrap h (b)(8) to read as follows :

a. Removing and reserving paragraph s (b)(6) and (b)(7). Formatted: ___GHG PARAGRAPH

Formatted: where

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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 CO 2 

### 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 paragraph text

.

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 CO 2 

### emissions, then you must report the

information listed in paragraphs (b)(1) through (18) of this section.

* * * * * Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH, No bullets or numbering

Formatted: ___GHG PARAGRAPH

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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)(1 e)(2 ), and (f )(2 ).

Subpart V—[AMENDED]

19. 20. Section 98.226 is amended by:

a. a. Revising the introductory paragraph text

.

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 N 2 

### O emission reduction for all production units combined.

Subpart X—[AMENDED]

20. 21. Section 98.246 is amended by:

a. a. Revising paragraph (a) introductory paragraph text and paragraph paragraphs

(a)(2) and(a)(4).

b. b. Adding paragraphs (a)(12) and (13).

c. c. Revising paragraph (b) introductory paragraph text

. Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH, No bullets or numbering

Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH, No bullets or numbering

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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. Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

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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 paragraph text

.

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 Formatted: ___GHG PARAGRAPH, No bullets or numbering

Formatted: ___GHG PARAGRAPH

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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 CO 2 

### concentration (volume or mole percent), the number of carbon containing

compounds other than CO 2 

### in the flare gas stream, and for each of the carbon containing

compounds other than CO 2 

### 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 ga s 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,

%CO 2 

### , 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. Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

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### (11) Indicate whether you use a measured value, a unit-specific emission factor, or a

default emission factor for CH 4 

### emissions. If you use a unit-specific emission factor for CH 4 

### ,

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 N 2 

### O emissions. If you use a unit- specific emission factor for N 2 

### O,

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 CO 2 

### 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 ca lculate 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). Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

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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 va lue, a unit-specific emission factor or a

default for CH 4 

### emissions. If you use a unit -specific emission factor for CH 4 

### , 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 N 2 

### O emissions. If you use a unit- specific emission factor for N 2 

### O,

report the basis for the factor.

(j) * * *

(5) If you use Equation Y–14 of this subpart, the basis for the CO 2 

### emission factor used.

(6) If you use Equation Y–15 of this subpart, the basis for the CH 4 

### 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 CO 2 

### 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 CH 4 

### emission factor used.

(k) * * * Formatted: ___GHG PARAGRAPH, Tab stops: 1.06", Left

Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

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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 CF 4 

### /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 interm ittent 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] Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

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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. Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

Formatted: ___GHG PARAGRAPH

Formatted: No underline

Formatted: ___GHG PARAGRAPH

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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 CO 2 

### 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

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

1 TECHNICAL MEMORANDUM

DATE : August 2013

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

FROM: Lisa Grogan-McCulloch

SUBJECT: Evaluation of Alternative V erification 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 repo rting 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 “Pro cess for Evaluating and Potentially Amending Part 98 Inputs to Emission Equations” (doc ket 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 requir e reporting of the “inputs to equations” data elements. This review ev aluates alternative veri fication methods for 25 subparts, based on the results of steps one through three of the f our-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 alte rnative verification approaches suggested in
comments to the Call for Information, which wa s 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 a lternative verification method that cons ists of an electronic verification tool developed by EPA, enhanced recordkeep ing 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 “inpu t to equation” data element is not listed explicitly in this
memorandum.

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

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 el ectronic reporting and verifi cation system for all subparts reporting under the program. The current veri fication approach for the GHGRP consists of requiring facility self-c ertification of the annual reports along with EPA conducting electronic

verification checks of the data en tered 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 re ported data other than inputs to emission equations (the reporting of which wa s deferred). For “supplier” subparts 2 

# (and starting in reporting year 2012 for subparts with inputs to emi ssion equations that were deferred until 2013),

these checks have been conducted us ing reported data that include the data needed to calculate outputs of the equations. Reporte rs under these subparts have been entering into e-GGRT the data needed to calculate the annual GHG quantities.

During reporting year 2010, EPA developed appr oximately 1,400 electronic verification checks to verify reported data. Based on these verifi cation checks, EPA followed up with facilities regarding potential da ta quality errors for approxima tely 2,360 of the approximately 6,700 facilities that reported in reporting year 2010. In reporti ng year 2011, EPA programmed an additional 1,000 checks into e-GGRT for the subpar ts that were reporting for the second year, expanding the number of checks to 2,400. EP A also programmed into e-GGRT, for 2011, approximately 1,300 checks for the newly-repor ting subparts. During re porting year 2011, EPA followed up with approximately 3,440 of the approximately 8,000 fac ilities that reported.

3.0 Evaluation of Alternative Verifica tion Methods Suggested by Commenters

The Call for Information notice specifically requested commenter i nput on alternative verification approaches that w ould not require reporting to EPA those data elements for which reporting may cause competitive harm. In res ponse, EPA received input from 16 commenters suggesting alternative verifica tion methods. The comments expr essed support for the following verification methods: (1) self -certification, (2) EPA complianc e 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.

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

3 to ensure that GHG emissions are being reporti ng accurately. EPA’s experience with reviewing the 2010 and 2011 reporting year annua l reports showed that there have been errors made in GHG emissions reporting. Self-certif ication alone would not addre ss these errors. As mentioned
in section 2.0 of this memorandum, EPA’s ve rification 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 signifi cantly 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 supplie rs in more than 40 source categories submit annual reports, it would be possible for EPA to vi sit only a very small fraction of the reporting facilities in any given year (e .g., even if EPA visited 100 fac ilities, that would be only 1.25 percent of reporters). Th erefore, relying solely on on-site compliance inspections as the primary method of verifying reported GHG data is impracti cal 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, th ere would be numerous other facili ties 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 co mpliance, EPA’s verification approach needs to collect enough information about al l 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 th eir 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 verificati on as an alternative verification method. EPA had previ ously considered third party ve rification, but decided against its implementation. Refer to EPA’s full rationale fo r not selecting third pa rty verification in the October 30, 2009 final rule (74 FR 56260). The followi ng is a summary of this rationale, as well as an explanation of why EPA has determ ined that these reasons still apply:

 The costs to the reporters of hiring third party verifiers woul d 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 woul d 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 ve rification, the vast majority of reporters did not subm it 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 gr eater 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 emissi ons as well as to gain a fuller picture of the emissions profile of the different sectors, a nd will continue to do so in the future.

 Developing the third party ve rification approach would re quire EPA to establish and develop emissions verification protocols and a system to qualify and accredit third party verifiers, as well as to devel op and administer a process to en sure that verifiers hired by reporting facilities do not have conflicts of interest. Such a program would require EPA
to review numerous individual conflict of in terest 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 cr iteria and systems described above to implement the GHGRP and ensure high quality emissions verificati on given the unique reporting requirements of the GHGRP. If EPA were to adopt third part y verification at this juncture, EPA would still have to develop the infras tructure described above to su pport 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 check s that EPA has developed over the first few years of the

program.

 Third party verification would pot entially 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 syst em, a facility would c ontract with a third party verifier and provide the ve rifier detailed data (by Marc h 31) so that the third party could perform the verification. The third party verifiers woul d 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 part y verifier would submit their findings to the facility with errors identified, which the f acility could then corre ct. For existing third party GHG verification programs, this verification process ge nerally 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 verificati on, EPA would review the data prior to release. EPA would then perform additional electronic checks on the full set of reported data because us ing such checks and statistical analyses on the entire data set would likely reveal inconsistencies and er rors in addition to those identified by the third party verifier. If EPA identified a dditional potential repor ting errors, EPA woul d then contact the facility to re solve the issue. It would be inefficient for EPA to perform verification of the data reported by faciliti es 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 conf licting, requests to the same facility regarding potential erro rs. As a result, this verification would likely be conducted after third party verification is complete. If EP A allows the same 4-month period it has in previous years for these EPA verification activ ities prior to publication/release of data,

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

5 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 f acilities to respond to both third party ve rifiers as well as
EPA.

3.4 Verification in EPA’s Toxic Release Inventory (TRI) Program

The TRI program requires annual facility leve l reporting of the amount of toxic chemicals released to the environment or otherwise manage d as wastes. Some aspects of the TRI program are similar to the GHGRP. The TRI reports co ntain a signed self- certification that the information reported is accurate. Each facility must also keep records of how emissions were calculated, including supporting ma terials, 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 electron ic submission of data,
conducts electronic data checks, and contact facilities to resolv e reporting errors. However, the TRI is a different type of program than th e GHGRP in that it does not require specific monitoring and calculation approach es, but rather requires that es timates 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 entere d 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 provide d 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 veri fication approaches of the two programs, direct applica tion 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 Altern ative Verification Method Using an Inputs Verification Tool, Enhanced Record keeping, 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 require ments. Section 4.1 describes th e inputs verification tool and options considered for implementation, secti on 4.2 describes the enhanced verification

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6 requirements, section 4.3 describes the addi tional 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 valu es. EPA considered using a similar approach whereby “inputs to equations” data elements woul d be entered into a new inputs verification tool within e-GGRT in such a way that the “inputs to e quations” 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 – De ployed 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 loca lly by the reporters. This option would be integrated without interrupting th e current electronic reporting pro cess. 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 persis ted (i.e., saved) within the e-GGR T database. Data entered into

the tool would be discarded when th e user’s session w ith e-GGRT ends.

If the reporter were to exit the inputs verification tool prio r to completing data entry or submitting their annual report, the tool would genera te a file of entered “inputs to equations” data elements, and allow the reporter to download th e file. The reporter w ould have the option to upload this file into the tool wh en 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 equa tions” data elements into the inputs verification
tool, the tool would calculate the annual GHG emissions valu es. The tool would use the following information in calculati ng these values: (1) “inputs to equations” data elements, (2) information entered into e-GGRT identifying whic h 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 a ppropriate reporting fields within e-GGRT. Reporters would then have the opportu nity to override the annual GHG emissions values calculated by the tool w ith their own calculated value.

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

7 Prior to annual report submittal, the inputs verifi cation tool would conduct a series of verification checks, including the following:

 Verification checks on the annual GHG emi ssion values calculated by the inputs verification tool. Reporters w ould have the opportunity to ove rride 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 equatio ns” data elements. For example, the tool would check: (1) whether all re quired data were entered; (2) whether entered “inputs to equations” data element values are within th e expected ranges for the data elements; and (3) whether expected relationships exist be tween 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 “input s to equations” data elements (i.e., using “real-time” checking), a nd other checks would be conducted after the reporter has entered all specified “inputs to eq uations” data elements, because some algorithms may compare certain “inputs to equations” da ta elements (e.g., produc tion quantity) to GHG emission values at the subpart or facility level. Also, prior to submittal of the annual report, the inputs verification tool would ge nerate a verification summary containing the results of the verification checks. The verification summary w ould specify whether any potential errors, as described above, were identified, without spec ifying any information about the “inputs to equations” data elements. The reporter would ha ve an opportunity to review the verification summary and make necessary revisions to the en tered “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 report er as a record of these data (refer to section

4.2 for further discussion of this recordkeeping requirement).

Inputs Verification Tool – Depl oyed 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 equa tions data, and storing the encrypted data at EPA. This option would have the same functiona lity as the inputs veri fication tool deployed within e-GGRT with the inputs to equations saved locally. The differe nce 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 repr esentatives 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, th e 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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8 the verification summary to EPA. Additionally, li ke 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 di scussion 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 i nputs to equations data elemen ts locally each time. Second, multiple users would be able to work on a fac ility’s inputs to equations concurrently or independently without needing to coordinate which downloaded i nputs to equation file is the
most recent file; however, as described below, mu ltiple 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 limitatio ns with the encryption option. On e 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 ma nner). 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 occurre d, users would have to re-enter i nputs to equations into the inputs verification tool, resulting in poten tially frustrated users. A third limitation is that if a reporter has multiple users and/or facilities, the users w ould have to coordinate the facility-specific encryption keys among various users across multiple f acilities. 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 a nd 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 ap plication that would need to

be installed on an individual user ’s desktop computer rather th an using a web-based system. In this option, EPA would develop a nd distribute a desktop, client-sid e application that reporters would download, install, and use locally. The us er would enter the inputs to equations data elements into the desktop application, which w ould perform the appropri ate verification checks and calculations. The application wo uld save inputs to the user’s local computer or drive and would transmit only the verification summary (whi ch, 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 ke pt by the reporter as a record of these data (refer to section 4.2 for further discussion of this reco rdkeeping requirement).

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9 A benefit of the desktop applica tion is that all inputs to equa tions data elements would be managed by users on their own comp uters and no inputs to equati ons data elements would be

transmitted to EPA.

EPA identified several challenges in herent 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 an nual 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 ea sily 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 a pplication, because it would require individual users to perform periodic application updates requiri ng administrative privileges. EPA would need to limit the number of updates in the software, which may limit EPA from improving the process as enha ncements are identified.

o Burden to users : The desktop application approach would likely increase the burden to
users. First, users would need to have ad ministrator privileges for their machines to install a local, client-side application. In many corporate environments, this is not possible without the assistance of inform ation 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 in stall the new version. Third,

it would be labor-intensive and difficult for EP A to develop a standal one application that replicates logic already presen t in e-GGRT, which assists us ers in such ways as guiding them to use the correct equations. This woul d most likely result in increased burden to users due to additional necessary foll ow-up by EPA during the post-submission verification process.

o Burden to EPA : Developing a desktop app lication 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 appl ications whenever the operating system changes. Also, if the software had probl ems or bugs, EPA would have to update the application, post the new release, and ask us ers to download and in stall it. There would be a significant increase in the burden to answ er questions that users typically experience during installation. Additionall y, 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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10 4.2 Description of Enhanced Recordkeeping Requirements

Because there may be more direct follow-up veri fication activities with the use of the inputs
verification tool, EPA considered two enhancements to recordk eeping requirements. First, EPA considered extending the record re tention period from 3 to 5 years. It would be important that

relevant records are available to EPA for follow- up activities with facil ities, including on-site audits if necessary, regarding potential errors, discrepancies, or questions. Should an EPA inspector visit a facility, it woul d be important to be able to ex amine not only the current year’s records, but also those from prev ious years, because previous ye ars’ data would provide year-toyear comparisons, which are useful for verifyi ng the current year’s data. A 5-year record retention period would ensure th e availability of relevant records for the follow-up activities

described above.

Second, EPA considered revisions to the record keeping 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 ha rd copy files. Requiring re porters to maintain an electronic or hard copy of the single file genera ted by the inputs verification tool (i.e., a file listing all “inputs to equations” data elements ente red into the tool) would ensure that EPA could readily access these data during site visits, en abling EPA to quickly a nd efficiently perform

calculations and data checks.

4.3 Description of Additional Reporting Requirements

To improve the efficiency of the data verificati on process under this alte rnative approach using the inputs verification tool desc ribed in section 4.1 and the enha nced recordkeeping described in section 4.2, EPA considered supplementing the information available to EPA under the GHGRP by requiring reporting of additiona l data. Certain additional data would enable EPA to perform
additional verification checks, th ereby minimizing the number of fo llow-up activities. Such data would provide information on the activity level at the facility, emission factors, characteristics of carbon-containing streams, and other process in formation that provide key information for verification (e.g., data confirming that emissions are appropriate for a given activity-level, and data estimating expected emissi ons based on data provided).

4.4 Review of Effectiveness of Using an Inputs Verification Tool, Enhanced Recordkeeping, and Additional Reportin g 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 electr onic 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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11  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 conduc t 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 th e 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 a pproach 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 dead line was deferred until 2013), except that eGGRT would not retain the “input s 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 cu rrently collected through the annua l report. By requiring use of the inputs verification tool, EPA would have th e additional certainty th at reported annual GHG

emissions values either were cal culated correctly (because the valu es 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 submitte d 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 veri fication once the annual report is submitted.

Once data verification within the inputs verifica tion 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 reporti ng requirements. Regarding any needed followup with facilities, the enhanced recordkeeping requirements descri bed 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

### E.O. 12866 Review – Draft – Do Not Ci te, Quote, or Release During Review

1 TECHNICAL MEMORANDUM

DATE : April August 2013

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

FROM: Lisa Grogan-McCulloch

SUBJECT: Analysis Evaluation of Alternative Verification Approaches For Greenhouse Gas Reporting Rule Subparts for whic h 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 (hereaf ter 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” (doc ket 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 th e 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 me thod 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.

### E.O. 12866 Review – Draft – Do Not Ci te, Quote, or Release During Review

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 repo rting 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” subparts 2 

### (and starting in reporting year 2012 for subparts with inputs to em ission 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 pa rty 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 qual ity 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 veri fication 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 t o the October 30, 2009 final rule that initiated the GHGRP, 74 FR 56260) that

self-certification is not sufficient to effectively 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 EP A 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 impracti cal 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 num erous 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 pa rty verifiers would be substantial, given the more than 8,000 reporters under the GHGR P. If EPA were to adopt third party verification at this juncture, the cost to th e 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 subm it 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 fo r 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 emi ssion 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 emission s 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 syst em, 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 part y verifiers would perform on-site visits to many of the facilities as part of the verifi cation process. After conducting the verification according to required protocols, the third pa rty verifier would submit their findings to the facility with errors identified, which the facility could then correc t. For existing third party GHG verification programs, this verification process generally takes three to six months. Given the large number of facilities (o ver 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 th e 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 co ntain a signed self-certification that the information reported is accurate. Each facility must also keep records of how emissions were calculated, including supporting materials, do cuments, 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 softwa re to facilitate electronic submission of data,
conducts electronic data checks, and contact faci lities 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 calculatio n 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 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 would result in a significantly reduced ability to verify emis sions and ensure compliance with the GHGRP.

4.0 Summary and Evaluation of an Alternat ive Verification Method Using an Inputs Verification Tool, Enhanced Recordk eeping, 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. Secti on 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 additi onal 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 woul d 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.

Such 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 c ould be deployed within

e-GGRT and with 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 th e 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 gene rate 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 us e the tool. This option would avoid facilities from needing to re-enter “inputs to equations” data el ements that were entered in previous e-GGRT

sessions.

After the reporter enters specified “inputs to equa tions” 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 whic h 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-fill ed into the appropriate reporting fields within

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7 e-GGRT. Reporters would then have the opportu nity to override the annual GHG emissions values calculated by the tool with their own calculated value.

Prior to annual report submittal, the inputs verifi cation 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 equa tions” 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 be tween 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 elem ents, 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 verifi cation 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-GG RT with Inputs Encrypted and Saved at EPA

EPA also considered having inputs to equations da ta 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 functiona lity 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 equation s 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 el ements to be kept by the reporter as a record of these data (refer to section 4.2 for further di scussion of this recordkeeping requirement)

EPA identified some benefits with the encryption opt ion. 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, mu ltiple 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 ma nner). 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 us ers 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 com puter rather than using a web-based system. In this option, EPA would develop and distribute a de sktop, 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 (w hich, as mentioned above, would not contain inputs to equations) to e-GGRT. Additionally, lik e 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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9 A benefit of the desktop application is that al l 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 inhe rent 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 a nnual production in th e 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, b ecause it would require individual users to perform periodic application updates requiri ng 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 informa tion 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, wh ich 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 fo llow-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 ve rification 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, be cause previous years’ data would provide year-toyear comparisons, which are us eful 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 record keeping 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, en abling EPA to quickly and efficiently perform

calculations and data checks.

4.3 Description of Additional Reporting Requirements

To improve the efficiency of the data verificatio n 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 th e 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) wo uld build on EPA’s experience with electronic reporting and verification during the first two ye ars of the GHGRP. As discussed in more detail in section 2.0, for reporting years 2010 and 2 011, 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 deadli ne 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 to ol, 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 verificatio n 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 reporti ng requirements. Regarding any needed followup with facilities, the enhanced recordkeeping requ irements 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 ap proach consisting of the use of the inputs verification tool, enhanced recordkeeping, and additional reporting as a viable alternative

a pproach to verifying data reported under the 2 5 subparts being evaluated in this memorandum

. This approach would ensure effective verif ication of reported emissions and compliance with the

program.

# Attachment K

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# 6560.50

ENVIRONMENTAL PRO TECTION 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 pot ential release of certain data that are inputs to emission

equations for which the reporting deadline was deferred until March 31, 2 015 while maintaining

the EPA’s ability to verify emissions and en sure 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 98

FEDERAL REGISTER ] to request a public hearing. If a hearing is requested, the EPA will

announce the details, including specif ic 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 Read ing Room, EPA West Building, Room

3334, 1301 Constitution Avenue, NW., Washingt on, 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 onlin e at http://www.regulations.gov , including any personal

information provided, unless the comment include s information claimed to be confidential

business information (CBI) or other information whose disclosure is re stricted by statute.

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# Page 3 of 98

Do not submit information that you consider to be CBI or otherw ise protected through

http://www.regulations.gov or email. Send or deliver inform ation identified as CBI to only the

mail or hand/courier delivery address listed a bove, 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 co ntact 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 automa tically 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 recomme nds that you include your name and other

contact information in the body of your comment a nd with any disk or CD–ROM you submit. If

the EPA cannot read your comment due to tec hnical difficulties and cannot contact you for

clarification, the EPA may not be able to cons ider your comment. Electr onic 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 li sted in the http://www.regulations.gov index.

Although listed in the index, some information is not publicly availabl e, e.g., CBI or other

information whose disclosure is re stricted by statute. Certain othe r material, such as copyrighted

material, will be publicly available only in ha rd 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 Constituti on 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 Read ing Room is (202) 566–1744, and the telephone

number for the Air Docket is (202) 566–1742.

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# Page 4 of 98

FOR FURTHER GENERAL INFORMATION CONTACT: Carole Cook, Climate Change

Division, Office of Atmospheric Programs (M C–6207J), Environmental Protection Agency,

1200 Pennsylvania Ave., NW., Washington, DC 20460; telephone number: (202) 343–9263; fax

number: (202) 343–2342; email address: GHGre porting@epa.gov. For technical information,

contact the Greenhouse Gas Re porting 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 greenho use 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 se parate copy of your comments, in addition to

the copy you submit to the official docket, to Ca role 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 woul d affect entities that must submit annual

greenhouse gas (GHG) reports under the Greenhous e 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 C AA section 307(d)(1)(V) (the pr ovisions of CAA section 307(d)

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apply to “such other actions as the Administra tor 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 boi lers, process heaters, incinerators, turbines, and in ternal combus tion engines. 321 Manufacturers of lumber and wood products. 322 Pulp and paper mills.
325 Chemical manufacturers.
324 Petroleum refineries an d manufacturers of coal products. 316, 326,
339 Manufacturers of rubber a nd 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 manuf acturing 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 manufactur ing facilities. Aluminum Production 331312 Primary al uminum production facilities
Ammonia Manufacturing 325311 Anhydrous and aqueous amm onia production facilities.

Cement Production 327310 Portland Ce ment manufacturing plants. Ferroalloy Production 331112 Ferroall oys manufacturing facilities.
Fluorinated GHG
Production 325120 Industrial gases manufacturing facilities.

Glass Production 327211 Flat gla ss 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 Hydr ogen production facilities
Iron and Steel
Production 331111 Integrated iron and steel m ills, 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 Nitr ic 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 transportati on of natural gas. 221210 Natural gas distribution facilities. 211 Extractors of crude petroleum and natural gas. 211112 Natural gas liquid ex traction 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 zi nc refining facilities. 331492 Zinc dust reclaiming facilities, recovering from scrap and/or alloying purchased metals. 311411 Frozen fruit, juice a nd vegetable manufacturing
facilities. 311421 Fruit and vegetable canning facilities.

Wastewater Treatment 1 

# 322110 Pulp mills. 322121 Paper mills. 322122 Newsprint mills. 322130 Paperboard mills. 311611 Meat processing facilities. 311411 Frozen fruit, juice a nd 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 ca tegories; however, these categories were evaluated in the EPA’s analysis of the potential impact from the releas e 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 s uppliers 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 rele vant 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 IN FORMATION CONTACT section.

Many facilities that are affected by 40 CF R part 98 have GHG emissions from multiple

source categories listed in Table 1 of this preamble.

Acronyms and Abbreviations

. The following acronyms and abbr eviations are used in this

document.

BAMM Best Available Monitoring Methods

CAA Clean Air Act

CO 2 

# 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 Indus try 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 Verificat ion Tool and Amendment to Reporting Requirements B. Proposed Revisions to Recordkeeping Requirements C. Proposed Requirement to Report Additional Data

IV. Confidentiality Determination for Prop osed New Data Elemen ts 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 Planni ng and Review and Executive Order 13563: Improving Regulation a nd 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 Coor dination with Indian Tribal Governments.
G. Executive Order 13045: Protection of Children from Environmental Health Risks and Safety
Risks

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H. Executive Order 13211: Actions that Significantly Affect En ergy 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 em ission factors. Reporte rs not using direct

measurement must use equations to calculate em issions. The inputs to these emission equations

often include process or producti on data that are specific to ea ch 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 e quations” are emission da ta. The CAA precludes

“emission data” from being tr eated as confidential.

Based on subsequent industry concerns regard ing the potential release of data elements

categorized as “inputs to emission equations,” th e EPA deferred reporting of these data elements

(see August 25, 2011 final action, 76 FR 53057) to a llow 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 record keeping requirements

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and an alternative verification a pproach for certain repor ters subject to 24 subparts for which the

reporting deadline for inputs to emission equa tions 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 th ese subparts, the designated inputs to emission equations

for which reporting was deferred to 2015 and di sclosure 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 i nputs (i.e., the inputs would

not be reported to EPA); instead, the tool would conduct certain chec ks (e.g., accuracy of

the inputs) at the time of data entry and generate a verifi cation summary. The verification

summary, which would be accessible to the EPA once the annual report is submitted,

would provide the EPA with informati on to conduct furt her verification if necessary.

 For reporters required to use th e inputs verification tool, chan ging the required format for

maintaining records of these inputs to emission equations.

 For reporters required to use th e inputs verification tool, le ngthening the record retention

period from 3 to 5 years for all records main tained 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 EP A’s verification purposes, and proposing

confidentiality determinations for the new data elements proposed to be reported.

1 

### Under this proposal, the inputs verificat ion 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 unde r sections 98.33(a)(5), 98.53(a)(2), and 98.223(a)(2) of Part 98) to calculate the reported GHG value, rath er than using "inputs to equations" data elements and the associated EPA-provided calculation methodolo gies 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 emissi on 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) ar e not proposed to be amended in this action. For

these inputs to equations, the de ferral 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 verificati on during the first 3 years of the GHGRP. By requiring the use

of the inputs verification tool, which would calculate GHG emissi ons 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 a dditional verification checks of the inputs to

emission equations that the i nputs verification tool would conduct (during th e process of

reporters entering data into the inputs verification tool ), would provide the EPA with information

necessary to conduct further verification once th e annual report is submitted. This alternative

verification approach, including the changes to the recordkeeping requirements and additional

reporting requirements, would provide an alterna tive 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 th e 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 EP A requires annual reporting of da ta from certain facilities and

suppliers above specified emission or quantity supplied thresholds. On July 7, 2010 (75 FR

39094) and subsequent proposal s (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) maki ng confidentiality determinations either categorically or on an

individual data elements basis. Refer to bot h 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 fo r a discussion of individual data element

confidentiality determinations. We have finaliz ed 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 ent itled 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 a ssigned to the “inputs to emission equations”

category are not entitled to confidential treat ment, 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 cat egorized as “inputs to emissi on 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 individu al circumstances of the facility).

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We determined that “these conc erns warranted an in-depth ev aluation 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 in formation (75 FR 81354) requesting additional

information to assist us in conducting our evalua tion. 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 specif ied 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 accompanyi ng 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 el ement assigned to the “inputs to emission

equations” category is alr eady publicly available.

 Step 2: For data elements assigned to the “i nputs to emission equatio ns” category that are

not publicly available, evaluate whether disclosure of the inform ation is likely to result in

substantial competitive harm.

 Step 3: For data elements assigned to the “i nputs to emission equatio ns” 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 “i nputs to emission equatio ns” 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 I nputs to Emission Equations for which Reporting

was Deferred to March 31, 2015.”

 “Evaluation of Competitive Harm from Di sclosure of ’Inputs to Equations’ Data

Elements Deferred to March 31, 2015”

 “Evaluation of Alternativ e Calculation Methods.”

 “Evaluation of Alternative Verification A pproaches 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 lis ted in Table 2 of this preamble. Table 2

includes most of the subparts with inputs to emission equations for whic h the reporting deadline

was deferred until 2015. Subpart W (Petroleum a nd Natural Gas Systems), subpart II (Industrial

Wastewater Treatment), and subpa rt C (only certain combustion un its associated with certain

electric generators connected and able to deli ver 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 ca tegories 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 th is table, the proposed

revision to the recordkeeping dur ation would apply to the reco rds 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—Mis cellaneous Uses of Carbonate

F—Aluminum Production V—Nitric Acid Production
G—Ammonia Manufacturing X—Petrochemical Production

H—Cement Production Y—Pe troleum 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—Tita nium Dioxide Production
Q—Iron and Steel Produc tion GG—Zinc Production

R—Lead Production TT—Industrial Waste Landfills

1 

## Certain proposed amendments affect other subparts not liste d 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 meeti ng 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 Pub lic Utilities Commissio n 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 preambl e to the 2009 final GHG reporting rule (74 FR

56260, October 30, 2009), CAA section 114(a)(1) provi des 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 vari ety of CAA provisions. See the preambles to the

proposed (74 FR 16448, April 10, 2009) and fi nal Part 98 (74 FR 56260, October 30, 2009) for

further information.

In addition, pursuant to sections 114, 301, a nd 307 of the CAA, the EPA is proposing

confidentiality determinations fo r the new data elements proposed in this notice. Section 114(c)

of the CAA requires that the EPA make publicly available in formation obtained under CAA

section 114 except for information (excluding em ission data) that quali fies for confidential

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treatment. The Administrator has determined that this action (Part 98 amendment and

confidentiality determinati ons) is subject to the provi sions of CAA section 307(d).

II. Summary of Proposed Changes to Part 98 Reporting and Recordkeeping Requirements

The EPA is proposing revisions to the reporti ng and recordkeeping requirements in Part

98 and alternative verification procedures that woul d apply to certain report ers subject to any of

the 24 subparts listed in Table 2 of this preambl e. Section II.A of this preamble summarizes a

proposed new requirement for these reporters if th ey 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 re quired to use an EPA-provided

electronic inputs verification tool to calculate emissions using da ta 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 verifi cation of reported GHG emissions data without

the need to collect “inputs to equations” data el ements for which disclosure concerns have been

identified. Section II.B of this preamble summar izes 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 summar izes proposed new repor ting requirements for

these reporters. Section III of this preamble expl ains 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 determinatio ns for proposed new data elements and the

EPA’s rationale for these determinations. Sectio n 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 s ubpart of Part 98, available du ring the public comment period for

this rulemaking. The “pilot” demonstrates how th e 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 ve rification tool would be depl oyed within e-GGRT and would

be integrated without interrupti ng the current electronic reporti ng process. While reporters enter

data into e-GGRT that are required to be reported in the annual re port, reporters w ould also enter

into e-GGRT (via the inputs veri fication tool) the “inputs to equa tions” 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 calcu late the equation output s, 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 require ment be removed. Accordingly, the EPA would

not have access to these “inputs to equations” data elements. In stead, the EPA would rely on the

verification summary, which would become acce ssible to the EPA when annual reports are

submitted, as a first step for conducting veri fication 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 s ubparts listed in Table 2 of this preamble. The EPA is proposing

that reporters use this tool starting with repor ting 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 ve rification tool is sp ecified in 40 CFR 98.5,

subpart A. Reporters would determine appli cability under this new requirement based on a

proposed new Table A-8 to Part 98, which lists a ll calculation methods unde r Part 98 for which

the inputs verification tool must be use d. Reporters calculating reported GHGs using a

calculation method specified in pr oposed Table A-8 would be requi red 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 reporti ng 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 “L ist of ‘Inputs to Equa tions’ 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 equati ons” data elements not represented in Table 3

of this preamble, the EPA is not amending thes e reporting requirements a nd 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 Report ing 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
Grid 2 

# 26 1 

# 26 1



# 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 report ers 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-f ired 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 faciliti es, the EPA is proposin g that the “inputs to

equations” data elements that are not being am ended in this action (a nd 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 repor ters prepare their re porting year 2014 annual

report via e-GGRT, they would be required to in clude these “inputs to equations” data elements

for reporting year 2014 as well as for all applicable previous repor ting years. The annual report,

including these “inputs to equations” data elem ents that would still be reported, would be

submitted via e-GGRT. This proposed approach woul d prevent facilities from being required to

revise, re-certify, and re-submit annual repo rts for each previous reporting year.

C. Proposed Changes to Recordkeeping Requirements

For each facility subject to a s ubpart listed in Table 2 of this preamble that uses “inputs to

equations” data elements to calculate and repor t GHGs (i.e., subject to using the proposed inputs

verification tool), the EPA is propos ing that the facility retain a ll records, includ ing records for

subparts not subject to the input s verification tool requirement, for 5 years, rather than the

current 3-year record retention period. In othe r 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 subp arts also be maintained for the 5 years. For

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example, if such a facility is required to report under both subp art C (in Table 2) and subpart HH

(not in Table 2), the facility would be require d 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 begi n with records for reporting year 2010.

Additionally, we are proposing that, at the time a reporter su bject 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 en tered “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 require d 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 report ers subject to using the prop osed 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 pres ented 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 N 2 

# O emission reduction for all production units combined.

G Ammonia Production Annual amm onia 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 clin ker production (metric tons).
Annual average clinker CO 2 

# emission factor for the facility, averaged across all kilns (metric tons
CO 2 

# /metric ton clinker produced).
Annual average cement kiln dust (CKD) CO 2 

# emission factor for the faci lity, averaged across all kilns (metric tons CO 2 

# /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 th e carbon mass balance method in 40 CFR 98.173(b)(1) to determine CO 2 

# 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 CO 2 

# emissions: The annual mass (metric tons) of all non-fuel material inputs (combined) specified in E quations 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 CO 2 

# 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, calcu lated 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 CO 2 

# 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 CO 2 

# emissions: The weighted average carbon c ontent 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 CO 2 

# 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 N 2 

# O 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 k iln: 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 fo r which you are not using Equation C-2c to calculate CO 2 

# 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 fo r which you are not using Equation C-2c to calculate CO 2 

# emissions: Ratio of the unit’s maximum rated heat input capacity to its design rated steam output cap acity (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 th is 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 a ddress those disclosure concerns, the EPA is

proposing an alternative verification approac h. This approach involves use of an inputs

verification tool and revisions to the reporting and recordkeepi ng 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 verifi cation tool and revisions to th e requirement to report certain

“inputs to equations” data elements. Secti on III.B addresses the proposed revisions to

recordkeeping requirements. Section III.C addresses the proposed addition of new reporting

requirements.

A. Proposed Inputs Verificat ion Tool and Amendment to Reporting Requirements

The EPA is proposing that facili ties 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 de ployed 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 requ ired 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 requi red starting in reporting year 2014, as further discussed in

Section III.A.2 of this preamble). As a built-in f eature 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 elemen ts, and generate a

verification summary. The tool w ould not retain the entered “input s 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-GGR T, 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 c onsists of electroni c verification checks

followed by direct follow-up with facilities. Fo r subparts where the re porting 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 repor ting of which was deferred). For

“supplier” subparts 5 

# (and starting in reporting year 2012 for subparts with inputs to emission

equations that were deferred unt il 2013), these checks have been conducted using reported data

that include the data needed to calculate outpu ts of the equations. Re porters under the supplier

subparts have been entering into e-GGRT th e data needed to calculate the annual GHG

quantities. For reporters under the direct emitter subparts listed in Ta ble 2 of this preamble that

4 

## Please see section III.A.3 of this preamble for a discussion on which “i nputs 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 us ed 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 va lues and verify these emission values. The

difference, however, is that these “inputs to equa tions” 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, reporte rs would log into e-GGRT. They would

enter data elements required for the annual repor t 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 w ould 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 verificati on tool would use entere d 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 verificati on tool prior to comp leting data entry or

submitting their annual report, the tool would genera te a file of entered “inputs to equations” data

elements, and allow the reporter to download the f ile. 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-e nter “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 woul d 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 th is 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 va lues 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 va lues calculated by the tool with their own

calculated value. If the reporter chose to override th e calculated value, this would be reflected in

the verification summary.

Prior to annual report submittal, the inputs verification tool woul d conduct a series of

verification checks, in cluding the following:

 Verification checks on the annual GHG emi ssion values calculated by the inputs verification tool. As mentioned above, reporte rs would have the opportunity to override
and revise the value calculat ed by the tool; however should this occur, the tool would note a discrepancy, which would prompt the EP A for further review after the reporter submits the annual report.

 Verification checks on entered “inputs to equatio ns” data elements. For example, the tool would check: (1) whether all re quired data were entered; (2) whether entered “inputs to equations” data element values are within th e expected ranges for the data elements; and (3) whether expected relationships exist be tween 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 el ements (e.g., production quantity) to GHG emission

values at the subpart or facility level.

Also, prior to submittal of the annual report, the inputs verifi cation tool would generate a

verification summary containing th e results of the verification ch ecks. The verification summary

would specify whether any potential errors, as described above, we re identified, without

specifying the “inputs to equations” data elemen ts. The reporter would have an opportunity to

review the verification summary and make n ecessary revisions to the entered “inputs to

equations” data elements and the reported data elements.

For example, a facility subject to subpart G that manufactures a mmonia using liquid and

solid feedstocks is currently required under 40 CFR 98.76(b)(1) to report annual CO 2 

# process

emissions for each ammonia manufacturing unit. Cu rrently, 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, a nd 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 veri fication tool to calculate annual CO 2 

# process

emissions. In calculating this value, the to ol would use Equations G-2, G-3, and G-4 of

Part 98 and the 48 “inputs to equa tions” data element entries.

 Once the annual CO 2 

# process emissions value is calcu lated, the inputs verification tool

would automatically conduct verification check s 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 en tered values for carbon content of liquid

feedstock is within the expected range fo r carbon content of liquid feedstock (based

on industry-wide data). The tool woul d conduct similar comparisons for the 12

entered “inputs to equations” data elemen ts for the carbon content value for solid

feedstock.

- Algorithm check comparing each of the 12 ente red 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 “input s to equations” data elements for the

quantity of solid feedstock. This type of ch eck would be conducte d after the reporter

has entered all “inputs to equations” data elements.

 Prior to annual report submittal, the inputs ve rification tool would automatically generate

a verification summary, which would flag any potential errors, providing an opportunity

for the reporter to review the verificat ion summary and revise entered data. The

verification summary would note if the repo rter 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-gener ate the verification summary prior to annual

report submittal. The EPA would access the ve rification summary (i.e., the same final

summary viewed by the reporter) following annual report submittal and certification.

 The inputs verification tool would also gene rate 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 ma intained as a record in a format currently

allowed under Part 98 (see 40 CFR 98.3(g), subp art A). Refer to Section III.B of this

preamble for further discussion of this propos ed amendment and the EPA’s rationale for

requiring this record.

The EPA has developed a “pilot” inputs veri fication tool for one subpart, subpart X,

which will be posted at http://www.epa.gov/ghgr eporting/reporters/tr aining/rulepilot.html , to

demonstrate how the tool would work within e-GGR T, 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 el ements. 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 Altern ative Verification Approaches

for Greenhouse Gas Reporting Rule Subparts fo r 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 addi tional 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 electr onic 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 ve rification 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 ve rification approach for facilities using “inputs

to equations” data elements to calculate repor ted GHGs under the subparts listed in Table 2 of

this preamble using the additional checks that w ould be conducted by the inputs verification tool.

During the first 3 years of the Greenhouse Ga s Reporting Program (GHGRP), the EPA has had

success developing and using an el ectronic reporting and verifi cation system for all subparts

reporting under the program. During reporti ng year 2010, the EPA developed approximately

1,400 electronic verification checks to verify repo rted 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, re sulting in approximately 2,300 f acilities resolvi ng verification

issues by responding to the EPA and/or resubmitt ing 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 th e 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 w ith approximately 3,440 of the

approximately 8,000 facilities that reported, resulting in approx imately 3,000 facilities resolving

their verification issues.

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For example, for subpart H, the EPA verifi es reported GHG emissi ons data using: (1)

reported cement production data and (2) public ly available industry data on GHG emissions.

Using these data, the EPA has established rang es 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 en suring the completeness and accuracy of reported data and reducing the

costs of compliance monitoring.

The inputs verification tool desc ribed in Section III.A.1 of this preamble utilizes the same

approach that the EPA currently uses for calcu lating and verifying data submitted for supplier

subparts (and starting in repor ting 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 generate d by the inputs verification tool, along with

verification summaries that are currently genera ted using data currently collected through the

annual report. By requiring use of the inputs veri fication tool, the EPA wo uld 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 eq uations” 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 lik ely 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” da ta elements were submitted to the EPA, this

approach would facilitate verification by identi fying 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 requ irement for “inputs to equations” data elements

for which our four-step evaluation did not iden tify 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 re porting would be retained and these proposed

new reported data elements would allow th e EPA to conduct additional verification and

minimize the number of follow-ups with facilities. Lastly, for th e 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 necessa ry follow-up with reporters. For the reasons

stated above, the EPA has determined that the pr oposed 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 identif ied in Table 2 of this preamble and is a

reasonable alternative to collec ting “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 verifi cation tool is designed to be used concurrently with annual

reporting by facilities. By the time the EPA ta kes 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 th ese years, given that most of th e data would likely already have

been published and that the use of best availa ble monitoring methods (BAMM) for these sectors

is relatively low during these years, the EPA ha s determined that the added benefit does not

outweigh the burden that would be required for faci lities to use the input s verification tool for

years prior to reporting year 2014.

3. Reporting of 440 “Inputs to Equations” Data El ements Would Not Be Necessary With the

Proposed Verification Approach.

The EPA is proposing to remove the reporti ng 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 Se ction III.A.2 of this preamble, the EPA would no

longer need to rely on th e collection of these “i nputs to equations” data elements to verify

emissions under those subparts. Not having these da ta 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 us ed to calculate the GHG emissions for each unit, operation, process,

6 

## For 23 of these “inputs to equations” data elements, we ar e 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 th e 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 record keeping sections of each subpart would improve

the clarity of the specific reco rds that would be required to be retained. Because the EPA is

proposing that the “inputs to equatio ns” data elements that would not be reported must be kept as

records in the format generated by the inputs ve rification tool (i.e., fi le 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 addi tional specificity within the recordkeeping

requirements of each subpart would improve the cl arity 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 reporti ng years 2010 through 2013, as appropr iate.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 No t To Be Reported” (refer to Docket ID No.

EPA–HQ–OAR–2010-0929) for a comple te 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 a ll “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 addr essed 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 prev ious reporting years (i .e., reporting years 2010

through 2013). Based on “Step 2” of our evaluati on 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 verificatio n, including conduct yea r-to-year comparisons,

thereby reducing the amount of di rect follow-up required with facilities. For the reason stated

above, collecting these data elements, even in th e absence of collecting al l “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 eval uation; however, the EPA is not retaining these

reporting requirements. The EPA determined that th ese 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 equatio ns” 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 th e 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 th e sum of the nameplate capacities for all such electric generators is greater than or e qual 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 equatio ns” 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 annua l report and they would

be accessible by the EPA once the reporter submits th e annual report. In order to ease the burden

on facilities, for reporting years prior to re porting 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 prepar e 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 app licable 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 re vise, re-certify, and re -submit annual reports for

reporting years 2010, 2011, 2012, and 2013.

The proposed revisions to the current reporti ng 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 reporte d GHGs. However, as noted in Table 2, we are

not proposing to amend the reporting requirements fo r 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 be en 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 subjec t 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 genera tors 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 fu rther 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 th e purpose of monitoring, calculating, and

reporting emissions. The EPA rec ognizes that stationary combus tion units grouped in these

reporting configurations could in clude both combustion units associ ated 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 combus tion units not associated with electric

generators (excluding generators co nnected to combustion units subjec t to subpart D of this part).

In these cases where combustion units are groupe d, the EPA has determined that there would be

no disclosure concerns with re porting of “inputs to equations” data elements for the grouped

combustion units. In reporting combined data fo r multiple units including those associated with

an electric generator and subject to reporting under this proposed acti on, no unit-specific data

would be revealed. Furthermore, should a facility not wish to disclose a ggregated data, it would

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have the option to calculate a nd 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 provi de detailed information about the concern, as well as whether

reporting on an individual unit basi s 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 inform ation in order to maintain the requirements

in these paragraphs.

The EPA requests comment on the proposed in puts verification tool and verification

approach, and the associated revision to the curre nt 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 re tention period and record format requirements

would be sufficient to allow the EPA to perform data verifica tion. 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 cu rrent format would be adequate for our

verification process. For example, we c onsidered 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 th e 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 ac tivities under this a lternative 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 repor ters 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, incl uding on-site audits if necessa ry, regarding po tential errors,

discrepancies, or questions. Should an EPA inspector visit a facility, it woul d be important to be

able to examine not only the cu rrent year’s records but those from previous years as well,

because previous years’ data would provide ye ar-to-year comparisons, which are useful for

verifying the current year’s data . A 5-year record retention peri od would ensure the availability

of relevant records for the follo w-up activities describe d above. The EPA is proposing that this

5-year record retention require ment begin with records for re porting year 2010, as discussed in

Section III.A.2 of this preamble.

For reporters subject to using the proposed i nputs verification tool, the EPA is proposing

to extend the record rete ntion period not only for the subparts listed in Table 2 of the preamble,

but also for other subparts that apply to reporte rs subject to a subpart in Table 2. Under this

proposal, any such facility subject to both a subp art listed in Table 2 of this preamble and a

subpart not listed in Table 2 would be require d to maintain all reco rds 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 unde r subpart HH (not in Table 2),

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the facility would be re quired to maintain all records required under both subparts for 5 years.

The EPA is proposing these provisions for two reas ons. First, the EPA determined that during a

site visit, if questions arise regarding the accuracy of an “input s to equations” data element, it

may be necessary to examine other non-input re cordkeeping information, such as a monitoring

plan or recordkeeping information in a differe nt 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 th e same record retention durati on for all subparts, as proposed,

would simplify recordkeeping and thereby mini mize the chance for recordkeeping errors.

In addition, the EPA is proposi ng revisions to the recordkeep ing format for “inputs to

equations” data elements. Currently, reporters ha ve the option to mainta in records of their

“inputs to equations” data elements in one or mo re electronic or hard copy files. The proposed

record format revision would requi re reporters to maintain an el ectronic or hard copy of the

single file generated by the proposed inputs verifi cation tool, listing all “i nputs to equations” data

elements entered into the tool. This proposed r ecord 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 vis its. All other records re quired 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 discusse d 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 re quirements, 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 amende d. 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 verifica tion 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 th e 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 th at certain reporters us ing 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. Thes e data elements are qua ntities that provide

information on the activity level at the facility, emission factors used, characteristics of carboncontaining streams, and other process informa tion that would provide key information for

verification, including co nfirming that emissions are appropria te for a given activity-level and

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estimating expected emissions based on data prov ided. These new data reporting elements would

also enable the EPA to better understand the follo wing 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 th e industry sect or; and (3) the

factors influencing GHG emissions.

The EPA is proposing to add six new equatio ns (Equations Q-9 through Q-14 of part 98)

to subpart Q to specify how to cal culate 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. Refe r to the following Section IV of this preamble

for the EPA’s proposed confidentiality determinat ions for the proposed new data elements.

IV. Confidentiality Determination for Propos ed 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 dete rminations, 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 ca tegory 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 el ements, 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 th at 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 Material s Consumed that are Not Inputs to Emission

Equations” data categories are enti tled to confidential treatment b ecause the data do not meet the

definition of “emission data” in 40 CF R 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 E quations” data category and 10

new data elements be assigned to the “Raw Mate rials Consumed that are Not Inputs to Emission

Equations” data category, as shown in Table 5 of this preamble, thereby applying the categorical

confidentiality determinations ma de for these categories in the 2011 final CBI rule (i.e., they are

CBI) to the proposed new reporting elements assigne d to these categories. This proposal is not

changing, nor soliciting comment on, the categorical confidentiality determ ination for these two

data categories. Should the EPA fi nalize the category assignment fo r these data elements, all new

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data elements assigned to these categories woul d be considered to be entitled to confidential

treatment.

Table 5. Data Elements Proposed to Be A ssigned 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)(1 8) 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 (inmetric 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 I nputs 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 CO 2 

# 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 CO 2 

# emissions: The annual mass (metric tons) of all non-fuel material inputs (combined) specified in Equations Q-1 through Q-7, calculated asspecified 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 CO 2 

# 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 CO 2 

# emissions: The weighted average carbon content of all gaseous, liquid, and solid fuels (combined) included in Equation Q-9, calculated asspecified 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 CO 2 

# emissions: The weighted average carbon content of all non-fuel inputs to all furnaces (combined) included in Equation Q-10, calculated asspecified 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 CO 2 

# 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 (inmetric 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 CO 2 

# 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 Equa tions” category and one proposed

new data element to the “Unit/Process Static Ch aracteristics that are Not Inputs to Emission

Equations” category. In the 2011 fina l CBI rule, the EPA determined that the data elements in

these categories are not “emission data” (as defi ned 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 de terminations, the EPA

considered the confidentiality criteria at 40 CF R 2.208, in particular whether release of the data

is likely to cause substantial harm to th e business’s competitive position. See 40 CFR

2.208(e)(1). The EPA is therefore following the sa me approach in this action for the proposed

new reporting elements assigne d to these two categories.

Table 6 of this preamble lists the data elements the EPA pr oposes 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 Determin ations for Proposed New Data Elements Assigned to the “Unit/Process Operating Char acteristics That Are Not Inputs to Emission Equations” and “Unit/Process ‘Static’ Charac teristics 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 N 2 

## O
emission
reduction for all production
units
combined. Not CBI The annual facility percent N 2 

## O
reduction could not be used to calculate adipic acid production.
The level of N 2 

## O 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 CO 2 

## emission
factor for the facility, averaged
across all kilns (metric

tons CO 2 

## /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)
CO 2 

## emission
factor for the facility, averaged
across all kilns (metric

tons CO 2 

## /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 N 2 

## O
emission
reduction for all production Not CBI The annual facility percent N 2 

## O
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 N 2 

## O 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 N 2 

## O
emission reduction information is already publicly available (seedocket 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 usingEquation 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 usingEquation 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 usingEquation 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 No t Inputs to Emission Equations” Data Category

AA - Pulp and Paper 40 CFR 98.276(m)(2) For each
chemical ND 1 

## 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 usingEquation C2c to
calculate CO 2 

## 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 da ta 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 da ta categories, please pr ovide specific comments

identifying which proposed new data elements may be mis-assigned along with a detailed

explanation of why you believe them to be inco rrectly assigned and in which data category you

believe they best belong.

Second, for those data elements included in Ta ble 6 of this preamble and assigned to the

two direct emitter data categories without cate gorical confidentiality determinations, the EPA

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seeks comment on the individual confidentiality de terminations 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 su ch 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 memora ndum, “Impacts Analysis of the Proposed 2015

Inputs Proposal,” available in EP A 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 da ta 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 (includi ng 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 el ements 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 verificati on tool and we have estimated a cost of

approximately $66 per facility, or $379,000 for the fi rst year for all affect ed facilities. During

their first session using the propos ed inputs verification tool, re porters would need to spend

approximately 1 hour becoming familiar with ho w the tool operates within e-GGRT. The

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proposed new requirement to use the inputs verifi cation tool would not re sult 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 informa tion about this cost estimate,

refer to the memorandum “Assessment of Cost Impacts of 2015 Inputs Proposal – Revisions to

Reporting, Recordkeeping, and Verification Re quirements under the Greenhouse Gas Reporting

Program” and the supporting statement for this proposed information collection request,

“Supporting Statement, Environmental Protec tion Agency: Revisions to Reporting and

Recordkeeping Requirements, and Proposed Confidentiality Determinations under the

Greenhouse Gas Reporting Program, OMB cont rol 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 previ ously required to be

reported under Part 98 (see Section II.D of this preamble for furt her discussion of this proposed

amendment), to be reported by f acilities in certain subparts that are required to use the proposed

inputs verification tool. Of thes e 26 data elements, nine data elements are related to annual

production or raw material usage, which are collec ted by a facility as a ro utine part of conducting

business. For these data elements, we are not pro posing 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 em issions 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 su bparts is $80,000. These costs represent the cost

for all affected faciliti es in the first year.

B. Additional Impacts of the Proposed Amendments

The proposed confidentiality determinations fo r 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 Execu tive Order Reviews

A. Executive Order 12866: Regulatory Planni ng and Review and Executive Order 13563:

Improving Regulation a nd Regulatory Review

Under Executive Order 12866 (58 FR 51735, October 4, 1993), this action is a

“significant regulatory action” b ecause 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 recommendati ons have been documented in the docket for

this action.

B. Paperwork Reduction Act

This action proposes to amend reporting and recordkeeping requireme nts and verification

procedures for the GHGRP. In addition, the EPA is proposing confidentiality determinations for

the proposed new data elements in this ac tion. The proposed amendments to the reporting

requirements in the source category-specific subpar ts are not anticipated to result in significant

burden for reporters. The new data elements requir ed 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 change s to the reporting re quirements in each

subpart are detailed in the memorandum “I mpacts Analysis of the Proposed 2015 Inputs

Proposal” (see Docket ID N o. EPA-HQ-OAR-2010-0929). The Of fice of Management and

Budget (OMB) has previously approved the inform ation collection requirements for 40 CFR part

98 under the provisions of th e 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 regul ations in 40 CFR are listed in 40 CFR

part 9.

C. Regulatory Flexibility Act (RFA)

The RFA generally requires an agency to prep are a regulatory flexibil ity analysis of any

rule subject to notice and comment rulemaking requirements under the Administrative Procedure

Act or any other statute unless the agency certifie s that the rule will not have a significant

economic impact on a substantial number of sm all entities. Small en tities include small

businesses, small organizations, a nd 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 sm all business as defined by the Small Business

Administration’s (SBA) regula tions at 13 CFR 121.201; (2) a sm all governmental jurisdiction

that is a government of a city, c ounty, 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 do minant in its field. After considering the

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economic impacts of today’s proposed amendments on small entities, I cert ify that this action

will not have a significant economic impact on a s ubstantial number of sm all entities. The small

entities directly regulated by these proposed rule amendments include sm all businesses across all

sectors of the economy encompassed by Part 98, small governmental jurisdictions, and small

non-profits. We have determined that these facil ities will experience impacts of roughly a firstyear cost of $66 per facility for learning new pr ocedures for the verification tool and an annual

cost of $100 per facility for the recordkeeping and reporti ng of 26 new data elements.

Although these proposed rule amendments w ill 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 potent ial impacts of the propos ed 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 privat e sector in any one year. Thus, the proposed

amendments and confidentiality determinations ar e not subject to the requirements of sections

202 or 205 of UMRA.

This rule is also not subject to the requi rements of section 203 of UMRA because it

contains no regulatory require ments that might significantly or uniquely affect small

governments. This action proposes to amend reporting and recordkeeping requirements and

verification procedures for the GHGRP. In a ddition, the EPA is proposing confidentiality

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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 implicat ions. 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 propos ed amendments and confidentiality

determinations apply to facilities that direc tly 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 leve ls (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 propos ed 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 Or der 13132, and consistent with EPA policy to promote

communications between the EPA and State and lo cal governments, the EPA specifically solicits

comments on this proposed action fro m State and local officials.

F. Executive Order 13175: Consultation and Coor dination with Indian Tribal Governments.

This proposed action does not have tribal im plications, as specified in Executive Order

13175 (65 FR 67249, November 9, 2000). The proposed amendments and confidentiality

determinations apply directly to facilities that directly em it greenhouses gases or that are

suppliers of GHGs. They would not have tribal implications unless the tribal entity owns a

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facility that directly emits GHGs above threshol d levels (such as a landfill or large combustion

device). Relatively few tribal facilities would be affected. T hus, 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 Executiv e Order has the potential to in fluence 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 En ergy 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 likel y to have a significant adverse effect

on the supply, distribution, or use of energy. Pa rt 98 relates to mon itoring, reporting, and

recordkeeping and does not impact energy supply, distribution, or use. Th is action proposes to

amend reporting and recordkeeping requirements and verification pr ocedures for the GHGRP. In

addition, the EPA is proposing confidentiality determinations for the proposed new data

elements in this action. These proposed amendmen ts 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 Nati onal 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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consensus standards in its regul atory activities unless to do so would be inconsistent with

applicable law or otherwise impractical. Volunt ary consensus standards are technical standards

(e.g., materials specifications, test methods, samp ling procedures, and busi ness 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. It s main provision directs federal ag encies, to the greatest extent

practicable and permitted by law, to make environmental justice part of their mission by

identifying and addressing, as appropriate, disp roportionately high and adverse human health or

environmental effects of their programs, policie s, 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 advers e human health or environmen tal 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 becau se the proposed amendments address information

collection and reporting a nd verification procedures.

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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, ti tle 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 paragra phs (c)(4)(vii), (d)(3)( v), (g) introductory

text, and (g)(2)(i) to read as follows:

§ 98.3 What are the general monitoring, rep orting, 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 faci lity is not required to report th e data elements specified in

Table A-7 to this subpart for cale ndar years 2010 through 2013 until March 31, 2015. D 

# ata

elements specified in Table A-7 to this s ubpart 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 cr iteria specified in §

98.36(f) of this part, report any facility operati ng data or process information used for the GHG

emission calculations.

* * * * *

(g) Recordkeeping . An owner or operator that is re quired to report GHGs under this part

must keep records as specified in this paragraph. Except as otherw ise 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 wh ich the record was generated. The records shall be kept in an

electronic or hard-copy format (a s appropriate) and reco rded 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 fo r 5 years from the date of submission of the

annual GHG report for the reporting year in whic h 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 record s 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 method s 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 representa tion for a facility or supplier must be

submitted electronically in accordan ce 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 calculati on 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 Elemen ts 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 fo r 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 Equa tion 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 cond ucting weekly sampling).

II 98.356(d)(3) All (if cond ucting weekly sampling).

II 98.356(d)(4) Only weekly aver age 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 averag e pressure (if conducting weekly sampling).

1 

# Required to be reported only by stationary fu el 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 stat ionary fuel combustion source contains at least
one combustion unit connected to a fuel-fired elec tric 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 subjec t 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 genera tors 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 calcula ting the anode effect minutes per cell-day (AEM) and slope coefficients (SCF 4), 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, th e 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 calcula tion, if applicable, as spec ified 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 bur n-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 combusti on sources (e.g., individual units, aggregations of units, common pipes, or common stacks) mee ting 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 (exclu ding generators that are connected to combustion units subject to subpart D of this part); and (2 ) the stationary fuel combustion s ource is located at a facility for which the sum of the nameplate capacities for all su ch 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 un its, common pipe, or common stack).

(b) * * *

(9) * * *

(iii) The annual CH 4 

# and N 2 

# O 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 CO 2 

# e.

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(iv) For each stationary fuel combustion s ource 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 combus ted in the unit during the report year.

* * * * *

(c) * * *

(2) * * *

(ix) For each type of fuel lis ted in Table C–2 of this subpa rt that was combusted during

the report year in the units sharing the common stack or duct during the report year, the annual

CH 4 

# and N 2 

# O mass emissions from the units sharing the common stack or duct, expressed in

metric tons of each gas and in metric tons of CO 2 

# e.

(x) For each stationary fuel combustion s ource 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, fo r 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, gallo ns 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 sour ce 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 ye ar. Express the quantity

of each fuel combusted during the measurement peri od in short tons for solid fuels, gallons for

liquid fuels, and scf for gaseous fuels.

