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No.

FAQ ID.

Relevant Subpart

Description

Comment

Rule References Needed? (Y/N)

Time Sensitive? (Y/N)

Reviewer

Proposed Action

Priority

Rework  

Date Last Updated

SAIC Approved

EPA Approved   

200

Q200

e-GGRT (General)

What are e-GGRT system requirements?

OK

N

N

Matt

Post

-

 


x 11/21/2011

 

201

Q201

e-GGRT (General)

How do I turn on Javascript in my browser?

OK

N

N

Matt

Post

-

 

 

 

 

202

Q202

e-GGRT (General)

Will my browser back button work when using e-GGRT?

OK

N

N

Matt

Post

-

 


x 11/21/2011

 

203

Q203

e-GGRT (General)

Will e-GGRT timeout due to inactivity? When does e-GGRT save?

OK

N

N

Matt

Post

-

 

 

x 11/21/2011

 

207

Q207

e-GGRT (General)

I use both CAMD Business System (CBS) and e-GGRT. Which system should I use to update my user or facility profile?

OK

N

N

Matt

Post

-

 


x 11/21/2011

 

211

Q211

e-GGRT (General)

I report emissions using ECMPS and CAMD Business System (CBS). Do I also have to submit reports using e-GGRT?

OK

N

N

Matt

Post

-

 


x 11/21/2011

 

212

Q212

e-GGRT (General)

Do you expect that most current CDX users will become e-GGRT users?

OK

N

N

Matt

Post

-

 

 

x 11/21/2011

 

213

Q213

e-GGRT (General)

If I complete user registration in e-GGRT, can I use my e-GGRT user ID and password to log in to CDX?

OK

N

N

Matt

Post

-

 

 

x 11/21/2011

 

218

Q218

e-GGRT (General)

Does facility data have to be entered manually or can you upload the data using files?

OK

N

N

Matt

Post

-

 

 

x 11/21/2011

 

229

Q229

e-GGRT (General)

What is e-GGRT?

OK

N

N

Matt

Post

-

 

 

x 11/21/2011

 

231

Q231

e-GGRT (General)

When will EPA offer training on e-GGRT?


The URL provided shows no plans for future training. Does EPA plan to provide training in future reporting years?

No updates needed. The EPA website provides the e-GGRT training webinars that EPA update. EPA has already added the BAMM training from 11/17/11.

N

N

Matt

EPA Review

3

 

 

 

 

232

Q232

e-GGRT (General)

Will EPA provide the opportunity to review e-GGRT, provide input and beta test?

OK

N

N

Matt

Post

-

 

 

x 11/21/2011

 

233

Q233

e-GGRT (General)

Do I have to use e-GGRT to report to the Greenhouse Gas Reporting Program (GHGRP)? Are there any source categories that will not use e-GGRT?

OK

N

N

Matt

Post

-

 

 

x 11/21/2011

 

234

Q234

e-GGRT (General)

Will e-GGRT and the XML Reporting Schema v1.0 account for reporting requirements proposed or promulgated for reporting year 2011?

Update when new version of the XML Reporting Schema is released.

N

Y

Matt

Draft Revision

3

 

 

 

 

236

Q236

e-GGRT (General)

During what hours is telephone support available? Will hours be extended during busy times?


Limit this response to hours of operation only? The remainder of the response addresssing rule-related questions duplicates FAQ238 and probably needs updating.

FAQ236 has been updated on 11/20/11.THe description of the HD and the various e-mail / web form destinations have been updated. The email address has been updated from GHGMRR@epa.gov to ghgreporting@epa.gov

N

N

Matt

Draft Revision

2

 

 

x 11/21/2011

 

237

Q237

e-GGRT (General)

Do Greenhouse Gas Reporting Program (GHGRP) reporters have to submit Monitoring Plans?


Add reference to 98.3(g)(5)

A reference to the rule about monitoring plans, 98.3(g)(5), has been added.

Y

N

Matt

Edit/Quick Fix

1

 

 

 

 

238

Q238

e-GGRT (General)

Where should I submit rule related questions on Part 98?

Email address needs to be updated to ghgreporting@epa.gov

The email address has been updated from GHGMRR@epa.gov to ghgreporting@epa.gov

N

N

Matt

Edit/Quick Fix

1

 

 

 

 

239

Q239

e-GGRT (General)

How do I contact the e-GGRT Help Desk?

OK

N

N

Matt

Post

-

 

 

x 11/21/2011

 

255

Q255

e-GGRT (General)

What is XML?

OK

N

N

Matt

Post

-

 

 

x 11/21/2011

 

268

Q268

e-GGRT (General)

The ten minute inactivity timeout in e-GGRT makes me nervous. Can I save as I go?

OK

N

N

Matt

Post

-

 

 

x 11/21/2011

 

303

Q303

e-GGRT (General)

Have any of the equations under the GHG reporting rule been revised, or have any new equations been added since the rule was finalized in 2009?

It looks like EPA issued final rule revisions for subparts I and W on 9/27/2011 that affect calculation methods including equations. EPA is likely to revise equations in the future, so this FAQ must be updated continually if references to specific rule revision actions are to be listed.
Consider posting existing FAQ and revising when rule changes are finalized.

FAQ303 has been updated on 11/10/11. One sentence has been added: For any revisions to equations in the rule for the current reporting year or future years please continue to monitor the EPA's Greenhouse Gas Reporting Program website for additional information under the Rulemaking Notices section http://www.epa.gov/climatechange/emissions/ghgrulemaking.html.

N

Y

Matt

EPA Review

2

 

 

 

 

304

Q304

e-GGRT (General)

When asked in e-GGRT if a unit has a CEMS, is it specifically referring to a CO2 CEMS?

OK

N

N

Matt

Post

-

 

 

x 11/21/2011

 

305

Q305

e-GGRT (General)

Does the information from the Reporting Forms populate e-GRRT fields or are they just uploaded files? If automatically populated, are these values available for review before submitting the report?

OK

N

N

Matt

Post

-

 

 

x 11/21/2011

 

306

Q306

e-GGRT (General)

When will the reporting tools for subparts I, L, T, W, DD, FF, II, QQ, SS, TT, and UU be available?

Update to include due date for Track 2 reports in 2012.

FAQ306 was re-edited to correct the due date for track 2 subparts of September 28, 2012.

N

Y

Matt

Draft Revision

2

 

 

x 11/21/2011

 

312

Q312

e-GGRT Confidential Business Information (CBI)

Will the data I submit in e-GGRT be treated as CBI?

Citation may need to be updated: "(76 FR 30782, published May 26, 2011)."
Update due date (currently 9/30/2011).

Updated Rule citation with new CBI deferral info: (76 FR 53057, published August 25, 2011).

N

N

Caitlin

Draft Revision

2

 

 

 

 

313

Q313

e-GGRT Confidential Business Information (CBI)

Can I mark my data as CBI in e-GGRT?

Citation may need to be updated: "(76 FR 30782, published May 26, 2011)."
Update due date (currently 9/30/2011).

Updated Rule citation with new CBI deferral info: (76 FR 53057, published August 25, 2011).

N

N

Caitlin

Draft Revision

2

 

 

 

 

314

Q314

e-GGRT Confidential Business Information (CBI)

Can I designate data as CBI in my XML file?

Citation may need to be updated: "(76 FR 30782, published May 26, 2011)."
Update due date (currently 9/30/2011).

Updated Rule citation with new CBI deferral info: (76 FR 53057, published August 25, 2011).

N

N

Caitlin

Draft Revision

2

 

 

 

 

315

Q315

e-GGRT Confidential Business Information (CBI)

EPA has said that data submitted during the testing period will not be treated as confidential. Is there a risk that data submitted during testing will be made publicly available?

No updates needed

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

316

Q316

e-GGRT Confidential Business Information (CBI)

The interim final rule published in December 2010 deferred reporting of inputs until August 31, 2011, but the 2011 reporting deadline is now September 30, 2011. How is this handled in e-GGRT?

Questions may be obsolete since the deferred dates are now set as of August 2011. This should be removed or edited. Relevant questions can be answered w/ FAQ 317.

N

N

Caitlin

Withdraw

-

 

 

 

 

317

Q317

e-GGRT Confidential Business Information (CBI)

Are inputs to emission equations being collected in e-GGRT?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

318

Q318

e-GGRT Confidential Business Information (CBI)

Should reporters include calculation inputs when they upload XML files?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

319

Q319

e-GGRT Confidential Business Information (CBI)

Are reporters required to use the calculation spreadsheets provided by EPA or may they use their own spreadsheets?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

320

Q320

e-GGRT Confidential Business Information (CBI)

Should reporters using the calculation spreadsheets submit them to EPA?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

185

Q185

e-GGRT Facility Registration

Can additional Agents be added to e-GGRT after Jan 30, 2011?

The question  needs to be updated.
Make generic (e.g., "...after the registration  deadline?"
Question is updated to read "after the registration deadline"

N

Y

Nvart

Edit/Quick Fix

1

 

11/9/2011

 

 

186

Q186

e-GGRT Facility Registration

Some of us are consultants who will be populating e-GGRT on behalf of our clients. Can you explain which role we should be assigned in e-GGRT?

Question does not refer to rule but the answer does.:"It is up to the facility to consult The Rule, Part 98.4 (specifically 98.4(a) and 98.4(b) as well as 98.4(j)) to determine the appropriate DR, ADR and Agent."  No change is necessary.

