P.1 

OAR Box 1672 

Prepped by Charmelle Mathews 

Document Number: 

ll-C-9 

Docket Number: 

A-98-13 

Printed 9/30/2008 11:01:00 AM Sheet 38 of 132 
FACSIMILE 

P.2 

A 98 13 

11-C- 1 

To: Del Billings 

Ted Cromwell 

John Dege 

Cliff Harvison 

Bob Hermanson 

Tom Hmiel 

Jack McClure 

Norman L. Morrow 

Brian Neville 

Darrell Poff 

Karin Ritter 

U.S. DOT 

Chemical Manufacturers 

Association (CMA) 

Dupont 

National Tank Truck 

Carriers (NTTC) 

Amoco Oil Company 

BASF Corporation 

Shell Oil Company 

Exxon Chemical Americas 

Independent Liquid 

Terminals Assoc. (ILTA) 

APCD of Jefferson 

County (Kentucky) 

American Petroleum 

Institute (API) 

fax (202) 366-8700 

fax (703) 741-6246 

fax (302) 774-1361 

fax (703) 684-5753 

fax (312) 616-0529 

fax (973) 426-2622 

fax (713) 241-2494 

fax (281) 588-2522 

fax (202) 466-4166 

fax (502) 574-5306 

fax (202) 682-8031 

From: Steve Shedd, U.S. Environmental Protection Agency 

Subject: First Industry Roundtable Meeting Scheduled for January 21,1998 

Date: January 9, 1998 

Comment: Please find attached the mailout for the first Roundtable Meeting for the Organic 

Liquids Distribution (non-Gasoline) source category. 

This facsimile comprises 8 pages including this page. 
P.3 

U .S ENVIRONMENTAL PROTECTION AGENCY 

OFFICE OF AIR QUALITY PLANNING & STANDARDS 

EMISSION STANDARDS DIVISION 

RESEARCH TRIANGLE PARK, NC 2771 1 

COVER SHEET 

DATE: 1/9/9 8 

TO: Persons intereste d i n the development of th e Organic Liquids 

Distributio n (non-Gasoline) NESHAP: Presumptive MACT (P-MACT) Phase 

FROM: Stev e Shedd 

OFFICE: OAQPS (MD-13) 

VOICE PHONE: 919-541-5397 

FAX NUMBER: 919-541-0246 

e-mail: shedd.Steve® 

epamail.epa.gov 

MESSAGE: 

RE: Organic Liquids Distributio n (non-Gasoline ) NESHAP 

Development(Presumptive MACT) 

January 21 , 1998; 

First Roundtable Meeting; 

EPA, RTP, NC 

The Meeting is scheduled to start at 9:00 a.m., and end at noon. 

The meeting place is the EPA Environmental Research Center (ERC) 

Building (very large building located in Research Triangle Park 

(RTP), at the intersection of Alexander Drive & NC 54)-- Classroom 

No. 2. (See enclosed map.) The Airport is Raleigh/Durham (RDU). 

This is an open meeting, but space is limited so attendees should 

contact Greg LaFlam at PES, Inc. at (919) 941-0333, fax (919) 941-

0234, or e-mail: glaflam@rtp.pes.com, as soon as possible stating 

the number in their party and whether they wish to make a 

presentation. We also need to be advised in advance of any required 

visual presentation equipment. 

A cafeteria is available in the building for early arrivals, break 

periods, and lunchtime. Attached to this cover sheet is a draft 

agenda, statement of goals of the meeting, a map of the immediate 

area, and a list of RTP area hotels. 

We welcome all participants and look forward to a productive 

interchange of ideas on this rule development. 

Page 1 of 7 (including cover sheet) 

•2-
P.4 

U.S. EPA - ORGANIC LIQUIDS DISTRIBUTION RULE 

1ST ROUNDTABLE MEETING 

EPA Environmental Research Center (ERC Building), Classroom 2 

Research Triangle Park, North Carolina 

January 21,1997 

Agenda 

9:00-9:15 Introductions 

Review of Meeting Objectives and Agenda 

U.S. EPA 

9:15-10:15 EPA Presentation 

Questions/Discussion 

U.S. EPA/PES 

All Participants 

10:15-11:00 - Industry Presentations (as requested) Industry Participants 

11:00-12:00 Discussion of Initial Issues/Data Needs 

• Next Steps 

• Action Items 

U.S. EPA/PES 

All Participants 

12:00 Meeting Adjourn 

3 
P.5 

U.S. EPA - ORGANIC LIQUIDS DISTRIBUTION NESHAP 

1ST ROUNDTABLE MEETING 

U.S. EPA ERC Building, RTP, North Carolina 

January 21,1998 (9:00 a.m.) 

