Promulgation: Mandatory Reporting of Greenhouse Gas Emissions 

Meeting Documentation for Telephone Call on September 3, 2010 with 3M Representatives RegGas Production Re-Proposal Rule Dates: September 3, 2010 Staff Contact Information (Name, email, phone #): Deborah Ottinger, EPA, 202-343-9149, Ottinger.deborah@epa.gov; Karen Schaffner, RTI, ksschaffner@rti.org; Carrie Ric

Name of Organization (Attach list of all attendees names and emails if possible):Dana Schnobrich, Tom Herzberg, Karl Warren, Brian Mader, Jeff Muffat, 3M 

Summary 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 calcula

emissions 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 to use the mass balance approach. Described an ex

reaction takes place, then sent to a tank, then stored as isolated intermediate, later the isolated intermediate is sent toperation. Each isolated intermediate is part of a larger process, i.e., isolated intermediate A, isolated intermediate intermediate C are all part of one product. The isolated intermediate that is sent to a separation process would be a

reaction 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 approac

included as one of the options available. 

• Analytical methods used to measure total Fluorine could include oxypyrohydrolysis, which is a standard technique 

sampling. 

• Conducting a field verification of batch processes would depend on the specific process. If the vent fan operates co

possibly use a similar approach as for continuous processes. However, for batch processes, to get uncontrolled em

destruction device, is complicated; measuring every episode is difficult, because some have short durations. For thto make assumptions about shorter emission episode events and focus on signification emission episodes. If the res

verification measurement showed a discrepancy, facilities would use the overall process material balance and adjus

there are accurate measurements of inputs, conduct material balance around the entire process, place more emphasiwhere 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 de

be due to detection level and not necessarily due to chemical differences or pyrolysis. [EPA noted Dr. Tsang of NI

demonstrated the difficulties of destroying CH4 and SF6 compared to other compounds such as HFCs.] 
• Facility typically uses a surrogate such as SF6 for all compounds other than PFCs, since SF6 has a low detection lev

evaluated on its own. The facility has looked for PICs from thermal oxidizer using a GC method and FTIR method fluorinated compounds; this analysis showed no fluorinated compounds at the outlet except CF4. Surrogate spiking 

compounds 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 T

• Composition of materials seen at lab-scale process would be the same as the composition at full-scale production. 

likely found in low boiler or high boiler streams where it is concentrated. In general, less rigor is used for destroyethan for a product stream, and for a process vent. 

• When 3M performed equipment leak monitoring by testing the room air exhaust vent, they also did conduct equipm

pieces of equipment in the room, and tested all in pieces in service. 3M noted they do not have equipment leak em

some data for F GHG equipment leak monitoring using Method 21 where the response factor was adequate; 3M wi

• Participants asked what happens when the approaches EPA provides in the rule do not work or are not appropriate. 

for alternatives, similar to the approach used under the NESHAP program? [EPA noted that BAMM is allowed for 

that a facility would have to go to prescribed methods in Subpart L.] Facility noted this is a short time period to deNoted that for the longer term, if the available methods are not working, facilities will need a mechanism ask for al

Written Comments Provided? No. Did they also submit to Docket? No. Date sent to EPA- CCD None 
Attachment 1 - Follow-up questions for 3M: 

1. In your comments, you note that you would like 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 intermediates.” Can you describe further the 

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

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

manufacturing process? 

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

the TSD meet your needs for transformation processes and for isolated intermediates? 

3. During our site visit last fall, 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 doing this? (NMR?) If so, do you have an 

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

are still interested? 

4. Can you describe further just how you would 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 destroyed 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 CF4? Other PFCs? Other F-GHGs? 

7. In the comment letter, you mentioned a need 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 alternative 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 validation 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 pilot-scale, these will typically 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 latter, 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 processes? (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?