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 Subpart 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 in the current 

rule that 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 expected net impact 

on reporter burden. Table 2 lists each of the other provisions in the current rule that EPA is 

proposing to remove or revise, the provision (if any) with which 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 burden. In some cases the new rule requirements would actually decrease 

burden. Where changes might result in a small net increase in burden for a particular 
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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 the 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 Greenhouse 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 associated 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 FGases: Subparts I, L, DD, QQ, SS.” In the initial economics evaluation, EPA assumed that the 

majority of affected 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 

proposing 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 calculation 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.
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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 additional burden.

Impact of Added Default GWPs on Subpart L Rule Applicability. In 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 subpart 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 to 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), there is one threshold in subpart L that 

relies on CO2e emissions to determine applicability 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 10,000 mtCO2e, 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 subpart L rule, for fluorinated GHGs 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 GWPs 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 analysis for subpart L. The initial economics evaluation for subpart 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 subpart L 

rule. We assumed the facilities were accurately calculating their CO2e emissions and that all 

process vents were appropriately categorized above or below the cutoff. Therefore 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.
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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 

Reporting 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 paragraph (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 between December 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 scenario 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.

Process 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; 
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Original Reporting Element(s)

Information Provided 

by Reporting Element(s)

Revised or Replacement 

Reporting 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 

fluorinated 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 

fluorinated 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 

CO2e.

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 CO2e for each 

chemical. Slight burden 

increase associated with 

adding up CO2e 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.
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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 CO2e 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 CO2e for each 

chemical. Slight burden 

increases associated with 

assessment of whether 

emissions are over or under 

threshold and with adding up 

CO2e 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 group for the 

facility as a whole in metric tons 

of CO2e.

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 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 

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 not 

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 
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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 CO2e.

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)). 

Subpart A already requires 

calculation of CO2e for each 

chemical. Slight burden 

increase associated with 

adding up CO2e 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.

§98.126(a)(2)(iii): Total mass in 

metric tons of each fluorinated 

GHG emitted 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): Total 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.
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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) 

analyzed 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 that 

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 emissions 

of each fluorinated GHG, i.e., 

mass balance, process-ventspecific emission factor, or 

process-vent-specific emission 

calculation factor, at the facility. 

If you use the process-ventspecific 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 group, 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 approach.

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 

(emissions/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 
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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 emissions 

control.

Table L-2, that encompasses the 

effective destruction efficiency 

calculated for that process on a 

CO2e 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 downtime of the destruction device. 

The proposed reporting 

requirement will require some 

calculations 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 massbalance 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), substitute 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 Balance 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.
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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 absolute 

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, if you calculated the 

relative and absolute errors 

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 

formula 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 

CO2e.

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 CO2e for each 

chemical. Slight burden 

increase associated with 

adding up CO2e 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.

§98.126(b)(6)-(b)(8)

(6) The mass and chemical 

formula of each fluorinecontaining reactant that is fed into 

the process (metric tons). a

(7) The mass and chemical 

formula of each fluorinecontaining 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 fluorinecontaining product that is 

removed from the process and fed 

into the destruction device (metric 

tons). a

(ii) The mass and chemical 

formula of each fluorinecontaining 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 fluorinecontaining reactant that is 

removed from the process and fed 

into the destruction device (metric 

tons). a

(iv) The mass and chemical 

formula of each fluorinecontaining 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 processes 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 genericallyidentified 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 allows 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 due to different 

levels of emissions 

control.

calculated for that process on a 

CO2e basis.

Other related rule paragraphs:

Proposed §98.123(h). 

and are also already required 

to track the up-time or downtime 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 ranges 

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; identification 

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 

CO2e.

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 CO2e.

Emissions by process 

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 

have 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 

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.

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 be 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 annual GHG 

reports for RY2011, RY2012, 

and RY2013 that contain the 

information specified in 

paragraphs (a) through (h) of 

this section. The reports must 

calculate CO2e 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 Reporting 

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)(iiv), and to remove and reserve §98.126(c)(2). 
16

Table 2. Comparison of Original Provisions in the Subpart 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 

assumed 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 process 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 

processes.

Other related rule paragraphs:

§98.124(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 §98.124(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 related 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; no 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 fluorinated 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 general captured in other 

sections, such as §98.126 Reporting Requirements.