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MEMORANDUM

TO : Rachel Schmeltz, EPA

FROM : Tracy Curtis, Brandon Long, Denise Bevington

, ERG

DATE : December 10

, 2015

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

Reporting Rule

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

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

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

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

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

GGRT )

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

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

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

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

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

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

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

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

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

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

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

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

year

. One

- time implementation costs would apply for certain revisions to applicability and monitoring revisions that would be implemented in RY 2017 and RY 2018; therefore, t o

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

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

Table 2.1 T otal Incremental Burden for Reporting Years 2016

- 2019 ($ 2011 /year)
Cost Summary RY 2016 RY 2017 RY 2018 RY 2019
First Year Costs $9,359 $ 25,650 $ 1,972,555

-- Subsequent Year Annual Costs for Changes Implemented in:

2016

-- $ 8,132 $ 8,132 $9,359
2017

-- -- $ 25,650 $ 25,650
2018

-- -- -- $ 1,046,821 Total Costs by Year (all subparts) $9,359 $ 33,782 $ 2,006,337 $ 1,081,830



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

1) Revise applicability such that additional facilities would be required to report under Part 98. EPA is proposing revisions that would expand the applicability of two subparts of Part 98: subpart V (Nitric Acid Production) and subpart OO (Suppliers of
Indus trial Greenhouse Gases).

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

. The EPA is proposing to add or revise 118 reported data elements in 21 subparts of Part 98 in order to improve the data quality of the GHGRP . EPA is also proposing to remove 18 data elements in five subparts to streamline rule requirements.

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

. EPA is proposing changes to the monitoring requirements of subp art FF of Part 98 (Underground Coal Mines) to remove the option to allow U.S. Mine Safety and Health Administration ( MSHA ) quarterly inspection reports to be used as a source of data for monitoring methane liberated from ventilation systems . Instead, facil ities would be required to independently collect their own grab samples on a quarterly
basis or use continuous emissions monitoring.

The schedule for the proposed revisions and the estimated incremental burden on reporters for each of these t hree categori es of changes are discussed in section 2.1. The methodology for estimating the change in burden for the subparts affected by these changes is
discussed in Section 3.0 of this document.

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

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

2.1 Implementation Schedule and Summary of Burden by Subp art

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

Table 2. 2 Implementation Schedule by Sub part
Reporting Year Subparts Affected
2016 I, HH, A (harmonizing revisions to §98.6)

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

2018 V, Y, FF, OO, A (harmonizing revisions to § 98.7 (l) and Table A

- 5)



### As noted above, to quantify the burden associated with the proposed amendments, the estimated incremental change in burden was calculated for amendments that : 1 ) revise applicability such that additional facilities would be required to report; 2) change the r eporting requirements by adding, revising, or removing existing data elements; or 3) revise monitoring requirements such that facilities would need to collect additional data. Revisions to reporting requirements would be implemented in RY 2016, RY 2017, and RY 2018 on a subpart basis and include annual labor costs. Revisions to monitoring requirements (subpart FF only) would be implemented in RY2018 ; the burden associated with these proposed revisions includes both
annual burden and o ne

- time implementation cos ts that would apply for RY201 8 . Revisions that affect the applicability of subparts (subparts V and OO only) would be implemented in RY2018; the burden associated with these proposed revisions includes both annual burden and o ne

- time implementation costs t hat would apply for RY2018

.

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

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

Subpart Costs for Additional

Reporters Costs for Revisions to Reporting Costs For Revisions to

Monitoring Provisions Total Cost

First Year Subsequent

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

O $0 $0 $106 $ 106 $0 $0 $106 $ 106
P b $0 $0 $0 $0 $0 $0 $0 $0 Q b $0 $0 $0 $0 $0 $0 $0 $0

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

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

CC $0 $0 $33 $ 33 $0 $0 $33 $ 33
DD $0 $0 $ 2,000 $ 2,000 $0 $0 $ 2,000 $ 2,000
II $0 $0 $2,562 $2,562 $0 $0 $2,562 $2,562
LL c $0 $0

- $17

- $17 $0 $0

- $17

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

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

RR d $0 $0 $0 $0 $0 $0 $0 $0
TT b $0 $0 $0 $0 $0 $0 $0 $0

UU b $0 $0 $0 $0 $0 $0 $0 $0 Total Costs for Changes Implemented in RY2017 $ 25,650 $ 25,650 Changes Implemented in RY2018
V $83,544 $66,403 $1 29 $ 129 $0 $0 $83,6 73 $ 66,531
Y $0 $0 $1,448 $ 1,448 $0 $0 $1,448 $ 1,448
FF $0 $0 $ 2,066 $ 2,066 $ 1,848,57 1 $ 949,58 2 $ 1,850,638 $ 951,648
OO $36,215 $26,612 $ 582 $ 582 $0 $0 $36, 797 $27, 194 Total Costs for Changes Implemented in RY2018 $ 1,972,555 $ 1,046,821 Total Cost (All Subparts) $119,759 $93,015 $ 39,23 4 $ 38,007 $ 1,848,57 1 $ 949,582 $ 2,006,337 $ 1,081,830

a Costs for subpart I include new data elements related to the triennial technology report required by §98.96(y). The first rep ort must be submitted with RY2016 reports on March 31, 2017 and every three years thereafter. For the p urposes of estimating burden , the annual costs associated with the data elements were includ ed for RY2016 and RY2019 (Table 2.1) and not for RY2017 or RY2018

. b The proposed changes to this subpart include only minor revisions, c larifications, and corrections that have no impact on the burden to reporters.

c This entry is a negative value because five data elements were removed from the reporting requirements of subpart LL and no new data elements were added or current data elements revised for the subpart, resulting in a net cost savings for this source category.

### 6 d There is no increase in costs for the new data element proposed to be reported under subpart RR ( Geologic Sequestration of Carbon Dioxide ) because there are no fa cilities currently reporting, or projected to report, under this source category in the next three years.


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

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

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

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

non

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

r evising, or r emoving r eporting r equirements , we determined that these facilities will experience
annual impacts of roughly $ 11 per facility. Because this cost is minimal, no small entity impacts are anticipated for facilities subject to the revisions that add, revise, or remove reporting requirements.

3.0 METHODOLOGY FOR ESTI MATING BURDEN

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

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

3.1.1.1 Identifying New Reporters For subpart V, EPA is proposing to change the definition of the source category t o require reporting from all reporters that produce nitric acid, regardless of the nitric acid strength. The source category definition for subpart V in Part 98 is currently based on the New Source Performance Standard (NSPS) in 40 CFR Part 60, which is on ly applicable to weak nitric acid (specifically between 30 percent and 70 percent in strength). When the GHGRP was published in 2009, only one nitric acid plant in the United States produced nitric acid greater than 70 percent

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in strength (i.e., strong nit ric acid). In the interim, further research has indicated the existence of three other nitric acid trains capable of producing strong nitric acid, including one existing plant and two potential plants becoming operational as early as the end of 2015 (s ee t he memorandum, “Re: Strong Nitric Acid Facilities in the U.S.” from Natalie Tang, EPA to Alexis McKittrick and Mausami Desai, EPA, dated January 29, 2015, in Docket Id. No. EPA

- HQ

- OAR

- 20 15

- 0526 )

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

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

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

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

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

- depleting substances (ODSs) to EPA under the Stratospheric Protection Program. Because fluorinated GHGs are chemically similar to ODSs, are manufactured and imported by many of the s ame facilities and companies that manufacture and import ODSs, and are used in many of the same applications as ODSs, the set of facilities destroying fluorinated GHGs is likely to be similar to the set of facilities destroying ODSs. These facilities inclu de hazardous waste treatment facilities that use a variety of different destruction technologies such as plasma arc and combustion. Facilities destroying very small quantities of ODSs were excluded from the total because similar quantities of fluorinated G HGs appeared unlikely to equal or exceed the proposed 25,000 mtCO2e threshold (using an average GWP of 2000). For the purposes of estimating burden, an average of 8 new reporters were assumed to be required to report under Part 98. T here is no anticipated impact on small businesses as a result of these changes (see Section 4.23 of this document for a discussion of small entity impacts.)

