FAQ Table
FAQ No. Topic Area Question 1 Subpart A What is the action being taken? 2 Subpart A What is the purpose of the rule? 3 Subpart A What is the effective date of the rule? 5 Subpart A Who will have to report under the final rule? 7 Subpart A Which greenhouse gases (GHGs) are covered under the rule? 9 Subpart A Are mobile sources included in this rule? 10 Subpart A What is the definition of a “facility”? 11 Subpart A Will EPA collect data at the unit-, facility-, or corporate-wide level? 12 Subpart A Will EPA accept emissions information from facilities that do not have to report under the greenhouse gas reporting rule? Basically can reporters provide voluntary information to EPA following Part 98 protocols? In turn would EPA keep this info and share it with the states? 13 Subpart 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. 14 Subpart A What is the estimated cost to implement this rule? 15 Subpart A What impact does this rule have on small businesses? 16 Subpart A Did EPA engage stakeholders in the development of the rule? 18 Subpart A Is this rule a cap and trade regulation? 19 Subpart JJ How does the restriction attached to EPA's Appropriation Bill for 2010 impact Subpart JJ (Manure Management Systems) in the final greenhouse gas reporting rule that was published in the Federal Register on October 30, 2009? 20 Subpart A Does the rule apply to U.S. Territories? 21 Subpart A How did EPA develop the general threshold of 25,000 metric tons of carbon dioxide equivalent (mtCO2e) per year? 22 Subpart A How much is 25,000 metric tons of CO2 equivalent (mtCO2e)? 23 Subpart 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? 26 Subpart A Is there a simple way for facilities with stationary fuel combustion units to determine if they will be required to report? 27 Subpart A Will individual home owners be required to report under this rule? 28 Subpart A Will individual car or truck owners be required to report? 29 Subpart A Will owners of commercial buildings be required to report? 30 Subpart A Will federal, state, or local facilities have to report emissions? 31 Subpart A Are terrestrial carbon sequestration (“sinks”) and offsets projects included in this rule? 32 Subpart A Why are both downstream and upstream reporting required? 33 Subpart A Will there be double-reporting of emissions under this rule? 36 Subpart A The applicability tool says I need to report, but I don’t think the tool is right. 37 Subpart A Is applicability based on actual emissions or potential emissions? 42 Subpart A How will emissions data be verified? 43 Subpart A Will EPA provide training and guidance for reporters? 44 Subpart 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? 45 Subpart 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? 50 Subpart A When are reporters required to complete their GHG Monitoring Plan? 51 Subpart A What representative of a reporting facility is in charge of reporting? Is it the operator or facility owner? Can a third party be hired to report on behalf of the reporting facility? 53 Subpart A Does this final rule preempt states from regulating or requiring reporting of greenhouse gases (GHGs)? 54 Subpart A Will data collection be delegated to state agencies? 56 Subpart A How is this reporting rule different from the Inventory of U.S. Greenhouse Gas Emissions and Sinks report (Inventory)? 57 Subpart A Will this rule negate the need for the Inventory of U.S. Greenhouse Gas Emissions and Sinks in the future? 58 Subpart A Would this rule need to be addressed in Title V operating permits? 60 Subpart A How will the greenhouse gas reporting rule fit in or be harmonized with state and local reporting obligations for criteria pollutants, toxics, and state-specific GHG reporting requirements? 61 Subpart A How will data be efficiently shared among existing state greenhouse gas (GHG) programs and this new federal reporting program? 62 Subpart A Where can I find more detailed information on the rule? 64 Subpart C Should pilot light emissions be included in greenhouse gas emissions reported in subpart C of Part 98? 66 Subpart C Where does no. 2 diesel fuel fit into Table C-1 and C-2? 67 Subpart C Where the heat input capacity of a combustion unit is less than 250 mmBtu 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...? 68 Subpart 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... 69 Subpart C Does fuel use for comfort heating and hot water heaters need to be reported? 70 Subpart 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)? 73 Subpart 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? 74 Subpart 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? 75 Subpart 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? 76 Subpart 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? 77 Subpart 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? 80 Subpart 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? 81 Subpart 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)? 82 Subpart 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… 84 Subpart 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? 85 Subpart 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? 86 Subpart 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? 87 Subpart 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? 88 Subpart 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… 90 Subpart C Does EPA accept thermal flow meters for measuring volumetric flow rate under 98.34? 91 Subpart C Are orifice, venturi, and nozzle flow meters required to have temperature, and total pressure transmitters located on the flowmeters? 93 Subpart C What should facilities do if the calibration error for fuel flow meters that exceeds the 5.0% performance specification? 95 Subpart 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... 96 Subpart C Is there a recurring fuel flow meter calibration requirement for Tier 1 and Tier 2 units? 97 Subpart C Does the calibration exemption for fuel billing meters still apply for common pipe reporting option? 98 Subpart 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? 100 Subpart HH When does moisture content need to be corrected for in Equation HH-4? 102 Subpart HH What models are acceptable for performing the calculations in subpart HH? 103 Subpart HH How should inert wastes be accounted for in Equation HH-1? 104 Subpart HH The methods listed in section 98.344 are not applicable to my monitor, how should I calibrate? 105 Subpart HH What is the definition of a facility as it relates to landfills and landfill gas to energy (LFGTE) plants? 106 Subpart 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? 107 Subpart HH If an MSW landfill has a dedicated area which receives waste other than MSW, may this area be excluded from the rule requirements? 108 Subpart HH If an MSW landfill is later remediated as a hazardous waste landfill, does it need to comply with the rule? 109 Subpart 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? 110 Subpart 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? 111 Subpart HH Do landfills have to report the biogenic CO2 that is included in LFG emissions and the CO2 that is emitted from flares? 113 Subpart HH If all of our landfill gas gets piped offsite to another facility, what do we need to report? 114 Subpart HH Can an alternate oxidation factor, other than 10% be used in the calculations? 116 Subpart HH Do passive flares count as gas collection systems? Do the landfills with flares have to monitor for landfill gas and methane concentration? 117 Subpart 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? 119 Subpart HH Are annubars or v-cone flowmeters acceptable for compliance with the rule requirements? 120 Subpart HH Is weekly monitoring of both gas flow and methane concentration allowed? 