TECHNICAL SUPPORT DOCUMENT FOR BULK
IMPORTS AND EXPORTS OF FLUORINATED
GHGS, N2O, AND CO2:
PROPOSED RULE FOR MANDATORY
REPORTING OF GREENHOUSE GASES
Office of Air and Radiation
U.S. Environmental Protection Agency
February 2, 2009
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Contents
1. Source Description 3
a. Total Inventory 3
2. Review of Existing Reporting Programs and Methodologies 4
3. Options for Reporting Threshold 4
4. Options for Monitoring Methods 5
5. Procedures for Estimating Missing Data 5
6. QA/QC Requirements 5
7. Reporting Procedures 5
8. Definitions 6
9. References 6
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1. Source Description
Fluorinated greenhouse gases (fluorinated GHGs) are man-made gases used in several sectors, and include
hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulfur hexafluoride (SF6), nitrogen trifluoride (NF3),
fluorinated ethers, and other compounds such as perfluoropolyethers. (Fluorinated GHGs also include
chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs), but since these ozone-depleting substances
(ODSs) are currently being phased out and otherwise regulated under the Montreal Protocol and Title VI of the
Clean Air Act, EPA is not proposing requirements for them under this rule.) Fluorinated GHGs are powerful
greenhouse gases whose ability to trap heat in the atmosphere is often thousands to tens of thousands as great as that
of CO2, on a pound-for-pound basis. Some fluorinated GHGs are also very long lived; SF6 and the PFCs have
lifetimes ranging from 3,200 to 50,000 years (IPCC 2006).
HFCs are the most common fluorinated GHGs, used primarily to replace ODSs in a number of applications,
including air-conditioning and refrigeration, foams, solvents, and aerosols. PFCs are used in the fire fighting and in
the semiconductor and other electronics sectors. SF6 is used in a diverse array of applications, including electrical
transmission and distribution equipment (as an electrical insulator and arc quencher) and in magnesium casting
operations (as a cover gas to prevent oxidation of molten metal). NF3 is used in the semiconductor industry,
increasingly to reduce overall semiconductor greenhouse gas emissions through processes such as NF3 remote
cleaning and NF3 substitution during in-situ cleaning. Fluorinated ethers (HFEs and HCFEs) are used as anesthetics
(e.g., isofluorane, desflurane, and sevoflurane) and as heat transfer fluids (e.g., the H-Galdens). Fluorinated GHGs
are also used as feedstocks to produce other chemicals.
Other non-fluorinated bulk GHGs are also imported into the United States. Specifically, nitrous oxide (N2O) and
carbon dioxide (CO2) are imported into the country. N2O is primarily used as a carrier gas with oxygen to
administer more potent inhalation anesthetics for general anesthesia, as well as a propellant in pressure and aerosol
products. Bulk CO2 gas is utilized by a wide variety of industries for operations such as welding, oil and gas
recovery, fire extinguishing, and chemical production. CO2 is also used in an array of consumer products, such as
carbonated beverages and refrigerated appliances.
a. Total Inventory
It is estimated that 110 million metric tons of CO2 equivalent (MMTCO2e) of bulk HFC, PFC, NF3, SF6, N2O, and
CO2 gas were imported into the United States in 2006 (PIERS, 2007). More specifically, 2006 imports of HFCs are
estimated to have exceeded 25 MMTCO2e, imports of PFCs are estimated to have exceeded 14 MMTCO2e, imports
of SF6 and NF3 are estimated to have exceeded 35 MMTCO2e each, imports of N2O are estimated to almost reach
0.3 MMTCO2e, and imports of CO2 are estimated to be almost 0.1 MMTCO2e. The breakdown of total bulk gas
imports by gas in shown in Table 1. Although NF3 and SF6 account for less than 10 percent of imports on a metric
ton basis, they account for over 60% of imports when weighted by global warming potential (GWP).
