Final Rule: Mandatory Reporting ofFluorinated Gases Source Categories
 

Meeting Documentation Interagency Meeting - Provide Overview ofKey Comments and Responses, August 19,
 

2010 

Date Staff Contact Information Name of Summary of Discussion (e.g., applicability, reporting Written Comments Date sent to EPA­

(Name, email, phone #) Organization requirements, etc.) Provided? CCD 

(Attach list of Did they also 

all attendees submit to Docket? 

names and 

emails if 

possible) 

8/19/10 Suzie Kocchi, Agencies A conference call was held to provide the No N/A 

Kocchi.suzanne@epa.gov attending: interagency group an overview on the key 

202-343-9387 OMB, CEQ, comments and responses on fluorinated gas rule 

DOE,EPA, that contains the following subparts: electronics, 

Commerce, SF6 in electric power systems, SF6 in electrical 

USTR, CEA, equipment, fluorinated gas production, imported 

NASA products containingfluorinated gases. 
Thanks, 

Suzie 

FinaLOMB Briefing 8.19.10.ppl 
MRR: Additional Sources of
 

Fluorinated GHGs
 

Summary of Comments and Responses 

Interagency Review
 

August 19, 2010
 

Fluorinated GHGs 

• F-GHGs include potent, long-lived • Due to high GWPs, small quantity of gases = large 

emissions per facility 

• 2010 Proposal covers: 

• Imports and exports F-GHGs inside pre-charged 

equipment and closed-cell foams (Subpart QQ) 

• Manufacturers of T&D equipment (Subpart SS) 

• Users ofT&D equipment (Subpart DD) 

• Emissions from fluoriJ.;lated gas production (L) 

• Electronics (Subpart I) 

2 
g

, 

, 

• Published in FR: April 12, 2010 

• 1public hearing: April 20, 2010 

- 4 speakers: 3 industry, 1 environmental NGO 

• Outreach meetings: 20 to date • 60-day comment period (April 12-June 11) 

- Approx. 60 entities provided unique comments on 5 

subparts 

- In general, comments were technical in nature; no major 

policy changes required 

- Key comments described by subpart iIi subsequent slides 

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Imports and Exports ofF-GHGs in PreCharged Equipment and Closed-cell 

Foam: Key Comments & Responses 

Equipment is hermetically sealed, charge Quantities are significant in aggregate, 

size is small. GHGs will be emitted during use and 

disposal. 

Motor vehicle air conditioners are moving Timing and extent of a transition are 

to low GWP refrigerant unknown, insufficient evidence to exempt 

- Exempt/delay/reduce requirements entire sector. 

Off-ramp for 3 yrs under 15,000 mtC02e 

and 5 yrs under 25,000 mtC02e already 

provided by 2009 final rule. 

In some cases, reporters may not have Added alternate reporting requirements for 

access to particular closed-cell foam data. such instances. 

4 
Scale accuracy of 1% and annual Relax accuracy requirements (±2Ibs).
 

recalibration requirements are
 Require recalibration at frequency burdensome and may not be technically recommended by scale manufacturer. feasible. 

Clarify boundary between Equipment Added clarifying language to both
 

Manufacture (Subpart SS) and subparts.
 

Equipment Use (Subpart DD).
 

5 

T&D Equipment Use:
 

Key Comments & Responses
 

__

<G.ommedt Res,ponse 

Definition of Facility =System Added language clarifying boundary 

-System generally acceptable between systems. -Clarify boundary between systems. 

Requirement to inventory quantity ofSF6 Exclude small equipment from requirement 

currently contained in small equipment is to inventory quantity ofSF6 currently 

burdensome. contained in equipment. 

Exclude Subpart D Electric Generating Clarify that only EGU facilities that exceed 

Units (EGU) from reporting requirements the Subpart DD threshold must report SF6 

for this source category. emissions from this source category. 

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Raise emissions "cut-oft" that triggers 

more rigorous vent measurements. 

Emissions from equipment leaks small 

and current methods don't apply to FGHGs. 

Allow more than one year to complete 

testing 

Change method for estimating emissions
 

for purposes of applying the cutoff,
 

effectively raising it.
 

Allow facilities more flexibility in 

estimating equipment leaks (facilityspecific methods, default EFs). 

Allow petition to use Best Available 

Monitoring Methods (BAMM) where it is 

not reasonably feasible to install 

measurement equipment or acquire 

.measurement services by rule deadlines. 

