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OAR Box 1875 

Prepped by Ollie Stewart 

Document Number: 

43) ll-E-61 

Docket Number: 

A-90-19 

Printed 12/1/2008 11:12:46 AM Sheet 43 of 86 
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 isl'Fir^-pTT "-E-61 

SUMMARY OF TELEPHONE CONFERENCE nrn r, ,. jQQ- •') • 

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Date: September 21. ,1992A / ••» , r „ . " 

Subject: Monitoring and Recordkeeping for the Hazardous Organic 

NESHAP (HON) 

Attendees: Jan Meyer, Standards Development Branch, EPA 

Daphne McMurrer, Standards Development Branch, EPA 

Richard Sigman, Chemical Manufacturers Association 

Ted Cromwell, Chemical Manufacturers Association 

Kathy Bailey, Chemical Manufacturers Association 

Annette Stanley, Chemical Manufacturers Association 

Joe Hovias, Union Carbide 

Brian Taranto, Exxon Chemical 

Chuck Malloch, Monsanto 

John Dege, DuPont 

The Chemical Manufacturers Association (CMA) requested this 

call to discuss the monitoring and recordkeeping requirements in 

the draft HON proposal and any alternative requirements that EPA 

might have under consideration. EPA began the call by stating that 

the purpose of the call was to answer clarifying questions and that 

no changes to the monitoring and recordkeeping requirements in the 

HON had been approved by all the offices in the EPA. Specifically, 

EPA stated that the Stationary Source Compliance Division (SSCD) 

and the Office of Enforcement (OE) could not have representatives 

present at this meeting, and had not approved any changes to the 

HON's compliance requirements. 

CMA asked the following questions regarding parameter 

monitoring for control devices: (1) How should the range of 

acceptable parameter monitoring values be established? (2) Are 

performance test results needed for each end of the acceptable 

range? (3) What are the consequences of having a monitored value 

outside the parameter range considered acceptable? (4) How long can 

the monitoring results be outside the acceptable range before the 

source is considered in violation? (5) What type of violation would 

be associated with parameter values outside the acceptable range? 

and (6) What would be needed to set a new range for a given 

parameter after some values had been recorded outside the 

acceptable range. EPA indicated that SSCD and OE should be 

involved in answering the above listed questions, and committed to 

a follow-up meeting to provide the complete answers to CMA. 

CMA asked the following questions regarding recordkeeping of 

parameter monitoring results: (1) If all the recorded values are 

below the acceptable limit, does the source have to average them 

for the 3-hour average, or can they keep the actual recorded values 

instead? (2) If a source has a computer operated monitoring system 

that records data more often than once every 15-minutes (the HON's 

requirement), does the source have to keep all the data, or just 

the 15 minute averages of the more frequent recordings? and (3) Can 
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a source get a case-by-case approval to use an alternative 

recording system that only records data outside a pre-set range of 

values? Again, EPA indicated that SSCD and OE should be included 

in answering these questions, and committed to including these 

topics in a future discussion with those offices. 

EPA did request more information about the alternative recording 

systems that only record data outside a pre-set range. 

Specifically, EPA asked CMA for information on how these systems 

work and the source ensures that the system is operating properly.