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OAR Box 1875 

Prepped by Ollie Stewart 

Document Number: 

14) ll-E-32 

Docket Number: 

A-90-19 

Printed 12/1/2008 11:12:44 AM Sheet 14 of 86 
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A-90-19 

ll-E-32 

MEETING NOTES 

DATE: February 13, 1992 

PLACE: Durham, NC 

SUBJECT: Hazardous Organic NESHAP (HON) Meeting with Members of 

the Chemical Manufacturers Association (CMA) 

Attached is a summary of a 1-day informational meeting 

between EPA personnel and members of CMA. At this meeting, EPA 

described the provisions in the 12/24/91 draft HON and answered 

CMA questions about the draft rulemaking package. 

Attachment 

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MEETING SUMMARY 

This document summarizes the meeting with the Chemical 

Manufacturers Association (CMA) held February 13, 1992, at the 

Guest Quarters Hotel in Durham, North Carolina. It is organized 

into a question and answer format and divided into seven 

sections: Overview of the Regulation, Wastewater, Process Vents, 

Transfer, Storage Tanks, Emissions Averaging, and Suggestions. A 

list of participants is in Attachment A. 

The CMA began the meeting by indicating that the 

organization is currently in the stage of learning and 

understanding the Hazardous Organic National Emission Standard 

for Hazardous Air Pollutants (NESHAP), commonly referred to as 

the HON, and appreciated the opportunity to meet with the 

Environmental Protection Agency (EPA) to ask clarifying questions 

on the draft regulation. The points for discussion were outlined 

in the meeting agenda (Attachment B). The CMA then indicated 

that it would not be making official comments on the regulation 

at the meeting; rather, it will submit comments during the public 

comment period after proposal of the regulation. 

The Emissions Standards Division (ESD) director, Mr. Bruce 

Jordan, welcomed the CMA and indicated that the EPA also 

appreciated the opportunity to answer CMA's questions on the 

draft regulation. 

1.0 OVERVIEW OF THE REGULATION 

Ms. Daphne McMurrer of the Standards Development Branch 

(SDB) began the EPA presentations by giving a general 

introduction to the regulation and by providing an overview of 

Subparts F, G, and H. She indicated that Subpart F contains the 

applicability and general requirements; Subpart G contains the 

provisions for process vents, storage tanks, transfer operations, 

wastewater collection and treatment operations, and emissions 

averaging; and Subpart H contains provisions for equipment leaks 

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per the Negotiated Regulation. Ms. McMurrer also went over 

specific areas in which.the EPA is requesting public comment. 

The handouts for her presentation are in Attachment C. 

Ouestions and Answers on Overview 

CMA - In the specific areas requiring public comment, what does 

the term "compliance gridlock" mean? 

EPA - Some CMA representatives have said facilities may have 

difficulty complying because of a gridlock of technology — 

demand for control equipment and engineering services may be 

higher than the supply. 

CMA - In the discussion of applicability in the preamble, it says 

that SOCMI is defined by SIC 2865 and 2869. Does this mean that 

only processes with these SIC numbers are considered SOCMI 

processes? 

EPA - Whether a process is SOCMI is determined by the 

applicability definition in Subpart F. The preamble is giving a 

general guideline. It is possible that a process that is not in 

one of those SIC codes may be considered a SOCMI process for the 

HON. The preamble will be reviewed for clarity and changed, if 

appropriate. 

CMA - The definition of source is all emission points in a 

contiguous facility. How does the definition relate to 

facilities with both SOCMI and non-SOCMI processes? 

EPA - In this rule, the source includes only SOCMI processes 

subject to the HON. 

CMA - If a chemical process produces a SOCMI chemical and the 

chemical is stored and then used to make a polymer or resin, 

where does HON applicability end? 

EPA - In such a case, Subpart F defines the point where a SOCMI 

process ends as the product storage tank. Subpart F also 

specifies that a SOCMI process ends where the product enters 

another air oxidation or reactor process on-site or is 

transferred off-site. 

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CMA - It is not clear in a situation where the SOCMI product is 

piped directly into a non-SOCMI process without a reactor where 

HON applicability ends. 

EPA - This issue will be reviewed and clarified. 

CMA - The description of batch operations on page 301, 

paragraph (iii) is unclear regarding applicability. 

EPA - The paragraph in question is not intended to expand the 

applicability for batch operations. The intent is for the rule 

to apply to processes producing chemicals listed in Table 2 of 

Subpart F. Paragraph (iii), discussing batch operations, will be 

reviewed and reworded if appropriate. 

CMA - The draft regulation states that HON does not apply to 

storage of liquids that contain HAP's as impurities, but CMA 

believes the storage applicability and definition of impurity are 

not clear enough. For example, if a SOCMI product has undergone 

purification, and the waste contains a small amount of the SOCMI 

chemical, is the storage of the waste covered? 

EPA - The EPA requested that CMA provide specific examples of 

where applicability is unclear. The examples will receive review 

and comment, and the regulatory package will be edited, if 

appropriate. CMA agreed to provide such examples. 

CMA - If a company leases land, and supplies utilities to another 

company that owns and operates equipment in the middle of their 

facility, are these two facilities considered the same source? 

EPA - This situation will be reviewed, the regulation will be 

made clearer, and an answer will be forwarded to CMA. 

2.0 WASTEWATER 

Ms. Mary Tom Kissell of SDB presented the wastewater 

provisions under the HON. Attachment D contains the summary 

slide presentation and information provided. 

In discussing new unit requirements, Ms. Kissell pointed out 

a mistake that was made in the HON wastewater guide which had 

been distributed to some CMA members prior to this meeting. The 

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mistake was in Figure 4 of the guide. The wording "One or More 

Group 1 Streams" should read "One Group 1 Stream." It was then 

explained that for the control of Table 8 HAP's, one of the 

treatment options is to reduce each Table 8 HAP to less than 

10 ppmw. Since dilution cannot be used to achieve compliance, 

only one stream can be considered for that option. Ms. Kissell 

then distributed revised versions of the wastewater guide. 

The discussion on HON wastewater provisions continued with 

Ms. Penny Lassiter of the Chemicals and Petroleum Branch (CPB) 

presenting three case studies. Ms. Lassiter used wastewater 

stream data and schematic diagrams to illustrate alternatives 

that may be used to comply with the wastewater provisions of the 

HON. Her handouts are in Attachment E. 

Questions and Answers on Wastewater 

CMA - Does a new unit have to be controlled for Table 8 and 

Table 9 HAP's? 

EPA - New units must be evaluated for Table 8 and 9 HAP's. A 

wastewater stream from the unit must be controlled if it exceeds 

the applicability criteria for either Table 8 or 9 HAP's. 

CMA - Does the 1 megagram per year (Mg/yr) facility total only 

include contributions of Group 1 wastewater streams? 

EPA - Yes, the total only includes Group 1 wastewater streams, 

which are not controlled to the level required by the standard. 

CMA - Should the wording on Figure 5 still read "One or More 

Group 1 Streams," or is it incorrect like Figure 4? 

EPA - Figure 5 is correct. 

CMA - Can the concentration data for the wastewater streams be 

obtained from EPA Reference Method 25D or another validated 

method. 

EPA - Yes, if measurements are taken, either Method 25D or a 

method validated by Method 301 can be used to determine 

concentrations. 

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CMA - How are combined SOCMI and non-SOCMI wastewater streams 

considered under the rule? 

EPA - Non-SOCMI streams would be considered Group 2 streams, 

since anything that was not explicitly defined as a Group 1 

stream is a Group 2 stream. For combined SOCMI and non-SOCMI 

streams, the applicable treatment requirements for combined 

Group 1 and Group 2 streams would be followed. [Although, for 

the purposes of demonstrating compliance, the non-SOCMI streams 

can be treated in the same manner as Group 2 SOCMI streams, they 

should not be called Group 2 streams. The non-SOCMI wastewater 

streams would not be used to determine the source's emission 

limit and cannot be included in an emission average.] 

CMA - Will the HON override the benzene waste standard if an 

existing unit had a stream that contained benzene, or will 

compliance with both regulations be necessary? Also, would a 

benzene-containing wastewater stream, that is below the 

applicability for the benzene regulation, be covered by the HON? 

EPA - A facility will have to meet any applicable standards in 

addition to the HON, such as the benzene NESHAP or the Resource 

Conservation and Recovery Act (RCRA) rules. The HON could apply 

to a benzene-containing wastewater stream that is below the 

applicability for the benzene NESHAP. It seems improbable that a 

stream containing only benzene would not be subject to the 

benzene NESHAP requirements, but would require control because of 

HON. The EPA would be interested in hearing about any specific 

cases where this situation could occur. 

