P.1 

OAR Box 1878 

Prepped by Charmelle Mathews 

Document Number: 

129) ll-E-13 

Docket Number: 

A-90-19 

Printed 11/28/2008 1:21:26 PM Sheet 129 of 145 
P.2 

A-90-19 

ll-E-13 

*1 =00' l* 

UNITED STATES ENVIRONMENTAL PROTECTIO 

Office of Air Quality Planning and Standards 

Research Triangle Park, North Carolina 27711 

0 1 MAR 1990 

J E 0 W E 

DEC I 8 1992 

EPAAIRDOCKE1 

MEMORANDUM 

SUBJECT 

FROM: 

TO; 

Meeting with Chemical Manufacturers Association (CMA) to 

Discuss Hazardous Organic NESHAP 

Robert E. Rosensteel, Chief 

Chemical Manufacturing Section (MD-13) 

Susan R. Wyatt, Chief 

Chemicals and Petroleum Branch (MD-13) 

1. A meeting was conducted on January 30, 1990, in the tenth floor conference 

room between representatives of CMA and EPA to discuss various air toxics 

activities. Attendees at the meeting were: 

Oft 

David Gustafson - DOW 

Roger Mai one - Union Carbide 

Bob Trautner - Shell 

Brian Taranto - Exxon 

Dorothy Bowers - Merck 

Ernie Rosenberg - Occidental 

Karen Fidler - CMA 

Richard Sigman r CMA 

RADIAN CORP 

Reese Howie 

Sheryl Hatklns 

2. Topics Discussed in Meeting: 

David Markwordt - CPB 

Gill Wood - EMB 

Darryl Von Lehmden - AREAL 

Al Wehe - SDB 

Laura Butler - SDB 

Joseph Knoll - AREAL 

Roger Shigehara - EMB 

Kelvin Martin - CPB 

Randy McDonald - CPB 

K.C Hustvedt - CPB 

Rodney Midgett - AREAL 

Tom Walton - SDB 

Bob Rosensteel - CPB 

Debbie Stackhouse - SDB 

Bob Kellam - PAB 

After brief introductions of those in attendance, an agenda was distributed as 

a guide for discussion during the meeting (Attachment I). 
P.3 

: "v 

3; Air Toxics Implementation: 

Bob Kellam of the Pollutant Assessment Branch provided an overview of the 

authority contained in proposed legislation before Congress (H.R.3030/S.1490) 

and discussed implementation activities for which ESQ of OAQPS has the lead 

(Attachment 2). 

4. Hazardous Organic NESHAP Overview: 

The next topic of discussion was the general technical approach to the rule 

making and discussion of the individual regulations lead by the EPA and Radian 

representatives identified in the agenda (Attachment 3). 

There was general discussion concerning details of the technical analysis, and 

EPA representatives identified some potential areas for industry input, e.g. 

characteristics of production or user processes of one or more of the organics 

on the list of 191, baseline levels of control, distribution of tanks by size, 

and information on distribution of transfer operations. A CMA representative 

asked for EPA to provide a list of processes where technical inputs were not 

available in the literature, and the industry would try to provide data to 

fill those gaps. 

5. The proposed program for developing emission measurement methods for 

organic pollutants on the list of 191 was discussed by a representative from 

AREAL (Attachment 4). There was a request from the AREAL representatives for 

further interaction with industry in identifying and providing sites for 

methods development testing and possible joint cooperation in developing 

methods. 

6. The draft questionnaires for transfer emissions and wastewater were 

distributed to the attendees (Attachments 5 and 6) , and the industry 

representatives agreed to provide comments by February 16, 1990. 

7. The CMA responded with specific proposals for follow-up activities in a 

letter to me dated February 1, 1990 (Attachment 7). 

cc: Glenn Rives, Radian 

Debbie Stackhouse, (MD-13) 
P.4 

Attachment I 

Agenda 

CMA and EPA Meeting to 

Discuss Hazardous Organic NESHAP (HON) 

January 30, 1990 

I. Introduction - Bob Rosensteel 

II. Title III Implementation - Bob Kellam 

III. HON Technical Approach 

A. Overview - Debbie Stackhouse 

B. Process Vents - Bob Rosensteel 

C. Equipment Leaks - Dave Markwordt 

D. Transfer Operations - Dave Markwordt 

E. Storage - Randy McDonald 

F. Wastewater - K.C. Hustvedt 

G. Industry Profile - Reese Houle 

IV. Sampling/Analytical Methods Program - Joe Knoll 

V. Discussion of Draft Questionnaires 

A. Transfer Operations - Dave Markwordt 

B. Wastewater - K.C. Hustvedt 
AIR TOXICS 

IMPLEMENTATION PLANNING 

pi 

o 

zr B 

a 

Information Briefing 

for 

CMA 

January 30, 1990 

u 
PURPOSE 

Describe Activities Necessary to Implement Title III 

Identify Major Implementation Issues 

Discuss Coordination Plans 

b> 
H.R. 3030/S. 1490 

Title III - Air Toxics 

i 

Alternative Compliance 

i I 

Exemption from MACT upon 

domondrntion of vokmtsfy 

90% omission foduction I 

1 

Exemption from MACT 

upon damonttration of 

•—•-•*- • * * 

J 

List ol191 

Hazardous 

I 

1 Petitions to""! 

PuUWi Major 

Source Category 

UaHnFW 

naWMrt 12{imOn-tfi 

EPA ranking of 

Raoutotory Aoanda 

I 

Maximum Achievable 

Control ToohnotoQy 

(MACT) 

I 

I 

Pr omiaaato standard* to protect adequately 

against "unreasonable mm* oonaldaring 

coat, technical leatNfty. and haattt-basad 

Stales Issue 

Oparaling Parmta 

EPARifhw 

^i 
QinnipD<®inni(©o1tSQ."ttooo ^otowo'ttO 

Specified Actions 

Procedural Requirements 

Coordination with Other Titles 

co 
Specified Actions: 

Publish Source Category List 

Meet Regulatory Timetables 

Issue Negligible Risk Guidance 

Issue Voluntary Reduction Guidance 

Conduct Utility Steam Generator Hazard Study 

Promulgate Accident Prevention Regulations and Pollutant List 

Conduct Great Lakes Study * 

* added in Lent-Dingell substitute 

CO 
Procedural Requirements: 

Procedures for addition/deletion of pollutants (including petitions) 

System for ranking source categories 

Criteria for establishing lesser quantity for major source cut-offs 

Rationale for designation of area source categories 

Procedures for withdrawal of source categories 

Health benchmarks for listed pollutants 

Criteria and scope of unreasonable residual risk determination 

Research on prevention, measurement, and control of emissions 

and evaluation of health and ecological risk 

Mechanism for assistance to small sources (Clearinghouse) 

* added in Lent-Dingell substitute 

O 
Coordination with Other Titles: 

