Industrial Wastewater Treatment Sources

		Environmental Protection

Greenhouse Gas Reporting Program	Aaency

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 fi'om 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 (CO2s). Owners or operators are required to collect wastewater
characterization and biogas emissions data, calculate GHG emissions, andfollow 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 CH4 recovered from each anaerobic treatment process (reactor, lagoon, and
sludge digester);

•	Annual mass of CH4 emitted from each anaerobic treatment process (reactor, lagoon, and sludge
digester.

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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 CH4 generated, 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
BOD 5 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 CH4 generated by each
anaerobic wastewater treatment process during the week. Weekly values must be summed to calculate the
annual mass of CH4 generated.

For all anaerobic treatment processes (reactors, lagoons, and sludge digesters) from which some biogas is
recovered, facilities must calculate the annual quantity of CH4 recovered based on continuous monitoring
of the biogas flow rate; continuous or weekly monitoring of CH4 concentration, temperature, pressure,
and moisture content; and appropriate biogas collection efficiencies provided in the regulation. They
must also calculate the annual quantity of CH4 emitted, based on appropriate values for biogas leakage
and biogas destruction device destruction efficiency. CH4 destruction efficiency must be based on either
the manufacturer's specified efficiency or 99 percent, whichever is less.

When Does Reporting Begin?

Facilities subject to subpart II must begin monitoring GHG emissions on January 1, 2011 in accordance
with the methods specified in subpart II. For 2012 only, the GHG report must be submitted to EPA by
September 28, 2012. This reporting deadline applies to all subparts being reported by the facility. If your
subpart II facility submitted a GHG annual report for reporting year 2010 under another subpart (e.g.,
subpart C for general stationary fuel combustion), then by April 2, 2012 you must notify EPA through e-
GGRT that you are not required to submit the second annual report until September 28, 2012 (the
notification deadline according to 4 CFR 98.3(b) is March 31, 2012, however, because this date falls on a
Saturday in 2012, the notification is due on the next business day).

Starting in 2013 and each year thereafter, reports must be submitted to EPA 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.

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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.

•	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 (B0) 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.

•	For each anaerobic wastewater treatment process (reactor, 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 CH4 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 CH4 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.

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EPA has temporarily deferred the requirement to report data elements in the above list that are used as
inputs to emission equations (76 FR 53057, August 25, 2011). For the current status of reporting
requirements, including the list of data elements that are considered to be inputs to emissions equations,
consult the following link: http://www.epa.gov/climatechange/emissions/CBI.html

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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