1

Responses to EPA Review of Fluoropolymers Incineration ECA Final Study Report

The	text	below	responds	to	each	of	the	Questions	on	the	Final	Study	Report	for	Fluoropolymer	

Incineration	ECA	Testing	sent	by	e‐mail	on	May	20,	2013	from	Joe	Avcin	of	EPA	to	Philip	Taylor.		

Both	Phase	I	and	Phase	II	testing	described	in	the	Final	Study	Report	were	performed	in	accordance	

with	the	requirements	of	the	Enforceable	Consent	Agreement	(ECA)	and	TSCA	GLPs	as	embodied	in	

the	EPA‐approved	Quality	Assurance	Project	Plans	(QAPPs).		The	project	team	established	and	

executed	a	quality	management	system	to	assure	conformance	with	the	EPA‐approved	QAPPs	and	

documented	such	conformance	in	the	Final	Study	Report	submitted	October	30,	2009.	

Area #1 – Preparation of Composite #3

The ECA test protocol stipulates that the four fluoropolymer test substance composites will consist of

the 17 components listed in Table 1 below.  Composite #1 shall be representative of a dry non‐melt resin

and will contain compound numbers 1, 3, and 13.  Composite #2 shall be representative of a dry melt

resin and will contain compound numbers 2, 3, 4, 5, 6, and 12.  Composite #3 shall be representative of

a fluoroelastomer (a dry non‐melt gum) and will contain compound numbers 4, 7, 8, 9, 10, 11, 15, 16,

and 17.  Composite #4 shall be representative of an aqueous dispersion and will contain compound

numbers 1, 2, 3, 4, and 14.  However, the documented composition of Composite #3 does not seem to

comply with the stipulations of the ECA test protocol.

According to the Phase II composite preparation report, Composite 3 does not appear to have been

prepared with all specified materials.  The composite preparation data logs indicated that compound 4

and 7 were not included in the composition of the composite.  Upon further review, it appears that

Dyneon, LLC was responsible for providing compound 4 for Composite 2 and 4.  However, it is unclear

whether the company was also responsible for providing compound 4 for Composite 3.  The report also

indicates that compound 7 was not assigned to any of the participating companies to provide for the

study by the ECA.  The reason for this discrepancy and responsible party are not clear.
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Table 1.  Fluoropolymers To Be Formulated Into Composites For This ECA Testing Program