Title I-Ozone, PM10 

• Co-Control 

• Ranking by Toxic Fraction 

• Lead 

Title II - Mobile Sources 

• Study of Air Toxics from Mobile Sources 

Title IV - Permits 

• Negligible Risk, Voluntary Reduction Guidance 

• Training of Permitting Authorities 

• Permit Data Base 

Title VII - Miscellaneous 

• Air Pollutant Release Investigation Board 
SCRS 

MACT 

Negligible 

Risk 

Guidance 

Voluntary 

Reduction 

Guidance 

Petitions to 

Add/Delete 

Utility 

Study 

Great 

Lakes 

Study 

Accidental 

Release 

Regulations 

lf/09 EhadmMf 

Implementation Timeline 

Enactment*! Ei-d0imli2 EhadmenM &iatf/ne/iM Enactments 

Title il 

Study 

Title IV 

Permits 

Prop )se 

Guid wee 

Petit 

Filod 

Prop pse 

Miniinum 

Elerr 

Pub ish 

"15 ~ 

Propo 

Categ Mies 

(ind. ben hmarks) 

Prop ase 

>e 10 Promul jate 10 pr0p 0S e 

Guid mce 

Promt Igate 

Guida ice 

ons 

ents 

Categ Dries 

(ind. bei tchmarks) 

Prorr ulgate 

Guid mce 

Grant or 

Deny 

and 

Complete 

Toxics Study 

Pror mlgate 

Mini num 

Elements 

25 Vo 

(ind. be -dvnaiks) (ind. ben -nmarks) 

Repc rt to 

Conj ress 

Pro; ose Prorr ulgate 

Regufi itions Regul ttions 

Ust and 

Prom jlgate 

25>/« 

Exte naJ 

Re>ri 

List 

Report :o 

ew Congre ss 
Immediate Priorities: 

Complete Source Category Ranking 

Decide on Area Sources, Lesser Quantity Criteria 

Identify and Proceed with Regulation Development 

for Initial Categories 

Develop Negligible Risk Guidance and Health Benchmarks 

for First Standards 

Develop Voluntary Reduction Guidance 

Establish Petition Response Procedures 

Develop Tracking System for Activities 

TI 

CO 
Near Term: 

Select Additional Categories for Regulation Development 

Develop Health Benchmarks for Remaining Pollutants 

TI 
At Enactment: 

Initiate Utility Study 

Begin Development of Accidental Release Regulations and List 

Begin Planning Great Lakes Study 

Initiate Development of Research Objectives 

Establish Assistance Mechanism for Small Sources 

TI 
DRAFT AGENDA 

February 7, 1990 

8:00 - 8:45 Welcome and Overview of Title III - Plenary Session 

8:45-9:15 SESSION I: Source Category Identification and Ranking 8:45-9:15 

9:15-10:30 Split into Discussion Groups 

10:30-10:45 Coffee Break 

10:45-11:30 Reports from Discussion Groups 

9:15-10:30 

10:30-10:45 

10:45-11:30 

SESSION II: Petition Process and Criteria for 

Additions/Deletions 

Split into Discussion Groups 

Coffee Break 

Reports froa Discussion Groups 

11:30-1:00 LUNCH 

1:00-1:30 SESSION III: Development of MACT standards and 

Initial Source Category Selection 

1:30-3:45 Discussion and Sugary 

1:00-1:30 SESSION IV: Negligible Risk Guidance 

1:30-3:00 Split into Discussion Groups 

3:00-3:45 Reports froa Discussion Groups 

4:00-5:00 SlBMARi - Plenary Session 
DRAFT AGENDA 

February 8, 1990 

8:00-8:15 Brief Status Report - Plenary Session 

8:15-8:30 SESSION V: Unreaeoaable Risk Determination 

8:30-9:30 Split into DiSCUSSiOD Groups 

9:30-9:45 Coffee Break 

9:45-10:00 Reports froa Discussion Groups 

10:00-10:15 SESSION V (Cont): Research Needs 

10:15-11:15 Split into Discussion Groups 

11:15-11:30 Reports froa Discussion Groups 

8:15-8:45 SESSION VI: 90* Voluntary Reduction 

Guidelines 

8:45-10:15 Split into Discussion Groups 

10:15-10:30 Coffee Break 

10:30-11:30 Reports fron Discussion Groups 

11:30-1:00 LUNCH 

1:00-1:15 SESSION VII: Coordination with Other Titles, Offices 1:00-1:40 SESSION VIII A: Accidental Release Regulations 

Discussion and Suaury 

1:15-2:15 Discussion & Sumary 1:40-2:15 B: Great Lakes Study 

Discussion and Suaury 

2:15-3:15 Split into Constituent Groups (Regional Offices, STAPPA/ALAPCO, 

Program Offices, ORD, Enforcement) to Identify Issues Specific 

to the Groups 

3:15-4:00 Reports froa Constituent Groups 

4:00-5:00 SUMMARY 

TJ 
P.18 

Attachment .3 

Hazardous Organic NESHAP 

Project Overview 

Coverage: 

- Production of organic hazardous air pollutants (HAP's). 

- Use of organic HAP's in SOCMI industry. 

Source Category: Could be defined as chemical production unit 

(e.g. butadiene production is a source category). 

Emission Sources: 

- Continuous process vents 

• Air oxidation vents 

• Distillation vents 

• Reactor vents 

- Storage tanks 

- Pumps, valves, flanges (i.e., equipment) 

- Transfer equipment (i.e., loading racks) 

- Wastewater handling equipment 

Other Coverage: Could potentially include storage and 

equipment leaks associated with pesticides, pharmaceuticals, 

styrene-butadiene rubber production, and others. 

Standards: Plan to develop generic standards for each emission 

source to broadly cover all or most source categories. 

Sasis For Standards: 

Would rely on existing data bases and controls from 

previous NSPS sources. 

• Process vents - 98% control by incineration or 

flaring. Could potentially have a cutoff based on 

emissions, cost-effectiveness, or other vent stream 

characteristic. 

• Storage tanks - 95% control with fixed roof control 

vented to vapor recovery or destruction devices or 

use of equivalent controls. Could have cutoffs 

based on tank size, chemical vapor pressure, or 

other criteria. 

• Equipment leaks - Current approach is about 60 

to 70% control. EPA is negotiating a new approach 

that may achieve 95% control. 

- Section 114 information collection effort is needed on 

transfer and wastewater. Existing information such 

as benzene NESHAP, industrial wastewater CTG would also 

be used. 
P.19 

Project Schedules: Schedules are grouped consistent with the 

time needed to complete data gathering and analysis. 

Emission Sources 

1. Air Oxidation vents 

2. Distillation vents 

3. Reactor vents 

4. Storage 

5. Equipment leaks 

6. Transfer 

7. Wastewater 

Proposal 

6/91 

8/91 

10/91 

Promulgation 

6/92 

8/92 

10/92 
P.20 

j . ' 

EQUIPMENT LEAKS 

TECHNICAL BASIS FOR THE STANDARD: 

. Regulatory Negotiation Committee 

APPROACH: 

Develop model plants based on in-house data 

Profile will be provided via another task 

Develop emission impacts 

allocate model plants 

hazards associated with chemical 

Update costs from NSPS and Use Reg/Neg 
P.21 

PROCESS VENTS 

SCOPE: 

. Separate regulations will be developed for reactor processes, 

distillation processes, and air oxidation processes. 

