2010-2011-2012 GHGRP Industrial Profiles

Fluorinated Chemicals

Direct Emissions from Fluorinated
Chemicals (Including HCFC-22)

Production

Highlights

•	Emissions from Fluorinated Gas Production increased by
six percent from 2011 to 2012, to 7.4 million metric tons
C02e (MMT C02e).

•	Emissions from HCFC-22 Production and HFC-23
Destruction decreased by 37% from 2011 to 2012, to
4.3 MMT C02e. One facility was responsible for 81% of this reduction.

•	The observed decreases in emissions from HCFC-22 Production and HFC-23 Destruction
continue a long-term trend established under an EPA voluntary emission reduction
program; emissions from HCFC-22 Production and HFC-23 Destruction have decreased by
88% since 1990 under that program.

•	Due to the high global warming potentials of fluorinated GHGs, the per-facility emissions
from this sector are large, averaging 0.73 MMT C02e per facility, nearly double the GHGRP-
wide average.

About this Sector

The Fluorinated Chemicals Production Sector comprises
facilities that produce fluorinated gases. Facilities that
produce fluorinated gases must report GHG emissions
under one of two source categories: (1) fluorinated gas
production (excluding processes that generate HFC-23
during the production of HCFC-22) and (2) HCFC-22
production and HFC-23 destruction.

Fluorinated gas production consists of processes that produce a fluorinated gas (including HFCs,
PFCs, SF6, NF3, HFEs, CFCs, and HCFCs) from any raw material or feedstock chemical, except for
processes that generate HFC-23 during the production of HCFC-22. Fluorinated gases are
manufactured for use as refrigerants, foam blowing agents, insulators in electrical equipment, feed-
stocks for manufacturing synthetic polymers, and for a variety of other applications. These
fluorinated GHGs may be products, by-products, or feed-stocks for the process, and they may be
emitted from process vents, equipment leaks, container filling (including container evacuation prior
to refilling), or air pollution control devices. Hereafter, emissions from these processes may be
referred to as Subpart L emissions.

HCFC-22 production and HFC-23 destruction consists of (1) processes that produce HCFC-22 from
chloroform and hydrogen fluoride, and (2) HFC-23 destruction processes, whether the destruction
process is located at the HCFC production facility or not The GHG emissions reported are emissions
of HFC-23 generated during the production of HCFC-22. HFC-23 is a potent GHG that is generated as
a by-product during the manufacture of HCFC-22, and is either vented to the atmosphere, captured
for use in a limited number of applications, or destroyed. HFC-23 is also emitted from thermal
oxidizers during the destruction of HFC-23. Hereafter, emissions from these processes may be
referred to as Subpart 0 emissions.

HCFC-22 is primarily employed in refrigeration and air conditioning systems and as a chemical
feedstock for manufacturing synthetic polymers. HCFC-22 is an ozone-depleting substance (ODS)

All emissions presented here
are as of 9/1/2013 and
exclude biogenic C02. All
GHG emissions data
displayed in units of carbon
dioxide equivalent (C02e)
reflect the global warming
potential (GWP) values from
TPCC AR4.

Because fluorinated GHGs often
have global warming potentials
(GWPs) in the thousands,
emissions that are relatively small
in mass of a chemical can be large
in terms of C02e.

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2010-2011-2012 GHGRP Industrial Profiles

Fluorinated Chemicals

that is regulated under the Clean Air Act and the Montreal Protocol. Production of HCFC-22 for
non-feedstock uses is scheduled to be phased out completely by 2020. However, production of
HCFC-22 for use as a feedstock is allowed to continue indefinitely. Together, these two trends are
expected to result in a decline in U.S. HCFC-22 production through 2020, followed by a gradual
increase.1

Who Reports?

In total, 16 facilities in the Fluorinated Chemicals Production Sector reported in 2012. Total
reported emissions were 11.7 MMT CC^e. In 2012, the Fluorinated Chemicals Production Sector
represented 0.2% of the facilities reporting direct emissions to the GHGRP and about 0.4% of total
U.S. GHG emissions.2

Table 1: Fluorinated Chemicals Production Sector - Reporting Schedule by Subpart

Subpart

Source Category

Applicability

First Reporting
Year

L

Fluorinated Gas
Production

Facilities that would emit > 25,000 metric tons
C02e/year in the absence of emission controls.

2011

0

HCFC-22 Production,
HFC-23 Destruction

All facilities that produce HCFC-22 and facilities
not co-located with a HCFC-22 production facility
that destroy more than 2.14 metric tons of HFC-
23 per year.

