Promulgation: Mandatory Reporting of Greenhouse Gas EmissionsMeeting Documentation for Telephone Call on June 4, 2010with DuPont Representatives Regarding FluorinatedGas Production Re-Proposal RuleDates:June 4, 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; RoyNeulicht, RTI, rmneulicht@rti.orgName of Organization (Attach list of all attendees names and emails if possible)John Dege, Brad Martin, Suhas Mahuli, KeithWillkins, John Wehner, Mike McCord, Gwen Lawless, Ed Robertson, Bruce Davis, Mike McCord,Sean Messinger, Paul Jann, Greg Shankowitz, Jeremy Blanks, Bob Reich, 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 concernsregarding the reporting rule.DuPont representatives noted the following:•A GWP methodology should be added to the rule. Facilities that have low GWP components should not need to monitor. Have concernsregarding 1 mt F GHG threshold for calculations versus emissions testing for compounds with no GWP.•Some participants suggested a revision to allow BAMM short termand 2nd or 3rd year use GWP method, both a GWP & ton limit,•Noted concerns regarding applicability to fluoropolymers whereF GHG compounds are fairly heavy and have low vapor pressure,however the F GHG definition is low at 1 mm Hg vapor pressure.If EPA regulates F GHG from nonGHG products, this pulls manyproducts and compounds into the rule applicability. DuPont has dozens of products impacted by the inclusion of fluoropolymers (andCFC/HCFCs) and requested a modification be made to rule applicability. Some F GHG compounds will be at impurity levels and bebelow the 1 mt GF GHG thresholds, so that calculations would typically be used for these, however even engineering calculationsaresignificant effort for these and means large additional cost. Ifan impurity is a F GHG, it is not “produced” and it is not “sold as aproduct.” EPA noted that subpart L is meant to cover evenunintended F GHG that are created and emitted to atmosphere.•Noted that CFC and HCFC processes do not emit F GHG. The facility has an in-line GC on the process to look for HFC compounds buthave never detected any of these (in place for process control andto avoid problems with downstream contamination). Also conductgrab samples a few times a month and analyze in laboratory.•Discussed the application of the 25,000 mtCO2e threshold, regarding whether this was per polymer process or per facility and suggestedthis be clarified. EPA noted that the threshold was for the whole facility.•Expressed concern that downstream production measurements should not be included and are double-counting with subpart OO.Suggested that subpart L state that emissions “before the flowmeter” are covered and that would be clearer inventory to break betweenmanufacturing and supply. Noted that for subpart O is key wordis “produce” and for subpart L thekey word is “emit.” There is oftenanother layer of downstream where product is sent to another facility for repackaging, and chasing after these emissions is complicatedand has too much possibility of double or triple counting. EPAnoted that subpart L would focus only on the emissions that occurred atthe production facility and not focus on other facilities where products are sent, which may have emissions less than the 25, 000 mtCO2threshold.•The initial scoping study requires sophisticated sampling and analysis. DuPont is good at measurements for product quality butforprocess vents not necessarily even have sampling ports or capabilities due to hazardous nature of these streams. Personal protectiveequipment must be worn. For the initial scoping study, it needsto be clear in the rule that facilities can use calculations to determinewhether a process is above or below the threshold, as isstated in the preamble (but not in rule text).•Other testing and analytical methods should be included in therule; it is too prescriptive. Asked for flexibility. Stack testing methods arenot appropriate for process fluids. Noted concerns about the validation protocol M301 and use of this protocol would necessitatesimultaneous running of a method along with EPA M18. EPA noted that a method can be validated against itself too.•For determining whether a process vent is above or below the 1mt F GHG threshold, for a process vent with a process condenser,wouldthe measurement or emissions level be determined prior to or after the condenser?•For mass balance, a single monthly flow measurement would be made, which essentially equates to a grab sample or spot check.Participants noted that the engineering flow sheets would providebetter average of the stream flow rate and composition than asinglemonthly measurement.•Noted that certified calibration standards do not exist for allF GHG compounds. The hierarchy of calibration would be (1) certifiedcalibration standard, (2) in-house standard where purity is known and can be corrected for, and (3) a chemically similar surrogate. For thelast, the facility would develop a response factor. Noted thatcalibration should be set once and that over calibration is problematic. Theappropriate frequency of calibrationdepends on the instrument and measurement. Concentrations in streams can be determined byanalyzing the relative size of peaks, at least in fully characterized streams. The facility would use a normalized area percent to do this.Facilities should be allowed to describethe calibration in the GHG Monitoring Plan.•Their experience with equipment leak emissions is that emissionsare low, less than 1,000 lb of emissions, and typically have leak ratesless than 0.5 percent. Suggested that skip-year options are best, where monitoring is not required every year. If monitoringwith M21must be done, then limited effort should be required. For example, in general rotating equipment(pumps, valves) have the biggeremissions and these should be monitored but not other equipment.Noted that connectors and flanges should be monitored every 5yearssince have little emissions. Noted that typicalmonitors (FID or PID) for M21 do not detect most F GHG. An IR technique couldbe usedhowever these have issues too. Response factors for F GHG would bein range of 15 to 20. Rule requirements for EL monitoringof FGHG is premature, as this is an area that is just starting research. For non-VOC F GHG, facilities should be allowed to use the SOCMIAverage Emission Factors. EPA noted that a conservative estimate of EL is not necessarily the best approach where actual emissions areneeded. Noted that monitoring of equipment leaks for F GHG would be best as a one time exercise to determine the amount of emissions.Leaks could be counted with soap bubbles(out of M21) and then measuring with M21 a sublot of equipment pieces to determineemissions. It would be best if EPA allowed flexibility in EL emission measurement approaches and facilities could document theapproach in the site GHG Monitoring Plan.Noted that most VOC and HAP rules havean in service definition where a piece is monitoredonly if 5 percent or greater and this should be added to the rule.•Tried to conduct the mass balance error calculation using the statistical equations for a process. The emissions estimated were in line withexpectations however the error was larger than expected. Because the emissions are lower, the relative error can be large. Suggested anabsolute error of 5,000 or 10,000 mtCO2e would be better to not burden small emitting processes. Transformation processes should beable to used the mass balance approach.EPA noted that the MB equations assume that emissions are F GHG product, and application totransformation processes would require partitioning emissions todetermine how much is F GHG byproduct, how much is non-GHGfluorine product, or reactant, etc.•The requirement for an initial scoping test and for the error calculation related to mass balancerequire too much effort for a reporting rule,and these are not seen in other MRR GHG rules.•Noted concern with CBI issues related to routine reporting and thelevel of detail EPA asks for. In the past, companies have found thattheir CBI information gets released. Reporting of process chemistry equations, ratio of reactants, mass balance numbers, impurityprofiles, others can back calculate and identify process information. These details canbe critical to ending up with the final product.Facilities want to keep information onsite so that EPA can validate the numbers. Under other regulatory programs have not hadthisreporting detail.•Asked about BAMM provisions. EPA noted BAMM is usedfor first quarter, and there is a petitioning process too.Written Comments Provided?No.Did they also submit to Docket?No.Date sent to EPA- CCDNone