Fluorinated Gas Production
- United States
Subpart L, Mandatory Reporting of Greenhouse Gases Aaencjmental Pl°t9ction
Under the Mandatory Reporting Rule for Additional Sources of Fluorinated Greenhouse Gases,
owners or operators of facilities that contain fluorinated gas production processes (as defined
below) and whose uncontrolled emissions equal or exceed 25,000 metric tons of carbon dioxide
equivalent per year from fluorinated gas production, stationary combustion, miscellaneous use of
carbonates, and other source categories (see information sheet on General Provisions- subpart A)
must report emissions from all source categories located at the facility for which emission
calculation methods are defined in the rule. Owners or operators must collect emission data,
calculate greenhouse gas (GHG) emissions, and follow the specified procedures for quality
assurance, missing data, recordkeeping, and reporting.
Producers of fluorinated gases should also review the requirements of 40 CFRpart 98, subparts
O andOO (HCFC-22 Production andHFC-23 Destruction; Suppliers of Industrial Greenhouse
Gases) to determine if they must also report emissions under those subparts.
How Is This Source Category Defined?
The fluorinated gas production source category consists of processes that produce fluorinated gases from
any raw material or feedstock chemical. Fluorinated gases include fluorinated GHGs (described further
below), chlorofluorocarbons (CFCs), and hydrochlorofluorocarbons (HCFCs). This source category does
not include reuse or recycling of fluorinated gases and the generation of HFC-23 from the production of
HCFC-22. Emissions of HFC-23 from HCFC-22 production are covered in subpart O (HCFC-22
Production and HFC-23 Destruction).
What GHGs Must Be Reported?
Fluorinated GHGs include hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulfur hexafluoride (SF6),
nitrogen trifluoride (NF3), hydrofluoroethers (HFEs), and other fluorinated compounds as defined in 40
CFR98.6.
You must report the annual mass of each fluorinated-GHG emitted from:
• Each fluorinated gas production process and all fluorinated gas production processes combined.
• Each fluorinated gas transformation process that is not part of a fluorinated gas production process
(e.g., the transformation of an isolated intermediate into something other than a fluorinated gas)
and all such fluorinated gas transformation processes combined. (However, facilities are required
to separately report fluorinated GHG emissions from transformation processes where a fluorinated
GHG reactant is produced at another facility).
• Each fluorinated gas destruction process that is not part of a fluorinated gas production process or a
fluorinated gas transformation process (e.g., the destruction of a fluorinated GHG returned from the
field) and all such fluorinated gas destruction processes combined.
• Venting of residual fluorinated GHGs from containers returned from the field.
Each facility must also report GHG emissions for other source categories for which calculation methods are
provided in other subparts of the rule. For example, facilities must report carbon dioxide (CO2), nitrous
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oxide (N2O), and methane (CH^ emissions from each stationary combustion unit on site by following the
requirements of 40 CFRpart 98, subpart C (General Stationary Fuel Combustion Sources). If applicable,
facilities must also report the emissions of HFC-23 from HCFC-22 production processes and HFC-23
destruction processes as required by 40 CFR part 98, subpart O (HCFC-22 Production and HFC-23
Destruction). Please refer to the relevant information sheet for a summary of the requirements for
calculating and reporting emissions from any other source categories at the facility.
How Must GHG Emissions Be Calculated?
You must estimate GHG emissions using either the mass-balance approach or the emission factor or
emission calculation factor approach. Regardless of the approach used to estimate fluorinated gas emissions
from production and transformation processes, emissions must also be calculated for destruction processes,
and for venting of residual fluorinated GHGs from containers (e.g., cylinder heels).
Scoping Speciation
To determine what processes and gases to include in your GHG report, you must sample and analyze
process streams or process vents to identify all fluorinated GHGs that are generated in processes that have
at least one process vent with annual uncontrolled fluorinated GHG emissions of one metric ton or more.
Mass-Balance Approach
Accuracy and precision requirements. Before using the mass-balance approach for a process, you must
ensure that the process and the equipment and methods used to collect data meet either (1) certain absolute
or relative error limits, or (2) specific accuracy, precision, frequency and throughput requirements.
1. A process qualifies to use the mass-balance equation under the error limits approach if either
one of the two following conditions is met:
o the absolute error of the emissions estimated under the mass-balance approach is less than
or equal to 3,000 metric tons CO2e per year, or
o the relative error is less than or equal to 30 percent of the estimated process emissions.
