1 

Response to EPA Review of Fluorotelomers Amended Final Study Report 

The text below responds to each of the questions raised in the Review of Fluorotelomer 

Incineration ECA Final Report sent by e-mail on November 17, 2010 from Maj’d ElZoobi to Philip Taylor. Both Phase I and Phase II testing described in the Amended 

Final Study Report were performed in accordance with the requirements of the 

Enforceable Consent Agreement (ECA) and TSCA GLPs as embodied in the EPAapproved Quality Assurance Project Plans (QAPPs). Some of the questions seem to go 

beyond these requirements. It is important to note that the project team established and 

executed a quality management system to assure conformance with the EPA-approved 

QAPPs and documented such conformance in the Final Study Report, as amended on 

December 22, 2008. 

I. Phase I PFOA Transport Testing 

1. Reactor Temperature Profile 

How have the authors assured that there is no significant difference between the 

temperature profile of the reactor during the calibration of the reactor heater, and the 

actual temperature profile occurring during the experimental runs? 

As described in Section I.A.1 of the Final Study Report, the quartz reactor was housed 

in a Thermcraft Model SST-3.00-0-30-3C-D2155-BE three-zone temperature controlled 

split tube furnace. Therefore, based on the design of this furnace, the temperature of the

quartz reactor tube was controlled by external radiant heating supplied by the split-tube 

furnace. The Reynolds number of the gas for the 250oC case (Phase I) was roughly 

100. Under these conditions, heat transfer is dominated by radiation. The addition of 

water and slightly higher gas flow during transport test runs compared to pre-Phase I 

temperature profiling does not materially change the heat transfer coefficient which in 

both cases is dominated by the radiation contribution. Hence, the effect of water and 

higher gas flow during Phase I experimental runs is negligible. 

II. Phase II Incineration Testing 

1. Phase II Reactor Temperature Profile 

a. The reactor was held at 1000°C for most of its length, but the heater temperature 

set-points were in the range of 979°C to 993°C. However, heat transfer from 

heater to quartz tube requires that the temperature of the earlier be higher than 

that of the later which is contrary to what is reported; is this explained by an 

erroneous heater temperature controller, such that the actual heater set-point is 

actually greater than 1000°C? 

As described in Section I.A.1 and Section II.F.1 of the Final Study Report, the quartz 

reactor was housed in a Thermcraft Model SST-3.00-0-30-3C-D2155-BE three-zone 

temperature controlled split tube furnace. By design, the furnace temperature 

controllers operate on feedback from the thermocouples imbedded in the furnace and 

were not tied to the calibrated thermocouples used to monitor the surface temperature 
2 

of the quartz reactor tube. The thermocouples integral to the furnace and used with the 

furnace temperature controllers do not appear to be calibrated to the same degree as 

the Omega “special limits of error” thermocouples used to monitor the quartz reactor 

tube. Reactor midpoint quartz tube surface temperature T3 was calibrated prior to 

Phase II testing in accordance with Table B-2 of the EPA-approved Phase II QAPP. 

b. Why does the reactor’s temperature drop beginning at length 32 in.? Is that 

because the heater ends at this length and does not cover the entire reactor? 

Even if that were the case, it is surprising that temperature would drop 600°C in 

the span of only 4 in. due to ambient cooling only (ie, without the use of a cooling 

device.) 

The furnace is an SST-3.00-0-30 model, meaning that it is 3 feet long and has a 30 inch 

heated length. Therefore, the first 3 inches of the furnace and the last 3 inches of the 

furnace are not radiantly heated. As radiation is the dominant heat transfer 

mechanism, when the gas stops being heated, the temperature quickly drops on its own 

without external cooling. 

Pursuant to ECA and QAPP requirements, the outlet transfer line (on the discharge end 

of the furnace) was separately electrically heated to assure it stayed above 200o

C to 

prevent potential condensation. 

c. How have the report authors determined whether the reaction heat effects will 

cause any significant difference between the temperature profile of the reactor 

during the calibration of the reactor heater, and the actual temperature profile 

occurring during the experimental runs to ensure that the correct effective length 

was determined and consequently that the desired residence time of 2 sec. was 

actually established? 