CMA - Referring to the second example, Existing SOCMI Source II, 

in Ms. Lassiter's case study, does the loading cutoff of 1 Mg/yr 

pertain to all the streams from a process unit, including the 

treated streams? 

EPA - The facility loading cutoff pertains to streams within the 

contiguous area, under common ownership or control. Streams that 

This material was not discussed at the meeting. 

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are treated in accordance with the various alternatives do not 

count toward the limit, nor do Group 2 streams. 

CMA - The benzene NESHAP specified a certain percentage of water 

in defining the term "aqueous." Regarding the definition of 

wastewater under the HON, does it refer to a specific water 

content in order to be aqueous? 

EPA - Although no percentage of water is specified in the HON, 

these wastewater streams are aqueous by virtue of direct or 

indirect contact with water. It may need to be clarified that 

non-aqueous streams are not included. 

CMA - Are the liquids from auxiliary equipment such as heat 

exchangers and (glycol) cooling systems covered? What if the 

equipment is shared among various non-SOCMI and SOCMI processes? 

EPA - Units dedicated and integral to SOCMI processes would 

likely be covered; there is some uncertainty regarding how units 

tied to both non-SOCMI and SOCMI processes would be treated. The 

EPA requested that CMA send examples of this occurrence so that 

the EPA can further investigate this issue. 

CMA - Are all concentration measurements to be annual averages or 

maximum values? 

EPA - References to maximum concentrations are incorrect; 

concentrations are to be annual averages. 

CMA - Give a short summary that provides guidance on the quantity 

of data deemed sufficient by the EPA in determining flow rates, 

concentrations, etc. to quantify wastewater stream 

characteristics at the point of generation. Determining these 

parameters would especially be a problem with intermittent 

wastewater streams generated by maintenance operations. 

EPA - There is no short summary explaining these details; 

however, if the annual average values of a maintenance stream are 

not greater than either: (1) 10,000 parts per million by weight 

(ppmw) of VOHAP's and (2) not greater than 500 ppmw of VOHAP's or 

1 liter per minute (1pm), the stream would not be covered. In 

turn, this cutoff would eliminate the need for sampling many of 

the maintenance streams. 

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CMA - In regard to the methodology for determining the removal of 

volatile organics with biological treatment (bio-treatment) 

systems, does the credited treatment have to occur entirely 

within the bio-treatment system itself, or can removal from a two 

or three step approach, including clarifiers, also be counted? 

EPA - Treatment from the whole system is considered, but 

compliance with practices such as suppressing emissions from the 

wastewater (i.e., covered, etc.) until the volatile organic HAP's 

are treated or destroyed is required. 

CMA - What is the distinction between collection and treatment in 

terms of equipment and location? 

EPA - A separation or distinction is not made. Since these 

operations are occurring within the same overall system, a 

distinction does not appear to be warranted. 

CMA - Does the HON definition of wastewater cover spent caustics? 

This issue arose under the benzene NESHAP since such a stream 

would contain a very small amount of water. An example is a 

caustic stream that strips acid gases and is subsequently sent to 

an open sewer of a SOCMI process. 

EPA - The intent of the wastewater definition was to cover 

streams being sewered. If the spent caustic is not discharged to 

the sewer, then it is not subject to the rule because the HON 

addresses wastewater as opposed to wastes. If there is a closedloop recycle of the caustic stream such that it does not get 

mixed with water or exposed to air, then it would likely not be 

covered within the HON, since this condition could be considered 

as returning the stream to the process. A stream containing 

spent caustic that is discharged to the sewer would be subject to 

the HON. There are fundamental differences between the HON and 

the benzene NESHAP. Any suggestions on clarifying the 

definitions and applicability would be appreciated. 

CMA - What is the origin of the 10 ppmw and the 0.02 1pm levels 

cited in the HON? 

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EPA - These levels reflect the benzene NESHAP requirements, which 

were judged to represent the new source MACT floor, the "best of 

the best" control. 

CMA - Is there a limitation on recycled streams regarding the 

processes to which the streams could be sent, similar to the 

limitations within the benzene NESHAP. Specifically, can 

recycled streams be sent to processes other than the one from 

which the streams originated, including non-SOCMI processes? 

EPA - The streams can go back to any process, including 

non-SOCMI, as long as the recycle is closed-loop and emissions 

are controlled during recycle. 

CMA - Are calculations for required mass removal, as present in 

Example Calculation #2 of Ms. Lassiter's case study, based on 

treating both Group 1 and Group 2 streams, or can Group 2 streams 

be backed out of the calculation? 

EPA - It can be done either way. 

CMA - Regarding the earlier presentation by Ms. Kissell, how do 

the numbers on the flow diagrams on the overheads and in the 

handouts correspond to the numbers on the earlier versions cited 

in the regulatory package? 

EPA - The old Figure 1 has been divided into new Figures 1 and 2; 

all other old figure numbers have consequently increased by one. 

CMA - What is a new unit? Was the intent to cover a new wash 

drum in an existing process? 

EPA - The intent was not to call a new drum a new source, but to 

cover a new chemical manufacturing process. 

CMA - How do modifications or reconstructions influence whether 

processes are considered new or existing? 

EPA - These determinations will be defined under Section 112(g) 

rules. The HON just explains what to do in each of those 

circumstances. 

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3.0 PROCESS VENTS 

Ms. Sheila Milliken of SDB reviewed the major sections of the 

process vent portion of the HON regulation (applicability, 

monitoring, recordkeeping and reporting, and test methods) 

highlighting the similarities to the SOCMI NSPS for Process Vents 

from Air Oxidation Processes and Distillation Operations. 

Attached is the handout she went over (Attachment F). 

Ouestions and Answers on Process Vents 

CMA - The k factor on page 367 and the b constant for halogenated 

streams on page 371 appear to be a incorrect. The k factor 

should be IO"6 instead of IO"5. 

EPA - These will be reviewed and corrected if necessary. 

CMA - Is there guidance on the conditions at which the 

performance test must be run? 

EPA - Guidance will be in the General Provisions to Subpart 63. 

CMA - Regarding the calculation of TRE, what vents should be 

combined? Would streams that are already controlled with 

combustion to 98 percent be included? If there are five streams 

in a process unit that have a combined TRE less than one, can 

three streams be controlled and the other two not controlled if 

the two uncontrolled streams have a combined TRE greater than 

one? 

EPA and Radian - The draft HON package requires that the TRE be 

calculated for all individual vent streams in a process unit and 

for all possible combinations of vent streams in a process unit. 

The intent of combining streams must be further discussed to 

develop an answer for the questions regarding which vent streams 

are required to be combined when calculating the TRE. The answer 

will be forwarded to CMA. 

CMA - What is meant by combining streams? 

EPA - Volumes of gas and concentrations of gas in the vent 

streams are mathematically combined not physically. 

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CMA - Are analyzer gas streams covered by the process vent 

provisions? 

EPA - It is considered an equipment leak, and therefore not 

covered by the process vent provisions in Subpart G. However, 

whether analyzer gas is considered an equipment leak subject to 

Subpart H of the HON will be double checked. 

CMA - If changes in conditions trigger a new TRE calculation or a 

performance test, do all the vents have to be retested or just 

the vent that changed? 

EPA - Only the vent that changed. 

CMA - Does the rule refer to 100 ppmv of the halogenated material 

or of the halogen? 

EPA - The 100 ppmv refers to the sum of all halogenated compounds 

present in the stream. If a scrubber is applied, the 99-percent 

removal or 0.5 mg/dscm limit refers to the halogens and hydrogen 

halides measurable by Method 26 or 26A. 

CMA - Is a pressure vacuum vent on a storage tank a process vent? 

The inclusion of product accumulator vessels in the process vent 

definition makes it seem like it would be. Are pressure vacuum 

vents on storage tanks considered equipment leaks? 

EPA - Pressure vacuum vents on tanks are not intended to be 

called process vents. We have been reviewing how to address 

potential overlaps between process vents, storage, and equipment 

leaks. The EPA will have to get back to CMA and may further 

clarify the regulation. 

CMA - The regulation needs to be clarified as to whether upset 

conditions are exempt from triggering a new performance test. 

EPA - In general, temporary malfunctions would not likely trigger 

a new performance test, only a significant, intentional process 

change would trigger a retest. The EPA will consider clarifying 

this in either the General Provisions or the HON regulation. 

CMA - If TRE or compliance is being determined and a recovery or 

combustion control device is present, does the TRE or compliance 

demonstration have to be determined at the maximum expected 

values of the operating parameters which have to be monitored? 

