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OAR Box 1672 

Prepped by Charmelle Mathews 

Document Number: 

g\^ti W-0-2Z 

Docket Number: 

A-98-13 

Printed 9/30/2008 11:01:00 AM Sheet 52 of 132 
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A 98 13 

ll-C-23 

Date sent: • Fri, 10 Apr 1998 08:42:47 -0400 

From: STEVE SHEDD <SHEDD.STEVE@epamail.epa.gov> 

Subject: OLD MACT - ICR - Section 114 Survey -Reply 

To: bill_r_beck@email.mobil.com 

Copies to: rwhermanson@amoco.com, ritterk@api.org, siegler@api.org, 

dtemery@bvemx.ppco.com, dkbh@chevron.com, jacp@chevron.co 

chuck.p.feerick@exxon.sprint.com, ztcdcm@is.arco.com, gla 

mlevon@mail.arco.com, grwilson@marathonoil.com, nfseppi@m 

ellettar@ocspol.usaclv.msnet.bp.com, bhaneke@rtp.pes.com, 

glaflam@rtp.pes.com, JHELMS@rtp.pes.com, jlmcclure@sh.ellu 

callaga@texaco.com, gilmelk@texaco.com, leea@texaco.com 

Bill, 

Thanks for the comments. We will give them some more thought but here 

are my first impressions. See below. 

Steve Shedd 

>>> <bill_r_beck@email.mobil.com> 04/09/98 02:49pm >>> 

Steve: Confirming my audix to you, I am baffled by the requirement in 

Section G.(Item 1) of the OLD MACT Section 114 survey instructions 

that call for discussion of "gasoline operations" at ALL facilities. 

Comment #1: Does this mean ALL facilities, regardless of size cutoff 

in Section A? This is not clear 

Response to #1: In section "A" we discuss that only large emitters 

have to submit a survey and the third paragraph repeats that we 

require no information on non-large emitters. I believe the section 

is clear but I am concerned that you do not. Can you suggest some 

wording changes and fax to me? I will give you a call to discuss. 

Comment#2: In my understanding, this requirement means that all 

gasoline handling facilities with actual HAP emissions above one-half 

of a major source will have to submit "a brief written description" 

regardless of whether they are subject to Gasoline Distribution MACT 

(GMACT) or an area source under GMACT and even if they only handle 

gasoline and distillates at the terminal (which is generally the 

case). This seems an onerous requirement that will generate 

information of little redeeming value. 

Can you explain the purpose and justification for this requirement? 

Response to #2: Good comment and view. This is why getting another 

perspective on this material is important. We were attempting to 

reduce gasoline questions at all facilities but did not figure in this 

type of facility that: only handles gasoline products and wastes and 

what we call non-surveyed liquids (section C). I agree, we need to 

assess the need and use for information from this subset of facilities 

and clarify the instructions. Right now I cannot determine a use for 

1 

Bernd Haneke -- 1 -- Fri, 10 Apr 1998 08:48:35 
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this infomation from this type of facility. 

Regards, Bill Beck 703-849-6245 

>>> <bill_r_beck@email.mobil.com> 04/09/98 02:49pm >>> 

Steve: Confirming my audix to you, I am baffled by the requirement in 

Section G.(Item 1) of the OLD MACT Section 114 survey instructions 

that call for discussion of "gasoline operations" at ALL facilities. 

Comment #1: Does this mean ALL facilities, regardless of size cutoff 

in Section A? This is not clear 

Comment#2: In my understanding, this requirement means that all 

gasoline handling facilities with actual HAP emissions above one-half 

of a major source will have to submit "a brief written description" 

regardless of whether they are subject to Gasoline Distribution MACT 

(GMACT) or an area source under GMACT and even if they only handle 

gasoline and distillates at the terminal (which is generally the 

case). This seems an onerous requirement that will generate 

information of little redeeming value. 

Can you explain the purpose and justification for this requirement? 

Regards, Bill Beck 703-849-6245 

CO 

Bernd Haneke -- 2 -- Fri, 10 Apr 1998 08:48:35