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

### e of fluorinated HTFs or GHGs . We anticipate that few, if any, suppliers of fluorinated HTFs would be required to b egin reporting under this provision because all suppliers of fluorinated HTFs are believed to report under subpart OO already. One possible exception is facilities that destroy but do not produce or import

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fluorinated HTFs, but this group of facilities is included in the set of destructi on facilities discussed above. Therefore, no additional reporters were assumed to be required to report based on the proposed changes. The costs for existing suppliers to report additional information for
fluorinated heat tr ansfer fluids are accounted for in section 3. 2 of this document.

3.1.1.2 Estimating Cost Impacts

The cost impacts for new reporters subject to subparts V and OO were calculated by multiplying the average costs per facility and the number of new facilities estima ted to be subject to each subpart. Average costs per facility were calculated using data from the most recent information collection request for the GHG RP (May 2013) 1 

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

. 2



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

- time costs for respondents from Appendix G

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

- 3, resp ectively. 3



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

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

. For subpart V reporters, average first year and subsequent year costs per facility also
include costs obtained from Table 1 of the information collection request for the “Revisions to Reporting and Recordkeeping Requirements, and Proposed Confidentiality Determinations under the Greenhouse Gas Reporting Program” (August, 2013). 4 

### These average costs per facility
in clude first year labor costs to comply with initial training for the Inputs Verification Tool ($66

1 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.

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

- 0629, ICR number 2300.12. August 2013.

3 One

- time costs from App endix G

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

. 06 ) that would apply to first

- time reporters.

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

- 0629; ICR number 2300.12.

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per facility) and first year and subsequent year costs to comply with annual reporting of new data elements ($33 per facility).

To obtain costs for new repo rters under subparts V and OO, the average cost per facility was applied to the number of new facilities anticipated to report under the proposed
amendments. Table 3. 1 summarizes the impacts to new facilities required to report subpart V and
OO emissions.

Table 3. 1

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

Subpart Number of

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

First Year a Subsequent

Years b First Year a Subsequent Years b

V

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

OO

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

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

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

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

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

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

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

- 3, respectively. These costs and the “One

- Time Costs” are based on an estimated 45 respondents (in lieu of 37) for subpart V and 167 respondents (in lieu of 49) f or subpart OO. These costs were updated to 2011 dollars using the Bureau of Labor Statisti cs Employment Cost Index and Chemical Engineering Plant Cost Index (CEPCI). ($19,700 per subpart V facility and $3,400 per subpart OO facility. ) 3. For subpart V, the es timate includes first year labor costs to comply with initial training for the Inputs Verification Tool ($66 per facility) and first year costs to comply with annual reporting of new data elements ($33 per facility) per ICR 2300.12.
b Th ese data w ere extracted from Exhibit 6 .1 of the Supporting Statement Part A: Information Collection Request for t he Greenhouse Gas Reporting Program (U.S. EPA, 2013).



### 3.2 Revisions That Add, Revise, or Remove Reporting Requirements EPA is proposing to add or revise 118 re ported data elements in 21 subparts of Part 98 in order to improve the data quality of the GHGRP and to remove 18 data elements in five subparts to streamline rule requirements. These revised reporting requirements would apply to existing reporters under P art 98, as well as new reporters who would be required to submit annual reports under the proposed revisions.

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Table 3. 2 shows the number of new, revised, and removed data elements in each subpart;

t he specific data elements that EPA is proposing to add, r evise, or remove in the 2015 Revisions

are included in Section 4.0 of this document.

Table 3. 2 GHG Reporting Rule Subparts with Proposed New, Revised, or Removed Data Elements

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

Revised Data Elements No. of

Deleted Data Elements

A General Provisions 6

- - C General Stationary Fuel Combustion Sources 3

- -

E Adipic Acid Production 1 0 0

F Aluminum Production 2 0 0

G Ammonia Manufacturing 3 0 0

I Electronics Manufacturing 7 0 0

O HCFC

- 22 Production and HFC

- 23 Destruction 1 10 3

S Lime Manufacturing (non

- CEMS) 3 0 0

V Nitric Acid Production 1 0 0

X Petrochemical Production 3 2 0

Y Petroleum Refineries 7 3 7

Z Phosphoric Acid Production 0 1 0

CC Soda Ash Manufacturing 2 0 0

DD Use of Electric Transmission and Distribution Equipment 7 0 2

FF Underground Coal Mines 5 0 0

HH Municipal Solid Waste Landfills 2 1 1

II Industrial Wastewater Treatment 1 4 0

LL Suppliers of Coal based Liquid Fuels 0 0 5

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

OO Suppliers of Industrial Greenhouse Gases 4 1 0 0

RR Geologic Sequestration of Carbon Dioxide 1 0 0



### All costs to the regulated industry resulting f rom the changes in Table 3.2 are labor costs (i.e., the cost of labor by facility staff to collect , calculate, and submit information via e

- GGRT ). The change in burden was calculated for each subpart by determining the annual labor hours required to review the new, revised, or remove d data elements and applying labor costs.

Total annual labor hours

. The change in technical labor hours associated with proposed revisions that add, revise, or remove reported data elements w as calculated by multiplying the number of data elements that were added, substantially revised (such that different data is

### 11

required to reported) , or removed in each subpart (i.e., number of data elements added plus the number of data elements revised, minu s the number of data elements removed) by the number of hours required to review each data element. EPA assumed 3 minutes of technical labor to calculate each data element using readily available data and to submit the value via e

- GGRT as part of the annua l report. Managerial and clerical labor hours were then estimated as 5% and 10% of the total technical hours required, respectively.

Annual hourly estimates were then determined for each subpart based on the number of
reporters that would be anticipated to be require d to report each new and revised data element or cease reporting each removed data element. For each subpart except subparts A, C, V, and OO, the incremental change in the hourly labor was multiplied by the number of existing reporters for

eac h subpart (for reporting year 2013) to obtain total annual hourly estimates by labor category. Because subparts A and C apply to a large number of reporters, burden for these subparts was estimated by multiplying the incremental change in hourly labor by t he number of existing reporters in each subpart that would be anticipated to be required to report each new data element. Because the proposed changes to subparts V and OO would expand applicability and add reporters, burden for these subparts was estimate d by multiplying the incremental change in hourly labor by the total number of existing reporters and anticipated new reporters to which the new data elements would apply. The estimated number of reporters affected by new data elements in subparts A, C, V, and OO are described below.

For subpart A, the number of existing reporters who would be affected by each of the six
new data elements was estimated as summarized in Table 3. 3

.