Compound

Number

Inventory ID #,

Accession ID #,

and/or CAS ID # Chemical Name Generic Chemical Name

1 CAS # 9002‐84‐0 Ethene, tetrafluoro‐, homopolymer PTFE

2 CAS # 25067‐11‐2 1‐Propene, 1,1,2,3,3,3‐hexafluoro‐, polymer

with tetrafluoroethene

FEP

3 CAS # 26655‐00‐5 Propane,1,1,1,2,2,3,3‐heptafluoro‐3‐

[(trifluoroethenyl)oxy]‐, polymer with

tetrafluoroethene

Modified PTFE

4 CAS # 25190‐89‐0 1‐Propene, 1,1,2,3,3,3‐hexafluoro‐, polymer

with 1,1‐difluoroethene and

tetrafluoroethene

THV

5 DCN # 63040000026 ETFE ETFE

6 CAS # 35560‐16‐8 1‐Propene, 1,1,2,3,3,3‐hexafluoro‐, polymer

with ethene and tetrafluoroethene

HTE

7 CAS # 9011‐17‐0 1‐Propene, 1,1,2,3,3,3‐hexafluoro‐, polymer

with 1,1‐difluoroethene

Fluoroelastomer

Copolymers

8 CAS # 54675‐89‐7 1‐Propene, polymer with 1,1‐difluoroethene

and tetrafluoroethene

Base Resistant Elastomer

9 CAS # 27029‐05‐6 1‐Propene, polymer with tetrafluoroethene Base Resistant Elastomer

10 CAS # 26425‐79‐6 Ethene, tetrafluoro‐, polymer with

trifluoro(trifluoroethoxy) ethene

Perfluoro Elastomer

11 CAS # 9010‐75‐7 Ethene, chlorotrifluoro‐, polymer with 1,1‐

difluoroethene

CTFE Elastomer

12 CAS # 31784‐04‐0 Ethene, tetrafluoro‐, polymer with

trifluoro(pentafluoroethoxy)ethene

Not Available

13 DCN # 6304000018A Polytetrafluoroethylene Polytetrafluoroethylene

14 DCN # 6304000018B Polytetrafluoroethylene Polytetrafluoroethylene

15 DCN # 6304000018C Fluoroelastomer Fluoroelastomer

16 DCN # 6301000018D Fluoroelastomer Fluoroelastomer

17 ACC # 137678 Low Temperature Fluoroelastomer Low Temperature

Elastomer

EPA	states	that	“the	documented	composition	of	Composite	#3	does	not	seem	to	comply	with	the	

stipulations	of	the	ECA	test	protocol”,	noting	that	CAS	25190‐89‐0	and	CAS	9011‐17‐0	were	

apparently	not	included	in	Composite	#3.	

During	the	call,	we	confirmed	that	the	term	“test	protocol”	refers	to	the	“Quality	Assurance	Project	

Plan	for	the	ECA	Incineration	Testing	Program	–	Phase	II	Fluoropolymers	Incineration	Testing”	

(QAPP).			The	Composite	Preparation	Report	for	Composite	#3	(fluoroelastomers)	is	contained	in	

Appendix	28	to	the	Final	Study	Report.		Report	Table	1	and	the	supporting	information	in	
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Appendices	ARDL‐C	and	ARDL‐D	show	that	3	of	the	materials	added	to	Composite	#3	were	not	

identified	with	a	CAS	number,	apparently	in	order	to	protect	confidential	business	information	

(CBI).			Unlike	the	Study	Director,	the	QA	Unit	for	the	project	had	access	to	confidential	identity	

information	for	the	materials	sent	by	the	companies	to	form	the	composites.		As	the	QA	Unit’s	

Composite	Preparation	Report	Review	for	preparation	of	the	fluoroelastomer	composite	at	ARDL	in	

Appendix	1	to	the	Final	Study	Report	shows,	“The	documented	composition	of	this	composite	is	as	

described	in	Attachment	8	of	the	QAPP	with	tabulated	components	as	described	in	Attachment	7	of	

the	QAPP.”		In	order	to	ensure	that	the	Final	Study	Report	would	not	contain	CBI,	the	companies	

claiming	CBI	on	the	identity	of	their	contributions	to	a	test	substance	composite	sent	non‐redacted	

copies	of	the	Chain	of	Custody	Form	(used	to	transmit	samples	to	ARDL)	to	Docket	OPPT‐2003‐

0071	at	the	EPA	OPPT	Document	Control	Office	that	included	the	confidential	CAS	numbers	for	the	

material(s)	pursuant	to	Section	XIV.D	of	the	ECA.		Therefore,	EPA	staff	has	access	to	the	confidential	

identity	information	provided	by	the	Companies	that	can	be	used	to	confirm	the	QA	Unit’s	finding	

that	Composite	#3	was	prepared	in	accordance	with	the	requirements	of	the	QAPP.	

Area #2 – Deviation from QAPP

Table 2 below provides a summary of the facilities responsible for the major activities related to Phase II

incineration testing for the fluoropolymer incineration study.  For each major activity, the table lists the

facilities specified in the QAPP and the actual facilities specified in the final report that performed the

task.  The principle deviation in the facilities from the QAPP is the inclusion of Akron Rubber

Development Laboratory, Inc. and Shealy Environmental Services, Inc. for compositing and analysis.  

Additionally, Exygen Research was purchased by MPI Research and is referenced in the final study report

as MPI Research.
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Table 2.  Facilities Responsible for the Activities Related to Phase II Incineration Testing for the

Fluoropolymer Incineration Study

Activity Facility Specified in QAPP

Actual Facility Specified in Final

Report

Supply of fluoropolymer

components

AGC Chemicals Americas, Inc.