In accordance with Table B-2 of the approved Phase II QAPP, the temperature 

calibration prior to Phase II experiments was performed to relate the external surface 

temperature of the reactor tube with internal gas temperature as the external surface 

temperature would be continuously monitoring during the experiments. As described in 

Section II.F.1.a of the Final Study Report, the Phase II temperature profile presented in 

Figure 3 of the Final Study Report was also determined prior to actual combustion 

testing. 

In response to this question, we have performed a supplemental in-depth engineering 

analysis to examine the potential effect of the heat of reaction of methanol oxidation on 

gas residence time at temperature. This investigation of the reaction heat effects 

indicates that the gas temperature could have overshot the 1000o

C target temperature 

by up to 283o

C (to 1283oC) and cooled to the target temperature range within less than 

0.2 seconds. Hence, these calculations confirm operation at 1000±10oC over a gas 

residence time controlled within the range of 1.8 to 2.2 seconds in conformance with the 

measurement performance criteria in Section A7.1 of the EPA-approved Phase II 

QAPP. As the average gas temperature across the 1.98 sec residence time was 
3 

1000.5oC (see page 38 of Final Study Report), the average gas temperature across the 

total 2.13 (=1.98 + 0.15) seconds (including the region associated with temperature 

overshoot and cool down) would be 1003.3o

C. 

The 1283o

C value is the adiabatic reaction temperature and thereby the theoretical 

maximum temperature attainable by the reaction gas mixture due to the oxidation of 

methanol as described in Table R-1. 

Calculations to determine the duration of the cool down from this maximum temperature 

to the target temperature range are presented in Table R-2. First, the temperature 

range between 1283o

C and 1020oC was divided into incremental segments, and the 

heat duty for each increment was determined (Qinc = mCpΔT). (With a wall temperature 

of 1008oC [see Appendix 28 to Final Study Report], an end temperature of 1020oC was 

chosen because as the gas temperature approaches the wall temperature, the heat 

transfer asymptotically goes to zero.) Second, the heat transfer coefficient (h) and the 

radiant flux (Qrad/A) for each increment were determined. Third, the surface area (A) for 

each increment was determined via heat balance. Next, the incremental lengths were 

calculated for each cylindrical section, and cumulative length was determined. 

Similarly, the incremental volumes and residence times were computed to yield a 

cumulative gas residence time for cool down of 0.149 second. 

The derivation of the thermal conductivity of the gas mixture using available information 

on component thermal conductivities is described in Tables R-3 and R-4. Table R-5 

lists the references cited in this supplemental engineering analysis. 

Data on full-scale mass burn municipal waste combustors in Section D.4.2 of Appendix 

D.4 to the ECA showing time-average (over 2 seconds) temperatures of approximately 

1230o

C indicate that a potential short-duration peak value of 1283oC for the lab reactor 

system is consistent with operating data for full-scale combustors. This comparison 

confirms that Phase II test conditions were representative of typical full-scale municipal 

waste combustor operations even when the theoretical maximum attainable 

temperature for the reacting gas is assumed. 

2. Consideration of Formation of Other PFC

a. According to Table 8, “Pyroprobe Cartridge and Sample Weight Measurement for 

FTBP Composites”, a residue was formed on the pyroprobe in two of the nine 

experimental runs. A 3μg and 4μg residue was formed in runs FTBP1-1 and 

FTBP2-3 respectively. Taking into account balance accuracy of ±2.5 μg, the 

amount of residue is 0.5μg and 1.5μg for runs FTBP1-1 and FTBP2-3 

respectively. However, in the report (F. Combustion Testing / 2. Description of 

Test Conditions / a. Test Substance Weight Measurements / P. 33) it is stated 

that the residue reported in Table 8 for these two runs is within the weighing 

accuracy of the microbalance. Please explain this taking into account the above. 
4 

The value shown in Table 8 of the Final Study Report for residue was a calculated 

value. Table 8 of the Final Study Report has 9 such values, 5 of which are negative, 2 

of which are zero, and 2 of which are positive. This suggests variability is important to 

understanding this calculated value. 