121 Subpart 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? 122 Subpart HH Can a landfill ever stop reporting under the rule? 123 Subpart 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. 125 Subpart 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? 126 Subpart 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? 127 Subpart A If a campus is divided by a non-owned body of water (e.g., a river), does that create two distinct facilities? 129 Subpart 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? 130 Subpart 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? 131 Subpart A Some entities may choose to report all greenhouse emissions for ease of data management. If cap and trade rules on greenhouse gas emissions are promulgated, could you speculate whether entities would be able to restate their emissions? 132 Subpart 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". 133 Subpart C Can I use more than 1 Tier Method for my facility? 134 Subpart 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? 135 Subpart 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? 137 Subpart 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? 138 Subpart C Please explain what High Heat Value (HHV) testing is and how a school's EH&S personnel would know if this is occurring? 139 Subpart 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... 140 Subpart C Would the following be considered stationary or portable sources, assuming their location falls within the definition of facility? 141 Subpart HH My site has a gas collection system. Which equations do I need to use to determine my methane generation and methane emissions for subpart HH? 142 Subpart 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? 146 Subpart 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. 149 Subpart C If coal comes from the same source, how many deliveries must be analyzed to have a representative sample? 150 Subpart HH Are scales required for Municipal Solid Waste Landfills? 151 Subpart HH Must every container or vehicle be weighed coming in and going out of the landfill? 153 Subpart HH Does EPA accept thermal flow meters for measuring volumetric flow rate of LFGs? 154 Subpart HH What additional considerations are necessary when using a mass flow meter for landfill gas? 164 Subpart 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? 165 Subpart 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? 166 Subpart 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)? 167 Subpart 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." 168 Subpart MM Am I required to report under subpart MM even though my refinery does not input any crude oil? 169 Subpart 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? 170 Subpart 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? 171 Subpart 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? 172 Subpart MM Can a product-specific factor developed at one facility be used at another facility for the same type of product? 173 Subpart MM What is meant by "otherwise used on site" for the subpart MM equations using feedstock quantities? 174 Subpart 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? 175 Subpart MM What biomass activities are included in Equation MM-3, and in what cases should I subtract biomass out of equation MM-8? 176 Subpart 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)? 178 Subpart OO Are importers of HFCs required to obtain EPA approval before importing the HFCs into the U.S.? 179 Subpart 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"? 183 Subpart 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? 184 Subpart JJ Can facilities with manure management systems report under the Greenhouse Gas Reporting Program? 185 Facility Registration Can additional Agents be added to e-GGRT after Jan 30, 2011? 186 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? 187 Facility Registration Is the technical person who prepares the information for signature the "Agent" in your terminology? 188 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? 189 Facility Registration Can Agents be removed at any time? 190 Facility Registration Does an e-GGRT user have access to multiple facilities from one login if he or she is helping multiple clients? 191 Facility Registration Can an Agent appoint another Agent? 192 Facility Registration Can a contractor register for e-GGRT on behalf of a client? Or should it only be an employee? 193 Facility Registration Is there a limit to the number of Agents or Alternate Designated Representatives (ADR) for any one company? 194 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? 195 Facility Registration Must the Designated Representative (DR) and Alternate Designated Representative (ADR) appoint the same Agents? 196 Facility Registration Is it possible for an Agent to prepare annual greenhouse gas (GHG) reports as well as submit reports? 197 Facility Registration Do Agents need to be set up by the Designated Representative (DR) and Alternate Designated Representative (ADR)? 198 Facility Registration Does the person setting up have access to our facility data in e-GGRT? 199 Facility Registration What address information should be entered for suppliers reporting at the company level? 200 e-GGRT (General) What are e-GGRT system requirements? 201 e-GGRT (General) How do I turn on Javascript in my browser? 202 e-GGRT (General) Will my browser back button work when using e-GGRT? 203 e-GGRT (General) Will e-GGRT timeout due to inactivity? When does e-GGRT save? 204 User Registration I am a CAMD Business System (CBS) user. What information will be imported to e-GGRT during user registration? 205 User Registration Are the Certificates of Representation still required to be submitted if EPA has the current Designated Representative (DR) registered in CAMD Business System (Part 75 CAIR)? 206 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? 207 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? 209 User Registration Is it mandatory to link the CAMD Business System Designated Representative (DR) user account with the e-GGRT DR user account? 211 e-GGRT (General) I report emissions using ECMPS and CAMD Business System (CBS). Do I also have to submit reports using e-GGRT? 212 e-GGRT (General) Do you expect that most current CDX users will become e-GGRT users? 213 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? 214 Facility Registration Does the Designated Representative (DR) have to be a vice president? Can an environmental manager prepare reports? 215 Facility Registration Can the Alternate Designated Representative (ADR) create a user profile before a Designated Representative (DR)? 216 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. 217 Facility Registration Can a company designate more than one Alternate Designated Representative (ADR)? 218 e-GGRT (General) Does facility data have to be entered manually or can you upload the data using files? 219 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? 220 Facility Registration What is the process for changing a Designated Representative (DR) or Alternate Designated Representative (ADR)? 221 Facility Registration Like the Electronic Signature Agreement, does the Certificate of Representation need to be printed out, signed and mailed to EPA? 222 Facility Registration Does a Designated Representative (DR) need to grant or appoint a consultant access to their facility? 223 Facility Registration Can an ADR be appointed after the registration deadline? 224 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? 225 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? 226 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? 227 Facility Registration What is the difference between a Designated Representative (DR) and Alternate Designated Representative (ADR), and an Agent? 