P.1 

OAR Box 1875 

Prepped by Ollie Stewart 

Document Number: 

13) ll-E-31 

Docket Number: 

A-90-19 

Printed 12/1/2008 11:12:44 AM Sheet 13 of 86 
P.2 

t. > 

A-90-19 

y II-E-31 

MEETING NOTES 

DATE: February 11, 1992 

PLACE: Mutual Building, Durham, N.C. 

ATTENDEES: ^-~"nl ^' ' \\

 V« 

%%>"" ":v\ 

Dale Brooks, Chevron W^Xr-**" o.\Q9^

 V \ 

Clayton R. Freeberg, Chevron v \\ nCC, ^ ' \ 

Bruce Jordan, EPA \\^\ «*• **""*'\ \ 

Mary Tom Kissell, EPA Yv'-\ *.-^v • li- ' 

Penny Lassiter, EPA \ ^I| ^

 ::* 

Daphne McMurrer, EPA 

Jan Meyer, EPA 

Mark A. Piersante, Chevron 

Joan W. LaRock, Consultant to Chevron 

Bob Rosensteel, EPA 

SUBJECT: HON REGULATION 

PURPOSE OF MEETING 

The meeting was held at the request of Chevron Corporation. 

The purpose of this meeting was to discuss the provisions of the 

draft HON regulation. 

Meeting attendees were reminded that the regulation is in a 

draft form and must still undergo Office of Management and Budget 

review. Therefore, the materials presented at the meeting did 

not necessarily represent the final form of the proposed 

regulation. 

SUMMARY OF DISCUSSION 

A letter summarizing Chevron's staff's concerns served as 

the agenda for the meeting. This letter is included in the 

minutes as Attachment 1. Most comments in the Attachment 1 were 

discussed. The comments were grouped as: general, wastewater, 

process vents, storage tanks, transfer operations, equipment 

leaks, and, emissions averaging. Detailed comments for each 

group of topics were distributed during the meeting (Attachments 

2-8). The comments are a compilation of Chevron's staff's 

comments. 

The meeting discussion paralleled the order of the comments 

as they were presented in the attachment to the Chevron letter 

(Attachment 1 to these minutes). The minutes are organized in 

the same manner. The entire content of Chevron's staff's 
P.3 

* < J 

comments is not repeated below as it is available in the 

attachments. 

1. General Comments (Attachment 2). 

A. EPA Should Strive for Consistency Between the HON 

and Other Standards. Chevron reiterated the need for 

consistency across regulations. The company feels 

consistency is necessary for heading off confusion and 

contradictions in compliance. 

The EPA staff stated that it has been their intent to 

draft the HON to be consistent with other regulations. 

Cases when the HON may not be consistent with other 

regulations are when: more than one rule regulating the 

same emission points are not consistent; and, EPA or 

industry has experienced problems with the way a rule 

has been written. In the latter case, EPA may not use 

the same wording in a definition for example, so that 

past confusion or complaints will be avoided in the 

HON. When past rules are not consistent, EPA cannot 

make the HON consistent with every regulation. 

EPA staff asked Chevron to forward any inconsistencies 

found in the draft regulation to EPA. 

B. The Allowed Time Proposed for Submittal of the 

Implementation Plan is Too Short. Chevron proposes 

that the time allowed for the submittal of the 

implementation plan be increased from 120 days to at 

least one year for Subpart G. They also expressed 

concern about the implementation plan being 

incorporated into the permit and the resulting 

inflexibilities when modifications to the plan are 

necessary. 

EPA explained that this plan was not envisioned to be 

incorporated into the permit provisions in draft form 

since most permitting programs would not yet be in 

place at the time of HON compliance. However, the time 

for submittal of the implementation plan can be 

reconsidered. 

C. Estimated Capital Costs Appear Unrealistically Low. 

Based on industry experience installing controls 

required by the Benzene Waste NESHAP, Chevron believes 

industry's capital costs would exceeds estimate of $530 

million by as much as five times. 

Both Chevron and EPA agreed that without specific 

numbers and assumptions, this comment can not be 

adequately addressed. The cost estimate was based on 
P.4 

/ 

the data available to EPA and used existing peer 

reviewed control cost calculations. 

D. EPA Should Address How Toxicity Should Be 

Considered in Setting MACT Standards. The HON does not 

have different control requirements for different 

HAP's. Chevron recommended EPA request comments on 

this issue when the HON is proposed. 

EPA staff stated that the absence of indexing for 

toxicity was a policy decision based on the language of 

the 1990 Clean Air Act Amendments. 

E. The Proposed Quarterly Reporting Requirements 

Create an Excessive Burden. Chevron suggested an 

annual reporting requirement. 

EPA responded that quarterly reporting is an 

enforcement policy for NESHAP and that no reports are 

required if no exceedances exist for the quarter. 

F. Increase in CO and NOx Emissions from Combustion 

Technologies to Control HAP Emissions Appear 

Significant. Chevron staff stated that the 

significance of increased CO and N0X emissions from 

control devices should be discussed. 

EPA will add a statement to the preamble that EPA 

considers increased emissions from CO and NOx 

insignificant relative to the total inventory. 

2. Wastewater (Attachment 3). 

A. Benzene Waste NESHAP. Chevron emphasized again the 

need for consistency across regulations, in particular, 

the benzene waste rule. They cited biodegradation 

units as a specific example of potential inconsistency 

between benzene waste and the HON. 

EPA staff stated that specific Chevron concerns were 

unclear, but that the benzene waste rule and the HON 

are consistent. Dr. Meyer will contact Chevron 

reviewer Nick Spiridakis for clarification of the 

issues. 

B. Point of Generation. Chevron asked that EPA 

reconsider the definition of point of generation to 

allow the option of measuring VOHAP concentration at 

the point of exposure to the atmosphere to facilitate 

sampling. 
P.5 

/ 

EPA staff noted that the process unit alternative 

treatment standard provides the flexibility of 

measuring concentration at the point before exposure to 

the atmosphere. Also, the draft regulation allows 

knowledge of wastewater in lieu of taking measurements 

as a method to determine total VOHAP average 

concentration. 

C. Carbon Adsorber Standard. Chevron asked that the 

95% efficiency for carbon adsorbers be based on the 

HAP's listed in Table 1 of the regulation instead of 

total organics. 

EPA staff responded that Table 1 is a list of 110 

organic HAP's and Table 2 is a list of 399 SOCMI 

chemicals. EPA staff will contact Chevron reviewer 

Nick Spiridakis for further clarification and 

discussion of the issue. 

D. Recordkeeping. Chevron suggested that inspection 

frequency, including visual inspections, be decreased 

from quarterly to annually. 

EPA staff responded that many of these inspection 

requirements are the same as required in NSPS 

regulations. EPA also noted that the draft regulation 

was not meant to require a separate 90 day report 

unless excursions occurred. 

Chevron staff will supply EPA with specific problem 

areas. 

E. Reporting Requirements. Discussion of reporting 

requirements was subsumed by the recordkeeping 

discussion in paragraph D. above. 

F. Alternate Treatment Requirements. Chevron 

expressed concern about the alternative treatment 

requirement option and how it differs from the other 

treatment requirement options. 

EPA staff stated that they recognized the draft 

regulation required additional clarifications and 

especially so for the alternate treatment requirements. 

EPA staff supplied Chevron staff with a guide to the 

HON wastewater provisions (Attachment 9). 

G. Costs. Chevron staff estimates the costs of 

implementation are underestimated by EPA by an order of 

magnitude. The specific models and data used by 

Chevron staff to estimate costs were not available at 
P.6 

/ 

the time of the meeting. Chevron will forward specific 

cost information to EPA. 

EPA staff noted that average and facility based cost 

estimates are not appropriate because some process 

units have no wastewater controls. 

H. Emissions Averaging. Chevron supports the 

emissions averaging concept and is still reviewing the 

requirements in the draft regulation. 

I. Research and Development. Chevron supports the 

exclusion of research and development facilities from 

the regulation. 

3. Process Vents (Attachment 4). 

A. Definition of "Vent Stream" Should Exclude Streams 

Routed to Fuel Gas Systems. Chevron proposed that EPA 

modify the definition of "vent stream" to exclude 

process vents that are routed to a fuel gas stream 

where the fuel gas is used as the primary fuel for the 

boiler or process heater operation. 

EPA staff explained that although vent streams routed 

to a fuel gas stream used for primary fuel are not 

excluded from the definition of vent streams for HON, a 

TRE calculation is not necessary. TRE calculations are 

not necessary in general when vents streams are routed 

to combustion devices. One instance where this general 

statement is not true is when emissions averaging 

credit is taken for a vent; emissions must be 

calculated if the vent is to be included in emissions 

averaging. 

B. Definitions Between Sections Should Be Consistent. 

Relief valve discharges and equipment leaks are 

excluded in the definition of "relief valve" in §63.111 

of the HON. However, in §63.101, it says that relief 

valves discharges and leaks regulated under Subpart H 

are not regulated by the process vents provisions in 

Subpart G. 

EPA staff clarified that relief valves are not process 

vents for the purposes of the HON. 

C. Testing to Determine TRE Should Not Be Required for 

Streams Already Controlled. 

EPA staff agreed that TRE's should not be required for 

streams already controlled unless the vent will used in 
P.7 

emissions averaging. EPA will try to clarify 

regulatory language before proposal. 

D. EPA Should Strive for Consistency in Title I and 

Title III Control Measures. 

EPA staff noted that the only difference between Title 

I and Title III control requirements are applicability 

criteria. The difference in applicability criteria is 

an outgrowth of the differences in purpose and 

objectives of Title I and Title III. 

4. Storage Vessels (Attachment 5). 

A. No de minimis HAP cutoff. Chevron voiced concern 

about how "impurities" will be defined and whether 

HAP's present in low concentrations will be exempted as 

impurities are. They also recommended a numerical 

cutoff for exemption such as 5 percent. 

EPA staff agreed to reconsider a quantitative 

definition of impurity. 

B. Requirements for Existing Floating Roof Tanks Are 

Confusing. 

EPA staff does not understand what is confusing about 

this language. Chevron was asked to supply more 

detailed comments to help pinpoint the confusion. 

C. Differences and Similarities of Proposed Regulation 

to NSPS Subpart Kb. Chevron asked why EPA lowered key 

parameters from NSPS Subpart Kb for HON. They also 

found the 72 hours per year allowed for routine 

maintenance too restrictive. 

EPA staff reiterated that NSPS Subpart Kb is a Title I 

regulation and HON is a Title III regulation. 

Therefore, as previously discussed, the only difference 

between Title I and Title III control requirements are 

applicability criteria which is an outgrowth of the 

differences in purpose and objectives of Title I and 

Title III. 

D. General Comments. In the emissions estimating 

section of the draft regulation (page 587 of the 

December 24, 1991 draft), "p" is defined as the true 

vapor pressure of the HAP. Chevron believes "p" should 

be defined as the true vapor pressure of the product. 
P.8 

EPA staff will review whether "p" should be defined as 

HAP vapor pressure or product vapor pressure. 