Y

N

Nvart

Edit/Quick Fix

1

 

 

 

 

187

Q187

Facility Registration

Is the technical person who prepares the information for signature the "Agent" in your terminology?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

188

Q188

Facility Registration

Some reporters may have the Designated Representative (DR) and (ADR) at the plant, but a corporate employee will coordinate all the reporting. Can one employee be set up as an Agent for all plants?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

189

Q189

Facility Registration

Can Agents be removed at anytime?

May want to add the following to "Yes" answer to this question: To remove one or more Agents, select the Agent(s) you wish to remove and click REMOVE. If you remove one or more Agents, e-GGRT will require you to sign a revised Notice of Delegation. To cancel the changes, click CANCEL and you will be returned to the Facility Summary page.Added the above statement.

N

N

Nvart

Draft Revision

3

 

 

 

 

190

Q190

Facility Registration

Does an e-GGRT user have access to multiple facilities from one login if he or she is helping multiple clients?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

191

Q191

Facility Registration

Can an Agent appoint another Agent?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

192

Q192

Facility Registration

Can a contractor register for e-GGRT on behalf of a client? Or should it only be an employee?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

193

Q193

Facility Registration

Is there a limit to the number of Agents or Alternate Designated Representatives (ADR) for any one company?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

194

Q194

Facility Registration

I am a technical professional who will be preparing the report for my plant manager to certify. Should we both go through the process for setting up a user profile? Can I be set up as a user even though I will not certify the submission?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

195

Q195

Facility Registration

Must the Designated Representative (DR) and Alternate Designated Representative (ADR) appoint the same Agents?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

196

Q196

Facility Registration

Is it possible for an Agent to prepare annual greenhouse gas (GHG) reports as well as submit reports?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

197

Q197

Facility Registration

Do Agents need to be set up by the Designated Representative (DR) and Alternate Designated Representative (ADR)?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

198

Q198

Facility Registration

Does the person setting up have access to our facility data in e-GGRT?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011x 11/21/2011

 

199

Q199

Facility Registration

What address information should be entered for suppliers reporting at the company level?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

214

Q214

Facility Registration

Does the Designated Representative (DR) have to be a vice president? Can an environmental manager prepare reports?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

215

Q215

Facility Registration

Can the Alternate Designated Representative (ADR) create a user profile before a Designated Representative (DR)?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

216

Q216

Facility Registration

How does a consultant enter data for a client who is the Designated Representative (DR)? What does a consultant do on the DR and Alternate Designated Representative (ADR) screen, since the consultant is neither the DR nor authorized to appoint the DR.

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

217

Q217

Facility Registration

Can a company designate more than one Alternate Designated Representative (ADR)?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

219

Q219

Facility Registration

So, if I understand correctly, I can register and appoint myself as the Alternate Designated Representative (ADR) and my boss as the Designated Representative (DR), but I will not get an invitation to accept the appointment until he registers and accepts?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

220

Q220

Facility Registration

What is the process for changing a Designated Representative (DR) or Alternate Designated Representative (ADR)?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

221

Q221

Facility Registration

Like the Electronic Signature Agreement, does the Certificate of Representation need to be printed out, signed and mailed to EPA?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

222

Q222

Facility Registration

Does a Designated Representative (DR) need to grant or appoint a consultant access to their facility?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

223

Q223

Facility Registration

Can an ADR be appointed after Jan 30, 2011?

The question only needs to be updated.
Make generic (e.g., "...after the registration  deadline?" Changed the date to read "after the registration deadline"

N

Y

Nvart

Edit/Quick Fix

1

 

11/9/2011

 

 

224

Q224

Facility Registration

For the Environmental Mgr to become the Designated Representative (DR) does he or she need a formal letter from the facility owners? Does that letter need be submitted with the signature page?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

225

Q225

Facility Registration

Can an e-GRRT user enter in (but not sign, submit) all facility greenhouse gas (GHG) emissions without being a Designated Representative (DR), Alternate Designated Representative (ADR) or Agent?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

226

Q226

Facility Registration

The Designated Representative (DR) may appoint one Alternate Designated Representative (ADR) at each facility or supplier. If my operation is both a facility and a supplier can the DR be two different people, one for the facility and one for the supplier?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

227

Q227

Facility Registration

What is the difference between a Designated Representative (DR) and Alternate Designated Representative (ADR), and an Agent?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

228

Q228

Facility Registration

What events require the Designated Representative (DR) or Alternate Designated Representative (ADR) to resubmit a Certificate of Representation for the facilities they represent?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

251

Q251.

Facility Registration

What if I can't find my facility or supplier on the e-GGRT facility search page? Will e-GRRT provide the ability to add a new facility?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

252

Q252

Facility Registration

Does the facility registration process need to be completed in one session like the user registration process?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

253

Q253

Facility Registration

Will suppliers of fossil fuels (such as natural gas local distribution companies) follow the same procedure to set up a companywide Certificate of Registration?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

254

Q254

Facility Registration

Our operation includes a supplier under one subpart and a facility under another. Do they have to have the same Designated Representative (DR)?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

267

Q267

Facility Registration

If there is a change in owner or operator, does e-GGRT need to be updated within 90 days?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

270

Q270

Facility Registration

Where can I find the Certificate of Representation to file?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

271

Q271

Facility Registration

If a Designated Representative's (DR) or Alternate Designated Representative's (ADR) password expires, will their Agents still be able to access and work in e-GGRT?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

272

Q272

Facility Registration

Must a large company with multiple facilities in different states have one Designated Representative (DR) for all facilities, or can each facility have its own DR?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

273

Q273

Facility Registration

Is there any way to be the Agent for all facilities at a company and fill out only one Notice of Delegation?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

274

Q274

Facility Registration

If you want someone to be able to prepare an electronic report but not submit, what role should they have?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

275

Q275

Facility Registration

If the Designated Representative (DR) or Alternate Designated Representative (ADR) changes at a facility but no Agents change, must the DR or ADR submit new a Notice of Delegation for each Agent?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

283

Q283

Facility Registration

What address information should be entered for facilities with no street or mailing address?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

285

Q285

Facility Registration

I am required to report as both a facility and a supplier under Part 98? How will e-GGRT handle registration and reporting for my facility?

No updates needed.

Y

N

Nvart

Post

-

 

 

 

 

293

Q293

Sandbox Testing

Can I submit my annual GHG report during the Sandbox testing?

There will be a Track 2 sandbox in the late spring (poss. May) so sandbox FAQs may be useful but I would think think they should be retired or archived until they can be reviewed under the specific context of the actual Track 2 sandbox process.
Unless e-GGRT and/or the Sandbox testing protocol is revised, most of these FAQs will need no further revision.

N

N

Matt

Post

-

 

 

x 11/21/2011

 

294

Q294

Sandbox Testing

Will data entered during Sandbox testing be saved by EPA?

Updates could be needed for track 2 subparts
No further revision required for this sandbox FAQ.

N

N

Matt

Post

-

 

 

x 11/21/2011

 

295

Q295

Sandbox Testing

Will data I enter during Sandbox testing be subject to public information disclosure requests?

Updates could be needed for track 2 subparts
No further revision required for this sandbox FAQ.

N

N

Matt

Post

-

 

 

x 11/21/2011

 

296

Q296

Sandbox Testing

Should I enter my actual emissions information during Sandbox testing?

Updates could be needed for track 2 subparts
No further revision required for this sandbox FAQ.

N

N

Matt

Post

-

 

 

x 11/21/2011

 

297

Q297

Sandbox Testing

If I note a problem with e-GGRT during Sandbox testing what should I do?

Updates could be needed for track 2 subparts
Update link to Help Desk.

N

N

Matt

Edit/Quick Fix

3

 

 

 

 

298

Q298

Sandbox Testing

I notice that there are no webinars scheduled for several subparts for which I will be reporting. Does this mean that I'll be unable to test these subparts during Sandbox testing?

Updates could be needed for track 2 subparts

N

N

Matt

EPA Review

2

 

 

 

 

300

Q300

Sandbox Testing

Is the e-GGRT Sandbox testing different than the beta testing of e-GGRT?

Updates could be needed for track 2 subparts
No further revision required for this sandbox FAQ.

N

N

Matt

Post

-

 

 

x 11/21/2011

 

301

Q301

Sandbox Testing

Does the Sandbox testing period just give the user an early look at how e-GGRT will work?

Updates could be needed for track 2 subparts
No further revision required for this sandbox FAQ.

N

N

Matt

Post

-

 

 

x 11/21/2011

 

302

Q302

Sandbox Testing

Are there specific tasks that the Sandbox users must complete during their testing period?

Updates could be needed for track 2 subparts
No further revision required for this sandbox FAQ.

N

N

Matt

Post

-

 

 

x 11/21/2011

 

367

Q367

Sandbox Testing

When will the Data Reporting tab be available to start entering data?

Updates could be needed for track 2 subparts
Update deadline date for Track 2.

N

N

Matt

Edit/Quick Fix

3

 

 

 

 

368

Q368

Sandbox Testing

Is there a way to develop the data input needed for reporting during the Sandbox testing, save it, and then use it when performing the actual emission reporting?

Updates could be needed for track 2 subparts

N

N

Matt

Post

-

 

 

x 11/21/2011

 

369

Q369

Sandbox Testing

Do you have to be associated with a registered facility to perform the Sandbox testing or can you enter data into a fictional facility?

Updates could be needed for track 2 subparts

N

N

Matt

Post

-

 

 

x 11/21/2011

 

370

Q370

Sandbox Testing

Is there a deadline for signing up for Sandbox testing?

Updates could be needed for track 2 subparts
Add punctuation.

N

N

Matt

Edit/Quick Fix

3

 

 

 

 

371

Q371

Sandbox Testing

During Sandbox testing, do we create our own facility or do we use the facility provided by EPA?

