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OAR Box 1878 

Prepped by Charmelle Mathews 

Document Number: 

131) ll-E-15 

Docket Number: 

A-90-19 

Printed 11/28/20081:21:26 PM Sheet 131 of 145 
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A-90-19 

ll-E-15 

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

Office of Air Quality Planning and Standards 

Research Triangle Park, North Carolina 27711 

U DEC KM AAUA^'l \A~---"—*'-• 11.1

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'••-. DEC 181992 A \ 

MEMORANDUM 

SUBJECT: 

FROM: 

TO: 

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£PAAiKnccisi;[J 

Meeting with Representatives of the Synthetic Organic 

Chemical Manufacturing Association (SOCMA) 

Robert E. Rosensteel, Chief |£rW"£ fLw/$J* 

Chemical Manufacturing Section, CPB/ESD (MD-13) 

Susan R. Wyatt, Chief 

Chemicals and Petroleum Branch, ESD (MD-13) 

The meeting was held at the Washington, D.C. headquarters of SOCMA on 

November 26, 1990, in order for the Environmental Protection Agency (EPA) to 

provide background information and a status report on the Hazardous Organic 

NESHAP project, obtain comments from SOCMA, and provide contacts between the 

two groups for future information exchange. 

Those present at the meeting were: 

Ralph Johnson 

Gale Hoffnagle 

Micheal Moore 

Robert Campaigne 

Michael Dixon 

Mary J. Legatski 

Susan R. Wyatt 

Robert E. Rosensteel 

Dixie Chemical Company 

TRC Environmental Consultants 

INOLEX Chemical Company 

Upjohn Company 

The Advent Group 

SOCMA 

EPA 

EPA 

The presentation of information was started by EPA using the Background 

Information for the Hazardous Organic NESHAP (HON) briefing paper, a copy of 

which is attached. As the briefing progressed questions and comments were 

raised by the SOCMA representatives. The comments that were raised during the 

discussion are summarized below: 

1. There were several questions raised concerning the scope of the 

rulemaking as it is anticipated by EPA at this time. It was clarified that 

the significant portion of the rule is expected to affect production of (1) 

Synthetic Organic Chemical Manufacturing Industry (SOCMI) chemicals that are 

Hazardous Air Pollutants (HAPS) listed as one of the 189 HAPs in the Clean Air 

Act Amendments (CAAA) or (2) use one or more HAPs as reactants to produce a 

SOCMI chemical. It was also pointed out that some non-SOCMI processes are 

also expected to be included in the rule to control equipment leaks and 

storage emissions; these sources will be limited to those emitting one of the 
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eight organic intent to list pollutants. 

2. The presenter acknowledged that EPA does not expect at this time to 

include control of batch process vents. A SOCMA representative provided 

descriptors for various process types as outlined below: 

a. Continuous process - one which is operated at steady conditions 

regarding flow, concentration, heat content etc. of exhaust streams 

producing one product 

b. Batch process (dedicated) - one which is operated at non-steady 

state conditions regarding flow, concentration, heat content or 

other variables of exhaust streams producing one product or a 

product line differing only in grades having little effect on 

emission characteristics, e.g. a polyvinyl chloride unit producing 

various grades of suspension resins 

c. Batch process (multi-product) - one operated non-steady state as 

b. but also producing diverse product lines that require many 

different sets of operating conditions, i.e. conditions change for 

processing each different product type. Obviously this multiproduct batch process results in the most variations in emission 

characteristics of the three. During this discussion EPA pointed 

out that future Control Technique Guideline documents (CTGs) or 

NESHAPS may require controls of certain batch processes. The Batch 

Processes CTG will most likely be the first of such publications or 

rules available for public review and comment. It was agreed by 

EPA to provide all SOCMA attendees copies of the National Air 

Pollution Control Techniques Advisory Committee (NAPCTAC) mailout 

for the Batch Processes CTG; a mailout that was projected for 

Spring 1991 by EPA. It was also mentioned that work had been 

started in FY 1991 to develop a NESHAP for epichlorohydrin users; 

an industry dominated by batch processes. Future NESHAPs were 

expected by the EPA representatives to address other batch 

processes emitting one or more of the 189 HAPs, but no firm 

projects or schedules could be provided at the time of the meeting. 

3. Several SOCMA representatives mentioned that the public had in some 

instances confused thermal incinerators used for vapor reductions at chemical 

plants with hazardous waste incinerators, and there had been public opposition 

to permits for thermal incinerators at some sites. This suggests need for 

public education regarding the benefits of combustion devices in some cases to 

control organic vapor pollutants. 