As PDF page 194 (notebook page 99 of Appendix 4) of the Appendices to the Final 

Study Report shows, the standard deviation of the reference weight measurements 

during this project was 2.5 μg. As the second paragraph of Section II.F.2.a. of the Final 

Study Report attempts to explain, if each of the two measurements used to compute the 

calculated sample residue value in Table 8 was accurate to ±2.5 μg, then the resulting 

residue value would be ±5 μg (=±2.5 μg + ±2.5 μg). Hence, any calculated residue 

value less than 5 μg would not have been distinguishable from measurement error 

associated with the use of the microbalance. Hence, Section II.F.2.a. of the Final Study 

Report stated, “The apparent residue remaining for weighings denoted FTBP 1-1 and 

FTBP 2-3 is an artifact of the sampling weighing process.” 

Upon further review, we now see that the measurement error associated with this set of 

weight measurements was actually ±7 μg rather than ±5 μg and that our original 

description of the measurement error associated with the residue calculation was not 

robust. From statistics, we know that the 95% confidence interval for each weight 

measurement on this balance during this project was 2σ = 2 * 2.5 = 5 μg. Hence, each 

weighing on this balance was actually ±5 μg. Since residue is calculated from two 

weighings, each of which is ±5 μg, it is necessary to consider the variance associated 

with each weighing to determine the expected error in the residue calculation. Residue 

is effectively calculated as a sum. The variance of a sum is the sum of the variances. 

With a standard deviation of 2.5, the variance for the calculated residue value is 

calculated as (2.52

 + 2.52 = 6.25 + 6.25) = 12.5. Standard deviation is the square root of 

variance. With a variance of 12.5, the standard deviation for the calculated residue 

value is the square root of 12.5 = 3.5. Hence, the standard deviation associated with 

the residue calculation is ±3.5 μg. Therefore the 95% confidence interval for the 

calculated residue values is ±7 μg (=2 * 3.5 μg). None of calculated residue values in 

Table 8 of the Final Study Report are outside of ±7 μg. Consequently, no residue was 

actually observed in any of the experimental run pyroprobe cartridges. 

b. Another consideration in regard to the possibility that other PFC were formed is 

whether a fluorine mass balance closes. Do you have any data on a fluorine 

balance? 

For the paper we are preparing for submission to a peer-reviewed journal, we have 

calculated fluoride recoveries and found that for 2 out of 3 runs for each composite the 

fluoride balance closes within 70 to 130%. For example, the calculated fluoride ion 

recovery for run 1 was 89%. As the journal article will demonstrate, the calculated HF 

emission concentrations are comparable to municipal waste combustor HF exhaust 

concentrations prior to air pollution control equipment. Detailed examination of the 

fluoride analytical data during manuscript preparation reveals that there was a low bias 

in the fluoride ion chromatography results in part due to a negative y-intercept in the 
5 

instrument calibration curve used by the laboratory, perhaps due to contamination of 

their calibration standards. 

Based on our telephone discussion in December, we have also computed mass of 

fluoride ion per mass of polymer for each run and mass of HF per mass of polymer for 

inclusion in the attached table. See the table titled “Fluoride Ion Recovery, Exhaust Gas 

Hydrogen Fluoride (HF) Concentration, and Fluoride Yield”. We plan to provide EPA 

with a preprint of the journal article once it is accepted for publication.
Table R-1. Adiabatic Reaction Temperature for Oxidation of Methanol Reaction: CH3OH + 1.5 O2 --> CO2 + 2 H

AB C D

Hf

o

298 

(cal/gmol) Cp/R = A + BT + CT 2 + DT -2 

CH3OH (g) 2.211 1.222E-02 -3.450E-06 0 -48,050 Heat capacity (Cp) constants: Smith & Van 

