Suppliers of Industrial Greenhouse Gases oEPA

Subpart OO, Greenhouse Gas Reporting Program

Under Subpart OO of 40 CFR Part 98, Suppliers of Industrial Greenhouse Gases (GHGs) that meet
the applicability requirements of the Greenhouse Gas Reporting Program (GHGRP) (see Information
Sheet on General Provisions) must report GHG emissions that would result from the release of each
fluorinated GHG, fluorinated heat transfer fluid (HTF), and nitrous oxide (N2O) that they produce,
import, export, transform, or destroy. Suppliers of industrial GHGs are required to collect data on their
products and follow the specified procedures for ensuring data quality, amending missing data, and
meeting recordkeeping and reporting requirements per the requirements of 40 CFR Part 98 Subpart OO -
Suppliers of Industrial Greenhouse Gases.

How Is This Source Category Defined?

Suppliers of industrial GHGs include:

•	Facilities that produce fluorinated GHGs, fluorinated HTFs, or N2O.

•	Bulk importers or exporters of fluorinated GHGs, fluorinated HTFs, or N2O must report if either
their total imports or their total exports of fluorinated GHGs, fluorinated HTFs, N2O, and carbon
dioxide (CO2) are greater than or equal to 25,000 metric tons of carbon dioxide equivalent (CChe)
per year.

•	Facilities that destroy fluorinated GHGs or fluorinated HTFs must report if the total quantities of
fluorinated GHGs and fluorinated HTFs that they destroy are greater than or equal to 25,000
metric tons CChe per year.

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Production of fluorinated GHGs includes the following activities:

•	Manufacture of fluorinated GHGs from any raw material or feedstock chemical.

•	Manufacture of fluorinated GHGs as isolated intermediates for use in a process that will result in
their transformation on site or at another facility. (However, note that isolated intermediates that
are produced and transformed at the same facility are exempt from the monitoring, reporting, and
recordkeeping requirements of subpart OO.)

•	Creation of a fluorinated GHG (with the exception of HFC-23) that is captured and shipped off
site for any reason, including destruction.

Production of fluorinated GHGs excludes the following activities:

•	Reuse or recycling of a fluorinated GHG or N2O.

•	Creation of HFC-23 as a byproduct during the production of HCFC-22.

•	Creation of intermediates that are created and transformed in a single process with no storage of
the intermediates.

•	Creation of fluorinated GHGs that are released or destroyed at the production facility before the
production measurement at 40 CFR 98.414(a).

Production of fluorinated HTFs is defined similarly to production of fluorinated GHGs. See "What
Greenhouse Gases Must be Reported?" below for the definition of fluorinated HTF.

Production of N2O includes producing nitrous oxide by thermally decomposing ammonium nitrate
(NH4NO3). Producing N2O does not include the reuse or recycling of nitrous oxide or the creation of
byproducts that are released or destroyed at the production facility.

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What Greenhouse Gases Must Be Reported?

Under subpart 00, suppliers of industrial GHGs must report the GHG emissions that would result from
the complete release of N2O and each fluorinated GHG or fluorinated HTF produced, imported, exported,
transformed, or destroyed during the calendar year, with the following qualifications:

•	Suppliers must report destruction of those fluorinated GHGs or fluorinated HTFs that were
previously produced, e.g., fluorinated GHGs that are returned to the facility from the field for
reclamation but are found to be irretrievably contaminated and are thus destroyed. They are not
required to report destruction of fluorinated GHGs or fluorinated HTFs that are created and
destroyed before the production measurement.

•	Suppliers are not required to report the production, import, export, transformation or destruction
of low-concentration constituents of fluorinated GHG or fluorinated HTF products. A low-
concentration constituent is a fluorinated GHG or fluorinated HTF constituent of a fluorinated
GHG or fluorinated HTF product that occurs in the product below a certain concentration.

o For purposes of fluorinated GHG and fluorinated HTF production and export, the

concentration is 0.1 percent by mass,
o For purposes of fluorinated GHG and fluorinated HTF import, the concentration is 0.5
percent by mass.

•	Suppliers are not required to report the production or transformation of isolated intermediates that
are produced and transformed at the same facility.

•	Suppliers are not required to report the destruction of N2O.

Importers and exporters of CO2 must calculate and report annual GHG emissions of CO2 according to 40
CFR part 98, subpart PP.

Fluorinated GHGs include hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulfur hexafluoride
(SF6), nitrogen trifluoride (NF3), hydrofluoroethers (HFEs), and others as defined in 40 CFR 98.6.
Fluorinated GHGs do not include chlorofluorocarbons (CFCs) or hydrochlorofluorocarbons (HCFCs) that
are listed as ozone-depleting substances under EPA's stratospheric ozone protection regulations (40 CFR
part 82). Although CFCs and HCFCs contribute to climate change, their emissions are excluded from the
GHGRP because they are already subject to the stratospheric ozone protection regulations.

