p.1 

OAR Box 1877 

Prepped by Keeia Richards 

Document Number: 

4) ll-B-1 

Docket Number: 

A-90-19 

Printed 12/2/2008 10:36:46 AM Sheet 4 of 46 
P.2 

A-90-19 

II-B-1 

&2 EPA 

National Air Pollution Control Techniques 

Advisory Committee 

Minutes of Meeting 

January 29-31, 1991 

U. S. Environmental Protection Agency 

Emission Standards Division (MD-13) 

Office of Air Quality Planning and Standards 

Office of Air and Radiation 

Research Triangle Park, North Carolina 27711 
P.3 

April 17, 1991 

SUBJECT: Distribution of the Minutes for the January 29-31, 1991 Meeting of 

the National Air Pollution Control Techniques Advisory Committee 

TO: See Attached List 

Attached is a copy of the minutes. The minutes with the pink cover were 

copied in OAQPS; a reprint (green cover) was done through Judy Elkins' office. 

The first copies are not as good as the reprint, so I am using them for 

internal distribution. The only place that you may have a problem with 

legibility is the record of attendance. I have the original if you need to 

make a clearer copy. 

Please note that an errata sheet has been prepared for the dry cleaning 

portion of the minutes (this is included with your copy of the minutes). 

MARYUAHE CLARK 

Attachment 
P.4 

•Indicates Presenter 4/17/91-MJC1ark 

JANUARY 29, 30, AND 31, 1991 NAPCTAC MEETING 

DISTRIBUTION LIST FOR MINUTES - ESD STAFF/CONTRACTORS 

(DOCKET COPIES SENT TO EPA LEAD AS NOTED) 

Overview of Title III Clean Air Act Aeendaents - No Docket 

Bill Harnett* 

Definition of Source - No Docket 

Jim Weigold* 

Petition Process - Docket A-90-48 

Dianne Byrne 

Judith Graham (ECAO) 

Nancy Pate* 

Source Category List - Docket A-90-49 

Joel Watson-Radian 

Karen Blanchard 

Bob Rosensteel* 

Tim Mohin 

Earlv Eaission Reduction - Docket A-90-47 

Linda Chaput 

Dave Beck* 

Dry Cleaning - Docket A-88-11 

Kim Kepford/Carolyn Norris-Radian 

Shirley Tabler Brenda Jellicorse-RTI 

Dave Beck* Tom Walton 

Ethylene Oxide Co—ercial Sterilizers - Docket A-88-03 

Beth Friedman/Val deOlloqui-MRI 

Dave Markwordt* 

Chroeif Electroplating - Docket A-88-02 

Robin Barker-MRI 

Fred Dimmick Al Wehe 

Lalit Banker* Al Vervaert 

Andy Smith* (not sent--no longer in ESD) 

Hazardous Organic NESHAP (HON) on Source Categories in the Cheaical Industry 

Dockets A-90-19/A-90-20/A-90-21/A-90-22/A-90-23 

Leslie Evans 

Bob Rosensteel* Randy McDonald 

Jan Meyer Penny Lassiter 

Asbestos-Coeorehensive Revisions - Docket A-90-40 

M1ke Laney-RTI 

Sims Roy* Gary McAlister 

Municipal Waste CoufeustQrs 

David White-Radian 

Walt Stevenson Jim Kilgroe-ORD 

Mike Johnston* 

Fred Porter 

Tank Vessel Standards 

Becky Nicholson/David Kapella-MRI 

Dave Markwordt* 
P.5 

U.S. ENVIRONMENTAL PROTECTION AGENCY 

. NATIONAL AIR POLLUTION CONTROL TECHNIQUES ADVISORY COMMITTEE 

Cnairperson and Designated Federal Official 

Director, Emission Standards Division (MD-13) 

Office of Air Quality Planning and Standards 

U. S. Environmental Protection Agency 

Research Triangle Park, North Carolina 27711 

(919) 541-5572 

FTS: 629-5572 

COMMITTEE MEMBERS 

Mr. Paul H. Arbesman* 

Director, Pollution Control 

All ied-Signal,Inc. 

Columbia Road and Park Avenue 

Morristown, New Jersey 07962 

(201) 455-4286 

Mr, Donald R. Arkell 

Director 

Lane Regional * 3 Pollution Authority 

Z25 ciorzn Stn oLreet-Sune 501 

Springfield, Oregon 97477 

(503) 726-2514 

Dr. Patrick R. Atkins 

Director, Environmental Control 

Aluminum Company of America 

1501 Alcoa Building 

Pittsburgh, Pennsylvania 15219 

(412) 553-3805 

Mr. Charles A. Collins* 

Administrator, Air Quality Division 

Wyoming Department of 

Environmental Quality 

122 West 25th Street 

Cheyenne, Wyoming 82002 

(307) 777-7391 

Mr. William J. Dennison* 

Dennison and Associates 

4 Cintilar 

Irvine, California 92720 

(714) 573-0738 

(formerly Director of Engineering, 

South Coast Air Quality Management District) 

Mr. Ralph E. Hise* 

President 

Advanced Technologies Management, Inc. 

2964 Falmouth Road 

Cleveland, Ohio 44122 

(216) 751-5135 

Mr. James A. Martin 

President 

Environmental Systems Division 

Asea Brown Boveri, Inc. 

Post Office Box 43030 

Birmingham, Alabama 35243 

(205) 991-2832 

Ms. Vivian M. Mclntire 

Environmental Affairs 

Eastman Chemicals Company 

Post Office Box 511 

Kingsport, Tennessee 37662 

(615) 229-3045 

Mr. William O'Sullivan* 

Assistant Director 

Air Quality Engineering and Technology 

N.J. Department of Environmental Protection 

401 East State Street, CN027 

Trenton, New Jersey 08625 

(609) 984-6721 

Dr. John E. Pinkerton* 

Program Director, Air Quality 

National Council of the Paper Industry 

for Air and Stream Improvement, Inc. 

260 Madison Avenue 

New York, New York 10016 

(212) 532-9047 

Ms. Deborah A. Sheiman 

Resource Specialist 

Natural Resources Defense 

1350 New York Avenue, N.W. 

Washington, D. C. 20005 

(202) 783-7800 

Council 

-Suite 300 

;na January 1991 

n i 
P.6 

X. NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) 

BASED ON MAXIMUM -ACHIEVABLE CONTROL TECHNOLOGY (MACT) 

EPA PRESENTATION 

Mr. Robert E. Rosensteel 

Emission Standards Division 

Office of Air Quality Planning and Standards 

U.S. Environmental Protection Agency 

Research Triangle Park, NC 27711 

SUMMARY 

EPA reported to the National Air Pollution Control Techniques 

Advisory Committee (NAPCTAC) on the development of National 

Emission Standards for Hazardous Air Pollutants (NESHAP) for 

hazardous organics. The Hazardous Organic NESHAP (HON), being 

. developed under Group I Standards of Title III of the Clean Air 

• Act Amendments, will regulate the Synthetic Organic Chemical 

Manufacturing Industry (SOCMI). 