* * * * *

(C) For each stationary fuel combustion sour ce that meets the criteria specified in

paragraph (f) of this section, the high heat values used in the CO 2 

# 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 re quired. 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 sour ce that meets the criteria specified in

paragraph (f) of this section, if Equation C–2c of this subpart is used to calculate CO 2 

# mass

emissions, report the total quantity (i.e. , pounds) of steam produced from MSW or solid fuel

combustion during each month of the reporting ye ar, 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 CO 2 

# 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 sour ce that meets the criteria specified in

paragraph (f) of this section, th e quantity of each type of fuel combusted in the unit or group of

units (as applicable) during each month of the repor ting year, in short tons for solid fuels, gallons

for liquid fuels, and scf for gaseous fuels.

* * * * *

(C) For each stationary fuel combustion sour ce 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 valu e of each parameter. If multiple values of a

parameter are obtained in a given month, repor t the arithmetic averag e value for the month.

Express carbon content as a decimal fraction for so lid 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 sour ce that meets the criteria specified in

paragraph (f) of this section, the annual averag e HHV, when measured HHV data, rather than a

default HHV from Table C–1 of this subpart, are used to calculate CH 4 

# and N 2 

# O emissions for a

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

* * * * *

(ix) * * *

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(D) For each stationary fuel combustion sour ce 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 CO 2 

# per mmBtu.

(E) For each stationary fuel combustion s ource that meets the criteria specified in

paragraph (f) of this section, the annual av erage 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 sour ce that meets the criteria specified in

paragraph (f) of this section, th e 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 reporti ng 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 combus tion 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 lo cated at a facility for which the sum of the

nameplate capacities for all electric generators specified in paragr aph (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 a ll production lines combin ed (metric tons).

(n) Annual percent N 2 

# O emission reduction for all production units combined.

* * * * *

Subpart F—[AMENDED]

8.Section 98.66 is amended by:

a. Removing and reserving pa ragraphs (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 (o r 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 pr oduction (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 para graphs (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 m onthly clinker production from each kiln.

(16) Annual clinker prod uction (metric tons).

(17) Annual average clinker CO 2 

# emission factor for the faci lity, averaged across all kilns

(metric tons CO 2 

# /metric ton clinker produced).

(18) Annual average CKD CO 2 

# emission factor for the facil ity, averaged across all kilns

(metric tons CO 2 

# /metric ton CKD produced).

Subpart K—[AMENDED]

11. Section 98.116 is amended by:

a. Removing and reserving paragrap hs (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 determin ation of carbon content for each material

included for the calculation of annual process CO 2 

# emissions for each EAF (e.g. , supplier

provided information, analyses of re presentative 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 reservi ng paragraph (b)(2);

c. Revising paragraphs (b)(6), (b )(7), and (b)(8)( i) through (iv);

d. Removing and reserving para graphs (b)(8)(v) and (b)(9);

e. Revising paragraph (c)(1);

f. Removing and reserv ing paragraph (c)(2);

g. Revising paragraph (d); and

h. Removing and reserving paragrap hs (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 unde r paragraph § 98.123(b)(1).

* * * * *

(6) The chemical formula of each fluorine-contai ning reactant that is fed into the process.

(7) The chemical formula of each fluorine-c ontaining product produced by the process.

(8) * * *

(i) The chemical formula of each fluorine-c ontaining product that is removed from the

process and fed into the destruction device.

(ii) The chemical formula of each fluorine- containing by-product th at is removed from

the process and fed into the destruction device.

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(iii) The chemical formula of each fluorine-c ontaining 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 leng th of time the data were missing, and the

method used to estimate the missing data.

(2) Estimates of the missing data for all mi ssing 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) a nd (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 paragrap hs (d)(1), (d)(5), and (e)(1).

The revisions read as follows:

§ 98.156 Data reporting requirements.

* * * * *

(d) If the HFC–23 concentration measured pur suant to §98.154(l) is greater than that

measured during the performance test that is th e 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 appropr iate, and paragraphs (c)

through (e) of th is 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 paragr aphs (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 CO 2 

# 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 (v i) of this section

aggregated for all process units for which CO 2 

# 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 t ons) of all gaseous, liquid, and solid fuels (combined) used

in process units for which CO 2 

# 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	൅ ܨ ௦,௜ 

# 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 un its where fuel is used.

F g,i 

# = Annual volume of gaseous fuel combusted (“(F g 

# )” in Equations Q-1, Q-4 and Q-7 of this section) for each process (scf).

MW i 

# = 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.

F l,i 

# = Annual volume of the liquid fuel combusted (“(F l 

# )” included in Equation Q-1 of this section) for e ach process unit (gallons).

F s,i 

# = Annual mass of the solid fuel combusted (“(F
s 

# )” in Equation Q-1 of this section) for each process unit (metric tons).

ρ l,i = 

# Density of the liquid fuel (kg/gallon).

0.001 = Conversion factor fr om kg to metric tons.

(ii) The annual mass (metric tons) of all non-f uel material inputs (combined) specified in

Equations Q-1 through Q-7 of this section, calcu lated as specified in Equation Q-10 of this

section.

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ൌ ܫܨܰ ∑ሺ ݈݁݁ݐܵ ൅ ݀݁݋ݎݐ݈݁ܿܧ ൅ ݁݁݀ܨ ൅ ݈ܽ݋ܥ ൅ ݊݋ܾݎܽܥ ൅ ݔݑ݈ܨ ൅ ݌ܽݎܵܿ ൅ ݊݋ݎܫ ൅ ܱ ௡௜ ௡ ௜ୀଵ 

# ൅

݁ݎܱ ൅ ݎ݄݁ݐܱ .Eq ( (-10Q

Where:

NFI = Annual mass of all non-fuel inputs (t o all process unit types) specified in Equations Q-1 through Q-7 of th is section (metric tons).

n = Number of process units, all process types.

O = Annual mass of greenball (taconite) pe llets fed to the taconite furnace(s) (metric tons).

Iron = Annual mass of molten iron charge d to the basic oxygen furnace(s) plus
annual mass of direct reduced iron char ged 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 char ged to the basic oxygen furnace(s) and EAF(s) (metric tons).

Carbon = Annual mass of carbonaceous mate rials (e.g., coal, coke) charged to the basic oxygen furnace(s), EAF(s), and dire ct 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 mate rial charged to the sinter process(es) (metric tons).

Electrode = Annual mass of carbon electrode consumed in the EAF(s) (metric tons).

Steel in 

# = Annual mass of molten steel charged to the decarburizat ion vessels (metric tons).

Ore = Annual mass of iron ore or iron or e pellets fed to the direct reduction furnace(s) (metric tons).

Other = Annual mass of other material s charged to the direction reduction furnace(s) (metric tons).

(iii) The annual mass (metric tons) of a ll solid and liquid pro ducts and byproducts

(combined) specified in Equations Q-1 through Q-7 of this secti on, calculated as specified in

Equation Q-11 of this section.

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ൌ ݏݐܿݑ݀݋ݎܲ ∑ሺ ݈݁݁ݐܵ ൅ ܴ ൅ ܲ ௨௧௢ 

# ܯܰ ൅ ݊݋ݎܫ ൅ ݎ݁ݐܵ݅݊ ൅ ݇݁݋ܥ ൅ ݈ܵܽ݃ ൅ ௡ ୀଵ௜ 

# ሻ ሺ (-11Q .Eq

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).

Steel out 

# = 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 fr om 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 mate rials 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:

CF avg 

# = Weighted average carbon content of all gaseous, liquid, and solid fuels included in Equation Q-9 of th is 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.

C gf,i 

# = Average carbon content of the gaseous fuel used in each process, from the fuel analysis results (kg C per kg of fuel).

C lf,i 

# = Carbon content of the liquid fuel used in each process, from the fuel analysis results (kg C per gallon of fuel.

C sf 

# = 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 al l non-fuel inputs to all process units

(combined) included in Equation Q-10 of this se ction, calculated as specified in Equation Q-13

of this section.

ܫܥ ௔௩௚ 

# ൌ ൫ ∑ ேிூ ೔ 

### ∗஼ ಿಷ಺೔ ೙ ೔సభ 

### ൯

ேிூ 

# (Eq. Q-13)

Where:

CI avg 

# = Weighted average carbon content of all non-fuel inputs to all process units included in Equation Q-10 of th is section (weight fraction).

n = Number of non-fuel inputs to all process units as used in Equation Q-10.

NFI i 

# = Annual mass of each non-fuel input used in Equation Q-10 (metric tons).

C NFIi 

# = 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 (combine d) 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:

CP avg 

# = 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.

Product i 

# = Annual mass of each product or byp roduct used in Equation Q-11 (metric tons).

C p,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 se ction (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 determinati on of carbon content for each material used

for the calculation of annual process CO 2 

# emissions using Equation R–1 of this subpart for each

smelting furnace (e.g. , supplier provided info rmation, 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 CO 2 

# 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 N 2 

# O emission reduction for all production units combined.

Subpart X—[AMENDED]

21. Section 98.246 is amended by:

a. Revising paragraph (a) introductory te xt 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 methodol ogy in § 98.243(c), you must report the

information specified in paragraphs (a)(1) thr ough (a)(13) of this se ction for each type of

petrochemical produced, re ported 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 ga seous 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 t ons) of each product included in Equations X1, X-2, and X-3 of § 98.243 of this subpart.

(b) If you measure emissions in accordan ce 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 t ons) 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 reserv ing 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 para graphs (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 CO 2 

# concentration (volume or mole pe rcent), the number of carbon containing

compounds other than CO 2 

# in the flare gas stream, and for each of the carbon containing

compounds other than CO 2 

# in the flare gas stream:

* * * * *

(9) If you use Equation Y–3 of this subpa rt, the number of SSM events exceeding

500,000 scf/day.

(10) The basis for the value of the fracti on 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 flar e 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,

%CO 2 

# , 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 va lue, a unit-specific emission factor, or a

default emission factor for CH 4 

# emissions. If you use a unit-specific emission factor for CH 4 

# ,

report the basis for the factor.

(12) Indicate whether you use a measured va lue, a unit-specific emission factor, or a

default emission factor for N 2 

# O emissions. If you use a unit-specific emission factor for N 2 

# O,

report the basis for the factor.

(13) If you use Equation Y–11 of this subpart , the number of rege neration 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 th e 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 CO 2 

# emissions in the tail gas wa s used in Equation Y–12. If

so, then report:

(i) The value of the correction.

(ii) If the following data ar e not used to calculate the r ecycling correction factor, report

the information specified in paragraphs (h )(5)(ii)(A) thr ough (C) of this section.

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(A) The annual volume of recycl ed 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 po rtion of the dust is recy cled, or none of the dust

is recycled).

* * * * *

(7) Indicate whether you use a measured va lue, a unit-specific emission factor or a

default for CH 4 

# emissions. If you use a unit-specific emission factor for CH 4 

# , report the basis for

the factor.

(8) Indicate whether you use a measured va lue, a unit-specific emission factor, or a

default emission factor for N 2 

# O emissions. If you use a unit-specific emission factor for N 2 

# O,

report the basis for the factor.

(j) * * *

(5) If you use Equation Y–14 of th is subpart, the basis for the CO 2 

# emission factor used.

(6) If you use Equation Y–15 of th is subpart, the basis for the CH 4 

# 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 th is subpart, the basis for the CO 2 

# emission factor used

and the basis for the carbon emission factor used.

(9) If you use Equation Y–17 of th is subpart, the basis for the CH 4 

# 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 CF 4 

# /kg-mole gas,

wet basis).

* * * * *

(l) * * *

(5) The annual volumetric flow discharged to the atmosphere (in sc f), and an indication

of the measurement or estimation method, annual average mole fraction of each GHG above the

concentration threshold or ot herwise required to be reporte d and an indication of the

measurement or estimation method, and for intermitte nt vents, the number of venting events and

the cumulative venting time.

(m) * * *

(3) For uncontrolled blowdown systems re porting 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 gr eater, 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 a nd 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 contai n 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 Li quor, 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 info rmation 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 ea ch chemical recovery combustion unit for

which you are not using Equation C-2c to calculate CO 2 

# emissions, report the information

specified in paragraphs (m)(1) and (2) of this section.

(1) The annual mass of steam generated (lb st eam), individually for each fossil fuel type

and for spent liquor solids.

(2) The ratio of the unit’s maximum rated he at input capacity to its design rated steam

output capacity (mmBtu/lb steam), individually fo r 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 reserv ing paragraph (c)(3)(i);

b. Revising paragraph (c)(3)(ii); and

c. Removing and reservi ng paragraph (c)(3)(iii).

The revisions read as follows:

§ 98.466 Data reporting requirements.

* * * * *

(c) * * *

(3) * * *

(ii) The year of the data used in Equa tion 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 th e Greenhouse Gas Reporting Program. This action

addresses concerns about the potential release of certain data that are inputs to emission

equations whose for which the reporting deadline was deferred until March 31, 2015 while

maintaining the EPA’s ability to verify emissi ons 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 100

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, EP A Docket Center (EPA/DC), Mailcode

6102T, Attention Docket ID No. EP A–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 onli ne 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. Formatted: Line spacing: Double

Formatted: Underline

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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: Dock et 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 co ntact 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 tec hnical 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 encr yption, 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 re stricted 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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### Page 4 of 100

FOR FURTHER GENERAL INFORMATION CONTACT: Carole Cook, Climate Change

Division, Office of Atmospheric Programs (MC–6207J), Environmenta l 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 greenhou se gas reporting rule Web site at

http://www.epa.gov/climatechange/emissions/ghgrule making.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 Formatted: Indent: First line: 0"

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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 331 312 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 ma nufacturing 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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Cate g or y NAICS Exam p les 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 Productio n 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 dist ribution 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 faci lities, recovering from scrap and/or alloying purchased metals. 311411 Frozen fruit, juice and vegetable manufacturing
facilities. 311421 Fruit and vegetable canning facilities.

Wastewater Treatment 1 

### 322110 Pulp mills. 322121 Paper mills. 322122 Newsprint mills. 322130 Paperboard mills. 311611 Meat processing facilities.

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Cate g or y NAICS Exam p les 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 ca tegories; however, these categories were evaluated in the EPA’s analysis of the potential impact from the releas e 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 su ppliers 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 IN FORMATION 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

CO 2 

### 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 Planni ng 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 C oordination 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 Significan tly 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 (GHGR P) 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 em issions. The inputs to these emission equations

often include process or production data that ar e 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,” th e 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 equati ons 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 reta in 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 gene rate a verification summary. The verification

summary, which would be accessible to the EPA once the annual report is submitted,

would provide the EPA with informati on to conduct further verification if necessary.

 For reporters required to use the inputs veri fication tool, changing the required format for

maintaining records of these inputs to emission equations.

 For reporters required to use the inputs verifi cation 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, ra ther than using "inputs to equations" data elements and the associated EPA-provided calculation methodologies to calculate the reported GHG value. Formatted: Line spacing: Double

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 For reporters required to use the inputs veri fication 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 fi rst 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 abilit y to identify facilities that potentially reported

emissions incorrectly. This, combined with a dditional 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 verificati on 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 altern ative 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 fr om 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 in puts 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 a ssigned 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 evaluati on. 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 speci fied 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 In puts 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 co mpetitive harm if disclosed, evaluate potential alternative

calculation methods. Formatted: Line spacing: Double

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 Step 4: For data elements assigned to the “inputs to emission equations” category that are

likely to cause substantial co mpetitive 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 evaluate d 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 Pr ogram (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 li sted 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 subpart II

(Industrial Wastewater Tr eatment), 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 Part 98 is not included in

Table 2 because reporting of inputs to emission eq uations 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 no t 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). Refe r 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—Ph osphoric 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, th e 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 40
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 Pub lic 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 pream ble 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 el ements 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 preambl e. 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 veri fication 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 summ arizes 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 expl ains 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 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 e

GGRT, 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 elec tronic 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 veri fication 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 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), an d 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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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
Grid 2 

### 26 1 

### 26 1



### 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 part Part 98 and applies to only certain reporters under subpart C of part Part 98.

2 The reporting requirements applicable to certain statio nary 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 fo llowing criteria: (1) the stationary fuel combustion source
contains at least one combustion unit connected to a fuel-f ired 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 co mbined 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 facilitie s, 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 repor ters prepare their reporting year 2014 annual

report via e-GGRT, they would be required to in clude these “inputs to equations” data elements

for reporting year 2014 as well as for all applicab le 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 w ould prevent facilities from being required to

revise, re-certify, and re-submit annual re ports 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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subparts not subject to the input s 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 genera ted 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 require d 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 Subpar ts 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 N 2 

### O emission reduction for all production units combined.

G Ammonia Production Annual amm onia 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 CO 2 

### emission factor for the facility, averaged across all kilns (metric tons
CO 2 

### /metric ton clinker produced).
Annual average cement kiln dust (CKD) CO 2 

### emission factor for the facility, averaged across all kilns (metric tons CO 2 

### /metric ton CKD produced).
P Hydrogen Production Na me 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 CO 2 

### 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 CO 2 

### 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 CO 2 

### 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 CO 2 

### 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 CO 2 

### 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 CO 2 

### 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 N 2 

### O 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 CO 2 

### emissions: Annual mass of steam generated (l b 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 CO 2 

### emissions: Ratio of the unit’s maximum rated heat input capacity to its design rated steam output cap acity (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 veri fication 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 “input s 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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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 c onsists 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 discussi on on which “inputs to equations” data elements the EPA is proposing that the reporting requirements be removed.

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“supplier” subparts 5 

### (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 us ed 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 va lues 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, repo rters 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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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-ent er “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 valu es: (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 (notinto 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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 Verification checks on the annual GHG emission values calculated by the inputs verification tool. As mentioned above, report ers 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 equa tions” 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 be tween 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 elem ents (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 CO 2 

### process

emissions for each ammonia manufacturing unit. Curr ently, 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 a ll four “inputs to equations” data elements).

 The reporter would use the inputs verification tool to calculate annual CO 2 

### 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 CO 2 

### 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 eq uations” 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 ente red 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 Formatted: Line spacing: Double

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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-gener ate 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 gene rate 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), su bpart 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/ghg reporting/reporters/training/rulepilot.html , to

demonstrate how the tool would work within e-GG RT, 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 Formatted: Underline

Formatted: Underline

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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 Ve rification 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, us ing 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 facilitie s to verify data currently reported via e-GGRT.

The EPA is proposing to supplement the curr ent verification approach for facilities

reporting using “inputs to equations” data elements to calculate reported GHGs under the

subparts listed in Table 2 of this preamble us ing the additional checks that would be conducted

by the inputs verification tool. During the firs t 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 Formatted: Line spacing: Double

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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 2 011, 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 verifi es 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 bot h 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 Sec tion 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 ve rification tool, the EPA would have the additional

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certainty that reported annual GHG emissions valu es 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” da ta elements were submitted to the EPA, this

approach would facilitate verification by identi fying 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 iden tify 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 Section III.B of this preamble, the EPA is pro posing 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” Da ta 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 “i nputs to equations” data elements to verify

emissions under those subparts. Not having these da ta 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 el ements 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 un it, operation, process,

and activity, categorized by fuel or material t ype” 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 reco rdkeeping 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 elemen ts 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 must 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 fo r 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 comp arisons, thereby reducing the amount of direct

follow-up required with faciliti es. 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 beca use 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., in dividual 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 fu el-fired electric generator that has been granted access by the Public Utilities Commission to deliver power to the local or regional elect ric 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 th e 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 equation s” 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 report ing 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 previo us 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 repor ting 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 co mbustion 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 combus tion 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 genera tors 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 combus tion 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 info rmation 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 descri bed 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 2,0 00 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 a udits 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 r ecords but those from previous years as well,

because previous years’ data would provide ye ar-to-year comparisons, which are useful for

verifying the current year’s data. A 5-year record retention period would ensure the availability Formatted: Line spacing: Double

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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 r ecords for reporting year 2010, as discussed in

Section III.A. 1 2 of this preamble.

For reporters subject to using the proposed i nputs 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 su bpart 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 re asons. 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 reco rdkeeping information, such as a monitoring

plan or recordkeeping information in a differen t 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 mini mize 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 verifi cation 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 prop osed 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 un der 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 th at 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 informa tion that would provide key information for

verification, including confirming that emission s are appropriate for a given activity-level and

estimating expected emissions based on data provi ded. 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 collecti ng 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 determinat ions 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 Material s Consumed that are Not Inputs to Emission Formatted: Line spacing: Double

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Equations” data categories are en titled to confidential treatment b ecause the data do not meet the

definition of “emission data” in 40 CF R 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 Mate rials 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 assign ed 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 woul d 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 Equa tions” Data Categories
Subpart Proposed Cita tion Data Element “Production/Throughput Data that are Not Inputs to Emission Equations” Data Category

G - Ammonia Production 40 CFR 98.76( c b )(14) Annual ammonia production (metric tons). 40 CFR 98.76( d 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)(1 8) Annual quantity (metric tons) of lime product sold, by type.

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Subpart Proposed Cita tion 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 (inmetric 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 CO 2 

### 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 Does 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 e)(6)(ii ) If you use the carbon mass
balance method in 40 CFR 98.173(b)(1) to determine CO 2 

### emissions: The annual mass (metric tons) of all non-fuel material inputs (combined) specified in Equations Q-1 through Q-7, calculated asspecified in a new Equation Q10 in the proposed rule
amendments.

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Subpart Proposed Cita tion Data Element 40 CFR 98.176( i)(3 e)(6)(iii ) If you use the carbon mass
balance method in 40 CFR 98.173(b)(1) to determine CO 2 

### 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 e)(6)(iv ) If you use the carbon mass
balance method in 40 CFR 98.173(b)(1) to determine CO 2 

### emissions: The weighted average carbon content of all gaseous, liquid, and solid fuels (combined) included in Equation Q-9, calculated asspecified in a new Equation Q12 in the proposed rule
amendments. 40 CFR 98.176( i)(5 e)(6)(v ) If you use the carbon mass
balance method in 40 CFR 98.173(b)(1) to determine CO 2 

### emissions: The weighted average carbon content of all non-fuel inputs to all furnaces (combined) included in Equation Q-10, calculated asspecified in a new Equation Q13 in the proposed rule
amendments.

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Subpart Proposed Cita tion Data Element 40 CFR 98.176( i e )(6 )(vi ) If you use the carbon mass
balance method in 40 CFR 98.173(b)(1) to determine CO 2 

### 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 (inmetric 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 CO 2 

### 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 Ch aracteristics 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 define d 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 elemen ts 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’ Charac teristics 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 N 2 

### O
emission
reduction for all production
units
combined. Not CBI The annual facility percent N 2 

### O
reduction could not be used to calculate adipic acid production.
The level of N 2 

### O 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 CO 2 

### emission
factor for the facility, averaged
across all kilns (metric

tons CO 2 

### /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)
CO 2 

### emission
factor for the facility, averaged
across all kilns (metric

tons CO 2 

### /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 N 2 

### O
emission
reduction for all production
units
combined. Not CBI The annual facility percent N 2 

### O
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 N 2 

### O 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 N 2 

### O
emission reduction information is already publicly available (seedocket 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 usingEquation 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 usingEquation 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 usingEquation 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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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 usingEquation C2c to
calculate CO 2 

### 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. ND 1 

### 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 cate gorical 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, report ers 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 th e 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 th e inputs verification t ool 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 Re quirements under the Greenhouse Gas Reporting

Program” and the supporting statement for th is 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 pro posing 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 emi ssions 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 Planni ng 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 calcul ated 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 prep are 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 certifi es that the rule will not have a significant

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economic impact on a substantial number of small entities. Small entities include small

businesses, small organizations, a nd small governmental jurisdictions.

For purposes of assessing the impacts of the today’s proposed rule amendments on small

entities, “ small entity ” is defined as: (1) A 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. 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 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. The We 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 continues Although these proposed rule amendments will not have a significant

economic impact on a substantial number of sm all entities, the EPA none theless 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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We continue to be interested in the potential impacts of the proposed rule amendments on

small entities and welcomes 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 ar e 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 mi ght significantly or uniquely affect small

governments. This action proposes to amend reporting and recordkeeping requirements and

verification procedures for the GHGRP. In addi tion, 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 States , or

on the distribution of power and responsibilitie s among the various levels of government, as

specified in Executive Order 13132. The proposed amendments and confidentiality

determinations apply to facilities that direct ly 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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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 State and local governments, the EPA specifically

solicits comments on this proposed action from state 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 th at 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 threshol d 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 Significan tly Affect Energy Supply, Distribution, or Use

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This proposed action is not a “significant en ergy 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. Volunt ary consensus standards are technical standards

(e.g., materials specifications, test methods, sa mpling 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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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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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 re quired to report the data elements specified in

Table A-7 to this subpart for calendar years 2010 through 2013 until March 31, 2015. D 

### ata

elements specified in Table A-7 to this subpa rt 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 proc ess 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 st acks) subject to subpart C of part 98 that meet both of the following criteria: (1) the sta tionary 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 combus tion 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 genera tors 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 calcu lating 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) meet ing both of the following criteria: (1) the

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stationary fuel combustion source contains at le ast one combustion unit connected to a fuel-fired electric generator electric (exclu ding generators that are connected to combustion units subject to subpart D of this part); and (2) the stationary fu el combustion source is located at a facility for which the sum of the nameplate capacities for all su ch 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, fo r each stationary fuel combustion source (e.g.,

individual unit, aggregation of units, common pipe, or common stack).

(b) * * *

(9) * * *

(iii) The annual CH 4 

### and N 2 

### O 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 CO 2 

### e.

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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

CH 4 

### and N 2 

### O mass emissions from the units sharing the common stack or duct, expressed in

metric tons of each gas and in metric tons of CO 2 

### 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 CO 2 

### 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 re quired. 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 subpa rt is used to calculate CO 2 

### 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 CO 2 

### 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 co mbusted in the unit or group of

units (as applicable) during each month of the reporti ng 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 ca rbon 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 so lid fuels, kg C per gallon for liquid fuels, and

kg C per kg of fuel for gaseous fuels. Express th e 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 averag e HHV, when measured HHV data, rather than a

default HHV from Table C–1 of this subpart, are used to calculate CH 4 

### and N 2 

### O 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 CO 2 

### per mmBtu.

(E) For each stationary fuel combustion s ource that meets the criteria specified in

paragraph (f) of this section, the annual aver age 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 fu el combusted during the

reporting year, in lb, gallons, or scf, as appropriate.

* * * * *

(f) Each stationary fuel combustion source (e .g., individual unit, ag gregation 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 gran ted access by the Public Utilities Commission to

deliver power to the local or regional electr ic 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 electr ic generators specified in para graph (f)(1) of th is 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 N 2 

### O 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 intr oductory 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 ( c b)(14 ) and ( d 15 ).

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).

( d 15 ) 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 CO 2 

### emission factor for the facilit y, averaged across all kilns

(metric tons CO 2 

### /metric ton clinker produced).

(18) Annual average CKD CO 2 

### emission factor for the facility, averaged across all kilns

(metric tons CO 2 

### /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 CO 2 

### 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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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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(b) If a CEMS is used to measure CO 2 

### 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 CO 2 

### 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 gase ous, liquid, and solid fuels (combined) used

in process units for which CO 2 

### 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	 ൅ ܨ ௦,௜ 

### 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.

F g,i 

### = Annual volume of gaseous fuel combusted (“(F g 

### )” in Equations Q-1, Q-4 and Q-7 of this section) for each process (scf).

MW i 

### = 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.

F l,i 

### = Annual volume of the liquid fuel combusted (“(F l 

### )” included in Equation Q-1 of this section) for each process unit (gallons).

F s,i 

### = Annual mass of the solid fuel combusted (“(F
s 

### )” in Equation Q-1 of this section) for each process unit (metric tons).

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ρ l,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.

ൌ ܫܨܰ ∑ሺ ݈݁݁ݐܵ ൅ ݀݁݋ݎݐ݈݁ܿܧ ൅ ݁݁݀ܨ ൅ ݈ܽ݋ܥ ൅ ݊݋ܾݎܽܥ ൅ ݔݑ݈ܨ ൅ ݌ܽݎܵܿ ൅ ݊݋ݎܫ ൅ ܱ ௡௜ ௡ ௜ୀଵ 

### ൅

݁ݎܱ ൅ ݎ݄݁ݐܱ .Eq ( (-10Q

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 di rect 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 mate rial charged to the sinter process(es) (metric tons).

Electrode = Annual mass of carbon electrode consumed in the EAF(s) (metric tons).

Steel in 

### = 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.

ൌ ݏݐܿݑ݀݋ݎܲ ∑ሺ ݈݁݁ݐܵ ൅ ܴ ൅ ܲ ௨௧௢ 

### ܯܰ ൅ ݊݋ݎܫ ൅ ݎ݁ݐܵ݅݊ ൅ ݇݁݋ܥ ൅ ݈ܵܽ݃ ൅ ௡ ୀଵ௜ 

### ሻ ሺ (-11Q .Eq

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).

Steel out 

### = 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 fro m 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 sect ion, 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:

CF avg 

### = 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.

C gf,i 

### = Average carbon content of the gaseous fuel used in each process, from the fuel analysis results (kg C per kg of fuel).

C lf,i 

### = Carbon content of the liquid fuel used in each process, from the fuel analysis results (kg C per gallon of fuel.

C sf 

### = 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 sect ion, calculated as specified in Equation Q-13

of this section.

ܫܥ ௔௩௚ 

### ൌ ൫ ∑ ேிூ ೔ ∗஼ ಿಷ಺೔ ೙ ೔సభ ൯

ேிூ 

### (Eq. Q-13)

Where:

CI avg 

### = 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.

NFI i 

### = Annual mass of each non-fuel input used in Equation Q-10 (metric tons).

C NFIi 

### = 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:

CP avg 

### = 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.

Product i 

### = Annual mass of each product or byproduct used in Equation Q-11 (metric tons).

C p,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 CO 2 

### emissions using Equation R–1 of this subpart for each

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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 CO 2 

### 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 N 2 

### O 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 paragrap hs (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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### Page 93 of 100

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)(i i), (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 CO 2 

### concentration (volume or mole percent), the number of carbon containing

compounds other than CO 2 

### in the flare gas stream, and for each of the carbon containing

compounds other than CO 2 

### 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 ga s 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,

%CO 2 

### , 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 CH 4 

### emissions. If you use a unit-specific emission factor for CH 4 

### ,

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 N 2 

### O emissions. If you use a unit- specific emission factor for N 2 

### O,

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 CO 2 

### 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 ca lculate 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 va lue, a unit-specific emission factor or a

default for CH 4 

### emissions. If you use a unit -specific emission factor for CH 4 

### , report the basis for

the factor.

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### Page 96 of 100

(8) Indicate whether you use a measured value, a unit-specific emission factor, or a

default emission factor for N 2 

### O emissions. If you use a unit- specific emission factor for N 2 

### O,

report the basis for the factor.

(j) * * *

(5) If you use Equation Y–14 of this subpart, the basis for the CO 2 

### emission factor used.

(6) If you use Equation Y–15 of this subpart, the basis for the CH 4 

### 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 CO 2 

### 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 CH 4 

### 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 CF 4 

### /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 interm ittent 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 CO 2 

### 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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### Page 99 of 100

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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### Page 100 of 100

# Attachment M

### *** 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- ]**

**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 125 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 125
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 125

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 125 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 125 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.

### *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 7 of 125
**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.

### *** E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review *** Page 9 of 125
**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

CO 2 

### carbon dioxide

CBI confidential business information

CEMS Continuous Emission Monitoring System

CFR Code of Federal Regulations

e-GGRT Electronic Greenhouse Gas Reporting Tool

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

Page 10 of 125 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

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

Page 11 of 125 **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

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

Page 12 of 125 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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Page 13 of 125

 

### 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.

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

Page 14 of 125 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

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

Page 15 of 125 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).

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

Page 16 of 125 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).

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

Page 17 of 125 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.

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

Page 18 of 125

 

### “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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Page 19 of 125 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 amendments would 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
Grid 2 

### 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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Page 20 of 125
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

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

Page 22 of 125 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.

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

Page 23 of 125 “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

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

Page 24 of 125 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 Grid 2 

### 26 1 

### 26 1



### 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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Page 25 of 125

**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.

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

Page 26 of 125

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)

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

Page 27 of 125 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 N 2 

### O 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.

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

Page 28 of 125 **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 CO 2 

### emission factor for the facility, averaged across all kilns (metric tons

CO 2 

### /metric ton clinker produced). Annual average cement kiln dust (CKD) CO 2 

### emission factor for the facility, averaged across all kilns (metric tons CO 2 

### /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 CO 2 

### 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 CO 2 

### 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.

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

Page 29 of 125 **Subpart Subpart Name New Data Element Description** If you use the carbon mass balance method in 40 CFR 98.173(b)(1) to
determine CO 2 

### 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 CO 2 

### 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 CO 2 

### 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 CO 2 

### 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 N 2 

### O emission reduction for all production units
combined.

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

Page 30 of 125 **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 perMMscf) (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 CO 2 

### 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 CO 2 

### emissions: Ratio of the unit’s maximum rated heat input capacity to its design rated steam output

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

Page 31 of 125 **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

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

Page 32 of 125 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?

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

Page 33 of 125 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” subparts 4 

### (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.

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

Page 34 of 125 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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Page 35 of 125 “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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Page 36 of 125 (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 CO 2



### 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

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

Page 37 of 125 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 CO 2 

### 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 CO 2 

### 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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Page 38 of 125 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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Page 39 of 125 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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Page 40 of 125 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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Page 41 of 125 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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Page 42 of 125 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]: P lease explain why the
record retention time needs to be lengthened.

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Page 43 of 125 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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Page 44 of 125 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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Page 45 of 125 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 **r** eporting 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.

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

Page 46 of 125 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.

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

Page 47 of 125 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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Page 48 of 125 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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Page 49 of 125 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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Page 50 of 125 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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Page 51 of 125

 

### 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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Page 52 of 125 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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Page 53 of 125 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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Page 54 of 125 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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Page 55 of 125 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).

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

Page 56 of 125 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).

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

Page 57 of 125 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

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

Page 58 of 125 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

t ons). 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

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

Page 59 of 125 **Subpart Proposed Citation Data Element**

calculate GHG
emissions: Name and annual quantity (in metric tons) of eachcarbon-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 (metrictons) 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 CO 2 

### 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

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

Page 60 of 125 **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 CO 2 

### 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 CO 2 

### 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 CO 2 

### emissions: The weighted average

carbon content of all gaseous, liquid, and

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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 CO 2 

### 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 CO 2 

### 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.

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

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 CO 2 

### 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

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

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

N 2 

### O
emission
reduction

for all productio
n units
combined. Not CBI The annual facility percent N 2 

### O reduction

could not be used to calculate adipic acid production. The level

of N 2 

### O 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

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

Page 64 of 125

**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

CO 2 

### emission

factor

for the facility, averaged

across all kilns (metric

tons

CO 2 

### /metri

c ton
clinker produced)

. CBI T his 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) CO 2 

### emission

factor

for the facility, averaged

across all kilns (metric

tons

CO 2 

### /metri

c ton CKD produced)

. CBI T his data element could provide information

a bout the efficiency of the operation, which
would result in competitive disadvantage

**.**

V –
Nitric
Acid
Producti

on 40 CFR 98.226(q) Annual percent

N 2 

### O
emission
reduction

for all productio
n units Not CBI The annual facility percent N 2 

### O 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 N 2 

### O
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 N 2 

### O 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

c haracteristics, 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

t hus gain a competitive advantage. The EPA applied the same
rationale in the 2010

p roposed 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**

3 0806), in support of a
non-CBI determination for reporting of the following same data element currently

r equired to be reported

i f 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

c haracteristics, 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

t hus gain a competitive advantage. The EPA applied the same
rationale in the 2010

p roposed and 2011 final CBI rules (75 FR 39113 76 FR 30803 - 30806), in support of a non- C BI
determination for reporting of the following same data element currently

r equired to be reported

i f a different equation (Equation Y-1a) is used: annual average

m olecular weight of the flare gas (kg/kg-mole)

under 40 CFR 98.256(e)(6).

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Page 67 of 125

**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

c haracteristics, 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

t hus gain a competitive advantage. The EPA applied the same
rationale in the 2010

p roposed and 2011 final CBI rules (75 FR 39113 76 FR 30803 - 30806), in support of a non- C BI
determination for reporting of the following same data element currently

r equired to be reported

i f a different equation (Equation Y-1a) is used: annual average

carbon content of the

f lare gas (kg carbon/kg

f lare 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

f raction 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

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

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

CO 2 

### 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 ND 1 

### 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

b etween 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

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

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 During Review ***

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

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

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

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

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

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

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

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

Page 75 of 125 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

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

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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Page 77 of 125
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

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

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

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

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 During Review *** **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. D 

### ata

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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**Page** 83 of 125

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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**Page** 84 of 125

(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 c**  **ited 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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**Page** 85 of 125

**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 c**  **ited 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 CO 2 

### e missions using the site-specific emission factor method in §98.173(b)(2) based on the total quantity of raw material feed (metric tons of CO 2 

### per metric ton of raw material feed), only annual quantity taconite pellets, coke, iron, and raw steel.

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**Page** 86 of 125

**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 c**  **ited 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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**Page** 87 of 125

**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 c**  **ited 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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**Page** 88 of 125

**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 c**  **ited 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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**Page** 89 of 125

**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 c**  **ited 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 w eekly 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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**Page** 90 of 125

**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 c**  **ited 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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**Page** 91 of 125

§ 98.36 Data reporting requirements.

* * * * *

(b) * * *

(9) * * *

(iii) The annual CH 4 

### and N 2 

### O 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 CO 2 

### e.

(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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**Page** 92 of 125

sharing the common stack or duct during the report year, the

annual CH 4 

### and N 2 

### O mass emissions from the units sharing the

common stack or duct, expressed in metric tons of each gas and

in metric tons of CO 2 

### 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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**Page** 93 of 125

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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**Page** 94 of 125

(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 CO 2 

### 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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**Page** 95 of 125

Equation C–2c of this subpart is used to calculate CO 2 

### 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 CO 2 

### 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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**Page** 96 of 125

(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 CH 4 

### and N 2 

### O 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 CO 2 

### 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 CO 2e 

### 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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**Page** 99 of 125

(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 N 2 

### O 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 CO 2 

### emission factor for the

facility, averaged across all kilns (metric tons CO 2 

### /metric ton

clinker produced).

(18) Annual average CKD CO 2 

### emission factor for the

facility, averaged across all kilns (metric tons CO 2 

### /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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process CO 2 

### 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 CO 2 

### emissions or if you

determined CO 2 

### 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 CO 2 

### 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 CO 2 

### 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 CO 2



### 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	 ൅ ܨ ௦,௜ 

### 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.

F g,i 

### = Annual volume of gaseous fuel combusted (“(F g 

### )” in Equations Q-1, Q-4 and Q-7 of this section) for each process (scf).

MW i 

### = 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.

F l,i 

### = Annual volume of the liquid fuel combusted (“(F l 

### )” included in Equation Q-1 of this section) for each process unit (gallons).

F s,i 

### = Annual mass of the solid fuel combusted (“(F s 

### )” in Equation Q-1 of this section) for each process unit (metric tons).

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ρ l,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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Steel in 

### = 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.

ൌ ݏݐܿݑ݀݋ݎܲ ∑ሺ ݈݁݁ݐܵ ൅ ܴ ൅ ܲ ௨௧௢ 

### ܯܰ ൅ ݊݋ݎܫ ൅ ݎ݁ݐܵ݅݊ ൅ ݇݁݋ܥ ൅ ݈ܵܽ݃ ൅ ௡ ୀଵ௜ 

### ሻ ሺ (-11Q .Eq

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).

Steel out 

### = 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:

CF avg 

### = 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.

C gf,i 

### = Average carbon content of the gaseous fuel used in each process, from the fuel analysis results (kg C per kg of fuel).

C lf,i 

### = Carbon content of the liquid fuel used in each process, from the fuel analysis results (kg C per gallon of fuel.

C sf 

### = 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:

CI avg 

### = 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.

NFI i 

### = Annual mass of each non-fuel input used in Equation Q-10 (metric tons).

C NFIi 

### = 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:

CP avg 

### = 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.

Product i 

### = Annual mass of each product or byproduct used in Equation Q-11 (metric tons).

C p,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 CO 2 

### 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 CO 2 

### 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 N 2 

### O 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 CO 2 

### concentration (volume or mole percent), the number of

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carbon containing compounds other than CO 2 

### in the flare gas

stream, and for each of the carbon containing compounds other

than CO 2 

### 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, %CO 2 

### , 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 CH 4



### emissions. If you use a unit-specific emission factor for CH 4 

### ,

report the basis for the factor.

(12) Indicate whether you use a measured value, a unitspecific emission factor, or a default emission factor for N 2 

### O

emissions. If you use a unit-specific emission factor for N 2 

### O,

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 CO 2



### 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 CH 4 

### emissions. If you

use a unit-specific emission factor for CH 4 

### , report the basis for

the factor.

(8) Indicate whether you use a measured value, a unitspecific emission factor, or a default emission factor for N 2 

### O

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emissions. If you use a unit-specific emission factor for N 2 

### O,

report the basis for the factor.

(j) * * *

(5) If you use Equation Y–14 of this subpart, the basis for

the CO 2 

### emission factor used.

(6) If you use Equation Y–15 of this subpart, the basis for

the CH 4 

### 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 CO 2 

### 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 CH 4 

### 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

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

**Page** 122 of 125

fraction of methane in coking gas (in kg-mole CF 4 

### /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]**

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

**Page** 123 of 125

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]

* * * * *

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

**Page** 124 of 125

(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 CO 2 

### 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 th e “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 Reported 1

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 abbr eviated 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 stati onary 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 CO 2 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 lis ted 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 com busted 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 CO 2 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 ar ithmetic 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 durin g 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 combus ted 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 combus ted 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 combus ted 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 combus ted 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 combus ted 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 combus ted 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 combus ted 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 emissi on 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 emissi on 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 emissi on 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 CO 2 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 CO 2 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 CO 2 is determined according to §98.33(e)(2), re port 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 N 2 O 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 pe rformance 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 minu tes per cell-day. (AEM) F-2

F §98.66(c)(2) Anode effect over voltage 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 overvolta ge. 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 c oke (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 (m etric 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-cal cined 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 CO 2 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 ra w kiln feed or annual consumption of each
raw material. H-5

H §98.86(b)(15) Monthly kiln-specific raw kiln f eed 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 mate rial included for the calculation of annual process CO 2 emissions (No CEMS): Mreducing agenti= Annual mass of reducing agent i fed, charged, or ot herwise introduced into the EAF (tons). K-1

K §98.116(e)(4) Annual material quantity for each mate rial included for the calculation of annual process CO 2 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 mate rial included for the calculation of annual process CO 2 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 mate rial included for the calculation of annual process CO 2 emissions (No CEMS): Mfluxj= Annual mass of flux material j fed, charged, or otherwis e introduced into th e EAF to facilitate slag formation (tons). K-1

K §98.116(e)(4) Annual material quantity for each mate rial included for the calculation of annual process CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 emissions (No CEMS): Cnon-product outgoingl= Carbon conten t 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, e xpressed as one half of a 95 percent confidence interval). Note that where eSA = th e overall absolute error calculated for the process emissions y ou report under §98.126(a)(2), this data element was not deferred in the input s 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

10 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, e xpressed as one half of a 95 percent confidence interval). No te 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 th e 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, e xpressed as one half of a 95 percent confidence interval). Note that where eSA = th e overall absolute error calculated for the process emissions y ou report under §98.126(a)(2), this data element was not deferred in the input s deferral rule (76 FR 53057, August 25, 2011) , and would be re quired 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, e xpressed as one half of a 95 percent confidence interval). Note that where ePA = th e overall absolute error calculated for the process emissions y ou report under §98.126(a)(2), this data element was not deferred in the input s deferral rule (76 FR 53057, August 25, 2011) , and would be re quired 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, e xpressed as one half of a 95 percent confidence interval). Note that where ePR = th e overall relative error calculated for the process emissions y ou report under §98.126(a)(2), this data element was not deferred in the input s deferral rule (76 FR 53057, August 25, 2011) , and would be re quired to be reported. L-4

L §98.126(b)(1) 3 ePA (absolute error of the product, e xpressed as one half of a 95 percent confidence interval). Note that where ePA = th e overall absolute error calculated for the process emissions y ou report under §98.126(a)(2), this data element was not deferred in the input s deferral rule (76 FR 53057, August 25, 2011) , and would be re quired to be reported. L-4

L §98.126(b)(2) The balanced chemical equa tion 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-contai ning reactant that is fed into the process. (Rd) L-6

L §98.126(b)(7) The mass of each fluorine-cont aining 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 destruc tion device (metric tons). (Pj) L-7

L §98.126(b)(8)(ii) The mass of each fluorine-containing by-produc t that is removed from the process and fed into the destruc tion 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 destruc tion device (metric tons). (Rdj) L-7

L §98.126(b)(8)(iv) The mass of each fluorine-containing by-produc t 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 fluorin ated 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 efficien cy 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 r eactant 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 refl ects 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 refl ects 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 refl ects 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 refl ects 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 refl ects 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. (RE D ) 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 (G 23 in Eq. O-4). O-4

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

O §98.156(a)(9) Annual mass of any HFC-23 sent off site for destruction (OD 23 used in Eq. O-4). O-4

O §98.156(a)(10) Mass of HFC-23 in storage at the beginni ng of the year (used to calculate I 23 , 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 I 23 , 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 fo r each fuel and feedstock used in hydrogen production: Gaseous. P-1

P §98.156(b)(5) Monthly analyses of carbon content fo r each fuel and feedstock used in hydrogen production: Liquid. P-2

P §98.156(b)(5) Monthly analyses of carbon content fo r each fuel and feedstock used in hydrogen production: Solid. P-3

P §98.156(b)(6) Monthly analyses of the molecular wei ght 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 ir on 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 pr oduced (No CEMS and not using the sitespecific EF method under §98.173(b)(2)). Q-2

Q §98.176(b) Annual quantity si nter 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 pr oduced (No CEMS and not using the sitespecific EF method under §98.173(b)(2)). Q-5

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

Q §98.176(b) Annual quantity ir on 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 CO 2 emissions (No CEMS) - solid fuel combusted (Csf). Q-1

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS) -gaseous fuel combusted(C gf ). Q-1

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- liquid fuel combusted (C lf ). Q-1

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- greenball pellets produced (Co). Q-1

Q §98.176(e)(1) Carbon content of each process output us ed 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 CO 2 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 CO 2 emissions (No CEMS)- Iron (C iron ). Q-2

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Scrap (C scrap ). Q-2

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Flux (C flux ). Q-2

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Carbonaceous material (C carbon ). Q-2

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Steel produced (C steel ). Q-2

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Slag produced (C slag ). Q-2

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Air pollution control residue collected (C R ). Q-2

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Coal charged to coke battery (C coal ). Q-3

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Coke produced by coke battery (C coke ). Q-3

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Air pollution control residue collected from coke battery (C R ). 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 CO 2 emissions (No CEMS)- Gaseous fuel combusted in the sinter process (C gf ). Q-4

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS) - sinter feed (C Feed ). Q-4

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - sinter (C Sinter ). Q-4

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Air pollution control residue collected from sinter process (C R ). Q-4

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Iron (C iron ) used in EAF. Q-5

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Scrap (C scrap ) used in EAF. Q-5

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Flux (C flux ) used in EAF. Q-5

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Carbonaceous material (C carbon ) used in EAF. Q-5

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Electrode consumed in EAF (C electrode ). Q-5

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Steel produced (C steel ) in EAF. Q-5

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Slag produced (C slag ) in EAF. Q-5

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Air pollution control residue collected (C R ) for EAF. Q-5

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS) - molten steel before decarburization (C steelout ) in EAF. Q-6

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - molten steel after decarburization (C steelout ) in EAF. Q-6

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Air pollution control residue collected (C R ) for EAF. Q-6

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS) - Gaseous fuel combusted in the direct reduction furnace (F g ) . Q-7

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS) - iron ore or iron ore pellets fed into the direct reduction furnace (C
ore ) . Q-7

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Carbonaceous material (C carbon ) used in the direct reduction furnace

. Q-7

Q §98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS) - Other materials charged to the direct reduction furnace (C other ). Q-7

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Iron produced from direct reduction furnace (C iron ). Q-7

Q §98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Non-metallic materials produced from direct reduction furnace (C NM ). 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 CO 2 emissions (No CEMS) - Air pollution control residue collected (C R ) for direct reduction
furnace. Q-7

Q §98.176(e)(3) Annual volume of each type of gaseous fuel used to determine CO 2 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 CO 2 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
CO 2 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
CO 2 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
CO 2 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
CO 2 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
CO 2 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
CO 2 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
CO 2 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
CO 2 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
CO 2 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
CO 2 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
CO 2 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
CO 2 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
CO 2 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
CO 2 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 CO 2 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
CO 2 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
CO 2 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
CO 2 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
CO 2 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
CO 2 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
CO 2 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
CO 2 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 ma ss 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
CO 2 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
CO 2 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
CO 2 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
CO 2 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
CO 2 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 CO 2 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
CO 2 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
CO 2 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
CO 2 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
CO 2 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
CO 2 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
CO 2 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 fuel s (No CEMS) - Taconite Indurating
Furnace. Q-1

Q §98.176(e)(4) Molecular weight of gaseous fuel s (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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 emissions (No CEMS) (Other = A nnual 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 CO 2 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 CO 2 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 CO 2 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 CO 2 emissions (No CEMS). (CCarbon=
Carbon content of the carbonaceous ma terials, 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 CO 2 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 factor s 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 compositi on 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 compositi on 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 compositi on 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 b yproduct/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/w aste 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 consumpti on by carbonate type. U-1

U §98.216(b) Annual carbonate input by carbonate type. U-2

U §98.216(e)(1) Annual carbonate consumpti on by carbonate type. U-1

U §98.216(e)(2) Annual calcination frac tions 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 N 2 O abatement technology is operating (tons, 100% acid basis). V-2

V §98.226(m)(1) Emission factor calculated fo r 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 fo r 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 pe rformance 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" ((F gf ) 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" ((P gf ) 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 feed stocks (used in Equation X-1). X-1

X §98.246(a)(4) Molecular weights for gaseous pr oducts (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" ((F lf )

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" ((P lp )

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" ((F lf )

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" ((P lp )

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" ((CC lf )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" ((F sf )

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" ((P sp )

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" ((CC lf )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 fo r 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 sta tionary combustion unit or group of units (as applicable). C-8

Y §98.256(e)(6) 3 If using Equation Y-1a: report the mo lar volume conversion factor (in scf/gmole) for each flare. Y-1a

Y §98.256(e)(7) 3 If using Equation Y-1b: report mola r volume conversion factor for each
flare. Y-1b

Y §98.256(e)(7)(ii) If using Equation Y-1b: report th e carbon mole number of each carbon containing compound other than CO 2 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 heati ng 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 mo lar 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 th e 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 CH 4 emission factor. Used in method specified in §98.253(c)(4)

Y §98.256(f)(11) Activity data for calcul ating emissions (input). Used in method specified in §98.255(c)(4)

Y §98.256(f)(11) Activity data fo r calculating emissions (product). Used in method specified in §98.255(c)(4)

Y §98.256(f)(12) Activity data for calcul ating emissions (input). Used in method specified in §98.255(c)(5)

Y §98.256(f)(12) Activity data for calcula ting 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 fact or 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 N 2 O 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: Annua l 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 ma ss 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 fo r 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 CH 4 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 CH 4 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 un it-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) CO 2 emission factor for each asphalt blowing unit. Y-14

Y §98.256(j)(6) CH 4 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 CO 2 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: CH 4 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: Cumu lative 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): CH 4 emission
factor used. Y-20

Y §98.256(m)(3) 3 Uncontrolled blowdown systems repor ting under §98.253 (k): Molar volume
conversion factor. Y-20

Y §98.256(m)(3) Uncontrolled blowdown systems reporti ng under §98.253 (k): Total quantity of crude oil plus the quantity of interm ediate products received from off-site that are processed at the f acility 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 unstabili zed crude oil: Quantity of unstabilized crude oil received during the calendar year. Y-23

Y §98.256(o)(4)(iii) For storage tanks that pro cess unstabilized crude oil: Average pressure
differential. Y-23

Y §98.256(o)(4)(iv) 3 For storage tanks that process uns tabilized crude oil: Molar volume
conversion factor. Y-23

Y §98.256(o)(4)(v) For storage tanks that process unstab ilized crude oil: Average Mole fraction
of CH 4 in vent gas from the unstabilized crude oil storage tanks. Y-23

Y §98.256(p)(2) For loading operations: Quantity of materi als loaded by vessel type that have an equilibrium vapor-phase concentration of CH 4 of 0.5 volume percent or greater. Used in methodsspecified 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 deci mal fraction) (No CEMS). Z-1a

Z §98.266(f)(5) Monthly CO 2 (ton CO 2 /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 ro ck 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 CaCO 3 used for the reporting year used in Equation
AA-3. AA-3

AA §98.276(i) Make-up quantity of Na 2 CO 3 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 pe troleum 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) CO 2 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 co nsumption for each production line (No CEMS). EE-2

EE §98.316(b)(9) Monthly carbon content factor of petr oleum coke (percent by weight expressed as a decimal fraction) (No CEMS). EE-2

GG §98.336(b)(6) Annual mass of each carbon-containing i nput 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 i nput 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 i nput 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 i nput 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) fo r each kiln or fu rnace (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) fo r each kiln or fu rnace (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) fo r each kiln or fu rnace (percent by weight, expressed as a decimal fract ion) (No CEMS) - other carbonaceous
materials. GG-1

GG §98.296(b)(10) Carbon content of the carbon electrode s 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) fo r 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 fact or (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 “inpu ts to equations” data elemen ts in §98.226(c) (included in Table A-7 of subpart A of part 98). In its memorandum “Evaluation of Competit ive Harm from Reporting “I nputs to Equations” Data Elements Deferred to March 31, 2015” (refer to docket EPA-HQ-OAR-2010-0929), EPA identifi ed these five “inputs to e quations” data elements as production or raw material data, which were identified as having disclosure concerns. Based on these analysis results, EPA woul d
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 ta king any action to reinstate this provision.

2 

### Combustion units connected to devices connected to the loca l 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 P ublic Utilities Commission to deliver power to the local or regio nal electric power grid (e.g., electricity generators); and (2) the combined nameplate capacity (for all such devices at the facili ty) is greater than or equal to 1 megawatt electric.

3 

### Data element would not be usef ul for data verification and would not inform future GHG polic y development, in the absence of
other data elements included in this table for whic h 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 abbr eviated 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 mo re stationary fuel combustion units at a facility are combined together and discharged through a common stack or duct before exiting to the atmosphere a nd if CEMS are used to continuously
monitor CO 2 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 lis ted 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

# 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 . . . 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 com busted 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 CO 2 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 ar ithmetic 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: Tota l quantity (i.e., pounds) of steam produced from
MSW or solid fuel combustion durin g 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 th e 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 th e 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 th e 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 aver age HHV, when measured HHV da ta, 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 CO 2 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 CO 2 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 CO 2 is determined according to §98.33(e)(2), re port 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 fo r 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) N 2 O concentration per test run during performance test for each unit (CN2O). E-1

E §98.56(j)(5) Volumetric flow rate per test r un 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 th at are sent to the abatement technology) if equation E-3c is used. (FC N ) E-3c

E §98.56h Abatement utilization factor fo r each abatement technology. (AF) E-3b

H §98.86(b)(11) Quarterly kiln-specific CKD CO 2 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 (m ass 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 ra te (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 CO 2 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 utiliz ation factor (AF). V-3a

V §98.226(j) Abatement utiliz ation factor (AF). V-3b

V §98.226(j) Abatement utiliz ation 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) N 2 O 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 t echnology (percent of total emissions from the production unit th at 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 CH 4 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 CO 2 used in equation AA-1. AA-1

AA §98.276(e) Default or site specific emission factor for CH 4 used in equation AA-1. AA-1

AA §98.276(e) Default or site specific emission factor for N 2 O used in equation AA-1. AA-1

CC §98.296(b)(10)(i) Stack gas volumetric flow ra te during performance test (dscfm) for each manufacturing line or stack. CC-3

CC §98.296(b)(10)(ii) Hourly CO 2 concentration during perf ormance test (percent CO 2 ) for each manufacturing line or stack. CC-3

CC §98.296(b)(10)(iii) CO 2 emission factor of process vent flow from mine water for each manufacturing line or stack. CC-5

CC §98.296(b)(10)(iv) CO 2 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) Annua l 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 destructi on (if using weekly sampling). II-4

II §98.356(d)(6) Weekly averag e 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 U tilities 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 rule making.

# Attachment O

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

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 Suppo rt 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 re porting 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 dete rmine 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 fo r the first step of the evaluation process: EPA’s analysis of public availability of the inputs to emission equations deferred to March 31, 2015 (hereaft er referred to as “inputs to equations”). The review was undertaken for 27 of the 28 subparts of the greenhouse gas reporting pr ogram (GHGRP) with “inputs to equations” data elements. 1



# Section 2.0 of this memorandum presents the pr ocedures used to coll ect 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 evalua ted to be the same as publicly available information. Appendix A lists the 2015 data in puts. Appendix B provides detail on the data gathered from each of the s ources reviewed for the subpart s 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 subp art I because reporting of th e “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 availa ble data that are identical to the “inputs to equations” data elements. Data sources that we re 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., wh ether 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 in formation 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 re viewed 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 us ed to develop air regulations, such as
National Emission Standards for Hazardous Air Pollutants (NESHAP) and New Source Performance Standards (NSPS), were reviewed to iden tify 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 incl uded 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 “inpu ts to equations” data elements. References for information and data from rule development doc kets 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

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3 Subpart Dockets Reviewed Docket Number
C NESHAP for Industria l, Commercial, and
Institutional Boilers a nd Process Heaters - Area Sources (40 CFR part 63 subpart JJJJJJ) EPA-HQ-OAR-2006-0790

NESHAP for Industria l, 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 Ce ment 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 Manu facturing – 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 Manuf acturing (40 CFR part 63 subpart AAAAA) A-95-41; EPA-HQ-OAR-2002-0052 U No applicable docket identified
V NSPS for Nitric Acid Plan ts (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 CF R 60 subpart OOOO) X NESHAP for Ethylene Pr ocesses (40 CFR part 63 subparts YY and UU) A-2000-14; EPA-HQ-OAR-2004-0411
Y NSPS for Petroleum Refi neries (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 smalle r sources, are required to obtain Title V operating permits. Title V operating permits that we re available online were reviewed for public availability of the “inputs to e quations” 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 f acilities reporting under each applicable subpart (if available online). Due to the large number of sources subject to subp arts 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 perm its 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 revi ewed is provided as items B-1 through B-197 in
Section 5.0.

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

5 Table 3-2. Summary of Title V Perm its Reviewed for each Subpart

Subpart Permits Reviewed 1



## 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 2-24 2 

## 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 re viewed 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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6  Clean Air Markets Division (CAMD) Acid Ra in Program database – Includes data from various market-based regulatory programs designed to improve air quality, particularly the acid rain program;

 Emission and Generation Integrated Data base (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 Informa tion 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 database s, data available in 2011 for reporting year 2010
were reviewed. Section 4.0 summarizes the informa tion 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 publ ish data related to the industry sectors required to report “inputs to equatio ns” data elements were also reviewed. Online databases were identified for three regions and 18 states that have considered adop ting or have adopted mandatory GHG reporting programs. The follo wing regional databases were reviewed:

 The Climate Registry (TCR) – A voluntary co llaboration between stat es 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 wester n U.S. states that includes information on GHG emissions; and

 Regional Greenhouse Gas Initia tive (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 reviewe d. 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 provide d as items D-1 through D-3 in Section 5.0.

