Proposed Rule: Mandatory Reporting of Greenhouse Gas EmissionsMeeting Documentation for October 2009 Telephone Calls withINEOS Fluor Representatives RegardingFluorinated Gas ProductionDate:8October 2009and 27 October 2009Staff Contact Information (Name, email, phone #):Deborah Ottinger, EPA, 343-9149,Ottinger.deborah@epa.gov; Karen Schaffner, RTI,ksschaffner@rti.org, Roy Neulicht, RTIName of Organization (Attach list of all attendees namesand emails if possible):Joel Hall, Shawn Cunningham, John Pacillo, INEOS FluorSummary of Discussion(e.g., applicability, reporting requirements, etc.):The purpose of the conference call was to discuss emissionestimation techniques and analytical methods available tomeasure fluorinated gasemissions. The INEOS Fluor representatives noted the following:The facility makes R-134a and is primarily a continuousoperation. Product goes to shift tanks where it is sampled for quality control and then istransferred to storage tanks. Staff routinely calculate production efficiency (yields) but do not conduct a detailed breakdown of what is lost andwhere. At their facility, no continuous process vents arevented to the atmosphere, all continuous process vents aresent to the thermal oxidizer forcombustion, followed by a scrubber. There are low fluorinated gas emissions at the outlet of the thermal oxidizer. Measuring of HF vents isdifficult.Emissions are typically calculated based on chemical engineering calculations. Process vents are not routinely analyzed because the streamscontain hazardous components, e.g., HF, and these streamsare not safe to measure. The facility limits any potential exposure of operators to HF.Operators are required to “suit up” in personal protectiveequipment (PPE) to work with HF streams. It is tricky to sample HF and fluorinatedorganics, since there are personnel and facility safety issues along with issues of sampling and analytical instrument damage. Based on theoriginal plant design, staff use the mass balance based on the process design. The facility has trouble measuring flowrates as well asconcentrations and does not typically have flow meters in place, since the materials of construction of the meter device are an issue with highlyacidic and corrosive streams. The facility has triedflow meters on several process streams but have not had luckwith them working properly.Typically the facility measures the HF flow through the scrubbing system in series with the thermal oxidizer. Formeasuring the flow rate to thethermal oxidizer, there is no Coriolis meter that can measure vapor flow rates to the accuracy of the originalproposed rule. The facility does nothave much flexibility in whether they conduct measurements ordo calculations due to the presence of HF. The facility noted that somebyproducts may be present in vent streams. They also noted that these would all be sent to the thermal oxidizer.The processes can run for a few days without venting to the thermal oxidizer and without venting to the atmosphere, if needed for some reason.The facility uses an emission factor based approach, specifically a site-specific emission factor approach, which could be considered a variant ofthe mass balance approach. The facility bases emission factors on monitoring over some period of time that accountsfor variability and seasonalconditions to determine emissions and the production rate. Thefacility noted that they would like EPA to match the level of effort with the size ofthe emission source. Cutoffs for individual vents could alsobe included, perhaps based on its percentage of the totalplantthroughput.The yield or efficiency of the process for the fluorinated organic is a focus. If a mass balance was an approach that EPA ends up requiring, theywould prefer the mass balance on the fluorinated organiccomponent only and not on HF. They have HF losses during theproduction process thatare not related to product. They are still trying to figure out how they would do a mass balance approach as laidout in the original proposal. Themeasurements that could be taken would not be to the accuracy of the original proposed rule. Tthe facility currently measures production from theday tanks to the storage spheres and then adjust for “in plant” inventory. The inventory in the day tanks is much more of an issue with a dailymass balance requirement than for a monthly balance or anannual balance. Daily analysis would show much variability. The monthly basis isbest, and this is what their current financial system isbased on.With respect to calibration of Coriolis meters, the facility noted that the vendor recommendation is that no ongoingcalibration is needed, i.e., theseunits never need to be recalibrated. These Coriolis meters conduct a validation check on themselves, i.e., the Coriolis self-checks and sends a flagor message if there is an error.The facility noted they sample the product stream on a regular basis. There is a consistent level of acid gasin the product stream, and they wouldlike to have the flexibility to use chemical engineering andthermodynamic principles to estimate the concentrations.The facility noted that decontamination of process equipment is only conducted when the thermal oxidizer is running.They also noted that whenmaintenance on the thermal oxidizer is needed, the processshuts down. A performance test was conducted on the thermaloxidizer using asurrogate compound to determine the DRE. There is alsoa scrubber on the backside of the thermal oxidizer, to scrubout HF before release of thestream to the atmosphere.The facility indicated that equipment leaks are small.They would not want to do actual monitoring/testing for equipment leaks.The facility decontaminates equipment but does not occur frequently (no cleaning is conducted). The composition of the decontamination streamsare known, based on the pressure, and these are sent to thethermal oxidizer. The facility currently develops emissionfactors for reportingemissions from decontamination. The facility develops morethan one decontamination EF, depending on the circumstances of thedecontamination, i.e., for unplanned shutdown, and for plannedshutdown.Measurement of streams with HF was discussed. The facility noted that measuring the organics can be done easily if you can clean or take the HFout of the stream. However, they noted that they would prefer to use engineering calculations. Hastelloy steel is agood material for HF samplinglines. The facility noted that they tried online sampling previously where they tried to strip out the HF before the GC. This was difficult to dosafely given the pressures involved. This approach is successful at measuring the fluorinated organic, but cannot determine the flow rate becausenot certain how much HF is stripped.The facility tried an FTIR type monitoring device in the1990’s. This was an inline, continuous device. The sample cell window got etched fromHF in the stream and required much maintenance on thesample cell windows. The facility noted that HF does notinterfere with the measurementof the fluorinated organic.The facility noted that they have used a Boreal laserto measure very low concentrations of HF in vent streams.It is used essentially as a “bypassvent monitor” or “vent monitoring system” on a vent that should never have HF.Written Comments Provided?Did they also submit to Docket?NoDate sent to EPA-CCDNone