Only continuous product processes will be included in this effort 

TECHNOLOGY BASIS OF STANDARDS: 

. Combustion control devices (thermal incinerators, flares) 

APPROACH: 

Use existing data bases for vent stream characteristics - air 

oxidation, distillation; reactor processes and 114 data collected 

for source assessments. 

Identify product/processes for each SOCMI chemical on the HAP list 

as air oxidation, or reactors or distillation. 

Develop model plants for each process type including number of 

vents, and vent stream characteristics. 

Identify HAP to total VOC ratio for model streams. 

Calculate baseline emissions, potential emission reductions, 

control costs, and cost effectiveness for model vent streams. 

Extrapolate model vent stream emissions and costs for development 

of national impacts. 

AREAS WHERE CMA CAN CONTRIBUTE: 

Existing level of control 

Characteristics of production/user processes 
P.22 

STORAGE TANKS 

SCOPE: 

Tank services covered: 

• Raw material storage 

Intermediate product storage 

Product storage 

• 

Tank type covered: 

• Fixed-roof tanks 

• Floating-roof tanks 

Open-top tanks 

TECHNICAL BASIS FOR THE STANDARD: 

Subpart Kb and demonstrated technology more effective than 

controls required jy Subpart Kb. 

APPROACH: 

Develop industry profile with respect to storage tank types, tank 

sizes and controls, from readily available information. The bulk 

of this information will come from Source Assessment/Source 

Category Investigations. 

Extrapolate the impacts of controls on the model processes to 

develop national impacts. 

AREAS WHERE CMA CAN CONTRIBUTE: 

Distribution of tank types and sizes in service 

Existing level of control 
P.23 

TRANSFER OPERATIONS 

(Tank Trucks, Railcars, Marine Vessels) 

TECHNICAL BASIS OF STANDARD: 

Combustion device capable of 98% reduction of VOC 

APPROACH: 

CAA amendment/Marine Vessel Control 

Army Corps of Engineers data base for industry profile 

National Research Council Study for costs 

. Tank Trucks/Rail cars 

Section 114 Request for Data 

Develop models for loading operations 

Benzene transfer regulation provides cost basis 

Industry profile provided via separate task 

Develop national impacts 

AREAS WHERE CMA CAN CONTRIBUTE: 

• Review draft 114 Questionnaire 

. Provide industry profile data 

. Existing control requirements (by State) 
P.24 

WASTEWATER 

TECHNICAL BASIS OF STANDARD 

Collect certain wastewater streams at the point of generation and 

transfer through closed piping and controlled storage tanks to a 

treatment device (likely steam stripper). Alternatives of controlling 

the wastewater system would likely be allowed. 

GENERAL APPROACH 

Existing information- gathered through Section 114 questionnaires to 

support the development of the CTG for industrial wastewaters and 

through Section 308 questionnaires to support Effluent Guidelines 

developed will be used. 

Additional information gathering to fill data gaps will be conducted 

through Section 114 questionnaires. 

Model plant analysis will be used to estimate impacts such as baseline 

emissions, potential emission reductions, control costs, and cost 

effectiveness of control. 

The model plant impacts will be extrapolated to develop national 

impacts. 

AREAS WHERE CMA CAN CONTRIBUTE: 

Number and volume of continuous and batch streams per product process. 

Organic loading in streams (i.e. percent of saturation) 
P.25 

INDUSTRIAL PROFILE TASK 

PURPOSE: 

Characterize the SOCMI Industry as it relates to the organic HAPs 

listed in the CAA (either produced or used) and the sources to be 

regulated. This includes: 

Identify the SOCMI product processes where a HAP is produced or 

used as a reactant (number of facilities and quantities 

processed). 

Identify the types of emission sources likely to be present in 

each product process (i.e., reactor vents, distillation vents, 

fixed roof storage, etc.). 

Develop chemical trees, so that the cost impacts on various 

chemical products can be evaluated. 

Develop the conceptual framework for evaluating the costs and 

environmental impacts of candidate regulatory options 

APPROACH: 

Working from the list of -350 SOCMI chemicals in 40 CFR 60 VV, identify 

the major production routes for each chemical, the raw materials and 

the products. Identify the organic chemicals reacted or produced in 

each process that are HAPs (based on CAA bill). 

Develop information on the number of plants that use each process, the 

quantity of each HAP used and the quantity of each HAP produced. In 

most cases, process stochiometry will be used to estimate use as a 

factor of production. Also, develop information on the geographical 

distribution of plants. 

Develop chemical use trees for all of the HAPs produced or used in 

SOCMI. 

Review State regulations to determine the required baseline level of 

control for various geographical regions, for each emission source 

type. 

Assign a representative set of model sources (i.e., process vents, 

storage tanks, equipment components) to each product process. 

Based on model source assignments, State regulations, number of plants, 

and geographical distribution; estimate baseline emissions. 

For each regulatory option, compute national impacts (emission 

reduction and costs) for each product process based on model 

assignments, and then sum for all product processes. 
P.26 

AREAS WHERE CMA CAN CONTRIBUTE: 

Filling information gaps: descriptions of SOCMI processes for which 

there is no information in public sources, including the number of 

facilities and capacities. 

Assignment of representative models to product processes for which 

there is no emissions data available. 

Identification of product processes which do not have certain emission 

source types. For example, there may not be raw material storage tanks 

or loading operations due to captive use. 

Assist in defining baseline control levels. 

Since much of the current emissions data is for VOC, the HAP portion of 

total VOC will need to be estimated. CMA could provide assistance is 

estimating the HAP:V0C ratios for specific product processes. In the 

case of wastewater, assistance in estimating the ratio of HAPs to 

priority pollutants could reduce Information gathering requirements 

significantly. 
NEED FOR MEASUREMENT METHODS 

CONDUCT INDUSTRIAL SURVEYS 

DETERMINE CONTROL DEVICE EFFICIENCY 

USE IN THE STANDARD SETTING PROCESS 

VALIDATE "NEGLIGIBLE RISK" CLAIMS 

DETERMINE IF MACT DEVICES ARE WORKING 

DEVELOP PERFORMANCE STANDARDS FOR CEMS 

VALIDATE "RECORD KEEPING" STANDARDS 

o 

-T 

a 

a 
SCREENING METHODS 

MEASURES A COMMON PROPERTY 

DOES NOT GIVE COMPOUND SPECIFIC 

INFORMATION 

USEFUL TO DEMONSTRATE OPERATION OF MACT 

USEFUL WHEN ONLY A SINGLE POLLUTANT IS 

EMITTED 

USEFUL WHEN ALL EMISSIONS ARE REGULATED 

USEFUL WHEN EMISSIONS ARE FAR BELOW 

STANDARD 

oo 
EXAMPLES OF SCREENING METHODS 

TOTAL HYDROCARBON ANALYZER (THC) 

AN INSTRUMENTAL METHOD 

USE A FLAME IONIZATION DETECTOR 

RESPONSE VARIES WITH COMPOUNDS 

USEFUL FOR ON-LINE MEASUREMENTS 

TOTAL ORGANIC CHLORINE METHOD (TOCL) 

