### 1 MEMORANDUM

TO : Debbie Ottinger , EPA

FROM : Carrie Richardson Fry and Karen Schaffner, RTI

DATE : November 6 , 2013

SUBJECT : Economic Analysis of Proposed Amendments to the Greenhouse Gas Reporting Rule for the Fluorinated Gas Production Source Category (Subpart L)

Proposed changes to subpart L, Fluorinated Gas Production

, of the Greenhouse Gas Mandatory Reporting Rule (GHG MRR) were evaluated to determine their economic impact on subpart L facilities . The proposed changes to subpart L include changes to the reporting requirements, the removal of the option to use the mass

- balance approach, and the establishment
of a new set of default GWPs for fluorinated GHGs that are not currently listed on Table A

- 1 of subpart A.

Impact of Subpart L Amendments on S ubpart L Reporters

. Changes to Reporting Requirements

. The proposed changes to the subpart L Fluorinated Gas Production source category would replace many of the current reporting requirements with requirements to report at a higher level of aggregation. In a few cases, reporting requirements would be removed but not replaced. Table 1 lists each of the reporting elements i n the current
rule th at EPA is proposing to remove or revise, the information provided by that reporting element, the reporting element (if any) with which EPA would replace the current reporting element, the information provided by that revised reporting element, and the expe cted net impact on reporter burden. Table 2 lists each of the other provision s in the current rule that EPA is proposing to remove or revise, the provision (if any) with w hich EPA would replace the current provision

, and the expected net impact on reporter burden. Note that in some cases, there is not a perfect one

- to

- one correspondence between the current and proposed elements; the column summarizing the impact on burden notes where the revised reporting element may be related to multiple current elements

. We have concluded that the changes to the reporting requirements would not result in a

net increase in the burden associated with reporting under subpart L. In most instances

, the revised reporting requirement would simply replace or update an existing requirement to be consistent with changes to the rule without adding additional steps or requirements that would significantly increase bu rden. In some cases the new rule requirements would actually decrease
burden. Where changes might result in a small ne t increase in burden for a particular

### 2 requirement , this increase is expected to be offset by the decrease in burden for other reporting requirements.

Mass Balance Approach

. In the current subpart L rule, facilities may choose from two options for calculating GHG emissions: the mass balance ( MB ) approach, and the emission
factor or emission calculation factor (EF/ECF) approach. EPA is proposing to amend subpart L

to remove th e option to use the MB approach from the calculation and monitoring requirements
of the rule

. Facilities would be able to use the EF/ECF approaches to monitor, calculate, and report fluorinated GHG emissions. Based on reporting in the electronic Greenhou se Gas Reporting Tool (eGGRT), no facilities are currently using the MB approach to estimate
emissions but rather are using the EF/ECF approach

. 1 

### However, a few facilities used the MB approach in RY 2011. To address disclosure concerns that could be associ ated with reporting these RY 2011 emissions in detail, EPA is proposing to amend the reporting requirements associated with the MB approach; those changes are analyzed in Table 1

. The initial economic evaluation for subpart L was presented in the November 2010 “Economic Impact Analysis for the Mandatory Reporting of Greenhouse Gas Emissions F

Gases: Subparts I, L, DD, QQ, SS.” In the initial economics evaluation, EPA assumed that the majority of affect ed facilities would use the EF/ECF approach and that a small percentage would

use the MB approach. Modifying the analysis to reflect that all covered facilities would use the EF/ECF approach results in less than a one percent (1%) increase in overall calculated costs to the industry.

Clarification of Emission Factor Method. In the current version of subpart L, those facilities choosing to use process vent testing as specified in §98.124(c)(1) are required to test for
all fluorinated GHGs that occur in more than trace concentrations in the vent stream. EPA is

p roposing to require process vent testing for all fluorinated GHGs that were identified in the initial scoping speciation or that are otherwise known to occur in the vent stream. We have concluded that any impacts on these facilities were accounted for in the initial economic analysis for subpart L. The initial economic analysis assumed that facilities would test for and report (as applicable) all fluorinated GHGs identified in the scoping speciation. In addition, the cost of testing for gases identified in the scoping speciation that facilities have not already tested for should be relatively small because the gases’ spectra have already been identified in the scoping speciation and because testing is already being performed for other fluorinated GHGs. The addition of the requirement to assume an emissions level of half the detection limit for all

1 A few facilities have indicated in their annual reports in eGGRT that they use the MB approach, however, in follow

- up discussions with the facilities regarding the calculat ion methods used, EPA confirmed that no facilities are actually using the MB approach. These few facilities re

- submitted their annual reports for RY2012 to indicate that the EF/ECF approach was used to estimate and report fluorinated GHG emissions.

