### Date: November 4, 2010

From: Karen S. Schaffner Cynthia W. Hancy

Subject: Threshold Analysis for Emissions Promulgation of 40 CFR Part 98, subpart L, Fluorinated Greenhouse Gas Production EPA Contract Number EP-W-07- 069; Technical Directive No. 20100504

I. Introduction

This memorandum describes the method used to conduct a threshol d analysis of the emissions occurring from the production of fluorinated gases for the promulgation of 40 CFR Part 98. Fluorinated GHG emissions from fluor inated gas production may include HFCs, PFCs, SF 6 

### , NF 3 

### , and fluorinated anesthetics.

II. Background To estimate the regulatory impact of requi ring companies to report emissions occurring from the production of fluorinated gases, including fluorinated anesthetics, a threshold analysis that evaluated emissions from the production of th ese gases at the facility level against emission thresholds of 1,000; 10,000; 25,000; and 100,000 mtCO 2 

### e, was conducted.

III. Emission Threshold Analysis – HFCs, PFCs, SF 6 

### , NF 3 

### , CFCs, and HCFCs

Estimates of facility-level production for each fluorinated GHG were primarily obtained from industry representatives through th e Alliance for Responsible Atmospheric Policy (the Alliance Data). This confidential pr oduction data was supplem ented with production capacity data reported in SRI Consulting’s CE H Marketing Research Report on Fluorocarbons (Will 2004), and publically-accessible data as available. In some instances, facility production was provided as a range.

Uncontrolled emissions . Facility-specific uncontrolled em issions (i.e., pre- control) were estimated for fluorinated GHG production pro cesses (including fluorinated anesthetics production processes) by multiplying a factor of 3.0 percent by the estimated production at each facility. For CFC and HCFC production processe s (except for HCFC-22 production processes), uncontrolled emissions were estimated by multiplying a factor of 2 percent by the estimated production at each facility. The coverage of each facility was estimated by comparing the emission threshold to each fac ility’s estimated emissions. The results of the analysis for uncontrolled emissions from the production of HFCs, PFCs, SF 6 

### , NF 3 

### , HFEs, CFCs, and HCFCs

### are shown in Table 1. (No emissions of fluorinat ed GHG from transformation processes, such as fluoropolymer production processes, are included in the analysis.)

Table 1: Threshold Analysis for Fluorinate d GHG Emissions from Production of HFCs, PFCs, SF 6 

### , NF 3 

### , CFCs, and HCFCs (Based on Generated Emissions) Threshold Level (mtCO 2 e) Total National Emissions (mtCO 2 e) Number of Facilities Emissions Covered Facilities Covered

mtCO 2 e Percent Number Percent HFCs, PFCs, SF 6 , NF 3 , CFCs, and HCFCs

1,000 10,600,000 14 10,600,000 100% 14 100%

10,000 10,600,000 14 10,600,000 100% 14 100%

25,000 10,600,000 14 10,600,000 100% 14 100%

100,000 10,600,000 14 10,600,000 100% 13 93%

Fluorinated Anesthetics

1,000 17,000 6 17,000 100% 6 100%

10,000 17,000 6 0 0% 0 0%

25,000 17,000 6 0 0% 0 0%

100,000 17,000 6 0 0% 0 0%



### Controlled emissions . As a general assumption, controlled emissions were assumed to be half of uncontrolled emissions at each facility. Facility-specific controlle d emissions (i.e., those following the destruction device, if in place) were estimate d for fluorinated GHG production processes (including anesthetics production proc esses) by multiplying a factor of 1.5 percent by the estimated production at each facility. Fo r CFC and HCFC production processes (except for HCFC-22 production processes), controlled emissi ons were estimated by multiplying by a factor of 1.0 percent by the estimated production at each f acility. The coverage of each facility was estimated by comparing the emission threshold to each facility’s estimated emissions. Table 2 summarizes the results of the threshold analysis based on controlled (actual) emissions from the production of HFCs, PFCs, SF 6 

### , NF 3 

### , CFCs, and HCFCs. (No emissions of fluorinated GHG from transformation processes, such as fluoropol ymer production processes, are included in the analysis.)

### Table 2: Threshold Analysis for Fluorinate d GHG Emissions from Production of HFCs, PFCs, SF 6 

### , NF 3 

### , HFEs, CFCs, and HCFCs (Based on Actual Emissions)

Threshold Level (mtCO 2 e) Total National Emissions (mtCO 2 e) Number of Facilities Emissions Covered Facilities Covered

mtCO 2 e Percent Number Percent HFCs, PFCs, SF 6 , NF 3 , CFCs, and HCFCs 1,000 10,600,000 14 10,600,000 100% 14 100% 10,000 10,600,000 14 10,600,000 100% 14 100%

25,000 10,600,000 14 10,600,000 100% 14 100%

100,000 10,600,000 14 10,300,000 97% 10 71%

Fluorinated Anesthetics 1,000 17,000 6 17,000 100% 6 100% 10,000 17,000 6 0 0% 0 0%

