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 threshold analysis of the 

emissions occurring from the production of fluorinated gases for the promulgation of 40 CFR 

Part 98. Fluorinated GHG emissions from fluorinated gas production may include HFCs, PFCs, 

SF6, NF3, and fluorinated anesthetics. 

II. Background 

To estimate the regulatory impact of requiring companies to report emissions occurring 

from the production of fluorinated gases, including fluorinated anesthetics, a threshold analysis 

that evaluated emissions from the production of these gases at the facility level against emission 

thresholds of 1,000; 10,000; 25,000; and 100,000 mtCO2e, was conducted. 

III. Emission Threshold Analysis – HFCs, PFCs, SF6, NF3, CFCs, and HCFCs 

 

 Estimates of facility-level production for each fluorinated GHG were primarily 

obtained from industry representatives through the Alliance for Responsible Atmospheric Policy 

(the Alliance Data). This confidential production data was supplemented with production 

capacity data reported in SRI Consulting’s CEH 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 emissions (i.e., pre-control) were 

estimated for fluorinated GHG production processes (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 processes (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 facility’s estimated emissions. The results of the analysis for 

uncontrolled emissions from the production of HFCs, PFCs, SF6, NF3, HFEs, CFCs, and HCFCs 
are shown in Table 1. (No emissions of fluorinated GHG from transformation processes, such as 

fluoropolymer production processes, are included in the analysis.) 

Table 1: Threshold Analysis for Fluorinated GHG Emissions from Production of HFCs, 

PFCs, SF6, NF3, CFCs, and HCFCs (Based on Generated Emissions) 

Threshold 

Level 

(mtCO2e) 

Total National 

Emissions 

(mtCO2e) 

Number of 

Facilities 

Emissions Covered Facilities Covered 

mtCO2e Percent Number Percent

HFCs, PFCs, SF6, NF3, 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 controlled emissions (i.e., those 

following the destruction device, if in place) were estimated for fluorinated GHG production 

processes (including anesthetics production processes) by multiplying a factor of 1.5 percent by 

the estimated production at each facility. For CFC and HCFC production processes (except for 

HCFC-22 production processes), controlled emissions were estimated by multiplying by a factor 

of 1.0 percent by the estimated production at each facility. 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, SF6, NF3, CFCs, and HCFCs. (No emissions of fluorinated GHG 

from transformation processes, such as fluoropolymer production processes, are included in the 

analysis.) 

 
Table 2: Threshold Analysis for Fluorinated GHG Emissions from Production of HFCs, 

PFCs, SF6, NF3, HFEs, CFCs, and HCFCs (Based on Actual Emissions) 

Threshold 

Level 

(mtCO2e) 

Total National 

Emissions 

(mtCO2e) 

Number of 

Facilities 

Emissions Covered Facilities Covered 

mtCO2e Percent Number Percent

HFCs, PFCs, SF6, NF3, 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 production processes for HFC, PFC, SF6, NF3, CFC, 

HCFC and summarizes the non-confidential information obtained on emissions from fluorinated 

GHG producers. 

Table 3: Data Sources for Threshold Analysis of Emissions from Production Processes for 

HFC, PFC, SF6, and NF3, CFC, HCFC by Facility 

Company Location 

Emissions 

from 

Production 

(mtCO2e) 

Emissions 

from 

Production 

Capacity 

(mtCO2e) 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 

available 
Company Location 

Emissions 

from 

Production 

(mtCO2e) 

Emissions 

from 

Production 

Capacity 

(mtCO2e) 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, and sevoflurane) was conducted. Facility-level 

fluorinated anesthetic production was estimated by evenly dividing national anesthetic 

production as estimated by Berry (2007) across the six fluorinated anesthetic-producing facilities 

in the U.S. (Krasney 2008). Table 4 identifies facilities with production processes for HFE and 

summarizes the information obtained on fluorinated anesthetics. 

Table 4: Emissions from Fluorinated Anesthetic Production by Facility 

Company Location 

Emissions from 

Production 

(mtCO2e) 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 occurring from the domestic production of 

fluoropolymers (i.e., transformation of a F GHG 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 fluorinated gases that are transformed into other 

products is not known. Table 5 identifies facilities that are likely to have transformation 

processes for fluoropolymers. 

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

Company Location 

Emissions from 

Production 

(mtCO2e) 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 industry 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 Center, 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 Research on U.S Other Anesthetics Industry.” Memo 

to Debbie Ottinger, EPA. 20 May 2008. 

“Mitsui to expand nitrogen trifluoride 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 Protection 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.