Facilities may make a decision if they will or will not use IVT for each Subpart C unit. The following flowchart outlines the decision process and the implications of those decisions:
Facilities are required to indicate whether or not a source meets these conditions on the Equation Inputs Reporting page when the source is first entered in e-GGRT.
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Please note that if a facility is required to report equation inputs for Reporting Year 2014 (RY2014), it will also be required to back-report the inputs to equations for this source for all previous reporting years as part of the RY2014 annual report.
If a facility that is not required to report equation inputs for a source determines that potential disclosure of these inputs is not a concern, it can elect to report these inputs to emission equations. However, if a facility makes this election, it is also required to report its subpart C inputs to emission equations for which reporting was deferred to 2015 for reporting years 2010 through 2014 in the reporting year 2014 annual report. In e-GGRT, the facility would indicate this preference by checking the second checkbox for "I would like to report my inputs to equations for this configuration to EPA...." in response to the question that appears if the facility indicates that it is not required to report equation inputs for the source.
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If a facility indicates that it would like to report equation inputs, it will be asked to confirm its decision to waive its right to make a confidentiality claim for the equation inputs reported to EPA (see screen shot below).
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A facility that is not required to report equation inputs for a source configuration can protect these inputs from disclosure by using the Inputs Verification Tool (IVT), which is the verification software specified in §98.5(b). In lieu of reporting equation inputs, facilities enter these data into IVT, where they are used to perform electronic verification and to calculate the emission equation results. IVT does not retain the entered inputs; instead, IVT conducts certain checks (e.g., accuracy of the inputs and the calculated emissions values) at the time of data entry and generates a verification summary. The EPA does not have access to the entered inputs either during the time of entry or any time thereafter. However, the verification summary, which is accessible to the EPA once the reporter has completed using IVT and the annual report has been submitted, provides the EPA with information to conduct further verification if necessary.
If a facility elects to use IVT for a subpart C source, it will NOT be required to back-report the inputs to equations for this source for all previous reporting years as part of the RY2014 annual report.