Updates could be needed for track 2 subparts

N

N

Matt

Post

-

 

 

x 11/21/2011

 

372

Q372

Sandbox Testing

Will everyone be able to be in the Sandbox facility at the same time? And will we see each other's entries?

Updates could be needed for track 2 subparts

N

N

Matt

Post

-

 

 

x 11/21/2011

 

373

Q373

Sandbox Testing

Does my existing user name and password get me into the Sandbox?

Updates could be needed for track 2 subparts
Link to sandbox registration may need to be updated.

N

N

Matt

Edit/Quick Fix

3

 

 

 

 

374

Q374

Sandbox Testing

How do we train our "leadership" to sign and submit if this capability is disabled in the Sandbox? Will there be printed or PDF instructions with screen shots and flow diagrams for these steps?

Updates could be needed for track 2 subparts
Change tense, e.g., "EPA has posted detailed reporting instructions..."

N

N

Matt

Edit/Quick Fix

3

 

 

 

 

375

Q375.

Sandbox Testing

In the Sandbox, will I be able to test both the XML upload capability and the web forms on my one test facility?

Updates could be needed for track 2 subparts
No further revision required for this sandbox FAQ.

N

N

Matt

Post

-

 

 

x 11/21/2011

 

376

Q376

Sandbox Testing

Since the Sandbox only allows for one facility is there a simple way to clear all entered data and start over to test different types of facilities?

Updates could be needed for track 2 subparts
No further revision required for this sandbox FAQ.

N

N

Matt

Post

-

 

 

x 11/21/2011

 

377

Q377

Sandbox Testing

During the Sandbox testing, will we be able to create any number of units or groups with different subparts?

Updates could be needed for track 2 subparts
No further revision required for this sandbox FAQ.

N

N

Matt

Post

-

 

 

x 11/21/2011

 

378

Q378

Sandbox Testing

In the Sandbox, can we submit more than once for a facility?

Updates could be needed for track 2 subparts
No further revision required for this sandbox FAQ.

N

N

Matt

Post

-

 

 

x 11/21/2011

 

379

Q379

Sandbox Testing

Can we test web forms using our facility, and at a later date repeat the test using a different data set? Or, do we have only one chance to test with data?

Updates could be needed for track 2 subparts
No further revision required for this sandbox FAQ.

N

N

Matt

Post

-

 

 

x 11/21/2011

 

380

Q380

Sandbox Testing

This Sandbox testing doesn't cover Subpart LL and MM, correct? I haven't gone through the website in detail yet - are there any webinars or Sandbox testing opportunities for entering data for Subparts LL or MM?

Updates could be needed for track 2 subparts
No further revision required for this sandbox FAQ provided reporting for subparts LL and MM will be continue to be conducted via OTAQREG.

N

N

Matt

Post

-

 

 

x 11/21/2011

 

381

Q381

Sandbox Testing

When the report bug or problem link is clicked, will it keep the page we're on open?

Updates could be needed for track 2 subparts
No further revision required for this sandbox FAQ.

N

N

Matt

Post

-

 

 

x 11/21/2011

 

382

Q382

Sandbox Testing

Will there only be any additional testing opportunities after the June Sandbox testing period and before the first reporting deadline on September 30, 2011?

Updates could be needed for track 2 subparts
Yes, update for Track 2 including  changing dates.

N

N

Matt

Draft Revision

3

 

 

 

 

383

Q383

Sandbox Testing

Is there a chance that any of the calculation spreadsheets will be revised between the Sandbox testing and when e- GGRT is available for actual reporting?

Updates could be needed for track 2 subparts
No further revision required for this sandbox FAQ.

N

N

Matt

Post

-

 

 

x 11/21/2011

 

384

Q384

Sandbox Testing

Will all subparts be available during the Sandbox testing?

Updates could be needed for track 2 subparts
Update to reflect scope of Track 2 Sandbox testing.

N

N

Matt

Draft Revision

3

 

 

 

 

385

Q385

Sandbox Testing

Might the XML schema change as a result of Sandbox testing?

Updates could be needed for track 2 subparts
No further revision required for this sandbox FAQ.

N

N

Matt

Post

-

 

 

x 11/21/2011

 

386

Q386

Sandbox Testing

My XML report generation tool will not be ready until late in the year. Can I access the Sandbox at that time?

Updates could be needed for track 2 subparts
Update for Track 2 if still applicable (i.e., if XML report generation tool for Track 2 subparts is not available during Sandbox testing).

N

N

Matt

Draft Revision

3

 

 

 

 

204

Q204

User Registration

I am a CAMD Business System (CBS) user. What information will be imported to e-GGRT during user registration?

No. All facilities, whether they are CAMD (old or new) or non-CAMD, are registered the same. CAMD facility information is no longer exported into e-GGRT.

We are still capturing CAMD ESA information for individual users. No changes are needed.

N

N

Nvart

Draft Revision

2

 

11/9/2011

 

 

205

Q205

User Registration

Are the Certificates of Representation still required to be submitted by Jan 30, 2011 (for reporting year 2010), if EPA has the current Designated Representative (DR) registered in CAMD Business System (Part 75 CAIR)?

Needs to be made generic, remove the date.
Revise to accommodate users at Track 2 facilities and new Track 1 facilities?
Need to verify the required date for COR submission.  Changed to Jan 30, 2012 (for reporting year 2011)

N

Y

Nvart

Draft Revision

2

 

11/16/2011

 

 

206

Q206

User Registration

If someone has both a CAMD Business System user account and a CDX account which one do they use to log in to e-GGRT?

May want to reword it.  Added "You can however, use your CDX user name and password to login to eGRRT."

N

N

Nvart

Draft Revision

2

 

11/9/2011

 

 

208

Q208

User Registration

I am the Designated Representative (DR) in CAMD Business System (CBS). Do I need to be the first user to log in to e-GGRT for my facility or can someone else log in first?

No longer relevant, stopped importing CAMD facility data into eGRRT.  Need to delete.

N

N

Nvart

Draft Revision

2

 

 

 

 

209

Q209

User Registration

Is it mandatory to link the CAMD Business System Designated Representative (DR) user account with the e-GGRT DR user account?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

210

Q210

User Registration

Why can't I find my CAMD Business System (CBS) facility in the facility search page?

May want to delete the question.

N

N

Nvart

Withdraw

-

 

 

 

 

240

Q240

User Registration

The address shown for the Electronic Signature Agreement submission looks like a street address. Can we send the Electronic Signature Agreement by via regular mail, certified mail or other express mail?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

241

Q241

User Registration

Similar to Toxics Release Inventory (TRI), does only the certifier need to complete the Electronic Signature Agreement or do all users and Agents?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

242

Q242

User Registration

Will it be possible to get a copy of the e-GGRT Terms and Conditions so I can review them in advance?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

243

Q243

User Registration

If a single individual will be entering information for multiple facilities, can a single Electronic Signature Agreement be submitted to cover all facilities or will multiple Electronic Signature Agreements need to be submitted?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

245

Q245

User Registration

If I've already submitted an Electronic Signature Agreement for my CDX account, do I have to submit another one for e-GGRT?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

246

Q246

User Registration

If I've submitted an Electronic Signature Agreement for my CAMD Business System account, will that work for e-GGRT?

This is how the ESA linkage is performed the FAQ is correct, no need for change.

N

N

Nvart

Draft Revision

2

 

 

 

 

247

Q247

User Registration

To what address do I send the Electronic Signature Agreement?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

248

Q248

User Registration

My Electronic Signature Agreement is lost. How do I print a new copy and mail it in?

May want to reword it to make it clear.Updated the question and the answer as follows:

"Q248. My Electronic Signature Agreement has not been approved and is lost. How do I print a new copy and mail it in?

A. If your Electronic Signature Agreement (ESA) has not been approved, you may log in to e-GGRT and click on the link that says "Electronic Signature Agreement". Next, print out a new copy, then sign and date it and mail it to the address shown on the form."

N

N

Nvart

Draft Revision

2

 

11/15/2011

 

 

249

Q249

User Registration

Why would EPA reject an Electronic Signature Agreement?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

256

Q256

User Registration

Do Agents have a different login and password from the Designated Representative (DR)?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

257

Q257

User Registration

What happens if you do not complete user registration in one session? Can you start again later?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

258

Q258

User Registration

Does e-GGRT allow an international address in the user profile?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

259

Q259

User Registration

Is there a mechanism to support multiple companies from a single email address?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

260

Q260

User Registration

How often do I need to change my e-GGRT password?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

261

Q261

User Registration

I forgot my e-GGRT user name. How do I retrieve it?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

262

Q262

User Registration

I lost my password. How can I get it reset?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

263

Q263

User Registration

How do I reset my expired password?

Need to be  updated, add instructions how to reset. Added instructions for resetting password.

N

N

Nvart

Draft Revision

2

 

11/9/2011

 

 

264

Q264

User Registration

How do I unlock my e-GGRT account?

No updates needed.

 

 

Nvart

Post

-

 

 

x 11/21/2011

 

265

Q265

User Registration

During user registration, I already provided a secret question and answer. Why do I also need challenge questions and answers?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

269

Q269

User Registration

If I submit data only once a year, why does the password expire every 90 days?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

277

Q277

User Registration

Can you log in to e-GGRT with your ECMPS user name and password?

No updates needed.

N

N

Nvart

Post

-

 

 

x 11/21/2011

 

1

Q1

A

What is the action being taken?

Fixed tenses.

Y

N

Caitlin

Post

2

 

 

x 11/21/2011

 

2

Q2

A

What is the purpose of the rule?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

3

Q3

A

What is the effective date of the rule?

No updates needed.

