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Chapter 12

Recordkeeping and Reporting

Contents

12.1 General................................................................................................................................. 2

12.2 Notifications......................................................................................................................... 3

12.3 Recordkeeping ..................................................................................................................... 3

12.4 Electronic Reporting ............................................................................................................ 6

Compliance with Part 75 Reporting........................................................................................ 6

New Reporting to ECMPS...................................................................................................... 7

Duplicative Reporting............................................................................................................. 8
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12.1 GENERAL

Comment 12.1-1: Commenter 9664 asked that the reporting and recordkeeping provisions be 

changed. The commenter requested that the EPA change 60.46Da (h) and 60.46Da (i) be updated 

to include the following language, "any EGU meeting the standard through long-term 

containment in a subsurface geological formation (either through geologic sequestration or in 

enhanced oil recovery) [must] provide documentation showing that the volume of captured CO2

necessary to achieve the standard has been injected onsite to a facility permitted under the UIC 

program and reporting under Subpart RR [of Part 98], or transferred to a facility that is permitted 

under the UIC program and reports under Subpart RR." The commenter also asked that the 

reporting become a condition of the title V permit for the facility. 42 USC section 7661c(a).

Response 12.1-1: As explained in section III.B of the final rule preamble, the EPA is combining 

the steam generator and combustion turbine categories into a single category of fossil fuel-fired 

electricity generating units for purposes of promulgating standards of performance for GHG 

emissions. The standards of performance for CO2 emissions will be codified in a new 40 CFR 

part 60, subpart TTTT. The EPA is not finalizing the co-proposed approach of codifying the 

standards of performance in the 40 CFR part 60, subparts Da and KKKK. Although the comment 

regards requested revisions to 40 CFR part 60, subpart Da provisions, a response to the substance 

of the comment in terms of subpart TTTT is provided. See Chapter 6 of this document for 

responses relating to 40 CFR Part 98 Subpart RR. See preamble section XII. Implications for 

PSD and Title V Programs for further discussion on PSD and Title V permits.

Comment 12.1-2: Comment 2: Commenter 8952 asked that the recordkeeping and reporting 

provisions be changed. The commenter recommended a few revisions to the recordkeeping and 

reporting requirements:

 change hourly fuel consumption rates to monthly fuel consumption

 change hourly generation data to monthly generation data

The commenter stated that the EPA could "gather these data directly without imposing an 

additional regulatory burden on facilities." The commenter noted that substantial amounts of 

these data are available through the EIA Electric Power Monthly.

Response 12.1-2: The final rule does not require records of hourly fuel consumption or hourly

generation to be kept as separate entities. However, for sources using Appendices D and G of 

Part 75 to demonstrate compliance, the quarterly Part 75 electronic emissions reports do require 

hourly fuel flow rates to be reported. And for all affected units, gross hourly electrical load is 

reported in the quarterly Part 75 electronic emissions data reports (EDRs).
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Comment 12.1-3: Commenter 9427 asked "when do notification, recordkeeping, monitoring, 

and reporting requirements begin to apply?" The commenter recommended the following 

language, "Notifications, recordkeeping, monitoring, and periodic reporting requirements would 

be the responsibility of new stationary combustion turbine owners/operator that meet the 'three 

consecutive calendar years' applicability criteria."

Response 12.1-3: In view of the changes to the applicability section of the rule, there is no need 

to provide any notices of applicability. Initial applicability is based solely on the design heat 

input capacity of the unit and the size of the electrical generator, and once a unit is identified as 

“affected”, it remains in the program. Other notifications (i.e., the commencement of 

construction and unit startup notices in §60.7(a) and the applicable notifications in §75.61 shall 

be submitted within the time frames specified in those sections.

12.2 NOTIFICATIONS

Comment 12.2-1: Two commenters (9425 and 9666) supported the notifications required by the 

rulemaking.

Response 12.2-1: The EPA acknowledges the commenters’ support.

Comment 12.2-2: Two commenters (9425 and 9666) noted some duplicative notifications.