228 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? 229 e-GGRT (General) What is e-GGRT? 231 e-GGRT (General) When will EPA offer training on e-GGRT? 234 e-GGRT (General) Will e-GGRT and its XML Reporting Schema account for reporting requirements promulgated for future reporting years? 236 e-GGRT (General) During what hours will Greenhouse Gas Reporting Program (GHGRP) Help Desk support available? 237 e-GGRT (General) Do Greenhouse Gas Reporting Program (GHGRP) reporters have to submit Monitoring Plans? 238 e-GGRT (General) Where should I submit rule related questions on Part 98? 239 e-GGRT (General) How do I contact the e-GGRT Help Desk? 240 User Registration The address shown for the Electronic Signature Agreement submission looks like a street address. Can we send the Electronic Signature Agreement via regular mail, certified mail or other express mail? 241 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? 242 User Registration Will it be possible to get a copy of the e-GGRT Terms and Conditions so I can review them in advance? 243 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? 245 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? 246 User Registration If I've submitted an Electronic Signature Agreement for my CAMD Business System account, will that work for e-GGRT? 247 User Registration To what address do I send the Electronic Signature Agreement? 249 User Registration Why would EPA reject an Electronic Signature Agreement? 251 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? 252 Facility Registration Does the facility registration process need to be completed in one session like the user registration process? 253 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? 254 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)? 255 XML Reporting What is XML? 256 User Registration Do Agents have a different login and password from the Designated Representative (DR)? 257 User Registration What happens if you do not complete user registration in one session? Can you start again later? 258 User Registration Does e-GGRT allow an international address in the user profile? 259 User Registration Is there a mechanism to support multiple companies from a single email address? 260 User Registration How often do I need to change my e-GGRT password? 261 User Registration I forgot my e-GGRT user name. How do I retrieve it? 262 User Registration I lost my password. How can I get it reset? 263 User Registration How do I reset my expired password? 264 User Registration How do I unlock my e-GGRT account? 265 User Registration During user registration, I already provided a secret question and answer. Why do I also need challenge questions and answers? 267 Facility Registration If there is a change in owner or operator, does e-GGRT need to be updated within 90 days? 268 e-GGRT (General) The fifteen minute inactivity timeout in e-GGRT makes me nervous. Can I save as I go? 269 User Registration If I submit data only once a year, why does the password expire every 90 days? 270 Facility Registration Where can I find the Certificate of Representation to file? 271 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? 272 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? 273 Facility Registration Is there any way to be the Agent for all facilities at a company and fill out only one Notice of Delegation? 274 Facility Registration If you want someone to be able to prepare an electronic report but not submit, what role should they have? 275 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? 277 User Registration Can you log in to e-GGRT with your ECMPS user name and password? 278 Subpart 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? 279 Subpart 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)? 280 Subpart HH I have a landfill gas powered engine located at a landfill that must report under subpart HH. Under which subpart am I required to report combustion emissions for the engine? What about for a flare located at the landfill? 281 Subpart HH I don't see landfill gas listed in Table C-1, is a there a default high heating value or emission factor I am required to use for landfill gas when calculating emissions for subpart C? 282 Subpart JJ Can someone tell me if livestock operations need to report this year or not? I have heard from EPA personnel, Cattlemen industry people and state officials, but continue to get conflicting information. 283 Facility Registration How should the “physical street address” be reported for facilities located offshore? 284 Subpart A The definition of "owner" and "operator" under 98.6 refers to a "person." Is a person only a single individual? 285 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? 286 Subpart 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? 287 Subpart 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? 289 Subpart NN How should an LDC determine if it "delivers" more than 460,000 Mscf per year? Does this include quantities delivered to other LDCs and or large end-users? What about natural gas placed into or removed from storage? 299 Subpart A What does EPA mean by the term "sequential or simultaneous" in the definition of co-generation? 303 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? 304 e-GGRT (General) When asked in e-GGRT if a unit has a CEMS, is it specifically referring to a CO2 CEMS? 305 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? 307 Subpart 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? 308 Subpart 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? 309 Subpart D Will e-GGRT import any data from Electronic Data Reports (EDRs) or CAMD? 310 Subpart AA For subpart AA in e-GGRT, on the screen to enter CO2 emissions from makeup chemicals, why are there two boxes to check? 311 Subpart AA For subpart AA in e-GGRT, can a reporter add multiple instances of makeup chemical use? 312 Confidential Business Information (CBI) Will the data I submit in e-GGRT be treated as CBI? 313 Confidential Business Information (CBI) Can I mark my data as CBI in e-GGRT? 314 Confidential Business Information (CBI) Can I designate data as CBI in my XML file? 315 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? 317 Confidential Business Information (CBI) Are inputs to emission equations whose reporting deadline was deferred until 2013 being collected in e-GGRT? 318 XML Reporting Should reporters include calculation inputs when they upload XML files? 319 Confidential Business Information (CBI) Are reporters required to use the calculation spreadsheets provided by EPA or may they use their own spreadsheets? 320 Confidential Business Information (CBI) Should reporters using the calculation spreadsheets submit them to EPA? 321 Subpart A Does the roll-up calculator distinguish between direct emitters and suppliers? 322 Subpart C To what precision should emission values for CO2, N2O, and CH4 be reported in e-GGRT? 325 Subpart C What are biogenic emissions? 326 Subpart C What are non-biogenic CO2 emissions? 327 Subpart C If multiple subparts apply to our sources such as subparts A, C, and D, are we reporting data under all three subparts? 328 Subpart 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? 329 Subpart C Is a blend of natural gas and biogas a unique fuel type that must be added? 330 Subpart 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? 331 Subpart C Am I required to report emissions for emergency generators? 332 Subpart C Is there a limit on the number of units or fuel types listed for an aggregation of units configuration? 333 Subpart C Can you change configuration types from year to year? 334 Subpart C Is there any flexibility in deciding what configuration type I can use for a unit or group of units? 