Promulgation: Mandatory Reporting of Greenhouse Gas Emissions 

Meeting Documentation for Telephone Call on May 17, 2010 with ACC Representatives Regard

Gas Production Re-Proposal Rule

Dates: May 17, 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

Godwin, EPA Name of Organization (Attach list of all attendees names and emails if possible):Lorraine Gershman (ACC), Rich Raiders (Arkema), Joel Hall (Mexichem Fluor), Greg Watson (Arkema), Brian Keck (Air (DuPont), Dana Schnobrich (DuPont), Dave Godwin (EPA), John Dege (DuPont), Brad Martin (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. ACC focused on two topics: emission factors for calculating emissions, and the monitoring and QA/QC requirements. ACthe following: 

• Rule does not allow for site-specific testing protocols and does not allow for adjusting methods. For batch testing 

methods will need to be tweaked or adjusted. 

• Companies are talking to stack testing firms about batch testing. Stack testers prefer use of summa canisters, whic

18. There is much variety in the chemistry in this industry and flexible testing methods are needed. 

• There are safety issues with testing for this source category. Measuring upstream of the destruction device is probl

facilities have HF issues. Hazardous materials are typically used behind blast walls. Post-destruction measuremenAttendees expressed concern about exposing workers to hazardous materials in streams. 

• Facilities will require extra time to install test ports required in rule since they do not currently exist; to conduct tes

2011, facilities must shutdown to install ports and prepare for testing. Facilities would not be allowed to do a live t

• For those process vents not sent to a destruction device, facilities would use engineering calculations. • In general, it is best to have a blending of approaches to allow best method to be used. 

• For batch testing, if a batch lasts for 3 days, they would have to test over 3 days which is too much work for one te

incorporate use of Pharmaceuticals approach to decide on emission episodes. 

• The scoping study is not necessary and that calculations and other measurements could provide most of the relevan

• Use of audio, visual, and olfactory (AVO) or sensory monitoring for equipment leaks should be included. • Noted concerns regarding accuracy and precision requirements for monitoring instruments. 
• Noted concerns about how decontamination and maintenance activities fit in the rule. 

• Transformation processes should be allowed to use mass balance approach. (EPA noted that mass balance equatio

assumption that any material not accounted for is product emissions; and for transformation processes, the product 

reactant is the F GHG. EPA noted that a variation of the mass balance approach could potentially be developed.) 

• Only certain compounds have certified calibration standards; other compounds will not have. There aren’t certified 

for EL monitoring for F GHG. 

• Initial scoping test methods focus on stack test methods, but other data and analysis on the process vessel should be 

• EPA evaluate relative GWP and account for that accordingly. • Requested a 2 week extension on comment submissions. They are looking at multiple product lines, talking to mu

staff to determine the issues. 

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