### 12

Table 3. 3 Number of Existing Reporters Affected by New Data Elements in Subpart A

Data Element (s) No. Reporters Affected Rationale

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

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

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

GGRT identification number of the reconstituted facility no later than March 31 of the year following such cha nges

. 51 The requirement to report the e

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

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

new e

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

luorinated heat transfer fluid (HTF), the CAS registry or SRS number

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

one

- time requirement

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



### For subpart C, the number of existing reporters who would be affected by each of the proposed three new data elements was estimated as summarized in T able 3. 4

.

### 13

Table 3. 4 Number of Existing Reporters Affected by New Data Elements in Subpart C
Data Element (s) No. Reporters Affected Rationale

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

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

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

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

- 1 an d C

- 8

. 132 The requirement to report moisture content applies only to those facilities that calculate wet basis HHV for wood and wood residuals. The number of reporters affected was determined by identify the number of facilities that reported for wood and wood residuals in the recent reporting year

.



### For subparts V and OO, burden was estimated based on the total number of existing and new reporters to which the new data elements would apply. For subpart V, EPA is proposing to
revise the definition of th e source category to require reporting from all reporters that produce nitric acid, regardless of the nitric acid strength (see section 3. 1 of this document for additional information). The number of reporters who would be affected by the one new data elem ent include the total number of existing reporters for reporting year 2013 (35) and four new facilities that produce strong nitric acid.

As discussed in section 3.1 of this document, E PA is proposing to revise the scope of subpart OO to include reporting of fluorinated HTFs that are not fluorinated GHGs

, and to expand applicability to destruction facilities that do not currently report as a producer, importer, or exporter under subpart OO

. The number of reporters that would be required to report the new data elements was estimated based on the number of existing reporters under Part 98 to which the new data elements would apply (i.e., the number of existing reporters expected to report
fluorinated heat transfer fluids that are not also fluorinate d GHGs), and the number of new destruction facilities that would be newly required to report under subpart OO, as described in
section 3. 1 . For subpart OO, because all suppliers of fluorinated HTF are believed to currently report, the revised reporting of fluorinated HTFs that are not fluorinated GHGs would most likely only affect two or three existing suppliers of fluorinated HTFs. These three suppliers would be required to report 40 new data elements related to fluorinated HTFs. As discussed in
section 3. 1 , the estimated number of new reporters that would be required to report under subpart

### 14

OO includes eight destruction facilities that do not currently report as a producer, importer, or exporter under subpart OO ; these facilities would be required to repor t seven of the new data
elements that relate to destruction facilities

. Therefore, the total burden was estimated based on three reporters reporting 40 new data elements and eight reporters reporting seven new data
elements. F or additional information, inc luding a list of those new data elements that would apply to existing and new reporters under subpart OO , see section 4.23 of this document

.

T otal labor costs

. Once total annual hour estimates were obtained for each subpart, the
total labor costs for each subpart were estimated. To calculate labor costs, Bureau of Labor
Statistics estimates were us ed in an approach consistent with the ICRs associated with the GHGRP currently approved by OMB. 5 

### For all subparts the labor rates are: $59.12 for technical
worker s, $77.23 for managers, and $31.35 for clerical support. These labor costs were applied to the total annual hour estimates for each labor category to obtain the total costs for each subpart.
These costs are summarized in Table 3. 5 of this document.

The total annual labor hours and the total labor costs for each subpart are assumed to be equal for the first and subsequent years (i.e., the data elements are required to be reported in each year), with the exception of subpart I. For subpar t I, the seven new data elements in the proposed rule pertain to the triennial technology report required under 40 CFR 98.96(y) . The first report must be submitted with RY2016 reports no later than March 31, 2017 and every three years thereafter. For the purposes of estimating burden for this rulemaking, the annual burden and
costs associated with the subpart I data elements were calculated for RY2016 and RY2019 (see Table 2.1 of this document)

.

5 May 2011 National Industry

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

### 15 Table 3. 5 Labor Hours and Costs for New, Revised, and Removed Data Elements by Subpart

Item Subpart

A b A c A d A e C f C g E F G I h O S V X Y Z CC DD FF HH II LL NN OO i RR Total

# Affected Reporter s a 319 310 166 51 132 3,540 3 11 23 53 4 75 3 9 65 146 12 5 121 125 1,230 155 1 530 11 0 7,127 j

# New Data Elements 3 1 1 1 1 2 1 2 3 7 1 3 1 3 7 0 2 7 5 2 1 0 1 41 1 9 7
# Revised Data Elements 0 0 0 0 0 0 0 0 0 0 10 0 0 2 3 1 0 0 0 1 4 0 0 0 0 2 1

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

Respondent Hours

Technical 48 16 8 3 7 177 0.15 1.10 3.45 18.55 1.60 11.25 1. 9 5 16.25 21.90 0.60 0.50 30.25 31.25 123.00 38.75

- 0.25 26.50 8.80 0.00 593

Clerical 5 2 1 0 1 18 0.02 0.11 0.35 1.86 0.16 1.13 0. 20 1.63 2.19 0.06 0.05 3.03 3.13 12.30 3.88

- 0.03 2.65 0. 88 0.00 59 Managerial 2 1 0 0 0 9 0.01 0.06 0.17 0.93 0.08 0.56 0. 10 0.81 1.10 0.03 0.03 1.51 1.56 6.15 1.94

- 0.01 1.33 0 .44 0.00 30

Total 55 18 10 3 8 201 0.17 1.27 3.97 21.33 1.84 12.94 2. 24 18.69 25.19 0.69 0.58 34.79 35.94 141.45 44.56

- 0.29 30.48 10.12 0.00 682
Respondent Costs
Technical $2,829 $916 $491 $151 $390 $10,464 $9 $65 $204 $1,097 $95 $665 $1 15 $961 $1,295 $35 $30 $1,788 $ 1,848 $7,272 $2,291

- $15 $1,567 $ 520 $0 $ 35,082

Clerical $150 $49 $26 $8 $21 $555 $0 $3 $11 $58 $5 $35 $ 6 $51 $69 $2 $2 $95 $ 98 $386 $121

- $1 $83 $ 28 $0 $ 1,860 Managerial $185 $60 $32 $10 $25 $683 $1 $4 $13 $72 $6 $43 $ 8 $63 $85 $2 $2 $117 $ 121 $475 $150

- $1 $102 $ 34 $0 $ 2,291

Total $3,164 $1,025 $549 $169 $436 $11,703 $10 $73 $228 $1,226 $106 $744 $1 29 $1,074 $1,448 $40 $33 $2,000 $ 2,066 $8,132 $2,562

- $17 $1,752 $ 582 $0 $ 39,234

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

b The total number of affected facilities required to report subpart A data elements §98.3(c)(4)(iii)(G) and §98.3(c)(5)(ii) re lated to identifying the chemical name, CAS registry or SRS number, and the linear chemical formula. Applicable to facilities [ § 98 .3(c)(4)(iii)(G)] and suppliers [ § 98.3(c)(5)(ii)] that report under the following subparts: I, F, L, O, OO, DD, SS, QQ.