4. One company representative stated that the nature of their processes 

required a large number of small tanks, i.e. tanks which are smaller than the 

smallest HON model tank. At one plant site which has a total of 3,000 product 

profiles, i.e. a customer could order any one of the 3,000 products, the plant 

actually produces over 300 different products during the year. For this plant 

there are about 125 storage tanks, the largest of which is an 8,000 gallon 

vessel. 
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5. One representative pointed out that in his judgement biological 

systems may be as efficient or even more efficient than steam stripping. EPA 

pointed out that steam stripping is applied preferentially to wastewater 

streams that have the greatest potential for control by steam stripping as 

determined by Reference Method 25D applied to the waste. It was also pointed 

out by an industry attendee that batch process waste streams may also be nonsteady state relative to flow and concentration similar to the situation for 

batch process vents. 

6. A question was raised concerning how a cutoff might be applied in 

the HON; whether it could be expressed in terms of capacity or actual 

production if a production cutoff were applied. EPA responded that the work 

was too preliminary to be able to answer such a question since the Agency 

review and concurrence process had not begun yet. 

EPA agreed to provide the information described below to SOCMA as a 

follow-up to the meeting. 

1. The EPA contract report which has been used to define SOCMI. 

2. A prioritized list of information needs. 

3. Meet with SOCMA at their request or meet to discuss information as the 

need might arise. 

Attachment 

cc: Linda Chaput (MD-13) 

Les Evans (MD-13) 

K.C. Hustvedt (MD-13) 

Penny Lass iter (MD-13) 

Tom Walton (MD-13) 

Bennett King (Radian) 
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BACKGROUND INFORMATION FOR THE 

HAZARDOUS ORGANIC NESHAP (HON) 

SOCMA - EPA MEETING 

WASHINGTON, D.C. 

NOVEMBER 26, 1990 
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PURPOSE: TO PROVIDE INFORMATION CONCERNING THE SCOPE OF THE HON, 

DESCRIBE THE CONTROL TECHNIQUES THAT WILL BE ANALYZED FOR 

REDUCING EMISSIONS, AND DESCRIBE THE ANALYTICAL APPROACH TO 

ESTIMATE NATIONAL IMPACTS OF CANDIDATE REGULATORY ALTERNATIVES 
P.7 

i, 

v. 

SCOPE OF HON 

THE SYNTHETIC ORGANIC CHEMICAL MANUFACTURING INDUSTRY (SOCMI) 

INCLUDES THE PRODUCTION OF SOME 600+ CHEMICALS 

THE HON SCOPE INCLUDES (1) SOCMI PROCESSES THAT (A) PRODUCE A HAP ON 

THE CAAA LIST OF 189, OR (B) USE (AS REACTANT) ONE OR MORE HAP TO 

PRODUCE A CHEMICAL, and (2) STORAGE AND EQUIPMENT LEAKS FOR 

PRODUCTION OF NEOPRENE, STYRENE-BUTADIENE RESINS, POLYBUTADIENE, . 

PHARMACEUTICALS (PROCESS SOLVENT), PESTICIDES (PROCESS SOLVENT), 

CHLORINE AND MISCELLANEOUS BUTADIENE PRODUCTS 

ABOUT 420 CHEMICALS HAVE BEEN IDENTIFIED THAT FALL WITHIN THE HON 

SCOPE 

TO DATE WE HAVE IDENTIFIED AN AVERAGE OF 1.5 ROUTES TO PRODUCE EACH 

CHEMICAL, EACH ROUTE TO PRODUCE A CHEMICAL IS DEFINED AS A PRODUCT 

PROCESS 

THEREFORE OVER 600 PRODUCT PROCESSES MAY ULTIMATELY BE 

SUBJECT TO THE RULE 

CURRENT SCHEDULE CALLS FOR PROPOSAL IN NOVEMBER 1991 AND PROMULGATION 

IN NOVEMBER 1992 (WITHIN TWO YEARS OF CAAA ENACTMENT) 
P.8 

REGULATIONS HAVE BEEN DEVELOPED FOR 

SOCMI AND RELATED EMISSION SOURCES 

PROCESS VENTS 

AIR OXIDATION PROCESSES (NSPS PROMULGATION) 

DISTILLATION OPERATIONS (NSPS PROMULGATION) 

REACTOR PROCESSES (NSPS PROPOSAL) 

EQUIPMENT LEAKS (NSPS AND BENZENE NESHAP PROMULGATION) 

VOLATILE ORGANIC LIQUID STORAGE (NSPS PROMULGATION) 