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Also, what must be done if a monitored parameter is out of range? 

Does a new TRE or compliance determination have to be conducted? 

There is a concern for situations where the maximum expected 

operating parameter values would not occur during the 180-day 

time period in which industry has to demonstrate compliance. For 

example, the temperature of the control device would be hottest 

in August, but the TRE test or demonstration of compliance might 

need to be completed in the winter to meet the regulatory 

schedule. 

EPA - A TRE determination.is done initially to determine whether 

a vent is Group 1 or Group 2. If a Group 2 vent (TRE >1) has a 

recovery device, then recovery device operating parameters must 

be monitored. If the monitored values are out of the range 

established in the initial TRE determination, this does not in 

itself constitute a violation of the standard or mean that TRE 

must be retested or the vent becomes a Group 1 vent. However, if 

the operating parameter values are consistently out of range, the 

industry or enforcement agency may decide a new test should be 

conducted. 

The same idea applies to monitoring of combustion controls 

where monitoring parameter ranges are established during the 

initial performance test of the control device. Again, a 

monitoring value being out of range triggers an excess emission 

report, but is not a violation of the standard and does not 

necessarily mean the performance test must be redone. 

CMA can submit information on what is a reasonable time 

limit within which representative conditions can be obtained and 

a compliance test completed and submitted. 

CMA - What is the basis of TRE, maximum flow or average flow? 

EPA and Radian - The General Provisions say representative 

conditions. 

CMA - The draft NESHAP General Provisions say tests should be run 

under whatever conditions the Administrator agrees on. Most 

permitting is based on maximums, the performance test should be 

based on maximums too. In Part 60, the performance tests are 

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also run at maximums, clarification needs to be made in the 

General Provisions. 

EPA - Run the Performance test at the maximum flow at which the 

process unit is expected to operate, monitor what is required, 

and report it if it goes out of range. It is expected the NESHAP 

General Provisions will be similar to the Part 60 General 

Provisions. 

CMA - Is there an assumption in the rule that TRE is directly 

related to production capacity? 

EPA - No, this assumption is not made in the rule. 

4.0 TRANSFER 

Dr. Jan Meyer of SDB presented an overview of the transfer 

provisions of the HON. The handout is attached (Attachment G). 

There was a correction to the handout made during the 

presentation. On the page with the heading "Group 1 Racks," the 

100 ppm should read 0.5 mg/dscm. 

Ouestions and Answers on Transfer 

CMA - Is a rack an individual loading arm? 

EPA - No, a rack can be made up of several arms. It is a 

continuous unit with any number of arms. 

CMA - The term marine vessel is defined but is not used in the 

regulation. 

EPA - The package will be checked to see if the definition is 

needed. It seems that the term was present to be used in 

applicability. 

CMA - The definition of Group 1 rack should say annual 

throughput. 

EPA - That is correct, we will add annual throughput to the 

definition. 

CMA - On page 441, the emission rate is corrected to 3 percent 

oxygen, not all control devices run at this percent oxygen. 

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EPA and Radian - The data are normalized to 3 percent 

mathematically, the stream is not physically adjusted to 

3 percent. 

CMA - The standard covers tank trucks and railcars, are you 

intending to exclude packing that does not have wheels, such as 

drums and isocontainers? 

EPA - Yes, we are intending to exclude the minor sources. 

CMA - Can Group 1 racks be controlled using vapor balancing? 

Vapor balancing would make sense from a resource 

recovery/pollution prevention view point. 

EPA - Vapor balancing can be used if 98 percent emission 

reduction is shown. This may be difficult to show. 

CMA - CMA is concerned that vapor balancing is not part of the 

rule. How can a performance test be run on vapor balancing? 

Vapor balancing systems would have no emission points except the 

storage tanks to which the vapor is returned, and these emissions 

would be covered by the storage tank rule. 

EPA - We will review the possibility of putting vapor balancing 

in the rule. 

CMA - In the preamble, pages 301 and 302, it says that combustion 

is the universally applicable control device for transfer, it 

should be vapor balancing. 

EPA - Universally applicable in SOCMI may not be what most 

facilities are doing. By "universally applicable," it is meant 

that combustion is the most stringent technology that could be 

applied to all transfer emissions. 

CMA - In the handout, what is ppmc? 

EPA - Parts per million by compound (by volume). 

CMA - Is there guidance in the rule explaining how to setup the 

performance test for a rack with multiple arms? If there are 

three compounds transferred at a rack, the control device will 

reduce the emissions of each by different amounts due to 

differences in chemical properties, how should the performance 

test be run? 

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EPA - The performance test, which determines the efficiency of 

the control device using the inlet and outlet concentration, must 

be run at representative conditions. It is not possible to state 

specifically what is meant by representative conditions for all 

cases. A facility must determine what representative conditions 

are appropriate for the typical conditions seen by the control 

device and the performance test run at these conditions. 

CMA - If several vents from various sources are routed to one 

incinerator, is only one performance test required? 

EPA - Yes, the performance test is to determine whether the 

control device is functioning properly; therefore, only one test 

is required for one control device. There is nothing in the 

regulation that would require more than one performance test. 

This should be made obvious in the supplemental information the 

EPA plans to distribute at the time of proposal. 

CMA - In the provisions page 433 paragraph (h), it says that a 

collection system cannot be operated at a pressure greater than 

the vapor tightness test pressure. The vapor tightness test is 

conducted at a pressure less than the vapor pressure of some of 

the chemicals, making it impossible to operate the collection 

system with some chemicals. 

EPA - Yes, this is incorrect; it will be corrected. 

5.0 STORAGE 

Dr. Jan Meyer reviewed the Storage Provisions. She compared and 

contrasted the provisions to the NSPS for VOL Storage and Benzene 

Storage. Attached is the handout outlining the presentation 

(Attachment H). 

Ouestions and Answers on Storage 

CMA - It is difficult from an enforcement standpoint to know when 

a seal fails in an internal roof. 

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EPA - The rule clearly states what constitutes a failure, such as 

seals that are torn or detached. There will be additional 

information in the supplemental information, giving guidance to 

the States. Any suggestions that CMA may have on how to inspect 

for seal failures in internal roofs should be sent to Jan Meyer. 

CMA - The definition of new versus existing storage vessels 

depends on the date of publication. Which date of publication is 

meant, promulgation or proposal? 

EPA - The definition of new and existing is based on the date of 

proposal; however, the rule does not go into effect until the 

date of promulgation. 

6.0 EMISSIONS AVERAGING 

Ms. Daphne McMurrer gave a short presentation summarizing the 

emissions averaging provisions. The handout is the last page of 

the first handout (Attachment C). 

Ouestions and Answers on Emissions Averaging 

CMA - If the reference control technology is used and achieves a 

higher percent reduction, can this be counted as a credit? 

EPA - If the reference control technology is being used in a 

different way or adjustments have been made to it, and if the 

higher percent reduction is acknowledged by the EPA then, yes, it 

can be counted as a credit. 

CMA - What is a discount factor? 

EPA - The discount factor, which will be between 0 and 

20 percent, shaves the amount of the credit by the amount of the 

factor. Therefore, a little more than one Mg reduction is needed 

to generate one credit and to balance one debit. 

CMA - If a pollution prevention measure went into effect last 

year, can it be used as a credit? 

EPA - Yes, pollution prevention measures that have gone into 

effect after 1987 can be counted as credits. The only question 

CMA3.MTG 1 5 
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is how much of the reduction can be counted as credits. For 

instance, all control of a Group 1 point would not be counted 

because some control is being required by the HON rule. Only 

control beyond the percent control that would be achieved by 

applying the reference technology to a Group 1 emission point can 

be credited. 

CMA - What is the difference between pollution prevention and 

add-on controls? 

EPA - To qualify as pollution prevention, an act must result in 

source reduction as defined by the Pollution Prevention Act. The 

difference between pollution prevention and add-on controls, in 

terms of credits, is that credit can be given for pollution 

prevention if it went into effect since 1987; credit can only be 

given to add-on controls if they are installed after promulgation 

or are part of an Early Reduction commitment. 

CMA - Are steam stripping of wastewater and internal floating 

roofs (IFR) on storage tanks considered pollution prevention or 

add-on controls? Is an IFR on a Group 2 tank pollution 

prevention or add-on control? 

EPA - These are still being considered; an IFR on a Group 2 tank 

will probably be considered pollution prevention. 

CMA - Are the quarterly calculations of credits and debits based 

on actual or allowable emissions? 

EPA - The calculations are based on actual emissions. 