Table 1. 2006 U.S. Bulk Gas Imports by Gas Type
Bulk Gas
Type
HFCs
PFCs
NF3
SF6
N2O
C02
All F-Gases
All Gases
Amount Imported
(mt)
32,245
1,679
2,035
1,485
957
981
37,625
39,563
Percent of mt
Total
82%
4%
5%
4%
2%
2%
95%
100%
Amount Imported
(mtCO2e)
25,192,652
14,024,068
35,009,809
35,502,625
296,783
981
109,729,154
110,026,918
Percent of mtCO2e
Total
23%
13
32
32
<0.5
<0.5
100%
100%
Source: PIERS (2007)
It is estimated that there are 147 importers of bulk GHG gases into the United States (PIERS, 2007).
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Several other gases with GWPs may also be imported, including fluorinated ethers, H-Galdens, and anesthetics such
as desflurane (HFE-236ea2), isoflurane (HCFE-235da2), and sevoflurane (HFE-347mcc3). The imports of these
gases have not currently been quantified.
2. Review of Existing Reporting Programs and Methodologies
Protocols and guidance reviewed for this analysis include the 2006IPCC Guidelines, Title VI of CAA, Part 75
Appendix D (measurement requirements for oil and natural gas), the Toxic Release Inventory (TRI), the Technical
Guidelines for the Voluntary Reporting of Greenhouse Gases (1605(b) Program), the Toxic Substances Control Act
(TSCA) Chemical Substance Inventory, EPA's Climate Leaders Program, the Climate Registry, the European
Commission's Article 6 reporting, and the Australian Commonwealth Government Ozone Protection and Synthetic
Greenhouse Gas Reporting Program.
Many existing programs require importers to provide the quantities imported and to keep more detailed records that
permit verification of the reports. Title VI of the CAA includes detailed requirements for reporting and
recordkeeping related to imports and exports of ozone-depleting substances; these requirements (with appropriate
modifications) are being used as the model for the proposed rule. TSCA Inventory Update Reporting (IUR) requires
importers to keep additional records beyond what is reported, which may be accessed by EPA at any time. Under
the Ozone Protection and Synthetic Greenhouse Gas Management Act of 1989, Australia requires that importers of
ODSs and fluorinated GHGs be certified prior to importing these gases and that they report all imports of these
gases.
For the full review of existing programs, please refer to (EPA-HQ-OAR-2008-0508-054).
3. Options for Reporting Threshold
EPA evaluated a range of threshold options for bulk imports and exports. These included emission-based thresholds
of 1,000, 10,000, 25,000, and 100,000 mtCO2e, summing imports across all gases. EPA also considered setting no
threshold (requiring reporting of all imports), as is the case under Title VI of the Clean Air Act (CAA) and the
Australian Synthetic Greenhouse Gas Reporting Program.
The results of this analysis are presented in Table 2. Virtually 100 percent of imports are covered by every threshold
considered. However, the percentage of importers reporting varies markedly among thresholds, ranging from 30
percent at a threshold of 100,000 mtCO2e to 76 percent at a threshold of 1,000 mtCO2e. Forty-one percent of
importers would be required to report at a threshold of 25,000 mtCO2e.
Table 2. Threshold Analysis for Importers of Bulk Fluorinated GHGs and N2O
Threshold Considered
1,000
10,000
25,000
100,000
Number of Importers
Covered (% of Total)
111(76%)
81 (55%)
61 (41%)
44 (30%)
Volume of Gas Covered in mtCO2e
(% of Total)
110,025,045(100%)
109,922,020 (100%)
109,580,102(100%)
108,703,147(99%)
Source: PIERS (2007)
When imports of CO2 are also considered, the number of importers covered at the l,000-mtCO2e threshold increases
by one, to 112. There are no changes at higher thresholds.
