Proposed Rule: Mandatory Reporting of Greenhouse Gas Emissions 

Meeting Documentation for October 2009 Telephone Calls with INEOS Fluor Representatives RFluorinated Gas ProductionDate: 8 Octo

ber 2009 and 27 October 2009

Staff Contact Information (Name, email, phone #): Deborah Ottinger, EPA, 343-9149, Ottinger.deborah@epa.gov; Karen Schaffner, RTI, ksschaffner@rti.org, Roy Neulicht, 

Name of Organization (Attach list of all attendees names and emails if possible):

Joel Hall, Shawn Cunningham, John Pacillo, INEOS Fluor 

Summary of Discussion (e.g., applicability, reporting requirements, etc.):The purpose of the conference call was to discuss emission estimation techniques and analytical methods available to measemissions. The INEOS Fluor representatives noted the following: The facility makes R-134a and is primarily a continuous operation. Product goes to shift tanks where it is sampled for qualtransferred to storage tanks. Staff routinely calculate production efficiency (yields) but do not conduct a detailed breakdow

where. At their facility, no continuous process vents are vented to the atmosphere, all continuous process vents are sent to combustion, followed by a scrubber. There are low fluorinated gas emissions at the outlet of the thermal oxidizer. Measur

difficult. Emissions are typically calculated based on chemical engineering calculations. Process vents are not routinely analyzed becontain hazardous components, e.g., HF, and these streams are not safe to measure. The facility limits any potential exposu

Operators are required to “suit up” in personal protective equipment (PPE) to work with HF streams. It is tricky to sample organics, since there are personnel and facility safety issues along with issues of sampling and analytical instrument damagoriginal plant design, staff use the mass balance based on the process design. The facility has trouble measuring flow rates 

concentrations and does not typically have flow meters in place, since the materials of construction of the meter device are acidic and corrosive streams. The facility has tried flow meters on several process streams but have not had luck with them 

Typically the facility measures the HF flow through the scrubbing system in series with the thermal oxidizer. For measurin

thermal oxidizer, there is no Coriolis meter that can measure vapor flow rates to the accuracy of the original proposed rule. have much flexibility in whether they conduct measurements or do calculations due to the presence of HF. The facility notbyproducts 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 needThe facility uses an emission factor based approach, specifically a site-specific emission factor approach, which could be cthe mass balance approach. The facility bases emission factors on monitoring over some period of time that accounts for vconditions to determine emissions and the production rate. The facility noted that they would like EPA to match the level o
the emission source. Cutoffs for individual vents could also be included, perhaps based on its percentage of the total plant 

The yield or efficiency of the process for the fluorinated organic is a focus. If a mass balance was an approach that EPA enwould prefer the mass balance on the fluorinated organic component only and not on HF. They have HF losses during the 

are not related to product. They are still trying to figure out how they would do a mass balance approach as laid out in the 

measurements that could be taken would not be to the accuracy of the original proposed rule. Tthe facility currently measu

day tanks to the storage spheres and then adjust for “in plant” inventory. The inventory in the day tanks is much more of an 

mass balance requirement than for a monthly balance or an annual balance. Daily analysis would show much variability. T

best, and this is what their current financial system is based on. With respect to calibration of Coriolis meters, the facility noted that the vendor recommendation is that no ongoing calibratunits never need to be recalibrated. These Coriolis meters conduct a validation check on themselves, i.e., the Coriolis self-or 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 gas in the product slike to have the flexibility to use chemical engineering and thermodynamic principles to estimate the concentrations. The facility noted that decontamination of process equipment is only conducted when the thermal oxidizer is running. The

maintenance on the thermal oxidizer is needed, the process shuts down. A performance test was conducted on the thermal surrogate compound to determine the DRE. There is also a scrubber on the backside of the thermal oxidizer, to scrub out Hstream to the atmosphere. The facility indicated that equipment leaks are small. They would not want to do actual monitoring/testing for equipment lThe facility decontaminates equipment but does not occur frequently (no cleaning is conducted). The composition of the dare known, based on the pressure, and these are sent to the thermal oxidizer. The facility currently develops emission factoemissions from decontamination. The facility develops more than one decontamination EF, depending on the circumstancedecontamination, i.e., for unplanned shutdown, and for planned shutdown. Measurement of streams with HF was discussed. The facility noted that measuring the organics can be done easily if you c

out of the stream. However, they noted that they would prefer to use engineering calculations. Hastelloy steel is a good m

lines. The facility noted that they tried online sampling previously where they tried to strip out the HF before the GC. Thisafely given the pressures involved. This approach is successful at measuring the fluorinated organic, but cannot determine 

not certain how much HF is stripped. The facility tried an FTIR type monitoring device in the 1990’s. This was an inline, continuous device. The sample cell w
HF in the stream and required much maintenance on the sample cell windows. The facility noted that HF does not interfere 

of the fluorinated organic. The facility noted that they have used a Boreal laser to measure very low concentrations of HF in vent streams. It is used event monitor” or “vent monitoring system” on a vent that should never have HF. Written Comments Provided?Did they also submit to Docket?No Date sent to EPA- CCDNone