N

N

Caitlin

Post

-

 

 

 

 

5

Q5

A

Who will have to report under the final rule?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

7

Q7

A

Which greenhouse gases (GHGs) are covered under the rule?

No updates needed.

N

N

Caitlin

Post

-

 

 

 

 

9

Q9

A

Are mobile sources included in this rule?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

10

Q10

A

What is the definition of a "facility"?

No updates needed.

N

N

Caitlin

Post

-

 

 

 

 

11

Q11

A

Will EPA collect data at the unit-, facility-, or corporate-wide level?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

12

Q12

A

Will EPA accept emissions information from facilities that do not have to report under the mandatory reporting rule? Basically can reporters provide voluntary information to EPA following MRR protocols? In turn would EPA keep this info and share it with the states?

Revise to make explicit EPA's policy with respect to reporting by facilities/suppliers that do not meet threshold.
Also, provide reference to specific comment (EPA-HQ-OAR-2008-0508-0212m, Excerpt 4).

Provided reference to specific comment (EPA-HQ-OAR-2008-0508-0212m, Excerpt 4

N

N

Caitlin

Draft Revision

3

 

 

 

 

13

Q13

A

Can you please describe what constitutes a facility? For example, if a hospital has four buildings, does the rulemaking pertain to the four buildings as a composite, or to each individually? What if the four separate buildings are connected by above-ground or below-ground walkways/tunnels? What if an industrial campus has several different businesses on its property? Each business calculates their own? And if one of the businesses has several buildings, are they treated as a composite or individually? Additionally, the same would apply for a University that has buildings on one campus, or as in many urban settings, the buildings are located in various addresses in a city.

The response assumes that the properties for the two companies in the industrial park example are contiguous. This may not be the case. Should be updated to include other instances.

N

N

Caitlin

Draft Revision

2

 

 

 

 

14

Q14

A

What is the estimated cost to implement this rule?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

15

Q15

A

What impact does this rule have on small businesses?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

16

Q16

A

Did EPA engage stakeholders in the development of the rule?

No updates needed, unless EPA wants to include new stakeholder engagement in 2012 reporting.
OK to post now and revise later.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

17

Q17

A

Was my comment submitted during the public comment period addressed?

May need to be updated to include new comments to reporters documentation and rule signing dates.
OK to post now and revise later.

Y

N

Caitlin

Post

-

 

 

 

 

18

Q18

A

Is this rule a cap and trade regulation?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

20

Q20

A

Does the rule apply to U.S. Territories?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

21

Q21

A

How did EPA develop the general threshold of 25,000 metric tons of carbon dioxide equivalent (mtCO2e) per year?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

22

Q22

A

How much is 25,000 metric tons of CO2 equivalent (mtCO2e)?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

23

Q23

A

Are there some sectors where all facilities have to report regardless of whether they meet the 25,000 metric tons of carbon dioxide equivalent (mtCO2e) annual threshold?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

25

Q25

A

Will all direct emitters of greenhouse gases (GHGs) be included in the rule?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

26

Q26

A

Is there a simple way for facilities with stationary fuel combustion units to determine if they will be required to report?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

27

Q27

A

Will individual home owners be required to report under this rule?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

28

Q28

A

Will individual car or truck owners be required to report?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

29

Q29

A

Will owners of commercial buildings be required to report?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

30

Q30

A

Will federal, state, or local facilities have to report emissions?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

31

Q31

A

Are terrestrial carbon sequestration ("sinks") and offsets projects included in this rule?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

32

Q32

A

Why are both downstream and upstream reporting required?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

33

Q33

A

Will there be double-reporting of emissions under this rule?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

35

Q35

A

How is the reporting of ethanol production and or biogenic emissions being handled in the rule?

No updates needed unless EPA wants to update information about the following "At this time, the Mandatory Reporting of Greenhouse Gases Rule does not require emissions from onsite industrial landfills and wastewater treatment to be reported (see Question 1)."

N

N

Caitlin

Draft Revision

2

 

 

 

 

36

Q36

A

The Applicability Tool says I need to report, but I don't think the tool is right. Please confirm.

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

37

Q37

A

Is applicability based on actual emissions or potential emissions?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

42

Q42

A

How will emissions data be verified?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

43

Q43

A

Will EPA provide training and guidance for reporters?

May need to update based on new webinars/training for 2012 reporters: "Finally, EPA will be hosting a number of webinars and attending meetings to provide information to reporters about the final requirements."

N

N

Caitlin

EPA Review

2

 

 

 

 

45

Q45

A

If facility intends to obtain fuel usage data from utility bills, but its utility bills reflect fuel usage through middle of the month, how does EPA recommend a facility estimate fuel use for the calendar year? Is it acceptable to pro-rate fuel use?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

50

Q50

A

When are reporters required to complete their GHG Monitoring Plan?

Monitoring Plan dates may need to be updated to include 2012 Reporters.
Revision should address requirements for new facilities and existing facilities that were not required to report at outset of program but which later meet applicability criteria.

N

N

Caitlin

Draft Revision

2

 

 

 

 

51

Q51

A

What representative of a reporting facility is in charge of reporting? For example, is it the operator or facility owner? What if a contractor operates a facility owned by someone else? Lastly, can a third partybe hired to report on behalf of the reporting facility?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

53

Q53

A

Does this final rule preempt states from regulating or requiring reporting of greenhouse gases (GHGs)?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

54

Q54

A

Will data collection be delegated to state agencies?

"EPA carefully considered the issue of state delegation, particularly in light of the leadership and experience of several states in developing greenhouse gas (GHG) reporting and reduction programs, and also in the context of the pressing need for a nationwide reporting program and the strong emphasis placed in the vast majority of the rule comments for EPA to ensure that data collection begins on January 1, 2010 and that data are reported early in 2011. " May want to update dates since reporting was in late 2011.

N

N

Caitlin

Edit/Quick Fix

2

 

 

 

 

56

Q56

A

How is this reporting rule different from the Inventory of U.S. Greenhouse Gas Emissions and Sinks report (Inventory)?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

57

Q57

A

Will this rule negate the need for the Inventory of U.S. Greenhouse Gas Emissions and Sinks in the future?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

58

Q58

A

Would this rule need to be addressed in Title V operating permits?

Only needs updates if the following has been changed: "Currently, the Mandatory Reporting of Greenhouse Gases Rule requirements do not have to be incorporated into a facility's Title V permit."

N

N

Caitlin

EPA Review

1

 

 

 

 

59

Q59

A

How could the passing of the Waxman-Markey Bill affect this regulation?

Waxman-Markey never became law. Delete or make question more generic. (The existing response would be appropriate for many questions on legislation before Congress.)

N

N

Caitlin

Withdraw

-

 

 

 

 

60

Q60

A

How will the GHG Reporting Rule fit in or be harmonized with state and local reporting obligations for criteria pollutants, toxics, and state-specific GHG reporting requirements?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

61

Q61

A

How will data be efficiently shared among existing state greenhouse gas (GHG) programs and this new federal reporting program?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

62

Q62

A

Where can I find more detailed information on the rule?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

110

Q110

A

If two entities share a Title V permit would that preclude them from reporting separately even if there is no common ownership or control?

No updates needed unless EPA wants to update its ruling on Title V permits.

N

N

Caitlin

EPA Review

1

 

 

 

 

126

Q126

A

If a campus is divided by several blocks of property not owned by the entity – can that area be defined as a facility by itself?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

127

Q127

A

If a campus is divided by a non-owned body of water (e.g., a river), does that create two distinct facilities?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

129

Q129

A

I leased space within my definition of "facility", if I do not track fuel use for that space, do I have to include it in my report?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

130

Q130

A

I have space which I own, but lease to a third party within my "facility" and the tenant pays the utilities, do I have to include that building space?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

131

Q131

A

Some entities may choose to report all greenhouse emissions for ease of data management, even if some sources do not meet the definition of "facility" and exceed the threshold. If cap and trade rules on greenhouse gas emissions are promulgated in the future and GHG Reporting Rule data is used to establish a cap and trade system, could you speculate whether entities would be able to restate their emissions?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

132

Q132

A

Provide one or two specific examples of what would be acceptable to EPA under §98.3(g)(5)(i)(B), "Explanation of processes and methods used to collect the necessary data for the GHG calculations".

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

142

Q142

A

In the event fuel volume is based on third-party fuel billing meters that meet the exemption in 98.3(i)4, what are the record keeping requirements?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

155

Q155

A

How did EPA use input from stakeholders in the development of the proposed rule amendments?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

179

Q179

A

Section 98.4(b) states the designated representative shall be an individual selected by an agreement binding on the owner or operator of the facility. What constitutes the "agreement"?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

180

Q180

A

For subparts that were published on June 12, 2010, which are magnesium production (subpart T), underground coal mines (subpart FF), industrial wastewater treatment (subpart II) and industrial landfills (subpart TT), when is the Certificate of Representation (COR) due?

No updates needed unless these dates have changed: "Subparts T, FF, II, and TT facilities must submit their first GHG report to EPA on March 31, 2012 for 2011 emissions. They must submit their COR no later than 1/31/2012."

N

Y

Caitlin

Post

-

 

 

x 11/21/2011

 

181

Q181

A

When are the requests for use of Best Available Monitoring Methods (BAMM) for subparts T, FF, II, and TT due?

No updates needed unless these dates have changed:"For subparts that were published on June 28, 2010, which are magnesium production (subpart T), underground coal mines (subpart FF), industrial wastewater treatment (subpart II) and industrial landfills (subpart TT), the BAMM request is due October 12, 2010. The use of BAMM will not be approved beyond December 31, 2011. Note: The rule does not automatically authorize use of BAMM for the first quarter of 2011 for subparts T, FF, II, and TT."

