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**MEMORANDUM TO**  : Jessica Gordon, Rachel Schmeltz, EPA **FROM** : Donna Lazzari, Jason Renzaglia , Tracy Curtis, ERG **DATE** : September 30 , 2013 **SUBJECT** : Assessment of Emissions and Cost Impacts of Final 2013 Revisions to the

Greenhouse Gas Reporting Rule and Confidentiality Determinations for New or Substantially

Revised Data Elements EPA intends to updat e the Global Warm ing Potentials (GWPs) in Table A - 1 of subpart A to match the GWPs published by the Intergovernmental Panel on Climate Change ( IPCC ) in the 2007 Fourth Assessment Report . Additionally, EPA is finalizing technical corrections and other amendments to 30 subparts of the GHG reporting rule (40 CFR part 98). This memorandum explains how reporters will be affected b y changes to the GWPs in the GHG reporting rule and discusses the impacts of the technical corrections and other amendments. The memorandum is organized as follows: Section 1 .0 : Background and Intro duction for GWP Revisions Section 2 .0 : Id entification of Subparts Affected b y the GWP Revisions in Subpart A Section 3 .0 : Summary

of Impacts and Small Entity Impacts - All Reporters Section 4 .0 : Methodology for Estimating Impacts to Current Reporters Secti on 5 .0 : Methodology for Estimating Impacts to New Reporters Section 6 .0 : Impacts of Other Technical Corrections and Amendments **1.0 BACKGROUND AND INTRO**  **DUCTION FO**  **R GWP REVISIONS** Facilities affected b y the GHG reporting rule must report their GHG emissions to EPA through the electronic Greenhouse Gas Reporting Tool ( e - GGRT ) . In general, t o calculate GHG emissions, reporters us e the GWPs in Table A - 1 to subpart A of the GHG reporting rule. EPA is finalizing updates to the GWPs in Table A - 1 using the GWPs from th e IP CC 2007 Fourth Assessment Report 1 .

1 IPCC, 2007 . Climate Change 2007: Synthesis Report. Contribution of Working Groups I, II and III to the Fourth Assessment. Report of the Intergovernmental Panel on Climate Change [Core Writing Team, Pachauri, R.K and Reisinger, A. (eds.)]. IPCC, Geneva, Switzerland, 1 04 pp2

This section explains how the changes to Table A - 1 will affect reporters. Two kinds of reporters are described in this memorandum :  **Current reporters**  are those reporters that are already subject to the GHG reporting rule and have already reported their emissions to e - GGRT for the year 2010 and 2011 or for only the ye ar 2011 . Emissions data for these reporters is available through the EPA website .  **Ne w reporters**  are those reporters that are not currently affected by

the GHG reporting rule, but would become subject to the rule as a result of the changes to Table A - 1 . **1.1 How GWPs Affect Emissions and Applica**  **bility to the GHG Reporting Rule** A change to the GWP for a GHG will change the calculated emissions or supply of that gas and m ight also change the number of facilities or suppliers that are subject to the GHG reporting rule . Th e number of facilities or suppliers c ould change because f or some subpart s applicability

to the GHG reporting rule is based on the amount of GHG that is either consumed, generated , emitted , imported, or exported over a calendar ye ar, expressed in carbon dioxide equivalent s (CO 2 e). Carbon dioxide equivalent is a metric used to compare the emissions of various GHGs based on their GWP. Because different GHGs have different heat trapping capabilities and atmospheric lifetimes, they are not directly

comparable without translating emissions into a common unit of measure. The GWP is a measure of the total energy that a gas abs orbs over a particular period of time (usuall y 100 years) compared to carbon dioxide, which has a GWP of 1.0. The CO 2 e for a specific gas is derived b y multiplying the mass of the gas b y the associated GWP. For example, methane currently has a GWP of 21. A facility that emits 1,000 tons of CO 2 emits 1,000 tons per year of CO 2 e. A facility that emits 1,000 tons of methane emits 21,000 tons per year of CO 2 e. Based on revised radiative forcing research, the IP CC in the 2007 Fourth Assessment Report updated the GWP values for the following compounds: methane, nitrous oxide, certain hydrofluorocarbons, perfluorinated compounds, and fluorinated ethers, substances controlled b y the Montreal protocol, and certain hydrocarbons and other compounds with direct warming effects. The revised GWP values by IPCC represent an increase in the GWP for methane ( CH 4 ) , a slight decrease for nitrous oxide (N 2 O ) , an increase for 10 f luorinated gases, and a decrease for three fluorinated gases. The GWP for all other GHGs currently on Table A - 1 are unchanged. The GHGs that are covered by the GHG reporting rule are carbon dioxide (CO 2 ), CH 4 , N 2 O, sulfur hexafluoride ( SF 6 ), hydrofluorocarbons, perfluorocarbons, and other fluorinated GHGs (which include fluorinated ethers). The GHG reporting rule does not require reporting of emission s of the Montreal protocol substances or the hydrocarbons with direct effects (dimethylether, methylene chloride, and methyl chloride). Appendix A of this memorandum lists the compounds covered b y the GHG reporting rule along with the original GWPs and the final GWP revisions.3

Currently , some source categories under 40 CFR part 98 provide calculation methodologies and reporting requirements for fluorinated greenhouse gases (F - GHGs ) or fluorinated heat transfer fluids ( F - HTFs ) for which GWPs were not available in the IPCC assessment reports or other scientific assessments at promulgation. The GWPs in Table A - 1 of subpart A are primaril y used for threshold calculations to determine rule applicability (40 C FR 98.2(b)) and for reporting total GHG emissions or supply in CO 2 e for each facility or supplier (40 CFR 98.3(c)(4)). Those F - GHGs or F - HTFs whose GWPs are currentl y not listed in Table A - 1 are not included in threshold calculations for applicability or in the CO 2 e totals reported b y facilities and suppliers , but are instead reported in metric tons of substance emitted or supplied (40 CFR 98.3(c)(4)). Revisions to the GWP s affect the calculation of CO 2 e from facility emissions, and thus any increase in th e GWPs in a threshold anal ys is could cause a given facility or supplier to exceed the emissions reporting threshold , even if the facility did not previously exceed the threshold. A change to a facility ’s reporting status would cause the facility to incur c osts for monitoring, recordkeeping, and reporting emissions. In this memorandum, the impacts of the revis ed GWPs in Table A - 1 to subpart A are evaluated on the emissions reported and on the emissions from new reporters that would be required to report under each subpart if the changes are incorporated into the reporting rule . The compliance costs that would be incurred b y these new reporters are also estimated . The methodology

used to identify

the subparts for which emissions calculated as CO 2 e would ch ange is described in s ection 2 .0 of this memorandum. A summary of cost and emissions impacts due to the revisions is provided in s ection 3.0 . The methodologies used to determine cost and emissions impacts to current reporters are described in s ection 4.0 . The methodologies used to determine cost and emissions impacts to new reporters are described in s ection 5.0 . **2.0 IDENTIFICATION OF SU**  **BP ARTS AFFECTED BY T**  **HE GWP**  **REVISIONS IN SUBPART A**  **2.1 Current**  **Reporters** Current reporters are those reporters that are already affected by

the GHG reporting rule and have already reported their GHG emissions to e - GGRT (or are expected to report their estimated emissions to e - GGRT in the near future ) . Each GHG source category is identi fied in Table 2 - 1 . **Table 2 -**  **1. GHG Reporting Rule Subpart and Source Category Subpart**  **GHG Source Category**  C General Stationary Fuel Combustion Sources D Electricity Generation4 **Table 2 -**  **1. GHG Reporting Rule Subpart and Source Category Subpart**  **GHG Source Category**  E Adipic Acid Production F Aluminum Production G Ammonia Manufacturing H Cement Production I Electronics Manufacturing K Ferroalloy Production L Fluorinated Gas Production N Glass Production O HCFC - 22 Production and HFC - 23 Destruction P Hydrogen Production Q Iron and Steel Production R Lead Production S Lime Manufacturing (non - CEMS) T Magnesium Production U Miscellaneous Uses of Carbonate V Nitric Acid Production W Petroleum and Natural Gas Systems X Petrochemical Production Y Petroleum Refineries Z Phosphoric Acid Production AA Pulp and Paper Manufacturing BB Silicon Carbide Production CC Soda Ash Manufacturing DD Use of Electric Transmission and Distribution Equipment EE Titanium Dioxide Production FF Underground Coal Mines GG Zinc Production HH Municipal Solid Waste Landfills II Industrial Wastewater Treatment JJ Manure Management b LL Suppliers of Coal based Liquid Fuels MM Suppliers of Petroleum Products NN Suppliers of Natural Gas and Natural Gas Liquids OO Suppliers of Industrial Greenhouse Gases PP Suppliers of Carbon Dioxide QQ Importers / Exporters of Equipment Pre - charged with F - GHGs RR Geologic Sequestration of Carbon Dioxide SS Manufacture Electric Transmission and Distribution Equipment TT Industrial Waste Landfills UU Injection of Carbon Dioxide The calculated emissions impacts (due to the revised GWPs) were estimated for current reporters associated with each of the GHG source categories identified in Table 2 - 1 . The revised5

GWP s would have no effect on subparts with CO 2 as the sole GHG (i.e., subparts MM, NN, PP, RR, and UU) because GWP is a measure of the heat trapped b y specific gas(es) as compared to the heat trapped b y CO 2. Actual CO 2 emissions are not converted to CO 2 e, and thus GWP has no bearing on the emissions or supply in these cases. Similarly, although CO 2 , CH 4 , and/or N 2 O combustion emissions are required to be reported for subparts G, R, U, Z, CC, EE, and GG, the sole emission ty

pe reported under these specifi c subparts is CO 2 process emissions (because combustion emissions are required to be reported under subpart C). Therefore, for purposes of this memorandum, any

change to combustion emissions associated with these subparts is incorporated into the impact an al ys is performed on subpart C; and no other impact (due to the revised GWP s ) is identified for these specific subparts. The methodology

used to determine the impact of the revision s to Table A - 1 for current reporters is presented in s ection 4 .0 . **2.2 New Repo**  **rters** New reporters are those reporters that are not affected by the current GHG reporting rule, but will become subject to the rule as a result of revisions to th e GWPs in Table A - 1 . Affected subparts that m ight have new reporters due to revised GWPs are those that meet all three of these criteria: 1) subpart has a reporting threshold 2 and the threshold is based on CO 2 e, 2) subpart requires reporting of emissions of CH 4 , N 2 O, or a F - GHG , and 3) EPA estimates that all facilities in the subpart did not previously exceed the threshold. The subparts that meet these three criteria are subparts I, T, W, HH, II, OO, and TT. The revised GWP s would not create new reporters for subparts that have no threshold, because all applicable facilities are already reporting. Similarly , categories with thresholds not based on CO 2 e would not create new reporters resulting from a revised GWP (e.g., for subpart FF, underground coal mines, the threshold is based on the annual volume of methane liberated from a mine) . Also, if all facilities in the subpart are currentl y expected to exceed the 25,000 metric tons of CO 2 e threshold (based on an evaluation of the supporting documents for each subpart), then it was assumed that there would be no new reporters. In particular, all potential reporters under subpart s K, L, and QQ (importers only) are estimated to exceed the 25,000 metric tons of CO 2 e threshold, so no new reporters are expected for these subparts due to the new and revised GWP s . For subpart QQ (exporters), all facilities are expected to exceed the 25,000 metric tons of CO 2 e threshold with the exception of exporters of SF 6 electrical equipment. No additional SF 6 equipment exporters are expected to exceed the 25,000 metric tons of CO 2 e threshold because the GWP fo r SF 6 is decreasing. The ty pe of emissions required to be reported b y each subpart were also considered . Subparts with CO 2 as the sole emission ty pe were eliminated; the revised GWPs would not

2 For some subparts, all facilities are required to report.6

create new reporters for the se subparts because GWP is a measure of the heat trapped b y specific gas(es) as compared to the heat trapped b y CO 2 . Actual CO 2 emissions are not converted to CO 2 e, and thus GWP has no bearing on the outputs in these cases. Subparts with emissions solely f rom combustion experienced such small impacts from the GWP revisions that they were not expected to trigger any additional reporters . For example, for coal burning, there is only a 0.024% increase in CO 2 e as a result of the change to the GWP of CH 4 and N 2 O emissions resulting from combustion, and for natural gas, there was onl y a 0.005% increase. Table 2 - 2 provides detail for this calculation. **Table 2 -**  **2. Example Emission**  **Calculation for 100 Million BTU /hour**  **Combustion Unit**  **-**

**Comparison of CO2e for Current and Revised GWP**  **Identifier for**  **Me thodology**  **Description and/or Me** **thodology Anthracite Coal**  **Natural Gas A**  CO 2 EF (kg CO 2/mmBTU) 103.50 53.02 **B** CH 4 EF (kg CH 4/mmBTU) 1.10E - 02 1.00E - 03 **C** Current GWP for CH 4 21 **D** Revised GWP for CH 4 25 **E** N 2 O EF (kg N 2 O /mmBTU) 1.60E - 03 1.00E - 04 **F** Current GWP for N 2 O 310 **G** Revised GWP for N 2 O 298 **H** Current CH 4 CO 2 e

( B*C ) 0.231 0.021 **I** Revised CH 4 CO 2 e

( B* D ) 0.275 0.025 **J** Current N 2 O CO 2 e

( E*F ) 0.496 0.031 **K** Revised N 2 O CO 2 e

( E*G ) 0.477 0.030 **L** Current Total CO 2 e

(A+H+J ) 104.23 53.072 **M** Revised Total CO 2 e

(A+I+K) 104.25 53.075 **Percent Change ((** **M -**  **L )/** **L )**  **0.024% 0.005%**  For subpart I, facilities that manufacture semiconductors, liquid crystal display s (LCDs), and micro - electromechanical sy stems (MEMS) must calculate annual emissions for threshold applicability

purposes considering onl y the gases for which default emission factors are provided in Table I - 1 to subpart I. Facilities must account for F - HTF emissions as a percentage of the total annual production process emissions at a facility ( calculated using the default factors in Table I -7

1 ) . Table I - 1 does not include F - GHGs affected by the changes to Table A - 1 , therefore the applicability

for these facilities wil l not change. Table 2 - 3 lists all of the GHG reporting rule subparts and the rationale for including or excluding the subpart in th e new reporter impact analysis described in s ection 5.0 . As noted in Table 2 - 3 all facilities subject to subparts L and QQ are expected to be above the reporting threshold, therefore there are no additional facilities that will be required to report. Emissions of fluorinated gases for subpart DD (Use of Electric Transmissions and Distribution Equipment) and subpart SS (Electric al Equipment Manufacture) were reported as only SF 6 emissions ; therefore, the assignment of GWPs for other F - GHGs would have no effect on reporters under subpart DD and SS. For subpart T (Magnesium Production), the primary gas emitted is SF 6 . Because the GWP for SF 6 is decreasing, the calculated emissions would decrease, and no additional facilities would be required to report as a result. For subpart OO (Industrial GHG Suppliers), EPA identified the potential of three additional reporters due to the revisi ons to the GWPs in Table A - 1. **Table 2 -**  **3 . Rationale for**  **GHG Subpart Selection**  **for New Reporter Impact Analysis Subpart**  **Excluded /**

**Included in New**  **Reporter Impact Analysis**  **Rationale** C - Stationary Combustion Excluded Com bustion emissions only D - Electricity Generation Excluded Threshold not based on CO 2 e E - Adipic Acid Excluded All facilities must report - no threshold F - Aluminum Excluded All facilities must report - no threshold G - Ammonia Excluded All facilities must report - no threshold H - Cement Excluded All facilities must report - no threshold I - Electronics **Included** Threshold category that emits mainly fluorinated GHG K - Ferroalloy Excluded All facilities in subpart expected to be above threshold L - Fluorinated Gas Excluded All facilities in subpart expected to be above thre shold N - Glass Excluded CO 2 and/or combustion emissions only O - HCFC - 22, HFC - 23 Excluded Threshold not based on CO 2 e P - Hydrogen Excluded CO 2 and/or combustion emissions only Q - Iron & Steel Excluded CO 2 and/or com bustion emissions only R - Lead Excluded CO 2 and/or combustion emissions only S - Lime Excluded All facilities must report - no threshold T - Magnesium **Included** Threshold category that emits mainly fluorinated GHG U - Carbonate Excluded CO 2 emissions only V - Nitric Acid Excluded All facilities must report - no threshold W - Petroleum & Natural Gas **Included** Threshold category that emits methane X - Petrochemicals Excluded All facilities must report - no threshold8 **Table 2 -**  **3 . Rationale for**  **GHG Subpart Selection**  **for New Reporter Impact Analysis Subpart**  **Excluded /**

**Included in New**  **Reporter Impact Analysis**  **Rationale** Y - Refineries Excluded All facilities must report - no threshold Z - Phosphoric Acid Excluded All facilities must report - no threshold AA - Pulp & Paper Excluded All facilities in subpart expected to be above threshold BB - Silicon Carbide Excluded All facilities must report - no threshold CC - Soda Ash Excluded All facilities must report - no threshold DD - Electrical Transmission Excluded Threshold not based on CO 2 e EE - Titanium Dioxide Excluded All facilities must report - no threshold FF - Underground Coal Mines Excluded Threshold not based on CO 2 e GG - Zinc Excluded CO 2 and/or combustion emissions only HH - MSW Landfills **Included** Threshold category that emits mostly methane II - Industrial Wastewater **Included** Threshold is based on methane generation JJ - Manure Mgmt Excluded Subpart is not being implemented LL - Coal -based Liquid Fuels Suppliers Excluded CO 2 is the only GHG reported MM - Petroleum Suppliers Excluded CO 2 is the only GHG reported NN - Natural Gas Suppliers Excluded Threshold not based on CO 2 e OO - Industrial GHG Suppliers **Included** Importers/exporters have threshold for fluorinated GHG PP - CO 2 Suppliers Excluded CO 2 is the only GHG reported QQ - Im porters / Exporters of F - gases in pre - charged equipment or closed - cell foams Excluded Threshold category and all importers/exporters in the category are expected to be above threshold a RR - Geologic Sequestration Excluded All facilities must report - no threshold SS - Electrical Equipment Excluded Threshold not based on CO 2 e TT - Industrial Waste Landfills **Included** Threshold is based on methane generation UU - CO 2 Injection Excluded All facilities must report - no threshold a Some facilities with SF 6 containing electrical equipment were below the threshold; SF 6 GWP is decreasing, therefore no additional affected facilities.9

**3.0 SUMMARY OF IMPACTS**  **AND SMALL ENTITY IMP ACTS**  **– ALL**  **REPORTERS 3.1**  **Summary of**  **Em issions and Cost**  **Impacts** The impacts to the quantity of CO 2 e reported and costs resulting from the GWP revisions for each subpart are presented in two tables :

 Ta ble 3 - 1 includes a summary of impacts to the quantity of CO 2 e reported for all reporters ; and  Table 3 - 2 includes a summary of the cost impacts for th e new reporters anticipated . These tables include the estimated changes to the number of affected facilities and expected CO 2 e reported . **Table 3 -**  **1. 2011 Reporters -**  **Summary of Impacts Due to GWP Revisions for Source Categories Reporting in 2011** 

**Subpart Number of**  **Reporters Affected by GWP**  **Revisions a**  **Expected Total**

**CO 2**  **e Reported After GWP**  **Revisions (m**  **etric tons CO 2**  **e per year)**  **b Total Change in** 

**CO 2**  **e Due to GWP Revisions**  **(m etric tons**  **CO 2**  **e per year)** C

– Stationary Combustion 5,426 618,943,387 145,552 D

– Electricity Generation 1,258 2,134,344,533 270,863 E

– Adipic Acid 3 10,200,670 (410,765) F

– Aluminum 10 7,635,878 170,321 G - Ammonia 0 14,012,704 0 H

– Cement 94 52,854,721 4,764 I

– Electronics 53 3,720,318 593,554 K

– Ferroalloy 10 2,280,270 1,913 L

– Fluorinated Gas 16 6,913,066 812,347 N

– Glass 110 2,074,305 4 O

– HCFC - 22, HFC - 23 5 8,771,214 1,837,214 P

– 103 32,958,021 1010 **Table 3 -**  **1. 2011 Reporters -**  **Summary of Impacts Due to GWP Revisions for Source Categories Reporting in 2011** 

