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MEMORANDUM B 

To: Docket EPA-HQ-OAR-2011-0028 

From: Barbora Master and Lisa Bacanskas, EPA/Climate Change Division and 

 Charles Goodhue, Amanda Baynham, and Ruth Mead, ERG 

Date: December 20, 2011 

Subject: List of data elements assigned to the inputs to emission equations data category in 40 

CFR part 98, subparts L, DD, and SS and proposed to be assigned to the inputs to 

emissions data category in subparts FF and TT. 

In this memorandum, we show the list of data elements that we have assigned to the 

inputs to emission equations data category for subparts L, DD, and SS in the Change to the 

Reporting Date for Certain Data Elements Required Under the Mandatory Reporting of 

Greenhouse Gases Rule. We also show the list of three data elements as amended in the 

Technical Corrections final rule (76 FR 73886, November 29, 2011) that we propose to assign to 

the inputs to emission equations data category for subparts FF and TT.

Background

EPA published the Mandatory Greenhouse Gas Reporting Rule on October 30, 2009 (74 

FR 56260). This rule was designed to collect information necessary to characterize and quantify 

greenhouse gas (GHG) emissions from a broad range of industry sectors, including direct 

emitters of GHGs (e.g., glass manufacturing facilities) and suppliers of certain products that 

would result in GHG emissions if released, combusted, or oxidized by the downstream user of 

these products (e.g., fossil fuels and industrial GHGs). The requirements for the Mandatory 

GHG Reporting Rule are codified at 40 CFR Part 98. During the development of Part 98, EPA 

received a number of comments from businesses and other stakeholders regarding their concern 

that some of the data required to be reported consisted of trade secrets and other confidential 

business information (CBI) that, if released to the public, would likely harm their competitive 

position. To address these concerns, EPA published the Confidentiality Determinations for Data 

Required Under the Mandatory Greenhouse Gas Reporting Rule and Amendments to Special 

Rules Governing Certain Information Obtained Under the Clean Air Act (76 FR 30782, May 26, 

2011; hereinafter referred to as the Final CBI rule).1 

EPA decided not to finalize in the Final CBI rule the determination for data elements 

assigned to the inputs to emissions equations category. EPA received numerous public 

comments on the proposed confidentiality determination for this category that raised valid 

concerns regarding the release of data that are in the inputs to emission equations data category. 

 

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 For additional information on the data categories and the general approach to making confidentiality 

determinations for data elements, see the preamble to the final rulemaking Confidentiality Determinations for Data 

Required under the Mandatory Greenhouse Gas Reporting Rule and Amendment to Special Rules Governing 

Certain Information Obtained under the Clean Air Act published on May 26, 2011 (76 FR 30782). 
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EPA decided that those concerns warranted additional deliberation and therefore published three 

notices that impact the data elements listed in the inputs to emission equations data category. 

The first notice was an interim final rule to defer reporting of inputs to emission equations to 

August 31, 2011 (see Interim Final Regulation Deferring the Reporting Date for Certain Data 

Elements Required Under the Mandatory Reporting of Greenhouse Gases Rule, 75 FR 81338, 

December 27, 2010). The second notice was a call for information that solicited additional 

information to assist EPA evaluating the best path forward with regard to the inputs to emission 

equations data category (see Call for Information: Information on Inputs to Emission Equations 

under the Mandatory Reporting of Greenhouse Gases Rule, 75 FR 81366, December 27, 2010). 

The third notice is the Final Deferral (see Change to the Reporting Date for Certain Data 

Elements Required Under the Mandatory Reporting of Greenhouse Gases Rule) published 

August 25, 2011 (76 FR 53057). In that action, EPA deferred the deadline for direct emitter 

reporters to report inputs to emission equations data elements. EPA deferred the deadline for 

reporting some of these data elements to March 31, 2013 and the deadline for reporting others to 

March 31, 2015. That notice allows EPA additional time to consider the concerns raised by 

commenters before reporters are required to submit those data elements in their annual reports. 

