GHG Inventory Guidance for Fugitive Emissions
GHG Inventory Guidance for Fugitive Emissions
December 2023
The U.S. EPA Center for Corporate Climate Leadership’s (The Center) GHG guidance is based on The Greenhouse Gas
Protocol: A Corporate Accounting and Reporting Standard (GHG Protocol) developed by the World Resources Institute
(WRI) and the World Business Council for Sustainable Development (WBCSD). The Center’s GHG guidance is meant to
extend upon the GHG Protocol to align more closely with EPA-specific GHG calculation methodologies and emission
factors, and to support the Center’s GHG management tools.
For more information regarding the Center for Corporate Climate Leadership, visit [Link]/climateleadership.
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Table of Contents
Table of Contents
Introduction ............................................................................................................................. 1
Greenhouse Gases Included ..................................................................................................... 1
Completeness ..........................................................................................................................14
Documentation .......................................................................................................................16
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Fugitive Emissions Guidance Section 1: Introduction
Introduction
An important category of scope 1 direct greenhouse gas (GHG) are fugitive emissions, which result from the direct release
to the atmosphere of GHG compounds from various types of equipment and processes. This guidance document focuses
on several fugitive emissions sources that are common for organizations in many sectors: refrigeration and air conditioning
systems, fire suppression systems, and the purchase and release of industrial gases.
Historically, air conditioning and refrigeration equipment utilized various Ozone Depleting Substances (ODSs), primarily
chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs). However, in accordance with the Clean Air Act
Amendments of 1990 (Title VI) and the Montreal Protocol, these ODSs are being phased out of manufacture and use in
the United States.
Hydrofluorocarbons (HFCs) and, to a lesser extent, perfluorocarbons (PFCs) are used as substitutes for the regulated ODSs.
In addition, some air conditioning and refrigeration systems use non-halogenated refrigerants such as ammonia, carbon
dioxide (CO2), propane, or isobutane. Also, some fire suppression equipment, which historically used ozone-depleting
halons, use carbon dioxide (CO2), inert gases, and other substances.
Emissions from the refrigeration and air conditioning sector result from the manufacturing process, from leakage and
service over the operational life of the equipment, and from disposal at the end of the useful life of the equipment. These
gases’ global warming potential (GWP) is typically greater than 1,000 times that of CO2, so their potential impact on
climate change can be significant. By the same token, any reductions of these gases can have a large potential benefit.
This guidance document addresses the following emissions from owned or leased sources that are within an
organization’s inventory boundary:
• Emissions from users of refrigeration and air conditioning equipment including household refrigeration, domestic air
conditioning and heat pumps, mobile air conditioning, chillers, retail food refrigeration, cold storage warehouses,
refrigerated transport, industrial process refrigeration, and commercial unitary air conditioning systems.
• Emissions from fixed and portable fire suppression equipment.
• Direct emissions from purchased industrial gases. These gases can be used in processes such as manufacturing,
testing, or laboratory applications.
This document does not address fugitive emissions within the supply chain (e.g., refrigerated shipping vessels), or
emissions from aerosols, solvent cleaning, foam blowing, or other applications.
Ozone depleting substances include numerous compounds such as CFCs, HCFCs, and halons, all of which are GHGs. As
mentioned, these ODSs are being phased out of production due to their ozone depleting properties. However, some
entities may still use these substances directly or in blends within refrigeration, air conditioning, or fire suppression
equipment.
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Fugitive Emissions Guidance Section 1: Introduction
It is customary to exclude CFCs, HCFCs, and halons from GHG inventories because they are regulated and are being phased
out by the Clean Air Act. These substances are also excluded from GHG inventories because their global warming impact is
complicated by the fact that they deplete stratospheric ozone, which is a GHG. The GHG Protocol allows for reporting of
these ODSs as separate memo items on an organization’s GHG inventory. They are reported as total release of gases, but
no GWP values are applied, and they do not contribute to an organization’s total CO2-equivalent emissions inventory.
Therefore, organizations that currently use ODSs and switch to HFCs or PFCs may show an increase in their overall GHG
emissions inventory. Documenting the use of these ODSs will help communicate the reasons for this increase.
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Fugitive Emissions Guidance Section 2: Methods for Calculating Emissions
Four methods with varying levels of accuracy and required data collection are outlined in this guidance to calculate GHG
emissions. Organizations may calculate fugitive GHG emissions from refrigeration and air conditioning equipment, fire
suppression systems, or purchased industrial gases with one of the following methods.
Section 2.1 describes a preliminary Screening Method to estimate emissions from refrigeration, air conditioning, and fire
suppression equipment based on the type of equipment used and emission factors. This method requires the least actual
data collection and is not applicable for quantifying emissions from purchased gases. It is recommended that this method
be used only as a screening tool because the emissions factors used in the approach are highly uncertain. Emission factors
vary between individual pieces of equipment and vary over time. Even if the amount of refrigerant added to a piece of
equipment has been tracked carefully, allowing the previous leak rate of that equipment to be established, that leak rate
can change after a leak is repaired or as the equipment ages. If emissions from this equipment are determined to be
significant when compared to an organization’s other emission sources (e.g., stationary combustion, mobile sources), then
one of the other methods should be applied to calculate emissions more accurately.