The presentation covered the significance and scope of HON, HON 

emission sources, candidate technologies being considered to 

determine Maximum Achievable Control Technologies (MACT), impacts 

and economic analyses, regulatory options development, 

interactions with external groups, and the project schedule. 

This section summarizes the presentation, a copy of which is 

included as Attachment l. 

HON contributes significantly to the Title III requirement to set 

standards for 40 or more source categories or subcategories 

within 2 years of enactment of the Clean Air Act Amendments 

(CAAA), and regulates a large portion of SOCMI, including as many 

as 110 of the 189 Hazardous Air Pollutants (HAPs) listed in the 

CAAA. A SOCMI production process is regulated under the HON if 
P.7 

it produces or uses one or more of the approximately 110 SOCMI 

HAPs included in the CAAA. HON includes 400 subcategories and 

affects approximately 1000 individual process units as estimated 

by our analysis at this time. 

HON emission sources include equipment leaks, process vents, 

storage vessels, transfer operations; and wastewater operations. 

A determination of MACT will be made for each of these emission 

sources. This determination will include selection of control 

techniques (including pollution prevention options) and 

applicability criteria to determine what classes, types, and 

sizes of SOCMI sources are required to apply control. Control 

techniques have already been identified based on past and current 

rulemaking efforts. These controls vers selected tc result ir. 

maximum emission reduction for each of tne five emission source 

types. Applicability criteria will be the focus of future 

regulatory options analysis. Control and pollution prevention 

techniques for each source type are listed in Table 1 of 

Attachment 1. 

The impacts analysis for the HON is a four-step approach that 

includes characterization of the industry, development of model 

emission sources unique to each source type, assignment of models 

to each production process, and estimation of emissions, emission 

reductions, and control costs. Economic analyses will be 

conducted to determine response to regulations and the need for 

additional analyses for a subset of chemicals. Cumulative cost, 

chemical cost increases, and detailed and market analysis of 

selected subsets will be included in the economic analyses. 

Regulatory options will be developed' for four of the emission 

source types. Options for equipment leaks will not be evaluated 

in the HON. Regulatory options will comprise both control 

technologies and applicability criteria and will be at least as 

stringent as the MACT floors. Applicability criteria will 

9 (.4 
P.8 

include measurable characteristics of the emission source and 

chemical properties as shown in Table 2. The impacts considered 

for regulatory options include baseline emissions, MACT floor, 

HAP and VOC emission reduction, incremental emission reduction, 

number and percent of emission sources controlled, annualized and 

incremental control costs, average and incremental cost 

effectiveness, and chemical cost increases. Other environmental 

and energy impacts, including barrels of oil equivalent, water 

impacts, and secondary air emission impacts, will also be 

estimated. 

EPA has met or made contact with several external groups in the 

process of developing the HON standards. These groups include 

"hs -Th emical Mar.ufaczursrn .'___3cci__'c;._;r_ 'TMA; ~r.e 5vr.ir.'j-z:... 

Organic Chemical Manufacturers Association (SOCMA), the State and 

Territorial Air Pollution Program Administrators/Association of 

Local Air Pollution Control Officials (STAPPA/ALAPCO), the 

National Association of Manufacturers (NAM), and the National 

Resources Defense Council (NRDC). Additional contact with these 

and other groups is expected. The current schedule calls for HON 

standards to be proposed on November 22, 1991, and promulgated on 

November 15, 1992. 

DISCUSSION 

Following the presentation, Committee member Ms. Deborah Sheiman 

(NRDC) asked how cutoffs for the different source categories will 

be determined and how they will compare with NSPS cutoffs. 

Mr. Rosensteel, EPA, replied that different cutoffs incorporating 

various degrees of stringency will be developed, based on 

applicability criteria. For example, size and vapor pressure 

will be considered for storage vessels, and stream flow and 

concentration will be considered for process vents. NSPS cutoffs 

will be considered as an aid in developing the MACT floor, but 

are not expected to be adopted as cutoffs for these rules. 
P.9 

M s . Sheiman inquired what standards will be required for emission 

sources below the cutoff. Mr. Rosensteel responded that these 

sources will have to maintain stream characteristics below the 

cutoff level. Ms . Sheiman argued for development of control 

requirements for sources both above and below the cutoff, and 

indicated that sources below the cutoff should also be required 

to reduce emissions. Mr. Rosensteel replied that these sources 

do have to maintain emissions below the cutoff level. 

While she acknowledged the limited time available to gather 

information, Ms . Sheiman indicated that EPA should gather more 

source-specific data in order to develop more robust standards. 

M r. Rosensteel indicated that it was impractical to gather and 

_._*•.*•_. "—3 • — -.*<a-y—-- ;a~a _~Zm7 ~r_s 3nti_T3 l_iau3~r"*. Mr. J"i.7. "***5-_.'zcl_-

EPA, added that previous efforts to regulate this industry had 

been thwarted by a cycle of continual analysis and that 

disciplined action was necessary to implement controls. 

M r. Weigold added that EPA would use any information provided. 

Committee member Ralph Hise (Advanced Technologies Management) 

questioned whether it was practical to develop standards for 

400 subcategories in 2 years, considering that the law only calls 

for the development of 40. Mr. Rosensteel replied that 

similarities among all the processes and control techniques makes 

it practical to develop the standards simultaneously. Mr. Hise 

questioned whether 1000 process units or 1000 chemicals were 

being regulated, and inquired about the total number of major 

area sources. Mr. Rosensteel responded that 1000 process units 

is our current estimate, and that the number of major and minor 

sources has not yet been analyzed. He indicated that there are 

6000 process units in the chemical and allied industries 

[Standard Industrial Classification (SIC) Code 28] and that the 

SOCMI is a subset of SIC 28. Mr . Rosensteel added that our 

estimates show the SOCMI accounting for 1000 process units with a 
P.10 

/ judgement that the HON would not affect more than 2000 process 

units. . 

Committee member Vivian Mclntire (Eastman Chemicals Company) 

complimented EPA on their pollution prevention approach, 

encouraged EPA to develop flexible standards, and indicated the 

need to consider how compliance will be demonstrated, as it will 

be hard to quantify the effects of process changes. She also 

inquired whether facilities that recycle and recover chemicals 

would be subject to the HON. Mr. Rosensteel replied that these 

facilities probably would be so regulated. Mr. Rosensteel added 

that previous applicability decisions on the distillation NSPS 

considered recovery facilities to be subject to the rule if they. 

cr~duc3 _. SOC_iI chemical fcr sals. 

Ms. Mclntire indicated that most wastewater treatment plants have 

mixtures of potentially regulated and non-regulated chemicals and 

questioned whether such mixtures would be controlled under the 

HON. Ms. Mclntire indicated that further description would be 

needed, as many facilities combine many streams from many types 

of. processes. Ms. Penny Lassiter, EPA, replied that 

determinations of control requirements would be made at the point 

of generation of the stream. However, for treatment, streams 

could be combined. Ms. Lassiter added that streams would be 

considered at the point of generation since a few streams 

represent a large percentage of the emission potential, and it is 

more efficient to control them before mixing. 

