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OAR Box 1875 

Prepped by Ollie Stewart 

Document Number: 

49) ll-E-67 

Docket Number: 

A-90-19 

Printed 12/1/200811:12:47 AM Sheet 49 of 86 
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A-90-19 

ll-E-67 

or

 f j UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

Office of Air Quality Planning and Standards 

* •-VVl/Z " Research Triangle Park, North Carolina 27711 V'n'",-, ",, r. 

v T > . XlO' y.\" 

DEC 2 I992 DEC . '> I992 

PRO^ 

MEMORANDUM 

SUBJECT: CMA and EPA/ESD Meeting of April 15, 1992 on 

Applicability of the Hazardous Organic NESHAP (HON) 

FROM: Janet S. Meyer CW^T~ S - /^Y-W-c^x 

Standards Development Branch, ESD (MD-13) 

TO: Docket A-90-19, Hazardous Organic NESHAP: 

General Information and Process Vents 

I. Purpose 

Representatives of the Environmental Protection Agency's 

(EPA's) Emission Standards Division (ESD) met with the Chemical 

Manufacturers Association (CMA) to discuss ways to clarify the 

applicability of the draft proposal package. The objectives of 

the discussion were to identify a method that would result in 

minimum overlap with other categories (e.g., polymers and resins) 

and to create a reproducible decision process. 

II. Place and Date of Meeting 

Guest Quarters Hotel 

Research Triangle Park, NC 

8:00 a.m. - 12:00 p.m. 

April 15, 1992 

III. Attendees 

Name Organization Phone # 

Jan Meyer EPA/SDB 919 541-5254 

Les Evans EPA/CPB 919 541-5410 

David Gustafson Dow 517 636-2953 

Tom Kittleman Dupont 302 366-4718 

Amy Meyers CMA 202 887-1370 

Norm Morrow Exxon Chemicals 504 359-7226 

Bob Rosensteel EPA/CPB 919 541-5608 
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IV. Discussion 

This meeting's discussions were a continuation of earlier 

discussions on the definition of the source category. Key 

discussion topics were: (1) definition of product; (2) 

allocation of shared equipment among processes; and (3) ethylene 

units. These discussions are summarized below. 

Definition of Product 

The discussion on the definition of product focused on 

several illustrative examples of overlap of SOCMI and non-SOCMI 

chemical manufacturing activities. Attachment 1 presents several 

illustrative examples of situations where questions are expected 

to arise in application of the draft rule: 

Scenarios 1 and 3 illustrate different types of 

recycle/recovery operations. 

Scenario 2 illustrates recycle/recovery operations that 

are typically associated with polymer manufacturing 

operations. 

Scenario 4 illustrates questions on boundaries of 

units. 

Scenario 5 is an example of a process whose primary 

product is not a regulated product but the reaction coproduct is a regulated product. 

Each of these scenarios was discussed considering whether this 

situation was intended to be in the scope of the source category 

and whether the present decision criteria correctly identify 

operations that are subject. 

AUogatipn of. Shared Equipment 

Where equipment, such as storage vessels and transfer racks, 

is shared among chemical manufacturing processes and source 

categories, there will be questions regarding which standard 

applies to the shared equipment. The approach discussed was to 

allocate equipment based on predominant use of the equipment. 

This approach was identified because it should be unbiased and 

should result in a more efficient regulation. 

The following actions were agreed upon to answer remaining 

outstanding questions. The CMA representatives agreed to develop 

additional flow diagrams on solvent recovery operations and 

allocation of storage vessels and transfer racks. The EPA 

representatives agreed to confirm that distillation operations 

that are an integral part of operations of another source 
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category are being addressed in standards for that category. A 

specific example of this overlap is the standard for polymers and 

resins, and whether it will include the distillation operations. 

Ethylene Units 

The final discussion topic concerned ethylene units (olefin 

units) and whether they are considered to be part of SOCMI and 

thus subject to the HON. Attachment 2 illustrates the 

relationship of ethylene units to the processes considered in the 

impact analysis for the HON. There was agreement between EPA and 

CMA representatives that the HON processes begin at the benzene 

and butadiene manufacturing units after separation of the crude 

butadiene and crude benzene streams from the mixed streams. 

Thus, the ethylene unit is not considered to be part of the SOCMI 

source category. The EPA representatives agreed to review the 

source category list documentation to determine which category or 

industry group includes ethylene units. 
Attachment 1 

•i 

3 IRON OXIDE MANUFACTURING UNIT 

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ID 

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LL 

Ul 

•'•I 

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|J> 

^H 

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Q 

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CL 

•X 

(Primary Product - Iron Oxide) 

Non-Hon Process 

Iron Chips 

MNB 

Pickle 

Liquor 

• > 

& 

•^ Batch 

RXT Clarification 

Aniline/H20 

Iron Oxide 

(100MMLb/Yr) 

Grinding 

and 

Milling 

• > 

Continuous 

Distillation 

V 

Water Residue 

Aniline 

40MM Lb/Yr 

- > 

3/31/92 
POLYETHYLENE TEREPHTH ALATE (PET) 

Manufacturing Unit 

(Primary Product - PET) 

Non-Hon Process 

Ethylene Glycol 

Storage 

Dimethyl Terephthalate (DMT) 

Storage 

^ 

> 

Polymerization 

Methanol (Impure) 

> DIST 

<e 

• ^ PET Product 

-^C Storage j -

Recycle 

->Sel l 

DMT Manufacturing Unit 

| Hon Process 

DMT 

Product <r 

Methanol Raw 

Material Feed <e 

Feed 
^oc^r^ (zecoKiefi-y 

Sell 
ACRYLONiTRILE (AN) MANUFACTURING UNIT 

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