2. Alternatively, a process qualifies to use the mass-balance equation if all of the following
conditions are met:
o The process must have a total annual throughput of 500,000 mtCO2e or less, where the
throughput is defined as the sum of the CO2-weighted masses of the fluorinated GHG
reactants, products, and by-products.
o You must measure the masses and concentrations identified in the rule at least weekly, and
you must calculate emissions at least weekly.
o You must measure the masses identified in the rule with an accuracy and precision of ±0.2
percent of full scale or better.
o You must measure the concentrations identified in the rule using analytical methods with
an accuracy and precision of ±10 percent or better.
If neither of these conditions is met, you must use the emission factor or emission calculation factor
approach for the process.
Mass-balance measurements and calculations. Under the mass-balance approach, fluorinated GHG
emissions must be calculated by measuring or calculating the following variables:
• Total mass of each fluorine-containing reactant fed into the process (measured at least monthly)
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• Total mass of the fluorine-containing product produced by the process (measured at least monthly)
• Total mass of fluorine in destroyed or recaptured streams containing fluorine-containing reactants,
products, and byproducts
• Mass fractions of each emitted fluorinated GHG reactant, product, and by-product relative to the
total mass of all emitted fluorinated GHGs
In order to calculate these variables, the following inputs must be measured at least monthly:
• Mass removed from the process in each stream that is fed into the destruction device and that
contains greater than trace concentrations of fluorine-containing reactants, products, or by-products
• Mass removed from the process in each recaptured stream that contains greater than trace
concentrations of fluorine-containing by-products
• Concentration (mass fraction) of each fluorine-containing reactant, product, and by-product in each
stream that is fed into the destruction device
• Concentration (mass fraction) of each fluorine-containing by-product in each recaptured stream.
• Destruction efficiency of the destruction device as demonstrated for each fluorinated GHG in each
stream
Process-Vent-Specific Emission Factor and Emission Calculation Factor Approach
This approach has different requirements for continuous and batch processes. For batch processes, you
may develop either process-vent-specific emission factors (Emission Factor Approach) or process-vent-
specific emission calculation factors (Emission Calculation Factor Approach). For continuous processes,
you must perform a preliminary estimate of emissions for each process vent to determine whether you may
use the Emission Calculation Factor Approach or must use the Emission Factor Approach. In either case,
you must also estimate emissions from equipment leaks.
Preliminary estimate and choice of method. For continuous process vents, facilities must calculate the
CO2-equivalent emissions from each process vent using the engineering calculations or assessments
specified in the rule. For fluorinated GHGs whose GWPs are not listed in Table A-l of subpart A of part
98, you may use a default GWP of 2000. Alternatively, you may submit a request to EPA to use
provisional GWPs for these fluorinated GHGs if:
• the fluorinated GHGs are emitted in quantities that, with a default GWP of 2000, result in total
calculated annual emissions equal to or greater than 10,000 metric tons CO2e for the vent, and
• you submit data and analysis that support GWPs for the fluorinated GHGs that would result in total
calculated annual emissions less than 10,000 metric tons CO2e for the vent.
If an individual continuous process vent has fluorinated GHG emissions of less than 10,000 metric
tons CO2e per year, then use either:
• Process-vent-specific emission factor method.
• Process-vent-specific emission calculation factor method.
If an individual continuous process vent within an operating scenario has fluorinated GHG emissions of
greater than 10,000 metric tons CO2e per year, then use:
• Process-vent-specific emission factor method.
If you are estimating emissions from a batch process vent, then use either:
• Process-vent-specific emission factor method.
• Process-vent-specific emission calculation factor method.
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Emission factor and emission calculation factor measurements and calculations.
Under the process-vent-specific emission factor method, fluorinated GHG emissions must be calculated
using the following:
• Process-vent-specific emission factor based on emission testing during representative performance
of the process or operating scenario(s) of the process, as applicable.
o If the vent is controlled and annual emissions bypassing, i.e., not venting to, the destruction
device are less than 10,000 mtCO2e, the facility may conduct emissions testing after the
destruction device.
o Otherwise, the facility must conduct emissions testing before the destruction device.
• Total annual process activity.
• Destruction efficiency, only for the portion of the process activity during which the vent is vented
to a destruction device.
Under the process-vent-specific emission calculation factor method, fluorinated GHG emissions must be
calculated using the following:
• Process-vent-specific emission calculation factor.
• Total annual process activity.
• Destruction efficiency, only for the portion of the process activity during which the vent is vented
to a destruction device.
Equipment leaks. For both the process-vent-specific emission factor method and the process-vent-specific
emission calculation factor method, information must be collected on the number and type of equipment;
service of each piece of equipment; concentration of each fluorinated GHG in the stream; and the time
period each piece of equipment was in service. Emissions from equipment leaks must be calculated using
any of the following methods:
• Average Emission Factor Approach in the EPA Protocol for Equipment Leak Estimates.