O2 3.639 5.060E-04 0 -2.270E+04 0 Standard Heats of Formation (Hf

o

298): Smith 

N2 3.280 5.930E-04 0 4.000E+03 0

CO2 5.457 1.045E-03 0 -1.157E+05 -94,051

H2O (g) 3.470 1.450E-03 0 1.210E+04 -57,798

Units

Value

Basis gmol CH3OH 1

Δ

Ho298 cal -161,597

Δ

Ho298 J -676,122

R J/gmol-K 8.314Reference T (Tr) C 25

Reference T (Tr) K 298.15Inlet Temp (Ti

) C 300

Inlet Temp (Ti

) K 573.15

Reactant Mean T (TmR) K 435.65

Excess (xs) air % 154.6%Molar quantities stoichiometric actual

Reactant CH3OH gmol 1 1Reactant O2 gmol 1.5 3.819

Reactant N2 gmol 5.643 14.367

Product CO2 gmol 1 1

Product H2O gmol 

2

2

Product O2 gmol 0 2.319Product N2 gmol 5.643 14.367

CpmeanR,CH3OH J/gmol-K 57.00

CpmeanR,O2 J/gmol-K 30.98CpmeanR,N2 J/gmol-K 29.61-Δ

Ho

R J 165,209

Final T (Tf) C 1283

Final T (Tf

) K 1556.50

Predicted 

Δ

Ho

P J 841,331

Prod Mean T (TmP) K 927.32

CpmeanP,CO2 J/gmol-K 51.35

CpmeanP,H2O J/gmol-K 40.25CpmeanP,O2 J/gmol-K 33.75CpmeanP,N2 J/gmol-K 31.91Calculated 

Δ

Ho

P J 841,331

Iterate until Predicted 

Δ

Ho

P = Calculated 

Δ

Ho

P

Δ

Ho

P = (Tf - 298.15) 

∑products (nCpmeanP)

CpmeanP = R [(A + BTmP + C/3 (4T2mP - TrTf) + D/(TrTf)]

Δ

Ho

P = (- 

Δ

Ho

R) - 

Δ

Ho298

TmP = (Tr + Tf)/2

Actual moles Reactant O2 = (stoichiometric moles Reactant O2) * (1CH3OH + 1.5 O2 --> CO2 + 2 H2O (g)

TmR = (Tr+ Ti)/2

CpmeanR = R [(A + BTmR + C/3 (4T2mR - TrTi) + D/(TrTi)]

-Δ

Ho

R = (Ti - 298.15) 

∑reactants (nCpmeanR) where Ti 

≥ 298.15

Actual moles N2 = (stoichiometric moles N2) * (100 + %xs air)/100standard heat of reaction (calculated)4.184 J / calCommentUniversal Gas Constant; with this R, Cp is in J/gmol-Ktemperature at which CH3OH conc corresponds to lower flammabilit
Table R-2. Cool Down from Adiabatic Reaction Temperature

g/min mol/min Vol % g/mol Comment

CO2 0.068 0.002 5.10% 44.01 mol/min & Vol % from Table 4 of 

H2O 0.056 0.003 10.19% 18.02 Appendix 7 to Final Study Report

O2 0.115 0.004 11.80% 32.00 g/min = mol/min * g/mol

N2 0.620 0.022 72.91% 28.01

total 0.859 0.030

mmix g/min 0.859 mass flow rate

MWmix g/mol 28.28 molecular weight of gas mixture

mmix lb/hr 0.114

L ft 3.000 reactor tube length (inside furnace)

D mm 14 reactor tube internal diameter

D cm 1.4

D ft 0.046

Lm ft 0.046 mean beam length = D for cylinder

P atm 1.023 reactor P (Report, Appendix 7, Table 4)

Pc atm 0.052 partial pressure of CO2

PcL ft-atm 0.002 PcL = Pc * Lm

Pw atm 0.104 partial pressure of H2O

PwL ft-atm 0.005 PwL = Pw * Lm

σ Btu/hr-ft2

- ̊R4 1.74E-09 Stefan-Boltzmann constant

T  ̊C 1300 1283 1250 1200 1150 1100 1050 1020 assympote; stop calcs as T nears Twall

CpCO2/R 7.054 7.035 6.999 6.943 6.887 6.831 6.774 6.739 Cp/R = A + BT + CT 2

 + DT -2 

CpH2O/R 5.756 5.731 5.684 5.612 5.540 5.467 5.395 5.352 where A, B, C, and D from Table R-1

