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OAR Box 1875 

Prepped by Ollie Stewart 

Document Number: 

48) ll-E-66 

Docket Number: 

A-90-19 

Printed 12/1/2008 11:12:47AM Sheet 48 of 86 
A-90-19 

ll-E-66 

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SUMMARY OE TELEPHONE CONFERENCE 

Date: October 19, 1992 

Subject: Monitoring 

Attendees: Lydia Wegman, Deputy Director of the Office of Air 

Quality Planning and Standards, EPA 

Bruce Jordan, Director of the Emissions Standards 

Division, EPA 

Daphne McMurrer, Emissions Standards Division, EPA 

Jan Meyer, Emissions Standards Division, EPA 

Rich Biondi, Deputy Director of the Stationary 

Source Compliance Division, EPA 

Mamie Miller, Stationary Source Compliance 

Division, EPA 

Scott Throw, Stationary Source Compliance Division, 

EPA 

Jane Engert, Stationary Source Compliance Division, 

EPA 

Charles Garlow, Air Enforcement Division, EPA 

Richard Sigman, Chemical Manufacturers Association 

Ted Cromwell, Chemical Manufacturers Association 

Kathy Bailey, Chemical Manufacturers Association 

Annette Stanley, Chemical Manufacturers Association 

Joe Hovias, Union Carbide 

Brian Taranto, Exxon Chemical 

Chuck Malloch, Monsanto 

John Dege, DuPont 

Jack McClure, Shell Oil 

Rich Phelps, Eastman Kodak 

Attached are three documents exchanged in preparation for this 

meeting. The first is a note faxed from Daphne McMurrer to Jack 

McClure, of Shell Oil, for him to distribute to the CMA 

representatives. In response to this fax, CMA sent EPA the second 

attachment. This document describes CMA's preferred system for HON 

compliance with operating parameter monitoring. The third 

attachment is a note from Ted Cromwell, of CMA, to Daphne McMurrer, 

of EPA. This note includes CMA's comments on a draft preamble 

discussion regarding HON recordkeeping. These attachments were not 

discussed in detail, but were referred to when CMA had questions 

concerning EPA's intent in the potential monitoring provisions for 

the HON. 

The EPA representatives summarized the potential monitoring 

provisions for the HON. The draft proposed HON requires continuous 

monitoring of operating parameters for control devices on Group 1 

emission points and emission points in emission averages. Each 

source would establish site-specific ranges for the monitored 

parameters through the operating permit or Notification of 
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» . 

Compliance Status. Records would be kept of the values of each 

parameter recorded once every 15 minutes. If values are measured 

more frequently, the 15-minute average may be recorded instead of 

each individual reading. 

The daily average value of each monitored parameter would be 

calculated and recorded. This would be the average over the number 

of hours of operation in a day (24 hours if operation is 

continuous). If the daily average value of a monitored parameter 

were outside the site-specific established range, the excursion 

would be reported. There would be between 3 and 6 excused 

excursions (3 to 6 days) for each 6-month reporting period. 

Excused excursions would not be considered violations, but 

additional excursions would be. The EPA is considering proposing 

the range of 3 to 6 days for comment, and selecting a final number 

at promulgation. 

A CMA representative suggested that the EPA consider allowing 

the source to define the start of the operating day in their 

permit, instead of reguiring daily averages to be calculated for 

the period from midnight to midnight. The CMA's suggested approach 

would allow the operating day to coincide with the plant's shift 

schedules. 

A CMA representative asked whether the operator would need to 

calculate every 24-hour average. He pointed out that in cases 

where all, or the great majority, of the recorded values are within 

the established range, an operator would know that the daily 

average was within the range without incurring the burden of doing 

a mathematical calculation. The SDB suggested that if every 

recorded value in an operating day is within the range, EPA could 

consider allowing operators to make a notation to that effect in 

the log (and keep the 15-minute records), instead of calculating 

the daily average. 

