1 

MEMORANDUM 

TO: Michael Rohwer, Jessica Gordon, Rachel Schmeltz, EPA 

FROM: Donna Lazzari, Jason Renzaglia, Tracy Curtis, ERG 

DATE: December 31, 2012 

SUBJECT: Assessment of Emissions and Cost Impacts of 2013 Revisions to the Greenhouse 

Gas Reporting Rule and Proposed Confidentiality Determinations for New or 

Substantially Revised Data Elements 

EPA intends to update the Global Warming Potentials (GWPs) in Table A-1 of subpart A 

to match the GWPs published by the Intergovernmental Panel on Climate Change (IPCC) in the 

2007 Fourth Assessment Report. EPA also intends to add GWPs for fluorinated greenhouse 

gases (GHG) not previously included in Table A-1 of subpart A. Additionally, EPA is proposing 

technical corrections and other amendments to 30 subparts of the GHG reporting rule (40 CFR 

part 98). 

Sections 1 through 6 of this memorandum explain how reporters would be affected by 

changes to the GWPs in the GHG reporting rule. Section 7 discusses the impacts of the technical 

corrections and other proposed amendments. This memorandum is organized as follows: 

1. Background and Introduction for Proposed GWP Revisions 

2. Identification of Subparts Affected by the Proposed GWP Revisions in Subpart A 

3. Data Quality for Subparts Evaluated 

4. Summary of Impacts and Small Entity Impacts - All reporters 

5. Methodology for Current Reporters 

6. Methodology for New Reporters 

7. Impacts of Other Proposed Technical Corrections and Amendments 

The following Excel workbook files, which will be placed in the rulemaking docket, 

contain the data and analyses described in this memorandum. These files are referenced in the 

respective sections of this memorandum. 

• GWP Change - Impact Analysis Summary.xlsx 

• Subpart I GWP Impact Analysis 9-14-2012.xlsx 

• Industrial Wastewater Thresholds_071708.xlsx 

• Subpart W GWP Impact Analysis 7-25-2012.xlsx 
2 

• Industrial Wastewater Wastewater_Thresholds_Ethanol Mills_052611.xlsx 

1.0 BACKGROUND AND INTRODUCTION FOR PROPOSED GWP REVISIONS 

Facilities affected by the GHG reporting rule must report their GHG emissions to EPA 

through the electronic Greenhouse Gas Reporting Tool (e-GGRT). To calculate GHG emissions, 

reporters use the GWPs in Table A-1 to subpart A of the GHG reporting rule. EPA is proposing 

to update the GWPs in Table A-1 using the GWPs from the IPCC 2007 Fourth Assessment 

Report1. EPA is also proposing to add additional fluorinated GHGs to Table A-1. 

This section explains how the proposed changes to Table A-1 will affect reporters. Three 

kinds of reporters are described in this memorandum: 

• 2010 reporters are those reporters that are already subject to the GHG reporting 

rule and have already reported their emissions to e-GRRT for the year 2010. 

Emissions data for these reporters is available through the EPA website. 

• 2011 reporters are those reporters that are already subject to the GHG reporting 

rule and are required to report GHG emissions beginning in the 2011 reporting 

year. Emissions data are not available at the time of writing this memorandum. 

• New reporters are those reporters that are not currently affected by the GHG 

reporting rule, but would become subject to the rule as a result of the proposed 

changes to Table A-1. 

1.1 How GWPs Affect Emissions and Applicability to the GHG Reporting Rule 

A change to the GWP for a GHG will change the calculated emissions of that gas and 

might also change the number of facilities or suppliers that are subject to the GHG reporting rule. 

The number of facilities or suppliers could change because for some subparts applicability to the 

GHG reporting rule is based on the amount of GHG that is either consumed, generated, emitted, 

imported, or exported over a calendar year, expressed in carbon dioxide equivalents (CO2e). 

Carbon dioxide equivalent is a metric used to compare the emissions of various GHGs based on 

their GWP. Because different GHGs have different heat trapping capabilities and atmospheric 

lifetimes, they are not directly comparable without translating emissions into a common unit of 

measure. The GWP is a measure of the total energy that a gas absorbs over a particular period of 

time (usually 100 years) compared to carbon dioxide, which has a GWP of 1.0. The CO2e for a 

specific gas is derived by multiplying the mass of the gas by the associated GWP. For example, 

methane currently has a GWP of 21. A facility that emits 1,000 tons of CO2 emits 1,000 tons per 

year of CO2e. A facility that emits 1,000 tons of methane emits 21,000 tons per year of CO2e. 

 

1

 IPCC, 2007. Climate Change 2007: Synthesis Report. Contribution of Working Groups I, II and III to the Fourth 

Assessment. Report of the Intergovernmental Panel on Climate Change [Core Writing Team, Pachauri, R.K and 

Reisinger, A. (eds.)]. IPCC, Geneva, Switzerland, 104 pp 
3 

Based on revised radiative forcing research, the IPCC in the 2007 Fourth Assessment 

Report updated the GWP values for the following compounds: methane, nitrous oxide, the 

hydrofluorocarbons, perfluorinated compounds, fluorinated ethers, substances controlled by the 

Montreal protocol, and hydrocarbons and other compounds with direct warming effects. The 

revised GWP values by IPCC represent an increase in the GWP for CH4, a slight decrease for 

N2O, an increase for 10 fluorinated gases, and a decrease for three fluorinated gases. The GWP 

for all other GHGs currently on Table A-1 are unchanged. The GHGs that are covered by the 

GHG reporting rule are carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), sulfur 

hexafluoride (SF6), hydrofluorocarbons, perfluorocarbons, and other fluorinated GHGs (which 

include fluorinated ethers). The GHG reporting rule does not require reporting of emissions of 

the Montreal protocol substances or the hydrocarbons with direct effects (dimethylether, 

methylene chloride, and methyl chloride). Appendix A of this memorandum lists the compounds 

covered by the GHG reporting rule along with the original GWPs and the proposed GWP 

revisions. 

The EPA is also proposing to amend subpart A of Part 98 to add 26 fluorinated GHGs (FGHGs) to Table A-1 where the EPA has identified the GWP based on an assessment of recent 

scientific literature. 

Currently, some source categories under 40 CFR part 98 provide calculation 

methodologies and reporting requirements for F-GHGs or F-HTFs for which GWPs were not 

available in the IPCC assessment reports or other scientific assessments at promulgation. The 

GWPs in Table A-1 of subpart A are primarily used for threshold calculations to determine rule 

applicability (40 CFR 98.2(b)) and for reporting total GHG emissions or supply in CO2e for each 

facility or supplier (40 CFR 98.3(c)(4)). Those F-GHGs or F-HTFs whose GWPs are currently 

not listed in Table A-1 are not included in threshold calculations for applicability or in the CO2e 

totals reported by facilities and suppliers, but are instead reported in metric tons of substance 

emitted or supplied (40 CFR 98.3(c)(4)). Appendix A of this memorandum lists the compounds 

that EPA is proposing to include in Table A-1, and their newly proposed GWPs. 

Revisions to the GWPs affect the calculation of carbon dioxide equivalents (CO2e) from 

facility emissions, and thus any increase in the GWPs or the inclusion of newly proposed GWPs 

in a threshold analysis could cause a given facility or supplier to exceed the emissions reporting 

threshold, even if the facility did not previously exceed the threshold. A change to a facility’s 

reporting status would cause the facility to incur costs for monitoring, recordkeeping, and 

reporting emissions. 

In this memorandum, we evaluate the impacts of the proposed new or revised GWPs in 

Table A-1 to subpart A on the emissions reported and the estimated number of new reporters that 
4 

would be required to report under each subpart if the proposed changes are incorporated into the 

reporting rule. We also estimated the compliance costs that would be incurred by these additional 

reporting facilities. The methodology used to identify the subparts for which emissions 

calculated as CO2e would change is described in Section 2 of this memorandum. The quality of 

data used in this analysis is discussed in Section 3 of this memorandum. A summary of cost and 

emissions impacts due to the proposed revisions is provided in Section 4 of this memorandum. 

The methodologies used to determine emissions impacts to 2010 and 2011 reporters are 

described in Section 5 of this memorandum. The methodologies used to determine cost and 

emissions impacts to new reporters are described in Section 6 of this memorandum. 

2.0 IDENTIFICATION OF SUBPARTS AFFECTED BY THE PROPOSED GWP 

REVISIONS IN SUBPART A 

2.1 2010 and 2011 Reporters 

2010 and 2011 reporters are those reporters that are already affected by the GHG 

reporting rule and have already reported their GHG emissions to eGRRT (or are expected to 

report their estimated emissions to eGRRT in the near future). ERG categorized reporters as 

either associated with a source category that has already reported to e-GGRT in 2010 and the 

reporting data are available, or a source category for which emissions data are not available at 

the time of writing this memorandum. Each GHG source category, and whether 2010 e-GGRT 

data are available, is identified in Table 2-1. 

Table 2-1. 2010 e-GGRT Data Availability for All GHG Source Categories 

Subpart Source Category 

2010 e-GGRT Reporting 

Data Availablea

C General Stationary Fuel Combustion Sources Yes

D Electricity Generation Yes

E Adipic Acid Production Yes

F Aluminum Production Yes

G Ammonia Manufacturing Yes

H Cement Production Yes

I Electronics Manufacturing No

K Ferroalloy Production Yes

L Fluorinated Gas Production No

N Glass Production Yes

O HCFC-22 Production and HFC-23 Destruction Yes

P Hydrogen Production Yes

Q Iron and Steel Production Yes

R Lead Production Yes

S Lime Manufacturing (non-CEMS) Yes

T Magnesium Production No
5 

Table 2-1. 2010 e-GGRT Data Availability for All GHG Source Categories 

Subpart Source Category 

2010 e-GGRT Reporting 

Data Availablea

U Miscellaneous Uses of Carbonate Yes

V Nitric Acid Production Yes

W Petroleum and Natural Gas Systems No

X Petrochemical Production Yes

Y Petroleum Refineries Yes

Z Phosphoric Acid Production Yes

AA Pulp and Paper Manufacturing Yes

BB Silicon Carbide Production Yes

CC Soda Ash Manufacturing Yes

DD Use of Electric Transmission and Distribution Equipment No

EE Titanium Dioxide Production Yes

FF Underground Coal Mines No

GG Zinc Production Yes

HH Municipal Solid Waste Landfills Yes

II Industrial Wastewater Treatment No

JJ Manure Management b--

LL Suppliers of Coal based Liquid Fuels No Reporters

MM Suppliers of Petroleum Products Yes

NN Suppliers of Natural Gas and Natural Gas Liquids Yes

OO Suppliers of Industrial Greenhouse Gases Yesc

PP Suppliers of Carbon Dioxide Yes

QQ Importers / Exporters of Equipment Pre-charged with FGHGs No 

RR Geologic Sequestration of Carbon Dioxide No

SS Manufacture Electric Transmission and Distribution 

Equipment No 

TT Industrial Waste Landfills No

UU Injection of Carbon Dioxide No

a

 Data extracted from e-GGRT in December 2012.

b This memorandum does not cover subpart JJ because EPA will not be implementing subpart JJ of Part 98 due to a 

Congressional restriction prohibiting the expenditure of funds for this purpose. 

c Summary data only available for this subpart. 

 

ERG estimated the calculated emissions impacts (due to the proposed new and revised 

GWPs) on 2010 and 2011 reporters associated with each of the GHG source categories identified 

in Table 2-1. The proposed new and revised GWPs would have no effect on subparts with CO2

as the sole emission type (i.e., subparts MM, NN, PP, RR, and UU) because GWP is a measure 

of the heat trapped by specific gas(es) as compared to the heat trapped by CO2. Actual CO2

emissions are not converted to CO2e, and thus GWP has no bearing on the emissions in these
6 

cases. Similarly, although CO2, CH4, and/or N2O combustion emissions are required to be 

reported for subparts G, R, U, Z, CC, EE, and GG, the sole emission type reported under these 

specific subparts is CO2 process emissions (because combustion emissions are required to be 

reported under subpart C). Therefore, for purposes of this memorandum, any change to 

combustion emissions associated with these subparts is incorporated into the impact analysis 

performed on subpart C; and no other impact (due to the new and revised GWPs) is identified for 

these specific subparts. 

The addition of compounds to Table A-1 would potentially affect reporters covered under 

the subparts that have calculation methods for F-GHGs (i.e., subparts I, L, T, DD, OO, QQ, and 

SS). As discussed in Section 5.6, emissions that are projected for subpart DD (Use of Electric 

Transmissions and Distribution Equipment) and subpart SS (Electrical Equipment Manufacture) 

are assumed to be entirely SF6 emissions; therefore, the assignment of GWPs for other F-GHGs 

would have no effect on reporters under subpart DD and SS. We do not anticipate a significant 

increase in calculated emissions from reporters for subparts I, T, or QQ. The methodology ERG 

used to determine the impact of the proposed revisions to Table A-1 for 2010 and 2011 reporters 

is presented in Section 5.0. 

2.2 New Reporters 

New reporters are those reporters that are not affected by the current GHG reporting rule, 

but will become subject to the rule as a result of revisions to the GWPs in Table A-1. Affected 

subparts that might have new reporters due to the proposed new and revised GWPs are those that 

meet all three of these criteria: 1) subpart has a reporting threshold2 and the threshold is based on 

CO2e, 2) subpart requires reporting of emissions of CH4, N2O, or a F-GHG, and 3) EPA 

estimates that all facilities in the subpart did not previously exceed the threshold. The subparts 

that meet these three criteria are subparts I, T, W, HH, II, OO, and TT. The revised GWPs would 

not create new reporters for subparts that have no threshold, because all applicable facilities are 

already reporting. Similarly, categories with thresholds not based on CO2e would not create new 

reporters resulting from a revised GWP (e.g., for subpart FF, underground coal mines, the 

threshold is based on the annual volume of methane liberated from a mine). Also, if all facilities 

in the subpart are currently expected to exceed the 25,000 metric tons of CO2e threshold (based 

on an evaluation of the supporting documents for each subpart), then ERG assumed that there 

would be no new reporters. In particular, all potential reporters under subparts K, L, and QQ 

(importers only) are estimated to exceed the 25,000 metric tons of CO2e threshold, so no new 

reporters are expected for these subparts due to the new and revised GWPs. For subpart QQ 

 

2

 For some subparts, all facilities are required to report. 
7 

(exporters), all facilities are expected to exceed the 25,000 metric tons of CO2e threshold with 

the exception of exporters of SF6 electrical equipment. No additional SF6 equipment exporters 

are expected to exceed the 25,000 metric tons of CO2e threshold because the GWP for SF6 is 

decreasing. 

ERG also assessed the type of emissions for each subpart. Subparts with CO2 as the sole 

emission type were eliminated; the revised GWPs would not create new reporters for these 

subparts because GWP is a measure of the heat trapped by specific gas(es) as compared to the 

heat trapped by CO2. Actual CO2 emissions are not converted to CO2e, and thus GWP has no 

bearing on the outputs in these cases. Subparts with emissions solely from combustion 

experienced such small impacts from the GWP revisions that they were not expected to trigger 

any additional reporters. For example, for coal burning, there is only a 0.024% increase in CO2e 

as a result of the change to the GWP of CH4 and N2O emissions resulting from combustion, and 

for natural gas, there was only a 0.005% increase. Table 2-2 provides detail for this calculation. 

Table 2-2. Example Emission Calculation for 100 Million BTU/hour Combustion Unit - 

Comparison of CO2e for Current and Revised GWP 

Identifier for 

Methodology 

Description and/or

Methodology Anthracite Coal Natural Gas 

A CO2 EF (kg CO2/mmBTU) 103.50 53.02

B CH4 EF (kg CH4/mmBTU) 1.10E-02 1.00E-03

C Current GWP for CH4 21

D Revised GWP for CH4 25

E N2O EF (kg N2O /mmBTU) 1.60E-03 1.00E-04

F Current GWP for N2O 310

G Revised GWP for N2O 298

H Current CH4 CO2e

(B*C) 0.231 0.021 

I Revised CH4 CO2e

(B*D) 0.275 0.025 

J Current N2O CO2e

(E*F) 0.496 0.031 

K Revised N2O CO2e

(E*G) 0.477 0.030 

L Current Total CO2e

(A+H+J) 104.23 53.072 

M Revised Total CO2e

(A+I+K) 104.25 53.075 

Percent Change

((M-L)/L) 0.024% 0.005%
8 

ERG does not anticipate that the addition of F-GHGs to Table A-1 of subpart A will 

result in any new reporters. Assigning GWPs to additional F-GHGs would only potentially affect 

reporters covered under the subparts that require calculation of emissions of F-GHGs (i.e., 

subparts I, L, T, DD, OO, QQ, and SS). 

For subpart I, facilities that manufacture semiconductors, liquid crystal displays (LCDs), 

and micro-electromechanical systems (MEMS) must calculate annual emissions for threshold 

applicability purposes considering only the gases for which default emission factors are provided 

in Table I-1 to subpart I. Facilities must account for F-HTF emissions as a percentage of the total 

annual production process emissions at a facility (calculated using the default factors in Table I1). Table I-1 does not include F-GHGs affected by the proposed changes to Table A-1, therefore 

the applicability for these facilities will not change. Facilities that manufacture photovoltaic cells 

(PVs) are not expected to emit any of the gases EPA is proposing to add to Table A-1 to subpart 

A. Therefore, there are no additional PV facilities that will report as a result of the change. 

 As noted in Table 2-3 all facilities subject to subpart L and QQ are expected to be above 

the reporting threshold, therefore there are no additional facilities that will be required to report 

as a result of the addition of F-GHGs to Table A-1. As described in Section 5.6, emissions that 

are projected for subpart DD (Use of Electric Transmissions and Distribution Equipment) and 

subpart SS (Electrical Equipment Manufacture) are assumed to be entirely SF6 emissions; 

therefore, the assignment of GWPs for other F-GHGs would have no effect on reporters under 

subpart DD and SS. 

For subpart T (Magnesium Production), EPA is proposing to add a GWP for the 

fluorinated ketone FK-5-1-12 (proposed to be included in Table A-1 of subpart A). However, 

because FK-5-1-12 is a low-GWP gas (proposed GWP=1.8), we do not anticipate that additional 

facilities will be required to report as a result of the additional F-GHG. As described in Section 

5.6, because FK-5-1-12 is used as an alternative to the high-GWP gas SF6 (GWP=22,800), any 

conversion to the use of FK-5-1-12 in production would decrease the calculated emissions of 

GHG, and no additional facilities would be required to report as a result. 

For subpart OO (Industrial GHG Suppliers), EPA identified the potential of three 

additional reporters due to the revisions to the GWPs in Table A-1. For the compounds added to 

Table A-1, these gases are primarily used in the electronics industry. The importers and 

exporters that are primarily serving the electronics are currently subject to subpart OO reporting, 

no new reporters were identified sue to the addition of compounds to Table A-1. Table 2-3 lists 

all of the GHG reporting rule subparts and the rationale for including or excluding the subpart in 

the new reporter cost impact analysis described in Section 6 of this memorandum. 
9 

Table 2-3. Rationale for GHG Subpart Selection for New Reporter Impact Analysis 

Subpart 

Excluded / 

Included in New 

Reporter Impact 

Analysis Rationale 

C- Stationary Combustion Excluded Combustion emissions only

D- Electricity Generation Excluded Threshold not based on CO2e

E - Adipic Acid Excluded All facilities must report - no threshold

F - Aluminum Excluded All facilities must report - no threshold

G - Ammonia Excluded All facilities must report - no threshold

H - Cement Excluded All facilities must report - no threshold

I - Electronics Included Threshold category that emits mainly fluorinated 

GHG 

K -Ferroalloy Excluded All facilities in subpart expected to be above threshold

L - Fluorinated Gas Excluded All facilities in subpart expected to be above threshold

N - Glass Excluded CO2 and/or combustion emissions only

O - HCFC-22, HFC-23 Excluded Threshold not based on CO2e

P - Hydrogen Excluded CO2 and/or combustion emissions only

Q - Iron & Steel Excluded CO2 and/or combustion emissions only

R - Lead Excluded CO2 and/or combustion emissions only

S - Lime Excluded All facilities must report - no threshold

T - Magnesium Included Threshold category that emits mainly fluorinated 

GHG 

U - Carbonate Excluded CO2 emissions only

V - Nitric Acid Excluded All facilities must report - no threshold

W - Petroleum & Natural Gas Included Threshold category that emits methane 

X - Petrochemicals Excluded All facilities must report - no threshold

Y - Refineries Excluded All facilities must report - no threshold

Z - Phosphoric Acid Excluded All facilities must report - no threshold

AA - Pulp & Paper Excluded All facilities in subpart expected to be above threshold

BB - Silicon Carbide Excluded All facilities must report - no threshold

CC - Soda Ash Excluded All facilities must report - no threshold

DD - Electrical Transmission Excluded Threshold not based on CO2e

EE - Titanium Dioxide Excluded All facilities must report - no threshold

FF - Underground Coal Mines Excluded Threshold not based on CO2e

GG - Zinc Excluded CO2 and/or combustion emissions only
10 

Table 2-3. Rationale for GHG Subpart Selection for New Reporter Impact Analysis 

Subpart 

Excluded / 

Included in New 

Reporter Impact 

Analysis Rationale 

HH - MSW Landfills Included Threshold category that emits mostly methane 

II - Industrial Wastewater Included Threshold is based on methane generation 

JJ - Manure Mgmt Excluded Subpart is not being implemented

LL - Coal-based Liquid Fuels

Suppliers Excluded CO2 emissions only 

MM - Petroleum Suppliers Excluded CO2 emissions only

NN - Natural Gas Suppliers Excluded Threshold not based on CO2e

OO - Industrial GHG Suppliers Included Importers/exporters have threshold for fluorinated 

GHG 

PP - CO2 Suppliers Excluded CO2 emissions only

QQ - Importers / Exporters of Fgases in pre-charged equipment or 

closed-cell foams 

Excluded Threshold category and all importers/exporters in the 

category are expected to be above thresholda

RR - Geologic Sequestration Excluded All facilities must report - no threshold

SS - Electrical Equipment Excluded Threshold not based on CO2e

TT - Industrial Waste Landfills Included Threshold is based on methane generation 

UU - CO2 Injection Excluded All facilities must report - no threshold

a

Some facilities with SF6 containing electrical equipment were below the threshold; SF6 GWP is decreasing, therefore no 

additional affected facilities.

3.0 DATA QUALITY FOR SUBPARTS EVALUATED 

This analysis relied on data developed for the initial economic impact assessment of the 

2009 GHG reporting rule. The data used to perform this evaluation varied in the level of detail 

available from subpart to subpart. 

• Data quality level “A” means 2010 emissions data was available, or for 2011 

reporters the facility level data used in the original economic analysis was 

available. Emissions estimates and facility lists were updated using the proposed 

new or revised GWP for each facility identified as a potential reporter under the 

subpart. 

• Data quality level “B” means 2010 reported emissions data was not available and 

the facility level data used in the original threshold analysis or economic impact 

assessment were not available, but a reasonable estimate of emissions and the 

number of facilities potentially affected by the proposed new or revised GWP was 
11 

made using summary data available in the technical support documents or other 

published documents. 

• Data quality level “C” means that 2010 reported emissions data was not available, 

and data used in the original threshold analysis or economic impact assessment 

were not available, or a complete list of potential reporters for a subpart was not 

developed as part of the original economic impacts assessment for the GHG 

reporting rule; therefore, this assessment of GWP impacts used qualitative data to 

assess impacts. 

3.1 Data Quality for 2010 and 2011 Reporters Emissions Impact 

For the subparts listed in Table 2.1 that indicate 2010 e-GGRT emissions data is 

available, the data quality is rated “A”. For subparts that do not yet have information available in 

e-GGRT, the data quality rating is listed in Table 3-1. 