CpO2/R 4.424 4.415 4.398 4.372 4.346 4.320 4.294 4.278

CpN2/R 4.214 4.204 4.185 4.155 4.126 4.096 4.067 4.049

Cpmix/R 4.541 4.529 4.506 4.472 4.437 4.402 4.367 4.346

Cpmix Btu/lbmol- ̊F 9.019 8.995 8.950 8.881 8.812 8.743 8.673 8.632 R = 1.986 Btu/lbmole- ̊F

Cpmix Btu/lb- ̊F 0.319 0.318 0.316 0.314 0.312 0.309 0.307 0.305 heat capacity of gas mixture

ΔT  ̊C 0 17 33 50 50 50 50 30 gas temp change in each segment

Qinc Btu/hr 0.000 1.105 2.135 3.210 3.185 3.160 3.135 1.872 incremental heat duty = mCpΔT

k mix Btu/hr-ft- ̊F 0.060 0.059 0.058 0.057 0.055 0.053 0.052 0.051 thermal conductivity of gas mixture

Gz dimensionless 1.811 1.822 1.846 1.884 1.925 1.969 2.016 2.049 Graetz number = mCpL/k

Nu dimensionless 4.017 4.021 4.029 4.041 4.054 4.067 4.082 4.092 HTRI: Nusselt number = C1 + C2 Gz1⁄3

h Btu/hr-ft2

-F 5.249 5.206 5.123 4.996 4.867 4.737 4.606 4.522 h = k Nu/D

T  ̊F 2372 2341 2282 2192 2102 2012 1922 1868 T( ̊F) = T( ̊C)*1.8 + 32

εCO2 dimensionless 0.0065 0.0067 0.0070 0.0073 0.0080 0.0085 0.0087 0.0090 emissivity, Perry's 5th ed., Fig. 10-55

εH2O dimensionless 0.0028 0.0030 0.0031 0.0035 0.0038 0.0042 0.0048 0.0055 emissivity, Perry's 5th ed., Fig. 10-56
Table R-2. Cool Down from Adiabatic Reaction Temperature (continued)

Cso dimensionless 0.007 0.007 0.007 0.007 0.007 0.007 0.007 0.007 spectral overlap, Perry's 5th ed., Fig. 10-58

Cw dimensionless 1.1 1.1 1.1 1.1 1.1 1.1 1.1 1.1 P correction factor for H2O, Fig. 10-57

εgas dimensionless 0.010 0.011 0.011 0.012 0.013 0.014 0.015 0.016 εgas = (εCO2+εH2O)Cw(1-Cso)

T  ̊K 1573 1556 1523 1473 1423 1373 1323 1293 T = T ( ̊C) + 273.15

Tg  ̊R 2832 2801 2742 2652 2562 2472 2382 2328 Tg = Tgas ( ̊R) = [T ( ̊K) ]*1.8

Twall  ̊C 1008 1008 1008 1008 1008 1008 1008 1008 ref Final Study Report (p. 38)

Twall  ̊R 2306 2306 2306 2306 2306 2306 2306 2306

εCO2,Tw dimensionless 0.0070 0.0073 0.0075 0.0080 0.0085 0.0086 0.0087 0.0090 ref Perry's 5th ed, pp 10-56 - 10-59

εH2O,Tw dimensionless 0.0060 0.0058 0.0057 0.0055 0.0054 0.0053 0.0052 0.0050 ref Perry's 5th ed, pp 10-56 - 10-59

αCO2 dimensionless 0.008 0.008 0.008 0.009 0.009 0.009 0.009 0.009 αCO2 = εCO2,Tw *(Tgas/Twall)

0.65

αH2O dimensionless 0.007 0.007 0.007 0.006 0.006 0.006 0.006 0.006 αH2O = εH2O,Tw *(Tgas/Twall)

0.45 * Cw

αgas dimensionless 0.015 0.015 0.015 0.015 0.015 0.015 0.015 0.014 αgas = (αCO2+ αH2O)(1-Cso)

Qrad/A Btu/hr-ft2

353 351 309 245 195 151 97 87 Qrad/A =0.9σ(Tg

4

εgas - Tw

4

αgas)

