Re: Summary of interagency comments under E012866 on the Magnesium, 

Underground Coal Mines, Industrial Wastewater Treatment and Landfills Final 

Rule ~ 

Suzanne Kocchi to: King, Heidi R 05/25/201010:32 AM 

Cc: "Higgins, Cortney", Rachel Schmeltz 

Hi Heidi, CortneyAttached below are our responses to the interagency comments. Please let us know if you have any 

questions and when you want to discuss next steps. 

response to OMB questions. doc 

Thanks -

Suzie 

"King, Heidi R" 05/17/201005:06:47 PM 

From: 

To: 

Cc: 

Date: 

Subject: 

"King, Heidi R." <HeldLR._King@omb.eop.gov> 

Suzanne Kocchi/DC/USEPAlUS@EPA 

"Higgins, Cortney" <Cortney _Higglns@omb.eop.gov> 

05/17/201005:06 PM 

Summary of interagency comments under E012866 on the Magnesium, Underground Coal Mines, 

Industrial Wastewater Treatment and Landfills Final Rule 

Good evening, Suzie, 

Here is a summary of the interagency comments / questions submitted during E012866 review of the 

GHG Mandatory Reporting Final Rule for Magnesium, Underground Coal Mines,) ndustrial Wastewater 

Treatment and Landfills: 

P. 42 states IIFurther, operators of anaerobic sludge digesters are required to report the 

amount of Ch4 recovered and emitted from the recovery systems" -- it seems this reporting 

requirement is due to an existing regulatory reqUirement, and not this GHG reporting rule. Can 

EPA clarify under what regulation this is required and perhaps add that to the text? 

P. 48 and 49 - EPA states on page 49 that emissions from wastewater treatment at 

individual facilities could be significant as a reason why wastewater treatment emissions have 

not been excluded from the rule. For the sources required to report wastewater treatment 

emissions (e.g. pulp and paper, food processing, etc.) can EPA provide quantification/estimation 

of emissions? 

Would these facilities, regardless of size, be required to report emissions anyway because 

other processes exceed the 25,000 tpy threshold? 

nd 

I look forward to picking up where we left off when I return to the office on Wednesday June 2 . If you 
Response to comments/questions from OMB interagency review. 

P. 42 states "Further, operators of anaerobic sludge 

digesters are required to report the amount of Ch4 recovered and 

emitted from the recovery systems" -- it seems this reporting 

requirement is due to an existing regulatory requirement, and not 

this GHG reporting rule. Can EPA clarify under what regulation 

this is required and perhaps add that to the text? 

The assumption that the reporting requirement is due to an existing regulatory 

requirement is not correct. The preamble wording can be changed to "Further, this rule 

requires operators of anaerobic sludge digesters to report the amount of CH4 recovered 

and emitted from the recovery systems" 

P. 48 and 49 - EPA states on page 49 that emissions 

from wastewater treatment at individual facilities could be 

significant as a reason why wastewater treatment emissions have 

not been excluded from the rule. For the sources required to 

report wastewater treatment emissions (e.g. pulp and paper, food 

processing, etc.) can EPA provide quantification/estimation of 

emissions? 

EPA's estimated emissions resulting from wastewater treatment, alone. These estimates 

are summarized in the following table: 

1 
Estimated Number of Plants Required to Report Emissions from Wastewater 

Treatment and Estimated Emissions 

Estimated 

If 

:i ~ No. of Plants 

Required to Estimated 

Report Wastewater 

Emissions Estimated No. Treatment 

No. of froni of Reporting Emissions Plants 

Plants in Estimated Plants with Wastewater Plants with are Required to 

Category the U.S. Anaerobic Treatment Treatment C~Recovery Report (tCOle) 

Pulp and paper 565 25% 141 0 4,075,044 

Fruits and Vegetables 1,746 100% have anaerobic 0 0 123,000 

Processing treatment, but none (0) 

exceed reporting 

threshold 

Meat Processing 3,337 33% have anaerobic 13 0 0 

treatment, but EPA 

estimates only 13 exceed 

the reporting threshold 

Poultry Processing 536 25% have anaerobic 50 0 1,250,000 

treatment, but EPA 

estimates not more than 

50 exceed the reporting 

threshold 

Ethanol- wet mill 25 33% ofthe12 have 4 4 26,681 

15% of 170 mills plants that have enough 

production to exceed the 

reporting threshold 

Ethanol - dry mill 145 100% but none exceed 0 0 0 

85% of 170 mills reporting threshold 

Petroleum Refineries 150 100% 150 0 616,674 

nla - Not available 

Would these facilities, regardless of size, be required to report emissions 

anyway because other processes exceed the 25,000 tpy threshold? 

GHG emissions from many pulp and paper mills will exceed the 25,000 tpy threshold. 

Thus, these facilities are required to report even without the wastewater treatment 

reporting requirements. 

All petroleum refineries are required to report (no threshold). 

Ethanol production facilities are required to report their GHG emissions ifthey exceed 

25,000 tC02e per year in combined emissions from all source categories. In particular, 

EPA expects that these facilities could have emissions from stationary combustion, 

industrial landfills, and industrial wastewater treatment. EPA estimated that four ethanol 

production facilities would be required to report GHG emissions based on emissions from 

industrial wastewater treatment, only. EPA has no information about emissions from 

2 
stationary fuel combustion sources or industrial solid waste landfills at ethanol 

production facilities; however, these facilities are generally small. Thus, EPA believes 

that few ethanol production facilities will exceed the reporting threshold because of 

emissions from stationary fuel combustion sources and/or industrial solid waste landfills. 

Food processing facilities (fruits and vegetables processing, meat processing, and 

poultry processing) like ethanol production facilities, are required to report their GHG 

emissions if they exceed Q5,OOO tC02e per year in combined emissions all source 

categories. In particular, EPA expects that these facilities could have emissions from 

stationary combustion, industrial landfills, and industrial wastewater treatment. EPA 

estimated that 63 of 5,619 (1 %) food processing facilities would be required to report 

GHG emissions based on emissions from industrial wastewater treatment, only. EPA has 

no information about emissions from stationary fuel combustion sources or industrial 

solid waste landfills at food processing facilities; however, these facilities are generally 

small. Thus, EP A believes that few food proces~ing facilities will exceed the reporting 

threshold because of emissions from stationary fuel combustion sources and/or industrial 

solid waste landfills. . 

3