1 

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 Greenhouse Gas Reporting Rule 

for the Fluorinated Gas Production Source Category (Subpart L) 

Final 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 EPA is revising the reporting and recordkeeping requirements for 

subpart L. The final changes to subpart L include:

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

detail in which emissions are reported. 

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

• Clarifying the process vent testing requirements for 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 disclosure 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 being useful in the absence of other 

deferred inputs for which reporting requirements are 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 elements”) and disclosure concerns have 

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

and performs electronic verification. 

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

equations for subpart L reporters using the inputs verification tool. 
2 

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

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

Reporting More Aggregated Data. The final 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 removing or revising, the information provided by that reporting element, the 

reporting element (if any) with which EPA is replacing 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 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 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 simply replaces or updates 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 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 amending 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 amending the reporting requirements associated with the MB 

approach; those changes are analyzed in Table 1. 

 

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. 
3 

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. 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 more 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 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 or occurring in more than trace concentrations in the vent 

stream or inlet to the destruction device. 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 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 Chemical-Specific and Default GWPs on Subpart L Rule Applicability. 

The applicability impacts to subpart L for adding 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. 

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

The impact on other subpart L provisions from adding 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. The EPA is eliminating the reporting of 

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

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

(IVT) within eGGRT. 
4 

The EPA has determined that there will be no cost increase 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 reporters 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 Table 1 below, however, the removal of the 

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

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

facilities that used the mass-balance method in 2011.) 

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 inputs verification tool. Based on this technical 

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

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

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

(12 facilities x 1 hour = 12 hour. 12 technical hours 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, Recordkeeping, and Verification Requirements 

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

Recordkeeping Changes. The changes to the GHGRP include 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 requiring reporters who use the inputs verification 

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

equations” data elements. This list of data elements 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 create any additional burden for a reporting 

facility in addition to the recordkeeping burden estimated in the 2010 Impact Analysis.
5 

Table 1. Comparison of Original Reporting Elements in the Subpart L Rule vs. the Final Reporting Elem

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) N

§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. Final §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 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 c

§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).

Final §98.126(a)(1): The information in paragraphs (a)(2), (3), (4), (5), and (6) of this section must be reported annually. 

Frequency of reporting under §98.126(a).

No cFacigene(See revissubp

§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 

Final §98.126(a)(2): For each production and transformation process at the facility, you must: (i) Provide a number, letter, or 

Process identification by process type, subtype, and letter or number 

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6 

Original Reporting Element(s) 

Information Provided 

by Reporting Element(s) 

Revised or Replacement 

Reporting Element 

Information Provided 

by Revised Element(s) N

other identifier for the process, consistent from year to year. (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). 

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§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 

Final §98.126(a)(3): For facilities that produce more than 

one fluorinated gas product: For each generically identified process and each fluorinated GHG group, report the total GWP-weighted emissions of all fluorinated GHGs in that group from the process, in metric tons CO2e. 

Emissions by process and fluorinated GHG group, referencing final §98.126(a)(2) identification of process type. 

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7 

Original Reporting Element(s) 

Information Provided 

by Reporting Element(s) 

Revised or Replacement 

Reporting Element(s) 

Information Provided 

by Revised Element(s) N

§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. 

Final §98.126(a)(4)(i): For facilities that produce more than one fluorinated gas product: For 

each fluorinated GHG with emissions of 1,000 metric tons of CO2e or more from 

production and transformation processes summed across the facility as a whole, report the total mass in metric tons of the 

fluorinated GHG emitted from production and transformation processes summed across the facility as a whole. Identify the fluorinated GHG group, as applicable. 

Emissions by facility and chemical. 

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Final §98.126(a)(4)(ii): For facilities that produce more than one fluorinated gas product: For all other fluorinated GHG emitted from production and transformation processes, report total GWP-weighted emissions from production and transformation processes of those fluorinated GHGs by fluorinated GHG group, summed across the facility as a whole, in metric tons of CO2e. 