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

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

e The number of affected facilities required to report the subpart A data element §98.2(i)(6) for a notification to t he Administrator that announces the discontinuation of reporting and the e

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

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

g The total number of affected facilities required to report either subpart C data element §98.36(c)(1)(iii) or subpart C data element §98.36(c)(3)(ii); applicable to 3,540 facilit ies that report heat input capacity for either the GP or CP configuration

. h Costs for the seven new data elements in subpart I are related to the triennial technology report [§98.96(y)]. The first report must be submitted with RY2016 reports by March 31, 2017 and every three years thereafter. For the purposes of estimating burden, the annual costs associated with the data elements were calculated for RY2016 and RY2019 (see Table 2.1 of this document) and not for RY2017 or RY2018

. i Includes the number of new and existing reporters anticipated to be affected by the addition of new data elements to subpart OO. Note that 34 of the 41 new data elements would only apply to 3 existing reporters that would report data related to fluorinated HTFs that are not fluo rinated GHGs, 1 data element would apply only to 8 new reporters that are destruction facilities not currently reporting under subpart OO, and 6 data elements related to destruction of fluorinated HTFs would apply to both the 8 new and 3 existing reporters

. Additional information on the data elements that apply to reporters under subpart OO are discussed in Section 4.23 of this document. j The number of respondents subject to the required activities was estimated separately for each subpart, and in situations where a facility reports under multiple subparts, the facility was counted once per subpart (e.g., facilities that report emissions under both subpart X and subpart C were counted as separate facilities un der each subpart). As a result, the actual total number of respondents that will perform the required activities for each year across all subparts is lower than estimated.

### 16

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

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

### The analysis also estimates the costs
for facilities that would use CEMS. The ARI analysis accounts for differences in costs between mines that already take quarterly grab samples and those that use MSHA data or are new reporting mines. Currently, about 50 percent of subpart FF reporters already collect quarterly gas samples. For mines that currently use MSHA data and new reporting mines , the annual incremental costs for taking grab samples on a quarterly basis was estimated as the cost o f taking the samples, less the avoided cost of obtaining, interpreting and reporting MSHA data.

For the proposed rulemaking, the incremental costs to the regulated industry resulting
from changes to the monitoring requirements for Underground Coal Mines a re based on the cost methodology and assumptions provided by ARI for the collection of independent monthly grab samples in ventilation air. It was assumed that facilities would not install a CEMS as a result of the monitoring changes. The costs resulting f rom removing the use of MSHA quarterly data include additional labor costs, capital costs (e.g., the costs of anemometers or sample kits, for reporters that are not currently conducting sampling), and the cost asso ciated with gas sample analysis . Hourly la bor costs were estimated based on the number of labor hours for developing the sampling methodology and purchasing the devices, and the number of hours required for sampling. No costs were estimat ed f or mines that already take grab samples ; it was assumed that they have an adequate monitoring plan in place with the necessary equipment, thus there are no additional labor hours associated with developing a methodology

, purchasing equipment , and sampling, and no additional capital costs.

Using the cost method ology and assumptions provided by ARI, l abor, operating and maintenance (O&M), and capital costs were estimated in $2011. To calculate labor costs, labor

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

### 17

rates published by the Bureau of Labor Statistics were used

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

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

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

- wide cost burden.

Table 3.6 Annual Incremental Cost Per Mine for R 

### emoving the Option to Allow MSHA Quarterly Inspection Report Data Cost Category Year 1 Subsequent Years
Labor a $ 17,281 $ 7,913

O & M b $ 6,696 $ 6,696 Capit a l c ,d $4,463 $ 0

Total $ 28,440 $ 14,609

a Labor costs include costs for developing sampling methodology, accompanying inspectors, send ing samples, and purchasing devices.

b Operating and Maintenance ( O&M ) costs include the cost for gas analysis for sampling 3 s hafts per mine on a quarterly basis ( 3 x 4 = 12 samples per year ).

d Capital costs include the cost of 4 air sample kits and 2 anemometers.



### Table 3.7 Annual Ind u s try

- wide Incremental Cost Burden for Monthly Sampling

Current Monitoring Number of Mines Year 1 Subsequent Years

Annual incremental cost for mines currently using MSHA data and new reporting mines
Labor 65 $1,123,236 $514,342

O & M $435,240 $435,240 Capitol $290,095 N/A

Total Cost $1,848,571 $949,582



### 4.0 IMPACTS BY INDIVIDUAL SUBPAR T

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

. Specifically, this section summarizes for each subpart :

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

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

### 18

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

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

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

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

4.1 Subpart A

– General Provisions Revisions to Subpart A that Impact Burden

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

. These data elements are information that reporters are expected to have readily available, therefore, burden was estimated as
described in Section 3. 2 of this document.

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

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

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

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

supplier that is already rep orting GHG data under this part

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

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

. New

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

fluid (HTF), the chemical name. New

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

fluid (HTF), the CAS registry or SRS number

. New

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

fluid (HTF), the linear c hemical formula. New

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

be included in the annual GHG report. New



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

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

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

- ramp ” provisions apply to suppliers and direct emitters

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

### 19

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

- ramp” provisions apply for :

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

 A bandoned underground coal mines

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

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

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

rea sons for the cessation of operation

.

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

- days at least 5

- days prior to their current due date. The proposed change would str eamline the reporting requirements, however, because the reporter would still be required to submit a request for an extension prior to the end of their current due date, no change in burden is expected.

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

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

4.2 Subpart C

- General Stationary Fuel Combustion Sources

Rev isions to Subpart C that Impact Burden. The proposed revisions would add three
new data element s to s ubpart C, as shown in Table 4.2. These data elements are information that reporters are expected to have readily available, therefore, burden was estimated as described in
Section 3. 2 of this document.

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

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

rated heat input capacity of the group

. New

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

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

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

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

- 1 and C

- 8

. New

### 20

Revisions to Subpart C with No or Minimal Impact on Burden

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

- 1 and C

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

4.3 Subpart E

– Adipic Acid Production Revisions to Subpart E that Impact Burden

. EPA is proposing revisions that would add

one new data element to subpart E , as shown in Table 4.3

. This data element requires information that reporters are expected to have readily available, therefore, burden was estimated
as described in Section 3. 2 of this document.

Table 4.3 New, Revised, or Remove d Data Elements in Subpart E

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



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

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

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

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

. T his proposed change is anticipated to generally reduce burden to reporters using the alternative calcu lation method, however, t he reporter would be required to notify EPA that they are using an already approved alternative testing method when they submit their annual report. By requiring requests only for new approvals or for methods that have changed sinc e prior approval, EPA burden required to review and approve the methods would
also be reduced. Because this change applies only to reporters who elect to use an alternative calculation method, this change is expected to have no significant impact on burden

. There are no other changes to subpart E in the proposed rule.

### 21

4.4 Subpart F

– A luminum Production Revisions to Subpart F that Impact Burden

. EPA is proposing two new data elements in subpart F, as shown in Table 4.4. These data elements are information that reporters are expected to have readily available, therefore, burden was estimated as described in Section 3. 2 of this
document.

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

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

- specific information on an annual basis: (2)

Anode effect minutes per cell

- day (AE

- mins/cell

- day), anode effect frequency (AE/cell

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

98. 66(c)(3) Smelter

- specific slope coefficient (or overvoltage emission factors) New



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

. EPA is also proposing

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

, and would have no impact on burden.

4.5 Subpart G

– Ammonia Manufacturing Revisions to Subpart G that Impact Bur den

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

. These data elements are information that reporters are expected to have readily available, therefore,
burden was estimated as described in Section 3. 2 of this document.