Copies of all three notices are available on EPA’s website: 

http://www.epa.gov/climatechange/emissions/CBI.html. 

EPA finalized subparts FF and TT on July 12, 2010 (75 FR 39756). In the Final Deferral 

notice (76 FR 53057), EPA deferred the reporting deadline for all data elements that were 

assigned to the inputs to emission equations data category; however, EPA subsequently 

published revisions to these subparts in the Technical Corrections final rule (76 FR 73886, 

November 29, 2011), which revised 21 data elements that are inputs to emission equations and 

added three new data elements. These three new data elements (two in subpart FF and one in 

subpart TT) are listed in Table A-1 of Appendix A in this memorandum. We are proposing that 

the three new data elements be assigned to the inputs to emission equations data category and 

that reporting of these data elements be deferred until 2013. 

For 18 of the 21 revised data elements, the revisions are editorial in nature and do not 

affect the decisions made in the August 25, 2011 final deferral. For the remaining three inputs, 

however, the revisions are more substantive as they change section references for subpart TT 

input data elements. These three data elements were added in the August 25, 2011, Final Deferral 

to Table A-6 to subpart A of part 98, which lists by section the inputs to emission equations to be 

reported by March 31, 2013. Because of the changes in citations for these three data elements, 

we are proposing to amend Table A-6 to reflect the amended citations for these three subpart TT 

data elements. 

Data Elements Covered in this Memorandum

In this memorandum, we list all the data elements that we have assigned to the inputs to 

emission equations data category for the following three final subparts: 

• Subpart L, Fluorinated Gas Production (75 FR 74774, December 1, 2010); 

• Subpart DD, Electrical Transmission and Distribution Equipment Use (75 FR 

74774, December 1, 2010); and 
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• Subpart SS, Electrical Equipment Manufacture or Refurbishment (75 FR 74774, 

December 1, 2010). 

Additionally, we show the three data elements as finalized in the Technical Corrections 

final rule (76 FR 73886, November 29, 2011) that we propose in this action to assign to the 

inputs to emission equations data category and that are proposing to defer the reporting deadline 

to March 31, 2013 for the following final subparts: 

• Subpart FF, Underground Coal Mines (75 FR 39736, July 12, 2010) 

• Subpart TT, Industrial Waste Landfills (75 FR 39736, July 12, 2010). 

For a list of data elements from these subparts assigned to the inputs to emission 

equations direct emitter source data category, see Table A-1 in Appendix A at the end of this 

memorandum. For the discussion of the rationale for the proposed category assignments for the 

data elements in this memorandum and our rationale for the proposed 2013 deferral of the three 

new input data elements, please see the action titled Proposed Confidentiality Determinations for 

8 Subparts and Proposed Amendments to Table A-6 in Subpart A under the Mandatory 

Reporting of Greenhouse Gases Rule. For further information on the deferred inputs to emission 

equations data elements, please see the Final Deferral and the associated memorandum entitled, 

Process for Evaluating and Potentially Amending Part 98 Inputs to Emission Equations (Docket 

EPA-HQ-OAR-2010-0929). Copies of these and other documents are available on EPA’s 

website: http://www.epa.gov/climatechange/emissions/CBI.html. 

Data elements listed below in subparts L, DD, and SS have been assigned as inputs in the 

Final Deferral (76 FR 53057, August 25, 2011). Those listed in subparts FF and TT are data 

elements added after the Final Deferral by the Technical Corrections final rule (76 FR 73886, 

November 29, 2011) and are being proposed as inputs and that reporting of these data elements 

be deferred until 2013.
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Appendix A 

Data Elements Assigned to the “Inputs to Emission Equations” Data Category 

for Subparts L, DD, and SS, and Proposed to be Assigned for Subparts FF 

and TT. 