**Subpart Number of**  **Reporters Affected by GWP**  **Revisions a**  **Expected Total**

**CO 2**  **e Reported After GWP**  **Revisions (m**  **etric tons CO 2**  **e per year)**  **b Total Change in** 

**CO 2**  **e Due to GWP Revisions**  **(m etric tons**  **CO 2**  **e per year)** Hydrogen Q

– Iron & Steel 128 30,664,338 (28) R

– Lead 0 736,087 0 S

– Lime 73 16,153,152 162 T

– Magnesium 9 2,092,420 (96,541) U

– Carbonate 0 122,216 0 V

– Nitric Acid 36 10,888,395 (438,459) W

– Petroleum & Natural Gas 1,646 158,187,220 18,289,767 X

– Petrochemicals 64 9,302,398 11,872 Y

– Refineries 145 56,471,884 114,025 Z

– Phosphoric Acid 0 1,438,428 0 AA

– Pulp & Paper 110 7,495,513 53,421 BB

– Silicon Carbide 1 139,994 2,398 CC

– Soda Ash 0 1,341,446 0 DD

– Electrical Transmission 97 3,688,839 (177,970) EE

– Titanium Dioxide 0 1,346,279 0 FF

– Underground Coal Mines 146 32,896,721 5,263,475 GG

– Zinc 0 816,621 0 HH

– MSW Landfills 1,259 109,562,567 2,562,567 II

– Industrial Waste water 153 4,499,394 769,883 JJ

– Manure Mgmt 0 0 011 **Table 3 -**  **1. 2011 Reporters -**  **Summary of Impacts Due to GWP Revisions for Source Categories Reporting in 2011** 

**Subpart Number of**  **Reporters Affected by GWP**  **Revisions a**  **Expected Total**

**CO 2**  **e Reported After GWP**  **Revisions (m**  **etric tons CO 2**  **e per year)**  **b Total Change in** 

**CO 2**  **e Due to GWP Revisions**  **(m etric tons**  **CO 2**  **e per year)** LL

– Coal -based Liquid Fuels Suppliers 0 -- c 0 MM

– Petroleum Suppliers 0 -- c 0 NN

– Natural Gas Suppliers 0 -- c 0 OO

– Industrial GHG Suppliers 170 -- c 44,060,000 PP

– CO 2 Suppliers 0 -- c 0 QQ

– Im porters / Exporters of F - gases in pre - charged equipment or closed cell foams 34 -- c -- d RR

– Geologic Sequestration 0 0 0 SS

– Electrical Equipment 5 293,767 (14,173) TT

– Industrial Waste Landfills 192 10,581,216 2,129,795 UU

– CO 2 Injection 0 -- c 0 a Includes ne w reporters who would be required to submit an annual report due to the changes to GWPs in Table A - 1. b Expected total CO 2 e reported includes the change in emissions for existing reporters and from new reporters who would be required to submit an annual report due to the changes to GWPs in Table A - 1 for the source category identified. The expected total CO 2 e reported does not include emissions from reporters who may be required to newly submit an annual report for multiple source categories . c Not included for subparts for which to tals include reporting of CBI. d Not included for subparts for which totals include reporting of CBI. Assume a nominal 1 6 % increase over current CO 2 e reported . This estimated increase equals the average of the percent change in GWP for the HFCs, and PFCs and SF 6 .12 **Table 3 -**  **2. Summary of Cost Impact Due to the GWP Revisions Subpart**  **Number of**

**New Reporters**  **Due to GWP Revisions**  **Incremental CO 2**  **e**

**for New Reporters (m**  **etric tons CO 2**  **e per year)**  **First Year**

**Cost Impact ($/yr)**  **Incremental Cost**

**Impact ($/yr)**  I

– Electronics 4 18,076 12 9,500 237,000 T

– Magnesium 0 0 0 0 W

– Petroleum & Natural Gas 99 2,572,881 1,648,000 772,000 HH

– MSW Landfills a 57 1,560,000 246,000 182,200 II

– Industrial Wastewater 2 59,500 10,800 10,500 OO

– Industrial GHG Suppliers 3 75,000 13,100 10,000 TT

– Industrial Waste Landfills a 19 520,000 112,000 98,050 **Total 184**  **4,805,457 2,195,400**  **1,316,750 a**  Subpart HH cost impact includes average annualized reporting costs for 43 closed landfills that will exit the reporting program later than expected. Similarly, subpart TT cost impact includes average annualized costs for 8 closed facilities. **3.2 Small Entity Impacts**  There will be a cost impact of the change to GWP for new reporters and for closed landfills that will be required to rem ain in the program for a longer period of time ; the cost of reporting will not significantly change for those entities already required to report. A detailed discussion of the cost impact to small entities is included in the individual subpart anal ys es for new reporters in section 5 .0 . For each affected subpart that may have new reporters due to the revised GWPs , information available in supporting documents was used to identify the small businesses affected, and an impact evaluation was performed. F or each subpart evaluated , it was determined that there is not a significant impact on a substantial number of small businesses. **4.0 METHODOLOGY FOR**  **ESTIMATING IMPACTS T O**  **CURRENT REPORTERS 4.1**  **Emissions Impacts**  **(current reporters)** The level of increased calculated CO 2 e that will be reported by existing reporters (due to the revised GWPs) was estimated by adjusting the 2011 reported GHG emissions using the new GWP for each reported compound. The reported emissions of each GHG (CO 2 , CH 4 , N2 O, etc.)13

were extracted from the most recent data reported to EPA (US EPA 2013a). The total number of facilities reporting under each subpart was defined and the total reported emissions of each GHG for each subpart were calculated. The total reported mass emissions of each GHG were multiplied by

the current GWP (see 40 CFR part 98, subpart A, Table A - 1) to determine the original reported emissions of each GHG in metric tons of CO 2 e. To calculate the emissions impacts in metric tons of CO 2 e (due to the revised GWPs) for each source category , the mass emissions for each GHG were multiplied by the difference between the existing GWP and the revised GWPs from the IPCC AR4 . For some subparts, Table 3 - 1 shows no change in the expected CO 2 e reported emissions from the changes to the GWPs . A lthough CO 2 , CH 4 , and N 2 O combustion emissions are required to be reported for subparts G, R, U, Z, CC, EE, and GG, the sole emission ty

pe reported under these specific subparts is CO 2 process emissions (because combustion emissions are required to be reported under subpart C and there are no CH 4 or N 2 O process emissions for these subparts ). Therefore, for purposes of this anal ys is , any change to combustion emissions associated with the se subparts is incorporated into the impact anal ys is performed on subpart C; and no other impact (due to the revised GWP s ) is identified for these specific subparts. For several subparts that report fluorinated gases, emissions information was not availab le for the individual compounds. Emissions estimates for these subparts are discussed in more detail in sections 4. 1.1 and 4. 1.2 . **4.1.1 Subpart I**  **Emissions Impacts**  **(current reporters)** In the original threshold anal ys is (U.S. EPA, 2010a), EPA identified the number of facilities that would be covered under subpart I with a 25,000 metric tons CO 2 e emissions - based threshold. For LCDs and PVs, EPA calculated the total annual emissions, in metric tons of CO 2 e , for each facility

using the IPCC Tier 1 default emissions factors. The emissions factors were converted to metric tons of CO 2 e basis by multiplyingthe factors b y the appropriate GWP value. EPA used the results to estimate the magnitude of emissions from those facilities expected to emit greater than the 25,000 metric tons CO 2 e threshold. The number of, and emissions from, MEMS facilities were calculated using the same procedure, but with an emission factor developed b y the EPA (U.S. EPA, 2010b). In the original anal ys is, EPA used the same procedure described ab ove (i.e., default IPCC Tier 1 factors) to determine the number of semiconductor facilities that were expected to emit greater than the 25,000 metric tons CO 2 e threshold. To estimate the magnitude of emissions from those semiconductor facilities expected to emit greater than the threshold, EPA used emission estimations that were derived using outputs from the EPA PFC Emissions Vintaging Model (PEVM), as well as the EPA PFC Reduction/Climate Partnership for Semiconductors partner and non -partner shares of U. S. emissions. EPA also accounted for heat transfer fluid emission14

estimates by

assuming such emissions were equal to 11 percent of total clean and etch emissions at a facility . To determine the level of increased emissions that will be reported b y existing reporters under subpart I due to the revised GWPs , the methodology from EPA’s original threshold anal ys is was followed, but with the updated GWP values. The PEVM was not accessible to reproduce the original emission estimates; therefore, it was assumed that the PEVM based emissions would increase by the same percentage as the emissions estimated using the IPCC Tier 1 default factors and updated GWP values. This is a valid assumption because no other inputs to the PEVM are expected to change. The overall increase in emissions for this subpart is estimated at approximately 18.4 percent above the 2011 reported emissions. **4.1.2 Subpart L and QQ Emissions Impacts (current reporters)**  Because there are 17 different fluorinated compounds for which the GWP will change by varying amounts, and a breakdown of emissions by compound was not available for subpart Lor QQ , a nominal 1 6 percent increase was estimated as the expected increase in emissions due to revised GWP s for SF 6 , HFCs, and PFCs . This estimated increase equals the average of the percent change in GWP for the HFCs, and PFCs and SF6 for compounds listed in Table A - 1 . **4.2 Cost Impacts (current reporters)**  For reporters th at currently are subject to the rule for reporting, there would be no significant cost impacts resulting from the revised GWPs , with the exception of landfills expected to close after 2014 for subparts HH and TT (see the discussion in section 5 .4 and section 5 .7 for subpart HH and TT , respectivel y) . Although some affected facilities and suppliers would report higher CO 2 e emissions in their annual GHG report, using the revised GWPs would not affect the cost of monitoring and recordkeeping and would not materially affect the cost for calculating emissions . **4.3 References for**  **Section 4**  **.0** U.S. EPA, 201 3 a. 201 1 Greenhouse Gas Reporting Program Data ( reported to EPA by facilities as of February 17, 2013 ) . U.S. EPA, 2012b. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990 - 2010, April 2012. http://epa.gov/climatechange/Downloads/ghgemissions/US - GHG - Inventory - 2012 - Main - Text.pdf U.S. EPA, 2010 a . Subpart I Detailed Threshold Analysis. See Docket ID: EPA - HQ - OAR - 2009 - 0927 - 0158. November 2010. U.S. EPA, 2010b . Technical Support Document for Process Emissions from Electronics Manufacture (e.g., Micro - Electro - Mechanical Systems, Liquid Crystal Displays, Photovoltaics, and Semiconductors): Proposed Rule for Mandatory Reporting of Greenhouse Gases. Revised November 2010. Available at: http://www.epa.gov/climatechange/emissions/downloads10/Subpart - I_TSD.pdf15

**5.0 METHODOLOGY**  **FO R**  **ESTIMATING IMPACTS T O**  **NEW REPORTERS** The methodologies u sed to determine cost and emissions impacts to new reporters ( due to the revised GWPs in Table A - 1 to subpart A) are described in this section . Summaries of the methodology , reference documents, and any assumptions specific to each subpart (that are identi fied as not currently being affected by

the GHG reporting rule, but will become subject to the rule as a result of revisions to the GWPs in Table A - 1) are documented in the following individual subpart subsections. Each of these individual subpart subsections are further organized into smaller sections that discuss the following topics : identifying new reporters; estimating emissions impacts; estimating cost impacts; small entities impacts; summary of impacts; and references . **5.1 Subpart I**  Subpart I requires reporting of fluorinated GHGs from the following source categories that emit 25,000 metric tons CO 2 e per year or more: e lectronics manufacturing including manufacture of semiconductors , PVs , LC Ds, and MEMS. Changes to the fo llowing GWPs affect subpart I : CF 4 , C 2 F 6 , CHF 3 , C 3 F 8 , SF 6 , C 6 F 14 (semiconductors); SF 6 (MEMS); CF 4 , SF 6 (LCDs); and CF 4 , C 2 F 6 (PVs). As discussed in section 2.2 , subpart I reporters must calculate annual emissions for threshold applicability purposes cons idering onl y the gases for which default emission factors are provided in Table I - 1. Although facilities must also account for F - HTF emissions, these emissions are estimated as a percentage of the total annual production process emissions at a facility

(ca lculated based on gases in Table I - 1). **5.1.1 Subpart I**  **(identifying new reporters)** In the original threshold anal ys is (U.S. EPA, 2010a), EPA identified the number of facilities that would be covered under subpart I with a 25,000 metric tons CO 2 e emissions - based threshold. The original threshold anal ys is included a list of facilities for each product ty pe (i.e., semiconductors, MEMS, LCDs, and PVs) and estimates of substrate area processed and total annual emissions for each facility . For LCDs and PVs, EPA calculated the total annual emissions, in metric tons of CO 2 e , for each facility

using the IPCC Tier 1 default emissions factors. The emissions factors were converted to metric tons of CO 2 e basis by multiplyingthe factors b y the appropriate GWP value. EPA evaluated the results to determine which facilities were expected to emit greater than the 25,000 metric tons CO 2 e threshold. EPA also used the results to estimate the magnitude of emissio ns from those facilities expected to emit greater than the 25,000 metric tons CO 2 e threshold. The number of, and emissions from, MEMS facilities were calculated using the same procedure, but with an emission factor developed by the EPA (U.S. EPA, 2010b).16

In the original threshold anal ys is, EPA used the same procedure described above (i.e., default IPCC Tier 1 factors) to determine the number of semiconductor facilities that were expected to emit greater than the 25,000 metric tons CO 2 e threshold. EPA did n ot consider emissions from heat transfer fluids when determining which semiconductor facilities would meet the threshold. To estimate the magnitude of emissions from those semiconductor facilities expected to emit greater than the threshold, EPA used emiss ion estimations that were derived using outputs from the EPA PEVM, as well as the EPA PFC Reduction/Climate Partnership for Semiconductors partner and non -partner shares of U.S. emissions. EPA also accounted for heat transfer fluid emission estimates by as suming such emissions were equal to 11 percent of total clean and etch emissions at a facility . To determine the additional number of facilities that would meet the threshold due to changes to the GWP values in subpart A , the methodology from EPA’s origin al threshold anal ys is was followed, but with the updated GWP values. The PEVM was not accessible to reproduce the original emission estimates; therefore, it was assumed that the PEVM based emissions would increase by the same percentage as the emissions es timated using the IPCC Tier 1 default factors and updated GWP values. This is a valid assumption because no other inputs to the PEVM are expected to change. Table 5 - 1 identifies the number of new subpart I reporters that will become subject to the rule as a result of revisions to the GWPs in Table A - 1. **Table 5 -**  **1. New Subpart I Reporters Facility Type**  **Number of New Reporters Due to GWP Revisions**  Large Semiconductor 0 Non - Large Semiconductor 4 Non - Semiconductor 0 **Total 4**  **5.1.2 Subpart I**  **(estimating em**  **issions i mpacts**  **)** An emissions increase would be expected from new subpart I reporters that will become subject to the rule as a result of revisions to the GWPs in Table A - 1 . This emissions increase was determined using the methodology from EPA’s original threshold anal ys is (U.S. EPA, 2010a), but with the updated GWP values. Itwas assumed that the PEVM - based emissions would increase b y the same percentage as the emissions estimated using the IPCC Tier 1 default factors and updated GWP values. Table 5 - 2 identifies the emissions impact from new subpart I reporters.17 **Table 5 -**  **2. Emissions Impact From New Subpart I Reporters**  **Facility Type Incremental CO**  **2 e Emissions for New Reporters**  **(m etric tons of CO**  **2 e per year )**  Large Semiconductor - Non - Large Semiconductor 18,100 Non - Semiconductor - **Total 18,100**  **5.1.3 Subpart I**  **(estimating cost i mpacts**  **)** Costs were calculated b y multiplying the average costs per facility and the number of new facilities estimated to be subject to subpart I (from revising the GWPs). Average costs per facility were calculated by

dividing total cost by

the number of respondents identified in the most recent information collection request for the GHG reporting program (U.S. EPA, 2013). Appendices J and L to the most recent information collection request for the GHG reporting program (U.S. EPA, 2013) were used to obtain first year average cost per facility that is incurred from reporting under subpart I. Cost details from Exhibit 6 .1 of the most recent information collection request for the GHG reporting program (U.S. EPA, 2013) were used to determine the subsequent years average cost per facility . These average costs per facility include labor costs (i.e., the cost of labor b y facility staff to meet the rule’s information collection requirements) and non - labor (capital , and operation and maintenance ) costs. Additional details of the data, methods, and assumptions underlying these costs are documented in the most recent information collection request (U.S. EPA, 2 01 3 ). Table 5 - 3 shows first and subsequent year average cost per facility subject to subpart I. **Table 5 -**  **3. Annual Average Cost Per Facility Subject to Subpart I Subpart**  **Total Number**

**of Respondents**  **a Total Cost**  **(2011$ per year) Cost Per Facility**  **(2011$ per year)**  **First Year b**  **Subsequent**

**Years a**  **First Year b**  **Subsequent Years**  **a** I

– Electronics 94 3,042,000 5,567,000 32,400 59, 2 00 a This data was extracted from Exhibit 6 .1 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013). EPA is currently updating certain provisions of subpart I. Those updates are reflected in the ICR for that rulemaking effort. b T he first year total cost are from the current cost & burden table identified as “First - Year Burden & Cost” in Appendix J - 3 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013) and includes $80.91 from the current burden & cost table identified as “First Reporting Year” table of Appendix L - 2 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013). The $80.91 is the cost contributed to provisions of information on parent companies, NAICS codes, and whether emissions are from cogeneration. These costs were updated to 2011 dollars using the Bureau of Labor Statistics Employment Cost Index and the Chemical Engineering Plant Cost Index (CEPCI).18

By revising the GWP values in subpart A, four additional non - large semiconductor facilities will be required to report under subpart I . The first year cost for these four facilities will be approximately

$12 9 ,500 per year (4 x $ 32, 365 = $ 12 9 , 500 ), and the annualized industry wide cost is approximately

$ 237,000 per ye ar (4 x $59,2 00 = $ 236,800 ) . Because EPA has recently published the “Final Amendments and Confidentiality Determinations for Subpart I” ( signed by the Administrator on August 16, 2013 ), it is assumed that the costs presented above are overl y conservative. The final amendments to subpart I are expected to reduce the cost to reporters. The updated costs for subpart I have been submitted for approval to the Office of Managem ent and Budget. **5.1.4 Subpart I Small Entity Impacts (new reporters)**  In the subpart I Economic Impact Analysis (U.S. EPA, 2010c), EPA originally assessed the impact of compl ying with subpart I requirements on all small entities in the electronics manufacturing industry

by calculating a cost - to - sales ratio for six enterprise size ranges (i.e., 1 to 20 employees, 20 to 99 employees, 100 to 499 employees, 500 to 749 employees, 750 to 999 employees, and 1,000 to 1,499 employees) using the average total annualized mandatory reporting costs to the average annual sales receipts for each establishment. The results of this anal ys is are represented in Table 14 of the preamble for the publication of the subpart I rule (75 FR 74811, December 1, 2010). Based on this analy sis, EPA concluded that subpart Iwill not have a significant economic impact on a substantial number of small entities (U.S. EPA, 2010c) 3 . EPA made this determination assuming that all entities in the industry would report (including those above and below the reporting threshold), resulting in a conservativel y high anal ys is. EPA determined that no significant small business economic impacts were expected to occur. The anal ys is showed that the cost - to - sales ratio for all entity sizes except for the smallest siz ed enterprises was less than 1 percent. EPA concluded that although the cost - to - sales ratio for the 1 to 20 employee range for semiconductor and related device manufacturing was greater than one percent (i.e., 1.16 percent); facilities with emissions greater than 25,000 metric tons CO 2 e per ye ar are unlikely to be included in the 1 to 20 employees size category (U.S. EPA, 2010c). The revised emission estimates (using the revised GWPs) place the 4 new affected facilities above the 25,000 metric tons CO 2 e threshold. In addition, the emission estimates for the 4 facilities in the original threshold anal ys is were just slightly below the threshold (3 to 10 percent). Based on EPA’s conclusion that facilities with emissions greater than 25,000 metric tons CO 2 e per ye ar are unlikely to be included in the 1 to 20 employees size category , the 4

3 Refer to Section 5.3 of the 2010 EIA (U.S. EPA, 2010a).19

additional facilities are not expected to be included in the 1 to 20 employees size category either. As a result, the changes to the GWPs will not have a significant impact on a substantial number of small entities. **5.1.5 Subpart I**  **(summary of i mpacts**  **)** Table 5 - 4 summarizes the impacts of updating the GWP values in Table A - 1 to subpart A, on new facilities required to report subpart I emissions. **Table 5 -**  **4. New Reporters —**  **Summary of Subp art I Impacts Due to the Revisions to GWPs**  **Facility Type Number of New**  **Reporters Due to GWP**  **Revisions Incremental** 

**CO 2**  **e Emissions for New**  **Reporters (m**  **etric tons of CO**  **2 e per year )**  **a Incremental Cost Impact For New**  **Reporters (2011$ per year)**  **First Year a**  **Subsequent**