A ft20 3.8E-04 8.4E-04 1.6E-03 2.2E-03 3.4E-03 7.0E-03 1.0E-02 Q = hA(Tg-Tw) + (Qrad/A)A

Linc ft 0 2.6E-03 5.8E-03 1.1E-02 1.5E-02 2.3E-02 4.9E-02 7.0E-02 incremental length = A/(πD)

Linc cm 0.000 0.080 0.178 0.344 0.467 0.714 1.487 2.141 1 ft = 30.48 cm

Lcumul cm 5.411 cumulative length under curve = ΣLinc

Vinc cm3

0.000 0.123 0.273 0.529 0.720 1.099 2.289 3.296 incremental volume =π(D2

/4) * Linc

Vol Flo L/sec 0.065 0.065 0.063 0.061 0.059 0.057 0.055 0.054 vol flow rate = (mol flow rate)(RT/P)

Vol Flo cm3

/sec 65.33 64.62 63.25 61.17 59.10 57.02 54.94 53.70 R = 0.08206 L-atm/(mole- ̊K)

tinc sec 0.000 0.002 0.004 0.009 0.012 0.019 0.042 0.061 incremental res time = Vinc/vol flowrate

tcumul sec 0.000 0.002 0.006 0.015 0.027 0.046 0.088 0.149 cumulative res time = Σtinc

AUC sec- ̊C 0.00 0.03 0.14 0.43 0.61 0.96 2.08 1.84 area under cool-down curve

Tavg,UC  ̊C 1040.9 Tavg, under curve = ΣAUC / Σtinc + 1000

Tavg,2s  ̊C 1000.5 avg T over 2 sec res time per Report (p.38)

Tavg,tot  ̊C 1003.3 Tavg, tot=(tcumul*Tavg,UC+2*1000)/(2+tcumul)

Note: using 1.98 sec for "2 sec" per Report (p.38)

C1, C2 = Heat Transfer Research Institute (HTRI) proprietary constants
Table R-3. Thermal Conductivity (k ) of Nitrogen, Carbon Dioxide, Oxygen, Water, & Mixture

Nitrogena

Carbon 

Dioxideb Oxygenb Waterc Mixtured Mixturee

T T k k k k k k

(C) (K) (W/m-K) (W/m-K) (W/m-K) (W/m-K) (W/m-K) (Btu/hr-ft-F)

1020 1293.15 0.08071 0.08256 0.09007 0.13830 0.08786 0.05076

1050 1323.15 0.08214 0.08379 0.09171 0.14373 0.08970 0.05183

1100 1373.15 0.08451 0.08576 0.09442 0.15123 0.09259 0.05350

1150 1423.15 0.08684 0.08761 0.09711 0.15879 0.09545 0.05515

1200 1473.15 0.08914 0.08936 0.09977 0.16640 0.09828 0.05679

1250 1523.15 0.09141 0.09100 0.10241 0.17405 0.10109 0.05841

1283 1556.15 0.09289 0.09204 0.10414 0.17910 0.10292 0.05947

1300 1573.15 0.09365 0.09255 0.10502 0.18174 0.10386 0.06001

a Ref.: NIST Webbook at P = 1 bar* [Lemmon et al, 2011]

b Ref.: DIADEM Professional (The DIPPR Information and Data Evaluation Manager for 

the Design Institute for Physical Properties, Version 5.0) at P = 1 bar* [Rowley et al, 

2010]

c Ref: NIST REFPROP Version 8.1 Beta at P = 1 bar* [Kestin et al, 1984 in Lemmon et 

al, 2010]

d Calculated using Mason and Saxena modification to the Wasiljewa equation [Reid et 

al, 1977, pp. 508-509]; see examples in Table R-4

e Conversion factor for W/m-K to Btu/hr-ft-F is 0.57779

* The effect of pressure on thermal conductivity of gas in the range of 1 bar to 1.023 atm 

is negligible because thermal conductivity of a gas changes about 1% per atmosphere 

in the region below 10 atm. [Reid et al, 1977, pp. 499-500]
Table R-4. Sample Calculations: Computing Thermal Conductivity of Actual Mixture at Two Temperatures

