HCFC-22 Production and HFC-23 Destruction <>EPA
United States
Final Rule: Mandatory Reporting of Greenhouse Gases Environmental protection
Under the Mandatory Reporting of Greenhouse Gases (GHGs) rule, owners or operators of facilities that
contain hydrochlorofluorocarbon-22 (HCFC-22) production or hydrofluorocarbon-23 (HFC-23)
destruction processes (as defined below) must report emissions from HCFC-22 production, HFC-23
destruction processes, and all other source categories located at the facility for which methods are
defined in the rule. Owners or operators are required to collect emission data; calculate GHG emissions;
and follow the specified procedures for quality assurance, missing data, recordkeeping, and reporting.
How Is This Source Category Defined?
This source category consists of:
• Processes that produce HCFC-22 (chlorodifluoromethane, or CHC1F2) using chloroform and
hydrogen fluoride.
• HFC-23 destruction processes located at HCFC-22 production facilities.
• HFC-23 destruction processes that destroy more than 2.14 metric tons of HFC-23 per year and
that are not located at HCFC-22 production facilities.
What GHGs Must Be Reported?
Facilities that produce HCFC-22 or destroy HFC-23 must report the following emissions:
• HFC-23 emissions from HCFC-22 production processes at the facility.
• HFC-23 emissions from HFC-23 destruction processes.
In addition, each facility must report GHG emissions for other source categories for which calculation
methods are provided in the rule. For example, facilities must report carbon dioxide (CO2), nitrous oxide
(N2O), and methane (CH4) emissions from each stationary combustion unit on site by following the
requirements of 40 CFR 98, subpart C (General Stationary Fuel Combustion Sources). Please refer to the
relevant information sheet for a summary of the rule requirements for calculating and reporting emissions
from any other source categories at the facility.
How Must GHG Emissions Be Calculated?
Owners or operators must calculate HFC-23 emissions as follows:
• For HCFC-22 production processes that do not use a thermal oxidizer or that have a thermal
oxidizer that is not connected to the production equipment, calculate annual HFC-23 emissions at
the facility level using a mass balance equation and the following annual information:
o Mass of HFC-23 generated (using one of two alternative estimation methods specified in
the rule).
o Mass of HFC-23 sent off site for sale.
o Mass of HFC-23 sent off site for destruction.
o Mass of HFC-23 destroyed on site (calculated by multiplying the mass of HFC-23 fed
into the destruction device by the destruction efficiency).
o Increase in the HFC-23 inventory.
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• For HCFC-22 production processes with a thermal oxidizer that is connected to the production
equipment, calculate annual HFC-23 emissions at the facility level using an equation and the
following annual information:
o Mass of HFC-23 emissions from equipment leaks (calculated using default emission
factors and measured number of leaks in valves, pump seals, compressor seals, pressure
relief valves, connectors, and open-ended lines).
o Mass of HFC-23 emissions from process vents (calculated for each vent using the HFC-
23 emission rate from the most recent emission test and the ratio of the actual production
rate and the production rate during the performance test). Emission tests must be
conducted every five years, or after significant changes to the process.
o Mass of HFC-23 from the thermal oxidizer (calculated by subtracting the amount of
HFC-23 destroyed by the destruction device from the measured mass of HFC-23 fed into
the destruction device).
• For HFC-23 destruction processes, calculate HFC-23 emissions based on the mass of HFC-23 fed
into the destruction device and the destruction efficiency.
For the destruction efficiency, the owner or operator must conduct a performance test or use the
destruction efficiency determined during a previous performance test. To confirm the destruction
efficiency, the owner or operator must measure the fluorinated GHG concentration at the outlet to the
destruction device annually.
A checklist for data that must be monitored is available at:
www.epa.gov/climatechange/emissions/downloads/checklists/HCFC22Prod HFC23Destruc.pdf
When Must Reports be Submitted?
The submission date for the annual GHG report can vary in the first 3 years of the program.
• Reporting Year 2010. The report was required to be submitted by September 30, 2011.
• Reporting Year 2011. The due date depends on which source categories are included in the
report. If the report includes one or more of the source categories listed below, then the report
must be submitted by September 28, 2012. This reporting deadline applies to all subparts being
reported by the facility. In addition, if the facility contains one or more of these source categories
and the 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).
o Electronics Manufacturing (subpart I)
o Fluorinated Gas Production (subpart L)
o Magnesium Production (subpart T)
o Petroleum and Natural Gas Systems (subpart W
o Use of Electric Transmission and Distribution Equipment (subpart DD)
o Underground Coal Mines (subpart FF)
o Industrial Wastewater Treatment (subpart II)
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o Geologic Sequestration of Carbon Dioxide (subpart RR)
o Manufacture of Electric Transmission and Distribution (subpart SS)
o Industrial Waste Landfills (subpart TT)
o Injection of Carbon Dioxide (subpart UU)
o Imports and Exports of Equipment Pre-charged with Fluorinated GHGs or Containing
Fluorinated GHGs in Closed-cell Foams (subpart QQ)
If the report contains none of the source categories listed above, then the report must be submitted
by April 2, 2012 (the deadline is March 31, 2012, however, because this date falls on a Saturday,
the annual report is due on the next business day).
• Reporting Year 2012. Starting in 2013 and each year thereafter, the report 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.
What Information Must Be Reported?
In addition to the information required by the General Provisions at 40 CFR 98.3(c), the rule requires
owners or operators to report the following information on an annual basis at the facility level:
• For each HCFC-22 production process, owners or operators must report:
o Mass of HCFC-22 produced (metric tons).
o Loss factor accounting for loss of HCFC-22 upstream of the measurement.
o Reactants input to the HCFC-22 production process.
o Mass of materials other than HCFC-22 and HFC-23 (e.g., unreacted reactants, hydrogen
chloride [HC1], other byproducts) that occur in more than trace concentrations and that
are permanently removed from the process.
o Method for tracking startups, shutdowns, and malfunctions and the HFC-23
generation/emissions during these events.
o Names and addresses of facilities to which HFC-23 was sent for destruction and the
quantity of HFC-23 sent to each facility.
o Mass of HFC-23 generated and emitted (metric tons).
o Mass of HFC-23 sent off site for sale and for destruction (metric tons).
o Mass of HFC-23 in storage at the beginning and end of the year (metric tons).
o Mass of HFC-23 emitted from equipment leaks and process vents (metric tons).
• For each HFC-23 destruction process, owners or operators must report the following on an annual
basis:
o Mass of HFC-23 emissions from the thermal oxidizer.
o Mass of HFC-23 fed into and destroyed by the thermal oxidizer.
o The results of the annual emission measurements (and performance test, if applicable),
including, as applicable, the HFC-23 flow rate into the destruction device, the flow rate
of the gas at the outlet of the destruction device, the HFC-23 concentration in the gas at
the outlet, and the calculated HFC-23 emission rate.
• Facilities with HFC-23 destruction processes are also required to submit a one-time report that
must include the following:
o Destruction efficiency.
o Methods used to determine the destruction efficiency.
o Methods used to record the amount of HFC-23 destroyed.
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o Name of other relevant federal or state regulations that may apply to the destruction
process.
o A revised report must be submitted if any changes are made that affect destruction
efficiency or the HFC-23 measurement methods used
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 the final preamble and rule, 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: GHGreporting@epa.gov.
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