Purpose: To bring together EPA and industry stakeholders to work together in the 

development of a Federal hazardous air pollutant rule for the organic liquids 

distribution (non-gasoline) industry. 

Goals: The EPA has three fundamental goals for this meeting: 

(1) To review the presumptive MACT (P-MACT) development process with 

industry, and discuss issues of concern to all parties. 

(2) To present a summary ofthe information the Agency has acquired so far, 

and to solicit additional information and data from industry. This 

information may include: 

(a) Industry Profile: number and locations of facilities, capacities, 

process descriptions, types of liquids handled, and an identification 

of facilities that are major sources of air pollution. 

(b) Emissions Characterization: HAP emission points and sources of 

fugitive emissions (e.g., component leaks); emission factors and 

losses from various processes (e.g., storage, transfer, waste 

treatment, etc.). 

(c) Emission Controls: air pollution control technologies, pollution 

prevention techniques, and control device performance. 

(3) To coordinate regulatory development efforts and scheduling with 

industry representatives, and to discuss potential data sources and action 

items for participants. 

The attached agenda presents the general topics that will be covered. We look forward to 

an informative and productive meeting. 

4 
P.6 

Directions, to EPA Environmental Research Center http://epawww.epa.gov/rtpww/campus/map_dir/to_erc.htm 

Directions to EPA Environmental Research 

Center 

-j*__fS » • ** * 2\ t * * \ 4 * * 

** _j. •-*• * ~**~* * " 

4>4> * 

S • v 

* *• * 

t 3 

«f£&d—-A 

From Raleigh, Raleigh-Durham International Airport, and Points 

East via Interstate 40 

Take Interstate 40 West to Exit 279A, "Durham Freeway (NC Highway 147) South". (The sign prior to 

the exit says "To Alexander Drive".) Take exit, which will put you on the Durham Freeway, and continue 

until you reach a traffic light at the "T" intersection with Alexander Drive. Turn right onto Alexander 

Drive. Go to next traffic light, which is N.C. Highway 54. The ERC is the very large brick building on the 

opposite corner. Cross N.C. 54 and immediately turn left into the parking lot. 

From Chapel Hill and Points West via Interstate 40 

Take Interstate 40 East to Exit 279A, "Durham Freeway (or N.C. 147) South". (The sign prior to the exit 

says "To Alexander Drive".) Take exit, which will put you on the Durham Freeway, and continue until 

you reach a traffic light at the "T" intersection with Alexander Drive. Turn right onto Alexander Drive. 

Go to next traffic light, which is N.C. Highway 54. The ERC is the very large brick building on the 

opposite corner. Cross N.C. 54 and immediately turn left into the parking lot. 

From Downtown Durham via Durham Freeway 

Take Durham Freeway (NC Highway 147) South toward Research Triangle Park. Continue until you 

reach a traffic light at the "T" intersection with Alexander Drive. Turn right onto Alexander Drive. Go to 

next traffic light, which is N.C. Highway 54. The ERC is the very large brick building on the opposite 

corner. Cross N.C. 54 and immediately turn left into the parking lot. 

£ j Return to RTP Wide Web Home Page 

lof2 

5 

1/5/98 8:44 AM 
P.7 

EPA and Related Facilities 

in the Research Triangle Park 

N 

t 

Route 14? 

G»--teOr 

?• CMIHI m 

140 

EPA 

ENVIRONMENTAL 

RESEARCH 

CENTER 

Te IUl«lgit, 

ROU Airport 

itmtt«•_•«'AUemr 

FROM DURHAM: Route 147 "Freeway" South to Alexander Drive. Right on Alexander, past Cornwallis. 

* AdmuVAnnex. 4201 and 4501 Buildings in "Research Commons" on left before 

1-40 overpass. 

* ERC Building on rightjust after 1-40 overpass. 

FROM RALEIGH OR CHAPEL HILL: 

1-40 to exit 279-A (Route 147. Freeway South to Alexander Drive). At "T" intersection, 

turn right on Alexander, cross NC54 at light 

* ERC Building is first drive on left. 

