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MEMORANDUM

TO : Debbie Ottinger, EPA

FROM : Carrie Richardson Fry and Karen Schaffner, RTI

DATE : November 21, 2014

SUBJECT : Economic Analysis of Final Amendments to the Gre enhouse Gas Reporting Rule

for the Fluorinated Gas Production Source Category (Subpart L)

Final changes to subpart L, Fluorinated Gas Product ion, of the Greenhouse Gas

Mandatory Reporting Rule (GHG MRR) were evaluated t o determine their economic impact on

subpart L facilities. The EPA is revising the repo rting and recordkeeping requirements for

subpart L. The final changes to subpart L include:

• Replacing the current reporting requirements with r equirements to reduce the level of

detail in which emissions are reported.

• Removing the option to use the mass balance approac h to calculate GHG emissions.

• Clarifying the process vent testing requirements fo r facilities that use the emission factor

method.

• Removal of the requirement to report certain inputs to emission equations for which

reporting was deferred to 2015 and for which disclo sure concerns have been identified,

and requiring these data to be kept as records.

• Removal of the requirement to report certain inputs to emission equations for which

reporting was deferred to 2015 due to their not bei ng useful in the absence of other

deferred inputs for which reporting requirements ar e being removed.

• Adding a requirement for subpart L reporters to use an EPA-provided inputs verification

tool. The designated inputs to emission equations for which reporting was deferred to

2015 (referred to as “input to equations’ data elem ents”) and disclosure concerns have

been identified are entered into the tool. The too l calculates the emission equation results

and performs electronic verification.

• Changing the required format for maintaining record s of these inputs to emission

equations for subpart L reporters using the inputs verification tool.

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• Lengthening the record retention period from 3 to 5 years for all records maintained

under Part 98 for reporters required to use the inp uts verification tool.

Reporting More Aggregated Data. The final changes to the subpart L Fluorinated Gas

Production source category would replace many of th e current reporting requirements with

requirements to report at a higher level of aggrega tion. In a few cases, reporting requirements

would be removed but not replaced. Table 1 lists e ach of the reporting elements in the current

rule that EPA is removing or revising, the informat ion provided by that reporting element, the

reporting element (if any) with which EPA is replac ing the current reporting element, the

information provided by that revised reporting elem ent, and the expected net impact on reporter

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

revising, the provision (if any) with which EPA is replacing the current provision, and the

expected net impact on reporter burden. Note that in some cases, there is not a perfect one-toone correspondence between the current and final el ements; 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 reportin g under subpart L. In most instances, the

revised reporting requirement simply replaces or up dates 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 require ments would actually decrease burden.

Where changes might result in a small net increase in burden for a particular requirement, this

increase is expected to be offset by the decrease i n burden for other reporting requirements.

Mass Balance Approach. In the current subpart L ru le, facilities may choose from two

options for calculating GHG emissions: the mass ba lance (MB) approach, and the emission

factor or emission calculation factor (EF/ECF) appr oach. EPA is amending subpart L to remove

the option to use the MB approach from the calculat ion and monitoring requirements of the rule.

Facilities would be able to use the EF/ECF approach es to monitor, calculate, and report

fluorinated GHG emissions. Based on reporting in t he 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 amending the reporting requirements associated with the MB

approach; those changes are analyzed in Table 1.

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# A few facilities have indicated in their annual reports in eGGRT that they use the MB approach, how ever, in

follow-up discussions with the facilities regarding the calculation methods used, EPA confirmed that n o facilities are

actually using the MB approach. These few faciliti es 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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The initial economic evaluation for subpart L was p resented in the November 2010

“Economic Impact Analysis for the Mandatory Reporti ng 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/EC F approach and that a small percentage would

use the MB approach. Modifying the analysis to refl ect 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 cu rrent 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. In the final

rule, the EPA is requiring process vent testing for all fluorinated GHGs that were identified in

the initial scoping speciation or that occur in mor e than trace concentration in either the vent

stream or the inlet to the destruction device. We have concluded that any impacts on these

facilities were accounted for in the initial econom ic 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 or occurring i n more than trace concentrations in the vent

stream or inlet to the destruction device. In addit ion, the cost of testing for gases identified in th e

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 fluorinated GHGs that are not found when

conducting a process vent test but that were presen t at the scoping speciation is expected to result

in very little additional burden.

Impact of Added Chemical-Specific and Default GWPs on Subpart L Rule Applicability.