CMA - If there is a tank that is being used as a credit 

generator, but it is not used for 3 months, does it generate 

credits for those 3 months? 

EPA - It does not get counted if it is not being used. 

CMA - Explain the 3-month rolling average. 

EPA - Monthly estimates are determined and then 3-month averages 

are calculated each month. The 3 months to be averaged are 

rolled each month so that the average is calculated on the 

current month and the two preceding months. In the month of 

March, the 3-month average would include data from January, 

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February and March; in April, the 3-month average would be for 

February, March, and April, etc. 

CMA - So a bad month gets counted for 3 rolling averages? 

EPA - Yes, and a good month is counted for 3 rolling averages. 

CMA - Can the averaging be with any combination of emission 

points at the facility and then the calculations would only be 

made for these points? 

EPA - Yes, any combination of points that are subject to the HON. 

7.0 OTHER SUGGESTIONS AND QUESTIONS 

The EPA asked if there were any additional questions or any 

suggestions. 

CMA - It would be helpful if the new and existing stream in the 

wastewater provisions were written up in parallel paragraphs. 

EPA - Everything about new streams under one set of paragraph and 

everything regarding existing streams under another set of 

paragraphs? 

CMA - Yes. 

CMA - The implementation of the rule is very complicated and time 

consuming. One hundred and twenty days may not be enough time to 

prepare the implementation document. Also, with the 

implementation plan being tied to the operating permit, it is 

very difficult to change the implementation plan. A source would 

have to go through all of the permit review procedures to change 

the implementation plan. 

EPA - The implementation plan was tied to the operating permit 

because similar information is in both documents. The permit 

program has to be finalized to fully understand the implications 

of this requirement. To ensure enforceability, the Agency would 

like to have the implementation plan submitted as soon as 

possible. The time requirement will be reviewed. 

CMA - In Table 3 on page 329, the footnote regarding organic 

cyanides is technically incorrect and is not necessary. 

EPA - We will remove that footnote. 

CMA3.MTG 1 7 
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CMA - Is the HON being affected by President Bush's 90-day 

moratorium on regulations? 

EPA - Regulations which have a statutory deadline are not 

affected. Since the HON has a statutory deadline, ESD staff 

believes it will not be affected. This is not an official 

decision. 

CMA - The recordkeeping and reporting requirements are very 

complicated, why do they have to be in the regulation in 

November? The monitoring provisions could be completed by 

November, while the recordkeeping and reporting provisions could 

be proposed and promulgated after they are reworked. 

EPA - From an enforcement perspective, it would be difficult to 

publish the regulation without the recordkeeping and reporting 

provisions. What specifically is the problem with recordkeeping 

and reporting? 

CMA - It is a good idea for us to talk further with the EPA about 

reporting and recordkeeping because there may be some data that 

are very difficult for us to provide and that may not be 

necessary from an enforcement point of view. 

EPA - Much of the complication comes from the regulations being 

flexible; we also need feedback on those aspects of the rule in 

which the flexibility is not needed, or is less important. 

CMA - There was an earlier question regarding modifications 

triggering a repeat of the performance test. It was clarified 

that only significant intentional changes would trigger a retest. 

Can words be added to the regulation to reflect this? 

EPA - It would be helpful for CMA to provide a summary of these 

areas of concern. 

CMA - Are dryers or thin film evaporators considered distillation 

columns? 

EPA - The definition of "distillation operation" is very broad 

and would include any separation that is achieved by 

redistribution of the components between the liquid- and vaporphases as they approach equilibrium within the unit. Thin-film 

evaporators would be included under this definition. Because 

CMA3.MTG 18 
————— a P.21 

dryers do not generally contain a liquid phase, they are not 

expected to come under the distillation operation definition. 

CMA - Does the regulation cover the storage of distillation 

bottoms? 

EPA - This is a waste and is not intended to be covered in this 

regulation. 

Mr. Jordan thanked everyone for coming and asked the participants 

to send any additional comments or questions to the EPA. He 

expressed his desire that the cooperative working relationship 

between the EPA and CMA continue. 

CMA3.MTG 1 9 
P.22 

ATTACHMENT A 
P.23 

EPA - CMA 

HON CLARIFICATION DISCUSSION 

Name 

David Emerson 

Alan T. Roy 

Tom Stark 

David DiMarcello 

Dennis E. Miller 

Jim Lewis 

David Woodring 

Nancy Cookson 

Amy Meyers 

Gary O'Dea 

Richard Sigman 

Annette Stanley 

Sonya Winner 

David Gustafson 

Steve Coppola 

John Dege 

Paul Jann 

Tom Kittleman 

Vivian Mclntire 

Joe Woolbert 

Dennis Beauregard 

Michele Dubow 

Linda Herring 

Bruce Jordan 

Mary Tom Kissell 

Penny Lassiter 

Affiliation 

Air Products and 

Chemicals 

Allied-Signal 

Amoco Chemical 

BASF 

BASF 

B.F. Goodrich 

B.P. Chemical 

CMA 

CMA 

CMA 

CMA 

CMA 

Covington & Burling 

Dow 

DuPont 

DuPont 

DuPont 

DuPont 

Eastman Chemical 

Eastman Chemical 

EPA, TSD 

EPA, ESD 

EPA, ESD 

EPA, ESD 

EPA, ESD 

EPA, ESD 

Telephone Number 

215-481-8347 

804-530-6155 

312-856-2813 

201-397-4591 

201-316-3809 

216-447-7979 

216-586-8670 

202-887-1241 

202-887-1370 

202-887-1353 

202-887-1313 

202-887-1103 

202-662-5572 

517-636-2953 

302-773-0149 

302-773-4229 

302-366-3219 

302-366-4718 

615-229-3045 

903-237-5475 

919-541-5512 

919-541-3803 

919-541-5358 

919-541-5572 

919-541-4516 

919-541-5396 

MCH/082 

affil.lst 
Name 

Daphne McMurrer 

Jan Meyer 

Sheila Milliken 

Bob Rosensteel 

Debbie Stackhouse 

Kim Boudreaux 

Gordon Brown 

Brian Taranto 

Danny Anderson 

Raymond Rudek 

Bruce Wallington 

J. Scott Hartman 

Jeff Klieve 

Chuck Malloch 

Connie J. Keating 

Lloyd Stone 

Laszlo Takacs 

Jeff Elliott 

Guy E. Fortier 

Ruth Mead 

Julie Anne Probert 

Mae Thomas 

Pat Moran 

Jack McClure 

Kevin P. Batt 

Joe Hovious 

Joe Ledvina 

David E. Davis 

Affiliation 

EPA, ESD 

EPA, ESD 

EPA, ESD 

EPA, ESD 

EPA, ESD 

Ethyl Corporation 

Exxon Chemical 

Exxon Chemical 

First Chemical 

Merck 

Merck 

Miles, Inc. 

Monsanto 

Monsanto 

OxyChem 

OxyChem 

OxyChem 

Radian Corporation 

Radian Corporation 

Radian Corporation 

Radian Corporation 

Radian Corporation 

Rohm and Haas KY, 

Inc. 

Shell Oil Company 

Union Carbide 

Union Carbide 

Vista Chemical 

Vulcan Chemicals 

Telephone Number 

919-541-0248 

919-541-5254 

919-541-2625 

919-541-5608 

919-541-5258 

504-388-7776 

713-425-5033 

713-870-6117 

601-938-2227 

908-302-7397 

908-302-7815 

412-777-7647 

314-694-3712 

314-694-8889 

713-474-0442 

713-393-5556 

716-286-3103 

919-541-9100 

919-541-9100 

919-541-9100 

919-541-9100 

919-541-9100 

502-449-5258 

713-241-3999 

304-747-4718 

203-794-5183 

713-588-3446 

205-877-3854 

MCH/082 

affil.lst 
-l-"5 < " "=-J_ a

 MiT, CHEM. MfiMJFACTURERS ASSN. TO 

cat* 

CNgMCAI. MANUFACTURERS ASSOCIATION 

January 24, 1.92 

Tentative Agenda 

HON neetlng between SPA and CMA 

9:45 - 10:39 Introduction and Overview 

10:30 - 12:00 Vastevater 

1Z:00 - l:oo Lunch 

1:00-2:00 ocess Vents 

z:00 - 2:30 Transfer Operations 

2--30 - 3:oo storage Tanks 

3:00 - 3:30 Eaissions Averaging 

3:30 - 4:00 Wrap - Op 

cc: K. Bailey 

N. Cookson 

T. Croswell 

B. Horaa 

0. O'Dea 

A. Stanley 

?30iMS ^,^.wa 8 « ^ T6aDC2003 r JOMK^OO TetexB9ei7(CMAVVSH) 