Information about importers and quantities imported were obtained from PIERS (2007). The PIERS database uses
"N/A" to indicate an imported shipment for which no importer was identified. The above analysis assumes that
importers that were identified as "N/A" are one single entity. An additional sensitivity analysis that assumes that
"N/A" importers are all separate entities was also performed. A total of 494 importers were identified under this
analysis. Of this amount, 221 (45%) would be required to report under a 25,000 mtCO2e threshold, capturing 99%
of bulk gas imports. The nearly equal results of the main threshold analysis and the additional sensitivity analysis
indicate that the results of the main threshold analysis are robust with regard to unidentifiable importers.
Because it may be relatively easy for importers and exporters to create new corporations in order to divide up their
imports and exports and remain below applicable thresholds, EPA considered setting no threshold for importers and
exporters. The drawback of this approach is that it could substantially increase the burden of the rule, especially
upon small businesses, without necessarily substantially increasing the quantity of imports or exports reported.
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EPA also considered a range of publications from which to draw the 100-year GWPs that importers would use to
determine whether their CO2-equivalent imports exceeded the applicable threshold. These included the IPCC
Second Assessment Report (SAR) and later IPCC and other reports (e.g., the 2006 Scientific Assessment of Ozone
Depletion published by the World Meteorological Organization.) The advantage of using the GWPs published in
the SAR is that these are the GWPs that are used for current U.S. and international reporting of CO2-equivalent
GHG emissions. The disadvantage is that the SAR does not list GWPs for some of the fluorinated GHGs that are
coming into increasing use (notably NF3 and many of the fluorinated ethers). However, if SAR GWPs were not
available, importers could use the most recent GWP from either an IPCC Assessment Report or a WMO Scientific
Assessment of Ozone Depletion.
4. Options for Monitoring Methods
The quantities of GHGs imported could be reported by chemical in tons or in mtCO2e. Reporting in tons of
chemical would provide more transparency and reduce mistakes such as arithmetic errors or the use of inappropriate
GWPs. In addition, tons of chemical is the unit in which other quantities (production, emissions, etc.) are proposed
to be reported under this rule. Reports could include quantities imported in mixtures, and the name/number of the
mixture, if applicable (e.g., HFC-410A).
Currently, net weight of chemical in bulk containers is declared using U. S. Customs and Border Protection CBP
Form 7501: Entry Summary. This form requires reporting of gross shipment weight as well as "manifest quantity,"
using Harmonized Tariff Schedule numbers and associated units of measure; the units of measure associated with
chemical goods is kilograms, net of container weight. This applies for importers as well as the Census' "Schedule
B" for exports.
5. Procedures for Estimating Missing Data
No data should be missing as the data are required for importing and exporting in the United States.
6. QA/QC Requirements
QA/QC requirements could include reviewing the annual submission against the import and export transaction
records to ensure that the information submitted to EPA is being accurately transcribed as the correct chemical or
blend in the correct units and quantities (metric tons).
7. Reporting Procedures
Reporting of the following data would be useful for confirming and documenting import estimates:
• The quantity of GHGs imported by chemical in tons of chemical;
• The date on which the GHGs were imported;
• The port of entry through which the GHGs passed;
• The country from which the imported GHGs were imported; and
• The importer number for the shipment.
The following records would be useful for confirming and documenting import estimates:
• A copy of the bill of lading for the import;
• The invoice for the import;
• The U.S. Customs entry form;
• If applicable, dated records documenting the sale or transfer of the imported GHG for transformation or
destruction; and,
• Persons who import heels of GHGs could be required to label their bill of lading or invoice indicating that
the GHG in the container is a heel; and, in a manner as defined for ozone depleting substances in 40 CFR
section 82.13, to report the amount brought into the United States and certify that the residual amount in
each shipment is less than 10 percent of the volume of the container and will:
o Remain in the container and be included in a future shipment;
o Be recovered and transformed; or,
o Be recovered and destroyed.