Fluorinated HTFs include fluorinated GHGs used for temperature control, device testing, cleaning
substrate surfaces and other parts, and soldering in processes including but not limited to certain types of
electronics manufacturing production processes. Fluorinated HTFs must be reported even if their vapor
pressures fall below the limit in the definition of fluorinated GHG in §98.6 (1 mm Hg absolute at 25 °C).
Fluorinated HTFs include, but are not limited to, perfluoropolyethers, perfluoroalkanes, perfluoroethers,
tertiary perfluoroamines, and perfluorocyclic ethers. Fluorinated HTFs do not include fluorinated GHGs
used as lubricants or surfactants.

How Must Greenhouse Gas Mass Be Calculated?

Suppliers must determine annual GHG supply flows in metric tons as follows:

•	The "net" mass of each fluorinated GHG, fluorinated HTF, or N2O produced must be determined
by measuring the mass of each fluorinated GHG, fluorinated HTF, or N2O produced (i.e., gas
coming out of the production process) and subtracting the mass of each fluorinated GHG,

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fluorinated HTF, or N2O added to the process upstream (i.e., where used GHGs are added back to
the production process for reclamation).

•	If the measured mass includes more than one fluorinated GHG or fluorinated HTF, the
concentrations of each of the fluorinated GHGs or fluorinated HTFs, other than low-
concentration constituents, must be measured as specified in 40 CFR Part 98 Subpart 00. These
concentrations must be multiplied by the measured mass to obtain the masses of each fluorinated
GHG or fluorinated HTF coming out of the production process.

•	The mass of each fluorinated GHG, fluorinated HTF, or N2O transformed must be determined by
using the measured mass of the fluorinated GHG, fluorinated HTF, or N2O fed into the
transformation process and the efficiency of the transformation process (as indicated by yield
calculations or quantities of unreacted fluorinated GHGs, fluorinated HTFs, or N2O permanently
removed from the process and recovered, destroyed, or emitted).

•	The mass of each fluorinated GHG or fluorinated HTF destroyed must be determined by
measuring the mass of fluorinated GHG or fluorinated HTF fed into the destruction device and
applying the destruction efficiency of the destruction device.

What Information Must Be Reported?

In addition to the information required by the General Provisions at 40 CFR 98.3(c), each annual report
must include the following information for production facilities, importers, exporters, and destruction
facilities:

Production Facilities

Production facilities must annually report the following information in metric tons by process for N2O
and each fluorinated GHG and fluorinated HTF, as applicable:

•	Mass produced, excluding mass shipped off site for destruction.

•	Mass transformed on site.

•	Mass of each fluorinated GHG or fluorinated HTF that is destroyed on site and that was
previously produced.

•	Mass sent to another facility for transformation.

•	Mass of each fluorinated GHG or fluorinated HTF sent to another facility for destruction,
excluding mass removed from the production process as byproducts or waste.

•	Mass of each fluorinated GHG or fluorinated HTF that is sent to another facility for destruction
and that is removed from the production process as byproducts or waste.

•	Mass fed into the transformation process.

•	Mass of each fluorinated GHG or fluorinated HTF that is fed into the destruction device and that
was previously produced.

•	Mass measured coming out of the production process.

•	Mass of used product added back into the production process (e.g., because it is being reclaimed).

•	Name and address of each facility to which industrial GHGs and fluorinated HTFs are sent for
transformation, and the mass of N2O and each fluorinated GHG or fluorinated HTF sent to each
facility.

•	Name and address of each facility to which fluorinated GHGs or fluorinated HTFs are sent for
destruction, and the mass of each fluorinated GHG or fluorinated HTF sent to each facility.

•	Where missing data have been estimated, the reason the data were missing, the length of time the
	data were missing, the method used to estimate the missing data, and the estimates of those data.

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Facilities that begin producing fluorinated GHGs must, within 60 days of commencing fluorinated GHG
production, submit a one-time report describing:

•	The methods by which the producer in practice measures the mass of fluorinated GHGs
produced, including the instrumentation used (e.g., Coriolis flowmeter, other flowmeter, weigh
scale) and its accuracy and precision.

•	The methods by which the producer in practice estimates the mass of fluorinated GHGs fed into
the transformation process, including the instrumentation used (e.g., Coriolis flowmeter, other
flowmeter, weigh scale) and its accuracy and precision.

•	The methods by which the producer in practice estimates the fraction of fluorinated GHGs fed
into the transformation process that is actually transformed, and the estimated precision and
accuracy of this estimate.

•	The methods by which the producer in practice estimates the masses of fluorinated GHGs fed into
the destruction device, including the methods used to estimate the concentration of the fluorinated
GHGs in the destroyed material, and the estimated precision and accuracy of this estimate.

•	The estimated percent efficiency of each production process for the fluorinated GHG produced.