* Admin/Annex. 4201 and 4501 Buildings in "Research Commons" on rightjust 

after 1-40 overpass. 

Catawba Building on NC54 between Daw and Alexander Drive. 

6 

m 

I 
P.8 

RTP Area Hotels 

The following is a list of hotels in close proximity to EPA's Research 

Triangle Park facilities and Raleigh-Durham International Airport. This 

service is provided to EP A-RTP personnel so that they may give hotel 

information to out-of-town business visitors. 

1. Best Western Hotel Crown Park 

4627 S. Miami Blvd., RTP 

(800) 528-1234 or (919) 941-6066 

2. Budgetel Inn 

1001 Aerial Center Parkway, Morrisville 

(800) 428-3438 or (919) 481-3600 

3. Courtyard by Marriott 

2001 Hospitality Court, Durham 

(800) 321-2211 or (919) 467-9444 

4. Doubletree Guest Suites 

2515 Meridian Parkway, Durham 

(800) 222-8733 or (919) 361-4660 

5. Fairfield Inn by Marriott 

4507 N.C. Highway 55, Durham 

(800) 228-2800 or (919) 361-2656 

6. Holiday Inn Raleigh-Durham Airport 

4810 New Page Road, RTP 

(800) 465-4329 or (919) 941-6000 

7. Innkeeper of Durham/RTP 

4433 N.C. Highway 55, Durham 

(919) 544-4579 

8. Marriott at RTP 

4700 Guardian Drive, RTP 

(800) 228-9290 or (919) 941-6200 

9. Meredith Suites at the Park 

1900 Meredith Drive, Durham 

(919)361-1234 

1 
P.9 

10. Omni Durham (Downtown, near Mutual Building) 

201 Foster Street, Durham 

(919) 683-6664 

11. Radisson Governors Inn 

Highway 54, RTP 

(800) 333-3333 or (919) 549-8631 

12. Red Roof Inn 

Interstate 40 and N.C. Highway 55, Durham 

(919)361-1950 

13. Sheraton Imperial Hotel and Convention Center 

Imperial Center, RTP 

(800) 325-3535 or (919) 941-5050 

NOTE: Please e-mail any recommendations for modification ofthe Area Hotel list to the RTP 

Wide Web's listings of commercial services to RTPWW-GROUP or rtpww@epamail.epa.gov. 

% 
P.10 

1/21/98 

PRESUMPTIVE MACT FOR 

ORGANIC LIQUIDS DISTRIBUTION 

(NON-GASOLINE) FACILITIES 

JANUARY 21,1998 

FIRST ROUNDTABLE MEETING 

WITH PROJECT WORK TEAM 

(PRELIMINARY INFORMATION) 

Waste and Chemical Processes Group 

U.S. Environmental Protection Agency 

Research Triangle Park, NC 

<\ 
P.11 

OVERVIEW 

Standards Development Process 

Presumptive MACT 

• MACT 

• Project Schedule 

Affected Sources 

• Definition of Source Category 

• Industry Profile 

Model Plants/Facilities 

Emissions and Controls 

• HAP Emissions 

• Control Techniques 

Current Control Levels (MACT Floors) 

Issues/Questions 

Next Steps 

2 

10 
P.12 

STANDARDS DEVELOPMENT 

PROCESS 
P.13 

PRESUMPTIVE MACT IS... 

[MACT = maximum achievable control technology] 

An estimate of what MACT would be, based on a 

review of currently available information 

Assists State and local agencies in making caseby-case MACT determinations 

Not a regulation - offered only for guidance and 

information 

A starting point for the MACT standard 

development process 

4 
P.14 

STATUTORY REQUIREMENTS 

Promulgation of national emission standards 

for hazardous air pollutants (NESHAP) for 

listed source categories required under §112(d) 

of the Clean Air Act 

Organic Liquids Distribution (Non-Gasoline) is 

a listed major source category under §112(c) 

Promulgation of standards is required by 

November 2000 

5 

\2> 
P.15 

STATUTORY REQUIREMENTS 

(2) 

"Major Source" means any stationary source or 

group of stationary sources located within a 

contiguous area and under common control that 

emits or has the potential to emit, considering 

controls, in the aggregate, 10 tons per year of any 

hazardous air pollutant (HAP) or 25 tons per year 

of any combination of HAP 

"Area Source" means any stationary HAP source 

that is not a major source 

"New Source" means a stationary source, the 

construction or reconstruction of which is 

commenced after the Administrator first proposes 

regulations under §112 establishing an emission 

standard applicable to such source 

"Existing Source" means any stationary source 

other than a new source 

4 
P.16 

STATUTORY REQUIREMENTS 

(3) 

