Promulgation: Mandatory Reporting of Greenhouse Gas EmissionsMeeting Documentation for Telephone Call on September 3,2010 with 3M Representatives Regarding FluorinatedGas Production Re-Proposal RuleDates:September 3, 2010Staff Contact Information (Name, email, phone #):Deborah Ottinger, EPA, 202-343-9149,Ottinger.deborah@epa.gov; Karen Schaffner, RTI,ksschaffner@rti.org; Carrie Richardson, RTI.Name of Organization (Attach list of all attendees names and emails if possible):Dana Schnobrich, Tom Herzberg, Karl Warren, Brian Mader, Jeff Muffat, 3MSummary of Discussion (e.g., applicability, reporting requirements, etc.):The purpose of the call was to discuss their public comments regarding emission estimation techniques available to calculate fluorinated GHGemissions along with other concerns regarding the reporting rule.3M representatives provided input on the follow-up questions, see Attachment 1, as follows:•3M has diverse operations and some processes may not be able touse the mass balance approach.Described an example process, where areaction takes place, then sent to a tank, then stored as isolated intermediate, later the isolated intermediate is sent to a separationoperation. Each isolated intermediate is part of a larger process, i.e., isolated intermediate A,isolated intermediate B, andisolatedintermediate C are all part of one product. The isolated intermediate that is sent to a separation process would be an exampleof a nonreaction process, and mass balance could be conducted on this.•A mass balance on total Fluorine for transformation processes and for isolated intermediates may be better approach, but best to beincluded as one of the options available.•Analytical methods used to measure total Fluorine could includeoxypyrohydrolysis, which is a standard technique both for waterand airsampling.•Conducting a field verification of batch processes would depend on the specific process.If the vent fan operates continuously, couldpossibly use a similar approach as for continuous processes. However, for batch processes, to get uncontrolled emissions priorto thedestruction device, is complicated; measuring every episode isdifficult, because some have short durations. For the most part, would haveto make assumptions about shorter emissionepisode events and focus on signification emission episodes. If the results of the fieldverification measurement showed a discrepancy, facilities would use the overall process material balance and adjust to get bestfit (i.e.,there are accurate measurements of inputs, conduct materialbalance around the entire process, place more emphasis on measurementswhere facility has the most confidence in). Another option may be to potentially redo the test.•When asked about comparison of efficiencies for HFC compared to PFCs, participants noted that differences in destruction efficiency maybe due to detection level and not necessarilydue to chemical differences or pyrolysis.[EPA noted Dr. Tsang of NIST 1997 paperthatdemonstrated the difficulties of destroying CH4and SF6compared to other compounds such as HFCs.]•Facility typically uses a surrogate such as SF6for all compounds other than PFCs, since SF6has a low detection level, and CF4would beevaluated on its own. The facility has looked for PICs from thermal oxidizer using a GC method and FTIR method where looked for 40fluorinated compounds; this analysis showed no fluorinated compounds at the outlet except CF4. Surrogate spiking was conducted withcompounds not in 3M wastes.•The analytical methods proposed in subpart OO should be sufficient, and there is likely no need to add TO-14 or TO-15.•Composition of materials seen at lab-scale process would be the same as the composition at full-scale production. Byproducts are mostlikely found in low boiler or high boiler streams where it is concentrated. In general, less rigor is used for destroyed streams compositionthan for a product stream, and for a process vent.•When 3M performed equipment leak monitoring by testing the roomair exhaust vent, they also did conduct equipment leak monitoring onpieces of equipment in the room, and tested all in pieces in service. 3M noted they do not have equipment leak emissions. Theydo havesome data for F GHG equipment leak monitoring using Method 21where the response factor was adequate; 3M will share this data.•Participants asked what happens when the approaches EPA provides in the rule do not work or are not appropriate. Can facilities petitionfor alternatives, similar to theapproach used under the NESHAP program? [EPA noted that BAMM is allowed for 3 months, and afterthat a facility would have to go to prescribed methods in SubpartL.] Facility noted this is a short time period to deal witha lot of issues.Noted that for the longer term, if the available methods are notworking, facilities will need a mechanism ask for alternatives.Written Comments Provided?No.Did they also submit to Docket?No.Date sent to EPA- CCDNone

# Attachment 1 - Follow-up questions for 3M:

1. In your comments, you note that you would lik e to use the mass-balance approach for

transformation processes and for processes in which reactions do not take place. As an

example of the latter, you cite “isolated in termediates.” Can you describe further the

types of processes you have in mind in whic h reactions do not take place? Are these

processing steps that occur subsequent to chem ical reactions? Are they part of a larger

manufacturing process?

2. Would the mass-balance equations based on fl uorine inputs and outputs and presented in

the TSD meet your needs for transformation pr ocesses and for isolated intermediates?

3. During our site visit last fa ll, you briefly mentioned the possibility of analyzing the

fluorine contents of streams by burning them rather than by speciating their contents.

Are you aware of an analytical method for doi ng this? (NMR?) If so, do you have an

estimate of the accuracy and prec ision of this method? Is this an approach in which you

are still interested?

4. Can you describe further just how you woul d perform a “field verification” of an

emission calculation factor for a batch process?

5. When you have performed DE testing on your destruction devices, have you compared

the efficiencies with which HFCs are destr oyed to the efficiencies with which PFCs,

CFCs, or HCFCs are destroyed?

6. When you have performed DE testing on your destruction devices, have you looked for

products of incomplete combustion (PICs) from combustion of PFCs and other F-GHGs?

Which ones? Have you looked for CF 4? Other PFCs? Other F-GHGs?

7. In the comment letter, you mentioned a n eed for including TO-14 and TO-15. Are you

aware of a specific need for including these, or would the recently proposed language for

analytical methods under subpart OO (paragraph 98.414(n)), if used in subpart L, cover

the need for use of TO-14 and TO-15 as alte rnative methods? TO-15 was included in the

re-proposal regulatory text for subpart L as an alternative method; however, that

regulatory text would have required va lidation of TO-15 using EPA method 301.

8. In our phone call, you mentioned that while some compounds may be generated at fullscale production that were not generated at pilo t-scale, these will typi cally be generated at

low concentrations, i.e., less than 1,000 ppm. Is this the concentration in emitted streams

(i.e., streams that one would expect to be relatively enriched with unwanted byproducts)

or in the general product stream? If the latt er, what would the concentration be in emitted

streams?

9. Do you have follow-up questions regarding how the mass-balance approach could be

adapted to work for transformation processe s? (That is, have you seen pages 18 through

22 of the Technical Support Document?)

# 10. When you performed your equipment leak check, did you sniff each piece of potentially

leaky equipment? Or did you just test the vented room air?