Promulgation: Mandatory Reporting of Greenhouse Gas Emissions 

Meeting Documentation for Telephone Call on May 21, 2010 with Air Products Representatives 

Fluorinated Gas Production Re-Proposal Rule

Dates: May 21, 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) Brian Keck, Chris Kahuhn, Keith Adams, Woody Holbrook, Pete Marguilies, David Cooper, Air Products 

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. Air Products participants have been reviewing the re-proposed rule and plan to continue their review. Air Products participfollowing: 

• Participants reviewed the definition of a “process” and identified example cases and asked how they should be inte

has multiple process lines where the product is pulled/comes together? [RTI noted these are likely one process.] I

are vented together, from the same process, are they considered one process vent? [RTI noted that yes, these are li

facility had identical process lines, can develop an emission factor for one and use that for the other lines? If differ

are made? [EPA noted if same grade of product, then likely yes.] 

• A hybrid approach should be considered that doesn’t use either the mass balance or emission factor approach but ra

of these. The mass balance is used more for the overall process, in looking at the raw material fed and the product 

approach), and then the emission factor approach could also be used to look at emissions from process vents (micro noted that it would be okay to mix and match approaches for a process, if facilities are able to separate the process 

Participants suggested EPA should allow facilities to do whatever makes the most sense as long as it captures the eshould provide guidance regarding equipment that comes on and offline as a part of operation (i.e., two pieces of ewhere one goes offline to regenerate). 

• Requested clarification on determining whether a process is continuous or batch. Some processes are part continuo

emissions occur from startup or shutdown, and some batch or episodic venting of emissions occurs from continuou

suggested that it may be better to look at individual process vents and categorize them according to continuous pro

process vent; for example, a continuous process may have batch emission events.] 
• Requested flexibility and additional test method options be included. The test methods included in the re-proposal 

for NF3 production. There are safety issues for streams and vents where HF is present; industry would like to avoid 

Method 21 is not appropriate for NF3. Significant analytical work is conducted in the research and develop stage, i

spectrometry, and gas chromatography. 

• Noted that facility uses control devices for control of HF and not for F GHG. 

• Noted that the mass balance error criteria could use some clarification regarding the “less than” and “or” terms. [

error calculation worksheet was available to share with industry.] 

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