The applicability impacts to subpart L for adding c hemical-specific and default GWPs to Table

A-1 are discussed in the memorandum “Economic Analy sis of Adding Chemical-Specific and

Default GWPs to Table A-1 (Subpart A)”, in EPA Dock et No. EPA-HQ-OAR-2009-0927.

Impact of Added Chemical-Specific and Default GWPs on Other Subpart L Provisions.

The impact on other subpart L provisions from addin g chemical-specific and default GWPs to

Table A-1 are discussed in the memorandum “Economic Analysis of Adding Chemical-Specific

and Default GWPs to Table A-1 (Subpart A)”, in EPA Docket No. EPA-HQ-OAR-2009-0927

Use of the Electronic Inputs Verification Tool. Th e EPA is eliminating the reporting of

many inputs to equations data elements due to discl osure concerns. The EPA is replacing these

reporting requirements with a requirement to enter the data into a new inputs verification tool

(IVT) within eGGRT.

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The EPA has determined that there will be no cost i ncrease to enter inputs to equations

data elements into the inputs verification tool, as compared to the cost associated with reporting

these data via e-GGRT. The EPA expects that report ers would spend the same time to complete

entry of inputs to equations data elements into the inputs verification tool as they would spend

reporting these data via e-GGRT. (As noted in Tabl e 1 below, however, the removal of the

requirement to report certain data elements associa ted with use of the mass-balance method, for

which EPA is not developing an IVT module, does res ult in some decrease in burden for those

facilities that used the mass-balance method in 201 1.)

The EPA recognizes, however, that there may be some time associated with learning the

new procedures for the verification tool. The EPA has estimated that each reporter will spend

one technical hour to become familiar with the inpu ts verification tool. Based on this technical

labor estimate, the associated clerical and manager ial labor hours and an estimated 12 subpart L

reporters that are not already reporting under anot her subpart, the EPA estimates that using the

new inputs verification tool would cost approximate ly $792 for the first year or $66 per facility.

(12 facilities x 1 hour = 12 hour. 12 technical ho urs x $59.12/hour + 1.6 clerical hours x

$31.35/hour + 0.8 managerial hours x $77.23/hour = $792.) The approach for the cost estimate

is identical to the Final Inputs Rule approach (see memorandum “Assessment of Cost Impacts of

2015 Inputs Final Rule - Revisions to Reporting, Re cordkeeping, and Verification Requirements

Under the Greenhouse Gas Reporting Program”, availa ble in Docket ID No. EPA-HQ-OAR2010-0929).

Recordkeeping Changes. The changes to the GHGRP in clude a provision to retain

records of all “inputs to equations” data elements for five years instead of the three years

currently required. Additionally, the EPA is requir ing reporters who use the inputs verification

tool to maintain a record of a file generated by th e tool, which lists the entered “inputs to

equations” data elements. This list of data element s could be maintained in a format (e.g.,

electronic, hard copy) currently allowed under Part 98. The EPA does not anticipate that this

change to the recordkeeping requirements would crea te any additional burden for a reporting