Commenters 9425 and 9666 stated, "EPA should exempt the notices in Section 75.61 from the 

duplicate reporting requirements in Section 60.4, which requires that all 'request, reports, 

applications, submittals, and other communications to the Administrator' be submitted 'in 

duplicate' to the appropriate EPA Regional Office and to any delegated state." Commenter 9666 

noted that "section 75.61 already requires submission to those officials, there is no basis for 

requiring additional reporting 'induplicate' under Part 60."

Response 12.2-2: Table 3 of the final rule clarifies that the notices under §75.61 are not subject 

to the submittal requirements of §60.4, and that duplicate submittals are not required for 

information that is subject to those requirements. 

12.3 RECORDKEEPING

Comment 12.3-1: Commenter 9426 asked that the EPA specify what "maintaining records of 

calculations" means. The commenter wanted assurance that the EPA did not expect "sources to 

manually calculate all averages used for compliance with these rules, and then maintain hard 

copies of those calculations." The commenter asked that the EPA modify the rule so that "the 

rule is clear that computerized database records and calculations, with reporting verifications of 

equations such as required under 40 CFR Part 75, are acceptable." 

Response 12.3-1: The EPA agrees with the commenter. The final rule specifies that 

computerized (electronic) records are acceptable as long as they can be made readily available to 

inspectors and auditors upon request.
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Comment 12.3-2: Commenters 9426 and 10023 commented on duplicative recordkeeping 

requirements. The commenters asked that the EPA "not impose any additional recordkeeping 

requirements that either duplicate Part 75 or go beyond what is required for Part 75."

Response 12.3-2: The final rule does not require any duplicative recordkeeping between Parts 

60 and 75. However, there are certain records that must be kept for the purposes of the NSPS 

(e.g., records of the calculations used for the compliance determinations), which are not required 

under Part 75.

Comment 12.3-3: Several commenters (9426, 9514, 9666, and 10023) offered recommendations 

related to electronic compliance records. One commenter (9426) asked that the EPA modify the 

language in paragraphs 60.46Da(i)(8) and 60.4391(h)(3) so that it is clear that electronic records 

are acceptable for the initial two years. Three commenters (9426, 9666, and 10023) asked for 

clarification on the terms "onsite" and "offsite" when related to recordkeeping. Commenter 9426 

asked that the language be modified to indicate that electronic records can "be stored at an offsite 

location for the first two years as long as they are readily accessible onsite," while commenters 

9666 and 10023 stated that "as long as the facility can access the information onsite, there is no 

reason for it to be physically located there."

Commenter 9514 stated that "EPA has not identified any particular (or even generalized) basis 

for its proposal to permit offsite storage after two years." The commenter asked that the EPA 

adopt additional language covering record retention. The commenter stated, "For example, under 

the subpart 98 reporting program for GHGs, records may be stored off site only 'if the records 

are readily available for expeditious inspection and review.' 40 C.F.R. Section 98.3(g). In 

addition, for any records stored electronically, '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.' Id."

Commenter 9514 asked for clarification on the term "readily available." The commenter 

suggested "available on demand, not just to EPA, but to state and local authorities, irrespective 

of jurisdiction over the site where the records are stored, and to the general public."

Response 12.3-3: As explained in section III.B of the final rule preamble, the EPA is combining 

the steam generator and combustion turbine categories into a single category of fossil fuel-fired 

electricity generating units for purposes of promulgating standards of performance for GHG 

emissions. The standards of performance for CO2 emissions will be codified in a new 40 CFR 

part 60, subpart TTTT. The EPA is not finalizing the co-proposed approach of codifying the 

standards of performance in the 40 CFR part 60, subparts Da and KKKK. Although the comment 

refers to 40 CFR part 60, subpart Da provisions, a response to the substance of the comment in 

terms of subpart TTTT is provided. The final rule requires that records be maintained for 3 years 

after the date of each occurrence, measurement, maintenance, corrective action, report or record. 

The final rule clarifies that each record must be kept on site or be accessible from a central 

location by computer or other means that instantly provide access at the site for at least 2 years 

after the date of each recorded action and may be kept off site for the remaining year(s).
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Comment 12.3-4: Commenters 9666 and 10023 noted places in the proposed rule that contain 

unnecessary or duplicative recordkeeping provisions. Commenters 9666 and 10023 noted that 

the provisions in 60.7(b), 60.7(f), 60.5560(a), 60.4391(a) referring to startups and shutdowns 

have no basis to require records of those periods because there are no provisions in the NSPS 

that apply only to startup or shutdown. Commenter 9666 also opposed any recordkeeping 

requirements that are duplicative of Part 75, specifying 60.5560(b)-(d), 60.46 Da(i)(1), and 

60.4391(b). This commenter (9666) asked that the EPA remove all recordkeeping provisions that 

refer to operating months because the compliance period is not monthly.

