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EPA-Mandated PCB Removal Could Cost Billions
The EPA issued a proposed rule last April, which made improvements on an earlier version. The final rule, which was scheduled to appear in the Federal Register sometime in late November 2010, goes even further than the July proposal to meet improvements requested by INGAA, who had submitted a detailed, laundry list of changes it wanted made to the April proposed rule. Whether it goes far enough is not clear. INGAA officials were unable to comment. Among INGAA's biggest concerns has been measurement of GHG emissions from reciprocating compressor rod packing vents. The EPA had been pressing for annual “three-mode” testing (i.e., measurements during each operational mode that occurs during a reporting period): operating; standby pressurized; and not operating, depressurized.
In the final rule, the EPA backed off that position and clarified that companies can conduct an annual measurement of each compressor in the mode as it exists at the time the annual measurement is taken. But each compressor must be measured at least once during every three-year period in the “not operating and depressurized” mode without blind flanges in place. Blind flanges are flat plates inserted between flanges on a valve or piping connection to assure absolute isolation of the equipment from process fluids and hence, compromise through valve leakage measurement. Isolation valve leakage through the compressor blow down vent, when the compressor is in the not operating and depressurized mode, must be measured before blind flanges are installed.
Besides reciprocating compressor rod packing vents, transmission pipelines will be required to measure emissions from pneumatic device venting, blow down vent stacks, storage tanks, centrifugal compressor venting and other emissions from equipment. The rule applies to that emit GHGs greater than or equal to 25,000 metric tons of CO2 equivalent per year. The rule requires annual reporting of GHGs including carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulfur hexafluoride (SF6) and other fluorinated compounds (e.g., hydrofluoroethers (HFEs).