As described in the July 17, 2008 memorandum (ERG, 2008b), EPA was unable to obtain plant-specific information for poultry processors; neither production levels nor whether facilities use anaerobic wastewater treatment were found. Therefore, using national default values for wastewater generation, COD in wastewater concentrations, and assuming all wastewater is treated anaerobically on site, EPA back-calculated the production rate that would trigger each of four emission thresholds. EPA estimated that production of 93 million lb/yr would result in emissions exceeding 10,000 metric tons CO2e. Production of 232 million lb/yr would result in emissions exceeding 25,000 metric tons CO2e. EPA had publicly available data obtained to support EPA Office of Water's effluent guidelines for the meat and poultry products industry. These data classified "nonsmall" poultry processors as facilities producing more than 100 million pounds per year and reported 206 "nonsmall" poultry producers. The data also indicated that 25% of the industry uses onsite anaerobic treatment. Consequently, EPA estimated that 50 poultry producers (206 x 25%) would exceed the 10,000 metric tons CO2e threshold (ERG, 2008b). EPA used this estimate as a conservatively high estimate of the number of poultry producers that would be subject to subpart II. Because this estimate includes producers with emissions as low as 10,000 metric tons CO2e, no additional facilities are estimated to report as a result of the change in GWP of methane from 21 to 25.
Red meat processing. During the development of the GHG reporting rule, as part of the estimate of the potential costs of subpart II, EPA estimated 13 red meat processors have methane emissions above 25,000 metric tons CO2e. As described in July 17, 2008 memorandum (ERG, 2008b), EPA was unable to obtain plant-specific information for red meat processors, neither production levels nor whether facilities use anaerobic wastewater treatment. EPA used limited published information and engineering judgment to estimate the number of red meat processing facilities required to report, as follows:
Data available on Tyson Foods indicates that covers have been installed on anaerobic lagoons at five meat processing plants (4 beef, 1 pork). Prior to the installation of the covers, all five sites were estimated to emit more than 25,000 metric tons CO2e and one of these sites emitted more than 100,000 metric tons CO2e. Following installation of the covers, only one of these sites emits more than 25,000 metric tons CO2e and three more emit more than 10,000 metric tons CO2e.
Data from Cargill Meat Solutions, Inc. (Cargill) indicate they have installed covers on all of their anaerobic lagoons at U.S. meat packing plants (8 beef, 2 pork). It is estimated that these plants would have emitted more than 25,000 metric tons CO2e each. It is unknown what their actual emissions are now.
From these data, it is estimated that no more than 13 meat processing facilities actually emit more than 25,000 metric tons CO2e (ERG, 2008b). Because so few red meat processing facilities are required to report using the current GWP, it is likely that no new facilities will be required to report if the GWP for methane increases from 21 to 25.
Table 5-23 identifies the number of new subpart II reporters that will become subject to the rule as a result of revisions to the GWPs in Table A-1.
                     Table 5-23. New Subpart II Reporters
                                 Facility Type
                 Number of New Reporters Due to GWP Revisions
                                   Petroleum
                                       0
                                Pulp and Paper
                                       0
                                    Ethanol
                                       2
                                  All Others
                                       0
                                     Total
                                       2

Subpart II (estimating emissions impacts)
Because there are no new petroleum refiners, pulp and paper manufacturing facilities, and food processing facilities anticipated to be affected by the revised GWPs, there is no emissions impact from new subpart II reporters related to these facility types. However, it is estimated that emissions will increase by 59,500 metric tons CO2e per year from the two additional facilities that are expected to report. This estimate is based on the threshold analysis discussed in section 5.5.1 which was used to determine the increase in emissions from the additional reporters that would be expected due to the revised GWPs in Table A-1. Table 5-24 identifies the emissions impact from new subpart II reporters.
          Table 5-24. Emissions Impact From New Subpart II Reporters
                                 Facility Type
                 Incremental CO2e Emissions for New Reporters
                        (metric tons of CO2e per year )
                                   Petroleum
                                       0
                                Pulp and Paper
                                       0
                                    Ethanol
                                    59,500
                                  All Others
                                       0
                                     Total
                                    59,500

Subpart II (estimating cost impacts)
Costs were calculated by multiplying the average costs per facility and the number of new facilities estimated to be subject to subpart II (from revising the GWPs). Average cost per facility for the first year was calculated by dividing total cost by the number of respondents identified in the initial information collection request for subpart II (U.S. EPA, 2010). Average cost per facility for subsequent years was calculated by dividing total cost by the number of respondents identified in the most recent information collection request for the GHG reporting program (U.S. EPA, 2013).
Appendix A to the initial information collection request for subpart II (U.S. EPA, 2010) and Appendix L-2 of the most recent information collection request for the GHG reporting program (U.S. EPA, 2013) were used to obtain first year average cost per facility that is incurred from reporting under subpart II. Cost details from Appendices H-1 and L-2 of the most recent information collection request for the GHG reporting program (U.S. EPA, 2013) were used to determine the subsequent years average cost per facility. These average costs per facility include labor costs (i.e., the cost of labor by facility staff to meet the rule's information collection requirements) and non-labor (capital, and operation and maintenance) costs. Additional details of the data, methods, and assumptions underlying these costs are documented in the information collection requests (U.S. EPA, 2010 and U.S. EPA, 2013).
Table 5-25 shows first and subsequent year average cost per facility subject to subpart II.
Table 5-25. Annual Average Cost Per Facility Subject to Subpart II
                                    Subpart
                        Total Number of Respondents [a]
                                  Total Cost
                               (2011$ per year)
                               Cost Per Facility
                               (2011$ per year)

                                First Year [b]
                             Subsequent Years [a]
                                First Year [b]
                             Subsequent Years [a]
                                   Petroleum
                                      150
                                    625,000
                                    605,900
                                     4,200
                                     4,040
                                Pulp and Paper
                                      141
                                    627,000
                                    607,900
                                     4,400
                                     4,300
                                    Ethanol
                                       4
                                    21,600
                                    21,000
                                     5,400
                                     5,300
                                  All Others
                                      63
                                    263,000
                                    254,500
                                     4,200
                                     4,040
a The total number of respondents and the subsequent year costs are from Appendix H-1 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013). The subsequent costs include $44.25 from the revised burden & cost table identified as "Average Annual Burden and Cost" table of Appendix L-2 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013). The $44.25 is the cost contributed to provisions of information on parent companies, NAICS codes, and whether emissions are from cogeneration.
[b] The first year costs are from the "Year 1" table of Appendix A to the initial information collection request for subpart II (U.S. EPA, 2010). The first year cost includes $80.91 from the current burden & cost table identified as "First Reporting Year" table of Appendix L-2 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013). The $80.91 is the cost contributed to provisions of information on parent companies, NAICS codes, and whether emissions are from cogeneration. These costs were updated to 2011 dollars using the Bureau of Labor Statistics Employment Cost Index and the Chemical Engineering Plant Cost Index (CEPCI).

By revising the GWP values in subpart A, two additional ethanol production facilities will be required to report under subpart II. The first year cost for these facilities will be approximately $10,800 per year (2 x $5,400 = $10,800), and the annualized industry wide cost is $10,500 per year (2 x $5,270 = $10,500).
Subpart II Small Entity Impacts (new reporters)
The only additional subpart II reporters expected as a result of a change to the GWP of methane from 21 to 25 are two ethanol production facilities. Both of these facilities are owned by a large corporation that has been determined not to be a small entity. Therefore, it was determined that there are no small entity impacts to any subpart II reporters associated with this action.
Subpart II (summary of impacts)
Table 5-26 summarizes the impacts of updating the GWP values in Table A-1 to subpart A, on new facilities required to report subpart II emissions.
Table 5-26. New Reporters -- Summary of Subpart II Impacts Due to the Revisions to GWPs
                                 Facility Type
                 Number of New Reporters Due to GWP Revisions
                 Incremental CO2e Emissions for New Reporters
                      (metric tons of CO2e per year ) [a]
                   Incremental Cost Impact For New Reporters
                               (2011$ per year)

