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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 e quations data category in 40

CFR part 98, subparts L, DD, and SS and proposed to be assig ned 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 Repor ting of Greenhouse Gases Rule . We also show the list of three data elements as am ended 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 subpart s 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 nece ssary 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). Th e requirements for the Mandatory GHG Reporting Rule are codified at 40 CFR Part 98. During th e 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 Spec ial 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 de termination for data elements assigned to the inputs to emissions equations category. EP A received numerous public comments on the proposed confidentiality determination f or 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 t he general approach to making confidentiality determinations for data elements, see the preamble t o the final rulemaking Confidentiality Determinations for Data Required under the Mandatory Greenhouse Gas Reporting Rule and Amendme nt 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 deli beration and therefore published three notices that impact the data elements listed in the i nputs to emission equations data category. The first notice was an interim final rule to defer repo rting 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 informa tion that solicited additional information to assist EPA evaluating the best path for ward 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 de adline for direct emitter reporters to report inputs to emission equations data elem ents. EPA deferred the deadline for reporting some of these data elements to March 31, 2013 and th e deadline for reporting others to March 31, 2015. That notice allows EPA additional time to co nsider the concerns raised by commenters before reporters are required to submit those dat a elements in their annual reports. Copies of all three notices are available on EPA’s we bsite: 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 a ll data elements that were assigned to the inputs to emission equations data category; however, EPA subsequently published revisions to these subparts in the Technical Corr ections final rule (76 FR 73886, November 29, 2011), which revised 21 data elements that are input s to emission equations and added three new data elements. These three new data ele ments (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 deferr al. For the remaining three inputs, however, the revisions are more substantive as they c hange section references for subpart TT input data elements. These three data elements were added i n 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 citatio ns 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 Equ ipment Use (75 FR 74774, December 1, 2010); and

# 3 of 4 • Subpart SS, Electrical Equipment Manufacture or Refurbish ment (75 FR 74774, December 1, 2010). Additionally, we show the three data elements as fina lized 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 propos ing 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 assign ed 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 t he 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 emi ssion equations data elements, please see the Final Deferral an d the associated memorandum entitled
, Process for Evaluating and Potentially Amending Part 98 Inputs to Emission E quations (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 subpar ts FF and TT are data elements added after the Final Deferral by the Technical Co rrections final rule (76 FR 73886, November 29, 2011) and are being proposed as inputs and that re porting of these data elements be deferred until 2013.

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# Appendix A
Data Elements Assigned to the “Inputs to Emission Equati ons” 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 fluo rinated 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, i ncluding quantities and their accuracies and precisions. 98.126b1

L - Fluorinated Gas Production The data used in calculating the relative errors, i ncluding 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 f ed into the process (metric tons). 98.126b6

L - Fluorinated Gas Production Mass of each fluorine-containing product produced b y the process (metric tons). 98.126b7

L - Fluorinated Gas Production Mass of each fluorine-containing product that is re moved 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 r emoved 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 fo r 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 th e 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 dest ruction 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 e ach fluorine-containing reactant. 98.126b10

L - Fluorinated Gas Production The fraction of the mass emitted that consists of t he fluorine-containing product. 98.126b11

L - Fluorinated Gas Production The fraction of the mass emitted that consists of e ach fluorine-containing by-product. 98.126b12

L - Fluorinated Gas Production The quantity of the process activity used to estima te emissions (e.g., tons of product or tons of reactant consumed). 98.126c1

L - Fluorinated Gas Production The site-specific, process-vent-specific emission f actor(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 CF R 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 P FCs 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 Eleme nts 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 Deferr al (76 FR 53057, August 25, 2011). Those listed in subparts FF and TT are data element s added after the Final Deferral by the Technical C orrections 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 Eleme nts 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 Deferr al (76 FR 53057, August 25, 2011). Those listed in subparts FF and TT are data element s added after the Final Deferral by the Technical C orrections 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 P FCs 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 equi pment, at the beginning of the year (pounds). 98.306 d

DD - Use of Electric Transmission and Distribution Equipment PFCs stored in containers, but not in energized equ ipment, at the beginning of the year (pounds). 98.30 6d

DD - Use of Electric Transmission and Distribution Equipment SF6 stored in containers, but not in energized equi pment, 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 equ ipment, 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 di stributors (pounds). 98.306f

DD - Use of Electric Transmission and Distribution Equipment PFCs purchased in bulk from chemical producers or d istributors (pounds). 98.306f

DD - Use of Electric Transmission and Distribution Equipment SF6 purchased from equipment manufacturers or distr ibutors 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 dist ributors 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 othe r entities (pounds). 98.306i

DD - Use of Electric Transmission and Distribution Equipment PFCs in bulk and contained in equipment sold to oth er 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 Eleme nts 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 Deferr al (76 FR 53057, August 25, 2011). Those listed in subparts FF and TT are data element s added after the Final Deferral by the Technical C orrections 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 o f 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 ins ide 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 custo mers 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 v alve 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 Eleme nts 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 Deferr al (76 FR 53057, August 25, 2011). Those listed in subparts FF and TT are data element s added after the Final Deferral by the Technical C orrections 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 condi tions 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 e quipment 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 ele ctric 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 Equat ion SS-6. 98.456r

SS - Manufacture of Electric Transmission and Distribution Equipment The nameplate capacity of the equipment installed a t 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 fact or (MCF) value used in the calculations. 98.466b4 

## blank

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