Ms. Mclntire then asked how the HON standards would interface 

with those in the Resource.Conservation and Recovery Act (RCRA). 

Ms. Susan Wyatt, EPA, replied that HON and RCRA regulations 

complement each other, as wastewater tanks are not covered under 

RCRA. Ms. Mclntire inquired which rule would cover sewers. 

Ms. Wyatt replied that HON would regulate emissions from sewers 

and sumps. Ms. Wyatt added that, since EPA's Emission Standard 

<_67 
P.11 

Division is developing both the RCRA and the HON, the two 

rulemakings will-be well coordinated. 

Ms. Mclntire questioned why control efficiency for equipment 

leaks was set at 85-88 percent rather than 88-90 percent, and 

asked whether credits for 90 percent early reduction would be 

given. Mr. Rosensteel replied that the percentages were 

preliminary numbers that may be changed and would in any case 

depend on site-specific process characteristics. Ms. Mclntire 

also inquired whether fugitive emissions could be considered for 

the 90 percent early reduction credit. Mr. Weigold replied that 

the amount of credit for fugitive emissions was under debate. 

Ms. Mclntire emphasized the importance of industry options and 

flexible ccr.arcis fcr MACT, and advocated the allowance cf 

alternatives to corr.bu.s-ion control. Mr. TRosensteel responded 

that performance standards would be emphasized and could be met 

using any technology. Ms. Mclntire commented that increased N0X 

and CO emissions are likely effects of compliance if combustion 

is used. Mr. Weigold*indicated that EPA would consider NOx and 

CO emission levels from combustion devices. Mr. Weigold also 

mentioned that the relative worth of HAP emission reduction and 

NOx/CO emission increase would need to be determined. 

Committee member William 0'Sullivan (New Jersey Department of 

Environmental Protection) commented that flares may not be as 

efficient as incinerators and that enclosed flares may perform 

better than open flares. Mr. Rosensteel replied that previous 

research defined flare operating conditions and showed,that, when 

operated properly, both open and enclosed flares are efficient. 

Mr. 0*Sullivan inquired whether carbon adsorbers were included, 

Mr. Rosensteel responded that, while not specifically listed in 

the handout, carbon adsorbers are a pollution prevention device 

that individual facility owners could consider using. 
P.12 

Mr. O1Sullivan commented that both vapor pressure and weight 

percent HAP concentration should be included as an applicability 

criteria for process vents in order to determine if condensation 

would work. Mr. Rosensteel indicated that vapor pressure is a 

variable that the individual source needs to obtain if 

considering condensation as a technique for reducing their 

organic emissions. It is not a variable that needs to be 

considered as applicability criteria for combustion. Individual 

facility owners can evaluate whether condensation is a practical 

alternative to combustion for their stream characteristics. 

Ms. Mclntire recommended moving the proposal date from 

November 22, in order to avoid conflict with the Thanksgiving 

holiday. Mr. Charles Collins (Wyoming Department of 

Environmental Quality) asked vherher che standard crac-uasd 

sending wastewater to public treatment facilities. Ms. Wyatt 

responded that if emissions were above the cutoff level, 

wastewater streams may need to be treated before being sent to 

public facilities. 

Committee member Paul Arbesman (Allied-Signal, Inc.) emphasized 

the importance of adequate information to develop the rules, and 

inquired what the format of the standard would be, noting that 

simple concentration standards had been problematic. He also 

indicated that effluent guidelines on concentration levels were 

difficult to implement, especially considering water conservation 

efforts. Mr. Rosensteel replied that a number of applicability . 

criteria cutoffs would be considered, including HAP weight 

percent and flow. (See Table 2 of Attachment 1.) Ms. Wyatt 

added that process vent units exceeding the cutoff would probably 

have to meet a percent control. Mr. Arbesman also inquired 

whether Appendix A of the HON overview paper (December 1990) 

corresponded to the 110 HAPs. Mr. Rosensteel responded that 

Appendix A included production of the 110 SOCMI HAPs, as well as 

SOCMI chemicals that use a HAP in their production. 
P.13 

Ms. Mclntire inquired whether process vent batch operations would 

be regulated. Mr. Rosensteel replied that process vent emissions 

from batch operations would be exempt under HON, as they will be 

covered in another rulemaking effort. Committee member 

William Dennison (Dennison and Associates) commented that the 

equipment leaks part of the HON regulation should also specify 

pump seals and valve packing requirements. Mr. Rosensteel 

indicated that further specific requirements, including use of 

superior eguipment, have been developed during the equipment 

leaks negotiated regulation. It was not possible to include all 

of these specifics on the handout. 
P.14 

ATTACHMENT 1 

HAZARDOUS ORGANIC 

NESHAP (HON) 

NATIONAL AIR POLLUTION CONTROL TECHNIQUES 

ADVISORY COMMITTEE 

JANUARY 30, 1991 
P.15 

OUTLINE 

SIGNIFICANCE OF HON 

SCOPE OF HON 

HON EMISSION SOURCES 

DETERMINATION OF MACT 

IMPACTS ANALYSIS 

ECONOMIC ANALYSIS 

REGULATORY OPTIONS DEVELOPMENT 

INTERACTIONS WITH EXTERNAL GROUPS 

PROJECT SCHEDULE 
P.16 

SIGNIFICANCE OF HON 

• MEETS TITLE III REQUIREMENT TO SET 

STANDARDS FOR 40 OR MORE SOURCE 

CATEGORIES WITHIN 2 YEAr.S OF CLcAN 

AIR ACT AMENDMENT (CAAA) ENACTMENT 

• REGULATES A LARGE PORTION OF 

SYNTHETIC ORGANIC CHEMICAL 

MANUFACTURING INDUSTRY (SOCMI) AND 

UP TO 110 OF THE 189 HAPs LISTED IN 

THE CAAA 

o AN ESTIMATE BASED ON TRIS INDICATES 

THAT 6 TO 10 PERCENT OF HAP 

EMISSIONS FOR THESE 110 ORIGINATE 

FROM SOCMI 
P.17 

SCOPE OF HON 

A SOCMI PRODUCTION PROCESS IS 

INCLUDED IF IT: 

(1) PRODUCES (AS A O90DUCT. 

CO-PRODUCT, BY-PRODUCT, OR 

INTERMEDIATE) 1 OR MORE OF 

THE APPROXIMATELY 110 SOCMI 

HAPs INCLUDED IN THE CAA 

AMENDMENTS LIST OF 189 HAPs; 

OR 

(2) USES 1 OR MORE OF THE 

APPROXIMATELY 110 SOCMI HAPs 

AS A REACTANT OR RAW 

MATERIAL. 

->7<1 
P.18 

SCOPE OF HON (CONTINUED) 

© INCLUDES ABOUT 400 SUBCATEGORIES. 

TOTAL PRODUCTION CAPACITY FOR THESE 

CHEMICALS IS 70 MILLION METRIC TONS 

(MG) PER YEAR. 

e THE HON MAY AFFECT APPROXIMATELY 

1,000 INDIVIDUAL PROCESS UNITS. 
P.19 

HON EMISSION SOURCES 

• EQUIPMENT LEAKS 

• PROCESS VENTS 

© STORAGE VESSELS 

© TRANSFER OPERATIONS 

© WASTEWATER OPERATIONS 
WHAT ARE THE AFFECTED SOURCE TYPES? 