913155414028 FP.2! 

___ ^ ^ > 

TOTAL P.02 

P.25 
P.26 

HON Regulatory Package 

Subpart F: Applicability and General Requirements 

° Specifies covered pollutants and sources 

Defines SOCMI 

° Defines 7 non-SOCMI Processes for the Equipment Leaks 

standard 

Subpart G: Provisions for Process Vents, Storage Vessels, Transfer 

Operations and Wastewater 

SOCMI only 

° Control requirements 

° Emissions averaging 

Subpart H: Provisions for Equipment Leaks 

0

 Regulatory negotiation 

0

 Work practice standard 
P.27 

Subpart F 

Specifies covered pollutants and sources 

Organic HAPs 

110 HAPs regulated by Subpart G 

149 HAPs regulated by Subpart H 

Major sources only, including those created by Lesser 

Quantity Cutoffs 

Defines SOCMI 

399 chemical manufacturing processes for Subpart G, 453 

for Subpart H 

Process Vents, Storage Vessels, Transfer Operations, 

Wastewater Collection Treatment Operations and 

Equipment Leaks 

Source defined as all emission points in a contiguous area 

under common control 

Defines 7 non-SOCMI Processes for Equipment Leaks standard 

Styrene/butadiene rubber production 

Polybutadiene production 

Chlorine production 

Pesticide production 

Chlorinated hydrocarbon use 

Pharmaceutical production 

Miscellaneous butadiene use 
Subpart G 

SOCMI Source Category Only, excluding equipment leaks 

Control Requirements 

Reference Control Technology (RCT) 

0

 More than one device or practice can be the RCT 

0

 Most widely applicable controls 

0

 Similar control, monitoring, recordkeeping and 

reporting requirements in existing rules 

Applicability Criteria for Control Requirements 

° Interacts with RCT to determine the overall control 

level from source 

0

 Compared to the "Floor levels of control" for each 

kind of emission point 

0

 Used to define Group 1 and Group 2 points 

Emissions Averaging 

Allows flexibility while achieving equal or greater 

emission reductions 
P.29 

Subpart H 

Regulatory Negotiation 

Finished in November 1990 

Representatives from: 

° Petroleum, Chemical and Pharmaceutical industries 

0

 State and local agencies 

° Environmental groups 

Agreed to exclude Petroleum Refinery processes 

Work practice standard 

Based on pre-existing equipment leak standard 

Cannot be assigned a control efficiency that would be 

consistent across sources or across time for a given source 

Allows staggered implementation 

Includes incentives for good performance 

If a source wants to include Equipment Leaks in its enforceable 

commitment for the Early Reductions rule, the commitment 

must be filed before proposal of the HON 
P.30 

Requests for Public Comment 

0

 Use of a Discount Factor for Emissions Averaging 

0

 Proposed exclusion for area sources and pilot plants 

° Definition of SOCMI used to determine applicability 

0

 Test methods for process vents 

0

 Need and potential ways to address compliance gridlock 

Ways to ensure compliance with emissions averaging prior to 

issuance of operating permits 

Remaining Issues 

Consistency with CTGs and RACT policy 

Interpollutant Averaging 
P.31 

Emissions Averaging 

Control requirements used to predict "allowable emissions" 

Hypothetically apply the RCT to Group 1 points, predict 

post-control emissions 

Predict emissions from Group 2 points with baseline 

controls 

System of credits and debits used to balance emissions from 

points that are averaged 

Debits for "under control" of a Group 1 point 

Credits for: 

° New controls above the RCT level on a Group 1 

point 

0

 New controls on a Group 2 point 

° Pollution prevention measures taken since 1987 

° Appropriate Early Reductions controls 

Discounting factor applied to credit generating points 

Credits and Debits must balance 

In Mg 

On a quarterly basis 
P.32 

ATTACHMENT D 
HAZARDOUS ORGANIC NESHAP (HON) 

CMA Meeting 

13 February 1992 
Benzene and HON Wastewater — A Comparison Overview 

Waste streams Subject 

to Standard 

Basis of Control 

Treatment 

Requirements 

Affected Waste 

Management Units 

BENZENE 

• all benzene containing wastes 

• facility threshold for control and 

stream threshold 

• treatment alternatives: 

•reduce benzene concentration to 

below 10 ppmw 

•remove 99% of benzene on a 

mass basis 

•treat in incinerator operatine at 

99% efficiency 

•treat in wastewater treatment 

system 

• tanks 

• surface impoundments 

• oil-water separators 

• containers 

• individual drain systems 

HON WASTEWATER 

• wastewater streams 

• individual stream threshold* 

•treatment alternatives: 

•recycle to process 

•treat with design steam 

stripper 

• reduce pollutant 

concentration to numerical 

standard 

•reduce mass flow rate by 

specified percentages 

• tanks 

• surface impoundments 

• oil-water separators 

• containers 

• individual drain systems 

* with exemption 
No Group 2 

WW Stream 

Treatment and Controls 

to Meet New and Existing 

Treatment Standards 

Treatment and Controls 

to Meet Existing 

Treatment Standards 

Figure 8. HON Wastewater Operations 
P.36 

WHAT IS A WASTEWATER STREAM? 

Any organic HAP-containing liquid or material separated from the 

liquid (i.e., residual) resulting from direct or indirect contact of water 

with organic compounds 

Wastewater streams are classified as Group 1 or Group 2 based on a 

concentration and flow criteria 

Examples of wastewater streams are: 

• process wastewater 

•product or feed tank drawdown 

• leachate landfill 

•cooling tower blowdown 

•steam trap condensate 

•material recovered from waste management units 

WHAT IS POINT OF GENERATION? 

For wastewater (except landfill leachate) 

• where wastewater stream exits the process unit or storage tank prior to 

handling or treatment in a piece of equipment not integral to the operation 

of the process unit 

For landfill leachate: 

•At the pump well where the leachate is removed from the landfill 
P.37 

WHICH STREAMS ARE GROUP 1 WASTEWATER STREAMS 

FOR CONTROL OF TABLE 8 HAP'S? 

• Streams generated from new process units are Group 1 wastewater streams 

required to control for Table 8 HAP's when: 

• Flow rate > 0.02 fpm, 

AND 

• concentration of any Table 8 HAP > 10 ppmw 

WHICH STREAMS ARE GROUP 1 WASTEWATER STREAMS 

FOR CONTROL OF TABLE 9 HAP'S? 

• Streams are Group 1 wastewater streams for control of Table 9 HAP's 

when: 

• total VOHAP concentration > 10,000 ppmw 

OR 

• total VOHAP concentration > 500 ppmw and 

flow rate > 1 t pm 

• an existing process unit wastewater stream is exempt from treatment 

requirements if source total VOHAP mass < 1 Mg/yr 
P.38 

New Units 

WHAT ARE THE TREATMENT REQUIREMENTS FOR GROUP 1 

WW STREAMS REQUIRING CONTROL OF TABLE 8 HAP'S? 

• When treating one Group 1 wastewater stream for control of Table 8 

HAP's, the owner/operator is required to: 

• recycle to a process 

or 

• treat with a design steam stripper 

or 

• reduce each Table 8 HAP to less than 10 ppmw 

New Units 

WHAT ARE THE TREATMENT REQUIREMENTS FOR GROUP 1 

WW STREAMS REQUIRING CONTROL OF TABLE 8 HAP'S? 

• When treating one or more Group 1 and Group 2 wastewater streams for 

control of Table 8 HAP'S, the owner/operator is required to: 

• recycle to a process 

or 

• treat with a design steam stripper 

or 

• reduce combined mass flow rate of Table 8 compounds by 99% 

or 

• achieve required mass removal of total VOHAP's 
P.39 

Existing and New Units 

WHAT ARE THE TREATMENT REQUIREMENTS FOR GROUP 1 

WW STREAMS REQUIRING CONTROL OF TABLE 9 HAP'S? 

• When treating one or more Group 1 wastewater streams for the control of 

Table 9 HAP's, the owner/operator is required to: 

• recycle to the process 

or 

• treat with a design steam stripper 

or 

• reduce total VOHAP mass flow rate by 99% 

or 

• reduce total VOHAP mass flow rate for each group of HAP's in 

accordance with Table 9 

or 

• reduce total VOHAP average concentration to no more than 50 

ppmw 

Existing and New Units 

WHAT ARE THE TREATMENT REQUIREMENTS FOR GROUP 1 

WW STREAMS REQUIRING CONTROL OF TABLE 9 HAP'S? 