Minimum level of standards ("MACT floor") 

• For existing sources, the standard shall be at 

least as stringent as the average emission 

limitation achieved by the best performing 12 

percent of existing sources, or, in the case of 

categories with less than 30 sources, the 

average emission limitation achieved by the 

best performing 5 sources 

• For new sources, the standard shall be at least 

as stringent as the emission control achieved 

in practice by the best controlled similar 

source 

7 

|5 
P.17 

PROJECT SCHEDULE 

(TENTATIVE DATES) 

Event Date 

Kickoff Meetings 

Plant Visits 

September 24-25,1997 

Dec. 1997 - Mar. 1998 

Initial Roundtable 

(Work Team) 

January 21,1998 

Second Roundtable March 20,1998 

(discuss draft P-MACT) 

Third Roundtable May 20,1998 

(review final P-MACT, 

if needed) 

Issue P-MACT Report June 1998 

Start Standards July 1998 

Development Process 

8 

ll* 
P.18 

AFFECTED SOURCES 

9 

n 
P.19 

HOW IS THE SOURCE CATEGORY 

DEFINED? 

Initial Source Category Description: 

Activities associated with the storage and distribution of 

organic liquids other than gasoline, at sites that serve as 

distribution points from which organic liquids may be 

obtained for further use and processing. For oil and 

gas production, includes only petroleum facilities that 

handle and distribute hydrocarbon liquids after the 

point of custody transfer. 

Facility Types May Include: 

• Pipeline facilities 

• Stand-alone terminals 

• Collocated terminals (e.g., associated with refineries or 

chemical plants) 

• Compounding/packaging plants 

10 
P.20 

Organic Liquids Distribution 

Facilities Industry 

CHEMICALS 

Chemical 

Manufacturing 

(SOCMI) 

Consumer 

(Retail) 

Packaging/Distribution 

Facility 

. 

Facilities using 

chemicals as 

feedstocks 

j_t 

Consumer 

(Retail) 

1 

Packaging/ 

Distribution 

Facility 

t 

PETROLEUM 

Domestic 

Oil/Gas 

Production 

Foreign 

Crude Oil 

Petrochemical 

Manufacturing 

J

1 Petroleum 

Refining 

i 

Consumer 

(Retail) 

Packaging/ 

Distribution 

Facility 

Intermediate Storage Facility 

11 

h 
INDUSTRY PROFILE-BASED ON SIC CODES 

Major Group Industry 

Group 

Number 

SIC 

Code" 

NAICS 

Equiv. 

Facility Type" Total No. of 

Establishments'* 

Size Distribution 

by No. of EmpIoyeesb 

<50 >50 >100 

PIPELINES 

46 . 

47 

49 

4610 

4780 

4920 

4612 

4613 

4619 

4789 

4922 

4923 

4924 

4925 

48611 

48691 

48699 

488999 

48621 

48621 

22121 

22121 

Pipelines, Except Natural GasPipelines, Except Natural Gas 

Crude Petroleum Pipelines 

Refined Petroleum Pipelines 

Pipelines, Not Elsewhere Classified 

Transportation Services 

Miscellaneous Services Incidental to 

Transportation 

Transp. Services, Not Elsewhere Classified 

Electric, Ga$> and Sanitary Services 

Gas Production and Distribution 

Natural Gas Transmission and Storage 

Natural Gas Transmission and 

Natural Gas Distribution 

Mixed, Manuf., or Liq. Pet. Gas 

838 

59 

2,349 

4,062 

93% 

100% 

92% 

93% 

4% 

5% 

7% 

3% 

3% 

7% 

12 
INDUSTRY PROFILE-BASED ON SIC CODES (CONTINUED) 

P 

Major Group Industry 

Group 

Number 

SIC 

Code" 