Emissions by facility and fluorinated GHG group. 

Final §98.126(a)(5): Where facilities produce only one fluorinated gas product but emissions consist of a major fluorinated GHG constituent of a fluorinated gas product, and the product is sold or transferred to another person: report the 

Emissions by facility and chemical. 

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8 

Original Reporting Element(s) 

Information Provided 

by Reporting Element(s) 

Revised or Replacement 

Reporting Element(s) 

Information Provided 

by Revised Element(s) N

total mass in metric tons of each fluorinated GHG emitted from production and transformation processes and that is a major fluorinated GHG constituent of the product. 

prodthan alreaOO a

Final §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: Aggregate and report the total GWPweighted emissions from production and transformation processes of fluorinated GHGs by fluorinated GHG group for the facility as a whole, in metric tons of CO2e. 

Emissions by facility and fluorinated GHG group 

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§98.126(a)(3): The chemical identities of the contents of the stream(s) (including process, emissions, and destroyed streams) analyzed under the initial scoping 

Preliminary identification of fluorinated GHGs that may be emitted from the process. 

Reporting requirement removed from rule; data element kept as record. 

NA Decr
9 

Original Reporting Element(s) 

Information Provided 

by Reporting Element(s) 

Revised or Replacement 

Reporting Element(s) 

Information Provided 

by Revised Element(s) N

speciation of fluorinated GHG at § §98.124(a), by 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 Decr

§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. 

Final §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., process-ventspecific emission factor, process-vent-specific emission calculation factor, or mass balance,. Final §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 (for RY 2011 through 2014 only). 

Calculation method used for each process, process vent, and fluorinated GHG group. 

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§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), 

Final §98.126(a)(6): For each generically-identified process, the range, based on Table L-1, 

Provides insight into the level of emissions control for the process. 

SlighFacilto de
10 

Original Reporting Element(s) 

Information Provided 

by Reporting Element(s) 

Revised or Replacement 

Reporting Element(s) 

Information Provided 

by Revised Element(s) N

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. 

that encompasses the effective destruction efficiency calculated for that process on a CO2e basis. 

Other related rule paragraphs: Final §98.123(h). 

efficidevicand ato tratime The frequicalcudeterdestrcategin the 

§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 amemAnalSubpProvthe imoptioapproindivrequibalanbelow

§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 

Final §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 

Slighlongefor e
11 

Original Reporting Element(s) 

Information Provided 

by Reporting Element(s) 

Revised or Replacement 

Reporting Element(s) 

Information Provided 

by Revised Element(s) N

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. 

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. 

§98.126(b)(2): The balanced chemical equation that describes the reaction used to manufacture the fluorinated GHG product and each fluorinated GHG transformation product.

Allows emission calculations to be verified. 

Reporting requirements removed from the rule; data elements kept as records. 

NA Decr

data be reappro

§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 

Final §98.126(a)(3): For facilities that produce more than one fluorinated gas product: For 

each generically-identified process and each fluorinated GHG group, report the total GWP-weighted emissions of all fluorinated GHGs in that group from the process, in metric tons CO2e. 

Emissions by process and fluorinated GHG group, referencing final §98.126(a)(2) identification of process type 

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§98.126(b)(6)-(b)(8)  (6) The mass and chemical formula of each fluorinecontaining reactant that is fed into 

In conjunction with current §98.126(b)(3)-(b)(5) and §98.126(b)(10)-(b)(12), allows emission 

Reporting requirements removed from rule; data elements kept as records. 

