Protection of Stratospheric Ozone: Updates Related to the Use of Ozone-Depleting Substances as Process Agents
Controlled Substances ODS Ozone-Depleting-Substances Process Agents
2023-11-14 2023-12-12
EPA-HQ-OAR-2022-0707-0017 EPA-HQ-OAR-2022-0707-0019
05:00:00 05:00:00
https://api.regulations.gov/v4/comments/EPA-HQ-OAR-2022-0707-0017 https://api.regulations.gov/v4/comments/EPA-HQ-OAR-2022-0707-0019
Anonymous Anonymous
Anonymous Anonymous
The Montreal Protocol is deemed one of the most successful international environmental treaties as it was the first treaty to achieve ratification by all countries in the world. It has created unprecedented results in reducing ozone-depleting substances (ODS) and greenhouse gases. According to the UN Environment Programme, the Parties have phased out 98% of ODS globally compared to 1990 levels. With a significant portion of ODS being greenhouse gases, the Protocol has also contributed to protecting the climate and recovering the ozone layer. With the United States leaving and re-entering the Paris Agreement, it is essential to demonstrate that the country is still committed to international cooperation and environmental protection. With more transparent reporting and recordkeeping, the US can demonstrate its commitment to improving climate protection globally and accurately documenting its contribution. The EPA has put concerted efforts into replacing ODS with non-ozone-depleting substances, but there are still circumstances when using ODS is necessary. Decision X/14 of the Protocol permits the use of ODS as process agents. All parties must submit an annual report detailing process agent emissions, containment technology, and production and importation of controlled substances for use as process agents to the Secretariat. The proposed rule by EPA defines precise recordkeeping and reporting requirements for US entities.EPA has compared the difference between applying TRI and GHGRP approaches. The TRI approach does not require the entity to report the source of its information or the emission factors used. With EPA suspecting only six entities will be impacted by this proposed rule, none of which are small entities, the GHGRP approach is more reasonable. Because this approach would require the entity to use specific methodology and report more detailed information, the data is more consistent and manageable for EPA to validate.In EPAs draft memo for emission reporting for process agents, the methods described for different processes are often engineering calculations, chemical engineering principles, or engineering assessments, which allow estimates to be created for various process components based on specific assumptions and knowledge. These methods are more likely to produce more reliable emissions data than the mass balance approach. A mass balance approach requires the quantification of the process inputs and outputs. When calculating ODS emissions from process agents, the accuracy of the inputs and outputs of the process is a concern, so the emission factors produced from a mass balance method may be more unreliable. Subsequently, setting one testing method for different processes instead of allowing multiple is reasonable. Although permitting multiple methods would enable the entities to use the form best suited to their available resources and expertise, there are few entities that this rule impacts. Consistent, validated information is better for evaluating process agent emissions in the United States and provides more reliable information to the Secretariat. Based on this review, EPA should finalize the rule as proposed. The rule will provide more consistent, reliable, validated data to be reported to the Secretariat. With the United States making up the most consumption of ODS for process agents and creating the most emissions out of any country under the Montreal Protocol, improving recordkeeping and reporting is vital to accurately representing emissions in the United States and understanding the global impact of those emissions.  Comments provided in the uploaded file.  