Promulgation: Mandatory Reporting of Greenhouse Gas Emissions 

Meeting Documentation for Telephone Call on May 11, 2010 with Arkema Representatives Reg

Gas Production Re-Proposal Rule. 

Dates: May 11, 2010 Staff Contact Information (Name, email, phone #): Deborah Ottinger, EPA, 202-343-9149, Ottinger.deborah@epa.gov; Karen Schaffner, RTI, ksschaffner@rti.org; Carrie Ric

Name of Organization (Attach list of all attendees names and emails if possible):Rich Raiders, Greg Watson, Arkema 

Summary 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 calcula

emissions 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 for batch or continuous operatio

whether 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), no

emission threshold were included, the emissions would not have to be estimated for small process vents. EPA noted that th

emission threshold; the rule is requiring comprehensive reporting of emissions. Arkema noted that they were unsure of wh

where a process vent that is routed to a control device and can perform the ECF also had periods when it was not vented to potentially 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 piecomponents are behind a blast wall where no operators are allowed due to OSHA, and they use non-monitoring factors rath

example, use of subpart UU (Equipment Leaks) pressure testing the line and calculate leak rates. In general, alternative tec

allowed for equipment that is unsafe-to-monitor or not accessible. Another possible option would be to add General Provissimilar to that in part 60 and 63, petition process for alternative methods/process to subpart L, where surrogates could be us

monitoring instrument may be used (for example, switch to PID or ECD, as long as the response factor is less than 10 for th

surrogate). Issues with use of Method 21 for fluorinated gases was also 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 be adapted to fit needs specific to the facility, or in 

cannot determine the compound of interest. 
Arkema also noted other issues with equipment leak monitoring; 

• There usually is an annual exemption for equipment that is in service less than 300 hour/yr; EPA could allow avera

emissions rather than monitoring equipment in service for short periods, rather than requiring monitoring effort for levels. 

• Completion dates for testing. Arkema was unsure if testing could be finished by December 2011 due to shutdowns 

among other reasons. Arkema needs to develop response factors (RF) for Method 21 but they don’t know which coneed for RFs until after initial scoping test. Arkema stated there are only a few testing contractors with whom they 

working with. 

Arkema asked whether it is necessary to do both initial scoping testing and emission testing and whether one test could be u

should be acceptable if a facility is able to combine those tests. Batch and continuous process vent testing were discussed. Under Pharmaceutical NESHAP, subpart GGG, facilities are re

emission profile across the batch process to identify and select the hours of the batch that are worse case emissions. A simi

used under this rule to use the emission profile to identify emission episodes and the time periods to conduct testing for batcontinuous process vents, facilities do use HWC. If additional compounds are identified under initial scoping test and emisthese compounds will not have known autoignition temperatures (AITs). If the compound is contributing to 99.99 percent 

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 outlet sta concern. If compounds are less than trace concentrations, selection of the most-difficult-to-destroy compound should nocompounds 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 me

fluorinated GHG may not be detectable with Method 18, so another method will have to be used. In addition, there are calFacilities must find known, certified calibration standard gases, and calibration standards are not available for a particular chas 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

production only infrequently for some processes. These points and ports can only be installed during shutdown periods, sin

policies related to no “live taps” installation of ports. Timing for equipment leak monitoring is also a concern; it takes time factors for Method 21, and the facility will not know which compounds will need response factors to be developed until aft

test is complete. Arkema noted that NESHAP rule implementation, for example for HON and MON, the rules allowed 3 ythis rule, there is no control device installation but they are not certain that 1 year is sufficient for the monitoring and report

Arkema noted that there are few testing contractors they would be willing to work with, and scheduling testing is not easy. 
Written Comments Provided? No. 

Did they also submit to Docket? No. 

Date sent to EPA- CCD None