5. Transfer Operations (Attachment 6). 

A. EPA Should Establish a de minimis Cutoff for 

Transfer Operations. Chevron recommended that EPA: 

adopt a definition for impurities consistent with the 

equipment leaks regulation; and, adopt 340,000 gallon 

per year exemption level for annual loading volume 

which is consistent with the benzene transfer NESHAP. 

EPA staff agreed to reconsider a quantitative 

definition of impurity. 

B. EPA Should Consider an Emission Rate Standard 

Instead of a Percent Efficiency Standard. Chevron 

recommended EPA delete the 95/98 percent standard and 

replace it with a HAP mass rate per liter loaded 

standard. 

EPA staff noted that the draft regulation is consistent 

with the benzene transfer rule and referred Chevron 

staff to the March 7, 1990 Federal Register for a more 

in-depth discussion. 

C. Responsibility for Tank Truck/Rail Car Vapor 

Tightness Should Rest on Tank Truck/Rail Car Operator. 

EPA staff thinks both parties are legally liable and 

will clarify the decision in the preamble. 

D. Estimated Cost Effectiveness Appears 

Unrealistically Low. 

EPA staff could not respond to Chevron staff's comments 

without specific knowledge about cost data and 

modelling assumptions. 

E. Scrubber Efficiency Requirement for Hydrogen 

Halides/Halogens Should Be Lower. Chevron recommended 

a scrubber efficiency of 98 percent instead of the 99 

percent required in the draft regulation. 

EPA staff asked that Chevron submit any relevant data 

for EPA review and evaluation. 
P.9 

/ 

6. Emissions Averaging (Attachment 7). 

A. HON Baseline Will Cause Reductions to be Postponed. 

EPA staff questioned the significance of these 

potential delays and emphasized that only the 

difference between required emission controls and 

emissions controlled more stringently may be included 

in emissions averaging calculations. 

B. Environment Benefits if Averaging Is Allowed Across 

Source Categories. Chevron suggested that EPA allow 

emissions averaging to include any point within the 

fence line of a contiguous facility, not just emission 

points regulated by the HON. 

EPA staff stated that the Office of General Counsel has 

made a legal finding that the scope of averaging 

systems is limited by statue to a single standard. 

C. Credit for Certain Shutdowns. 

EPA staff clarified that those shutdowns associated 

with pollution prevention would be creditable under 

current emissions averaging policy. 

D. Mandated "Cook Book" versus Case-by-Case. Chevron 

commented that case-by-case determinations for 

emissions averaging would work better and provide more 

flexibility. 

EPA staff stated that for emissions averaging to remain 

enforceable and palatable to States, the "cook book" 

approach would have to remain. The States are 

concerned that compliance and enforcement will be 

greatly complicated by the emissions averaging 

provisions. 

7. Equipment Leaks (Attachment 8). Equipment leaks 

comments were not discussed due to time constraints. 
P.10 

Attachment 1 

•-> JOANWLAROOC 

GOVERNMENT RELATIONS CONSULTANT 

February 7,1992 

Mr. Bruce Jordan 

Director, Emission Standards Division 

U. S. Environmental Protection Agency 

Office of Air Quality Planning & Standards 

MD-13 

Research Triangle Park, NC 27711 

Dear Bruce, 

My client conducted a quick review of the December 24,1991 draft of the proposed 

Hazardous Organic National Emission Standard for Hazardous Air Pollutants (the 

HON). Subpart A was not included in our package, so we were unable to refer to it 

when referenced in other sections. We also did not have access to the Background 

Information Documents and thus were not able to provide comments on them. 

Our initial, overall impression is that the proposed HON is cohesive but very 

complex, and imposes cumbersome reporting and recordkeeping burdens on 

industry. Attached are specific comments addressing our concerns. 

A few key points from our attached comments are as follows: 

• EPA should lengthen the time allowed for submittal of the 

implementation plan from 120 days to at least one year for Subpart G. 

• EPA should strive for consistency between the HON and other relevant 

standards such as NSPSs, the Benzene Waste NESHAPs, and CTGs, where 

appropriate. 

• The baseline date for emissions averaging needs to be changed to allow 

credit for emission reductions that occur before the promulgation date of the MACT 

rule, and a five-year banking provision needs to be added. 

• We suggest EPA set a storage vessel exemption at <5% total HAPs, 

which is the exemption cutoff for the equipment leak regulation, and where 

appropriate, attempt to make provisions elsewhere in the rule consistent with those 

for equipment leaks (Subpart H). 

• We believe the EPA's estimated capital cost of $530 million to comply 

with the HON is unrealistically low. We urge EPA to confirm their current capital 

cost estimate to ensure it is as realistic as possible. We also suggest that EPA confirm 

their cost effectiveness estimates. 

801 PENNSYLVANIA AVENUE, N.W. • SUITE 1213 • WASHINGTON, D.C. 20004 • (202) 628-4322 • FAX (202) 628-4323 
P.11 

s 

Mr. Bruce Jordan 

Page 2 

My client and I look forward to discussing our comments with you in more detail 

on February 11 at 10:00 a.m. in your office in Durham, NC. We will continue our 

detailed review of the proposal and plan to pass on to you any additional comments. 

We are available at your convenience to discuss any aspect of this important 

proposal with you and your staff. Thank you for the opportunity to provide you 

with comments. 

Sincerely, 

iv 

Joan W. LaRock 

Attachment 
PRELIMINARY COMMENTS ON THE 

DRAFT HAZARDOUS ORGANIC NESHAP (HON) 

February 11,1992 

GENERAL COMMENTS 

A EPA Should Strive for Consistency. 

We believe that EPA should strive for consistency between the HON and other existing 

standards, such as NSPS, Benzene Waste NESHAPS and CTGs. If EPA only departs from 

regulatory precedent where it is truly warranted, the HON will be more readily accepted by 

all parties. EPA should also consider extending key provisions in the equipment leak 

negotiated rule to other parts of the HON. 

B Implementation Plan Submittal Time Is Too Short. 

EPA should lengthen the time allowed to submit Implementation Plans from 120 days 

(pg. 644) to at least one year for Subpart G. This longer time is necessary to gather data, 

conduct sampling, evaluate compliance alternatives, and make decisions regarding the use 

of emissions averaging. 

Q Estimated Capital Costs Appear Low. 

Although we did not have time to estimate the capital costs associated with implementation 

of the HON, we believe EPA estimated capital cost of $530 million (pg. 66) is much too low. 

We urge EPA to develop cost estimates that are as realistic as possible based on input from 

impacted companies and trade organizations. We also suggest that EPA perform their 

economic analysis on a cumulative rather than source specific basis. 

D EPA Should Address How Toxicity Should Be Considered In Setting MACT Standards. 

The proposed HON treats all HAPs as though they are of equal toxicity. But in the Early 

Reduction Credit rule and the 112(g) Modifications rule, toxicity of HAPs are taken into 

account. We recommend that EPA solicit comment in the preamble on this issue, 

particularly on how toxicity can be factored into determining cost effectiveness and which 

compounds should receive more stringent control. 

E Quarterly Reporting Requirements Creates Excessive Burden. 

Although quarterly reporting is required under several exiting standards, we believe that the 

proposed quarterly reporting requirements for Subpart G will be excessive. We recommend 

an annual reporting frequency. 

p Increase in CO and NOv Emissions from Combustion Appears Significant. 

EPA estimates the combined increase in CO and NOx emissions from the use of 

combustion control devices to be 20,660 tons per year (pg. 65). This estimate ignores any 

increases in CO and NOx emissions resulting from the use of combustion devices to control 

equipment leaks and storage vessels. Even so, the estimated increase appears significant. 

Yet, there is no discussion of the impact of these emissions. 

WASTEWATER -

This section of the HON increases the record-keeping burden due to the large list of chemicals. 

In order to make the rule more workable, there are a number of aspects that need to be improved: 
P.13 

/ 

A HON Controls Requirements for Benzene Should Be the Same as the Benzene Waste 

NESHAP (BWN) Regulation. 

BWN exempts enhanced biodegradation from control requirements as long as the inlet 

concentration is less than 10 ppm benzene. The HON, on the other hand, subjects 

biological treatment to the same mass removal requirements as other treatment processes. 

If the HON is not modified, facilities may be subject to additional control requirements 

beyond what they have already started to construct to comply with the BWN. 

B Point of Waste Generation Should Be Moved Downstream Coincident with Actual 

Emission Points. 

We recommend that facilities that now have controlled sewers be allowed to assign points 

of waste generation at actual emission points since upstream points are already 

controlled.In order to prevent unknowing dilution of waste streams, a 1-megagram facilitywide limit might be applied to the treatment system effluent. 

Q The Standard for Carbon Adsorption Includes Compounds Which Are Not Contained 

in Table I (Organic Hazardous Air Pollutants). 

Propane and butane are not listed in Table I (pg. 316) and should not be covered in the 

adsorption standard since these substances are not HAPs. These two compounds are not 

readily adsorbed by carbon and including them would make compliance difficult. 

Q The Frequency of Inspection and Reporting Are Not Justified. 

Once a facility has installed equipment to treat VOHAP in wastewater streams, the benefit 

derived from frequent inspections of incidental sources is questionable. We recommend 

that yearly inspections and exception reporting be implemented rather than the proposed 

quarterly inspection and reporting. 

E The Detail and Volume of Data Required in 90 Days Is Unrealistic. 

The requirement to submit initial data within 90 days (pg. 574) is inconsistent with the 120 

day requirements for the other HAP sources. We recommend extending the data 

generation phase to a year or reduce the detail and volume of data. We urge EPA to 

examine the benefit of providing flow diagrams before the compliance date. The volume 

of data required would impose enormous burdens on both the regulated community to 

produce and EPA to process without corresponding benefits. 

p The Standard for Treating Waste Streams Combined "Within" Process Units Is 

Inconsistent with that for "Downstream" of Units. 

We recommend that EPA add the options of providing a stream stripper or requiring 99% 

mass removal after determining which wastewater streams within the process unit were 

above 500 ppm total VOHAP. This would be consistent with the standard for combining 

streams downstream of process units. 

Q Costs to Comply with the Wastewater Section Are Understated. 

The average facility capital expenditure of $570,000 is low considering the number of 

streams and requirements. One steam stripper is likely to cost in excess of $1,000,000. 

The total expenditure for one facility could easily exceed $5,000,000 or more. Economic 

analysis should be on a cumulative rather than source specific basis. Otherwise, each 

source can seem to have a minor impact independently while the total cost of all sources 

is high. 
P.14 

PROCESS VENTS 

A Definition of "Vent Stream" Should Exclude Streams Routed to Fuel Gas Systems. 

In the HON, vent streams that are mixed with primary fuel to a boiler or process heater are 

exempt from performance testing and monitoring because EPA believes these situations 

already provide 98% control. We agree. And, EPA should reduce the reporting burden 

further (e.g., TRE determination) by modifying the "vent stream" definition to exclude 

streams routed to fuel gas systems that fuel boilers and process heaters since these 

streams are already adequately controlled. 

• Definitions Between Sections Should Be Consistent. 

IV. 

