From: "Cerri, Gus" <gus.cerri@honeywell.com>

To: Deborah Ottinger/DC/USEPA/US@EPA

Date: 11/13/2009 12:52 PM

Subject: RE: Proposed Rule and Recap of Questions

Debbie:

I read the proposed rules, if I understand them correctly, a fluorocarbon plants would only have to track HFC emissions. HCFC's and CFC's would not be tracked. In my opinion the method that is proposed could work well for the main HFC product over a reasonably long time period, but would be difficult to implement accurately for the byproducts. If I understand correctly thatonly HFC byproducts are covered, then it certainly makes it less complicated, but not problemfree.

As I mentioned before, daily tracking of the main HFC product from each plant would be difficult because it requires information that is often not available on a real time basis (truck and railcar weights) and changes in tank levels (which are not particularly accurate values). A longer tracking period (about one month or quarterly) would be more meaningful, since we could wait until all the truck and railcar weights are in and changes in tank levels become a smaller percentage of the total value the longer the time period that is used. Daily tracking of small byproducts is just about impossible because t hese are usually very small numbers so small changes in inventory in process equipment, which are impossible to measure, can significantly affect the calculated number. Also, recycles in the process make if difficult to determine exactly how much of a particular component is made in the reactor. Generally, we can get reasonably good estimations of most of the main byproducts, but assumptions have to be made about recycles and fugitive losses. In general to operate the unit we can look at ratio of components rather than absolute rates to determine if a particular byproduct is within normal range, high, or low at any particular time. But normally a single analysis is not necessarily indicative of a trend so we will use several analyses over several days before trying to make adjustments if

necessary.

In my opinion, tracking the main HFC product by material balance over a reasonable time period is feasible. Our overall yield is relatively easy to track because it is a simple issue of material balance: how much HFC leaves the plant vs. how much raw material came into the plant.

However, separating that yield loss into the various ways of losing product is a lot more complicated because it involves a lot of small numbers. Yield losses consist of: byproducts of reaction that are either destroyed or vented (through permitted vents); product that is not separated from these byproducts, and therefore is also lost when the byproduct is destroyed or vented; fugitive losses, which consist of product and byproducts, depending where the fugitive loss occurs; losses from clearing equipment for maintenance or emergencies (e.g.: pressure relief).

The flow of streams sent to destruction or permitted vents can be measured and analyzed. But there are so many components in these streams that it is often difficult to obtain a good analysis of the composition on a routine basis. The analysis is simpler if we only have to track the HFC's, but again, where there are many co mponents the analysis would still only be an estimation (there are often interference between components, unknowns for which responsefactors cannot be determined, etc.). However, it is nearly impossible to accurately determine the fugitive and losses for maintenance and emergencies. The amount of these might be estimated by material balance (feed in minus product out minus measured losses) over a reasonably long period (monthly or quarterly). But it is impossible to accurately determine how much of these losses are HFC's or other byproducts of the reaction (HCFC's and CFC's). Even the subtraction of raw material in minus produc t and measured streams to destruction or vents to determine the fugitive loss rate can only be an estimation since it requires knowing the composition of the known vents and as I ment ioned above, that composition will include an

error.

Essentially, the issue is that we are trying to measure small differences in large numbers. The smaller the difference the more it approaches the error band of the large number. For example, if we can measure the raw material and product material balance at +/- 1% accuracy (for example only) and approximately 5% of the raw ma terial is known to go to byproducts, then the error in flow measurements can be as much as 20% of the byproducts. If we then add errors in analytical measurements and the fact that what we want to know is the portion of the HFC's that went to atmosphere (potentially an even smaller number), then the error in the original flow measurement can be an even greater % of the number we need to report (emissions to atmosphere). In addition, the 0.2% accuracy for the flow measurements may be very difficult to implement. The mass flow meters advertise this a ccuracy, but I believe that it applies to liquid measurement within the normal range. I think it may be lower for gases (all our vents to destruction are gases) and for both liquids and gases the accuracy reduces significantly if the flow is in the low range of the meter. These v ent flows can vary significantly because they are very small flows out of a large plant, so an oversized flow meter may have to be used to prevent from going out of range when the flow is high.

Regarding whether Honeywell would be interested in the material balance approach, I cannot speak for the many operating plants but in my opinion a combination of material balance to determine the amount of total emissions (tons per month, quarter, or other period) combined with standard factors (based on historical measurements and engineering judgment) to account for composition and other difficult to measure variations may be workable. I hope this information is helpful.

I am trying to identify a contact for the SF6 plant and will let you know when I can.-----Original Message----- From: Ottinger.Deborah@epamail.epa.gov Sent: Tuesday, November 10, 2009 5:11 PM To: Cerri, Gus Subject: Proposed Rule and Recap of Questions

Gus,

Thanks once again for answering my questions. FYI, here is a link to the overall website for the proposed mandatory reporting rule:

http://www.epa.gov/climatechange/emissions/archived/ghgrulemaking.html

You can find the preamble here:

http://www.epa.gov/climatechange/emissions /archived/downloads/Preamble_E9-5711.pdf

The proposed regulatory text is here:

http://www.epa.gov/climatechange/emissions/archived/downloads/RULE_E9-5711.pdf

The text relevant to emissions from fluor inated gas production (Subpart L) begins on page 16503 of the preamble and on page 16655 of the regulatory text.

As I mentioned during our phone call, we received quite a few comments objecting to performing the mass-balance calculation daily. Some commenters also objected to the proposed accuracy and precision requirements. We are taking this comments into

consideration as we move forward.

To recap my questions: we were wondering whether (1) Honeywell might be interested in using the mass-balance approach (which will be revised taking into account the comments we have received) and whether (2) Honeywell's process for producing SF6 posed any special emission estimation issues (i.e., issues different from those raised for processes making HFCs). My understanding from our conversation was t hat you thought Honeywell would probably be interested in using the mass-balance approach for at least some of its processes, and that you would send me contact information for one of your colleagues who is familiar with Honeywell's processes for making SF6.

Thanks again for your help!

Best Regards,

Debbie

Deborah Ottinger Schaefer Inventory Analyst for High-GWP Emissions Climate Change Division U.S. Environmental Protection Agency

e-mail: ottinger.deborah@epa.gov phone: 202-343-9149