Table 3-1. Data Quality for Subparts Evaluated 

Subpart Quality Level 

I – Electronics A

L- Fluorinated Gas C

T – Magnesium B

W - Petroleum & Natural Gas A/Ba

DD- Electrical Transmission A

FF- Underground Coal Mines A

HH - MSW Landfills A

II - Industrial Wastewater C

OO - Industrial GHG Suppliers A

QQ- Importers / Exporters of Equipment Precharged with F-GHGs C 

SS- Electrical Equipment A

TT - Industrial Waste Landfills C

a

Six of eight industry segments have a data quality of A, the remaining two segments 

have a data quality level B.

3.2 Data Quality for Estimating New Reporters - Emissions and Cost Estimates 

For the subparts where new reporters are expected as a result of the revisions to Table A1 subpart A, Table 3.2 indicates the data quality available to conduct the analysis of additional 

reported emissions and the associated cost impact. 
12 

Table 3-2. Data Quality for Subparts Evaluated for New Reporters 

Subpart Quality Level 

I – Electronics A

T – Magnesium B

W - Petroleum & Natural Gas A/Ba

HH - MSW Landfills A

II - Industrial Wastewater C

OO - Industrial GHG Suppliers B

TT - Industrial Waste Landfills C

a

Six of eight industry segments have a data quality of A, the remaining two segments 

have a data quality level B.

4.0 SUMMARY OF IMPACTS AND SMALL ENTITY IMPACTS – ALL 

REPORTERS 

4.1 Summary of Emissions and Cost Impacts 

ERG found that reporters subject to either subpart HH or OO (2010 reporters), or subpart 

W, FF, or TT (2011 reporters) would collectively incur an increase of 2,000,000 metric tons of 

CO2e or more (per subpart) if EPA revised the GWPs in Table A-1or included additional GWPs 

in Table A-1 of subpart A. In addition, we found that the most significant cost impacts to new 

reporters are to those subparts that have high methane emissions. Subpart W (Oil and Gas), and 

subpart HH (MSW Landfills), have the highest cost impacts and the highest amount of expected 

additional reported emissions. 

The emissions and cost impacts resulting from the proposed revised and new GWPs for 

each subpart are presented in four tables: Table 4-1 includes a summary for subparts that 

reported in 2010; Table 4-2 includes a summary of subparts that report beginning in year 2011; 

Table 4-3 combines all source categories for a total impact assessment; Table 4-4 provides a 

summary of the cost impact for the new reporters anticipated. The tables include the estimated 

changes to the number of affected facilities and expected emissions reported; details can be 

found in the Excel workbook associated with this memorandum that is entitled “GWP ChangeImpact Analysis Summary.” Figure 4-1 presents the emissions impacts for all subparts. 
13 

Table 4-1. 2010 Reporters - Summary of Impacts Due to GWP Revisions for Source Categories Reporti

Subpart 

Total 

Number of 

Facilities in 

Source 

Category

Number of 

Reporters 

Prior to 

GWP 

Revisions

Number of 

Reporters 

Affected by 

GWP 

Revisions 

2010 Total 

Emissions Prior 

to GWP 

Revisions 

(non-biogenic) 

(metric tons 

CO2e per year)

Incremental Cost Impact 

for New 

Reporters 

(in 2011$ per year)

Incremental 

Emissions for 

New Reporters 

(metric tons 

CO2e per 

year) 

2010 Emissions 

After GWP 

Revisions 

(metric tons 

CO2e per year) 

Emis

2010 

Rep

Combi

GWP 

(met

CO2e 

C 350,000 4,211 4,211 619,572,472 0 0 619,684,811 619,

D 3,243b 1,263 1,263 2,231,408,653 0 0 2,231,701,929 2,231

E 4 2 2 4,397,310 0 0 4,227,092 4,2

F 14 9 9 4,298,897 0 0 4,581,938 4,5

G 24 22 0 13,596,985 0 0 13,596,985 13,5H 107 97 97 42,734,686 0 0 42,737,342 42,7K 9 10 10 2,240,907 0 0 2,242,650 2,2N 374 103 103 2,061,679 0 0 2,061,679 2,0O 5 5 5 6,351,797 0 0 8,034,752 8,0

P 101 101 101 31,261,120 0 0 31,261,130 31,2

Q 130c 123 123 27,094,226 0 0 27,094,205 27,0

R 27d 12 0 588,209 0 0 588,209 58

S 89 70 70 15,566,816 0 0 15,566,989 15,5

U NA 19 0 122,663 0 0 122,663 12V 45 36 36 11,990,739 0 0 11,526,582 11,5X 88 63 63 9,445,122 0 0 9,457,094 9,4Y 150 145 145 55,751,060 0 0 55,851,755 55,8

Z 14 13 0 1,080,913 0 0 1,080,913 1,0

AA 425 110 110 7,562,923 0 0 7,613,331 7,6

BB 1 1 1 122,466 0 0 124,607 12CC 5 4 0 1,221,863 0 0 1,221,863 1,2
14 

Table 4-1. 2010 Reporters - Summary of Impacts Due to GWP Revisions for Source Categories Reporti

Subpart 

Total 

Number of 

Facilities in 

Source 

Category

Number of 

Reporters 

Prior to 

GWP 

Revisions

Number of 

Reporters 

Affected by 

GWP 

Revisions 

2010 Total 

Emissions Prior 

to GWP 

Revisions 

(non-biogenic) 

(metric tons 

CO2e per year)

Incremental Cost Impact 

for New 

Reporters 

(in 2011$ per year)

Incremental 

Emissions for 

New Reporters 

(metric tons 

CO2e per 

year) 

2010 Emissions 

After GWP 

Revisions 

(metric tons 

CO2e per year) 

Emis

2010 

Rep

Combi

GWP 

(met

CO2e 

EE 8 7 0 1,447,634 0 0 1,447,634 1,4

GG 9 6 0 730,209 0 0 730,209 73HH 7,802 1,202 1,259 107,000,000 137,500 1,560,000 108,227,153 109,

MM NA 155 0 2,493,881,410 0 0 2,493,881,410 2,493

NN NA 476 0 909,000,000 0 0 909,000,000 909,OO 351 167 170 254,554,000 10,500 75,000 298,539,000 298,

TOTAL 363,025 8,432 7,778 6,855,084,759 148,000 1,635,000 6,902,203,925 6,903

a Number of facilities is from the proposed rule from April 10, 2009 unless otherwise indicated. 

b From RIA EPA–HQ–OAR–2008–0508–046. c Originally estimated as 3, number of actual reporters indicates otherwise. d Originally estimated as 77, number of actual reporters indicates otherwise. 
15 

Table 4-2. 2011 Reporters-- Summary of Emissions Impacts Due to GWP Revisions for 

Source Categories With Initial Report Required in 2011 (data not yet available) 

Subpart 

Total 

Number of 

Facilities in 

Source 

Category

Number of 

2011 

Reporters 

Prior to 

GWP 

Revisions

Number of 

Reporters 

Affected by 

GWP 

Revisions

Total Emissions 

From 2011 

Reporters Prior 

to GWP 

Revisions 

(non-biogenic) 

(metric tons 

CO2e per year)

Incremental Cost Impact 

for New 

Reporters 

(in 2011$ per year)

Incremental 

Emissions for 

New Reporters

(metric tons 

CO2e per 

year) 

Emissions for 

2011 Reporters 

After GWP 

Revisons 

(metric tons 

CO2e per year) 

Emis

2011 

Rep

Combi

G

Revisio

tons C

y

I 216 94 98 5,622,570 88,900 18,076 6,657,398 6,6

L 14 14 14 10,600,000 0 0 11,660,000 11,6T 13 11 11 1,067,000 0 0 1,029,787 1,0

W 29,530 2,786 2,885 337,000,000 860,000 2,572,881 375,563,940 378,

DD 1,364 141 141 10,320,000 0 0 9,845,021 9,8

FF 612 114 114 33,823,404 0 0 40,265,957 40,2

II 444 244 246 5,845,000 10,300 59,500 6,958,333 7,0

JJ NA 0 0 0 0 0 0 

LL NA 0 0 0 0 0 0 

PPa NA 99 0 33,500,000 0 0 33,500,000 33,5QQ 108 108 108 21,907,182 0 0 23,822,182 23,8

RR 10 10 0 7,162,885 0 0 7,162,885 7,1

SS 10 10 10 814,128 0 0 776,658 77

TT 369 200 219 13,700,000 87,300 520,000 16,309,524 16,8

UU 92 92 0 48,735,442 0 0 48,735,442 48,7

TOTAL 32,782 3,923 3,846 530,097,611 1,046,500 3,170,457 582,287,127 585,

a Subpart PP included in this table although reporting was required in 2010 because data is not available.
16 

Table 4-3. 2010, 2011, and New Reporters -- Summary of Impacts Due to GWP Revisions for All Source 

Subpart 

Total 

Number 

of 

Facilities 

in Source 

Category

Number of 

Reporters 

Prior to 

GWP 

Revisions

Number of 

Reporters 

Affected 

by GWP 

Revisions

Total 

Emissions 

Prior to GWP 

Revisions 

(non-biogenic)

(metric tons 

CO2e per 

year)

Incremental Cost Impact 

for New 

Reporters 

(2011$ 

per year)

Incremental 

Emissions for 

New 

Reporters 

(metric tons 

CO2e per 

year) 

Emissions for 

Reporters 

After GWP 

Revisions 

(metric tons 

CO2e per 

year) 

Emis

Curr

New R

Com

Afte

Rev

(met

CO

y

2010

Reporters 

Total

363,025 8,432 7,778 6,855,084,759 148,000 1,635,000 6,902,203,925 6,903

2011 

Reporters 

Total 

32,782 3,923 3,846 530,097,611 1,046,500 3,170,457 582,287,127 585,

TOTAL 395,807 12,355 11,624 7,385,182,369 1,194,500 4,805,457 7,484,491,052 7,489
17 

283

41,137

50

6,443

44,060

112 

293 

(170)

0 

3 

1,053 

2 

1,060 

0 

1,683 

0 

(0.02)

0 

0 

(37)

0 

(464)

12 

101 

0 

2 

0 

(475)

0 

0 

2,787 

1,173 

0 

0 

0 

0 

0 

1,915 

0 

(37)

3,130 

CDEFGHIKLNOPQRSTUVWXYZ

AA

BB

CC

DD

EE

FF

GG

HH

II

JJ

LL

MM

NN

OO

PP

QQ

RR

SS

TT

0

40,00080,000

120,000160,000

Subpart

Thousand Metric Tons of CO

2

e

Figure 4-1. Emissions Impacts by Subpart Due to Table A

Revisions
18 

Table 4-4. Summary of Cost Impact Due to the GWP Revisions

Subpart 

Number of New 

Reporters Due to 

GWP Revisions 

Incremental 

Emissions for New 

Reporters (metric 

tons CO2e per year) 

Incremental Cost Impact for 

New Reporters ($/yr) 

I – Electronics 4 18,076 88,900

W - Petroleum & Natural Gas 99 2,572,881 860,000

HH - MSW Landfills 57 1,560,000 137,500

II - Industrial Wastewater 2 59,500 10,300

OO - Industrial GHG 

Suppliers 3 75,000 10,500 

TT - Industrial Waste 

Landfills 19 520,000 87,300 

Total 184 4,805,457 1,194,500

4.2 Small Entity Impacts 

There will be a cost impact of the change to GWP only for new reporters; the cost of 

reporting will not significantly change for those entities already required to report. A detailed 

discussion of the cost impact to small entities is included in the individual subpart analyses for 

new reporters in section 6.0 of this memorandum. For each affected subpart that may have new 

reporters due to the revised GWPs, we used information available in supporting documents to 

identify the small businesses affected, and an impact evaluation was performed. We have 

concluded for each subpart evaluated that there is not a significant impact on a substantial 

number of small businesses. 

5.0 METHODOLOGY FOR 2010 AND 2011 REPORTERS 

For reporters that currently are subject to the rule for reporting year 2010 or 2011, there 

would be no significant cost impacts resulting from the proposed new and revised GWPs. 

Although some affected facilities and suppliers would report higher CO2e emissions in their 

annual GHG report, using the proposed new and revised GWPs would not affect the cost of 

monitoring and recordkeeping and would not materially affect the cost for calculating emissions. 

The level of increased calculated emissions that will be reported by existing reporters (due to the 

proposed new and revised GWPs) was estimated by adjusting the 2010 reported GHG emissions, 

to the extent that the reported data were available. Emissions data for 2010 were available for 26 

of the GHG subparts. The methodology for these subparts is explained in Section 5.1 of this 

memorandum. For subparts for which emissions data were not available at the time of this 

analysis (i.e., subparts that are applicable beginning with reporting year 2011 and therefore data 

is not yet available, and 2010 subparts for which the 2010 emission verification process had not 
19 

been completed by EPA), and for subparts affected by the new F-GHGs and associated GWPs 

that EPA is proposing to include in Table A-1, ERG used other methods that were based on the 

use of summary emissions impacts data that were developed to support the original rule. Sections 

5.2 through 5.10 of this memorandum explain the methodologies used to calculate the emissions 

impacts for these subparts. Summaries of the original methodology, reference documents, and 

any additional calculation assumptions specific to each subpart are explained in these sections. 

Section 5.10 of this memorandum summarizes the emissions impacts for current reporters. The 

methodology for estimating the emissions impacts due to new reporters (due to the GWP change) 

is explained in section 6.0. 

5.1 Emissions Impacts - 2010 Reporters 

For subparts for which 2010 reporting year data from e-GGRT were available, ERG used 

the 2010 reporting year data to calculate the emissions impacts of the proposed revised GWPs. 

ERG began by extracting the reported emissions of each GHG (CO2, CH4, N2O, etc.) from the 

most recent data supplied by EPA as of December 2012 from the “Data Mart” or “SPAGO” 

database (US EPA 2012a). ERG then identified the total number of facilities reporting under 

each subpart and calculated the total reported emissions of each GHG for each subpart. The total 

reported mass emissions of each GHG were multiplied by the current GWP (see 40 CFR part 98, 

subpart A, Table A-1) to determine the original reported emissions of each GHG in metric tons 

of CO2e. To calculate the emissions impacts (due to the revised GWPs) for each source category 

(in metric tons of CO2e) ERG multiplied the mass emissions for each GHG by the difference 

between the existing GWP and the proposed revised GWPs from the IPCC AR4. For some 

subparts, Table 4-1 shows no impact of the GWP changes. Although CO2, CH4, and N2O 

combustion emissions are required to be reported for subparts G, R, U, Z, CC, EE, and GG, the 

sole emission type reported under these specific subparts is CO2 process emissions (because 

combustion emissions are required to be reported under subpart C and there are no CH4 or N2O 

process emissions for these subparts). Therefore, for purposes of this analysis, any change to 

combustion emissions associated with these subparts is incorporated into the impact analysis 

performed on subpart C; and no other impact (due to the new or revised GWPs) is identified for 

these specific subparts. 

For the 2010 supplier categories, the revised GWPs will have no effect on subparts MM 

and NN, because CO2 is the only GHG required to be reported. With the exception of subpart 

OO, there are no impacts anticipated from the addition of the new F-GHGs and associated GWPs 

to Table A-1, because the 2010 reporters do not report F-GHGs for their source categories. For 

subpart OO the emissions impact was calculated for the F-GHGs that were revised in Table A-1 

to the IPCC AR4 values. Emission impacts were not calculated for the chemicals that are 

proposed to be added to Table A-1 because this data is not publicly available. 
20 

5.2 Subpart I Emissions Impacts - 2011 Reporters 

Emissions of fluorinated gases for subpart I (Electronics Manufacturing) were not 

reported for 2010, and the emissions for the reporting year 2011 will not be available until after 

this memorandum is completed. 

In the original threshold analysis (U.S. EPA, 2010i), EPA identified the number of 

facilities that would be covered under subpart I with a 25,000 metric tons CO2e emissions-based 

threshold. For LCDs and PVs, EPA calculated the total annual emissions, in metric tons of CO2e, 

for each facility using the IPCC Tier 1 default emissions factors. The emissions factors were 

converted to metric tons of CO2e basis by multiplying the factors by the appropriate GWP value. 

EPA used the results to estimate the magnitude of emissions from those facilities expected to 

emit greater than the 25,000 metric tons CO2e threshold. The number of, and emissions from, 

MEMS facilities were calculated using the same procedure, but with an emission factor 

developed by the EPA (U.S. EPA, 2010j). 

In the original analysis, EPA used the same procedure described above (i.e., default IPCC 

Tier 1 factors) to determine the number of semiconductor facilities that were expected to emit 

greater than the 25,000 metric tons CO2e threshold. To estimate the magnitude of emission from

those semiconductor facilities expected to emit greater than the threshold, EPA used emission 

estimations that were derived using outputs from the EPA PFC Emissions Vintaging Model 

(PEVM), as well as the EPA PFC Reduction/Climate Partnership for Semiconductors partner and 

non-partner shares of U.S. emissions. EPA also accounted for heat transfer fluid emission 

estimates by assuming such emissions were equal to 11 percent of total clean and etch emissions 

at a facility. 

To determine the level of increased emissions that will be reported by existing reporters 

under subpart I due to the revised GWPs, ERG recreated the EPA’s original threshold analysis3

with the updated GWP values. ERG was not able to access the PEVM to reproduce the original 

emission estimates; therefore, we assumed that the PEVM based emissions would increase by the 

same percentage as the emissions estimated using the IPCC Tier 1 default factors and updated 

GWP values. We believe this is a valid assumption because no other inputs to the PEVM are 

 

3

 In their original threshold analysis, EPA considered only gases with IPCC Tier 1 emission factors for MEMS, 

LCDs, and PVs. By recreating EPA’s original analysis, ERG has assumed that facilities that manufacture MEMS, 

LCDs, and PVs do not use any of the new F-GHGs EPA is proposing to add to Table A-1 to subpart A. 

Additionally, because ERG was not able to access the PEVM, we assumed that the addition of new F-GHGs to 

Table A-1would not affect the emissions reported by existing reporters for semiconductors. We note that Table I-3 

to subpart I includes emission factors for C4F8O for semiconductor manufacturing for 150mm and 200mm wafers 

sizes; however, in the report titled “2010 ISMI Semiconductor Greenhouse Gas (GHG) Reporting Rule Survey 

Results” published by International SEMATECH Manufacturing Initiative (ISMI Technology Transfer 

#10065097A-TR) Table 2 on page 13 indicates that consumption of C4F8O represents only 0.2 percent of total gas 

consumption for semiconductor manufacturing. 
21 

expected to change. Detailed analyses for each facility type (e.g., semiconductor, MEMS, etc.) 

are provided in the Excel workbook associated with this memorandum that is entitled “Subpart I 

GWP Impact Analysis.” The emissions that are attributed to the anticipated reporters of subpart I 

(due to the revised GWPs) are shown in Table 5-1 for each subpart I facility type. 

Table 5-1. 2011 Reporters — Summary of Emissions Impacts Due to GWP Revisions for 

Subpart I Facility Types 

Facility Type 

Number of 2011 

Reporters Prior to 

Revised GWP

Total Emissions From 

2011Reporters Prior to 

GWP Revisions 

(non-biogenic) 

(metric tons CO2e 

per year)

Emissions 

for 2011 Reporters 

After GWP Revisions 

(metric tons CO2e 

per year)

Semiconductors 91 5,492,066 6,526,269

MEMS 2 96,164 91,739

LCDs - - -

PVs 1 34,340 39,390

TOTAL 94 5,622,570 6,657,398

We have not evaluated the increase in emissions estimates from subpart I reporters based 

on the additional compounds that EPA is proposing to include in Table A-1. We anticipate an 

increase in calculated CO2e emissions if additional F-GHGs and f-HTFs are included in the 

subpart A tables. However, because consumption and emissions data for F-HTFs were 

unavailable at the time of publication of this memorandum, we are unable to estimate the impacts 

of additional F-HTFs added to Table A-1. 

5.3 Subpart L and QQ Emissions Impacts - 2011 Reporters 

Emissions of fluorinated gases for subpart L (Fluorinated Gas Production) and subpart 

QQ (Imports and Exports of Equipment Pre-charged with Fluorinated GHGs or Containing 

Fluorinated GHGs in Closed-cell Foams) were not reported for 2010, and the emissions for the 

reporting year 2011 will not be available until after this memorandum is completed. Compound 

specific expected emissions of fluorinated gases were not available in the Technical Support 

Documents (U.S. EPA, 2010a), or other supporting documents available for this analysis. 

Information was available for the total number of facilities expected to report under subpart L 

and for the total emissions in terms of CO2e expected (U.S. EPA, 2010b). 

From the original rulemaking docket, projected emissions for subpart QQ were available 

for HFCs (as total CO2e) and for SF6 in electrical equipment (U.S. EPA, 2010c). For subpart QQ, 

emission impacts due to the revised GWP for SF6 were calculated by multiplying the total 
22 

expected emissions of SF6 by the difference between the existing GWP and the IPCC AR4 GWP 

(22,800 – 23,900). 

Because there are 17 different fluorinated compounds for which the GWP will change by 

varying amounts and 60 additional fluorinated compounds which EPA is proposing to add to 

Table A-1 subpart A, and a breakdown of emissions by compound was not available for subpart 

L or QQ, a nominal 10 percent increase was estimated as the expected increase in emissions due 

to new and revised GWPs for fluorinated compounds. This estimated increase was based upon a 

model fluorinated gas of HFC-134a. HFC-134a was chosen as the model compound because it is 

a widely used and manufactured fluorinated gas, and makes up approximately 75% of the 

fluorinated gas emissions of HFCs and PFCs used as substitutes for ozone depleting substances 

(U.S. EPA, 2012b). 

Further justification for a nominal 10% increase for subpart L comes from the 

requirement that reporters currently may use a best estimate of the GWP or may use a default 

GWP of 10,000 for fluorinated gases that are fully fluorinated and a default of 2,000 for other 

fluorinated gases when calculating emissions in CO2e for gases not listed in Table A-1 to subpart 

A. Of the 26 additional fluorinated GHGs which EPA is proposing to add to Table A-1, 24 of 

those gases have GWPs less than 2,000. Therefore, we do not expect an increase in calculated 

CO2e emissions as a result of the inclusion of the additional fluorinated GHGs in Table A-1 to 

subpart A. 

5.4 Subpart T Emissions Impacts - 2011 Reporters 

Emissions attributed to anticipated 2011 reporters of subpart T (Magnesium Production) 

due to the revised GWPs reflect emissions of SF6 and HFC-134a. ERG used information from 

the threshold analysis for the original rule and updated data from the EPA’s SF6 Emission 

Reduction Partnership for the Magnesium Industry to determine the expected number of 

reporters for this subpart. The threshold analysis for the magnesium production category for the 

original rule is summarized in “Additional Methodological Information Supporting Threshold 

Analysis for Specific Source Categories” (hereafter referred to as “2010 Threshold Analysis”) 

(U.S. EPA, 2009). Based on the 2010 Threshold Analysis, the magnesium production and 

processing source category was composed of 13 nationwide facilities, with 11 facilities meeting 

the 25,000 mtCO2e threshold. The 2010 Threshold analysis utilized 2006 annual reporting data 

on metal production and SF6 consumption provided through the SF6 Emission Reduction 

Partnership. 