335 Subpart C Am I required to enter emissions for each fuel type? 337 Subpart C If a facility is permitted to burn fuel of a certain type, is it required to identify that fuel type in e-GGRT? 338 Subpart C For Tier 3, if I have multiple combustion sources using a single fuel type, should I enter this as an aggregation of units? 339 Subpart 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? 341 Subpart P Does subpart P require me to account for ammonia emitted as an air emission? 342 Subpart 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? 345 Subpart Y For storage tank emissions reported in Subpart Y, do you enter aggregate emissions or emissions on a tank-by-tank basis? 346 Subpart AA Is a paper making company required to report GHG emissions under Subpart AA if the only source of emissions is on -site combustion? 347 Subpart HH What is meant by manufacturer of gas collection system? 348 Subpart 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? 349 Subpart HH My facility has a gas collection system and some gas is sent off-site while the rest is consumed on-site. How should I report this in e-GGRT? 350 Subpart 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 a different waste content? 351 Subpart HH Have any of the equations been revised, or have any new equations been added since Subpart HH was finalized in 2009? 352 Subpart HH What are definitions of wet and dry gas in subpart HH? 353 Subpart 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? 354 Subpart HH Do the emission formulas differ from those used in LandGEM? 355 Subpart HH Do we have to use the quantity of waste disposed of for every year since 1960 to calculate the modeled CH4 generation rate? 356 Subpart 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? 357 Subpart HH A site has 3 cells. Cells 1 and 2 have active LFG collection systems and cell 3 does not, how do we proceed? 358 Subpart HH If we have an MSW landfill with other types of landfills (e.g., a C&D portion) at our facility, do we have to count those other non-MSW landfill portions towards our methane generation? 359 Subpart HH If the landfill accepts only incinerator ash (inert) and does not generate gas, should we consider reporting the quantities of ash? 360 Subpart HH How do you address a landfill which may have portions of lined and unlined areas at the same landfill? 361 Subpart HH I am required to provide the values of Equations HH-5 to HH-8. How are the waste depth data and surface area data used? 362 Subpart HH How do we account for highly variable landfill designs with variable depths and different cover cross-sections under Subpart HH? 363 Subpart 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? 364 Subpart OO How do I calculate addition to the "net supply"? 365 Subpart OO Why do net additions of GHGs have to be added manually when they already exist in the uploaded 366 Subpart 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)? 387 Subpart 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 ? 388 Subpart A Who must submit requests and one-time reports to EPA under Part 98? 389 Subpart 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? 390 Subpart OO How do I report imports and exports of refrigerant blends that contain both HCFCs and HFCs? 391 XML Reporting Will XML reporting instructions cover the combination of multiple units at one facility? 392 XML Reporting My XML editor is showing an error on the namespace declaration. How do I resolve it? 393 XML Reporting Will the e-GGRT XML reporting schema be made available as a single XSD file instead of a number of small files? 394 XML Reporting Are there tools available that will generate an e-GGRT XML file out of the values in our database? 395 XML Reporting Can I enter test data using the web forms, generate a report as XML and use that as a guideline for creating XML files? 396 XML Reporting What happens if I upload multiple XML files for a facility during the reporting period? Which one counts as the "official" submission? 397 XML Reporting Will e-GGRT provide an error message that points to the specific tag or data element if an upload fails the schema validation check? 398 XML Reporting I understand that an XML file must cover one and only one facility. Will e-GGRT support uploading XML files for multiple facilities at one time? 399 XML Reporting What file extensions does e-GGRT support for XML upload? 400 XML Reporting After I use the "Bulk upload of XML" option for a facility can I switch to the "Data entry via e-GGRT web-forms" option? 401 XML Reporting If I report via web forms this year can I change to XML next year? 402 XML Reporting Is there a required version attribute on the XML schema? 403 XML Reporting Is an XML file submission subject to all the same validation checks as when using the web forms? 404 XML Reporting Will reporters be able to upload an XML file and then edit the data via web forms? 405 GHG Data & Publication What are the benefits of this data? 406 GHG Data & Publication What is the scope of this data? 407 GHG Data & Publication How does EPA review the data for accuracy? 408 GHG Data & Publication Should I be worried about a local facility's GHG emissions? 409 GHG Data & Publication In what year was each source category required to begin reporting? 410 GHG Data & Publication What can a facility do to reduce its GHG emissions? 411 GHG Data & Publication How is the GHG Reporting Program data different from the U.S. GHG Inventory? 412 GHG Data & Publication What do the quantities of GHG emissions mean in everyday terms? 413 GHG Data & Publication What percentage of total U.S. GHG emissions is covered in the GHG Reporting Program? 414 GHG Data & Publication How can I determine what percentage of total GHGs come from a particular sector since the GHG Reporting Program (GHGRP) does not cover 100% of U.S. emissions? 415 GHG Data & Publication EPA's Data Publication Tool shows a reporting facility nearby, but I don't see a factory or other facility that would emit large amounts of GHGs. Is that a mistake? 417 XML Reporting Is there documentation on how e-GGRT performs rounding in calculations? 422 GHG Data & Publication Why does the reporting tool show dashes for some of the data? 423 GHG Data & Publication What is the difference between direct emitters and suppliers? 424 GHG Data & Publication Why can’t I view data from direct emitters and suppliers together? 425 GHG Data & Publication Can I obtain the raw GHG data? 426 GHG Data & Publication Will the GHG Reporting Program negate the need for the U.S GHG Inventory in the future? 430 GHG Data & Publication The factory nearby isn’t listed. Why not? 431 GHG Data & Publication Where can I get information on other emissions from these facilities (i.e., toxics, SO2, PM)? 433 GHG Data & Publication What is EPA’s plan for incorporating the GHG Reporting Program data into the U.S. GHG Inventory? 435 Subpart W Who is required to report under subpart W? 436 Subpart W What GHG emissions at oil and natural gas system facilities are covered under the rule? 438 Subpart W Do the facility definitions in this rule affect other EPA reporting requirements? 439 Subpart W How does this final rule relate to EPA’s Natural Gas STAR program? 441 Subpart W When registering my subpart W facility in e-GGRT, how should I enter the facility address? 447 Subpart W What information must be reported by subpart W (oil and natural gas systems) facilities? 448 Subpart A When must I submit my annual GHG report? 451 Subpart A What are the flow meter calibration requirements? 454 Subpart A If I use BAMM, do I still need to have a completed monitoring plan? 455 Subpart A Will EPA provide a template for the monitoring plans and review plans? 460 Subpart W Will EPA provide a tool to assist oil and natural gas system facilities in assessing their applicability under this rule? 461 Subpart W When does reporting for subpart W begin? 