• When treating one or more Group 1 and/or Group 2 wastewater streams 

for the control of Table 9 HAP's, the owner/operator is required to: 

• recycle to the process 

or 

• treat with a design steam stripper 

or 

• reduce total VOHAP mass flow rate by at least 99% 

or 

• reduce total VOHAP mass flow rate for each group of HAP's in 

accordance with Table 9 

or 

• achieve required mass removal for Group 1 wastewater streams 

-
» 

• 

-

Existing and New Units 

WHEN CAN THE PROCESS UNIT ALTERNATIVE TREATMENT 

REQUIREMENTS BE IMPI_EMENTED? 

• The Process Unit Alternative Treatment Provisions may be chosen by the 

owner/operator as a treatment alternative if: 

• controUing for Table 9 HAP's 

and 

• wastewater streams generated within the process unit are not mixed 

with streams from other units 

and 

• all wastewater streams generated within the unit comply with the 

treatment provisions 

Existing and New Units 

WHAT ARE THE PROCESS UNIT ALTERNATIVE TREATMENT 

REQUIREMENTS? 

• Wastewater streams with concentrations < 10 ppmw do not require 

treatment 

• When treating wastewater streams with concentrations > 10 ppmw, the 

owner/operator is required to: 

• recycle to a process 

or 

• reduce total VOHAP concentration to 

less than 10 ppmw 

P.40 
P.41 

New SOCMI Source 

SOCMI 

Process Unit A 

Maximum Table S HAP = 300 ppmw 

Stream A-1 350 ppmw VOHAP, 10 Ipm 

* Maximum Table B HAP = 3 ppmw 

Strea m A- 2 e05ppmwVOHAP,3lpm 

SOCMI 

Process Unit B 

Maximum Table 8 HAP = 100 ppmw 

Strea m B- 1 700ppmwVOHAP,20lpm 

Maximum Table 8 HAP = 5 ppmw 

Strea m B- 2 400 ppmw VOHAP. 30 Ipm 

* Group 1 stream: because either: 

- Concentration of a Table 8 HAP > 10 ppmw and flow > 0.02 Ipm, or 

- Concentration of VOHAP > 500 ppmw and flow > 1 Ipm or 

- Concentration of VOHAP > 10,000 ppmw. 
P.42 

NEW SOURCE 

Example 

Treat Stream A-1 individually: 

• Treat each Table 8 HAP to < 10 ppmw 

or • Recycle to process 

or • Treat stream with design steam stripper 

Treat Combined Streams A-2 and B-1 

• Recycle to process 

or • Treat with design steam stripper 

or • Treat each Table 8 HAP to achieve 99% mass 

reduction, and either 

i. 99% reduction in total VOHAP mass flow 

rate 

ii. Total VOHAP concentration of 

< 50 ppmw 

iii. Percent reductions in mass flow rate for 

each group of HAP's in Table 9 
P.43 

Existing SOCMI Source II 

SOCMI 

Source 

Process Unit A 

Stream A-1 

30 Ipm, 225 ppmw VOHAP, 3.5 Mg/yr 

Stream A-2 * 

11.5 Ipm. 550 ppmw VOHAP, 3,3 Mg/yr 

Stream A-3 * 

12 Ipm, 580 ppmw VOHAP, 3.6C Mg/yr 

Stream A-4 * 

0.5 Ipm, 10,000 ppmw VOHAP, 2.63 Mg/yr 

11.5 Ipm, 5 ppmw 

99% control 

12.5 Ipm, 151 ppmw, 0.98 Mg/yr 

84% corrtrol 

Group 1 streams because their VOHAP concentration > 500 ppmw and 

flowrate > 1 Ipm, or VOHAP concentration > 10,000 ppmw. 
P.44 

EXISTING SOCMI SOURCE II 

EXAMPLE OF FACILITY LOADING CUTOFF 

Stream A-2 Treat by design steam stripper 

Streams A-3 and A-4 Treat to get below facility loading of 

1 Mg/yr. 

NOTE: Only Group 1 streams not treated to the levels 

required in the standard are included in this analysis. 
Legend 

Undwyround 

GROUP 1-W< stroma - # 

EXAMPLE WASTEWATER COLLECTION & TREATMENT SYSTEM 

EXISTING SOCMI SOURCE 
P.46 

EXISTING SOURCE 

EXAMPLE TREATMENT OPTIONS 

DEFINE EXAMPLE 

Treat Stream A-1 individually 

Treat Streams A-4, B-1, B-2, and B-3 combined 

Treat Process Unit C Streams by Process Unit Alternative 

Treatment Standards 

Stream A-1: One or more Group 1 Stream Treatment (Attached 

Calculation #1) 

or 

Treat with design steam stripper 

Treat to achieve 99 percent reduction in total VOHAP 

mass flow rate 

or 

• Treat to achieve target effluent total VOHAP 

concentration of 50 ppmw 

or • Treat to achieve percent reductions in mass flow rate 

for each group of HAP's in Table 9. 
P.47 

EXISTING SOURCE (CONTINUED) 

Combined treatment of streams A-4, B-1, B-2, and B-3. 

• Treat with design steam stripper 

or 

• Treat to achieve 99 percent reduction in total VOHAP 

mass flow rate 

or 

• Treat to achieve reductions in mass flow rates for 

each Group of HAP's in Table 9 

or 

• Treat to achieve required total VOHAP mass removal 

(both of Table 8 HAP's and total VOHAP) 

(Attached Calculation # 2) 

Process Unit C streams: Process Unit Alternative Treatment 

Standard (Attached Calculation #3) 

Treat all streams (combined or individual) to a total 

VOHAP concentration < 10 ppm, prior to contact 

with the atmosphere or combination with streams 

from other process units. 
P.48 

EXAMPLE CALCULATION #1 

EXISTING SOURCE I Process Unit A 

(One or more Group 1 Stream Treatment) 

Stream A-1 

Flow = 10 Ipm 

HAP Compound 

Benzene 

Nitrobenzene 

Aniline 

Toluene 

VOHAP 

Concentration 

(ppmw) 

1500 

500 

1000 

500 

3500 

VOHAP Mass 

Flowrate 

(Mg/yr) 

7.88 

2.63 

5.26 

2.63 

18.4 

TREATMENT OPTION 1: 

Treat with design steam stripper 

TREATMENT OPTION 2: 

Treat to achieve 99% reduction in total VOHAP mass flow rate 

Total VOHAP Mass Flow Rate = 18.4 Mg/yr 

(18.4) - (18.2) = 0.18 Mg/yr 

Total VOHAP mass flow rate after control 

TREATMENT OPTION 3: 

Treat to achieve target effluent total VOHAP concentration of 

50 ppmw 

Total VOHAP concentration prior to control = 3500 ppm 

Reduce total VOHAP concentration to 50 ppmw via steam 

stripping 
P.49 

EXAMPLE CALCULATION #1 (CONTINUED) 

STREAM A-1 

TREATMENT OPTION 4: 

Treat to achieve percent reduction in mass flow rate for each 

group of HAP's in Table 9. 

Group 

A 

B 

C 

Compounds 

Benzene, Toluene 

Nitrobenzene 

Aniline 

Required Removal 

Efficiency 

99 

95 

70 

Benzene: 

7.88 Mg/yr before control 

7.88 - 7.80 = 0.079 Mg/yr after control 

Nitrobenzene: 

2.63 Mg/yr before control 

2.63 - 2.50 = 0.13 Mg/yr after control 

Aniline: 

5.26 Mg/yr before control 

5.26 - 3.68 = 1.58 Mg/yr after control 

Toluene: 

2.63 Mg/yr before control 

2.63 - 2.60 = 0.026 Mg/yr after control 

Total VOHAP mass flow rate after control = 1.82 
P.50 

EXAMPLE CALCULATION #2 

EXISTING SOURCE 

Combined Treatment of Streams A-4, B-1, B-2, and B-3 

Required Mass Removal (RMR) 

Treat to achieve required total VOHAP mass removal (RMR) for all 

Group I wastewater stream streams 

RMR = 

K 

10e 

V E 

i-i 

u * _____ 

1

 100 

/HON Wastewater 

\ Reg p. 550 

K 

V 

Cj 

Density of the Group 1 wastewater stream (assumed 

to be 1.0 Mg/m3 for this example). 

Annual wastewater quantity of the Group 1 

wastewater stream, cubic meters per year. 

Average VOHAP concentration of each Table 8 organic 

HAP compound "j" in the Group 1 wastewater stream 

at the point of generation, ppmw. 

Required percent removal of each VOHAP 

concentration of compound "j" (target removal 

efficiency from Table 9). 