**Years a**  Large Semiconductor 0 - - - Non - Large Semiconductor 4 18,100 12 9 , 6 00 237,000 Non - Semiconductor 0 - - - **Total 4**  **18,100 12**  **9 ,**  **6 00**  **237,000** a Values rounded. **5.1.6 References for Subpart I**  U.S. EPA, 2010 a . Subpart I Detailed Threshold Analysis. See Docket ID: EPA - HQ - OAR - 2009 - 0927 - 0158. November 2010. U.S. EPA, 2010b. Technical Support Document for Process Emissions from Electronics Manufacture (e.g., Micro - Electro - Mechanical Systems, Liquid Crystal Displays , Photovoltaics, and Semiconductors): Proposed Rule for Mandatory Reporting of Greenhouse Gases. See Docket ID: EPA - HQ - OAR - 2009 - 0927 - 0195. Revised November 2010. U.S. EPA, 2010c. Economic Impact Analysis for the Mandatory Reporting of Greenhouse Gas Emissi ons F - Gases: Subparts I, L, DD, QQ, SS Final Report. See Docket ID: EPA - HQ - OAR - 2009 - 0927 - 0179. November 2010. U.S. EPA, 2013. Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program. OMB Control No. 2060 - 0629 . EPA ICR No. 2300.10 . May 2013. **5.2 Subpart T**  Magnesium production and processing facilities are defined as any site where magnesium metal is produced through smelting (including electroly tic smelting), refining, or remelting operations, or any site where molten magnesium is used in alloying, casting, drawing, extruding, forming, or rolling operations. Each facility must report total annual emissions for each of the following cover or carrier gases used in magnesium production or processing: SF 6 , HFC - 134a, the fluorinated ketone FK 5 - 1 - 12, CO 2 , and any other fluorinated GHG as defined in the greenhouse gas reporting rule.20

**5.2.1 Subpart**  **T (identifying new reporters)**  In the 2010 Threshold Analysis for the magnesium production category for the original rule (U.S. EPA, 2009), EPA identified 13 nationwide facilities in the magnesium production and processing source category . EPA evaluated a range of threshold options for these facilities, utilizing 2006 annual reporting data on metal production and SF 6 consumption provided through the EPA’s SF 6 Emission Reduction Partnership for the Magnesium Industry as the basis for the anal ys is. These included emission - based thresholds of 1,000, 10,000, 25,000 and 100,000 metric tons CO 2 e , as shown in Table 5 - 5 , and capacity- based thresholds equivalent to these. The July 12, 2010 final rule established an emissions threshold of 25,000 metric tons CO 2 e , which was estimated to cover all currently operating U.S. primary

and secondary

magnesium ingot producers and most di e casters, accounting for over 99 percent of emissions from these source categories. This threshold anal ys is excluded small die casting facilities as well as facilities that performed other types of casting, which represent only a small fraction of total emissions from this source category . The emissions threshold of 25,000 metric tons CO 2 e established in the final rule was equal to emissions of 1,046 kg of SF 6 ; 19,231 kg of HFC

– 134a; or 25,000,000 kg of CO 2 (based on the GWP values established in Table A - 1 to subpart A of part 98) (U.S. EPA, 2009). **Table 5 -**  **5. Threshold Analysis for Subpart T –**  **Ma gnesium Production**  **Emission Threshold**  **Level (m etric**  **tons CO**  **2 e/yr)**  **Total**

**National Emissions**  **(m etric tons**  **CO 2**  **e/yr) Total** 

**Number of Facilities**  **Emissions Covered Facilities Covered** 

**metric tons CO**  **2 e/yr**  **Percent Facilities**  **Percent** 1,000 3,200,000 13 2,954,559 92% 13 100.0% 10,000 3,200,000 13 2,939,741 92% 11 85.0% 25,000 3,200,000 13 2,939,741 92% 11 85.0% 100,000 3,200,000 13 2,872,982 90% 9 69.0% Facility- level information from the threshold analy sis for the 2010 final rule was not published in Docket No. EPA

–HQ

–OAR

–2008

–0508 due to confidentiality concerns. Therefore, for purposes of this memorandum, the incremental impacts to the magnesium produc tion industry were estimated based on the available aggregate data. In order to estimate the source category impacts from revising the GWP s in Table A - 1 to subpart A of part 98 , the 2004 GWPs reflected in Table A - 1 to subpart A were compared to the revised GWPs to determine the increase for each reported pollutant . Only SF 6 and HFC - 134a have been evaluated for the purposes of estimating the impacts of the revised GWPs. Table 5 - 6 lists the pollutants and associated increase in GWP for each chemical. Emissio ns of the fluorinated ketone FK 5

– 1

– 1 2, although required to be reported21

under 40 CFR 98.202, are not included in this threshold analysis , because this gas has a GWP of 1.8 and is not expected to significantl y impact reported emissions . **Table 5 -**  **6. Increas e in GWP for Pollutants Associated with** 

**Magnesium Production and Processing Pollutant Nam**  **e CAS No.**  **Chemical formula GWP in Table A**  **** **1 of the final rule New GWP**  **% Increase** FK- 5 - 1 - 12 756 - 13 - 8 C 3 F 7 C(O)C 2 F 5 NA 1.8 - HFC

– 134a 811

–97

–2 CH 2 FCF 3 1,300 1,430 10 SF 6 2551

– 62

–4 SF 6 23,900 22,800 - 5 As shown in Table 5 - 6 , emissions from facilities utilizing SF 6 that meet the current 25,000 metric tons CO 2 e threshold would decrease as a result of the revised GWP for SF 6 . For these facilities, this decrease would be significant only if the revisions to the GWP reduced their annual emissions to less than 25,000 metric tons CO 2 e for 5 consecutive years (per 40 CFR 98.2(i)). Therefore, the impacts of these emissions reductio ns were not assessed in this memorandum. Facilities utilizing the cover gas HFC - 134a could potentially become subject to the GHG reporting rule if the increase in the GWP brought facility- wide emissions above 25,000 metric tons CO 2 e . This would include onl y facilities with current total facility emissions between 22,500 metric tons CO 2 e and 25,000 metric tons CO 2 e . The aggregate data from the 2010 Threshold Analysis showed that the 11 facilities exceeding the 10,000 metric tons CO 2 e threshold also exceeded the 25,000 metric tons CO 2 e threshold (see Table 5 - 5). Based on these data, there would be no facilities meeting the 10,000 metric tons CO 2 e threshold that would be affected by the revised GWPs, because these facilities already exceed the 25,000 metric tons CO 2 e threshold . Only two facilities not meeting the 25,000 metric tons CO 2 e threshold could potentially be affected by

an increase in the GWP s; these two facilities did not exceed the 10,000 metric tons CO 2 e threshold at the time subpart T was finaliz ed in July

2010 , therefore it is unlikely that these facilities would exceed 25,000 tons CO 2 e per year with the GWP change. Updated data from the SF 6 Emission Reduction Partnership program 4 for the 2010 reporting year were used to verify the conclusion that no additional facilities will be impacted by the revised GWPs. EPA operated the SF 6 Emission Reduction Partnership to encourage industry to reduc e emissions of SF 6 and eliminate the usage of SF 6 as a cover gas. As a result, facilities have increased usag e of FK 5

– 1

– 1 2 (proposed GWP =1.8 ) and HFC - 134a (proposed GWP=1,430) as cover gases, resulting in an overall reduction in industry GHG emissions . Facilities reporting under the SF 6 Emission Reduction Partnership include major emitters. Non - 4 See EPA’s SF6 Emission Reduction Partnership for the Magnesium I ndustry at: http://www.epa.gov/highgwp/magnesium - sf6/index.html22

reporting facilities include smaller facilities (e.g., sand casting or small die casters) whose emissions are expected to be less than the threshold reporting level. The Partnership data is limited because not all facilities consistently report gas use each year; additionally, process data reported under the Partnership has historically been considered confidential. For this anal ys is, only aggregate facility- level emissions based on SF 6 usage were available; emissions data from other gas usage were not available . Based on the 2010 SF 6 Partnership data, 16 facilities reported , and 11 facilities reported use of SF 6 . This is close to the original estimate of 13 processing facilities in the 2010 Threshold Analy sis , which was based on 2006 emission estimates . The reported 2010 SF 6 emissions are summarized in Table 5 - 7 .

**Table 5 -**  **7. 2010 SF 6**  **Em issions Reported through the SF6 Partnership**  **Total Number of Facilities**  SF 6 Emissions Level (metric tons CO 2 e/yr) **Facilities Meeting SF 6**  **Em ission**  **Level** 16 0 - 999 16 1,000 - 9,999 11 10,000 - 22,499 9 22,500 - 24,999 9 25,000 - 99,999 7 >100,000 3 For the purposes of this analy sis, it was assumed that the 11 facilities reporting SF 6 usage through the EPA’s SF 6 Magnesium Partnership are using FK 5

– 1

– 1 2, HFC - 134a, or alternative cover gases in addition to the SF 6 reported. Five facilities reported no emissions of SF 6 ; these facilities are assumed to have used onl y alternative gases, such as HFC - 134a or FK 5

– 1

– 1 2, for all production in 2010. Total SF 6 emissions reported through the Partnership showed a 67% reduction in emissions from 2006. Based on the Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990 - 20 12 (U.S. EPA, 2012 ) , emissions of SF 6 from magnesium production and processing in the United States were estim ated to be 1.3 million metric tons CO 2 e in 2010, a reduction from 3.2 million metric tons CO 2 e in 2006. Therefore, it is anticipate d that the emissions estimates summarized in Table 5 - 7 are a reasonable representation of gas usage in the industry following the 2010 Threshold Anal ys is. There is no available data on the total gas consumption of the alternative cover gases HFC - 134a or FK - 5 - 1 - 12. However, the field of potential reporters was examined to determine if it could be affected if HFC - 134a usage were increased. Without data on HFC - 134a usage, it is unclear whether the five facilities that did not report SF 6 emissions to the SF 6 Partnership currentl y exceed or could exceed the 25,000 metric tons CO 2 e threshold. However, because the GWP s of HFC - 134a (new GWP=1,430) and FK - 5 - 1 - 12 (prop osed GWP=1.8) are significantly lower than that of SF 6 (new GWP = 22,800), facilities converting production gases entirel y from SF 6 to entirely

HFC - 134a or FK- 5 - 1 - 12 would need to use significantly more cover gas to23

exceed the threshold. For example, a fac ility would need to use approximately 16 times more HFC - 134a as a cover gas in production to meet the 25,000 metric tons CO 2 e threshold than if SF 6 were used . Furthermore, the 2010 Partnership Data show the largest - emitting facility to have maximum SF 6 emi ssions of ~386,000 metric tons CO 2 e . Assuming that total gas usage rates remain ed the same, if this facility were to convert all production gases to HFC - 134a, the maximum GHG emissions would be just under the 25,000 metric tons CO 2 e threshold (386,000 * [1 ,430/22,800] = 24,200) . Similarly, if this facility were to convert all production gases to FK - 5 - 1 - 12, the maximum GHG emissions would under 31 metric tons CO2e (386,000 *[1.8/22,800]= 30.5). Therefore, facilities utilizing the cover gas FK- 5 - 1 - 12 are unlikel y to exceed the 25,000 metric tons CO 2 e threshold. Therefore, it is anticipate d that the remaining facilities do not likely use sufficient HFC - 134a or FK- 5 - 1 - 12 to meet or exceed th e 25,000 metric tons CO 2 e threshold , and the total number of facilities required to report w ould not be affected due to the revised GWPs . The total number of facilities reporting under subpart T is expected to decrease over time due to the conversion of co ver gas from SF 6 to HFC - 134a or FK 5

– 1

– 1 2 . Table 5 - 8 identifies the number of new subpart T reporters that will become subject to the rule as a result of revisions to the GWPs in Table A - 1 . **Table 5 -**  **8. New Subpart T Reporters Facility Type**  **Number of New R eporters Due to**  **GWP Revisions** T

– Magnesium 0 **5.2.2 Subpart**  **T (estimating emissions i**  **mpacts )**  Because there are no new facilities anticipated to be affected b y the revised GWPs, there is no emissions impact from new subpart T reporters. Table 5 - 9 identifies the emissions impact from new subpart T reporters. **Table 5 -**  **9. Emissions Impact From New Subpart T Reporters**  **Facility Type Incremental CO**  **2 e Emissions for New Reporters**  **(m etric tons of CO**  **2 e per year )**  T

– Magnesium 0 **5.2.3 Subpart**  **T (estimating cost i**  **mpacts )**  Costs were calculated b y multiplying the average costs per facility and the number of new facilities estimated to be subject to subpart T (from revising the GWPs). Average cost per facility for the first year was calculated by dividing total cost b y the number of respondents identified in the initial information collection request for subpart T (U.S. EPA, 2010). Average24

cost per facility

for subsequent years was calculated by dividing total cost by

the number of respondents identified in the most recent inf ormation collection request for the GHG reporting program (U.S. EPA, 2013). Appendix A to the initial information collection request for subpart T (U.S. EPA, 2010) was used to obtain first year average cost per facility that is incurred from reporting under subpart T. Cost details from Exhibit 6 .1 of the most recent information collection request for the GHG reporting program (U.S. EPA, 2013) were used to determine the subsequent years average cost per facility . These average costs per facility include la

bor costs (i.e., the cost of labor b y facility staff to meet the rule’s information collection requirements) and non - labor (capital , and operation and maintenance ) costs. Additional details of the data, methods, and assumptions underlying these costs are documented in the information collection requests (U.S. EPA, 201 0 and U.S. EPA, 201 3 ). Table 5 - 10 shows first and subsequent year average cost per facility subject to subpart T . **Table 5 -**  **10. Annual Average Cost Per Facility Subject to Subpart T Subpart**  **Total Number**

**of Respondents**  **a Total Cost**  **(2011$ per year) Cost Per Facility**  **(2011$ per year) First Year**  **b Subsequent** 

**Years a**  **First Year b**  **Subsequent Years**  **a** T

– Magnesium 11 123,000 124,000 11, 1 00 11, 300 a This data was extracted from Exhibit 6 .1 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013). b This data wa s extracted from the “Year 1” table of Appendix A to the initial information collection request for subpart T (U.S. EPA, 2010) . These costs were updated to 2011 dollars using the Bureau of Labor Statistics Em ployment Cost Index and the Chemical Engineering Plant Cost Index (CEPCI). The change of GWP for HFC - 134a from 1,300 to 1,400, the change of GWP for SF 6 from 23,900 to 22,800, and the proposed, but not finalized, addition of a GWP of 1.8 for FK - 5 - 1 - 12 is not anticipated to result in additional facilities subject to subpart T. Therefore, there are no significant rule implementation costs associated with th e amendment (0 x $11,272 = $ 0). **5.2.4 Subpart T Small Entity Impacts (new reporters)**  Since it is estimated that no new subpart T entities will be required to report as a result of revisions to the GWPs in Table A - 1 , it is anticipate d that there is not a signific ant impact on a substantial number of small entities subject to reporting under subpart T as a result of this action. **5.2.5 Subpart**  **T (summary of i**  **mpacts )**  Table 5 - 11 summarizes the impacts of updating the GWP values in Table A - 1 to subpart A, on new facilities required to report subpart T emissions.25 **Table 5 -**  **11. New Reporters —**  **Summary of Subpart T Impacts Due to the Revisions to GWPs Facility Type**  **Number of New Reporters Due to**  **GWP Revisions Incremental CO**  **2 e** 

**Emissions for New Reporters**  **(m etric tons of**  **CO 2**  **e per year )**  **Incremental Cost**

**Impact For New Reporters**  **(2011$ per year)** T

– Magnesium 0 0 0 **5.2.6 References for Subpart T**  U.S. EPA, 2009. Additional Methodological Information Supporting Threshold Analysis for Specific Source Categories. See Docket ID No. EPA - HQ - OAR - 2008 - 0508 - 0046. March 2009. U.S. EPA, 2010. Supporting Statement Part A: Information Collection Request for the Mandatory Reporting of Greenhouse Gases from Magnesium Production, Underground Coal Mines, Industrial Wastewater Treatment, and Indus trial Waste Landfills

– Final Rule. OMB Control No. 2060 - 0647. EPA ICR No. 2396.01. July 2010. U.S. EPA, 2012. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990 - 2012. April 15, 2012. US EPA #430 - R - 12 - 001. U.S. EPA, 2013. Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program. OMB Control No. 2060 - 0629 . EPA ICR No. 2300.10 . May 2013. **5.3 Subpart W**  Subpart W requires petroleum and natural gas facilities to report annual CH 4 , CO 2 , and N 2 O emissions from spe cific source types that are dependent upon the industry segment . The industry segments include: NG Processing, NG Transmission, Underground NG Storage, LNG Storage, LNG Import/Export, NG Distribution, Onshore Production, and Offshore Production. **5.3.1 Subpart**  **W (identifying new reporters)**  The facility

and source specific emissions data used to develop the subpart W Economic Impact Anal ys is (U.S. EPA. 2010 ) was used t o identify the additional subpart W facilities that may be required to report using the revised GWP s. Subpart W requires emissions reporting for CO 2 , CH 4 , and N 2 O; therefore, the incremental cost impacts due to the revised GWP were evaluated for onl y these compounds. The GWP for CO 2 remains the same. The GWP for CH 4 is increasing b y 19%. The GWP for N 2 O is decreasing b y 4%. These GWP changes were applied to the source specific emissions data for each subpart W facility to identif y the additional facilities that would be required to report under the new GWPs. Table 5 - 12 identifies the number of new subp art W reporters ( for each subpart W industry

segment) that will become subject to the rule as a result of revisions to the GWPs in Table A - 1 .26 **Table 5 -**  **12. New Subpart W Reporters by Industry Segment Subpart W Industry Segm**  **ent Number of New Reporters Due to**  **GWP Revisions**  NG Processing 2 NG Transmission 7 Underground NG Storage 6 LNG Storage 2 LNG Import/Export 0 NG Distribution 16 Onshore Production 52 a Offshore Production 14 **Total (8 Segm ents)**  **99** a Conservatively assumes that all emissions related to non - combustion sources are methane, and all emissions related to combustion sources are carbon dioxide. **5.3.2 Subpart**  **W (estimating emissions i**  **mpacts )**  Table 5 - 13 identifies the emissions impact from new subpart W reporters by industry segment. The em issions estimates are based on the facility and source specific emissions data used to develop the subpart W Economic Impact Analysis (U.S. EPA. 2010 ) . For LNG storage and NG distribution, the incremental expected emissions were estimated to be 450,000 metric tons CO 2 e by

calculating the number of new facilities in these two industry segments (2+16 = 18) by 25,000 metric tons CO 2 e because it was assumed these facilities would only just meet the 25,000 metric tons CO 2 e reporting threshold.

