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OAR Box 1669 

Prepped by Charmelle Mathews 

Document Number: 

Docket Number: 

A-98-13 

Printed 9/23/2008 9:36:49 AM Sheet 71 of 110 
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0 

TO: 

FROM: 

DATE: 

A 9 8 13 

MEMORANDUM 

Steve Shedd 

U.S. EPA/OAQPS/ESD/WCPG 

ESD Project No. 96/05 

r::: 

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•:;>A •',!'•. POf'Kl-'r 

Bernd Haneke and Greg LaFlam 

Pacific Environmental Services, Inc. (PES) 

February 3,1998 

SUBJECT: First Roundtable Meeting on the P-MACT for Organic Liquids Distribution 

(Non-Gasoline) Facilities 

I. Purpose 

The purpose ofthis meeting was to bring together the project Work Team, including the 

EPA and its contractor, to discuss information and issues pertinent to the development of 

presumptive MACT (P-MACT) for organic liquids distribution facilities. This work is in support 

ofthe development of national emission standards for hazardous air pollutants (NESHAP) for the 

Organic Liquids Distribution (non-Gasoline) source category. 

H. Location and Date 

U.S. Environmental Protection Agency 

Environmental Research Center Building, Classroom No. 2 

Research Triangle Park, NC 27711 

January 21,1998, 9:00 am to noon 

in. Participants 

Bill Beck, Mobil Corporation 

Ted Cromwell, Chemical Manufacturers Association 

John Dege, Dupont 

Joel Fazzio, International Matex Tank Terminals 

Joe Federowicz, EMCO Wheaton DTM, Inc. 

Bemd Haneke, Pacific Environmental Services, Inc. (PES) 

Cliff Harvison, National Tank Truck Carriers 

Jay Helms, PES 

Greg LaFlam, PES 

Denise Michelson, ARCO Pipe Line Company 

Norman Morrow, Exxon Chemical Americas 
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Memo - 1st Roundtable Summary 

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Brian Neville, Independent Liquid Terminals Association 

Robert Norton, PES 

Karin Ritter, American Petroleum Institute 

Steve Shedd, U.S. Environmental Protection Agency 

John Stock, EMCO Wheaton DTM, Inc. 

Gary Wilson, Marathon Oil Company 

IV. Discussion 

EPA Introduction 

After the participants introduced themselves, Steve Shedd began the discussion by 

emphasizing that this meeting would be held in the form of an open discussion, and was not 

going to be merely a presentation by the EPA or PES. Greg LaFlam referred to a handout of 

preliminary P-MACT information and issues distributed before the meeting (Enclosure 1), and 

stated that the meeting would follow the structure ofthe handout. He said that the following key 

topic areas would be presented, and questions or discussion would be welcome at any time. 

Standards Development Process 

Affected Sources 

Emissions and Controls 

Issues/Questions 

Next Steps 

From this point, Mr. LaFlam proceeded by beginning a discussion ofthe standards development 

process. 

Standards Development Process 

Mr. LaFlam addressed the fact that presumptive maximum achievable control technology 

(P-MACT) is a short-term judgment of what the "MACT floor" of control should be, and 

provides a basis from which the NESHAP will be developed. He further emphasized that 

P-MACT is not a regulation, but is offered as guidance and information to entities making 

case-by-case MACT decisions. 

Mr. LaFlam and Mr. Shedd presented a brief discussion of statutory requirements, which 

included definitions of several key terms. Following this discussion, Cliff Harvison stated that 

uniformity of truck loading equipment was needed between the States. He pointed out that, for 

example, a tank truck from Texas would have to be able to unload in Michigan, and be able to 

use the same equipment nationwide. He pointed out that facilities with different hardware could 

become a nightmare for truck operators. Mr. Shedd replied that the industry was best suited to 
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work out the details of what hardware would be needed to make tank trucks compatible with 

regulated facilities, but that the EPA would address the issue if it became necessary. 