2010

Table 2: Fluorinated Chemicals Production Sector - Number of Reporters (2010-2012)

Source Category

Number of Reporters

2010

2011

2012

Total Fluorinated Chemicals Production Sector

	a

16b

16b

Fluorinated Gas Production

__a

16

16

HCFC-22 Production, HFC-23 Destruction

5

5

5

a Facilities began reporting emissions under Subpart L in reportingyear 2011.

b All Subpart 0 reporters also produce other fluorinated chemicals and, therefore, also report under Subpart L. So there
are a total of 16 facilities reporting in 2011 and 2012.

Table 3: Fluorinated Chemicals Production Sector - GHGRP Coverage

Source Category

GHGRP Coverage of Industry

Estimated Percent of
Industry Facilities
Covered by GHGRP

Estimated Percent of
Industry Emissions
Covered by GHGRP

Fluorinated Gas
Production

Facilities that would emit >25,000
metric tons C02e/year in the
absence of emission controls.

89%a

>95%b

1	Sixth Climate Action Report (draft), available at:

http://www.state.gov/e/oes / climate/ccreport2 014/index.htm.

2	The total U.S. GHG emissions are 6,525.6 MMT C02e as reported in the Inventory of U.S. Greenhouse Gas
Emissions and Sinks: 1990-2012. U.S. Environmental Protection Agency. April 15, 2014. EPA 430-R-14-003.
Available at: http://www.epa.gov/climatechange/ghgemissions/usinventorvreporthtml.

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2010-2011-2012 GHGRP Industrial Profiles

Fluorinated Chemicals

Source Category

GHGRP Coverage of Industry

Estimated Percent of
Industry Facilities
Covered by GHGRP

Estimated Percent of
Industry Emissions
Covered by GHGRP

HCFC-22
Production,
HFC-23
Destruction

All facilities that produce HCFC-22,
and facilities not co-located with a
HCFC-22 production facility that
destroy more than 2.14 metric tons
of HFC-23 per year.

100%

100%

a Estimate of size of industiy was based on data reported by suppliers of fluorinated gases (GHGRP Subpart 00]. Two

fluorinated gas production facilities are estimated to fall below the Subpart L reporting threshold.
b Assuming that emissions from the two non-reporting facilities are equal to 1.5 percent of their C02e production, the
midpoint of the range of estimated emission rates for this sector3, emissions from these facilities account for less than 5
percent of total emissions from fluorinated gas production.

Reported Emissions

HCFC-22 producers and HFC-23 destruction facilities reported their emissions to the GHGRP for
reporting years 2010, 2011, and 2012. Producers of other fluorinated gases reported their
emissions in reporting years 2011 and 2012. For these reporting years, producers of other
fluorinated gases reported their total facility emissions only in C02e. However, by March 31, 2015,
facilities will provide more detailed reports for reporting years 2011 through 2014, including
chemical-specific reports of most of their emissions.

Table 4: Fluorinated Chemicals Production Sector - Emissions by Subsector (2010-2012)

Fluorinated Chemicals Production Sector

Emissions (MMT C02e)a

2010

2011

2012

Total Fluorinated Chemicals Production Sector3

N/A

13.9

11.7

Fluorinated Gas Production

N/Ab

6.1

6.6

Stationary Fuel Combustionc

N/Ab

0.9

0.7

HCFC-22 Production, HFC-23 Destruction

7.0

6.9

4.3

a Represents total emissions reported to the GHGRP from this industiy. Additional emissions may occur at facilities that

have not reported; for example, those below the reporting threshold.
b Facilities began reporting emissions under Subpart L in reporting year 2011.

c Emissions from fuel combustion are provided here for informational purposes. Generally throughout this document,

these emissions are included in the total presented for Fluorinated Gas Production.

Note: Totals may not sum due to independent rounding

3 Based on the emissions rate for HCFC-22(2006 IPCC Guidelines, Volume 3, section 3.10.2.1), which is
expected to be similar to other fluorinated GHG production processes.

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2010-2011-2012 GHGRP Industrial Profiles

Fluorinated Chemicals

Figure 1: Fluorinated Chemicals Production Sector - Emissions by Subsector (2012)

2012 TOTAL REPORTED DIRECT EMISSIONS FROM CHEMICALS
(FLUORINATED), BY SUBSECTOR (AS OF 9/1/13)

Combustion
6%

57%

Click here to view the most current information for 2012 using FLIGHT.