3.5 Journals

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7 Trade and technical journals th at publish data related to th e industry sectors were also
reviewed. Table 3-3 lists the trade journals associated with the i ndustry 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-tim e basis. Section 4.0 summarizes the information found in trade and technical journa ls that is the same as the “i nputs 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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8 Subpart Journal Name

S None Identified

U None Identified

V None Identified

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9 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 industr y, but not in a database . The following websites
were identified:

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10  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 ar e listed as items F-1 th rough 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 availa bility or non-availabi lity, the cited source was reviewed to confirm whether the source did provide informa tion on the “inputs to equations” data elements,
and to assess whether the data in the source we re 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 s ources 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 subpart s, including age of the data, whether the data were a one-time occurrence or on-going, the numbe r of sources reporting the data, and the exact reference for the data source, are provided in Ap pendix 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 si gnificantly different than information publicly available for the lime industry (subject to subpar t S) due to differing sect or-specific regulations and trade publications. For electr ic generators, Table B-1D summ arizes the information required to be reported in the DOE/EIA forms and info rmation 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 availa ble as well as EPA’s analysis of their public availability. Appendix C shows that 37 da ta 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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11 elements are constants used in equations, 24 of the data elements were evaluated in this memorandum (see Appendix B) to be publicly ava ilable on a recurring basis for a minority of reporters or on a one-time basis, and four of the data elements ha d 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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12 Table 4-1. Summary of Publicly Released Data Identical to Inputs to Equations

Subpart # Sources a


## 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 1,985 b 

## 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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13 5.0 References

A-1. "Gilberton Power Company, John B Rich Memori al 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/#!documen tDetail;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, Sept ember 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/#!documen tDetail;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: EP A-HQ-OAR-2002-0032-0223. January 24, 1997. Available: http://www.regula tions.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/#!documen tDetail;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 pa rt 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/#!documen tDetail;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/#!documen tDetail;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/#!documen tDetail;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/#!documen tDetail;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/#!documen tDetail;D=EPA-HQ-OAR-2007-0011-0272.

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14 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.re gulations.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/#!documen tDetail;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/#!documen tDetail;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/#!documen tDetail;D=EPA-HQ-OAR-2008-0154-0018.

A-16. "Information Collection Request (ICR) - Globe Me tallurgical, Selma, AL." 40 CFR part 63 subpart YYYYYY. Docket ID: EPA-HQ-OAR-2008-0154-0019. September 27, 2006. Available: http://www.regulations.gov/#!documen tDetail;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/#!documen tDetail;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/#!documen tDetail;D=EPA-HQ-OAR-2008-0154-0023.

A-19. "Information Collection Request (ICR) - West Virgin ia Alloy." 40 CFR part 63 subpart YYYYYY. Docket ID: EPA-HQ-OAR-2008-0154-0024. September 27, 2006. Available: http://www.regulations.gov/#!documen tDetail;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/#!documen tDetail;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. Decemb er 10, 2004. Available: http://www.regulations.gov/#!documen tDetail;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. D ecember 10, 2004. Available: http://www.regulations.gov/#!documen tDetail;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-2006-0360-004 9. November 3, 2004. Available: http://www.regulat ions.gov/#!documentDetail;D =EPA-HQ-OAR-20 06-0360-0049.

A-24. "Information Collection Request (ICR) Response - Guardian Industries Corp, Corsicana, TX." 40 CFR part 63 subpart SSSSSS. Docket ID: EPA- HQ-OAR-2006-0 360-0057. Available: http://www.regulations.gov/#!documen tDetail;D=EPA-HQ-OAR-2006-0360-0057.

A-25. "Information Collection Request (ICR) Response - Guardian Industries Corporation, Carleton, MI." 40 CFR part 63 subpart SSSSS S. Docket ID: EPA-HQ-OAR -2006-0360-0056. Available: http://www.regulations.gov/#!documen tDetail;D=EPA-HQ-OAR-2006-0360-0056.

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15 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/#!documen tDetail;D=EPA-HQ-OAR-2006-0360-0060.

A-27. "Information Collection Request (ICR) Response - Guardian Industries Corporation, Richburg, SC." 40 CFR part 63 subpart SSSSS S. Docket ID: EPA-HQ-OAR -2006-0360-0062. Available: http://www.regulations.gov/#!documen tDetail;D=EPA-HQ-OAR-2006-0360-0062.

A-28. "Information Collection Request (I CR) 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/#!documen tDetail;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/#!documen tDetail;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/#!documen tDetail;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/#!documen tDetail;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. Do cket ID: EPA-HQ-OAR-200 4-0083-0054. December 2, 2005. Available: http://www.regulations.gov/#! documentDetail;D=EPA-HQ-OAR-2004-0083-0054.

A-33. "Letter and attachment, J . Wo od, 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.regulat ions.gov/#!documentDetail;D =EPA-HQ-OAR-20 02-0052-0212.

A-34. "Letter and attachment, J. Wood, EPAMIGG, to A. Seeger, Morgan, Lewis, and Bockius, July 16, 1996, enclosing spreadsheets containing and summarizing n on-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.re gulations.gov/#!documentDetail;D=EPA-HQ-OAR-2002-
0052-0196.

A-35. "Letter and attachment, J. Wo od, 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.regulati ons.gov/#!documentDeta il;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/#!documen tDetail;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, Alab ama 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/#!documen tDetail;D=EPA-HQ-OAR-2002-0052-0234.

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16 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/#!documen tDetail;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.r egulations.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.regula tions.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.regula tions.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.re gulations.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.regula tions.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.regulat ions.gov/#!documentDetail;D =EPA-HQ-OAR-20 04-0083-0034.

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17 A-49. "Letter and Attachments: Completed Survey Re sponse 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.regula tions.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-
0030.

A-50. "Letter and Attachments: Completed Survey Re sponse 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.regula tions.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-
0031.

A-51. "Letter and Attachments: Completed Survey Re sponse 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.regula tions.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-
0032.

A-52. "Letter and Attachments: Completed Survey Re sponse 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.regula tions.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. Dock et 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 Respon se 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 Respon se 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 Respon se 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/#!documen tDetail;D=EPA-HQ-OAR-2004-0083-0044.

A-57. "Letter and Attachments: Completed Survey Respon se 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/#!documen tDetail;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.re gulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-
0083-0036.

A-62. "Letter and Attachments: Completed Survey Resp onse 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.re gulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-
0083-0057.

A-63. "Letter and Attachments: Completed Survey Resp onse 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/#!do cumentDetail;D=EPA-HQ-OAR-2004-
0083-0058.

A-64. "Letter and Attachments: Completed Survey Resp onse 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.re gulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-
0083-0061.

A-65. "Letter and Attachments: Completed Survey Resp onse 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.re gulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-
0083-0062.

A-66. "Letter and Attachments: Completed Survey Resp onse from The Timken Comp any, 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.regula tions.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-
0016.

A-67. "Letter and Attachments: Completed Survey Resp onse from The Timken Comp any, 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.regula tions.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-
0017.

A-68. "Letter and Attachments: Completed Survey Resp onse from The Timken Comp any, 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.regula tions.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-
0018.

A-69. "Letter and Attachments: Completed Survey Resp onse from The Timken Comp any, 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.regula tions.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-
0019.

A-70. "Letter and Attachments: Completed Survey Resp onse from The Timken Comp any, 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.regula tions.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-
0020.

A-71. "Letter and Attachments: Completed Survey Resp onse from The Timken Comp any, 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.re gulations.gov/#!documentDetail;D=EPA-HQ-OAR-2004-
0083-0022.

A-72. "Letter and Attachments: Completed Survey Resp onse from The Timken Comp any, 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.regula tions.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-
0023.

A-73. "Letter and Attachments: Completed Survey Resp onse from The Timken Comp any, 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.regula tions.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-
0024.

A-74. "Letter and Attachments: Completed Survey Resp onse from The Timken Comp any, 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.regula tions.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-
0025.

A-75. "Letter and Attachments: Completed Survey Resp onse from The Timken Comp any, 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.regula tions.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-
0026.

A-76. "Letter and Attachments: Completed Survey Resp onse from The Timken Comp any, 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.regula tions.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-
0027.

A-77. "Letter and Attachments: Completed Survey Resp onse from The Timken Comp any, 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.regula tions.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0083-
0028.

A-78. "Letter and Attachments: Completed Survey Resp onse from The Timken Comp any, 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.regula tions.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-O AR-2002-0051-1956. August 6, 2007. Available: http://www.regulations.gov/#!documen tDetail;D=EPA-HQ-OAR-2002-0051-1956.

A-80. "Letter from Timothy L. Matz, Director of Envi ronmental 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 subp art LLL. Docket ID: EPA- HQ-OAR-2002-0 051-1963. August 2, 2007. Available: http://www.regulations.gov/#!docu mentDetail;D=EPA-HQ-OAR-2002-0051-
1963.

A-81. "Letter from Timothy L. Matz, Director of Envi ronmental 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. Do cket 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

20 A-82. "Letter from Timothy L. Matz, Director of Envi ronmental 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. Do cket 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 Envi ronmental 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. Do cket 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 Envi ronmental Affairs, Lehigh Cement Company to Keith Barnett, USEPA -Section 114 Request Response, Merc ury and THC Data - Evansville, PA Plant." Lehigh Cement Companv. 40 CFR part 63 subpart LLL. Do cket 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 Co mpany, 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/#!documen tDetail;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, Merc ury and THC Data - Mason City, IA Plant." Lehigh Cement Companv. 40 CFR part 63 subpart LLL. Do cket 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 Nu cor 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/#!do cumentDetail;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/#!documen tDetail;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/#!docum entDetail;D=EPA-HQ-OAR-2004-0083-0052

.

A-91. "Letter regarding completed survey response for th e 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/#!docum entDetail;D=EPA-HQ-OAR-2004-0083-0053

.

A-92. "Letter regarding completed survey response fo r 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/#!documen tDetail;D=EPA-HQ-OAR-2004-0083-0056.

A-93. "Letter to Bruce C. Jordan, USEPA, from Tom B ach, KN Energy, Inc, re: Tr ansmission 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/#!documen tDetail;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/#!documen tDetail;D=EPA-HQ-OAR-2004-0383-0021.

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

21 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 O il 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.regulat ions.gov/#!documentDetail;D =EPA-HQ-OAR-20 02-0051-2098.

A-97. "Letter to Mary Tom Kissel." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083- 0063. December 11, 2005. Availa ble: http://www.regul ations.gov/#!documen tDetail;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-O AR-2004-0083-0055. December 2, 2005. Available: http://www.regulations.gov/#!documen tDetail;D=EPA-HQ-OAR-2004-0083-0055.

A-99. "Letter to Mary Tom Kissell, USEPA, from Debor ah 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.re gulations.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/#!documen tDetail;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/#!documen tDetail;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/#!documen tDetail;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.reg ulations.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/#!documen tDetail;D=EPA-HQ-OAR-2002-0052-0080.

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

22 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/#!documen tDetail;D=EPA-HQ-OAR-2002-0052-0070.

A-107. "Natural Gas Production NSPS – Technology Review s." 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/#!documen tDetail;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.regula tions.gov/#!documentDetail;D=EPA-HQ-OAR-2004-0382-
0007.

A-109. "Oil and Natural Gas Production Maximum Achiev able 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/#!documen tDetail;D=EPA-HQ-OAR-2010-0505-0062.

A-110. "Part of E.O. 12866 Review: USEPA Staff Respon se: 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/#!documen tDetail;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.regulat ions.gov/#!documentDetail;D =EPA-HQ-OAR-20 02-0051-2115.

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/#!documen tDetail;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/#!documen tDetail;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.regulat ions.gov/#!documentDetail;D =EPA-HQ-OAR-20 02-0051-2116.

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/#!documen tDetail;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/#!documen tDetail;D=EPA-HQ-OAR-2002-0051-2111.

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

23 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.regulat ions.gov/#!documentDetail;D =EPA-HQ-OAR-20 02-0051-1933.

A-121. "Secondary Lead ICR Form Responses (CD)." 40 CFR part 63 subpart X. Docket ID: EPA-HQ-OAR2011-0344-0113. Available: http://www.regulati ons.gov/#!documentDetail;D=EPA-HQ-OAR-2011-0344-
0113.

A-122. "Section 114 Response - Ash Grove Cement Compan y - 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.regulat ions.gov/#!documentDetail;D =EPA-HQ-OAR-20 02-0051-2130.

A-123. "Section 114 Responses in the Ethylene MACT Do cket (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/#!documen tDetail;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.regula tions.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.regulat ions.gov/#!documentDetail;D =EPA-HQ-OAR-20 07-0011-0119.

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 Co ast 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/#!documen tDetail;D=EPA-HQ-OAR-2007-0011-0187.

A-127. "Source Test Report conducted at Conoco-Phillip s Refinery, Carson, Californi a -- 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, Californi a -- 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 Co ast 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/#!documen tDetail;D=EPA-HQ-OAR-2007-0011-0189.

A-130. "State of Missouri Department of Natural Resour ces: 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/#!do cumentDetail;D=EPA-HQ-OAR-2002-
0052-0495.

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

24 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 Apr il 2001)." 40 CFR part 63 subpart YYYYY. Docket ID: EPA-HQ-OAR-2004-0083-0021. October 28, 2005. Available: http://www.regulations.gov/#!documen tDetail;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/#!documen tDetail;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/#!documen tDetail;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. Pe rmit ID: 166TVP01. Available: http://dec.alaska.gov/.

B-2. Alaska Department of Environmental Conservatio n. Title V Permit for BP E xploration (Alaska) Inc., Central Gas Facility, Prudhoe Bay, Alaska. Permit ID: 270TVP01. Available: http://dec.alaska.gov/.

B-3. Alaska Department of Environmental Conservatio n. Title V Permit for BP E xploration (Alaska) Inc., Northstar Caribou Crossing Compressor Facility, Prudhoe Bay, Alaska. Permit ID: AQ0427TVP02. Available: http://dec.alaska.gov/.

B-4. Alaska Department of Environmental Conservatio n. 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. T itle 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: 1 000044. 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, Ar izona. Permit ID: OP#17. Available: http://www.azdeq.gov/.

B-10. Arkansas Department of Enviro nmental 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 Enviro nmental Quality. Title V Permit for Arkansas Lime Company, Batesville, Arkansas. Permit ID: 0045-AOP-R5. Available: http://www.adeq.state.ar.us/.

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

25 B-12. Arkansas Department of Enviro nmental 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 Enviro nmental 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 Enviro nmental 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 Enviro nmental Quality. Title V Permit for Green Bay Packaging, Inc. - AR Kraft Division, Morrilton, Arkansas. Permit ID: 0224-AO P-R12. Available: http://www.adeq.state.ar.us/.

B-16. Arkansas Department of Envi ronmental 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 Envi ronmental Quality. Title V Permit fo r 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 Ai r Liquid Large Industries, US LP, Rodeo, California.
Permit ID: B7419. Available: h ttp://www.arb.ca.gov/homepage.htm.

B-20. California Air Resources Board. Title V Permit for Calpine Pittsburg Power Plan t, Pittsburg, California.
Permit ID: B1928. Available: h ttp://www.arb.ca.gov/homepage.htm.

B-21. California Air Resources Board. Title V Perm it 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. Availa ble: http://www.arb.ca.gov/homepage.htm.

B-23. California Air Resources Board. Title V Permit fo r Tesoro Refining and Marketing Company, Martinez,
California. Permit ID: B2758 & B2759. Avai lable: 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 Enviro nment. Title V Permit for CEMEX, Inc. - Lyons Cement Plant, Lyons, Colorado. Permit ID: 95OPBO082. Ava ilable: http://www.colorad o.gov/cs/Satellite/CDPHEMain/CBON/1251583470000.

B-26. Colorado Department of Public Health and E nvironment. 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 Envi ronment. Title V Permit fo r 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 Enviro nment. 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.

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

26 B-29. Colorado Department of Public Health and Enviro nment. Title V Permit for Duke Energy Field Services, LP - Roggen Gas Plant, Weld County, Co lorado. Permit ID: 95OPWE055. Available: http://www.colorado.gov/cs/Satellite/CDPHE-Main/CBON/1251583470000.

B-30. Colorado Department of Public Health and Enviro nment. 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 Environm ent. 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 Environm ent. Title V Permit for EnCana Oil & Gas (USA), Inc. - Hunter Mesa Compressor Station, Garfield Coun ty, Colorado. Permit ID: 03OPGA267. Available: http://www.colorado.gov/cs/Satellite/CDPHE-Main/CBON/1251583470000.

B-33. Colorado Department of Public Health and E nvironment. Title V Permit for Northwest Pipeline GP, Pleasant View Compressor Station, Montezuma Coun ty, Colorado. Permit ID: 95OPMN085. Available: http://www.colorado.gov/cs/Satellite/CDPHE-Main/CBON/1251583470000.

B-34. Colorado Department of Public Health and Enviro nment. 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: 0310157-0 02-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. Pe rmit 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. T itle V Permit for Georgia-Pacific Corporation – Palatka Mill, Palatka, Florida. Permit ID: 1070005-0 31-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, Fl orida. 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-A V. 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. Av ailable: 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. Pe rmit ID: 2952-1 13-0013-V-01-0. Available: http://www.gadnr.org/.

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

27 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 Plan t, 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, Ge orgia. Permit ID: 2631-305 -0001-V-02-0. Available: http://www.gadnr.org/.

B-47. Georgia Department of Natural Resources, Enviro nmental 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 Clear water 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: h ttp://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. Ava ilable: http://www.epa.state.il.us/.

B-57. Illinois Environmental Protection Agency. Title V Permit for Honeywell International, Inc., Metropolis,
Illinois. Permit ID: 127854AAD. Ava ilable: 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

28 B-61. Illinois Environmental Protection Agency. Title V Permit for Saint-Gobain Containers, Inc., Lincoln,
Illinois. Permit ID: 107035AAX. Ava ilable: http://www.epa.state.il.us/.

B-62. Indiana Department of Environmental Manage ment. Title V Permit for Anchor Glass Container Corporation, Winchester, Indiana. Permit ID: T1 35-27245-00012. 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 Pro ducts 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 Manageme nt. 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 Manageme nt. Title V Permit for Green Plains Bluffton, LLC, Bluffton, Indiana. Permit ID: T179-29393-00 033. Available: http://www.in.gov/idem/.

B-68. Indiana Department of Environmental Manageme nt. 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. T itle V Permit for Lone Star Industries, Inc. dba Buzzi Unicem USA, Greencastle, Indiana. Permit ID: T1 33-26830-00002. 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. T itle V Permit for Praxair, Inc ., East Chicago, Indiana.
Permit ID: T089-21430 -00330. Available: h ttp://www.in.gov/idem/.

B-72. Indiana Department of Environmental Manageme nt. Title V Permit for Quem etco, Inc., Indianapolis,
Indiana. Permit ID: T097-27020-00079. Available: http://www.in.gov/idem/.

B-73. Indiana Department of Environmental Manageme nt. Title V Permit for Tyson Foods, Inc. - Corydon Facility, Corydon, Indiana. Permit ID: M061-273 83-00029. Available: http://www.in.gov/idem/.

B-74. Iowa Department of Natural Resources. Title V Pe rmit 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. Availabl e: http://www.iowadnr.gov/.

B-77. Iowa Department of Natural Resources. Title V Pe rmit for Green Valley Chemical Corporation, Creston,
Iowa. Permit ID: 99-TV-002R2. Ava ilable: 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/.

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

29 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 Pe rmit 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. T itle V Permit for Air Products and Chemicals, Inc. – New Orleans Facility, New Orleans, Louisian a. Permit ID: 2140-00016-V7. Available: http://www.deq.louisiana.gov/portal/.

B-82. Louisiana Department of Environmental Quality. T itle V Permit for Air Products and Chemicals, Inc. – SMR Facility, Convent, Louisiana. Pe rmit 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. Av ailable: 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, Louisian a. Permit ID: 2490-001 42-V4. Available: http://www.deq.louisiana.gov/portal/.

B-87. Louisiana Department of Environmental Quality. T itle V Permit for Norco Chemical Plant – West Site, Shell Chemical LP, Norco, Louisian a. 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, Louisian a. 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: h ttp://www.maine.gov/dep/.

B-92. Michigan Department of Environmental Quality. T itle V Permit for Guardian Industrial Corporation, Carleton, Michigan. Permit ID: MI-ROP-B1877-2 009. Available: http://www.michigan.gov/deq.

B-93. Michigan Department of Environmental Quality. T itle V Permit for Marathon Petroleum Company, LLC., Detroit, Michigan. Permit ID: 199700013c. Available: http://www.michigan.gov/deq.

B-94. Michigan Department of Environmental Qua lity. Title V Permit for Menominee Paper Company, Menominee, Michigan. Permit ID: MI-ROP-B1855-2 011. Available: http://www.michigan.gov/deq.

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

30 B-95. Michigan Department of Environmental Quality. T itle 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: h ttp://www.michig an.gov/deq.

B-97. Michigan Department of Environmental Quality . Title V Permit for St. Marys Cement, Inc. (US), Charlevoix, Michigan. Permit ID: MI-ROP-B1559-2 008. 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 Perm it 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, Missi ssippi. Permit ID: 2980-00008. Available: http://www.deq.state.ms.us/.

B-102. Mississippi Department of Environmental Qua lity. 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 US A, 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. Av ailable: 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 Co ntainers, Pevely, Missouri. Permit ID: OP2007-035A. Available: http://www.dnr.mo.gov/.

B-108. New Mexico Environment Department. Title V Pe rmit 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 Environmen tal Conservation. Title V Permit for ALCOA Massena Operations (West Plant), Mass ena, New York. Permit ID: 6-4058-00003/00365. Available: http://www.dec.ny.gov/.

B-110. New York State Department of Environmental C onservation. 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

31 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 Environmenta l Conservation. Title V Pe rmit 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 Cons ervation. 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 an d 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 Na tural Resources. Title V Perm it for E.I. du Pont de Nemours & Co., LLC DBA, DuPont Company – Fayetteville Works, Duart Township, North Carolina.
Permit ID: 03735T32. Available: h ttp://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 Na tural Resources. Title V Perm it for International Paper, Riegelwood, North Carolina. Permit ID: 03138R36. Available: http://portal.ncdenr.org/web/guest.

B-119. North Carolina Department of Environment an d 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 an d 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 Pe rmit 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 Pe rmit 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: P00 82545. 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

32 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 Pe rmit 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 Pe rmit 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 Pe rmit 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 Pe rmit 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-T V. 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, Wetumk a, 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: 99-0 92-TV. Available: http://www.deq.state.ok.us/.

B-143. Oregon Department of Environmental Quality. T itle V Permit for Ash Grove Ce ment Co., Durkee, Oregon. Permit ID: 01-0029. Available: http://w ww.oregon.gov/DEQ/P ages/index.aspx.

B-144. Rhode Island Department of Environmental Management. Title V Permit for Brown University, Providence, Rhode Island. Permit ID: RI-09-06 (R 3). 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. Pe rmit 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: RN101865 715. Available: http://www.tceq.state.tx.us/.

B-147. Texas Commission on Environmental Quality. T itle V Permit for Air Produc ts 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 Corporatio n, Pampa, Texas. Permit
ID: O1623. Available: h ttp://www.tceq.state.tx.us/.

B-149. Texas Commission on Environmental Quality. T itle 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 Pl ant, 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. Availa ble: http://www.tceq.state.tx.us/.

B-152. Texas Commission on Environmental Quality. Title V Permit for Duke Energy Fi eld 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. Ava ilable: 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. Av ailable: 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 Natu ral 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. Av ailable: http://www.tceq.state.tx.us/.

B-158. Texas Commission on Environmental Quality. T itle V Permit for International Paper Company, Queen City, Texas. Permit ID: O1378. Ava ilable: 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. Availa ble: http://www.tceq.state.tx.us/.

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

34 B-163. Utah Department of Environmental Quality. T itle 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. T itle 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. T itle 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 Qua lity. 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-202 25. Available: http://www.deq.state.va.us/.

B-171. Virginia Department of Environmental Quality. T itle 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. T itle V Permit for Honeywell International Inc. – Hopewell Plant, Hopewell, Virginia. Permit ID: PRO50 232. 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. Availa ble: http://www.deq.state.va.us/.

B-175. Virginia Department of Environmental Quality. Title V Permit for Smurfit-Stone Container Enterprises, Inc., Hopewell, Virginia. Perm it ID: PRO-50370. Available: http://www.deq.state.va.us/.

B-176. West Virginia Department of Environmental Pr otection. 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/P ages/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/P ages/default.aspx.

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

35 B-179. West Virginia Department of Environmental Prot ection. Title V Permit for Er gon - West Virginia, Inc., Newell, West Virginia. Permit ID: R30-02900008-2010. Available: http://www.dep.wv.gov/P ages/default.aspx.

B-180. West Virginia Department of Environmental Prot ection. 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/P ages/default.aspx.

B-181. West Virginia Department of Environmental Protec tion. Title V Permit for SFK Pu lp Recycling U.S., Inc. - Fairmont Division, Fairmont, West Virginia. Permit ID: R30-04900043-2008. Available: http://www.dep.wv.gov/P ages/default.aspx.

B-182. Wisconsin Department of Natural Resources. T itle V Permit for Cardinal FG, Menomonie, Wisconsin.
Permit ID: 617049840-P10. Ava ilable: http://dnr.wi.gov/.

B-183. Wisconsin Department of Natural Resources. Title V Permit for Graymont (WI) Inc., Superior, Wisconsin.
Permit ID: 816036430-P01. Ava ilable: 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: 6030079 00-F20. Available: http://dnr.wi.gov/.

B-185. Wisconsin Department of Natural Resources. T itle 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. Ava ilable: 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. T itle 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, Pavilli on, Wyoming. Permit ID: 3-1-063. Available: http://deq.state.wy.us/.

B-191. Wyoming Department of Environmental Quality. T itle 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. T itle 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. Av ailable: http://deq.state.wy.us/.

B-194. Wyoming Department of Environmental Quality. T itle 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, Wyomi ng. Permit ID: 3-1-119. Available: http://deq.state.wy.us/.

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

36 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 Reso urce Integrated Database (eGRID). Available: http://www.epa.gov/cleanenergy/en ergy-resources/egrid/index.html.

C-4. U.S. EPA, 2010. Toxic Re lease Inventory. Available: http://www.epa.gov/tri/index.htm.

C-5. U.S. Energy Information Administra tion, 2011. Available http://www.eia.gov/.

C-6. U.S. EPA, 2012. Enforcemen t and Compliance History Online (E CHO). Available: http://www.epaecho.gov/echo/index.html.

D-1. The Climate Registry, 2011. Availa ble: http://www.theclimateregistry.org/.

D-2. Western Climate Initiative, 2011. Available: http://www.westernclimateinitiative.org/index.php.

D-3. Regional Greenhouse Gas Initiative (RGG I), 2011. Available: http://www.rggi.org/.

E-1. “2011 Survey of Top 200 U.S. Oil and Gas Co mpanies.” 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 Ev aluation of Opportunities to Reduce Methane Losses at Four Gas Processing Plants." June 20, 2002. Available: http://www.epa.gov/gasstar/doc uments/four_plants.pdf.

F-2. Gas Research Institute (GRI) and U.S. EPA. “Met hane Emissions from the Natural Gas Industry, Volume 7: Blow and Purge Activities.” June 1996. Tabl es 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/gasst ar/documents/workshops/farmington2010/08_recs_farmington_nm_final.pdf.

F-4. U.S. EPA. "Cost-Effective Di rected 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/d ocuments/clearstone _II_03_2006.pdf.

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

37 F-5. American Petroleum Institute (A PI). Industry Statistics, Quarterly Well Completion Report. Available: http://www.api.org/Publications-Standards-and-Statis tics/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.g ov/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/MediaCente r/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/transp ort/gassafe/pdf/Presentation-H azardous_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

39Subpart

Citation Data Element Data Element is used as Input to Equation . . . Number of Facilities a

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 CO 2 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 st ack 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 CO 2 emissions calculations for ea ch 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 combus ted 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 combus ted 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 combus ted 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 combus ted 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 combus ted 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 combus ted 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 combus ted 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

40Subpart Citation Data Element Data Element is used as Input to Equation . . . Number of Facilities 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-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 CH 4 and N 2 O 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 CO 2 is determined according to §98.33(e)(2), report the carbon-base d 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 CO 2 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 CO 2 is determined according to §98.33(e)(2), report the total quantity of fo ssil 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 N 2 O abatement technology (l ocated after the test point) is operating (Pz,N) E-2 3

E 98.56(g) Abatement technology destruction efficien cy 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 fo r each abatement technology (AF) E-3a 3

E 98.56(h) Abatement utilization factor fo r each abatement technology (AFN) E-3b 3

E 98.56(h) Abatement utilization factor fo r each abatement technology (AFN) E-3c 3

E 98.56(j)(1) Emission factor for each unit (EFN 2 Oz) E-3a 3

E 98.56(j)(1) Emission factor for each unit (EFN 2 O) E-3b 3

E 98.56(j)(1) Emission factor for each unit (EFN 2 O) E-3c 3

E 98.56(j)(1) Emission factor for each unit (EFN 2 O) 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) N 2 O concentration per test run during performance test for each unit (CN 2 O) E-1 3

E 98.56(j)(5) Volumetric flow rate per test run du ring performance test for each unit (Q) E-1 3

E 98.56(l) Fraction control factor for each abatement t echnology (percent of total emissions from the production unit that are sent to the abatement technology) if equation E-3c is used. (FC N ) 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

41Subpart Citation Data Element Data Element is used as Input to Equation . . . Number of Facilities a

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 consum ed for ammonia manuf acturing - 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 consum ed for ammonia manuf acturing - Solid
Feedstock G-3 22

G 98.76(b)(7) Carbon conten t 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 tota l CaO in CKD not r ecycled 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 CO 2 emission factors for each kiln H-2 96

H 98.86(b)(11) Quarterly kiln-specific CKD CO 2 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 fe ed or annual consumption of each raw material H-5 96

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

42Subpart Citation Data Element Data Element is used as Input to Equation . . . Number of Facilities a 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 40CFR 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 quan tity for each material included for the calculation of annual process CO 2 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 quan tity for each material included for the calculation of annual process CO 2 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 quan tity for each material included for the calculation of annual process CO 2 emissions (No CEMS): Moreh= Annual mass of ore h charged to the EAF (tons). K-1 10

K 98.116(e)(4) Annual material quan tity for each material included for the calculation of annual process CO 2 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 quan tity for each material included for the calculation of annual process CO 2 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 CO 2 emissions (No CEMS): Creduc ing agenti= Carbon content in reducing agent i (percent by weig ht, 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 CO 2 emissions (No CEMS): Celectrodem= Carbon content of the carbon electrode m (percent by weig ht, 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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

43Subpart Citation Data Element Data Element is used as Input to Equation . . . Number of Facilities a 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 percen t 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, expresse d 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 fluor inated 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 gr eater 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 th at is recaptured (metric tons). (cTFl) L-17 16

L 98.126(b)(9)(iii) The weighted average destruction ef ficiency of the destructi on 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 co nsumed). (ActivityC) L-21 16

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

44Subpart Citation Data Element Data Element is used as Input to Equation . . . Number of Facilities a 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 co nsumed). (ActivityC) L-22 16

L 98.126(c)(2) The site-specific, pro cess-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, pro cess-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, pro cess-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, pro cess-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, pro cess-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, pro cess-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, pro cess-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. (RE D ) 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-ra w 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 (G 23 in Eq. O-4) O-4 5

O 98.156(a)(8) Annual mass of any HFC-23 sent off site for sale (S 23 in Eq. O-4) O-4 5

O 98.156(a)(9) Annual mass of any HFC-23 sent off site for destruction (OD 23 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 I 23 , 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 I 23 , 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 destructi on 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 destru ction 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 destructi on 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

45Subpart Citation Data Element Data Element is used as Input to Equation . . . Number of Facilities a 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 destru ction 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 destructi on 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 efficien cy (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 CO 2 emissions (No CEMS) - solid fuel combusted (Csf) Q-1 128

Q 98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS) -gaseous fuel combusted (C gf ) Q-1 128

Q 98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- liquid fuel combusted (C lf ) Q-1 128

Q 98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- greenball pellets produced (Co) Q-1 128

Q 98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Iron (C iron ) Q-2 128

Q 98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Scrap (C scrap ) Q-2 128

Q 98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Flux (C flux ) Q-2 128

Q 98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Carbonaceous material (C carbon ) Q-2 128

Q 98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Coal charged to coke battery (C coal ) Q-3 128

Q 98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Gaseous fuel combusted in the sinter process (C gf ) Q-4 128

Q 98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS) - sinter feed (C Feed ) Q-4 128

Q 98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Iron (C iron ) used in EAF Q-5 128

Q 98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Scrap (C scrap ) used in EAF Q-5 128

Q 98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Flux (C flux ) used in EAF Q-5 128

Q 98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Carbonaceous material (C carbon ) used in EAF Q-5 128

Q 98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Electrode consumed in EAF (C electrode ) Q-5 128

Q 98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS) - molton steel before decarburization (C steelout ) in EAF Q-6 128

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

46Subpart Citation Data Element Data Element is used as Input to Equation . . . Number of Facilities a Q 98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS) - Gaseous fuel combusted in the direct reduction furnace (F g ) Q-7 128

Q 98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS) - iron ore or iron ore pellets fed into the direct redu ction furnace (C

ore ) Q-7 128

Q 98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS)- Carbonaceous material (C carbon ) used in the direct reduction furnace Q-7 128

Q 98.176(e)(1) Carbon content of each process input used to determine CO 2 emissions (No CEMS) - Other materials charged to the direct reduction furnace (C other ) Q-7 128

Q 98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Fired pellets produced (Cp) Q-1 128

Q 98.176(e)(1) Carbon content of each process output used to determine CO 2 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 CO 2 emissions (No CEMS) - Steel produced (C steel ) Q-2 128

Q 98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Slag produced (C slag ) Q-2 128

Q 98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Air pollution control residue collected (C R ) Q-2 128

Q 98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Coke produced by coke battery (C coke ) Q-3 128

Q 98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Air pollution control residue collected from coke battery (C R ) Q-3 128

Q 98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - sinter feed (C Feed ) Q-4 128

Q 98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Air pollution control residue collected from sinter process (C R ) Q-4 128

Q 98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Steel produced (C steel ) in EAF Q-5 128

Q 98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Slag produced (C slag ) in EAF Q-5 128

Q 98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Air pollution control residue collected (C R ) for EAF Q-5 128

Q 98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - molton steel after decarburization (C steelout ) in EAF Q-6 128

Q 98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Air pollution control residue collected (C R ) for EAF Q-6 128

Q 98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Iron produced from direct reduction furnace (C iron ) Q-7 128

Q 98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Nonmetallic materials produced from direct reduction furnace (C NM ) Q-7 128

Q 98.176(e)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Air pollution control residue collected (C R ) for direct re duction furnace Q-7 128

Q 98.176(e)(3) Annual volume of each type of gaseous fuel used to determine CO 2 emissions (reported separately for each type in standard cubic f eet) (No CEMS) - Taconite Indurating Furnace Q-1 128

Q 98.176(e)(3) Annual volume of each type of gaseous fuel used to determine CO 2 emissions (reported separately for each type in standard cubi c 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 CO 2 emissions (reported separately for each type in standard cubic f eet) (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 CO 2 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 CO 2 emissions (No CEMS)- Annual mass of greenball (tac onite) 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 emissions (No CEMS)- Annual mass of carbon (e.g., co al, coke) charged to furnace (Carbon) Q-2 128

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

47Subpart Citation Data Element Data Element is used as Input to Equation . . . Number of Facilities a Q 98.176(e)(3) Annual mass (in metric tons) of each other process input used to determine CO 2 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 CO 2 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 CO 2 emissions (No CEMS)- Annual mass of direct redu ced 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 CO 2 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 CO 2 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 CO 2 emissions (No CEMS)- Annual mass of carbon elect rode 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 emissions (No CEMS) - Annual ma ss 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 emissions (No CEMS)- Annual mass of s inter Produced (Sinter) Q-4 128

Q 98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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

48Subpart Citation Data Element Data Element is used as Input to Equation . . . Number of Facilities a Q 98.176(e)(3) Annual mass (in metric tons) of each other process output used to determine CO 2 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 CO 2 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 dur ing 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 CO 2 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 CO 2 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 CO 2 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 CO 2 emissions (No CEMS) (Scrap = Annual mass of lead scrap charged to the smelt ing furnace (tons).)

R-1 13

R 98.186(b)(6) Annual material quantity used for the calculation of annual process CO 2 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 CO 2 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 CO 2 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 conten t determinations for each material used for the calculation of annual process CO 2 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 conten t determinations for each material used for the calculation of annual process CO 2 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 conten t determinations for each material used for the calculation of annual process CO 2 emissions (No CEMS). (CFlux= Carbon content of the flux materials, from the carbon analysis (percen t by weight, expressed as a decimal fraction).)

R-1 13

R 98.186(b)(7) Annual average of the carbon conten t determinations for each material used for the calculation of annual process CO 2 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 conten t determinations for each material used for the calculation of annual process CO 2 emissions (No CEMS). (COthe r= 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

49Subpart Citation Data Element Data Element is used as Input to Equation . . . Number of Facilities a 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 N 2 O 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 (EFN 2 Ot) V-3a 36

V 98.226(m)(1) Emission factor calculated for each nitric acid train (EFN 2 Ot) V-3b 36

V 98.226(m)(1) Emission factor calculated for each nitric acid train (EFN 2 Ot) V-3c 36

V 98.226(m)(1) Emission factor calculated for each nitric acid train (EFN 2 Ot) 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) N 2 O 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 CO 2 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

50Subpart Citation Data Element Data Element is used as Input to Equation . . . Number of Facilities a W 98.236(c)(3)(iii) For Calculation Methodology 3 of §98.233(d), annual average volume fraction of CO 2 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 CO 2 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 CO 2 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 CO 2 content of natural gas out of each acid gas removal unit. W-4B 186

W 98.236(c)(3)(iv) Annual quantity of CO 2 , that was recovered from each acid gas removal unit and transferred
outside the facili ty (metric tons CO 2 e), 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 MMsc fd, 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 thro ughput 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 CO 2 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 CH 4 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 measur ed well venting (cubic feet per hour). W-7 873

W 98.236(c)(5)(ii)(C) For well venting for liquids unloadi ng, 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 unloadi ng, 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 completi ons and workovers with hydraulic fracturing, repor t 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 completi ons and workovers with hydraulic fracturing, repor t 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 completi ons and workovers with hydraulic fracturing, repor t 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 completi ons and workovers with hydraulic fracturing, repor t 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 completi ons and workovers with hydraulic fracturing, repor t 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 ty pe (horizontal or vertical) combin ation: Total count of completions in calendar year. W-13 873

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

51Subpart Citation Data Element Data Element is used as Input to Equation . . . Number of Facilities a W 98.236(c)(6)(ii)(B) For well completions and workovers without hydraulic fracturing, report the following for each sub-basin and well ty pe (horizontal or vertical) combin ation: 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 oi l 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 oi l 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 CO 2 gas quantities that were recovered (metric tons CO 2 e), 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 CO 2 gas quantities that were recovered (metric tons CO 2 e), 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 CO 2 gas quantities that were recovered (metric tons CO 2 e), 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 (r efer 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 comp ressors 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

52Subpart Citation Data Element Data Element is used as Input to Equation . . . Number of Facilities a 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 blo wdown 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 blo wdown 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 blo wdown 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: Report er 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 on shore petroleum and natural gas production: Count of

compressors. W-29 200

W 98.236(c)(15)(ii)(A) For equipment leaks calculated usi ng 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 usi ng 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: Nu mber 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 CO 2 for each sub-basin categ ory: Volume of crude oil produced (barrels per year). W-38 N/A

W 98.236(c)(18)(ii) For EOR hydrocarbon liquids dissolved CO 2 for each sub-basin category: Amount of CO 2 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 ga s production and natural gas distribution combustion
emissions: Cumulative volume of fuel combusted in external fuel combustion units with a rated heat capacity larger th an 5 mmBtu/hr, by fuel type. W-39A 873

W 98.236(c)(19)(iv) For onshore petroleum and natural ga s production and natural gas distribution combustion
emissions: Cumulative volume of fuel combusted in external fuel combustion units with a rated heat capacity larger th an 5 mmBtu/hr, by fuel type. W-39B 873

W 98.236(c)(19)(iv) For onshore petroleum and natural ga s production and natural gas distribution combustion
emissions: Cumulative volume of fuel combusted in external fuel combustion units with a rated heat capacity larger th an 5 mmBtu/hr, by fuel type. W-40 873

W 98.236(c)(19)(vii) For onshore petroleum and natural ga s 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

53Subpart Citation Data Element Data Element is used as Input to Equation . . . Number of Facilities a W 98.236(c)(19)(vii) For onshore petroleum and natural ga s 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 ga s 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" ((F gf ) 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" ((P gf ) 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" ((F lf )

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" ((P lp )

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" ((F lf )

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" ((P lp )

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" ((F sf )

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" ((P sp )

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" ((CC lf )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" ((CC lf )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 gase ous 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) Quan tity of each type of fuel us ed 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 fu els, 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 v olume 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 CO 2 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 th e 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

54Subpart Citation Data Element Data Element is used as Input to Equation . . . Number of Facilities a

Y 98.256(f)(11) Units of measure for the unit-specific CH 4 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 CH 4 : report the unit-specifi c emission factor for
CH 4 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 N 2 O was used: report the unit-specific emission factor
for N 2 O 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 N 2 O 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 recycl ing 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 co ke 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 CH 4 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 CH 4 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 N 2 O 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 N 2 O 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-s pecific emission factor for N 2 O 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) CO 2 emission factor for each asphalt blowing unit Y-14 145

Y 98.256(j)(6) CH 4 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 CO 2 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: CH 4 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

55Subpart Citation Data Element Data Element is used as Input to Equation . . . Number of Facilities a

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 pr oducts 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): CH 4 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 fa cility in the reporting year Y-22 145

Y 98.256(o)(4)(ii) For storage tanks that process unstabilized cr ude 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 unstabilize d crude oil: Average pressure differential

Y-23 145

Y 98.256(o)(4)(iv) For storage tanks that process unstabilize d 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 CH 4 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 CH 4 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 CH 4 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 CH 4 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 CH 4 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 CO 2 (ton CO 2 /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

56Subpart Citation Data Element Data Element is used as Input to Equation . . . Number of Facilities a 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 CO 2 used in equation AA-1 AA-1 110

AA 98.276(e) Default or site specific emission factor for CH 4 used in equation AA-1 AA-1 110

AA 98.276(e) Default or site specific emission factor for N 2 O 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 CaCO 3 used for the reporting year used in Equation AA-3 AA-3 110

AA 98.276(i) Make-up quantity of Na 2 CO 3 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) CO 2 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 CO 2 concentration during performance test (percent CO 2 ) for each manufacturing line
or stack CC-3 4

CC 98.296(b)(10)(iii) CO 2 emission factor of process vent flow from mine water for each manufacturing line or
stack CC-5 4

CC 98.296(b)(10)(iv) CO 2 emission mass emission rate during pe rformance test (metri c 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 fo r 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) charge d 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 el ectrode 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 el ectrode consumed in furnace “k” GG-1 6

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

57Subpart Citation Data Element Data Element is used as Input to Equation . . . Number of Facilities a

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 de cimal 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 de cimal fraction) (No CE MS) - 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 CH 4 concentration for eac h week that biogas is collected for destruction. (if using weekly sampling) II-4 151

II 98.356(d)(4) Weekly average temperat ure at which flow is measured for biogas collected for destruction (if using weekly sampling) II-4 151

II 98.356(d)(5) Weekly average moistu re 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 aver age waste disposal factor (WDF). TT-2 173

TT 98.466(c)(3)(iii) Average waste disposal factor (WDF) calculate d 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 Ava ilable 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 states 1 

# No data elements were identified as being publicly available
NEI/Federal
databases Subpart C is referenced in 26 other industrial process subparts 2 

# 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 facilities 3 

# 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 states 4 

# 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 Industria l, 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 in tegrated 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 h istory
online database.

4 

### CA, CT, CO, DE, FL, HI, IA, MA, MD, ME, NC, NJ, NM, NV, OR, WA, WI, WVE.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review60Table B-1A. Number of Facilities in the 2008 NEI that Report Combustion Data Identical to Subpart C “Inputs toEquations” (Summarized By Subpart)Data element withcitationSubpartEFGHKL N O P Q R S U V W XYZAABBCCEEGGIITTTotal quantity ofeach type of fuelcombusted duringthe reporting year[98.36(e)(2)(i), eq.C-1, C-1a, C-1b, C8]0 13721715190620a1742700 2 0 5 27HHV for each fuelcombusted, annualbasis[98.36(e)(2)(iv)(F),eq. C-8]0 0 1010802 80017a0438 00 0 0 3 2Blank cells denote the data element is not publicly available. Noother data elements were identical to the publicly availableinformation.aAn analysis of exact facility matches between the GHGRP and NEI was not completed due to the large number of facilities in thissubpart.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review61Table B-1B. Number of Facilities In Other Federal Databases (DOE, CAMD, eGRID)(a)That Report Combustion DataIdentical to Subpart C ”Inputs to Equations” (Summarized By Subpart)Data element with citationSubpartEFGHKLNOPQRSU VXYZAABBCCEEGGEstimateoftheheatinputfromeachtypeoffuel[98.36(b)(9)(iii),eq.C‐10;98.36(c)(2)(ix),eq.C‐10]3 1 3 3 11 2 25 58 146 6 11 1Totalquantityofeachtypeoffuelcombustedduringthereportingyear[98.36(e)(2)(i),eq.C‐1,C‐1a,C‐1b]6 1 3 3 11 2 25 54 146 6 11 1Totalquantityofeachtypeoffuelcombustedduringeachmonthofthereportingyear[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 54 146 6 11 1Total quantity of fossil fuel combusted foreach fuel combusted at units that combustboth fossil fuel and biomass, annual basis[98.36(e)(2)(ix)(F),eq.C‐13]3 1 3 3 9 1 23 51 122 6 11 1Blank cells denote the data element is not publicly available. Noother data elements were identical to the publicly availableinformation.(a) DOE = DOE Energy information administration database; CAMD = clean air markets divisionreports for units subject to the acid rain program; eGRID = Emissions & Generation ResourceIntegrated Database containing environmental characteristics of electrical power generated in the United States.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review62Table B-1C. Number of Facilities InThe Boiler Rule Development Dockets(c)That Report Combustion Data Identicalto Subpart C ”Inputs to Equations” (Summarized By Subpart)Data element with citationSubpart(a)F,K,Q,R,GG(331-primarymetals 3-digitNAICS)H, N, S(327-nonmetallicminerals 3-digitNAICS)E,G,L,O,P,V,X,Z,BB,CC,EE(325‐chemicalmanufacturing3‐digitNAICS)YAAHHV 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 MSWor solid fuel combustionduring each month of thereporting year [98.36(e)(2)(ii)(D), eq. C-2c]24HHV for each fuel combusted at units that combust bothfossil fuel and biomass, annual basis [98.36(e)(2)(ix)(E),eq. C-13]2(b)1(b)51Other data elements(d)Blank cells denote the data element is notpublicly available. No otherdata elements were identical to the publicly availableinformation.(a) The NAICS codes were used to align facilities in the boiler MACT database to part 98 subparts.Only three-digit NAICS codeswere providedinstead of the full NAICS codes; therefore, only general categories are known and it isnot possible to determine if a data element is specificallyavailable for a single subpart (other than for subparts Y and AA).(b) Facilities may have reported HHV,data element is available forsome 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) andthe NESHAPfor 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 monthof thereporting 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 ofthe reporting year in which carbon content and, if applicable, molecular weight determination is required, report a value of each parameter. Ifmultiple 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 combustboth fossil fuel and biomass, when biogenic CO2is 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 Review63Table B-1D. Summary of Information Reported and Publicly Available in EIA Forms for Electric Generators

SubpartCitationData ElementData Element isused as Input toEquation . . .Required to beReported (R) inEIA Form forFacility (F), Unit(U), orAggregated Units(A)1Can beCalculatedfrom DataRequired to beReported (R)or Public (P)InformationPubliclyAvailable (P)from EIA forFacility(F), Unit (U), orAggregatedUnits (A)1C 98.36(b)(9)(iii) Estimate of the heatinput from each type of fuel listed inTable C-2 that was combusted in theunit during the report yearC-102RC 98.36(c)(2)(ix) The flue gases from two or more stationary fuel combustion units at a facility are combinedtogether and discharged through a common stack or duct before exiting to the atmosphere and ifCEMS are used to continuously monitor CO2mass emissions at the common stack or ductaccording to the Tier 4 Calculation Methodology, you may report the combined emissions fromthe units sharing the common stack or duct, in lieu of separately reporting the GHG emissionsfrom the individual units. This monitoring and reporting alternative may also be used whenprocess off-gases or a mixture of combustion products and process gases are combined together ina common stack or duct before exiting to the atmosphere. An estimate of the heat input from eachtype of fuel listed in Table C-2 combusted during the reporting year.C-10C 98.36(e)(2)(i) Total quantity of each type of fuel combusted in each unit or group of aggregated units (asapplicable) during the reporting year, in short tons for solid fuels, gallons for liquid fuels andstandard cubic feet for gaseous fuels, or, if applicable, therms or mmBtu for natural gas.C-12F RC 98.36(e)(2)(i) Total quantity of each type of fuel combusted in each unit or group of aggregated units (asapplicable) during the reporting year, in short tons for solid fuels, gallons for liquid fuels andstandard cubic feet for gaseous fuels, or, if applicable, therms or mmBtu for natural gas.C-1a2F RC 98.36(e)(2)(i) Total quantity of each type of fuel combusted in each unit or group of aggregated units (asapplicable) during the reporting year, in short tons for solid fuels, gallons for liquid fuels andstandard cubic feet for gaseous fuels, or, if applicable, therms or mmBtu for natural gas.C-1b2F RC 98.36(e)(2)(i) Total quantity of each type of fuel combusted in each unit or group of aggregated units (asapplicable) during the reporting year, in short tons for solid fuels, gallons for liquid fuels andstandard cubic feet for gaseous fuels, or, if applicable, therms or mmBtu for natural gas.C-82F RC 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 fuelcombusted during the measurement period in short tons for solid fuels, gallons for liquid fuels,and scf for gaseous fuels.C-2bF, U, AFC 98.36(e)(2)(ii)(C) High heat values used in the CO2emissions calculations for each fuel combusted during thereporting year. Report a HHV value for each calendar month in which HHV determination isrequired. If multiple values are obtained in a given month, report the arithmetic average value forthe month.C-2bF, U, AC 98.36(e)(2)(ii)(D) If Eq. C-2c is used: Total quantity (i.e., pounds) of steam produced from MSW or solid fuelcombustion during each month of the reporting year,C-2cC 98.36(e)(2)(ii)(D) If Eq. C-2c is used: Ratio of the maximum rate heat input capacity to the design rated steamoutput capacity of the unitC-2cC 98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as applicable) during eachmonth of the reporting year (Fuel)C-3F, U, AFE.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review64

SubpartCitationData ElementData Element isused as Input toEquation . . .Required to beReported (R) inEIA Form forFacility (F), Unit(U), orAggregated Units(A)1Can beCalculatedfrom DataRequired to beReported (R)or Public (P)InformationPubliclyAvailable (P)from EIA forFacility(F), Unit (U), orAggregatedUnits (A)1C 98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as applicable) during eachmonth of the reporting year (Fuel)C-4F,U, AFC 98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as applicable) during eachmonth of the reporting year (Fuel)C-5F, U, AFC 98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as applicable) during eachmonth of the reporting year (Fuel)C-8F, U, AFC 98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as applicable) during eachmonth of the reporting year (Fuel)C-8aF, U, AFC 98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as applicable) during eachmonth of the reporting year (Fuel)C-8bF, U, AFC 98.36(e)(2)(iv)(A) Quantity of each type of fuel combusted in the unit or group of units (as applicable) during eachmonth of the reporting year (Fuel)C-13F, U, AFC 98.36(e)(2)(iv)(C) The carbon content used in the emission calculations (including both valid and substitute datavalues). For each calendar month of the reportingyear in which carbon content and, if applicable,molecular weight determination is required, report a value of each parameter. If multiple values ofa parameter are obtained in a given month, reportthe arithmetic average value for the month. (CC)C-3C 98.36(e)(2)(iv)(C) The carbon content used in the emission calculations (including both valid and substitute datavalues). For each calendar month of the reportingyear in which carbon content and, if applicable,molecular weight determination is required, report a value of each parameter. If multiple values ofa parameter are obtained in a given month, reportthe arithmetic average value for the month. (CC)C-4C 98.36(e)(2)(iv)(C) The carbon content used in the emission calculations (including both valid and substitute datavalues). For each calendar month of the reportingyear in which carbon content and, if applicable,molecular weight determination is required, report a value of each parameter. If multiple values ofa parameter are obtained in a given month, reportthe arithmetic average value for the month. (CC)C-5C 98.36(e)(2)(iv)(C) Gas molecular weight values used in the emission calculations (including both valid and substitutedata values). For each calendar month of the reporting year in which carbon content and, ifapplicable, molecular weight determination is required, report a value of each parameter. Ifmultiple values of a parameter are obtained in a given month, report the arithmetic average valuefor the month.C-5C 98.36(e)(2)(iv)(F) The annual average HHV, when measured HHV data, rather than a default HHV from Table C-1of this subpart, areused to calculate CH4and N2O emissions for a Tier 3unit, in accordance with§98.33(c)(1).C-82RC 98.36(e)(2)(ix)(D) For units that combust both fossil fuel and biomass, when biogenic CO2is determined accordingto §98.33(e)(2), report the carbon-based F-factor used in Equation C-13 of this subpartC-13C 98.36(e)(2)(ix)(E) For units that combust both fossil fuel and biomass, when biogenic CO2is determined accordingto §98.33(e)(2), report the annual average HHV value used in Equation C-13 of this subpartC-132RC 98.36(e)(2)(ix)(F) For units that combust both fossil fuel and biomass, when biogenic CO2is determined accordingto §98.33(e)(2), report the total quantity of fossil fuel combusted during the reporting year.C-132F RE.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review651Facility (F)wide data are required to be reported for plants with total nameplate capacity≥50 MW;Unit(U) information is required to be reported for steamboilers at plants with steam turbines (orcombined cycle plants for supplementary firing of HRSG units) that have a nameplate capacity≥10 MW;Aggregated(A) unit information (e.g., report natural gas consumed by all combustion turbines as one value and diesel fuel consumed by allIC engines as one value) for allgas turbines (including combined cycle plants), IC engines, and steam-electric plants < 10 MW.2Information 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 states 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 

### 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 states 1 

# 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 states 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 

### 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 states 1 

# 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 betwee n NEI and 2011 GHGRP reporters we re not assessed. The 21 facili ties 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 responsesfrom 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

states 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 

### 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 states 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) 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 states 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 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 states 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 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

programs 2 

# 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 fa cilities report annual quan tity 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 qua ntity 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
CO 2 

# 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 states 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) 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 states 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 

### 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 states 1 

# 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

programs 2 

# 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 states 1 

## 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 efficien cy [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 recipro cating 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 combus ted in external fuelcombustion units [98.236(c)(19)(iv), eq. W39A, W-39B, W-40] and internal fuelcombustion 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 stacks 3 

## : 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 programs 2 

## 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 andDistribution 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 CO 2 

## [98.236(c)(4)(i)(H)],
and Concentration of CH 4 

## [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 ma tches between the 1,550 subpart W facilit ies 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 states 1 

# 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 dur ing 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 combusti on 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

states 1 

# 6 permits provided the information on the number of catalytic cr acking 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 id entified 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 cycl es 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 id entified 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 states 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) 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 states 1 

# 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 inlime 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

programs 2 

# 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 ”I nputs to Equations” for Subpart BB

Source Description of Sources Reviewed Results

Permits 1 Title V permit (100% of identified sources) from 1 state 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 

### 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 state 1 

# 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 ”I nputs to Equations” for Subpart EE

Source Description of Sources Reviewed Results

Permits 4 Title V permits (50% of identified sources) from 2 states 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 

### 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 state 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 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 programs 2 

# 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 NonferrousMetals-- Zinc, Cadmium, and Beryllium (EPA-HQOAR-2006-0510)