N

Y

Caitlin

Post

-

 

 

x 11/21/2011

 

182

Q182

A

For subparts T, FF, II, and TT, is the use of Best Available Monitoring Methods (BAMM) automatically allowed for the first quarter of 2011 (January 1, 2011 to March 31, 2011)?

No updates needed unless these dates have changed:"No, the use of BAMM is not automatically allowed for the first quarter of 2011 for subparts T, FF, II, and TT. Facilities must submit a request to use BAMM by October 12, 2010. The use of BAMM will not be approved beyond December 31, 2011.

N

Y

Caitlin

Post

-

 

 

x 11/21/2011

 

278

Q278

A

My facility has completed its use of best available monitoring methods (BAMM) and is now fully following the methods in the final rule. Do and I need to notify EPA of this change?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

284

Q284

A

The definition of "owner" and "operator" under 98.6 refers to a "person." Is a person only a single individual?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

299

Q299

A

What does EPA mean by the term "sequential or simultaneous" in the definition of co-generation?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

321

Q321

A

Does the roll-up calculator distinguish between direct emitters and suppliers?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

388

Q388

A

Who must submit requests and one-time reports to EPA under Part 98?

No updates needed.

N

N

Caitlin

Post

-

 

 

 

 

44

Q44

C

There are currently no CEMS available at my facility. Is there a provision to allow calculations of Tier 1, 2 or 3 if the cost of purchasing and installing CEMS will be seriously detrimental to the company?

Change "CEMS are" to "CEMS is" in 2nd sentence of response. Delete 2nd paragraph, which is applicable to RY2010 only.

N

Y

Dick

Edit/Quick Fix

1

 

11/29/2011

 

 

64

Q64

C

Should pilot gas be included in greenhouse gas calculations?

OK

N

N

Dick

Post

-

 

 

x 11/21/2011

 

66

Q66

C

Where does no. 2 diesel fuel fit into Table C-1 and C-2?

OK

N

N

Dick

Post

-

 

 

x 11/21/2011

 

67

Q67

C

Where the heat input capacity of a combustion unit is less than 250 mm Btu per hour input capacity and the unit is not subject to Tier 3 or 4 per Subpart Y of Part 98, and where there might be more than one fuel type fed to...?

Change "mm Btu" to "mmBtu" in question.

N

N

Dick

Edit/Quick Fix

1

 

 

 

 

68

Q68

C

40 CFR §98.33(a)(3)(iii) indicates that "For units that combust municipal solid waste (MSW) and that produce steam, use Equation C-2c of this section". However, Table C-1...

OK

N

N

Dick

Post

-

 

 

x 11/21/2011

 

200

Q69

C

Does fuel use for comfort heating and hot water heaters need to be reported?

OK

N

N

Dick

Post

-

 

 

x 11/21/2011

 

70

Q70

C

Would fuels combusted in a test stand be considered as stationary fuel combustion when the articles being tested are mobile sources (aircraft, rocket, missile, spacecraft)?

OK

N

N

Dick

Post

-

 

 

x 11/21/2011

 

71

Q71

C

For CAIR-affected units that monitor SO2 and NOX emissions and Heat Input using the provisions of Part 75 Appendix D & E, but are not required to report CO2 mass emissions, may Part 75 Appendix G be used for CO2 reporting under Part 98?

OK

N

N

Dick

Post

-

 

 

x 11/21/2011

 

72

Q72

C

For a unit that currently uses gas monitors for other pollutants, but does not have a flow monitor, is it necessary to install and certify a flow monitor by March 31, 2010...?

Reword question and response to make it applicable to RY2011. Can be deleted for RY2012.

?

Y

Dick

Draft Revision

2

 

 

 

 

73

Q73

C

If a non-Acid Rain unit combusts coal or other solid fossil fuel and has gas monitors installed but does not have a stack flow monitor, is installation and certification of a stack flow monitor required?

Retain 1st sentence of response only (and include citation for flow monitor requirement).

Y

Y

Dick

Edit/Quick Fix

1

 

 

 

 

74

Q74

C

If a unit that combusts only fossil fuels has a CEMS for CO2 and uses Tier 4, must CO2 be reported by fuel type?

OK

N

N

Dick

Post

-

 

 

x 11/21/2011

 

75

Q75

C

For a unit that combusts fossil and biomass fuels that has a CEMS for CO2 and uses Tier 4, must CO2 be reported by fuel type?

OK

N

N

Dick

Post

-

 

 

x 11/21/2011

 

76

Q76

C

For a group of units that combusts only pipeline quality natural gas, may a shared fuel flow meter on a common pipe or gas supplier billing meter data be used to determine the CO2 mass emissions for the group of units?

OK

N

N

Dick

Post

-

 

 

x 11/21/2011

 

77

Q77

C

For a unit that has an O2 monitor and doesn't meet the conditions required to use Tier 4, but elects to use Tier 4, what are the monitoring requirements?

Spell out acronym (RATA)?  (RATA = relative accuracy test audit.)

N

N

Dick

Edit/Quick Fix

1

 

 

 

 

78

Q78

C

For a source that has CEMS for other pollutants, but not for CO2 mass measurement, and is required to use Tier 4, when must the monitors be installed and certified?

Delete or revise to make applicable for new facility, i.e., how soon after beginning of operations must CEMS be installed and certified and CO2 data recorded and reported to EPA?

Y

Y

Dick

Draft Revision

2

 

 

 

 

80

Q80

C

If the HHV is known as part of a general energy management system, but not sampled on a routine basis, may Tier 1 be used?

Address requirement for units >250 mmBtu/hr.

N

N

Dick

Draft Revision

2

 

 

 

 

211

Q81

C

If a combustion unit is greater than 250 mmBtu per hour, combusts a biomass fuel listed in Table C-1, and receives HHV data at the required frequency in §98.34(a), may Tier 1 be used per 40 CFR 98.33(b)(1)(iii)?

OK

N

N

Dick

Post

-

 

 

x 11/21/2011

 

82

Q82

C

For a non-Acid Rain combustion turbine rated over 250 mmBtu per hour that only burns diesel oil and pipeline natural gas, is it acceptable to use Tier 2...

OK

N

N

Dick

Post

-

 

 

x 11/21/2011

 

83

Q83

C

For diesel fuel (e.g., No. 1 or No. 2 fuel oil) shipments that are received 1 or 2 times a year, is it sufficient to sample the fuel carbon content upon receipt of each shipment for Tier 3?

OK

N

N

Dick

Post

-

 

 

x 11/21/2011

 

84

Q84

C

For a unit that is not required to use Tier 4 (CEMS monitoring), which tier is required if you receive HHV with some coal shipments, but not every coal shipment?

Consider adding discussion of missing data procedures for fuel lots for which no HHV is obtained?

?

N

Dick

Draft Revision

2

 

 

 

 

85

Q85

C

Is the use of Subpart C tiers required after 2010 and is it acceptable to use the best available monitoring provisions under Subpart A beyond 2010?

Delete unless there are exceptions to prohibition on using BAMM after RY2010 (i.e., for Track 2 facilities)

?

Y

Dick

Draft Revision

1

 

 

 

 

86

Q86

C

Does Tier 3 have to be used if a unit is less than or equal to 250 mmBtu per hour, but has a continuous gas chromatograph to determine carbon content?

Add rule reference

Y

N

Dick

Edit/Quick Fix

1

 

 

 

 

87

Q87

C

What Tier, if any, must be used for a fuel not listed in Table C-1 that is less than 10% of the heat input of a combustion unit?

OK

Y

N

Dick

Edit/Quick Fix

1

 

 

 

 

88

Q88

C

If a combustion unit with a heat input capacity less than 250 mmBtu per hour burns both natural gas and a liquid fuel, and the quantities are known...

Add rule reference

Y

N

Dick

Edit/Quick Fix

1

 

 

 

 

89

Q89

C

Do facilities that are required to use the Tier 4 calculation methodology in subpart C have to apply for an extension under 98.3(d)(2) if they cannot get the appropriate equipment in place by March 31, 2010?

Delete. Revised FAQ 78 will cover this issue for RY2011 and beyond.

N

Y

Dick

Withdraw

1

 

 

 

 

90

Q90

C

Does EPA accept thermal flow meters for measuring volumetric flow rate under 98.34?

Add rule reference

Y

N

Dick

Edit/Quick Fix

1

 

 

 

 

91

Q91

C

Are orifice, venturi, and nozzle flow meters required to have temperature, and total pressure transmitters located on the flowmeters?

Add rule reference

Y

N

Dick

Edit/Quick Fix

1

 

 

 

 

92

Q92

C

For a unit that operates continuously with infrequent outages and will not be able to meet the April 1, 2010 deadline for the initial calibration of a Tier 3 fuel flow meter, does the facility have to request an extension from EPA?

Delete?
Consider revising for Track 2 facilities and new/existing facilities that meet applicability criteria after RY2010.

N

Y

Dick

EPA Review

2

 

 

 

 

93

Q93

C

What should facilities do if the calibration error for fuel flow meters that exceeds the 5.0% performance specification?

Revise for RY2011 and beyond to remove reference to BAMM. Add rule reference.

Y

Y

Dick

Draft Revision

2

 

 

 

 

94

Q94

C

For Tier 3, if the equipment in place on January 1, 2010 is unable to measure carbon content and molecular weight of the fuel on a daily basis, must that equipment be replaced?

Update question and response to make it applicable to RY2011 and beyond.