The project schedule was addressed next by Mr. LaFlam, who pointed out that there was 

a potential for two more roundtable meetings. Bill Beck asked what the schedule for the EPA's 

planned industry survey was going to be. Mr. Shedd responded that the survey will most likely 

be sent out to a limited number of facilities in March, but the results will not be able to be 

tabulated before June/July 1998. Norman Morrow pointed out that the complexity ofthe draft 

survey indicates that it will require in excess of 60 days for facilities to complete a response. Mr. 

Shedd pointed out that the results ofthe survey will likely not be fully analyzed in time for 

incorporation into the P-MACT decision. Brian Neville asked whether P-MACT would have a 

formal comment period, to which Mr. Shedd responded that the draft P-MACT document will be 

an expanded version ofthe preliminary P-MACT information being discussed at this meeting, 

and will be available for review before it is finalized. Also, P-MACT will be posted on the 

EPA's Technology Transfer Network (TTN) bulletin board where it will be available to any 

interested party. 

Affected Sources 

Mr. LaFlam introduced this topic by pointing out that the initial source category 

description is still quite general, and additional work will be required to narrow it down. He said 

that included in this source category would be activities associated with the storage and 

distribution of organic HAP liquids other than gasoline, at sites that serve as distribution points 

from which organic liquids may be obtained for further use and processing. For oil and gas 

production, the category will include only petroleum facilities that handle and distribute 

hydrocarbon liquids after the point of custody transfer. Mr. LaFlam also stated that the EPA and 

PES will be looking at certain petroleum and crude oil storage and transmission facilities as 

potential sources for regulation. 

The issue ofthe extent of coverage ofthe standards was raised. John Dege suggested that 

the source category should only include sources not already covered, or due to be covered, by 

other MACT rules. Mr. Morrow asked if the source category would be limited to independent 

facilities, or if it would go beyond that. Mr. Shedd replied that collocated distribution facilities 

would also be evaluated. He stated that the other MACT rules cannot simply be listed as areas 

for exclusion; specific language needs to be included to define the coverage of each rule. Mr. 

Dege agreed that the Organic Liquids Distribution NESHAP would require language that takes 

into account other NESHAP. 

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Mr. LaFlam briefly discussed the types of facilities that might be included in this source 

category. These included: 

1. Pipeline facilities 

2. Stand-alone terminals 

3. Collocated terminals 

4. Compounding/packaging facilities. 

Mr. Dege asked how pipeline facilities would be covered, mentioning that one party may 

own a pipeline that is operated by another party. He felt that the term "owner or operator" was 

useful in covering these cases. He also asked if pipelines that connect local facilities would be 

addressed. Mr. Dege gave an example of an 8-mile pipeline connecting a manufacturing facility 

to a terminal, asking if a pipeline ofthis nature would be covered. Mr. Morrow expressed 

agreement that the issue of pipelines would have to be clarified. Mr. Shedd noted that the 

EPA/PES team for this project is just learning about the pipeline industry, and they will be 

conducting a detailed review of pipeline operations as the project proceeds. 

Mr. Dege commented that the terminology "stand-alone terminal" might not be adequate 

to cover the independent distribution facilities. He mentioned that various scenarios of 

ownership and operation are possible, which precluded the use ofthe phrase "stand-alone." He 

suggested that the proper terminology might be "separate owner/operator facilities." 

Mr. LaFlam stated that the EPA has very little information about collocated distribution 

facilities and how they interact with their producing facility (refineries or chemical plants). 

Further information is needed, and it is hoped that the Work Team can help provide this 

information. 

Mr. Harvison noted that a good organization to contact for compounding/packaging 

plants would be the National Association of Chemical Distributors (NACD), based in 

Washington D.C. He further noted that the NACD is involved with small packaging operations, 

and has regional/local distribution. A roundtable participant asked if the packaging of small 

bottles would be covered by this NESHAP, and if there would be a size cutoff. Mr. Shedd 

responded that this had not yet been determined. 