 NESHAP: Area Source Stan dards for Aluminum,

Copper, and Other Nonfe rrous 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 states 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 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 mi lls 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 ”I nputs 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 InputsE.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review93Review of Sources Cited By Sierra Club that Provide Publicly Available Information for the 2015 Data InputsSubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceC98.36(b)(9)(iii)EstimateofheatinputEx.C1(Spreadsheet).Worksheet"ProcessDataOrganicsTesting"ColumnM.SurveyresponseExamplewheresourceshavereportedthisinformationpreviouslyYNDataavailableonaone‐timebasis.Surveyresponseisdailyaverageheatinput(MMBtu/hr)fora30dayperiodthatincludesatestingperiodforICRdatacollection,notannualinput.Datasourceisevaluatedinthepublicavailabilityanalysis.SeeAppendixB.C98.36(c)(2)(i)(x)AnestimateoftheheatinputfromeachtypeoffuelEx.C1(Spreadsheet).Worksheet"ProcessDataOrganicsTesting"ColumnM.SurveyresponseExamplewheresourceshavereportedthisinformationbeforeNNDataavailableonaone‐timebasis.Surveyresponseisdailyaverageheatinput(MMBtu/hr)fora30dayperiodthatincludesatestingperiodforICRdatacollection,notannualinput.C98.36(e)(2)(i)TotalquantityofeachtypeoffuelcombustedEx.C3,p.vii.U.S.DepartmentofEnergyEnergyInformationAdministrationFormEIA‐767(2005),STEAM‐ELECTRICPLANTOPERATIONANDDESIGNREPORTCommonreportingrequirementinallpermitsYNDataavailableonlyforelectricpowerplantswithcapacity>1MW,andconnectedtopowergrid.Datasourceisevaluatedinthepublicavailabilityanalysis.SeeAppendixB.C98.36(e)(2)(ii)(A)TotalmonthlyquantityofeachtypeoffuelcombustedEx.C3,p.vii.U.S.DepartmentofEnergyEnergyInformationAdministrationFormEIA‐767(2005),STEAM‐CommonreportingrequirementinallpermitsYNDataavailableonlyforelectricpowerplantswithcapacity>1MW,andconnectedtopowergrid.Datasourceisevaluatedinthepublicavailabilityanalysis.SeeAppendixB.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review94SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceELECTRICPLANTOPERATIONANDDESIGNREPORTC98.36(e)(2)(ii)(C)MonthlyhighheatvaluesusedintheCO2emissionscalculationsforeachtypeoffuelcombustedEx.C3,p.vii.;Seealsop.xxii.U.S.DepartmentofEnergyEnergyInformationAdministrationFormEIA‐767(2005),STEAM‐ELECTRICPLANTOPERATIONANDDESIGNREPORTHeatingvaluesforcommonfuelsareavailableinstandardreferenceYNDataavailableonlyforelectricpowerplantswithcapacity>1MW,andconnectedtopowergrid.Datasourceisevaluatedinthepublicavailabilityanalysis.SeeAppendixB.CEx.C4.SurveyresponseHeatingvaluesforcommonfuelsareavailableinstandardreferenceNNDataavailableonaone‐timebasis.SurveyresponseisdailyHigherHeatingValue(HHV)(asreceived)reportedforICRthreedayperiod.NotanexactmatchformonthlyHHVvalues.C98.36(e)(2)(ii)(D)Totalquantity(i.e.,pounds)ofsteamproducedfromMSWorsolidfuelcombustionduringtheyear,Ex.C1(Spreadsheet).Worksheet"ProcessDataOrganicsTesting"ColumnN.SurveyresponseNNDataavailableonaone‐timebasis.SurveyresponseisSteamOutput(1,000lbssteam/hr)hourlyaveragefora30dayperiodforICRdatacollection,notannualquantity.C98.36(e)(2)(ii)(D)RatioofthemaximumrateheatinputcapacitytothedesignratedsteamoutputcapacityoftheunitNonecitedNotprovidedArithmeticcalculation.NNNoevidencethatthisdataisavailable.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review95SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceC98.36(e)(2)(iv)(A)QuantityofeachtypeoffuelcombustedduringeachmonthEx.C1(Spreadsheet).Worksheet"ProcessDataOrganicsTesting"ColumnC.SurveyresponsePreviouslyreportedNNDataavailableonaone‐timebasis.Fuelconsumptionreportedforone30dayperiodforICRdatacollection,notquantityeachmonth.C98.36(e)(2)(iv)(A)Ex.C‐3.U.S.DepartmentofEnergyEnergyInformationAdministrationFormEIA‐767(2005),STEAM‐ELECTRICPLANTOPERATIONANDDESIGNREPORTPreviouslyreportedYNDataavailableonlyforelectricpowerplantswithcapacity>1MW,andconnectedtopowergrid.Datasourceisevaluatedinthepublicavailabilityanalysis.SeeAppendixB.C98.36(e)(2)(iv)(C)ALLThecarboncontentusedintheemissioncalculations(includingbothvalidandsubstitutedatavalues).Seehttp://bioenergy.ornl.gov/papers/misc/energy_conv.htmlwebsiteCarboncontentformostfuelsareavailableinstandardreferencesNNAveragecarboncontentoffossilfuelsandbioenergyfeedstocksareavailable,butindividualreporters’valuesarenotavailable.C98.36(e)(2)(iv)(C)ALLgasmolecularweightvaluesusedintheemissioncalculations(includingbothvalidandsubstitutedatavalues).Seehttp://www.engineeringtoolbox.com/molecular‐weight‐gas‐vapor‐d_1156.htmlwebsiteGasmolecularweightsareavailableinstandardreferencesNNReferencecontainsmolecularweightofpurefuels;doesnottakeintoaccountadditivesorimpuritiesfoundinfacilityspecificfuels.Informationnotpubliclyavailableforallmolecularweightvaluesused.C98.36(e)(2)(iv)(C)Monthlyaveragevaluesforcarboncontentusedintheemissioncalculations(includingbothvalidandsubstitutedataSeehttp://bioenergy.ornl.gov/papers/misc/energy_conv.htmlwebsiteCarboncontentformostfuelsareavailableinstandardreferencesNNAveragecarboncontentoffossilfuelsandbioenergyfeedstocksareavailable,butindividualreporters’monthlyaveragevaluesarenotavailable.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review96SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferencevalues).C98.36(e)(2)(iv)(C)Monthlyaveragevaluesforgasmolecularweightvaluesusedintheemissioncalculations(includingbothvalidandsubstitutedatavalues).Seehttp://www.engineeringtoolbox.com/molecular‐weight‐gas‐vapor‐d_1156.htmlwebsiteGasmolecularweightsareavailableinstandardreferencesNNReferencecontainsmolecularweightofpurefuels;doesnottakeintoaccountadditivesorimpuritiesfoundinfacilityspecificfuels.Informationnotpubliclyavailableformonthlyaveragevalue.C98.36(e)(2)(iv)(F)TheannualaveragemeasuredHHVdatausedtocalculateCH4andN2OemissionsNoreferenceprovidedNotprovidedHHVdataforcommonfuelsareavailableinstandardreferences.YNDefaultHHVvaluesareavailable;measuredHHVdataarenotpubliclyavailable.Datasourceisevaluatedinthepublicavailabilityanalysis.SeeAppendixB.C98.36(e)(2)(ix)(D)Carbon‐basedF‐factorusedinEquationC‐13ofthissubpartforeachfossilfuelEx.C4.,EPAMethod19SurveyresponseAvailableinregulationsasprovidedintheequationNNCarbonbasedF‐factornotavailableinreferenceddocumentonafacility/site‐specificbasis.C98.36(e)(2)(ix)(E)AnnualaverageHHVvalueusedinEquationC‐13ofthissubpartforeachfossilfuelNoreferenceprovidedNotprovidedArithmeticcalculation.NNFacilityspecificannualaverageHHVnotavailable.AveragecouldonlybedeterminedifindividualvaluesreportedC98.36(e)(2)(ix)(F)TotalquantityoffossilfuelcombustedduringthereportingyearNoreferenceprovidedNotprovidedArithmeticcalculation.NNNospecificreferenceprovided.TotalcouldonlybedeterminedifindividualvaluesreportedC98.36(e)(2)(x)(A)ResultsofeachquarterlysampleanalysisEx.C1(Spreadsheet).Worksheet"ProcessDataOrganicsTesting"ColumnC.SurveyresponseFuelcompositionisalreadybeingreportedNNDataavailableonaone‐timebasis.SurveyresponseincolumnCiscoalfiringrate(tons/hr).Notamatchforquarterlysampleanalysis.HHVanalysesavailableinsurveyforathreedayperiod.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review97SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceCEx.C‐3USDOE/EIAFormEIA‐767U.S.DepartmentofEnergyEnergyInformationAdministrationFormEIA‐767(2005),STEAM‐ELECTRICPLANTOPERATIONANDDESIGNREPORTFuelcompositionisalreadybeingreportedYNDataavailableonlyforelectricpowerplantswithcapacity>1MW,andconnectedtopowergrid.Datasourceisevaluatedinthepublicavailabilityanalysis.SeeAppendixB.C98.36(e)(2)(xi)98.36(e)(2)(xi)ResultsofeachquarterlysampleanalysisResultsofquarterlysampleanalysisEx.C1(Spreadsheet).Worksheet"ProcessDataOrganicsTesting"ColumnC.SurveyresponseFuelcompositionisalreadybeingreportedNNDataavailableonaone‐timebasis.SurveyresponseincolumnCiscoalfiringrate(tons/hr).Notamatchforquarterlysampleanalysis.HHVanalysesavailableinsurveyforathreedayperiod.Ex.C‐3USDOE/EIAFormEIA‐767U.S.DepartmentofEnergyEnergyInformationAdministrationFormEIA‐767(2005),STEAM‐ELECTRICPLANTOPERATIONANDDESIGNREPORTFuelcompositionisalreadybeingreportedNNDataavailableonlyforelectricpowerplantswithcapacity>1MW,andconnectedtopowergrid.Datasourceisevaluatedinthepublicavailabilityanalysis.SeeAppendixB.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review98SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceH98.86(b)(2)Monthlyclinkerproduction(NoCEMS)Ex.CEM1:HolcimRomaniapaper2002,p.23Romanianstudypapertitled"JI‐ProjectforreductionofCO2emissionsatAlesdCementPlantandCampulungCementPlant"Canbecalculatedorestimatedfromcementproductionbyassumingtypicalfactororbydirectmeasurement.ReportedinEurope.NNMonthlyclinkerproductionnotavailable.Thisreportdoesnotcontainactualclinkerproductionforthe2Romanianfacilities(onlydailycapacities).H98.86(b)(5)QuarterlyquantityofCKDnotrecycledtothekilnEx.CEM6:AshgroveDurkee(example)EPA‐HQ‐OAR‐2002‐0051‐3572,p.4Section114requestforAshGroveCementCompany'sfacilityinDurkee,OR;documentlocatedindocketforPortlandCementManufacturingNESHAP(A‐92‐53)SimilartopreviouslyreportedbycompaniesaspartofNESHAPICRNNDataavailableonaone‐timebasis.Surveyresponseisannualbaghousereturndustforoneyear.DoesnotprovideexactmatchtoquarterlyCKDrecycledtothekiln.H98.86(b)(6)MonthlyfractionoftotalCaOinclinkerEx.CEM1:HolcimRomaniapaper2002,p.26Romanianstudypapertitled"JI‐ProjectforreductionofCO2emissionsatAlesdCementPlantandCampulungCementPlant"EssentiallyannualaveragereportedandinpublicdomainNNMonthlyfractionoftotalCaOinclinkernotavailable.ThetypicalpercentCaOfromclinkerforyear2000providedforeachoftheRomanianfacilities[pg.26].E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review99SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceH98.86(b)(6)MonthlyfractionoftotalMgOinclinkerEx.CEM1:HolcimRomaniapaper2002,p.26Romanianstudypapertitled"JI‐ProjectforreductionofCO2emissionsatAlesdCementPlantandCampulungCementPlant"EssentiallyannualaveragereportedandinpublicdomainNNMonthlyfractionoftotalMgOinclinkernotavailable.ThetypicalpercentMgOfromclinkerforyear2000isprovidedforeachoftheRomanianfacilities[pg.26].H98.86(b)(6)Monthlyfractionofnon‐calcinedCaOinclinkerEx.CEM1:HolcimRomaniapaper2002,p.26Romanianstudypapertitled"JI‐ProjectforreductionofCO2emissionsatAlesdCementPlantandCampulungCementPlant"EssentiallyannualaveragereportedandinpublicdomainNNMonthlyfractionofnon‐calcinedCaOinclinkernotavailable.ThetypicalpercentCaOfromclinkerforyear2000isprovidedforeachoftheRomanianfacilities[pg.26].H98.86(b)(6)Monthlyfractionofnon‐calcinedMgOinclinkerEx.CEM1:HolcimRomaniapaper2002,p.26Romanianstudypapertitled"JI‐ProjectforreductionofCO2emissionsatAlesdCementPlantandCampulungCementPlant"EssentiallyannualaveragereportedandinpublicdomainNNMonthlyfractionofnon‐calcinedMgOinclinkernotavailable.ThetypicalpercentCaOfromclinkerforyear2000isprovidedforeachoftheRomanianfacilities[pg.26H98.86(b)(8)QuarterlyfractionoftotalCaOinCKDnotrecycledtothekilnEx.CEM7:Prof.WalshPowerpoint,DalhousieUniversityPowerPointslidestitled"InvestigationintotheUseofCKDforWastewaterTreatment";AlreadyreportedandinpublicdomainNNDataavailableonaone‐timebasis,notaquarterlyanalysis.ReferencecontainstheCaOcontenttypicalofCKDsamplesfrom6facilities[pg.19];IncludespreviouslypublishedworkfromPeethamparanetal.,2008withCaOcontent(wt%)of4CKDsamples(noE.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review100SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferencePresentedatPortlandCementAssociation'sManufacturingTechnicalCommitteeMeetingbyM.E.WalshandC.B.Lake,Dept.ofCivil&ResourceEngineering,DalhousieUniversity(NovaScotia,Canada)samplelocationsprovided)[pg.20],andTodresetal.,1992withCaOcontent(wt%)of3CKDsamples(nosamplelocationsprovided)[pg.21].Doesnotindicateifitisrecycledtokiln.H98.86(b)(8)QuarterlyfractionoftotalMgOinCKDnotrecycledtothekilnEx.CEM7:Prof.WalshPowerpoint,DalhousieUniversityPowerPointslidestitled"InvestigationintotheUseofCKDforWastewaterTreatment";PresentedatPortlandCementAssociation'sManufacturingTechnicalCommitteeMeetingbyM.E.WalshandC.B.Lake,Dept.ofCivil&ResourceEngineering,DalhousieUniversity(NovaScotia,AlreadyreportedandinpublicdomainNNDataavailableonaone‐timebasis,notaquarterlyanalysis.MgOcontent(wt%)ofCKDsamplesfrom6facilities[pg.19];IncludespreviouslypublishedworkfromPeethamparanetal.,2008withMgOcontent(wt%)of4CKDsamples(nosamplelocationsprovided)[pg.20],andTodresetal.,1992withMgOcontent(wt%)of3CKDsamples(nosamplelocationsprovided)[pg.21].Doesnotindicateifitisrecycledtokiln.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review101SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceCanada)H98.86(b)(8)Quarterlyfractionofnon‐calcinedCaOinCKDnotrecycledtothekilnEx.CEM7:Prof.WalshPowerpoint,DalhousieUniversityPowerPointslidestitled"InvestigationintotheUseofCKDforWastewaterTreatment";PresentedatPortlandCementAssociation'sManufacturingTechnicalCommitteeMeetingbyM.E.WalshandC.B.Lake,Dept.ofCivil&ResourceEngineering,DalhousieUniversity(NovaScotia,Canada)AlreadyreportedandinpublicdomainNNDataavailableonaone‐timebasis,notaquarterlyanalysis.MgOcontent(wt%)ofCKDsamplesfrom6facilities[pg.19];IncludespreviouslypublishedworkfromPeethamparanetal.,2008withMgOcontent(wt%)of4CKDsamples(nosamplelocationsprovided)[pg.20],andTodresetal.,1992withMgOcontent(wt%)of3CKDsamples(nosamplelocationsprovided)[pg.21].Doesnotindicateifitisrecycledtokiln.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review102SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceH98.86(b)(8)Quarterlyfractionofnon‐calcinedMgOinCKDnotrecycledtothekilnEx.CEM7:Prof.WalshPowerpoint,DalhousieUniversityPowerPointslidestitled"InvestigationintotheUseofCKDforWastewaterTreatment";PresentedatPortlandCementAssociation'sManufacturingTechnicalCommitteeMeetingbyM.E.WalshandC.B.Lake,Dept.ofCivil&ResourceEngineering,DalhousieUniversity(NovaScotia,Canada)AlreadyreportedandinpublicdomainNNDataavailableonaone‐timebasis,notaquarterlyanalysis.MgOcontent(wt%)ofCKDsamplesfrom6facilities[pg.19];IncludespreviouslypublishedworkfromPeethamparanetal.,2008withMgOcontent(wt%)of4CKDsamples(nosamplelocationsprovided)[pg.20],andTodresetal.,1992withMgOcontent(wt%)of3CKDsamples(nosamplelocationsprovided)[pg.21].DoesnotindicateifitisrecycledtokilnH98.86(b)(10)Monthlykiln‐specificclinkerCO2emissionfactorsNonecitedNotprovidedCO2dataisfromCEMSandisthereforeemissions.Productiondatafromrecordkeeping.NodataprovidedNNoevidencethatthisdataisavailableH98.86(b)(11)Quarterlykiln‐specificCKDCO2emissionfactorsNonecitedNotprovidedCO2dataisfromCEMSandisthereforeemissions.Productiondatafromrecordkeeping.nodataprovidedNNoevidencethatthisdataisavailableE.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review103SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceH98.86(b)(12)AnnualorganiccarboncontentofeachrawkilnfeedorannualorganiccarboncontentofeachrawmaterialEx.CEM6:AshgroveDurkee(example)EPA‐HQ‐OAR‐2002‐0051‐3572,lastseveralpages.Section114requestforAshGroveCementCompany'sfacilityinDurkee,OR;documentlocatedindocketforPortlandCementManufacturingNESHAP(A‐92‐53)PreviouslyreportedbycompaniesaspartofNESHAPsICRYNDataavailableonaone‐timebasis.Surveyresponseistotalorganiccarboncontent(inppm)ofrawmaterials(limestone,shale,clay,iron)fromdailysamplingin2006and2007(30samplestotal);Returndustcarboncontent(inppm)alsoprovidedfor2006only(30samplestotal)[pgs.13‐16].Datasourceisevaluatedinthepublicavailabilityanalysis.SeeAppendixB.H98.86(b)(13)AnnualconsumptionofeachrawkilnfeedorannualconsumptionofeachrawmaterialsEx.CEM6:AshgroveDurkee(example)EPA‐HQ‐OAR‐2002‐0051‐3572,p.4Section114requestforAshGroveCementCompany'sfacilityinDurkee,OR;documentlocatedindocketforPortlandCementManufacturingNESHAP(A‐92‐53)PreviouslyreportedbycompaniesaspartofNESHAPsICRYNDataavailableonaone‐timebasis.Surveyresponseis2006usageofrawmaterials[limestone,shale,clay,slag(ironsource)]intons[pg.4].Datasourceisevaluatedinthepublicavailabilityanalysis.SeeAppendixB.H98.86(b)(15)Monthlykiln‐specificclinkerfactors(ifused)foreachkilnEx.CEM1:HolcimRomaniapaper2002,p.23Romanianstudypapertitled"JI‐ProjectforreductionofCO2emissionsatAlesdCementPlantandCampulungReportedpreviouslyforkilnsinEurope.NNMonthlykiln‐specificclinkerfactorsnotavailable.AsingleclinkerfactorisprovidedforeachoftheRomanianfacilities[pg.23].E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review104SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceCementPlant"Q98.176(b)AnnualproductionquantityforproductsEx.S1:EPA‐HQ‐OAR‐2004‐008‐0058NucorPlymouth,p.8/86(pdf).Ex.S2,p.2/76(pdf).StacktestresultsandassociatedrequirementsforTitleVoperationpermitforNucorSteel(PObox100,WestCemeteryRoad,PlymouthUT84330),PreviouslypubliclyreportedYNDataavailableonaone‐timebasis.StacktestingisrequiredfortheferroalloyindustryasaninitialrequirementundertheNSPSandMACTstandards.Testresultsprovideannualamountofscrapchargedforpreviousthreeyears.Norequirementforannualproductiondatatobereported.Datasourceisevaluatedinthepublicavailabilityanalysis.SeeAppendixB.SurveyResponsePreviouslypubliclyreportedYNDataavailableonaone‐timebasis.Surveyresponseincludestotalproductionofrawsteelfor2003intons,hourlyproductionrateforeachbaghouse.SubmittedaspartofSection114request,availableinDocket:EPA‐HQ‐OAR‐2004‐0083.Datasourceisevaluatedinthepublicavailabilityanalysis.SeeAppendixB.Q98.176(e)(1)CarboncontentofprocessinputstodetermineCO2emissionsMaterialsafetydatasheet(MSDS)(didnotofferaspecificMSDSasanexample,butreferredtoMSDSforcoalorcoke)Materialsafetydatasheet(MSDS)Generallyknown(forcoal,petcoke,scrap,ironore,limestone,fluxes,etc.)fromMSDSs.NNCarboncontentofallprocessinputsisnotavailable.AnMSDSliststypicalmaterialcompositionformaterialsbypercentweight.Compositionalinformationonhazardouscomponentsarerequired,reportingthe%ofothercomponentsisvoluntary.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review105SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceQ98.176(e)(1)CarboncontentofprocessoutputstodetermineCO2emissionsMaterialsafetydatasheet(MSDS)(didnotofferaspecificsheetasanexample)Materialsafetydatasheet(MSDS)Generallyknown(forsteels,slag,etc.).FromMSDSs.NNCarboncontentofallprocessoutputsisnotavailable.AnMSDSlisttypicalmaterialcompositionforproductsbypercentweight.Compositionalinformationonhazardouscomponentsarerequired,reportingthe%ofothercomponentsisvoluntaryQ98.176(e)(3)AnnualvolumeofeachtypeofgaseousfuelusedtodetermineCO2emissions(reportedseparatelyforeachtypeinstandardcubicfeet)UtilitybillsNotprovidedKnownfromutilitybills,forexampleNNAnnualvolumeofgaseousfueltothefacility(notbyprocessasrequiredinPart98)willbeavailableonutilitybills.Utilitybillsarenotgenerallypubliclyavailable.Q98.176(e)(3)AnnualvolumeofeachtypeofliquidfuelusedtodetermineCO2emissions(reportedseparatelyforeachtypeingallons)UtilitybillsNotprovidedKnownfromutilitybills,forexampleNNVolumeofliquidfuelbyprocessisnotavailable.Annualvolumeofliquidfueltothefacilitywillbeavailableonsupplierbills,howeverthesebillsarenotgenerallypubliclyavailable.Q98.176(e)(3)Annualmass(inmetrictons)ofeachallotherprocessinputsandoutputsusedtodetermineCO2emissionsNoneNotprovidedThisistoogeneral.Noneedforlessercontributinginputsandoutputsforthemassbalance.NNNoevidencethatthisdataisavailableQ98.176(e)(4)MolecularweightofgaseousfuelsNoneNotprovided BasicchemistryNNMolecularweightofpuregaseousfuelsisbasicchemistry,andcaneasilybefoundinreferencematerials.However,compositionofspecificfuelsusedbythefacilityarenotavailable.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review106SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceQ98.176(f)(1)MeasuredaveragehourlyCO2emissionrateduringthetestNoneNotprovidedDirectEmissionsDataNNNoevidencethatthisdataisavailableQ98.176(f)(2)AveragehourlyfeedorproductionrateEx.S1:EPA‐HQ‐OAR‐2004‐008‐0058NucorPlymouth,p.8/86(pdf).StacktestresultsPreviouslypubliclyreportedYNDataavailableonaone‐timebasis.StacktestingisrequiredfortheferroalloyindustryasaninitialrequirementundertheNSPSandMACTstandards.Testresultsprovideaveragehourlyfeedrateduringthetest.Datasourceisevaluatedinthepublicavailabilityanalysis.SeeAppendixB.Q98.176(f)(3)Site‐specificemissionfactorNoneNotprovided DerivedfromcalculationusingdataaboveandbelowNNDataelementscitedbycommenterthatarerequiredtoperformthiscalculationarenotpubliclyavailable.Q98.176(f)(4)AnnualfeedorproductionrateusedtoestimateannualCO2emissionsEx.S1:EPA‐HQ‐OAR‐2004‐008‐0058NucorPlymouth,p.8/86(pdf).StacktestresultsPreviouslypubliclyreportedNNDataavailableonaone‐timebasis.StacktestingisrequiredfortheferroalloyindustryasaninitialrequirementundertheNSPSandMACTstandards.Testresultsprovideannualamountofscrapchargedforpreviousthreeyears.Norequirementforannualproductiondatatobereported.Q98.176(g)Theannualamountofcoalchargedtothecokeovens(inmetrictons).DeliveriesNotprovidedCanbeascertainedbytrackingdeliveries(trains,trucks,etc.andbymakingreasonableassumptions)NNNoevidencethatthisdataisavailable.Deliveriesofcoalisnotpubliclyavailableinformation.Q98.176(h)Forflaresburningcokeovengasorblastfurnacegas,theinformationspecifiedin§98.256(e)ofsubpartY(PetroleumRefineries)ofthispart.1Seereferencesat98.256(e)Seereferencesat98.256(e)SeerefineriesSee98.256(e)See98.256(e)See98.256(e)W98.236(c)(1)(i)Actualcountofnaturalgaspneumatichighbleeddevices.NationalEmissionStandards(NESHAP)SubpartHHandNSPSSubpartKKKRegulationEPArequiresfugitiveemissionsreportingfortheoilandgasindustryundertheNationalEmissionStandardsforNNSubpartHHandKKKrequireaNOCSreportincludingthecountofallancillaryequipmentinfugitiveemissionsprogram.NaturalgaspneumatichighbleeddevicesarenotspecificallynamedE.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review107SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceHazardousAirPollutants(NESHAP),SubpartHHforOilandGasandNSPSSubpartKKKforgasprocessingplants.intherule.W98.236(c)(1)(i)Estimatedcountofnaturalgaspneumatichighbleeddevices.NationalEmissionStandards(NESHAP)SubpartHHandNSPSSubpartKKKRegulationEPArequiresfugitiveemissionsreportingfortheoilandgasindustryundertheNationalEmissionStandardsforHazardousAirPollutants(NESHAP),SubpartHHforOilandGasandNSPSSubpartKKKforgasprocessingplants.NNSubpartHHandKKKrequireaNOCSreportincludingthecountofallancillaryequipmentinfugitiveemissionsprogram.Naturalgaspneumatichighbleeddevicesarenotspecificallynamedintherule.W98.236(c)(1)(ii)Actualcountofnaturalgaspneumaticlowbleeddevices.NationalEmissionStandards(NESHAP)SubpartHHandNSPSSubpartKKKRegulationEPArequiresfugitiveemissionsreportingfortheoilandgasindustryundertheNationalEmissionStandardsforHazardousAirPollutants(NESHAP),SubpartHHforOilandGasandNSPSSubpartKKKforgasprocessingplants.NNSubpartHHandKKKrequireaNOCSreportincludingthecountofallancillaryequipmentinfugitiveemissionsprogram.Naturalgaspneumaticlowbleeddevicesarenotspecificallynamedintherule.W98.236(c)(1)(ii)Estimatedcountofnaturalgaspneumaticlowbleeddevices.NationalEmissionStandards(NESHAP)SubpartHHandNSPSSubpartKKKRegulationEPArequiresfugitiveemissionsreportingfortheoilandgasindustryundertheNationalEmissionStandardsforHazardousAirPollutants(NESHAP),SubpartHHforOilandGasandNSPSSubpartKKKforgasprocessingplants.NNSubpartHHandKKKrequireaNOCSreportincludingthecountofallancillaryequipmentinfugitiveemissionsprogram.Naturalgaspneumaticlowbleeddevicesarenotspecificallynamedintherule.W98.236(c)(1)(iii)Actualcountofnaturalgaspneumaticintermittentbleeddevices.NationalEmissionStandards(NESHAP)SubpartHHandNSPSSubpartKKKRegulationEPArequiresfugitiveemissionsreportingfortheoilandgasindustryundertheNationalEmissionStandardsforHazardousAirPollutants(NESHAP),SubpartHHforOilandGasandNSPSSubpartKKKNNSubpartHHandKKKrequireaNOCSreportincludingthecountofallancillaryequipmentinfugitiveemissionsprogram.Naturalgaspneumaticintermittentbleeddevicesarenotspecificallynamedintherule.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review108SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceforgasprocessingplants.W98.236(c)(1)(iii)Estimatedcountofnaturalgaspneumaticintermittentbleeddevices.NationalEmissionStandards(NESHAP)SubpartHHandNSPSSubpartKKKRegulationEPArequiresfugitiveemissionsreportingfortheoilandgasindustryundertheNationalEmissionStandardsforHazardousAirPollutants(NESHAP),SubpartHHforOilandGasandNSPSSubpartKKKforgasprocessingplants.NNSubpartHHandKKKrequireaNOCSreportincludingthecountofallancillaryequipmentinfugitiveemissionsprogram.Naturalgaspneumaticintermittentbleeddevicesarenotspecificallynamedintherule.W98.236(c)(2)(i)Countofnaturalgasdrivenpneumaticpumps.NationalEmissionStandards(NESHAP)SubpartHHandNSPSSubpartKKKRegulationEPArequiresfugitiveemissionsreportingfortheoilandgasindustryundertheNationalEmissionStandardsforHazardousAirPollutants(NESHAP),SubpartHHforOilandGasandNSPSSubpartKKKforgasprocessingplants.NNSubpartHHandKKKrequireaNOCSreportincludingthecountofallancillaryequipmentinfugitiveemissionsprogram.Pumpsarelistedancillaryequipment,althoughthespecificpumptypeisnotrequired.Dataelementevaluatedinpublicavailabilityanalysis,seeAppendixB.AttachmentNo.5‐1BOEMREAirEmissionReporting.pdf[Title30:MineralResources;PART250—OILANDGASANDSULPHUROPERATIONSINTHEOUTERCONTINENTALSHELF;SubpartB—PlansandInformation;ContentsofDevelopmentandProductionPlans(DPP)andDevelopmentOperationsCoordinationDocuments(DOCD)]eCFR;BOEMRERegulationsat30CFR250.513YNDataonnaturalgasdrivenpumpsiscollectedbyBOEMREforoffshorefacilitiesbutnotpubliclyavailableinthegulfwideinventory.Dataelementevaluatedinpublicavailabilityanalysis,seeAppendixB.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review109SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceW98.236(c)(3)(i)Totalthroughputofeachacidgasremovalunitusingameterorengineeringestimatebasedonprocessknowledgeorbestavailabledata.AttachmentNo.4‐1NorthDakotaAmineUnitAppl.PDF(PERMITAPPLICATION‐NATURALGASPROCESSINGSWEETENINGOPERATIONS,NORTHDAKOTADEPARTMENTOFHEALTHDIVISIONOFAIRQUALITY)OperatingPermitApplicationsSomestatesrequireamineunitdatatobereportedtotheirdepartmentofpublichealth,forexampleNNDatareportedisdesignflowratetotheunit,nottotalactualthroughput.NewSourcePerformanceStandardSubpartLLRegulationSubpartLLrequiresreportingforgassweeteningunitsandsulfurrecoveryunits.NNNSPSsubpartLLisStandardsofperformanceforMetallicMineralProcessingPlantsandisnotapplicabletooilandgas.AttachmentNo.5‐1BOEMREAirEmissionReporting.pdf[Title30:MineralResources;PART250—OILANDGASANDSULPHUROPERATIONSINTHEOUTERCONTINENTALSHELF;SubpartB—PlansandInformation;ContentsofDevelopmentandProductionPlans(DPP)andDevelopmentOperationsCoordinationDocuments(DOCD)]eCFR;BOEMRERegulationsat30CFR250.513YNThroughputdataiscollectedbutnotpubliclyavailableinthegulfwideinventory.Dataelementevaluatedinpublicavailabilityanalysis,seeAppendixB.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review110SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceW98.236(c)(3)(ii)ForCalculationMethodology2of§98.233(d),annualaveragefractionofCO2contentintheventfromeachacidgasremovalunit.AttachmentNo.4‐1NorthDakotaAmineUnitAppl.PDF(PERMITAPPLICATION‐NATURALGASPROCESSINGSWEETENINGOPERATIONS,NORTHDAKOTADEPARTMENTOFHEALTHDIVISIONOFAIRQUALITY)OperatingPermitApplicationsTheCO2contentoftheventedgasinnotproprietarybusinessdataandwillnotcreateaneconomicorstrategicdisadvantagetoacompanyifdisclosedtothepublicatthistime.TheCO2contentmaybereportedtolocal,stateorfederalagenciesaspartofaprojectdescriptionorbypermitNNPermitapplicationrequiresCO2concentration.Theannualaverageconcentrationisnotreported.W98.236(c)(3)(iii)ForCalculationMethodology3of§98.233(d),annualaveragevolumefractionofCO2contentofnaturalgasintoeachacidgasremovalunit.AttachmentNo.4‐1NorthDakotaAmineUnitAppl.PDF(PERMITAPPLICATION‐NATURALGASPROCESSINGSWEETENINGOPERATIONS,NORTHDAKOTADEPARTMENTOFHEALTHDIVISIONOFAIRQUALITY)OperatingPermitApplicationsTheCO2contentoftheventedgasinnotproprietarybusinessdataandwillnotcreateaneconomicorstrategicdisadvantagetoacompanyifdisclosedtothepublicatthistime.TheCO2contentmaybereportedtolocal,stateorfederalagenciesaspartofaprojectdescriptionorbypermitNNPermitapplicationrequiresCO2concentration.Theannualaverageconcentrationisnotreported.W98.236(c)(3)(iv)AnnualquantityofCO2,thatwasrecoveredfromeachacidgasremovalunitandtransferredoutsidethefacility(metrictonsCO2e),undersubpartPPofthispart.AttachmentNo.4‐1NorthDakotaAmineUnitAppl.PDF(PERMITAPPLICATION‐NATURALGASPROCESSINGSWEETENINGOPERATIONS,NORTHDAKOTADEPARTMENTOFHEALTHDIVISIONOFAIRQUALITY)OperatingPermitApplicationsTheCO2contentoftheventedgasinnotproprietarybusinessdataandwillnotcreateaneconomicorstrategicdisadvantagetoacompanyifdisclosedtothepublicatthistime.TheCO2contentmaybereportedtolocal,stateorfederalagenciesaspartofaprojectdescriptionorbypermitNNPermitapplicationdoesnotrequirereportingofCO2recoveredandtransferred.W98.236(c)(4)(i)(A)Foreachglycoldehydratorwiththroughputgreaterthanorequalto0.4MMscfd:GlycolAttachmentNo.1‐5UtahGasDispositionReport.pdf(StateofUtahMonthlyOilandGasDispositionReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNGlycoldehydratorfeedrateisnotrequiredonthisreport.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review111SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferencedehydratorfeednaturalgasflowrateinMMscfd,determinedbyengineeringestimatebasedonbestavailabledata.AttachmentNo.1‐6LouisianaGasDispositionReport.pdf(StateofLouisianaMonthlyOilandGasDispositionReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNGlycoldehydratorfeedrateisnotrequiredonthisreport.AttachmentNo.1‐7AlaskaGasDispositionReporting.xls(AlaskaDepartmentofRevenue(ADOR)AS43.55MonthlyInformationReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNGlycoldehydratorfeedrateisnotrequiredonthisreport.AttachmentNo.1‐9NorthDakotaGasandComposition.pdf(OIL/GASPRODUCTIONFACILITYREGISTRATION,NORTHDAKOTADEPARTMENTOFHEALTH,DIVISIONOFAIRQUALITY)OperatingPermitApplicationsGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNGlycoldehydratorfeedrateisnotrequiredonthisreport.AttachmentNo.2‐6ColoradoAirPermitApp.PDF(OperatingPermitApplication,ColoradoDepartmentofPublicHealthandEnvironment,AirPollutionControlDivision)OperatingPermitApplicationsGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNForm2000‐307concernsdehydrators.Naturalgasflowrateisnotrequired.Dataonregeneratorheatingrate(MMBtu/hr),glycolcirculationrate,glycoltype,controltechnology,gaspressure,gastemperature,andgascompositionarerequired.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review112SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceAttachmentNo.5‐1BOEMREAirEmissionReporting.pdf[Title30:MineralResources;PART250—OILANDGASANDSULPHUROPERATIONSINTHEOUTERCONTINENTALSHELF;SubpartB—PlansandInformation;ContentsofDevelopmentandProductionPlans(DPP)andDevelopmentOperationsCoordinationDocuments(DOCD)]eCFR;BOEMRERegulationsat30CFR250.513BOEMRERegulationsat30CFR250.513requiresairemissionreporting,includingthebasisforallcalculationsYYTotalgasthroughputisreported.Requirestheoperatortoreportadescriptionofprocesses,processingequipment,combustionequipment,fuels,andstorageunits.Dataelementisevaluatedinpublicavailabilityanalysis,seeAppendixB.AttachmentNo.5‐2ColoradoAirPermitApp.pdf(OperatingPermitApplication;ColoradoDepartmentofPublicHealthandEnvironmentAirPollutionControlDivision)OperatingPermitApplicationsColoradoDepartmentofPublicHealthandEnvironment,AirPollutionControlDivision,OperatingPermitApplications,requiresdetailedinformationongasdehydratorequipmentNNNaturalgasflowrateisnotrequiredinthisapplication.Form2000‐307concernsdehydrators.Dataonregeneratorheatingrate(MMBtu/hr),glycolcirculationrate,glycoltype,controltechnology,gaspressure,gastemperature,andgascompositionarerequired.AttachmentNo.5‐3NorthDakotaGlycolDehydratorReport.pdf(PERMITAPPLICATION‐GLYCOLDEHYDRATIONUNITSNORTHDAKOTADEPARTMENTOFHEALTHDIVISIONOFAIRQUALITY)OperatingPermitApplicationsNorthDakotaDepartmentofPublicHealth,DivisionofAirQuality,OperatingPermitApplications,requiresdetailedinformationongasdehydratorequipmentNNThisisaone‐timepermitapplication.Actualthroughput(design)isrequiredinthepermitapplication,butisnotanannualreportingrequirement.Thepermitapplicationrequiresoperatorstoreportthedesigncapacity,actualthroughput,andVOCemissionsfromglycoldehydrationunits.W98.236(c)(4)(i)(B)Foreachglycoldehydratorwiththroughputgreaterthanorequalto0.4MMscfd:GlycolAttachmentNo.1‐5UtahGasDispositionReport.pdf(StateofUtahMonthlyOilandGasDispositionReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNGlycoldehydratorabsorbentcirculationpumptypeisnotrequiredinthereport.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review113SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferencedehydratorabsorbentcirculationpumptype.AttachmentNo.1‐6LouisianaGasDispositionReport.pdf(StateofLouisianaMonthlyOilandGasDispositionReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNGlycoldehydratorabsorbentcirculationpumptypeisnotrequiredinthereport.AttachmentNo.1‐7AlaskaGasDispositionReporting.xls(AlaskaDepartmentofRevenue(ADOR)AS43.55MonthlyInformationReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNGlycoldehydratorabsorbentcirculationpumptypeisnotrequiredinthereport.AttachmentNo.1‐9NorthDakotaGasandComposition.pdf(OIL/GASPRODUCTIONFACILITYREGISTRATION,NORTHDAKOTADEPARTMENTOFHEALTH,DIVISIONOFAIRQUALITY)OperatingPermitApplicationsGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNGlycoldehydratorabsorbentcirculationpumptypeisnotrequiredinthereport.AttachmentNo.2‐6ColoradoAirPermitApp.PDF(OperatingPermitApplication,ColoradoDepartmentofPublicHealthandEnvironment,AirPollutionControlDivision)OperatingPermitApplicationsGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNGlycoldehydratorabsorbentcirculationpumptypeisnotrequiredinthepermitapplication.Form2000‐307concernsdehydrators.Dataonregeneratorheatingrate(MMBtu/hr),glycolcirculationrate,glycoltype,controltechnology,gaspressure,gastemperature,andgascompositionarerequired.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review114SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceAttachmentNo.5‐1BOEMREAirEmissionReporting.pdf[Title30:MineralResources;PART250—OILANDGASANDSULPHUROPERATIONSINTHEOUTERCONTINENTALSHELF;SubpartB—PlansandInformation;ContentsofDevelopmentandProductionPlans(DPP)andDevelopmentOperationsCoordinationDocuments(DOCD)]eCFR;BOEMRERegulationsat30CFR250.513BOEMRERegulationsat30CFR250.513requiresairemissionreporting,includingthebasisforallcalculationsNNPumptypeisnotrequiredinthereport.Requirestheoperatortoreportadescriptionofprocesses,processingequipment,combustionequipment,fuels,andstorageunits.AttachmentNo.5‐2ColoradoAirPermitApp.pdf(OperatingPermitApplication;ColoradoDepartmentofPublicHealthandEnvironmentAirPollutionControlDivision)OperatingPermitApplicationsColoradoDepartmentofPublicHealthandEnvironment,AirPollutionControlDivision,OperatingPermitApplications,requiresdetailedinformationongasdehydratorequipmentNNPumptypeisnotrequiredinthepermitapplication.Form2000‐307concernsdehydrators.Dataonregeneratorheatingrate(MMBtu/hr),glycolcirculationrate,glycoltype,controltechnology,gaspressure,gastemperature,andgascompositionarerequired.AttachmentNo.5‐3NorthDakotaGlycolDehydratorReport.pdf(PERMITAPPLICATION‐GLYCOLDEHYDRATIONUNITSNORTHDAKOTADEPARTMENTOFHEALTHDIVISIONOFAIRQUALITY)OperatingPermitApplicationsNorthDakotaDepartmentofPublicHealth,DivisionofAirQuality,OperatingPermitApplications,requiresdetailedinformationongasdehydratorequipmentNNPumptypeisnotrequiredinthepermitapplication.Thepermitapplicationrequiresoperatorstoreportthedesigncapacity,actualthroughput,andVOCemissionsfromglycoldehydrationunits.W98.236(c)(4)(i)(C)Foreachglycoldehydratorwiththroughputgreaterthanorequalto0.4MMscfd:ReportAttachmentNo.1‐5UtahGasDispositionReport.pdf(StateofUtahMonthlyOilandGasDispositionReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydrators.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review115SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferencewhetherstrippergasisusedinglycoldehydrator.AttachmentNo.1‐6LouisianaGasDispositionReport.pdf(StateofLouisianaMonthlyOilandGasDispositionReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydrators.AttachmentNo.1‐7AlaskaGasDispositionReporting.xls(AlaskaDepartmentofRevenue(ADOR)AS43.55MonthlyInformationReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydrators.AttachmentNo.1‐9NorthDakotaGasandComposition.pdf(OIL/GASPRODUCTIONFACILITYREGISTRATION,NORTHDAKOTADEPARTMENTOFHEALTH,DIVISIONOFAIRQUALITY)OperatingPermitApplicationsGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydrators.AttachmentNo.2‐6ColoradoAirPermitApp.PDF(OperatingPermitApplication,ColoradoDepartmentofPublicHealthandEnvironment,AirPollutionControlDivision)OperatingPermitApplicationsGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNStrippergasreportingisnotrequiredinthepermitapplication.Form2000‐307concernsdehydrators.Dataonregeneratorheatingrate(MMBtu/hr),glycolcirculationrate,glycoltype,controltechnology,gaspressure,gastemperature,andgascompositionarerequired.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review116SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceAttachmentNo.5‐1BOEMREAirEmissionReporting.pdf[Title30:MineralResources;PART250—OILANDGASANDSULPHUROPERATIONSINTHEOUTERCONTINENTALSHELF;SubpartB—PlansandInformation;ContentsofDevelopmentandProductionPlans(DPP)andDevelopmentOperationsCoordinationDocuments(DOCD)]eCFR;BOEMRERegulationsat30CFR250.513BOEMRERegulationsat30CFR250.513requiresairemissionreporting,includingthebasisforallcalculationsYNUseofstrippergasisreportedbutnotpubliclyavailableinthegulfwideinventory.Dataelementevaluatedinpublicavailabilityanalysis,seeAppendixB.AttachmentNo.5‐2ColoradoAirPermitApp.pdf(OperatingPermitApplication;ColoradoDepartmentofPublicHealthandEnvironmentAirPollutionControlDivision)OperatingPermitApplicationsColoradoDepartmentofPublicHealthandEnvironment,AirPollutionControlDivision,OperatingPermitApplications,requiresdetailedinformationongasdehydratorequipmentNNTheuseofstrippergasisnotrequiredinthepermitapplication.Form2000‐307concernsdehydrators.Dataonregeneratorheatingrate(MMBtu/hr),glycolcirculationrate,glycoltype,controltechnology,gaspressure,gastemperature,andgascompositionarerequired.AttachmentNo.5‐3NorthDakotaGlycolDehydratorReport.pdf(PERMITAPPLICATION‐GLYCOLDEHYDRATIONUNITSNORTHDAKOTADEPARTMENTOFHEALTHDIVISIONOFAIRQUALITY)OperatingPermitApplicationsNorthDakotaDepartmentofPublicHealth,DivisionofAirQuality,OperatingPermitApplications,requiresdetailedinformationongasdehydratorequipmentNNTheuseofstrippergasisnotrequiredinthepermitapplication.Thepermitapplicationrequiresoperatorstoreportthedesigncapacity,actualthroughput,andVOCemissionsfromglycoldehydrationunits.W98.236(c)(4)(i)(D)Foreachglycoldehydratorwiththroughputgreaterthanorequalto0.4MMscfd:ReportAttachmentNo.1‐5UtahGasDispositionReport.pdf(StateofUtahMonthlyOilandGasDispositionReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydrators.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review117SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferencewhetheraflashtankseparatorisusedinglycoldehydrator.AttachmentNo.1‐6LouisianaGasDispositionReport.pdf(StateofLouisianaMonthlyOilandGasDispositionReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydrators.AttachmentNo.1‐7AlaskaGasDispositionReporting.xls(AlaskaDepartmentofRevenue(ADOR)AS43.55MonthlyInformationReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydrators.AttachmentNo.1‐9NorthDakotaGasandComposition.pdf(OIL/GASPRODUCTIONFACILITYREGISTRATION,NORTHDAKOTADEPARTMENTOFHEALTH,DIVISIONOFAIRQUALITY)OperatingPermitApplicationsGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydrators.AttachmentNo.2‐6andAttachmentNo.5‐2.ColoradoAirPermitApp.PDF(OperatingPermitApplication,ColoradoDepartmentofPublicHealthandEnvironment,AirPollutionControlDivision)OperatingPermitApplicationsGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.YNDataelementisrequiredforColoradopermitapplicationsonlyandnotforamajorityofreporters.Form2000‐307concernsdehydrators.Useofaflashtankisrequiredtobereported.Dataelementevaluatedinpublicavailabilityanalysis,seeAppendixB.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review118SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceAttachmentNo.5‐1BOEMREAirEmissionReporting.pdf[Title30:MineralResources;PART250—OILANDGASANDSULPHUROPERATIONSINTHEOUTERCONTINENTALSHELF;SubpartB—PlansandInformation;ContentsofDevelopmentandProductionPlans(DPP)andDevelopmentOperationsCoordinationDocuments(DOCD)]eCFR;BOEMRERegulationsat30CFR250.513BOEMRERegulationsat30CFR250.513requiresairemissionreporting,includingthebasisforallcalculationsYNUseofaflashtankisreportedstoBOEMbutisnotpubliclyavailableinthegulfwideinventory.Dataelementevaluatedinpublicavailabilityanalysis,seeAppendixB.AttachmentNo.5‐3NorthDakotaGlycolDehydratorReport.pdf(PERMITAPPLICATION‐GLYCOLDEHYDRATIONUNITSNORTHDAKOTADEPARTMENTOFHEALTHDIVISIONOFAIRQUALITY)OperatingPermitApplicationsNorthDakotaDepartmentofPublicHealth,DivisionofAirQuality,OperatingPermitApplications,requiresdetailedinformationongasdehydratorequipmentNNUseofaflashtankisnotreported.Thepermitapplicationrequiresoperatorstoreportthedesigncapacity,actualthroughput,andVOCemissionsfromglycoldehydrationunits.W98.236(c)(4)(i)(E)Foreachglycoldehydratorwiththroughputgreaterthanorequalto0.4MMscfd:Reporttypeofabsorbent.AttachmentNo.1‐5UtahGasDispositionReport.pdf(StateofUtahMonthlyOilandGasDispositionReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydrators.AttachmentNo.1‐6LouisianaGasDispositionReport.pdf(StateofLouisianaMonthlyOilandGasDispositionReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydrators.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review119SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceAttachmentNo.1‐7AlaskaGasDispositionReporting.xls(AlaskaDepartmentofRevenue(ADOR)AS43.55MonthlyInformationReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydrators.AttachmentNo.1‐9NorthDakotaGasandComposition.pdf(OIL/GASPRODUCTIONFACILITYREGISTRATION,NORTHDAKOTADEPARTMENTOFHEALTH,DIVISIONOFAIRQUALITY)OperatingPermitApplicationsGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydrators.AttachmentNo.2‐6andAttachmentNo.5‐2.ColoradoAirPermitApp.PDF(OperatingPermitApplication,ColoradoDepartmentofPublicHealthandEnvironment,AirPollutionControlDivision)OperatingPermitApplicationsGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.YNPermitapplicationisforColoradoreportersonlyandnotforamajorityofreporters.Form2000‐307concernsdehydrators.Typeofglycolisreported.Dataevaluatedinpublicavailabilityanalysis,seeAppendixB.AttachmentNo.5‐1BOEMREAirEmissionReporting.pdf[Title30:MineralResources;PART250—OILANDGASANDSULPHUROPERATIONSINTHEOUTERCONTINENTALSHELF;SubpartB—PlansandInformation;ContentsofDevelopmentandProductionPlans(DPP)andDevelopmenteCFR;BOEMRERegulationsat30CFR250.513BOEMRERegulationsat30CFR250.513requiresairemissionreporting,includingthebasisforallcalculationsNNTypeofglycolisnotreportedandisassumedtobeTEG.Requirestheoperatortoreportadescriptionofprocesses,processingequipment,combustionequipment,fuels,andstorageunits.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review120SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceOperationsCoordinationDocuments(DOCD)]AttachmentNo.5‐3NorthDakotaGlycolDehydratorReport.pdf(PERMITAPPLICATION‐GLYCOLDEHYDRATIONUNITSNORTHDAKOTADEPARTMENTOFHEALTHDIVISIONOFAIRQUALITY)OperatingPermitApplicationsNorthDakotaDepartmentofPublicHealth,DivisionofAirQuality,OperatingPermitApplications,requiresdetailedinformationongasdehydratorequipmentYNPermitapplicationisforNorthDakotareportersonlyandnotforamajorityofreporters.Thepermitapplicationappearstorequireglycoltype.Itrequiresoperatorstoreportthedesigncapacity,actualthroughput,andVOCemissionsfromglycoldehydrationunits.W98.236(c)(4)(i)(F)Foreachglycoldehydratorwiththroughputgreaterthanorequalto0.4MMscfd:Totaltimetheglycoldehydratorisoperatinginhours.AttachmentNo.1‐5UtahGasDispositionReport.pdf(StateofUtahMonthlyOilandGasDispositionReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydrators.AttachmentNo.1‐6LouisianaGasDispositionReport.pdf(StateofLouisianaMonthlyOilandGasDispositionReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydrators.AttachmentNo.1‐7AlaskaGasDispositionReporting.xls(AlaskaDepartmentofRevenue(ADOR)AS43.55MonthlyInformationReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydrators.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review121SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceAttachmentNo.1‐9NorthDakotaGasandComposition.pdf(OIL/GASPRODUCTIONFACILITYREGISTRATION,NORTHDAKOTADEPARTMENTOFHEALTH,DIVISIONOFAIRQUALITY)OperatingPermitApplicationsGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydrators.AttachmentNo.2‐6andAttachmentNo.5‐2.ColoradoAirPermitApp.PDF(OperatingPermitApplication,ColoradoDepartmentofPublicHealthandEnvironment,AirPollutionControlDivision)OperatingPermitApplicationsGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNForm2000‐307concernsdehydrators.Actualtimedehydratorisoperatedisnotreportedonthisform..AttachmentNo.5‐1BOEMREAirEmissionReporting.pdf[Title30:MineralResources;PART250—OILANDGASANDSULPHUROPERATIONSINTHEOUTERCONTINENTALSHELF;SubpartB—PlansandInformation;ContentsofDevelopmentandProductionPlans(DPP)andDevelopmentOperationsCoordinationDocuments(DOCD)]eCFR;BOEMRERegulationsat30CFR250.513BOEMRERegulationsat30CFR250.513requiresairemissionreporting,includingthebasisforallcalculationsNNTimeunitoperatedisnotreported.VOCemissionsareestimatedbasedonvolume,nottimeunitwasoperating.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review122SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceAttachmentNo.5‐3NorthDakotaGlycolDehydratorReport.pdf(PERMITAPPLICATION‐GLYCOLDEHYDRATIONUNITSNORTHDAKOTADEPARTMENTOFHEALTHDIVISIONOFAIRQUALITY)OperatingPermitApplicationsNorthDakotaDepartmentofPublicHealth,DivisionofAirQuality,OperatingPermitApplications,requiresdetailedinformationongasdehydratorequipmentNNActualtimedehydratorisoperatedannuallyisnotreportedonthisform.Formrequiresoperatorstoreportthedesigncapacity,actualthroughput,andVOCemissionsfromglycoldehydrationunits.W98.236(c)(4)(i)(G)Foreachglycoldehydratorwiththroughputgreaterthanorequalto0.4MMscfd:Temperatureofthewetnaturalgas(degreesFahrenheit).AttachmentNo.1‐5UtahGasDispositionReport.pdf(StateofUtahMonthlyOilandGasDispositionReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydratorsAttachmentNo.1‐6LouisianaGasDispositionReport.pdf(StateofLouisianaMonthlyOilandGasDispositionReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydratorsAttachmentNo.1‐7AlaskaGasDispositionReporting.xls(AlaskaDepartmentofRevenue(ADOR)AS43.55MonthlyInformationReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydratorsAttachmentNo.1‐9NorthDakotaGasandComposition.pdf(OIL/GASPRODUCTIONFACILITYREGISTRATION,NORTHDAKOTADEPARTMENTOFHEALTH,DIVISIONOFAIRQUALITY)OperatingPermitApplicationsGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydratorsE.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review123SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceAttachmentNo.2‐6ColoradoAirPermitApp.PDF(OperatingPermitApplication,ColoradoDepartmentofPublicHealthandEnvironment,AirPollutionControlDivision)OperatingPermitApplicationsGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNForm2000‐307concernsdehydrators.Gastemperatureisreported,howeverannualreportingisnotrequired.Designdataonregeneratorheatingrate(MMBtu/hr),glycolcirculationrate,glycoltype,controltechnology,gaspressure,gastemperature,andgascompositionarerequired.AttachmentNo.5‐1BOEMREAirEmissionReporting.pdf[Title30:MineralResources;PART250—OILANDGASANDSULPHUROPERATIONSINTHEOUTERCONTINENTALSHELF;SubpartB—PlansandInformation;ContentsofDevelopmentandProductionPlans(DPP)andDevelopmentOperationsCoordinationDocuments(DOCD)]eCFR;BOEMRERegulationsat30CFR250.513BOEMRERegulationsat30CFR250.513requiresairemissionreporting,includingthebasisforallcalculationsYNWetgastemperatureisreportedtoBOEM,butisnotpubliclyavailableinthegulfwideinventory.Dataelementevaluatedinpublicavailabilityanalysis,seeAppendixB.AttachmentNo.5‐2ColoradoAirPermitApp.pdf(OperatingPermitApplication;ColoradoDepartmentofPublicHealthandEnvironmentAirPollutionControlDivision)OperatingPermitApplicationsColoradoDepartmentofPublicHealthandEnvironment,AirPollutionControlDivision,OperatingPermitApplications,requiresdetailedinformationongasdehydratorequipmentNNForm2000‐307concernsdehydrators.Annualreportingofgastemperatureisnotrequired.Designdataonregeneratorheatingrate(MMBtu/hr),glycolcirculationrate,glycoltype,controltechnology,gaspressure,gastemperature,andgascompositionarerequired.AttachmentNo.5‐3NorthDakotaGlycolDehydratorReport.pdf(PERMITAPPLICATION‐GLYCOLDEHYDRATIONUNITSOperatingPermitApplicationsNorthDakotaDepartmentofPublicHealth,DivisionofAirQuality,OperatingPermitApplications,requiresdetailedinformationongasdehydratorequipmentNNGastemperatureisnotreported.Thepermitapplicationrequiresoperatorstoreportthedesigncapacity,actualthroughput,andVOCemissionsfromglycoldehydrationunits.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review124SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceNORTHDAKOTADEPARTMENTOFHEALTHDIVISIONOFAIRQUALITY)W98.236(c)(4)(i)(G)Foreachglycoldehydratorwiththroughputgreaterthanorequalto0.4MMscfd:Pressureofthewetnaturalgas(psig).AttachmentNo.1‐5UtahGasDispositionReport.pdf(StateofUtahMonthlyOilandGasDispositionReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydratorsAttachmentNo.1‐6LouisianaGasDispositionReport.pdf(StateofLouisianaMonthlyOilandGasDispositionReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydratorsAttachmentNo.1‐7AlaskaGasDispositionReporting.xls(AlaskaDepartmentofRevenue(ADOR)AS43.55MonthlyInformationReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydratorsAttachmentNo.1‐9NorthDakotaGasandComposition.pdf(OIL/GASPRODUCTIONFACILITYREGISTRATION,NORTHDAKOTADEPARTMENTOFHEALTH,DIVISIONOFAIRQUALITY)OperatingPermitApplicationsGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydratorsAttachmentNo.2‐6andAttachment5‐2.ColoradoAirPermitApp.PDF(OperatingPermitApplication,ColoradoDepartmentofPublicOperatingPermitApplicationsGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNGaspressureisreported,annualreportingisnotrequired.Form2000‐307concernsdehydrators.Applicationrequiresdesigndataonregeneratorheatingrate(MMBtu/hr),glycolcirculationrate,glycoltype,controltechnology,gaspressure,gasE.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review125SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceHealthandEnvironment,AirPollutionControlDivision)temperature,andgascompositionarerequired.AttachmentNo.5‐1BOEMREAirEmissionReporting.pdf[Title30:MineralResources;PART250—OILANDGASANDSULPHUROPERATIONSINTHEOUTERCONTINENTALSHELF;SubpartB—PlansandInformation;ContentsofDevelopmentandProductionPlans(DPP)andDevelopmentOperationsCoordinationDocuments(DOCD)]eCFR;BOEMRERegulationsat30CFR250.513BOEMRERegulationsat30CFR250.513requiresairemissionreporting,includingthebasisforallcalculationsYNPressureofgasisreported.Dataelementevaluatedinpublicavailabilityanalysis,seeAppendixB.AttachmentNo.5‐3NorthDakotaGlycolDehydratorReport.pdf(PERMITAPPLICATION‐GLYCOLDEHYDRATIONUNITSNORTHDAKOTADEPARTMENTOFHEALTHDIVISIONOFAIRQUALITY)OperatingPermitApplicationsNorthDakotaDepartmentofPublicHealth,DivisionofAirQuality,OperatingPermitApplications,requiresdetailedinformationongasdehydratorequipmentNNGaspressureisnotreported.Thepermitapplicationrequiresoperatorstoreportthedesigncapacity,actualthroughput,andVOCemissionsfromglycoldehydrationunits.W98.236(c)(4)(i)(H)Foreachglycoldehydratorwiththroughputgreaterthanorequalto0.4MMscfd:AttachmentNo.1‐5UtahGasDispositionReport.pdf(StateofUtahMonthlyOilandGasDispositionReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydratorsE.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review126SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceConcentrationofCO2inwetnaturalgas.AttachmentNo.1‐6LouisianaGasDispositionReport.pdf(StateofLouisianaMonthlyOilandGasDispositionReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydratorsAttachmentNo.1‐7AlaskaGasDispositionReporting.xls(AlaskaDepartmentofRevenue(ADOR)AS43.55MonthlyInformationReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydratorsAttachmentNo.1‐9NorthDakotaGasandComposition.pdf(OIL/GASPRODUCTIONFACILITYREGISTRATION,NORTHDAKOTADEPARTMENTOFHEALTH,DIVISIONOFAIRQUALITY)OperatingPermitApplicationsGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydrators.AttachmentNo.2‐6ColoradoAirPermitApp.PDF(OperatingPermitApplication,ColoradoDepartmentofPublicHealthandEnvironment,AirPollutionControlDivision)OperatingPermitApplicationsGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNGasinletcompositionisrequiredfortheapplication,annualreportingnotrequired.Form2000‐307concernsdehydrators.Designdataonregeneratorheatingrate(MMBtu/hr),glycolcirculationrate,glycoltype,controltechnology,gaspressure,gastemperature,andgascompositionarerequired.AttachmentNo.2‐9BLMTestData.pdf(Title43:PublicLands:Interior;PART3160—ONSHOREOILANDGASOPERATIONS;Subpart3162—RequirementsforOperatingRightsOwnersandOperators)eCFR;BLMRegulationsat43CFR3162.4‐1Glycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.YBGascompositiontestresultsarerequiredduringwelldrillingandcompleting,andperiodictestingisrequired.Noindicationthatdataisrecurringorcollectedinadatabasethatispubliclyavailable.Dataelementevaluatedinpublicavailabilityanalysis,seeAppendixB.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review127SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceAttachmentNo.5‐1BOEMREAirEmissionReporting.pdf[Title30:MineralResources;PART250—OILANDGASANDSULPHUROPERATIONSINTHEOUTERCONTINENTALSHELF;SubpartB—PlansandInformation;ContentsofDevelopmentandProductionPlans(DPP)andDevelopmentOperationsCoordinationDocuments(DOCD)]eCFR;BOEMRERegulationsat30CFR250.513BOEMRERegulationsat30CFR250.513requiresairemissionreporting,includingthebasisforallcalculationsNNGascompositionisnotreportedinthereferenceddocument.Asurrogategasanalysisisusedfortheestimates.AttachmentNo.5‐2ColoradoAirPermitApp.pdf(OperatingPermitApplication;ColoradoDepartmentofPublicHealthandEnvironmentAirPollutionControlDivision)OperatingPermitApplicationsColoradoDepartmentofPublicHealthandEnvironment,AirPollutionControlDivision,OperatingPermitApplications,requiresdetailedinformationongasdehydratorequipmentNNGasinletcompositionisrequiredfortheapplication,annualreportingnotrequired.Form2000‐307concernsdehydrators.Applicationrequiresdesigndataonregeneratorheatingrate(MMBtu/hr),glycolcirculationrate,glycoltype,controltechnology,gaspressure,gastemperature,andgascompositionarerequired.AttachmentNo.5‐3NorthDakotaGlycolDehydratorReport.pdf(PERMITAPPLICATION‐GLYCOLDEHYDRATIONUNITSNORTHDAKOTADEPARTMENTOFHEALTHDIVISIONOFAIRQUALITY)OperatingPermitApplicationsNorthDakotaDepartmentofPublicHealth,DivisionofAirQuality,OperatingPermitApplications,requiresdetailedinformationongasdehydratorequipmentNNGascompositionisnotrequiredinthepermitapplication.Thepermitapplicationrequiresoperatorstoreportthedesigncapacity,actualthroughput,andVOCemissionsfromglycoldehydrationunits.W98.236(c)(4)(i)(H)Foreachglycoldehydratorwiththroughputgreaterthanorequalto0.4MMscfd:AttachmentNo.1‐5UtahGasDispositionReport.pdf(StateofUtahMonthlyOilandGasDispositionReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydratorsE.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review128SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceConcentrationofCH4inwetnaturalgas.AttachmentNo.1‐6LouisianaGasDispositionReport.pdf(StateofLouisianaMonthlyOilandGasDispositionReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydratorsAttachmentNo.1‐7AlaskaGasDispositionReporting.xls(AlaskaDepartmentofRevenue(ADOR)AS43.55MonthlyInformationReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydratorsAttachmentNo.1‐9NorthDakotaGasandComposition.pdf(OIL/GASPRODUCTIONFACILITYREGISTRATION,NORTHDAKOTADEPARTMENTOFHEALTH,DIVISIONOFAIRQUALITY)OperatingPermitApplicationsGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydratorsAttachmentNo.2‐6andAttachment5‐2.ColoradoAirPermitApp.PDF(OperatingPermitApplication,ColoradoDepartmentofPublicHealthandEnvironment,AirPollutionControlDivision)OperatingPermitApplicationsGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNApplicationisforColoradoreportersonly.Gasinletcompositionisrequiredfortheapplication,annualreportingnotrequired.Form2000‐307concernsdehydrators.Permitapplicationrequiresdataonregeneratorheatingrate(MMBtu/hr),glycolcirculationrate,glycoltype,controltechnology,gaspressure,gastemperature,andgascompositionarerequired.