ERG received updated data from the SF6 Emission Reduction Partnership program for the 

2010 reporting year. Because process data reported under the Partnership has historically been 

considered confidential, only aggregate facility-level emissions of SF6 were available for this 
23 

analysis. Emissions data from other gas usage were not available. In the 1990s, EPA operated the 

SF6 Emission Reduction Partnership for the Magnesium Industry to encourage reductions in the 

GHG emissions associated with magnesium production, which were largely based on usage of 

SF6. Partners in the program agreed to implement practices to reduce SF6 emissions, prepare 

corporate-wide annual inventories of SF6 emissions, and eliminate the usage of SF6 as a cover 

gas. Based on the 2010 SF6 Partnership data, 16 facilities reported, and 11 facilities reported use 

of SF6. This is close to the original estimate of 13 processing facilities in the 2010 Threshold 

Analysis. Five facilities reported zero emissions of SF6 in the Partnership data; it was assumed 

that although these facilities may use other F-GHG, they would be unlikely to meet the 25,000 

mtCO2e threshold and report in 2011 due to the reduced GWPs of these compounds (see section 

6.2 of this memorandum). Therefore, ERG assumed that only the 11 facilities would report in 

2011. 

Facilities participating in the SF6 Reduction program have gradually converted to the 

usage of FK 5–1–12 (proposed GWP=1.8) and HFC-134a (proposed GWP=1,430) as alternatives 

to SF6 as a cover gas. Therefore, ERG assumed that the 11 facilities reporting SF6 usage through 

the EPA’s SF6 Magnesium Partnership are using FK 5–1–12, HFC-134a, or alternative cover 

gases in addition to the SF6 reported. There is no available data on the total gas consumption of 

these alternative cover gases. Because FK-5-1-12 is a low-GWP gas with a proposed GWP of 

1.8, ERG assumed that the addition of FK-5-1-12 to Table A-1 would not significantly change 

the CO2e emissions reported by existing reporters. Facilities currently report emissions of FK-5-

1-12 in metric tons; under the proposed rule, they would be required to report these emissions as 

metric tons CO2e. Instead, ERG conservatively examined how the increase in the GWP of the 

high-GWP gas, HFC-134a, would affect emissions from 2011 reporters. To determine how the 

proposed increase in the GWP for HFC-134a would affect calculated emissions, ERG first 

characterized industry emissions of HFC-134a from the 2010 Partnership data, taking into 

account the industry decrease in SF6 usage and increase in HFC-134a usage. The total SF6

emissions reported through the Partnership showed a 67% industry-wide reduction in emissions 

from 2006 to 2010. Because no HFC-134a emissions data is available for subpart T, ERG 

estimated the expected 2010 industry emissions of HFC-134a prior to the GWP change using the 

2006 and 2010 SF6 emissions data and assuming that SF6 reductions in the industry from 2006 to 

2010 were achieved by substituting HFC-134a for SF6 as a cover gas. ERG then summed the 

estimated 2010 HFC-134a industry emissions and the reported 2010 SF6 emissions from the 

Partnership data to determine total expected industry emissions prior to the GWP revisions. 

Expected industry emissions from the GWP revisions were estimated by multiplying the 2010 

SF6 emissions data and the estimated 2010 HFC-134a emissions by the change in GWP for SF6

and HFC-134a, respectively. If facilities were to convert from SF6 to FK-5-1-12 (proposed 

GWP=7), the anticipated emissions would be expected to be even lower. 
24 

Table 5-2. Summary of Subpart T Emissions Impacts Due to the Revised GWP 

Number of Expected 

Reporters Prior to 

Revised GWP 

Estimated HFC134a Industry 

Emissions from 

2011 Reporters 

(metric tons 

CO2e per year)a

Total Emissions Prior to 

GWP Revisions 

(non-biogenic) 

(metric tons CO2e 

per year)b

Emissions 

After GWP Revisions 

(metric tons CO2e 

per year)c

11 107,704 1,067,000 1,029,787

a Estimated 2010 HFC-134a Industry Emissions = (2006 Reported SF6 Emissions – 2010 Reported SF6 

Emissions)*(GWP HFC-134a/ GWP SF6 or 1300/23,900) 

b

 Total Emissions From 2011 Reporters Prior to Revised GWP = Estimated 2010 HFC-134a Industry Emissions + 

2010 Reported SF6 Emissions (from Partnership data) 

c

 Emissions for 2011 Reporters at Revised GWP = (2010 SF6 Emissions * (1-0.05)) + (Estimated 2010 HFC-134a 

Industry Emissions * (1+0.10)) 

5.5 Subpart W Emissions Impacts - 2011 Reporters 

The emissions that are attributed to 2011 reporters of subpart W (due to the revised 

GWPs) are shown in Table 5-3 for each subpart W industry segment. For six industry segments, 

ERG based emissions estimates on facility/emissions lists from the subpart W Economic Impact 

Analysis (U.S. EPA, 2010d). These facility lists contained source-specific emissions data for 

CO2, CH4, and N2O. ERG applied the revised GWPs to the source specific emissions data for 

each subpart W industry segment facility list. 

Table 5-3. 2011 Reporters — Summary of Emissions Impacts Due to GWP Revisions for 

Subpart W Industry Segments 

Industry Segment 

Number of 2011 

Reporters Prior to 

Table A-1 Revisionsa 

Total Emissions From 

2011 Reporters Prior to 

GWP Revisions 

(non-biogenic) 

(metric tons CO2e 

per year)b 

Emissions 

for 2011 Reporters 

After GWP Revisions 

(metric tons CO2e 

per year)c 

NG Processing 289 NA 49,407,234

NG Transmission 1145 NA 41,669,730

Underground NG Storage 133 NA 11,042,454

LNG Storagec33 NA 825,000

LNG Import/Export 4 NA 2,049,792

NG Distributionc143 NA 3,575,000

Onshore Production 981 NA 255,118,960

Offshore Production 58 NA 11,875,771

TOTAL 2,786 337,000,000 375,563,940

a

 Number of expected reporters is based on information provided in the EIA for subpart W (U.S. EPA, 2010d). 

b

 Total emissions for expected reporters is based on an estimate provided in the preamble to the subpart W final 

rule dated November 30, 2010 (75 FR 74458). 

c

 For LNG storage and NG distribution, these emissions were estimated by multiplying the number of expected 
25 

Table 5-3. 2011 Reporters — Summary of Emissions Impacts Due to GWP Revisions for 

Subpart W Industry Segments 

Industry Segment 

Number of 2011 

Reporters Prior to 

Table A-1 Revisionsa 

Total Emissions From 

2011 Reporters Prior to 

GWP Revisions 

(non-biogenic) 

(metric tons CO2e 

per year)b 

Emissions 

for 2011 Reporters 

After GWP Revisions 

(metric tons CO2e 

per year)c 

NG Processing 289 NA 49,407,234

NG Transmission 1145 NA 41,669,730

Underground NG Storage 133 NA 11,042,454

LNG Storagec33 NA 825,000

LNG Import/Export 4 NA 2,049,792

reporters in these two industry segments by 25,000 metric tons CO2e because ERG assumed the reporters would 

only just meet the 25,000 metric tons CO2e reporting threshold. 

5.6 Subparts DD and SS Emissions Impacts - 2011 Reporters 

The emissions that are projected for subpart DD (Use of Electric Transmissions and 

Distribution Equipment) and subpart SS (Electrical Equipment Manufacture) in the Technical 

Support Documents (U.S. EPA, 2010e , 2010f, 2010g) are assumed to be entirely SF6 emissions. 

This assumption was made because the majority of electrical equipment is filled with SF6, 

although perfluorocarbons are used in small quantities as dielectrics and heat transfer fluids in 

power transformers. This analysis used the information available in the Technical Support 

Document for Subpart DD and SS to estimate the number of facilities expected to report and the 

total emissions of SF6 from expected reporters. Emission impacts due to the revised GWP for 

SF6 were calculated by multiplying the total expected emissions of SF6 by the difference between 

the existing GWP and the revised GWP (23,900 – 22,800 = 1,100). 

5.7 Subpart FF Emissions Impacts - 2011 Reporters 

Emissions of methane are reported under subpart FF (Underground Coal Mines) for those 

mines that liberate 36.5 million cubic feet of methane or more each year. Information for the 

number of expected reporters and the expected methane emissions as stated in the Technical 

Support Document (U.S. EPA, 2010h) for subpart FF was used for this analysis. Emission 

impacts due to the revised GWP for methane was calculated by multiplying the total expected 

emissions of methane by the difference between the existing GWP and the revised GWP (25 - 21 

= 4). 

5.8 Subpart II Emissions Impacts - 2011 Reporters 

Emissions of methane are reported under Subpart II (Industrial Wastewater Treatment) 

for those industrial wastewater treatment facilities that use anaerobic treatment or sludge 

digestion. Information for the number of anticipated reporters and the expected methane 
26 

emissions as stated in the Technical Support Document for subpart II was revised for this 

analysis using information recently obtained by EPA (see Section 6.5 of this memorandum for a 

complete description of the revised methodology for estimating emissions). Emission impacts 

due to the revised GWP for methane were calculated by multiplying the total expected emissions 

of methane by the difference between the existing GWP and the revised GWP (25 - 21 = 4). 

5.9 Subparts LL, PP, RR, and UU Emissions Impacts - 2011 Reporters 

The revised GWPs will have no effect on subparts LL, PP, RR, and UU because CO2 is 

the sole emission type required to be reported for these subparts. GWP is a measure of the heat 

trapped by specific gas(es) as compared to the heat trapped by CO2. Actual CO2 emissions are 

not converted to CO2 equivalents, and thus GWP has no bearing on GHG emissions in these 

cases. 

5.10 Emissions Impacts Summary for Current Reporters 

Results are presented in Tables 5-4 through 5-6 (Table 5-4 shows emissions impacts for 

source categories for which 2010 e-GGRT data were available, Table 5-5 shows emissions 

impacts for source categories for which information other than the 2010 e-GGRT data were used, 

and Table 5-6 shows emissions impacts for all source categories for a total impact assessment). 

Additional details are provided in the Excel workbook associated with this memorandum that is 

entitled “GWP Change - Impact Analysis Summary.” 

Table 5-4. 2010 Reporters — Summary of Emissions Impacts Due to GWP Revisions for 

Source Categories With Reporting Data Available from 2010 Reporting Year 

Subpart 

Number of 2010 

Reporters Prior 

to Revised 

GWP

2010 Reported

Emissions Prior to 

GWP Revisions 

(non-biogenic) 

(metric tons 

CO2e per year)

2010 Reported 

Emissions 

After GWP Revisions 

(metric tons 

 CO2e per year) 

Change in Emissions 

Due to GWP Revisions 

from 2010 Reporters 

(metric tons 

 CO2e per year) 

C 4,211 619,572,472 619,684,811 112,339 

D 1,263 2,231,408,653 2,231,701,929 293,276 

E 2 4,397,310 4,227,092 (170,218) 

F 9 4,298,897 4,581,938 283,040 

G 22 13,596,985 13,596,985 0 

H 97 42,734,686 42,737,342 2,657 

K 10 2,240,907 2,242,650 1,743 

N 103 2,061,679 2,061,679 0 

O 5 6,351,797 8,034,752 1,682,955 

P 101 31,261,120 31,261,130 10 

Q 123 27,094,226 27,094,205 (21) 
27 

Table 5-4. 2010 Reporters — Summary of Emissions Impacts Due to GWP Revisions for 

Source Categories With Reporting Data Available from 2010 Reporting Year 

Subpart 

Number of 2010 

Reporters Prior 

to Revised 

GWP

2010 Reported

Emissions Prior to 

GWP Revisions 

(non-biogenic) 

(metric tons 

CO2e per year)

2010 Reported 

Emissions 

After GWP Revisions 

(metric tons 

 CO2e per year) 

Change in Emissions 

Due to GWP Revisions 

from 2010 Reporters 

(metric tons 

 CO2e per year) 

R 12 588,209 588,209 0 

S 70 15,566,816 15,566,989 174 

U 19 122,663 122,663 0 

V 36 11,990,739 11,526,582 (464,158) 

X 63 9,445,122 9,457,094 11,973 

Y 145 55,751,060 55,851,755 100,695 

Z 13 1,080,913 1,080,913 0 

AA 110 7,562,923 7,613,331 50,408 

BB 1 122,466 124,607 2,141 

CC 4 1,221,863 1,221,863 0 

EE 7 1,447,634 1,447,634 0 

GG 6 730,209 730,209 0 

HH 1,202 107,000,000 108,227,153 1,227,153 

MM 155 2,493,881,410 2,493,881,410 0 

NN 476 909,000,000 909,000,000 0 

OO 167 254,554,000 298,539,000 43,985,000 

TOTAL 8,432 6,855,084,759 6,902,203,925 47,119,166 

Table 5-5. 2011 Reporters — Summary of Emissions Impacts Due to GWP Revisions for Source 

Categories With Initial Report Required in 2011(Reporting Data Not Available) 

Subpart 

Number 

2011Reporters 

Prior to GWP 

Revisions

Total Emissions 

From 2011Reporters 

Prior to GWP 

Revisions 

(non-biogenic) 

(metric tons CO2e 

per year)

Emissions 

for 2011 Reporters 

After GWP 

Revisions 

(metric tons CO2e 

per year) 

Change in Emissions 

Due to GWP 

Revisions from 

2011Reporters 

(metric tons CO2e 

per year) 

I 94 5,622,570 6,657,398 1,034,829 

L 14 10,600,000 11,660,000 1,060,000 

T 11 1,067,000 1,029,787 (37,213) 

W 2,786 337,000,000 375,563,940 38,563,940 

DD 141 10,320,000 9,845,021 (474,979) 

FF 114 33,823,404 40,265,957 6,442,553 
28 

Table 5-5. 2011 Reporters — Summary of Emissions Impacts Due to GWP Revisions for Source 

Categories With Initial Report Required in 2011(Reporting Data Not Available) 

Subpart 

Number 

2011Reporters 

Prior to GWP 

Revisions

Total Emissions 

From 2011Reporters 

Prior to GWP 

Revisions 

(non-biogenic) 

(metric tons CO2e 

per year)

Emissions 

for 2011 Reporters 

After GWP 

Revisions 

(metric tons CO2e 

per year) 

Change in Emissions 

Due to GWP 

Revisions from 

2011Reporters 

(metric tons CO2e 

per year) 

II 244 5,845,000 6,958,333 1,113,333 

JJ 0 0 0 0 

LL 0 0 0 0 

PPa99 33,500,000 33,500,000 0 

QQ 108 21,907,182 23,822,182 1,915,000 

RR 10 7,162,885 7,162,885 0 

SS 10 814,128 776,658 (37,470) 

TT 200 13,700,000 16,309,524 2,609,524 

UU 92 48,735,442 48,735,442 0 

TOTAL 3,923 530,097,611 582,287,127 52,189,517 

a

 Subpart PP included in this table although reporting was required in 2010 because data is not available. 

Table 5-6. 2010 and 2011 Reporters — Summary of Emissions Impacts Due to 

GWP Revisions for All Source Categories 

Number of 

Reporters Prior 

to Revised GWP

Total Emissions Prior 

to Revised GWP 

(non-biogenic) 

(metric tons 

CO2e per year)

Total Emissions 

at Revised GWP 

(metric tons 

CO2e per year) 

Change in 

Emissions (metric 

tons 

CO2e per year) 

2010 Reporters 

Total 8,432 6,855,084,759 6,902,203,925 47,119,166 

2011Reporters 

Total 3,923 530,097,611 582,287,127 52,189,517 

TOTAL 12,355 7,385,182,369 7,484,491,052 99,308,682 

5.11 References for Section 5 

U.S. EPA, 2012a. 2010 Greenhouse Gas Reporting Program Data (December 2012 eGGRT database) 

U.S. EPA, 2010a. Economic Impact Analysis for the Mandatory Reporting of Greenhouse Gas Emissions 

F-Gases: Subparts I, L, DD, QQ, SS. Available at: 

http://www.epa.gov/climatechange/emissions/downloads10/F-gas_EIA.pdf

U.S. EPA, 2010b. Technical Support Document for Emissions from Production of Fluorinated Gases: 

Final Rule for Mandatory Reporting of Greenhouse Gases. Available at: 

http://www.epa.gov/climatechange/emissions/downloads10/Subpart-L_TSD.pdf
29 

U.S. EPA, 2010c. Technical Support Document for Imports and Exports of Fluorinated Greenhouse 

Gases in Pre-charged Equipment and Closed-cell Foams, Mandatory Reporting of Greenhouse Gases: 

Additional Sources of Fluorinated Greenhouse Gases, Revised September 2010. Available at: 

http://www.epa.gov/climatechange/emissions/downloads10/Subpart-QQ_TSD.pdf

U.S. EPA, 2012b. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2010, April 2012. 

http://epa.gov/climatechange/Downloads/ghgemissions/US-GHG-Inventory-2012-Main-Text.pdf

U.S. EPA, 2010d. Economic Impact Analysis for the Mandatory Reporting of Greenhouse Gas Emissions 

Under Subpart W Final Rule (GHG Reporting). See Docket ID: EPA– HQ–OAR–2008–0508. Available 

at: http://www.epa.gov/climatechange/emissions/downloads10/Subpart-W_EIA.pdf

U.S. EPA, 2010e. Economic Impact Analysis for the Mandatory Reporting of Greenhouse Gas Emissions 

F-Gases: Subparts I, L, DD, QQ, SS. Available at: 

http://www.epa.gov/climatechange/emissions/downloads10/F-gas_EIA.pdf

U.S. EPA, 2010f. Technical Support Document for Process Emissions of Sulfur Hexafluoride (SF6) and 

PFCs from Electric Power Systems: Proposed Rule for Mandatory Reporting of Greenhouse Gases. 

Available at: http://www.epa.gov/climatechange/emissions/downloads10/Subpart-DD_TSD.pdf

U.S. EPA, 2010g. Technical Support Document for Emissions from Electric Equipment Manufacture or 

Refurbishment and Manufacturing of Electrical Components. Available at: 

http://www.epa.gov/climatechange/emissions/downloads10/Subpart-SS_TSD.pdf

U.S. EPA, 2010h. Technical Support Document for Underground Coal Mining: Rule for Mandatory 

Reporting of Greenhouse Gases. Available at: 

http://www.epa.gov/climatechange/emissions/downloads10/Subpart-FF_TSD.pdf

U.S. EPA, 2010i. Subpart I Detailed Threshold Analysis. See Docket ID: EPA-HQ-OAR-2009-0927-

0158. November 2010. 

U.S. EPA, 2009. Technical Support Document for Process Emissions From Magnesium Production and 

Processing: Proposed Rule for Mandatory Reporting of Greenhouse Gases. Available at: 

http://www.epa.gov/climatechange/emissions/archived/downloads/tsd/TSD%20Magnesium_20090210.pd

f

U.S. EPA, 2010j. Technical Support Document for Process Emissions from Electronics Manufacture 

(e.g., Micro-Electro-Mechanical Systems, Liquid Crystal Displays, Photovoltaics, and Semiconductors): 

Proposed Rule for Mandatory Reporting of Greenhouse Gases. Revised November 2010. Available at: 

http://www.epa.gov/climatechange/emissions/downloads10/Subpart-I_TSD.pdf

6.0 METHODOLOGY FOR NEW REPORTERS 

To estimate the cost impacts resulting from the proposed new and revised GWPs, we 

used the subpart-specific regulatory impacts analysis from the original GHG reporting rule, and 

updated the cost information to 2011 dollars. As discussed in Section 2.2, ERG does not expect 

that the new GWPs proposed to be added to Table A-1 to subpart A will result in any new 

reporters with the exception of subpart OO. An additional three reporters is expected for subpart 

OO. 
30 

In the original economic analysis, each affected subpart used similar methodologies for 

estimating economic impacts and identifying affected facilities. In general, for the original 

economic analysis, EPA determined total reporting costs for each subpart by assigning model 

facility costs to individual affected facilities in each industry sector. Model facilities of various 

sizes were developed for some of the subparts. Labor costs were determined for monitoring, 

recordkeeping, and reporting according to the rule requirements. Capital costs for monitoring 

equipment were also estimated for each model facility. The total cost for each subpart was 

determined by multiplying the model facility cost by the number of affected facilities. For 

“threshold” categories, EPA estimated the number of facilities that exceeded the annual 

emission-based threshold of 25,000 metric tons CO2e. 

For this analysis, ERG used the costs developed for the original GHG reporting rule, and 

multiplied the individual facility cost by the number of additional facilities that did not 

previously exceed the threshold, but will exceed the threshold after the proposed revisions to 

Table A-1. 

For this analysis, ERG used several data sources to identify additional affected facilities 

in each subpart. Information from industry surveys, publicly available data sources, and existing 

data from EPA, states, and industry trade associations were assessed to compile a list of affected 

facilities in each subpart. Combined with source-specific emissions data, we used these facility 

lists to estimate the additional facilities that would be required to report using the proposed new 

and revised GWPs. Once the facilities were identified, EPA determined the reporting costs by 

assigning model facility costs to individual facilities in the respective industry segment based on 

relative size. 

Summaries of the methodology, reference documents, and any assumptions specific to 

each subpart are documented in the following individual subpart sections of this section. 

6.1 Subpart I (Electronics Manufacturing) Impacts - New Reporters 

Subpart I requires reporting of fluorinated GHGs from the following source categories 

that emit 25,000 metric tons CO2e per year or more: electronics manufacturing including 

manufacture of semiconductors, PVs, LCDs, and MEMS. Changes to the following GWPs affect 

subpart I: CF4, C2F6, CHF3, C3F8, SF6, C6F14 (semiconductors); SF6 (MEMS); CF4, SF6 (LCDs); 

and CF4, C2F6 (PVs). As discussed in Section 5.2, ERG has assumed that facilities that 

manufacture MEMS, LCDs, and PVs do not use any of the new F-GHGs EPA is proposing to 

add to Table A-1 to subpart A. ERG also assumed that the addition of new F-GHGs or F-HTFs 

to Table A-1 would not affect the number of new reporters for semiconductors. As discussed in 

Section 2.2 of this document, subpart I reporters must calculate annual emissions for threshold 

applicability purposes considering only the gases for which default emission factors are provided 
31 

in Table I-1. Although facilities must also account for F-HTF emissions, these emissions are 

estimated as a percentage of the total annual production process emissions at a facility 

(calculated based on gases in Table I-1.) 

By revising the GWP values in subpart A, four additional non-large semiconductor 

facilities will be required to report under subpart I with an additional annualized industry wide 

cost of approximately $89,000 per year. These changes are not expected to have a significant 

economic impact on a substantial number of small entities. 

6.1.1 Methodology for Identifying Affected Facilities 

In the original threshold analysis (U.S. EPA, 2010c), EPA identified the number of 

facilities that would be covered under subpart I with a 25,000 metric tons CO2e emissions-based 

threshold. The original threshold analysis included a list of facilities for each product type (e.i., 

semiconductors, MEMS, LCDs, and PVs) and estimates of substrate area processed and total 

annual emissions for each facility. 

For LCDs and PVs, EPA calculated the total annual emissions, in metric tons of CO2e, 

for each facility using the IPCC Tier 1 default emissions factors. The emissions factors were 

converted to metric tons of CO2e basis by multiplying the factors by the appropriate GWP value. 

EPA evaluated the results to determine which facilities were expected to emit greater than the 

25,000 metric tons CO2e threshold. EPA also used the results to estimate the magnitude of 

emissions from those facilities expected to emit greater than the 25,000 metric tons CO2e 

threshold. The number of, and emissions from, MEMS facilities were calculated using the same 

procedure, but with an emission factor developed by the EPA (U.S. EPA, 2010d). 