The definition for "vent stream" in Section 63.111 contains an exclusion for relief valve 

discharges and equipment leaks. However, on page 45 and in Section 63.101, statements 

are made that process vents exclude relief valve discharges and leaks regulated under 

Subpart H. The latter phrase should be deleted so aH relief valve discharges and equipment 

leaks are excluded regardless of whether they are regulated under the HON equipment 

leaks provisions. 

Q Testing to Determine TRE Should Not Be Required for Streams Already Controlled. 

The proposed HON requires initial testing of all vent streams to determine which ones are 

de minimis (exempt from HON controls) from those subject to controls. Streams that are 

already controlled should not be required to perform the initial testing to determine the TRE 

index values. 

D EPA Should Strive for Consistency in Title I and III Control Measures. 

To avoid confusion for industry and state regulators, EPA should only create differences 

between NSPS/CTG and HON where it is truly warranted. Two inconsistencies that need 

to be addressed are: 

1. SOCMI definition in the CTG for SOCMI distillation and reactor processes needs to 

be clarified as in the HON, which clearly excludes refinery processes. 

2. The proposed NSPS for SOCMI reactor processes and the NSPS for SOCMI 

distillation operations require performance testing and temperature monitoring for 

boilers/heaters smaller than 44 megawatts. These NSPSs should be changed to 

reflect EPA's new thinking in the HON that aH boilers/heater are exempt from such 

testing and monitoring where the vent stream is mixed with the primary fuel. 

STORAGE TANKS ; ' 

A De minimis HAP Content Should Be Specified. 

The HON exempts tanks that store stocks that contain organic HAPs as impurities (pg.46). 

"Impurities" is ill-defined. We suggest that EPA set the tank exemption at <5% total HAPs, 

which is the exemption cutoff in the equipment leak section of the HON. 

B Must Existing External Floating-Roof Tanks Be Converted to Internal? 

The HON states on page 403, "An existing external floating-roof vessel shall be converted 

to an internal floating-roof vessel." We suggest that EPA clarify this section to allow other 

control options outlined in the HON (e.g. external floating-roof tank with secondary seals 

-3-
P.15 

and controlled fittings, closed vent system with control device, or equivalent). We assume 

that we would not be required to convert all existing external floating-roof tanks to internal 

as this would be very onerous. 

v TRANSFER OPERATIONS 

VI. 

A EPA Should Establish a De Minimis HAP Cutoff for Transfer Operations. 

The HON covers terminals which load more than 170,00 gallons per year of HAPs with a 

vapor pressure of 1.5 psi and greater. Stocks with only HAP impurities are exempt, but the 

impurity level is not defined. We recommend that EPA adopt a definition which is 

consistent with the equipment leak part of HON - 5% total HAPs as the de minimis cutoff. 

The proposed exemption level for the annual loading volume is significantly lower than the 

Benzene Transfer NESHAP. We recommend that EPA adopt the 340,000 gallon per year 

throughput exemption for the HON to be consistent with the Benzene NESHAP. 

B Percent Efficiency vs Emission Rate Standard. 

Over the last 20 years the control standard for gasoline marketing has shifted from a 

percentage basis to an emission rate basis (e.g., 35mg/l NSPS for Bulk Terminals) because 

it's easier for performance testing. For this reason and consistency with existing loading 

regulations, we recommend that EPA delete the 95%/98% standard and instead set a mass 

HAP rate per liter loaded. 

Q Responsibility for Vapor Tightness of Cargo Vessel Should Rest On Tank Truck/Rail 

Car Operator. 

Owners and operators of SOCMI facilities rely heavily on third party operators of tank trucks 

and railcars to handle transportation of chemical products. We therefore believe the 

responsibility for ensuring the vapor tightness should rest on the owner/operator of the tank 

truck or rail car. This can be done by providing documentation to the plant operator that 

ail trucks or railcars being loaded are certified as vapor-tight. 

D Estimated Cost Effectiveness Appears Unrealistically Low. 

We were unable to evaluate EPA's estimated cost effectiveness of $10,000 per ton, because 

EPA did not provide a detailed cost breakdown. However, based on our experience with 

tank truck loading terminals for small transfer operations, we believe EPA's estimated cost 

effectiveness is too low. We urge EPA to review their estimate to ensure the estimated cost 

effectiveness is as realistic as possible. 

EQUIPMENT LEAKS 

A Equipment Leak Control Is Not a "Cost Savings." 

We do not believe control of emissions from equipment leaks represent a net cost savings 

(pg. 69). In most cases the value of product saved is small compared to the cost of 

"Inspection and Maintenance" programs. 

B Emissions Can Be Quantified from Equipment Leaks. 

We believe emissions can be calculated from fugitive equipment leaks. The HON implies 

that emissions averaging cannot be used for these sources because the emissions cannot 

be quantified (pg. 166). The regulations should state that equipment leaks cannot be used 

for emissions averaging because the negotiating committee could not agree on this issue. 
P.16 

C. Minor Corrections. 

The equipment leak regulation is the same as the negotiated agreement, but there are some 

typographical errors. We will provide you a list of those errors. 

VII. 

EMISSIONS AVERAGING 

A Proposed Baseline Will Cause Emission Reductions to Be Postponed. 

The HON proposes not to allow credit for emission reductions that occur before the 

promulgation date of the MACT rule. This creates a disincentive for industry to implement 

early reductions, and some companies may even pull out of EPA's 33/50 Program because 

of this baseline issue. We recommend that EPA add a 5-year banking provision that allows 

industry to reduce emissions when the opportunity arises and not be forced to wait until the 

MACT rule is finalized. The baseline period could be the time when the credit application 

is submitted. Another baseline option is 1990 when the Clean Air Act was enacted. 

B The Environment Can Benefit More If Averaging Is Allowed Across Source Categories. 

With the proposed discount factor provision, the averaging approach will create more 

reductions than straight MACT. Therefore, EPA should encourage more "bubbling" by 

allowing facilities to reduce emissions across different source categories if the emission 

points are within the fenceline of the facility, such as allowed in the Early Reduction Credit 

rule. EPA states in the HON (pg 166) that the Act's "floor requirement" for MACT prevents 

EPA from allowing averaging across source categories. We read the statutory language as 

giving EPA much discretion in this area. We recommend that EPA allow averaging across 

categories. An additional benefit is that other sources may be discovered that would 

otherwise remain uncontrolled. 

Q EPA Should Give Credit for Certain Shutdowns. 

The HON disallows credit for any shutdowns, while the criteria pollutant trading policy 

allows credit for certain shutdowns, such as replacements or future shutdowns that received 

prior agency review. EPA should retain the principles in the criteria pollutant trading policy 

that evolved over the last decade after much give-and-take from all parties. 

0 Mandated "Cook Book" vs Case-by-Case. 

The HON includes a very complex emission accounting system with fixed control 

efficiencies and emission estimating equations. We recommend that EPA not dictate a 

single, rigid formula. It will be under constant attack and require frequent updates. EPA 

should set key principles, such as "quantifiable" and "enforceable," and put the burden on 

industry to meet those parameters. Setting control efficiencies removes incentives for 

industry to improve performance. 

-5-
Attachment 2 

ATTACHMENT I 

GENERAL COMMENTS 

Our comments on the proposed HON are based on a rather quick review of the approximately 800 

pages. As we have a chance to review it in greater detail, we will likely discover other issues and 

concerns. Subpart A was not included in the HON package we received, so we were unable to 

refer to it when referenced in other sections. We were also able to review the test methods 

specified in the proposal only briefly, but will review them in more detail in the near future. Since 

the HON is very complex, EPA may want to consider developing concise, but detailed summaries 

of the specific requirements to facilitate review. 

A. EPA Should Strive for Consistency Between the HON and other Standards. 

We believe EPA should strive to make the HON consistent with other existing 

regulations and standards. We understand the EPA has used existing criteria 

pollutant regulations (eg; NSPS) as a reference in developing the HON, and we 

fully endorse this approach. In fact, we recommend that EPA not depart from those 

well-established requirements unless EPA can clearly justify the difference. 

Coordination between Title I and Title III controls will be much easier if the actual 

requirements are as similar as possible. This will make things less confusing to 

state regulators and industry. 

Areas that can be made more consistent include: 

• Instead of a "percentage control" type emission standard, the HON should 

use a mass limit as in the NSPS for Gasoline Bulk Terminals. 

• The baseline period and banking provisions specified in the criteria pollutant 

trading policy should be used in the HON's emission averaging provisions. 

• The throughput and equipment size cutoffs in respective NSPSs should be 

the same in HON unless the need for a change is clearly demonstrated. 

• The equipment leak standard (Subpart H) applies to equipment containing or 

contacting process materials that are 5% or greater VHAP. We recommend 

using this criterion in Subpart G where appropriate for sources such as 

storage vessels and transfer operations. Since the concepts in Subpart H 

were agreed to by a negotiating committee, there is precedent that they are 

acceptable to a number of interest groups. We believe Subpart G as 

proposed can be improved by incorporating some of the concepts contained 

in Subpart H. 

B. The Allowed Time Proposed for Submittal of the Implementation Plan is Too 

Short. 

As proposed, a source-specific implementation plan for existing sources must be 

submitted within 120 days of promulgation of the final HON (p. 644). Each 

emission point must be identified as to its location and whether it is a Group 1 or 

Group 2 emission point. For process vents, actual source testing is required to 

obtain the information needed to calculate the TRE index value. Other data and 

1-1 
P.18 

HON PROPOSAL 

Detailed Comments 

Page 2 

information is required in order to evaluate compliance alternatives and determine if 

it is beneficial to use emissions averaging. 

We believe the time allowed for submittal of the implementation plan should be 

increased from the proposed 120 days to at least one year for Subpart G. This will 

ensure that a facility has the time it needs to develop an effective implementation 

plan. 

C. Estimated Capital Costs Appear Unrealisticallv Low. 

EPA estimates the capital costs to comply with the HON are $530 million (p. 66). 

We believe this estimate is unrealistically low, based on our experience with 

installing controls required by Benzene Waste NESHAPS. It would therefore seem 

that industry's capital costs to comply for the entire SOCMI will be perhaps five 

times as high the EPA estimate. 

We urge the EPA to revisit their estimate of the capital costs to make sure they are 

as realistic as possible. We suggest that the estimate be based on input from the 

SOCMI and trade associations. We would be happy to work directly with EPA on 

this issue. 

D. EPA Should Address How Toxicity Should Be Considered in Setting MACT 

Standards. 

The proposed HON treats all HAPs as though they are of equal toxicity. However, 

in the Early Reduction Credit rule and Section 112(g) Modifications rule, the 

toxicity of the HAPs are taken into account. We strongly recommend that EPA 

solicit comment on this issue in the preamble of the proposed HON. In particular, 

we suggest EPA solicit comment on, and evaluate how, toxicity can be factored into 

the determination of cost effectiveness. EPA should also evaluate which HAPs 

require more stringent control. 