(Bayonne, NJ); Clariant GmbH

(Charlotte, NC); Daikin America,

Inc. (Orangeburg, NY); E.I. du

Pont de Nemours and Company

(Wilmington, DE)

AGC Chemicals Americas, Inc.

(Bayonne, NJ); Clariant GmbH

(Charlotte, NC); Daikin America,

Inc. (Orangeburg, NY); E.I. du

Pont de Nemours and Company

(Wilmington, DE)

Compositing fluoropolymer

composites

StereoChemical, Inc. (Newark,

DE)

Composites 1, 2, and 4:

StereoChemical, Inc. (Newark,

DE)

Composite 3: Akron Rubber

Development Laboratory, Inc.

(Akron, OH)

Composite analysis (carbon and

hydrogen and percent solids)

Exygen Research (State College,

PA)

Akron Rubber Development

Laboratory, Inc. (Akron, OH)

Composite analysis (total

fluorine and percent solids)

StereoChemical, Inc. (Newark,

DE)

StereoChemical, Inc. (Newark,

DE)

Incineration testing facility

(combustion stoichiometry, TGA,

ATRS operation, and exhaust gas

monitoring)

UDRI (Dayton, OH) UDRI (Dayton, OH)

Impinger samples and field

blanks analysis (PFOA and total

fluorine)

Exygen Research (State College,

PA)

PFOA: MPI Research (formerly

Exygen Research)

Fluoride ion: Shealy

Environmental Services, Inc.

(West Columbia, SC)

	 	
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EPA	indicates	apparent	discrepancies	between	the	facilities	specified	in	the	QAPP	and	those	who	

performed	the	work	for	the	following	activities:	

a.	Preparation	of	fluoropolymer	composites,	

b.	Composite	analysis	for	carbon	and	hydrogen,	

c.	Impinger	analysis	for	fluoride	ion,	and	

d.	Name	change	of	Exygen	Research	to	MPI	Research.	

a.		

Section	A4	of	the	EPA‐approved	QAPP	(page	11)	notes	that	Edward	Gaffney	of	StereoChemical,	Inc.	

(Newark,	DE)	will	serve	as	compositing	facility	Task	Manager	for	those	composites	prepared	by	

StereoChemical,	Inc.	and	that	Jon	Kopsky	of	Akron	Rubber	Development	Laboratory	(ARDL)	will	

serve	as	compositing	facility	task	manager	for	one	or	more	test	substance	composites.		Hence,	the	

same	two	facilities	specified	in	the	QAPP	for	composite	preparation	were	used	for	composite	

preparation	as	noted	in	the	Final	Study	Report.	

b.,	c.,	d.	

Section	C1.4	of	the	EPA‐approved	QAPP	describes	the	Corrective	Action	approach	used	for	this	

project.		As	noted	in	QAPP	Section	C1.4,	“Corrective	action	is	the	process	of	identifying,	

recommending,	approving,	and	implementing	measures	to	correct	...	deficiencies	...	or	deviations	

from	the	approved	QAPP.”			Therefore,	the	Corrective	Action	process	was	used	during	this	project	

where	necessary	to	make	revisions	to	aspects	of	the	QAPP	needed	to	achieve	the	data	quality	

objective	for	the	project.		Corrective	Action	Forms	documenting	required	changes	to	the	QAPP	

made	in	accordance	with	Section	C1.4	of	the	QAPP	are	included	in	the	Quality	Assurance	Summary	

in	Appendix	1	to	the	Final	Study	Report.		Pursuant	to	Section	C2.1	of	the	QAPP	and	Section	XIV.A	of	

the	ECA,	the	companies	submitted	interim	progress	reports	every	180	days	during	the	project	

containing	QA/QC	Status	Reports	that	included	reporting	on	such	corrective	actions.	

b.		