N

Y

Dick

Draft Revision

2

 

 

 

 

95

Q95

C

If a facility has a billing meter for natural gas distributed to the combustion units throughout the facility, and if these combustion units also have their own meters, is there an obligation...

OK

N

N

Dick

Post

-

 

 

x 11/21/2011

 

226

Q96

C

Is there a recurring fuel flow meter calibration requirement for Tier 1 and Tier 2 units?

OK

N

N

Dick

Post

-

 

 

x 11/21/2011

 

227

Q97

C

Does the calibration exemption for fuel billing meters still apply for common pipe reporting option?

Add rule reference

Y

N

Dick

Edit/Quick Fix

1

 

 

 

 

133

Q133

C

Can I use more than 1 Tier Method for my facility?

Add rule reference

Y

N

EPA SME

Edit/Quick Fix

1

 

 

 

 

134

Q134

C

I have a natural gas emergency generator and a boiler in a building within the facility but no means to separate the usage out – how do I account for that, since the e-gen is not included?

Add rule references

Y

N

EPA SME

Edit/Quick Fix

1

 

 

x 11/21/2011

 

135

Q135

C

I have natural gas meter records for a building that uses natural gas for heating and cooking – but no separate meters – how do we account for that?

Add rule reference

Y

N

EPA SME

Edit/Quick Fix

1

 

 

x 11/21/2011

 

137

Q137

C

I do not have a fuel meters at a building on the source, but know how much fuel is delivered. This is not the actual amount used, since my inventory at the beginning of the year may be different than the end – should I use the delivered amount?

Edit question ("I do not have a fuel meters on the source at a building on the source...") and add rule reference.

Y

N

EPA SME

Edit/Quick Fix

1

 

 

x 11/21/2011

 

138

Q138

C

Please explain what High Heat Value (HHV) testing is and how a school's EH&S personnel would know if this is occurring?

Response doesn't really address the question. Revise one or the other.

Y

N

Dick

Draft Revision

2

 

 

 

 

139

Q139

C

Would a boiler (or other combustion unit) that is mounted on a trailer or movable platform, that is used to provide temporary services while facility equipment is serviced, upgraded, or replaced, and where such equipment remains at the facility...

Add rule reference for exclusion of portable equipment (40 CFR 98.30(b)(1)).

Y

N

EPA SME

Edit/Quick Fix

1

 

 

x 11/21/2011

 

140

Q140

C

Would the following be considered stationary or portable sources, assuming their location falls within the definition of facility?

Reformat. Add rule reference.

Y

N

EPA SME

Edit/Quick Fix

1

 

 

x 11/21/2011

 

235

Q146

C

Many facilities use mass or volumetric flow meters to measure gaseous streams. Please confirm whether it is acceptable to use a mass flow meter to determine the volumetric flow rate of gaseous streams under Subpart C or the GHG Reporting Rule.

Add rule reference

Y

N

EPA SME

Edit/Quick Fix

1

 

 

x 11/21/2011

 

148

Q148

C

With respect to coal or fuel oil, the rule requires analysis of at least one representative sample from each lot. Does EPA have any additional guidance on what constitutes a "lot?"

OK

N

N

Dick

Post

-

 

 

x 11/21/2011

 

237

Q149

C

If coal comes from the same source, how many deliveries must be analyzed to have a representative sample?

Add rule reference

Y

N

EPA SME

Edit/Quick Fix

1

 

 

x 11/21/2011

 

307

Q307

C

How do you report a unit in e-GGRT that uses Tier 2 or 3 for part of the year and CEMS for the remainder of the year?

Add rule references

Y

N

EPA SME

Edit/Quick Fix

1

 

 

x 11/21/2011

 

239

Q308

C

How do you report in e-GGRT a fuel that changed calculation methodology from Tier 1 to Tier 2 for a given configuration during the middle of the year?

OK

N

N

Dick

Post

-

 

 

x 11/21/2011

 

322

Q322

C

To what precision should emission values for CO2, N2O, and CH4 be reported in e-GGRT?

Add rule reference

Y

N

EPA SME

Edit/Quick Fix

1

 

 

x 11/21/2011

 

323

Q323

C

If I am only reporting subpart C emissions for the 2010 reporting year, am I allowed to use the subpart C abbreviated reporting module?

Delete

N

Y

Dick

Withdraw

-

 

 

 

 

324

Q324

C

If a facility is eligible to use the subpart C abbreviated reporting form, is it required to or may it use the full subpart C reporting form?

Delete

N

Y

Dick

Withdraw

-

 

 

 

 

325

Q325

C

What are biogenic emissions?

OK

N

N

Dick

Post

-

 

 

x 11/21/2011

 

326

Q326

C

What are non-biogenic emissions?

OK

N

N

Dick

Post

-

 

 

x 11/21/2011

 

327

Q327

C

If multiple subparts apply to our sources such as subparts A, C, and D, are we reporting data under all three subparts?

OK

N

N

Dick

Post

-

 

 

x 11/21/2011

 

328

Q328

C

For Tier 4 configurations, if there is no missing data, do you still have to report total operating hours in the reporting year and zeros for hours in which substitute data was use?

Correction: "if there are no missing data..."

N

N

EPA SME

Edit/Quick Fix

1

 

 

x 11/21/2011

 

329

Q329

C

Is a blend of natural gas and biogas a unique fuel type that must be added?

Add rule reference

Y

N

Dick

Edit/Quick Fix

1

 

 

 

 

330

Q330

C

If a natural gas common pipe is connected to a series of small combustion units and a subpart D unit, how should emissions be reported?

OK

N

N

Dick

Post

-

 

 

x 11/21/2011

 

331

Q331

C

Am I required to report emissions for emergency generators?

Add rule reference for emergency generator definition (40 CFR 98.6).

Y

N

Dick

Edit/Quick Fix

1

 

 

 

 

332

Q332

C

Is there a limit on the number of units or fuel types listed for an aggregation of units configuration?

Add rule reference

Y

N

Dick

Edit/Quick Fix

1

 

 

 

 

333

Q333

C

Can you change configuration types from year to year?

Add rule references?

Y?

N

Dick

Edit/Quick Fix

1

 

 

 

 

334

Q334

C

Is there any flexibility in deciding what configuration type I can use for a unit or group of units?

Add rule references to aggregation of units and common pipe configurations?

Y?

N

Dick

Edit/Quick Fix

1

 

 

 

 

335

Q335

C

Am I required to enter emissions for each fuel type?

OK

N

N

Dick

Post

-

 

 

x 11/21/2011

 

337

Q337

C

If a facility is permitted to burn fuel of a certain type, is it required to identify that fuel type in e-GGRT?

Question could be clarified to indicate that we are talking about fuels that are permitted but not actually used by the facility in the reporting year.

N

N

Dick

Draft Revision

2

 

 

 

 

338

Q338

C

For Tier 3, if I have multiple combustion sources using a single fuel type, should I enter this as an aggregation of units?

Add rule references

Y

N

Dick

Edit/Quick Fix

1

 

 

 

 

309

Q309

D

Will e-GGRT import any data from Electronic Data Reports (EDRs) or CAMD?

OK

N

N

Dick

Post

-

 

 

x 11/21/2011

 

339

Q339

D

Will a subpart D unit that co-fires biogas have to set up both Subpart D and C modules to calculate the biogenic CO2 per 98.33?

OK

N

N

Dick

Post

-

 

 

x 11/21/2011

 

340

Q340

D

Are CAIR units part of Subpart D reporting?

OK

N

N

Dick

Edit/Quick Fix

1

 

12/2/2011

x 12/2/2011

 

387

Q387

L

Are processes with scrubbers that decompose F-GHGs required to submit the one-time report required by §98.126i, even though they have no combustion control device and do not technically emit "PICs" from the scrubber vent ?

Delete.  Date for submission of one time report (6/30/2011) has passed.

N

Y

Dick

Withdraw

-

 

 

 

 

291

Q291

O

On March 18, 2011, EPA extended the deadline for reporting 2010 GHG data from March 31, 2011 to September 30, 2011. Does this extension also apply to the one-time reports that are due on March 31, 2011, and that are required under subpart O at §98.156(e)? If not, then how and where should these reports be submitted?

Delete.  Date for submission of one time report (3/31/2011) has passed.
Consider revising to accommodate new facilities and existing facilities that become subject to subpart L after RY2011.

N

Y

Dick

EPA Review

3

 

 

 

 

341

Q341

P

Does subpart P require me to account for ammonia emitted as an air emission?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

123

Q123

Y

For petroleum refineries, which subpart should be followed for flare calculations? Section 98.252(a) says to use Subpart C. However, section 98.253(b) specifies a method for flares.

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

342

Q342

Y

Are you required to submit information for all of the "facility-level emissions" categories within Subpart Y, even if no emissions exist for some categories?

Only needs updates if EPA decided that certain facilities do not need to report in all of the unit and facility-level sections in Y.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

345

Q345

Y

For storage tank emissions reported in Subpart Y, do you enter aggregate emissions or emissions on a tank-by-tank basis?

No updates needed.

N

N

Caitlin

Post

-

 

 

x 11/21/2011

 

125

Q125

AA

The definition of the source category for Pulp and Paper is relatively broad to include a range of pulp and paper manufacturing activities. If a facility falls under the definition of 98.270 (a) but does not contain emission units specified in 98.270(b) for which greenhouse gas emissions must be reported, is such a facility subject Subpart AA?

OK

N

N

Emily

Post

-

 

 

x 11/21/2011

 

310

Q310

AA

For subpart AA in e-GGRT, on the screen to enter CO2 emissions from makeup chemicals, why are there two boxes to check?

Suggest editorial revisions; language in first sentence is awkward.