BENZENE NESHAP HAS BEEN DEVELOPED FOR EMISSIONS FROM 

WASTEWATER AND TRANSFER OPERATIONS 

THESE RULES AND DATA FROM THEIR ANALYSES WILL BE USED 

TO AID IN IDENTIFYING CONTROL TECHNOLOGIES, AND TO HELP IN 

ESTABLISHING FLOORS FOR EXISTING SOURCES, 
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IT IS ANTICIPATED THAT THE HON WILL 

REGULATE THESE EMISSION SOURCES 

PROCESS VENTS (CONTINUOUS PROCESSES) 

EQUIPMENT LEAKS 

STORAGE VESSELS 

TRANSFER 

WASTEWATER 
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CONTROL TECHNIQUES THAT ARE CANDIDATES FOR MACT: 

PROCESS VENTS 

NON - CHLORINATED ORGANIC VAPOR CONTAINING 

STREAMS - 98% COMBUSTION 

HALOGENATED ORGANIC VAPOR CONTAINING 

STREAMS - 98% COMBUSTION BY INCINERATION PLUS 

SCRUBBING 

EQUIPMENT LEAKS 

RESULTS OF THE REGULATORY NEGOTIATION 
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CONTROL TECHNIQUES THAT ARE CANDIDATES FOR MACT: 

(CONTINUED) 

STORAGE VESSELS 

UNDERGROUND OR HORIZONTAL VESSELS - REFRIGERATED 

CONDENSERS 

NON CHLORINATED - FIXED ROOF TANKS WITH INTERNAL 

FLOATING COVER HAVING ACCEPTABLE SEAL(S) 

CHLORINATED - REFRIGERATED CONDENSER 
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CONTROL TECHNIQUES THAT ARE CANDIDATES FOR MACT: 

(CONTINUED) 

TRANSFER 

NONCHLORINATED - 98% COMBUSTION DEVICE 

CHLORINATED - 98% INCINERATOR + SCRUBBING 

WASTEWATER 

STEAM STRIPPING OF AQUEOUS WASTE STREAM + WATER 

COOLED CONDENSER + REFRIGERATED CONDENSER 
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INDUSTRIAL PROFILE SPECIFICS 

PURPOSES 

• CHARACTERIZE INDUSTRY . . . CHEMICALS PRODUCED, PROCESSES 

USED, MANUFACTURING LOCATIONS, EMISSION SOURCES 

• DEVELOP A STRUCTURE TO USE INDUSTRY CHARACTERISTICS AND 

CALCULATE BASELINE EMISSIONS, EMISSION REDUCTIONS, CONTROL 

COSTS ANO OTHER IMPACTS (FRAMEWORK DATABASE SYSTEM) 

• PROVIDE MECHANISM FOR EVALUATING REGULATORY ALTERNATIVES 
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INDUSTRIAL PROFILE SPECIFICS 

(CONTINUED) 

FEATURES 

• IDENTIFYING UNIQUE WAYS TO PRODUCE EACH CHEMICAL 

(PRODUCT-PROCESSES), HOW MUCH IS PRODUCED, AND WHO 

PRODUCES IT 

• FOR EACH EMISSION SOURCE TYPE, ASSIGN EMISSION AND 

CONTROL/COST MODELS TO EACH PRODUCT-PROCESS 

• MODELS WILL CALCULATE VALUES FOR EACH PROCESS 

UNIT USING PARTICULAR PRODUCT-PROCESS CHARACTERISTICS 

• OUTPUT FILES CONTAINING BASELINE EMISSIONS AND EMISSION 

REDUCTIONS, CONTROL COSTS, AND OTHER IMPACTS FOR EACH 

CONTROL OPTION (CONTROL TECHNOLOGY) AT THE PROCESS UNIT 

LEVEL 

• RESULTS: MAXIMUM FLEXIBILITY IN SELECTING AND EVALUATING 

REGULATORY ALTERNATIVES 

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INDUSTRIAL PROFILE SPECIFICS 

(CONTINUED) 

STEPS IN CHARACTERIZING INDUSTRY 

• REVIEW OF READILY AVAILABLE LITERATURE 

• ANALYSIS OF LITERATURE TO DETERMINE . . . 

NATIONAL CAPACITY AND PRODUCTION 

MARKET PRICE 

INDIVIDUAL PRODUCERS AND CAPACITIES 

UNIQUE COMMERCIAL PRODUCTION PROCESSES 

(PRODUCT-PROCESSES) 

FOR EACH PRODUCT-PROCESS 

RELATION OF REACTANTS AND PRODUCTS TO 

KNOWN PRODUCT CAPACITY (KG/KG PRODUCT) 

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» 

INDUSTRIAL PROFILE SPECIFICS 

(CONTINUED) 

FRAMEWORK DATABASE SYSTEM 

• INPUTS . . . 

