2012 Technical Corrections and Amendments Cost Memo

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TO: Docket EPA-HQ-OAR-2011-0147

FROM: Akachi Imegwu, U.S. EPA, Climate Change Division

DATE: May 11, 2012

SUBJECT: 2012 Technical Corrections and Amendments Cost Memo 

The 2009 final GHG Reporting Rule was signed by EPA Administrator Lisa Jackson on 

September 22, 2009 and published in the Federal Register on October 30, 2009 (74 FR 56260). 

The 2009 final rule, which became effective on December 29, 2009, requires reporting of GHGs 

from various facilities and suppliers, consistent with the 2008 Consolidated Appropriations Act.

After the promulgation of the 2009 main rule, additional notices were published in 2010 

finalizing the requirements for subpart TT (75 FR 39736, July 12, 2010), subpart W (75 FR 

74458, November 30, 2010), and subpart L (75 FR 74774, December 1, 2010).

EPA further finalized five technical corrections and clarifying amendments to these and 

other subparts under the Greenhouse Gas Reporting Program (GHGRP) from 2010 to early 2012

(please see 75 FR 66434, October 28, 2010; 75 FR 79092, December 17, 2010; 76 FR 73866, 

November 29, 2011; 76 FR 80554, December 23, 2011 and 77 FR 10373, February 22, 2012). 

The corrections and amendments within those five actions generally did not change the basic 

requirements of the rule, but were intended to improve clarity and ensure consistency across the 

calculation, monitoring, and data reporting requirements. Similarly, in this action, the 

corrections, clarifying and other amendments are intended to provide greater clarity and 

flexibility to facilities subject to reporting in 2012.

The four source categories being amended in the 2012 technical corrections rulemaking

are the general provisions (subpart A), fluorinated gas production (subpart L), petroleum and 

natural gas systems (subpart W) and industrial waste landfills (subpart TT). The amendments to 

these subparts do not change the respondent burden. The amendments can be categorized as 

follows:

 Revisions to correct equations under Subpart W.

 Revisions to provide additional flexibility for reporters based on questions raised during 

implementation. 

 Revisions and harmonizing changes that correct and clarify inconsistencies in monitoring

methodologies or reporting requirements.

 Revisions that clarify terms and definitions based on questions raised during 

implementation. 

See Appendix A for examples of proposed amendments that would fall under each of these 

categories. 
2012 Technical Corrections and Amendments Cost Memo

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Appendix A: Revisions that Do Not Affect Burden

Corrections, clarifications, and amendments to data reporting requirements: 

For subpart A, we are proposing to add a data element in Subpart A that impacts only Subpart I 

reporters. This additional data element is a harmonizing change that makes the subpart A 

requirements consistent with the recently finalized February 22, 2012 subpart I amendments (77 

FR 10373). As EPA stated in the preamble to that rule, the amendments made in that action did 

not impose additional burden on reporters. 

For subpart L, we are proposing the greenhouse gas emissions be reported in a less detailed 

manner for two years. During these two years, reporters would still have to use the same 

monitoring and calculation methodologies as is in the current rule. As a result, there is no 

change in burden from these proposed amendments. 

For subpart W, potential reporters have identified several inconsistencies in and expressed 

confusion about the reporting requirements in §98.236. EPA is proposing corrections and 

providing clarification based on questions submitted by potential reporters. EPA, for example, 

included a proposed clarification in 40 CFR 98.236(c)(13) to state that the emissions resulting 

from centrifugal compressors using calculation methodologies in 40 CFR 98.233(o) must be 

reported in metric tons of CO2e for each gas, instead of the current provision which required 

reporting in cubic feet per hour, which was incorrect. As a result, there is no change in burden 

from the proposed amendments to subpart A in this action.

Corrections and clarifications to equations and monitoring methods:

Based on input from reporters and EPA internal review, EPA has identified several 

inconsistencies in and confusion about the calculation methodologies in §98.233 in Subpart W. 

EPA is proposing corrections and providing clarification to these equations. A detailed list of 

corrections to subpart W Equations is available in the Technical Support Document Memo for 

the Technical Corrections Rule in Docket EPA-HQ-OAR-2011-0147. The following is a listing

of some of the corrections and clarifications to equations;

 Desiccant dehydrator – removed the divisor of 1,000 in the equation to provide output 

in cubic feet rather than thousand cubic feet.

 Well completions and workovers with hydraulic fracturing – clarified that output 

from choke measurement calculations in Equations W-11A and W-11B are in actual 

conditions.

 Conversion from actual to standard conditions – clarified that paragraph 98.233(t) 

does not apply if the output from an equation is already in standard units. 

These proposed amendments do not change the overall calculation or monitoring requirements 

for facilities, rather they clarify the existing rule requirements. Therefore, there is no change in 

burden from these types of proposed changes. 

 
2012 Technical Corrections and Amendments Cost Memo

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Increased flexibility for reporters:

EPA has proposed additional flexibility in the monitoring methods for estimating emissions from 

the following sources under subparts TT and W. These proposed amendments are based on 

questions submitted by potential reporters. 

Under subpart TT, we are proposing to clarify how a facility can determine whether they receive 

only inert wastes, and therefore would not be subject to subpart TT. Specifically, we are 

proposing to add an additional methodological option to enable facilities to make this 

assessment. 

For subpart W, examples of proposed amendments that provide additional flexibility are as 

follows. For gas well liquids unloading we are proposing to allow facilities to voluntarily take 

more than the required one sample measurement per sub-basin, well-tubing diameter, and 

pressure grouping. Similarly, for gas well completions and workover with hydraulic fracturing, 

we are proposing to allow facilities to voluntarily take more than the required one sample 

measurement per sub-basin and well type.

Because EPA is not changing the number of measurements required, but merely providing the 

option for reporters to use additional measurements if available, there is no change in the burden.