E. The Proposed Quarterly Reporting Requirements Create an Excessive Burden. 

Although quarterly reporting is required under several existing standards, we 

believe that the proposed quarterly reporting for Subpart G is a bit excessive. This 

is primarily due to the volume of information required and the number of chemicals 

which are covered by the proposal, some which may be present only in trace 

amounts. Ongoing chemical analyses may be necessary to obtain the information 

required for the quarterly report. We suggest that EPA consider an annual reporting 

interval for Subpart G. 

F. Increase in CO and NOX Emissions from use of Combustion Technologies to 

Control HAP Emissions is Significant 

The EPA has estimated the increase in CO and NOX emissions resulting from the 

use of combustion technologies that will be used for HAP control to be 20,660 tons 

1-2 
P.19 

HON PROPOSAL 

Detailed Comments 

Page 3 

per year (p. 65). However, this ignores any increases in CO and NOX emissions 

resulting from the use of combustion technologies to control equipment leaks and 

storage vessels. There should be some CO and NOX emissions resulting from 

control of these sources. 

However, we believe that even the current estimate of increased CO and NOX 

emissions is significant. There should be some discussion as to the significance of 

these emissions. 

1-3 
Attachment 3 

WASTEWATER HON COMMENTS 

A. Benzene Waste NESHAP (BWN) 

SOCMI facilities are currently dealing with compliance aspects of 

BWN. It is extremely important that EPA takes a consistent 

approach in the HON and BWN with regard to wastewater operations to 

prevent duplication of work and having to modify or remove control 

equipment installed to comply with BWN. Since there will be at 

least a three year lag between compliance dates for the two 

regulations, facilities cannot base today's decisions on tomorrow's 

requirements unless there is a clear understanding of what those 

requirements will be. By applying a consistent approach to control 

requirements the environment can be protected without duplicating 

money and effort. Since the oil refining industry is also subject 

to BWN and will be subject to its own HON even further in the 

future than SOCMI plants, there is even less reliability in 

predicting the future. Consistency here is vital. 

A specific area of inconsistency is the issue of biodegradation. 

In BWN, an enhanced biodegradation unit is exempt from controls if 

the inlet benzene concentration is less than 10 ppm. In the HON, 

on the other hand, a biodegradation unit is required to demonstrate 

required mass removal. We suggest that concentration based 

guidelines may be developed by EPA to allow a similar exemption 

according to total VOHAP concentration. 

B. Point of Waste Generation 

The definition of "the point of waste generation" in the regulation 

it is necessitates sampling and analyzing each wastewater stream as 

it leaves the process and before it is mixed with other streams or 

exposed to the atmosphere. This definition is consistent with BWN. 

Because of BWN, many facilities have sampled these streams and have 

since, or will be, combining and/or hardpiping the streams so that 

it is either impossible or nearly so to obtain samples required for 

the HON. Also, in many cases there is no opportunity for emission 

to atmosphere to occur because of the use of closed systems. We 

suggest that facilities be given the option of measuring the VOHAP 

concentration at the point of first exposure to atmosphere for 

those instances where upstream samples do not add additional or 

unique information. For this option, EPA can impose the facility 

wide limit of 1 megagram per year on total VOHAP measured at the 

downstream effluent point. This would obviate EPA's concern over 

using dilution as a means of complying. 
P.21 

C. Carbon Adsorber Standard 

The regulation specifies that a carbon adsorber control device 

shall have an efficiency of 95% total organics, not including 

methane and ethane. However, the definition for reference control 

technology states that 95% HAP must be removed in a carbon 

adsorber. We suggest that the basis be set as 95% Table I organic 

hazardous air pollutants. If this basis is adopted it would not 

require measuring non-hazardous compounds which are not readily 

adsorbed on carbon, such as propane and butane. 

D. Record Keeping 

The draft regulation requires a facility to perform quarterly 

inspections and to file quarterly reports. For an affected 

facility this would result in very high costs without corresponding 

benefit. Once a facility has installed equipment to treat VOHAP in 

wastewater streams the benefit derived from frequent inspections on 

incidental sources is questionable. As an alternative we suggest 

that we initially the inspection and reporting schedule be less 

frequent but subject to modification if data so warrant. 

Specifically, we suggest that a-facility perform yearly inspection 

and report exceptions to the standards. 

E. Reporting Requirements 

The regulation would require that a facility submit both flow 

diagrams and detailed process information within 90 days after the 

effective date. The BWN similarly required that a complete listing 

of streams and applicability be submitted within 90 days. Many 

facilities found it was impossible to complete the inventory, 

sampling, analytical and data reduction tasks since there were 

literally thousands of streams which required documentation. As a 

result, many facilities had to submit amended reports subsequent to 

the 90 day requirement. Of course, in BWN the only chemical of 

concern was benzene. It is expected that compliance with the 

reporting provisions of the HON will be even more problematical for 

several reasons. First, more streams are impacted by the 

regulation and many more chemicals will have to be analyzed. 

Facilities will also be using a new method (25D) which will 

probably have some implementation problems. Finally, the 

additional stipulation to provide flow diagrams of the complete 

sewer systems will be a very labor intensive and time consuming 

task. Since all the streams will be documented flow diagrams would 

have dubious value. Since the record keeping burden is increased 

we suggest as an alternative that stream tables can be provided in 

six months after promulgation and that the issue of the need for 

flow diagrams be revisited by EPA. In any case, there does not 

appear to be any significant benefit to providing those 

diagrams before the actual regulation compliance date. 
P.22 

F. Alternate Treatment Reguirements 

As currently proposed the standard for treating waste streams 

combined within process units is different than the standard for 

wastewater streams combined downstream of process units. 

Specifically, the cutoff for in-process combination is 10 ppm total 

VOHAP while it is 500 ppm total VOHAP for downstream combination. 

This is done, apparently, to avoid dilution of waste streams. For 

streams less than 1000 ppm total VOHAP this can result in <99% 

removal requirement. For streams greater than 1000 ppm VOHAP 

removal requirements would be > 99%. This is because the removal 

requirement is a stream containing < 10 ppm total VOHAP. We 

suggest that the requirement should be consistent throughout the 

regulation. This can be done by adding the options of providing a 

steam stripper or requiring 99% mass removal after determining 

which wastewater streams within the process unit were above 500 ppm 

total VOHAP. 

G. CQ8t8 

Overall, the cost estimates to comply with the wastewater section 

appear overly optimistic. Assuming EPA's estimate that 340 

facilities would be impacted, the average capital expenditure per 

facility would be $570,000. Based on the experience in complying 

with BWN this number may be under estimated by an order of 

magnitude. Additionally, in discussing the economic impact on 

wastewater facilities the regulation considers source specific 

economic impacts only. This type of analysis understates the 

importance of each source contribution since it does consider the 

economic impact of the regulation as a whole. We suggest that the 

economic impacts should, instead, be based on a cumulative 

analysis. 

H. Emissions Averaging 

In general we support the concept of emissions averaging and offsets. We recognize that more time needs to be devoted to the 

actual proposals and calculation procedures before we can feel more 

comfortable with this section of the regulation. 

I. Research and Development 

We support the exclusion of R&D facilities from the regulation. 

hon 2-92a 
P.23 

Attachment 4 

ATTACHMENT III 

PROCESS VENTS 

A. DEFINITION OF "VENT STREAM" SHOULD EXCLUDE STREAMS ROUTED TO 

FUEL GAS SYSTEMS. 

Under the proposed HON, any vent stream that is mixed with the primary fuel to a boiler 

or process heater is exempt from the initial performance test and temperature 

monitoring requirements regardless of size (+/- 44 megawatts) because available 

information shows that boilers and process heaters achieve 98% reduction in the 

organic content of the process vent stream (pages 133 and 136). EPA has determined 

that management of the vent stream in this manner complies with the proposed emission 

reduction standards and that further evaluation through performance testing or 

monitoring is not required. 

Based on this information, EPA should reduce the reporting burden further (e.g., TRE 

determination) by modifying the definition of "vent stream" contained in 63.101 and 

63.111 to exclude process vents that are routed to a fuel gas system where the fuel gas 

is used as the primary fuel for the boiler or process heater operation since EPA has 

determined that they are already adequately controlled. 

B. DEFINITIONS BETWEEN SECTIONS SHOULD BE CONSISTENT. 

The definition for "vent stream" in Section 63.111 contains an exclusion for relief valve 

discharges and equipment leaks. However on page 45 in Section 63.101, statements are 

made that process vents exclude relief valve discharges and leaks regulated under 

Subpart H. These definitions should be reviewed for consistency and modified to ensure 

that ail relief valve discharges and equipment leaks are excluded regardless of whether 

they are regulated under the HON equipment leaks provisions. 

C. TESTING TO DETERMINE TRE SHOULD NOT BE REQUIRED FOR STREAMS 

ALREADY CONTROLLED. 

An initial test is required for all process vent streams to obtain the information 

necessary to calculate the TRE (Total Resource Effectiveness) index value. The TRE Index 

Value is used to determine whether the vent is a Group 1 (TRE < 1.0) or Group 2 (TRE > 

1.0) process vent. Group 1 process vents must reduce emissions of organic HAP using a 

control device (flare, process heater, boiler) or increase the TRE to greater than 1.0 by 

adding a product recovery device (such as an absorber, carbon adsorber, or condenser) 

or similar device. Group 2 process vents are not subject to the emission control 

requirements. 

Existing sources which are currently controlling process vents per the proposed 

standards should not be required to conduct an initial test to calculate the TRE index. 

These process vents would automatically be considered Group 1 vents unless otherwise 

demonstrated. A new source should only be required to calculate the TRE index value if a 

111-1 
P.24 

product recovery device is used to reduce emissions or to justify that a particular vent 

stream does not require the addition of emission controls. 

D. EPA SHOULD STRIVE FOR CONSISTENCY IN TITLE I AND III CONTROL 

MEASURES. 

On December 12, 1991, EPA released for public review the Control Technique 

Guidelines (CTG's) for SOCMI Distillation Operations and SOCMI Reactor Processes. 

Based on a review of the CTG and the proposed SOCMI HON for process vents, the 

following issues regarding potential overlap are raised: 

Definition of SOCMI: The broad definition of SOCMI contained in the CTG could possibly 

draw in processes that have not been traditionally considered as SOCMI processes. To 

avoid confusion on the part of the regulated community, EPA should adopt a consistent 

definition of SOCMI processes that specifically excludes refinery processes as part of the 

CTG and the HON MACT standards. This would allow for a clear definition of which 

processes are covered and would be consistent with the tentative schedule for refinery 

MACT. 

For purposes of the SOCMI HON, petroleum refinery processes are not part of the SOCMI 

source category even if one of the processes produce feedstocks that are supplied to a 

SOCMI chemical manufacturing process. Examples of refinery processes not covered by 

the HON was developed as part of the equipment leaks negotiated standards (see attached 

list). A separate HON will be developed for petroleum refineries. The proposed refinery 

HON including process vents is expected to be issued late November, 1993. For purposes 

of the CTG, the definition of SOCMI is much more general and includes any process that 

produces or uses a chemical listed in the proposed guideline. Facilities located in nonattainment areas must be in compliance with the CTG standards by May, 1995. 