STORAGE TANKS 

(2) EQUIPMENT 

LEAKS 

WASTEWATER 

(4) 

PROCESS VENTS 0) 

Air oxidation 

Distillation 

Reactors 

Organic Emissions 

Into Atmoshere If 

Uncontrolled 

TRANSFER 

(5) 

ro 

o 
P.21 

DETERMINATION OF MAXIMUM ACHIEVABLE 

CONTROL TECHNOLOGY (MACT) 

• INCLUDES SELECTION OF: 

(1) CONTROL TECHNIQUES INCLUDING 

POLLUTION PREVENTION OPTIONS, 

AND 

(2) APPLICABILITY CRITERIA TO 

DETERMINE WHAT CLASSES, 

TYPES, AND SIZES OF SOCMI 

SOURCES ARE REQUIRED TO APPLY 

CONTROL. 

n^ Q 
P.22 

DETERMINATION OF MAXIMUM ACHIEVABLE 

CONTROL TECHNOLOGY (MACT) (CONTINUED) 

- CONTROL

 TECHMI(.UES "AVE BEEN 

IDENTIFIED. THESE CONTROLS RESULT 

IN MAXIMUM EMISSION REDUCTION FOR 

EACH OF THE FIVE EMISSION SOURCE 

TYPES. THE SELECTION OF CONTROLS 

WAS BASED ON PAST AND CURRENT 

RULEMAKING EFFORTS. 

o APPLICABILITY CRITERIA WILL BE THE 

FOCUS OF FUTURE REGULATORY OPTIONS 

DEVELOPMENT FOR THE HON. 
TABLE 1. CONTROL TECHNIQUES AND POLLUTION PREVENTION TECHNIQUES 

SOURCE TYPES 

(CONTROL EFFICIENCY) 

CONTROL TECHNIQUE 

EQUIPMENT LEAKS 

(85-88%) 

POLLUTION PREVENTION 

TECHNIQUES 

LEAK DETECTION AND 

REPAIR, IMPROVED 

MAINTENANCE PRACTICE 

CO 

o 

PROCESS VENTS 

(98%) 

- FLARE 

- THERMAL INCINERATOR 

- THERMAL INCINERATOR 

PLUS SCRUBBER 

INCREASED PRODUCT 

RECOVERY EFFICIENCY 

STORAGE TANKS 

(-95%) 

INTERNAL FLOATING 

ROOF 

- CONDENSER 
TABLE 1. CONTROL TECHNIQUES AND POLLUTION PREVENTION TECHNIQUES 

SOURCE TYPES 

(CONTROL EFFICIENCY) 

CONTROL TECHNIQUE 

TRANSFER OPERATIONS 

(98%) 

- FLARE 

- THERMAL INCINERATOR 

- THERMAL INCINERATOR 

PLUS SCRUBBER 

POLLUTION PREVENTION 

TECHNIQUES 

- PROCESS CHANGE 

(VAPOR BALANCING) 

WASTEWATER 

(-95%) 

STEAM STRIPPER PROCESS .CHANGES TO 

REDUCE LOSSES 

RECYCLING OF WASTES 

TO PROCESS 

EMISSIONS MAY ALSO BE VENTED TO EXISTING BOIL___IS OR PROCESS HEATERS AS 

AN ENERGY CONSERVATION MEASURE. 

ro 
P.25 

IMPACTS ANALYSIS 

© FOUR STEP APPROACH 

(1) CHARACTERIZATION OF INDUSTRY 

(E.G., PRODUCER IDENTIFICATION, 

CAPACITY, PROCESS TYPE, 

COMPLEXITY, GEOGRAPHIC LOCATION) 

(2) DEVELOPMENT OF MODEL EMISSION 

SOURCES UNIQUE TO EACH SOURCE 

TYPE 

(3) ASSIGNMENT OF MODELS TO EACH 

PRODUCTION PROCESS 

(4) ESTIMATION OF EMISSIONS, 

EMISSIONS REDUCTIONS, AND 

CONTROL COSTS 

© CONSIDERS EXISTING CONTROL REQUIREMENTS 
P.26 

ECONOMIC ANALYSIS 

© PURPOSES 

(1) DETERMINE RESPONSE TO 

REGULATIONS 

(2) DETERMINE WHAT ADDITIONAL 

ANALYSES ARE NEEDED 
P_2Z_ 

ECONOMIC ANALYSIS (CONTINUED) 

© APPROACH FOR. HON 

(1) CUMULATIVE COST 

(2) CHEMICAL COST INCREASES 

(3) SUBSET SELECTION FOR DETAILED 

ANALYSIS 

(4) MARKET ANALYSIS OF SUBSET 

284 
P.28 

REGULATORY OPTIONS DEVELOPMENT 

« REGULATORS :?-:;MS WILL •£ 

DEVELOPED FOR EACH OF THE FOUR 

EMISSION SOURCE TYPES (OPTIONS FOR 

EQUIPMENT LEAKS WILL NOT BE 

EVALUATED IN THE HON) 

© ALL OPTIONS WILL BE AT LEAST AS 

STRINGENT AS THE MACT FLOORS 

9QC* 
P.29 

REGULATORY OPTIONS DEVELOPMENT (CONTINUED) 

• REGULATORY OPTIONS WILL INCLUDE 

CONTROL LEVELS PREVIOUSLY PRESENTED 

FOR STORAGE) AND APPLICABILITY 

CRITERIA 

© APPLICABILITY CRITERIA WILL INCLUDE 

MEASURABLE CHARACTERISTICS OF THE 

EMISSION SOURCE AND CHEMICAL 

PROPERTIES. SEE TABLE 2. 

286 
P.30 

TABLE 2. CANDIDATE APPLICABILITY CRITERIA 

SOURCE TYPE 

EQUIPMENT 

LEAKS 

PROCESS VENTS 

STORAGE 

CANDIDATE APPLICABILITY 

CRITERIA 

- HAP SERVICE (AT LEAST 

5% BY WEIGHT)* 

• 

-

 rL0WRATE 

- HAP WEIGHT PERCENT 

- HEAT CONTENT 

- TANK SIZE 

- VAPOR PRESSURE OF HAP 

HAS BEEN DETERMINED FROM REGULATORY 

NEGOTIATION, WILL NOT BE ANALYZED FOR HON 
P.31 

TABLE 2. (CONTINUED) 

SOURCE TYPE CANDIDATE APPLICABILITY 

CRITERIA 

TRANSFER - THROUGHPUT 

- VAPOR PRESSURE OF HAP 

WASTEWATER - FLOWRATE 

- VHAP CONCENTRATION 

288 
P.32 

• IMPACTS PRESENTED FOR REGULATORY 

OPTIONS 

- BASELINE EMISSIONS 

- MACT FLOOR 

- EMISSION REDUCTION (HAP AND VOC) 

- INCREMENTAL EMISSION REDUCTION 

- NUMBER AND PERCENT OF EMISSION 

SOURCES CONTROLLED 

- CONTROL COSTS (ANNUALIZED) 

- INCREMENTAL CONTROL COSTS 

- AVERAGE COST EFFECTIVENESS 

- INCREMENTAL COST EFFECTIVENESS 

- CHEMICAL COST INCREASES 

'*OC 
P.33 

• OTHER ENVIRONMENTAL AND ENERGY 

IMPACTS WILL 1LSO .Z ESTIM£TE_. 