462 Subpart W Does the final rule amending 40 CFR Part 98 apply to both onshore and offshore petroleum and natural gas production? 463 Subpart W Are sites in south Louisiana located within the State boundaries in lakes, bays, and bayous (not in Federal waters but subject to the ebb and flow of the tide) considered to be seaward of the terrestrial border and thus offshore? 464 Subpart W Are emissions from stationary sources of fuel combustion to be quantified and reported in accordance with the methodologies specified in 40 CFR Part 98 Subpart C and not as described in BOEMRE's GOADS instructions? 465 Subpart W Does an offshore facility reported in the GOADS 2008 that did not exceed the combined emissions threshold for subparts C and W sources of more than 25,000 metric tons CO2e have to report GHG emissions for RY2011 if emissions exceed this threshold? 466 Subpart W Would an offshore facility that emits 20,000 metric tons CO2e from from subpart W sources based on GOADS calculation methodology and 10,000 metric tons CO2e from stationary combustion sources be required to report GHG emissions during 2011? 467 Subpart W Can we use 2011 BOEMRE data, rather than the previously available data from 2008, for reporting RY2011 emissions from an offshore petroleum and natural gas production facility? 468 Subpart W If an offshore oil and gas production platform or facility is farther out in the ocean than the limit of state waters, as defined by the Submerged Lands Act, does that facility have to report emissions data to EPA for Subpart C? 470 Subpart W Is it necessary to monitor of "hours operated" for "natural gas, diesel, and dual-fired turbines" as required in Subpart W via GOADS. 471 Subpart W How are new offshore facilities that are subject to GOADS supposed to report in 2012? Since published GOADS data are not available, should they be using the GOADS methodologies to calculate the emissions? 479 Subpart W In 98.233(j)(1) is the average thoroughput of oil an annual or daily average? 480 Subpart W How should the daily oil throughput for onshore production storage tanks be determined to compare with the threshold of 10 barrels a day in 98.233.j(1)? 487 Subpart W Under onshore natural gas processing where are vent emissions reported? 502 Subpart W For transmission tank venting sent to the flare, the reporter is referred to the emissions source for flare stack emissions, but guidance is only provided for upstream production and gas processing in this section. 503 Subpart W In the natural gas transmission segment, do only condensate tanks at the facilities require leak checks (not other tanks at the facility or not at the facility)? 517 Subpart W Do I have to calculate emissions from operational LNG storage tank venting at LNG storage facilities or LNG import or export terminals? 524 Subpart W For a liquefied natural gas import facility, do boil-off venting emissions from an LNG storage tank need to be reported? 542 Subpart W In 98.236(c)(3)(i) is the "total throughput off the acid gas removal unit" to be reported is the volume of gas exiting the AGR unit (outlet gas), not the volume of gas vented to atmosphere? 543 Subpart W In 98.233.d.8 are we allowed to assume that volume fraction of CO2 content in natural gas out of the AGR unit is zero? 544 Subpart W Do acid gas removal units which are used only to sweeten a liquid stream meet the definition of acid gas removal units? 545 Subpart W If all of the emissions from an AGR unit are recovered and transferred outside of the facility, does the facility still need to calculate emissions pursuant to Section 98.233(d)(11) and then "reduce" the emission to zero? 546 Subpart W Can facilities performing on-site acid gas injection estimate their emissions downward according to the provisions in 98.233(d)(11) for AGR unit emissions recovered and transferred outside the facility? 548 Subpart W For AGR vents is the use of a meter to measure flow rates required? 553 Subpart W For which units of measure are we required to calculate and report emissions using Equation W-3? May we use a flow meter to calculate annual emission CO2? 557 Subpart W For blowdown vent stacks does the 98.233.i reference to containers less than 50 cubic feet total physical volume refer to a gas volume or a physical container volume? 558 Subpart W ay average blowdown volumes be used for industry segments (processing, transmission, and LNG imports-exports) where reporting of this emission source is required? 576 Subpart W In 98.233(e), is the daily thoroughput for glycol dehydrators based on annual average daily thoroughput? 578 Subpart W Do dehydrators which are used to dry a liquid stream meet the definition of dehydrator? 579 Subpart W The emission methods for dehydrator vents with daily throughputs less than 0.4 MMscfd in the preamble (use flow rate of wet NG and EF) contradict the requirements in the rule (use dehydrator count and EF). 580 Subpart W For onshore petroleum and natural gas facility dehydrator vents at glycol dehydrators with throughputs less than 0.4 million standard cubic feet per day, can GRI-GLYCalc be used instead of Method 2 in §98.233(e)(2)? 581 Subpart W 586 Subpart W For Equation W-21, Flare Emissions, Do you use "5" for Rj (number of carbon atoms) for hydrocarbons with more than 5 carbons? 588 Subpart W Are flare emissions included in the 98.2(a)(3)(iii) combined emissions from all stationary fuel combustion sources when determining applicability for Subpart W per §98.231(a)? 593 Subpart W Emissions from flares are specifically excluded under 98.232(e) but methods for these emissions are provided in 98.233. Can you clarify which section of the rule is the correct guiding action? 595 Subpart W Does a simple open pipe with no flare tip count as a flare under 98.233 (n ) in Subpart W? 597 Subpart W Under Subpart W, under both the onshore production and gas processing source categories, are we required to report emissions from all flares at the gas processing facility or on or associated with a well pad, including emergency flares? 613 Subpart W Is there any way we can get unlocked subpart W screening spreadsheets from the applicability tool? 614 Subpart W The applicability tool for Onshore Petroleum and Natural Gas has an operating factor for associated gas venting from produced hydrocarbons. How does this operating factor correlate with the barrels of crude oil produced? 615 Subpart W For a 2011 report with the "Liquefied Natural Gas Storage" option selected, how does the "calculation utility" excel spreadsheet account for "Population Count and Emission Factors" when providing the user with a final CO2e number? 616 Subpart W Where can I find the screening tool for onshore petroleum and natural gas production? 617 Subpart W Does EPA offer guidance on how to estimate a worst case scenario for GHG emissions from transmission storage tanks for purpose of determining applicability? 618 Subpart W In the applicability tool calculation spreadsheets, why do transmission compression and underground storage differ in the units used for vented emission from reciprocating compressor rod-packing venting? 619 Subpart W For a facility that operates stationary combustion equipment and only became subject to 40 CFR part 98 due to subpart W related emissions, should the monitoring plan have been put in place a by January 1 or April 1, 2011? 622 Subpart W Do the emissions from external combustion sources with rated heat capacity equal to or less than 5 mmBtu per hour need to be included in the 25,000 metric ton threshold determination? 