                                First Year [a]
                             Subsequent Years [a]
                                   Petroleum
                                       0
                                       -
                                       -
                                       -
                                Pulp and Paper
                                       0
                                       -
                                       -
                                       -
                                    Ethanol
                                       2
                                    59,500
                                    10,800
                                    10,500
                                  All Others
                                       0
                                       -
                                       -
                                       -
                                     Total
                                       2
                                    59,500
                                    10,800
                                    10,500
[a] Values rounded.
References for Subpart II
ERG, 2008b. Memorandum: Revised Threshold Analysis for the Estimation of Greenhouse Gas Emissions from Individual Industrial Facilities. Prepared for Melissa Weitz, EPA. See Docket ID: EPA-HQ-OAR-2008-0508-0132. See Docket ID: EPA-HQ-OAR-2008-0508-0132. July 17, 2008.
ERG, 2010. Memorandum: Greenhouse Gas Reporting Rule, Industrial Wastewater Treatment Source Category, Costs for Final Rule Monitoring Requirements  -  Revised. Prepared for Rachel Schmeltz, EPA. See Docket ID: EPA-HQ-OAR-2008-0508-2297. March 5, 2010.
U.S. EPA, 2008. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2006. April 2008. USEPA #430-R-08-005.
U.S. EPA, 2010. Supporting Statement Part A: Information Collection Request for the Mandatory Reporting of Greenhouse Gases from Magnesium Production, Underground Coal Mines, Industrial Wastewater Treatment, and Industrial Waste Landfills  -  Final Rule. OMB Control No. 2060-0647. EPA ICR No. 2396.01. July 2010.
U.S. EPA, 2013.  Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program.  OMB Control No. 2060-0629. EPA ICR No. 2300.10. May 2013.
Subpart OO
Subpart OO applies to the suppliers of industrial GHGs source category, which consists of all facilities that produce a fluorinated GHG or nitrous oxide, and any importer or exporter of fluorinated GHGs or nitrous oxide with annual bulk imports or exports that are equivalent to 25,000 metric tons CO2e or more. F-GHGs that do not appear on Table A-1 are not included in the threshold analysis. However, if a supplier of industrial GHGs is above the threshold of 25,000 metric tons CO2e based on the Table A-1 chemicals, they must report production, imports and exports of all F-GHG.
Subpart OO (identifying new reporters)
All production facilities are required to report regardless of threshold, therefore, there are not additional facilities as a result of the revised GWPs.
A list of importers and exporters was developed for the 2009 subpart OO threshold analysis (U.S. EPA, 2009) and for the addition of bulk exporters to the threshold analysis (Ottinger, 2009). As described in the referenced reports, this list was developed using information obtained primarily from the Port Import Export Reporting Service (PIERS), a database that collects, organizes and stores bills of lading from port cargo. These data were supplemented with data obtained from industry representatives through the Alliance for Responsible Atmospheric Policy.
Table 5-27 shows the number of facilities that EPA identified for each of the industry segments covered by subpart OO that would report.
Table 5-27. Number of Facilities Reporting by Industry Segment
                                    Segment
                             Number of Facilities
                    Number of Facilities Expected to Report
HFC, PFC, SF6 and NF3 Producers
                                      12
                                      12
N2O Producers
                                       5
                                       5
N2O and Fluorinated GHG Importers
                                      116
                                      61
N2O and Fluorinated Exporters
                                  192-244[a]
                                     89[a]
[a] 	The number of facilities was estimated as an upper bound and lower bound estimate. The data contained many similar, but not identically named companies.

This list of importers and exporters was used to determine the additional facilities that would be required to report under subpart OO if the revised GWPs from the IPCC Fourth Assessment Report were used. The import and export quantities for each importer and exporter were multiplied by the revised GWPs to determine which entities would exceed the threshold of 25,000 metric tons CO2e, and be required to report using the revised GWP. It is estimated that approximately three additional importer or exporter entities would be required to report as a result of the revisions to the GWPs for compounds currently in Table A-1. Table 5-28 identifies the emissions impact from new subpart OO reporters.
                     Table 5-28. New Subpart OO Reporters
                                 Facility Type
                 Number of New Reporters Due to GWP Revisions
OO  -
Industrial GHG Suppliers
                                       3

Subpart OO (estimating emissions impacts)
Each new reporter was estimated to report at the threshold of 25,000 metric tons CO2e because ERG assumed these facilities would only just meet the 25,000 metric tons CO2e reporting threshold. Table 5-29 identifies the emissions impact from new subpart OO reporters.
          Table 5-29. Emissions Impact From New Subpart OO Reporters
                                 Facility Type
                 Incremental CO2e Emissions for New Reporters
                        (metric tons of CO2e per year )
OO  -
Industrial GHG Suppliers
                                    75,000

Subpart OO (estimating cost impacts)
Costs were calculated by multiplying the average costs per facility and the number of new facilities estimated to be subject to subpart OO (from revising the GWPs). Average costs per facility were calculated by dividing total cost by the number of respondents identified in the most recent information collection request for the GHG reporting program (U.S. EPA, 2013).
Appendices G and L to the most recent information collection request for the GHG reporting program (U.S. EPA, 2013) were used to obtain first year average cost per facility that is incurred from reporting under subpart OO. Cost details from Exhibit 6.1 of the most recent information collection request for the GHG reporting program (U.S. EPA, 2013) were used to determine the subsequent years average cost per facility. These average costs per facility include labor costs (i.e., the cost of labor by facility staff to meet the rule's information collection requirements) and non-labor (capital, and operation and maintenance) costs. Additional details of the data, methods, and assumptions underlying these costs are documented in the most recent information collection request (U.S. EPA, 2013).
Table 5-30 shows first and subsequent year average cost per facility subject to subpart OO.
Table 5-30. Annual Average Cost Per Facility Subject to Subpart OO
                                    Subpart
                        Total Number of Respondents [a]
                                  Total Cost
                               (2011$ per year)
                               Cost Per Facility
                               (2011$ per year)

                                First Year [b]
                             Subsequent Years [a]
                                First Year [b]
                             Subsequent Years [a]
OO  -
Industrial GHG Suppliers
                                      49
                                    730,000
                                    163,000
                                     4,400
                                     3,300
[a] This data was extracted from Exhibit 6.1 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013).
[b] The first year total cost, and cost per facility, are based on an estimated 167 respondents (in lieu of 49). The $730,000 value was determined by adding together the "One-Time Costs" ($6,932,000 / 6,616 x 167) and the "OO. Suppliers of Industrial GHG" total cost ($511,000) that are provided in the current burden & cost table in Appendix G-3 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013), and also includes $80.91 from the current burden & cost table identified as "First Reporting Year" table of Appendix L-2 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013). The $80.91 is the cost contributed to provisions of information on parent companies, NAICS codes, and whether emissions are from cogeneration. These costs were updated to 2011 dollars using the Bureau of Labor Statistics Employment Cost Index and the Chemical Engineering Plant Cost Index (CEPCI).

By revising the GWP values in subpart A, three additional facilities will be required to report under subpart OO. The first year cost for these three facilities will be approximately $13,100 per year (3 x $4,370 = $113,100), and the annualized industry wide cost is $10,000 per year (3 x $3,300 = $9,900).
Subpart OO Small Entity Impacts (new reporters)
EPA originally assessed the impact of complying with subpart OO requirements on entities subject to the rule by calculating a cost to sales ratio for eight enterprise size ranges (i.e., all categories, 1 to 20 employees, 20 to 99 employees, 100 to 499 employees, 500 to 749 employees, less than 500 employees, 750 to 999 employees, and 1,000 to 1,499 employees) using the ratio of average total annualized mandatory reporting costs to the average establishments receipts. For this analysis, because the affected establishments are import and export entities with smaller volumes of imported or exported gases, an analysis was performed for the smallest size ranges of entities in the NAICS code 42469 (Other chemical and allied products, merchant wholesalers). Based on the 2007 economic census database published by U.S. Bureau of the Census, the receipts, number of establishments and the average receipts for different size entities is summarized in Table 5-31.
Table 5-31. Sales Test for Subpart OO

                                0- 4 Employees
                                 5-9 Employees
                                10-19 Employees
Average Receipts for each Establishment $
                                   2,557,209
                                   4,737,209
                                  17,593,574
First Year Cost per Entity $
                                     4,370
                                     4,370
                                     4,370
Subsequent Year Cost per Entity $
                                     3,300
                                     3,300
                                     3,300
First Year Sales Test
                                    0.171%
                                    0.092%
                                    0.025%
Subsequent Year Sales Test
                                    0.129%
                                    0.070%
                                    0.019%

The results in Table 5-31 show that the costs for GHG reporting for even the smallest facilities subject to subpart OO are well below 1% of the sales for all entities in the NAICS code 42469. Therefore, there is not a significant economic impact to a substantial number of small entities for the facilities subject to subpart OO as a result of the revised GWPs.
Subpart OO (summary of impacts)
Table 5-32 summarizes the impacts of updating the GWP values in Table A-1 to subpart A, on new facilities required to report subpart OO emissions.
Table 5-32. New Reporters -- Summary of Subpart OO Impacts Due to the Revisions to GWPs
                                 Facility Type
                 Number of New Reporters Due to GWP Revisions
                 Incremental CO2e Emissions for New Reporters
                      (metric tons of CO2e per year ) [a]
                   Incremental Cost Impact For New Reporters
                               (2011$ per year)

