P.1 

OAR Box 1669 

Prepped by Charmelle Mathews 

DocumenVNumber: 

Docket Number: 

A-98-13 

Printed 9/23/2008 9:36:49 AM Sheet 69 of 110 
P.2 

a a 

_P' 

A 98 13 

ll.£-f 

MEMORANDUM 

TO: Steve Shedd 

U. S. Environmental Protection Agency, ESD/WCPG 

FROM: Greg LaFlam and Jay Helms 

Pacific Environmental Services, Inc. (PES) 

DATE: October 30, 1997 

P:\N812 

SUBJECT: Organic Liquids Distribution NESHAP: Summary of Meeting between U.S. 

EPA and CMA 

I. Purpose 

The purpose of this telephone meeting was to introduce the Organic Liquids 

Distribution NESHAP project to the Chemical Manufacturers Association (CMA) and to begin 

to define the scope of this source category. The meeting was also intended to identify 

stakeholders and obtain information about available data needed to categorize this industry. 

H. Location of Call and Participants 

Place: Call placed from NC Mutual Life Building, 10th Floor, 

U.S. EPA, Durham, North Carolina, to interested parties 

at CMA 

Date: September 25, 1997, 9:00 a.m. - 9:50 a.m. 

Participants: See List of Participants (Attachment 1) 

III. Discussion 

Attachment 2 contains a copy of the materials faxed to CMA prior to the conference 

call. The discussion followed the agenda for the most part, beginning with introductions, 

which was followed by a discussion of the scope of the Orgamc Liquids Distribution source 

category. Steve Shedd of the EPA stated that the definition of the scope of this NESHAP .. 

would require a thorough review of proposed, promulgated, and planned Federajjsgulafiohs 

along with various State and local rules applicable to this category, todgtermine what parts\of 
P.3 

Memo to Steve Shedd 

October 30, 1997 

Page 2 

the industry have already been regulated in terms of air emissions. He mentioned that the 

present scope is considered to include "stand alone" distribution facilities, including their 

loading racks, by modes including pipeline, tank truck, railcar, and barge for all organic 

liquids, excluding gasoline. Ted Cromwell of CMA stated that, typically, chemicals and 

petrochemicals are transported by rail and tank truck, with barge traffic in some areas. 

The CMA asked what the controls under this regulation are expected to be. The EPA 

responded that the control standards are likely to mirror past Federal regulations, such as the 

hazardous organic NESHAP (HON). The CMA inquired as to which organic liquids would be 

regulated by this rule, and the EPA replied that there will possibly be some vapor 

pressure/volatility, volume, and cost considerations that may affect cutoff limits. The EPA 

stated that they will investigate storage, transfer operations, equipment leaks, and wastewater 

for possible regulation, 

The EPA asked CMA for feedback as to the accuracy of the Organic Liquids 

Distribution facilities source category figure (see Attachment 2). The CMA stated that the 

figure was a good representation of the industry. The EPA asked if the CMA currently knew 

of any regulation or trade association for "compounding" facilities (facilities that blend 

individual chemicals or solvents into a fixed product mixture for distribution and sale), and the 

CMA said they were not aware of any. 

The EPA inquired as to any specific affiliation of die Independent Liquid Terminals 

Association (ILTA) with CMA. The CMA said that they are not specifically affiliated with 

the ILTA. The EPA asked if CMA member companies own their own distribution facilities, 

and CMA replied that some do, while others utilize "independent" terminals for storage and 

distribution of their products. 

Next, the EPA described the schedule for the P-MACT process, a 6-month process that 

ends with a presumptive MACT determination. One or more EPA/industry/States round table 

meetings will take place during this P-MACT process, with the first one most likely sometime 

in December 1997 or January 1998. States most likely to have strong interest in this NESHAP 

are considered to be Texas, California, Louisiana, and New Jersey. Proposal is expected to be 

near the end of 1999, and promulgation is scheduled for November of 2000. The 

identification of stakeholders included API, CMA, ILTA, PMA, NTTC, PPA, DOT, and 

SOCMA. 

The EPA expressed the need for help in securing data and information about the 

practices of the industry, such as the HAP content of petroleum products, distribution 

information, and control technologies information. The CMA stated that the Chemical 

Independent Councils for States such as Texas, Louisiana, New Jersey, and Ohio along with 

Randy Speight of CMA may be able to provide information about chemicals distribution. Mr. 