• Other Approaches in the EPA Protocol for Equipment Leak Estimates in conjunction with EPA
Method 21.
• Other Approaches in the EPA Protocol for Equipment Leak Estimates in conjunction with site-
specific leak monitoring methods.
• Site-specific leak monitoring methods.
Establishing Destruction Efficiencies
If you choose to apply the destruction efficiency (DE) of a destruction device to a fluorinated GHG, you
must establish the DE of that device for that fluorinated GHG. To establish the destruction efficiency,
either conduct a performance test or use the destruction efficiency determined during a previous
performance test that meets the rule requirements. For certain difficult-to-destroy fluorinated GHGs
including CF4, SF6, and saturated PFCs other than CF4, a destruction efficiency must be developed
specifically for that compound or for a more difficult-to-destroy surrogate that is specified in the rule (e.g.,
CF4 may be used as a surrogate for SF6 and either CF4 or SF6 may be used as a surrogate for saturated
PFCs). For other fluorinated GHGs, the destruction efficiency may be developed using a more-difficult-to-
destroy surrogate from the list of Class 1 compounds on the Thermal Stability Rankings (Appendix D,
Table D-l of "Guidance on Setting Permit Conditions and Reporting Trial Burn Results; Volume II of the
Hazardous Waste Incineration Guidance Series," January 1989, EPA Publication EPA 625/6-89/019.)
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Destruction of Fluorinated GHGs that were Previously "Produced"
Calculate emissions from the destruction of fluorinated GHGs that were previously "produced" (e.g., that
are returned from the field for destruction because they are irretrievably contaminated) using the following:
• Mass of fluorinated GHGs previously "produced" that are fed into the destruction device.
• Destruction efficiency of the destruction device for each fluorinated GHG.
Venting of Residual Fluorinated GHGs in Containers
Calculate emissions from the venting of residual fluorinated GHGs from containers using one the following
methods:
• Measure the contents of each container before and after venting.
• Develop a heel factor (based on representative samples) for each combination of fluorinated GHG,
container size, and container type, and apply this factor to the number of containers vented.
What Information Must Be Reported?
In addition to the information required by the General Provisions at 40 CFR 98.3(c), you must report the
following information:
• Annual mass in metric tons of each fluorinated GHG emitted from:
o Each fluorinated gas production process and all fluorinated gas production processes
combined.
o Each fluorinated gas transformation process that is not part of a fluorinated gas production
process and all such fluorinated gas transformation processes combined, except report
separately fluorinated GHG emissions from transformation processes where a fluorinated
GHG reactant is produced at another facility.
o Each fluorinated gas destruction process that is not part of a fluorinated gas production
process or a fluorinated gas transformation process and all such fluorinated gas destruction
processes combined.
o Venting of residual fluorinated GHGs from containers returned from the field.
• Chemical identities of the contents of the process or emissions stream(s) analyzed under the initial
scoping speciation of fluorinated GHG, by process.
• Location and function of the process or emissions stream(s) that were analyzed under the initial
scoping speciation of fluorinated GHG, by process.
• Method used to determine the mass of emissions of each F-GHG, for each process and process vent
at the facility.
• Chemical formula and total mass produced of the fluorinated gas product in metric tons, by
chemical and process.
• Missing data periods, including reporting the reasons for the missing data, the length of time the
data were missing, the method used to estimate values for missing data, and the estimates of those
data.
In addition, facilities must report information specific to each method that they use to estimate emissions
from their processes. Please see the final rule for the reporting requirements for facilities using each
estimation method.
Fluorinated gas production facilities that destroy fluorinated GHGs must submit:
• Excess emissions that result from malfunctions of the destruction device.
• Destruction device testing report.
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• For each previously produced fluorinated GHG destroyed:
o The mass of the fluorinated GHG fed into the destruction device.
o The mass of the fluorinated GHG emitted from the destruction device.
• A one-time report by June 30, 2011, that describes any measurements, research, or analysis that it
has performed or obtained that relate to the formation of products of incomplete combustion (PICs)
that are fluorinated GHGs during the destruction of fluorinated gases.
Fluorinated gas production facilities that vent residual fluorinated GHGs from containers must report the
following for each fluorinated GHG vented:
• Annual mass of the residual fluorinated GHG vented from each container size and type (metric
tons).
• If applicable, the heel factor calculated for each container size and type.
For More Information
Visit EPA's Web site (www.epa.gov/climatechange/emissions/ghgrulemaking.html) for more information
and additional information sheets, or go to www.regulations.gov to access the rulemaking docket EPA-HQ-
OAR-2009-0927.
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 rule. They are not
intended to be a substitute for the rule.
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