                                First Year [a]
                             Subsequent Years [a]
OO  -
Industrial GHG Suppliers
                                       3
                                    75,000
                                    13,100
                                    10,000
[a] Values rounded.
References for Subpart OO
Ottinger, D., 2009. Addition of Bulk Exporters of Fluorinated GHGs, Nitrous Oxide and Carbon Dioxide to Threshold Analysis of Industrial Gas Suppliers. Washington, DC: US EPA. See Docket ID: EPA-HQ-OAR-2008-0508-0230. April 2009.
U.S. EPA, 2009. Additional Methodological Information Supporting Threshold Analysis for Specific Source Categories. See Docket ID: EPA-HQ-OAR-2008-0508-0046. March 2009.
U.S. EPA, 2013.  Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program.  OMB Control No. 2060-0629. EPA ICR No. 2300.10. May 2013.
Subpart TT
Subpart TT applies to industrial waste landfills that accept wastes that have volatile solids concentration above 0.5 percent, that have total landfill design capacity greater than or equal to 300,000 metric tons, and that are located within a facility with GHG emissions equal to or greater than 25,000 metric tons of CO2e per year. Therefore, the GHG emissions from an industrial waste landfill alone cannot determine the applicability of subpart TT and the GHG emissions from the entire facility must be considered.
In general, industrial waste landfills that meet the GHG reporting criteria are co-located with refineries, petrochemical production facilities, pulp and paper mills, and food processing facilities. All refineries and petrochemical production facilities are required to report (no threshold), and all pulp and paper mills are expected to be above the reporting threshold; therefore, all are expected to report under subpart TT if a landfill is present. This impact analysis focuses on the additional industrial waste landfills located in food processing facilities that are subject to subpart TT due to the revised GWP for CH4 from 21 to 25 and the cost associated with these additional landfills subject to subpart TT.
Subpart TT (identifying new reporters)
In the TSD for the Landfill Sector (U.S. EPA, 2009), it was estimated that 200 industrial waste landfills would be subject to subpart TT, including 100 landfills co-located with pulp and paper mills and 100 landfills co-located with food processing facilities. Because landfill emissions are not the primary emissions from pulp and paper mills, the revised CH4 GWP should not affect the subpart TT applicability for pulp and paper facilities.
The number of total food processing facilities has not been updated since the Economic Impact Analysis for the Mandatory Reporting of Greenhouse Gas Emissions: Subparts: T, FF, TT, and II (U.S. EPA, 2010a) was developed in June 2010. According to that economic impact analysis for subpart TT (U.S. EPA, 2010a), the food processing facilities with the following NAICS codes were identified as the potential facilities under subpart TT:
311611  -  Animal (except Poultry) Slaughtering
311411  -  Frozen Fruit, Juice, and Vegetable Manufacturing
311421  -  Fruit and Vegetable Canning
Based on the e-GGRT data for the 2010 reporting year, there are 107 food processing facilities reported with the above three NAICS codes. This is close to the original estimate of 100 food processing facilities in the TSD for the landfill sector (U.S. EPA, 2009). Therefore, the same food processing facilities information in the TSD for the landfill sector (U.S. EPA, 2009) was used to estimate the additional food processing facilities affected by subpart TT due to the revised CH4 GWP.
According to the TSD for the landfill sector (U.S. EPA, 2009), there were 189 food processing facilities (based on 1985 data) and 70 of them have GHG emissions between 10,000 metric tons per year and 25,000 metric tons per year of CO2e based on engineering judgments. The list of the food processing facilities is not available. Assuming that CH4 emissions are the main GHG emissions from food processing facilities, the food processing facilities with GHG emissions between 21,000 metric tons per year and 25,000 metric tons per year of CO2e in the TSD are the additional facilities that could be affected by the revised CH4 GWP from 21 to 25. Assuming an even distribution of facilities across this range of emissions, the number of food processing facilities with CO2e emissions between 21,000 metric tons per year and 25,000 metric tons per year is estimated to be 70 x (25,000  -  21,000) / (25,000  -  10,000) = 19 facilities.
Closed landfills and active landfills that plan to be closed within the next ten years were investigated for potential incremental GHG reporting impacts identically to the analysis conducted for subpart HH. This analysis found that eight currently closed landfills will experience an increased reporting period due to the increased CH4 GWP. No currently active landfills that are planned to shut down in the next ten years were expected to incur prolonged reporting requirements during the next ten years.
Based on the discussions above, Table 5-33 identifies the number of new subpart TT reporters that will become subject to the rule as a result of revisions to the GWPs in Table A-1.
Table 5-33. New Subpart TT Reporters by Type of Industrial Waste Landfill
                       Type of Industrial Waste Landfill
                 Number of New Reporters Due to GWP Revisions
Located in Pulp and Paper Mills
                                       0
Located in Food Processing Facilities
                                      19
Landfills that will Incur Additional Reporting Requirements in the Next Ten Years
                                       8
                                     Total
                                      27
Subpart TT (estimating emissions impacts)
From Table 5-33, there would be 19 additional facilities subject to subpart TT due to the revised CH4 GWP. Emissions from these 19 additional facilities were estimated by multiplying the number of new affected facilities (19) by the average CH4 generation for each new affected facility. The average CH4 generation for each new affected facility is assumed to be (25,000 + 21,000)/2 x 25/21 = 27,381 metric tons/yr of CO2e. The amount of CO2 equivalent has been adjusted using the new GWP for CH4 of 25. Therefore, the total CH4 generation for all new affected facilities combined is equal to about 520,000 metric tons/yr of CO2e (19 x 27,381 = 520,239). Table 5-34 identifies the emissions impact from new subpart TT reporters.
          Table 5-34. Emissions Impact From New Subpart HH Reporters
                                 Facility Type
                 Incremental CO2e Emissions for New Reporters
                        (metric tons of CO2e per year )
TT  -
Industrial Waste Landfills
                                    520,000

Subpart TT (estimating cost impacts)
Costs were calculated by multiplying the average costs per facility and the number of new facilities estimated to be subject to subpart TT (from revising the GWPs). Average cost per facility for the first year was calculated by dividing total cost by the number of respondents identified in the initial information collection request for subpart TT (U.S. EPA, 2010b). Average cost per facility for subsequent years was calculated by dividing total cost by the number of respondents identified in the most recent information collection request for the GHG reporting program (U.S. EPA, 2013).
Appendix A to the initial information collection request for subpart TT (U.S. EPA, 2010b) was used to obtain first year average cost per facility that is incurred from reporting under subpart TT. Cost details from Exhibit 6.1 of the most recent information collection request for the GHG reporting program (U.S. EPA, 2013) were used to determine the subsequent years average cost per facility. These average costs per facility include labor costs (i.e., the cost of labor by facility staff to meet the rule's information collection requirements) and non-labor (capital, and operation and maintenance) costs. Additional details of the data, methods, and assumptions underlying these costs are documented in the information collection requests (U.S. EPA, 2010b and U.S. EPA, 2013).
Table 5-35 shows first and subsequent year average cost per facility subject to subpart TT.
Table 5-35. Annual Average Cost Per Facility Subject to Subpart TT
                                    Subpart
                        Total Number of Respondents [a]
                                  Total Cost
                               (2011$ per year)
                               Cost Per Facility
                               (2011$ per year)

                                First Year [b]
                             Subsequent Years [a]
                                First Year [b]
                             Subsequent Years [a]
TT  -
Industrial Waste Landfills
                                      200
                                   1,182,000
                                    881,000
                                     5,900
                                     4,400
[a] This data was extracted from Exhibit 6.1 of the Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program (U.S. EPA, 2013).
[b] This data was extracted from the "Year 1" table of Appendix A to the initial information collection request for subpart TT (U.S. EPA, 2010b). These costs were updated to 2011 dollars using the Bureau of Labor Statistics Employment Cost Index and the Chemical Engineering Plant Cost Index (CEPCI).