In the original analysis, EPA used the same procedure described above (i.e., default IPCC 

Tier 1 factors) to determine the number of semiconductor facilities that were expected to emit 

greater than the 25,000 metric tons CO2e threshold. EPA did not consider emissions from heat 

transfer fluids when determining which semiconductor facilities would meet the threshold. To 

estimate the magnitude of emission from those semiconductor facilities expected to emit greater 

than the threshold, EPA used emission estimations that were derived using outputs from the EPA 

PEVM, as well as the EPA PFC Reduction/Climate Partnership for Semiconductors partner and 

non-partner shares of U.S. emissions. EPA also accounted for heat transfer fluid emission 

estimates by assuming such emissions were equal to 11 percent of total clean and etch emissions 

at a facility. 

To determine the additional number of facilities that now meet the threshold due to 

changes to the GWP values in subpart A, ERG recreated the EPA’s original threshold analysis 

with the updated GWP values. ERG was not able to access the PEVM to reproduce the original 

emission estimates; therefore, we assumed that the PEVM based emissions would increase by the 
32 

same percentage as the emissions estimated using the IPCC Tier 1 default factors and updated 

GWP values. We believe this is a valid assumption because no other inputs to the PEVM are 

expected to change. Detailed threshold analyses for each facility type (e.g., semiconductor, 

MEMS, etc) are provided in the Excel workbook associated with this memorandum that is 

entitled “Subpart I GWP Impact Analysis.” 

6.1.2 Methodology for Estimating Impacts 

To determine cost impacts for subpart I resulting from the revised GWPs, ERG used the 

procedures and calculations presented in the Economic Impact Analysis (EIA) for the Mandatory 

Reporting of Greenhouse Gas Emissions F-Gases: Subparts I, L, DD, QQ, SS Final Report and 

the subpart I cost tables available in the rulemaking docket (U.S. EPA, 2010a, 2010b). The 

original EIA and cost tables presented all costs in year 2006 dollars; therefore, ERG updated 

labor and equipment costs to year 2011 dollars using the Bureau of Labor Statistics Labor Index 

and the Chemical Engineering Plant Cost Index (CEPCI), respectively. Costs were updated to 

year 2011 dollars using the ratios presented in Table 6-1. 

Table 6-1. Labor and Equipment Cost Indices 

Year Index

Bureau of Labor Statistics – All Occupations Labor Indexa(Ratio to year 2004)

2006 1.06416 

2011 1.18387 

Labor Cost Adjustment Factor 1.11249 

Chemical Engineering Plant Cost Indexb 

2006 499.6 

2011 585.7 

Equipment Cost Adjustment Factor 1.172 

a

 Bureau of Labor Statistics – All Occupations Labor Index http://data.bls.gov/cgi-bin/surveymost?cm 

b

 Chemical Engineering Plant Cost Index http://www.che.com/pci/

In the original EIA (U.S. EPA, 2010a, 2010b), EPA calculated costs for monitoring, 

reporting, and recordkeeping for each facility type (i.e., non-semiconductor facilities, large 

semiconductor facilities, and non-large semiconductor facilities) by estimating the number of 

labor hours necessary to comply with the subpart I requirements. EPA then multiplied the labor 

hour requirements by the appropriate loaded hourly rate to determine the total labor costs. A 

capital and operations and maintenance (O&M) cost component was calculated for large 

semiconductor facilities. The capital and O&M cost included the development and maintenance 

of apportioning software and emission factors. EPA determined that non-large semiconductor 

facilities and non-semiconductor facilities would not incur any capital and O&M costs. 
33 

After identifying the additional facilities that are affected by the change in GWPs 

(described in Section 6.1.1), final cost impacts were determined by multiplying the number of 

additional facilities by the updated facility cost for each facility type (i.e., non-semiconductor 

facilities, large semiconductor facilities, and non-large semiconductor facilities). Updated costs 

on a facility basis are presented in Table 6-2. Detailed updated costs on a facility- and industrywide basis can be found in the Excel workbook associated with this memorandum that is entitled 

“Subpart I GWP Impact Analysis.” 

Table 6-2. Subpart I Compliance Costs on a Facility Basis (2011 Dollars) 

Facility Type 

First Year Cost 

($/year) 

Subsequent Year Cost 

($/year) 

Tier 2b (Non-Semiconductor Facilities) 17,851 17,851

Tier 2c (Non-Large Semiconductor Facilities) 22,228 22,228

Tier 2da(Large Semiconductor Facilities) 64,053 151,003

a

Includes Capital and O&M Costs for apportioning software and emission factor development.

6.1.3 Impacts 

Table 6-3 summarizes the impacts of updating the GWP values in Table A-1 to subpart 

A, on facilities regulated by subpart I. 

Table 6-3. New Reporters—Summary of Subpart I Impacts Due to the Revisions to GWPs

Facility Type 

Total 

Number 

of 

Facilities 

in 

Source 

Category 

Number 

of 

Reporters 

Prior to 

GWP 

Revisions 

Number of 

New 

Reporters 

Due to 

GWP 

Revisions 

Total 

Emissions 

Prior to 

GWP 

Revisions 

(metric tons 

of CO2e per 

year)a 

Incremental 

Emissions 

For New 

Reporters 

(metric tons 

of CO2e per 

year ) 

Incremental 

Cost Impact 

For New 

Reporters 

(2011$ per 

year) 

Large 

Semiconductor 29 29 0 3,287,000 - - 

Non-Large 

Semiconductor 146 62 4 2,205,000 18,100 88,900 

NonSemiconductor 41 3 0 130,500 - - 

Total 216 94 4 5,623,000 18,100 88,900

a Based on estimates provided in the 2010 EIA (U.S. EPA, 2010a).

6.1.4 Small Entity Impacts 

In the subpart I Economic Impact Analysis (U.S. EPA, 2010a), EPA originally assessed 

the impact of complying with subpart I requirements on all small entities in the electronics 

manufacturing industry by calculating a cost-to-sales ratio for six enterprise size ranges (i.e., 1 to 

20 employees, 20 to 99 employees, 100 to 499 employees, 500 to 749 employees, 750 to 999 
34 

employees, and 1,000 to 1,499 employees) using the average total annualized mandatory 

reporting costs to the average annual sales receipts for each establishment. The results of this 

analysis are represented in Table 14 of the preamble for the publication of the subpart I rule (75 

FR 74811, December 1, 2010). 

Based on this analysis, EPA concluded that subpart I will not have a significant economic 

impact on a substantial number of small entities (U.S. EPA, 2010a)4. EPA made this 

determination assuming that all entities in the industry would report (including those above and 

below the reporting threshold), resulting in a conservatively high analysis. EPA determined that 

no significant small business economic impacts were expected to occur. The analysis showed 

that the cost-to-sales ratio for all entity sizes except for the smallest sized enterprises was less 

than 1 percent. EPA concluded that although the cost-to-sales ratio for the 1 to 20 employee 

range for semiconductor and related device manufacturing was greater than one percent (i.e., 

1.16 percent); facilities with emissions greater than 25,000 metric tons CO2e per year are 

unlikely to be included in the 1 to 20 employees size category (U.S. EPA, 2010a). 

The revised emission estimates (using the revised GWPs) place the 4 new affected 

facilities above the 25,000 metric tons CO2e threshold. In addition, the emission estimates for the 

4 facilities in the original threshold analysis were just slightly below the threshold (3 to 10 

percent). Based on EPA’s conclusion that facilities with emissions greater than 25,000 metric 

tons CO2e per year are unlikely to be included in the 1 to 20 employees size category, ERG does 

not expect the 4 additional facilities to be included in the 1 to 20 employees size category either. 

As a result, the changes to the GWPs will not have a significant impact on a substantial number 

of small entities. 

6.1.5 References for Subpart I 

U.S. EPA, 2010a. Economic Impact Analysis for the Mandatory Reporting of Greenhouse Gas Emissions 

F-Gases: Subparts I, L, DD, QQ, SS Final Report. See Docket ID: EPA-HQ-OAR-2009-0927-0179. 

November 2010. 

U.S. EPA, 2010b. Subpart I Cost Tables. See Docket ID: EPA-HQ-OAR-2009-0927-0240. November 

2010. 

U.S. EPA, 2010c. Subpart I Detailed Threshold Analysis. See Docket ID: EPA-HQ-OAR-2009-0927-

0158. November 2010. 

U.S. EPA, 2010d. Technical Support Document for Process Emissions from Electronics Manufacture 

(e.g., Micro-Electro-Mechanical Systems, Liquid Crystal Displays, Photovoltaics, and Semiconductors): 

Proposed Rule for Mandatory Reporting of Greenhouse Gases. See Docket ID: EPA-HQ-OAR-2009-

0927-0195. Revised November 2010. 

 

4

 Refer to Section 5.3 of the 2010 EIA (U.S. EPA, 2010a). 
35 

6.2 Subpart T Impacts - New Reporters 

Magnesium production and processing facilities are defined as any site where magnesium 

metal is produced through smelting (including electrolytic smelting), refining, or remelting 

operations, or any site where molten magnesium is used in alloying, casting, drawing, extruding, 

forming, or rolling operations. Each facility must report total annual emissions for each of the 

following cover or carrier gases used in magnesium production or processing: SF6, HFC-134a, 

the fluorinated ketone FK 5-1-12, CO2, and any other fluorinated GHG as defined in the 

greenhouse gas reporting rule. 

The change of GWP for HFC-134a from 1,300 to 1,400, the change of GWP for SF6 from 

23,900 to 22,800, and the addition of a GWP of 7 for FK-5-1-12 is not anticipated to result in 

additional facilities subject to subpart T. Therefore, there are no significant rule implementation 

costs associated with the proposed amendment. There is no significant economic impact on small 

entities for the facilities subject to subpart T. 

6.2.1 Methodology for Identifying Affected Facilities 

As discussed in section 5.4 of this memorandum, the 2010 Threshold Analysis for the 

magnesium production category for the original rule (U.S. EPA, 2009), identified 13 nationwide 

facilities in the magnesium production and processing source category. EPA evaluated a range 

of threshold options for these facilities, utilizing 2006 annual reporting data on metal production 

and SF6 consumption provided through the EPA’s SF6 Emission Reduction Partnership for the 

Magnesium Industry as the basis for the analysis. These included emission-based thresholds of 

1,000, 10,000, 25,000 and 100,000 metric tons CO2e, as shown in Table 6-4, and capacity-based 

thresholds equivalent to these. The July 12, 2010 final rule established an emissions threshold of 

25,000 metric tons CO2e, which was estimated to cover all currently operating U.S. primary and 

secondary magnesium ingot producers and most die casters, accounting for over 99 percent of 

emissions from these source categories. This threshold analysis excluded small die casting 

facilities as well as facilities that performed other types of casting, which represent only a small 

fraction of total emissions from this source category. The emissions threshold of 25,000 metric 

tons CO2e established in the final rule was equal to emissions of 1,046 kg of SF6 ; 19,231 kg of 

HFC–134a; or 25,000,000 kg of CO2 (based on the GWP values established in Table A-1 to 

subpart A of part 98) (U.S. EPA, 2009). 

Table 6-4. Threshold Analysis for Subpart T – Magnesium Production 

Emission 

Threshold 

Level (metric 

tons 

CO2e/yr) 

Total 

National 

Emissions 

(metric tons 

CO2e/yr) 

Total 

Number of 

Facilities 

Emissions Covered Facilities Covered

metric tons 

CO2e/yr Percent Facilities Percent 

1,000 3,200,000 13 2,954,559 92% 13 100.0%
36 

10,000 3,200,000 13 2,939,741 92% 11 85.0%

25,000 3,200,000 13 2,939,741 92% 11 85.0%

100,000 3,200,000 13 2,872,982 90% 9 69.0%

Facility-level information from the threshold analysis for the 2010 final rule was not 

published in Docket No. EPA–HQ–OAR–2008–0508 due to confidentiality concerns. Therefore, 

ERG estimated the incremental impacts to the magnesium production industry based on the 

available aggregate data. In order to estimate the source category impacts from revising the 

GWPs in Table A-1 to subpart A of part 98, the 2004 GWPs reflected in Table A-1 to subpart A 

were compared to the proposed new and revised GWPs to determine the increase for each 

reported pollutant. 

Only SF6 and HFC-134a have been evaluated for the purposes of estimating the impacts 

of the revised GWPs. Table 6-5 lists the pollutants and associated increase in GWP for each 

chemical. Emissions of the fluorinated ketone FK 5–1–12, although required to be reported 

under 40 CFR 98.202, are not included in this threshold analysis, because this gas has a GWP of 

1.8 and is not expected to significantly impact reported emissions. 

Table 6-5. Proposed Increase in GWP for Pollutants Associated with 

Magnesium Production and Processing 

Pollutant Name CAS No. Chemical formula 

GWP in Table A1 of the final rule Proposed GWP % Increase 

FK-5-1-12 756-13-8 C3F7C(O)C2F5 NA 1.8 -

HFC–134a 811–97–2 CH2FCF3 1,300 1,430 10

SF6 2551–62–4 SF6 23,900 22,800 -5

As shown in Table 6-5, emissions from facilities utilizing SF6 that meet the current 

25,000 metric tons CO2e threshold would decrease as a result of the revised GWP for SF6. For 

these facilities, this decrease would be significant only if the proposed revision to the GWP 

reduced their annual emissions to less than 25,000 metric tons CO2e for 5 consecutive years (per 

40 CFR 98.2(i)). Therefore, ERG has not assessed the impacts of these emissions reductions in 

this memorandum. Facilities utilizing the cover gas HFC-134a could potentially become subject 

to the GHG reporting rule if the increase in the GWP brought facility-wide emissions above 

25,000 metric tons CO2e. This would include only facilities with current total facility emissions 

between 22,500 metric tons CO2e and 25,000 metric tons CO2e. 

The aggregate data from the 2010 Threshold Analysis showed that the 11 facilities 

exceeding the 10,000 metric tons CO2e threshold also exceeded the 25,000 metric tons CO2e 

threshold (see Table 6-5). Based on these data, there would be no facilities meeting the 10,000 

metric tons CO2e threshold that would be affected by the revised GWPs, because these facilities 
37 

already exceed the 25,000 metric tons CO2e threshold. Only two facilities not meeting the 25,000 

metric tons CO2e threshold could potentially be affected by an increase in the GWPs; these two 

facilities did not exceed the 10,000 metric tons CO2e threshold at the time subpart T was 

finalized in July 2010, therefore it is unlikely that these facilities would exceed 25,000 tons CO2e 

per year with the proposed GWP change. 

ERG received updated data from the SF6 Emission Reduction Partnership program for the 

2010 reporting year. These data were used to verify the conclusion that no additional facilities 

will be impacted by the revised GWPs. As discussed in section 5.4 of this memorandum, EPA 

operated the SF6 Emission Reduction Partnership to encourage industry to reduce emissions of 

SF6 and eliminate the usage of SF6 as a cover gas. As a result, facilities have increased usage of 

FK 5–1–12 (proposed GWP=1.8) and HFC-134a (proposed GWP=1,430) as cover gases, 

resulting in an overall reduction in industry GHG emissions. Facilities reporting under the SF6

Emission Reduction Partnership include major emitters. Non-reporting facilities include smaller 

facilities (e.g., sand casting or small die casters) whose emissions are expected to be less than the 

threshold reporting level. The Partnership data is limited because not all facilities consistently 

report gas use each year; additionally, process data reported under the Partnership has 

historically been considered confidential. For this analysis, only aggregate facility-level 

emissions based on SF6 usage were available; emissions data from other gas usage were not 

available. Based on the 2010 SF6 Partnership data, 16 facilities reported, and 11 facilities

reported use of SF6. This is close to the original estimate of 13 processing facilities in the 2010 

Threshold Analysis, which was based on 2006 emission estimates. The reported 2010 SF6

emissions are summarized in Table 6-6. 

Table 6-6. 2010 SF6 Emissions Reported through the SF6 Partnership 

Total Number of 

Facilities

SF6 Emissions Level 

(metric tons CO2e/yr)

Facilities Meeting SF6 Emission 

Level 

16 

0-999 16

1,000-9,999 11

10,000-22,499 9

22,500-24,999 9

25,000-99,999 7

>100,000 3

For the purposes of this analysis, ERG assumed that the 11 facilities reporting SF6 usage 

through the EPA’s SF6 Magnesium Partnership are using FK 5–1–12, HFC-134a, or alternative 

cover gases in addition to the SF6 reported. Five facilities reported no emissions of SF6; these 

facilities are assumed to have used only alternative gases, such as HFC-134a or FK 5–1–12, for 

all production in 2010. Total SF6 emissions reported through the Partnership showed a 67% 

reduction in emissions from 2006. Based on the Inventory of U.S. Greenhouse Gas Emissions 
38 

and Sinks: 1990-2012 (U.S. EPA, 2012), emissions of SF6 from magnesium production and 

processing in the United States were estimated to be 1.3 million metric tons CO2e in 2010, a 

reduction from 3.2 million metric tons CO2e in 2006. Therefore, we anticipate that the emissions 

estimates summarized in Table 6-6 are a reasonable representation of gas usage in the industry 

following the 2010 Threshold Analysis. 

There is no available data on the total gas consumption of the alternative cover gases 

HFC-134a or FK-5-1-12. ERG examined whether the field of potential reporters could be 

affected if HFC-134a usage were increased. Without data on HFC-134a usage, it is unclear 

whether the five facilities that did not report SF6 emissions to the SF6 Partnership currently 

exceed or could exceed the 25,000 metric tons CO2e threshold. However, because the GWPs of 

HFC-134a (proposed GWP=1,430) and FK-5-1-12 (proposed GWP=1.8) are significantly lower 

than that of SF6 (proposed GWP = 22,800), facilities converting production gases entirely from 

SF6 using entirely HFC-134a FK-5-1-12 would need to use significantly more cover gas to 

exceed the threshold. For example, a facility would need to use approximately 16 times more 

HFC-134a as a cover gas in production to meet the 25,000 metric tons CO2e threshold than if SF6

were used. Furthermore, the 2010 Partnership Data show the largest-emitting facility to have 

maximum SF6 emissions of ~386,000 metric tons CO2e. Assuming that total gas usage rates 

remained the same, if this facility were to convert all production gases to HFC-134a, the 

maximum GHG emissions would be just under the 25,000 metric tons CO2e threshold (386,000 * 

[1,430/22,800] = 24,200). Similarly, if this facility were to convert all production gases to FK-5-

1-12, the maximum GHG emissions would be under 17 metric tons CO2e (386,000 

*[1.8/22,800]= 30.5). Therefore, facilities utilizing the cover gas FK-5-1-12 are unlikely to 

exceed the 25,000 metric tons CO2e threshold. Therefore, we anticipate that the remaining 

facilities do not likely use sufficient HFC-134a of FK-5-1-12 to meet or exceed the 25,000 

metric tons CO2e threshold, and the total number of facilities required to report would not be 

affected due to in the proposed new or revised GWPs. The total number of facilities reporting 

under subpart T is expected to decrease over time due to the conversion of cover gas from SF6 to 

HFC-134a or FK 5–1–12. 

6.2.2 Impacts 

Because there are no new facilities anticipated to be affected by the proposed new or 

revised GWPs, ERG does not anticipate a cost impact for subpart T. 

6.2.3 Small Entity Impacts 

Because it is not anticipated that any new entities will be required to report as a result of 

the proposed new or revised GWP in subpart A of part 98, we do not anticipate that there will be 

significant impact on a substantial number of small entities as a result of this action 
39 

6.2.4 References for Subpart T 

U.S. EPA, 2009. Additional Methodological Information Supporting Threshold Analysis for Specific 

Source Categories. See Docket ID No. EPA-HQ-OAR-2008-0508-0046. March 2009. 

U.S. EPA, 2010. Economic Impact Analysis for the Mandatory Reporting of Greenhouse Gas Emissions: 

Subparts: T, FF, TT, and II.. See Docket ID No. EPA-HQ-OAR-2008-0508-2313. June 2010. 

U.S. EPA, 2012. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2012. April 15, 2012. 

USEPA #430-R-12-001.

6.3 Subpart W Impacts - New Reporters 

Subpart W requires petroleum and natural gas facilities to report annual CH4, CO2, and 

N2O emissions from specific source types that are dependent upon the industry segment. 

ERG determined that 99 additional facilities would be subject to subpart W due to the 

revised GWP. The total cost for the 99 additional facilities is $3.4 million for the first year and 

$860,000 for the subsequent years. Table 6-7 shows a summary of the subpart W impacts due to 

the revised GWP; the summary table provides estimated changes to the number of affected 

facilities and expected emissions reported. 

Table 6-7. Summary of Subpart W Impacts Due to the Revised GWP 

Total Number 

of Facilities in 

Source 

Category 

Number of 

Reporters Prior 

to GWP 

Revisions 

Number of New 

Reporters Due 

to GWP 

Revisions 

Total Emissions 

Prior to GWP 

Revisions 

(metric tons of 

CO2e per year)a 

Incremental 

Emissions For 

New Reporters 

(metric tons of 

CO2e per year) 

Incremental 

Cost Impact 

For New 

Reporters 

(2011$ per 

year) 

29,530 2,786 99 337,000,000 2,572,881 860,000

a Total emissions for reporters is based on an estimate provided in the preamble to the subpart W final rule dated 

November 30, 2010 (at 75 FR 74458). 

6.3.1 Methodology for Identifying Affected Facilities 

To identify the additional facilities that may be required to report using the revised GWPs 

(see the Excel workbook associated with this memorandum that is entitled “Subpart W GWP 

Impact Analysis”), ERG used facility lists and source specific emissions data. ERG obtained 

facility lists that were used to develop the subpart W Economic Impact Analysis (U.S. EPA. 

2010). These facility lists also contain source-specific emissions data for CO2, CH4, and N2O. 

Subpart W requires emissions reporting for CO2, CH4, and N2O; therefore, ERG 

evaluated the incremental cost impacts due to the revised GWP for only these compounds. The 

GWP for CO2 remains the same. The GWP for CH4 is increasing by 19%. The GWP for N2O is 

decreasing by 4%. ERG applied these GWP changes to the source specific emissions data for 

each subpart W facility to identify the additional facilities that would be required to report under 
40 

the new GWPs The number of new affected facilities that ERG identified for each subpart W 

industry segment is provided in Table 6-8. 

Table 6-8. Number of New Affected Facilities by Industry Segment 

Segment

Number of New Affected Facilities

(due to GWP Revisions)

NG Processing 2

NG Transmission 7

Underground NG Storage 6

LNG Storage 2

a

LNG Import/Export 0

NG Distribution 16b

Onshore Production 52c

Offshore Production 14

Total (8 Segments) 99

a The list of LNG storage facilities used in the EIA (U.S. EPA. 2010) is not available. However, the EIA identifies 41

LNG storage expected reporters that would have to report under the annual emission-based threshold of 10,000 

metric tons CO2e, and 33 expected reporters that would have to report under the annual emission-based threshold 

of 25,000 metric tons CO2e. Because CH4 is the primary GHG emittedfrom LNG storage facilities, the LNG 

storage facilities with GHG emissions between 21,000 metric tons/yr and 25,000 metric tons/yr of CO2e in the EIA 

are the only facilities that would be affected by the GWP change for CH4 from 21 to 25. Assuming an even 

distribution of facilities across the range of emissions between 10,000 and 25,000, the number of additional LNG 

storage facilities that would be required to report is 2. 

b

 The list of NG distribution facilities used in the EIA (U.S. EPA. 2010) is not available. However, the EIA identifies 

the number of NG Distribution expected reporters (203) that would have to report under the annual emission-based 

threshold of 10,000 metric tons CO2e, and the expected reporters (143) that would have to report under the annual 

emission-based threshold of 25,000 metric tons CO2e. Assuming that CH4 emissions are the main GHG emissions 

from NG Distribution facilities, the NG Distribution facilities with GHG emissions between 21,000 metric tons/yr 

and 25,000 metric tons/yr of CO2e in the EIA are equal to the additional facilities affected by the GWP change for 

CH4 from 21 to 25. Assuming an even distribution of facilities across the range of emissions between 10,000 and 

25,000, the number of additional NG distribution facilities that would be required to report is 16. 

c

 Conservatively assumes that all emissions related to non-combustion sources are methane, and all emissions related 

to combustion sources are carbon dioxide.