Mr. Dege asked how general and hazardous waste was going to be addressed, as much of 

this is covered by the Resource Conservation and Recovery Act (RCRA). Mr. Shedd answered 

that this had not yet been looked at, but this MACT rule would not attempt to cover the 

operations addressed under RCRA. 

Mr. Morrow mentioned that the draft industry survey is too broad and is not clear enough 

to provide concise, useful answers. He stated that the draft survey as currently constructed would 

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collect data from every manufacturing facility within the United States. On similar lines, Mr. 

Dege mentioned that for every question asked about pipelines, at least 14 additional questions 

would surface. 

Mr. LaFlam next addressed the "Organic Liquids Distribution Facilities Industry," noting 

that the included industry diagram (page 11 in Enclosure I) was created to provide a mental 

image ofthe industry. He also stated that the diagram would need to be refined as more is 

learned about the source category. 

The industry profile table based on SIC codes was briefly discussed. No specific 

discussion was brought about by the SIC code listing of pipeline and stand-alone terminals. 

Denise Michelson noted that SIC Code 13 (Oil and Gas Extraction) applies to petroleum 

products before the point of custody transfer, which are excluded from the OLD source category. 

Upon discussing the compounding and packaging facilities, Mr. Dege asked if pharmaceutical 

bottling would be covered. His opinion was that the Pharmaceuticals MACT rule would likely 

cover this type of operation. 

Mr. Shedd mentioned that the EPA requires information regarding rail transportation of 

organic liquids. Mr. Harvison noted that the two primary trade organizations for this are the 

Association or American Railroads (AAR) and the Railway Progress Institute (RPI). He further 

noted that railcars are owned by the shipper and have dedicated service. Also, railcars will haul a 

limited number of chemicals ofthe same family on an average of 6-7 round trips/year. On the 

other hand, tank trucks will do up to 3 round trips a week and carry a variety of chemicals in the 

same delivery tank. 

Mr. LaFlam briefly discussed the processes and equipment that might be covered by the 

NESHAP; among these are storage tanks, liquid transfers of truck, railcar, pipeline, marine 

vessel, equipment leaks, and wastewater collection and treatment. Mr. Beck stated that he 

thought the definition of "organic liquid" in this rule should be limited by vapor pressure. He 

further stated that the survey should limit the data request for liquids by a vapor pressure cutoff. 

The issue of area versus major source determination was brought up and Mr. Shedd responded 

that an area source determination (for health or environmental impact) needed to be made before 

area sources could be eliminated from consideration. 

Regarding which liquids should be covered, Mr. LaFlam listed synthetic organic HAP 

chemicals, petrochemicals, crude oil or other unrefined petroleum liquids, refined petroleum 

(non-gasoline), and other pure liquids or mixtures with HAP content. Mr. Beck mentioned that 

the §112(k) Urban Air Toxics study should be reviewed to see what was considered. 

Regarding the table ofthe "Top 20 Organic HAP Chemicals by Volume (1993-96)," the 

EPA pointed out that information is required on the units of these chemicals, as well as a 

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determination ofthe major chemicals that should be addressed. Mr. Morrow mentioned that 

mixtures should be addressed in this table. 

Mr. LaFlam described the model industry profile, based on the Independent Liquid 

Terminal Association's (ILTA) 1997 directory. He said that no model industry profile had been 

developed for pipeline, collocated, or compounding and packaging facilities due to a lack of 

information. Mr. Harvison stated that a good source of infonnation for pipelines was the 

American Petroleum Institute (API) and the Department of Transportation's (DOT) Office of 

Pipeline Safety (Rich Felder, contact) within the DOT's Research and Special Programs 

Administration (RSP A). Mr. Harvison named Al Roberts (Associate Administrator of RSP A) as 

a specific contact within. 

Emissions and Controls 

Mr. LaFlam briefly stated that emissions calculations utilizing parameters such as 

volume, loading method, and vapor pressure were going to be made for model plants in the 

source category. The HAP content of organic liquids would also need to be known to quantify 

emissions. 