25,000 17,000 6 0 0% 0 0%

100,000 17,000 6 0 0% 0 0%



### Table 3 identifies facilities with prod uction processes for HFC, PFC, SF 6 

### , NF 3 

### , CFC, HCFC and summarizes the non-confidential inform ation obtained on emissions from fluorinated GHG producers.

Table 3: Data Sources for Threshold Analysis of Emissions from Prod uction Processes for HFC, PFC, SF 6 

### , and NF 3 

### , CFC, HCFC by Facility

Company Location Emissions from Production

(mtCO 2 e) Emissions from Production

Capacity (mtCO 2 e) Year Data Source Comments

3M Cordova, IL CBI CBI 2006 Alliance Data

Air Products Hometown, PA CBI CBI 2006 Alliance Data

Arkema, Inc. Calvert City, KY Proprietary Proprietary 2003 SRI

Chemtura El Dorado, AR Proprietary Proprietary 2003 SRI

DuPont Corpus Christi, TX CBI CBI 2006 Alliance Data SRI capacity estimates also availableCompany Location Emissions from Production

(mtCO 2 e) Emissions from Production

Capacity (mtCO 2 e) Year Data Source Comments

Deepwater, NJ CBI CBI 2006 Alliance Data SRI capacity estimates also available Louisville, KY CBI CBI 2006 Alliance Data

Halocarbon Products North Augusta, SC CBI CBI 2008 Data reported
to Stratospheric

Protection Division under 40 CFR part 82

Honeywell Metropolis, IL CBI CBI 2006 Alliance Data

Baton Rogue, LA CBI CBI 2006 Alliance Data SRI capacity estimates also available

Geismar, LA CBI CBI 2006 Alliance Data SRI capacity estimates also available

Ineos Fluor Americas St. Gabriel, LA CBI CBI 2006 Alliance Data SRI capacity estimates also available

MitsuiAnderson Develop. Co. Adrian, MI 51,600 68,800 2007 Japan Chemical

Week

Solvay Solexis Thorofare, NJ CBI CBI 2008 Data reported
to Stratospheric

Protection Division under 40 CFR part 82

### IV. Emission Threshold Analysis – Fluorinated Anesthetics A threshold analysis for emissions occurring from the domestic production of fluorinated anesthetics (i.e., desflurane, isofluorane, a nd sevoflurane) was c onducted. Facility-level fluorinated anesthetic production was estimat ed by evenly dividing national anesthetic production as estimated by Berry (2007) across the six fluorinated anesthe tic-producing facilities in the U.S. (Krasney 2008). Table 4 identifies facilities with production processes for HFE and summarizes the information obtaine d on fluorinated anesthetics.

Table 4: Emissions from Fluorinated Anesthetic Production by Facility

Company Location Emissions from Production

(mtCO 2 e) Year Data Source

Abbott Laboratories Unknown 2,780 2005 Berry (2007) and Krasney (2008)

AirGas Incorporated Unknown 2,780 2005 Berry (2007) and Krasney (2008) Baxter Healthcare Corporation Unknown 2,780 2005 Berry (2007) and Krasney (2008) Halocarbon Corporation North Augusta, SC 2,780 2005 Berry (2007) and Krasney (2008)

MINRAD Incorporated Unknown 2,780 2005 Berry (2007) and Krasney (2008)

Rhodia Incorporated Unknown 2,780 2005 Berry (2007) and Krasney (2008)



### V. Emission Threshold Analysis – Fluoropolymers A threshold analysis for emissions occu rring from the domestic production of fluoropolymers (i.e., transformation of a F GH G into a fluoropolymer) was not conducted because the number of facilities affected is not known (uncertainty regarding F GHG emitted and the magnitude of emissions). The quantity of fl uorinated gases that are transformed into other products is not known. Table 5 identifies facilities that ar e likely to have transformation processes for fluoropolymers.

### Table 5: Facilities Likely to have Fluoropolymer Processes (i.e., Transformation)

Company Location Emissions from Production

(mtCO 2 e) Year Data Source Daikin America/ Dyneon (3M) 1 Decatur, AL NA NA SRI

DuPont Fayetteville, NC NA NA SRI
Washington, WV NA NA SRI

Yerkes, NY NA NA SRI



### VI. References Alliance Data Request. The U.S. EPA queried indu stry representatives through the Alliance for Responsible Atmospheric Policy in December 2007/January 2008. Berry, James. Telephone conversation between Dr . James Berry, Professor, Department of Anesthesiology, Vanderbilt University Medical Cent er, and Deborah Ottinger, U.S. EPA. March 21, 2007.
EPA. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2006 . Washington: GPO, 2008. Krasney, Toby, and Marian Van Pelt. “ICF Resear ch on U.S Other Anesthetics Industry.” Memo to Debbie Ottinger, EPA. 20 May 2008.
“Mitsui to expand nitrogen tr ifluoride capacity by 80%.” Japan Chemical Week 9 August 2007. Will, Raymond, Akihiro Kishi, and Stefan Schlag. CEH Market Research Report: Fluorocarbons

. SRI Consulting, 2004. Data reported to Stratospheric Pr otection Division under 40 CFR part 82.

1 Assumed that Daikin America and Dyneon are the same facility in Decatur, AL; they are perhaps co-located but not clear.