Promulgation: Mandatory Reporting of Greenhouse Gas EmissionsMeeting Documentation for Telephone Call on October27, 2010 with Arkema Representatives RegardingFluorinated Gas Production Re-Proposal RuleDates:October 27, 2010Staff Contact Information (Name, email, phone #):Deborah Ottinger, EPA, 202-343-9149,Ottinger.deborah@epa.gov; Karen Schaffner, RTI,ksschaffner@rti.org; Carrie Richardson, RTIName of Organization (Attach list of all attendees names and emails if possible):Rich Raiders, Greg Watson, ArkemaSummary 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.Arkema representatives noted the following:•In general, Arkema considers the fate of the condensate as thedeciding factor in making determinations regarding whether the condenseris a process condenser or a control condenser. Arkema requested that facilities havethe ability in the rule to distinguish between controlcondensers and process condensers. What is considered a process condenser varies between Miscellaneous Organic NESHAP (MON) andPharmaceutical NESHAP. Arkema noted that use the Pharmaceutical equations be allowed for preliminary emission assessments.•Comprehensive Performance Testing (CPT) is conducted every fiveyears under the Hazardous Waste Combustor NESHAP. The facilityprefers to use the same CPT to meet all compliance requirements they have, including for subpart L . Most of their materials fed fromprocesses are relatively easy to destroy, andthey spike with a surrogate that is the most difficult to destroy compound. Thefacility sendscompounds that have both chlorine and fluorine in their molecular structure to be destroyed, and they can select a surrogate orproxycompound that meets all requirements. [EPA noted that surrogates must be on the Thermal Stability Ranking list to confirm where acompound falls with respect to other compounds presentin the process streams and sent to be destroyed.]•The automatic waste feed cutoff (AWFCO) isused when any operating parameter or setting on the hazardous waste combustor (HWC)isout of its operating range. The question typically is whether thewaste in the chamber when the AWFCO occurs is destroyed to the correctDE, and at their facility, the unit’s residence time is < 1 secondand all waste is destroyed to the correct DE. There is no portion that is notdestroyed. When an AWFCO occurs, the facility has the capability to immediately storematerial in tanks for a certain length of time,where it is stored until the HWC is online again. No bypass of process streams or waste occurs at the facility; the facility is not authorizedbypass. The facility also has the capability to route process streams or waste toanother thermal oxidizer onsite. The facility would like totreat this as two different operating scenarios, i.e., one operating scenario for venting to the HWC and another operating scenario forventing to the thermal oxidizer, instead of identifying the AWFCO as uncontrolled emissions. The facility would track production or timeperiods for each operating scenario. [EPA noted that this seems reasonable.]Written Comments Provided?No.Did they also submit to Docket?No.Date sent to EPA- CCDNone