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OAR Box 1669 

Prepped by Charmelie Mathews 

Document Number: 

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Docket Number: 

A-98-13 

Printed 9/23/2008 9:36:49 AM Sheet 84 of 110 
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MEMORANDUM 

TO: Martha Smith 

U.S. EPA/OAQPS/ESD/WCPG 

ESD Project No. 96/05 

FROM: Greg LaFlam 

Pacific Environmental Services, Inc. (PES) 

DATE: January 5,1999 

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.,., . 

OCT I 3E33 

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EPA/_n!X>CK2T 

SUBJECT: December 15,1998 Third Roundtable Meeting for the Organic Liquids 

Distribution (non-Gasoline) MACT Rule 

I. Purpose 

The purpose of this meeting was to bring together the project Work Team, including the 

U.S. Environmental Protection Agency (EPA) and its contractor, to discuss current issues in the 

project and the preliminary data analysis of the responses to the EPA's April 1998 industry 

survey. This work is in support of the development of national emission standards for 

hazardous air pollutants (NESHAP) for the Organic Liquids Distribution (non-Gasoline) source 

category. 

II. Location and Date 

U.S. Environmental Protection Agency 

Environmental Research Center (ERC), Classroom #2 

Research Triangle Park, North Carolina 

December 15,1998,9:30 am to 2:45 pm 

III. Participants 

In person 

Bill Beck, Mobil Oil 

Ted Cromwell, Chemical Manufacturers Association 

Alice Crowe, American Petroleum Institute 

Bemd Haneke, Pacific Environmental Services, Inc. (PES) 

Cliff Harvison, National Tank Truck Carriers 

Greg LaFlam, PES 

Denise Michelson, ARCO Pipe Line Company 

Robert Nolan, Exxon Company U.S.A. 

Karin Ritter, American Petroleum Institute 

Steve Shedd, EPA 
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Martha Smith, EPA 

John Stock, Emco Wheaton 

Don Wang, Union Carbide 

Gary Wilson, Marathon Oil Company 

Phone-in 

Bill Allmond, National Association of Chemical Distributors 

Dave Darling, National Paint and Coatings Association 

Tom Hmiel, BASF Corporation 

Jordan Jacobsen, Alyeska Pipeline Service Company 

Paul Jann, Dupont 

Jack McClure, Shell Chemical Company 

Usha Mehra, GATX 

Brian Neville, Independent Liquid Terminals Association 

Liane Piatt, Dow 

Jackie Surles, Louisiana DEQ 

Hal Taback, Hal Taback Company 

Rick Wright, Ashland Chemical Company 

The attendance sheet filled out at the meeting is included as Attachment 1 to this memo. 

IV. Discussion 

EPA Introduction 

Steve Shedd, EPA, began the meeting by asking the telephone callers to identify 

themselves. He then noted that this Roundtable meeting was intended to address two main 

topic areas: current issues in the project that need resolution by the Work Team, and a review of 

the EPA's preliminary analysis of the data received in response to the industry survey sent out 

in April 1998. Mr. Shedd introduced Martha Smith, indicating that she would be taking over 

duties as EPA project leader, and that he would take on an advisory role. The participants 

present in the room then introduced themselves. 

Greg LaFlam, PES, reviewed the agenda for the meeting (Attachment 2), and said that 

the discussion would follow the presentation that had been sent out to the Team prior to the 

meeting (Attachment 3). Mr. Shedd called attention to the project schedule on page 3 of the 

presentation, noting that some of the milestones had been delayed due to budget cuts (although 

nothing had been cut out). Mr. LaFlam then began a review of project issues, which are 

summarized on pages 4 through 12 of the presentation in Attachment 3. 