Table A-1: List of Data Elements in the “Inputs to Emission Equations” Data Category. 
Subpart Data Element

Reporting 

Section

L - Fluorinated Gas 

Production

For requests to use a GWP other than 2,000 for fluorinated GHGs whose GWPs are not listed in 

Table A-1: Estimated GWP of the F-GHG

98.123c1viA2

L - Fluorinated Gas 

Production

The data used in calculating the absolute errors, including quantities and their accuracies and 

precisions.

98.126b1

L - Fluorinated Gas 

Production

The data used in calculating the relative errors, including quantities and their accuracies and 

precisions.

98.126b1

L - Fluorinated Gas 

Production

Balanced chemical equation describing the reaction used to manufacture the F-GHG product and 

each F-GHG transformation product .

98.126b2

L - Fluorinated Gas 

Production

Mass of each fluorine-containing reactant that is fed into the process (metric tons). 98.126b6

L - Fluorinated Gas 

Production

Mass of each fluorine-containing product produced by the process (metric tons). 98.126b7

L - Fluorinated Gas 

Production

Mass of each fluorine-containing product that is removed from the process and fed into the 

destruction device (metric tons).

98.126b8i

L - Fluorinated Gas 

Production

Mass of each fluorine-containing by-product that is removed from the process and fed into the 

destruction device (metric tons).

98.126b8ii

L - Fluorinated Gas 

Production

Mass of each fluorine-containing reactant that is removed from the process and fed into the 

destruction device (metric tons).

98.126b8iii

L - Fluorinated Gas 

Production

Mass of each fluorine-containing by-product that is removed from the process and recaptured (metric 

tons).

98.126b8iv

L - Fluorinated Gas 

Production

Destruction efficiency of the destruction device for each F-GHG fed into the device from the process 

in greater than trace concentrations (fraction).

98.126b8v

L - Fluorinated Gas 

Production

Mass of fluorine in each stream that is fed into the destruction device (metric tons). 98.126b9i

L - Fluorinated Gas 

Production

Mass of fluorine that is recaptured (metric tons). 98.126b9ii

L - Fluorinated Gas 

Production

Weighted average destruction efficiency of the destruction device calculated for each stream under 

40 CFR 98.123(b)(16).

98.126b9iii

L - Fluorinated Gas 

Production

The fraction of the mass emitted that consists of each fluorine-containing reactant. 98.126b10

L - Fluorinated Gas 

Production

The fraction of the mass emitted that consists of the fluorine-containing product. 98.126b11

L - Fluorinated Gas 

Production

The fraction of the mass emitted that consists of each fluorine-containing by-product. 98.126b12

L - Fluorinated Gas 

Production

The quantity of the process activity used to estimate emissions (e.g., tons of product or tons of 

reactant consumed).

98.126c1

L - Fluorinated Gas 

Production

The site-specific, process-vent-specific emission factor(s) or emission calculation factor for each 

process vent.

98.126c2

L - Fluorinated Gas 

Production

Where missing data have been estimated pursuant to 40 CFR 98.125: Estimate of the missing data. 98.126d

L - Fluorinated Gas 

Production

Destruction efficiency of each destruction device, for each F-GHG whose destruction the facility 

reflects in 40 CFR 98.123, in accordance with 40 CFR 98.124(g)(1)(i) through (iv).

98.126f1

L - Fluorinated Gas 

Production

Mass of F-GHG fed into the destruction device. 98.126g1

L - Fluorinated Gas 

Production

Each fluorinated gas production facility that vents residual fluorinated GHGs from containers, the 

heel factor calculated for each container size and type.

98.126h2

blank

DD - Use of Electric 

Transmission and 

Distribution Equipment

Nameplate capacity of equipment containing SF6 or PFCs that was new during the year (all SF6-

insulated equipment, including hermetically sealed-pressure switchgear).

98.306a2

Table A-1: List of Assigned and Proposed Data Elements in the “Inputs to Emission 

Equations” Data Category.

Note: Data elements listed below in subparts L, DD, and SS have been assigned as inputs in the Final Deferral (76 FR 53057, August 25, 2011). 

