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OAR Box 1878 

Prepped by Charmelle Mathews 

Document Number: 

128) ll-E-12 

Docket Number: 

A-90-19 

Printed 11/28/20081:21:26 PM Sheet 128 of 145 
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A-90-19 

ll-E-12 

UNITED STATES ENVIRONMENTAL PROTECTK 

Office of Air Quality Planning and Stancu.uo 

Research Triangle Park, North Carolina 27711 

2 6 JAN 1990 

DEC 181992 ' "' ; i - i 

MEMORANDUM CPAAiR:30C'\£l 

SUBJECT: Meeting with Chemical Manufacturing Association (CMA) 

on January 30, 1990 

FROM: Bob Rosensteel 

TO: See Below 

The meeting will be held in the 10th Floor Conference Room of the North 

Carolina Mutual Building, from 1:00pm to 4:00pm. The items to be discussed at 

this meeting are: 

1. Introductions - Bob Rosensteel 

2. Title III Implementation - Bob Kellam 

Hazardous Organic NESHAP -

Technical Approach 

a. Overview - Oebbie Stackhouse 

b. Process Vents - Bob Rosensteel 

c. Equipment Leaks - Dave Markwordt 

d. Transfer Operations - Dave Markwordt 

e. Storage - Randy McDonald 

f. Wastewater - K.C. Hustvedt 

g. Industry Profile - Glenn Rives/Reese Houle 

3. Sampling/Analytical Methods Program - Joe Knoll 

a. Transfer Operations - Dave Markwordt/Susan Miller 

b. Wastewater - K.C. Hustvedt/Jeff Elliott 
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cc: Doug Bell (MD-13) 

Laura Butler (MD-13) 

K.C. Hustvedt (MD-13) 

Bob Kellam (MD-13) 

Dave Markwordt (MD-13) 

Randy McDonald (MD-13) 

Jan Meyer (MD-13) 

John Robson (MD-13) 

Debbie Stackhouse (MD-13) 

Tom Walton (MD-13) 

Al Wehe (MD-13) 

Gill Wood (MD-14) 

CMA 

Karen Fidler 

ORD 

Joe Knoll (MD-77A) 

Darryl Von Lehmden (MD-77) 

Rodney Midgett (MD-77A) 

RADIAN 

Jeff Elliott 

Reese Houle 

Susan Miller 

Glenn Rives 
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Hazardous Organic NESHAP Project Overview - Notes of 1/30/90 Meeting with CMA 

Refer to eight-page handout (attached) for specific comments. 

1. General Overview - Debbie Stackhouse 

o Emphasized that HON at formative/conceptual stage, with Radian 

preparing workplans. 

o Emphasis on preparing generic standards for all source categories, 

not standards specific to each category (e.g., when comparing 

operations with differing economics, a representative 

sample/subset will be selected for the economic analysis; details 

are being worked out). CMA expressed concern about this approach. 

o CMA Q: How generally will economics be handled? 

EPA A: By an affordability test of generic economic impacts (an 

area where EPA will be most subject to criticism). 

o CMA Q: Will it be a technology vs. emission standard? 

EPA A: Unknown for now; work is still in an early stage. 

o CMA Q: How will facilities affected by a standard be defined, by 

source categories or emission types? 

EPA A: A laundry list of source categories by emission type. 

o EPA is assuming passage of the Clean Air Act in October 1990, with 

a rigid staggered schedule of ten or more regulations that must be 

met. 

o CMA Q: How will this staggered schedule affect permitting, which 

is triggered by standards for a source? 

EPA A: Unknown. 

o CMA Q: If generics are promulgated on this schedule, how does 

this affect specifics? 

EPA A: They would be subject to and regulated by all standards 

that are applicable. 

2. Equipment Leaks - Dave Markwordt 

o Will rely on Regulatory Negotiations. 

o Will probably involve some form of leak detection and repair. 

3. Process Vents - Bob Rosensteel 

o A profile for each source category will be constructed; a 

percentage of a HAP to total VOCs will be determined. 

o EPA & Radian will provide Karen Fiddler/CMA a list of product 

processes about which little is known in the public domain, i.e., 

"troublemakers." 
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4. Storage Tanks - Randy McDonald 

o Expand to include all tank types including pressure vessels; how 

broad coverage would be is questionable, 

o CMA asked about horizontal tanks used commonly in some processes; 

different controls are needed for these. 

5. Transfer Operations - Dave Markwordt 

o Current CAA handles marine vessels differently (i.e., not covered) 

than trucks and railcars. If the proposed CAA language changes, 

the NESHAP will likely apply to marine vessels. 

