Promulgation: Mandatory Reporting of Greenhouse Gas EmissionsMeeting Documentation for Telephone Call on May 13, 2010 with MexichemFluor Representatives RegardingFluorinated Gas Production Re-Proposal Rule.Dates:May 13, 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.Name of Organization (Attach list of all attendees names and emails if possible):Joel Hall, Shawn Cunningham, John Pacillo, Mexichem FluorSummary 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.Mexichem Fluor representatives also discussed concerns associated with the reporting rule. Mexichem Fluor representatives notedthat clearerdefinitions of “byproduct,” “destruction efficiency,” and “Traceconcentration” should be included. They questioned whether impurities wereconsidered by-products.Mexichem Fluor representatives noted that it is not clear when and how to do the mass balance error calculations. EPA noted that a spreadsheethad been prepared with example calculations, and EPA would sharethe spreadsheet. In particular, for a feed meter or a weigh scale, is it theaccuracy/precision of the instrument that should be used, oris it the accuracy/precision or error over 12 months for each measurement. EPA notedthat it is the error of the monitoring instrument that should be used; the 12 measurements over a year show the variability ofthe process, and thevariability would even out over time. Mexichem Fluor representatives noted that they would determine the error for each streamand sum the errorover all streams over the process, and as an example, that they would include the accuracy/precision of the meter on the vent from the distillationsection that would be used, and the error on the analytical measurement for analysis of the concentration or composition of thestream, todetermine the error for that stream.Mexichem Fluor representatives noted that certified calibration standards are difficult to obtain for some fluorinated compounds, particularly forby-products.Mexichem Fluor representatives noted that they still have HF in their main stream, and there is not a testing method for this stream (requiressophisticated chemistry). The initial scoping study requires testing HF streams on a pre-control basis, i.e., before the control device, but there is aproblem with employee exposure. Also, if the facility uses theemission factor approach, emissions testing must be done for this, too. EPA notedthat there may sometimes be unexpected byproducts in the process. Mexichem Fluor representatives noted that they are not certain they couldanalyze the HF and fluorinated GHG streams even under a one-time scoping test.Mexichem Fluor representatives noted that the 99.9 percent DE would have to be demonstrated for all fluorinated GHG compounds.Some DDare not achieving 99.9 percent. EPA explained that process vents with emissions greater than 10,000 mtCO2e or greater than 1 mt fluorinatedGHG and do not vent to a DD with 99.9 percent DE would have to do the emission factor approach (as opposed to the emission calculationapproach), but that EPA asked for commenton the 99.9 percent DE. Mexichem Fluor representatives noted that sampling HF containing streamsat the inlet to the DD is a problem. Mexichem Fluor representatives noted that the DE could be based on CO2e rather than fluorinated GHG. Fortheir facility, the vent will contain mostly one fluorinatedGHG compound and only trace concentration levels or impurities ofother compounds.Mexichem Fluor representatives also noted that trace concentration is 0.1 percent of “fluorinated GHG” and not for one specificcompound.Mexichem Fluor representatives noted that they have a decontamination process that they will likely develop an emission factor for, but they arenot certain what the process activity would be.Mexichem Fluor representatives noted that the process activity measurement with ±1 percent of full scale for the emission factor and emissioncalculation factor is too strict and is not used in other options of the rule.Mexichem Fluor representatives noted concerns with the confidentialinformation that must be reported. The rule requires reporting of the productmade, raw material in, the amount fed to and out of thermal oxidizer, and the remainder would be fugitive. They would rather see an overallapproach and not have to sample streams.This would allow for not direct sampling.Mexichem Fluor representatives noted other issues and concerns associated with equipment leak monitoring. Fugitive emissions with HF arereadily apparent with alarms and are immediately addressed, so any fluorinated GHG in a stream with HF is not likely to be emitted either.Streams with HF concentrations greater than a particular threshold should be excluded from equipment leak monitoring. If an HFconcentrationthreshold were included for equipment leaks, this wouldsignificantly reduce the number of equipment leak pieces.Mexichem Fluor representatives suggested that BAMM be extended for2 years. The rule has many testing requirements, there areissues with thetesting methods, and 1 year is not enough time. EPA noted that BAMM in the re-proposal rule is only in effect through the first quarter of 2011.If facilities develop emission factors, they would have until December 2011 to test and develop, but would be required to track the activity throughthe year.Written Comments Provided?No.Did they also submit to Docket?No.Date sent to EPA- CCDNone