Using Cal e-GGRT to Prepare Your Subpart AA Report
Note: The Cal e-GGRT help system includes general instruction on using the California GHG reporting tool. However, the help system may not explain differences between California and U.S. EPA reporting requirements. Please refer to the ARB reporting website for California-specific reporting requirements and additional help.


Subpart AA consists of facilities that produce market pulp, manufacture pulp and paper, produce paper products from purchased pulp, produce secondary fiber from recycled paper, and convert paper into paperboard products.

This page provides an overview of subtopics that are central to Subpart AA reporting:

The end of the page contains links you can use for more information on these topics.

Subpart AA Summary Information for this Facility

Subpart AA requires you to report the following data about your facility:

  • The annual steam purchases (pounds)
  • The annual production of pulp products (metric tons)
  • The annual production of paper products (metric tons)

Section 95119(d) requires you to report the following data about your faciltiy:

  • Annual production of recycled boxboard (short tons)
  • Annual production of recycled linerboard (short tons)
  • Annual production of recycled medium (short tons)
  • Annual production of tissue (short tons)

Subpart AA Makeup Chemical Usage Information

For Makeup Chemical Usage within your facility, Subpart AA requires you to report the following data:

Subpart AA Process Unit Information

For each process unit at your facility, the following unit information is required:

  • A unique name or identifier, plus optional description for this unit. See also About Unique Unit Names.
  • The type of unit, selected from the following:
    • Pulp mill lime kiln
    • Chemical recovery furnace
    • Chemical recovery combustion unit
  • An indication of whether the unit is monitored by Continuous Emissions Monitoring System (CEMS)

Subpart AA Emissions Information

The required emissions information and the manner by which required emissions information is entered into Cal e-GGRT is different for makeup chemical usage, process units that are monitored by a CEMS, and process units that are NOT monitored by a CEMS.

As a result, separate help content has been created in this subpart for entering emissions information for makeup chemical usage, process units monitored by CEMS and process units NOT monitored by CEMS.

For makeup chemical usage, the following emissions information is required:

  • The annual CO2 process emissions
  • An indication of whether a substitute value was used for CaCO3
  • An indication of whether a substitute value was used for NaCO3

For each chemical recovery furnace that is NOT monitored by CEMS at your facility, the following emissions information is required:

  • The annual biogenic CO2, CH4 and N2O process emissions
  • The basis for annual mass of spent liquor solids, selected from the following:
    • TAPPI method
    • On-line metering/measuring system
  • An indication of whether a substitute value was used for annual mass of spent liquor solids
  • The total annual CO2 mass emissions from fossil fuel
  • The total annual CH4 mass emissions from fossil fuel
  • The total annual N2O mass emissions from fossil fuel
  • Calculation methodology start date and end date, for each fuel type
  • Calculation methodology used for the emissions calculation period specified, for each fuel type:
    • Tier 1/Equation C-1: Annual fuel combusted, default heating value, and default CO2 emission factor
    • Tier 1/Equation C-1a: Annual natural gas usage from billing records (therms) and default CO2 emission factor
    • Tier 1/Equation C-1b: Annual natural gas usage from billing records (mmBtu) and default CO2 emission factor
    • Tier 2/Equation C-2a: Annual fuel combusted, measured heating value, and default CO2 emission factor
    • Tier 2/Equation C-2c: Steam generation, ratio of maximum rated heat input capacity to design rated steam output capacity, and default CO2 emission factor (for MSW and solid fuels listed in Table C-1))
    • Tier 3/Equation C-3: Annual mass of solid fuel combusted and average carbon content of the solid fuel
    • Tier 3/Equation C-4: Annual mass of liquid fuel combusted and average carbon content of the liquid fuel
    • Tier 3/Equation C-5: Annual volume of gaseous fuel combusted, average carbon content of the gaseous fuel, and average molecular weight of the gaseous fuel

For each chemical recovery combustion unit that is NOT monitored by CEMS at your facility, the following emissions information is required:

  • The annual biogenic CO2, CH4 and N2O process emissions
  • The basis for annual mass of spent liquor solids, selected from the following:
    • TAPPI method
    • On-line metering/measuring system
  • An indication of whether a substitute value was used for annual mass of spent liquor solids
  • The total annual CO2 mass emissions from fossil fuel
  • The total annual CH4 mass emissions from fossil fuel
  • The total annual N2O mass emissions from fossil fuel
  • Calculation methodology start date and end date, for each fuel type
  • Calculation methodology used for the emissions calculation period specified, for each fuel type:
    • Tier 1/Equation C-1: Annual fuel combusted, default heating value, and default CO2 emission factor
    • Tier 1/Equation C-1a: Annual natural gas usage from billing records (therms) and default CO2 emission factor
    • Tier 1/Equation C-1b: Annual natural gas usage from billing records (mmBtu) and default CO2 emission factor
    • Tier 2/Equation C-2a: Annual fuel combusted, measured heating value, and default CO2 emission factor
    • Tier 2/Equation C-2c: Steam generation, ratio of maximum rated heat input capacity to design rated steam output capacity, and default CO2 emission factor (for MSW and solid fuels listed in Table C-1))
    • Tier 3/Equation C-3: Annual mass of solid fuel combusted and average carbon content of the solid fuel
    • Tier 3/Equation C-4: Annual mass of liquid fuel combusted and average carbon content of the liquid fuel
    • Tier 3/Equation C-5: Annual volume of gaseous fuel combusted, average carbon content of the gaseous fuel, and average molecular weight of the gaseous fuel