2. 
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A. Project Issues 

Characterization and scoping of the OLD industry Tissue 1) 

In presenting Issue No. 1, Mr. LaFlam stated that the project team (EPA and its 

contractor) were attempting to identify additional organic liquids distribution (OLD) industry 

segments that have not been included, such as end-users of liquids (primarily miscellaneous 

manufacturing operations). Bill Allmond, NACD, asked which category the facilities with SIC 

code 5169 would fit into, and Mr. LaFlam responded that these are being included with the 

petroleum terminals that have the code 5171. Usha Mehra, GATX, noted that her company's 

facilities report under SIC code 4226, liquid warehousing. Jordan Jacobsen, Alyeska, stated 

that he felt it would be inappropriate to consider as distribution the receipt of "own-use" fuel 

into a facility. Mr. Shedd noted that end-users could be considered under two categories: those 

with own-use fuel and those who use received chemicals as a feedstock in their products. He 

also said that the definition of distribution has not been finalized for this source category. Tom 

Hmiel, BASF, felt that at end-user facilities the storage tanks have already been covered by 

other Federal rules, but Mr. Shedd pointed out that some standards are silent on storage tanks or 

cover only certain tanks. 

With regard to the industry diagram (page 6 of the presentation), Mr. Jacobsen stated 

that non-collocated terminals typically exist between the pumping/breakout stations and the 

refineries, and would be part of the distribution network. No other comments were made on the 

diagram. 

Cliff Harvison, NTTC, noted that the transportation sector was not specifically included 

in the industry survey, and asked whether they were in the "regulatory loop." For example, tank 

trucks at cleaning racks release vapors during the cleaning process. Mr. Shedd replied that we 

have not targeted the tank cleaning process, and it has been our impression that RCRA rules 

would address the hazardous by-products from these processes. Other meeting participants 

pointed out that the EPA's Office of Water is developing rules related to mobile tank cleaning. 

Other MACT coverage Tissue 2. 

Dave Darling, NPCA, was interested in finding out the interpretation the project team 

had of the Miscellaneous Organic NESHAP (MON), which is under development. Mr. Shedd 

and Mr. LaFlam stated that we are maintaining contact with that rule process, and the EPA 

intends to not duplicate coverage of any sources between the MON and the OLD rule. Mr. 

Hmiel asked whether data could be shared between the two projects, and Mr. Shedd replied that 

the EPA may consider this after the survey data have been reviewed. Bill Beck, Mobil, asked 

whether the EPA survey data would apply at MON (batch process) sources, and Mr. LaFlam 

responded that MON-type process facilities were excluded from the survey request. 

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Denise Michelson, ARCO Pipe Line, asked whether HAP rules developed under 40 

CFR Part 61 (non-MACT NESHAP) would be considered in the same way as current MACT 

coverage. Mr. Shedd replied that, if the control technology required in those rules is equivalent 

to the MACT level, the new OLD rule would not duplicate existing NESHAP coverage. 

Ms. Mehra asked whether a facility with mostly MACT-covered equipment, in order to 

simplify things would have the option of extending the current MACT coverage rather than 

applying the new OLD MACT requirements. Mr. Shedd stated that the EPA has not used this 

approach in the past. He noted that if the facility was emitting below the major source cutoffs 

(10 tpy of any single HAP, 25 tpy of all HAP) with the current MACT controls in place, the 

new MACT control requirements would not apply. 

Don Wang, Union Carbide, noted that the Polyethers/Polyols (PEPO) MACT is not 

going to cover liquid transfer activities because the liquids contain essentially no HAP. Will 

the OLD rulemaking make the same decision? Mr. Shedd responded that for low-HAP liquids 

a similar conclusion is likely for the OLD rule. 

Rule applicability Tissue 3. 

Ms. Mehra stated that the majority of terminals in Texas have permits that indicate their 

major source status. She suggested that the project team check among the States to see whether 

this is a typical occurrence. Mr. Beck suggested that Option C in Issue No. 3 (sources below 

5/12.5 tpy of actual emissions only keep records) be considered as an alternative for sources 

without a Title V permit. He noted that the Marine Vessel Loading MACT has set similar 

applicability cutoffs. Mr. Beck and Mr. Shedd stated that the cutoffs of 5 and 12.5 tpy are 

contained in the EPA's potential to emit (PTE) guidance. 

Ted Cromwell, CMA, expressed concern over what he termed "negative" recordkeeping 

and reporting. He asked what records would have to be kept by sources with emissions below 

the 5/12.5 tpy cutoffs. Mr. Shedd responded that these would be records of distribution 

activity, but details have not been worked out. It was noted that this requirement would likely, 

only apply to stand-alone terminal facilities. 

