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OAR Box 1669 

Prepped by Charmelle Mathews 

Document Number: 

1& j€) ll-E-7 

Docket Number: 

A-98-13 

Printed 9/23/2008 9:36:49 AM Sheet 75 of 110 
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A 98 13 

II- E - V 

MEMORANDUM 

TO: 

FROM: 

DATE: 

Steve Shedd 

U.S. EPA, OAQPS/ESD/WCPG 

GregLaFlam^jf 

Pacific Environmental Services, Inc. (PES) 

May 19,1998 

P:\N812 

. v-lJ J ' i -I^rtJJ •r,iij Jl <j *yvvS 

EPA AIR DOCKET 

SUBJECT: April 6,1998 Telephone Call with the American Petroleum Institute 

Organic Liquids Distribution (non-Gasoline) NESHAP 

PARTICIPANTS: Bill Beck 

Allen Ellett 

Chuck Feerick 

Bernd Haneke 

Jay Helms 

Greg LaFlam 

Jack McClure 

Karin Ritter 

Steve Shedd 

Gary Wilson 

Mobil Corporation (703) 849-6245 

British Petroleum (216) 586-8030 

Exxon 

PES 

PES 

PES 

Shell 

API 

U.S. EPA 

Marathon Oil 

(713)656-7960 

(919)941-0333 

(919)941-0333 

(919)941-0333 

(713)241-3999 

(202) 682-8472 

(919)541-5397 

(419)421-3666 

The U.S. EPA and its contractor (PES) participated in a conference call with the 

American Petroleum Institute (API) on April 6,1998 from 11:00 am to noon. The purpose of 

the call was for API to present its comments on the draft P-MACT document that was presented 

by the EPA at the second Roundtable meeting on March 24,1998. The API had also requested 

an opportunity to present their comments on the draft instructions for the upcoming EPA 

survey ofthe organic liquids distribution (OLD) industry. The issues and questions raised by 

API, and the ensuing discussion, are summarized below. 

EPA/API Telephone Discussion - April 6,1998 

Steve Shedd began by summarizing the principal comments on P-MACT that were 

raised by members ofthe Work Team who attended the March 24th Roundtable meeting. 

/ 
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Memo to Steve Shedd 

May 19,1998 

Page 2 

A. Comments on Draft P-MACT 

1. API: The title of Table 1 -1 (page 1 -4) should be changed to reflect that the table 

identifies State and local rules, rather than being a summary of P-MACT. 

EPA: We wish to retain the existing title indicating that this is the P-MACT summary, 

but we will show in the title that P-MACT is based on the levels found in these rules. 

2. API: The description of stand-alone terminals in Section 2.1 (page 2-1) should delete 

reference to oceangoing tankers and tank barges. Marine vessel loading is already 

regulated by another MACT rule (40 CFR 63, subpart Y). 

EPA: This description is intended to describe OLD terminals generally, and is not 

meant to list emission sources that are to be covered under OLD industry standards. 

Also, even though marine vessel loading is already covered, some aspects of these 

operations (such as storage vessels or equipment leaks) may need to be investigated 

under this OLD standards development. 

3. API: Does the compounding/blending/packaging segment described in Section 2.4 

(page 2-3) include lube oil blending (or handling of similar low vapor-pressure 

products)? 

EPA: We do not currently have data.on the vapor pressures and HAP contents of these 

products. If they do not meet the criteria in the industry survey (at least 0.1 psia true 

vapor pressure and 1,000 ppmw of HAP), they would not likely be covered by these 

standards. 

4. API: P-MACT should be based on actual facility data, and not just on the levels 

prescribed by existing rules. Also, the API representatives requested a second review of 

the summary table and the support section ofthe document after it is revised. 

EPA: We presently have very little facility data, but expect to have a data base of 

information from the industry survey. For the purposes ofthe P-MACT document, we 

will expand our discussion ofthe basis for the P-MACT levels, and will place it both in 

Section 5 and in the front (summary section) ofthe document. 

It was discussed that after the revisions have been made based on all ofthe Team's 

comments, the EPA will send summary Table 1-1, Section 5 (Current Control Levels), 

and possibly other sections ofthe document that have been significantly revised to the 

Team for another quick review. 

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Memo to Steve Shedd 

May 19,1998 

Page 3 

5. API: What does the EPA plan to do with the P-MACT document? Will it be published 

in the Federal Register? 

EPA: After the document is finalized, it will be placed on the EPA's TTN (website). 

The EPA Regional air contacts and the OLD Work Team will be notified through an Email message as to its availability. 

B. Comments on Draft ICR Instructions 

1. API: The instructions are difficult to read. The EPA should eliminate the confusing 

double negatives which are used in the sections related to chemical production and 

refinery plant sites. The sections should also be reorganized to state the most important 

information first. 

EPA: The sections causing the confusion will be rewritten to enhance clarity. As part 

ofthis revision, the "easy sentence" in each section stating the basic requirement for 

each type of production plant site will be moved to the front ofthe section as suggested 

by API. 

2. API: The term "distribution storage vessel" used in the instructions should be defined. 

EPA: We will add a clarification ofthis term. 

3. API: Will the facilities that responded to the Ethylene MACT section 114 survey also 

have to respond to the OLD survey? Can the OLD project use the results ofthis 

previous survey? 

EPA: We will discuss the coverage ofthe Ethylene MACT survey with Warren 

Johnson, who is the EPA lead on that project. Our goal is to not request information 

that was obtained previously and is still considered to be current. However, it is likely 

that the Ethylene MACT rule, like the HON and the Refinery MACT rule, will not 

regulate tankage or liquid transfers related to distribution. 

4. API: Has a wastewater throughput cutoff been added to the survey? 

EPA: We have selected 0.5 million gallons per year as the wastewater cutoff (which 

excludes segregated wastewater), below which a plant site need not report its 

wastewater practices in the survey. The EPA received little data from industry 

following the second Roundtable meeting, so this cutoff was based on conversations 

with EPA staff familiar with wastewater levels from their work in other projects. (API 

representatives said they would look into this value.) 
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Memo to Steve Shedd 

May 19,1998 

Page 4 

API: The API will work on arranging a location (probably in Houston) for the planned 

ICR workshop, and will try to secure a date in the week of May 18, 1998. Perhaps a 

notice ofthe workshop could be included with each survey being sent out. The 60-day 

"clock" for returning the survey response should start on the date ofthe workshop, 

because ofthe time needed to route surveys to the appropriate facilities within each 

company, and because many will not begin to fill it out until after the workshop is held. 

EPA: The EPA will prepare a workshop presentation that addresses how to complete 

the survey, and will consider the API's request concerning the timing ofthe responses. 

The EPA will also attempt to include notification ofthe workshop in with the ICR as it 

is mailed out to companies. If the workshop details are not final at that time, further 

notification could be made, such as a notice placed on the TTN. 

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