### 1

MEMORANDUM

TO : Michael Rohwer, Jessica Gordon, Rachel Schmeltz, EP A

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

DATE : December 31, 2012

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

Gas Reporting Rule and Proposed Confidentiality Determinat ions 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 subpart s of the GHG reporting rule (40 CFR part 98).

Sections 1 through 6 of this memorandum explain how report ers would be affected by changes to the GWPs in the GHG reporting rule. Sectio n 7 discusses the impacts of the technical corrections and other proposed amendments. This memorandu m 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 repor ters
5. 

### Methodology for Current Reporters

6. 

### Methodology for New Reporters

7. 

### Impacts of Other Proposed Technical Corrections and Amend ments

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 Mil ls_052611.xlsx

1.0 BACKGROUND AND INTRODUCTION FOR PROPOSED GWP REVISI ONS Facilities affected by the GHG reporting rule must report their GHG emissions to EPA through the electronic Greenhouse Gas Reporting Tool (e-GG RT). 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 IPC C 2007 Fourth Assessment Report 1 

### . EPA is also proposing to add additional fluorinated GHG s 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 G HG reporting rule and have already reported their emissions to e-GR RT 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 G HG reporting rule and are required to report GHG emissions beginning in the 2011 reporting year. Emissions data are not available at the time of wr iting 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 re sult of the proposed changes to Table A-1.

1.1 How GWPs Affect Emissions and Applicability to the GHG Rep orting 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 r eporting 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 c arbon dioxide equivalents (CO 2 

### e). Carbon dioxide equivalent is a metric used to compare the emissions of various GHGs based on
their GWP. Because different GHGs have different he at trapping capabilities and atmospheric lifetimes, they are not directly comparable without tra nslating 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 CO 2 

### e 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 emi ts 1,000 tons of CO 2 

### emits 1,000 tons per year of CO2e. A facility that emits 1,000 tons of methan e emits 21,000 tons per year of CO 2 

### e.

1 IPCC, 2007. Climate Change 2007: Synthesis Report. Contribut ion of Working Groups I, II and III to the Fourth Assessment. Report of the Intergovernmental Panel on Cli mate 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 i n the 2007 Fourth Assessment Report updated the GWP values for the following compounds: m ethane, nitrous oxide, the hydrofluorocarbons, perfluorinated compounds, fluorinated ethe rs, substances controlled by the Montreal protocol, and hydrocarbons and other compounds with d irect warming effects. The revised GWP values by IPCC represent an increase in the G WP for CH 4 

### , a slight decrease for
N 2 

### O, 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 (CO 2 

### ), methane (CH 4 

### ), nitrous oxide (N 2 

### O), sulfur hexafluoride (SF 6 

### ), hydrofluorocarbons, perfluorocarbons, and other fluorin ated GHGs (which include fluorinated ethers). The GHG reporting rule does n ot 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 m emorandum 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 t o 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 pro vide calculation methodologies and reporting requirements for F-GHGs or F -HTFs for which GWPs were not available in the IPCC assessment reports or other sci entific assessments at promulgation. The GWPs in Table A-1 of subpart A are primarily used for th reshold calculations to determine rule applicability (40 CFR 98.2(b)) and for reporting total GHG emi ssions or supply in CO 2 

### e for each facility or supplier (40 CFR 98.3(c)(4)). Those F-GHGs or F-HTFs whose GWPs are currently
not listed in Table A-1 are not included in threshold calc ulations for applicability or in the CO 2 

### e totals reported by facilities and suppliers, but are instea d reported in metric tons of substance emitted or supplied (40 CFR 98.3(c)(4)). Appendix A of this memor andum lists the compounds that EPA is proposing to include in Table A-1, and their ne wly proposed GWPs.

Revisions to the GWPs affect the calculation of carbo n dioxide equivalents (CO 2 

### e) from facility emissions, and thus any increase in the GWPs o r 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 propo sed new or revised GWPs in Table A-1 to subpart A on the emissions reported and the e stimated number of new reporters that

### 4

would be required to report under each subpart if the propos ed 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 CO 2 

### e would change is described in Section 2 of this memorandum. The quality of data used in this analysis is discussed in Section 3 of thi s memorandum. A summary of cost and emissions impacts due to the proposed revisions is provided i n 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 methodologie s used to determine cost and emissions impacts to new reporters are described in Sect ion 6 of this memorandum.

2.0 IDENTIFICATION OF SUBPARTS AFFECTED BY THE PROPOSE D 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 emissi ons to eGRRT (or are expected to report their estimated emissions to eGRRT in the near fut ure). ERG categorized reporters as either associated with a source category that has alre ady reported to e-GGRT in 2010 and the reporting data are available, or a source category for whi ch emissions data are not available at the time of writing this memorandum. Each GHG source ca tegory, 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 Ca tegories

Subpart Source Category 2010 e - GGRT Reporting Data Available a

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 Ca tegories

Subpart Source Category 2010 e - GGRT Reporting Data Available a

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 Yes c

PP Suppliers of Carbon Dioxide Yes QQ Importers / Exporters of Equipment Pre

- charged with F

GHGs 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 wi ll 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 th e proposed new and revised GWPs) on 2010 and 2011 reporters associated with each of the GH G source categories identified in Table 2-1. The proposed new and revised GWPs would have no effect on subparts with CO 2 

### 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 CO 2. 

### Actual CO 2 

### emissions are not converted to CO 2 

### e, and thus GWP has no bearing on the emissions in these

### 6

cases. Similarly, although CO 2 

### , CH 4 

### , and/or N 2 

### O combustion emissions are required to be reported for subparts G, R, U, Z, CC, EE, and GG, the sol e emission type reported under these specific subparts is CO 2 

### process emissions (because combustion emissions are re quired to be reported under subpart C). Therefore, for purposes of this m emorandum, any change to combustion emissions associated with these subparts i s 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 affe ct 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 pro jected for subpart DD (Use of Electric Transmissions and Distribution Equipment) and subpart SS ( Electrical Equipment Manufacture) are assumed to be entirely SF 6 

### emissions; therefore, the assignment of GWPs for oth er 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 subp arts I, T, or QQ. The methodology ERG used to determine the impact of the proposed revisions to Ta ble 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 affecte d by the current GHG reporting rule, but will become subject to the rule as a result of revis ions to the GWPs in Table A-1. Affected subparts that might have new reporters due to the propo sed new and revised GWPs are those that meet all three of these criteria: 1) subpart has a re porting threshold 2 

### and the threshold is based on
CO 2 

### e, 2) subpart requires reporting of emissions of CH 4 

### , N 2 

### O, or a F-GHG, and 3) EPA estimates that all facilities in the subpart did not pr eviously 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 thre shold, because all applicable facilities are already reporting. Similarly, categories with thresholds not based on CO 2 

### e would not create new reporters resulting from a revised GWP (e.g., for subpart FF , underground coal mines, the
threshold is based on the annual volume of methane liberat ed from a mine). Also, if all facilities in the subpart are currently expected to exceed the 25,000 m etric tons of CO 2 

### e threshold (based on an evaluation of the supporting documents for each sub part), then ERG assumed that there would be no new reporters. In particular, all potential r eporters under subparts K, L, and QQ (importers only) are estimated to exceed the 25,000 metric tons of CO 2 

### e threshold, so no new reporters are expected for these subparts due to the new and revised GWPs. For subpart QQ

2 For some subparts, all facilities are required to repor t.

### 7

(exporters), all facilities are expected to exceed the 25, 000 metric tons of CO 2 

### e threshold with the exception of exporters of SF 6 

### electrical equipment. No additional SF 6 

### equipment exporters are expected to exceed the 25,000 metric tons of CO 2 

### e threshold because the GWP for SF 6 

### is decreasing.

ERG also assessed the type of emissions for each subpart . Subparts with CO 2 

### 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 s pecific gas(es) as compared to the heat trapped by CO 2. 

### Actual CO 2 

### emissions are not converted to CO 2 

### e, and thus GWP has no bearing on the outputs in these cases. Subparts with emi ssions solely from combustion experienced such small impacts from the GWP revisions th at they were not expected to trigger any additional reporters. For example, for coal burning, th ere is only a 0.024% increase in CO 2 

### e as a result of the change to the GWP of CH 4 

### and N 2 

### O emissions resulting from combustion, and for natural gas, there was 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 CO 2 EF (kg CO 2 /mmBTU) 103.50 53.02

B CH 4 EF (kg CH

4 /mmBTU) 1.10E

- 02 1.00E

- 03
C Current GWP for CH 4 21

D Revised GWP for CH 4 25

E N 2 O EF (kg N 2 O /mmBTU) 1.60E

- 03 1.00E

- 04

F Current GWP for N 2 O 310
G Revised GWP for N 2 O 298

H Current CH 4 CO 2 e (B*C) 0.231 0.021

I Revised CH 4 CO 2 e (B*D) 0.275 0.025

J Current N 2 O CO 2 e

(E*F) 0.496 0.031

K Revised N 2 O CO 2 e

(E*G) 0.477 0.030

L Current Total CO 2 e

(A+H+J) 104.23 53.072

M Revised Total CO 2 e

(A+I+K) 104.25 53.075

Percent Change ((M-L)/L) 0.024% 0.005%

### 8

ERG does not anticipate that the addition of F-GHGs t o Table A-1 of subpart A will result in any new reporters. Assigning GWPs to additiona l F-GHGs would only potentially affect reporters covered under the subparts that require calculatio n of emissions of F-GHGs (i.e., subparts I, L, T, DD, OO, QQ, and SS).

For subpart I, facilities that manufacture semiconducto rs, liquid crystal displays (LCDs), and micro-electromechanical systems (MEMS) must calcu late annual emissions for threshold applicability purposes considering only the gases for which def ault emission factors are provided in Table I-1 to subpart I. Facilities must account for F-H TF emissions as a percentage of the total annual production process emissions at a facility (calcul ated 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 pr oposing to add to Table A-1 to subpart A. Therefore, there are no additional PV facilities th at will report as a result of the change.

As noted in Table 2-3 all facilities subject to subpart L a nd QQ are expected to be above the reporting threshold, therefore there are no additio nal 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 Transmiss ions and Distribution Equipment) and subpart SS (Electrical Equipment Manufacture) are assu med to be entirely SF 6 

### emissions; therefore, the assignment of GWPs for other F-GHGs wo uld have no effect on reporters under subpart DD and SS.

For subpart T (Magnesium Production), EPA is proposing to a dd 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 th e additional F-GHG. As described in Section 5.6, because FK-5-1-12 is used as an alternative to the high- GWP gas SF 6 

### (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 rep ort as a result.

For subpart OO (Industrial GHG Suppliers), EPA identified t he 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 electro nics 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 c ompounds to Table A-1. Table 2-3 lists all of the GHG reporting rule subparts and the rational e for including or excluding the subpart in the new reporter cost impact analysis described in Secti on 6 of this memorandum.

### 9 Table 2-3. Rationale for GHG Subpart Selection for New R eporter 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 CO 2 e
E

- Adipic Acid Excluded All facilities must report

- no threshold

F

- Aluminum Excluded All facilities must report

- no threshold
G

- Ammonia Excluded All facilities must report

- no threshold

H

- Cement Excluded All facilities must report

- no threshold

I - Electronics Included Threshold category that emits mainly fluorinated GHG

K

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

L

- Fluorinated Gas Excluded All facilities in subpart expected to be above thre sh old

N

- Glass Excluded CO 2 and/or combustion emissions only
O

- HCFC

- 22, HFC

- 23 Excluded Threshold not based on CO 2 e
P

- Hydrogen Excluded CO 2 and/or combustion emissions only Q

- Iron & Steel Excluded CO 2 and/or combustion emissions only

R

- Lead Excluded CO 2 and/or combustion emissions only
S

- Lime Excluded All facilities must report

- no threshold

T - Magnesium Included Threshold category that emits mainly fluorinated GHG

U

- Carbonate Excluded CO 2 emissions only

V

- Nitric Acid Excluded All facilities must report

- no threshold

W - Petroleum & Natural Gas Included Threshold category that emi ts 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 CO 2 e
EE

- Titanium Dioxide Excluded All facilities must report

- no threshold

FF

- Underground Coal Mines Excluded Threshold not based on CO 2 e GG

- Zinc Excluded CO 2 and/or combustion emissions only

### 10 Table 2-3. Rationale for GHG Subpart Selection for New R eporter Impact Analysis

Subpart Excluded / Included in New Reporter Impact Analysis Rationale

HH - MSW Landfills Included Threshold category that emits mostl y methane

II - Industrial Wastewater Included Threshold is based on methane g eneration

JJ

- Manure Mgmt Excluded Subpart is not being implemented

LL

- Coal

- based Liquid Fuels Suppliers Excluded CO 2 emissions only

MM

- Petroleum Suppliers Excluded CO 2 emissions only

NN

- Natural Gas Suppliers Excluded Threshold not based on CO 2 e

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

PP

- CO 2 Suppliers Excluded CO 2 emissions only QQ

- Importers / Exporters of F

gases in pre-charged equipment or closed-cell foams Excluded Threshold category and all importers/exporters in the category are expected to be above threshold a

RR

- Geologic Sequestration Excluded All facilities must report

- no threshold
SS

- Electrical Equipment Excluded Threshold not based on CO 2 e

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

UU

- CO 2 Injection Excluded All facilities must report

- no threshold

a Some facilities with SF 6 containing electrical equipment were below the threshold; SF 6 GWP is decreasing, therefore no additional affected facilities.