Section 2.2 describes a Method for Purchased Gases which applies to an organization that purchases, uses, and releases
industrial gases. If an organization maintains an inventory of industrial gases or uses equipment that contains a charge of
an industrial gas, similar to a charge of refrigerant in air conditioning equipment, it is recommended that one of the
material balance methods be used.
Section 2.3 describes a Material Balance Method of calculating emissions from the installation, operation, and disposal of
refrigeration and air conditioning equipment. This method is recommended for organizations that maintain their own
equipment and requires available data on the total inventory of refrigerants at the beginning and end of the reporting
period, purchases during the reporting period, and changes in total equipment refrigerant capacity. This material balance
method can also be used to calculate emissions from fire suppression equipment.
Section 2.4 describes a Simplified Material Balance Method that is appropriate for entities that do not maintain and track a
stock of refrigerants, and that have not retrofitted equipment to use a different refrigerant during the reporting period.
This method is recommended for organizations that have contractors service their refrigerant-containing equipment. This
method tracks emissions from equipment installation, operation, and disposal. The method requires data on the quantity
of refrigerant: (a) used to fill new equipment during installation, (b) used to service equipment, and (c) recovered from
1
See Chapter 1 of the GHG Protocol for more on materiality and significance of emissions sources.
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Fugitive Emissions Guidance Section 2: Methods for Calculating Emissions
retiring equipment, as well as the total refrigerant capacities of new and retiring equipment. If notified in advance of the
need for this information, the service contractor should be able to provide it.
Screening Method
The method relies on the use of emission factors which are equipment specific. Therefore, this document provides two
different methods, one for refrigeration and air conditioning equipment and a second for fire suppression equipment. This
method is not applicable for quantifying emissions from purchased gases.
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Fugitive Emissions Guidance Section 2: Methods for Calculating Emissions
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Fugitive Emissions Guidance Section 2: Methods for Calculating Emissions
the reporting period. If the organization makes a bulk purchase and plans on using the gas over multiple years, divide the
bulk amount by the expected years of usage and consider that to be the purchase amount for the current reporting
period, as well as the applicable future reporting periods.
Step 1: Calculate the change in inventory (IB - IE). Equation 5: Calculating Refrigerant Emissions with the
Subtract the amount of refrigerant in inventory at the Material Balance Method
end of the reporting period from the inventory at the Emissions = (IB - IE) + P - S + (CB - CE)
beginning of the reporting period to calculate the change
in inventory. The inventory of refrigerants is defined as the total stored on site in cylinders or other storage. This does not
include refrigerants contained within equipment.
2
The term “refrigerant” is used in this section, but this method can also apply to fire suppressants or industrial gases.
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Fugitive Emissions Guidance Section 2: Methods for Calculating Emissions
Sales and disbursements may include refrigerant: (a) in containers or left in equipment that is sold or disposed of, (b)
returned to suppliers, and (c) sent off-site for recycling, reclamation, or destruction. The amount of refrigerant left in
equipment should be the actual amount, which may be less than the total capacity.
Section 3.3 describes in more detail the type of data that is used in determining emissions.
It may be illustrative to describe how the installation or disposal of equipment impacts the Material Balance Method’s
calculation. If equipment is installed, the refrigerant capacity of that equipment is included in both term P as an acquisition
and in term CE as capacity at the end of the year. As a result, the installation has no net impact on emissions.
If equipment is disposed, the refrigerant capacity of that equipment is included in term CB, as capacity at the beginning of
the year, and the actual amount of refrigerant contained in the equipment upon disposal is included in term S as a
disposition. If the amount of refrigerant contained in the equipment upon disposal equals its refrigerant capacity, the
disposal will have no net impact on emissions. If the actual amount is less than the capacity, the difference is assumed to
represent emissions.
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Fugitive Emissions Guidance Section 2: Methods for Calculating Emissions
Equation 6 should be applied to each type of refrigerant used. Calculating emissions with the Simplified Material Balance
Method requires the following steps for each type of refrigerant:
3
The term “refrigerant” is used in this section, but this method can also apply to fire suppressants or industrial gases.
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Fugitive Emissions Guidance Section 2: Methods for Calculating Emissions
Section 3.4 describes in more detail the type of data that is used in determining emissions.
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Fugitive Emissions Guidance Section 3: Choice of Activity and Emission Factors
Screening Method
The Screening Method requires organizations to determine the following information:
• Type of Equipment
• Number of Units
• Refrigerant or Fire Suppressant Used
• Total Refrigerant or Fire Suppressant Charge for the Equipment (lb.)
The Screening Method is based on the Tier 2 approach from the 2006 Intergovernmental Panel on Climate Change (IPCC)
Guidelines for National Greenhouse Gas Inventories.