facility in addition to the recordkeeping burden es timated in the 2010 Impact Analysis.5Table 1. Comparison of Original Reporting Elementsin the Subpart L Rule vs. the Final Reporting Elements (Long-termSubpart L Rule Changes)Original Reporting Element(s)Information Providedby Reporting Element(s)Revised or ReplacementReporting ElementInformation Providedby Revised Element(s)Net Impact on Burden§98.126(a) (Intro paragraph):All facilities, in addition to theinformation required by §98.3(c),you must report the informationin paragraphs (a)(2) through(a)(6) of this section.Introductory paragraph.Final §98.126(a)(Introparagraph):All facilities, inaddition to the informationrequired by §98.3(c), you mustreport the information inparagraphs (a)(2) through (a)(6)of this section according to theschedule in paragraph (a)(1) ofthis section, except as otherwiseprovided in paragraph (j) of thissection or in §98.3(c)(4)(vii) andTable A-7 to subpart A of thispart.Introductory paragraph. No change in burden.§98.126(a)(1):The informationin paragraphs (a)(2), (5), and (6)of this section must be reportedannually. The information inparagraphs (a)(3) and (4) of thissection must be reported once byMarch 31, 2012 for each processand operating scenarios thatoperates between December 31,2010 and December 31, 2011.For other processes and operatingscenarios, the information inparagraphs (a)(3) and (4) of thissection must be reported once byMarch 31 of the year followingthe year in which the process oroperating scenario commences orrecommences.Frequency of reportingunder §98.126(a).Final §98.126(a)(1):Theinformation in paragraphs (a)(2),(3), (4), (5), and (6) of thissection must be reportedannually.Frequency of reportingunder §98.126(a).No change in burden.Facilities continue to reportgeneral information annually.(See below for discussion ofrevisions to individualsubparagraphs.)§98.126(a)(6):The chemicalformula of the fluorinated gasproduct in metric tons, bychemical and process.Process identification byproduct of processFinal §98.126(a)(2):For eachproduction and transformationprocess at the facility, you must:(i) Provide a number, letter, orProcess identification byprocess type, subtype,and letter or numberLittle or no net change.Process type already requiredunder §98.126(a)(2)(i) and (ii).Product no longer identified;6Original Reporting Element(s)Information Providedby Reporting Element(s)Revised or ReplacementReporting ElementInformation Providedby Revised Element(s)Net Impact on Burdenother identifier for the process,consistent from year to year.(ii) Indicate whether the processis a fluorinated gas productionprocess, a fluorinated gastransformation process where nofluorinated GHG reactant isproduced at another facility, ora fluorinated gas transformationprocess where one or morefluorinated GHG reactants areproduced at another facility; and(iii) Indicate whether the processcould be characterized asreaction, distillation, orpackaging (include all thatapply).instead, process subtype andletter or number are provided.§98.126(a)(2)(i):Total mass inmetric tons of each fluorinatedGHG emitted from eachfluorinated gas productionprocess.§98.126(a)(2)(ii): Total mass inmetric tons of each fluorinatedGHG emitted from eachfluorinated gas transformationprocess that is not part of afluorinated gas productionprocess, except report separatelyfluorinated GHG emissions fromtransformation processes where afluorinated GHG reactant isproduced at another facility.Emissions by process andchemical; identificationof process typeFinal §98.126(a)(3): Forfacilities that produce more thanone fluorinated gas product: Foreach generically identifiedprocess and each fluorinatedGHG group, report the totalGWP-weighted emissions of allfluorinated GHGs in that groupfrom the process, in metric tonsCO2e.Emissions by processand fluorinated GHGgroup, referencing final§98.126(a)(2)identification of processtype.Little or no net change.Subpart A already requirescalculation of CO2e for eachchemical. Slight burdenincrease associated withadding up CO2e emissions ofeach chemical to reportemissions by fluorinated GHGgroup. Slight burden decreaseassociated with reportingmaximum of 12fluorinatedGHG groups rather than largernumber of individualchemicals.7Original Reporting Element(s)Information Providedby Reporting Element(s)Revised or ReplacementReporting Element(s)Information Providedby Revised Element(s)Net Impact on Burden§98.126(a)(2)(i): Total mass inmetric tons of each fluorinatedGHG emitted from all fluorinatedgas production processescombined.