**Table 5 -**  **13. Em issions Impact From** **New Subpart W Reporters Subpart W Industry Segm**  **ent Incremental CO**  **2 e Emissions for New Reporters**  **(m etric tons of CO**  **2 e per year )**  NG Processing 52,067 NG Transmission 177,091 Underground NG Storage 158,286 LNG Storage 50,000 LNG Import/Export 0 NG Distribution 400,000 Onshore Production 1,372,641 Offshore Production 362,796 **Total (8 Segm ents)**  **2,572,881 5.3.3**  **Subpart W**  **(estimating cost i mpacts**  **)** Costs were calculated b y multiplying the average costs per facility and the number of new facilities estimated to be subject to subpart W (from revising the GWPs). Average costs per27

facility were calculated by

dividing total cost by

the number of respondents identified in the most recent information collection request for the GHG reporting program (U.S. EPA, 2013). Appendices I and L to the most recent information collection request for the GHG reporting program (U.S. EPA, 2013) were used to obtain first ye ar average cost per facility that is incurred from reporting under subpart W. Cost details from Exhibit 6 .1 of the most recent information collection request for the GHG reporting program (U.S. EPA, 2013) were used to determine the subsequent years avera ge cost per facility . These average costs per facility include labor costs (i.e., the cost of labor b y facility staff to meet the rule’s information collection requirements) and non - labor (capital , and operation and maintenance ) costs. Additional details o f the data, methods, and assumptions underlying these costs are documented in the most recent information collection request (U.S. EPA, 201 3 ). Table 5 - 14 shows first and subsequent year average cost per facility subject to subpart W . **Table 5 -**  **14. Annual Ave rage Cost Per Facility Subject to Subpart W**  **Subpart W Industry Segment**  **Total**

**Number of Respondents**  **a Total Cost** 

**(2011$ per year) Cost Per Facility**  **(2011$ per year) First Year**  **b Subsequent** 

**Years a**  **First Year b**  **Subsequent Years**  **a** NG Processing 289 8,952,000 2,32 4,000 31,000 8 , 000 NG Transmission 1,145 17,249,000 7,30 3,000 15,100 6 , 400 Underground NG Storage 133 2,695,000 1,12 2,000 20,300 8 , 400 LNG Storage 33 792,000 270,000 24,000 8,200 LNG Im port/Export 4 89,000 39,200 22,300 9,800 NG Distribution 143 2,089,000 1,498, 000 14,600 10,500 Onshore Production 981 17,932,000 7,958,000 18,300 8,100 Offshore Production 58 525,000 22 7,000 9,100 3 , 90 0 a This data was extracted from Exhibit 6 .1 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013). b The first year total cost are from the current cost & burden table identified as “First - Year Burden & Cost” in Appendix I - 3 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013) and includes $80.91 from the current burden & cost table identified as “First Reporting Year” table of Appendix L - 2 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013). The $80.91 is the cost contributed to provisions of information on parent companies, NAICS codes, and whether emissions are from cogeneration. T hese costs were updated to 2011 dollars using the Bureau of Labor Statistics Employment Cost Index and the Chemical Engineering Plant Cost Index (CEPCI). By revising the GWP values in subpart A, 99 additional facilities (refer to Table 5 - 12 to see these facilities b y subpart W industry segment) will be required to report under subpart W.28

The first year cost for these facilities will be approximately $1, 648 ,000 per year [ ( 2 x $ 31,000 )+(7 x $ 15,100 )+(6 x $ 20,300 )+(2 x $ 24, 000 )+(0 x $ 22,300 )+(16 x $ 14,600 )+(52 x $ 18,300 )+(14 x $ 9,100 ) = $ 1, 648,009 ], and the annualized industry wide cost is approximately $7 7 2 , 0 00 per ye ar [ ( 2 x $ 8 , 0 00 )+(7 x $6, 400 )+(6 x $8, 400 )+(2 x $ 8,200 )+(0 x $ 9,800 )+(16 x $10, 500 )+(52 x $8,19 00 )+(14 x $3,90 0 ) = $7 7 1,900 ] . **5.3.4 Subpart W Small Entity Impacts (new reporters)**  In the subpart W Economic Impact Anal ys is (U.S. EPA. 2010), EPA originally assessed the impact of compl ying with subpart W requirements on small entities in the petroleum and natural gas s ys tems source category by calculating a cost - to - sales ratio for eight enterprise size ranges (i.e., all categories, 1 to 20 employees, 20 to 99 employees, 100 to 499 employees, 500 to 749 employees, less than 500 employees, 750 to 999 employees, and 1,000 to 1,499 employees) using the ratio of average total annualized reporting costs to the average annual sales receipts for each establishment. The results of this analy sis are represented in Table 9 of the preamble for the publication of the subpart W rule ( 75 FR 74482, November 30, 2010). Based on this analy sis, EPA concluded that subpart W will not have a significant economic impact on a substantial number of small entities. EPA made this determination assuming that all entities in the industry would report (including those above and below the reporting threshold) and determined that no significant small business economic impacts were expected to occur. This analy sis showed that the cost

–to - sales ratio for all entity sizes except for the smallest sized enter

prises was less than 1 percent. EPA concluded that although the cost- to sales ratio for the 1 to 20 employee range for crude petroleum and natural gas extraction was greater than 1 percent (i.e., 1.33%); in most cases, the small enterprises in this size range have very small operations (such as single famil y owning a few production wells) that are highl y unlikely to cross the 25,000 metric tons CO 2 e reporting threshold. It is unlikely that any of the 99 new affected facilities that were estimated to become subject to subpart W (due to the revised GWP) would fall into the 1 to 20 employee range enterprise. Therefore, the changes to the GWP will not have significant impact on a substantial number of small entities in Subpart W . **5.3.5 Subpart**  **W (summary of i**  **mpacts )**  T able 5 - 15 summarizes the impacts of updating the GWP values in Table A - 1 to subpart A, on new facilities required to report subpart W emissions. **Table 5 -**  **15. New Reporters —**  **Summary of Subpart W Impacts Due to the Revisions to GWPs Subpart W Industry**  **Segm ent**  **Number of New**

**Reporters Due to GWP**  **Incremental**

**CO 2**  **e Emissions for New**  **Incremental Cost Impact For New Reporters**  **(2011$ per year)**29 **Revisions Reporters** 

**(m etric tons of**  **CO 2**  **e per year ) First Year**  **a Subsequent**  **Years a**  NG Processing 2 52,067 62,000 16 , 100 NG Transmission 7 177,091 105,000 44 , 600 Underground NG Storage 6 158,286 122,000 50 , 600 LNG Storage 2 50,000 48,000 16,400 LNG Import/Export 0 0 0 0 NG Distribution 16 400,000 234,000 168,000 Onshore Production 52 1,372,641 951,000 422,000 Offshore Production 14 362,796 127,000 54,700

**Total 99**  **2,572,881 1,648,000**  **77 2**  **,000** a Values for total are rounded. **5.3.6 References for Subpart W**  U.S. EPA , 2010. “Economic Impact Analysis for the Mandatory Reporting of Greenhouse Gas Emissions Under Subpart W Final Rule (GHG Reporting)”. Available at: http://www.epa.gov/ghgreporting/documents/pdf/2010/Subpart - W_EIA.pdf . U.S. EPA, 2013. Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program. OMB Control No. 2060 - 0629 . EPA ICR No. 2300.10 . May 2013. **5.4 Subpart HH**  Subpart HH applies to Municipal Solid Waste (MSW) landfills that accepted waste on or after January

1, 1980 and generate CH 4 in amounts equivalent to 25,000 metri c tons of CO 2 e per ye ar or more. **5.4.1 Subpart**  **HH (identifying new reporters)**  According to the technical supporting document (TSD) for the Landfill Sector (U.S. EPA, 2009a), 2,551 MSW landfills were estimated to be subject to subpart HH. This includes 771 active large MSW landfills, 230 active small landfills, and 1,550 closed landfills. The methods and database that were used to estimate the affected facilities for subpart HH in the TSD for the landfill sector (U.S. EPA, 2009a) can be divided into the following four categories: **Active Large MSW Landfills (771):**  The number of active large MSW landfills subject to subpart HH was identified based on the actual CH 4 generation information for each active landfill in the Landfill Methane Outreach Program (LMOP) database in 2006. The CH 4 generation rate in 2006 was calculated using the actual waste - in - place information and a landfill - specific model. The landfill - specific model used the first order decay model with a methane generation potential ( L 0 ) of 100 m 3 /mt and three different methane generation rate constant (k) values based on rainfall levels (U.S. EPA, 2005 a).30

**Active Small Landfills (230):**  It was estimated that there were 460 small active landfills in 2009 that were not covered by the 2006 LMOP database and 50% of them have CH 4 generation greater than 25,000 metric tons/y

r of CO 2 e. Fifty

percent was based on engineering judgments. **Closed Landfills (1,550):**  It was estimated that there were 6,200 closed landfills in 2009 and 25% of them have CH 4 generation greater than 25,000 metric tons/yr of CO 2 e. Twenty- five percent was based on engineering judgments. **Landfills that will Incur Additional Reporting Requirements in the Next Ten Years:**  Additional subsets of both active and closed landfills will incur additional GHG reporting burden over the ten - ye ar period following the finalization of the CH 4 GWP revision (assumed to occur in calendar year 2014). o Closed L andfills - Itis estimated that 196 closed landfills have a current CH 4 generation greater than 25,000 metric tons/y r CO 2 e and may

be required to stay

in the program longer with the revised CH 4 GWP. This estimate was based on e GGRT data for the reporting ye ar of 2011. o Active Landfills expected to close within 10 ye ars - A similar issue will occur for landfills that are currently in operation but plan to close within the ten - ye ar timeframe (calendar ye ars 2015 through 2024). Based on data from the LMOP database (U.S. EPA, 2013a), it is estimated that 233 landfills will close during that ten - ye ar timeframe that may incur an incremental reporting burden.

 Of these 233 landfills, 230 either currentl y have CH 4 generation greater than 25,000 metric tons/yr CO2 e , or will have this generation rate in the scheduled closur e year.  The remaining 3 landfills currentl y do not emit above 25,000 metric tons/y r CO 2 e and also would not in the scheduled closure ye ar; however the revised CH 4 GWP would result in the landfills emitting more than 25,000 metric tons/y

r CO 2 e at some point within the ten - ye ar timeframe. Based on the e - GGRT data for the reporting year of 2010, there are 1,202 MSW landfills that reported under subpart HH, including 936 active landfills and 266 closed landfills. The number of the closed MSW landfills repo rted under subpart HH (266) is significantly lower than the original estimate of 1,550 in the TSD for the landfill sector (U.S. EPA, 2009a). However, the number of active landfills reported (936) is close to the original estimate of 1,001 (771 active large + 230 active small) landfills. Therefore, except for closed landfills, the original methods used in the TSD for the landfill sector (U.S. EPA, 2009a) to estimate the number of affected31

active landfills is reasonable, and the same approach is used in this analysis to estimate the number of additional MSW landfills subject to subpart HH due to the revised CH 4 GWP. Because the reporting threshold for subpart HH is based on CH 4 generation (not emissions), the facilities that currently have CH 4 generation betwe en 21,000 and 25,000 metric tons/y r of CO 2 e are the additional facilities affected by the GWP change for CH 4 from 21 to 25. Because the CH 4 generation from landfills changes with time and the amount of waste in place, the time factor should be considered in this anal ys is. The additional active large MSW landfills, active small MSW landfills, closed landfills, and landfills that will close within the next ten years subject to subpart HH are estimated as follows: **Additional Active Large MSW Landfills:** Although the LMOP database (U.S. EPA, 2012) includes most of the input data (such as landfill open and closure years, amount of waste accepted, etc.) for the landfill - specific model used in the original anal ysis, this model was not re - run for this analy sis. Therefore, the actual CH 4 generation in 2011 for each MSW landfill covered b y the LMOP database was not calculated. The best CH 4 generation information available is the 2006 CH 4 generation information in the supporting data for the TSD for the landfill sector (U.S. EPA, 2009a). According to this supporting data, there were 1,142 active large MSW landfills and 21 of them have CH 4 generation between 21,000 and 25,000 metric tons/y r of CO 2 e based on 2006 LMOP database. This is equivalent to 1.8% of the total activ e landfills identified in LMOP database. According to the 2012 LMOP data (U.S. EPA, 2012), there are 1,123 active MSW landfills in 2012 (excluding the closed landfills). Assuming that the profile of landfills not in the LMOP database is similar to those landfills in the LMOP database, the number of active large landfills with CH 4 generation between 21,000 and 25,000 metric tons/yr of CO 2 e is estimated to be 1,123 x 1.8% = 20 facilities. **Additional Active Small MSW Landfills:** Small landfills are not include d in the LMOP database, therefore a different approach was used to estimate the additional active small landfills affected b y the change in GWP. In the TSD for the landfill sector (U.S. EPA, 2009a), it was estimated that there were 460 small active landfil ls in 2009 and 50% of them have CH 4 generation greater than 25,000 metric tons/y r of CO 2 e and were included in the original estimates of number of reporting facilities. Thirty percent of small landfills are estimated to have CH 4 generation between 10,000 and 25,000 metric tons/y r of CO 2 e. Assuming that the proportion of all small active landfills is the same as those in the LMOP database, and the distribution across the available range of estimated emissions (10,000 to 25,000) is even, the number of small active landfills with CH 4 generation between32

21,000 and 25,000 metric tons/y r of CO 2 e is estimated to be 460 x 30% x (25,000

– 21,000) / (25,000

– 10,000) = 37 facilities. **Additional Closed MSW Landfills:** For closed landfills, CH 4 generation and emissions decrease over time. It is estimated that the CH 4 generation decreases 18% in 5 ye ars based on the CH 4 generation calculated using EPA’s Landfill Gas Emissions Model ( LandGEM ) (U.S. EPA, 2005b). The closed MSW landfills identified in the 2006 LMOP database with CH 4 generation equal to 25,000 metric tons of CO 2 e now should have CH 4 generation around 25,000 x (1 - 18%) = 20,500 metric tons/y r of CO 2 e in 2011. With the updated GWP for CH 4 , the CH 4 generation for these landfills is 20,500 / 21 x 25 = 24,405 metric tons/y r of CO 2 e, which is still less than the reporting threshold of 25,000 metric tons/y

r. Therefore, the closed landfills that were identified in 2006 and with CH 4 generations between 21,000 and 25,000 metric tons/y r of CO 2 e still would not exceed the 2 5,000 metric tons/year generation threshold of subpart HH after 2011 due to the revised CH 4 GWP. According to the 2012 LMOP data , 92 MSW landfills were closed in the time period of 2007 through 2011 (U.S. EPA, 2012 ). Based on the waste in place information , none of these newl y closed landfills have CH 4 generation between 21,000 tons and 25,000 tons of CO 2 e based on a GWP for CH 4 of 21. Therefore, no additional closed landfills are expected to exceed the 25,000 metric tons/year generation threshold using a GWP of 25. Additionally , as part of the final rule requirements, EPA has revised the applicability provisions for subpart HH to exclude closed landfills that have not previously had to report under subpart HH that would be required to newl y report in 2014 b y exceeding the 25,000 metric tons CO 2 e emissions threshold for the first time solel y due to th e increase in the GWP of CH 4 . Specificall y, EPA is revising 40 CFR 98.340 to add a paragraph to state: “This source category does not include MSW landfills that have not received waste on or after January 1, 2013, and that had CH 4 generation, as determined using both Equation HH - 5 and Equation HH - 7 of this subpart , of less than 1,190 metric tons of CH 4 in the 2010, 2011, 2012 and 2013 reporting years.” Therefore, no additional closed landfills meeting these provisions would be required to newly report under subpart HH in 2014. **Landfills that will Incur Additiona l Reporting Requirements in the Next Ten Years**  **:** Although landfill closure dates and waste - in - place information are available in the LMOP database (U.S. EPA, 2013 a), e - GGRT data for the 2012 reporting year was used to identify 43 closed landfills that would incur additional reporting requirements. For the 196 closed landfills with CH 4 generation greater than 25,000 metric tons/y r CO 2 e, a total of 36 (18%) were identified as facilities that over the next ten years, will required to report for more ye ars than originally anticipated. An analysis was conducted for reporters that may33

have additional ye ars of reporting over the next ten years. Using the modeled generation rates for closed landfills in the subpart HH rule, a typical rate of decline in CH 4 generatio n was calculated for closed landfills equivalent to a 3.6% reduction in CH 4 generation each year and assumed that is a linear reduction (18% over five ye ars). This value matched well with the modeled decrease in CH 4 generation in the LMOP database. The annual CH 4 generation reported in e - GGRT was reduced b y this amount for a period of ten years, with each ye ar being analyzed in sequence. There were a total of 36 landfills that were predicted to be subject to at least one year of additional GHG required repo rting with an increase in the CH 4 GWP from 21 to 25. For active landfills that are planning to close within the next ten years, the LMOP database was selected as the source of information to use in the economic impact anal ys is instead of the e - GGRT 2012 reporting year data. This is because a subset of the applicable active landfills may

not be currently

subject to subpart HH and thus not currently required to report GHG emissions through e - GGRT. A total of four active landfills that are planned to close within the next ten years were identified as facilities that may be required to report for more years than originall y anticipated over the ten year period. The LMOP database provides an annual waste acceptance rate which was used to estimate the total waste - in - place in the planned closure ye ar. This waste amount was used to calculate CH 4 generation in the closure ye ar using Equation HH 1 from subpart HH. CH 4 generation was then scaled downwards by 3.6% each year, with each ye ar being anal yz ed in sequence. The active landfills in the LMOP database were also researched for instances where the CH 4 GWP of 21 would never result in the landfill emitting greater than 25,000 metric tons CO 2 e, but would be above this threshold within the next ten years using a CH 4 GWP o f 25. These represent landfills that would trigger the reporting requirements of subpart HH. These landfills would not be covered under the large or small active landfill sections described above because the increased CH 4 GWP would not result in subpart HH applicability in the current ye ar; instead, the landfill would trigger the reporting requirements of subpart HH at some point within the next ten years. An identical year- over- ye ar anal ys is was conducted for the three landfills identified. Based on the di scussions above, Table 5 - 16 identifies the number of new subpart HH reporters that will become subject to the rule as a result of revisions to the GWPs in Table A - 1 .

**Table 5 -**  **16. New Subpart HH Reporters by Type of MSW Landfill Type of MSW Landfill**  **Number of New Reporters Due to GWP Revisions**  Large Active Landfills 20 Small Active Landfills 37 Closed Landfills 0 Landfills that will Incur Additional Reporting Requirements in the Next Ten Years 4334 **Total 100**  **5.4.2 Subpart**  **HH (estimating emissions i**  **mpacts )**  From Table 5 - 16 , there would be 57 additional facilities subject to subpart HH due to the revised CH 4 GWP. Emissions from these 57 additional facilities were estimated by multiplying the number of new affected facilities (57) b y the average CH 4 generation for each new affected facility . The average CH 4 generation for each new affected facility is assumed to be (25,000 + 21,000)/2 x 25/21 = 27,381 metric tons/y r of CO 2 e. The amount of CO 2 equivalent has been adjusted using the new GWP for CH 4 of 25. Therefore, the total CH 4 generation for all new affected facilities combined is equal to about 1,560,000 metric tons/y r of CO 2 e (57 x 27,381 = 1,560,717). Table 5 - 17 identifies the emissions impact from new subpart HH reporters.

**Table 5 -**  **17. Em issions Impa**  **ct From New Subpart HH Reporters**  **Facility Type Incremental CO**  **2 e Emissions for New Reporters**  **(m etric tons of CO**  **2 e per year )**  HH

– MSW Landfills 1,560,000 **5.4.3 Subpart**  **HH (estimating cost i**  **mpacts )**  Costs were calculated b y multiplying the average costs per facility and the number of new facilities estimated to be subject to subpart HH (from revising the GWPs). Average costs per facility were calculated by

dividing total cost by

the number of respondents identified in the most recent information collection request for the GHG reporting program (U.S. EPA, 2013). Appendices G and L to the most recent information collection request for the GHG reporting program (U.S. EPA, 2013) were used to obtain first ye ar average cost per facility that is incurred from reporting under subpart HH. Cost details from Exhibit 6 .1 of the most recent information collection request for the GHG reporting program (U.S. EPA, 2013) were used to determine the subsequent years average cost per facility . These average costs per facility include labor costs (i.e., the cost of labor b y facility staff to meet the rule’s information collection requirements) and non - labor (capital , and operation and maintenance ) costs. Additional details of the data, methods, and assumptions underlying these costs are documented in the most recent information collection request (U.S. EPA, 201 3 ). Table 5 - 18 shows first and subsequent year average cost per facility subject to subpart HH . **Table 5 -**  **18 . Annual Average Cost Per Facility Subject to Subpart**  **HH Subpart**  **Total Number of**

**Respondents a**  **Total Cost (2011$ per year)**  **Cost Per Facility (2011$ per year)** 35 **First Year b**  **Subsequent**

**Years a**  **First Year b**  **Subsequent Years**  **a** HH

– MSW Landfills 1,195 10,894,000 2,804,000 4, 300 2,3 00 a This data was extracted from Exhibit 6 .1 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013). b This data was extracted from the current burden & cost table in Appendix G - 3 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013). The one - time costs in Appendix G - 3 ($2,497,000 or $2,644, 000 w hen updated to 2011 dollars) were added to the "HH. Landfills" cost provided in Appendix G - 3 ($7,736,000 or $8,046,000 updated to 2011 dollars). The costs were updated to 2011 dollars using the Bureau of Labor Statistics Employment Cost Index and the Chemical Engineering Plant Cost Index (CEPCI). An additional $204,216 ($80.91 per respondent) was added to the total first year cost based on the current burden & cost table identified as “First Reporting Year” table of Appendix L - 2 of the Supporting Stat ement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013). The $80.91 is the cost contributed to provisions of information on parent companies, NAICS codes, and w

hether emissions are from cogeneration. These cal culations (that were used to determine the first year total cost, and cost per facility) are based on an estimated 2,524 respondents to be consistent with Appendix G - 3. By revising the GWP values in subpart A, 57 additional facilities will be required to report under subpart HH. The first year cost for these 57 facilities will be approximately $2 46,0 00 per ye ar (57 x $4, 300 = $ 246,000 ), and the annualized industry wide cost is $133,700 per year (57 x $2,346 = $133,7 00 ). An additional 43 closed or soon to - be - closed landfills will experience an incremental reporting burden over the next ten year period, due to an extended number of ye ars reporting would be required; total additional rule implementation costs would be $ 3 73 , 600 for these landfills over that ten year period, or an average of $ 3 7 , 36 0 per ye ar. This includes extended subsequent year reporting costs for 36 closed landfills, first year reporting costs for three active facilities that would be brought into Part 98 as a result of the revised GWPs, and extended subsequent year reporting costs for four active facilities that are expected to closed between 2014 and 2024 , as summed over a ten - ye ar period . A ye ar - over- ye ar breakdown of these costs is included in Section 5.4.5 below. **5.4.4 Subpart HH Small**  **Entity Impacts (new reporters)** The small entity

economic impact for landfills was measured using the “sales tests” approach (represented as cost - to - receipt ratios) for NAI C S codes associated with the affected subparts in the Regulatory Impact Anal ys is for the GHG Reporting Rule (U.S. EPA, 2009b ). The same approach is used in this analysis for the additional facilities subject to subpart HH due to the revised CH 4 GWP. I f the ratio of rule implementation cost to sales is less than 1%, the impact is not considered to be significant (U.S. EPA, 2010b ). Based on the 2007 economic census database published by U.S. Bureau of the Census, the receipts (sales), number of establishments, and the average receipts for different size of Waste Management and Remediation S ervices facilities (with a NAI CS code of 562) information36

is summarized in Table 5 - 19. The average receipts information is adjusted from 2007 dollars to 2011 dollars based on the consumer price index published by Bureau of Labor Statistics .