The total RMR is calculated by adding together the RMR for each 

Group 1 stream to be combined for treatment. 
P.51 

EXAMPLE CALCULATION #2 (CONTINUED) 

Stream 

A-4 

B-1 

B-2 

HAP 

Compound 

Toluene 

Phenol 

Phenol 

Toluene 

Benzene 

VOHAP 

Cone. 

(ppmw) 

500 

320 

200 

100 

250 

250 

V 

(Ipm) 

12 

12 

13 

V 

(m3/yr) 

6300 

6300 

6800 

VOHAP 

Mass 

Loading 

3.2 

2.02 

1.26 

0.68 

2.39 

2.39 

F 

(%) 

99 

0 

70 

0 

99 

99 

Stream A-4 

Cj 

F 

RMR (A-4) 

RMR (A-4) 

500 ppmw 

99 

(1.0 Mg/m3) (6300 m3/yr) (500 ppmw) 

(10-6) (99/100) 

3.12 Mg/yr 

Stream B-1 

Cj 320 + 200 = 520 ppmw 

RMR (B-1) = 6300 x10' 6x [(320 x 0) + (200 x 70/100)] 

0.882 Mg/yr 
P.52 

EXAMPLE CALCULATION #2 (CONTINUED) 

Stream B-2 

CJ =10 0 ppm + 350 ppmw + 350 ppm = 800 

ppmw 

RMR (B-2) = (6800) x 10 6 x [(100 x 0) + (350 x 99/100) + 

(350 X 99/100)] 

= 4.71 Mg/yr 

RMRTotal = 3.12 + 0.882 + 4.71 = 8.71 Mg/yr 

Group 2 streams also treated in biological treatment tank 

• Stream B-3: 10 Ipm, 50 ppmw 

• Combined stream: (measured at influent to biological 

treatment tank) from other Group 2 wastewater streams 

Actual mass removal must be at least 8.71 Mg/yr. 

Removal = [VOHAP mass loading in (Group 1 and Group 2 

streams) - VOHAP mass loading out] x Fbjo 

where: 

Fbi0 = The theoretical fraction of VOHAP entering the 

unit destroyed by biological treatment, calculated 

using CHEMDAT.7, with site specific biorate 

factors developed using the biorate protocol. 
P.53 

EXAMPLE CALCULATION #3 

EXISTING SOURCE I 

PROCESS UNIT C: Process Unit Alternative Treatment 

Standard 

TREATMENT: Treat all streams in process unit (combined 

or individual) to a VOHAP concentration 

< 10 ppmw prior to contact with ambient 

air or combination with stream from other 

process units. 

Stream 

C-1 

C-2 

C-3 

C-4 

VOHAP Concentration 

(ppmw) 

1000 

100 

700 

5 

Example Shown 

Streams C-1, C-2, and C-3 are hard-piped to a 

steam stripper for product recovery. 

Steam stripper effluent VOHAP concentration < 10 

ppmw => meets requirements 

Stream C-4 VOHAP concentration < 10 ppmw => 

meets requirements 
HAZARDOUS ORGANIC NESHAP REQUIREMENTS 

PROCESS VENTS 

OVERVIEW 

• Similar to NSPS for SOCMI Air Oxidation Processes and Distillation 

Operations 

• Applicable to only continuous vents 

• Uses Total Resource Effectiveness (TRE) Format to distinguish between 

Group 1 and Group 2 Vents 

• Details specific compliance provisions for different control options 
ALL VENTS 

• All vents subject to initial TRE Determination 

Parameters: flow rate, net heating value, total organic compound 

(TOC) emission rate, and total organic HAP emission rate 

• Associated monitoring, reporting, and recordkeeping requirements depending 

on control option 

• . • ' 
GROUP 1 VENTS 

• TRE value <_ 1.0 

$11,000/Mg HAP removed for new sources 

$5,000/Mg HAP removed for existing sources 

• Achieve compliance using one of the following: 

Combustion Device: Reduce emissions of total organic HAP or TOC 

(less methane and ethane) by 98 weight-percent or 20 parts per million 

by volume (ppmv) 

• Halogenated vent streams >_ 100 ppmv of halogenated compounds 

require acid gas scrubbing 

Flare: Follow requirements in General Provisions 

Recovery Device or Process Change to increase TRE value and change 

vents to "Group 2" Vents 

Ul 
GROUP 2 VENTS 

• TRE value > 1.0 

• Achieve compliance using one of the following: 

Recovery Device: Maintain TRE index value > 1.0 at final recovery 

device outlet 

Process Change: Maintain TRE value > 1.0 prior to release to the 

atmosphere 

• V 
r . 

TEST METHODS 

Measurement of TOC or HAP: Method 18 

Method 301 

Measurement of Scrubber parameters: Method 26 

Method 26A 

Method 301 
MONITORING REQUIREMENTS 

• Similar to NSPS for Air Oxidation Processes and Distillation Operations 

• Monitoring of acid gas scrubbers required 

• No monitoring provisions for Boilers/Process Heaters using vent stream 

as primary fuel 

' -
RECORDKEEPING/REPORTING REQUIREMENTS 

• Similar to NSPS for Air Oxidation Processes and Distillation Operations 

• Initial and Periodic Reporting 

Initial: Demonstrate compliance with standard 

Periodic: Exceedances of initial parameters and measurements 

• Recordkeeping of monitoring results and initial test results 
REFERENCE MATERIALS 

b> 
TEST METHODS 

TRE DETpiMINATION 

Selection of sampling site 

Vent stream flow rate 

Concentration of Organic Compound 

Concentration of Carbon Monoxide and Hydrogen 

Water vapor content 

METHOD 

1 or IA (Part 60, Appendix A) 

2, 2A, 2C, or 2D (Part 60, Appendix A) 

18 (Part 60, Appendix A) 

ASTM D1946-77 

4 (Part 60, Appendix A) 
TEST METHODS 

COMBUSTION DEVICE 

Selection of sampling site 

Gas Volumetric flow rate 

Total organic HAP or TOC 98 weight percent or 20 ppmv 

METHOD 

1 or IA (Part 60, Appendix A) 

2, 2A, 2C, or 2D (Part 60, Appendix A) 

18 (Part 60, Appendix A) or Method validated to Method 

301 (Part 63, Appendix A) 

<. 
TEST METHODS 

SCRUBBER 

Measured concentration of compounds containing 

halogens (Applicability cutoff determination) 

Compliance with 0.5 mg/dscm limit or 99% efficiency 

METHOD 

18 (Part 60, Appendix A), or method validated to 

Method 301 (Part 63, Appendix A) 

26, 26A (Part 60, Appendix A), or method validated to 

Method 301 (Part 63, Appendix A) 

::;1;M 

Performance Test 

•l:i;li|2:iiK 

22 (Part 60, Appendix A) 

18 (Part 60, Appendix A) 

ASTM D1946-77 

ASTM D2382-76 

2, 2A, 2C, or 2D (Part 60, Appendix A) 
CONTROL DEVICE 

Incinerator 

Boiler/Process Heater <_ 44 MW and not 

using vent stream as primary fuel 

Boiler/Process Heater using vent stream as 

primary fuel 

Boiler/Process Heater > 44 MW 

Scrubber 

Flare 

MONTlpRING REQUIREMENTS 

Temperatures, depending on type of incinerator (See 63.117, 

Table 3) 

Combustion temperature 

No monitoring required 

No monitoring required 

L/G ratio, pH of scrubber effluent 

Presence of flame at pilot light 

RECOVERY DEVICE 

1 < TRE Value <. 8.0 

TRE > 8.0 

MONITORING REQUIREMENTS 

TRE parameters (i.e., flow rate, net heating value, etc.) 

Temps, specific gravity, steam mass flow, concentration level 

depending on type of recovery device (63.117, See Table 4) 

No monitoring required 

Change in construction/operation that change TRE value 
Control Device: 

Incinerator 

Boiler/Process Heater _<. 44 MW and not 

using vent stream as primary fuel 

Boiler/Process Heater > 44 MW 

Scrubber 

Flare 

All Devices 

Bypass Lines 

AU vents 

RECORPKEEPING/REPORTING R^UmEMENTS 

*Percent reduction of concentration of HAP or TOC 

Exceedances in 63.117, Table 3 

"Location of introduction of vent stream 

•Percent reduction in concentration of HAP or TOC 

Exceedances in 63.117, Table 3 

•Location of introduction of vent stream 

Percent reduction or outlet concentration of hyrogen halides and 

halogens 

Exceedances in 63.117, Table 3 

•Visible emissions reading 

Absence of pilot flame 

Operating parameters in 63.117, Table 3 

Notification to Administrator of compliance option 

Stream diverted through bypass line or inspection of seal not closed 

or seal changed if bypass line valve used 

•Schematic Diagram of vent streams, collection systems, fuel 

systems, combustion devices, and bypass systems 

Initial Reporting 

b> 
RECOVERY DEVICE 

1 < TRE Value <_ 8.0 

TRE > 8.0 

RECQRDKEEPING/REPORTING R^UIREMENTS 

AU measurements and calculations for TRE determination 

Exceedances in 63.117, Table 4 

AU measurements and calculations for TRE determination 

Change in construction/operation that change TRE value 

. . -
\ ' *. 