T ENERGY IMPACTS (BARRELS OF OIL 

EQUIVALENT) 

- WATER IMPACTS 

- SECONDARY AIR EMISSION IMPACTS 

?9Q 
P.34 

INTERACTIONS WITH EXTERNAL GROUPS 

CMA 

SOCMA 

STAPPA/ALAPCO 

NAM 

NRDC 
P.35 

HON PROJECT SCHEDULE 

PROPOSAL 

PROMULGATION 

11/22/91 

11/15/92 

on. 
P.36 

/ / If 

Institute 

A Division of The Society of The Plastics Industry, Inc. 

COMMENTS ON THE EPA HAZARDOUS ORGANIC NESHAP (HON) PROJECT 

The Vinyl Institute, a division of The Society of the 

Plastics Industry, Inc.*^ is pleased to provide these comments 

to the National Air Pollution Control Techniques Advisory 

Commit-_.ee (NAPCTAC) on the U.S. Environmental Protection 

Chemical Manufacturing Industry ("SOCMI") under the National 

Emission Standards for Hazardous Air Pollutants ("NESHAP") for 

Hazardous Organics, otherwise known as the HON program. 

Members of the Vinyl Institute represent the majority 

of domestic manufacturers of vinyl chloride, polyvinyl 

1/ SPJ: is a 2,000 member not-for-profit trade organization 

representation all segments of the plastics industry in the 

United States. The Society's members include processors and 

manufacturers of plastics and plastic products, suppliers of 

raw material, processors and converters of plastic resins and 

manufacturers of accessory equipment for the plastic industry. 

Founded in 1937, SPI is the major national trade association of 

the plctstics industry. 

Members of the Vinyl Institute include the BF Goodrich 

Company, Borden Chemicals and Plastics' Industries, CertainTeed 

Corporation, The Dow Chemical Company, Georgia Gulf Corporation, Occidental Chemical Corporation, PPG Industries, Inc., 

PW Resins, Shintech, Inc., and Vista Chemical. Members of the 

Vinyl Institute account for approximately 82% of the domestic 

production of vinyl chloride and 63% of the domestic production 

of polyvinyl chloride. 

Wayne Interchange Plaza II • 755 Route 46 West • Wayne, NJ 07470 • (201) 890-9299 
P.37 

- 2 -

chloride, and ethylene dichloride. Because these substances 

are listed under newly amended section 112 of the Clean Air 

Act, and because many Vinyl Institute members fall within the 

SOCMI point source category, the developing HON regulations are 

of significant concern. EPA must carefully consider the 

interrelationship between specific standards for individual 

substances such as vinyl chloride and general standards such as 

those presented in the HON and equipment leaks proceedings. 

Ay __iC u _____ _ '-» .i***. .* ^.w _!_..___.__. 

The Clean Air Act Amendments of 1990 direct EPA to 

establish source categories and subcategories for facilities 

emitting any of the listed hazardous air pollutants specified 

in Section 112(b). EPA must then promulgate regulations 

specifying maximum achievable control technology (MACT) for 

such categories and subcategories. The initial regulations 

will be subsequently followed by a residual risk analysis. 

The current EPA proposal would establish broad MACT 

requirements for five emission sources — .process vents, 

wastewater treatment operations, storage tanks, transfer 

operations and equipment leaks. Equipment leaks are, however, 

addressed in a separate regulatory proceeding. EPA is to 

evaluate possible control technologies in light of specific 

source categories, emission levels, production rates or 
P.38 

- 3 -

capacities, chemical properties, or physical characteristics 

and based on its evaluation determine the appropriateness of 

mandating a particular control technology as MACT. 

The list of hazardous air pollutants specified in 

Section 112(b) of the Clean Air Act includes chemicals for 

which EPA has already promulgated NESHAP regulations. For 

example, a NESHAP has been established for vinyl chloride which 

applies to vinyl chloride emissions from ethylene dichloride 

40 C.F.R. § 61.60 (1989). 

Vinyl chloride is one of only seven pollutants that 

were regulated under former Section 112 prior to the 1990 

amendments.* The rule was initially promulgated in 1976 and 

underwent extensive review leading to minor revisions in 1986. 

The rule was most recently amended in 1990. 41 Fed. Reg. 46561 

(Oct. 21, 1976); 51 Fed. Reg. 34904 (Sept. 30, 1986); 55 Fed. 

Reg. 23346 (July 10, 1990). As part of the 1986 revisions, EPA 

reviewed available control technology. At that time, EPA 

concluded that there was no preferable process or control 

technology superior to that mandated by the standard. 50 Fed. 

Reg. 1182, 1183-1186 (Jan. 9, 1985). . 

The members of the Vinyl Institute are concerned about 

potential redundancy or conflict arising between a generally 

O Q C 
P.39 

- 4 -

applicable HON regulation and the existing vinyl chloride 

NESHAP. Concerns in this regard may be more clearly stated 

after reviewing the situation that might exist with regard to 

specific, emission source types. 

B. HON PROPOSAL AND THE VINYL CHLORIDE NESHAP 

1. PROCESS VENTS 

_rr!,"_3 icnt^ol tschroloc*-' "sed ^.s the basis ^or ,/l?'Crn 

-3~3-T._.r.i_c_.'cr. ._o_r jZ'cz^z^ss .;_*__'C3 '»"cu__c- >^e a. Jb-o con-Cxroj. iSV^i 

achieved, for halogenated streams, by using a thermal 

• _7 

incinerator plus acid gas scrubbing.-

In PVC plants, under the existing vinyl chloride 

standard, vinyl chloride emissions from resin driers are 

2/ The overview of the EPA HON project is quite general. For 

example, in assessing emission reductions of 95% or 98%, we 

assume that the Agency is referring to a 98% reduction from 

uncontrolled emissions. We believe that a 95% or 98% reduction 

of existing emissions is clearly infeasible. 

There are other characteristics of the EPA proposal that 

warrant clarification. For example, we assume, but it is not 

stated, that the percentage reduction figures address routine 

emissions. Episodal or emergency releases should not be part 

of this particular target figure, and EPA should.state so 

explicitly. Similarly, some States will include fugitive 

emissions from piping and related equipment in a storage area 

as part of the storage equipment release figures. Under the 

EPA plan, such emissions are properly handled as equipment 

leaks, not as storage tank emissions. This should also be made 

explicit. 