**Table 5 -**  **19. Receipts, Number of Establishments, and Average Receipts for Waste Managem**  **ent and Remediation Services (NAICS code of 562) Owned by Enterprises with:**  **1 -**  **19 Employees**  **20 -**  **99**

**Employees 100**  **- 249** 

**Employees 250**  **- 499** 

**Employees 500**  **- 999** 

**Employees 1,000 and** 

**above Employees**  Receipts (million, 2007$) $10,492 $14,318 $6,856 $3,365 $3,732 $35,420 Number of Establishments 12,579 2,678 646 248 263 2,910 Average Receipts for Each Establishment (million, 2007$) $0.83 $5.35 $10.61 $13.57 $14.19 $12.17 Average Receipts for Each Establishment (million, 2011$) $0.90 $5.80 $11.51 $14.72 $15.40 $13.20 According to the cost information listed in Table 5 - 18 , the rule implementation costs for subpart HH is $ 4, 300 for the first year and $ 2,3 00 for the subsequent ye ars (in 2011 dollars). The sales tests (cost - to - receipt ratios) results are shown in Table 5 - 20 for the first year and subsequent years. **Table 5 -**  **20. Sales Tests for Subpart HH Facilities**  **Owned by Enterprises with: 1**  **- 19**  **Employees 20**  **- 99** 

**Employees 100**  **- 249** 

**Employees 250**  **- 499** 

**Employees 500**  **- 999** 

**Employees 1,000 and** 

**above Employees**  Sales Test

– First Year 0. 48 % 0. 0 7 % 0. 0 4 % 0. 0 3 % 0. 0 3 % 0. 0 3 % Sales Test - Subsequent Years 0. 2 6 % 0.04% 0.02% 0.02% 0. 0 1 % 0.02% The results in Table 5 - 20 show that the costs for GHG reporting for the facilities subject to subpart HH is well below 1% of the sales for all size of Waste Management and Remediation S ervices facilities with a NAI CS code of 562. Therefore, it was determined that there is not a significant impact on a substantial number of small businesses subject to reporting under subpart HH as a result of this action. **5.4.5 Subpart**  **HH (summary of i**  **mpacts )**  Table 5 - 21 summarize s the impacts of updating the GWP values in Table A - 1 to subpart A, on new facilities required to report subpart HH emissions.37

**Table 5 -**  **21 . New Reporters** **— Summary of Subpart**  **HH Impacts Due to the Revisions to GWPs**  **Facility Type Number of New**  **Reporters Due to GWP**  **Revisions Incremental** 

**CO 2**  **e Emissions for New**  **Reporters (m**  **etric tons of CO**  **2 e per year )**  **a Incremental Cost Impact For New**  **Reporters (2011$ per year)**  **First Year a**  **Subsequent**

**Years a**  HH

– MSW Landfills 57 1,560,000 246,000 133,700 a Values rounded. The incremental reporting burden is provided in year- over- ye ar format in Table 5 - 22 for both the new reporters and the 43 existing facilities that would trigger extended reporting requirements over the following ten ye ars. The costs for closed facilities were calculated based on applying first year and subsequent year costs to the facilities identified (see “ Landfills that will Incur Additional Reporting Requirements in the Next Ten Years ”, Section 5.4.1) in each ye ar for which the facil ity would be subject to extended reporting requirements or would be brought into Part 98. This includes extended subsequent year reporting costs ($2,300 per facility) for 36 landfills that are or would be closed b y 2014 , first year reporting costs ($4,300 per facility) for three active facilities that would be brought into Part 98 as a result of the revised GWPs , and extended subsequent year reporting costs ($2,300 per facility) for four active facilities that are currently receiving waste but are expected to close between 2014 and 2024.

**Table 5 -**  **22. Summary of Subpart HH Cost Impacts $/year**  **2015 2016**  **2017 2018**  **2019 2020**  **2021 2022**  **2023 2024**  Landfills Closed before 2024 1 8 , 8 00 2 8 , 1 00 30 , 1 00 3 5 , 1 00 39 , 8 00 4 6 , 8 00 4 4 , 5 00 4 6 , 8 00 3 7 , 4 00 45 , 9 00 New Reporters 246,000 133,700 133,700 133,700 133,700 133,700 133,700 133,700 133,700 133,700 Total a 264 , 8 00 16 1 , 8 00 16 3 , 8 00 16 8 , 8 00 17 3 , 5 00 18 0 , 5 00 17 8 , 2 00 18 0 , 5 00 17 1 , 1 00 179 , 6 00 a Total average Incremental Cost Impact for New Reporters and Reporters with Extended Reporting Requirements is $ 182 , 20 0 per year. **5.4.6 References for Subpart HH**  U.S. EPA, 2005a. Development of Landfill - s pecific Methane Inventory Model; Memorandum from Jeff Coburn and Marvin Branscome, RTI, to Elizabeth Scheele, EPA. See Docket ID: EPA - HQ - OAR - 2 008 - 0058 - 0083. May 6, 2005. U.S. EPA, 2005b. Landfill Gas Emissions Model (LandGEM), , Version 3.02. [Computer software]. Retrieved July 12, 2012. Available from http://www.epa.gov/ttn/catc/products.html#software U.S. EPA, 2009a. Technical Support Document for the Landfill Sector: Proposed Rule for Mandatory Reporting Of Greenhouse Gases. See Docket ID: EPA - HQ - OAR - 2008 - 0508 - 0034. February 4, 2009.38

U.S. EPA, 2009b. Regulatory Impact Analysis for the Mandatory Reporting of Greenhouse Gas Emissions Final Rule (GHG Reporting). See Docket ID: EPA - HQ - OAR - 2008 - 0508 - 2229. September 2009. U.S. EPA, 2012. Landfill Methane Outreach Program (LMOP)

– Landfill and Project Database. January 4, 2012 . Available from: http://www.epa.gov/lmop/documents/xls/lmopdata.xls U.S. EPA, 2013a. Landfill Methane Outreach Program (LMOP)

– Landfill and Project Database. June 13, 2013. Available from : http://www.epa.gov/lmop/documents/xls/lmopdata.xls U.S. EPA, 2013b. Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program. OMB Control No. 2060 - 0629 . EPA ICR No. 2300.10 . May 2013. **5.5 Subpart II**  The industrial wastewater treatment source category consists of anaerobic processes used to treat industrial wastewater and industrial wastewater treatment sludge at facilities that perform the following operations: p etroleum refining ; pulp and paper manufacturing facilities; ethanol production ; and f

ood processing . Facilities that meet reporting thresholds must report the amount of CH 4 generated, emitted, and/or recovered from anaerobic treatment of industrial wastewaters and industrial wastewater treatment sludges. Subpart II applies only to anaerobic treatment processes. For the industries covered by subpart II, the reporting thresho lds are specified as follows:  Petroleum refineries are required to report if the facility is subject to reporting under subpart Y of 40 CFR part 98 . There is no threshold for reporting.  Pulp and paper manufacturing facilities are required to report if the facility emits 25,000 metric tons CO 2 e or more per ye ar . All pulp and paper facilities are expected to meet this threshold.  Ethanol production facilities are required to report if the facility emits 25,000 metric tons CO 2 e or more per ye ar.  Food processing facilities are required to report if the facility emits 25,000 metric tons CO 2 e or more per ye ar. **5.5.1 Subpart**  **II (identifying new reporters)**  This section discusses how EPA estimate d the number of facilities required to report during the development of the Greenhouse Gas Reporting Rule. It then discusses how these estim ates would change if the methane GWP increased from 21 to 25. Th e discussion i s presented separatel y for each of the four industries included in subpart II. Petroleum refineries . During the development of the GHG reporting rule, EPA noted that 40 CFR 98.2(a)(1) requires all 150 petroleum refineries to report their GHG emissions. As part of the es timate of the potential costs of subpart II, EPA further estimated that 25% of refineries have anaerobic wastewater treatment and would be required to report subpart II emissions (ERG,39

2010). However, in the 2011 reporting year, there were no facilities identified that reported both petroleum refining emissions and subpart II emissions. For th ese reason s , any change to the methane GWP will have no impact on the estimated number of petroleum refineries required to report subpart II emissions. Pulp and paper manufacturing facilities . During the development of the GHG reporting r ule, as part o f the estimate of the potential costs of subpart II, EPA estimated that 25% of the 565 U.S. pulp and paper mills have anaerobic treatment. EPA further assumed that all 141 mills with anaerobic secondary treatment would meet the 25,000 metric tons CO 2 e thre shold of emissions from their subpart AA operations and would be required to report subpart II emissions (ERG, 2010). In the 2011 reporting year, there were 7 facilities that reported both pulp and paper manufacturing emissions and subpart II emissions. Be cause mills are assumed to meet the reporting threshold based on their subpart AA CO 2 emissions, any change to the methane GWP will have no impact on the estimated number of pulp and paper mills required to report subpart II emissions. Ethanol production facilities . Ethanol production facilities are required to report their GHG emissions if they

exceed 25,000 metric tons CO 2 e per year in combined emissions from all specified sources, such as stationary fuel combustion units, industrial landfills, and indus trial wastewater treatment. However, for the purpose of its March 2010 cost estimate, because EPA had no basis for estimating emissions from other sources at the ethanol production facility , EPA assumed facilities that exceed 25,000 metric tons CO 2 e per ye ar in emissions from industrial wastewater treatment would incur monitoring costs (ERG, 2010). Facilities use one of two processes to produce ethanol: dry milling or wet milling. During the development of the GHG reporting r ule, EPA obtained information from the Renewable Fuels Association that included facility identification, production, and whether the facility used dry milling or wet milling. This information did not identify facilities that use anaerobic wastewater treatment. Assuming each facility use d anaerobic treatment and using standard waste generation rates based on ethanol production, chemical oxygen demand ( COD ) concentrations, and methane generation rates, EPA calculated potential methane emissions per plant. Dry milling. The maximum estimated emissions from a facility were slightly

over 1,800 metric tons CO 2 e per year. Even if the methane GWP were increased b y 20%, no dry milling ethanol plant would meet the 25,000 metric tons CO 2 e per year reporting threshold . Wet milling. Wet milling ethanol production facilities generate more wastewater per unit of production and have somewhat greater production per facility than dry milling facilities. Four wet milling facilities produce 1 .5 to 2 .5 times as much ethanol as the largest dry milling facility . Because EPA had very

little information on how individual ethanol production facilities treat40

wastewater, in order to estimate the potential costs of subpart II , EPA estimated that 33% of the wet milling facilities used anaerobic was tewater treatment. Using standard waste generation rates based on ethanol production, COD concentrations, and methane generation rates, EPA calculated that four (4) wet milling facilities emitted in excess of the 25,000 metric tons CO 2 e per year reporting threshold. EPA estimated that ethanol production facilities would incur $20,600 in total annualized costs to meet the GHG reporting rule monitoring requirements (ERG, 2010), or $5,150 per facility . In a more recent anal ys is, EPA estimated that two wet mi lling ethanol production facilities exceeded the reporting threshold. Changing the GWP to 25 would increase this estimate by two, to a total of four facilities. In the 2011 reporting ye ar, there were 17 ethanol production facilities that reported subpart I I emissions. However, the subpart II emissions for each of these facilities were under the 25,000 tons per year threshold; the facilities exceeded the threshold based on subpart C combustion emissions. Using these sources of information, it is estimated th at the impact of a change to the GWP for methane from 21 to 25 will result in two additional facilities that will be required to report . Food processing facilities. Food processing facilities are required to report their wastewater emissions if Facility GH G emissions exceed 25,000 metric tons CO 2 e per year in combined emissions from all specified sources, such as stationary fuel combustion units, industrial landfills, and industrial wastewater treatment. However, for the original development of the rule , be cause EPA had no basis for estimating emissions from other sources at the food processing facility , EPA assumed facilities that exceed 25,000 metric tons CO 2 e per year in emissions from anaerobic industrial wastewater treatment alone would be subject to th e rule (ERG, 2010). Food processing facilities that are most likely to have anaerobic wastewater treatment are : 1) fruits and vegetable processing , 2) poultry processing, and 3) red meat processing. Fruits and vegetable processing. During the development of the GHG r eporting r ule, as part of the estimate of the potential costs of subpart II, EPA estimated that no fruit and vegetable processing facilities would incur reporting costs because all would be under the reporting threshold (ERG, 2010). As discusse d in the July 2008 threshold anal ys is (ERG, 2008b), EPA could not identify

plant - specific information to calculate greenhouse gas emissions for fruit and vegetable processors. The national level of emissions from the 2006 U.S. Inventory of U.S. Greenhouse Gas Emissions and Sinks is 123,000 metric tons CO 2 e . There are approximately 100 processors with onsite anaerobic treatment (U.S. EPA, 2008); therefore, the average emission was estimated to be about 1,200 metric tons CO 2 e per plant (ERG, 2008b). If the methane GWP increased from 21 to 25, the average emission would increase to about 1,460 metric tons CO 2 e per plant, still significantly below the 25,000 metric tons CO 2 e reporting threshold. Thus, an41

increase in the methane GWP would have no effect on the number of fruit and vegetable processing facilities required to report subpart II emissions. Poultry processing. During the development of the GHG r eporting r ule, as part of the estimate of the potential costs of subpart II, EPA determined it did not have sufficient information to estimate the number of poultry processing facilities that exceed the 25,000 metric ton CO 2 e reporting threshold. EPA estimated 50 poultry processors have methane emissions above 10,000 metric tons CO 2 e (ERG, 2010). This is an overes timate of those that have emissions above 25,000 metric tons CO 2 e, but EPA does not have sufficient facility- specific information to refine the estimate, nor to estimate the impact of changing the methane GWP. As described in the July

17, 2008 memo randum ( ERG, 2008b ) , EPA was unable to obtain plant - specific information for poultry processors; neither production levels nor whether facilities use anaerobic wastewater treatment were found. Therefore, using national default values for wastewater generation, COD in wastewater concentrations, and assuming all wastewater is treated anaerobicall y on site, EPA back- calculated the production rate that would trigger each of four emission thresholds. EPA estimated that production of 93 million lb/y r would result in emis sions exceeding 10,000 metric tons CO 2 e. Production of 232 million lb/y r would result in emissions exceeding 25,000 metric tons CO 2 e. EPA had publicly available data obtained to support EPA Office of Water’s effluent guidelines for the meat and poultry pro ducts industry . These data classified “nonsmall” poultry processors as facilities producing more than 100 million pounds per year and reported 206 “nonsmall ” poultry producers. The data also indicated that 25% of the industry

uses onsite anaerobic treatment. Consequently , EPA estimated that 50 poultry producers (206 x 25%) would exceed the 10,000 metric tons CO 2 e threshold (ERG, 2008b). EPA used this estimate as a conservatively high estimate of the number of poultry producers that would be subject to subpart II. Because this estimate includes producers with emissions as low as 10,000 metric tons CO 2 e, no additional facilities are estimated to report as a result of the change in GWP of methane from 21 to 25. Red meat processing. During the development of the GHG reporting r ule, as part of the estimate of the potential costs of subpart II, EPA estimated 13 red meat processors have methane emissions above 25,000 metric tons CO 2 e. As described in July 17, 2008 memo randum (ERG, 2008b) , EPA was unable to obt ain plant - specific information for red meat processors, neither production levels nor whether facilities use anaerobic wastewater treatment. EPA used limited published information and engineering judgment to estimate the number of red meat processing facil ities required to report, as follows:42

 Data available on Tyson Foods 5 indicates that covers have been installed on anaerobic lagoons at five meat proce ssing plants (4 beef, 1 pork). Prior to the installation of the covers, all five sites were estimated to emit more than 25,000 metric tons CO 2 e and one of these sites emitted more than 100,000 metric tons CO 2 e. Following installation of the covers, onl y one of these sites emits more than 25,000 metric tons CO 2 e and three more emit more than 10,000 metric tons CO 2 e.  Data from Cargill Meat Solutions, Inc. (Cargill) 6 indicate they have installed covers on all of their anaerobic lagoons at U.S. meat packing plants (8 beef, 2 pork). It i s estimated that these plants would have emitted more than 25,000 metric tons CO 2 e each. It i s unknown what their actual emissions are now. From these data, it is estimated that no more than 13 meat processing facilities actually emit more than 25,000 metric to ns CO 2 e (ERG, 2008b) . Because so few red meat processing facilities are required to report using the current GWP, it is likely that no new facilities will be required to report if the GWP for methane increases from 21 to 25. Table 5 - 23 identifies the numb er of new subpart II reporters that will become subject to the rule as a result of revisions to the GWPs in Table A - 1 . **Table 5 -**  **23. New Subpart II Reporters Facility Type**  **Number of New Reporters Due to GWP Revisions**  Petroleum 0 Pulp and Paper 0 Ethanol 2 All Others 0 **Total 2**  **5.5.2 Subpart**  **II (estimating emissions i**  **mpacts )**  Because there are no new p etroleum refin ers, pulp and paper manufacturing facilities, and f ood processing facilities anticipated to be affected by the revised GWPs, there is no emissions impact from new subpart II reporters related to these facility typ es. However, it is estimated that emissions will increase by 59,500 metric tons CO 2 e per ye ar from the two additional facilities that are expected to report. This estimate is based on the threshold anal ys is discussed in section 5.5.1 which was used to determine the increase in emissions from the additional reporters that would be expected due to the revised GWPs in Table A - 1. Table 5 - 24 identifies the emissions impact from new subpart II reporters.