Tank truck/railcar control and testing Tissues 4 and 5) 

Mr. Harvison stated that tank trucks that transport hazardous liquids are subject to a 

variety of State, DOT, and OSHA regulations, some of which create risky situations for the 

drivers. There is a fundamental difference between gasoline and chemical tank trailers. 

Typically, gasoline cargo tanks are outfitted with intrinsic vapor recovery (VR) equipment in 

response to Federal and State air regulations. However, chemical trailers are generally not 

equipped with VR. Thus, in order to recover vapors from these tanks, existing connections 

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(sometimes called cleanout nipples) are used as vapor outlets. Where connections are not 

present, an operator may improvise the VR hookup and inadvertently create an unsafe situation. 

Mr. Harvison asserted that the EPA needs to be aware of existing conditions and issue 

compatible requirements where the transportation sector is directly affected. 

With regard to Issue No. 5, Mr. Harvison pointed out that the annual DOT test is a 

"pressure" or "leak tightness" test, and not a "hydrostatic" test as stated in the presentation. 

The hydrostatic test is performed every 5 years, and involves stressing the tank shell to 1.5 

times its design pressure. Mr. Harvison noted that the title of the EPA's pressure/vacuum test 

(Reference Method 27) indicates that it applies to gasoline tank trucks. Since chemical trailers 

are not equipped with a vapor valve, a modified version of RM 27 is used to test these tanks. 

Rick Wright, Ashland Chemical, stated that Texas allows either the DOT test of RM 27 to be 

performed for chemical trailers. Mr. Harvison felt that RM 27 should be modified to suit 

chemical trailers if the EPA intended to impose leak tightness standards on these sources. Mr. 

Shedd concluded the discussion by requesting that Mr. Harvison supply additional information 

on the application of RM 27 to chemical tanks. Mr. LaFlam added that information on the 

costs of performing the test and converting chemical trailers to a vapor recovery configuration 

would be useful to the project team in determining impacts of any proposed requirements. 

Equipment leak emission factors Tissue 6) 

Mr. Beck asked what the issue was concerning emission factors for leaking equipment 

(pumps, valves, flanges, etc.). Mr. Shedd responded that these factors will be used for 

determining baseline emissions and the environmental impacts of controls. The result of this 

analysis could affect the decision on whether to impose a leak detection and repair (LDAR) 

program (either instrument-based or visual). Mr. Shedd pointed out that some have 

recommended using the gasoline marketing facility factors that appear on the EPA's website. 

These are much lower than the EPA factors that are specific to SOCMI or refinery equipment. 

Distribution sources have been reporting during EPA site visits that they typically use the 

SOCMI factors in calculating emissions from their OLD equipment. Ms. Mehra stated that it 

would be inconsistent to use the marketing factors for gasoline and the higher factors for other 

types of sources. Mr. Wright felt that the SOCMI average factors should be used generally, and 

that the "stratified" factors should be used for plants with an LDAR program in place. Mr. 

Wang asked whether the chemical plant data collected for the HON could be used to help select 

the proper emission factors. He also felt that facilities with LDAR should use the lower 

marketing factors. Mr. Shedd concluded that the project team should use the SOCMI and 

refinery emission factors at the present time, unless and until data are located that indicate that 

there are situations where they are inappropriate. 

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Format of standards for transfer activities Tissue 7) 

Mr. LaFlam stated that the selection of appropriate units for the liquid transfer standards 

would be an ongoing technical issue. Mr. Wang pointed out that the HON contains both 

percent reduction and outlet concentration (ppmv) standards, while the Consolidated Air Rule 

(CAR) gives an option of several different formats. Mr. Beck noted that mass units (which tend 

to be associated with gasoline transfer standards) are not represented in terms of HAP in other 

rules, but as total organic compounds (TOC) or VOC. He suggested that the Benzene NESHAP 

be checked to see which units are used in that rule. Mr. Shedd concluded that the State rules 

may provide an indication of the most appropriate units, and that the project team would be 

reviewing these rules in the future. 

B. Preliminary ICR Data Analysis 

Bernd Haneke, PES, directed the presentation of the EPA's data analysis of the OLD 

industry survey responses. Included in this presentation were preliminary MACT floors for the 

emission sources identified in the survey. 