§98.126(a)(2)(ii): Total mass inmetric tons of each fluorinatedGHG emitted from all fluorinatedgas transformation processescombined, except reportseparately fluorinated GHGemissions from transformationprocesses where a fluorinatedGHG reactant is produced atanother facility.Emissions by processtype and chemical.Final §98.126(a)(4)(i): Forfacilities that produce more thanone fluorinated gas product: Foreach fluorinated GHG withemissions of 1,000 metric tonsof CO2e or more fromproduction and transformationprocesses summed across thefacility as a whole, report thetotal mass in metric tons of thefluorinated GHG emitted fromproduction and transformationprocesses summed across thefacility as a whole. Identify thefluorinated GHG group, asapplicable.Emissions by facilityand chemical.Little or no net change.Subpart A already requirescalculation of CO2e for eachchemical. Slight burdenincreases associated withassessment of whetheremissions are over or underthreshold and with adding upCO2e emissions of eachchemical to report emissionsby fluorinated GHG group.Slight burden decreaseassociated with reportingmaximum of 12 fluorinatedGHG groups rather than largernumber of individualchemicals.Final §98.126(a)(4)(ii): Forfacilities that produce more thanone fluorinated gas product: Forall other fluorinated GHGemitted from production andtransformation processes, reporttotal GWP-weighted emissionsfrom production andtransformation processes ofthose fluorinated GHGs byfluorinated GHG group,summed across the facility as awhole, in metric tons of CO2e.Emissions by facilityand fluorinated GHGgroup.Final §98.126(a)(5): Wherefacilities produce only onefluorinated gas product butemissions consist of a majorfluorinated GHG constituent ofa fluorinated gas product, andthe product is sold or transferredto another person: report theEmissions by facilityand chemical.Small burden increase possiblyassociated with consultingrecords to assess whetheremissions consist of a majorfluorinated GHG constituent ofa product that is sold ortransferred to another person.(Chemical analysis of each8Original Reporting Element(s)Information Providedby Reporting Element(s)Revised or ReplacementReporting Element(s)Information Providedby Revised Element(s)Net Impact on Burdentotal mass in metric tons of eachfluorinated GHG emitted fromproduction and transformationprocesses and that is a majorfluorinated GHG constituent ofthe product.product that contains morethan one fluorinated GHG isalready required under subpartOO at §98.414(n)).Final §98.126(a)(5): Wherefacilities produce only onefluorinated gas product andeither emissions are not a majorfluorinated GHG constituent ofthat product or the product is notsold or transferred: Aggregateand report the total GWPweighted emissions fromproduction and transformationprocesses of fluorinated GHGsby fluorinated GHG group forthe facility as a whole, in metrictons of CO2e.Emissions by facilityand fluorinated GHGgroupLittle or no net change. Smallburden increase possiblyassociated with consultingrecords to assess whetheremissions consist of a majorfluorinated GHG constituent ofa product that is sold ortransferred to another person.(Chemical analysis of eachproduct that contains morethan one fluorinated GHG isalready required under subpartOO at §98.414(n)).Subpart A already requirescalculation of CO2e for eachchemical. Slight burdenincrease associated withadding up CO2e emissions ofeach chemical to reportemissions by fluorinated GHGgroup. Slight burden decreaseassociated with reportingmaximum of 12 fluorinatedGHG groups rather than largernumber of individualchemicals.§98.126(a)(3): The chemicalidentities of the contents of thestream(s) (including process,emissions, and destroyed streams)analyzed under the initial scopingPreliminary identificationof fluorinated GHGs thatmay be emitted from theprocess.Reporting requirement removedfrom rule; data element kept asrecord.NA Decrease in burden.9Original Reporting Element(s)Information Providedby Reporting Element(s)Revised or ReplacementReporting Element(s)Information Providedby Revised Element(s)Net Impact on Burdenspeciation of fluorinated GHG at§ §98.124(a), by process.§98.126(a)(4): The location andfunction of the stream(s)(including process streams,emissions streams, and destroyedstreams) that were analyzed underthe initial scoping speciation offluorinated GHG at §98.124(a),by process.Background onpreliminary identificationof fluorinated GHGs thatmay be emitted from theprocess.Reporting requirement removedfrom rule; data element kept asrecord.NA Decrease in burden.§98.126(a)(5): The methods usedto determine the mass emissionsof each fluorinated GHG, i.e.,mass balance, process-ventspecific emission factor, orprocess-vent-specific emissioncalculation factor, at the facility.If you use the process-ventspecific emission factor orprocess-vent-specific emissioncalculation factor method, reportthe methods used to estimateemissions from equipment leaks.Calculation method usedfor each process, processvent, and fluorinatedGHG.Final §98.126(a)(2)(iv): Foreach generically-identifiedprocess and each fluorinatedGHG group, report the methodsused to determine the massemissions of that fluorinatedGHG group from that processfrom vents, i.e., process-ventspecific emission factor,process-vent-specific emissioncalculation factor, or massbalance,.Final §98.126(a)(2)(v): Foreach generically-identifiedprocess and each fluorinatedGHG group, report themethod(s) used to determine themass emissions of thatfluorinated GHG group fromthat process from equipmentleaks, unless you used the massbalance approach (for RY 2011through 2014 only).Calculation method usedfor each process, processvent, and fluorinatedGHG group.No change in burden. Theemissions monitoring andcalculation approach wasalready required to be reportedby process, emission type, andspeciated fluorinated GHG,and is to be reported bygeneric process, emission type,and fluorinated GHG group.