NA Decr

data be reappro
12 

Original Reporting Element(s) 

Information Provided 

by Reporting Element(s) 

Revised or Replacement 

Reporting Element(s) 

Information Provided 

by Revised Element(s) N

the process (metric tons). (7) The mass and chemical formula of each fluorinecontaining product produced by the process (metric tons). (8) If you use §98.123(b)(4) to estimate the total mass of fluorine in destroyed or recaptured streams, report the following. (i) The mass and chemical formula of each fluorinecontaining product that is removed from the process and fed into the destruction device (metric tons). (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). (iii) The mass and chemical formula of each fluorinecontaining reactant that is removed from the process and fed into the destruction device (metric tons). (iv) The mass and chemical formula of each fluorinecontaining by-product that is 

calculations to be verified. 
13 

Original Reporting Element(s) 

Information Provided 

by Reporting Element(s) 

Revised or Replacement 

Reporting Element(s) 

Information Provided 

by Revised Element(s) N

removed from the process and recaptured (metric tons). (v) The demonstrated destruction efficiency of the destruction device for each fluorinated GHG fed into the device from the process in greater than trace concentrations (fraction). §98.126(b)(9): If you use §98.123(b)(15) to estimate the total mass of fluorine in destroyed or recaptured streams, report the following. (i) The mass of fluorine in each stream that is fed to the destruction device. (ii) The mass of fluorine that is recaptured. (iii) The weighted-average destruction efficiency of the destruction device calculated for each stream under §98.123(b)(16) 

Allows emission calculations to be verified. 

Reporting requirements removed from the rule; data elements kept as records. 

NA Decr

data be reappro

§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. 

In conjunction with current §98.126(b)(3)-(b)(8), allows emission calculations to be verified. 

Reporting requirements removed from rule; data elements kept as records. 

NA Decr

data be reappro
14 

Original Reporting Element(s) 

Information Provided 

by Reporting Element(s) 

Revised or Replacement 

Reporting Element(s) 

Information Provided 

by Revised Element(s) N

(12) The fraction of the mass emitted that consists of each fluorine-containing by-product. §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 Final §98.126(b)(2) 

NA No c

§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 c

§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). 

In conjunction with emission factor reported under §98.126 (c)(2), allows emission calculations to be 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 

Final §98.126(a)(6): For each generically identified process, the range, based on Table L-1, that encompasses the effective destruction efficiency calculated for that process on a CO2e basis. 

Other related rule paragraphs: Final §98.123(h). 

Provides insight into the level of emissions control for the process. 

SlighFacilto deefficidevicand ato tratime The frequicalcudeterdestrcategin the 
15 

Original Reporting Element(s) 

Information Provided 

by Reporting Element(s) 

Revised or Replacement 

Reporting Element(s) 

Information Provided 

by Revised Element(s) N

levels of emissions control. 

§98.126(c)(2): The site-specific process-vent-specific emission factor or emission calculation factor for each process vent.

In conjunction with the activity reported under §98.126 (c)(2), allows emission calculations to be verified. 

§98.126(c)(2): [Reserved]. NA No c

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§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)

Final §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. 

Final §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).

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§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 missing, the method used to estimate the missing data, and the estimates of those data. a

Provides information regarding nature and scope of missing data. 

Final §98.126(d): Reporting for 

missing data. Final §98.126(d)(1): The generically-identified process for which data were missing. Final §98.126(d)(2): The reason the data were missing, the length of time the data were missing, and the method used to estimate the missing data. 

No change. No c
16 

Original Reporting Element(s) 

Information Provided 

by Reporting Element(s) 

Revised or Replacement 

Reporting Element(s) 

Information Provided 

by Revised Element(s) N

Final §98.126(d)(3): Estimates of the missing data for all missing data associated with data elements required to be reported. 

§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. 

Final §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 former §98.123(b) and in §98.123 (c). Such excess emissions would occur if the destruction efficiency was reduced due to the malfunction. 

Technical correction changes “would” to “must. 

No c

§98.126(f)(1): Destruction efficiency of each destruction device for each fluorinated GHG whose destruction is reflected in 98.123. §98.126(f)(5): If you make a change to the destruction device that would affect its destruction efficiencies, submit a revised report that includes the revised destruction efficiencies, by March 31 of the year following the change. 