### 3.0 DATA QUALITY FOR SUBPARTS EVALUATED This analysis relied on data developed for the initial eco nomic impact assessment of the 2009 GHG reporting rule. The data used to perform this evaluat ion 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 e conomic analysis was available. Emissions estimates and facility lists wer e updated using the proposed new or revised GWP for each facility identified as a pote ntial 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 estimat e of emissions and the number of facilities potentially affected by the proposed n ew or revised GWP was

### 11 made using summary data available in the technical support doc uments 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 econo mic impact assessment were not available, or a complete list of potential re porters for a subpart was not developed as part of the original economic impacts assess ment for the GHG reporting rule; therefore, this assessment of GWP impact s 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-GG RT emissions data is available, the data quality is rated “A”. For subparts tha t 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/B a



### 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 Pre

charged with F-GHGs 

### C

SS

- Electrical Equipment A

TT

- Industrial Waste Landfills C

a S ix 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 r esult 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 Rep orters

Subpart Quality Level
I

– Electronics A

T

– Magnesium B
W

- Petroleum & Natural Gas A/B a



### HH

- MSW Landfills A

II

- Industrial Wastewater C
OO

- Industrial GHG Suppliers B
TT

- Industrial Waste Landfills C

a S ix 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 i ncrease of 2,000,000 metric tons of
CO 2 

### e 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 emi ssions. Subpart W (Oil and Gas), and subpart HH (MSW Landfills), have the highest cost impac ts and the highest amount of expected additional reported emissions.

The emissions and cost impacts resulting from the prop osed 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 r eport 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 antic ipated. The tables include the estimated changes to the number of affected facilities and expecte d emissions reported; details can be
found in the Excel workbook associated with this memoran dum that is entitled “GWP ChangeImpact Analysis Summary.” Figure 4-1 presents the emissions impacts for all subparts.13Table 4-1. 2010 Reporters - Summary of Impacts Due to GWP Revisions for Source Categories Reporting in 2010SubpartTotalNumber ofFacilities inSourceCategoryNumber ofReportersPrior toGWPRevisionsNumber ofReportersAffected byGWPRevisions2010 TotalEmissions Priorto GWPRevisions(non-biogenic)(metric tonsCO2e per year)IncrementalCost Impactfor NewReporters(in 2011$per year)IncrementalEmissions forNew Reporters(metric tonsCO2e peryear)2010 EmissionsAfter GWPRevisions(metric tonsCO2e per year)Emissions for2010 and NewReportersCombined AfterGWP Revisions(metric tonsCO2e per year)Total Changein EmissionsDue to GWPRevisions(metric tonsCO2e peryear)C 350,000 4,211 4,211 619,572,472 0 0 619,684,811 619,684,811 112,339D3,243b1,263 1,263 2,231,408,653 0 0 2,231,701,929 2,231,701,929 293,276E 4 2 2 4,397,310 0 0 4,227,092 4,227,092 (170,218)F 14 9 9 4,298,897 0 0 4,581,938 4,581,938 283,040G 24 22 0 13,596,985 0 0 13,596,985 13,596,985 0H 107 97 97 42,734,686 0 0 42,737,342 42,737,342 2,657K 9 10 10 2,240,907 0 0 2,242,650 2,242,650 1,743N 374 103 103 2,061,679 0 0 2,061,679 2,061,679 0O 5 5 5 6,351,797 0 0 8,034,752 8,034,752 1,682,955P 101 101 101 31,261,120 0 0 31,261,130 31,261,130 10Q 130c123 123 27,094,226 0 0 27,094,205 27,094,205 (21)R 27d12 0 588,209 0 0 588,209 588,209 0S 89 70 70 15,566,816 0 0 15,566,989 15,566,989 174U NA 19 0 122,663 0 0 122,663 122,663 0V 45 36 36 11,990,739 0 0 11,526,582 11,526,582 (464,158)X 88 63 63 9,445,122 0 0 9,457,094 9,457,094 11,973Y 150 145 145 55,751,060 0 0 55,851,755 55,851,755 100,695Z 14 13 0 1,080,913 0 0 1,080,913 1,080,913 0AA 425 110 110 7,562,923 0 0 7,613,331 7,613,331 50,408BB 1 1 1 122,466 0 0 124,607 124,607 2,141CC 5 4 0 1,221,863 0 0 1,221,863 1,221,863 014Table 4-1. 2010 Reporters - Summary of Impacts Due to GWP Revisions for Source Categories Reporting in 2010SubpartTotalNumber ofFacilities inSourceCategoryNumber ofReportersPrior toGWPRevisionsNumber ofReportersAffected byGWPRevisions2010 TotalEmissions Priorto GWPRevisions(non-biogenic)(metric tonsCO2e per year)IncrementalCost Impactfor NewReporters(in 2011$per year)IncrementalEmissions forNew Reporters(metric tonsCO2e peryear)2010 EmissionsAfter GWPRevisions(metric tonsCO2e per year)Emissions for2010 and NewReportersCombined AfterGWP Revisions(metric tonsCO2e per year)Total Changein EmissionsDue to GWPRevisions(metric tonsCO2e peryear)EE 87 0 1,447,634 0 0 1,447,634 1,447,634 0GG 96 0 730,209 0 0 730,209 730,209 0HH 7,8021,202 1,259 107,000,000 137,500 1,560,000 108,227,153 109,787,153 2,787,153MM NA155 0 2,493,881,410 0 0 2,493,881,410 2,493,881,410 0NN NA476 0 909,000,000 0 0 909,000,000 909,000,000 0OO 351167 170 254,554,000 10,500 75,000 298,539,000 298,614,000 44,060,000TOTAL 363,0258,432 7,778 6,855,084,759 148,000 1,635,000 6,902,203,925 6,903,838,925 48,754,166aNumber of facilities is from the proposed rule fromApril 10, 2009 unless otherwise indicated.bFrom RIA EPA–HQ–OAR–2008–0508–046.cOriginally estimated as 3, number of actual reporters indicates otherwise.dOriginally estimated as 77, number of actual reportersindicates otherwise.15Table 4-2. 2011 Reporters-- Summary of Emissions Impacts Dueto GWP Revisions forSource Categories With Initial Report Required in 2011 (datanot yet available)SubpartTotalNumber ofFacilities inSourceCategoryNumber of2011ReportersPrior toGWPRevisionsNumber ofReportersAffected byGWPRevisionsTotal EmissionsFrom 2011Reporters Priorto GWPRevisions(non-biogenic)(metric tonsCO2e per year)IncrementalCost Impactfor NewReporters(in 2011$per year)IncrementalEmissions forNew Reporters(metric tonsCO2e peryear)Emissions for2011 ReportersAfter GWPRevisons(metric tonsCO2e per year)Emissions for2011 and NewReportersCombined AfterGWPRevisions(metrictons CO2e peryear)Total Changein EmissionsDue to GWPRevisions(metric tonsCO2e peryear)I 216 94 98 5,622,570 88,900 18,076 6,657,398 6,675,474 1,052,905L 14 14 14 10,600,000 0 0 11,660,000 11,660,000 1,060,000T 13 11 11 1,067,000 0 0 1,029,787 1,029,787 (37,213)W 29,530 2,786 2,885 337,000,000 860,000 2,572,881 375,563,940 378,136,821 41,136,821DD 1,364 141 141 10,320,000 0 0 9,845,021 9,845,021 (474,979)FF 612 114 114 33,823,404 0 0 40,265,957 40,265,957 6,442,553II 444 244 246 5,845,000 10,300 59,500 6,958,333 7,017,833 1,172,833JJ NA 0 0 0 0 0 0 0 0LL NA 0 0 0 0 0 0 0 0PPaNA 99 0 33,500,000 0 0 33,500,000 33,500,000 0QQ 108 108 108 21,907,182 0 0 23,822,182 23,822,182 1,915,000RR 10 10 0 7,162,885 0 0 7,162,885 7,162,885 0SS 10 10 10 814,128 0 0 776,658 776,658 (37,470)TT 369 200 219 13,700,000 87,300 520,000 16,309,524 16,829,524 3,129,524UU 92 92 0 48,735,442 0 0 48,735,442 48,735,442 0TOTAL 32,782 3,923 3,846 530,097,611 1,046,500 3,170,457 582,287,127 585,457,584 55,359,974aSubpart PP included in this table although reporting was required in 2010 because data is not available.16Table 4-3. 2010, 2011, and New Reporters -- Summary of ImpactsDue to GWP Revisions for All Source CategoriesSubpartTotalNumberofFacilitiesin SourceCategoryNumber ofReportersPrior toGWPRevisionsNumber ofReportersAffectedby GWPRevisionsTotalEmissionsPrior to GWPRevisions(non-biogenic)(metric tonsCO2e peryear)IncrementalCost Impactfor NewReporters(2011$per year)IncrementalEmissions forNewReporters(metric tonsCO2e peryear)Emissions forReportersAfter GWPRevisions(metric tonsCO2e peryear)Emissions forCurrent andNew ReportersCombinedAfter GWPRevisions(metric tonsCO2e peryear)TotalChange inEmissionsDue to GWPRevisions(metric tonsCO2e peryear)2010ReportersTotal363,025 8,432 7,778 6,855,084,759 148,000 1,635,000 6,902,203,925 6,903,838,925 48,754,1662011ReportersTotal32,782 3,923 3,846 530,097,611 1,046,500 3,170,457 582,287,127 585,457,584 55,359,974TOTAL395,807 12,355 11,624 7,385,182,369 1,194,500 4,805,457 7,484,491,052 7,489,296,509 104,114,13917

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 0-60006001,2001,8002,4003,0003,6004,2004,8005,400

C D E F G H I K L N O P Q R S T U V W X Y Z AA BB CC DD EE FF GG HH II JJ LL MM NN OO PP QQ RR SS TT UU040,00080,000120,000160,000 **Thousand Metric Tons of CO 2**  **e Subpart** 

**Thousand Metric Tons of CO 2**  **e Figure 4-1. Emissions Impacts by Subpart Due to Table** **A-1 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 CO 2 e 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 18 4 4,8 05 ,457 1, 194 , 5 00



### 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 entiti es already required to report. A detailed discussion of the cost impact to small entities is inc luded in the individual subpart analyses for new reporters in section 6.0 of this memorandum. For eac h affected subpart that may have new reporters due to the revised GWPs, we used information availa ble in supporting documents to identify the small businesses affected, and an impact ev aluation 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 fo r reporting year 2010 or 2011, there would be no significant cost impacts resulting from the pr oposed new and revised GWPs. Although some affected facilities and suppliers would report higher CO 2 

### e emissions in their annual GHG report, using the proposed new and revised GWPs wo uld 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 th e 2010 reported GHG emissions, to the extent that the reported data were available. Em issions 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 wit h reporting year 2011 and therefore data is not yet available, and 2010 subparts for which the 2010 emiss ion verification process had not

### 19

been completed by EPA), and for subparts affected by the n ew 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 develo ped 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 m ethodology, 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 ne w 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 we re available, ERG used the 2010 reporting year data to calculate the emissions im pacts of the proposed revised GWPs. ERG began by extracting the reported emissions of each GH G (CO 2 

### , CH 4 

### , N 2 

### O, 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 num ber 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 th e current GWP (see 40 CFR part 98, subpart A, Table A-1) to determine the original reported e missions of each GHG in metric tons
of CO 2 

### e. To calculate the emissions impacts (due to the revised GWPs) for each source category (in metric tons of CO 2 

### e) ERG multiplied the mass emissions for each GHG by the difference between the existing GWP and the proposed revised GWPs fro m the IPCC AR4. For some subparts, Table 4-1 shows no impact of the GWP changes. A lthough CO 2 

### , CH 4 

### , and N 2 

### O combustion emissions are required to be reported for sub parts G, R, U, Z, CC, EE, and GG, the sole emission type reported under these specific subparts is CO 2 

### process emissions (because combustion emissions are required to be reported under s ubpart C and there are no CH 4 

### or N 2 

### O process emissions for these subparts). Therefore, for purposes of this analysis, any change to combustion emissions associated with these subparts i s 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 n o effect on subparts MM and NN, because CO 2 

### is the only GHG required to be reported. With the excepti on 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 th e F-GHGs that were revised in Table A-1 to the IPCC AR4 values. Emission impacts were not calcul ated for the chemicals that are proposed to be added to Table A-1 because this data is not publicl y 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 i dentified the number of facilities that would be covered under subpart I with a 25, 000 metric tons CO 2 

### e emissions-based threshold. For LCDs and PVs, EPA calculated the total a nnual emissions, in metric tons of CO 2 

### e, for each facility using the IPCC Tier 1 default emission s factors. The emissions factors were
converted to metric tons of CO 2 

### e basis by multiplying the factors by the appropriate GWP v alue. EPA used the results to estimate the magnitude of emissio ns from those facilities expected to emit greater than the 25,000 metric tons CO 2 

### e threshold. The number of, and emissions from, MEMS facilities were calculated using the same procedure, but with an emission factor developed by the EPA (U.S. EPA, 2010j).