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2010-2011-2012 GHGRP Industrial Profiles	Fluorinated Chemicals

Figure 2: Location and Emissions Range for Each Reporting Facility in the Fluorinated
Chemicals Production Sector (as of 9/1/13)

(T^Tr-	

/ \	I	{

\

> \



< Mr L	yH,

IT&	/ \ J

\ TWw WM r

L l; J, A .\p

\	I	S X i	/ HI

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sf ^

\ / 		— I

\ P*

vV

	,			 —-A.

N			S x

\	/	if	\	*7	f ^—"w%* /

-I

X

\ L-ih

9

(metric tons CO;e)	\

y

GHGRP, 2012	^	ft

- <&> \

Fluorlnalcd Chemical Sector Emissions

r

g

•	«3».€W

•	2W.0W-5W.W0

®	SOOWO-I.QOT.WO

O	IWOuOW -1.SW.W0

0	>1.5M.W0

Data Swurco: 2012 Greenhouse Gas. Reporting Pre-gram
As OH: OOTiam

This map shows the locations of direct-emitting facilities. The size of a circle corresponds to the
quantity of emissions reported by that facility. Fluorinated chemical producers are concentrated
along the Mississippi River and its tributaries.

Readers can identify the largest emitting facilities by visiting the Facility Level Information on
Greenhouse Gases (FLIGHT) website fhttp:]_/ghgdata.epa.gov!.

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2010-2011-2012 GHGRP Industrial Profiles

Fluorinated Chemicals

Figure 3: Fluorinated Chemicals Production Sector - Emissions by State (2012)a

DIRECT EMISSIONS BY STATE FROM THE FLUORINATED
CHEMICALS SECTOR

2012 Emissions (million metric tons C02e)

Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Guam
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virgin Islands
Virginia
Washington
West Virginia
Wisconsin
Wyoming

Fluorinated GHG Production
HCFC-22 Production and
HFC-23 Destruction

a Represents total emissions reported to the GHGRP from this industiy. Additional emissions may occur at facilities that
have not reported, such as those below the reporting threshold.

Click here to view the most current information for 2012 using FLIGHT.

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2010-2011-2012 GHGRP Industrial Profiles

Fluorinated Chemicals

Fluorinated Chemicals Production Sector Emissions Trends 2010 to 2011

Emissions from HCFC-22 Production and HFC-23 Destruction were steady between 2010 and 2011.
(Fluorinated gas producers reported for the first time in 2011 and are therefore not included in this
trend).

Fluorinated Chemicals Production Sector Emissions Trends 2011 to 2012

Fluorinated Chemicals Production Sector emissions were approximately 2.2 MMT C02e lower in
2012 than in 2011 (a 16% decrease). Although emissions for Fluorinated Gas Production increased
by 0.4 MMT COze, overall emissions decreased due to a reduction of 2.6 MMT C02e in the HCFC-22
Production, HFC-23 Destruction industry. This reduction was driven both by decreased emissions
per unit production and by decreased HCFC-22 production in RY 2012.

Figure 4: Fluorinated Chemicals Production Sector - Emissions Trend (2010-2012)

ANNUAL REPORTED DIRECT GHG EMISSIONS FROM THE
FLUORINATED CHEMICALS SECTOR, BY SUBSECTOR

Click here to view the most current information using FLIGHT.

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2010-2011-2012 GHGRP Industrial Profiles

Fluorinated Chemicals

Table 5: Fluorinated Chemicals Production Sector - Emissions by GHG (MMT C02e)a

Fluorinated Chemicals Production Sector

Reporting Year

2010

2011

2012

Number of facilities

N/A

16

16

Total emissions (MMT C02e)

N/A

13.9

11.7

Emissions by GHG

Carbon dioxide (C02)

•	Fluorinated Gas Production

•	HCFC-22 Production / HFC-23 Destruction

N/A
0.6

0.9
0.0a

^ 0
0 d

Methane (CH4)

•	Fluorinated Gas Production

•	HCFC-22 Production / HFC-23 Destruction

N/A

^^b

^^b

0.0a

^^b

0.0a

Nitrous oxide (N20)

•	Fluorinated Gas Production

•	HCFC-22 Production / HFC-23 Destruction

N/A

^^b

^^b

0.0a

^^b

0.0a

Total fluorinated GHGs

•	Fluorinated Gas Production (emissions are
HFCs, PFCs, SF6, NF3, and others)

•	HCFC-22 Production / HFC-23 Destruction
(emissions are HFC-23)

N/A
6.4

6.1c
6.9

6.6C
4.3

a Subpart L facilities were required to begin reporting in reporting year 2011.

b Subpart 0 facilities are all co-located with Subpart L facilities. Combustion emissions were assigned to Subpart 0 in

2010 and to Subpart L in 2011 and 2012.
c For reporting years 2011 and 2012, Subpart L facilities were not required to report emissions of individual fluorinated

gases, but report the total CChe for the facility.