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

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

units reported within subpart G). New

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

ammonia manufacturing New

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



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

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

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

### 22

4.6 Subpart I

– Electronics Manufacturing Revisions to Subpart I that Impact Burden.

The proposed amendments would add 7 dat a reporting requirements to the content of the triennial technology report for subpart I reporters, as shown in Table 4.6 . These data elements are information that reporters are expected to have readily available, therefore, burden was estimated
as describ ed in Section 3. 2 of this document.

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

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

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

processes

. New

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

. New



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

. EPA is proposing to revise Equation I

- 24 to incorporate two changes :

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

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

 Create a second equation (Equation I

- 24B) to calculate the weighted

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

The revisions to Equation I

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

EPA is also proposing several minor c orrections and clarification to subpart I of Part 98, including editorial changes, harmonizing changes, and clarifications to reporting requirements.
These minor revisions are summarized in the Table of Revisions and would have no impact on
burden.

### 23

4.7 Subpart N

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

4.8 Subpart O

– HCFC

- 22 Production and HFC

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

- 22 production and HFC

- 23 emissions fo r each HCFC

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

, revise
10 existing reporting requirements

, and remove three reporting requirements as shown in Table
4.7. The new a nd revised data elements are information that reporters are expected to have readily available. Burden was estimated for these data elements as described in Section 3. 2 of
this document.

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

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

98.156(a)(1) The HCFC

- 22 production facility shall report the following

information from each HCFC

- 22 production process: Annual mass of HCFC

- 22 produced in metric tons. Revised from a facility

level basis to a process

level basis

98.156(a)(3) The HCFC

- 22 production facility shall report the following

information from each HCFC

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

level bas is to a process

level basis

98.156(a)(4) The HCFC

- 22 production facility shall report the following

information from each HCFC

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

- 22 and HFC

23 (i.e., unreacted reactants, HCl and othe r by

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

level basis to a process

level basis

98.156(a)(5) The HCFC

- 22 production facility shall report the following

information from each HCFC

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

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

level basis to a process

level basis

98.156(a)(6) The HCFC

- 22 production facility shall report the following

information from each HCFC

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

- 23 was sent for destruction Revised from a facility

level basis to a process

level basis

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

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

98.156(a)(6) The HCFC

- 22 production fac ility shall report the following

information from ea ch HCFC

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

- 23 was sent for destruction Revised from a facility

level basis to a process

level basis

98.156(a)(6) The HCFC

- 22 production facility shall report the following

information from each HCFC

- 22 production process: The quantities of HFC

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

level basis to a process

level basis

98.156(a)(11) The HCFC

- 22 production facility shall rep ort the following

information from each HCFC

- 22 production process: Annual mass of HFC

- 23 emitted in metric tons. Revised from a facility

level basis to a process

level basis

98.156(a)(12) The HCFC

- 22 production facility shall report the following

informa tion from each HCFC

- 22 production process: Annual mass of HFC

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

level basis to a process

level basis

98.156(a)(13) The HCFC

- 22 production facility shall report the following

information from each HCFC

- 22 production process: Annual mass of HFC

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

level basis to a process

level basis

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

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

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

- 23 at the outlet of the

destruction device. Removed

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

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

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



### 4.9 Subpart Q

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

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

### , CH 4 

### , and N 2 

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

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

4.10 Subpart S

– Lime Manufacturing EPA is proposing to revise subpart S to require reporting of three new data elements , as shown in Table 4.8. These data elements are information that r eporters are expected to have readily available, therefore, burden was estimated as described in Section 3. 2 of this document. There are no other changes to subpart S in the proposed rule.

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

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

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

by lime type that is sold

. New

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

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

. New



### 4.11 Subpart V

– Nitric Acid Production Revisions to Subpart V that Impact Burden

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

Revisions to applicability. EPA is proposing to change the definition of the source category in 40 CFR 98.220 to require reporting from all reporters that produce nitric acid, regardless of the nitric acid strength. These changes are anticipated to result in approximately four new report ers under subpart V, which would result in an increase in burden for this subpart.
The methodology for determining new reporters and the cost impacts for n ew reporters subject to subpart V are described in Section 3. 1 of this document.

Revisions to report ing requirements. The EPA is proposing the addition of one data
element to subpart V as shown in Table 4.9. The proposed data element would apply to both new and existing reporters. This data element requires information that reporters are expected to have readily available, therefore, burden was estimated as described in Section 3. 2 of this document.

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

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



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

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

### O) emissions f

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

. By requiring requests only for new approvals or for methods that have changed since prior approval, EPA burden required to review and approve the methods would

### 26

also be reduced. Because this change applies only to reporters who elect to use an alternative calculation method, this change is expected to have no significant impact on burden.

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

Small Entity Impact Analysis

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

- to

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



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

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

Owned by Enterprises with:
1

- 19 Employees 20

- 99

Employees 100

- 499

Employees 500

- 999

Employees 1,000

- 1,499

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

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

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

- (a) Note from 2012 economic census database

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



### According to the cost information listed in Table 3. 1 , the rule implementation costs for subpart V are $20,886 for the first year and $16,601 for subsequent years (in 2011 dollars). The sales tests (cost

- to

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

years.

7 U.S. EPA. 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.

### 27 Table 4.11 Sales Tests for Subpart V F acilities Owned by Enterprises with:

1

- 19 Employees 20

- 99

Employees 100

- 499

Employees 500

- 999

Employees 1,000

- 1,499

Employees
Sales Test

- First Year 0.41% 0.10% 0.18% 0.17%

- Sales Test

- Subsequent Years 0.33% 0.08% 0.14% 0.14%

-



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

4.12 Subpart X

– Petrochemical Production Revisions to Subpart X that Impact Burden. EPA is proposing to amend the subpart X reporting requirements to add three new data elements and to revise two data e lements, as sh own in Table 4. 12 . These data elements are information that reporters are expected to have readily available, therefore, burden was estimated as described in Section 3. 2 of this document.

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

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

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

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

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

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

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

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

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

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

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

.



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

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

### , CH 4 

### , and N 2 

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

.

EPA is also proposing to revise s ubpart X to clarify how integrated ethylene dichloride ( EDC ) manu facturers would perform the mass balance calculations. Subpart X currently requires integrated EDC manufacturers to perform the mass balance around operations involved in the

### 29

production of the EDC, including situations where EDC is produced as an intermedi ate in the production of vinyl dichloride monomer ( VCM )

. Under the existing rule, integrated EDC and
VCM manufacturers could incur burden from modifying the ir process es to enable measurement
of an intermediate EDC stream

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

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

.

4.13 Subpart Y

– Petroleum Refineries

Revisions to Subpart Y that Impact Burden

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

. The new and revised data elements are information that reporters are expected to have readily available. B urden was estimated for these
data elements a s described in Section 3. 2 of this document.

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

flare gas recovery system New

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

- 1a of §98.253, either the annual

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

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

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

throughput of the unit, in bbl/stream day New

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

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

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

CH4) for the delayed coking unit Revised from cumulative facility

- basis to unit

- basis.