As	the	Corrective	Action	Form	dated	December	6,	2007	(in	Appendix	1	to	the	Final	Study	Report)	

shows,	MPI	Research	(formerly	called	Exygen	Research)	discontinued	carbon	and	hydrogen	

analysis	testing,	triggering	the	need	to	identify,	recommend,	approve,	and	implement	a	replacement	

laboratory	to	perform	this	analysis.		This	Corrective	Action	Form	was	used	to	revise	the	QAPP	to	

name	Akron	Rubber	Development	Laboratory	at	2887	Gilchrist	Road	in	Akron,	OH	as	the	laboratory	

for	carbon	and	hydrogen	analysis	of	test	substance	composites	for	this	project.		Interim	Report	No.	

5	(dated	December	21,	2007)	informed	EPA	of	this	facility	change	and	the	related	corrective	action.	

c.		

As	the	Corrective	Action	Form	dated	August	28,	2009	(in	Appendix	1	to	the	Final	Study	Report)	

shows,	MPI	Research	(formerly	called	Exygen	Research)	had	difficulty	meeting	the	sensitivity	

requirements	for	analyzing	fluoride	ion	in	impinger	samples	via	ion	chromatography	(IC)	during	

the	Phase	II	Fluorotelomers	project.		Consequently,	Shealy	Environmental	Services	(West	Columbia,	

SC)	was	identified	as	a	qualified	laboratory	to	conduct	fluoride	ion	analysis	via	IC	for	the	Phase	II	

Fluoropolymers	project.		This	revision	to	the	QAPP	was	documented	in	the	Corrective	Action	Form	

noted,	and	this	Corrective	Action	Form	was	included	in	Appendix	1	to	the	October	2009	Final	Study	

Report.	

d.		

As	noted	by	EPA,	Exygen	Research	(State	College,	PA)	was	purchased	by	MPI	Research	and	changed	

its	name	to	MPI	Research.		This	name	change	was	documented	in	a	Corrective	Action	Form	dated	
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June	8,	2007	(included	in	Appendix	1	to	the	Final	Study	Report).		This	Corrective	Action	Form	is	

included	in	Appendix	1	to	the	Final	Study	Report.		Interim	Report	No.	3	(dated	December	29,	2006)	

to	EPA	included	contemporaneous	information	on	the	acquisition	of	Exygen	by	MPI.		Interim	Report	

No.	4	(dated	June	29,	2007)	to	EPA	noted	the	name	change	and	resulting	corrective	action.	

Area #3 – O‐ring a source of F?

During Composite 2 incineration testing of the previously‐completed fluorotelomer Phase II incineration

study, unsteady oxygen and carbon dioxide exhaust concentrations, perhaps due to exhaust gas leaks,

led to reactor system repairs.  The repairs included replacing corroded stainless steel tubing and

replacing the reactor exit‐end silicone O‐ring with a higher‐temperature‐rated perfluoroelastomer O‐

ring.  This perfluoroelastomer O‐ring remained in service during all fluoropolymer Phase II incineration

testing.  EPA would like to better understand if the observed fluoride ion concentrations in the impinger

samples may be the result of the O‐ring used in the reactor system as well as the combustion of the

fluoropolymer composites.

The final report concludes that the fluoride ion concentration resulting from the experimental runs are

due entirely to the combustion of the fluoropolymer composites.  This conclusion was made with the

following statement on page 16 and 17 of the final report:

“Fluoride ion analytical results for the pre‐test steam cleanings (in contrast to pre‐test

thermal blanks) indicate that degradation of the perfluoroelastomer O‐ring on the

reactor exit is the primary source of fluoride ion in the impingers under post‐run steam

cleaning conditions. (These conditions include higher exit end fitting temperature and

much higher exhaust gas water concentration than during experimental runs.) Hence,

the fluoride ion results for the experimental runs correspond directly to the combustion

of the fluoropolymer composites, independent of O‐ring degradation during steam

cleaning.”