296 
P.40 

- 5 -

controlled by stripping vinyl chloride from the PVC resin 

before drying. This provision was incorporated into the 

existing vinyl chloride NESHAP due to (1) the technical and 

economic infeasibility of controlling vinyl chloride emissions 

from the large-air volume, high-moisture, low vinyl chloridecontaining drier exhaust stream and (2) the emissions of other 

pollutants associated with combustion.-7 Since the vinyl 

chloride NESHAP was first promulgated 17 years ago, the PVC 

industry's utilized and perfected resin stripping technology. 

below the levels contemplated when the original rule was 

developed. 

A similar situation exists with PVC reactor opening 

emissions. The existing vinyl chloride emissions limit was 

based on the use of a reactor steam sweep and/or clean reactor 

technology. These technologies reduce the potential for vinyl 

chloride emissions before opening the reactor to the 

atmosphere. 40 C.F.R. § 61.64(a). This technology has 

advanced over the years to the point where actual emissions 

today are significantly less than those contemplated by the 

original NESHAP regulations. 

2J For example, increased N0X, CO, C02 levels and energy 

consumption requirements associated with additional 

incineration. 
P.41 

- 6 -

PVC plants utilize combustion technology and/or 

absorber/stripper technology to control all in-process vents to 

the 10 parts per million (ppm) level specified in the existing 

vinyl chloride NESHAP. 40 C.F.R. § 61.64(b). The HON 

currently being considered by EPA could be interpreted to 

prohibit the use of absorber/stripper technology. This would 

result in unproductive expenditures for the PVC industry 

because vinyl chloride emissions are very effectively 

controlled through the use of an absorber/stripper technology. 

recovery and reuse of vinyl chloride and does not produce 

combustion related emissions. 

Resin stripping and reactor steam sweeping might be 

characterized as a process modification rather than end-of-thestack or end-of-the-pipe control. As such, it is consistent 

with EPA's new focus on process modification in lieu of end-ofthe-stack controls. Further, EPA should, whenever possible, 

promulgate standards that require certain emission reduction 

performance rather than specifying the use of particular 

control technologies. Thus, in-process controls, su'ch as 

slurry stripping and reactor purging, should be considered 

MACT, instead of requiring add-on incineration or similar 

control devices. 
P.42 

- 7 -

2. WASTEWATER TREATMENT OPERATIONS 

The vinyl chloride NESHAP currently requires that 

inprocfiss wastewater be stripped to 10 ppm or less for vinyl 

chloride.'40 C.F.R. §.61.65(b)(9). This is comparable to the 

benzene wastewater NESHAP in which the HON is based on 

wastewciter treatment. Therefore, the existing vinyl chloride 

standard meets control technology candidates that EPA has 

identified as a basis for establishing MACT criteria. 

3. STORAGE 

The EPA proposal would require approximately 95% 

pollutant control, with the exact level of control depending on 

individual chemical properties. The vinyl chloride industry 

exceeds the 95% control criteria, since vinyl chloride is 

stored in unvented pressurized tanks. Indeed, except for 

emergency relief discharges, the vinyl chloride standard states 

that "there is to be no discharge to the atmosphere from any 

relief valve on any equipment in vinyl chloride service." 

40 C.F.R. § 61.65(a); see also § 61.65(b)(5)(similar limitation 

4/ 

on manual venting). 

4/ "'In vinyl chloride service' means that a piece of 

equipment either contains or contacts a liqu.id that is at least 

10 percent vinyl chloride by weight or a gas that is at least 

10 percent by volume vinyl chloride . . . ." 40 C.F.R. § 

61.61(1). 
P.43 

- 8 -

4. TRANSFER OPERATIONS 

Under the EPA proposal, the Agency envisions a 90% 

reduction in hazardous air pollutant emissions resulting from 

transfer operations following the same guidelines that would 

apply to process vents. The current vinyl chloride standard 

already addresses this situation. 40 C.F-R- § 61.65(b)(1). 

Emissions from any loading or unloading lines in vinyl chloride 

service are to be minimized by purging the lines and venting 

"-__'•• "•**5riicTr=d ""nv"1 — hicrids thrcuch a control 3vst3_r. '••"hose 

exr.aus" gas aoes noc exceea 10 ppm vinyi cnioriae. 

5. EQUIPMENT LEAKS 

Equipment leaks would be addressed by EPA through the 

Regulatory Negotiation process. In any event, we note that 

equipment leaks (fugitive emissions) are addressed extensively 

under the vinyl chloride NESHAP. 40 C.F.R. § 61.65(b). We 

certainly understand the Agency's desire to apply the equipment 

leak provisions developed in the Regulatory Negotiation process 

to facilities not covered by the vinyl chloride NESHAP. Under 

this strategy, however, either the vinyl chloride NESHAP or the 

Regulatory Negotiation provisions could apply, not both. The 

overlap or redundancy created by applying both sets of 

requirements would be unnecessary, confusing and 

counterproductive. 

300 
P.44 

- 9 -

C. COORDINATING GENERIC AND SPECIFIC STANDARDS 

The Vinyl Institute requests that EPA carefully 

consider the requirements of the existing vinyl chloride NESHAP 

and the technologies currently employed and developed by the 

vinyl industry in .evaluating appropriate MACT control. EPA 

should allow equivalent control technologies to.avoid 

redundancy and duplicity of generic MACT requirements with 

existing vinyl chloride NESHAP requirement. 

MACT is defined under Section 112(d)(3) for existing 

standards as controls equivalent to the average of those 

presently employed at the most tightly controlled existing 

facilities.- Under this approach, the average emission 

5/ MACT is broadly defined in Section 112(d)(3) as follows: 

The maximum degree of reduction in emissions that is 

deemed achievable for new sources in a category or 

subcategory shall not be less stringent than the 

emission control that is achieved in practice by the 

best controlled similar source, as determined.by the 

Administrator. Emission standards promulgated under 

this subsection for existing sources in a category or 

subcategory may be less stringent than standards for 

new sources in the same category or subcategory but 

shall not be less stringent, and may be more stringent 

than — • 

(A) the average emission' limitation achieved by 

the best performing 12 percent of the existing 

sources (for which the Administrator has 

emissions information), excluding those sources 

that have, within 18 months before the emission 

standard is proposed or within 30 months before 

such standard is promulgated, whichever is 

later, first achieved a level of emission rate 
P.45 

- 10 -

limitation of the best 12% of existing sources or the best 

performing 5 sources, depending on industry size, will indicate 

that the vinyl chloride NESHAP-mandated technology is MACT. 

For example, the vinyl industry is not aware of any.plans that 

control downstream emissions from resin other than through 

stripping, before the drier. 

Part of EPA's policy in implementing the Clean Air Act 

Amendments of 1990 is referred to as E3. By this, the Agency 

while supporting strong and sustainable economic growth and 

sound energy policy.- The use of process modifications to 

achieve emission reductions, instead of end of the stack 

incineration, is consistent with EPA's energy conservation and 

"cleanest, technologically feasible manner" policy.-7 

5/(...continued) 

or emission reduction which complies, or would 

comply if the source is not subject to such 

standard, with the lowest achievable emission 

rate (as defined by section 171) applicable to 

the source category and prevailing at the time, 

in the category or subcategory for categories 

and subcategories with 3 0 qr more sources, or 

(B) the average emission limitation achieved by 

• the best performing 5 sources (for which, the 

Administrator has or could reasonably obtain 

emissions information) in the category or 

subcategories with fewer than 3 0 sources. 

