Promulgation: Mandatory Reporting of Greenhouse Gas EmissionsMeeting Documentation for Telephone Call on September 16, 2010 with DuPont Representatives RegardingFluorinated Gas Production Re-Proposal RuleDates:September 16, 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):John Dege, Robert Giraud, Paul Jann, Suhas Mahuli, Brad Martin, Patricia McGee, Ed Robinson, DuPontSummary 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.DuPont representatives noted the following:•With respect to destruction devices, they are not looking at PICs, but this may havebeen done on the pilot-scale testing. NIST has donemuch work on PICs, particularly Dr. Wing Tsang. University ofDayton has also done much workon the thermal stability list. [EPA notedthat CF4is difficult to destroy and tends to form as a PIC.] Ingeneral, get good bond breakage for C-F bond at the correct hightemperatures. Under the temperature and residence time of their destruction device, it achieves C-F bond breaks. Typically CF4would bein concentrations of ppm at the outlet and not in the percent level. If PIC testing must be done, EPA should allow literatureor modeling tobe done, and also conduct testing on small-scale or bench-scale destruction devices because these approach are much less expensive. Useinformation from models and literature data. The costs are high for measuring compounds down totrace concentrations, i.e., 7ppmvversus 7 percent are significantly different; often will use simulation modeling to determine thewhether the concentration isin ppmvrange or the percent range.•A mass balance approach based on total Fluorine seems reasonable,however the facility will have tothink through this approachfurther.The total Fluorine approach allows its use on transformation processes. The total Fluorine content could be determined from aburnermethod. Once you get total Fluorine then must figure out howto allocate to product compounds, reactant compounds, and byproductcompounds. This approach seems to include a few more steps thanthe re-proposed mass balance method. In some ways, the totalFluorine balance may be more simple, however they will need towork through an example by applying it to a process to see howreasonable. In other example applications of the mass balanceapproach, the error calculation showed high error, and the errorcriterialimits are too tight. A mass balance on an element is likelygood, and option to base on another element besides Fluorine would also beappropriate. Perhaps having both mass balance approaches as available options would begood. [EPA asked about appropriate methodsthat could be used for total fluorine analysis.]•The schedule for subpart L is tight. Subpart OO was relatively simple compared to subpart L requirements. Facilities will need BAMMfor the full first year.Written Comments Provided?No.Did they also submit to Docket?No.Date sent to EPA- CCDNone