In the original analysis, EPA used the same procedure descr ibed above (i.e., default IPCC Tier 1 factors) to determine the number of semiconductor f acilities that were expected to emit greater than the 25,000 metric tons CO 2 

### e threshold. To estimate the magnitude of emission from those semiconductor facilities expected to emit greater t han the threshold, EPA used emission estimations that were derived using outputs from the EPA P FC Emissions Vintaging Model (PEVM), as well as the EPA PFC Reduction/Climate Part nership for Semiconductors partner and non-partner shares of U.S. emissions. EPA also account ed 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 E PA’s original threshold analysis 3 

### with the updated GWP values. ERG was not able to access t he PEVM to reproduce the original emission estimates; therefore, we assumed that the P EVM based emissions would increase by the same percentage as the emissions estimated using the IPC C 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 onl y 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 P EVM, we assumed that the addition of new F-GHGs to Table A-1would not affect the emissions reported by exist ing reporters for semiconductors. We note that Table I -3 to subpart I includes emission factors for C 4 F 8 O for semiconductor manufacturing for 150mm and 200mm wafers sizes; however, in the report titled “2010 ISMI Semiconduct or Greenhouse Gas (GHG) Reporting Rule Survey Results” published by International SEMATECH Manufacturing Init iative (ISMI Technology Transfer #10065097A-TR) Table 2 on page 13 indicates that consumption of C 4 F 8 O 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 me morandum that is entitled “Subpart I GWP Impact Analysis.” The emissions that are attribut ed 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 t o 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 estim ates 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-GH Gs and f-HTFs are included in the subpart A tables. However, because consumption and emiss ions 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 Ga s Production) and subpart QQ (Imports and Exports of Equipment Pre-charged with Fluo rinated 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 m emorandum 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 ava ilable for this analysis.
Information was available for the total number of facil ities expected to report under subpart L
and for the total emissions in terms of CO 2 

### e expected (U.S. EPA, 2010b).

From the original rulemaking docket, projected emissions for subpart QQ were available for HFCs (as total CO 2 

### e) and for SF 6 

### in electrical equipment (U.S. EPA, 2010c). For subpart QQ

, emission impacts due to the revised GWP for SF 6 

### were calculated by multiplying the total

### 22

expected emissions of SF 6 

### by the difference between the existing GWP and the IPCC AR4 GWP (22,800 – 23,900).

Because there are 17 different fluorinated compounds for whi ch 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 t he expected increase in emissions due to new and revised GWPs for fluorinated compounds. This estim ated 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 appro ximately 75% of the fluorinated gas emissions of HFCs and PFCs used as substi tutes for ozone depleting substances (U.S. EPA, 2012b).

Further justification for a nominal 10% increase for subpa rt 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 fluorinat ed and a default of 2,000 for other fluorinated gases when calculating emissions in CO 2 

### e for gases not listed in Table A-1 to subpart A. Of the 26 additional fluorinated GHGs which EPA is propo sing 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
CO 2 

### e emissions as a result of the inclusion of the addit ional 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 SF 6 

### and HFC-134a. ERG used information from the threshold analysis for the original rule and updated data from the EPA’s SF 6 

### Emission Reduction Partnership for the Magnesium Industry to determi ne the expected number of reporters for this subpart. The threshold analysis for t he magnesium production category for the original rule is summarized in “Additional Methodologic al Information Supporting Threshold Analysis for Specific Source Categories” (hereafter r eferred to as “2010 Threshold Analysis”) (U.S. EPA, 2009). Based on the 2010 Threshold Analysis, the m agnesium production and processing source category was composed of 13 nationwide fac ilities, with 11 facilities meeting the 25,000 mtCO2e threshold. The 2010 Threshold analysis utiliz ed 2006 annual reporting data on metal production and SF 6 

### consumption provided through the SF 6 

### Emission Reduction Partnership.

ERG received updated data from the SF 6 

### 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 emiss ions of SF 6 

### were available for this

### 23

analysis. Emissions data from other gas usage were not available. In the 1990s, EPA operated the
SF 6 

### Emission Reduction Partnership for the Magnesium Industry to encourage reductions in the GHG emissions associated with magnesium production, whi ch were largely based on usage of
SF 6 

### . Partners in the program agreed to implement practices t o reduce SF 6 

### emissions, prepare corporate-wide annual inventories of SF 6 

### emissions, and eliminate the usage of SF 6 

### as a cover gas. Based on the 2010 SF 6 

### Partnership data, 16 facilities reported, and 11 facilities reported use
of SF 6 

### . This is close to the original estimate of 13 processing f acilities in the 2010 Threshold Analysis. Five facilities reported zero emissions of SF 6 

### in the Partnership data; it was assumed that although these facilities may use other F-GHG, th ey would be unlikely to meet the 25,000 mtCO2e threshold and report in 2011 due to the reduced GWPs of t hese compounds (see section 6.2 of this memorandum). Therefore, ERG assumed that only the 11 facilities would report in
2011.

Facilities participating in the SF 6 

### Reduction program have gradually converted to the usage of FK 5–1–12 (proposed GWP=1.8) and HFC-134a (proposed GWP=1,430) a s alternatives
to SF 6 

### as a cover gas. Therefore, ERG assumed that the 11 faci lities reporting SF 6 

### usage through
the EPA’s SF 6 

### Magnesium Partnership are using FK 5–1–12, HFC-134a, or alternat ive cover gases in addition to the SF 6 

### reported. There is no available data on the total gas co nsumption of these alternative cover gases. Because FK-5-1-12 is a lo w-GWP gas with a proposed GWP of 1.8, ERG assumed that the addition of FK-5-1-12 to Table A-1 w ould not significantly change
the CO 2 

### e emissions reported by existing reporters. Facilities cur rently report emissions of FK-5- 1-12 in metric tons; under the proposed rule, they would be r equired to report these emissions as
metric tons CO 2 

### e. Instead, ERG conservatively examined how the increas e in the GWP of the high-GWP gas, HFC-134a, would affect emissions from 2011 report ers. To determine how the proposed increase in the GWP for HFC-134a would affect cal culated emissions, ERG first characterized industry emissions of HFC-134a from the 2010 Par tnership data, taking into account the industry decrease in SF 6 

### usage and increase in HFC-134a usage. The total SF 6 

### emissions reported through the Partnership showed a 67% indus try-wide reduction in emissions
from 2006 to 2010. Because no HFC-134a emissions data is availa ble for subpart T, ERG estimated the expected 2010 industry emissions of HFC-134a prior to the GWP change using the
2006 and 2010 SF 6 

### emissions data and assuming that SF 6 

### reductions in the industry from 2006 to 2010 were achieved by substituting HFC-134a for SF 6 

### as a cover gas. ERG then summed the estimated 2010 HFC-134a industry emissions and the reported 2010 SF 6 

### emissions from the Partnership data to determine total expected industry emissio ns prior to the GWP revisions. Expected industry emissions from the GWP revisions were estimated by multiplying the 2010
SF 6 

### emissions data and the estimated 2010 HFC-134a emissions by th e change in GWP for SF 6 

### and HFC-134a, respectively. If facilities were to conver t from SF 6 

### to FK-5-1-12 (proposed GWP=7), the anticipated emissions would be expected to be ev en lower.

### 24 Table 5-2. Summary of Subpart T Emissions Impacts Due t o the Revised GWP

Number of Expected Reporters Prior to Revised GWP Estimated HFC

134a Industry Emissions from 2011 Reporters (metric tons CO 2 

### e 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 1,0 29

, 787

a Estimated 2010 HFC

- 134a Industry Emissions = (2006 Reported SF 6 Emissions

– 2010 Reported SF 6 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 SF 6 Emissions (from Partnership data)

c Emissions for 2011 Reporters at Revised GWP = (2010 SF 6 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 subpar t 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 contain ed source-specific emissions data for
CO 2 

### , CH 4 

### , and N 2 

### O. ERG applied the revised GWPs to the source specific emis sions data for each subpart W industry segment facility list.

Table 5-3. 2011 Reporters — Summary of Emissions Impacts Due t o GWP Revisions for Subpart W Industry Segments

Industry Segment Number of 2011 Reporters Prior to Table A-1 Revisions a 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 Storage c 33 NA 825,000 LNG Import/Export 4 NA 2,049,792
NG Distribution c 143 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 prov ided in the EIA for subpart W (U.S. EPA, 2010d).

b Total emissions for expected reporters is based on an es timate 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 we re estimated by multiplying the number of expected

### 25

Table 5-3. 2011 Reporters — Summary of Emissions Impacts Due t o GWP Revisions for Subpart W Industry Segments

Industry Segment Number of 2011 Reporters Prior to Table A-1 Revisions a 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 Storage c 33 NA 825,000 LNG Import/Export 4 NA 2,049,792 reporters in these two industry segments by 25,000 metric tons CO 2 e because ERG assumed the reporters would only just meet the 25,000 metric tons CO 2 e 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 Equipme nt Manufacture) in the Technical Support Documents (U.S. EPA, 2010e , 2010f, 2010g) are assumed to be entirely SF 6 

### emissions. This assumption was made because the majority of elect rical equipment is filled with SF 6 

### , although perfluorocarbons are used in small quantities as d ielectrics and heat transfer fluids in power transformers. This analysis used the information a vailable in the Technical Support Document for Subpart DD and SS to estimate the number of facilities expected to report and the
total emissions of SF 6 

### from expected reporters. Emission impacts due to the revise d GWP for
SF 6 

### were calculated by multiplying the total expected emissions of SF 6 

### 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 (Undergro und 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 emi ssions as stated in the Technical Support Document (U.S. EPA, 2010h) for subpart FF was used for t his 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 exi sting GWP and the revised GWP (25 - 21 = 4).

5.8 Subpart II Emissions Impacts - 2011 Reporters Emissions of methane are reported under Subpart II (Industri al Wastewater Treatment)
for those industrial wastewater treatment facilities that use anaerobic treatment or sludge digestion. Information for the number of anticipated re porters 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 S ection 6.5 of this memorandum for a complete description of the revised methodology for esti mating emissions). Emission impacts due to the revised GWP for methane were calculated by mult iplying the total expected emissions of methane by the difference between the existing GWP a nd the revised GWP (25 - 21 = 4).

5.9 Subparts LL, PP, RR, and UU Emissions Impacts - 2011 Report ers The revised GWPs will have no effect on subparts LL, PP, RR, and UU because CO 2 

### is the sole emission type required to be reported for thes e subparts. GWP is a measure of the heat trapped by specific gas(es) as compared to the heat trapped by CO 2 

### . Actual CO 2 

### emissions are
not converted to CO 2 

### 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 show s emissions impacts for source categories for which 2010 e-GGRT data were availabl e, Table 5-5 shows emissions impacts for source categories for which information othe r than the 2010 e-GGRT data were used, and Table 5-6 shows emissions impacts for all source categ ories for a total impact assessment). Additional details are provided in the Excel workbook asso ciated with this memorandum that is entitled “GWP Change - Impact Analysis Summary.”

Table 5-4. 2010 Reporters — Summary of Emissions Impacts Due t o GWP Revisions for Source Categories With Reporting Data Available from 2010 Reportin g Year

Subpart Number of 2010

Reporters Prior to Revised GWP 2010 Reported

Emissions Prior to GWP Revisions (non-biogenic) (metric tons CO 2 e per year) 2010 Reported Emissions After GWP Revisions (metric tons CO 2 e per year) Change in Emissions

Due to GWP Revisions from 2010 Reporters (metric tons CO 2 e 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 t o GWP Revisions for Source Categories With Reporting Data Available from 2010 Reportin g Year

Subpart Number of 2010

Reporters Prior to Revised GWP 2010 Reported

Emissions Prior to GWP Revisions (non-biogenic) (metric tons CO 2 e per year) 2010 Reported Emissions After GWP Revisions (metric tons CO 2 e per year) Change in Emissions

Due to GWP Revisions from 2010 Reporters (metric tons CO 2 e 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 t o 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 CO 2 e per year) Emissions

for 2011 Reporters After GWP Revisions (metric tons CO 2 e per year) Change in Emissions

Due to GWP Revisions from 2011Reporters (metric tons CO 2 e 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 t o 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 CO 2 e per year) Emissions

for 2011 Reporters After GWP Revisions (metric tons CO 2 e per year) Change in Emissions

Due to GWP Revisions from 2011Reporters (metric tons CO 2 e per year) II 244 5,845,000 6,958,333 1,113,333

JJ 0 0 0 0

LL 0 0 0 0

PP a 99 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 r equired 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 CO 2 e per year) Total Emissions at Revised GWP (metric tons CO 2 e per year) Change in

Emissions (metric tons CO 2 e 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 Mandator y Reporting of Greenhouse Gas Emissions F-Gases: Subparts I, L, DD, QQ, SS. Available at: http://www.epa.gov/climatechange/emissions/downloads10/F-gas_E IA.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 E xports of Fluorinated Greenhouse Gases in Pre-charged Equipment and Closed-cell Foams, M andatory Reporting of Greenhouse Gases: Additional Sources of Fluorinated Greenhouse Gases, Revised September 2010. Available at: http://www.epa.gov/climatechange/emissions/downloads10/Subpart-Q Q_TSD.pdf
U.S. EPA, 2012b. Inventory of U.S. Greenhouse Gas Emissions a nd Sinks: 1990-2010, April 2012. http://epa.gov/climatechange/Downloads/ghgemissions/US-GHG-Inven tory-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: E PA– 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_E IA.pdf
U.S. EPA, 2010f. Technical Support Document for Process Emi ssions of Sulfur Hexafluoride (SF6) and PFCs from Electric Power Systems: Proposed Rule for Man datory 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. Ava ilable at: http://www.epa.gov/climatechange/emissions/downloads10/Subpart-S S_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-F F_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 Emis sions From Magnesium Production and Processing: Proposed Rule for Mandatory Reporting of G reenhouse 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 Emis sions from Electronics Manufacture (e.g., Micro-Electro-Mechanical Systems, Liquid Crys tal 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 S ection 2.2, ERG does not expect that the new GWPs proposed to be added to Table A-1 to subpar t A will result in any new reporters with the exception of subpart OO. An addition al 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 facil ities. 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 ea ch 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 numbe r of affected facilities. For “threshold” categories, EPA estimated the number of fac ilities that exceeded the annual emission-based threshold of 25,000 metric tons CO 2 

### e.
For this analysis, ERG used the costs developed for the or iginal GHG reporting rule, and multiplied the individual facility cost by the number o f additional facilities that did not previously exceed the threshold, but will exceed the thres hold after the proposed revisions to
Table A-1.