### 30 Table 4. 1 3 New, Revised, or Removed Data Elements in Subpart Y
Citation Data Element(s) New, Revised, or Removed 98.256(k)(5) The total number of delayed coking vessels (or coke

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

- basis to unit

- basis. 98.256(k)(6) The basis for the typical dry mass of coke in the delayed

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

- 18a). New

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

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

- 18c or pressure correlation and Equation Y

- 18d). New

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

- specific methane

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

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

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

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

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

dimensions, the number of coking drums in the set

. Removed

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

dimensions, the mole fraction of methane in coking gas

. Removed

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

vessel prior to steaming

. Removed

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

ga s. Removed

98.256(k)(6) (existing) If you use Equation Y

- 19 of this subpart, the relevant

information required under paragraph (l)(5) of this section for each set of coke drums or vessels of the same si ze. Removed



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

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

### emissions from delayed coking units in Equation Y

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

The proposed revisions also require reporters to determine the mass of water in the coke drum based on the height of water in the coke drum and the mass of coke in the coke dr um. Reporters would use one of two methods to estimate the average temperature of the coke bed

### 31

contents: 1) a method based on the measured overhead temperature of the drum, and 2) a method based on the overhead pressure using a temperature

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

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

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

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

- 18/Y

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

- specific
emissions estimate. If a unit

- specific methane emissions factor is not available, reporters would

use a default methane emissi ons factor for DCU of 7.9 kg methane

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

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

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

4.14 Subpart Z

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

. This data element requires information that reporters are expected to have readily available, therefore, burden was estimated as described in Section 3. 2 of
this document. There are no additional changes to subpart Z in the proposed rule.

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

(tons) for each wet

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

### 32

4.15 Subpart AA

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

. EPA is proposing to:

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

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

- GGRT CEMS web forms and associated verification checks and documentation

, and would make no s ignificant changes in burden for reporters.

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

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

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

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

 Clarifying edits to the labels in Table AA

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

, ” and to add a footnote to Table AA

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

4.16 Subpart CC

– Soda Ash Manufacturing

Revisions to Subpart CC that Impa ct Burden

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

. These data elements are information that reporters are expected to have readily available, therefore, burden was estimated as described in
Section 3. 2 of th is document.

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

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

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

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

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

### 33

Revisions to Subpart CC with No or Minimal Impact on Burden

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

4.17 Subpart DD

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

. These data elements are information that reporters are expected to have readily available, therefore, burden was estimated as described in Section 3. 2 of
this document. There are no additional changes to subpart DD in the proposed rule.

Table 4. 1 6 New, Revised, or Removed Data El ements in Subpart DD

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

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

- pressure switchgear during the year. New

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

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

- insulated equipment other than hermetically sealed

- pressure switchgear during the year. New

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

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

- pressure switchgear during the year. New

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

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

- insulated equipment other than hermetically sealed

- pressure switchgear during the year. New

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

state or territory New

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

(1) New hermetically sealed

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

- insulated equipment other than hermetically sealed

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

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

- insulated equipment other than hermetically sealed

- pressure switchgear during the year. New

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

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

- insulated equipment, including hermetically sealed

- pressure switchgear)

. Removed

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

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

- insulated equipment, including hermetically sealed

- pressure switchgear)

. Removed

### 34

4.18 Subpart FF

– Underground Coal Mines Revisions to Subpart FF that Impact Burden

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

.
Revisions that expand monitoring requirements . EPA is proposing to amend 40 CFR 98.324(b) to no longer allow MSHA quarterly inspection reports to be used as a source of data for monitoring methane liberated from ventilation systems. Instead, the facility will be required

to use either of the two other methods to monitor methane released from mine ventilation
systems: independently collected quarterly grab samples or continuous emissions monitoring systems (CEMS). Because the proposed changes could require reporters to implement their own sampling, an increase in burden has been calculated for these changes. The burden increase anticipated from these monitoring revisions is discussed in Section 3.3 of this document.

The EPA is proposing additional changes to subpart FF that are necessary to ensure consistency with the proposal to remov e the option to use MSHA quarterly inspection report
data . These changes do not present any additional burden.

Revisions to reporting requirements . EPA is proposing revisions to subpart FF that wou ld
add five data elements to the reporting requirements, as shown in Table 4. 17

. Burden was
estimated for these data elements as described in Section 3. 2 of this document.

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

Citation Data Element(s) New, Revised, or Removed 98.326(f) Specify whether the volumetric flow rate measurement at each

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

98.326(g) Specify whether the CH4 concentration measurement at each

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

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

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

98.326(i) Specify whether the CH4 concentration measurement at each

degasification monitori ng point is on dry basis or wet basis. New

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



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

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

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

### concentration from a specific mine

### 35

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

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

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

. Small Entity Impact Analysis

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

- to

- receipt ratios) for
the NAICS code associated with the affected subpart in the Economic Impact Analysis for Subparts FF. The same approach is used in this analysis for the facilities subject to the subpart

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



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

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

- HQ

- OAR

- 2008

- 0508

- 2313. June 2010.

### 36

Table 4.18 Receipts, Number of Establishments, and Average Receipts for Bituminous Coal

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

- 19 Employees 20

- 99

Employees 100

- 499

Employees 500

- 999

Employees 1,000

- 1,499

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

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

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

-

(a) Note from 2012 economic census database

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



### According to the cost information listed in Table 3.7 , the rule implementation costs for subpart F F are $ 28,440 for the first year and $ 14,609 for subsequent years (in 2011 dollars). The sales tests (cost

- to

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

years.

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

- 19 Employees 20

- 99

Employees 100

- 499

Employees 500

- 999

Employees 1,000

- 1,499

Employees
Sales Test

- First Year 1.20 % 0.29 % 0.06 % 0.04 %

- Sales Test

- Subsequent Years 0.62 % 0.15 % 0.03 % 0.02 %

-



### The results in Table 4.19 show that the costs for the rule revisions for facilities subject to subpart FF are below 1 percent of the sales for size categories with greater than 20 employees for Bituminous Coal Underground Mining facilities with a NAICS code of 212112

. The sales test exceeded 1 percent for the 1

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

4.19 Subpart HH

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

, add two data elements

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

. The new and revised data elements are

### 37

information that reporters are expected to have readily available. Burden was estimated for these
data elements as described in Section 3. 2 of this document.

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

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

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

determined on an area

- weighted average basis (Option 1) or a volume

- weighted average basis (Option 2) New

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

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

- 6 of this subpart or Equation HH

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

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

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

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

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

each cover type. Removed



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

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

 Revisions to Table HH

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

- based weighting approach or a volume

- based weighting approach.

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

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

 S everal changes to Table HH

- 4 to revise and clarify the soil cover requirements

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

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

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

### 38

 To a dd a footnote to Table HH

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

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

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

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

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

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

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

.

4.20 Subpart II

– Industrial Wastewater Treatment

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

. These data elements are information that reporters are

### 39

expected to have readily available, therefore, burden was estimated as described in Section 3. 2 of
this document.

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

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

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

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

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

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

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



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

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

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

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

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

4.21 Subpart LL

– Suppliers of Coal

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

. The change in burden from the removal
of these data elements was estimated as described in Section 3. 2 of this document.

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

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

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

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

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

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

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

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

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

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

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



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

.

4.22 Subpart NN

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

. This data element requires information that reporters are expected to have readily availa ble, therefore, burden was estimated
as described in Section 3. 2 of this document.

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

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

this report submission. New



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

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

.