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Reporting of the following data would be useful for confirming and documenting export estimates:
• The names and addresses of the exporter and the recipient of the exports;
• The exporter's Employee Identification Number;
• The quantity exported by chemical in tons of chemical;
• The date on which, and the port from which, the GHGs were exported from the United States or its
territories; and
• The country to which the GHGs were exported.
The following records would be useful for confirming and documenting export estimates:
• A copy of the bill of lading for the export; and
• The invoice for the export.
Because heels (residual quantities inside returned containers) and transshipments (GHGs that originate in a foreign
country and that are destined for another foreign country) would not be released in the United States, it may be
appropriate to exclude them from reporting. However, it would be reasonable to require importers and exporters to
keep records documenting the nature of these transactions. For example, parties who transship a GHG could be
required to maintain records that indicated that the GHG originated in a foreign country and was destined for
another foreign country and did not enter into commerce in the United States.
These reporting and recordkeeping requirements would be consistent with those of the Stratospheric Ozone
Protection Program.
8. Definitions
Definitions from 40 CFR Part 82. Subpart A
Heel means the amount of a controlled substance that remains in a container after it is discharged or off-loaded (that
is no more than ten percent of the volume of the container) and that the person owning or operating the container
certifies the residual amount will remain in the container and be included in a future shipment, or be recovered for
transformation, destruction or a non-emissive purpose.
Import means to land on, bring into, or introduce into, or attempt to land on, bring into, or introduce into any place
subject to the jurisdiction of the United States whether or not such landing, bringing, or introduction constitutes an
importation within the meaning of the customs laws of the United States, with the following exemptions:
(1) Off-loading used or excess controlled substances or controlled products from a ship during
servicing,
(2) Bringing controlled substances into the U.S. from Mexico where the controlled substance had
been admitted into Mexico in bond and was of U. S. origin, and
(3) Bringing a controlled product into the U.S. when transported in a consignment of personal or
household effects or in a similar non-commercial situation normally exempted from U.S. Customs
attention.
Transshipment means the continuous shipment of a controlled substance, from a foreign state of origin through the
United States or its territories, to a second foreign state of final destination, as long as the shipment does not enter
into United States jurisdiction. A transshipment, as it moves through the United States or its territories, cannot be re-
packaged, sorted, or otherwise changed in condition.
9. References
Folland, C.K., T.R. Karl, J.R. Christy, R.A. Clarke, G.V. Gruza, J. Jouzel, M.E. Mann, J. Oerlemans, M.J.
Salinger and S.-W. Wang (2001) Observed Climate Variability and Change. In: Climate Change 2001: The
Scientific Basis. Contribution of Working Group I to the Third Assessment Report of the
Intergovernmental Panel on Climate Change, Houghton, J.T.,Y. Ding, D.J. Griggs, M. Noguer, P.J. van der
Linden, X. Dai, K. Maskell, and C.A. Johnson (eds.). Cambridge University Press, Cambridge, United
Kingdom and New York, NY, USA.
IPCC (2007) Climate Change 2007: The Physical Science Basis. Contribution of Working Group I to the
Fourth Assessment Report of the Intergovernmental Panel on Climate Change, Solomon, S., D. Qin, M.
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Manning, Z. Chen, M. Marquis, K.B. Averyt, M. Tignor and H.L. Miller (eds.). Cambridge University
Press, Cambridge, United Kingdom and New York, NY, USA.
IPCC (2006) 2006 IPCC Guidelines for National Greenhouse Gas Inventories. The National Greenhouse
Gas Inventories Programme, The Intergovernmental Panel on Climate Change, H.S. Eggleston, L. Buendia,
K. Miwa, T. Ngara, and K. Tanabe (eds.). Hayama, Kanagawa, Japan.
PIERS (2007) PIERS Import/Export Data. 1 November 2006 through 31 October 2007.
WMO (World Meteorological Organization) (2007) Scientific Assessment of Ozone Depletion: 2006,
Global Ozone Research and Monitoring Project - Report No. 50. Geneva, Switzerland.
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