For this analysis, ERG used several data sources to ide ntify additional affected facilities in each subpart. Information from industry surveys, public ly available data sources, and existing data from EPA, states, and industry trade associations w ere 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, E PA determined the reporting costs by assigning model facility costs to individual facilities i n the respective industry segment based on
relative size.

Summaries of the methodology, reference documents, and a ny assumptions specific to each subpart are documented in the following individual sub part sections of this section.

6.1 Subpart I (Electronics Manufacturing) Impacts - New Report ers Subpart I requires reporting of fluorinated GHGs from the f ollowing source categories that emit 25,000 metric tons CO 2 

### e per year or more: electronics manufacturing including manufacture of semiconductors, PVs, LCDs, and MEMS. Cha nges to the following GWPs affect subpart I: CF 4 

### , C 2 

### F 6 

### , CHF 3 

### , C 3 

### F 8 

### , SF 6 

### , C 6 

### F 14 

### (semiconductors); SF 6 

### (MEMS); CF 4 

### , SF 6 

### (LCDs);
and CF 4 

### , C 2 

### F 6 

### (PVs). As discussed in Section 5.2, ERG has assumed t hat 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 add ition 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 calc ulate annual emissions for threshold applicability purposes considering only the gases for which def ault 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 pro cess emissions at a facility (calculated based on gases in Table I-1.)

By revising the GWP values in subpart A, four additional n on-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 entit ies.

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 CO 2 

### e emissions-based threshold. The original threshold analysis included a li st of facilities for each product type (e.i., semiconductors, MEMS, LCDs, and PVs) and estimates of su bstrate area processed and total annual emissions for each facility.

For LCDs and PVs, EPA calculated the total annual emissi ons, in metric tons of CO 2 

### e, for each facility using the IPCC Tier 1 default emission s factors. The emissions factors were
converted to metric tons of CO 2 

### e basis by multiplying the factors by the appropriate GWP v alue.
EPA evaluated the results to determine which facilities were expected to emit greater than the 25,000 metric tons CO 2 

### e threshold. EPA also used the results to estimate the magnitude of emissions from those facilities expected to emit great er than the 25,000 metric tons CO 2 

### e threshold. The number of, and emissions from, MEMS fac ilities 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 descr ibed above (i.e., default IPCC Tier 1 factors) to determine the number of semiconductor f acilities that were expected to emit greater than the 25,000 metric tons CO 2 

### e threshold. EPA did not consider emissions from heat transfer fluids when determining which semiconductor faci lities would meet the threshold. To estimate the magnitude of emission from those semiconduc tor 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 Partne rship for Semiconductors partner and non-partner shares of U.S. emissions. EPA also account ed 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 no w 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 t he PEVM to reproduce the original emission estimates; therefore, we assumed that the P EVM based emissions would increase by the

### 32

same percentage as the emissions estimated using the IPC C 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 wi th 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 Impa ct 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 do cket (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 Bure au of Labor Statistics Labor Index and the Chemical Engineering Plant Cost Index (CEPCI), r espectively. 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 Index a (Ratio to year 2004)

2006 1.06416

2011 1.18387
Labor Cost Adjustment Factor 1.11249
Chemical Engineering Plant Cost Index b

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 c osts for monitoring, reporting, and recordkeeping for each facility type (i.e., non-semiconductor facilities, large semiconductor facilities, and non-large semiconductor fac ilities) by estimating the number of labor hours necessary to comply with the subpart I re quirements. EPA then multiplied the labor hour requirements by the appropriate loaded hourly rate to dete rmine the total labor costs. A capital and operations and maintenance (O&M) cost compone nt was calculated for large semiconductor facilities. The capital and O&M cost incl uded the development and maintenance of apportioning software and emission factors. EPA determine d 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 aff ected by the change in GWPs (described in Section 6.1.1), final cost impacts were deter mined by multiplying the number of additional facilities by the updated facility cost for ea ch facility type (i.e., non-semiconductor facilities, large semiconductor facilities, and non-lar ge 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 2d a (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 t o 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 CO 2 e per year) a Incremental

Emissions For New Reporters (metric tons of CO 2 e 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

Non

Semiconductor 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 al l small entities in the electronics manufacturing industry by calculating a cost-to-sales rati o for six enterprise size ranges (i.e., 1 to 20 employees, 20 to 99 employees, 100 to 499 employees, 500 to 749 emp loyees, 750 to 999

### 34

employees, and 1,000 to 1,499 employees) using the average tota l annualized mandatory reporting costs to the average annual sales receipts for e ach establishment. The results of this analysis are represented in Table 14 of the preamble for t he 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 conserva tively high analysis. EPA determined that no significant small business economic impacts were ex pected to occur. The analysis showed that the cost-to-sales ratio for all entity sizes e xcept for the smallest sized enterprises was less than 1 percent. EPA concluded that although the cost-to-s ales ratio for the 1 to 20 employee range for semiconductor and related device manufacturing was greater than one percent (i.e., 1.16 percent); facilities with emissions greater than 25,000 metric tons CO 2 

### e per year are unlikely to be included in the 1 to 20 employees size cate gory (U.S. EPA, 2010a).

The revised emission estimates (using the revised GWPs) p lace the 4 new affected facilities above the 25,000 metric tons CO 2 

### e threshold. In addition, the emission estimates for t he 4 facilities in the original threshold analysis were j ust slightly below the threshold (3 to 10 percent). Based on EPA’s conclusion that facilities w ith emissions greater than 25,000 metric
tons CO 2 

### e per year are unlikely to be included in the 1 to 20 emplo yees size category, ERG does not expect the 4 additional facilities to be included in t he 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 Mandator y Reporting of Greenhouse Gas Emissions F-Gases: Subparts I, L, DD, QQ, SS Final Report. See Do cket 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 Emis sions from Electronics Manufacture (e.g., Micro-Electro-Mechanical Systems, Liquid Crys tal 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 a s any site where magnesium metal is produced through smelting (including electrolytic sme lting), 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 product ion or processing: SF 6 

### , HFC-134a, the fluorinated ketone FK 5-1-12, CO 2 

### , and any other fluorinated GHG as defined in the greenhouse gas reporting rule.

The change of GWP for HFC-134a from 1,300 to 1,400, the change of GWP for SF 6 

### from 23,900 to 22,800, and the addition of a GWP of 7 for FK-5-1-12 is no t anticipated to result in additional facilities subject to subpart T. Therefore, t here 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 Thre shold Analysis for the magnesium production category for the original rule (U.S. EPA, 2009), identified 13 nationwide facilities in the magnesium production and processing so urce category. EPA evaluated a range of threshold options for these facilities, utilizing 2006 annual reporting data on metal production
and SF 6 

### consumption provided through the EPA’s SF 6 

### Emission Reduction Partnership for the Magnesium Industry as the basis for the analysis. The se included emission-based thresholds of 1,000, 10,000, 25,000 and 100,000 metric tons CO 2 

### e, as shown in Table 6-4, and capacity-based thresholds equivalent to these. The July 12, 2010 final rul e established an emissions threshold of 25,000 metric tons CO 2 

### e, which was estimated to cover all currently operating U.S. primary and secondary magnesium ingot producers and most die casters, a ccounting for over 99 percent of emissions from these source categories. This threshol d 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 CO 2 

### e established in the final rule was equal to emissions of 1, 046 kg of SF 6 

### ; 19,231 kg of HFC–134a; or 25,000,000 kg of CO 2 

### (based on the GWP values established in Table A-1 to subpart A of part 98) (U.S. EPA, 2009).

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

Emission Threshold Level (metric tons CO 2 e/yr) Total

National Emissions (metric tons CO 2 e/yr) Total

Number of Facilities Emissions Covered Facilities Covered

metric tons CO 2 e/yr Percent Facilities Percent 1,000 3,200,000 13 2,954,559 92% 13 100.0%

### 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 co ncerns. Therefore, ERG estimated the incremental impacts to the magnesi um production industry based on the available aggregate data. In order to estimate the source c ategory impacts from revising the GWPs in Table A-1 to subpart A of part 98, the 2004 GWPs refle cted in Table A-1 to subpart A were compared to the proposed new and revised GWPs to determ ine the increase for each reported pollutant.

Only SF 6 

### and HFC-134a have been evaluated for the purposes of estimati ng the impacts of the revised GWPs. Table 6-5 lists the pollutants and ass ociated increase in GWP for each chemical. Emissions of the fluorinated ketone FK 5–1–12, alt hough 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 emis sions.

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

Magnesium Production and Processing

Pollutant Name CAS No. Chemical formula GWP in Table A

1 of the final rule Proposed GWP % Increase
FK

- 5

- 1

- 12 756

- 13

- 8 C 3 F 7 C(O)C 2 F 5 NA 1.8

- HFC

– 134a 811

– 97

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

– 62

–

4 SF 6 23,900 22,800

- 5



### As shown in Table 6-5, emissions from facilities utilizi ng SF 6 

### that meet the current 25,000 metric tons CO 2 

### e threshold would decrease as a result of the revised GWP for SF 6 

### . For these facilities, this decrease would be significant onl y if the proposed revision to the GWP reduced their annual emissions to less than 25,000 metric tons CO 2 

### e for 5 consecutive years (per 40 CFR 98.2(i)). Therefore, 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 br ought facility-wide emissions above 25,000 metric tons CO 2 

### e. This would include only facilities with current total f acility emissions between 22,500 metric tons CO 2 

### e and 25,000 metric tons CO 2 

### e.

The aggregate data from the 2010 Threshold Analysis showed th at the 11 facilities exceeding the 10,000 metric tons CO 2 

### e threshold also exceeded the 25,000 metric tons CO 2 

### e threshold (see Table 6-5). Based on these data, there woul d be no facilities meeting the 10,000
metric tons CO 2 

### e threshold that would be affected by the revised GWPs, beca use these facilities

### 37

already exceed the 25,000 metric tons CO 2 

### e threshold. Only two facilities not meeting the 25,000
metric tons CO 2 

### e threshold could potentially be affected by an increase in the GWPs; these two facilities did not exceed the 10,000 metric tons CO 2 

### e threshold at the time subpart T was finalized in July 2010, therefore it is unlikely that thes e facilities would exceed 25,000 tons CO 2 

### e per year with the proposed GWP change.

ERG received updated data from the SF 6 

### Emission Reduction Partnership program for the 2010 reporting year. These data were used to verify the concl usion that no additional facilities will be impacted by the revised GWPs. As discussed in sect ion 5.4 of this memorandum, EPA operated the SF 6 

### Emission Reduction Partnership to encourage industry to reduc e emissions of
SF 6 

### and eliminate the usage of SF 6 

### as a cover gas. As a result, facilities have increas ed 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 emiss ions. Facilities reporting under the SF 6 

### Emission Reduction Partnership include major emitters. Non -reporting facilities include smaller facilities (e.g., sand casting or small die casters) w hose 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 report ed under the Partnership has historically been considered confidential. For this analys is, only aggregate facility-level
emissions based on SF 6 

### usage were available; emissions data from other gas usage were not available. Based on the 2010 SF 6 

### Partnership data, 16 facilities reported, and 11 facilities reported use of SF 6 

### . This is close to the original estimate of 13 processing facilities in the 2010 Threshold Analysis, which was based on 2006 emission estim ates. The reported 2010 SF 6 

### emissions are summarized in Table 6-6.

Table 6-6. 2010 SF 6 

### Emissions Reported through the SF6 Partnership

Total Number of Facilities SF 6 Emissions Level (metric tons CO 2 e/yr) Facilities Meeting SF 6 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 SF 6 

### usage through the EPA’s SF 6 

### Magnesium Partnership are using FK 5–1–12, HFC-134a, or alternat ive cover gases in addition to the SF 6 

### reported. Five facilities reported no emissions of SF 6 

### ; 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 SF 6 

### emissions reported through the Partnership showed a 67% reduction in emissions from 2006. Based on the Inventory of U.S. Greenhouse Gas Emissions

### 38

and Sinks: 1990-2012 (U.S. EPA, 2012), emissions of SF 6 

### from magnesium production and processing in the United States were estimated to be 1.3 m illion metric tons CO 2 

### e in 2010, a
reduction from 3.2 million metric tons CO 2 

### e in 2006. Therefore, we anticipate that the emissions estimates summarized in Table 6-6 are a reasonable repres entation 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 poten tial reporters could be affected if HFC-134a usage were increased. Without data on H FC-134a usage, it is unclear whether the five facilities that did not report SF 6 

### emissions to the SF 6 

### Partnership currently exceed or could exceed the 25,000 metric tons CO 2 

### e threshold. However, because the GWPs of HFC-134a (proposed GWP=1,430) and FK-5-1-12 (proposed GWP=1.8) are si gnificantly lower
than that of SF 6 

### (proposed GWP = 22,800), facilities converting production gases entirely from
SF 6 

### 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 ne ed to use approximately 16 times more HFC-134a as a cover gas in production to meet the 25,000 metri c tons CO 2 

### e threshold than if SF 6 

### were used. Furthermore, the 2010 Partnership Data show the l argest-emitting facility to have
maximum SF 6 

### emissions of ~386,000 metric tons CO 2 

### e. Assuming that total gas usage rates remained the same, if this facility were to convert al l production gases to HFC-134a, the maximum GHG emissions would be just under the 25,000 metric tons CO 2 

### e threshold (386,000 * [1,430/22,800] = 24,200). Similarly, if this facility were to convert all producti on gases to FK-5- 1-12, the maximum GHG emissions would be under 17 metric ton s CO2e (386,000 *[1.8/22,800]= 30.5). Therefore, facilities utilizing the cove r gas FK-5-1-12 are unlikely to exceed the 25,000 metric tons CO 2 

### e threshold. Therefore, we anticipate that the remain ing facilities do not likely use sufficient HFC-134a of FK-5-1-12 to meet or exceed the 25,000
metric tons CO 2 

### e threshold, and the total number of facilities required to report would not be affected due to in the proposed new or revised GWPs. The tot al 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 af fected 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 ent ities as a result of this action

### 39

6.2.4 References for Subpart T U.S. EPA, 2009. Additional Methodological Information Supporting Thre shold Analysis for Specific Source Categories. See Docket ID No. EPA-HQ-OAR-2008-0508-0046. Mar ch 2009.