NAIC 

Code 

Facility Type" Total No. of 

Establishments'* 

Size Distribution 

by No. of Employees'* 

<50 >50 >100 

STAND-ALONE TERMIN.ALS 

42 

44 

51 

4220 

4490 

5160 

5170 

4226 

4491 

5169 

5171 

5172 

49319 

48831/2 

42269 

454311 

42272 

Motor Freight Transportation and 

Warehousing 

Public Warehousing and Storage 

Special Warehousing and Storage, Not 

Elsewhere Classified 

Water Transportation 

Services Incidental to Water Transportation 

Marine Cargo Handling 

Wholesale Trade—Nondurable Goods 

Chemicals and Allied Products 

Chemicals and Allied Products, Not 

Elsewhere Classified 

Petroleum and Petroleum Products 

Petroleum Bulk Stations and Terminals 

Petroleum & Petroleum Products 

Wholesalers, except Bulk Stations and 

Terminals 

1,479 

6,742 

854 

14,436 

10,695 

14,636 

10,562 

3,864 

93% 

95% 

78% 

97% 

97% 

97% 

97% 

97% 

4% 

2% 

10% 

2% 

2% 

2% 

3% 

2% 

3% 

3% 

12% 

1% 

1% 

1% 

<1% 

1% 

13 
INDUSTRY PROFILE-BASED ON SIC CODES (CONTINUED) 

;

j 

Major Group Industry 

Group 

Number 

SIC 

Code" 

NAICS 

Code 

Facility Type" Total No. of 

Establishments1* 

Size Distribution 

by No. of Employees'* 

<50 >50 >100 

COMPOUNDING AND PACKAGING FACILITIES 

29 

47 

2950 

2990 

4780 

2951 

2992 

4783 

324121 

324191 

488991 

Petroleum Refining and Related Industries 

Asphalt Paving and Roofing Materials 

Asphalt Paving Mixtures and Blocks 

Miscellaneous Products of Petroleum and 

Coal 

Lubricating Oils and Greases 

Transportatioa Service 

Miscellaneous Services Incidental to 

Transportation 

Packing and Crating 

1,322 

1,073 

458 

380 

2,349 

91% 

97% 

81% 

83% 

92% 

5% 

3% 

12% 

11% 

5% 

4% 

<1% 

7% 

6% 

: 

2% 

14 
INDUSTRY PROFILE-BASED ON SIC CODES (CONCLUDED) 

Major 

Group 

Industry 

Group 

Number 

SIC 

Code8 

Facility Type3 Total No. of 

Establishments1* 

Size Distribution 

by No. of 

Employees'1 

<50 >50 >100 

COLLOCATED DISTRIBUTION FACDLITIES (e.g., with chemical or petrochemical facilities) 

9 

• 

9 

• 

9 

• 

9 

• 

9 

• 

9 

• 

9 

• 

9 

• 

"Standard Industrial Classification Manual, 1987 (Office of Management and Budget) 

hCounty Business Patterns, 1995 (Bureau of the Census) 

15 
HOW IS THE SOURCE CATEGORY 

DEFINED? 

(2) 

Which processes and equipment would be covered? 

• All HAP emission sources at regulated facilities 

• Possible sources: 

- Storage tanks 

- Liquid transfer 

- truck 

- railcar 

- pipeline 

- marine vessel (covered by subpart Y) 

- Equipment leaks 

- Wastewater collection and treatment 

Which liquids? 

Synthetic organic HAP chemicals 

Petrochemicals 

Crude oil or other unrefined petroleum liquids 

Refined petroleum (non-gasoline) 

Other pure liquids or mixtures with HAP content 

16 
P.26 

TOP 20 ORGANIC HAP CHEMICALS 

BY VOLUME (1993-96)1 

Chemical Name 

Ethylene dichloride 

MTBE 

Vinyl chloride 

Methanol 

Styrene 

Ethyl benzene 

Formaldehyde 

Ethylene oxide 

p-Xylene 

Ethylene glycol 

Cumene 

Phenol 

1,3-Butadiene 

Acrylonitrile 

Vinyl Acetate 

Benzene 

Caprolactam 

Aniline 

Methylene chloride 

Phthalic anhydride 

Production (10 metric tons) 

7.2 

6.7 

6.5 

5.1 

5.0 

5.0 

3.7 

3.1 

2.8 

2.5 

2.4 

1.7 

1.6 

1.4 

1.3 

0.9 

0.7 

0.5 

0.5 

0.4 

Chemical & Engineering News, 1994-97. 

