Promulgation: Mandatory Reporting of Greenhouse Gas Emissions 

Meeting Documentation for Telephone Call on July 7, 2010 with DuPont Representatives Regard

Gas Production Re-Proposal Rule

Dates: July7, 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

McDonald, EPA. Name of Organization (Attach list of all attendees names and emails if possible):John Dege, Brad Martin, Paul Jann, Gwen Lawless, Keith Wilkins, Bruce Davis, DuPont. 

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. DuPont representatives noted the following: 

• Their Comment No. 15 in the public comment letter should have been 1.5 percent and not 15 percent. As in the pr

denominator is also based on reactants not just emissions. Participants noted that error calculation could be express

reactants. Discussed examples of error calculations in different processes. If yield loss is as high as 1.5 percent, th

inefficient process, is essentially throwing reactant away, and facilities will track the yield loss to ensure it remains an example where the emission rate was 0.6 percent as a fraction of production, while the absolute error was 1.3 peproduction. The absolute error was modest compared to production but high compared to emissions. 

• Their Comment No. 18 in the public comment letter is to keep equipment leak monitoring frequencies on a commo

criteria for equipment leaks need to focus resources on significant F GHG emissions. Typical Method 21 monitori

some F GHG, and use of Method 21 monitoring and calculations for F GHG will require newer technologies. Faci

best approach for their processes and F GHG and document their approach in the site GHG Monitoring Plan; the ru

the technology for F GHG monitoring evolves, and later EPA and industry could work on best practices and guidaninstruments. Focus should be on a cost-effective approach to estimate emissions without overstating equipment lea

calibration differences between an IR and an FID instrument. A Method 21 instrument needs to be a lightweight, psafe instrument. FID and PID have response factors for F GHG well over 10, so will not meet the Method 21 requ

Most IR instruments are close to 25 lb, which is relatively heavy for “portable” equipment. Certified calibration gatraditional Method 21 calibration are not available for F GHG; facilities can develop their own calibration gas stan

document [EPA noted Method 21 allows facilities to prepare calibration gas standards]. DuPont is evaluating the M
to sample some processes, however it has a sampling rate and probe diameter that do not meet M21 requirements. 

at specific band width associated with specific compound; have to adjust the band width to look at other compound

to specific chemicals). These IR instruments are typically 4 times the cost of FID or PID instruments. 

• Other equipment leak details that are necessary include: a process threshold of 100 ton/yr; a 5 percent F GHG con

considered in F GHG service; add a light liquid definition; include difficult to monitor, unsafe to monitor, and in v

exclusions; focus on rotating equipment which account for the majority of leaks; monitoring frequency should be bmonitoring frequency should be common across equipment types to simplify the program (i.e., use entire populatioto develop leak frequency/rate); use sublot sampling, or soap bubble monitoring following by use of Method 21, to 

since this is not an LDAR rule (no repair, estimate emissions only). Noted that use of default average emission fac

leak protocol overestimates emissions because really less than 2 percent of components leak. In their equipment leEmission Factors overestimate emissions by 100 to 1000 times the true emissions. They noted equipment leak emi

of production, and noted that leak monitoring is a waste of time and money. Some monitoring such as with soap buse of the emission leaks average emission factor for identified leaks is a better option. A participant suggested usthen using SOCMI factors for leaks identified. 

• For initial scoping test and other process sampling and measurement for mass balance, allow process sampling. Fa

allowed to sample either the process vent or process streams. Use of upstream process sampling where there are alshould be allowed (e.g., sample bottoms of distillation) along with process knowledge of in-stream process flows. measurement of process streams is allowed.] Facilities have their own methods for conducting process sampling. 

cannot be measured, not every unit has sampling ports, and facilities analyze where it can be done safely, then do cflows in and out, measurements that can be made, etc. As each process is different, facilities will have to best deteneeded to sample each process and the best way to identify the compounds present. Process vents that are hazardo

could be monitored after scrubbers however 100 percent humidity environment and difficult to monitor. 

• Both 124(a) initial scoping testing and 124(c) process vent testing have similar requirements, however the intent of 

explained better in the preamble. 98.124(c)(1) requires universal stack testing for process vents >10,000 mtCO2e, 

streams there are safety issues. For batch processes, the accuracy of testing is questionable. Process vents may be oxidizers or sometimes only a scrubber; the scrubber may be for F GHG in a few cases but mainly for acid gas con

• [EPA asked about work done on PICs.] 

Written Comments Provided? No. Did they also submit to Docket? No. Date sent to EPA- CCD None