### 3 fluorinated GHGs that are not found when conducting a process vent test but that were present at the scoping speciation is expected to result in very little addit ional burden.

Impact of Added Default GWPs on Subpart L Rule Applicability

. I n Table L

- 1 of subpart L

, EPA is proposing default GWPs based on five fluorinated GHG chemical groups

. Facilities would apply these default GWPs to fluorinated GHGs that do not have GWPs listed in
Table A

- 1 for purposes of determining whether the facility exceeds the threshold for reporting under subpart L. We have concluded that the applicability of su bpart L , as determined in §98.2(a) and §98.121, would not be affected by EPA’s proposed addition of the default GWPs

, because all of the fluorinated gas production facilities emitting GHGs that are not currently
included in Table A

- 1 are already expected t o be above the threshold.

Impact of Added Default GWPs on Other Subpart L Provisions

. Other than the general threshold for reporting under subpart L at § 98.2(a)(2), t here is one threshold in subpart L that
rel ies on CO 2 

### e emissions to determine applicabili ty of rule requirements. In particular, the preliminary calculation in § 98.123(c) (1) and the method selection in §98.123(c)(2) may be
affected. In § 98.123(c) (1) and (2), facilities determine whether process vents are above or below
the threshold of 10,00 0 mtCO 2 

### e, with those below the threshold being required to either conduct emissions testing or conduct calculations, and those above the threshold being required to conduct emissions testing for developing an EF for the process vent.

Under the current subp art L rule, for fluorinated GHG s that do not have a GWP listed in
Table A

- 1 of subpart A, facilities must use a default GWP of 2000 for the preliminary
calculation in § 98.123(c) (1)

. EPA is proposing to amend § 98.123 (a) to refer to the default
GWPs in Table L

- 1 of subpart L , which range from 1 to 10,000. The default GWP of 10,000 would be applied to fully fluorinated GHGs. Thus, facilities that emit fully fluorinated GHGs are most likely to be affected by the revision of the default GWP s at § 98.123 (c) (1)

. We know from annual reporting in eGRRT that four to five facilities may emit these compounds and use
the default GWP.

We have concluded that any impacts on these facilities were accounted for in the initial
economic a nalysis for subpart L. The initial economics evaluation for s ubpart L assumed that the affected facilities were using GWPs that accurately reflected the actual GWPs of the emitted compounds when performing the applicability calculations required as a part of the s ubpart L
rule. We assumed t he facilities were accurately calculating their CO 2 

### e emissions and that all process vents were appropriately categorized above or below the cutoff . T herefore the revision of
the default GWPs in § 98.123 (a) is not expected to increase the costs incurred by subpart L facilities above those initially calculated for subpart L

.

### 4 Table 1. Comparison of Original Reporting Elements in the Subpart L Rule vs. the Proposed Reporting Elements (Long

- term Subpart L Rule Changes)

Original Reporting Element( s) Information Provided by Reporting Element(s) Revised or Replacement Re porting Element Information Provided by Revised Element(s) Net Impact on Burden §98.126(a) (Intro paragraph): All facilities, in addition to the information required by §98.3(c), you must report the information in paragraphs (a)(2) through (a)(6) of this section. Introductory paragraph. Proposed §98 .126(a)( Intro paragraph) : All facilities, in addition to the information required by §98.3(c), you must report the information in paragraphs (a)(2) through (a)(7) of this section according to the schedule in p aragraph (a)(1) of this section, except as otherwise provided in paragraph (j) of this section or in §98.3(c)(4)(vii) and Table A

- 7 to subpart A of this part. Introductory paragraph. No change in burden.

