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OAR Box 1669 

Prepped by Charmelie Mathews 

Document Number: 

1.II-E-1 3 

Docket Number: 

A-98-13 

Printed 9/23/2008 9:36:49 AM Sheet 81 of 110 
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U-B-13 

MEMORANDUM 

TO: Steve Shedd 

U.S. Environmental Protection Agency, ESD/WCPG 

FROM: Greg LaFlam and Jay Helms 

Pacific Environmental Services, Inc. (PES) 

DATE: October 27, 1997 

P:\N812 

SUBJECT: Organic Liquids Distribution NESHAP: Summary of Initial Meeting between 

U.S. EPA and API 

I. Purpose 

The main purpose of this meeting was to introduce the Organic Liquids Distribution 

NESHAP project to the American Petroleum Institute (API) and begin to define the scope of 

this source category. The meeting was also intended to identify stakeholders and obtain 

information about available data needed to categorize this industry. 

II. Location of Meeting and Participants 

Pfcce: NC Mutual Life Building, 10th Floor Conference Room, 

U.S. EPA, Durham, North Carolina 

Date: September 24, 1997, 2:20 p.m. - 3:45 p.m. 

Participants: See List of Attendees (Attachment 1) 

III. Discussion 

Attachment 2 contains a copy of the materials distributed at the meeting. The meeting 

followed the agenda for the most part, beginning with introductions, which was followed by a 

discussion of the scope of the Organic Liquids Distribution source category. 

The EPA stated that the scope of the Organic Liquids NESHAP currently includes 

"stand alone" distribution facilities and their loading and storage equipment. The rule will 

cover distribution by pipeline, truck, rail, barge, and tanker ship for all organic liquids with 

HAP emission potential, excluding gasoline. Those present representing industry stated that 

most chemicals are transported by rail, truck or marine vessel. Barges and coastal tankers are 

used for transporting long distances, while trucks are used to transport shorter distances. 
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Memo to Steve Shedd 

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Foreign crude oil is transported by pipeline from Canada and Mexico, and by marine vessel 

from Saudi Arabia. Jack McClure of Shell said that jet fuel is shipped to their customers by 

pipeline because it is shipped in large quantities. 

The EPA opened a discussion about independent liquid terminals. Industry (production 

interests) stated that they maintain custody of their liquids while they are held in independent 

terminals, and until they are received by the customer. The independent liquid terminals 

handle both petroleum and chemical products. 

The EPA stated that defining the scope of this NESHAP would require a thorough 

review of proposed and promulgated maximum achievable control technology (MACT) 

standards along with various State and local rules possibly related to this category, in order to 

determine what parts of the industry have already been regulated. 

The EPA asked if there were any suggestions as to which MACT rules currently 

regulate portions of this industry. Jack McClure stated that intermediate storage facilities that 

take crude oil off of ships or barges may be regulated by the PRPU. Miriam Lev-On of 

ARCO stated that to her knowledge, the transmission of crude oil from the field to refineries 

was left out of the Exploration and Production MACT rule, with the intent of having this 

source be regulated by the Organic Liquids NESHAP. She also stated that interstate and 

intrastate pipelines are currently regulated by the Department of Transportation (DOT) and 

State regulations, respectively. Some of the combustion devices at pipeline breakout stations 

are regulated by the ICCR. The industry representatives said that they ship products to other 

chemicals users, labs, manufacturers, wholesalers, and warehouses which may be regulated by 

the solvent cleaning, aerospace, or printing MACT rules. 

Bill Beck of Mobil stated that, most likely, only a few of the facilities the EPA will be 

looking at in the petroleum industry are major sources. He also requested that the EPA take a 

look at the State regulations which usually regulate VOC emissions. He stated that many of 

the facilities of concern are not currently regulated because they have low VOC emissions and, 

thus, low HAP emissions. 

The EPA asked industry representatives if they are aware of the distribution of 

"petrochemicals." Jack McClure said that there are "compounding" facilities that use 

petrochemicals, which may have toluene and xylene emissions. Mr. McClure suggested that 

the EPA take a look at setting vapor pressure cutoffs for the chemicals to be regulated. They 

ship several chemicals, such as ethylene glycol (by barge), which have such low vapor 

pressures that they are extremely low VOC emitters. 

Next, the EPA described the schedule for the presumptive MACT (P-MACT) process, 

which is a 6-month process. A full roundtable meeting of interested stakeholders will take 

A 
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Memo to Steve Shedd 

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place during this P-MACT process, most likely sometime in December or January. Proposal 

of the regulation is expected to be near the end of 1999, and promulgation is scheduled for 

November of 2000. 

