Industrial Wastewater Treatment Sources

Greenhouse Gas Reporting Program                                               Aaancy


Under the Greenhouse Gas Reporting Program (GHGRP), owners or operators of certain
facilities that use anaerobic processes to treat industrial wastewater and wastewater treatment
sludge must report emissions from processes present at the facility if aggregate annual
greenhouse gas (GHG) emissions are equal to or more than 25,000 metric tons of carbon
dioxide equivalent (CO^). Owners or operators are required to collect wastewater
characterization and biogas emissions data, calculate GHG emissions, and follow the specified
procedures for quality assurance, missing data, recordkeeping, and reporting.

How Is This Source Category Defined?

The industrial wastewater treatment source category consists of anaerobic processes used to treat
industrial wastewater and wastewater treatment sludge at facilities that perform the following operations:
    •   Pulp and paper manufacturing;
    •   Food processing (fruits, vegetables, meat, and poultry processing only);
    •   Ethanol production; and
    •   Petroleum refining.

The category does not include anaerobic processes used to treat wastewater and wastewater treatment
sludge at other industrial facilities. It also does not include emissions from:

    •   Municipal wastewater treatment plants;
    •   Separate treatment of sanitary wastewater at industrial facilities;
    •   Oil/water separators; or
    •   Aerobic and anoxic treatment of industrial wastewater.

Anaerobic processes use microorganisms to degrade organic matter in wastewater, wastewater treatment
sludge, or other material in the absence of oxygen, resulting in the generation of carbon dioxide and
methane (CH4). The anaerobic treatment processes included in this category are:
    •   Anaerobic wastewater treatment reactors;
    •   Anaerobic wastewater treatment lagoons; and
    •   Anaerobic sludge digesters.

What GHGs Must Be Reported?

Facilities that are subject to the rule must report:
    •   Annual mass of CH4 generated by each anaerobic wastewater treatment reactor and each
       anaerobic wastewater treatment lagoon;
    •   Annual mass of CFLt recovered from each anaerobic treatment process (reactor, lagoon, and
       sludge digester)
    •   Annual mass of CFLj emitted from each anaerobic treatment process (reactor, lagoon, and sludge
       digester.
Environmental Protection
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In addition, each facility must report GHG emissions for any other source categories for which calculation
methods are provided in other subparts of the rule, as applicable.

How Must GHG Emissions Be Calculated?

The mass of CH4generated, recovered, and emitted must be calculated using the following inputs:
    •   Measured wastewater flow into each anaerobic wastewater treatment process;
    •   Measured concentration of chemical oxygen demand (COD) or biochemical oxygen demand
       (BOD5) in wastewater flow into each anaerobic wastewater treatment process;
    •   Measured flow of biogas recovered from each anaerobic process;
    •   Measured CH4 concentration of the biogas recovered from each anaerobic process;
    •   Appropriate values for methane producing potential, methane conversion factor, biogas collection
       efficiency, biogas leakage, and biogas destruction device destruction efficiency; and
    •   Operating time per year.

For anaerobic wastewater treatment processes, each week that the process is operating, facilities must
collect 24-hour composite samples of the wastewater flowing into the process and analyze it for COD or
BOD5 concentration.  They must measure the flow rate of wastewater for the same 24-hour period for
which they collect samples. Using these measurements and appropriate values for methane producing
potential and methane conversion factor, facilities must then calculate the CFLt generated by each
anaerobic wastewater treatment process during the week. Weekly values must be summed to calculate the
annual mass of CFLj generated.

For all anaerobic treatment processes (reactors, lagoons, and sludge digesters) from  which some biogas is
recovered, facilities must calculate the annual quantity of CFI4 recovered based on continuous monitoring
of the biogas flow rate; continuous or weekly monitoring of CFI4 concentration, temperature, pressure, and
moisture content; and appropriate biogas collection efficiencies provided in the regulation. They must
also calculate the annual quantity of CFI4 emitted, based on appropriate values for biogas leakage and
biogas destruction device destruction efficiency.  CFI4  destruction efficiency must be based on either the
manufacturer's specified efficiency or 99 percent, whichever is  less.