§98 .126(a)(1): The information in paragraphs (a)(2), (5), and (6) of this section must be reported annually. The information in paragraphs (a)(3) and (4) of this section must be reported once by March 31, 2012 for each process and operating scenarios that operates betw een D ecember 31, 2010 and December 31, 2011. For other processes and operating scenarios, the information in paragraphs (a)(3) and (4) of this section must be reported once by March 31 of the year following the year in which the process or operating scena rio commences or

recommences. Frequency of reporting under §98.126(a). Proposed §98 .126(a)(1): The information in paragraphs (a)(2), (3), (4), (5), (6), and (7) of this section must be reported annually. Frequency of reporting under §98.126(a). No change in burden. Facilities continue to report general information annually. (See below for discussion of revisions to individual subparagraphs.)

§98 .126(a)(6) : The chemical formula of the fluorinated gas product in metric tons, by chemical and process. P rocess identification by product of process Proposed §98 .126(a)(2): For each production and transformation process at the facility, you must: Process identification by process type, subtype, and letter or number Little or no net change. Process type already required under §98.126(a)(2)(i) and (ii). Product no longer identified;

### 5 Original Reporting Element( s) Information Provided by Reporting Element(s) Revised or Replacement Re porting Element Information Provided by Revised Element(s) Net Impact on Burden (i) Provide a number, letter, or other identifier for the process. (ii) Indicate whether the process is a fluorinated gas production process, a fluorinated gas transformation process where no fluorinated GHG reactant is produced at another facility, or a fluorinated gas transformation process where one or more fluorinate d GHG reactants are produced at another facility; and (iii) Indicate whether the process could be characterized as reaction, distillation, or packaging (include all that apply). instead, process subtype and letter or number are provided.

§98 .126(a)(2)(i): Total mass in metric tons of each fluorinated GHG emitted from each fluorinated gas production
process

.
§98 .126(a)(2)(ii) : Total mass in metric tons of each fluorinated GHG emitted from each fluorinated gas transformation
process that is not part of a fl uorinated gas production process, except report separately fluorinated GHG emissions from transformation processes where a fluorinated GHG reactant is produced at another facility. Emissions by process and chemical; identification of process type Proposed §98.126(a)(3) : For facilities that produce multiple products : For each generically identified process and each fluorinated GHG group , report the total GWP

- weighted emissions of all fluorinated GHGs in that group emitted from the process , in metric tons C O 2 e. Emissions by process and fluorinated GHG group, referencing proposed §98.126(a)(2) identification of process type Little or no net change. Subpart A already requires calculation of CO 2 e for each chemical. Slight burden increase associated with adding up CO 2 e emissions of each chemical to report emissions by fluorinated GHG group. Slight burden decrease associated with reporting maximum of five fluorinated GHG groups rather than larger number of individual chemicals.

### 6 Original Reporting Element (s) Information Provided by Reporting Element(s) Revised or Replacement Reporting Element(s) Information Provided by Revised Element(s) Net Impact on Burden §98 .126(a)(2)(i) : Total mass in metric tons of each fluorinated GHG emitted from all fluorinated
gas production processes combined

.
§98 .126(a)(2)(ii) : Total mass in metric tons of each fluorinated GHG emitted from all fluorinated gas transformation processes combined , except report separately fluorinated GHG emissions from transformation processes where a fluorinated GHG reactant is produced at another facility. Emissions by process type and chemical Proposed §98 .126(a)(4)(i) : For facilities with multiple fluorinated gas products : For each fluorinated GHG with emissions of 1,000 metric tons of CO 2 e or more from the facility as a whole, the total mass in metric tons of the fluorinated GHG emitted from the facility as a whole

. Emissions by facility and chemical Little or no net change. Subpart A already requires calculation of CO 2 e for each chemical . Slight burden increases associated with assessment of whether emissions are over or under threshold and with adding up CO 2 e emissions of each chemical to report emissions by fluorinated GHG group. Slight burden decrease associated with reporting maximum of five fluorinated GHG groups rather than larger number of individual chemicals. Proposed §98 .126(a)(4)(ii) : For facilities with multiple fluorinated gas products : Aggregated emissions of all other fluorinated GHGs by fluorinated GHG grou p for the facility as a whole in metric tons of CO 2 e. Emissions by facility and fluorinated GHG
group

