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OAR Box 1875 

Prepped by Ollie Stewart 

Document Number: 

46) ll-E-64 

Docket Number: 

A-90-19 

Printed 12/1/200811:12:46 AM Sheet 46 of 86 
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- A-90-19 

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: ll-E-64 

SUMMARY OF TELECONFERENCE 

Date: September 29, 1992 

Subject: Chemical Manufacturers Association Issues on the 

Hazardous Organic NESHAP (HON) 

Attendees: Bruce Jordan, Director of the Emissions Standards 

Division, EPA 

Daphne McMurrer, Emissions Standards Division, EPA 

Jan Meyer, Emissions Standards Division, EPA 

Rich Biondi, Deputy Director of the Stationary 

Source Compliance Division, EPA 

Mamie Miller, Stationary Source Compliance 

Division, EPA 

\ Scott Throw, Stationary Source Compliance Division, 

••' EP A 

Jane Engert, Stationary Source Compliance Division, 

EPA 

Charles Garlow, Air Enforcement Division, EPA 

Richard Sigman, Chemical Manufacturers Association 

Ted Cromwell, Chemical Manufacturers Association 

Kathy Bailey, Chemical Manufacturers Association 

Annette Stanley, Chemical Manufacturers Association 

Joe Hovias, Union Carbide 

Brian Taranto, Exxon Chemical 

Chuck Malloch, Monsanto 

John Dege, DuPont 

Jack McClure, Shell 

Attached is a handout EPA provided for this meeting. It was 

the primary subject of discussion. The discussion will be 

summarized in order of the issues described in the handout. 

Bio Units for Wastewater Treatment 

EPA sought CMA comment on the outline for a preamble 

discussion of biotreatment that was included in the handout. CMA 

agreed to comment in the next few weeks. EPA stated that, due to 

a desire to have the HON [proposed in the near future, EPA would 

begin drafting from the outline immediately. 

Recordkeeping for Process Controls 

CMA posed hypothetical questions about what types of 

alternative data gathering and storing systems might be used to 

comply with the HON. EPA stated that a more thorough discussion of 

these systems would be essential before a determination could be 

made. EPA agreed to seek comment on this issue in the HON 

preamble. The preamble discussion would specifically request data 

about how these computer controlled monitoring systems work. 
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Monitoring and Violations 

EPA began the discussion by explaining the questions included 

in the handout. CMA agreed to provide answers to these questions, 

however, they cautioned that it would be very time consuming to 

cover all possible instances in detail, so the answers would be 

general. 

Emissions Averaging 

EPA explained the plan to take comment on CMA's idea of how 

the quarterly emission check requirement should be structured. 

Jack McClure, of CMA, proposed adding an exception to the quarterly 

and annual emissions balances requirement for situations in which 

total actual emissions were lower than total anticipated (and 

permitted) emissions. EPA agreed to consider this idea. 

1 Attachment 
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AGENDA 

CMA/EPA MEETING ON THE HON 

SEPTEMBER 29, 1992 

Issue 1: Bio Units for Wastewater Treatment 

Issue 2: Recordkeeping for Process Controls 

Issue 3: Monitoring and Violations 

Issue 4: Emissions Averaging 
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Outline for Preamble Paragraph on Bio Units 

BSflFF 

Introduction. Draft proposal for HON requires bio units 

to meet same control efficiency as a steam stripper. 

Several concerns have been raised: 

should well operated and maintained bio units in 

conjunction with trapped drains and collection 

systems define the floor? 

has the appropriate reference control technology 

(RCT) been selected? 

will existing treatment systems installed to meet 

other rule requirements have to be augmented by 

steam strippers to comply with HON? 

Discussion of Floor. EPA analysis of floor control was 

based on standards for air emissions. EPA did not have 

the information needed to evaluate performance achieved 

because of the CWA or other rules. Factors suggesting 

there may be a floor level of control for wastewater are: 

biological treatment units are commonly used to 

meet effluent limitations established under CWA 

industry has reported in the last few months that 

common practice is to have trapped collection 

system and that many facilities also have covered 

ponds, lagoons, etc. 

• if wastewater collection systems are typically 

controlled down to the bio unit, then there 

may be a floor level of control 

• if so, must evaluate additional option, 

including effects on costs for steam stripping 

compounds not readily biodegraded 

To determine if there is a floor and the 

performance achieved at a floor defined by bio 

units, need to: 

• determine and document representative 

wastewater collection and treatment system 

designs for SOCMI 

• define performance achieved by best performing 

12% of the sources 
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1H.I 

• identify characteristics of good systems 

• identify representative practices 

Selected Reference Control Technology (RCT). Questions 

concerning the appropriate reference technology control 

have been raised. The steam stripper was chosen as the 

RCT because the information EPA had showed it is the most 

universally applicable technology. The selected RCT is 

being reviewed because: 

in some cases bio units may achieve a high degree 

of control 

• need to evaluate what that performance is and 

characteristics of these systems 

to evaluate bio units, need additional information 

on wastewater collection systems and other 

information outlined in Request for Data below 

if the necessary information is received, EPA will 

evaluate control options based on bio treatment and 

consider whether to issue a supplemental proposal 

for use of bio treatment as a separate RCT 

Request for Data. 

efficiency of bio units in terms of mass removal 

design and operating parameters 

models to predict biodegradation rates 

costs 

collection system design 

compounds not efficiently degraded in bio units 

28 Sep 92 
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Recordkeeping 

Issue: Can systems that do not record data unless there is a 

excursion be used for compliance with the HON? 