The EPA asked API for their help in the identification of those who would have 

interest in this NESHAP. The API replied that States likely to have an interest in this 

NESHAP are Texas, California, Louisiana, and New Jersey. Industry groups likely to have 

interest include the API, the Chemical Manufacturer's Association (CMA), the Independent 

Liquid Terminals Association (ILTA), the Petroleum Marketers' Association (PMA), National 

Tank Truck Carriers (NTTC), the Petroleum Pipeline Association (PPA), the DOT, and 

SOCM A. The API said that they will form a committee to participate in this rule 

development. 

The EPA expressed the need for help in securing data about the practices of the 

industry, such as the HAP content of petroleum products, distribution information, and control 

technologies information. Miriam Lev-On stated that Dave Markwordt of EPA/ESD could be 

contacted for infonnation on pipeline emission factors. Karin Ritter of API said the API 

library can do a sophisticated search for the location of distribution facilities of interest. 

Emission factors for flashing losses from crude oil may be obtained from Paul Martino of API. 

Turnaround losses information can be obtained from Jason Becstrum. 

The Oil & Gas Journal is a good data source and should have annual rates; DOT 

should have information on pipeline, rail, and truck transfers. The Department of Energy 

(DOE) has both information about production of petroleum products and a book of facts. 

Miriam Lev-On stated that subcategorization of the industry may be needed, because 

the EPA may not be able to design one Information Collection Request (ICR) that will be 

applicable for this whole source category. The EPA stated that they are currently looking at 

the Vegetable Oil MACT, Refinery MACT, and OMB approved generic ICR as possibilities. 

The API agreed to review any ICR for this project to ensure it is understandable and 

technically appropriate. 

The EPA asked for site visit suggestions. Mr. McClure responded that a visit to a 

chemical compounding facility would be a good idea. 

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Memo to Steve Shedd 

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Attachment 1 

List of Attendees 

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Memo to Steve Shedd 

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List of Attendees 

Organic Liquids Distribution MACT 

EPA/API Meeting 

September 24, 1997 

Name 

Greg LaFlam 

Jay Helms 

Steve Shedd 

Miriam Lev-On 

Ed Williams 

Jack McClure 

Bill Beck 

Karen Ritter 

Nancy Kralik 

Affiliation 

Pacific Environmental Services, 

Pacific Environmental Services, 

EPA 

ARCO 

Marathon Oil 

Shell 

Mobil 

API 

Marathon Oil 

Inc. 

Inc. 

Phone Number/FAX 

(919) 941-0333/0234 

(919) 941-0333/0234 

(919) 541-5397 

(213) 486-2610/2021 

(618) 544-2121 

(713) 241-3999/2494 

(703) 849-6245 

(202) 682-8472 

(419) 421-3295 

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Memo to Steve Shedd 

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Attachment 2 

Handouts 

to 
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ORGANIC LIQUIDS DISTRIBUTION NESHAP 

U.S. Environmental Protection Agency 

Initial Meeting with the American Petroleum Institute 

September 24,1997,2:30 pm 

EPA Mutual Bldg., Durham, NC, 10th Fir. Conf. Room 

-^AGENDA* 

1. Welcome/Introductions 

2. Description of Source Category 

3. Presumptive MACT (P-MACT) Approach 

4. Project Schedule 

5. Identification of Stakeholders 

6. Data Needs 

7. General Discussion/Next Steps 

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INDUSTRY GROUP - LIQUIDS DISTRIBUTION 

Source Category': Gasoline Distribution (Stage 1) 

The Gasoline Distribution (Stage 1) source category includes 

the storage and transfer facilities associated with the movement 

of gasoline. This category includes, but is not limited to, the 

gasoline vapor emissions associated with the loading of transport 

trucks or rail cars, storage tank emissions, and equipment leaks 

from leaking pumps, valves, and connections at bulk terminals, 

bulk plants, and pipeline facilities. Also included in this 

category are the storage tank filling operations that occur at 

public and private gasoline dispensing facilities (e.g., service 

stations, convenience stores, etc.). 

•"TOT Source Category: Organic Liquids Distribution (Non-Gasoline) 

The Organic Liquids Distribution (Non-Gasoline) source 

category includes, but is not limited to, those activities 

associated with the storage and distribution of organic liquids 

other than gasoline, at sites which serve as distribution points 

from which organic liquids may be obtained for further use and 

processing. 

& 
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Organic Liquids Distribution 

Facilities Industry 

o 

i 

Consumer 

(Retail) 

CHEMICALS 

Chemical 

Manufacturing 

(SOCMI) 

Packaging/Distribution 

Facility 

Facilities using 

chemicals as 

feedstocks 

Consumer 

(Retail) 

Packaging/ 

Distribution 

Facility 

PETROLEUM 

Domestic 

Oil/Gas 

Production 

Foreign 

Crude Oil 

Petrochemical 

Manufacturing 

J

1 Petroleum 

Refining 

Consume

u 

r 

(Retail) 

Packaging/ 

Distribution 

Facility 

- Intermediate Storage Facility 

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