EPA finds a potential issue with using a perfluoroelastomer O‐ring as a corrective action to repair a leak

in the exhaust gas line and with concluding that its use had no effect on the results for experimental

runs.  The impinger results for the thermal blanks also contained a detectable concentration of fluoride

ion ranging from 0.031 to 0.12 mg/L (approximately ten‐ to twenty‐times less than the combustion

experimental run results).  The contribution of fluoride ion during the thermal blank runs may also be a

result of O‐ring degradation.  Therefore, EPA wants to know if it is possible that a portion of the fluoride

ion present during the experimental runs may also be a result of O‐ring degradation.   

EPA	asks	about	the	potential	contribution	of	perfluoroelastomer	O‐ring	degradation	under	

experimental	run	conditions	to	fluoride	ion	results	for	experimental	run	impinger	samples.	

We	are	looking	into	this	question	and	plan	to	respond	to	the	Agency	on	this	area	at	a	later	date.				
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Area #4 – CGA Concerns

Issues were encountered during testing that involved the continuous gas analyzer (CGA).  During the

post‐run thermal blank for the third run, the CGA unexpectedly shutdown and the post‐run thermal

blank had to be rerun.  As a result of this issue, the CGA was serviced by the manufacturer prior to the

seventh set of runs.  It is noted in the final report on page 47 that the pressure drop across the CGA

decreased to 14 inches W.C. during the final six runs compared to 22 inches W.C. that was observed

during the first six runs.  It was also noted that the records for the recalibration of the CGA after it was

serviced were not provided (see response to Subtask 8).  It is not clear how this pressure drop may have

affected the final results or if it had any effect at all.

Additionally, during part of the ninth post‐run steam cleaning and all of the twelfth post‐run steam

cleaning, the CGA was connected to the reactor system exhaust gas.  The established protocol was to

not have the CGA connected during steam cleanings to prevent condensation from occurring in the

tubing of the machine.  It is not clear how this affected the final results or if it had any effect at all.   

EPA	raises	questions	about	(a)	recalibration	of	the	continuous	gas	analyzer	(CGA)	following	service	

by	the	manufacturer	prior	to	beginning	Run	7	(see	page	47	of	Final	Study	Report),	(b)	the	potential	

impact	of	the	change	in	pressure	drop	across	the	CGA	as	a	result	of	such	service,	and	(c)	potential	

effect	of	the	CGA	being	connected	to	the	reactor	system	exhaust	during	post‐run	steam	cleaning	for	

part	of	Run	9	and	all	of	Run	12.	

(a)	As	the	October	7,	2009	Corrective	Action	Form	by	Richard	Striebich	on	this	subject	(in	Appendix	

1	to	the	Final	Study	Report)	shows,	the	ABB	(CGA	manufacturer)	service	engineer	visited	the	UDRI	

lab	on	August	3,	2009.		As	a	result	of	his	diagnosis	of	the	cause	of	the	unexpected	shutdown	of	the	

CGA	during	the	Run	3	Post‐Run	Thermal	Blank	on	July	30,	2009,	the	ABB	service	engineer	bypassed	

the	malfunctioning	CGA	flow	sensor.		This	ABB	field	service	visit	did	not	include	conducting	or	

providing	a	record	for	calibration.		Following	the	August	3,	2009	service	and	prior	to	beginning	Run	

7,	the	CGA	was	recalibrated	by	UDRI	on	August	3,	2009	as	described	in	Richard	Striebich’s	notebook	

pages	62‐63	(in	Appendix	36	to	the	Final	Study	Report).		These	notebook	pages	constitute	the	

records	for	this	recalibration.	

(b)	We	are	still	looking	into	the	pressure	drop	question	and	plan	to	respond	to	the	Agency	on	this	

sub‐area	at	a	later	date.						