Those listed in subparts FF and TT are data elements added after the Final Deferral by the Technical Corrections final rule (76 FR 73886, 

November 29, 2011) and are being proposed as inputs.

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Subpart Data Element

Reporting 

Section

Table A-1: List of Assigned and Proposed Data Elements in the “Inputs to Emission 

Equations” Data Category.

Note: Data elements listed below in subparts L, DD, and SS have been assigned as inputs in the Final Deferral (76 FR 53057, August 25, 2011). 

Those listed in subparts FF and TT are data elements added after the Final Deferral by the Technical Corrections final rule (76 FR 73886, 

November 29, 2011) and are being proposed as inputs.

DD - Use of Electric 

Transmission and 

Distribution Equipment

Nameplate capacity of equipment containing SF6 or PFCs that was retired during the year (all SF6-

insulated equipment, including hermetically sealed-pressure switchgear).

98.306a3

DD - Use of Electric 

Transmission and 

Distribution Equipment

SF6 stored in containers, but not in energized equipment, at the beginning of the year (pounds). 98.306d

DD - Use of Electric 

Transmission and 

Distribution Equipment

PFCs stored in containers, but not in energized equipment, at the beginning of the year (pounds). 98.306d

DD - Use of Electric 

Transmission and 

Distribution Equipment

SF6 stored in containers, but not in energized equipment, at the end of the year (pounds). 98.306e

DD - Use of Electric 

Transmission and 

Distribution Equipment

PFCs stored in containers, but not in energized equipment, at the end of the year (pounds). 98.306e

DD - Use of Electric 

Transmission and 

Distribution Equipment

SF6 purchased in bulk from chemical producers or distributors (pounds). 98.306f

DD - Use of Electric 

Transmission and 

Distribution Equipment

PFCs purchased in bulk from chemical producers or distributors (pounds). 98.306f

DD - Use of Electric 

Transmission and 

Distribution Equipment

SF6 purchased from equipment manufacturers or distributors with or inside new equipment, 

including hermetically sealed-pressure switchgear (pounds).

98.306g

DD - Use of Electric 

Transmission and 

Distribution Equipment

PFCs purchased from equipment manufacturers or distributors with or inside new equipment, 

including hermetically sealed-pressure switchgear (pounds).

98.306g

DD - Use of Electric 

Transmission and 

Distribution Equipment

SF6 returned to facility after off-site recycling (pounds). 98.306h

DD - Use of Electric 

Transmission and 

Distribution Equipment

PFCs returned to facility after off-site recycling (pounds). 98.306h

DD - Use of Electric 

Transmission and 

Distribution Equipment

SF6 in bulk and contained in equipment sold to other entities (pounds). 98.306i

DD - Use of Electric 

Transmission and 

Distribution Equipment

PFCs in bulk and contained in equipment sold to other entities (pounds). 98.306i

DD - Use of Electric 

Transmission and 

Distribution Equipment

SF6 returned to suppliers (pounds). 98.306j

DD - Use of Electric 

Transmission and 

Distribution Equipment

PFCs returned to suppliers (pounds). 98.306j

DD - Use of Electric 

Transmission and 

Distribution Equipment

SF6 sent off-site for recycling (pounds). 98.306k

DD - Use of Electric 

Transmission and 

Distribution Equipment

PFCs sent off-site for recycling (pounds). 98.306k

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Subpart Data Element

Reporting 

Section

Table A-1: List of Assigned and Proposed Data Elements in the “Inputs to Emission 

Equations” Data Category.

Note: Data elements listed below in subparts L, DD, and SS have been assigned as inputs in the Final Deferral (76 FR 53057, August 25, 2011). 

Those listed in subparts FF and TT are data elements added after the Final Deferral by the Technical Corrections final rule (76 FR 73886, 

November 29, 2011) and are being proposed as inputs.