17 

^5 
P.27 

INDUSTRY PROFILE 

(2) 

Model Industry 

• Stand-Alone Organic Liquid Facilities 

(in ILTA Membership) 

Primary SIC codes: 4226,5169,5171 

• Primary States by Total Storage Capacity: 

State 

Texas 

Louisiana 

New Jersey 

California 

Illinois 

Capacity (barrels) 

55,582,440 

29,383,594 

29,252,303 

24,329,888 

9,881,577 

Range in number of storage tanks: 

1 to 420 + 

Percent of Total 

21% 

11% 

11% 

9% 

4% 

Range in total storage capacity of individual facilities: 

2,700 to 12,500,000 barrels 

Modes of transportation 

- marine vessel (tanker ship, barge) 

- tank truck 

- railcar 

- pipeline 

18 
P.28 

INDUSTRY PROFILE 

(3) 

Collocated Organic Liquid Facilities (e.g., associated 

with refineries or chemical plants) 

SIC codes? 

Pipeline Facilities 

Compounding/Packaging Facilities 

<Data gathering has commenced. All of these facilities 

potentially have four major emission sources: 

• storage 

• transfer operations 

• equipment leaks 

• wastewater> 

19 

nA 
EMISSIONS AND CONTROLS 

20 

S 
P.30 

EMISSION FACTORS 

Emissions Calculations 

- HAP content 

- Models/methods for estimating emissions 

- Parameters: volume, loading method, 

vapor pressure, etc.) 

HAP Content 

- pure compound (100% HAP) 

- see chemicals table, page 13 

- always stored at 100% strength? 

- mixtures (partial HAP content) 

- petroleum liquids 

- also diluted pure HAP chemicals? 

- need data (industry survey?) 

Organic Liquids with Partial HAP Content 

Stored 

Liquid 

Crude oil 

Gasoline 

Aviation 

gasoline 

Diesel fuel 

TVP 

(70°F) 

3-4 

4-8 

9 

• 

9 

• 

Annual Volume 

(Barrels/yr) 

9 

• 

9 

• 

9 

• 

9 

• 

HAP Content in Vapors 

Range 

9 

• 

9 

• 

9 

• 

9 

• 

Average 

9 

• 

9 

• 

9 

• 

9 

• 

21 

s 
P.31 

Stored 

Liquid 

Jet 

kerosene 

Other 

petroleum 

mixtures 

Other 

chemical 

mixtures 

Wastewater 

Others? 

TVP 

(70 °F) 

0.01 

9 

• 

9 

9 

• 

9 

• 

Annual Volume 

(Barrels/yr) 

9 

• 

9 

• 

9 

• 

9 

• 

9 

• 

HAP Content in Vapors 

Range 

9 

• 

9 

• 

9 

• 

9 

• 

9 

• 

Average 

9 

• 

? 

9 

• 

9 

9 

• 

Models and Methods 

- Storage tanks 

- AP-42, Section 7.1 (TANKS3 software) 

- Liquid transfer 

- AP-42, Section 5.2 (designed for 

petroleum products) 

- Equipment leaks 

- SOCMI factors 

- refinery factors 

- gasoline marketing facility factors 

- Wastewater air emissions 

- collection and treatment system model (Water 8) 

Facility Parameters (model industry) 

22 

3c 
P.32 

VAPOR PRESSURES OF SELECTED 

PETROCHEMICALS/PETROLEUM LIQUIDS 

True Vapor Pressure at 70 °F 

• • 

Hydrogen cyanide 

Ammonium hydroxide (28.8% 

Diethyl ether 

Gasoline, RVP 13 

Methylene chloride 

Gasoline, RVP 10 

Gasoline, RVP 7 

Diethylamine 

Crude Oil, RVP 5 

Chloroform 

Carbon Tetrachloride 

Jet Naphtha 

Benzene 

Acetonitrile 

Toluene 

Jet Kerosene 

#2 Fuel Oil 

#6 Fuel Oil 

solution) 

11.85 

10.76 

8.70 

8.3 

6.79 

6.2 

4.3 

3.87 

3.4 

3.19 

1.80 

1.6 

1.5 

1.4 

0.43 

0.011 

0.009 

0.00006 

23 

2.1 
P.33 

CONTROL TECHNIQUES 

Storage Tanks 

• Route vapors to control device 

• Floating roof seals and fitting controls 

Liquid Transfer/Loading 

• Vapor balancing 

• Route vapors to control device 

• Vapor-tight vessels (trucks, railcars) 

Equipment Leaks 

• Leak detection and repair program 

• Visual inspections 

Wastewater 

• Cover (eliminate exposure to atmosphere) 

• Treatment 

- oil-water separation 

- biological treatment 

- filtration (sand, carbon, etc.) 