(c)	Richard	Striebich	prepared	a	separate	October	7,	2009	Corrective	Action	Form	(included	in	

Appendix	1	to	the	Final	Study	Report)	regarding	the	connection	of	the	CGA	to	the	reactor	system	

exhaust	gas	during	post‐run	steam	cleaning.		Standard	practice	aimed	at	preventing	excess	water	

entering	the	CGA.		However,	the	CGA	was	inadvertently	left	connected	to	the	reactor	exhaust	during	

the	first	20	minutes	of	the	75	minute	water	injection	phase	of	the	Run	9	post‐run	steam	cleaning	

and	for	the	complete	75	minute	water	injection	phase	of	the	Run	12	post‐run	steam	cleaning.		As	

this	Corrective	Action	Form	indicates,	excess	water	entering	the	CGA	during	these	two	situations	

resulted	in	artificial	CO	spikes	due	to	the	overlap	of	the	infrared	absorbance	spectra	for	water	and	

CO.		As	the	CGA	graphical	output	in	Appendix	67	to	the	Final	Study	Report	shows,	the	CGA	readings	

for	CO,	CO2,	and	oxygen	during	both	the	Run	9	and	the	Run	12	Post‐Run	Thermal	Blanks	(following	

the	corresponding	Steam	Cleanings)	returned	to	levels	comparable	to	the	Pre‐Run	Thermal	Blanks.		
8

Therefore,	there	was	no	lasting	effect	of	the	inadvertent	introduction	of	excess	water	to	the	CGA	

during	the	Run	9	and	Run	12	Steam	Cleanings.	

Area #5 – Table 18 Fluoride Ion Recovery

The results in this table show that the fluoride ion recovery greatly varied from as low as 58% to as high

as 120%.  The report did not offer any explanations as to the reason for the deviations in recovery.  

Further, the study did not subtract any estimate of baseline fluoride ion levels due to degradation of the

O‐ring: the measured fluoride ion concentration and measured impinger water volume were used to

calculate the recovered fluoride ion.  The presence of a baseline level of fluoride ion could potentially

account for the fluoride ion recoveries greater than 100% but would not account for the fluoride ion

recoveries less than 100%.

EPA	notes	that	the	report	did	not	explain	the	reason	for	fluoride	ion	recovery	values	in	Table	18	

ranging	from	58%	to	120%.	

As	Section	II.F.4.b(1)	of	the	Final	Study	Report	(p.	56)	notes,	“Comparison	of	experimental	run	

fluoride	ion	results	to	predicted	fluoride	levels	in	the	impingers	yield	recoveries	between	70%	and	

130%	for	at	least	two	of	three	runs	for	each	composite.”		We	focused	on	closing	the	fluoride	

material	balance	within	70%	to	130%	for	two	of	three	runs	based	on	the	two	out	of	three	logic	used	

in	Section	C.2.5.5	of	Appendix	C	to	the	ECA	(QAPP	Attachment	2).			

Notwithstanding	that	logic,	all	of	the	experimental	run	results	for	fluoride	had	recoveries	within	the	

50%	to	150%	range,	which	is	strong	performance	considering	the	small	quantities	of	fluoride	in	the	

system	needed	to	assure	that	theoretical	thermal	reactor	system	exhaust	HF	concentrations	were	

consistent	with	uncontrolled	HF	emission	levels	from	full‐scale	municipal	waste	combustors	as	

noted	in	Section	II.F.4.b(2)	of	the	Final	Study	Report	(p.	57).			This	consistency	helped	assure	that	

thermal	reactor	system	operations	were	representative	of	typical	full‐scale	municipal	waste	

combustor	operating	conditions.			

As	the	Discussion	of	Results	in	Section	II.F.4	of	the	Final	Study	Report	(pp.	53‐55)	demonstrates,	

laboratory‐scale	testing	was	conducted	within	the	ranges	specified	in	the	EPA‐approved	QAPP	for	

the	four	primary	factors	specified	in	the	QAPP	to	assure	that	laboratory‐scale	testing	was	

conducted	under	conditions	representative	of	typical	full‐scale	municipal	waste	combustor	

operations:	(1)	temperature,	(2)	gas	residence	time,	(3)	exhaust	gas	oxygen	concentration,	and	(4)	

exhaust	gas	water	concentration.		Consistency	between	theoretical	thermal	reactor	system	exhaust	

HF	concentration	and	available	information	on	uncontrolled	HF	emission	levels	from	full‐scale	

municipal	waste	combustors	provided	a	fifth	assurance	that	this	laboratory‐scale	testing	was	

conducted	under	conditions	representative	of	full‐scale	municipal	waste	combustor	operations.		