SJ See EPA Office of Air and Radiation, Implementation 

Strategy for the Clean Air Act Amendments of 1990, at 7 and 

Figure 1 (Jan. 15, 1991). 

7/ Id. at 7. 
P.46 

- 11 -

Moreover, the policy explicitly encourages market-based 

principles and other innovative approaches, such as 

"performance-based standards. "-/ 

The Vinyl Institute endorses this approach. The 

existing process and emission performance standards contained 

in the current yinyl chloride NESHAP standard are consistent 

with-this policy. The Vinyl Institute would be happy to 

provide additional detail to the Committee or EPA. 

Respectfully submitted, 

/"' " -kx.^. y • -•--

 i/(- - *.•*. 3 

Peter E. de la Cruz 

Associate General Counsel 

OF COUNSEL: 

Jerome H. Heckman 

Keller and Heckman 

1150 17th Street, N.W. 

Washington, D.C. 20036 

(202) 956-5600 

January 30, 1991 

8/ Id. at 7 
P.47 

STATEMENT OF 

W. C. HOLBROOK 

ON BEHALF OF 

THE CHEMICAL MANUFACTURERS ASSOCIATION 

BEFORE THE 

NATIONAL AIR POLLUTION CONTROL 

TECHNIQUES ADVISORY COMMITTEE 

ON THE 

HAZARDOUS ORGANIC 

NATIONAL EMISSION STANDARDS 

FOR HAZARDOUS AIR POLLUTANTS 

JANUARY 30, 1991 

305 
P.48 

CHEMICAL MANUFACTURERS ASSOCIATION 

TESTIMONY BEFORE THE NATIONAL AIR POLLUTION CONTROL 

TECHNIQUES ADVISORY COMMITTEE ON 

EPA'S PROJECT TO DEVELOP NATIONAL EMISSION STANDARDS 

FOR HAZARDOUS AIR POLLUTANTS (NESHAP) 

' FOR HAZARDOUS ORGANICS 

My name is W.C. Holbrook. I am Director of Environmental Affairs 

for the Chemical Group of BF Goodrich. I am speaking to you today on 

behalf of the Chemical Manufacturers Association (CMA) where I serve as 

a member of the Air Toxics Work Group. CMA is a nonprofit trade 

association whose member companies represent over 90 percent of the 

production capacity of basic industrial chemicals in the United 

States. We are pleased to have this opportunity to present our views 

to the National Air Pollution Control Techniques Advisory Committee. 

CMA played an active role in shaping the new Section 112 

provisions in the Clean Air Act Amendments of 1990 as they relate to 

development of Maximum Achievable Control Technology (MACT) standards. 

CMA was a strong supporter of the MACT concept and believes it 

represents an effective way of achieving significant reductions in 

emissions of hazardous air pollutants. 

CMA further supports the efforts at EPA to set MACT standards for 

sources of hazardous air pollutants in the chemical manufacturing 

industry through a hazardous organic NESHAP, otherwise known as the 

"HON." We believe such an approach is a practical way of regulating a 

significant number of sources of hazardous air pollutants within the 

time frames specified in the Clean Air Act Amendments. However, CMA 

has several suggestions for strengthening EPA's approach for setting 

MACT standards under the HON project which we would like to summarize 

today. Our suggestions fall into the following general areas: 

1) EPA plans to apply the HON to almost 400 different chemical 

manufacturing processes. EPA must be careful to take into 

account unique differences among these processes when 

developing standards. 

2) EPA has identified possible control technology approaches 

for MACT based on recent rulemakings for the Synthetic 

Organic Chemical Manufacturing Industry (SOCMI). CMA 

encourages EPA to retain features in these recent regulations 

that provide flexibility to facilities to use different types 

of control technologies to comply with the regulations. 

Furthermore, CMA encourages EPA to develop a straightforward 

process for demonstrating equivalent approaches that may be 

developed in the future. 

306 
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P.50 

W.C. Hol'brook Testimony 1/30/91 

Hazardous Organic Nat'l Emission 

Standards fcr Hazardous Air Pollutants 

Page 5 

identifying the need for separate control requirements. We will share 

the results of our efforts with EPA as soon as they are available. 

Equipment Leaks 

CMA was a key participant in the recently concluded negotiations 

to develop MACT standards for equipment leaks. CMA supports the 

equipment leaks regulation as drafted by the Negotiating Committee. 

Therefore, the remainder of our comments today are limited to EPA's 

approach for regulating the remaining four source types. 

Process Vents 

CMA urges EPA to consider incorporation of flexibility in the MACT 

standard, both from control technology and control efficiency points of 

view. The recently promulgated New Source Performance Standards for 

SOCMI Distillation and Air Oxidation processes provided flexibility to 

comply using a variety of combustion and recovery techniques. CMA 

believes that such flexibility is a critical element in MACT standards, 

especially as they apply to existing sources where a wide variety of 

effective control technologies are already in place. Failure of the 

MACT standards to allow for use of different types of control 

technologies would in some cases require facilities to replace existing 

control equipment with new equipment at significant cost and no 

resulting environmental benefit. Therefore, CMA encourages EPA to 

retain in the MACT standards for process vents the features in these 

recent rulemakings that provide for use of different types of control 

technologies. 

In addition, the MACT standards should provide opportunity and 

incentive for facilities to apply new, innovative control 

technologies. This can be accomplished by providing flexibility within 

the standards themselves and by establishing a straightforward process 

for facilities to demonstrate that new approaches developed in the 

future are equivalent to the standards. 

In selecting MACT for process vents, the control device efficiency 

should not be the sole criteria. As directed by Congress in Section 

112(d)(2) of the Clean Air Act Amendments, EPA should consider other 

factors such as overall environmental impact, recovery and recycle, and 

multi-media impact. For example, catalytic incinerators operate at a 

lower temperature than thermal incinerators, therefore they generate 

less NOx emissions. NOx emissions are a contributor to ozone 

formation. EPA should weigh the advantages of significantly lower NOx 

emissions against slightly lower emissions of hazardous organic 

emissions when identifying control technology candidates for MACT. 

308 
P.51 

W.3. Holbrook Testimony 1/30/91 

Htzardous Organic Nat'l Emission 

--tandara: fcr hczaracus fiir Pollutants 

'ra,??* -a 

Similarly, if a stream can be recycled to the process, by 

recovery techniques such as adsorption, absorption or condensation, 

than such practices should have preference over disposal techniques 

such as incineration - even if the control efficiency falls somewhat 

short of that achieved by incineration. 

Likewise, if a process can be so modified that the formation of a 

pollutant is prevented, instead of destroying or capturing the formed 

pollutant, then the prevention should be favored over control. 

Prevention of formation of an air pollutant avoids the problem 

associated with the disposal of wastewater and/or solid waste generated 

in controlling that air pollutant. 