INDUSTRY CHARACTERISTICS 

BASELINE CONTROL LEVEL-STATE REGULATIONS, NESHAP 

EMISSION MODELS-ALGORITHM TO CALCULATE BASELINE EMISSIONS 

CONTROL MODELS-ALGORITHM TO CALCULATE EMISSIONS REDUCTIONS 

AND COSTS FOR A SPECIFIC CONTROL OPTION (CONTROL TECHNOLOGY) 

(MODELS DEVELOPED BY FIVE HON REGULATORY PROJECTS) 

• OUTPUTS ... 

BASELINE EMISSIONS 

EMISSION REDUCTIONS (FOR EACH CONTROL OPTION) 

CONTROL COSTS (FOR EACH CONTROL OPTION) 

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INDUSTRIAL PROFILE SPECIFICS 

(CONTINUED) 

METHODOLOGY 

INDUSTRY CHARACTERISTICS IN DATABASE ON PRODUCT-PROCESS 

BASIS 

LARGELY AUTOMATED PROCESS FOR ASSIGNING EMISSION AND 

CONTROL MODELS TO PRODUCT-PROCESSES 

COMPLETELY AUTOMATED PROCESS FOR CALCULATING BASELINE 

EMISSIONS, EMISSION REDUCTIONS, AND CONTROL COSTS ONCE 

MODELS ARE ASSIGNED TO PRODUCT-PROCESSES 

WE WILL PROJECT NATIONAL IMPACTS BASED ON THE PRODUCTPROCESSES COMPLETELY DEFINED 

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THE ROLE OF ECONOMIC ANALYSES 

ECONOMIC ANALYSES INVESTIGATE THE BEHAVIORAL RESPONSE TO REGULATIONS 

• CHANGES IN PRICE, PRODUCTION, EMPLOYMENT, MARKET STRUCTURE 

• DISTRIBUTION OF THE COST OF CONTROL 

THE RESULTS OF THE ANALYSES ARE CONSIDERED IN DETERMINING THE FORM 

AND STRINGENCY OF THE STANDARD 

• BOTH PRIVATE AND SOCIAL COSTS ARE CONSIDERED 

• ARE THE SOURCES TO BE REGULATED SIMILAR TO THOSE FOR WHOM THE 

CONTROL HAS BEEN DEMONSTRATED? 

THE RESULTS ARE USED TO DETERMINE IF OTHER ANALYSES ARE NEEDED 

• REGULATORY FLEXIBILITY ANALYSIS (SMALL BUSINESS CONCERNS) 

• REGULATORY IMPACT ANALYSES (MAJOR REGULATIONS) 

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CHALLENGES FOR HON ECONOMIC ANALYSES 

BREADTH 

THE HON WILL COVER MANY PRODUCT-PROCESSES 

OUR NORMAL ANALYSIS THAT COVERS AT LEAST EACH DIRECTLY 

REGULATED PRODUCT CAN NOT BE DONE 

INTERDEPENDENCE 

THE CONCEPT OF CHEMICAL TREES IMPLIES COMPLEX INTERACTIONS 

AMONG REGULATED PRODUCTS 

CUMULATIVE REGULATORY COSTS ARE BOTH IMPORTANT AND DIFFICULT 

TO ESTIMATE 

TIME 

PRELIMINARY COSTS WILL NOT BE AVAILABLE UNTIL LATE DECEMBER 

THE PRELIMINARY ECONOMIC ANALYSIS IS NEEDED BY LATE FEBRUARY 

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APPROACH FOR HON ECONOMIC ANALYSES 

CUMULATIVE COST 

• USE OF CHEMICAL TREES 

• BOTH AVERAGE AND HIGHER COST ESTIMATES 

SUBSET SELECTION FOR DETAILED ANALYSIS 

• CUMULATIVE COSTS WILL BE USED TO SELECT SOME PRODUCTS 

OF BOTH AVERAGE AND HIGHER CONTROL COSTS 

• WILL ALSO INCLUDE THE PRODUCTS FOR WHICH PRELIMINARY 

ANALYSIS WAS INITIATED UNDER THE OLD EFFORT 

SUBSET ANALYSIS 

• MARKET ANALYSIS PERFORMED FOR EACH PRODUCT CHOSEN ABOVE 

• THE RESULTS FOR THE WHOLE SET WILL BE USED TO ADDRESS 

POTENTIAL IMPACT FOR PRODUCTS NOT SELECTED FOR DETAILED 

ANALYSIS 

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