Proposed §98 .126(a)(5) : Where facilities produce only one fluorinated gas product but emissions consist of a major fluorinated GHG constituent of that fluorinated gas product, and the product is sold or transferred to another person: total mass in metric tons of each fluorinated GHG emitted that is a major fluorinated GHG constituent of the product. Emissions by facility and chemical Small bu rden increase possibly associated with consulting records to assess whether emissions consist of a major fluorinated GHG constituent of a product that is sold or transferred to another person. (Chemical analysis of each product that contains more than one fluorinated GHG is already required under subpart OO at §98.414(n)). Proposed §98 .126(a)(5) : Where facilities produce only one fluorinated gas product and either emissions are not a major fluorinated GHG constituent of that product or the product is n ot sold or transferred : Aggregated Emissions by facility and fluorinated GHG
group Little or no net change. Small burden increase possibly associated with consulting records to assess whether emissions consist of a major fluorinated GHG constituent of a product that is sold or

### 7 Original Reporting Element (s) Information Provided by Reporting Element(s) Revised or Replacement Reporting Element(s) Information Provided by Revised Element(s) Net Impact on Burden
GWP

- weighted emissions of fluorinated GHGs by fluorinated GHG group for the facility as a whole , in metric tons of CO 2 e. transferred to another person. (Chemical analysis of each
p roduct that contains more than one fluorinated GHG is already required under subpart OO at §98.414(n)). Subpart A already requires calculation of CO 2 e for each chemical. Slight burden increase associated with adding up CO 2 e emissions of each chemical to r eport emissions by fluorinated GHG group. Slight burden decrease associated with reporting maximum of five fluorinated GHG groups rather than larger number of individual chemicals. §98 .126(a)(2)(iii) : T otal mass in metric tons of each fluorinated GHG emi tted from 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. Emissions by process type and chemical. No change except renumbered

as Proposed 126(a)(6)(i)

. No change. No change in burden.

§98 .126(a)(2)(iv) : T otal mass in metric tons of each fluorinated GHG emitted from venting of residual fluorinated GHGs from containers returned from the field Emissions by container size and type and chemical. No change except renumbered

as Proposed 126(a)(6)(ii). No change. No change in burden.

§98 .126(a)(3) : The chemical identities of the contents of the stream(s) (including process, Preliminary identification of fluorinated GHGs that may be emitted from the Reporting requirement removed from rule; data element kept as record. NA Decrease in burden.

### 8 Original Reporting Element (s) Information Provided by Reporting Element(s) Revised or Replacement Reporting Element(s) Information Provided by Revised Element(s) Net Impact on Burden emissions, and destroyed streams)

an alyzed under the initial scoping speciation of fluorinated GHG at § §98 .124(a), by process. process.

§98 .126(a)(4) : The location and function of the stream(s) (including process streams, emissions streams, and destroyed streams) that were analyzed under the initial scoping speciation of fluorinated GHG at §98.124(a), by process. Background on preliminary identification of fluorinated GHGs t hat may be emitted from the
process. Reporting requirement removed from rule; data element kept as record. NA Decrease in burden.

§98 .126(a)(5) : The methods used to determine the mass emission s of each fluorinated GHG, i.e., mass balance, process

- vent

specific emission factor, or
process

- vent

- specific emission calculation factor, at the facility. If you use the process

- vent

specific emission factor or
process

- vent

- specific emission calculation factor method, report the methods used to estimate emissions from equipment leaks. Calculation method used for each process

, process vent , and fluorinated GHG

. Proposed §98 .126(a)(2)(iv) : For each generically

- identified process and each fluorinated GHG gr oup, report the methods used to determine the mass emissions of that fluorinated GHG group from that process from vents, i.e., mass balance,
process

- vent

- specific emission factor, or process

- vent

- specific emission calculation factor.