**Total reported emissions are less than 0.05 MMT CChe.

Note: Totals may not sum due to independent rounding.

Emissions from HCFC-22 Production Before 2010

From 1995 through 2010, U.S. HCFC-22 producers reported their combined HFC-23 emissions and
combined HCFC-22 production to EPA under a voluntary program. The emissions reported under
the voluntary program are comparable to those reported under the GHGRP, covering essentially the
same set of facilities (with the exception of one low-emitting HFC-23 destruction facility) and being
based on the same emission estimation methods. The HFC-23 emissions and emission rate (tons
HFC-23/ton HCFC-22) reported under the program and under the GHGRP are shown in Figure 5,
below.

The 81% decline between 1990 emissions and 2011 emissions was due to a 21% decrease in HCFC-
22 production and a 76% decrease in the HFC-23 emission rate after 1990. The decrease in the
emission rate was primarily attributable to five factors: (a) five plants that did not capture and
destroy the HFC-23 generated ceased production of HCFC-22 after 1990, (b) one plant that captures
and destroys the HFC-23 generated began to produce HCFC-22, (c) one plant implemented and
documented a process change that reduced the amount of HFC-23 generated, (d) the same plant
began recovering HFC-23, primarily for destruction and secondarily for sale, and (e) another plant
began destroying HFC-23.

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2010-2011-2012 GHGRP Industrial Profiles

Fluorinated Chemicals

Figure 5: HFC-23 Emissions and Emission Rates per unit Production Reported by U.S.
HCFC-22 Producers under Voluntary Program and GHGRP

HFC-23 EMISSIONS AND EMISSION FACTORS REPORTED BY
U.S. HCFC-22 PRODUCERS UNDER VOLUNTARY PROGRAM
AND GHGRP

HFC-23 Emissions
(million metrics tons CO,e)

 p> 05 05 c$ 05 05 05 05 05 o o o o o o o a o ^

p> P) ® 05 P5P5 05 P5P5 05 O Q C5 C5 C5 Ci	

I*V.	N	w 'V tV	<\ <\ <\ <\ <\ V	(V

2.5%

2.0%

1.5%

.0%

0.5%

0%

Due to the high global warming potentials of many fluorinated GHGs, including HFC-23, the per-
facility emissions from fluorinated gas production are relatively high, with 11 out of 16 facilities
emitting more than 100,000 MT CC^e and 4 out of 16 facilities emitting more than 1,000,000 MT
C02e. HCFC-22 Production/HFC-23 Destruction facilities reported average emissions of roughly
868,000 MT CC^e from those activities, while producers of other fluorinated gases reported
average emissions of roughly 460,000 MT C02e. However, all HCFC-22 producers also produce
other fluorinated gases, leading to average facility emissions of roughly 730,000 MT CC^e. These
figures compare to average per-facility emissions of 401,000 metric tons C02e for all GHGRP
facilities and 168,000 metric tons C02e for GHGRP facilities other than electricity generators
(Figure 6).

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2010-2011-2012 GHGRP Industrial Profiles

Fluorinated Chemicals

Figure 6: Fluorinated Chemicals Production Sector - Average Emissions

per Reporter (2012)a

AVERAGE EMISSIONS PER REPORTER FROM THE FLUORINATED
CHEMICALS SECTOR

2012 Emissions (thousand metric tons C02e)

0	200	400	600	800	1,000

HCFC-22 Production,
HFC-23 Destruction

Fluorinated Gas
Production

GHGRP Average
(Direct Emitters Only)

a All HCFC-22 Production/HFC-23 Destruction facilities also produce other fluorinated gases. Emissions from fuel
combustion from each facility are assigned to fluorinated gas production rather than to HCFC-22 production.
Emissions from fuel combustion comprise nine percent of the emissions attributed to fluorinated gas production (see
Table 4).