6. Wastewater - K.C. Hustvedt 

o Existing info gathered thru Sect. 114 questionnaires thru Benzene 

Waste NESHAP. 

o Will use database of Office of Water priority pollutants. 

o CMA comment: Data sought do not exist; not in Sect. 308 forms; 

some in supplemental Sect. 308 forms; the key component is not 

analytical data available; live with what is available. 

o CMA Q: Can all major streams be separated out? 

EPA A: Unknown. 

o Apply similar technologies to similar streams. 

o EPA will decide -Feb/Mar on types of info needed. 

7. Industrial Profile Task - Reese Howie 

o Needs are common to all sources. 

o Overall consistency is needed to extrapolate national impacts. 

o Addressing nonreactant issues (i.e., use of solvents) will be 

difficult. 

o Tie in impacts of generic emissions to overall impacts. 

o There may be multiple processes for a given product. 

o No resolution of question re marginal facilities; EPA wants to 

avoid a plant-specific approach; a factoring approach is being 

discussed to address this, but it is not rigorous and uses a 

worst-case scenario approach. 

o Workplan preparation will be intense and ready in -2 months so 

other sources are not held up. 

8. Other/General 

o Is EPA considering a different MACT for old vs. new plants? 
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Hazardous Organic NESHAP 

Project Overview 

Coverage: 

- Production of organic hazardous air pollutants (HAP's). 

- Use of organic HAP's in SOCMI industry. 

Source Category: could be defined as chemical production unit 

(e.g. butadiene production is a source category). 

Emission Sources: 

Continuous process vents 

• Air oxidation vents 

• Distillation vents 

• Reactor vents 

Storage tanks 

- Pumps, valves, flanges (i.e., equipment) 

Transfer equipment (i.e., loading racks) 

- Wastewater handling equipment 

Other Coverage: Could potentially include storage and 

equipment leaks associated with pesticides, pharmaceuticals, 

styrene-butadiene rubber production, and others. 

Standards: Plan to develop generic standards for each emission 

source to broadly cover all or most source categories. 

Basis For Standards: 

- Would rely on existing data bases and controls from 

previous NSPS sources. 

• Process vents - 98% control by incineration or 

flaring. Could potentially have a cutoff based on 

emissions, cost-effectiveness, or other vent stream 

characteristic. 

• Storage tanks - 95% control with fixed roof control 

vented to vapor recovery or destruction devices or 

use of equivalent controls. Could have cutoffs 

based on tank size, chemical vapor pressure, or 

other criteria. 

• Equipment leaks - Current approach is about 60 

to 70% control. EPA is negotiating a new approach 

that may achieve 95% control. 

- Section 114 information collection effort is needed on 

transfer and wastewater. Existing information such 

as benzene NESHAP, industrial wastewater CTG would also 

be used. 
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Project Schedules: Schedules are grouped consistent with the 

time needed to complete data gathering and analysis. 

Emission Sources 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

Air Oxidation vents 

Distillation vents 

Reactor vents 

Storage 

Equipment leaks 

Transfer 

Wastewater 

ProDOsal 

6/91 

8/91 

10/91 

Promulgation 

6/92 

8/92 

10/92 
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EQUIPMENT LEAKS 

TECHNICAL BASIS FOR THE STANDARD: 

Regulatory Negotiation Committee 

APPROACH: 

Develop model plants based on in-house data 

Profile will be provided via another task 

Develop emission impacts 

allocate model plants 

• hazards associated with chemical 

Update costs from NSPS and Use Reg/Neg 
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PROCESS VENTS 

SCOPE: 

Separate regulations will be developed for reactor processes, 

distillation processes, and air oxidation processes. 

Only continuous product processes will be included in this effort 

TECHNOLOGY BASIS OF STANDARDS: 

Combustion control devices (thermal incinerators, flares) 

APPROACH: 

Use existing data bases for vent stream characteristics - air 

oxidation, distillation; reactor processes and 114 data collected 

for source assessments. 

Identify product/processes for each SOCMI chemical on the HAP list 

as air oxidation, or reactors or distillation. 

Develop model plants for each process type including number of 

vents, and vent stream characteristics. 

Identify HAP to total VOC ratio for model streams. 

Calculate baseline emissions, potential emission reductions, 

control costs, and cost effectiveness for model vent streams. 

Extrapolate model vent stream emissions and costs for development 

of national impacts. 

AREAS WHERE CMA CAN CONTRIBUTE: 

Existing level of control 

Characteristics of production/user processes 
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STORAGE TANKS 

SCOPE: 

Tank services covered: 

Raw material storage 

Intermediate product storage 

Product storage 

Tank type covered: 

Fixed-roof tanks 

• Floating-roof tanks 

Open-top tanks 

TECHNICAL BASIS FOR THE STANDARD: 

Subpart Kb and demonstrated technology more effective than 

controls required by Subpart Kb. 