Response 12.3-4: The final rule does not require any duplicative recordkeeping between Parts 

60 and 75. However, there are certain records that must be kept for the purposes of the NSPS 

(e.g., records of the calculations used for the compliance determinations), which are not required 

under Part 75. The monthly recordkeeping requirements have been removed; rather, records must 

be kept for each “compliance period”. 

The final rule does not require records of startup and shutdown to be kept. The quarterly Part 75 

electronic emissions reports show only hours in which the unit operated (combusted fuel). Unit 

startups and shutdowns are easily identified from the date and time stamps on the operating 

hours. 

Comment 12.3-5: Commenter 9666 disagreed with the EPA's "5 year record retention period for 

all of the supporting information for the 12-operating-month rolling average standard, unless 

EPA can show a special need as required under the Paperwork Reduction Act regulations." The 

commenter recommended a 3-year record retention requirement to match part 75.

Response 12.3-5: The EPA agrees that records should be maintained for 3 years after the date of 

each occurrence, measurement, maintenance, corrective action, report or record, and has revised 

the final rule accordingly.

Comment 12.3-6: Commenter 8957 asked that the EPA require the owner or operator to keep 

records that verify its applicability status. The commenter stated, "If the owner or operator 

considers themselves to be subject, they should keep all records and submit all reports as 

required by the rule on an annual basis. If the owner or operator does not consider themselves to 

be affected by the rule, they should only be required to keep records that verify that they are not 

subject to the rule. A reporting requirement for non-affected sources should not be required; 

records should be maintained for five years and reported to EPA or the permitting agency upon 

request."

Response 12.3-6: In view of the changes to the applicability section of the rule, there is no need 

to provide any notices of applicability. Initial applicability is based solely on the design heat 

input capacity of the unit and the size of the electrical generator, and once a unit is identified as 

“affected”, it remains in the program. 
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12.4 ELECTRONIC REPORTING

Compliance with Part 75 Reporting

Comment 12.4-1: Two commenters (9425 and 9666) recommended changes to the reporting 

language.

Commenter 9425 noted that many combined cycle systems share a single turbine generator with 

two or more combustion turbines. The commenter suggested the following text be included in 

Section 60.4374(a)(3)(i):

"The steam turbine output should be accounted for using one of the methods allowed in 

the Part 75 Policy Manual, Section 17.2 Unit Load Reporting:

(1) For a combined-cycle unit (with or without auxiliary firing), if a single generator 

serves the CT and HRSG, report the electrical outputs (megawatts) from this generator.

(2) For a combined-cycle unit (with or without auxiliary firing), if separate generators 

serve the CT and HRSG add the electrical outputs (megawatts) from these generators.

(3) If the HRSG of two or more combined cycle units (CCUs) share a common steam 

turbine, then, for each CCU, add the electrical output (megawatts) from the generator 

that serves the CT to an apportioned fraction of the electrical output from the shared 

steam turbine. Apportion the combined electrical load from the common steam turbine to 

the individual CCUs according to the fraction of the total steam load contributed by each 

unit. Alternatively, if the turbines are identical, you may apportion the combined 

electrical load from the common steam turbine to the individual CCUs according to the 

fraction of the total heat input contributed by each unit."

Commenter 9666 noted that requiring compliance with "'all applicable reporting requirements in 

Part 75" in 60.5555(c), 60.46Da(h)(4), and 60.4376(d) is overly broad. The commenter 

suggested that the EPA "reword this provision to explain that 'applicable reporting requirements' 

means reporting of information needed to calculate lbs CO2/MWh - i.e., hourly load and any

information used to calculate CO2 mass emissions." Commenter 9666 also noted that all of the 

data needed to calculate compliance already are recorded and reported under Part 75 and there is 

no reason to separately require any reporting under this NSPS until the calendar quarter that 

contains the end of the month that corresponds to the end of the first compliance period.

