Proposed Rule: Mandatory Reporting of Greenhouse Gas Emissions 

Meeting Documentation for 17 November 2009 Telephone Call with Air Products RepresentativFluorinated Gas ProductionDate: 17 November 2009Staff Contact Information (Name, email, phone #): Deborah Ottinger, EPA, 343-9149, Ottinger.deborah@epa.gov; Karen Schaffner, RTI, ksschaffner@rti.orgName of Organization (Attach list of all attendees names and emails if possible):

Keith Adams, Brian Keck, Woody Holbrook, Air Products 

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 Air Products representatives noted the following: Fluorinated GHG processes may be batch or continuous. The company makes two products (NF3 and CF4) here in the U.S

specific emission calculation factors that are based on detailed engineering calculations for the process, extensive process k

balances, i.e., stoichiometric balance, and computer simulations. To determine the emissions from each process step, the faemission calculation factor and the process activity measurement, then sums up each vent or unit emissions. The facility is comfortable that their site-specific emission factors are correct. The facility does currently estimate GHG emissions howevreport. The facility focuses on maximizing yield. ASPEN is one computer simulation software they use, along with a site-spreadsheet that has been developed to conduct calculations.The facility noted that daily measurements and calculations are not appropriate. Longer timeframes than daily give better d

recommend a quarterly or annual basis. The facility explained that in addition to the emission calculation factor, they have conducted emissions testing and compar

emission values with calculated emission values. The facility set up a two week testing period to measure vent concentrati

analytical equipment to verify the calculated emissions. The measured emissions rate was close to the calculated emissions approximately 10 percent. There is significant effort that goes in to conducting testing and vent measurements; this should 

could be done once. The facility does not have permanent concentration measurement monitors in place. The facility calcurelying on engineering calculations and by testing to develop the emissions factor. The facility tracks on an ongoing basis of the process. To ensure that emission factors are representative of process operation, the facility completed a detailed study to verify theiNF3). Under this detailed testing program, they operated and tested through all process conditions. Startup and shutdown p

from steady state operations, however each startup and each shutdown were consistent from one to another (i.e., repeatable

some small differences from summer to winter (and some small differences for unexpected events, such as lightning and po
were no true “value” differences. Prior to conducting testing, the facility did upfront work/study of where to place the sam

when to conduct testing, and for how long. Safety issues during testing are a significant concern. Typically, it is PhD analrunning these methods, so the testing costs can be significant. They have also begun another study to verify their emission 

Ms. Ottinger asked whether the facility had conducted any efforts similar to a scoping test to identify byproducts. The faci

byproduct analysis, using GC laboratory analysis. The facility determined there are not a lot of byproducts for their proces

from the analysis that were not recognizable and already known. The byproduct compounds formed are considered propriefacility confirmed that no fluorinated GHG byproducts are made. The facility has developed emission factors for all fluorin

emitted from processes. The facility suggested that the rule reference and allow other emission test methods. For PFCs, the Protocol for Measuring Destruction or Removal Efficiency of Fluorinated Greenhouse Gas Abatement Equipment in Elect

(EPA’s DRE Protocol). There is no destruction device for the fluorinated gas processes. Scrubbers are in place to control emissions of HF, fluorinederivatives. The facility minimizes equipment leak emissions. The site uses diaphragm or bellows valves to minimize leaksniffers or monitors are used. However, newly built equipment is leak tested with helium before being put into service. Th

pressures, which minimizes fugitive emissions, and most process equipment is indoors, i.e., within production buildings. A

NF3) are permanently in place within production process rooms to protect operators; these are mainly for safety purposes a

environmental emission estimating purposes. Cleaning is not done for the most part for their processes, since the processes use dedicated equipment. Purging is conduct

in the facility emissions estimate based on an emissions calculation (based on T, P, thermodynamic conditions). The uncertainty of the emissions estimates is estimated at about +/-14 percent. This was based on engineering judgment, in

between calculated and measured emissions and the estimated uncertainties of the various factors feeding into the emission

error propagation was not used. The staff summarized by noting that short-term measurement and calculation are not appropriate. The proposed rule mass 

costly and less accurate, and certainly no more accurate, than their EF approach with monitoring input variables and proces

emissions. They noted that knowing the process very well was key to valid emission estimates. The emission factor appro

approach. If the emissions factor value was reviewed periodically or remeasured periodically, these data would show that edecline/reduce over the years. This is due to process improvements that continually occur to lower emissions. The facility specific process changes occur, they evaluate the changes by assessing on paper, i.e., fundamental chemical engineering ca

Staff commented on the overlap between subpart L and subpart OO. Written Comments Provided?Did they also submit to Docket?
No

Date sent to EPA- CCDNone