Industrial Wastewater Treatment Sources oEPA
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 (COie). Owners and 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 per
the requirements of 40 CFR Part 98 Subpart II - Industrial Wastewater Treatment.
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 reactors;
•	Anaerobic lagoons;
•	Anaerobic sludge digesters; and
•	Biogas destruction devices.
What Greenhouse Gases Must Be Reported?
Facilities that are subject to the rule must report:
•	Annual mass of CH4 generated, CH4 emitted, and CFU recovered from the treatment of industrial
wastewater at each anaerobic lagoon and anaerobic reactor.
•	Annual mass of CFU emitted and CFU recovered from each anaerobic sludge digester.
•	Annual mass of CFU emitted and CFU destroyed by each biogas collection and biogas destruction
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.
Subpart II, Greenhouse Gas Reporting Program
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How Must Greenhouse Gas Emissions Be Calculated?
The mass of CH4 generated, recovered, and emitted must be calculated using the following inputs:
•	Measured wastewater flow into each anaerobic process;
•	Measured concentration of chemical oxygen demand (COD) or biochemical oxygen demand
(BOD5) in wastewater flow into each anaerobic 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, and biogas destruction device destruction efficiency;
•	Calculated value of CH4 leakage at the anaerobic process; and
•	Operating time of the biogas recovery system and biogas destruction devices 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
BOD, concentration. Facilities must also 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 CFU generated by each
anaerobic wastewater treatment process during the week. Weekly values must be summed to calculate the
annual mass of CFU generated.
For all anaerobic treatment processes (reactors, lagoons, and sludge digesters) from which some biogas is
recovered, facilities must calculate the annual quantity of CFU recovered based on continuous monitoring
of the biogas flow rate; continuous or weekly monitoring of CFU concentration, temperature, pressure,
and moisture content; and appropriate biogas collection efficiencies as specified in the rule. They must
also calculate the annual quantity of CFU emitted, based on calculated values for biogas leakage and
values for biogas destruction device destruction efficiency. CFU destruction efficiency must be based on
either the manufacturer's specified efficiency or 99 percent, whichever is less.
A checklist for data that must be monitored is available at: https://www.cpa.gov/ghgrcporting/monitoring-
checklist-subpart-ii-industrial-wastewater-treatment.
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 information:
•	Identification of the anaerobic processes used in the industrial wastewater treatment system, a
unique identifier for each process, an indication of the average depth in meters of each anaerobic
lagoon, and an indication as to whether biogas generated by each process is recovered. Each
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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•	A description or diagram of the industrial wastewater treatment system, identifying the processes
used; indicating how the processes are related to each other and providing the unique identifier
for each process.
•	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 CH4 production potential (Bo) used to calculate CH4 generation,
o Methane conversion factor (MCF) used to calculate CH4 generation,
o Annual mass of CH4 generated by each anaerobic wastewater treatment process,
o If the facility performs an ethanol production processing operation, an indication if the
facility uses a wet or dry milling process.
•	For each anaerobic reactor, anaerobic lagoon, and anaerobic sludge digester from which some
biogas is recovered, facilities must report:
o Annual quantity of CFU recovered from the anaerobic treatment processes,
o Total weekly volumetric biogas flow for each week that biogas is collected for destruction,
o Weekly average CFU 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 CFU 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 CH4 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 CH4 emitted from all anaerobic processes, including anaerobic processes from
which biogas is not recovered and anaerobic processes from which some biogas is recovered.
When and How Must Reports Be Submitted?
Annual reports must be submitted by March 31 of each year, unless the 31st is a Saturday, Sunday, or
federal holiday, in which case the reports are due on the next business day. Annual reports must be
submitted electronically using the electronic Greenhouse Gas Reporting Tool (e-GGRT). the GHGRP's
online reporting system. Additional information on setting up user accounts, registering a facility and
submitting annual reports is available at https://ccdsupport.com/confluence/.
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When Can a Facility Stop Reporting?
There are several scenarios under which a facility may discontinue reporting. These scenarios are
summarized in the Subpart A Information Sheet as well as in an FAQ.
For More Information
For additional information on Subpart II, visit the Subpart II Resources webpage. For additional
information on the Greenhouse Gas Reporting Program, visit the Greenhouse Gas Reporting Program
Website, which includes information sheets on other rule subparts, data previously reported to the
Greenhouse Gas Reporting Program, training materials, and links to frequently asked questions.
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 Greenhouse Gas
Reporting Program.
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