Production facilities are also required to submit reports regarding the constituents of their products:

•	Facilities that produce fluorinated GHGs were required to submit a one-time report by March 31,
2011, that included the concentration of each fluorinated GHG constituent in each fluorinated
GHG product.

•	Facilities that produce fluorinated HTFs that are not also fluorinated GHGs must submit a one-
time report by March 31, 2019, that includes the concentration of each fluorinated HTF or
fluorinated GHG constituent in each fluorinated HTF product.

•	If the facility begins to produce a fluorinated GHG or fluorinated HTF that was not included in
the initial report, or if the facility performs a repeat measurement that shows that the identities or
concentrations of the fluorinated GHG or fluorinated HTF constituents of a fluorinated GHG or
fluorinated HTF product have changed, then the facility must submit a revision to the report
reflecting the new or changed concentrations by the next March 31st.

Facilities and Importers that Destroy Fluorinated GHGs or Fluorinated HTFs

Facilities (including production facilities and destruction-only facilities) and importers that destroy
fluorinated GHGs or fluorinated HTFs must also submit a one-time report that contains the following
information:

•	Destruction efficiency (DE) of each destruction process.

•	Methods used to determine DE.

•	Methods used to record the mass of fluorinated GHGs or fluorinated HTFs destroyed.

•	Chemical identity of the fluorinated GHGs used in the performance test conducted to determine
DE.

•	Name of all federal or state regulations applicable to the destruction process.

•	If any process changes are made affecting unit DE or the methods used to record the mass
destroyed, a revised report must be submitted within 60 days of the change.

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•	The deadline for the one-time report depends on what is destroyed and when the destruction
begins:

•	Any fluorinated GHG production facility or importer that destroys fluorinated GHGs
must submit the one-time destruction report by March 31, 2011 or within 60 days of
commencing fluorinated GHG destruction, whichever is later.

•	Any fluorinated GHG production facility or importer that destroys fluorinated HTFs that
are not also fluorinated GHGs must submit the one-time destruction report by March 31,
2019 or within 60 days of commencing fluorinated HTF destruction, whichever is later.

•	Any facility that destroys fluorinated GHGs or fluorinated HTFs but does not produce or
import fluorinated GHGs must submit the one-time destruction report by March 31, 2019
or within 60 days of commencing fluorinated GHG or fluorinated HTF destruction,
whichever is later.

Importers

Bulk importers of fluorinated GHGs, fluorinated HTFs, or N2O must submit an annual report at the
corporate level. The report must include the following information for each import (excluding
transshipments, heels, and shipments of less than 25 kilograms of fluorinated GHGs, fluorinated HTFs, or
N20):

•	Mass in metric tons of each fluorinated GHG, fluorinated HTF, or N20 imported in bulk.

•	Mass in metric tons of each fluorinated GHG, fluorinated HTF, or N20 that is sold or transferred
to persons other than the importer for use in processes resulting in the transformation or
destruction of the chemical.

•	Date imported.

•	Port of entry.

•	Country from which imported.

•	Commodity code.

•	Importer number for the shipment.

•	Mass in metric tons of each fluorinated GHG and fluorinated HTF destroyed by the importer.

•	Names and addresses of the persons and facilities to which the N20, fluorinated GHGs, or
fluorinated HTFs were sold or transferred for transformation, and the quantities (metric tons) of
N20 and of each fluorinated GHG and fluorinated HTF that were sold or transferred to each
facility for transformation.

•	Names and addresses of the persons and facilities to which the fluorinated GHGs or fluorinated
HTFs were sold or transferred for destruction, and the quantities (metric tons) of each fluorinated
GHG or fluorinated HTF that were sold or transferred to each facility for destruction.

Exporters

Bulk exporters of fluorinated GHGs, fluorinated HTFs, or N2O must submit an annual report at the
corporate level. The report must include the following information for each export (excluding
transshipments, heels, and shipments of less than 25 kilograms of fluorinated GHGs, fluorinated HTFs, or
N20):

•	Mass in metric tons of each fluorinated GHG, fluorinated HTF, or N20 exported in bulk.

•	Names and addresses of the exporter and recipient.

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•	Date exported.

•	Port from which each fluorinated GHG, fluorinated HTF, or N20 were exported from the
United States or its territories.

•	Countries to which each fluorinated GHG, fluorinated HTF, or N20 were exported.

•	Commodity code of each fluorinated GHG, fluorinated HTF, or N20 exported.

•	Exporter's Employee Identification Number.

Destruction-Only Facilities

Facilities that destroy fluorinated GHGs or fluorinated HTFs but that do not produce or import them must
report the mass in metric tons of each fluorinated GHG or fluorinated HTF that is destroyed at that
facility.

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. Access additional information on setting up user accounts, registering a facility
and submitting annual reports.

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

Access additional information on Subpart 00. Access additional information on the Greenhouse Gas
Reporting Program, including information sheets on other GHGRP 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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