-_.-
P.4 

Memo to Steve Shedd 

October 30,1997 

Page 3 

Cromwell stated that those developing the Miscellaneous Organic NESHAP (MON) are 

currently in the data gathering stage and they may be a possible reference for information and 

data. The EPA asked CMA if they knew of any new studies on emission factors for organic 

liquids. The CMA was not aware of any such studies. 

Mr. Shedd stated that the EPA intends to send out an Information Request (IR) to 

companies owning facilities in this industry. The CMA said that most likely the IRs will need 

to go to the customers for the products, rather than to the manufacturers themselves. 

The EPA asked CMA if they would be interested in participating in the development of 

this regulation, and CMA responded that they are very interested in participating. Mr. 

Cromwell stated that at least six CMA members had expressed interest, and he said he would 

e-mail a list of interested companies to Greg LaFlam of PES. 

3 
P.5 

Memo to Steve Shedd 

October 30, 1997 

Page 4 

Attachment 1 

List of Participants 

1 
P.6 

Memo to Steve Shedd 

October 30, 1997 

Page 5 

List of Participants 

Organic Liquids Distribution MACT 

EPA7CMA Conference Call 

September 25, 1997 

North Carolina Mutual Life Building, Durham, NC, Steve Shedd's Office 

Name 

Greg LaFlam 

Jay Helms 

Steve Shedd 

Ted Cromwell 

Carlos Thomas 

Norm Morrow 

Affiliation 

Pacific Environmental Services, 

Pacific Environmental Services, 

EPA 

CMA 

CMA 

CMA 

Inc. 

Inc. 

Phone Number/FAX 

(919) 941-0333/0234 

(919) 941-0333/0234 

(919) 541-5397 

(703) 741-5246 

(703) 741-5246 

(703) 741-5246 

5 
P.7 

Memo to Steve Shedd 

October 30,1997 

Page 6 

Attachment 2 

Handouts 

G 
P.8 

ORGANIC LIQUIDS DISTRIBUTION NESHAP 

U.S. Environmental Protection Agency 

Initial Meeting with the Chemical Manufacturers Association 

September 25,1997,9:00 am 

EPA Mutual BIdg., Durham, NC, 10th Fir. 

Phone No. (919) 541-5397 

^AGENDA* 

1. Description/Scope of Source Category 

2. Presumptive MACT (P-MACT) Approach 

3. Project Schedule 

4. Identification of Stakeholders 

5. Data Needs 

6. General Discussion/Next Steps 

1 
P.9 

INDUSTRY GROUP - LIQUIDS DISTRIBUTION 

Source Category': Gasoline Distribution (Stage 1) 

The Gasoline Distribution (Stage 1) source category includes 

the storage and transfer facilities associated with the movement 

of gasoline. This category includes, but is not limited to, the 

gasoline vapor emissions associated with the loading of transport 

trucks or rail cars, storage tank emissions, and equipment leaks 

from leaking pumps, valves, and connections at bulk terminals, 

bulk plants, and pipeline facilities. Also included in this 

category are the storage tank filling operations that occur at 

public and private gasoline dispensing facilities (e.g., service 

stations, convenience stores, etc.). 

~*&T Source Category: Organic Liquids Distribution (Non-Gasoline) 

The Organic Liquids Distribution (Non-Gasoline) source 

category includes, but is not limited to, those activities 

associated with the storage and distribution of organic liquids 

other than gasoline, at sites which serve as distribution points 

from which organic liquids may be obtained for further use and 

processing. 

% 
P.10 

Organic Liquids Distribution 

Facilities Industry 

CHEMICALS 

Chemical 

Manufacturing 

(SOCMI) 

Consumer 

(Retail) 

Packaging/Distribution 

Facility 

Consumer 

(Retail) 

Facilities using 

chemicals as 

feedstocks 

Packaging/ 

Distribution 

Facility 

PETROLEUM 

Domestic 

Oil/Gas 

Production 

Petrochemical 

Manufacturing 

Packaging/ 

Distribution 

Facility 

Foreign 

Crude Oil 

Petroleum 

Refining 

Consumer 

(Retail) 

Intermediate Storage Facility 

<\