6.3.2 Methodology for Estimating Impacts 

ERG determined the incremental impacts due to the revised GWP factors by multiplying 

the average costs per facility by the number of additional facilities required to report under 

subpart W due to the revised GWP factors. In the original economic impact analysis, EPA 

estimated the total cost to the private sector (in 2006 dollars) for the petroleum and natural gas 

systems source category (subpart W) to be $61.8 million in the first reporting year and $19.0 

million in subsequent years (U.S. EPA, 2010). Table 6-9 shows the annualized, first-year, and 

subsequent year cost estimates for each of the eight subpart W industry segments. These 

estimates include costs for reporters to monitor and report emissions, and the costs for non-
41 

reporters to make an applicability determination for the annual emission-based threshold of 

25,000 MtCO2e. 

Table 6-9. Cost Estimates for Petroleum and Natural Gas Systems (2006 Dollars) 

Segment

First Year Subsequent Year

Annualized 

Costa

($Million)

Annualized 

Costb

($Million)

National 

Cost 

($Million)

Cost

($/metric 

ton)

National 

Cost 

($Million)

Cost

($/metric 

ton)

NG Processing 8.13 0.26 2.10 0.07 2.43 2.57

NG 

Transmission 16.87 0.40 6.49 0.15 7.02 7.26 

Underground 

NG Storage 2.73 0.35 1.02 0.13 1.10 1.14 

LNG Storage 0.70 0.41 0.26 0.15 0.28 0.29

LNG 

Import/Export 0.14 0.44 0.03 0.09 0.04 0.04 

NG Distribution 3.31 0.15 1.35 0.06 1.47 1.52

Onshore 

Production 26.58 0.12 7.54 0.03 8.61 9.05 

Offshore 

Production 3.33 0.65 0.24 0.05 0.42 0.49 

Total 

(8 Segments) 61.78 0.18 19.01 0.06 21.36 22.34 

a

 The cost to report annualized over 20 years at 3 percent. 

b

 The cost to report annualized over 20 years at 7 percent.

With the exception of onshore production, EPA determined these total reporting costs 

shown in Table 6-9 by assigning model facility costs (small, medium, and large) to individual 

facilities in the respective industry segments that were estimated to exceed the annual emissionbased threshold of 25,000 metric tons CO2e. Average cost per facility was then determined by 

dividing the total segment costs by the number of facilities that exceeded the reporting threshold. 

Non-monitoring costs for facilities in the onshore production industry segment were estimated 

using the model facilities; however, equipment monitoring costs were estimated at the national 

level and then apportioned to individual operators in basins by production rates. Additional 

details of the data, methods, and assumptions underlying these costs are documented in the final 

report (U.S. EPA, 2010). 

For this analysis, the cost estimates identified in Table 6-9 were updated to 2011 dollars 

by multiplying the estimates by the ratio of the 2006 and 2011 Chemical Engineering Plant Cost 

Index (i.e., 585.7 / 499.6 = 1.172338). The updated cost estimates are shown in Table 6-10. 
42 

Table 6-10. Cost Estimates for Petroleum and Natural Gas Systems 

(Updated To 2011 Dollars) 

Segment

First Year Subsequent Year

Annualized 

Costa

($Million)

Annualized 

Costb

($Million)

National 

Cost 

($Million)

Cost

($/metric 

ton)

National 

Cost 

($Million)

Cost

($/metric 

ton)

NG Processing 9.53 0.3 2.46 0.08 2.85 3.01

NG 

Transmission 19.78 0.47 7.61 0.18 8.23 8.51 

Underground 

NG Storage 3.2 0.41 1.2 0.15 1.29 1.34 

LNG Storage 0.82 0.48 0.3 0.18 0.33 0.34

LNG 

Import/Export 0.16 0.52 0.04 0.11 0.05 0.05 

NG Distribution 3.88 0.18 1.58 0.07 1.72 1.78

Onshore 

Production 31.16 0.14 8.84 0.04 10.09 10.61 

Offshore 

Production 3.9 0.76 0.28 0.06 0.49 0.57 

Total 

(8 Segments) 72.43 0.21 22.29 0.07 25.04 26.19 

a

 The cost to report annualized over 20 years at 3 percent. 

b

 The cost to report annualized over 20 years at 7 percent.

Table 6-11 shows the number of facilities EPA identified expected reporters for each of 

the industry segments covered by subpart W that would have to report under the annual 

emission-based threshold of 25,000 metric tons CO2e (U.S. EPA, 2010). In order to determine 

average costs per facility, ERG divided the updated costs identified in Table 6-10 by the facility 

counts identified in Table 6-11. 

Table 6-11. Number of Expected Reporters by Industry Segment 

Segment Number of Facilities

NG Processing 289

NG Transmission 1,145

Underground NG Storage 133

LNG Storage 33

LNG Import/Export 4

NG Distribution 143

Onshore Production 981

Offshore Production 58

Total (8 Segments) 2,786
43 

The average costs per facility are shown in Table 6-12. ERG determined the incremental 

impacts due to the revised GWP factors by multiplying the average costs per facility by the 

number of additional facilities required to report under subpart W due to the revised GWP 

factors. 

Table 6-12. Average Costs per Facility for Petroleum and 

Natural Gas Systems (2011 Dollars) 

Segment

First Year Subsequent Year

Annualized 

Costa

($Million 

/Facility)

Annualized 

Costb

($Million 

/Facility)

National 

Cost 

($Million 

/Facility)

Cost

($/metric 

ton/Facility) 

National 

Cost 

($Million 

/Facility)

Cost

($/metric 

ton/Facility)

NG Processing 0.03298 0.00104 0.00851 0.00028 0.00986 0.01042

NG 

Transmission 0.01728 0.00041 0.00665 0.00016 0.00719 0.00743 

Underground

NG Storage 0.02406 0.00308 0.00902 0.00113 0.0097 0.01008 

LNG Storage 0.02485 0.01455 0.00909 0.00545 0.01 0.0103

LNG 

Import/Export 0.04 0.13 0.01 0.0275 0.0125 0.0125 

NG Distribution 0.02713 0.00126 0.01105 0.00049 0.01203 0.01245

Onshore 

Production 0.03176 0.00014 0.00901 0.00004 0.01029 0.01082 

Offshore 

Production 0.06724 0.0131 0.00483 0.00103 0.00845 0.00983 

Total

(8 Segments) 0.026 0.00008 0.008 0.00003 0.00899 0.0094 

a

 The cost to report annualized over 20 years at 3 percent. 

b

 The cost to report annualized over 20 years at 7 percent.

6.3.3 Impacts 

The incremental cost impacts due to the revised GWPs are shown in Table 6-13 by 

subpart W industry segment. ERG obtained these cost estimates by multiplying the average costs 

per facility from Table 6-12 by the number of new affected facilities identified in Table 6-8. 

Table 6-13. Incremental Cost Impacts Due to the GWP Revisions by Industry Segment 

Segment

First Year Subsequent Year

Annualized 

Costa

($Million)

Annualize

d Costb

($Million)

National 

Cost 

($Million)

Cost

($/metric 

ton)

National 

Cost 

($Million)

Cost

($/metric 

ton)

NG Processing 0.07 0.0021 0.02 0.0006 0.02 0.02

NG Transmission 0.12 0.0029 0.05 0.0011 0.05 0.05

Underground NG 

Storage 0.14 0.02 0.05 0.01 0.06 0.06 

LNG Storage 0.05 0.0291 0.02 0.0109 0.02 0.02
44 

Table 6-13. Incremental Cost Impacts Due to the GWP Revisions by Industry Segment 

Segment

First Year Subsequent Year

Annualized 

Costa

($Million)

Annualize

d Costb

($Million)

National 

Cost 

($Million)

Cost

($/metric 

ton)

National 

Cost 

($Million)

Cost

($/metric 

ton)

LNG Import/Export 0 0 0 0 0 0

NG Distribution 0.43 0.0202 0.18 0.0078 0.19 0.20

Onshore Production 1.65 0.0073 0.47 0.0021 0.54 0.56

Offshore Production 0.94 0.18 0.07 0.01 0.12 0.14

Total 

(8 Segments) 3.40 0.26 0.86 0.04 1.00 1.05 

a The cost to report annualized over 20 years at 3 percent.

b The cost to report annualized over 20 years at 7 percent.

The additional emissions that are attributed to new affected facilities (due to the revised 

GWPs) are shown in Table 6-14 by subpart W industry segment. For the six industry segments 

for which data were available, ERG based these emissions estimates on the facility/emissions 

lists discussed in Section 2. For LNG storage and NG distribution, the incremental expected 

emissions were estimated to be 450,000 metric tons CO2e by calculating the number of new 

facilities in these two industry segments (2+16 = 18) by 25,000 metric tons CO2e because ERG 

assumed these facilities would only just meet the 25,000 metric tons CO2e reporting threshold. 

Table 6-14. Additional Emissions That Are Attributed To New Affected 

Facilities by Industry Segment 

Segment

Emissions Attributed To New Affected Facilities

(metric tons CO2e)

NG Processing 52,067

NG Transmission 177,091

Underground NG Storage 158,286

LNG Storage 50,000

LNG Import/Export 0

NG Distribution 400,000

Onshore Production 1,372,641

Offshore Production 362,796

Total (8 Segments) 2,572,881

6.3.4 Small Entity Impacts 

In the subpart W Economic Impact Analysis (U.S. EPA. 2010), EPA originally assessed 

the impact of complying with subpart W requirements on small entities in the petroleum and 

natural gas systems source category by calculating a cost-to-sales ratio for eight enterprise size 

ranges (i.e., all categories, 1 to 20 employees, 20 to 99 employees, 100 to 499 employees, 500 to 
45 

749 employees, less than 500 employees, 750 to 999 employees, and 1,000 to 1,499 employees) 

using the ratio of average total annualized reporting costs to the average annual sales receipts for 

each establishment. The results of this analysis are represented in Table 9 of the preamble for the 

publication of the subpart W rule (75 FR 74482, November 30, 2010). 

Based on this analysis, EPA concluded that subpart W will not have a significant 

economic impact on a substantial number of small entities. EPA made this determination 

assuming that all entities in the industry would report (including those above and below the 

reporting threshold) and determined that no significant small business economic impacts were 

expected to occur. This analysis showed that the cost–to-sales ratio for all entity sizes except for 

the smallest sized enterprises was less than 1 percent. EPA concluded that although the cost-tosales ratio for the 1 to 20 employee range for crude petroleum and natural gas extraction was 

greater than 1 percent (i.e., 1.33%); in most cases, the small enterprises in this size range have 

very small operations (such as single family owning a few production wells) that are highly 

unlikely to cross the 25,000 metric tons CO2e reporting threshold. It is unlikely that any of the 99 

new affected facilities that ERG determined would become subject to subpart W (due to the 

revised GWP) would fall into the 1 to 20 employee range enterprise. 

Therefore, based on the cost-to-sales ratios in Table 9 of the November 30, 2009 

preamble, the proposed changes to the GWP will not have significant impact on a substantial 

number of small entities. The cost-to-sales ratios in Table 9 are conservatively high estimates of 

the impacts of the GWP changes because it assumes that all facilities in each enterprise range 

would become subject to the rule due to the revised GWP’s. Even in this unlikely situation, the 

impact in all size ranges except for the smallest size range is less than 1 percent. It is highly 

unlikely that any entities in this smallest size range would emit 25,000 metric tons CO2e per 

year, even with the revised GWPs that are proposed. 

6.3.5 References for Subpart W 

U.S. EPA, 2010. “Economic Impact Analysis for the Mandatory Reporting of Greenhouse Gas Emissions 

Under Subpart W Final Rule (GHG Reporting)”. Available at: 

http://www.epa.gov/climatechange/emissions/downloads10/Subpart-W_EIA.pdf

6.4 Subpart HH Impacts - New Reporters 

Subpart HH applies to Municipal Solid Waste (MSW) landfills that accepted waste on or 

after January 1, 1980 and generate CH4 in amounts equivalent to 25,000 metric tons of CO2e per 

year or more. 

The revised CH4 GWP will result in an additional 57 facilities subject to subpart HH and 

additional rule implement costs of $309,738 for the first year and $137,500 for the subsequent 
46 

years. There is no significant economic impact on small entities for the facilities subject to 

subpart HH. 

6.4.1 Methodology for Identifying Affected Facilities 

According to the TSD for the Landfill Sector (U.S. EPA, 2009a), 2,551 MSW landfills 

were estimated to be subject to subpart HH. This includes 771 active large MSW landfills, 230 

active small landfills, and 1,550 closed landfills. The methods and database that were used to 

estimate the affected facilities for subpart HH in the TSD for the landfill sector (U.S. EPA, 

2009a) can be divided into the following three categories: 

For Active Large MSW Landfills (771):

• The number of active large MSW landfills subject to subpart HH was identified 

based on the actual CH4 generation information for each active landfill in the 

Landfill Methane Outreach Program (LMOP) database in 2006. The CH4

generation rate in 2006 was calculated using the actual waste-in-place information 

and a landfill-specific model. The landfill-specific model used the first order 

decay model with a methane generation potential (L0) of 100 m3/mt and three 

different methane generation rate constant (k) values based on rainfall levels (U.S. 

EPA, 2005a). 

For Active Small Landfills (230):

• It was estimated that there were 460 small active landfills in 2009 that were not 

covered by the 2006 LMOP database and 50% of them have CH4 generation 

greater than 25,000 metric tons/yr of CO2e. 50% was based on engineering 

judgments. 

For Closed Landfills (1,550):

• It was estimated that there were 6,200 closed landfills in 2009 and 25% of them 

have CH4 generation greater than 25,000 metric tons/yr of CO2e. 25% was based 

on engineering judgments. 

Based on the e-GGRT data for the reporting year of 2010, there are 1,202 MSW landfills 

reported under subpart HH, including 936 active landfills and 266 closed landfills. The number 

of the closed MSW landfills reported under subpart HH (266) is significantly lower than the 

original estimate of 1,550 in the TSD for the landfill sector (U.S. EPA, 2009a). However, the 

number of active landfills reported (936) is close to the original estimate of 1,001 (771 active 

large + 230 active small) landfills. Therefore, except for closed landfills, the original methods 

used in the TSD for the landfill sector (U.S. EPA, 2009a) to estimate the number of affected 

active landfills is reasonable, and the same approach is used in this analysis to estimate the 

number of additional MSW landfills subject to subpart HH due to the revised CH4 GWP. 
47 

Because the reporting threshold for subpart HH is based on CH4 generation (not 

emissions), the facilities that currently have CH4 generation between 21,000 and 25,000 metric 

tons/yr of CO2e are the additional facilities affected by the GWP change for CH4 from 21 to 25. 

Because the CH4 generation from landfills changes with time and the amount of waste in place, 

the time factor should be considered in this analysis. The additional active large MSW landfills, 

active small MSW landfills, and closed landfills subject to subpart HH are estimated as follows: 

Additional Active Large MSW Landfills: 

Although the LMOP database (U.S. EPA, 2012) includes most of the input data (such as 

landfill open and closure years, amount of waste accepted, etc.) for the landfill-specific model 

used in the original analysis, this model was not re-run for this analysis. Therefore, we did not 

calculate the actual CH4 generation in 2011 for each MSW landfill covered by the LMOP 

database. The best CH4 generation information available is the 2006 CH4 generation information 

in the supporting data for the TSD for the landfill sector (U.S. EPA, 2009a). According to this 

supporting data, there were 1,142 active large MSW landfills and 21 of them have CH4

generation between 21,000 and 25,000 metric tons/yr of CO2e based on 2006 LMOP database. 

This is equivalent to 1.8% of the total active landfills identified in LMOP database. According to 

the 2012 LMOP data (U.S. EPA, 2012), there are 1,123 active MSW landfills in 2012 (excluding 

the closed landfills). Assuming that the profile of landfills not in the LMOP database is similar to 

those landfills in the LMOP data base, the number of active large landfills with CH4 generation 

between 21,000 and 25,000 metric tons/yr of CO2e is estimated to be 1,123 x 1.8% = 20 

facilities. 

Additional Active Small MSW Landfills:

Small landfills are not included in the LMOP database, therefore a different approach was 

used to estimate the additional active small landfills affected by the change in GWP. In the TSD 

for the landfill sector (U.S. EPA, 2009a), it was estimated that there were 460 small active 

landfills in 2009 and 50% of them have CH4 generation greater than 25,000 metric tons/yr of 

CO2e and were included in the original estimates of number of reporting facilities. 30% of small 

landfills are estimated to have CH4 generation between 10,000 and 25,000 metric tons/yr of 

CO2e. Assuming that the proportion of all small active landfills is the same as those in the LMOP 

database, and the distribution across the available range of estimated emissions (10,000 to 

25,000) is even, the number of small active landfills with CH4 generation between 21,000 and 

25,000 metric tons/yr of CO2e is estimated to be 460 x 30% x (25,000 – 21,000) / (25,000 – 

10,000) = 37 facilities. 

Additional Closed MSW Landfills:

For closed landfills, CH4 generation and emissions decrease over time. It is estimated that 

the CH4 generation decreases 18% in 5 years based on the CH4 generation calculated using 
48 

EPA’s Landfill Gas Emissions Model (LandGEM) (U.S. EPA, 2005b). The closed MSW 

landfills identified in the 2006 LMOP database with CH4 generation equal to 25,000 metric tons 

of CO2e now should have CH4 generation around 25,000 x (1-18%) = 20,500 metric tons/yr of 

CO2e in 2011. With the updated GWP for CH4, the CH4 generation for these landfills is 20,500 / 

21 x 25 = 24,405 metric tons/yr of CO2e, which is still less than the reporting threshold of 25,000 

metric tons/yr. Therefore, the closed landfills that were identified in 2006 and with CH4

generations between 21,000 and 25,000 metric tons/yr of CO2e still would not exceed the 25,000 

metric tons/year generation threshold of subpart HH after 2011 due to the revised CH4 GWP. 

According to the 2012 LMOP data, 92 MSW landfills were closed in the time period of 2007 

through 2011 (U.S. EPA, 2012). Based on the waste in place information, none of these newly 

closed landfills have CH4 generation between 21,000 tons and 25,000 tons of CO2e based on a 

GWP for CH4 of 21. Therefore, no additional closed landfills would exceed the 25,000 metric 

tons/year generation threshold using a GWP of 25. 

Based on the discussions above, the additional MSW landfills subject to subpart HH as a 

result of the revised CH4 GWP are summarized in Table 6-15: 

Table 6-15. Number of Additional MSW Landfills Subject to Subpart HH 

Type of MSW Landfills 

Number of Additional 

Affected MSW Landfills 

Large Active Landfills 20

Small Active Landfills 37

Closed Landfills 0

Total 57

6.4.2 Methodology for Estimating Impacts 

To determine the cost impacts resulting from the revised GWP for CH4, ERG used the 

same methodology that was used in the Regulatory Impact Analysis for the GHG Reporting Rule 

(U.S. EPA, 2009b). The economic impact analysis is based on the number of facilities affected 

and the rule implementation cost for each facility. Cost information for each affected industrial 

waste landfill is based on the labor cost and capital cost information listed in the Regulatory 

Impact Analysis for Subpart HH (U.S. EPA, 2009b). Labor costs were adjusted from 2006 to 

2011 using the Bureau of Labor statistics average labor factors. Capital costs were adjusted from 

2006 to 2011 using the CEPCI. The Small Entity Impact Analysis is measured using a “sales 

tests” (represented as cost-to-receipt ratios) for the waste management and remediation services 

facilities that have a NAICS code of 562. 

6.4.3 Impacts 

The cost impact of the revised CH4 GWP was evaluated based on the number of 

additional affected landfills and the rule implementation cost for each facility. Cost information 
49 

for each affected industrial waste landfill is based on the labor cost and capital cost information 

listed in the Regulatory Impact Analysis for Subpart HH (U.S. EPA, 2009b). Labor costs were 

adjusted from 2006 to 2011 using the Bureau of Labor statistics average labor factors. Capital 

costs were adjusted from 2006 to 2011 using the Chemical Engineering Plant Cost Index 

(CEPCI). The rule implementation cost information for subpart HH is summarized in Table 6-16. 

Table 6-16. Rule Implementation Costs for Subpart HH for Each Facility 

Labor Costs Capital and O&M Costs Total

First Year 

Subsequent 

Year First Year 

Subsequent 

Year First Year 

Subsequent 

Year 

in 2006$ $4,715 $1,999 $161 $161 $4,876 $2,160

in 2011$ $5,245 $2,224 $189 $189 $5,434 $2,413

 

From Table 6-15, there would be 57 additional facilities subject to subpart HH due to the 

revised CH4 GWP. The total cost for the 57 additional facilities is $309,738 for the first year and 

$137,500 for the subsequent years. The impacts due to the revised CH4 GWP for subpart HH are 

summarized in Table 6-17. 

Table 6-17. Summary of Subpart HH Impacts due to the Revised GWP 

Total Number 

of Facilities in 

Source 

Categorya 

Number of 

Reporters 

Prior to 

Revised GWPb 

Number of 

New Reporters 

Due to Revised 

GWP 

Total Emissions 

Prior to Revised 

GWP 

(metric tons of 

CO2e per year)b 

Incremental 

Emissions For 

New Reporters 

(metric tons of 

CO2e per year )c 

Incremental 

Cost Impact 

For New 

Reporters 

(2011$ per 

year) 

7,802 1,202 57 107,000,000 1,560,000 137,500

a

 From the TSD for the landfill sector (U.S. EPA, 2009a). 

b

 Based on the e-GGRT data for 2010 reporting year. The amount of CO2 equivalent was calculated using 21 as 

the GWP for CH4. 

c

 Estimated by multiplying the number of new affected facilities (57) by the average CH4 generation for each new 

affected facility. The average CH4 generation for each new affected facility is assumed to be (25,000 + 21,000)/2 

x 25/21 = 27,381 metric tons/yr of CO2e. The amount of CO2 equivalent has been adjusted using the new GWP 

for CH4 of 25. 

6.4.4 Small Entity Impacts 

The small entity economic impact for landfills was measured using the “sales tests” 

approach (represented as cost-to-receipt ratios) for NACIS codes associated with the affected 

subparts in the Regulatory Impact Analysis for the GHG Reporting Rule (U.S. EPA, 2009b). The 

same approach is used in this analysis for the additional facilities subject to subpart HH due to 

the revised CH4 GWP. If the ratio of rule implementation cost to sales is less than 1%, the impact 

is not considered to be significant (U.S. EPA, 2010b). 
50 

Based on the 2007 economic census database published by U.S. Bureau of the Census, 

the receipts (sales), number of establishments, and the average receipts for different size of 

Waste Management and Remediation Services facilities (with a NAICS code of 562) information 

is summarized in Table 6-18. The average receipts information is adjusted from 2007 dollars to 

2011 dollars based on the consumer price index published by Bureau of Labor Statistics. 

Table 6-18. Receipts, Number of Establishments, and Average Receipts for 

Waste Management and Remediation Services (NAICS code of 562)

Owned by Enterprises with:

1-19 

Employees 

20-99 

Employees 

100-249 

Employees 

250-499 

Employee

s 

500-999 

Employee

s 

1,000 and 

above 

Employees 

Receipts

(million, 2007$) $10,492 $14,318 $6,856 $3,365 $3,732 $35,420 

Number of 

Establishments 12,579 2,678 646 248 263 2,910 

Average Receipts for 

Each Establishment 

(million, 2007$) 

$0.83 $5.35 $10.61 $13.57 $14.19 $12.17 

Average Receipts for 

Each Establishment 

(million, 2011$) 

$0.90 $5.80 $11.51 $14.72 $15.40 $13.20 

 

According to the cost information listed in Table 6-16, the rule implementation costs for 

subpart HH is $5,434 for the first year and $2,413 for the subsequent years (in 2011 dollars). The 

sales tests (cost-to-receipt ratios) results are shown in Table 6-19 for the first year and the 

subsequent years. 

