Promulgation: Mandatory Reporting of Greenhouse Gas Emissions 

Meeting Documentation for Telephone Call on June 4, 2010 with DuPont Representatives Regar

Gas Production Re-Proposal Rule

Dates: June 4, 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

Neulicht, RTI, rmneulicht@rti.org Name of Organization (Attach list of all attendees names and emails if possible) John Dege, Brad Martin, Suhas Mahuli, Keith Willkins, John Wehner, Mike McCord, Gwen Lawless, Ed Robertson, Bruce Sean Messinger, Paul Jann, Greg Shankowitz, Jeremy Blanks, Bob Reich, DuPont 

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. DuPont representatives noted the following: 

• A GWP methodology should be added to the rule. Facilities that have low GWP components should not need to m

regarding 1 mt F GHG threshold for calculations versus emissions testing for compounds with no GWP. 

• Some participants suggested a revision to allow BAMM short term and 2nd or 3rd year use GWP method, both a G

• Noted concerns regarding applicability to fluoropolymers where F GHG compounds are fairly heavy and have low 

however the F GHG definition is low at 1 mm Hg vapor pressure. If EPA regulates F GHG from nonGHG producproducts and compounds into the rule applicability. DuPont has dozens of products impacted by the inclusion of flu

CFC/HCFCs) and requested a modification be made to rule applicability. Some F GHG compounds will be at imp

below the 1 mt GF GHG thresholds, so that calculations would typically be used for these, however even engineerisignificant effort for these and means large additional cost. If an impurity is a F GHG, it is not “produced” and it iproduct.” EPA noted that subpart L is meant to cover even unintended F GHG that are created and emitted to atmo

• Noted that CFC and HCFC processes do not emit F GHG. The facility has an in-line GC on the process to look for 

have never detected any of these (in place for process control and to avoid problems with downstream contaminatio

grab 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 

this 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 

Suggested that subpart L state that emissions “before the flowmeter” are covered and that would be clearer invento

manufacturing and supply. Noted that for subpart O is key word is “produce” and for subpart L the key word is “e

another layer of downstream where product is sent to another facility for repackaging, and chasing after these emisand has too much possibility of double or triple counting. EPA noted that subpart L would focus only on the emis

the production facility and not focus on other facilities where products are sent, which may have emissions less thathreshold. 

• The initial scoping study requires sophisticated sampling and analysis. DuPont is good at measurements for produ

process vents not necessarily even have sampling ports or capabilities due to hazardous nature of these streams. Pequipment must be worn. For the initial scoping study, it needs to be clear in the rule that facilities can use calculawhether a process is above or below the threshold, as is stated in the preamble (but not in rule text). 

• Other testing and analytical methods should be included in the rule; it is too prescriptive. Asked for flexibility. Sta

not appropriate for process fluids. Noted concerns about the validation protocol M301 and use of this protocol wousimultaneous running of a method along with EPA M18. EPA noted that a method can be validated against itself t

• For determining whether a process vent is above or below the 1 mt F GHG threshold, for a process vent with a proc

the 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 

Participants noted that the engineering flow sheets would provide better average of the stream flow rate and compomonthly measurement. 

• Noted that certified calibration standards do not exist for all F GHG compounds. The hierarchy of calibration wou

calibration standard, (2) in-house standard where purity is known and can be corrected for, and (3) a chemically sim

last, the facility would develop a response factor. Noted that calibration should be set once and that over calibratio

appropriate frequency of calibration depends on the instrument and measurement. Concentrations in streams can b

analyzing the relative size of peaks, at least in fully characterized streams. The facility would use a normalized are

Facilities should be allowed to describe the calibration in the GHG Monitoring Plan. 

• Their experience with equipment leak emissions is that emissions are low, less than 1,000 lb of emissions, and typi

less than 0.5 percent. Suggested that skip-year options are best, where monitoring is not required every year. If m
must be done, then limited effort should be required. For example, in general rotating equipment (pumps, valves) 

emissions and these should be monitored but not other equipment. Noted that connectors and flanges should be mo

since have little emissions. Noted that typical monitors (FID or PID) for M21 do not detect most F GHG. An IR thowever these have issues too. Response factors for F GHG would be in range of 15 to 20. Rule requirements for GHG is premature, as this is an area that is just starting research. For non-VOC F GHG, facilities should be alloweAverage Emission Factors. EPA noted that a conservative estimate of EL is not necessarily the best approach wheneeded. Noted that monitoring of equipment leaks for F GHG would be best as a one time exercise to determine thLeaks could be counted with soap bubbles (out of M21) and then measuring with M21 a sublot of equipment piece

emissions. It would be best if EPA allowed flexibility in EL emission measurement approaches and facilities could approach in the site GHG Monitoring Plan. Noted that most VOC and HAP rules have an in service definition whe

only 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 esti

expectations however the error was larger than expected. Because the emissions are lower, the relative error can babsolute error of 5,000 or 10,000 mt CO2e would be better to not burden small emitting processes. Transformation able to used the mass balance approach. EPA noted that the MB equations assume that emissions are F GHG prod

transformation processes would require partitioning emissions to determine how much is F GHG byproduct, how mfluorine product, or reactant, etc. 

• The requirement for an initial scoping test and for the error calculation related to mass balance require too much ef

and these are not seen in other MRR GHG rules. 

• Noted concern with CBI issues related to routine reporting and the level of detail EPA asks for. In the past, compa

their CBI information gets released. Reporting of process chemistry equations, ratio of reactants, mass balance num

profiles, others can back calculate and identify process information. These details can be critical to ending up with Facilities want to keep information onsite so that EPA can validate the numbers. Under other regulatory programs reporting detail. 

• Asked about BAMM provisions. EPA noted BAMM is used for first quarter, and there is a petitioning process too

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