U.S. EPA, 2010. Economic Impact Analysis for the Mandatory Reporting of G reenhouse Gas Emissions: Subparts: T, FF, TT, and II.. See Docket ID No. EPA-HQ-O AR-2008-0508-2313. June 2010.
U.S. EPA, 2012. Inventory of U.S. Greenhouse Gas Emissions a nd 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 r eport annual CH 4 

### , CO 2 

### , and
N 2 

### O emissions from specific source types that are dependent upon the industry segment.

ERG determined that 99 additional facilities would be subje ct to subpart W due to the
revised GWP. The total cost for the 99 additional faciliti es 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 chan ges 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 CO 2 e per year) a Incremental

Emissions For New Reporters (metric tons of CO 2 e per year) Incremental

Cost Impact For New Reporters (2011$ per year) 29,530 2,786 99 33 7 ,000,000 2,57 2

, 881 860,000

a Total emissions for reporters is based on an estimate p rovided 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 requir ed 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 spec ific emissions data. ERG obtained facility lists that were used to develop the subpart W E conomic Impact Analysis (U.S. EPA. 2010). These facility lists also contain source-specific emissions data for CO 2 

### , CH 4 

### , and N 2 

### O.

Subpart W requires emissions reporting for CO 2 

### , CH 4 

### , and N 2 

### O; therefore, ERG evaluated the incremental cost impacts due to the revised GW P for only these compounds. The
GWP for CO 2 

### remains the same. The GWP for CH 4 

### is increasing by 19%. The GWP for N 2 

### O is decreasing by 4%. ERG applied these GWP changes to the sourc e specific emissions data for each subpart W facility to identify the additional fac ilities that would be required to report under

### 40

the new GWPs The number of new affected facilities th at ERG identified for each subpart W industry segment is provided in Table 6-8.

Table 6-8. Number of New Affected Facilities by Industr y 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 16 b



### Onshore Production 52 c


### 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 t o report under the annual emission-based threshold of 25,000 metric tons CO2e. Because CH 4 is the primary GHG emittedfrom LNG storage facilitie s, the LNG storage facilities with GHG emissions between 21,000 metr ic tons/yr and 25,000 metric tons/yr of CO2e in the EIA are the only facilities that would be affected by the G WP change for CH 4 from 21 to 25. Assuming an even distribution of facilities across the range of emission s 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 iden tifies the number of NG Distribution expected reporters (203) that w ould 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. Assumi ng that CH 4 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 CH 4 from 21 to 25. Assuming an even distribution of facili ties across the range of emissions between 10,000 and 25,000, the number of additional NG distribution facilities t hat would be required to report is 16.

c Conservatively assumes that all emissions related to non-combustion sources are methane, and all emission s related to combustion sources are carbon dioxide.



### 6.3.2 Methodology for Estimating Impacts ERG determined the incremental impacts due to the revised G WP factors by multiplying the average costs per facility by the number of addition al facilities required to report under subpart W due to the revised GWP factors. In the original e conomic impact analysis, EPA estimated the total cost to the private sector (in 2006 dol lars) 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 sh ows the annualized, first-year, and subsequent year cost estimates for each of the eight subpa rt W industry segments. These estimates include costs for reporters to monitor and rep ort emissions, and the costs for non-

### 41

reporters to make an applicability determination for the annual emission-based threshold of 25,000 MtCO 2 

### e.

Table 6-9. Cost Estimates for Petroleum and Natural Gas Sys tems (2006 Dollars)

Segment First Year Subsequent Year
Annualized Cost a ($Million) Annualized

Cost b ($Million) National Cost ($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 t hese 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 wer e estimated to exceed the annual emissionbased threshold of 25,000 metric tons CO 2 

### e. Average cost per facility was then determined by dividing the total segment costs by the number of facilit ies that exceeded the reporting threshold. Non-monitoring costs for facilities in the onshore pro duction industry segment were estimated using the model facilities; however, equipment monitorin g 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 th ese costs are documented in the final report (U.S. EPA, 2010).

For this analysis, the cost estimates identified in Ta ble 6-9 were updated to 2011 dollars by multiplying the estimates by the ratio of the 2006 and 2011 C hemical Engineering Plant Cost Index (i.e., 585.7 / 499.6 = 1.172338). The updated cost estimates a re shown in Table 6-10.

### 42 Table 6-10. Cost Estimates for Petroleum and Natural Gas Sys tems

(Updated To 2011 Dollars)

Segment First Year Subsequent Year
Annualized Cost a ($Million) Annualized

Cost b ($Million) National Cost ($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 e xpected 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 CO 2 

### e (U.S. EPA, 2010). In order to determine average costs per facility, ERG divided the updated costs ide ntified in Table 6-10 by the facility
counts identified in Table 6-11.

Table 6-11. Number of Expected Reporters by Industry Segm ent
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. ER G determined the incremental impacts due to the revised GWP factors by multiplying the ave rage costs per facility by the number of additional facilities required to report under s ubpart 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 Cost a ($Million /Facility) Annualized

Cost b ($Million /Facility) National Cost ($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 ar e shown in Table 6-13 by subpart W industry segment. ERG obtained these cost es timates 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 Revisio ns by Industry Segment

Segment First Year Subsequent Year
Annualized Cost a ($Million) Annualize

d Cost b ($Million) National Cost ($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 Revisio ns by Industry Segment

Segment First Year Subsequent Year
Annualized Cost a ($Million) Annualize

d Cost b ($Million) National Cost ($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 aff ected facilities (due to the revised GWPs) are shown in Table 6-14 by subpart W industry segmen t. For the six industry segments for which data were available, ERG based these emission s estimates on the facility/emissions lists discussed in Section 2. For LNG storage and NG distr ibution, the incremental expected emissions were estimated to be 450,000 metric tons CO 2 

### e by calculating the number of new facilities in these two industry segments (2+16 = 18) by 25, 000 metric tons CO 2 

### e because ERG assumed these facilities would only just meet the 25,000 me tric tons CO 2 

### e 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 CO 2 e) 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 s mall 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 emp loyees, 100 to 499 employees, 500 to

### 45

749 employees, less than 500 employees, 750 to 999 employees, a nd 1,000 to 1,499 employees) using the ratio of average total annualized reporting costs t o the average annual sales receipts for each establishment. The results of this analysis are re presented 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 entit ies. 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 smal l 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 petrol eum 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 fe w production wells) that are highly unlikely to cross the 25,000 metric tons CO 2 

### e reporting threshold. It is unlikely that any of the 99
new affected facilities that ERG determined would become subject to subpart W (due to the revised GWP) would fall into the 1 to 20 employee range ente rprise.

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 sig nificant 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. E ven in this unlikely situation, the impact in all size ranges except for the smallest siz e range is less than 1 percent. It is highly unlikely that any entities in this smallest size range wo uld emit 25,000 metric tons CO 2 

### e 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 CH 4 

### in amounts equivalent to 25,000 metric tons of CO 2 

### e per
year or more.

The revised CH 4 

### GWP will result in an additional 57 facilities subject to subpart HH and additional rule implement costs of $309,738 for the first y ear and $137,500 for the subsequent

### 46

years. There is no significant economic impact on sma ll 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. E PA, 2009a), 2,551 MSW landfills were estimated to be subject to subpart HH. This includes 771 ac tive large MSW landfills, 230 active small landfills, and 1,550 closed landfills. The m ethods 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 subpa rt HH was identified based on the actual CH 4 

### generation information for each active landfill in th e Landfill Methane Outreach Program (LMOP) database in 2006. The CH 4 

### generation rate in 2006 was calculated using the actual wast e-in-place information and a landfill-specific model. The landfill-specific mo del used the first order decay model with a methane generation potential (L 0 

### ) of 100 m 3 

### /mt and three different methane generation rate constant (k) values based on rainfall levels (U.S. EPA, 2005a).

For Active Small Landfills (230):

• It was estimated that there were 460 small active land fills in 2009 that were not covered by the 2006 LMOP database and 50% of them have CH 4 

### generation greater than 25,000 metric tons/yr of CO 2 

### e. 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 CH 4 

### generation greater than 25,000 metric tons/yr of CO 2 

### e. 25% was based on engineering judgments.

Based on the e-GGRT data for the reporting year of 2010, t here are 1,202 MSW landfills reported under subpart HH, including 936 active landfills and 266 cl osed 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 s ector (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 f or 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 i s used in this analysis to estimate the number of additional MSW landfills subject to subpart HH due to the revised CH 4 

### GWP.

### 47

Because the reporting threshold for subpart HH is based o n CH 4 

### generation (not emissions), the facilities that currently have CH 4 

### generation between 21,000 and 25,000 metric tons/yr of CO 2 

### e are the additional facilities affected by the GWP chan ge for CH 4 

### from 21 to 25.
Because the CH 4 

### generation from landfills changes with time and the a mount of waste in place, the time factor should be considered in this analysis. Th e additional active large MSW landfills, active small MSW landfills, and closed landfills subje ct 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 accepte d, etc.) for the landfill-specific model used in the original analysis, this model was not re-run f or this analysis. Therefore, we did not
calculate the actual CH 4 

### generation in 2011 for each MSW landfill covered by the L MOP
database. The best CH 4 

### generation information available is the 2006 CH 4 

### generation information in the supporting data for the TSD for the landfill sect or (U.S. EPA, 2009a). According to this supporting data, there were 1,142 active large MSW landfills and 21 of them have CH 4 

### generation between 21,000 and 25,000 metric tons/yr of CO 2 

### e 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 MS W landfills in 2012 (excluding the closed landfills). Assuming that the profile of lan dfills not in the LMOP database is similar to those landfills in the LMOP data base, the number of a ctive large landfills with CH 4 

### generation between 21,000 and 25,000 metric tons/yr of CO 2 

### e is estimated to be 1,123 x 1.8% = 20
facilities.

Additional Active Small MSW Landfills:
Small landfills are not 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 estim ated that there were 460 small active
landfills in 2009 and 50% of them have CH 4 

### generation greater than 25,000 metric tons/yr of
CO 2 

### e and were included in the original estimates of number of reporting facilities. 30% of small
landfills are estimated to have CH 4 

### generation between 10,000 and 25,000 metric tons/yr of
CO 2 

### e. Assuming that the proportion of all small active la ndfills is the same as those in the LMOP database, and the distribution across the available ran ge of estimated emissions (10,000 to 25,000) is even, the number of small active landfills with CH 4 

### generation between 21,000 and 25,000 metric tons/yr of CO 2 

### e is estimated to be 460 x 30% x (25,000 – 21,000) / (25,000 – 10,000) = 37 facilities.

Additional Closed MSW Landfills:
For closed landfills, CH 4 

### generation and emissions decrease over time. It is es timated that
the CH 4 

### generation decreases 18% in 5 years based on the CH 4 

### generation calculated using

### 48

EPA’s Landfill Gas Emissions Model (LandGEM) (U.S. EP A, 2005b). The closed MSW
landfills identified in the 2006 LMOP database with CH 4 

### generation equal to 25,000 metric tons
of CO 2 

### e now should have CH 4 

### generation around 25,000 x (1-18%) = 20,500 metric tons/yr of
CO 2 

### e in 2011. With the updated GWP for CH 4 

### , the CH 4 

### generation for these landfills is 20,500 / 21 x 25 = 24,405 metric tons/yr of CO 2 

### e, 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 CH 4 

### generations between 21,000 and 25,000 metric tons/yr of CO 2 

### e still would not exceed the 25,000 metric tons/year generation threshold of subpart HH af ter 2011 due to the revised CH 4 

### GWP. According to the 2012 LMOP data, 92 MSW landfills were clo sed in the time period of 2007 through 2011 (U.S. EPA, 2012). Based on the waste in place inf ormation, none of these newly
closed landfills have CH 4 

### generation between 21,000 tons and 25,000 tons of CO 2 

### e based on a
GWP for CH 4 

### of 21. Therefore, no additional closed landfills would exc eed the 25,000 metric tons/year generation threshold using a GWP of 25.