Table 6-19. Sales Tests for Subpart HH Facilities

Owned by Enterprises with:

1-19 

Employees 

20-99 

Employees 

100-249 

Employees 

250-499 

Employees 

500-999 

Employees 

1,000 and 

above 

Employees 

Sales Test –

First Year 0.60% 0.09% 0.05% 0.04% 0.04% 0.04% 

Sales Test -

Subsequent Years 0.27% 0.04% 0.02% 0.02% 0.02% 0.02% 

 

The results in Table 6-19 show that the costs for GHG reporting for the facilities subject 

to subpart HH is well below 1% of the sales for all size of Waste Management and Remediation 

Services facilities with a NAICS code of 562. Therefore, we have determined that there is not a 

significant impact on a substantial number of small businesses subject to reporting under subpart 

HH. 
51 

6.4.5 References for Subpart HH 

U.S. EPA, 2005a. Development of Landfill-specific Methane Inventory Model; Memorandum from Jeff 

Coburn and Marvin Branscome, RTI, to Elizabeth Scheele, EPA. May 6, 2005. 

U.S. EPA, 2005b. Landfill Gas Emissions Model (LandGEM), , Version 3.02. [Computer software]. 

Retrieved July 12, 2012. Available from http://www.epa.gov/ttn/catc/products.html#software

U.S. EPA, 2009a. Technical Support Document for the Landfill Sector: Proposed Rule for Mandatory 

Reporting Of Greenhouse Gases. See Docket ID: EPA-HQ-OAR-2008-0508-0034. February 4, 2009. 

U.S. EPA, 2009b. Regulatory Impact Analysis for the Mandatory Reporting of Greenhouse Gas 

Emissions Final Rule (GHG Reporting). See Docket ID: EPA-HQ-OAR-2008-0508-2229. September 

2009. 

U.S. EPA, 2012. Landfill Methane Outreach Program (LMOP) – Landfill and Project Database. January 

4, 2012. Available from: http://www.epa.gov/lmop/documents/xls/lmopdata.xls

6.5 Subpart II Impacts - New Reporters 

The industrial wastewater treatment source category consists of anaerobic processes used 

to treat industrial wastewater and industrial wastewater treatment sludge at facilities that perform 

the following operations: 

1. Petroleum refining 

2. Pulp and paper manufacturing 

3. Ethanol production 

4. Food processing 

Facilities that meet reporting thresholds must report the amount of CH4 generated, 

emitted, and/or recovered from anaerobic treatment of industrial wastewaters and industrial 

wastewater treatment sludges. Subpart II applies only to anaerobic treatment processes. 

For the industries covered by subpart II, the reporting thresholds are specified as follows: 

• Petroleum refineries are required to report if the facility is subject to reporting 

under subpart Y of 40 CFR part 98. There is no threshold for reporting. 

• Pulp and paper manufacturing facilities are required to report if the facility emits 

25,000 metric tons CO2e or more per year. All pulp and paper facilities are 

expected to meet this threshold. 

• Ethanol production facilities are required to report if the facility emits 25,000 

metric tons CO2e or more per year. 

• Food processing facilities are required to report if the facility emits 25,000 metric 

tons CO2e or more per year. 
52 

6.5.1 Methodology for Identifying Affected Facilities and Estimating Impacts 

This section discusses how EPA estimated the number of facilities required to report 

during the development of the Greenhouse Gas Reporting Rule. It then discusses how these 

estimates would change if the methane GWP increased from 21 to 25. The discussion is 

presented separately for each of the four industries included in subpart II. 

Petroleum refineries. During the development of the GHG reporting rule, EPA noted that 

40 CFR 98.2(a)(1) requires all 150 petroleum refineries to report their GHG emissions. As part 

of the estimate of the potential costs of subpart II, EPA further estimated that 25% of refineries 

have anaerobic wastewater treatment and would be required to report subpart II emissions (ERG, 

2010). For this reason, any change to the methane GWP will have no impact on the estimated 

number of petroleum refineries required to report subpart II emissions. 

Pulp and paper manufacturing. During the development of the GHG reporting rule, as 

part of the estimate of the potential costs of subpart II, EPA estimated that 25% of the 565 U.S. 

pulp and paper mills have anaerobic treatment. EPA further assumed that all 141 mills with 

anaerobic secondary treatment would meet the 25,000 metric tons CO2e threshold of emissions 

from their subpart AA operations and would be required to report subpart II emissions (ERG, 

2010). Because mills are assumed to meet the reporting threshold based on their subpart AA CO2

emissions, any change to the methane GWP will have no impact on the estimated number of pulp 

and paper mills required to report subpart II emissions. 

Ethanol production facilities. Ethanol production facilities are required to report their 

GHG emissions if they exceed 25,000 metric tons CO2e per year in combined emissions from all 

specified sources, such as stationary fuel combustion units, industrial landfills, and industrial 

wastewater treatment. However, for the purpose of its March 2010 cost estimate, because EPA 

had no basis for estimating emissions from other sources at the ethanol production facility, EPA 

assumed facilities that exceed 25,000 metric tons CO2e per year in emissions from industrial 

wastewater treatment would incur monitoring costs (ERG, 2010). 

Facilities use one of two processes to produce ethanol: dry milling or wet milling. During 

the development of the GHG reporting rule, EPA obtained information from the Renewable 

Fuels Association that included facility identification, production, and whether the facility used 

dry milling or wet milling. This information did not identify facilities that use anaerobic 

wastewater treatment. Assuming each facility used anaerobic treatment and using standard waste 

generation rates based on ethanol production, chemical oxygen demand (COD) concentrations, 

and methane generation rates, EPA calculated potential methane emissions per plant. 

Dry milling. The maximum estimated emissions from a facility were slightly over 1,800 

metric tons CO2 e per year. Even if the methane GWP were increased by 20%, no dry milling 
53 

ethanol plant would meet the 25,000 metric tons CO2 e per year reporting threshold (ERG, 

2008a). 

Wet milling. Wet milling ethanol production facilities generate more wastewater per unit 

of production and have somewhat greater production per facility than dry milling facilities. Four 

wet milling facilities produce 1.5 to 2.5 times as much ethanol as the largest dry milling facility. 

Because EPA had very little information on how individual ethanol production facilities treat 

wastewater, in order to estimate the potential costs of subpart II, EPA estimated that 33% of the 

wet milling facilities used anaerobic wastewater treatment. Using standard waste generation rates 

based on ethanol production, COD concentrations, and methane generation rates, EPA calculated 

that four (4) wet milling facilities emitted in excess of the 25,000 metric tons CO2 e per year 

reporting threshold. EPA estimated that ethanol production facilities would incur $20,600 in total 

annualized costs to meet the GHG reporting rule monitoring requirements (ERG, 2010), or 

$5,150 per facility. 

In a more recent analysis (ERG, 2011), EPA estimated that two wet milling ethanol 

production facilities exceeded the reporting threshold. Changing the GWP to 25 would increase 

this estimate by two, to a total of four facilities. Using these two sources of information, we are 

estimating the impact of a change to the GWP for methane from 21 to 25 will result in two 

additional facilities that will be required to report, at a cost of $10,300. 

Food processing facilities. Food processing facilities are required to report their 

wastewater emissions if Facility GHG emissions exceed 25,000 metric tons CO2e per year in 

combined emissions from all specified sources, such as stationary fuel combustion units, 

industrial landfills, and industrial wastewater treatment. However, for the original development 

of the rule, because EPA had no basis for estimating emissions from other sources at the food 

processing facility, EPA assumed facilities that exceed 25,000 metric tons CO2e per year in 

emissions from anaerobic industrial wastewater treatment alone would be subject to the rule 

(ERG, 2010). Food processing facilities that are most likely to have anaerobic wastewater 

treatment are: 1) fruits and vegetable processing, 2) poultry processing, and 3) red meat 

processing. 

Fruits and vegetable processing. During the development of the GHG reporting rule, as 

part of the estimate of the potential costs of subpart II, EPA estimated that no fruit and vegetable 

processing facilities would incur reporting costs because all would be under the reporting 

threshold (ERG, 2010). As discussed in the July 2008 threshold analysis (ERG, 2008b), EPA 

could not identify plant-specific information to calculate greenhouse gas emissions for fruit and 

vegetable processors. The national level of emissions from the 2006 U.S. Inventory of U.S. 

Greenhouse Gas Emissions and Sinks is 123,000 metric tons CO2e. There are approximately 100 
54 

processors with onsite anaerobic treatment (U.S. EPA, 2008); therefore, the average emission 

was estimated to be about 1,200 metric tons CO2e per plant (ERG, 2008b). If the methane GWP 

increased from 21 to 25, the average emission would increase to about 1,460 metric tons CO2e 

per plant, still significantly below the 25,000 metric tons CO2e reporting threshold. Thus, an 

increase in the methane GWP would have no effect on the number of fruit and vegetable 

processing facilities required to report subpart II emissions. 

Poultry processing. During the development of the GHG reporting rule, as part of the 

estimate of the potential costs of subpart II, EPA determined it did not have sufficient 

information to estimate the number of poultry processing facilities that exceed the 25,000 metric 

ton CO2e reporting threshold. EPA estimated 50 poultry processors have methane emissions 

above 10,000 metric tons CO2e (ERG, 2010). This is an overestimate of those that have 

emissions above 25,000 metric tons CO2e, but EPA does not have sufficient facility-specific 

information to refine the estimate, nor to estimate the impact of changing the methane GWP. 

As described in the July 17, 2008 memorandum (ERG, 2008b), EPA was unable to obtain 

plant-specific information for poultry processors; neither production levels nor whether facilities 

use anaerobic wastewater treatment were found. Therefore, using national default values for 

wastewater generation, COD in wastewater concentrations, and assuming all wastewater is 

treated anaerobically on site, EPA back-calculated the production rate that would trigger each of 

four emission thresholds. EPA estimated that production of 93 million lb/yr would result in 

emissions exceeding 10,000 metric tons CO2e. Production of 232 million lb/yr would result in 

emissions exceeding 25,000 metric tons CO2e. EPA had publicly available data obtained to 

support EPA Office of Water’s effluent guidelines for the meat and poultry products industry. 

These data classified “nonsmall” poultry processors as facilities producing more than 100 million 

pounds per year and reported 206 “nonsmall” poultry producers. The data also indicated that 

25% of the industry uses onsite anaerobic treatment. Consequently, EPA estimated that 50 

poultry producers (206 x 25%) would exceed the 10,000 metric tons CO2e threshold (ERG, 

2008b). EPA used this estimate as a conservatively high estimate of the number of poultry 

producers that would be subject to subpart II. Because this estimate includes producers with 

emissions as low as 10,000 metric tons CO2e, no additional facilities are estimated to report as a

result of the change in GWP of methane from 21 to 25. 

Red meat processing. During the development of the GHG reporting rule, as part of the 

estimate of the potential costs of subpart II, EPA estimated 13 red meat processors have methane 

emissions above 25,000 metric tons CO2e. As described in July 17, 2008 memorandum (ERG, 

2008b), EPA was unable to obtain plant-specific information for red meat processors, neither 

production levels nor whether facilities use anaerobic wastewater treatment. EPA used limited 
55 

published information and engineering judgment to estimate the number of red meat processing 

facilities required to report, as follows: 

• Data available on Tyson Foods5 indicates that covers have been installed on 

anaerobic lagoons at five meat processing plants (4 beef, 1 pork). Prior to the 

installation of the covers, all five sites were estimated to emit more than 25,000 

metric tons CO2e and one of these sites emitted more than 100,000 metric tons 

CO2e. Following installation of the covers, only one of these sites emits more than 

25,000 metric tons CO2e and three more emit more than 10,000 metric tons CO2e. 

• Data from Cargill Meat Solutions, Inc. (Cargill)6 indicate they have installed 

covers on all of their anaerobic lagoons at U.S. meat packing plants (8 beef, 2 

pork). It is estimated that these plants would have emitted more than 25,000 

metric tons CO2e each. It is unknown what their actual emissions are now. 

From these data, we estimate that no more than 13 meat processing facilities actually 

emit more than 25,000 metric tons CO2e (ERG, 2008b). 

Because so few red meat processing facilities are required to report using the current 

GWP, we conclude that no new facilities will be required to report if the GWP for methane 

increases from 21 to 25Small Entity Impacts 

The only additional subpart II reporters expected as a result of a change to the GWP of 

methane from 21 to 25 are two ethanol production facilities. Both of these facilities are owned by 

a large corporation that has been determined not to be a small entity. Therefore, we have 

determined that there are no small entity impacts to any subpart II reporters associated with this 

action. 

6.5.2 Summary of Impacts 

The cost impact and the number of additional facilities required to report subpart II 

emissions as a result of an increase in methane GWP from 21 to 25 is summarized in Table 6-20. 

 

5 Verification of Blue Source Emissions Reductions Credits from Methane Capture and Flare Projects at Tyson 

Foods Facilities, prepared by RAVEN RIDGE RESOURCES, INCORPORATED, February 23, 2004. 

6 Cargill’s Corporate Citizenship Review.
56 

Table 6-20. Summary of Subpart II Impacts Due to the GWP Revisions 

Industry 

Segment 

Total 

Number 

of 

Facilities 

in Source 

Category 

Number of 

Reporters 

Prior to 

GWP 

Revisions 

Number of 

New 

Reporters 

Due to 

GWP 

Revisions 

Total Emissions 

Prior to GWP 

Revisions 

(metric tons of 

CO2e per year)a 

Incremental 

Emissions 

For New 

Reporters 

(metric tons 

of CO2e per 

year ) 

Incremental 

Cost Impact 

For New 

Reporters 

(2011$ per 

year) 

Petroleum 38 38 0 355,000 0 0

Pulp & Paper 141 141 0 3,865,000 0 0

Ethanol 102 2 2 50,000 59,500 10,300

Fruit & Veg 100 0 0 0 0 0

Poultry 50 50 0 1,250,000 0 0

Meat 13 13 0 325,000 0 0

Total 444 244 2 5,845,000 59,500 10,300

a Estimate of emissions is from original threshold analysis (ERG, 2008a). 

An increase in the GWP for methane may possibly increase the number of reporting 

facilities that perform ethanol production (wet milling) operations by two facilities. In support of 

the final rule, EPA estimated that the total subpart II reporting costs would be $1.4 million. EPA 

estimated that reporting costs for ethanol production facilities would be $5,150 per facility 

(ERG, 2010). Consequently, adding two ethanol production facilities would increase the 

reporting costs by $10,300. There are no small entity impacts associated with this change. 

6.5.3 References for Subpart II 

Eastern Research Group, Inc. (ERG), 2008a. Supporting Documentation: Industrial Wastewater 

Thresholds_071708.xls. Prepared for Melissa Weitz, EPA. July 17, 2008. 

ERG, 2008b. Memorandum: Revised Threshold Analysis for the Estimation of Greenhouse Gas 

Emissions from Individual Industrial Facilities. Prepared for Melissa Weitz, EPA. See Docket ID: EPAHQ-OAR-2008-0508-0132. See Docket ID: EPA-HQ-OAR-2008-0508-0132. July 17, 2008. 

ERG, 2010. Memorandum: Greenhouse Gas Reporting Rule, Industrial Wastewater Treatment Source 

Category, Costs for Final Rule Monitoring Requirements – Revised. Prepared for Rachel Schmeltz, EPA. 

See Docket ID: EPA-HQ-OAR-2008-0508-2297. March 5, 2010. 

ERG, 2011. Supporting Documentation: Industrial_Wastewater_Thresholds_Ethanol Mills_052611.xlsx. 

Prepared for Melissa Weitz, EPA. May 26, 2011. 

U.S. EPA, 2008. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2006. April 2008. 

USEPA #430-R-08-005. 

Additional Reference, Not Specifically Cited 

U.S. EPA, 2009. Technical Support Document for Wastewater Treatment: Proposed Rule for Mandatory 

Reporting of Greenhouse Gases. See Docket ID: EPA-HQ-OAR-2008-0508-0035. February 4, 2009. 
57 

6.6 Subpart OO Impacts - New Reporters 

The suppliers of industrial GHGs source category consists of all facilities that produce a 

fluorinated GHG or nitrous oxide, and any importer or exporter of fluorinated GHGs or nitrous 

oxide with annual bulk imports or exports that are equivalent to 25,000 metric tons CO2e or 

more. F-GHGs that do not appear on Table A-1 are not included in the threshold analysis. 

However, if a supplier of industrial GHGs is above the threshold of 25,000 metric tons CO2e 

based on the Table A-1 chemicals, they must report production, imports and exports of all FGHG. 

The revised GWPs for F-GHGs currently included Table A-1 to subpart A of part 98 will 

result in three additional facilities subject to subpart OO. No additional reporters are expected as 

a result of the addition of chemicals to Table A-1. The additional rule implementation costs are 

$10,500 for each year. There is no significant economic impact on small entities for the facilities 

subject to subpart OO.

6.6.1 Methodology for Identifying Affected Facilities 

All production facilities are required to report regardless of threshold, therefore, there are 

not additional facilities as a result of the revised GWPs. A list of importers and exporters was 

developed for the 2009 subpart OO threshold analysis (U.S. EPA, 2009b) and for the addition of 

bulk exporters to the threshold analysis (Ottinger, 2009). As described in the referenced reports, 

this list was developed using information obtained primarily from the Port Import Export 

Reporting Service (PIERS), a database that collects, organizes and stores bills of lading from 

port cargo. These data were supplemented with data obtained from industry representatives 

through the Alliance for Responsible Atmospheric Policy. 

Table 6-21 shows the number of facilities that EPA identified for each of the industry 

segments covered by subpart OO that would report. 

Table 6-21. Number of Facilities Reporting by Industry Segment 

Segment Number of Facilities

Number of Facilities Expected to 

Report 

HFC, PFC, SF6 and NF3 Producers 12 12

N2O Producers 5 5

N2O and Fluorinated GHG Importers 116 61

N2O and Fluorinated Exporters 192-244a89a

a The number of facilities was estimated as an upper bound and lower bound estimate. The data contained many 

similar, but not identically named companies. 

This list of importers and exporters was used to determine the additional facilities that 

would be required to report under subpart OO if the proposed revised GWPs from the IPCC 
58 

Fourth Assessment Report were used. The import and export quantities for each importer and 

exporter were multiplied by the proposed revised GWPs to determine which entities would 

exceed the threshold of 25,000 metric tons CO2e, and be required to report using the revised 

GWP. It is estimated that approximately three additional importer or exporter entities would be 

required to report as a result of the revisions to the GWPs for compounds currently in Table A-1. 

For the compounds added to Table A-1, these gases are primarily used in the electronics 

industry. EPA reviewed the importers and exporters that are primarily serving the electronics 

industry to identify those reporters that may be under the reporting threshold. Our analysis of the 

data indicates that of the importers and exporters serving the electronics industry, for those 

entities that are now expected to be below the reporting threshold, the inclusion of additional 

chemicals in Table A-1 would not cause an increase in the number of reporters. Of the 26 

additional fluorinated GHGs which EPA is proposing to add to Table A-1, 24 of those gases 

have GWPs less than 2,000. Therefore, we do not expect a significant increase in calculated 

CO2e emissions or any new reporters as a result of the inclusion of the additional fluorinated 

GHGs in Table A-1 to subpart A. 

6.6.2 Methodology for Estimating Impacts 

To determine the cost impacts resulting from the revised GWPs, ERG used the same 

methodology that was used in the Regulatory Impact Analysis for the Mandatory Reporting of 

Greenhouse Gas Emissions Final Rule (U.S. EPA, 2009a). In that analysis, EPA estimated the 

total cost to the private sector (in 2006 dollars) for the Industrial GHG Suppliers category 

(subpart OO) to be $0.521 million in the first year and $0.521 million in subsequent years.). 

These estimates consist of costs for recordkeeping and reporting. There is no capital cost 

required for compliance with this subpart. 

EPA estimated the total reporting costs by assigning model facility costs to individual 

facilities by type of facility (N2O producers, fluorinated gas producers, and fluorinated gas 

importers and exporters). Costs in 2006 dollars include $1,700 per facility for recordkeeping, 

$500 per facility for reporting, and a first year and subsequent year process cost that varied by 

type of facility ($820 for producers of F-gases, $473 for N2O producers, and $946 for importers). 

Costs were estimated for all production facilities and for importers and exporters that were 

expected to exceed the annual emission based threshold of 25,000 metric tons CO2e. 

Approximately 40% of all importers and exporters were expected to report. Additional details of 

the data, methods, and assumptions underlying these costs are documented in the final report 

(U.S. EPA, 2009a). For this analysis, the labor costs were adjusted from 2006 to 2011 using the 

Bureau of Labor statistics average labor factors. The total average cost per facility for new 

reporters (importers and exporters) in 2011 dollars is estimated to be $3,500. 
59 

6.6.3 Cost Impacts 

The incremental cost impacts for subpart OO due to the revised GWP are shown in 

Table 6-22. This cost estimate was obtained by multiplying the average costs per facility 

($3,500) by the number of new affected facilities identified (three). 

Table 6-22. Rule Implementation Costs for Subpart OO 

Segment

First Year and Subsequent Year

National Cost ($)

HFC, PFC, SF6 and NF3 Producers 0

N2O Producers 0

N2O and Fluorinated GHG Importers and Exporters $10,500

Total $10,500

Table 6-23 summarizes the subpart OO impacts due to the revised GWPs; the summary 

table provides estimated changes to the number of affected facilities and expected emissions 

reported. Each new reporter was estimated to report at the threshold of 25,000 metric tons CO2e 

because ERG assumed these facilities would only just meet the 25,000 metric tons CO2e 

reporting threshold. 

Table 6-23. Summary of Subpart OO Impacts Due to the GWP Revisions 

Total Number 

of Facilities in 

Source 

Category 

Number of 

Reporters Prior 

to GWP 

Revisions 

Number of New 

Reporters Due 

to GWP 

Revisions 

Total Emissions 

Prior to GWP 

Revisions 

(metric tons of 

CO2e per year)a 

Incremental 

Emissions For 

New Reporters 

(metric tons of 

CO2e per year ) 

Incremental 

Cost Impact 

For New 

Reporters 

(2011$ per 

year) 

351 167 3 254,554,000 75,000 10,500

a

 EPA provided 2010 summary information. 

6.6.4 Small Entity Impacts 

EPA originally assessed the impact of complying with subpart OO requirements on 

entities subject to the rule by calculating a cost to sales ratio for eight enterprise size ranges (i.e., 

all categories, 1 to 20 employees, 20 to 99 employees, 100 to 499 employees, 500 to 749 

employees, less than 500 employees, 750 to 999 employees, and 1,000 to 1,499 employees) 

using the ratio of average total annualized mandatory reporting costs to the average 

establishments receipts. For this analysis, because the affected establishments are import and 

export entities with smaller volumes of imported or exported gases, an analysis was performed 

for the smallest size ranges of entities in the NAICS code 42469 (Other chemical and allied 

products, merchant wholesalers). Based on the 2007 economic census database published by 

U.S. Bureau of the Census, the receipts, number of establishments and the average receipts for 

different size entities is summarized in Table 6-24. 
60 

Table 6-24. Sales Test for Subpart OO 

0- 4 Employees 5-9 Employees 10-19 Employees

Average Receipts for each 

Establishment $ 2,557,209 4,737,209 17,593,574 

Impact per Entity $ 3,500 3,500 3,500

Sales Test 0.137% 0.074% 0.020%

The results in Table 6-24 show that the costs for GHG reporting for even the smallest 

facilities subject to subpart OO are well below 1% of the sales for all entities in the NAICS code 

42469. Therefore, we have concluded that there is not a significant economic impact to a 

substantial number of small entities for the facilities subject to subpart OO as a result of the 

revised GWPs. 