The CMA noted that sometimes two or three parameters may be 

monitored for the same control device. A single technical problem 

could cause all of the parameters to go outside their ranges. 

Would this situation be considered as one excursion or multiple 

excursions? The SSCD responded that it would count as one 

excursion per day per control device. 

The CMA requested that EPA include a table of example ranges 

for monitored parameters in the preamble. The SDB representatives 

indicated that the ranges included in the December 1991 draft could 

be used as examples, but that the proposed regulation would require 

sources and their regulatory authorities to establish site-specific 

ranges. 

3 Attachments 
PA_ 

FAX to Jack McClure, Shell Oil 

From Daphne McMurrer, EPA 

Oct. 8, 1992 

Attached is a summary of the compliance system EPA has 

developed for Subpart G of the HON. I am sending this to you as 

requested by CMA at our meeting on October 6, 1992. At that 

meeting we agreed that: 1) EPA would send a summary of the 

compliance envisioned for the HON to you on October 8; 2) CMA 

would review the EPA summary; and 3) someone from CMA would call 

Lydia Wegman to discuss the need for future meeting or other next 

steps. 

If you have guestions about the attached summary, please call 

me at (919) 541-0248. 
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HON Compliance and Operating Parameters 

HON requirements for excused excursions: 

1) What units of time will be used to define excused periods? 

o For devices with a 3-hour monitoring requirement, excused 

excursions would be allocated based on the 3-hour 

periods, 

o For devices with a different monitoring requirement, the 

duration of the required monitoring would be the basis 

for excursions. 

2) How will the excused periods be allocated? 

o By control device. 

3) How many excused excursions will be allowed as equating to 

proper operation and maintenance? 

o Three ranges will be proposed. 

o The three sets of ranges are based on the weeks of 

operation during the semi-annual period, 

o The following ranges will be proposed: 

Weeks of Operation Proposed Range of Excused Excursions 

24-2 6 15-4 8 excused excursions 

10-23 8-2 4 excused excursions 

1 - 9 4-1 2 excused excursions 

o The lower end of these ranges is based on EPA's original 

idea of 1% of the device's operating time. 

o The higher end of the range is based on CMA's idea of 6 

days (24-hour periods). 

4) There is a work practice element to the requirement. The 

source is required to: 

record that the excursions occurred; 

keep records of any diagnostic and corrective 

actions; and 

initiate corrective actions, if necessary, within 

24-hours of the first excursion reading. 

5) The following cannot be counted as excused excursions: 

Events in the Startup, Shutdown & Malfunction Plan 

Efforts to by-pass of the control device 

6) EPA will take comment on the idea of reducing excused 

excursions as a device is in service. For example, 48 

excursions could be excused for newly installed devices; 33 

for devices in use over a year but less than 2; and 15 for 

devices in use over 2 years. 
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.. i " ;•. ' . ' 

HON COMPLIANCE AND OPERATING PARAMETERS - EXCUSED EXCURSIONS 

1) How will excused periods be defined? 

o For devices requiring a 3 hour averaged monitoring parameter, 

excused excursions would be baser! on the 3 hour average. A 

twenty-four hour operating day would be divided into eight 3 

hour block periods. 

o For devices with different averaging periods, the duration of 

the required averaged monitoring period would be the basis for 

excused excursions. 

2. How are excused periods allocated? 

o By control device. 

o A control device may have a maximum of one excursion per 3 hour 

average, regardless of the number of monitored parameters. 

3. How many excursions will be allowed as meeting proper operation 

and maintenance? 

CMA Option - Measured as a % of operating days 

a) A deviation from a 3 hour averaged monitoring requirement 

would count as one excursion day. Up to eight deviations of 

the 3 hour average in an operating day would count as one 

excursion day. Every day a source operates counts as one 

operating day. The maximum number of operating days in a 

semiannual period is 183. 

b) The excused excursions would be equal to 3% of the actual 

operating days. If a source operates every day of a 

semiannual period, the maximum number of excused excursion 

days is 6. 