Based on the discussions above, the additional MSW lan dfills subject to subpart HH as a
result of the revised CH 4 

### 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 G WP for CH 4 

### , ERG used the same methodology that was used in the Regulatory Impact A nalysis 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 co sts were adjusted from 2006 to 2011 using the Bureau of Labor statistics average labor fact ors. Capital costs were adjusted from 2006 to 2011 using the CEPCI. The Small Entity Impact Analysi s 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 CH 4 

### GWP was evaluated based on the number of additional affected landfills and the rule implementat ion cost for each facility. Cost information

### 49

for each affected industrial waste landfill is based o n 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 Engine ering 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 Ea ch 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 subj ect to subpart HH due to the
revised CH 4 

### 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 revise d CH 4 

### GWP for subpart HH are
summarized in Table 6-17.

Table 6-17. Summary of Subpart HH Impacts due to the Revi sed GWP

Total Number of Facilities in Source Category a Number of

Reporters Prior to Revised GWP b Number of

New Reporters Due to Revised GWP Total Emissions

Prior to Revised GWP (metric tons of CO 2 e per year) b Incremental

Emissions For New Reporters (metric tons of CO 2 e 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 amo unt of CO 2 equivalent was calculated using 21 as the GWP for CH 4 .
c Estimated by multiplying the number of new affected fac ilities (57) by the average CH 4 generation for each new affected facility. The average CH 4 generation for each new affected facility is assumed to be (25,000 + 21,000)/2 x 25/21 = 27,381 metric tons/yr of CO 2 e. The amount of CO 2 equivalent has been adjusted using the new GWP for CH

4 of 25.



### 6.4.4 Small Entity Impacts The small entity economic impact for landfills was m easured using the “sales tests” approach (represented as cost-to-receipt ratios) for NACI S 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 CH 4 

### GWP. If the ratio of rule implementation cost to sa les 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. Burea u 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 informat ion is adjusted from 2007 dollars to 2011 dollars based on the consumer price index published by Burea u 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, th e rule implementation costs for subpart HH is $5,434 for the first year and $2,413 for the subse quent 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 r eporting for the facilities subject to subpart HH is well below 1% of the sales for all siz e 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 busi nesses 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), , V ersion 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 Landfil l 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 Manda tory Reporting of Greenhouse Gas Emissions Final Rule (GHG Reporting). See Docket ID: EP A-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 co nsists 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 th e amount of CH 4 

### generated, emitted, and/or recovered from anaerobic treatment of in dustrial wastewaters and industrial wastewater treatment sludges. Subpart II applies only to ana erobic 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 re porting 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 emi ts 25,000 metric tons CO 2 

### e 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 CO 2 

### e or more per year.

• Food processing facilities ar e required to report if the facility emits 25,000 metric tons CO 2 

### e or more per year.

### 52

6.5.1 Methodology for Identifying Affected Facilities and Estimating I mpacts
This section discusses how EPA estimated the number of f acilities 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 f rom 21 to 25. The discussion is presented separately for each of the four industries incl uded 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 repor t 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 t o report subpart II emissions (ERG, 2010). For this reason, any change to the methane GWP wil l have no impact on the estimated number of petroleum refineries required to report subpart I I emissions.

Pulp and paper manufacturing . During the development of the GHG reporting rule, as part of the estimate of the potential costs of subpart I I, 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 t ons CO 2 

### e 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 thres hold based on their subpart AA CO 2 

### emissions, any change to the methane GWP will have no i mpact 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 th eir GHG emissions if they exceed 25,000 metric tons CO 2 

### e per year in combined emissions from all specified sources, such as stationary fuel combustion uni ts, 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 source s at the ethanol production facility, EPA assumed facilities that exceed 25,000 metric tons CO 2 

### e 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 i nformation from the Renewable Fuels Association that included facility identification , production, and whether the facility used dry milling or wet milling. This information did not identif y facilities that use anaerobic wastewater treatment. Assuming each facility used anae robic treatment and using standard waste generation rates based on ethanol production, chemical o xygen demand (COD) concentrations, and methane generation rates, EPA calculated potential methane emissions per plant.

Dry milling. The maximum estimated emissions from a facility were s lightly over 1,800
metric tons CO 2 

### 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 CO 2 

### e per year reporting threshold (ERG, 2008a).

Wet milling. Wet milling ethanol production facilities generate more w astewater per unit of production and have somewhat greater production per facili ty than dry milling facilities. Four wet milling facilities produce 1.5 to 2.5 times as much etha nol as the largest dry milling facility. Because EPA had very little information on how individua l 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 treatme nt. Using standard waste generation rates based on ethanol production, COD concentrations, and meth ane generation rates, EPA calculated that four (4) wet milling facilities emitted in excess o f the 25,000 metric tons CO 2 

### e per year reporting threshold. EPA estimated that ethanol production facilities would incur $20,600 in total annualized costs to meet the GHG reporting rule monitoring r equirements (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. Chan ging the GWP to 25 would increase this estimate by two, to a total of four facilities. Us ing these two sources of information, we are estimating the impact of a change to the GWP for methan e 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 excee d 25,000 metric tons CO 2 

### e per year in combined emissions from all specified sources, such as stat ionary fuel combustion units, industrial landfills, and industrial wastewater treatment. However, for the original development of the rule, because EPA had no basis for estimating emis sions from other sources at the food processing facility, EPA assumed facilities that excee d 25,000 metric tons CO 2 

### e per year in
emissions from anaerobic industrial wastewater treatme nt alone would be subject to the rule (ERG, 2010). Food processing facilities that are most like ly to have anaerobic wastewater treatment are: 1) fruits and vegetable processing, 2) poul try 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 I I, 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 thresho ld 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 CO 2 

### e. 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 CO 2 

### e per plant (ERG, 2008b). If the methane GWP increased from 21 to 25, the average emission would increas e to about 1,460 metric tons CO 2 

### e per plant, still significantly below the 25,000 metric tons CO 2 

### e reporting threshold. Thus, an
increase in the methane GWP would have no effect on th e number of fruit and vegetable processing facilities required to report subpart II emissi ons.

Poultry processing. During the development of the GHG reporting rule, as pa rt of the estimate of the potential costs of subpart II, EPA deter mined it did not have sufficient information to estimate the number of poultry processing facilities that exceed the 25,000 metric
ton CO 2 

### e reporting threshold. EPA estimated 50 poultry processors have methane emissions above 10,000 metric tons CO 2 

### e (ERG, 2010). This is an overestimate of those that hav e emissions above 25,000 metric tons CO 2 

### e, but EPA does not have sufficient facility-specific information to refine the estimate, nor to estimate the impact of changing the methane GWP.

As described in the July 17, 2008 memorandum (ERG, 2008b), EPA wa s unable to obtain plant-specific information for poultry processors; neith er production levels nor whether facilities
use anaerobic wastewater treatment were found. Therefore , using national default values for wastewater generation, COD in wastewater concentratio ns, 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 CO 2 

### e. Production of 232 million lb/yr would result in emissions exceeding 25,000 metric tons CO 2 

### e. EPA had publicly available data obtained to support EPA Office of Water’s effluent guidelines for the m eat and poultry products industry. These data classified “nonsmall” poultry processors as f acilities producing more than 100 million pounds per year and reported 206 “nonsmall” poultry producers. Th e data also indicated that 25% of the industry uses onsite anaerobic treatment. Conse quently, EPA estimated that 50 poultry producers (206 x 25%) would exceed the 10,000 metric tons CO 2 

### e threshold (ERG, 2008b). EPA used this estimate as a conservatively high est imate of the number of poultry producers that would be subject to subpart II. Because this e stimate includes producers with emissions as low as 10,000 metric tons CO 2 

### e, no additional facilities are estimated to report as a result of the change in GWP of methane from 21 to 25.

Red meat processing. During the development of the GHG reporting rule, as part of the estimate of the potential costs of subpart II, EPA esti mated 13 red meat processors have methane emissions above 25,000 metric tons CO 2 

### e. As described in July 17, 2008 memorandum (ERG, 2008b), EPA was unable to obtain plant-specific informatio n for red meat processors, neither production levels nor whether facilities use anaerobic w astewater 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 Foods 5 

### 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 estim ated to emit more than 25,000 metric tons CO 2 

### e and one of these sites emitted more than 100,000 metric t ons CO 2 

### e. Following installation of the covers, only one of the se sites emits more than 25,000 metric tons CO 2 

### e and three more emit more than 10,000 metric tons CO 2 

### e.

• Data from Cargill Meat Solutions, Inc. (Cargill) 6 

### indicate they have installed covers on all of their anaerobic lagoons at U.S. meat packing plants (8 beef, 2 pork). It is estimated that these plants would have emit ted more than 25,000 metric tons CO 2 

### e 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 CO 2 

### e (ERG, 2008b).

Because so few red meat processing facilities are requir ed to report using the current GWP, we conclude that no new facilities will be require d to report if the GWP for methane increases from 21 to 25Small Entity Impacts

The only additional subpart II reporters expected as a r esult 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 s ubpart 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, IN CORPORATED, February 23, 2004.
6 Cargill’s Corporate Citizenship Review.

### 56 Table 6-20. Summary of Subpart II Impacts Due to the GWP Re visions

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 CO 2 e per year) a Incremental

Emissions For New Reporters (metric tons of CO 2 e 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 analy sis (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 fa cilities would be $5,150 per facility (ERG, 2010). Consequently, adding two ethanol production facil ities would increase the reporting costs by $10,300. There are no small entity impacts a ssociated with this change.

6.5.3 References for Subpart II Eastern Research Group, Inc. (ERG), 2008a. Supporting Docume ntation: 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, Industria l 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_Thresho lds_Ethanol Mills_052611.xlsx. Prepared for Melissa Weitz, EPA. May 26, 2011.
U.S. EPA, 2008. Inventory of U.S. Greenhouse Gas Emissions a nd Sinks: 1990-2006. April 2008. USEPA #430-R-08-005.
Additional Reference, Not Specifically Cited
U.S. EPA, 2009. Technical Support Document for Wastewater T reatment: 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 consis ts 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 equivale nt to 25,000 metric tons CO 2 

### e or more. F-GHGs that do not appear on Table A-1 are not incl uded in the threshold analysis. However, if a supplier of industrial GHGs is above the t hreshold of 25,000 metric tons CO2e based on the Table A-1 chemicals, they must report produc tion, 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 subpar t 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 im pact 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 GW Ps. A list of importers and exporters was developed for the 2009 subpart OO threshold analysis (U.S. EP A, 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, or ganizes and stores bills of lading from port cargo. These data were supplemented with data obtain ed from industry representatives through the Alliance for Responsible Atmospheric Policy.

Table 6-21 shows the number of facilities that EPA ident ified for each of the industry segments covered by subpart OO that would report.

Table 6-21. Number of Facilities Reporting by Industry Seg ment

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

- 244 a 89 a

a The number of facilities was estimated as an upper bound and lower bound estimate. The data contained many similar, but not identically named companies.



### This list of importers and exporters was used to determine t he additional facilities that would be required to report under subpart OO if the proposed re vised 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 det ermine which entities would exceed the threshold of 25,000 metric tons CO 2 

### e, and be required to report using the revised GWP. It is estimated that approximately three additional importer or exporter entities would be required to report as a result of the revisions to the GW Ps for compounds currently in Table A-1.

For the compounds added to Table A-1, these gases are primari ly used in the electronics industry. EPA reviewed the importers and exporters that ar e 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 servi ng the electronics industry, for those entities that are now expected to be below the reportin g threshold, the inclusion of additional
chemicals in Table A-1 would not cause an increase in th e number of reporters. Of the 26 additional fluorinated GHGs which EPA is proposing to add to T able A-1, 24 of those gases have GWPs less than 2,000. Therefore, we do not expect a significant increase in calculated
CO 2 

### e emissions or any new reporters as a result of the incl usion 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 G WPs, ERG used the same methodology that was used in the Regulatory Impact Analys is 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 mi llion in subsequent years.). These estimates consist of costs for recordkeeping and r eporting. 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 (N 2 

### O producers, fluorinated gas producers, and fluorinated gas importers and exporters). Costs in 2006 dollars include $1,700 per f acility 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 N 2 

### O producers, and $946 for importers). Costs were estimated for all production facilities and f or importers and exporters that were expected to exceed the annual emission based threshold of 25, 000 metric tons CO 2 

### e. Approximately 40% of all importers and exporters were expect ed to report. Additional details of the data, methods, and assumptions underlying these costs a re documented in the final report (U.S. EPA, 2009a). For this analysis, the labor costs we re adjusted from 2006 to 2011 using the Bureau of Labor statistics average labor factors. The t otal average cost per facility for new reporters (importers and exporters) in 2011 dollars is estima ted to be $3,500.

### 59

6.6.3 Cost Impacts The incremental cost impacts for subpart OO due to the r evised GWP are shown in Table 6-22. This cost estimate was obtained by multiplying t he 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, SF 6 and NF 3 Producers 0
N 2 O Producers 0
N 2 O and Fluorinated GHG Importers and Exporters $ 10,500
Total $ 10,500



### Table 6-23 summarizes the subpart OO impacts due to the revi sed GWPs; the summary table provides estimated changes to the number of affected f acilities and expected emissions reported. Each new reporter was estimated to report at th e threshold of 25,000 metric tons CO 2 

### e because ERG assumed these facilities would only just mee t the 25,000 metric tons CO 2 

### e reporting threshold.

Table 6-23. Summary of Subpart OO Impacts Due to the GWP R evisions

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 CO 2 e per year) a Incremental

Emissions For New Reporters (metric tons of CO 2 e per year ) Incremental

Cost Impact For New Reporters (2011$ per year)
351 167 3 254

, 554 ,000 75 ,000 10

, 5 00

a EPA provided 2010 summary information.



