Proposed Rule: Mandatory Reporting of Greenhouse Gas EmissionsMeeting Documentation for 17 November 2009 Telephone Call with Air Products Representatives RegardingFluorinated Gas ProductionDate:17November 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 namesand emails if possible):Keith Adams, Brian Keck, Woody Holbrook, Air ProductsSummary of Discussion(e.g., applicability, reporting requirements, etc.):The purpose of the conference call was to discuss emissionestimation techniques and analytical methods available tomeasure fluorinated gasemissions. The Air Products representatives noted the following:Fluorinated GHG processes may be batch or continuous.The company makes two products (NF3and CF4) here in the U.S. The facility uses sitespecific emission calculation factors that are based ondetailed engineering calculations for the process, extensiveprocess knowledge, basic massbalances, i.e., stoichiometric balance, and computer simulations. To determine the emissions from each process step,the facility combines theemission calculation factor and the process activity measurement, then sums up each vent or unit emissions. Thefacility is very confident andcomfortable that their site-specific emission factors are correct. The facility does currently estimate GHGemissions however they do not currentlyreport. The facility focuses on maximizing yield. ASPEN is one computer simulation software they use, along with asite-specific Excelspreadsheet that has been developed to conduct calculations.The facility noted that daily measurements and calculations are not appropriate. Longer timeframes than dailygive better data, and theyrecommend a quarterly or annual basis.The facility explained that in addition to the emission calculation factor, they have conducted emissions testing andcompared the measuredemission values with calculated emission values. Thefacility set up a two week testing period to measure vent concentrations with temporaryanalytical equipment to verify the calculated emissions.The measured emissions rate was close to the calculated emissions rate, withinapproximately 10 percent. There is significant effort that goes in to conducting testing and vent measurements; this should not be done daily butcould be done once. The facility does not have permanent concentration measurement monitors in place. The facility calculates emissions byrelying on engineering calculations and by testing to develop theemissions factor. The facility tracks on an ongoing basisthe inputs and outputsof the process.To ensure that emission factors are representative of process operation, the facility completed a detailed studyto verify their emission factors (forNF3). Under this detailed testing program, they operated andtested through all process conditions. Startup and shutdownperiods were differentfrom steady state operations, however each startup and each shutdown were consistent from one to another (i.e., repeatable). There were alsosome small differences from summer to winter (and some small differences for unexpected events, such as lightning andpower outages), but therewere no true “value” differences.Prior to conducting testing, the facility did upfront work/study of where to place the sample ports for testing,when to conduct testing, and for how long. Safety issues during testing are a significant concern. Typically, it isPhD analytical chemists who arerunning these methods, so the testing costs can be significant. They have also begun another study to verify their emission factors for CF4.Ms. Ottinger asked whether the facility had conducted any efforts similar to a scoping test to identify byproducts.The facility has conductedbyproduct analysis, using GC laboratory analysis. The facility determined there are not a lot of byproducts for their processes: no other peaksfrom the analysis that were not recognizable and already known. The byproduct compounds formed are considered proprietary,however, thefacility confirmed that no fluorinated GHG byproducts aremade. The facility has developed emission factors forall fluorinated GHG present andemitted from processes. The facility suggested that the rule reference and allow other emission test methods. For PFCs, the facility suggested theProtocol for Measuring Destruction or Removal Efficiency of Fluorinated Greenhouse Gas Abatement Equipment in Electronics Manufacturing(EPA’s DRE Protocol).There is no destruction device for the fluorinated gas processes. Scrubbers are in place to control emissions of HF, fluorine, and fluorinederivatives. The facility minimizes equipment leak emissions. The site uses diaphragm or bellows valves to minimize leaks. No handheldsniffers or monitors are used. However, newly built equipment is leak tested with helium before being put into service. The processes run at lowpressures, which minimizes fugitive emissions, and most process equipment is indoors, i.e., within production buildings.Ambient monitors (e.g.,NF3) are permanently in place within production process roomsto protect operators; these are mainly for safety purposes as opposed toenvironmental emission estimating purposes.Cleaning is not done for the most part for their processes, since the processes use dedicated equipment. Purging isconducted and is accounted forin the facility emissions estimate based on an emissionscalculation (based on T, P, thermodynamic conditions).The uncertainty of the emissions estimates is estimated at about +/-14 percent. This was based on engineering judgment, including comparisonsbetween calculated and measured emissions and the estimated uncertainties of the various factors feeding into the emissions estimate. Formalerror propagation was not used.The staff summarized by noting that short-term measurement and calculation are not appropriate. The proposed rulemass balance method is verycostly and less accurate, and certainly no more accurate, than their EF approach with monitoring input variablesand process activity to estimateemissions. They noted that knowing the process very well was key to valid emission estimates. The emission factor approach is the bestapproach. If the emissions factor value was reviewed periodically or remeasured periodically, these data wouldshow that emissions factor valuesdecline/reduce over the years. This is due to process improvements that continually occur to lower emissions. The facility noted that whenspecific process changes occur, they evaluate the changes by assessing on paper, i.e., fundamental chemical engineering calculations and analysis.Staff commented on the overlap between subpart L and subpart OO.Written Comments Provided?Did they also submit to Docket?NoDate sent to EPA-CCDNone