Proposed Rule: Mandatory Reporting of Greenhouse Gas Emissions 

Documentation for October 2009 Site Visit to DuPont Corpus Christi, Texas Regarding FluorinaProductionDate: 19 October 2009Staff Contact Information (Name, email, phone #): Deborah Ottinger, EPA, 343-9149, Ottinger.deborah@epa.gov; Karen Schaffner, RTI, ksschaffner@rti.orgName of Organization (Attach list of all attendees names and emails if possible):

Tim McDaniel, Mark Kaufman, Bob Blaschke, Steve Kaaffman, Arky Andrews, Kristie Glenig., Michael Bates, Jim O’Co

Summary of Discussion (e.g., applicability, reporting requirements, etc.):The purpose of the site visit was to discuss emission estimation techniques and analytical methods available to measure flu

The DuPont representatives noted the following: DuPont produces fluorocarbon products at multiple sites and noted that they manage highly hazardous processes that use H

fluorinated and chlorinated compounds are hazardous and employee safety is their number one concern. The Corpus Chrisfacility and is considered a flagship plant. This site produces HFC-134a and HFC-152a. There is an intermediates process produces feedstream for the HFC-134a process. It is anticipated that the facility would be subject 40 CFR part 98, subpart 

facility is considered an area source for HAP. The facility has invested in emission controls. The site conducts extensive v

are vented to the thermal converter. The site has worked to reduce fugitive emissions, for example from equipment leaks. closed loop sampling and tank car loading and unloading. The requirement in the proposed rule to conduct daily samples is a significant issue for the facility. The facility prefers not streams daily but noted they could sample occasionally, for example annually rather than daily. A reduced frequency is mufrequent sampling increases the risk to employees from hazardous stream constituents. Process streams have been well-chaunderstood based on process chemistry, and the process flow sheet identifies compounds. These process flow sheets could alternative to daily sampling. In tracking production, the facility conducts a number of “cycle checks” or “true ups.” They have two systems that allow tmeasurement of production. One system is a process monitoring system along with a digital control system (DCS) where pis stored; it provides a data historian and archiving. The other system is a financial tool to determine the amount of materia

available to sell. This system is the official depository of production information. Sometimes the two tracking systems donnot intended to match up). The facility conducts a weekly “check” or “true up” (requires 2 days to complete the check) and 

balance or mass balance on a monthly basis to close the loop on raw material inputs, losses, and product generated. They n

conduct material balances on a daily basis. Staff noted that daily mass balance will lead to an increase in errors, for exampthis is due to multiple tanks, multiple transmitters, and movement of materials through the process and lag times. 
Currently, the facility collects data on the plant’s physical inventory, flow transmitters, and the process design for product a

inventory data includes storage weights and tank levels. Flow transmitters that are used include orifice meters (with lower percent required in the April 2009 proposed rule); magnetic meters; and Coriolis meters (these have lower maintenance, higalthough some difficulties include corrosive material contact and the unit not being compatible with all streams). The accu

each of these types of flow meters vary. The facility would use Coriolis meters in most every application if they could; a C

(i.e., 2 flanges) while an orifice meter would have several leak points (several flanges). A typical 1 inch to 3 inch Coriolis Hastelloy steel would be approximately $7,000 to $10,000. Staff noted that a mass balance that averages the yield for all raw materials is problematic. Invariably, the yield for one raw process will be high, for example on the organic, while the yield for another will be lower. If you must average them, then yield that is not representative. It may be better to estimate a “weighted mass” average yield that would be more true. 

Most processes are continuous. The facility may produce products in different equipment for a particular campaign. The fbased on zero emissions that emphasizes waste minimization, pollution prevention and reduction, recycle, and treatment. Aequipment leak emissions have been reduced by reducing the number of flanges/valves, and increasing use of seal-less pumincreased welded piping. For the most part, point sources are vented to an air pollution control device and are therefore a stotal facility emissions. Because the point source emission levels are small, equipment leak emissions are actually a larger facility emissions. This likely is a different emissions profile than may be seen at other facilities. Emissions are reported to the TCEQ each year. Emissions reporting at the facility is based on a number of methods, includassumptions, EPA AP-42 emissions factors and calculation equations, SOCMI factors, etc., monthly and yearly production 

maximum flow rates, in some instances the valve positions for vents or lines, the destruction efficiency of control devices s

recovery devices, and the thermal converter, vendor equipment specifications, and process flow sheets (pilot plant data, plu

knowledge). Overall, the facility uses AP-42 emission factors and calculations in permitting to estimate potential to emit edetermining the flow rates to the thermal converter, some vent lines have flow meters, while for others the valve position is the flow rate. The facility uses standard chemical engineering calculations in addition to AP-42 equations. The facility useflows, compositions, temperatures, molecular weights, etc. to estimate emissions. To develop emissions factors, the facility 

process chemistry and models (ASPEN) to determine and characterize compounds and concentrations for estimating emiss