### 6.6.4 Small Entity Impacts EPA originally assessed the impact of complying with subpa rt OO requirements on entities subject to the rule by calculating a cost to sa les 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, a nd 1,000 to 1,499 employees) using the ratio of average total annualized mandatory reporti ng costs to the average establishments receipts. For this analysis, because the affected establishments are import and export entities with smaller volumes of imported or expo rted gases, an analysis was performed for the smallest size ranges of entities in the NAIC S 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 esta blishments 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 r eporting for even the smallest facilities subject to subpart OO are well below 1% of th e sales for all entities in the NAICS code 42469. Therefore, we have concluded that there is not a sig nificant economic impact to a
substantial number of small entities for the facilitie s 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 Fluorinate d GHGs, Nitrous Oxide and Carbon Dioxide to Threshold Analysis of Industrial Gas Suppliers. Washingt on, DC: US EPA.
U.S. EPA, 2009a. Regulatory Impact Analysis for the Mand atory Reporting of Greenhouse Gas Emissions Final Rule. See Docket ID:EPA-HQ-OAR-2008-0508-2229. Se ptember 2009.
U.S. EPA, 2009b. Additional Methodological Information Supporting Th reshold 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 acce pt wastes that have volatile solids concentration above 0.5 percent, that have total landfil l design capacity greater than or equal to 300,000 metric tons, and that are located within a facility with GHG emissions equal to or greater than 25,000 metric tons of CO 2 

### e per year. Therefore, the GHG emissions from an industrial waste landfill alone cannot determine the appli cability of subpart TT and the GHG emissions from the entire facility must be considere d.

In general, industrial waste landfills that meet the G HG reporting criteria are co-located with refineries, petrochemical production facilities, pulp and paper mills, and food processing facilities. All Refineries and petrochemical production f acilities are required to report (no threshold) and all pulp and paper mills are expected to be a bove 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 CH 4 

### from 21 to 25 and the cost associated with these additional landfills subject to subpart TT.

The revised CH 4 

### 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 econ omic 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 landfi lls co-located with food processing facilities. Because landfill emissions are not the pr imary emissions from pulp and paper mills,
the revised CH 4 

### GWP should not affect the subpart TT applicability for pu lp and paper facilities.

The number of total food processing facilities has not b een updated since the Economic Impact Analysis for the Mandatory Reporting of Greenhouse G as Emissions: Subparts: T, FF, TT, and II (U.S. EPA, 2010b) was developed in June 2010. Accord ing to that economic impact analysis for subpart TT (U.S. EPA, 2010b), the food processi ng 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 CH 4 

### GWP.

According to the TSD for the landfill sector (U.S. E PA, 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 CO 2 

### e based on engineering judgments. The list of the food processing facilities is not ava ilable. Assuming that CH 4 

### emissions are the main GHG emissions from food processing facilities, th e food processing facilities with GHG emissions between 21,000 metric tons per year and 25,000 metr ic tons per year of CO 2 

### e in the
TSD are the additional facilities that could be affect ed by the revised CH 4 

### GWP from 21 to 25. Assuming an even distribution of facilities across this range of emissions, the number of food processing facilities with CO 2 

### e emissions between 21,000 metric tons per year and 25,000 metr ic 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 r esult of the revised CH 4 

### GWP are
summarized in Table 6-25:

### 62 Table 6-25. Number of Additional Industrial Waste Landfill s Subject to Subpart TT as a Result of GWP Revisions

Type of Industrial Waste Landfills Number of Additional Affected Landfills After Revisions to CH 4 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 G WP for CH 4 

### , ERG used the same methodology that was used in the Economic Impact A nalysis for Subpart TT (U.S. EPA, 2010b). The economic impact analysis is based on the num ber of facilities affected and the rule implementation cost for each facility. The cost info rmation is adjusted to the dollar value in 2011. The Small Entity Impact Analysis is measured using “sal es 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 CH 4 

### GWP was evaluated based on the number of additional affected facilities and the rule implementati on cost for each facility. Cost information
for each affected industrial waste landfill is based o n the labor cost and capital cost information listed in the original Economic Impact Analysis for Subpa rt TT (U.S. EPA, 2010b). Labor costs were adjusted from 2006 to 2011 using the Bureau of Labor statist ics 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 summ arized in Table 6-26.

Table 6-26. Rule Implementation Costs for Subpart TT for Ea ch 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
CH 4 

### 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 GW P Revisions

Total Number of Facilities in Source Category a Number of

Reporters Prior to GWP Revisions a Number of

New Reporters Due GWP Revisions Total Emissions

From Reporters Prior to GWP Revisions (metric tons of CO 2 e per year) a Incremental

Emissions For New Reporters (metric tons of CO 2 e 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 fac ilities (19) by the average CH 4 generation for each new affected facility. The average CH 4 emissions for each new affected facility are assumed to be (25,000 + 21,000)/2 x 25/21 = 27,381 metric tons/yr of CO 2 e. The amount of CO 2 equivalent has been adjusted using the new GWP for CH 4 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 s ubpart TT due to the revised CH 4 

### GWP. If the ratio of rule implementation cost to sales is less t han 1%, the impact is not considered to be significant (U.S. EPA, 2010b).

Based on the information provided in Tables 5-10 (Number of E stablishments) 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 (sal es) for the food processing facilities with NAICS codes of 311611, 311411, and 311421 were calculated by dividing t he total receipts information by the number of establishments for each e nterprise 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 Ent erprise 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 Ent erprise 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 fo r each size of enterprise. According to the cost information listed in Table 6-26, the rule implem entation costs for subpart TT is $6,240 for the first year and $4,593 for the subsequent years (in 2011 do llars). 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: Subse quent 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 thi s 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 Wa ste Landfill Sector: Final Rule For Mandatory Reporting Of Greenhouse Gases. See Docket ID: E PA-HQ-OAR-2008-0508-2310. June 9, 2010.
U.S. EPA 2010b. Economic Impact Analysis for the Mandatory Re porting 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 subpar ts in the GHG reporting rule. In this section, we discuss the potential burden impacts for facilities a nd 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 co rrections are discussed in the memorandum titled “Table of 2013 Technical Corrections, Clar ifying and other Amendments to Certain Provisions of the Mandatory Greenhouse Gas Reporti ng 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 facilit ies that would be required to report based on the revised GWPs. The remaining proposed amendmen ts 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 e xpected 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 long itude 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 T ier 1 methodology to be used
for Table C-1 fuels that are combusted in a unit with a m aximum rated heat input capacity greater than 250 mmBtu/hr, if the fuel provides less than 10 pe rcent of the annual heat input to the unit. Expanding the use of the Tier 1 methodology is expe cted 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 facto rs 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 th e 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 combustio n in addition to other fuels. The majority of coal coke produced (92 percent) in the United St ates 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 ty pically use coke as the primary fuel, we do not expect any additional facilities would be required t o report due to an increase in
calculated CO 2 

### emissions resulting from the proposed increase to the c oke emission factor in
Table C-1.

7.3 Subpart H – Cement Production EPA is proposing to require annual, facility-wide cement pr oduction instead of monthly, kiln-specific cement production for facilities that use a CEMS to measure CO 2 

### emissions. Because facilities already expected to track facility-w ide cement production for budgeting purposes, we do not expect this revision to result in any addit ional burden for cement production
facilities.

7.4 Subpart K – Ferroalloy Production EPA is proposing two changes to subpart K. The first cha nge corrects a conversion factor in equation K-3 and we do not expect any additional reporter b urden as a result. The second change requires facilities to report the annual process CH 4 

### emissions from each electric arc furnace (EAF) used for the production of any ferroalloy lis ted in Table K-1 of subpart K. Because facilities must already monitor and calculate e missions of CH 4 

### from each EAF, we do not expect that the proposed changes would impose and addit ional 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 repor ting 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 propo sed 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-ba sed mineral mass-fractions to allow for more accurate measurement methods and provide flexibili ty for reporters. EPA is proposing facilities use consensus standards that specify X-ray fl uorescence (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 o f 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 (WA L, 2009). Based on the similarity in cost, we do not believe that revi sing 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 a dding flexibility for monitoring and measurement methodologies and removing redundant reporting requirements. EPA is also proposing changes that clarify rule text an d equation terms. None of the proposed amendments for subpart P are expected to impose any additi onal burden on reporters.

7.8 Subpart Q – Iron and Steel Production EPA is proposing multiple amendments to subpart Q to cl arify certain provisions and calculation methods. Two of the proposed revisions may pote ntially affect the reporting burden for facilities covered under subpart Q. First, EPA is pr oposing to include direct reduction furnaces not co-located with an integrated iron and ste el manufacturing process, as these furnaces were inadvertently excluded from the original r ulemaking. Because this change only impacts one facility that is already reporting under sub part 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 deter mine 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 addit ional 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 CO 2 

### emissions to use Equation C-10 of subpart C to Part 98
to calculate CH 4 

### and N 2 

### O emissions from burning process off-gas. We do not expect an increase
in burden since Tier 4 units can use best available informat ion 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 reporte rs 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 allo w the alternative sampling requirements for feedstocks and products when the composit ion 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 i nputs for gaseous feedstock and products to be measured on either a mass basis or on a vo lume basis in Equation X-1. EPA is also proposing to allow facilities to use industry standa rd practices for the analysis of carbon black feedstock oils and carbon black products, instead of a s pecified 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 re porters.

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 conte nts, and missing molecular weights for gaseous feedstocks and products. EPA is also pro posing to add missing data requirements for flares. Because these proposed amendm ents only clarify the existing missing data procedures for subpart X facilities, we do not expect t hese amendments will impose any additional burden on reporters.

Additionally, EPA is proposing several amendments to rep orting 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 petroch emical process unit. EPA is also proposing to require facilities to provide an estimate of the fraction of total CO 2 

### 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 keepi ng procedures; therefore, we do not expect these additional reporting requirement to signif icantly 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 cha nge the reporting requirement of the annual permitted phosphoric acid production capacity to the an nual phosphoric acid production capacity. We do not expect this change to impose any addition al burden on reporters since the information should be readily available in facility r ecords. EPA is also proposing to add a reporting requirement to report the number of times missi ng data procedures were used to
estimate the CO 2 

### content of the phosphate rock. Again, we do not expect any additional burden for reporters as a result of this change because faciliti es are already required to keep records for estimating missing values of CO 2 

### content of phosphate rock per 40 CFR 98.265(a), and no new
information would need to be collected.

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 o missions, and inconsistencies from Table AA-1 and AA-2. We do not anticipate any additional burden due t o these changes since no additional reporting requirements or monitoring would be requi red.

EPA is also proposing to amend the reporting requirement f or the annual pulp and/or paper production information that must be reported. EPA is cl arifying that the annual production information must consist of the production of air-drie d, unbleached virgin pulp produced onsite during the reporting year and the production of paper products e xiting the paper machine(s) during the reporting year, prior to application of any off-m achine 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 t he GHG reporting rule. In their guidance, EPA specified that facilities should report virgi n 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 repo rting or monitoring would be required by reporters. As a result, we do not expect the pr oposed 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 proposi ng to remove the requirement for facilities to report CH 4 

### emissions from silicon carbide process units or furnaces . Additionally, EPA is proposing to amend subpart BB such that facilitie s would calculate and report CO 2 

### emissions for all process units and furnaces combined, inst ead of each process unit or production furnace. The remaining changes to subpart BB either support thes e 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 Equ ipment Use EPA is proposing two technical corrections to subpart DD to correct the accuracy and precision requirements for weighing cylinders. Instead of sc ale 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 DD 7 

### , and the preamble to the final Part 98 (74 FR 56260, October 30, 2009). In their res ponse 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 n ot 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 m ajority of proposed changes include terminology revisions that more accurate ly reflect industry operations, correction of subscript errors, and minor clarificatio ns of rule text. More substantially, EPA is proposing to include reporting of the following data element s: 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 clo se 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
CH 4 

### routed to each destruction device, and the Mine Safety an d Health Administration (MSHA)
identification. All of these data elements are readil y 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 c overed 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 us ed measured values for the degradable organic carbon content in Equation HH-1. EPA is a lso clarifying that the fraction by
volume of CH 4 

### in the landfill gas, used in Equation HH-1, should be cor rected to zero percent oxygen. Additionally, EPA is reducing the measurement frequen cy for sampling methane concentrations from weekly to monthly for the paramete r “N” in Equation HH-4. To clarify how to calculate methane emissions at landfills with gas c ollection 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 clarificatio ns and amendments including removing duplicative reporting requirements. Facilities are not requi red to report any additional data elements, or implement any additional monitoring equipmen t 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 add ition to clarifying reporting requirements, EPA is proposing changes to remove the require ments at 40 CFR 98.386(a)(1), (a)(5), (a)(13), (b)(1) and (c)(1) for each facility, impo rter, and exporter to report the annual quantity of each product or natural gas liquid on the basis o f 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 requi rements from the rule.

7.17 Subpart MM – Suppliers of Petroleum Products

In addition to several minor correction and clarifica tions, 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 postpone ment 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) a nd (c)(1) for each facility, importer, and exporter to report the annual quantity of each petroleu m product or natural gas liquid on the basis of the measurement standard method or industry stan dard practice used. In another step to reduce recordkeeping and reporting burden, the reporting requirem ents for crude oil at 40 CFR 98.396(a)(20) are proposed to be changed to require only the annua l quantity of crude oil. EPA is also proposing to eliminate the requirement to measure th e API gravity of each batch of crude oil at 40 CFR 98.394(d). EPA is proposing to add and revise several d efinitions 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 M M will provide additional flexibility for reporters and reduce the reporting and recordkeeping burden f or 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 i n multiple states, the operations in each state are considered a separated LDC. EPA is also propos ing a revision to clarify that interstate and intrastate pipelines delivering natural gas either directl y to major industrial users or to farm taps upstream of the LDC inlet are not included in the defi nition of an LDC. We do not expect these clarifications to impose any additional burden on re porters. In “Q286” of the “Frequently Asked Questions” section of EPA’s supporting website for t he 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. Therefo re, the proposed clarifications are a follow-up to previous guidance and we do not expect any additiona l owners/operators would be required to report as a result of the change.