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review129SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceAttachmentNo.5‐1BOEMREAirEmissionReporting.pdf[Title30:MineralResources;PART250—OILANDGASANDSULPHUROPERATIONSINTHEOUTERCONTINENTALSHELF;SubpartB—PlansandInformation;ContentsofDevelopmentandProductionPlans(DPP)andDevelopmentOperationsCoordinationDocuments(DOCD)]eCFR;BOEMRERegulationsat30CFR250.513BOEMRERegulationsat30CFR250.513requiresairemissionreporting,includingthebasisforallcalculationsNNGascompositionisnotreported.Asurrogategasanalysisisusedfortheestimates.AttachmentNo.5‐3NorthDakotaGlycolDehydratorReport.pdf(PERMITAPPLICATION‐GLYCOLDEHYDRATIONUNITSNORTHDAKOTADEPARTMENTOFHEALTHDIVISIONOFAIRQUALITY)OperatingPermitApplicationsNorthDakotaDepartmentofPublicHealth,DivisionofAirQuality,OperatingPermitApplications,requiresdetailedinformationongasdehydratorequipmentNNGascompositionisnotrequired.Thepermitapplicationrequiresoperatorstoreportthedesigncapacity,actualthroughput,andVOCemissionsfromglycoldehydrationunits.W98.236(c)(4)(ii)(A)Forallglycoldehydratorwiththroughputlessthan0.4MMscfd:Countofglycoldehydrators.AttachmentNo.1‐5UtahGasDispositionReport.pdf(StateofUtahMonthlyOilandGasDispositionReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydratorsAttachmentNo.1‐6LouisianaGasDispositionReport.pdf(StateofLouisianaMonthlyOilandGasDispositionReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydratorsE.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review130SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceAttachmentNo.1‐7AlaskaGasDispositionReporting.xls(AlaskaDepartmentofRevenue(ADOR)AS43.55MonthlyInformationReport)ReportFormGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydratorsAttachmentNo.1‐9NorthDakotaGasandComposition.pdf(OIL/GASPRODUCTIONFACILITYREGISTRATION,NORTHDAKOTADEPARTMENTOFHEALTH,DIVISIONOFAIRQUALITY)OperatingPermitApplicationsGlycoldehydratorventingdataistypicallyreportedtoanairpermittingauthorityorincludedinthegasdispositionreports.NNReportdoesnotcollectinformationonglycoldehydratorsAttachmentNo.2‐6andAttachment5‐2.ColoradoAirPermitApp.PDF(OperatingPermitApplication,ColoradoDepartmentofPublicHealthandEnvironment,AirPollutionControlDivision)OperatingPermitApplicationsColoradoDepartmentofPublicHealthandEnvironment,AirPollutionControlDivision,OperatingPermitApplications,requiresdetailedinformationongasdehydratorequipmentYNPermitapplicationisforColoradoreportersonlyandnotforamajorityofreporters.Form2000‐307concernsdehydrators.Eachglycoldehydratorispermitted.Dataelementevaluatedinpublicavailabilityanalysis,seeAppendixB.AttachmentNo.5‐1BOEMREAirEmissionReporting.pdf[Title30:MineralResources;PART250—OILANDGASANDSULPHUROPERATIONSINTHEOUTERCONTINENTALSHELF;SubpartB—PlansandInformation;ContentsofDevelopmentandProductionPlans(DPP)andDevelopmenteCFR;BOEMRERegulationsat30CFR250.513BOEMRERegulationsat30CFR250.513requiresairemissionreporting,includingthebasisforallcalculationsYNNumberofglycoldehydratorsisreportedbutnotavailableforamajorityofreporters.Dataelementevaluatedinpublicavailabilityanalysis,seeAppendixB.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review131SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceOperationsCoordinationDocuments(DOCD)]AttachmentNo.5‐3NorthDakotaGlycolDehydratorReport.pdf(PERMITAPPLICATION‐GLYCOLDEHYDRATIONUNITSNORTHDAKOTADEPARTMENTOFHEALTHDIVISIONOFAIRQUALITY)OperatingPermitApplicationsNorthDakotaDepartmentofPublicHealth,DivisionofAirQuality,OperatingPermitApplications,requiresdetailedinformationongasdehydratorequipmentYNPermitapplicationisforNorthDakotareportersonlyandnotforamajorityofreporters.Dataonallglycoldehydratorsisreported.Dataelementevaluatedinpublicavailabilityanalysis,seeAppendixB..W98.236(c)(6)(i)(B)Forwellcompletionsandworkoverswithhydraulicfracturing,reportthefollowingforeachsub‐basinandwelltype(horizontalorvertical)combination:WhenusingEquationW‐10A,measuredflowrateofbackflowduringwellcompletion(cubicfeetperhour).AttachmentNo.2‐4ADNRWellReporting.pdf(StateofAlaskaDNR,DivisionofOilandGas,WellDataSubmittalRequirementJanuary2011)ReportingrequirementsAlaskaDepartmentofNaturalResources(ADNR)requireswellrecordandcompletionreporting,includingcasingsize,flowratesandrecordsofstimulationandworkoveractivitiesandinformationonoilandgascompositionNNReportingrequirementsfornumerousparameters,includingproductiontests,butdoesnotspecificallyincludemeasuredflowrateofbackflowduringwellcompletion.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review132SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceW98.236(c)(6)(i)(E)Forwellcompletionsandworkoverswithhydraulicfracturing,reportthefollowingforeachsub‐basinandwelltype(horizontalorvertical)combination:WhenusingEquationW‐10A,totalnumberofdaysofbackflowfromallwellsduringcompletions.AttachmentNo.2‐3NYSDrillingCompletionReport.pdf(NEWYORKSTATEDEPARTMENTOFENVIRONMENTALCONSERVATION,DIVISIONOFMINERALRESOURCES,BUREAUOFOILANDGASREGULATIONWELLDRILLINGANDCOMPLETIONREPORT)ReportFormNewYorkStateDepartmentofEnvironmentalConservation(NYSDEC)requireswellrecordandcompletionreporting,includingcasingsize,flowratesandrecordsofstimulationandworkoveractivitiesNNReportrequiresthedatesdrillingcommenced,completedandfinalcompletion/recompletiondates.Doesnotrequirenumberofdaysofbackflow.AttachmentNo.5‐1BOEMREAirEmissionReporting.pdf[Title30:MineralResources;PART250—OILANDGASANDSULPHUROPERATIONSINTHEOUTERCONTINENTALSHELF;SubpartB—PlansandInformation;ContentsofDevelopmentandProductionPlans(DPP)andDevelopmentOperationsCoordinationDocuments(DOCD)]eCFR;BOEMRERegulationsat30CFR250.513BOEMRERegulationsat30CFR250.513requirereportingofwellcompletionoperationsNNNumberofdaysofbackflownotspecificallyrequired.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review133SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceAttachmentNo.7‐1WyomingWellCompletionReport.pdf(WY‐EXAMPLEWELLCOMPLETIONS(“GREENCOMPLETIONS”)PERMIT–March2010)examplePermitWyomingrequiresdetailedinformationonwellventinganda“greencompletions”permit(AttachmentNo.7‐1),includingrecordsidentifyingandsummarizingtotalvolumesofhydrocarbonliquids(bbls)andnaturalgas(MMCF)recovered(flared,vented,storedintanks,pits,trucksorothercontainment,orsoldtogatheringlines,storageorcontainmentvesselsortrucks)fromthewellboreduringcompletion/re‐completionactivities,maintainedonaperwellbasis.NNTotalnumberofdaysofbackflownotspecificallyrequired.Reportrequirestotalemissionsduringwellcompletionandcompletionstartandenddate.W98.236(c)(6)(ii)(A)Forwellcompletionsandworkoverswithouthydraulicfracturing,reportthefollowingforeachsub‐basinandwelltype(horizontalorvertical)combination:Totalcountofcompletionsincalendaryear.AttachmentNo.2‐1TRRCDrillingCompletionReport.pdf(RAILROADCOMMISSIONOFTEXASSummaryofDrilling,CompletionandPluggingReportsProcessedJanuary2009)MonthlySummaryReportTexasRailRoadCommission(TRRC),SummaryofDrilling,CompletionandPluggingReportsshowingthatoperatorsreportdrillingandcompletionactivitydata.NNNumberofcompletionsreportedmonthlyratherthanannualandmaynotreportspecificdatainformationationAttachmentNo.2‐2PADrillingCompletionReportingReq.pdf(StateofPennsylvaniaWellReportingRule)ReportingRulePennsylvaniaDepartmentofEnvironmentalQuality(DEQ)requireswellrecordandcompletionreporting,includingcasingsize,flowratesandrecordsofstimulationandworkoveractivities.See25PACodeChapter78(§§78.121AnnualProductionReport‐78.122WellRecordandYNWellcompletionsarereportedandnotforamajorityofreporters.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review134SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceCompletionReport)AttachmentNo.2‐3NYSDrillingCompletionReport.pdf(NEWYORKSTATEDEPARTMENTOFENVIRONMENTALCONSERVATION,DIVISIONOFMINERALRESOURCES,BUREAUOFOILANDGASREGULATIONWELLDRILLINGANDCOMPLETIONREPORT)ReportFormNewYorkStateDepartmentofEnvironmentalConservation(NYSDEC)requireswellrecordandcompletionreporting,includingcasingsize,flowratesandrecordsofstimulationandworkoveractivitiesYNWellcompletionsarereportedandnotforamajorityofreporters.AttachmentNo.2‐4ADNRWellReporting.pdf(StateofAlaskaDNR,DivisionofOilandGas,WellDataSubmittalRequirementJanuary2011)ReportformAlaskaDepartmentofNaturalResources(ADNR)requireswellrecordandcompletionreporting,includingcasingsize,flowratesandrecordsofstimulationandworkoveractivitiesandinformationonoilandgascompositionYNWellcompletionsarereportedandnotforamajorityofreporters.AttachmentNo.2‐7BOEMREDrillComplReportReq.pdf(Title30:MineralResources;PART250—OILANDGASANDSULPHUROPERATIONSINTHEOUTERCONTINENTALSHELF;SubpartE—OilandGasWell‐CompletioneCFR;BOEMRERegulationsat30CFR250.513BOEMRERegulationsat30CFR250.513requirereportingofwellcompletionoperationsYNWellcompletionsarereportedtoBOEMbutarenotpubliclyavailableinthegulfwideinventory.Dataelementevaluatedinpublicavailabilityanalysis,seeAppendixB.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review135SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceOperations)AttachmentNo.2‐8BLMDrillComplReport.pdf(Title43:PublicLands:Interior;PART3160—ONSHOREOILANDGASOPERATIONS;Subpart3162—RequirementsforOperatingRightsOwnersandOperators)eCFR;BLMRegulationsat43CFR3162.4‐1BLMRegulationsat43CFR3162.4‐1requirereportingofwellcompletionoperationsYNWellcompletionsarereportedbutnotonarecurringbasisandnoinformationdataisforamajorityofreporters..AttachmentNo.2‐10APIQuarterlyWellCompletionReportAd.pdf(APIproductdescription)websiteTheAmericanPetroleumInstitute(API)compilesandreportspublicallyavailabledataonwellcompletionactivityinitsQuarterlyWellCompletionReportYNNoindicationinformationisfromrecurringactivity.Informationonreporteddrillingactivity,aswellasestimatesofthetotalnumberofwellsandfootagedrilledforthecurrentandrecentquartersDataelementevaluatedinpublicavailabilityanalysis,seeAppendixB.W98.236(c)(6)(ii)(B)Forwellcompletionsandworkoverswithouthydraulicfracturing,reportthefollowingforeachsub‐basinandwelltype(horizontalorvertical)combination:TotalcountofworkoversincalendaryearthatflaregasorventgasAttachmentNo.1‐8MMSCFRFuelFlareReporting.pdf(BureauofOceanEnergyManagement(BOEMRE)reportingrule)eCFR;title30,Part250.SubpartK;250.1163NNRecordsmustbemaintainedofreasongasisflaredorvented.Reportingnotrequired.AttachmentNo.7‐1WyomingWellCompletionReport.pdf(WY‐EXAMPLEWELLCOMPLETIONS(“GREENCOMPLETIONS”)PERMITReportWyomingrequiresdetailedinformationonwellventinganda“greencompletions”permitNNTotalcountofworkoversisnotrequired,howeverrecordkeepingisrequiredforcauseofflaringorventing.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review136SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferencetotheatmosphere.–March2010)AttachmentNo.7‐2TRCCGasVentReport.pdf(STATEWIDERULE32EXCEPTIONDATASHEET)RegulationTexasRailRoadCommission(TRRC),requiresdetailedinformationonwellventingandflaringNNPermitmustbeobtainedpriortoventingorflaringgasandreasonmustbegiven.Totalcountbyreasonisnotreported,howeverthedatacouldbeextractedfromthisinformationreported.W98.236(c)(7)(i)(A)Forblowdownventstackemissionsource,foreachuniquephysicalvolumethatisblowndownmorethanonceduringthecalendaryear:Totalnumberofblowdownsforeachuniquephysicalvolumeinthecalendaryear.(whenusingEq.W‐14A)AttachmentNo.1‐10WyomingBlowdownVentPermit.pdf(STATEOFWYOMING,DepartmentofEnvironmentalQuality‐AirQualityDivision,Blowdown/VentingPermitApplication)Blowdown/VentingPermitApplicationWyomingrequiresdetailsinformationonblowdownandothergasventingNNEmissionsmustbecalculatedforeachblowdownevent,howeveronlysummaryofventedemissionsarereported.W98.236(c)(8)(i)(F)Forwellheadgas‐liquidseparatorwithoilthroughputgreaterthanorequalto10barrelsperday,usingCalculationMethodology1and2of40CFR98.233(j),reportbysub‐basincategory:Totalvolumeofoilfromallwellheadseparatorssenttotank(s)inbarrelsperyear.AttachmentNo.1‐9NorthDakotaGasandComposition.pdf(OIL/GASPRODUCTIONFACILITYREGISTRATION,NORTHDAKOTADEPARTMENTOFHEALTH,DIVISIONOFAIRQUALITY)OperatingPermitApplicationsNorthDakotaDepartmentofPublicHealth,DivisionofAirQuality,OperatingPermitApplications,requiresdetailedinformationontanks.NNPermitdoesnotincludeinformationforvolumeofoilfromseparators.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review137SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceW98.236(c)(8)(i)(K)Forwellheadgas‐liquidseparatorwithoilthroughputgreaterthanorequalto10barrelsperday,usingCalculationMethodology1of40CFR98.233(j),reportbysub‐basincategory:AnnualCO2gasquantitiesthatwererecovered(metrictonsCO2e),forallwellheadgas‐liquidseparatorsorstoragetanksusingCalculationMethodology1of§98.233(j).AttachmentNo.1‐9NorthDakotaGasandComposition.pdf(OIL/GASPRODUCTIONFACILITYREGISTRATION,NORTHDAKOTADEPARTMENTOFHEALTH,DIVISIONOFAIRQUALITY)OperatingPermitApplicationsNorthDakotaDepartmentofPublicHealth,DivisionofAirQuality,OperatingPermitApplications,requiresdetailedinformationontanks.NNPermitrequiresinformationonfateoftankgasemissions,butdoesnotrequireannualreportingofCO2recovery..W98.236(c)(8)(ii)(A)Forwellswithoilproductiongreaterthanorequalto10barrelsperday,usingCalculationMethodology3and4of40CFR98.233(j),reportthefollowingbysub‐basincategory:Totalvolumeofsalesoilfromallwells(barrelsperyear).AttachmentNo.1‐5UtahGasDispositionReport.pdf(StateofUtahMonthlyOilandGasDispositionReport)GasdispositionreportGasdispositionreportsstatewhetherthegaswasproducedandsold,usedasfuel,flaredorvented.Therearedifferentroyaltyandtaxtreatmentsforvariousgasdispositionmethods.And,insomestatesflaredandventedgasesmustpayadditionalemissionfees.Gasdispositiondataispublicallyavailable,andmayonlybeheldconfidentialonanexplorationwellYNVolumestransportedoff‐sitearereportedandnotforamajorityofreporters.Dataelementevaluatedinpublicavailabilityanalysis,seeAppendixB.AttachmentNo.1‐6LouisianaGasDispositionReport.pdf(StateofLouisianaMonthlyOilandGasDispositionReport)GasdispositionreportYNTotalvolumeofoilisreportedandnotforamajorityofreporters.Dataelementevaluatedinpublicavailabilityanalysis,seeAppendixB.AttachmentNo.1‐7AlaskaGasDispositionReporting.xls(AlaskaDepartmentofRevenue(ADOR)AS43.55MonthlyInformationReport)GasdispositionreportYNTotalvolumeofoilisreportedbycompanyandregionandnotforamajorityofreporters.Summaryreportsavailable.Dataelementevaluatedinpublicavailabilityanalysis,seeAppendixB.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review138SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceAttachmentNo.1‐11and1‐12U.S.DepartmentofEnergy,EnergyInformationAdministration(EIA)gasdispositionreportingNNAggregateddataispublished,nottotalsbycompanyandsub‐basin.W98.236(c)(8)(iii)(A)Forwellheadgas‐liquidseparatorsandwellswiththroughputlessthan10barrelsperday,usingCalculationMethodology5of40CFR98.233(j)EquationW‐15of40CFR98.233:Numberofwellheadseparators.AttachmentNo.1‐9NorthDakotaGasandComposition.pdf(OIL/GASPRODUCTIONFACILITYREGISTRATION,NORTHDAKOTADEPARTMENTOFHEALTH,DIVISIONOFAIRQUALITY)OperatingPermitApplicationsNorthDakotaDepartmentofPublicHealth,DivisionofAirQuality,OperatingPermitApplications,requiresdetailedinformationontanksNNThenumberofwellheadseparatorsisnotreported.AttachmentNo.2‐6ColoradoAirPermitApp.PDF(OperatingPermitApplication,ColoradoDepartmentofPublicHealthandEnvironment,AirPollutionControlDivision)OperatingPermitApplicationsColoradoDepartmentofPublicHealthandEnvironment,AirPollutionControlDivision,OperatingPermitApplications,requiresdetailedinformationontankequipmentNNAlltanksmustbelistedifgreaterthan500gallonsorhavedailythroughputgreaterthan25gallonsThetankmaynotbespecificallyidentifiedasawellheadseparator..Form2000‐301concernsstoragetanks.Materialstoredisreported.Informationontankdimensionsandmaterialthroughput(gal/yr)isrequired.AttachmentNo.5‐1BOEMREAirEmissionReporting.pdf[Title30:MineralResources;PART250—OILANDGASANDSULPHUROPERATIONSINTHEOUTERCONTINENTALSHELF;SubpartB—PlansandInformation;ContentsofDevelopmentandProductionPlans(DPP)andDevelopmentOperationsCoordinationDocuments(DOCD)]eCFR;BOEMRERegulationsat30CFR250.513BOEMREregulationsat30CFR250.513requiresairemissionreporting,includingthebasisforallcalculations,includingtankemissionsYNInformationforeachvesselisreportedintoEPA’sGOADSsystemandcompiledintothegulfwideinventory.Noinformationondataelementisincludedinthegulfwideinventory.Datasourceisevaluatedinthepublicavailabilityanalysis.SeeAppendixB.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review139SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceAttachmentNo.6‐1ColoradoAirPermitApp.pdf(OperatingPermitApplicationColoradoDepartmentofPublicHealthandEnvironmentAirPollutionControlDivision)OperatingPermitApplicationsColoradoDepartmentofPublicHealthandEnvironment,AirPollutionControlDivision,OperatingPermitApplications,requiresdetailedinformationontankequipmentNNForm2000‐301concernsstoragetanks.Alltanksmustbelistedifgreaterthan500gallonsorhavedailythroughputgreaterthan25gallons.Materialstoredisreported.Thetankmaynotbespecificallyidentifiedasawellheadseparator.Informationontankdimensionsandmaterialthroughput(gal/yr)isrequired.AttachmentNo.6‐3NorthDakotaTankReporting.pdf[PERMITAPPLICATION‐VOLATILEORGANICCOMPOUNDSSTORAGETANK;NORTHDAKOTADEPARTMENTOFHEALTHDIVISIONOFAIRQUALITYSFN8535(12‐05)(AP‐112)]OperatingPermitApplicationsNorthDakotaDepartmentofPublicHealth,DivisionofAirQuality,OperatingPermitApplications,requiresdetailedinformationontanksNNThepermitapplicationmaynotidentifythetankspecificallyasawellheadseparator.Permitapplicationrequiresdataontankcapacity,dimensions,typeofroof,typeofseal,andvapordisposal(ventedtoatmosphere,vaporrecoveryunit,flare,orother).Alsorequiredisdataontypeofliquidstored,itsvaporpressure,theaveragethroughput,averageturnoversperyear,andtankemissions.40CFR112SpillPrevention,ControlandCountermeasurePlanRegulationEPArequiresreportingoftankspecificationinformationinafacility’sSpillPrevention,ControlandCountermeasure(SPCC)plan(40CFR112).YNNotrecurring.Regulationrequiresaplanbedevelopedandsubmittedformostfacilities.Mustcontainalistofalloilcontainingtanksabove55gallons.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review140SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceW98.236(c)(12)(ii)Forflarestacks:Volumeofgassenttoflare(cubicfeetperyear).AttachmentNo.1‐1TRRCO&GReportingRequirements.pdf(TexasRailRoadCommission(TRRC)productionstatisticswebsite)InstructionforonlinedatareportingTRRCrequiresreportingoffuel,flare,andventedgas.NNThedataelementreportediscombinedvolumeofgasventedorflared,notvolumeofgassenttotheflare.AttachmentNo.1‐2TRRCGasFlaredVentedReport.pdf(TexasRailRoadCommission(TRRC),OilandGasProductionReportInstructions)OnlineSummaryReportTRRCproducesareportthatincludestheamountofflaredandventedgas.NNThedataelementreportediscombinedvolumeofgasventedorflared,notvolumeofgassenttotheflare.(annualaggregatenumberforstate).AttachmentNo.1‐4Alaska2004_Gas_Disposition_Final.pdf(AlaskaOilandGasConservationCommission(AOGCC)2004AnnualReportonGasDisposition)AnnualSummaryReportAOGCCrequiresoperatorstoreportgasdispositiononamonthlybasis,includinginformationontheamountofgasusedforfuel,flare,ventedorusedforpilot/purge.NNThedataelementreportediscombinedvolumeofgasventedorflared,notvolumeofgassenttotheflare.AttachmentNo.1‐5UtahGasDispositionReport.pdf(StateofUtahMonthlyOilandGasDispositionReport)ReportFormStateofUtahDepartmentofNaturalResources,DivisionofOil,GasandMining,requiresmonthlygasdispositionreportinformationontheamountofgasusedforfuel,flare,orventedNNThedataelementreportediscombinedvolumeofgasventedorflared,notvolumeofgassenttotheflare.AttachmentNo.1‐6LouisianaGasDispositionReport.pdf(StateofLouisianaMonthlyOilandGasDispositionReport)ReportFormStateofLouisianaOfficeofConservationrequiresmonthlygasdispositionreportinformationontheamountofgasusedforfuel,flare,orventedYNRecurringdataelementforLouisianareportersonly.ReporteddataisvolumeVENTED(SYSTEMFLARE)Dataelementevaluatedinpublicavailabilityanalysis,seeAppendixB.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review141SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceAttachmentNo.1‐7AlaskaGasDispositionReporting.xls(AlaskaDepartmentofRevenue(ADOR)AS43.55MonthlyInformationReport)ReportFormAlaskaDepartmentofRevenue(ADOR)requiresoperatorstoreportgasdispositiononamonthlybasis,includinginformationontheamountofgasusedforfuel,flare,ventedorusedforpilot/purgeYNRecurringdataelementforAlaskareportersonly.Totalflarevolumes(MCF).Dataelementevaluatedinpublicavailabilityanalysis,seeAppendixB.AttachmentNo.1‐8MMSCFRFuelFlareReporting.pdf(BureauofOceanEnergyManagement(BOEMRE)reportingrule)eCFR;title30,Part250.SubpartK;250.1163BOEMRErequiresoperatorstoreportgasdispositiontoitsoffshoreemissiontrackingsystemGOADSandunderthereportingrequirementsof30CFR250.1163YNDataelementforGulfoffshorefacilitiesisrequiredtobereportedtoBOEM,butinformationisnotavailableinthegulfwideinventoryforamajorityofsources.Amountofgasflaredandtheamountofgasventedseparately.Dataelementevaluatedinpublicavailabilityanalysis,seeAppendixB.AttachmentNo.1‐9NorthDakotaGasandComposition.pdf(OIL/GASPRODUCTIONFACILITYREGISTRATION,NORTHDAKOTADEPARTMENTOFHEALTH,DIVISIONOFAIRQUALITY)OperatingPermitApplicationsNorthDakotaDepartmentofPublicHealth,DivisionofAirQuality,OperatingPermitApplications,requiresdetailedinformationongasdispositionandcompositionNNDataelementreportedisvolumeofgasflared,estimateamountMcf/day.Doesnotrequirereportingofflarevolumeonanannualbasis.AttachmentNo.4‐1NorthDakotaAmineUnitAppl.PDF(PERMITAPPLICATION‐NATURALGASPROCESSINGSWEETENINGOPERATIONS,NORTHDAKOTADEPARTMENTOFHEALTHDIVISIONOFAIRQUALITY)OperatingPermitApplicationsNNAverageacidgasflowratetoflareisreported.Doesnotrequirereportingofflarevolumeonanannualbasis.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review142SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceAttachmentNo.5‐1BOEMREAirEmissionReporting.pdf[Title30:MineralResources;PART250—OILANDGASANDSULPHUROPERATIONSINTHEOUTERCONTINENTALSHELF;SubpartB—PlansandInformation;ContentsofDevelopmentandProductionPlans(DPP)andDevelopmentOperationsCoordinationDocuments(DOCD)]eCFR;BOEMRERegulationsat30CFR250.513YNDataelementforGulfoffshorefacilitiesisrequiredtobereportedtoBOEM,butinformationisnotavailableinthegulfwideinventoryforamajorityofsources..Volumeofgasflaredisreported.Dataelementevaluatedinpublicavailabilityanalysis,seeAppendixB.AttachmentNo.7‐2TRCCGasVentReport.pdf(STATEWIDERULE32EXCEPTIONDATASHEET)ReportFormYNExceptiondatasheetforgasventing.Thetypeandamountofgasreleased,andifitisflaredorvented.Dataelementevaluatedinpublicavailabilityanalysis,seeAppendixB.AttachmentNo.8‐2TRRCMonthlyProductionReport.pdf(TRCC:INSTRUCTIONSFORMPR:MONTHLYPRODUCTIONREPORT)ReportinginstructionsNNVolumesventedorflaredhavesamecodeandarenotdifferentiated.W98.236(c)(12)(v)Forflarestacks:Flarecombustionefficiency.AttachmentNo.1‐1TRRCO&GReportingRequirements.pdf(TexasRailRoadCommission(TRRC)productionstatisticswebsite)InstructionforonlinedatareportingTRRCrequiresreportingoffuel,flare,andventedgasNNCombustionefficiencynotreported.Thedataelementreportediscombinedvolumeofgasventedorflared.AttachmentNo.1‐5UtahGasDispositionReport.pdf(StateofUtahMonthlyOilandGasDispositionReport)ReportFormStateofUtahDepartmentofNaturalResources,DivisionofOil,GasandMining,requiresmonthlygasdispositionreportinformationontheamountofgasusedforfuel,flare,orventedNNCombustionefficiencynotreported.Thedataelementreportediscombinedvolumeofgasventedorflared.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review143SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceAttachmentNo.1‐6LouisianaGasDispositionReport.pdf(StateofLouisianaMonthlyOilandGasDispositionReport)ReportFormStateofLouisianaOfficeofConservationrequiresmonthlygasdispositionreportinformationontheamountofgasusedforfuel,flare,orventedNNCombustionefficiencynotreported.Dataelementreportedisvolumeofgasventedtosystemflare.AttachmentNo.1‐7AlaskaGasDispositionReporting.xls(AlaskaDepartmentofRevenue(ADOR)AS43.55MonthlyInformationReport)ReportFormAlaskaDepartmentofRevenue(ADOR)requiresoperatorstoreportgasdispositiononamonthlybasis,includinginformationontheamountofgasusedforfuel,flare,ventedorusedforpilot/purgeNNCombustionefficiencynotreported.Dataelementreportedistotalflarevolumes.AttachmentNo.2‐6ColoradoAirPermitApp.PDF(OperatingPermitApplication,ColoradoDepartmentofPublicHealthandEnvironment,AirPollutionControlDivision)OperatingPermitApplicationsYNCombustionefficiencyisrequiredforColoradoreportersonly.Form2000‐403concernscontrolequipment;specifically,thermaloxidation.Dataoninletconcentration,outletconcentrationandcontrolefficiencyisrequired.AttachmentNo.5‐1BOEMREAirEmissionReporting.pdf[Title30:MineralResources;PART250—OILANDGASANDSULPHUROPERATIONSINTHEOUTERCONTINENTALSHELF;SubpartB—PlansandInformation;ContentsofDevelopmentandProductionPlans(DPP)andDevelopmentOperationsCoordinationDocuments(DOCD)]eCFR;BOEMRERegulationsat30CFR250.513BOEMRErequiresoperatorstoreportgasdispositiontoitsoffshoreemissiontrackingsystemGOADSandunderthereportingrequirementsof30CFR250.1163NNDataoncontrolefficiencyofaflareiscollectedthroughGOADSandcompiledinthegulfwideinventory.However,inventorydoesnotshowreportsfordataelement.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review144SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceW98.236(c)(13)(v)(A)Forcentrifugalcompressorsinonshorepetroleumandnaturalgasproduction:Countofcompressors.AttachmentNo.1‐9NorthDakotaGasandComposition.pdf(OIL/GASPRODUCTIONFACILITYREGISTRATION,NORTHDAKOTADEPARTMENTOFHEALTH,DIVISIONOFAIRQUALITY)OperatingPermitApplicationsNorthDakotaDepartmentofPublicHealth,DivisionofAirQuality,OperatingPermitApplications,requiresdetailedinformationongasdispositionandcompositionNNDataelementisonlyforcompressorswhosecollectiveHPratingexceeds500HP),centrifugalandreciprocatingnotreportedseparately.W98.236(c)(14)(v)(A)Forreciprocatingcompressorsinonshorepetroleumandnaturalgasproduction:Countofcompressors.AttachmentNo.1‐9NorthDakotaGasandComposition.pdf(OIL/GASPRODUCTIONFACILITYREGISTRATION,NORTHDAKOTADEPARTMENTOFHEALTH,DIVISIONOFAIRQUALITY)OperatingPermitApplicationsNorthDakotaDepartmentofPublicHealth,DivisionofAirQuality,OperatingPermitApplications,requiresdetailedinformationongasdispositionandcompositionNNDataelementisonlyforcompressorswhosecollectiveHPratingexceeds500HP),centrifugalandreciprocatingnotreportedseparately.W98.236(c)(19)(iv)Foronshorepetroleumandnaturalgasproductionandnaturalgasdistributioncombustionemissions:Cumulativevolumeoffuelcombustedinexternalfuelcombustionunitswitharatedheatcapacitylargerthan5mmBtu/hr,byfueltype.AttachmentNo.1‐1TRRCO&GReportingRequirements.pdf(TexasRailRoadCommission(TRRC)productionstatisticswebsite)InstructionforonlinedatareportingTRRCrequiresreportingoffuel,flare,andventedgasNNDataelementreportedisgasusedorgiventoothersforfieldoperations,orfuel.Sizeofcombustionunitnotspecified.AttachmentNo.1‐3TACProducerreportingrequirements.Title34,Part1chapter3,subchapterB,Rule3.17;TaxAdministrationNaturalGasTACrequiresreportingofproductionusedbytheoperatorforleaseoperationsNNDataelementreportedisgasusedorgiventoothersforfieldoperations,orfuel.Sizeofcombustionunitnotspecified.AttachmentNo.1‐4Alaska2004_Gas_Disposition_Final.pdf(AlaskaOilandGasConservationCommission(AOGCC)2004AnnualReportonGasDisposition)AnnualSummaryReportAOGCCrequiresoperatorstoreportgasdispositiononamonthlybasis,includinginformationontheamountofgasusedforfuel,flare,ventedorusedforpilot/purge.NNThedataelementinreportisvolumeofgasusedforfuel.Sizeofcombustionunitnotspecified.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review145SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceAttachmentNo.1‐5UtahGasDispositionReport.pdf(StateofUtahMonthlyOilandGasDispositionReport)ReportFormStateofUtahDepartmentofNaturalResources,DivisionofOil,GasandMining,requiresmonthlygasdispositionreportinformationontheamountofgasusedforfuel,flare,orventedNNThedataelementinreportisvolumeofgasusedon‐site.Sizeofcombustionunitnotspecified.AttachmentNo.1‐6LouisianaGasDispositionReport.pdf(StateofLouisianaMonthlyOilandGasDispositionReport)ReportFormStateofLouisianaOfficeofConservationrequiresmonthlygasdispositionreportinformationontheamountofgasusedforfuel,flare,orventedNNThedataelementreportedisthevolumeofgasinMCFusedinfieldoperations.Sizeofcombustionunitnotspecified.AttachmentNo.1‐7AlaskaGasDispositionReporting.xls(AlaskaDepartmentofRevenue(ADOR)AS43.55MonthlyInformationReport)ReportFormAlaskaDepartmentofRevenue(ADOR)requiresoperatorstoreportgasdispositiononamonthlybasis,includinginformationontheamountofgasusedforfuel,flare,ventedorusedforpilot/purgeNNThedataelementreportedisthevolumeofgasinMCFusedinleaseoperations.Sizeofcombustionunitnotspecified.AttachmentNo.1‐9NorthDakotaGasandComposition.pdf(OIL/GASPRODUCTIONFACILITYREGISTRATION,NORTHDAKOTADEPARTMENTOFHEALTH,DIVISIONOFAIRQUALITY)OperatingPermitApplicationsNorthDakotaDepartmentofPublicHealth,DivisionofAirQuality,OperatingPermitApplications,requiresdetailedinformationongasdispositionandcompositionNNThedataelementreportedisthevolumeofgasinMCFusedinleaseoperations.Sizeofcombustionunitnotspecified.AttachmentNo.8‐2TRRCMonthlyProductionReport.pdf(TRCC:INSTRUCTIONSFORMPR:MONTHLYPRODUCTIONREPORT)ReportinginstructionsNNDataelementisgasusedasfuelonsite.Sizeofcombustionunitnotspecified.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review146SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceW98.236(c)(19)(vii)Foronshorepetroleumandnaturalgasproductionandnaturalgasdistributioncombustionemissions:Cumulativevolumeoffuelcombustedininternalcombustionunitswitharatedheatcapacitylargerthan1mmBtu/hror130horsepower,byfueltype.AttachmentNo.1‐1TRRCO&GReportingRequirements.pdf(TexasRailRoadCommission(TRRC)productionstatisticswebsite)InstructionforonlinedatareportingTRRCrequiresreportingoffuel,flare,andventedgasNNDataelementreportedisgasusedorgiventoothersforfieldoperations,orfuel.Sizeofcombustionunitnotspecified.AttachmentNo.1‐3TACProducerreportingrequirements.Title34,Part1chapter3,subchapterB,Rule3.17;TaxAdministrationNaturalGasTACrequiresreportingofproductionusedbytheoperatorforleaseoperationsNNDataelementreportedisgasusedorgiventoothersforfieldoperations,orfuel.Sizeofcombustionunitnotspecified.AttachmentNo.1‐4Alaska2004_Gas_Disposition_Final.pdf(AlaskaOilandGasConservationCommission(AOGCC)2004AnnualReportonGasDisposition)AnnualSummaryReportAOGCCrequiresoperatorstoreportgasdispositiononamonthlybasis,includinginformationontheamountofgasusedforfuel,flare,ventedorusedforpilot/purge.NNThedataelementinreportisvolumeofgasusedforfuel.Sizeofcombustionunitnotspecified.AttachmentNo.1‐5UtahGasDispositionReport.pdf(StateofUtahMonthlyOilandGasDispositionReport)ReportFormStateofUtahDepartmentofNaturalResources,DivisionofOil,GasandMining,requiresmonthlygasdispositionreportinformationontheamountofgasusedforfuel,flare,orventedNNThedataelementinreportisvolumeofgasusedon‐site.Sizeofcombustionunitnotspecified.AttachmentNo.1‐6LouisianaGasDispositionReport.pdf(StateofLouisianaMonthlyOilandGasDispositionReport)ReportFormStateofLouisianaOfficeofConservationrequiresmonthlygasdispositionreportinformationontheamountofgasusedforfuel,flare,orventedNNThedataelementreportedisthevolumeofgasinMCFusedinfieldoperations.Sizeofcombustionunitnotspecified..AttachmentNo.1‐7AlaskaGasDispositionReporting.xls(AlaskaDepartmentofRevenue(ADOR)AS43.55MonthlyInformationReport)ReportFormAlaskaDepartmentofRevenue(ADOR)requiresoperatorstoreportgasdispositiononamonthlybasis,includinginformationontheamountofgasusedforfuel,flare,ventedorusedforNNThedataelementreportedisthevolumeofgasinMCFusedinleaseoperations.Sizeofcombustionunitnotspecified..E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review147SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferencepilot/purgeAttachmentNo.1‐9NorthDakotaGasandComposition.pdf(OIL/GASPRODUCTIONFACILITYREGISTRATION,NORTHDAKOTADEPARTMENTOFHEALTH,DIVISIONOFAIRQUALITY)OperatingPermitApplicationsNorthDakotaDepartmentofPublicHealth,DivisionofAirQuality,OperatingPermitApplications,requiresdetailedinformationongasdispositionandcompositionNNThedataelementreportedisthevolumeofgasinMCFusedinleaseoperations.Sizeofcombustionunitnotspecified..AttachmentNo.1‐11U.S.DepartmentofEnergy,EnergyInformationAdministrationMonthlyNaturalGasProductionReportReportformInstructionU.S.DepartmentofEnergy,EnergyInformationAdministration(EIA)requiresdetailedmonthlygasdispositionreportingandannualgasdispositionreportingNNThedataelementreportedisthevolumeofgasusedinleaseoperations.Sizeofcombustionunitnotspecified.AttachmentNo.8‐2TRRCMonthlyProductionReport.pdf(TRCC:INSTRUCTIONSFORMPR:MONTHLYPRODUCTIONREPORT)ReportinginstructionsTexasRailRoadCommissionrequiresamonthlyproductionreport.NNDataelementreportedisgasusedorgiventoothersforfieldoperations,orfuel.Sizeofcombustionunitnotspecified.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review148SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceY98.256(e)(6)IfusingEquationY‐1a:reportthemolarvolumeconversionfactor(inscf/g‐mole)foreachflare.NoneconstantSomeofthedeferredelementsaresimplyconstantconversionfactorsthatwouldnotvaryfromfacilitytofacilityYYConstantisavailable.MVC=Molarvolumeconversionfactor(849.5scf/kg‐moleat68°Fand14.7poundspersquareinchabsolute(psia)or836.6scf/kg‐moleat60°Fand14.7psia)Y98.256(e)(7)IfusingEquationY‐1b:reportmolarvolumeconversionfactorforeachflare.NoneconstantSomeofthedeferredelementsaresimplyconstantconversionfactorsthatwouldnotvaryfromfacilitytofacilityYYConstantisavailable.MVC=Molarvolumeconversionfactor(849.5scf/kg‐moleat68°Fand14.7poundspersquareinchabsolute(psia)or836.6scf/kg‐moleat60°Fand14.7psia)Y98.256(e)(7)(ii)IfusingEquationY‐1b:reportthecarbonmolenumberofeachcarboncontainingcompoundotherthanCO2intheflaregasstreamforeachflare.Ex.R2:BAAQMDRegulation12,Rule11,401.2.LocalRuleonperformancestandards,includesFlareDataReportingRequirements.NNReferencerequiresmonitoringandreportingoftotalhydrocarbon,methaneandsulfur.GCmonitorsthatprovideinformationoncompositionareoptional.Dataelementisnotthesameinformation.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review149SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceY98.256(e)(9)AnnualvolumeofflaregascombustedduringnormaloperationsEx.R2:BAAQMDRegulation12,Rule11,401.1.Ex.R3:Seehttp://hank.baaqmd.gov/enf/flares/LocalRuleonperformancestandards,includesFlareDataReportingRequirements.Publiclyavailable‐seeforexamplethemonthlyflarereportssubmittedbytheBayArearefineriesYNDataavailableforBayAreareportersonlyandnotforamajorityofreporters..Websitereferencedprovidesdetailedflarevolumeinformationforoperationsatalltimes(normalandevents).Toobtainannualvolume,readerwouldneedtosummarize.Y98.256(e)(9)AnnualaveragehigherheatingvalueoftheflaregasEx.R2:BAAQMDRegulation12,Rule11,401.9.LocalRuleonperformancestandards,includesFlareDataReportingRequirements.Similarinformation(lowerheatingvalue)ispubliclyavailable.NNDataavailabledoesnotprovideHHVofflaregas;methane,non‐methanehydrocarbonandsulfuranalysesarerequired.Y98.256(e)(9)VolumeofgasflaredduringSSMeventEx.R3:Seehttp://hank.baaqmd.gov/enf/flares/BayAreaAirQualityManagementDistrictwebsitePubliclyavailable‐seeforexamplethemonthlyflarereportssubmittedbytheBayArearefineriesYNDataavailableforBayAreareportersonlyandnotforamajorityofreporters..Websitereferencedprovidesdetailedflarevolumeinformationforoperationsatalltimes(normalandevents).Toobtainannualvolume,readerwouldneedtosummarize.Y98.256(e)(9)AveragemolecularweightEx.R3:Seehttp://hank.baaqmd.gov/enf/flares/BayAreaAirQualityManagementDistrictwebsitePubliclyavailable‐seeforexamplethemonthlyflarereportssubmittedbytheBayArearefineriesNNDataavailabledoesnotincludeaveragemolecularweight.Dataavailableincludesventgasflowrate,estimatedemissionsformethane,NMHC,andSulfurDioxide.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review150SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceY98.256(e)(9)CarboncontentoftheflaregasNoreferenceNodocumentPubliclyavailable‐seeforexamplethemonthlyflarereportssubmittedbytheBayArearefineriesNNDataavailabledoesnotincludecarboncontentofthegas.Dataavailableincludesventgasflowrate,estimatedemissionsformethane,NMHC,andSulfurDioxideY98.256(e)(9)IfusingEquationY‐3:reportthemolarvolumeconversionfactorforeachflare.NoreferenceNodocumentSomeofthedeferredelementsaresimplyconstantconversionfactorsthatwouldnotvaryfromfacilitytofacilityYYConstantisavailable.MVC=Molarvolumeconversionfactor(849.5scf/kg‐moleat68°Fand14.7poundspersquareinchabsolute(psia)or836.6scf/kg‐moleat60°Fand14.7psia)Y98.256(e)(10)Fractionofcarbonintheflaregascontributedbymethane(usedinEquationY‐4)Ex.R2:BAAQMDRegulation12,Rule11,401.2.LocalRuleonperformancestandards,includesFlareDataReportingRequirements.Canbecalculatedfromcompositiondata.NNAlthoughnotanexactmatchforthereporteddataelement,themethanecontentofflaregasispubliclyavailableforBayAreareportersonly.BAAQMDrulerequiresmethane,non‐methanehydrocarbonandsulfuranalyses.Y98.256(f)(7)IfusingEquationY‐6:reportthemolarvolumeconversionfactor.NoreferenceNodocumentSomeofthedeferredelementsaresimplyconstantconversionfactorsthatwouldnotvaryfromfacilitytofacilityYYConstantisavailable.MVC=Molarvolumeconversionfactor(849.5scf/kg‐moleat68°Fand14.7poundspersquareinchabsolute(psia)or836.6scf/kg‐moleat60°Fand14.7psia)E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review151SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceY98.256(f)(10)Cokeburn‐offfactorEx.R4,p.400BAAQMDMajorFacilityReviewPermit;ChevronProductsCompanyDraftPermitTitleVrecordkeepingrequirementNNRequirementisforBayAreareportersonlyandnotforamajorityofreporters..Permitrequiresrecordkeepingofcokeburn‐offrate.Noindicationthatthecokeburn‐offfactorisroutinelyreported.Y98.256(f)(10)AnnualthroughputofunitEx.R5,p.6ChevronRichmondAnalysis,CBECommentsonChevron1/25/08FEIRPart1.RefineryFeedstockSwitch.ResponsetocommentsPubliclyavailableviaotherpermitreportingrequirementsNNDocumentisaonetimereport.Dataavailableinthisdocumentisactualaveragethroughput.Y98.256(f)(10)AveragecarboncontentofcokeNospecificreferenceprovidedNotApplicableDefaultprovidedNNDataavailableisadefaultcarboncontent,notactualplantvalues.Y98.256(f)(11)Unitsofmeasurefortheunit‐specificCH4emissionfactorNospecificreferenceprovidedNodocumentNotbusinesssensitiveNNThisisaunitofmeasureassociatedwiththeactualvalue.Y98.256(f)(11)ActivitydataforcalculatingemissionsNotprovidedNodocumentToogeneralNNNoevidencethatthisdataisavailableY98.256(f)(11)Ifyouuseaunit‐specificemissionfactorforCH4:reporttheunit‐specificemissionfactorforCH4eachcatalyticcrackingunits,traditionalfluidcokingunits,andcatalyticreformingunitsNotprovidedNodocumentCalculatedvalueNNNoevidencethatthisdataisavailableY98.256(f)(12)Ifaunit‐specificemissionfactorforN2Owasused:reporttheunit‐specificemissionfactorforN2OeachcatalyticNotprovidedNodocumentCalculatedvalueNNNoevidencethatthisdataisavailableE.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review152SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferencecrackingunits,traditionalfluidcokingunits,andcatalyticreformingunitsY98.256(f)(12)Unitsofmeasurefortheunit‐specificN2OemissionfactorNospecificreferenceprovidedNodocumentNotbusinesssensitiveNNThisisaunitofmeasureassociatedwiththeactualvalue.Y98.256(f)(12)ActivitydataforcalculatingemissionsNospecificreferenceprovidedNodocumentNotbusinesssensitiveNNNoevidencethatthisdataisavailableY98.256(f)(13)AveragecarboncontentofcokeNotprovidedNodocumentGenerallywellknownwithinarangeNNDataavailableisadefaultcarboncontent,notactualplantvalues.Y98.256(h)(4)IfEquationY‐12isused:AnnualvolumetricflowtothesulfurrecoveryplantNospecificreferencelistedforthisitem.Ex.R4ChevronRichmondPermitreviewedPermitTitleVpermitsNNPermitfromBAAQMDprovidedforChevrondidnotspecifyreportingofflowtosulfurrecoveryplant.Y98.256(h)(4)IfEquationY‐12isused:reportthemolarvolumeconversionfactorSomeofthedeferredelementsaresimplyconstantconversionfactorsthatwouldnotvaryfromfacilitytofacilityYYConstantisavailable.MVC=Molarvolumeconversionfactor(849.5scf/kg‐moleat68°Fand14.7poundspersquareinchabsolute(psia)or836.6scf/kg‐moleat60°Fand14.7psia)Y98.256(h)(4)IfEquationY‐12isused:AnnualaveragemolefractionofcarboninthesourgasR6:EnsuringConsistentGreenhouseGasEmissionsEstimates,RitteretalArticle;cepmagazine.orgDataelementsthatareimportantfortheestimationandverificationofemissionsareequallyasimportantasthecalculatedemissionsestimatesNNNoevidencethatthisdataisavailable.ReferenceprovidesgeneralstatementsonreportingandcalculationofGHGsandexamplecalculationsfortwotheoreticalsources.Y98.256(h)(5)ValueofthecorrectionR6:EnsuringConsistentGreenhouseGasEmissionsEstimates,RitteretalArticle;cepmagazine.orgDataelementsthatareimportantfortheestimationandverificationofemissionsareequallyasimportantasthecalculatedemissionsestimatesNNNoevidencethatthisdataisavailable.ReferenceprovidesgeneralstatementsonreportingandcalculationofGHGsandexamplecalculationsfortwotheoreticalsources.Y98.256(h)(5)Annualvolumeofrecycledtailgas(ifusedtocalculaterecyclingcorrectionfactor)R6:EnsuringConsistentGreenhouseGasEmissionsEstimates,RitteretalArticle;cepmagazine.orgDataelementsthatareimportantfortheestimationandverificationofemissionsareequallyasimportantasthecalculatedemissionsestimatesNNNoevidencethatthisdataisavailable.ReferenceprovidesgeneralstatementsonreportingandcalculationofGHGsandexamplecalculationsfortwotheoreticalsources.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review153SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceY98.256(h)(5)Annualaveragemolefractionofcarboninthetailgas(ifusedtocalculaterecyclingcorrectionfactor)R6:EnsuringConsistentGreenhouseGasEmissionsEstimates,RitteretalArticle;cepmagazine.orgDataelementsthatareimportantfortheestimationandverificationofemissionsareequallyasimportantasthecalculatedemissionsestimatesNNNoevidencethatthisdataisavailable.ReferenceprovidesgeneralstatementsonreportingandcalculationofGHGsandexamplecalculationsfortwotheoreticalsources.Y98.256(i)(5)IfyouuseEq.Y‐13,reporttheannualmassofgreencokefedtotheforeachcokecalciningunitR6:EnsuringConsistentGreenhouseGasEmissionsEstimates,RitteretalArticle;cepmagazine.orgDataelementsthatareimportantfortheestimationandverificationofemissionsareequallyasimportantasthecalculatedemissionsestimatesNNNoevidencethatthisdataisavailable.ReferenceprovidesgeneralstatementsonreportingandcalculationofGHGsandexamplecalculationsfortwotheoreticalsources.Y98.256(i)(5)IfyouuseEq.Y‐13,reportthecarboncontentofgreencokefedtotheforeachcokecalciningunitR6:EnsuringConsistentGreenhouseGasEmissionsEstimates,EnvironmentalManagement,RitteretalArticle;cepmagazine.orgDataelementsthatareimportantfortheestimationandverificationofemissionsareequallyasimportantasthecalculatedemissionsestimatesNNNoevidencethatthisdataisavailable.ReferenceprovidesgeneralstatementsonreportingandcalculationofGHGsandexamplecalculationsfortwotheoreticalsources.Y98.256(i)(5)IfyouuseEq.Y‐13,reporttheannualmassofmarketablecokeproducedforeachcokecalciningunitR6:EnsuringConsistentGreenhouseGasEmissionsEstimates,RitteretalArticle;cepmagazine.orgDataelementsthatareimportantfortheestimationandverificationofemissionsareequallyasimportantasthecalculatedemissionsestimatesNNNoevidencethatthisdataisavailable.ReferenceprovidesgeneralstatementsonreportingandcalculationofGHGsandexamplecalculationsfortwotheoreticalsources.Y98.256(i)(5)IfyouuseEq.Y‐13,reportthecarboncontentofmarketablecokeproducedforeachcokecalciningunitR6:EnsuringConsistentGreenhouseGasEmissionsEstimate,RitteretalsArticle;cepmagazine.orgDataelementsthatareimportantfortheestimationandverificationofemissionsareequallyasimportantasthecalculatedemissionsestimatesNNNoevidencethatthisdataisavailable.ReferenceprovidesgeneralstatementsonreportingandcalculationofGHGsandexamplecalculationsfortwotheoreticalsources.Y98.256(i)(5)IfEquationY‐13usedforcokecalciningunits:reporttheannualmassofcokedustremovedfromtheprocessthroughcollectedindustcollectionsystemsR6:EnsuringConsistentGreenhouseGasEmissionsEstimates,RitteretalArticle;cepmagazine.orgDataelementsthatareimportantfortheestimationandverificationofemissionsareequallyasimportantasthecalculatedemissionsestimatesNNNoevidencethatthisdataisavailable.ReferenceprovidesgeneralstatementsonreportingandcalculationofGHGsandexamplecalculationsfortwotheoreticalsources.Y98.256(i)(7)Forcokecalcining:Theunit‐specificCH4emissionfactorNospecificreferenceprovidedNodocumentCalculatedvalueNNNoevidencethatthisdataisavailableE.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review154SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceY98.256(i)(7)Forcokecalcining:Unitsofmeasurefortheunit‐specificCH4emissionfactorNospecificreferenceprovidedNodocumentNotbusinesssensitiveNNThisdataelementisaunitofmeasure.Y98.256(i)(7)Forcokecalcining:ActivitydataforcalculatingemissionsNospecificreferenceprovidedNodocumentNotbusinesssensitiveNNNoevidencethatthisdataisavailableY98.256(i)(8)Forcokecalcining:IfaunitspecificemissionfactorwasusedfortheN2Ofactor:reporttheunitsofmeasurefortheunit‐specificfactorNospecificreferenceprovidedNodocumentNNThisdataelementisaunitofmeasure.Y98.256(i)(8)Forcokecalcining:IfaunitspecificemissionfactorwasusedfortheN2Ofactor:reporttheactivitydatausedforcalculatingemissionsNospecificreferenceprovidedNodocumentNotbusinesssensitiveNNNoevidencethatthisdataisavailableY98.256(i)(8)Forcokecalcining:Ifaunit‐specificemissionfactorforN2Owasused,reportthesite‐specificemissionfactorNospecificreferenceprovidedNodocumentNotbusinesssensitiveNNNoevidencethatthisdataisavailableY98.256(j)(2)QuantityofasphaltblownforeachforeachasphaltblowingunitR6:EnsuringConsistentGreenhouseGasEmissionsEstimates,RitteretalArticle;cepmagazine.orgDataelementsthatareimportantfortheestimationandverificationofemissionsareequallyasimportantasthecalculatedemissionsestimatesNNNoevidencethatthisdataisavailable.ReferenceprovidesgeneralstatementsonreportingandcalculationofGHGsandexamplecalculationsfortwotheoreticalsources.Y98.256(j)(2)QuantityofasphaltblownforeachforeachasphaltblowingunitR6:EnsuringConsistentGreenhouseGasEmissionsEstimates,RitteretalArticle;cepmagazine.orgDataelementsthatareimportantfortheestimationandverificationofemissionsareequallyasimportantasthecalculatedemissionsestimatesNNNoevidencethatthisdataisavailable.ReferenceprovidesgeneralstatementsonreportingandcalculationofGHGsandexamplecalculationsfortwotheoreticalsources.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review155SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceY98.256(j)(2)QuantityofasphaltblownforeachforeachasphaltblowingunitR6:EnsuringConsistentGreenhouseGasEmissionsEstimates,RitteretalArticle;cepmagazine.orgDataelementsthatareimportantfortheestimationandverificationofemissionsareequallyasimportantasthecalculatedemissionsestimatesNNNoevidencethatthisdataisavailable.ReferenceprovidesgeneralstatementsonreportingandcalculationofGHGsandexamplecalculationsfortwotheoreticalsources.Y98.256(j)(2)QuantityofasphaltblownforeachforeachasphaltblowingunitR6:EnsuringConsistentGreenhouseGasEmissionsEstimates,RitteretalArticle;cepmagazine.orgDataelementsthatareimportantfortheestimationandverificationofemissionsareequallyasimportantasthecalculatedemissionsestimatesNNNoevidencethatthisdataisavailable.ReferenceprovidesgeneralstatementsonreportingandcalculationofGHGsandexamplecalculationsfortwotheoreticalsources.Y98.256(j)(2)QuantityofasphaltblownforeachforeachasphaltblowingunitR6:EnsuringConsistentGreenhouseGasEmissionsEstimates,RitteretalArticle;cepmagazine.orgDataelementsthatareimportantfortheestimationandverificationofemissionsareequallyasimportantasthecalculatedemissionsestimatesNNNoevidencethatthisdataisavailable.ReferenceprovidesgeneralstatementsonreportingandcalculationofGHGsandexamplecalculationsfortwotheoreticalsources.Y98.256(j)(5)CO2emissionfactorforeachasphaltblowingunitNospecificreferenceprovidedNodocumentCalculatedvalueNNNoevidencethatthisdataisavailableY98.256(j)(6)CH4emissionfactorforeachasphaltblowingunitNospecificreferenceprovidedNodocumentCalculatedvalueNNNoevidencethatthisdataisavailableY98.256(j)(7)IfEquationY‐16isused:reportthecarbonemissionfactorNospecificreferenceprovidedNodocumentCalculatedvalueNNNoevidencethatthisdataisavailableY98.256(j)(8)IfEquationY‐16bisused:reporttheCO2emissionfactorusedNospecificreferenceprovidedNodocumentCalculatedvalueNNNoevidencethatthisdataisavailableY98.256(j)(8)IfEquationY‐16bisused:reportthecarbonemissionfactorNospecificreferenceprovidedNodocumentCalculatedvalueNNNoevidencethatthisdataisavailableY98.256(j)(9)IfyouuseEq.Y‐17:CH4emissionfactorNospecificreferenceprovidedNodocumentCalculatedvalueNNNoevidencethatthisdataisavailableY98.256(k)(3)Fordelayedcokingunits:DimensionsofcokedrumorvesselNospecificreferenceprovidedNodocumentPubliclyreportedasmodelinginputNNNoevidencethatthisdataisavailableE.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review156SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceY98.256(k)(3)Fordelayedcokingunits:TypicalgaugepressureofthecokingdrumwhenfirstventedtotheatmosphereR6:EnsuringConsistentGreenhouseGasEmissionsEstimates,RitteretalArticle;cepmagazine.orgDataelementsthatareimportantfortheestimationandverificationofemissionsareequallyasimportantasthecalculatedemissionsestimatesNNNoevidencethatthisdataisavailable.ReferenceprovidesgeneralstatementsonreportingandcalculationofGHGsandexamplecalculationsfortwotheoreticalsources.Y98.256(k)(3)Fordelayedcokingunits:TypicalvoidfractionofcokedrumorvesselNospecificreferenceprovidedNodocumentDefaultsuggestedNNNoevidencethatthisdataisavailableY98.256(k)(3)Fordelayedcokingunits:Annualnumberofcoke‐cuttingcyclesofcokedrumorvesselR6:EnsuringConsistentGreenhouseGasEmissionsEstimates,RitteretalArticle;cepmagazine.orgDataelementsthatareimportantfortheestimationandverificationofemissionsareequallyasimportantasthecalculatedemissionsestimatesNNNoevidencethatthisdataisavailable.ReferenceprovidesgeneralstatementsonreportingandcalculationofGHGsandexamplecalculationsfortwotheoreticalsources.Y98.256(k)(3)Fordelayedcokingunits:reportthemolarvolumeconversionfactorforeachcokedrumorvessel.NospecificreferenceprovidedNodocumentConstantYYConstantisavailable.MVC=Molarvolumeconversionfactor(849.5scf/kg‐moleat68°Fand14.7poundspersquareinchabsolute(psia)or836.6scf/kg‐moleat60°Fand14.7psia)Y98.256(k)(4)Fordelayedcokingunits:HeightanddiameterofthecokedrumsNospecificreferenceprovidedNodocumentPubliclyreportedasmodelinginputNNNoevidencethatthisdataisavailableY98.256(k)(4)Fordelayedcokingunits:CumulativenumberofvesselopeningsforalldelayedcokingdrumsinthesetNospecificreferenceprovided.Ex.R4reviewed.NodocumentTitleVpermitsNNDatacollectionisrequiredforBayAreareportersonlyNodocument.BAAQMDRegulation8,rule10requiresmonitoringofvesselopenings.Recordkeepingrequirement.Noreportingrequirement.Y98.256(k)(4)Fordelayedcokingunits:TypicalventingpressureR6:EnsuringConsistentGreenhouseGasEmissionsEstimates,RitteretalArticle;cepmagazine.orgDataelementsthatareimportantfortheestimationandverificationofemissionsareequallyasimportantasthecalculatedemissionsestimatesNNReferenceprovidesgeneralstatementsonreportingandcalculationofGHGsandexamplecalculationsfortwotheoreticalsources.Y98.256(k)(4)Fordelayedcokingunits:VoidfractionNospecificreferenceprovidedNodocumentDefaultsuggestedNNNoevidencethatthisdataisavailableE.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review157SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceY98.256(k)(4)Fordelayedcokingunits:MolefractionofmethaneincokinggasNospecificreferenceprovidedNodocumentDefaultsuggestedNNNoevidencethatthisdataisavailableY98.256(l)(5)Foreachprocessvent:MolarvolumeconversionfactorNoreferenceNodocumentSomeofthedeferredelementsaresimplyconstantconversionfactorsthatwouldnotvaryfromfacilitytofacilityYYConstantavailable.MVC=Molarvolumeconversionfactor(849.5scf/kg‐moleat68°Fand14.7poundspersquareinchabsolute(psia)or836.6scf/kg‐moleat60°Fand14.7psia)Y98.256(m)(3)Uncontrolledblowdownsystemsreportingunder98.253(k):Totalquantityofcrudeoilplusthequantityofintermediateproductsreceivedfromoff‐sitethatareprocessedatthefacilityinthereportingyearR6:EnsuringConsistentGreenhouseGasEmissionsEstimates,RitteretalArticle;cepmagazine.orgDataelementsthatareimportantfortheestimationandverificationofemissionsareequallyasimportantasthecalculatedemissionsestimatesNNReferenceprovidesgeneralstatementsonreportingandcalculationofGHGsandexamplecalculationsfortwotheoreticalsources.Y98.256(m)(3)Uncontrolledblowdownsystemsreportingunder98.253(k):CH4emissionfactorusedNospecificreferenceprovidedNodocumentDefaultsuggestedNNNoevidencethatthisdataisavailableY98.256(m)(3)Uncontrolledblowdownsystemsreportingunder98.253(k):MolarvolumeconversionfactorNospecificreferenceprovidedNodocumentConstantYYConstantavailable.MVC=Molarvolumeconversionfactor(849.5scf/kg‐moleat68°Fand14.7poundspersquareinchabsolute(psia)or836.6scf/kg‐moleat60°Fand14.7psia)Y98.256(n)(3)Forequipmentleaks:NumberofeachtypeofemissionsourcelistedinEquationY‐21(ifusingEq.Y‐21)NospecificreferenceprovidedArticle;cepmagazine.orgPubliclyavailableinTitleVpermitsYNTitleVpermitsrequirereportingofnumberofspecifictypesofcomponentsonaone‐timebasis.Datasourceisevaluatedinthepublicavailabilityanalysis.SeeAppendixB.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review158SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceY98.256(o)(2)(ii)Totalquantityofcrudeoilplusthequantityofintermediateproductsreceivedfromoff‐sitethatareprocessedatthefacilityinthereportingyearR6:RitteretalpaperArticle;cepmagazineorgDataelementsthatareimportantfortheestimationandverificationofemissionsareequallyasimportantasthecalculatedemissionsestimatesNNNoevidencethatthisdataisavailableY98.256(o)(4)(ii)Forstoragetanksthatprocessunstabilizedcrudeoil:QuantityofunstabilizedcrudeoilreceivedduringthecalendaryearR6:RitteretalpaperArticle;cepmagazine.orgDataelementsthatareimportantfortheestimationandverificationofemissionsareequallyasimportantasthecalculatedemissionsestimatesNNNoevidencethatthisdataisavailableY98.256(o)(4)(iii)Forstoragetanksthatprocessunstabilizedcrudeoil:AveragepressuredifferentialR6:RitteretalpaperArticle;cepmagazine.orgDataelementsthatareimportantfortheestimationandverificationofemissionsareequallyasimportantasthecalculatedemissionsestimatesNNNoevidencethatthisdataisavailableY98.256(o)(4)(iv)Forstoragetanksthatprocessunstabilizedcrudeoil:MolarvolumeconversionfactorNospecificreferenceprovidedNodocumentConstantYYConstantavailable:MVC=Molarvolumeconversionfactor(849.5scf/kg‐moleat68°Fand14.7poundspersquareinchabsolute(psia)or836.6scf/kg‐moleat60°Fand14.7psia)Y98.256(o)(4)(v)Forstoragetanksthatprocessunstabilizedcrudeoil:AverageMolefractionofCH4inventgasfromtheunstabilizedcrudeoilstoragetanksR6:EnsuringConsistentGreenhouseGasEmissionsEstimates,RitteretalArticle;cepmagazine.orgDataelementsthatareimportantfortheestimationandverificationofemissionsareequallyasimportantasthecalculatedemissionsestimatesNNNospecificreferenceprovidedY98.256(o)(4)(vi)IfyoudidnotuseEquationY‐23:reportthetank‐specificmethanecompositiondataR6:EnsuringConsistentGreenhouseGasEmissionsEstimates,RitteretalArticle;cepmagazine.orgDataelementsthatareimportantfortheestimationandverificationofemissionsareequallyasimportantasthecalculatedemissionsestimatesNNProvidesgeneralstatementsonreportingandcalculationofGHGsandexamplecalculationsfortwotheoreticalsources.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review159SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceusedtoestimatecumulativeCH4emissionsforstoragetanksusedtoprocessunstabilizedcrudeoil.Y98.256(o)(4)(vi)IfyoudidnotuseEquationY‐23:reportthegasgenerationratedatausedtoestimatecumulativeCH4emissionsforstoragetanksusedtoprocessunstabilizedcrudeoil.R6:EnsuringConsistentGreenhouseGasEmissionsEstimates,RitteretalArticle;cepmagazine.orgDataelementsthatareimportantfortheestimationandverificationofemissionsareequallyasimportantasthecalculatedemissionsestimatesNNProvidesgeneralstatementsonreportingandcalculationofGHGsandexamplecalculationsfortwotheoreticalsources.Y98.256(o)(6)QuantityofunstabilizedcrudeoilreceivedduringthecalendaryearR6:EnsuringConsistentGreenhouseGasEmissionsEstimates,RitteretalArticle;cepmagazine.orgDataelementsthatareimportantfortheestimationandverificationofemissionsareequallyasimportantasthecalculatedemissionsestimatesNNProvidesgeneralstatementsonreportingandcalculationofGHGsandexamplecalculationsfortwotheoreticalsources.Y98.256(o)(6)AveragepressuredifferentialR6:EnsuringConsistentGreenhouseGasEmissionsEstimates,RitteretalArticle;cepmagazine.orgDataelementsthatareimportantfortheestimationandverificationofemissionsareequallyasimportantasthecalculatedemissionsestimatesNNProvidesgeneralstatementsonreportingandcalculationofGHGsandexamplecalculationsfortwotheoreticalsources.Y98.256(o)(6)MolefractionofCH4inventgasfromtheunstabilizedcrudeoilstoragetankNospecificreferenceprovidedNodocumentDefaultsuggestedNNNoevidencethatthisdataisavailableY98.256(o)(7)Tank‐specificmethanecompositiondataR6:EnsuringConsistentGreenhouseGasEmissionsEstimates,RitteretalArticle;cepmagazine.orgDataelementsthatareimportantfortheestimationandverificationofemissionsareequallyasimportantasthecalculatedemissionsestimatesNNProvidesgeneralstatementsonreportingandcalculationofGHGsandexamplecalculationsfortwotheoreticalsources.Y98.256(o)(7)GasgenerationratedataNospecificreferenceprovidedNodocumentEmissionsNNNoevidencethatthisdataisavailableE.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review160SubpartReportingSectionDataElementReferenceCitedbyCommenterTypeofDocumentCommenterJustificationforWhyDataisPubliclyAvailableIsAvailableDataExactlytheSameasGHGRPDataElement?IsDataElementPubliclyAvailableRecurringforMajorityofReportersEvaluationofDataElementPresentedinReferenceY98.256(p)(2)Forloadingoperations:Quantityofmaterialsloadedbyvesseltypethathaveanequilibriumvapor‐phaseconcentrationofCH4of0.5volumepercentorgreaterR6:EnsuringConsistentGreenhouseGasEmissionsEstimates,RitteretalArticle;cepmagazine.orgDataelementsthatareimportantfortheestimationandverificationofemissionsareequallyasimportantasthecalculatedemissionsestimatesNNProvidesgeneralstatementsonreportingandcalculationofGHGsandexamplecalculationsfortwotheoreticalsources.