DD - Use of Electric 

Transmission and 

Distribution Equipment

SF6 sent off-site for destruction (pounds). 98.306l

DD - Use of Electric 

Transmission and 

Distribution Equipment

PFCs sent off-site for destruction (pounds). 98.306l

blank

FF- Underground Coal 

Mines

Moisture content used in Eq. FF-1 and FF-3. 98.326o

FF- Underground Coal 

Mines

The gaseous organic concentration correction factor used, if Equation FF-9 was required. 98.326o

blank

SS - Manufacture of 

Electric Transmission and 

Distribution Equipment

SF6 and PFC stored in containers at the beginning of the year. 98.456a

SS - Manufacture of 

Electric Transmission and 

Distribution Equipment

SF6 and PFC stored in containers at the end of the year 98.456b

SS - Manufacture of 

Electric Transmission and 

Distribution Equipment

SF6 and PFC purchased in bulk 98.456c

SS - Manufacture of 

Electric Transmission and 

Distribution Equipment

SF6 and PFC returned by equipment users with or inside equipment. 98.456d

SS - Manufacture of 

Electric Transmission and 

Distribution Equipment

SF6 and PFC returned from off site after recycling. 98.456e

SS - Manufacture of 

Electric Transmission and 

Distribution Equipment

SF6 and PFC inside new equipment delivered to customers 98.456f

SS - Manufacture of 

Electric Transmission and 

Distribution Equipment

Pounds of SF6 and PFCs delivered to equipment users in containers. 98.456g

SS - Manufacture of 

Electric Transmission and 

Distribution Equipment

SF6 and PFC returned to suppliers 98.456h

SS - Manufacture of 

Electric Transmission and 

Distribution Equipment

SF6 and PFC sent off site for destruction 98.456i

SS - Manufacture of 

Electric Transmission and 

Distribution Equipment

SF6 and PFC sent off site to be recycled 98.456j

SS - Manufacture of 

Electric Transmission and 

Distribution Equipment

Values for EFC for each hose and valve combination and the associated valve fitting sizes and hose 

diameters.

98.456m

SS - Manufacture of 

Electric Transmission and 

Distribution Equipment

Total number of fill operations for each hose and valve combination, or, FCi of Equation SS-5 of this 

subpart.

98.456n

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Subpart Data Element

Reporting 

Section

Table A-1: List of Assigned and Proposed Data Elements in the “Inputs to Emission 

Equations” Data Category.

Note: Data elements listed below in subparts L, DD, and SS have been assigned as inputs in the Final Deferral (76 FR 53057, August 25, 2011). 

Those listed in subparts FF and TT are data elements added after the Final Deferral by the Technical Corrections final rule (76 FR 73886, 

November 29, 2011) and are being proposed as inputs.

SS - Manufacture of 

Electric Transmission and 

Distribution Equipment

Mean value for each make, model, and group of conditions if the mass of SF6 or the PFC disbursed 

to customers in new equipment over the period p is determined by assuming that it is equal to the 

equipment’s nameplate capacity or, in cases where equipment is shipped with a partial charge, equal 

to its partial shipping charge.

98.456o

SS - Manufacture of 

Electric Transmission and 

Distribution Equipment

SF6 and PFCs used to fill equipment at off-site electric power transmission or distribution locations 

(pounds), or MF, of Equation SS-6.

98.456q

SS - Manufacture of 

Electric Transmission and 

Distribution Equipment

SF6 and PFCs used to charge the equipment prior to leaving the electrical equipment manufacturer 

or refurbishment facility (pounds), or MC, of Equation SS-6.

98.456r

SS - Manufacture of 

Electric Transmission and 

Distribution Equipment

The nameplate capacity of the equipment installed at off-site electric power transmission or 

distribution locations used to determine emissions from installation (pounds), or NI, of Equation SS6.

98.456s

SS - Manufacture of 

Electric Transmission and 

Distribution Equipment

For any missing data: Substitute parameters used to estimate emissions in their absence. 98.456t

blank

TT- Industrial Landfills The methane correction factor (MCF) value used in the calculations. 98.466b4

blank

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