T (K) No. Species

Mole fraction [y]

Molecular Weight [M]

k 

(W/m-K) T (K) No. Species

Mole fraction [y]

Molecular Weight [M]

(

1556.15 1 N2 0.7291 28.0134 0.09289 1573.15 1 N2 0.7291 28.0134 

1556.15

2 CO2 0.0509 44.0095 0.09204 1573.15

2 CO2 0.0509 44.0095 

1556.15

3 O2 0.1181 31.9988 0.10414 1573.15

3 O2 0.1181 31.9988 

1556.15

4 H20 0.1019 18.0153 0.17910 1573.15

4 H20 0.1019 18.0153 

1556.15 mixture 0.10292 1573.15 mixture 

i j Mi/Mj k i

/k j Aij

Mole fraction j ∑

yj*Aij i j Mi/Mj k i

/k j 

1 1 1.00000 1.00000 1.00000 0.7291 0.981122 1 1 1.00000 1.00000 

2 0.63653 1.00928 0.89790 0.0509

2 0.63653 1.01185 

3 0.87545 0.89201 0.94120 0.1181

3 0.87545 0.89170 

4 1.55498 0.51865 0.93390 0.1019

4 1.55498 0.51530 

2 1 1.57102 0.99081 1.12025 0.7291 1.096849

2 1 1.57102 0.98829 

2 1.00000 1.00000 1.00000 0.0509

2 1.00000 1.00000 

3 1.37535 0.88380 1.04909 0.1181

3 1.37535 0.88126 

4 2.44290 0.51389 1.03319 0.1019

4 2.44290 0.50926 

3 1 1.14227 1.12107 1.06508 0.7291 1.044369

3 1 1.14227 1.12145 

2 0.72709 1.13147 0.95154 0.0509

2 0.72709 1.13474 

3 1.00000 1.00000 1.00000 0.1181

3 1.00000 1.00000 

4 1.77620 0.58145 0.99398 0.1019

4 1.77620 0.57788 

4 1 0.64310 1.92807 1.03992 0.7291 1.02255

4 1 0.64310 1.94063 

2 0.40935 1.94596 0.92214 0.0509

2 0.40935 1.96362 

3 0.56300 1.71985 0.97809 0.1181

3 0.56300 1.73046 

4 1.00000 1.00000 1.00000 0.1019

4 1.00000 1.00000 
Table R-5. References 

Bodurtha, F. T., 1980. Industrial Explosion Prevention and Protection. McGraw-Hill, Inc., New York. 

Environmental Standards, Inc., 2006. Quality Assurance Project Plan for the ECA Incineration Testing 

Program – Phase II Fluorotelomer Incineration Testing. 

EPA, 2005. Enforceable Consent Agreement for Fluorotelomer-based Polymers Chemicals (EPA docket 

No. OPPT-2004-0001). 

Kestin, J., Sengers, J. V., Kamgar-Parsi, B. and Levelt Sengers, J. M. H., 1984. Thermophysical 

Properties of Fluid H2O. J. Phys. Chem. Ref. Data. 13(1), 175-183. 

Knudsen, J. G., Bell, K. J., Holt, A. D., Hottel, S. M., Sarofim, A. F., Standiford, M. S., Stuhlborg, D., and 

Uhl, V. W., 1973. Heat Transmission, in: Perry, R. H. and Chilton, C. H. (Eds.), Chemical Engineers’ 

Handbook, 5th edition. McGraw-Hill, New York, Section 10. 

Lemmon, E. W., Huber, M. L., McLinden, M. O., 2010. NIST Standard Reference Database 23: 

Reference Fluid Thermodynamic and Transport Properties-REFPROP, Version 9.0, National Institute of 

Standards and Technology, Standard Reference Data Program, Gaithersburg. 

Lemmon, E.W., McLinden, M. O. and Friend, D. G, 2011. Thermophysical Properties of Fluid Systems in: 

Linstrom, P. J. and Mallard, W. G. (Eds.), NIST Chemistry WebBook, NIST Standard Reference Database 

Number 69, http://webbook.nist.gov. 

