Promulgation: Mandatory Reporting of Greenhouse Gas Emissions 

Meeting Documentation for Telephone Call on May 13, 2010 with Mexichem Fluor RepresentatFluorinated Gas Production Re-Proposal Rule. Dates: May 13, 2010 Staff Contact Information (Name, email, phone #): Deborah Ottinger, EPA, 202-343-9149, Ottinger.deborah@epa.gov; Karen Schaffner, RTI, ksschaffner@rti.org; Carrie Ric

Name of Organization (Attach list of all attendees names and emails if possible):Joel Hall, Shawn Cunningham, John Pacillo, Mexichem Fluor 

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 calcula

emissions along with other concerns regarding the reporting rule. Mexichem Fluor representatives also discussed concerns associated with the reporting rule. Mexichem Fluor representativedefinitions of “byproduct,” “destruction efficiency,” and “Trace concentration” should be included. They questioned whethconsidered by-products. Mexichem Fluor representatives noted that it is not clear when and how to do the mass balance error calculations. EPA no

had been prepared with example calculations, and EPA would share the spreadsheet. In particular, for a feed meter or a weaccuracy/precision of the instrument that should be used, or is it the accuracy/precision or error over 12 months for each m

that it is the error of the monitoring instrument that should be used; the 12 measurements over a year show the variability ovariability would even out over time. Mexichem Fluor representatives noted that they would determine the error for each s

over all streams over the process, and as an example, that they would include the accuracy/precision of the meter on the vesection that would be used, and the error on the analytical measurement for analysis of the concentration or composition of determine the error for that stream. Mexichem Fluor representatives noted that certified calibration standards are difficult to obtain for some fluorinated compo

by-products. Mexichem Fluor representatives noted that they still have HF in their main stream, and there is not a testing method for thisophisticated chemistry). The initial scoping study requires testing HF streams on a pre-control basis, i.e., before the contro

problem with employee exposure. Also, if the facility uses the emission factor approach, emissions testing must be done fothat there may sometimes be unexpected byproducts in the process. Mexichem Fluor representatives noted that they are noanalyze 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 co

are not achieving 99.9 percent. EPA explained that process vents with emissions greater than 10,000 mtCO2e or greater th

GHG and do not vent to a DD with 99.9 percent DE would have to do the emission factor approach (as opposed to the emisapproach), but that EPA asked for comment on the 99.9 percent DE. Mexichem Fluor representatives noted that sampling 

at the inlet to the DD is a problem. Mexichem Fluor representatives noted that the DE could be based on CO2e rather than 

their facility, the vent will contain mostly one fluorinated GHG compound and only trace concentration levels or impurities 

Mexichem Fluor representatives also noted that trace concentration is 0.1 percent of “fluorinated GHG” and not for one speMexichem Fluor representatives noted that they have a decontamination process that they will likely develop an emission fnot 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 calculation factor is too strict and is not used in other options of the rule. Mexichem Fluor representatives noted concerns with the confidential information that must be reported. The rule requires made, raw material in, the amount fed to and out of thermal oxidizer, and the remainder would be fugitive. They would rath

approach 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 emireadily apparent with alarms and are immediately addressed, so any fluorinated GHG in a stream with HF is not likely to b

Streams with HF concentrations greater than a particular threshold should be excluded from equipment leak monitoring. If threshold were included for equipment leaks, this would significantly reduce the number of equipment leak pieces. Mexichem Fluor representatives suggested that BAMM be extended for 2 years. The rule has many testing requirements, t

testing methods, and 1 year is not enough time. EPA noted that BAMM in the re-proposal rule is only in effect through the If facilities develop emission factors, they would have until December 2011 to test and develop, but would be required to trthe year. 

Written Comments Provided? No. Did they also submit to Docket? No. Date sent to EPA- CCD None