Potential Differences in Requirements: Under the proposed HON, any vent stream that is 

mixed with the primary fuel to a boiler or process heater is exempt from the initial 

performance test and temperature monitoring requirements regardless of size (+/- 44 

megawatts). EPA has determined that management of the vent stream in this manner 

complies with the control requirements (achieves 98% reduction) and that further 

performance testing and monitoring is not required. 

On pages 133 and 136, the statement is made that the proposed SOCMI reactor process 

NSPS (Subpart RRR) will require testing and temperature monitoring of process 

boilers and heaters of less than 44 megawatts regardless of how that vent stream is 

introduced in the combustion unit. Since EPA has made a decision not to require 

monitoring and testing for units burning vent streams mixed with primary fuel under 

the SOCMI HON, the proposed NSPS for reactor processes, the existing NSPS for 

distillation operations and the CTG should be changed to reflect this and provide 

consistency between Title I and Title III. 

III-2 
P.25 

TABLE 8. EXAMPLES OF REFINERY PROCESSES EXCLUDED 

FROM THE NEGOTIATED REGULATION 

Thermal Processes 

Gas-oil cracking 

Thermal cracking 

Visbreaking 

Coking (fluid) 

Coking (delayed) 

Coking (flexi) 

Other 

Catalytic Cracking 

Fluid 

Other 

Catalytic Reforming 

- Semiregenerative 

conventional catalyst 

bimetallic catalyst 

Cyclic 

conventional catalyst 

bimetallic catalyst 

Other 

continuous catalytic reforming 

conventional catalyst 

bimetallic catalyst 

Catalytic Hydrocracking 

- Distillate upgrading 

- Residual upgrading 

- Lube-oil manufacturing 

Other 

187 

 
P.26 

TABLE 8. (Continued) 

Catalytic Hydrorefining 

Residual desulfurizing 

Heavy gas-oil desulfurizing 

Cat-cracker and cycle-stock feed pretreatment 

Middle distillate 

Other 

Fractionation 

Pipe stills 

Light ends 

- Gas recovery units 

On-Site Transfer and Blending Operations of 

gasoline and other fuels 

Lube Oil and Specialties Processes 

Catalytic Hydrotreating 

Pretreating cat-reformer feeds 

- Naphtha desulfurizing 

Naphtha olefin or aromatics saturation 

Straight-run distillate 

Other distillate 

Lube-oil "polishing" 

Other 

Alkylation 

Sulfuric acid 

Hydrofluoric acid 

Refinery Polymerization Processes 

Crude Units (Atmospheric and Vacuum) 

Refinery Isomerization Process 

188 
P.27 

Attachment 5 

Attachment IV 

COMMENTS ON STORAGE VESSEL PROVISIONS 

A. There is no de minimis HAP cutoff 

There is no de minimis % HAP cutoff in the existing regulation, 

other than an exemption for stocks which "contain organic HAPs only 

as impurities" (pg 46). We have two concerns with this provision. 

There will be cases where HAPs are present in organic stocks at low 

concentrations, but not as impurities. It may not be costeffective to control emissions from tanks containing these stocks. 

Also, it would be helpful to have an exemption definition more 

quantifiable than 'as an impurity1. We recommend one identical to 

the equipment leak regulation (< 5% total HAPs). 

B. The requirements for existing floating roof tanks are confusing 

Section (a) (i) of the HON (pp. 396) states that all new and 

existing Group 1 storage vessels must meet the provisions of 

paragraphs (b), (c), (d) , or (e) . In Section (d) however (pp. 

403), it states that "An existing external floating roof vessel 

shall be converted to an internal floating roof vessel." 

The word "existing" makes this confusing. Must all existing Group 

1 external floating roof tanks be converted to internal floating 

roof tanks, or is this just one of several options (ie. are options 

(c) and (e) also available)? 

C. The proposed regulation is similar to NSPS Subpart Kb, but there 

are some important differences 

1. The vapor pressure exemption has been reduced in the SOCMI HON 

as compared to NSPS Kb, and the HON is attempting to regulate new 

tanks in the 10,000-20,000 gallon range. 

Vapor Pressure Exemptions 

NSPS Subpart Kb 

Volume > 40,000 gal 

exempt if 

Pv < 0.5 psia 

20,000 < Volume < 40,000 gal 

exempt if 

Pv < 2.2 psia 

SOCMI HON 

Volume > 40,000 gal 

exempt if 

Pv < 0.1 psia 

10,000 < Volume < 40,000 gal 

exempt if 

Pv < 1.9 psia 

What is EPA's basis for lowering these two key parameters? 
2. On page 404, it is stated that "periods of routine maintenance 

[for a closed vent system and control device] shall not exceed 72 

hours per year." This is very restrictive. In the event that 

routine maintenance were required, it is hard to imagine that it 

could be completed in this short time frame. This restriction 

could provide a disincentive to do routine maintenance. We believe 

the restriction that the liquid level in the storage vessel may not 

be raised during periods of routine maintenance is sufficient. 

D. Genera ] gffnnni«nfc« 

In the emissions estimating section of the HON (pp. 587) "P" is 

defined as the "true vapor pressure of the HAP" when it should be 

the true vapor pressure of the product. This is of concern only 

when the tank contains something other than a pure HAP. 
P.29 

Attachment 6 

ATTACHMENT V 

TRANSFER OPERATIONS 

A. EPA Should Establish a DeMinimus Cutoff for Transfer Operations. 

Loading terminals which load more than 170,000 gallons per year of HAPs with a 

vapor pressure of 1.5 psia and greater are covered by the HON. However, 

chemicals with impurities are exempt, although the impurity level is not defined. 

We recommend that EPA adopt a definition which is consistent with the equipment 

leak regulation, where a stream with less than 5% VHAP is exempted. 

Also, the proposed exemption level for the annual loading volume is significantly 

lower than the Benzene Transfer NESHAP. We recommend that EPA adopt the 

340,000 gallon per year throughout exemption for the HON to be consistent with 

Benzene Transfer NESHAP. 

B. EPA Should Consider an Emission Rate Standard Instead of a Percent Efficiency 

Standard. 

Over the last 20 years the control standard for gasoline marketing has shifted from a 

percentage basis to an emission rate basis (e.g., 35mg/l NSPS for Bulk Terminals) 

because its's easier for performance testing. For this reason and consistency with 

existing loading regulations, we recommend that EPA delete the 95%/98% standard 

and instead set a mass HAP rate per liter loaded. The emission rate standard could 

take toxicity of the HAPs into account, using the "toxicity bins" in the Early 

Reduction Credit rule. 

C. Responsibility for Tank Truck/Rail Car Vapor Tightness Should Rest on Tank 

Truck/Rail Car Operator. 

Owners and operators of SOCMI facilities rely heavily on third party operators of 

tank trucks and rail cars to handle transportation of chemical products. We 

therefore believe the responsibility for ensuring the vapor tightness should rest on 

the owner/operator of the tank truck or rail car. This could be accomplished by 

requiring the tank truck or rail car operator to provide documentation to the SOCMI 

plant operator certifying that all trucks or rail cars being loaded are vapor-tight. 

D. Estimated Cost Effectiveness Appears Unrealistically Low. 

We were unable to evaluate the EPA's estimated cost effectiveness of.$10,000 per 

ton for transfer operation emissions control. However, based on our experience 

with tank truck loading terminals for small transfer operations, we believe EPA's 

estimated cost effectiveness is too low. We urge EPA to review their estimate to 

ensure the estimated cost effectiveness is as realistic as possible. 

E. Scrubber Efficiency Requirement for Hydrogen Halides/Halogens Should be 

Lower. 

The HON specifies that a scrubber capable of a 99% reduction or greater be used to 

control hydrogen halide and halogen emissions which remain following use of a 

combustion device. We recommend that a scrubber efficiency of 98% be specified 

to provide consistency. 

V-l 
Attachment 7 

ATTACHMENT VII 

COMMENTS 

ON 

EMISSION AVERAGING 

In our general comments, we stressed the need for consistency across EPA's air programs to avoid 

confusion and to gain acceptance more readily. In the HON (page 176) EPA refers to its 1986 

Emissions Trading Policy Statement for criteria pollutants as justification for having a discount 

factor in the toxic program - to be consistent. We agree that a precedent has been set for discount 

factors. Consistency is important That is why we are very concerned to see in other parts of the 

HON averaging provision that EPA is departing drastically from its 1986 Trading Policy with very 

little explanation or evidence of the need for change. EPA appears to be deleting provisions that 

industry has found to be very useful. The 1986 Trading Policy evolved over 10 years of much 

"give and take" from all parties. EPA should not re-open "old battles" unless strong evidence 

indicates the need. Some of our recommendations below include references to principles in EPA's 

1986 Policy. 

A. HON Baseline Will Cause Reductions to be Postponed. 

The HON proposes not. to allow credit for reductions that occur before the promulgation date of the 

MACT rule. This creates a real disincentive for industry to voluntarily reduce emissions early. 

EPA tries to justify this HON position by saying such early reductions "would have occurred 

anyway" (pg 172). For EPA to lump all early reductions into this **would anyway" category is 

unfair and arbitrary. Many companies today are volunteering to reduce their emissions (e.g., the 

33/50 Program) to maintain good relations with the public. Those plans could quickly change if 

EPA now creates a situation whereby industries must keep their emissions up to permitted levels 

until the date of MACT promulgation in order to participate in the cost-effective MACT bubble 

provision. EPA should not force industry into such game playing. EPA should remove roadblocks 

to early reductions, not make them. 

The 1986 EPA Trading Policy includes banking provisions that allows industry to reduce criteria 

emissions when the opportunities arise and not be forced to "run dirty" until the time when the 

credit is needed. EPA should be consistent and allow some banking in the toxic program. (We 

would be willing to accept a 5-year life on credits.) 

The baseline date for banking credits could be the date of the company's credit application to the 

agency, but EPA's proposed MACT promulgation date is definitely unworkable. Another baseline 

option could be 1990 when the Clean Air Act was enacted. 

B. Environment Benefits if Averaging Is Allowed Across Source Categories. 

With EPA's proposed discount factor, the averaging approach will create more emission reductions 

than straight MACT. Therefore, EPA should encourage more "bubbling" by allowing facilities to 

reduce emissions across source categories as long as the emission points are within the facility's 

fenceline. The HON proposes to limit the pool of reduction candidates to only those emission 

points covered by this MACT's source category (i.e., tanks, wastewater, vents & loading). There 

are other emission points in most chemical plants, but industry is not allowed to reduce them and 
P.31 

get credit. This HON approach is arbitrary and in conflict with the criteria pollutant bubble policy 

which allows any emission point within the plant fenceline to be a reduction candidate. EPA should 

be consistent between toxics and criteria pollutants. In the HON, de minimis emission points that 

are are not required to be controlled by MACT but are the same source type (e.g., small tanks) may 

be used as reduction candidates. What is the difference in extending the bubble scope to other 

points not required to be controlled by MACT? (We suspect EPA's real reason is its reluctance to 

account for toxicity differences, but perhaps EPA should take that step to satisfy several states' 

concerns.) 