By revising the GWP values in subpart A, 19 additional facilities will be required to report under subpart TT. The first year cost for these 19 facilities will be approximately $112,000 per year (19 x $5,900 = $112,300), and the annualized industry wide cost is approximately $83,700 per year (19 x $4,400 = $83,695). An additional eight closed landfills will experience an incremental reporting burden over the next ten year period, due to an extended number of years reporting would be required; total additional rule implementation costs would be $120,400 for these landfills over that ten year period, or an average of $12,000 per year. This includes applying extended subsequent year reporting costs for eight currently closed landfills that will experience an increased reporting period due to the increased CH4 GWP, as summed over a ten-year period. A year-over-year breakdown of these costs is included in Section 5.7.5 below.
Subpart TT Small Entity Impacts (new reporters)
The small entity economic impact was measured using the "sales tests" approach (represented as cost-to-receipt ratios) for NACIS codes associated with the affected subparts in the Economic Impact Analysis for Subpart TT (U.S. EPA, 2010a). The same approach is used in this analysis for the additional facilities subject to subpart TT due to the revised CH4 GWP. If the ratio of rule implementation cost to sales is less than 1%, the impact is not considered to be significant (U.S. EPA, 2010a).
Based on the information provided in Tables 5-10 (Number of Establishments) and 5-11 (Receipts by Industry and Enterprise Size, in 2002 dollars) of the Economic Impact Analysis for Subpart TT (U.S. EPA, 2010a), the average receipts (sales) for the food processing facilities with NAICS codes of 311611, 311411, and 311421 were calculated by dividing the total receipts information by the number of establishments for each enterprise size. In addition, the average receipts information has been adjusted from 2002 dollars to 2011 dollars based on the consumer price index published by Bureau of Labor Statistics. These results are shown in Table 5-36.
Table 5-36. Average Receipts for Each Establishment by Enterprise Size (million, 2011$)
                                     NAICS
                               NAICS Description
                               SBA Size Standard
                          Owned by Enterprises with:

                                     1-19
                                   Employees
                                20-99 Employees
                               100-499 Employees
                               500-749 Employees
                               750-999 Employees
                             1,000-1,499 Employees
                                    311611
                     Animal (except Poultry) Slaughtering
                                 500 employees
                                     1.31
                                     25.38
                                       D
                                       D
                                   1,412.28
                                       D
                                    311411
             Frozen Fruit, Juice, and Vegetable Manufacturing, and
                                 500 employees
                                     2.47
                                     45.87
                                     10.46
                                       D
                                    234.82
                                       D
                                    311421
                          Fruit and Vegetable Canning
                                 500 employees
                                     1.78
                                     20.77
                                     14.77
                                     54.92
                                    139.00
                                       D
Note: D denotes that receipt data was not disclosed.

Although the number of establishment information has been updated in the 2007 economic census, there is no updated receipts (sales) information for each size of enterprise. According to the cost information listed in Table 5-35, the rule implementation costs for subpart TT is $5,900 for the first year and $4,400 for the subsequent years (in 2011 dollars). The sales tests (cost-to-receipt ratios) results are shown in Table 5-37 for the first year and Table 5-38 for the subsequent years.
Table 5-37. Sales Tests for Subpart TT Facilities: First Year
                                     NAICS
                               NAICS Description
                               SBA Size Standard
                          Owned by Enterprises with:

                                     1-19
                                   Employees
                                20-99 Employees
                               100-499 Employees
                               500-749 Employees
                               750-999 Employees
                             1,000-1,499 Employees
                                    311611
                     Animal (except Poultry) Slaughtering
                                 500 employees
                                     0.45%
                                     0.02%
                                       D
                                       D
                                     0.00%
                                       D
                                    311411
               Frozen Fruit, Juice, and Vegetable Manufacturing
                                 500 employees
                                     0.24%
                                     0.01%
                                     0.06%
                                       D
                                     0.00%
                                       D
                                    311421
                          Fruit and Vegetable Canning
                                 500 employees
                                     0.33%
                                     0.03%
                                     0.04%
                                     0.01%
                                     0.00%
                                       D
Note: D denotes that receipt data was not disclosed.

Table 5-38. Sales Tests for Subpart TT Facilities: Subsequent Years
                                     NAICS
                               NAICS Description
                               SBA Size Standard
                          Owned by Enterprises with:

                                     1-19
                                   Employees
                                20-99 Employees
                               100-499 Employees
                               500-749 Employees
                               750-999 Employees
                             1,000-1,499 Employees
                                    311611
                     Animal (except Poultry) Slaughtering
                                 500 employees
                                     0.34%
                                     0.02%
                                       D
                                       D
                                     0.00%
                                       D
                                    311411
               Frozen Fruit, Juice, and Vegetable Manufacturing
                                 500 employees
                                     0.18%
                                     0.01%
                                     0.04%
                                       D
                                     0.00%
                                       D
                                    311421
                          Fruit and Vegetable Canning
                                 500 employees
                                     0.25%
                                     0.02%
                                     0.03%
                                     0.01%
                                     0.00%
                                       D
Note: D denotes that receipt data was not disclosed.

The results in Tables 5-37 and 5-38 show that the costs for GHG reporting for the facilities subject to subpart TT is well below 1% of the sales for all size of Waste Management and Remediation Services facilities with a NAICS code of 562. Therefore, it was determined that there is not a significant impact on a substantial number of small businesses subject to reporting under subpart TT as a result of this action.
Subpart TT (summary of impacts)
Table 5-39 summarize the impacts of updating the GWP values in Table A-1 to subpart A, on new facilities required to report subpart TT emissions. The incremental reporting burden is provided in year-over-year format in Table 5-40 for both the new reporters and the eight closed facilities that would trigger extended reporting requirements over the following ten years.
Table 5-39. New Reporters -- Summary of Subpart TT Impacts Due to the Revisions to GWPs
                                 Facility Type
                 Number of New Reporters Due to GWP Revisions
                 Incremental CO2e Emissions for New Reporters
                      (metric tons of CO2e per year ) [a]
                   Incremental Cost Impact For New Reporters
                               (2011$ per year)