A MANUAL METHOD 

ORGANIC CMPD COMBUSTED, CHLORIDE MEASURED 

FOR SCREENING CHLORINATED SOLVENTS 
GENERIC METHODS 

FUNCTIONAL GROUP ANALYSIS 

COMMON SAMPLING AND ANALYTICAL 

METHOD 

YIELDS COMPOUND SPECIFIC INFORMATION 

SAMPLE QUANTIFIES MORE THAN ONE 

POLLUTANT 

SAVES TIME AND COST IN DEVELOPMENT 

CO 
EXAMPLES OF GENERIC METHODS 

CHLORINATED HYDROCARBONS 

BROMINATED HYDROCARBONS 

ALDEHYDES AND KETONES 

ISOCYANATES 

ARYL AMINES 

HYDRAZINES 

VOST METHOD 

MODIFIED METHOD 5 (Semi-VOST) 

TI 

CO 
METHODS DEPEND ON THE LEVEL OF THE STANDARD 

DIFFERENT TECHNIQUES ARE NEEDED FOR DIFFERENT LEVELS 

EXAMPLE: BENZENE 

IN THE 1-100 PPM RANGE: 

Tedlar Bag Sampling, GC-FID Measurement 

Sample Stability Better, Detection Limits 

Not Problem 

Both Development and Use Less Costly 

IN THE PPB RANGE: THE VOST METHOD MUST BE USED. 

Absorber Tube Collection, GC/MS Measurement 

Both Development and Use More Expensive 
POLLUTANT-SPECIFIC METHODS 

SOME POLLUTANTS HAVE UNIQUE PROPERTIES 

SOME ARE HIGHLY REACTIVE 

SOME MAY OCCUR IN UNIQUE MATRICES 

EXAMPLES: 

DIAZOMETHANE 

ETHYLENEIMINE 

PHOSGENE 

PHOSPHENE 
SCHEDULE 

f-91 

SCREENING METHOD FOR CHLORINATED ORGANICS COMPLETED. 

GENERIC METHOD FOR CHLORINATED ORGANICS INITIATED. 

METHODS FOR FIFTEEN POLLUTANTS COMPLETED, BY BOTH GENERIC AND POLLUTANT 

SPECIFIC PROCEDURES. 

DESIGN AND ACQUIRE THC CEMS AND BEGIN FIELD TESTS. 

DEVELOP METHOD SPECIFIC QUALITY ASSURANCE GUIDANCE, AUDIT MATERIALS AND 

PROCEDURES. 
SCHEDULE 

-92 

GENERIC METHOD FOR CHLORINATED AND BROMINATED ORGANICS COMPLETED. 

GENERIC METHOD FOR ALDEHYDES AND KETONES COMPLETED. 

Tbrh 

METHODS FOR TWENTY-FIVE POLLUTANTS COMPLETED BY BOTH GENERIC AND POLLUTANT 

SPECIFIC PROCEDURES. 

FIELD TEST THE THC SYSTEM ON MACT APPLICATION DURING STANDARDS SETTING 

PHASE. 

DEVELOP METHOD SPECIFIC QUALITY ASSURANCE GUIDELINES AUDIT MATERIALS AND 

PROCEDURES. 
SCHEDULE 

r-93 

GENERIC METHOD FOR ISOCYANATES COMPLETED. 

METHODS FOR TWENTY-FIVE POLLUTANTS COMPLETED BY BOTH GENERIC AND POLLUTANT 

SPECIFIC PROCEDURES. 

CONDUCT PROGRAM OF SPECIFIC TOXIC ORGANIC CEMS FOR THOSE COMPOUNDS 

REQUIRED. 

REPORT ON AUDIT RESULTS. 
SCHEDULE 

?Y-94 

GENERIC METHOD FOR ARYL AMINES COMPLETED. 

METHODS FOR TWENTY-FIVE POLLUTANTS COMPLETED BY BOTH GENERIC AND POLLUTANT 

SPECIFIC PROCEDURES. 

?T-95 

METHODS FOR TEN SPECIFIC POLLUTANTS COMPLETED. 

TI 

CO 

^1 J 
SCHEDULE 

FY-96 

METHODS FOR TEN SPECIFIC POLLUTANTS COMPLETED 

FY-97 

METHODS FOR TEN SPECIFIC POLLUTANTS COMPLETED 
P.39 

Attachment 5 

ATTACHMENT 

TRANSFER EMISSIONS 

This information request is directed toward each loading rack at a plant 

that loads a "SOCMI/HAP". For those racks that are used to transfer SOCMI/HAP 

chemicals, please provide the following information on Tables 1 though 5 for 

all products loaded. The information should include data on non SOCMI/HAP 

materials loaded at the rack. This information should be for the calendar 

year 1988 and will be used to estimate loading emissions. The materials 

transferred should include any raw materials, feedstocks, products, wastes, 

and intermediates for the entire facility that load into tank trucks, 

railcars, and marine vessels. 
TABLE 1. MATERIAL TRANSFER* 

Haterial 

Rack/Dock* 

Designation 

Quantity 

Transferred6 

(SaO 

Percent of 

Total 

Production 

Tranaferred 

Coaposition 

of 

Product11 

(Vol. X or 

Ut. X) 

(Circle your 

Choice) 

Transfer Vehicle Breakdown* 

Tank Marine Loading 

Truck Raitcar Vessel Teaperature* 

(X) (X) (X) (°F) 

ro 

'Coaplete Tabla 1 for each Material containing a NAP chemical. 

^Provide unique identifier for each rack or dock. 

'Provide tha total quantity transferred containing the subject HAP cheaical and any other cheat cats 

if a Mixture. 

Provide a coaplete coaposition of the product transferred. 

"Provide the percent breakdown by transfer vehicle for each cheaical. 

Provide the Material teaperature during loading. 

vch/098 

TI 
TABLE 2. TRANSFER VEHICLE SPECIFICATIONS* 

P.41 

Transfer 

Vehicle 

Loading" 

Technique 

Rated 

Capacity 

Range 

(Gallons) 

Number' 

in Fleet 

Number In 

Fleet Fitted 

With Emissions. 

Controls 

Tank Truck 

Rail car 

Marine Vessel 

'Identify transfer vehicle specifications for your carrier fleet. 

"Splash loading, submerged loading, or bottom filling. 

'Number of transfer vehicles in your carrier fleet. 

vch/098 
P.42 

TABLE 3. TANK TRUCK LOADING RACK OPERATION 

Rack 

Designation* 

Number Trucks 

Loaded 

Simultaneously 

Maximum Loading 

,For All 

Arms" 

Emission 

Controls5 

'Correlate to Table 1. 

"Provide maximum total loading rate for all arms loading simultaneously in 

GPM. 

cIdentify the emission control device and complete Table 6 if appropriate. 

vch/098 
P.43 

TABLE 4. RAILCAR LOADING RACK OPERATION 

Rack 

Designation* 

Number Cars 

Loaded 

Simultaneously 

Maximum Loading 

For All 

Armsb 

Emission 

Controls' 

•Correlate to Table 1. 