6.6.5 References for Subpart OO 

Ottinger, D., 2009. Addition of Bulk Exporters of Fluorinated GHGs, Nitrous Oxide and Carbon Dioxide 

to Threshold Analysis of Industrial Gas Suppliers. Washington, DC: US EPA. 

U.S. EPA, 2009a. Regulatory Impact Analysis for the Mandatory Reporting of Greenhouse Gas 

Emissions Final Rule. See Docket ID:EPA-HQ-OAR-2008-0508-2229. September 2009. 

U.S. EPA, 2009b. Additional Methodological Information Supporting Threshold Analysis for Specific 

Source Categories. See Docket ID: EPA-HQ-OAR-2008-0508-0046. March 2009. 

6.7 Subpart TT Impacts - New Reporters 

Subpart TT applies to industrial waste landfills that accept wastes that have volatile solids 

concentration above 0.5 percent, that have total landfill design capacity greater than or equal to 

300,000 metric tons, and that are located within a facility with GHG emissions equal to or 

greater than 25,000 metric tons of CO2e per year. Therefore, the GHG emissions from an 

industrial waste landfill alone cannot determine the applicability of subpart TT and the GHG 

emissions from the entire facility must be considered. 

In general, industrial waste landfills that meet the GHG reporting criteria are co-located 

with refineries, petrochemical production facilities, pulp and paper mills, and food processing 

facilities. All Refineries and petrochemical production facilities are required to report (no 

threshold) and all pulp and paper mills are expected to be above the reporting threshold, 

therefore all are expected to report under subpart TT if a landfill is present. Therefore, this 

impact analysis focuses on the additional industrial waste landfills located in food processing 

facilities that are subject to subpart TT due to the revised GWP for CH4 from 21 to 25 and the 

cost associated with these additional landfills subject to subpart TT. 

The revised CH4 GWP will result in approximately 19 additional facilities subject to 

subpart TT and additional rule implementation costs of $118,560 for the first year and $87,300 
61 

for the subsequent years. There is no significant economic impact on small entities for the 

facilities subject to subpart TT. 

6.7.1 Methodology for Identifying Affected Facilities 

In the Technical Support Document (TSD) for the Landfill Sector (U.S. EPA, 2009), it 

was estimated that 200 industrial waste landfills would be subject to subpart TT, including 100 

landfills co-located with pulp and paper mills and 100 landfills co-located with food processing 

facilities. Because landfill emissions are not the primary emissions from pulp and paper mills, 

the revised CH4 GWP should not affect the subpart TT applicability for pulp and paper facilities. 

The number of total food processing facilities has not been updated since the Economic 

Impact Analysis for the Mandatory Reporting of Greenhouse Gas Emissions: Subparts: T, FF, 

TT, and II (U.S. EPA, 2010b) was developed in June 2010. According to that economic impact 

analysis for subpart TT (U.S. EPA, 2010b), the food processing facilities with the following 

NAICS codes were identified as the potential facilities under subpart TT: 

• 311611 – Animal (except Poultry) Slaughtering 

• 311411 – Frozen Fruit, Juice, and Vegetable Manufacturing 

• 311421 – Fruit and Vegetable Canning 

Based on the e-GGRT data for the 2010 reporting year, there are 107 food processing 

facilities reported with the above three NAICS codes. This is close to the original estimate of 100 

food processing facilities in the TSD for the landfill sector (U.S. EPA, 2009). Therefore, we used 

the same food processing facilities information in the TSD for the landfill sector (U.S. EPA, 

2009) to estimate the additional food processing facilities affected by subpart TT due to the 

revised CH4 GWP. 

According to the TSD for the landfill sector (U.S. EPA, 2009), there were 189 food 

processing facilities (based on 1985 data) and 70 of them have GHG emissions between 10,000 

metric tons per year and 25,000 metric tons per year of CO2e based on engineering judgments. 

The list of the food processing facilities is not available. Assuming that CH4 emissions are the 

main GHG emissions from food processing facilities, the food processing facilities with GHG 

emissions between 21,000 metric tons per year and 25,000 metric tons per year of CO2e in the 

TSD are the additional facilities that could be affected by the revised CH4 GWP from 21 to 25. 

Assuming an even distribution of facilities across this range of emissions, the number of food 

processing facilities with CO2e emissions between 21,000 metric tons per year and 25,000 metric 

tons per year is estimated to be 70 x (25,000 – 21,000) / (25,000 – 10,000) = 19 facilities. The 

total additional facilities subject to subpart TT as a result of the revised CH4 GWP are 

summarized in Table 6-25: 
62 

Table 6-25. Number of Additional Industrial Waste Landfills 

Subject to Subpart TT as a Result of GWP Revisions 

Type of Industrial Waste Landfills Number of Additional Affected Landfills

After Revisions to CH4 GWP 

Located in Pulp and Paper Mills 0

Located in Food Processing Facilities 19

Total 19

6.7.2 Methodology for Estimating Impacts 

To determine the cost impacts resulting from the revised GWP for CH4, ERG used the 

same methodology that was used in the Economic Impact Analysis for Subpart TT (U.S. EPA, 

2010b). The economic impact analysis is based on the number of facilities affected and the rule 

implementation cost for each facility. The cost information is adjusted to the dollar value in 

2011. The Small Entity Impact Analysis is measured using “sales tests” (represented as cost-toreceipt ratios) for food processing facilities with the NAICS codes identified in the Economic 

Impact Analysis for Subpart TT (U.S. EPA, 2010b). 

6.7.3 Impacts 

The cost impact due to the revised CH4 GWP was evaluated based on the number of 

additional affected facilities and the rule implementation cost for each facility. Cost information 

for each affected industrial waste landfill is based on the labor cost and capital cost information 

listed in the original Economic Impact Analysis for Subpart TT (U.S. EPA, 2010b). Labor costs 

were adjusted from 2006 to 2011 using the Bureau of Labor statistics average labor factors. 

Capital costs were adjusted from 2006 to 2011 using the CEPCI plant cost index. The rule 

implementation cost information for subpart TT is summarized in Table 6-26. 

Table 6-26. Rule Implementation Costs for Subpart TT for Each Facility

Labor Costs Capital and O&M Costs Total

First Year 

Subsequent 

Year First Year 

Subsequent 

Year First Year 

Subsequent 

Year 

in 2006$ $5,088 $3,607 $495 $495 $5,583 $4,102

in 2011$ $5,660 $4,013 $580 $580 $6,240 $4,593

 

From Table 6-25, there are19 additional facilities subject to subpart TT due to the revised 

CH4 GWP. The total cost for the 19 additional facilities is $118,560 for the first year and 

$87,300 for the subsequent years. The impact due to the revised GWP for subpart TT is 

summarized in Table 6-27. 
63 

Table 6-27. Summary of Subpart TT Impacts due to the GWP Revisions 

Total Number 

of Facilities in 

Source 

Categorya 

Number of 

Reporters 

Prior to GWP 

Revisionsa 

Number of 

New Reporters 

Due GWP 

Revisions 

Total Emissions 

From Reporters 

Prior to GWP 

Revisions 

(metric tons of 

CO2e per year)a 

Incremental 

Emissions For 

New Reporters 

(metric tons of 

CO2e per year )b 

Incremental 

Cost Impact 

For New 

Reporters 

(2011$ per 

year) 

369 200 19 13,700,000 520,000 87,300

a

 From the TSD for Subpart TT (U.S. EPA, 2010a). 

b

 Estimated by multiplying the number of new affected facilities (19) by the average CH4 generation for each new 

affected facility. The average CH4 emissions for each new affected facility are assumed to be (25,000 + 

21,000)/2 x 25/21 = 27,381 metric tons/yr of CO2e. The amount of CO2 equivalent has been adjusted using the 

new GWP for CH4 of 25. 

6.7.4 Small Entity Impacts 

The small entity economic impact was measured using the “sales tests” approach 

(represented as cost-to-receipt ratios) for NACIS codes associated with the affected subparts in 

the Economic Impact Analysis for Subpart TT (U.S. EPA, 2010b). The same approach is used in 

this analysis for the additional facilities subject to subpart TT due to the revised CH4 GWP. If the 

ratio of rule implementation cost to sales is less than 1%, the impact is not considered to be 

significant (U.S. EPA, 2010b). 

Based on the information provided in Tables 5-10 (Number of Establishments) and 5-

11(Receipts by Industry and Enterprise Size, in 2002 dollars) in the Economic Impact Analysis 

for Subpart TT (U.S. EPA, 2010b), the average receipts (sales) for the food processing facilities 

with NAICS codes of 311611, 311411, and 311421 were calculated by dividing the total receipts 

information by the number of establishments for each enterprise size. In addition, the average 

receipts information has been adjusted from 2002 dollars to 2011 dollars based on the consumer 

price index published by Bureau of Labor Statistics. These results are shown in Table 6-28. 

Table 6-28. Average Receipts for Each Establishment by Enterprise Size (million, 2011$) 

NAICS 

NAICS 

Description 

SBA Size 

Standard 

Owned by Enterprises with: 

1-19 

Employees 

20-99 

Employees 

100-499 

Employees 

500-749 

Employees 

750-999 

Employees 

1,000-

1,499 

Employees 

311611 

Animal (except 

Poultry) 

Slaughtering 

500 

employees 1.31 25.38 D D 1,412.28 D 

311411 

Frozen Fruit, 

Juice, and 

Vegetable 

Manufacturing, 

and 

500 

employees 2.47 45.87 10.46 D 234.82 D 

311421 

Fruit and 

Vegetable 

Canning 

500 

employees 1.78 20.77 14.77 54.92 139.00 D 
64 

Table 6-28. Average Receipts for Each Establishment by Enterprise Size (million, 2011$) 

NAICS 

NAICS 

Description 

SBA Size 

Standard 

Owned by Enterprises with: 

1-19 

Employees 

20-99 

Employees 

100-499 

Employees 

500-749 

Employees 

750-999 

Employees 

1,000-

1,499 

Employees 

Note: D denotes that receipt data was not disclosed.

Although the number of establishment information has been updated in 2007 economic 

census, there is no updated receipts (sales) information for each size of enterprise. According to 

the cost information listed in Table 6-26, the rule implementation costs for subpart TT is $6,240 

for the first year and $4,593 for the subsequent years (in 2011 dollars). The sales tests (cost-toreceipt ratios) results are shown in Table 6-29 for the first year and in Table 6-30 for the 

subsequent years. 

Table 6-29. Sales Tests for Subpart TT Facilities: First Year

NAICS 

NAICS 

Description 

SBA Size 

Standard 

Owned by Enterprises with: 

1-19 

Employees 

20-99 

Employees 

100-499 

Employees 

500-749 

Employees 

750-999 

Employees 

1,000-

1,499 

Employees 

311611 

Animal (except 

Poultry) 

Slaughtering 

500 

employees 0.48% 0.02% D D 0.00% D 

311411 

Frozen Fruit, 

Juice, and 

Vegetable 

Manufacturing 

500 

employees 0.25% 0.01% 0.06% D 0.00% D 

311421 

Fruit and 

Vegetable 

Canning 

500 

employees 0.35% 0.03% 0.04% 0.01% 0.00% D 

Note: D denotes that receipt data was not disclosed.

Table 6-30. Sales Tests for Subpart TT Facilities: Subsequent Years

NAICS 

NAICS 

Description 

SBA Size 

Standard 

Owned by Enterprises with: 

1-19 

Employees 

20-99 

Employees 

100-499 

Employees 

500-749 

Employees 

750-999 

Employees 

1,000-

1,499 

Employees 

311611 

Animal (except 

Poultry) 

Slaughtering 

500 

employees 0.35% 0.02% D D 0.00% D 

311411 

Frozen Fruit, 

Juice, and 

Vegetable 

Manufacturing 

500 

employees 0.19% 0.01% 0.04% D 0.00% D 

311421 

Fruit and 

Vegetable 

Canning 

500 

employees 0.26% 0.02% 0.03% 0.01% 0.00% D 

Note: D denotes that receipt data was not disclosed.
65 

The results in Tables 6-29 and 6-30 show that the costs for GHG reporting for the 

facilities subject to subpart TT is well below 1% of the sales for all size of food processing 

facilities identified. Therefore, we have concluded that there is not a significant impact on a 

substantial number of small entities as a result of this action. 

6.7.5 References for Subpart TT 

U.S. EPA, 2009. Technical Support Document For the Landfill Sector: Proposed Rule For Mandatory 

Reporting Of Greenhouse Gases. See Docket ID: EPA-HQ-OAR-2008-0508-0034. February 4, 2009. 

U.S. EPA 2010a. Technical Support Document For the Industrial Waste Landfill Sector: Final Rule For 

Mandatory Reporting Of Greenhouse Gases. See Docket ID: EPA-HQ-OAR-2008-0508-2310. June 9, 

2010. 

U.S. EPA 2010b. 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. 

7.0 IMPACTS OF OTHER PROPOSED TECHNICAL CORRECTIONS AND

AMENDMENTS 

In addition to the proposed amendments to GWPs, EPA is also proposing technical 

corrections and other clarifications to several subparts in the GHG reporting rule. In this section, 

we discuss the potential burden impacts for facilities and reporters affected by the proposed 

amendments. The more substantive technical corrections, clarifying and other amendments to the 

GHG reporting rule are discussed here. Additional minor corrections are discussed in the 

memorandum titled “Table of 2013 Technical Corrections, Clarifying and other Amendments to 

Certain Provisions of the Mandatory Greenhouse Gas Reporting Rule (40 CFR Part 98),” which 

is available in the rulemaking docket. 

7.1 Subpart A - General Provisions 

The majority of the proposed revisions to subpart A are associated with changes to 

additions of GWP values and provisions that apply to facilities that would be required to report 

based on the revised GWPs. The remaining proposed amendments to subpart A include adding 

requirements that provide reporters instruction regarding reporting of location, ownership, and 

facility identification (i.e., reporting of ORIS codes). The remaining proposed changes also 

include revising and adding definitions. Except for the proposed amendments related to the GWP 

changes, the proposed amendments to subpart A are not expected to result in any additional 

burden for facilities subject to the GHG reporting rule. All of the proposed revisions not related 

to the GWP changes are either clarifications, or require reporting of information that facilities are 

expected to have readily available (e.g., latitude and longitude of the facility, ORIS code for each 

power generating unit). 
66 

7.2 Subpart C - General Stationary Fuel Combustion Sources 

For subpart C, EPA is proposing to expand the use of the Tier 1 methodology to be used 

for Table C-1 fuels that are combusted in a unit with a maximum rated heat input capacity 

greater than 250 mmBtu/hr, if the fuel provides less than 10 percent of the annual heat input to 

the unit. Expanding the use of the Tier 1 methodology is expected to reduce monitoring burden 

for facilities that are subject to the requirements of subpart C and combust small amounts of 

secondary fuels. 

EPA is also proposing to revise several emission factors and higher heating values 

(HHVs) for fuels in Table C-1 including, but not limited to, coals and coke, liquefied petroleum 

gases (e.g. propane, propylene, ethane, etc.), wood and wood residuals, and biogases. Of the 

proposed changes to emission factors, the change with the largest percent difference 

(approximately 11 percent) is the emission factor for coke (which is also being revised to read 

“coal coke”). Approximately 1.6 percent of facilities that reported under subparts C and D for 

reporting year 2011 indicated using coke as a fuel for combustion in addition to other fuels. The 

majority of coal coke produced (92 percent) in the United States is used in blast furnaces for the 

conversion of iron ore into iron (U.S. EPA, 2001). The emission factor for coal coke is not used 

in the calculation of CO2 emissions for iron furnaces. Due to the small number of facilities that 

reported using coke as a fuel, and because facilities do not typically use coke as the primary fuel, 

we do not expect any additional facilities would be required to report due to an increase in 

calculated CO2 emissions resulting from the proposed increase to the coke emission factor in 

Table C-1. 

7.3 Subpart H – Cement Production 

EPA is proposing to require annual, facility-wide cement production instead of monthly, 

kiln-specific cement production for facilities that use a CEMS to measure CO2 emissions. 

Because facilities already expected to track facility-wide cement production for budgeting 

purposes, we do not expect this revision to result in any additional burden for cement production 

facilities. 

7.4 Subpart K – Ferroalloy Production 

EPA is proposing two changes to subpart K. The first change corrects a conversion factor 

in equation K-3 and we do not expect any additional reporter burden as a result. The second 

change requires facilities to report the annual process CH4 emissions from each electric arc 

furnace (EAF) used for the production of any ferroalloy listed in Table K-1 of subpart K. 

Because facilities must already monitor and calculate emissions of CH4 from each EAF, we do 

not expect that the proposed changes would impose and additional burden on reporters. The 
67 

proposed data element reflects aggregated annual information that is currently gathered by 

reporters. 

7.5 Subpart L – Fluorinated Gas Production 

EPA is proposing to extend temporary, less detailed reporting requirements to allow EPA 

time to evaluate concerns raised by producers regarding the potential sensitivity of the more 

detailed reporting required by the 2010 final rule. As the proposed revision would be an 

extension of existing requirements, we do not anticipate any additional reporter burden as a 

result. 

7.6 Subpart N – Glass Production 

In addition to clarify several requirements and equations terms, EPA is proposing to 

revise the monitoring methods used to measure carbonate-based mineral mass-fractions to allow 

for more accurate measurement methods and provide flexibility for reporters. EPA is proposing 

facilities use consensus standards that specify X-ray fluorescence (XRF). To determine if 

requiring XRF methods would impose any additional burden, we compared the cost of the 

currently required methods to methods using XRF. The costs of ASTM D-3682 and D-6349 are 

listed as $165 from Wyoming Analytical Laboratories (WAL). The costs of similar analyses 

using XRF (ASTM D-4326) range from $165 to $195 according to WAL (WAL, 2009). Based 

on the similarity in cost, we do not believe that revising the measurement methods to specify 

XRF will impose any additional burden on facilities subject to subpart N. 

7.7 Subpart P – Hydrogen Production 

EPA is proposing several amendments to subpart P including adding flexibility for 

monitoring and measurement methodologies and removing redundant reporting requirements. 

EPA is also proposing changes that clarify rule text and equation terms. None of the proposed 

amendments for subpart P are expected to impose any additional burden on reporters. 

7.8 Subpart Q – Iron and Steel Production 

EPA is proposing multiple amendments to subpart Q to clarify certain provisions and 

calculation methods. Two of the proposed revisions may potentially affect the reporting burden 

for facilities covered under subpart Q. First, EPA is proposing to include direct reduction 

furnaces not co-located with an integrated iron and steel manufacturing process, as these 

furnaces were inadvertently excluded from the original rulemaking. Because this change only 

impacts one facility that is already reporting under subpart Q, we do not anticipate this change 

will impose any additional burden on reporters. 

Second, EPA is proposing to amend Equation Q-5 in subpart Q to account for the use of 

gaseous fuels in EAFs. Because facilities currently determine the mass rate of fuels using the 
68 

procedures in subpart C and must report the annual volume of gaseous fuels, we do not expect 

that reporters will need to collect or record any additional information to account for the use of 

gaseous fuels in equation Q-5 in subpart Q. Therefore, we do not expect any additional burden 

will be imposed on reporters subject to subpart Q. 

7.9 Subpart X – Petrochemical Production 

EPA is proposing several substantial changes to subpart X. EPA is proposing to require 

reporters using CEMS to determine CO2 emissions to use Equation C-10 of subpart C to Part 98 

to calculate CH4 and N2O emissions from burning process off-gas. We do not expect an increase 

in burden since Tier 4 units can use best available information to estimate fuel use (see 40 CFR 

98.22(c)(4)(i) and 40 CFR 98.33(c)(4)(ii)(C)). 

EPA is also proposing several changes for those reporters that use the mass balance 

calculation method. First, EPA is allowing flexibility for the source of the carbon measurements 

for feedstocks and products. Next, EPA is proposing to allow the alternative sampling 

requirements for feedstocks and products when the composition is greater than 99.5 percent of a 

single compound to be used during all times that the average monthly concentration is above 

99.5 percent. Additionally, EPA is proposing to allow the inputs for gaseous feedstock and 

products to be measured on either a mass basis or on a volume basis in Equation X-1. EPA is 

also proposing to allow facilities to use industry standard practices for the analysis of carbon 

black feedstock oils and carbon black products, instead of a specified list of standards currently 

provided in 40 CFR 98.244(b)(4). We do not anticipate any additional burden as a result of these 

changes since they allow additional flexibility for reporters. 

EPA is clarifying the requirements for flares to specify that facilities must conduct 

monitoring and quality assurance in accordance with 40 CFR 98.245, which was EPA’s original 

intent. Since the proposed change is a clarification, we do not expect any additional burden as a 

result. 

EPA is proposing to clarify the missing data procedures for missing feedstock and 

product flow rates, missing feedstock and product carbon contents, and missing molecular 

weights for gaseous feedstocks and products. EPA is also proposing to add missing data 

requirements for flares. Because these proposed amendments only clarify the existing missing 

data procedures for subpart X facilities, we do not expect these amendments will impose any 

additional burden on reporters. 

Additionally, EPA is proposing several amendments to reporting requirements. The 

majority of amendments to the reporting requirements are clarifications; however, one particular 

amendment would require facilities to identify combustion units that burned both process off-gas 
69 

and supplemental fuel and that are not part of the petrochemical process unit. EPA is also 

proposing to require facilities to provide an estimate of the fraction of total CO2 emissions that 

are attributable to the petrochemical process unit (based on engineering judgment) if the CEMS 

monitoring location meets the conditions in 40 CFR 98.426(b)(2) or (3). Although these are new 

reporting requirements, facilities would not be required to install any additional monitoring 

equipment or develop any additional monitoring and record keeping procedures; therefore, we do 

not expect these additional reporting requirement to significantly increase burden for facilities 

reporting under subpart X. 

7.10 Subpart Z – Phosphoric Acid Production 

EPA is proposing several clarifying amendments to subpart Z, phosphoric acid 

production. Of those amendments, EPA is proposing to change the reporting requirement of the 

annual permitted phosphoric acid production capacity to the annual phosphoric acid production 

capacity. We do not expect this change to impose any additional burden on reporters since the 

information should be readily available in facility records. EPA is also proposing to add a 

reporting requirement to report the number of times missing data procedures were used to 

estimate the CO2 content of the phosphate rock. Again, we do not expect any additional burden 

for reporters as a result of this change because facilities are already required to keep records for 

estimating missing values of CO2 content of phosphate rock per 40 CFR 98.265(a), and no new 

information would need to be collected. 

7.11 Subpart AA – Pulp and Paper Production 

EPA is proposing changes to correct emission factors and clarify the information that 

must be reported under subpart AA. First, EPA is proposing to remove the references to sitespecific emission factors in 40 CFR 98.273(a)(3), 40 CFR 98.276(e) and Equation AA-1. EPA is 

also proposing to correct printing errors, inadvertent omissions, and inconsistencies from Table 

AA-1 and AA-2. We do not anticipate any additional burden due to these changes since no 

additional reporting requirements or monitoring would be required. 