N

N

Emily

Edit/Quick Fix

1

 

 

 

 

311

Q311

AA

For subpart AA in e-GGRT, can a reporter add multiple instances of makeup chemical use?

Mass quantity of makeup chemicals/year is specified in calculation in 98.273(d). 

Y

N

Emily

Edit/Quick Fix

1

 

 

 

 

346

Q346

AA

Is a paper making company required to report GHG emissions under Subpart AA if the only source of emissions is on -site combustion?

Reference to the units required in 98.270(b) might be added. 

Y

N

Emily

Draft Revision

2

 

 

 

 

288

Q288

FF

Do small, non-gassy mines need to report MSHA samples quarterly even though they are not specifically required to?

OK.  (May be subject to future rule change.)

N

N

Dick

Post

1

 

 

x 11/21/2011

 

98

Q98

HH

The landfill industry uses a portable meter that uses an IR method to determine methane and carbon dioxide concentrations. Has the EPA determined if these units are acceptable and comply with the accuracy required by the rule?The landfill industry uses a portable meter that uses an IR method to determine methane and carbon dioxide concentrations. Has the EPA determined if these units are acceptable and comply with the accuracy required by the rule?

98.644(b)(6) should be referenced

Y

N

Emily

Edit/Quick Fix

1

 

 

 

 

100

Q100

HH

When does moisture content need to be corrected for in Equation HH-4?

Reference to 98.343(b)(1) is required.  This question is ok, and direct. However, moisture content came up quite a bit during the last cycle--we may want to add more FAQs

Y

N

Emily

Edit/Quick Fix

1

 

 

 

 

102

Q102

HH

What models are acceptable for performing the calculations in subpart HH?

OK

N

N

Emily

Post

-

 

 

x 11/21/2011

 

103

Q103

HH

How should inert wastes be accounted for in Equation HH-1?

Could be more broadly rewritten to incorporate Q359. 

N

N

Emily

Draft Revision

2

 

 

 

 

104

Q104

HH

The methods listed in section 98.344 are not applicable to my monitor, how should I calibrate?

OK

N

N

Emily

Post

-

 

 

x 11/21/2011

 

105

Q105

HH

What is the definition of facility as it relates to landfills and landfill gas to electric (LFGTE) plants?

This should be updated in the event that this guidance from EPA has changed (Marty hinted that it might be; I do not know if additional guidance was issued).  References to the facility definitions in subpart A should be included

Y

N

Emily

EPA Review

1

 

 

 

 

106

Q106

HH

We do not have any records or receipts for the waste quantities that were placed in our landfill before 2000, how do we estimate historic waste quantities before that year?

Could be rewritten to actually specify the methods included in 98.343(a)(3). 

N

N

Emily

Draft Revision

2

 

 

 

 

107

Q107

HH

If an MSW landfill has a dedicated area which receives waste other than MSW, may this area be excluded from the rule requirements?

Should reference facility requirements in Subpart A.  Can be expanded to discuss how the calculations are applied when different types of waste exist (see JIRA 15335)

Y

N

Emily

Draft Revision

2

 

 

 

 

108

Q108

HH

If an MSW landfill is later remediated as a hazardous waste landfill, does it need to comply with the rule?

Could include reference to applicability requirements in 98.340. 

Y

N

Emily

Edit/Quick Fix

1

 

 

 

 

109

Q109

HH

If I use a flame ionization detector (FID) or an infrared (IR) monitor, am I required to determine an annual non-methane organic correction factor?

Needs to be cross-referenced or (preferably) combined with Q98. 

N

N

Emily

Draft Revision

2

 

 

 

 

111

Q111

HH

Do landfills have to report the biogenic CO2 that is included in LFG emissions and the CO2 that is emitted from flares?

Refer to 98.342 (CO2 not included in gases to report) and 98.30(a)(4) (exclusion of flares from Subpart C).

Y

N

Emily

Edit/Quick Fix

1

 

 

 

 

112

Q112

HH

How does EPA define "at least weekly" in the monitoring requirements?

OK

N

N

Emily

Post

-

 

 

x 11/21/2011

 

113

Q113

HH

If all of our landfill gas gets piped offsite to another facility, what do we need to report?

OK

N

N

Emily

Post

-

 

 

x 11/21/2011

 

114

Q114

HH

Can an alternate oxidation factor, other than 10% be used in the calculations?

Can this be rewritten to tell the user why an alternate oxidation factor cannot be used?  Also, rule reference required.

Y

N

Emily

Edit/Quick Fix

1

 

 

12/1/2011

 

116

Q116

HH

Do passive flares count as "gas collection systems" under the provision below? Do the landfills with these systems have to collect data weekly?

Delete the part of the question asking about "weekly"--it's not relevant.  Could be expanded w additional detail (several JIRA tickets on this) on passive flares (there was some confusion for users as to if their systems were passive or not).l

N

N

Emily

Draft Revision

2

 

 

 

 

117

Q117

HH

Does EPA's definition of treatment equipment include moisture knockout and blower systems? Is it acceptable to EPA for the flow meter to be placed after the moisture knockout and blower or is it required to be placed before these items?

Rule reference is 98.343(b), however, this is an interpretation of the language. 

Y

N

Emily

Edit/Quick Fix

1

 

 

 

 

119

Q119

HH

Are annubars or v-cone flowmeters acceptable for compliance with the rule requirements?

98.344(c) is the only necessary citation.  Note on calibration is unnecessary, as it's specified in same rule reference.

Y

N

Emily

Edit/Quick Fix

1

 

 

 

 

120

Q120

HH

Is weekly monitoring of both gas flow and methane concentration allowed?

Rephase into a more general question about acceptable monitoring periods; combine with 112 above.  This answer is also slightly confusing--it answers "no," then states that it is allowed if continuous monitoring is not in place. 

Y

N

Emily

Draft Revision

2

 

 

 

 

121

Q121

HH

The applicability tool refers to a 350,000 waste-in-place threshold. Is reporting required if the total waste-in-place is less than 350,000 tons?

Could refer to applicability sections in rule.

Y

N

Emily

Edit/Quick Fix

1

 

 

 

 

122

Q122

HH

Can a landfill ever stop reporting under the rule?

Include rule citation

Y

N

Emily

Edit/Quick Fix

1

 

 

 

 

141

Q141

HH

My site has a gas collection system, which equations do I need to calculate to determine my methane generation and GHG emissions?

OK

N (but refers to calcs)

N

Emily

Post

-

 

 

x 11/21/2011

 

291

Q150

HH

Are scales required for Municipal Solid Waste Landfills?

Should reference 98.343(a)(3)

Y

N

Emily

Edit/Quick Fix

1

 

 

 

 

151

Q151

HH

Must every container or vehicle be weighed coming in and going out of the landfill?

Should reference 98.343(a)(3)(i)

Y

N

Emily

Edit/Quick Fix

1

 

 

 

 

153

Q153

HH

Does EPA accept thermal flow meters for measuring volumetric flow rate of LFGs?

Combine into a more general question on acceptable flowmeters with Q119. 

Y

N

Emily

Draft Revision

2

 

 

 

 

154

Q154

HH

What additional considerations are necessary when using a mass flow meter for landfill gas?

OK

Y

N

Emily

Post

-

 

 

 

 

347

Q347

HH

What is meant by manufacturer of gas collection system?

OK

N

N

Emily

Post

-

 

 

x 11/21/2011

 

348

Q348

HH

What if two methods are used to estimate waste disposal quantities in a single year? How does a reporter indicate that in e-GGRT?

OK

N

N

Emily

Post

-

 

 

x 11/21/2011

 

349

Q349

HH

The questions on reporting where gas is destroyed seem to consider only 2 options - either entirely on-site or entirely off-site. What if some gas is sent off-site and the rest is consumed on-site?

OK

N

N

Emily

Post

-

 

 

x 11/21/2011

 

350

Q350

HH

What if I have more than one landfill or more than one cell at my facility, one is closed, one is open, and each has different waste content?

OK

Y

N

Emily

Post

-

 

 

 

 

351

Q351

HH

Have any of the equations been revised, or have any new equations been added since Subpart HH was finalized in 2009?

Should be updated to refer to the most recent rule--also there's a typo for the October 2010 rule.

Y

N

Emily

Edit/Quick Fix

1

 

 

 

 

352

Q352

HH

What are definitions of wet and dry gas in subpart HH?

OK

N

N

Emily

Post

-

 

 

x 11/21/2011

 

353

Q353

HH

If a LFG flow meter malfunctions and is out for service for a week or two, are we required to have a backup meter or can we use the estimating missing data provisions of 98.345 to estimate the gas volumes during the period that the meter was not in place?

Could be made more general with respect to missing data procedures

Y

N

Emily

Draft Revision

2

 

 

 

 

354

Q354

HH

Do the emission formulas differ from those used in LandGEM?

Needs to more directly answer the question as to how the model and equation HH-1 are similar.  Could be combined with Q102 above.

N

N

Emily

Draft Revision

2

 

 

 

 

355

Q355

HH

Do we have to use the quantity of waste disposed of for every year since 1960 to calculate the modeled CH4 generation rate?

OK

N

N

Emily

Post

-

 

 

x 11/21/2011

 

356

Q356

HH

How far back in the past do we answer questions about the facility? How do we handle unknown information when the site was owned by someone prior?

OK

N

N

Emily

Post

-

 

 

x 11/21/2011

 

357

Q357

HH

A site has 3 cells. Cells 1 and 2 have active LFG collection systems and cell 3 does not, how do we proceed?