626 Subpart AA In 40 CFR Part 98, Subpart AA (Pulp and Paper Manufacturing) EPA requires reporting of annual production of pulp or paper products produced under 98.276(k). Is EPA asking for the virgin pulp production or the quantity of pulp sold off-site? 629 Subpart DD To what extent does a subpart DD facility include potential subpart C sources located in the same physical structure? Would it include sources using natural gas for comfort heating in warehouses and office complexes on the electric power system? 637 Subpart A What should I do if my facility ceased operations? 638 Subpart W For an onshore natural gas production facility for which I reported stationary combustion emissions under subpart C for RY2010 and for which I will be reporting under subpart W for RY2011, do I need to make any changes to my RY2010 report? 639 Subpart W For an onshore natural gas production facility that was subject to subpart C for RY2010 and will be subject to subpart W for RY2011, do I report my basin emissions under the same facility registration I used for my RY2010 report? 641 Subpart DD Our utility owns power plants that are subject to Part 98 subpart D and 100-150 substations. Do we report SF6 and PFC emissions under subpart DD as a separate facility or together? 642 Subpart DD Our facility owns SF6- or PFC-containing equipment, but we are not an electric power transmission or distribution entity as defined in 98.308. Are we required to report emissions under subpart DD? 643 Subpart DD Should we report the SF6 and PFC emissions from a substation located at a power plant subject to subpart D under subpart DD? If so, would the SF6 and PFC emissions be reported under the same report as the subpart D emissions or as a separate report? 644 Subpart DD At what point during the year does the reporting threshold apply for subpart DD? 645 Subpart DD Does equipment that has been sent out for reconditioning (not on-site) count toward the subpart DD threshold? 646 Subpart DD Our facility has SF6 gas cylinders. Do we include those in reporting under subpart DD? 649 Subpart DD Hermetic seals should not leak. Do we include the quantity of SF6 contained in hermetically sealed equipment when determining applicability under subpart DD? 651 Subpart W Would a monitoring plan that results in 10% of stations being monitored in each of years 1 and 2, 40% in year 3, 20% in year 4 and 20% in year five, be consistent with the rule language of “approximately equal across all years in the cycle.” 652 Subpart W Are the results of Equations W-11A and W-11B in standard conditions or actual conditions? 653 Subpart AA In e-GGRT, the "Subpart AA Summary Information For This Facility" requires reporting of "Annual Production of Pulp Products (metric tons)." Should this value be in terms of air dried metric tons of bleached or unbleached pulp? 655 Subpart W Are geologic provinces 160 and 160A one basin or separate basins for the purposes of defining a facility for onshore petroleum and natural gas production? 656 Subpart Y My fluidized catalytic cracking unit (FCCU) is monitored by a CEMs. How should those emissions be reported? 665 Facility Registration How does EPA define “identification of the facility or supplier” in 98.4(i )(1) with regard to a facility’s certificate of representation? 666 Subpart UU How does EPA define “identification of the facility or supplier” in 98.4( i )(1) with regard to a facility’s certificate of representation? 667 Subpart W How do I determine applicability for Subpart W facilities with stationary combustion sources? 669 Subpart UU How should the “physical street address” be reported for Subpart UU facilities that don’t have a physical street address? 671 Subpart TT If an industrial landfill did not receive waste in the reporting year but is expected to receive waste in future years, should the landfill be classified as "open" or "closed" for GHG reporting purposes? 672 Subpart TT How many samples or test results are required if a facility is using a 60-day anaerobic biodegradation test to determine if their industrial waste landfill is exempt from reporting GHG emissions under §98.460(c)(2)(xiii)? 673 Subpart TT Must I report waste streams that are defined as inert and, if I do, what DOC value must I use for this waste stream? 674 Subpart TT My facility generates construction and demolition (C&D) waste, among other waste streams. Do I need to report my C&D waste? 675 Subpart TT Can you report multiple industrial waste landfills at one facility in e-GGRT? 676 Subpart TT For evaluating eligibility for the inert waste reporting exemption, can a 60-day anaerobic biodegradation test be used to determine the DOC of a waste stream similar to one managed historically but not received during the first reporting year? 677 Subpart TT For a facility required to report, what test may be used to determine volatile solids concentration of a waste stream that is similar to an historically managed waste stream that was not received during the first reporting year? 683 GHG Data & Publication What do I do if I see an error in the data shown for a facility? 686 Subpart FF What is the definition of facility as it relates to mines and coal mine methane energy plants? 687 Subpart FF If all of our coal mine methane gets piped offsite to another facility, what do we need to report? 688 Subpart FF Does the 25,000 ton CO2e per year limit (threshold) apply to the compressors individually, or in aggregate (all such compressors or equipment at the mine)? 689 Subpart FF Is a “methane buster", aka “methane exhauster", (compressor that runs on some of the methane from the borehole) without a flare required to be reported under Subpart FF? 690 Subpart FF Where do I report CO2 emissions from compressors used at the mine that run on methane? 691 Subpart FF What is the definition of portable equipment? 692 Subpart FF What is the GWP for methane that is used for this rule? 693 Subpart FF In equation FF-1, is the value supposed to be standard cubic feet per minute, or actual cubic feet per minute? 694 Subpart FF Are there any provisions for extended inaccessibility of remote sites (e.g., degasification or gob vent boreholes) due to inclement weather (e.g., deep snow) that may restrict site access for weeks or even months? 695 Subpart P What is a hydrogen production process unit? 696 Subpart P Should combustion emissions from a steam methane reforming (SMR) furnace be reported under subpart C or subpart P? Is the answer different if refinery fuel gas is used to fire the SMR furnace? 697 Subpart P How should fuels and feedstocks be reported for hydrogen production process units? 698 Subpart P How do I determine the quantity of hydrogen produced? 699 Subpart P How do I determine the quantity of CO2 emissions produced for hydrogen production process units that use multiple fuels and feedstocks? 700 Subpart Y Should material vented to a flare on a daily or otherwise frequent basis due to the cyclic operation of certain units be considered a startup, shutdown, or malfunction (SSM) event in Equation Y-3? 701 Subpart Y In Equation Y-3, startup, shutdown, or malfunction (SSM) events exceeding 500,000 standard cubic feet per day (scf per day) must be reported. What time period and flare gas volume should be used to assess if this threshold was exceeded? 702 Subpart Y For a startup, shutdown, or malfunction (SSM) event lasting several days, should the flare flow term in Equation Y-3 include the cumulative flow for the entire event or only for the day(s) during which the 500,000 scf per day threshold was exceeded? 703 Subpart A What must I do if EPA notifies me of a potential substantive error in an annual GHG report? 708 Subpart MM, Subpart LL If I am a refinery or coal-to-liquid facility required to report under subpart MM or LL and also report direct emissions under another Part 98 subpart, do I need one e-GGRT registered entity or two? Which subparts do I include in each report? 