General background 

The number and types of facilities surveyed were reviewed. Mr. Haneke related that the 

confidential business information (CBI) was being stored on a separate, secured computer, and 

would be integrated with the non-CBI data in the future. The list of organic liquids reported 

(and their relative prevalence in the data base) may change after additional work is done to 

integrate the HAP constituents from mixtures into the listing. The project team stressed that the 

quality assurance (QA) review of the data base had not yet been completed, and so the data 

summary and preliminary MACT floors are subject to change. 

Storage tanks 

Mr. Haneke noted that, on page 18 of the presentation, floating roofs were not meant to 

be designated as a "control device" and should be stricken from the list of control device types. 

Several Team members stated that tank controls may be dictated by seasonal or equipment 

flexibility considerations and other non-regulatory reasons, especially in cases where low vapor 

pressure liquids or small tanks are shown as subject to control. The EPA should consider this 

when deciding on regulatory cutoffs for tanks. Mr. Beck suggested that respondents reporting 

"anomalous" data be contacted to verify such data. 

The project team described the assumptions used to determine the tank MACT floors, 

and Mr. Shedd noted that we have not yet completed the floor analysis for floating deck fitting 

controls. 

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Liquid transfer 

The project team described some of the assumptions used to determine MACT floors 

for tank truck, railcar, and smaller container liquid transfer controls. Robert Nolan, Exxon, 

asked whether there are any trade organizations for railroads, and Mr. Shedd indicated that the 

project team has communicated with a few such groups. Mr. Shedd also stated that, while we 

have separated tank trucks and railcars for this analysis, it does not appear that the MACT 

floors would change if these two transportation modes were grouped together and new floors 

determined for combined cargo tanks. 

With regard to container filling, Mr. Wright asked whether capture efficiency was 

included in the percentage reductions shown as the floors. Mr. Shedd indicated that it was not. 

Mr. Wright asserted that it would be difficult to control drum filling operations. Mr. Nolan 

stated that lube oil has a vapor pressure below 0.1 psia, and his company would not consider 

controlling lube oil drum filling. Mr. LaFlam pointed out that low vapor pressure liquids are 

sometimes subject to controls due to their low odor threshold. One attendee asked whether the 

project team had investigated the quantity of emissions from smaller container filling. Mr. 

Shedd replied that there is nothing in the statute regarding lower emission cutoffs; therefore, we 

are looking into all potential emission sources regardless of size. 

Wastewater and other waste 

Mr. Shedd stated that, based on the team's analysis of individual units of the wastewater 

collection and treatment systems, there appear to be MACT floors for the subsystems used to 

collect and treat the wastewater. However, it is unclear from the data how effective these 

current controls are in suppressing emissions from the water handling system as a whole. Thus, 

the project team intends to examine these data using a systems-based approach. 

Mr. Shedd indicated that more information is needed on what respondents to the survey 

meant by collecting their semi-aqueous waste in a "closed system." Attendees stated that crude 

oil tank bottoms and refinery waste qualify as hazardous wastes under RCRA. 

Equipment leaks/LDAR 

Suggestions for modifications to the two LDAR tables on page 34 of the presentation 

were made by some of the Work Team members. In the first table, it was suggested that the 

MACT floor leak definition be shown separately for each component type. In the second table, 

it was suggested that the monitoring method (i.e., instrument or visual check) be shown with 

each of the monitoring frequencies listed in the last two columns. Mr. Haneke indicated that 

the project team was still reviewing these data to confirm the preliminary floors. 

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Blending/packaging 

Mr. Haneke stated that little useful information on blending and packaging operations 

was received in the survey. While there do not appear to be non-zero existing source MACT 

floors, there may potentially be floors for new sources. As with wastewater, waste, and 

equipment leaks, further analysis will be necessary, and may include contacting some survey 

respondents. 

Next Steps 

Mr. Beck asked that, in reviewing the ICR data base (quality assurance), the project 

team list and provide to him the data quality issues that have been resolved as well as those 

issues that are still open. He also requested that a summary of issues and assumptions be 

included with the data base when it is released to the public. Mr. Shedd and PES agreed to 

prepare these items. 

The meeting was adjourned by Mr. Shedd at approximately 2:45 pm. 

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