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 ?
A387. §98.126(i) reads as follows: 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.
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.