                                First Year [a]
                             Subsequent Years [a]
TT  -
Industrial Waste Landfills
                                      19
                                    520,000
                                    112,000
                                    83,700
[a] Values rounded.
The incremental reporting burden is provided in year-over-year format in Table 5-22 for both the new reporters and the eight closed facilities that would trigger extended reporting requirements over the following ten years. The costs for closed facilities were calculated based on applying subsequent year costs ($4,400 per facility) to the facilities identified (see Section 5.7.1) in each year for which the facility would be subject to extended reporting requirements or would be brought into Part 98. No currently active landfills that are planned to shut down in the next ten years were expected to incur prolonged reporting requirements during the next ten years.
Table 5-40. Summary of Subpart TT Cost Impacts
                                    $/year
                                     2015
                                     2016
                                     2017
                                     2018
                                     2019
                                     2020
                                     2021
                                     2022
                                     2023
                                     2024
                         Landfills Closed before  2024
                                     8,800
                                     4,400
                                     4,400
                                       0
                                     8,800
                                    13,200
                                    17,600
                                    23,500
                                    17,600
                                    22,000
                                 New Reporters
                                    112,000
                                    83,700
                                    83,700
                                    83,700
                                    83,700
                                    83,700
                                    83,700
                                    83,700
                                    83,700
                                    83,700
                                   Total[a]
                                    120,800
                                    88,100
                                    88,100
                                    83,700
                                    92,500
                                    96,900
                                    101,300
                                    107,200
                                    101,300
                                    105,700
[a]	Total average Incremental Cost Impact for New Reporters and Reporters with Extended Reporting Requirements is $98,580 per year.
References for Subpart TT
U.S. EPA, 2009. Technical Support Document For the Landfill Sector: Proposed Rule For Mandatory Reporting Of Greenhouse Gases. See Docket ID: EPA-HQ-OAR-2008-0508-0034. February 4, 2009.
U.S. EPA 2010a. Economic Impact Analysis for the Mandatory Reporting of Greenhouse Gas Emissions: Subparts: T, FF, TT, and II. See Docket ID: EPA-HQ-OAR-2008-0508-2313. June 2010.
U.S. EPA, 2010b. Supporting Statement Part A: Information Collection Request for the Mandatory Reporting of Greenhouse Gases from Magnesium Production, Underground Coal Mines, Industrial Wastewater Treatment, and Industrial Waste Landfills  -  Final Rule. OMB Control No. 2060-0647. EPA ICR No. 2396.01. July 2010.
U.S. EPA, 2013.  Supporting Statement Part A: Information Collection Request For The Greenhouse Gas Reporting Program.  OMB Control No. 2060-0629. EPA ICR No. 2300.10. May 2013.
impacts of Other technical corrections and amendments
In addition to the amendments to GWPs, EPA is also finalizing technical corrections and other clarifications to several subparts in the GHG reporting rule. In this section, we discuss the potential burden impacts for facilities and reporters affected by the amendments. The more substantive technical corrections, clarifying and other amendments to the GHG reporting rule are discussed here. Additional minor corrections are discussed in the memorandum titled "Table of 2013 Technical Corrections, Clarifying and other Amendments to Certain Provisions of the Mandatory Greenhouse Gas Reporting Rule (40 CFR Part 98)," which is available in the rulemaking docket.
Subpart A - General Provisions
The majority of the revisions to subpart A are associated with changes to additions of GWP values and provisions that apply to facilities that would be required to report based on the revised GWPs. The remaining amendments to subpart A include adding requirements that provide reporters instruction regarding reporting of location, ownership, and facility identification (i.e., reporting of plant codes). The remaining changes also include revising and adding definitions. Except for the amendments related to the GWP changes, the amendments to subpart A are not expected to result in any additional burden for facilities subject to the GHG reporting rule. All of the revisions not related to the GWP changes are either clarifications, or require reporting of information that facilities are expected to have readily available (e.g., latitude and longitude of the facility).
Subpart C - General Stationary Fuel Combustion Sources
For subpart C, EPA is expanding the use of the Tier 1 methodology to be used for Table C-1 fuels that are combusted in a unit with a maximum rated heat input capacity greater than 250 mmBtu/hr, if the fuel provides less than 10 percent of the annual heat input to the unit and the use of Tier 4 is not required. Expanding the use of the Tier 1 methodology is expected to reduce monitoring burden for facilities that are subject to the requirements of subpart C and combust small amounts of secondary fuels.
EPA is also revising several emission factors and higher heating values (HHVs) for fuels in Table C-1 including, but not limited to, coals and coke, liquefied petroleum gases (e.g. propane, propylene, ethane, etc.), wood and wood residuals, and biogases. Of the changes to emission factors, the change with the largest percent difference (approximately 11 percent) is the emission factor for coke (which is also being revised to read "coal coke"). Approximately 1.6 percent of facilities that reported under subparts C and D for reporting year 2011 indicated using coke as a fuel for combustion in addition to other fuels. The majority of coal coke produced (92 percent) in the United States is used in blast furnaces for the conversion of iron ore into iron (U.S. EPA, 2001).  The emission factor for coal coke is not used in the calculation of CO2 emissions for iron furnaces. Due to the small number of facilities that reported using coke as a fuel, and because facilities do not typically use coke as the primary fuel, we do not expect any additional facilities would be required to report due to an increase in calculated CO2 emissions resulting from the increase to the coke emission factor in Table C-1.
All of the other revisions are either clarifications, or require reporting of information that facilities are expected to have readily available (plant code for each power generating unit).
Subpart H  -  Cement Production
EPA is requiring annual, facility-wide cement production instead of monthly, kiln-specific cement production for facilities that use a CEMS to measure CO2 emissions. Because facilities already expected to track facility-wide cement production for budgeting purposes, we do not expect this revision to result in any additional burden for cement production facilities.
Subpart K  -  Ferroalloy Production
EPA is finalizing two changes to subpart K. The first change corrects a conversion factor in equation K-3 and we do not expect any additional reporter burden as a result. The second change requires facilities to report the annual process CH4 emissions from each electric arc furnace (EAF) used for the production of any ferroalloy listed in Table K-1 of subpart K. Because facilities must already monitor and calculate emissions of CH4 from each EAF, we do not expect that the changes would impose and additional burden on reporters. The data element reflects aggregated annual information that is currently gathered by reporters.
Subpart L  -  Fluorinated Gas Production
EPA is extending temporary, less detailed reporting requirements to allow EPA time to evaluate concerns raised by producers regarding the potential sensitivity of the more detailed reporting required by the 2010 final rule. As the revision would be an extension of existing requirements, we do not anticipate any additional reporter burden as a result.
Subpart N  -  Glass Production
In addition to clarify several requirements and equations terms, EPA is revising the monitoring methods used to measure carbonate-based mineral mass-fractions to allow for more accurate measurement methods and provide flexibility for reporters. EPA is requiring that facilities use consensus standards that specify X-ray fluorescence (XRF). To determine if requiring XRF methods would impose any additional burden, we compared the cost of the currently required methods to methods using XRF. The costs of ASTM D-3682 and D-6349 are listed as $165 from Wyoming Analytical Laboratories (WAL). The costs of similar analyses using XRF (ASTM D-4326) range from $165 to $195 according to WAL (WAL, 2009). Based on the similarity in cost, we do not believe that revising the measurement methods to specify XRF will impose any additional burden on facilities subject to subpart N.
Subpart P  -  Hydrogen Production
EPA is finalizing several amendments to subpart P including adding flexibility for monitoring and measurement methodologies and removing redundant reporting requirements. EPA is also finalizing changes that clarify rule text and equation terms. None of the amendments for subpart P are expected to impose any additional burden on reporters.
Subpart Q  -  Iron and Steel Production
EPA is finalizing multiple amendments to subpart Q to clarify certain provisions and calculation methods. Two of the revisions may potentially affect the reporting burden for facilities covered under subpart Q. First, EPA is including direct reduction furnaces not co-located with an integrated iron and steel manufacturing process, as these furnaces were inadvertently excluded from the original rulemaking. Because this change only impacts one facility that is already reporting under subpart Q, we do not anticipate this change will impose any additional burden on reporters.
