First Name | Kurt |
---|---|
Last Name | Werner |
Email Address | ktwerner@mmm.com |
Affiliation | 3M |
Subject | GHG Reporting / Definition of Fluorinated greenhouse gas |
Comment | 3M recognizes that the definition of fluorinated ghg is consistent with the U.S. EPA definition and that both definitions exempt materials with a vapor pressure of less than 1 mmHg at 25C. Please be aware that the vapor pressure threshold in this definition raised concerns because EPA also defined, "heat transfer fluids" and tied the definition of a heat transfer fluid to the definition of a fluorinated ghg. The concern, simply stated, is that heat transfer fluids are used at elevated temperatures so their vapor pressures at 25C are not indicative of emission potential. EPA has recently proposed amending the definition of a heat transfer fluid to address this concern. EPA's proposal is attached (pg 56022). 3M calls CARB's attention to this issue in the event CARB, in the future, also defines heat transfer fluid. |
Attachment | www.arb.ca.gov/lists/ghg2010/113-epa_ghg_reporting_rule_subpart_i_proposed_rule_to_correct_htfs.pdf |
Original File Name | EPA GHG Reporting Rule Subpart I Proposed Rule to correct HTFs.pdf |
Date and Time Comment Was Submitted | 2011-09-13 10:47:49 |
If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.