EPA states in the HON (pg 166) that the Clean Air Act's "floor requirement" for MACT prevents 

EPA from allowing averaging across source categories. Various industry attorneys have studied 

that same statutory language and have concluded that it does allow averaging across source 

categories within a facility's fenceline (eg; CMA's letter to M. S. Winer of EPA-OGC, 12/6/91). 

Has EPA's Office of General prepared a written position on this issue? 

We recommend that EPA allow toxic bubbling to include any emission point within the fenceline of 

a contiguous facility. This broad approach would be consistent with the 1986 Trading Policy and 

the Toxics Early Reduction Credit Program. This broad approach has the additional benefit of 

helping EPA identify additional emission points as yet unknown and unregulated. It will unleash 

the search capabilities of thousands of plant engineers and operators. 

C. Credit for Certain Shutdowns. 

The HON proposes to not allow credit for process unit shutdowns (pg 579). However, the criteria 

pollutant bubble policy allows credit for shutdowns that occur after August 7, 1977 (enactment 

date of previous Act amendments) if the area has an approved attainment plan. In areas without 

approved plans, companies can still get credit if they apply for credit prior to the shutdown or if 

the shutdown is being replaced. We believe toxic credit for certain shutdowns should be allowed, 

especially replacements. Shutdowns are such an important source of potential credit that we would 

probably be willing to accept a higher discount factor (eg; 50%) for this type of reduction. At a 

minimum, if EPA doesn't allow any shutdown credit in the HON, EPA should fully explain why it 

is being inconsistent between its two bubble policies. 

D. Mandated "Cook Book" vs. Case-bv-Case. 

It appears that EPA in the HON is striving to develop a simple, standardized way to administer 

toxic bubbles. Although a noble goal, EPA appears to be trying to nail down too many details that 

are better handled case-by-case in the facilities' bubble applications and permits. For example, 

EPA proposes to set control efficiencies for standard control technologies (e.g., 95%) and not 

allow companies extra credit for operating the devices at higher efficiencies (e.g., 98%)*. 

Although the rigid efficiencies allow for easier accounting, they remove any incentive for operators 

to develop finetuning improvements in design or operating practice. Also, the HON includes rigid 

equations for estimating emissions, but history has shown that estimating methods change 

frequently as more accurate methods are developed. The HON equations will probably be outdated 

the day the HON is promulgated. We suggest EPA shift from such a rigid, detailed "cookbook" 

approach, and instead focus on defining key principles such as "quantifiable" and "enforceable". 

•See page 168 in draft HON 

VTI-2 
DRAFT—For Discussion Purposes Only 

FIGURE 8 — HON WASTEWATER OPERATIONS 

REQUIREMENT 

Existing process units-Table 9 Group 1 WW stream 

- total VOHAP concentration greater than or 

equal to 10,000 ppmw, or 

- total VOHAP concentration greater than or 

equal to 500 ppmw and flow rate greater than or 

equal to 1 Cpm, or 

- total VOHAP concentration greater than or 

equal to 10 ppmw (when streams generated within 

the same process unit are combined) 

- exemption: unless, source total VOHAP mass 

flow rate of all Group 1 wastewater streams is 

less than 1 Mg/yr 

24 DEC 91 DRAFT 

REGULATORY 

CITATION 

§63.132(d) (2) (i) 

§63.132(d)(2)(ii) 

§63.138(d)(2) 

§63.132(d)(4) 

PAGE 

NO. 

470 

470 

470 

471 
DRAFT—For Discussion Purposes Only 

FIGURE 8 — HON WASTEWATER OPERATIONS 

REQUIREMENT 

Existing treatment standards 

- treat residuals and control for air emissions 

- one or more Group 1 streams 

• recycle to process, or 

• treat with design stripper, or 

• reduce total VOHAP mass flow rate by 99%, or 

• reduce total VOHAP average concentration to 

50 ppmw, or 

• reduce total VOHAP mass flow rate for each 

group of HAP's in accordance with Table 9 

24 DEC 91 DRAFT 

REGULATORY 

CITATION 

§63.138(c) and 

§63.138(f). 

§63.138 (c) (1) (i) 

§63.138 (c) (1) (ii) (A) 

§63.138 (c) (1) (ii) (B) 

§63.138 (c) (1) (ii) (C) 

§63.138 (c) (1) (ii) (C) 

PAGE 

NO. 

487/ 

497 

487 

488 

488 

488 

488 
DRAFT—For Discussion Purposes Only 

FIGURE 8 — HON WASTEWATER OPERATIONS 

REQUIREMENT 

Existing treatment standards 

- treat residuals and control for air emissions 

- for combination of one. or more Group 1 and Group 2 

wastewater streams (includes wastewater streams 

generated within the same.process unit or wastewater 

streams combined from different process units) 

• recycle to process, or 

• treat with design steam stripper, or 

• reduce total VOHAP mass flow rate by 99%, or 

• reduce VOHAP mass flow rate for each qroup of 

HAP's in accordance with Table 9 efficiencies, 

or 

• achieve required mass removal of Group 1 

wastewater streams 

- for wastewater streams generated within the same 

process unit 

• recycle to process, or 

• reduce total VOHAP concentration to less than 

10 ppmw for each stream (before exposure to 

atmoshpere or wastewaters generated from 

different process unit) 

24 DEC 91 DRAFTREGULATORY 

CITATION 

§63.138(c) and 

§63.138(f) 

§63.138 (c) (1) (i) 

§63.138 (c) (1) (iii) (A) 

§63.138 (c) (1) (iii) (B) 

§63.138 (c) (1) (iii) (C) 

§63.138(c) (1) (iii) (C) 

and §63.145(h) 

§63.138(d)(2)(i)(A) 

§63.138(d)(2)(i)(B) 

' 

487/ 

497 

487 

488 

488 

488 

495/ 

550 

496 

496 
DRAFT—For Discussion Purposes Only 

FIGURE 8 HON WASTEWATER OPERATIONS 

REQUIREMENT 

New process units -- Table 8 Group 1 WW stream 

- flow rate qreater than or equal to 0.02 {pm, and 

- concentration of any Table 8 HAP greater than or 

equal to 10 ppmw 

New treatment standards 

- treat residuals and control for air emissions for 

all alternatives 

- one Group 1 wastewater stream 

• recycle to process, or 

• reduce each Table 8 HAP to less than lOppmw, 

or 

• treat with design steam stripper 

- combination of Group 1 and Group 2 ww streams 

• recycle to process, or 

• reduce combined mass flow rate of Table 8 

compounds by 99%, or 

• treat with design steam stripper, or 

• achieve required mass removal of total 

VOHAP's 

24 DEC 91 DRAFT 

REGULATORY 

CITATION 

§63.132(c) 

§63.138(c) and 

§63.138(f) 

§63.138(b) (1) (i) 

§63.138(b)(1)(ii)(A) 

§63.138(b)(1)(ii)(B) 

§63.138(b)(1)(i) 

§63.138(b)(1)(iii)(A) 

§63.138(b) (1) (iii) (B) 

§63.138(b) (1) (iii) (C) 

PAGE 

NO. 

467 

487/ 

497 

486 

486 

486 

486 

486 

486 

486 
DRAFT—For Discussion Purposes Only 

FIGURE 8 — HON WASTEWATER OPERATIONS 

REQUIREMENT 

SOCMI sourc e 

- produce s one o r more of a lis t of SOCMI chemicals, 

New process unit 

- constructe d o r modifie d afte r th e proposa l dat e 

24 DEC 91 DRAFT 

REGULATORY 

CITATION 

§63.100(b ) an d 

§63.10 5 

§63.100(f ) (1) 

PAGE 

NO. 

301 / 

315 

306 
Attachment 8 

ATTACHMENT VI 

Comments on subpart H 

(Equipment Leaks Regulation) 

A. The Published Regulation is the Same as What was Agreed to 

by the Negotiating Committee 

This regulation was developed and agreed to by a negotiated 

rulemaking process. Our review of these sections focused on 

confirming that the regulation agreed to by the committee is the 

same as the one currently proposed for publication. With the 

exception of some typographical errors (see attached table) , the 

regulation is the same as has been agreed to previously. 

B. Eguipment Leak Control is not a "Cost saving" 

On page 69 it is stated that "the annual costs of controlling 

emissions from equipment leaks reveal a cost savings." We 

believe this statement is not valid considering that the bulk of 

the cost for this regulation will be the additional annual cost 

required for Inspection and Maintenance programs. 

C. Emissions can be Calculated from Equipment Leaks 

The HON states that one of the reasons emissions averaging 

cannot be used for equipment leaks is that "no method currently 

exists for determining the magnitude of allowable emissions to 

assign leaks" (page 166). Yet on page 63, they have quantified 

the emissions reductions resulting from the HON. We believe 

methods are available for calculating emissions from equipment 

leaks. Our understanding is that the negotiating committee 

could not agree on the use of emissions averaging for equipment 

leaks. We suggest that it be stated in the HON that the reason 

emissions averaging cannot be used is that the committee was 

unable to reach agreement on this issue. 
ATTACHMENT VI (CONT.) 

TYPOGRAPHICAL ERRORS IN 

FUGITIVE EQUIPMENT REGULATION 

A. Section VIII. Rationale for Negotiated Rule for Eguipment 

Leaks 

1) . Page 197, The third sentence in the second paragraph should 

read. "This review showed that many plants had no valves or 

pumps exceeding 10.000 ppm and no plants had more than 1.5 

percent valves...." 

2 ). Page 207, The 4th sentence appears to be missing a word 

after the second appearance of "from". 

3 ). Page 208, The second sentence appears to be missing a word 

after the word "such". 

4) Page 214, In the second sentence there appears to be a phrase 

missing after the phrase "monthly monitoring". 

5) Page 220, In second sentence of the last paragraph, "movings" 

should read "moving parts". The same comment applies to the 

second sentence in the second paragraph on page 268. 

B. Subpart H - National Emission Standards for Organic Hazardous 

Air Pollutants from Synthetic Organic Chemical Manufacturing 

Eguipment Leaks. 

1) Page 5, last sentence, in the previous version of the 

regulation, "1,3-diisocobpayanate" was spelled "1,3 

diisocyanate". 

2) Page 15, in subpart (a), "63.175 and 63.176" should read 

"63.175 through 63.179". 

3) Page 35, in the first paragraph (subpart (2)), "63.163" 

should be "63.172". 

4) Page 43, in the first paragraph (subpart (2)), "254 cm" 

should be "5.08 cm". 

5) Page 76, Table 1, in the last line of the Table, "100/5" 

should be "100%". 
P.39 

DRAFT—For Discussion Purposes Only Attachment 9 

GUIDE TO HON WASTEWATER RULE 

1. Introduction to Guide. The EPA is developing a standard to 

limit emissions of hazardous air pollutants (HAP's) from SOCMI 

chemical manufacturing operations. This rule is called the 

hazardous organic NESHAP or HON. The HON will regulate air 

emissions of certain organic hazardous air pollutants from five 

SOCMI operations: process vents; wastewater collection and 

treatment operations; storage vessels; transfer operations; and, 

equipment leaks. 