§98.126(a)(6):The total massproduced of the fluorinated gasproduct in metric tons, byAllows calculation of animplied emission factor(emissions/production),Final §98.126(a)(6): For eachgenerically-identified process,the range, based on Table L-1,Provides insight into thelevel of emissionscontrol for the process.Slight increase in burden.Facilities are already requiredto determine the destruction10Original Reporting Element(s)Information Providedby Reporting Element(s)Revised or ReplacementReporting Element(s)Information Providedby Revised Element(s)Net Impact on Burdenchemical and process. which provides a meansof comparing theemissiveness of processesthat have differentproduction levels.Emissiveness may varydue to inherent processdifferences (e.g.,byproduct generationrates) or due to differentlevels of emissionscontrol.that encompasses the effectivedestruction efficiency calculatedfor that process on a CO2e basis.Other related rule paragraphs:Final §98.123(h).efficiency of the destructiondevice by fluorinated GHG,and are also already requiredto track the up-time or downtime of the destruction device.The final reportingrequirement will require somecalculations from these data todetermine the effectivedestruction efficiency and tocategorize as one of the rangesin the final rule.§98.126(b)(Intro paragraph):For processes whose emissionsare determined using the massbalance approach under§98.123(b), you must report theinformation listed in paragraphs(b)(1) through (b)(13) of thissection for each process on anannual basis. Identify andseparately report fluorinatedGHG emissions fromtransformation processes wherethe fluorinated GHG reactants areproduced at another facility. Ifyou use an element other thanfluorine in the mass-balanceequation pursuant to§98.123(b)(3), substitute thatelement for fluorine in thereporting requirements of thisparagraph.General reporting formass balance approach.§98.126(b)(Intro paragraph):Mass balance reporting must beconducted for RY2011,RY2012, RY2013, and RY2014,as applicable. For processeswhose emissions are determinedusing the mass balance approachunder §98.123(b), you mustreport the information listed inparagraphs (b)(1) and (b)(2) ofthis section for each process onan annual basis.Amends the generalreporting for massbalance approach foryears prior to RY2015.See accompanyingmemorandum, “EconomicAnalysis of Amendments toSubpart L ReportingProvisions” for a discussion ofthe impact of removing theoption to use the mass balanceapproach. The changes toindividual reportingrequirements for the massbalance approach are discussedbelow.§98.126(b)(1): For processeswhose emissions are determinedusing the mass balance approach,on an annual basis, if youVerifies compliance withMass Balance errorlimits; indicates dataquality; permitsFinal §98.126(b)(1): Forprocesses whose emissions aredetermined using the massbalance approach, on an annualVerifies compliancewith Mass Balance errorlimits and indicates dataqualitySlight reduction in burden. Nolonger required to report inputsfor each calculation.11Original Reporting Element(s)Information Providedby Reporting Element(s)Revised or ReplacementReporting Element(s)Information Providedby Revised Element(s)Net Impact on Burdencalculate the relative and absoluteerrors under §98.123(b)(1), theabsolute and relative errorscalculated under paragraph§98.123(b)(1) report, as well asthe data used in thesecalculations, including quantitiesand their accuracies andprecisions.verification of errorcalculation.basis, if you calculated therelative and absolute errorsunder the former §98.123(b)(1),the overall absolute and relativeerrors calculated for the processunder the former §98.123(b)(1),in tons and decimal fraction,respectively.§98.126(b)(2): The balancedchemical equation that describesthe reaction used to manufacturethe fluorinated GHG product andeach fluorinated GHGtransformation product.Allows emissioncalculations to beverified.Reporting requirementsremoved from the rule; dataelements kept as records.NA Decrease in burden. Fewerdata elements are required tobe reported for mass balanceapproach.§98.126(b)(3)-(b)(5)(3) The mass and chemicalformula of each fluorinated GHGreactant emitted from the processin metric tons.(4) The mass and chemicalformula of the fluorinated GHGproduct emitted from the processin metric tons.