Promulgation: Mandatory Reporting of Greenhouse Gas EmissionsMeeting Documentation for TelephoneCall on May 14, 2010 with 3M Representatives Regarding Fluorinated GasProduction Re-Proposal Rule.Dates:May 14, 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, Jeff Muffat, Jeff McComas, Mike Parent, Tom Herzberg, Karl Warren, Brian Mader, Sooi Ooi, Leslie Kampf, 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 shared slide handouts for the conference call; see the attached slides for the full list of topics. 3M comments focused onbatch testing, lack ofGWP for all compounds, equipment leak monitoring and alternatives,and industry variability. 3M representatives noted this industry is the mostcomplicated of all the source categories includedin the MRR for GHG. 3M noted the following:3M representatives had comments on the initial scoping test and suggested that facilities be able to use available data (for example, do materialbalance, use past data, use modeling data), since measurements are done at laboratory scale process, in pilot plant scale process, etc. 3Mrepresentatives expressed concerns regarding extremely high costsassociated with scoping test and compliance with this rule. 3M representativesnoted that other methods should be allowed in 98.124(c)(4)(v) ,such as internal methods, and that Method 18 is not usually used. 3Mrepresentatives noted that surrogates shouldbe allowed for calibration standards.3M representatives had comments on mass balance approach and transformation processes. 3M representatives were not certain that they woulduse the mass balance approach but the rule should allow for use of mass balance approach for transformation processes. EPA noted that the reproposal mass balance approach assumes that everything not accounted for is product, however EPA asked for comment conducting an emissioncharacterization. EPA noted that a tweaked version of the massbalance approach might could be used for transformation processes.3M representatives had comments on the preliminary emissions estimates for process vents. 3M representatives supported use ofcalculations forthe preliminary emission estimates for process vents. For developing emission factors for batch processes, calculations wouldbe better thanrequiring emission testing.For process vent emissions thresholds, 3M representatives noted that post-control emissions levelswould be better than pre-control emissions,particularly for batch processes. 3M representatives noted that the1 mt fluorinated GHG emission threshold is too low, especially for uncontrolledemission levels. 3M representatives suggested the rulebe made consistent with the title V Tailoring Rule.3M representatives noted that there are issues with meeting the 99.9 percent DE, based on the DL and quantity of feed material.If the majority ofa fluorinated GHG is destroyed and not measurable at the outlet tothe DD, then the amount of POHC fed to the DD would have tobe increased todetermine a DE. 3M representatives noted their concern about testing the corporate HWC that happens to be located onsite with fluorinated GHGproduction. 3M representatives noted that the preamble uses the term “surrogate” for DDtesting but the rule text does not. 3M representativesnoted that some fluorinated GHG are not on the trial burn compound lists. 3M representatives noted concerns about whether process scrubberswould be considered destruction devices andbe required to conduct DE testing for them. Process scrubbers are used as backup control devicesand are used for HF removal; these process scrubbers may removecertain fluorinated GHG but are not in place for this purpose.3M representatives noted that emission testing for process vents would have to be completed by December 2011. 3M representatives suggested atiered schedule be adopted for emissions testing, where thresholds could be incorporated and those process vents with high emissions would betested the first year and other lower emitting process vents could be tested the second year. With the requirement to completetesting December2011 and the number of process vents to be tested, the facility will be doing stack testing all year. The large number of process vents that requirestack testing is costly and requires much manpower. The tiered testing approach allows highly skilled analytical staff to be able to provideoversight of testing activities.3M representatives also noted that if emission testing is conducted for one operating scenario of a process, then EPA should allow calculations toaugment the emission factor for a second operating scenario, i.e.,integrate the emission test with engineering calculations for developing emissionfactor. There are high costs associated with having to test every operating scenario. They suggested requiring testing for the largest emittingoperating scenario and use of engineering calculations for other operating scenarios.3M representatives noted that use of IPCC procedures for determining GWP is appropriate, and EPAshould approve use of GWP determinedusing this method. 3M representatives has several batch processesthat have fluorinated GHG compounds that do not have GWP inthe peerreviewed literature. 3M representatives noted that there needs tobe a procedure for adding GWP to Table A-1 of subpart A.3M representatives noted that three one-hour test runs for continuous process vents testing is typical. 3M representatives noted that otheralternative to Methods 1 to 4 should be allowed. For batch process vents testing, integrated flow and concentration methods would be needed. 3Mrepresentatives noted that batch process vent testing for longbatch cycles will be costly. 3M representatives will provide more detailed commentson batch testing in their written comments.3M representatives also requested a lifetime cutoff for vents, or for pieces to be excluded if they do not affect the GWP of the stream in asignificant way. 3M representatives also expressed concerns aboutthe possible presence of HF in the streams and concerns aboutvariability withingrab samples.Written Comments Provided?No.Did they also submit to Docket?No.Date sent to EPA- CCDNone11/8/2010

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# General Comments

 

## Emissions Testing (Batch) Emissions Testing (Batch)
 

## Lack of a GWP Metric for non-Table A-1 Compounds
 

## Equipment Leaks Equipment Leaks
 

## Industry variability and flexibility



# 1. Scoping Analysis

 

## Variety of methods that may be used to Variety of methods that may be used to determine air stream contents Laboratory, Pilot Plant, and/or factory
 