Proposed §98 .126(a)(2)(v) : For each generically

- identified process and each fluorinated GHG group, report the method(s) used to determine the mass emissions of that fluorinated GHG group from that process from equipment leaks , unless you used the mass balance approac h

. Calculation method used for each process, process vent, and fluorinated GHG group. No change in burden. The emissions monitoring and calculation approach was already required to be reported by process, emission type, and speciated fluorinated GHG, and is proposed to be reported by generic process, emission type, and fluorinated GHG
group.

§98 .126(a)(6) : The total mass produced of the fluorinated gas product in metric tons, by Allows calculation of an implied emission factor (emis sions/production)

, Proposed §98 .126(a)(7) : For each generically identified process, the range, based on Provides insight into the level of emissions control for the process. Slight increase in burden. Facilities are already required to determine the destruction

### 9 Original Reporting Element (s) Information Provided by Reporting Element(s) Revised or Replacement Reporting Element(s) Information Provided by Revised Element(s) Net Impact on Burden chemical and process. which provides a means of comparing the emissiveness of processes that have different production levels. Emissiveness may vary due to inherent process differences (e.g., byproduct generation rates) or due to different levels of emission s control. Table L

- 2, that encompasses the effective destruction efficiency calculated for that process on a CO 2 e basis.

Other related rule paragraphs: Proposed §98 .123(h)

. efficiency of the destruction device by fluorinated GHG, and are also already required to track the up

- time or down

time of the destruction device. The proposed reporting requirement will require some calculation s from these data to determine the effective destruction efficiency and to categorize as one of the ranges in the proposed rule. §98 .126(b)(Intro paragraph) : For processes whose emissions are determined using the mass

balance approach under §98.123(b), you must report the information listed in paragraphs (b)(1) through (b)(13) of this section for each process on an annual basis. Identify and separately report fluorinated GHG emissions from transformation processes where the fluorinated GHG reactants are produced at another facility. If you use an element other than fluorine in the mass

- balance equation pursuant to §98.123(b)(3), s ubstitute that element for fluorine in the reporting requirements of this paragraph. General reporting for mass balance approach. §98.126(b)(Intro paragraph) : Mass balance reporting must be conducted for RY2011, RY2012, RY2013, and RY2014, as applicable

. For processes whose emissions are determined using the mass

- balance approach under §98.123(b), you must report the information listed in paragraphs (b)(1) and (b)(2) of this section for each process on an annual basis. Amends the general reporting for mass balance approach for
years prior to RY2015. See accompanying memorandum, “Economic Analysis of Amendments to Subpart L Reporting Provisions” for a discussion of the impact of removing the option to use the mass balance approach. The changes to individual reporting requirements for the mass balance approach are discussed below.

§98 .126(b)(1) : For processes whose emissions are determined using the mass balance approach

, on an annual basis, if you Verifies compliance with Mass Bala nce error limits; indicates data quality; permits Proposed §98 .126(b)(1) : For processes whose emissions are determined using the mass balance approach , on an annual Verifies compliance with Mass Balance error limits and indicates data quality Slight reduction in burden. No longer required to report inputs for each calculation.

### 10 Original Reporting Element (s) Information Provided by Reporting Element(s) Revised or Replacement Reporting Element(s) Information Provided by Revised Element(s) Net Impact on Burden
calculate the relative and absolu te errors under §98 .123(b)(1), the absolute and relative errors calculated under paragraph §98.123(b)(1) report , as well as the data used in these calculations, including quantities and their accuracies and precisions. a verification of error calculation. basis, i f you calculated the relative and absolute erro rs under the former §98.123(b)(1), the overall absolute and relative errors calculated for the process under the former §98.123(b)(1), in tons and decimal fraction, respectively. a

§98.126(b)(3)

- (b)(5)

(3) The mass and chemical formula of each fluorinated GHG reactant emitted from the process in metric tons.

(4) The mass and chemical fo rmula of the fluorinated GHG product emitted from the process in metric tons.

(5) The mass and chemical formula of each fluorinated GHG by

- product emitted from the process in metric tons. Emissions by process and chemical Proposed §98.126(a)(3) : For facilities that produce multiple products : For each generically identified process and each fluorinated GHG group , report the total GWP

- weighted emissions of all fluorinated GHGs in that group emitted from the process , in metric tons CO 2 e. Emission s by process and fluorinated GHG group, referencing proposed §98.126(a)(2) identification of process type Little or no net change. Subpart A already requires calculation of CO 2 e for each chemical. Slight burden increase associated with adding up CO 2 e emiss ions of each chemical to report emissions by fluorinated GHG group. Slight burden decrease associated with reporting maximum of five fluorinated GHG groups rather than larger number of individual chemicals.