EPA is also proposing to amend the reporting requirement for the annual pulp and/or 

paper production information that must be reported. EPA is clarifying that the annual production 

information must consist of the production of air-dried, unbleached virgin pulp produced onsite 

during the reporting year and the production of paper products exiting the paper machine(s) 

during the reporting year, prior to application of any off-machine coatings. Prior to this proposal, 

EPA clarified the production reporting requirement under 40 CFR 98.276(k) in the “Frequently 

Asked Questions” section of EPA’s supporting website for the GHG reporting rule. In their 

guidance, EPA specified that facilities should report virgin chemical pulp production at the mill 

separate from the mass of paper product exiting all of the paper machine(s) at the mill; therefore, 
70 

EPA is clarifying the reporting requirement and no new reporting or monitoring would be 

required by reporters. As a result, we do not expect the proposed clarification to the rule to 

impose any additional burden on reporters. 

7.12 Subpart BB – Silicon Carbide Production 

For subpart BB, Silicon Carbide Production, EPA is proposing to remove the requirement 

for facilities to report CH4 emissions from silicon carbide process units or furnaces. Additionally, 

EPA is proposing to amend subpart BB such that facilities would calculate and report CO2

emissions for all process units and furnaces combined, instead of each process unit or production 

furnace. The remaining changes to subpart BB either support these amendments, or provide 

minor clarifications of the rule text. We expect that both of these major changes will reduce the 

reporting burden for facilities subject to subpart BB. 

7.13 Subpart DD – Electrical Transmission and Distribution Equipment Use 

EPA is proposing two technical corrections to subpart DD to correct the accuracy and 

precision requirements for weighing cylinders. Instead of scale accuracies of “2 pounds of the 

scale’s capacity,” EPA is proposing to revise the rule to be consistent with their original intention 

of “2 pounds of true weight.” This accuracy requirement was noted in the technical support 

document to subpart DD, EPA’s response to public comments for subpart DD7, and the preamble 

to the final Part 98 (74 FR 56260, October 30, 2009). In their response to comments, EPA noted 

that a “2 pounds of true weight” requirement would be less burdensome that the 1 percent of true 

weight requirement originally proposed; therefore, we do not expect any added burden would 

result from amending the rule to reflect EPA’s original intent. 

7.14 Subpart FF – Underground Coal Mines 

EPA is proposing numerous amendments to subpart FF. The majority of proposed 

changes include terminology revisions that more accurately reflect industry operations, 

correction of subscript errors, and minor clarifications of rule text. More substantially, EPA is 

proposing to include reporting of the following data elements: the moisture correction factor 

used in the emissions equations, units of measure for the volumetric flow rates reported, method 

of determining the gas composition, the start date and close date of each well or shaft, the 

number of days the well or shaft was in operation during the reporting year, and the amount of 

CH4 routed to each destruction device, and the Mine Safety and Health Administration (MSHA) 

identification. All of these data elements are readily available to reporters and would not require 

additional data collection or monitoring; therefore, we do not expect the proposed changes to 

subpart FF would impose any significant additional burden to covered facilities. 

 

7

 For more information, refer to http://www.epa.gov/ghgreporting/reporters/subpart/dd.html
71 

7.15 Subpart HH – Municipal Solid Waste Landfills 

For subpart HH, EPA is proposing to remove the option to used measured values for the 

degradable organic carbon content in Equation HH-1. EPA is also clarifying that the fraction by 

volume of CH4 in the landfill gas, used in Equation HH-1, should be corrected to zero percent 

oxygen. Additionally, EPA is reducing the measurement frequency for sampling methane 

concentrations from weekly to monthly for the parameter “N” in Equation HH-4. To clarify how 

to calculate methane emissions at landfills with gas collection systems that have multiple 

measurement locations and/or multiple destruction devices, EPA is proposing to amend 

Equations HH-6, HH-7, and HH-8 and surrounding text to generalize these equations. EPA is 

also proposing to make several more minor clarifications and amendments including removing 

duplicative reporting requirements. Facilities are not required to report any additional data 

elements, or implement any additional monitoring equipment or procedures as a result of these 

proposed amendments. Therefore, we do not expect any additional burden for reporters subject 

to subpart HH as a result of these proposed revisions. 

7.16 Subpart LL – Suppliers of Coal-based Liquid Fuels 

EPA is proposing several amendments to subpart LL. In addition to clarifying reporting 

requirements, EPA is proposing changes to remove the requirements at 40 CFR 98.386(a)(1), 

(a)(5), (a)(13), (b)(1) and (c)(1) for each facility, importer, and exporter to report the annual 

quantity of each product or natural gas liquid on the basis of the measurement standards method 

or industry standard practice used. We expect a reduction in burden for reporters subject to 

subpart LL since EPA is proposing to remove reporting requirements from the rule. 

7.17 Subpart MM – Suppliers of Petroleum Products 

In addition to several minor correction and clarifications, EPA is proposing several 

substantial technical corrections for subpart MM. First, EPA is proposing to amend the 

equipment calibration requirements for petroleum products suppliers to be consistent with other 

Part 98 calibration requirements to allow for postponement of calibrations for units and 

processes that operate continuously with infrequent outages and therefore provide flexibility for 

reporters meeting the equipment calibration requirements. Next, EPA is proposing to remove the 

requirements of 40 CFR 98.396(a)(1), (a)(5), (a)(13), (b)(1) and (c)(1) for each facility, importer, 

and exporter to report the annual quantity of each petroleum product or natural gas liquid on the 

basis of the measurement standard method or industry standard practice used. In another step to 

reduce recordkeeping and reporting burden, the reporting requirements for crude oil at 40 CFR 

98.396(a)(20) are proposed to be changed to require only the annual quantity of crude oil. EPA is 

also proposing to eliminate the requirement to measure the API gravity of each batch of crude oil 

at 40 CFR 98.394(d). EPA is proposing to add and revise several definitions and the default 

density and emission factors in Table MM-1 in subpart MM to harmonize with the proposed 
72 

changes. We expect that the proposed changes to subpart MM will provide additional flexibility 

for reporters and reduce the reporting and recordkeeping burden for those facilities required to 

report under subpart MM. 

7.18 Subpart NN – Suppliers of Natural Gas Liquids 

EPA is proposing several technical corrections to subpart NN. In addition to minor 

changes, EPA is proposing several amendments that may affect the reporting burden of facilities 

subject to subpart NN. First, EPA is proposing to amend the definition of Local Distribution 

Companies (LDS) to clarify that for LDCs that operate in multiple states, the operations in each 

state are considered a separated LDC. EPA is also proposing a revision to clarify that interstate 

and intrastate pipelines delivering natural gas either directly to major industrial users or to farm 

taps upstream of the LDC inlet are not included in the definition of an LDC. We do not expect 

these clarifications to impose any additional burden on reporters. In “Q286” of the “Frequently 

Asked Questions” section of EPA’s supporting website for the GHG reporting rule, EPA initially 

clarified its intent that the owner/operator of each LDC that is regulated as a separate operating 

company by State public utility commissions or that operate as independent municipally–owned 

distribution systems must submit an annual report. Therefore, the proposed clarifications are a 

follow-up to previous guidance and we do not expect any additional owners/operators would be 

required to report as a result of the change. 

EPA is also proposing to change the calculation and reporting requirements that require 

LDCs to report the annual volume of natural gas delivered to each meter registering supply equal 

to or greater than 460,000 million standard cubic feet (Mscf). EPA is proposing that if the LDC 

knows that a series of meters serves one particular customer receiving a total of greater than 

460,000 Mscf during the year, the LDC would be required to report these deliveries per customer 

rather than per meter. If the LDC does not know if the series of meters serve a single customer or 

multiple customers, the LDC may continue to report deliveries to individual meters. Because 

LDCs would be able to report on a per customer, rather than per meter basis, we expect a 

reduction in the reporting burden as a result of this proposed change. 

EPA is proposing to amend part of the calculation methodology in subpart NN. Subpart 

NN currently requires the use of a single emission factor for all types of gas streams accounted 

for in Equation NN-5. Because the characteristics of these streams may differ, EPA is proposing 

equation NN-5 be replaced with two equations, NN-5a and NN-5b. The greenhouse gas quantity 

associated with the net amount of natural gas that is placed into or removed from storage during 

the year is proposed to be calculated using equation NN-5a. Emissions that would result from the 

combustion or oxidation of natural gas that bypassed the city gate are proposed to be calculated 

using Equation NN-5b, which allows the use of different emission factors for different streams of 

gas. Additionally, EPA is proposing a change to Equation NN-6 that incorporates the two 
73 

proposed NN-5 equations. Reporters would only be required to modify their calculation 

methodology and would not be required to install any additional monitoring equipment. 

Therefore, we do not expect any additional burden on facilities required to report under subpart 

NN as a result of these proposed changes. 

EPA is also proposing to require reporting of the quantity of o-grade, y-grade, and other 

types of bulk natural gas liquids (NGLs) received, and the quantity not fractionated, but supplied 

downstream. We do not anticipate that reporters would be required to purchase or install any new 

monitoring equipment as a result of these proposed reporting requirements since (per 40 CFR 

98.404(a)(1)) fractionators and LDCs are required to determine quantities using methods in 

common use in the industry for billing purposes as audited under existing Sarbanes Oxley 

regulation. 

7.19 Subpart QQ – Importers of Exporters of Fluorinated Greenhouse Gases Contained 

in Pre-Charged Equipment of Closed Cell Foams 

EPA is proposing multiple revisions to subpart QQ. In addition to minor corrections and 

clarifications, EPA is proposing to remove the following reporting requirements: 40 CFR 

98.436(a)(5), (a)(6)(iv), (b)(5), and (b)(6)(iv). We expect that the removal or reporting 

requirements will alleviate reporting burden for facilities required to report under subpart QQ. 

7.20 Subpart RR – Geologic Sequestration of Carbon Dioxide 

In addition to minor corrections and clarifications to subpart RR, EPA is proposing to add 

a reporting requirement for facilities to report the standard or method used to calculate the mass 

or volume of contents in containers that is redelivered to another facility without being injected 

into the well. The proposed data element does not require additional data collection or 

monitoring from reporters, and as it is not a significant change. Therefore, we do not expect that 

this amendment would add burden to reporting entities. 

7.21 Subpart TT – Industrial Waste Landfills 

EPA is proposing multiple changes to subpart TT. EPA is proposing to revise definitions 

in Equation TT-1 and TT-7 and to correct Equation TT-7 by deleting an erroneous term. EPA is 

also proposing a change to clarify that the number of waste streams for which Equation TT-1 is 

used includes the number of "Inert" waste streams disposed of in the landfill. Additionally, EPA 

is proposing to expand the provisions to determine volatile solids concentration for historically 

managed waste streams so that they may also be used for determining a site-specific DOC value 

for historically managed waste streams. EPA is also proposing to eliminate duplicative reporting 

requirements and to clarify the requirements for reporters when using Equations TT-4a or TT-4b. 

EPA is also proposing amendments to Table TT-1 to include the DOC default value of 0.09 for 

“Industrial Sludge,” and the corresponding k-values. None of the proposed changes to subpart 
74 

TT would require any additional monitoring or recordkeeping and reporting by facilities, 

therefore we do not anticipate any additional burden as a result of the proposed changes to 

subpart TT. 

7.22 Subpart UU – Injection of Carbon Dioxide 

EPA is proposing several technical amendments to subpart UU. Most substantial, EPA is 

proposing to add two reporting requirements. First, reporters would be required to report the 

purpose of CO2 injection. Second, facilities would be required to report the standard or method 

used to calculate the parameters for CO2 received in containers. Neither of these reporting 

requirements would require facilities to collect any additional data or install and operate any 

additional monitoring equipment. As a result, we do not expect the proposed changes would 

impose any additional significant burden on facilities required to report under subpart UU. 

7.23 Additional Subparts with Proposed Corrections 

EPA is proposing several changes to subparts E, G, O, S, V, Y, II, PP, and SS; however, 

all of the proposed changes are clarifications and/or corrections for consistency throughout the 

subparts. Therefore, we do not expect any additional burden for facilities subject to the reporting 

requirements of subpart E, G, O, S, V, Y, II, PP, and SS. 

7.24 References for Section 7 

U.S. EPA, 2001. National Emission Standards for Hazardous Air Pollutants (NESHAP) for Coke Ovens: 

Pushing, Quenching, and Battery Stacks – Background Information for Proposed Standards. EPA-453/R01-006. Available at: http://www.epa.gov/ttn/atw/coke2/coke2p_bid.pdf. 

WAL, 2009. Wyoming Analytical Laboratories, Inc. Prices as of Spring 2009. Available at: 

http://www.wal-lab.com/DownloadFiles/CementFlyAsh%20SoilsOverb.pdf. 
Appendix A 

GWPs – Proposed Revisions to Table A-1 
A-1

Appendix A: GWPs Proposed Revisions to Table A-1 of Subpart A 

Name CAS No. Chemical Formula 

Table A-1 

Global 

Warming 

Potential 

(100 yr.) 

New or 

Revised 

Global 

Warming 

Potentials 

(100 yr.) Increase 

% 

Increase 

Carbon Dioxide CO2 1 1 -- --

Methane 74-82-8 CH4 21 25 4 19%

Nitrous oxide 10024–97–2 N2O 310 298 -12 -4%

HFC–23 75–46–7 CHF3 11,700 14,800 3,100 26%

HFC–32 75–10–5 CH2F2 650 675 25 4%

HFC–41 593–53–3 CH3F 150 92 -58 -39%

HFC–125 354–33–6 C2HF5 2,800 500 -2,300 -82%

HFC–134 359–35–3 C2H2F4 1,000 1,100 100 10%

HFC–134a 811–97–2 CH2FCF3 1,300 1,430 130 10%

HFC–143 430–66–0 C2H3F3 300 353 53 18%

HFC–143a 420–46–2 C2H3F3 3,800 4,470 670 18%

HFC–152 624–72–6 CH2FCH2F 53 53 0 0%

HFC–152a 75–37–6 CH3CHF2 140 38 -102 -73%

HFC–161 353–36–6 CH3CH2F 12 12 0 0%

HFC–227ea 431–89–0 C3HF7 2,900 3,220 320 11%

HFC–236cb 677–56–5 CH2FCF2CF3 1,340 1,340 0 0%

HFC–236ea 431–63–0 CHF2CHFCF3 1,370 1,370 0 0%

HFC–236fa 690–39–1 C3H2F6 6,300 9,810 3,510 56%

HFC–245ca 679–86–7 C3H3F5 560 693 133 24%

HFC–245fa 460–73–1 CHF2CH2CF3 1,030 1,030 0 0%

HFC–365mfc 406–58–6 CH3CF2CH2CF3 794 794 0 0%

HFC–43–10mee 138495–42–8 CF3CFHCFHCF2CF3 1,300 1,640 340 26%

Sulfur hexafluoride 2551–62–4 SF6 23,900 22,800 -1,100 -5%

Trifluoromethyl 

sulphur pentafluoride 373–80–8 SF5CF3 17,700 17,700 0 0% 

Nitrogen trifluoride 7783–54–2 NF3 17,200 17,200 0 0%

PFC–14 

(Perfluoromethane) 75–73–0 CF4 6,500 7,390 890 14% 

PFC–116 

(Perfluoroethane) 76–16–4 C2F6 9,200 12,200 3,000 33% 

PFC–218 

(Perfluoropropane) 76–19–7 C3F8 7,000 8,830 1,830 26% 

Perfluorocyclopropane 931–91–9 C-C3F6 17,340 17,340 0 0%

PFC–3–1–10 

(Perfluorobutane) 355–25–9 C4F10 7,000 8,860 1,860 27% 

Perfluorocyclobutane 115–25–3 C-C4F8 8,700 10,300 1,600 18%

PFC–4–1–12 

(Perfluoropentane) 678–26–2 C5F12 7,500 9,160 1,660 22% 

PFC–5–1–14 355–42–0 C6F14 7,400 9,300 1,900 26%
A-2

Appendix A: GWPs Proposed Revisions to Table A-1 of Subpart A 

Name CAS No. Chemical Formula 

Table A-1 

Global 

Warming 

Potential 

(100 yr.) 

New or 

Revised 

Global 

Warming 

Potentials 

(100 yr.) Increase 

% 

Increase 

(Perfluorohexane)

PFC–9–1–18 306–94–5 C10F18 7,500 7,500 0 0%

HCFE–235da2 

(Isoflurane) 26675–46–7 CHF2OCHClCF3 350 350 0 0% 

HFE–43–10pccc (H–

Galden 1040x) E1730133 

CHF2OCF2OC2F4OC

HF2 1,870 1,870 0 0% 

HFE–125 3822–68–2 CHF2OCF3 14,900 14,900 0 0%

HFE–134 1691–17–4 CHF2OCHF2 6,320 6,320 0 0%

HFE–143a 421–14–7 CH3OCF3 756 756 0 0%

HFE–227ea 2356–62–9 CF3CHFOCF3 1,540

HFE–236ca12 (HG–10) 78522–47–1 CHF2OCF2OCHF2 2,800 2,800 0 0%

HFE–236ea2 

(Desflurane) 57041–67–5 CHF2OCHFCF3 989 989 0 0% 

HFE–236fa 20193–67–3 CF3CH2OCF3 487 487 0 0%

HFE–245cb2 22410–44–2 CH3OCF2CF3 708 708 0 0%

HFE–245fa1 84011–15–4 CHF2CH2OCF3 286 286 0 0%

HFE–245fa2 1885–48–9 CHF2OCH2CF3 659 659 0 0%

HFE–254cb2 425–88–7 CH3OCF2CHF2 359 359 0 0%

HFE–263fb2 460–43–5 CF3CH2OCH3 11 11 0 0%

HFE–329mcc2 67490–36–2 CF3CF2OCF2CHF2 919 919 0 0%

HFE–338mcf2 156053–88–2 CF3CF2OCH2CF3 552 552 0 0%

HFE–338pcc13 (HG–

01) 188690–78–0 CHF2OCF2CF2OCHF2 1,500 1500 0 0% 

HFE–347mcc3 28523–86–6 CH3OCF2CF2CF3 575 575 0 0%

HFE–347mcf2 E1730135 CF3CF2OCH2CHF2 374 374 0 0%

HFE–347pcf2 406–78–0 CHF2CF2OCH2CF3 580 580 0 0%

HFE–356mec3 382–34–3 CH3OCF2CHFCF3 101 101 0 0%

HFE–356pcc3 160620–20–2 CH3OCF2CF2CHF2 110 110 0 0%

HFE–356pcf2 E1730137 CHF2CH2OCF2CHF2 265 265 0 0%

HFE–356pcf3 35042–99–0 CHF2OCH2CF2CHF2 502 502 0 0%

HFE–365mcf3 378–16–5 CF3CF2CH2OCH3 11 11 0 0%

HFE–374pc2 512–51–6 CH3CH2OCF2CHF2 557 557 0 0%

HFE–449s1 (HFE–

7100) Chemical blend 

163702–07–6

 163702–08–7 

C4F9OCH3

(CF3)2CFCF2OCH3 297 297 0 0% 

HFE–569sf2 (HFE–

7200) Chemical blend 

163702–05–4 

163702–06–5 

C4F9OC2H5

(CF3)2CFCF2OC2H5 59 59 0 0% 

Sevoflurane 28523–86–6 CH2FOCH(CF3)2 345 345 0 0%

HFE–356mm1 13171–18–1 (CF3)2CHOCH3 27 27 0 0%
A-3

Appendix A: GWPs Proposed Revisions to Table A-1 of Subpart A 

Name CAS No. Chemical Formula 

Table A-1 

Global 

Warming 

Potential 

(100 yr.) 

New or 

Revised 

Global 

Warming 

Potentials 

(100 yr.) Increase 

% 

Increase 

HFE–338mmz1 26103–08–2 CHF2OCH(CF3)2 380 380 0 0%

(Octafluorotetramethylene)hydroxymethyl 

group NA X-(CF2)4CH(OH)-X 73 73 0 0% 

HFE–347mmy1 22052–84–2 CH3OCF(CF3)2 343 343 0 0%

Bis(trifluoromethyl)-

methanol 920–66–1 (CF3)2CHOH 195 195 0 0% 

2,2,3,3,3-

pentafluoropropanol 422–05–9 CF3CF2CH2OH 42 42 0 0% 

PFPMIE NA 

CF3OCF(CF3)CF2OCF

2OCF3 10,300 10,300 0 0% 

HFC-1234ze 29118-24-9 C3H2F4 NA 6 NA NA 

hexafluoropropylene 

(HFP) 116-15-4 C3F6

NA

0.25 

NA NA

perfluoromethyl vinyl 

ether (PMVE) 1187-93-5 CF(CF3)OCF3

NA

3 

NA NA

tetrafluoroethylene 

(TFE) 116-14-3 C2F4

NA

0.02 

NA NA

trifluoro propene (TFP) 677-21-4 C3H3F3 NA 3 NA NA

vinyl fluoride (VF) 75-02-5 C2H3F NA 0.7 NA NA

vinylidiene fluoride 

(VF2) 75-38-7 C2H2F2

NA

0.9 

NA NA

carbonyl fluoride 353-50-4 COF2 NA 2 NA NA

perfluoropropyl vinyl 

ether 1623-05-8 C5F10O

NA

3 

NA NA

perfluoroethyl vinyl 

ether 10493-43-3 C4F8O

NA

3 

NA NA

HFC-1234yf 754-12-1 C3H2F4 NA 4 NA NA

perfluorethyl iodide (2-

I) 354-64-3 C2F5I 

NA

3 

NA NA

perfluorbutyl iodide 

(PFBI, 42-I) 423-39-2 C4F9I 

NA

3 

NA NA

perfluorhexyl iodide (6-

I) 355-43-1 C6F13I 

NA

2 

NA NA

perfluoroctyl iodide (8-

I) 507-63-1 C8F17I 

NA

2 

NA NA

1,1,1,2,2-pentafluoro-4-

iodo butane (22-I) 40723-80-6 C4H4F5I 

NA

2 

NA NA

1,1,1,2,2,3,3,4,4-

nonafluoro-6-iodo 

hexane (42-I) 2043-55-2 C6H4F9I 

NA

2 NA NA 
A-4

Appendix A: GWPs Proposed Revisions to Table A-1 of Subpart A 

Name CAS No. Chemical Formula 

Table A-1 

Global 

Warming 

Potential 

(100 yr.) 

New or 

Revised 

Global 

Warming 

Potentials 

(100 yr.) Increase 

% 

Increase 

perfluorobutyl ethene 

(42-U) 19430-93-4 C6H3F9

NA

2 

NA NA

perfluorohexyl ethene 

(62-U) 25291-17-2 C8H3F13

NA

1 

NA NA

perfluorooctyl ethene 

(82-U) 21652-58-4 C10H3F17

NA

1 

NA NA

1H,1H, 2H,2Hperfluorohexan-1-ol 

(42-AL) 2043-47-2 C6H5F9O 

NA

5 

NA NA

FK-5-1-12; Novec 612; 

Novec 

1230;Perfluoroketone; 

FK–5–1–12myy2; nPerfluorooctane; 

Octanedecafluorooctan

e 756-13-8 CF3CF2C(O)CF(CF3)2

NA

1.8 

NA NA

C7 Fluoroketone, 

Novec 774/FK-6-1-12 

813-44-5 and 

813-45-6 

Blend of two isomers: 

3- 

pentanone,1,1,1,2,4,5,

5,5- 

octafluoro-2,4- 

bis(trifluoromethyl) 

and 3- 

hexanone,1,1,1,2,4,4,5

,5,6,6,6- 

undecafluoro-2-

(trifluoromethyl) 

NA

1 

NA NA

trans-1-chloro-3,3,3-

trifluoroprop-1-ene 2730-43-0 CF3CH=CHCl 

NA

7 

NA NA

PFC-6-1-12;

hexadecofluoroheptane 335-57-9 C7F16

NA

7930 

NA NA

PFC-7-1-18;

octadecafluorooctane 307-34-6 C8F18

NA

8340 

NA NA