CMA Modification of the EPA Option - Measured as a % of 3 hour time 

periods 

a) Any deviation from a 3 hour averaged monitoring requirement 

would count as an excursion. The number of 3 hour block 

averaging periods would be those of actual operation in a 

semiannual period. The maximum number of 3 hour block averages 

in a semiannual period is 1,464. 

b) The excused excursions would be equal to 3% of the actual 3 

hour block averaging periods. If a source operates every day 

of a semiannual period, the maximum number of excused excursion 

periods is 44. 

The 3% excused excursion value is based on industry operating 

experience of the types of upsets that can normally be expected to 

occur. 

U 
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4. Work practice element. The source is required to: 

- record that the excursions occurred; 

- keep records of any diagnostic and corrective actions; and, 

- intitate any necessary corrective actions within 24 hours of the 

first excursion reading. 

5. The following cannot be counted as excused excurions: 

- Events in the Startup, Shutdown, and Malfunction Plan. 

- Efforts to by-pass the control device. 

6. EPA will take comment on the idea of reducing the percentage of 

excused excursions over time as a device is in service. 
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1 J 

October 13, 1992 

To: Daphne McMurrer 

From: Ted Cromwell 

The following includes the EPA language with suggested changes 

from CMA. CMA changes are underlined and are In bold type. 

HON Recordkeeping 

To be Inserted Into the R&R Section 

The proposed rule requires sources to keep readily accessible 

records of monitored parameters. For those control devices that must 

be monitored continuously, records which Include at least one 

monitored value for every 15 minutes of operation are considered 

sufficient. These monitoring records must be maintained for 5 years. 

Industry sources have informed EPA that some existing computer 

controlled processes have monitoring systems that only store data that 

is outside some predetermined range of acceptable values. For 

example, these systems could be (are) set to record and store all 

monitored values outside a range such as •*•- 1%. If a monitored value 

did not exceed the specified range, no value would be stored. When the 

value exceeded the range, a value would be stored. It Is then deemed 

that all data in between the stored values Is the same as the last 

recorded value. This systems could also be used to record those 

periods when a monitored parameter may be outside the parameter ranges 

established by the source to represent proper operation of a control 

device. Keeping only these records would dramatically reduce the data 

storage requirements. 

Industry sources have also informed EPA that many existing 

process control computer systems obtain monitoring data much more 

frequently than every 15 minutes, but are not designed to maintain a 

record of such data for five years. Such systems use this extensive 

monitoring data to calculate average parameter values for the 

compliance period for the emission source (e.g . 3 hour average). The 

Individual data points could be kept In an accessible record for a 

period of several days so that the averaging procedure could be 

verified, and then could be "written over" to conserve computer time 

and memory storage space. The average for the 3-hour compliance period 

would be retained in an accessible record for 5 years. EPA request 

comments on whether such a system would satisfy records retention 

requirements and provide an adequate basis for compliance 

demonstration • 

At this time, EPA does not have sufficient data about these 

systems to ensure that they reliably reflect the source's continued 

compliance. Therefore, EPA has not included them as a recordkeeping 

option in the proposed rule. Instead, EPA is seeking comment on 

whether and how these systems should be allowed for compliance with the 
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recordkeeping requirements in the HON. Specifically, EPA is interested 

in: what criteria are used to determine the values that are stored by 

these existing monitoring systems; how the validity of the data is 

verified; the frequency of calibration for this type of system; how 

operators ensure the accuracy of the results from these existing 

systems; and what types of processes or controls are currently being 

monitored with these systems. In addition, EPA is seeking comment on 

how the requirements allowing the used of these systems to comply with 

the HON might be structured. Finally, EPA is seeking comment on the 

concept of determining compliance based on data that do not Include 

values to represent the entire compliance period (i.e . absence of data 

indicating a violation would constitute evidence of compliance.)