"Provide maximum total loading rate for all arms loading simultaneously in 

GPM. 

'Identify the emission control device and complete Table 6 if appropriate. 

vch/098 

J 
P.44 

TABLE 5. MARINE VESSELS LOADING DOCK OPERATION 

Dock 

Designation* 

Number Vessels 

Loaded 

Simultaneously 

Maximum Loading 

For All 

Arms* 

Emission 

Controls' 

'Correlate to Table 1. 

"Provide maximum total loading rate for all arms loading simultaneously in 

GPM. 

'Identify the emission control device and complete Table 6 if appropriate. 

vch/098 

J 
P.45 

TABLE 6. EMISSION CONTROL DEVICES 

Control VOC 

Rack/Dock Control Oevlce Destruction 

Designation* Device Design Capacity Efficiency 

*If a single control device 1s used for more than 1 rack/dock, 11st all 

applicable rack/dock designation. 

vch/098 
P.46 

Attachment 6 

ENCLOSURE 1 

IDENTIFICATION OF PLANT LOCATIONS AND SPECIFIC PROCESS UNITS 

(WHERE POSSIBLE) FOR WHICH INFORMATION IS REQUESTED 

nja.029 1-1 
P.47 

ENCLOSURE 2 

WASTEWATER HAZARDOUS ORGANIC NESHAP QUESTIONNAIRE 

The purpose of this questionnaire is to gather information on potential 

air emissions from the collection, treatment, and handling of industrial 

wastewater. The information requested is for each process unit specified in 

Enclosure 1. For each of these process units, information should be reported 

for all hazardous air pollutants listed in Enclosure 3 and for total organic 

compounds. The compounds listed in Enclosure 3 are the organic compounds in 

the list of 191 hazardous air pollutants. The information requested is for 

the 1989 calendar year. 

Enclosure 3, which presents of the 191 potentially hazardous air 

pollutants (HAPs), includes only the organic compounds in the list of 191. 

Throughout this questionnaire, information is requested for all of these HAPs 

used or produced in specific process units within your facility. To 

facilitate completing this questionnaire, your responses may be keyed to "HAP 

codes." If you wish to avoid repeatedly listing each pollutant throughout the 

questionnaire, complete Table 1 for all applicable HAPs. 

The questionnaire is designed to gather information on wastewater streams 

at the point of process generation (such as a water wash column or a 

decanter), prior to exposure to ambient air and prior to mixing with 

additional wastewater streams. These streams may be continuous or 

intermittent (batch streams, leaks, and spills). Information is also 

requested for any operations (such as steam stripping, or carbon adsorption) 

utilized at the facility to remove or recover organic compounds from 

wastewater streams or to treat these streams before discharging the wastewater 

from the process. 

The questionnaire Is divided into the following three sections; 

(A) Company and Process Information, (B) Process Wastewater Stream Data, and 

(C) Information on Recovery/Removal Operations. Section A, Table 2 in 

Section B, and the applicable tables in Section C should be reproduced and 

completed for each process unit listed 1n Enclosure 1. Sampling data is 

requested in Section B. Please provide these data if available, however, 

additional sampling is not required.- If the information is not available, 

please provide a best estimate of the requested pollutant loading and 

concentration data. 

nja.029 2-1 
P.48 

TABLE 1. HAZAROOUS AIR POLLUTANT CODES 

HAP Code 

Chemical A 

Chemical B 

Chemical C 

Chemical D 

Chemical E 

Chemical F 

Chemical G 

Chemical H 

Chemical I 

Chemical J 

CAS Number Chemical Name 

nja.029 2-2 
P.49 

Section C 1s designed to obtain detailed information on each operation 

utilized to recover or remove organic compounds from process wastewater 

streams generated in the process unit or to treat wastewater streams prior to 

discharge from the facility. Complete flnly. the tables that are applicable to 

this process unit. 

The following Sections are to be completed for each process unit at the 

facility listed in Enclosure 1. Please make a separate coov of these sections 

for each applicable process unit. 

nja.029 2-3 
« 

SECTION - A 

COMPANY AND PROCESS INFORMATION 

I. COMPANY INFORMATION 

Please provide the following company information. 

A. What is the primary 4-digit Standard Industrial Classification (SIC) 

code for this facility? 

B. What is the secondary 4-digit SIC code for this facility? 

II. GENERAL PROCESS INFORMATION 

Provide the following information for each process unit Identified in 

Enclosure 1 that generates wastewater streams containing any of the 

compounds listed in Enclosure 3. 

A. Process ID 

B. Process Name 

C. Process Description 

nja.029 2-4 

P.50 
P.51 

D. Provide a process block flow diagram identifying all process stream 

(e.g.,. inputs/feedstocks, intermediate products, products, 

byproducts) and wastewater streams. Provide a description of the 

wastewater streams (e.g., wash tower sour water, decanter drawoff, 

etc.) and show any operations utilized to treat or remove/recover 

organic compounds from these wastewater streams. Each wastewater 

stream should be identified by an identification number for use in 

Table 2 presented in Section C. Operations utilized to treat or 

remove/recover organic compounds from these wastewater streams 

should be assigned identification numbers as well. 

Product(s) 

F. Type of Process - batch, continuous, semi-continuous 

(circle one) 

G. Nominal Production Capacity (Design Capacity) (pounds/year) 

H. Capacity Utilization for the 1989 Calendar Year 

(% of design capacity) (list for each product) 

nja.029 2-5 
P.52 

I. What were the main CHEMICAL INPUTS/FEEDSTOCKS used by the 

process in 1989 and how much was used of each input/feedstock? 

Identify by chemical name or HAP code if appropriate. 

Chemical Inputs/Feedstocks Quantity Used in 1989 

pounds or - tons 

pounds or tons 

pounds or tons 

, pounds or tons 

What was the principal chemical product (by weight) that this 

process unit produced in 1989? Identify by chemical name or HAP 

code if appropriate. 

How much of the principal chemical product did this process unit 

produce in 1989? 

L. What is the main END USE of this principal chemical product? 

M. Did the process unit produce any other chemical products in 1989? 

Yes No (If No, skip to question P) 

nja.029 2-6 
P.53 

N. What other chemicals did this process unit produce in 1989 and how 

much did it produce of each of these other chemical products? 

Identify by chemical name or HAP code if appropriate. 

Other Chemical Products Quantity Produced in 1989 

oounds or 

pounds or 

pounds or 

pounds or 

tons 

tons 

tons 

tons 

0. What were the main END USES of these other chemical products in 1989? 

Other Chemical Products End Use of Chemical Products 

P. What was the total value (1989$) of each individual chemical product 

produced by this process unit in 1989? 

Q. List below any HAPs that occur in wastes (other than wastewater) or 

Intermediate materials that were produced in this process in 1989 

and the quantity produced of each. Identify by chemical name or HAP 

code if appropriate. Do not include any wastes that are permitted 

under the Resource Conservation and Recovery Act (RCRA) or that are 

managed in RCRA-permitted units. An example of a waste that should 

be reported would be a waste that 1s recycled and reused in the 

production process'. 

nja.029 2-7 
P.54 

Wastes/Intermediate Material Quantity Produced in 1989 

" pounds or tons 

pounds or tons 

_ pounds or ions 

pounds or tons 

R. For each waste or intermediate material Identified in 4 above, 

indicate the destination of that material (e.g., recycled within the 

production unit, used in another production unit, sold as 

intermediate, etc.) 