When Must Reporting Begin?

Industrial wastewater facilities subject to subpart II must begin monitoring GHG emissions on January  1,
2011 in accordance with the methods specified in the subpart. The first reports are due to EPA on March
31, 2012 and annually thereafter.

What Information Must Be Reported?

In addition to the information required by the General  Provisions at 40 CFR 98.3(c), each facility must
report the following:

    •   A description or diagram of the industrial wastewater treatment system, identifying the processes
       used to treat industrial wastewater and industrial wastewater treatment sludge. The anaerobic
       processes must be identified as:

           o   Anaerobic reactor;
           o   Anaerobic deep lagoon (depth more than 2 meters);
           o   Anaerobic shallow lagoon (depth less  than 2 meters); or
           o   Anaerobic sludge digester.
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    •  For each anaerobic wastewater treatment process (reactor or lagoon), facilities must report:
           o   Weekly average COD or BOD5 concentration of wastewater entering each anaerobic
               wastewater treatment process, for each week the anaerobic process was operated.
           o   Volume of wastewater entering each anaerobic wastewater treatment process for each
               week the  anaerobic process was operated.
           o   Maximum CFLt production potential (B0) used to calculate CFLt generation.
           o   Methane  conversion factor (MCF) used to calculate CFi4 generation.
           o   Annual mass of CFi4 generated by each anaerobic wastewater treatment process.

    •  For each anaerobic wastewater treatment process (reactor or lagoon( and anaerobic sludge
       digester, facilities must report:
           o   Annual quantity of CH4 recovered from the anaerobic treatment processes.
           o   Cumulative volumetric biogas flow for each week that biogas is collected for destruction.
           o   Weekly average CFi4 concentration for each week that biogas is collected for destruction.
           o   Weekly average temperature for each week at which flow is measured for biogas
               collected for destruction, or statement that temperature is incorporated into monitoring
               equipment internal calculations.
           o   Whether  flow was measured on a wet or dry basis, whether CFi4 concentration was
               measured on a wet or dry basis, and if required, weekly average moisture content for each
               week at which flow is measured for biogas collected for destruction, or statement that
               moisture  content is incorporated into monitoring equipment internal calculations.
           o   Weekly average pressure for each week that flow is measured for biogas collected for
               destruction, or statement that pressure is incorporated into monitoring equipment internal
               calculations.
           o   CFi4 collection efficiency used to calculate biogas recovery.
           o   Whether  destruction occurs at the facility or off-site. If destruction occurs at the facility,
               facilities  must also report whether a back-up destruction device is present, the annual
               operating hours for the primary destruction device, the annual operating hours for the
               back-up destruction device (if present), the destruction efficiency for the primary
               destruction device, and the destruction efficiency for the backup destruction device  (if
               present).
           o   Annual quantity of CH4 emitted from the process.

    •  The total mass of CFI4 emitted from all anaerobic processes, including anaerobic processes from
       which biogas is not recovered and anaerobic processes from which some biogas is recovered.

For More Information

This document is provided solely for informational purposes. It does not provide legal advice, have
legally binding effect, or expressly or implicitly create, expand, or limit any legal rights, obligations,
responsibilities, expectations, or benefits in regard to  any person. The series of information sheets is
intended to assist reporting facilities/owners in understanding key provisions of the final rule.

Visit EPA's Web site (www.epa.gov/climatechange/emissions/ghgrulemaking.html) for more
information, including all rulemakings related to the Greenhouse Gas Reporting Program, additional
information sheets on specific industries, the schedule for training sessions, and other documents and
tools. For questions that cannot be answered through the Web site, please contact us at: ghgmrr@epa.gov.
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