## Methods listed in 98.124 (c)(4)(v)
 

## Subpart OO language changes11/8/2010

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# 2. Transformations

 

### Requirement for process vent testing (98 123) Requirement for process vent testing (98

. 123)
 

### Leave open the possibility that facilities would use the material balance method for processes that consume but do not product an F-GHG



# 3. Mass Balance Method

 

## Might only be used on a limited basis Might only be used on a limited basis
 

## Isolated intermediates where reactions do not take place Packaging Filtration Distillations11/8/2010

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# 4. Preliminary Estimate

 

### No comments on this section (still under No comments on this section (still under review)  

### Consistent with current measurement practices  

### Methods need to be included with Processvent-specific emission factor method (98 123(b)(3)) (98

. 123(b)(3)) Vapor Displacement of Liquids Packaging losses Different operating scenarios



# 5. Process vent annual limit and control determinations - 98.123(b)(2)

 

### Post rather than pre

- control emissions Post rather than pre control emissions Manage our emissions Eliminates the need for detailed characterization of streams that are being destroyed  

### Increased threshold, i.e. 10,000 lb/yr
 

### 99 9% control threshold 99

. 9% control threshold
 

### Eliminate the “either” requirement, i.e. combination of controlled and uncontrolled emissions11/8/2010

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# 6. Process vent testing (98.124 (c)) (c)(1): Initial and periodic testing

 

## 2011 Testing: Distributed throughout the five year period
 

## Priority based on emissions quantity
 

## Start-up, shutdown, and malfunctions are appropriately addressed



## 6. Process vent testing (98.124 (c)) (cont.) (c)(2): Different operating scenarios (c)(2): Different operating scenarios

 

## Section should allow for the use of engineering calculations to augment any emissions testing of a particular process
 

## Required testing if greater than 15% difference (EPA Comment Request)
 

## Example11/8/2010

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## 7. Process vent testing (98.124 (c)) (continuous processes) (c)(3): Number of Runs (c)(3): Number of Runs

 

## Adequate for continuous processes
 

## Consistent with previous discussions
 

## Easier validation Easier validation

8. Process vent testing (98.124 (c)) (batch processes) (c)(3): Number of Runs (c)(3): Number of Runs

 

### Still under review
 

### Origin of requirement
 

### Integration of flow and concentration
 

### Equipment/piping modifications
 

### Use of mass flow meters
 

### Only a part of emission factor development11/8/2010

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## 8

. Process vent testing (98.124 (c)) (batch processes, cont.) ( c )( 3 ) : Number of Runs ( cont. ) )( ) ( )

 

### Testing Requirement Not a worst case 0.2 RSD: Six runs requi red for all processes Batch cycles: 24

- 48 hours Batch cycles: 24 48 hours Extended time to complete View as combined GWP
 

### Integrated with other methods



## 8

. Process vent testing (98.124 (c)) (batch processes, cont.) ( c )( 3 ) : Number of Runs ( cont. ) )( ) ( )

 

### Cost estimate is still being prepared
 

### 100-400 samples
 

### $2-5MM G t i i ith i ti  

### G eome t r i c i ncrease w ith spec i a ti on11/8/2010

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## 9. Equipment Leaks (98.123 (c)(3))

 Leak Detection and Re p ai r NESHAPs and Permit Conditions Method 21 and Pressure Tests (Alternative Work Practice)  Insignificant Emission Source Mechanical integrity programs Welded vs. flanged fittings Industrial Hygiene issues Pressure checks  Example HAP Emissions: Screening Value Correlation Equipment Leak Emissions: 1% of Total



## 9. Equipment Leaks (cont.)

 

### Protocol for Equipment Leak Emission Estimates
 

### Cordova Study (May, 2010) FTIR TestingMeasurement of 300+ pieces of equipment in FGHG service GHG service Area Ventilation Monitoring Exhausts

 EPA Method 204 Capture Efficiency

 EPA Testing Methods11/8/2010

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## 9. Equipment Leaks (cont.)

 

### Recommended changes to rule language Recommended changes to rule language Reduced testing frequency Use of “survey” information Alternative methodologies Exemption of low-GWP processes



# Other Issues – Process Scrubbers

 

## HF Removal
 

## Secondary control devices
 

## Removal/reaction of acid halides Carbonyl fluoride, CF 2 

### O Atmospheric Lifetime: 5

- 10 days Atmospheric Lifetime: 5 10 days Tracked in 3M’s inventory, but no GWP contribution
 

## Evaluate gas stream at outlet of scrubber11/8/2010

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## Other Issues – 3M Corporate Incinerator

 Co -l ocated i h F- G H G p r oduct i o n f ac ili ty w t a G p oduct o ac ty  Multi-divisional plant site  Corporate Hazardous Waste Incinerator Rotary kiln incinerator Multiple waste feed capabilities Stand alone facility  98.124(f)(3)or(4): “....most-difficult-to-destroy fluorinatedGHG fed into devices from pro cesses subject to this part...”  Language differs from preambl e discussion, i.e. surrogate  Trial Burn Scheduling



# Summary

 

# Analytical speciation Analytical speciation
 

# Flexibility
 

# 3M Climate Leaders Model