10


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2010-2011-2012 GHGRP Industrial Profiles

Fluorinated Chemicals

Figure 7: Number of Reporters by Total Reported Direct Emissions (2012)

(Includes emissions from both HCFC-22 and Other Fluorinated Gas Production)

NUMBER OF FACILITIES IN THE FLUORINATED CHEMICALS
SECTOR AT VARIOUS EMISSION RANGES

¦D
£

<0,03

0.03-0.06 0.06-0.10 0.10-0.25	0.25-1

2012 Emissions (million metric tons CO,e)

1 -3

>3

11


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2010-2011-2012 GHGRP Industrial Profiles

Fluorinated Chemicals

Figure 8: Percentage of Reporters by Range of Emissions (2012)

PERCENTAGE OF FACILITIES IN THE FLUORINATED CHEMICALS
SECTOR AT VARIOUS EMISSION RANGES

0
Ui

c

(0
DC

"D

1,000

2012 Emissions (thousand metric tons C02e)

Table 6: Fluorinated Chemicals Production Sector - Emissions by Facility,
by Subsector (2012)a

Name

Emissions
(MMT
C02e)

Location

Fluorinated Gas Production

Arkema, Inc.

2.6

Calvert City, KY

3M Cordova

1.4

Cordova, IL

DuPont Washington Works

0.94

Washington, WV

Honeywell International Inc - Geismar Complex

0.73

Geismar, LA

Air Products

0.39

Tamaqua, PA

Daikin America, Inc.

0.32

Decatur, AL

Honeywell International, Inc. Baton Rouge

0.23

Baton Rouge, LA

DuPont Fayetteville Works

0.14

Fayetteville, NC

DuPont Chambers Works

0.14

Deep water, NJ

Mexichem Fluor

0.13

Saint Gabriel, LA

Anderson Development Co

0.097

Adrian, MI

DuPont El Dorado

0.091

El Dorado, AR

3M Decatur

0.055

Decatur, AL

DuPont - Corpus Christi Plant

0.039

Gregory, TX

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2010-2011-2012 GHGRP Industrial Profiles

Fluorinated Chemicals

Name

Emissions
(MMT
C02e)

Location

DuPont Louisville

0.032

Louisville, KY

3M Cottage Grove Center

0.022

Cottage Grove, MN

HCFC-22 Production, HFC-23 Destruction

DuPont Louisville Works

2.6

Louisville, KY

Honeywell International Inc - Baton Rouge Plant

1.7

Baton Rouge, LA

Honeywell International Inc - Geismar Complex

<0.01

Geismar, LA

Daikin America, Inc.

<0.01

Decatur, AL

DuPont Washington Works

<0.01

Washington, WV

This table lists all facilities that submitted reports for reporting year 2012.

Figure 9: Fluorinated Chemicals Production Sector Total Facility Emissions (MMT C02e) by

Year3

ANNUAL REPORTED EMISSIONS FOR FACILITIES IN THE
FLUORINATED CHEMICALS PRODUCTION SUBSECTOR

O
O


C

o

0
£
c
o


c
o

2011

2012

r^



eK >° c/	<*°

\S) K0° ^ ^ ^

^ # c*°

rv-





\0°"

\Cf
(?>



^ ks	<*•

4/ ^



v

&

&

F 
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2010-2011-2012 GHGRP Industrial Profiles

Fluorinated Chemicals

Figure 10: HCFC-22 Production / HFC-23 Destruction Total Facility Emissions (MMT C02e) by

Year

ANNUAL REPORTED EMISSIONS FOR FACILITIES IN THE
HCFC-22 PRODUCTION / HFC-23 DESTRUCTION SUBSECTOR

o
a


c
o



£

¦¦

2010

~

2011

~

2012

Daikin America,
Inc.

DuPont
Louisville

DuPont
Washington

Honeywell
Baton Rouge

Honeywell
Geismar

Calculation Methods Used

The production of fluorinated chemicals results in both process-related emissions (fluorinated
greenhouse gas emissions from manufacturing and gas destruction processes) and fuel combustion
emissions (CCh, CH4, and N2O from the burning of fuel for energy).

Stationary Fuel Combustion Emissions

Facilities must report any emissions from stationaly fuel combustion sources by following the
calculation methods of 40 CFR part 98, Subpart C (General Stationary Combustion Sources). The
calculation methodologies for Subpart C are explained here.

Process Emissions

Facilities in the Fluorinated Chemicals Production Sector can use one of several different
methodologies to report their process emissions, depending on the subsector.