For each pulp mill lime kiln that is NOT monitored by CEMS at your facility, the following emissions information is required:

  • The total annual CO2 mass emissions
  • The total annual CH4 mass emissions
  • The total annual N2O mass emissions
  • Calculation methodology start date and end date, for each fuel type
  • Calculation methodology used for the emissions calculation period specified, for each fuel type:
    • Tier 1/Equation C-1: Annual fuel combusted, default heating value, and default CO2 emission factor
    • Tier 1/Equation C-1a: Annual natural gas usage from billing records (therms) and default CO2 emission factor
    • Tier 1/Equation C-1b: Annual natural gas usage from billing records (mmBtu) and default CO2 emission factor
    • Tier 2/Equation C-2a: Annual fuel combusted, measured heating value, and default CO2 emission factor
    • Tier 2/Equation C-2c: Steam generation, ratio of maximum rated heat input capacity to design rated steam output capacity, and default CO2 emission factor (for MSW and solid fuels listed in Table C-1))
    • Tier 3/Equation C-3: Annual mass of solid fuel combusted and average carbon content of the solid fuel
    • Tier 3/Equation C-4: Annual mass of liquid fuel combusted and average carbon content of the liquid fuel
    • Tier 3/Equation C-5: Annual volume of gaseous fuel combusted, average carbon content of the gaseous fuel, and average molecular weight of the gaseous fuel

For each CEMS Monitoring Location, provide the following information:

  • A unique unit name or identifier for the CML (see also About Unique Unit Names)
  • An optional description or label for the CML
  • The configuration of processes or process units that are monitored by the CML:
    • Single industrial process or process unit that exhausts to a dedicated stack
    • Multiple industrial processes or process units share a common stack
    • Industrial process or process unit shares a common stack with one or more stationary fuel combustion units
  • The name of each fuel combusted in the unit(s) monitored by the CEMS
  • The Tier 4/CEMS methodology start and end dates
  • The cumulative total of hourly CO2 mass emissions for each quarter of the reporting year (in metric tons) (Do not cumulate emissions data between quarters)
  • The total annual CO2 mass emissions measured by the CEMS (in metric tons)
  • An indication whether emissions reported for the CEMS include emissions calculated according to 98.33(a)(4)(viii) for a slipstream that bypassed the CEMS
  • The total annual biogenic CO2 emissions from the combustion of all biomass fuels combined (in metric tons) (if applicable)
  • The total annual non-biogenic CO2 emissions (includes fossil fuel, sorbent, and process CO2 emissions, in metric tons)
  • The total annual CH4 and N2O emissions associated with the combustion of all Table C-2 fuels combusted in all processes/process units monitored by the CEMS derived from application of Equation C-10 (in metric tons) (if there are no combustion emissions in this CML, please enter zero)
  • The total number of source operating hours in the reporting year
  • The total operating hours in which a substitute data value was used in the emissions calculations for the CO2 concentration parameter
  • The total operating hours in which a substitute data value was used in the emissions calculations for the stack gas flow rate parameter
  • If moisture correction is required and a continuous moisture monitor is used, the total operating hours in which a substitute data value was used in the emissions calculations for the stack gas moisture content parameter
  • An indication of the process units monitored by the CML

Subpart AA Validation Report

You can use the Validation Report to ensure the completeness and quality of your reporting data.

You should use the Validation Report to check your work. The Validation Report performs two types of checks:

  • Data Completeness: Data that are required for reporting is missing or incomplete.
  • Data Quality: Data are outside of the expected range of values.

You may view the Validation Report at any time.

Note that the Validation Report is intended to assist users in entering data, but it is not an indication that the reporter has entered all necessary information, nor is it an indication that the reporter is in compliance with 40 CFR Part 98. Furthermore a negative finding on the validation report is not a guarantee that a data element was entered incorrectly.

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See Also

Screen Errors
Using Cal e-GGRT to Prepare Your Subpart AA Report
Subpart AA Summary Information for this Facility
Subpart AA Makeup Chemical Usage Information
Subpart AA Process Unit Information for Units NOT Monitored by CEMS
Subpart AA Process Unit Information for Units Monitored by CEMS
Subpart AA Emissions Information for Makeup Chemical Recovery
Subpart AA Emissions Information for Units NOT Monitored CEMS
Subpart AA Emissions Information for Units Monitored by CEMS
Subpart Validation Report

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