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{longname}  Q387. Are processes with scrubbers that decompose F-GHGs required to submit the one-time report required by §98.126i, even though they have no combustion control device and do not technically emit "PICs" from the scrubber vent ?

{longname}

A387.

...

Fluorinated

...

gas

...

production

...

facilities

...

that

...

destroy

...

fluorinated

...

gases

...

must

...

submit

...

the

...

one-time

...

report

...

required

...

under

...

§98.126

...

(i)

...

even

...

if

...

they

...

use

...

destruction

...

technologies

...

other

...

than

...

thermal

...

oxidation,

...

such

...

as

...

caustic

...

scrubbers.

...

§98.126

...

(i)

...

reads

...

as

...

follows:

...

Each

...

fluorinated

...

gas

...

production

...

facility

...

that

...

destroys

...

fluorinated

...

gases

...

must

...

submit

...

a

...

one-time

...

report

...

by

...

June

...

30,

...

2011,

...

that

...

describes

...

any

...

measurements,

...

research,

...

or

...

analysis

...

that

...

it

...

has

...

performed

...

or

...

obtained

...

that

...

relate

...

to

...

the

...

formation

...

of

...

products

...

of

...

incomplete

...

combustion

...

that

...

are

...

fluorinated

...

GHGs

...

during

...

the

...

destruction

...

of

...

fluorinated

...

gases.

...

The

...

report

...

must

...

include

...

the

...

methods

...

and

...

results

...

of

...

any

...

measurement

...

or

...

modeling

...

studies,

...

including

...

the

...

products

...

of

...

incomplete

...

combustion

...

for

...

which

...

the

...

exhaust

...

stream

...

was

...

analyzed,

...

as

...

well

...

as

...

copies

...

of

...

relevant

...

scientific

...

papers,

...

if

...

available,

...

or

...

citations

...

of

...

the

...

papers,

...

if

...

they

...

are

...

not.

...

No

...

new

...

testing

...

is

...

required

...

to

...

fulfill

...

this

...

requirement.

...

If

...

the

...

facility

...

hasn't

...

"performed

...

or

...

obtained"

...

"measurements,

...

research,

...

or

...

analysis

...

that

...

relate

...

to

...

the

...

formation

...

of

...

PICs

...

that

...

are

...

F-GHGs"

...

(e.g.,

...

because

...

its

...

only

...

destruction

...

devices

...

are

...

caustic

...

scrubbers)

...

then

...

the

...

facility

...

can

...

simply

...

note

...

this

...

in

...

its

...

report.

...

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Source: This question and answer was derived from a Legacy FAQ

Approval / Publishing History: Version 1

Expiration : none

Relevant Subparts: Subpart L
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