4.23 Subpart OO

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

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

### 41

Revisions to applicability. The proposed amendments include two revisions to the
definition of the source c ategory. First, EPA is proposing to revise 40 CFR 98.410(a) to i nclude
facilities that destroy 25,000 mtCO2e or more of fluorinated GHGs and fluorinated HTFs annually. This expansion of the definition of the subpart OO source category would impact only facilities that destroy previously produced fluorinated GHGs and that are not already required to report any residual emissions of the destroyed fluorinated GHGs under another subpart. These changes are anticipated to result in 5

- 10 new reporters under sub part OO which would result in an increase in burden for this subpart. The burden was estimated assuming an additional eight
reporters.

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

### e of fluorinated HTFs or GHGs. The re are no new suppliers of fluorinated HTFs anticipated to be required to begin reporting per the proposed changes.

The methodology for determining new reporters and the cost impacts for n ew reporters subject to subpart OO based on the proposed changes to applicability are described in Section 3. 1
of this document.

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

. The proposed revisions to the reporting requirements would add reporting of 41 new data elements, as shown in Table 4.2 4

. Of these 41 new data elements, 40 apply to
certain existing reporters and seven apply to new reporters as described below. The methodology for estimating the proposed costs and the impacts are presented in Section 3. 2 of this document.

Existing Reporters

. Based on a review of currently reporting facilities , t he EPA anticipates that the revised reporting would involve only two to t hree of the existing population of reporting suppliers of fluorinated HTFs that are not fluorinated GHGs , rather than the entire existing reporting field , as all suppliers of fluorinated HTFs currently report under subpart OO

. For these three reporters, t h e proposed revisions would add reporting of 34 new data elements related to reporting fluorinated HTF production, import, or export and six data elements related to destruction of fluorinated HTFs, as listed in Table 4.2 4

.

### 42

New Reporters

. The EPA anticipat es that there will be approximately eight new reporters that destroy fluorinated GHGs or fluorinated HTFs but do not otherwise repor t under subpart
OO

. For these eight reporters, t he proposed revisions to the reporting requirements would
include reporting of s ix new data elements related to destruction of fluorinated HTFs and one
new data element related to fluorinated GHG or fluorinated HTF destruction facilities that do not otherwise reporter under subpart OO , as listed in Table 4.2 4

.

Table 4. 2 4 New Data Elements in Subpart OO

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

.

produced at that facility by process, except for amounts that are captured solely to be shipped off site for destruction. 3 existing suppliers of fluorinated HTFs

98.416(a)(2) Mass in metric tons of each fluorinated HTF . . .

transformed at that facility, by process. 3 existing suppliers of fluorinated HTFs 98.416(a)(3) Mass in metric tons of . . . fluorinated HTF that is

destroyed at that facility and that was previously produced as defined at § 98.410(b). Quantities to be reported under this paragraph (a)(3) of this section include but are not limited to quantities that are shipped to the facility by another facility for destruction and quantities that are returned to the facility for reclamation but are found to be irretrievably contaminated and are therefore destroyed. 3 existing suppliers of fluorinated HTFs

98.416(a)(5) Total mass in metric tons of each. . . fluorinated HTF. . .

sent to another facility for transformation. 3 existing suppliers of fluorinated HTFs 98.416(a)(6) Total mass in metric tons of each . . . fluorinated HTF

sent to another facility for destruction, except. . . fluorinated HTFs that are not included in the mass produced in § 98.413(a) because they are removed from the production process as by

- products or other wastes. Quantities to be reported under this paragraph (a)(6) could include, for example, fluorinated GHGs that are returned to the facility for reclamation but are found to be irretrievably contaminated and are therefore sent to another facility for destr uction. 3 existing suppliers of fluorinated HTFs

98.416(a)(7) Total mass in metric tons of each . . . fluorinated HTF that

is sent to another facility for destruction and that is not included in the mass produced in § 98.413(a) because it is removed from the production process as a byproduct or other waste. 3 existing suppliers of fluorinated HTFs

98.416(a)(10) Mass in metric tons of any . . .fluorinated HTF . . . fed

into the transformation process, by process. 3 existing suppliers of fluorinated HTFs

### 43 Table 4. 2 4 New Data Elements in Subpart OO

Citation Proposed Data Element Applies to...
98.416(a)(11) Mass in metric tons of . . . fluorinated HTF that is fed into

the destruction device and that was previously produced as defined at § 98.410(b). Quantities to be reported under this paragraph (a)(11) of this section include but are not limited to quantities that are shipped to the facility by another facility for destruction and quantities that are returned to the facility for reclamation but are found to be irretrievably contaminated and are therefore destroyed. 3 existing suppliers of fluorinated HTFs

98.416(a)(12) Mass in metric tons of . . . fluorinated HTF . . . that is

measured coming out of the production process, by
process. 3 existing suppliers of fluorinated HTFs

98.416(a)(13) Mass in metric tons of each used . . . fluorinated HTF . . .

added back into the production process (e.g., for reclamation), including returned heels in containers that are weighed to measure the mass in §98.414(a), by
process. 3 existing suppliers of fluorinated HTFs

98.416(a)(14) Names and addresses of facilities to which any . . .

fluorinated HTFs were sent for transformation. 3 existing suppliers of fluorinated HTFs 98.416(a)(14) Quantities (metric tons) of ... each . . . fluorinated HTF

that were sent to each for transformation. 3 suppliers of fluorinated HTFs 98.416(a)(15) Names and addresses of facilities to which any ...

fluorinated HTFs were sent for destruction. 3 existing suppliers of fluorinated HTFs 98.416(a)(15) Quantities (metric tons) of each . . . fluorinated HTF tha t

were sent to each for destruction. 3 existing suppliers of fluorinated HTFs Any facility that destroys ... fluorinated GHGs or fluorinated HTFs shall submit a one - time report containing the following information ...for each destruction process : 98.416(b)(1) Destruction efficiency (DE). ~11 respondents including 3 existing suppliers of fluorinated HTFs that are not fluorinated GHGs and 8 new suppliers that destroy previously produced fluorinated GHGs or fluorinated HTFs. 98.416(b)(2) Methods use d to determine the destruction efficiency. ~11 respondents including 3 existing suppliers of fluorinated HTFs that are not fluorinated GHGs and 8 new suppliers that destroy previously produced fluorinated GHGs or fluorinated HTFs. 98.416(b)(3) Methods used to record the mass of . . . fluorinated HTF

destroyed. ~11 respondents including 3 existing suppliers of fluorinated HTFs that are not fluorinated GHGs and 8 new suppliers that destroy previously produced fluorinated GHGs or fluorinated HTFs.

### 44 Table 4. 2 4 New Data Elements in Subpart OO

Citation Proposed Data Element Applies to...
98.416(b)(4) Chemical identity of the fluorinated GHG(s) used in the

performance test conducted to determine DE. ~11 respondents including 3 existing suppliers of fluorinated HTFs that are not fluorinated GHGs and 8 new suppliers that destroy previously pr oduced fluorinated GHGs or fluorinated HTFs. 98.416(b)(5) Name of all applicable federal or state regulations that

may apply to the destruction process. ~11 respondents including 3 existing suppliers of fluorinated HTFs that are not fluorinated GHGs and 8 new suppliers that destroy previously produced fluorinated GHGs or fluorinated HTFs. 98.416(b)(6) If any process changes affect unit destruction efficiency

or the methods used to record mass of . . . fluorinated HTF destroyed, then a revised report mus t be submitted to reflect the changes. ~11 suppliers including 3 existing suppliers of fluorinated HTFs that are not fluorinated GHGs and 8 new suppliers that destroy previously produced fluorinated GHGs or fluorinated HTFs. Each bulk importer of . . .fluorinated HTFs . . . shall submit an annual report that summarizes its imports at the corporate level, except for shipments including less than twenty

- five kilograms of fluorinated GHGs, fluorinated HTFs, or nitrous oxide, transshipments, and heels that meet the conditions set forth at §98.417(e). The report shall contain the following information for each import: 98.416(c)(1) Total mass in metric tons of . . . each . . . fluorinated HTF

imported in bulk, including each... fluorinated HTF constituent o f the. . . fluorinated HTF product that makes up between 0.5 percent and 100 percent of the product by

mass. 3 existing suppliers of fluorinated HTFs that are not fluorinated GHGs.