Sources of information for the incomplete table titled "Organic Liquids with Partial HAP 

Content" were requested by Mr. Shedd and Mr. LaFlam. Mr. Morrow said that DOT tracks 

these, upon which Mr. Harvison responded that this was no longer the case. Producers now are 

holding this type of data. 

Mr. Beck questioned why gasoline was included in the table, to which Mr. Shedd 

answered that it was purely for purposes of comparison. Mr. Shedd stated that the HAP content 

is the real issue in deciding on emission potential, to which Mr. Dege asked what vapor pressure 

cutoff would be appropriate. Mr. Beck added that there should be a HAP content limit on the 

liquids included for coverage. Mr. Morrow agreed with this, emphasizing that many organic 

liquid streams contain HAP in minute quantities (<1 ppm) and that there is no value in collecting 

this information. Mr. Shedd responded that the EPA and PES would require good boundaries 

from the industry, and that the survey may be modified to address these values. 

One participant questioned the inclusion of wastewater in the table, since off-site 

wastewater is already covered by a separate NESHAP. Mr. Shedd responded that off-site 

operations would not be considered for coverage by the OLD rule. 

Mr. LaFlam then described the models and methods that will be utilized to calculate 

emissions from facilities. Among these are AP-42, the TANKS3.1 program, the WATER8 

program for estimating emissions from wastewater, and various other publications including 

"Fugitive Emission Factors for Crude Oil and Product Pipeline Facilities," by API. Karin Ritter 

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mentioned that API is developing its own wastewater emissions modeling software as an 

alternative to WATER8. She furthermore asked if a table was being worked out showing State 

and Federal regulations pertaining to the P-MACT. Mr. Shedd responded that such a summary is 

being developed by PES. 

Examples of control techniques for storage tanks, liquid transfer/loading, equipment leaks 

and wastewater were then described by Mr. LaFlam. Mr. Morrow asked if covered liquids would 

include liquefied natural gases. Mr. Shedd replied that these liquids are intended to be covered. 

Mr. Morrow said that pressure vessels and specific transfer methods for such liquids would need 

to be recognized. Joel Fazzio then stated that it would not be feasible to route vapors from No. 2 

and No. 6 fuel oil operations to control devices because of their low vapor pressures. Mr. Beck 

then reiterated the need for vapor pressure cutoffs to eliminate such low vapor pressure liquids. 

A discussion commenced regarding the current control levels on the Federal level. Mr. 

Beck mentioned that the listing in the EPA's presentation did not reflect current control levels as 

some ofthe rules have not been promulgated. The rules not promulgated included the 

Miscellaneous Organic NESHAP (MON), the Storage Vessel NESHAP (subpart WW), and the 

Oil-Water Separator NESHAP (subpart VV). It was also mentioned that not all applicable rules 

had been listed; among these were the Off-Site Wastewater NESHAP, the 112(k) Urban Air 

Toxics Rule, the Benzene Wastewater Storage and Transfer NESHAP, and the 

Consumer/Commercial Products NESHAP. 

Future facility/plant visits were also discussed. Mr. Morrow asked what facilities the 

EPA had visited, upon which he was informed that two facilities in New Jersey and one in 

Philadelphia had been surveyed by the EPA/PES team. 

A discussion ofthe survey prompted Mr. Beck to state that in his opinion a separate 

roundtable discussion is required to prevent the survey from being useless as a data gathering 

tool. Mr. Shedd then requested a commitment by the group to review the ICR, and to develop 

questions and comments for revising the document. He further requested that comments and 

questions be prepared by early February, so that a meeting could be organized. Ms. Ritter 

suggested the week of February 9th, and February 12th was tentatively selected as the meeting 

date. 

One technical question brought up during the roundtable regarding the survey consisted 

of Mr. Morrow asking how to address tanks that frequently change service. He cited the example 

that some tanks may hold a high vapor pressure liquid for only 1 week out ofthe year. Mr. 