24 

3^ 
P.34 

CURRENT CONTROL LEVELS 

Information on present levels of control is being 

obtained from: 

• Federal Rules 

Refinery NESHAP (subpart CC) 

Gasoline Distribution NESHAP (subpart R) 

Oil/Natural Gas Production/Transmission 

(subparts HH, HHH) 

Marine Vessel Loading NESHAP (subpart Y) 

Hazardous Organic NESHAP (HON) (subparts 

F, G, H, I) 

Miscellaneous Organic NESHAP (MON) 

Storage Vessel NESHAP (subpart WW) 

Oil-Water Separators (subpart VV) 

Benzene Storage and Transfer 

NSPS rules (Storage Tanks-subpart Kb, etc.) 

25 
P.35 

CURRENT CONTROL LEVELS 

(2) 

Industry Data 

• Plant visits 

• Survey responses 

- screen all facilities? 

- detailed survey: 

• to a limited number of facilities? 

• facility types? 

• types of liquids surveyed? 

• facilities covered by other MACT 

rules? 

• facility size (< 50% of 10/25 tpy HAP 

criteria)? 

- survey packaging and pipeline facilities 

separately? 

• Other information 

26 
P.36 

CURRENT CONTROL LEVELS 

(3) 

State/Local Rules (Examples) 

• Storage Vessels - California and Illinois rules 

among the most stringent 

tanks > 19,800 gallons, > 1.5 psia, or 

tanks > 39,630 gallons, > 0.5 psia: 

• floating roof or vapor control at 95% by weight 

any capacity, > 11 psia: 

• pressure tank and vapor control at 95% by weight 

tank cleaning: 

• liquid balancing to < 0.5 psia, or vapor control at 

90% 

• Transfer Operations -Texas, Alaska, and 

California rules among the most stringent 

• > 0.5 psia: vapor control at 90% (Texas) 

• > 1.5 psia: emission limit = 0.08 lb/1,000 gallons 

(lOmg/liter) (Alaska, California) 

• Wastewater Operations - Connecticut, Virginia, 

and Hawaii rules among the most stringent 

• > 200 gallons (VOC>1.5 psia)/day: vapor control 

at 95% (Connecticut, Virginia) 

• > 200 gallons (VOC>0.5 psia)/day: floating roof 

tank (Hawaii) 

27 
P.37 

ISSUES/QUESTIONS 

What facilities/processes should be included? 

What are the emission sources at compounding 

and packaging operations? 

Impact of the other Federal air rules 

• Do they adequately cover collocated distribution 

emission sources? 

• Which emission sources in presently regulated source 

categories should be considered? 

Impact on or from other media standards 

Water (Benzene Waste NSPS?) 

• Solid waste 

Others? 

28 

34 
ISSUES/QUESTIONS 

(2) 

Area Sources 

• Some are small businesses (how many?) 

• Must cover area sources if they present 

"a threat of adverse effects to human health 

or the environment" (§ 112(c)(3)) 

• Need to develop simple mechanisms to distinguish 

them from major sources (throughput, equipment 

size, etc.) 

Need additional information to define industry 

and complete industry profile 

Completion of data collection for MACT floor 

determination 

Other questions 

29 

31 
P.39 

NEXT STEPS 

Finalize and mail out industry survey (ICR) 

Additional site visits 

Develop draft P-MACT 

Second Roundtable Meeting (to receive comments 

on and discuss draft P-MACT) 

Work with Team to gather additional information 

30 
P.40 

U.S. EPA - ORGANIC LIQUIDS DISTRIBUTION RULE 

1ST ROUNDTABLE MEETING 

EPA Environmental Research Center (ERC Building), Classroom 2 

Research Triangle Park, North Carolina 

January 21,1997 

Agenda 

9:00-9:15 Introductions 

Review of Meeting Objectives and Agenda 

U.S. EPA 

9:15-10:15 EPA Presentation 

Questions/Discussion 

U.S. EPA/PES 

All Participants 

10:15-11:00 - Industry Presentations (as requested) Industry Participants 

11:00-12:00 Discussion of Initial Issues/Data Needs 

• Next Steps 

• Action Items 

U.S. EPA/PES 

All Participants 

12:00 Meeting Adjourn 

*b°\