For equipment leak monitoring, the facility conducts monitoring under different regulatory programs. The equipment leakprocess are subject to a state regulation, the TCEQ 28M program (covers lines that are 2 inches in diameter and greater), anfor HFC-152a are subject to Federal regulation in 40 CFR part 60, subpart VV; the rule allows “skip” monitoring provisionthan 2 percent leakers, where monitoring that is required each quarter would be required less frequently, for example, semiprocess meets the criteria for less frequent monitoring. The facility noted that they use default emissions factors to determi

emissions for equipment leaks and they use the correlation equations for reporting actual emissions to TCEQ. The facility contractor who conducts monitoring and estimates the annual emissions. Methane is used as the calibration gas. 
For tanker car loading, the facility uses AP-42 loading equations to estimate emissions. 

The thermal converter was installed in 1991 to 1992 and an initial performance test was conducted in 1994. The device de

compounds. Parametric monitoring is conducted to ensure the converter is operating at compliance levels. Staff noted that 

measure and speciate fluorinated compounds in the inlet vent stream to the Thermal Convertor due to acid compounds in th

inlet compounds are not currently speciated. The fluorinated gas concentration in the inlet stream to the thermal convertor Annual or quarterly sampling and recordkeeping will provide more useful data than daily sampling and recordkeeping. Dasampling and analysis, for streams that contain hazardous compounds significantly increase operator exposure to highly toxThe facility provided input on subpart OO. The existing measurement instruments meet ±1 percent. Unfortunately, the facrequired to speciate the onsite thermal convertor outlet streams; this problematic because the stream contains acids (HF) anscrubbed prior to measurement. This requires installing a sampling port along with an automated sampling and GC system of manual sampling. The capital costs for a GC instrument are high. Use of manual sampling, or process stream grab sampadditional manpower hours (and $) to suit up in personal protective equipment (PPE). Some processes with HF or other ha

would require that operators wear their PPE, including an acid suit and a breathing apparatus. These suits are cumbersome additional time and sometimes multiple operators to complete a task. The facility does not currently conduct periodic procsuits are used for process breakdown, shutdowns, or maintenance events. The facility provided input on the subpart L compliance schedule. The subpart L compliance schedule is challenging for th

multiple processes that include HF, HCl, Cl2, and flammable compounds, they follow a “management of change” process, OSHA Process Safety Management (PSM) and EPA Risk Management Program (RMP). A Change of Design (COD) imp

time, somewhere between 6 to 12 months cycle time. This rule requires a 12 month cycle time, which may be difficult to iother programs’ management of change processes. EPA should consider the business and practical implementation of increthat is consistent with other programs. The facility also noted that multiple facilities will be attempting to procure measurement equipment at the same time, whic

for the industry and certain vendors/equipment manufacturers. Staff also noted that there is no viable technology available 

acid streams (HF). For GC/MS, there are interference issues when measuring multiple fluorinated gases. Staff suggested icharacterize the waste stream. Staff noted that there are no HFC emissions from intermediate processes at the site; these intermediate processes generate CThere are no fluorinated GHG emissions from production of CFCs or HCFCs. The DuPont facility in Fayetteville, North Carolina also has hazardous compounds (odorless, colorless, toxic) and conducts 
The Fayetteville site manufactures polymers or HFEs (Teflon processes) and emits HFE’s, and the site will have some fluo

not have GWPs assigned. The DuPont facility in Parkersburg, West Virginia manufactures polymers or HFEs (Teflon procStaff reviewed several points from the discussion: the monitoring device or measurement device accuracy is not the same awhen there are multiple measurement devices, the precision is additive; the material balance for a continuous process can bdaily basis; suggested theoretical instrument accuracy and precision of ±1 percent; and monthly resolution of mass or mateappropriate. [Additional information is contained in the Confidential Addendum to the site visit containing additional notes.] Written Comments Provided?Did they also submit to Docket?No Date sent to EPA- CCDNone 
EPA Docket No. EPA-HQ-OAR-2009-0927 

 The following information is located in the confidentiality files of the Director, Climate 

Change Division, U. S. Environmental Protection Agency, Washington DC. This information is 

confidential pending final determination by the Administrator and is not available for public 

inspection. 

 Site Visit Notes from DuPont Corpus Christi, TX, D. Ottinger, U.S. EPA and K. 

Schaffner, RTI International. Dated October 19, 2009. 

 The notes contain additional information about the DuPont fluorinated gas production 

processes and the facility’s experience with emission estimation for fluorinated GHG. The 

confidential material is comprised of 13 pages of notes.