The IPCC guidelines also include a table of emission factors for the different phases of the equipment’s life by equipment
type. The IPCC table provides ranges of values for the different emission factors, the percent remaining at disposal, and
the recovery efficiency. However, since this method is intended as a screening approach, it is recommended that the
upper end of the ranges be used. These values are provided in Table 1. The ranges in capacity are provided only for
reference; organizations should use the actual capacity of their equipment.
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Fugitive Emissions Guidance Section 3: Choice of Activity and Emission Factors
Table 1: Default Emission Factors for Refrigeration/Air Conditioning Equipment Type of Equipment
Installation Refrigerant
Emission Operating Remaining at Recovery
Type of Equipment Factor Emissions Disposal Efficiency
Capacity K X (% of y z
(kg) (% of capacity) capacity/yr.) (% of capacity) (% of remaining)
Source: 2019 Refinement to the 2006 IPCC Guidelines for National Greenhouse Gas Inventories, Chapter 7: Emissions of Fluorinated Substitutes
for Ozone Depleting Substances, Table 7.9, Default Estimates for Charge, Lifetime, and Emission Factors for Refrigeration and Air-Conditioning
Systems.
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Fugitive Emissions Guidance Section 3: Choice of Activity and Emission Factors
If beginning and ending capacity values are not known, the following information can be used:
Note: “Refrigerant capacity” refers to the full and proper charge of the equipment rather than to the actual charge, which
may reflect leakage.
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Fugitive Emissions Guidance Section 3: Choice of Activity and Emission Factors
Note: “Refrigerant capacity” refers to the full and proper charge of the equipment rather than to the actual charge, which
may reflect leakage.
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Fugitive Emissions Guidance Section 4: Completeness
Completeness
Forr an organization’s GHG inventory to be complete, it must include all emission sources within the organization’s
inventory boundaries. See Chapter 3 of the GHG Protocol for detailed guidance on setting organizational boundaries and
Chapter 4 of the GHG Protocol for detailed guidance on setting operational boundaries of the inventory.
On an organizational level, an organization’s inventory should include emissions from all applicable facilities or fleets of
vehicles. Completeness of organization-wide emissions can be checked by comparing the list of sources included in the
GHG emissions inventory with those included in other emission’s inventories, environmental reporting, financial reporting,
etc.
At the operational level, an organization should include all GHG emissions from the sources included in their GHG
inventory. Possible GHG emission sources are stationary fuel combustion, combustion of fuels in mobile sources,
purchases of electricity, and process or fugitive emissions. Organizations may refer to this guidance document for
calculating fugitive GHG emissions from air conditioning and refrigeration equipment, as well as fire suppression
equipment and industrial gases, and to the Center’s Guidance documents for calculating emissions from other sources.
When calculating emissions from this equipment use, organizations should include all applicable sources of refrigerant
emissions. If a third party is used for any component of refrigerant tracking, the third party should provide any necessary
information. For the Screening Method, all pieces of equipment of all different types need to be accounted for. For the
Material Balance Methods, all activities and different types of refrigerants or blends should be tracked.
As described in Chapter 1 of the GHG Protocol there is no materiality threshold set for reporting emissions. The materiality
of a source can only be established after it has been assessed. This does not necessarily require a rigorous quantification
of all sources, but at a minimum, an estimate based on available data should be developed for all sources.
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Fugitive Emissions Guidance Section 5: Uncertainty Assessment
Uncertainty Assessment
There is some level of uncertainty associated with all methods of calculating GHG emissions. It is recommended that
organizations attempt to identify the areas of highest uncertainty in their emissions calculations and consider options for
improving the quality of this data in the future.
The Screening Method for estimating emissions is highly uncertain. Factors vary between individual pieces of equipment
and over time. Even if the amount of refrigerant added to a particular piece of equipment has been tracked carefully,
allowing the previous leak rate of that equipment to be established, that leak rate can change after the leak is repaired or
as the equipment ages.
The major uncertainty introduced in the material balance approaches occurs with recently installed equipment.
Equipment can leak for two or more years before needing a recharge, so emissions over this period are not detected until
after they occur. Despite this minor drawback, the material balance approaches provide a highly accurate estimate of
emissions.
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Fugitive Emissions Guidance Section 6: Documentation
Documentation
To ensure that emissions calculations are transparent and verifiable, the documentation sources listed in Table 2 should
be maintained. These documentation sources should be collected to ensure accuracy and transparency, and should also
be included in the organization’s Inventory Management Plan (IMP).
Amounts Recovered from Equipment Repair records; repair invoices; daily reports; disposal records
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Fugitive Emissions Guidance Section 7: Inventory Quality Assurance and Quality Control (QA/QC)
• Care should be taken that releases are not double counted (e.g., from reporting both refrigerant blend and individual
blend component use).
• Verify that your inventory is complete. Because the GWP values of fluorinated compounds are so large (particularly
when compared to carbon dioxide and methane), failure to account for even relatively small releases of fluorinated
compounds can introduce significant errors. Also, tracking specific GHGs separately is important, because of the
differing GWP values.
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