Response 12.4-1: The final rule incorporates the Commenter 9425’s suggestion to allow the 

electrical output of a common steam turbine to be apportioned to the individual EGUs according 

to fraction of the total steam load or (if the units are identical) based on the fraction of the total 

heat input to the EGUs.

The Agency has also incorporated Commenter 9666’s recommendation to make the Part 75 

reporting requirements more specific, i.e., that 'applicable reporting requirements' means 

reporting of information needed to calculate the CO2 mass emissions.
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EPA agrees with Commenter 9666 that the first submission of a quarterly compliance reports 

should not be required until the initial 12-operating month compliance period has been 

completed. The final rule makes this clear.

New Reporting to ECMPS

Comment 12.4-2: Commenter 9425 asked that "EPA simply require reporting under Part 75. 

The reference to ECMPS is unnecessary and inappropriate."

Response 12.4-2: The EPA disagrees with the commenter and believes it is necessary to call out 

ECMPS as the reporting mechanism in the regulation.

Comment 12.4-3: Commenter 9666 "does not object to reporting once a year the facility's gross 

electric output sold to an electric grid during the year, and the potential electric output of the 

facility."

Response 12.4-3: The EPA thanks the commenter for their comment.

Comment 12.4-4: Commenters 9425 and 9666 asked that the EPA specify that the rule 

determines reporting requirements, not ECMPS. Commenter 9425 noted that the EPA referred to 

"other information" and "other modifications" that are not clearly specified. Commenter 9666 

"would object to any attempt by EPA to use ECMPS to require reporting of any information, 

codes, calculations, or other information that is not identified both in the rule and in an ICR 

approved by OMB."

Response 12.4-4: The EPA disagrees with the commenter and the reporting instructions contains 

“codes” and other instructions that are necessary to allow data to be submitted in a consistent 

manner for data elements that are required by the rule. 

Comment 12.4-5: Commenters 9425 and 9666 commented on aspects of ECMPS that require 

clarification. Specifically, Commenter 9425 noted that CO2 data in ECMPS are reported 

hourly but the rule has a different compliance period. Additionally, commenter 9666 asked that 

the EPA specify reporting of CO2 in lb/MWh rounded to the nearest whole number consistent 

with ASTM rounding conventions and objected to the use of electronic auditing software within 

ECMPS to "impose on reporting facilities any requirements or quality assurance criteria that are 

not identified in the rule."

Response 12.4-5: The final rule specifies hourly reporting of CO2 consistent with 40 CFR part 

75 and the EPA has expanded upon the requirements of reporting as it relates to both the rule and 

part 75 reporting. Compliance will be determined on a 12-operating month rolling average basis 

which is calculated using all of the hourly data reported to ECMPS. Additionally, ECMPS does 

not impose “additional” QA/QC requirements but will provide electronic verification to ensure 

that data reported are consistent with the reporting requirements of the rule.
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Comment 12.4-6: Commenter 9666 noted that §72.21(b)(2) requires that each submission under 

Part 75 be certified by the facility's DR, however this is not defined under Part 60. The 

commenter recommended that EPA modify ECMPS to allow certification for Part 60 data by the 

owner or operator instead of the DR as defined in Part 75.

Response 12.4-6: The final rule requires the DR under 72.2 to make the submissions and the 

EPA believes the final rule clarifies the commenters concern.

Duplicative Reporting

Comment 12.4-7: Commenters 9425 and 9666 asked that the EPA avoid duplicative reporting in 

the rule. Commenter 9425 asked for exemptions from part 60 QA/QC for sources using CEMS 

and to exempt ECMPS reports from the duplicate reporting requirements in §60.4. Additionally, 

Commenter 9666 asked to exempt Subparts Da and KKKK from §60.7(c) and exempt all 

electronic reporting requirements from §60.4.

Response 12.4-7: The EPA is removing the requirement for any reporting under 60.4 that would 

be in duplicate to information that is reported electronically through ECMPS.

Comment 12.4-8: One commenter (9426) stated that reporting CH4 and N2O emissions under 

the NSPS would be duplicative with the GHGRP.

Response 12.4-8: This rule does not require reporting of CH4 and N2O emissions.