(5) The mass and chemicalformula of each fluorinated GHGby-product emitted from theprocess in metric tons.Emissions by process andchemicalFinal §98.126(a)(3): Forfacilities that produce more thanone fluorinated gas product: Foreach generically-identifiedprocess and each fluorinatedGHG group, report the totalGWP-weighted emissions of allfluorinated GHGs in that groupfrom the process, in metric tonsCO2e.Emissions by processand fluorinated GHGgroup, referencing final§98.126(a)(2)identification of processtypeLittle or no net change.Subpart A already requirescalculation of CO2e for eachchemical. Slight burdenincrease associated withadding up CO2e emissions ofeach chemical to reportemissions by fluorinated GHGgroup. Slight burden decreaseassociated with reportingmaximum of 12 fluorinatedGHG groups rather than largernumber of individualchemicals.§98.126(b)(6)-(b)(8)(6) The mass and chemicalformula of each fluorinecontaining reactant that is fed intoIn conjunction withcurrent §98.126(b)(3)-(b)(5) and§98.126(b)(10)-(b)(12),allows emissionReporting requirementsremoved from rule; dataelements kept as records.NA Decrease in burden. Fewerdata elements are required tobe reported for mass balanceapproach12Original Reporting Element(s)Information Providedby Reporting Element(s)Revised or ReplacementReporting Element(s)Information Providedby Revised Element(s)Net Impact on Burdenthe process (metric tons).(7) The mass and chemicalformula of each fluorinecontaining product produced bythe process (metric tons).(8) If you use §98.123(b)(4) toestimate the total mass of fluorinein destroyed or recapturedstreams, report the following.(i) The mass and chemicalformula of each fluorinecontaining product that isremoved from the process and fedinto the destruction device (metrictons).(ii) The mass and chemicalformula of each fluorinecontaining by-product that isremoved from the process and fedinto the destruction device (metrictons).(iii) The mass and chemicalformula of each fluorinecontaining reactant that isremoved from the process and fedinto the destruction device (metrictons).(iv) The mass and chemicalformula of each fluorinecontaining by-product that iscalculations to beverified.13Original Reporting Element(s)Information Providedby Reporting Element(s)Revised or ReplacementReporting Element(s)Information Providedby Revised Element(s)Net Impact on Burdenremoved from the process andrecaptured (metric tons).(v) The demonstrated destructionefficiency of the destructiondevice for each fluorinated GHGfed into the device from theprocess in greater than traceconcentrations (fraction).§98.126(b)(9): If you use§98.123(b)(15) to estimate thetotal mass of fluorine in destroyedor recaptured streams, report thefollowing.(i) The mass of fluorine in eachstream that is fed to thedestruction device.(ii) The mass of fluorine that isrecaptured.(iii) The weighted-averagedestruction efficiency of thedestruction device calculated foreach stream under §98.123(b)(16)Allows emissioncalculations to beverified.Reporting requirementsremoved from the rule; dataelements kept as records.NA Decrease in burden. Fewerdata elements are required tobe reported for mass balanceapproach.§98.126(b)(10)-(b)(12):(10) The fraction of the massemitted that consists of eachfluorine-containing reactant.(11) The fraction of the massemitted that consists of thefluorine-containing product.In conjunction withcurrent §98.126(b)(3)-(b)(8), allows emissioncalculations to beverified.Reporting requirementsremoved from rule; dataelements kept as records.NA Decrease in burden. Fewerdata elements are required tobe reported for mass balanceapproach.14Original Reporting Element(s)Information Providedby Reporting Element(s)Revised or ReplacementReporting Element(s)Information Providedby Revised Element(s)Net Impact on Burden(12) The fraction of the massemitted that consists of eachfluorine-containing by-product.§98.126(b)(13): The methodused to estimate the total mass offluorine in destroyed orrecaptured streams (specify§98.123(b)(4) or (15)).Provides method used fordestroyed or recapturedstreams.No change except renumberedasFinal §98.126(b)(2)NA No change in burden.§98.126(c) Intro paragraph: Forthe emission factor or emissioncalculation factor approach,report fluorinated GHG emissionsfor each process, and reportseparately the emissions fromtransformation processes wherefluorinated reactants are producedat another facility.General reporting foremission factor andemission calculationfactor approach, for eachprocess.§98.126(c) Intro paragraph:For the emission factor oremission calculation factorapproach, report fluorinatedGHG emissions for eachgenerically-identified process.General reporting foreach genericallyidentified process.No change in burden.