Promulgation: Mandatory Reporting of Greenhouse Gas EmissionsMeeting Documentation for TelephoneCall on May 11, 2010 withArkema Representatives Regarding FluorinatedGas Production Re-Proposal Rule.Dates:May 11, 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.Name 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 noted that 98.123(b)(1)(i) and (ii) does not explicitly state whether it may be used forbatch or continuous operationsand wanted to knowwhether these were allowed for continuous processes, too.Arkema questioned the 1 metric ton F GHG threshold and the less than 10,000 mtCO2e threshold in §98.123(b)(2)(i)(A), noting that if a loweremission threshold were included, the emissions would not have tobe estimated for small process vents. EPA noted that there was not loweremission threshold; the rule is requiring comprehensive reporting of emissions. Arkemanoted that they were unsure of what todo during periodswhere a process vent that is routed to a control device and canperform the ECF also had periods when it was not vented to a control device thatpotentially could increase emissions above the 10,000 mtCO2e threshold.Arkema noted several issues with the equipment leak monitoring requirements. Their facilities have unsafe-to-monitor pieces of equipment, eithercomponents are behind a blast wall where no operators are alloweddue to OSHA, and they use non-monitoring factors rather thanMethod 21, forexample, use of subpart UU (Equipment Leaks) pressure testing theline and calculate leak rates. In general, alternative techniques should beallowed for equipment that is unsafe-to-monitor or not accessible.Another possible option wouldbe to add General Provisionspetition processsimilar to that in part 60 and 63, petition process for alternative methods/process to subpart L, where surrogates could be used, or an alternativemonitoring instrument may be used (for example, switch to PIDor ECD, as long as the response factor is less than 10 for the target compound orsurrogate).Issues with use of Method 21 for fluorinated gases wasalso discussed and the Arkema noted the following:•For Method 21 the response factor should be tied to the compound, not the instrument (FID).•Could allow Method 21 “Modifications”, i.e., Method 21 could beadapted to fit needs specific tothe facility, or in the case where an FIDcannot determine the compound of interest.Arkema also noted other issues with equipment leak monitoring;•There usually is an annual exemption for equipment that is inservice less than 300 hour/yr; EPA could allow average EF for estimatingemissions rather than monitoring equipment in service for short periods, rather than requiring monitoring effort for very smallemissionlevels.•Completion dates for testing. Arkema was unsure if testing couldbe finished by December 2011 due to shutdowns for installing portsamong other reasons. Arkema needs to develop response factors (RF) for Method 21 but they don’t know which compounds they willneed for RFs until after initial scoping test. Arkema stated there are only a few testing contractors with whom they fell comfortableworking with.Arkema asked whether it is necessary to do both initial scoping testing and emission testing and whether one test could be usedfor both. Thisshould be acceptable if a facility isable to combine those tests.Batch and continuous process vent testingwere discussed. Under Pharmaceutical NESHAP, subpart GGG, facilities are required todevelop andemission profile across the batch process to identify and selectthe hours of the batch that are worse case emissions. A similar activity could beused under this rule to use the emission profile to identify emission episodes and the time periods to conduct testing for batch processes. Forcontinuous process vents, facilities do use HWC. If additional compounds are identified under initial scoping test and emission testing, many ofthese compounds will not have known autoignition temperatures (AITs). If the compound is contributing to 99.99 percent destruction efficiency,i.e., compound is detected at the inlet but not at the outlet, then not a concern; if a compound is a bigger part of the outletstream, then this could bea concern. If compounds are less than trace concentrations,selection of the most-difficult-to-destroy compound should not be driven bycompounds that are present in less than trace concentrations.Arkema suggested that different test methods than those included in §98.124(c)(4) should be allowed as alternative test methods. Somefluorinated GHG may not be detectable with Method 18, so anothermethod will have to be used. In addition, there are calibration issues.Facilities must find known, certified calibration standard gases,and calibration standards are not available for a particularcompound. The facilityhas not used Method 301 verification testing.Arkema has concerns with completion of testing by December 2011,particularly is they must install bleed points, test ports, since they shutdownproduction only infrequently for some processes. These points andports can only be installed during shutdown periods, since their facility haspolicies related to no “live taps” installation of ports. Timing for equipment leak monitoring is also a concern; it takes time to develop responsefactors for Method 21, and the facility will not know which compounds will need response factors to be developed until after the initial scopingtest is complete. Arkema noted that NESHAP rule implementation, for example for HON and MON, the rules allowed 3 years to implement. Inthis rule, there is no control device installation but they arenot certain that 1 year is sufficient for the monitoring and reporting requirements.Arkema noted that there are few testing contractors they would be willing to work with, andscheduling testing is not easy.Written Comments Provided?No.Did they also submit to Docket?No.Date sent to EPA- CCDNone