5 Verification of Blue Source Emissions Reductions Credits from Methane Capture and Flare Projects at Tyson Foods Facilities, prepared by RAVEN RIDGE RESOURCES, INCORPORATED, February 23, 2004. 6 Cargill’s Corporate Citizenship Review.43 **Table 5 -**  **24. Em issions Impact From** **New Subpart II Reporters Facility Type**  **Incremental CO 2**  **e Emissions for New Reporters (m**  **etric tons of CO 2**  **e per year )** Petroleum 0 Pulp and Paper 0 Ethanol 59,500 All Others 0 **Total 59,500**  **5.5.3 Subpart**  **II (estimating cost i**  **mpacts )**  Costs were calculated b y multiplying the average costs per facility and the number of new facilities estimated to be subject to subpart II (from revising the GWPs). Average cost per facility for the first year was calculated by dividing total cost b y the number of respondents identified in the initial information collection request for subpart II (U.S. EPA, 2010). Average cost per facility

for subsequent years was calculated by dividing total cost by

the number of respondents identified in the most recent information collection request for the GHG reporting program (U.S. EPA, 2013). Appendix A to the initial information collection request for subpart II (U.S. EPA, 2010) and Appendix L - 2 of the most recent information collection request for the GHG reporting program (U.S. EPA, 2013) were used to obtain first year average cost per facility that is incurred from reporting under subpart II. Cost details from Appendices H - 1 and L - 2 of the most recent information collection request for the GHG reporting program (U.S. EPA, 2013) were used to determine the subsequent years average cost per facility . These average costs per facility include labor costs (i.e., the cost of labor b y facility staff to meet the rule’s information collection requirements) and non - labor (capital , and operation and maintenance ) costs. Additional details of the data, methods, and assumptions underlying these costs are documented in the information collection requests (U.S. EPA, 201 0 and U.S. EPA, 201 3 ). Table 5 - 25 s hows first and subsequent year average cost per facility subject to subpart II . **Table 5 -**  **25 . Annual Average Cost Per Facility Subject to Subpart**  **II Subpart**  **Total Number**

**of Respondents**  **a Total Cost**  **(2011$ per year) Cost Per Facility**  **(2011$ per year) First Year**  **b Subsequent** 

**Years a**  **First Year b**  **Subsequent Years**  **a** Petroleum 150 625,000 605, 900 4,200 4,040 Pulp and Paper 141 627,000 607, 900 4,400 4,3 00 Ethanol 4 21,600 21,000 5,400 5, 300 All Others 63 263,000 254, 500 4,200 4,040 a The total number of respondents and the subsequent year costs are from Appendix H - 1 of the Supporting Statement44

Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013) . The subsequent costs include $44.25 from the r evised burden & cost table identified as “Average Annual Burden and Cost” table of Appendix L - 2 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013). The $44.25 is the cost contributed to provisions of information on parent companies, NAICS codes, and whether emissions are from cogeneration. b The first year costs are from the “Year 1” table of Appendix A to the initial information collection request for subpart II (U.S. EPA, 2010) . The first year cost includes $80.91 from the current burden & cost table identified as “First Reporting Year” table of Appendix L - 2 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013). T he $80.91 is the cost contributed to provisions of information on parent companies, NAICS codes, and whether emissions are from cogeneration. These costs were updated to 2011 dollars using the Bureau of Labor Statistics Employment Cost Index and the Chemic al Engineering Plant Cost Index (CEPCI). By revising the GWP values in subpart A, two additional ethanol production facilities will be required to report under subpart II. The first year cost for these facilities will be approximately

$10, 800 per year (2 x $5, 400 = $ 10, 800 ), and the annualized industry wide cost is $ 10,500 per ye ar ( 2 x $ 5, 270 = $ 10,500 ). **5.5.4 Subpart II Small Entity Impacts (new reporters)**  The only additional subpart II reporters expected as a result of a change to the GWP of methane from 21 to 25 are two ethanol production facil ities. Both of these facilities are owned b y a large corporation that has been determined not to be a small entity . Therefore, it was determined that there are no small entity impacts to any

subpart II reporters associ ated with this action. **5.5.5 Subpart**  **II (summary of i**  **mpacts )**  Table 5 - 26 summarizes the impacts of updating the GWP values in Table A - 1 to subpart A, on new facilities required to report subpart II emissions. **Table 5 -**  **26 . New Reporters** **— Summary of Subpart**  **II Impacts Due to the Revisions to GWPs**  **Facility Type Number of New**  **Reporters Due to GWP**  **Revisions Incremental** 

**CO 2**  **e Emissions for New**  **Reporters (m**  **etric tons of CO**  **2 e per year )**  **a Incremental Cost Impact For New**  **Reporters (2011$ per year)**  **First Year a**  **Subsequent**

**Years a**  Petroleum 0 - - - Pulp and Paper 0 - - - Ethanol 2 59,500 10, 8 00 10,500 All Others 0 - - - **Total 2**  **59 ,**  **5 00**  **10, 8**  **00 10**  **, 5**  **00** a Values rounded.45

**5.5.6 References for Subpart II**  ERG, 2008b. Memorandum: Revised Threshold Analysis for the Estimation of Greenhouse Gas Emissions from Individual Industrial Facilities. Prepared for Melissa Weitz, EPA. See Docket ID: EPA HQ - OAR - 2008 - 0508 - 0132. See Docket ID: EPA - HQ - OAR - 2008 - 0508 - 0132 . July 17, 2008. ERG, 2010. Memorandum: Greenhouse Gas Reporting Rule, Industrial Wastewater Treatment Source Category, Costs for Final Rule Monitoring Requirements

– Revised. Prepared for Rachel Schmeltz, EPA. See Docket ID: EPA - HQ - OAR - 2008 - 0508 - 2297 . March 5, 2010. U.S. EPA, 2008 . Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990 - 200 6. April 200 8. USEPA #430 - R - 08 - 00 5 . U.S. EPA, 2010. Supporting Statement Part A: Information Collection Request for the Mandatory Reporting of Greenhouse Gases from Magnesium P roduction, Underground Coal Mines, Industrial Wastewater Treatment, and Industrial Waste Landfills

– Final Rule. OMB Control No. 2060 - 0647. EPA ICR No. 2396.01. July 2010 . U.S. EPA, 2013. Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program. OMB Control No. 2060 - 0629 . EPA ICR No. 2300.10 . May 2013. **5.6 Subpart OO**  Subpart OO applies to the suppliers of industrial GHGs source category , which consists of all facilities that produce a fluorinated GHG or nitrous oxi de, and any importer or exporter of fluorinated GHGs or nitrous oxide with annual bulk imports or exports that are equivalent to 25,000 metric tons CO 2 e or more. F - GHGs that do not appear on Table A - 1 are not included in the threshold anal ys is. However, if a supplier of industrial GHGs is above the threshold of 25,000 metric tons CO2e based on the Table A - 1 chemicals, they must report production, imports and exports of all F - GHG. **5.6.1 Subpart**  **OO (identifying new reporters)**  All production facilities are required to report regardless of threshold, therefore, there are not additional facilities as a result of the revised GWPs. A list of importers and exporters was developed for the 2009 subpart OO threshold anal ys is (U.S. EPA, 2009) and for the addition of bulk exporters to the threshold analysis (Ottinger, 2009) . As described in the referenced reports, this list was developed using information obtained primarily from the Port Import Export Reporting Service (PIERS), a database that collects, organizes and stores b ills of lading from port cargo. These data were supplemented with data obtained from industry representatives through the Alliance for Responsible Atmospheric Policy . Table 5 - 27 shows the number of facilities that EPA identified for each of the industry segments covered b y subpart OO that would report .46 **Table 5 -**  **27. Num ber of Facilities Reporting by Industry Segm**  **ent Segm**  **ent Number of Facilities**  **Number of Facilities Expected to Report**  HFC, PFC, SF6 and NF3 Producers 12 12 N2O Producers 5 5 N2O and Fluorinated GHG Importers 116 61 N2O and Fluorinated Exporters 192 - 244 a 89 a a The number of facilities was estimated as an upper bound and lower bound estimate. The data contained many similar, but not identically named companies. This list of importers and exporters was used to determine the additional facilities that would be required to report under subpart OO if the revised GWPs from the IPCC Fourth Assessment Report were used. The import and export quantities for each importer and exporter were multiplied by

the revised GWPs to determine which entities would exceed the threshold of 25,000 metric tons CO 2 e, and be required to report using the revised GWP. It is estimated that approximately

three additional importer or exporter entities would be required to report as a result of the revisions to the GWPs for compounds currentl y in Table A - 1. Table 5 - 28 identifies the emissions impact from new subpart OO reporters. **Table 5 -**  **28. New Subpart OO Reporters Facility Type**  **Number of New Reporters Du e to**  **GWP Revisions** OO

– Industrial GHG Suppliers 3 **5.6.2 Subpart**  **OO (estimating emissions i**  **mpacts )**  Each new reporter was estimated to report at the threshold of 25,000 metric tons CO2e because ERG assumed these facilities would only just meet the 25,000 metric tons CO2e reporting threshold. Table 5 - 29 identifies the emissions impact from new subpart OO reporters.

**Table 5 -**  **29. Em issions Impact From** **New Subpart OO Reporters Facility Type**  **Incremental CO 2**  **e Emissions for New Reporters (m**  **etric tons of CO 2**  **e per year )** OO

– Industrial GHG Suppliers 75,000 **5.6.3 Subpart**  **OO (estimating cost i**  **mpacts )**  Costs were calculated b y multiplying the average costs per facility and the number of new facilities estimated to be subject to subpart OO (from revising the GWPs). Average costs per facility were calculated by

dividing total cost by

the number of respondents identified in the most recent information collection request for the GHG reporting program (U.S. EPA, 2013).47

Appendices G and L to the most recent information collection request for the GHG reporting program (U.S. EPA, 2013) were used to obtain first ye ar average cost per facility that is incurred from reporting under subpart OO. Cost details from Exhibit 6 .1 of the most recent information collection request for the GHG reporting program (U.S. EPA, 2013) were used to determine the subsequent years average cost per facility . These average costs per facility include labor costs (i.e., the cost of labor b y facility staff to meet the rule’s information collection requirements) and non - labor (capital , and operation and maintenance ) costs. Additional details of the data, methods, and assumptions underlying these costs are documented in the most recent information collection request (U.S. EPA, 201 3 ). Table 5 - 30 shows first and subsequent year average cost per facility subject to subpart OO . **Table 5 -**  **30 . Annual Average Cost Per Facility Subject to Subpart**  **OO Subpart**  **Total Number**

**of Respondents**  **a Total Cost**  **(2011$ per year) Cost Per Facility**  **(2011$ per year) First Year**  **b Subsequent** 

**Years a**  **First Year b**  **Subsequent Years**  **a** OO

– Industrial GHG Suppliers 49 730,000 163,000 4, 400 3,3 00

a This data was extracted from Exhibit 6 .1 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013). b The first year total cost, and cost per facility, are based on an estimated 167 respondents (in lieu of 49). The $ 730,000 value was determined by adding together the “One - Time Costs” ($6, 932 ,000 / 6,616 x 167) and the “OO. Suppliers of Industrial GHG” total cost ($511,000) that are provided in the current burden & cost table in Appendix G - 3 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013) , and also includes $80.91 from the current burden & cost table identified as “First Reporting Year” table of Appendix L - 2 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013). The $80.91 is the cost contributed to provisions of information on parent companies, NAICS codes, and whether emissions are from cogeneration. These costs were updated to 2011 dollars using the Bureau of Labor Statistics Employment Cost Index and the Chemical Engineering Plant Cost Index (CEPCI). By revising the GWP values in subpart A, three additional facilities will be required to report under subpart OO. The first year cost for these three facilities will be approximately $1 3 ,100 per ye ar (3 x $4, 370 = $ 1 13,100 ), and the annualized industry wide cost is $ 10,000 per ye ar ( 3 x $ 3, 300 = $ 9, 900 ). **5.6.4 Subpart OO Small Entity Impacts (new reporters)**  EPA originall y assessed the impact of compl ying with subpart OO requirements on entities subject to the rule by calculating a cost to sales ratio for eight enterprise size ranges (i.e., all categories, 1 to 20 employees, 20 to 99 employees, 100 to 499 employees, 500 to 749 employees, less than 500 employees, 750 to 999 employees, and 1,000 to 1,499 employees)48

using the ratio of average total annualized mandatory reporting costs to the average establishments receipts. For this anal ys is, because the affected establishments are import and export entities with smaller volumes of imported or exported gases, an analysis was performed for the smallest size ranges of entities in the NAICS code 42469 (Other chemic al and allied products, merchant wholesalers). Based on the 2007 economic census database published b y U.S. Bureau of the Census, the receipts, number of establishments and the average receipts for different size entities is summarized in Table 5 - 31. **Table 5**  **- 31. Sales Test for Subpart OO**  **0 -**  **4 Em ployees**  **5 -**  **9 Em ployees**  **10 -**  **19 Employees** Average Receipts for each Establishment $ 2,557,209 4,737,209 17,593,574 First Year Cost per Entity $ 4,370 4,370 4,370 Subsequent Year Cost per Entity $ 3,300 3,300 3,300 First Year Sales Test 0.171% 0.092% 0.025% Subsequent Year Sales Test 0.129% 0.070% 0.019% The results in Table 5 - 31 show that the costs for GHG reporting for even the smallest facilities subject to subpart OO are well below 1% of the sales for all entities in the NAI CS code 42469. Therefore, there is not a significant economic impact to a substantial number of small entities for the facilities subject to subpart OO as a result of the revised GWPs. **5.6.5 Subpart**  **OO (summary of i**  **mpacts )**  Table 5 - 32 summarize s the impacts of updating the GWP values in Table A - 1 to subpart A, on new facilities required to report subpart OO emissions. **Table 5 -**  **32 . New Reporters** **— Summary of Subpart**  **OO Impacts Due to the Revisions to GWPs**  **Facility Type Number of New**  **Reporters Due to GWP**  **Revisions Incremental** 

**CO 2**  **e Emissions for New**  **Reporters (m**  **etric tons of CO**  **2 e per year )**  **a Incremental Cost Impact For New**  **Reporters (2011$ per year)**  **First Year a**  **Subsequent**

**Years a**  OO

– Industrial GHG Suppliers 3 75 ,000 13,100 1 0 , 0 00 a Values rounded. **5.6.6 References for Subpart OO**  Ottinger, D., 2009. Addition of Bulk Exporters of Fluorinated GHGs, Nitrous Oxide and Carbon Dioxide to Threshold Analysis of Industrial Gas Suppliers. Washington, DC: US EPA. See Docket ID: EPA - HQ OAR - 2008 - 0508 - 0230. April 2009. U.S. EPA, 2009. Additional Methodological Information Supporting Threshold Analysis for Specific Source Categories. See Docket ID: EPA - HQ - OAR - 2008 - 0508 - 0046 . March 2009 .49

U.S. EPA, 2013. Supporting Statement Part A: Information Collecti on Request For The Greenhouse Gas Reporting Program. OMB Control No. 2060 - 0629 . EPA ICR No. 2300.10 . May 2013. **5.7 Subpart TT**  Subpart TT applies to industrial waste landfills that accept wastes that have volatile solids concentration above 0.5 percent, that have total landfill design capacity greater than or equal to 300,000 metric tons , and that are located within a facility with GHG emissions equal to or greater than 25,000 metric tons of CO 2 e per ye ar. Therefore, the GHG emissions from an industrial waste landfill alone cannot determine the applicability of subpart TT and the GHG emissions from the entire facility must be considered. In general, industrial waste landfills that meet the GHG reporting criteria are co - located with refineries, petrochemical production facilities, pulp and paper mills, and food processing facilities. All refineries and petrochemical production facilities are required to report (no threshold), and all pulp and paper mills are expected to be above the reporting threshold; therefor e, all are expected to report under subpart TT if a landfill is present. This impact anal ys is focuses on the additional industrial waste landfills located in food processing facilities that are subject to subpart TT due to the revised GWP for CH 4 from 21 to 25 and the cost associated with these additional landfills subject to subpart TT. **5.7.1 Subpart**  **TT (identifying new reporters)**  In the TSD for the Landfill Sector (U.S. EPA, 2009 ), it was estimated that 200 industrial waste landfills would be subject to subpart TT, including 100 landfills co - located with pulp and paper mills and 100 landfills co - located with food processing facilities . Because landfill emissions are not the primary emissions from pulp and paper mills, the revised CH 4 GWP should not affect the subpart TT applicability for pulp and paper facilities. The number of total food processing facilities has not been updated since the Economic Impact Anal ys is for the Mandato ry Reporting of Greenhouse Gas Emissions: Subparts: T, FF, TT, and II (U.S. EPA, 2010 a) was developed in June 2010. According to that economic impact anal ys is for subpart TT (U.S. EPA, 2010 a), the food processing facilities with the following NAI CS codes w ere identified as the potential facilities under subpart TT:  311611

– Animal (except Poultry) Slaughtering  311411

– Frozen Fruit, Juice, and Vegetable Manufacturing  311421

– Fruit and Vegetable Canning Based on the e - GGRT data for the 2010 reporting year, there are 107 food processing facilities reported with the above three NAICS codes. This is close to the original estimate of 100 food processing facilities in the TSD for the landfill sector (U.S. EPA, 2009 ). Therefore, the50

same food processing facilities information in the TSD for the landfill sector (U .S. EPA, 2009 ) was used to estimate the additional food processing facilities affected b y subpart TT due to the revised CH 4 GWP. According to the TSD for the landfill sector (U.S. EPA, 2009 ), there were 18 9 food processing facilities (based on 1985 data) and 70 of them have GHG emissions between 10,000 metric tons per ye ar and 25,000 metric tons per ye ar of CO 2 e based on engineering judgments. The list of the food processing facilities is not available. Assuming that CH 4 emissions are the main GHG emissions from food processing facilities, the food processing facilities with GHG emissions between 21,000 metric tons per ye ar and 25,000 metric tons per year of CO 2 e in the TSD are the additional facilities that could be affected b y the revised CH 4 GWP from 21 to 25. Assuming an even distribution of facilities across this range of emissions, the number of food processing facilities with CO 2 e emissions between 21,000 metric tons per year and 25,000 metric tons per ye ar is estimated to be 70 x (25,000

– 21,000) / (25,000

– 10,000) = 19 facilities. Closed landfills and active landfills that plan to be closed within the next ten years were investigated for potential incremental GHG reporting impacts identicall y to th e anal ys is conducted for subpart HH . This anal ys is found that eight currently closed landfills will experience an increased reporting period due to the increased CH 4 GWP. No currentl y active landfills that are planned to shut down in the next ten years wer e expected to incur prolonged reporting requirements during the next ten years. Based on the discussions above, Table 5 - 33 identifies the number of new subpart TT reporters that will become subject to the rule as a result of revisions to the GWPs in Table A - 1 .

**Table 5 -**  **33. New Subpart TT Reporters by Type of Industrial Waste Landfill Type of Industrial Waste Landfill**  **Number of New Reporters Due to GWP Revisions** Located in Pulp and Paper Mills 0 Located in Food Processing Facilities 19 Landfills that will Incur Additional Reporting Requirements in the Next Ten Years 8 **Total 27**  **5.7.2 Subpart**  **TT (estimating emissions i**  **mpacts )**  From Table 5 - 33 , there would be 19 additional facilities subject to subpart TT due to the revised CH 4 GWP. Emissions from these 19 additio nal facilities were estimated by multiplying the number of new affected facilities ( 19 ) b y the average CH 4 generation for each new affected facility . The average CH 4 generation for each new affected facility is assumed to be (25,000 + 21,000)/2 x 25/21 = 2 7,381 metric tons/y r of CO 2 e. The amount of CO 2 equivalent has been adjusted using the new GWP for CH 4 of 25. Therefore, the total CH 4 generation for all new51

affected facilities combined is equal to about 520,000 metric tons/y r of CO 2 e (19 x 27,381 = 520,2 39). Table 5 - 34 identifies the emissions impact from new subpart TT reporters.

**Table 5 -**  **34. Em issions Impact From** **New Subpart HH Reporters Facility Type**  **Incremental CO 2**  **e Emissions for New Reporters (m**  **etric tons of CO 2**  **e per year )** TT

– Industrial Waste Landfills 520,000 **5.7.3 Subpart**  **TT (estimating cost i**  **mpacts )**  Costs were calculated b y multiplying the average costs per facility and the number of new facilities estimated to be subject to subpart TT (from revising the GWPs). Average cost per facility for the first ye ar was calculated b y dividing total cost b y the number of respondents identified in the initial information collection request for subpart TT (U.S. EPA, 2010b). Average cost per facility

for subsequent years was calculated by dividing total cost by the number of respondents identified in the most recent information collection request for the GHG reporting program (U.S. EPA, 2013). Appendix A to the initial information collection request for subpart TT (U.S. EPA, 2010b) was used to obtain first year average cost per facility that is incurred from reporting under subpart TT. Cost details from Exhibit 6 .1 of the most recent information collection request for the GHG reporting program (U.S. EPA, 2013) were used to determine the subsequent ye ars average cost per facility . These average costs per facility include labor costs (i.e., the cost of labor by facility staff to meet the rule’s information collection requirements) and non - labor (capital , and operation and maintenance ) costs. Additional details of the data, methods, and assumptions underlying these costs are documented in the information collection requests (U.S. EPA, 201 0b and U.S. EPA, 201 3 ). Table 5 - 35 shows first and subsequent year average cost per facility subject to subpart TT . **Table 5 -**  **35 . An**  **nual Average Cost Per Facility Subject to Subpart T T**  **Subpart Total Number** 

**of Respondents**  **a Total Cost**  **(2011$ per year) Cost Per Facility**  **(2011$ per year) First Year**  **b Subsequent** 

**Years a**  **First Year b**  **Subsequent Years**  **a** TT

– Industrial Waste Landfills 200 1,182,000 881,000 5, 900 4,40 0

a This data was extracted from Exhibit 6 .1 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013). b This data wa s extracted from the “Year 1” table of Appendix A to the initial information collection request for52

subpart T T (U.S. EPA, 2010 b ) . These costs were updated to 2011 dollars using the Bureau of Labor Statistics Em ployment Cost Index and the Chemical Engine ering Plant Cost Index (CEPCI). By revising the GWP values in subpart A, 19 additional facilities will be required to report under subpart TT. The first year cost for these 19 facilities will be approximately $1 12 ,000 per ye ar (19 x $5, 900 = $ 112,300 ), and the annualized industry wide cost is approximately

$ 83,700 per year ( 19 x $ 4,40 0 = $ 83,695 ). An additional eight closed landfills will experience an incremental reporting burden over the next ten year period, due to an extended number of ye ars reporting would be required ; total additional rule implementation costs would be $ 12 0 , 4 00 for these landfills over that ten year period, or an average of $12, 0 00 per ye ar. This includes applying extended subsequent year reporting costs for eight currently closed l andfills that will experience an increased reporting period due to the increased CH 4 GWP, as summed over a ten - year period. A year- over- ye ar breakdown of these costs is included in Section 5.7.5 below. **5.7.4 Subpart TT Small Entity Impacts (new reporters)**  The sm all entity

economic impact was measured using the “sales tests” approach (represented as cost - to - receipt ratios) for NACIS codes associated with the affected subparts in the Economic Impact Analy sis for Subpart TT (U.S. EPA, 2010 a). The same approach is us ed in this analysis for the additional facilities subject to subpart TT due to the revised CH 4 GWP. I f the ratio of rule implementation cost to sales is less than 1%, the impact is not considered to be significant (U.S. EPA, 2010 a). Based on the information provided in Tables 5 - 10 (Number of Establishments) and 5 - 11 (Receipts b y Industry

and Enterprise Size, in 2002 dollars) of the Economic Impact Analysis for Subpart TT (U.S. EPA, 2010 a), the average receipts (sales) for the food processing facil ities with NAI CS codes of 311611, 311411, and 311421 were calculated by dividing the total receipts information by

the number of establishments for each enterprise size. In addition, the average receipts information has been adjusted from 2002 dollars to 2 011 dollars based on the consumer price index published by Bureau of Labor Statistics . These results are shown in Table 5 - 36.