§98.126(c) (1): The identity andquantity of the process activityused to estimate emissions (e.g.,tons of product produced or tonsof reactant consumed).In conjunction withemission factor reportedunder §98.126 (c)(2),allows emissioncalculations to beverified.Also allows calculation ofan implied emissionfactor (emissions/activity), which providesa means of comparing theemissiveness of processesthat have differentactivity levels.Emissiveness may varydue to inherent processdifferences (e.g.,byproduct generationrates) or due to differentFinal §98.126(a)(6): For eachgenerically identified process,the range, based on Table L-1,that encompasses the effectivedestruction efficiency calculatedfor that process on a CO2e basis.Other related rule paragraphs:Final §98.123(h).Provides insight into thelevel of emissionscontrol for the process.Slight increase in burden.Facilities are already requiredto determine the destructionefficiency of the destructiondevice by fluorinated GHG,and are also already requiredto track the up-time or downtime of the destruction device.The final reportingrequirement will require somecalculation from these data todetermine the effectivedestruction efficiency and tocategorize as one of the rangesin the final rule.15Original Reporting Element(s)Information Providedby Reporting Element(s)Revised or ReplacementReporting Element(s)Information Providedby Revised Element(s)Net Impact on Burdenlevels of emissionscontrol.§98.126(c)(2): The site-specificprocess-vent-specific emissionfactor or emission calculationfactor for each process vent.In conjunction with theactivity reported under§98.126 (c)(2), allowsemission calculations tobe verified.§98.126(c)(2): [Reserved].NANo change in burden.Facilities will enter data intoIVT rather than e-GGRT.§98.126(c)(3): The mass of eachfluorinated GHG emitted fromeach process vent (metric tons).§98.126(c)(4): The mass of eachfluorinated GHG emitted fromequipment leaks (metric tons).Emissions by process andchemical; identificationof emissions type (ventedvs. leaked)Final §98.126(c)(3): For eachfluorinated GHG group, the totalGWP-weighted mass of allfluorinated GHGs in that groupemitted from all process ventscombined, in metric tons ofCO2e.Final §98.126(c)(4): For eachfluorinated GHG group, the totalGWP-weighted mass of allfluorinated GHGs in that groupemitted from equipment leaks,in metric tons CO2e.Emissions by processand fluorinated GHGgroup; identification ofemissions type (ventedvs. leaked).Little or no net change.§98.126 (d):Reporting formissing data.Where missing datahave been estimated pursuant to§98.125, you must report thereason the data were missing, thelength of time the data weremissing, the method used toestimate the missing data, and theestimates of those data.aProvides informationregarding nature andscope of missing data.Final §98.126(d):Reporting formissing data.Final §98.126(d)(1): Thegenerically-identified processfor which data were missing.Final §98.126(d)(2): The reasonthe data were missing, the lengthof time the data were missing,and the method used to estimatethe missing data.No change. No change in burden.16Original Reporting Element(s)Information Providedby Reporting Element(s)Revised or ReplacementReporting Element(s)Information Providedby Revised Element(s)Net Impact on BurdenFinal §98.126(d)(3): Estimatesof the missing data for allmissing data associated withdata elements required to bereported.§98.126(e):Reporting ofdestruction device excessemissions data.Each fluorinatedgas production facility thatdestroys fluorinated GHGs mustreport the excess emissions thatresult from malfunctions of thedestruction device, and theseexcess emissions would bereflected in the fluorinated GHGestimates in §98.123(b) and (c).Such excess emissions wouldoccur if the destruction efficiencywas reduced due to themalfunction.Provides excessemissions that result fromdestruction devicemalfunctions.Final §98.126(e):Reporting ofdestruction device excessemissions data. Each fluorinatedgas production facility thatdestroys fluorinated GHGs mustreport the excess emissions thatresult from malfunctions of thedestruction device, and theseexcess emissions must bereflected in the fluorinated GHGestimates in former §98.123(b)and in §98.123 (c). Such excessemissions would occur if thedestruction efficiency wasreduced due to the malfunction.Technical correctionchanges “would” to“must.No change in burden.§98.126(f)(1): Destructionefficiency of each destructiondevice for each fluorinated GHGwhose destruction is reflected in98.123.§98.126(f)(5): If you make achange to the destruction devicethat would affect its destructionefficiencies, submit a revisedreport that includes the reviseddestruction efficiencies, by March31 of the year following thechange.Provides insight into thelevel of emissions controlfor processes.§98.126(f)(1): [Reserved]§98.126(f)(5): [Reserved]NA No change in burden.Facilities will enter data intoIVT rather than e-GGRT.17Original Reporting Element(s)Information Providedby Reporting Element(s)Revised or ReplacementReporting Element(s)Information Providedby Revised Element(s)Net Impact on Burden§98.126(f)(2): Chemical identityof the fluorinated GHG used inthe performance test conducted todetermine destruction efficiency.§98.126(f)(3): Date of the mostrecent destruction device test.