Second, EPA is amending Equation Q-5 in subpart Q to account for the use of gaseous fuels in EAFs. Because facilities currently determine the mass rate of fuels using the procedures in subpart C and must report the annual volume of gaseous fuels, we do not expect that reporters will need to collect or record any additional information to account for the use of gaseous fuels in equation Q-5 in subpart Q. Therefore, we do not expect any additional burden will be imposed on reporters subject to subpart Q.
Subpart X  -  Petrochemical Production
EPA is finalizing several substantial changes to subpart X. EPA is requiring reporters using CEMS to determine CO2 emissions to use Equation C-10 of subpart C to Part 98 to calculate CH4 and N2O emissions from burning process off-gas. We do not expect an increase in burden since Tier 4 units can use best available information to estimate fuel use (see 40 CFR 98.22(c)(4)(i) and 40 CFR 98.33(c)(4)(ii)(C)).
EPA is also finalizing several changes for those reporters that use the mass balance calculation method. First, EPA is allowing flexibility for the source of the carbon measurements for feedstocks and products. Next, EPA is allowing the alternative sampling requirements for feedstocks and products when the composition is greater than 99.5 percent of a single compound to be used during all times that the average monthly concentration is above 99.5 percent. Additionally, EPA is allowing the inputs for gaseous feedstock and products to be measured on either a mass basis or on a volume basis in Equation X-1. EPA is also allowing facilities to use industry standard practices for the analysis of carbon black feedstock oils and carbon black products, instead of a specified list of standards currently provided in 40 CFR 98.244(b)(4). We do not anticipate any additional burden as a result of these changes since they allow additional flexibility for reporters.
EPA is clarifying the requirements for flares to specify that facilities must conduct monitoring and quality assurance in accordance with 40 CFR 98.254(b) through (e) for each flare gas flow meter, gas composition meter, and/or heating value monitor that is used to comply with 40 CFR 98.253(b)(1) through (3), which was EPA's original intent. We are specifying in the final amendments that reports must implement the applicable QA/QC requirements by January 1, 2015. Since the change is a clarification, we do not expect any additional burden as a result.
EPA is clarifying the missing data procedures for missing feedstock and product flow rates, missing feedstock and product carbon contents, and missing molecular weights for gaseous feedstocks and products. EPA is also adding missing data requirements for flares. Because these amendments only clarify the existing missing data procedures for subpart X facilities, we do not expect these amendments will impose any additional burden on reporters.
Additionally, EPA is finalizing several amendments to reporting requirements. The majority of amendments to the reporting requirements are clarifications; however, one particular amendment would require facilities to identify combustion units that burned both process off-gas and supplemental fuel and that are not part of the petrochemical process unit. EPA is also finalizing a requirement for facilities to provide an estimate of the fraction of total CO2 emissions that result from CO2 directly emitted by the petrochemical process unit plus CO2 generated by the combustion of off-gas from the petrochemical process unit (based on engineering judgment) if the CEMS monitoring location meets the conditions in 40 CFR 98.426(b)(2) or (3). Although these are new reporting requirements, facilities would not be required to install any additional monitoring equipment or develop any additional monitoring and record keeping procedures; therefore, we do not expect these additional reporting requirement to significantly increase burden for facilities reporting under subpart X.
Subpart Z  -  Phosphoric Acid Production
EPA is finalizing several clarifying amendments to subpart Z, phosphoric acid production. Of those amendments, EPA is changing the reporting requirement of the annual permitted phosphoric acid production capacity to the annual phosphoric acid production capacity. We do not expect this change to impose any additional burden on reporters since the information should be readily available in facility records. EPA is also adding a reporting requirement to report the number of times missing data procedures were used to estimate the CO - 2 content of the phosphate rock. Again, we do not expect any additional burden for reporters as a result of this change because facilities are already required to keep records for estimating missing values of CO - 2 content of phosphate rock per 40 CFR 98.265(a), and no new information would need to be collected.
Subpart AA  -  Pulp and Paper Production
EPA is correcting emission factors and clarifying the information that must be reported under subpart AA. First, EPA is removing the references to site-specific emission factors in 40 CFR 98.273(a)(3), 40 CFR 98.276(e) and Equation AA-1. EPA is also correcting printing errors, inadvertent omissions, and inconsistencies from Table AA-1 and AA-2. We do not anticipate any additional burden due to these changes since no additional reporting requirements or monitoring would be required.
EPA is also amending the reporting requirement for the annual pulp and/or paper production information that must be reported. EPA is clarifying that the annual production information must consist of the production of unbleached virgin pulp produced onsite during the reporting year and removed the proposed requirement that the production of paper products exiting the paper machine(s) during the reporting year, prior to application of any off-machine coatings be reported. In the final amendments we removed the proposed requirement to report a positive (non-zero) value for pulp production. EPA clarified the production reporting requirement under 40 CFR 98.276(k) in the "Frequently Asked Questions" section of EPA's supporting website for the GHG reporting rule. In their guidance, EPA specified that facilities should report virgin chemical pulp production at the mill separate from the mass of paper product exiting all of the paper machine(s) at the mill; therefore, EPA is clarifying the reporting requirement and removing the requirement to report paper production. No new reporting or monitoring would be required by reporters. As a result, we do not expect the clarification to the rule to impose any additional burden on reporters.
Subpart BB  -  Silicon Carbide Production
For subpart BB, Silicon Carbide Production, EPA is removing the requirement for facilities to report CH4 emissions from silicon carbide process units or furnaces. Additionally, EPA is amending subpart BB such that facilities would calculate and report CO2 emissions for all process units and furnaces combined, instead of each process unit or production furnace. The remaining changes to subpart BB either support these amendments, or provide minor clarifications of the rule text. We expect that both of these major changes will reduce the reporting burden for facilities subject to subpart BB.
Subpart DD  -  Electrical Transmission and Distribution Equipment Use
EPA is finalizing two technical corrections to subpart DD to correct the accuracy and precision requirements for weighing cylinders. Instead of scale accuracies of "2 pounds of the scale's capacity," EPA is revising the rule to be consistent with their original intention of "2 pounds of true weight." This accuracy requirement was noted in the technical support document to subpart DD, EPA's response to public comments for subpart DD, and the preamble to the final Part 98 (74 FR 56260, October 30, 2009). In their response to comments, EPA noted that a "2 pounds of true weight" requirement would be less burdensome than the 1 percent of true weight requirement originally proposed; therefore, we do not expect any added burden would result from amending the rule to reflect EPA's original intent.
 Subpart FF  -  Underground Coal Mines
EPA finalizing numerous amendments to subpart FF. The majority of the changes include terminology revisions that more accurately reflect industry operations, correction of subscript errors, and minor clarifications of rule text. More substantially, EPA is including the reporting of the following data elements: the moisture correction factor used in the emissions equations; units of measure for the volumetric flow rates reported; method of determining the gas composition; the start date and close date of each well, shaft, or vent hole; the number of days the well, shaft, or vent hole was in operation during the reporting year; the amount of CH4 routed to each destruction device; and the identification number assigned by the Mine Safety and Health Administration (MSHA). All of these data elements are readily available to reporters and would not require additional data collection or monitoring; therefore, we do not expect the changes to subpart FF would impose any significant additional burden to covered facilities.
Subpart HH  -  Municipal Solid Waste Landfills
For subpart HH, EPA is removing the option to used measured values for the degradable organic carbon content in Equation HH-1. EPA is also clarifying that the fraction by volume of CH4 in the landfill gas, used in Equation HH-1, should be corrected to zero percent oxygen. Additionally, EPA is reducing the measurement frequency for sampling methane concentrations from weekly to monthly for the parameter "N" in Equation HH-4. To clarify how to calculate methane emissions at landfills with gas collection systems that have multiple measurement locations and/or multiple destruction devices, EPA is amending Equations HH-6, HH-7, and HH-8 and surrounding text to generalize these equations and to refer to oxidation fractions in Table HH-4. EPA is finalizing the oxidation fraction values in Table HH-4 as proposed, with the exception that we are limiting the landfills that can use these new methane flux-dependent oxidation fractions to those that have cover soils of 24 inches or more over a majority of the landfill area containing waste.
EPA is also making several more minor clarifications and amendments including removing duplicative reporting requirements. We are finalizing amendments that methane recovery calculated using Equation HH-4 and the annual operating hours of the gas collection systems are to be reported separately for each measurement location. Because 40 CFR 98.343(b)(1) and (2) require use of Equation HH-4 separately for each monitoring location, it is clear that the methane recovery and the fraction of hours the recovery system operated needs to be determined separately for each measurement location as these are separate inputs for Equations HH-6 and HH-8 when multiple measurement locations are used. Since this change is a clarification, we do not expect any additional burden as a result.