§98.126(b)(6)

- (b)(8)

(6) The mass and chemical formula of each fluorine

containing reactant that is fed into the process (metric tons). a

(7) The mass and chemical formula of each fluorine

containing product produced by In conjunction with current §98.126(b)(3)

- (b)(5) and §98.126(b)(10)

- (b)( 12), allows emission calculations to be verified. Reporting requirements removed from rule; data elements kept as records. NA Decrease in burden. Fewer data elements are required to be reported for mass balance approach

### 11 Original Reporting Element (s) Information Provided by Reporting Element(s) Revised or Replacement Reporting Element(s) Information Provided by Revised Element(s) Net Impact on Burden the process (metric tons). a

(8) If you use §98.123(b)(4) to estimate the total mass of fluorine in destroyed or recaptured streams, report the following. a

(i) The mass and chemical formula of each fluorine

containing product that is removed from the process and fed into the destruction device (metric tons). a

(ii) The mass and chemi cal formula of each fluorine

containing by

- product that is removed from the process and fed into the destruction device (metric tons). a

(iii) The mass and chemical formula of each fluorine

containing reactant that is removed from the process and fed into the destruction device (metric tons). a

(iv) The mass and chemical formula of each fluorine

containing by

- product that is removed from the process and recaptured (metric tons). a

(v) The demonstrated destruction efficiency of the destruction

### 12 Original Reporting Element (s) Information Provided by Reporting Element(s) Revised or Replacement Reporting Element(s) Information Provided by Revised Element(s) Net Impact on Burden
device for each fluorinated GHG fed into the device from the process in greater than trace concentrations (fraction). a §98.126(b)(10)

- (b)(12) :

(10) The fraction of the mass emitted that consists of each fluorine

- containing reactant.

(11) The fraction of the mass emitted that consists of the fluorine

- containing product.

(12) The fraction of the mass emitted that consists of each fluorine

- containing by

- product. In conjunction with current §98.126(b)(3)

- (b)(8) a , allows emission calculations to be verified. Reporting requirements removed from rule; data elements kept as records. NA Decrease in burden. Fewer data elements are required to be reported for mass balance approach.

§98 .126(b)(13) : The method used to estimate the total mass of fluorine in destroyed or recaptured streams (specify §98.123(b)(4) or (15)). Provides method used for destroyed or recaptured
streams. No change except renumbered

as Proposed §98. 126(b)(2) NA No change in burden.

§98 .126(c) Intro paragraph : For the emission factor or emission calculation factor approach, report fluorinated GHG emissions for each process, and report separately the emissions from transformation proces ses where fluorinated reactants are produced at another facility. General reporting for emission factor and emission calculation factor approach, for each
process. §98.126(c) Intro paragraph : For the emission factor or emission calculation factor approach , report fluorinated GHG emissions for each generically

- identified process,. General reporting for each generically

identified process. No change in burden.

§98 .126(c) (1) : The identity and quantity of the process activity used to estimate emissions (e.g., tons of product produced or tons of reactant consumed). a In conjunction with emission factor reported under §98.126 (c)(2), a allows emission calculations to be Proposed §98 .126(a)(7) : For each generically identified process, the range, based on Table L

- 2, that encompasses the effective destruction efficiency Provides insight into the level of emissions control for the process. Slight increase in burden. Facilities are already required to determine the destruction efficiency of the destruction device by fluorinated GHG,

### 13 Original Reporting Element (s) Information Provided by Reporting Element(s) Revised or Replacement Reporting Element(s) Information Provided by Revised Element(s) Net Impact on Burden
verified.

Also a llows calculation of an implied emission factor (emissions/ activity ) , which provides a means of comparing the emissiveness of processes that have different activity levels. Emissiveness may vary due to inherent process differences (e.g., byproduct generation rates) or du e to different levels of emissions control. calculated for that process on a CO 2 e basis.