Provides insight into the level of emissions control for processes. 

§98.126(f)(1): [Reserved] §98.126(f)(5): [Reserved] 

NA No c

FacilIVT 
17 

Original Reporting Element(s) 

Information Provided 

by Reporting Element(s) 

Revised or Replacement 

Reporting Element(s) 

Information Provided 

by Revised Element(s) N

§98.126(f)(2): Chemical identity of the fluorinated GHG used in the performance test conducted to determine destruction efficiency. §98.126(f)(3): Date of the most recent destruction device test. §98.126(f)(4): Name of all applicable Federal or State regulations that apply to the destruction process.

Details on the emissions testing conducted on destruction devices and applicable regulations. 

No change. No change. NA 

§98.126(g)(1): For destruction of previously produced fluorinated GHG, report the mass of fluorinated GHG fed to the destruction device. 

In conjunction with §98.126(g)(2), allows emission calculations to be verified. 

Final §98.126(g)(1): [Reserved] NA No c

FacilIVT 

§98.126(g)(2): For destruction of previously produced fluorinated GHG, report the mass of fluorinated GHG emitted from the destruction device.

Emissions by process and chemical. 

No change. No change. NA 

§98.126(h)(1): For venting of residual fluorinated GHGs from containers, report the mass of the residual fluorinated GHG vent from each container size and type annually.

Emissions by container size and type and by chemical. 

Final §98.126(h)(1): For 

venting of residual fluorinated GHGs from containers, report the mass of the residual fluorinated GHG vented from containers annually. 

Emissions by chemical. Sligh

§98.126(h)(2): For venting of Provides heel factor Final §98.126(h)(2): [Reserved] NA No c
18 

Original Reporting Element(s) 

Information Provided 

by Reporting Element(s) 

Revised or Replacement 

Reporting Element(s) 

Information Provided 

by Revised Element(s) N

residual fluorinated GHGs from containers, report the heel factor for each container size and type.

information. Facil

IVT 

§98.126(i), 98.126(j): NO CHANGE 

NA NA NA NA 
19 

Table 2. Comparison of Original Provisions in the Subpart L Rule vs. the Final Provisions (Long-term Su

Changes) a

Original Provision(s) Revised or Replacement Provision Net Impact 

§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(c)(1)(v) §98.124(c)(2)

Final §98.123(a): [Reserved]. Final Table A-1 to subpart A: Included 12 fluorinated GHG groups with default GWPs. Other related rule paragraphs: Final §98.123(c)(1)(v) Final §98.124(c)(2) Final §98.126 Final §98.128

No change in burden 

§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 isremoved for reporting year 2015 and later reportingyears.) Final §98.123(b): Removal of calculations for the mass balance approach for reporting year 2015 and later reporting years. Other related rule paragraphs: Final §98.124(b): Removal of monitoring requirements for the mass balance approach for reporting year 2015 

and later reporting years. 

See accompanying memAnalysis of AmendmentProvisions” for a discussremoving the option to uapproach. 

§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: 

Final §98.123(c)(1)(vi): [Reserved] Expired provision remov

§98.123(g)(2)(ii): Calculation of residual mass Final §98.123(g)(2)(ii): Calculation of residual mass in No change in burden. 
20 

Original Provision(s) Revised or Replacement Provision Net Impact 

in cylinders/containers, when monitoring the pressure. 

cylinders/containers, when monitoring the pressure.

§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) 

Final §98.124(c)(1): For the EF approach, facilities must test for any fluorinated GHG identified in the

initial scoping speciation or that occurs in more than trace concentration in the vent stream or in the inlet to the destruction device. 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: Final §98.124(c)(5) 

As discussed in accompa“Economic Analysis of AL Reporting Provisions,” expected to change the b2010 final subpart L. Tedevelopment for fluorinathe scoping speciation wthe initial cost analysis fopromulgated 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 gen

sections, such as §98.126 Reporting Requirements.