APPROACH: 

Develop industry profile with respect to storage tank types, tank 

sizes and controls, from readily available information. The bulk 

of this information will come from Source Assessment/Source 

Category Investigations. 

Extrapolate the impacts of controls on the model processes to 

develop national impacts. 

AREAS WHERE CMA CAN CONTRIBUTE: 

Distribution of tank types and sizes in service 

• Existing level of control 
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TRANSFER OPERATIONS 

(Tank Trucks, Railcars, Marine Vessels) 

TECHNICAL BASIS OF STANDARD: 

. Combustion device capable of 98% reduction of VOC 

APPROACH: 

CAA amendment/Marine Vessel Control 

• Army Corps of Engineers data base for industry profile 

National Research Council Study for costs 

Tank Trucks/Rail cars 

Section 114 Request for Data 

Develop models for loading operations 

Benzene transfer regulation provides cost basis 

Industry profile provided via separate task 

Develop national impacts 

AREAS WHERE CMA CAN CONTRIBUTE: 

Review draft 114 Questionnaire 

Provide industry profile data 

Existing control requirements (by State) 
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WASTEWATER 

TECHNICAL BASIS OF STANDARD 

Collect certain wastewater streams at the point of generation and 

transfer through closed piping and controlled storage tanks to a 

treatment device (likely steam stripper). Alternatives of controlling 

the wastewater system would likely be allowed. 

GENERAL APPROACH 

Existing information gathered through Section 114 questionnaires to 

support the development of the CTG for industrial wastewaters and 

through Section 308 questionnaires to support Effluent Guidelines 

developed will be used. 

Additional information gathering to fill data gaps will be conducted 

through Section 114 questionnaires. 

Model plant analysis will be used to estimate impacts such as baseline 

emissions, potential emission reductions, control costs, and cost 

effectiveness of control. 

The model plant impacts will be extrapolated to develop national 

impacts. 

AREAS WHERE CMA CAN CONTRIBUTE: 

Number and volume of continuous and batch streams per product process. 

Organic loading in streams (i.e. percent of saturation) 
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INDUSTRIAL PROFILE TASK 

PURPOSE: 

Characterize the SOCMI Industry as it relates to the organic HAPs 

listed in the CAA (either produced or used) and the sources to be 

regulated. This includes: 

Identify the SOCMI product processes where a HAP is produced or 

used as a reactant (number of facilities and quantities 

processed). 

Identify the types of emission sources likely to be present in 

each product process (i.e., reactor vents, distillation vents, 

fixed roof storage, etc.). 

Develop chemical trees, so that the cost impacts on various 

chemical products can be evaluated. 

Develop the conceptual framework for evaluating the costs and 

environmental impacts of candidate regulatory options 

APPROACH: 

Working from the list of -350 SOCMI chemicals in 40 CFR 60 VV, identify 

the major production routes for each chemical, the raw materials and 

the products. Identify the organic chemicals reacted or produced in 

each process that are HAPs (based on CAA bill). 

Develop information on the number of plants that use each process, the 

quantity of each HAP used and the quantity of each HAP produced. In 

most cases, process stochiometry will be used to estimate use as a 

factor of production. Also, develop information on the geographical 

distribution of plants. 

Develop chemical use trees for all of the HAPs produced or used in 

SOCMI. 

Review State regulations to determine the required baseline level of 

control for various geographical regions, for each emission source 

type. 

Assign a representative set of model sources (I.e., process vents, 

storage tanks, equipment components) to each product process. 

Based on model source assignments, State regulations, number of plants, 

and geographical distribution; estimate baseline emissions. 

For each regulatory option, compute national impacts (emission 

reduction and costs) for each product process based on model 

assignments, and then sum for all product processes. 
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AREAS WHERE CMA CAN CONTRIBUTE: 

Filling information gaps: descriptions of SOCMI processes for which 

there is no information in public sources, including the number of 

facilities and capacities. 

Assignment of representative models to product processes for which 

there is no emissions data available. 

Identification of product processes which do not have certain emission 

source types. For example, there may not be raw material storage tanks 

or loading operations due to captive use. 

Assist in defining baseline control levels. 

Since much of the current emissions data is for VOC, the HAP portion of 

total VOC will need to be estimated. CMA could provide assistance is 

estimating the HAP:V0C ratios for specific product processes. In the 

case of wastewater, assistance in estimating the ratio of HAPs to 

priority pollutants could reduce information gathering requirements 

significantly.