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OAR Box 1669 

Prepped by Charmelle Mathews 

Document Number: 

ft 80) ll-E-21 

Docket Number: 

A-98-13 

Printed 9/23/2008 9:36:49 AM Sheet 89 of 110 
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/\-<.e-/3 

These are outgoing notes to OMB 

Martha Smith 

07/18/2001 02:48 PM 

To:balIen@omb.eop.gov 

cc: 

Subject:OLD electronic preamble and rule 

Here you go! See attached file. OLDPreambleAndRule-JuIv-1-

_-__-

OCT - H200I 

EPA AIR DOCKET 

•V 

Martha Smith 

07/23/2001 02:25 PM 

To:ballen@omb.eop.gov 

cc: 

Subject:Organic Liquid Distribution questions 

Response to OMB on Questions on the NESHAP: OLD 

I would like to see some data supporting the 

decision to include all types of crude oil other than black oil under this NESHAP. Particularly, I 

would like to see the data that justifies classifying OLD facilities that handle only crude, or only 

some types of crude, as "major sources". 

ESD does not designate facilities as "major 

sources" or "area sources". We have identified types of facilities that could be "major" 

and should therefore make their individual determination based on their size, throughput, 

and types of liquids handled (the parameters of applicability). By excluding black oil from 

our liquids of consideration, we have essentially said black oil is not a high emitting liquid 

and the likelihood of facilities that handle exclusively black oil ever emitting enough to 

trigger the 10/25 major source threshold is nil. We reached this conclusion after reviewing 

of other MACT standards which regulated oil, specifically the Oil and Natural Gas 

Production MACT. 

I am attaching a number of files (memos) in 

which we describe what we observed and concluded from our data collection for OLD. In 

these memos, we discuss the percent HAP reported in the crude and the amount of crude 

distributed in the OLD source category (% overall in the source category). 
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On the loading rack issues, I would like to 

see some an estimate of the cost to add another loading rack position and a comparison of this 

cost to the cost to implement the required controls on a position. 

ESD does not maintain costing for new 

equipment, only new air pollution control equipment. However, I'd like to refer you to the 

f preamble, Section III; D. "How did we determine the basis and level of the proposed 

| standards for existing and new sources?, 3. "Selection of the Standards". In there it states: 

} ; • "Some transfer racks at OLD 

j facil'ities are used only on a periodic or intermittent basis and, 

| therefore, have relatively low volume throughputs and low 

| emissions. We do not believe it would be reasonable to install a 

Lcontrol system on such low usage racks. However, the survey data 

did not indicate any specific throughput level below which 

transfer rack emission controls were not being used in OLD 

operations. 

As the survey data could not 

provide direction.on a throughput cutoff, we searched existing 

Federal and State air rules to evaluate the cutoffs in use. The 

provisions of 40 CFR 63.1101, subpart YY (Generic MACT 

Standards), define a low throughput transfer rack as a rack that 

transfers less than 11.8 million liters (3.12 million gallons) 

per year of liquid containing regulated HAP. This cutoff is 

equivalent to about one tank truck full of liquid per day. No 

additional cutoffs affecting individual transfer racks were 

identified. The cutoff used in subpart YY was considered 

reasonable for the OLD transfer rack control requirement, and, 

therefore, we are proposing to regulate only those transfer rack 

positions that load 11.8 million liters per year or more of 

organic liquid. 

A transfer rack may have more 

than one loading position (i.e., "parking spot") for cargo tanks. 

Since each loading position may receive liquid from a specific 

storage tank independently of the other positions, each position 

can be considered an individual emission source during the time 

that a cargo tank is in place and loading liquid. Therefore, we 

are applying both the emission limit and throughput cutoff to 

each individual loading position. Under this approach, owners 

and operators will have maximum flexibility in determining the 

optimum configuration for their loading activities." 

It has occurred to me that your 

discomfort with the loading racks might be concern over small 

facilities. In memo six in the Technical Support Document, page 

6-30, we discuss transfer racks. On page 6-39, further rationale 

on costing is presented. 

2-
&> 

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Martha Smith 

07/30/2001 10:14AM 

To:ballen@omb.eop.gov 

cc: 

Subject:OLD request 

Here are the Technical Support Document and Economic Impact Analysis files. Larry Sorrels is the 

economics person responsible for the EIA and the small business analysis. He has recommended that 

you look at section 5 of the EIA for any questions you may have on small business decisions. 

Tsd2.wpd OLD EIA ApxA Methodolc OLD EIA ApxB Economic Compute OLD EIA ApxC Sens Anal 

OLD EIA sect' 

OLD EIA sec2 find Pro OLD EIA sec3 (Enqineerinq C OLD EIA sec4.< OLD EIA sec5(Small Business Irru 

OLD EIA toc.v oldEIAcover.w 

Martha Smith 

08/02/2001 08:21 AM 

To:ballen@omb.eop.gov 

cc: 

SubjectOLD database 

see attached. Orqliq97.mdl 

3 
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Martha Smith 

Toikevin.bromberg@sba.gov 08/13/2001 11:13 AM cc : 

Subject:RE: *** OLD MACT Rule 

Kevin, The OLD rule covers about 4 types of facilities. They are: chemical (and other various) 

manufacturing, refineries, crude oil pipeline stations, and for-hire terminals. Some of these operations are 

regulated under other rules. For example refineries and chemical manufacturing. However, under those 

other rules "distribution" activities and the equipment associated with distribution (into and out of the 

facility) are not covered by those other rules. The tanks that come under regulation by the OLD rule are 

only in the distribution end of the facility and have not been regulated by other rules because they aren't 

part of the "manufacturing" processes. 

