p.1 

OAR Box 1875 

Prepped by Ollie Stewart 

Document Number: 

51) ll-E-69 

Docket Number: 

A-90-19 

Printed 12/1/200811:12:47 AM Sheet 51 of 86 
P.2 

A-90-19 

ll-E-69 

„,. *°

 sr^„ 

„* ^ %o UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

I »>s^^7 - Office of Air Quality Planning and Standards 

I __^V|/^. J? Research Triangle Park, North Carolina 27711 

X—-° o

v 

DEC 1 6 |99 2 ;i , ; n]99 2 

MEMORANDUM .... X: X'[Xk : .*V" 

SUBJECT: May 14, 1992 Conference Call between EPA and Synthetic 

Organic Chemical Manufacturers Association 

FROM: Jan Meyer (MD-13) typ^^^X' 

Standards Development Branch (\ 

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

Information and Process Vents 

I. Purpose 

This conference call was held to hear Synthetic Organic Chemical 

Manufacturer's Association, Inc. (SOCMA) concerns regarding the draft 

proposed package for the Hazardous Organic NESHAP (HON). 

II. Participants 

Jan Meyer EPA/SDB 

Sherry Edwards SOCMA 

Mike Dixon Advent Group 

Dot Kelly CIBA Geigy 

Mike Moore Enterlab 

III. Discussion 

The SOCMA reguested a conference call to discuss several 

concerns regarding the 12/91 draft proposal package's impact on batch 

processors and specialty chemical manufacturers. The discussion 

topics were: (1) applicability; (2) lesser guantity emission rate; 

(3) implementation plan; and (4) recordkeeping, reporting, and 

testing reguirements. The discussion is summarized below by these 

topics. 

Applicability 

The SOCMA representatives mentioned three areas of concern: (1) 

definition of batch operation, (2) definition of product, and (3) 

clarification of which provisions apply to batch operations. The 

concerns were similar to those mentioned by representatives of the 

Chemical Manufacturers Association (CMA) regarding batch operations 

and applied to the same draft language in the proposal package. Jan 

Meyer described the planned clarifications to the definition of batch 

operation and to the applicability section. In addition, Jan Meyer 
P.3 

. 

operation and to the applicability section. In addition, Jan Meyer 

described the investigation into a clearer process for defining 

applicability of the rule while achieving the same result. It was 

suggested that SOCMA consider coordinating with others on this 

effort. 

Lesser Quantity Emission Rate 

The SOCMA representatives inguired whether there were definite 

plans to establish lesser guantity emission rates. Jan Meyer 

explained that the status of this project was uncertain at this time. 

The 12/91 package mentions lesser guantity emission rates to alert 

sources of the possibility that the major source definition may 

reflect something other than 10 or 25 tons/yr of HAP emissions. 

Implementation Plan 

The SOCMA representatives expressed concerns with the amount of 

information being reguired within 120 days of issuance of the final 

rule. In their view, it would be impossible to submit all the 

information at that time and it will be a very labor-intensive report 

to prepare. They thought that the level of detail was more 

appropriate for a permit application. Jan Meyer described a revised 

approach that was under consideration in which a source would submit 

a simple notice at 120 days. The simple notice would provide the 

information needed by Regions and States for planning. Under the 

revised approach, consideration was being given to reguiring the 

implementation plan only if there were no permit application in 

process. This change was being considered because it would eliminate 

duplicative reporting of the same information. 

Recordkeeping. Reporting, and Testing 

The SOCMA representatives expressed concerns with the vast 

amount of recordkeeping, testing, and reporting in the draft proposal 

package. In their opinion, some of the reguirements such as flow 

rate cutoffs and flow weighted annual average concentrations are 

unworkable for batch operations and expose plants to compliance 

penalties for minor paperwork violations. They suggested that EPA 

should consider allowing use of engineering calculations and 

alternatives to some of the testing provisions. 

Jan Meyer reguested that they also provide suggestions on more 

workable approaches for reporting and recordkeeping that would 

provide the necessary enforcement information. She acknowledged that 

the burden was large and described several ideas being considered to 

reduce the burden and consolidate some of the recordkeeping and 

reporting reguirements. The burden associated with the eguipment 

leak provisions was also briefly discussed. Jan Meyer reguested that 

they submit suggestions on ways to reduce the burden. 

The SOCMA representative also noted that the 3-months rolling 

average for emissions averages precludes use of emissions averaging 

provisions by multi-purpose batch operations because of the 

difficulty in predicting product demand over short time periods, like 

3-months, and the associated recordkeeping burden.