Area #6 – Other Perfluorinated Compounds

The identity of the ions associated with some peaks in the chromatograms at various points during the

experiment were not clear.  What is the likelihood that there were other perfluorinated compounds

present in the samples?
9

EPA	notes	that	the	identity	of	ions	associated	with	some	peaks	in	the	chromatograms	were	not	

clear.	

We	appreciate	the	Agency	clarifying	during	the	call	which	chromatograms	were	being	referred	to.	

We	are	looking	into	this	question	and	plan	to	respond	to	the	Agency	on	this	area	at	a	later	date	after	

we	are	able	to	get	assistance	from	resources	familiar	with	the	LC/MS/MS	method.						

Area #7 – Exhaust Gas Data

Data were not found to support the estimate of an exhaust gas concentration of water of ~15 vol%

(calculated range of 8‐20%) for all Phase II experimental runs.  The only support for this statement is the

sample stoichiometric calculations provided in Appendix 10.   

EPA	indicates	that	the	only	support	for	exhaust	gas	concentration	of	water	in	the	Final	Study	Report	

is	in	the	stoichiometric	calculations	in	Appendix	10.	

Section	A7.1	of	the	approved	QAPP	(page	14)	includes	the	following	measurement	performance	

criterion:	

 Operation	of	the	thermal	reactor	system	to	provide	a	water	concentration	in	the	

exhaust	gas	of	approximately	15%	and	the	calculated	[emphasis	added]	water	

concentration	in	the	exhaust	gas	within	the	range	of	8%	to	20%.

Accordingly,	the	main	method	for	demonstrating	exhaust	gas	water	concentration	was	indeed	via	

the	stoichiometric	calculations	in	Appendix	10.			As	Section	F.4.a(3)	of	the	Final	Study	Report	(page	

55)	also	states,	MSD	(mass	selective	detector)	monitoring	data	in	Appendix	45	indicate	

approximate	water	levels	between	11.7%	and	14.4%	during	the	thermal	blanks	and	experimental	

runs.	

Area #8 – Calibration and Material Certs

During both Phase I and Phase II testing, a Florite 990 M2C2 universal flow controller was used to

control the flow rates of synthetic air, nitrogen, and the designated calibration gas through their

respective mass flow controllers.  While calibration records and certificates are provided for the

individual mass flow controllers, these data are not provided for the universal flow controller itself.

Additionally, during Phase II testing, the CGA aborted itself during the post run thermal blank after the

third experimental run.  As a result, the equipment was serviced by a technician from the equipment

manufacturer and recalibrated.  A calibration certificate and records of the calibration were not

provided for the recalibration of the CGA after the service was performed.

In	addition	to	apparently	repeating	the	first	part	of	Area	#4,	EPA	asks	about	calibration	records	for	

the	Florite	990	M2C2	universal	flow	controller.	
10

The	Florite	990	M2C2	universal	flow	controller	(UFC)	is	an	input‐output	device	that	provides	a	

digital	interface	with	the	Brooks	mass	flow	controllers.		As	such,	we	are	not	aware	of	any	calibration	

record	or	certificate	that	accompanied	the	Florite	990	M2C2.		

Detailed	calibration	information	for	the	actual	flow	metering	devices	(the	Brooks	mass	flow	

controllers)	is	presented	in	Appendices	11	and	40.				

During	the	Phase	II	Fluoropolymers	project,	UDRI	checked	the	overall	flow	measurement	system	

(Florite	UFC	plus	Brooks	MFCs)	to	confirm	accurate	gas	flow	monitoring;	this	overall	flow	check	is	

presented	in	Appendix	43	to	the	Final	Study	Report	along	with	the	Certificate	of	Assessment	for	the	

NIST‐traceable	Agilent	ADM‐2000	used	to	check	these	flows.