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 ifyou have any questions and when you wantto 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 ofthe interagency comments/ questions submitted during E012866 review ofthe GHG Mandatory Reporting Final Rule for Magnesium, Underground Coal Mines,) ndustrial Wastewater Treatment and Landfills: P. 42 states IIFurther, operators ofanaerobic sludge digesters are required to report the amount ofCh4 recovered and emitted from the recovery systems"
-- itseems this reporting requirement is due to an existing regulatory reqUirement, and not this GHG reporting rule. Can EPA clarify underwhat 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 wastewatertreatment emissions have not been excluded from the rule. For the sources required to report wastewatertreatment emissions (e.g. pulp and paper, food processing, etc.) can EPA provide quantification/estimation ofemissions? Would these facilities, regardless ofsize, 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 offwhen I return to the office on Wednesday June 2

. Ifyou

### Response to comments/questions from OMB interagency review. P. 42 states "Further, operators ofanaerobic sludge digesters are required to report the amount ofCh4 recovered and emitted from the recovery systems"

-- it seems this reporting requirement is due to an existingregulatory requirement, and not this GHG reporting rule. Can EPA clarify under what regulation this is required and perhaps add thatto the text?
The assumptionthat the reporting requirement is due to an existing regulatory requirement is not correct. The preamble wording can be changedto "Further, this rule requires operators ofanaerobic sludge digesters to report the amount ofCH4 recovered and emitted from the recovery systems"

P. 48 and 49

- EPA states onpage 49 that emissions from wastewater treatment at individual facilities could be significant as a reason why wastewatertreatment emissions have not been excluded from the rule. Forthe sources required to report wastewater treatment emissions (e.g. pulp and paper, food processing, etc.) can EPAprovide quantification/estimation of emissions? EPA's estimated emissions resulting from wastewatertreatment, alone. These estimates are summarized in the following table:

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### Estimated NumberofPlants Required to Report Emissions from Wastewater Treatmentand Estimated Emissions
Estimated If

## :i**~** No. ofPlants Required to Estimated Report Wastewater Emissions Estimated No. Treatment No. of froni ofReporting 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, butEPA estimates only 13 exceed

the reporting threshold Poultry Processing 536 25% have anaerobic 50 0 1,250,000 treatment, butEPA estimates not more than 50 exceedthe reporting threshold Ethanol- wet mill 25 33% ofthe12 have 4 4 26,681 15% of 170 mills plants thathave enough production to exceedthe 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 ofsize, be required to report emissions anyway because otherprocesses exceed the 

### 25,000 tpy threshold? 

### GHG emissions from many

### pulp and papermills will exceed the 

### 25,000 tpy threshold
. Thus, these facilities are required to report even withoutthe wastewater treatment reporting requirements. All 

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

### Ethanolproduction facilities are requiredto reporttheir 

### GHG emissions ifthey exceed 

### 25,000 tC02eperyearin combined emissions from all source categories. Inparticular, EPA expects thatthese facilities couldhave emissions from stationary combustion, industrial landfills, and industrial wastewatertreatment. EPA estimated that four ethanol production facilities wouldberequiredto report 

### GHG emissions based on emissions from industrial wastewatertreatment, only. EPAhas no information about emissions from

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### 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, meatprocessing, and poultry processing) like ethanol production facilities, are required to reporttheir GHG emissions ifthey exceed Q5,OOO 

### tC02

### e per year in combined emissions all source categories. Inparticular, EPA expects that these facilities couldhave emissions from stationary combustion, industrial landfills, and industrial wastewatertreatment. EPA estimated that 63 of5,619 (1%) 

### food processing facilities would be required to report GHG emissions based on emissions from industrial wastewatertreatment, 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, EPA believes that few food**proces~ing** 

### facilities will exceed the reporting threshold because ofemissions from stationary fuel combustion sources and/or industrial solid waste landfills.
.

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