709 Subpart MM, Subpart LL If my corporation owns refineries or coal-to-liquids facilities subject to subpart MM or subpart LL and also imports and/or exports sufficient petroleum products or coal-based liquid products to be required to report imports and/or exports under subpart MM or subpart LL, can I submit one e-GGRT report or do I need to submit multiple reports? 718 Subpart W Will EPA approve the use of BAMM relating to the measurement of isolation valves at compressors in the shut down depressurized mode that are to be measured at least once every three calendar years? 719 Subpart FF How do we determine if our underground coal mine is required to report its emissions to EPA? 720 GHG Data and Publication How does EPA group the source categories that report GHG data into sectors for purposes of publication? 721 GHG Data and Publication For certain sectors, why is the GHG data not necessarily comparable between 2010 and subsequent reporting years? 724 GHG Data and Publication Why are emissions from petroleum and natural gas systems – onshore production represented by geographic areas instead of individual point sources? 725 GHG Data and Publication How is an R&D project defined for geologic sequestration of carbon dioxide (Subpart RR)? 726 GHG Data and Publication What are the reporting requirements for geologic sequestration research and development (R&D) projects under the Greenhouse Gas Reporting Program? 727 GHG Data and Publication Where do I download GHGRP data? 728 GHG Data and Publication Does EPA archive past versions of the GHGRP data set? 730 Subpart W What emissions are reported for petroleum and natural gas systems facilities? 731 Subpart W What segments of the petroleum and natural gas systems sector are covered by the GHGRP? 732 Subpart W Does the GHGRP include all U.S. emissions from petroleum and natural gas systems? 733 Subpart W What percentage of emissions from petroleum and natural gas systems are reported under the GHGRP? 734 Subpart W How does EPA define a “facility” for petroleum and natural gas systems? 735 Subpart W Why did EPA require that facilities conducting onshore petroleum and natural gas production report by basin? 736 Subpart W Did all petroleum and natural gas system facilities subject to the Greenhouse Gas Reporting Program report to EPA? 737 Subpart W What is the quality of the petroleum and natural gas systems data? 738 Subpart W How did the use of Best Available Monitoring Methods (BAMM) affect emissions? 739 Subpart W How does the petroleum and natural gas systems data reported under the GHGRP compare to the data reported to the California Air Resources Board (CARB)? 741 GHG Data and Publication Why did some facilities that have emissions below 25,000 metric tons CO2e submit a GHG report? 742 GHG Data and Publication How can I generate a list of facilities affiliated with a given parent company? What should I know before I use the parent company data? 743 Subpart HH My site has a gas collection system that did not operate at all during the reporting year, but did operate in prior reporting years. Which equations should I use to calculate my methane generation and GHG emissions for the current reporting year? 744 Subpart HH Can a site receiving inert or construction and demolition (C&D) wastes in addition to bulk MSW use the “material specific modeling approach” for the inert or C&D wastes and then use the bulk waste DOC value of 0.20 for the MSW? 745 Subpart HH A portion of my landfill is covered with a geomembrane, but e-GGRT does not include that as a choice when asking about the type of cover material used. What should I select? Are there definitions for the types of cover materials? 746 Subpart HH What is the best way to determine the surface area of my landfill if there is significant surface topography? 747 Subpart TT What is the best way to determine the surface area of my landfill if there is significant surface topography? 748 Subpart HH What is meant by landfill capacity? 749 Subpart W What are the notification requirements when an Onshore Petroleum and Natural Gas Production facility, reporting under Subpart W, sells wells and associated equipment in a basin? 750 Subpart W Will EPA approve the use of Subpart W Best Available Monitoring Methods (BAMM) relating to the measurement of compressor vents routed to flare? 751 Subpart W Will EPA approve the use of Subpart W Best Available Monitoring Methods (BAMM) relating to the measurement of individual compressor vents routed a common manifold? 752 GHG Data & Publication I recently re-submitted a GHG report. When will EPA update the publication materials to show my revised data? 753 Subpart C How do I use Equation C-2b to calculate the annual average high heating value (HHV) of my fuel if the rule requires sampling less frequently than monthly? 754 Subpart W When are Best Available Monitoring Method (BAMM) requests due for Subpart W reporters? 755 Subpart HH How are data reported in the previous reporting year carried over into the current year reports? 756 Subpart FF Do I need to calculate the moisture content of the methane emitted from my coal mine? 757 General I registered my facility in eGGRT, but my facility has never been subject to Part 98. What should I do? I’d like to stop getting email communications from EPA about the GHG Reporting Program. 758 Subpart A My facility does not have a physical street address. How do I report my latitude and longitude to EPA? 759 Subpart A My facility does not have a physical street address thus, a latitude and longitude is reported as the address on the COR. If the facility's operations have moved do I need to update the facility’s latitude and longitude on the COR? 760 Subpart D Is an electric generating unit (EGU) that has a new unit exemption from the Acid Rain Program (40 CFR 72.7) subject to Subpart D? If not, is it subject to subpart C? 761 Subpart D How do I report emissions from a new electric generating unit (EGU) that started operations during the reporting year, but did not have the CEMS certified by December 31? 762 Subpart N Are subpart N reporters able to use a default assumption of 1.0 in Equation N-1 for determining calcination fraction of carbonate-based raw materials charged to glass melting furnaces? How does this impact monitoring? 763 Subpart DD Should the beginning of year nameplate capacity in the current reporting year equal the prior year’s calculated end of year nameplate capacity? 764 GHG Data & Publication Why is the GHG quantity reported by Suppliers of Petroleum Products (Subpart MM) not provided for 2010 or 2011? GHG Data & Publication GHG Data & Publication I have a unit that operates continuously and am not able to complete a calibration of the flow meter without disrupting normal operations. Can I postpone the calibration until the next scheduled maintenance? What are the optional delayed reporting requirements for wildcat wells and delineation wells? How do I reference the Greenhouse Gas Reporting Program in a manuscript? Do I need to update my Subpart W deferred data submission(s) if I resubmit an annual report for RY2011, 2012 or 2013? Per FAQ 815, I need to update my Subpart W deferred data submission(s) after I have resubmitted an annual report for RY2011, 2012 or 2013. How do I do it? Do enclosed flare systems have to report emissions under 40 CFR part 98 subpart C? How did reporting of emissions for Fluorinated Gas Producers change in 2015? How are aggregate CO2 totals associated with supplied products determined for petroleum product producers and natural gas liquids fractionators? What data were reported by petroleum and natural gas systems facilities for the first time as part of the Reporting Year 2014 submittal? How did EPA determine a facility’s emissions by fuel type? How should a gathering and boosting facility that previously reporting under Subpart C report in RY2016? My gathering pipeline has a GOR less than 300 scf/STB, so it is not part of the Onshore Petroleum and Natural Gas Gathering and Boosting segment. Does the exemption only apply to the pipeline itself, or is all equipment along the pipeline excluded as well? How do I determine the gas to oil ratio (GOR) for my oil well operations to decide whether I need to report emissions from completions and workovers of oil wells with hydraulic fracturing? Can facilities covered by the Subpart W Onshore Petroleum and Natural Gas Gathering and Boosting industry segment use Subpart C emission factors for calculating combustion emissions? What are the Subpart W BAMM provisions for reporting year 2016? Under §98.233(e)(1), emissions must be calculated from dehydrator vents with throughput greater than or equal to 0.4 million standard cubic feet per day. Is this throughput specific to vent throughput or dehydrator throughput? 