EPA Response: 

o Different system from past practice 

Historically required evidence that source was 

actually in compliance, not just proof of when the 

source was out of compliance 

o Enhanced Monitoring/Compliance Certification (Title VII) 

requires that source's certify periods of compliance 

o However, since the issue deals with different types of 

monitoring systems from what is traditionally used, EPA 

is willing to consider alternative requirements 

o For HON proposal, EPA willing to take comment on this 

issue 

Need more info about these systems 

Need to consider what types of requirements are 

appropriate to judge the effectiveness of a 

particular system 

For systems that monitor different parameters than 

what is listed in the HON, need to better 

understand how the monitored parameters relate 

to emissions 

o Info gathered during comment period will be used to 

determine policy for promulgation 
P.8 

HON Compliance and Operating Parameters 

Issues: 1) What should be defined as compliance with the 

HON? 

2) Should a number of parameter monitoring 

excursions be excusable? 

3) If so, how should the system of excusable 

parameter excursions be structured? 

Background 

EPA considering the use of parameter monitoring as an 

indicator of proper operation and maintenance and 

allowing some number ("x") of excursions beyond the 

source's pre-set parameter boundary. Compliance 

would be defined as having fewer than "x" excursions 

in the relevant monitoring period. 

Currently, the HON's monitoring provisions consist of: 

(1) equipment inspections (e.g., by-pass lines, closed 

vent systems); 

(2) parameter monitoring of vapor control devices (e.g., 

temperature monitoring in an incinerator); and 

(3) "work practice" provisions for certain types of 

carbon adsorbers. 

Regarding #2 parameter monitoring: There is 

some variation among the kinds of points, but, in 

general, the monitoring data are averaged over 3-

hour periods. 
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HON Compliance and Operating Parameters cont. 

Questions 

1. General 

a. In a scenario where source's set their own 

parameter ranges, EPA must better understand: 

in which cases are excursions likely to happen 

(certain kinds of points or kinds of devices)?; 

what efforts are needed to prevent 

excursions?; 

what is needed to stop on-going excursions?; 

How long should it take to stop an excursion? 

b. EPA needs CMA to identify causes for excursions 

outside the parameter boundaries that a source 

would set for themselves in the permit, such as: 

operating variations? 

control device "malfunctions"? 

others? 

2. Scope 

a. Should parameter monitoring for Group 2 points be 

treated differently than monitoring of devices 

controlling Group 1 points? 

For example, vents maintaining a TRE > 1 

with recovery or facilities that meet facilitywide total waste quantity provisions 

b. Should the system of excused periods be used 

only for continuous parameter monitoring 

provisions? 
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HON Compliance and Operating Parameters cont. 

Questions cont. 

3. Number and duration of excused periods: 

a. What units of time should be used to define 

excused periods? 

One 3-hour average 

An operating day 

Specify by point and control device used 

(whatever the monitoring frequency of that 

device) 

b. How should the excused periods be allocated? 

per control device 

per process unit 

per plant 

by number and type of control device (the 

item that must be monitored) 

c. How can EPA determine the number of excused 

excursions that equate to proper operation and 

maintenance? 

4. If a work practice approach to the parameter monitoring 

requirements is to be developed: 

a. What are appropriate follow-up actions? 

b. Should the required follow-up actions be listed 

specifically or generically? 

c. In what time must the actions be completed? 
P.11 

Emissions Averaging 

Issue: How should the quarterly emissions check on emissions 

be structured? 

EPA Idea: 

o Quarterly check on emissions based on a comparison of 

that quarter's credits and debits 

o Source allowed to have debits = (1.25 * credits) 

without a violation 

o Benefits of EPA system: 

Easy to calculate; and 

Imposes no absolute cap on emissions 

o Does have the illogical result of a chance for violations 

when the total volume of emissions is lower than the 

source had anticipated (and permitted) for the average 

CMA Idea: 

o Allow the source to set a "cap" for each quarter based 

on the strict application of MACT 

No violations unless actual emissions are higher 

than the "allowed" emissions level 

o Requires a calculation of "allowable emissions" 

o Sets absolute emission limits 

Resolution: 

o Propose EPA option, seeking comment on the quarterly 

factor (should the # be 1.25 or what?) 

o Also, Explain and seek comment on CMA's idea