Shedd responded that this issue would be addressed during work on the ICR survey. He then 

asked if any participant was aware of current studies being performed on emissions from these 

types of operations. No mention of any current studies was made. 

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A discussion then ensued regarding the portion ofthe P-MACT covering State and local 

rules. Mr. LaFlam suggested, and Mr. Dege agreed, that the rule summaries presented here 

might be misinterpreted. Mr. Morrow mentioned that the rules had been tabulated before. Ms. 

Michelson inquired about rules covering equipment leaks, to which Shedd responded that PES 

would be reviewing this type of information. 

Mr. Dege stated that he would never agree with SOCMI data and emission factors. Ms. 

Ritter remarked that API may have information regarding emissions from transfer facilities and 

operations. Mr. Shedd stated that he would share information regarding State rules and 

regulations with the industry in February. 

Issues and Questions 

Mr. Shedd inquired as to the impact of standards dealing with other media (i.e., water, 

solid waste) on the P-MACT process. Mr. Beck proposed that the EPA and PES prepare a list of 

organic liquid limitations and exclusions based upon the following criteria: 

1. Vapor Pressure cutoffs 

2. HAP percentage cutoffs 

3. Other rules that may overlap or impact the OLD NESHAP 

4. Loading of pressurized liquids. 

Mr. Beck suggested that this list be used to limit the industry survey. There was some discussion 

on the issue ofthe survey being too large and that, if left as is, it could produce excess 

information that would not be useful. 

Next'Steps 

Next steps in the P-MACT process as discussed during the meeting included holding a 

meeting to discuss the industry survey, finalizing and mailing ofthe survey, and planning future 

site visits. Further development ofthe draft P-MACT was also addressed, at which time Mr. 

Dege mentioned that he thought it was a waste of time, money, energy, and taxpayers' dollars. 

Mr. Beck replied that this might be the case for those not understanding the true nature ofthe PMACT process. Ted Cromwell stated that he thought the roundtable meetings should be longer 

so as to cover more information. Mr Shedd mentioned that the minutes ofthe roundtable would 

be posted on the EPA's TTN bulletin board. 

V. Pertinent Issues 

During the meeting, various issues regarding the industry survey and the entire OLD 

NESHAP development were raised that the EPA considers to be important and believes need to 

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be investigated and discussed further by the Work Team. These principal issues are summarized 

below: 

ICR Issues 

1. Define the specific facilities that need to report data. 

2. Are separate surveys needed for different types of facilities (industry subcategories)? 

3. Should limitations be placed on the liquids to be reported (i.e., vapor pressure or HAP 

content cutoffs)? 

4. Consider a cutoff of total facility emissions (i.e., <50 percent of major source levels). 

Thus, smaller facilities would not have to respond. 

5. Can the survey be simplified by allowing respondents to group data or provide summaries 

of certain information? 

6. How should a facility report on tanks that have variable storage; for example, storing a 

particular HAP liquid for a very short time during the year? 

OLD NESHAP Issues 

1. How should the source category be defined (i.e., which facilities should be covered)? 

2. Issues regarding hazardous waste and liquids controlled by RCRA. 

3. Local pipelines and their inclusion in the OLD rule. 

4. Define terms such as "stand-alone," "collocated," "pipeline," etc. 

5. Will area sources be covered by this NESHAP? 

6. How many facilities are small businesses? 

7. Develop an understanding of State/Federal rules that already regulate sectors ofthe liquid 

distribution industry. 

8. Loading of liquefied natural gases/LPG is mostly excluded from other rules; will it be the 

same here? 

9. Similar sources covered by other MACT rules need to be addressed and clarified. 

Identification of any unregulated emission sources within those MACT categories must 

be made, along with a decision on possible coverage by the OLD rule. 

10. Impacts of standards dealing with other media on the OLD NESHAP. 

11. Are compounding/packaging operations a separate type of facility that needs to be 

understood and regulated? Ifso, they need to be defined, emissions estimated, etc. 

T