# Attachment P

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# 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 re ferred 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 comp etitive 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 Ev aluating 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 sector s required to report “inputs to equations” data elements, to dete rmine whether conditions exist within the
market structures such that the release of th e data could result in competitive harm, and

 Part Two: For those sectors for which the ma rket structure analysis determined that reporting of the “inputs to equations” data elements could result in competitive harm, an evaluation of each individual “inputs to equati ons” 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 fo r 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 subpa rt A “input to equation” data element. As a result, the one subpart A “input to equation” is not listed explicitly in this memorandum.

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# EPA’s evaluation of current market structures is presented in Part One of this memorandum. For all sectors in which the market structure analys is summarized in Part One determined that the

conditions exist within the market such that firm s could use released “inputs to equations” data elements to gain a competitive advantage, EPA pr oceeded 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.

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# Part 1: Evaluation of Market Structures

1.0 Introduction

The following section describes the overall process used to assess th e 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 ma rket such that competitive harm could occur should “inputs to equations” data elements be re leased to the public. Section 2.0 summarizes the connection between market structure and the po tential 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 term s of the commodity marketed and the geographic scope of the market.

Competitive markets are characte rized by many suppliers and produc ts that are identical or nearly identical, in terms of produc t characteristics that users value. In such markets, firms are “price takers”; that is, they are unable to infl uence the market price, and must determine their profit-maximizing production level as a function of the price set by the mark et. In such markets, strategic behavior is not possible because th ere are too many competitors, making it impossible for them to make decisions based on their competit ors’ 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 nu mber 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 measur es that characterize th e share of the market served by the largest firms. Specific tools used include the Herfindahl-Hirschman Index (HHI).

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# For a given market, the HHI is calculated by squari ng the market share of each firm competing in the market, then summing the squared shares.

HHI =  i 

# s i 2 

# , where s i 

# = the market share of the i th 

# firm.

Potential values of the HHI range from near zer o (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 sm aller 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 c onsidered 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 pr ocess level because customers make purchasing decisions for specific products or services. While identifying a concentrated or moderately concentrated NAICS is sufficient to identify s ubparts in which facilities are aware of their competitors, and thus subparts for which revealing sensitive information would have the potential to lead to competitiv e harm, it is not the only indicator that a market may have the potential to lead to competitive harm should se nsitive 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 pr oducing the product that they are aware of each other’s operations and may behave stra tegically. In these cases, publication of some data could result in ei ther reduced competition or competitive harm. Similarly, some products are traded in regional, ra ther than national markets; for these, even if the sector does not appear concentrated or mode rately 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 addi tion, 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 re sult, for subparts for which the national-level

NAICS assessment indicates that the sector ma y be unconcentrated, EPA performed additional

assessments.

Thus, EPA’s analysis foll owed a tiered approach:

2 Department of Justice. Use of HHI. http://www.justice.gov/atr/pu blic/divisionmanual.html , and Federal Trade Commission (FTC), 2004. The Petroleum Industry: Mergers, Struct ural Change, and Antitrust Enforcement

. http://www.ftc.gov/opa/ 2004/08/oilmergersrpt.shtm
3 Census Bureau. Economic Cens us, Concentration Ratios, 2007. http://www.census.gov/econ/concentration.html

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# 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 s ubpart, and not all NAICS are in the same concentration category, EPA determined whethe r 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 firm s 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 ma rkets for specialty products.

If EPA found that either of th e criteria under the third tier ab ove 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 th e release of “inputs to eq uations” data elements for the subpart would be minima l. If EPA found that any of th e above criteria is true for a subpart, EPA determined that the market is conc entrated, 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 subpa rt 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 (Combusti on), II (Industrial Wastewater Treatment), and TT (Industrial Landfills), the subparts represent a proc ess that may take place at facilities in a number of industry sectors. Anot her subpart, subpart U (Miscellane ous Uses of Carbonates), also includes a variety of industry sectors. The mark ets in which these facilities compete, and for
which concentration must be assessed, are the ma rkets for the goods or services they produce. To

evaluate the concentration in th ese markets, therefore, EPA id entified the NAICS codes for the industry sectors reported by these facilities, and examin ed 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 sect or NAICS codes, for

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# which HHI information is compiled by the Census Bureau. Subparts CC and W 4 

# did not have manufacturing NAICS reported, and thus HHI values were not available. As a result, for these subparts, EPA conducted a qua litative 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 concentr ation 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 re lease of the “inputs to eq uations” data elements to lead to reduced competition or competitiv e harm, EPA determined the level of sector

concentration at the national NAICS code leve l. 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 th e firms in the subpart are likely are aware of

each other’s actions. EPA focused its assessmen t on the 200 manufacturing sector NAICS codes

associated with GHG re porting facilities.

Appendix A lists concentration ratios for the 6-dig it 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 additi on, 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 consid ered 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 m oderately concentrated. Recognizing that it is actually the market or the sector that is concentrated, for conve nience throughout the rest of this document, EPA refers to such subparts as concen trated or moderately concentrated. Using this criterion, EPA found that the following subparts ar e 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 ex amining individual data elements to determine if harm would be likely to occur. Refer to th e Part 2 of this memorandum for this evaluation.

4 

### Three of the 1,549 fa cilities reporting under subpart W in 2011 reporte d manufacturing NAICS code s. See section 4.4 for
further discussion.

5 

### Some facilitiesreported multiple NAICS; t hus, facilities may be counted several times within a subpart, and the sum of NAICS cited by facilities within a subpa rt may exceed the number of fac ilities reporting under that subpart.

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# 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 co ncentrated within a part icular NAICS, or if the goods are traded in regional markets, which woul d have fewer firms than the national markets and thus are more likely to be con centrated; see the analysis below.

Subpart E, Adipic Acid Producers . Production of adipic acid falls under NAICS 325199, All Other Basic Inorganic Chemical Manufacturing; th is is a very broad NAICS code, encompassing production of many different inorgani c chemicals. Adipic acid production is a small subset of the overall NAICS. Thus, EPA examined adipic acid producers specifically, rath er than relying on a

NAICS-level assessment. Three facilities re ported under subpart E for Reporting Year 2011.
Even without firm-level data, the HHI is useful because with only three pl ants, the lowest value
the HHI could have is 3,267. 6 

# Because this source category does not have a threshold for applicability, all ad ipic acid producers in the U.S. are reporting under the GHGRP. Thus, EPA concluded that the market for adipic acid is conc entrated 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 like ly 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 Cens us. In addition, Appendix 1 shows that the NAICS codes reported by GHGRP facilities in 2011 are unconcen trated. Therefore, EPA proceeded to assess whether regi onal markets are concentrated.

High cement transportation cost rela tive 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 regi onal, and imperfectly competitive. 7 

# That is, market

concentration within a re gional market is sufficiently high that firms are aware of competitors. For example, this analysis identified 20 regiona l markets for gray cement (a subset of this sector), with the number of plants in each market ranging from one to nine 6 

# ; 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 ba sed on their knowledge of other (competing) producers’ behavior. In additi on, 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 33 2 

### ). In fact,the threshold of 1,000 for moderately concentrated markets tr anslates 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/regdat a/RIAs/portlandcementfinalria.pdf , EPA-HQ-OAR-2002-0051-3477.

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# identity and interested in production and market information a bout their competitors. It is important to note that faciliti es in the cement industry may pr oduce a variety of cement products. Some cement products are homogeneous (e.g. gray cem ent) and are traded in regional markets; others such as white, Type III and Type V repres ent niche products with different markets, with few firms but possibly servi ng a larger geographic area. 8



# As a result of these assessments, EPA conclude d that the structure of the markets that exist within this source catego ry warrant further evaluation of the “inputs to equations” data elements in subpart H. Therefore, EPA further evalua ted 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. Business 9 

# , there are 19 firms nationwide that produce ferroall oys. 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 ad dition, if a sector that has 19 firms nationwide includes a few firms with relatively large market sh are (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 s ubpart K. Therefore, EPA further evaluated the “inputs to equations” da ta 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, genera lly for captive use. Because th ese sectors are considered at least moderately concentrated (see discussion fo r subpart Y, below), we concluded that the

structure of the markets that exist within this source category warrant fu rther evaluation of the “inputs to equations” data elements in subpart P. Therefore, EPA further evaluated the “inputs to equations” data elements by examining each indivi dual 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 structur e of the iron and steel sector, using HHI data from the Census Bureau and ot her information. Steel pr oduction is generally characterized by economies of scale, resulting in markets dominated by a few large firms.

8 EPA’s Regulatory Impact Anal ysis: National Emissions Standards for Hazar dous 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 furn aces (high capital investment costs) and pose entry barriers. High transportation cost re lative 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 lik ely to behave strategically based on their knowledge of other (competing) pr oducers’ behavior. Nationally, the majority of facilities reporting under this source category ha d 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 di fferent markets (possibly different geographic dimensions). Both regional markets and nich e markets have relatively small numbers of producers, indicating at least m oderate market concentration.

EPA computed HHI at the proce ss, 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 website 10 

# . 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 proce ss. The results indicated that th ere 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 stat e or parent company, th e HHI values show at
least moderate concentration, w ith the exception of EAFs, which are unconcentrated even at the

state level. As a result, when EPA accounted for the di stinctions of regi on, parent company ownership, and steelmaking process EPA concluded th at the structure of the markets that exists within this source catego ry warrant further evaluation of the “inputs to equations” data elements in subpart Q. Therefore, EPA further evalua ted 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 concentr ated at the national le vel. Both subpart R (lead smelting) and subpart GG (zinc smelti ng) fall under NAICS 331410, Nonferrous Metal (except Aluminum) Smelting and Refining. In add ition 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). Fo r 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 ar e 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” da ta elements. Therefore, EPA further evaluated

10 ] 

### http://www.steel.org/en /Making%20Stee l/Where%20Its%20Made.aspx

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# the “inputs to equations” data elements by exam ining each individual data element to determine if harm would be likely to occur. Refer to Part 2 of this memora ndum for this evaluation.

Subpart X: Petrochemicals . In 2011, 64 petrochemical manuf acturing 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 si x 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 mo re than 17 firms, and most had ten or fewer. 11


# As a result, EPA concluded that th e structure of the markets that ex ist within this source category warrant further evaluation of the “inputs to equa tions” data elements in subpart X. Therefore, EPA further evaluated the “inputs to equations” da ta 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 ba rriers to entry facing firms wanting to enter the refining industry. First, ther e 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 ba rriers 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 Ec onomic 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 th e 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 mode rately concentrated (HHI=1,246 in 2003).

Individual petroleum products are relatively homogeneous, although different firms produce a different mix of products, and some produce spec ialty products for which there are few other producers. The U.S. Department of Energy collec ts 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 char acterize the petroleum market, EP A 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 fo r petroleum refineries shows that activity for

11 

### U.S. Environmental Protection Agency. Te chnical Support Document for the Petroc hemical 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/in fo/twip/padddef.html

13 

### http://www.eia.gov/petrol eum/refinerycapacity/

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# several key products/processes is at least moderately concentrat ed. The data includes capacity data for 3 thermal cracking processes (visbreak ing, fluid coking, other) an d together there are only 9 facilities nationwide with this cap ability (HHI = 5,568, 2,463, and 10,000 respectively). Similarly, desulfurization and cat alytic hydrocracking are proce sses where there is at least moderate concentration (HHI 1,023, 5,109 respectively). Additiona lly, 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 mode rately 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 th is source category warrantfurther evaluation of the “inputs to equations” data elements in s ubpart 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 Pa rt 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 repo rting 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 define d by production processes or wa ste 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 informati on related to these sour ce categories has the potential to cause competitive harm depends on the concentration of the markets in which the facilities sell their produc ts rather than on the total number of facilities repo rting 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-digi t 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 th ese facilities come from a wide variety of sectors for which EPA does not have specific information beyond th e 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 th e 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 li st 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 mark ets 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 “input s to equations” data elements could potentially cause competitive harm or reduce competition. Du e to the limitations of the market structure analysis for these subparts, and because the result s of the analysis demonstrate that some of the facilities that report under these subparts are in sectors that ar e 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 Herfin dahl-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

HHIs 1



# 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 facili ties, because some facilities report multiple NAICS codes.

2 

### Includes only facility reports of NAI CS codes with non-missing HHI values.



# 4.4 Analysis of Non-Manufacturing Sectors

As shown in Appendix A, HHIs were not available for subpart W 14 

# (Petroleum and Natural Gas) and subpart CC (soda ash manufacturing). As a result, a qualitative analysis of the market

structures that exist within th ese 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 thes e, 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 re sult, EPA conducted a qualitative analysis of the segments within

this sector.

For each segment, EPA examined the market stru cture to determine if revelation of “inputs to equations” data elements by firms in that segmen t had the potential to cause competitive harm or reduce competition. For source categories that ar e in the manufacturing sector, as shown in
Sections 4.1 and 4.2 of this memorandum, EPA exam ined concentration at the national level, as well as at the regional, product, or process level. Because of the unique na ture of the subpart W source category with a relatively large numbe r of producers selling a relatively homogeneous product, EPA determined that it would not be appr opriate to assess the ma rket structure at the product or process level. As a result, EPA consid ered the market structure of each segment as well as the types of informati on 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 producti on segment covers emissions related to onshore production wellheads. The market stru cture 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 in formation during the ea rly development of a formation when lease prices have not stabi lized 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, in formation about production becomes publically available and the advantage incurred by the ope rator drilling exploration wells is lost.
However, once a well has been drilled, decision s to produce are based on market prices and the ability to control flow from the well. Alt hough 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-basi n level, as defined by county boundaries, and which is a large enough scale that disclosure of the data co llected 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 collect ed for this segment, EPA did not proceed to evaluate each “input to equation” da ta element in this segment.

The onshore natural gas production market overlap s many of the geological formations of petroleum production. Furthermore, the market it self is structured the same, with a large number of operators within each formation. Li ke onshore oil production, disclosure of data for onshore natural gas production at the sub- basin level would al so 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 collect ed for this segment, EPA did not proceed to evaluate each “input to equation” da ta 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 dr illing and exploration th at 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 l ongitude 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 producti on would not reveal any proprietary information about the facility or cost to do business. As the likelihood of

harm can be characterized for all informati on collected for this segment, EPA did not proceed to evaluate each “input to equati on” data element in this segment.

Natural Gas Processing


# Natural gas processors are regionally located cl ose 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 concentr ation would pose data sensitivity issues because the “inputs to equati ons” data elements in this segment would not reveal any proprietary information about the f acility, cost of natural gas, or cost to do

business. As the likelihood of harm can be char acterized 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 tr ansport natural gas from processors to end users. Firms are regionally concentrated, havi ng control over particul ar 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 relate d to pipeline construction an d natural gas transmission; technological innovation is mainly in the area of pipeline secur ity; (2), the rate charged for transport is highly regulated, preventing use of the data for strategic price competition; and (3) once pipeline and compression ar e built in a given corridor, th ere 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 th is 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 e nd-users. This market is regionally located with distributers having exclusive access to spec ific cities and other localities. Both publiclyand privately-owned companies are highly regulat ed, unable to charge market based rates for service. The regulation by government and th e 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 woul d not reveal any proprietary information about the facility or cost to do business. As the li kelihood 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 sm ooth out volatility in c onsumption and use of natural gas. The market is regional; facilities ar e located either near major distribution centers or near oil and gas fields. Even with the regi onal market structure, competitors are not known to engage in strategic competition in building st orage facilities. First, facilities are built in response to other upstream factors, such as in creased gas supply coming to distributors, not to undermine other competitors. Second, storag e firms are constrained by the geographical and geological requirements needed for underg round storage, preventing firms from moving in and increasing their market share. Finall y, 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 char acterized 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 operate s 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 possibi lities for disruptive competitive undercutting;
however, there we determined that this is un likely for the following two reasons. First, LNG storage is primarily owned by highly regulated distributors, preventing competitive firms from undercutting the market. Second, LNG stor age 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 elemen ts 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 collect ed for this segment, EPA did not proceed to evaluate each “input to equation” da ta element in this segment.

Liquefied Natural Gas Import/Export


# Currently the U.S. has only twelve LNG im port terminals and one LNG export terminal. There are nine onshore import terminals a nd three offshore import terminals. LNG technology is not proprietary. Th e technology is relatively simp le 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 la rger natural gas supply sector that is a much larger market. The product delivered or cons umed by LNG Import/Export is identical to the product generated in onshore and offshore natu ral 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 pr ices 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. Therefor e, release of information a bout 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 procee d 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 aggr egation that protects in dividual 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 re porting 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 firm s with relatively large market share (as opposed
to a sector where all firms are similar size, and each has roughly 1/18 shar e of the market), it is likely to be concentrated. As a re sult, EPA concluded that the stru cture of the markets that exist within this source catego ry warrant further evaluation of the “inputs to equations” data elements in subpart CC. Therefore, EPA further evalua ted 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 structur es for subparts with “inpu ts to equations” data

elements to determine whether conditions exist with in 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 ex amined except for facilities reporting under subpart
W. As a result, EPA did not further evaluate competitive harm for f acilities reporting under subpart W. For the “inputs to equations” data elements in the remaining 26 subparts examined, EPA further evaluated the data elements by exam ining each individual data element to determine if harm would be likely to occur. Refer to Part 2 of this memora ndum for this evaluation.

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# Part Two: Evaluation of Individu al Data Elements

1.0 Introduction

As discussed in Part One of this memorandum, EP A determined that conditions exist within the market structures such that competitive harm c ould occur should certain types of information be released for all of the subpart s examined in this memorandum except for facilities reporting under subpart W. As a result, no further evaluati on 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 da ta elements to determine if ha rm would be likely to occur.

2.0 Evaluation of Harm

Based on EPA’s previous consideration of co mpetitive harm (see proposed CBI rule, 75 FR 39115 – 39116, July 7, 2010), EPA’s previous consid eration 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 th e 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 a nd operation, and cost to do business.

Additionally, EPA determined that many other “i nputs to equations” data elements, which alone

would not reveal information that could cause co mpetitive 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 furthe r discussed below. In all, 525 “inputs to equations” data elemen ts (excluding “inputs to equations ” for facilities subject to subpart W) were reviewed according to the proce ss 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 th at publicly releasing f acility-specific data on the quantity or composition of raw materials or products would likely cause competitive harm. In these previous actions, EPA finalized CBI determ inations 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 pr oposed CBI rule, disc losing a facility’s production or throughput data would be detrimental to a firm’s competitiveness by revealing confidential process information and operati onal and marketing strategies, as follows:

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#  Annual production quantities, used in conjunction with othe r 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 th roughput quantities and product compositions could give competitors insight into a firm’s local and regional market conditions and expansion plans, enabling competitors to devi se strategies to prevent expansion and to steal market share in specific locations; and

 Disclosing a facility’s feed stock quantities and compositi on and reactants fed into particular processes at a facility could pr ovide 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 identifi ed 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 da ta 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 prev iously proposed CBI determinati ons). 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 requireme nt to report the quantity or composition of raw materials or products are id entified 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 ha s determined that data related to process design, process performance and operation, and cost to do busi ness 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 capac ity 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 wea knesses (e.g., disclosing an aluminum production facility’s cell performance would disclose current production efficiency);and

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#  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, w ould reveal the amount of product that is lost).

Data elements determined to include a requireme nt 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 pro ducts (see section 2.1), in combination with currently reported data el ements and other “inputs to equations” data elements could be used to back-calculate the ty pes of data specified in sections 2.1 and 2.2 (e.g., production quantity, cost to do business). For exampl e, for a nitric acid production facility, the abatement technology destruction e fficiency, if reported alone, woul d not reveal any information that would likely cause harm; however, if reported together with the abatement utilization factor, emission factor, and reported N 2 

# O emissions, it could be used to back-calculate an estimate of the mass of nitric acid produced, which is the type of data id entified in section 2.1 of this

memorandum. Data elements determined to rev eal 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 (a s required under §98.226(j)), together with annual

N 2 

# O emissions from nitric acid production (in §98.3(c)(4)), the emission factor (in §98.226(m)(1)), and the destruction e fficiency (in §98.226(i)), these da ta together could be used

to calculate the mass of nitric ac id produced. However, if repor ting of the emission factor were
removed, the abatement utilization factor coul d be reported without revealing proprietary information about nitric acid production. Any su ch “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 evaluate d in this memorandum. EPA did not proceed to Step 3 of the evaluation for subpart W (Petrole um and Natural Gas Systems) and Subpart II (Industrial Wastewater Treatment).

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# Appendix A

Subpart Sector Concentration Assessm ent, National NAICS Code Level

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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

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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

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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

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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

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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

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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 ma y 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, wh ichever is lower. Values less than 1000 are considered

## E.O. 12866 Review

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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.

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38 

# Appendix B

Results of the Evaluation of Competitive Harm from Reporting Data Elements Deferred to March 31, 2015

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39 

# Table B-1. Results of the Evaluation of Comp etitive 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 f acility 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 fromeach type of fuel listed in Table C2 that was combusted in the unit during the report year. C-10 Provides data relate d 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 pro cess 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 CO 2 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 fromeach type of fuel listed in Table C2 combusted during the reporting

year. C-10 Provides data relate d 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

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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 describe d in section 2.1 of Part Two of this memorandum. Also, in certain cases provides data related to process design; proce ss 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 CO 2 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 relate d 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 pro cess 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 rela ted 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 rela ted 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.

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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 relate d 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 pro cess 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 relate d 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 pro cess 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 relate d 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 pro cess 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 relate d 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 pro cess efficiency and cost to produce a product.

## E.O. 12866 Review

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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 relate d 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 pro cess 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
CO 2 is determined according to§98.33(e)(2), report the carbonbased F-factor used in Equation C13 of this subpart. C-13 Provides data relate d 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 pro cess 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
CO 2 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 relate d 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 pro cess 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
CO 2 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; proce ss 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

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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 f acility 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 fromeach 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 CO 2 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 fromeach 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.

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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

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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 CO 2 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 municipa lities. 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.

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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

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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

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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 othe r 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 pe rformance, 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

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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
CO 2 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
CO 2 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 othe r 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 pe rformance, 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
CO 2 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 othe r 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 pe rformance, 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.

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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 N 2 O 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 desc ribed 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 pe rformance, 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 desc ribed 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 N 2 O 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 pe rformance, 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 pe rformance, design, and operation; cost to do business; raw material usage; or production.

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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 descri bed 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 inform ation 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 descri bed 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 desc ribed 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 N 2 O 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 pe rformance, design, and operation; cost to do business; raw material usage; or production.

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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 N 2 O 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 descri bed 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 N 2 O 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 informati on 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 N 2 O 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.

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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) N 2 O 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 pe rformance, 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)), N 2 O 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 pe rformance, 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)), N 2 O 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 pe rformance, design, and operation; cost to do business; raw material usage; or production.

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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. (FC N ) E-3c Provides data descri bed 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 N 2 O 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 pe rformance, 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

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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)) orusing 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 overvolta ge. 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.

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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.

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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 CO 2 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 CO 2 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.

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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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2emissions (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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2emissions (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 pe rformance, 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

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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.

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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 wei ghted average destruction efficiency of the destruction device
calculated for each stream under §98.123(b)(16). (DEavgj) L-17 Provides data descri bed in section 2.3 of
Part Two of this memorandum that could
be used to calculate the concentration of fluorine-containing r eactants, 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 descri bed 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 descri bed 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 descri bed 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 descri bed 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

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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 descri bed 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 descri bed 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 descri bed 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 descri bed 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 (mis sing 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 descri bed 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 descri bed 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 descri bed 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 descri bed 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. (RE D ) 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 descri bed 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 (G 23 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 (S 23 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 (OD 23 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 I 23 , 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
I 23 , 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.

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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 te st 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. Specifica lly, 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 te st 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 pe rformance, 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 te st 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 pe rformance, design, and operation; cost to do business; raw material usage; or production.

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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 te st 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 te st 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 beestimated. 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.

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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 qua ntity iron produced (NoCEMS 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 qua ntity 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 qua ntity iron produced (NoCEMS 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 CO 2 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 CO 2 emissions (No CEMS) -gaseous fuel combusted(C gf ). 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 CO 2 emissions (No CEMS)- liquid fuel combusted (C lf ). 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 CO 2 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.

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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 CO 2 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 CO 2 emissions (No CEMS)- Iron (C iron ). 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 CO 2 emissions (No CEMS)- Scrap (C scrap ). 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 CO 2 emissions (No CEMS)- Flux (C flux ). 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 CO 2 emissions (No CEMS)- Carbonaceous material (C carbon ). 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 CO 2 emissions (No CEMS) - Steel produced (C steel ).. 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 CO 2 emissions (No CEMS) - Slag produced (C slag ). 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 CO 2 emissions (No CEMS) - Air pollution control residue collected (C R ). 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 CO 2 emissions (No CEMS)- Coal charged to coke battery (C coal ). 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 CO 2 emissions (No CEMS) - Coke produced by coke battery (C coke ). 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 CO 2 emissions (No CEMS) - Air pollution control residue collected from coke battery (C R ). Q-3 Provides production or raw material data
described in section 2.1 of Part Two of this
memorandum.

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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 CO 2 emissions (No CEMS)- Gaseous
fuel combusted in the sinter process (C gf ). 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 CO 2 emissions (No CEMS) - sinter feed (C Feed ). 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 CO 2 emissions (No CEMS) - sinter (C Sinter ). 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 CO 2 emissions (No CEMS) - Air pollution control residue collected from sinter process (C R ). 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 CO 2 emissions (No CEMS)- Iron (C iron )
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 CO 2 emissions (No CEMS)- Scrap (C scrap ) 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 CO 2 emissions (No CEMS)- Flux (C flux )
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 CO 2 emissions (No CEMS)- Carbonaceous material (C carbon )
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 CO 2 emissions (No CEMS)- Electrode consumed in EAF (C electrode ). 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 CO 2 emissions (No CEMS) - Steel produced (C 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)(1) Carbon content of each process output used to determine CO 2 emissions (No CEMS) - Slag produced (C slag ) in EAF. Q-5 Provides production or raw material data
described in section 2.1 of Part Two of this
memorandum.

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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 CO 2 emissions (No CEMS) - Air pollution control residue collected (C R ) 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 CO 2 emissions (No CEMS) - molten
steel before decarburization (C steelout ) 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 CO 2 emissions (No CEMS) - molten steel after decarburization (C steelout )
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 CO 2 emissions (No CEMS) - Air pollution control residue collected (C R ) 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 CO 2 emissions (No CEMS) - Gaseous
fuel combusted in the direct reduction furnace (F g ) . 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 CO 2 emissions (No CEMS) - iron ore or iron ore pellets fed into the direct reduction furnace (C

ore ) . 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 CO 2 emissions (No CEMS)- Carbonaceous material (C carbon )
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 CO 2 emissions (No CEMS) - Other materials charged to the direct reduction furnace (C other ). 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 CO 2 emissions (No CEMS) - Iron produced from direct reduction furnace (C iron ). 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 CO 2emissions (No CEMS) - Nonmetallic materials produced from direct reduction furnace (C NM ). Q-7 Provides production or raw material data
described in section 2.1 of Part Two of this
memorandum.

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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 CO 2 emissions (No CEMS) - Air pollution control residue collected (C R ) 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
CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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.

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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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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
CO 2 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 CO 2 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

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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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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

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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 CO 2 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 CO 2 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 CO 2 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
CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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.

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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 CO 2 emissions (NoCEMS)- 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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

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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 CO 2 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
CO 2 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
CO 2 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
CO 2 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
CO 2 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
CO 2 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 CO 2 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

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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 CO 2 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 CO 2 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 CO 2 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 CO 2 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 CO 2 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
CO 2 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

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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 calci nation 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

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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 N 2 O 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 pe rformance, 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 pe rformance, design, and operation; cost to do business; raw material usage; or production.

## E.O. 12866 Review

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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 ab atement 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 informati on 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 th e 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 informati on 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 th e 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 informati on about facility or process performance, design, and operation; cost to do business; raw material usage; or production.

## E.O. 12866 Review

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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 descri bed in section 2.3 of
Part Two of this memorandum that could
be used to calculate th e 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 th e 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

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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 desc ribed in section 2.3 of
Part Two of this memorandum that could
be used to calculate th e 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 informati on 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 th e 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) N 2 O 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.

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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)), N 2 O 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)), N 2 O 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 c ontrol 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 informati on 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%.

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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" ((F gf ) 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" ((P gf ) 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" ((F lf )

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" ((P lp )

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" ((F lf )

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" ((P lp )

n ). X-2 Provides production or raw material data
described in section 2.1 of Part Two of this
memorandum.

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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" ((CC lf )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" ((F sf )

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" ((P sp )

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" ((CC lf )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.

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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 CO 2 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.

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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 Pr ovides 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 CO 2 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.

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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 emissionfactor 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 N 2 O 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 CH 4 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 factorfor 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 N 2 O 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.

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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.

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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 CH 4 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 CH 4 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 CH 4 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 N 2 O 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.

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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) CO 2 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 CO 2 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) CH 4 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 CH 4 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 descri bed in section 2.3 of
Part Two of this memorandum that could be used to calculate the annual asphalt production if the CO 2 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 CO 2 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 CO 2 emissions (as currently required to be reported under 40 CFR 98.252(f) and made publicly avaiable) 5 and the carbon emission factor
“CEF AB ” (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 CO 2 emissions (as currently required to be reported under 40 CFR 98.252(f) and made publicly avaiable) 5 and the CO 2 emission factor
“EF AB,CO2 ” (required to be reported under 40 CFR 98.256(j)(8)) are also known. Additionally, if the uncontrolled emissions represented by the CO 2 emisison factor
“EF AB,CO2 ” are very low, could estimate annual asphalt production if only this
carbon factor and the CO 2 emisisons are
known.

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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: CH 4 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 CO 2 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.

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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, hei ght 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): CH 4 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 CO 2 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 listedin 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 CH 4 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 CH 4 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 CH 4 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 ra te 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 typethat have an equilibrium vaporphase concentration of CH 4 of 0.5 volume percent or greater. Used in methodsspecified 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 contentof 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 CO 2 (ton CO 2 /ton of phosphate rock) for which Equation Z-1b is used (No CEMS). Z-1b Provides data descri bed in section 2.3 of
Part Two of this memorandum that could
be used to calculate the amount of phosphate rock consumed if the N 2 O 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.

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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 CO 2 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 informati on about facility or process performance, design, and operation; cost to do business; raw material usage; or production.

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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 CH 4 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 informati on 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 N 2 O 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 informati on 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 CaCO 3 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 Na 2 CO 3 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) CO 2 emissions factor for each
month. BB-2 Provides data descri bed in section 2.3 of
Part Two of this memorandum that could
be used to estimate the amount of petroleum coke consumed if the CO 2 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 CO 2 concentration during performance test (percent CO 2 ) for each manufacturing line or stack. CC-3 Provides information about the CO 2 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) CO 2 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 pe rformance, 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) CO 2 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 av erage 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 U tilities 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 spec ified 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 rep orted 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”

cat egory (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 re porting 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 eq uations. EPA outlined a four-step process for this evaluation in the final rule, and in a supporting memorandum en titled “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 a lternative 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 calcu lation analysis was undertaken for 25 of the 28 subparts of the greenhouse gas reporting pr ogram (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 di d not identify the need to proceed to Step 3. a


# Please see memorandum “Evalu ation 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 ev aluate application of direct measurement of emissions using CEMS, and summarizes the re sults of the evaluati on. Section 4 provides a summary of the analysis. Appendix A presents detailed evaluations of all the alternative calculation equations reviewed fo r each subpart. Appendix B presen ts a detailed characterization of facilities and processes using CEMS for each of the subparts. Appendix C provides detailed cost estimates of requiring CO 2 

# 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 “inpu t to equation” data element is not listed explicitly in this
memorandum.

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2 Section 2.0 of this memorandum evaluate s alternative equations to calculate GHG emissions. Section 2.1 discusses the procedures used to identify alternative calculation equations,
section 2.2 discusses the data s ources reviewed to obt ain the alternative ca lculation equations,
and section 2.3 summarizes th e results of the review.

2.1 Procedures for Identifying and Review ing Alternative Calculation Equations

Alternative calculation equations were identif ied 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 repor ting 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 ca lculation was evaluated to determ ine if it was the same as the
method chosen in the GHGRP. For calculations di fferent than what is required in the GHGRP, the alternative calculation equations were evalua ted 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 decr ease accuracy or increase uncertainty in the calculated emissions based on information pr ovided in the sources reviewed. For those calculation equations that were id entified as using inputs different than the “inputs to equations” data elements, and also have similar or lowe r uncertainty and similar or higher accuracy in emissions estimation than the current method, costs were estimated if suffi cient cost information
was available. The cost of the alternativ e 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 consider ed but not included in the final rule were
identified in the techni cal 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 dete rmine if the calcula tion 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 Re gistry (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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3  Country-specific GHG reporting programs (Australia National Greenhouse Gas Reporting Program (ANGGRP), Canada)

 World Resources Institute/World Busine ss 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 progr ams 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 no tice solicited input from commenters on
alternative calculation methods. Commenters s uggested alternative cal culation methods for 5 subparts: K, P, Q, R, and X. 45-48



# 2.3 Results of Analysis

Table 2-1 summarizes the results of evalua ting alternative calculation equations. The table indicates that for all of the subparts ex cept 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 concerns 49 

# , mandated process configuratio ns (which is not the intent of the GHGRP), or increased uncertainty or d ecreased accuracy in em ission estimates. Because of this result, no further evalua tion of costs was undertaken for th ese alternative ca lculations. For
alternatives that were identified as viable in Su bparts X and Y, further analysis indicated they resulted in a high cost to implement. Appendix A contains detailed eval uations for each subpart
and for each alternative cal culation 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 Equations a



## Uses Same
2015 Inputs to Equations b 

## Uses Same Type of Inputs
that do not

Alleviate
Disclosure
Concerns c 

## Mandate
s Process Design d 

## Increased Uncertainty/

Decreased Accuracy High Cost

to Implement e



# C N √ NA

E N √ √ NA

F N √ √ NA
G N √ √ √ NA

H N √ √ √ NA

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4 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 configur ations (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 Cont inuous Emissions Mo nitoring Systems

Section 3.0 of this memorandum evaluates the use of CEMS for each subpart instead of calculation equations for GHG reporting. For the ev aluation of CEMs, we initially applied the
same criteria that were used for the Alternative Calculati on Equations. Because CEMS are directly measuring emissions, no equation inputs ar e used. As a result, the use of CEMS would
alleviate the disclosure concerns identified in Step 2 of the an alysis. In addition, use of the
CEMS does not result in increase d 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 ar e not routed through a stack. Th is review characterizes the facilities (or process units in a facility) that currently use CO 2 

# CEMS (or N 2 

# O or methane CEMS if applicable), the facili ties 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 u pgrades. 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 CO 2 

# CEMS only if a facility already has CEMS for another regulation and meets cert ain 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 CO 2 

# emissions using a CEMS. Most of the subparts with “inputs to equations” data elements allo w CEMS as an option to determine CO 2 

# emissions (some
also allow N 2 

# O with approval).

Characterization of Facilities and Process Units The first step in the evaluation of applyi ng 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 a nnual report submissions in the
GHGRP 50 

# provides the most up-to-date information on f acility 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. Ther efore, for this analysis, we also used information in the GHGRP regulatory impacts analysis (RIA) 51 

# , the GHGRP background technical support documents (TSD), and inform ation in other EPA databases (particularly databases used in the development of air rule s and regulations, such as new source performance standards (NSPS) or national emission standard s for hazardous air pollutants (NESHAP)), to
obtain information on facilities a nd process units with non-GHG CEMS.

Estimating Current and Potential CEMS usage

Where information was available in the GHGRP indicating reporters using CEMS for
CO 2 

# , CH 4 

# , and N 2 

# O in facilities, those data were used to identify the actual number of facilities or process units th at currently use CO 2 

# CEMS (or N 2 

# O or methane, if applicable). NSPS and NESHAP rule requirements that a pply to GHGRP reporters may also require CEMS usage not related to GHGs. These regulations do not generally require CO 2 

# CEMS because they regulate criteria pollutants and air t oxics. However, the CEMS installed to meet the rules may be modified to be used for GHG re porting, which would lower the overall cost of installing the CEMS. Table 3-1 summarizes th e NSPS and NESHAP app licable to sources subject to each subpart with “inputs to equatio ns” data elements, and identifies the NSPS and NESHAP that have CEMS as an option or re quirement. The CEMS standards in the NESHAPs and NSPS were used to develop a count of poten tial facilities or proce ss 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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6 Table 3-1. NSPS and NESHAP Applicable to GHGRP reporters with “inputs to equations” data elements

Subpart
of Part
98 NESHAP/NSPS Subparts Reviewed a 

# 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 CE MS 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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7 Subpart
of Part
98 NESHAP/NSPS Subparts Reviewed a 

# 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 one of several compliance options NSPS: Subpart NNN 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 Kraf t 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 in stall a CO2 CEMS for the purpose of monitoring for the GHGRP may be minimal, such as adding a CO 2 

# analyzer only, or more co stly, such as adding a CO 2 

# 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 CO 2 

# CEMS at a reduced cost was evaluated. Based on the requirements in the rules, the GHGRP subparts, and the proce ss/facility count and CEMS information (discussed earlier), the following CEMS usages were identified:

 Source has CO 2 

# CEMS

 Source has non-CO 2 

# GHG CEMS (such as N 2 

# O CEMS) or has non-GHG CEMS (such as
NO X 

# or CO monitors)

 Source has no CEMS

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8 After the CEMS characteri zation was completed, the co st impacts of requiring CO 2 

# 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 wa s reviewed and separated into the components necessary for CO 2 

# CEMS. 51 

# Based on the type of CEMS used, five CEMS usage scenarios were developed. The costs associated with addi ng equipment to meet the GHGRP monitoring requirements for sources/units in each of the fi ve CEMS usage scenarios were developed from the CEMS component costs. Table 3-2 summari zes the costs and equipment necessary for each scenario. For Scenarios 2 and 3, costs were assign ed considering specific rule requirements that are presented in Appendix B and information in the RIA.

Table 3-2. Summary of Costs for CO 2 

# CEMS Modifications

Scenario
# Scenario Total annual cost/application

1 Source has no CEMS -- Add CO 2 

## analyzer, flow meter, and
infrastructure $ 70,265

2 Source has CEMS for other pollutants -- Add CO 2 

## analyzer
and flow meter $ 56,040

3 Source has CEMS for other pollutants -- Add CO 2 

## analyzer only $ 20,593



# 4 Source has CEMS for other pollutants -- Add flow monitor only $ 24,511

5 Source has CO 2 

## 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 CO 2 

# CEMs, non-CO 2 

# GHG CEMS, or non-GHG CEMS. The ta ble also shows the potential number of sources that may have the same monitoring equipment base d on a review of requirements in NSPS or NESHAP, and assumptions regarding which faci lities would use CEMS. The potential number
includes both the actual number and additional units/facilities th at 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 th e CEMS characterization analysis for each subpart.

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9 Table 3-3. Summary of CEMS Characteriza tion for Each Subpart with “Inputs to Equations”

Subpart Basis Number Subject to Subpart a 

## Reporting CO 2 

## CEMS in GHGRP Reporting non
‐ CO 2 

## 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 0 b 

## 14 c 

## 14 c



## Units 140 112 0 b 

## 0 d 

## 28 e



## 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 20 g 

## NA

Units 65 NA NA 36 g 

## 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 104 h



## Process

Units 317 26 NA NA 317 i



## Y ‐ Other

Process

Units j 

## Facilities 145 0 0 0 0

Process

Units 1,580 0 0 0 0

Z Facilities 13 NA NA 7 k 

## 7 k



## AA Facilities 110 0 l 

## NA 89 m 

## NA

Units 330 m 

## 0 l 

## NA 266 m 

## NA

BB Facilities 1 NA NA NA NA

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10 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 faciliti es that reported to the GHGRP in 2011.

b 

### No units or facilities are known to be using non-CO 2 

### GHG CEMS (e.g., for CH 4 

### or N 2 

### O).

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 CO 2 

### 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 CO 2 

### 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 Environm ental and Cost Impacts for Final Portla nd Cement NESHAP and NSPS” (August 6, 2010), minus the 112 that reported to GHGRP in 2011 that they are using CO 2 

### 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 th e inventory data were reported by the facility and presumed to

be the actual count of units with NO X 

### 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 calc ining, catalytic reforming, fl ares, loading operations, and ot her 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 th ey were using a CEMS to report GHG emissions.

m 

### The NCASI survey provided process unit data and the 2009 RIA es timated that units were subject to Ti er 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
CO 2 

# CEMS are required for sources or process units subject to the GHGRP. The table does not show the cost of applying N 2 

# O or CH 4 

# CEMS. The table presents th e cost to upgrade monitoring equipment (existing equipment for actual sour ces and likely equipmen t for potential sources based on the air rules) and the cost to add full CO 2 

# CEMS for facilities that are subject to the GHGRP, but do not have CEMS. Table 3-4 su mmarizes costs based on actual counts of units/facilities with CEMS, and potential counts of units/facilit ies 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 base d on NESHAP and NSPS rule requirements. See Appendix B for detailed information for each s ubpart. Appendix C contains detailed cost estimates for each subpart and each CEMS scenari o. Appendix C also contains cost estimates for all three types of GHG CEMS (CO 2 

# , N 2 

# O, and CH 4 

# ).

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)
Actual a 

# Potential b 

# Actual a 

# Potential b

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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/fac ilities 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 de tailed 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 evaluate d in this memorandum.

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12 5.0 References

1. U.S. EPA. "Technical Support Document fo r 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/TS D%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/document s/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 Greenhous e 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 fo r Process Emissions from Cement: Proposed Rule for Mandatory Reporting of Greenhous e Gases." Office of Air and Radiation. January 28, 2009. Available: http://www.epa.gov/ghgreporting/document s/pdf/archived/tsd/TSD%20Cement%20_EP A%201-28-09.pdf.

6. U.S. EPA. "Technical Support Document fo r the Ferroalloy Producti on Sector: Proposed Rule for Mandatory Reporting of Greenhous e Gases." Office of Air and Radiation. January 22, 2009. Available: http://www.epa.gov/ghgreporting/documents/pdf/archived/tsd/TS D%20Ferroalloys%20_ EPA%201-22-09.pdf.

7. U.S. EPA. "Technical Support Document fo r 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/docu ments/pdf/2010/Subpart-L_TSD.pdf.

8. U.S. EPA. "Technical Support Document fo r the Glass Manufactur ing Sector: Proposed Rule for Mandatory Reporting of Greenhous e Gases." Office of Air and Radiation. January 22, 2009. Available:

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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 fo r Emissions of HFC-23 from Production of HCFC-22: Proposed Rule for Mandatory Repor ting 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 fo r 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/document s/pdf/archived/tsd/TSD%20Lead%20%20_E PA%201-22-09.pdf.

13. U.S. EPA. "Technical Support Document fo r the Lime Manufacturing Sector: Proposed Rule for Mandatory Reporting of Greenhous e Gases." Office of Air and Radiation. January 22, 2009. Available: http://www.epa.gov/ghgreporting/document s/pdf/archived/tsd/TSD%20Lime%20_EPA% 201-22-09.pdf.

14. U.S. EPA. "Technical Support Document fo r the Miscellaneous Uses of Carbonate Sector: Proposed Rule for Mandatory Repor ting 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 Greenhous e 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.

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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 fo r the Petroleum Refining Sector: Proposed Rule for Mandatory Reporting of Greenhous e 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/document s/pdf/archived/tsd/TSD%20Soda%20Ash%2 0_EPA%201-22-09.pdf.

22. U.S. EPA. "Technical Support Document fo r 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:

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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 fo r 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 fo r 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 Emi ssions and Sinks: 1990-2006." April, 2008. EPA
430-R-08-005. Available: http://www.epa.gov/climatechange/ghgemissi ons/usinventoryreport/archive.html.

27. Climate Leaders Greenhouse Gas Inventory Protocol. Available: http://www.epa.gov/climateleader ship/guidance/index.html.

28. Voluntary Reporting of Greenhouse Ga ses 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-repo rting-protocol/.

30. California Climate Action Re gistry. August 2008. Available: http://www.climateregistry.org/tools/prot ocols/general-repor ting-protocol.html.

31. California Air Resources Board Ca p 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.westernclimatei nitiative.org/index.php.

35. Eggleston H.S., Buendia L., Miwa K., Ng ara T. and Tanabe K. (eds). "2006 IPCC
Guidelines for National Greenhouse Gas I nventories." Prepared by the National
Greenhouse Gas Inventories Programme. The Intergovernmental Panel on ClimateChange (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/L exUriServ.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.cleanenergyregul ator.gov.au/NationalGreenhouse-and-Energy-Repor ting/Fact-sheets-FAQs-andguidelines/Guidelines/Pages/default.aspx.

38. Environment Canada - Canada's Greenhous e Gas Emissions Monitoring, Reporting and
Verification of Greenhouse Gas Sources and Si nks. Available: http://www.ec.gc.ca/gesghg/default.asp?lang=En&n=1357a041-1.

39. World Resources Institute and World Bu siness Council for Sustainable Development
Greenhouse Gas Protocol. Availabl e: http://www.ghgprotocol.org/.

40. "Compendium of Greenhouse Gas Emissions Methodologies for the Oil and Natural Gas Industry." American Petroleum Ins titute (API). August 2009. Available: http://www.api.org/environment-hea lth-and-safety/climate-change/whatsnew/compendium-ghg-methodologie s-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 Conventi on on Climate Change. Available: http://cdm.unfccc.int/methodologies/index.html.

44. "Clean Energy Legislative Package." Aust ralian Government Department of Climate Change and Energy Efficiency. Available: http://www.cleanenergyfuture.gov.au/cleanenergy-future/our-plan/.

45. Comment on the Mandatory Greenhouse Ga s 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 Defens e Council, and Sierra Club, EPA-HQ-OAR2010-0964-0029.

49. “Evaluation of Competitive Harm from Re porting ‘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/re porters/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.re gulations.gov/#!documentDetail;D=EPA-HQOAR-2008-0508-2229.

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18 Appendix A1 Summary Evaluation of Altern ative Calculation Equations

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19 Table A1-1. Summary of the Evaluation of Alt ernative 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 a lternative 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, disclo sure 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 us ed instead of facility-specific information resulting in lower accuracy than Tier 1. Bo th methods still requir e 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 CF 4 

## and C 2 

## F 6 

## and IPCC Tier 1 for
CO 2 

## emitted during electrolysis) use defau lt emission factors which result in greater uncertainty than the current method. The third for calculating CF 4 

## and C2F 6 

## 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 CF 4 

## and
C 2 

## F 6 

## , ±50 percent. The alternatives still use pr oduction 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 info rmation, 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., ra w 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 an alysis, 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 un certainty 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

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

20 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 CO 2 

## , 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 CH 4



## . 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 HF C-23 emissions). The alternative methods reviewed still use production da ta 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 em ission 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 id entified 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 ex cludes small contributors, and (5) plant-

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21 Subpart Description Summary of Evaluation of Alternative Calculations
wide CO 2 

## 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 an alysis, 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 da ta. 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 consum ed); 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, disclo sure concerns were identified for this
information. a 

## U Carbonate No calculation methodologies were identif ied that would be an appropriate alternative.
Two alternative calculation methods were id entified: 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 dolom ite. 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; accord ing 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 al so 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 iden tified 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 inform ation; according to Step 2 of th e 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 CO 2 

## and
CH 4 

## (published by IPCC) multiplied by the production of each product. The method still uses plant specific producti on 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 CO 2 

## ; 30-80% higher for CH 4 

## ). 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 CO 2 

## 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 co mmenter suggested allowing the use of subpart PP methodologies, which require dire ct 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 iden tified 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 we re identified for calculating CO 2 

## emissions. The first alternative approach uses default emission factors multiplied by the amount of flare gas burned. The second method uses te st 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 CO 2 

## and CH 4 

## 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 GH G 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 analysis a 

## , 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 Samplers TM 

## , 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 uncert ainty 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 measuremen ts for some inaccessible components, this approach is likely to be difficult and costly to implement. Storage Tanks: For storage tanks used to store unstab ilized fuel oil, 3 alternatives were identified. The first uses default emission factors multiplied by the quantity of crude oil
to calculate the CH 4 

## 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

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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.); accord ing to Step 2 of th e 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, sulf ur 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, disclo sure concerns were identified for this
information. a 

## AA Pulp and Paper No calculation methodologies were id entified 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 furn aces were identified. Both are based onusing default factors. One is based on using default values for HHV instead of sitespecific values and the method is only applicab le 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 slig ht 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, disclo sure 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

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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. Th e second option is to estimate emissions based on the carbon reducing agent. Emi ssions would be estimated by multiplying the tonnage of carbon reducing agent and 2 defau lt factors. The uncertainty of this option has not been determined, but is likely much higher than the cu rrent method because 2
default factors are used rather th an 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 ba sed on the quantity of carbon used in the production of metal. This method has a lo wer uncertainty, but it is still is not as
accurate as the cu rrent 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 CH 4 

## 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, ple ase 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 Altern ative 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 Source 1 

### ID Description CARB 1 Same as 40 CFR part 75: CEMS.
2 Calculate emissions sim ilar to IPCC methods usi ng fuel consumption and
carbon or heat content. Sti ll requires fuel input info rmation for calculations, which was identified as having disclosure concerns in Step 2 of the analysis.
CCAR 1 Similar to IPCC met hods. Still requires information on fuel burned in calculations, which was identified as ha ving disclosure concerns in Step 2 of the analysis 2 Same as 40 CFR part 75: CEMS.
TCR 1 Calculate emissions si milar 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 usi ng WRI/WBCSD protocols. St ill requires fuel input data in calculations, which was identif ied 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 in formation which was identified as having disclosure concerns in Step 2 of the analysis. .
40 CFR part 75 CO 2 

### 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 bala nce approach similar to Tier 3. Still requires fuel and heat content informa tion 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 iden tified as having disclosure concerns in Step 2 of the analysis. .
Tier
3 Similar to IPCC Tier 2, but uses EF based on repr esentative 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 IP CC Tier 3 approaches.
2 CEMS when a CO 2 

### diluent monitor is installe d for measurements of other pollutants. EU ETS 1 Emissions calculated using mass bala nce 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 CO 2 

### 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 R egistry; 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 Reportin g Program.