This guide focuses on the proposed wastewater operations 

provisions and is intended to be used with the attached Figures 1 

through 8. Figure 1 maps the decision process for determining 

whether the HON is applicable to wastewater streams generated 

within a specific process unit. Figures 2 and 3 outline the 

decision process for determining whether wastewater streams are 

Group 1 or Group 2 wastewater streams. Figures 4 and 5 outline 

treatment provisions required for Group 1 wastewater streams. 

Figure 6 outlines alternate treatment provisions. Figure 7 

outlines treatment options for residuals from Group 1 wastewater 

streams. Figure 8 provides a summary of HON wastewater 

requirements and provides references from the 24 Dec 91 draft 

regulation. Please note that Figures 1 and 2 were combined in 

previously distributed drafts of the figures. 

Table 8, Organic HAP Compounds Subject to New Process Unit 

Requirements, and Table 9, Organic HAP Strippability Groups and 

Target Removal Efficiencies are available in the draft 

regulation. 

2. Overview. The goal of the HON is to limit organic HAP 

emissions in accordance with the Clean Air Act Amendments of 

1990. While the magnitude of emissions from wastewater depends 

on a number of stream and facility specific factors, the most 

significant factors are wastewater flow rate and organic HAP 

concentration. 

There are two potential strategies for control of HAP emissions 

from the collection and treatment of contaminated wastewater. 

The first control strategy is waste minimization through process 

modifications, modification of operating practices, preventative 

maintenance, recycling, or segregation of waste streams. The EPA 

recognizes that many sources may be able to achieve significant 

reductions in HAP emissions through the implementation of waste 

minimization/recycling. Therefore, recycling a wastewater stream 

is an option for complying with the treatment provisions for any 

stream. 
PAO 

DRAFT—For Discussion Purposes Only 

The second control strategy is to reduce the HAP content of the 

wastewater through treatment before the wastewater stream 

contacts atmosphere. This is accomplished by controlling 

emissions from collection and treatment system components and 

treating the wastewater stream to specified levels before 

discharge. 

A complete strategy for reducing the HAP content of wastewater 

includes: (l) emissions suppression from transport, handling, 

and treatment, (2) reduction of HAP content, and (3) treatment of 

residuals. Each of these steps is essential to the effective 

reduction of organic HAP emissions. 

3. Definitions. General definitions and descriptions are 

outlined in this paragraph. 

a. New means that construction or reconstruction 

(per §112(g) of the CAAA) began after the HON proposal 

date. 

b. The point of generation means the location where a 

wastewater stream exits a process unit component, or 

product or feed storage tank, prior to handling or 

treatment in a piece of equipment which is not an 

integral part of the production process. A piece of 

equipment is considered an integral part of the process 

unit if its removal would result in a process unit 

production shutdown. The point of generation for 

landfill leachate is at the pump well from which the 

leachate is pumped out at the landfill. 

The point of generation was selected as the point at 

-which applicability is determined and regulation 

begins. This point was selected because: (1) at this 

point the production process ends and the wastewater 

system begins; (2) this is the point where the organic 

concentration is highest; and, (3) after this point the 

potential for emissions from wastewater occurs. 

c. Residual means any material containing VOHAP that is 

removed from a wastewater stream by a waste management 

unit that does not destroy organics. Examples of 

residuals include the organic layer and bottom residue 

removed by a decanter or organic-water separator, and 

the overhead condensate stream from a steam or air 

stripper. 

d. A SOCMI process unit is defined as a unit producing one 

or more of a list of SOCMI chemicals that is a HAP or 

uses a HAP as a reactant. Process units include all 
P41 

DRAFT—For Discussion Purposes Only 

equipment associated with unit operations, storage and 

transport of feed material to the unit operations and 

storage and transfer of products from unit operations. 

Equipment associated with waste management and waste 

treatment is not part of the process unit. 

e. A source is considered to be all SOCMI operations 

subject to the HON within a contiguous area and under 

common control. 

f. VOHAP means the volatile portion of an individuallyspeciated organic HAP in a wastewater stream or 

residual that is measured by a combination of Method 

25D and Method 18. Total VOHAP means the sum of the 

individually-speciated organic HAP's as measured by the 

combination of Methods 25D and 18. 

Determination of total VOHAP average concentration is 

specified in §63.144. 

g. Wastewater is any organic HAP-containing liquid or 

material separated from the liquid resulting from 

indirect or direct contact of water with organic HAP's 

which are subsequently discarded, stored, or treated 

prior to being discharged, discarded, or recycled. 

Examples of wastewater streams include process 

wastewater, production feed tank drawdown, landfill 

leachate, cooling tower blowdown, and steam trap 

condensate. 

Wastewater generation can be continuous or intermittent 

in nature. 

Wastewater streams are classified as Group 1 or Group 2 

wastewater streams. Group 1 wastewater streams require 

emissions control and monitoring. Group 2 wastewater 

streams may be subject to monitoring. Owners and 

operators of both groups are subject to certain 

reporting requirements. 

Group 1 wastewater stream determinations depend upon 

whether the stream is generated within a new or 

existing process unit. 

A wastewater stream from an new or existing process 

unit is a Group 1 wastewater stream requiring control 

for Table 9 HAP's if: 

- total VOHAP average concentration is greater 

than or equal to 10,000 parts per million by 

weight; or 
P.42 

DRAFT—For Discussion Purposes Onlv 

- total VOHAP average concentration is greater 

than or equal to 500 parts per million by weight 

and flow rate is greater than or 

equal to 1 liter per minute. 

An exemption for wastewater streams generated within 

existing units is provided. Wastewater streams from an 

existing process units are not Group 1 wastewater 

streams requiring control for Table 9 HAP's if the 

total VOHAP mass flow rate for the source is less than 

1 megagram per year. 

A wastewater stream from a new process unit is a 

Group 1 wastewater stream requiring control for Table 8 

HAP's if: 

- the annual average flow rate is 0.02 liter per 

minute or greater; and. 

- the average concentration of any one of the 

Table 8 compounds is 10 parts per million by 

weight or greater. 

4. HON Wastewater Operations Applicability (Figure 1) . Figure 1 

is used to determine whether wastewater streams generated in an 

individual process unit are: subject to the HON regulation 

(i.e., the process unit is a SOCMI process unit); and, generated 

within new or existing units. 

5. New Process Unit — Determination of Group 1 Wastewater 

Streams for Table 8 HAP's (Figure 2). 

Existing and New Process Units — Determination of Group 1 

Wastewater Streams for Table 9 HAP's (Figure 3). 

The decision schemes presented in Figures 2 and 3 help to 

determine whether the streams will be Group 1 wastewater streams. 

Total VOHAP average concentration and average flow rate for each 

wastewater stream must be calculated based on measurements taken 

at the point of generation. 

a. A distinction is made between new and existing process 

units. New units are required to achieve a more stringent 

level of emissions control than existing units for Table 8 

HAP's. Because of this distinction, two sets of criteria 

are used to determine whether a stream is a Group 1 

wastewater stream; one for new units and one for existing 

units. 
P.43_ 

DRAFT—For Discussion Purposes Only 

b. Figure 2. For each individual stream generated within a 

new process unit, the concentration of compounds in Table 8 

and the flow rate for each stream at the point of generation 

must be determined. The Table 8 compounds are those with 

volatilities equal to or greater than benzene. If the flow 

rate for an individual stream is greater than or equal to 

0.02 liter per minute (£pm), and the concentration of any 

individual Table 8 HAP is greater than or equal to 10 part 

per million by weight (ppmw), the wastewater stream must 

meet the treatment provisions for new units. The 10 ppmw 

concentration is the same concentration as in the NESHAP for 

Benzene Waste Operations and Vinyl Chloride. These rules 

were used in the determination of the control level for new 

units. The flow rate is the same as that for the Benzene 

Waste Operations NESHAP. 

A Group 1 or Group 2 wastewater stream for Table 8 HAP's 

must also be evaluated as a potential Group 1 wastewater 

stream for Table 9 HAP's. 

c. Figure 3. The first decision diamond in this figure 

asks two questions. The first question is whether the 

wastewater stream is generated within an existing unit or is 

generated from within a new unit not subject to Table 8 HAP 

control requirements. The second question in the diamond 

asks whether the stream is segregated from other wastewater 

streams or mixed only with wastewater streams generated 

within the same process unit before exposure to the 

atmosphere. When the answer to both questions is yes, the 

stream may be controlled according to the treatment 

provisions outlined in Figure 5 or Figure 6. If the answer 

to either of the questions is no, the wastewater stream must 

be controlled in accordance with the treatment provisions 

outlined in Figure 5. 

When the treatment provisions outlined in Figure 6 are used 

to achieve compliance, no Group 1/ Group 2 determination is 

made — all the wastewater streams must be evaluated for 

treatment or recycling. When Figure 5 treatment provisions 

are used to achieve compliance, Figure 3 is used to 

ascertain which streams require control, i.e, which streams 

are Group 1 wastewater streams for Table 9 HAP's. 

For each wastewater stream using Figure 3 to make a 

Group 1 determination, total VOHAP average concentration and 

average flow rate must be determined at the point of 

generation. The wastewater stream is Group 1 wastewater 

stream if: 

(1) the total VOHAP average concentration of the 

wastewater stream is greater than or equal to 10,000 

parts per million by weight (ppmw); or, 
P.44 

DRAFT—For Discussion Purposes Only 

(2) the total VOHAP average concentration is greater 

than or equal to 5'00 parts per million by weight and 

the average flow rate is equal to or greater than 1 

liter per minute. 

An exemption to the Group 1 determination for existing 

process units is provided. Mass flow rates for all 

individual wastewater streams determined to be uncontrolled 

Group 1 wastewater streams by the criteria above are 

calculated and summed. This summation is the total source 

VOHAP mass flow rate. If the total source VOHAP mass flow 

rate is less than 1 megagram per year, treatment is not 

required for those streams. 

6. New Process Units — Treatment Provisions (Figure 4). 

Wastewater management units handling Group 1 wastewater streams 

must control for air emissions using appropriate control 

techniques. The control techniques must be employed both before 

and during treatment and/or recycling of the wastewater stream. 

Wastewater streams that are recycled to a process unit require no 

further treatment. Because the most effective and least costly 

control technique will vary on a site specific basis, the 

standards are structured to allow several alternatives for 

achieving the required emission reductions. 

For wastewater streams composed of one Group 1 wastewater stream, 

one of the following treatment alternatives is required: 

(1) recycle to a process, or 

(2) reduce each Table 8 HAP to 10 ppmw or less, or 

(3) install and operate a steam stripper meeting the 

design and operation specifications required by the 

regulation. 

For wastewater streams composed of one or more Group 1 and/or 

Group 2 wastewater streams, treatment options are structured to 

prevent dilution as a means of achieving compliance. There are 

four treatment alternatives for these combined Group 1/Group 2 

wastewater streams: 

(1) recycle to a process, or 

(2) reduce by 99 percent or more the combined mass 

flow rate of the Table 8 HAP's, or 

(3) install and operate a steam stripper meeting the 

design and operation specifications required by the 

regulation, or 

(4) . achieve the required mass removal of VOHAP from 

Table 8 compounds contributed by Group 1 wastewater 

streams (as determined by the procedure in §63.145(g)). 
P.45 

DRAFT—For Discussion Purposes Only 

The last alternative, required mass removal, is designed to 

require 99 percent reduction of only those Table 8 HAP's 

contributed by the Group l wastewater streams. Choosing to 

comply with the required mass removal standard would not penalize 

a source for combining Group 1 and Group 2 wastewater streams for 

treatment. Alternatively, the overall 99 percent reduction 

standard could potentially be a more stringent option for mixed 

streams, but would be less complex in terms of demonstrating 

compliance. 

