Document npnzjEwXB1dDkXGervv4ZYvrG

Comments Kaneka North America LLC's Supplemental Environmental Project (SEP) Advanced Emissions Monitoring Project Item #1 Completion Timeline Cost Details Comments Portable Emission Monitors 7 months $60,000 Phase One -Install portable VOC emissions monitors that are battery operated, for site wide perimeter monitoring. The data and trends will be contained in localized stations and indication of an emission detection will notify operations. While the site evaluation is being performed the portable monitors will be in place to assist with interim monitoring. Once the site evaluation has been completed with defined monitoring location, the portable monitors will continue to be used by the site as another layer of monitoring - Item #2 Completion Timeline Estimated Cost & Value Details Fixed IR Perimeter Monitors 18 months $240,000 Phase Two -Installation of fixed perimeter monitors for the RMP covered areas at a minimum. The installation of these monitors will require infrastructure work to occur, thus requiring capital resources for the hard wiring and logic to alarm back to the unit DCS systems. There are several steps that must occur for this to be fully implemented (site evaluation, installation of (hard wire) infrastructure, data digitalization and instrumentation). Item #3 Completion Timeline Estimated Cost and Value Details Comments Total Thermal Imaging Camera 4 months $86,000 Kaneka will also be purchasing a Thermal Imaging Camera with VOC quantification capabilities to assist with leak detection identification as well as mitigating accidental releases. $386,000 Compliance with EPA SEP Policy: The Advanced Emissions Monitoring Project is eligible for recognition by US EPA Region 6 as a SEP for the purpose of mitigating the civil penalty in this matter. The following demonstrates how the Advance Emissions Monitor Project satisfies the requirements of the EPA SEP Policy: A. The Advanced Emissions Monitoring Project proposes to install and operate state-of-the-art emissions sensing equipment to monitor conditions in areas of the facility used to store and handle chemicals regulated under 40 CFR Part 68. Early detection and enhanced protection from releases of hazardous air pollutants from regulated sources is clearly "environmentally beneficial" to the residents of Pasadena and the surrounding areas. The Advanced Emissions Monitoring Project SEP will help enable Kaneka to continuously monitor its facility and to detect early and respond quickly if a detectable release occurs. This will enable personnel to know whether hazards are present in the area before entering and will enable the facility to quickly and effectively respond to any leaks or vapors to prevent both onsite and offsite exposures. B. The SEP will be undertaken in connection with the settlement of an EPA enforcement action, Docket No. CAA-06-2023-3308. C. Kaneka is not otherwise required to install and operate this emissions sensing equipment by any federal, state, or local law or regulation, nor pursuant to any agreement or grant, not as injunctive relief awarded in any other action in any forum. D. The installation and operation of the emissions sensing equipment pursuant to this SEP is not a project Kaneka had planned or committed to perform prior to the initiation of the enforcement action by EPA, which will be resolved in the CAFO. E. Kaneka has not received, and is not negotiating to receive, credit for the Advanced Emissions Monitoring Project SEP in any other enforcement action. F. Kaneka will not receive any reimbursement for any portion of the eligible SEP. G. Emissions monitoring and sensing technologies will continue to advance and change, and as they advance and change, Kaneka will be allowed, after implementation of the SEP, to modify its approach to ensure continued optimization and improvements to its emissions monitoring program.