Promulgation: Mandatory Reporting of Greenhouse Gas EmissionsMeeting Documentation for TelephoneCall on May 21, 2010 with Air Products Representatives RegardingFluorinated Gas Production Re-Proposal RuleDates:May 21, 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)Brian Keck, Chris Kahuhn, Keith Adams, Woody Holbrook, Pete Marguilies, David Cooper, Air ProductsSummary 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 concerns regarding the reporting rule.Air Products participants have been reviewing the re-proposed rule and plan to continue their review. Air Products participants noted thefollowing:•Participants reviewed the definition of a“process” and identified examplecases and asked how they should be interpreted. Ifa facilityhas multiple process lines where the product is pulled/comes together? [RTI noted these are likely one process.] If multipleprocess ventsare vented together, from the same process, are they consideredone process vent? [RTI noted that yes, these are likely one vent.] If afacility had identical process lines, can develop an emission factor for one and use that for the other lines? If different grades of productare 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 rather uses a collectionof these. The mass balance is used more for the overall process,in looking at the raw material fed and the product made (macroapproach), and then the emission factor approach could also beused to look at emissions from process vents (micro approach).[EPAnoted that it would be okay to mix and match approaches for aprocess, if facilities are able toseparate the process into discrete segments.]Participants suggested EPA should allow facilities to do whatever makes the most sense as long as it captures the emissions, and EPAshould provide guidance regarding equipment that comes on and offline as a part of operation (i.e., two pieces of equipment inparallel,where one goes offline to regenerate).•Requested clarification on determining whether a process is continuousor batch. Some processes are part continuous and part batch,emissions occur from startup or shutdown, and some batch or episodic venting of emissions occurs from continuous processes, etc. [RTIsuggested that it may be better to lookat individual process vents and categorize them according to continuous process vent orbatchprocess vent; for example, a continuous process may have batch emission events.]•Requested flexibility and additional test method options be included. The test methodsincluded in the re-proposal rule are not applicablefor NF3production. There are safety issues for streams and vents whereHF is present; industry would like to avoid tapping an HF line.Method 21 is not appropriate for NF3. Significant analytical work is conducted in the research and develop stage, including FTIR, massspectrometry, 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. [EPA notedthat a drafterror calculation worksheet was available to share with industry.]Written Comments Provided?No.Did they also submit to Docket?No.Date sent to EPA- CCDNone