Waste/Intermediate Material Destination 

nja.029 2-8 
P.55 

SECTION - B 

PROCESS WASTEWATER STREAM DATA 

For each process wastewater stream shown 1n the flow sheet diagram, 

provide the information requested in Table 2. The table requests information 

on process wastewater flow data, and process wastewater pollutant 

concentration data. 

The process wastewater flow questions are designed to obtain flow 

characteristics of each process wastewater stream shown in the diagram 

requested in Section A. The information requested should be completed for all 

wastewater streams. For intermittent wastewater streams, please provide best 

estimates of frequency, duration, and flow rate during flow periods. If the 

information on the wastewater streams provided Is based on actual sampling 

data, provide sampling period, frequency, and method. 

Table 2 also requests individual HAP and total organic compound 

concentration data for each individual process wastewater stream at the point 

of generation (prior to mixing with other wastewaters). If the wastewater 

stream was sampled, please provide the measured concentrations of each HAP 

detected, and the total organic compound concentration in Table 2. In 

addition, please indicate the analytical method utilized to quantify each 

pollutant concentration. If sampling was not conducted, please provide a 

best estimate of the requested concentrations based on operational 

considerations (e.g., equilibrium solubility, etc.). 

nja.029 2-9 
TABLE 2. PROCESS WASTEWATER STREAM DATA 

Oraenlc Concentration 

Waatawatar* Waatawajar flow pat. Annua l ^.^.4 t„lm t 

Streaa 10 Flow Rata" Unlta litli for Eatlaatec Caaapound" Average Kanae" Eatlaate* Controla* 

*Uae atraaa IdantlfIcatIon provldad ln tha procaaa flow dlagraa. 

If contlnuoua. raport flow durlna noma I oparatlon. If noncont lnuoua, provlda frequency of flow (nuabar par day), duration of flow (hr). and 

flow rata (gal/hr). 

cIf flow cat* aaaaureaant data ara avaliabla, provlda aaapllna period, aaapllna anthod, and fraquancy. If flow rata la baaad on an aatlaata, provlda 

baals for aatlaata. 

"Provlda Individual concantratlona for all HAPs llatad ln Encloaura 3 which ara praaant In tha waatawatar atraaa, and provlda a total orsanic 

concant rat Ion. 

'Provlda tha ranea of concant rat lona aapactad for tha compound tn that waatawatar atraaa. 

'Indicate concentration and whether concentration waa aMaaurad (a), or eatlaeted, (a). If aeasured, raport aathod 

(a.».. EPA aethod 601. 625, ate), 

'identify operation* utilised to recover/r«aoy« organic compound* froa tha waatawatar atraaa. Uaa the operation Identification nuabar provldad ln tha 

procaaa flow dlagraa and coaplete appropriate tablaa In Section C for the operation. 
P.57_ 

SECTION - C 

INFORMATION ON ORGANIC RECOVERY/REMOVAL OPERATIONS 

For each operation utilized to recover/remove organic compounds from 

wastewater streams generated by processes that produce or process as a 

reactant any of the HAPs in Table 1, provide the following data concerning the 

specific operations in the appropriate tables. Tables are provided for seven 

operations commonly used to recover/remove organics from wastewater or to 

treat wastewater prior to discharge to a wastewater treatment facility. If an 

operation is being utilized other than one of the seven listed operations, 

please attach a sheet detailing similar design data. 

Information is requested for each operation on the major piece of 

equipment (I.e., the stripper column, the carbon adsorber, etc.). In 

addition, for steam strippers, a breakdown of the major system components as 

well as utility usage is requested. Complete only the tables that are 

utilized in your process. 

nja.029 2-11 
P.58 

TABLE 3. AIR STRIPPING - COLUMN DESIGN 

Air Stripping Column ID* 

Column Operating Variables 

Pressure Drop (psig) 

Temperature (°F) 

Air/Feed Ratio (scfm air/lb feed) 

Column Dimensions: 

Diameter (ft) 

Height (ft) 

Internals: 

Trays (no., type) 

Packing (type) 

Design Efficiency, % 

(Specify by chemical) 

Stripped Organics Destination" 

Air Emission Control Device 

Specify8 

Efficiency, X 

(Specify by chemical) 

*Use the same identification that was used in the flow diagram. 

"Process recycle, incinerator, etc. 

'Carbon adsorber, condenser, etc. 

nja.029 2-12 
P.59 

« .» 

TABLE 4. ADSORPTION - ADSORBER DESIGN 

Adsorber ID* 

Liquid or Gas phase (specify) 

Type of Adsorbent" 

Adsorption Column Dimensions: 

Height, (ft)c 

Diameter, (ft)e 

System Variables: 

Contact time, (m1n)e 

System configuration" 

Adsorbent Regeneration* 

Adsorbent Capacity, 

(lb solute/lb adsorbent) 

Design Efficiency, % 

(Specify by chemical) 

Adsorbed Organics Destination1 

•Use the same identification that was used in the flow diagram. 

"Activated Carbon (GAC.PAC), Ion Exchange Resin, Other (describe). 

'Specify units 1f different from the units listed. 

Parallel, Series, Moving bed, Upflow-expanded bed, Other (specify). 

•Thermal, Chealcal, Other (specify). 

'Incinerator, Recycle to Process, etc. 

nja.029 2-13 
P.60 

TABLE 5. DISTILLATION - COLUMN DESIGN 

Distillation ID* 

Column Operation Mode" 

Column Operating Variables 

Pressure (psig)c 

Temperature (°F)C 

Steam/Feed Ratio* 

Column Dimensions: 

Diameter (ft)c 

Height (ft)c 

Internals: 

Trays (no., type) 

Packing (type) 

Design Efficiency, % 

(Specify by chemcial) 

Distilled Organics Destination* 

Is condenser vented to the atmosphere? 

Condenser Temperature (°F),C 

Condenser Pressure (psig)° 

•Use the saat Identification number that was used in the flow diagram. 

"Batch or continuous. 

'Specify units if not the same as requested. 

Specify units. 

'Incineration, process recycle, etc. 

nja.029 2-14 
P.61 

' *. 

TABLE 6. STEAM STRIPPING - STRIPPER AND AUXILIARY EQUIPMENT DESIGN 

Steam Stripping ID* 

Column Operating Variables 

Pressure Drop (psig)b 

Temperature (°F)b 

Steam/Feed Ratio* 

Steam Temperature (°F)b 

Steam Pressure (pslg)" 

Column Dimensions: 

Diameter (ft)" 

Height (ft)b 

Internals: 

Trays (number, type) 

Packing (type) 

Design Efficiency, % 

(Specify by chemical) 

Stripped Organics Destination11 

•Use the same Identification that was used in the flow diagram. 