98.416(c)(2) Total mass in metric tons of . . . fluorinated HTF imported

in bulk and sold or transferred to persons other than the importer for use in processes resulting in the transformation or destruction of the chemical. 3 existing suppliers of fluorinated HTFs that are not fluorinated GHGs.

98.416(c)(3) Date on which the... fluorinated HTFs . . . were imported. 3 existing suppliers of fluorinated HTFs that are not fluorinated GHGs. 98.416(c)(4) Port of entry through which the . . . fluorinated HTFs . . .

passed. 3 existing suppliers of fluorinated HTFs that are not fluorinated GHGs. 98.416(c)(5) Country from which the imported ... fluorinated HTFs . . .

were imported. 3 existing suppliers of fluorinated HTFs that are not fluorinated GHGs. 98.416(c)(6) Commodity code of the ... fluorinated HTFs ...shipped. 3 existing suppliers of fluorinated HTFs that are not fluorinated GHGs. 98.416(c)(7) Importer number for the shipment. 3 existing suppliers of fluorinated HTFs that are not fluorinated GHGs.

### 45 Table 4. 2 4 New Data Elements in Subpart OO

Citation Proposed Data Element Applies to...
98.416(c)(8) Total mass in metric tons of each . . .fluorinated HTF

destroyed by the importer. 3 existing suppliers of fluorinated HTFs that are not fluorinated GHGs. 98.416(c)(9) Names and addresses of facilities. 3 existing suppliers of fluorinated HTFs that are not fluorinated GHGs. 98.416(c)(9) Quantities of fluorinated HTFs sold or transferred to each

facilities for transformation. 3 existing suppliers of fluorinated HTFs that are not fluorinated GHGs. 98.416(c)(10) If applicable, the names and addresses of the persons and

facilities to which the . . . fluo rinated HTFs were sold or transferred for destruction. 3 existing suppliers of fluorinated HTFs that are not fluorinated GHGs. 98.416(c)(10) If applicable, the quantities (metric tons) of each . . .

fluorinated HTF that were sold or transferred to each facility for destruction. 3 existing suppliers of fluorinated HTFs that are not fluorinated GHGs. Each bulk exporter of fluorinated GHGs, fluorinated HTFs, or nitrous oxide shall submit an annual report that summarizes its exports at the corporate level, except for shipments including less than twenty

- five kilograms of fluorinated GHGs, fluorinated HTFs, or nitrous oxide, transshipments, and heels. The report shall contain the following information for each export: 98.416(d)(1) Total mass in metric tons of . . . each . . .fluorinated HTF

exported in bulk. 3 existing suppliers of fluorinated HTFs that are not fluorinated GHGs. 98.416(d)(2) Names and addresses of the exporter and the recipient of

the exports. 3 existing suppliers of fluorinated HTFs that a re not fluorinated GHGs. 98.416(d)(3) Exporter's Employee Identification Number. 3 existing suppliers of fluorinated HTFs that are not fluorinated GHGs. 98.416(d)(4) Commodity code of the . . . fluorinated HTFs . . . shipped. 3 existing suppliers of fluorinated HTFs that are not fluorinated GHGs. 98.416(d)(5) Date on which, and the port from which, the . . .

fluorinated HTFs . . . were exported from the United States or its territories. 3 existing suppliers of fluorinated HTFs that are not fluorinate d GHGs. 98.416(d)(6) Country to which the . . . fluorinated HTFs . . . were

exported. 3 existing suppliers of fluorinated HTFs that are not fluorinated GHGs. Each facility that produces a fluorinated HTF or each facility that destroys fluorinated GHGs or fluorinated HTFs but does not otherwise reported under subpart OO , as applicable... 98.416(i) Each facility that destroys fluorinated GHGs or

fluorinated HTFs but does not otherwise report under this section shall report the mass in metric tons of each flu orinated GHG or fluorinated HTF that is destroyed at that facility and that was previously produced as defined at § 98.410(b) or (d), as applicable. Quantities to be reported under this paragraph (i) include but are not limited to quantities that are shipp ed to the facility by another facility for destruction and quantities that are returned to the facility for reclamation but are found to be irretrievably contaminated and are therefore destroyed. 8 new suppliers, including suppliers that destroy previously produced fluorinated GHGs or fluorinated HTFs.

### 46 Table 4. 2 4 New Data Elements in Subpart OO

Citation Proposed Data Element Applies to... 98.416(j) If the facility commences production of a fluorinated HTF

product that was not included in the initial report or performs a repeat measurement under § 98.414(n) that shows that the identities or co ncentrations of the fluorinated HTF or fluorinated GHG constituents of a fluorinated HTF product have changed, then the new or changed concentrations must be provided in a revised report. 3 existing suppliers of fluorinated HTFs that are not fluorinated G HGs.

98.416(j) If the facility commences production of a fluorinated HTF

product that was not included in the initial report or performs a repeat measurement under § 98.414(n) that shows that the identities or concentrations of the fluorinated HTF or fluorinated GHG constituents of a fluorinated HTF product have changed, the date of the change must be provided in a revised report. 3 existing suppliers of fluorinated H TFs that are not fluorinated GHGs.



### Small Entity Impact Analysis

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

to

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

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



### Based on the 20 12 economic census database published by U.S. Bureau of the Census, the receipts (sales), number of establishments, and the average receipts for different sizes of Industrial Gas Manufacturing facilities ( with a NAICS code of 325120) are summarized in Tabl e 4.25 . The average receipts information is adjusted from 2012 dollars to 2011 dollars based on the consumer price index published by Bureau of Labor Statistics.

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

Owned by Enterprises with:

1

- 19 Employees 20

- 99

Employees 100

- 499

Employees 500

- 999

Employees 1,000

- 1,499

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

- (a)

- (a)

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

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

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

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

### 47

According to the cost information listed in Table 3. 1 , the rule implementation cost s for subpart OO are $ 4,527 for the first year and $ 3,327 for subsequent years (in 2011 dollars). The sales tests (cost

- to

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

years.

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

1

- 19 Employees 20

- 99

Employees 100

- 499

Employees 500

- 999

Employees 1,000

- 1,499

Employees
Sales Test

- First Year 0.22% 0.02%

- - - Sales Test

- Subsequent Years 0.16% 0.01%

- - -



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

su bpart OO as a result of this action.

4.24 Subpart RR

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

. This data eleme nt requires information that reporters are expected to have readily available, therefore, burden was estimated
as described in Section 3. 2 of this document. There are no additional pr oposed changes to this subpart.

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

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

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

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



### 4.25 Subpart TT

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

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

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

### 48

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

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

specific factors.

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

4.26 Other Minor Revisions, Clarifications, and Corrections

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

cross

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

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

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

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

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