Promulgation: Mandatory Reporting of Greenhouse Gas EmissionsMeeting Documentation for TelephoneCall on May 17, 2010 with ACC Representatives Regarding FluorinatedGas Production Re-Proposal RuleDates:May 17, 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; DaveGodwin, EPAName of Organization (Attach list of all attendees names and emails if possible):Lorraine Gershman (ACC), Rich Raiders (Arkema), Joel Hall (Mexichem Fluor), Greg Watson (Arkema), Brian Keck (Air Products), Bob Reich(DuPont), Dana Schnobrich (DuPont),Dave Godwin (EPA), John Dege(DuPont), Brad Martin (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 calculate fluorinated GHGemissions along with other concerns regarding the reporting rule.ACC focused on two topics: emission factors for calculating emissions, and the monitoring and QA/QC requirements. ACC participants notedthe following:•Rule does not allow for site-specific testing protocols and doesnot allow for adjusting methods. For batch testing in particular, themethods will need to be tweaked or adjusted.•Companies are talking to stack testing firms about batch testing. Stack testers prefer use of summa canisters, which are not part of Method18. There is much variety in the chemistry in thisindustry and flexible testing methods are needed.•There are safety issues with testing for this source category.Measuring upstream of the destruction device is problematic since manyfacilities have HF issues. Hazardous materials are typically used behind blast walls. Post-destruction measurement is betteroption.Attendees expressed concern about exposing workers to hazardous materials in streams.•Facilities will require extra time to install test ports requiredin rule since they do not currently exist; to conduct testingby December2011, facilities must shutdown to install ports and prepare for testing. Facilities would not be allowed to do a live tap.•For those process vents not sent to a destruction device, facilities would use engineering calculations.•In general, it is best to have a blending ofapproaches to allow best method to be used.•For batch testing, if a batch lasts for 3 days, they would have totest over 3 days which is too much work for one test run. EPA couldincorporate use of Pharmaceuticals approach to decide on emission episodes.•The scoping study is not necessary and that calculations and other measurements could provide most of the relevant info.•Use of audio, visual, and olfactory (AVO) or sensorymonitoring for equipment leaks should be included.•Noted concerns regarding accuracy and precision requirements for monitoring instruments.•Noted concerns about how decontamination and maintenance activities fit in the rule.•Transformation processes should be allowed to use mass balance approach. (EPA noted that mass balance equations require theassumption that any material not accounted for is product emissions; and for transformation processes, the product is not the FGHG, thereactant is the F GHG. EPA noted that a variation of the mass balance approach could potentially be developed.)•Only certain compounds have certified calibration standards; other compounds will not have. There aren’t certified calibrationstandardsfor EL monitoring for F GHG.•Initial scoping test methods focus on stack test methods, but other data and analysis on the process vessel should be used.•EPA evaluate relative GWP and account for that accordingly.•Requested a 2 week extension on comment submissions. They arelooking at multiple product lines, talking to multiple sets of technicalstaff to determine the issues.Written Comments Provided?No.Did they also submit to Docket?No.Date sent to EPA- CCDNone