Add specific reference to 98.343(c)(3)(ii)

Y

N

Emily

Edit/Quick Fix

1

 

 

 

 

358

Q358

HH

Did you say if we have an MSW with other parts we don't have to count those parts towards our methane generation if they were another type of landfill? (i.e., a C & D portion)? I assume I heard that wrong.

Combine w Q107--dealing with landfills that have portions that do not contain MSW.

Y

N

Emily

Draft Revision

2

 

 

 

 

359

Q359

HH

If the landfill accepts only incinerator ash (inert) and does not generate gas, should we consider reporting the quantities of ash?

Could be combined with Q103

N

N

Emily

Draft Revision

2

 

 

 

 

360

Q360

HH

How do you address a landfill which may have portions of lined area and others that are not lined for the same landfill?

OK

N

N

Emily

Post

-

 

 

x 11/21/2011

 

361

Q361

HH

I am required to provide the values of Eq. HH-5 - HH-8. How are the depth waste data used?

Expand to include more detail on how was depth informs CE (in several JIRA tickets)

Y

N

Emily

Draft Revision

2

 

 

 

 

362

Q362

HH

How do we account for highly variable designs i.e. pre and post Subtitle D, with variable depths and different cover cross-sections?

Ok

N

N

Emily

Post

-

 

 

x 11/21/2011

 

389

Q389

HH

Within e-GGRT, how would a landfill handle multiple destruction devices including a portion of the gas sent off-site for destruction? Is there a way to add multiple on-site destruction devices for a gas system?

OK

Y

N

Emily

Post

-

 

 

 

 

19

Q19

JJ

How does the restriction attached to EPA's Appropriation Bill for 2010 impact Subpart JJ (Manure Management Systems) in the final Mandatory Reporting of Greenhouse Gases Rule that was published in the Federal Register on October 30, 2009?

Delete and combine with Q184--this is the same issue.

N

N

Emily

Withdraw

-

 

 

 

 

184

Q184

JJ

Can facilities with manure management systems report under the Greenhouse Gas Reporting Program?

Rephrase the question and answer--the question is not so much "can" these facilities report, but whether they will be able to with the current system & appropriations.  Suggest that the answer include a link to the Subpart JJ page on the EPA website (http://www.epa.gov/climatechange/emissions/subpart/jj.html), as this has information on both 2010, 2011 appropriations. Will need to be updated with any additional appropriations acts.

N

Y

Emily

Draft Revision

2

 

 

 

 

183

Q183

LL

Under subpart LL, are coal-to-liquids facilities required to report on coal-based products that are solid products (such as coke), or is reporting limited to liquid products?

OK

 

 

Emily

Post

-

 

 

x 11/21/2011

 

164

Q164

MM

A third party measures the quantity of a petroleum product I receive with equipment that is not located on my site. Am I allowed to use that data to report quantity in my annual GHG report? Who is responsible for retaining the associated records? Who is responsible for the accuracy of that measurement?

OK

N

N

Matt

Post

-

 

 

x 11/21/2011

 

165

Q165

MM

What is an industry standard practice, and when can one be used? How should I report an industry standard practice? Is "third party verification" or "delivery record" an industry standard practice?

Add reference to §98.7

Y

N

Matt

Edit/Quick Fix

1

 

 

 

 

166

Q166

MM

The quantity of petroleum product that I import is determined by a third party gauger who is approved by Customs & Border Protection (CBP). How should I comply with the quantity determination requirements in §98.393(a)?

OK

N

N

Matt

Post

-

 

 

x 11/21/2011

 

167

Q167

MM

If my refinery sells a fuel product to a pipeline company that is measured by a custody transfer meter that is owned and operated solely by the customer, can I define this meter as a "fuel gas billing meter" as in subpart A §98.3 \(i) (4), which says: "Fuel billing meters are exempted from the calibration requirements of this section, provided that the fuel supplier and any unit combusting the fuel do not have any common owners and are not owned by subsidiaries or affiliates of the same company."

OK

N

N

Matt

Post

-

 

 

x 11/21/2011

 

168

Q168

MM

Am I required to report under subpart MM even though my refinery does not input any crude oil?

Add reference to §98.2(a)(4), Table A-5

Y

N

Matt

Edit/Quick Fix

1

 

 

 

 

169

Q169

MM

Does the rule cover imports into and exports from all U.S. possessions, including Puerto Rico, Guam, U.S. Virgin Islands, and other U.S. territories?

OK

N

N

Matt

Post

-

 

 

x 11/21/2011

 

170

Q170

MM

Does the rule require reporting for import shipments into a specified U.S. territory from another U.S. location, and export shipments from a specified U.S. territory to another U.S. location?

Add reference to §98.6 (Definitions)

Y

N

Matt

Edit/Quick Fix

1

 

 

 

 

171

Q171

MM

If my refinery produces a product, feedstock or blendstock stream that is not listed in Table MM-1, how should I comply with the subpart MM reporting requirements? Am I required to use Calculation Method 2 to develop my own emission factor?

OK

N

N

Matt

Post

-

 

 

x 11/21/2011

 

172

Q172

MM

Can a product-specific factor developed at one facility be used at another facility for the same type of product?

OK

N

N

Matt

Post

-

 

 

x 11/21/2011

 

173

Q173

MM

What is meant by "otherwise used on site" for the subpart MM equations using feedstock quantities?

OK

N

N

Matt

Post

-

 

 

x 11/21/2011

 

174

Q174

MM

How do I account for intermediate stocks that are traded between different refineries. For example, if I send gasoil to another location, do I account for it or do I only report finished products?

OK

N

N

Matt

Post

-

 

 

x 11/21/2011

 

175

Q175

MM

What biomass activities are included in Equation MM-3, and in what cases should I subtract biomass out of equation MM-8?

Add reference to §98.393

FAQ175 has been updated on 11/10/11. Rule references 98.393(c) and 98.393(h)(1) have been added.

Y

N

Matt

Edit/Quick Fix

1

 

 

 

 

176

Q176

MM

If a refinery imports and exports petroleum products, should these products be reported both at the facility level under §98.396(a) as well as at the corporate level under §98.396(b) and (c)?
Disclaimer This information is intended to provide general and administrative information about 40 CFR Part 98. It does not represent legal advice. This information

OK

N

N

Matt

Post

-

 

 

x 11/21/2011

 

286

Q286

NN

If a natural gas supplier has companies it owns in different states, can the supplier report all of the companies together or should they be separated by state or company name?

OK

N

N

Matt

Post

-

 

 

x 11/21/2011

 

289

Q289

NN

The rule states that LDCs need to report under subpart NN if they delivered more than 460,000 Mscf in 2010. How should an LDC determine if it "delivered" more than 460,000 Mscf in 2010? Does this include quantities delivered to other LDCs and/or large end-users? What about natural gas placed into/removed from storage?

OK

N

N

Matt

Post

-

 

 

x 11/21/2011

 

178

Q178

OO

Are importers of HFCs required to obtain EPA approval before importing the HFCs into the U.S.?

The first sentence is the only one that directly answers question; Where does it say that you shouldn't report CFCs/HCFCs?  Citation needed for applicability sections, if those are really determined to apply to this question.

Y

N

Emily

Draft Revision

2

 

 

 

 

287

Q287

OO

How does one handle the calculation of blends such as R-410A? Do we calculate on the basis of the components, e.g., HFC-125 and HFC-32?

OK.  Cannot be sourced to rule; is based on industry knowledge of this category.

N

N

Emily

Post

-

 

 

x 11/21/2011

 

292

Q292

OO

On March 18, 2011, EPA extended the deadline for reporting 2010 GHG data from March 31, 2011 to September 30, 2011. Does this extension also apply to the one-time reports that are due on March 31, 2011, and that are required under subpart OO at §98.416(b), (e), and (f)? If not, then how and where should these reports be submitted?

Revised to make applicable to future reporters (those who are required to report w/in 60 days of commencing destruction).  The March 31 deadline no longer applies

N

Y

Emily

Draft Revision

3

 

 

 

 

363

Q363

OO

Does the information from the Reporting Forms populate e-GRRT fields or are they just uploaded files? If automatically populated, are these values available for review before submitting the report?

Suggest this be made more general to the spreadsheet Reporting Forms. 

N

N

Emily

Draft Revision

2

 

 

 

 

364

Q364

OO

How do I calculate addition to the "net supply"?

Need to source area in the spreadsheet and rule that applies.  Combine w/ FAQ 365.

Y

N

Emily

Draft Revision

2

 

 

 

 

365

Q365

OO

Why do net additions of GHGs have to be added manually when they already exist in the uploaded

Combine with 364 above.

Y

N

Emily

Withdraw

-

 

 

 

 

366

Q366

OO

Can we upload multiple copies of the same file if we have more than 10 processes? How will eGGRT know that the second copy is a report for processes 11-20 and not just an overwrite of the report filed for processes 1-10? For more than 10 production processes and multiple forms, can we just fill out Part 2 of the additional forms (process information, not facility information)?

OK.  Not necessary to reference rule, this is a usage question

N

N

Emily

Post

-

 

 

x 11/21/2011

 

390

Q390

OO

How do I report imports and exports of refrigerant blends that contain both HCFCs and HFCs?

Doesn't seem to directly answer the question--discusses reporting requirements for these gases, but not specifically reporting requirements for the blends.  More detailed rule references are required. 

Y

N

Emily

Draft Revision

3

 

 

 

 

279

Q279

PP

To measure the composition of the CO2 stream, am I limited to the two methods listed in 40 CFR part 98.424(b)(2)?

Correct rule reference:  40 CFR part 98(a)(4) should be 40 CFR part 98.426(a)(4).

N

N

Dick

Edit/Quick Fix

1

 

 

 

 

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