Other related rule paragraphs: Proposed §98 .123(h)

. and are also already required to track the up

- time or down

time of the destruction device. The proposed reporting requirement will require some calculation from these data to determine the effective destruction efficiency and to categorize as one of the r anges in the proposed rule.

§98 .126(c)(3) : The mass of each fluorinated GHG emitted from each process vent (metric tons).

§98 .126(c)(4) : The mass of each fluorinated GHG emitted from equipment leaks (metric tons). Emissions by process and chemical; ide ntification of emissions type (vented vs. leaked) Proposed §98 .126(c)(3) : For each fluorinated GHG group, the total GWP

- weighted mass of all fluorinated GHGs in that group emitted from all process vents combined, in metric tons of CO 2 e.

Proposed §98 .126(c)(4) : For each fluorinated GHG group, the total GWP

- weighted mass of all fluorinated GHGs in that group emitted from equipment leaks, in metric tons CO 2 e. Emissions by p rocess and fluorinated GHG
group; identification of emissions type (vented vs. leaked)

. Little or no net change.

§98 .126 (d) : Reporting for missing data. Where missing data ha ve been estimated pursuant to § 98.125, you must report the

reason the data were missing, the length of time the data were Provides information regarding nature and scope of missing data. Proposed §98 .126(d) : Reporting for missing data. No change proposed . No change

. No change in burden

.

### 14 Original Reporting Element (s) Information Provided by Reporting Element(s) Revised or Replacement Reporting Element(s) Information Provided by Revised Element(s) Net Impact on Burden missing

, the method used to estimate the missing data , and the estimates of those data

. a §98 .126(e) : Reporting of destruction device excess emissions data. Each fluorinated gas production facility that destroys fluorinated GHGs must report the excess emissions that result from malfunctions of the destruction device, and these excess emissions would be ref lected in the fluorinated GHG estimates in §98.123(b) and (c). Such excess emissions would occur if the destruction efficiency was reduced due to the malfunction. Provides excess emissions that result from destruction device malfunctions. Proposed §98 .126 (e) : Reporting of destruction device excess emissions data . Each fluorinated gas production facility that destroys fluorinated GHGs must report the excess emissions that result from malfunctions of the destruction device, and these excess emissions must b e reflected in the fluorinated GHG estimates in §98.123(b) and (c). Such excess emissions would occur if the destruction efficiency was reduced due to the malfunction. Technical correction changes “would” to “must. No burden change.

§98.126(f)

, §98.126( g )

, §98.126( i )

, 98.126(j) : NO CHANGE NA NA NA NA

§98 .3(c)(4)(iii) and §98 .126(a)(2), (a)(3), (a)(4), (a)(6), (b), (c), (d), (e), (f), (g) and (h) : Deferred for RY2011, RY2012, and RY2013 until March 31, 2015. Detailed reporting of emissions under subpart A and subpart L, deferred for RY2011, RY2012, and RY2013 until March 31, 2015 under §98.126(j)(1). Proposed §98.126(k): Submission of RY2011, RY2012, and RY2013 GHG reports by March 2015. You must submit ann ual GHG reports for RY2011, RY2012, and RY2013 that contain the information specified in paragraphs (a) through (h) of this section. The reports must calculate CO 2 e using the GWPs in Table A

- 1 Global Warming Potentials to subpart A of this part and Table L

- 1 Default Requires reporting of RY2011, RY2012, and RY2013 emissions at the level of detail in the proposed amendments to subpart L. Little or no net change, as detailed above.

### 15 Original Reporting Element (s) Information Provided by Reporting Element(s) Revised or Replacement Reporting Element(s) Information Provided by Revised Element(s) Net Impact on Burden Global Warming Potentials for Compounds that Do Not Appear on Table A

- 1 (if applicable) to subpart A of this part

. The GHG reports must be submitted by March 31, 2015.

a The Inputs Rule ( Revisions to Reporting and Recordkeeping Requirements, and Proposed Confidentiality Determinations under the Greenhouse Gas R eporting Program , proposed in September 2013) would also amend these provisions , e.g., to remove “the mass” from §98.126(b)(6) , §98.126(b)(7), and §98.126 (b)(8)(i

iv), and to remove and reserve §98.126(c)(2)

.