We are making one revision to subpart HH based on comments received on the expansion of applicability that will occur in the MSW Landfill sector due to the revision of the GWP for methane to the IPCC AR4 value. Specifically, we are providing a very limited exclusion within 40 CFR 98.340 for certain closed landfills that have not previously had to report under subpart HH, but would newly be required to report starting in reporting year 2014 because the amended methane GWP causes them to exceed the 25,000 metric tons CO2e emissions threshold for the first time. We have added this exclusion to reduce the burden for these closed landfills, who would otherwise be required to estimate historical waste quantities and develop their first annual report, as discussed in Section 5.4 of this document.
Facilities are not required to report any additional data elements, or implement any additional monitoring equipment or procedures as a result of these amendments. Therefore, we do not expect any additional burden for reporters subject to subpart HH as a result of these revisions.
Subpart LL  -  Suppliers of Coal-based Liquid Fuels
EPA is finalizing several amendments to subpart LL. In addition to clarifying reporting requirements, EPA is removing the requirements at 40 CFR 98.386(a)(1), (a)(5), (a)(13), (b)(1) and (c)(1) for each facility, importer, and exporter to report the annual quantity of each product or natural gas liquid on the basis of the measurement standards method or industry standard practice used. We expect a reduction in burden for reporters subject to subpart LL since EPA is removing reporting requirements from the rule.
Subpart MM  -  Suppliers of Petroleum Products
In addition to several minor correction and clarifications, EPA is finalizing several substantial technical corrections for subpart MM. First, EPA is amending the equipment calibration requirements for petroleum products suppliers to be consistent with other Part 98 calibration requirements to allow for postponement of calibrations for units and processes that operate continuously with infrequent outages and therefore provide flexibility for reporters meeting the equipment calibration requirements. Next, EPA is removing the requirements of 40 CFR 98.396(a)(1), (a)(5), (a)(13), (b)(1) and (c)(1) for each facility, importer, and exporter to report the annual quantity of each petroleum product or natural gas liquid on the basis of the measurement standard method or industry standard practice used. EPA is also removing the requirements of 40 CFR 98.396(a)(4), (a)(8), (a)(15), (b)(4), and (c)(4) for each facility, importer, and exporter to report a complete list of methods used to measure the annual quantities reported for each product or natural gas liquid. In another step to reduce recordkeeping and reporting burden, the reporting requirements for crude oil at 40 CFR 98.396(a)(20) are changed to require only the annual quantity of crude oil. EPA is also eliminating the requirement to measure the API gravity of each batch of crude oil at 40 CFR 98.394(d). EPA is adding and revising several definitions and revising the default density and emission factors in Table MM-1 in subpart MM. We expect that the changes to subpart MM will provide additional flexibility for reporters and reduce the reporting and recordkeeping burden for those facilities required to report under subpart MM.
Subpart NN  -  Suppliers of Natural Gas Liquids
EPA is finalizing several technical corrections to subpart NN. In addition to minor changes, EPA is finalizing several amendments that may affect the reporting burden of facilities subject to subpart NN. First, EPA is amending the definition of Local Distribution Companies (LDS) to clarify that for LDCs that operate in multiple states, the operations in each state are considered a separated LDC. EPA is also clarifying that interstate and intrastate pipelines delivering natural gas either directly to major industrial users or to farm taps upstream of the LDC inlet are not included in the definition of an LDC. We do not expect these clarifications to impose any additional burden on reporters. In "Q286" of the "Frequently Asked Questions" section of EPA's supporting website for the GHG reporting rule, EPA initially clarified its intent that the owner/operator of each LDC that is regulated as a separate operating company by State public utility commissions or that operate as independent municipally - owned distribution systems must submit an annual report. Therefore, the clarifications are a follow-up to previous guidance and we do not expect any additional owners/operators would be required to report as a result of the change.
EPA is also changing the calculation and reporting requirements that require LDCs to report the annual volume of natural gas delivered to each meter registering supply equal to or greater than 460,000 million standard cubic feet (Mscf). EPA is finalizing a requirement that if the LDC knows based on readily available information that multiple meters serve one large end user facility (defined in the final rule as a facility receiving a total of greater than 460,000 Mscf during the year), the LDC would be required to report these deliveries per facility rather than per meter. If the LDC does not know if the series of meters serve an individual end user or multiple facilities, the LDC may continue to report deliveries to individual meters. Because LDCs would be able to report on a per facility, rather than per meter basis, we expect a reduction in the reporting burden as a result of this change.
EPA is amending part of the calculation methodology in subpart NN. Subpart NN currently requires the use of a single emission factor for all types of gas streams accounted for in Equation NN-5. Because the characteristics of these streams may differ, EPA is replacing equation NN-5 with two equations, NN-5a and NN-5b. The greenhouse gas quantity associated with the net amount of natural gas that is placed into or removed from storage during the year is to be calculated using equation NN-5a. Emissions that would result from the combustion or oxidation of natural gas received by the LDC that bypassed the city gate are calculated using Equation NN-5b, which allows the use of different emission factors for different streams of gas. Additionally, EPA is changing Equation NN-6 to incorporate the two NN-5 equations.  Reporters would only be required to modify their calculation methodology and would not be required to install any additional monitoring equipment. Therefore, we do not expect any additional burden on facilities required to report under subpart NN as a result of these changes.
EPA is also requiring the reporting of the quantity of o-grade, y-grade, and other types of bulk natural gas liquids (NGLs) received, and the quantity not fractionated, but supplied downstream. We do not anticipate that reporters would be required to purchase or install any new monitoring equipment as a result of these reporting requirements since (per 40 CFR 98.404(a)(1)) fractionators and LDCs are required to determine quantities using methods in common use in the industry for billing purposes as audited under existing Sarbanes Oxley regulation.
Subpart QQ  -  Importers of Exporters of Fluorinated Greenhouse Gases Contained in Pre-Charged Equipment of Closed Cell Foams
EPA is finalizing multiple revisions to subpart QQ. In addition to minor corrections and clarifications, EPA is removing the following reporting requirements: 40 CFR 98.436(a)(5), (a)(6)(iv), (b)(5), and (b)(6)(iv). We expect that the removal or reporting requirements will alleviate reporting burden for facilities required to report under subpart QQ.
Subpart RR  -  Geologic Sequestration of Carbon Dioxide
In addition to minor corrections and clarifications to subpart RR, EPA is adding a reporting requirement for facilities to report the standard or method used to calculate the mass or volume of contents in containers that is redelivered to another facility without being injected into the well. The data element does not require additional data collection or monitoring from reporters, and as it is not a significant change. Therefore, we do not expect that this amendment would add burden to reporting entities.
Subpart TT  -  Industrial Waste Landfills
EPA is finalizing multiple changes to subpart TT. EPA is revising definitions in Equation TT-1 and TT-7 and to correct Equation TT-7 by deleting an erroneous term. EPA is also making a change to clarify that the number of waste streams for which Equation TT-1 is used includes the number of "Inert" waste streams disposed of in the landfill. Additionally, EPA is expanding the provisions to determine volatile solids concentration for historically managed waste streams so that they may also be used for determining a site-specific DOC value for historically managed waste streams. EPA is also eliminating duplicative reporting requirements and to clarify the requirements for reporters when using Equations TT-4a or TT-4b. EPA is finalizing amendments to revise the oxidation fraction default value ("OX") in Equation TT-6 to reference the new default oxidation factors in Table HH-4; however, we have revised the amendments to limit  the new oxidation factors to landfills with soil covers of at least 24 inches for a majority of the landfill area containing waste, and to allow the continued use of the 0.10 default oxidation factor for facilities that do not meet these requirements. EPA is also making changes to Table TT-1 to include the DOC default value of 0.09 for "Industrial Sludge," and the corresponding k-values. None of the changes to subpart TT would require any additional monitoring or recordkeeping and reporting by facilities, therefore we do not anticipate any additional burden as a result of the changes to subpart TT.
Subpart UU  -  Injection of Carbon Dioxide
EPA is finalizing technical amendments to subpart UU. In particular, EPA is adding two reporting requirements. First, reporters would be required to report the purpose of CO2 injection. Second, facilities would be required to report the standard or method used to calculate the parameters for CO - 2 received in containers. Neither of these reporting requirements would require facilities to collect any additional data or install and operate any additional monitoring equipment. As a result, we do not expect the changes would impose any additional significant burden on facilities required to report un_)der subpart UU.
Additional Subparts with Corrections
EPA is finalizing several changes to subparts E, G, O, S, V, Y, II, PP, and SS; however, all of the changes are clarifications and/or corrections for consistency throughout the subparts. Therefore, we do not expect any additional burden for facilities subject to the reporting requirements of subpart E, G, O, S, V, Y, II, PP, and SS as a result of these changes.
References for Section 6
U.S. EPA, 2001. National Emission Standards for Hazardous Air Pollutants (NESHAP) for Coke Ovens: Pushing, Quenching, and Battery Stacks  -  Background Information for Proposed Standards. EPA-453/R-01-006. Available at: http://www.epa.gov/ttn/atw/coke2/coke2p_bid.pdf.
WAL, 2009. Wyoming Analytical Laboratories, Inc. Prices as of Spring 2009. Available at: http://www.wal-lab.com/DownloadFiles/CementFlyAsh%20SoilsOverb.pdf.