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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 Source 1 

### ID Description
IPCC Tier
1 Multiplies facility-level production times the highest default emissions factor in IPCC Tier 1, which assumes no abatement of N 2 

### O 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 dest ruction factors and not
defaults. More accu rate than IPCC Tier 2 but st ill 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 Climat e Change, 2006; U.S. Inv = U.S. National I nventory Report, 2008 Method; WRI/WBCSD = Wo rld Resources
Institute/World Business Council for Sustai nable Development; DOE = Department of Energy’s 1605 (b) Voluntary Reporting Program ; TCR = The Climate Registry.

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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 Source 1 

### ID Description
IPCC Tier 1 -
General Uses default emission factors for CF 4 

### and C 2 

### F 6 

### 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 CF 4 

### and C 2 

### F 6 

### . High uncertainty compared to estimating
emissions with the current method for CF 4 

### and C 2 

### F 6 

### , about ±50 percent. Could develop new emission factors for CF 4 

### and C 2 

### F 6 

### to reduce the uncertainty of the methodology, but the method still uses quantity of aluminum produced which was identifie d as having disclosure concerns in Step 2 of the analysis. .
Tier 1 - Electrolysis Uses default emission factors for CO 2 

### 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 Pa nel on Climate Change, 2006.

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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 Source 1 

### 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 ha ving 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 concer ns 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 us es 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 oxi dation 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 St ep 2 of the analysis. Very accurate method only if actual carbon conten t 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 de fault carbon content value and calculates annual, fa cility-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/WB CSD = The World Resource Institute and World Business Council fo r Sustainable Development’s Greenhouse Gas Protocol; TCR-GRP = The Climate Regi stry General Reporting Protocol For the Voluntary Reporting Pr ogram, May 2008; DOE = Department of Energy 1605(b) Voluntary Reporting Program – Amm onia; U.S. Inv = U.S. National Inventory Report, 2008 Method.

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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 Source 1 

### ID Method Type 2 

### Description

IPCC Tier
1 Cement Default factor s; 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/WBCS D, 1A but w/default factors.

WRI/WBCS

D 2A Cement Site/corpora te 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/WBCS D, 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/WBCS D, 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 Climat e Change, 2006; U.S. Inv = U.S. National I nventory Report, 2008 Method; WRI/WBCSD = Wo rld Resources
Institute/World Business Council for Sustai nable Development; CA AB32 = CA Mandatory Reporting Program; CCA R = California Clima te Action Registry; DOE = Department of Energy’s 1605 (b) Voluntary Reporting Program; CL = EPA Climate Leaders; EU ETS = European Union Emission T rading 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 ma terials consumed, the quantity of clinker incorporated into the cement, and the quantity of cement produced. It calculates CO 2 emissions based on the amount of raw materials and thei r carbonate content. This approach directs companies to collect data on cement production, the raw ma terial ratio to produce clinker and the CaCO 3 equivalent content of the raw mate rials, thus allowing companies to monitor changes in emissions due to m odifying the cement manufacturing process.
Clinker Production-Based method is a mass balance approach based on the qua ntity of clinker produced. It calculates CO 2 emissions based on the volume and composition of clinker produced as well as the amount of cement k iln dust (CKD) not recycled to th e kiln. This approach has bec ome 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 produc e clinker, as well as the respective emission factor(s) of the carbona te(s) consumed. It includes an adjustment to subtract any u ncalcined 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 Source 1 

### ID Description

Dow Corning 1 Same as current method for CO 2 

### , except excludes from the mass balance inputs contributing less than 5% of plan t 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 e quations” 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 CO 2 

### , except with more flexibility in how carbon content is reported (e.g., supplier, in dependent 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 CO 2 

### Tier
1 Uses mass of process outputs (pr oduct and nonproduct) and productionbased emission factors. S till uses production data which was identified as having disclosure concerns in Step 2 of the analysis. Method decreases accuracy of estimates 25-50%.
IPCC CO 2 

### Tier
2 Similar to current method but uses default emission factors instead of facility specific carbon content. Still us es 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 ma terial, energy content of carbon material, and emission factor based on energy cont ent. Use of default factors would decrease accuracy of estimates by 15-40%. Use of facility specific factors
would be similar to current method. St ill requires knowing carbon content of
materials and amount of ma terials which was identified as having disclosure concerns in Step 2 of the analysis. .
U.S. Inv Same as IPCC CO 2 

### Tier 1.

IPCC CH 4 

### Tier
1 Use mass of product and generic produc tion-based emission factors. Still uses production data which was identifie d 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 Climat e 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 Green house Gas Emissions
and Sinks.

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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 fa ctor 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 measur ement of the concentration and flow-rate (i.e., CEMS ) from the vents at an individual plant to obtain instantaneous F-gas emissi on rate. Total quantity of F-gas
released is the annual sum of measured instan taneous 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 ra te, 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 Pa nel 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 modi fied version of IPCC Tier 3. Process CO 2 

# emissions are calculated using a carbon mass balance for each conti nuous glass melting furnace. The equation is based on:
mass fraction of carbonate mineral in each raw materi al, mass of carbonate raw material charged, default emission factor for carbonate-based raw material (s hown 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 Source 1 

### 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. Signi ficant decrease in accuracy of emission estimates (60% from current method).
IPCC Tier
2 Output Uses default emission factor s and cullet ratios, and production information for specific types of gl ass 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 equatio ns” 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 di fferent 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 us es “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 equatio ns” data elements.

Protocols and

programs created after
GHGRP No new calculation methods identified.

1 IPCC = Intergovernmental Panel on Climat e Change, 2006; U.S. Inv = U.S. National I nventory Report, 2008 Method; DOE = Departme nt of Energy’s 1605 (b) Voluntary Reporting Program; EU ETS = European Union Emission Trading System; ANMGGRP = Aust ralian National Mandatory Greenhous e Gas Reporting Program; EB = European Bank for Reconstruction and Development.

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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 destruct ion efficiency. Still requires produc tion 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 da ta 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 conc entration of HFC-23 in the gas vented from process, mass flow of process stream, mass flow of HFC-23/othe r product stream, and fraction HFC-23 in HCFC-22/other stream.) Methods allow continuous and less frequent monitoring. Still requires 2015 in put data which were identi fied 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 c ontent 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 dest royed 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 = Wo rld Resources Institute & World Business Council for Sustainable Development. Gre enhouse Gas Protocol: HCFC-22 Emissions from Production of HCFC-22, Version 2.0. Dece mber 2007; DOE = Department of Energy’s 1605(b) Voluntary Report ing Program; TCR = The Climate Registry.

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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 woul d 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 provid ed to assess the accuracy of the methodology. Method would not reveal any of the “inputs to eq uations” 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 Source 1 

### 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 CO 2 

### 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 inform ation which were identified as having disclosure concerns in Step 2 of the analysis. API 1 Uses production rate and simplified stoich iometric ratios. Met hod 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 proportiona lity 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 Mec hanism.

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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 consider ed but not adopted in the final GHGRP: (1) a simple mass ba lance assuming all the carbon input to the process converts to CO 2 

### ; and (2) exclude small contributors from the mass balance fo r EAFs only. These are addressed in the following

summary. Methods previously
considered but not adopted in
final GHGRP Source 1 

### ID Description

CL Section
2.2 Exclude small contributors from mass bala nce (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 factor s instead of site-specific information and information on inputs.

 Not comprehensive, i.e., IPCC listed only 5 of the 7 pr ocesses in GHGRP

 Hides recipes/ingredients, but not pr oduction 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 recipe s/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 ca rbon 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 CO 2 

### mass balance (ignore movement of energy sources within plant bounda ries) 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 ad opted in the final GHGRP or are id entical 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 guidelin es, section 4.66 (similar to IPCC Tier 2)

 UN, Framework on Climate Change – Clean De velopment 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/WBCS D = World Resources Institute/Wor ld Business Council for Susta inable Development; DOE = Department of Energy; CL = EPA Climate Leaders; EU ETS = European Union Emission Trading System; AISI = American Iron and Steel Institute.

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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 de fault 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% uncer tainty compared to the current method. However, the annual mass of each carbon-containing ma terial is the same type of inform ation 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 produc tion type (imperial smel ting furnace, direct smelting furnace). Uses production data, whic h was identified as having disclosure concerns in Step 2 of the analysis, and re sults in a ±45% increase in uncertainty. IPCC Tier 2 Similar to IPCC Tier 1 except emi ssion factors are based on country-specific information on the use of reducing agen ts, 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-specifi c emission factors that is applied to the quantity of feed or pr oduct material. Appropria te for facilities where process inputs and operating paramete rs are consistent. This option was not adopted because of the potent ial 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 conten t 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 mate rials, 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 Clim ate Change, 2006; ANMGGRP = Australian Nati onal 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 Source 1 

### ID Method Type 2 

### 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 carb onate inputs to the kiln and emission
factors and calcinations fractions to the carbonates consumed. Low uncertainty in emissions but requir es feedstock information which was identified as having disclosure concerns in Step 2 of the analysis. U.S. Inv Output Sa me 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 a nd 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 lim e. It is not widely used (or used at all) and not appropriate for considerat ion. The CDM provides a methodology for hy draulic lime production uses fossil fuel usage and electricity usage to estima te emissions. This method is for a ne w method of producing hydraulic lime for construction purposes by blendi ng conventional hydraulic lime with alternative material additives.

1 IPCC = Intergovernmental Panel on Climat e Change, 2006; U.S. Inv = U.S. National I nventory Report, 2008 Method; WRI/WBCSD = Wo rld Resources
Institute/World Business Council for Sustaina ble Development; EU ETS = European Union Emission Trading System; TCR = The Climat e 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 Source 1 

### 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 know ing overall carbonate consumed which was identified as having di sclosure concerns in Step 2 of the analysis.
IPCC Tier
2 Same as Tier 1, except the fraction of li mestone 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 Clim ate Change, 2006; ANMGGRP = Australian Nati onal Mandatory Greenhouse Gas Reporting Progr am.

# 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 Source 1 

### ID Description

IPCC Tier
1 Uses default emission factors and assumes no abatement. Facility level based
rather than unit based. St ill 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 an d destruction factors on a site-specific basis. Still requires using production in formation 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 N 2 

### O 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 nationa l 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-se lective catalytic reduction control technologies.
Protocols and

programs created after
GHGRP None identified.

1 IPCC = Intergovernmental Panel on Climat e Change, 2006; U.S. Inv = U.S. National I nventory Report, 2008 Method; WRI/WBCSD = Wo rld Resources
Institute/World Business Council for Sustai nable 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 us e 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 CO 2 

### and CH 4 

### 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
CO 2 

### ; 30-80% for CH 4 

### )

 Default factors cannot reflect site-sp ecific differences in characteristics such as the type of feedstock, operating conditions, etc.

 More appropriate for s ector wide estimates IPCC Tier 3,
modified Direct

measurements Requires routing of process vent emissions to stacks for direct and continuous
measurements of CO 2 

### 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

 CH 4 

### and N 2 

### O emissions from combustion s ources would be calculated using subpart C procedures.

 More accurate and less uncertainty than current option

 Similar to IPCC Tier 3 approach, exce pt IPCC indicates that process vent emissions may be either esti mated or measured, and IPCC CH 4 

### 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 defa ult 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 emi ssion factor approach is thought to be reasonably accurate during normal operation.

 More appropriate for s ector wide estimates.
API Test data Uses vendor or f acility test data to ca lculate CO 2 

### and CH 4 

### emissions (N 2 

### O are considered negligible by API).

 More accurate than default emission fa ctors; however, level of uncertainty is higher compared to using meas ured 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 Climat e Change, 2006; U.S. Inv = U.S. National I nventory Report, 2008 Method; WRI/WBCSD = Wo rld Resources
Institute/World Business Council for Sustaina ble Development; EU ETS = European Union Emission Trading System; API = American P etroleum 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 CO 2 

### emissions (allowed only for units with throughputs less than 10,000 bbls/stream day), th e 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 defaul t emission factors fo r calculating the
emissions of CO 2 

### and CH 4 

### from asphalt blowing operations. Part 98
calculations methods for both controlled and uncont rolled asphalt blowing operations relies on site-s pecific 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-sp ecific differences in characteristics such as operatin g conditions, etc.

 More appropriate for s ector 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-sp ecific differences in characteristics such as operating conditions, effect iveness of LDAR programs, etc.

 More appropriate for s ector wide estimates

Protocols and

programs created after
GHGRP UNFCCC Direct

measurements Measure the flow rates of the phys ical leaks using Hi-Flow Samplers TM



### , calibrated bag, or other suitable flow measurements technology and calculate the emissions using the rate x time period of leaking.

 More accurate and less uncerta inty than current option.

 More costly due to large numbe r of components to monitor.

 May not be practical to monitor so me components due to safety and accessibility issues.

 Data used to calculate emissi ons does not contain information
determined to have disclosure con cerns in Step 2 of the analysis.

1 API = American Petroleum Institute; UNFCCC = Unit ed 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 CH 4 

### published by API multiplied by the quantity of crude oil.

 Still uses the amount of unstabili zed 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 w ould likely be high compared to
current methods

 Default factors cannot reflect site-sp ecific differences in characteristics such as the type of crude, operating conditions, etc.

 More appropriate for s ector wide estimates
API API E&P
TANKS

program API E&P TANKS program, which uses pr essure differentia l, 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 unsta bilized 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 unsta bilized 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 Source 1 

### ID Description U.S. Inv Option 1 Uses default fa ctors based on regional chemical composition of phosphate rock. Less accurate than current method, but still requires mont hly 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.

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

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 Type 2 

### 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 altern ative methodologies were reviewed fo r these sources as they will be covered under the subpart C analysis.

 Subpart AA requires reporting of fossil fuel and biogeni c emissions from recovery furnaces and lime kilns.

The fossil fuel component of the emissions are calcul ated using methods in subpa rt 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 S ubpart AA for calculations.

1 GHG TSD = GHG technical support documents ; WRI/WBCSD = World Re sources Institute/World Business Council for Sustainable Devel opment; ICFPA/NCASI = International Council on Forest and Paper Association/National Council for Air and Stream Improvement; CARB = California Air Resources
Board.

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

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 Source 1 

### ID Description IPCC Tier 1 Output based approach (using production information) and using default CO 2 

### and
CH 4 

### emission factors from the 2006 IPCC guide lines, and silicon carbide output. Uncertainty estimated to 10%. Requires pr oduction 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 CO 2 

### and CH 4 

### 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 Pa nel on Climate Change, 2006.

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

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 Source 1 

### 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 s ite-specific emission factor to es timate emissions. A nnual 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 disclo sure concerns in Step 2 of the analysis.
Protocols and

programs created after
GHGRP None identified.

1 IPCC = Intergovernmental Pa nel on Climate Change, 2006.

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

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 Source 1 

### 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 Clim ate Change, 2006; ANMGGRP = Australian Nati onal Mandatory Greenhouse Gas Reporting Progr am.

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

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 Source 1 

### ID Description

IPCC Tier
1 Uses default emission factor per unit of output and national productivity data. Has a high uncertainty. More appropriate for aggr egated process information on a sectorwide or nationwide basis. If applied on a facility basis, would require production data which was identified as having disclosu re concerns in Step 2 of the analysis..
IPCC Tier
1a Same as Tier 1, but uses default emissi on 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 a ccounts 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 emi ssion 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 Climat e Change, 2006; U.S. Inv = U.S. National I nventory Report, 2008 Method; ANGGRP = Austr alian National Government Greenhouse and Energy Reporting Program.

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

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 Source 1 

### ID Description

U.S. Inv Reporters use the existing part 98 CH 4 calculation methodology. Higher uncertainty in
emissions than the current method due to defau lt 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 Em issions and Sinks 1990-2006).

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

55 Appendix B Summary of CEMS Characterization for Each Subpart with Inputs to Equations

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

56 Appendix B. General Stationary Fuel Combustion Sources – Subpart C

Industry Background

Stationary fuel combustion comprises many so urces, including boilers , heaters, engines, furnaces, kilns, ovens, flares, incinerators, dryers, and any other equipment or machinery that burns fuel. From two regulatory databases, count s for certain sources ar e available: there are 14,142 industrial, commercial, and institutiona l boilers and 55 CISWI units. Based on 2011 annual report submissions, there were 1,985 faciliti es that reported to GHGRP under subpart C.

Under subpart C, sources must provide emission estimates for CO 2 

# , CH 4 

# , and N 2 

# O for each combustion unit. Emissions must be reported separa tely 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, NO X 

## , SO 2 

## CEMS Yes Yes

Subparts CCCC and DDDD - CISWI NSPS
and Emissions Guidelines PM, NO X 

## , SO 2 

## 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 inst allation 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 Fac ilities 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 le vel. This included CEMS for PM, CO, NO X 

# , and SO 2



# . Table C-2 provides the total number of units wh ich have at least one CEMS installed. In addition, with new requirements in the Boiler MACT, there are an a dditional 95 units which would install a CEMS; this value is also show n in Table C-2. There were 177 facilities that reported under the GHGRP using a total of 311 CO 2 

# CEMS.

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

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 AdditionalBoilers Installing nonGHG CEMS to Comply Total Incinerator

Count/Count of

Incinerators with nonGHG CEMS Count of Facilities with

CO 2 

## CEMS/Total

Count of CO 2 

## CEMS

14,142/1025 95 55/31 177/311



# Subpart C CEMS Count

Table C-3 summarizes the actual data collected for facilities using CO 2 

# CEMS, non-CO 2 

# 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 CO 2 

## CEMS for
GHGRP Reporting non-CO 2 

## GHG CEMS for
GHGRP Reporting non-GHG CEMS for Other EPA Programs

Actual

Facilities 177 a 

## NA
-

Units 311 b 

## NA 1,056

NA = No information available.

a 

## Number of facilities reporting to GHGRP in 2011 that they are using a CEMS to report CO 2 

## emissions.

b 

## The total number of CO 2 

## CEMS at the facilit ies which reported CO 2 

## CEMS.

.

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

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 N 2 

# O process emissions from all adipic acid production units
combined. For N 2 

# O emissions, facilities may either use a si te-specific emission factor applied to the annual adipic acid production, or directly measure the emissions using an EPA-approved
alternative method to the si te-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 Indust ry (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 con centration level of orga nic compounds exiting the recovery device based on a detection principle such as infra-red, photoi onization, or thermal conductivity and each is equipped with a contin uous 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 faci lities 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 an alysis it was assumed that no equipment is installed which would faci litate the installation of GHG CEMS.

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

59 Summary of Available Data on Fac ilities Reporting the Use of CEMS

No facility counts for the use of CO 2 

# CEMS were reported through GHGRP. Subpart E facilities may also use an N 2 

# O CEMS alternative monitoring option provided approval is granted.

Subpart E CEMS Count

Table E-2 summarizes the actual data collected for facilities using N 2 

# O CEMS and non-GHG
CEMS. No facilities were id entified with pre-existing N 2 

# O CEMS and CO 2 

# 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 CO 2 

## CEMS for the
GHGRP Reporting non-CO 2 

## GHG CEMS for the
GHGRP Reporting non-GHG CEMS for Other EPA Programs

Actual Potential a



## 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.

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

60 Appendix B. Aluminum Production – Subpart F

Industry Background

Based on 2011 annual report submissions, there we re 10 facilities that reported to GHGRP under subpart F.

Under subpart F, facilities estimate CF 4 

# and C 2 

# F 6 

# process emissions from anode effects in all prebake and Søderberg electrolysis cells combined. Facilities also estimate CO 2 

# emissions from anode consumption and on- site anode baking. For CF 4 

# emissions, facilities must calculate the emissions using a mass balance approach. Emissions of C 2 

# F 6 

# must be calculated from the CF 4 

# emissions using a tested ratio of C 2 

# F 6 

# to CF 4 

# production. For CO 2 

# 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 subpar t do not require monitoring which is related to CEMS equipment and would thus not f acilitate the instal lation of GHG CEMS.

Summary of Available Data on Fac ilities 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 CO 2 

# CEMS were reported to the GHGRP.

Subpart F CEMS Count
Table F-2 summarizes the actual data collected for facilities using CO 2 

# CEMS, non-CO 2 

# GHG CEMS, and non-GHG CEMS. No facilities were identified with pre-existing CEMS. No assumption could be made for a potential count ba sed on lack of informa tion 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 CO 2 

## CEMS for
GHGRP Reporting non-CO 2 

## GHG CEMS for
GHGRP Reporting non-GHG CEMS for Other EPA Programs

Actual Potential a



## 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.

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

62 Appendix B. Ammonia Manufacturing – Subpart G

Industry Background

Based on 2011 annual report submissions, there we re 22 facilities that reported to GHGRP under subpart G.

Under subpart G, facilities estimate CO 2 

# process emissions from each ammonia manufacturing unit, and CO 2 

# emissions collected and either used on-si te or transferred off-site following the requirements of subpart PP (CO 2 

# suppliers). For estimating CO 2 

# 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 ap plicable to ammonia manufacturers.

Summary of Available Data on Fac ilities 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 CO 2 

# CEMS, non-CO 2 

# GHG CEMS, and non-GHG CEMS. No facilities we re identified with pre-existing CO 2 

# CEMS. No assumption could be made for a potential count ba sed on lack of information on control devices and monitoring requirements.

Table G-1. Subpart G CEMS Counts

Basis CO 2 

## CEMS for
GHGRP Reporting non-CO 2 

## GHG CEMS for
GHGRP Reporting non-GHG CEMS for Other EPA Programs

Actual Potential a



## 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.

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

63 Appendix B. Cement Production – Subpart H

Industry Background

The Portland Cement Association’s 2004 plant level su mmary 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 submissi ons, 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 CO 2 

## process emissions from calcination in each kiln and CO 2 

## combustion emissions from each kiln. They ar e also required to estimate and report CH 4 

## and N 2 

## O
combustion emissions from each kiln. For CO 2 

## 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 Industry a 

## 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 O 2 

## CEMS to correct to

constant O 2



## . Yes No

Subpart F

— NSPS for Portland

Cement Plants PM CEMS, NO X 

## CEMS, SO 2 

## 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 so urces, except for kiln s that burn hazardous waste and are subject to and regulated under 40 CFR 63, subpart EEE.

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

64 Summary of Available GHGRP and Other Da ta on Facilities Reporting the Use of CEMS



# Table H-2. CEMS Data from Databases

GHGRP Cement NSPS Database

Count of Facilities with CO 2 

## CEMS/Total Count of CO 2 

## CEMS Total Kiln Count/Count of Kilns with CEMS; Total Facility Count/Count of

Facilities with non-CO 2 

## CEMS
82/112 121/50; 64/36



##  The cement NSPS database only provides CEMS counts for SO 2 

## , NO X 

## , 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 GHGR P 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 ar e 100 plants with 140 kilns.

 The data from GHGRP and the cement database ar e 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 co llected for facilities and units using CO 2 

## CEMS, non-CO 2 

## 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 CO 2 

## CEMS for
GHGRP Reporting non-CO 2 

## GHG CEMS for
GHGRP Reporting non-GHG CEMS for Other EPA Programs

Actual Potential f



## Facilities 82 a 

## 0 c 

## 0 c 

## 14 d



## Units 112 b 

## 0 c 

## 0 c 

## 28 e



## NA = No estimate is available.

a 

## Number of facilities reporting to GHGRP in 2011 that they are using a CEMS to report CO 2 

## emissions.

b 

## The total number of CO 2 

## CEMS at the facilit ies which reported CO 2 

## CEMS.

c 

## No units or facilities are known to be using non-CO 2 

## GHG CEMS (e.g., for CH 4 

## or N 2 

## O).

d 

## Based on assuming that all kilns will have a non-GHG CE MS 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-GH G 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.

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

65 Appendix B. Ferroalloy Production – Subpart K

Industry Background

Based on 2011 annual report submissions, there we re 10 facilities that reported to GHGRP under subpart K.

Under subpart K, facilities estimate CO 2 

# process emissions from each electric arc furnace that is used for any type of ferroalloy produ ction. Facilities also estimate CH 4 

# emissions from each electric arc furnace that is used for the producti on of silicon metal or ferrosilicon (65%, 75%, or 90%). For estimating CO 2 

# process emissions, facilities may either use a mass balance approach
or use a CEMS. Emissions of CH 4 

# must be estimated by multiplying the annual production of silicon metal or ferrosilicon and applying an appl icable emission factor provided in the subpart.

Applicable NSPS and NESHAP for Ferroalloy Plants

Table K-1. Applicable NE SHAP 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 Fe rroalloy 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 Fac ilities Reporting the Use of CEMS

No data on CEMS counts applicable to subpart K facilities were available.

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

66 Subpart K CEMS Count

Table K-2 summarizes the actual data collected for facilities using CO 2 

# CEMS, non-CO 2 

# GHG CEMS, and non-GHG CEMS. No facilities were identified with pre-existing CEMS. No assumption could be made for a potential count ba sed on lack of informa tion on control devices.

Table K-2. Subpart K CEMS Counts

Basis CO 2 

## CEMS for
GHGRP Reporting non-CO 2 

## GHG CEMS for
GHGRP Reporting non-GHG CEMS for Other EPA Programs

Actual Potential a



## 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.

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

67 Appendix B. Fluorinated Gas Production – Subpart L

Industry Background

Based on 2011 annual report submissions, there we re 16 facilities that reported to GHGRP under subpart L.

Under subpart L, facilities estim ate emissions of HFCs, PFCs, SF 6 

# , NF 3 

# , and HFEs from each fluorinated gas production process and all fluor inated gas production processes combined, each fluorinated gas transformation pro cess that is not a part of a fl uorinated gas production process, each fluorinated GHG destruction process that is not a part of a fl uorinated 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 emissi ons. However, this is only an alternative and no data were provided to determ ine how many (if any) would comply using this method. Since more economical options are availabl e it is not anticipated any facilities would comply using CEMS. In addition, CPMS requirement s would not be applicab le to installation of CEMS equipment (e.g., CPMS includes monito ring temperature or liquid flow rate).

Summary of Available Data on Fac ilities Reporting the Use of CEMS

From the response to comments document for S ubpart L, there was a specific request for

allowance of CEMS to monitor fl uorinated 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 in stallations was provided with discussion on how all equipment

was able to withstand the corrosi ve environment. The commenter stated that five FTIR CEMS were installed at this facility. Note that disc ussion on CEMS installations was specific to a particular facility; the commenter did not impl y 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

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

68 Table L-2 summarizes the actual data collected for facilities using CO 2 

# CEMS, non-CO 2 

# GHG CEMS, and non-GHG CEMS. Based on the public comm ent, 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 CO 2 

## CEMS for
GHGRP Reporting non-CO 2 

## GHG CEMS for
GHGRP Reporting non-GHG CEMS for Other EPA Programs

Actual Potential a



## 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.

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

69 Appendix B. Glass Production – Subpart N

Industry Background

Based on 2011 annual report submissions, there we re 110 facilities that reported to GHGRP under subpart N.

Under subpart N, facilities estimate CO 2 

# process emissions from each continuous glass melting
furnace and CO 2 

# combustion emissions from each continuous glass melting furnace. They are also required to estimate and report CH 4 

# and N 2 

# O combustion emissions from each continuous glass melting furnace. For CO 2 

# emissions, facilities may either use a mass balance approach for separate process and combustion emissions, or us e a CEMS to determine combined process and
combustion emissions.

Applicable NSPS and NE SHAP 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 subpar t do not require monitoring which is related to CEMS equipment and would thus not f acilitate the instal lation of GHG CEMS.

Summary of Available Data on Fac ilities Reporting the Use of CEMS

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

70 There were three facilities which reported CO 2 

# CEMS in GHGRP and each only reported one

CEMS.

Subpart N CEMS Count

Table N-2 summarizes the actual data collected for facilities using CO 2 

# CEMS, non-CO 2 

# GHG CEMS, and non-GHG CEMS. The only source with data regarding CEMS installations was the

CO 2 

# 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 CO 2 

## CEMS for
GHGRP Reporting non-CO 2 

## GHG CEMS for
GHGRP Reporting non-GHG CEMS for Other EPA Programs

Actual Potential c



## Facilities 3 a 

## NA NA NA

Units 3 b 

## NA NA NA

NA = No information available.

a 

## Number of facilities reporting to GHGRP in 2011 that they are using a CEMS to report CO 2 

## emissions.

b 

## The total number of CO 2 

## CEMS at the facilit ies which reported CO 2 

## CEMS.

c 

## Potential facilities or process units that may have equipment installed that could be modified for use in the GHGRP.

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

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 NE SHAP 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 emissi ons. However, this is only an alternative and no data were provided to determ ine how many (if any) would comply using this method. Since more economical options are availabl e it is not anticipated any facilities would comply using CEMS. In addition, CPMS requirement s would not be applicab le to installation of CEMS equipment (e.g., CPMS includes monitoring temperature for thermal oxidizers which was a control device specifically mentio ned in subpart O rule language).

Summary of Available Data on Fac ilities Reporting the Use of CEMS

No facility counts for use of CEMS were available. Of note, subpa rt L facilities specifically requested the use of CEMS to measure fluorinat ed gases. However, a similar request was not made for subpart O. Since FTIR CEMS were show n 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.

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

72 Subpart O CEMS Count

Table O-2 summarizes the actual data collected for facilities using CO 2 

# CEMS, non-CO 2 

# 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 CO 2 

## CEMS for
GHGRP Reporting non-CO 2 

## GHG CEMS for
GHGRP Reporting non-GHG CEMS for Other EPA Programs

Actual Potential a



## 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.

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

73 Appendix B. Hydrogen Production – Subpart P

Industry Background

Based on 2011 annual report submissions, there we re 103 facilities that reported to GHGRP under subpart P.

Under subpart P, facilities estimate CO 2 

# process and combustion emissions from each hydrogen production unit. CO 2 

# collected and either used on site or transferred off site must also be
estimated. Facilities also estimate CH 4 

# and N 2 

# O combustion emissions from each hydrogen production unit. For CO 2 

# emissions, facilities may either use a mass balance approach for separate process and combustion emissions, or us e 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 no t require monitoring which is related to CEMS equipment and would thus not facili tate the installation of GHG CEMS.

Summary of Available Data on Fac ilities Reporting the Use of CEMS

There were three facilities which reported CO 2 

# CEMS in GHGRP and each reported only one
CEMS.

Subpart P CEMS Count

Table P-2 summarizes the actual data collected for facilities using CO 2 

# CEMS, non-CO 2 

# GHG CEMS, and non-GHG CEMS. The only source with data regarding CEMS installations was the

CO 2 

# 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 CO 2 

## CEMS for
GHGRP Reporting non-CO 2 

## GHG CEMS for
GHGRP Reporting non-GHG CEMS for Other EPA Programs

Actual Potential c



## Facilities 3 a 

## NA NA NA

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

74 Units 3 b 

## NA NA NA

NA = No information available.

a 

## Number of facilities reporting to GHGRP in 2011 that they are using a CEMS to report CO 2 

## emissions.

b 

## The total number of CO 2 

## CEMS at the facilit ies which reported CO 2 

## CEMS.

c 

## Potential facilities or process units that may have equipment installed that could be modified for use in the GHGRP.

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

75 Appendix B. Iron and Steel Production – Subpart Q

Industry Background

The iron and steel production source category under s ubpart 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-lo cated with an integrated iron and steel manufacturing process.

Under subpart Q, process CO 2 

## 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 CO 2 

## emissions using either a carbon mass balance method, a site-specific emission factor, or by a CO 2 

## CEMS that meets the Tier 4 calculation methodology requirements of subpart C. Facilities are not required to determine CH 4 

## , N 2 

## O 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 submis sions, 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 equipmen t, 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.

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

76 Table Q-1. Summary of NSPS and NESHAP Monitori ng Requirements Applicab le 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 FFFFF a 

## (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 FFFFF a 

## (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 fu rnace 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

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

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 st eel making blast furnaces, but these are not included in the processes in 40 CFR part 98, subpart Q. Subpart Q includes blast furnaces among th e units that produce GHG emissions only from fuel combustion and not from raw mate rials. 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 vol ume 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 ra te 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 performan ce 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 f acilitate 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 CO 2 

## CEMS with a total of 14 CEMS. These 11 facilities are owned by two companies; two faciliti es are owned by ArcelorMittal and nine by Nucor.

 One of the ArcellorMittal facilities (Indiana) is an integr ated 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 emissi ons must be determined under subpart Q.

 We do not know which units at the ArcellorMittal facility are using a CEMS.

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

78 Subpart Q CEMS Count

Table Q-2 summarizes the actual data co llected for facilities and units using CO 2 

## CEMS, non-CO 2 

## 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 CO 2 

## CEMS for
GHGRP Reporting non-CO 2 

## GHG CEMS for
GHGRP Reporting non-GHG CEMS for Other EPA Programs

Actual Potential c



## Facilities 11 a 

## NA NA NA

Units 14 b 

## NA NA NA

NA = No information available.

a 

## Number of facilities reporting to GHGRP in 2011 that they are using a CEMS to report CO 2 

## emissions.

b 

## The total number of CO 2 

## CEMS at the facilit ies which reported CO 2 

## CEMS.

c 

## Potential facilities or process units that may have equipment installed that could be modified for use in the GHGRP.

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

79 Appendix B. Lead Production – Subpart R

Industry Background

Based on 2011 annual report submissions, there we re 13 facilities that reported to GHGRP under subpart R.

Under subpart R, facilities estimate CO 2 

# process emissions from each smelting furnace and CO 2 

# combustion emissions from each smelting furnace. Th ey are also required to estimate and report
CH 4 

# and N 2 

# O combustion emissions from each smelting furnace. For CO 2 

# 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 SO 2 

## 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 sme lters do not contain any relevant monitoring requirements. The NSPS for primary lead smelters requires SO 2 

# monitoring, but applies only to primary lead smelters constructed after Oct ober 16, 1974. There have be en 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 SO 2 

# CEMS.

Summary of Available Data on Fac ilities 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 CO 2 

# CEMS, non-CO 2 

# GHG CEMS, and non-GHG CEMS. No facilities we re identified with pre-existing CO 2 

# CEMS. No

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

80 assumption could be made for a potential count ba sed on lack of information on control devices and monitoring requirements.

Table R-2. Subpart R CEMS Counts

Basis CO 2 

## CEMS for
GHGRP Reporting non-CO 2 

## GHG
CEMS for GHGRP Reporting non-GHG CEMS for Other EPA Programs

Actual Potential a



## 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.

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

81 Appendix B. Lime Manufacturing – Subpart S

Industry Background

Based on 2011 annual report submissions, there we re 73 facilities that reported to GHGRP under subpart S.

Under subpart S, facilities estimate CO 2 

# process emissions from each lime kiln and CO 2 

# combustion emissions from each lime kiln. They ar e also required to estimate and report CH 4 

# and N 2 

# O combustion emissions from each lime kiln. For CO 2 

# 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 subpar t do not require monitoring which is related to CEMS equipment and would thus not f acilitate the instal lation of GHG CEMS.

Summary of Available Data on Fac ilities Reporting the Use of CEMS

One facility was reported to use CO2 CEMS in th e 2011 GHGRP. The RIA for part 98 identified

that all facilities would meet the Tier 4 criter ia 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 CO 2 

# CEMS, non-CO 2 

# 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 CO 2 

## CEMS for
GHGRP Reporting non-CO 2 

## GHG CEMS for Reporting non-GHG CEMS for Other EPA Programs

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

82 GHGRP Actual Potential b



## Facilities 1 a 

## 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 CO 2 

## emissions.

b 

## Potential facilities or process units that may have equipment installed that could be modified for use in the GHGRP.

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

83 Appendix B. Miscellaneous Uses of Carbonates Facilities – Subpart U

Industry Background

Based on 2011 annual report submissions, there we re 18 facilities that reported to GHGRP under subpart U.

Under subpart U, facilities estimate CO 2 

# process emissions for all miscellaneous carbonate use at the facility. For estimating CO 2 

# process emissions, facilities mu st use a mass balance approach.

Applicable NSPS and NESHAP for th e Miscellaneous Use of Carbonates

There is no NSPS or NESHAP specifically appli cable to miscellaneous use of carbonates.

Summary of Available Data on Fac ilities 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 CO 2 

# CEMS, non-CO 2 

# GHG CEMS, and non-GHG CEMS. No facilities we re identified with pre-existing CO 2 

# CEMS. No assumption could be made for a potential count ba sed on lack of information on control devices and monitoring requirements.

Table U-1. Subpart BB CEMS Counts

Basis CO 2 

## CEMS for
GHGRP Reporting non-CO 2 

## GHG
CEMS for GHGRP Reporting non-GHG
CEMS for Other EPA Programs
Potential a



## 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.

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

84 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 N 2 

# O process emissions from each nitric acid train. For N 2 

# O emissions, facilities may either use a mass balan ce 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 NO X 

## CEMS required for units
constructed or modified after August 17, 1971 Yes No



# Each emission point for nitric acid production shall install NO X 

# CEMS if constructed or modified after 1971; no alte rnatives are provided.

Summary of Available Data on Fac ilities 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 NO X 

# CEMS installed. Of the 45 nitric acid production plants, 20 nitric acid production plants employ CEMS for NO X 

# emissions. At these 20 nitric acid plants ther e are 36 processes which have NO X 

# CEMS; this is approximately 58 percent of the total processe s. It is presumed that the processes which do not have NO X 

# CEMS installed were built prior to 1971. No facilities reported CO 2 

# CEMS through GHGRP.

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

85 Subpart V CEMS Count

Table V-3 summarizes the actual data collected for facilities using CO 2 

# CEMS, non-CO 2 

# 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 CO 2 

## CEMS for
GHGRP Reporting non-CO 2 

## GHG CEMS for
GHGRP Reporting non-GHG CEMS for Other EPA Programs

Actual Potential b



## Facilities NA NA 20 a 

## NA

Units NA NA 36 a 

## 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 no t generated since the inventory data were reported by the facility and presumed to be the actual count of units with NO X 

## CEMS.

b 

## Potential facilities or process units that may have equipment installed that could be modified for use in the GHGRP.

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

86 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 CO 2 

## process emissions and CO 2 

## , CH 4 

## , and N 2 

## O emissions generated by combustion of process off-gas in stationa ry combustion units and flares. GHG estimates are also necessary for CO 2 

## , CH 4 

## , and N 2 

## O emissions from burning supplemental fuel in stationary combustion units that also burn process off-gas. If Tier 4 criteria are met then CO 2 

## emissions must be estimated by CEMS, otherwise the mass balance method is required. For CH 4 

## and N 2 

## O the emission factor method is used. For ethylene processes only CO 2 

## emissions may be estimated using Tier 3 or Tier 4 for combustion of process off-gas.

Based on 2011 annual report submis sions, there were 64 facilities that reported to GHGRP under subpart

X.

Applicable NSPS and NESHAP for Petr ochemical Plants and Facility Counts

Table X-1 shows the applicable NESHAP and N SPS for each facility type. Table X-2 shows the monitoring required by each of the NESHAP and N SPS 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

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

87 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 Manu facturing Industry Subpart G—NESHAP From the Synthetic Organic Chemical Manuf acturing 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 Manu facturing 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, photoioniz ation, 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 complia nce due to cost, and would likely use other options instead (e.g., temperature monitoring). Due to the am ount of unknown variables, for this analysis it was assumed that no equipment is installed which w ould facilitate the installation of GHG CEMS.

Summary of Available GHGRP Data on Facilities Reporting the Use of CEMS

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

88 There were two facilities which reported CO 2 

## 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 co llected for facilities and units using CO 2 

## CEMS, non-CO 2 

## GHG CEMS, and non-GHG CEMS. The only source with da ta regarding CEMS installations was the CO 2 

## 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 CO 2 

## CEMS for
GHGRP Reporting non-CO 2 

## GHG CEMS for
GHGRP Reporting non-GHG CEMS for Other EPA Programs

Actual Potential c



## Facilities 2 a 

## NA NA NA

Units 2 b 

## NA NA NA

NA = No information available.

a 

## Number of facilities reporting to GHGRP in 2011 that they are using a CEMS to report CO 2 

## emissions.

b 

## The total number of CO 2 

## CEMS at the facilit ies which reported CO 2 

## 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.

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

89 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 cont ains 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 Re fineries, Refinery Database Counts, and GHG Reporting Requirements

Table Y-1 provides a general overview of the N ESHAP 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 NES HAP 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 availabl e that correlated with the NESHAP/NSPS rules.

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

90 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, O 2 

## monitor Subpart J—NSPS for Petroleum Refi neries Flow rate, CO CEMS, O 2 

## monitor, SO 2 

## monitor



## Table Y-2. GHGs Reported for Ea ch Refinery Process, Process Unit Counts, and Monitoring Information from Applic able 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
CO 2 

### CH 4 

### N 2 

### O

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 O 2 

### , temperature, or operation of flare pilot. Flow monitoring required if modified
before 1973 and control
device is an ESP.

Fluid Coking Y Y Y

132 a 

### N NA

Coke Calcining Y Y Y N NA

Delayed Coking N Y N N NA
Catalytic Reformi ng Y Y Y 120 N NA
Sulfur Recovery Y N N 187 Y SO 2 

### and O 2 

### 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 vent s’. This count was applied to all processes which refer to co ke operations.

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

91

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

92 The refinery database provided a total facility count of 148 refineries, and contains 317 catalytic cracking and sulfur recovery units. For catalytic cracking pr ocesses, CO CEMS are only applicable to catalytic cracking unit catalyst regenerators. Each catalytic cr acking 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 SO 2 

## /O 2 

## monitor associated with it. For CEMS installation cost estimates, a unit count of 1,580 w as 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 CO 2 

## CEMS within GHGRP, with a total of 24 CO 2 

## 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 determin ation we will not include the boiler data in the subpart Y CEMS counts.

Subpart Y CEMS Count

Table Y-3 summarizes the actual data co llected for facilities and units using CO 2 

## CEMS, non-CO 2 

## 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 CO 2 

## CEMS for
GHGRP Reporting nonCO 2 

## GHG CEMS
for GHGRP Reporting non-GHG CEMS for Other EPA Programs

Actual Potential f



## Catalytic Cracking and
Sulfur Recovery Facilities 21 a 

## NA NA 104 c



## Units 26 b 

## NA NA 317 d



## 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 CO 2 

## emissions.

b 

## The total number of CO 2 

## CEMS at the facilit ies which reported CO 2 

## 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.

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

93 Appendix B. Phosphoric Acid Production – Subpart Z

Industry Background

Based on 2011 annual report submissions, there we re 13 facilities that reported to GHGRP under subpart Z.

Under subpart Z, facilities estimate CO 2 

# process emissions from each wet-process phosphoric acid process line. For CO 2 

# emissions, facilities may either us e 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 In dustry: Wet-Process Phosphoric Acid Plants (No relevant monitoring requirements) No No



# The applicable NESHAP and NSPS for this subpar t do not require monitoring which is related to CEMS equipment and would thus not f acilitate the instal lation of GHG CEMS.

Summary of Available Data on Fac ilities 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 CO 2 

# CEMS. Phosphoric acid process emissions are

combined with combustion emissions for calciners and dryers at 7 facilities. The ICR indicates

that the 7 measure O 2 

# instead of CO 2



# .

Subpart Z CEMS Count

Table Z-2 summarizes the actual data collected for facilities using CO 2 

# CEMS, non-CO 2 

# 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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94 Table Z-2. Subpart Z CEMS Counts

Basis CO 2 

## CEMS for
GHGRP Reporting non-CO 2 

## GHG CEMS for
GHGRP Reporting non-GHG CEMS for Other EPA Programs

Actual Potential b



## Facilities NA NA 7 a 

## 7 a



## 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.

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

95 Appendix B. Pulp and Paper Manufacturing – Subpart AA

Industry Background

The pulp and paper manufacturing source category und er 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 (CaCO 3 

## , Na 2 

## CO 3 

## ) in the chemical recovery areas of chemical pulp mills.

Approximately 425 pulp and paper m ills 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) (NCA SI 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 subpa rt AA. Based on 2011 annual report submissions, there were 110 facilities that reported to GHGRP under subpart AA.

Applicable GHGRP, NSPS, and NESHAP Monitori ng 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 a nd paper facilities under subpart AA of part 98, and under the relevant NSPS and NESHAP.

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

96 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 BB b 

## Monitoring Required by 40 CFR 63, subpart S Monitoring Required by 40 CFR 63, subpart MM

Kraft or Soda

Mill Each chemical

recovery furnace CO 2 

## , biogenic

CO 2 

## , CH 4 

## , N 2 

## O 168 Total reduced sulfur (TRS) CEMS, O 2 

## CEMS, percent volume dry basis

[60.284(a)(2)] No relevant monitoring No relevant monitoring

Kraft or Soda

Mill Lime Kilns,

fossil fuel

combustion CO 2 

## , biogenic

CO 2 

## , CH 4 

## , N 2 

## O 164 TRS CEMS, O 2 

## CEMS, percent volume dry basis

[60.284(a)(2)] No relevant monitoring No relevant monitoring

Sulfite Pulp

Mills Each chemical

recovery furnace CO 2 

## , biogenic

CO 2 

## , CH 4 

## , N 2 

## O 13 No relevant monitoring No relevant monitoring No relevant monitoring

Stand Alone

Semichemical

Mills Each chemical

recovery furnace CO 2 

## , biogenic

CO 2 

## , CH 4 

## , N 2 

## O 12 No relevant monitoring No relevant monitoring No relevant monitoring

Chemical pulp mills Makeup

chemical

addition to

chemical

recovery area CO 2



## ≤ 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 SO 2 

## , NO X 

## , 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 perfo rming that monitoring was not available. The NSPS (subpart BB) requires oxygen monitoring only fo r chemical recovery furnaces and pulp mill lime kilns at kraft pulp mills. The two Pulp and Pape r 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 reco very 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), O 2 

## , 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, O 2 

## , and moisture CEMS would mean that these units would also have the basic CEMS infrastructure in pl ace, such as platforms, sampling lines, and data

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

97 acquisition systems, and this would lower the cost of adding GHG CEMS equipment, such as a CO 2 

## 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 incine rators (CISWI) and the boiler and process heater

NESHAP. Table AA-2 summarizes these data for the to tal number of units and those with a CEMS.

Table AA-2. Summary of CEMS Da ta from Other EPA Databases

GHGRP CISWI Database Boiler and Process Heater
NESHAP Database Count of Facilities Which Reported
CO 2 

## 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 CO 2 

## emissions were reported through GHGRP.

In the CISWI and the boiler and pro cess heater survey data, we can iden tify 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 pr ocess 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 th ose 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 CO 2 

## CEMS, non-CO 2 

## 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 CO 2 

## CEMS for
GHGRP Reporting non-CO 2 

## GHG CEMS for
GHGRP Reporting non-GHG CEMS for Other EPA Programs

Actual Potential b

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98 Facilities NA NA NA NA

Units NA NA 266 a 

## 266 a



## NA = No information available

a 

### The NCASI survey provided process unit data and the 2009 RIA es timated that units were subject to Ti er 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 O 2 

## CEMS and, therefore, already have some basic infrast ructure for a CEMS that could be used to estimate
GHG emissions with the addition of a flow meter and CO 2 

## analyzer. Similarly, the RIA estimates that a large portion of the sources will meet Tier 4 requi rements. However, because the number of facilities reporting to GHGRP (110) is substantially lower th an 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.

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

99 Appendix B. Silicon Carbide Production – Subpart BB

Industry Background

Based on 2011 annual report submissions, there we re 1 facility that reported to GHGRP under subpart BB.

Under subpart BB, facilities estimate CO 2 

# and CH 4 

# process emissions from all silicon carbide process units or furnaces combined. For estimating CO 2 

# process emissions, facilities may either use a mass balance approach or us e a CEMS. Process emissions of CH 4 

# are estimated using emission factors relevant to the monthly amount of petroleum coke cons umed at the facility.

Applicable NSPS and NESHAP fo r Silicon Carbide Manufacturers

There is no NSPS or NESHAP specifically appl icable to silicon carbi de manufacturers.

Summary of Available Data on Fac ilities Reporting the Use of CEMS

No data on CEMS counts applicable to subpart BB facilities we re available.

Subpart BB CEMS Count

Table BB-1 summarizes the actual data collected for facilities using CO 2 

# CEMS, non-CO 2 

# GHG CEMS, and non-GHG CEMS. No facilities we re identified with pre-existing CO 2 

# CEMS. No assumption could be made for a potential count ba sed on lack of information on control devices and monitoring requirements.

Table BB-1. Subpart BB CEMS Counts

Basis CO 2 

## CEMS for
GHGRP Reporting non-CO 2 

## GHG CEMS for
GHGRP Reporting non-GHG CEMS for Other EPA Programs

Actual Potential a



## 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.

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

100 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 CO 2 

# process emissions from each soda ash manufacturing
line and CO 2 

# combustion emissions from each soda ash manufacturing line. They are also required to estimate and report CH 4 

# and N 2 

# O combustion emissions from each soda ash manufacturing line. For CO 2 

# emissions, facilities may use a mass balance or emission factor approach to estimate separate process and comb ustion 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 subpar t do not require monitoring which is related to CEMS equipment and would thus not f acilitate the instal lation of GHG CEMS.

Summary of Available Data on Fac ilities Reporting the Use of CEMS

One facility reported the use of one CO 2 

# CEMS to report emissions.

Subpart CC CEMS Count

Table CC-2 summarizes the actual data collected for facilities using CO 2 

# CEMS, non-CO 2 

# GHG CEMS, and non-GHG CEMS. No facilities we re identified with pre-existing CO 2 

# CEMS. No assumption could be made for a potential count ba sed on lack of information on control devices and monitoring requirements.

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101 Table CC-2. Subpart CC CEMS Counts

Basis CO 2 

## CEMS for
GHGRP Reporting non-CO 2 

## GHG CEMS for
GHGRP Reporting non-GHG CEMS for Other EPA Programs

Actual Potential c



## Facilities 1 a 

## NA NA NA

Units 1 b 

## NA NA NA

NA = No information available.

a 

## Number of facilities reporting to GHGRP in 2011 that they are using a CEMS to report CO 2 

## emissions.

b 

## The total number of CO 2 

## CEMS at the facilit ies which reported CO 2 

## CEMS.

c 

## Potential facilities or process units that may have equipment installed that could be modified for use in the GHGRP.

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

102 Appendix B. Titanium Dioxi de 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 CO 2 

# process emissions from each chloride process line. For estimating CO 2 

# 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 subpar t do not require monitoring which is related to CEMS equipment and would thus not f acilitate the instal lation of GHG CEMS.

Summary of Available Data on Fac ilities 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 CO 2 

# CEMS, non-CO 2 

# GHG CEMS, and non-GHG CEMS. No facilities we re identified with pre-existing CO 2 

# CEMS. No assumption could be made for a potential count ba sed on lack of information on control devices and monitoring requirements.

Table EE-2. Subpart EE CEMS Counts

Basis CO 2 

## CEMS for
GHGRP Reporting non-CO 2 

## GHG CEMS for
GHGRP Reporting non-GHG CEMS for Other EPA Programs

Actual Potential a



## 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.

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

103 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 CO 2 

# process emissions from each Waelz kiln and electrothermic furnace, and CO 2 

# combustion emissions from each Waelz kiln and electrothermic furnace. They are also required to estimate and report CH 4 

# and N 2 

# O combustion emissions from
each Waelz kiln and electrothermic furnace. For CO 2 

# emissions, facilities may use a mass balance or emission factor approa ch to estimate separate proc ess and combustion emissions, or use a CEMS to determine combined process and combustion emissions.

Applicable NSPS and NE SHAP 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 SO 2 

## 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



# SO 2 

# CEMS is only applicable for roasters at prim ary zinc smelters which are not applicable to GHG reporting and are thus not rela ted to GHG CEMS installation.

Summary of Available Data on Fac ilities Reporting the Use of CEMS

No data on CEMS counts applicable to subpart GG facilities were available.

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

104 Subpart GG CEMS Count

Table GG-2 summarizes the actual data collected for facilities using CO 2 

# CEMS, non-CO 2 

# GHG CEMS, and non-GHG CEMS. No facilities we re identified with pre-existing CO 2 

# CEMS. No assumption could be made for a potential count ba sed on lack of information on control devices and monitoring requirements.

Table GG-2. Subpart CC CEMS Counts

Basis CO 2 

## CEMS for
GHGRP Reporting non-CO 2 

## GHG CEMS for
GHGRP Reporting non-GHG CEMS for Other EPA Programs

Actual Potential a



## 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.

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

105 Appendix B. Industrial Waste Landfills – Subpart TT

Industry Background

Based on 2011 annual report submissions, there we re 173 facilities that reported to GHGRP under subpart TT.

Under subpart TT, facilities must estimate annual CH 4 

# generation, emission, and destruction from the landfill. For estimating CH 4 

# generation, facilities may meas ure the generation directly
or estimate a value based on histor ic annual waste disposal quantitie s. Facilities that collect and control landfill gas must calculate CH 4 

# 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 CH 4 

# recovered.

Applicable NSPS and NESHAP for Industrial Waste Landfills

There are no NSPS or NESHAP which are applicab le to industrial waste landfills. The definition
of industrial waste landfills fo r purposes of the GHGRP specifically excludes municipal waste landfills, so part 60 subpart WWW (NSPS fo r MSW Landfills) is not applicable.

Summary of Available Data on Fac ilities Reporting the Use of CEMS

No data on CEMS counts applicable to subpart TT f acilities were available. It is noted in subpart TT that industrial waste landfills may collect meth ane with a gas collection system. If they do the rule requires them to report the annual CH 4 

# recovered. The method of recording the amount of methane recovered using the gas collection sy stem is unknown, so the applicability of CH 4 

# CEMS is also unknown. For these purposes it will be assumed that no facility uses CEMS to

monitor CH 4 

# recovery. Also, for those industrial waste landfills which have gas collection systems, the facility is required to monitor the flow rate and temper ature; the applicability of this equipment to installing CEMS (e.g., is the flow monitor located at a position which would also meet flow monitor requireme nts for CEMS) is also unknown.

Subpart TT CEMS Count

Table TT-1 summarizes the actual data collected for facilities using CO 2 

# CEMS, non-CO 2 

# GHG CEMS, and non-GHG CEMS. No facilities we re identified with pre-existing CH 4 

# CEMS. No assumption could be made for a potential count based on lack of information.

Table TT-1. RSubpart TT CEMS Counts

Basis CO 2 

## CEMS for
GHGRP Reporting non-CO 2 

## GHG CEMS for
GHGRP Reporting non-GHG CEMS for Other EPA Programs

Actual Potential a



## Facilities NA NA NA NA

Units NA NA NA NA

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106 NA = No information available.

a 

## Potential facilities or process units that may have equipment installed that could be modified for use in the GHGRP.

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

107 Appendix C Detailed CEMS Costing for Subparts with “Inputs to Equations”

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

108 Appendix C

Detailed GHG CEMS Cost Analysis

====================================================== ==============

C.1 GHG CEMS Cost Assumptions

To determine the economic impact of installi ng GHG CEMS for each subpart, a determination of the applicable population of sources for each subp art 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 in cluded installations of GHG CEMS (CO 2 

# , CH 4 

# , or N 2 

# O) and non-GHG CEMS (NO X 

# , 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 a nd only facility counts were known. In those instances, on ly the facility count was used to determine the CEMS cost; while this may underestimate costs for certain subpart s, due to a lack of data, it was not possible to provide a reliable count for number of pr ocess units. To determine counts the following sources were used: GHGRP data, part 98 GHG t echnical support documents for each subpart, a review of applicable NESHAP and NSPS rule requirements a nd associated databases and supporting documentation for each subpart, and th e part 98 GHG Regulatory Impact Analysis (RIA). See Appendix B for a revi ew of the information obtained.

To keep this CEMS cost analysis consis tent 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 CO 2 

# CEMS

 Source has non-CO 2 

# GHG CEMS (such as N 2 

# O CEMS) or has non-GHG CEMS (such as
NO X 

# or CO monitors)

 Source has no CEMS

Five different cost scenarios we re identified from the usage information and are summarized in Table C-1. Cost scenario 1 is a complete GHG CE MS installation for sour ces which do not have any CEMS related equipment installed. Cost scen arios 2 through 4 are reduced costs for sources
which have current CEMS installations and w ould need to install minimal equipment (e.g., a
CO 2 

# analyzer and/or flow meter). The decision to apply scenarios 2, 3, or 4 costs to a particular subpart is based off applicab le NSPS/NESHAP regulation knowl edge and information provided
in the GHG RIA. It was determined that no f acilities/process units me t 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 CO 2 

# CEMs
and no costs are calculated.

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

109 Table C-1. Summary of Costs for CO 2 

# CEMS Modifications

Scenario
# Scenario Total annual

costs

1 Source has no CEMS -- Add CO 2 

## analyzer, flow meter, and
infrastructure $ 70,265

2 Source has CEMS for other pollutants -- Add CO 2 

## analyzer
and flow meter $ 56,040

3 Source has CEMS for other pollutants -- Add CO 2 

## analyzer only $ 20,593



# 4 a 

## Source has CEMS for other pollutants -- Add flow monitor only $ 24,511

5 Source has CO 2 

## CEMS No Cost

a 

## No facilities/process units were determined to meet the scenario.



# Within each scenario, multiple cost scenarios we re calculated because each subpart may require one analyzer or a combination of analyzers to measure GHGs. The most common GHG to report
is CO 2 

# , however CH 4 

# and N 2 

# O are also applicable depending on the subpart. While the GHG RIA provided a cost estimate for a CO 2 

# CEMS, CH 4 

# and N 2 

# O CEMS costs were not available. For this analysis, vendors were contacted and co st 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. Subpa rt O requires reporting of fluorinated gases; the applicability of CEMS for fluorinated gase s was not analyzed, and therefore no costs were calculated for subpart O. Table C-2 su mmarizes the vendor cost information.

Costs for each subpart were determined based on the count information identified (see Appendix B for subpart-specific details) a nd the scenario cost options. Cost s 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 fo r installing the appropriate GHG CEMS.

 If current non-CO 2 

# CEMS installations were identified for a subpart then either scenario 2 or 3 costs were applied for these counts de pending on the type of CEMS identified. For facility/process units without current non-CO2 CEMs, the scenar io 1 costs were applied. These two costs were added together to get the total cost for the facility.

