Promulgation: Mandatory Reporting of Greenhouse Gas EmissionsMeeting Documentation for Telephone Call on July 7, 2010with DuPont Representatives Regarding FluorinatedGas Production Re-Proposal RuleDates:July7, 2010Staff Contact Information (Name, email, phone #):Deborah Ottinger, EPA, 202-343-9149,Ottinger.deborah@epa.gov; Karen Schaffner, RTI,ksschaffner@rti.org; Carrie Richardson, RTI; RandyMcDonald, EPA.Name of Organization (Attach list of all attendees names and emails if possible):John Dege, Brad Martin, Paul Jann, Gwen Lawless, Keith Wilkins, Bruce Davis, DuPont.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 calculate fluorinated GHGemissions along with other concernsregarding the reporting rule.DuPont representatives noted the following:•Their Comment No. 15 in the public comment letter should have been 1.5 percent and not 15 percent. As in the preamble, thedenominator is also based on reactants not just emissions. Participants noted that error calculation could be expressed as a share of F GHGreactants. Discussed examples of error calculations in differentprocesses. If yield loss is as high as 1.5 percent, the facility has aninefficient process, is essentially throwing reactant away, and facilities will track the yield loss to ensure it remains low.Participants citedan example where the emission rate was 0.6 percent as a fractionof production, while the absolute error was 1.3 percent as a fraction ofproduction. The absolute error was modest comparedto production but high compared to emissions.•Their Comment No. 18 in the public comment letter is to keep equipment leak monitoring frequencies on a common basis. Regulatorycriteria for equipment leaks need to focus resources on significant F GHG emissions. Typical Method 21 monitoring devices do not detectsome F GHG, and use of Method 21 monitoring and calculationsfor F GHG will require newer technologies. Facilities should usethebest approach for their processes and F GHG and document their approach in the site GHG MonitoringPlan; the rule needs flexibility asthe technology for F GHG monitoring evolves, and later EPA and industry could work on best practices and guidance for theseinstruments. Focus should be on a cost-effective approach toestimate emissions without overstating equipment leak emissions.There arecalibration differences between an IR and anFID instrument. A Method 21 instrument needs to be a lightweight, portable, intrinsicallysafe instrument. FID and PID have response factors for F GHG well over 10, so will not meet the Method 21 requirements (that RF <10).Most IR instruments are close to 25 lb, which is relatively heavy for “portable” equipment. Certified calibration gas standardsfortraditional Method 21 calibration are not available for F GHG; facilities can develop their own calibration gas standards, andcandocument [EPA noted Method 21 allows facilities to prepare calibration gas standards]. DuPont is evaluating the MIRAN IR instrumentto sample some processes, however it has a sampling rate and probe diameter that do not meet M21 requirements. These instruments lookat specific band width associated with specific compound; have toadjust the band width to look at other compounds (i.e., requires tuningto specific chemicals). These IR instruments are typically4 times the cost of FID or PID instruments.•Other equipment leak details that are necessary include: a process threshold of 100 ton/yr; a 5 percent F GHG content threshold to beconsidered in F GHG service; add a light liquid definition; include difficult to monitor, unsafe tomonitor, and in vacuum serviceexclusions; focus on rotating equipment which account for the majority of leaks; monitoring frequency should be based on leak rates;monitoring frequency should be common across equipment types tosimplify the program (i.e., use entire population of rotating equipmentto develop leak frequency/rate); use sublot sampling, or soapbubble monitoring following by use of Method 21, to estimate emissionssince this is not an LDAR rule (no repair, estimate emissionsonly). Noted that use of default average emission factors from equipmentleak protocol overestimates emissions because really less than 2percent of components leak. Intheir equipment leak work, theAverageEmission Factors overestimate emissions by 100 to 1000 times the true emissions. Theynoted equipment leak emissions of 0.007percentof production, and noted that leak monitoring is a waste of time and money. Some monitoring such as with soap bubbles combined withuse of the emission leaks average emission factor for identified leaks is a better option. A participant suggested using soapbubbles andthen using SOCMI factors for leaks identified.•For initial scoping test and other process sampling and measurement for mass balance, allow process sampling. Facilities should beallowed to sample either the process vent or process streams. Use of upstream process sampling where there are already sampling portsshould be allowed (e.g., sample bottoms ofdistillation) along with process knowledge of in-stream process flows. [EPA noted thatmeasurement of process streams is allowed.] Facilities have their own methods forconducting process sampling. Every processstreamcannot be measured, not every unit has sampling ports, and facilities analyze where it can be done safely, then do calculationsbased onflows in and out, measurements that can be made, etc. As each process is different, facilities will have to best determine the approachneeded to sample each process and the best way to identify the compounds present.Process vents that are hazardous (i.e., HF present)could be monitored after scrubbershowever 100 percent humidity environment and difficult to monitor.•Both 124(a) initial scoping testing and 124(c) process vent testing have similarrequirements, however the intent of the requirements isexplained better in the preamble. 98.124(c)(1) requires universal stack testing for process vents >10,000 mtCO2e, but for hazardousstreams there are safety issues. For batch processes, the accuracy of testing is questionable. Process vents may be controlled by thermaloxidizers or sometimes only a scrubber; the scrubber may be forF GHG in a few cases but mainlyfor acid gas control.•[EPA asked about work done on PICs.]Written Comments Provided?No.Did they also submit to Docket?No.Date sent to EPA- CCDNone