                                  Appendix A
                        GWPs  - Revisions to Table A-1

Appendix A: GWPs Revisions to  Table A-1 of Subpart A
                                     Name
                                    CAS No.
                               Chemical Formula
                 Table A-1 Global Warming Potential
(100 yr.)
              New or Revised Global Warming Potentials
(100 yr.)
                                   Increase
                                  % Increase
Carbon Dioxide

CO2
                                                                              1
                                                                              1
                                                                            --
                                                                            --
Methane
                                                                        74-82-8
CH4
                                                                             21
                                                                             25
                                                                              4
                                                                            19%
Nitrous oxide
                                                                 10024 - 97 - 2
N2O
                                                                            310
                                                                            298
                                                                            -12
                                                                            -4%
HFC - 23
                                                                    75 - 46 - 7
CHF3
                                                                         11,700
                                                                         14,800
                                                                          3,100
                                                                            26%
HFC - 32
                                                                    75 - 10 - 5
CH2F2
                                                                            650
                                                                            675
                                                                             25
                                                                             4%
HFC - 41
                                                                   593 - 53 - 3
CH3F
                                                                            150
                                                                             92
                                                                            -58
                                                                           -39%
HFC - 125
                                                                   354 - 33 - 6
C2HF5
                                                                          2,800
                                                                            500
                                                                         -2,300
                                                                           -82%
HFC - 134
                                                                   359 - 35 - 3
C2H2F4
                                                                          1,000
                                                                          1,100
                                                                            100
                                                                            10%
HFC - 134a
                                                                   811 - 97 - 2
CH2FCF3
                                                                          1,300
                                                                          1,430
                                                                            130
                                                                            10%
HFC - 143
                                                                   430 - 66 - 0
C2H3F3
                                                                            300
                                                                            353
                                                                             53
                                                                            18%
HFC - 143a
                                                                   420 - 46 - 2
C2H3F3
                                                                          3,800
                                                                          4,470
                                                                            670
                                                                            18%
HFC - 152
                                                                   624 - 72 - 6
CH2FCH2F
                                                                             53
                                                                             53
                                                                              0
                                                                             0%
HFC - 152a
                                                                    75 - 37 - 6
CH3CHF2
                                                                            140
                                                                             38
                                                                           -102
                                                                           -73%
HFC - 161
                                                                   353 - 36 - 6
CH3CH2F
                                                                             12
                                                                             12
                                                                              0
                                                                             0%
HFC - 227ea
                                                                   431 - 89 - 0
C3HF7
                                                                          2,900
                                                                          3,220
                                                                            320
                                                                            11%
HFC - 236cb
                                                                   677 - 56 - 5
CH2FCF2CF3
                                                                          1,340
                                                                          1,340
                                                                              0
                                                                             0%
HFC - 236ea
                                                                   431 - 63 - 0
CHF2CHFCF3
                                                                          1,370
                                                                          1,370
                                                                              0
                                                                             0%
HFC - 236fa
                                                                   690 - 39 - 1
C3H2F6
                                                                          6,300
                                                                          9,810
                                                                          3,510
                                                                            56%
HFC - 245ca
                                                                   679 - 86 - 7
C3H3F5
                                                                            560
                                                                            693
                                                                            133
                                                                            24%
HFC - 245fa
                                                                   460 - 73 - 1
CHF2CH2CF3
                                                                          1,030
                                                                          1,030
                                                                              0
                                                                             0%
HFC - 365mfc
                                                                   406 - 58 - 6
CH3CF2CH2CF3
                                                                            794
                                                                            794
                                                                              0
                                                                             0%
HFC - 43 - 10mee
                                                                138495 - 42 - 8
CF3CFHCFHCF2CF3
                                                                          1,300
                                                                          1,640
                                                                            340
                                                                            26%
Sulfur hexafluoride
                                                                  2551 - 62 - 4
SF6
                                                                         23,900
                                                                         22,800
                                                                         -1,100
                                                                            -5%
Trifluoromethyl sulphur pentafluoride
                                                                   373 - 80 - 8
SF5CF3
                                                                         17,700
                                                                         17,700
                                                                              0
                                                                             0%
Nitrogen trifluoride
                                                                  7783 - 54 - 2
NF3
                                                                         17,200
                                                                         17,200
                                                                              0
                                                                             0%
PFC - 14 (Perfluoromethane)
                                                                    75 - 73 - 0
CF4
                                                                          6,500
                                                                          7,390
                                                                            890
                                                                            14%
PFC - 116 (Perfluoroethane)
                                                                    76 - 16 - 4
C2F6
                                                                          9,200
                                                                         12,200
                                                                          3,000
                                                                            33%
PFC - 218 (Perfluoropropane)
                                                                    76 - 19 - 7
C3F8
                                                                          7,000
                                                                          8,830
                                                                          1,830
                                                                            26%
Perfluorocyclopropane
                                                                   931 - 91 - 9
C-C3F6
                                                                         17,340
                                                                        17,340
                                                                             0
                                                                            0%
PFC - 3 - 1 - 10 (Perfluorobutane)
                                                                   355 - 25 - 9
C4F10
                                                                          7,000
                                                                          8,860
                                                                          1,860
                                                                            27%
Perfluorocyclobutane
                                                                   115 - 25 - 3
C-C4F8
                                                                          8,700
                                                                         10,300
                                                                          1,600
                                                                            18%
PFC - 4 - 1 - 12 (Perfluoropentane)
                                                                   678 - 26 - 2
C5F12
                                                                          7,500
                                                                          9,160
                                                                          1,660
                                                                            22%
PFC - 5 - 1 - 14 (Perfluorohexane)
                                                                   355 - 42 - 0
C6F14
                                                                          7,400
                                                                          9,300
                                                                          1,900
                                                                            26%
PFC - 9 - 1 - 18
                                                                   306 - 94 - 5
C10F18
                                                                          7,500
                                                                          7,500
                                                                              0
                                                                             0%
HCFE - 235da2 (Isoflurane)
                                                                 26675 - 46 - 7
CHF2OCHClCF3
                                                                            350
                                                                            350
                                                                              0
                                                                             0%
HFE - 43 - 10pccc (H - Galden 1040x)
                                                                       E1730133
CHF2OCF2OC2F4OCHF2
                                                                          1,870
                                                                          1,870
                                                                              0
                                                                             0%
HFE - 125
                                                                  3822 - 68 - 2
CHF2OCF3
                                                                         14,900
                                                                         14,900
                                                                              0
                                                                             0%
HFE - 134
                                                                  1691 - 17 - 4
CHF2OCHF2
                                                                          6,320
                                                                          6,320
                                                                              0
                                                                             0%
HFE - 143a
                                                                   421 - 14 - 7
CH3OCF3
                                                                            756
                                                                            756
                                                                              0
                                                                             0%
HFE - 227ea
                                                                  2356 - 62 - 9
CF3CHFOCF3
                                                                          1,540

HFE - 236ca12 (HG - 10)
                                                                 78522 - 47 - 1
CHF2OCF2OCHF2
                                                                          2,800
                                                                          2,800
                                                                              0
                                                                             0%
HFE - 236ea2 (Desflurane)
                                                                 57041 - 67 - 5
CHF2OCHFCF3
                                                                            989
                                                                            989
                                                                              0
                                                                             0%
HFE - 236fa
                                                                 20193 - 67 - 3
CF3CH2OCF3
                                                                            487
                                                                            487
                                                                              0
                                                                             0%
HFE - 245cb2
                                                                 22410 - 44 - 2
CH3OCF2CF3
                                                                            708
                                                                            708
                                                                              0
                                                                             0%
HFE - 245fa1
                                                                 84011 - 15 - 4
CHF2CH2OCF3
                                                                            286
                                                                            286
                                                                              0
                                                                             0%
HFE - 245fa2
                                                                  1885 - 48 - 9
CHF2OCH2CF3
                                                                            659
                                                                            659
                                                                              0
                                                                             0%
HFE - 254cb2
                                                                   425 - 88 - 7
CH3OCF2CHF2
                                                                            359
                                                                            359
                                                                              0
                                                                             0%
HFE - 263fb2
                                                                   460 - 43 - 5
CF3CH2OCH3
                                                                             11
                                                                             11
                                                                              0
                                                                             0%
HFE - 329mcc2
                                                                 67490 - 36 - 2
CF3CF2OCF2CHF2
                                                                            919
                                                                            919
                                                                              0
                                                                             0%
HFE - 338mcf2
                                                                156053 - 88 - 2
CF3CF2OCH2CF3
                                                                            552
                                                                            552
                                                                              0
                                                                             0%
HFE - 338pcc13 (HG - 01)
                                                                188690 - 78 - 0
CHF2OCF2CF2OCHF2
                                                                          1,500
                                                                           1500
                                                                              0
                                                                             0%
HFE - 347mcc3
                                                                 28523 - 86 - 6
CH3OCF2CF2CF3
                                                                            575
                                                                            575
                                                                              0
                                                                             0%
HFE - 347mcf2
                                                                       E1730135
CF3CF2OCH2CHF2
                                                                            374
                                                                            374
                                                                              0
                                                                             0%
HFE - 347pcf2
                                                                   406 - 78 - 0
CHF2CF2OCH2CF3
                                                                            580
                                                                            580
                                                                              0
                                                                             0%
HFE - 356mec3
                                                                   382 - 34 - 3
CH3OCF2CHFCF3
                                                                            101
                                                                            101
                                                                              0
                                                                             0%
HFE - 356pcc3
                                                                160620 - 20 - 2
CH3OCF2CF2CHF2
                                                                            110
                                                                            110
                                                                              0
                                                                             0%
HFE - 356pcf2
                                                                       E1730137
CHF2CH2OCF2CHF2
                                                                            265
                                                                            265
                                                                              0
                                                                             0%
HFE - 356pcf3
                                                                 35042 - 99 - 0
CHF2OCH2CF2CHF2
                                                                            502
                                                                            502
                                                                              0
                                                                             0%
HFE - 365mcf3
                                                                   378 - 16 - 5
CF3CF2CH2OCH3
                                                                             11
                                                                             11
                                                                              0
                                                                             0%
HFE - 374pc2
                                                                   512 - 51 - 6
CH3CH2OCF2CHF2
                                                                            557
                                                                            557
                                                                              0
                                                                             0%
HFE - 449s1 (HFE - 7100) Chemical blend
                                              163702 - 07 - 6

 163702 - 08 - 7
C4F9OCH3 (CF3)2CFCF2OCH3
                                                                            297
                                                                            297
                                                                              0
                                                                             0%
HFE - 569sf2 (HFE - 7200) Chemical blend
                                                163702 - 05 - 4 163702 - 06 - 5
C4F9OC2H5 (CF3)2CFCF2OC2H5
                                                                             59
 59
                                                                              0
                                                                             0%
Sevoflurane
                                                                 28523 - 86 - 6
CH2FOCH(CF3)2
                                                                            345
                                                                            345
                                                                              0
                                                                             0%
HFE - 356mm1
                                                                 13171 - 18 - 1
(CF3)2CHOCH3
                                                                             27
                                                                             27
                                                                              0
                                                                             0%
HFE - 338mmz1
                                                                 26103 - 08 - 2
CHF2OCH(CF3)2
                                                                            380
                                                                            380
                                                                              0
                                                                             0%
(Octafluorotetramethy-lene)hydroxymethyl group
                                                                             NA
X-(CF2)4CH(OH)-X
                                                                             73
                                                                             73
                                                                              0
                                                                             0%
HFE - 347mmy1
                                                                 22052 - 84 - 2
CH3OCF(CF3)2
                                                                            343
                                                                            343
                                                                              0
                                                                             0%
Bis(trifluoromethyl)-methanol
                                                                   920 - 66 - 1
(CF3)2CHOH
                                                                            195
                                                                            195
                                                                              0
                                                                             0%
2,2,3,3,3-pentafluoropropanol
                                                                   422 - 05 - 9
CF3CF2CH2OH
                                                                             42
                                                                             42
                                                                              0
                                                                             0%
PFPMIE
                                                                             NA
CF3OCF(CF3)CF2OCF2OCF3
                                                                         10,300
                                                                         10,300
                                                                              0
                                                                             0%