The second critical element of the MACT standard setting process 

for process vents is the development of applicability criteria. EPA 

incorporated such criteria in its recently promulgated NSPS for SOCMI 

Distillation and Air Oxidation operations. Specifically, the concept 

of Total Resource Effectiveness in these regulations is an effective 

me.ans of accounting for the characteristics of a vent stream in 

determining whether additional controls are required. CMA urges EPA to 

retain these concepts when developing the applicability criteria for 

th'. MACT standards for process vents. 

CMA has one final point related to process vents. It is not clear 

if the percent control efficiency is to be measured on the basis of all 

hazardous air pollutants combined or each specific pollutant. CMA 

believes that the control efficiency basis should be all hazardous air 

pollutants combined for several reasons. First, the Clean Air Act 

Amendments of 1990 require EPA to develop MACT standards for categories 

of major sources not for specific pollutants. Second, it may be 

difficult to achieve a single percent control efficiency for each 

individual pollutant, especially those with low inlet concentrations, 

due to variability in chemical and physical properties. 

Wastewater Treatment 

In selecting MACT standards for wastewater treatment units, CMA 

believes that it is important that the EPA utilize a database which 

represents wastewater treatment practices and emission potential for 

the variety of chemical manufacturing processes that are expected to be 

covered. EPA has not had occasion to develop such a data base for 

wastewater treatment unit operations as they have for other chemical 

manufacturing industry sources such as process vents, equipment leaks, 

and storage tanks which have been previously regulated under New Source 

Performance Standards. A representative data base is essential if EPA 

is to properly account for unique differences between different 

chemical manufacturing processes when developing MACT standards for 

wastewater treatment. 

309 
P.52 

W.C. Holbrook Testimony 1/30/91 « 

Hazardous Organic Nat'l Emission 

Standards i_: Hazeraou_ Air Pollutant: 

Page 5 

As with process vents, the control strategy for wastewater 

treatment sources should be flexible to take into account the wide 

range of wastewater treatment plant designs. For example, while steam 

stripping is one technique for reducing emissions from wastewater 

treatment systems, the standards should allow other methods that 

achieve the same reductions. 

The applicability criteria for the MACT standards for wastewater 

treatment are particularly critical. Process conditions, such as flow 

rate, temperature, and concentration of wastewater constituents should 

be included as applicability criteria. In addition, the standards 

should take into account the volatility of hazardous air pollutants in 

wastewater streams. One method for accounting for volatility would be 

to establish minimum concentration levels requiring control as a 

function of volatility, i.e, vapor pressure and vapor liquid 

equilibrium behavior such as Henry's Law constant. Under this 

approach, streams containing pollutants with high volatility would 

require controls at lower concentrations than would streams containing 

pollutants with low volatility. 

CMA offers one final point relating to the applicability criteria 

for wastewater treatment standards. The test method that EPA provides 

for determining concentration of wastewater components will have a 

significant impact on applicability determinations. CMA has previously 

provided comments on EPA's proposed Reference Test Method 25D which is* 

expected to be applied to wastewater stream measurements. CMA would 

like to continue to work with EPA as it completes development of this 

test method. 

Storage 

As in the case of process vents, CMA recommends that the MACT 

standard for storage tanks provide for flexibility in control 

technologies that achieve the same level of control. In addition, the 

applicability criteria should be similar in concept to that provided in 

the NSPS for Volatile Organic Liquid Storage. Specifically, the need 

for controls should depend both upon the size of the tank and the 

volatility of the hazardous pollutants being stored. 

Transfer Operations 

Control technology flexibility is equally important for the MACT 

standards for transfer operations as for process vents and storage 

tanks. In addition, CMA suggests that the applicability criteria for 

transfer operations take into account the volatility of-.the***-haza-rdous 

pollutant being transferred in addition to those criteria already 

incorporated into the recently promulgated NESHAP for Benzene Transfer 

Operations. 

310 
P.53 

W.C. Holbrook Testimony 1/30/91 

Hazardous Organic Nat'l Emission 

Standards for Hazardous Air Pollutants 

Pjg«s 6 

Sources Covered Under Existing NESHAP Regulations 

CMA member companies currently subject to NESHAP regulations for 

ben_:ene and vinyl chloride are concerned about the duplicative 

potential of MACT regulations. In establishing the HON regulations, 

EPA should assure that confusion and duplication does not occur. For 

example, EPA should consider sources that are subject to existing 

NESHAP requirements for benzene or vinyl chloride that have controls 

that are at least as stringent as MACT requirements to be in 

conformance with MACT. Furthermore, EPA should avoid imposing * 

duplicative monitoring and recordkeeping requirements on sources 

subject to benzene and vinyl chloride NESHAP requirements where such 

requirements provide no environmental benefit. In the event that EPA 

chooses to apply MACT to sources already covered by existing NESHAPs, 

CMA believes that EPA should repeal the existing NESHAP regulations. 

CMA looks forward to working with EPA as they continue development 

ni '-.he HON regulations. 

This concludes my remar;.:;. 1' 11 be r.appy zz answer any questions. 
P.54 

DISCUSSION 

Committee member Ralph Hise (Advanced Technologies 

Management) commented that EPA should coordinate HAP and NO 

standards, as decreased HAP emissions may lead to increased NO 

emissions. Jim Weigold (EPA) concurred that such coordination 

was important. 

Committee member John Pinkerton (NCASI) asked CMA to 

elaborate on wastewater treatment, inquiring whether volatility 

should be a criteria. Mr. Holbrook replied that the volatile 

HAPs result in greater emissions than non-volatile HAPs. 

Existing benzene and vinyl chloride regulations should also be 

considered. Concentration levels are also important criteria; 

CMA recommends concentration cutoffs of at least 10 ppm. 

Mr. Pinkerton also asked whether the proposed Reference Test 

Method 25D considered differences in volatility. Penny Lassiter, 

EPA, replied that parameters were set to effect removal of the 

volatile T___T_3__"*'___Ls

 ,*v*. "*••"' -".CiS__"*".c_r_ ~-r_s_"_ ~c_t1_r.2r_i_.3d •_.i",3'-' ""CC 

_czi'."."_v _._*. z*_L-jlccric2.i 3*'*3T:arr.s snculd 'zs -___T-,i.-:c2c_. is "cST.av.;r_r.3r 

-reacmenr regulations ^culd result i.~ dispersemenr of VOCs into 

biological wastewater treatment systems. Mr . Pinkerton added 

that the CHEMDAT.7 model may be an answer. Mr . Holbrook replied 

that CMA is exploring these issues under SARA 313 emission 

reporting. He also added that enclosing wastewater treatment 

systems and ducting to control devices may be more cost effective 

than other methods . 

Vivian Mclntire asked whether there was a difference between 

reactants and raw materials on the CMA list of organic HAPs . 

M s . Mclntire also asked whether solvents were regulated. 

M r. Rosensteel replied that solvents were not regulated. 

M r . Holbrook requested clarification from EPA regarding whether 

there is any difference between reactants and raw materials . 

M r . Rosensteel replied that use of a HAP is covered only if it is 

used to produce a SOCMI chemical , but not if it is used to 

produce a non-SOCMI chemical. One exception to this is that the 

equipment leaks negotiated regulation does cover seven specific 

non-SOCMI processes.