Reid, R. C., Prausnitz, J. M., and Sherwood, T. K., 1977. The Properties of Gases and Liquids, 3rd

edition. McGraw-Hill, Inc., New York. 

Rowley, R. L., Wilding, W. V., Oscarson, J. L., and Giles, N. F., 2010. DIPPR® Data Compilation of Pure 

Chemical Properties. Design Institute of Physical Properties, AIChE, New York. 

Smith, J. M. and Van Ness, H. C., 1975. Introduction to Chemical Engineering Thermodynamics, 3rd

edition. McGraw-Hill, Inc., New York. 

Smith, J. M. and Van Ness, H. C., 1987. Introduction to Chemical Engineering Thermodynamics, 4th

edition. McGraw-Hill, Inc., New York. 

Taylor, P. H., 2008. ECA Incineration Testing Program: Laboratory-Scale Incineration Testing of 

Fluorotelomer-based Polymers Amended Final Study Report. 
Fluoride Ion Recovery, Exhaust Gas Hydrogen Fluoride (HF) Concentration, and Fluoride Yield

Experimental 

Run

Measured 

Fluoride ion 

concentration

Mass of 

polymer

Fluorine in 

polymer

Water volume

Predicted 

Fluoride ion 

concentration

Fluoride ion 

Recovery

Observed HF 

concentration Run Avg 

O2 

conc

Observed HF 

concentration 

at 7% O2

Predicted HF 

concentration 

at 7% O2 

(mg/L) (μg) (%) (mL) (mg/L) (%) (mg/dscm) (%) (mg/dscm) (mg/dscm)

P

1 0.58 102 38.6 60.28 0.65 89 3.6 13.32 6.6 7.4 

2 0.48 104 38.6 60.51 0.66 72 3.0 13.29 5.5 7.5 

3 0.28 103 38.6 60.43 0.66 43 1.8 13.25 3.2 7.4 

4 0.45 108 32.1 60.81 0.57 79 2.9 13.20 5.1 6.4 

5 0.47 108 32.1 60.69 0.57 82 3.0 13.22 5.3 6.4 

6 0.29 91 32.1 60.20 0.49 60 1.8 13.23 3.3 5.4 

Notes:Measured Fluoride ion concentration from MPI Report. Lab notes "QC measurements did not meet the criteria specified in 

QAPP. The data should be considered estimated values."

Mass of polymer is Sample Net Weight.Concentration of Fluorine in polymer is normalized fluorine concentration on dry basis.Water volume is total water volume in impingers for run, assuming water density = 1 g/mL.Predicted Fluoride ion concentration = [(mass of polymer) * (% Fluorine in polymer)/100] / (water volume)Fluoride ion Recovery (%) = (measured Fluoride ion concentration) / (predicted Fluoride ion concentration) * 100Observed HF concentration = (measured F ion conc) * (water volume) / 1000 * [(Molecular Wt of HF)/(Atomic Wt of F)] / (dMolecular weight of HF = (atomic weight of H) + (atomic weight of F)Atomic weight of H = 1.008 g/moleAtomic weight of F = 18.998 g/moleDry gas volume is volumetric flow rate on dry basis * duration of pyroprobe heating (16 min)Volumetric flow rate = 6.32E-04 dscm/min (from stoichiometric calculations)Run Avg O2 conc is run average oxygen concentration from CGA for run.

Observed HF concentration at 7% O2 = (observed HF concentration) * (21.1% - 7%) / (21.1% - [(Run Avg O2 conc) %])

Predicted HF concentration at 7% O2 = (predicted HF concentration) * (21.1% - 7%) / (21.1% - [(Run Avg O2 conc) %])

Predicted HF concentration = (predicted F ion conc) * (water volume) / 1000 * [(Molecular Wt of HF) / (Atomic Wt of F)] / (F ion Emission Factor = (measured F ion conc)*(water volume)*1000/(mass of polymer)HF Emission Factor = (measured F ion conc)*(water volume)*1000/(mass of polymer)*(Molec Wt of HF)/(Atomic Wt of F)