**Table 5 -**  **36. Average Receipts for Each Establishment by Enterprise Size (million, 2011$)**

**NAICS NAICS** 

**Description SBA Size** 

**Standard Ow**  **ned by Enterprises with:**

**1 -**  **19 Em** **ployees 20**  **- 99** 

**Em ployees**  **100 -**  **499**

**Em ployees**  **500 -**  **749**

**Em ployees**  **750 -**  **999**

**Em ployees**  **1,000 -** 

**1,499 Em** **ployees** 311611 Animal (except

Poultry) Slaughtering 500

em ployees 1.31 25.38 D D 1,412.28 D 311411 Frozen Fruit,

Juice, and Vegetable Manufacturing, 500

em ployees 2.47 45.87 10.46 D 234.82 D53 **Table 5 -**  **36. Average Receipts for Each Establishment by Enterprise Size (million, 2011$)**

**NAICS NAICS** 

**Description SBA Size** 

**Standard Ow**  **ned by Enterprises with:**

**1 -**  **19 Em** **ployees 20**  **- 99** 

**Em ployees**  **100 -**  **499**

**Em ployees**  **500 -**  **749**

**Em ployees**  **750 -**  **999**

**Em ployees**  **1,000 -** 

**1,499 Em** **ployees** and 311421 Fruit and

Vegetable Canning 500

em ployees 1.78 20.77 14.77 54.92 139.00 D Note: D denotes that receipt data was not disclosed. Although the number of establishment information has been updated in the 2007 economic census, there is no updated receipts (sales) information for each size of enterprise. According to the cost information listed in Table 5 - 35 , the rule implementation cos ts for subpart TT is $ 5, 900 for the first year and $ 4,40 0 for the subsequent years (in 2011 dollars). The sales tests (cost - to - receipt ratios) results are shown in Table 5 - 37 for the first ye ar and Table 5 - 38 for the subsequent years .

**Table 5**  **- 37**  **. Sales Tests for Subpart TT Facilities: First Year** 

**NAICS NAICS** 

**Description SBA Size** 

**Standard Ow**  **ned by Enterprises with:**

**1 -**  **19 Em** **ployees 20**  **- 99** 

**Em ployees**  **100 -**  **499**

**Em ployees**  **500 -**  **749**

**Em ployees**  **750 -**  **999**

**Em ployees**  **1,000 -** 

**1,499 Em** **ployees** 311611 Animal (except

Poultry) Slaughtering 500

em ployees 0.4 5 % 0.02% D D 0.00% D 311411 Frozen Fruit,

Juice, and Vegetable Manufacturing 500

em ployees 0. 2 4 % 0.01% 0.06% D 0.00% D 311421 Fruit and

Vegetable Canning 500

em ployees 0. 3 3 % 0.03% 0.04% 0.01% 0.00% D Note: D denotes that receipt data was not disclosed.

**Table 5 -**  **3 8**  **. Sales Tests for Subpart TT Facilities: Subsequent Years**

**NAICS NAICS** 

**Description SBA Size** 

**Standard Ow**  **ned by Enterprises with:**

**1 -**  **19 Em** **ployees 20**  **- 99** 

**Em ployees**  **100 -**  **499**

**Em ployees**  **500 -**  **749**

**Em ployees**  **750 -**  **999**

**Em ployees**  **1,000 -** 

**1,499 Em** **ployees** 311611 Animal (except

Poultry) Slaughtering 500

em ployees 0. 3 4 % 0.02% D D 0.00% D 311411 Frozen Fruit,

Juice, and Vegetable Manufacturing 500

em ployees 0. 1 8 % 0.01% 0.04% D 0.00% D 311421 Fruit and 500 0. 2 5 % 0.02% 0.03% 0.01% 0.00% D54 **Table 5 -**  **3 8**  **. Sales Tests for Subpart TT Facilities: Subsequent Years**

**NAICS NAICS** 

**Description SBA Size** 

**Standard Ow**  **ned by Enterprises with:**

**1 -**  **19 Em** **ployees 20**  **- 99** 

**Em ployees**  **100 -**  **499**

**Em ployees**  **500 -**  **749**

**Em ployees**  **750 -**  **999**

**Em ployees**  **1,000 -** 

**1,499 Em** **ployees** Vegetable Canning em

ployees Note: D denotes that receipt data was not disclosed. The results in Table s 5 - 37 and 5 - 38 show that the costs for GHG reporting for the facilities subject to subpart TT is well below 1% of the sales for all size of Waste Management and Remediation S ervices facilities with a NAICS code of 562. Therefore, it was determined that there is not a significant impact on a substantial number of small businesses subject to reporting under subpart TT as a result of this acti on. **5.7.5 Subpart**  **TT (summary of i**  **mpacts )**  Table 5 - 3 9 summarize the impacts of updating the GWP values in Table A - 1 to subpart A, on new facilities required to report subpart TT emissions. The incremental reporting burden is provided in year - over - ye ar format in Table 5 - 40 for both the new reporters and the eight closed facilities that would trigger extended reporting requirements over the following ten ye ars. **Table 5 -**  **39 . New Reporters** **— Summary of Subpart**  **TT Impacts Due to the Revisions to GWPs**  **Facility Type Number of New**  **Reporters Due to GWP**  **Revisions Incremental** 

**CO 2**  **e Emissions for New**  **Reporters (m**  **etric tons of CO**  **2 e per year )**  **a Incremental Cost Impact For New**  **Reporters (2011$ per year)**  **First Year a**  **Subsequent**

**Years a**  TT

– Industrial Waste Landfills 19 520,000 112,000 8 3,700 a Values rounded. The incremental reporting burden is provided in year- over- ye ar format in Table 5 - 22 for both the new reporters and the eight closed facilities that would trigger extended reporting requirements over the following ten ye ars. The costs for closed facilities were calculated based on applying subsequent year costs ($4,400 per facility) to the facilities identified (see Section 5.7.1) in each ye ar for which the facility would be subject to extended reporting requirement s or would be brought into Part 98. No currently active landfills that are planned to shut down in the next ten years were expected to incur prolonged reporting requirements during the next ten years.55 **Table 5 -**  **40 . Summary of Subpart**  **TT Cost Impacts**  **$/year 2015**  **2016 2017**  **2018 2019**  **2020 2021**  **2022 2023**  **2024** Landfills Closed before 2024 8 , 8 00 4, 4 00 4, 4 00 0 8 , 8 00 13, 2 00 1 7 , 6 00 2 3 , 500 1 7 , 600 22 , 000 New Reporters 112,000 83,700 83,700 83,700 83,700 83,700 83,700 83,700 83,700 83,700 Total a 120 , 80 0 88, 100 88, 100 83,700 92, 500 96 , 900 10 1 , 3 00 107 , 200 101 , 300 105 , 700 a Total average Incremental Cost Impact for New Reporters and Reporters with Extended Reporting Requirements is $ 98 , 580 per year. **5.7.6 References for Subpart TT**  U.S. EPA, 2009. Technical Support Document For the Landfill Sector: Proposed Rule For Mandatory Reporting Of Greenhouse Gases . See Docket ID: EPA - HQ - OAR - 2008 - 0508 - 0034. February 4, 2009. U.S. EPA 2010 a . Economic Impact Analysis for the Mandatory Reporting of Greenhouse G as Emissions: Subparts: T, FF, TT, and II. See Docket ID: EPA - HQ - OAR - 2008 - 0508 - 2313. June 2010. U.S. EPA, 2010b. Supporting Statement Part A: Information Collection Request for the Mandatory Reporting of Greenhouse Gases from Magnesium Production, Underground Coal Mines, Industrial Wastewater Treatment, and Industrial Waste Landfills

– Final Rule. OMB Control No. 2060 - 0647. EPA ICR No. 2396.01. July 2010 . U.S. EPA, 2013. Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Rep orting Program. OMB Control No. 2060 - 0629 . EPA ICR No. 2300.10 . May 2013. **6.0 IMPACTS OF**  **OTHER TECHNICAL CORRECTION**  **S AND AMENDMENTS** In addition to the amendments to GWPs, EPA is also finalizing technical corrections and other clarifications to several subpar ts in the GHG reporting rule . In this section, we discuss the potential burden impacts for facilities and reporters affected b y the amendments. The more substantive technical corrections, clarifying and other amendments to the GHG reporting rule are discus sed here. Additional minor corrections are discussed in the memorandum titled “Table of 2013 Technical Corrections, Clarifying and other Amendments to Certain Provisions of the Mandatory

Greenhouse Gas Reporting Rule (40 CFR Part 98),” which is available in the rulemaking docket. **6.1 Subpart A**  **- General Provisions**  The majority

of the revisions to subpart A are associated with changes to additions of GWP values and provisions that apply to facilities that would be required to report based on the revised GWPs. The remaining amendments to subpart A include adding requirements that provide reporters instruction regarding reporting of location, ownership, and facility identification (i.e., reporting of plant codes). The remaining changes also include revising and adding definitions. Except for the amendments related to the GWP changes, the amendments to subpart A are not expected to result in any additional burden for facilities subject to the GHG56

reporting rule. All of the revisions not related to the GWP changes a re either clarifications, or require reporting of information that facilities are expected to have readil y available (e.g., latitude and longitude of the facility). **6.2 Subpart C**  **- General Stationary Fuel Combustion Sources**  For subpart C, EPA is expanding the use of the Tier 1 methodology to be used for Table C - 1 fuels that are combusted in a unit with a maximum rated heat input capacity greater than 250 mmBtu/hr, if the fuel provides less than 10 percent of the annual heat input to the unit and the use of Tier 4 is not required . Expanding the use of the Tier 1 methodology is expected to reduce monitoring burden for facilities that are subject to the requirements of subpart C and combust small amounts of secondary fuels. EPA is also revising several emission f actors and higher heating values (HHVs) for fuels in Table C - 1 including, but not limited to, coals and coke, liquefied petroleum gases (e.g. propane, prop yl ene, ethane, etc.), wood and wood residuals, and biogases. Of the changes to emission factors, the change with the largest percent difference (approximately 11 percent) is the emission factor for coke (which is also being revised to read “coal coke”). Approximately 1.6 percent of facilities that reported under subparts C and D for reporting ye ar 2011 in dicated using coke as a fuel for combustion in addition to other fuels . The majority of coal coke produced (92 percent) in the United States is used in blast furnaces for the conversion of iron ore into iron (U.S. EPA, 2001) . The emission factor for coal coke is not used in the calculation of CO 2 emissions for iron furnaces . Due to the small number of facilities that reported using coke as a fuel , and because facilities do not ty picall y use coke as the primary fuel, we do not expect any additional facilities would be required to report due to an increase in calculated CO 2 emissions resulting from the increase to the coke emission factor in Table C - 1. All of the other revisions are either clarifications, or require reporting of information that faci lities are expected to have readily available (plant code for each power generating unit). **6.3 Subpart H**  **– Cement Production**  EPA is requiring annual, facility- wide cement production instead of monthly , kiln specific cement production for facilities that use a CEMS to measure CO 2 emissions. Because facilities already expected to track facility- wide cement production for budgeting purposes, we do not expect this revision to result in any additional burden for cement pro duction facilities. **6.4 Subpart K**  **– Ferroalloy Production**  EPA is finalizing two changes to subpart K. The first change corrects a conversion factor in equation K- 3 and we do not expect any additional reporter burden as a result. The second change requires facilities to report the annual process CH 4 emissions from each electric arc57

furnace (EAF) used for the production of any ferroalloy listed in Table K - 1 of subpart K. Because facilities must already monitor and calculate emissions of CH 4 from each EAF, we do not expect that the changes would impose and additional burden on reporters. The data element reflects aggregated annual information that is currently gathered b y reporters. **6.5 Subpart**  **L –**  **Fluorinated Gas Production** EPA is extending temporary , less detailed reporting requirements to allow EPA time to evaluate concerns raised by producers regarding the potential sensitivity of the more detailed reporting required b y the 2010 final rule. A s the revision would be an extension of existing requirements, we do not anticipate any additional reporter burden as a result. **6.6 Subpart N**  **– Glass Production**  In addition to clarify

several requirements and equations terms, EPA is revis ing the monitoring methods used to measure carbonate - based mineral mass - fractions to allow for more accurate measurement methods and provide flexibility for reporters. EPA is requiring that facilities use consensus standards that specify X - ray fluorescence (XRF). To determine if requiring XRF methods would impose any additional burden, we compared the cost of the currentl y required methods to methods using XRF. The costs of ASTM D - 3682 and D - 6349 are listed as $165 from Wyoming Anal ytical Laboratories (WAL). The costs of similar anal ys es using XRF (ASTM D - 4326) range from $165 to $195 according to WAL (WAL , 2009) . Based on the similarity

in cost, we do not believe that revising the measurement methods to specify XRF will impose any

additional burden on f

acilities subject to subp art N. **6.7 Subpart P**  **– Hydrogen Production**  EPA is finalizing several amendments to subpart P including adding flexibility for monitoring and measurement methodologies and removing redundant reporting requirements. EPA is also finalizing changes that clarify rule text and equation terms. None of the amendments for subpart P are expected to impose any additional burden on reporters. **6.8 Subpart Q**  **– Iron and Steel Production**  EPA is finalizing multiple amendments to subpart Q to clarify certain provisions and calculati on methods. Two of the revisions may potentially

affect the reporting burden for facilities covered under subpart Q. First, EPA is including direct reduction furnaces not co located with an integrated iron and steel manufacturing process, as these furnaces were inadvertentl y excluded from the original rulemaking. Because this change only impacts one facility that is already

reporting under subpart Q, we do not anticipate this change will impose any additional burden on reporters.58

Second, EPA is amending E quation Q - 5 in subpart Q to account for the use of gaseous fuels in EAFs. Because facilities currentl y determine the mass rate of fuels using the procedures in subpart C and must report the annual volume of gaseous fuels, we do not expect that reporters wi ll need to collect or record any additional information to account for the use of gaseous fuels in equation Q - 5 in subpart Q. Therefore, we do not expect any additional burden will be imposed on reporters subject to subpart Q. **6.9 Subpart X**  **– Petrochemical Pro**  **duction** EPA is finalizing several substantial changes to subpart X. EPA is requiring reporters using CEMS to determine CO 2 emissions to use Equation C - 10 of subpart C to Part 98 to calculate CH 4 and N 2 O emissions from burning process off - gas. We do not exp ect an increase in burden since Tier 4 units can use best available information to estimate fuel use (see 40 CFR 98.22(c)(4)(i) and 40 CFR 98.33(c)(4)(ii)(C)). EPA is also finalizing several changes for those reporters that use the mass balance calculatio n method. First, EPA is allowing flexibility for the source of the carbon measurements for feedstocks and products. Next, EPA is allow ing the alternative sampling requirements for feedstocks and products when the composition is greater than 99.5 percent of a single compound to be used during all times that the average monthly concentration is above 99.5 percent. Additionally , EPA is allow ing the inputs for gaseous feedstock and products to be measured on either a mass basis or on a volume basis in Equation X - 1. EPA is also allow ing facilities to use industry standard practices for the anal ys is of carbon black feedstock oils and carbon black products, instead of a specified list of standards currentl y provided in 40 CFR 98.244(b)(4). We do not anticipate any additional burden as a result of these changes since they allow additional flexibility for reporters. EPA is clarifying the requirements for flares to specify that facilities must conduct monitoring and quality assurance in accordance with 40 CFR 98. 254(b) through (e) for each flare gas flow meter, gas composition meter, and/or heating value monitor that is used to comply with 40 CFR 98.253(b)(1) through (3) , which was EPA’s original intent. We are specifying in the final amendments that reports must impl ement the applicable QA/QC requirements b y J anuary 1, 2015. Since the change is a clarification, we do not expect any additional burden as a result. EPA is clarifying the missing data procedures for missing feedstock and product flow rates, missing feedstock and product carbon contents, and missing molecular weights for gaseous feedstocks and products. EPA is also adding missing data requirements for flares. Because these amendments only

clarify the existing missing data procedures for subpart X facilities , we do not expect these amendments will impose any additional burden on reporters.59

Additionally , EPA is finalizing several amendments to reporting requirements. The majority of amendments to the reporting requirements are clarifications; however, one par ticular amendment would require facilities to identify combustion units that burned both process off - gas and supplemental fuel and that are not part of the petrochemical process unit. EPA is also finalizing a requirement for facilities to provide an estimate of the fraction of total CO 2 emissions that result from CO 2 directly emitted by the petrochemical process unit plus CO 2 generated b y the combustion of off - gas from the petrochemical process unit (based on engineering judgment) if the CEMS monitoring loc ation meets the conditions in 40 CFR 98.426(b)(2) or (3). Although these are new reporting requirements, facilities would not be required to install any additional monitoring equipment or develop any additional monitoring and record keeping procedures; therefore, we do not expect these additional reporting requirement to significantl y increase burden for facil ities reporting under subpart X. **6.10 Subpart Z**  **– Phosphoric Acid Production**  EPA is finalizing several clarifying amendments to subpart Z, phosphoric acid production. Of those amendments, EPA is changing the reporting requirement of the annual permitted phosphoric acid production capacity to the annual phosphoric acid production capacity . We do not expect this change to impose any additional burden on report ers since the information should be readily available in facility

records. EPA is also adding a reporting requirement to report the number of times missing data procedures were used to estimate the CO 2 content of the phosphate rock. Again, we do not expec t any additional burden for reporters as a result of this change because facilities are already required to keep records for estimating missing values of CO 2 content of phosphate rock per 40 CFR 98.265(a), and no new information would need to be collected . **6.11 Subpart AA**  **– Pulp and Paper Production**  EPA is correcting emission factors and clarifying the information that must be reported under subpart AA. First, EPA is removing the references to site - specific emission factors in 40 CFR 98.273(a)( 3), 40 CFR 98.276(e) and Equation AA - 1. EPA is also correcting printing errors, inadvertent omissions, and inconsistencies from Table AA - 1 and AA - 2. We do not anticipate any additional burden due to these changes since no additional reporting requirements or monitoring would be required. EPA is also amending the reporting requirement for the annual pulp and/or paper production information that must be reported. EPA is clarifying that the annual production information must consist of the production of unble ached virgin pulp produced onsite during the reporting year and removed the proposed requirement that the production of paper products exiting the paper machine(s) during the reporting year, prior to application of any off - machine6 0

coatings be reported . In the final amendments we removed the proposed requirement to report a positive (non - zero) value for pulp production. EPA clarified the production reporting requirement under 40 CFR 98.276(k) in the “Frequently Asked Questions” section of EPA’s supporting website for the GHG reporting rule. In their guidance, EPA specified that facilities should report virgin chemical pulp production at the mill separate from the mass of paper product exiting all of the paper machine(s) at the mill; therefore, EPA is clarifying the reporting requirement and removing the requirement to report paper production . N o new reporting or monitoring would be required by reporters. As a result, we do not expect the clarification to the rule to impose any additional burden on reporters. **6.12 S**  **ubpart BB –**  **Silicon Carbide Production** For subpart BB, Silicon Carbide Production, EPA is removing the requirement for facilities to report CH 4 emissions from silicon carbide process units or furnaces. Additionall y, EPA is amending subpart BB such that fac ilities would calculate and report CO 2 emissions for all process units and furnaces combined, instead of each process unit or production furnace. The remaining changes to subpart BB either support these amendments, or provide minor clarifications of the rule text. We expect that both of these major changes will reduce the reporting burden for facilities subject to subpart BB. **6.13 Subpart DD**  **– Electrical Transmission and Distribution Equipment Use**  EPA is finalizing two technical corrections to subpart DD to correct the accuracy and precision requirements for weighing cylinders. Instead of scale accuracies of “2 pounds of the scale’s capacity ,” EPA is revising the rule to be consistent with their original intention of “2 pounds of true weight.” This accuracy requirement was noted in the technical support document to subpart DD, EPA’s response to public comments for subpart DD 7 , and the preamble to the final Part 98 (74 FR 56260, October 30, 2009). Intheir response to comments, EPA noted that a “2 pounds of true we ight” requirement would be less burdensome tha n the 1 percent of true weight requirement originally proposed; therefore, we do not expect any added burden would result from amending the rule to reflect EPA’ s original intent. **6.14 Subpart FF**  **– Underground Coal**  **Mines** EPA finalizing numerous amendments to subpart FF. The majority of the changes include terminology

revisions that more accuratel y reflect industry operations, correction of subscript errors, and minor clarifications of rule text. More substantially , E PA is including the reporting of the following data elements: the moisture correction factor used in the emissions equations ; units of measure for the volumetric flow rates reported ; method of determining the gas composition ; the start date and close date of each well , shaft, or vent hole; the number of days the well , shaft , 7 For more information, refer to http://www.epa.gov/ghgreporting/reporters/subpart/dd.html61

or vent hole was in operation during the reporting year ; the amount of CH 4 routed to each destruction device ; and the identification number assigned b y the Mine Safety and Health Admini stration (MSHA). All of these data elements are readily available to reporters and would not require additional data collection or monitoring; therefore, we do not expect the changes to subpart FF would impose any significant additiona l burden to covered f acilities. **6.15 Subpart HH**  **– Municipal Solid Waste Landfills**  For subpart HH, EPA is removing the option to used measured values for the degradable organic carbon content in Equation HH - 1. EPA is also clarifying that the fraction by volume of CH 4 in the landfill gas, used in Equation HH - 1, should be corrected to zero percent oxygen. Additionally , EPA is reducing the measurement frequency for sampling methane concentrations from weekl y to monthly for the parameter “N” in Equation HH - 4. To clarify how to calculate methane emissions at landfills with gas collection systems that have multiple measurement locations and/or multiple destruction devices, EPA is amending Equations HH - 6, HH - 7, and HH 8 and surrounding text to generalize these equations and to refer to oxidation fractions in Table HH - 4 . EPA is finalizing the o xidation fraction values in Table HH - 4 as proposed, with the exception that we are limiting the landfills that can use these new methane flux - dependent oxidation fractions to those that have cover soils of 24 inches or more over a majority of the landfill area containing waste. EPA is also making several more minor clarifications and amendments including removing duplicative reporting requirements. We are finalizing amendments that methane recovery calcul ated using Equation HH - 4 and the annual operating hours of the gas collection sy stems are to be reported separately for each measurement location . Because 40 CFR 98.343(b)(1) and (2) require use of Equation HH - 4 separately for each monitoring location , it is clear that the methane recovery and the fraction of hours the recovery sy stem operated needs to be determined separatel y for each measurement location as these are separate inputs for Equations HH - 6 and HH - 8 when multiple measurement locations are used. Since this change is a clarification, we do not expect any additional burden as a result. W e are making one revision to subpart HH based on comments received on the expansion of applicability

that will occur in the MSW L andfill sector due to the revision of the GWP for methane to the IPCC AR4 value. Specifically , we are providing a very limited exclusion within 40 CFR 98.340 for certain closed landfills that have not previously had to rep ort under subpart HH, but would newl y be required to report starting in reporting ye ar 2014 because the amended methane GWP causes them to exceed the 25,000 metric tons CO 2 e emissions threshold for the first time. We have added this exclusion to reduce the burden for these closed landfills, who would otherwise be required to estimate historical waste quantities and develop their first annual report , as discussed in Section 5.4 of this document.62