EPA is also proposing to change the calculation and repo rting 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 c ustomer receiving a total of greater than 460,000 Mscf during the year, the LDC would be required to report t hese 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 deli veries to individual meters. Because LDCs would be able to report on a per customer, rather th an per meter basis, we expect a reduction in the reporting burden as a result of this propo sed change.

EPA is proposing to amend part of the calculation metho dology in subpart NN. Subpart NN currently requires the use of a single emission fac tor for all types of gas streams accounted for in Equation NN-5. Because the characteristics of th ese 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 p laced into or removed from storage during the year is proposed to be calculated using equation NN-5a. E missions that would result from the combustion or oxidation of natural gas that bypassed the ci ty gate are proposed to be calculated using Equation NN-5b, which allows the use of different e mission 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 modi fy their calculation methodology and would not be required to install any additio nal monitoring equipment. Therefore, we do not expect any additional burden on facil ities 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 qua ntity not fractionated, but supplied downstream. We do not anticipate that reporters would be r equired to purchase or install any new monitoring equipment as a result of these proposed repor ting 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 unde r existing Sarbanes Oxley regulation.

7.19 Subpart QQ – Importers of Exporters of Fluorinated Green house Gases Contained in Pre-Charged Equipment of Closed Cell Foams EPA is proposing multiple revisions to subpart QQ. In addit ion to minor corrections and clarifications, EPA is proposing to remove the followi ng reporting requirements: 40 CFR 98.436(a)(5), (a)(6)(iv), (b)(5), and (b)(6)(iv). We expect t hat the removal or reporting requirements will alleviate reporting burden for facilit ies required to report under subpart QQ.

7.20 Subpart RR – Geologic Sequestration of Carbon Dioxide

In addition to minor corrections and clarifications t o subpart RR, EPA is proposing to add a reporting requirement for facilities to report the sta ndard or method used to calculate the mass
or volume of contents in containers that is redelivere d 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 significan t 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 pr oposing to revise definitions in Equation TT-1 and TT-7 and to correct Equation TT-7 by dele ting an erroneous term. EPA is also proposing a change to clarify that the number of wa ste streams for which Equation TT-1 is used includes the number of "Inert" waste streams dispose d 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 pro posing to eliminate duplicative reporting requirements and to clarify the requirements for reporte rs when using Equations TT-4a or TT-4b. EPA is also proposing amendments to Table TT-1 to includ e the DOC default value of 0.09 for “Industrial Sludge,” and the corresponding k-values. None of t he proposed changes to subpart

### 74

TT would require any additional monitoring or recordkeeping an d 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 U U. Most substantial, EPA is proposing to add two reporting requirements. First, reporte rs would be required to report the purpose of CO 2 

### injection. Second, facilities would be required to report the standard or method used to calculate the parameters for CO 2 

### received in containers. Neither of these reporting requirements would require facilities to collect any addit ional data or install and operate any additional monitoring equipment. As a result, we do not e xpect the proposed changes would impose any additional significant burden on facilities requ ired 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 co rrections 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 Inform ation 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%20SoilsOver b.pdf.

# Appendix A GWPs – Proposed Revisions to Table A-1

### A- 1 Appendix A: GWPs Proposed Revisions to Table A-1 of Sub part 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 CO 2 1 1

-- -- Methane 74

- 82

- 8 CH 4 21 25 4 19%
Nitrous oxide 10024

– 97

– 2 N 2 O 310 298

- 12

- 4%
HFC

– 23 75

– 46

– 7 CHF 3 11,700 14

, 800 3

, 100 26%
HFC

– 32 75

– 10

– 5 CH 2 F 2 650 675 25 4%
HFC

– 41 593

– 53

– 3 CH 3 F 150 92

- 58

- 39%
HFC

– 125 354

– 33

– 6 C 2 HF 5 2,800 500

- 2

, 300

- 82%
HFC

– 134 359

– 35

– 3 C 2 H 2 F 4 1,000 1

, 100 100 10%
HFC

– 134a 811

– 97

– 2 CH 2 FCF 3 1,300 1

, 430 130 10%
HFC

– 143 430

– 66

– 0 C 2 H 3 F 3 300 353 53 18%
HFC

– 143a 420

– 46

– 2 C 2 H 3 F 3 3,800 4

, 470 670 18%
HFC

– 152 624

– 72

– 6 CH 2 FCH 2 F 53 53 0 0%
HFC

– 152a 75

– 37

– 6 CH 3 CHF 2 140 38

- 102

- 73%
HFC

– 161 353

– 36

– 6 CH 3 CH 2 F 12 12 0 0%
HFC

– 227ea 431

– 89

– 0 C 3 HF 7 2,900 3

, 220 320 11%
HFC

– 236cb 677

– 56

– 5 CH 2 FCF 2 CF 3 1,340 1

, 340 0 0%
HFC

– 236ea 431

– 63

– 0 CHF 2 CHFCF 3 1,370 1

, 370 0 0%
HFC

– 236fa 690

– 39

– 1 C 3 H 2 F 6 6,300 9

, 810 3

, 510 56%
HFC

– 245ca 679

– 86

– 7 C 3 H 3 F 5 560 693 133 24%
HFC

– 245fa 460

– 73

– 1 CHF 2 CH 2 CF 3 1,030 1

, 030 0 0%
HFC

– 365mfc 406

– 58

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

– 43

– 10mee 138495

– 42

– 8 CF 3 CFHCFHCF 2 CF 3 1,300 1

, 640 340 26%
Sulfur hexafluoride 2551

– 62

– 4 SF 6 23,900 22

, 800

- 1

, 100

- 5% Trifluoromethyl sulphur pentafluoride 373–80–8 SF 5 CF 3 17,700 17,700 0 0% Nitrogen trifluoride 7783

– 54

– 2 NF 3 17,200 17

, 200 0 0%
PFC

– 14 (Perfluoromethane) 75–73–0 CF 4 6,500 7,390 890 14%
PFC

– 116 (Perfluoroethane) 76–16–4 C 2 F 6 9,200 12,200 3,000 33%
PFC

– 218 (Perfluoropropane) 76–19–7 C 3 F 8 7,000 8,830 1,830 26% Perfluorocyclopropane 931

– 91

– 9 C

- C 3 F 6 17,340 17,340 0 0%
PFC

– 3

– 1

– 10 (Perfluorobutane) 355–25–9 C 4 F 10 7,000 8,860 1,860 27% Perfluorocyclobutane 115

– 25

– 3 C

- C 4 F 8 8,700 10

, 300 1

, 600 18%
PFC

– 4

– 1

– 12 (Perfluoropentane) 678–26–2 C 5 F 12 7,500 9,160 1,660 22%
PFC

– 5

– 1

– 14 355

– 42

– 0 C6F14 7,400 9

, 300 1

, 900 26%

### A- 2 Appendix A: GWPs Proposed Revisions to Table A-1 of Sub part 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 C 10 F 18 7,500 7

, 500 0 0%
HCFE

– 235da2 (Isoflurane) 26675–46–7 CHF 2 OCHClCF 3 350 350 0 0%
HFE

– 43

– 10pccc (H

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

– 125 3822

– 68

– 2 CHF 2 OCF 3 14,900 14

, 900 0 0%
HFE

– 134 1691

– 17

– 4 CHF 2 OCHF 2 6,320 6

, 320 0 0%
HFE

– 143a 421

– 14

– 7 CH 3 OCF 3 756 756 0 0%
HFE

– 227ea 2356

– 62

– 9 CF 3 CHFOCF 3 1,540
HFE

– 236ca12 (HG

– 10) 78522

– 47

– 1 CHF 2 OCF 2 OCHF 2 2,800 2

, 800 0 0%
HFE

– 236ea2 (Desflurane) 57041–67–5 CHF 2 OCHFCF 3 989 989 0 0%
HFE

– 236fa 20193

– 67

– 3 CF 3 CH 2 OCF 3 487 487 0 0%
HFE

– 245cb2 22410

– 44

– 2 CH 3 OCF 2 CF 3 708 708 0 0%
HFE

– 245fa1 84011

– 15

– 4 CHF 2 CH 2 OCF 3 286 286 0 0%
HFE

– 245fa2 1885

– 48

– 9 CHF 2 OCH 2 CF 3 659 659 0 0%
HFE

– 254cb2 425

– 88

– 7 CH 3 OCF 2 CHF 2 359 359 0 0%
HFE

– 263fb2 460

– 43

– 5 CF 3 CH 2 OCH 3 11 11 0 0%
HFE

– 329mcc2 67490

– 36

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

– 338mcf2 156053

– 88

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

– 338pcc13 (HG

– 01) 188690–78–0 CHF 2 OCF 2 CF 2 OCHF 2 1,500 1500 0 0%
HFE

– 347mcc3 28523

– 86

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

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

– 347pcf2 406

– 78

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

– 356mec3 382

– 34

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

– 356pcc3 160620

– 20

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

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

– 356pcf3 35042

– 99

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

– 365mcf3 378

– 16

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

– 374pc2 512

– 51

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

HFE–449s1 (HFE– 7100) Chemical blend 163702

– 07

– 6

163702–08–7 C 4 F 9 OCH 3

(CF 3 ) 2 CFCF

2 OCH 3 297 297 0 0%
HFE

– 569sf2 (HFE

– 7200) Chemical blend 163702

– 05

– 4 163702–06–5 C 4 F 9 OC 2 H 5

(CF 3 ) 2 CFCF

2 OC 2 H 5 59 59 0 0%
Sevoflurane 28523

– 86

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

– 356mm1 13171

– 18

– 1 (CF 3 ) 2 CHOCH 3 27 27 0 0%

### A- 3 Appendix A: GWPs Proposed Revisions to Table A-1 of Sub part 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 CHF 2 OCH(CF 3 ) 2 380 380 0 0 % (Octafluorotetramethy

lene)hydroxymethyl group NA X-(CF 2 ) 4 CH(OH)-X 73 73 0 0%
HFE

– 347mmy1 22052

– 84

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

- methanol 920–66–1 (CF 3 ) 2 CHOH 195 195 0 0% 2,2,3,3,3

- pentafluoropropanol 422–05–9 CF 3 CF 2 CH 2 OH 42 42 0 0%

PFPMIE NA CF 3 OCF(CF 3 )CF 2 OCF

2 OCF 3 10,300 10,300 0 0%
HFC-1234ze 29118-24-9 

### C 3 

### H 2 

### F 4 NA 6 NA NA hexafluoropropylene (HFP) 116-15-4 

### C 3 

### F 6 NA 0.25 NA NA

perfluoromethyl vinyl ether (PMVE) 1187-93-5 

### CF(CF 3 

### )OCF 3 NA 3 NA NA

tetrafluoroethylene (TFE) 116-14-3 

### C 2 

### F 4 NA 0.02 NA NA

trifluoro propene (TFP) 677-21-4 

### C 3 

### H 3 

### F 3 NA 3 NA NA vinyl fluoride (VF) 75-02-5 

### C 2 

### H 3 

### F NA 0.7 NA NA vinylidiene fluoride (VF2) 75-38-7 

### C 2 

### H 2 

### F 2 NA 0.9 NA NA

carbonyl fluoride 353-50-4 

### COF 2 NA 2 NA NA perfluoropropyl vinyl ether 1623-05-8 

### C 5 

### F 10 

### O NA 3 NA NA

perfluoroethyl vinyl ether 10493-43-3 

### C 4 

### F 8 

### O NA 3 NA NA

HFC-1234yf 754-12-1 

### C 3 

### H 2 

### F 4 NA 4 NA NA perfluorethyl iodide (2

- I) 354-64-3 C 2 F 5 I NA 3 NA NA

perfluorbutyl iodide (PFBI, 42-I) 423-39-2 C 4 F 9 I NA 3 NA NA

perfluorhexyl iodide (6

- I) 355-43-1 C 6 F 13 I NA 2 NA NA

perfluoroctyl iodide (8

- I) 507-63-1 C 8 F 17 I NA 2 NA NA

1,1,1,2,2

- pentafluoro

- 4

- iodo butane (22-I) 40723-80-6 C 4 H 4 F 5 I NA 2 NA NA

1,1,1,2,2,3,3,4,4

- nonafluoro-6-iodo hexane (42-I) 2043-55-2 C 6 H 4 F 9 I NA

2 NA NA

### A- 4 Appendix A: GWPs Proposed Revisions to Table A-1 of Sub part 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 C 6 H 3 F 9 NA 2 NA NA

perfluorohexyl ethene (62-U) 25291-17-2 C 8 H 3 F 13 NA 1 NA NA

perfluorooctyl ethene (82-U) 21652-58-4 C 10 H 3 F 17 NA 1 NA NA

1H,1H, 2H,2H

perfluorohexan-1-ol (42-AL) 2043-47-2 C 6 H 5 F 9 O NA

5 NA NA

FK

- 5

- 1

- 12 ; Novec 612; Novec 1230;Perfluoroketone;FK–5–1–12myy2; nPerfluorooctane; Octanedecafluorooctan e 756-13-8 CF 3 CF 2 C(O)CF(CF 3 ) 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 CF 3 CH=CHCl NA 7 NA NA

PFC

- 6

- 1

- 12; hexadecofluoroheptane 335-57-9 C 7 F 16 NA 7930 NA NA

PFC

- 7

- 1

- 1 8 ; octadecafluorooctane 307-34-6 C 8 F 18 NA 8340 NA NA