7. Existing and New Process Units — Treatment Provisions 

(Figure 5). Waste treatment units handling Group 1 wastewater 

streams must control for air emissions using appropriate control 

techniques. The control techniques must be employed both before 

and during treatment and/or recycling of the waste stream. 

Streams that are recycled to the process unit will require no 

further treatment. 

The first decision diamond in this figure asks two questions. 

The first question is whether the wastewater stream is generated 

within an existing unit or is generated from within a new unit 

not subject to Table 8 HAP control requirements. The second 

question in the diamond asks whether the stream is segregated 

from other wastewater streams or mixed only with wastewater 

streams generated within the same process unit before exposure to 

the atmosphere. When the answer to both questions is yes, the 

stream may be controlled according to the treatment provisions 

outlined in Figure 5 or Figure 6. If the answer to either of the 

questions is no, the wastewater stream must be controlled in 

accordance with the treatment provisions outlined in Figure 5. 

There are several treatment alternatives outlined in Figure 5. 

These are discussed in the paragraphs below. 

For wastewater streams composed of one or more Group 1 wastewater 

streams, compliance with one of the following five treatment 

alternatives is required: 

(1) recycle to a process, or 

(2) install and operate a steam stripper meeting the 

design and operation specifications required by the 

regulation, or 

(3) reduce total VOHAP mass flow rate by 99% or more, 

or 

(4) reduce total VOHAP average concentration to less 

than 50 parts per million by weight, or 

(5) reduce total VOHAP mass flow rate of each group of 

organic HAP's by the reduction efficiency percentages 

specified in Table 9. 
— — — — P.46 

DRAFT—For Discussion Purposes Only 

As with wastewater generated within new process units, wastewater 

streams generated from existing units and composed of one or more 

Group 1 and/or Group 2 wastewater streams are not allowed to use 

dilution as a means to achieving compliance. There are five 

treatment alternatives for these combined Group 1/Group 2 

wastewater streams: 

(1) recycle to a process, or 

(2) install and operate a steam stripper meeting the 

design and operation specifications required by the 

regulation, or 

(3) reduce total VOHAP mass flow rate by 99% or more, 

or 

(4) reduce VOHAP mass flow rate of each group of 

organic HAP's by the reduction percentages given in 

Table 9, or 

(5) achieve the required mass removal of total VOHAP 

contributed by Group 1 wastewater streams (as 

determined by the procedures in §63.145(h)). 

The procedure in §63.145 for computing mass removal is based on 

the percentage removal that can be achieved for- each of the Table 

9 groups, and is designed to require removal of only the VOHAP 

contributed by the Group 1 wastewater streams. 

Following wastewater treatment, all residuals removed from the 

process must also be treated properly. 

8. Alternative Treatment Provisions (Figure 61. Wastewater 

streams generated within new units cannot choose the treatment 

alternatives in Figure 6 to achieve compliance for Table 8 HAP's. 

All other wastewater streams may chose the Figure 6 treatment 

alternatives, provided the wastewater streams are not mixed with 

wastewater streams from other units. 

The treatment standards illustrated in Figure 6 are applicable 

only if all wastewater streams generated within the same process 

unit are considered together. This does not mean that all 

wastewater streams will require treatment. The decision whether 

a wastewater stream requires treatment is based on total VOHAP 

average concentration at the point where the wastewater stream is 

first exposed to the atmosphere or combined with wastewaters from 

other process units. 

All wastewater streams generated within the unit and having 

concentrations greater than or equal to 10 parts per million by 

weight before exposure to the atmosphere or wastewaters from 

other process units must: 

- recycle to a process, or 
P.47 

DRAFT—For Discussion Purposes Only 

- reduce total VOHAP concentration for each wastewater 

stream to less than 10 parts per million by weight. 

Using this alternative, all streams generated within the unit 

must comply with the 10 ppmw concentration standard or be 

recycled to a process unit before contact with the atmosphere or 

wastewaters from other units. 

For the treatment alternatives presented in Figures 4 and 5, HAP 

concentration measurement, and therefore Group 1 wastewater 

stream determination, is made before the wastewater stream enters 

a waste management unit. The Figure 6 alternative allows the 10 

ppmw concentration standard to be applied after the stream has 

been treated in a waste management unit located in the same 

process unit area. It is important to note that the 10 ppmw 

concentration determination is made before exposure to the 

atmosphere or wastewaters generated within other process units. 

Not all wastewater streams are required to pass through the waste 

management unit; however, all wastewater streams generated within 

the process unit must be measured against the 10 ppmw standard. 

Residuals produced by the treatment process must also be treated 

properly. 

9. Treatment of Residuals (Figure 71. Residuals produced in the 

wastewater treatment process must be controlled for emissions. 

Residuals include oil phases, condensates, vapor streams, and 

some sludges which are removed from wastewater streams. Each 

waste management unit that handles residuals before and during 

treatment must be controlled for emissions using the control 

techniques specified by the proposed standard. 

Three alternatives are available for treating residuals. These 

are: 

(1) return the residual to the process, or 

(2) return the residual to a treatment device, or 

(3) destroy the total VOHAP mass flow rate of the 

residual by at least 99 percent. 

10. Emissions Averaging. This guide does not explore emissions 

averaging. Emissions averaging is a regulatory option that 

reduce emissions facility-wide. Emissions averaging may 

encompass wastewater streams. 

11. Summary. All of the regulatory options used to evaluate 

potential controls for these sources are based on comprehensive 
DRAFT—For Discussion Purposes Uniy ' ^ ^

 P4 8 

control of wastewater streams from the points of generation 

through transport, handling, and final treatment. The wastewater 

streams must be treated to remove or destroy organic HAP's that 

would otherwise be emitted during wastewater collection and 

treatment. 

Figure 8. is provided as an summary of the HON wastewater 

operations decision-making process. 

The proposed control provisions provide many alternative 

requirements in order to allow facilities a high degree of 

flexibility in complying with the standard. Because of the 

flexibility provided, the proposed standard is complex in terms 

of determining which wastewater streams must be controlled and 

the level of control required for wastewater streams generated by 

new and existing SOCMI process units. 

This guide has been written as an aid in introducing the HON 

wastewater regulation. More information will be available in the 

preamble, background information documents, and the draft 

regulation. 

The information in this guide is based on the draft regulation 

and will change as the regulation continues to develop and 

undergo internal reviews. This means some of the guide 

information is subject to reconsideration as the draft regulation 

evolves into the proposed and final regulation. 

Update: FEB 1992 

10 
Do For Each Process Unit 

Out 

No 

Yes 

Yes 

Figure 1. HON Wastewater Operations Applicability 
Determine Concentration (Cone.) 

of Table 8 Compounds and Flow 

Rate for Each Stream at 

Point of Generation 

Do For Each Wastewater Stream 

Figrue 2. New Process Units - Determination of Group 1 Wastewater 

for Table 8 HAP's 
Yes 

From 

existing unit or 

new unit not subject to 

Table 8 HAP control requirements? 

and not mixed with WW 

streams from other 

units? 

Do For Each Wastewater Stream 

Determine Total VOHAP 

Cone, and Flow Rate for Each 

Stream at Point of Generation 

Yes 

Determine Source Total VOHAP 

Mass Flow Rate (can be done after 

controlled treatment) from All 

Streams Which Are Above Flow and 

Cone, at Point of Generation 

Figure 3. Existing and New Process Units - Determination of Group 1 WW Streams 

for Table 9 HAP's 
Control for Air Emissions from 

Each Waste Management 

Unit that Handles Stream 

Before and During Treatment/Recycle 

No - One Group 1 Stream 

1. Recycle to process 

or 

2. Treat each Table 8 

HAPto<10ppm 

or 

3. Install and Treat 

Stream with Design 

Steam Stripper 

1. Reduce to process 

or 

2. Reduce Table 8 HAP's 

(which are a 10 ppmw before combination) 

in combined stream by 99% 

or 

3. Install and Treat Combined Stream 

with Design Steam Stripper 

or 

4. Treat Combined Stream to Achieve 

Required Mass Removal 

8 

Figure 4. New Process Units - Treatment Requirements 
From 

existing unit or 

new unit not subject 

to Table 8 HAP control requirements? 

and 

Not mixed with ww streams 

from other units? 

Yes 

Properly Control Air Emissions from Each 

Waste Management Unit that Handles Stream 

Before and During Treatment/Recycle 

No-one or more 

Group 1 streams 

Control Options: 

1. Recycle to process 

or 

2. Treat wit design steam stripper 

or 

3. Treat to achieve 99% reduction 

in total VOHAP Mass Flow Rates 

or 

4. Treat to achieve total VOHAP 

concentration < 50 ppmw 

or 

5. Treat to achieve % reductions in Mass Flow 

Rate for each Group of HAP's in Table 9 

Yes-one or more 

Group 1/Group 2 streams 

Control Options for Combined Stream: 

1. Recycle to process 

or 

2. Treat with design steam stripper 

or 

3. Treat to achieve 99% reduction in 

total VOHAP Mass Flow Rate 

or 

4. Treat to achieve % reductions Mass Flow 

Rates for each Group of HAP's in Table 9 

or 

5. Treat to achieve required total VOHAP 

mass removal 

Treat 

Residuals Removed from 

Wastewater Stream 

Go to Figure 7 

Figure 5. Existing and New Process Units - Treatment Provisions 
Control for Air 

Emissions Each Waste 

Management Unit 

Handling or Treating 

Wastewater Streams 

Generated Within 

Process Unit 

(all streams in a unit 

must be treated by 

these provisions if this 

option is selected.) 

Each stream generated within 

process unit may be handled 

individually, or may be combined 

with other streams from same 

process unit. 

Determine Total VOHAP cone. 

for individual streams at point of 

generation, for combined streams 

at point following combination and 

before exposure to atmosphere 

Yes 

1. Recycle to Process 

or 

2. Treat Stream to Achieve a Total 

VOHAP Cone. <10 ppmw 

Figure 6. Process Unit Alternative Treatment Provisions 
Control for 

Air Emissions Each 

Waste Management 

Unit that Handles 

Residual Before and 

During Treatment/Recycle 

For All Residuals: 

1. Recycle to Process 

or 

2. Return to Treatment Process 

or 

3. Destroy Total VOHAP 

Mass Flow Rate 99% 

Figure 7. Treatment of Residuals 
Treatment and Controls 

to Meet New and Existing 

Treatment Standards 

Treatment and Controls 

to Meet Existing 

Treatment Standards 

No Group 2 

WW Stream 

Figure 8. HON Wastewater Operations 

TJ