Martha Smith To:Jonathan.Pawlow@sba.gov, Bryon_P._Allen@omb.eop.gov 

OC' 

08/16/2001 08:23 AM SubfectRE: ~ OLD MACT Rule 

Jon and Bryon, When I responded to this email earlier this week, I didn't realize that I'd 

only sent it to Kevin. So, here it is. I am currently trying to find the electronic versions of 

meeting notes, etc. with trade groups. I still haven't heard back from Jon, about 

clarification of his email, so I'm responding as I interpret his comments. By the way, my 

phone number is 919-541-2421. 

-— Forwarded by Martha Smith/RTP/USEPA/US on 08/16/2001 08:08 AM — 

Martha Smith 

To:kevin.bromberg@sba.gov 08/13/2001 11:13 AM --. 

Subject:RE: *** OLD MACT Rule 

Kevin, The OLD rule covers about 4 types of facilities. They are: chemical (and other 

various) manufacturing, refineries, crude oil pipeline stations, and for-hire terminals. 

Some of these operations are regulated under other rules. For example refineries and 

chemical manufacturing. However, under those other rules "distribution" activities and the 

equipment associated with distribution (into and out of the facility) are not covered by 

those other rules. The tanks that come under regulation by the OLD rule are only in the 

distribution end of the facility and have not been regulated by other rules because they 

aren't part of the "manufacturing" processes. 

1 
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Martha Smith 

08/16/2001 10:54 AM 

To:Bryon_P.__A!leni§j6mb.eop.gov, Jonathan.Pawlow@sba.gov, 

kevin.bromberg@sba.gov 

cc: 

SubjectOLD MACT Rule 

MEET 924.W CALL 925.W PHONEAI RTSUMM.WI ICRSUM.WI RT2SUMM.W PHONE2AA NACDTELE.W 

MEETSUMM.W NPCA.WP ILTA.WPC MEETSUMM.W 

Here are some meeting summaries that I believe are responses to your request from last week. Let me 

know if you need anything else; 

Martha Smith 

08/20/2001 10:35 AM 

To:Bryon_P _Allen@omb.eop.gov, Jonathan.Pawlow@sba.gov, 

kevin.bromberg@sba.gov, Ken Hustvedt/RTP/USEPA/US@EPA 

cc: 

Subject:OLD meeting 

Bryon, Where is this meeting to take place? Room number and building would be helpful. 

Martha Smith 

08/22/2001 08:25 AM 

To:Bryon_P._Allen@omb.eop.gov, Jonathan.Pawlow@sba.gov, 

kevin.bromberg@sba.gov, Ken Hustvedt/RTP/USEPA/US@EPA 

cc: 

Subject:8/24/01 OLD Meeting 

Bryon -

It appears that the Travel Authorizations for trips to DC on Friday have been denied. If you would, please 

let any other individuals who were planning on meeting with KC Hustvedt know that he will not be there. 

As far as the OLD meeting goes, we can use the conference line that I set up earlier this week. I have 

attached the briefing materials that we'll use. They are in Power Point. 

_ • 
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"-t--

Martha Smith 

To:Bryon P. Allen@omb.eop.gov 

08/30/2001 10:28 AM cc : ' 

Subject:Re: OLD text edits 

Larry is doing the sensitivity analysis that John asked for, Greg is calling vendors trying to get flare prices. 

If the flare prices are significantly different than what we've used, we need to talk, maybe we'll need to talk 

regardless to decide what is "significant". It will be at least next week, before we have something to bring 

back to you. Probably Thursday or Friday. 

Martha Smith To:Bryon_P._AIlen@omb.eop.gov 

cc 

09/06/2001 03:12 PM SubjectOLD response to OMB comments 

In response to your phone message, I'm still waiting for the sensitivity analysis that John Pawlow wanted 

and the pricing figures from the vendors (3) that we've contacted. I've made the verb tense changes, 

have language requesting comment on costing, and language clarifying applicability. I'll give you a call on 

Monday to hopefully share all of the above. 

Martha Smith To:Bryon_P._Allen@orhb.eop.gov 

CO' 

09/10/2001 03:21 PM SubjecCOLD preamble edits 

see attached. 

Martha Smith 

««._._„-««_.--««__. To:Bryon P. Allen@omb.eop.gov 

09/13/2001 07:29 AM cc 

Subject:Re: Remaining OLD info 

Bryon- We (KC,Larry,Greg, and myself) are meeting this morning to discuss where we stand. Hopefully, 

I'll have good news for after lunch. Martha 

Martha Smith To:Bryon_P _Allen@omb.eop.gov 

09/17/2001 12:43 PM SubjecCOLD preamble and rule 

This is the preamble and rule which we have agreed upon and will be sent to EPA DC for signature. 

k>