### 16 Table 2. Comparison of Original Provisions in the Subpar t L Rule vs. the Proposed Provisions (Long

- term Subpart L Rule Changes) a Original Provision (s) Revised or Replacement Provision Net Impact on Burden §98.123(a) : Use a value of 2000 for fluorinated GHGs that do not have GWPs listed in Table A

- 1 to subpart A.

Other related rule paragraphs: §98.123(b)(1)(viii) §98.123(c)(1)(v) §98.124(b)(8)(iv) §98.124(c)(2) Proposed §98.123(a): Use of default GWPs for fluorinated GHGs that do not have GWPs listed in Table A

- 1 to subpart A, as provided in Table L

- 1.

Other related rule paragraphs: Proposed §98.123(b)(1)(viii) Proposed §98.123(c)(1)(v) Proposed §98.124(b)(8)(iv) Proposed §98.124(c)(2) Proposed §98.126 Proposed §98.128 As discussed in accompanying memorandum, “Economic Analysis of Amendments to Subpart L Reporting Provisions,” this amendment is not expected to change the burden calculated for the 2010 final subpart L. Initial cost analysis

assum ed that all facilities were using GWPs that accurately reflect the actual GWPs when determining applicability of stack testing requirements at §98.123(c)(2).

§98.123 (header paragraph): Facilities must calculate the fluorinated GHG emissions from each pro cess using either the mass balance method or the emission factor or emission calculation factor method.

§98 .123(b) : Calculations for the mass balance approach for determining emissions from
processe s

.

Other related rule paragraphs: §98 .12 4(b): mass

- balance monitoring requirements

. . §98.123 (header paragraph): Facilities must calculate the fluorinated GHG emissions from each process using either the emission factor or emission calculation factor method. (Option to use the mass balance approach is removed for reporting year 2015 and later reporting
years. )

Proposed §98 .123(b ) : Removal of calculations for the mass balance approach for reporting year 2015 and later reporting years.

Other related rule paragraphs: Proposed §98 .12 4 (b): Removal of monitoring requirements for the mass balance approach for reporting year 2015 and later reporting years. See accompanying memorandum, “Economic Analysis of Amendments to Subpart L Reporting Provisions” for a discussion of the impact of removing the option to use the mass balance approach.

§98.123(c)(1)(vi) : Use of an alternative GWP value for fluorinated GHGs that do not have GWPs listed in Table A

- 1 to subpart A; the request must be made by February 28, 2011.

Other rel ated rule paragraphs: §98.123(c)(1)(vi)(A)( 4 ) §98.123(c)(1)(vi)(B) Proposed §98.123(c)(1)(vi): [Reserved] Expired provision removed; n o change in burden.

### 17 Original Provision (s) Revised or Replacement Provision Net Impact on Burden §98.123(g)(2)(ii) : Calculation of residual mass in cylinders/containers, when monitoring the
pressure. Proposed §98.123(g)(2)(ii) : Calculation of residual mass in cylinders/containers, when monitoring the
pressure. No change in burden.

§98.124(c)(1) : For the EF approach, facilities must test for any fluorinated GHG that occurs in more than trace concentrations.

Other related rule paragraphs: §98 .124(c)(5) Proposed §98.124(c)(1) : For the EF approach, facilities must test for any fluorinated GHG identified in the initial scoping speciation or that is known to occur in the vent. If a fluorin ated GHG is not detected in the testing but was identified in the scoping speciation or is known to occur, facilities assume that fluorinated GHG is emitted at half the detection limit.

Other related rule paragraphs: Proposed §98 .124(c)(5) As discussed in accompanying memorandum, “Economic Analysis of Amendments to Subpart L Reporting Provisions,” this amendment is not expected to change the burden calculated for the 2010 final subpart L. Testing and emission factor development for fluorinated GHGs identified in the scoping speciation were already included in the initial cost analysis for the original promulgated rule.

a Amendments and revisions to §98.122 of subpart L are not included in this table; the amendments and revisions in §98.122 are in g eneral captured in other sections , such as §98.126 Reporting Requirements

.