Promulgation: Mandatory Reporting of Greenhouse Gas Emissions 

Meeting Documentation for Telephone Call on May 14, 2010 with 3M Representatives Regardin

Production Re-Proposal Rule.

Dates: May 14, 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, Jeff Muffat, Jeff McComas, Mike Parent, Tom Herzberg, Karl Warren, Brian Mader, Sooi Ooi, Leslie K

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 shared slide handouts for the conference call; see the attached slides for the full list of topics. 3M comments focused o

GWP for all compounds, equipment leak monitoring and alternatives, and industry variability. 3M representatives noted th

complicated of all the source categories included in 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 

balance, use past data, use modeling data), since measurements are done at laboratory scale process, in pilot plant scale prorepresentatives expressed concerns regarding extremely high costs associated with scoping test and compliance with this ru

noted that other methods should be allowed in 98.124(c)(4)(v) , such as internal methods, and that Method 18 is not usually 

representatives noted that surrogates should be allowed for calibration standards. 3M representatives had comments on mass balance approach and transformation processes. 3M representatives were not cuse the mass balance approach but the rule should allow for use of mass balance approach for transformation processes. EPproposal mass balance approach assumes that everything not accounted for is product, however EPA asked for comment co

characterization. EPA noted that a tweaked version of the mass balance approach might could be used for transformation p

3M representatives had comments on the preliminary emissions estimates for process vents. 3M representatives supported the preliminary emission estimates for process vents. For developing emission factors for batch processes, calculations worequiring emission testing. For process vent emissions thresholds, 3M representatives noted that post-control emissions levels would be better than preparticularly for batch processes. 3M representatives noted that the1 mt fluorinated GHG emission threshold is too low, espemission levels. 3M representatives suggested the rule be 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 mat

a fluorinated GHG is destroyed and not measurable at the outlet to the DD, then the amount of POHC fed to the DD would 

determine a DE. 3M representatives noted their concern about testing the corporate HWC that happens to be located onsite production. 3M representatives noted that the preamble uses the term “surrogate” for DD testing but the rule text does not. 

noted that some fluorinated GHG are not on the trial burn compound lists. 3M representatives noted concerns about whethwould be considered destruction devices and be required to conduct DE testing for them. Process scrubbers are used as bac

and are used for HF removal; these process scrubbers may remove certain fluorinated GHG but are not in place for this pur3M representatives noted that emission testing for process vents would have to be completed by December 2011. 3M repretiered schedule be adopted for emissions testing, where thresholds could be incorporated and those process vents with high tested the first year and other lower emitting process vents could be tested the second year. With the requirement to compl2011 and the number of process vents to be tested, the facility will be doing stack testing all year. The large number of pro

stack testing is costly and requires much manpower. The tiered testing approach allows highly skilled analytical staff to be 

oversight of testing activities. 3M representatives also noted that if emission testing is conducted for one operating scenario of a process, then EPA shoulaugment the emission factor for a second operating scenario, i.e., integrate the emission test with engineering calculations ffactor. There are high costs associated with having to test every operating scenario. They suggested requiring testing for thoperating scenario and use of engineering calculations for other operating scenarios. 3M representatives noted that use of IPCC procedures for determining GWP is appropriate, and EPA should approve use ousing this method. 3M representatives has several batch processes that have fluorinated GHG compounds that do not have 

reviewed literature. 3M representatives noted that there needs to be a procedure for adding GWP to Table A-1 of subpart A3M representatives noted that three one-hour test runs for continuous process vents testing is typical. 3M representatives nalternative to Methods 1 to 4 should be allowed. For batch process vents testing, integrated flow and concentration method

representatives noted that batch process vent testing for long batch cycles will be costly. 3M representatives will provide m

on 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 t

significant way. 3M representatives also expressed concerns about the possible presence of HF in the streams and concerns 

grab samples. 

Written Comments Provided? No. Did they also submit to Docket? 
No. 

Date sent to EPA- CCD None 
11/8/2010

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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 changes
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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

Distillations
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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 Post rather than pre-control emissions 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 emissions
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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)

 Example 
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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 development
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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 required for all processes

Batch cycles: 24 Batch cycles: 24-48 hours 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 Geometric increase with speciation
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9. Equipment Leaks (98.123 (c)(3))

 Leak Detection and Repair

 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 Testing 

Measurement of 300+ pieces of equipment in FGHG service GHG service

Area Ventilation Monitoring Exhausts

 EPA Method 204 Capture Efficiency

 EPA Testing Methods 
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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, CF2O

Atmospheric Lifetime: 5 Atmospheric Lifetime: 5-10 days 10 days

Tracked in 3M’s inventory, but no GWP 

contribution 

 Evaluate gas stream at outlet of scrubber
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Other Issues – 3M Corporate Incinerator

 Co-located w t a i h F-G G p oduct o ac ty HG production facility

 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 processes subject to this part...”

 Language differs from preamble discussion, i.e. surrogate

 Trial Burn Scheduling

Summary

Analytical speciation Analytical speciation

Flexibility

3M Climate Leaders Model