"Include units If not sane as requested. 

'Specify units. 

Recycle to Process, Incineration, etc. 

nja.029 2-15 
P.62 

TABLE 6. STEAM STRIPPING - AUXILIARY EQUIPMENT OESIGN (continued) 

Steam Stripper ID* 

System Tanks 

List and specify type," 

Volume (gal)6 

Hold-up time (min)c 

Heat exchangers 

List and specify surface area, ft2)' 

Pumps 

List and specify hp 

Condensers 

List and specify type 

Other system components 

List and specify 

Utility Usage 

Steam (psig, lb/yr)° 

Electricity (kw-hr/yr)« 

Water (gal/yr)e 

Process air (ft3/yr)a 

Other (specify) 

•Use the I.D. used in the flow diagram. 

"Feed tank, treated wastewater surge tank, etc. 

'Specify units if different from the units listed. 

nja.029 2-16 
P.63 

' \. 

TABLE 7. SOLVENT EXTRACTION - EXTRACTOR DESIGN 

Solvent Extraction ID* 

Operation Mode" 

Extracting Solvent Used 

Vessel Description0 

Vessel Dimensions 

Diameter (ft)d 

Height (ft)4 

Sol vent:Feed Ratio* 

Design Efficiency, % 

(Specify by chemical) 

Extracted Organics Destination' 

•Use the same identification that was used in the flow diagram. 

"Batch or continuous. 

'Mixing-settling vessels, spray tower, packed tower, etc. 

dSpecify units if not same as requested. 

'Specify units. 

'Distillation column, Incinerator, etc. 

nja.029 2-17 
P.64 

J i\i 

t *-

TABLE 8. CHEMICAL OXIDATION - OXIDIZER DESIGN 

Chemical Oxidation ID* 

Oxidizing Agent" 

Oxidant:Feed Ratio* 

Reaction Vessel Description4 

Vessel Dimensions: 

Height (ft)* 

Diameter (ft)* 

Required Contact Time (min.)' 

Design Efficiency, % 

(Specify by chemical) 

'Use the same Identification that was used in the flow diagram. 

"Hydrogen peroxide, ozone, potassium permanganate, etc. 

'Specify units. 

"Open top tank, closed vessel, etc. 

'Include units if not same as requested. 

nja.029 2-18 
P.65 

» Vi 

• r 

TABLE 9. BIOLOGICAL TREATMENT - TREATMENT BASIN DESIGN 

Biological Treatment ID* 

Treatment Basin/Tank Description 

Treatment Basin Diameter (ft)c 

Treatment Basin Depth (ft)0 

Minimum Freeboard (ft)* 

Aerators (type) 

Number 

Power (hp)° 

Volume (gal) 

Retention time (hrs)' 

Design Efficiency, X 

(Specify by chemical) 

'Use the same identification that was used in the flow 

diagram. 

"Open top tank, holding basin, surface impoundment (lined, unlined), covered 

tank, etc. 

'Include units if not sane as requested. 

njt.029 2-19 
P.66 

TABLE 10. OIL/WATER SEPARATOR DESIGN 

Oil Water Separator ID* 

Separator Length (ft)" 

Separator Width (ft)" 

Volume (gal)" 

Retention time (hr)b 

Influent Composition 

Oil Fraction (weight %) " 

Total Organic Compounds 

(specify by chemical) 

Design Efficiency (X) 

Oil Fraction 

Total Organic Compounds 

(specify by chemical) 

Removed Organics Destination0 

Utility Usage 

Electricity (kw-hr/yr)" 

Other (specify) 

Air Emission Controls* 

'Use the same Identification that was used in the flow 

diagram. 

"Include units 1f not same as requested. 

'Recycle to process, Incineration, etc. 

'Describe any controls in place to reduce air emissions from the oil-layer. 

nja.029 2-20 
P.67 

ENCLOSURE 3 

HAZARDOUS AIR POLLUTANTS 

CAS 

NUMBER 

CHEMICAL 

NAME 

75070 Acetaldehyde 

60355 Acetamide 

75058 AcetonitrUe 

98862 Acetophenone 

53963 2-Acetylaminofluorine 

107028 Acrolein 

79061 Aery1 amide 

79107 Acrylic add 

107131 Acrylonitrile 

107051 Allyl chloride 

92671 4-Aminobiphenyl 

62533 Aniline 

90040 o-Anisidine 

71432 Benzene (Including benzene from gasoline) 

92875 Benzidine 

98077 Benzotrichloride 

100447 Benzyl chloride 

92524 Biphenyl 

117817 B1s(2-ethylhexy1)phtha1ate (DEHP) 

542881 B1s(chloromethyl)ether 

75252 Bromoform 

106990 1,3-Butadiene 

105602 Caprolactam 

133062 Captan 

63252 Carbaryl 

75150 Carbon disulfide 

56235 Carbon tetrachloride 

163581 Carbonyl sulfide 

120809 Catechol 

133904 Chloranben 

57749 Chlordant 

79118 Chloroacetic add 

532274 2-Chloroacetophenone 

108907 Chlorobenzene 

510156 Chlorobenzllate 

67663 Chloroform 

107302 Chloromethyl methyl ether 

126998 Chloroprene 

319773 Cresols/Cresyllc acid (Isomers and mixture) 

95487 Cresols/Cresyllc acid (Isomers and mixture) 

108394 Cresols/Cresyl1c acid (Isomers and mixture) 

106445 Cresols/Cresyl1c acid {isomers and mixture) 

98828 Cumene 

nja.029 3-1 
P.68 

ENCLOSURE 3 (Continued) 

CAS 

NUMBER 

94757 

3547044 

334883 

132649 

96128 

84742 

106467 

91941 

111444 

542756 

62737 

111422 

121697 

64675 

119904 

60117 

119937 

79447 

68122 

57147 

131113 

77781 

534521 

51285 

121142 

123911 

122667 

106898 

106887 

140885 

100414 

51796 

75003 

106934 

107062 

107211 

151564 

75218 

96457 

75343 

50000 

76448 

118741 

87683 

77474 

CHEMICAL 

NAME 

2,4-D, salts and esters 

DDE 

Diazomethane 

Dibenzofurans 

l,2-01bromo-3-chloropropane 

Dlbutylphthalate 

1,4-D1ch1orobenzene(p) 

3,3-D1ch1orobenzidene 

Dichloroethyl ether (b1s(2-chloroethyl)ether) 

l,3-D1chloropropene 

Dichlorvos 

Diethanolamine 

N,N-D1ethyl aniline (N,N-Dimethylan1l1ne) 

Diethyl sulfate 

3,3'-D1methoxybenz1dine 

Dimethyl aminoazobenzene 

3,3'-Dimethyl benzidine 

Dimethyl carbamoyl chloride 

Dimethyl formamide 

1,1-Dimethyl hydrazine 

Dimethyl phthalate 

Dimethyl sulfate 

4,6-D1n1tro-o-cresol, and salts 

2,4-D1n1tropheno1 

2,4-01n1trotoluene 

1,4-Dioxane (l,4-D1ethyleneoxide) 