TABLE 3. MONITORING AND REPORTING/RECORDKEEPING REQUIREMENTS FOR COMPLYING 

WITH 98 WEIGHT-PERCENT REDUCTION OR TOC EMISSIONS OF 20 PPMV 

Type of 

Combustion 

Device Used for 

Compliance 

Thermal 

Incinerator 

Catalytic 

Incinerator 

.,. 

Monitoring 

Equipment 

Required* 

Temperature 

monitoring 

device 

(installed in 

firebox or in 

the ductwork 

immediately 

downstream of 

the firebox)c 

equipped with a 

continuous 

recorder 

{63.114(a)(1)) 

Temperature 

monitoring 

device 

(installed in 

gas stream 

immediately 

before and after 

catalyst bed) 

equipped with a 

continuous 

recorder 

{63.114(a)(1)) 

Parameters to 

be Monitored3 

Average firebox 

temperature 

Average 

temperature 

upstream and 

downstream of 

the catalyst 

bed 

Recordkeeping 

Requirements" 

Continuous 

records 

Continuous 

records 

Parameter I 

Boundary 1 

Exceedances to 1 

Record and 1 

Report3 | 

All 3-hour | 

periods of 1 

operation when | 

average j 

combustion | 

temperature is 1 

>28 °C (50 °F) | 

below the average f 

value measured V 

during the most 

recent 

performance test. 

All 3-hour 

periods of j 

operation when j 

the average 1 

temperature of | 

vent stream 1 

upstream of the [ 

catalyst bed is [ 

>28 °C (50 °F) 

below the average | 

value from the | 

most recent | 

performance test, f 
TABLE 3 (Continued) 

Type of 

Combustion 

Device Used for 

Compliance 

Catalytic 

Incinerator 

(Continued) 

Boiler or 

Process Heater 

with a design 

heat input 

capacity 

<44 megawatts 

and Vent Stream 

is not the 

primary fuel 

Flare 

Monitoring 

Equipment 

Required3 

Temperature 

monitoring 

device 

(installed in 

firebox) 

equipped with 

continuous 

recorder 

{63.114(a)(3)) 

Heat sensing 

device 

{63.114(a)(2)) 

Parameters to 

be Monitored3 

Average 

combustion 

temperature 

Presence of a 

flame at the 

pilot light 

Recordkeeping 

Requ i rements" 

Continuous 

records 

Continuous 

records 

Parameter 

Boundary 

Exceedances to 

Record and 

Report3 

All 3-hour 

periods of 

operation when 

the average 

temperature 

difference across 

the catalyst bed 

is <80% of the 

average 

temperature 

difference 

measured during 

the most recent 

performance test. 

All 3-hour 

periods of 

operation when 

average 

combustion 

temperature is 

>28 °C (50 °F) 

below the average 

value from the 

most recent 

performance test. 

All periods when | 

the pilot flame | 

is absent 1 

_ -». 
TABLE 3 (Continued). 

Type of 

Combustion 

Device Used for 

Compliance 

All combustion 

devices 

Monitoring 

Equipment 

Required3 

1. Flow 

indicator 

equipped 

with 

continuous 

recorder 

installed at 

all bypass 

lines to the 

atmosphere or 

2. Seal valves 

closed with 

car-seal or 

lock-and-key 

(63.114) 

configuration 

Parameters to 

be Monitored3 

1. Presence of 

flow 

diverted to 

the 

atmosphere 

from the 

control 

device or 

2. Monthly 

inspections 

of sealed 

valves 

Recordkeeping 

Requirements^ 

1. Continuous 

records of 

flow/no 

flow or 

2. Records of 

monthly 

inspections 

Parameter 

Boundary 

Exceedances to 

Record and 

Report3 

1. Periods 

when the 

vent 

stream is 

diverted 

through a 

bypass 

line or 

2. Inspections j 

that show 1 

valves are | 

not sealed 

closed or 

seal has 

been changed 
TABLE 3 (Continued) 

1 Type of 

1 Combustion 

1 Device Used for 

1 Compliance 

1 Scrubber (for 

vent streams 

with greater 

than 100 ppmv 

halogenated 

compounds. 

Note: 

Controlled by a 

combustion 

device other 

than a flare) 

Monitoring 

Equipment 

Required3 

pH monitoring 

device 

(63.114(a)(4)), 

and 

Flow meters to 

measure scrubber 

liquid influent 

and inlet gas 

flow rates 

Parameters to 

be Monitored3 

pH of scrubber 

effluent 

Scrubber 

liquid/gas 

ratio 

Recordkeeping 

Requirements" 

Continuous 

records 

Continuous 

records 

Parameter 

Boundary 

Exceedances to 

Record and 

Report3 

All 3-hour 

periods of 

operation when 

the average pH of 

the scrubber 

effluent is more 

than 1 pH unit 

below the value 

measured during 

the most recent 

performance test 

All 3-hour 

periods of I 

operation when j 

the L/G ratio is { 

less than 

95 percent of the 

value measured 

during the most 

recent 

performance test 

3Regulatory citations are listed in brackets. 

^Continuous records require measurements at least once every 15 minutes. 

cMonitor may be installed in the ductwork immediately downstream of the firebox before 

any substantial heat exchange is encountered. 
TABLE 4. MONITORING AND REPORTING/RECORDKEEPING REQUIREMENTS FOR 

MAINTAINING A TRE INDEX VALUE > 1.0 and < 8.0 

* 'V •> 

Final 

Recovery 

Device 

Absorberb 

Condenser0 

Monitoring 

Equipment Required3 

Scrubbing liquid 

temperature monitor 

equipped with a 

continuous recorder 

(63.114(b)(1)}, and 

Specific gravity 

monitor equipped 

with a continuous 

recorder 

(63.114(b)(1)) 

Condenser exit 

temperature 

monitoring device 

equipped with 

continuous recorder 

(63.114(b)(2)) 

Parameters to 

be Monitored 

Average exit 

temperature of 

the absorbing 

liquid 

Exit specific 

gravity (or 

alternative 

parameter that 

measures the 

degree of 

absorbing 

liquid 

saturation, if 

approved by the 

Administrator) 

Average exit 

(product side) 

temperature 

Recordkeeping 

Requirements0 

Continuous 

records 

Continuous 

records 

Continuous 

records 

Boundary 

Exceedances to 

Report3 

All 3-hour periods 

of operation when 

average 

temperature is 

>11 °C (20 °F) 

above the average 

value from the 

most recent 

performance test. 

All 3-hour periods 

of operation when 

average liquid 

specific gravity 

is >0.1 unit above 

or below the 

average value from 

the most recent 

performance test. 

All 3-hour periods 

of operation when 

average 

temperature is 

>6 °C (ll °F) 

above the average 

value from the 

most recent 

performance test. 

H 
P.73 

" l 

4 

• 

Hazardous Organic NESHAP 

Transfer Operations 

Similar to Benzene Transfer Operations NESHAP 

Applicable to loading of: 

Tank Trucks 

Rail Cars 

Uses vapor pressure and throughput to determine Group 1 and 

Group 2 racks 
Group 1 Racks 

• Group 1 racks 

vp _>_ 1.5 psia 

throughput _> 170,000 gal/yr 

• Control - 98% or < 20 ppmc 

• Control acid gases - 99% or 100 ppm 

• Expanded compliance provisions to additional control systems 

• Allow use of either Method 18, 25A, or 301 for compliance 

demonstration 

• Recordkeeping for Group 1 racks to process vents provisions 

4 \ 

V. 

fc 
P.75 

ATTACHMENT H 
Hazardous Organic NESHAP 

Storage Vessels 

Similar to NSPS for VOL Storage and Benzene Storage 

Differs in: 

Uses different vapor pressures and capacity criteria for 

control 

Added requirements for fittings for external floating roof 

tanks 

Added requirements for external floating roof tanks 

converted to internal floating roof 

Reporting: 

Initial report 

Reports when detect seal failure