765 Q765 Subpart W How do I determine “actual” temperature and pressure in emission calculations? 766 Q766 Subpart W What are the requirements for determining the GHG mole fraction for emission calculations when a continuous gas composition analyzer is not available? 767 Q767 Subpart W What are the requirements for determining the volume of gas sent to a flare? 768 Q768 Subpart W What types of instruments are permissible for use in detecting equipment leaks and through valve leakage in Subpart W? 769 Q769 Subpart W If a facility does not have a gas-to-oil ratio (GOR) value for a well, what options are available to facilities in order to determine the GOR for associated gas venting and flaring? 770 Q770 Subpart FF Do I have to keep reporting for an underground coal mine that liberates more than 36.5 million cubic feet of methane per year making it subject to subpart FF but whose total annual emissions from all sources are less than 25,000 metric tons CO2e? 771 Q771 What is the difference between the Greenhouse Gas (GHG) emission data reported by electric generating units (EGUs) to EPA’s Clean Air Markets Division (CAMD) under Part 75 and to EPA’s Greenhouse Gas Reporting Program under Subpart D of Part 98? 772 Q772 What are the differences in the universe of electricity generating units (EGUs) that report Greenhouse Gas (GHG) emissions to EPA’s Clean Air Markets Division (CAMD) under Part 75 and to EPA’s Greenhouse Gas Reporting Program under Part 98? 774 Q774 Subpart MM I'm trying to submit data for subpart MM for RY2013, where are tabs 1 (Measurement Method) and 6 (Crude Oil)? 775 Q775 Subpart MM The Crude Oil tab is gone on the RY2013 reporting form, where do I report the quantity of Crude Oil entering my refinery? 776 Q776 Subpart MM The Global Warming Potentials (GWPs) for greenhouse gases in the rule have changed. Does this impact my reporting for Subpart MM? 777 Q777 Subpart MM 778 Q778 Subpart HH Why did the global warming potential (GWP) for methane change this year? Will more MSW landfill facilities be required to report now? 779 Q779 Subpart HH How do I calculate the collection efficiency for a site where extraction wells were installed in only one third of the landfill but had additional wells installed to cover the entire landfill during the second half of the year? 780 Q780 Subpart HH Different daily cover materials can be used throughout the year on the working face of a landfill. The surface area can change as additional lifts of waste are added. At what point in the year should the surface area measurements be taken? 781 Q781 Subpart HH Is there an operational hour threshold when calculating fDest for startup operations of a destruction device? 782 Q782 Subpart HH What does the majority of the landfill refer to when determining which oxidation fraction to use in Table HH-4? 783 Q783 Subpart HH My facility has more than one landfill gas collection system and the operating hours for the systems are not the same. How should we report the annual operating hours for multiple landfill gas collection systems? 784 Q784 Subpart HH For a facility with two landfills with separate gas collection systems and destruction devices, can I calculate a collection efficiency (CE) for each landfill gas collection and control system, or does the CE have to represent the entire facility? 785 Q785 Subpart HH When can I use a collection efficiency (CE) of 75% from Table HH-3? 786 Q786 Subpart HH How should I report substitute data for the annual volume of landfill gas collected and/or the annual average methane concentration of the landfill gas collected? 787 Q787 Subpart II What equations do I use to calculate emissions for processes without recovery? 788 Q788 Subpart II What equations do I use to calculate emissions for processes with recovery? 789 Q789 Subpart II How do I get back to the “Add/Edit an Anaerobic Process” screen in the webform? 790 Q790 Subpart II I can’t submit my report, how do I determine what errors are preventing my submission? 791 Q791 Subpart II What is the difference between an Anaerobic Sludge Digester and an Anaerobic Reactor? 792 Q792 Subpart II Should I submit my calculations and calculation spreadsheets to EPA? 793 Q793 Subpart II What if my process only has recovery for part of the year? 794 Q794 Subpart II If I have multiple anaerobic lagoons, do I need to report for each one? 798 Q798 GHG Data & Publication When is a facility eligible to stop reporting? 799 Q799 GHG Data & Publication What are the global warming potentials (GWPs) used in publication of GHGRP data? 800 Q800 GHG Data & Publication What factors could have influenced greenhouse gas trends? 801 Q801 GHG Data & Publication Which facilities are located on tribal land? 802 Q802 GHG Data & Publication Which facilities are given an orange facility symbol in FLIGHT? 804 Q804 GHG Data & Publication What factors could have influenced greenhouse gas trends in the chemical pulp and paper production industry? 805 Q805 GHG Data & Publication What factors could have influenced trends in GHGs associated with natural gas and natural gas liquids supply? 806 Q806 GHG Data & Publication Why do trend lines in FLIGHT not include data reported in 2010? 807 Q807 Subpart A My facility is not required to report for RY 2014. Am I still required to report inputs to emissions equations that were deferred from reporting until 2015 for previous reporting years? 808 Q808 Subpart A My facility has had ownership changes occur in the past few years. Who is responsible for reporting inputs to emissions equations that were deferred from reporting until 2015 for previous years? 809 Q809 Subpart W What are the current BAMM provisions for reporting year 2015? 810 Q810 GHG Data & Publication How do I turn off compatibility mode in Internet Explorer version 9 or later? 811 Q811 Subpart A A GHGRP facility is being sold by my company to another company. My company does not want to be responsible for monitoring GHG data or submitting annual reports after the sale. What should we do? 812 Q812 Subpart FF My facility is using MSHA data to report ventilation air methane emissions. I am having difficulty interpreting the MSHA report. Is any guidance available on how to correctly interpret MSHA data to report VAM to the GHGRP? 813 Q813 Subpart W 814 Q814 GHG Data & Publication 815 Q815 Subpart W 816 Q816 Subpart W 817 Q817 Subpart C 818 Q818 GHG Data & Publication 819 Q819 GHG Data & Publication 820 Q820 Subpart W 821 Q821 GHG Data & Publication 822 Q822 Subpart W 823 Q823 Subpart A Who is eligible to discontinue complying with the GHGRP using the “offramp”? 824 Q824 Subpart A What must I do if I discover a substantive error in an annual GHG report? 825 Q825 Subpart W How do I determine the gas to oil ratio (GOR) for my gathering pipelines? 826 Q826 Subpart W 827 Q827 Subpart W 828 Q828 Subpart W 829 Q829 Subpart W
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