For HCFC-22 Production and HFC-23 destruction (Subpart 0), facilities use different calculations to
estimate HFC-23 emissions depending upon whether or not the facility has an HCFC-22 production
process that is directly connected to a destruction device.

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2010-2011-2012 GHGRP Industrial Profiles

Fluorinated Chemicals

•	Process Measurements - This method is used by facilities whose HCFC-22 production
processes are not directly connected to a destruction device. The generation of HFC-23 is
measured in the process, and a mass balance is performed to determine the amount emitted
after accounting for any HFC-23 destroyed on site, sent offsite for destruction or for sale, or
added to an on-site inventory.

•	Emissions Measurements - This method is used by facilities whose HCFC-22 production
processes are directly connected to a destruction device. An emissions test is required for
the process vents every five years, and the results of the emissions test are used to estimate
process vent emissions. These process vent emissions are added to estimates of emissions
from equipment leaks and from destruction processes.

•	Emissions from Destruction Devices - This method is used by facilities that destroy HFC-
23 but do not contain an HCFC-22 production process.. The destruction efficiency (DE) of
the destruction device is multiplied by the amount of HFC-23 fed into the device to calculate
the amount destroyed and the emissions from the device. The results are used to estimate
emissions under the "Emissions Measurements" method, under the "Process
Measurements" method (if applicable), or from destruction devices that are not co-located
with HCFC-22 production processes. The DE must be equated to the DE determined during
a new or previous performance test of the destruction device. The DE of the destruction
device must be confirmed annually, and if necessary, revised.

Table 7: HCFC-22 Production, HFC-23 Destruction - Methodologies

Type of
Emissions

Methodology

Percentage of Emissions Monitored
by Method (by Type)

2010

2011

2012

Process
Emissions

Process measurements

51.4%

67.9%

60.3%

Emissions measurements

48.6%

32.0%

39.2%

Destruction processes that are not co-located
with HCFC-22 production processes

<0.1%

0.1%

0.5%

Combustion
Emissions

Measured high heating values (HHVs) and
default emission factors (Tier 2)

82.5%

N/Aa

N/Aa

Default HHVs and emission factors (Tier 1)

17.5%

N/Aa

N/Aa

a N/A indicates not applicable, as each of the facilities that reported under Subpart 0 in RY 2010 subsequently reported
under Subpart L in RY 2011 and RY 2012, and the combustion emissions reported under Subpart C for these facilities in
RY 2011 and RY 2012 are attributed to Subpart L, Fluorinated GHG Production.

For fluorinated gas production (Subpart L), facilities may estimate fluorinated GHG emissions using
a mass-balance approach, an emission factor approach, or an emission calculation factor approach.
Emissions must also be calculated for destruction processes and for venting of residual gas from
containers. Emissions for the year 2011 and 2012 were reported in CO 2e only. For fluorinated
GHGs that do not have a global warming potential listed in Table A-1, facilities are required to use
either a default GWP or their best estimate of the GWP.

•	Mass-balance - The mass balance approach may be used if the facility meets the error
criteria specified in the rule for measuring each of the process inputs and outputs.

•	Process-vent-specific emission factors - For vents from continuous processes with
annual controlled emissions greater than 10,000 MT CC^e, emissions testing is required to
establish an emission factor. Equipment leak estimates must also be made.

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2010-2011-2012 GHGRP Industrial Profiles

Fluorinated Chemicals

• Process-vent-specific emission calculation factors - For vents from batch processes and
vents from continuous processes with annual controlled emissions of less than 10,000 MT
CC>2e, engineering calculations or assessments may be used to establish a vent-specific
emission factor. Equipment leak estimates must also be made.

Table 8: Fluorinated Gas Production - Methodologies

Type of Emissions

Methodology

Percentage of Emissions
Monitored by Method (by
Type)





2010*

20 \\

2012

Process Ventb

Emission factors (vent test)

-

4.2%

3.7%

Emission calculation factors

-

16%

13%



Average emission factor approach

-

51%

15%



Screening ranges approach with
Method 21

-

0.62%

0.05%



EPA Correlation approach with Method
21

-

3.2%

1.9%

Process -
Equipment Leak
Estimation

Screening range approachd

-

>0%

>0%

EPA Correlation approach in
conjunction with site-specific leak
monitoring methodd

-

>0%

>0%



Unit specific correlation approach in
conjunction with site specific leak

..