 For subparts which have a CO 2 

# CEMS installed but would also report CH 4 

# and/or N 2 

# O, only the cost associated with installing a CH 4 

# and/or N 2 

# O analyzer was incorporated, and
no costs for CO 2 

# analyzers were included.

Costs are shown for each subpart based on two c ount options: actual and potential CEMS counts.
The actual count and associated CEMS costs co rrespond to the actual CEMS installation counts
which were able to be identified from the vari ous sources discussed previously. The potential

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

110 count and associated CEMS costs correspond to the potential CEMS installation counts which were estimated based on requirements in NSPS a nd NESHAP rules. The potential counts include the actual counts plus the addi tional units/facilities that may be affected by NSPS or NESHAP requirements. The costs associated with the act ual 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 installatio n) costs. For the costs associated with the potential count, the resulting cost s were lower than the actual count scenario because more
CEMS installations were estimated which resulte d in fewer units in scenario 1 and more in scenarios 2 or 3. For many subparts, the actu al 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)

CO 2 

## analyzer $5,000 (a) $15,000

‐ $20,000 $12,000 $7,917 $12,472 $13,000

N 2 

## O analyzer $5,000 (a) $15,000

‐ $20,000 $15,000 $10,096 $14,199 $14,000

CH 4 

## 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 brea kdown into counts for each scenario, costs for installing GHG CEMS were estima ted. 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 capita l and annual costs for installation of CO 2 

# CEMS only (similar to the GHG RIA). Tables C-5 th rough C-7 summarize the count information for actual and potential units/faciliti es with CEMS control, and the assumptions used in the count determination. Tables C-8 through C-11 provide data on all three t ypes of GHG CEMS (CO 2 

# , N 2 

# O, and CH 4 

# ). 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, di stributing the total un it installation cost
between two or three CEMS is not appropriate; there are redundant component costs associated

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

111 with CO 2 

# , CH 4 

# , and N 2 

# O CEMS. If a facility were to in stall CEMS for all three GHGs, for example, the total cost incurred by the f acility would not equal the sum of the CO 2 

# , CH 4 

# , and
N 2 

# O individual monitor costs. Instead, cost estim ates were developed based on vendor quotes for each possible combination of CO 2 

# , CH 4 

# , and N 2 

# O CEMS for each cost scenario. For this reason,
the CO 2 

# , N 2 

# O, and CH 4 

# costs in Tables C-8 through C-11 do not equal the total cost column; the
CO 2 

# , N 2 

# O, and CH 4 

# costs shown are the cost for instal ling individual GHG CEMS while the total cost is the more representative co st for installing multiple GHG CEMS.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review112Table C-3. Capital Cost Breakdown into Each Costing Scenario for Installation of CO2CEMS Only, Based on Actual Counts and Potential CountsSubpartCapitalInvestmentScenario1Scenario2Scenario3TotalActualaPotentialbActualaPotentialbActualaPotentialbActualaPotentialbC$1,578,065,753$1,578,065,753$102,182,259$111,374,792$0$0$1,680,248,013$1,689,440,545E$‐$‐$‐$‐$‐$‐$‐$‐F$1,229,981$1,229,981$‐$‐$‐$‐$1,229,981$1,229,981G$2,705,958$2,705,958$‐$‐$‐$‐$2,705,958$2,705,958H$3,443,947$‐$‐$‐$560,101$560,101$4,004,048$560,101K$1,229,981$1,229,981$‐$‐$‐$‐$1,229,981$1,229,981L$‐$‐$‐$‐$‐$‐$‐$‐N$13,160,798$13,160,798$‐$‐$‐$‐$13,160,798$13,160,798O$‐$‐$‐$‐$‐$‐$‐$‐P$12,299,811$12,299,811$‐$‐$‐$‐$12,299,811$12,299,811Q$18,572,715$18,572,715$‐$‐$‐$‐$18,572,715$18,572,715R$1,598,975$1,598,975$‐$‐$‐$‐$1,598,975$1,598,975S$8,855,864$‐$‐$‐$‐$‐$8,855,864$‐U$2,213,966$2,213,966$0$0$0$0$2,213,966$2,213,966V$‐$‐$‐$‐$‐$‐$‐$‐X$7,625,883$7,871,879$‐$‐$‐$‐$7,625,883$7,871,879Y$191,139,063$155,346,613$‐$18,094,775$‐$2,080,376$191,139,063$175,521,765Z$737,989$737,989$‐$‐$140,025$140,025$878,014$878,014AA$7,881,432$7,881,432$25,731,576$25,731,576$‐$‐$33,613,009$33,613,009BB$122,998$122,998$‐$‐$‐$‐$122,998$122,998CC$368,994$368,994$‐$‐$‐$‐$368,994$368,994EE$860,987$860,987$‐$‐$‐$‐$860,987$860,987GG$737,989$737,989$‐$‐$‐$‐$737,989$737,989TT$‐$‐$‐$‐$‐$‐$‐$‐TOTAL$1,852,853,085$1,800,578,888$127,913,836$158,684,630$700,127$2,780,503$1,981,467,047$1,962,044,020aCosts are based on the actual number of units/facilities for whichinformation was available indicating current use of CEMS. See Appendix B for detailed information for eachsubpart.bCosts are based on potential number of units/facilities that may beusing CEMS based on NESHAP and NSPS rule requirements. Costs include actual number of units/facilitieswhere information is known as well as the additional potential number of units/facilities that may be using CEMS based on NESHAP and NSPS rulerequirements. SeeAppendix B for detailed information for each subpart.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review113Table C-4. Annual Cost Breakdown into EachCosting Scenario for Installation of CO2CEMS Only, Based on Actual Counts and Potential CountsSubpartAnnualCostScenario1Scenario2Scenario3TotalActualaPotentialbActualaPotentialbActualaPotentialbActualaPotentialbC$901,499,950$901,499,950$59,178,240$64,502,040$‐$‐$960,678,190$966,001,990E$‐$‐$‐$‐$‐$‐$‐$‐F$702,650$702,650$‐$‐$‐$‐$702,650$702,650G$1,545,830$1,545,830$‐$‐$‐$‐$1,545,830$1,545,830H$1,967,420$‐$‐$‐$576,604$576,604$2,544,024$576,604K$702,650$702,650$‐$‐$‐$‐$702,650$702,650L$‐$‐$‐$‐$‐$‐$‐$‐N$7,518,355$7,518,355$‐$‐$‐$‐$7,518,355$7,518,355O$‐$‐$‐$‐$‐$‐$‐$‐P$7,026,500$7,026,500$‐$‐$‐$‐$7,026,500$7,026,500Q$10,610,015$10,610,015$‐$‐$‐$‐$10,610,015$10,610,015R$913,445$913,445$‐$‐$‐$‐$913,445$913,445S$5,059,080$‐$‐$‐$‐$‐$5,059,080$‐U$1,264,770$1,264,770$0$0$0$0$1,264,770$1,264,770V$‐$‐$‐$‐$‐$‐$‐$‐X$4,356,430$4,496,960$‐$‐$‐$‐$4,356,430$4,496,960Y$109,191,810$88,744,695$‐$10,479,480$‐$2,141,672$109,191,810$101,365,847Z$421,590$421,590$‐$‐$144,151$144,151$565,741$565,741AA$4,502,417$4,502,417$14,902,287$14,902,287$‐$‐$19,404,705$19,404,705BB$70,265$70,265$‐$‐$‐$‐$70,265$70,265CC$210,795$210,795$‐$‐$‐$‐$210,795$210,795EE$491,855$491,855$‐$‐$‐$‐$491,855$491,855GG$421,590$421,590$‐$‐$‐$‐$421,590$421,590TT$‐$‐$‐$‐$‐$‐$‐$‐TOTAL$1,058,477,417$1,031,144,332$74,080,527$89,883,807$720,755$2,862,427$1,133,278,700$1,123,378,467aCosts are based on the actual number of units/facilities for whichinformation was available indicating current use of CEMS. See Appendix B for detailed information for eachsubpart.bCosts are based on potential number of units/facilities that may beusing CEMS based on NESHAP and NSPS rule requirements. Costs include actual number of units/facilitieswhere information is known as well as the additional potential number of units/facilities that may be using CEMS based on NESHAP and NSPS rulerequirements. SeeAppendix B for detailed information for each subpart.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review114Table C-5. Total Facility and Units Counts and Current CEMS Installation CountsaSubpartNumberofAffected...DoesSubpartRequireReportingEmissionsof:NumberwithCO2CEMSNumberwithnon‐CO2GHGCEMSNumberwithnon‐GHGCEMSFacilitiesUnitsCO2?N2O?CH4?FacilitiesUnitsFacilitiesUnitsFacilitiesUnitsC1,98514,197YESYESYES177311unknownunknownunknown1,056to1,151E33NOYESNOunknown unknownunknown unknown unknown unknownF1010YESNO NOunknown unknownunknown unknown unknown unknownG2222YESNO NOunknown unknownunknown unknown unknown unknownH96140YESYES YES8211200 0to140to28K1010YESNOYES unknown unknownunknown unknown unknown unknownL1616NONO NOunknown unknown15unknown unknownN110110YESYES YES33unknown unknown unknown unknownO55NONO NOunknown unknownunknown unknown unknown unknownP103103YESYES YES33unknown unknown unknown unknownQ128165YESYES YES1114unknown unknown unknown unknownR1313YESYES YES unknown unknownunknown unknown unknown unknownS7373YESYES YES1to731to73unknown unknown unknown unknownU1818YESNO NOunknown unknownunknown unknown unknown unknownV3665NOYESNOunknown unknown002036X6464YESYES YES22unknown unknown unknown unknownY1451,580YESYES YES2126unknown unknown≤104≤317Z1313YESNO NOunknown unknownunknown unknown7≥7AA110330YESYES YES unknown0to36unknown unknown89266BB11YESNOYES unknown unknownunknown unknown unknown unknownCC44YESYES YES11unknown unknown unknown unknownEE77YESNO NOunknown unknownunknown unknown unknown unknownGG66YESYES YES unknown unknownunknown unknown unknown unknownTT173173NONOYES unknown unknownunknown unknown unknown unknownaSee Appendix B for detailed summary for each subpart.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review115Table C-6. Counts Used to Determine Costs for Each Scenario, Actual CEMS countsaSubpartNumberinScenario1NumberinScenario2NumberinScenario3FacilitiesUnitsFacilitiesUnitsFacilitiesUnitsCO2N2OCH4TotalCO2N2OCH4TotalCO2N2OCH4TotalCO2N2OCH4TotalCO2N2OCH4TotalCO2N2OCH4Total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aSee Appendix B for detailed summary for each subpart.NA = Data not available on basis.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review116Table C-6 (cont.) Notes Explaining the Actual CEMS Count Distribution for Each SubpartSubpartNOTES–ActualCEMSCountsCBoilerandCISWIdatabasesreviewedtogetcountofunitswithCEMS(1,056).NoneoftherelevantregulationsrequireCO2orflowmonitors,buttheydorequireCEMSsystemsforotherpollutants.Assumedthatall1,056Tier4unitswouldbeinscenario2andunitswithknownCO2CEMSwouldbeinscenario3.ECurrentCEMSinstallationunknown;assumedallfacilities/unitsinscenario1.FCurrentCEMSinstallationunknown;assumedallfacilities/unitsinscenario1.GCurrentCEMSinstallationunknown;assumedallfacilities/unitsinscenario1.HAssumedunitswithcurrentCEMSinstallationswouldbeinscenario3.KCurrentCEMSinstallationunknown;assumedallfacilities/unitsinscenario1.LCO2,N2O,andCH4notrequiredtobereportedforthissubpart,thusnoassociatedcostsorunitcounts.NScenario3costsappliedtofacilitieswithCO2CEMS,othersassumedtobeinscenario1.AssumptionmadethatthefacilitieswithCO2CEMShaveonlyoneunit.OCO2,N2O,norCH4requiredtobereportedforthissubpart,thusnoassociatedcostsorunitcounts.PScenario3costsappliedtofacilitieswithCO2CEMS,othersassumedtobeinscenario1.AssumptionmadethatthefacilitieswithCO2CEMShaveonlyoneunit.QScenario3costsappliedtofacilitieswithCO2CEMS,othersassumedtobeinscenario1.AssumptionmadethatthefacilitieswithCO2CEMShaveonlyoneunit.RCurrentCEMSinstallationunknown;assumedallfacilities/unitsinscenario1.STheRIAforpart98identifiedallfacilitiesbeingapplicabletoTier4requirementsandwouldthusinstallaCO2CEMS.Note,however,thatthiscountmaynotbeexclusivetosubpartSemissionssourcesand,forexample,someoftheidentifiedunitsmayfallundersubpartC.Fortheactualscount,itwasassumedallunitswouldbeinscenario1(exceptthe1facilitywithaknownCO2CEMS).UCurrentCEMSinstallationunknown;assumedallfacilities/unitsinscenario1.VScenario3costsappliedtofacilitieswithCEMS,othersassumedtobeinscenario1.XScenario3costsappliedtofacilitieswithCO2CEMS,othersassumedtobeinscenario1.AssumptionmadethatthefacilitieswithCO2CEMShaveonlyoneunit.YScenario3costsappliedtofacilitieswithCO2CEMS,othersassumedtobeinscenario1.ForactualCEMScount,assumedzerofacilitieshavenon‐GHGCEMSinstalled.ZScenario3costsappliedtofacilitieswithCEMS,othersassumedtobeinscenario1.AAScenario2costsappliedforfacilitieswithCEMS;basedoffGHGRIAestimatethatmostfacilitieswouldmeetthisforTierIVrequirements.BBCurrentCEMSinstallationunknown;assumedallfacilities/unitsinscenario1.CCScenario3costsappliedtofacilitieswithCO2CEMS,othersassumedtobeinscenario1.AssumptionmadethatthefacilitieswithCO2CEMShaveonlyoneunit.EECurrentCEMSinstallationunknown;assumedallfacilities/unitsinscenario1.GGCurrentCEMSinstallationunknown;assumedallfacilities/unitsinscenario1.TTCurrentCEMSinstallationunknown;assumedallfacilities/unitsinscenario1.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review117Table C-7. Counts Used to Determine Costs for Each Scenario, Potential CEMS CountsaSubpartNumberinScenario1NumberinScenario2NumberinScenario3FacilitiesUnitsFacilitiesUnitsFacilitiesUnitsCO2N2OCH4TotalCO2N2OCH4TotalCO2N2OCH4TotalCO2N2OCH4TotalCO2N2OCH4TotalCO2N2OCH4Total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aSee Appendix B for detailed summary for each subpart.NA = Data not available on basis.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review118Table C-7 (cont.) Notes Explaining the Potential CEMS CountDistribution for Each SubpartSubpartNOTES–PotentialCEMScountsCBoilerandCISWIdatabasesreviewedtogetcountofunitswithCEMS(1,151).NoneoftherelevantregulationsrequireCO2orflowmonitors,buttheydorequireCEMSsystemsforotherpollutants.Assumedthatall1,151Tier4unitswouldbeinscenario2andunitswithknownCO2CEMSwouldbeinscenario3.ECurrentCEMSinstallationunknown;assumedallfacilities/unitsinscenario1.FCurrentCEMSinstallationunknown;assumedallfacilities/unitsinscenario1.GCurrentCEMSinstallationunknown;assumedallfacilities/unitsinscenario1.HAssumedunitswithcurrentCEMSinstallationswouldbeinscenario3.KCurrentCEMSinstallationunknown;assumedallfacilities/unitsinscenario1.LCO2,N2O,andCH4notrequiredtobereportedforthissubpart,thusnoassociatedcostsorunitcounts.NScenario3costsappliedtofacilitieswithCO2CEMS,othersassumedtobeinscenario1.AssumptionmadethatthefacilitieswithCO2CEMShaveonlyoneunit.OCO2,N2O,norCH4requiredtobereportedforthissubpart,thusnoassociatedcostsorunitcounts.PScenario3costsappliedtofacilitieswithCO2CEMS,othersassumedtobeinscenario1.AssumptionmadethatthefacilitieswithCO2CEMShaveonlyoneunit.QScenario3costsappliedtofacilitieswithCO2CEMS,othersassumedtobeinscenario1.AssumptionmadethatthefacilitieswithCO2CEMShaveonlyoneunit.RCurrentCEMSinstallationunknown;assumedallfacilities/unitsinscenario1.STheRIAforpart98identifiedallfacilitiesbeingapplicabletoTier4requirementsandwouldthusinstallaCO2CEMS.Note,however,thatthiscountmaynotbeexclusivetosubpartSemissionssourcesand,forexample,someoftheidentifiedunitsmayfallundersubpartC.Forthepotentialcount,itwasassumedallunitswouldbeinscenario2,pertheRIA.UCurrentCEMSinstallationunknown;assumedallfacilities/unitsinscenario1.VScenario3costsappliedtofacilitieswithCEMS,othersassumedtobeinscenario1.XScenario3costsappliedtofacilitieswithCO2CEMS,othersassumedtobeinscenario1.AssumptionmadethatthefacilitieswithCO2CEMShaveonlyoneunit.YScenario3costsappliedtofacilitieswithCO2CEMS,othersassumedtobeinscenario1.ForpotentialCEMScount,distributednon‐GHGCEMSinscenario2and3basedonengineeringjudgment.ZScenario3costsappliedtofacilitieswithCEMS,othersassumedtobeinscenario1.AAScenario2costsappliedforfacilitieswithCEMS;basedoffGHGRIAestimatethatmostfacilitieswouldmeetthisforTierIVrequirements.BBCurrentCEMSinstallationunknown;assumedallfacilities/unitsinscenario1.CCCurrentCEMSinstallationunknown;assumedallfacilities/unitsinscenario1.EECurrentCEMSinstallationunknown;assumedallfacilities/unitsinscenario1.GGCurrentCEMSinstallationunknown;assumedallfacilities/unitsinscenario1.TTCurrentCEMSinstallationunknown;assumedallfacilities/unitsinscenario1.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review119Table C-8. Capital Costs (million dollars) forEach Scenario, Based on Actual CEMS CountsaSubpartCapitalCosts(MillionDollars)Scenario1Scenario2Scenario3Total‐AllScenariosCO2N2OCH4TotalCO2N2OCH4TotalCO2N2OCH4TotalC$1,578$1,603$1,640$1,960$102$104$107$134$‐$6.8$7.7$11.9$2,106E$‐$0.37$‐$0.37$‐$‐$‐$‐$‐$‐$‐$‐$0.4F$1.2$‐$‐$1.2$‐$‐$‐$‐$‐$‐$‐$‐$1.2G$2.7$‐$‐$2.7$‐$‐$‐$‐$‐$‐$‐$‐$2.7H$3.4$3.5$3.6$4.3$‐$‐$‐$‐$0.56$2.5$2.8$5.6$9.9K$1.2$‐$1.3$1.4$‐$‐$‐$‐$‐$‐$‐$‐$1.4L$‐$‐$‐$‐$‐$‐$‐$‐$‐$‐$‐$‐$‐N$13.2$13.4$13.7$16.3$‐$‐$‐$‐$‐$0.066$0.074$0.11$16.5O$‐$‐$‐$‐$‐$‐$‐$‐$‐$‐$‐$‐$‐P$12.3$12.5$12.8$15.3$‐$‐$‐$‐$‐$0.066$0.074$0.11$15.4Q$18.6$18.9$19.3$23.1$‐$‐$‐$‐$‐$0.31$0.35$0.54$23.6R$1.6$1.6$1.7$2.0$‐$‐$‐$‐$‐$‐$‐$‐$2.0S$8.9$9.0$9.2$11.0$‐$‐$‐$‐$‐$0.022$0.025$0.038$11.0U$2.2$‐$‐$2.2$‐$‐$‐$‐$‐$‐$‐$‐$2.2V$‐$3.6$‐$3.6$‐$‐$‐$‐$‐$0.79$‐$0.79$4.4X$7.6$7.7$7.9$9.5$‐$‐$‐$‐$‐$0.044$0.050$0.077$9.6Y$191$194$199$237$‐$‐$‐$‐$‐$0.57$0.65$1.00$238.5Z$0.74$‐$‐$0.74$‐$‐$‐$‐$0.14$‐$‐$0.14$0.88AA$7.9$8.0$8.2$9.8$25.7$26.2$27.0$33.7$‐$‐$‐$‐$43.4BB$0.12$‐$0.13$0.14$‐$‐$‐$‐$‐$‐$‐$‐$0.14CC$0.37$0.37$0.38$0.46$‐$‐$‐$‐$‐$0.022$0.025$0.038$0.50EE$0.86$‐$‐$0.86$‐$‐$‐$‐$‐$‐$‐$‐$0.86GG$0.74$0.75$0.77$0.92$‐$‐$‐$‐$‐$‐$‐$‐$0.92TT$‐$‐$22.1$22.1$‐$‐$‐$‐$‐$‐$‐$‐$22.1TOTAL$1,853$1,877$1,940$2,325$127.7$130.2$134$167.7$0.70$11.2$11.7$20.3$2,513aSee Appendix B for detailed summary for each subpart.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review120Table C-9. Annual Costs (million dollars) for Each Scenario, Based on Actual CEMS CountsaSubpartAnnualCosts(MillionDollars)Scenario1Scenario2Scenario3Total‐AllScenariosCO2N2OCH4TotalCO2N2OCH4TotalCO2N2OCH4TotalC$901$911$915$950$59.2$61.4$61.7$64.6$‐$6.6$6.7$7.1$1,022E$‐$0.21$‐$0.21$‐$‐$‐$‐$‐$‐$‐$‐$0.21F$0.70$‐$‐$0.70$‐$‐$‐$‐$‐$‐$‐$‐$0.70G$1.5$‐$‐$1.5$‐$‐$‐$‐$‐$‐$‐$‐$1.5H$2.0$2.0$2.0$2.1$‐$‐$‐$‐$0.6$2.4$2.4$2.7$4.8K$0.70$‐$0.71$0.73$‐$‐$‐$‐$‐$‐$‐$‐$0.73L$‐$‐$‐$‐$‐$‐$‐$‐$‐$‐$‐$‐$‐N$7.5$7.6$7.6$7.9$‐$‐$‐$‐$‐$0.06$0.06$0.07$8.0O$‐$‐$‐$‐$‐$‐$‐$‐$‐$‐$‐$‐$‐P$7.0$7.1$7.1$7.4$‐$‐$‐$‐$‐$0.06$0.06$0.07$7.5Q$10.6$10.7$10.8$11.2$‐$‐$‐$‐$‐$0.30$0.30$0.32$11.5R$0.91$0.92$0.93$0.96$‐$‐$‐$‐$‐$‐$‐$‐$0.96S$5.1$5.1$5.1$5.3$‐$‐$‐$‐$‐$0.021$0.021$0.023$5.4U$1.3$‐$‐$1.3$‐$‐$‐$‐$‐$‐$‐$‐$1.3V$‐$2.1$‐$2.1$‐$‐$‐$‐$‐$0.76$‐$0.76$2.8X$4.4$4.4$4.4$4.6$‐$‐$‐$‐$‐$0.042$0.043$0.046$4.6Y$109$110$111$115$‐$‐$‐$‐$‐$0.55$0.56$0.60$115.6Z$0.42$‐$‐$0.42$‐$‐$‐$‐$0.14$‐$‐$0.14$0.57AA$4.5$4.5$4.6$4.7$14.9$15.5$15.5$16.3$‐$‐$‐$‐$21.0BB$0.07$‐$0.07$0.07$‐$‐$‐$‐$‐$‐$‐$‐$0.07CC$0.21$0.21$0.21$0.22$‐$‐$‐$‐$‐$0.021$0.021$0.023$0.25EE$0.49$‐$‐$0.49$‐$‐$‐$‐$‐$‐$‐$‐$0.49GG$0.42$0.43$0.43$0.44$‐$‐$‐$‐$‐$‐$‐$‐$0.44TT$‐$‐$12.3$12.3$‐$‐$‐$‐$‐$‐$‐$‐$12.3TOTAL$1,058$1,066$1,082$1,129$74.1$76.8$77.3$80.9$0.74$10.8$10.2$11.9$1,223aSee Appendix B for detailed summary for each subpart.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review121Table C-10. Capital Costs (million dollars) for Each Scenario, Based on Potential CEMS CountsaSubpartCapitalCosts(MillionDollars)Scenario1Scenario2Scenario3Total‐AllScenariosCO2N2OCH4TotalCO2N2OCH4TotalCO2N2OCH4TotalC$1,578$1,603$1,640$1,960$111$114$117$146$‐$6.8$7.7$11.9$2,118E$‐$0.37$‐$0.37$‐$‐$‐$‐$‐$‐$‐$‐$0.4F$1.2$‐$‐$1.2$‐$‐$‐$‐$‐$‐$‐$‐$1.2G$2.7$‐$‐$2.7$‐$‐$‐$‐$‐$‐$‐$‐$2.7H$‐$‐$‐$‐$‐$‐$‐$‐$0.56$3.1$3.5$7.0$7.0K$1.2$‐$1.3$1.4$‐$‐$‐$‐$‐$‐$‐$‐$1.4L$‐$‐$‐$‐$‐$‐$‐$‐$‐$‐$‐$‐$‐N$13.2$13.4$13.7$16.3$‐$‐$‐$‐$‐$0.066$0.074$0.11$16.5O$‐$‐$‐$‐$‐$‐$‐$‐$‐$‐$‐$‐$‐P$12.3$12.5$12.8$15.3$‐$‐$‐$‐$‐$0.066$0.074$0.11$15.4Q$18.6$18.9$19.3$23.1$‐$‐$‐$‐$‐$0.31$0.35$0.54$23.6R$1.6$1.6$1.7$2.0$‐$‐$‐$‐$‐$‐$‐$‐$2.0S$‐$‐$‐$‐$‐$7.2$7.4$8.4$‐$‐$‐$‐$8.4U$2.2$‐$‐$2.2$‐$‐$‐$‐$‐$‐$‐$‐$2.2V$‐$3.6$‐$3.6$‐$‐$‐$‐$‐$0.79$‐$0.79$4.4X$7.9$8.0$8.2$9.8$‐$‐$‐$‐$‐$0.044$0.050$0.077$9.9Y$155$158$161$193$18.1$18.5$19.0$23.7$2.08$2.85$3.23$6.48$223.1Z$0.74$‐$‐$0.74$‐$‐$‐$‐$0.14$‐$‐$0.14$0.88AA$3.5$3.5$3.6$4.3$29.2$29.8$30.7$38.2$‐$‐$‐$‐$42.5BB$0.12$‐$0.13$0.14$‐$‐$‐$‐$‐$‐$‐$‐$0.14CC$0.37$0.37$0.38$0.46$‐$‐$‐$‐$‐$0.022$0.025$0.038$0.50EE$0.86$‐$‐$0.86$‐$‐$‐$‐$‐$‐$‐$‐$0.86GG$0.74$0.75$0.77$0.92$‐$‐$‐$‐$‐$‐$‐$‐$0.92TT$‐$‐$22.1$22.1$‐$‐$‐$‐$‐$‐$‐$‐$22.1TOTAL$1,801$1,823$1,885$2,260$158.7$169.0$174.4$216.4$2.8$14.0$15.0$27.2$2,504aSee Appendix B for detailed summary for each subpart.E.O. 12866 Review – Draft – Do Not Cite, Quote, or Release During Review122Table C-11. Annual Costs (million dollars) for Each Scenario, Based on Potential CEMS CountsaSubpartAnnualCosts(MillionDollars)Scenario1Scenario2Scenario3Total‐AllScenariosCO2N2OCH4TotalCO2N2OCH4TotalCO2N2OCH4TotalC$901$911$915$950$64.5$66.9$67.3$70.4$‐$6.6$6.7$7.1$1,027E$‐$0.21$‐$0.21$‐$‐$‐$‐$‐$‐$‐$‐$0.21F$0.70$‐$‐$0.70$‐$‐$‐$‐$‐$‐$‐$‐$0.70G$1.5$‐$‐$1.5$‐$‐$‐$‐$‐$‐$‐$‐$1.5H$‐$‐$‐$‐$‐$‐$‐$‐$0.6$3.0$3.0$3.4$3.4K$0.70$‐$0.71$0.73$‐$‐$‐$‐$‐$‐$‐$‐$0.73L$‐$‐$‐$‐$‐$‐$‐$‐$‐$‐$‐$‐$‐N$7.5$7.6$7.6$7.9$‐$‐$‐$‐$‐$0.06$0.06$0.07$8.0O$‐$‐$‐$‐$‐$‐$‐$‐$‐$‐$‐$‐$‐P$7.0$7.1$7.1$7.4$‐$‐$‐$‐$‐$0.06$0.06$0.07$7.5Q$10.6$10.7$10.8$11.2$‐$‐$‐$‐$‐$0.30$0.30$0.32$11.5R$0.91$0.92$0.93$0.96$‐$‐$‐$‐$‐$‐$‐$‐$0.96S$‐$‐$‐$‐$‐$4.2$4.3$4.4$‐$‐$‐$‐$4.4U$1.3$‐$‐$1.3$‐$‐$‐$‐$‐$‐$‐$‐$1.3V$‐$2.1$‐$2.1$‐$‐$‐$‐$‐$0.76$‐$0.76$2.8X$4.5$4.5$4.6$4.7$‐$‐$‐$‐$‐$0.042$0.043$0.046$4.8Y$89$90$90$94$10.5$10.9$10.9$11.4$2.14$2.75$2.79$3.15$108.1Z$0.42$‐$‐$0.42$‐$‐$‐$‐$0.14$‐$‐$0.14$0.57AA$2.0$2.0$2.0$2.1$16.9$17.6$17.6$18.5$‐$‐$‐$‐$20.6BB$0.07$‐$0.07$0.07$‐$‐$‐$‐$‐$‐$‐$‐$0.07CC$0.21$0.21$0.21$0.22$‐$‐$‐$‐$‐$0.021$0.021$0.023$0.25EE$0.49$‐$‐$0.49$‐$‐$‐$‐$‐$‐$‐$‐$0.49GG$0.42$0.43$0.43$0.44$‐$‐$‐$‐$‐$‐$‐$‐$0.44TT$‐$‐$12.3$12.3$‐$‐$‐$‐$‐$‐$‐$‐$12.3TOTAL$1,029$1,036$1,052$1,099$91.9$99.6$100.1$104.7$2.9$13.5$13.0$15.1$1,217aSee Appendix B for detailed summary for each subpart.

# Attachment R

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

1 TECHNICAL MEMORANDUM

DATE : April 2013

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

FROM: Lisa Grogan-McCulloch

SUBJECT: Analysis of Alternative Veri fication 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 repo rting 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 “Pro cess for Evaluating and Potentially Amending Part 98 Inputs to Emission Equations” (doc ket 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 requir e reporting of the “inputs to equations” data elements. This review ev aluates alternative veri fication methods for 25 subparts, based on the results of steps one through three of the f our-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 alte rnative verification approaches suggested in
comments to the Call for Information, which wa s 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 a lternative verification method that cons ists of an electronic verification tool developed by EPA, enhanced recordkeep ing 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 “inpu t to equation” data element is not listed explicitly in this
memorandum.

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

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 el ectronic reporting and verifi cation system for all subparts reporting under the program. The current veri fication approach for the GHGRP consists of requiring facility self-c ertification of the annual reports along with EPA conducting electronic

verification checks of the data en tered 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 re ported data other than inputs to emission equations (the reporting of which wa s deferred). For “supplier” subparts 2 

# (and starting in reporting year 2012 for subparts with inputs to emi ssion equations that were deferred until 2013),

these checks have been conducted us ing reported data that include the data needed to calculate outputs of the equations. Reporte rs under these subparts have been entering into e-GGRT the data needed to calculate the annual GHG quantities.

During reporting year 2010, EPA developed appr oximately 1,400 electronic verification checks to verify reported data. Based on these verifi cation checks, EPA followed up with facilities regarding potential da ta quality errors for approxima tely 2,360 of the approximately 6,700 facilities that reported in reporting year 2010. In reporti ng year 2011, EPA programmed an additional 1,000 checks into e-GGRT for the subpar ts that were reporting for the second year, expanding the number of checks to 2,400. EP A also programmed into e-GGRT, for 2011, approximately 1,300 checks for the newly-repor ting subparts. During re porting year 2011, EPA followed up with approximately 3,440 of the approximately 8,000 fac ilities that reported.

3.0 Evaluation of Alternative Verifica tion Methods Suggested by Commenters

The Call for Information notice specifically requested commenter i nput on alternative verification approaches that w ould not require reporting to EPA those data elements for which reporting may cause competitive harm. In res ponse, EPA received input from 16 commenters suggesting alternative verifica tion methods. The comments expr essed support for the following verification methods: (1) self -certification, (2) EPA complianc e 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.

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

3 to ensure that GHG emissions are being reporti ng accurately. EPA’s experience with reviewing the 2010 and 2011 reporting year annua l reports showed that there have been errors made in GHG emissions reporting. Self-certif ication alone would not addre ss these errors. As mentioned
in section 2.0 of this memorandum, EPA’s ve rification 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 Octobe r 30, 2009 final rule that initia ted 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 supplie rs in more than 40 source categories submit annual reports, it would be possible for EPA to vi sit only a very small fraction of the reporting facilities in any given year (e .g., even if EPA visited 100 fac ilities, that would be only 1.25 percent of reporters). Th erefore, relying solely on on-site compliance inspections as the primary method of verifying reported GHG data is impracti cal 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, th ere would be numerous other facili ties 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 co mpliance, EPA’s verification approach needs to collect enough information about al l 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 th eir 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 verificati on as an alternative verification method. EPA had previ ously considered third party ve rification, but decided against its implementation. Refer to EPA’s full rationale fo r not selecting third pa rty verification in the October 30, 2009 final rule (74 FR 56260). The followi ng is a summary of this rationale, as well as an explanation of why EPA has determ ined that these reasons still apply:

 The costs to the reporters of hiring third party verifiers woul d 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 woul d 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 ve rification, the vast majority of reporters did not subm it comments supporting this approach.

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

4  A centralized emissions verification system, as opposed to third party verification (which is de-centralized), provides a gr eater 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 emissi ons as well as to gain a fuller picture of the emissions profile of the different sectors, a nd will continue to do so in the future.

 Developing the third party ve rification approach would re quire EPA to establish and develop emissions verification protocols and a system to qualify and accredit third party verifiers, as well as to devel op and administer a process to en sure 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 cr iteria and systems described above to implement the GHGRP and ensure high quality emissions verificati on given the unique reporting requirements of the GHGRP. If EPA were to adopt third part y verification at this juncture, EPA would still have to develop the infras tructure described above to su pport 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 check s that EPA has developed over the first few years of the

program.

 Third party verification would pot entially 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 syst em, a facility would c ontract with a third party verifier and provide the ve rifier detailed data (by Marc h 31) so that the third party could perform the verification. The third party verifiers woul d 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 part y verifier would submit their findings to the facility with errors identified, which the f acility could then corre ct. For existing third party GHG verification programs, this verification process ge nerally 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 verificati on, EPA would review the data prior to release. EPA would then perform additional electronic checks on the full set of reported data because us ing such checks and statistical analyses on the entire data set would likely reveal inconsistencies and er rors in addition to those identified by the third p arty verifier. If EPA identified a dditional potential repor ting errors, EPA would then contact the facility to re solve the issue. It would be inefficient for EPA to perform verification of the data reported by faciliti es 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 conf licting, requests to the same facility regarding potential erro rs. As a result, this verification would likely be conducted after third party verification is complete. If EP A allows the same 4-month period it has in

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

5 previous years for these EPA verification activ ities 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 f acilities to respond to both third party ve rifiers as well as
EPA.

3.4 Verification in EPA’s Toxic Release Inventory (TRI) Program

The TRI program requires annual facility leve l reporting of the amount of toxic chemicals released to the environment or otherwise manage d as wastes. Some aspects of the TRI program are similar to the GHGRP. The TRI reports co ntain a signed self- certification that the information reported is accurate. Each facility must also keep records of how emissions were calculated, including supporting ma terials, 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 electron ic submission of data,
conducts electronic data checks, and contact facilities to resolv e reporting errors. However, the TRI is a different type of program than th e GHGRP in that it does not require specific monitoring and calculation approach es, but rather requires that es timates 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 entere d 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 provide d 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 Altern ative Verification Method Using an Inputs Verification Tool, Enhanced Record keeping, 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 requireme nts. 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 valu es. EPA considered using a similar approach whereby “inputs to equations” data elements woul d be entered into a new inputs verification tool within e-GGRT in such a way that the “inputs to e quations” 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 electroni c 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 el ements. 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 reporte r is actively using the tool, but would not be persisted (i.e., saved) within the e-GGRT database. Data entered into the t ool would be discarded

when the user’s session with e-GGRT ends.

If the reporter were to exit the inputs verification tool prio r to completing data entry or submitting their annual report, the tool would genera te a file of entered “inputs to equations” data elements, and allow the reporter to download th e file. The reporter w ould have the option to upload this file into the tool wh en 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 equa tions” data elements into the inputs verification
tool, the tool would calculate the annual GHG emissions valu es. The tool would use the following information in calculati ng these values: (1) “inputs to equations” data elements, (2) information entered into e-GGRT identifying whic h 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 a ppropriate reporting fields within e-GGRT. Reporters would then have the opportu nity to override the annual GHG emissions values calculated by the tool w ith their own calculated value.

Prior to annual report submittal, the inputs verifi cation tool would conduct a series of verification checks, including the following:

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

7  Verification checks on the annual GHG emi ssion values calculated by the inputs verification tool. Reporters w ould have the opportunity to ove rride 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 equatio ns” data elements. For example, the tool would check: (1) whether all re quired data were entered; (2) whether entered “inputs to equations” data element values are within th e expected ranges for the data elements; and (3) whether expected relationships exist be tween 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 “input s to equations” data elements (i.e., using “real-time” checking), a nd other checks would be conducted after the reporter has entered all specified “inputs to eq uations” data elements, because some algorithms may compare certain “inputs to equations” da ta elements (e.g., produc tion quantity) to GHG emission values at the subpart or facility level. Also, prior to submittal of the annual report, the inputs verification tool would ge nerate a verification summary containing the results of the verification checks. The verification summary w ould specify whether any potential errors, as described above, were identified, without spec ifying any information about the “inputs to equations” data elements. The reporter would ha ve an opportunity to review the verification summary and make necessary revisions to the en tered “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 report er 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 veri fication activities with the use of the inputs
verification tool, EPA considered two enhancements to recordk eeping requirements. First, EPA considered extending the record re tention period from 3 to 5 years. It would be important that

relevant records are available to EPA for follow- up activities with facil ities, including on-site audits if necessary, regarding potential errors, discrepancies, or questions. Should an EPA inspector visit a facility, it woul d be important to be able to ex amine not only the current year’s records, but also those from prev ious years, because previous ye ars’ data would provide year-toyear comparisons, which are useful for verifyi ng the current year’s data. A 5-year record retention period would ensure th e availability of relevant records for the follow-up activities

described above.

Second, EPA considered revisions to the record keeping format for “inputs to equations” data elements. Currently, reporters have the option to maintain records of their “inputs to equations”

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

8 data elements in one or more electronic or ha rd copy files. Requiring re porters to maintain an electronic or hard copy of the single file genera ted by the inputs verification tool (i.e., a file listing all “inputs to equations” data elements ente red into the tool) would ensure that EPA could readily access these data during site visits, en abling EPA to quickly a nd efficiently perform

calculations and data checks.

4.3 Description of Additional Reporting Requirements

To improve the efficiency of the data verificati on process under this alte rnative approach using the inputs verification tool desc ribed in section 4.1 and the enha nced recordkeeping described in section 4.2, EPA considered supplementing the information available to EPA under the GHGRP by requiring reporting of additiona l data. Certain additional data would enable EPA to perform
additional verification checks, th ereby minimizing the number of fo llow-up activities. Such data would provide information on the activity level at the facility, emission factor s, characteristics of carbon-containing streams, and other process in formation that provide key information for verification (e.g., data confirming that emissions are appropriate for a given activity-level, and data estimating expected emissi ons based on data provided).

4.4 Review of Effectiveness of Using an Inputs Verification Tool, Enhanced Recordkeeping, and Additional Reportin g 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 electr onic 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 conduc t 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 th e 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 a pproach 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 dead line was deferred until 2013), except that eGGRT would not retain the “input s to equations” data elements entered into the tool, as

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

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 cu rrently collected through the annua l report. By requiring use of the inputs verification tool, EPA would have th e additional certainty th at reported annual GHG

emissions values either were cal culated correctly (because the valu es 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 submitte d 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 veri fication once the annual report is submitted.

Once data verification within the inputs verifica tion 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 reporti ng requirements. Regarding any needed followup with facilities, the enhanced recordkeeping requirements descri bed 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 ap proach consisting of the use of the inputs verification tool, enhanced recordkeeping, and additional reporting as a viable alternative approach to verifying data re ported under the 25 subparts bei ng 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 unde r e-GGRT’s two reporting options as well as the
basic function of the tool. Se ction 3 describes the database design for the e-GGRT application and data structure for the inputs verification tool . Section 4 describes ho w the inputs verification tool manages data for the two reporting options.

2. Description

The inputs verification tool woul d accommodate the two reporting options currently available in e-GGRT: entry of data on web fo rms 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 basi c function of the tool.

For the web form reporting option, users would enter their annual GHG repor t 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, c onduct verification checks on the inputs to emission equations, and generate a verification summary listing the results of the verification check. The inputs to equations wo uld not be saved and would be immediately deleted when the user logs out, closes the brow ser window, or if the user’s session times out due to an extended period (e.g., 25 minutes) of inac tivity (see Section 4 of this memorandum for additional details). Only the verification summ ary as well as the data reporting elements required in the annual GHG report would be sa ved to the e-GGRT database and accessible during subsequent user sessions.

The inputs verification tool w ould be a module within the e- GGRT application. To access the inputs verification tool, users woul d 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 veri fication 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 th e 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 expe cted ranges, and whether expected relationships exist between inputs to equations da ta and other data entered for the facility that is part of the annual GHG report. The inputs verification tool w ould 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 upl oad an XML file cont aining 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 verifi cation tool XML schema (see Section 3 of this memorandum for additional information on the input s verification tool sche ma). 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 ve rification check. The in puts to equations XML
file would not be saved and woul d 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 fo r 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 input s verification tool screens. Instead, users would be prompted to upload th eir annual report XML file, upl oad their inputs to equations XML file, and the inputs verification tool pr ocesses the files in the background. When completed, users would be taken to a summary scr een 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 da ta entered into or us ed by the inputs verifi cation 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 input s verification tool have separate data structures. The data structure for the e-GGRT application defines ho w data in the annual re port 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., da te/timestamps, status va lues, etc.). The data structure for the inputs verification tool define s how the inputs to equa tions are organized and only provides for in-memory handli ng of inputs to equations and a ssociated metadata elements. The segregation of the two data st ructures ensures that annual repo rt 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 Nationa l Computing Center as the us er navigates through the e-GGRT web application and takes certai n 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 stor ed in the relational database is retrieved and formatted in accordance with the published e-GGRT XML Re porting Schema. The reporting schema does NOT contain any data element definitions for inputs to equations, en suring that annual GHG reports exclude inputs to equations.

For the XML reporting option, users would upload tw o XML files, one file with the annual GHG report data (comporting with the e-GGRT data struct ure) 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/additio nal data elements, it would be rejected as
invalid. EPA would conduct verification checks on th e inputs to equations stored temporarily in session memory and generate a verification summary. EPA w ould not save the inputs to equations file. EPA would only sa ve 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 ta ble or column exists to store the inputs to equations da ta elements. It also contains the data structure for the inputs verification tool pr ototype developed for subpart X, mass balance methodology.

4. Data Management

This section describes how the inputs verifica tion tool manages data for the two reporting options.

For the web form reporting option, users would ente r data into the inputs verification tool web forms. As the user enters this data, it is tem porarily stored to an area of the application server called the session. The session is a temporary, in-m emory 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 se ssion, even by logging in with the same username and password of a user who is cu rrently 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 a nd 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 exampl e, session data is not se nt to a recycle bin or deleted items folder. Because the inputs to equati ons 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 th e e-GGRT database is backed up daily and may periodically be replicated. Ho wever, as discussed above, the data base does not contain inputs to equations, so no copies of the inputs data are either created or maintained.

EPA anticipates that some users w ould not be able to enter all thei r inputs to equations into the inputs verification tool web form s during one sitting. Alternat ely, some users may want to update or correct inputs that were entered duri ng a prior session without having to re-enter all their inputs to equations. Because the inputs veri fication 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 repo rt in the one e-GGRT session. The inputs verification tool will assist users in this pro cess. 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 verificati on 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 w ould upload the inputs ve rification tool file as described in
Sections 2 and 3 of this memorandum. As with the web forms reporting option, the inputs verification tool would temporar ily store the data to the session. The input s 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 th e 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 br ief overview of how the inputs verifica tion tool functions from the user’s perspective (for the web forms reporting option).

To access the inputs verification tool, us ers would log in to e-GGRT with th eir 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 an d also entered the Subpart X reporti ng 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-cont aining product for the process unit.

Figure 1. e-GGRT Data Reporting Screen

From this screen, the user would us e the button labeled “Use Inputs Verifi er to calculate | GO” to access the inputs verification module and enter e quation inputs for the feedstock(s) and product(s) they have added.

# Page 2 The screens in the inputs verification tool module are different in appearan ce 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 e quations 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 w ould click the “SAVE” button, shown in Figure 3.

The inputs verification tool will calcu late 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 th e 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 th e information in the “Exporte d 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 user name 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 th e “Use Inputs Verifier to calcul ate | GO” button to open the inputs
verification tool module.

Figure 8 shows the inputs verificatio n 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 w ould click the link labeled “T emporarily 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 th e 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 input s data file that the user imported.

# Attachment U

# Attachment 2. Data Structure

# Database Structure

Figure 1 contains a sample annual GHG re port (in XML) for Subpart X that is properly formatted. This file
would be submitted to EPA and saved in the e-GGRT databa se. Note that there are no equation inputs contained in the annual report file structure. Figure 2 contains a sample Inputs Verifi cation Tool file (in XML) for Subpart X that is properly formatted. This file would be gene rated and used by the Inputs Ve rification Tool. This file
would not be saved to the eGGRT databa se. This file would be saved and maintained by reporters on their local machines. Figure 1 and Figure 2 demonstr ate that inputs data w ould not be intermixed w ith annual report data, but kept in separate data st ructures. Only the annual report data (as seen in Figure 1) w ould 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 represen tative 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 </ Local ityName >

**-** < 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 "> 30 6892.8 </ TotalNonBiogenicCO2eFacilitySubpartsCtoJJ >

< TotalBiogenicCO2Facili tySubpartsCtoJJ massUOM =" Metric

Tons "> 0 </ TotalBiogenicCO2Fa cilitySubpartsCtoJJ >

< 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 > Car bon 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 </ Pe troChemicalProductType >

**-** < 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 ">

< C alculatedValue > 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 >

**-** < A nnualQuantity massUOM =" Metric Tons ">

< MeasureValue > 500250 </ MeasureValue >

## </ AnnualQuantity >

**-** < MonthlyDetails >

< MonthName > January </ MonthName >

**-** < OtherProductF eedStockDetails >

**-** < VolumeorMass >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ VolumeorMass >

< VolumeorMassMethod > Tank level measurements </ VolumeorMassMethod >

**-** < CarbonContent >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ CarbonContent >

< CarbonContentMethod > ASTM D5373-08 </ CarbonContentMethod >

**-** < MolecularWeight >

< IsS ubstitutedIndicator > N </ IsSubstitutedIndicator > </ MolecularWeight >

< MolecularWeightMethod > Calculated based on chemical formula and atomic weights </ MolecularWeightMethod >

< VolumeTemperatureBasis > 60 degrees Fahrenheit </ VolumeTemperatureBasis > </ OtherProductF eedStockDetails > </ MonthlyDetails >

**-** < MonthlyDetails >

< MonthName > February </ MonthName >

**-** < OtherProductF eedStockDetails >

**-** < VolumeorMass >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ VolumeorMass >

< VolumeorMassMethod > Tank level measurements </ VolumeorMassMethod >

**-** < Carbon Content >

< 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 > </ OtherProductF eedStockDetails > </ MonthlyDetails >

**-** < MonthlyDetails >

< MonthName > March </ Mont hName >

**-** < OtherProductF eedStockDetails >

**-** < 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 > Calcu lated based on chemical formula and atomic weights </ MolecularWeightMethod >

## < VolumeTemperatureBasis > 60 degrees Fahrenheit </ VolumeTemperatureBasis > </ OtherProductF eedStockDetails > </ MonthlyDetails >

**-** < MonthlyDetails >

< MonthName > April </ MonthName >

**-** < OtherProductF eedStockDetails >

**-** < VolumeorMass >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ VolumeorMass >

< VolumeorMassMethod > Tank level measurements </ VolumeorMassMethod >

**-** < CarbonContent >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ CarbonContent >

< C arbonContentMethod > ASTM D5373-08 </ CarbonContentMethod >

**-** < MolecularWeight >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ MolecularWeight >

< MolecularWeightMethod > Calculated based on chemical formula and atomic weights </ MolecularWeightMethod >

< VolumeTemperatureBasis > 60 degrees Fahrenheit </ VolumeTemperatureBasis > </ OtherProductF eedStockDetails > </ MonthlyDetails >

**-** < MonthlyDetails >

< MonthName > May </ MonthName >

**-** < OtherProductF eedStockDetails >

**-** < VolumeorMass >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ Volume orMass >

< 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 > </ OtherProductF eedStockDetails > </ M onthlyDetails >

**-** < MonthlyDetails >

< MonthName > June </ MonthName >

**-** < OtherProductF eedStockDetails >

**-** < VolumeorMass >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ VolumeorMass >

< VolumeorMassMethod > Tank level measurements </ VolumeorMassMethod >

**-** < CarbonContent >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ CarbonContent >

< CarbonContentMethod > ASTM D5373-08 </ CarbonContentMethod >

**-** < MolecularWeight >

< IsS ubstitutedIndicator > N </ IsSubstitutedIndicator > </ MolecularWeight >

## < MolecularWeightMethod > Calculated based on chemical formula and atomic weights </ MolecularWeightMethod >

< VolumeTemperatureBasis > 60 degrees Fahrenheit </ VolumeTemperatureBasis > </ OtherProductF eedStockDetails > </ MonthlyDetails >

**-** < MonthlyDetails >

< MonthName > July </ MonthName >

**-** < OtherProductF eedStockDetails >

**-** < VolumeorMass >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ VolumeorMass >

< VolumeorMassMethod > Tank level measurements </ VolumeorMassMethod >

**-** < CarbonContent >

< IsSubstitutedIndicator > N </ IsS ubstitutedIndicator > </ 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 > </ OtherProductF eedStockDetails > </ MonthlyDetails >

**-** < MonthlyDetails >

< MonthName > August </ MonthName >

**-** < OtherProductF eedStockDetails >

**-** < VolumeorMass >

< IsS ubstitutedIndicator > 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 </ VolumeTem peratureBasis > </ OtherProductF eedStockDetails > </ MonthlyDetails >

**-** < MonthlyDetails >

< MonthName > September </ MonthName >

**-** < OtherProductF eedStockDetails >

**-** < VolumeorMass >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ VolumeorMass >

< VolumeorMassMethod > Tank level measurements </ VolumeorMassMethod >

**-** < CarbonContent >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ CarbonContent >

< CarbonContentMethod > ASTM D5373-08 </ CarbonContentMethod >

**-** < M olecularWeight >

## < IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ MolecularWeight >

< MolecularWeightMethod > Calculated based on chemical formula and atomic weights </ MolecularWeightMethod >

< VolumeTemperatureBasis > 60 degrees Fahrenheit </ VolumeTemperatureBasis > </ OtherProductF eedStockDetails > </ MonthlyDetails >

**-** < MonthlyDetails >

< MonthName > October </ MonthName >

**-** < OtherProductF eedStockDetails >

**-** < VolumeorMass >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ VolumeorMass >

< VolumeorMassMethod > Tank level measurements </ VolumeorMassMethod >

**-** < Carbon Content >

< 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 > </ OtherProductF eedStockDetails > </ MonthlyDetails >

**-** < MonthlyDetails >

< MonthName > November </ Mo nthName >

**-** < OtherProductF eedStockDetails >

**-** < 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 >

< M olecularWeightMethod > Calculated based on chemical formula and atomic weights </ MolecularWeightMethod >

< VolumeTemperatureBasis > 60 degrees Fahrenheit </ VolumeTemperatureBasis > </ OtherProductF eedStockDetails > </ MonthlyDetails >

**-** < MonthlyDetails >

< MonthName > December </ MonthName >

**-** < OtherProductF eedStockDetails >

**-** < VolumeorMass >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ VolumeorMass >

< VolumeorMassMethod > Tank level measurements </ VolumeorMassMethod >

**-** < CarbonContent >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ Carbon Content >

## < 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 > </ OtherProductF eedStockDetails > </ MonthlyDetails > </ ProductFeedStockDetails >

**-** < ProductFeedStockDetails >

< ProductOrFeedstockIndicator > Product </ ProductOrFeedstockIndicator >

< Type > Methanol </ Type >

< PhysicalState > Liquid </ PhysicalState >

**-** < F lowMeterDetails >

< ManufacturersRecommendedMethod > twice monthly

measurements </ ManufacturersRecommendedMethod >

< CalibrationMethod > twice monthly calibrations </ CalibrationMethod > </ FlowMeterDetails >

**-** < AnnualQuantity massUOM =" Metric Tons ">

< MeasureValue > 678260 </ MeasureValue > </ AnnualQuantity >

**-** < MonthlyDetails >

< MonthName > January </ MonthName >

**-** < OtherProductF eedStockDetails >

**-** < VolumeorMass >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ Volume orMass >

< VolumeorMassMethod > Tank level measurements </ VolumeorMassMethod >

**-** < CarbonContent >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ CarbonContent >

< CarbonContentMethod > SW-846 Method 9060A </ CarbonContentMethod >

**-** < MolecularWeight >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ MolecularWeight > </ OtherProductF eedStockDetails > </ MonthlyDetails >

**-** < MonthlyDetails >

< MonthName > February </ MonthName >

**-** < OtherProductF eedStockDetails >

**-** < VolumeorMass >

< IsS ubstitutedIndicator > N </ IsSubstitutedIndicator > </ VolumeorMass >

< VolumeorMassMethod > Tank level measurements </ VolumeorMassMethod >

**-** < CarbonContent >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ CarbonContent >

< CarbonContentMethod > SW-846 Method 9060A </ CarbonContentMethod >

**-** < MolecularWeight >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ MolecularWeight > </ OtherProductF eedStockDetails > </ M onthlyDetails >

**-** < MonthlyDetails >

## < MonthName > March </ MonthName >

**-** < OtherProductF eedStockDetails >

**-** < 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 > </ OtherProductF eedStockDetails > </ M onthlyDetails >

**-** < MonthlyDetails >

< MonthName > April </ MonthName >

**-** < OtherProductF eedStockDetails >

**-** < VolumeorMass >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ VolumeorMass >

< VolumeorMassMethod > Tank level measurements </ VolumeorMassMethod >

**-** < CarbonContent >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ CarbonContent >

< CarbonContentMethod > SW-846 Method 9060A </ CarbonContentMethod >

**-** < M olecularWeight >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ MolecularWeight > </ OtherProductF eedStockDetails > </ MonthlyDetails >

**-** < MonthlyDetails >

< MonthName > May </ MonthName >

**-** < OtherProductF eedStockDetails >

**-** < VolumeorMass >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ VolumeorMass >

< VolumeorMassMethod > Tank level measurements </ VolumeorMassMethod >

**-** < CarbonContent >

< IsSubstitutedIndicator > N </ IsS ubstitutedIndicator > </ CarbonContent >

< CarbonContentMethod > SW-846 Method 9060A </ CarbonContentMethod >

**-** < MolecularWeight >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ MolecularWeight > </ OtherProductF eedStockDetails > </ MonthlyDetails >

**-** < MonthlyDetails >

< MonthName > June </ MonthName >

**-** < OtherProductF eedStockDetails >

**-** < VolumeorMass >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ VolumeorMass >

< VolumeorMassMethod > Tank l evel measurements </ VolumeorMassMethod >

**-** < CarbonContent >

## < IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ CarbonContent >

< CarbonContentMethod > SW-846 Method 9060A </ CarbonContentMethod >

**-** < MolecularWeight >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ MolecularWeight > </ OtherProductF eedStockDetails > </ MonthlyDetails >

**-** < MonthlyDetails >

< MonthName > July </ MonthName >

**-** < OtherProductF eedStockDetails >

**-** < VolumeorMass >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ Volume orMass >

< VolumeorMassMethod > Tank level measurements </ VolumeorMassMethod >

**-** < CarbonContent >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ CarbonContent >

< CarbonContentMethod > SW-846 Method 9060A </ CarbonContentMethod >

**-** < MolecularWeight >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ MolecularWeight > </ OtherProductF eedStockDetails > </ MonthlyDetails >

**-** < MonthlyDetails >

< MonthName > August </ MonthName >

**-** < OtherProductF eedStockDetails >

**-** < VolumeorMass >

< IsS ubstitutedIndicator > N </ IsSubstitutedIndicator > </ VolumeorMass >

< VolumeorMassMethod > Tank level measurements </ VolumeorMassMethod >

**-** < CarbonContent >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ CarbonContent >

< CarbonContentMethod > SW-846 Method 9060A </ CarbonContentMethod >

**-** < MolecularWeight >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ MolecularWeight > </ OtherProductF eedStockDetails > </ MonthlyDetails >

**-** < Mont hlyDetails >

< MonthName > September </ MonthName >

**-** < OtherProductF eedStockDetails >

**-** < VolumeorMass >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ VolumeorMass >

< VolumeorMassMethod > Tank level measurements </ VolumeorMassMethod >

**-** < CarbonContent >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ CarbonContent >

< CarbonContentMethod > SW-846 Method 9060A </ CarbonContentMethod >

**-** < MolecularWeight >

< IsSubstitutedIndicator > N </ IsS ubstitutedIndicator > </ MolecularWeight > </ OtherProductF eedStockDetails >

## </ MonthlyDetails >

**-** < MonthlyDetails >

< MonthName > October </ MonthName >

**-** < OtherProductF eedStockDetails >

**-** < VolumeorMass >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ VolumeorMass >

< VolumeorMassMethod > Tank level measurements </ VolumeorMassMethod >

**-** < CarbonContent >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ CarbonContent >

< CarbonContentMethod > SW-846 Method 9060A </ CarbonContentMethod >

**-** < MolecularWeight >

< IsS ubstitutedIndicator > N </ IsSubstitutedIndicator > </ MolecularWeight > </ OtherProductF eedStockDetails > </ MonthlyDetails >

**-** < MonthlyDetails >

< MonthName > November </ MonthName >

**-** < OtherProductF eedStockDetails >

**-** < VolumeorMass >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ VolumeorMass >

< VolumeorMassMethod > Tank level measurements </ VolumeorMassMethod >

**-** < CarbonContent >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ CarbonContent >

< C arbonContentMethod > SW-846 Method 9060A </ CarbonContentMethod >

**-** < MolecularWeight >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ MolecularWeight > </ OtherProductF eedStockDetails > </ MonthlyDetails >

**-** < MonthlyDetails >

< MonthName > December </ MonthName >

**-** < OtherProductF eedStockDetails >

**-** < VolumeorMass >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ VolumeorMass >

< VolumeorMassMethod > Tank level measurements </ VolumeorMassMethod >

**-** < Carbon Content >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ CarbonContent >

< CarbonContentMethod > SW-846 Method 9060A </ CarbonContentMethod >

**-** < MolecularWeight >

< IsSubstitutedIndicator > N </ IsSubstitutedIndicator > </ MolecularWeight > </ OtherProductF eedStockDetails > </ MonthlyDetails > </ ProductFeedStockDetails >

**-** < XProductDetails >

< PetroChemicalProductType > Methanol </ PetroChemicalProductType > </ XProductDetails >

**-** < OffSpecProductMassorVolume volUOM =" G allons ">

< 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 >

< Star tDate > 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 </ SubpartNa me > </ SubpartBAMMDetails > </ FacilitySiteInformation > </ GHG >

# Figure 2: XML Structure for S ubpart 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 databa se during the export or import process.

Figure 1. Export Process

In Figure 1, the code highlighted in gray and outli ned 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 outli ned in yellow shows that the system stores the Java object in session after reading the user-suppl ied file. The location fo r 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.