EPA Proposes Revised Reporting Criteria For Coolants Used by Electronics Makers

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Electronics manufacturers would be required to report more of their greenhouse gas emissions from coolants used during production as part of an Environmental Protection Agency proposed rule that revises the reporting criteria for fluorinated heat transfer fluids.

The revision is part of a proposed rule to be published in the Federal Register Sept. 9 that also includes several proposed clarifications to the greenhouse gas reporting requirements for the petroleum and natural gas industry as well. EPA is proposing the various revisions to its mandatory greenhouse gas reporting rule at 40 C.F.R. Part 98 in response to petitions for reconsideration from a variety of industry groups.

EPA issued the reporting requirements for electronics manufacturing and petroleum and natural gas systems in 2010 (75 Fed. Reg. 74,774; 75 Fed. Reg. 74,458; 216 DEN A-9, 11/10/10).

Coolant Emissions Underreported

The 3M Co. petitioned EPA in January to reconsider how the agency defined fluorinated coolants for the purposes of the greenhouse gas reporting rule. Though EPA had included fluorinated greenhouse gases in its definition of heat transfer fluids, it had limited the reporting requirements to those with a vapor pressure greater than one millimeter of mercury at 25 degrees Celsius.

However, 3M said vapor pressure does not accurately predict greenhouse gas emissions from the coolants and EPA's reporting requirements would “result in dramatic under reporting of heat transfer fluid use and emissions.”

EPA's proposed revision to the definition of fluorinated heat transfer fluids would clarify that the vapor pressure portion does not apply for the purposes of the reporting rule.

EPA intends to finalize the rule by the end of 2011, but it is seeking comment on whether it would be practical for electronics manufacturers to implement this revised reporting requirements for greenhouse gas emissions from coolants by March 31, 2012, when the next reports are due. EPA also has proposed to extend that deadline until Sept. 28, 2012 (76 Fed. Reg. 47,392; 150 DEN A-3, 8/4/11).

Reporting Requirements Clarified

Additionally, EPA proposed several technical clarifications to the reporting requirements for petroleum and natural gas systems in response to requests from several industry groups, including the American Petroleum Institute, the American Gas Association, and the Interstate Natural Gas Association of America.

The revisions would provide “greater flexibility or simplified calculation methods” when reporting greenhouse gases from several petroleum and natural gas sources. Because the proposed revisions are considered minor and are intended to ease the reporting burdens on affected industries, EPA said they would take effect before the reporting deadline in 2012.

In the only revision it said would be significant, EPA would require oil and natural gas companies to report greenhouse gas emissions from certain wells and storage tanks on a county level and by geologic formation rather than by the field designations used by the Energy Information Administration. EPA said the field designations can be ambiguous, while counties are “readily identifiable and provide clear geographic boundaries.”

If companies find it infeasible to calculate their emissions by county by the 2012 reporting deadline, EPA said they would be allowed to report their emissions using alternate methods known as best available monitoring methods.

Other Proposed Revisions

Other proposed revisions include a clarification on reporting vented emissions separately from flared emissions and allowing companies to directly measure emissions from leaking dump valves in transportation storage tanks rather than implementing other leak detection methods.

EPA will accept comments on the proposed rule until Oct. 11. Comment can be made at http://www.regulations.gov and should reference docket No. EPA-HQ-OAR-2011-0512.

By Andrew Childers

For more information, contact Carole Cook in EPA's Office of Atmospheric Programs at (202) 343- 9263 or GHGReportingRule@epa.gov .