>0%

>0%



monitoring methodd









Other site specific leak monitoring
methods

-

17%

17%

Fuel Combustion

Measured high heating values (HHVs)
and default emissions factors (Tier 2)



65.0%

68.8%

Default HHVs and emission factors



35.0%

31.2%



(Tier 1)



a The initial reporting year for Subpart L facilities was RY 2011.

b For RY2011, this table covers approximately 20% of the process emissions. The balance of emissions in the Subpart L
source category occur at facilities that use more than one mass emission method, i.e. both process vent emission factors
and process vent emission calculation factors; these facilities using more than one method account for approximately
80% of emissions for RY2011.
c For RY2011, the table covers approximately 72% of the equipment leak emissions, and the balance of emissions from
EL in the Subpart L source category occur at facilities that use more than one EL method to estimate these emissions.
These facilities using more than one method account for 28% of EL emissions in RY2011.
d All facilities that used each of these methodologies also used additional equipment leak methods; while we can confirm
that some emissions could be apportioned for these methods, we are not able to determine the percentage of emissions
calculated for these methodologies.

Best Available Monitoring Methods (BAMM)

During the first year that the GHGRP applied, facilities were allowed to optionally use a best
available monitoring method (BAMM) to determine emission inputs for specific emissions sources
for a limited amount of time. The use of BAMM was allowed because it was not always feasible for a
newly subjected facility to acquire, install, and operate all of the required monitoring equipment by
the date required by the GHGRP. EPA's BAMM provision provided time for these facilities to replace
their equipment in a way that could minimize impacts to normal business operations. Subpart 0
facilities were allowed to use BAMM from Januaryl, 2010 to March 31, 2010. Subpart L facilities

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were allowed to use BAMM from January 1, 2011 to June 30, 2011 and under limited circumstances
thereafter. Learn more about BAMM.

Table 16: BAMM Use as Percent of Facilities

BAMM Use

2010

2011

2012

Fluorinated Gas Production

N/A

19%

12%

HCFC-22 Production, HFC-23 Destruction

20%

Not allowed

Not allowed

Data Verification and Analysis

As a part of the reporting and verification process, EPA evaluates annual GHG reports with
electronic verification checks. EPA contacts facilities regarding potential reporting issues. Statistics
related to EPA's verification of reports from this sector are provided below. Additional information
on EPA's verification process is available here.

Potential for Emission Reductions
HCFC-22 Production and HFC-23 Destruction

Options for reducing emissions of fluorinated GHGs from fluorinated chemical production include
process optimization (e.g. to decrease generation of by-products), destruction (e.g., thermal
oxidation and plasma arc), capture (which only delays emissions unless the captured gas is later
transformed, used to displace other fluorinated GHG products, or destroyed), recovery rather than
venting of residual fluorinated GHG products in returned containers, and leak detection and repair
(for emissions from equipment leaks).

As discussed above, HCFC-22 producers have greatly reduced both their HFC-23 emissions and
their HFC-23 emissions rate per unit production (tons HFC-23/ton HCFC-22) since 1990. To reduce
the emission rate one producer has optimized the HCFC-22 production process to reduce the
generation of the HFC-23 by-product, and all producers have implemented HFC-23 destruction
programs, to varying extents. As a result of these efforts, 2012 HFC-23 emissions were
approximately one fifth as large as they would be if facilities had continued to emit at the 1990 rate.
Nevertheless, opportunities for significant additional reductions remain. According to the report,
Global Mitigation of Non-CO2 Gases, consistent use of HFC-23 destruction devices can reduce
uncontrolled emissions by 95%.4 This implies that the current U.S. emission factor could be
reduced by an additional 75%, resulting in reductions of approximately 3 MMT CC^e. According to
Global Mitigation ofNon-C02 Gases, the cost of HFC-23 destruction is between $0 and $1 per ton of
CC>2e reduced.

Less is known regarding the potential for reducing emissions from production of fluorinated gases
other than HCFC-22. Production processes for different fluorinated gases are believed to have
significantly varying by-product generation rates and emission rates, and relatively little
information is available on these rates and the extent to which they have already been decreased.
At least some facilities are known to employ destruction devices to decrease emission rates.
However, as is true for HCFC-22 production, opportunities for significant additional reductions (i.e.
several MMT CC^e) are likely to exist

4 Global Mitigation of Non-C02 Greenhouse Gases: 2010-2030. EPA Publication No. EPA-430-R-13-011.
September 2013.

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GLOSSARY

CFCs mean chlorofluorocarbons. CFCs are gases covered under the 1987 Montreal Protocol and
used for refrigeration, air conditioning packaging, insulation, solvents, or aerosol propellants. Since
they are not destroyed in the lower atmosphere, CFCs drift into the upper atmosphere where, given
suitable conditions, they break down ozone.