Facilities are not required to report any additional data elements, or implement any additional monitoring equipment or procedures a s a result of these amendments. Therefore, we do not expect any

additional burden for reporters subject to subpart HH as a result of these revisions. **6.16 Subpart LL**  **– Suppliers of Coal**  **- based Liquid Fuels**  EPA is finalizing several amendments to subpart LL. In addition to clarifying reporting requirements, EPA is removing the requirements at 40 CFR 98.386(a)(1), (a)(5), (a)(13), (b)(1) and (c)(1) for each facility, importer, and exporter to report the annual quantity of each product or natural gas liquid on the b asis of the measurement standards method or industry standard practice used. We expect a reduction in burden for reporters subject to subpart LL since EPA is removing reporting requirements from the r ule. **6.17 Subpart MM**  **– Suppliers of Petroleum Products**  In addition to several minor correction and clarifications, EPA is finalizing several substantial technical corrections for subpart MM. First, EPA is amending the equipment calibration requirements for petroleum products suppliers to be consistent with other Par t 98 calibration requirements to allow for postponement of calibrations for units and processes that operate continuously

with infrequent outages and therefore provide flexibility for reporters meeting the equipment calibration requirements. Next, EPA is removing the requirements of 40 CFR 98.396(a)(1), (a)(5), (a)(13), (b)(1) and (c)(1) for each facility , importer, and exporter to report the annual quantity of each petroleum product or natural gas liquid on the basis of the measurement standard method or industry standard practice used. EPA is also removing the requirements of 40 CFR 98.396(a)(4), (a)(8), (a)(15), (b)(4), and (c)(4) for each facility , importer, and exporter to report a complete list of methods used to measure the annual quantities reported for each product or natural gas liquid. In another step to reduce recordkeeping and reporting burden, the reporting requirements for crude oil at 40 CFR 98.396(a)(20) are changed to require onl y the annual quantity of crude oil. EPA is also eliminating the requirement to measure the API gravity of each batch of crude oil at 40 CFR 98.394(d). EPA is adding and revis ing several definitions and revising the default density and emission factors in Table MM - 1 in subpart MM. We expect that the changes to subpart MM will provide additional flexibility for reporters and reduce the reporting and recordkeeping burden for those facilities required to report under subpart MM. **6.18 Subpart NN**  **– Suppliers of Natural Gas Liquids**  EPA is finalizing several technical corrections to subpart NN. In addition to minor changes, EPA is finalizing several amendments that may affect the reporting burden of facilities subject to subpart NN. First, EPA is amending the definition of Local Distribution Companies63

(LDS) to clarify

that for LDCs that operate in multiple states, the operations in each state are considered a separated LDC. EPA is also clarifying that interstate and intrastate pipelines delivering natural gas either directly to major industrial users or to farm taps upstream of the LDC inlet are not included in the definition of an LDC. We do not expect these clarifications to impose any

additional burden on reporters. In “Q286” of the “Frequentl y Asked Questions” section of EPA’s supporting website for the GHG reporting rule , EPA ini tially clarified its intent that the owner/operator of each LDC that is regulated as a separate operating company b y State public utility

commissions or that operate as independent municipally

–owned distribution sy stems must submit an annual report. Theref ore, the clarifications are a follow - up to previous guidance and we do not expect any additional owners/operators would be required to report as a result of the change. EPA is also changing the calculation and reporting requirements that require LDCs to report the annual volume of natural gas delivered to each meter registering supply equal to or greater than 460,000 million standard cubic feet (Mscf). EPA is finalizing a requirement that if the LDC knows based on readil y available information that multipl e meters serve one large end user facility (defined in the final rule as a facility receiv ing a total of greater than 460,000 Mscf during the ye ar) , the LDC would be required to report these deliveries per facility rather than per meter . If the LDC does no t know if the series of meters serve an individual end user or multiple facilities , the LDC may

continue to report deliveries to individual meters. Because LDCs would be able to report on a per facility , rather than per meter basis, we expect a reduction in the reporting burden as a result of this change. EPA is amending part of the calculation methodology in subpart NN. Subpart NN currentl y require s the use of a single emission factor for all types of gas streams accounted for in Equation NN - 5. Because th e characteristics of these streams may differ, EPA is replacing equation NN - 5 with two equations, NN - 5a and NN - 5b. The greenhouse gas quantity associated with the net amount of natural gas that is placed into or removed from storage during the ye ar is to be c alculated using equation NN - 5a. Emissions that would result from the combustion or oxidation of natural gas received b y the LDC that by passed the city gate are calculated using Equation NN - 5b, which allows th e use of different emission factors for different streams of gas. Additionally , EPA is changing Equation NN - 6 to incorporate the two NN - 5 equations. Reporters would only

be required to modify

their calculation methodology and would not be required to inst all any

additional monitoring equipment. Therefore, we do not expect any additional burden on facilities required to report under subpart NN as a result of these changes. EPA is also requiring the reporting of the quantity of o - grade, y- grade, and other ty pes of bulk natural gas liquids (NGL s) received, and the quantity not fractionated, but supplied downstream. We do not anticipate that reporters would be required to purchase or install any new64

monitoring equipment as a result of these reporting requirements since (per 40 CFR 98.404(a)(1) ) fractionators and LDCs are required to determine quantities using methods in common use in the industry for billing purposes as audited under existing Sarbanes Oxley regulation. **6.19 Subpart QQ**  **– Importers of Exporters of Flu**  **orinated Greenhouse Gases Contained in Pre**  **- Charged Equipment of Closed Cell Foams**  EPA is finalizing multiple revisions to subpart QQ. In addition to minor corrections and clarifications, EPA is removing the following reporting requirements: 40 CFR 98.436(a)(5), (a)(6)(iv), (b)(5), and (b)(6)(iv). We expect that the removal or reporting requirements will alleviate reporting burden for facilities required to report under subpart QQ. **6.20 Subpart RR**  **– Geologic Sequestration of Carbon Dioxide**  In addition to minor c orrections and clarifications to subpart RR, EPA is adding a reporting requirement for facilities to report the standard or method used to calculate the mass or volume of contents in containers that is redelivered to another facility without being injected into the well. The data element does not require additional data collection or monitoring from reporters, and as it is not a significant change. Therefore, we do not expect that this amendment would add burden to reporting entities. **6.21 Subpart TT**  **– Industria**  **l Waste Landfills** EPA is finalizing multiple changes to subpart TT. EPA is revising definitions in Equation TT - 1 and TT - 7 and to correct Equation TT - 7 by deleting an erroneous term. EPA is also making a change to clarify

that the number of waste streams fo r which Equation TT - 1 is used includes the number of "Inert" waste streams disposed of in the landfill. Additionally , EPA is expanding the provisions to determine volatile solids concentration for historicall y managed waste streams so that they

may also be used for determining a site - specific DOC value for historically managed waste streams. EPA is also eliminating duplicative reporting requirements and to clarify the requirements for reporters when using Equations TT - 4a or TT - 4b. EPA is finalizing amendments to revise the oxidation fraction default value (“OX”) in Equation TT - 6 to reference the new default oxidation factors in Table HH - 4; however, we have revised the amendments to limit the new oxidation factors to landfills with soil c overs of at least 24 inches for a majority of the landfill area containing waste, and to allow the continued use of the 0.10 default oxidation factor for facilities that do not meet these requirements. EPA is also making changes to Table TT - 1 to include th e DOC default value of 0.09 for “Industrial Sludge,” and the corresponding k- values. None of the changes to subpart TT would require any additional monitoring or recordkeeping and reporting b y facilities, therefore we do not anticipate any additional burden as a result of the changes to subpart TT.65

**6.22 Subpart UU**  **– Injection of Carbon Dioxide**  EPA is finalizing technical amendments to subpart UU. In particular , EPA is adding two reporting requirements. First, reporters would be required to report the purpose of CO 2 injection. Second, facilities would be required to report the standard or method used to calculate the parameters for CO 2 received in containers. Neither of these reporting requirements would require facilities to collect any additional data or instal l and operate any additional monitoring equipment. As a result, we do not expect the changes would impose any additional significant burden on facilities required to report un _) der subpart UU. **6.23 Additional Subparts with Corrections**  EPA is finalizing several changes to subpart s E, G, O, S, V, Y, II, PP , and SS ; however, all of the changes are clarifications and /or corrections for consistency throughout the subparts. Therefore, we do not expect any additional burden for facilities subject to the reporting requirements of subpart E, G, O, S, V, Y, II, PP , and SS as a result of these changes . **6.24 References for**  **Section 6**  U.S. EPA, 2001. National Emission Standards for Hazardous Air Pollutants (NESHAP) for Coke Ovens: Pushing, Quenching, and Battery Stacks

– Background Information for Proposed Standards. EPA - 453/R 01 - 006. Available at: http://www.epa.gov/ttn/atw/coke2/coke2p_bid.pdf . WAL, 2009. Wyoming Analytical Laboratories, Inc. Prices as of Spring 2009. Available at: http://www.wal - lab.com/DownloadFiles/CementFlyAsh%20SoilsOverb.pdf .

## Appendix A **GWPs –** **Revisions to Table A -**  **1**A - **1 Appendix A: GWPs**  **Revisions to Table A** **- 1 of**  **Subpart A**

**Nam e**  **CAS No. Chemical F**  **ormula Table A**  **- 1**  **Global W**  **arming P**  **otential (100 yr.)**  **New or**

**Revised Global**  **W arming**  **P otentials**  **(100 yr.) Increase**  **% Increase**  Carbon Dioxide CO 2 1 1 -- -- Methane 74 - 82 - 8 CH 4 21 25 4 19% Nitrous oxide 10024

– 97

–2 N 2 O 310 298 - 12 - 4% HFC

–23 75

–46

– 7 CHF 3 11,700 14 , 800 3 , 100 26% HFC

– 32 75

– 10

– 5 CH 2 F 2 650 675 25 4% HFC

–41 593

–53

–3 CH 3 F 150 92 - 58 - 39% HFC

– 125 354

–33

–6 C 2 HF 5 2,800 500 - 2 , 300 - 82% HFC

– 134 359

–35

–3 C 2 H 2 F 4 1,000 1 , 100 100 10% HFC

– 134a 811

–97

–2 CH 2 FCF 3 1,300 1 , 430 130 10% HFC

– 143 430

–66

–0 C 2 H 3 F 3 300 353 53 18% HFC

– 143a 420

–46

–2 C 2 H 3 F 3 3,800 4 , 470 670 18% HFC

– 152 624

–72

–6 CH 2 FCH 2 F 53 53 0 0% HFC

– 152a 75

– 37

– 6 CH 3 CHF 2 140 38 - 102 - 73% HFC

– 161 353

–36

–6 CH 3 CH 2 F 12 12 0 0% HFC

–227ea 431

– 89

–0 C 3 HF 7 2,900 3 , 220 320 11% HFC

–236cb 677

–56

–5 CH 2 FCF 2 CF 3 1,340 1 , 340 0 0% HFC

–236ea 431

–63

–0 CHF 2 CHFCF 3 1,370 1 , 370 0 0% HFC

–236fa 690

–39

– 1 C 3 H 2 F 6 6,300 9 , 810 3 , 510 56% HFC

–245ca 679

– 86

–7 C 3 H 3 F 5 560 693 133 24% HFC

–245fa 460

–73

– 1 CHF 2 CH 2 CF 3 1,030 1 , 030 0 0% HFC

– 365mfc 406

–58

–6 CH 3 CF 2 CH 2 CF 3 794 794 0 0% HFC

–43

– 10mee 138495

–42

– 8 CF 3 CFHCFHCF 2 CF 3 1,300 1 , 640 340 26% Sulfur hexafluoride 2551

– 62

–4 SF 6 23,900 22 , 800 - 1 , 100 - 5% Trifluoromethyl sulphur pentafluoride 373

– 80

– 8 SF 5 CF 3 17,700 17 , 700 0 0% Nitrogen trifluoride 7783

– 54

–2 NF 3 17,200 17 , 200 0 0% PFC

– 14 (Perfluoromethane) 75

– 73

–0 CF 4 6,500 7 , 390 890 14% PFC

– 116 (Perfluoroethane) 76

– 16

–4 C 2 F 6 9,200 12 , 200 3 , 000 33% PFC

–218 (Perfluoropropane) 76

– 19

– 7 C 3 F 8 7,000 8 , 830 1 , 830 26% Perfluorocyclopropane 931

–91

–9 C - C 3 F 6 17,340 17,340 0 0% PFC

– 3

– 1

– 10 (Perfluorobutane) 355

–25

–9 C 4 F 10 7,000 8 , 860 1 , 860 27% Perfluorocyclobutane 115

–25

–3 C - C 4 F 8 8,700 10 , 300 1 , 600 18% PFC

–4

– 1

– 12 (Perfluoropentane) 678

–26

–2 C 5 F 12 7,500 9 , 160 1 , 660 22% PFC

– 5

– 1

– 14 355

–42

–0 C6F14 7,400 9 , 300 1 , 900 26%A - **2 Appendix A: GWPs**  **Revisions to Table A** **- 1 of**  **Subpart A**

**Nam e**  **CAS No. Chemical F**  **ormula Table A**  **- 1**  **Global W**  **arming P**  **otential (100 yr.)**  **New or**

**Revised Global**  **W arming**  **P otentials**  **(100 yr.) Increase**  **% Increase**  (Perfluorohexane) PFC

– 9

– 1

– 18 306

–94

–5 C 10 F 18 7,500 7 , 500 0 0% HCFE

–235da2 (Isoflurane) 26675

–46

– 7 CHF 2 OCHClCF 3 350 350 0 0% HFE

–43

– 10pccc (H

– Galden 1040x) E1730133 CHF 2 OCF 2 OC 2 F 4 OC HF 2 1,870 1 , 870 0 0% HFE

– 125 3822

– 68

–2 CHF 2 OCF 3 14,900 14 , 900 0 0% HFE

– 134 1691

– 17

–4 CHF 2 OCHF 2 6,320 6 , 320 0 0% HFE

– 143a 421

– 14

–7 CH 3 OCF 3 756 756 0 0% HFE

–227ea 2356

– 62

– 9 CF 3 CHFOCF 3 1,540 HFE

–236ca12 (HG

– 10) 78522

–47

– 1 CHF 2 OCF 2 OCHF 2 2,800 2 , 800 0 0% HFE

–236ea2 (Desflurane) 57041

– 67

– 5 CHF 2 OCHFCF 3 989 989 0 0% HFE

–236fa 20193

– 67

– 3 CF 3 CH 2 OCF 3 487 487 0 0% HFE

–245cb2 22410

–44

–2 CH 3 OCF 2 CF 3 708 708 0 0% HFE

–245fa1 84011

– 15

–4 CHF 2 CH 2 OCF 3 286 286 0 0% HFE

–245fa2 1885

–48

– 9 CHF 2 OCH 2 CF 3 659 659 0 0% HFE

–254cb2 425

– 88

–7 CH 3 OCF 2 CHF 2 359 359 0 0% HFE

–263fb2 460

–43

–5 CF 3 CH 2 OCH 3 11 11 0 0% HFE

– 329mcc2 67490

– 36

–2 CF 3 CF 2 OCF 2 CHF 2 919 919 0 0% HFE

– 338mcf2 156053

– 88

–2 CF 3 CF 2 OCH 2 CF 3 552 552 0 0% HFE

– 338pcc13 (HG

– 01) 188690

–78

–0 CHF 2 OCF 2 CF 2 OCHF 2 1,500 1500 0 0 % HFE

– 347mcc3 28523

– 86

– 6 CH 3 OCF 2 CF 2 CF 3 575 575 0 0% HFE

– 347mcf2 E1730135 CF 3 CF 2 OCH 2 CHF 2 374 374 0 0% HFE

– 347pcf2 406

–78

–0 CHF 2 CF 2 OCH 2 CF 3 580 580 0 0% HFE

– 356mec3 382

–34

–3 CH 3 OCF 2 CHFCF 3 101 101 0 0% HFE

– 356pcc3 160620

–20

–2 CH 3 OCF 2 CF 2 CHF 2 110 110 0 0% HFE

– 356pcf2 E1730137 CHF 2 CH 2 OCF 2 CHF 2 265 265 0 0% HFE

– 356pcf3 35042

– 99

–0 CHF 2 OCH 2 CF 2 CHF 2 502 502 0 0% HFE

– 365mcf3 378

– 16

–5 CF 3 CF 2 CH 2 OCH 3 11 11 0 0% HFE

– 374pc2 512

–51

–6 CH 3 CH 2 OCF 2 CHF 2 557 557 0 0% HFE

–449s 1 (HFE

– 7100) Chemical blend 163702

–07

–6 163702

–08

–7 C 4 F 9 OCH 3

(CF 3 ) 2 CFCF 2 OCH 3 297 297 0 0% HFE

– 569sf2 (HFE

– 7200) Chemical blend 163702

–05

–4 163702

–06

–5 C 4 F 9 OC 2 H 5

(CF 3 ) 2 CFCF 2 OC 2 H 5 59 59 0 0 % Sevoflurane 28523

– 86

– 6 CH 2 FOCH(CF 3 ) 2 345 345 0 0 % HFE

– 356mm1 13171

– 18

– 1 (CF 3 ) 2 CHOCH 3 27 27 0 0%A - **3 Appendix A: GWPs**  **Revisions to Table A** **- 1 of**  **Subpart A**

**Nam e**  **CAS No. Chemical F**  **ormula Table A**  **- 1**  **Global W**  **arming P**  **otential (100 yr.)**  **New or**

**Revised Global**  **W arming**  **P otentials**  **(100 yr.) Increase**  **% Increase**  HFE

– 338mmz1 26103

–08

–2 CHF 2 OCH(CF 3 ) 2 380 380 0 0 % (Octafluorotetramethy lene)hydroxymethyl group NA X - (CF 2 ) 4 CH(OH) - X 73 73 0 0 % HFE

– 347mmy1 22052

– 84

–2 CH 3 OCF(CF 3 ) 2 343 343 0 0 % Bis(trifluoromethyl) - methanol 920

–66

– 1 (CF 3 ) 2 CHOH 195 195 0 0% 2,2,3,3,3 - pentafluoropropanol 422

–05

–9 CF 3 CF 2 CH 2 OH 42 42 0 0 % PFPMIE NA CF 3 OCF(CF 3 )CF 2 OCF 2 OCF 3 10,300 10 , 300 0 0%