Electronics Manufacturing: 

Key Comments & Responses 

Calculation/Reporting Methods- Semiconductors 

• Support use ofdefault EFs, but 

EPA's 9 category approach (default EFs) was 

not technically supported: 

• Flawed uncertainty analysis 

• Insufficient etch process emissions data. 

• Environmental NGO: Support use of 

directly measured EFs; use ofdefaults will 

result in less certain estimate as compared to 

direct measurement. 

• 1nllJlm:y: Gas apportionment method (based 

on wafer pass) is burdensome and would 

require new meters and/or software. 

• EPA recognizes data limitations, need for additional 

measurement-specifically for etch processes; EPA also 

recognizes that directly measured EFs will result in a more 

accurate emissions estimate. 

• Two different methodologies for semiconductor 

manufacturing facilities, depending on manufacturing 

capacity: 

• $10,500 m' siliean (approx. 62 facilities): Default EFs for 5 

process types llc sub-types. 

• > 10,500 m'silicon (approx. 29 facilities): Hybrid method: 

default EFs for 4 process types llc sub-types (i.e. clean 

processes) and directly measured EFs for etch process type. 

• EPA received limited information on alternatives in 

comments. 

• Industry cost estimates were much higher than EPA 

estimates, but were not substantiated. 

• Modified requirements to provide flexibility as 

long as the model is documented & verified (repeatable) . 

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8 
Iiiihi8tzy Jlatimatea EPA 
 

COliiblente.r 
 

Aaliiiiption 

Develop Proeess $16.3 Million $3.6 Million .I!F development costs would only be illtUned by lUi'" 

Emluion FaetonJ semicanductor companies (11 compmies operate 29lar&e 

(EPa) laallties). 2009 comments for directly 

measured Us: -Assumes 3 full time technicillJls per company. 

$.205 Mmion (perplltfonn basis) -Commenters included no detailed infonnation on bow coJ1. 

were calculated. $78.3 Million (per recipe basis) 

Apportioning gu $ 13.7 Million $2.2 Million -Assumes 11 companies operate 291argest facilities. 

usage-data ·Each company paying fun price (x) for one facility lUldo.s x management foreacb subsequent facility. 

a_are ·Commenters included no detailed information on how costs 

(291argeat Cabs) were calculated. 

Other Labor and $3·4Million $'.9 Million -Industry overestimated compliance costs and used higher 

OlkMCos" labor rates. 

Non..semtconductor -$1'" Million $0.05 Million -EPA estimate based on labor costs for 3 non-semioonduetor 

Electronics electronics facilities using default EFs and 2 process types. 

Facilities -EPA estimates no capital costs for using default EFt and 2 

process types. 

TOTAL $34.8 Million $7.8 Million	 -Both indu.stry and EPA total oost estimates do not include 

optional ORE testing. 

"EPA estimata based on 29 ISffje semiconductor facilitie. using Hybrid method; 62 non4affje semIconductor facililies u.ing clefauff
 

EFs for 5 process types 4. sub-lype:s; end 3 non-semiconrJudorelectronics facilities using defaults end 2 process typ....
 

Economic Impact Analysis: Overview 

• Background 

- Compliance costs directly related to GHG reporting, not GHG mitigation 

- Estimates based on labor and equipment required to 

• Measure and report emissions 

• Prepare monitoring and QA/QC plans 

• Maintain records and manage data 

• Baseline 

- Assumes none ofthe covered facilities are reporting GHG emissions 

• Cost model 

- Estimated costs using representative facility approach 

- Costs calculated separately for year and subsequent years 

• Total cost estimate - $6.8 million (year 1) and $7-4 million 

(subsequent years) 

• Changes since proposal 

- Revision of model facility and monitoring methods used in subpart I 

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10 
Imports and Exports ofF-GHGs in PreCharged Equipment and Foam 

Electrical Equipment Manufacture Electrical Equipment Use 

Fluorinated Gas Production 

Electronics Manufacturing 

Cost as proposed: $700,000 first year national 

cost - no change for final rule 

Cost as proposed: $200,000 first year national 

cost - no change for final rule 

Cost as proposed: $390,000 first year national 

cost - no change for final rule 

Cost as proposed: $2.1 million first year national 

cost - no major change in cost expected for final 

rule 

Cost as proposed: $2.9 million first year national 

cost - Cost increased approximately $300k for 

final rule (first year national cost $3.2 million, 

subsequent year national cost $5.6 million 

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