1,2-D1phenylhydrazine 

Epichlorohydrin (l-Ch1oro-2,3-epoxypropane) 

1,2-Epoxybutane 

Ethyl acrylate 

Ethyl benzene 

Ethyl carbamate (Urethane) 

Ethyl chloride (Chloroethane) 

Ethylene dlbromide (Dibromoethane) 

Ethylene dichloride (1,2-Dichloroethane) 

Ethylene glycol 

Ethylene 1m1ne (Aziridine) 

Ethylene oxide 

Ethylene thiourea 

EthylIdene dichloride (l,2-D1ch1oroethane) 

Formaldehyde 

Heptachlor 

Hexachlorobenzene 

Hexachlorobutadiene 

Hexachlorocyclopentadiene 

nja.029 3-2 
P.69 

ENCLOSURE 3 (Continued) 

CAS 

NUMBER 

67721 

822060 

680319 

110543 

302012 

123319 

78591 

58899 

108316 

67561 

72435 

74839 

74873 

71556 

78933 

60344 

74884 

108101 

624839 

80626 

1634044 

101144 

75092 

101688 

101779 

91203 

98953 

92933 

100027 

79469 

684935 

62759 

59892 

56382: 

8268% 

87865 

108952 

106503 

75445 

85449 

1336363 

1120714 

57578 

123386 

CHEMICAL 

NAME 

Hexachloroethane 

Hexamethylene-1,6-di isocyanate 

Hexamethy1phosphorami de 

Hexane 

Hydrazine 

Hydroquinone 

Isophorone 

Lindane (all isomers) 

Maleic anhydride 

Methanol 

Methoxychlor 

Methyl bromide (Bromomethane) 

Methyl chloride (Chloromethane) 

Methyl chloroform (1,1,1-Trichioroethane) 

Methyl ethyl ketone (2-Butanone) 

Methyl hydrazine 

Methyl Iodide (Iodomethane) 

Methyl isobutyl ketone (Hexone) 

Methyl 1socyanate 

Methyl methacrylate 

Methyl tert butyl ether 

4,4-Methylene b1s(2-chloroaniline) 

Methylene chloride (01chloromethane) 

Methylene diphenyl diisocyanate (MDI) 

4,4'-Methylenedlaniline 

Naphthalene 

Nitrobenzene 

4-Nitroblphenyl 

4-Nitrophenol 

2-N1tropropane 

N-N1troso-N-»ethylurea 

N-Nitrosodimethyl amine 

N-N1trosonorphol1ne 

Parathlon 

Pentachloronltrobenzene (Quintobenzene) 

Pentachlorophenol 

Phenol 

p-Phenylenedlamine 

Phosgene 

Phthalic anhydride 

Polychlorinated biphenyls (Aroclors) 

1,3-Propane sultone 

beta-Proplolactone 

Propionaldehyde 

nja.029 3-3 
P.70 

CAS 

NUMBER 

ENCLOSURE 3 (Continued) 

CHEMICAL 

NAME 

114261 Propoxur (Baygon) 

78875 Propylene dichloride (l,2-D1ch1oropropane) 

75569 Propylene oxide 

75558 l,2-Propylenim1ne (2-Methyl azlridine) 

91255 Quinoline 

106514 Quinone 

100425 Styrene 

96093 Styrene oxide 

1746016 2,3,7,8-Tetrachlorodibenzo-p-diox1n 

79345 1,1,2,2-Tetrachloroethane 

127184 Tetrachloroethylene (Perchloroethylene) 

7550450 Titanium tetrachloride 

108883 Toluene 

95807 2,4-Toluene diamine 

584849 2,4-Toluene diisocyanate 

95534 o-Toluidine 

8001352 Toxaphene (chlorinated camphene) 

120821 1,2,4-Trichlorobenzene 

79005 1,1,2-Trlchloroethane 

79016 Trichloroethylene 

95954 2,4,5-Trlchlorophenol 

88062 2,4,6-Trichlorophenol 

121448 Triethyl amine 

1582098 Trlfluralln 

540841 2,2,4-Trimethylpentane 

108054 Vinyl acetate 

593602 Vinyl bromide 

75014 Vinyl chloride 

75354 Vinylidene chloride (1,1dichloroethylene) 

1330207 Xylenes (Isomers and mixture) 

95476 Xylenes (Isomers and mixture) 

108383 Xylenes (Isomers and mixture) 

106423 Xylenes (Isomers and mixture) 

0 Glycol ethers* 

0 Polycyllc organic matter" 

'Includes mono and di- ethers of ethylene glycol, diethylene glycol, 

and triethylene glycol R-(OCH2CH2) -OR' where 

n • 

R -

R* 

1, 2, or 3 

alkyl or aryl groups 

• R, H, or groups which, when removed, yield glycol ethers with the 

structure: R-(0CH2CH)B-0H 

Polymers are excluded from the glycol category. 

"Includes organic compounds with more than one benzene ring, and which have 

a boiling point greater than or equal to 100'C. 

nja.029 3-4 
P.71 

Attachment 7 

CHEMICAL MANUFACTURERS ASSOCIATION 

February 1, 1990 

Mr. Robert Rosensteel, Chief 

Chemical Manufacturing Section 

Chemicals and Petroleum Branch 

Office of Air Quality Planning and Standards 

MD-13 

U.S. Environmental Protection Agency 

Research Triangle Park, NC 27711 

^,_ . r. n „ 1-. . 

On behalf of Karen Fidler, myself and the CMA member companies, I 

would like to thank you and the other OAQPS staff for taking the time 

to discuss EPA's plans for implementing Title III of the Clean Air Act 

amendments. The discussion was most informative for us and we .hope 

that we were able to give you some idea of what areas we were concerned 

with and how we may able to provide you with additional information for 

your regulatory development efforts. 

I have listed below some of the topics the group agreed were areas 

for follow up: 

o Holding a joint workshop to discuss specific implementation 

topics in more detail; 

o Holding a meeting to discuss how cost will be factored into 

standard development; 

o Possible joint funding of research activities; 

o Availability of plant sites for EPA research activities; 

o CMA comments on draft questionnaires on wastewater and 

*-.ri7if»fr.r oparst f?r.n; 

o Filling industry profile gaps on selected chemical production 

processes. 

In addition, CMA suggests that we have further discussions on the 

feasibility of providing information to EPA on the following: 

o Existing levels of control in the chemical industry; 

o Characterization of model plants for selected chemical 

production processes; 

o Estimating HAP:VOC ratios for selected chemical production 

processes. 

2501 M Street. NW. Washington. DC 20037 202-887-1100 Telex 89617 (CMA WSH) 
P.72 

2/: 

With regard to the questionnaires, CMA anticipates submitting 

comments to EPA the week of February 12-16. Karen or I will call you 

in the next few days about the best forum for presenting our comments 

to EPA. 

If you have any questions, please give us a call. 

Once again, thank you for the opportunity to meet with you, and we 

look forward to working with you in the future. 

Sincerely, 

Richard G. Sigman 

Associate Director, 

Air Programs 

cc: Michael Shapiro 

Stanley Meiburg 

Bob Kellatn