BAMM means Best Available Monitoring Methods. Facilities approved for BAMM may use best
available monitoring methods for any parameter (e.g., fuel use, feedstock rates) that cannot
reasonably be measured according to the monitoring and QA/QC requirements of a relevant
subpart

FLIGHT refers to EPA's GHG data publication tool, named Facility Level Information on Greenhouse
Gases Tool fhttp: //ghgdata.epa.govl.

Fluorinated greenhouse gas means sulfur hexafluoride (SF&), nitrogen trifluoride (NF3), and any
fluorocarbon except for controlled substances as defined at 40 CFR part 82, Subpart A and
substances with vapor pressures of less than 1 mm of Hg absolute at 25 degrees C. With these
exceptions, "fluorinated GHG" includes but is not limited to any hydrofluorocarbon, any
perfluorocarbon, any fully fluorinated linear, branched or cyclic alkane, ether, tertiary amine or
aminoether, any perfluoropolyether, and any hydrofluoropolyether.

Fluorocarbons: Carbon-fluorine compounds that often contain other elements such as hydrogen,
chlorine, or bromine. Common fluorocarbons include chlorofluorocarbons (CFCs),
hydrochlorofluorocarbons (HCFCs), hydrofluorocarbons (HFCs), and perfluorocarbons (PFCs).

Fluorinated gas means any fluorinated GHG, CFC, or HCFC.

GHGRP means EPA's Greenhouse Gas Reporting Program (40 CFR part 98).

GHGRP vs. GHG Inventory: EPA's Greenhouse Gas Reporting Program (GHGRP) collects and
disseminates annual greenhouse gas data from individual facilities and suppliers across the U.S.
economy. EPA also develops the annual Inventory of U.S. Greenhouse Gas Emissions and Sinks (GHG
Inventory) to track total national emissions of greenhouse gases to meet U.S. government
commitments to the United Nations Framework Convention on Climate Change. The GHGRP and
Inventory datasets are complementary and may inform each other over time. However, there are
also important differences in the data and approach. For more information, please see
http://www.epa.gov/climatechange/ghgemissions/usinventoryreporthtml.

HFC means hydrofluorocarbon, which refers to compounds containing only hydrogen, fluorine, and
carbon atoms. HFCs are primarily used as alternatives to ozone depleting substances, e.g., as
refrigerants and foam blowing agents. In addition, HFCs are emitted as by-products of industrial
processes and are also used in magnesium production and processing. They do not significantly
deplete the stratospheric ozone layer, but they are powerful greenhouse gases.

HFE means hydrofluoether, which is a complex organic solvent that was developed originally as a
replacement for CFCs, HFCs, HCFCs, and PFCs.

Hydrochlorofluorocarbons (HCFCs) are compounds containing hydrogen, fluorine, chlorine, and
carbon atoms. Although ozone depleting substances, they are less potent at destroying
stratospheric ozone than chlorofluorocarbons (CFCs). They have been introduced as temporary
replacements for CFCs and are also greenhouse gases.

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IPCC AR4 refers to the Fourth Assessment Report by the Intergovernmental Panel on Climate
Change. Climate Change 2007: The Physical Science Basis. Contribution of Working Group I to the
Fourth Assessment Report of the Intergovernmental Panel on Climate Change [Core Writing Team,
Pachauri, R.K. and Reisinger, A. (eds)]. IPCC, Geneva, Switzerland2007. The AR4 values also can be
found in the current version of Table A-l in Subpart A of 40 CFR part 98.

NF3 means nitrogen trifluoride, a powerful greenhouse gas that is used in electronics
manufacturing.

MMT means million metric tons.

PFC means perfluorocarbon. Perfluorocarbon refers to a group of chemicals composed of carbon
and fluorine only. These chemicals (predominantly CF4 and C2F6) are emitted as by-products of
industrial processes and are also used in manufacturing. In addition, PFCs were introduced as
alternatives, along with hydrofluorocarbons, to the ozone depleting substances. PFCs do not harm
the stratospheric ozone layer, but they are powerful greenhouse gases that remain in the
atmosphere for thousands of years.

SF6 means sulfur hexafluoride. Sulfur hexafluoride is a very powerful greenhouse gas used
primarily as an electrical insulator in electrical transmission and distribution systems and as a
dielectric in electronics.

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