§98.126(f)(4): Name of allapplicable Federal or Stateregulations that apply to thedestruction process.Details on the emissionstesting conducted ondestruction devices andapplicable regulations.No change. No change. NA§98.126(g)(1): For destruction ofpreviously produced fluorinatedGHG, report the mass offluorinated GHG fed to thedestruction device.In conjunction with§98.126(g)(2), allowsemission calculations tobe verified.Final §98.126(g)(1): [Reserved] NA No change in burden.Facilities will enter data intoIVT rather than e-GGRT.§98.126(g)(2): For destruction ofpreviously produced fluorinatedGHG, report the mass offluorinated GHG emitted from thedestruction device.Emissions by process andchemical.No change. No change. NA§98.126(h)(1): For venting ofresidual fluorinated GHGs fromcontainers, report the mass of theresidual fluorinated GHG ventfrom each container size and typeannually.Emissions by containersize and type and bychemical.Final§98.126(h)(1): Forventing of residual fluorinatedGHGs from containers, reportthe mass of the residualfluorinated GHG vented fromcontainers annually.Emissions by chemical. Slight decrease in burden.§98.126(h)(2): For venting of Provides heel factorFinal§98.126(h)(2): [Reserved]NA No change in burden.18Original Reporting Element(s)Information Providedby Reporting Element(s)Revised or ReplacementReporting Element(s)Information Providedby Revised Element(s)Net Impact on Burdenresidual fluorinated GHGs fromcontainers, report the heel factorfor each container size and type.information.Facilities will enter data intoIVT rather than e-GGRT.§98.126(i), 98.126(j): NOCHANGENANA NA NA19Table 2. Comparison of Original Provisions in theSubpart L Rule vs. the Final Provisions (Long-termSubpart L RuleChanges)aOriginal Provision(s)Revised or Replacement ProvisionNet Impact on Burden§98.123(a): Use a value of 2000 forfluorinated GHGs that do not have GWPs listedin Table A-1 to subpart A.Other related rule paragraphs:§98.123(c)(1)(v)§98.124(c)(2)Final §98.123(a):[Reserved].Final Table A-1 to subpart A: Included 12 fluorinatedGHG groups with default GWPs.Other related rule paragraphs:Final §98.123(c)(1)(v)Final §98.124(c)(2)Final §98.126Final §98.128No change in burden§98.123 (header paragraph):Facilities mustcalculate the fluorinated GHG emissions fromeach process using either the mass balancemethod or the emission factor or emissioncalculation factor method.§98.123(b): Calculations for the mass balanceapproach for determining emissions fromprocesses.Other related rule paragraphs:§98.124(b):Mass-balance monitoringrequirements.§98.123 (header paragraph):Facilities must calculatethe fluorinated GHG emissions from each process usingeither the emission factor or emission calculationfactormethod. (Option to use the mass balance approach isremoved for reporting year 2015 and later reportingyears.)Final §98.123(b):Removal of calculations for the massbalance approach for reporting year 2015 and laterreporting years.Other related rule paragraphs:Final §98.124(b):Removal of monitoring requirementsfor the mass balance approach for reporting year 2015and later reporting years.See accompanying memorandum, “EconomicAnalysis of Amendments to Subpart L ReportingProvisions” for a discussion of the impact ofremoving the option to use the mass balanceapproach.§98.123(c)(1)(vi): Use of an alternative GWPvalue for fluorinated GHGs that do not haveGWPs listed in Table A-1 to subpart A; therequest must be made by February 28, 2011.Other related rule paragraphs:Final §98.123(c)(1)(vi):[Reserved]Expired provision removed; no change in burden.§98.123(g)(2)(ii): Calculation of residual massFinal §98.123(g)(2)(ii): Calculation of residual mass in No change in burden.20Original Provision(s)Revised or Replacement ProvisionNet Impact on Burdenin cylinders/containers, when monitoring thepressure.cylinders/containers, when monitoring the pressure.§98.124(c)(1): For the EF approach, facilitiesmust test for any fluorinated GHG that occursin more than trace concentrations.Other related rule paragraphs:§98.124(c)(5)Final §98.124(c)(1): For the EF approach, facilitiesmust test for any fluorinated GHG identified in theinitial scoping speciation or that occurs in more thantrace concentration in the vent stream or in the inlet tothe destruction device. If a fluorinated GHG is notdetected in the testing but was identified in the scopingspeciation or is known to occur, facilities assumethatfluorinated GHG is emitted at half the detection limit.Other related rule paragraphs:Final §98.124(c)(5)As discussed in accompanying memorandum,“Economic Analysis of Amendments to SubpartL Reporting Provisions,” this amendment is notexpected to change the burden calculated for the2010 final subpart L. Testing and emission factordevelopment for fluorinated GHGs identified inthe scoping speciation were already included inthe initial cost analysis for the originalpromulgated rule.aAmendments and revisions to §98.122 of subpart Lare not included in this table; the amendments andrevisions in §98.122 are in general captured in othersections, such as §98.126 Reporting Requirements.